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200 South Ivy Street, Lausmann Annex, Room 240
Medford, OR 97501
Phone: (541) 774-2380
Fax: (541) 618-1708
Hours: 8AM - 5PM Mon-Fri


City of Medford Oregon / Planning / Comprehensive Plan / Urban Growth Boundary Amendment

Urban Growth Boundary Amendment


The webpage for the ISA/PAL and ESA components of
the urban growth boundary amendment project

Latest update: 21 April 2014


Every city in Oregon has a boundary line enclosing lands that are eligible for urban development. These urban growth boundaries (UGBs) separate “urbanizable” land from “non-urbanizable” land. By law, every city has to maintain a 20-year supply of buildable land in its UGB to accommodate growth.
Medford is working on an amendment to its UGB to comply with the supply requirement. In order to identify the 20-year demand, the City adopted an updated Economic Element and an updated Housing Element into its Comprehensive Plan; these demonstrate the estimated demand for commercial, industrial and for residential land over the next two decades. In 2007 the City conducted a Buildable Lands Inventory (BLI), which shows land in the UGB that is vacant and land that is underutilized or ready for redevelopment. Taken together, these studies indicate that Medford does not have 20-year supply.


Apr. 21
The revised staff report—which collects all the findings and conclusions developed over the course of the hearings—will be on the "consent calendar" of the Planning Commission agenda for this Thursday, 24 April 2014. Consent calendar items are typically final orders or recommendations and usually are not discussed individually; rather they are formally adopted as a group.
In this case the revised staff report constitutes the Planning Commission's formal recommendation to the Council on the PALs.
CP-13-032 Revised staff report, 2014-04-17

Mar. 17
The Planning Commission voted 8–0 to approve the "proposed amendment locations" recommended by staff, with a small reduction to PAL 640b so it would not back onto the lots on Windward Drive, and the addition of several inclusion requests. Until staff makes a final map, the following will serve to show the Planning Commission's recommendations:
PAL recommendations by PC, 2014-03-13
Note that the Internal Study Areas (ISAs) are defunct now that this step has been completed. They were a useful planning tool that served their purpose, but are no longer needed. 
The Commission's recommendation will not go to the City Council until the Commission has also prepared a recommendation on boundary expansion areas as well. That means it won't likely be until late this year—at the earliest—that the Council will take up this recommendation for consideration.

Mar. 6
As promised in the February 14 update, Planning Department staff has developed a recommendation for the Planning Commission to consider at its 3/13 meeting. In order to differentiate these recommended areas from the internal study areas (ISAs), they have been termed "proposed amendment locations" (PALs). The supplemental staff report and associated maps follow:
Staff report, supplemental
Map: Proposed Amendment Locations, staff recommendation, 2014-03-03
Map: PAL map showing GLUP context
Map: ISA scoring

Feb. 14
The Planning Commission held its last hearing last night on the ISA project. They will begin deliberations at their March 13 meeting, where the planning department will present its recommended version of the amendment areas. Remember: more than 800 acres were analyzed, but only about 80 acres of UM (medium-density residential) and 90 acres of UH (high-density residential) are needed. We also analyzed about 250 acres for potential conversion to CM (commercial), but the need is more than 700, so it would be ideal to get as much converted as is feasible.
The following is written testimony that was received from Feb. 7 through the end of the workday on Feb. 13, and written testimony received at the hearing:
Written testimony (4) received after the 2-13 meeting packet was prepared
Written testimony (5) received at the hearing

Feb. 7
The Planning Commission will hold its next hearing on Feb. 13 starting at 5:30 in the Council Chambers on the third floor of City Hall, 411 West 8th Street. The following is written testimony that was received from Jan. 24 through yesterday, Feb. 6:
Written testimony (3)

Jan. 24
The Planning Commission held its first ISA hearing last night and received testimony from nearly 50 individuals. The next hearing will be held on 13 February 2014. The goal is to concentrate discussion on the ISAs south of Jackson Street, but that doesn't bar anyone from speaking on any ISA.

The following items supplement the staff report and attachments posted under the Jan. 16 heading.

Written testimony (1) received after publication of the staff report
Written testimony (2) received at the hearing
Staff presentation

Jan. 16
The complete agenda packet for the Jan. 23 meeting is available on the Planning Commission's agenda page, but because it's such a large agenda, the staff report and attachments for just the ISA agenda item are available here:

CP-13-032 staff report, part 1
CP-13-032 staff report, part 2
CP-13-032 staff report, part 3

Jan. 16
Murphy Road. There has been a lot of talk lately about this street, but despite the rumors there is no plan to extend Murphy Road through the Rogue Valley Country Club. Actually, the concept exists only as a suggestion in a technical memo from a transportation consultant. One of many recommendations in that memo is that if the Country Club property were to ever redevelop, an extension of Murphy Road northward would help improve north-south transportation connectivity.
That memo was included in the staff report on the ISA project because its primary purpose was to examine the impacts of the ISAs on the City's transportation system. The City is not considering amendments to its Transportation System Plan at this stage, so the Murphy Road suggestion has not been evaluated or recommended by staff, and is not up for consideration at this time.

Dec. 20
Staff mailed out notices (view one here) to the property owners in the ISAs and to property owners within 200 feet of the ISAs to notify them of the hearings scheduled for 1/23/2014 and 2/13/2014. The City would like to concentrate on the internal study areas NORTH of Jackson Street at the 1/23 hearing and on the areas SOUTH of Jackson Street at the 2/13 hearing (see links to maps below). The City encourages those who wish to testify to appear on the night that is appropriate to the area they wish to testify on.

This is a legislative action to change the General Land Use Plan (GLUP) designation of several areas in the City. The GLUP designation of a piece of property is the basis for its zoning. The Planning Commission will take testimony and consider its recommendation to the City Council, which will make the final decision on which ISAs or portions of ISAs to adopt. The file number for this action is CP-13-032.

10/9: The Council authorized the Planning Commission to begin the hearings process on the internal study areas (ISAs; see below. See Resolution no. 2013-127, 9/5/2013, for authorization details).



There are two major components in the process. One is an analysis of areas inside the current UGB for opportunities and constraints for handling the expected growth. The other is an analysis of areas outside the UGB to assess their suitability for inclusion. 

  • Internal Study Areas (ISAs). The first component involves land-use plan map designation changes. For example, the city might look at an area that is vacant or ready to redevelop that could be changed from low-density housing to medium-density housing. Then, when that land develops, it will take up more of the projected housing demand than it would have done if the zoning were unchanged. Likewise, changing from industrial designation (of which there is a projected surplus) to a commercial designation (for which there is a projected need) will help take care of part of that need. Planning staff refers to these changes generically as "internal study areas" (ISAs).

Looking for the ISA map?  There are now two maps of the Internal Study Areas: one for ISAs north of Jackson Street and one for the ISAs south of Jackson Street.

You may view the North map here
You may view the South map here
You may view the complete map with ward boundaries here.

And there's a guidebook to the ISAs available here (4th edition; 2014-01-15).

The General Land Use Plan (GLUP) designations that are used in the map are explained in the following table. The General Land Use Plan map is part of the City’s Comprehensive Plan; it provides the underlying land-use pattern for the zoning designations.


GLUP designation Corresponding Zoning Designations Example Uses and
Potential Density

A         Airport

I-L       Light Industrial

 airport-related uses

CM      Commercial

C-N     Neighborhood Commercial
C-C     Community Commercial
C-R     Regional Commercial
C-H     Heavy Commercial

Retail stores, repair shops, restaurants, filling stations, banks, personal services, hotels, etc.

SC        Service Commercial

C-S/P  Service Commercial & Professional Office

Professional and medical offices, hospitals, some retail allowed
CC       City Center No specific zoning Allows any kind of zoning designation
UR       Urban Residential SFR-2, SFR-4, SFR-6, SFR-10
           Single-Family Residential
2–10 dwelling units per acre (depending on zoning)
UM      Urban Medium-Density MFR-15
           Multiple-Family Res.
10–15 dwelling units per acre
UH       Urban High-Density MFR-20, MFR-30
           Multiple-Family Res.
20–30 dwelling units per acre
GI         General Industrial I-L       Light Industrial
I-G      General Industrial
Traded-sector manufacturing, fabrication, warehousing; some banking and restaurant allowed
HI         Heavy Industrial I-G      General Industrial
I-H      Heavy Industrial
Traded-sector manufacturing, fabrication, warehousing; some banking and restaurant allowed
PS        Parks & Schools No corresponding zoning Parks and schools

  • External Study Areas (ESAs). The second component involves extending the boundary itself. There is a system for doing this laid out in State Statutes and Rules that puts highest priority on the urban reserve, which the City obtained through the State's acknowledgement of the Regional Plan (through the Greater Bear Creek Valley Regional Problem Solving (RPS) process), followed by “exception” or nonresource lands, then marginal agricultural and forest resource lands, and—at the lowest priority—good agricultural and forest resource lands. “Exception” lands, generally, are those under County zoning that are commercial, industrial, or residential because they have been granted exceptions from the Statewide Planning Goals related to protecting agricultural and forest lands.
  • The City will be selecting a number of areas from the urban reserve to study for the effects of urbanization on streets and other utilities. The amount of land chosen will exceed the city's 20-year need so the analysis to give decision makers enough information to eliminate the excess.

  • Looking for the ESA map? Find it hereNote that the areas on the map exceed the City's 20-year need by about a thousand acres, but we cannot do a comparative analysis of expansion areas without considering an excess of land.



What law requires:

How Medford is doing it:


STEP 1: OAR 660-024-0050 (1)

“When evaluating or amending a UGB, a local government must inventory land inside the UGB to determine whether there is adequate development capacity to accommodate 20-year needs determined in OAR 660-024-0040.

Buildable Lands Inventory (2008)


“For residential land, the buildable land inventory must include vacant and redevelopable land, and be conducted in accordance with OAR 660-007-0045 or 660-008-0010, whichever is applicable, and ORS 197.296 for local governments subject to that statute.

Housing Element (adopted by the City; not yet acknowledged [approved] by the State Land Conservation & Development Commission)


“For employment land, the inventory must include suitable vacant and developed land designated for industrial or other employment use, and must be conducted in accordance with OAR 660-009-0015(3).”

Economic Element (2009)


STEP 2: OAR 660-024-0050 (4)

“If the inventory demonstrates that the development capacity of land inside the UGB is inadequate to accommodate the estimated 20-year needs determined under OAR 660-024-0040, the local government must amend the plan to satisfy the need deficiency, either by increasing the development capacity of land already inside the city or by expanding the UGB, or both, and in accordance with ORS 197.296 where applicable.

The City will be pursuing both tracks: internal changes to increase “development capacity” and expansion of the boundary. See the following two descriptions for more details.


“Prior to expanding the UGB, a local government must demonstrate that the estimated needs cannot reasonably be accommodated on land already inside the UGB.

A set of “Internal Study Areas” (ISAs) is being evaluated to determine places in the city that can be rezoned or upzoned to accommodate the land need. Staff will analyze areas that are being considered for capacity increases for impacts on infrastructure and livability. There will be general meetings/open houses for early public input.


“Changes to the UGB must be determined by evaluating alternative boundary locations consistent with OAR 660-024-0060.”

A set of candidate expansion areas will be evaluated for impacts on public facilities.


STEP 3: OAR 660-024-0050 (5)

“When land is added to the UGB, the local government must assign appropriate urban plan designations to the added land, consistent with the need determination.

Since the city is trying to meet the needs for different types of land (commercial, residential, industrial), General Land Use Plan designations will be proposed so staff can quantitatively show how Medford is meeting those needs.


“The local government must also apply appropriate zoning to the added land consistent with the plan designation, or may maintain the land as urbanizable land either by retaining the zoning that was assigned prior to inclusion in the boundary or by applying other interim zoning that maintains the land’s potential for planned urban development until the land is rezoned for the planned urban uses.

By common practice, the current County zoning will remain on all land included in the urban growth boundary until those lots and parcels annex into the city limits.


“The requirements of ORS 197.296 regarding planning and zoning also apply when local governments specified in that statute add land to the UGB.”



Planning Commission (PC)

Joint Transportation Subcommittee (acting as Citizens Advisory Committee) and Technical Advisory Committee (ad hoc) to evaluate material produced for the traffic impact analysis being funded by a Transportation and Growth Management grant from the State of Oregon.


Draft technical memoranda from traffic analysis can be found on a website set up by the traffic consultant, Kittelson and Associates: medfordtsp.com.



Who you can talk to

Questions about the UGB Amendment Project may be directed to Suzanne Myers, AICP, or John Adam, AICP, at
City of Medford Planning Department

200 South Ivy Street
Medford, Oregon 97501

Tel. 541.774.2380

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