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LA 23-01: Analyses & Findings Page 1 of 5 Attachment 101 Analyses & Findings A. Legislative Amendment Applicable Provisions of the Woodburn Development Ordinance (WDO) WDO 4.01 Decision-Making Procedures 4.01.02E. Type V Decisions (Legislative): Type V decisions involve legislative actions where the City Council enacts or amends the City’s land use regulations, comprehensive plan, Official Zoning Map or some component of these documents. Type V decisions may only be initiated by the City Council. The Planning Commission holds an initial public hearing on the proposal before making a recommendation to the City Council. The City Council then holds a final public hearing and renders a decision. Public notice is provided for all public hearings (Section 4.01.14). The City Council’s decision is the City’s final decision and is appealable to LUBA within 21 days after it becomes final. This WDO amendment and modification to the TSP are considered a post-acknowledgement plan amendment to the Comprehensive Plan and qualify as a Type V decision. Staff completed all required public notices (originally noticed for October 9, 2025 and continued until October 23, 2025) pursuant to the WDO 4.01.14: September 4, 2025: 35-day PAPA notice to DLCD September 18, 2025 (WDO) notice requirements for legislative amendments mailed and posted, including notice to Marion County, service providers and ODOT Woodburn Comprehensive Plan Policies H. Transportation Goal 1.9 To ensure that growth is orderly and efficient, the City shall phase the needed public services in accordance with the expected growth. Extensions of the existing public services should be in accordance with the facility master plans and Public Facility Plan in this Comprehensive Plan. The proposed revisions provide updates for the continued orderly and efficient planning and growth in current and new UGB areas. The update includes planning for transportation with estimated costs for each project in the subarea. Not modifying the WDO to remove the trip cap in the IMA would prohibit any possibility of orderly growth and would prevent the opportunity for extension of necessary infrastructure to serve the SWIR and UGB expansion properties, as already approved by DLCD as part of our 2024 UGB expansion. ---PAGE BREAK--- LA 23-01: Analyses & Findings Page 2 of 5 B-2. Woodburn shall coordinate with affected state agencies regarding proposed comprehensive plan and land use regulation amendments, as required by state law. This project was partially funded by a grant from Business Oregon. DLCD, ODOT, and Marion County staff served on the Technical Advisory Group (TAG) that oversaw the project. All required parties were notified of the proposed amendments pursuant to state law and Staff made modifications to the WDO amendment to address written concerns raised by ODOT. H-6.2 Woodburn will implement plans as provided in the Woodburn TSP. The TSP shall include a map depicting future street connections for areas to be urbanized. This is especially important in Nodal Development Overlay and Southwest Industrial Reserve overlay areas. The TSP revisions were made to the roadway and local street connections maps, including street connections to serve the most recently approved UGB which includes both overlay Districts. B. Applicable Statewide Planning Goals There are a total of 19 Statewide Planning Goals. Staff finds Goals 3- 10, 13, 15 and Goals 16-19 for Coastal Statewide Planning Goals are not applicable. Staff finds that the Statewide Planning Goals applicable to this land use decision are as follows: • Goal 1: Citizen Involvement • Goal 2: Land Use Planning • Goal 9: Economic Development • Goal 11: Public Facilities and Services • Goal 12: Transportation • Goal 14: Urbanization Goal 1: Citizen Involvement - OAR [PHONE REDACTED](1) The City and its consultants provided citizen involvement opportunities in a variety of ways as part of the planning process. - Technical Advisory Group. The City formed and conducted meetings with a technical advisory group (TAG) that met over four times to review materials and provide direction at key milestones. - Planning Commission and City Council Meetings. Staff provided public workshops and updates on the TSP update before the Planning Commission and City Council to present information. - Staff provided notice to the Department of Land Conservation and Development (DLCD) in compliance with OAR [PHONE REDACTED] and notified affected government agencies in conformance with WDO 4.01.14D as outlined above. ---PAGE BREAK--- LA 23-01: Analyses & Findings Page 3 of 5 Goal 2: Land Use Planning - OAR [PHONE REDACTED](2) Goal 2 requires each local government in Oregon 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 base for such decisions and actions. Goal 2 also includes requirements for coordination with other jurisdictions and government agencies, requires that plans include implementation measures, and that plans be reviewed periodically and amended as needed. The City last updated and adopted its Transportation System Plan (TSP) in 2019 and in order to ensure that the City has an accurate plan for transportation needs and costs, most specifically for the recently expanded and fast-growing Southwest Industrial Reserve (SWIR), the City Council initiated this Type V legislative process and update with assistance from a transportation consultant. Goal 11: Public Facilities and Services - OAR [PHONE REDACTED](11) The City last updated and adopted its Transportation System Plan (TSP) in 2019 and in order to ensure that the City has an accurate plan for transportation needs and costs, most specifically for the recently expanded and fast-growing Southwest Industrial Reserve (SWIR), the City Council initiated this Type V legislative process and update with assistance from a transportation consultant. Goal 12: Transportation - OAR [PHONE REDACTED](12) Compliance with Goal 12 is found under Oregon Administrative Rules 660-012 below. Goal 14: Urbanization - OAR [PHONE REDACTED](14) The proposal furthers this goal by revising the TSP and WDO to ensure efficient and orderly infrastructure to address growth within the city’s UGB, including the recent UGB expansion of 237 acres. C. Applicable Oregon Administrative Rules: 660-012 Transportation Planning Rule (“TPR”) Local TSP’s and amendments to Plans must comply with the provisions of this rule. The TPR requires local governments to prepare a transportation systems plan (TSP) that meets the requirements of OAR 660-012. The City’s existing TSP complies with the requirements of Goal 12 and the proposed revisions do not render any elements out of compliance. ---PAGE BREAK--- LA 23-01: Analyses & Findings Page 4 of 5 Woodburn’s adopted 2019 TSP established a transportation system that is adequate to serve lands within the UGB at that time and is consistent with the Marion County TSP, and in coordination with ODOT and DLCD. The updated elements in the revised TSP include the new UGB area and removal of one of the trip caps in the IMA that is no longer applicable. All other requirements and protections of the IMA still apply. The IMA provisions envisioned by the City’s adopted targeted industries and Comprehensive Plan are preserved. [PHONE REDACTED] Provides that transportation planning be divided into two phases, transportation system planning and project development. These revisions update the TSP consistent with all provisions of Division 012. The proposed revisions do not render any elements out of compliance and staff finds the two phases are not changed. [PHONE REDACTED] Includes requirements for preparation and coordination of transportation system plans. The proposed revisions comply with all of the applicable requirements for preparation, coordination and adoption of TSPs as is required under this section of the TPR. The TSP amendments are incorporated as part of City’s Comprehensive Plan. The preparation of the Plan was closely coordinated with affected government agencies and service providers, including a Technical Advisory Group (TAG) comprised of ODOT, Marion County, and DLCD staff. The revisions also amend projects and cost summary basis under Chapter 3 of the TSP to remove completed project and add new needs for expansion areas. The proposed revisions do not render any elements out of compliance. [PHONE REDACTED] This section of the TPR describes the elements that TSPs must contain. Staff finds these amendments, together with the previously adopted and acknowledged TSP, include all of the elements required by the TPR and are consistent with OAR-[PHONE REDACTED]. These minor amendments to the TSP include updates to Chapters 3 (“Motor Vehicle System”) and 8 (“Planned Transportation System Cost Summary”). The amendments do not alter previously adopted policies, financial plans, TDM provisions, or non-vehicular plans. The projects added to the project list include locations, descriptions, providers, and planning level cost estimates per this Division. The proposed revisions do not render any elements out of compliance. [PHONE REDACTED] The provisions of this section set forth how needs shall be identified in TSP’s. The amendments comply with these requirements as noted in Technical Memorandum dated May 31, 2024 which included an assessment of needs for Bicycle Facilities; Pedestrian Facilities; Transit Service; Streets and Highways; Intersection Operations; and, Transportation Safety within and directly adjacent to, the study area and incorporated into the revised TSP. The proposed revisions do not render any elements out of compliance. ---PAGE BREAK--- LA 23-01: Analyses & Findings Page 5 of 5 [PHONE REDACTED] This section concerns how the transportation system alternatives analysis was performed. The City has an acknowledged TSP consistent with the TPR provisions of 660- 012-0035. Proposed amendments to the TSP account for the new UGB expansion area, address existing development(s), and remove completed TSP projects for a more current cost basis. As described in the Technical Memoranda prepared by the consultant and included in this amendment, ODOT’s Analysis Procedures Manual (APM versions 1 and 2) as well as guidance by the TAG, provide the basis for transportation system alternatives. Three alternatives were considered including a ‘No-Build’ option. [PHONE REDACTED] This section of the TPR requires that a TSP include a transportation financing program and sets forth what such a program is required to include. The funding program in the TSP is reasonably assured and the proposed revisions did not significantly modify the financing program. There are no changes to the fiscally constrained dollar amounts. The TSP amendments include a list of planned transportation facilities including the estimated timing and rough cost estimates. The proposed changes are de minimis and are consistent with OAR 660-012- 0040. [PHONE REDACTED] The provisions of this section concern how a TSP is implemented. The City has an adopted and acknowledged TSP, an approved WDO, and Public Works Standards that implement the TSP. The proposed revisions, together with previously adopted and acknowledged ordinances, fully implement the applicable provisions of OAR [PHONE REDACTED]. The WDO amendment to the IMA does not adversely impact the long-term capacity of the interchange since the parcel trip cap remains in place, as anticipated. The only revision is to remove the 20-year cap that has expired. All other IMA regulations remain in place on applicable properties within the IMA. These amendments have been adopted pursuant to all local and state requirements. [PHONE REDACTED] This section sets forth requirements for plan and land use regulation amendments. These amendments, together with previously adopted and acknowledged ordinances, fully implement the applicable provisions of OAR [PHONE REDACTED]. The revisions and WDO amendment do not alter any of the mobility targets for the interchange. The IMA trip cap remains in place on applicable properties in the IMA; therefore, no re-evaluation is necessary at the intersection at this time. The transportation facilities identified in the TSP amendments are considered to be financially feasible and are included in the System Cost Summary.