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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 28 of 56 <br />Option: (3) If necessary, adjust the density assumptions used in the residential land need <br />analysis so that the overall net density for all residential land need is at least 20% greater than <br />the density determined in OAR 660-038-0050(2), up to a maximum of.- <br />(a) Eight dwelling units per net acre for cities with population less than 10, 000. <br />(b) 10 dwelling units per net acre for cities with population greater than or equal to 10, 000. <br />0060: Buildable Lands Inventory (BLI) for Residential Land (Page 9) <br />General: This rule governs how cities must conduct a residential buildable lands inventory to <br />determine the available land within the existing UGB. The city is determining how much vacant <br />and partially vacant land is available to satisfy the residential land need. This overall requirement <br />is summarized in the introductory statement of this rule. <br />Section (1) requires cities to classify existing residential areas into low, medium, or high density <br />categories, consistent with the determination of land need. The basis for this classification should <br />be the city's comprehensive plan land use map. However, some cities do not differentiate <br />residential districts by density or type of housing, while other cities have a "one map" system <br />that combines the city's comprehensive plan map with the zoning map. In these situations, the <br />city is required to use its zoning map. For lands that are within a city's UGB but not annexed, the <br />city must use the applicable county land use or zoning map. <br />This section also provides requirements for classification of land use or zoning districts, <br />correlating them with the low, medium, and high density residential need categories. Since cities <br />vary in the densities of their residential zoning districts, and may have districts with residential <br />densities that don't fit neatly into the low, medium, and high density categories set forth in these <br />rules, the rule allows for some flexibility in the city's classifications. <br />Section (2) directs cities to identify all vacant, residentially designated parcels within the city's <br />UGB. The lot size and assessed value thresholds have been commonly used in buildable lands <br />inventories conducted by cities in the past. <br />Section (3) directs cities to identify all partially vacant, residentially-designated parcels within <br />the city's UGB. Identification of partially vacant land will require use of aerial photos, but such <br />photos are readily available. <br />The Oregon Home Builders Association believes that (1) the vacant land minimum lot size, <br />which is set at 3,000 square feet in conducting a buildable land inventory, is too low, and should <br />be raised to 5,000 square feet; and (2) that a lot should be considered fully developed and not <br />partially vacant if it less than one acre, rather than one-half acre. The department does not agree <br />with these recommendations, because (1) a survey of buildable lands inventories shows that the <br />3,000 square-foot threshold has been commonly used by cities; and (2) the one-half acre <br />
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