June 16, 2017 Page 11 <br />The City's belief that the University HDR redevelopment need will displace residential <br />redevelopment is also inconsistent with the City assumption of only 240 units baseline <br />residential redevelopment on HDR over the 20 years (12 units/year). The City soon will <br />exceed HDR and overall redevelopment expectations for the 20 years (233 units of current or <br />planned development), so any theoretical housing redevelopment displacement would occur <br />in a subsequent planning period, even if the City's redevelopment assumptions are correct. <br />Ex. 1 & 2. The City indicated that the University projected zero student growth over the 20 <br />years, meaning that there would be no assumed baseline demand for student housing in the <br />University area which could consume the claimed displaced HDR redevelopment land. <br />(November 15, 2013 Memo). <br />Even if one assumed such use would consume all HDR redevelopment land such that none <br />of the 240 units of assumed HDR redevelopment could be built, there still would remain 405 <br />unit capacity from the asserted University HDR land need which would be beyond the 240 <br />unit HDR redevelopment goal set by the City for the planning period. <br />The 30 HDR acres deducted by the City from the land supply reflects a deduction of HDR <br />land capacity of 645 units (30 acres X 21.5 units/acre) This amount should not have been <br />deducted, and the perceived 1,617 unit deficit should be reduced by 645 du. <br />B. Exclusion of Land for Gilham Road System Water Quality Facility (32 du) <br />The City may have incorrectly removed 3 MDR acres, 32 du (for the Gilham Road system <br />water quality facility). BLI Maps 8, 9. See Ex. 3. The Gilham Road system water quality <br />facility was apparently identified as capital project WK08B in the Willakenzie Basin. An <br />August 2002 City of Eugene Stormwater document shows the project apparently being <br />located in Tax Lot 17030832-08600, which, as I understand, was the Gilham Road property <br />the City re-designated from MDR to LDR as a Metro Plan amendment. If the land is now <br />LDR, then its use for a public water facility should not result in a reduction of the MDR or <br />HDR vacant or partially vacant land supply (to avoid double deduction of land). <br />C. Exclusion of Land for Adding to Amazon Park and S-M-J House (15 du) <br />The City may have also incorrectly removed from the land supply 1.1 acre MDR to acquire <br />Amazon Park inholdings along Hilyard Street, and .3 MDR acres to acquire land in front of <br />the Shelton-McMurphey-Johnson House, since this land was designated Developed <br />Residential Lands, Committed or Protected Lands or Commercial, and does not appear to be <br />part of the vacant or partially vacant land supply. BLI Map 8,9. This 1.4 MDR acres is 15 <br />units capacity which should be deducted from the asserted 1,617 du deficit. <br />D. Other Questionable Exclusions From the Land Supply <br />The City made other questionable deductions from the land supply. The City removed 6 <br />acres MDR and 6 acres HDR needed for group quarters other than dorms. However, it <br />seems that some of the group quarters would be redevelopment which would not use up the <br />land supply. The City removed 11 acres MDR and 8 acres HDR for employment in residential <br />land designations. Such employment apparently includes that provided by neighborhood <br />