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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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Yes
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I B. Failure to Use Current Job Numbers <br />2 Petitioners next argue that respondents improperly used higher pre- <br />3 recession job numbers when applying the OAR 660-024-0040(9) safe harbor <br />4 option under the Goal 14 administrative rule. The REA Scenario A <br />5 employment forecast was developed based on the Oregon Employment <br />6 Department (OED) 1.66% average annual growth rate (AAGR) forecast for <br />7 Lane County, relying on OAR 660-024-0040(9)(a), which provides that: <br />8 "A local government may estimate that the current number of jobs <br />9 in the urban area will grow during the 20-year planning period at <br />10 a rate equal to * * * [t]he county or regional job growth rate <br />11 provided in the most recent forecast published by the Oregon <br />12 Employment Department[.]" (Emphasis added.) <br />13 Petitioners assert that respondents erred, because the REA correctly applied the <br />14 1.66% AAGR over a period of 20 years to result in a thirty-nine percent <br />15 increase in jobs, but then applied that percentage to the 2006 jobs estimate <br />16 (3,316 jobs) that existed at the height of the economic boom rather than the <br />17 2012 jobs estimate (1,207 jobs), the most recent job count available. Petitioners <br />18 argue that due to this error, respondents over-estimated the amount of the <br />19 projected jobs in the 20-year planning period by almost a factor of three. <br />20 Intervenor responds: <br />21 * * That safe harbor is prescribed for the first of the three Goal <br />22 9 employment land considerations * * *a city's population <br />23 based employment needs. The safe harbor does not apply to either <br />24 of the two other Goal 9 considerationswhether there are suitable <br />25 site types or regional employment opportunities. * * <br />26 Intervenor-Respondent's Brief 36. <br />Page 56 <br />
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