Item 3: Ordinance Concerning Jefferson/Far West Plan Amendments

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is speculative at best and clearly is not something that used to demonstrate compliance with a Statewide Planning Goal. Thus while the calculations contained in the fmdings are interesting, because they are based on unsupported speculation they do not provide any meaningful indication of compliance with the Goal 1 0 requirement. Further as Eugene's Growth Management Policies, v,'ith their clear preference for infill over UGB expansion, were adopted after the .Inventor:y methodology.used in the 1999 Residential Land Inventory was established it can be argued that the methodology used in the next inventory will be different from that used in the last in'lentory particularly in regards to in-fill. The City of Eugene does not currently track: changes to the residential land inventory. Because it does not trackthe impact of park: development, natural resource and watershed protections, other zone changes, the actual density of new development and other similar activities on the residential land supply it is not possible to assess the full impact that the proposed density reduction would have on the buildable residential land supply. Specifically, itis not possible to detenrtine if this change would result in Eugene and the Metro Area having an inadequate residential land supply. This proposal could be the pro\rerbial straw that broke the camels back or not. We do not know because of a decision on tIle part of the CIty of Eugene not to track this matter. Thus in the final analysis we only actually knO\V that this proposal will reduce the number of d\,\reIling units that could be constructed ill the area. That information in and of itself does not show t~at the proposed Refinement plan a.mendment is in complianc.e with Goal 10. If an~ything it indicates a likelihood.that the proposal is not incompliance with Goal 10. Goal 12 T'ransportation Division 12 ofOregol1 Administrati\reRules Chapter 660 implements State Wide Planning Goal 12 (Transportation). One of the purposes for this part of the OARs is to direct tral1sportation plallliing in coordinatioll with land use plalming to ensure that changes to comprehensive plans are supported by adequate planned transportation facilities.[OAR 660-12-0000 (l)(i)] OAR 660- 12-0060 contains a re-quirement that \;vhen a la.nd use change signific,antly effects the transportation system that local governm,ent is to put in safeguards to insure that the land use is consistent with the function, capacity alId perfonnance of the s~ystenl. The exact language of tlns rule is: (1) Where an amendnlent to a functional plan, an ackno'Vvledged c,omprehenslve plan, or a land use regulatioll ~rould. significantly affect an existing or .planneed transportation facility, tIle, local go\,rernment shall put in place measures as provided in section (2). of this rule to assure that allowed.land uses are consistent ,vith.the identified function~ capacity, and performance standards (e.g. level of service, volume to c-apacity ratio, etc.) of the, facilit)l. A plan orlan,d use regulatioll amel1dment signjfi.carrtlyT affects a transportation facility if it w~ould: (a) Change the fullctionaJ classificatiol1 of an existing or planned transportation facilit)7 (exclusi\re of correction of map errors in all adopted plan); Hinkley 'restinlony on rvlA 06-5~ Ra 06-3 andCA 06-1 5 Deceluber 2006 Page 4 of 12 pages