HomeMy WebLinkAbout23_10_06 Batch1 TestimonyRiver Road-Santa Clara Neighborhood Plan
City File: MA 23 -5 , CA 23 -3
County File: 509-PA23 -05532
Testimony Batch 1
Batch Information Date Range
Batch Number Page Count Start End Submissions
1 31 09/12/2023 10/06/2023 11
From To Date Time Attachments
Michael Reader Testimony 10/6/2023 16:32 1
Steve Norris Testimony 10/6/2023 15:14 1
Bill Kloos Testimony 10/6/2023 13:31 1
Hillary Kittleson Testimony 10/5/2023 16:45
Bill Kloos on behalf of Kevin
Journey Testimony 10/3/2023 10:25 1
Teresa Bishow on behalf of
Action Rent All Testimony 10/3/2023 10:09 1
Ruby Matthews Testimony 10/2/2023 11:18
Bron Fain Testimony 10/2/2023 0:00
David Chubb Testimony 10/2/2023 0:00
Gordon and Connie Howard Testimony 9/28/2023 0:00
Beverly Barr Testimony 9/16/2023 20:33
Notes:
For reference, submissions are organized in reverse chronological order by the date they were included
in the record.
If viewing the digital PDF file, please note that bookmarks are included for navigating between each
submission.
From:Micheal Reeder
To:Eugene RR-SC Plan
Subject:RR/SC Plan and Code Amendments | Clemens Marina & Meeker Family Written Testimony
Date:Friday, October 6, 2023 4:33:32 PM
Attachments:image001.png
Reeder to PCs (Clemens Marina) 10-6-2023.pdf
[EXTERNAL ]
Dear Ms. Domingo:
Please include the attached letter into the record for the Eugene and Lane County Planning
Commissioners for their consideration. Please include me and my clients onto the interested
parties list.
Sincerely,
Mike
Office: (541) 225-8777 | oregonlanduse.com
375 W. 4th Ave., Suite 205, Eugene, OR 97401
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From:steve norris
To:Eugene RR-SC Plan
Subject:Comment re: proposed RR/SC Neighborhood Plan
Date:Friday, October 6, 2023 3:14:48 PM
Attachments:Comment-proposedRRSCNeighborhoodPlan.pdf
Comment-proposedRRSCNeighborhoodPlan.pdf
[You don't often get email from steve_norris@hotmail.com. Learn why this is important at
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[EXTERNAL ]
Thank you.
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Planning Commissioners, re: proposed River Road/Santa Clara Neighborhood Plan 10/6/2023
Thank you for this opportunity to submit comment on the proposed RR/SC Neighborhood Plan. First and
foremost; I want to express my sincere appreciation and gratitude to so many of my dedicated neighbors, who
volunteered considerable amounts of their time and energy collaborating with each other and multiple agencies,
over many years, to produce the Plan. I worked with the group for a while in the early days but not so much the
last few years. I never lost my interest though, which is centered on “Land Use” and respectful, collaborative
“Community.”
River Road and Santa Clara offer plentiful opportunity for residential developers (e.g. large lots, developer-
friendly building code) as well as challenges (e.g. underdeveloped infrastructure, overlapping jurisdictions).
Unfortunately, those same opportunities and challenges, combined with current code, can result in negative
impacts to current residents. As you deliberate the proposed Neighborhood Plan and action items – and add
your own ideas - I submit the following example of a current residential infill-project for your consideration.
The residential infill project example is “Howard Meadows” (outlined in red, above) – a 3 acre subdivision (12
lots) currently under construction at the intersection of Howard Ave. and Lake Dr. - in River Road. Before
development, the site was a flat, grass field with a gradual slope from South to North. I encourage you all to pay
a site-visit to gain further perspective. The shaded lots are ‘City’ (annexed) and all the others are ‘County’
(unannexed) properties. All streets in the immediate area are ‘County.’ ‘Howard Meadows’ constructed an
extension of Lake Dr. down the middle of their site, which connects with Rosewood Ave. at the NE corner of
the site. I’ve zoomed out for this photo in order to include 48 residential lots surrounding the development –
because, it appears, 48 units is what’s being approved to be constructed at ‘Howard Meadows’ (twelve 2-story
4-plexes). Providing on-site parking for all 48 units is, apparently, not required and there are “No Parking” signs
along half the new section of Lake on site. As you can see, there are no streets immediately adjacent to
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‘Howard Meadows’ to absorb/accommodate any overflow parking – which leaves Howard Ave. (with its new
‘Safe Routes to School’ project starting soon) as the nearest parking option – unless parking arrangements can
be made with Howard Elementary or …? Commissioners are aware of the parking situations created when the
‘ECCO Apartments’ complex was constructed at River Road and Hatton Ave. – with overflow parking from the
units now clogging Evergreen and other surrounding local County streets.
Related Neighborhood Plan references and recommendations:
Goal 11: Support development that is well designed and economically, socially, and environmentally
sustainable.
Action Plan 11.1.1, “Revise the Neighborhood/Developer meeting process that requires developers to
meet with the River Road or Santa Clara neighborhoods at least one month prior to submitting a land
use application …”: I also suggest adding a City Planner to the required guest list – to see the site, to bridge
the developer/neighbor information gap, to bridge the City/County information gap and to definitively answer
code and related questions.
Action Plan 11.2.1, Minimize land use conflict by adding code requirements that adjoining low density
and higher-density residential land are designed to be more compatible, as well as between residential
and non-residential uses. Develop and adopt development standards that provide form and site
transitions such as sloped setbacks, balcony offsets, and buffering between properties zoned low-density
residential and denser development in adjacent multi-unit housing and commercial zones. Prohibit upper
story balconies on housing walls that abut R-1 rear yards unless the buildings are at least 50 feet from the
property line.”: I strongly suggest this action apply to any/all community residential infill projects.
Goal 14: Promote land use and development that protects and enhances neighborhood character.
Action Plan 14.1.1, Develop transitions between R-1 properties: I suggest difficult puzzles are the most
satisfying to solve and certainly worth the effort.
Action Plan 14.1.2, Increase minimum required parking standards when higher density development
abuts R-1 zoning and the adjacent streets (i.e., lanes) aren’t developed to Eugene’s local street standard
or higher to avoid spillover parking problems. Do periodic review as automobile usage changes. I suggest
this issue regarding residential infill and parking and prior-existing neighborhood conditions deserves some
serious discussion and expedited action.
Above are ‘before’ (left) and ‘current’ (right) photos of the NE corner of ‘Howard Meadows’ – where the new
City section of Lake now abuts the old County section of Rosewood Ave. This section of Rosewood Ave. is 12’
wide and classified as a Local Access Road (LAR). Neighbors who front Rosewood have always maintained the
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road and ROW to high standards. There is a natural stormwater swale running along both sides of Rosewood
(notice the culverts lower-right) which neighbors are also responsible for maintaining and protecting. The
yellow house is City (annexed) property.
The ‘Howard Meadows’ developer submitted and the City approved a site design that called for filling and
raising the northern end of the 3 acre site by at least three feet – raising serious neighbor concerns. Neighbors
had to be fully engaged with the City and the subdivision process to ensure bollards were installed and
Rosewood was protected from construction vehicles and dangerous increased two-way traffic. Neighbors’
stormwater concerns, based on the elevation change on the North end, were duly noted.
Related Plan references and recommendations: ‘Stormwater’ and ‘Transportation’ are addressed in the
proposed Neighborhood Plan but there are so many nuances to the mix of jurisdictions in RR/SC that it would
have been very difficult to cover all the possibilities and …
Both the ‘Howard Meadows’ and ‘ECCO Apartments” examples raise an important question; what rights/voice
do County residential property owners, who front and have maintained LAR’s for decades in RR/SC, have
when it comes to new developments that directly impact them?
Community
Above are two more current photos from ‘Howard Meadows’ … to illustrate the lack of on-site parking
and how long-established neighbors who border the site will be impacted.
The ‘Howard Meadows’ subdivision is an example of how current code can be applied to negate many
of the aspirational goals, the heart of Community, in the Neighborhood Plan: ‘respect’ ‘compatibility’
‘neighborhood character’ ‘quality of life’ … each a subjective discussion, with an eye to collaborative
problem-solving, worth having.
Thank you again for the opportunity to recognize the work and dedication of my awesome RR/SC
neighbors and for letting me add my 2-cents worth of context to your discussion. I trust you will give
every aspect of the proposed Neighborhood Plan the serious consideration it deserves and I look
forward to hearing your recommendations.
Sincerely,
Steve Norris, River Road
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From:Bill Kloos
To:Eugene RR-SC Plan
Cc:KLOOS Bill (SMTP); Teresa Bishow (teresa@bishowconsulting.com); Kevin Journey (jbhomes4@msn.com); Mike
Reeder (mreeder@oregonlanduse.com)
Subject:Testimony for Planning Commission
Date:Friday, October 6, 2023 1:32:31 PM
Attachments:Kloos Lttr PC 10.6.2023.pdf
[EXTERNAL ]
Please provide the attached letter to the Planning Commission.
Thanks.
Bill Kloos
Law Office of Bill Kloos PC
375 W. 4th Ave., Suite 204
Eugene, OR 97401
Phone: 541-954-1260
Email: Bill Kloos@LandUseOregon.com
Web: www.LandUseOregon.com
CONFIDENTIALITY NOTICE: The information contained in this email communication may
contain confidential information that is legally privileged. If you are not the intended recipient, or if
you have reason to believe that this message has been addressed to you in error, you are
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email and then delete the e-mail from your computer and do not print, copy or disclose it to
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LAW OFFICE OF BILL KLOOS PC
OREGON LAND USE LAW
375 W. 4TH AVENUE, SUITE 204
EUGENE, OR 97401
TEL: 541.954.1260
WEB: WWW.LANDUSEOREGON.COM
BILL KLOOS
BILLKLOOS@LANDUSEOREGON.COM
October 6, 2023
Eugene Planning Commission
Lane County Planning Commission
c/o Elena Domingo
Eugene Planning Division
99 West 10th Avenue
Eugene, OR 97401
Sent Via Email: RRSCPlan@eugene-or.gov
RE: RRSC Plan and Code Amendments
Eugene Files MA 23-5 and CA 23-3 & County File 509-PA23-05532
Dear Commissioners:
This letter is filed on behalf of Kevin Journey and Action Rent-All & Events. The latter is
among all the C-2 uses that are being cut in half with the current, proposed code amendments.
This letter raises questions about the refinement plan changes.
The current refinement plan, although a bit tatty around the edges due to age, has all of the
essential elements that the Metro Plan says a refinement plan should have. First, it makes the
Metro Plan more specific by adding detail that helps determine what the plan designation is for
specific parcels. Second, it has specific, robust, mandatory policies to be applied in making site-
specific land use decisions. In short, the current plan has good planning legs.
The plan proposed for adoption has neither. First, there is no land use plan; it is missing in
action. Likely it was not overlooked or accidently left on the cutting room floor. Why, for gosh
sakes, is the City proposing to drop the land use plan from a refinement plan? What is the
thinking? Second, the proposed plan has no binding policies in the land use element that would
apply in the context of a land use application. None. Just “should” and “encourage” and
“pursue” and “update” and “monitor” and so on. There are no ultimate policy choices to apply in
making land use decisions. This is a refinement plan in name only.
If this document does not contain either a land use plan diagram or mandatory policies for land
use decisions, is it really a refinement plan? What is it refining? Not the Metro Plan Diagram
because it does not refine that diagram. Not the Metro Plan plan text because it adopts no
binding land use policies. Maybe it should be labeled as something more generic – like “RR-SC
Visioning Statement.”
The emphasis in the Staff Report is on describing the new language being adopted, which all soft
stuff. The Commission needs to focus equally on the existing plan being consigned to the plan
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Eugene Planning Commission
October 6, 2023
Page 2
document dumpster. The dumping of the old needs to be justified just like the adopting of the
new. With the dumping of the old, all property owners are being stripped of the plan
designations shown in and the policies stated in the existing RRSC plan. The City needs to
justify, under the city and state standards for amending plans, all of the information in the
existing plan that is being abandoned, Here is a short, partial list of clear, directive mapping and
policy that is being dumped:
• The current plan is used to determine what the plan designation is for specific properties
when that cannot be determined by the Metro Plan Diagram alone. See, e.g. Shin Zone
Amendment Z 06-3, an application denied by the HO but approved by the Commission.
• The current plan is used to determine whether a zone change is consistent with plan
policies. See Shin decision above.
• The current plan makes policy statements about what areas should be the subject of city-
initiate plan amendments.
• The land use element of the plan states five residential policies that apply to land use
decisions. RRSC Plan at 2-14.
• The commercial/industrial element of the plan states six policies that apply in
determining where these uses should go (and not go) and how they should be regulated to
be good neighbors. RRSC Plan at 2-18
• The plan states mandatory policies for growth in the many identified subareas. RRSC
Plan at 2-24.
If the old plan is being thrown out as the new plan is adopted, where will the Director and the
HO and Commission turn for the clear guidance that is now provided in the current plan? Is it
efficient or good planning to cut decision makers adrift as this amendment will do?
Maybe the City could have both. Leave the existing RRSC Plan, with its maps and grit and
specificity, in place and put the new plan on top of it. The new plan is general and largely
content free in terms of mandatory language such that it might fit on top of the existing plan with
minimal conflict.
The Commission should consider recommending to staff that a map be added to the new plan
that makes the new plan parcel-specific. The text of the Metro Plan says: (1) The Metro Plan is
not parcel specific, yet. (2) The parcels on the boundary line of two plan designations are of
indeterminate plan designation. (3) The RLID parcel database is the official database for the
current Metro Plan Diagram. (4) The City is committed to getting to a 100% parcel-specific plan
diagram. Given all of the above, the City could add to the plan a diagram that shows the plan
designation in the RLID database for each parcel. That would refine the Metro Diagram in the
way that the Metro Plan text anticipates and would have great utility in decision making. There
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Eugene Planning Commission
October 6, 2023
Page 3
would no arguing about what the plan designation is for a parcel. Just look at the map. That
would save a lot of time, expense, and litigation at LUBA.
LUBA on a regular basis has to make the final call what the plan designation is for a unit of land
in Eugene or where the plan boundary is. It has repeatedly asked, in the body of its opinions,
why it has to do that – why can’t Eugene adopt a plan diagram that is parcel specific, like all the
other cities manage to do? This Commission asks the same question from time to time. It is time
to ask it again, but not accept the “we are working on it” answer. Here is an example of how the
city is not working on it, but rather moving in the opposite direction. That is, the City is
abandoning a refinement plan map that, although not fully parcel specific has proven useful in
answering the recurring question in Eugene --“Hey, what is my property plan designated?”
From the standpoint of a practitioner, leaving the current refinement plan in place is far
preferrable to pitching it in favor of the current proposal.
Sincerely,
Bill Kloos
Bill Kloos
Cc: clients
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From:Hillary Kittleson
To:Eugene RR-SC Plan
Cc:Bev at Home; Jolene Siemsen; Charles Kittleson
Subject:Joint Hearing on River Road Santa Clara Neighborhood Plan
Date:Thursday, October 5, 2023 4:44:40 PM
You don't often get email from hillarykittleson@msn.com. Learn why this is important
[EXTERNAL ]
Members of the Eugene and Lane County Planning Commissions:
I have lived in the River Road neighborhood for over 30 years and served as a
member of SCRRPT, which worked hard to listen to our neighbors and then
lobby for the initiation of the neighbor plan. With an allocation of $100,000
from City Contingency funds, the formal planning process began. At that time,
the project time line called for completion in about two years. That was in
2017!
The triple squeeze of Covid and dramatic middle housing code changes at the
State and local level has caused years of delay and a reduced plan scope. So, I
am asking that the City mitigate the effects of the reduced scope by using one-
time funds to address concerns expressed by the Citizen Advisory Committee
and the board of the River Road Community Organization.
For me, this is a socio-economic equity issue that good land use planning can
address. In high SES neighborhoods, residents can have some assurance that
“highest and best use” will include basic amenities that contribute to a livable
neighborhood. In mixed SES areas, that assurance can only be given by the
government, through its policies and codes. The concerns expressed by the
RRCO board regarding potential loss of commercial properties is a good
example: …staff decision to eliminate the proposed Corridor Mixed Use zone
leave the majority of our current Commercial properties in the C-2 Community
Commercial Zone. This zone allows 100% of the properties in the zone to be
residential with no commercial at all. The eliminated Corridor Mixed Use zone
would have required commercial use on the ground floor. The economic study
included in Sera Architect’s River Road Corridor Study showed that economic
demand for housing is high and commercial use is low. Without regulation
requiring it or some kind of incentive to encourage it, the commercial facilities
we currently have may well be replaced by multi-family housing…
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My neighbors asked for walkable commercial areas back in listening sessions
we held in 2014 and continued to strongly support that concept in subsequent
citizen input events. To respond to that strong value, I am asking that you
recommend to the City Council use of one-time funds to create a
neighborhood-specific zone to protect the neighborhood and provide the
equity that it deserves. If City-wide changes are subsequently made that
protect all neighborhoods, the zone could be eliminated.
One-time funds could also be used to address the River Road Corridor issue
cited by the CAC and RRCO board and the parking issue cited by the RRCO
board.
In a time of constrained resources for ongoing services, the City has an
opportunity to strengthen the neighborhood plan by using one-time resources.
This approach will have far-reaching positive results, a great investment of City
funds and will keep faith with the two neighborhoods who have worked so long
and hard to develop this plan.
Sincerely,
Hillary Kittleson
995 Elkay Drive
Eugene, OR 97404
This testimony endorsed by:
Bev Barr, SCCRPT Member, Working Group Member
1275 Betty Lane
Eugene, OR 97404
Jolene Simpson, Working Group Member
190 Hawthorne Ave.
Eugene, OR 97404
Charles Kittleson
995 Elkay Drive
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Eugene, OR 97404
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From:Bill Kloos
To:Eugene RR-SC Plan
Cc:KLOOS Bill (SMTP); Teresa Bishow (teresa@bishowconsulting.com); Kevin Journey (jbhomes4@msn.com)
Subject:RRSC Testimony to PC on behalf of Kevin Journey
Date:Tuesday, October 3, 2023 10:24:31 AM
Attachments:Kloos Lttr to PC 10.3.2023.pdf
You don't often get email from billkloos@landuseoregon.com. Learn why this is important
[EXTERNAL ]
Elena –
Please add this letter to the record.
Thank you.
Bill Kloos
Law Office of Bill Kloos PC
375 W. 4th Ave., Suite 204
Eugene, OR 97401
Phone: 541-954-1260
Email: Bill Kloos@LandUseOregon.com
Web: www.LandUseOregon.com
CONFIDENTIALITY NOTICE: The information contained in this email communication may
contain confidential information that is legally privileged. If you are not the intended recipient, or if
you have reason to believe that this message has been addressed to you in error, you are
hereby notified that your receipt of this email was not intended by the sender and any disclosure,
copying, distribution or the taking of any action in reliance on the contents of this information
except its direct delivery to the intended recipient is strictly prohibited. If you have received this
email in error, please notify me immediately by telephone at the numbers listed above or by
email and then delete the e-mail from your computer and do not print, copy or disclose it to
anyone else. Thank you.
16
LAW OFFICE OF BILL KLOOS PC
OREGON LAND USE LAW
375 W. 4TH AVENUE, SUITE 204
EUGENE, OR 97401
TEL: 541.954.1260
WEB: WWW.LANDUSEOREGON.COM
BILL KLOOS
BILLKLOOS@LANDUSEOREGON.COM
October 3, 2023
Eugene Planning Commission
Lane County Planning Commission
c/o Elena Domingo Via Email only: RRSCPlan@eugene-or.gov
Eugene Planning Division
99 West 10th Ave.
Eugene, OR 97401
Re: RRSC Plan and Code Amendments (Eugene File AC 23-3)
Dear Commissioners:
I represent Action Rent-All & Events and Kevin Journey. They have very substantial
investments in C-2 property at 121, 141 and 151 River Avenue.
You will have more detailed testimony from Bishow Consulting explaining why the proposed
code amendments to C-2 accompanying the new RRSC neighborhood plan will be devastating to
the business and the owner. Cutting the C-2 density in half is not good policy for the RRSC area
or for the City at large, which will lose capacity of economic growth, jobs and housing.
Please extend the open record period in conjunction with your October 17 hearing, which will
allow more C-2 owners to weigh in on the merits of this proposal.
Also, please add my name to the list of persons entitled to written notice of the final decision.
Sincerely,
Bill Kloos
Bill Kloos
Cc: Bishow Consulting
Client
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From:Teresa Bishow
To:Eugene RR-SC Plan; DOMINGO Elena M
Cc:Kevin Journey (jbhomes4@msn.com); ActionRentAllEvents@gmail.com; KLOOS Bill (SMTP); Teresa Bishow
Subject:RRSC Plan Code Amendments (CA 23-3) - Action Rent-All Testimony
Date:Tuesday, October 3, 2023 10:08:38 AM
Attachments:Action Rent-All Testimony PC 2023 10 03.pdf
Some people who received this message don't often get email from teresa@bishowconsulting.com. Learn why thisis important
[EXTERNAL ]
Hi,
On behalf of Action Rent-All & Events, please accept the attached public testimony concerning draft
code amendments for the RRSC Plan Area.
Thanks for your consideration,
Teresa
Teresa Bishow, AICP
Bishow Consulting LLC
375 West 4th Ave, Suite 204
P.O. Box 50721
Eugene, OR 97405
541-514-1029
www.bishowconsulting.com
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PLANNING & DEVELOPMENT SERVICES
375 West 4th Ave., Ste 204
P.O. Box 50721
Eugene, OR 97405
541-514-1029
teresa@bishowconsulting.com
October 3, 2023
Eugene Planning Commission
Lane County Planning Commission
c/o Elena Domingo
Eugene Planning Division
99 West 10th Avenue
Eugene, OR 97401
Sent Via E-mail: RRSCPlan@eugene-or.gov
RE: RRSC PLAN CODE AMENDMENTS (Eugene File CA 23-3)
This letter is written on behalf of my client – Action Rent-All & Events. Established in
the mid-1960’s, the local business is located at 121 River Avenue. About 7 years ago,
the business was acquired by Lora Journey and significant financial investments were
made to sustain and grow the business onto adjacent property at 141 and 151 River
Avenue.
Action Rent-All & Events objects to the draft code amendments to the C-2 zone to:
1)Prohibit certain uses including “Equipment, Heavy, Rental/Sales/Service –
includes truck and tractor sales”.
2)Decrease the maximum building height from 120 feet to 60 feet.
3)Increase the percent of street facing facades of buildings being within the
maximum front yard setback from 25% to 80%.
4)Increase restrictions on blank walls from a maximum of 100 linear feet for
large commercial buildings to a maximum of 20 linear feet for all new
buildings. Currently, EC 9.2173 provides standards for exterior walls and
windows that only apply to new commercial buildings with 25,000 square
feet or more of floor area.
Action Rent-All & Events is financially adversely impacted by the draft code
amendments. The business currently rents heavy equipment and prohibiting the use
will thrust the business into a non-conforming status. The revised C-2 standards will
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Action Rent-All & Events Page 2 of 5
Planning Commission Testimony October 3, 2023
also cause a financial hardship to due plans to expand the business on to two adjacent
lots.
According to EC 9.8065 Code Amendment Approval Criteria, a code amendment shall
be consistent with applicable statewide planning goals, comprehensive plan, and
adopted refinement plan.
The draft code amendments are NOT consistent with Statewide Planning Goals.
Goal 2: Land Use Planning – To establish a land use planning process and
policy framework as a basis for all decisions and actions related to use of
land and to assure an adequate factual basis for such decisions and
actions.
The Measure 56 public notice states that “The proposed changes in C-2 include limiting
building height, adding design standards, and prohibiting certain new auto-oriented
uses.”
There is no factual basis in the record establishing what determined the list of “auto-
oriented” uses being prohibited. The draft RRSC Plan states, “These [code]
amendments reflect community feedback and certain high priority actions in the Action
Plan.” A review of the community feedback during the preparation of the draft RRSC
Plan does not point to any specific concerns regarding heavy equipment rental uses or
why they are considered “auto-oriented” uses.
It is irrefutable that a fast-food restaurant with a drive-up window serves the motorist far
more than a business renting heavy equipment, selling boats, or providing storage for
household goods.
There is also insufficient factual basis for the draft code amendments to substantially
decrease the allowed building height or impose different design standards for C-2 zoned
properties in the RRSC Plan area. How do the draft code amendments for C -2 impact
the projected commercial land needed to accommodate employment growth? What is
the factual basis for amending the city-wide C-2 standards to create special provisions
only applicable to the RRSC Plan Area?
Goal 9: Economic Development- To provide adequate opportunities
throughout the state for a variety of economic activities vital to the health,
welfare, and prosperity of Oregon’s citizens.
On commercially zoned land in the City of Eugene, the use “Equipment, Heavy,
Rental/Sale/Service” is only permitted in C-2, subject to a Conditional Use Permit
(CUP). The draft code amendment to prohibit this use on C -2 zoned properties in the
RRSC Plan Area will cause an immediate, adverse impact on my client and reduce the
variety of economic activities permitted in the neighborhood.
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Action Rent-All & Events Page 3 of 5
Planning Commission Testimony October 3, 2023
The draft code amendments are NOT consistent with the comprehensive plan and the
draft RRSC Plan.
The Metro Plan contains the applicable policy below in italics followed by information
demonstrating the draft code amendments are not consistent.
A.22 Expand opportunities for a mix of uses in newly developing areas and
existing neighborhoods through local zoning and development regulations.
The draft code amendments will narrow the range of uses permitted on C-2 zoned
property in the RRSC Plan Area and impose new development regulations. The
proposed changes will decrease the mix of uses in the area and create unnecessary
financial burdens on new commercial development.
The draft RRSC Plan contains the goals and policies below in italics followed by
information demonstrating the draft code amendments are not consistent.
Goal 1: Improve the neighborhood economy and empower local residents by
encouraging the growth and creation of local businesses.
Policy 1.1 Incentives for Local Businesses: Help neighborhood businesses
use existing local, regional, and state loan programs to support growth and
creation of neighborhood businesses.
Action Rent-All & Events is a locally owned business serving the River Road/Santa
Clara area for about 60 years. The business includes a catering service (e.g. tents and
other non-consumable party supplies), rental of light equipment (e.g. hand held power
tools) and rental of heavy equipment (e.g. rideable lawn mowers).
Of the total business revenue, about 30% of the catering service revenue and 90% of
the equipment rental is from customers living in the River Road/Santa Clara area.
The draft code amendment will prohibit the rental of heavy equipment and create new
standards both of which will cause the site to be in a non-conforming status. Banks and
other loan programs generally provide loans only to uses permitted and conforming with
local regulations.
Policy 1.2 Neighborhood Assets: Support business development that utilizes
neighborhood assets.
Action Rent-All & Events is conveniently located near River Road and Beltline, key
transportation corridors and neighborhood assets. Located on River Avenue along the
south side of Beltline, the business is suitable for the location and is not adversely
impacted by the traffic noise. The people living in River Road/Santa Clara provide a
strong customer base for the business. Due to the location and type of business, the
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Action Rent-All & Events Page 4 of 5
Planning Commission Testimony October 3, 2023
draft code amendments will substantially increase the cost of any new buildings as the
company looks to expand.
Policy 1.4 Regulatory Environment: Strive for a local regulatory environment
that is supportive of economic development in line with neighborhood vision
(such as creating small commercial nodes).
The business revenue from “heavy equipment” as defined in the Eugene code, is less
than 18% of the total revenue. As allowed in EC 9.2170(8)(b), the large rental
equipment is located outdoors. The business believed the heavy equipment rental was
a permitted use in C-2 as it was accessory to the main use of the site for light
equipment rental and catering services.
The draft code amendment appears to shift the use from “Accessory Use” or permitted
subject to a CUP, to a use prohibited in C-2 in the RRSC Plan Area. The draft code
amendment is not supportive of economic development.
Goal 11: Support development that is well designed and economically, socially,
and environmentally sustainable.
Policy 11.2. Well Designed Built Environment: Update design standards
through legislative updates to local land use regulations so that they provide for
gradual transitions between different uses and scales and incorporate pedestrian
scale design through building design, size, scale, and site layout requirements.
According to Ellen MacArthur Foundation, a circular economy is “a systemic approach
to economic development designed to benefit businesses, society, and the
environment. In contrast to the take-make-waste linear model, a circular economy is
regenerative by design and aims to gradually decouple growth from the consumption of
finite resources.” It is based on designing out waste and pollution while keeping
products and materials in use. The rental industry increases the longevity of equipment
and materials thus having a positive impact on the circular economy. Rental companies
often have other environmental efficiencies such as improved transportation and
logistics.
Increasingly community members are looking for ways to buy less consumable products
and decrease impacts to the environment. Action Rent-All & Events provides a
sustainable business model to help protect the environment by providing: 1) Shared
use, 2) Repairability, 3) Resource use, 4) Reusability, and 5) Recyclability.
In closing, the north side of River Avenue, east of River Road and south of Beltline,
consists of a mix of land uses and combination of C -2 and I-2 zoning. We hope the
Planning Commission will carefully consider our request not to amend the C -2 zoning to
impose special standards for RRSC Plan Area or remove the north side of River
Avenue from the geographic area subject to the new provisions.
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Action Rent-All & Events Page 5 of 5
Planning Commission Testimony October 3, 2023
Sincerely,
Teresa Bishow
Teresa Bishow, AICP
cc: Client
Bill Kloos
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From:Ruby Matthews
To:Eugene RR-SC Plan
Subject:Please approve the RRSC Plan !
Date:Monday, October 2, 2023 11:18:01 AM
[You don't often get email from rubyisawitch@icloud.com. Learn why this is important at
https://aka.ms/LearnAboutSenderIdentification ]
[EXTERNAL ]
I am so impressed with the way information was gathered and every effort was made to include all members of the
RRSC community in the process and formulation of this plan. Untold number of community volunteer hours has
added up to an excellent, environmentally responsible and solutions oriented vision for a more livable, connected,
and vibrant community. I am grateful to live in a place where so many caring people are willing to give of their time
and talents to create a better home for us all. I hope you will approve this blueprint for meeting the challenges ahead;
equity and resilience are built into the plan.
Sincerely,
Ruby Matthews
3050 Memory Lane
Santa Clara
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From:bkb@epud.net
To:Eugene RR-SC Plan
Subject:River Road-Santa Clara Neighborhood Plan
Date:Saturday, September 16, 2023 8:33:15 PM
You don't often get email from bkb@epud.net. Learn why this is important
[EXTERNAL ]
Hello to the Planning Commissions:
Please adopt the RR-SC Neighborhood Plan as quickly as you can! Tremendous time and years of
effort have been spent on this project. I believe that it is now as good as it can get. By adopting this
Plan, you will affirm the efforts of hundreds of citizens and staff members who have collectively
devoted hundreds if not thousands of hours in order to make our neighborhoods better and safer.
Now it is time to get going on the implementation. It cannot be soon enough. Please, let there be
no further delays.
Thank you for listening,
Beverly Barr
1275 Betty Ln
Eugene, OR 97404
bkb@epud.net
541-461-0688 land
541-543-9513 mobile
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