December 3-4, 2015 - LCDC Salem <br />Agenda Item 4, Attachment H <br />The OED's data is for covered employment, not total employment. Covered <br />employment typically excludes groups like sole proprietors, independent contractors, <br />railroad workers, etc. In most counties covered employment is two-thirds to three- <br />quarters of total non-farm employment. These non-covered employees require <br />workspace the same as covered employees, such as retail stores or office space. <br />For example, in 2012 Seventy-seven percent of total employment in was covered <br />employment in the Salem MSA (Marion and Polk County). The City of Salem had about <br />92,000 covered employees. We estimated that Salem had about 120,000 total employees, <br />assuming that 77% of all employees in Salem were covered employees.' <br />We are aware that the UO research based employment densities off of covered <br />employment and that the draft rule uses that data to establish employee per acre ranges <br />and that the methodology, as proposed, is consistent with that methodology. <br />Suggested changes <br />Clarify how public employment is factored into the land need calculations. This could be <br />done by creating a definition or by articulating where public land need is addressed or <br />by amending the language in OAR 660-038-100 and 110(3) to read "private <br />employment." <br />2. If this is an issue, then additional language will be required to define the planning <br />period dates similar to the way that OAR 660-024 addresses dates. <br />The key issue here is consistency, If the intent is to keep the forecast consistent with the <br />UO research, then we have no recommended changes. <br />Residential Buildable Lands Inventory, Definition of Partially Vacant Land <br />(OAR 660-038-0050(4)) <br />Issue <br />OAR 660-038-0050(4)(a) requires the city to identify all partially vacant parcels at are at least 1/2 <br />acre in size and contain a single-family residence. The city -qua dm adbon e <br />the residence, and count the rest of the parcel as vacant bmdimplicit assumption is that <br />these lands will subdivide in the 14-year period. <br />Our concern is about the likelihood that parcels between 1/2 and 2 acres will in fact subdivide <br />over the 14-year period. There are a number of factors that may make this unlikely, such as <br />placement of the dwelling on the property (i.e., a house in the center of the parcel) or owner <br />preference against subdividing. This assumption may considerably overstate partially vacant <br />land capacity based on the UO research on development in unincorporated areas of UGBs and <br />areas of large lot development that get annexed. <br />1 The math was 92,000 covered employees divided by 77%, which equaled 120,000 total employees <br />