June 16, 2017 Page 14 <br />For baseline redevelopment over the twenty years, the City assumed there would be 220 <br />units on MDR, 240 units on HDR, and 256 units on COM (Commercial and Commercial MU), <br />for a total of 716 units of baseline multifamily housing redevelopment on MDR/HDR and <br />COM. The MDR/HDR redevelopment was based upon an assumed 11 units per year on MDR <br />and 12 units per year on HDR, for 20 years, based upon the average annual redevelopment <br />between 2001 and 2012, as I understand. <br />For Commercial redevelopment, the City used a redevelopment tool to assume there would <br />be 21 units built downtown, 235 units built along Franklin Boulevard, and none built <br />elsewhere, over the 20 years. Thus, other than the 235 du student housing committed to be <br />built on COM as of 10/18/13, the City assumed 21 units of housing would be built on COM <br />throughout the City over the entire 20 year Envision Eugene period (actually 21 units <br />downtown and zero units throughout the rest of the City). This assumption was way too low. <br />The City accounted for 325 units of HDR and 853 units of COM student housing <br />redevelopment near the University committed since December 31, 2012 ("pipeline <br />redevelopment"). Committed was defined as having applied for a building permit or attended <br />a predevelopment consultation conference after 12/31/12 and before 10/18/13. Even though <br />the planning period was 2012-2032 and the population forecast was as of 7/1/12, the City <br />said "projects constructed prior to this date were accounted for through a separate analysis <br />updating the Buildable Lands Inventory and related assumptions." November 15, 2013 <br />Memo. The City decided to subtract the 235 units on COM assumed to be built along <br />Franklin Boulevard from the pipeline redevelopment, resulting in a net pipeline development <br />of 325 units HDR and 618 units COM, or a total of 943 du. See Ex. 3 <br />My studies, using certificate of occupancy as of 7/1/12, show that there has been or is <br />planned multifamily redevelopment of 638 units MDR, 558 units HDR and 2,023 units <br />"Other" (COM, GO, Committed or Protected Lands, but not LDR) as of now, 4.5 years into the <br />20 year planning period.14 When the City's net pipeline redevelopment is subtracted, there <br />remains actual or planned redevelopment of 638 units MDR, 233 units HDR, and 1,405 units <br />Other. This compares to the 20 year City assumptions of baseline redevelopment of 220 <br />units MDR, 240 units HDR and 256 units COM only 4.5 years into the planning period. The <br />City thus significantly underestimated baseline redevelopment. This adds 418 units MDR, -7 <br />units HDR and 1,149 units "Other" of redevelopment (1,560 units total) not considered by the <br />City in its assertion of a multifamily MDR/HDR deficit of 1,617 du capacity. Actual <br />redevelopment beyond that assumed by the City thus accounts for 96% of the asserted <br />multifamily land deficit, only 4.5 years into the planning period. Those projects planned but <br />not yet built may not be completed for another several years, but this would still be in the first <br />half of the twenty year planning period. <br />14 8 units MDR, 550 units HDR and 1,224 units Other for student housing; 630 units MDR, 8 units <br />HDR and 799 units Other for non-student housing. It is necessary to include COM, GO, Committed or <br />Protected Lands, but not LDR, in "Other" redevelopment so as to account for all multifamily residential <br />redevelopment, and not just that occurring on COM (or MDR/HDR). <br />