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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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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 of industrial and other employment uses likely to occur in the planning <br />2 area. The estimate must be based on information generated in response to <br />3 sections (1) to (3) of this rule and must consider the planning area's <br />4 economic advantages and disadvantages. * * <br />5 OAR 660-009-0015. <br />6 Read in that context, we agree with LUBA that the safe harbor set out <br />7 under OAR 660-024-0040(9) does not preclude a city, in its EOA analysis or an <br />8 "employment forecast," from considering other employment-based needs for a UGB <br />9 expansion. A city is not precluded from projecting a need that considers additional <br />10 employment opportunities from outside the urban area. A city may have many relevant <br />11 considerations when estimating employment-based growth needs and is not bound by the <br />12 safe harbor of OAR 660-024-0040(9) to consider the prescribed growth rate in isolation. <br />13 Rather, as noted in OAR 660-009-0015(1), for example, "[c]ities and counties are <br />14 strongly encouraged to analyze trends and establish employment projections in a <br />15 geographic area larger than the planning area and to determine the percentage of <br />16 employment growth reasonably expected to be captured for the planning area based on <br />17 the assessment of community economic development potential" outlined under that rule. <br />18 (Emphases added.) Therefore, OAR 660-024-0040(9) may limit a calculation of the 20- <br />19 year projected growth of the "current number of jobs in the urban area." (Emphasis <br />20 added.) The rule, however, does not prohibit a city from considering, as part of its <br />15 <br />
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