HomeMy WebLinkAboutPUBLIC COMMENT – BILL ASPEGREN (6-16-17)June 16, 2017
To: Eugene City Council and Lane County Board of Commissioners
From: Bill Aspegren
Subject: Testimony for the June 27, 2017 Joint Public Hearing of the Eugene City Council and
the Lane County board of Commissioners - Specifically Ordinance #2 (Land for Housing) Multi-
Family Problems
Over two years ago both the Eugene City Council and Eugene's Planning Division were told of
conflicts between the multi-family growth plan and what was happening in the community. No
action was taken to correct the problem. Excuses were made and the problem was ignored.
Work continued, without a change in direction, until today you have before you a multi-family
growth plan that bears no resemblance to reality. Even worse, the planning staff is
recommending changes to minimum density in R-2 residential zones based on inaccurate
information. This is to help offset an alleged deficit of 1,600 multi-family units. There is no deficit
(see endnote'), and no need for a code amendment.
Problems
Simply stated the growth plan's multi-family estimates have been grossly underestimated'.
Currently, between 75 and 80% of the projected 20-year need has been built, is being built or is
planned and the 20-year growth plan is only five years old.
How did this occur? Both data and assumptions used by the land model are incorrectz. This has
the potential to affect more than just multi-family projections.
Questions
Since we are already five years into the proposed plan, you would think there would be a
reasonable correlation between multi-family projections and actual experience. There isn't,
which raises many questions.
• Is it just incorrect data and assumptions?
• Are economic conditions creating more renters?
• Is the housing mix incorrect?
• Have multi-family units been overbuilt?
• How are lands for employment affected?
The problems with multi-family projections is a symptom of greater problems with the overall
growth plan. It raises the question of whether or not any of the projections can be trusted if the
data and assumptions are wrong.
1 Based on Lloyd Helikson's detailed analysis and testimony of multi-family housing development since July 2012 to
date. Submitted for review by the joint planning commissions and updated for the Eugene City Council and Lane
County Commissioners June 27, 2017 meeting.
2 See my testimony dated March 2, 2017 submitted for the joint planning commission's public hearing, especially
section titled Plan Problems.
Discussions
These problems and questions have been discussed with the planning staff to no avail. In fact,
in the February 24, 2017 Envision Eugene Newsletter3 there was a statement made about why
the data and assumptions could not be changed. The joint planning commissions also ignored
the problems with residential projections.
In order to set our UGB for twenty years of growth, certain assumptions and models were
used to determine just how much land is required to support our community vision. Things
like the number of jobs we expect to attract, our predicted population growth, and the
assumed household size all impact how much land we will need for homes, jobs, parks,
and schools. You can learn more about these assumptions in our Population and
Demographics Fact Sheet.
We know people are concerned about some of our assumptions, including population
forecasts and housing mix (the ratio of single family detached homes to multifamily
dwellings), and how they compare to recent reports about what is currently taking place in
our community. We know that 2012, the year our assumptions are based on, feels like a
long time ago. In order to move forward with creating our own UGB, Council gave us
direction to use the adopted population forecasts in 2012 and reaffirmed this direction in
2015, so that we could set our baseline UGB. Updating our assumptions now would set
us back a number of years. In addition, updating one assumption means you have to
update them all because they all interrelate.
Monitoring and Adjusting - Flexible Implementation
Setting our UGB allows us to begin monitoring - an important program that will allow us to
adapt to emerging trends. Setting our UGB also allows us to begin urban reserve planning
using the most recent population forecasts. If our previous population forecasts or
housing mix are off, we will be better prepared to consider necessary changes to
implement our community vision and values.
Obviously, the newsletter excerpts are an attempt to defuse comments such as mine.
I don't believe doing the job right will set the project back several years, and the staff has
already had more than two years to fix the problem.
The land model is a series of Excel spreadsheets. The assumptions can be changed with a few
key strokes, to test various scenarios and tune the model for correctness. Fixing the data is
more difficult.
s Ibid.
The following section was included in the June 8, 2017 Envision Eugene Newsletter.
Approval Criteria
Does ordinance #2 meet the approval criteria in the various Oregon Administrative Rules,
statutes and local approval criteria? To some degree this is a moot point since the growth plan
is so far off the mark it needs major revisions.
OAR 660-024-0040 states:
"The 20-year need determinations are estimates which, although based on the best
available information and methodologies, should not be held to an unreasonably high
level of precision."
The start date of the growth plan is five years ago. The staff and Council has been presented
with data, in the record, that shows multi-family projections lack reasonable precision. As
mentioned earlier this raises questions about many other aspects of the plan.
Staff has also alleged there will be a 1,600-unit deficit in multi-family housing over the next 20
years. The solution is to change minimum density for R2 property and to assume (hope) 1,000
units will be built downtown. First, this "solution" should be dropped since the evidence confirms
a deficit does not exist.
Second, ORS 197.296 (6) does not list assume/hope as an option for dealing with a residential
deficit.
The spirit of planning goal one, citizen involvement, has certainly not been met when problems
are pointed out and ignored. To make it worse staff then publishes articles trying to justify why
they ignored the warnings.
Monitoring
Staff has promised to monitor and update the growth plan within three years of UGB
acknowledgement (by who, Council, the State?). That will be over five years after staff was first
notified of the problems.
Approval
Council seems inclined to approve the growth plan based on monitoring and updating the plan
within three years. This seems like an overly optimistic approach based on the following points.
• The City's track record for setting and making deadlines is poor, for example, the
Envision Eugene project.
• Dealing with Needed Housing/code changes for objective standards and urban reserves
are complex and time-consuming processes and will probably delay any plan updates.
• With 75 to 80% of multi-family housing built or in process only five years into the plan
there may not be enough buildable land available to provide a cushion for three plus
years of monitoring and updating?
Relying on an approve it now and fix it later approach is dangerous.
Action
My preferred action would be to reject the proposed growth plan and send it back to create
more accurate data and assumptions. However, much time and effort has gone into the current
package and everyone wants to see this proposal move to the next level.
As an alternative, approve the plan with some conditions.
• Based on the data that shows multi-family development is far ahead of projections, do
not alter R2 minimum densities.
• Form a commission tasked with creating reliable data and a new detailed assessment of
land within the UGB:
o Using lot specific metro plan maps
o Resolving metro plan and zoning conflicts
o Creating site verified buildable land inventory maps
• Enter the updated data and new assumptions into the land model to create a new UGB
plan, and try various scenarios.
• As part of the commission include:
o A City Councilor
o A planning commissioner
o Planners
o Community members with land use interest and knowledge
o An outside consultant familiar with creating a buildable land inventory
• Set a hard target for completion of 18 months
• Defer work on code changes for objective standards and urban reserves
I want to see Eugene's growth plan move to the next level as much as anyone. At the same
time, I want the product to be based on the best available data and assumptions. Please
consider my comments when evaluating the proposed plan.
Thanks,
Bill Aspegren
Not having a multi-family deficit brings up the question, is MUPTE needed to build apartments downtown? City
policies may have already led to multi-family units being over built during the planning period and offering 10-year
property tax exemptions only makes the situation worse. Obviously, this does not affect ordinance #2, but points
out the danger of making decisions without proper information.
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