Item B: Parks, Recreation and Open Space Comprehensive Plan

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ll. The Eugene Parks Refinement Plan's proposed park land acquisitions are inconsistent with the Metro Plan fmdings and policies. Appendix B, Table B-1, of the proposed parks refinement plan defines Eugene's Goal 8 Parks and Open Space Standards and Anticipated Need, and the subsequent impact on the local land supply. The two columns under Net Need identify the amount of additional land required within the current UGB to meet the anticipated park need - 307.42 acres to provide for the additional needs of current residents and 1,316.04 acres to provide for the needs of future residents - a total of 1,623.46 acres. The proposed project plan and list are not included in the refinement plan but are attached to these comments as Appendix B. All proposed land acquisitions are to be acquired in the next ten years - in other words, during the planning period covered by the current Metro Plan and Residential Land Study. The Metro Plan is the document providing the framework within which detailed refinement plans are prepared (Metro Plan Principals, page II-I). As noted above, refinement plans must be consistent with the Metro Plan. Section III-A ofthe Metro Plan, entitled "Residential Land Use and Housing Element", incorporates the findings and policies relating to Goal 10 Housing. The table on II-A-3 shows the amount of surplus low-density residentia1land within the UGB as 940 acres, medium density surplus of239 acres, and 60 acres of surplus high density residential, for a total residential land surplus of 1,238 acres. This is the surplus acreage in 1995 for both Eugene and Springfield. Those numbers do not take into account any loss of acreage due to subsequent plan amendments or legislative zone changes since 1995. Nor does it account for land developed since 1995. Eugene's Goal 5 impact on the metro area's residential land supply, which is currently before the Eugene city council for adoption, shows a low and high demand residential surplus as depicted in the table below (the background report for GoalS impacts on the land supplies are attached to these comments as Appendix A). Again, these land surpluses apply to all ofthe metro area, not simply Eugene. e UPP1Y III xcess 0 eman a ef san oa Residential Low Density Medium High Density Total Density Low Demand 1,054.04 244.78 32.51 1,331.33 Hi2h Demand 127.04 126.78 5.51 259.33 NtS I' E fD d ft PAPA dG 15 It is obvious from the Goal 5 background materials that there is an insufficient amount of land in all three residential categories to accommodate the needed park lands. The Goal 5 background analysis also indicates there are only 85 acres of surplus commercial land in the metro area (Appendix A-9). Industrial lands are typically considered incompatible with park land and thus parks are not a permitted use on industrial lands. In addition, use of industrial land for other uses other than limited 4