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It is unclear if the IGA should contain provisions addressing goal compliance regarding future <br />actions that may invoke Goal 11 questions, particularly since the IGA establishing the <br />Commission restricts all land use and community growth decisions to the purview of the <br />Governing Bodies. It is unclear if the IGA per se is a land use document or would become a <br />land use document if conditions related to goal compliance were included as provisions of the <br />IGA. None of the existing MWMC IGAs are considered land use documents for the reasons <br />listed here. <br />Lane County Boundary Commission Requirements <br />The final local land use process involves the Lane County Local Government Boundary <br />Commission. The Boundary Commission has approval authority for changes, mergers, <br />dissolutions, and creation of service districts; and annexations and extra-territorial extension of <br />sewer if: a) the line is a “forced main” or, b) the line is a gravity line 8” or larger. This proposal <br />could be accommodated without a change in the Metropolitan Wastewater Management District <br />boundary (which is currently specified in the MWMC IGA as the UGB) provided Coburg is a <br />customer and not a partner. However, since Coburg’s Wastewater Facilities Plan specifies that <br />the discharge to the MWMC system would be by way of a force main, the Boundary <br />Commission has approval authority of the extension of this line. <br />An extension of a sewer line outside of the city limits of Eugene or Springfield, but within that <br />city’s UGB, is defined as an extra-territorial extension if not accompanied by an annexation of <br />the land over/under which the line is extended. An extension of the sewer line beyond the UGB <br />is similarly categorized. The Boundary Commission may not approve an annexation proposal of <br />any classification that does not comply with the policies of the applicable comprehensive plan <br />(ORS 199). Without the necessary and appropriate changes to the Metro Plan, RCP, and Coburg <br />Comprehensive Plan, the Boundary Commission could not approve the sewer line extension. <br />State Agency Involvement <br />All post-acknowledgment land use decisions are referred to the Department of Land <br />Conservation and Development (DLCD) for comment. The Department’s authority to approve <br />or deny an amendment is limited to the Periodic Review process. It does not appear that the <br />statute considers this proposal to be an application requiring the Periodic Review process The <br />Department would send a copy of the proposal to affected state agencies (DLCD, DEQ, OEDD, <br />for example) for comment on program consistency issues. It is difficult to project the nature or <br />content of those comments. <br />Time Line and Direct Costs for Processing Required Amendments and Approvals <br />Attempting to quantify time lines and costs associated with the various processes necessary to <br />complete this proposal is uncharted territory. Although the history of the Metro Plan does <br />include some extraordinary amendment proposals (Short Mountain sanitary sewer extension; <br />Prison siting, etc.) none were ever adopted and none involved the variety of issues, participants <br />or coordination demanded by this proposal. <br />The time line for the land use decision (Metro Plan and PFSP only) would begin with the formal <br />initiation process. One of the three governing bodies would be required to adopt a motion or <br />resolution initiating the action. Assuming the initiating government has enough information to <br />take this action, approximately a month would be necessary to accomplish this first step <br />(scheduling, report preparation, meeting action). The ideal time frames, and steps required by <br />the Metro Plan, for processing the proposed amendments is outlined below. <br /> Page 13 <br /> <br />