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Home My WebLink About02_Narrative City of Tigard: Comprehensive Plan Amendment Winterbrook Planning | August 2025 | Page 1 City of Tigard Steve Street Park Path Comprehensive Plan Amendment – Type -III – Modified Applicant: City of Tigard Public Works 13125 SW Hall Boulevard Tigard, OR 97223 Phone: (503) 718-2466 Applicant’s Representative: Grace Coffey, AICP Winterbrook Planning 610 SW Alder Street, Suite 810 Portland, Oregon 97205 Phone: 503-827-4422 Ext. 106 Site Location Map & Tax Lot Numbers: Base Zone: Sensitive Lands: Site Size: Land Use Review: Proposal protections from 0.03 acres of significant wetland buffer to allow for an 8-foot wide paved pathway to provide park access from SW Steve Street. City of Tigard: Comprehensive Plan Amendment Winterbrook Planning | August 2025 | Page 2 Contents Background ..................................................................................................................................... 4 Existing Conditions .................................................................................................................. 4 Project Purpose ....................................................................................................................... 8 Project Description ............................................................................................................... 10 Narrative Findings ......................................................................................................................... 11 1. City of Tigard Development Code (TDC) ............................................................................... 11 Parks and Recreation Zone (Chapter 18.140) ....................................................................... 11 Sensitive Lands (Chapter 18.510) ......................................................................................... 12 General Provisions (Chapter 18.710.030) ............................................................................. 16 Quasi-Judicial Amendments (Chapter 18.790.030) .............................................................. 18 2. Tigard Comprehensive Plan Consistency .............................................................................. 19 Goal 5: Natural Resources, Areas, and Open Spaces ............................................................ 19 Goal 8: Recreational Needs................................................................................................... 21 Goal 12: Transportation ........................................................................................................ 22 3. Statewide Planning Goals Consistency ................................................................................. 23 Goal 1: Citizen Involvement .................................................................................................. 23 Goal 2: Land Use Planning .................................................................................................... 23 Goal 5: Natural Resources, Scenic and Historic Areas, and Open Spaces ............................ 23 Goal 8: Recreational Needs................................................................................................... 24 Goal 12: Transportation ........................................................................................................ 24 Conclusion ..................................................................................................................................... 25 Citations ........................................................................................................................................ 25 City of Tigard: Comprehensive Plan Amendment Winterbrook Planning | August 2025 | Page 3 Exhibits • Exhibit A: Tigard Parks and Recreation System Plan • Exhibit B: ESEE Analysis • Exhibit C: Steve Street Park Natural Resources Report • Exhibit D: Wetland Delineation Report • Exhibit E: CWS Service Provider Letter • Exhibit F: Neighborhood Meeting Documentation • Exhibit G: Pre-Application Conference Notes • Exhibit H: Deed Acronyms • CPA: Comprehensive Plan Amendment • CWS: Clean Water Services • DSL: Oregon Department of State Lands • ESA: Environmental Science Associates • ESEE Analysis: Economic, Social, Environmental, and Energy consequences analysis • LWI: Local Wetland Inventory • SPL: Service Provider Letter • OAR: Oregon Administrative Rule • PR: Parks and Recreation Zone • TDC: City of Tigard Development Code Common Terms Significant Wetland: Wetlands in Tigard were deemed significant through a Goal 5 process in 2002, these significant wetlands are locally protected and are reflected in the Local Wetland Inventory. In Tigard “significant wetlands” and their Goal 5 protections via TDC Chapter 18.510 include both the wetland and the wetland buffer. Wetland Buffer: A buffer from the edge of a delineated wetland based on the vegetated corridor widths, described below. As noted above, in Tigard, the wetland buffer is included in the term “significant wetland” and is therefore locally protected. In the subject property, the wetland buffer is 50 feet. Vegetated Corridor: Regulated by CWS, a vegetated corridor is a strip of land surrounding a wetland or stream resource, based on Table 3.1, Vegetated Corridor Widths” and “Appendix C, Natural Resource Assessments” of the CWS “Design and Construction Standards. The vegetated corridor and wetland buffer are the same width around the subject wetland resource (50 feet in this case). City of Tigard: Comprehensive Plan Amendment Winterbrook Planning | August 2025 | Page 4 Background The City of Tigard (City) Department of Parks and Recreation is developing Steve Street Park1 to serve a park gap area identified in the City’s Park System Plan (Exhibit A). The 1.37-acre park will be located in northwest Tigard at the terminus of Steve Street and 84th Avenue, north of Highway 99 and east of Hall Boulevard (Figure 1). This is an underserved area that is more racially diverse, contains more multi-family homes, and has lower average household incomes than Tigard as a whole. The Steve Street Park Development project (Project) includes installation of a paved ADA- accessible path that would connect two dead end streets – Steve Street and SW 84th Avenue – to the commerce and residences along SW Hall Boulevard via SW Pfaffle Street. The path is currently established as an informal soft (unpaved) path and is within a 50-foot wide wetland buffer that is identified in the City’s Wetland and Stream Corridors map as a “significant wetland.” Significant wetlands are protected under Statewide Planning Goal 5 (Oregon Administrative Rule (OAR) 660-023-0100) and include wetlands and their associated buffers. The 8-foot-wide paved path would impact a 0.03-acre strip of a Goal 5 protected wetland buffer. The City protects all significant wetlands and does not allow landform alterations within wetlands or their buffers, per Chapter 18.510 of the City of Tigard’s Development Code (TDC). The City provides two mechanism for property owners to remove Goal 5 protection for mapped significant wetlands (including protected buffers): (1) a comprehensive analysis of environmental, social, economic, and energy (ESEE) consequences of the proposal to support a Comprehensive Plan Amendment (CPA) needed to remove Goal 5 protections for the impacted resource, or by (2) successfully demonstrating that the protected wetland no longer meets the significance threshold as defined in Goal 5 (OAR 660-023-0040). For this Project, the City prepared an ESEE analysis (Exhibit B) to evaluate the positive and negative consequences of allowing or denying the CPA needed to construct the proposed pathway. After assessing the ESEE consequences of the CPA, the City concluded that this CPA and subsequent construction of the proposed pathway in Steve Street Park has generally better consequences across the four categories than maintaining existing Goal 5 protections for the specific 0.03 strip of pathway area in the wetland buffer. Existing Conditions The 1.37-acre Steve Street Park property is zoned Parks and Recreation (PR) and is located on Tax lot WCTM 1S136CB Tax Lot 4402. The property is owned by the City of Tigard. The site is undeveloped, relatively flat, and open, allowing for high sun exposure and onsite views. The property gently slopes down to the north to an existing wetland. A tributary to Ash Creek runs through the wetland, creating a hydrologic connection to the headwaters of Ash Creek, an urban salmon-bearing stream in Tigard. 1 The project is part of the FY2022-23 Capital Improvement Plan project budget. City of Tigard: Comprehensive Plan Amendment Winterbrook Planning | August 2025 | Page 5 Figure 1: Vicinity Map The Tigard Local Wetland Inventory (LWI) depicts the wetland and wetland buffer in the northwest corner of the park property, extending off-site to the north and west (Fishman 1997). The LWI mapping of the site and adjacent properties was completed based on an off-site verification of data collected in 1989 (Fishman 1997). LWI’s provide approximate boundaries of wetlands and are not intended to replace site-specific wetland delineations. An on-site wetland investigation in 2024 concluded that the wetland and wetland buffer occupy a larger portion of the north end of the property compared to the LWI. Accordingly, the wetland buffer overlays the area where the paved path is proposed. The delineated wetland and proposed pathway are shown in Figure 2 below. The path and associated grading would impact 0.03 acres (1,437 square feet) of the wetland buffer. The wetland buffer within and adjacent to the proposed path footprint has been evaluated as a degraded vegetated corridor dominated by non-native pasture grasses and forbs (Exhibit C, Table 1). Two native trees (a Douglas fir and a big-leaf maple) are rooted along the eastern parcel boundary and contribute less than 25% canopy cover to the wetland buffer. No shrubs are present other than sprigs of Himalayan blackberry. Creeping buttercup and common dandelion are also present in the area of the proposed path. A 6-foot chain link fence within the southern and eastern portions of the on-site wetland buffer limits potential wildlife movement but will remain in place as part of the Project to prevent trespass onto adjacent private property. Utility lines, including sanitary sewer and stormwater, run underneath the proposed path area. Table 1. Vegetation within the Wetland Buffer Common Name Latin Name Percent Cover Holcus lanatus Poa annua Phalaris arundinacea Geranium molle Schedonorus pratensis Figure 2: Clip from Site Plan showing path impact to Wetland Buffer Figure 3: Path area looking north to Steve Street. Figure 4: Path area, wetland fencing to the left. Project Purpose The overall purpose of the Project is to serve a neighborhood of 616 Tigard residents in an area identified as park “Gap Area 11” in the City’s Parks and Recreation System Plan (City of Tigard, 2022). “Gap areas” are areas where residents are not able to access a park or natural area within a 10-minute walk of where they live. The Steve Street Park property was purchased with 2010 parks bond funds. The City will transform the existing undeveloped field into a neighborhood park to serve Gap Area 11 (Figure 5). The most significant issue addressed by the Project is fostering equity and inclusion across Tigard’s Parks system. Tigard identified twelve Gap Areas currently unserved by a park. Steve Street Park is being constructed ahead of other Gap Areas because it will serve a more racially diverse and economically challenged area. Figure 5. Clip from Tigard Parks and Recreation System Plan Tigard Parks and Recreation System Plan includes the following recommendation (page 47): “Tigard will pursue development of the Steve Street property, which will serve Gap Area 11. This parcel is well-located to serve Gap Area 11, which is densely populated and cut off from other parks by Highway 217. Development of a connecting trail from Hall Blvd, along large wetland complex along Oak Street, up onto the sidewalk over 217, down to Bagan Park, across Greenburg, under the rail bridge and ultimately to the Ash Creek Trail would provide a well- served recreation and transportation opportunity for Area 11.” Tigard Parks acquired a local share grant to fund part of the development of this park, which required extensive community engagement and informed the design of the park. Steve Street Park is also a critical recreation site supporting the Washington Square Regional Center area and is part of a plan to provide parks connected with comfortable bike/ped routes. Washington Square Regional Center (WSRC) is one of eight regional centers in the Metro regional growth plan because of its concentration of jobs and stores that are accessible from around the region via Highway 217, Hall Boulevard, Scholls Ferry Road, and multiple transit lines. The recreation services plan for this area is to develop open space and park sites that are connected through a system of comfortable pedestrian/bike routes (Figure 6). Steve Street Park is the southernmost park in this regional center. The existing informal pedestrian path along the wetland buffer is the only access to the regional center from the north side of the park. Otherwise, park users need to access the park from SW 84th Ave to the south, coming off SW Pfaffle Street. Figure 6: Clip from Washington Square Regional Center Update Final Report (2021) In summary proposed paved pathway is essential to the implementation of several city plans: the Tigard Park and Recreation System Plan, the Tigard Capital Improvement Plan, and the Washington Square Regional Center Plan – as well as the Metro Local Share grant that provided funding for Steve Street Park improvements. Project Description The proposed Project includes the installation of paved paths and trails (including a paved loop trail around the perimeter to facilitate transportation connectivity), the installation of a water quality facility in the northern portion of the park, and picnic and play areas. The CPA proposal would allow for the paving of an 8-foot-wide path in the wetland buffer. This path would provide access to the park from the north by connecting the park to Steve Street. The only other public access to the park is from SW 84th Ave to the south. Providing an accessible ADA path to the north is key for inclusive park access within a 10-minute walk of Gap Area 11. This relates to Tigard Parks and Recreation Strategy A1: Apply the 10-minute walk methodology when evaluating park access. This methodology uses the street and trail network (including bridges and over/undercrossings), factors in park pedestrian entrances and incorporates known barriers that limit access such as steep slopes and fences (see Appendix C). The proposed path is the only method for the park to connect to Steve Street and the northeast side of the park because wetlands cover the rest of the north side of the park. Additionally, formalizing this existing path will reduce the likelihood of users going off the path and trampling the remaining wetland buffer. Mitigation for the proposed encroachment will include replacing the impacted vegetated corridor with 3,790 square feet of mitigation and improve the existing vegetated corridor from a “marginal and degraded” status to a “good” condition. Proposed park development also includes restoring approximately 18,500 square feet (30% of the total site) to natural area, which will provide critical wildlife habitat within a highly urbanized neighborhood. Restoration of a degraded wetland buffer will significantly improve both the quality and quantity of wildlife habitat. Removing non-native species and replanting with a variety of native herbaceous plants, shrubs, and trees will provide year-round food sources and homes for urban wildlife in the area. Narrative Findings 1. City of Tigard Development Code (TDC) Parks and Recreation Zone (Chapter 18.140) 18.140.030 Other Zoning Regulations Sites with overlay zones, plan districts, inventoried hazards, or sensitive lands are subject to additional regulations. Specific uses or developments may also be subject to regulations as provided elsewhere in this title. Response: As identified in the Project description, the Project area contains sensitive lands, including significant wetlands (including wetland buffers) and Ash Creek vegetated corridor areas. The proposed pathway intersects with 0.03 acres of wetland buffer on the site. This narrative addresses the applicable provisions of TDC 18.510 for compliance. Sensitive Lands (Chapter 18.510) 18.510.050 General Provisions for Wetlands A. Code compliance requirements. Wetland regulations apply to those areas classified as significant on the City of Tigard “Wetland and Streams Corridors Map,” and to a vegetated corridor ranging from 25 to 200 feet wide, measured horizontally, from the defined boundaries of the wetland, as provided in “Table 3.1, Vegetated Corridor Widths,” and “Appendix C, Natural Resource Assessments,” of the CWS “Design and Construction Standards.” Wetland locations may include but are not limited to those areas identified as wetlands in “Wetland Inventory and Assessment for the City of Tigard, Oregon,” Fishman Environmental Services, 1994. Response: The Project area contains a wetland which is identified as a “significant wetland” on the City’s “Wetlands and Streams Corridors Map.” Environmental Science Associates (ESA) has field-verified the boundaries of this wetland, as shown in Exhibit D (the applicant’s wetland delineation report). The boundaries shown on these figures include vegetated corridors measured 50-feet horizontally from the delineated wetland boundary. The width of the vegetated corridor is based on Clean Water Services (CWS) standards (Design and Construction Standards, Chapter 3.03). The applicant has submitted a standard site assessment to CWS, which issued a service provider letter (Exhibit E). B. Delineation of wetland boundaries. Precise boundaries may vary from those shown on wetland maps; specific delineation of wetland boundaries may be necessary. Wetland delineation will be done by qualified professionals at the applicant’s expense. Response: ESA delineated the wetland boundaries within the Project area. The applicant’s wetland delineation report is included with this application as Exhibit D and was prepared by a team of qualified professionals, including wetland scientists and ecologists. The applicant has submitted the wetland delineation report to the Oregon Department of State Lands (DSL) for concurrence. 18.510.080 Special Provisions with Locally Significant Wetlands Along the Tualatin River, Fanno Creek, Ball Creek, and the South Fork of Ash Creek A. In order to address the requirements of Statewide Planning Goal 5 (Natural Resources) and the safe harbor provisions of the Goal 5 administrative rule (OAR 666-023-0030) pertaining to wetlands, all wetlands classified as significant on the City of Tigard “Wetlands and Streams Corridors Map” are protected. No land form alterations or developments are allowed within or partially within a significant wetland, except as allowed or approved in compliance with Section 18.510.100. Response: The Project area has a wetland identified as a “significant wetland” on the City’s “Wetlands and Streams Corridors Map.” ESA delineated the boundary of this wetland, as shown on Exhibit D. As previously described, the proposed pedestrian path intersects a small section of a wetland buffer. The applicant is requesting a CPA consistent with TDC 18.510.100 to remove Goal 5 protections from approximately 1,437 square feet, or 0.03 acres, of this significant wetland buffer to allow pathway development to occur. B. In order to address the requirements of Statewide Planning Goal 5 (Natural Resources) and the safe harbor provisions of the Goal 5 administrative rule (OAR 660-023-0030) pertaining to riparian corridors, a standard setback distance or vegetated corridor area, measured horizontally from and parallel to the top of the bank, is established for the Tualatin River, Fanno Creek, Ball Creek, and the South Fork of Ash Creek. 5. The standard setback distance or vegetated corridor area applies to all development proposed on property located within or partially within the vegetated corridors, except as allowed below: a. Roads, pedestrian or bike paths crossing the vegetated corridor from one side to the other in order to provide access to the sensitive area or across the sensitive area, as approved by the city in compliance with Section 18.510.070 and by CWS “Design and Construction Standards;” b. Utility or service provider infrastructure construction (i.e. storm, sanitary sewer, water, phone, gas, cable, etc.), if approved by the city and CWS; c. A pedestrian or bike path, not exceeding 10 feet in width and in compliance with the CWS “Design and Construction Standards;” d. Grading for the purpose of enhancing the vegetated corridor, as approved by the city and CWS; e. Measures to remove or abate hazards, nuisances, or fire and life safety violations, as approved by the regulating jurisdiction; f. Enhancement of the vegetated corridor for water quality or quantity benefits, fish, or wildlife habitat, as approved by the city and CWS; g. Measures to repair, maintain, alter, remove, add to, or replace existing structures, roadways, driveways, utilities, accessory uses, or other developments provided they are in compliance with city and CWS regulations, and do not encroach further into the vegetated corridor or sensitive area than allowed by the CWS “Design and Construction Standards.” Response: The Project consists of an 8-foot-wide pedestrian path that provides access across the sensitive area. These improvements have been designed in compliance with CWS “Design and Construction Standards.” Therefore, the standard setback and vegetated corridor area associated with Ash Creek do not apply. 18.510.100 Plan Amendment Option. A. Comprehensive plan amendment. Any owner of property affected by the Goal 5 safe harbor (1) protection of significant wetlands or (2) vegetated areas established for the Tualatin River, Ash Creek, Ball Creek, and the South Fork of Ash Creek may apply for a comprehensive plan amendment as provided in Chapter 18.790, Text and Map Amendments. This amendment must be based on a specific development proposal. The effect of the amendment would be to remove Goal 5 protection from the property, but not to remove the requirements related to the CWS Stormwater Connection Permit, which must be addressed separately through an alternatives analysis, as described in Section 3.02.5 of the CWS "Design and Construction Standards." The applicant must demonstrate that such an amendment is justified by either of the following: Response: Consistent with this provision, the applicant is proposing a CPA to remove Goal 5 protections from approximately 1,437 square feet, or 0.03 acres, of significant wetland buffer impacted by the Project’s proposed pathway improvements. The applicant is electing to meet the ESEE analysis option per TDC 18.510.100.B. B. ESEE analysis. The applicant may prepare an environmental, social, economic and energy (ESEE) consequences analysis prepared in compliance with OAR 660-23-040. 1. The analysis must consider the ESEE consequences of allowing the proposed conflicting use, considering both the impacts on the specific resource site and the comparison with other comparable sites within the Tigard Planning Area; Response: An Environmental, Social, Economic and Energy (ESEE) analysis is provided in Exhibit B of this application. The ESEE analysis was prepared to support the CPA decision process and describes the consequences of the proposed conflicting use. The ESEE analysis notes that, since the path proposal is specific to access to Steve Street Park, no other comparable sites exist within the Tigard Planning Area. Thus, this provision can be satisfied. 2. The ESEE analysis must demonstrate to the satisfaction of the city council that the adverse economic consequences of not allowing the conflicting use are sufficient to justify the loss, or partial loss, of the resource; Response: As described in the applicant’s ESEE analysis, the applicant has considered the economic consequences of prohibiting the conflicting use from occurring. As described in the Economic analysis section of the ESEE analysis: “Economic consequences for the proposed scenarios include city infrastructure costs and operational efficiency, construction jobs, and parks maintenance costs. Maintain Existing Protections The economic consequences of prohibiting conﬂicting uses and maintaining full wetland buffer protections mixed and generally negative. • Positive Consequences: There would be a short-term positive economic beneﬁt in that the City would save the up-front cost of building an accessible pathway and undergoing vegetated corridor restoration. • Negative Consequences: There may be slightly negative economic impacts of increasing park maintenance costs in the pathway area due to lack of paving. There is an opportunity cost in not providing an accessible pathway to Steve Street Park, as a key purpose of park development is to provide a neighborhood park in an identiﬁed Gap Area within a 10-minute walk of residents. If the pathway is not built and a park is not provided within a 10-minute walk of the residents, other park facilities may need to be acquired and built to meet this need Supporting plans, including the Tigard Parks and Recreation System Plan, the Washington Square Regional Plan, and the Capital Improvement Plan, relying on the Steve Street path to meet gap area needs would potentially need costly revisions. Economic benefits identified from Steve Street Park development (identified in the Washington Square Regional Plan and described in the Metro Local Share grant application) would be compromised. Allow Path Development Economic impacts of allowing path development are generally positive. • Positive Consequences: The property was bought with 2010 parks bond money to build a park in an underserved part of the community. The City identiﬁed the Steve Street Park development as a 2024 Capital Improvement Project and has invested in the neighborhood park. The pathway would deliver an important park function by providing a pedestrian connection to the north in an underserved area. Allowing the path development for park accessibility is aligned with the City’s funding priorities. The long-term investment in funding the Steve Street Park to meet the City and regional objectives, the use of the Metro Grand funding for improvements, the plans supporting the park and park connectivity (Tigard Parks and Recreation System Plan, the Capital Improvement Plan, Washington Square Regional Plan) would be able to be realized as planned and funded for. The pedestrian path along the VC is the only northern access to the Washington Square Regional Center, an area with a concentration of jobs and stores • Negative Consequences: The proposed change does not affect employment land. There are short-term costs to path construction efforts and mitigation efforts. Overall, the economic effects of allowing path development are positive, and aligned with the City’s funding priorities and decades of planning. This provision can be satisfied. 3. In particular, ESEE analysis must demonstrate why the use cannot be located on buildable land, consistent with the provisions of this chapter, and that there are no other sites within the Tigard Planning Area that can meet the specific needs of the proposed use; Response: The conflicting use (the 8-foot-wide accessible path) is specific to the wetland buffer resources at Steve Street Park. The park is designated as a neighborhood park and the path is key to providing equitable local park access. The installation of a path to Steve Street can only occur in the wetland buffer area. Nowhere else on the site can provide access to Steve Street and the rest of the northern part of the park is covered in significant wetland areas. This provision is met. 4. The ESEE analysis must be prepared by a team consisting of a wildlife biologist or wetlands ecologist and a land use planner or land use attorney, all of whom are qualified in their respective fields and experienced in the preparation of Goal 5 ESEE analysis; Response: The ESEE Analysis provided in Exhibit B was prepared by a qualified team consisting of land use planners (Winterbrook Planning) and environmental scientists (Environmental Science Associates) qualified in their respective fields with experience compiling such analyses. This provision is met. 5. If the application is approved, then the ESEE analysis must be incorporated by reference into the Tigard Comprehensive Plan, and the "Tigard Wetland and Stream Corridor Map" be amended to remove the site from the inventory. Response: Appendix A is designed to be readily incorporated into the Tigard Comprehensive Plan. This provision can be satisfied. C. Demonstration of change. In this case, the applicant must demonstrate that the sensitive area site no longer meets the applicable significance threshold defined by the Goal 5 administrative rule, relative to other comparable resources within the Tigard Planning Area. Response: The applicant is not asserting that the Project area’s significant wetland and buffer areas no longer meet the Goal 5 significance threshold. These provisions are not applicable. General Provisions (Chapter 18.710.030) 18.710.030 General Provisions A. Pre-application conferences. A pre-application conference is required for all Type II and Type III applications, except for Home Occupations, Extensions, and Complex Tree Removals. The Director may waive the requirement for a pre-application conference. Legislative actions are exempt from a pre-application conference. [...] Response: The applicant attended a pre-application conference with City staff on September 12, 2024. The notes issued by the City are included with this application as Exhibit F. B. Neighborhood meetings. A prospective applicant must hold a neighborhood meeting prior to filing the following applications: comprehensive plan map amendment (quasi-judicial), conditional use, major modifications, planned development review, sensitive lands review (Type II and III), site development review (Type II), subdivision, and zoning map amendment (quasi- judicial). Response: Neighborhood Meeting documentation is attached as Exhibit F. C. Application submittal. 1. Applications may be initiated by: a. All of the property owners, contract purchasers of the subject property, or any agent authorized to represent the property owners or contract purchasers. Easement holders are not considered owners for this section. If the subject property was divided without a partitioning or subdivision approval required by law at the time of the division, an application for approval of the land division may be filed by the owner, contract purchaser, or representative of one of the units of land created by the division; b. The Director; c. Tigard City Council; d. Tigard Planning Commission; or e. A public entity that has the right of eminent domain for projects the entity has the authority to construct. Response: This application is submitted on behalf of the City of Tigard Public Works, and a signed application form is included. 3. The application must include, at a minimum, the following items. The Director may waive items listed if they are not applicable to the proposed application. a. Application form, including signature of the property owner or public agency initiating the application. b. Deed, title report, or other proof of ownership. c. Detailed and comprehensive description of existing site conditions and all existing and proposed uses and structures, including a summary of all information contained in any site plans. d. Narrative that demonstrates how the proposal meets all applicable approval criteria, regulations, and development standards. e. Site plans, landscape plans, grading plans, elevation drawings, preliminary plat, final plat, or similar to scale. f. Any other materials required by a specific land use application. g. Any required service provider letters, including, but not limited to, clean water services, waste disposal company, or other entity. h. Any required studies or reports, including, but not limited to, a traffic impact analysis, wetland delineation report, or geotechnical report. i. Copy of any existing and proposed restrictions or covenants. j. Payment of all fees, based on the fee schedule in effect at time of submittal, as adopted by City Council. k. Copy of the pre-application conference notes, if applicable. l. Copy of the mailed neighborhood meeting letter, the mailing list, affidavits of mailing and posting, copy of the meeting sign-in sheets, meeting minutes, and any handouts provided at the meeting, including the site plan, if applicable. Response: The applicable items above are provided as follows: a. An application form is included with this package b. The vesting deed is included with this package as Exhibit H c. Existing site conditions and proposed uses are described in this narrative d. This narrative document demonstrated compliance with applicable criteria e. Site plans and graphics are included in this narrative and in Exhibit B (ESEE Analysis) f. An ESEE analysis is attached as Exhibit B g. A CWS service provider letter is attached as Exhibit E h. A wetland delineation report is attached as Exhibit D k. Preapplication conference notes are attached as Exhibit G l. Neighborhood Meeting documentation is attached as Exhibit F Quasi-Judicial Amendments (Chapter 18.790.030) A. Approval process. 1. A quasi-judicial zoning map amendment application that does not require a comprehensive plan map amendment is processed through a Type III-PC procedure, as provided in Section 18.710.080. 2. A quasi-judicial comprehensive plan map amendment application is processed through a Type III-Modified procedure, as provided in Section 18.710.090, which is decided by the City Council with a recommendation by Planning Commission. 3. A quasi-judicial zoning map amendment application that requires a comprehensive map plan amendment is processed through a Type III-Modified procedure, as provided in Section 18.710.090, which is decided by the City Council with a recommendation by Planning Commission. Response: The applicant is proposing to impact sensitive lands, including a significant wetland buffer, which is a Goal 5 resource. Per TDC 18.510.100, these impacts may only be approved through a comprehensive plan amendment, which is subject to the Type III-Modified review procedure. Therefore, this application shall be reviewed through the Type III-Modified process, with Tigard City Council as the review authority. B. Approval criteria. A recommendation or decision for a quasi-judicial zoning map amendment or quasi-judicial comprehensive plan amendment will be based on the following: 1. Demonstration of compliance with all applicable comprehensive plan policies and map designations; and Response: The applicant has reviewed and identified applicable comprehensive plan policies from the Tigard Comprehensive Plan related to the proposed Project and the proposed impacts to significant natural resources, including significant wetlands. Section 2 of the narrative findings addresses the applicable comprehensive plan policies, demonstrating how the Project is consistent and compliant with these policies. As demonstrated through the applicant’s findings provided in Section 2 of the narrative findings, this criterion is met. 2. Demonstration that adequate public services exist to serve the property at the intensity of proposed zoning. Factors to consider include the projected service demands of the property, the ability of the existing and proposed public services to accommodate the future use, and the characteristics of the property and development proposal, if any. Response: The proposal does not involve a change to the underlying zoning designation. The proposed amendments to the comprehensive plan to remove the “significant” designation from 1,801 square feet, or 0.03 acres, of wetland buffer areas impacted by the Project will have minimal impact on public services or demand for public services. This criterion is met. 2. Tigard Comprehensive Plan Consistency The applicant has reviewed and identified applicable comprehensive plan policies from the Tigard Comprehensive Plan related to the proposed Project and the proposed impacts to significant natural resources, including significant wetland buffers. The applicable goals and policies are set forth below, with findings demonstrating the Project’s consistency with these goals and policies. Goal 5: Natural Resources, Areas, and Open Spaces Goal 5.1 Protect natural resources and the environmental and ecological functions they provide and, to the extent feasible, restore natural resources to create naturally functioning systems and high levels of biodiversity. Policies 1. The City shall protect and, to the extent feasible, restore natural resources in a variety of methods to: A. contribute to the City's scenic quality and its unique sense of place; B. provide educational opportunities, recreational amenities, and buffering between differential land uses; C. maximize natural resource functions and services including fish and wildlife habitat and water quality; and D. result in healthy and naturally functioning systems containing a high level of biodiversity. Response: The north side of Steve Street Park is constrained by wetland natural resources and the associated buffer, offering no way to avoid the wetland buffer while still providing a connection to Steve Street. The applicant has designed the Project to avoid and minimize impacts to natural resources to the greatest extent practicable. The applicant will provide compensatory mitigation to ensure no net loss of significant functions and values. See the applicant’s ESEE analysis (Exhibit B) and CWS service provider letter (Exhibit E) for additional details on proposed mitigation methods. The Project will provide better access to recreational amenities. No buffering between land uses will be impacted. This policy is met. 8. The City shall protect and, to the extent feasible, restore the diverse ecological and non- ecological functions and services of streams, wetlands, and associated riparian corridors. Response: As described within the applicant’s ESEE analysis (Exhibit B) and the CWS service provider letter (Exhibit E), the applicant is incorporating mitigation measures to ensure the replacement of the functions and values of impacted resources. Further, as described throughout the submitted narrative and associated documents, the applicant has carefully designed the Project to avoid and minimize impacts to the significant wetlands and Ash Creek’s vegetated corridor areas to the maximum extent practicable. This policy is met. 10. The City shall complete a baseline inventory of significant natural resources and update or improve it as necessary, such as at the time of Comprehensive Plan Periodic Review, changes to Metro or State programs, or to reflect changed conditions, circumstances, and community values. Response: The City has conducted an inventory of natural resources in compliance with Statewide Planning Goal 5. The applicant is proposing amendments to the City’s “Wetlands and Streams Corridors Map,” a component of the Tigard Comprehensive Plan, to permit impacts to a significant wetland buffer area as described throughout this narrative and associated documents. The policy is met. 12. The City shall develop and implement standards and procedures that mitigate the loss of natural resource functions and services, with priority given to protection over mitigation. Response: The applicant has designed the Project to avoid and minimize impacts to natural resources to the greatest extent practicable; significant wetlands will not be impacted. The wetland buffer and Ash Creek vegetated corridor will be impacted, and the applicant will provide mitigation in compliance with CWS standards to ensure no net loss of significant functions and values. See CWS service provider letter (Exhibit E) for additional details on proposed mitigation methods. The policy is met. 13. The City shall identify, preserve, and create linkages between wildlife habitat areas, to the extent feasible, as a key component of parks, open space, and surface water management plans. Response: The applicant has delineated wetlands on the Steve Street Park site and included the delineation report as Exhibit D. No impacts or changes to the wetland are proposed; only the wetland buffer would be impacted. As discussed in the project description of this narrative, the area of the path will not impact high-quality habitat areas. The applicant has coordinated with CWS and provided a CWS natural resources site assessment, which details on-site mitigation and compliance with CWS standards. The policy is met. Goal 8: Recreational Needs Goal 8.1 Provide a wide variety of high-quality park and open spaces for all residents, including both: A. developed areas with facilities for active recreation; and B. undeveloped areas for nature-oriented recreation and the protection and enhancement of valuable natural resources within the parks and open space system. Response: The purpose of the Steve Street Park Project is to provide a neighborhood park for an underserved area of the City and an identified Gap area in the Tigard Parks and Recreation System Plan. Providing an accessible path will provide key pedestrian access to this community park. The park will include developed areas for active recreation and protection and enhancement of the wetland area within the Parks system. The policy is met. Policies 2. The City shall preserve and, where appropriate, acquire and improve natural areas located within a half mile of every Tigard resident to provide passive recreational opportunities. Response: The City of Tigard purchased the Steve Street property in 2010 to provide a park in an underserved area of the City. Neighborhood parks are intended to provide a variety of active and passive recreational opportunities for all age groups. As described within the applicant’s ESEE analysis (Exhibit B), the applicant is incorporating mitigation measures to ensure the replacement of the functions and values of impacted resources. Further, as described throughout the submitted narrative and associated documents, the applicant has carefully designed the Project to avoid and minimize impacts to the significant wetlands and Ash Creek’s vegetated corridor areas to the maximum extent practicable. Developing an accessible pathway near the wetland will provide the opportunity for passive recreational activities near the park’s natural areas. The policy is met. 4. The City shall endeavor to develop neighborhood parks [or neighborhood park facilities within other parks, such as a linear park] located within a half mile of every resident to provide access to active and passive recreation opportunities for residents of all ages. Response: The overall purpose of the Project is to provide a new park to a neighborhood of 616 residents of Tigard, for an area identified in the Parks and Recreation System Plan as lacking a park within a 10-minute walk of its residents. The proposed pathway will allow access to active and passive recreational opportunities consistent with this policy. 17. The City shall maintain and manage its parks and open space resources in ways that preserve, protect, and restore Tigard's natural resources, including rare, or state and federally listed species, and provide "Nature in the City" opportunities. Response: Th Project carefully evaluated natural resources within the proposed park area, identifying significantly more protected resources than Tigard originally mapped. The proposed location of the pathway provides the alignment with the least possible impact on natural resources while retaining park accessibility. The minor impacts are proposed to be mitigated as shown in Exhibit E. The proposal preserves, protects, and restores natural resources while providing “Nature in the City” opportunities, directly implementing this policy. 20. The City shall continue to improve access to neighborhood parks and other facilities in order to serve all citizens, regardless of ability. Response: People with mobility limitations are currently unable to access Steve Street Park from the north. The proposed path will be fully accessible to everyone, including those reliant on wheeled devices. The proposal improves access to a neighborhood park to serve all citizens, regardless of ability. The proposal directly implements this policy. Goal 12: Transportation GOALS AND POLICIES: 1. Provide a safe, comfortable, and connected transportation system for all users, especially pedestrians and other vulnerable users. Response: The Project implements this policy by creating an ADA-accessible pathway connecting Steve Street Park to Steve Street. This will provide a safe, comfortable, and connected transportation system related to the park, especially for pedestrians and pedestrians with mobility limitations. The policy is met. 2. Support environmental and community health by reducing our carbon footprint, minimizing impacts to natural resources, and addressing unequal health impacts/outcomes of our transportation system on low-income communities and communities of color. Response: The Project addresses disproportionate health impacts/outcomes for low-income communities and communities of color by providing a new park to a neighborhood of 616 residents of Tigard, identified in the Parks and Recreation System Plan as lacking a park within a 10-minute walk of its residents. The Gap Area is in an underserved part of the City that is also more racially diverse and economically challenged than Tigard generally. Providing this path will connect an underserved population to the neighborhood park while supporting environmental and community health by minimizing impacts to natural resources. The proposed pathway will not impact the wetland itself. Impacts to the wetland buffer will be mitigated by enhancing the quality of the vegetated corridor on-site. Allowing and encouraging pedestrian connections will reduce dependence on vehicle access to the park, reducing Vehicle Miles Traveled (VMT) and reducing the carbon footprint in the area. The policy is met. 4. Create livable neighborhoods that are designed to improve multimodal connections while discouraging unsafe interactions. Response: The Project supports this policy by adding a paved path from Steve Street Park to Steve Street, thereby encouraging pedestrian connections to the park and providing safer pedestrian facilities. The policy is met. 3. Statewide Planning Goals Consistency Goal 1: Citizen Involvement This goal outlines the citizen involvement requirement for the land use planning process, including the adoption of Comprehensive Plans and changes to the Comprehensive Plan and implementing documents. Response: Citizens, affected agencies, and other jurisdictions will be given the opportunity to participate in all phases of the planning process. Several opportunities for participation are built into the Comprehensive Plan Map amendment process, including public hearing notification requirements and neighborhood meeting requirements as documented in Exhibit F (TDC Chapter 18.710). This goal is satisfied. Goal 2: Land Use Planning This goal outlines the land use planning process and policy framework. Response: The Department of Land Conservation and Development (DLCD) has acknowledged the City’s Comprehensive Plan as being consistent with the statewide planning goals. The Development Code implements the Comprehensive Plan. The Development Code establishes a process and standards for reviewing changes to the Tigard Development Code in compliance with the Comprehensive Plan and other applicable state requirements. As discussed within this report, the applicable Development Code process and standards will be applied to the proposed amendment. The proposed plan amendment allows for consistency between the Parks and System Recreation Plan and Tigard’s natural resource protection program. This goal is satisfied. Goal 5: Natural Resources, Scenic and Historic Areas, and Open Spaces This goal outlines how cities must protect, inventory, and plan for natural and historic resources including waterways, groundwater, wildlife habitat, and trails. Response: In compliance with this goal, Exhibits C and D include an inventory of natural resources (wetlands and vegetated corridors) in the project area. The Project has been designed to avoid and minimize impacts to natural resources, including waterways, groundwater, wildlife habitat, and trails, to the greatest extent practicable. A CWS service provider letter is provided as Exhibit E. This goal is satisfied. Goal 8: Recreational Needs This goal requires local governments to plan for the recreation needs of their residents and visitors. Response: The Steve Street Park property was bought with 2010 bond money to build a park in an underserved part of the community. This Project will transform an undeveloped field into a neighborhood park. The Tigard Parks and Recreation System Plan includes recommended park improvements, including developing the Steve Street Park, and recommended trail connections to the north. The Parks and System Recreation Plan includes the following recommendation (page 47): “Tigard will pursue development of the Steve Street property, which will serve Gap Area 11. This parcel is well-located to serve Gap Area 11, which is densely populated and cut off from other parks by Highway 217. Development of a connecting trail from Hall Blvd, along large wetland complex along Oak Street, up onto the sidewalk over 217, down to Bagan Park, across Greenburg, under the rail bridge and ultimately to the Ash Creek Trail would provide a well- served recreation and transportation opportunity for Area 11.” The CPA proposal would allow for the paving of an 8-foot-wide path in the wetland buffer. This path would provide access to the park from the north by connecting the park to Steve Street. The only other public access to the park is from SW 84th Ave to the south. Providing an accessible ADA path to the north is key to providing inclusive park access within a 10-minute walk of Gap Area 11. This relates to Tigard Parks and Recreation Strategy A1: “Apply the 10-minute walk methodology when evaluating park access. This methodology uses the street and trail network (including bridges and over/undercrossings), factors in park pedestrian entrances and incorporates known barriers that limit access such as steep slopes and fences (see Appendix C).” This path is the only method for the park to connect to Steve Street and the neighborhood to the north because wetlands cover the rest of the north side of the park. This goal is satisfied. Goal 12: Transportation This goal outlines how each city must develop a transportation system plan that considers all modes of transportation. Response: The Project will pave an existing informal path to provide ADA-compliant pedestrian park access to Steve Street. Consistency with the city’s Transportation goals and policies is discussed in this report under applicable policies of the Tigard Comprehensive Plan. This goal is satisfied. CONCLUSION: Based on the above analysis, all statewide goals have been fully met. Conclusion As evidenced through this narrative and associated documents, the applicant’s proposed CPA request is consistent with all applicable local policies and regulations governing the allowance of this request. Therefore, the applicant requests approval of these applications. Citations City of Tigard, Oregon. (2022). FY 2022–2023 Capital Improvement Plan [PDF]. Tigard, OR: City of Tigard. Retrieved from City of Tigard website. City of Tigard, Oregon. (2025, March 4). Community Development Code (Title 18 of the Municipal Code). Retrieved from City of Tigard municipal code database. City of Tigard, Oregon. (2025, June 21). Wetlands and Stream Corridors (Map) Tigard, OR: City of Tigard, Environmental Services Department. Retrieved from City of Tigard maps portal. City of Tigard. (2022). Tigard Parks and Recreation System Plan [PDF]. Tigard, OR: Tigard Parks & Recreation Department. Retrieved from City of Tigard website. City of Tigard, Oregon. (2021, December). Washington Square Regional Center Update: Final Report & Recommendations. Tigard, OR: City of Tigard Community Development Department. Clean Water Services. (2019, December). Design & Construction Standards for sanitary sewer and surface water management: Resolution & Order 19-5 (as amended by R&O 19-22) [PDF]. Washington County, OR: Clean Water Services. Retrieved from Clean Water Services website. Fishman Environmental Services. (1997). City of Tigard Local Wetlands Inventory: Wetlands Assessment. Prepared for the City of Tigard, Oregon. December 1994; approved September 1997.