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PUBLIC COMMENT - DAN TERRELL & BILL KLOOS ON BEHALF OF HBA (1-4-17)
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PUBLIC COMMENT - DAN TERRELL & BILL KLOOS ON BEHALF OF HBA (1-4-17)
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Last modified
8/24/2017 1:48:08 PM
Creation date
2/7/2017 10:47:35 AM
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Template:
PDD_Planning_Development
File Type
CA
File Year
17
File Sequence Number
1
Application Name
UGB ADOPTION PACKAGE
Document Type
Public Comments
Document_Date
1/4/2017
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Yes
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I applying the OAR 660-024-0040(9)(a) safe harbor provision was not an issue <br />2 in Zimmerman. <br />3 This sub-assignment is sustained. <br />4 C. Error to Add Regional Large-Site Industry Capture to <br />5 Employment Based on Safe Harbor <br />6 Petitioners next assert the REA improperly inflated the safe harbor jobs <br />7 estimate by assuming Coburg will attract regional employers, in the future, who <br />8 are seeking large industrial sites. Petitioners rely on Friends of Yamhill County <br />9 v. City of Newberg, 62 Or LUBA 5 (2010), stating that the safe harbor does not <br />10 allow the simultaneous use of other methods. <br />11 Intervenor clarifies that the REA recognizes that the Scenario A <br />12 projection is based on anticipated economic growth derived from expected <br />13 population growth and does not capture all types of economic growth that may <br />14 be occurring in the region. Intervenor notes that the Scenario B regional <br />15 analysis is performed to accommodate larger regional industrial facilities that <br />16 have flexibility to locate anywhere in the region and beyond and have <br />17 particular siting requirements. Intervenor argues: <br />18 * * Importantly, neither Goal 14 nor Goal 9 state that if the safe <br />19 harbor is used for the population based component of the Goal 9 <br />20 analysis, that it precludes further application of the remaining <br />21 Goal 9 rule provisions that mandate a sufficient supply of <br />22 adequate sites by type and that encourage local governments to <br />23 pursue regional economic opportunities. * * Intervenor- <br />24 Respondent's Brief 36. <br />Page 58 <br />
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