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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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Anne Davies <br />February 4, 2014 <br />Page 4 <br />1. Urban reserve areas (Eugene does not have urban reserves); <br />2. Exception areas; nonresource land; non-high value resource land surrounded by <br />exception or nonresource land; <br />3. Marginal Lands (Lane County is a marginal land county); <br />4. Resource lands. <br />Sonic of the Goal 14 locational factors can be applied at the same time as the ORS 197.298 <br />priority factors, while others of the locational factors are to be applied at later stages of the <br />process to determine which lands are ultimately to be brought into a UGB. As discussed in more <br />detail below, the proper application of ORS 197.298 and Goal 14 has been the focus of Land <br />Conservation and Development Commission (LCDC) and Court of Appeal reviews of local UGB <br />expansion decisions. <br />Because there are no urban reserve lands in the Metro Plan area, the City must move to the next <br />highest priority land, as prescribed by ORS 197.298(1)(b) - land adjacent to the UGB that is <br />acknowledged as an exception area, or as nonresource land, or as resource land surrounded by <br />the former. All of the land that is subject to this proposal falls into this category. <br />The most significant point we wish to make here is that all of the land in the proposal area that is <br />plan designated Gravel by the county qualifies as "nonresource" land. The Oregon <br />Administrative Rules provide definitions for "Resource Land" and "Nonresource Land." OAR <br />660-004-0005 Definitions provides: <br />"(2) "Resource Land" is land subject to one or more of the statewide goals listed <br />in OAR 660-004-0010(1)(a) through (g) except subsections (c) and (d). <br />"(3) "Nonresource Land" is land not subject to any of the statewide goals listed in <br />OAR 660-004-0010(1)(a) through (g) except subsections (e) and (d). Nothing in <br />these definitions is meant to imply that other goals, particularly Goal 5, do not <br />apply to nonresource land." (See also OAR 660-021-0010(2) and (3), providing <br />identical definition). <br />The statewide goals identified in the above definitions listed in. OAR 660-004-0010 inclurde: <br />"(a) Goal 3 "Agricultural Lands" . <br />"(b) Goal 4 "Forest Lands" . <br />"(e) Goal 16 "Estuarine Resources" . <br />"(f) Goal 17 "Coastal Shorelands...... <br />"(c) Maximum efficiency of land uses within a proposed urban growth boundary requires <br />inclusion of lower priority lands in order to include or to provide services to higher priority <br />lands." <br />
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