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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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Last modified
8/24/2017 1:48:08 PM
Creation date
2/7/2017 10:47:35 AM
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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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I in all likelihood would be smaller, and could potentially be <br />2 significantly smaller." Record 303-304. <br />3 Intervenor and respondents (respondents) explain that the 2014 Update <br />4 confirmed the 2010 analysis, did not recommend any particular regional <br />5 scenario, but expressly stated that none were rejected and concluded that all of <br />6 the scenarios were generally consistent with the original assumptions regarding <br />7 employment land needs presented in 2010. <br />8 Petitioners' third assignment of error is a series of loosely connected <br />9 challenges, focusing in large part on what petitioners contend are unresolved <br />10 inconsistencies in the 2010 Study, REA, and 2014 Update. Respondents answer <br />11 that petitioners' confusion regarding the jobs forecasts is of petitioners' own <br />12 making, and that the UGB decision is supported by an adequate factual basis. <br />13 Respondents contend that the economic land component of the decision and its <br />14 adopted findings are consistent with Goal 14 Urbanization and its <br />15 implementing administrative rules. Respondents quote OAR 660-024-0040 as <br />16 the governing rule for determining land need for industrial lands, emphasizing <br />17 that a local government is required to provide a reasonable justification for the <br />18 job growth estimate but Goal 14 does not require that job growth estimates <br />19 necessarily be proportional to population growth.22 Below we have attempted <br />zz OAR 660-024-0040(5) provides in relevant part: <br />" * * * the determination of 20-year employment land need for an <br />urban area must comply with applicable requirements of Goal 9 <br />and OAR chapter 660, division 9, and must include a <br />Page 52 <br />
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