June 16, 2017 Page 13 <br />The City does not want to consider development to date within the planning period, but <br />nevertheless considered changes to Metro Plan land designations within the planning period. <br />The City amended the Metro Plan to re-designate 1,833 du MDR to LDR land. Eugene <br />Ordinances 20535, 20536 (8/10/14), MA-13-002. These changes removed an asserted LDR <br />land deficit and create an asserted MDR/HDR land deficit. The full amount of the asserted <br />MDR/HDR land deficit can be accounted for by this Metro Plan amendment. If the City insists <br />on not including actual development/redevelopment within the planning period, then it also <br />needs to exclude land use changes such as Metro Plan amendments, within the period. <br />The City has stated that it needs 3,776 5+ multifamily units within the 20 year period to meet <br />the population forecast. My studies show that the City will have met that goal within the next <br />several years from units built or planned since 7/1/12, based upon certificate of occupancy.12 <br />My studies show that there have been or will be 5,353 5+ units built with a certificate of <br />occupancy on or after 7/1/12, or planned since that date.13 The quantity of built or planned <br />units exceeds the 3,776 5+ multifamily unit goal by 1,577 5+ units. The City's goal will <br />have been met well within the first half of the twenty year period. Although this analysis does <br />not rely on the land supply, it must mean that the multifamily MDR/HDR land supply is <br />adequate. <br />VII. Development Within the Planning Period is at a Higher Density than Assumed by <br />the City <br />My studies show that multifamily development on vacant or partially vacant land has occurred <br />at a higher density than assumed by the City in its land model. Multifamily development on <br />MDR or HDR, planned or built with a certificate of occupancy on or after 7/1/12, has or will <br />occur at a higher density than assumed, resulting in an additional 585 du capacity. See <br />Exhibit 2. <br />VIII. Development Within the Planning Period is Higher on LDR Than Assumed <br />The City assumed that multifamily development on LDR would be 446 units (6,797 MF du <br />less 6,351 du MDR/HDR housing demand). See Exhibit 3. My studies show that built or <br />planned multifamily units within the planning period are currently at 716 units. Thus, an <br />additional 270 multifamily units are built or planned on LDR beyond that assumed by the City. <br />IX. Redevelopment Within the Planning Period Is Much Greater than City Assumptions <br />The City significantly underestimated the redevelopment which would occur for multifamily <br />housing during the planning period. <br />12 See attached studies, Exhibits 1, 2 & 3. <br />13 The certificate of occupancy date is the appropriate start date for purposes of assessing <br />development within the planning period. As previously discussed, the issuance of the certificate of <br />occupancy makes the development legally able to be occupied for purposes of meeting new <br />population growth reflected in the population forecast, which started July 1, 2012. Development with <br />a permit issued may not be legally able to be occupied for another year or two depending on the <br />complexity of the project, and thus a permit issue date is not appropriate to use as a start date. <br />