December 3-4, 2015 - LCDC Salem <br />Agenda Item 4, Attachment H <br />PLANNING DEPARTMENT <br />Room 106 • Justice Building • Douglas County Courthouse <br />Roseburg, Oregon 97470 <br />Doug as Planning Services On-Site Services Environmental Health <br />L~Quu (541) 4404289 (541) 440-6183 (541) 440-3574 <br />Fax 4 (541) 440-6266 Fax # (541) 464-,6429 Fax # (541) 957-2097 <br />"A Program With Great Spirit" <br />November 3, 2015 <br />Land Conservation and Development Commission <br />c/o Casaria Taylor <br />635 Capitol St., Ste. 150 <br />Salem, Oregon 97301 <br />To Whom It May Concern: <br />Re. Proposed Administrative Rules Establishing Streamlined UGB Process. <br />Thank you for giving Douglas County the opportunity to offer a few comments regarding the <br />draft new rules and rule amendments (Division 24, Urban Growth Boundaries) in response to <br />ORS 197A. <br />The major concern we have regarding the new rules deal with the fourth type of land that must <br />be evaluated in the study area for inclusion in the UGB identified in OAR 660-024-0067(5). This <br />fourth priority allows for the evaluation of agricultural land that is predominantly high value <br />farmland, but fails to capture the opportunity to evaluate timber land that is predominantly high <br />value forestland. <br />Not including the opportunity to evaluate forest land, will limit the opportunity for many Oregon <br />cities to possibly expand their UGB, simply because they are surrounded primarily or in some <br />cases completely by forestland rather than farmland. <br />The third priority identified in 660-024-0067(4), includes the opportunity to evaluate forestland, <br />but only in regards to whether it is considered not predominantly high value farmland. Given that <br />many of the twelve cities in Douglas County have a UGB surrounded by forestland, we feel <br />these lands should be equally considered within the four types of prioritized land identified in <br />660-024-0067. <br />Prohibiting forestlands from being considered will limit the opportunity for cities within different <br />regions of the state the opportunity to determine whether they might qualify for a possible UGB <br />expansion simply due to the fact that they are not surrounded by an adequate supply of <br />farmland. <br />