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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 31 of 56 <br />0080: Compare Residential Land Need to Land Supply (Page 13) <br />General: This rule requires cities to compare the amount of buildable lands with the residential <br />land need, and then determine if any additions to an urban growth boundary to meet residential <br />land needs are necessary. This direction is summarized in section (1). <br />Sections (2) through (4) reference Tables 3 through 5, which are attached to the rule. Table 3 <br />applies to cities with a UGB population of less than 2,500, Table 4 applies to cities with <br />population between 2,500 and 10,000, and Table 5 applies to cities with population greater than <br />10,000. The tables deal with all possible combinations of surplus and deficit for low, medium, <br />and high density categories of residential land within an existing UGB. <br />When all categories of land show a surplus or a deficit then the city's action is straightforward. A <br />surplus means that no UGB expansion for residential land need is necessary. If a city has a <br />deficit in all categories it may either add land to its UGB to satisfy the deficit, or alternatively it <br />may redesignate low density land within the existing UGB to meet a medium or high density <br />land deficit, and then add enough low density land to the UGB to satisfy that need as well. <br />The tables also cover situations involving cities with a deficit of one type of residential land, and <br />a surplus of another type. To summarize the tables for these situations: <br />• Cities may not redesignate surplus high or medium density land to satisfy a low density <br />land deficit. Land that has an existing high or medium density residential designation <br />should be preserved for those uses even if 14-year projections show a surplus, due to the <br />difficulty cities often have in identifying and designating such lands in their <br />comprehensive plans. <br />Cities with UGB population less than 10,000 are allowed to redesignate low density <br />surplus lands to satisfy or partially satisfy a medium or high density deficit, but are not <br />required to do so. This recommendation recognizes the difficulties cities have in <br />"upzoning" lands within an existing UGB. Such difficulties outweigh the benefits of <br />having higher density residential development adjacent to existing city facilities and <br />services because of the overall compact size of smaller cities. <br />Cities with UGB population greater than 10,000 are required to satisfy at least half of a <br />high or medium density deficit by redesignating surplus low density residential lands. In <br />larger cities the benefits of having higher density residential development adjacent to <br />existing city facilities and services justifies the difficulty cities may have in "upzoning" <br />land within an existing UGB. <br />Section (5) authorizes cities to designate surplus employment land as determined through the <br />employment land need analysis to satisfy all or part of a residential land deficit, except for <br />specific types of industrial land, which cannot be redesignated even if a surplus of them exists. <br />However, the proposed rule does not require such redesignation - employment land and <br />
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