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<br />was adopted. Therefore as City staff correctly indicates in the findings EC 9.8424(2) (a), (b), (d) <br />and (e) do not apply. <br /> <br />This leaves criteria (c). In tbe findings it is indicated tbat the Metro Plan amendment, which is <br />part of the three part legislative package, constitutes "New or amended community policies" and <br />thus the proposed Refinement Plan Amendment is consistent with EC 9.8424 and thus is a <br />permissible lilCtion. This conclusion is in error for a number of reasons. First, the Metro Plan has <br />not been amended yet, therefore it is not' a New or amended community policy. <br /> <br />Second as stated above tbe Metro Plan is being changed to be consistent with the Refinement <br />Plan rather then the more normal circumstance where the lower document changed to be <br />consistent with a high one. While somewhat unorthodox, as long as the finisb product is <br />consistent from higher to lower state requirements are met. It does however that does mean that <br />proposed Metro Plan Amendment does not represent a new or amended community policy that <br />requires a Refinement Plan Amendment, rather it is the Refinement Plan Amendment that <br />represents a new or amended community policy. One that would require the Metro Plan to be <br />changed for the final result to meet the Metro Plan Requirement that Refinement Plans be <br />c.onsistent with the Metro Plan. <br /> <br />As the Refinement Plan Amendment is a new community policy rather then "addressing" a new <br />community policy imposed from above, criteria (c) also does not apply. As none of the Criteria <br />in EC 9.8424 are met by the proposed Refinement Plan Amendment, that Amendment does not <br />meet the criteria contained in EC 9.8424 and should be rejected. <br /> <br />Subsection (1) <br />Subsection (l) ofEC 9.8424 requires that a proposed refmement plan amendment be consistent <br />with The Statewide Planning Goals and applicable provisions of the Metro Plan and remaining <br />portions of the .refineUlel1t plan. <br /> <br />The proposed refmement plan is not consistent 'With State Wide Planning Goals 10 and 12, Nor is <br />it consistent witllMetro PIa.n ~olic)l A 13 . <br /> <br />Goal 10 Housing <br /> <br />As it is correctly pointed out in the Findings, Go all 0- Housing requires that communities plan <br />for and maintain an inventory of buildable residential land for needed housing units. This is <br />commonly referred to as the "twenty year land supply" as the Administrative Rules establishing <br />the requirement for the inventory requires that the completed inventory show that at the time the <br />inventory is accepted there is a 20 year supply of residential land within the Urban Grovvth <br />Boundary. Equally correct is the assessment that by changing the designation of 57 acres of <br />buildable residential land from Medium Density to Low Density will impact the residential land <br />inventory by reducing the number of dwelling units that could be built in the area. <br /> <br />At this point the findings contain the unsupported assumption that the next Residential Land <br />Inventory Process will use the same methodology that the last one used. As a new Residential <br />Land Inventory has not been started and is not there a mandated methodology in statute or <br />ordinance that must be used in the next Residential Land Inventory any inventory methodology <br /> <br />I:1: ink ley <br />Testiulony on 1\1A 06-5, Ra 06-3 and (:1'\ 06-1 <br />5 fJecell1ber 2006 <br />Page 3 of 12 pages <br /> <br />