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1990-02415-Minutes for Meeting January 17,1990 Recorded 1/26/199090-02415
PUBLIC HEARING MINUTES
SURFACE MINING ORDINANCE 89-011
I t 19) - 1180
DESCHUTES COUNTY BOARD OF COMMISSIONERS
January 17, 1990 Chair Throop opened the public hearing at 1:35 p.m. Board members
in attendance were Dick Maudlin, Tom Throop and Lois Bristow
Prante. Also present were Karen Green, Community Development
Director; George Read, Planning Director; and Bruce White,
Assistance Legal Counsel.
Chair Throop announced that the Board would be leaving the record
open through the close of business on Wednesday, February 7, 1990,
for written testimony; and that after the oral testimony was given
today, the public hearing would be continued to 11 a.m. on
February 7, 1990, for additional oral testimony.
George Read gave the staff report. He said this was the second
public hearing on the draft surface mining zoning ordinance which
also included the surface mining impact area combining zone which
affected uses on property within one half mile of SM zoned
property.
He said at the previous hearing there had been considerable written
and oral testimony which had been taken into consideration when
rewriting the current draft. The section regarding excavation that
had been attached to the back of the previous draft had been
removed from the ordinance. He said one of the major changes in
the ordinance was the removal of the specific use standards which
had been incorporated into the general operation standards of the
ordinance. He said that crushing, which had been originally
proposed as an outright use, had been moved to the conditional use
section. Any site specific restrictions that the Board placed on
individual surface mines as part of the ESEE analysis hearings
would be imposed in addition to the surface mining ordinance, or
if the Board's restrictions were more lenient than the ordinance,
they would prevail over the ordinance.
He said the statutory language defining surface mining and
determining what would be regulated by the Counties was changed by
the legislature in their last session. They required Counties to
regulate resource lands with 1,000 cu yds of material and more.
The present county ordinance regulated sites with 2,500 cu yds of
material and more.
One other issue that had been left out of the earlier draft of the
ordinance was where batch plants and concrete plants should be
allowed. The statutory language changed to say that batch plants
and concrete plants had to be located at least two miles from
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, t.10 ° 1181
vineyards. So the County used this two-mile limit for the minimum
distance from residences as well. He said this limit was
restrictive but that those uses were generally considered
industrial uses, and there was industrial zoned land available in
the county. Where someone could show that the use was dependent
upon a resource, they could apply for a limited use combining zone.
He said the staff felt that this process allowed flexibility in the
location of batch plants and also provided protection for the
neighborhoods. He said they viewed it as a separate process from
the ESEE analysis and Goal 5 analysis that had been done in zoning
the property SM. He said that each site should be considered on
its own individual merits.
He said he had received letters from the Department of
Environmental Quality, Oregon Department of Fish & Wildlife, and
Oregon Department of Transportation Parks and Recreation. They
substantially stated concurrence with the revised ordinance.
Brent Lake, Department of Land Conservation and Development, said
he appreciated that the Board was leaving the record open for an
additional three weeks. He said they would have a recommendation
for the County that could work out some of the differences that
have appeared at the hearings. He said the DLCD would grant the
county an extension of time for an additional month to the end of
February for the submission of its SM package. He said the revised
ordinance was far superior to the previous draft.
William Miller, Central Oregon Pumice Company, #1 NW Greenwood,
Bend, said he appreciated having more time to make comments. His
first question was regarding pg 5, item F where it allowed the
processing of aggregate into asphalt or portland cement as a
conditional use. He asked why the processing of other minerals was
not listed as a conditional use. He used the example of processing
pumice into soap on the site. George Read said under the ordinance
it would not be allowed without applying for the Rural Industrial
Zone which could be approved as a limited use combining zone.
Mr. Miller felt that the processing of any minerals should be
allowed as a conditional use.
Commissioner Maudlin asked why the processing of aggregate into
asphalt should be allowed as a conditional use. George Read said
the initial draft did not include it, however, the State Highway
Division located those types of plants in conjunction with Highway
projects, so it was added as a legitimate and historic use. Also
for the first time, the legislature specifically allowed aggregate
processing into asphalt in resource zones, so the staff felt it
should be added to the ordinance for discussion. He personally
felt processing plants were more appropriately located in
industrial zones, except for the historic highway project use.
However, he was not sure that the Board had the latitude to deviate
from the state statute without taking an exception to the statewide
planning goals.
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Mr. Miller's second issue was on screening. He said screening was
expensive. Commissioner Maudlin pointed out that the ordinance
said that if the topography was such that screening wouldn't do any
good, he wouldn't have to screen.
Mr. Miller's next questioned what the benefits were of being a
preexisting site. George Read told him that unless the operation
was expanded beyond what was covered by a state or county permit,
it would not have to comply with the ordinance.
Commissioner Maudlin questioned what "produced" and "products"
meant in Page 4, Section 3, D. George Read said the mineral became
a "product" when something was done to the mineral to make it
different. Karen Green felt the intention of the word "product"
here was to mean the mineral product crushed down to a certain size
or screened to a certain size rather than a secondary product such
as cement, concrete, asphalt or cinder blocks. However, she said
the terminology was not clear and needed to be refined.
Frank Parisi, 520 SW Yamhill, Portland, OR 97204, said he was the
attorney for the Oregon Concrete and Aggregate Producers
Association and R. L. Coats. He said he was the attorney who filed
the appeal on Deschutes County's acknowledgement. He and his
clients wanted to be in a position where they didn't have to make
any further appeals in Deschutes County. He said the current draft
ordinance was a tremendous step forward from the previous draft,
and there were now clear and objective standards in most cases.
However, he did not agree with the noise standard which was a
distance standard. What they wanted was a performance standard.
He said that if there was a distance standard of a one-half or two
mile set back, they would need to have a half or a whole section
before there could be any mining. They would prefer performance
standards, i.e. for a crushing or processing operation, the
performance standard could be, for example, "no more than 10 dba
above the ambient noise level." He said on some sites that might
mean a building would have to be built around the crusher. He said
this would give the miners a specific standard to deal with.
Mr. Parisi said everyone needed to keep asking themselves whether
the new ordinance would allow any new surface mining sites. He
said if the end result of the ordinance was no new sites, then the
ordinance did not work.
Mr. Parisi said he did not feel that the language in the ordinance
stated clearly that the ESEE analysis always controlled over the
ordinance. Karen Green agreed that language should be added to
say that in the event there was a conflict between the site
specific set backs specified in the ESEE analysis and the Ordinance
standards, that the ESEE analysis standards would control.
PAGE 3 MINUTES: 1/17/90
100 1183
Mr. Parisi said the Comprehensive Plan Policies adopted one year
ago were more consistent with the prior draft of the ordinance and
needed to be revised also. Karen Green said staff was in the
process of reviewing the Goals and Policies which were adopted a
year ago for conformance with this draft. She said the Board would
be adopting them again in February and that a public hearing might
be scheduled if there was enough interest.
Mr. Parisi said he understood that the county couldn't do
reclamation and that only the Department of Geology and Mineral
Industries (DOGAMI) could. Karen Green said it was the County's
intention that the standards for the County and DOGAMI be the same,
and that the County would work cooperatively with DOGAMI on a joint
site and reclamation planning process. DOGAMI would be involved
in the technical, mining technique part of the operation, with the
County being involved in the traditional land use aspects of
reclamation. She said it would be a part of DOGAMI's reclamation
permit process. George Read said the County had had meetings with
DOGAMI regarding the criteria. DOGAMI was asked if they felt their
reclamation authority preempted Deschutes County's regulations in
any of these areas, and they said no. He said that DOGAMI felt
that at least 50% of the responsibility was the county's. He also
said that the statute required the county to regulate reclamation
on everything 1,000 cu yds and above that was not regulated by
DOGAMI, meaning sites with 1,000 cu yds but less than 5,000 cu yds
of material.
Mr. Parisi felt that if the County expected mine operators to pay
for damage done to the roads due to the mining operation, that in
order to be fair, the same requirement should be imposed on all
businesses, i.e. Safeway stores and lumber mills. He said any
assessment should be based on actual deterioration not presumed or
predicted deterioration.
Mr. Parisi said that the set back requirements should be
reciprocal. He felt that when a buffer was created between a
mining operation and a subdivision, all parties should have to move
back the same distance. George Read said that they had tried to
make the set backs identical. Mr. Parisi asked about the two mile
set back for processing. George Read said that would be an
exception.
Mr. Parisi asked a hypothetical question. If the ESEE analysis on
a given site allowed mining subject to certain restrictions under
3 (c) , and a homeowner wanted to build a home in a way which was
inconsistent with the ESEE analysis, would the prospective
homeowner have to seek an amendment to the comprehensive plan to
change the ESEE analysis? George Read said that an ESEE analysis
would have to be done as part of the site plan review in the
surface mining area impact zone. Karen Green restated that if a
property owner wanted to put a home where it had been prohibited
by an ESEE analysis, the property owner would have to provide a new
PAGE 4 MINUTES: 1/17/90
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ESEE analysis indicating that the mining operation could continue
and meet all of its requirements (i.e. noise and dust levels) with
the home at that site.
Robert L. Coats, mining operator, testified that he felt the new
draft ordinance was an improvement over the original, but he still
felt that it was too restrictive. He said that processing was
necessary at the surface mining site in order for it to be
economical and should be allowed outright. He gave the example of
a hard rock mine where they had to drill and shoot the rock which
would break out into big pieces which couldn't be moved to an
industrial site for processing. However, in a gravel operation,
he said it could be moved to an industrial site for processing.
He felt there should be just one permit from the beginning that
would authorize everything that would be allowed on the site. He
did not feel that it was economically feasible for a site to be
developed without knowing whether the processing permit would be
authorized later on. He said with these restrictions there
wouldn't be any new mines opening up in the county. He felt the
five acre limit for the mining site wasn't large enough for a
crusher, asphalt plant, and concrete plant. George Read pointed
out that the five acre limit was only for the pit, and that all of
the other items Mr. Coats listed were exempted from the five acre
limit. He said there was no limit on the size of the entire
operation. Karen Green said that Mr. Coats' concern had been
specifically addressed on page 15 where it stated that if the
mining techniques normally associated with that type of mining
required a larger extraction site size, an exception could be
requested. Commissioner Maudlin said the County wanted mine
operators to mine only five acres at a time, then to reclaim it
and open up another five acres, etc. Commissioner Maudlin said
that they did not want 30 or 60 acre holes in the ground.
Ted Keener, property appraiser, testified that he appreciated the
changes made in the new draft. He felt that any combining zone
should be recorded on all of the affected parcels so that when
someone contemplated buying the parcels, it would show up in a
title search. He also felt that if the mine was within 250 to
1,000 feet of homes, the hours of operation should be 8 a.m. to
5 p.m. He would like to see screening and washing as conditional
uses also since they could create as much noise as crushing.
Robert Windlinx, mine owner, testified that he felt the ordinance
was very complicated, and he didn't understand most of it. He said
his operation did a little more than 1,000 cu yds a year. He was
concerned that all the land within one-half mile of the pit was
excluded from tree harvests. George Read said that a site plan
review would be done for a proposed use in the surface mining zone,
and if it could be determined that the proposed use wouldn't be
negatively impacted by the surface mining zone, the proposed use
would be allowed. Mr. Windlinx asked if he could change a surface
PAGE 5 MINUTES: 1/17/90
I()U - 1185
mining zone back to RR-10 after it was reclaimed? Commissioner
Throop said yes, and that it was part of the reclamation process
to determine what the future use of the property would be, and then
zone the site appropriately. Mr. Windlinx asked whether there
would be a public hearing if this type of zone change was
requested. George Read said that any time discretion was exercised
in a land use decision, a public hearing would be required.
Randy Davis, Geologist for the State Highway Division, was
testifying for the state as a surface mining operator. He had six
questions regarding language interpretation.
1. On pages 5 & 6, Section 6, B and C. Mr. Davis was confused
since "B" referred to 250' from a noise or dust sensitive use
and "C" referred to storage and processing not allowed closer
than 1/4 mile. He felt that any surface mining activity would
create noise and dust, so he didn't understand when the 250'
set back would apply. George Read said he would discuss it
with him more extensively at another time.
2. Page 6, Section (d). Mr. Davis was not aware of what the ESEE
analysis and formal recommendations were on the State Highway
sites. Commissioner Throop said the document was not
finished, and he would be sent a copy when it was completed.
Karen Green said that minutes of the decision meetings were
now available.
3. Page 10, (c). Mr. Davis asked if this section meant that
aggregate stockpiles didn't need to be screened. George Read
said the ordinance did not require that stockpiles be
screened. Mr. Davis suggested that the stockpiles might be
used to help screen some of the activity on the site.
4. Page 19, Section 13, D, (b). Mr. Davis asked if the Highway
Department still had to get a conditional use permit when they
did temporary highway projects. George Read said they would
still need a conditional use permit. Karen Green said it was
necessary since the temporary plant might be located where
they couldn't otherwise put a plant.
Commissioner Maudlin said that when the surface mining process
began, processing meant extraction, blasting, crushing, etc.; and
now he felt it meant making black top. George Read said that up
until October of last year when the state law went into effect,
batch plants and concrete plants were not allowed under state
statute in resource zones, and, therefore, the original draft
ordinance didn't allow them. The statute was changed and now
allows batch plants and concrete plants, so they have been included
in the current draft ordinance as a conditional use. Karen Green
said they would attempt to clarify the language before the next
hearing. George Read reminded the Board that the County had to
amend its surface mining zoning ordinance about three years ago
PAGE 6 MINUTES: 1/17/90
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in order to remove batch plants and processing plants because they
weren't allowed under state statute at that time.
5. Page 20, Section 15(b). Mr. Davis asked what "exemption"
referred to here. Karen Green said it meant you would not be
subject to DOGAMI regulations. George Read said that if a
site was mined prior to 1972, there was one type of exemption,
and another type of exemption if it was mined prior to 1975,
and then there were other types of exemptions regarding the
extent that mining had occurred on the property. He said
there were various permits that were site specific on each
type of operation.
6. Page 20, Section (e). Mr. Davis asked what constituted an
expansion or alteration of the preexisting surface mining use?
For example, if they had a 40 acre site which had a valid
DOGAMI operating permit covering the total 40 acres, but they
had only opened up 3 acres of it, did the language mean they
could mine the whole 40 acres and still be exempt from the
ordinance. George Read said that the determination of the
preexisting limits of the site was very difficult and very
site specific and would be looked at based upon the extent of
the permit. George Read said that if DOGAMI wouldn't require
an additional reclamation plan, a new reclamation plan, or an
expansion of a reclamation plan for the area, then they would
not be subject additional regulation.
Mr. Davis asked whether they would be covered by the ordinance
if they had a preexisting permit covering one acre, and they
disturbed the area 500 yds from the preexisting boundary?
George Read said the County's ordinance was worded exactly as
the state statute, and therefore if DOGAMI required a permit,
the County would also. George Read said when they expanded
beyond one acre, it became a surface mine, which would require
a permit and compliance with the ordinance. Mr. Davis said
DOGAMI wouldn't require it under those circumstances. He said
that DOGAMI wouldn't require a permit unless they went over
5,000 cu yds of material. George Read said the state statute
said exactly what DOGAMI rules said regarding what constituted
surface mining, except that the state statute required
Counties to regulate the mining of 1,000 cu yds or more of
material.
There was no one else who wished to testify.
PAGE 7 MINUTES: 1/17/90
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Commissioner Throop continued the public hearing until February 7,
1990, at 11 a.m. and said the Board would accept written comments
until 5 p.m. on February 7, 1990.
DESCHUTES COUNTY BOARD OF COMMISSIONERS
Lois Bristo Prante, Commissioner
Tom hroop, C j r
Dick Maudlin, Commissioner
BOCC:alb
PAGE 8 MINUTES: 1/17/90