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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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December 3-4, 2015 - LCDC Salem <br />Agenda Item 4, Attachment H <br />Suggested changes <br />We suggest allowing a city to assume that some portion of partially vacant land will develop <br />over the 14-year period. This might be accomplished through an examination of the average <br />number of partitions and minor subdivisions of single-family parcels over the past five to 10 <br />years. Allow the city to assume the average number of new lots will be created this way over <br />the next 14 years or the average number plus 25% or 50% (assuming increasing levels of <br />density). <br />Initiating the Process (OAR 660-038-0010(4)) <br />Issue <br />OAR 660-038-0010(4) defines what it means to initiate the process. Initiating the process is a <br />public notice for a proposed plan amendment that concerns evaluating or amending the UGB or <br />approval of a periodic review work program that includes a work task concerning a UGB. <br />While this process is intended to be faster and easier than the existing process, problems may <br />arise that delay the process. For example, we find that completing the technical analysis often <br />happens relatively quickly but issues arise with the public process, requiring the city to take <br />time to address concerns or discuss policies to address concerns. This process can take months <br />or longer. <br />Suggested changes <br />We suggest that there is a notification that cities can use to notify DLCD that they are initiating <br />the process for a specific 14-year time period. That way, if the process takes a year, rather than <br />six months, the city does not have to update the technical analysis to make it a new 14-year <br />period. <br />Determine Amount of Land Needed for Each Housing Type (OAR 660-038- <br />0050 and OAR 660-038-0060). <br />Issue <br />The implementation of OAR 660-038-0050(3) and OAR 660-038-0060(6) is neither clear nor <br />simple. We think the intent is that cities would develop a current estimate of the average <br />density of needed housing and compare that with the existing density of housing. <br />(6) The city must identify all residentially-designated developed parcels and those portions <br />of partially vacant parcels within the UGB that are developed and calculate the total area of <br />developed residentially-designated land, the total number of existing dwelling units located on <br />residentially-designated land, and the net density of developed residentially-designated land within <br />the UGB. [emphasis added] <br />The UO research pretty clearly demonstrates that unit counts by tax lot are not available in most <br />Oregon counties. Thus, cities will be left to figure out how to do the analysis (our guess is most <br />
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