Item 2: PH on Resolution Adopting Amended SDC Methodology and Rates

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affordable single-family detached homes in Eugene; thus, families and single persons who need affordable housing must increasingly rely on rental units in multifamily complexes for housing. Further raising the SDCs on new multifamily units is counterproductive in terms of having affordable housing in Eugene. We only raise this issue because, first, we are always concerned whenever SDCs methodologies rely on questionable data and, second, we are going to suggest a trade later in these written comments. III. The methodology relies on levels of service from a source that has been remanded by the Land Use Board of Appeals (LUBA). There are some who argue that the requirement in the state statute that an SDC methodology be based on a project list eliminated the Level of Service approach to methodologies in Oregon. Others (including me) believe that the level of service approach is appropriate as long as it is all adopted level of service that leads to the development of the project list. Suppose a community of 100,000 residents decides through its park planning process that it wants 15 acres of natural area per 1000 residents, it is expecting to grow by 20,000 residents during the planning period, and the jurisdiction currently has a level of service of 10 acres per resident. It is then a simple math problem to calculate how many new acres of natural areas need to be acquired, how many acres current residents must pay for to raise their level of service from 10 acres per thousand to 15 per thousand; and how many acres are needed to meet the demands of growth. Current residents would need (15 acres - the current 10 acres) x 100,000 residents / 1,000 = 500 more acres. Growth would need 15 acres x 20,000 residents r 1000 = 300 acres. Thus, the project list would include the acquisition of 800 more acre~ of natural area with current residents paying for 62.5% of the cost and new residents paying 37.5% of the cost. The proposed methodology states under:Section 1.2.2 Improvement Fee that "(T)he project list represents the community's desired level of service over the planning period, as articulated through the PROS Comprehensive Plan development process." This would appear to meet the requirement that the project list be the result of a planned level of service rather than vice versa. However~ there are two problems with the statement in the methodology. First, LUBA has remanded the PROS Comprehensive Plan and one of the issues is the lack of mandatory standards (Le. desired level of services). The HBA and the HCC appealed the PROS Plan to LUBA, principally because the city contended that PROS was an "aspirational" document that had no impact on the residential land supply. On the issue of whether PROS could be an "aspirational" document that guides park acquisition and development, LUBA held: In summary, we agree with petitioners that a PROS Plan that is a purely aspirational document, which is binding on no one, is not sufficient to comply with Metro Plan Parks and Recreation Facilities Element Policy H.2 and related provision$ in the Metro Plan Parks and Recreation