this sub-prioritization should take place. DLCD's new UGB administrative rules (2016) provide some <br />direction for cities and counties in terms of how the classification system should be used to prioritize <br />potential expansion areas. Cities that fall under the new UGB expansion rules at OAR 660-024-0067 are <br />explicitly required to prioritize in terms of "farm land that is not predominantly high-value farm land" <br />verses "agricultural land that is predominantly high-value farmland." While the current UGB expansion <br />for Eugene and Lane County are not subject to this new rule, the rule demonstrates the significance of <br />Oregon's "high value farmland" in terms of prioritizing land under the capability classification system. <br />Lane County's "Lane County Soil Ratings for Forestry and Agriculture" document provides a list of all the <br />high value soils in Lane County based on data from the United States Department of Agriculture - <br />Natural Resources Conservation Service (NRCS) and the Oregon Department of Land Conservation and <br />Development (DLCD). Both those agencies, and the Oregon Department of Forestry (ODA), reviewed <br />Lane County's list and support the methodology used to produce it. <br />As the "High Value Farmland Designations" map shows, the portion of Eugene's industrial expansion <br />study area that contains the remaining candidate sites is almost completely composed of high value <br />farmland soils. Furthermore, although small portions of soil not identified as high value farmland soil is <br />present on a few sites, every remaining candidate site is predominantly high value farmland.54 Sites, as <br />defined in this analysis, are consistent with the use of the term "tracts" in OAR 660-033-0020 in that <br />tracts presuppose tax lots with common ownership, and sites (including the options that combine sites) <br />indicate areas with the opportunity for aggregation of ownership. <br />Considering that all of Eugene's options for expanding its UGB to add suitable industrial sites require <br />expansion onto high value farmland, Eugene's prioritization is based on identifying the expansion option <br />that disrupts as few areas of high value farmland as possible. This prioritization is addressed along with <br />the application of the boundary location factors of Goal 14, below. <br />(2) Boundary Location Factors of Goal 14 / Selecting the Land for Inclusion in <br />the UGB <br />Twenty-two (22) sites were identified in Section (f), above, as sufficiently unconstrained and having the <br />needed site characteristics for at least one of the acreage-based categories of industrial land needed. As <br />addressed previously, the City of Eugene has identified a need for eleven (11) total sites, with the <br />following size characteristics: <br />• Two (2) industrial sites of 75 acres or larger <br />• Three (3) industrial sites of between 50 and 75 acres <br />• Two (2) industrial sites of between 20 and 50 acres <br />• Four (4) industrial sites of between 10 and 20 acres <br />The remaining candidate land includes sites that meet all of these size characteristics, as shown in the <br />map "Size Categories of Remaining Candidate Sites." Multiple combinations of these sites could be used <br />to meet the need for the full 11-site portfolio. Different combinations would have a different impact on <br />the urban form, and so are evaluated below for how they address the Goal 14 boundary location factors. <br />"Appendix A analyzes the specific soil content of each candidate site and corresponding tax lot. <br />Appendix B to Findings May 2017 Page 130 <br />