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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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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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I overall analysis, growth from larger projected employment trends outside that urban <br />2 growth area.9 <br />3 2. "Double-Counting" in REA Einployfnent Forecasts <br />4 Before LUBA and now again before this court, the parties disputed how <br />5 Hovee arrived at the particular calculations in the REA for Scenarios BI, B2, and B3, and <br />6 whether those projections were permissibly calculated. At the heart of this argument is a <br />7 chart titled, "Coburg Industrial Scenarios with Regional Large Site Industrial Capture," <br />prepared by Hovee. That chart is described as "depict[ing] results of alternative regional <br />9 capture rates that might be considered in terms of resulting 20-acre land demand added to <br />10 existing local industrial need as previously indicated for [Scenario A]." (Emphasis in <br />11 original.) <br />12 Land Watch challenges that, in determining a final employment-based land <br />13 need, the city took a subset of the "Scenario A" calculation and reused it in calculating <br />14 "Scenario B." Relying on that understanding of the urbanization study, Land Watch <br />15 asserts that, because the analysis reused the same subset of projected employment-based <br />16 need, the analysis impermissibly "resulted in a double-counting of employment need." 10 <br />The forecast must, of course, be supported by an adequate factual basis and may <br />be challenged to demonstrate how its approach in creating its forecast is reliable. See, <br />e.g., Meyer v. Douglas County, 61 Or LUBA 412, 416 (2010); Friends of Marion County <br />v. City ofKeizer, 45 Or LUBA 236, 248-50 (2003). <br />io Specifically, Land Watch contends that the REA "added Scenario A's 68.7 acres <br />and Scenario B 1's 51.4 acres, resulting in a total industrial land need of 120.1 acres <br />accommodating a total of 1,272 jobs (809 [industrial jobs] + 463 [industrial jobs])." <br />(Emphasis omitted.) <br />16 <br />
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