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<br />Plan contains a policy that specifically directs redesignation of the subject parcel, the same <br />findings made for all Downtown Plan policies can be transferred to this current redesignation <br />action. Staff does not concur with this argument. <br /> <br />The Downtown Plan has no land use diagram, and no redesignations or rezones were approved <br />concurrent with the Downtown Plan adoption. The Plan policy in question is: "Facilitate <br />downtown redevelopment by re-designating and rezoning underutilized properties, such as <br />surface parking lots, to a commercial land use designation and a commercial zone such as C-2 <br />or C-3" (Policy 2). Contrary to what the applicant suggests, this policy is not parcel-specific. ; It <br />applies to a number of unspecified properties downtown that are "underutilized," some of which <br />may also be surface parking lots at any given time. While this policy does apply to the subject <br />parcel, it did not have the effect of redesignating. the site. It is a general policy directing that <br />underutilized properties downtown should be redesignated, but does not itself redesignate those <br />properties. <br /> <br />The applicant notes that the Council findings for the Downtown Plan stated that "No change in <br />the functional classification of these streets is intended to result from this Plan..." and that "the <br />Plan does not, by its adoption, allow types or levels of land uses which would result in <br />inconsistencies with the functional classification ofa transportation facility..." (applicant's letter <br />to City July 24, 2006). However, those earlier findings do not obviate the requirement for the <br />current proposal to comply with OAR 660-012-0060(1), which requires a determination of <br />"significant effects" ort transportation facilities as a result of the current proposed plan <br />amendment. A change from a High Density Residential designation to a Commercial designation <br />can result in allowable uses that would increase the potential number of vehicle trips, with <br />potentially significant effects on transportation facilities. Although general Downtown Plan <br />policies were acknowledged as consistent with Statewide goals, that acknowledgement is <br />insufficient to conclude that the redesignation of a specific parcel without further analysis is <br />consistent with Statewide goals. Staff does not agree that 2004 Downtown Plan findings are <br />sufficient for the current proposal, and finds that additional information is needed to demonstrate <br />the proposal's consistency with Statewide Goal 12. <br /> <br />2) Although the subject parcel is within a Nodal Development area and Transit Oriented <br />Development overlay zone, and future development will meet the multi-modal goals of these <br />designations (applicant's revised findings August 21,2006), having those designations in itself is <br />not sufficient evidence that the land use change will have no significant effect on transportation <br />facilities. <br /> <br />3 ) CATS, an implementation plan, identifies future transit routes and contains policies that promote <br />an improved pedestrian system (applicant's revised findings August 21, 2006). However, these <br />strategies are not specific to the proposed amendment, and CATS does not evaluate whether the <br />allowable uses on the site would have a significant effect on a transportation facility, nor does it <br />identify specific measures that would mitigate identified impacts stemming from a plan <br />amendment pursuant to the requirements of OAR 660-012-0060(1). <br /> <br />To meet the requirements of OAR 660-012-0060 it is necessary to evaluate the proposed amendment <br />relative to criteria outlined in the TPR used to determine "significant effect." According to City of <br />Eugene Public Works Engineering, this requires data such as trip generation, trip distribution and <br />assignment (or similar data, depending on uses, traffic patterns, surrounding streets, etc., that describes <br />existing and anticipated traffic levels) and comparative analysis of each of these under existing plan <br /> <br /> <br />