Agenda Item 4 - UGB Rulemaking <br />December 3-4, 2015 - LCDC Meeting <br />Page 26 of 56 <br />• ORS 197.303, which defines needed housing types, does not apply to cities with <br />population less than 2,500. As such, cities of that size should not be required to go <br />beyond that statute in the simplified process, and would probably not use it. <br />• As a practical matter, cities will have a choice to determine residential land need and <br />housing mixes using either the traditional UGB evaluation or amendment method or the <br />new simplified method. If the method requires housing mix ranges perceived by small <br />cities as unrealistic or unattainable, those cities will probably not choose to use the new <br />simplified method for UGB evaluation and amendment. <br />The 1000 Friends of Oregon comment on this issue seems to imply a concern that cities <br />will choose the lowest possible numbers within the housing mix ranges offered. The <br />department has proposed these ranges with an expectation that the low end of each range <br />would still achieve the intended goals of this method. Regardless, many cities in Oregon <br />realize the need to provide higher density housing options to meet the housing needs of <br />their residents, and many will likely take advantage of the range offered to significantly <br />increase percentages of medium and higher density housing mixes within their UGBs. <br />The Oregon Home Builders Association comment on this issue implies that cities will <br />make housing mix assumptions that are unrealistic in relation to the real estate market <br />and cities that make such aggressive housing mix assumptions will not plan to carry these <br />out. The department believes that the density increases cities may attain using the high <br />end of the ranges are not so high as to be unreasonable from a real estate market <br />perspective based on a historic view of that market. In addition, the rules require a city to <br />provide plan and zone designations and codes that will realistically allow implementation <br />of the mix assumptions, using clear and objective standards for needed housing. <br />As a technical matter, if a city already has experienced any significant amount of <br />redevelopment or mixed-use development, or development of accessory dwelling units, <br />the actual percentages of medium and high density residential development the city <br />provides for will be higher than the long term residential mix mandated through use of <br />Table 1. This is because Table 1 accounts only for development by increasing the land <br />need the city must forecast - redevelopment and mixed-use residential development (and <br />ADU development), which occurs on already developed land, is accounted for separately <br />because such development does not generate need for vacant or partially vacant land. <br />And since redevelopment and mixed-use development is predominantly, if not entirely, <br />of a medium density or high density nature, it will skew the mixes shown in Table 1 <br />further toward these types of residential development. <br />If the commission wishes to accept an alternative to the department's recommendation on this <br />issue in terms of changing the required mix numbers for cities, it would be accomplished through <br />changes to proposed Table 1. <br />