Meeker Family/Clemens A/larnia <br />ATA 23-5/CA 23-3/509-PA23-05532 <br />March 2, 2024 4 <br />The plans shall be the basis for specific implementation measures. 'these <br />measures shall be consistent with and adequate to carry out the plans. <br />Each plan and related implementation measure shall be coordinated with <br />plans of affected governmental units." <br />The proposed code amendments are required to be coordinated -,with and be consistent <br />with the adopted land use plans, including the Metro Plan and the Envision Eugene Comprehensive <br />Plan. However, there is no factual basis for reducing the maximum building height of the C-2 <br />zone or imposing a blanket prohibition of RV/Boat & Watercraft/Motor Vehicle sales and <br />service in the C-2 zone in this area. The impacts to the City's buildable lands inventory have <br />not been addressed. <br />part: <br />The Envision Eugene Residential Land Supply Study (RLSS), Part 1, Page 12, states in <br />"Eugene has some additional land supply in the form of new housing <br />that will be added through redevelopment of developed residential and <br />commercial land." <br />The RLSS Table 7, Part V — Page 4, identifies 29 acres (in addition to "Downtown" <br />capacity) of Commercial land to be used for High Density Residential between the 2012 and <br />2032 planning period. Reducing the height of Commercial development from 120 feet to 60 <br />feet necessarily reduces the City's High Density Residential Inventory (as well as reducing the <br />impetus for actual High Density Residential development). Eliminating half of the <br />development potential for residential in the C-2 zone in the RR -SC area frustrates the City <br />Council's ultimate policy choice to grow up and not out and utilize Commercial property to <br />meet the demand of residential land. Had the City not counted some Commercial property, <br />which includes C-2 property in the RR -SC area, the City would have had to account for the <br />land deficiency in other ways, including possibly expanding the UGB for residential. <br />Terri Harding's November 14, 2023 memo, on page 4, seems to attempt to justify the <br />height reductions in regards to the Buildable Lands Inventory for Employment, but she failed <br />to address the impact that the height reduction would have on the Residential land supply <br />inventory. The City justified not expanding the urban growth boundary for residential lands, <br />in part, because the C-2 zone permits High-density housing. Lowering the allowed height for <br />potential housing by half in this area undercuts the assumptions used by the City to justify not <br />expanding the UGB for residential land. Where the Envision Eugene Comprehensive Plan <br />attempted to push development upwards rather than outward, the proposed code <br />amendments, if adopted, would do the opposite. The City has not provided an adequate factual <br />basis for the proposed code amendments. <br />Goal 9: Economic Development — <br />The statewide planning goal for economic development, Goal 9, states in relevant part: <br />Office phone: (541) 225-8777 375 W. 4th Ave., Suite 205 <br />mreeder@oregonlanduse.com Eugene, Oregon 97401 28 <br />oregonlanduse.com <br />