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<br />which are inconsistent with the functional classification of a transportation facility; <br />or <br />(d) Would reduce the performance standards ofthefacility below the minimum <br />acceptable level identified in the TSP <br /> <br />Due to the minor nature of these amendments, the amendments do not affect the provision of <br />safe, convenient and economic transportation systems and do not significantly affect any <br />transportation facilities. <br /> <br />In a May 27,2008 letter to the City, the Department of Land Conservation and Development <br />(DLCD) has asserted that the City must show how the imposition of building height transitions in <br />the South University neighborhood (EC 9.2751(3)(c)) is "consistent with the region's <br />development strategy required by OAR 660-012-0035(5)." The City interprets DLCD's assertion <br />to mean that the City is required to show the amendment is consistent with the performance <br />measures in TransPlan that were adopted in 2002 pursuant to OAR 660-012-0035(5). DLCD <br />specifically refers to the performance measure that calls for 23.3% of new dwelling units in <br />Eugene and Springfield to be to be in areas designated for nodal development by 2015. While a <br />portion of the South University neighborhood is identified in TransPlan as being part of a <br />"Potential Nodal Development Area," no portion of the South University neighborhood has <br />received the Nodal Development Area designation in the Metro Plan and no portion has been <br />rezoned to include the /ND Nodal Development overlay zone. <br /> <br />Similarly, DLCD raises a concern that the increase in parking requirements for new multi-family <br />developments in the West University and South University neighborhoods will encourage <br />automobile use in a nodal area. Like the South University neighborhood, a portion of the West <br />University neighborhood is identified in TransPlan as being part of a "Potential Nodal <br />Development Area," but no portion of the neighborhood has received the Nodal Development <br />Area designation in the Metro Plan and no portion has been rezoned to include the /ND Nodal <br />Development overlay zone. <br /> <br />It is not clear that any of the areas affected by the height and parking amendments will be <br />designated and zoned as nodal areas for purposes of the 2015 performance measure. The <br />transition requirement applies only to the R-3 Limited High Density Residential and R-4 High <br />Density Residential zoned land just south of the University, within the area bound by Hilyard <br />Street to the west, Agate Street to the east, E. 18th Avenue to the north and E. 20th Avenue to the <br />south. Further, the building heights in the R-3 and R-4 zones would be restricted to 35 feet only <br />for that portion of a building located within 160 feet from the abutting boundary of, or directly <br />across an alley from, land zoned R-1, and building heights in the R-4 zone would be restricted to <br />50 feet only for that portion of a building located within 175 feet of land zoned R-3, and to 75 <br />feet for a portion of a building greater than 175 feet and up to 225 feet from land zoned R-3. <br />DLCD has not identified a basis for concluding that the proposed height transitions will <br />unlawfully interfere with the region's ability to meet its 23.3% performance standard and the City <br />finds no such basis. Further, the City finds that the modest parking requirements are necessary to <br />address excessive demand for on-street parking resulting from the increase in multi-family <br />developments in the area and finds that the requirements do not conflict with any nodal policy, <br />standard or criterion. <br /> <br />Findings <br /> <br />4 <br />