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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
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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Agenda Item 4 - UGB Rulemaking <br />December 3-4, 2015 - LCDC Meeting <br />Page 27 of 56 <br />Section (4) directs cities to apply the housing mix percentages determined in section (3) to the <br />total housing need number to determine the actual numbers of low, medium, and high density <br />dwelling units needed. <br />0050: Determine Amount of Land Needed for Each Housing Type (Page 9) <br />General: This rule requires cities to convert the numbers of needed housing units into an amount <br />of needed land for those units. <br />Section (1): In this section, a city will divide the number of needed housing units for low, <br />medium, and high density housing as determined in the housing mix rule by projected residential <br />densities to arrive at the amount of net residential land need. These densities are contained in <br />Table 2, which is attached to the rule. The low density and medium density residential ranges <br />reflect the findings of UO in their research. The high density residential ranges reflect a review <br />of recent buildable lands inventories completed by Oregon cities. <br />Section (2): This section directs cities to convert the amount of net residential land need <br />determined in section (1) to gross land need by adding an amount equal to 25 percent of the net <br />land need to account for public lands such as streets, parks, and schools. This number is the same <br />as the "safe harbor" in the existing UGB analysis method in division 24, and approximates the <br />amount of public land within cities found in UO research. <br />Sections (3) and (4) provide a "check" on the assumptions and ranges used by cities to calculate <br />residential land need. ORS 197A.310 and 197A.312 both contain requirements a city "[w]ill not <br />become less efficient in its use of land as a result of a change to the urban growth boundary." <br />These sections require a city to calculate the existing density of its developed residential lands, <br />and then show that its assumptions will not result in new residential development at densities less <br />than those of the existing city. <br />1000 Friends of Oregon recommends that this standard be strengthened by requiring a city to <br />meet the density that has been achieved by more recent residential development within its <br />boundaries, which they assert can be approximated at approximately 20 percent greater than the <br />overall historic residential densities occurring within a city. The UO research shows that cities <br />have increased residential density and efficiency in the 21st century. However, the statutory <br />language does not require that cities become more efficient than has occurred over any particular <br />time period, and the department does not recommend that the commission read this requirement <br />into the statute. <br />However, if the Commission agrees with the 1000 Friends of Oregon position, the following <br />replacement language would meet the Department's other concern - that a 20% increase in <br />overall historic densities applied at every future instance the city analyzed its urban growth <br />boundary would result in a "never-ending cycle" of higher and higher required residential <br />density. The alternative language puts a reasonable cap in terms of dwelling units per acre on <br />densities required by this section: <br />
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