Ord 2240 - Annex Factory Outlet
COUNCIL BILL NO. 1977
ORDINANCE NO. 2240
AN ORDINANCE APPROVING ANNEXATION 98-03; COMPREHENSIVE PLAN MAP
AMENDMENT 98-02; ZONE MAP AMENDMENT 98-04; FOR THE CONSTRUCTION
OF PHASES nAND m OF A FACfORY OUTLET CENTER; ATTACHING CERTAIN
CONDITIONS THERETO; AND DECLARING AN EMERGENCY.
WHEREAS, the Woodburn Comprehensive Plan and Zoning Map have established
certain land uses within the City of Woodburn's Urban Growth Boundary; and
WHEREAS, the Woodburn City Council has reviewed the record in Annexation Case
98-03, Comprehensive Plan Map 98-02, and Zone Map Amendment 98-04, and considered all
public testimony previously presented; NOW, THEREFORE,
THE CITY OF WOODBURN ORDAINS AS FOLLOWS:
Section 1. The land use applications before the City Council are as follows:
A. A request for annexation to the City of Woodburn of Tax Lot 101 consisting of
8.0 acres that is within the Woodburn Urban Growth Boundary.
B. A Comprehensive Plan Amendment from "High Density Residential" to
"Commercial" on Tax Lot 101.
C. A Zoning Map Amendment in conformance with the Woodburn Comprehensive
Plan Map designation from Urban Transition Farm to Commercial Retail.
Section 2. The applicant and owner of the Tax Lot 101 is Craig Realty Group-
Woodburn, LLC.
Section 3. The property which is subject to the land use applications is Tax Lot 101,
which is legally described in Attachment "A".
Section 4. The property legally described in Attachment" A" is annexed to the City of
Woodburn, based upon the findings and conclusions contained in Attachment "B."
Section 5. That the Comprehensive Plan Map amendment from "High Density
Residential" to "Commercial" and a Zoning Map Amendment from Urban Transition Farm
("UTF") to Commercial Retail ("CR") in conformance with the Comprehensive Plan Map
designation on the Tax Lot 101, which is legally described in Attachment "A", is approved based
Page 1 - Council Bill No. 1977
Ordinance No. 2240
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upon the findings and conclusions contained in Attachment "B."
Section 6. That the land use approvals herein are subject to the Conditions of Approval
contained in Attachment "B", which the City Council finds reasonable.
Section 7. This ordinance being necessary for the immediate preservation of the public
peace, health and safety, an emergency is declared to exist and this ordinance shall take effect
immediately upon passage by the Coun~l ~~oval by the Mayor.
Approved as to formfY1 rrv<r {~ ,- <t -, 1
City Attorney Date
~ ~
APPROVED: ~
RICHARD JENNING , MAYOR
Passed by the Council
Submitted to the Mayor
Approved by the Mayor
Filed in the Office Of~
ATIEST: I!/~
Mary T t, City Recorder
City of Woodburn, Oregon
July 26. 1999
July 27, 1999
Julv 27. 1999
July 27, 1999
Page 2 - Council Bill No. 1977
Ordinance No. 2240
ATTACHMENT 8
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BEFORE THE CITY COUNCIL FOR THE CITY OF WOODBURN, OREGON
In the Matter of a Request to approve an
Annexation of approximately 8.0 acres within
the Woodburn Urban Growth Boundary, to
Approve a Comprehensive Plan Map
Amendment from "High Density Residential"
to "Commercial" on 8.0 acres and to Approve
a Zoning Map Amendment in Conformance
with the Woodburn Comprehensive Plan Map
Designation of "Commercial" on 8.0 acres
from "Urban Transition Farm" to
"Commercial Retail"
I. APPLICA nON INFORMATION.
A. Application Description.
This application includes three (3) requests:
) FINDINGS OF FACT AND
) CONCLUSIONS OF LAW
)
) CITY OF WOODBURN FILE NOS.
) ANNEXA nON 98-03,
) COMPREHENSIVE PLAN MAP
) AMENDMENT 98-02 AND ZONING
) MAP AMENDMENT 98-04
)
(1) An annexation of Tax Lot 10 1 consisting of 8.0 acres that is within the
Woodburn Urban Growth Boundary ('UGB").
(2) A request for an amendment to the Woodburn Comprehensive Plan map from
"High Density Residential" to "Commercial" on Tax Lot 101
(3) A zoning map amendment in conformance with the requested Woodburn
Comprehensive Plan map designation from "Urban Transition Farm" to "Commercial Retail"
B. Site Description.
This site is located northwest of the intersection of State Highway 214/219 and
Interstate Highway 5. The application affects one lot of record, Tax Lot 101.
This site is flat with relatively little elevation change. Vegetation on the site consists of
native grass. Two drainage swales exist on the property.
Adjacent to the site on the south and east is the area of Woodburn Company Stores
Phase I approved in 1998. Tax Lot 101 will accommodate Woodburn Company Stores,
Phases II and III.
Page 1 - Findings and Conclusions
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ATTACHMENT ~
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C. Adiacent and On-Site Land Use. Comurehensive Plan Map and Zonine
Map Desienations and Utilities.
(1) Adjacent Comprehensive Plan Map Desi~nations.
Woodburn Company Stores Phase I to the south and east is designated "Commercial"
on the Woodburn Comprehensive Plan ("Plan") map. To the north of this site is the Urban
Growth Boundary which is designated Exclusive Farm Use ("EFU") on the Marion County
Comprehensive Plan map. Land directly to the west of Tax Lot 101 is within the City's Urban
Growth Boundary and is designated "High Density Residential" on the City's Plan map.
(2) Adjacent Zonine Map Desi~nations.
Adjacent property inside the City is zoned CR. Adjacent property outside of the City
but within the UGB is zoned UTF. Adjacent property outside of the UGB is zoned EFU.
(3) Land Use on Adjacent Properties.
The property to the north in Marion County is in farm use. The property to the east
within the Urban Growth Boundary contains a single-family residence. The property to the
south and east within the City limits is under development as Phase I of Woodburn Company
Stores.
(4) On-Site Land Use.
Tax Lot 101 is vacant.
(5) Utilities.
Public utilities (water, sanitary sewer and storm drainage) are available to the site's
boundaries. There will be no difficulty in connecting these existing public utilities and
providing public utilities to the site. The applicant is responsible for all on-site public facility
improvements.
The City of Woodburn ("City") found in 1992 and 1998 that it had sufficient water,
sanitary sewer and storm drainage capacity to serve the Phase I retail development.
ll. PROCEDURAL HISTORY.
The Applicant submitted this application on September 18, 1998. After timely notice
of a public hearing as required by the Woodburn Zoning Ordinance, the Woodburn Planning
Commission heard the application at a public hearing on February 11, 1999. No party
requested that the hearing be continued or that the record remain open. The Planning
Page 2 - Findings and Conclusions
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Commission tentatively approved the application at the conclusion of the public hearing. The
Planning Commission adopted a final order recommending that the Woodburn City Council
approve the application on February 25, 1999.
The City of Woodburn provided timely notice of the City Council's hearing on
May 10, 1999. The City had previously provided the required 45-day written notice to the
Oregon Department of Land Conservation and Development for this post-acknowledgment
amendment.
The Mayor opened the public hearing and read the announcements required by
ORS 197.763(5). No party objected to the City Council's jurisdiction.
The City Council heard testimony from the applicant and the Oregon Department of
Transportation. ODOT requested that the record remain open. However, the City Council
chose not to keep the record open pursuant to ORS 197.763(4)(b). This section provides Ifif
additional documents or evidence are provided by any party, the local government may allow a
continuance or leave the record open to allow the parties a reasonable opportunity to respond. If
The City Council finds that this statute provides it with the discretion as to whether to
keep the record open. In this case, the application has not changed since the February 11,
1999 Planning Commission hearing and ODOT had the opportunity to place a letter into the
record concerning the application. Moreover, ODOT did not object to the City Council's
denial of its request that the record remain open. The City Council also notes that ODOT did
not request an opportunity to rebut any additional evidence presented at the hearing but had a
full and fair opportunity to make its case during its testimony. The City Council placed no
time limits on ODOT's testimony.
The Mayor closed the public hearing. The City Council tentatively approved the
application with a motion by Councilor Figley seconded by Councilor Pugh on a vote of 5-1
(Councilor Bjelland opposed). The City Council directed the applicant's attorney to prepare
findings for review by city staff and adoption by the City Council at its meeting on June 14,
1999.
The City Council decided not to impose a condition, which was recommended by the
Planning Commission, that traffic impact be determined based upon an additional Traffic
Impact Study (TIS) to be paid for and obtained by the applicant. However, the City Council
added a condition that the City address the issue of required traffic impact mitigation at the
time of site plan review.
The applicant's attorney proposed fmdings and submitted them to the City Attorney.
After the findings were reviewed by city staff, certain revisions were made and condition IV-6
was added, as follows: "That any additional traffic impact mitigation would be required at the
site plan stage, if necessary. "
Page 3 - Findings and Conclusions
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A disagreement arose between city staff and the applicant's attorney as to whether the
City Council intended to include condition IV -6 as part of the findings.
At its meeting on July 12, 1999, the City Council was presented the proposed findings
and discussed the inclusion of Condition IV -6. . The City Council then clarified its intent
through a motion by Councilor Figley. Councilor Figley's motion, seconded by Councilor
Pugh, was a follows:
I would move that item IV, sub 6 be amended to say that no additional traffic
impact study be required of applicant~ that the issue of traffic impact mitigation be
required at the site plan stage, and no "if necessary." ...I made that
motion... someone would second it so we could discuss .....
The motion passed 5-0.
A second motion was then made at the July 12, 1999 meeti~g to direct city staff to
revise the Findings and Conclusions to be consistent with the inclusion of Condition IV -6, as
amended, and to present the revised Council Bill for approval at the following City Council
meeting. This motion passed 5-0.
ID. APPLICABLE APPROVAL CRITERIA.
The City Council herein adopts these fmdings approving this application. The City
Council expressly incorporates by reference the findings as to the applicable approval criteria
contained in the applicant's submittal dated September 18, 1998. Where there is a conflict
between these findings and that submittal, these findings shall control.
A. Annexation.
(1) Relevant Ap>>roval Criteria.
a. Statewide Plannine Goals ("Goals").
(i) Goal 1. "Citizen Involvement. "
"To develop a citizen involvement program and
insures the opportunity for citizens to be involved
in all phases of the planning process. "
FINDING:
The City of Woodburn has established a land use notification and hearings procedures
to assure citizen involvement.
Page 4 - Findings and Conclusions
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ATTACHMENT i3
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(ii) Goal 2. "Land Use Planning. II
"To establish a land use planning process and
policy framework as a basis for all decisions and
actions related to the use of land and to assure an
adequate factual base for such decisions and
actions. II
FINDING:
This Goal requires that the City coordinate Plan amendments, including annexations,
with affected governmental units. The City has coordinated this application with Marion
County, the Oregon Department of Transportation ("ODOT"), and the Department Land
Conservation and Development ("DLCD").
(iii) Goal 5. "Natural Resources. Scenic and Historic Areas.
and Open Spaces. II
liTo protect natural resources and conserve scenic
and historic areas and open spaces. II
FINDING:
No Goal 5 resource exists on Tax Lot 101.
(iv) Goal 6. II Air. Water and Land Resources Ouality. II
liTo maintain and improve the quality of the air,
water and land resources of the state. II
FINDING:
State agencies play a key role in achieving this goal. At the time of development, the
Department of Environmental Quality ("DEQ") is responsible for administering permits for
drainage and for air Quality ("DEQ") with respect to large parking facilities. The Division of
State Lands ("DSL") is responsible for administering wetlands.
(v) Goal 7. "Areas Subject to Natural Disasters and
Hazards. II
liTo protect life and property from natural
disasters. II
Page 5 - Findings and Conclusions
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ATTACHMENT 8lf
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FINDING:
There are no hazards associated with the subject property.
(vi) Goal 8. "Recreational Needs. I'
"To satisfy the recreational needs of the citizens of
the state and visitors, where appropriate, to
provide for the siting of necessary recreational
facilities including destination resorts. 'I
FINDING:
The Subject property has not been identified by the City as a potential park site for any
type of recreational facility.
(vii) Goal 9. "Economic Develo.pment.'1
"To provide adequate opportunities throughout the
state for a variety of economic activities vital to
the health, welfare, and prosperity of Oregon's
citizens. "
FINDING:
The subject property provides the opportunity to reinforce the activity of the existing
factory outlet center. There is no other site in the Urban Growth Area with the same
locational characteristics. The opportunity for expansion of the factory outlet center to an
abutting parcel will better serve the existing market area and expand the market area, thereby
creating more jobs and local payrolls.
(viii) Goal 10. "Housing."
"To provide for the housing needs of citizens of
the state. "
FINDING:
The City of W oodbum has provided for a variety of housing types and densities in its
Plan and implementing ordinances, consistent with the Guidelines for implementing Goal 9.
The available inventory of residential land within the UGB exceeds the amount needed to serve
future population needs.
Page 6 - Findings and Conclusions
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As documented on page 39 of the Plan, there is sufficient land designated for
residential use in the Plan to accommodate a population of 28,000, plus a surplus that includes
approximately 100 acres of both the Low Density and High Density Plan designations. This
analysis is based on the carrying capacity of the two (2) residential categories in the plan in
relation to the densities permitted in the underlying zoning. The capacity of the Low Density
Residential designation is six (6) dwelling units per gross acre. The capacity of the High
Density designation is conservatively indexed at a density of twelve (12) dwelling units per
gross acre, where the corresponding zoning allows densities ranging up to twenty-five
(25) dwelling units per gross acre.
(ix) Goal 11. "Public Facilities and Services. "
"To plan and develop a timely, orderly and
efficient arrangement of public facilities and
services to serve as a framework for urban and
rural development. II
FINDING:
The subject property is well positioned for the further extension of public facilities
constructed to serve Phase I development of the factory outlet center.
(x) Goal 12. "Tran$POrtation. II
"To provide and encourage a safe, convenient and
economic transportation system. II
FINDING:
This Goal is implemented by the Transportation Planning Rule ("TPR"). The City of
Woodburn has implemented the Goal 12 and the TPR through the adoption of an
acknowledged Transportation System Plan ("TSP") in 1996, Ordinance 2170. The TSP
accounts for the development of all the land within the Urban Growth Boundary as provided
for the Woodburn Comprehensive Plan.
The TSP fulfills the Goal 12 through facility plans for streets, bicycles, pedestrians,
and transit; implementation priorities and a financing program. The City has established a
TSP that reflects the annexation and urbanization of the subject property. Additional findings
demonstrating compliance with the TPR are found below.
(xi) Goal 13. "Energy Conservation. II
liTo conserve energy. "
Page 7 - Findings and Conclusions
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FINDING:
The development of the subject property will assist in conserving the energy used for
shopping by encouraging one stop shopping due to the aggregation of a wide range of goods at
a single location. The buildings in the center will all conform with required energy
conservation codes.
(xii) Goal 14. "Urbanization. "
"To provide for an orderly and efficient transition
from rural to urban land use. "
FINDING:
Goal 14 provides for an orderly and efficient transition from rural to urban land use.
Tax Lot 101 is "urbanizable" and not "rural" since it is within the Urban Growth Boundary.
Urbanizable lands are defined as lands with the UGB which are determined to be necessary and
suitable for future urban uses, can be served by urban services and facilities and are needed for
the expansion of an urban area.
The 8.0 acre annexation is an appropriate parcel to be included within the City. Since
the property abuts the existing factory outlet center, it is a logica11ocation for expansion of the
center. The public need for this particular land use at this particular location was documented
in the City's 1992 and 1998 annexation land use approvals of the factory outlet center. As a
facility with a regional market area, the annexation provides the opportunity for the factory
outlet center to increase its market penetration by expanding in a location that has previously
been selected and improved for the purpose. The annexation fulfills the City's need to grow
incrementally and to provide for mutually supporting uses.
(xiii) Goals 3. 4.15 and 16 throu~h 19.
FINDING:
The following goals are inapplicable to this proposal: Goal 3, Agricultural Lands;
Goa14, Forest Lands; Goal 15, Willamette River Greenway; and Goals 16 through 19, the
Coastal Goals.
b. Woodburn Comprehensive Plan.
(i) Commercial Development Policies
. Plan Policy B-1. The City should at all times have sufficient land to
accommodate the retail needs of the City and the surrounding market area. The
Page 8 - Findings and Conclusions
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ATTACHMENT 6
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City presently has four major commercial areas: 99E, 1-5 Interchange, the
downtown area and the 2l4/2l9/99E four corners intersection area. No new
areas should be established.
FINDING:
Plan page 14 identifies the special market area considerations for commercial uses at
this location:
"This area serves as an interstate service center. It is a freeway
oriented service center. This area also has a more regional retail
orientation than the rest of Woodburn. "
Consequently, the need for commercial land in this area is independent of other commercial
sites in the City. There are no comparable sites in the area available for commercial use. The
proposed (a factory outlet center) use can only be served at the proposed location. A factory
outlet center is appropriately located at this location because of its location relative to
transportation facilities
. Plan Policy B-2. Lands for high traffic generating uses (shopping centers,
malls, restaurants, etc) should be located on well improved arterials. The use
should provide the necessary traffic control devices needed to ameliorate their
impact on the arterial streets.
FINDING:
The subject property is located on Arney Road, which is classified as a "Service
Collector." Arney Road has been improved to essentially the same standards as a "Minor
Arterial," except that the turn refuge lane is two (2) feet narrower. Arney Road has direct
access to Highway 214, which is classified as a "Major Arterial." The appropriate traffic
control requirements along Arney Road have been identified as part of the traffic impact
analysis.
(ii) Annexation Policies
. Plan Policy D-l. While it is important that enough land is available for the
necessary development anticipated in the City of Woodburn, it is also essential
to prevent too much land from being included in the city limits as this leads to
inefficient, sprawling development. The City should ensure that there is a five
(5) year supply of vacant land within the City. Services should be provided to
the land during the five (5) year period.
Page 9 - Findings and Conclusions
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FINDING:
ATTACHMENT 6
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As found in Commercial Development Policy (V.D.1.a. above), the 1-5 Interchange
location of the subject property has special, regional market characteristics and therefore is not
directly competitive with other commercial sites within Woodburn. In addition there is
virtually no other vacant commercial land available at the interchange at present. Therefore
the subject property satisfies this policy.
. Plan Policy D-2. Prior to the approval of Site Plan, Subdivision or Planned
Unit Developments for land annexed to the city west of Interstate 5, a detailed
Transportation Impact Study with the Department of Transportation involvement
will be required.
FINDING:
This process allows the City to condition development with transportation improvement
requirements that are "roughly proportional" to the traffic impacts that are generated by the
development.
A Traffic Impact (fIS) Study was completed by the applicant and is contained in the
record. The City finds that this policy is satisfied for the purposes of this application and will
not require the applicant to prepare an additional traffic impact study for Woodburn Company
Stores, Phases IT and IT!. However, the City reserves its right to address any future traffic
mitigation issues when a Site Plan review application is submitted on the subject property.
. Plan Policy M-4. The County shall retain responsibility for regulating land use
on lands within the urban growth area until such lands are annexed by the City.
The urban growth area has been identified by the City as urbanizable and is
considered to be available, over time, for urban development.
FINDING:
Based on the on-going needs of the community to accommodate growth and the specific
commitment to construct Phase I of the factory outlet center, it is timely to allow urbanization
of the subject property.
. Plan Policy M-6. Upon receipt of an annexation request or the initiation of
annexation proceedings by the City, the City shall forward information
regarding the request (including any proposed zone change) to the County for
comments and recommendations. The County shall have twenty days to
respond unless they request and the City allows additional time to submit
comments before the City makes a decision on the annexation proposal.
Page 10 - Findings and Conclusions
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FINDING:
ATTACHMENT f3
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The City notified Marion County of the proposed annexation by letter in November
1998. The County Public Works Department responded December 13, 1998 for the Land Use
and Transportation Divisions. The comments indicated the need for a copy of the
Transportation Impact Analysis for Woodburn Company Stores Phases II & III, dated
December 1998 which was subsequently provided. In addition the County requested a site
plan addressing access, including the abutting property to the west of the subject property.
. Plan Policy M-7. All land use actions within the urban growth boundary and
outside the city limits shall be consistent with the City's Comprehensive Plan
and County's land use regulations.
FINDING:
The proposed annexation is consistent with the Plan because it is a proposal to permit
the urbanization of the subject property, subject to a concurrent Plan map amendment. There
are no County regulations that preclude the proposed annexation.
. Plan Policy M -11. Conversion of land within the boundary to urban uses be
based on consideration of [the following five (5) factors]:
a. Orderly, economic provision of public facilities and
services;
FINDING:
All the public facilities necessary to develop the abutting property for the same use
have been provided. Access to these public facilities therefore only requires minor extensions.
b. Availability of sufficient land for the various uses to
ensure choices in the marketplace;
FINDING:
The proposed annexation is required to provide the opportunity for future expansion of
a specific regional commercial use in the only site within the City that is appropriate.
c. LCDC Goals;
FINDING:
The LCDC Statewide Goals are addressed above.
Page 11 - Findings and Conclusions
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ATTACtJ,MENT 13
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d. Encouragement of in-filling development within
developed areas before conversion of urbanizable areas;
and
FINDING:
As a site to expand a specific existing use there are no in-fill locations that are suitable
for this purpose.
e. Applicable provision of the Marion County and City
comprehensive plans.
FINDING:
The proposed annexation is found to be consistent with the applicable portions of the
Woodburn Comprehensive Plan as indicated in section V.D. The proposal is consistent with
the Marion County Comprehensive Plan in that the County Plan establishes the Urban Growth
Boundary as the area specifically set aside for urbanization after annexation to the City.
d. Transportation System Plan
FINDING:
. Functional Classification of Streets.
FINDING:
The proposed Plan amendment does not warrant any change in the functional
classification of streets as shown on TSP Figure 29.
TSP Figure 29 indicates a potential street connection along the north boundary of the
subject property. Marion County has also indicated this need (Attachment A). The
appropriate facility to fulfill this need will be addressed at the time of site plan review for
Phases II and m.
. Improvement Projects.
FINDING:
Development of a commercial use will cause the need for transportation facility
improvements as described in the TIA. These improvements are consistent with those
described in the TSP.
B. Comprehensive Plan Map Amendment
Page 12 - Findings and Conclusions
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ATTACHMENT t3
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(1) Pro,posal.
The proposal is to change the Plan map designation for this site from "High
Density Residential" to "Commercial."
(2) Relevant Approval Criteria.
a. Plan Amendment Criteria, Woodburn Zoning Ordinance,
Section 16.050:
"a. Compliance with Statewide Goals.
"b. Compliance with Woodburn Comprehensive Plan Goals
and Policies" ,
"c. Demonstrated Public Need for the Plan Map Amendment.
"d. Proposal Best Satisfies the Need.
b. Burden of Proof, Woodburn Zoning Ordinance,
Section 16.080(b)
. Comoliance with Statewide Planninf Goals.
The findings regarding compliance with applicable statewide planning goals are found
above and are expressly incorporated herein by reference.
. Comoliance with Woodburn Comprehensive Plan Goals and Policies.
The findings regarding compliance with applicable Woodburn Comprehensive Plan
Goals and Policies are found above and are expressly incorporated herein by reference.
. Demonstrated Public Need for the Plan Map Amendment.
The proposed change in the Plan map from "High Density Residential" fulfills a
demonstrated public need. It represents a change from the way the Plan was originally
mapped but was accounted for in the goals and policies of Plan. Consistency with the intent of
the Plan demonstrates that the public need is served by the change. As time passes, there is a
public need to weigh issues and opportunities and recognize that incremental changes to the
Plan map benefit the community.
In this instance, there is demonstrated public need to accommodate an opportunity to
Page 13 - Findings and Conclusions
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strengthen the economy, consistent with Goal 9. Goal 9 states that the Plan shall provide for
at least an adequate supply of sites of suitable sizes, types, location and service levels for a
variety of commercial uses consistent with plan policies. Currently the Plan is lacking a
adequate supply of suitably located property that can be used to bolster the regional shopping
function at the Woodburn Interchange. The subject change is needed to achieve the full
potential of the interchange, particularly the existing factory outlet center. The public need is
served by expanded employment opportunities and desirable mix of land uses for a
freestanding community.
The Statewide Guidelines for Economic Development address the public's need to
accommodate expansion of commercial use. The Statewide Guidelines state that:
"Plans should strongly emphasize the expansion of and
increased productivity from existing firms as a means to
strengthen local and regional economic development" .
The subject change in the Plan designation is needed to be consistent with this guideline. The
Plan change augments the supply of suitable sites. The proposal is the only available site that
not only accounts for market forces, market location, and key public facilities, but that is
readily adaptable to expansion of the existing mall layout. The, proposal maximizes the use of
the existing facilities and the location advantages provided by freeway visibility and access and
complementary commercial uses.
The proposal is consistent with the Woodburn commercial land use policies. Part of
the public need is to exercise the Plan in away that recognizes change and positive growth
opportunities that build a strong, liveable community. The proposal is consistent with the
Plan. This consistency is demonstrated in section V.D. above.
Key considerations in reviewing the need for the change include the fact that it
concentrates commercial activity in a priority commercial area. Concentrating commercial
provides the benefit of cumulative attraction which in turn enhances market share and reduces
overall shopping trips. And significantly, the map change takes advantage of existing public
and private investment.
. Proposal Best Satisfies the Need.
The need for additional commercial land to support the expansion of the existing
factory outlet center is best served by this property. This reinforces the policy of
concentrating commercial development. It strengthens the shopping pattern for existing
commercial uses and avoids the proliferation of commercial uses in a dispersed pattern that
lacks the mutual support of like uses.
In this specific instance a commitment has already been made in this location to
Page 14 - Findings and Conclusions
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establish a special shopping area that serves a regional market area. This is the only location
in Woodburn that has the visibility, the access and an existing commercial use of this type.
The subject property is the only site within the community that can accommodate the
expansion of the existing factory outlet center.
The previous actions by the City in 1992 and 1998 clearly have set the stage that there
is a community need for this type of commercial use. Based on the public and private
commitments and investments, the location characteristics and the conformance with
commercial land use policy the subject property best satisfies the need for the expansion of the
factory outlet center.
. Burden of Proof.
(I) first criterion is to prove that the original Plan was in error.
FINDING:
Conditions have changed since the Comprehensive Plan was originally drafted and first
adopted in 1978. In that context there are errors in the forecasts as well as the assumptions
about the composition of uses in land use categories. Such errors reflect changes in
circumstance that warrant amending the Plan map.
(ii) The second criterion requires showing how the community has changed
since the original Plan was adopted
FINDING:
The 1992 and 1998 decisions to approve the site for the retail center found that the
actual population growth in Woodburn substantially exceeded the population forecast used to
formulate the original Plan. This increased rate of population is found to demonstrate a
change for the predicted patterns of growth since those apparent when the Plan was adopted.
The fmdings of the previous decision also describe how multi-family land needs were
over estimated in the original plan and that the interchange location is a less than optimum
location for a large concentration of multi-family residential use. Present circumstances
confirm that finding.
In addition, the exposure and access provided by the interchange location has resulted
in the development of the factory outlet retail center, a use which has a regional market.
Commercial development with a regional market was not anticipated or accounted for in the
original plan. The commercial activity with this broad market does not supplant local
commercial uses but rather adds to the commercial land needs of the City.
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(iii) The ordinance provides the alternative to address either the second or
third criterion. Haying addressed the second criterion, above there is no
requirement,to address the third criterion.
C. Zonine Map Amendment.
(1) Relevant Approval Criteria.
. Initiation of a Zone Change by Petition, Woodburn Zoning Ordinance,
Section 15.030
. Burden of Proof, Woodburn Zoning Ordinance, Section 16.080(b)
. Woodburn Comprehensive Plan Goals and Policies
(2) W oodbum Comprehensive Plan Goals and Policies.
Findings on these criteria are addressed in above, and are incorporation herein by
reference. The City Council finds that the Commercial Plan map designations implemented by
the CR zoning district.
D. Response to Issues Raised by the Oree:on Department of Transportation.
The Oregon Department of Transportation ("ODOT") submitted two letters into the
record dated February 4, 1999 and May 5, 1999. The May 5, 1999 letter states that it is
intended to update comments contained in the February 4, 1999 letter. This portion of the
decision responds to issues raised by ODOT.
As noted with respect to Goal 2, the City is required to give notice of this application
to ODOT, to allow ODOT an opportunity to comment on the application and to consider the
comments as much as possible. The City is not required, however, to agree with all of
ODOT's comments or to adopt them.
(1) The City Council finds that the I-5/Highway 214/219 Interchange will be
improved with sufficient capacity consistent with the adopted City of Woodburn Transportation
System Plan ("TSP").
ODOT argues that the applicant's transportation impact study ("TIS ") is flawed because
it is: "Based on the assumption that a major improvement to the 1-5 Interchange will be
completed. Such an improvement is not, however, included in the City's TSP or the
Woodburn Comprehensive Plan. In fact, the TSP contains Goal 2, Policy 2, which states:
"Develop a strategy for providing improved access to 1-5
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from the Woodburn area, through either improvements of the
existing Highway 214 Interchange and/or a new interchange in
the Woodburn vicinity (with supporting local roadway
improvements). This strategy will be developed following a
refinement study as outlined in the Transportation Planning
Rule."
The City Council finds that the applicant has satisfied OAR 660-12-060(1) because
the application has no present "significant affect" on a transportation facility. Further, the
administrative rule provides that the City may approve the application subject to conditions of
approval which mitigate a significant affect. The City Council finds that Condition IV -6,
requiring that the traffic mitigation issues by addressed by the City at the time of site plan
review, serves to mitigate any potential significant affect.
The City Council finds that the applicant's TIS demonstrates that the application will
not have a significant affect on the transportation facility identified as the 1-
5/Highway 214/219 Interchange. Table 4 of the TIS prepared by Kittelson & Associates, Inc.
("KAI") shows that in the year 2001, 1-5 will operate during a Friday p.m. peak hour at level
of service ("LOS") "C" or better, with minor improvements. TIS at pages 24-25. TIS
Table 5 shows that in the year 2003, the interchange will operate at LOS "DI' or better. The
City Council finds nothing in the TPR requires it to look at the year 2015. In order to
determine whether the application has a present significant affect on the application, the City
Council fmds that Tables 4 and 5 demonstrate that the application will cause the interchange to
operate at acceptable LOS through at least the next four (4) years.
In the whereas clauses adopted by the City Council for the TSP, a number of fmdings
demonstrate that the TSP, with its required refinement study, will satisfy the capacity
requirements of the TPR at this interchange. The City Council notes that neither ODOT nor
the Oregon Department of Land Conservation and Development ("DLCDI') appealed the City
Council's adoption of its TSP.
One whereas clause adopted by the City Council for the TSP found:
"The City Council finds that the transportation system plan
adopted herein complies with OAR 660-12-06O(1)(b) for the
affected transportation facilities, including but not limited to the
Highway 214/1-5 Interchange/Parr Road area."
Further, incorporated in the staff report for the TSP were several fmdings relevant to
the TPR. The City Council adopted findings regarding OAR 660-12-025(1). This section of
the TPR provides "except as provided in Section (3) in this rule, adoption of a TSP shall
constitute the land use decision regarding the need for transportation facilities, services and
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major improvements in their function, mode and general location. " Section (3) of the
administrative rule provides that a local government may defer decisions regarding function,
general location and mode of a refinement plan if the necessary findings are adopted. Pursuant
to the administrative rule, the city did defer, certain significant decisions. The City decided to
defer the decision regarding the mode of improvements to the existing 1-5 interchange and
make this decision after completion of a refinement plan. Three options were evaluated in the
TSP but there are other potential alternatives. The information as to mode of interchange
improvement could not be arrived at because Marion County had not completed its plan and
further evaluation of the area was needed. However, the city's deferral did not invalidate any
of the TSP assumptions because the need for an interchange improvement will still be
addressed and local improvements to aid traffic flow will still be addressed. Delay of this
decision did not, and should not, preclude implementation of the remainder of the TSP and
consideration of the present application. The result of the refinement study, which will include
a detailed, technical evaluation of the three current alternatives, plus others, will be an
interchange alternative which is precisely defmed.
Additionally, the City Council found that the TSP satisfied OAR 660-12-030. The City
Council found:
"The TSP identifies the City's transportation needs including
those of the transportation disadvantaged, and support of
industrial and commercial development. These needs were based
on a 20-year forecast in population and employment within the
acknowledged comprehensive plan. ..
Further, the City Council adopted findings regarding OAR 660-12-060(1). The City
Council found:
"That the transportation system plan adopted here complies with
OAR 660-12-060(1)(b) for the affected transportation facility,
including but not limited to the Highway 214/1-5
Interchange/Parr Road area."
The TSP adopted by the City Council adopted three (3) 1-5 access alternatives U= TSP
at page 1). The TSP states: "An element of the TSP is an improvement to existing 1-5/214
Interchange" and "a reconfiguration of the interchanges proposed." (TSP at page 89.)
The City Council also notes that Table 6 (TSP at page 41) shows that at least one of the
options (the two interchange options) would result in LOS "0" or better in the year 2015.
The TSP contains a section entitled "Required Street Upgrades." The portion of this
section dealing with freeways states: "In the longer-term, reconfiguration of the interchange is
proposed. A specific improvement (improve existing interchange, split diamond interchange
or second interchange at Butteville Road) will be identified through a follow-up interchange
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refinement study of the TSP." (TSP at page 89.)
The City Council fmds that while it has not completed the refmement study, it is
unnecessary to do so in order for it to determine that OAR 660-12-060(1)(b) is satisfied for the
purposes of granting this application. With the TSP and required refmement study, a solution
to the long-term capacity needs of the interchange will be provided. In fact, the TSP
transportation fmancing plan contains a proposed roadway system capacity improvement for
the 1-5 interchange. <.s.= TSP at page 115; Table 17.) Thus, not only has the City Council
determined to improve the interchange, it has provided some estimated costs for the
improvement in the TSP long-term financing plan.
The City Council finds that it need not complete the refinement study prior to this
application. Because the TSP is part of the City's acknowledged plan and because the TSP
states that a solution will be identified, the TSP has determined that the interchange will be
upgraded.
The City Council finds that under Goal 2, Policy 2 of the TSP a strategy will be
developed following a refinement study as outlined in the TPR. OAR 660-12-025(3)(c) says
that deferral of a solution to a refmement plan is allowed if it does not invalidate the TSP. In
this case, the refinement plan carries out the TSP's acknowledged strategies without
invalidating them. For these reasons, the City Council fmds that the lack of refinement study
is not an impediment to a conclusion that the 1-5 has sufficient capacity in the short term, as
required by the TPR, and in the long term sufficient capacity will be provided through a
solution identified in a refmement study.
The City Council declined to impose a condition, which was recommended by the
Planning Commission, that traffic impact be determined based upon an additional Traffic
Impact Study (TIS) to be paid for and obtained by the applicant. Instead, The City Council
imposed a condition that the City address the issue of required traffic impact mitigation at the
time of site plan review.
(2) The City Council finds that KAI's TIS correctly analyzes the level of service at
the time of this a.Rplication.
ODOT argued that the TIS does not adequately analyze the plan amendment impacts.
ODOT requested that the TIS be revised to reflect a "worst case analysis, II meaning an analysis
of the highest traffic generating land use permitted in the commercial retail ("CR") zoning
district.
The City Council finds that this issue is not required to be reached because a condition
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of approval requires that the site be limited to a factory outlet center. This is consistent with
the City Council's 1992 and 1998 decisions regarding Phase I of the Woodburn Company
Stores. Thus, a worst case scenario for the highest traffic generator in the CR zoning district
is unnecessary since, in the event the Woodburn Company Stores Phase IT and III is not
constructed, the property owner will be required to amend this condition of approval which
will require an amendment to this decision.
(3) OAR 660-12-045 is or can be satisfied.
ODOT argues that because the City of Woodburn has not implemented the
requirements of OAR 660-12-055(2), that it must address the applicable provisions of
OAR 660-12-045(3),(4)(a)-(e) and (5)(d). The City Council agrees with ODOT.
. OAR 660-12-045(3)(a).
This section requires bicycle parking facilities as part of new retail developments. The
City Council finds that it is feasible, at the site development review stage, for the application
to provide bicycle parking given the size of the facility (8.0 acres). The finding of feasibility
is based on the similar Phase I development.
. OAR 660-12-045(3)(b).
This criterion requires on-site facilities accommodating safe and convenient pedestrian
and bicycle access within new shopping centers to adjacent residential areas and transit stops.
It also requires that pedestrian circulation through parking lots generally be provided in the
form of access ways.
The City Council finds that it is feasible to satisfy this requirement. As with bicycle
parking facilities, Phase I of the Woodburn Company Stores has demonstrated that it is
feasible to meet both of these requirements. Therefore, the City Council finds that this
criterion can be satisfied.
. OAR 660-12-045(3)(c).
The City Council finds that it is feasible to require off-site road improvements that
would include facilities accommodating convenient pedestrian and bicycle travel. The City
Council has required the applicant, in the approval of Phase I of Woodburn Company Stores,
to provide a bicycle lane and sidewalks along Arney Road.
. OAR 660-12-045(3)(e).
This criterion requires that internal pedestrian circulation within commercial
developments be provided through the location of buildings, construction of accessways,
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walkways and similar techniques. The City Council finds that because the applicant satisfied
this requirement in Phase I, it is feasible to satisfy this requirement in Phases II and III.
. OAR 660-12-045(4)(a).
The City Council finds that it is feasible to require this applicant to provide transit
facilities designed to support transit use through the provision of bus stops, pullouts and
shelters, optimum road geometrics, on-road parking restrictions and similar facilities as
appropriate.
. OAR 660-12-045(4)(b).
This criterion requires that retail development at or near major transit stops provide for
convenient pedestrian access to the transit stop. The City Council finds that there is no major
transit stop as that term is defined near this. site.
. OAR 660-12-045(4)(c).
The City Council finds that this criterion is inapplicable since a pedestrian district has
not been established in this area.
. OAR 660-12-045(4)(d).
The City Council finds that it is feasible to require employee parking in Phases II and
III to provide for preferential car pool and van pool parking. The City Council makes this
finding based on its approval of Phase I.
. OAR 660-12-045(4)(e).
This criterion is inapplicable since it applies to existing development.
. OAR 660-12-045(5)(d).
The City Council fmds that it is feasible to satisfy this criterion by providing a transit
stop along Arney Road or providing a corniection to a transit stop if the transit operator
requires such an improvement. The City Council makes this finding based on its approval of
Phase I of Woodburn Company Stores.
For these reasons, the City Council finds that the issues raised by ODOT have been
satisfied and are not a basis for denial of this application.
E. Response to issues raised by Department of Land Conservation and
Development in March 22. 1999 Letter.
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(1) Statewide Plannine Goal 10. "Housine". Is Satisfied.
DLCD argues that the City must adopt an updated buildable lands needs analysis to
satisfy Goal 10. Only at that point, DLCD suggests, is it possible for the City to assess
whether conversion of 8.0 acres from a multi-family designation to a commercial designation
satisfies Goal 10. The City Council rejects this argument.
This application is subject to compliance with the Goals and the acknowledged Plan.
ORS 197.175(2). Goal 10 simply requires the City to provide for housing needs. The City
has done this. The findings at the outset of this decision state the housing needs of the City of
Woodburn have been satisfied through the year 2014. The acknowledged Plan states that there
are 688 acres of high density residential designation. Of this, 57 acres are undeveloped and
188 acres are underdeveloped. (plan at pages 15 and 16.)
The Plan further notes that the City has 238 surplus acres designated for multi-family
land uses. (plan at page 38.) This allows, at 12 dwelling units per acre, an additional
2,353 dwelling units. (klJ Table 9 of the Plan at page 39 shows that the City has a surplus of
1,305 multi-family dwelling units through the year 2014. The Council notes that the Plan has
recently been amended in March 1996 and in August 1997.
Moreover, assuming that this eight (8.0) acres can accommodate twice the 12 dwelling
units per acre figure, this area would accommodate 192 dwelling units. Removal of this site
from the High Density Residential designation would still leave 1,013 surplus multi-family
dwelling units by the year 2014.
The City Council finds that the acknowledged Plan's determination of a surplus of
multi-family housing units is a sufficient basis for it to determine that this application will
allow the City to continue to meet the housing needs of its citizens. There is no legal
requirement that the City defer this determination until the periodic review is completed as
suggested by DLCD. DLCD's assertion that the City's acknowledged Plan contains an "out-
of-date buildable lands inventory" does not mean that the City cannot rely on its acknowledged
Plan.
(2) Statewide Planning Goal 9 Is Satisfied.
DLCD argues that the City must satisfy the administrative rule implementing Statewide
Planning Goal 9; OAR Chapter 660, Division 9. The City Council finds that this
administrative rule applies only at periodic review. OAR 660-09-10(2). However, assuming
that the administrative rule applies to non-periodic review decisions, the City Council finds, as
it did in 1992 and in 1998 that this application satisfies the administrative rule for the
following reasons.
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First, this application results in eight (8.0) acres of commercial development which will
increase the amount of the City's property taxes. Increased property taxes provide
additional revenue to the City. Secondly, an eight (8.0) acre commercial development
provides additional jobs for city and area residents. Finally, consistent with the Plan, approval
of this application further encourages the development of the 1-5 commercial area. The
acknowledged plan has long anticipated that this area will be developed for commercial uses.
(3) The City Has Coordinated with ODOT. DLCD and Marion County.
DLCD argues that ORS 197.015 provides that a Plan is coordinated when the needs of
all levels of government have been considered and accommodated as much as possible. DLCD
argues that ODOT's needs have not been satisfied since that agency requested a refinement
study. For the reasons described above, the City Councii finds that a refinement study is not
necessary now. Moreover, the City Council has considered ODOT's request that a refmement
study be prepared before this application is approved but has rejected this request as explained
above. Nothing requires the City Council to agree with ODOT in order to satisfy its
coordination requirement under state law.
Finally, DLCD suggests that the City ought to defer this decision until the City's
periodic review has been completed. However, nothing in state law requires deferral of an
annexation, plan map amendment or zoning map amendment for completion of a periodic
review work task. 1
(4) The Application does not Conflict With Periodic Review.
The City Council rejects DLCD' s argument that the Plan amendment must be deferred
until the City has completed its periodic review work tasks. DLCD cites no legal basis for
requiring deferral until the periodic review work tasks are satisfied.
(5) The City Has Satisfied the 4S-Day Post Acknowledgment Amendments.
The City caused notice of the February 22, 1999 Planning Commission hearing to be
timely mailed prior to that hearing. However, the "final hearing on adoption" of these
amendments was the May 10, 1999 City Council hearing. Thus, both OOOT and OLCO had
1 ODOT and DLCD's comments are directed at the comprehensive plan map amendment
and not at the annexation or zoning map amendment. Because ODOT and DLCD have not raised
an issue with the respect to the annexation, there would be no basis for the Land Use Board of
Appeals to remand or reverse the annexation decision. The City Council finds that ODOT and
DLCD raised issues related only to the Plan map amendment and not to the annexation
amendment. Consistent with ORS 197.763(1), these agencies did not raise issues with sufficient
specificity as to the annexation and the zoning map amendment.
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more than 45 days notice of the City's fmal hearing on adoption which is required by OAR
Chapter 660, Division 18. Moreover, to the extent DLCD's comment raises a procedural
error, the City Council finds that the agency's substantial right to a full and fair hearing and an
opportunity to make its case have not been prejudiced. ODOT and DLCD placed letters into
the record and ODOT's representative appeared at the May 10, 1999 City Council hearing.
Thus, both agencies had a full and fair opportunity to make their case. 2
IV. CONCLUSIONS AND CONDITIONS.
The City Council finds for the reasons contained herein to approve this application subject
to the following conditions of approval.
(1) The access improvements required along the north line of the property shall be
determined at the time of Site Plan Review.
(2) The delineation of the wetlands and the required mitigation measures approved by
the Division of State Lands shall be required at the time of Site Plan Review.
(3) This approval is limited to a factory outlet center.
(4) That there be no development of Phase IT until construction of improvements which
were required for Phase I as conditions of approval for Phase I are completed
satisfactorily.
(5) That the site plan review application shall satisfy OAR 660-12-045.
(6) That the applicant shall not be required to submit an additional traffic impact study
but that traffic mitigation shall be addressed at the time of site plan review.
2 ODOT requested that the City Council record remain open at the May 10, 1999 hearing.
ORS 197.763(4)(b) provides that a City Council may continue a hearing when it is not the initial
evidentiary hearing. The initial evidentiary hearing in these applications was the February 22,
1999 Planning Commission hearing. The City Council notes that ODOT's representative did not
object to the City Council's denial of his request that the record remain open.
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