December 3-4, 2015 - LCDC Salem <br />Agenda Item 4, Attachment H <br />1 (3) When a•1- purpose for expansion of the UGB is to accommodate a particular <br />2 industrial use that requires specific site characteristics, or to accommodate a public facility that <br />3 requires specific site characteristics and the site characteristics may be found in only a small <br />4 number of locations, the preliminary study area may be limited to those locations within the <br />5 distance described in section (1) or (2), whichever is appropriate, that have or could be improved <br />6 to provide the required site characteristics vithin the planning period. This limitation shall be <br />7 only for purposes of evaluating land for that particular industry use or public facility. Site <br />8 characteristics may include but are not limited to size, topography and proximity. For purposes <br />9 of this section: <br />10 (a) The definition of "site characteristics" in OAR 660-009-0005(11) applies for purposes of <br />11 identifying a particular industrial use. <br />12 (b) A "public facility" may include a facility necessary for public sewer, water, storm water, <br />13 transportation, parks, schools, or fire protection. <br />14 (4) The local government may exclude land from the preliminary study area if it determines that <br />15 ~ (a) Based on the standards in section (7) of this rule, it is impracticable to provide water, <br />16 sanitary sewer, storm water management fire protection, or transportation facilities <br />17 i9tilb ie f eil ti°s R to the land: <br />18 (b) The land is subject to significant development hazards, due to a risk of: <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />(A) Landslides: substantial evidence demonstrates that the land is subject to risk of <br />landslide that cannot be mitigated using commonly accepted construction techniques -,t4+@ <br />ct to.t;ao r a J;ao r + r~ 4;ar- n-lego (cr rPrn pialo„iso 3 2 <br />(DO ^ nor) P@e@ nb@r- 2014, 44@ +h4 th@ i4lepo^;t or- +4^"v tr,o a„t„ <br />rRd At ealp, of 1:40000 goof-, <br />26 (B) Flooding, including inundation during storm surges: the land is within the Floodway <br />27 or Special Flood Hazard Area (SFHA) identified on the applicable Flood Insurance Rate <br />28 Map (FIRM); <br />29 (C) Tsunamis: the land is within a tsunami inundation zone established pursuant to ORS <br />30 455.446; <br />31 (c) The land consists of a significant scenic, natural, cultural or recreational resource <br />32 described in this subsection: <br />33 (A) ,ands that are designated on an acknowledged comprehensive plan prior to <br />34 initiation of the UGB amendment, or that are mapped on a published state or federal <br />35 inventory at a scale sufficient to determine its location for purposes of this rule, as: <br />Comment [14141]: This should be changed to <br />ensure that cities don't have to do a separate PAPA <br />for each of these uses. The commission should <br />interpret the statute to mean the primary purpose <br />of that PART of a UGB expansion is to site a <br />particular industrial or public use. <br />Comment [14142]: remove comma? it's not in <br />the statute and may change the meaning. Eugene's <br />suggestion <br />Comment [14143]: Eugene wants this added. <br />Comment [14144]: this needs to be defined to <br />mean water, sewer, storm, fire, transportation, not <br />left open ended like this. otherwise, we'll be having <br />battles over what's "necessary" <br />Comment [14145]: The SLIDO database does not <br />map known landslide risks. It maps known historic <br />slide areas, which may have happened in prehistoric <br />times. The SLIDO website is clear that this mapping <br />is appropriate for regional planning only, and is not <br />a substitute for a site specific analysis - that's what's <br />needed to determine whether there is a real risk <br />today. The website states that SLIDO data should <br />not be used to make legally binding decisions. <br />Also, many risks can be mitigated with construction <br />techniques - there's no need to exclude the lands. <br />Again this is where a site specific analysis comes in. <br />If this isn't changed, it will cause unnecessary loss of <br />farmland. <br />Comment [14146]: DLCD still hasn't <br />acknowledged the fundamental problem with <br />relying on county, state or federal habitat mapping <br />to determine whether an area is so significant that <br />cannot be urbanized. <br />We should only list resources here if we can be sure <br />than in every case, the resource is so valuable that it <br />justifies jumping the priority scheme. When we <br />exclude at this level, we are making a policy choice <br />that no matter how good the farmland may be, it is <br />not as important as this habitat resource. It that <br />really Oregon policy? <br />We cannot rely on county or state determinations of <br />Goal 5 protections for rural land, to tell us whether <br />or not a resources is significant enough to warrant <br />sacrificing farmland. That's because a county would <br />not have evaluated that question in an ESEE <br />analysis, since rural land by definition is not going to <br />be urbanized. Just because a county decided to <br />protect big game range by limiting rural parcel sizes <br />(for example), that doesn't constitute a decision <br />that the resource is so significant that we have to <br />avoid urbanizing it forever. <br />Similarly, a state or federal mapping of habitat <br />hasn't made that determination. Nobody has done <br />an ESEE for these areas, to determine that in every <br />case, prime farmland is less important than <br />preserving the habitat. It's just an inventory of <br />habitat. <br />It seems the right approach here is to start with <br />those areas that are already under regulatory <br />limitations that prohibit destruction of habitat. For <br />example, if there is an ESA nest site, that can't be <br />disturbed no matter what. But federal critical <br />habitat has no such restrictions. <br />