Springfield planners review code audit identifying state compliance gaps, appoint advisory committees

SPRINGFIELD — The Springfield Planning Commission on Tuesday reviewed a code-and-plan audit for the city's Housing Design Initiative that finds much of the development code already complies with state statutes but identifies specific changes the city must make to meet Oregon requirements and several recommended changes to encourage housing production.

Haley Campbell, senior planner for the Housing Design Initiative code and plan update, introduced the project and said the audit's primary goal is to "bring the city code into compliance with housing related statutes and state rules" while also identifying strategic amendments to support housing production and affordability. Victor Tran, project manager for consultant Cascadia Partners, led the presentation of findings from the code audit and the plan audit.

The audit compared Springfield's code against several Oregon Revised Statutes and related state rules. Tran said the review covered ORS chapters concerning comprehensive planning, permitting and review, and land divisions and that the project team had put the full findings in an appendix in the packet for commissioners. "This first section has to do with legal compliance with state statute. So these are required and mandatory," Tran said during the presentation.

Why it matters: the audit sets the list of mandatory code changes the city must adopt to stay within state law and highlights discretionary or strategic amendments the city can choose to adopt to make it easier to build more housing.

Key findings

- Broad compliance: The auditors reported many code sections already meet state requirements and require no changes.

- Partially compliant items: The report identifies a set of provisions that need tweaks to reach full compliance, including clarifying allowances for residential uses in zones that currently allow single-family housing, allowing manufactured-home parks and prefabricated dwellings in all zones where the allowed density supports them, and ensuring no minimum lot size greater than 1 acre blocks manufactured-home parks.

- Statutory noncompliance: The team identified one code section that does not comply with state statute: local rules on recreational-vehicle (RV) occupancy. Tran said the city must allow RVs to be used for residential occupancy without a time limit in RV parks and manufactured-home parks if the units are connected to water, electricity and sewage; allow RV residential occupancy without utilities following a natural disaster; and align temporary-use expiration timelines with the state provision.

- Clear-and-objective standards: State law requires cities to offer a clear-and-objective approval path for housing development. The auditors found multiple instances of subjective or discretionary language in the code's land-use districts, overlay districts, development standards and application submittal lists. Tran gave the example of a massing/design standard that reads in part, "Avoid single monolithic forms that are not relieved by variations in massing," and recommended rewriting standards to measurable tests (for example, "buildings shall incorporate at least two of the following massing techniques for any facade longer than 50 feet"), so applicants can meet objective criteria.

- Plan audit and barriers: The plan audit found the reviewed neighborhood refinement plans are generally consistent with state statute but flagged policies and plan provisions that could impede housing production. Common themes included large minimum-development-area requirements, additional planning prerequisites such as master plans or development-area plans that add time and complexity, policies that favor downzoning or commercial designations that reduce residential land supply, and aspirational refinement-plan language encouraging setbacks or buffers that could conflict with housing production goals if interpreted rigidly.

- Other barriers: Auditors noted many commercial and mixed-use zones currently specify commercial-dominant intents that prohibit stand-alone residential development; some development regulations such as height and lot-coverage limits may reduce feasibility for multi-story housing; and market and infrastructure constraints in some Climate Friendly Areas (CFAs) could limit realistic housing yields compared with state-assigned capacity calculations.

Interviews and market context

Tran said the consultant team's market-oriented analysis included interviews with two major stakeholders: the Glenwood development team and PeaceHealth. He said the Glenwood development team is already pursuing major housing redevelopment, while PeaceHealth plans to reserve campus land for medical expansion and is therefore not pursuing housing on that campus. He also said the audit contrasted the state's capacity methodology'which assumes widespread parcel redevelopment'with a market-informed view that infrastructure constraints and varying landowner willingness could reduce actual yield.

Timeline and next steps

Campbell said the audit was intended to be finalized with input from tonight's planning commission review and a scheduled presentation to city council next week. The project schedule presented at the meeting calls for developing code-and-plan concepts through September, a round of community engagement in July'August, drafting amendments in the fall and preparing an adoption package by the end of the year; staff cautioned that formal adoption is unlikely before June of the following year due to the adoption process timeline.

Commissioner questions and staff clarifications

Commissioners asked for clarification on several points, including the meaning of the state rule on occupancy limits based on familial relationships. Tran and the city attorney, identified only as Christina in the meeting, explained the relevant ORS provision prevents a local code from setting different occupancy limits based on whether occupants are related; the city's code was found to be in compliance on that point.

Commissioners also pressed for clarification about the market constraints cited in the memo. Tran reiterated that the state methodology for housing capacity is permissive and assumes broad redevelopment, while a market study considers infrastructure capacity, developer and landowner willingness and other practical constraints that can reduce realistic housing yields.

Committee appointments and votes

The commission also took two formal actions tied to the Housing Design Initiative: it appointed a technical advisory committee (TAC) from applicants and designated a two-member governance committee that will coordinate with city council while council is on summer break.

- Technical advisory committee: Staff reported 17 applicants for the TAC, including architects, planners, engineers, property owners and residents; the application summary noted five Springfield residents, four property owners, two renters, four business owners, 16 who work or conduct business in Springfield and 13 with volunteer experience in the region. The commission voted to appoint all 17 applicants. The roll call recorded four aye votes (Chair Buck, Commissioner Driggs, Commissioner Thompson and Vice Chair Schmunk), one abstention (Commissioner Greenwell) and one absent (Commissioner Weber). The motion passed (4 yes, 0 no, 1 abstain, 1 absent).

- Governance committee: The commission appointed two planning commissioners to a governance committee that will meet ad hoc over the summer to coordinate with city council on policy direction. Chair Buck and Commissioner Driggs were designated; the roll call on that motion was recorded as five ayes, zero noes and one absent.

The planning commission also approved minutes for its April 15 meeting with no corrections recorded.

What stays unresolved

The audit identifies mandatory code changes the city must adopt to comply with state statutes and other, discretionary recommendations aimed at increasing housing capacity and flexibility. Commissioners and staff noted that many of the strategic policy trade-offs (for example, how much commercial floor-area requirement to retain in mixed-use districts) will be explored in the next project phase (code-and-plan concepts) and in public engagement this summer.

Quotes

"This first section has to do with legal compliance with state statute. So these are required and mandatory," Victor Tran said about the audit's required changes. Haley Campbell said the project team "hope[s] to finalize it tonight" and planned to present the audit to city council next week for input. Discussing RV occupancy, Tran said the city must allow RVs "to be used for residential occupancy with no time limit, in RV parks and manufactured home parks if they are sufficiently connected, to water, electricity, and sewage."

Ending

Staff will finalize the audit after incorporating commission and council input, then move into the concept and public-engagement phase this summer. Commissioners asked that the forthcoming public materials include clear visuals and explanations to help community members understand trade-offs between commercial requirements, mixed-use design and housing feasibility. The technical advisory committee will begin work on a monthly basis once organizers schedule the first meeting, and the two-member governance committee will provide interim policy direction during council's summer break.