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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
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PDD_Planning_Development
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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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Agenda Item 4 - UGB Rulemaking <br />December 3-4, 2015 - LCDC Meeting <br />Page 25 of 56 <br />Cities with UGB populations under 25,000 and with medium or high density housing <br />percentages in the top 25 percent for cities in the same population category would be <br />required to at least maintain their current percentage of such housing going forward. <br />Cities with UGB populations of 25,000 or greater that had attained the highest <br />percentages among such cities would be required to at least maintain their current <br />percentage of such housing going forward. <br />The upper range for medium and high density housing allowed to cities in determining <br />their housing mix would be significantly higher than current percentages. For example, a <br />city with a UGB population less than 2,500 and an existing higher density mix of housing <br />within the city of 16 percent would be allowed to project at least 31 percent of higher <br />density housing going forward, because the city would be allowed to project a mix of up <br />to 15 percent higher than its current percentage of higher density housing. <br />Several commenters recommended changes to this section: <br />• The League of Women Voters of Oregon recommends that cities with population less <br />than 2,500 be required to determine housing mixes based upon three categories as with <br />other cities, rather than two, so that these small cities would be required to increase <br />residential "efficiency" standards similar to larger cities. <br />1000 Friends of Oregon recommends use of a higher "push" factor to determine the <br />required medium and high density housing percentages needed, for all cities, because the <br />department's proposal "won't provide enough of an increase in medium and high density <br />housing." <br />• The Home Builders Association recommends that cities be required to assume their <br />current mix of housing types will be maintained going forward, and not be allowed to <br />forecast that significant increases in percentages of medium and high density housing will <br />occur, since such forecasts are speculative, and if they do not actually occur it may mean <br />that UGBs do not provide a sufficient supply of land for needed housing. <br />The department does not concur with these recommendations, for the following reasons: <br />The statutes in question, ORS 197A.310 and ORS 197A.312, require that the method be <br />designed such that a city using the method, "[w]ill not become less efficient in its use of <br />land as a result of a change to the urban growth boundary." Also the statutes require that <br />under the method "urban population per square mile will continue, subject to market <br />conditions, to increase over time on a statewide basis and in major regions of the state, <br />including that portion of the Willamette Valley outside of Metro." The department <br />believes that these two statutory directives, when taken in combination, require that the <br />department's recommendations or something equivalent must be in these rules, so as to <br />require cities to forecast long term increases in housing densities in the manner of the <br />suggested ranges. <br />
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