Eugene Planning Commission <br />October 17, 2023 <br />Page 2 <br /> <br />with and adequate to carry out the plans. Each plan and related implementation <br />measure shall be coordinated with the plans of affected governmental units.” <br /> <br />Planning staff should be able to identify each element for a “plan” as required by Goal 2. <br />On the surface of things, the new plan is missing some major elements. If the new plan <br />were a car, it would be missing the drive shaft. <br /> <br />3. Repealing the existing plan will have a significant impact on land use decisions because <br />the existing Plan Policies have determined the outcome of land use decisions for decades. <br />The plan has mandatory policies for specific areas of the neighborhood. See the Bishow <br />Consulting documentation of how the existing plan has been used in making decisions. <br /> <br />4. Repealing the existing plan will have a significant impact on land use decisions because <br />the Refinement Plan Maps in the existing plan have determined the outcome of land use <br />decisions for decades. The existing plan has detailed plan maps for specific areas of the <br />neighborhood. The existing plan makes the ambiguous Metro Plan Diagram specific, <br />such that the plan designation of parcels generally can be determined. See Bishow <br />Consulting documentation. <br /> <br />5. For many parcels in this neighborhood, the existing Refinement Plan Maps are the only <br />way to determine what the plan designation is for a specific parcel. Repealing those <br />maps will create ambiguity for many owners. They will no longer know what their plan <br />designation is because the Metro Plan Diagram is not parcel specific in many instances. <br /> <br />6. Losing certainty about plan designations with the repeal of the existing plan will increase <br />confusion, delay, controversy and litigation. Time spent arguing about and litigating <br />what the plan designation is delays development of and increases the cost of housing. <br />There are embarrassing examples of this Eugene. <br /> <br />7. The Metro Plan text says that the City has been moving toward a parcel-specific Metro <br />Plan Diagram since 1981 – just four decades. Every other City has one! Here, repeal of <br />the existing refinement plan would be a giant step in the wrong direction. <br /> <br />8. Repealing a refinement plan that helps identify the plan designation of specific parcels <br />without replacing it with something equivalent violates the state Needed Housing Statute, <br />ORS 197.307(4). That statute says the City may only adopt clear and objective standards <br />for housing. Repealing the more specific refinement plan maps and leaving owners with <br />only the ambiguous Metro Plan Diagram would not align with the mandate for clear and <br />objective standards for housing. It would be a dumbing down of the plan designation <br />information. <br /> <br />9. The Planning Director has not reviewed the effectiveness of the existing plan or <br />attempted to justify the repeal of the refinement plan maps pursuant to statewide planning <br />Goal 2. Goal 2 requires the City to justify the repeal of the existing plan and the adoption <br />of the new plan with an adequate factual basis. No justification for the repeal of the <br />20