The Employment Lands Supply Study 2012-2032 (ELSS) is included as Appendix B in the City's <br />comprehensive plan, Envision Eugene, and complies with the requirements of Goal 9 and the <br />corresponding Administrative Rule. <br />The ELSS classifies the subject properties as "developed commercial and industrial lands." See <br />Employment Land Supply (2012) Figure 5, map tile 11 of 18. Based on this classification, the <br />subject property was not included in the inventory of available or developable employment <br />lands within Eugene's Urban Growth Boundary. Therefore, while the subject property may have <br />some developable area, the proposed amendment to the Metro Plan will have no impact on the <br />City's adopted available or developable employment land capacity. <br />Further, OAR 660-009-010(4) includes specific requirements for changes in plan designation <br />that involve land in excess of two acres within an existing urban growth boundary from an <br />industrial use designation to a non-industrial use designation, or another employment use <br />designation to any other use designation. Goal 9 requires that the City provide for at least an <br />adequate supply of sites of suitable size, types, locations, and service level for a variety of <br />industrial and commercial uses consistent with Metro Plan Policies. Oregon Administrative Rule <br />660-009-000 et seq. (Division 9) establishes the applicability of Goal 9 rules. OAR 660-009- <br />0010(4) states: <br />For a post-acknowledgement plan amendment under OAR chapter 660, division 18, that <br />changes the plan designation of land in excess of two acres within an existing urban <br />growth boundary from an industrial use designation to a non-industrial use designation, <br />or another employment use designation to any other use designation, a city or county <br />must address all applicable planning requirements, and: <br />a) Demonstrate that the proposed amendment is consistent with its most recent <br />economic opportunities analysis and the parts of its acknowledged comprehensive <br />plan which address the requirements of this division; or <br />b) Amend its comprehensive plans to incorporate the proposed amendment, consistent <br />with the requirements of this division; or <br />c) Adopt a combination of the above, consistent with the requirements of this division. <br />The proposed Metro Plan Amendment involves a plan designation change of land in excess of <br />four acres from a Light-Medium Industrial land use to Mixed Use designation. For the purposes <br />of the City's ELSS, mixed use designations are grouped under the broad category of commercial <br />uses. Therefore, because the proposed amendment proposes changes to the plan designation <br />of land in excess of four acres from an industrial use to another employment use designation, <br />OAR 660-009-010(4) applies. <br />For the purpose of demonstrating consistency with the ELSS, it is important to discuss how the <br />ELSS categorizes the subject site and to review past measures the City has implemented to <br />increase employment development based on the ELSS findings. The ELSS divides forecasted <br />industrial employment growth into tax lot site sizes ranging from less than 10 acres or larger <br />Findings <br />MA-20-2 / RA 20-2 / Z-20-8 <br />