PUBLIC COMMENT – LLOYD HELICKSON (6-16-17)

June 16, 2017 Page 4 but not immediately replaced, and perhaps other scenarios. Examples of these types of issues are discussed in section IV. The City appears to have used permit issue date as the end date for development prior to the planning period and the start date for development within the planning period. However, the permit issue date could be one or more years before a commercial apartment project becomes available to meet the population forecast for multifamily units. A much better indication of development at the start of the planning period would be the existence of an address with a year built before 2012 or certificate of occupancy before 7/11/12. A certificate of occupancy is the best date to use since it is the exact date when development is legally able to be occupied and becomes available to meet the population forecast which starts 7/11/12. IV. Buildable Land Inventory Data Issues There may be problems with the City's BLI data, and some examples are set forth below. The examples reveal up to 457 du multifamily residential unit capacity, or more, not included in the BLI. These potential problems may apply to other land beyond these examples. The BLI data is represented in 10 pdf maps available online. See link to "2012 Residential Buildable Lands Inventory Maps" at www.eugene-or.gov/2453/Land-Supply-and-Capacity. A. Potential error in considering land developed when address assigned by City prior to 8/1/12, earlier than when permit or certificate of occupancy issued ( up to 149 du) Tax Lot 17042410-01000: 17.30 HDR acres (created PUD lots: 02100, 02200, 02300, 02400): Riverwalk Apartments, Waterford Grand. The lot shows on BLI map 5 as partially vacant HDR, but does not identify how much was considered developed versus vacant.5 Land use documents indicate that the land was vacant (e.g., PDT 9-001). The four PUD lots (02100, 02200, 02300, 02400) total 14.51 HDR acres. This leaves 2.79 acres of the original lot which might have been considered development (greenway and Eugene bike lane along the river), and which might not have been part of the four PUD lots. All of the four created lots had permits issued after 8/1/12 and should not have been considered developed.6 Lot 02400 (6.94 acres) had a permit applied for prior to 8/11/12, but not issued until after that date (1/8/13). An address, later changed, was assigned prior to the permit issue date. The Lot had zero RMV for structures as of the 2013-14 tax year, 1 /1 /13, based upon Lane County Tax Property Account Information. The Metro Plan shows the 02400 lot as split designated HDR, MDR and POS. There could be an error in removing up to 6.94 HDR vacant acres (149 du capacity) from the Eugene residential land supply as of 8/1/12.7 5 It is not clear what portion of a partially vacant lot the City includes in the land supply. 6 Again, the certificate of occupancy date rather than permit issuance date should have been used as the end date for development, but it does not appear to make a difference in this case. 7 LDR density @ 4.0 units/acre; MDR density @ 10.7 units/acre; HDR density @ 21.5 units/acre. These are minimum densities for discussion purposes, and may be higher in specific cases.