[Note: LandWatch and the City are both substantially revising their technical approach to determining a 20-year residential need. Given that, this analysis is somewhat less relevant than before. We will be issuing another critique when appropriate.]

Back in July, when the City and County Planning Commissions held joint hearings on the Bend UGB Expansion, LandWatch prepared and entered into the record a critique of the City's Residential Land Study. The point of the "RLS" is to calculate the number of acres the city needs to bring in to an expanded UGB to create a land supply - including existing vacant and redevelopable land within the current UGB - suitable for handling 20 years worth of residential growth.

Based on its work in the RLS and a related memo referred to as the efficiency memo, the City calculated a twenty-year need for 2,550 gross acres of residential land. Owing to several technical errors, which LandWatch has detailed in the "Technical Fixes" memo attached below, we believe the city has substantially overestimated its actual need, which we believe to be 1,234 acres.

The technical errors in the methodology used by the city can be summarized as follows:

1. The City’s methodology falls short of addressing projected demand for multi-family units. By
   planning for too many low-density single-family units, the City is over-estimating its future land need;
2. Although the efficiency memo claims to present acreages representative of a 20-year need, it actually
   appears to represent a 22-year need. As a result, the city is substantially overestimating its 20-year
   residential land need;
3. The city’s methodology for determining future demand for second homes substantially overestimates
   past demand, which in turn is used – albeit in rather arbitrary fashion – to gauge future need. As a
   result, the city is substantially overestimating its future residential land need.

These conclusions are based on our own reproduction of the city's process. We were able to reproduce the city's exact methodology and come to the exact same results. In this work, we made no new policy assumptions, choosing to focus on technical accuracy instead.

A second element of our critique, outlined in a separate memo below, involves the number of acres the city proposes to use for rights-of-way (roads), parks, and schools. State law (OAR 660-024-0040) suggests that 25% of the net buildable land proposed for inclusion should be devoted to these uses. A city can elect to pursue more land, but it must justify its need to the state. The City of Bend has calculated that a full 50% of its overall land need will be for roads, schools, and parks, and so far has not explained why it needs twice as much land as presumed by state law.

If the city were to use a 25% standard instead, the number of acres drops from 1,234 to roughly 700 acres. It's likely that the City can justify a higher percentage than 25%, but can it justify 50%? That remains to be seen.

While we're on the topic, it's worth pointing out that in order to meet state requirements, the City of Bend must grow at an aggregate density of only about six housing units per gross acre. That's pretty low for a city on its way to and beyond 100,000 people. If Bend were to grow at an average density of 7 or 8 units per gross acre, it would help facilitate public transit and save a fair amount on infrastructure. Not that we expect this to happen, but if the City of Bend were truly growing "smart" then really, there would be very little need for any additional (residential) land at all in the present expansion because the city ALREADY WOULD HAVE a twenty-year supply.*

*Although many builders have been screaming for more acreage to be brought in, saying we are facing a tremendous shortage of "shovel ready" land and so forth, the reality is that numbers don't lie. Bend isn't facing a supply shortage, at least as concerns residential land. How the City can propose 5,000 acres (1,500 above their own calculated residential and economic need of 3,050) is still a complete mystery. How development interests can call that low, is, well, kind of a head-scratcher to us.