December 3-4, 2015 - LCDC Salem <br />Agenda Item 4, Exhibit 1 <br />As planning practitioners, our goal is a clear and concise path that avoids litigation. Our last UGB attempt cost <br />well over $200,000 in staff time alone, not counting legal department time. We respectfully ask the Commission <br />to provide as much clarity and plain language in the rule as possible in the hopes that litigation over the details <br />might be avoided. <br />Lastly, we would like to communicate a point of frustration with this process as a whole. We find it a bit <br />frustrating that something as vitally important to planning practitioners as UGB rulemaking is not more inclusive <br />of planners who will be implementing the rules. The UGB rulemaking was largely off our radar until the end of the <br />process when we started participating on one of the sub-workgroups. With all of the available technology, we <br />would have liked to see more outreach on this issue, much earlier, such as webinars, surveys, focus groups, <br />regional meetings, etc., to adequately gather and incorporate input from practitioners. We hope that future <br />rulemaking efforts will continue to improve on this front. <br />Thank you for considering our comments. <br />Sincerely <br />Doug Rux, AICP / eica lz, AICP <br />C ommunity Development Director Planner <br />"Working Together For A Better Community-Serious About Service" <br />X:\FILES.UGB\EMPLOYMENT PATH WORI<GROUP\LCDC LETTER_2015-1120.DOCX <br />