Item B: Ordinance Concerning Goal 5 Natural Resources Study

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~ Home Builders ASSOCIATION of Lane County September 28, 200S Mayor Piercy Eugene City Council City of Eugene 777 Pearl Street Eugene, Oregon 9740 I RECEIVED OCT - 3 2005 CITY OF EUGENE PLANNING DEPARTMENT Dear Mayor Piercy and Councilors, The Home Builders Association of Lane County and the Home Builders Construction Company appreciates the opportunity to comment on the Goal S impact on the residential buildable land supply and the proposed ordinance. The HBA has previously expressed concern about the acute shortage of residential land within the Eugene / Springfield urban growth boundary. The analysis of the Goal S impact, combined with information from LCOG's June, 2001, Eugene/Springfield Metro Area Residential Land Monitoring Annual Report, demonstrates the reason for our concern. The Goal S analysis, for example, concludes that the remaining surplus oflow density residential land under the high demand possibility is a mere 127.04 acres- approximately a six-month supply ofland. However, the analysis fails to take various necessary deductions into account. The Goal S analysis properly deducts land impacts from previous plan amendments and changes in land use designations. However, a notation to the table "City of Eugene Plan Amendments that Redesignated Land and Affected Buildable Land Inventories" states that the table does not include reductions in the land supply due to legislative rezoning. As noted in the Goal S background information, the 1999 Residential Land Study defined residential land as: "land that is zoned or designated residential in the Eugene- Springfield DGB". Therefore, land that is rezoned from residential to another land use must also be deducted from the available supply of residential land. The impacts from zoning changes from July, 1992 and June, 2000 is provided by LCOG in the monitoring report it did in 2001. Any additional changes since June, 2000 would have additional impacts on the land supply. The analysis ofthe GoalS impact on the land supply also did not take slopes of the impacted lands into account. It is not sufficient to analyze the impact on the supply of land. The impact on the demand for land must also be considered. At the time that Goal S is being considered, a significantly greater portion ofthe remaining land is on slopes greater than 2S% (compare the table of sloped lands in the 1999 Residential Lands and Housing Study Supply and Demand Technical Analysis, page 42, with the updated data 2053 Laura Street Springfield, OR 974n (541) 484-5352 FAX: (541) 484-5386