Item 3: Ordinance Concerning Jefferson/Far West Plan Amendments

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(b) Change standards implementing a functional classification system; or (c) As measured at the end of the planning period identified in the adopted transportation system plan: ' (A) Allow land uses or levels of development that would result in types or levels of travel or access that are inconsistent with the functional classification of an existing or planned transportation. facility; (B) Reduce the performance of an existing or planned tranSportation facility below the minimutn acceptable performance standard identified in the TSP or comprehensive plan; or (C) Worsen the performance of an existing or planned transportation facility that is otherwise projected to perfonn below the mininlutn acceptable performance standard identified in the TSP or comprehensive plan. [OAR 660-12-0060 (1)] The proposed Refinement Plan Amendment is a change of the level of development of Area 15. The pertinent question is whether or not this change significantly affects a transportation facility. A Transportation Facility is defmed in the statute as being "any physical facility that moves or assist in the movement of people or goods..." [OAR 660-1 2-0020 (3 O)l Locally two governmental organizations operate a transportation facility in this part of Eugene, the City of Eugene and Lane Transit District. The findings do not include any assessment on the part of Lane Transit District as to the inlpact . of this Refinement Plan Amendment on their transportation facility... As a result these findings are incomplete and do not support a conclusion that the proposed amendment is in compliance with Goal 12. And while the findings do contain an assessment by Eugene Public Works Department that assessment is fatally flawed. Public Works staff was incorrect in their detemUnation that the proposed down zoning would not have an impact on Eugene's transportation system. particularly erroneous is their conclusion that by down zoning Area 15 the impact on the transportation system would be reduced. The flaw in their reasoning is in not recognizing the fact that by limiting development in Area 15 the City is displacing that development to other parts of Eugene and the Metro Area. It is clear that growth creates a demand for housing, a demand that the housing market responds to by.building more housing. Where that new development will occur we do not know ,only that it will happen and the residents of these new housing units will use the transportation system. Thus it is not possible to accurately detenninewhat impact this change will have on compliance with the requirements of the Transportation Planning Rule. However, an extremely rough estimation can be made. Area 15 is located near the center ofthe City, given land prices and currept developnlent patterns 'it is very likely that the displaced units will be developed further from the city center then Area 15, making it more likely that their reliance on the automobile will be greater then that of Area 15. Beyond that we do not know. Like Goal 1 0, because of a lack of data it is not possible to show compliance with TPR and as a llinkley Testimony on MA 06-5, Ra 06-3 and CA 06-1 .5 Dec,enlber 2006 Page 5 of 12 pages