HomeMy WebLinkAbout2007-1016 Documents Submitted at the Meeting
TO THE ASHLAND CITY COUNCIL
I BELIEVE THAT IT IS TIME FOR SOME ACCOUNTABILITY AND TAKING
RESPONSIBILITY FOR ACTIONS I HAVE SOME QUESTIONS THAT I THINK THE
PEOPLE WHO ELECTED YOU ARE ENTITLED TO HAVE YOU ANSWER>
Reoorted in the latest Sneak Preview that Counsilors were asked not to soeak to the oress.
aooarentlv about the latest controversy about counsel dysfunction or exoenditures for counseling
WHO ASKED YOU NOT TO SPEAK TO THE PRESS? WHAT WAS THE MOTIVE
FOR THAT REQUEST?
WHO DECIDED THAT COUNSELING WAS APPROPRIATE AND BY THIS DR
KIRSCHNER IN PARTICULAR? The first explanation appeared in the Sneak Preview
yesterday that Mr. Morrison talked to the counselors and each one felt ity was something you
needed to do. EXCEPT FOR MS. HARDESTY WHO SUGGESTED DR. KIRSCHNER,
WERE ANY OTHER COUNSELORS CONSIDERED, CONSIDERING THE HIGH COST?
The Tidings states that a group of residents who seek to limit growth and undermine the planning
process are working with Counsilors Hartzell, Navickas and Hardesty to undermine the city
processes and overwhelm city departnents. IS THIS TRUE?
Shadow Government. Cathy Shaw was quoted in the Tidings as saying that Cate Hartzell, Alice
Hardesty and others got together on Sunday mornings to plan overwhelming department heads
or administrators. The Tidings says the existqnce of a shadow govt is uncertain. DOES IT
EXIST?
The Tidings reports that Ms. Hartzell is at the heart of dysfunction in the Counsel. Alan DeBoer
stated that Ms Hartzell takes over an issue, is unprepared and tries to micro manage MY
QUESTION TO HER IS HOW DO YOU JUSTIFY THIS BEHAVIOR?
To Mr. Navickas: MR. CHAPMAN REPORTED THAT HE SIMPLY LOST HIS TEMPER.
WITHOUT EXCUSING MR. CHAPMAN'S CONDUCT, YOU HAVE BEEN ACCUSED OF
CONSISTENT NEGATIVE BEHAVIOR IN THE COUNSIL. HOW DO YOU JUSTIFY
BEHAVIOR THAT WOULD CAUSE A FELLOW COUSELOR TO ERUPT IN PROFANITY?
Discussion in the Press has talked about Insulating the City Staff from Council interference
Kathy Shaw states that a strong mayor is the ChiefExective of this Municipal corporation and
that the Mayor appoints dept. heads and can insulate them from the Counsel. MR MORRISON
WHY HAVE YOU NOT DONE THAT?
There are many other questions that can be asked that I don't have time for. But I think that it is
time that it is time for accountability. A place to start is answering these questions and others
raised by press reports and by citizens here.
Another place to start. . . I understand that City Departments and the council itself are not required
to do line item budgeting. Then this is another place to start. I suggest that no city expenditure
in excess of $5000 be permitted without going to competitive bidding...that is public
competitive bidding. This would have eliminated this unreasonable expenditure of $37,000 for
therapy, counseling or training, whatever you call it.
CAN YOU GIVE US ANY ANSWERS?
Don Stone
395 Kearney St., Ashland
48'f(-~CJ7D
TO THE ASHLAND CITY COUNCIL
I BELIEVE THAT IT IS TIME FOR SOME ACCOUNTABILITY AND TAKING
RESPONSIBILITY FOR ACTIONS I HAVE SOME QUESTIONS THAT I THINK THE
PEOPLE WHO ELECTED YOU ARE ENTITLED TO HAVE YOU ANSWER>
RepOrted in the latest Sneak Preview that Counsilors were asked not to sneak to the press.
apparentlv about the latest controversv about counsel dysfunction or expenditures for counseling
WHO ASKED YOU NOT TO SPEAK TO THE PRESS? WHAT WAS THE MOTIVE
FOR THAT REQUEST?
WHO DECIDED THAT COUNSELING WAS APPROPRIATE AND BY THIS DR
KIRSCHNER IN PARTICULAR? The first explanation appeared in the Sneak Preview
yesterday that Mr. Morrison talked to the counselors and each one felt ity was something you
needed to do. EXCEPT FOR MS. HARDESTY WHO SUGGESTED DR. KIRSCHNER,
WERE ANY OTHER COUNSELORS CONSIDERED, CONSIDERING THE HIGH COST?
The Tidings states that a group of residents who seek to limit growth and undermine the planning
process are working with Counsilors Hartzell, Navickas and Hardesty to undermine the city
processes and overwhelm city departnents. IS THIS TRUE?
Shadow Government. Cathy Shaw was quoted in the Tidings as saying that Cate Hartzell, Alice
Hardesty and others got together on Sunday mornings to plan overwhelming department heads
or administrators. The Tidings says the existqnce of a shadow govt is uncertain. DOES IT
EXIST?
The Tidings reports that Ms. Hartzell is at the heart of dysfunction in the Counsel. Alan DeBoer
stated that Ms Hartzell takes over an issue, is unprepared and tries to micro manage MY
QUESTION TO HER IS HOW DO YOU JUSTIFY THIS BEHAVIOR?
To Mr. Navickas: MR. CHAPMAN REPORTED THAT HE SIMPLY LOST HIS TEMPER.
WITHOUT EXCUSING MR. CHAPMAN'S CONDUCT, YOU HAVE BEEN ACCUSED OF
CONSISTENT NEGATIVE BEHAVIOR IN THE COUNSIL. HOW DO YOU JUSTIFY
BEHAVIOR THAT WOULD CAUSE A FELLOW COUSELOR TO ERUPT IN PROFANITY?
Discussion in the Press has talked about Insulating the City Staff from Council interference
Kathy Shaw states that a strong mayor is the Chief Exective of this Municipal corporation and
that the Mayor appoints dept. heads and can insulate them from the Counsel. MR MORRISON
WHY HAVE YOU NOT DONE THAT?
There are many other questions that can be asked that I don't have time for. But I think that it is
time that it is time for accountability. A place to start is answering these questions and others
raised by press reports and by citizens here.
Another place to start...I understand that City Departments and the council itself are not required
to do line item budgeting. Then this is another place to start. I suggest that no city expenditure
in excess of $5000 be permitted without going to competitive bidding. . . that is public
competitive bidding. This would have eliminated this unreasonable expenditure of$37,000 for
therapy, counseling or training, whatever you call it.
CAN YOU GIVE US ANY ANSWERS?
Don Stone
395 Kearney St., Ashland
INTERGOVERNMENTAL AGREEMENT
FOR LIBRARY SERVICES
City of Ashland and Jackson County
This Agreement is entered into this _ day of , 2007 by and
between THE CITY OF ASHLAND, Oregon, and JACKSON COUNTY, Oregon. The
EFFECTIVE DATE of this Agreement is November I, 2007.
RECITALS
A. ORS 190.010 permits units of local government to enter into intergovenunental
agreements for the performance of any or all functions and activities that a party to the agreement
has authority to perform; and
B. ORS 357.410(3) permits units of local government to provide jointly a public
library or public library services or share in the use of facilities, under such terms and conditions
as may be agreed upon.
C. Jackson County has entered into a contract with Library Systems & Services, LLC
(LSSI) to provide inter alia library services at the City of Ashland Branch at a level of service
more fully described in the Professional Services Agreement Between Jackson County and
Library Systems & Services, LLC. dated September 18, 2007; and
D. The City of Ashland desires to supplement the level of service provided by LSSI
to Ashland residents by providing funding to Jackson County to contract for additional services
via an amendment to the Professional Services Agreement Between Jackson County and Library
Systems & Services, LLC; and
E. The City and County entered into an Agreement conceming the Ashland Branch
of the Jackson County Library on February I, 2000. The provisions of that agreement remain in
full force and effect and any actions, claims or proceedings arising out of or pursuant to that
Agreement are expressly not waived, amended or altered by this Agreement;
NOW, THEREFORE, in consideration for the mutual covenants contained herein the
receipt and sufficiency of which are hereby acknowledged, the parties agree as follows:
I. RECITALS. The recitals set forth above are true and correct and are
incorporated herein by this reference.
2. DURATION AND OPTION TO EXTEND. [ORS 190.020(1)(e)]. The
term of this Agreement shall be after approval and execution by both parties and shall expire on
June 30, 2009. The Ashland City Administrator has the option to extend this Agreement once, by
twelve (12) months, by indicating in writing to Jackson County that an extension of the
Agreement is sought under the same terms and conditions of this Agreement and that the City
has secured funding for the extension. Approval of the extension option is the sole discretion of
Jackson County Administrator.
Intergovernmental Agreement
Library Services - City of Ashland and Jackson County
Page 1 of7
3. FUNCTIONS OR ACTIVITIES. [ORS 190.020(1)]
A. A detailed scope of services to be provided to the Ashland Branch of the
Jackson County Library pursuant to the September 18, 2007, Professional Services
Agreement Between Jackson County and Library Systems & Services, LLC. (Operations
Agreement) is fully set forth in the Agreement, (including Table A) and includes
generally the full compliment of Jackson County Library Services, with 24 hours of
Ashland Branch Library operation and six (6) full time employees (FTE) at the Ashland
Branch, said Operations Agreement being incorporated herein by this reference. The
additional services requested by the City of Ashland pursuant to this Intergovernmental
Agreement shall be in addition to, and not in lieu of services provided by Jackson County
to the Ashland Branch Library pursuant to the September 18, 2007, Operations
Agreement. The City of Ashland recognizes and acknowledges that technological
innovation, professional development, and maximum staff effectiveness in library
operations, among many other factors, determines the total number of staff located at
each particular library branch, and that the number has the potential likelihood to change.
B. A detailed scope of services to be added by the proposed Amendment to
the Operation Agreement (Enhanced Services) and the itemization of costs for such
services, and required contract amendment provisions as contemplated in this
Intergovernmental Agreement, including generally an additional 16 hours of Library
operation per week, and up to three (3) full time employees (FTE) or the equivalent, is
more fully set forth in Exhibit A attached hereto ~d made a part hereof by this reference.
4. PAYMENT. [ORS 190.020(1)(a)]. The City of Ashland shall promptly pay
monthly to Jackson County for the cost of the additional services provided to the Ashland Branch
of the Jackson County Library as contemplated in Exhibit A. Payment shall be made to Jackson
County on or before the 5th day of each month in advance of the service due to the contractual
payment obligations of Jackson County with the Contractor. Jackson County shall retain
responsibility to make payment to Contractor in accordance with the Operations Agreement.
5. REVENUE. [ORS 190.020(I)(b)]. There are no revenues expected to be derived
pursuant to this Agreement that need to be apportioned between the parties. All fees, fines and
charges, collected by Jackson County's contractor, LSSI, as a result of the work performed by
LSSI pursuant to the Amendment contemplated by this Agreement to provide enhanced services
to the City of Ashland shall be the sole property of Jackson County and LSSI, and Ashland shall
have no claim or entitlement to such revenues.
6. PERSONNEL. [ORS 190.020(I)(c)]. No employees will be formally transferred
between County and City pursuant to this Agreement and this Agreement does not change the
status of any employee, contractor or officer of the respective parties.. Jackson County has an
existing contractual relationship with LSSl and neither this Intergovernmental Agreement nor the
Amendment contemplated herein shall change the contractor status of LSSI, its officers or
employees or make any personnel of LSSI or Jackson County an employee or contractor of the
City of Ashland.
Intergovernmental Agreement
Library Services - City of Ashland and Jackson County
Page 2 of7
7. REAL OR PERSONAL PROPERTY. [ORS 190.020(l)(d)] There shall be no
transfer of title or possession to any real or personal property pursuant to this Agreement. At the
time this agreement is entered into by the City of Ashland and Jackson County, the City is the
owner of the building and of all materials in the Library acquired prior to 1970. Jackson County
is the owner of all the equipment and materials in the building including but not limited to books,
furniture, shelving and library equipment. No provision of this Agreement shall expressly or
impliedly operate as a waiver or release of any of the terms, conditions or requirements of the
2000 Intergovernmental Agreement or otherwise act as a waiver or release of any demands,
claims, actions or proceedings arising out of a violation or breach of the 2000 Intergovernmental
Agreement, whether such breach concerns transfer or possession of real or personal property, or
any other claim or action.
8. TERMINATION.
A. TERMINATION by Mutual Consent: This Agreement may be terminated
at any time by mutual consent of both parties.
B. TERMINATION for Convenience: After the first twelve (12) months of
the term hereof, this Agreement may be terminated at any time by either party upon at
least 90 days' notice in writing and delivered by certified mail or in person.
C. TERMINATION for Default or Breach: Either County or City may
terminate this contract in the event of a breach of the contract by the other. Prior to such
termination the party seeking termination shall give to the other party written notice of the
breach and intent to terminate. If the party committing the breach has not entirely cured
the breach within fifteen (15) days of the date of the notice, or within such other period
beyond fifteen (15) days as the party giving the notice may authorize or require, then the
contract may be terminated at any time thereafter by a written notice of termination by the
party giving notice. The rights and remedies of the parties provided in this subsection are
not exclusive and are in addition to any other rights and remedies provided by law or
under this contract.
D. OBLIGA TION/LIABILITY OF PARTIES: Termination or modification
of this contract pursuant to subsections A, B, and C, above, shall be without prejudice to
any obligations or liabilities of either party already accrued prior to such termination or
modification. However, upon receiving a notice of termination (regardless whether such
notice is given pursuant to subsections A, B, C, or D, of this section) County shall
immediately cease all activities under this contract, unless expressly directed otherwise by
City in the notice of termination. Further, upon termination, County shall deliver to City
all contract documents, information, works-in-progress and other property that are or
would be deliverables had the contract been completed. City shall pay County for work
performed prior to the termination date if such work was performed in accordance with
the Contract.
Intergovernmental Agreement
Library Services - City of Ashland and Jackson County
Page 3 of7
E. NON-APPROPRIATION: Notwithstanding the termination provisions
above, termination may occur for non-appropriation. Specifically, all City obligations to
expend money under this Intergovernmental Agreement are contingent upon future
appropriation as part of the City budget process and local budget law, and the failure of the
Council and Budget Committee to make the appropriation shall necessarily result in
termination of the Agreement. As such, in the event insufficient funds are appropriated for
the payments under this Agreement and the City has no other lawfully available funds,
then the City may terminate this Agreement at the end of its current fiscal year, with no
further liability or penalty to the City. The City shall deliver written notice to County of
such termination no later than thirty (30) days from the determination by the City of the
event of non-appropriation.
9. HOLD HARMLESS. The City of AsWand is not providing services but purchasing
services through Jackson County's contractor. Accordingly, to the extent permitted by Article
11, Section 7, and Article 11, Section 10 of the Oregon Constitution and the Oregon Tort Claims
Act, The parties both shall hold each other harmless, defend and indemnifY the other from any
and all claims, demands, damages or injuries, liability of damage, including injury resulting in
death or damage to property, that anyone may have or assert by reason of any error, act or
omission of the other, its officers, employees, agents and contractors pursuant to this Agreement
or the Amendment contemplated herein. Such indemnification shall also cover claims brought
against either party under state or federal employees' compensation laws. Provided however,
Jackson County shall not be held responsible for any claims, actions, costs, judgments or other
damages, directly and proximately caused by the criminal or wanton acts of the City of AsWand
employees or the negligence of the City of AsWand. Similarly, the City of Ashland shall not be
held responsible for any claims, actions, costs, judgments or other damages, directly and
proximately caused by the criminal or wanton acts of the Jackson County employees or the
negligence of Jackson County. If any aspect of this indemnity shall be found to be illegal or
invalid for any reason whatsoever, such illegality or invalidity shall not affect the validity of the
remainder of this indemnification.
10. MONITORING I REVIEW OF ENHANCED SERVICES. The Amendment
shall provide for the right of the City to monitor and review the provision of enhanced services
provided pursuant to this Agreement. County shall copy City, upon request by and at the
expense of the City, with any regular reports on services and outcomes, or other ad hoc
investigations that fairly include or touch on the provision of enhanced services paid for by the
City of Ashland. Unless authorized in writing by the County Administrator, City shall not
directly interact with Contractor or interfere with the operations of the County's contractor but
shall bring all complaints and or issues regarding the provision of enhanced services to the
County Administrator's attention. The County Administrator or his designee shall promptly
respond to reasonable inquiries and requests for information regarding compliance and service
issues received in writing from the City Administrator. As a result of such monitoring and
review, needed changes, including but not limited to enhancements, modifications, (e.g. hours
and days of operation), or other alterations, shall be addressed by mutual agreement by the
Administrators of the County and City, with modifications to documents as necessary.
Intergovernmental Agreement
Library Services - City of Ashland and Jackson County
Page 4 of?
II. METHOD AND PLACE OF GIVING NOTICE, SUBMITTING BILLS,
AND MAKING PAYMENTS. All notices, bills, and payments shall be made in writing and
may be given by personal delivery or by mail. Notices, bills, and payments sent by mail should
be addressed as follows:
City of Ashland
Attn: Martha Bennett
20 East Main Street
Ashland, Oregon 97520
Phone: 541-488-6002
Jackson County
Attn: Danny Jordan
10 South Oakdale, Rm. 214
Medford, Oregon 97501
Phone: 541-774-6003
and when so addressed, shall be deemed given upon deposit in the United States Mail, postage
prepaid. In all other instances, notices, bills, and payments shall be deemed given at the time of
actual delivery. Changes may be made to the names and addresses of the person to who notices,
bills, and payments are to be given by providing notice pursuant to this paragraph.
12. MERGER. This writing is intended. both as the final expression of the
Agreement between the parties with respect to the included terms and as a complete and
exclusive statement of the terms of the Agreement. No modification of this Agreement shall be
effective unless and until it is made in writing and signed by both parties.
IN WITNESS WHEREOF, the parties hereto have caused this instrument to be executed
in two (2) duplicate originals, either as individuals, or by their officers, thereunto duly
authorized.
Dated this _ day of
,2007.
City of Ashland, Oregon
Jackson County, Oregon
By:
John Morrison, Mayor
City of Ashland
By:
Danny Jordan, County Administrator
Jackson County
Approved as to Form:
Approved as to Form:
Senior Assistant County Counsel
Intergovernmental Agreement
Library Services - City of Ashland and Jackson County
Page 5 of7
Exhibit A
Intergovernmental Agreement for Library Services
between Jackson County and the City of Ashland, Oregon
Scope of "Enhanced Services" :
Jackson County shall amend the Professional Services Agreement Between Jackson County and
Library Systems & Services, LLC. to provide the following additional services. alkJa/
"Enhanced Services" at the specified rates and charges to the City of Ashland Branch of the
Jackson County Library:
. Full compliment of Jackson County Library services, as set forth in the Professional
Services Agreement Between Jackson County and Library Systems & Services, LLC.
providing for an additional 16 hours per week at the Ashland Branch, inclusive of all
normal operations and staffing required for a total of 40 hours per week. (SEE NEW
HOURS TABLE BELOW)
. Three (3) additional full time employees (FTE) or the equivalent at the Branch location.
Staffing preference includes two (2) FTE or the equivalent to cover the 16 additional
hours of operation as well as an additional FTE or the equivalent for Library outreach
activities.
. NEW HOURS TABLE:
MONDAY TUESDAY WEDNESDAY THURSDAY FRIDAY SATURDAY SUNDAY
BASE 12-8 12-4 2-6 12-4 CLOSED 12-4 CLOSED
ADDED 10-12 10-12,4-6 10-2 4-5 CLOSED 4-5 12-4
NEW 10-8 10-6 10-6 12-5 CLOSED 12-5 12-4
The City of Ashland shall pay Jackson County $20,000/month from November 2007, through
June 2008, for the 16 additional hours of full library service at the Ashland Branch [inclusive of
(2) FTEs or equivalent] not to exceed $160,000; and $20,600/month from July 2008, through
June 2009, not to exceed $247,200. If an extension to this Agreement is granted for an additional
year, the cost shall be increased by 3%.
The City of Ashland shall also pay $7,083 per month from November 2007, through June 2008,
not to exceed $56,664; and $7,295.49/month from July 2008, to June 2009, not to exceed
$87,545.88 for the outreach activities [inclusive of I FTE or equivalent]. If an extension to this
Agreement is granted for an additional year, the cost shall be increased by 3%.
Scope of Additional contractual provisions:
Jackson County shall amend the Professional Services Agreement Between Jackson County and
Library Systems & Services, LLC. to provide for the following additional contractual
provisions as they related to the provision of additional services to the City of Ashland Branch
of the Jackson County Library:
Intergovernmental Agreement
Library Services - City of Ashland and Jackson County Page 6 of7
Duration: Notwithstanding the duration of the Operation Agreement in Section 3.0, the
Amendment shall not obligate the parties to provide the additional services set forth herein
beyond the June 30, 2009 termination date for additional services. The Amendment may
provide for an administrative extension of the Agreement amendment for up to 12 months, upon
execution of an extension to this Intergovernmental Agreement. If an extension to this
Agreement is granted for an additional year, the cost shall be increased by 3%.
Living Wage: The County will require that LSSI shall be subject to the City of Ashland "Living
Wage" ordinance with respect to any employee providing services at the Ashland Branch Library.
City has been assured that LSSI already complies with this provision requiring at least $12.43 per
hour for employees working more than 1040 hours per year. Accordingly the County need not
continuously monitor compliance but shall provide documentation to the City of Ashland for
purposes of monitoring compliance upon written request of the City Administrator. If it is found
that an LSSI employee performing services at the Ashland Branch Library is paid in violation of
the provisions of the City of Ashland living wage law, LSSI shall be given an opportunity to cure
prior to any enforcement action.
Privacy: The Amendment shall restate and reaffirm the cornmitment Jackson County to strictly
maintain the confidentiality of Library patron records as established under Oregon public records
law.
Meeting Rooms: The Amendment shall restate and reaffirm that public meeting rooms shall be
open and available for public in accordance with the Library's Policy covering use of community
meeting rooms, and City and County policies on nondiscrimination.
Coordination: The Amendment shall include a requirement that the Ashland Branch Manager
attend Ashland Citizen Library Ad Hoc Committee meetings at least quarterly, preferably
monthly to maintain coordination with the City of Ashland and the local community on the
specific needs of the City and community.
Intergovernmental Agreement
Library Services - City of Ashland and Jackson County
Page 7 of?
1000
FRIENDS
OF OREGON
534 SW Third Avenue, Suite 300, Portland, OR 97204. (503) 497-1000. fax (503) 223-0073 . www.friends.org
Southern Oregon Office. P.O. Box 2442. Grants Pass, OR 97528. (541) 474-1155' fax (541) 474.9389
Willamette Valley Office' 189 Liberty Street NE, Suite 307A' Salem, OR 97301 . (503) 371-7261 . fax (503) 371-7596
Central Oregon Office' P.O. Box 1380. Bend, OR 97709' (541) 382-7557' fax (541) 317-9129
October 10, 2007
Greater Bear Creek Regional Problem Solving Policy Committee
c/o Rogue Yalley Council of Governments
Post Office Box 3275
Central Point, OR 97502
SUBJECT: Bear Creek Vallev Ree:ional Problem Solvinl! Process
Dear Members of the Policy Committee:
On behalf of 1000 Friends of Oregon, I would like to thank you for this opportunity to once
again address you regarding the Bear Creek Yalley Regional Problem Solving project, and
specifically to comment on the September 12,2007 "Regional Problem Solving Draft Plan."
Please accept this letter into the record of the October 10,2007 public hearing.
I. 1000 Friends ofOree:on SUPpOrts Ree:ional Problem Solvinl! in tbe ROI!ue Vallev
1000 Friends of Oregon congratulates the Rogue Yalley Council of Governments (RYCOG) and
all of the participating jurisdictions on the progress made to date in the effort to coordinate
regionally on growth management and protection of our area's valuable agriculture industry.
The Bear Creek Yalley is an important region of Oregon for many reasons, and we believe that
the RPS process presents the region with a unique and valuable opportunity to direct its
development in the future.
The September 12 "Regional Problem Solving Draft Plan"t identifies the three "problems" being
addressed in this process as:
I. The lack of a mechanism for coordinated regional growth planning;
2. The loss of valuable farm and forest land caused by urban expansion; and
3. The loss of community identity.2
The "Project Goals" associated with solving these problems are identified as:
I. Manage future regional growth for the greater public good;
I Hereinafter referred to as the "Draft Plan."
2 Draft Plan, p. 1-7.
RPS Policy Committee
October 10, 2007
Page 2 of 24
2. Conserve resource and open space lands for their important economic, cultural, and
livability benefits; and
3. Recognize and emphasize the individual identity, unique features, and relative
competitive advantages and disadvantages of each community within the Region.3
Because we fully support these project goals, 1000 Friends of Oregon has taken an active interest
in the creation of a regional plan that will be both approvable when delivered to the state for
review, and practical when it comes to the implementation phase. We continue to believe that it
is possible to create such a plan.
With these outcomes in mind, I have attended nearly every meeting of the Policy Committee and
the Technical Advisory Committee (T AC) held since November 2002, most of the meetings of
the Resource Lands Review Committee (RLRC) and the only meeting of the Citizen
Involvement Committee (PCIC) held during that time. I have submitted several rounds of written
comments4 and was a frequent participant in discussions at both the T AC and the Policy
Committee meetings until the Policy Committee voted to preclude public comment on specific
growth areas at their meetings.
The comments that follow are based on our continued participation in the RPS process and on
the most recently available information-some of which has only become available since the
Draft Report was issued.
After a procedural issue, we turn to the content of the Draft Plan itself.
IT Sendinl! the Draft Plan to the Land Conservation and Development Commission is
Premature Because Reeional Consensus Has Not Been Reached
The "Timeline for RPS Regional Plan Approval and Implementation"S shows that the project
intends to submit the Draft Plan to the Land Conservation and Development Commission
(LCDC) "for review" at its November 28-30 meeting. However, LCDC is precluded by state law
from taking any action on the Draft Plan. Submitting it at this time would be a procedural
mistake. We are concerned that this will result in unnecessary delay and costs to the
jurisdictions.
State law prohibits LCDC from taking any action on the plan at this time. Under the Regional
Problem Solving (RPS) statute,6 LCDC may only review the amended or new comprehensive
pans and regulations that arise out of a completed process that complies with the RPS statute.
3 Draft Plan, pp. 1-9 - 1-10.
'Letter from Greg Holmes to Michael Cavallero, RVCOG, May 5, 2003; Memo from Greg Holmes to the RPS
T AC, August 18,2004; Written Comments submitted by Greg Holmes to the RPS Policy Committee, September 15,
2006.
, http://www.rvcog.org/rpsydf/Plan_Sequence_March_LCDC.pdf
60RS 197.652 to 658.
RPS Policy Comminee
October 10. 2007
Page 3 of 24
(ORSI97.656(2)(a) requires, in part, that LCDC may only approve plan and regulation
amendments that deviate in any way from the rules of the commission that implement the
statewide planning goals they are:
".based upon agreements reached by all local participants, the commission, and other
participating state agencies, in the collaborative regional problem-solving process.
This plan seeks to deviate from state rules, and is thus subject to this requirement.
The voting members of the Policy Committee have apparently signed off on the Draft Plan.
However, it is far from clear that "all local participants," defined as the cities, the County, and
special districts/ have agreed to the Draft Plan. None of the jurisdictions has reported back from
their councils/commissions.
What is clear is that the "participating state agencies" have not agreed to the Draft Plan, as stated
in the April 4, 2007 letter from the Agencies to the Policy Committee.8 The Draft Plan has not
addressed the concerns expressed by the state agencies, and as of this writing the they have not
revised their position. Submitting the plan now is likely to result in additional and unnecessary
costs and delays.
Finally, there was extensive discussion at the Policy Committee meeting of October 9,2007,
about whether or not this Draft Plan and the related Regional Problem Solving Agreement would
ultimately be the mechanism used by the region to establish urban reserve areas. Until questions
of this magnitude are answered and the RPS process is completed, it is premature to submit
anything to LCDC.
It is our hope that, whatever form it takes, the project can reach agreement on a plan that best
serves the region.
III. 1000 Friends ofOrll2on Supoorts the Rll2ion's Efforts at Rll2ional Planninl! But We
Cannot Support the Current "Draft Plan"
Although we strongly support using coordinated regional planning as a means of accomplishing
the project's goals, we cannot support the current Draft Plan. As will be discussed in more detail
below, the September 12 Draft Plan contains numerous technical, legal, and logical
inconsistencies that have led to erroneous conclusions. At least some of these weaknesses result
from flaws in the process used to generate this draft. Taken together, this has resulted in a
7 The draft "Greater Bear Creek Valley Regional Problem Solving Agreement" dated October 5, 2007, lists the local
districts that must sign off on this plan as the Metropolitan Planning Organization (MPO), the Medford Water
Commission, and the Rogue Valley Sewer Services.
8 Leiter from John Renz (DLCD), Darcy Strahan (OHCD), Terry Harbour (ODOT), John Becker (DEQ), Larry
Holzgang (OECDD) and Jim Johnson (ODA), to the Greater Bear Creek Valley Regional Problem Solving Policy
Committee, "The State of Oregon's Comments and Position on the findings in support of urbanization of
commercial farm land and other matters," April 4, 2007.
RPS Policy Committee
October 10. 2007
Page 4 of 24
significant overstatement of both the amount ofland needed by the region to accommodate a
doubling of population and in the amount of resource land needed for the same purpose.
A. Introduction: On Its Face tbe Draft Plan Fails to Resolve tbe Original Problems tbe
Project Set Out to Address
The Draft Plan states that "Effective regional planning cannot be the sum of the planning parts.,,9
We agree.
What became the RPS process began with the Our Region initiative in the 1 990s. In that
initiative, concerned residents sought to protect the region's critical agricultural economy by
identifying the most valuable farmland left in the valley. It was only then that they began talking
about how to grow the cities in a way that would preserve those farmlands. Unfortunately, the
Draft Plan is the result of a process that took a different approach and fails to achieve the original
intended result.
According to the Draft Report, the current plan includes about 9,200 acres of proposed Urban
Reserve Areas.lo Of this total:
. About 7,] 25, or approximately 77 percent, are currently zoned Exclusive Farm Use or
other resource designation.
· About 1,640, or approximately 18 percent, were determined by the RLRC to be critical to
"the region's commercial agricultural" base ofland.
During the RPS process, each city worked independently to determine the urban reserve areas it
felt would bet meet its own needs. I I The leftover agricultural lands were assumed to be both
available and sufficient for the continued viability of the region's commercial agriculture.
Because no regional analysis has been conducted, there is no factual basis for this assumption in
the record. The process and the outcome are contrary to the RPS problem statement and goals
and the RPS statute.
Given the sheer magnitude of commercial agriculture acres at risk, and the options that are
available, it is difficult to conceive of the argument that would lead one to conclude that the draft
plan, as currently written, achieves the project goal to "Conserve resource and open space lands
for their important economic, cultural and livability benefits."
9 Draft Plan, p. 1-7.
10 Draft Plan, p. 1-14 lists a total of9,473. This figure does not include about ],877 acres of parkland already owned
by the City of Medford. We do not object to the Medford parks being included so long as they are designated for
park use only. Consistent with the treatment in Chapter 5, and with the Land Needs Calculator in the appendix of the
Draft Plan, we have also subtracted 266 acres ofland that is part ofPH-3. Although we disagree with the premise
that no improvements in density can be made in PH-3, we also do not object to the conditions under which this areas
is presently included. These lands will not be considered in any calculations presented in this testimony.
II The process each city undertook is described a pp. 2-3 - 2-7 of the Draft Plan.
RPS Policy Committee
October J 0, 2007
Page 5 of 24
As will be described in more detail below, the proposed urban reserve areas might do an
adequate job of perpetuating the land use patterns currently on the ground in the region, but that
was exactly what the RPS process was supposed to stop. The land needs are overstated to the
point that the Draft Plan also fails to meet the Project Goal of managing future growth for the
greater public good,
In addition to failing to meet the project's own goals, the current Draft Plan also violates
provisions ofORS 197.656(6) and of numerous Statewide Planning Goals, as will be discussed
below,
B. Issue 1: Significant Parts of the Draft Plan are Based on Erroneous Legal
Interpretations
The extent to which the project is hoping to modify or not comply with the Urban Reserve Rule
(OAR 660-021-0000 to 0100), and the statutory interpretations justifying the project's approach
and outcome, have only become apparent since the Draft Plan was made available for review.
The Draft Plan bases parts of its analyses and several of its conclusions on interpretations of the
RPS Statute (ORS 197.652 to 658) which we believe to be erroneous. Among those:
I. The Draft Report notes that ORS I 97.656(2)(c) allows LCDC to approve amendments to
comprehensive land use plans and regulations that do not fully comply with administrative
rules if they". ..conform, on the whole, with the purpose of the statewide planning goals."
From this, the Draft Plan jumps to the conclusion that, "Because the Goals are OARs" the
project can "make findings based on the Goals' purpose statements and not their full texts.,,]2
Two pages later the Draft Plan asserts that "the RPS statute directs the process to address [the
Goals] on the "purpose" level.',]3
This is a strained reading of the RPS statute. The statewide planning Goals do not contain a
section identified as the "Purpose Statement"; the purpose is to be derived from the entire
Goal; and any actual attempt to measure compliance of a plan or regulation amendment with
the purpose of a Goal by looking at only one sentence of a Goal simply does not hold up.
2, The Urban Reserve Rule implements a statute, ORS 195.145, not a Goal. The hierarchy in
the Urban Reserve Rule cannot be altered in its application. Even if a stretched reading of
the Urban Reserve Rule and RPS statute allowed this, there is no evidence that altering the
hierarchy, resulting in urbanization of the region's commercial agricultural lands, meets the
purpose of Goals 3, 12, and 14 or the requirements of the RPS statute. In fact, urbanization
of these lands would be contrary to the Goals themselves and would thus require exceptions.
3, The Draft Report asserts that the RPS statute's "differentiation between resource lands that
are and are not recommended as part of the base" only requires the project to develop
12 Draft Plan, p, J -] 0,
13 Draft Plan, p, 1-] 2,
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October 10. 2007
Page 6 of 24
detailed findings for that land that is determined to be part of the base.14 This does not
comply with the RPS statute. The plan must meet all the requirements of the RPS statute
(see, e.g., ORS ] 97.656(2) and (6)) and take an exception(s).
C. Issue 2: Necessary Regional Analyses Have Not Been Conducted
Since "deliberations" concluded earlier this year, the project has adopted the concept of a
"regional community," with each city in the project representing the equivalent of a
"neighborhood"J5 within that community. This is a useful way oflooking at the project that
conforms with both the letter and the spirit of the RPS statute.
Unfortunately, this concept has not been used consistently. Some examples include the
following:
I. One of the "Policies" adopted by the project under Project Goal 3 t6 was that "The Region
will develop a strategy permitting an unequal distribution of certain land uses among its
jurisdictions." We believe this is an appropriate policy, and that it has resulted in some
creative and positive solutions-the South Valley Employment Center being among those.
This parallels how development would occur in the normal planning for a community-some
neighborhoods get some uses, others get other uses, as appropriate. But not every
neighborhood gets all uses.
A number of proposed urban reserve areas have been included in the Draft Plan that are, like
the South Valley Employment Center, intended for industrial use. The project's own
modeling shows there is a huge excess of industrial land in the proposal. 17 Adding more,
based on the justification that each "neighborhood" needs its own, violates the intent and
purpose of numerous Statewide Planning Goals, rules, and statutes and exacerbates the
excess.
Oversupplying industrial land is also problematic from a practical standpoint. Designating
land as an urban reserve represents a commitment that the local governments will insure the
infrastructure necessary to urbanize those lands will be provided when needed. Including
excess lands could result in draining local resources to provide unnecessary services, and
those lands will compete with lands already inside UGBs that are waiting for development.
That this extra land included in a proposal where 75 percent of the land is resource land and
17 percent is land that is critical to the region's agricultural economy only adds to the
violations.
14 Draft Plan, p. 1-14.
15 This concepl is described al p. 4-8 of the Draft Plan.
16 "Recognize and emphasize the individual identity, unique features, and relative competitive advantages and
disadvantages of each community within the Region."
17 This will be discussed in more detail below.
RPS Policy Committee
October 10, 2007
Page 7 of 24
It also violates the intent of the "neighborhood" concept. To be consistent with the concept of
a "regional community" made of up "regional neighborhoods," the region will need to
address the needs of the community from a regional perspective, and not only as the sum of
the neighborhood parts.
2. The above example relates to industrial land, but the same concept applies to the distribution
of population within the "community" and to the resulting locations of all land uses within
the "community." When a community establishes population estimates for planning, it is
done at the community level rather than by having each neighborhood propose how much it
would like to grow and adding up all the proposals.
The method used for distributing the expected population to individual jurisdictions was not
a regional exercise. Much like the process for selecting the urban reserve proposals in the
Draft Plan, each city (neighborhood) came to the group with an independently generated
proposal. When all of the individual proposals were added up, the total was near enough the
doubling ofthe region's population that the exercise was ended. This is a sum of the parts
approach that results in outcomes that may not benefit the overall community.
For example, the two cities (neighborhoods) wishing for the greatest population increases are
one with significant road connectivity issues (wanting to increase population by 173 percent)
and one that is completely surrounded by some of the best farmland remaining in the valley
(wanting to increase population by 131 percent).
It is incumbent on the community to at least ask the question: Does it really makes sense,
from a regional perspective, to direct such large population increases to these two areas? Is
there another way the community can help those neighborhoods achieve their goals?
The answer to the first question may have an impact on what urban reserve areas are finally
selected by the project. Unfortunately, the question has not been asked--{)r answered.
3. The answer to the above question becomes particularly relevant when the project attempts to
comply with ORS 197.656(2)(b )(B) or the requirement in OAR 660-021-0030(2) that
inclusion of resource land in an urban reserve be based on "a demonstration that there are no
reasonable alternatives that will require less, or have less effect upon, resource land."
Compliance with applicable law requires that this requirement be at the community
(regional) level and the neighborhood level. 18
The "alternatives analyses" provided in Chapter 5 of the Draft Plan are conducted
neighborhood by neighborhood. Thus far, the project has not conducted this type of analysis
18 This is one point at which the concept of the region as a single community is not entirely accurate. Some needs
that are specific to individual communities will be justified and alternatives considered at that level. However. thus
far that is the only level at which an alternatives analysis has been conducted and, as noted above, even some of
those analyses do not comply with state regulations.
RPS Policy Committee
October 10, 2007
Page 8 of 24
at the community (regional) leve!.'9 The provisions of both the RPS Statute and the Urban
Reserve Rule require that a regional alternatives analysis be conducted. Without such a
regional alternatives analysis, using the RPS process to justify regional "needs" (such as the
South Valley Employment Center) that would not otherwise be possible is a violation of
numerous provisions of state law.
The Policy Committee did develop and adopt objective criteria for evaluating, on a regional
basis, whether regional needs could be met in ways that would require less of the RLRC-
identified base farmland. However, these criteria were removed from the evaluation process
by the Policy Committee and were not replaced by any standard for review.
Thus far the project has not conducted an alternatives analysis at the regionalleve!. We hope
that when a regional analysis is conducted it will help the region find ways to support our
farms and farmers.
D. Issue 3: Overall Land Needs Are Over-Stated
The RPS process does not exist simply to provide a new mechanism for duplicating today's land
use patterns and problems in the future. The promise of the RPS process is that it provides a way
to get to a new kind offuture, and the problems and goals defined by this RPS process clearly
reflect this.
As noted above, and as is clearly described in Chapters 2 and 5 of the Draft Plan, selecting and
justifying the urban reserve areas was a neighborhood (local), rather than a regional process.
While the process of determining the regional "need" for the total land to be included in the
urban reserves was ostensibly a regional effort, it was based in large part on assumptions and
projections that were derived at the local level and added together with little or no regional
analysis.20
The step that was not taken was to ask if this collection of parts was adequate to serve the whole.
It also appears that some of the inputs that were developed regionally suffer from erroneous
assumptions or faulty conclusions.
19 Some of the city-specific alternatives analyses suffer from significant deficiencies as well. Several offer
justifications for avoiding non-resource lands by expressing the desire for large, flat parcels, or of spreading the
growth evenly around the city. These desires are not among the criteria to be addressed for compliance with Goal 14
and do not meet the project's problem statement or goals. At least one of the city-specific alternatives analyses also
fails to mention non-resource land that, ifJeft out, would result in the violation of the County's Comprehensive Plan.
20 Page 4-13 lists "Regional Selection Criteria" that were adopted by the Policy Committee at the outset of the
"deliberations" process. These criteria were initially adopted by the Policy Committee as a means of conducting a
regional analysis of each of the proposed urban reserve areas during the process. While it is true that some
jurisdictions did use them in preparing their proposed urban reserve area justifications, they were not systematically
used by the process beyond that. The minutes of the deliberations process will show that these criteria were only
applied to the first few urban reserve areas the Policy Committee considered during the "deliberations" process.
RPS Policy Committee
October 10, 2007
Page 9 of 24
For example:
. The Hispanic population is the fastest growing ethnic group in Oregon's population, The
study area is seeing a similar trend, As demonstrated by the RPS project's consultant,
Hispanic residents tend to have larger household sizes (and more multi-generational homes)
than other segments of the population,21
The fastest growing age segments of the population for the study area are projected to be
those over 65, followed by those 45-64,2 Most of the people in these age groups will not live
through the planning horizon, In the interim, as this group ages, they will seek out housing
opportunities that involve less maintenance (i,e" smaller dwelling units with little or no yard)
that are in neighborhoods that provide or are closer to the services they need, and that include
transportation options that don't rely solely on the automobile,
Both trends will provide a significant push in the market toward higher density
neighborhoods (in the first case more people per household, and thus per acre, and in the
second case more units per acre), This conclusion was not reached or incorporated into the
inputs into the land needs calculations,
· The project's Economic Opportunities Analysis concluded there will be a need for people to
work in the jobs that provide the services that an aging population needs-and a related need
for housing that those workers can afford, Among the most obvious ways to reduce the costs
of new housing are to build more dwelling units per acre, and to build them in neighborhoods
that will support non-automobile dependent transportation options, This conclusion is not
reflected in the land needs calculations,
· Providing the infrastructure to support new development is becoming increasingly expensive,
In this valley, those costs are largely borne by taxpayers, As budgets get tighter,
municipalities already face the choice of charging developers the true and full costs or of
increasing the efficiency with which existing and new facilities are used by development
This means fewer miles of roads, sewers, water lines, etc. Policies for minimizing such costs
are not included in the Draft Plan or reflected in the models,
· As the DEQ, the Medford Water Commission, and the Rogue Valley Sewer Services have
indicated on the record, increasing population will place additional burdens on the quality of
life in the region, Development patterns that work to reduce reliance on the automobile,
reduce per capita water consumption, and reduce the amount of impermeable surfaces
channeling stormwater runoff will temper these effects, The results of transportation
modeling conducted thus far, which support this conclusion, are not reflected in the land
needs analyses in the plan,
Every one of these trends and realities is an argument in favor of being aggressive in
implementing the project's policy of increasing the region's urban housing density, This is not a
hypothetical argument Demand for housing that meets the needs outlined above is already
increasing in national and state markets, and is emerging in parts of the valley as well,
21 See the Housing Needs Analysis conducted by ECO, Final Report, July 2006, pp. 3-4 to 3-5.
22 Ibid, p. 3-7.
RPS Policy Committee
October 10. 2007
Page 100f24
Similar points can be made for employment lands necessary to meet future needs.
Specific weaknesses in the regional land needs calculations, and the impacts those deficiencies
have on the amount of land needed to meet the Project Goals while complying with local and
state regulations, are set forth below.
1. Residential Land Needs
As one means of meeting the established Project Goals, the Policy Committee adopted a policy
to increase the region's overall urban housing density. Meeting state and federally mandated
transportation and air quality standards and addressing environmental concerns will require
increasing densities. The cost to taxpayers of providing services, as well as market forces that are
already being felt, will also dictate higher densities.
To address the policy of increasing residential density, the project established a region-wide
average target density of 6.20 units per acre as the region builds out the urban reserves. The
Draft Plan asserts that this is an "ambitious" goal that represents a 14 percent increase over the
current average density of 5.45 units per acre. Given the project's goals and other factors listed
above, and the amount of critical agricultural land that is included in the urban reserve areas to
accommodate residential growth, this goal should be increased.
a. The goal of6.2 units per acre would result in an average lot size of 7,000 square feet. If the
current trends reported in the Draft Plan23 were to continue, even without the RPS plan the
region will be more dense than the 6.2 units per acre target within 25 years. An end-result
density of 6.2 units per acre would actually result in lower densities than.market forces
suggest might be expected with no additional policy changes.
b. If residential buildout follows the pattern in the Draft Plan, the resulting overall density of the
region (what is on the ground now plus what is built to accommodate the new population)
wi II be about 5.9 units per acre. That is less than the current density in the city of Phoenix,
which project documentation shows to be 6.0 units per acre.
c. The project ran a second set of calculations called the "Low Land Needs Scenario." By
changing certain assumptions in the model (including the target density, which was set at
7.02 units per acre), the need for residential land to be included in urban reserves dropped by
about 1,200 acres.24 Making this one change alone could reduce the amount of critical
agricultural land in the urban reserves proposal by hundreds of acres. The project has
dismissed that calculation as "aspirational." We think this target helps to better address the
stated problems and meet the project's goals.
23 See p. 3-2: "During the same time [1994-2004], the percentage oflots smaller than 7,000 square feet increased
from 29 to 35 percent."
24 Based on the figures presented in Exhibit 3-2, p. 3-6 of the Draft Plan. The low land need total 00,007 is about
1,200 lower than the high land need total of 4,272.
RPS Policy Committee
October 10, 2007
Page II of24
Much more aggressive targets are already being implemented in other parts of the state. For
example, while Marion County is different from Jackson County in some respects, there are
also great similarities. Both face population growth pressure and both contain numerous
communities that are surrounded by economically valuable resource lands and that are trying
to protect their individual identities.
For the planning horizon to 2050, Marion County has adopted the "Marion County Urban
Growth Management Framework.,,25 Their targets are not based on an overall average, but
on community size. If the density targets in that framework were adopted in the Bear Creek
Valley, the result would be a goal of6 units per gross acre in Jacksonville and Phoenix
(which already meets this target), 7 units per gross acre in Eagle Point and Talent, and 8 units
per gross acre in Ashland, Central Point, and Medford.
For comparison, if these goals were met the average built density in the urban reserve areas
would be 7.78 dwelling units per acre. This result would help the region's overall livability,
keep infrastructure costs to taxpayers down, and help meet the project's goal of protecting
farmland and the agricultural economy.
d. There are local examples already being built that exceed both the Marion County goals and
the moderate targets established by the project. As an example, the Twin Creeks
development in Central Point includes] ,500 dwelling units on 230 acres.26
o That represents a density of 6.52 dwelling units per acre, but
o Because 4] of those acres are parks and open space (which the region's land needs
calculations count in a separate category), the total being developed is only 189 acres,
which results in a density of 7.94 dwelling units per acre.
o This acreage comes with a bonus of 200,000 square feet of commercial and office space,
which will not require additional land zoned for those uses.
If that development were to be built out at the project's "ambitious" target of6.2 units per
acre, the result would be fewer homes with no parks or open space and no commercial or
office space.
Even with these densities, Twin Creeks is being built with a mix of dwelling types (multi and
single family), and a variety of lot sizes as large as 10,000 square feet (just shy of 1. acre). It
is also worth noting that there is already a significant local demand for this type of
development--even in an otherwise depressed real estate market homes in this development
are selling as fast as they can be built.
25 This document was attached to our May 5,2003 letter to the Executive Director of the RVCOG and copied to all
jurisdictions involved in this project.
26 See http://www.tndwest.com/twincreeks.html
RPS Policy Committee
October 10, 2007
Page 12 of24
e. In addition to under-reaching on the goals, numerous assumptions used in the model result in
over-stating the amount of land needed to accommodate residential expansion. For example:
o The land calculations assume vacancy rates of 5 percent for single family dwellings and 7
percent for multifamily dwellings. Census records show that in 2000 the actual rates in
Medford were).8 percent and 4.9 percent, respectively. The OLCO handbook, "Planning
for Residential Growth," suggests 2 percent and 5 percent, respectively.27 The rates used
by the project inflate residential land needs.
o The calculations also assumed that only 12 percent of future housing needs would be met
by infill or redevelopment in existing neighborhoods. Projects like "The Commons," in
Medford, are already adding large numbers of residences in existing developed areas.
There is no evidentiary evidence that this is realistic as the project did not generate
specific figures regarding current rates of infill and redevelopment. What is known is that
the 12 percent figure is low compared to other regions of the state. For example, plans
currently in effect in Salem assume 15 percent, McMinnville assumes 25 percent, and the
Portland Metro area assumes over 28 percent. This is a policy area where cities could
easily influence development patterns. This is already happening in communities that are
creating ordinances and fee structures that encourage infill and redevelopment. Changing
infill assumptions and policies would have a large impact on the amount ofland needed
for urban reserves.
Conclusion: )fthe Twin Creeks example were followed, the resulting need for new residential
lands in urban reserves would be about 2,300 acres--{)r 1,700 acres less than is currently in the
Draft Plan. That total is slightly more than the sum total of all of the urban reserve lands the
RLRC has determined to be critical to the region's agricultural economy.28 Even if only a
portion of future development were to meet this target, the result would reduce the need for
parkland and commercial land, since some of each are included in the same residential acreage.
Making a few reasonable and achievable changes in the assumptions regarding how future
development will occur will both reduce the pressure on lands critical to the agricultural
economy and help the project to meet its stated goals. Indeed, if the project made no other
changes other than to adopt its own "Low Land Need Scenario," the result would show that the
proposed urban reserve areas include an excess of approximately 800 acres of residential land
over the justified need.29 Given the project's goals of using land more efficiently and preserving
agricultural land that is critical to the region's economy, it is difficult to understand why the
project would not adopt this target.
27 htto:/lwww.lcd.state.or.us/LCD/docs!publicatiolls!olanning for residelltial e:rowth.odf pp. 30-3]
28 Calculation made by changing the assumed du/acre figure and leaving all other assumptions in the project's land
needs calculations unchanged.
29 Draft Plan, p. 3-5. The Draft Plan indicates a total residential acreage of about 4,000 acres in all urban reserve
areas, and a low land need calculation of about 3,200 acres.
RPS Policy Committee
October 10. 2007
Page 13 of 24
2. Commercial and Industrial Land Needs
The needs analysis for employment lands similarly overstates needs for employment lands.
a. Approximately 1,500 acres of urban reserve lands that have been proposed by individual
jurisdictions as industrial land. This is about 16 percent of the total proposed urban reserve
area. The Tolo and South Valley Employment Center areas account for about 850 of these
acres, but the rest are scattered in several of the other cities. Indeed, every city except
Ashland has proposed including some land for industrial use.
The models used to calculate the amount ofland needed in the region to accommodate
industrial and commercial uses consistently showed that every industrial job that will be
added during the study period can be accommodated on the lands currently zoned for
industrial use within existing UGBs. Therefore, on a regional basis, all lands proposed for
industrial use are in excess of what is needed.
b. At the same time the model consistently showed that, even with the lands proposed in the
urban reserve areas, there would be a deficit of land available for commercial uses. This
deficit could be reduced somewhat by modifying regulations to provide parking for average
rather than peak use, incorporating transit facilities, providing incentives for multi-use
developments, and other strategies. Without further study it is impossible to determine what
affect pursuit of these strategies might have, but the project modeling done so far shows a
deficit.
c. To avoid having to force changes to jurisdiction-specific proposals, the project's solution to
the surplus/deficit problem was to simply combine both industrial and commercial lands into
one category called "employment lands" and call the result close enough. This violates Goal
9 and the Goal 9 rule, which requires both adequate and appropriate supplies of both
industrial and commercial lands.
d. Over-supplying industrial lands and under-supplying commercial lands will not average out
on the ground. Not all sites that are appropriate for one use will be appropriate for the other.
The predictable result of this situation will be that at the end of the planning horizon there
will still be a glut of industrial land in the region, some of the land that was justified in this
plan as needed for industrial uses will have been converted to commercial uses, and some
jurisdictions will have found it necessary find land outside of their urban reserves to add to
their UGBs.
We also understand that not all industrial land is created equaL Location, proximity to
facilities, and planned uses all make some sites more suitable than others. If the region has a
glut of the wrong kind of industrial land in the wrong places, the response is not to simply
add more, but to convert the excess to other uses or, if no other uses are appropriate, to
remove them from the UGB. Both of these options have been exercised in Oregon.
RPS Policy Committee
October 10, 2007
Page 14 of24
The region must plan for the amount of industrial land that will actually be needed. If the
economy is changing and supply needs to be shifted around, that can be justified. If the
amount of land cannot be justified, then the proposals need to be scaled back.
Likewise, an adequate supply of commercial land should be planned in places where
commercial activities are appropriate. It makes more sense to plan for realistic growth in both
sectors now than adopt a plan that will cause individual jurisdictions and businesses
problems later.
e. Some of the assumptions in the models also result in over-stating the land needed for
employment purposes. Among them:
o The model does not account for the impact that the expanding agricultural and timber
industries30 will have on the region and does not account for new jobs in those sectors
that will be held by residents of the region. A large percentage of those jobs will be
outside of the urban growth boundaries and urban reserves.
o The model does not account for employment that will be absorbed in mixed-use
development within the urban reserve areas-requiring no additional commercial,
office, or industrial lands. 3t
o The model assumes only IS percent32 of new jobs will be accommodated without
additional commercial or industrial lands. This goal is very low in comparison to
other jurisdictions. For example, Salem assumes 30 percent. Metro assumes 40
percent. The Bear Creek Valley is not either of these two places, but it can certainly
achieve more than 15 percent. Doing so will help preserve the lands that support local
jobs in the agriculture industry.
o The model includes assumptions for number of employees per acre for industrial (9 to
II), commercial (16 to 18), and government employees (7-9). In addition to these
assumptions be unrealistically low, the model is completely missing another category:
office employees. The city of McMinnville uses densities of II for industrial, 22 for
commercial, 22 for office and 35 for public. Projects like The Commons in Medford
will significantly out-perform even these numbers. The RPS model dramatically
inflates the land need as compared to these figures.
o The model assumes a "net to gross" factor of 15 percent.33 Ten percent is a typical
factor used in other parts of Oregon.
30 Draft Plan, p. 3-8.
31 The same might be said of the housing needs model, which should set goals for residential units to be built in
conjunction with commercial facilities.
32 The model assumes 10 percent for its ""high land needs" scenario, 15 percent for the "medium", and 20 percent for
the ""low." The project is using the ""medium" model run as its "benchmark" justifying employment land needs.
33 The net to gross factor calculates how much developable land is left once public rights of way (streets) and other
public facilities are built. For example, a 10 acre lot that has a 15 percent net to gross ratio would have about 1.5
RPS Policy Committee
October 10, 2007
Page 15 of24
Conclusion: All the assumptions cited above inflate the projected land needs for the region,
Indeed, the Draft Plan states that, even with the inflated needs generated by the assumptions
above, if the cities simply meet the targets in the project's "]ow land needs" model they could
shave 600 acres off of the total needed.34 Changing some of the assumptions above would reduce
the total acres needed by many hundred more.
3. Parks and Institutional Land Needs
The Draft Plan does not appear to include specific acreage estimates for the total park and
institutional lands included in the proposal, or a description of how those estimates were
derived.35 Instead, it is necessary to go to the "Land Need Calculations and Population
Allocation" model generated by the project consultants.
We have no objection to the inclusion of Medford's Crissy and Prescott parks in the urban
reserve areas. However, the remaining need for parks and institutional lands is overstated.
For example, while we applaud the thought, Medford has included severa] hundred acres of
parkland in MD-5 in the southeast comer of the city. This area is very close to both Crissy and
Prescott parks-which total nearly 1,900 acres. The proximity of those parks, combined with
multi-use development patterns that will create additional open space in lands included in the
residential lands wi II reduce the need for these additional parks. Other urban reserve areas
similarly overstate the need for park and institutional lands.
A similar problem exists with the amount of land being proposed for schools. At page 3-] 3 the
Draft Plan states that High Schools need up to 50 acres of land. While the details of specific
acreages are not provided in any of the calculations showing land needs, most of the cities have
included lands for schools in their proposals. The assumptions for the amount of land needed for
schools should be reviewed, as current professional guidelines do not support the designation of
50 acres for a high school. 36
Jurisdictions can also be more aggressive about combining uses-thus saving both money and
land. Combining school and park facilities is an obvious example. While the goal of providing
"buffers" between the cities is also laudable, the aspiration to stay off of these lands does not
override the lega] hierarchy oflands to be included in urban reserves. Including some of the
"buffer" lands in the urban reserves for parkland both preserves the buffer between cities and, in
some cases, will reduce pressure for including lands that have been determined to be critical to
the region's agricultural economy.
acres of roads or other facilities, leaving about 8.5 acres for development. The model uses a range of between 10
percent for the low, 15 percent for the medium, and 20 percent for the high land needs calculations.
l4 Draft Plan, p. 3-12. The Draft Plan lists the Current industrial and commercial lands within the proposed urban
reserves total about 5,900 acres. The low land needs figure is given as 5,300 acres.
3S One could glean the total number of acres and some of the justifications by searching each city's justifications in
Chapter 5, but there is no discussion similar to residential or employment lands in this draft.
36 See http://www .smartgrowth.org!news/article.asp?art~6262&state~52&res~ 1680
RPS Policy Committee
October 10, 2007
Page ]6 of24
Conclusion: As these options have not been studied on a regional basis, it is not possible at this
point to determine what affect they have on the total amount ofland needed for the project to
accomplish its goals.
E. The Need for Resource Lands is Over-Stated and Violates State Law
The Resource Lands Review Committee (RLRC) was established by the RPS Policy Committee
as required by ORS 197.656(6). The Committee was made up of experts appointed by the Policy
Committee and used criteria that was approved by the Policy Committee to help guide the
project in implementing Project Goal 2, also approved by the Policy Committee.
Given that the total number of needed acres is overstated in the current proposal, and the fact that
about 77 percent of the land in the proposal is currently zoned resource land, it is clear that the
proposed urban reserves include far too many acres of resource land. This outcome directly
violates the project's own goals, the purposes of the statewide planning goals, and numerous
other requirements under state law.
The extent to which overall land needs are over-stated is discussed above. Specific instances of
how that affects resource lands, and additional violations of the ORS statute, are outlined below.
I. The alternatives analyses do not meet statutory requirements. ORS I 97.656(2)(b)(B) requires
that the project explore "optional techniques to achieve the goals for each regional problem
that is the subject of the process." One of the regional problems being addressed in this
process is the "loss of valuable farm and forest land caused by urban expansion."
To evaluate optional techniques and conform with the purposes of the statewide planning
goals, certain questions must be asked regionally. These questions would help the region
evaluate whether, instead of nearly 1,650 acres of land designated by the RLRC as critical to
the region's local economy, there any non-resource lands or less valuable resource lands that
could better meet the needs of the region and achieve the project's goals.
For example:
o The proposal includes high-quality resource land to be designated as parks or open
while avoiding lower-quality land between the cities that can serve this same purpose
while maintaining community separation. This violates the purposes of the Urban
Reserve Rule, the purposes of Goals 3 and 14, and the local goals of this project.
o A regional approach to the problems might involve moving population away from
jurisdictions that are surrounded by high quality resource land or that have
connectivity issues. Is there something the region could "give" those jurisdictions in
exchange? This would conform with the purposes of the URA rule, the RPS statute
and the purposes of Goals 3, 12 and 14.
RPS Policy Committee
October 10. 2007
Page 17 of24
o The project's models show that every acre proposed for industrial use is in excess of
what is needed. Much or most of this acreage is resource land and much of it is
included based on a purported need for large flat parcels to serve industrial uses.
Adjusting the proposal to accurately reflect commercial and industrial land needs will
result in a different amount, type, and location of needed land. The proposed
industrial designation offarmland that is part of the commercial agricultural base
violates the RPS statue, the purpose of the URA rule, the purposes of Goals 3, 9, and
14, and the local goals set out by the RPS project
o The region's housing needs can be better met by increasing density targets to at least
reflect existing trends, thereby easing the pressure on resource lands. This would
conform with the purposes of Goals 3, 10 and 14.
o Each jurisdiction did an independent alternatives analysis for its own wishes and
needs, but the region has not conducted an analysis to determine whether land
rejected by a jurisdiction might better meet the needs of the region for a specific use.
Such an analysis is required by the RPS statute.
The jurisdiction-specific alternatives analyses that are memorialized in the Draft Plan
also fail to comply with state law. As stated above, we do not believe the project can
ignore the hierarchy of land that is required to be addressed for designation of urban
reserves.
o Chapter 5 provides very detailed descriptions as to why the included areas will work,
but very cursory descriptions of why other areas were excluded and whether these
alternative areas are higher or lower priority for inclusion under the hierarchy.
The descriptions of excluded areas have inconsistent levels of detail regarding current
zoning, whether any resource land within them was identified as part of the
commercial agriculture base, and what the soil class is or how it would rank in the
urban reserve hierarchy. They cite various factors but do not actually reach the
conclusion that:
(a) Future urban services could not reasonably be provided to the higher priority
area due to topographical or other physical constraints; or
(b) Maximum efficiency of land uses within a proposed urban reserve area
requires inclusion of lower priority lands in order to include or to provide services
to higher priority lands.
Under the urban reserve rule, these are the only valid reasons for including lower-
priority land in an urban reserve area instead of higher-priority land.37
37 OAR 660-02]-0030(4).
RPS Policy Committee
October] 0, 2007
Page 18 of24
o The analyses do not address the sometimes significant differences between the
proposed urban reserves and the results of the Base Case analysis done by project
consultants, 38
2, The rationalization for avoiding the Urban Reserve hierarchy of lands is flawed, The Draft
Report indicates that some of the pockets of non-resource land that might otherwise have
been included in urban reserves were not chosen because they might pull the city's growth
out onto resource lands as well, The Draft Plan cites that project's Phase I Report and "Iong-
held, regional opinion" as the basis for this assertion,39
Whether that assertion is accurate or not is impossible to tell from the evidence presented
with the Draft Plan, What is certain, however, is that every acre of non-resource land that
was included in these expansions would be one less acre of resource land needed,
We are not aware of any analyses that have been conducted to determine the impact of
including such lands, This issue was only raised as a reason for avoiding non-resource lands
in the alternatives analyses for lands between Medford and Jacksonville,
3, As described in the Draft Report, the COSA strategy was the eventual outcome of one of the
tasks originally assigned to the Project Citizen Involvement Committee (PCIC). Making this
policy "optional" effectively neuters it and makes it meaningless as a tool for helping achieve
Project Goals and the implementing policies,
IV Other Issues and Additional Concerns
In order to the issues identified above, we have several additional concerns,
A. The Transportation Planning for the Project is Incomplete and Violates State Law
and the Purpose of Goal 12
The project recognized early on that transportation and land use were intimately linked:o and
has spent considerable resources to address those linkages. Although "Trends" are discussed in
the Draft Plan, the "Transportation Needs" discussion consists of nothing more than a section
header.'1 Based on the trends, however, we are concerned that the assumptions underlying the
entire analysis violate current law and mandated state and federal regulations, and have thus
resulted in a modeling paradigm that works against meeting the Project Goals.
J8 The Draft Plan includes the following: "Although the Base Case was not used as fonnative input in the delineation
of urban reserves, it was useful in formulating the findings and alternatives analyses, and in determining where RPS
was deviating form the standard urban reserve priority criteria." (p. 4-12) The differences between the Base Case
and the urban reserves are generally not addressed in the local alternatives analyses.
39 Draft Plan, p, 1-13,
.0 Indeed, Goal t, Policies 5 and 6 specifically address this linkage,
41 Draft Plan, p, 3-15,
RPS Policy Committee
October 10, 2007
Page 190[24
According to the Draft Report, the beginning assumption for the transportation analysis is that
vehicle miles traveled (VMT) in the region will increase by 135 percent by 2050:2 The
transportation analyses are thus being planned as if VMT will increase faster than the population
will increase. Assuming this to be the case, and not taking direct action to reverse this trend, is a
direct violation of Goal 12 and the Transportation Planning Rule (TPR), which calls for
reductions in per capita VMT. Planning this result is also a violation of the purpose of Goal 13,
and will likely result in violation of Department of Environmental Quality (DEQ) air quality
standards.
Even if the underlying assumption were appropriate, earlier versions of the project's
transportation model indicate that modifications to proposed development patterns are
appropriate. These results specifically showed that "nodal" development would be the pattern
that created the least degradation to the road network:3 Nodal development would require less
land in urban reserves-particularly if some of that development were accomplished as infill or
redevelopment-and may allow the region to cut back on some of the proposed urban reserve
areas that add to the region's transportation burden. The public has not seen these results and has
seen no indication of how the Draft Plan will be modified in response.
In addition to the plan not including these results, there is one element that is completely missing
from any modeling that has been presented thus far: transit. We understand that transit is
supposed to be included in the next model runs, but it does not appear that the results will be
available until the very end of October at the earliest.
Given the current proposed schedule (which does not include any public hearings after tonight)
the public will not have any opportunity to review and comment on the role transportation will
play in the plan prior to the proposed review by LCDC in November. This is a violation of both
Goal I and ofORS 197.654.
B. The Amount and Adequacy of Regional Citizen Involvement in Developing the
Draft Plan is Over-Stated, and Violates State Law and the Purpose of Statewide
Planning Goall
The purpose of the RPS project has been to create a regional plan for addressing regional
problems created by regional growth. The RPS Statute and Goal I both require the opportunity
for the public to participate. Although there have been opportunities for limited public
participation at various points in the project, the Draft Plan overstates the role citizens have
played at the regional level in helping create this regional plan.
I. The Project Citizen Involvement Committee (PCIC) was active during the very early stages
of this project. They represented a good cross section of citizen concerns, and they were
given a significant role in the project. One ofthe responsibilities of the PCIC was to "provide
42 Draft Plan, p, 3- 1 4.
43 "Regional Problem Solving Model Outputs III," presented by the Policy Committee September 11,2007.
RPS Policy Committee
October 10. 2007
Page 20 of 24
a significant opportunity for broad-based public input." While the PCIC existed, this
opportunity existed.
The last time this committee met was January, 2003. They disbanded without having
completed at least seven of the 12 responsibilities given them."
The committee was not replaced with any similar forum for ongoing citizen input into the
project at the regional level.
2. As is well described in Chapter 2 of the Draft Plan, citizen input into the initial process of
selecting potential urban reserve areas was largely focused at the city level. Each city held
workshops and hearings at which citizens from that city were able to provide input regarding
potential urban reserves for their city. Some cities allowed residents of the county that would
be affected by potential urban reserves to participate. Others did not.
What the project did not provide, either during that stage or after that stage but before Policy
Committee "deliberations," was the opportunity for the citizens of the region to formally
review and comment on these proposals from a regional perspective.
Before the present set of hearings, there was no forum provided for a citizen of one
jurisdiction to look at the entire regional proposal, including the proposed urban reserve areas
of other jurisdictions, and formally comment, on the record. Residents of the County were
never provided such a forum. 45
3. During the summer of 2006, the project held three "informational" meetings, or open houses,
at which representatives of the project presented the package of city proposed urban reserves.
While this was an opportunity for the public to become familiar with the project, there was
no formal mechanism for collecting citizen input to the project about what they learned at
those meetings.
4. After soliciting written comments from the state agencies, local agencies, and 1000 Friends
of Oregon regarding the proposed package of urban reserve areas, in the late fall of 2006 the
Policy Committee began what they called "deliberations" on the urban reserve proposals
advanced by each city.
The term "deliberations" is a mis-nomer in this context, as deliberations normally follow
public hearings. In this case, there were no public hearings before the "deliberations" process
began. Except to note their existence, the informational meetings held during the prior
summer were not referred to during the "deliberations" process. Nor were the results of the
surveys taken.
44 See http://www.rvcog.org/MN.asp?pg=rps_committees.
45 While it could be argued that citizens could have attended the endless meetings of the lAC and the Policy
Committee, calling that an opportunity for meaningful citizen involvement is problematic. Many of these meetings
were held during work hours and, as will be discussed below, citizens were not always allowed to speak about topics
of concern.
RPS Policy Committee
October 10, 2007
Page 2] of24
What is worse still is that, at the beginning of the "deliberations" process the Policy
Committee voted to bar citizens from speaking about specific urban reserve proposals at their
meetings. That ban was enforced several times when citizens attempted to address the
committee.
It was not, however, uniformly enforced against everyone. On at least four separate occasions
property owners or their representatives were allowed to address the Policy Committee
regarding their properties.
5. Even during this hearing process, being held after the "deliberations" have been completed,
the Policy Committee is directing citizens to provide their input on specific urban reserve
areas back to the city that proposed the area--even if their concerns are regional in nature.
C. Basic Questions of Regional Importance Have Not Been Asked Or Answered
In addition to the questions of population distribution and regional alternatives to meet needs,
there are several other critical questions of regional importance that have not been answered in
the process that led to the Draft Plan. Among those:
I. The project is planning, we think appropriately, to shift population and land uses among
communities to alleviate some regional problems. The question that remains un-answered:
How will new population and uses end up in the desired locations? Regardless of what areas
the project designates for increases in population, there has not been a realistic discussion yet
as to how the region plans to steer development to those areas.
The South Valley Employment Center is a good example. As project modeling has
illustrated, an excess of industrial land already exists in the region. If the project adds more in
the south valley, how will businesses be encouraged to locate there rather than somewhere
else? If the development of the South Valley Employment Center depends on raising funds
for an over crossing at South Stage Road, or if it is tied into an urban renewal district to help
fund upgrades to PH-3 or other areas within the region, will development there be
competitive with sites already within other UGBs and near services?
There are several questions like this that need to be answered, and those answers may affect
which urban reserve areas can be justified in the end.
2. Where is affordable housing in the plan, and how is it going to be provided? Thus far, very
little discussion of this issue has taken place.
Goal 10 and its implementing rules require that every city provide for adequate housing at
price ranges commensurate with the financial capabilities of residents. The plan that comes
out of this project must meet Goal 10 requirements. That gives a partial answer to the
"where. "
The "how" is yet unanswered. How will the region assure that land is designated for
affordable housing, and that such land is protected for that use? Will the region consider
RPS Policy Committee
October 10, 2007
Page 22 of 24
adoption of uniform procedures? Higher densities mean less land cost per unit-will the
region consider minimum density standards? Designation of multi-family zones? Deed
restrictions tying appreciation to increases in median income or some other marker? Will the
region consider condominium conversion ordinances or other measures to protect existing
and future rental stock? Is the region willing to push for changes in state laws to allow tools
like inclusionary zoning?
The answers to these questions may also have an impact on how much land is needed and
where it is located,
3. Linking transportation planning to future urban development and expansion will be critical.
This conversation has begun, but thus far there has been little meaningful discussion of
options in addition to increasing road capacities for automobiles.
4. How will all of this be paid for? This is a huge question that has not been addressed in a
comprehensive way, There has been some conversation of tying two urban reserve areas
within a jurisdiction together in an Urban Renewal District, but other questions remain un-
asked.
For example, the viability of many urban reserve areas at the north end of the valley are
going to be dependent on upgrades to state and county road facilities. Who will pay for
these? If not the state or the county---or even if only partially by them-will the region set up
a system to contribute? Will cities be responsible for coming up with funds to improve
facilities their growth affects? Will cities be allowed to expand into new urban reserve areas
before this funding is in place?
How will the funds be raised? Will the cities increase System Development Charges (SDCs)
to contribute to these types of projects as well as pay increasing costs for internal
infrastructure?
A related question is whether the region will provide financial assistance to a jurisdiction that
may not get everything it thinks it needs from this project, or to one that is compelled to
accept something it may not want due to existing policies,
These questions are relevant to the amount of land the region will be able to afford to supply
services to, and thus to the determination of what urban reserve areas can be justified.
D. The Draft Plan and Draft Shareholders Agreement Fail to Comply with ORS
197.656(2)(b)
Chapter 6 of the Draft Plan purports to address the I 96.656(2)(b) requirements that must be met,
in addition to 2(a) and 2(c), before LCDC can acknowledge a plan that doesn't comply with
Goals or their implementing rules. These are:
(b) The regional problem-solving process has included agreement among the participants on:
(A) Regional goals for resolution of each regional problem that is the subject of the process;
(B) Optional techniques to achieve the goals for each regional problem that is the subject of
the process;
RPS Policy Committee
October 10, 2007
Page 23 of 24
(C) Measurable indicators of performance toward achievement of the goals for each regional
problem that is the subject ofthe process;
(0) A system of incentives and disincentives to encourage successful implementation ofthe
techniques chosen by the participants to achieve the goals;
(E) A system for monitoring progress toward achievement of the goals; and
(F) A process for correction of the techniques if monitoring indicates that the techniques are
not achieving the goals.
The current draft falls short of these requirements.
For example, it identifies increasing average residential density by 14% over 50 years as an
implementation strategy to provide for more efficient land utilization and thus manage regional
growth. It also identifies a review process to monitor progress toward achieving this increase in
density. It does not, however:
. Identify optional techniques to achieve this goal, such as minimum density standards,
reducing minimum lot sizes, etc.
. Layout measurable indicators of perforrnance toward achievement. Can the entire
increase be achieved in the final five years of the plan with no increase in previous forty?
. Identify incentives and disincentives to encourage successful implementation. Will the
County concur with a city expansion of its UGB if their density is decreasing
(disincentive)? Will there be some sort of rewards for cities that achieve their density
targets?
. It doesn't identify a process for correction if density fails to increase or even decreases.
Although the details vary, these general weaknesses also exist for other goals and techniques.
On a larger level, once a jurisdiction receives acknowledgement of its urban reserve areas, what
binds it to remaining part of the project and participating in ongoing monitoring and
enforcement? The need to justify Tolo and the South Valley Employment Center will provide
Central Point and Phoenix incentive to stay with the project. For the others, the major incentive
to stay with the project is the potential that MPO funding priorities may be directed away from
them. The MPO has not yet made such a commitment, and the extent to which they legally can
do this has not been resolved.
RPS Policy Committee
October 10, 2007
Page 24 of 24
V. Specific Urban Reserve Areas
In past correspondence we have provided comments on specific proposed urban reserve areas.46
Given the deficiencies noted above, it is not appropriate to provide specific comments at this
time.
VI. Conclusions
According to modeling done by the project consultants, even based on current assumptions, the
residential, commercial and industrial land needed to accommodate a doubling of the region's
population can be reduced by over 1,400 acres from the current proposal. We believe that
correcting some of the deficiencies noted above, planning for demonstrable needs for industrial
and commercial lands, and incorporating the results of appropriate regional analyses, that total
can be cut ever further. Such changes would likely better meet the requirements of the RPS
statute, the purposes of the statewide planning Goals, and the goals and policies of the project
itself.
As described above, there are a number of issues that remain to be resolved before this plan and
the resulting local plans and regulations can be acknowledged by LCDC. Overall, however,
while the issues are significant, we believe they are not insurmountable.
The project now faces what may be its most daunting challenge since agreeing to embark on this
journey-that of getting all of the required parties to agree by consensus to a plan that best
serves the region.
We still believe that is possible, and we continue to stand ready to help in any way we can.
Thank you again for this opportunity to comment,
Greg Holmes
Southern Oregon Planning Advocate
1000 Friends of Oregon
46 The latest set of these comments was provided in the written comments submitted by Greg Holmes to the RPS
Policy Committee, September ]5,2006, and included in the Deliberations Packet provided to the members of the
Policy Committee at the beginning of the "deliberations" phase.
,A w\. b Uj(,l
Ros 611./5
1"iJ) [(( Fon-\ }]1 'S';pee€ J~
/O/;{o/ or)
One thing we have in common
act is highly pleasurable.
including the human animal,
with these anima13 is that the reproductive
Nature wants it that way so that animals I
have an incentive to ~eproduce.
So the genitals of dogs, eat.s, people, sheep, cows and pigs, and ot.her
mammals are filled with sensitive net:ve endil1':]s.
That's why when dc'gs and cats ar~ spayed or neuter-ed ~ they get
anest.hetized.
But on farms and ranch8~1 it's standard practice to castrate male ~heep,
co~s and pigs without painkiller. Most farmers and ranchers just slice
off the Ben~itive genitals.
These animals suffee eXGcuGiating pain] but appacently not enough of
America cares about them enough to create laws requlrlng that they
receive painkiller. TherE.~5 a doublE! ~tandard: etfl.!? for dogs and cats!
and another for sheep, cows and piq3~ It's purely arbitrarYI since each
suffers similarly 'When cast.rated without anesthetic.
Le.t ':5 not- be like that,) and have a double st.andard for these animals
when it comes to (:JUt tetherin9 ordinance.
Thl2Y all ar-e socia} anirrlals whet lJOuld be lonely ti€:>d up in a corner of
the yard fo~ much or all their lives. They all need exercise, and they
need t.o run and play. They would feel frustrated living on a rope.
They all can strangle to death, get attacked by other animals, 01: get
dehydr-at:,ed if they get tangled up and can't reach water' ~
I ask that you look beyond what species they happen to be. I ask that
you look into the hearts and souls of each of these animals and
r-ecognize that they all need a tethering lindt, just .as much as dogs do~
I talked about
a9ain~t ::Jomeone
of species ism :
speciesism: a prejudice that makes people discriminate
::limply because he's not human. But. there'::l anot.her kind
blindly favoring one species over another.
Let':3 not be like the fanners and r-ancher-s who take their- dogs and cats
to th€ vet8~ina~ian to be ~paY8d and n8ute~ed with thB cQmfQ~t of
anesthetic, then tur'n ar-ound and slice- off the genitals of their male
sheep, cows and pigs.
Let';'] not blindly favor one dom6:"JtiG'ated mammal ove~ a.nother, and. limit
tethering for dogs but allow these equally needy animals [point to
pictures} to live on a chain.
You're the gover-nment of Ashland, one of the most. p[.ogr:essive tCH,.ms in
the
and
not
u.s.
hope
Just
I appeal to your
you ~.o'il1 deal out
to dogs~ when you
higher c(lnsciousnees and ethics ~ I expect.
jU3tic8 to all these domesticated mammals,
pass your tethering limits~ Thank you~
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Dear Councilors and
r~lava\~ :.
,
I'm concerned about the animals in Ashland ~,ho are tied up at their homes
for e:<ce'~siYe periods. They suffer loneliness. frustration and boredom.
They also run the ris~: of strangling to deattl, getting abused by ~:ids or
adults, getting attacked by animals, ar dying of heatstroke.
Jackson
chains.
ha\/e to
i lle9a.1.
at their
County allouIs animals to be tied for their entire lives on short
This is not a life that anyone in Ashland, including pets, should
enciure~ PllE"~ase pa.'5S a lal.ll to make l;his kind of arfimal abuse
Please heavily restrict the tethering af dogs and ather animals
hames. '
do i n9
also help people.
likely to bite
YJ.
IS.
IoJ~t~ ~ uS c . e-J.,^--
"kel L" 1 (j)lY)
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-(II/lEI /fV AJ-lJckIV!J
Dear Counc i lor's and l'1a.YCJ''''1
I'm concerned about the animals in A5hl~nd who are tied UP at their homes
for excessive periods. They suffer loneliness. frustration and boredom.
They also run the risk of strangling to death, getting abused by kids or
adults, getting attacked by animals, or dying of heatstroke.
Jackson County allows animals to be tied for their entire lives on short
chains. This is not a life that anyone in Ashland, including pets, should
have to endure. Please pass a law to make this kind of animal abuse
illegal. Please heavily restrict the tethering of dogs and other animals
at their homes.
By doing this, you
nuisance. They're
~1:g. .
also help people. Chained dogs are often a barking
more likely to bite than oth r dogs are.
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Dear Councilors and Maya~c
I'm concerned about the animals in Ashland who are tied up at their hemes
for e~<cessive periods. They suffer loneliness, 'fru.stration and boredom.
They also run the risk of strangling to death, getting abused by kids or
adults, getting attacked by anilllals, 01" dying of heatstroke.
Jackson County allows animals to be tied for their entire lives on short
chains. This is not a life that anyone in Ashland, including pets, should
have to endure. Please pass a. law to make this kind of animal abuse
illeqal. Please heavily ['estrict the tethering of dogs and other animals
at their homes.
By doing this, you
nuisance. They're
~-~~ .
~-:t:l
also help people. Chained dogs are often a barking
like~y to bite eORle than oth I' dogs are.
~ -
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Dear Councilors and
r~lavaf' :
,
r 'm conc:er'ned abol_tt the anim.3..1s i.n Ashla.nd 1.'lho a.re ti~d Llp at thE"~ir hc.1mes
for e:(ce~~ive periad5. They suffer loneliness. frustration and boredom.
They also run the ris~: of strarlgling to death, getting abused by ~:ids or
adults, getting attack:ed by animals, or dying af heatstroke.
Jackson
chains.
have to
ille9a1.
at theil'
Cou~ty allouIs animals to be tied far their entire live$ on shart
This is not a life that anyone in Ashland, including pets, should
endu,~. PIE'~ase pass a 1 a 1,11 to make this ki.nd of ari.~imal abuse
Please heavily restrict the tethering af dogs and ather animals
homes.
'\
By doing this, you
~uisance. Thex're
~~,:;:~
also help people.
likely to bi.te
:c.
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Dear Ct"Junc i lors and Mayor":
I'm concerned about the animals in Ashland l.Alha ar'e ti't.~d up at their' he-'hnes
for excessive periods. They suffer loneliness, frustr~tion and boredom.
They also run the risk of strangling to death, getting abused by kids or
.3.dults, getting attacked by animals, "'1' dying of heatstroke.
Jackson County allows animals to be tied far their entire lives on short
eha. i ns. Th is is not a 1 i fe that anyone in Ash land, inc Iud i ng pet.s, ';;hould
have to endure. Please pass a law to make this kind of animal abuse
illegal. Please heavil~ restrict the tethering of dogs and other animals
ai; their- homes.
also help people. Chained dogs are often a barking
likely to bite eORle than oth r dogs are.
.,
RlCt+ RoS"bVTlt.A:L.
-;:J0<vY1;& \Zo~o..l
l22-'3
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Dear Councilors and
r~la.vor :
/
I'm concerned about the animals in As~,land ~,ha ar'e tied up at their homes
far e:<cessive periods. They suffer loneliness. frustration and boredom.
They also run the ris~: of strang1ir19 to death, getting abused by ~:ids or
adults, getting attacked by animals, or dying of heatstra~:e.
Jackson
chains.
ha ',,'e to
i lleqa 1.
at their
County allows animal.s to be tied for their entire lives on short
This is not a life th.3.t anY',~ne in A':shland, includinq pets, ":si""1>:)ul.j
endure. Plr:.=ase pa'::ss a 1al)/ to make this kind of ari'1mal abuse
Please heavily restrict the tethering of dogs and ather animals
hc>mes.
likely 1:;0
By doing
l"1u.isance.
also
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, Kif 517(1 r-fovv-ct! 611 Ie j) (j / ~ /-
Dear Councilors and
r-1avar;
,
I 'lT1 conceT~ned abol_\-t th>:=-~ animats in Ashland ~~Iha ar'e tied up at thoEir r\ChHeS
for e:<cessive periods. They suffer loneliness, frustra~ion and bor@dam.
They also run the ris~: of stranglir1g to death, getting abused bl kids or
adults, getting at~acked' by animals, or dying qf heatstroke.
J';:.Lckson
chains.
ha ',/8 to
i llega 1.
at their
County allauls animals to be tied for their entire lives on short
This is nat a life that anyone in Ashland, including pets, should
endure~ Pl'€"~a:;e pass a lal.~1 to make this kind of arfj.mal abuse
Please.heavily re'5trict the tethert'ng of dogs and ather animals
homes. . '
also help people. Chained dogs are often a barking
likely to bite people than ath~r dOQs are.
""I , ' M....Q.../ ,.~ 't' .~
By doing this, you
...-.. fluisance. Thev're
.,:~C& '.
2)eicnz.. Copple..
f,
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CD
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Dear Councilors and
t~la.var :
,
I'm conc8f'ned abol_tt thl.:-:! animals in A3hland 1.'lna ar'e tied Ltp at their home3
for e:<cessive periods. They suffer loneliness. frustration and boredom.
They also run the ris~: of strar\gling to death, getting abused by kids or
adults, getting attacked by animals, ar dying af heatstroke.
Jackson
chains.
have to
illegal.
at their
County allQ~'s animals to be tied for their entire lives on shart
This is not a life that anyone in Ashland, including pets, should
endl_lre. Please pa'5S a 1.:1!.'/ to make l:his kind of an~imal abLtSe
Plea$e heavjly restrict the tethering of dogs and other animals
hc)mes a
By doing this, you
...n _. ~u i sa. nee. The-X" . f"e
~~~
also help people. Chained
likely to bite
-3Lb <6\ -u:::>
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504- ,As4L~ <I
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1:'"
Dear Councilors and
r.lavar:
T
I'm concerned about l;he animals i.n A'shla.nd I.~,ha a.r'e tied up a.t their hCHnes
for e:<cessive periods. They suff~r loneliness, frustration and boredom.
They also run the rish: of strangling to death, getting abused by k:ids or
adults, getting at~ach:ed by animals, or dying of heatstroh:e.
Jackson
chains.
have to
il 1 eg a 1 .
at their
County allauls animals to be tied for their entire liv23 on shart
This is not a life that anyone in Ashland, including pets, should
endure~ PIE".:-3.se pass a lal.~! to make this kind of an'11mal abuse
Please heavily restrict the tethering of dogs and other animals
h':)mes.
,
'~
By doinl~
~.~2~isance.
also help people. Chained
mare likely to bite people
.p -,
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1;22.07
M~k eVlV\.tz
. ~Vh&J;eir1 V\O\@ pO~.Jox . co Vh.
Dear Councilors and
r~la va f~ :
/
I'm concerned about the animals in Astlland ~Iho are tied up at their homes
fer e:<ce~sive periods. They suffer loneliness. frustration and boredom.
They also run the risk of strar\gling to death, getting abused by kids or
adults, getting at~ac~:ed by animals, or dying af heatstroke.
"
Jackson County allou1s animals to be tied for their entire live3 on short
chains. This i.s nelc a life th":!1.t anyone in A-5hland, includin'~ pets, '3h'~uld
ha'"le to endu,e~ PIEla=:ie pass .at. lal.~' to make this kind af an~iiTl.a.l abuse
illegal. Please heavilv restrict the teth~ri~g af dogs and ather animals
, I
at their homes.
By doing
.......-, net i sa nc'e..
~tf'
cv~V01
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also help people. Chained dogs
likel..... to bite
, ...
are..
~N\a.
S.,
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Dear Councilors and
t~1a.va{~ :
,
I'm concerned abou't the animals in Ashland ~Iha ar'e tied up at their homes
far e:<ces~tve periods. They suffer loneliness~ frustration and boredom.
They also run the ris~: of stranglirlg to death, getting abused by kids or
adults, getting attacked by animals, or dying of heatstra~:e.
Jac~:sar' County alla~'s animals to be tied for their entire lives on short
chains. This is not a life that anyone in Ashland, including pets, should
ha....'e to encil_Ire. PIE'.:ase pass a lal.JJ to make this kind of aril':itTtal abLlse
illegal. Please heavily restrict the tethering af dogs and other animals
at their :",,7~1;7 ~{j'b<;/\./\... .;w.V 7T" 51 /Jf'T e .s-~ '1fJ,?(
By doing this, yau ~!ill also help people. Chained
The'~'re als~ more li~:ely to bite people
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Dear Cal~ncLlars and Mayor:
['111 co:1ncE-~f'n~~d 3.bol_\r; !:;rv.2 .:ani.lTt.3.l.':s i.n Ashla.nd I.Alho3.r'e tled up 3.1:; l::h.:-:ir' r\l:.lln~~.5
\;or l2:';:I=~?:5::;;i.""'e p~?f'i,:>d5. The'/ sl_l.frel- lDneLtne-3.:;;j. ff'I_I.5l::r.3.ti':Jnand bore,j':JI11.
T~\ey aLso run the risk of strarlglLrlg to deatt1, getti.ng abused by ~:ida or
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I I~QJc",unty a(la",,, anlf",,-1.5 t;'J be tled fat' th,~ir entlre lJ.....,~" '''n5r''~
chai.ns. "fhi-s i.s nCJI:;-:3. Life th:tl:; any":>n'= tn H::ihlarv::i, i.n.=lu.din,;! pet5, '3h(~IJl.,j
have to endure. Please pass a laul to mak:e thlS ~::ind of a~lmal abuEe
IO/~/~~:~~~i~ ~~~~ "iti3\3'~qLrb~~ ather anl,nol~
I By dOlng th15, YOU~llflll :Lisa help pe':1ple. Chaln~==d d(EJS :are o-fl:;en a. bar'~ lng
They're .3.1sl~_mcJre likely to bite pe":Jple th~n othe,r: d>:>q'5,:a.re.
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