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A.-ft WPlanning Plan Amendment Completeness Review Form Planning Division Application File Name 1400 Cross Street (MA 20-1 / Z 20-1) Date: 02/12/2020 Applicant's Name: John Tokatly, 1400 Cross Street, LLC Zoning: 1-2 4 S-W/SR Representative's Name: Richard Satre, The Satre Group Reviewed by: Rodney Bohner, Associate Planner Phone: (541) 682-5437 E-mail: RBohner@eugene-or.gov General Type I Metro Plan Amendment / Zone Change Comments: METRO PLAN AMENDMENT Written Statement Required for all Applications Submitted Missing Incomplete N/A 1. Submitted a written statement demonstrating that the requested ❑ ❑ ® ❑ amendment satisfies the criteria found in EC 9.7730(3). Described any unchanged portions of the Metro Plan the amendment may affect. 2. Submitted a written statement demonstrating that the requested ❑ ❑ ® ❑ amendment satisfies the criteria found in EC 9.8424. Described any unchanged portions of the refinement plan the amendment may affect. Comments: 1. (a) Please revise the written statement to correctly discern the proposed Metro Plan diagram designations and proposed base zoning/overlay zoning. The written statement is not consistent and at times incorrectly identifies the Whiteaker Special Area Zone as an overlay zone. Base zones and overlay zones are identified at EC 9.1030 (Base zones) and EC 9.1040 (Overlay zones). 1. (b) Please address EC 9.7730(5)(a) and (b). The response does not address the relationship between the Metro Plan and the Whiteaker Plan nor does the response include findings related to plan designations. Zoning and plan designations are separate matters. 1. (c) Please revise statements regarding impacts to the Land Supply Study. The response appears to state that the mixed-use designation will both provide industrial employment land and simultaneously increase residential land availability. While housing could be built, the BLI combined mixed use plan designations with Commercial and Major Commercial, as one 'Commercial' designation category. No housing was assumed outright on vacant or partially vacant Commercial designations because our code does not require residential, or even require a minimum residential density for commercial zones. Industrial employment assumptions were applied to a combined 'Industrial' designation category. 1. (d) Please submit a statement consistent with the requirement under EC 9.7735(2). The response is conclusory. The response states that the proposed amendment does not make the Metro Plan internally inconsistent nor inconsistent with the Whiteaker Plan. The response provides no findings or evidence to support this conclusion. 1. (e) Please address the applicable Economic Development policies from the Envision Eugene Comprehensive Plan, which is available here: https://www.eugene-or.gov/848/Studies-and-Adopted-Plans To help clarify the situation, Envision Eugene is on ongoing update to replace the Metro Plan overtime. Currently, several chapters are complete, such as the Economic Development chapter. Therefore, the economic element of the Metro Plan is no longer applicable. In addition to any policies you address, please be sure to specifically address the following policies from Envision Eugene, which appear to be relevant to your project: 3.23 1. (f) Please address the applicable policies from the Metro Plan. The response relies on compliance with Envision Eugene, however, as described above at item #1(e), the Metro Plan is still applicable to the subject request. You may want to reference the Zone Change findings as a start. 2. The written statement does not explicitly state how or why consistency with the refinement plan only requires a refinement plan diagram amendment. Typically, applicants submit a concurrent refinement plan amendment Refinement Plan Amendment Completeness Review Form Page 1 of 3