Item B: Parks, Recreation and Open Space Comprehensive Plan

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mixing of office, commercial, and industrial uses is discouraged under the metro plan (see policies under Economic Element, IU.B). The land needed under the Eugene parks refinement plan would only be taken from vacant land available in Eugene's UGB or outside the metro UGB - any land surpluses in Springfield's UGB would presumably not be impacted by this refinement plan. The question that must then be addressed is how much surplus land does Eugene have available for parks? Can the 1,623.46 acres needed for parks under this refinement plan be accommodated using surplus land supplies within Eugene's current UGB? Ifnot, does the Eugene Refinement Plan meet the requirements of a parks master plan that would permit the establishment of local parks outside the UGB? The short answer to both questions is no. (The latter question will be discussed below.) The amount of land needed for park acquisition in the refinement plan is inconsistent with the Goal 9 and Goal 10 resources available in the Metro Plan. llI. The Eugene Parks Refmement Plan is inconsistent with the Metro Plan because the proposed park facilities are not included in the plan. The proposed plan will be an element of the comprehensive plan. As such it must include a plan for future recreation facilities. As discussed below, the requirement to include future facility projects in the plan is based on the nature of a comprehensive plan, state statutes and rules for preparing plans for parks, and in the1anguage of the Metro Plan itself. This draft fails to meet this requirement. Here the future parks projects have been excised from the plan and put in a second document, which is not intended to be part ofthe adopted plan, and will not be adopted through the land use process (Proposed projects and maps of anticipated acquisitions I developments are attached as Appendix B). Nature of "comprehensive plan" includes future projects and mapping: This refinement plan will be an element of the comprehensive plan for the Metro area. What constitutes a "comprehensive plan" is defined by statute. See ORS 197.015(5). By definition, a comprehensive plan must include "policy statements" and ''maps'' relating to proposed "recreational facilities." This draft includes a map of existing park facilities, but it does not show the location of proposed park projects. That map has been relegated to a second document not proposed to be a part of the plan. This draft describes the current park inventory, but it does not describe what specific projects will be added in the future. Again, that information has been put in a second document that will not be a part of the plan. The City has the infonnation needed to make this a comprehensive plan in the meaning of the statute, but it is proposing to exclude that information from the plan. Statutes and rules for park planning require future projects and mapping: This parks planning effort is subject to state statutes and LCDC rules for parks planning. The draft put forward by staff does not meet the minimum state requirements in many respects. 5