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2000-776-Minutes for Meeting June 29,2000 Recorded 7/12/2000VOL: CJ2000 PAGE: 776 RECORDED DOCUMENT STATE OF OREGON COUNTY OF DESCHUTES *CJ2000-776 * Vol -Page Printed: 07/12/2000 14:43:04 DO NOT REMOVE THIS CERTIFICATE (This certificate constitutes a part of the original instrument in accordance with ORS 205.180(2). Removal of this certificate may invalidate this certificate and affect the admissibility of the original instrument into evidence in any legal proceeding.) I hereby certify that the attached instrument was received and duly recorded in Deschutes County records: DATE AND TIME: DOCUMENT TYPE: Jul. 12, 2000; 1:01 p.m. Regular Meeting (CJ) NUMBER OF PAGES: 17 MARY SUE PENHOLLOW DESCHUTES COUNTY CLERK KE Pu GNEQ J'--1?2000 E (fff 0�0&) - 77/c� Board of Commissioners 1130 N.W. Harriman St., Bend, Oregon 97701-1947 (541) 388-6570 • Fax (541) 388-4752 www.co.deschutes.orus Linda L. Swearingen Dennis R. Luke MINUTES OF MEETING Tom Dew°'f DESCHUTES COUNTY BOARD OF COMMISSIONERS PUBLIC HEARING ON APPEAL NO. A-008, OF APPLICATION NO. CU -00-3 Applicant: Sheehan (Dayton Road, Bend) Administration Building 1130 NW Harriman Street, Bend Thursday, June 29, 2000 Chair Linda Swearingen opened the meeting at 10:00 a.m. Present were Commissioners Swearingen, Dennis Luke and Tom DeWolf. Also present were Bruce White, County Legal Counsel; Tracy White and Kevin Harrison, Community Development Department; Tia Lewis, Attorney for the Applicants; and Applicants Tom and Mimi Sheehan. CHAIR LINDA SWEARINGEN: In the interest of time, I would like to submit the opening statement for the public hearing on this appeal into the record. Does the applicant have any objection to waiving the reading of this statement? TIA LEWIS (Attorney for the Applicant): - No. C - r S WEARINGEN: Have any members of the Board had any pre -hearing contacts? M -_:- COMMISSIONER DENNIS LUKE: _, No. co Board of Commissioners' Meeting Appeal No. A-008, Application No. CU -00-3 Page 1 of 9 Pages Thursday, June 29, 2000 Quality Services Performed with Pride COMMISSIONER TOM DEWOLF: No. S WEARINGEN: Are there any challenges as to bias, prejudgment or personal interest? (None were given.) Then we will proceed with the staff report. TRACY WHITE: Presented an oversized map showing the subject property in relation to other properties in the area. A general discussion ensued regarding the map. She then read her opening statement for the public hearing on the appeal (Exhibit A). She also read the Staff Presentation (Exhibit B). S WEARINGEN: Based on this map, it is not going to alter the area. LUKE: I have a question regarding the map. Parcels across from the subject parcel have quite a few houses on them. Why aren't those located? WHITE: The rules state that the analysis does not include land zoned for rural residential and non -resource use, in particular the MUA zoned land that you are looking at, which should not be a factor in your decision. LUKE: There could be one hundred houses in there and we aren't supposed to take that into account? S WEARINGEN: That just doesn't make sense. WHITE: These could not be taken into consideration. The agricultural land use pattern has to be considered. There are old subdivisions that pre -date the Oregon land use system, a rural residential exception area zoned RR -10 or MUA-10. DEWOLF: Do most of these have homes on them? Board of Commissioners' Meeting Page 2 of 9 Pages Appeal No. A-008, Application No. CU -00-3 Thursday, June 29, 2000 WHITE: I think most of them do. But we could not consider these in the decision. S WEARINGEN: I know you don't make the rules, but this sounds kind of silly that these can't be considered. WHITE: Our analysis was applied under the administrative rules. We made the assumption that allowing this dwelling would encourage additional non-farm dwellings in the area, and would alter overall land use in the area. S WEARINGEN: We have seen that if a dwelling is place on a parcel, typically it is more likely to be actually farmed and put to use than it would be if the owners do not live on the property. Often in this case it just lies fallow. Would the owners of this property actually lose their water rights if a residence is allowed? WHITE: They would lose their farm deferral, but could keep their water rights. The record does indicate that the Sheehans are not farming it. LUKE: They can keep their water rights. The irrigation company may ask for the owner to sell back the water rights for the land where the dwelling is place. When was this property previously split? WHITE: It was split into two lots prior to 1992, and it could have possibly been built on in 1992. It would have been a conditional use permit and would have been reviewed under the requirements at the time. WHITE: The applicant has argued that the proposed non-farm homesite is on a portion of the parcel that is not irrigated and is generally non-productive land, encompassing about 120 feet by 140 feet, or about 1/2 acre. We have found that it is composed predominately of class 1 to 6 soils, so it is presumed to be suitable for farming. The homesite location is class 3 to 4 irrigated, and class 6 dry. Board of Commissioners' Meeting Page 3 of 9 Pages Appeal No. A-008, Application No. CU -00-3 Thursday, June 29, 2000 The record indicates that the area where the dwelling would be placed had been irrigated in the past until the applicant transferred about 1/3 acre of water from it. It has the same soil types as the adjoining properties, which are being farmed. LUKE: The adjoining properties all have homes on them, is that true? WHITE: Yes, I believe they do. Those houses date from a different regulatory scheme, and are associated with farm uses. DEWOLF: If staff feels the entire parcel is suitable for farming, does this disqualify the whole parcel? KEVIN HARRISON: The decision would be to deny the application unless a portion is found unsuitable for farming. LUKE: Has there been any public testimony against a dwelling being allowed? WHITE: None has been received, either oral or written. HARRISON: In 1992, the rules on the EFU zone were being rewritten and were also under an enforcement order. The stability standard has changed significantly since then. We can now use a portion to determine suitability. In 1992 you had to show that the entire parcel was unsuitable. DEWOLF: Can LCDC sue the County? HARRISON: It has happened in the past, instigated by ARLU DeCo. Deschutes County was place on one year's probation in the early 1990's. LCDC can initiate an enforcement order. Board of Commissioners' Meeting Page 4 of 9 Pages Appeal No. A-008, Application No. CU -00-3 Thursday, June 29, 2000 S WEARINGEN: Although the soil suitability can be questioned, I do not think allowing a non-farm dwelling would alter the stability of the land. Any potential change in the land use pattern is not significant, especially considering all the properties right across the road that have homes on them. TIA LEWIS: For the record, the original parcels were created in 1974, and the Sheehans have owned theirs since 1994. (Referred to a map showing the dates parcels were created.) S WEARINGEN: We will adjourn the hearing until later today at 2:30 p.m. CONTINUATION OF HEARING Thursday, June 29, 2000, 2:30 p.m. Chair Linda Swearingen reopened the hearing. Present were Commissioners Linda Swearingen, Dennis Luke, and Tom DeWolf. Also present were Bruce White, County Legal Counsel; Tracy White, Community Development; and Attorney Tia Lewis, and her clients Tom and Mimi Sheehan. TIA LEWIS: I'm here on behalf of the applicants, Tom and Mimi Sheehan, who own approximately 10 acres on Dayton Road, adjacent to Matt Day's property. The area is most known for Matt Day's residence. (Distributed photos that have already been included as Exhibit B of the applicant's burden of proof in the existing record.) The photos are taken from the proposed residence — the rocky area you see is on the proposed homesite; photos have been taken toward all directions. (General discussion ensued regarding the land shown in the photos.) This parcel is about 1/3 of the size of the average farm parcel in the area. It also has a little over 1/4 of the irrigation for the minimum irrigated acreage in the sub - zone. The Sheehans have owned it for about six years. Both staff and the Hearing Officer found that all criteria were met except two. Board of Commissioners' Meeting Page 5 of 9 Pages Appeal No. A-008, Application No. CU -00-3 Thursday, June 29, 2000 TOM SHEEHAN: In 1994 my wife, Mimi, and I bought this property solely for building a home on it. We had no idea it would be this difficult, although we knew it was zoned EFU; we started this process last July. We have four sheep, chickens, dogs and cats. We want to use the land like everyone else in the area, as a hobby farm. We noted there are at least a couple of dozen homes already in the area, and we can see at least half of those from our property. Down the street there is a 6.33 acre parcel with a conditional use permit already in place for sale, with four acres of irrigation. Nearly all parcels in the area have homes on them, with or without irrigation. We never farmed the property. When we bought it the previous owner had not been irrigating, and it was just a dust bowl. We have irrigated every year, just to keep it green and keep to the dust down. We have eight acres of irrigation. A neighbor uses the land for grazing three to five cows, and we turn our sheep out onto it. The proposed building site is primarily rock, and is not irrigated. There are boulders spread out on much of the parcel, making it impossible to farm. The parcel is separated by a mainline and a fence, and we have an irrigation pond. About 2,000 feet away there are three homes, and about 100 feet away in another direction are two other homes. (She discussed proposed location of the dwelling on the map, in relation to other residences in the area.) We met with neighbors Matt and Leslie Day to go over our plans, and they weren't opposed to them at all. The other immediate neighbor has sent in a letter of support. If we're denied the ability to build a home there, the land is basically worthless to us. There are a lot of gophers and sage rats in that area, and the gopher control man got halfway through the land and left after breaking two augers on the big rocks under the surface. TIA LEWIS: There are two criteria at issue. One is the stability standard — which addresses the dwelling's effect on the overall land use pattern of the area — and I believe this application meets this criterion. You need to consider "similarly situated". This process is designed to determine if this will affect the pattern in the area. As I see it, approval of this application would not affect the pattern and set precedence. It would have no bearing on the possible future development of a 400 -acre parcel. Board of Commissioners' Meeting Page 6 of 9 Pages Appeal No. A-008, Application No. CU -00-3 Thursday, June 29, 2000 That's how the analysis is done. Within the circle, staff and the Hearings Officer take every vacant farm parcel and use that as the starting point. You should look at the ones where it's likely to set some sort of precedent. Common sense needs to be used. When you look at similarly situated parcels, you will find that term is not defined in Deschutes County ordinances, administrative rules or state statutes. Yamhill County, in a case that LUBA quoted with approval, defined it as "parcels within the same category of developability". When you consider this parcel against those of the same size and use — soils, location, and terrain — and I used twenty acres or less - I came up with seven similarly situated parcels in the area that may possibly be affected by the decision on this issue. When you consider the size of the area and how many parcels there are, the likelihood that seven more dwellings could be approved is not a material alteration. WHITE: The map shows the potential area, excluding the big parcel. (General discussion about the parcels on the map.) LEWIS: The other issue relating to this criterion is to look at farm parcels and whether the creation of this would lead to other non-farm dwellings. We aren't creating another parcel, but the Hearings Officer indicated this might cause the addition of another two or three. Also, the "portion of a lot" was not included in the Hearings Officer's document. The evidence we have about the parcel's unsuitability consists of a number of things: the rockiness, the inability to run farm equipment on it, and so on. Mark Higham, an expert in farm operations, testified that the area where the homesite would be placed is generally unsuitable for the production of livestock or for farming. (She distributed the testimony of the expert that was given at a previous hearing on this matter) Also, consider the size of the parcel, the non -irrigation of the location where the dwelling would be. Tumalo Irrigation District allowed the water rights to be moved to a different, more productive area on the parcel, and they are very careful about moving water rights. The applicants want to live on the parcel so they can keep irrigating it, make it more productive and keeping livestock on it. Board of Commissioners' Meeting Page 7 of 9 Pages Appeal No. A-008, Application No. CU -00-3 Thursday, June 29, 2000 WHITE: I want to reiterate the number of parcels that have developability similar to the subject property. The map does not include any potential parcels, either. And the soils scientist's data, previously submitted, conflicts with the testimony that the whole back of the property is too rocky to farm. S WEARINGEN: I think the statement, "generally unsuitable", is very subjective. WHITE: When I visited the property, I did see rocky areas, but I saw other areas that look very farmable. The pictures show what they are intended to show. LUKE: Rocks have a tendency to grow in this area, especially when the land is tilled. WHITE: We do have some guidelines to follow. We can assume that it will reduce options for increasing farmland or acreage in farm use, and will increase the number of dwellings. LUKE: I am not worried about other applications, as I'm sure they will end up coming before us. I don't believe this dwelling would affect the overall stability of the area, especially with rural residential properties right across the street. I can't see how this house would disrupt the stability of the area. S WEARINGEN: Nor can I. I believe the applicants have made their case. DEWOLF: I would like some time to do a site visit, and put the decision on next Wednesday's agenda. S WEARINGEN: The written record will close on Monday, July 3rd, 2000, at 5:00 p.m., with any written rebuttal to be received by Wednesday, July 5th, 2000 at 9:00 a.m. The decision will be on the regular Board agenda for Wednesday, July 5th, at 10:00 a.m. Board of Commissioners' Meeting Page 8 of 9 Pages Appeal No. A-008, Application No. CU -00-3 Thursday, June 29, 2000 Chair Swearingen adjourned the meeting at 3:10 p. m. Dated this 29th Day of June 2000 for the Deschutes County Board of Commissioners. mda L. Sw6grinaen, hair ATTEST: Board of Commissioners' Meeting Appeal No. A-008, Application No. CU -00-3 Gam: s R. Luke, Commissioner Tom DeWolf, Co oner Page 9 of 9 Pages Thursday, June 29, 2000 OPENING STATEMENT FOR PUBLIC HEARING ON AN APPEAL Introduction: This is a de novo public hearing on Appeal A008, an appeal of the Deschutes County Hearings Officer's decision to deny CU -00-3, a conditional use permit for a nonfarm dwelling. This appeal application has not previously been heard. Burden of Proof and Applicable Criteria: The applicants have the burden of proving that they are entitled to the approval sought. The approval criteria shall be projected on the wall using the overhead projector during the hearing. Hearings Procedure: The Procedures Ordinance establishes the following procedures for this hearing: The Board of County Commissioners will hear testimony, receive evidence and consider the testimony, evidence and information submitted into the record, as well as that evidence constituting the record before the Hearings Officer. The record as developed to this point is available for public review at this hearing. Testimony and evidence at this hearing must be directed toward the criteria set forth in the notice of this hearing, which are projected on the wall using the overhead projector. Testimony may also be directed to any other criteria in the County Comprehensive Plan or land use regulations that any person believes apply to this decision. Failure on the part of any person to raise an issue with sufficient specificity to afford the Board and parties to this proceeding an opportunity to respond to the issue precludes appeal to the Land Use Board of Appeals on that issue. Order of Presentation: The hearing will be conducted in the following order. The Staff will give a report on the prior proceedings and the decision of the Hearings Officer. The applicant, also the appellant in this case will then have an opportunity to make a presentation and offer testimony and evidence. The opponents will then be given a chance to make a presentation. After both the applicant/appellant and opponents have made a presentation, the Board may allow rebuttal statements at the Board's discretion. At the conclusion of this hearing, the staff will be afforded an opportunity to make any closing arguments. The Board may limit the time period for presentations. Questions to and from the chair may be entertained at any time at the Boad's discretion. Cross-examination of witnesses will not be allowed. However, if any person wishes a question be asked of any person during that person's presentation, please direct such question to the chair after being recognized. The Chair is free to decide whether or not to ask such questions of the witness. Open Hearing on Appeal A008 (C0003) Page 1 Pre -hearing Contacts: I will now direct a question to the other m6mbers of the Board of County Commissioners. If any member of the Board, including myself, has had any pre -hearing contacts, now is the time to state the substances of the contacts so that all persons present at this hearing can be fully advised of the nature and context of those contacts and with whom contact was made. Are there any contacts that need to be disclosed? At this time, do any members of the Board need to set forth the substance of any ex parte observations or facts of which this body should take notice concerning this appeal? Any person in the audience has the right during the hearings process to rebut the substanm of any communication or observation that has been placed in the record. Challenges for Bias, Prejudgment, or Personal Interest Any party prior to the commencement of the hearing may challenge the qualifications of the Board of County Commissioners or any member thereof of bias, prejudgment or personal interest. This challenge must be documented with specific reasons supported by facts. I will accept challenges now. Should any Board member be challenged, the member may disqualify himself or herself, withdraw from the hearing or make a statement on the record of their capacity to hear the appeal. Hearing no challenges, I shall proceed. Staff report Open Hearing on Appeal A008 (CU003) Page 2 Staff presentation - C003 (A008), Sheehan Staff contact: Tracy White, Associate Planner, Deschutes County Planning This is a de novo hearing for File A008, appeal of the Hearings Officer's decision to deny File C0003 a CUP for a nonfarm dwelling. Procedural History Hearings Officer Green's decision, dated April 26th, outlines the procedural history up to the appeal process. The Sheehans, submitted a Notice of Appeal on May 9th. The appeal period ended May lot" The Board agreed to hear the appeal de novo on May 24th. Notice of today's hearing was mailed to the parities according to the procedures ordinance. The 150 -day period for the county to issue a final land use decision expires July 7th, seven days from today. Applicable Criteria The applicable criteria are listed in the Hearings Officer Decision, the staff report and projected on the wall. Summary The subject parcel is 10 acres with 8.1 acres irrigated, receiving special farm assessment. The Sheehans applied for a nonfarm dwelling on a portion of the parcel. Hearings Officer Green denied the nonfarm CUP for two reasons. 1. The applicants failed to meet the 'stability standard in DCZO 18.16.050(G)(1)(a)(i i ). 2. The applicant's failed to meet the 'generally unsuitable standard in (DCZO 18.16050(G)(1)(a)(i i -iii). CU003 (A008), Sheehan Page 1 Staff presentation - C003 (A008), Sheehan Stability standard The 'stability' standard requires the county to determine the cumulative impact on agriculture land of approving nonfarm dwellings on vacant similarly situated parcels in the EFU zone. The term similarly situated is not defined in the OARS. LUBA interpreted the term in Blosser v. Yamhill County (1989) to mean vacant parcels with the "same category of developabilitiy." In 1998 LCDC amended OAR 660-033 for agricultural lands to include case law and clarify the'stability' standard. In particular, the rule now requires counties to apply a three-step 'stability analysis first outlined in Sweeten v. Clackamas County. Step 1. Select a study area. We examine the EFU-zoned land within a mile of the subject parcel. Step 2. Examine of the pattern of agricultural land uses and the history of residential development in the area. • The rule states the analysis does not include land zoned for rural residential or non -resource uses. In particular, the MUA zoned land should not be a factor in your decision. • The agricultural land use pattern is the pattern of farm tracts and individual lots in farm use. • We determined the residential land use pattern by inventorying the existing houses, noting the year each house was built, what if any land use permit was approved and by classifying the house as a farm or nonfarm dwelling. In particular, we count the houses built since 1993, after HB 3661, when the standards for dwellings became more restrictive. Step 3. Describe the land use pattern that would result from approving all the potential nonfarm dwellings. CU003 (A008), Sheehan Page 2 Staff presentation - C003 (A008), Sheehan • We determine the potential residential land use pattern by calculating how many nonfarm dwellings could potentially be approved on vacant parcels in the area; and how many nonfarm parcels could be created. • Finally, the existing agricultural land use pattern is compared with the existing and projected residential land use pattern. The goal is to maintain the stability of the agricultural land use pattern in the area. The assumption is if the Sheehan's nonfarm dwelling is approved, then a series of nonfarm dwellings on similar properties would be encouraged. The question is, what land use pattern would be created if all the potential nonfarm dwellings were approved on similar properties? Will the change be insignificant / immaterial or will it materially alter the agricultural land use pattern to the detriment of agriculture? Evidence This study area contains 1,713 acres of privately -owned EFU-zoned land. • 83% of this land receives special assessment as farmland. • 1,567 acres comprise 8 farm tracts (listed in Hearings Officer decision). • 1,136 acres are irrigated. Only 329 acres or. 16% of the EFU-zoned land reviewed is dry land taxed at real market value. The evidence is 59 of the EFU tax lots have a house. 36 are farm houses, 21 are nonfarm houses. • 30 or I of the houses date from 1910 to 1976, before the Oregon land use program was in effect. • 21 date from 1979 to 1992, before H8 3661 imposed restrictive standards. • 6 houses date from 1993 to present. The county has approved only 4 CUPS for nonfarm dwellings in this area since 1993. All 4 are on tax lots that currently have no irrigation and are assessed at real market value. 19 vacant EFU tax lots with potential for a nonfarm dwelling exist in this area. • 10 are nonfarm tax lots with no irrigation, assessed at real market value. • 9 are farm tax lots, 0 to 90% irrigated, assessed at farm value. CU003 (A008), Sheehan Page 3 Staff presentation - C003 (A008), Sheehan • 5 of the 9 farm tax lots, including the Sheehan's have been or remain part of a larger farm tract. (161125-200, 161113-901, 161124-100, 161113-700 and 161124-1101) • 8 of the 9 farm tax lots total 139 acres with a total of 104 irrigated acres. • The 9th is 407 acres, part of Matt Day's Hooker Creek Ranch. It is dry rangeland assessed at farm value. The GIS group prepared maps showing the existing and projected agricultural land use patterns. • The map Exhibit A shows in green the tax lots that are receiving special farm assessment. • The farm tracts are outlined in dark green. • Tax lots on the 1992 ag. land inventory in the Comp Plan Resource Element are marked by green crosshatch. This inventory data is interesting because it shows which land has remained in farm use since 1992. • Nnonfarm tax lots - taxed at real market value - are shown in brown. If a nonfarm dwelling were approved on the 10 vacant nonfarm tax lots shown in brown (w/o a house symbol), the acreage in farm use and the water rights available to farms would not decrease. In contrast, if a nonfarm dwelling is approved on the Sheehan's property, the acreage in farm use would decrease by 10 acres and water rights available to other farms would decrease by 8.1 acres. Staff believes 8 vacant farm tax lots have the "same category of developabilitiy" as the Sheehan's property. If a nonfarm dwelling were approved on all 8, the acreage in farm use would decrease by an additional 549 acres or by 132 acres not including the Hooker Creek Ranch parcel. If a nonfarm dwelling were approved on the other 5 irrigated farm tax lots the water rights available to other farms would decrease by an additional 101 acres. This would decrease options for existing farms in the area to use these resources. The map Exhibit B shows the 8 farm tax lots that would convert to nonfarm status if a nonfarm dwelling were approved and the resulting change in the agricultural land use pattern. The converted tax lots are green on Exhibit A and pale orange on Exhibit B. 6 irrigated tax lots, including the Sheehan parcel, identified on the 1992 ag. land inventory would convert to nonfarm status. They are shown in pale C0003 (A008), Sheehan Page 4 Staff presentation - C003 (A008), Sheehan orange with green crosshatch. The Sheehan parcel is yellow with green crosshatch. The proposed nonfarm dwelling would meet the stability standard if the Board finds the pattern of potential nonfarm residential development is insignificant or immaterial and would not materially alter the agricultural land use pattern to the detriment of agriculture in this area. Suitability standard The applicant has argued the proposed a nonfarm homesite is on a portion of the parcel that is not irrigated, generally unproductive land, encompassing an area 120 feet by 140 feet or 28,000 SF - a little more than If acre. The suitability standard states "A lot or parcel is presumed to be suitable if it is composed predominantly of Class 1-6 solls" The subject parcel is composed entirely of Soil 34C, Deschutes Stukel Complex. This soil is class 3-4 irrigated / class 6 dry. Based on National Resource Conservation Service soil capability rating the Hearings Officer found the entire parcel, including the proposed homesite, is presumed to be suitable for producing farm crops and livestock with/without irrigation. The evidence is the home site has been irrigated until recently when the Sheehan's transferred about one-third acre of water from the homesite. The Sheehan's hired a soil scientist to examine the soils at the homesite. He dug 11 soil test pits and recorded the depth and nature of the soil at the pits. His report documents the soil depth to bedrock is 14 to 32 inches on about 7,000 SF or w of the proposed homesite. However, soil depths on the majority of the homesite range from 50 to 60 inches - deeper than expected according to the NRSC description of Soil 34C. The record shows Soil 34C is being used for hay crops and livestock pasture on two adjoining tax lots and on other farms in the area. CU003 (A008), Sheehan Page 5 Staff presentation - C003 (A008), Sheehan The applicant argues the parcel has no agricultural value and does not have a history of farm use. However, as noted, this parcel is listed in the ag. land inventory in the Comp Plan Resource Element. The inventory was completed in 1992 for the Agricultural Lands Project. It was used to determine the farm unit size(s) appropriate to maintain commercial agricultural enterprise in each EFU subzone. The inventory is important because it shows the subject parcel was part of a +27.62 acre irrigated farm tract that ranked among the top 90% of land assessed for farm use in Deschutes County. In 1992, the farm tract was composed of tax lot 1101 now owned by Sheehans and tax lot 1000 now owned by Haldors. The only evidence that the proposed I acre nonfarm homesite is unsuitable is that it includes 7,000 SF of somewhat shallower soils. Otherwise the evidence is the proposed homesite is undifferentiated from the rest of the 10 -acre parcel that has been irrigated, is receiving special assessment as farmland and has historically been farmed as part of a larger tract. Conclusion The Planning Division staff supports the Hearings Office's decision. CU003 (A008), Sheehan Page 6