On January 30, 2019, HLA submitted written testimony to object to Metro’s proposed Urban Growth Boundary (UGB) expansion. HLA believes that it is imperative that Metro recommit to providing present and future urban Clackamas, Washington, and Multnomah County residents with greater access to affordable housing. By Metro’s authority within Oregon’s statewide land use system and its own code provisions, and pursuant to state and federal requirements, as set forth below, HLA believes the time for Metro to integrate these obligations into any plans to expand the urban growth boundary is now.
HLA argued the following points in objecting to the UGB expansions:
- Metro and the state Land Conservation and Development Commission (LCDC) are subject to federal fair housing obligations. Yet, the UGB expansion decision does not meet those obligations to affirmatively further fair housing.
- Metro failed to demonstrate that the UGB expansion complies with Goal 10, the Needed Housing Statutes, and planning obligations under Metro Code Chapter 3.
- Metro failed to justify the need to expand the UGB because it did not analyze what is already happening across the region in relation to buildable land supplies and housing needs analyses. This final argument explores:
- the incorrect calculation of existing capacity by failing to take into account Accessory Dwelling Units, as required under SB 1051 and ORS 197.312.
- that Metro cannot hide behind its charter limitation to suggest that it cannot require increased densities and HLA contends this charter provision is preempted by state and federal law,
- Metro failed to prepare a comparative analysis of social consequences for housing affordability, suitability, and location as required under Goal 14,
- a region-wide HNA should be considered prior to the expansion, and
- the conditions imposed by Metro do not accomplish affordable housing goals.
HLA’s full letter objecting to the UGB expansion can be found on the DLCD website:
HLA Letter to DLCD – Metro UGB Expansion (January 30, 2019)
More information about the proposed UGB expansion can be found on this page of the DLCD website.