June 16, 2017 Page 2 <br />The Buildable Land Inventory ("BLI") and the Eugene Land Model, which is based upon the <br />BLI, appear to have errors in data, assumptions, and analysis. The City's analysis is complex <br />and not transparent in some respects. Statewide Planning Goal 1 requires that the City <br />"develop a citizen involvement program that insures the opportunity for citizens to be involved <br />in all phases of the planning process." The program is required to "provide for continuity of <br />citizen participation and of information that enables citizens to identify and comprehend the <br />issues." Although the City should not be held to "an unreasonably high level of precision," the <br />20-year need determinations are estimates which are to be "based on the best available <br />information and methodologies." OAR 660-024-0040(1). The City's calculations and <br />estimates should be adjusted so as to be based upon the best available information and <br />methodologies. <br />II. Lack of an Updated 2004 Metro Plan Diagram <br />The planning problems start with the use of an outdated 2004 Metro Plan diagram. The <br />diagram is an 11" X 17" piece of paper containing the metropolitan Eugene-Springfield land <br />use designations. A memo from the City Attorney's office indicated that "the City does not <br />have an adopted digitized map. The 2004 Metro Plan Diagram was `derived' from a digital <br />database; however, the hard copy of the 11 x 17 map was the only diagram that was officially <br />adopted." 2 <br />The Metro Plan diagram is the governing source of land use designations for land use <br />decisions in Eugene. 3 "[T]he `digital version' of the Metro Plan diagram is one or more maps <br />generated by a digital database maintained by the Lane County Council of Governments <br />(LCOG)." "[M]aps generated from the LCOG database are not officially adopted maps, and <br />* * * the paper 2004 Metro Plan diagram is the relevant Metro Plan diagram for purposes of <br />EC 9.8865(1)." Laurel Hill Valley Citizens v. City of Eugene (Or. LUBA 2016), at 40 n 1. The <br />diagram has been the source of planning issues. Id. <br />Under ORS 197.296(4)(c), "[e]xcept for land that may be used for residential infill or <br />redevelopment, a local government shall create a map or document that may be used to <br />verify and identify specific lots or parcels that have been determined to be buildable lands." <br />The 2004 Metro Plan Diagram presumably was used to create the 2012 Buildable Land <br />Inventory (BLI) dated 8/1/12.4 The inventory is required to include vacant or partially vacant <br />lands "planned or zoned for residential use." ORS 197.296(4)(a)(A) & (B). The City <br />presumably used the Metro Plan land designations for the BLI, even where an existing <br />refinement plan and/or zoning is "higher" than such designations. <br />2 Memorandum dated October 23, 2015 from Anne Davies to the Planning Commission related to <br />Laurel Ridge (Z 15-5), at 3 n 1. Exhibit 4 <br />3 Id. Memorandum at 1-2. The Memo describes the diagram as "blobby" and indicates "city limits <br />and tax lots are not depicted on the 2004 Metro Plan diagram." Memo at 2, 3. Exhibit 4 <br />4 The digital non-official version of the 2004 Metro Plan Diagram may have been used for creating <br />the BLI. The City may have used an updated digitized diagram, incorporating changes to the Metro <br />Plan since 2004. Such information may be reflected in the online "Lane County Easy Property <br />Information Lookup." <br />