HomeMy WebLinkAboutAgenda Item - 2020-10-26 - Number 06.1 - Staff Memo 10/23/20 w-Exh (LU 20-0016) '1 .i
MEMORANDUM
(731REGDta
TO: Planning Commission
FROM: Jessica Numanoglu, Planning Manager
Planning and Building Services Department
SUBJECT: Additional written testimony and rebuttal received
LU 20-0016 (Marylhurst Code Amendments)
DATE: October 23, 2020 MEETING DATE: October 26, 2020
At the October 12, 2020, Planning Commission public hearing on this matter, a request was made to
leave the record open per LOC 50.07.003.4.a.xi.The Commission elected to allow written testimony
only, and set the following deadlines:
• New testimony due by 5:00 pm on October 19
• Rebuttal to any new testimony received due by 5:00 pm on October 21
SUMMARY OF TESTIMONY RECEIVED
The main issues raised in the additional public testimony received were as follows:
• Subarea I-A should not be included in the area where multi-family residential use will be allowed
because it contains one historic building and is too small and constrained by resource overlays
to support additional development (Exhibits G-012, G-125, and G-214);
• A 45-foot tall building is too tall; any new multi-family development should be limited to two
stories to keep the "village" concept of the campus (Exhibit G-125);
• No access to multi-family development should be allowed from Gleason Dr. (a private drive) as
suggested in the staff report because it is substandard and doesn't have sidewalks (Exhibits G-
125 and G-214);
• Multi-family use should only be allowed in the area where the existing dormitories would be
removed and not the entire 50-acre campus (Exhibits G-012 and G-215);
• A new traffic study should be required because traffic has changed since Marylhurst University
ceased operations (Exhibit G-215). Others noted that traffic congestion on HWY 43 is a result of
population growth in the area and commuters coming from north of the City limits and 1-205,
and that the proposal would limit traffic to the same level as it was for the prior university
(Exhibits G-124 and G-125);
• The site is not appropriate for multi-family residential use because of the natural habitat areas,
steep slopes around the site, lack of shopping opportunities for residents, increased light
pollution, and too much density(Exhibit G-216); and
503.635.0215 380 A Avenue PO BOX 369 Lake Oswego, OR 97034 www.ci.oswego.or.us
Page 2
• The applicant would benefit from affordable housing on the site because they are a non-profit
organization that does not pay taxes and future residents of affordable housing on the site
would likely receive rent subsidies, and workers that may reside there would likely only be
receiving minimum wage (Exhibit G-217).
The applicant submitted testimony(Exhibit F-008) stating that Subarea I-A was never contemplated for
multi-family development, but was included only because it was part of the Marylhurst University
campus and formed a convenient boundary.The applicant proposes to remove Subarea I-A from the
request so that the proposed amendments to allow multi-family residential use in the CI zone would
only apply to Subarea I (see Exhibit E-001 for a map showing Subarea I).
Since the proposed area is smaller, the applicant provided a revised traffic study for the trip cap (Exhibit
F-008, pgs. 9-13).They found that the single building in Subarea I-A was not actually included in the
original trip cap analysis; therefore,the total square-footage for the 14 buildings in Subarea I used in the
analysis (see table on pg. 2 of Exhibit F-008) is the same and the trip cap is unchanged, except that the
trip cap would only apply to Subarea I.The applicant also submitted a revised calculation of the site area
with Subarea I-A removed, which is estimated to be 40 acres.
The applicant provided revised draft code amendments removing Subarea I-A from the area of the CI
zone where multi-family residential use would be allowed (Exhibit F-008, pgs. 4-6). The changes from
the original draft code amendments are highlighted in yellow for easy identification.
Only the applicant submitted rebuttal testimony during the rebuttal period (Exhibit F-009).The applicant
rebutted the testimony received that the area of the campus where multi-family residential use would
be allowed should be limited only to the area of the site where the existing dormitories would be
removed.The applicant argues that restricting the use to a specific and small area of the campus is not
practical or necessary because any future multi-family development would be adequately regulated by
existing and proposed code standards (and subject to Design Review)to assure compatibility with other
buildings on the campus, preserve historic landmarks, provide adequate buffering between the campus
and abutting residential uses, ensure adequate open space, parking, and landscaping, etc., and to
protect existing Sensitive Lands on the site.The applicant also noted that future development will be
limited by the trip cap, which will apply to both existing and proposed uses in Subarea I.They also note
that the campus could currently be redeveloped with other buildings, such as congregate care or office
buildings, and there is no reason to single out multi-family buildings. Finally, they contend that it would
be difficult and confusing to establish an arbitrary boundary that is a subset of Subarea I when site
features and lot lines can change in the future.
STAFF FINDINGS AND RECOMMENDATION
None of the public comments received cite any applicable comprehensive plan policies or criteria. With
regard to the comment that a 45-foot height limit for multi-family residential development is too tall
and should be limited to two stories,the 45-foot height limit is the existing height limit for all buildings
in the CI zone and is not proposed to be changed. Staff could find no plan policy or other basis for
establishing a different height limit for multi-family buildings.
Another comment stated that Gleason Drive (a private drive) should not be used for access to the
Marylhurst site as stated in the staff report. In the staff report, staff was only noting that there are two
existing access points to the overall campus (including Mary's Woods) at the signalized intersections of
503.675.3984 380 A Avenue PO Box 369 Lake Oswego, OR 97034 www.ci.oswego.or.us
Page 3
Holy Names Dr. (access road to Mary's Woods) and Furman Dr. (access road to Marylhurst). Gleason Dr.
provides an internal connection between Holy Names Dr. and Furman Dr.for travel between the two
areas of the overall campus. Staff did not intend to suggest that future multi-family use would only use
the Mary's Woods entrance via Gleason Dr.to access the new development. Access to any new multi-
family development on the Marylhurst campus would likely continue to be primarily from Furman Dr.
rather than from Holy Names Dr. because the latter is a longer and indirect route to the Marylhurst
campus; however, internal trips between Marylhurst and Mary's Woods would use Gleason Dr., as is the
case currently.
The applicant's proposal to exclude Subarea I-A does not affect compliance with the applicable policies
as discussed in the staff report. Staff has reviewed the revisions to the draft code amendments prepared
by the applicant and confirmed it eliminates all the amendments that were associated with Subarea I-A.
Staff recommends approval of the Comprehensive Plan and Community Development Code
amendments as revised on pgs.4-6 of Exhibit F-008 to remove Subarea I.
Exhibits received after the October 12t" hearing, listed below, are available at the following link
http://www.ci.oswego.or.us/boc pc/lu-20-0016-communitv-development-code-and-comprehensive-
plan-amendments-related-former. Go to the "Public Record of File" link on the right side of the screen.
Additional Testimony Submitted by Applicant After Publication of Staff Report/During New Evidence
and Rebuttal Periods:
APPLICANT'S WRITTEN EXHIBITS:
F-008 Applicant's additional testimony, dated 10-19-20
F-009 Applicant's rebuttal memo, dated 10-21-20
Additional Public Testimony Submitted After Publication of Staff Report/During New Evidence and
Rebuttal Periods:
TESTIMONY NEITHER FOR NOR AGAINST:
G-012 Letter from Paden and Norma Prichard, dated 10-15-20
TESTIMONY IN FAVOR:
G-124 Letter from Ray McGovern, dated 10-13-20
G-125 Letter from Richard Cronn, dated 10-19-20
TESTIMONY IN OPPOSITION:
G-214 Email from Simin Partovi, dated 10-13-20
G-215 Email from Amy and Steve Burford, dated 10-17-20
G-216 Email from Bill Schlaudecker, dated 10-18-20
G-217 Email from Carolyne Jones, dated 10-19-20
503.675.3984 380 A Avenue PO Box 369 Lake Oswego, OR 97034 www.ci.oswego.or.us
IBMDATE: October 19, 2020
TO: Jessica Numanoglu, City of Lake Oswego
jnumanoglu@ci.oswego.or.us
THE FROM: Debbie Cleek,The Bookin Group LLC
BODKIN
GROUP SUBJECT: Additional testimony for Marylhurst Commons LU 20-0016
LLC
The Society of the Sisters of the Holy Names of Jesus and Mary (SNJM) is submitting additional
testimony to respond to the written and oral testimony received by the Planning Commission at
Land Use& the hearing held on October 12, 2020.
Institutional
Planning
Amended Site(remove Subarea I-Al:
Policy Analysis As indicated at the Planning Commission hearing SNJM has never been considering development
in Subarea I-A of the Marylhurst Campus Intuitional Area (shown on the Marylhurst Campus map
Project in LOC 50.11.006:Appendix F).This area of the campus includes the historic"Education Building",
Management
a state recognized landmark, used by SNJM's as administrative offices and a stream corridor
Group covered by the Resource Protection Area overlay. With these historic and environmental
Facilitation protections in place,developing Subarea I-A is neither possible or practical,and was never under
consideration by SNJM.
Subarea I-A was included in the original proposal because Subareas I and I-A combined represent
all of the area that was previously used by Marylhurst University and zoned CI (Campus
Institutional) without the added OC (Office Campus) zoning which already allows multi-family
development. However, the concerns raised by adjoining neighbors at the public hearing about
potential development in Subarea I-A has led SNJM to determine that amending the proposal is
necessary to make it 100% clear that Subarea I-A is not under consideration for multi-family
development.
Included with this letter is annotated code language for both the Community Development Code
amendment and the Comprehensive Plan amendment that removes all references to Subarea I-
A.As a result of changing the proposed site,the additional amendment added by Planning Staff,
related to development in Subarea I-A being "located in a major building and no more than two
buildings" is no longer necessary and should be removed from the staff recommendation.
Reduced Acreage of Site:
Removing Subarea I-A from the proposal will reduce the overall site size effected by the
amendments. The maps in the Community Development Code that show the campus subareas
are conceptual and not easily scalable for the purposes of determining the size of Subarea I-A.
However, using LOMaps the total size of Subarea I-A equates to approximately 5.09 acres —
measured using the north property line of Parcel 2 of Partition Plat 2018-102 on the north edge,
and the centerline of Marylhurst Creek on the south edge.
140 SW I ItnAve. In addition,the original proposal stated that the total site size for the area of the campus zoned
Suite 500 CI was 50 acres, which included Parcels 1-3 of Partition Plat 2018-102, and did not include the
Portland,Oregon one-acre historic cemetery. However, as staff indicated at the public hearing, Parcel 1-the area
97205 that is directly adjacent to Highway 43 - is actually zoned Cl/OC and therefore was mistakenly
503.24 I.2423 included in the site area.This parcel totals 5.27 acres.Additionally, according to staff,the historic
bookingroup.com
cemetery which is zoned Cl (without the OC zone) should have been included in the proposal,
based solely on its CI zoning. To be clear, the historic cemetery is a state historic landmark,
LU 20-0016 EXHIBIT F-008/PAGE 1 OF 13
entirely undevelopable and not under consideration by SNJM for any future development
whatsoever. However,to be consistent with staff's interpretation of the site including everything
in the campus area zoned CI the one acre cemetery should be added back into the total site area.
With these two subtractions and the addition of the cemetery,the total site area for the proposal
is reduced to 40.64 acres. Or for simplicity 41 acres.A revised site plan,showing the amended 41
acre site has been provided with this letter.
Confirmation of Trip Cap:
The Traffic Memo prepared by Kittelson &Associates (Exhibit F-002 of the Staff Report) indicated
that the proposed trip cap was based on a total of 300,388 square feet consisting of 15 existing
buildings that had previously been used by Marylhurst University. Removing Subarea I-A which
includes the "Education Building"from the proposal would indicate that this square footage total
should be reduced. However, in re-confirming the total square footage with SNJM it turns out
that the Education Building was never included in the square footage total to begin with.
SNJM purchased the Education Building from Marylhurst University in 2015 to use the as their
administrative offices. At that point the building was no longer regarded as part of the formal
University. When Marylhurst University closed in 2018 and the ownership of all their buildings
reverted back to SNJM the Education Building was not part of this transfer. When preparing the
original amendment application and Traffic Memo there was a miscommunication with SNJM's
facility manager who provided the total square footage of only the University buildings included
in the 2018 transfer and not all the buildings on the original site plan. As such the Education
Building was excluded from the square footage total used in the Traffic Memo and no adjustments
to the Trip Cap are necessary.
The following table confirms the square footage of the 14 existing buildings that are included in
the trip cap calculation and confirms that total has not changed from 300,388 sq. ft.
Building Name Square Footage
B.P.John 63,850 sq.ft.
Aquinas 3,510 sq. ft.
Flavia Hall 13,252 sq.ft.
St Catherine's Hall 11,390 sq.ft.
St. Anne's Chapel 11,296 sq.ft.
Shoen Library 32,326 sq.ft.
Edwin Mayer Art Building 13,804 sq.ft.
Clark Commons 20,357 sq.ft.
Villa Maria 20,530 sq.ft.
Davignon Hall 38,336 sq.ft.
Marian Hall 33,627 sq.ft.
Thompson Hall 17,895 sq.ft.
O'Hara Hall 17,890 sq.ft.
Baxter Hall 2,325 sq.ft.
Total 300,388 sq.ft.
All of these buildings are shown on the Campus Map provided as Exhibit B of the original
application.
LU 20-0016 EXHIBIT F-008/PAGE 2 OF 13
An amended Traffic Memo by Kittelson & Associates has been submitted with this letter that
includes the following revisions:
- All references to Subarea I-A being included in the site area have been removed.
- The site area has been reduced to 41 acres.
- The number of existing buildings included in the trip cap has been changed from 15 to 14.
- The stated number of historic landmark buildings on the site has been reduced from 5 to 4.
It is important to clarify that the trip cap proposed with the amendments applies only to the
campus area shown on the site plan, which does not include Subarea I-A. Therefore, any trips to
or from any current or future uses located in Subarea I-A don't count towards this trip cap.
Conclusion:
The removal of Subarea I-A and the reduction of overall site area will help assure that the
proposed amendments align more accurately with the future 75-100 multi-family units SNJM is
considering on the site. By focusing the amendments only on Subarea I and preserving the existing
character of Subarea I-A it shows SNJM's commitment to preserving the historic character and
natural amenities on the site. Some of the written testimony submitted to the City suggests
prohibiting any future development in Subarea I-A. This suggestion is neither necessary, since
SNJM has never had any development plans for Subarea I-A, or appropriate, since this area has
been removed from the proposal. The future development rights of Subarea I-A are no longer
germane to the discussion of the amendments that are being proposed.
Attachments:
• Amended Community Development Code and Comprehensive Plan language
• Area measurement of Subarea I-A from LOMaps.
• Amended Site Plan
• Amended Traffic Memo
LU 20-0016 EXHIBIT F-008/PAGE 3 OF 13
COMMUNITY DEVELOPMENT CODE AMENDEMENTS
F1IAIY.U1IY4I SJ 04I04I aWf 111 I'1 I►I'1U1 I 1:l 111•'104 n 1 a iIUk►'1 W4•J►14►1
2. SPECIFIC STANDARDS FOR COMMERCIAL, MIXED USE, AND INDUSTRIAL ZONES
****
c. Standards Applicable to Specific Locations
****
v. Marylhurst Campus Site Subarea I
The uses in Subarea I (as shown on the Marylhurst Campus map in LOC 50.11.006: Appendix F)
are limited to those that collectively generate 327 or fewer trips during the AM weekday peak hour
and 351 or fewer trips during the weekday PM peak hour per the traffic memo submitted in LU
20-0016, Exhibit F-002.
1. CAMPUS INSTITUTIONAL ZONE
****
b. Site Development Limitations
i. Required yards are those needed to maintain the appearance and character of the Marylhurst
Campus.
Exception: No yard setback is required for residential development, except that residential
buildings shall be set back from the common line of abutting residentially-zoned lots a
distance equal to the height of the proposed residential buildings.
ii. There are no minimum lot area or dimensions.
iii. Maximum height of a structure is 45 ft.
c. Special Requirements
The approved plan for the Marylhurst Campus Institutional Area is contained in LOC 50.11.006: Appendix
F. The land use designations and conditions of that portion of the plan are by this reference made a part
of this Code and are conditions and limitations of the zone.
Exception: Multi-Family residential development shall be exempt from the requirements of
LOC 50.11.006: Appendix F.
****
LU 20-0016 EXHIBIT F-008/PAGE 4 OF 13
�.IAIXAj1IY4U}1 r_I:1 u q
****
3. COMMERCIAL, MIXED USE, INDUSTRIAL,AND SPECIAL PURPOSE DISTRICTS USE TABLE
TABLE 50.03.002-2: COMMERCIAL, MIXED USE, INDUSTRIAL AND SPECIAL PURPOSE
DISTRICTS USE TABLE
P = Permitted Use I Blank= Not Permitted I C = Conditional Use I A=Accessory Use
Use Category Use Type Special Use-Specific Standards
Purpose
CI PF I PNA
RESIDENTIAL USES
Household Residential use at R-5 P WLG zones: 50.03.003.1.a; NC,
Living density or greater GC,and EC, and CI zones:
50.03.003.2
2. RESIDENTIAL USES IN COMMERCIAL AND SPECIAL PURPOSE ZONES
****
c. CI Zone
1. (i) Multi-family housing use is limited to Subareas I a A as shown on the Marylhurst Campus
map in LOC 50.11.006: Appendix F, and shall consist of 20 or more units where at least 10% of
the units are continuously rented, leased or made available for an amount of rent plus expenses
associated with occupancy, such as utilities and fees. totaling not more than 30% of the income
level that is 80% of area median income according to the Clackamas County Housing Authority's
income limits for affordable housing, adiusted for household size.
c
s
****
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Campus Institutional: Definition
Land uses allowed in Campus Institutional areas are all Office Campus uses, including those for
educational, religious, social services, governmental agencies, related residential uses and facilities for
care of the handicapped or other special care needs, and multi-family dwellings located in a campus
setting which preserves a substantial amount of landscaping and open space and the character of
existing institutions.
GENERAL POLICIES
1. A mix of uses within the Marylhurst campus will be allowed, including educational, cultural, social,
governmental, office, and residential activities.
LU 20-0016 EXHIBIT F-008/PAGE 5 OF 13
2. The campus-like character of the area will be maintained as much as possible.
3. Traffic and access will be controlled to preserve the capacity of Pacific Highway and the intersections
at Marylhurst. Proper internal circulation will be provided.
4. The Willamette River Greenway will be preserved for scenic and recreational uses.
****
COMPREHENSIVE PLAN VOLUME II: NEIGHBORHOOD AND SPECIAL DISTRICT
PLANS
Marylhurst Area
****
POLICIES
1. A mix of uses within the Marylhurst campus will be allowed, including education, cultural, social,
government, office, and residential activities.
****
7. Establish permissible uses, intensities, development criteria and conditions for specific sub-areas with
the campus, in addition to other policies.
a. SUB-AREA I: CAMPUS INSTITUTIONAL
1. Allowed uses will include educational, religious, social service, governmental, institutional
housing, multi-family dwellings, and their supporting services.
2. The appearance and character of the present Marylhurst Education Center campus, especially
the scale of buildings, parking areas, building locations, materials, open areas and landscaping,
will be continued in new development. (Exception: The development standards of LOC Chapter
50 implement this policy for multi-family development.)
****
20. Encourage development of multi-family affordable housing in the Campus Institutional zone within
Subareas I and-I-A.
LU 20-0016 EXHIBIT F-008/PAGE 6 OF 13
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LU20-0016 MarylhurgfELE3fiiP dhs8A'thendments
KV KITTELSON 851SW 6th AVENUE,SUITE 600
f� & ASSOCIATES 204
P 50T3.228.5230 D 97F 503.273.8169
MEMORANDUM
Date: October 19, 2020 Project#: 25259
To: Will Farley, City of Lake Oswego Traffic Engineering
Sister Mary Rita Rohde, Society of the Sisters of the Holy Names of Jesus and Mary
Debbie Cleek & Chris Hagerman,The Bookin Group
From: Julia Kuhn & Chris Brehmer
Project: Marylhurst Campus
Subject: Transportation Planning Rule (TPR) compliance— Revised per City Comments
The Society of the Sisters of the Holy Names of Jesus and Mary (SNJM) is proposing to amend the Lake
Oswego Community Development Code (CDC) and Comprehensive Plan to enable multi-family housing
as a permitted use within the Subarea I portion of the Campus Institutional (CI) zone of the Marylhurst
Campus Institutional Area. As currently envisioned, these amendments are intended to enable the
provision of future affordable housing within the campus although no development is proposed at this
time.
As part of assessing the proposed amendments, compliance with the Statewide Planning Goals must be
addressed. The Oregon Transportation Planning Rule (TPR) implements Statewide Planning Goal 12,
"Transportation." OAR Sections 660-012-0060(1) and (2) apply to amendments to zoning map
designations.These sections establish a two-step process for evaluating an amendment's impacts on the
transportation system. First,the trip generation potential of the site assuming a "reasonable worst-case"
development scenario under the existing and proposed zoning is assessed. If the development under the
proposed zoning could increase the trip generation potential, additional operational analysis is required
to assess whether the rezone will "significantly affect" the transportation system. Conversely, if the trip
generation under the proposed zoning is equal to or less than that under the existing zoning, no
additional operational analysis is necessary to conclude that the proposal does not "significantly affect"
the transportation system.
This memorandum presents how the proposed amendments comply with both the TPR as well as
applicable City Comprehensive Plan Transportation Policies. As discussed herein, a trip cap is
recommended to limit existing and future site development on the Subarea I property to uses that
collectively generate 351 or fewer weekday PM peak hour trips(the number of trips previously generated
by Marylhurst University. With the trip cap in place, the proposed amendments to the CI zoning would
not have a significant transportation impact and would allow for compliance with City policies.
FILENAME:H.•125125259-MARYLHURST UNIVERSITY RE-USEI REPORTI FINAL IOCTOBER TPR MEMO FOR MARYLHURST 25259.DOCX
LU 20-0016 EXHIBIT F-008/PAGE 9 OF 13
Marylhurst Campus Project#:25259
October 2020 Page 2
Existing Campus Description
The Marylhurst Campus Institutional Area is generally located to the east of Highway 43 (Willamette
Drive) and south of Furman Drive in Lake Oswego and includes lands that are currently zoned CI and
Cl/OC (Office Campus). The requirements of the Campus Institutional Zone are addressed in Section
50.02.003 of the CDC. This zone regulates a special purpose district established for the Marylhurst
Campus. Further details on the purpose and regulations of this zoning are contained in Section 50.11.006
(Appendix F) of the CDC. As described in this section, the CI zone enables a mix of educational, cultural,
social,governmental and residential activities within a campus-like setting. Subarea I is proposed for the
amendment and is approximately 41 acres in size. The remainder of the land within the Marylhurst
Campus Institutional Area and owned by the SNJM is zoned Cl/OC,a designation that enables multifamily
housing.
Today, the Cl-zoned lands include the Marylhurst Cemetery, a stream corridor, and 14 buildings within
Subarea I that were previously used by the Marylhurst University. Four of the buildings within Subarea I
and the Cemetery are designated as historic resources. With the closure of the University, many of the
buildings are currently vacant and/or used as office space for small non-profit organizations. Each of the
buildings could be re-used in the future. As currently envisioned, only the three residence hall buildings
in the southeast corner of the campus would be removed and replaced with up to 100 affordable housing
units. These residence hall buildings are currently 38,110 square feet in size. Accordingly, the TPR
analyses first considers the impacts of replacing 38,100 square feet of campus space with 100 affordable
housing units.
Replacing the residence halls with multi-family units is presented as a "reasonable"future alternative for
TPR-based analyses versus a scenario that assumes the site would be completely redeveloped with no
existing buildings maintained and all new multi-family development added in its place (a complete
redevelopment as multi-family could be considered a "worse case redevelopment" analysis scenario for
TPR purposes but does not reflect the historic and community assets associated with the property nor
the future uses of the property).
Comparison between Existing Zoning and Proposed Amendment Trip Generation
As noted above, the area within the CI designated lands proposed to enable multi-family housing is
currently occupied by 38,110 square feet of residence halls. For the purposes of the TPR analysis,the trip
generation is based on the rates associated with a University/College within the Trip Generation Manual,
as published by the Institute of Transportation Engineers (10th Edition).This is reflected in Table 1.
As proposed, the amendment to the CI zoning would enable the provision of affordable housing on the
Subarea I portion of the campus site. The Trip Generation Manual does not include trip rates for
affordable housing for the general urban/suburban context, only a dense downtown context. Further,
this dense downtown data is limited in nature so the low-rise apartment rates (Land Use 220) were used
for trip comparison purposes.
Kittelson&Associates,Inc. Portland,Oregon
LU 20-0016 EXHIBIT F-008/PAGE 10 OF 13
Marylhurst Campus Project#:25259
October 2020 Page 3
Table 1. Comparison of Trip Generation Using Market Rate Multi-family Housing Trip Rates
Land Use ITE Code Size
Total Daily Weekday AM Peak Hour Weekday PM Peak Hour
Trips Total Trips In Out Total Trips In Out
Existing CI Zoning
University 550 38,110 sq ft 992 42 32 10 45 14 31
Proposed CI Amendment
Multi-Family 220 100 units 732 46 11 35 56 35 21
Difference between Proposed Amendment and Existing Zoning
Proposed—Existing -260 4 -21 25 11 21 -10
All trip rates are reflective of the average rate and not the fitted curve.Use of the fitted curve would not measurably change the results.
As shown in Table 1, the proposed amendment results in a decrease in daily trips; however, use of the
multifamily (market rate) housing rates would represent a small increase in weekday AM and PM peak
hour trip generation associated with the proposed amendments. Based on the TPR,this could constitute
a significant effect; however, as discussed below, a trip cap is proposed to address the potential impact
and no further operational analyses is needed. This trip cap is also reflective of the "reasonable
development scenario" analyzed for TPR purposes.
Overall CI Zoned Trip Cap
For future planning purposes, we estimated the trip generation associated with the Subarea I CI zoned
lands based on the previous University use in the 14 existing buildings. This trip generation can be used
to establish the "trip cap"associated with the existing CI zoned portions of the Campus within Subarea I.
Per information received from the SNJM, the total size of these buildings is 300,388 square feetl. The
estimated trip generation for the existing uses associated with the CI zoning within Subarea I is reflected
in Table 2.
Table 2. Overall Existing CI Trip Generation Estimate
Land Use ITE Code Size
Total Daily Weekday AM Peak Hour Weekday PM Peak Hour
Trips Total Trips In Out Total Trips In Out
University 550 300,388 sq ft 7,822 327 252 75 351 112 239
1 SJNM representatives indicate the campus building area consists of the following 14 buildings: B.P.John:63,850 square
feet; Aquinas: 3,510 square feet; Flavia Hall: 13,252 square feet; St Catherine's Hall: 11,390 square feet; St. Anne's
Chapel: 11,296 square feet; Shoen Library: 32,326 square feet; Edwin Mayer Art Building: 13,804 square feet; Clark
Commons: 20,357 square feet; Villa Maria: 20,530 square feet; Davignon Hall: 38,336 square feet; Marian Hall: 33,627
square feet;Thompson Hall: 17,895 square feet; O'Hara Hall: 17,890 square feet;and Baxter Hall: 2,325 square feet for
a total of 300,388 square feet.
Kittelson&Associates,Inc. Portland,Oregon
LU 20-0016 EXHIBIT F-008/PAGE 11 OF 13
Marylhurst Campus Project#:25259
October 2020 Page 4
The City can impose a trip cap of 351 weekday PM peak hour trips on the property to be rezoned, limiting
any future development to generate no more trips than the prior Marylhurst University use.This trip cap
will allow for a flexibility of future uses that comply with the proposed CI zoning amendments so long as
the cumulative trip generation of the uses remains at or under 351 weekday PM peak hour trips.
Accordingly, there will be no anticipated future increase in overall trip generation above what occurred
in the past and thus no new significant impact as defined by the TPR.
Transportation System Plan Considerations
The City's Transportation System Plan (TSP) includes an analysis of"existing" and future conditions along
Highway 43;the intersection within the TSP nearest to the Campus is Glenmorrie Drive.The TSP does not
address private streets and as such the operations at Highway 43/Furman Drive are not assessed. Instead,
we used the Glenmorrie Drive as a proxy for understanding the potential effects of the CI zoning. As
reflected in Figure 21 of the TSP Appendix', the weekday PM peak hour volumes on Highway 43 (as
measured in 2013)were approximately 1,990 vehicles per hour and the intersection operated acceptably
per the applicable Oregon Department of Transportation (ODOT) mobility target. Further, as discussed
in Section 6 of the TSP Appendix, the City does not intend to widen Highway 43 in the future.
TPR Findings
Based on the above, one can reasonably conclude that there are no TPR-related impacts associated with
the amendments and no further analyses should be required, given:
■ The use of the multi-family (market rate housing) trip rates would result in a decrease in
daily trips but a small increase in weekday AM and PM peak hour trips; this increase
represents an increase of 0.5 percent of the "existing" weekday PM peak hour traffic (i.e.,
11 trip increase/ 1,990 existing volume), less in the weekday AM peak hour, and even less
in the year 2035.
■ Recognizing that reasonable worst-case future site development could result in a small
increase in weekday AM and PM site trip generation compared to the prior university use,
we recommend a trip cap on the 50 acre portion of the campus where the proposed
amendments will apply.
■ Imposing a trip cap of 351 weekday PM peak hour trips on the property to be rezoned
would limit any future site development to generate no more trips than the prior university
use and thus no new significant impact could occur as defined by the TPR.
■ The Highway 43/Glenmorrie Drive currently meets ODOT mobility targets and is projected
to do so in the future per the TSP. As noted previously, this intersection was used as a proxy
for understanding the impacts of the amendments in lieu of the private Furman
Drive/Highway 43 intersection.
■ The City TSP establishes a directive to not widen Highway 43 in the future.
z httos://www.ci.oswego.or.us/sites/default/files/fileattachments/oublicworks/weboage/19139/final to tso-technical aooendices.odf
Kittelson&Associates,Inc. Portland,Oregon
LU 20-0016 EXHIBIT F-008/PAGE 12 OF 13
Marylhurst Campus Project#:25259
October 2020 Page 5
Comprehensive Plan Transportation Policy Considerations
In addition to the TPR,there are a number of policy-related considerations as part of the City's review of
the proposed amendments to the Marylhurst Area District Plan of the Comprehensive Plan to enable
multi-family housing as a permitted use within the CI zoned portions of the Marylhurst Campus. The
section below demonstrates how the proposed amendments to the CI zoning can be found to comply
with the applicable transportation policies.
Policy A.1 c. Minimize and/or mitigate adverse traffic impacts generated by new development on
adjacent neighborhoods;
Response:The proposed trip cap on the Cl-zoned property within Subarea I will limit the
combination of any current and future uses on campus within Subarea Ito generate no more
trips than the prior university use. As such, there is no new significant traffic impact as
defined by the TPR.
Policy 8-2. Provide street and frontage improvements such as dedicated facilities, landscaping, and street
lighting and permit amenities such as benches and shelters to encourage walking and biking as viable
travel modes,particularly along corridors that serve the primary transit network and employment centers,
town centers and neighborhood villages.
Response:The needed street and frontage improvements can be assessed in conjunction
with each future site development application. Today, the campus is served by system of
pathways connecting between buildings, a sidewalk along the eastside of Highway 43, and a
transit stop just north of the Furman Drive/Highway 43 intersection. The need for street and
frontage improvements are not applicable to the proposed Comprehensive Plan
amendments but rather to any relevant site development proposals in the future. As such,
this policy is met.
Policy 8-3. Require development, redevelopment, and public transportation improvement projects to
provide facilities that accommodate pedestrian, bicycle, and transit use, particularly in areas with
identified gaps in the transportation system and in all employment centers, town centers, neighborhood
villages, commercial corners, and neighborhood commons.
Response: As noted above, an existing pathway system connects buildings within the
campus, sidewalks are provided along Highway 43 and TriMet provides service to the
campus via Route 35, which connects Lake Oswego with the Oregon City transit center and
downtown Portland. Bike lanes are also provided along portions of Highway 43.The need for
additional multimodal facilities is not applicable to the proposed Comprehensive Plan
amendments but rather to any relevant site development proposals in the future. As such,
this policy is met.
Kittelson&Associates,Inc. Portland,Oregon
LU 20-0016 EXHIBIT F-008/PAGE 13 OF 13
DATE: October 21, 2020
TO: Jessica Numanoglu, City of Lake Oswego
jnumanoglu@ci.oswego.or.us
THE
BOOKIN FROM: Debbie Cleek,The Bookin Group LLC
GROUP
LLC SUBJECT: Rebuttal Testimony for Marylhurst Commons LU 20-0016
The Society of the Sisters of the Holy Names of Jesus and Mary (SNJM) is submitting a rebuttal
to written testimony provided to the Planning Commission prior to the close of the record on
Land Use& October 19, 2020.
Institutional
Planning
Summary of Comments Received by the City:
Policy Analysis
• Email from Norma and Paden Prichard (Exhibit G-012): This email suggests that
Project approving the proposed amendments to allow multi-family housing on the entire campus
Management
would compromise the historic buildings and jeopardize the visual, natural, and historic
Group aspects of the west side of campus.This email recommends that the rezoning should only
Facilitation be applied to the east side of the campus using the west property line of Parcel 3 of
Partition Plan 2018-102 as the demarcation line.
Note: This email also suggests removing Subarea I-A from the proposal and prohibiting
any further development in this Subarea.This issue has been addressed separately in the
letter from SNJM submitted to the City on October 19, 2020 (Exhibit F-008) in which
Subarea I-A was formally requested to be removed from the proposal. As such, the
development rights of Subarea I-A are no longer germane to the discussion of the larger
proposal.
Rebuttal:
SNJM does not agree with reducing the size of the area in which the multi-family use would be
allowed. At this point no specific development plans for the future 75-100 units of housing have
been developed and the specific area needed for the housing is still unknown.SNJM is committed
to having the future development be consistent with the existing campus setting and
architecture. This may result in shorter building(s) that require a larger footprint as opposed to
taller building(s) that would take up less site area. Additionally, there is a desire to provide
amenities to the housing such as daycare, a children's play area, outdoor recreation space, and
ample parking—all of which will require additional site area. SNJM requests the ability to
integrate the housing into the existing campus in a way that will best meet the needs of the
future residents without being subject to an arbitrary and limited site area.
Reducing the site area of the amendments (which currently covers 41 acres with the removal of
Subarea I-A) should not be supported by the Planning Commission for the following reasons:
1 140 SW I I th Ave.
• Development on the site is already adequately limited and controlled.Any development on
Suite 500 the Marylhurst Campus site is subject to a trio of requirements that already ensure that all
Portland,Oregon future development proposals protect the aesthetic, natural, and historic integrity of the
97205 campus.This includes:
503.241.2423 — The Marylhurst Campus Institutional Area (Appendix F of Chapter 50 of LOC) which
bookingroup.com includes policies that require that the "campus-like character" of the area be maintained
by addressing the architectural character of buildings (including the scale, height, bulk
LU 20-0016 EXHIBIT F-009/PAGE 1 OF 3
and materials) maintaining the open character of the property, preserving scenic vistas,
maintaining stream corridors, providing buffers to adjoining properties, and maintaining
a large setback to Highway 43.
— The City's Design Review process ensures public input on any future development
proposals on the campus and adherence to the development standards and policies of
the Marylhurst Campus Institutional Area.
— The proposed Trip Cap will limit any future development on the site to the level in place
in 2018 when Marylhurst University closed which will keep a check on future growth on
the site.
The rigor of the regulations already in place or to be added with this proposal assure that the
integrity of the west side of the campus will be maintained.
• Limiting multi-family housing does not limit development. Though SNJM currently have no
plans to develop any part of the campus beyond the 75-100 units of multi-family housing
currently under consideration, it is important to note that the CI Zoning currently allows a
variety of uses on the campus including: Group and Institutional Housing, Community
Institutional, Public Facilities,Business and Professional Services,Personal Services and Office.
Any of these uses that are allowed by right could be located in a new building sited anywhere
on the campus so long as the project met the development standards described in the
paragraph above. Therefore, limiting the area where multi-family housing can be located
creates no additional protection to the west side of the campus.These protections come from
the rigorous development standards and limitations included in the zoning code as it is written
today. There is no need to create an artificial constraint on the site that would dictate the
type of housing or the design of the project.
• Applying the amendments to only a small portion of the campus is essentially spot zoning.
"Spot zoning" is the process of singling out a small parcel of land for a use classification
different from that of the surrounding area for the benefit of some and the detriment of
others,and there is a long history of land use law showing that this type of zoning is not legally
supportable. The original proposal submitted by SNJM included all of the CI zoned campus, a
50-acre area easily recognized by its zoning designation. Based on public concerns the
proposal was reduced to just Subarea I, a 41-acre area clearly defined on the maps included
in Appendix F of the Zoning Code.
In both of these instances the area of the proposed amendments is a tract of land that has
already been identified by the City as having enough unique characteristics that it warrants
having a defined boundary,a specific zoning designation and a prescriptive set of regulations.
No evidence has been provided showing what characteristics exist on the east side of campus
that make it distinctive enough from the west side of the campus to warrant the application
of a different zoning on just this area alone.
• There is no agreed upon line to define the "east side of the campus". With any new zoning
code language it is important to consider the future application of the requirements. In other
words, will someone reading the zoning code 20 years in the future be able to consistently
interpret how and where the regulations should be applied. Currently, Subarea I is the
smallest recognized boundary bifurcating the campus and matches SNJM's current proposal.
To further limit the size of the site would require creating a new boundary that would need
to be able to clearly identify where the additional use is and is not allowed.
One proposal put forth in the written testimony is to define the "east side of the campus"
based on the location of existing roads or buildings on the site. This is problematic because
LU 20-0016 EXHIBIT F-009/PAGE 2 OF 3
there is no assurance that these roads and buildings wouldn't be removed, leaving the
location of the zoning line up to speculation in the future.
Another idea is to have the boundary of the amendments be the west property line of Parcel
3 of Partition Plat 2018-102, however, this parcel was created when Marylhurst University
still owned the property and it represents a different vision of the future of the campus. As
stated in the original application, if this lot line is left in place at all it would likely need to be
adjusted to match the development of the multi-family housing. As such, placing a zoning
demarcation line on a property line that can be moved at any time by the owner of the
property would not result in a zoning regulation that could be interpreted and applied
consistently in the future. Furthermore, since there is no minimum lot size in the CI zone this
lot line could be moved to virtually anywhere on the campus, making the intention of using it
to define the "east side of the campus" virtually meaningless.
The proposal as it is currently presented, which includes only Subarea I within the CI zone
represents a clearly defined and long recognized geographic boundary for the amendments.
Subarea I is already clearly illustrated in Appendix F of the zoning code and its location is
commonly agreed upon by the public. Furthermore, it represents the smallest subdivision of
the campus currently on record.
SNJM sees an acknowledged need in the community to provide workforce housing at an
affordable price and meeting this need aligns with their mission and commitment to serving the
community. They have renamed the project "Marylhurst Commons" because they envision the
campus being a community that welcomes everyone, including the neighbors who enjoy using the
campus for recreation, exercise, and communing with nature. The goal for the existing buildings
on site is to repurpose them in-part for community focused uses such as meeting rooms and
performance space. However, none of this vision can come to fruition without a full-time, on-site
community helping to support and enliven the campus.
In the original application SNJM fully demonstrated how the proposed amendments meet the
approval criteria of the zoning code and all of the applicable policies of the comprehensive plan.
Furthermore, the proposed amendments will help the City of Lake Oswego meet the affordable
housing and multi-family goals stated in the 2013 Housing Needs Analysis. The application
demonstrated that the City was drastically behind in meeting the housing goals set for 2035 and
the proposed amendments would help the City catch up without removing viable existing
buildings or developing a green-field site.
Therefore, we respectfully request that the Planning Commission allow SNJM the flexibility they
require by applying the multi-family use to all of Subarea I. City Staff has determined that the
proposal meets all of the relevant approval criteria. The written testimony submitted to the
Commission did not identify any approval criteria or policy that would be better met by restricting
multi-family housing to a smaller area of the site. These amendments will permit SNJM to
establish a housing community that addresses the residents needs and matches SNJM's mission
while still preserving the campus-like character of the site.While the University closure was a sad
moment for SNJM and the broader community, allowing a much-needed new use on the site can
help offset this loss.
LU 20-0016 EXHIBIT F-009/PAGE 3 OF 3
To: Lake Oswego Planning Commission
and
Jessica Numanoglu. jnumanoalu@ci.osweao.or.us
Iris McCaleb ,rccaleb@ci.osweao.or.us
Dear Jessica, Iris and Planning commission Members,
Please accept this additional written testimony regarding LU 20-0016
October/14/2020
To repeat somewhat our testimony from October 12, Norma and I are in favor of
the work force housing as originally described to the Marys Woods residents by
the Sisters of the Holy Names of Jesus and Mary. We do not believe the entire
Campus should be re-zoned. We understand a zoning area would typically
follow a property or land division line. There is now a land division line crossing
the eastern portion of the campus (see E-002 and F-0003) which in due course
may have to be re-aligned in order to build across. The applicant's narrative
(see note 1 mentions that lot line and indicates that it may have to be adjusted.
We ask that this re-zoning apply to that adjusted portion of the property. In the
future, if it becomes necessary or desirable for the SNJM to rezone additional
parts of the property, they could do so at that time.
If the SNJM is not willing to do that, then we ask that they, at the least, request
the City to re-state that portion of the staff report referring to Subarea 1 -A. And
indicate for Subarea 1 -A, that "NO NEW DEVELOPMENT shall be permitted in
this area."
(Note 1) (from Exhibit F-001/page 7 of 43 of applicant's narrative) " It is also
anticipated that a property line adjustment between existing Parcels 2 and 3
might be necessary to reconfigure the access and parking associated with the
new development."
Further: Under
Comp Plan Vol II
Marylhurst area
Policies
20. Encourage development of multi-family affordable housing in the
Subarea I. (delete Subarea I-A)
Portions of the staff report that refer to residential uses being permitted or
encouraged in Subarea I and Subarea I-A should ONLY refer to Subarea I ( the
SNJM has stated in their testimony before the PC that they DO NOT plan any
change to Subarea I-A, so we feel that area while it may be re-zoned should not
be listed as area for development We believe the Staff recommendation should
reflect that.
LU 20-0016 EXHIBIT G-012/PAGE 1 OF 3
Text in black below taken from the Marylhurst Master Plan.
Text in blue is my comment.
3. b. SUBAREA I-A: CAMPUS INSTITUTIONAL
Uses should be located in a major building and no more than two buildings.
There is now one major historic building on this site.
2. Design of access to the eastern portion of the site must provide for
emergency vehicles. The eastern portion of this site is all resource area, so
access is not possible.
3. Development may not occur beyond the top of the banks of the drainage
ways. Removal of trees will be minimized as much as possible. The top of the
bank is very close to the existing building and there are significant major trees to
the west of the building.
4. Access into the site must be designed to be compatible with the existing
Education Building, and should be located on the north side. On the north side of
this building is a resource area and the Marys Woods Campus so access is not
possible. Existing access is from the west, Gleason Drive, and is only possible
from this side.
5. Vehicle access or parking in the eastern portion of the site will be
discouraged. The east portion of this site is primarily a resource area.
6. Drainage management must be designed to prevent erosion of the banks of
the drainage ways which have a severe potential landslide hazard.
Please consider that by re-zoning the entire Marylhurst Campus, preservation of
these important buildings and the visual and historic aspect of the west side of
the Campus area could be jeopardized now, or in the future, if development is
permitted on the "Green". Even though the Sisters have stated they have no
intentions to develop the upper part of the Campus now . these statements
do not bind any future land owner. We fell that development should be limited to
the eastern part of the Campus.
Please continue this application, and request the applicant modify their request
as noted on the following page.
Respectfully submitted:
Norma and Paden Prichard
17555 Gleason Drive #113
Lake Oswego, OR 97034
LU 20-0016 EXHIBIT G-012/PAGE 2 OF 3
Attachment to letter from Norma and Paden Prichard:
We ask the SNJM to modify their request for a zone change as noted below:
We respectfully request the following modifications to the applicants request:
No change
Corrcction. Correction
Strikc out. Add text
I. APPLICANT'S REQUEST
The applicant is proposing to amend:
Comprehensive Plan, Vol. II, Marylhurst Area Special District Plan;
LOC 50.02.003.1 -- Campus Institutional Zone;
LOC Table 50.03.002-2 - Commercial, Mixed Use, Industrial and Special Purpose
Districts Use Table;
LOC 50.03.003.2 - Residential Uses in Commercial Zones; and
LOC 50.11 .006 - Appendix F - Marylhurst Campus Institutional Area
in order to add affordable multi-family dwellings as a permitted use in that portion of
Phasco Subarea I and I A as that area more or less identified in Exhibit F-001 as the
area of feasibility study, (Exhibit E-001) of the Campus Institutional (CI) zone on the
former Marylhurst University Campus site. No actual development is proposed at this
time.
The proposed amendments are detailed in Attachment B of draft Ordinance 2855
(Exhibit A-1). The Planning Commission will make a recommendation to City Council
after conducting a public hearing, using the quasi-judicial major development land use
review process.
STAFF RECOMMENDATION:
Approval of the proposed CDC and Comprehensive Plan amendments, with the
following additional CDC amendments:
Amend LOC 50.02.002.2.c, Standards Applicable to Specific Locations, adding a
new standard for Subareas I and I-A of the Marylhurst Campus limiting the combined
uses to those that collectively generate 327 or fewer trips during the AM weekday
peak hour and 351 or fewer trips during the weekday PM peak hour, as stated in the
traffic memo (Exhibit F-002);
Amend LOC 50.02.003.1 .b, CI Zone Site Development Limitations, adding a clear and
objective setback standard for residential development requiring a minimum setback
from any abutting residentially-zoned lots (including lots that are not in the City) that is
equal to the height of the proposed residential building.; and
Amend LOC 50.03.003.2 to require that residential uoes no new development shall be
permitted in Subarea I-A d in a majorhan two
buildings.
( While our wording is most likely not absolutely correct, I believe you will understand
our intent. ). N and P Prichard
LU 20-0016 EXHIBIT G-012/PAGE 3 OF 3
October 13, 2020
Jessica Numanoglu, A1CP
Planning Manager
380 A Avenue
PO BOX 369, Lake Oswego OR 97034
Dear Ms. Numanoglu;
I wish to rebut some of the comments made in opposition to the Affordable
Housing as planned on Marylhurst Commons by the SNJM Sisters at the City
Planning meeting held on evening of October 12, 2020.
Traffic:
The traffic problem on Hwy. 43 is not at the Marylhurst Commons, but at 1-205 to
the south and the north city limits of Lake Oswego. To say that no business,
housing, etc. should be added between those two points that will add to the
traffic congestion is ridicules. Hwy. 43 at the Marylhurst Commons is the only
section that is four lanes and has left-turn sections so not to slow traffic. The
traffic problem lies elsewhere and should be addressed elsewhere. The traffic
added by this venture would be no different than when Marylhurst University was
fully operating and will be less of a problem now as attested to by the traffic
study.
Property values:
One's home is their lifetime investment in the future and no one wants to see
their investment go down. The location of the once Marylhurst University, now
Commons, increased the property values around it by its "open space" and
appearance to the neighborhood. Slightly changing that appearance, which most
will not be able to see, should not lower any property values around the site.
Zoning:
The Planning Commission's staff was correct in how the property was re-zoned
and if, for some unforeseeable reason, the SNJM Sisters wish to make any
LU 20-0016 EXHIBIT G-124/PAGE 1 OF 3
changes they would have to make that request through the Planning Commission
which would control the changes; not the Sisters.
The SNJM Sisters have maintained and protected the property for over 100 years.
They could have put the property on the market when the University closed. The
value of the property would be in the millions. The Sisters do not view the
property as a benefit to them financially, but as a benefit to others who are in
need; it is their calling. How the site would be allowed to be used if sold would be
up to the Planning Commission. Would the Commission see it as a tax advantage
or used for low cost housing or whatever? That decision would definitely change
the overall ambiance of the neighborhood and the property values surrounding
the site?
As an 11 years resident of Lake Oswego I believe the Sister's vision is the correct
one for use of the property and will benefit both Lake Oswego and West Linn for
many years to come.
Thank y u for your time.
..41/d ..P.,/----
Ray McGovern
17440 Holy Names' Drive — Unit 413
Lake Oswego, OR 97034
(503) 635-1456
Mcgovern2239@comcast.net
LU 20-0016 EXHIBIT G-124/PAGE 2 OF 3
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October 19, 2020
TO:Jessica Numanoglu
Planning Manager
Lake Oswego, OR
RE: FILE 20—0016
17600 Pacific Highway
Lake Oswego, OR 97036
My name is Richard (Dick) Cronn
17565 Mesnard ST UNIT#303
Lake Oswego, OR 97034
(Mary's Woods)
I watched and listened to the entire Planning Commission meeting last Monday October 12,
2020 and read through the report and findings that were attached.
I have a few comments and questions.
Under III Background/ Existing Conditions
Item 2 in the first paragraph on page 4 it refers to 513 parking spaces—Is this on the 50 acre
Marylhurst campus alone or does it include all od Mary's Woods?
Under VI Findings on page 5, Policy A— 1 b. on the findings on page 7 it states "access to the
campus is limited to two points on to Pacific Highway". I assume Gleason Drive has been there
for many years so Marylhurst University personnel and students could have used it as well as
Furman Drive to access Pacific Highway. I would hope the direct route up Furman would be the
preferred choice as there are limited sidewalks on Gleason which we walk twice every day.
The traffic issue on Pacific Highway is brought up several times in the report such as on page 8.
Traffic count of 351 for PM peak hours and 327 for AM peak hours which was said it would be
the same as when the University was having its peak enrollment. I, as an individual, drove Hwy
43 from October 1994 through June 2018 twice a day in the morning busy time and the
afternoon busy time going from West Linn to southeast Portland and back. It would take about
20 minutes one way normally and when it was bad about 45 minutes. Some of the neighbors
across 43 spoke very strongly against the "huge" amount of traffic this zone change would bring
to which I say no.The population of our area has really grown.
On page 10- Policy A—5 Findings. I strongly oppose 1A included in the zone change for housing!
Similarly listed on page 24 as 1A for housing- NO. There is the historic building that is to remain
and no room for additional buildings with the water drainage, etc.
Throughout the application, maps and the findings it state that the proposed, in the future,
"affordable housing" will be located where the three existing dormitories are now.
LU 20-0016 EXHIBIT G-125/PAGE 1 OF 2
Under the Ordinance 2855 draft dated 10/1/20. 50.02.003 SPECIAL PURPOSE DISTRICTS 1.b.III
states the maximum height to be no more than 45 feet. It seems to me, even though the
application is for zone change only,this needs to be very thoroughly looked as I feel there
should be a maximum of two stories to create a "village" concept.
Bottom line is I am very much in favor of the concept of the zone change on sub-area 1 and the
mission and values of the SJNM. We are very thankful to be living here!
Our firm as a lathing and plastering subcontractor worked on multiple buildings at Marylhurst
University for over 25 years.
Thank you Jessica for your time,
Richard Cronn
503-250-0172
LU 20-0016 EXHIBIT G-125/PAGE 2 OF 2
Original Message
From: simin partovi <siminpartovi72@gmail.com>
Sent:Tuesday, October 13, 2020 6:17 PM
To: Swanson, Leah <Iswanson@ci.oswego.or.us>
Subject: Public Hearing Marylhurst Commons (LU 20-0016)
Greetings,
The Sisters of the Holly Names request regarding re-zoning and comprehensive plan amendments to
Subarea 1-A of Marylhurst Campus SHOULD be denied.
The Subarea 1-A is very much part of the Mary's Woods than a part of the Marylhurst University.
This area is the only open space affording the Rainault Building residents the view of natural
surroundings.
This is very much personal to me. I am one of the 67 senior adult residents of Rainault Building.
My 3rd floor apartment windows open up to this area. I do not wish that the beauty, and the peace ad
quiet Of my natural surrounding be disturbed by the traffic and crowds of Marylhurst Commons.
Further more,the Subarea 1-A is separated from Rainault by Gleason Drive, should not be allowed to
more traffic that it currently has.
Gleason Drive is a narrow, substandard street and had no sidewalks on either side.
It is the only access available to the walkers to walk themselves and their dogs everyday and
occasionally multiple times.
Allowing Gleason Drive to be used as one of the major accesses to the Highway 43 (as indicated in the
report) is dangerously UNSAFE and SHOULD NOT be permitted.
I believe,the Sisters request contradicts their promises and assurances to Mary's Woods residents.
Therefore,the Planning Commissioner of the city of Lake Oswego SHOULD deny the request to
amend the developmental codes regarding Subarea 1-A.
Respectfully submitted:
Simin Partovi
Mary's Woods Village
Rainault Building Unit#311
17555 Gleason Drive
Lake Oswego, Oregon 97034
408-921-2727
Sent from my iPhone
LU 20-0016 EXHIBIT G-214/PAGE 1 OF 1
From:Amy Burford <amyburfordmail@gmail.com>
Sent:Saturday, October 17, 2020 10:22 AM
To: Numanoglu,Jessica <jumanoglu@ci.oswego.or.us>
Cc: Steve Burford <steveburfordmail@gmail.com>
Subject: Re: Opposed - Request by Society of the Sisters of the Holy Names of Jesus and Mary
Hello Jessica,
After listening to the meeting on Oct 12, we would like to add to our previous comments. Thank you in
advance for forwarding this note appropriately.
Knowing more about the rezoning application by the Society of the Sisters of the Holy Names of Jesus
and Mary,we would like to state additional concerns about rezoning the former Marylhurst campus.
Rezone only 3 acres
If the area must be rezoned, which we oppose for the reasons in our previous email,why rezone the
entire 50 acre campus when only 3 acres are under consideration to be built as affordable housing? We
understand that additional steps need to be made to rezone only the existing dormitory land, but that
seems to be a very reasonable and common sense compromise. Please approach this radical change
slowly.
Traffic on Highway 43
Please require a new traffic study be conducted before approving the application. Traffic is not the
same as when the former university was granted it's number of trips. Please use current data.
Please protect the slippery slope we're on. Thank you very much.
Amy and Steve Burford
18265 River Edge Ct.
Lake Oswego
LU 20-0016 EXHIBIT G-215/PAGE 1 OF 1
McCaleb, Iris
From: Bill Schlaudecker <bschl26@comcast.net>
Sent: Sunday, October 18, 2020 4:40 PM
To: McCaleb, Iris
Subject: Testimony against Marylhurst Commons
Attachments: Hearing for Proposed Zoning Change for Marylhurst Commons.pages
About 8:30pm I lost my Zoom connection,but this is my testimony.
Bill Schlaudecker
17540 Mesnard St. No.300
Lake Oswego,Or 97034
503-705-2441
Sent from Bill Schlaudecker's iPad
LU 20-0016 EXHIBIT G-216/PAGE 1 OF 2
Proposed Marylhurst Commons Development
1 . Habitat destruction: The proposed development will forever damage
one of the last open parcels in Lake Oswego, one which is rich in
natural habitat, and the home of so much wildlife, and many old growth
trees. It is not uncommon to see deer, coyotes, skunk, raccoon, mink,
weasels, shrews, and innumerable bird species. Building a hundred
apartments, for 200 to 300 people, with parking, playground facilities,
lighting, underground utilities, trash facilities, and roads, will alter this
special property, forever.
2. Unsuitable for this location: Steep ravines and rock cliffs border this
parcel on 3 sides, making it unacceptably dangerous for children.
Also the entire property steeply drops from the highway, with the
proposed development occurring at the lowest point. In the winter
water accumulates there, and lingering fog is common. Temperatures
there are 5-10 degrees colder than they are in the hills. It's dreary and
unpleasant down there on winter nights.
3. No Shopping Nearby: It will be necessary for residents of these
apartments to drive to do their grocery shopping, but is likely that
many of them will not have vehicles. What will they do?
4. Light pollution: Extensive additional lighting will be required for the
proposed development. Mary's Woods, next door, just added much
brighter lighting to that campus, so the cumulative light pollution will
be seen from the surrounding neighborhoods.
5. Population density: The Mary's Woods retirement community has
approximately 600 residents and 300 support staff. Add another 300
renters in the Marylhurst Commons and there will be 1200 people living
or working in a 3 block area. How can that kind of density not have an
impact on local roads and community services?
LU 20-0016 EXHIBIT G-216/PAGE 2 OF 2
McCaleb, Iris
From: Carolyne Jones <jonescarolyne@hotmail.com>
Sent: Monday, October 19, 2020 5:19 PM
To: McCaleb, Iris
Subject: ADDITIONAL CITIZEN INPUT TTO BE SUBMITTED INTO THE PUBLIC RECORD FOR FILE
#LU 20-0016 - Society of the Sisters of the Holy Names of Jesus and Mary,PO Box 398,
Marylhurst, OR 97036Mary
At this time, in Lake Oswego, there is much attention on issues of Diversity, Equity, and Inclusion, so the
comments I share here will center on those terms to make the core points I will attempt to make regarding
this Application, which I cannot support and request that members of the Planning Commissions also consider
not supporting.
Upon reading the Application for this project I initially, wondered, why at a time when national attention is
focused on the consequences of the "Covid Pandemic" would a so called, Charitable Organization, with a Tax-
Free Status, seek a zone change on a large parcel of land currently zoned Campus Institutional (CI) in order to
build "affordable multi-family dwellings"? I believe the key toward answering that and other questions, lies in
the label, "affordable multi-family dwellings" as well as by answering to the question, affordable for who?
It is no secret that the people who the Applicant who claims will be the beneficiaries of the proposed housing,
who are commonly known as caregivers, usually receive minimum wages, if anything at all in cases where the
caregiver works for family members. Yet, the work can be very challenging and the same time very
tedious. In speculation, while some intended workers may be specialized and be able to earn higher-level
wages, it is unlikely that caregivers could purchase a home in Lake Oswego, at least not without personal
resources that they could contribute, but public rent subsidies could made available, from taxpayers could pick
up the tab for a portion of the rent.
The Applicant states in the application that their primary objective to is to preserve the Tax-Free Status, which
means, that all of the units built on the proposed Marylhurst Campus site, will necessarily be rentals, as the
coveted tax-free status could not be retained if the units were sold. From the standpoint of diversity, workers
from all over the world could potentially come and live on the site, where they could not accumulate equity,
but could enjoy living in close proximity to where they work. Living in close proximity, however, may be
considered a form of inclusion, but, is also could mean into being vulnerable to being "on call", a potential
detriment to a worker who likes to be able to depend on free time.
The Lake Oswego Library has a DVD, entitled, Casino Jack and the United States of Money, a film by Alex
Gibney, that provides
insight into how similar schemes have worked in the past, and
how they can impact a community.
Carolyne Jones
2818 Poplar Way
Lake Oswego, OR 97034
LU 20-0016 EXHIBIT G-217/PAGE 1 OF 2
From: Debbie Cleek<cleek@bookingroup.com>
Sent: Tuesday, October 20, 2020 11:23 AM
To: Numanoglu,Jessica <jumanoglu@ci.oswego.or.us>
Subject: Re:Additional Testimony- LU 20-0016
It is my understanding that the City received written testimony from Carolyn Jones yesterday at 5:19
pm, after the public record has been closed. SNJM waives any objection to including this testimony into
the public record even though it was not submitted in time.
Debbie Cleek, LEED AP
The Bookin Group
1140 SW 11th Ave, Suite 500
Portland, OR 97205
503.241.2423 (Office)
503.789.3211 (Cell)
LU 20-0016 EXHIBIT G-217/PAGE 2 OF 2