Eugene Planning Commission <br />October 17, 2023 <br />Page 3 <br /> <br />existing plan has been offered, and no facts have been provided as a basis to justify the <br />repeal. Likewise, no facts have been offered to adopt the new plan; nor has justification <br />been provided as to why the more detailed land use maps and existing plan’s land use <br />policies are being eliminated. <br /> <br />10. Because the existing plan has lots of detail in maps and text that applies to decisions, and <br />the new plan has no detail that applies to decisions, the Director should consider leaving <br />the existing plan in effect and adding the new plan on top of it. That way we will not lose <br />what we already have that is working, but we can also add the new plan that city planners <br />want. <br /> <br />Proposed changes to the zoning code for C-2 are drastic, parochial, and unjustified: <br /> <br />1. The amendments delete from the C-2 zone six major commercial uses that are needed by <br />residents of the RRSC neighborhood, including the Action Rent-All use. This prohibition <br />is not justified in either the existing plan or the new plan. It pushes these kinds of uses <br />into other citizens’ neighborhoods. The equity of that is not justified in either the existing <br />plan or the new plan. <br /> <br />2. The amendments reduce the development density in C-2 by about half by cutting the <br />allowed height in half. This reduction in commercial capacity is not justified in the plan. <br />When the City reduces its capacity for economic growth it has an obligation under <br />Statewide Planning Goals 2 and 9 to demonstrate that it still has the capacity needed for <br />the planning period. Eugene plans don’t have much slack in the Goal 9 land inventory. <br />Planners will need supporting findings for the proposed shrinkage of capacity. The plan <br />does not yet reflect any thought about this. <br /> <br />3. The new restrictions for C-2 uses (including proposed transition and design standards for <br />commercial buildings) are so extensive as to amount to a new zone. It amounts to a C- <br />1.5 zone – somewhere between the C-1 and C-2. Or perhaps it should be adopted as a <br />Special Area Zone for this neighborhood. Restrictions this drastic should not be buried in <br />footnotes in the zoning code. <br /> <br />4. The new restrictions run afoul of Economic Policy 3.5 in the new Eugene Comprehensive <br />Plan: “Business retention and expansion. Facilitate the retention and growth of <br />existing businesses in the community.” Plan at ED-4. The code changes will make <br />Action Rent-All a nonconforming use, prohibit its expansion, and require it to move to a <br />different neighborhood to survive and grow. EC 9.1200-9.1245. <br /> <br />In summary, this new plan is not ready for adoption in the form proposed; it should not replace <br />the existing plan because they are not equivalents. The existing plan makes binding policy <br />statements and refines the Metro Plan Diagram. The new plan is more of a vision statement that <br />avoids binding policy choices and has no plan diagram. It is not a plan at all. <br /> <br />21