December 3-4, 2015 - LCDC Salem <br />Agenda Item 4, Attachment H <br />Areas for Clarification <br />Below are some suggestions for issues to clarify. <br />Sufficiency of buildable lands. OAR 660-038-0020(2) says that a city must demonstrate <br />that they have enough development capacity for housing and employment <br />opportunities. What if a city has enough for housing but not employment? Does a city <br />have to expand their UGB if they find they do not have enough capacity to <br />accommodate 14-years of growth? Does the city have to expand their UGB for <br />employment? Can a city review one class of land (e.g., employment) without <br />addressing others? <br />Housing mix. OAR 660-038-0040(2) says that single-family detached dwellings shall be <br />considered low density residential. Does single-family dwellings include manufactured <br />dwellings on parks or in lots? Does it include accessory dwelling units? <br />Residential redevelopment. The UO research showed that residential redevelopment <br />was happening relatively infrequently, especially in smaller cities. We agree with the <br />direction the rule is taking and recommend that the required percentages be kept low <br />(5% to 10%) at least until better data on redevelopment exists. Many instances exist of <br />local backlash against planning for redevelopment-particularly when it involves low- <br />density neighborhoods. <br />• Vacant residential parcels. OAR 660-038-0060(3) says that vacant parcels are parcels of <br />at least 3,000 square feet in size. What if a 3,000 square foot parcel is not a legal lot? <br />Addressing residential land deficits. OAR 660-038-0080 directs cities to Tables 3 and 4, <br />which allows a city with a surplus of low-density land and a deficit of medium or high- <br />density land to redesignate low density land to satisfy the higher density land deficits. <br />What does the city do if the redesignation creates a deficit of low-density land? Can they <br />contemplate UGB expansion? <br />Categorizing employment. OAR 660-038-0010(2) and (3) defines commercial and <br />industrial land. Do these definitions separate government employment from private <br />employment? For example, federal postal carriers are classified under NAICS code 491 <br />(under warehouse and distribution), along with private mail carriers like Federal <br />Express. Put another way, will the employment estimates include government and <br />private employment or only private employment? <br />Additional Planning for Residential Lands Added to the UGB (OAR 660-038-019012). <br />The UO research is clear that parcelization below two acres is detrimental to achieving <br />future urban densities. Consider requiring the planning to prohibit land divisions that <br />result in parcels of less than two acres without annexation or a similar provision that <br />would discourage creation of lots that are less than two acres but not urban density. <br />