On the agenda: Brookings meeting — Data Center (Sep 1)

City of Brookings

MEETING AGENDA
SPECIAL JOINT CITY COUNCIL/PLANNING
COMMISSION WORKSHOP
Tuesday, September 1, 2026, 6:00 pm
Emergency Operations Center, 888 Elk Drive, Brookings, OR 97415
A. Call to Order
B. Introductions
C. Topics

1. Housing Needs Analysis Update
a. Draft Housing Needs Analysis
D. Adjournment

All public City meetings are held in accessible locations. Auxiliary aids will be provided upon
request with at least 72 hours advance notification. Please contact 469-1102 if you have
any questions regarding this notice.

City of Brookings
Housing Needs Analysis
2026-2046
PRELIMINARY DRAFT FOR REVIEW
AUGUST, 2026

Acknowledgements

This study was prepared by Green Top Planning, Development, and Research (Green Top PDR) with the
City of Brookings. It was supported by funding from

A group of stakeholders generously commited their �me and though�ul opinions and guidance in the
development of this document:

STAKEHOLDERS
Hui Rodomsky, Oregon Department of Land Conserva�on and Development
Skip Watwood, Century 21 Agate Realty, Realtor and Property Manager
Diana Carter, CORE Response, Advocacy
Clayton Malmberg, Brookings City Council
Mayor Phoebe Pereda, City of Brookings
Sr. Cora Rose, Deaconess, St. Timothy Episcopal Church
Jeff Groom, CFO South Coast Lumber
Project Team
City of Brookings
Tim Rundell, City Manager
Wendy Giordano
Tony Baron, Public Works and Development Services Director
Lauri Ziemer
Green Top PDR
Nikki Hart-Brinkley, Principal and GIS Lead
Mat Brinkley, AICP, Principal and Urban Planning Lead

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Table of Contents

Executive Summary............................................................................................................................6
Population Growth.................................................................................................................................... 6
Affordability .............................................................................................................................................. 7
Changing Community ................................................................................................................................ 7
Housing Land Availability .......................................................................................................................... 8
Chapter 1: Community Profile ............................................................................................................9
Key Findings .............................................................................................................................................. 9
Historical Population Trend .................................................................................................................... 10
Future Population Trend ......................................................................................................................... 12
Income .................................................................................................................................................... 15
Age .......................................................................................................................................................... 16
Household Size ........................................................................................................................................ 18
Race and Ethnicity................................................................................................................................... 19
Housing Affordability .............................................................................................................................. 20
Homelessness ......................................................................................................................................... 23
People with Disabilities ........................................................................................................................... 25
Chapter 2. Residential Buildable Lands Inventory..............................................................................27
Key Findings ............................................................................................................................................ 28
Statutory Authority and Applicable Administrative Rules ...................................................................... 29
Methodology........................................................................................................................................... 29
Residential Land Base ............................................................................................................................. 30
Development Constraints ....................................................................................................................... 36
Development Status................................................................................................................................ 47
Chapter 3. Residential Lands Capacity Analysis .................................................................................53
Key Findings ............................................................................................................................................ 53
Past & Current Residential Development Patterns and Trends.............................................................. 55
Tenure ..................................................................................................................................................... 55
Current Housing Inventory ..................................................................................................................... 56
Regulated Affordable Housing ................................................................................................................ 57
Vacancy ................................................................................................................................................... 58
Age of Housing ........................................................................................................................................ 61
Recent Residential Development Trends................................................................................................ 63

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Residential Density.................................................................................................................................. 66
Projected Housing Demand .................................................................................................................... 69
Residential Land Capacity & Sufficiency ................................................................................................. 74
Chapter 4. Targeted Implementation Framework..............................................................................76
Summary ................................................................................................................................................. 76
Strategy 1 - System Development Charge Reductions ........................................................................... 76
Strategy 2 - Annexation Incentive Program ............................................................................................ 77
Strategy 3 - Middle Income Revolving Loan (MIRL) and Multiple Unit Property Tax Exemption (MUPTE)
................................................................................................................................................................ 79
Strategy 4 - Local Public Infrastructure Funding Options ....................................................................... 80
Strategy 5 - Land Development Code Audit............................................................................................ 82
Strategy 6 - Short term rental policy assessment ................................................................................... 83
Strategy 7 -Annexation and UGB Analysis .............................................................................................. 84
Strategy 8 - Homelessness Action Plan ................................................................................................... 85
Brookings Housing Needs Analysis - Appendix A ...............................................................................87
1. Introduction and Purpose ................................................................................................................... 87
2. Regulatory Framework and Data Crosswalk ....................................................................................... 87
3. Data Sources and Vintage ................................................................................................................... 88
4. Coordinate System and Measurement Conventions .......................................................................... 89
5. Tax Lot Base Preparation .................................................................................................................... 89
6. Zoning Attribution ............................................................................................................................... 90
7. Residential Land Identification ........................................................................................................... 90
8. Buildable Lands Classification ............................................................................................................. 90
9. Development Constraints Analysis ..................................................................................................... 91
9.1 Environmental and geologic constraints........................................................................................... 92
9.2 Slope constraints ............................................................................................................................... 93
9.3 Coastal constraints ............................................................................................................................ 94
10. Net Buildable Acreage....................................................................................................................... 94
11. Residential Density and Capacity ...................................................................................................... 94
12. Data Delivery and Public Access ....................................................................................................... 95
13. Limitations and Assumptions ............................................................................................................ 95
Brookings Housing Needs Analysis - Appendix B ...............................................................................97
A. Purpose and Statewide Planning Goal 1 Alignment ........................................................................... 97
B. Engagement Methods and Reach ....................................................................................................... 97
C. Participation Timeline and Response Drivers ..................................................................................... 99

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D. Who Responded ............................................................................................................................... 100
E. Most Significant Housing Challenges ................................................................................................ 100
F. Housing Types the Community Wants More Of ............................................................................... 101
G. Lived Housing Experiences ............................................................................................................... 102
H. Respondents’ Own Words ................................................................................................................ 102
I. Stakeholder Engagement Summary................................................................................................... 103
J. Community-Identified Priorities Informing the Targeted Implementation Framework ................... 106
K. Methodology and Data Notes........................................................................................................... 109

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Executive Summary

Although various studies and reports have addressed different aspects of housing in and around Brookings,
this is the first Goal 10 compliant Housing Needs Analysis undertaken by the City of Brookings for its Urban
Growth Boundary (UGB). Oregon’s statewide planning system requires that local jurisdic�ons ensure an
adequate supply of land for residen�al and employment development. For housing, statewide planning
Goal 10 charges locali�es with the responsibility to “provide for the housing needs of ci�zens of the state”
and to create plans that “shall encourage the availability of adequate numbers of needed housing units at
price ranges and rent levels which are commensurate with the financial capabili�es of Oregon households
and allow for flexibility of housing loca�on, type and density.” 1 A Housing Needs Analysis (also known as
a Housing Capacity Analysis) provides the technical founda�on for communi�es to develop policy that
addresses this responsibility.
But this study, produced over the course 5 months during 2026, is more than an exercise in regulatory
compliance: it represents a strong commitment within this community to plan for housing and address
challenges so that Brookings has enough of the right housing to meet the needs of its current and future
residents. To that end, it includes of an assessment of the factors that will drive demand for housing over
the next 20 years and examines the current state of housing and housing produc�on throughout the
Brookings Urban Growth Boundary. Finally, it offers a number policy ac�ons that may be taken by the City
of Brookings to address deficiencies and challenges.

Popula�on Growth
Brookings has experienced strong popula�on growth over the past 30 years, adding 2,348 new residents
by 2020. This represents a 30-year growth rate of 53.4%. Brookings has grown faster, and more steadily
than many other communi�es on the southern Oregon coast. More recently, however, popula�on growth
has slowed.
By some measures, Brookings’ future growth is forecasted to be slower than its historical growth. By 2046
(the end of the 20-year planning period), the total popula�on within Brookings Urban Growth Boundary
(UGB) will have reached 12,861, having added a total of 932 new residents since 2026—a nearly 8%
increase over 20 years. However, the Oregon Housing Needs Analysis (OHNA) has established much more
robust outlook for housing demand in the UGB. It has set a 20-year housing produc�on target of 1,915

1

OAR 660-015-0000(10) Goal 10 Housing

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homes within the Brookings UGB, or 118 units/year during the first decade of the target period. The largest
number of units are needed to meet demand for households earning 0-30% of Area Median Income and
households earning over 120% of AMI (27% and 26% of the total 1-year produc�on target, respec�vely).

Affordability
Affordability was the most common concern men�oned housing in public outreach: 82% of survey
respondents overall and 95% of self-iden�fied renters iden�fied it as their highest concern. Concern about
the availability of housing for the workforce was the second most expressed concern.
These insights are completely consistent with data analyzed in this study. According to data collected by
the US Census Bureau American Community Survey, renters in Brookings pay a Median Gross Rent of
$1,415, the most among regional peer communi�es and nearly as much as the statewide average. It is
important to frame this sta�s�c within the reali�es of the local housing market: while half of renter
households spend less than this, half spend more. According to data collected by the US Census Bureau
American Community Survey, nearly 40% of renter households in Brookings spend more than 30% of their
pretax household income on rent and basic u�li�es, and cost burden is much more pronounced in Harbor
where nearly 55% of renter households are cost burdened. The percentage of homeowner households in
Brookings that pay more than 30% of their pretax income toward housing is nearly 27%--higher than the
statewide average of 25%. These findings are consistent with insights received from members of the public
through surveys and at public outreach events, as well as members of the stakeholder group.

Changing Community
Respondents to public outreach efforts o�en characterized Brookings as an aging community, with an
influx of wealthier re�rees. As some commenters noted, this makes it more difficult for less affluent
residents, many of whom provide needed services to the en�re community, to find housing, which in turn
makes Brookings a less desirable place to live.
But Brookings is somewhat unique in that while it is growing older like much of Oregon, it con�nues to
have a rela�vely large cohort of school aged children. In fact, 185 of the 469 respondents to the survey
reported having school aged children in their household. While Brookings will con�nue to need larger
homes with yards that are o�en more appealing to families with children, Brookings will also need to plan
for more smaller units for a growing number of smaller households.
The rela�vely high percentage of individuals repor�ng at least one type of disability will also require
considera�on in planning for the future.
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Housing Land Availability
One of the primary tasks of a Housing Needs Analysis and Residen�al Buildable Lands Inventory is to
determine whether or not an Urban Growth Boundary has enough residen�al land to accommodate
expected popula�on growth. This is the point where technical analysis o�en runs into the limita�ons of
real world condi�ons. The Brookings UGB is es�mated to have 704 acres of developable residen�al land
in its UGB, enough to accommodate forecasted popula�on growth at 7, 10, 14, and 20 year periods.
The reality, however, is more complicated. Much of the capacity for housing development is located in the
Lone Ranch MPD. This master planned development area is en�tled for 1,000 dwelling units. The planned
unit mix is consistent with the findings of this study that more medium and higher density housing is
needed. The fact that Lone Ranch provides so much of the overall housing capacity within the Brookings
UGB emphasizes the importance of its �mely development.
The results of this study demonstrate that much of the future need for low and high density residen�al
development can be met between the Lone Ranch MPD and other developable residen�al land in the
Brookings city limits. Medium density residen�al land is, however, a different story. Outside the Lone
Ranch MPD, there are only 25 acres of medium density residen�al land available for development in the
Brookings city limits. This means that barring significant rezoning of exis�ng low density residen�al land
in the City of Brookings, an addi�onal 84 acres of medium density residen�al development will need to
occur in the unincorporated part of the UGB. This will likely require close coordina�on with Curry County
to ensure that sufficient medium density land remains available in the unincorporated UGB or that these
lands are annexed and subject to City of Brookings land use regula�ons.

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Key Findings
•

Chapter 1: Community Pro�ile

Brookings has experienced strong popula�on growth over the past 30 years, adding 2,348 new
residents by 2020. This represents a 30-year growth rate of 53.4%. Brookings has grown faster,
and more steadily than many other communi�es on the southern Oregon coast. More recently,
however, popula�on growth has slowed.

•

Brookings’ future growth is forecasted to be slower than its historical growth. By 2046 (the end of
the 20-year planning period), the total popula�on within Brookings Urban Growth Boundary
(UGB) will have reached 12,861, having added a total of 932 new residents since 2026—a nearly
8% increase over 20 years. Growth is forecasted to be fastest at the beginning of this period,
slowing considerably therea�er.

•

The Oregon Housing Needs Analysis (OHNA) set a 20-year housing produc�on target of 1,915
homes within the Brookings UGB, or 118 units/year during the first decade of the target period.
The largest number of units are needed to meet demand for households earning 0-30% of Area
Median Income and households earning over 120% of AMI (27% and 26% of the total 1-year
produc�on target, respec�vely).

•

At nearly $75,000/year, Brookings has the highest median household income among its regional
peers. A litle more than a third of households earn less than $50,000/year; another 30% of
households fall into the 80-120% income group earning between $60,000 and $90,000/year.
Consistent with the 20-year OHNA Housing Produc�on Target, 36% of households (a rela�vely
large percentage) fall into the “over 120%” group, earning $100,000 or more.

•

At $446,700 according to the 2020-2024 5-Year ACS Es�mate, Brookings has the highest home
value within its immediate area. According to actual home sales data, by the end of 2025 the
average monthly median sale price for a home in Brookings was $516,146.

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•

Renters in Brookings pay a Median Gross Rent of $1,415, the most among regional peer
communi�es and nearly as much as the statewide average. It is important to frame this sta�s�c
within the reali�es of the local housing market: while half of renter households spend less than
this, half spend more. Given this, it is unsurprising that housing cost burden is significant in and
around Brookings. The percentage of homeowner households in Brookings that pay more than
30% of their pretax income toward housing is nearly 27%--higher than the statewide average of
25%. Nearly 40% of renter households in Brookings are cost burdened, and cost burden is much
more pronounced in Harbor where nearly 55% of renter households are cost burdened.

•

Even with a median age that is 10 years older than the statewide median, Brookings has the
highest percentage of school aged children of any of its neighbors (nearly 18% of Brookings’
popula�on is under 18), including Crescent City. In terms of housing, this suggests that there will
be demand for single unit, detached housing with substan�al private outdoor space for some �me
to come.

•

According to 2025 Oregon Statewide Homelessness Estimates produced by the Oregon
Department of Housing and Community Services (OHCS), Curry County had a “County Homeless
Rate” of 8.6/1,000 residents, slightly higher than Coos County at nearly 7/1,000.

•

Rela�vely higher percentages of Brookings and Harbor residents report living with a disability. This
is consistent with the age profile for both communi�es, which is older than average, and
something that can be addressed through local housing policy.

Historical Popula�on Trend
Brookings has experienced strong popula�on growth over the past 30 years, adding 2,348 new residents
by 2020. This represents a 30-year growth rate of 53.4%, which exceeds the State’s growth rate during that
period, and is more than double the rate of growth for Curry County overall during that �me. Popula�on
grew much faster within Brookings city limits than it did in the unincorporated, urbanized community of
Harbor.
Over the past 30 years, Brookings has grown faster than its regional peers as well. Although Brookings and
Crescent City currently have similar popula�ons, Brookings growth has been more consistent over �me,
avoiding large fluctua�ons that Crescent City experienced between 1990 and 2000 when it lost 1,147
residents, and then again between 2000 and 2010 when it gained 3,755.

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Regional Peers Historical Popula�on, 1990 – 2020
Geography

1990

2000

2010

2020

Change
1990-2020

% Change
1990-2020

Oregon
Curry County, OR
Brookings city, OR
Harbor CDP, OR

2,842,321
19,327
4,396
2,294

3,421,399
21,137
5,363
2,688

3,831,074
22,364
6,336
2,391

4,237,256
23,446
6,744
2,551

+1,394,935
+4,119
+2,348
+257

+49.1%
+21.3%
+53.4%
+11.2%

Bandon city, OR
Coos Bay city, OR

2,297
15,108

2,880
15,443

3,066
15,967

3,321
15,985

+1,024
+877

+44.6%
+5.8%

Crescent City, CA

5,035

3,888

7,643

6,673

+1,638

+32.5%

Table 1-1: Regional Peers Historical Popula�on, 1990 – 2020. Data Source: US Census Bureau, 1990
rebased counts (compiled); 2000 DP1; 2010 SF1 P1; 2020 DHC DP1

In addi�on to data from the US Census Bureau, the Popula�on Research Center at Portland State University
(PSUPRC) produces annual “cer�fied” popula�on es�mates every year. This provides a more detailed
account of popula�on growth and decline, year-over-year. Over the past ten years, Brookings has
con�nued to grow, if not as quickly as it once did. Between 2015 and 2025, the PSUPRC es�mates that its
popula�on grew by 285 from 6,565 to 6,850. During the period, Brookings grew at an average rate of
0.52% annually. Over that same period, the State grew at a slightly faster rate, while Curry County overall
grew at an average rate of 0.43% annually. Regional peer Bandon experienced strong growth, adding 668
people at an average annual rate of 2.38% over those ten years. Coos Bay, by contrast, experienced a
nega�ve average annual growth rate of -0.15%, losing 266 of its residents over 10 years. 2
As shown in Figure 2, Brookings’ annual growth over the past decade has been modest but consistent. A
small spike can be seen in 2020, a 1.75% increase over 2019. That sudden increase is offset, however, by
a nega�ve growth rate of -1.20% in 2024. Both of these instances are likely to be anomalies atributable
to PSUPRC’s es�ma�ng methodology and not actual changes in popula�on.

The 10-year Average Annual Growth Rates were calculated by averaging annual growth rate PSUPRC
cer�fied popula�on es�mate data over a 10-year period.
2

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Regional Peers Certified Poplution Estimates
2015 - 2025
25,000

23,375

22,470

Curry County,
OR

20,000

Brookings city,
OR

15,000
10,000

6,565

6,850

6,921

Bandon city, OR

5,000

Coos Bay city,
OR

July 1, 2025

July 1, 2024

July 1, 2023

July 1, 2022

July 1, 2021

July 1, 2020

July 1, 2019

July 1, 2018

July 1, 2017

July 1, 2016

July 1, 2015

0

Figure 1-1: Regional Peers Popula�on, 2015 – 2025. Data Source: PSUPRC, Cer�fied Popula�on Es�mate
Tables, 2015, 2016, 2017, 2018, 2019, 2020, 2025

Future Popula�on Trend
Looking into the future, Brookings is projected to con�nue to grow, consistent with growth from 2015 –
2025. From the base year of 2026, Brookings’ popula�on is expected to grow by 478 over the next seven
years, the most robust growth of the longer 20-year planning period. Ten years from now, Brookings will
have added another 142 residents, bringing the popula�on within its UGB to 12,548. By 2040, another
144 residents will have been added, and in the final year of the 20-year planning period, the Brookings
UGB will reach a total popula�on of 12,861, having added a total of 932 new residents since 2026—a
nearly 8% increase over 20 years.

Brookings UGB PSUPRC Forecast, 2026 – 2046

Select Years
Forecasted Popula�on

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2026
11,929

2033
12,406

2036
12,548

2040
12,692

2046
12,861

Popula�on Change from Base Year
478
620
764
932
Average Annual Growth Rate from Base Year
0.57%
0.52%
0.46%
0.39%
Growth Rate from Base Year
4.00%
5.19%
6.40%
7.81%
Table 1-2: Brookings UGB Popula�on Forecast, 2026 – 2046. Data for years 7, 10, 14, and 20. Data
Source: Portland State University Popula�on Research Center, 2026 Preliminary Region 2 Forecast.
Popula�on Change, Average Annual Growth Rates, and Growth Rate from Base were calculated by Green
Top PDR.
Compared with its peers on Oregon’s south coast, Brookings is projected to experience stable, if modest
growth (Figure 1-2). It is expected to grow faster than Curry County as a whole, and faster than its smaller
regional incorporated peers, Gold Beach and Port Orford, which are projected to lose several hundred
residents. 3

*****

Regional Peers Population Forecast
2020* - 2045

All Curry County

30,000
24,592

23,512

25,000

Brookings UGB
Gold Beach UGB

20,000

Port Orford UGB

15,000
12,837

11,750

10,000
5,000

Outside UGB Areas
Bandon UGB

0
2020

2025

2030

2035

2040

2045

Coos Bay UGB

Figure 1-2: Regional Peers Popula�on Forecast. Data Sources: PSUPRC 2026 Preliminary Popula�on
Forecast; * PSUPRC Cer�fied Popula�on Es�mate

3

Crescent City is not included in PSU’s projec�on, and Harbor is included in the forecast for Brookings UGB.

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Accoun�ng for historic underproduc�on, the presence of second homes and short term rentals, and other
factors, the 2026 Oregon Housing Needs Analysis set a robust 20-year target of 1,915 homes for Brookings.
Assuming an average household size of 2.19 people per household (see “Household Composi�on”, below),
the 932 new residents forecasted by the PSUPRC 2026 Forecast equates (roughly) to 426 new homes over
the 20-year planning period. The difference between the PSUPRC forecast and OHNA housing produc�on
target demonstrates the significant influence of other factors on housing demand that are addressed by
the OHNA and not by the PSUPRC Forecast.
This produc�on target is further broken down into five (5) income groups (Figure 1-3) that align with
household income categories used in a number of housing produc�on programs such as Local Innova�on
Fast Track (LIFT), administered by Oregon Department of Housing and Community Services (OHCS).
Consistent with current income distribu�on data presented below, the largest propor�on of overall
housing demand is present at both ends of the income con�nuum with the lowest and highest income
households genera�ng the most demand (approximately 30 new units/year for each group).

Brookings UGB 2026 OHNA Housing Production Target
2,500
2,000

1,915

1,500
1,000
500
0

381
118
Total New Units
Needed

296
32

0-30% AMI

597

467
20

174

11

30-60% AMI

60-80% AMI

2026-2046

1 year

25
80-120% AMI

31
>120% AMI

Figure 1-3: Oregon Housing Needs Analysis, City of Brookings Annual Housing Produc�on Targets by
Standard Income Groups

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Income
At nearly $75,000/year (according to the American Community Survey, 2020-2024 5-year Es�mate),
Brookings has the highest median household income within the peer group, followed by Curry County as
a whole. The Brookings median income is somewhat lower than the statewide median household income.
Closer to home, median household income in Harbor is nearly $20,000 lower than in incorporated
Brookings, again sugges�ng poten�al unmet demand for housing that is affordable to middle- and lowerincome households.

Regional Peers Median and Mean Household Income

Geography

Median HH Income ($)

Mean HH Income ($)

Oregon
$83,011
$111,542
Curry County, OR
$62,244
$82,583
Brookings city, OR
$74,933
$91,223
Harbor CDP, OR
$55,109
$71,740
Bandon city, OR
$48,187
$73,767
Coos Bay city, OR
$56,524
$74,079
Crescent City, CA
$35,540
$60,544
Table 1-3: Regional Peers Median and Mean Income Comparison. Data Source Household Income,
American Community Survey, S1901, 2020-2024 5-Year
Table 1-4 shows income ranges for the “standard” income groups for Brookings as used by the Oregon
Housing Needs Analysis in its housing produc�on targets. A litle more than a third of households earn less
than $50,000/year, which roughly corresponds with the upper income threshold for the 60-80% AMI
income group. In other words, approximately 30% of households in Brookings earn less than roughly
$60,000 (80% of AMI).

Brookings Household Income by Standard Group

Standard Income Group
Upper Income Threshold for Group
0 – 30%
$22,480
30 – 60%
$44,960
60 – 80%
$59,946
80 – 120%
$89,920
>120%
∞
Table 1-4: Brookings Housing Income by Standard Household Income Group. Data Source Household
Income, American Community Survey, S1901, 2020-2024 5-Year. Calcula�ons by Green Top PDR.

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O�en referred to as “middle income”, another 30% of households fall roughly into the 80-120% income
group. Consistent with the OHNA Housing Produc�on Target, 36% of households (a rela�vely large
percentage) fall into the “over 120%” group.

Brookings (city)

Total
Households

%
Total Total Households by % Households by
Income Category
Income Category
Households

Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999

75
15
305
251
341
508
415

2.5%
0.5%
10.2%
8.4%
11.4%
17.0%
13.9%

$100,000 to $149,999

547

18.3%

$150,000 to $199,999
$200,000 or more

251
278

8.4%
9.3%

394

13.20%

591

19.80%

508
415

17.0%
13.9%

1,075

36.00%

Table 1-5: Brookings Detailed Income Distribu�on. Data Source: Household Income, American
Community Survey, S1901, 2020-2024 5-Year Es�mate

Age
At 50.6 years, Brookings is older than the statewide median, but considerably younger than Curry County
overall. Harbor, on the other hand, is significantly older than both with a median age of 68.2 years.

Median Age

Oregon
Curry County, Oregon
Brookings, Oregon
Harbor CDP, Oregon
Gold Beach, Oregon
Port Orford, Oregon
Crescent City, California

Median Age
40.4
57.7
50.6
68.2
54.7
62.7
38.4

Table 1-6: Median Age in Brookings and Area Communi�es. Data Source: 2020-2024 ACS 5-Year
Es�mates Detailed Tables, Table B01002

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Although median age provides a glimpse at an important demographic factor that affects housing need, a
closer look at age distribu�ons within these communi�es reveals a more complex picture.
Even with a median age that is 10 years older than the statewide median, Brookings has the highest
percentage of school aged children of any of its neighbors (nearly 18% of Brookings popula�on is under
18), including Crescent City. In terms of housing, this suggests that there will be demand for single unit,
detached housing with substan�al private outdoor space for some �me to come.
Brookings, however, has the lowest percentage of young adults (18-24). More young adults live in Harbor
in both propor�onal and absolute terms: nearly 12% of Harbor residents, 283 in total, are between 18 and
24. Members of this cohort may be in college or other post-secondary educa�on or training, and are more
likely to have lower incomes. They are less likely to be in a posi�on to own a home. As renters with lower
incomes, their housing preferences are likely driven by value more than any factor. This may explain why
a higher percentage of young adults live in Harbor, where average rents are lower, than in Brookings.
Brookings has a high percentage of adults between the ages 25 and 44—27% of its total popula�on. This
is consistent with the statewide average (28%), but much lower than Crescent City where 40% of the
popula�on falls into these age categories. Households at the younger end of this group (25 – 34) are o�en
entering the workforce, beginning careers, and forming families. Just as their lives are transi�oning into
adulthood, their housing preferences are evolving. They usually have not reached their highest earning
poten�al, and between limited opportuni�es to build personal savings and financial liabili�es like student
loan debt, they are much less likely to be in a posi�on to enter into homeownership. Wai�ng longer to
form family households, they may be less likely to need or desire larger homes with yards. By the �me
they enter the 35-44 age group, they are deeper into careers, benefi�ng from higher wages, and are more
likely to have younger children. All of these factors shi� housing preferences.
Nearly 27% of Brookings’ popula�on is aged 45 – 64. This is slightly higher than the statewide and county
averages. Fewer members of this age group live in Harbor, but they s�ll represent nearly 22% of Harbor’s
total popula�on. Individuals in this category are much more likely to have formed family households than
their younger counterparts and they have reached the period in their careers with the highest earning
poten�al. Those with school aged children are more likely to have the resources and desire to live in single
unit detached homes with yards. As they re�re and their children leave home, they may downsize, crea�ng
opportuni�es for younger households to move out of smaller units as they try to accommodate growing
families. In order for this occur, however, older households need to be able to find smaller units of their
own or leave the community altogether.

17 of 110

A larger propor�on of Brookings residents are re�rement age (65+) than the statewide average (26% vs.
19%), but the propor�on of individuals in this age group in Brookings is much smaller than Curry County
overall where nearly 37% of the popula�on is 65 or older. In Harbor, 56% of the popula�on are members
of this age group. More significantly, 25% of Harbor residents are at least 75. This is consistent with the
large difference in median household size between Brookings and Harbor.

35.00%

Age Cohorts for Brookings and Surrounding Communities

Oregon

30.00%
Curry County,
OR

25.00%
20.00%

Crescent City
city, CA

15.00%

Brookings city,
OR

10.00%
5.00%
0.00%

Harbor CDP,
OR
0-17

18-24

25-34

35-44

45-54

55-64

65-74 75-85+

Figure 1-7: Age Cohorts for Brookings and Surrounding Communi�es. Data Source: 2020-2024 ACS 5-Year
Es�mates Detailed Tables, Table B01002

Household Size
As Table 1-4 demonstrates, Brookings’ household size is comparable to other peer communi�es, but at
2.19 person per household, it is much larger than the average household size for Harbor (1.74). This
suggests that housing demand in Harbor may tend toward smaller units, which is consistent with age data
presented previously.

Geography
Oregon
Curry County, OR
18 of 110

Total Households
1,718,422
11,159

Median Household Size
2.42
2.07

Brookings city, OR
2,987
2.19
Harbor CDP, OR
1,388
1.74
Bandon city, OR
1,831
1.78
Coos Bay city, OR
6,978
2.21
Crescent City, CA
1,693
2.26
Table 1-4: Regional Peers Median Household Size. Data Source Household Income, American Community
Survey 2020-2024 5-Year Es�mate Table S1101.

Race and Ethnicity
The racial and ethnic composi�on of a community, like age, can influence housing demand and inform
housing policy. Housing affordability, for example, can impact different groups of people in different ways.
Changes in homeownership paterns may likewise occur within different racial and ethnic groups. A 2025
report by the Na�onal Associa�on of Realtors states that “While homeownership rates have improved
across all racial and ethnic groups over the past decade, some groups con�nue to lag behind.” 4 According
to the report, homeownership among white households in Oregon is slightly above the current overall rate
of homeownership na�onally (67% and 65.24%, respec�vely), while the rate of homeownership among
black Oregonians was 30%. 5 Asian households in Oregon reported homeownership rates close to the
na�onal average (62%). 6 Hispanic households have experienced significant growth in homeownership
na�onally. In Oregon, 47% of Hispanic households own a home. 7
Data from the American Community Survey demonstrates that Oregon, Curry County, Brookings, and
Crescent City are becoming increasingly diverse, although at different rates and in different ways. As
depicted in Figure 1-8, even as the percentages of most racial and ethnic minority groups have remained
stable since 2016, the percentage of the popula�on iden�fying as “some other” or “two or more races”
has grown quickly across the state and within the communi�es considered in this study, accoun�ng for
approximately 12% of the popula�on in Curry County, Brookings, and statewide. This change is par�ally
atributable to the way survey ques�ons are asked, but also represents actual demographic change.

4
5
6
7

2025 Snapshot of Race and Home Buying in America, Na�onal Associa�on of Realtors, p. 6
Ibid., pp. 10, 11
Ibid., p. 12
Ibid., p. 13

19 of 110

PERCENT OF POPULATION

100.0

Race and Ethnicity, 2016 - 2024

% White

80.0

% Black

60.0

% AIAN

40.0

% Asian
% NHPI

20.0
% Some other
0.0

% Two+ races

Figure 1-8: Race and Ethnicity for Brookings and Surrounding Area, 2016 - 2024. Data Source: 2012-2016
ACS 5-year Es�mate, Table DP05; 2020-2024 ACS 5-Year Es�mates Detailed Tables, Table DP05.
The number of individuals repor�ng Hispanic ethnicity has grown faster in Curry County overall than it has
in Brookings where it increased by 0.8% from the 2012-2016 5-year Es�mate to the 2020-2024 5-year
Es�mate. The percentage of Brookings’ overall popula�on repor�ng Hispanic ethnicity has however,
remained much higher than Curry County (nearly 11% and nearly 8%, respec�vely). Crescent City saw a
significant contrac�on in its Hispanic popula�on according to the ACS, shrinking from nearly 36% to 28%
between 2016 and 2024.

Housing Affordability
Housing affordability is, fundamentally, the rela�onship between two factors: the cost of housing and the
ability to pay for it. At $446,700 according to the 2020-2024 5-Year ACS Es�mate, Brookings has the highest
median home value within its immediate area (Table 9). It is only slightly lower than the state average, and
significantly higher than Curry County overall and Harbor, where the median home value is 70% of that in
Brookings city limits ($316,000). Brookings’ median home value is similarly high compared to Crescent City
($306,500).

20 of 110

Median home values reported by the Census Bureau are based on survey data, and do not reflect current
home sales prices. By the end of 2025, the average monthly median sale price for a home in Brookings
was $516,146 according to data from Redfin. 8 That is about $4,000 higher than the statewide Annual
Average Monthly Median Home Sale Price of $512,650. This represents a high point over the past 10 years
for both metrics. Figure 7 shows a steady and rela�vely steep price escala�on during that period when
prices increased by over $245,000 from an Average Annual Monthly Median for Brookings of $270,569 in
2015. Since 2015, home prices have increased at an annual average rate of 7%. The most significant
increases occurred between 2019 and 2020, and between 2021 and 2022 when the average annual
median monthly price rose by 13% during both periods.
Average Annual Monthly Median Home Sale Price

$600,000

516,146

$400,000

Oregon

$200,000

Brookings
2025

2024

2023

2022

2021

2020

2019

2018

2017

2016

2015

$0

Figure 1-9: Annual Average Median Monthly Home Sales Prices. Data Source: Redfin Data Center.
Calcula�ons and analysis by Green Top PDR.

Renters in Brookings pay the most among regional peer communi�es, nearly as much as the statewide
average (Table 1-5). According to the most recent available data from the Census Bureau, Median Gross
Rent is just over $1,400, while renters in Harbor pay nearly $1,200—similar to the Median Gross Rent for
Curry County overall and Crescent City.
Connec�ng cost and income, cost burden measures number of households that pay more than 30% of
their income toward housing costs. 9 The percentage of homeowner households in Brookings that pay

Redfin processes data collected from mul�ple lis�ng services and calculates a median home sale price for
each month. Green Top PDR averaged those data to calculate an “Average Annual Monthly Median Home Sale Price”
for each of the past 10 years, in other words the average price of a home for an en�re 12 month period. Averaging
the median home sales price is intended to remove seasonality and monthly anomalies.

8

Cost burden is the most commonly used measure of rental housing affordability but is o�en used as a more
generalized measure of housing affordability for homeowner housing as well. It compares housing cost with
household income, establishing an income to housing cost threshold of thirty percent (30%). If a household spends

9

21 of 110

more than 30% of their pretax income toward housing is higher than the statewide average of 25%, and
comparable with Curry County overall and Crescent City (between 26-28%). Home values in both Curry
County and Crescent City are significantly lower sugges�ng that households with lower incomes are,
perhaps, able to find homeownership opportuni�es that are rela�vely more affordable in those
communi�es. Homeownership in Harbor, however, appears to be less affordable with slightly more than
34% of homeowner households experiencing cost burden.
Geography
Median Home Value
% Owners Paying more than 30%
Oregon
$477,600
25.1%
Curry County, OR
$381,300
27.6%
Brookings city, OR
$446,700
26.7%
Harbor CDP, OR
$316,600
34.4%
Crescent City, CA
$306,500
25.96%
Table 1-5: Homeowners Housing Cost Burden. Data Source: American Community Survey, Tables B25140
and DP04, 2020-2024 5-Year Es�mate. Calcula�ons and analysis by Green Top PDR.

As is true throughout Oregon and the United States, cost burden in and around Brookings affects renter
households much more frequently than homeowner households. Fewer renter households are costburdened in Brookings than throughout the state and Curry County overall, but nearly 40% of renter
households in Brookings pay more than 30% of their pretax gross income toward housing costs. Cost
burden is much more common in Harbor where nearly 55% of renter households are cost burdened,
similar to Crescent City where 52% of renter households are cost burdened. In both of these communi�es,
Median Gross Rent is lower than it is in Brookings, and considerably lower than the statewide median, but
household incomes in Harbor and Crescent City are also compara�vely lower, demonstra�ng the powerful
impact of income on affordability.

Geography
Oregon
Curry County

Median Gross Rent
$1,525
$1,241

% Renters paying 30% or more of pretax income
49.5%
43.5%

more than 30% of its income on housing, it is said to be rent or cost burdened. There are many cri�cisms of cost
burden as a measure of affordability. It is thought to underes�mate the financial impact (burden) of housing costs
on the poorest households. Whatever the case, it remains a commonly used metric of housing affordability that uses
readily available public data. For more discussion see “Rental Burdens: Rethinking Affordability Measure”, HUD User
Office
of
Policy
Development
and
Research,
htps://www.huduser.gov/portal/pdredge/pdr_edge_featd_ar�cle_092214.html

22 of 110

Brookings
$1,415
39.0%
Harbor CDP
$1,190
54.8%
Crescent City
$1,192
52.3%
Table 1-6: Renter Housing Cost Burden. Data Source: 2020-2024 5-year American Community Survey
Es�mates, Tables B25140, calcula�ons and analysis by Green Top PDR.
Renter cost burden is experienced differently by renters in different income groups. Renter households
earning more than $75,000 (slightly more than 100% of Household AMI for Brookings) did not report cost
burden. At the other end of the income con�nuum, renters earning less than $35,000 (less than 50% of
AMI) report experiencing rent burden most of the �me (Figure 8).
Brookings Renter Cost Burden by Income Group

400

Renter households

350
300
250
200
150
100
50
0

Less than
$10,000

$10,000 to
$19,999

$20,000 to
$34,999
Affordable (<30%)

$35,000 to
$49,999

$50,000 to
$74,999

$75,000 to
$99,999

$100,000 or
more

Cost-burdened (>30%)

Figure 1-10: Brookings Renter Cost Burden by Income Group. Data Source: 2020-2024 5-year American
Community Survey Es�mates, Tables B25122, calcula�ons and analysis by Green Top PDR.

Homelessness
Although other factors contribute to and exacerbate homelessness, housing affordability and availability
are a primary cause. When lower and moderate-income households (those earning under 60% of median
household income) are faced with rent burden, they can experience housing insecurity. As men�oned
above, over 50% of renters in Crescent City and Harbor pay more than 30% of the pre-tax household
income toward housing. Although the rate of renter cost burden is lower in the City of Brookings and Curry
County overall, around 40% experience cost burden. For these households, sudden financial hardship and
life-changing events can cause them to lose their housing temporarily or for long periods of �me,
some�mes precipita�ng chronic homelessness.

23 of 110

Table 1-7, below, summarizes Point-in-Time (PIT) and Housing Inventory Counts. In Curry County, the vast
majority of homeless individuals surveyed during the PIT Count were unsheltered (93%), meaning that
they were living in a place “not meant for human habita�on”. 10

2025 Houselessness
County

Sheltered

Unsheltered

Total

Curry County

14

190

204

Coos County

140

315

455

Oregon (state total)

10,607

16,512

27,119

Table 1-7: 2025 Houselessness Es�mates. Data Source: 2025 Oregon Statewide Homelessness Es�mates,
January 2026, Oregon Housing and Community Services. Data includes Point-in-Time Counts and
Housing Inventory Counts.

According to 2025 Oregon Statewide Homelessness Estimates produced by the Oregon Department of
Housing and Community Services (OHCS), Curry County had a “County Homeless Rate” of 8.6/1,000
residents, slightly higher than Coos County at nearly 7/1,000.
High rates of homelessness are not uncommon among coastal coun�es: in 2025, Clatsop County had the
highest rate of homelessness at nearly 30/1,000, and Lincoln County had a rate of 12/1,000. As Figure 9
shows, Curry and Coos Coun�es have seen lower es�mates from highs in 2024, while es�mates for Clatsop
and Lincoln Coun�es have either leveled off or con�nue to grow. It is important to understand that
es�mates are based, in part, on Point in Time Counts (PIT) that are known to have limited accuracy due to
methodological varia�ons.

*****

10

As defined by Department of Housing and Urban Development

24 of 110

Estimate of Homelessness by County
2022 - 2025
Curry

1,400
1,200
1,000

Coos

800
600
400

127

200

133

341

Clatsop
204

Lincoln

2022

2023

2024

2025

Tillamook

Figure 1-11: Es�mate of Homelessness by County, 2022 - 2025. Data Source: Oregon Statewide
Homelessness Es�mates 2022, 2023, 2024, and 2025. 11 Analysis and data aggrega�on by Green Top
PDR.

Other data, including McKinney-Vento repor�ng by school districts, are used in the annual es�mates to
augment PIT counts, providing a more comprehensive picture of those experiencing different types of
houselessness. According to the 2025 Oregon Statewide Homelessness Es�mate, 93 school children in
Curry County were reported to have experienced some kind of homelessness (sheltered, unsheltered,
“doubled-up”, living in short term rentals, etc.) during the school year, a nearly 23% reduc�on from the
previous school year. 12

People with Disabili�es
Physical, emo�onal, and cogni�ve disabili�es influence demand for housing in a couple of different ways.
Homes can be designed and constructed to beter meet the needs of those with disabili�es. Mobility
challenges, for example, can be addressed with zero threshold showers, zero step entries, wider hallways

11

Ibid., PSU Homelessness Research & Ac�on Collabora�ve

12

Ibid, p. 47

25 of 110

that accommodate mobility devices, single story home designs, etc. As popula�ons age, these
considera�ons become more and more important.
Disabili�es can also increase vulnerability to housing instability and homelessness. People with intellectual
and developmental disabili�es, for example, are dispropor�onately represented among people
experiencing homelessness, especially chronic homelessness. 13
According to data from the American Community Survey 2024 5-Year Es�mate, the incidence of various
kinds of disabili�es is higher in the City of Brookings than it is na�onally or across Oregon. The percentage
of people with disabili�es in Harbor is even higher: at over 25%, the percentage of people with disabili�es
in Harbor is nearly double the na�onal average of 13%.

Percentage of Population w/ Disabilities
30.00%

25.10%

25.00%
20.00%
15.00%

20.40%
13.30%

15.50%

10.00%
5.00%
0.00%
United States

Oregon

City of Brookings

Harbor CDP

Figure 1-12: Percentage of People with Disabili�es. Data source: 2020-2024 5-year American Community
Survey Es�mates, Table S1810.

*****

Thurman et al, 2023. The Intersec�on of Intellectual/Developmental Disability and Homelessness From the
Perspec�ves of Service Providers, Qualita�ve Health Research, Volume 33, pages 1017-1029.

13

26 of 110

Chapter 2. Residential Buildable Lands Inventory

Oregon Statewide Planning Goal 10 requires that “Buildable lands for residen�al use shall be inventoried”
in order to support the provision of adequate housing throughout the State of Oregon. 14 A residen�al
buildable lands inventory (RBLI) provides an assessment of the current development status of lands that
are designated in a community’s comprehensive plan for residen�al use and/or zoned for that purpose.
Simply put, it iden�fies lands that are available for the development of new housing; lands that are already
developed and cannot accommodate addi�onal development; and lands that cannot be developed due to
various types of constraints. Importantly, the RBLI captures the development status of residen�al land at
one point in �me. Although BLIs could be constantly updated, as a part of a city’s comprehensive plan and
a founda�onal planning document they are sta�c.
In the context of long range comprehensive planning, the RBLI provides a founda�on for further
inves�ga�on of a community’s capacity to accommodate future popula�on growth. It is an essen�al
component of a Housing Capacity Analysis or Housing Needs Analysis, but does not itself assess the
number of homes that could be developed on lands it determines to be developable. Nor does an RBLI
propose policy interven�ons that may address deficiencies in the provision of housing for a community’s
current and future residents. The aforemen�oned tasks are undertaken in subsequent parts of this study.
The manner in which an RBLI is produced is largely prescribed by state statute and administra�ve rule. In
par�cular, administra�ve rules 660-008-0005, 660-008-0100, 660-024-0050, 660-038-0060, 660-0380070, as well as ORS 197A.270 and ORS197A.280, establish requirements and standards for RBLIs. For
example, lands that are described in an inventory as “par�ally vacant” are defined by rule. Rules were
translated into a series of geoprocessing tasks using industry standard geospa�al informa�on systems
so�ware, ESRI ArcPro. Resul�ng data is stored in a geodatabase, allowing for future analysis and
inves�ga�on. Despite the highly prescrip�ve nature of these rules, there are instances that require
discre�on and allow for the applica�on of local knowledge to determine whether a property is fully
developed or has capacity for addi�onal residen�al development.

14

OAR 660-015-0000(10)

27 of 110

Key Findings
•

The RBLI documented 4,870 individual proper�es in the UGB (City of Brookings and
unincorporated Curry County including Harbor) that are zoned for residen�al uses or currently
have a residen�al use despite not being zoned or planned for a residen�al use 15. These residen�al
proper�es cover 4,342 acres.

•

83% of residen�al proper�es in the UGB are fully developed or otherwise unbuildable 16. These
proper�es, however, cover only 59% of the total residen�al land in the UGB.

•

A�er accoun�ng for environmental development constraints, the RBLI documented 704 acres of
buildable residen�al land within the UGB or 16.2% of the 4,342 acres currently zoned for or in
residen�al use.

•

With nearly 500 acres, most residen�al land available for development in the UGB is vacant (70%
of the 704 developable residen�al acres). By comparison, the vacant, developable por�on of
par�ally vacant residen�al land (residen�al land with an exis�ng residence that is zoned to allow
residen�al uses) totals nearly 213 acres represen�ng about 30% of developable residen�al land in
the UGB.

•

Nearly 407 acres or 58% of all residen�al land available for development is located within
Brookings’ city limits. Land in the Lone Ranch Master Plan Area accounts for more than half of
this. The remaining 297 acres or 42% of all residen�al land available for development is located in
unincorporated Curry County.

•

Altogether, 2,459 acres of residen�al land are constrained by environmental condi�ons such as
steep slopes or the presence of wetlands and riparian areas. Steep slopes and related
environmental constraints represented the most prevalent and impac�ul environmental
constraint. Slopes 25% and steeper, for example, affected 1,621 acres of residen�al land in the
UGB.

Proper�es with an exis�ng residen�al use that are not zoned to allow residen�al use are included in the
inventory for the purposes of accoun�ng for current capacity of land within the Brookings UGB to accommodate
housing. These proper�es are not assumed to any addi�onal capacity to accommodate future popula�on growth.

15

Residen�al lands with no or rela�vely litle development that were mostly constrained by environmental
condi�ons or regula�ons were placed in the “Developed” category.

16

28 of 110

Statutory Authority and Applicable Administra�ve Rules
As men�oned above, the authority and standards for Residen�al Buildable Land Inventories can be found
in several places in state statute and administra�ve rule. ORS 197A.280(3)(b) requires ci�es with a
popula�on of less than 10,000 to “Inventory the supply of buildable land available within the urban growth
boundary to accommodate needed housing […].” OAR 660-024-0050(1) further clarifies that local
governments must create an inventory to “determine whether there is adequate development capacity to
accommodate 20-year needs […]”. The development capacity of lands in the inventory is analyzed
separately in Technical Memorandum 3: Residen�al Capacity.
Inventories consist of several different categories 17 of land where housing has or can be developed. These
include
1. Vacant
2. Par�ally vacant
3. Redevelopable
4. Developed
5. Unbuildable
OAR 660-024-0050 requires that the inventory is “conducted in accordance with OAR 660-008-0100 […]”,
which defines the required contents of the inventory and methods for crea�ng it. OAR 660-008-0100(2)
requires that an RBLI “document the amount of buildable land in each plan designa�on 18 that allows
residen�al use under clear and objec�ves standards […].” Residen�al land designated by a comprehensive
plan or land zoned to allow residen�al development are categorized and quan�fied below in the
“Residen�al Land Base” sec�on.

Methodology
Pursuant to the aforemen�oned statutes and administra�ve rules, the following methodology was used
to generate this RBLI:

OAR 660-024-0050(1) iden�fies the first three types of “development status” measured in this RBLI. “Developed”
and “Unbuildable” categories are described throughout OAR 660-008 and 660-038.
18
Although this rule men�ons comprehensive “plan designa�ons”, OAR 660-008-0005(7) provides a broader
defini�on that includes lands “zoned to allow residen�al use”. Zones are used in this RBLI for proper�es under city
and county jurisdic�on.
17

29 of 110

1. Create a residen�al “land base” consis�ng of all proper�es that are zoned to permit residen�al
development. 19
2. Remove otherwise developable residen�al land from the inventory that subject to natural hazards,
natural resource protec�ons, has steep slopes, is within a “100-year flood plain or floodway”, or
“cannot be provided with public facili�es.” 20
3. Determine the development status of these lands as “vacant”, “par�ally vacant”, “redevelopable”,
unbuildable/undevelopable, and developed. 21
4. Tabulate remaining residen�al land available for development.

Residen�al Land Base
All residen�al lands in Brookings’ UGB were considered in this RBLI. There are 2,694 acres (4.2 square
miles) in Brookings current city limits. However, its Urban Growth Boundary is nearly three �mes as large
with 7,740 acres (12 square miles). Within the UGB, there are more than 5,500 tax lots, of which nearly
4,900 have an exis�ng residen�al use or are zoned 22 residen�al, covering 4,342 acres of the Brookings
UGB.
All acreages in this study—tax lots, development constraints, jurisdic�onal boundaries and the UGB—were
calculated directly in GIS rather than drawn from published sources which report differing acreages for
both city limits and UGB. All layers were analyzed in the NAD 1983 HARN Stateplane Oregon South
coordinate system (FIPS 3602), interna�onal feet.
Based on es�mated density calcula�ons, each zone was then placed into Low, Medium or High density
categories depending on where they fell within the following ranges 23:
•

Low Density, eight (8) or fewer units/acre

•

Medium Density, nine (9) to 16 units/acre

•

High Density, more than 16 units/acre.

OAR 660-008-0100(2) requires that an RBLI must “document the amount of buildable land in each plan
designa�on that allows residen�al use under clear and objec�ve standards […]”.
19

20

OAR 660-008-0005(7)(a) –(e)

21

OAR 660-008-0005(7) iden�fies these categories of “buildable land”.

Some proper�es have mul�ple zones. So-called “split” zoned proper�es in this RBLI have a “primary zone”
that is residen�al.
23
Density ranges are consistent with OAR 660-038-0060(1)(b)(B)
22

30 of 110

These densi�es were calculated based on regula�ons and should not be confused with “observed
densi�es” described in the capacity sec�on of this HNA.
Zones that allow residen�al uses with clear and objec�ve standards 24 are iden�fied in Table 1. In the City
of Brookings, residen�al development is permited with clear and objec�ve standards in 15 zones,
including three commercial zones: Professional Office, General Commercial, and Tourist Commercial
where residen�al uses are only permited on second and higher stories. Zones where residen�al
development is permited through a discre�onary land use process (for example a Condi�onal Use Permit)
were not included in the inventory.

For the purposes of this RBLI, “clear and objec�ve” is understood to be synonymous with “permited” or
“permited by right”. Zones wherein residen�al uses or development are only allowed with a condi�onal use permit
or other discre�onary en�tlement were not considered to meet this standard.

24

31 of 110

Min. Lot Size Min. Lot Size Max. DU/unit Max. DU/acre RBLI
Density
Zone
(square feet) (Acre)
of land
(net)
Category
SR 20,000
20,000.00
0.46
1.00
2.18
Low
SR 40,000*
40,000.00
0.92
1.00
1.09
Low
R-1-6
6,000.00
0.14
1.00
7.26
Low
R-1-8
8,000.00
0.18
1.00
5.45
Low
R-1-10
10,000.00
0.23
1.00
4.36
Low
R-1-12
12,000.00
0.28
1.00
3.63
Low
R-MH-6
6,000.00
0.14
1.00
7.26
Low
R-MH-8
8,000.00
0.18
1.00
5.45
Low
R-MH-10
10,000.00
0.23
1.00
4.36
Low
R-MH-12
12,000.00
0.28
1.00
3.63
Low
R-2
6,000.00
0.14
2.00
14.52
Medium
R-3
6,000.00
0.14
4.00
19.36
High
PO-1
6,000.00
0.14
None
48.40
High
C-3
None
None
None
48.40
High
C-4
None
None
None
48.40
High
Table 2-1: City of Brookings Residen�al Zones and Maximum Es�mated Densi�es. Note: None of the
commercial zones sets a maximum residen�al density. For the purposes of the RBLI, maximum
residen�al density for these zones was es�mated by assuming that a three story mixed use building
could be built within the maximum height, covering 50% of a lot, with 900 square foot units.
* No proper�es with an SR 40,000 zone were iden�fied
Table 2-1 summarizes the residen�al land base using these regulatory density ranges. Most of Brookings
residen�al land base is zoned within the “Low” density range of fewer than eight (8) dwelling units/net
acre, with R-1-6 the single largest zone in terms of number of lots and area; R-MH is the smallest in area.

*****

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Jurisdic�on

Zone

Brookings
Brookings
Brookings
Brookings
Brookings
Brookings

R-1-10
R-1-12
R-1-6
R-1-8
R-MH
SR-20

Residen�al
Lots in Zone

Tax Total Area in Zone Residen�al Use
(Acres)
(Low/Med/High)

Category

51
26.09
Low
7
31.75
Low
1,736
630.05
Low
19
12.23
Low
49
10.03
Low
112
71.35
Low
1,974
781
Brookings
MPD
4
549.07
Medium*
Brookings
R-2
600
243.99
Medium
604
793
Brookings
C-3
40
10.71
High
Brookings
C-4
7
20.79
High
Brookings
PO-1
0
0.00
High
Brookings
R-3
216
128.28
High
263
160
Table 2-2: City of Brookings Residen�al Land Base by Zone. Data sources: City of Brookings, Curry County,
Lane Council of Governments. Calcula�ons and analysis by Green Top PDR.
* The MPD zone consists en�rely of the Lone Ranch planned community. Density was calculated at 7.94
DU/gross acre across the en�re plan area based on plans approved by the City of Brookings in 2006.

Table 2-3 further summarizes this data and provides comparisons to the total residen�al land use base
within Brookings’ city limits. A litle more than 45% of Brookings residen�al land base is located within
zones that permit residen�al development at low densi�es (under eight units/net acre). This slightly
underrepresents low density land in the overall inventory, because the Lone Ranch PUD includes a
significant low density residen�al component (540 planned single detached units on 93 net acres).
Likewise, although medium and high density residen�al land account for only 14% and 9% of the land
base, respec�vely, Lone Ranch is also planned to include 150 single atached units (medium density) on
11 acres and 310 units on 22 acres (high density). Lone Ranch’s overall planned residen�al density is nearly
eight (8) units/net acre, placing it in the medium density category.

Residen�al
Residen�al
%
Total
%
Total
Total Area in
Land Density Taxlots
in Residen�al
Residen�al Land
Category (Acres)
Category
Zone
Taxlots
Area

33 of 110

Low
Medium
Lone
Ranch
PUD
High

1,974
600

69.48%
21.12%

781
244

45.06%
14.07%

4

0.14%

549

31.66%

263
9.26%
160
9.21%
2,841
1,734
Table 2- 3: City of Brookings Residen�al Land Base Summary. Data Source: City of Brookings, Curry
County, Lane Council of Governments, calcula�ons and analysis by Green Top PDR.
These propor�onal shares of residen�al land are consistent with current housing inventory data reported
in TM1, which found that nearly 61% of Brookings households live in a single detached home; nearly 14%
live in a single atached home; roughly 16% live in middle housing (mul�-unit developments with fewer
than 10 units; and nearly 8% live in mul�-unit developments with ten units or more).
Residen�al lands in Brookings’ unincorporated Urban Growth Boundary (UGB) are also inventoried in the
RBLI. Most of these proper�es are located in the more densely developed Harbor area. Curry County has
ten (10) zones in Brookings’ unincorporated UGB that allow residen�al development with clear and
objec�ve standards (Table 4, Curry County Residen�al Zones and Densi�es).
RBLI Density
Category
R-1
6,000.00
0.14
7.26
Low
R-2
6,000.00
0.14
14.52
Medium
R-3
6,000.00
0.14
21.78
High
RCR-1
43,560.00
1.00
1.00
Low
RCR-2.5
108,900.00
2.50
0.40
Low
RCR-5
217,800.00
5.00
0.20
Low
RCR-10
435,600.00
10.00
0.10
Low
RR-5
217,800.00
5.00
0.60
Low
RR-10
435,600.00
10.00
0.10
Low
C-1
6,000.00
0.14
43.56
High
Table 2-4: Curry County Residen�al Zones and Maximum Es�mated Densi�es. Note: None of the
commercial zones sets a maximum residen�al density. For the purposes of the RBLI, maximum
residen�al density for these zones was es�mated by assuming the most dense housing type permited
that could reasonably be developed was built on a minimum sized lot or other regulatory unit of land. 25
Zone

Min. Lot Size (square feet)

Min. Lot Size (Acre) Max. DU/acre (net)

Table 2-5 summarizes the residen�al land base in the unincorporated por�on of the Brookings UGB using
these same regulatory density ranges. Low density cons�tutes the single largest part of the residen�al

For R-2 proper�es, a duplex was assumed to be developed on a 6,000 square foot lot as permited under
CCLDO 3.111; for R-3, it was assumed that an acre site was developed at the maximum allowed density of 1 dwelling
unit/2,000 square feet of site area as permited under CCLDO 3.154.

25

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land base in the unincorporated UGB in area, with the two lowest density zones (RR-5 and RR-10)
occupying more than 1,200 acres between them. To put that in perspec�ve, RR-5 and RR-10 lands cover
almost as much area as all of Brookings low density zoned land and the Lone Ranch PUD combined.

Residen�al Use
Total Area in Zone
Category
(Acres)
(Low/Med/High)
County
R-1
150
95.69
Low
County
RR-10
444
550.25
Low
County
RR-5
218
595.47
Low
812
1,241.41
County
R-2
959
811.03
Medium
959
811.03
County
C-1
99
125.41
High
County
R-3
81
118.56
High
180
243.97
County
C-2
6
3.92
N/A
County
FG
1
5.80
N/A
County
I
0
0.00
N/A
County
MA
0
0.00
N/A
County
MPA/FG
14
223.27
N/A
County
PF
6
3.13
N/A
County
RC
44
56.61
N/A
County
RI
1
16.81
N/A
Table 2-5: Curry County Residen�al Land Base Summary. Data Source: Curry County, Lane Council of
Governments. Geoprocessing, calcula�ons and analysis by Green Top PDR.
Jurisdic�on

Zone

Residen�al
Taxlots in Zone

The unincorporated UGB also has significant amounts of medium and high density lands with the R-2, R3, and C-1 zones. As Table X demonstrates, although the unincorporated UGB has large tracts of extremely
low density residen�al land (RR-5 has a density of 0.60 dwellings/net acre and RR-10 only 0.10
dwellings/net acre), a litle more than 35% of residen�al lands in the unincorporated UGB are zoned for
medium density and nearly 11% are zoned for high density residen�al development.
Residen�al development can be found in unincorporated parts of Brookings’ UGB on land with zoning
designa�ons that do not permit residen�al development with clear and objec�ve standards, such as Public
Facili�es (PF). In such cases, residen�al development is assumed to have been permited through a
discre�onary process like a Condi�onal Use Permit or is legally nonconforming. Unlike the residen�al land

35 of 110

base located inside the City of Brookings, several large areas of nonresiden�al zoned land were found to
have exis�ng residen�al development (over 223 acres and nearly 57 acres in the MPA/FG and RC zones,
respec�vely). Although proper�es in these zones with exis�ng residen�al development are assumed to
con�nue to accommodate exis�ng residen�al uses, lands with similar zoning are not assumed to provide
addi�onal capacity for future residen�al development and are not included in the RBLI.

Development Constraints
The ability to develop residen�al land is affected by a variety of condi�ons. Many of these are
environmental, including the presence of natural hazards iden�fied in a comprehensive plan or land use
regula�on, and environmentally sensi�ve lands like wetlands and riparian areas. Infrastructure adequacy
also influences whether and when residen�al land can reasonably be expected to develop. Each of these
condi�ons are considered in detail in the following.
•

Steep slopes. The City of Brookings applies addi�onal development regula�ons to lands with
slopes over 15%. These regula�ons are designed to reduce risks posed by development on
geologically unstable land. State administra�ve rules, recognizing these same concerns, allow
residen�al lands with slopes of 25% or more to be designated as constrained (undevelopable).
This RBLI generally follows this rule, except in instances where exis�ng residen�al lots have been
plated and are otherwise available for development. In these cases, it is assumed that
geotechnical condi�ons have been addressed through the land division process and local
regula�ons have been met.
Steep slopes and related environmental condi�ons affected more residen�al land than other type
of environmental constraint. This RBLI documents that 1,621 acres were found to be constrained
by slopes 25% and steeper. 26 Land characterized as highly or very highly suscep�ble to landslides,
which are coincident with steep slopes, were also evaluated as constraints. They affected 1,336
and 488 acres, respec�vely.
The Department of Geology and Mineral Industries (DOGAMI), which also provides the landslide
suscep�bility data above, maintains data that iden�fies 775 acres of land impacted by “rapidly
moving landslides”. Again, much of this area coincides with the steep slopes and landslide
suscep�ble lands.

Land with slopes 25% and steeper were measured in units of one (1) con�guous acre. In other words, slopes 25%
and steeper had to cover at least 1 con�guous acre in order to “constrain” land.
26

36 of 110

Each of these constraints is depicted individually in Figures 2,3, and 4.
•

Floodplains. OAR 660-008-0005(7)((d) iden�fies residen�al land impacted by “100-year flood
plain or floodway” as poten�ally unavailable or unsuitable for development. 203 acres of
residen�al lands are impacted by the presence of floodplains (known as the “Special Flood Hazard
Area or SFHA). This constraint is depicted in Figure 5.

•

Riparian Areas. Both the City of Brookings and Curry County protect riparian areas with minimum
setbacks or buffers wherein development cannot occur or is very restricted. Buffers range from 50
feet from the Top of Bank for smaller creeks in the City of Brookings to a 75 foot buffer along the
Chetco River. Riparian areas were found to constrain 196 acres of residen�al land in the UGB. This
constraint is depicted in Figure 6.

•

Wetlands. The Brookings UGB contains a range of different types of wetlands including estuarine,
riverine, and freshwater forested. Altogether, these environmentally sensi�ve features cover (and
constrain) 134 acres. This constraint is depicted in Figure 7.

•

Coastal Conserva�on. This is a protec�ve overlay zone administered by Curry County for lands
abu�ng the ocean south of the Chetco River. Development regula�ons in the overlay are very
restric�ve, only allowing a limited number of conserva�on and recrea�on related uses. The
overlay affects 88 residen�al proper�es, covering 9.6 acres of residen�al land. This constraint is
depicted in Figure 8.

*****

37 of 110

As men�oned previously, environmental constraints o�en coincide with one another and overlap. Land
with steep slopes may also be suscep�ble to landslides and may have floodplains. In order to avoid double
or even triple coun�ng these constraints, each these individual constraints were combined into a single
feature using geospa�al (GIS) so�ware (Figure 1). The resul�ng combined environmental constraints cover
and constrain 2,459 acres of residen�al land.

Environmental
Constraint

Area of Impact on
# of Residen�al % of Residen�al
% of Residen�al
Residen�al Lands
Proper�es
Proper�es
Land Impacted
(Acres)
Impacted (Taxlots)
Impacted

FEMA Floodway & 1%
Flood
202.8
4.67%
398
8.17%
Slope
25%+
(1-ac
blocks)
1,620.7
37.32%
1,787
36.69%
Landslide - High
1,335.5
30.75%
1,848
37.95%
Landslide - Very High
487.6
11.23%
429
8.81%
Estuarine/Marine
Deepwater
2.8
0.06%
35
0.72%
Estuarine/Marine
Wetland
35.3
0.81%
234
4.80%
Freshwater Emergent
Wetland
9.0
0.21%
15
0.31%
Freshwater
Forested/Shrub
15.5
0.36%
70
1.44%
Freshwater Pond
1.8
0.04%
2
0.04%
Riverine
69.4
1.60%
468
9.61%
Riparian Setback
196.5
4.52%
282
5.79%
Rapidly Moving Slides
774.5
17.84%
817
16.78%
County Conserva�on
Zone
9.6
0.22%
88
1.81%
COMBINED
(deoverlapped union)
2,459.1
56.63%
2,365
48.56%
Coastal
Erosion
(EXCLUDED
from
combined)
137.7
3.17%
311
6.39%
Table 2-6: Environmental Constraints Summary. Data source: Curry County, Lane Council of
Governments, City of Brookings, GTPDR, Na�onal Wetlands Inventory, DOGAMI, FEMA. Geoprocessing
and analysis by Green Top PDR.

38 of 110

Figure 2-1: Combined Environmental Constraints. Data Sources: Curry County, Lane Council of
Governments, City of Brookings, GTPDR, Na�onal Wetlands Inventory, DOGAMI, FEMA

39 of 110

Figure 2-2: Slopes 25% and Steeper. Data Sources: Curry County, Lane Council of Governments, City of
Brookings, Green Top PDR. Geoprocessing and analysis by Green Top PDR.

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Figure 2-3: Lands with High and Very High Landslide Suscep�bility. Data Sources: Curry County, Lane
Council of Governments, City of Brookings, Green Top PDR, DOGAMI. Geoprocessing and analysis by
Green Top PDR.

41 of 110

Figure 2-4: Lands with High and Very High Landslide Suscep�bility. Data Sources: Curry County, Lane
Council of Governments, City of Brookings, Green Top PDR, DOGAMI. Geoprocessing and analysis by
Green Top PDR.

42 of 110

Figure 2-5: Special Flood Hazard Area (SFHA). Data Sources: Curry County, Lane Council of Governments,
City of Brookings, Green Top PDR, FEMA. Geoprocessing and analysis by Green Top PDR.

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Figure 2-6: Riparian Setbacks. Data Sources: Curry County, City of Brookings, Green Top PDR.
Geoprocessing and analysis by Green Top PDR.

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Figure 2-7: Wetlands. Data Sources: Curry County, Lane Council of Governments, City of Brookings,
Na�onal Wetland Inventory, Green Top PDR. Geoprocessing and analysis by Green Top PDR.

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Figure 2-8: Coastal Conserva�on Zone. Data Sources: Curry County, Lane Council of Governments, Green
Top PDR. Geoprocessing and analysis by Green Top PDR.

46 of 110

Development Status
State statute and administra�ve rules define whether land is buildable or not for the purposes of a
Residen�al Buildable Land Inventory. OAR 660-008-0005 defines residen�al “buildable land” as
land designated or zoned to allow residen�al use within the planning boundary, including vacant land,
par�ally vacant land, and developed land likely to be redeveloped, that is suitable, available, and necessary
for the development of needed housing over a 20-year planning period.
In addi�on to larger, open tracts of land that are more obvious candidates for development, ci�es must
also account for residen�al land that could be further developed, even if that is unlikely to occur. The
“suitability” or “availability” of residen�al land for development is determined based on the presence of
exis�ng development and environmental and other constraints or factors that may discourage or even
prevent development.
Par�ally vacant residen�al proper�es were reviewed one-by-one to address unique circumstances
affec�ng how much developable land might be available.

BLI Status

# Tax % of Total Total Area % of Total UGB Developable
Lots
Tax Lots
(Acres)
Residen�al Acres
Acres

% of Total
Res. Acres

Vacant
469
9.63%
1,312.3
30.22%
488.5
11.2%
Par�ally Vacant
214
4.39%
357.6
8.24%
212.5
4.9%
Redevelopable
1
0.02%
2.6
0.06%
2.6
0.1%
Undevelopable
160
3.29%
99.0
2.28%
0.0
0.0%
Developed
4,022 82.59%
2,550.8
58.74%
0.0
0.0%
Not Applicable
4
0.08%
20.0
0.46%
0.0%
Total
(all
residen�al
+
redevelopable)
4,870 100.00%
4,342.4
100%
703.7
16.2%
Table 2-7: Brookings UGB RBLI Status Summary. Data sources: Curry County, Lane Council of
Governments, City of Brookings, GTPDR, Na�onal Wetlands Inventory, DOGAMI, FEMA. Geoprocessing
and analysis by Green Top PDR.

The outcome of this review places residen�al proper�es into one of the following categories:
•

Developed. Consistent with OAR 660-008-01000(5)(b), residen�al proper�es smaller than 0.50
acres that have an exis�ng dwelling are considered “fully developed”. In addi�on, residen�al

47 of 110

proper�es with exis�ng dwellings 0.50 acres and larger may be classified as developed when the
property is encumbered by “ancillary” development (driveways and other pavements, accessory
structures, swimming pools and sports courts). The inventory documented 4,022 developed
residen�al proper�es in the UGB, covering 2,550 acres. As “developed” residen�al lands, it was
determined that they did not have any remaining capacity for further development by land
divisions or development of addi�onal units on the same lot. 27 Residen�al proper�es in this
category represent more than 83% of residen�al proper�es in the UGB and nearly 59% of the total
area occupied by residen�al land within the UGB (Table 7).
•

Vacant. These are residen�al proper�es with no structures or structures with very litle value. For
example, an acre of undeveloped residen�al zoned land with a small shed would be considered
“vacant”, able to be further developed.
In terms of both the number of proper�es and their overall acreage, the number of vacant lots in
UGB is small rela�ve to the number of and areal extent of developed residen�al lands: 469 tax
lots, covering 1,312 acres (30% of all residen�al lands within the UGB) were found to be vacant.
Of this, only 488.5 acres were found to be free from the environmental constraints discussed
above and suitable for development. Residen�al proper�es in this category represent just under
10% of residen�al proper�es in the UGB (Table 7) and just over 11% of the total area zoned or
used as residen�al land within the UGB (Table 7). Vacant designated land also cons�tutes nearly
70% of the 704 developable residen�al acres available in the UGB.

•

Par�ally Vacant. These are residen�al proper�es “with exis�ng development […] where the
remaining, unconstrained land area can be further developed within the applicable development
regula�ons.” 28
OAR 660-008-0100(5)(a) allows ci�es with a popula�on of no more than 25,000 (like Brookings)
to apply a safe harbor when calcula�ng the amount of addi�onal development that may occur on
a residen�al property with an exis�ng dwelling that is larger than 0.50 acres. This RBLI applies this
method, removing 0.25 acres for the exis�ng dwelling and designa�ng the remaining
unconstrained land as developable. Land is considered to be unconstrained when it is free from
environmental and other constraints discussed above. For example, a one-acre residen�al
property with an exis�ng home is assumed to have 0.75 acres available for further development

27
28

This does not include accessory dwelling units (ADUs).
OAR 660-008-01000(38)

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(1 acre – 0.25 acres for the exis�ng home = 0.75 acres). If, however, 0.25 acres are located within
a riparian setback, only 0.50 acres are considered to be available and suitable for further
development (some�mes known as “infill” development), because 0.25 acres are “constrained”.
Across the en�re UGB, only 214 tax lots covering 358 acres were determined to be par�ally vacant.
Residen�al proper�es in this category represent a litle over 4% of residen�al proper�es in the
UGB (Figure 10) and a litle over 8% of the total area designated as residen�al land within the UGB
(Figure 11).
The vacant por�on of these par�ally vacant proper�es that is free from environmental constraints
and available for development covers nearly 213 acres or just under 5% of developable residen�al
lands within the UGB.
•

Undevelopable/Unbuildable. These are lands that may be zoned to allow residen�al
development, but are not “available” or “suitable” for residen�al development because they are
publicly owned or in public use, or are otherwise constrained by site characteris�cs or regulatory
restric�ons that prevent development.

In addi�on to analysis of the RBLI database, the consultant also “coordinated with public en��es on any
publicly owned land” to determine if any might be available for residen�al development.
In the UGB, 160 proper�es, covering roughly 99 acres, were determined to be unbuildable for the reasons
described above. None of this land is considered to be developable. Proper�es in this category represent
nearly 3.3% of all residen�al proper�es in the UGB (Figure 10) and just over 2% of the residen�al land area
within the UGB (Figure 11).
•

Redevelopable. Redevelopable proper�es are those that can reasonably be expected to transi�on
to residen�al use or to a more intensive residen�al use over the planning period. Determining this
status is highly dependent on local knowledge of the unique characteris�cs affec�ng individual
proper�es. Only one commercial 2.6 acre property was placed in this category. Separate from the
inventory, the poten�al to redevelop commercial proper�es is evaluated further in the subsequent
capacity analysis.

Figure 2-9 illustrates the development or buildable status of residen�al land in the Brookings UGB.

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Figure 2-9: Residen�al Buildable Lands Inventory, Development Status. Data Sources: Curry County, City
of Brookings, Lane Council of Governments, Green Top PDR. Geoprocessing and analysis by Green Top
PDR.

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Development Status by Area (Acres)

Development Status by Tax Lots

Vacant;
1,312.3;
31%

Vacant; 469;
10%
Developed;
4,022; 83%

Developed;
2,550.8;
59%

Partially
Vacant;
214; 4%

Partially
Vacant;
357.6;
8%

Redevelopable;
1; 0%
Undevelo
pable;
99.0; 2%

Undevelopabl
e; 160; 3%

Redevelo
pable;
2.6; 0%

Figures 2-10 & 2-11: Residen�al Lands Development Status by Number of Proper�es and Area. Data
Sources: Curry County, City of Brookings, Lane Council of Governments, Green Top PDR; analysis by
Green Top PDR.
Altogether, the RBLI documented 704 acres of buildable residen�al land within the UGB or approximately
16% of the 4,342 acres currently zoned or in residen�al use within the UGB. As shown in Figure 12, 58%
of the total area of buildable residen�al land is located within the current city limits, while the remainder
is in unincorporated part of the UGB.

411 acres ; 58%
293 acres; 42%

Inside City Limits

County (within UGB)

Figure 2-12: Developable Residen�al Land Summary by Jurisdic�on. Data Sources: Curry County, City of
Brookings, Lane Council of Governments, Green Top PDR; analysis by Green Top PDR.

51 of 110

52 of 110

Chapter 3. Residential Lands Capacity Analysis

Key Findings
•

Housing development in the Brookings UGB has fluctuated over the years. Consistent with
historical popula�on trends, residen�al development in Brookings was highest in the period from
1990-1999 when, according to ACS data, nearly 950 dwelling units were constructed (almost 30%
of its exis�ng housing). Harbor, likewise, has newer housing stock, experiencing significant
development in the first decade of this century when 266 units were constructed (nearly 18% of
its exis�ng housing) over that 10 year period.

•

Average densi�es (the number of units/acre of residen�al zoned land) tend to be much lower than
the maximum densi�es allowed within each zone. R-1-6, for example is the most prevalent
residen�al zone in the City of Brookings, with 1,561 dwelling units on 504 acres. Although this
zone allows the densest single unit detached development in Brookings, it has been developed at
densi�es far below the maximum: 3.1 dwelling units/net acre.

•

Historical residen�al development paterns, which have tended toward lower density residen�al
development, will need to shi� in order to accommodate the community’s changing needs. These
needs are driven by demographic trends and the need for housing that is affordable to lower and
moderate income households. Development of more middle and higher density housing will be
needed to match projected demand over the next 20 years.
Although historical residen�al development paterns have tended toward the lower end of
permited densi�es, recent residen�al development has shi�ed toward higher permited
densi�es. This suggests emerging market alignment with the need for more medium and higher
density housing op�ons.

•

The City of Brookings has a vacancy rate of around 9%, about 300 dwelling units, which is rela�vely
high. Although higher vacancy rates can indicate so�er demand for owner and renter occupied
housing, that is probably not the case here. In Brookings, the reason for higher vacancy is likely to
be the result of second homes, that are seasonally or “recrea�onally” occupied, and short terms
rentals. Data suggests that vacancy may dispropor�onately impact the inventory of housing types
which might otherwise provide affordable market rate ownership and rental opportuni�es for
middle income households.

53 of 110

•

There is sufficient developable residen�al land available throughout the UGB to meet forecasted
housing demand over the next 20 years, and the intervening 7, 10, and 14 year intervals. Much of
this capacity is, however, provided by housing planned for the Lone Ranch MPD, which provides
enough capacity for low, medium, and high density residen�al development to meet the 20 year
need for low and high density residen�al development with its boundary. This emphasizes the
urgency of realizing the development poten�al of the Lone Ranch MPD.

•

Even with this planned capacity provided in the Lone Ranch MPD, there is a need for medium
density residen�al land elsewhere, which can be met across the remainder of the UGB. However,
only a litle over 25 acres of medium density land are available for development within the City of
Brookings, leaving 84 acres of needed medium density residen�al land in the unincorporated UGB.
This presents prac�cal challenges as medium density development may be less likely to occur in
the unincorporated UGB where there is less access to public infrastructure capable of suppor�ng
development at those densi�es.

******

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Past & Current Residen�al Development Paterns and Trends
Tenure
Historically, homeownership has been a goal for many households. It has been a vehicle for
intergenera�onal wealth accumula�on and transfer. Significant economic events like the Great Recession
and ensuing foreclosure crisis challenged some of those assump�ons. Meanwhile, changing
demographics, shi�s in consumer preferences among members of Genera�on Z, and the diminishing
affordability of homeownership have made ren�ng more atrac�ve.
The share of renters and homeowners in Brookings aligns with statewide and na�onal averages, and is
consistent with other communi�es throughout the larger region—roughly 60% homeowners to 40%
renters. Curry County overall, however, has a much higher percentage of homeowners with a 75% to 25%
split. This is most likely due to the prevalence of single detached homes outside of ci�es in unincorporated
rural areas. Although the percentage of homeownership is not quite as high in Harbor, at nearly 67%
homeownership is more prevalent in Harbor than in incorporated Brookings. Crescent City, in contrast, has
an unusually high percentage of renters with a 32% to 68% split between homeowners and renters.
Regional Peers Housing Tenure
Occupied
Units
1,718,422

OwnerOccupied
1,087,983

RenterOccupied
630,439

%
Owner
63.3%

%
Renter
36.7%

Oregon
Curry County,
11,159
8,276
2,883
74.2%
25.8%
OR
Brookings
2,987
1,787
1,200
59.8%
40.2%
city, OR
Harbor CDP,
1,388
926
462
66.7%
33.3%
OR
Bandon city,
1,831
1,158
673
63.2%
36.8%
OR
Coos Bay city,
6,978
4,192
2,786
60.1%
39.9%
OR
Crescent City,
1,693
547
1,146
32.3%
67.7%
CA
Table 3-1: Regional Peers Housing Tenure. Data Source: American Community Survey 2020-2024 5-Year
Es�mate, Tables DP04

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Current Housing Inventory
Single-detached homes are the most common housing type in Brookings. Of the approximately 2,990
occupied homes documented in the most recent American Community Survey 5-year Es�mate (ACS), a
litle more than 1,800 are single detached (almost 61% of the total). This is consistent with data collected
from Curry County Assessor records, which documents 1,757 total dwelling units in “Low Density” zones
in the City of Brookings. According to ACS data, nearly 90% (1,621) of these are occupied by homeowners.
At almost 14% of its housing inventory, Brookings has a rela�vely high percentage of “single-atached”
homes (the statewide average is around 5%). More commonly known as townhomes, this development
type is characterized by small private front and rear yards and at least one shared wall between units.
Most of these units are renter occupied, according to ACS data.
Middle housing types (duplexes, triplexes, small apartment buildings or complexes with fewer than 10
units) account for over 16% of all homes—similar to the number townhomes. The most common subtype
within this group are tri and quadplexes, accoun�ng for 142 of the 486 middle housing units. These homes
too are mostly renter occupied.
There are 237 units in larger, mul�-occupant residen�al buildings and complexes with ten or more units,
represen�ng almost 8% of all dwelling units in Brookings. Only 11 of these were owner-occupied; the
remaining 226 were renter occupied. Interes�ngly, the number of dwelling units in larger mul�unit
buildings or developments roughly corresponds with the number of regulated affordable housing units
available (see “Regulated Affordable Housing” in the next sec�on below).
Finally, manufactured housing in Brookings represents only 1.37% of total units. This is well below the
statewide average of 5.70%, and contrasts significantly with Curry County overall and Harbor where
manufactured housing accounts for almost 20% and over 46%, respec�vely.

56 of 110

Total Units by Housing Percentage
Type
Total

Housing Type

of

Owner

Renter

Single-Detached
1,814
60.73%
54.27%
6.46%
Single-Atached
409
13.69%
2.44%
11.25%
Middle
486
16.27%
2.14%
14.13%
Higher Density (10+)
237
7.93%
0.37%
7.57%
Manufactured
41
1.37%
0.60%
0.77%
Other
0
0.00%
0.00%
0.00%
Table 3-2: Brookings Housing Inventory by Tenure: American Community Survey 2020-2024 5-Year
Es�mate, Table B25032

1.37%

Brookings Housing Types
Percentage of Total Units

7.93%

Single-Detached
16.27%

13.69%

Single-Attached

60.73%

Middle
Higher Density (10+)
Manufactured

Figure 3-1: Brookings Current Housing Mix. Data Source: American Community Survey 2020-2024 5-Year
Es�mate, Table B25032

Regulated Affordable Housing
Table 3-3 iden�fies all “regulated” affordable housing available in the City of Brookings, according to the
State of Oregon affordability housing inventory database. Regulated affordable units are required to be
affordable to households at or below different households at income levels. This is o�en achieved through
deed restric�ons and ongoing program management and monitoring.

57 of 110

Affordability requirements are o�en condi�ons of different types of funding that are available to support
the development of this type of housing. Programs include federal Low Income Housing Tax Credits
(LIHTC), state of Oregon Local Innova�on and Fast Track (LIFT), and a range of other programs administered
by the na�onal Department of Housing and Urban Development (HUD).

Property Name
Heron Ridge Apartments
Jerstad Manor
Pelican's Perch
Pacific View Gardens II
Ocean Winds
Pacific View Gardens I
Maple Leaf
Azalea Reach Apartments

Total Units
36
24
24
19
40
16
5
40
204
Table 3-3: Regulated Affordable Housing, Brookings UGB. Data Source: Oregon Department of Housing
and Community Services (OHCS), Oregon Affordable Housing Inventory,
htps://data.oregon.gov/dataset/Oregon-Affordable-Housing-Inventory/p9yn-�ai/data_preview.

Vacancy
Vacancy rates can be used to assess whether local housing markets are balanced between supply and
demand. As a prac�cal mater, enough housing needs to be available at any given �me in order to
accommodate people searching for new places to live. At a higher, macroeconomic level, adequate
supplies of available housing moderate rapid infla�on in rents and sales prices.
Of the es�mated 3,296 total dwelling units in the City of Brookings, a litle more than 9% were unoccupied
according to the 2020-2024 American Community Survey 5-year Es�mate. This is consistent with historical
averages and more recent data available from private sources, which show vacancy closer to 10 or 11%.
In either case, over 300 units in Brookings are unoccupied (Table 3-4).

*****

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Brookings
Total Housing
Units:
3,296
Occupied
Units

Harbor

Vacant Units

% Vacant

2,987
309
Occupied
Vacant Units
Units
by
by Category
Category

9.38%
% Vacant
by
Category

1,496
Occupied
Units

Vacant Units

% Vacant

1,388
108
Occupied
Vacant Units
Units
by
by Category
Category

7.22%
% Vacant
by
Category

1-unit,
1,814
95
5.24%
564
30
5.32%
detached
1-unit,
409
115
28.12%
18
0
0.00%
atached
486
99
20.37%
60
0
0.00%
2-9 units
10 or more
237
0
0.00%
106
43
40.57%
units
Mobile home,
Boat, RV, Van, 41
0
0.00%
640
35
5.47%
etc.
Table 3-4: Housing Vacancy for Brookings and Harbor. Data Source: American Community Survey 20202024 5-Year Es�mate, Table B25136. Calcula�ons by Green Top PDR.

Although higher vacancy rates can indicate so�er demand for owner and renter occupied housing and
exert downward pressure on the cost of housing, higher vacancy rates may be an aberra�on and may not
presage a so�ening market and lower costs. Reasons for vacancy can include a home being for sale or rent,
seasonal occupancy (status as a second or vaca�on home), or inability to be occupied, but for Brookings
the reason for higher vacancy is likely to be the result of seasonal or recrea�onal occupancies. The 20202024 ACS 5-year Es�mate iden�fied 100% of vacant units as “For seasonal, recrea�onal, or occasional use”.
This number seems unrealis�cally high, but the previous ACS 5-year Es�mate (2019-2023) placed 80% of
vacant units in that category. Given Brookings’ status as a vaca�on des�na�on, it is reasonable to conclude
that a large percentage of vacant units are vacant because they are seasonally occupied, second homes or
short term rentals (STRs).
Like second homes, short-term rentals are not available to the long-term resident market. The City
authorizes whole-dwelling short-term rentals through Condi�onal Use Permits, and its registry records 70

59 of 110

ac�ve STR CUPs. 29 The number of STRs rose rapidly during the early 2020s but has held roughly steady
since 2023, as a modest number of new approvals each year has been largely balanced by permits leaving
the pool through owner-ini�ated inac�va�on, sale, or abandonment. Because a Condi�onal Use Permit
remains in force through annual registra�on rather than expiring, the ac�ve inventory is cumula�ve and,
at present, stable rather than expanding.
A small number of bed-and-breakfast and homestay opera�ons, eight in the current registry, are excluded
from this count. These are owner-occupied uses authorized as home occupa�ons rather than through the
Condi�onal Use Permit process. Because the operator con�nues to reside in the dwelling while ren�ng
individual rooms, the unit remains occupied as housing and is not withdrawn from the long-term supply.
Only whole-dwelling STR permits are counted here.
The vacancy rate in Brookings’ UGB (the City of Brookings in par�cular) does not impact all types of housing
equally. In both Brookings and Harbor, however, single detached homes (which represent the single most
common housing type in both communi�es) had the lowest vacancy rates—both just slightly over 5%,
which is s�ll nearly five �mes the na�onal average. 30 Harbor’s overall vacancy rate is lower than Brookings,
just over 7%. Vacancy rates for its single detached and manufactured homes are virtually iden�cal with
one another and that of Brookings at around 5.5%. Mul�unit buildings and developments with more than
10 units in Harbor had a very high vacancy rate of nearly 41%. This may be due to the fact that high density
housing in Harbor may be predominantly short term rental (STR) and/or seasonally occupied. Unlike the
City of Brookings, Curry County does not regulate short term rentals, so accurate informa�on about the
extent of STRs and seasonally occupied units is not available. In the City of Brookings, data shows a
rela�vely high vacancy rate for townhomes and middle housing units. This suggests that the high vacancy
rate, which is likely atributable to second homes and short term rentals, dispropor�onately impacts the
inventory of housing types which provide affordable market rate ownership and rental opportuni�es for
middle income households.

Source: City of Brookings Short-Term Rental Registry, current as of April 4, 2026. A small share of exited
permits carry no recorded end date, so counts for individual past years are approximate; the current ac�ve total is
firm.
30
The average vacancy rate for owner occupied homes na�onally was 1.2% at the end of the second quarter
in
2026
according
data
collected
by
the
Federal
Reserve
Bank
of
St.
Louis:
htps://fred.stlouisfed.org/series/RHVRUSQ156N
29

60 of 110

Age of Housing
The age of a community’s housing stock is o�en correlated with its overall condi�on. This informa�on can
shape policy intended to enable homeowners and landlords to maintain residen�al proper�es in good
condi�on and reduce long term costs of ownership and occupancy that are usually passed on to renters
or absorbed by homeowners. For example, homeowners and renters alike may enjoy greater long term
affordability in a home that has recent energy efficiency improvements.
Age of Housing Inventory
35.0%
30.0%
25.0%
20.0%
15.0%
10.0%
5.0%
0.0%

Oregon

Brookings city, OR

Harbor CDP, OR

Figure 3-2: Brookings Current Housing Mix. Data Source: American Community Survey 2020-2024 5-Year
Es�mate, Table DP04
Brookings’ housing stock is rela�vely new compared to the statewide average. Consistent with historical
popula�on trends, residen�al development in Brookings was highest in the period from 1990-1999 when,
according to ACS data, nearly 950 dwelling units were constructed (almost 30% of its exis�ng housing).
Harbor, likewise, has newer housing stock, experiencing significant development in the first decade of this
century when 266 units were constructed (nearly 18% of its exis�ng housing) over that 10 year period.
Since its peak in the 1990s, construc�on of new homes in the City of Brookings has fallen steadily and
sharply: according to ACS data, only 16 homes were constructed during the period between 2020 and
2025. Although this figure, which is based on sample data with a significant margin of error, is lower than
that observed in data collected from building permits records (see “Recent Residen�al Development
Trends” below), it is consistent with the conclusion that residen�al development slowed in Brookings’ UGB

61 of 110

at the beginning of this decade. Recent development trends discussed in the next sec�on of this report
suggest that may be changing.

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Recent Residen�al Development Trends
Over the past 10 years, residen�al development in Brookings’ UGB has fluctuated from year to year.
According to data collected from the Accela building permit tracking system, the most building permits for
new one and two-family homes issued in a single year were issued in 2021 and 2022 (19 in both years)
while the most permits issued for manufactured housing (28) were issued in 2020. From 2016-2026, an
average of 14 building permits for one and two-family homes and 15 permits for manufactured homes
have been issued every year. In the first five months of 2026, six permits had been issued for single and
two-family homes and only 2 permits had been issued for manufactured homes.
Not including new housing with three or more units (which are permited through Oregon’s commercial
structural code and not included in the building permits dataset used here), this represents a quarter of
the 118 dwelling unit annual produc�on target established by the OHNA.

Building Permits Issued 2016-2026
50
28

40

23

30

21

19
13

20
12

10

19
12

19

17

14

19

19

16

13

12

6
12

8
2
10

0
2016

2017

2018

2019

2020

New 1 or 2 Unit

2021

2022

2023

2024

2025

6
2026

New Manufactured

Figure 3-3: Building Permits Issued Brookings UGB, 2016-2026. Data Source: Accela permit tracking
system, calcula�ons and analysis by Green Top PDR.
Recent land use en�tlements in the City of Brookings, however, show a return to a patern of increased
residen�al development. Altogether, 144 dwelling units have been en�tled 31 since 2016, with more than
90% of these units approved in the last 6 years.

31

En�tlements include approved subdivisions, par��ons, and PUDs

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As depicted in Figure 4, these units were split 55% to 44% between land in R-1 and R-3 zones. All of the
subdivisions and the Bedrock PUD were approved over the last 6 years, and 7 of the 12 par��ons were
approved over the last 5 years, all evidence of accelera�ng momentum in residen�al development that
includes significant medium density development.

Total Dwelling Units Entitled
2016 - 2026
SR-20, 2,
1%

R-1, 79, 55%

R-3, 63, 44%

Figure 3-4: Dwelling Units En�tled in the City of Brookings, 2020-2026. Data Source: City of Brookings
records, calcula�ons and analysis by Green Top PDR.

The Ocean Winds development, the first phase of which has been completed, added 15 regulated
affordable townhomes to Brookings’ inventory. A subsequent phase of that development is in design. The
“Bedrock Subdivision” on Lundeen Lane is en�tled for 48 townhomes or duplexes. The Alderwood
Subdivision, located at Alderwood Lane and 4th Street, was approved in 2020 and completely built out by
2022 providing 15 manufactured homes on individual lots. The Seacrest Estates Subdivision was approved
between 2021 (Phase I and II) and 2024 (Phase III). The first two phases have been constructed, and the
third phase is under development currently. Upon total buildout, 42 single detached homes will have been
constructed. Further evidence of a strong increase in single detached home construc�on is found in Curry
County Assessor’s records, which documented that 14 units of this housing type were built in 2025.

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Figure 3-5: Brookings UGB Building Permit Ac�vity, 2016-2026. Data Sources: Curry County, Lane Council
of Governments, City of Brookings, Accela

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Residen�al Density
As discussed previously in the “Residen�al Lands” sec�on of the RBLI, the City of Brookings land
development code (BLDC) has 15 zones that permit residen�al development through clear and objec�ve
land use decision processes. In addi�on to these, the Master Plan Development District (MPD) allows
residen�al uses permited by right in R-1, R-2, R-3, C-2, C-3, and C-4 zones. 32 Brookings only has one MPD,
Lone Ranch, which is planned as a large mixed use neighborhood with a range of housing types (including
540 single detached, 150 single atached, and 310 mul�family dwelling units) and neighborhood serving
commercial. Another MPD on Lundeen Lane is nearing comple�on of its land use approvals. It is purely
residen�al, and planned for 48 total units upon buildout.

Zone
SR
20,000
R-1-6
R-1-8
R-1-10
R-1-12
R-MH
R-2
R-3
C-3
C-4

Max.
Min. Lot Size Min. Lot Max. DU/unit
DU/acre
(square feet) Size (Acre) of land
(net)
20,000.00
6,000.00
8,000.00
10,000.00
12,000.00
6,000.00
6,000.00
6,000.00
None
None

Actual Observed
RBLI Density
Density (DU/net
Category
acre)

0.46
1.00
2.18
1.39
0.14
1.00
7.26
3.10
0.18
1.00
5.45
4.66
0.23
1.00
4.36
2.24
0.28
1.00
3.63
0.28
0.14
1.00
7.26
4.88
0.14
2.00
14.52
4.99
0.14
4.00
19.36
8.99
None
None
None
7.31
None
None
None
0.80
Table 3-5: City of Brookings Residen�al Densi�es by Zone

Low
Low
Low
Low
Low
Low
Medium
High
High
High

Analysis of observed residen�al densi�es reveals a wide difference between the maximum density allowed
in each zone, and actual development. The R-1-6 zone has an observed density of less than half of what is
permited: 3.10 DU/net acre compared to 7.26 DU/net acre.
More recent development on R-1-6 zone land has occurred at higher than historical densi�es. The three
residen�al subdivisions approved since 2016 had the following density characteris�cs:

32

BLDC 17.70.030.A – B.

66 of 110

•

The gross residen�al density for 94 total units on 23 (gross) acres of R-1-6 zoned land is 4.15
du/gross acre and 5.22 du/net acre.

•

Net to gross factors for these subdivisions ranged from 0.23 to 0.30, with an average across all
three subdivisions of 0.26. In other words, for every 1 acre of land that is developed (a lot, for
example, in a subdivision), another 0.26 acres is required for public rights-of-way, open space, etc.

As men�oned throughout this report, R-1-6 is the most prevalent low density zone in the City of Brookings.
Given the trend toward higher densi�es in this zone, it is reasonable to assume that future low density
development in the City of Brookings will average around 5 units/net acre across its 6 low density
residen�al zones, with gross to net factor of 0.30. This results in an overall planned gross residen�al density
of 3.85 dwelling units/acre.
R-2 and R-3 proper�es have also developed under maximum densi�es, but (in the case of R-3) are trending
toward higher density. Closer study of two R-2 zoned areas found a gross density of 4.78 units/acre and a
net density of 6.09 units/acre. The net to gross factor for these two cases ranged from 0.30 to 0.25, with
an average of 0.28. On the other hand, medium density development planned for the Lone Ranch MPD
has a calculated density of 13.6 units/net acre. Considering historical densi�es on R-2 land and planned
density for Lone Ranch, it is reasonable to assume that medium density development in the City of
Brookings will average around 8 units/net acre in R-2, with gross to net factor of 0.25. This results in an
overall planned gross residen�al density of 6.4 dwelling units/acre.
Recent development on R-3 zoned land demonstrates a trend toward higher density development. The
recently completed first phase of the “Ocean Winds” townhomes, achieved a gross density of 15.15
units/acre and a net density of 15.94 units/acre. This extremely efficient development had a net to gross
factor of only 0.05. While anomalously low (the development is located at the end of a cul-de-sac and
does not have much street frontage), it does demonstrate how higher density development typically
requires less addi�onal land for public improvements (mostly public right-of-way). Older mul�unit
development in Brookings is lower density. Pacific View Gardens, for example, has a net density of 7.81
units/acre and a gross density of 6.4 units/acre, with a net to gross factor of 0.22. While this net to gross
factor is a more reasonable assump�on for future R-3 development, the Ocean Winds development
provides a more plausible density assump�on for future development in the R-3 zone. At nearly 16
units/net acre, it is also consistent with planned higher density development in Brookings’ two approved
MPD, the Lone Ranch and the Bedrock Estates MPD (14 units/net acre and 12.54 units/net acre,
respec�vely).

67 of 110

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Projected Housing Demand
Two different approaches were u�lized to es�mate needed housing in Brookings’ UGB. The first is a
conven�onal approach based on the PSUPRC popula�on forecast.
Table 3-6 provides es�mates for the number of dwelling units needed to meet housing demand based on
popula�on forecasts by the Popula�on Research Center at Portland State University at 7, 10, 14, and 20
year intervals from the base year of 2026. For example, between 2026 and 2033, a total of 248 new
dwelling units will be needed a�er accoun�ng for the number of individuals who are an�cipated to reside
in group quarters and a vacancy rate of 8.7%. Likewise, from 2026 to 2046, almost 500 addi�onal homes
will be needed in Brookings UGB according to these projec�ons.
Forecast Year
2033
2036
2040
2046
Projected Popula�on
12,406
12,548
12,692
12,861
Popula�on Change from 2026
478
620
764
932
Popula�on in Group Quarters
10
13
16
20
Projected Popula�on Change
Less Group Quarters
467
606
747
912
Median Household Size 33
2.05
2.05
2.05
2.05
# Needed DU
228
296
365
445
34
Vacancy Rate
8.70%
8.70%
8.70%
8.70%
Total New Units Needed
248
322
397
484
Table 3-6: Needed Housing Projec�ons. Data Source: 2020-2024 ACS 5-Year Es�mate, Tables B25136,
S1101, and B26001. Calcula�ons and analysis by Green Top PDR.
The next step in measuring housing demand is to calculate the number of units needed by income group.
These groups and the propor�on of the popula�on assigned to each were presented in the Technical
Memorandum #1. Households were placed into groups approxima�ng “standard” income groupings
commonly used in housing policy and programs.
Table 3-7 presents the number of units needed over 10 and 20 year periods to meet the housing needs
within each category, based on the PSUPRC Forecast.
Income Group
Forecast
Period

Total
New
0-30% AMI
Units Needed

31-60% AMI

61-80% AMI

81-120% AMI

>120%
AMI

Household size is a weighted composite combining Census reported median household sizes for the City of
Brookings and Harbor CDP. Weights were based on rela�ve popula�on size.
34
Vacancy rate is a weighted composite combining Census reported vacancy rates for the City of Brookings
and Harbor CDP. Weights were based on rela�ve number of total dwelling units in each community.
33

69 of 110

2026-2036 322
42
64
55
45
116
2026-2046 484
64
96
82
67
174
Table 3-7: Needed Housing Projec�ons by Standard Income Group. Data Source: 2020-2024 ACS 5-Year
Es�mate; PSUPRC Popula�on Forecast. Calcula�ons and analysis by Green Top PDR.
As discussed in Technical Memorandum #1, the Oregon Housing Needs Analysis (OHNA) allocates housing
produc�on targets for every city in Oregon. The OHNA set a much higher produc�on target for Brookings
than projected housing demand based on the PSUPRC forecast that is presented above: 1,915 units over
the next 20 years. This target accounts for factors that are not considered in the PSU target, including
•

The impact of short term rentals and second homes (a significant issue facing coastal communi�es
like Brookings);

•

Historic underproduc�on; and

•

The need for housing for unhoused people.

Using both figures, it can reasonably be concluded that at least 484 and as many as 1,915 new homes will
be needed to meet demand for housing in Brookings’ UGB over the next 20 years.
The OHNA produc�on target is also broken down into the same five categories income groups. Table 8
presents the total produc�on target and produc�on targets for each of these income groups over the next
20 years. Higher income households earning more than $90,000 a year (120% of AMI) represent the single
largest driver of housing demand over the next 20 years, genera�ng a need for a litle more than 31% of
the produc�on target. They are followed by middle income households that earn between $60,000/year
and $90,000/year (roughly 80-120% of AMI) that represent about 24% of the produc�on target. Lower
and moderate income households earning less than $60,000/year (80% of AMI) account for approximately
44% of projected housing demand.
Income Group

Forecast
Total
New
>120%
0-30% AMI 31-60% AMI 61-80% AMI 81-120% AMI
Period
Units Needed
AMI
2026-2046
1,915
381
296
174
467
597
Table 3-8: Needed Housing Projec�ons by Standard Income Group. Data Source: Oregon Housing Needs
Analysis.
Table 9 summarizes the current or historic residen�al development in the City of Brookings and
extrapolates how many units in each of the five different housing type categories would be needed to be
developed to meet the OHNA produc�on target of 1,915 in 2026.

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Housing
Demand
by
Housing Type
Single-Detached
Single-Atached
Middle
Higher Density
(10+)
Manufactured

Current/Historic
% Owner
54.27%
2.44%
2.14%

Projected
Current/Historic % Demand-Renter
Owner
6.46%
1,039
11.25%
47
14.13%
41

Projected
Demand-Renter
124
215
271

Total
Projected
Demand
1,163
262
312

0.37%
7.57%
7
145
152
0.60%
0.77%
12
15
26
59.83%
40.17%
1,146
769
1,915
Table 3-9: Brookings UGB Needed Housing Projec�ons by Unit Type and Tenure. Data Source: 2020-2024
ACS 5-Year Es�mate; Oregon Housing Needs Analysis. Calcula�ons and analysis by Green Top PDR.
As reported previously in TM1, approximately 60% of Brookings exis�ng housing inventory are single
detached units and 40% are other types. Among those other types, single atached units (townhomes)
represent roughly 14% of all units. Middle housing types (duplexes, triplexes, cotage clusters, and small
apartment buildings) represent another 16%; manufactured homes, on the other hand, represent a very
small propor�on.
Future residen�al development, however, is likely to diverge from this patern over the next 20 years. The
aging popula�on and smaller households discussed above, and other factors, will increase demand for
smaller units developed at higher densi�es. Addi�onally, the OHNA income group distribu�on presented
in Table 8 above also suggests that there is significant demand among lower and moderate income
households earning less than 80% of AMI. This will increase demand for medium and higher density
housing types that are more affordable to these households. At the same �me, the OHNA shows strong
demand among middle and upper income households that may prefer single detached homes at lower
densi�es.
Table 3-10 presents a housing demand outlook that balances historic development paterns with the
projected future demand of a changing community. In doing so, it is aligned with the need for more smaller
units that will be atrac�ve to smaller, aging households and households that need more atainable
housing op�ons. At the same �me, it accounts for demand for larger units for families with school-aged
children.
Housing Allocation by Density and
Income Group
Low Density (8 DU/net acre or less)
30% AMI, Max. Income $22,480
30 – 60% AMI, Max. Income $44,960
60 – 80% AMI, Max. Income $59,946
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Projected Units as a % of
Total Growth 2026-2046

Projected # Units 20262046

1.85%
1.92%
2.82%

35
37
54

80 – 120% AMI, Max. Income $89,920
> 120% AMI
Medium Density (9-16 DU/net acre)
30% AMI, Max. Income $22,480
30 – 60% AMI, Max. Income $44,960
60 – 80% AMI, Max. Income $59,946
80 – 120% AMI, Max. Income $89,920
> 120% AMI
High Density (more than 16 DU/net
acre)
30% AMI, Max. Income $22,480
30 – 60% AMI, Max. Income $44,960
60 – 80% AMI, Max. Income $59,946
80 – 120% AMI, Max. Income $89,920
> 120% AMI
Total

12.11%
23.21%
41.91%

232
445
803

11.91%
9.25%
5.17%
10.95%
7.00%
44.29%

228
177
99
210
134
849

6.15%
4.29%
1.08%
1.55%
0.74%
13.81%

118
82
21
30
14
265
1,917 35

Table 3-10: Brookings UGB Projected Needed Housing Projec�ons by Development Density. Data Source:
Oregon Housing Needs Analysis. Calcula�ons and analysis by Green Top PDR.

Residen�al development in the next 20 years under this scenario assumes a majority of housing demand
for households earning over 80% of AMI would be met through single detached homes built on low density
zoned land. Lower density housing op�ons affordable to lower and moderate income households are
assumed to be met through cotage clusters and manufactured housing.
Medium density residen�al would provide significant opportuni�es for lower and moderate income
households to own or rent small lot single unit detached 36, townhomes, and middle housing types
(“plexes” and mul�unit buildings with fewer than 10 units).

35

The total is slightly different than the total units projected by the OHNA (1,915) due to rounding in the underlying
calcula�ons.

Small lot single unit detached housing includes cotage clusters and small footprint detached homes on lots that
range from 2,700 square feet (0.06 acres) to 4,000 square feet (0.09 acres).
36

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72, 4%

Projected Dwelling Units by Type
2026 - 2046

SingleDetached
SingleAttached

265, 14%
731, 38%
424, 22%

Middle
Higher Density
(10+)

424, 22%

Manufactured

Figure 3-6: Brookings UGB Projected Needed Dwelling Units by Type. Data Source: Oregon Housing
Needs Analysis. Calcula�ons and analysis by Green Top PDR.

High density residen�al development would accommodate most of the housing need for low and
moderate income households, but it also assumes a small number (44 total) units would be occupied by
middle and upper income households. These would be market rate condos.

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Residen�al Land Capacity & Sufficiency
The capacity of residen�al land within Brookings’ UGB to accommodate the development of needed
housing is evaluated by comparing the demand for housing es�mated above with amount of land that is
available for development. This step uses the results of the Residen�al Buildable Lands Inventory
presented in Technical Memorandum 2 as the basis for this analysis.
First, the demand for housing units calculated above is converted into demand for residen�al land using
average densi�es discussed earlier. In addi�on to land for dwelling units (for example, a buildable
residen�al lot on which a house can be constructed), land is included for uses suppor�ve of and necessary
to residen�al development. This process of conver�ng “net developable” residen�al land to “gross
developable” residen�al accounts for things like land for public rights-of-way for roads and sidewalks. The
outcome is a more realis�c accoun�ng of how much land is actually needed for housing.
For this par�cular land sufficiency analysis, homes that have been planned and en�tled within the Lone
Ranch MPD were removed from needed units. The developable land area of Lone Ranch documented in
the RBLI was likewise removed from the RBLI for the purposes of calcula�ng needed developable
residen�al land.

Residen�al
Land Density

Low
Medium
High

Total
Needed
Units

Planned
Lone
Ranch
Units

Total
Needed
Units Less
Lone
Ranch

Average
Development
Density
(DU/net acre)

803
540
263
5.00
849
150
699
8.00
265
310
-45
16.00
1,917
917
Average residen�al density for 2026-2046 planning period (DU/gross
acres)

Needed
Net to
Residen�al
Gross
Land
(net
Factor
acres)

Developable
Residen�al
Land Needed
(gross acres)

52.64
87.35
-2.83
137.16

68
109
-3
174

0.30
0.25
0.20

5.26

Table 3-11: Brookings UGB Projected Needed Residen�al Land by Development Density. Calcula�ons and
analysis by Green Top PDR.
As shown in Table 11, a�er the en�tled capacity of Lone Ranch is accounted for, there is a need for
•

Nearly 53 net acres, 68 gross acres, of low density residen�al land

•

Over 87 net acres, 109 gross acres, of medium density residen�al land

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There is a surplus of nearly 3 acres of high density residen�al land. Lone Ranch, with its planned 310 high
density units, provides slightly more high density residen�al capacity than is currently needed.
The next, and final, step in this analysis is to determine whether the Brookings UGB currently has enough
land to meet these needs. Land within the city limits is considered first, because it is currently served by
urban services and infrastructure or is more likely to be served in the first 7 – 10 years of the planning
period.
Surplus/Deficiency
City of Brookings
Low
102.74
68
34
Medium
25.17
109
84
High
24.62
-3
28
Table 3-12: Brookings UGB Land Sufficiency—Brooking City Limits. Calcula�ons and analysis by Green
Top PDR.
City of Brookings

Developable Residen�al Land

Needed Residen�al Land

With nearly 103 acres of developable low density residen�al land in the City of Brookings, there is an
overall surplus of 34 acres of low density residen�al land. However, there is not enough developable
medium density residen�al land in the City of Brookings. With only 25 developable acres of medium
density land remaining, there is an 84 acre deficiency of medium density residen�al land in the City of
Brookings. With Lone Ranch’s current en�tlement for high density residen�al development, there is
currently a surplus of 28 acres of high density residen�al in the City of Brookings.
Developable residen�al land in the unincorporated UGB is then considered, resul�ng in surpluses in all
residen�al land categories: 222 acres of low density, 21 acres of medium density, and 39 acres of high
density residen�al land.
Unincorporated UGB
Surplus/Deficiency of En�re UGB
Developable Residen�al Land
Low
187
222
Medium
105
21
High
11
39
Table 3-13: Brookings UGB Land Sufficiency—Unincorporated UGB. Calcula�ons and analysis by Green
Top PDR.

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Chapter 4. Targeted Implementation Framework

Summary

The following iden�fies eight (8) strategies that the City of Brookings could pursue in its efforts to promote
housing produc�on within its UGB. These policies were selected and priori�zed based on their poten�al
impact, feasibility, and input collected from the stakeholder advisory commitee and the general public.
Strategies are divided roughly into three groups. Four economic strategies focus on reducing or managing
development costs in ways that can encourage and accelerate housing produc�on. Two regulatory
strategies address opportuni�es to make housing development easier and assess the impact of short-term
rentals (STRs) on Brookings exis�ng housing inventory. Policy & Partnerships focus on ac�ons that explore
important issues raised by the HNA that are beyond Brookings direct control.

Strategy 1 - System Development Charge Reduc�ons
Category
Economic
Problem Addressed
System Development Charges, while a necessary funding mechanism for public infrastructure suppor�ng
development, add considerable expense to the cost of a home. According to the 2025 SDC update study 37,
a single detached home would be assessed nearly $20,000 for water, sanitary sewer, stormwater, and
transporta�on SDCs. This may be even more of an impediment to the development of housing types with
smaller profit margins, such as middle and higher density mul�unit housing. SDC reduc�on programs have
been effec�ve in encouraging housing produc�on, perhaps most notably programs targe�ng ADUs in
Bend, Portland, and Medford. The City of Tigard has operated an SDC exemp�on program for regulated
affordable housing since 2018. It has observed posi�ve results.
Responses to public outreach and stakeholder input iden�fied rising development and construc�on costs
as an obstacle to housing development. Programs to reduce or waive SDCs for par�cular types of housing
can encourage produc�on.

Donovan Enterprises, Inc., Water Wastewater, Stormwater, and Transporta�on System Development Charge
Update Final Report, August 2025

37

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Priority
High: Reducing SDCs for specific types of housing can s�mulate development by making a par�cular
housing more financially feasible for private for profit and not-for-profit developers. The impact can be
par�cularly meaningful for housing for middle income households where costs are higher rela�ve to
poten�al returns.
Implementa�on Timeframe
1-2 years
Benefits/Costs
Reducing or elimina�ng SDCs can reduce funding for planned public improvements. This of course assumes
1) that projected funding for planned public improvements relied on the development of projects like the
one for which SDCs are not collected and 2) that foregone SDCs are not paid from other sources. For
example, a jurisdic�on could develop a housing fund with general fund resources and use the fund to
offset or eliminate SDCs for par�cular projects.
Key Issues
1. Establishing a legal basis for SDC exemp�ons/reduc�ons for specific types of housing if SDCs will
not be repaid to enterprise funds through general fund or other funding sources.
2. Developing a process and standards for evalua�ng and awarding requests.
Implementa�on Ac�ons
1. Local policy and program development & implementa�on.
2. Project development and selec�on.

Strategy 2 - Annexa�on Incen�ve Program
Category
Economic
Problem Addressed

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Annexa�on of vacant and par�ally vacant proper�es into the City of Brookings is essen�al for the buildout
of the Brookings UGB in a way that provides a range of housing types over the 20 year planning period.
Proper�es that are adjacent to exis�ng urban development or in areas experiencing development
represent opportuni�es for the City to add substan�ally to its housing inventory.
Smaller tracts of land are o�en owned by individuals who are not developers and are hesitant to take on
the significant upfront costs to en�tle land for future development. They might also be reluctant to bear
the cost of increased property taxes once land has been annexed.
The City could iden�fy proper�es mee�ng certain programma�c characteris�cs (size, proximity to exis�ng
infrastructure, and es�mated long term cost to serve) and offer to annex and zone proper�es free of
charge. As an addi�onal incen�ve, the City could offer to phase in its millage as permited under ORS
222.111(3).
Priority
High:
Implementa�on Timeframe
1-2 years
Benefits/Costs
The cost of land use en�tlements and addi�onal real estate taxes represent rela�vely small costs in
absolute terms for large developments, but are more significant for smaller developments that are more
likely to be undertaken by developers that may lack resources and exper�se. Reducing upfront land use
en�tlement costs and addi�onal carrying costs may encourage property owners to annex, making their
land available for development in the near term.
Phasing property taxes does have a fiscal cost, but may be rela�vely insignificant compared to the longer
term fiscal benefits that would not have been realized but for the program. Waiving land use fees also
carries a fiscal cost, but is likely to be offset in the long run by genera�on of new property taxes, user fees,
and SDCs.
Key Issues
1. Develop process and standards for evalua�ng proposals.
2. Establish program features that reasonably manage fiscal impacts.

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Implementa�on Ac�ons
1. Policy and program development & implementa�on.
2. Project development and selec�on.

Strategy 3 - Middle Income Revolving Loan (MIRL) and Mul�ple Unit Property Tax Exemp�on
(MUPTE)
Category
Economic
Problem Addressed
Housing that is affordable to middle and lower income households is o�en the most expensive to produce
on a per unit basis and has the slimmest profit or opera�ng margins. Offse�ng or reducing costs of
produc�on and/or ongoing opera�ons (in the case of rental housing specifically) can encourage not-forprofit and for-profit developers to build when they might not otherwise.
Responses to public outreach efforts (surveys and tabling events) and stakeholder input consistently
iden�fied the need for “workforce” housing. In a local economy that is increasingly dependent on lower
wage service industry jobs, workforce housing needs to be affordable to middle and lower income
households.
According to the Oregon Department of Housing and Community Services, MIRL has only been
implemented by Tillamook County. MUPTE, on the other hand, has been used extensively throughout
Oregon in ci�es like Portland, Salem, Eugene, and Medford where it has been used to support the
development of thousands of higher density units.
Priority
High: Aside from the poten�al effec�veness of these strategies to incen�vize the development of certain
housing types, they afford local jurisdic�ons considerable discre�on and flexibility in their design and
implementa�on. This is par�cularly true for MUPTE, which does not directly involve the State of Oregon
as MIRL does.
Implementa�on Timeframe
2-5 years

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Benefits/Costs
Both of these policies can provide meaningful economic incen�ves for developers to pursue desired
projects, and as men�oned above, both policies allow for considerable local par�cipa�on in program
design and implementa�on. MUPTE does require coopera�on from taxing jurisdic�ons in order to be most
effec�ve, which can be difficult poli�cally. MIRL does require the direct involvement of the Oregon
Department of Housing and Community Services (OHCS), and is a new, rela�vely untested program. Both
programs do require that par�cipa�ng jurisdic�ons forego property taxes for a period of �me, and both
programs require ongoing monitoring and repor�ng, which requires a longer term staffing commitment.
Unlike MUPTE, MIRL does not have buy-in requirements from par�cipa�ng taxing jurisdic�ons enabling
program par�cipants (local jurisdic�ons and developer partners) the use of the en�re property tax millage.
Key Issues
1. For MUPTE, jurisdic�ons must establish a geographic boundary within which the program may
operate. Otherwise, the program can only be used for regulated affordable housing development.
2. Understanding and then managing poten�al fiscal impacts of foregoing future property tax
revenue for a period of �me
3. Developing a process and standards for evalua�ng and awarding requests.
Implementa�on Ac�ons
1. Local policy and program development & implementa�on.
2. Project development and selec�on.
3. Monitoring & repor�ng.

Strategy 4 - Local Public Infrastructure Funding Op�ons
Category
Economic
Problem Addressed
Aside from SDCs, the actual costs incurred to construct infrastructure for residen�al development are
substan�al. Roads, water, sanitary sewer, and stormwater management are one of the most significant
cost components for new (especially greenfield) development. Unless iden�fied as a publicly funded

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improvement project paid with SDCs or other public funds, these costs are borne en�rely by private
developers who, in turn, pass those costs on to homebuyers and renters.
Alterna�vely, private developers and municipali�es can partner to deliver necessary public infrastructure,
reducing up front development costs and accelera�ng development. In this arrangement, the public en�ty
constructs infrastructure and is repaid through a Local Improvement District (LID) over �me as proper�es
are sold and/or through a special tax levy.
Priority
Medium: Of the three economic strategies, this may be the most complicated, requiring close coordina�on
between an interested developer, the City of Brookings, and (likely) the State of Oregon. It is also highly
con�ngent on development project �ming. This strategy also involves the most fiscal risk for the
municipality.
Implementa�on Timeframe
5-10 years
Benefits/Costs
LIDs can accelerate delivery of costly public improvements that otherwise discourage private development
or make projects infeasible altogether. They work best when there are rela�vely few affected proper�es
and agreements among those property owners can be easily reached. Large, greenfield development sites
are best suited to this strategy as opposed to smaller infill projects. The public en�ty does need to have
up front funding available for the project, but there are op�ons if it does not. The public en�ty is also at
risk if the development is not completed and/or private property owners are not able to pay the special
levy.
Key Issues
1. Managing risk of default or other failure of the private developer to complete a project and/or
repay the municipality.
2. Iden�fying project funding.
Implementa�on Ac�ons
1. Iden�fy public infrastructure projects needed for housing development that may benefit from this
strategy, and engage property owners to create awareness.

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2. Engage relevant State of Oregon departments and agencies to iden�fy funding for up front project
costs.

Strategy 5 - Land Development Code Audit
Category
Regulatory
Problem Addressed
In order to achieve the planned residen�al development outcomes described in the Housing Needs
Analysis, the Brookings Land Development Code should be evaluated holis�cally to ensure that it is
op�mally usable by the development community (which is responsible for housing produc�on), provides
a high level of certainty to both developers and the community at large, ensures a high level of efficiency
in the land use en�tlement process, and uses clear and objec�ve standards while allowing for flexibility.
Priority
High: An audit would likely iden�fy at least some changes to the code that would result in efficiencies both
for the development community and city staff. Addi�onally, changes to the code that support
development of certain kinds of housing should occur before opportuni�es are missed.
Implementa�on Timeframe
2-5 years
Benefits/Costs
Code changes o�en achieve benefits over the long term, if not immediately. But changes may have more
immediate benefits to both developers and the city. This project could be grant funded, making it a
rela�vely low cost (to the city) ini�a�ve with significant benefits.
Key Issues
1. The level of review (ministerial, administra�ve, quasi-judicial, and legisla�ve) should be
considered with the inten�on of using the most efficient review process possible.
2. The Code should also be evaluated for its ability to achieve minimum residen�al densi�es assumed
by the capacity analysis of 5 dwelling units/net acre for low density, 8 dwelling units/net acre for
medium density, and 16 dwelling units/net acre for high density.
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3. Establishing regulatory minimum residen�al densi�es should be seriously considered for all
residen�al zones (not including commercial zones where mixed use residen�al is permited).
4. Regulatory reforms that encourage medium density (middle housing types) should be a priority.
Implementa�on Ac�ons
1. Iden�fy and secure grant funding
2. Retain consultant to compete project
3. Public process for amendments

Strategy 6 - Short term rental policy assessment
Category
Regularoty
Problem Addressed
STRs u�lize housing that may be otherwise occupied by permanent residents. Although there are rela�vely
few STRs in the City of Brookings (80 current, ac�ve Condi�onal Use Permits), they may dispropor�onately
impact townhomes, a middle housing type that can provide affordable rental housing for a range of
households, including families with younger children, and homeownership opportuni�es for moderate
and middle income households. Whether or not STRs appreciably remove dwelling units from the local
housing market that would otherwise be occupied by full �me resident homeowners or renters is an open
ques�on, but comments gathered through the public outreach process indicate that it is commonly shared
held belief that they do.
STRs do, however, support tourism, which is a very important part of the local economy. Finding a balance
between reserving housing for full �me residents (par�cular low and middle income households) and
suppor�ng tourism would be the goal of this of ini�a�ve.
Priority
Medium: Brookings currently regulates STRs through a Condi�onal Use Permit and requires annual
registra�on for permited STRs. The expense of the CUP is not inconsequen�al, and a CUP is a discre�onary
land use ac�on that does not provide certainty of approval. Approvals may also condi�oned to mi�gate
nega�ve impacts atributed to an STR, which may have the effect of adding considerable up front costs for
someone seeking approval. That said, Brookings has not systema�cally reviewed the effec�veness of the
program and the program was never designed to achieve an op�mal number of STRs in the first place. The

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HNA did iden�fy a poten�al dispropor�onate impact on middle housing types that are an important
component of Brookings future inventory.

Implementa�on Timeframe
2-5 years
Key Issues
1. Measuring impact of STRs on housing inventory with par�cular concern for impacts to high priority
housing types (middle and high density).
2. Determining an acceptable balance between the benefits of STRs to property owners and the
tourism industry and the produc�on and preserva�on of needed housing types.
Benefits/Costs
Whether program assessment results in change is largely a poli�cal ques�on for City decision makers. An
assessment could support improvements to the program and help the city avoid a situa�on where the STR
market suddenly expanded.
Implementa�on Ac�ons
1. Iden�fy and secure grant funding
2. Retain consultant to compete project
3. Public process for amendments

Strategy 7 -Annexa�on and UGB Analysis
Category
Policy and Partnerships
Problem Addressed
Outside of the Lone Ranch MPD, there are rela�vely few large developable tracts of residen�al land in the
City of Brookings. Although infill development will meet some of the projected need for residen�al
development over the next 20 years, urbaniza�on of residen�al land in the unincorporated UGB is an
important considera�on as well. Large, systema�c annexa�ons can be poli�cally fraught and very
challenging. At the same �me, incorpora�on of par�cular parts of the unincorporated UGB may be an
effec�ve way to realize more residen�al development in the UGB than would have been possible under
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county jurisdic�on. It would also be necessary in the event that Brookings ever considered adjus�ng its
UGB to include land adjacent to the southern edge of the current UGB.
Priority
Medium: The City of Brookings has analyzed the poten�al annexa�on of Harbor before and determined
that annexa�on was not feasible at the �me. In addi�on, annexa�on may not even be possible under
current state law. In any event, the eventual buildout of newly incorporated lands would likely be a long
range solu�on.
Key Issues
1. Financial feasibility of annexa�on is an important considera�on for the City of Brookings which
would assume significant financial liability for infrastructure in annexed areas.
2. Understanding the poli�cal likelihood of annexa�on may be difficult, but it would be beneficial
before pursuing other ac�ons.
Implementa�on Timeframe
5-10 years
Benefits/Costs
Other strategies, like those recommended here, are likely to be more effec�ve short and medium term
solu�ons. For example, if the development of Lone Ranch proceeds rela�vely quickly, with significant
progress over the next 5-10 years, annexa�on of the unincorporated at any significant scale may not be
necessary. If, however, development within the City of Brookings is unable to achieve the City’s goals for
housing produc�on, this may become a necessary strategy.
Implementa�on Ac�ons
1. Iden�fy funding for and commission a study to assess the feasibility of annexa�on significant
por�ons of the unincorporated UGB—par�cular those that represent opportuni�es of medium
and higher density housing.

Strategy 8 - Homelessness Ac�on Plan
Category
Policy and Partnerships
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Problem Addressed
Homelessness was iden�fied as a common concern in public outreach. Data presented in the HNA suggests
that homelessness is a significant issue across Curry County. As its largest city and center for service
providers, the City of Brookings has an interest in the outcome of these and other ac�vi�es that address
homelessness.
Priority
Medium: Curry County is currently hos�ng a series of discussions on the topic of homelessness. Brookings
role as a municipality in the development and implementa�on of policies that address homelessness will
Key Issues
1. Understanding the impact of homelessness on the City of Brookings, specifically, and its
unincorporated UGB.
2. Defining Brookings’ role in the collabora�ve implementa�on of policy.
Implementa�on Timeframe
2-5 years
Benefits/Costs
Municipali�es, par�cularly those that do not directly receive provide mental health and other social
services, may be limited in their direct response to homelessness. That said, this could provide an
opportunity to build collabora�ve partnerships between public en��es, private service providers.
Probably grant funded.

Implementa�on Ac�ons
1. Par�cipate in regional ini�a�ves to beter understand and address homelessness.
2. Pursue grant funding for an ac�on plan.

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Brookings Housing Needs Analysis - Appendix A
GIS Analysis Methodology

Residen�al Buildable Lands Inventory (RBLI)

1. Introduc�on and Purpose
This appendix documents the geographic informa�on system (GIS) methodology used to produce the
Residen�al Buildable Lands Inventory (RBLI) suppor�ng the City of Brookings Housing Needs Analysis
(HNA). It is a companion to Technical Memorandum 2 (TM2), which presents the inventory results and the
resul�ng residen�al land supply findings. Where TM2 reports what the buildable land supply is, this
appendix documents how it was derived- the data sources, coordinate framework, classifica�on logic, and
constraint analysis behind the acreage figures in the memorandum.
The analysis is limited to residen�al land within the Brookings Urban Growth Boundary (UGB). It follows
the buildable lands inventory method established in OAR 660-038 (Housing Needs Analysis) and the
related administra�ve rules and statewide planning goals summarized in Sec�on 2. All spa�al analysis was
performed in ArcGIS Pro; results were published to ArcGIS Online for internal review and public access as
described in Sec�on 12.

2. Regulatory Framework and Data Crosswalk
Each element of the inventory traces to a specific rule, statute, or statewide planning goal. The crosswalk
below maps each authority to the analysis it requires and the GIS data used to perform that analysis.

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Authority

Required analysis

GIS data used

OAR 660-038-0040

Iden�fy residen�al land

Tax lots, zoning

OAR 660-038-0050 / - Net buildable acres and capacity by Buildable lands
0060
density
assump�ons

result, density

OAR 660-038-0070(1)(d)

Slope > 25% on ≥ 1 con�guous acre as LiDAR-derived slope constraints
physical constraint

OAR 660-024 / -024-0050

UGB land supply

OAR 660-008-0100

Coastal shoreland use standards Shoreland
(Goal 17)
polygons

Goal 16

Estuarine resource areas excluded Estuary management units / NWI
from supply
estuarine classes

Goal 18

Beach-and-dune areas

ORS 197A.270

Residen�al lands study scope within UGB boundary, comp plan / zoning
UGB

ORS 197A.350

Housing
Produc�on
developability inputs

UGB boundary, taxlots
management

area

Ac�ve beach / dune areas

Strategy Service areas, parcel size, access

3. Data Sources and Vintage
The inventory draws on the following authorita�ve datasets.
Dataset

Source

Vintage

Use

Tax lots and assessor Curry County Assessor
atributes

2026 hosted Base parcel geometry and
feature service residen�al atributes

Bare-earth LiDAR (DEM)

DOGAMI OLC South Coast

2008–2009

Wetlands (NWI)

USFWS Na�onal Wetlands 2026 hosted Environmental constraint
Inventory
feature service

Wetlands (state)

Oregon Dept. of State 2026 hosted Environmental constraint
Lands
feature service

Flood hazard (NFHL)

FEMA Map Service Center

2026 hosted Constraint / reference
feature service

Coastal
hazards

&

Estuary
units

management Oregon Estuary Plan Book 2026 hosted Goal 16 exclusion
(DLCD/DSL)
feature service

Aerial imagery

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geologic DOGAMI

Slope deriva�on

USDA NAIP/NAIP

2026 hosted Erosion / bluff reference
feature service

2024

Visual verifica�on baseline

Dataset

Source

Vintage

Use

Zoning

City of Brookings/Curry 2026 hosted Land-use basis (see Sec�on
County
feature service 6)

4. Coordinate System and Measurement Conven�ons
All spa�al data were projected to and analyzed in NAD 1983 (HARN) StatePlane Oregon South, FIPS 3602,
Interna�onal Feet (EPSG/WKID 2914). Every area figure reported in the inventory was computed directly
from GIS geometry in this projec�on rather than transcribed from published or online sources.
Consistently projected geometry keeps the inventory internally consistent and makes every total in TM2
reproducible. Minor differences between GIS-computed boundary acreages and published figures are
expected and are atributable to right-of-way treatment, the exclusion of non-taxlot water bodies such as
the Chetco River, and differences in projec�on and measurement basis.
As part of preparing the tax lot base, recorded assessor acreage was evaluated against the GIS-calculated
area for each parcel. Per-parcel deltas were measured, and the parcels showing a substan�ve difference
were iden�fied, inves�gated, and resolved. Across the inventory the deltas were nominal and consistent
with the expected variance between deeded or assessed acreage and geometry-based measurement. This
analysis supports the use of GIS-calculated acreage in this projec�on as the basis for all area figures
reported in the inventory.

5. Tax Lot Base Prepara�on
The inventory is built on a tax lot layer derived from Curry County Assessor parcel data and maintained in
the project geodatabase. Prepara�on intersected the county taxlots to the Brookings UGB, removed null
geometries, de-duplicated coincident polygons (discussed below), and reconciled the records so that each
tax lot resolves to a single inventory record. The prepared base contains 5,503 tax lots within the study
area.
A notable characteris�c of the source parcel data is the presence of duplicate, coincident geometries.
Where a single tax lot carries more than one ownership record, the county data represents each ownership
interest as its own polygon occupying the same footprint, producing stacked, "sandwiched" coincident
polygons for one physical tax lot. Le� in place, these duplicates would cause the same ground area to be
counted more than once in acreage, constraint, and capacity calcula�ons.
To prevent this double-coun�ng, the coincident geometries were de-duplicated so that each physical tax
lot is represented by a single shape. Ownership was not discarded in the process: a related table was
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produced that preserves every ownership record for all tax lots, keyed to the retained geometry by the tax
lot iden�fier. The single retained tax lot shape is the record that carries the added atribute fields and
against which all geometry (acreage and constraint overlap) is calculated, while the related table retains
the full ownership detail for reference.

6. Zoning Atribu�on
Reliable comprehensive-plan-designa�on GIS data was not available for the full study area, so zoning was
used as the primary land-use basis, consistent with the allowance in OAR 660-038. Each tax lot was
assigned zoning through a spa�al intersec�on of the tax lot layer with the zoning layer.
The accuracy of the zoning data itself, as derived from currently available GIS sources, is not fully
characterized; the degree to which the digital zoning layer precisely reflects adopted zoning at every parcel
boundary is not well understood. It is, however, the best available zoning data for the study area, and it is
the same data the county and the city rely on to make land use determina�ons, both in the unincorporated
UGB and within city limits. Using it as the basis for the inventory therefore aligns the analysis with the data
of record used in local land use administra�on.
Many parcels are split by more than one zone; 126 tax lots carry two or three zones. To assign a single
governing designa�on for summary purposes, a Dominant Zone approach was used: the zone occupying
the largest share of a parcel's area becomes its Dominant Zone (Zone 1), with secondary and ter�ary zones
retained in Zone 2 and Zone 3 fields. Slivers below a 0.05-acre threshold were disregarded so that
negligible boundary overlaps do not generate spurious split-zone assignments. Because residen�al site
addresses are recorded at the tax lot level and cannot be atributed to a specific zone segment within a
split parcel, density and capacity summaries use the Dominant Zone.

7. Residen�al Land Iden�fica�on
Residen�al land use was defined through a reviewed residen�al flag (Residen�al Flag – Reviewed). Each
tax lot's residen�al status was evaluated against zoning, assessor property class, and site characteris�cs
and flagged Yes or No. Filtering to reviewed-residen�al parcels yields the residen�al inventory universe of
4,870 tax lots.

8. Buildable Lands Classifica�on
Each residen�al tax lot was assigned a Dra� BLI Status describing its development poten�al. The
classifica�ons and their defini�ons are given in Table X-2. Classifica�on is based on the presence of a

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residen�al site address and structure, the developable area remaining a�er environmental constraints are
removed, ownership, and the development patern of comparable nearby parcels.

Table X-2. Dra� BLI Status classifica�ons.
BLI status

Defini�on

Vacant

No current site address or structure in residen�al use, and either retains
development capacity a�er environmental constraints are removed, or
comparable adjacent parcels demonstrate that development is possible.

Par�ally Vacant

Already carries some residen�al development but retains a quarter-acre (0.25
acre) or more of developable area a�er environmental constraints and exis�ng
on-parcel development are accounted for. When condi�ons appear
appropriate for development to occur on fewer than .25 acres, smaller
amounts of land are included as developable.

Redevelopable

Parcels with redevelopment poten�al. In this inventory this is the single
commercial (C-3) parcel described in Sec�on 7, brought into the residen�al
universe as a redevelopable site.

Developed

Lands fully developed with residen�al use, or privately owned and fully
constrained by environmental or other factors.

Undevelopable

Lands owned by a public en�ty — for example schools and city public-works
lands — together with public and private rights-of-way.

Not Applicable

All other lands not considered, such as commercial or other uses that do not
fall into the categories above.

Vacant and Par�ally Vacant lands form the core buildable supply, with the single Redevelopable parcel
reported as a dis�nct addi�on; Developed, Undevelopable, and Not Applicable lands fall outside the
buildable supply.
Two helper fields carry the values used in supply calcula�ons: ResFlagAdj (the reviewed residen�al flag)
and DevAc_Adj (the adjusted developable acreage). A key filtering rule applies to any supply query: parcels
are filtered on Residen�al Flag – Reviewed = Yes before being evaluated by BLI status.

9. Development Constraints Analysis
Physically and regulatorily constrained por�ons of otherwise buildable land were iden�fied and removed
from net buildable acreage. Every constraint layer used in the inventory — the same layers presented in
the project web map — is enumerated in Table X-1 with its data source and its role in the analysis. The
layers fall into three groups discussed below: environmental and geologic, slope, and coastal.
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Table X-1. Development constraint layers and data sources.
Constraint layer

Source / custodian

FEMA flood hazard (Special Flood FEMA Na�onal Flood Hazard Layer (Map Service Center).
Hazard Area)
Regulatory Floodway and 1% Annual Chance Flood Hazard.
Slope ≥ 25% (OAR 660-038)

Green Top PDR-derived from DOGAMI OLC South Coast LiDAR
(2008–09)

Landslide suscep�bility: High

DOGAMI SLIDO

Landslide suscep�bility: Very High

DOGAMI SLIDO

Rapidly
moving
suscep�bility

landslide DOGAMI

Wetland: Estuarine
Deepwater

&

Marine USFWS NWI / Oregon DSL

Wetland:
Wetland

&

Marine USFWS NWI / Oregon DSL

Estuarine

Wetland: Freshwater Emergent

USFWS NWI / Oregon DSL

Wetland: Freshwater Forested/Shrub USFWS NWI / Oregon DSL
Wetland: Freshwater Pond

USFWS NWI / Oregon DSL

Wetland: Riverine

USFWS NWI / Oregon DSL

Riparian setback

Green Top PDR- derived buffer; top of bank stream buffer from
NHD flowlines, aerial, and LiDAR

County Conserva�on Zone ("Coastal Curry County
Conserva�on" in TM2)

Each layer's overlap with the tax lots is stored as an individual per-layer acreage field for transparency and
documenta�on. These per-layer fields are not subtracted individually; the combined constraint figure used
in the supply calcula�on is a de-overlapped union of the "combined total" layers (Sec�on 10), so land
constrained by more than one factor is counted only once.

9.1 Environmental and geologic constraints
Flood hazard, wetlands, riparian setbacks, and landslide suscep�bility were compiled as constraint layers.
FEMA flood hazard was taken from the Na�onal Flood Hazard Layer. Wetlands were retained by the six
Na�onal Wetlands Inventory/DSL types listed in Table X-1. Riparian setbacks were generated by Green Top
PDR as a variable-width buffer measured from the top of bank- 75 feet along the Chetco River and 50 feet

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along other streams, as required by the applicable local land development ordinance. Geologic constraints
use the DOGAMI SLIDO landslide suscep�bility classes (High and Very High) together with rapidly moving
landslide suscep�bility; the use of High and Very High as the constraint threshold is consistent with the
"severely constrained" standard in OAR 660-008-0005.

9.2 Slope constraints
Slope was derived from the DOGAMI OLC South Coast bare-earth LiDAR (2008–2009, 3-foot cell). The slope
work produced three outputs:
1. State-rule constraint. This product implements OAR 660-038-0070(1)(d): con�guous areas of at
least one acre with slopes greater than 25 percent are iden�fied as physical development
constraints, with slope measured as rise over run. Slope was calculated across the study area,
areas exceeding 25 percent were isolated and dissolved into con�guous patches, and only patches
mee�ng the one-acre con�guity minimum were retained. To apply the one-acre con�guity test
correctly, it was run against a slope surface that extends beyond the UGB via a buffer, so that a
genuinely con�guous steep-slope area straddling the UGB line is evaluated at its true extent.
Without the buffer, the UGB line could clip a large con�guous slope feature, leaving the por�on
inside the UGB below one acre and causing it to fail the test even though the physical feature
qualifies; buffering beyond the boundary prevents this arbitrary line from disqualifying an actual
constraint.
2. Local slope-band layer. A second product classifies the study area into four slope classes to
support parcel-level flagging against the City's hillside standards. The Brookings Municipal Code
(BMC Chapter 17.100) uses a 15 percent average slope as the local hillside-review trigger.

Slope class

Basis

0–14%

Below local hillside trigger

15–19%

Local hillside review (BMC 17.100)

20–24%

Local hillside review (BMC 17.100)

25% +

State physical-constraint threshold (OAR 660-038)

3. Parcel-level hillside flag. A third product is a flag added to the tax lots iden�fying proper�es that
likely fall under the City's 15 percent hillside standard (BMC 17.100), so parcels probably subject

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to local hillside review can be iden�fied directly in the inventory, dis�nct from the acreage-based
slope-band layer.

9.3 Coastal constraints
As a coastal city, Brookings requires overlay analysis beyond zoning. Coastal shoreland management areas
(Goal 17 / OAR 660-008-0100), estuarine resource areas (Goal 16), and beach-and-dune areas (Goal 18)
were reviewed against the residen�al inventory. The County Conserva�on Zone is a Curry County
conserva�on designa�on, labeled "Coastal Conserva�on" in TM2 and is used as a mapped constraint,
contribu�ng to the combined total.

10. Net Buildable Acreage
Net buildable acreage was calculated by subtrac�ng the combined constraint surface from each parcel's
gross developable area. All "combined total" layers listed in Table X-1 were merged and dissolved into a
single non-overlapping surface so that land constrained by more than one factor is counted once, then
intersected with the buildable tax lots; the constrained area was subtracted to yield developable acres.
The result is a de-overlapped union rather than a sum of the per-layer acreages.
A professional-judgment rule was applied to parcels le� with only a small developable remnant. Where
subtrac�ng environmental constraints would leave a quarter-acre (0.25 acre) or less of developable area
(an amount that could technically classify the parcel as fully constrained and remove it from the buildable
inventory) the parcel was nonetheless retained as buildable if it shared clear characteris�cs with
neighboring tax lots that are already developed. In those cases, the parcel is assumed eligible for singleunit development comparable to the established surrounding development patern. Retaining these
parcels produces a more accurate representa�on of what is actually buildable rather than removing them
as fully constrained, which would understate developable condi�ons where the surrounding
neighborhood demonstrates that comparable development is feasible.

11. Residen�al Density and Capacity
Residen�al capacity was es�mated by applying density assump�ons to net buildable acres by zone and
jurisdic�on (City and unincorporated UGB), examining both actual and intended density. Zones were
grouped into three density categories:
Category

Threshold

Low

≤ 8 dwelling units per acre

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Category

Threshold

Medium

> 8 and ≤ 16 dwelling units per acre

High

> 16 dwelling units per acre

Density summaries use the Dominant Zone for split-zone parcels. The Lone Ranch master planned
development (MPD) (three South Coast Lumber tax lots totaling roughly 512.63 GIS acres) is reported as
its own line rather than absorbed into a standard density category, because its planned-development
character and large scale would distort per-zone density figures. These zone-based density categories are
dis�nct from the parcel-level RBLI Primary Density Category atribute, which classifies the MPD differently;
the two should not be conflated when reproducing the TM2 tables.

12. Data Delivery and Public Access
The dra� inventory is published as a hosted feature layer (DRAFT_Residen�al_Buildable_Lands_Inventory)
on the City's ArcGIS Online organiza�on. It feeds two public-facing ArcGIS des�na�ons: the project's
Housing Needs Analysis (HNA) Hub site, and an RBLI ArcGIS Experience Builder applica�on that presents
the buildable lands map and its suppor�ng data. The RBLI Experience Builder applica�on is embedded
within the HNA Hub site. A community housing survey was administered through Survey123, and its
results were incorporated into the HNA.
As a project deliverable, a file geodatabase will be delivered to the City once the inventory is finalized. It
will assemble the datasets underlying the analysis in a single package: the final RBLI tax lot layer, the Urban
Growth Boundary, the city limits, the city and county zoning layers, and each of the environmental
constraint layers used in the analysis. Every layer will be accompanied by appropriate metadata.

13. Limita�ons and Assump�ons
●

LiDAR vintage. Slope is derived from 2008–2009 LiDAR, the best available high-resolu�on
eleva�on data for the South Coast. Slope paterns are stable over this period, but recent grading
is not reflected.

●

Comprehensive plan GIS. Reliable comprehensive-plan-designa�on geometry was unavailable, so
zoning was used as the primary land-use basis, as permited under OAR 660-038.

●

Split-zone atribu�on. Density and capacity for split-zone parcels rely on the Dominant Zone
because unit and address data cannot be atributed below the parcel level.

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●

Developability horizons (analysis ongoing). A set of fields es�ma�ng the developability of vacant
and par�ally vacant land across 7-, 10-, 14-, and 20-year horizons has been added to the inventory
and remains under development. This horizon analysis is not yet folded into the buildable land
supply reported in TM2; it is noted here as an ongoing extension of the inventory and will be
incorporated.

●

Boundary acreages. GIS-computed city-limit and UGB acreages may differ from published figures
as noted in Sec�on 4.

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Brookings Housing Needs Analysis - Appendix B
Community Engagement Summary

Brookings-Harbor Community Housing Survey and Public Outreach Record

A. Purpose and Statewide Planning Goal 1 Alignment
This appendix documents the public engagement conducted for the City of Brookings Housing Needs
Analysis (HNA) and summarizes the results of the community housing survey. It is provided in fulfillment
of Oregon Statewide Planning Goal 1 (Ci�zen Involvement), which requires that the public be given
meaningful opportuni�es to par�cipate in land use planning and that the engagement process be
documented as part of the record.
The engagement described here was designed to reach a broad cross-sec�on of the Brookings-Harbor
community including residents, property owners, renters, workers, seniors, and households experiencing
housing instability using mul�ple channels of engagement types over a sustained period. The survey
findings in Sec�ons D through H, together with the stakeholder engagement summarized in Sec�on I,
reflect what the community and the project’s stakeholders iden�fied as the area’s most significant housing
challenges and needs. Sec�on J organizes these findings into community-iden�fied priori�es that will
inform the HNA’s Targeted Implementa�on Framework, the chapter presen�ng the plan’s recommended
policy changes.
As an opinion survey distributed through open public channels, the survey reflects the views of those who
chose to respond and is not a sta�s�cally representa�ve sample of the community. Its value is in
discovering the priori�es, concerns, and lived experiences of an engaged public, which are considered
alongside the quan�ta�ve housing analysis presented in the main body of the HNA.

B. Engagement Methods and Reach
Public input was gathered primarily through an online community housing survey, supported by a mul�channel outreach effort. The survey was built in ArcGIS Survey123 and hosted on a dedicated ArcGIS Hub
project site, accessible by phone, tablet, or computer. A QR code and short URL were placed on printed
materials to allow quick access from flyers and in-person outreach. Both the Hub and Survey123 are
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available in Spanish by toggling a language selector on either URL. The channels used to promote
par�cipa�on are summarized below.
Outreach channels
●

Project website (ArcGIS Hub): a public-facing site with project informa�on, documents, and a
direct link to the survey.

●

ArcGIS Survey123 online survey: the primary survey tool, distributed by direct link, short URL, and
QR code.

●

U�lity-billing email: the survey link was included in two City u�lity-billing communica�ons,
reaching a broad base of local households. A first distribu�on occurred in June 2026 and a second
in August 2026.

●

KURY radio: an on-air segment about the HNA encouraged residents to take the survey; the project
team principles were interviewed by sta�on staff on a segment aired the morning of July 13, 2026.

●

Facebook and social media: the project and survey were promoted through the City of Brookings
Facebook page. The project launched with a Facebook promo�on on June 9, 2026, and the City
published a Facebook post on the morning of July 13, 2026 to reinforce the KURY segment’s onair call to ac�on. The City also provided support through its social media channels and resident
newsflash emails.

●

Project one-pager: a printed and digital one-page summary of the HNA was completed and
distributed to explain the project and direct residents to the survey.

●

Stakeholder engagement: a standing stakeholder group provided input at working mee�ngs (see
Sec�on I, below).

●

In-person community outreach: the project team engaged residents at two Music in the Park
events at Azalea Park, held June 21 and July 12, 2026.

●

Community-partner outreach: with stakeholder Sr. Cora Rose, the project team iden�fied
addi�onal local organiza�ons serving seniors, lower-income households, and housing-insecure
residents (food and meal programs, income-restricted housing communi�es, and social-service
providers) as avenues to extend the survey’s reach beyond online channels. Contact was made to
many of the suggested programs, though not all were reached. The Chetco Community Public
Library verified pos�ng materials in their lobby.

Traffic sources and reach

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Analysis of project website traffic during the outreach period showed that social media was the leading
source of visits to the project site. When Facebook’s several link variants are combined, Facebook was the
single largest referral channel, ahead of direct visits. A large share of the remaining “direct” traffic is
atributable to “dark social”: links opened from stakeholder emails, texted links, QR-code scans, and
printed materials, which typically report as direct. Together, social media and email/print-driven traffic
were the two dominant pathways to the survey, confirming that the mul�-channel approach, rather than
any single channel, drove par�cipa�on.

C. Par�cipa�on Timeline and Response Drivers
The survey collected 494 responses between June 8 and August 6, 2026. Par�cipa�on was not steady over
�me; it arrived in dis�nct waves that align with the outreach ac�ons above. Daily counts below bin each
submission by its date.
Response Wave Event

Date

Responses

Facebook post: survey launch

June 9, 2026

110

June u�lity-billing distribu�on

June 24, 2026

118

Mid-July promo�on: KURY radio segment and City July 13, 2026
Facebook post

27

The launch wave was generated by the project’s Facebook promo�on beginning June 9 (110 responses
that day, with roughly 75 more over June 10–12 as the post con�nued to circulate) The consolidated
response-�meline analysis atributes this wave to Facebook. The second wave was the June u�lity-billing
distribu�on, which produced the single largest day (118 on June 24, plus 31 the following day). A third,
smaller wave appears on July 13 (27 responses, against one to five on the surrounding days), driven by the
KURY radio segment that aired that morning together with the City’s Facebook post reinforcing the on-air
call to ac�on. Across all three waves, the patern is consistent: each surge follows a specific, dated outreach
ac�on, underscoring that the mul�-channel approach (social media, radio, u�lity-billing email, and inperson events) sustained par�cipa�on. In-person outreach le� a smaller but iden�fiable footprint as well:
the first Music in the Park event at Azalea Park on June 21 corresponds to a modest same-day bump of
roughly eight responses, which the consolidated analysis flagged as community outreach. There were also
a small number of surveys manually added by Green Top as a result of conversa�ons had during these
outreach events.

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Note on the August u�lity billing: a second u�lity-billing distribu�on occurred in August 2026. This export
closes on August 6, 2026 and contains only two August responses, so any par�cipa�on generated by the
August billing is not yet captured here. The survey will close on September 1st and a full reconcilia�on of
the surveys will occur at that �me.

D. Who Responded
Par�cipa�on was strong for a community of this size and skewed toward people directly connected to
Brookings. Roughly seven in ten respondents live within city limits, and homeowners outnumbered renters
by more than three to one, a tenure split worth keeping in mind when weighing the results. Respondents
also skewed older, consistent with the area’s demographics. More than half were aged 55 or older.
Respondent profile

Count

Total responses

494

Live within Brookings city limits

336 (69%)

Live in unincorporated Harbor

77

Live elsewhere in Curry County

51

Own their home

340

Rent their home

101

Live with family / others, or in an unstable situa�on

32

Aged 55 or older

270 (56%)

Households with children under 18

135

Households with an adult age 65 or older

210

Substan�ve open-ended comments

221

Household income was distributed across the range, with meaningful representa�on at lower income
levels: 56 respondents reported household income of $30,000 or less and 103 reported $30,000–$60,000,
together roughly a third of those who answered (60 preferred not to say).

E. Most Significant Housing Challenges
When asked to name the most significant housing challenges in the area, one issue dominated: the cost
of housing rela�ve to local incomes, men�oned by more than four in five respondents. A shortage of rental
housing followed clearly in second. Notably, short-term rentals reducing long-term availability ranked
third, flagged by roughly half of all respondents. This is a community-driven concern that emerged strongly

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in the open-ended comments as well. Percentages are of the 478 respondents who answered this
ques�on; totals exceed 100% because mul�ple selec�ons were allowed.
Challenge

Share

Housing costs are too high rela�ve to local incomes

82%

Not enough rental housing available

67%

Short-term rentals are reducing long-term availability

51%

Lack of housing for people experiencing homelessness

41%

New housing development is not keeping pace with demand

38%

Not enough workforce housing

36%

Not enough housing op�ons for seniors / older adults

35%

Too many homes in poor condi�on

32%

How renters and owners differ
Renters and owners agree on the top three challenges but weigh them very differently, with renters
expressing markedly higher concern on each. This divergence is important for policy design, since renters
are directly exposed to the cost and supply pressures the survey iden�fies. Totals exceed 100% because
mul�ple selec�ons were allowed
Challenge

Renters

Owners

Housing costs too high rela�ve to incomes

95%

75%

Not enough rental housing available

80%

61%

Short-term rentals reducing availability

62%

45%

F. Housing Types the Community Wants More Of
Asked what types of housing the area needs more of, respondents pointed clearly toward the “missing
middle” and atainable ownership: smaller and starter homes led, followed by single-family homes for
purchase, apartments and mul�family rentals, and affordable or subsidized housing, each named by
roughly half or more. Senior housing, condos and townhomes, transi�onal or emergency housing, and
accessory dwelling units (ADUs) all drew meaningful support. Percentages are of the 485 respondents who
answered this ques�on; totals exceed 100% because mul�ple selec�ons were allowed.
Housing type

Share

Smaller / starter homes or cotages

65%

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Housing type

Share

Single-family homes for purchase

60%

Apartments or mul�family rentals

54%

Affordable / subsidized housing

50%

Senior or assisted-living housing

32%

Condos or townhomes

27%

Transi�onal or emergency housing

26%

Accessory Dwelling Units (ADUs)

21%

Manufactured or mobile homes

12%

G. Lived Housing Experiences
Respondents were also asked whether they had personally experienced specific housing difficul�es in the
past three years. About half selected “none of the above,” consistent with the homeowner-heavy
respondent pool; among the rest, difficulty finding housing and inability to afford a home were the most
common experiences, reinforcing the affordability and supply themes. Percentages are of the 474
respondents who answered.
Experience in the past three years

Share

None of the above

52%

Difficulty finding housing in the area

33%

Could not afford to buy a home in the area

32%

Could not find housing that fit my needs

21%

Rent increased significantly / was priced out

21%

Had to move farther from work due to housing costs

7%

H. Respondents’ Own Words
The survey drew 221 substan�ve open-ended comments. These comments deepen and, in places, extend
the closed-ended results, most notably by naming the cost and process of building housing (permits, fees,
and system development charges) as a barrier. The clusters below indicate how frequently each theme
appeared in the writen comments.
Open-ended comment theme

Frequency

Short-term / vaca�on rentals reducing supply

33 comments

Workforce, wages, and young families unable to stay

31 comments

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Open-ended comment theme

Frequency

ADUs, density, and “missing middle” housing

26 comments

Permi�ng, fees, and system development charges (SDCs)

23 comments

Seniors, aging, and fixed incomes

23 comments

Homelessness and the need for transi�onal housing

21 comments

Out-of-town, re�ree, or cash buyers driving up prices

11 comments

Aging or poor-condi�on housing stock

7 comments

A representa�ve selec�on of comments (lightly edited for length):
“I make ‘good money’ according to most people’s es�ma�ons. I am s�ll en�rely unable to afford a home
in this area. In six years, the rent of my one-bedroom apartment has gone from $1,200 to over $1,600,
while my income has not risen accordingly.”
“There is a need for affordable housing for seniors and young families looking to rent or own in the area.
Low-income seniors and young working families are being priced out.”
“Fixer-uppers run $500K+, addi�ons cost $500 per square foot, and permits alone top $30K. Brookings
housing is unworkable at every income level.”
“Need to limit short-term rentals to free up the limited supply of homes.”
“Stop penalizing homeowners who want to have ADUs by imposing excessive city fees.”
“To build a vibrant community, one must consider housing for our young people and our workforce that
matches their income.”

I. Stakeholder Engagement Summary
Alongside the public survey, the project team convened a stakeholder group to provide focused, itera�ve
input across the analysis. The group met three �mes during the study’s technical phase, May 18, June 22,
and July 13, 2026, in hybrid in-person and Zoom sessions, with a fourth mee�ng scheduled for August 17,
2026 to review the Dra� HNA and Targeted Implementa�on Framework. The first mee�ng was a structured
listening session; the second and third paired technical reviews (the Residen�al Buildable Lands Inventory
and the capacity and density analysis) with stakeholder feedback. Because the group is small and meets
in a working se�ng, its input is qualita�ve and delibera�ve rather than sta�s�cal.
Par�cipants

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The group brought together the perspec�ves most central to local housing supply:
●

Skip Watwood, Century 21 Agate Realty (real estate and local market)

●

Mayor Phoebe Pereda, City of Brookings

●

Clayton Malmberg, Brookings City Council

●

Jeff Groom, CFO, South Coast Lumber (major local employer)

●

Sr. Cora Rose, St. Timothy Episcopal Church (faith community; homelessness and housing-access
advocacy)

●

Hui Rodomsky, Oregon Department of Land Conserva�on and Development (state planning)

●

Diana Carter, CORE Response (homelessness services)

What stakeholders priori�zed
Workforce housing as the central concern. The group repeatedly framed workforce and entry-level
housing as the core issue. A major-employer representa�ve described difficulty recrui�ng and retaining
millwrights, electricians, and office staff for want of housing, with roughly a third of that workforce
commu�ng from Crescent City; the Mayor and others noted that police officers and teachers cannot afford
to buy locally. Stakeholders described an oversupply of homes above roughly $625,000 against an
undersupply of atainable workforce housing.
Atainable ownership and the ‘missing middle.’ There was clear appe�te for smaller, basic starter homes
with small yards (explicitly preferred over duplexes), cotage homes, and townhomes, enabled by smaller
lot sizes (3,000–4,000 sq �), increased R-1 density, and planned unit developments.
Policy and code levers. Dis�nct from the survey, stakeholders focused heavily on tools: system
development charge (SDC) deferral and the City’s workforce-housing SDC waiver, smaller-lot and density
code changes, PUDs, a Gold Beach-style streamlined residen�al zone, and a standing review of whether
current policy is poten�ally a barrier to development. The recurring goal for the group is the development
of the Targeted Implementa�on Framework, the high-impact strategies the City can act on.
Land supply, buildable land, and jurisdic�on. Stakeholders engaged the buildable-lands findings directly:
limited developable land, most of it in county RR-5/RR-10 that will not develop at density without
annexa�on; a city medium-density land deficiency offset only by coun�ng the unincorporated UGB; and
Lone Ranch as the largest single tract. They encouraged priori�zing infill on land already inside the city
before pursuing a UGB amendment or annexa�on.

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Harbor annexa�on. DLCD favored bringing Harbor into the city through the HNA, while local stakeholders
viewed near-term annexa�on as unrealis�c, ci�ng infrastructure and sewer costs, a 15-to-20-year horizon,
and community disinterest, but kept longer-term op�ons (agriculture lands south of Harbor, SB 1537 land
exchange) open for later study.
Infill on exis�ng buildings. Stakeholders saw untapped capacity in ADUs (allowed but underused, with a
call for informa�ve pamphlets) and in residen�al above commercial in the C-3/C-4 zones, no�ng business
owners who were unaware they could add upper-floor housing for workers.
Infrastructure as a hard constraint. Water and sewer capacity, especially in Harbor, was treated as a real
cap on where housing can go; the study’s infrastructure-grant origins were seen as posi�oning the City to
fund growth-enabling improvements.
Parallels and differences between the stakeholder and public groups
The two par�cipant types converge strongly on the core diagnosis and diverge on a few telling points. Both
independently iden�fied affordability rela�ve to local incomes as the central problem; both called for
smaller starter homes and missing-middle types (cotages, townhomes, small-lot single-family, ADUs, and
housing above commercial space); and both described local single-family stock being absorbed by re�rees
and higher-income buyers while workers and young families are priced out. The table below maps the
main themes across the two groups.
Theme

Public survey

Stakeholder group

Convergence

Affordability vs. local
incomes

Top concern (82%)

Central framing

Strong

Workforce/entry-level
housing

36%; ‘can’t stay’ (31
comments)

Leading theme

Strong

Smaller/starter & missing
middle

Most-wanted type (65%)

Small lots, cotages,
townhomes

Strong

ADUs & housing above
commercial

ADUs 21%; fee complaints

Underused; C-zone upper
floors

Aligned

Buyers pricing out locals

Raised in comments

Re�ree/higher-income
buyers

Aligned

Development cost
(permits, fees, SDCs)

Barrier/grievance (23
comments)

Lever to tune (SDC waiver)

Same issue, opposite
framing

Rental supply & rent
increases

67% (80% of renters)

Acknowledged; ownershipleaning

Par�al

Short-term rentals

Top-three driver (51%)

Less emphasized in
discussion

Different emphasis

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Theme

Public survey

Stakeholder group

Convergence

Homelessness/transi�onal
housing

41%; recurring

Less emphasized in
discussion

Different emphasis

Land supply, RBLI,
annexa�on, UGB

Out of scope for public

Major focus

Stakeholder-only

Senior housing/aging in
place

Senior/older-adult op�ons a
gap (35%); senior housing
wanted (32%)

Raised indirectly (downsizing
barriers)

Par�al

The clearest difference is short-term rentals: named by half of survey respondents (and 62% of renters) as
a driver of lost long-term supply, with many explicit calls to limit them. The two groups also frame
development cost from opposite ends with the public iden�fying it as a barrier (‘permits alone top $30K’),
and stakeholders iden�fying a lever to tune (the workforce-housing SDC waiver and SDC deferral). These
statements viewed together make development cost one of the best-supported themes across both
groups. Finally, the stakeholder group engaged the supply-side and regulatory machinery (buildable-land
supply, zoning and lot-size reform, annexa�on, the UGB, and infrastructure) that the survey by design did
not, while the survey captured lived-experience detail at a scale the small group could not. The two are
complementary inputs.

J. Community - Iden�fied Priori�es Informing the Targeted Implementa�on Framework
The following priori�es emerged from the survey with sufficient strength across both the closed-ended
results and the open-ended comments to warrant considera�on in the HNA’s Targeted Implementa�on
Framework. The stakeholder group (Sec�on I) independently reinforced most of them, especially
workforce and missing-middle housing, atainable ownership, ADUs and upper-story housing, and
development-cost levers, while the survey carries the stronger signal where the two diverge, notably on
short-term rentals and housing for people experiencing homelessness. Each priority below is a summary
of community input, not a recommenda�on. The Framework chapter will determine which of these
translate into specific policy changes and how; the illustra�ve policy direc�ons noted here are offered only
to show the kind of measure each priority points toward and will be evaluated against the HNA’s technical
findings, legal requirements, and City capacity.
1. Affordability rela�ve to local incomes

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Community input: The single strongest theme in the survey. Cost rela�ve to local incomes was men�oned
by 82% of respondents overall and 95% of renters, and was included in the open-ended comments,
including from higher earners who s�ll cannot afford to buy.
Illustra�ve policy direc�ons to evaluate: Tools that expand income-aligned housing and reduce the gap
between local wages and housing costs. For example, affordability-oriented land use and financing
measures considered in the sec�ons below.
2. Rental supply and mul�family housing
Community input:Two-thirds of respondents (67%) named a shortage of rental housing, rising to 80%
among renters. Apartments and mul�family rentals were among the most-requested housing types (54%).
Comments described extreme scarcity, including a single rental drawing dozens of applicants within days.
Illustra�ve policy direc�ons to evaluate: Measures that enable and encourage rental and mul�family
produc�on including zoning capacity, allowed densi�es and housing types, and removal of barriers to
mul�family development.
3. Short-term rentals and long-term housing supply
Community input: A dis�nctly community-driven priority. Half of respondents (51%, and 62% of renters)
flagged short-term rentals as reducing long-term availability, and it was the most frequent open-ended
theme (33 comments), with repeated, explicit calls to limit short-term rentals.
Illustra�ve policy direc�ons to evaluate: Short-term rental policy. For example, registra�on, caps, or
zoning-based limits as a lever specifically raised by the public to protect long-term housing stock.
4. Missing-middle and starter homes, including ADUs
Community input: The clearest direc�on on housing type: smaller and starter homes led all responses
(65%), and ADUs, condos/townhomes, and duplex-scale housing drew steady support (ADUs 21%).
Comments repeatedly cited zoning limits and excessive ADU fees as obstacles to this type of housing.
Illustra�ve policy direc�ons to evaluate: Code and standards changes that make missing-middle housing
and ADUs easier and cheaper to build. For example, allowed uses, lot and dimensional standards, and
ADU-specific fee relief.
5. Cost and process of building housing (permits, fees, and SDCs)

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Community input: Although not offered as a fixed answer choice in the survey, the cost and complexity of
permi�ng, fees, and system development charges was one of the most-raised open-ended themes (23
comments).
Illustra�ve policy direc�ons to evaluate: Development-process and cost measures. For example, fee or
SDC reduc�ons, deferrals, or waivers for targeted housing types, and permit streamlining.
6. Workforce housing and keeping young families
Community input: Workforce housing was named as a challenge by 36% of respondents, and ‘can’t
stay/priced out’ was the second-largest open-ended theme (31 comments), naming teachers, nurses, first
responders, and young families as those being lost.
Illustra�ve policy direc�ons to evaluate: Housing �ed to local employment and atainable to working
households. For example, workforce-targeted housing programs and incen�ves, and housing types
matched to local wages.
7. Senior and fixed-income housing
Community input: Consistent with the area’s older demographics, 35% named a shortage of senior
housing op�ons, senior/assisted-living housing was a top-requested type (32%), and 23 comments spoke
to aging in place on fixed incomes.
Illustra�ve policy direc�ons to evaluate: Housing op�ons that serve seniors and fixed-income households.
For example, senior and assisted-living housing, aging-in-place-friendly standards, and accessible smallerunit types.
8. Housing for people experiencing homelessness / transi�onal housing
Community input: A lack of housing for people experiencing homelessness was named by 41% of
respondents; transi�onal or emergency housing was requested by 26%; and 21 comments addressed
homelessness directly.
Illustra�ve policy direc�ons to evaluate: Transi�onal, emergency, and suppor�ve housing pathways,
coordinated with service providers and regional partners.

These priori�es point toward a small number of high-leverage focus areas; atainable ownership and rental
supply, the missing middle and ADUs, the cost and process of building, short-term rental impacts, and

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housing for specific popula�ons (workforce, seniors, and people experiencing homelessness). Narrowing
them to policy changes of the Targeted Implementa�on Framework is the work of that chapter; this
appendix establishes the community mandate on which those choices are informed.

K. Methodology and Data Notes
●

Stakeholder engagement: the Sec�on I summary draws on the notes from Stakeholder Mee�ngs
#1–#3 (May 18, June 22, and July 13, 2026); statements are paraphrased from those notes. A
fourth mee�ng (August 17, 2026) on the Dra� HNA and Targeted Implementa�on Framework will
be added to the final record.

●

Instrument and pla�orm: a community housing survey built in ArcGIS Survey123, hosted on an
ArcGIS Hub project site, open to any respondent via link, short URL, or QR code.

●

Dataset: 494 responses, collected June 8-August 6, 2026.

●

Mul�-select ques�ons: the challenge, housing-type, and experience ques�ons allowed mul�ple
selec�ons, so shares sum to more than 100%. Reported percentages use the number of
respondents who answered that specific ques�on as the denominator (noted in each sec�on), not
the full 494.

●

Not sta�s�cally representa�ve: results reflect self-selected par�cipants reached through public
channels and skew toward homeowners and older residents. They are intended to complement,
not replace, the quan�ta�ve analysis in the HNA.

Open-ended comments: 221 substan�ve comments were reviewed and grouped into recurring themes;
theme counts reflect the number of comments touching each theme and are approximate, as a single
comment may include more.

Prepared by

4495 South Pacific Highway
Phoenix, Oregon
97535

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