Approval Criteria <br />Does ordinance #2 meet the approval criteria in the various Oregon Administrative Rules, <br />statutes and local approval criteria? To some degree this is a moot point since the growth plan <br />is so far off the mark it needs major revisions. <br />OAR 660-024-0040 states: <br />"The 20-year need determinations are estimates which, although based on the best <br />available information and methodologies, should not be held to an unreasonably high <br />level of precision." <br />The start date of the growth plan is five years ago. The staff and Council has been presented <br />with data, in the record, that shows multi-family projections lack reasonable precision. As <br />mentioned earlier this raises questions about many other aspects of the plan. <br />Staff has also alleged there will be a 1,600-unit deficit in multi-family housing over the next 20 <br />years. The solution is to change minimum density for R2 property and to assume (hope) 1,000 <br />units will be built downtown. First, this "solution" should be dropped since the evidence confirms <br />a deficit does not exist. <br />Second, ORS 197.296 (6) does not list assume/hope as an option for dealing with a residential <br />deficit. <br />The spirit of planning goal one, citizen involvement, has certainly not been met when problems <br />are pointed out and ignored. To make it worse staff then publishes articles trying to justify why <br />they ignored the warnings. <br />Monitoring <br />Staff has promised to monitor and update the growth plan within three years of UGB <br />acknowledgement (by who, Council, the State?). That will be over five years after staff was first <br />notified of the problems. <br />Approval <br />Council seems inclined to approve the growth plan based on monitoring and updating the plan <br />within three years. This seems like an overly optimistic approach based on the following points. <br />• The City's track record for setting and making deadlines is poor, for example, the <br />Envision Eugene project. <br />• Dealing with Needed Housing/code changes for objective standards and urban reserves <br />are complex and time-consuming processes and will probably delay any plan updates. <br />• With 75 to 80% of multi-family housing built or in process only five years into the plan <br />there may not be enough buildable land available to provide a cushion for three plus <br />years of monitoring and updating? <br />Relying on an approve it now and fix it later approach is dangerous. <br />