Brochure 2 in IRR Series

 

December 22, 2003

 

Land Use Committee

Hugo Neighborhood Association & Historical Society

Member of the CACNA Coalition

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Oregon Statewide Goal 4 — Forest Lands OAR 660-015-0000(4)1

Forest lands are those lands acknowledged as forest lands as of the date of adoption of this goal amendment. Where a plan is not acknowledged or a plan amendment involving forest lands is proposed, forest land shall include lands which are suitable for commercial forest uses including adjacent or nearby lands which are necessary to permit forest operations or practices and other forested lands that maintain soil, air, water and fish and wildlife resources.

Comprehensive Plan - Goal 11, Policy 2.B. - Requests involving changes for lands from a resource designation to a non-resource designation shall either comply with statewide exception criteria contained in Oregon Revised Statutes 197.732, and as implemented in Oregon Administrative Rules, Chapter 660, Division 4, or demonstrate the land is non-resource pursuant to the criteria contained in Policy 3.

Goal 11, Policy 3.B.(1) This policy permits requests involving changes for lands from a resource designation (i.e., woodlot resource) to a non-resource designation through the internal rate of return, or IRR procedure.3

"A lot or parcel is considered forest land when the predominant (more than 50%) soil or soils on the parcel have an internal rate of return of 3.5 or higher (if a single forest-rated soil is present), or composite internal rate of return of 3.5 or higher (if multiple forest-rated soils are present)."

Plan Amendments Josephine County by adopting the IRR system, has imposed requirements in addition to compliance with the goals for plan amendments relating to forest lands. Goal 11, Policy 2.B. requires either an exception to the goals or a showing that the subject lands are not lands protected by the goals. Goal 11, Policy 3.B.(1) is a definition of forest land. The county's definition cannot supercede any definition of forest land found in statute or the goals. However, the county can impose regulations that are more restrictive - i.e. that offer more protection to resource lands - than state law or regulations.

Issues Concerning The IRR Procedure Over the last couple of decades many issues has been raised by neighbors in Josephine County concerning the value of the IRR or composite IRR procedures as they are actually applied.

. IRR/CIRR ratings and calculations without following the process to amend the comprehensive plan - ORS 197.175(2)(a) & ORS 197.835(6).

. CIRR calculations do not consider potential forest soils not rated by the Brown Report3 or the Soil Survey4, including farm soils.

. IRR formula uses a harvest rotation age of 85 years which is longer than the economic optimum (longest in southern Oregon is around 65 years).

. IRR formula uses old stumpage prices that are extremely low versus today’s prices.

. IRR formula uses a conservative percent (1% versus around 3%) projected increase in timber prices.

More Information. Would you like to learn more about citizen involvement in land use planning? Contact a member of the Land Use Committee of the Hugo Neighborhood.

2. Josephine County. October 2000. The Comprehensive Plan For Josephine County. Grants Pass, OR.

3. Lawrence F. Brown. 1985. Using The Internal Rate Of Return To Rate Forest Soils For Applications In Land Use Planning. Grants Pass, OR.; Michael Snider. 1999. Locational Factors Affecting Woodlot Resource Lands. Josephine County Planning Office. Grants Pass, OR.