1LAW OFFICE OF BILL KLOOS PC <br />OREGON LAND USE LAW <br />375 W. 4TH AVENUE, SUITE 204 <br />EUGENE, OR 97401 <br />TEL: 541.954.1260 <br />WEB: WWW.LANDUSEOREGON.COM <br /> <br />BILL KLOOS <br />BILLKLOOS@LANDUSEOREGON.COM <br /> <br /> <br />October 17, 2023 <br /> <br />Eugene Planning Commission <br />Lane County Planning Commission <br />c/o Elena Domingo <br />Eugene Planning Division <br />99 West 10th Avenue <br />Eugene, OR 97401 <br /> <br />Sent Via Email: RRSCPlan@eugene-or.gov <br /> <br />RE: RRSC Plan and Code Amendments <br />Eugene Files MA 23-5 and CA 23-3 & County File 509-PA23-05532 <br /> <br />Dear Commissioners: <br /> <br />This letter is filed on behalf of Kevin Journey and Action Rent-All & Events, which is a C-2 use. <br />It supplements my letter of October 6, based on my deeper look at the new plan/code and the <br />existing context. <br /> <br />I am coordinating this testimony with that of Bishow Consulting, who is taking a very close look <br />at the history of the refinement plan and decision making history in the neighborhood. <br /> <br />I would like to make the following summary points: <br /> <br />It would be a mistake in repealing the existing RR-SC Refinement Plan: <br /> <br />1. The proposal is to adopt the new refinement plan and repeal the existing refinement plan <br />from 1987. Adopting the new plan will have no impact on land use decisions; it is <br />explicitly not intended to be applied to site-specific land use decisions. Plan at 7. Further, <br />none of the “Land Use Polices” is stated in mandatory terms. Plan at 33. <br /> <br />2. Land use plans need to have certain elements under Statewide Planning Goal 2. The new <br />plan does not have them. Goal 2 requires in part: <br /> <br />“All land use plans shall include identification of issues and problems, inventories <br />and other factual information for each applicable statewide planning goal, <br />evaluation of alternative courses of action and ultimate policy choices, taking into <br />consideration social, economic, energy and environmental needs. The required <br />information shall be contained in the plan document or in supporting documents. <br />The plans, supporting documents and implementation ordinances shall be filed in <br />a public office or other place easily accessible to the public. The plans shall be the <br />basis for specific implementation measures. These measures shall be consistent <br />19