June 16, 2017 <br />Lloyd Helikson <br />Eugene, OR 97405 <br />541-357-0923 (cell) <br />lwhelikson@gmail.com <br />RE: Envision Eugene Planning Issues (Updated and Revised) <br />Mayor, City Council, Lane County Board of Commissioners and Staff: <br />1. Introduction <br />Page 1 <br />The planning done by the City as part of Envision Eugene includes apparent errors which <br />impact the data and analysis used to support the City staff findings, recommendations and <br />proposed policies. Some of the issues raised in this letter have previously been presented to <br />staff and/or Council.' The City has asserted a multifamily MDR/HDR deficit of 1,617 dwelling <br />units (du). My studies appear to show that this deficit does not exist in this planning period <br />(2012-2032). My studies also appear to show that development built or planned within the <br />planning period has resulted or will result in significantly more than the 3,776 5+ multifamily <br />units claimed by the City to be needed by the end of the planning period. Page 16 contains a <br />summary of my findings. <br />Issues: <br />• Lack of Updated 2004 Metro Plan Diagram - The official Metro Plan is a small map not <br />digitized and not lot specific. There appear to be instances where City Zoning and/or <br />Refinement Plans have "higher" designations than the Metro Plan, which presumably was <br />used to create the Buildable Land Inventory. <br />• Buildable Land Inventory/Land Model Assumption Issues - The City's data <br />assumptions may be incorrect, including as to the planning period start date. <br />• Buildable Land Inventory Data Issues -Analyzing the data to create the Buildable Land <br />Inventory revealed apparent errors resulting in underestimating multifamily dwelling unit <br />du") capacity by up to 469 du, and potentially more. <br />• Potential Inappropriate Exclusion of Capacity - The City's exclusion of capacity for <br />residential land used for non-residential purposes may have resulted in underestimating <br />multifamily dwelling unit capacity by up to 934 du. <br />• Development Much Greater Than City Assumed - A substantial amount of development <br />has occurred in Eugene since the start of the planning period, exceeding the 20 year goal <br />of 3,776 multifamily 5+ units by about 1,577 du. Such actual development has not been <br />incorporated into the Envision Eugene analysis. <br />• Development Assumptions - The assumptions made by the City for development during <br />the plan period are too low, and appear to underestimate multifamily capacity from <br />redevelopment by up to 1,560 du, from development on LDR by up to 270 du, and from <br />increased development density by up to 585 du. <br />1 See Letter to Mayor and City Council dated January 10, 2015; Rebuttal Letter to Mayor and City <br />Council dated July 13, 2015; Meeting with planning staff October 3, 2016; Letter to Mayor and City <br />Council dated October 22, 2016. Staff has been very responsive to past requests, but more recently <br />responded to requests for information and clarification by telling me "right now [staff is] focusing on <br />finalizing all the draft technical documents and not digging into technical inquiries." Email 11 /10/16. <br />