1992-28236-Minutes for Meeting August 05,1992 Recorded 8/19/19920-19-0as0
92-2b236
MINUTES
DESCHUTES COUNTY BOARD OF COMMISSIONERS
August 5, 1992
Chairman Maudlin called the meeting to order at 9:30 a.m. Boa"rd
members in attendance were Dick Maudlin, Tom Throop and Nancy Pope
Schlangen. Also present were: Rick Isham, County Counsel; Bruce
White, Assistant County Counsel; Catherine Morrow, Planner; George
Read, Planning Director; Karen Green, Community Development
Director; Lieutenant Greg Brown, Sheriff's Department; and Paul
Blikstad, Planner.
1. CONSENT AGENDA
Consent agenda items before the Board were: #1, signature of
Resolution 92-065 supporting the formation of an animal
overpopulation taskforce; #2, signature of MP -90-52 creating
two 40 -acre parcels south of Plainview Road in an EFU-40 and
F-2 zone for Bob and Jeanne Ricketts; #3, signature of Order
92-064 designating The Bulletin for publication of
foreclosures for 1992-93; #4, confirmation of appointments of
Corinne Martinez, Steve Gold, Linda Stephenson, Sylvia Shields
and Bill Kopacz to the LaPine Economic Development Board; #5,
chair signature of liquor license renewals for Twin Lakes
Resort Restaurant and Store, and Paulina Lake Resort; #6,
signature of Rental Agreement with Darla Ginocchio for house
on county property being developed as the site for the new
county jail; #7, signature of Resolution 92-064 declaring two
IBM keypunch machines surplus property; #8, signature of tax
refund Order 92-084.
THROOP: I'll move approval of the eight consent agenda
items.
SCHLANGEN: Second.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
2. ACCOUNTS PAYABLE VOUCHERS
Before the Board were accounts payable vouchers in the amount
of $172.661.12.
SCHLANGEN: Move approval upon review.
THROOP: Second the motion.
PAGE 1 MINUTES: 8-5-92
3.
4.
5.
0119-031
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
REQUEST TO RESCHEDULE J -J APPEAL CU -92-40
Before the Board was a request from Robert Lovlien, attorney
representing John Cooley, Bill Herz, Cheryl Circle and John
Lindsey, who were the appellants in the appeal of a
conditional use requested by the J Bar J Boys Ranch. His
clients were concerned that there would not be enough time at
a day -time hearing for everyone to testify and suggested
moving the hearing to the evening.
The Board felt that they would be able to allow adequate time
for everyone to testify at the time and date the appeal was
originally scheduled.
COMMUNITY EVENT DISPENSER LICENSE APPLICATION
Before the Board was chair signature of the Community Event
Dispenser License Application for The High Desert Museum.
They would be holding the "Sagebrush Rendezvous" at the Hooker
Creek Ranch on Gerking Market Road on August 22 starting at
4 p.m.
SCHLANGEN: I move signature by chair.
THROOP: Second the motion.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
TEMPORARY BUILDING INSPECTOR
Before the Board was a request from Karen Green to hire a
temporary building inspector to help out with the work load
this summer. She said there were adequate funds to pay for
this position from the fees. Chairman Maudlin said that he
would make sure that Mike Maier, County Administrator,
processed this request as quickly as possible.
THROOP: I'll move approval subject to review.
SCHLANGEN: Second.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
PAGE 2 MINUTES: 8-5-92
0149--Q 2
6. DECISION ON WILDLIFE AND SURFACE MINING PACKAGE
Before the Board was signature of the Wildlife Area and
Surface Mining Package of ordinances. Ordinance 92-040 would
amend the Deschutes County Year 2000 Plan to adopt text and
goals and policies concerning fish and wildlife; Ordinance 92-
041 would amend the Plan to adopt inventories conflict
analysis and ESEE determinations for fish and wildlife
resources; Ordinance 92-042 would amend the Deschutes County
Zoning Ordinance concerning wildlife protection; Ordinance 92-
044 would amend the Plan concerning surface mining ESEEs;
Ordinance 92-045 would amend the plan to adopt national
wetlands maps; and Ordinance 92-046 would amend the Deschutes
County Code to amend zoning maps designating new wildlife area
zones.
MAUDLIN: I would entertain a motion for first and second
reading of Ordinance 92-044 by title only.
THROOP: I'll make the motion.
SCHLANGEN: Second.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
Chairman Maudlin performed the first and second readings of
Ordinance 92-044 by title only.
THROOP: Move adoption.
SCHLANGEN: Second.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
Chairman Maudlin asked which ordinance he had voted against
previously. Bruce White said he thought they were 92-041 and
92-042 because they both set forth the policy to defer any
consideration of the "Goal 8/Goal 5 mapping interface."
Chairman Maudlin said it was his understanding that the County
was totally mapping the wildlife areas and deleting
destination resorts from the listing of things not allowed in
the wildlife area combining zone, then adding a new Section C
stating that no one could apply for a destination resort until
the County had finished the Goal 8 mapping process before the
end of this year. He said "he was opposed to a great deal of
PAGE 3 MINUTES: 8-5-92
01. 19-0383
it" but felt the County needed to go ahead with this stage.
He hoped he would have the opportunity to express his opinion
and vote on the balance of destination resort and farm land
issues before leaving office. Bruce White said the staff was
working toward that goal, however the appeal's process could
delay it. He suggested that something might be worked out
that would allow Chairman Maudlin to vote on those portions
which weren't still subject to appeal.
THROOP: I'll move first and second reading by title only of
Ordinance 92-040.
SCHLANGEN: Second.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
Chairman Maudlin performed the first and second readings of
Ordinance 92-040 by title only.
THROOP: Move adoptionmittee
SCHLANGEN: Second.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
SCHLANGEN: Move first and second reading of 92-041 by
title only.
THROOP: I'll second the motion.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
Chairman Maudlin performed the first and second readings of
Ordinance 92-041 by title only.
THROOP:
SCHLANGEN:
VOTE:
Move adoption.
Second.
THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
-------------
PAGE 4 MINUTES: 8-5-92
0I 19-054
THROOP: Move first and second reading of Ordinance 92-042
by title only.
SCHLANGEN: Second.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
Bruce White said he wanted to add into this ordinance a
paragraph on findings which would incorporate the generic
findings and asked that the Board adopt the ordinance subject
to that addition.
Chairman Maudlin mentioned that in Exhibit A, page 2, (B) of
this ordinance, it listed golf courses as not permitted in
wildlife areas, and that destination resorts normally included
golf course. Therefore when the destination resort issue was
considered later in the year, if they were allowed in wildlife
areas, they wouldn't be able to have golf courses because of
this language. Catherine Morrow said the Planning Commission
recommendation was not to allow golf courses. When the
Planning Commission was addressing the destination resort
question, they were concentrating on using the possibility of
allowing limited destination resort activities (i.e. open
space trails, picnic areas) in the wildlife area. They never
contemplated extensive structural development or golf courses
or improved recreational facilities in a wildlife area.
George Read pointed out that was basically the Jaqua proposal
which never included golf courses. Catherine Morrow said no
testimony had been given concerning golf courses in wildlife
areas. Bruce White suggested that if the Board wished to
clarify that issue, he would suggest stating for the record
that by excluding golf courses as "stand alone" facilities,
the County was not in anyway prejudging what the Board would
decide when it considered the destination resort issue.
Chairman Maudlin said he would like the language in the
ordinance to say, "Golf course, not included in a destination
resort." Bruce White said he also felt that it should be on
the record that by placing this new language in the ordinance,
the Board was not prejudging the other direction on
destination resorts. The other Board members had no objection
to this change in language. Bruce White wanted to make the
record clear that what the Board was trying to do was leave
their options open and that this new language would not "weigh
the balance either way on destination resorts."
THROOP: I'll accept those
motion.
SCHLANGEN: Second.
PAGE 5 MINUTES: 8-5-92
as friendly amendments to the
019-0385
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
Chairman Maudlin performed the first and second readings of
Ordinance 92-042 by title only.
SCHLANGEN: Move approval.
THROOP: Second the motion.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
SCHLANGEN: I move first and second reading of Ordinance
92-045 by title only.
THROOP: Second the motion
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
Chairman Maudlin performed the first and second readings of
Ordinance 92-045 by title only.
SCHLANGEN: Move approval.
THROOP: Second the motion.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
SCHLANGEN: I move first and second reading of Ordinance
92-046 by title only.
THROOP: Second.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
Chairman Maudlin performed the first and second readings of
Ordinance 92-046 by title only.
SCHLANGEN: Move approval.
PAGE 6 MINUTES: 8-5-92
01 (9-WS6
THROOP: I'll second.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
7. PERIODIC REVIEW PACKAGE
This item was postponed to the following week.
8. SELECTION OF ARCHITECT FOR NEW COUNTY JAIL
Greg Brown said the eight member architect selection committee
had been working to pick the best architect for the new county
jail over the last three and a half months. They reviewed
thirteen proposals from interested firms. The proposals were
reviewed against selection criteria, i.e. design philosophy,
history of their company, the current and past corrections
experience. Those thirteen companies were reduced to four.
Several members of the committee traveled to five western
states and visited each of the architectural firms and
traveled to some of their completed projects. During the
tours, they were looking at the design of the facility, how
well it fit into the existing neighborhood, staffing level
needed, safety of staff, and per bed cost. In the last three
years, the facilities which had been built in Oregon varied in
price from $40,000 to $73,000 per bed with some county jails
costing more than $90,000 per bed. The committee met with
each of the firms, and then made its recommendation: Lombard
Conrad Architects from Boise Idaho. The company was owned by
Ernie Lombard and Joe Conrad who had been architects for a
number of years and had for this firm sixteen years. They
were licensed architects in good standing in Oregon. They had
completed approximately 22 correctional facilities in the
northwest. Their most recent project opened three week ago in
Yakima Washington. They had also done correctional projects
in Elko Nevada, Twin Falls Idaho, and Burley Idaho, and had
been hired to do the Malheur County jail. The committee was
extremely impressed with this company. He felt they would be
able to build the new facility for under $40,000 per bed.
This company was extremely adept at building correctional
facilities which required a minimum number of correctional
staff while ensuring a safe environment for the correctional
officers. He did a lot of background checking on the company
and could not find any clients who had anything bad to say
about them. Everyone was very impressed with them for the
work they did during the project and also their follow
through.
Commissioner Throop asked which Lombard/Conrad projects the
committee had visited. Greg Brown said they visited the
Yakima Jail, the Twin Falls County Jail, Burley Idaho County
PAGE 7 MINUTES: 8-5-92
Jail, and the County Work Release Center and the State
Penitentiary in Boise Idaho. Commissioner Throop asked what
kinds of people they spoke with at these facilities. Greg
Brown said they talked with sheriffs, county commissioners,
construction companies, corrections staff, prison guards, and
the superintendent of one of the prisons. They spent a lot of
time with the project coordinators who spent months working
with this firm. They also did that with each of the other
three companies which were under consideration. They visited
17 facilities in their tour. They visited a few jail which
were not done by any of the four competing architects for a
comparison to see what else was on the market.
Commissioner Schlangen commented that the committee had done
its homework. Chairman Maudlin felt the work that the
committee had done was excellent. Commissioner Throop said
the Board had heard independently that Deschutes County's
selection process was one of the best which these firms had
encountered. They were extremely impressed with how
thoroughly County staff scrutinized their firms and interview
people.
MAUDLIN: I would entertain a motion for the selection of the
architect as presented by the committee.
SCHLANGEN: So moved.
THROOP: I'll second the motion.
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
9. IMPLEMENTATION OF LUBA DECISION ON DESTINATION RESORT MAPS
Before the Board was consideration of whether to appeal the
recent LUBA decision remanding the County's destination resort
mapping ordinances back to the County; and how the Eagle Crest
destination resort expansion application should be handled in
light of this remand.
Bruce White said Eagle Crest had applied for a destination
resort expansion under the map which had been remanded by
LUBA, and it was County Legal Counsel's opinion that because
of the remand, the County no longer had a valid map. Both Mr.
Gardner and the County had chosen to appeal the remand which
added a complication to how Eagle Crest might be allowed to
proceed. He had submitted a memo to the Board with four
options on how to proceed, however he now felt that Option 1
was no longer available because of the appeals. It was
staff's opinion that the effect of the appeals was to stay the
remand from taking effect, which meant that the mapping
PAGE 8 MINUTES: 8-5-92
0119-0388
ordinances were "revived pending this appeal." However it was
possible at the end of the appeals process, that the last
reviewing body could determine that the map was not valid.
Chairman Maudlin said he felt the remand decision should be
appealed. The remand was asking the County to go back and
make a decision which would make LUBA happy, and he didn't
want to do that.
Commissioner Throop said the state looked at the decisions the
County made to see whether they met statutory and rule
requirements. If they didn't, they sent them back to the
County for further planning. Chairman Maudlin pointed out
that when it was sent back, there was no clarification of the
remand, so it could go back and forth a number of times before
LUBA would be satisfied.
Commissioner Throop put another option on the table. Since he
felt it was important for the County not to take a position or
wage a battle it couldn't win, he recommended that the County
take on the substantive issue and determine whether or not
there were high value crop areas within three miles of the
northeast corner of the county.
Bruce White said the Board had previously directed County
Counsel to proceed with the appeal, which had been done;
however, even if the Board wanted to withdraw its notice of
appeal, there was still another appellant. So they needed to
find a way for the Board to get an answer from a higher
appeals court on the remanded issue while not holding Eagle
Crest up during the process. Staff felt that Option 4 was
"the best way to go." (Option #4. Repeal only that part of
the existing map that is more than three miles from the County
borders and replace the repealed portions with a new map.)
Chairman Maudlin thought it had been discussed that the County
would maintain the existing map with a line three miles inside
of the county borders. Commissioner Throop said doing that
would invalidate the County appeal. Bruce White said that
last week the staff didn't feel the County had a map to
proceed with because the map had been remanded. They felt
LUBA had invalidate the entire map, so in order to allow Eagle
Crest to proceed, they felt the County needed to adopt a new
map under which they could apply. The proposal would have
been to map all of the area short of three miles of the county
boundary. However, now the staff felt the County did have a
map because of the appeals, but were held hostage by whatever
the appeals courts would ultimately decide. Eagle Crest would
have the option of going forward under the current map,
however since it was still under appeal and there had already
been one adverse ruling, they would be accepting a
considerable risk of the ultimate outcome. Option 2 didn't
seem to be very attractive to Eagle Crest. Option 3 wouldn't
PAGE 9 MINUTES: 8-5-92
01 19-03OP9
have resolved the Board's desire to get a judicial ruling on
this question. Therefore, staff recommended proceeding with
Option 4. Chairman Maudlin agreed that Option 4 was how the
County should proceed.
Commissioner Throop felt there was a fifth option: "to drop
the appeal of the LUBA remand, ask Eagle Crest and Mr. Gardner
and Mr. Humphreys to meet to see if there was a way to
negotiate the dropping of the Gardner/Humphreys appeal and
then bring on the substantive issue rather than playing losing
games in court or in other words, move on to assessing whether
or not there are high value crop areas within three miles of
our northeast corner of the County. As part of that, adopt
Option 1 which allows us to adopt a new map as part of the
remand, excluding areas within three miles of the County line,
without having to hold additional public hearings."
Chairman Maudlin did not agree with Commissioner Throop that
this appeal could not be won. He pointed out that in other
County actions, i.e. siting a solid waste pit next to the
boarder with another County, nothing required that this County
consider issues raised by the other County. Bruce White said
there had been instances in the past where people within the
area of notice had been in other counties. George Read said
he felt it was required by statute that all properties owners
within the required distance be notified not just those within
the County.
Commissioner Throop said if the County didn't appeal the LUBA
remand, then the County would be able to adopt a new map
without having to go through public hearings. However if Mr.
Gardner and Mr. Humphreys continued with their appeal, that
probably wouldn't work. Bruce White said he had spoken with
their attorney the previous day, and was told that they had
filed a petition for judicial review, therefore they had set
the process in motion independent of the County. Commissioner
Throop felt they had just reserved a position, like the
County, since no briefs had been filed. Bruce White agreed.
He speculated that their position would be determined by their
factual analysis of whether or not there were high value crop
areas within the three-mile area in Jefferson County.
Commissioner Throop asked if he meant that if Mr. Gardner and
Mr. Humphreys went forward with their appeal, it was likely
that their analysis showed there was high value crop areas in
Jefferson County, while if they didn't go forward with their
appeal, it was likely their analysis showed there were no high
value crop areas. Bruce White said it would be more likely
for them not to continue with the appeal if they felt it was
clear that the remand would be of no consequence to them.
Rick Isham asked if there was a legal issue concerning what
constituted high value crop land in Jefferson County? Bruce
PAGE 10 MINUTES: 8-5-92
0119-0390
White said there might be, but he had not had a chance to
research it. He had heard through the press that McFeeder's
turf farm was being considered as a high value crop area,
however it was not clear that a turf farm would be considered
a high value crop as listed in Goal 8 or the statute.
Chairman Maudlin said he received a call from someone in
Redmond who said there was high value crop land in Crook
County which was close to the proposed Gardner development.
He suggested people with these contentions would "start coming
out of the woodwork" so he felt the County should take this
opportunity to win this battle by going forward with the
appeal. Commissioner Throop pointed out that the statute was
"very clear on its face" so the County would not be able to
argue legislative intent, therefore he felt there was a "zero
probability that we'll win this battle and again I think it's
a total waste of County resources." Chairman Maudlin said it
was no more of a waste of resources than to have to inventory
high crop lands in every bordering County. Commissioner
Throop said that was the law and the planning requirement for
destination resorts, and therefore the County would end up
doing it anyway.
Rick Isham reminded the Board that in order to proceed with
Option 4 in the short time line suggested would require a
unanimous vote of the Commission. Commissioner Throop said
that if the majority of the Board decided to go with Option 4,
he would also vote for Option 4 as the next best alternative
to Option 1 and his proposed Option 5. Bruce White pointed
out that Option 4 also had some risks. Eagle Crest did have
some opponents, and since the County was not adopting a map
through the remand process which would have limited additional
public input, the map would be open to renewed public
testimony and appeal. This risk had been explained to Eagle
Crest and they understood the risk. Bruce White said the
appellants had considered appealing on the issue of whether
there was high value crop areas within the County, but it was
not part of their appeal. Rick Isham said he believed that
those people who appeared in the first hearings would be
precluded from bringing this up under the new ordinance.
Bruce White and Planning staff were not as sure of this
position as Mr. Isham.
Bruce White suggested that the Board ask Eagle Crest to
request that the Board go forward with Option 4 knowing that
there were risks involved. Commissioner Throop asked who
would be paying for this extra work? Karen Green said Eagle
Crest would be paying for it since the conceptual master plan
conditional use permit had an actual cost for service fee
structure. They had paid a deposit and the County was logging
the time spent on their application which would be billed to
Eagle Crest. However, the time put in to developing the new
ordinance which would create the new map would not be charged
PAGE 11 MINUTES: 8-5-92
0-1_ 119-oti9i
to Eagle Crest. Any legislative land use matter was paid for
by fee payers (primarily building permit fee payers).
Chairman Maudlin asked why Eagle Crest needed to affirm their
preference in writing and to acknowledge the risk, since they
had already done so verbally. Rick Isham said part of the
reason was that Eagle Crest had a pending application under a
valid ordinance, and the County would be taking action to
repeal that ordinance. Under the law, Eagle Crest would still
have a right to proceed. So he understood that Eagle Crest
would withdraw that application and file a new application.
He felt it was a good idea to have the applicant indicate this
was the way they wanted to proceed, because of all the legal
issues which could be raised.
SCHLANGEN: I'll make a motion that we proceed with
Option 4 pending a letter acknowledging the
risk from Eagle Crest.
THROOP: I'll second the motion.
Commissioner Throop said this option was clearly a "distant
third priority alternative for him."
VOTE: THROOP: YES
SCHLANGEN: YES
MAUDLIN: YES
10. PACIFICORP APPEAL
Before the Board was a public hearing on the PacifiCorp appeal
of the Hearings Officer's conditions on CU -92-61 concerning an
electric transmission line in the Bend Urban Area.
Chairman Maudlin asked if anyone wanted to challenge any
member of the Board's ability to hear this matter. There were
no challenges.
Chairman Maudlin opened the public hearing, and asked for a
staff report. Paul Blikstad said PacifiCorp had applied for
and received approval of a conditional use permit for that
portion of a 6915 KV electric transmission line which was
proposed to be between the city limits of Bend and the urban
growth boundary. The line was ultimately proposed to connect
to the substation on Cleveland Avenue with the new China Hat
Substation on Rocking Horse Road. The applicant would need to
obtain approval from the City of Bend for that portion within
the City limits which was approximately from the Les Schwab
Tire Store to the Cleveland Substation and approved of a site
plan from the County for that short portion between Ponderosa
Way and the substation on Rocking Horse Road. The Hearings
Officer's decision was issued on June 26, 1992, with nine
PAGE 12 MINUTES: 8-5-92
conditions of approval.
conditions 7, 8 and 9 which
proposed line as an interim me
upon a community -wide review
appropriate location for the
south Bend area.
01 [9-0092
The applicant was appealing
iealt with the approval of the
isure for PacifiCorp and relying
process to determine the most
transmission line to serve the
Bruce White said that in their notice of appeal, the
applicants had proposed some substitute conditions for 7, 8,
and 9, however staff had not had an opportunity to discuss
them.
Chairman Maudlin asked for testimony from the appellants.
Clark Satre, Central Oregon Area Manager for Pacific Power &
Light, verbally gave the attached testimony.
Commissioner Throop asked if the current location of the
substation limited the alternatives for a second transmission
line, i.e. a line going south on Highway 97 and then east over
Forest Service ground to the BPA corridor. Mr. Satre said
they could not have had their substation any further east
because they would be out of their service area. There was a
practical limit of about 10 miles in length for the line from
Pilot Butte to China Hat substation, but there appeared to be
one way to build a line which was 10, 10-1/4, 10-1/2 miles
following essentially the route mentioned by Commissioner
Throop. Commissioner Throop clarified that he understood Mr.
Satre to mean that the location of the subdivision did not
make that route "infeasible or difficult or improbably." Mr.
Satre agreed. He said there was a section of private land
which would require acquisition of right of way east of the
highway, however that was a regular situation for the
construction of transmission lines. Chairman Maudlin asked if
the route being discussed was being considered instead of the
Highway 97 route. Commissioner Throop said no, he was looking
at it as a possibility for the second line. Mr. Satre said it
was about the maximum length a route could be and still be
workable.
Commissioner Throop asked if no other routes worked, would it
be feasible to "turn around and head back up 97." Mr. Satre
said it was not particularly desirable since there would be a
double circuit line on the highway or perhaps on line on the
west side and one side on the east side. This would also
require double circuiting more of the existing system than
what they would like, but it was an alternative. Commissioner
Throop asked what the negative was to double circuiting? Mr.
Satre said "you lose the degree of redundancy that you'd like
to have," i.e. a lightning strike could take out both circuits
on a pole, or a car accident would disable both circuits. He
said they would have a strong preference for siting one line
PAGE 13 MINUTES: 8-5-92
01]�9-olo3
on the east side and one line on the west side rather than a
double circuit. Commissioner Throop asked if there was any
major downside to a route that would go down through Forest
Service land, or would it be a preferred alternative. Mr.
Satre said he wanted to "stay away from preferred alternatives
in going into a community process," and he did not intend to
give preferred alternatives to the community. He would just
say "we need to get from point A to point B, and you find the
alternatives." He said that particular route had pluses and
minuses. It affected fewer homes, however some people would
not want to see transmission lines on forest lands.
Chairman Maudlin asked for testimony from those people in
opposition to the appeal.
Chris Reese said when the Board of Commissioners went through
this process before, they expressed concern that they did not
have a complete application before them, and that it was
difficult to find the best route without knowing where the
westside portion of the loop would go. She said the Hearings
Officer recommended and this Board concurred that a community-
wide citizens group should be formed to help determine where
the route should go. She did not feel that recommendation
involved "waiting for the outcome of this Highway 97 proposal"
as she said Mr. Satre expressed. That recommendation was made
seven months ago, and PacifiCorp was now coming to the Board
with no citizen group or input and an incomplete route. She
felt PacifiCorp was ignoring the County's recommendations.
She thought they were using the fear of power outages to get
this route approved. She did think this portion of the route
should be approved before a completed loop was determined,
since it would make it more difficult for a community -wide
process to make an independent determination. She asked that
the Board uphold all of the conditions set forth by the
Hearings Officer. Since she prepared her comments before she
heard Mr. Satre's testimony, she wanted to amend them to
include support for the completed route discussed by Mr.
Satre.
Commissioner Throop asked her if the "fear of the unknown for
the second route" was her concern. Ms. Reese said yes, and
that by putting in the substation and approving a segment of
the route, it impacted and made it more difficult to find
alternatives for the final segment. Commissioner Throop said
in PacifiCorp's testimony, Mr. Satre indicated that the
substation route would not limit options for the second line
and asked why she felt the location of the substation would
limit where the second line might go. Ms. Reese said they
didn't know since all of the options had not been explored.
Commissioner Throop asked if she could think of an alternative
which would be further in length that running down Highway 97
beyond private land on the south part of town, then running
PAGE 14 MINUTES: 8-5-92
01.19-0394
over to the BPA line, and then following existing corridors
back to Cleveland? Ms. Reese said she didn't and it seemed to
be the most workable. She said that the Forest Service and
Central Electric Coop and "done some things together before"
so she wouldn't rule out the use of Forest Service property.
Chairman Maudlin asked where she got the information that the
Hearings Officer had recommended a citizens committee seven
months ago? Ms. Reese said it was in January during the last
appeal's process. Chairman Maudlin said the Hearings Officer
wasn't involved with that process. He said he had made that
recommendation not the Hearings Officer, and he had made it
prior to the testimony where everyone was in agreement that
the best way to proceed would be to use Highway 97 for the
line. The only people at that hearing who felt Highway 97
"wasn't the way to go" were from PP&L. Now PacifiCorp was
before the Board proposing a line on Highway 97, and people
were testifying against it. Ms. Reese said it wasn't that she
was unhappy with the Highway 97 route, she said it just didn't
agree with the Board's recommendation that a completed route
be submitted. Chairman Maudlin said, "that was not a
recommendation. " She said she thought it was a recommendation
of the Hearings Officer. Commissioner Throop said he thought
it was part of the Board's written decision. Chairman Maudlin
said what he discussed at the previous hearing did not
included a requirement that a total line had to be submitted
for approval.
Jim Palmer said he thought the hearing was a significant
change in PP&L's position regarding underground lines, when
Mr. Satre said they would consider putting in short sections
of underground lines. He noted that the major costs
associated with underground lines were the transitions
underground and back out --not the length of the line.
Therefore, short sections of underground transmission lines
were the most expensive to consider. So he suggested that
they consider longer lengths of underground line. Concerning
the reliability of underground lines, he said these voltages
had been used for several years by utilities, and he didn't
feel that was an issue. Underground lines would be subject to
fewer hazards and damage than overhead lines. This was the
first time he had heard that a longer transmission line leg
might be acceptable. Previously the testimony had been that
the length of the two lines had to be very nearly the same.
He had questioned that because "impedance matching techniques
are available and have been used for many, many years that can
make the electric characteristics of the lines appear similar
to the power source even if they are not physically the same
length." He asked who would determine the makeup of the
consumer group. Chairman Maudlin said it would be the Board
of Commissioners. Mr. Palmer asked why the Commissioners
wouldn't proceed with the formation of this committee now? If
PAGE 15 MINUTES: 8-5-92
0-119-0305
one had been formed seven months ago when it had been
originally discussed, the process might be further along, and
it would help avoid further problems. Chairman Maudlin said
that was a possibility. He said they had trouble finding
anybody who hadn't already been involved, so it was difficult
to form a group. He was sure that this hearing was not the
end of the process.
Commissioner Throop asked Mr. Palmer what his background was.
Mr. Palmer said he was an electrical engineering graduate of
the University of California, and had spent 33 years as an
employee of the General Electric Company in engineering and
marketing positions frequently associated with the power
distribution/transmission area.
Jody Ward testified that they did "want to make this work and
we want to be cooperative." Their concern was that PacifiCorp
hadn't submitted acceptable solutions for both sides of the
loop. Their trust level wasn't very high, and they didn't
feel it was prudent not to have some limitations. They didn't
"want to pick a fight", since they wanted the power line.
However, if the County approved one leg of the loop, the
solutions which would be acceptable to the public would be
resisted by PacifiCorp. Commissioner Throop said he had
"difficulty seeing the level of risk here" since PacifiCorp
needed a connection to the power station. The second
connection was not a necessity, but was a safety valve.
Whatever PacifiCorp proposed for the second route would have
to go through a community process and the land use application
process. He asked her to define her "fear of the unknown."
Ms. Ward said if all that were true, why hadn't PacifiCorp
proposed the Highway 97 route to begin with? Commissioner
Throop said the Highway 97 route was far from PacifiCorp's
preferred alternative, and they had proposed that route as a
"distant fall -back position." It was technically feasible for
them to run a second line up Highway 97, however that was
probably the least acceptable alternative to PacifiCorp.
PacifiCorp indicated in testimony today, if the Highway 97
route for the second line was their only alternative to having
no second line at all, they would accept it. He felt
PacifiCorp had proposed a route which would connect to the
substation and activate the line, and he didn't see any real
risk. Ms. Ward asked if Commissioner Throop felt they
wouldn't be coming back saying there absolutely had to be a
second line? Commissioner Throop said there wasn't an
absolute necessity for a second line, however it was needed as
a backup should the first line go down or to use during
maintenance of the first line. However, they would have to
come back with a very acceptable route for the second line in
order "to get it through the community. " So the burden on
PacifiCorp was very high and there were no guarantees. He
said he was trying to weigh the need versus the risk. Ms.
PAGE 16 MINUTES: 8-5-92
01_ (9-0,196
Ward said pacifiCorp knew the Highway 97 route was a possible
location for the line and that it did not have nearly the
impacts on the public as the alternatives they proposed,
however they still chose not to propose it. When they had
been asked why the line couldn't be located in the forest,
Pacificorp had responded that the line couldn't be more than
10 miles in length. She was afraid that if this line was
approved without any conditions, PacifiCorp would come back
for the second route with so many restriction on where the
route could go that it "would be in my back yard."
Commissioner Throop pointed out that PacifiCorp was on the
record of this hearing stating that the eastside route would
work, and that a second line on Highway 97 was technically
feasible although not their preferred alternative.
Chairman Maudlin said the Board would accept written testimony
on this matter until 5 p.m. on Tuesday, August 11, 1992, and
the Board's decision would be made at 10 a.m. on Wednesday,
August 12, 1992.
A member of the audience mentioned that Chairman Maudlin had
alluded to the fact that it was difficult to get together a
community group because they couldn't find anyone who hadn't
already been involved. She asked why the Board wouldn't want
people who had been involved and understood the issues.
Chairman Maudlin said they hadn't put together a committee
because everyone had already been involved at the hearings,
and it never came up again. In the future, if the Board
desired to appoint such a committee on another line, he felt
it would certainly involve the people who had shown an
interest in the past.
DATED this�� day of L�;�
Commissioners of Deschutes Coun Ore on.
, 1992, by the Board of
op, r(ammissigner
AT T: Nancy P e'Sc
Recording Secretary Dic Maudlin,
PAGE 17 MINUTES: 8-5-92
, Commiss
01 is -0307
August 5, 1992
My name is Clark Satre. I am Central Oregon Area Manager for Pacific
Power & Light.
We're here today to appeal the County Hearings Officer's decision on
CU -92-61, a conditional use permit for a 69/115 KV electric transmission
line in the Bend urban area. Specifically, that line would extend from our
existing substation on Cleveland Avenue east of Highway 97, south
along Highway 97 to Rocking Horse Road, and west on Rocking Horse
Road to our substation known as China Hat substation. There are
existing poles and electric distribution lines for the entire length of this
route.
The portion of this route covered by CU -92-61 is a little less than one
mile in length from the Bend City limits on the north to the urban growth
boundary on this south.
The hearings officer approved the conditional use permit but with
1
01' [9-0ti98
conditions that are unacceptable to us. Those conditions are numbers
7, 8, and 9, and I will discuss why those conditions should preferably be
removed, but if not removed then altered substantially.
Before I discuss those conditions however 1 would first like to review the
facilities we need to adequately serve the south Bend area. First, we
need a new substation because our existing substations are overloaded,
and are not located so as to be able to adequately serve the growing
loads in the southern part of the community. This substation has been
built on Rocking Horse Road west of Highway 97 and is called China Hat
substation. This substation is an allowed use in the RR10 zone, and was
found by the County to meet all appropriate criteria for the issuance of
the necessary permits, and has been fully permitted.
Second, we need a new transmission line originating at Pilot Butte
substation east of town on Highway 20 and going to the new China Hat
substation. Pilot Butte substation is where bulk power comes into the
Bend area.
2
0-1_ � 9-0ti99
Third, we need a new transmission line from China Hat substation to a
point on the existing system west of the Deschutes River.
And, fourth, we need a switching station (which could also double as a
future substation) at the point on our system west of the river where the
new line from China Hat substation connects into our existing system.
The reasons why we need lines into and out of China Hat substation are
first for reliability of service to that substation, and second for
reinforcement of the entire transmission system. You will notice on the
system map that every substation has two lines to it. This is so that if
any one line or line section is out of service, either due to scheduled
maintenance or due to an outage, we can still provide power to any
substation through an alternate line. Likewise, for the same degree of
reliability to China Hat substation, and all of the customers that will be
served from China Hat substation, we need not one but two lines to
China Hat substation.
Now our existing transmission system also needs reinforcement due to
K
01.119-0400
all the growth in Bend, and that is why one line to China Hat must
originate at the source, Pilot Butte substation, and the other must join
our system west of the Deschutes River. And at the point where the new
line joins the west side of our system we will need a switching station
where circuit breakers will be located. These circuit breakers and related
equipment combined with remote controls will allow for automatic
detection of problems on any of the lines, and automated switching so
that any line in trouble can be disconnected while power continues to
flow with minimal interruption to all substations over the remaining lines
in service.
I would like to point out also that we have never concealed the fact that
all of these facilities will be needed. in fact, at every hearing in which
I've been involved we've made a point of stating that all these facilities
will be needed.
Now, going back to China Hat substation, whether or not the substation
is in the right location has. been a concern of several members of the
community including you the commissioners. Your concern is, as I
4
01-19-0401
understand it, that you cannot determine where are the best locations for
transmission lines if your alternatives are limited by the location of the
substation. I will demonstrate to you that if China Hat Substation were
located anywhere so as to be able to provide service where needed, the
transmission line routes we would all consider would be substantially the
same.
Consider the area that will be served by China Hat substation. To the
west is the Deschutes River. We know we're not going to have a
multitude of lines crossing the river, and the major load area is east of
the river, so that substation should be east of the river. To the south Is
U.S. Forest Service land, and we know we're not going to have any load
on Forest Service land so the substation should be north of the Forest
Service boundary. To the east is our boundary with Central Electric
Cooperative. Roughly, this boundary can be described by saying that
CEC serves east of 1 Sth Street, south of Knott Road, and east of China
Hat Road. Obviously our substation to serve our customers should be
located in our service area, not CEC's. And to the north is our existing
system which is not adequate for serving the southern part of the area,
5
01. 19-0402
so the new substation should be south of our nearest substation on
Cleveland Avenue.
Now we try as much as possible to put substations near the center of the
area they will serve. This means two things. First, we want Cleveland
Avenue substation to be near the center of the area it serves so it should
continue to service some load to the south. It wouldn't make sense to
have lines come all the way from a new substation to the south right up
to Cleveland Avenue substation when the load is a lot closer and can be
served more efficiently from Cleveland Avenue substation. So we still
want to allocate some of the area south of Cleveland Avenue substation
to be served from Cleveland Avenue. And second, we want the new
substation to be located not just within the area to be served, but
somewhere near the center rather than right against one of the
boundaries.
Besides being in the center of the load there are other considerations to
locating a substation. Among these are availability of property, zoning,
neighbors, potential routes for transmission lines and distribution lines,
6
01-19-0403
and access for some very large equipment. So when you take all these
factors Into consideration you may miss the geographic center of the
load area a little, but there are usually a very limited number of sites that
are both suitable and available.
Given the area to be served and criteria for choosing a substation site
where could China Hat substation be located other than where it is now?
Well, you don't want it right adjacent to the highway because some
people think substations aren't pretty. In fact we had property and a
fenced area adjacent to the highway where we could have built the
substation, but in response to community concerns we abandoned that
site and built where the substation would not be visible from the
highway.
But for major equipment access, It is desirable to have the substation
near the highway.
And once you get off the highway there are a lot of areas that are already
built up, or the lots are too small, the neighbors are close, or there are
7
01-19-0404
golf courses. So there aren't a lot of choices, but for the sake of
considering alternatives we would want to limit the area to probably no
more than a mile in any direction, maybe a little more to the south and
a little less to the east, from where China Hat substation already exists.
With that area in which to place a substation, where might we consider
building transmission lines from Pilot Butte substation and to the west
side of our system? I contend that all the alternatives are essentially the
same regardless of the substation location. All alternatives using
combinations of north -south and east -west roads in the southeast part
of the community would be considered. These roads combined with the
railroad tracks and the highway would be considered. Every route that
has been previously considered by us and either withdrawn or denied
would be feasible. The three routes suggested by the Citizens for
Responsible Power Placement would all be considered. These routes
were Highway 97, a route following the BPA right-of-way and crossing
Forest Service land, and a route following CEC right-of-way and Knott
Road.
D
01j9-0405
On the west side alternatives are limited no matter where the substation
is located, but one alternative that we would consider in any case is
Highway 97 combined with utilizing an existing river crossing within the
City. Another alternative that didn't work out but would have been
considered regardless of substation location was the line along Rocking
Horse and Buck Canyon Roads crossing the river and connecting to Mid -
State Electric Cooperative's line. With a different substation location we
might have also needed some line along the railroad tracks or highway
but this would still have been a good alternative because the area was
relatively undeveloped, houses were generally set back from the road,
and there was an existing distribution river crossing. In fact it is still my
belief that without the Awbry Hall fire that line would have been fully
permitted and built by now.
So, it is my conclusion on the issue of substation location, and I hope by
now it is also your conclusion, that you and the community can make the
best decisions about transmission line locations because all of the
alternatives that might be considered are essentially the same, except for
minor variations at the end, regardless of where the substation is located
9
01".1 9--0406
if it is located where it can meet the electric service needs of the area.
There are no factual or legal basis for reconsidering the location of China
Hat substation.
Now another thing everyone has said they would like to see is a
community involvement process to evaluate various transmission line
alternatives for all parts of the China Hat project. We understand that
desire and agree with it, so why you ask are we here with a single
proposal for only part of the overall project?
The answer is one of timing. The need is unquestioned. Growth
continues and the demands on our system continue to grow more and
more beyond its capability. Only mild temperatures last winter prevented
serious overloads, and normal temperatures next winter could cause
widespread and prolonged power outages.
As soon as we lost our appeal on the "Mountain High" route we
immediately began work on design and permitting for this route along
the highway. We held meetings to get input from City and County
10
planning departments, the highway department, and the Forest Service.
Working as quickly as we could, involving people knowledgeable in all
aspects of line siting, design and permitting, we are still here in early
August not yet having an acceptable permit to build anything. From this
date forward it will take an extraordinary effort to complete this line
before winter. We will make that effort, but I'm sure you can understand
that. if we had assembled a community group, educated them as to
technical considerations for transmission line siting, evaluated numerous
alternatives and then applied for permits we would have no chance of
completing any line this year. In fact I expect this kind of process to
take between two and three years. We are committed to initiating this
community involvement process for the second line route, but we simply
cannot ignore a problem that exists now and by doing so knowingly
subject our customers to potentially serious power outages.
And I guess you could say we've already had a lot of community input
through the many public hearings. In fact part of the reason we
proposed this Highway 97 route is because it was suggested and
endorsed by some opponents of previous routes.
11
01r 19-0408
However, because we're here with this partial solution there are some
who will accuse us of a wiily nilly, haphazard, piece meal approach with
no consideration for the community. Well, first of all, its only because we
are concerned about the community and our customers that we are
trying to build anything. And second, let me tell you what would have
happened if we had been in a rush and were not concerned about doing
a good job.
Perhaps you've noticed a fenced enclosure at the northwest corner of
Highway 97 and Rocking Horse Road. That piece of property, very
visible from the highway, is owned by us and has even today all the
permits necessary for construction of a substation. Without notification
or permission of anyone we could have gone ahead and built the
substation within that fenced area, and it would have been there for
thousands to see each day as they travel the highway. But instead we
decided that a location highly visible from the highway was not in the
community's best interest, so we purchased another lot off the highway
where the substation is much less visible.
12
01-19-0409
We also had a permit for a transmission line between Pilot Butte and
China Hat substations. We obtained the permit in 1982, and by letter
from the Deschutes County Planning Department dated November 21,
1989 we were told that our permit was still valid. If we had been
unconcerned for the community we would have simply built the line at
that point. But we looked at the route approved by that 1982 permit and
decided that due to more recent developments the community could be
better served if we could find a better route. So here we are, still looking
for that better route. It's true that in March 1990 the county reversed
itself and determined the 1982 permit was no longer valid, but if we had
gone ahead and built the line based on the county's letter to us in
November of 1989 we might today be in a different forum arguing other
issues related to that line and at whose expense it should stay or be
removed.
Next, I want to correct a statement on page 10 of the Findings and
Decision of the hearings officer that is completely in error. He states,
"The applicant has proposed an interim solution to the problem of energy
supply for the south Bend area." In fact, my statements at the hearing
13
01-19-0410
on June 2 include, 'This [line] is only part of what our ultimate system
needs to be." and ..."so while this [line] solves the immediate need of
energizing China Hat substation, it will also be a part of the overall
development of the system." There Is nothing In our application or our
testimony to indicate we are proposing an interim solution. A partial
solution, yes, but not an interim solution. The hearings officer is taking
this an interim measure because he wants to, not because we have
proposed it.
Now let me get to the specifics of our appeal of conditions 7, 8, and 9 of
the hearings officer's decision. By imposing these conditions the
hearings officer has given us a permit that is subject to revocation if
through an undefined process some entity identifies what they think is
a so called better location for the use. There is absolutely no legal or
factual basis for imposing this kind of condition, and I doubt you would
ever get anyone else to build anything in the County under this
condition. Neither is there any basis for limiting the duration of a
conditional use permit to three years. The hearings officer's decision
contained no findings or evidence to support such findings that our
14
01 19-0411
application failed to meet the approval criteria without conditions 7, 89
and 9, or that conditions 7, 8, and 9 are necessary to protect the best
interests of the surrounding area or the urban area as a whole.
Condition 7 as written by the hearings officer subjects the proposed line
on Highway 97 to a community wide review process to "make an
independent determination as to whether or not this route is feasible and
appropriate." There are absolutely no criteria set forth in his decision to
determine who constitutes "community wide", or what constitutes
feasibility and appropriateness.
Condition 8 subjects the existing substation as well as the transmission
line to a community -wide review process. As we've already discussed,
the substation is already fully permitted, there is no legal basis for
subjecting it to further review, and transmission line alternatives would
be essentially unchanged by any reasonable alternative substation
location. We simply cannot accept, nor should we have to accept,
further review of the substation location.
15
0-1--19-0412
Condition 8 also states that if "other routes are more appropriate and are
Feasible for engineering purposes" we must remove the line on Highway
97. Again, by what standards are appropriateness to be judged? Who
shall determine engineering feasibility? For example, Central Electric
Cooperative and ourselves design our systems differently. I would say
that we both follow good engineering practices, but what they consider
to be engineering feasibility might not be what we consider to be
engineering feasibility.
Condition 8 also states "... the applicant shall be required to remove the
route approved by this decision within 60 days of the date the other
transmission line is constructed." Note the singular, line, is used, not
lines. While there is so much concern over complete applications and
total solutions and piece meal approaches, we would be forced to
remove this line if only one other route is given to us. This gives no one
an incentive to completely solve the problem, just to find somewhere else
to put one line. According to these conditions, at the end of three years
we could be forced to build a new line and take out this one, still
needing another route to complete the loop but being no closer to a
16
0 . [9-01-13
complete solution than we are today.
To understand just how absurd this is consider the following scenario.
This fall we build the proposed line along the highway to energize China
Hat substation. A community group is formed, and this group decides
that the best route between Pilot Butte and China Hat substations is a
route following the BPA right of way, then crossing Forest Service land
to the highway, and north to Rocking Horse Road. We build this line,
and in accordance with the conditions imposed we remove the line on
Highway 97. The community process continues and eventually it is
decided that the best way to complete the loop is to build a line north
along the highway to our existing river crossing. So we build again the
line along the highway that was built and torn out under conditions of
this permit. I can't imagine anything more wasteful, yet that possibility
exists as the hearings officer's decision is written.
Condition 9 is even worse. It states that if "the community -wide review
process proposed by the applicant is not completed by July 1, 1995 ...
this permit shall be subject to review ... to determine ... whether or not
17
01 19-04-1-L4
this permit should be revoked." Theoretically, in a worst case scenario,
if the community process were unable to agree on a line route within
three years we could still be forced to remove this line leaving us unable
to serve what will undoubtedly be a much greater load after three more
years of growth.
Now let me tell you what we feel are acceptable conditions. The exact
wording is contained in our appeal: I will paraphrase and explain what
we propose.
We are willing to implement a community review process. We stated this
at the June 2 hearing. We propose to include representation from public
agencies, homeowner's associations, the environmental community,
commercial interests, and others who are willing to commit their time and
energy to solving this problem. We will seek a group such that when all
is said and done no one will feel they had no representation.
We will remove the transmission portion of the line on Highway 97 if
through this process we receive all permits necessary from all agencies
18
011_ 19-04-15
involved for construction of overhead transmission lines from Pilot Butte
substation to China Hat substation and from China Hat substation to the
west side of our existing system, plus the west side switching station.
These permits must be for facilities that are acceptable to Pacific Power
for engineering purposes.
We want the process to solve the whole problem, not just give us one
line as the hearings officer's conditions state. We are willing to risk
taking out this line if the tradeoff is a complete solution. We are not
willing to risk removing this line if the tradeoff is only one other line,
leaving us still in need of a second line and switching station. Further,
the line on Highway 97 could be a part of either a Pilot Butte to China
Hat route, or a China Hat to west side route. As I said before, under the
hearings officer's conditions, the community could give us one route
forcing us to remove the line on Highway 97, only to later determine that
a line on Highway 97 should be re -installed as part of the other route.
We are asking for overhead alternative routes because overhead
transmission is still the industry standard and it already exists in Bend
19
V I9 -04,s
so unobtrusively that people who have opposed us haven't even known
there were transmission lines already in their neighborhoods until we
told them. We believe there are numerous overhead line routes feasible,
and are willing to work with the community to identify those that are
acceptable. With todays questions about long term reliability of
underground transmission cables, and the well documented cost
differentials between overhead and underground construction we believe
it is only appropriate to consider overhead routes.
Of course if there are significant advances in technology in the next three
years such that overhead and underground cost differentials disappear
that could change our position.
And I will soften our position further by saying that if there is a route that
is suitable to us but that has a small section that is of particular
uniqueness such that an underground line section is the only way to
make the line buildable we will consider a short underground portion.
An example might be a line on Knott Road going by the end of the
Stevenson Ranch airstrip. If the community endorsed this route and the
20
only way to resolve the airstrip conflict were to underground a short
section of line we will consider doing so if that section is part of a loop
F-ystem.
While we are willing to remove the line on Highway 97 under these
conditions we would also ask that even if acceptable alternative facilities
are built that we remain free to apply for permanent status for this line
subject to all established procedures and permits.
Let me try to summarize. There is no legal basis for a permit that
potentially requires future removal of the permitted facilities. The
proposed line on Highway 97 is the fifth route to China Hat substation
to receive local government review. It is a route acceptable to us, it is
a route that has been endorsed by a large group of citizens, the hearings
officer made no findings that this proposal failed to meet any criteria for
being permitted. There is no basis for the imposition of conditions 7, 89
and 9, and we respectfully request on appeal that you remove those
conditions from the conditional use permit approval.
21
0' �-0-f 3
the alternative, if you are not comfortable with complete removal of
,hose conditions then we ask that you substitute our proposed
f;onditions that will make removal of this line conditioned on a complete
solution rather than a partial solution.
22