Agenda Item 4 - UGB Rulemaking <br />December 3-4, 2015 - LCDC Meeting <br />Page 32 of 56 <br />residential land often have characteristics that make them unsuitable for this kind of change of <br />use. <br />1000 Friends of Oregon recommends that Tables 3, 4, and 5 be eliminated, and that cities facing <br />surpluses and deficits of different types of industrial land should be required to make findings to <br />determine, on an individualized basis, whether redesignation is appropriate. The department does <br />not agree with this recommendation because it is directly opposite the "simplified" approach <br />behind the division 38 rules. The decisions and findings of cities on this topic would be subject <br />to legal challenge. The department believes that the generalized permissive aspect of this rule, <br />with the significant policy exceptions included, provides adequate and certain direction to cities. <br />Overview of Employment Land Need Path <br />General: The seven proposed rules from 0090 to 0150 provide the "Employment Land Need <br />Path," under which cities will determine long term commercial and industrial land need, <br />determine the supply of such land in the UGB, and determine whether a UGB amendment is <br />necessary. Changes to this path since the September version of the draft, an overview of testing <br />results and some comments are discussed briefly in this general overview. <br />We note that there are also changes between the public Draft 2 of this path, published November <br />13, and Draft 3, published with this report on November 23. The RAC meeting on November 18, <br />and comments received in the same time frame, identified some important citation errors and <br />other issues in the draft 2 wording; these have been corrected in draft 3. <br />Table 6: The proposed methods in rules 0100 and 0110 require that cities use their most recent <br />job counts, sorted in to "commercial" and "industrial" land. To help with this, the department is <br />proposing Table 6, which will provide data from OED indicating current jobs counts within all <br />existing UGBs based on geo-coded employment data and on the current UGB maps for each city <br />maintained by DLCD. The department is recommending that LCDC update the data in this table <br />annually as a minor rule amendment. Table 6 is quite large, since it includes employment data <br />for every city in the state. Therefore it is provided as a link. <br />Table 7: The rules provide an optional method for cities to forecast employment needs based on <br />OED's long term (10-year) employment forecast for each of the OED regions. Table 7 will <br />provide the 10-year regional forecast for each OED region, simply as the growth rate for <br />commercial and (separately) for industrial jobs over the 10-year period. These forecasts are <br />issued by OED on a two-year cycle, and as such the department recommends that LCDC update <br />this table every two years as that forecast is issued. In the future, OED is considering shifting to <br />an 8 year forecast period, perhaps delivered annually. <br />The UO research discussed earlier in this report found that, with respect to current jobs reported <br />by OED in UGBs, on average 20% of these jobs do not occur on land zoned for commercial or <br />industrial use. Rather, they occur on residential land or land zoned for other uses. As such, the <br />job forecasts that are provided in Tables 6 and 7 must be reduced by 20%, since those jobs do not <br />require land planned and zoned for commercial and industrial use. That 20% reduction had not <br />