Agenda Item 4 - UGB Rulemaking <br />December 3-4, 2015 - LCDC Meeting <br />Page 35 of 56 <br />determine the long-term growth rates forecast by OED for commercial jobs and for industrial <br />jobs in the OED region that includes the city. ("OED region" means Workforce Innovation and <br />Opportunity Act (WIOA) Areas for which OED forecasts long-term job growth). Next, in section <br />(3), the city must simply multiply the number of jobs currently in the UGB determined in section <br />(1) by the forecast rate of growth determined in section (2). This provides the long term forecast <br />of jobs. Finally, the method requires a 20% reduction of long term jobs, to reflect that 20% of <br />jobs forecast long term will occur on residential or other areas, discussed in the overview above. <br />The proposed OED forecast method in rule 0110 relies on the 10-year forecast growth rate for <br />commercial jobs, and separately for industrial jobs, rather than an "annual growth rate" or a 14- <br />year growth rate that could, theoretically, be inferred from OED's 10-year forecast. In the <br />employment path workgroup, and in the RAC meetings, OED representatives indicated that the <br />methodology for the forecast does not lend itself to any simple method to infer an annual growth <br />rate, nor to extension of the forecast to 14-years using a "straight-line projection." Furthermore, <br />OED has warned that its long term jobs forecast has historically overestimated jobs that actually <br />occur over time, often by a large amount. The department notes that, by restricting use of the <br />forecast such that cities may only use the rate that is actually forecast (a 10-year growth rate), <br />rather than an "extended" 14-year rate, the overestimation of jobs (should this continue to occur <br />in the future) is mitigated. <br />Comments have expressed a concern that this forecast may under-represent growth for the 14- <br />year planning period, and therefore cities should be allowed to extend the regional forecast by a <br />straight line method to 14 years, and have noted that, in fact, such extension is already allowed in <br />the "traditional" UGB method (see safe harbor in 660-024-0040(9)). The department agrees that <br />the authorization in the current "traditional process" (included as a "safe harbor") allows a 20- <br />year "extrapolated forecast" rather than the proposed 10-year forecast under the recommended <br />simplified process. If the commission determines that it would like to increase the employment <br />needs forecast under the proposed simplified process, with respect to the OED forecast method, <br />it may consider allowing cities to extrapolate the 10-year OED forecast to 14-years. While not <br />recommended by OED, allowing such extrapolation would mitigate some of the difference <br />between forecasts under the traditional method and the new method, at least compared to cities <br />that use the OED forecasts under the traditional method (apparently the safe harbor has been <br />used infrequently in the past). This has not been provided as an "Option" in the rule, but could be <br />easily inserted at the request of the commission. <br />0120: Buildable Land Inventory for Employment Land within the UGB (Page 16) <br />General: This rule provides a method to inventory vacant and partially vacant land (BLI) within <br />a UGB. The new statutes at ORS 197A require use of a BLI, and it has historically been a basic <br />part of UGB need analysis. The rule at 0120 is paired with another rule at 0130, which adjusts <br />the BLI based on constraints to land development. After applying both rules, the city will <br />produce a simple BLI for employment land. It should be noted that the department has changed <br />its recommendation from that provided in the September draft. Draft 3 of the rule recommends <br />some simple rules of thumb for determining vacant, partially vacant, and developed employment <br />