HomeMy WebLinkAboutAttachment 3 ESEE AnalysisCity of Tigard: Comprehensive Plan Amendment ESEE Analysis
Winterbrook Planning | August 2025 | Page 1
Exhibit B: ESEE Analysis
Introduction
The City of Tigard (City) is requesting a Comprehensive Plan Amendment (CPA) to
accommodate a paved pathway as part of the proposed Steve Street Park project (Project).
The City is developing Steve Street Park to serve a park “Gap Area” identified in the Tigard
Parks and Recreation System Plan (City of Tigard, 2022). “Gap Areas” are areas where
residents that are not able to access a park or natural area within a 10-minute walk of
where they live. 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. 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 Project includes paving an existing informal path within a 50-foot wide wetland buffer
that is identified on the City’s Wetland and Stream Corridors map as a “significant wetland”
(Figure 1). “Significant wetlands” are protected under Statewide Planning Goal 5, and in
Tigard, includes 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 landform alterations are not allowed within
wetlands or their buffers, as detailed in Chapter 18.510 of the City's Development Code
(TDC). The City provides two mechanism for property owners to remove Goal 5 protection
for mapped significant wetlands: (1) a comprehensive analysis of environmental, social,
economic, and energy (ESEE) supporting the 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 Oregon Administrative Rule
(OAR) 660-023-0040.
For this Project, the City prepared the following ESEE analysis to evaluate the positive and
negative consequences of allowing or denying the CPA needed to construct the proposed
pathway. The City assessed economic, social, environmental, and energy consequences
and has concluded that allowing the proposed CPA and constructing the proposed path
has generally better consequences across the four categories than maintaining existing
protections.
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
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Project Description
The proposed Steve Street Park will be located at 8400 SW Steve Street in Tigard,
Washington County, Oregon. The anticipated park development includes the installation of
paved walkways/trails (including a paved loop trail around the perimeter to provide
transportation connectivity), the installation of a water quality facility in the northern
portion, community garden beds, picnic and play areas, and parking with curb cut for
garden maintenance access at the southern portion of the park. The paved path would be
ADA accessible and 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 paved path and associated grading would encroach 1,437 square feet into the 50-foot
wetland buffer at the northeastern corner of the park. The City proposes to replace the
impacted wetland buffer/vegetated corridor at a minimum 1:1 ratio per Clean Water
Services (CWS) requirements. Mitigation would occur adjacent to the existing buffer, not to
exceed 3,790 square feet in area. Mitigation would include the removal of non-native
species followed by native plantings in between existing native trees within the mitigation
area. The Project would also improve the existing wetland buffer from marginal and
degraded to good condition with native plants.
Conflicting Use
Goal 5 Administrative Rule OAR 660-023-0010 defines “conflicting use” as “a land use, or
other activity reasonably and customarily subject to land use regulations, that could
adversely affect a significant Goal 5 resource (except as provided in OAR 660-023-
0180(1)(b)). The following sections present the ESEE decision process required under OAR
660-023-0040 and the City’s response to those requirements.
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
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Figure 1: Site Plan showing path impact to Wetland Buffer
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
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OAR 660-023-0040: ESEE Decision Process
(1) Local governments shall develop a program to achieve Goal 5 for all significant resource
sites based on an analysis of the economic, social, environmental, and energy (ESEE)
consequences that could result from a decision to allow, limit, or prohibit a conflicting use.
This rule describes four steps to be followed in conducting an ESEE analysis, as set out in
detail in sections (2) through (5) of this rule. Local governments are not required to follow
these steps sequentially, and some steps anticipate a return to a previous step. However,
findings shall demonstrate that requirements under each of the steps have been met,
regardless of the sequence followed by the local government. The ESEE analysis need not
be lengthy or complex, but should enable reviewers to gain a clear understanding of the
conflicts and the consequences to be expected. The steps in the standard ESEE process
are as follows:
(a) Identify conflicting uses;
(b) Determine the impact area;
(c) Analyze the ESEE consequences; and
(d) Develop a program to achieve Goal 5.
Response: The City of Tigard adopted its wetlands protection ordinance in 2002 to comply
with Oregon Statewide Planning Goal 5. A key component of the ordinance was the
establishment of the Water Resources Overlay District, which aims to protect water
resources. Tigard created the "Wetlands and Streams Corridors Map," which inventoried all
wetlands classified as significant within the City. All significant wetlands were protected,
and no landform alterations are allowed within wetlands or wetland buffers (TDC Chapter
18.510).
Figure 2 shows the location and approximate size of significant wetlands and streams
identified on the Local Wetland Inventory (LWI) in the Steve Street Park vicinity. The LWI was
completed in 1994 and has an estimated accuracy of +/- 15 feet. On-site delineations are
typically performed in development scenarios to determine more accurate boundaries.
The applicant’s wetland delineation report is included in this application. As shown on the
site plan, the delineated wetland is larger than that of the LWI; therefore, the 50-foot buffer
extends further to the east across the north end of the property.
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
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Figure 2: Comparison of LWI versus Delineated Wetland
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
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Figure 2 shows the LWI wetlands in the northwest corner of the Steve Street property
compared with the delineated wetland, extending further southeast into the property, on
the right side of the image.
(2) Identify conflicting uses. Local governments shall identify conflicting uses that exist, or
could occur, with regard to significant Goal 5 resource sites. To identify these uses, local
governments shall examine land uses allowed outright or conditionally within the zones
applied to the resource site and in its impact area. Local governments are not required to
consider allowed uses that would be unlikely to occur in the impact area because existing
permanent uses occupy the site. The following shall also apply in the identification of
conflicting uses:
(a) If no uses conflict with a significant resource site, acknowledged policies and
land use regulations may be considered sufficient to protect the resource site. The
determination that there are no conflicting uses must be based on the applicable
zoning rather than ownership of the site. (Therefore, public ownership of a site does
not by itself support a conclusion that there are no conflicting uses.)
(b) A local government may determine that one or more significant Goal 5 resource
sites are conflicting uses with another significant resource site. The local
government shall determine the level of protection for each significant site using the
ESEE process and/or the requirements in OAR 660-023-0090 through 660-023-0230
(see 660-023-0020(1)).
Response: For this ESEE analysis, there is only one conflicting use under consideration –
the planned pathway within existing resource area (the wetland buffer). The intent is to
allow for the paving of an existing unimproved path within the wetland buffer. No
development is allowed in wetland buffers; however, the Tigard Development Ordinance
and Goal 5 allow for amendments to the comprehensive plan to remove Goal 5
protections. Such requests require a comprehensive analysis of environmental, social,
economic, and energy (ESEE) consequences. This ESEE analysis is for the portion of the
proposed paved pathway that is within the Goal 5 protected wetland buffer.
(3) Determine the impact area. Local governments shall determine an impact area for each
significant resource site. The impact area shall be drawn to include only the area in which
allowed uses could adversely affect the identified resource. The impact area defines the
geographic limits within which to conduct an ESEE analysis for the identified significant
resource site.
Response: The impact area for this site-specific ESEE analysis is the 1.37-acre Steve Street Park
property. In contrast, the on-site wetland buffer area that will be disturbed by the paved
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
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pathway is 0.03 acres. The area of impact within the wetland buffer is shown with cross-
hatching (grading) and solid gray shading (pavement) in Figure 3.
Figure 3: Clip from Site Plan
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
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(4) Analyze the ESEE consequences. Local governments shall analyze the ESEE
consequences that could result from decisions to allow, limit, or prohibit a conflicting use.
The analysis may address each of the identified conflicting uses, or it may address a group
of similar conflicting uses. A local government may conduct a single analysis for two or
more resource sites that are within the same area or that are similarly situated and subject
to the same zoning. The local government may establish a matrix of commonly occurring
conflicting uses and apply the matrix to particular resource sites in order to facilitate the
analysis. A local government may conduct a single analysis for a site containing more than
one significant Goal 5 resource. The ESEE analysis must consider any applicable statewide
goal or acknowledged plan requirements, including the requirements of Goal 5. The
analyses of the ESEE consequences shall be adopted either as part of the plan or as a land
use regulation.
Response:
ESEE Analysis
The following analysis examines the positive and negative ESEE (Economic, Social,
Environmental, Energy) consequences of maintaining wetland buffer protections (Prohibit
conflicting use) in the 0.03-acre pathway area and the positive and negative ESEE
consequences of removing these protections from 0.03 acres to pave the existing
unimproved path (Allow conflicting use). Notably, other protections, such as vegetated
corridor protections regulated by CWS, will continue to stay in place regardless of changes
to wetland buffer protections.
Each consequence given a rating. -1, 0, or +1.
• -1 represents negative consequences, on balance.
• 0 represents neutral or mixed consequences.
• +1 represents positive consequences, on balance.
Economic Consequences
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.
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
Winterbrook Planning | August 2025 | Page 9
• 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.
Rating = -1
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.
Rating = +1
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
Winterbrook Planning | August 2025 | Page 10
Social Consequences
Social consequences of the two scenarios include aesthetic and scenic, health,
recreational, educational, and social equity.
Maintain Existing Protections
The social consequences of prohibiting conflicting uses and maintaining full wetland buffer
protections in the pathway area are limited and negative.
• Positive Consequences: None anticipated.
• Negative Consequences: The property was bought with 2010 parks bond money to
build a park in an underserved part of the community. The Tigard Parks and
Recreation System Plan includes recommended park improvements, such as
developing Steve Street Park with recommended trail connections to the north, as
shown in Figure 4 below (see Gap Area 11).
Figure 4: Clip from Tigard Parks and Recreation System Plan
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
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• The most significant issue addressed by the Project is fostering equity and inclusion
across Tigard’s Parks system. The overall purpose of this project is to provide a new
park to a neighborhood of 616 Tigard residents, identified in the Parks and
Recreation System Plan as not having a park within a 10-minute walk. 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. Maintaining protections where the
path is would limit the benefits of a neighborhood park in an underserved part of
Tigard, thus have negative social consequences.
Rating = -1
Allow Path Development
The social consequences of allowing conflicting uses and the proposed path are positive.
• Positive Consequences: The proposed amendments facilitate the timely
development of the park pathway, consistent with adopted plans. The property was
bought with 2010 parks bond money to build a park in an underserved part of the
community. The Tigard Parks and Recreation System Plan includes recommended
park improvements, including developing Steve Street Park with recommended trail
connections to the north, as shown in Figure 5 above (see Gap Area 11). The most
significant issue addressed by the Project is fostering equity and inclusion across
Tigard’s Parks system. The overall purpose of the Project is to provide a new park to
a neighborhood of 616 Tigard residents, identified in the Parks and Recreation
System Plan as not having a park within a 10-minute walk. 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. Neighbors in a 10-minute walk of the park are
expected to benefit most. This area has 266 households and a population of 616: a
higher percentage of Hispanic residents (12.3% compared to 11% citywide), a
higher percentage of black residents (3.5% compared to 2% citywide), 9% live below
the poverty line. The Park will also benefit the Washington Square Regional Center,
home to 2000 residents. It is identified as a destination to be linked by a ped/bike
trail loop connecting Bagan Park to the west and future mall property parks to the
north. WSRC is more diverse and has above average indicators of potential
disadvantage compared to Tigard overall.
• Negative Consequences: None anticipated.
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
Winterbrook Planning | August 2025 | Page 12
Rating = +1
Environmental Consequences
Environmental consequences of proposed changes include effects on water quality,
hydrologic control, wildlife habitat, and trees. Notably, the proposed changes would not
affect the vast majority of existing environmental protections at the Steve Street Park site,
including CWS vegetated corridor protections and wetland protections.
Maintain Existing Protections
Environmental consequences of maintaining existing protections in the path area would be
limited and mixed.
• Positive Consequences: Ecological values of this area are documented in the CPA
narrative as follows:
“The area within and adjacent to the path footprint is considered to be a degraded
vegetated corridor. The area of wetland buffer that would be impacted by this path is
dominated by non-native pasture grasses and forbs including the following listed
below. A couple native trees (Douglas fir, big-leaf maple) are rooted along the
eastern parcel boundary, but they contribute less than 25% canopy cover and no
shrubs are present other than sprigs of Himalayan blackberry. Creeping buttercup
and common dandelion are also present in the utility corridor. A 6-foot chain link
fence within the southern and eastern portions of the on-site wetland buffer limits
potential wildlife movement and further degrade the vegetated corridor. However,
this chain link fence will remain in place as part of the project to prevent trespass
into the adjacent private property. Additionally, utility easements exist where the
path is proposed, sanitary sewer lines and stormwater lines run underneath the path
area.”
Habitat values that would be protected are very limited. Maintaining protections
may allow for restoration that could introduce higher habitat values in the area in
the future and would limit any additional impervious surface in the area.
• Negative Consequences: Protecting this area from path development would have
the opportunity cost of the required vegetated corridor mitigation proposed as a part
of the Project. This would mean that 3,790 square feet of park area near the wetland
buffer would not be enhanced. Without a formalized path, pedestrian traffic may be
more likely to stray into and negatively impact higher habitat value areas nearby.
Rating = 0
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
Winterbrook Planning | August 2025 | Page 13
Allow Path Development
The environmental consequences of allowing conflicting uses and allowing the proposed
formalization of the pathway would be mixed and limited, but generally positive.
• Positive Consequences: Formalizing and paving the pathway would potentially
reduce deviations from the path into more sensitive vegetated corridor/wetland
buffer areas. Additionally, due to vegetated corridor impacts, onsite mitigation is
proposed. Park development will include restoring approximately 18,500 square
feet (30% of the total site) to natural area. Impacts to the vegetated corridor and
wetland buffer will be mitigated in an area not to exceed 3,790 square feet, and the
vegetated corridor area will be improved from “marginal or degraded status” to
“good” condition”. This restoration will replace nonnative ground cover with native
vegetation. Despite the conversion of a small portion of degraded wetland buffer to
a paved pathway, the overall functions and values of both the on-site wetland and
the larger wetland system will be maintained and enhanced through strategic
restoration efforts and improved habitat quality. The natural area will provide critical
wildlife habitat within a highly urbanized neighborhood. Restoration of a degraded
wetland and 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. No impacts to the wetland itself are
proposed.
• Negative Consequences: Paving the path would create disturbance within 50 feet of
a wetland, and add 982 square feet of impervious surface, creating a slight change
in water hydrology near a wetland. As described above, the habitat values in the
area of disturbance are limited and impacts to the vegetated corridor would be
mitigated.
Rating = +1
Energy Consequences.
Energy consequences considered for the scenarios include transportation connectivity
(VMT) and efficient urban development.
Maintain Existing Protections
The energy consequences of prohibiting conflicting uses and maintaining full wetland
buffer protections in the pathway area would be limited and slightly negative.
• Positive Consequences: None anticipated.
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
Winterbrook Planning | August 2025 | Page 14
• Negative Consequences: Maintaining protections would potentially result in less
energy-efficient park access by restricting effective pedestrian access to the south
from SW 84th Ave. This could increase vehicle miles traveled (VMT) and associated
greenhouse gas emissions.
Rating = -1
Allow Path Development
The energy consequences of allowing conflicting uses and allowing the proposed pathway
amendments would be mixed but slightly positive.
• Positive Consequences: There may be long-term transportation efficiencies by
allowing access to the park from the north. Otherwise, park users from the north
would need to circle around and access the park from SW 84th Ave to the south.
• Negative Consequences: Short-term energy costs include construction efforts.
Rating = +1
ESEE Analysis Conclusion
As described in the analysis above and summarized in the table below, economic and
energy consequences are limited, and the proposed amendment to allow a pathway has
generally better consequences across the four categories than maintaining existing
protections.
ESEE Summary Table
Economic -1 +1
Social -1 +1
Environmental 0 +1
Energy -1 +1
Allowing path development within the wetland buffer, paired with the approved mitigation
associated with vegetated corridor impacts, presents a net benefit under the ESEE
framework. This scenario allows the City to provide reasonable access to a neighborhood
park to an underserved area in the City and can result in a net ecological gain with on-site
mitigation.
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
Winterbrook Planning | August 2025 | Page 15
(5) Develop a program to achieve Goal 5. Local governments shall determine whether to
allow, limit, or prohibit identified conflicting uses for significant resource sites. This
decision shall be based upon and supported by the ESEE analysis. A decision to prohibit or
limit conflicting uses protects a resource site. A decision to allow some or all conflicting
uses for a particular site may also be consistent with Goal 5, provided it is supported by the
ESEE analysis. One of the following determinations shall be reached with regard to
conflicting uses for a significant resource site:
(a) A local government may decide that a significant resource site is of such importance
compared to the conflicting uses, and the ESEE consequences of allowing the conflicting
uses are so detrimental to the resource, that the conflicting uses should be prohibited.
(b) A local government may decide that both the resource site and the conflicting uses are
important compared to each other, and based on the ESEE analysis, the conflicting uses
should be allowed in a limited way that protects the resource site to a desired extent.
(c) A local government may decide that the conflicting use should be allowed fully,
notwithstanding the possible impacts on the resource site. The ESEE analysis must
demonstrate that the conflicting use is of sufficient importance relative to the resource site,
and must indicate why measures to protect the resource to some extent should not be
provided, as per subsection (b) of this section.
Response: Removing a 0.03-acre area from wetland buffer protections to allow for the
formalizing of a pathway to connect Steve Street Park to the north has been determined to
have generally positive ESEE consequences. Therefore, it is proposed that Tigard allow the
conflicting use in this 0.03-acre area consistent with (c) above. By approving the requested
CPA, the City of Tigard can effectively balance the need for providing park facilities to its
population with the preservation and enhancement of its valuable natural resources.
City of Tigard: Comprehensive Plan Amendment ESEE Analysis
Winterbrook Planning | August 2025 | Page 16
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
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