low, medium, and high-density residential land. Further, the Buildable Land Inventory (BLI) <br />recognized the subject site as developed and designated for industrial development. <br />In the initial findings, staff concluded that because the proposal does not include any lands <br />designated for residential use in the BLI, the proposed designation does not impact the <br />availability of residential lands for housing under Goal 10, nor does it impact the City's ability to <br />provide for housing needs in the future. Based on these findings, staff concludes Statewide <br />Planning Goal 10 does not apply. <br />As indicated in the written testimony, HLA and FHCO disagree. Staff understand their argument <br />as stating that any designation that allows for some level of housing will impact the mix of <br />residential dwellings within the City and therefore Statewide Planning Goal 10 is applicable. <br />Out of an abundance of caution, staff are amenable to contemplating HLA and FHCO's <br />argument. Indeed, the RLS recognizes that Eugene has some additional land supply in the form <br />of new housing that will be added through redevelopment of 'developed' commercial land. In <br />this case, the proposed amendments and zone change provide an opportunity to add 4.62 acres <br />of mixed use land with the ability to develop high-density residential uses that would not <br />otherwise be allowed under the existing industrial plan designation and zoning. This would <br />create additional housing opportunities which exceed HNA and BLI assumptions, consistent <br />with Goal 10. The proposed amendments do not leave the City with less than adequate <br />residential land supply in the types, locations, and affordability ranges affected. However, the <br />fact remains that the site is currently developed with existing industrial uses and no plans for <br />redevelopment of the site are under consideration at this time. <br />With these additional findings, staff conclude that the proposal meets the Goal 10 <br />requirements to the extent they could be construed as being applicable in this case. <br />GOAL 12: TRANSPORTATION PLANNING RULE <br />OAR 660-012-0060, the Transportation Planning Rule (TPR), implements Goal 12 for proposed <br />amendments to the Metro Plan. For any plan amendment or zone change, the requested <br />change must be consistent with the requirements of the TPR and the Eugene 2035 <br />Transportation System Plan (TSP). The applicant contracted Kelly Sandow, PE, of Sandow <br />Engineering, who prepared a TPR analysis. The applicant's TPR analysis is available in the <br />planning file. For ease of reference, the TPR analysis may also be viewed on the City's land use <br />application website: https://pdd.eugene-or.gov/LandUse/DocumentDetails?file=MA-20- <br />0002&id=2958205 <br />The analysis found that the requested plan amendment and zone change will not significantly <br />affect the operation of the studied intersections, in accordance with the TPR provisions located <br />at Oregon Administrative Rule (OAR) 660-012-0060. While staff's initial findings indicated <br />concurrence with the consultant's methodology and study, further consultation with Public <br />City of Eugene • 99 W. 10th Ave. • Eugene, OR 97401 • 541 -682-5481 • 541-682-5572 Fax <br />www.eugene-or.gov/planning <br />