City of Eugene – Zone Change <br />April 23, 2026 <br />Page 8 of 8 <br /> <br /> <br /> <br />(B) Degrade the performance of an existing or planned transportation facility such that <br />it would not meet the performance standards identified in the TSP or <br />comprehensive plan; or <br />(C) Degrade the performance of an existing or planned transportation facility that is <br />otherwise projected to not meet the performance standards identified in the TSP or <br />comprehensive plan. <br /> <br />Finding: The proposed Zone Change results in no significant affect to existing or planned transportation <br />facilities, and it complies with the applicable OAR subsection (1), excerpted above. The City of Eugene <br />has an acknowledged Transportation System Plan (TSP) that was adopted in 2017. The TSP <br />methodology assumes development consistent with the Metro Plan land use designations. <br /> <br />As stated in the 2035 Eugene TSP, “[t]he needs assessment and resulting projects … that establish a <br />transportation system adequate to meet the identified local transportation needs are based upon the land <br />use designations established by the Metro Plan. Because the 2035 TSP is based on the Metro Plan land <br />use designations, any zone allowed within the land use designation is consistent with both the Metro Plan <br />and this 2035 TSP.” Per this explanatory text, the Applicant understands that the transportation demand <br />modeling methodology assumes that areas designated Commercial may develop with commercial uses <br />at an intensity that is consistent with the designation. The Commercial designation is implemented by the <br />C-2 Community Commercial zone or C-3 Major Commercial, which are more intense zones than the <br />proposed C-1 zone. Therefore, the TSP accounted for greater development intensity than is allowed in <br />the proposed C-1 zone. The proposed C-1 zone does not introduce a land use or trip generator that was <br />not anticipated by the TSP analysis, as would be the case in the more common application of the C-1 <br />zone on a non-commercial designated parcel. <br /> <br />The proposed Zone Change does not lead to a change in the functional classification of an existing or <br />planned transportation facility or change standards implementing a functional classification system. The <br />proposed Zone Change is not inconsistent with subcriteria (A) through (C) above because the TSP <br />anticipated the greater development intensity of a C-2 or C-3 zone that implements the Commercial <br />designation. The proposed Zone Change to the C-1 zone is of lesser development intensity than that <br />allowed by the Commercial designation, therefore, it does not significantly affect an existing or planned <br />transportation facility. <br /> <br />VI. Conclusion <br /> <br />Based on the information and findings contained in this written statement and supporting attachments, <br />the proposed Zone Change meets the criteria of approval contained in the Eugene Code. The applicant <br />requests that the Hearings Official approve the proposal as presented. Both the applicant and the <br />applicant's representative are available for questions, as necessary. <br /> <br />If you have any questions about the above application, please contact Zach Galloway or Kristen Taylor at <br />TBG Architects + Planners (541.687.1010). <br /> <br />Z:\PROJ\202602 135 Ayres Road\Corresp\Agency\Zone Change\202602-ZC-WritState.docx