2003-851-Minutes for Meeting April 23,2003 Recorded 5/8/2003COUNTY OFFICIAL
TES
NANCYUBLANKENSHIP, COUNTY CLERKDS
COMMISSIONERS' JOURNAL 05/08/2003 08:33:35 AM
IIIIIIIII VIII IIIIIII VIII IIII III
2003-0008 1
DESCHUTES COUNTY CLERK
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Deschutes County Board of Commissioners
1130 NW Harriman St., Bend, OR 97701-1947
(541) 388-6570 - Fax (541) 388-4752 - www.deschutes.org
MINUTES OF PUBLIC HEARING
DESCHUTES COUNTY BOARD OF COMMISSIONERS
WEDNESDAY, APRIL 23, 2003
Commissioners' Hearing Room - Administration Building
1130 NW Harriman St., Bend
This meeting was held for the Board of Commissioners to make its decision on
proposed changes to Title 18 of the Deschutes County Code and Zoning Ordinance
that would, if approved, adopt changes to the County's land use regulations for
home occupations (File #TA -02-12).
The proposed changes include creating three types of home occupations and
standards for each type. These regulations, if adopted, would affect property
located outside of the urban growth boundaries of Bend, Redmond and Sisters.
Present were Commissioners Dennis R. Luke, Tom De Wolf and Michael M. Daly.
Also present were Catherine Tilton and Damian Syrnyk, Community Development;
Laurie Craghead, Legal Counsel, and approximately twenty citizens. No
representatives of the media were in attendance.
Chair Dennis Luke opened the meeting at 5: 30 p.m.
Damian Syrnyk explained that relevant documents are on the table and are
available to attendees, along with sign-up sheets for anyone wishing to testify or
receive future information.
He said an e-mail message from Misha Williams was received and forwarded to
the Board, and which is now a part of the record. Also available are copies of
record and testimony received at the Planning Commission's previous two
hearings. Mr. Syrnyk then gave an overview of the issue, referring to a
PowerPoint presentation.
Minutes of Public Hearing Page 1 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
SYRNYK:
What is before you is a proposed Ordinance, No. 2003-003, which is called a
legislative proposal. We're not looking at applying the law to any kind of a
specific property or situation, but are looking at a proposed change to what are the
land use laws in Deschutes County regarding home occupations.
LUKE:
This isn't a state legislative matter. It's a technical term meaning it is a legislative
action by the Board of County Commissioners.
Before you are changes to County zoning regulations on home occupations. These are
changes that, if they are ultimately adopted in some shape, would apply to areas outside
the cities of Bend, Redmond and Sisters -- outside their urban growth boundaries -- and
would apply to areas that are currently zoned for either farm or forest use, rural
residential or in unincorporated communities such as La Pine and Tumalo.
One of the things I wanted to talk about at the beginning is what we mean by home
occupation. This is a term that is in the zoning code. What it refers to is an
occupation or profession that's carried on within a dwelling or a residential
accessory structure. And one of the things I wanted to do at the beginning is talk
about what this does not include.
These proposed changes would not affect bed and breakfast inns, residential homes
such as adult foster care, family childcare providers, farm use or commercial
activities in conjunction with farm use, churches, or private schools.
LUKE:
The reason for excluding foster care is that it is covered under state law.
SYRNYK:
That's correct. Some of the uses that I have listed, such as adult foster care and
family childcare, are regulated by the State of Oregon or through another agency.
They are simply in our code as a use that we permit outright in a single-family
dwelling. Some uses, like bed and breakfast inns and churches, already have
regulations in place for how those are sited. So this is really going to be limited to
things where you are looking at a zone in the County, such as a rural residential
zone, and where you see a home occupation listed as a use that's permitted as a
conditional use, that's where these changes will really take place.
Minutes of Public Hearing Page 2 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
I'll move into some background about how this process started, and what went on
before the Planning Commission. We started this back in October 2002 after
setting an initial hearing date before the Planning Commission for November 14.
We prepared a notice that went out with the tax bills. It was a two-page notice that
also included a background report.
We tried to send it with the tax bills to really accomplish two things. One is to
alert as many residents as we could; but also there was a possibility of looking at
changes that might limit a use in the zoning code. Under state law passed in 1998
under what was called Ballot Measure 56, whenever a local government like a
county is looking at making changes to a land use law that might involve limiting
it, we have to provide certain notice.
One of the things I should state for the record is that we did hear from a number of
folks at the hearing before the Planning Commission that they had not received this
notice in their tax bill. What we tried to do notify as many people as we can is to
create a list of folks on a mailing list. We've also used our website, and with Anna
Johnson, the County's communications coordinator, we've released a couple of
press releases and notifications so we could inform people of this through other
media as well. .
The Planning Commission itself held two public hearings on this proposal. The
first one was in November of last year, and it was continued to January of this
year. The primary reason for that is that the Planning Commission had some other
matters on their agenda that were going to take up quite a bit of time, including a
proposal for the Oregon Water Wonderland sewer system. They wanted to give
people time to testify, and there were a number of people who testified at both
hearings.
After their last hearing, the Planning Commission conducted what are called work
sessions; they had three of them where they actually deliberated over the testimony
they heard, looked at our existing regulations, and tried to craft a proposal to
address a lot of the issues that they heard in testimony. And that's what I will be
presenting to you here in a little bit.
IIOJ.4
Are you going to cover how many people testified before the Planning
Commission?
Minutes of Public Hearing Page 3 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
SYRNYK:
I believe it is covered in the staff report. I think we had at least ten at the first
hearing, and eight at the second. I don't want to be dishonest and say there were a
total of eighteen, because I know we had some repeat folks at both hearings.
What I want to spend a little time on is talking about the current rules that are now
in place for home occupations. In the staff report I mentioned that a certain
category of home occupations is allowed in our code in a manner that is called
permitted outright, where you don't need to have any kind of permit from the
County, provided that you are operating within certain parameters. That's on the
brown handout sheet that's located in the back of the room.
These kinds of home occupations are limited to someone working out of their
home and to the family residing in the dwelling; and the current code limits the
amount of floor area in their home that they can use for this business to 25%. It's
also limited in such a way that no customers or employees can come to the site,
and they really can't engage in any kind of operations that might generate noise,
odors, flashing lights, and other things that might impact their neighbors. It is
really intended for somebody who might just be, for example, just using a bedroom
as an office.
IR, 'J4
May I ask a question? It says family residing in a dwelling. So, under current
regulations you couldn't have a rental that you rent out 75% of the time, and use
25% for a home occupation.
SYRNYK:
Right. This is really intended for somebody who gets up in the morning, has
breakfast, and then goes to a room in their house to run their business.
I do want to mention also that right now under the current code, this category
called permitted outright is only allowed in the unincorporated communities that
we have in Deschutes County, such as Tumalo, Terrebonne, La Pine and Alfalfa.
This is something that is not allowed in a rural residential zone or EFU or forest
zones.
Minutes of Public Hearing Page 4 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
Home occupations are allowed in many of the zones I just mentioned as a
conditional use, where someone actually has to fill out an application, write a
description of what they are doing, address some criteria, and there is a process
they go through to obtain approval. This is also limited, at this time, to folks who
reside in the dwelling that they will be working from. They could also use an
accessory structure. We do allow customers with this type of a home occupation,
but there are no limits or numbers; at this time we look at these on a case-by-case
basis.
One of the big things that we look at with this type of an application is whether
something is going to be compatible with the neighbors. We take into
consideration whether there might be, for instance in an agricultural or a rural
residential neighborhood, the operating characteristics of the business, the kind of
traffic they generate, and whether they might be working inside the home or doing
things outside. Related to that, we also look at traffic and access for these kinds of
applications in terms of parking, customer vehicles, and how they get to the
property.
Finally, one of the criteria for this kind of a permit is that they have to demonstrate
that they are going to be complying with any other county, state or federal laws.
So if they need to get some kind of building permit, that would be required; as well
as documenting that they will be able to obtain, for instance, some kind of state
license.
LUKE:
What kind of notice do you do on a conditional use?
SYRNYK:
There are two ways we handle these kinds of applications at this time. If we
handle them administratively, we would notify property owners within a certain
distance of the property and give them an opportunity of ten to fourteen days to
comment in writing. If there are no adverse comments and the application is
complete, and it meets all of the criteria, we can approve administratively. That
process might take about six to eight weeks. There is also a twelve -day appeal
period after that when we would notify the neighbors again that we acted on that
kind of a permit.
Minutes of Public Hearing Page 5 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
In some cases where there are a lot of people who would like to be heard from on
this kind of proposal, it might be referred to a public hearing before the Hearings
Officer. And that process might take twelve to fourteen weeks, depending on the
level of input and whether extra time is provided for providing written testimony.
Even after that is acted upon by the Hearings Officer, there is also the same
twelve -day appeal period where we would notify everybody who had participated
before the Hearings Officer on what was approved.
So I'm going to start going into the proposed changes. While I am doing this, I will
refer interchangeably to the recommendations of the Planning Commission. I'll
provide an overview before giving specifics.
One of the things that you'll see is a proposal to add a third category, giving a total
of three types of home occupations under the code. The proposal would relocate
our existing regulations from a chapter of the code dealing with conditional uses
into a new section. One of the purposes for that is if some version of the ordinance
is ultimately adopted, no matter what zone you are looking at that allowed a home
occupation, it would all refer to the same set of rules; so you wouldn't be looking at
different locations to see if you are complying with all the regulations for home
occupations.
In addition, you are also going to be looking at a proposal that would change some
of the existing regulations and add some new standards. I'll be talking about those
when I start talking about the three types of home occupations.
Finally, and one of the reasons that the ordinance itself is kind of thick, is that what
is proposed is changing the references in different zones, like EFU, rural
residential, and forest, to refer back to this new section. That's so we won't have
different references going to different parts of our code.
I'm going to start off with this first category that I mentioned, which is type 1. This
is the category that's modeled after our current version of home occupations that
are permitted outright. One of the things that is going to be the same in your
proposal is that this type of a home occupation would be carried on in a dwelling,
by members of the family residing on site.
LUKE:
Catherine (Morrow) mentioned before that those that are permitted outright are
only allowed in the unincorporated communities. Is your proposal, then, to allow
type 1 in all areas?
Minutes of Public Hearing Page 6 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
SYRNYK:
The proposal before you would add a type 1 home occupation to our MUA-10 and
to our RR -10 zones.
LUKE:
So the short answer is yes?
SYRNYK:
Yes. But there's a qualification to that. Under state law, home occupations in EFU
and forest zones have to be treated like conditional uses. So everywhere that a home
occupation is permitted outright currently, it would still be treated as a type 1.
LUKE:
Except for EFU and forest, this use in the rural residential communities under this
new ordinance would be permitted outright.
SYRNYK:
That's right. One of the changes that you will see proposed for this kind of a home
occupation category is the allowance to have some customer traffic come into their
site, limited to about five trips per day. For example, a very simply transaction
where a client might need to sign a document. One of the things that is retained as
part of this category of home occupation is that the operations don't create any kind
of odors, glare, or anything that might impact adjacent neighbors.
We are also retaining an existing standard that the floor area devoted to the home
occupation is still limited to 25% of the total. One of the things that the Planning
Commission wanted to add for your consideration is, this calculation not including
an attached garage. So if somebody was considering whether they had a business
that would meet the criteria for a type 1 home occupation, and they were looking at
the floor area of their home, they would subtract the floor are of the attached
garage.
LUKE:
But you could still use the garage for storage or things like that.
SYRNYK:
Right. Under this type of a home occupation there would be no display of any kind
of products or sale of products; no signage to advertise it; and finally there would
be no kind of inspection. So there would be no real permitting or inspection
required.
Minutes of Public Hearing Page 7 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF (hard to hear; microphone muted):
Could you give me an example of this?
I could give you a good example for a type 1. This could be limited to folks who
might be a sole proprietor, for example an accountant. They work out of their
home, and might have an occasional client stop by to drop off their materials for
taxes. But you wouldn't necessarily know they are there because they might be
working out of a bedroom.
DEWOLF (hard to hear; microphone muted):
If you are limiting it to five trips a day, that won't work around tax preparation
time.
LUKE:
Type 1 could be someone who works on line, maybe a commodities broker, or
somebody who does a lot of business on the phone. The customers could be in
other places.
DEWOLF (hard to hear):
And we wouldn't necessarily even know about these. It's kind of irrelevant.
SYRNYK:
This might be a good way to kind of segueway into giving you an example of type
2. There's a proposal to allow someone to have employees, up to two; for example,
the accountant might have a secretary and some help if they wanted to go this
route. They would be allowed a little bit more floor area of their home, but the
same percentage of 25%, but it would be the combined floor area of their house,
including the garage and one accessory building, with a cap of 1,500 square feet.
They would be allowed more traffic; up to ten trips per day. One of the proposals
for a type 2 is that they would be limited to certain business hours of 8 a.m. to 5
p.m., Monday through Friday. As a potential condition of an approval for this kind
of a permit, they may have to get an annual inspection, depending on the nature of
what they are proposing.
Minutes of Public Hearing Page 8 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LUKE:
Under type 2, where you can have two employees, those are employees on the site?
Let's say it's a building contractor and he has a construction truck there, and the
employee just comes and picks it up, and goes to a jobsite. So it's up to two
employees actually working at the site?
SYRNYK:
The ordinance says that this would be two employees who report to the site for
work. So it is intended to cover employees who actually work at the site. You just
raised a good question about whether that could also be interpreted to cover
employees that might come to somebody's home but then leave to go make
deliveries, for example.
One of the differences between a type 2 and a type 3 is that you are still allowed
employees under a type 3; you can have up to two; but that number can go up to
five if your property is zoned for farm or forest use and is at least twenty acres in
size. Five is the magic number in this case because this is a maximum under state
law that you can have in a farm or a forest zone.
LUKE:
That's state law for anything other than farm use or forest use. You can only have
five employees farming your farm?
LAURIE CRAGHEAD:
For your home occupation building. A farm is not covered under home
occupations. It's under ORS 215.448, for the record. And it says that it shall
employee on site no more five full-time or part-time persons, whether that be
family members or other people. For a farm, forest, or mixed farm and forest that
allows residential use.
SYRNYK:
With a type 3, you are also allowed more floor area, up to 35%. You are also
allowed up to twenty trips per day. One thing I should clarify when I'm talking
about trips per day is that includes customers and employees. There are no
limitations right now on hours; it would be variable and based on someone's
proposal, and ultimately would be approved if they could meet all other criteria.
For the purposes of home occupations, we're talking about someone who travels to
your site, not necessary a trip leaving the site.
Minutes of Public Hearing Page 9 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
One of the things that we have in our code right now is that current applications for
home occupations must have an annual inspection. This is something that the
Planning Commission proposed to retain for type 3. One of the major differences
between types 2 and 3 is that type 3 could have outdoor storage of equipment or
materials.
There are a couple of qualifications; it must be twenty or more acres, and you
would have to have your area screen. There is a proposal for the form of screening
as part of the Planning Commission's recommendation; it could be a fence, existing
tree cover, or landscaping.
DALY:
Why twenty acres?
SYRNYK:
The Planning Commission wanted to have essentially some separation between
somebody trying to do their business and a residence.
DALY:
If you have screening, what difference would it make?
SYRNYK:
A lot of it would depend on where the structures are located on the property; for
example, if they are using an existing building, and what kind of materials it might
be screening. With a twenty -acre minimum, for example, you are usually
guaranteed plenty of space between somebody who might be storing equipment or
materials and their nearest neighbor.
LUKE:
You could also screen it by having it inside of a building.
SYRNYK:
That's true.
DALY:
If it is in a building, you wouldn't need twenty acres, would you?
Minutes of Public Hearing Page 10 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
SYRNYK:
Under the proposed ordinance you would have to have twenty acres. One thing
you can consider when looking at it is whether you might allow storage inside a
building or maybe a combination with screening, as opposed to something like a
setback.
CATHERINE MORROW:
To answer your question, if the equipment is in a building, it's not outside storage.
And it could occur no matter what size your property is. And it could even be in
type 2. So you can have all the equipment you want if you keep it inside. But if
you want to store it outside, then those requirements would apply.
DALY:
They are asking for twenty acres.
MORROW:
That's what the Planning Commission's recommendation is.
DEWOLF:
As part of the twenty acres, are they saying where on that twenty acres this would
need to be sited? Because if it is right up against the property line, it's not really
achieving any purpose.
SYRNYK:
Right. Right now as proposed there is no setback or locational standards for
outdoor storage; just the screening.
CRAGHEAD:
There's also one further restriction on that in the farm and forest use zones. It
cannot be a structure that isn't already normally associated with the uses permitted
in the zone. So you couldn't build a garage just for your trucks in a farm zone,
unless that was a building that is normally allowed for your agricultural uses.
DEWOLF:
I agree with Mike (Daly); I don't understand the point of the twenty acres unless
we are going to actually have setbacks. It could be right up against the road or the
neighbor's property line. Because I can see issues related to noise and dust and
those types of things. I can understand a concept of twenty acres but not if we
aren't doing setbacks.
Minutes of Public Hearing Page 11 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LUKE:
Well, this is a conditional use. And part of a conditional use would be a plan
submitted by the applicant on where and how they are going to store things, and
then the neighbors would have an opportunity to comment on that. I think that's
probably where the screening comes from and how that screening will happen. A
person can say, I don't want that equipment right up against the property line
because that's where my bedroom is. That's the kind of comments you get the
conditional use permit.
DEWOLF:
But you wouldn't suggest any sort of standards?
LUKE:
Well, no. I think that through the application process and through staff and
perhaps the Hearings Officer those kinds of things work themselves out. If you
start to put some standards in, you're not going to hit everybody. The first thing
that's going to happen is that somebody is going to want a conditional use on a
conditional use, because this doesn't meet the standards.
DALY:
What you are saying is this could be done on two acres.
LUKE:
We can talk about that.
SYRNYK:
That's why we are having the hearing, to have these kinds of discussions.
What I'm going to move into right now is to talk about some of the similarities of
type 2 and type 3 where we are using some of our existing regulations and have
some new proposals.
One of the standards that is in our code right now is that we are going to be
considering whether someone's business might be compatible with the character of
their neighborhood or their area. We look at things like their operating
characteristics, and also what kind of buildings they are operating out of.
Minutes of Public Hearing Page 12 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
One of the things that's new is allowing on-site sales. For instance, if someone is
looking at cutting and styling hair, under our conditional use permit they could
have in their stock things like hair care products, shampoo, combs, and that kind of
thing. We're going to be looking at access and parking to make sure it will be
adequate for customers and employees. One of the things that is in our code right
now is our code prohibits any kind of external changes to a house or an accessory
building that would give the appearance of a business.
DEWOLF:
That doesn't make sense to me. If you are talking about having adequate parking
for however many cars, if all twenty trips happen at the same time of day, you'll
have a parking lot of twenty vehicles. How does that not look like a business?
SYRNYK:
That would be something we'd be looking at on a case-by-case basis with an
application. Somebody might have that allowance of twenty trips per day, but
depending upon the nature of what they may be doing, they may be doing things
by appointment or may be seeing people only during certain times of the day.
Those are the things that we exercise some discretion with in terms of looking at
whether they can meet that standard.
That's also a good question to talk about, what might be adequate in terms of --
DEWOLF:
Maybe I just missed this. The most number of trips on a type 3 is 20?
SYRNYK:
That's right.
DEWOLF:
So nothing anywhere is more than twenty trips per day.
SYRNYK:
That's right.
DEWOLF:
So if you are a chiropractor who works out of your home --
LUKE:
That includes the employee trips, too.
Minutes of Public Hearing Page 13 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
SYRNYK:
That's also a good issue for discussion in terms of how we reconcile those two
standards.
DALY:
Can you back up just a second? I've got a question on that issue, no external
changes to give the appearance of a business. In other words, we will allow a
business there but we don't want it to look like one. Is that what you are saying?
SYRNYK:
That's right.
DEWOLF:
You've got one little sign hanging by your mailbox that says Joe's Chiropractic.
But you can't have a big spine up on top of your chimney.
DALY:
This is type 2 and 3?
SYRNYK:
Yes.
114
They're talking about some areas that could be larger acreages, but they are also
talking about things that could be an acre or two residential lot. What you are
talking about is allowing businesses to operate within a residential area, and I think
we are trying to stay away from changing the appearance of a residential area.
SYRNYK:
That's exactly it. The idea is, kind of going back to the type 1 example, that one of
the purposes of creating this category is so that if someone working out of their
home but they are not engaging in such a practice or with certain operating
characteristics that you wouldn't know they are there. So as you are driving
through trying to find a business, it will look like another residential or rural
residential neighborhood.
Minutes of Public Hearing Page 14 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
Actually, I'm glad you brought up signage, because one of the things the Planning
Commission did propose to change is to allow folks a sign without any kind of a
sign permit that would be three square feet maximum, either a ground mounted
sign sitting at their driveway or on a wall of their home. One of the things that is
proposed to be retained is a standard that says the business itself can't use any
materials or equipment that would generate things like noise, vibrations, flashing
lights, and so on that would affect adjacent residences.
And, finally, I'd like to mention that with our current rules, as part of their permit
they still have to comply with any kind of county, state or federal requirements that
might be tied to their business.
DALY:
Getting back to the use of materials or equipment that would affect adjacent
residences. We're still talking the actual occupation being on the site itself, not just
equipment that shows up and leaves or whatever.
SYRNYK:
Exactly. That's referring to actual activities on site.
DEWOLF:
So if someone stores equipment on site, but they are a contractor and their jobs are
elsewhere, this doesn't apply.
SYRNYK:
Well, that's a gray area still. I think it would depend on whether they are actually
operating their business from their home, whether they would use it as a place of
business, where they do their books, talk with clients, store equipment, whatever.
That's something that as a Board you are probably going to be asked to think about
and reconcile in terms of what has been proposed by the Planning Commission.
LUKE:
There was a discussion at one time about a well driller, and of course a well driller
doesn't drill wells on his own property, but he occasionally needed to park his truck
there. That was a question, and those are the kinds of things we have to work
through. But typically the truck is not at his home, but is out somewhere else
working, and a lot of times it moves from one job to another. But occasionally it
has to come home to be cleaned up or repaired; and is that allowed? It is allowed
under this?
Minutes of Public Hearing Page 15 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
SYRNYK:
That's a good question.
DEWOLF:
And we're hitting gray areas here.
SYRNYK:
That's one of the reasons we're having the hearing.
DALY:
I almost think we need another type.
MORROW:
This issue of parking trucks was talked about quite a lot with the Planning
Commission. Say you are a carpet cleaner. You have a carpet cleaning truck with
a sign on the side, and you park it there every night. The Planning Commission
had a lot of discussion about this, and they said that if it is parked inside, we don't
care.
And then there are also some requirements I think that Damian didn't actually
emphasize in this presentation that have to do with gross vehicle weight. You
might want to go into that a little bit. I don't know if I can do the details. It
basically came down to that if it's a normal kind of passenger vehicle, even a van,
and you park it in your driveway, even if it has the advertising on it, it's okay. But
when it gets over a certain size, you either need to park it inside or meet these
requirements for parking equipment outside.
LUKE:
A pickup with a lumber rack and a business sign on the side would be allowed
because that's the typical rig somebody drives back and forth to home. But, a log
truck that has to start up at 4:00 a.m. to warm up the diesel before they go out in
the woods would be a different matter.
MORROW:
That's regulated.
Minutes of Public Hearing Page 16 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
SYRNYK:
Let me segueway into the two types of conditional use. One of the limitations that
is proposed under a type 2 home occupation is that the business could store used
vehicles or equipment with a gross vehicle weight of 10,000 pounds or more, or an
operating weight of 3,000 pounds or more. So if someone is using as part of their
business a small passenger van that says, Joe's Greeting Cards, on the side, that
might be allowed as a type 2, especially if they are making deliveries. But if you
are using heavier equipment, it wouldn't be allowed under type 2.
Under type 3, if they are using equipment like that, they would have to either park
it in a building such as a garage or accessory building, or screen it in an outdoor
storage area.
DALY:
When you say using equipment, are you talking about using it on site? We are
talking about a home occupation. That equipment normally would not be used on
site; it's just parked there at night.
SYRNYK:
It sounds like you are talking about something that might not be a home
occupation. If I can go back to the definition for a second, what our code talks
about with a home occupation is, an occupation or profession that's carried on from
within a dwelling or residential accessory structure.
DALY:
That's carried on within.
SYRNYK:
Right. Let me do this. Let's look at the definition of home occupation again, under
our code. What I want to talk about briefly is to kind of summarize the differences
between type 2 and type 3.
Under the proposal before you, a type 2 occupation would require a conditional use
permit. We handle these kinds of permits administratively. This means that
someone makes an application, we'd review it, and if it meets all the criteria we
would approve it and would give notice to the neighbors that we've approved
something like, for instance, a hair stylist.
Minutes of Public Hearing Page 17 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LUKE:
You give notice before you approve it, also.
SYRNYK:
As proposed, you'd be giving notice of the decision.
LUKE:
You are not proposing that when the application is made, that you'd give notice
then?
SYRNYK:
Not under type 2, because of the limitations that are under our type 2 home
occupation. Under a type 3, we'd be using our existing procedures with either
giving prior notice once the application came in, or maybe referring the application
to a public hearing.
In terms of uses, there's a list of excluded uses that wouldn't be eligible under a
type 2 home occupation. Under type 3 there is no such exclusions right now, as
proposed. We'd be looking at these on a case-by-case basis, and seeing whether
they meet all the criteria.
Let me summarize the ones that don't. They include things like the repair, towing
or storage of vehicles; appliance repair; and welding shops. These are excluded
from type 2. They may be allowed under a type 3.
We talked about outdoor storage. Under type 2, any kind of outdoor storage would
not be allowed, but storage of materials and equipment could occur inside a
building. Under type 3, it could be allowed with screening, if it meets the acreage
requirement. That's proposed.
In terms of annual inspections, they are required with type 3, as proposed. But
they may be required as a condition of approval under type 2.
The number of employees is the same in both cases; it's two. But under type 3, you
might be allowed more, if you are zoned for farm use or forest use and you've got
at least twenty acres.
Under type 3, you could have up to twenty trips per day. And in terms of floor
area, under type 3 you are allowed more floor area of your home and an accessory
building devoted to your business.
Minutes of Public Hearing Page 18 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LUKE:
Do you envision charging for inspections?
SYRNYK:
One of the things that we talked about internally, but I don't know if it is part of the
budget discussions right now, is that there is going to be some kind of a small fee,
like $20 or $25 just to do an annual review or inspection, just to check in to make
sure someone is complying with the terms of their permit.
What I wanted to go back to just briefly before we open the hearing is our
definition of home occupation. Again, this is part of our code right now, and our
code defines a home occupation as an occupation or profession carried on within a
dwelling or residential accessory structure. So one of the questions that you are
going to be asked to think about is whether someone who simply drives their truck
home, parks in the driveway, and maybe meets with an employee to go somewhere
offsite, whether that even qualifies as a home occupation. So one of the things that
we can consider is maybe clarifying that definition as well.
DEWOLF:
I guess I don't know how I feel about this stuff yet. I'm looking forward to the
debate. A concern I have is that I keep thinking about Joe the chiropractor. And
maybe we don't want chiropractors operating outside of a commercial zone. But if
in fact what this is going to allow is for Joe to work, or maybe Joelle's Hairdressing
Salon, brother and sister, so that's two people, and you have eighteen trips left.
That means they can each have nine people come to get their hair cut or whatever
during an eight-hour day, Monday through Friday.
If we were going to do this, I'm a little concerned about limiting the number of
trips on a type 3 to twenty. It seems like under type 3 we'd be so restrictive under
what we would allow, but if we are going to allow it, we'd want to be able to see
them succeed. Otherwise, why not get rid of it altogether and have these folks be
in a commercial zone within an urban area. I struggle with that.
If you've got one chiropractor, if an appointment lasts an hour, well that's eight
customers a day, with no lunch hour, you fit under the ten limitation. But if they
are every half-hour, that's an issue.
Minutes of Public Hearing Page 19 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
I0 .1.4
I would point out again, we are talking about placing businesses inside a residential
area. And if a person is going to do the kind of business that is being talked about,
they probably should be in a commercial area with more parking, better access, and
whether they can have the type of building they should have to meet customers'
needs. Because if you are going to do things that require inspections, especially
state and federal, there are certain restrictions on them that really don't do well in a
rural residential subdivision, although it might work in a city subdivision
depending on how it is set up. I'm interested in hearing the testimony. We are
talking about placing these in a residential area.
DEWOLF:
And recognizing that there is a fair amount that already exist out there that we are
not regulating, that we're not aware of, and that aren't causing any grief to their
neighbors. And what we are potentially doing is here is creating grief for people
that doesn't currently exist. And that's what I want to be aware of, to remember
that the knee bone is connected to the shinbone here. This will have an impact.
SYRNYK:
One thing, if I could just kind of wrap up before we open this up for testimony, one
of the reasons is we heard that people run a home-based business is that a lot of
businesses start out of peoples' homes. One of the things to consider is what
standards in place would allow them to do that without interfering with the use of
the neighbors' property, but also being mindful that they may reach a point where
we can't approve it as a conditional use anymore; that they might need to get a
better space. It's not just better for the neighbors, but it might be better for them in
terms of growing their business.
DALY:
With an annual inspection, if they get bigger every year?
SYRNYK:
It will be to verify that they comply with the terms of the permit.
LUKE:
Again, code violations are complaint driven, so that's always an option, too. If
something happens six months into the year that the neighbors find is beyond the
approval, that becomes a code violation.
Minutes of Public Hearing Page 20 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
SYRNYK:
Before you open up the testimony, I wanted to point out that we are not under a
deadline to finish this project. Staff would support leaving the record open if
people want to submit additional testimony, or even continue the hearing if the
Board wants to think about things and maybe get input on some changes, too.
LUKE:
I don't think there is any question that the record will be left open. We will attempt
to answer all your questions as you ask them tonight, but if you agree with
somebody who testified before you, we would appreciate it if you would say, I
agree, and add a couple of items if you want. In this way we can get as much
testimony as possible. The record will be left open for additional written
comments and to get questions answered if we can't answer them for you tonight.
At this time, Chair Luke opened up the hearing for public testimony.
JEFF EDWARDS:
I live in a rural residential area with all five -acre parcels.
SYRNYK:
Sorry to interrupt. If folks can be sure to give us their mailing address, if there is
another hearing or when we're all finished, we can get you a copy of the final
ordinance.
EDWARDS:
I'm here because we do live in a rural residential area, and we've got a business that
had been applied for and denied a conditional use permit, we went through a
Hearings Officer. It is the well drilling, as Mr. Luke announced earlier. That type
of business, even though you mentioned the noise and traffic and that stuff, even
though the vehicles are coming and maybe not being there every single day, there's
a number of vehicles. There are two or three large trucks, there are maintenance
trucks, there are water trucks, there's Hysters, there's pipe, and all kinds of stuff
that comes with that excess baggage. And it's very disrupting at times, in the
mornings when they start them up and in the evenings and weekends.
DEWOLF:
I'm confused. This is your business?
Minutes of Public Hearing Page 21 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
EDWARDS:
No. I'm opposed to a well drilling business being put right next door to my home
residence. Someone else applied, and it was denied.
LUKE:
So you are using your five acres strictly for residential.
EDWARDS:
And that's pretty much the way the whole area is set up. If it was a construction
truck, maybe for landscaping with a trailer behind it, that's one thing. But when
you have large well drilling trucks that are thousands of pounds, you've got
deliveries of raw materials -- betonite, pipe, all kinds of things coming in on
flatbed trucks -- it's very disrupting. Especially when you live on a cinder road.
They tear up the road, and so forth and so on. But there's been a lot of
documentation submitted through this whole process, which has been going on for
about two and one-half years now.
DEWOLF:
Are you close to all of this?
EDWARDS:
There are portions of it. I'm not opposed to somebody that has to make a living out
of their home. Like a landscaper or construction guy.
DEWOLF:
Who has a truck and a trailer, and does his phone calls at home.
EDWARDS:
And the way that that business is being operated right now, the one I'm speaking of
is a well drilling business, they are conducting their telephone calls, everything out
of their home because that's where the numbers go to. That has no adverse effect
on any of the neighbors; they could do that all day long. It's the coming and going
of the equipment, the storage of the equipment, the appearance. And what tends to
happen -- and there's plenty of photos and stuff that were submitted as well that the
Board can take a look at -- by not only myself but other neighbors as well.
There's a place for businesses of that nature, and that's in a business district.
People move into the country to enjoy the peace and quiet. And a lot of people
don't get to pick where they work, but they do get to pick where they want to live.
Minutes of Public Hearing Page 22 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
Like I said, I've spent a lot of time and money trying to keep this kind of activity
from going on in a residential area.
I just would appreciate your thoughts, and at least review the data. Perhaps some
of you have done so in the past. And really consider that when you are looking at
these different types. Mr. Daly said he thought there should be another type.
Maybe there should be, but then again, where do you draw that line. Who's going
to police the number of trips and that kind of stuff.
DEWOLF:
It's typically left up to the neighbors. Most of this stuff is complaint driven.
EDWARDS:
It is. And when you do submit a complaint, it takes forever to get it taken care of.
And then it becomes a major issue. So, I recommend that businesses of this nature
and that have multiple vehicles and multiple things going on, stay where they are
supposed to be.
DALY:
As proposed in type 3, if they went through a conditional use permit process before
this business was located there, and there was adequate screening and adequate
distance from your home and whatever, is that something you could live with then?
EDWARDS:
No, because you've still got the noise and the traffic, and like I said, if it was a
standard vehicle, a standard pickup pulling a trailer, that's one thing. But you've
got these things, thousands upon thousands of pounds, coming and going. Maybe
they would only come and go two or three times a week, but when there are two or
three of them and you've got other operations being done, it tends to be very
annoying.
DEWOLF:
We don't have any limitation on the number of vehicles that can be stored, as I
recall, do we? We've been talking numbers of trips.
SYRNYK:
As proposed, we are looking at numbers of trips and not numbers of vehicles.
Minutes of Public Hearing Page 23 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
EDWARDS:
And it's very key on how it's set up, too. You brought that up about setbacks and
stuff. And even though it might meet a setback, a setback on a five -acre parcel is a
lot different than a setback on a twenty -acre parcel. Because the way that this
business is set up right now, or the way that the operation is set up, I sit on my
patio and I've got to look right at it. But the way the residence of the owner is set
up, they don't see it because it's out back. Everybody else has to view it, though.
DALY:
I understand where you are coming from. I think we are familiar with the case.
Some five -acre parcels, depending on how they are configured, can allow a lot of
distance between residences.
EDWARDS:
That may be true, but the way it is set up is very key; and the way that this specific
thing is set up affects the view. I go outside, and it's right there.
DEWOLF:
And we aren't discussing the height of what's being stored. Crane operator, no
employees, one crane, but it's 45 feet tall.
EDWARDS:
You're talking about the size of the building; but you also have to consider the size
of the parking area. In this specific case, the parking area is probably a good acre
of red cinder -- I'm just guessing -- with a 36 by 60 or 40 by 60 building sitting
right there. There's no problem with the building. But it's everything that is left
outside. And, like I said, it just tears up the roads, and we've got to maintain our
own cinder road. The County doesn't do that.
SUE BEBE:
My name is Sue Bebe. I live in the Tall Pines subdivision of La Pine.
LUKE:
How big are the lots there?
We have an acre lot. Actually I used to have a home business as an accountant.
didn't do taxes for people, but did businesses, and they all mailed me their stuff.
So I very seldom had a client stop by.
Minutes of Public Hearing Page 24 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
So five trips a day is no big deal with the way that you did business.
BEBE:
No. But in the same respect, I lived in San Leandro, California, and at the time I
had to go around to all of my neighbors who had to sign that I was not causing any
problems with them, before I was allowed to do this. Possibly I could have gotten
by without that, but I chose to do it the legal way.
However, the reason I am here tonight is because, like Mr. Edwards, we have
problem in our neighborhood with a car repair business. We live on a cul-de-sac,
with nice homes. I believe Mr. DeWolf has seen this area, because he has had
some dealings with my neighbor Betty Smith.
DEWOLF:
Oh, you are off of Bullbat.
BEBE:
We're on Bullbat, at the very end of the cul-de-sac, past Betty, so we are actually
not so much affected as Betty would be, or my father who lives directly behind the
property involved. Mr. McConnell here, who is with me, also lives directly behind
it. However, a bunch of us neighbors got together and filed a complaint with the
County about this.
There is traffic. He hauls cars in all the time. He'll have as many as thirteen or
fourteen cars at a time on his property. He has piles of car parts in the backyard.
There are about forty differentials right now, just piled up in the backyard. He runs
his equipment a lot of times at night, and it interferes with my father's television
reception. In addition to that, it's only a cul-de-sac, and it's a dirt road, so hauling
these cars in and out tears up the road.
And it looks junky. We have a nice neighborhood, and we don't want it to look
junky. We've met with the County code enforcement, and they only have one code
enforcement person. They told us they know he is running a business, and it's not
a legal business. But, there's no way they can prove it. It's up to us to prove it. So
we're still fighting this after a year.
Minutes of Public Hearing Page 25 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
In this particular instance, this individual has been cited. There are a number of
difficulties. This is a code enforcement issue, and not a home occupation, because
there is no way he would be allowed to have this kind of home occupation. I
assume that he has still built up the stacks of wood around those differentials to
kind of screen them. Are you the one who is directly behind him?
MAN:
I'm directly behind him.
DEWOLF:
Then I was in your backyard, right.
MAN:
It's not getting better, either.
LUKE:
We need him now to put his name on the record. Why don't you come on up?
DEWOLF:
In any case, this is a code enforcement issue, and part of what we are dealing with
is that we've got one code enforcement person in Community Development, and
we've got one with the Sheriff s Office. And now we are looking at transferring
authority the Justice Court because Circuit Court is so limited in what they can do,
because of state budget cuts. So it's going to get worse with what we're facing.
BEBE:
That's true.
DEWOLF:
But I'm not sure that this applies to the home occupation, because there is just no
way that in this particular case he would be given any authority to run a car repair
business.
LUKE:
Please identify yourself.
Minutes of Public Hearing Page 26 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DAVID MCCONNELL:
My name is David McConnell. What I see happening here is that you are opening
a door for a lot more of these cases. And I think enforcement of what you have
now, until it comes up to satisfying the taxpayers, is the primary thing you should
be looking at.
I would like to say that we ourselves have investigated. I went on line and found
an advertisement of his business, and he has a separate phone line for that, under
High Desert Auto Repair. He's listed in the white pages as High Desert Auto
Repair. We told this to the enforcement people, and they said that's good, and
we're meeting with them again. The main concern that I have is the same as Mr.
McConnell. It is that we are making regulations even looser. If we can't enforce
the regulations we have now, why are we loosening the regulations?
LUKE:
For the record, Mr. McConnell is also from La Pine and has signed up. Why don't
you go ahead and testify as long as you're up here, if you'd like.
MCCONNELL:
My biggest concern is that what you are opening up is La Pine, Deschutes River
Woods, Terrebonne, every place, to become totally industrialized and ruined for
residential. Just like the gentleman with the well drilling problem. If he has
already been denied by the County, why is he still allowed to do it?
DEWOLF:
I know what you've been facing. Betty brought this to my attention two years ago.
MCCONNELL:
We're all collecting photographic evidence and all of the other stuff, and keeping a
log on what's happening, and we have a meeting scheduled with the enforcement
people on May 7`". And we hope that with our evidence they can cite them into
court or something. But we're taking six people's complaints, and allowing the
man to keep on going with his business.
DALY:
I think what we are doing here would never allow what you are describing. I don't
see it as loosening up regulations that would allow that.
Minutes of Public Hearing Page 27 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
MCCONNELL:
But if you can't enforce what you've already got, you're adding more.
DEWOLF:
I think that's what we do need to be aware of, is if this proposal is in fact allowing
a variety of new types of business uses in residential zones, you end up pitting
neighbor against neighbor who are upset with each other, and then what happens to
our code enforcement. I definitely respect the concern there. That's what we need
to be aware of, if in fact what is being proposed is just clarifying this, which would
tighten up the regulations, that would be one thing. And I'm not sure that's what
we are doing here.
DALY:
With type 2 and type 3, you are talking about the conditional use process, which is
a very extensive process anyway. If this person that they are talking about actually
went through that process, obviously he wouldn't have been allowed to be there
anyway. So, by putting this through a conditional use process for some of these
businesses, it possibly could allow businesses that would be compatible with the
neighbors, and they have to go through this criteria anyway. So, I think we are
tightening up that part of this by allowing some of these things.
LUKE:
I would like to point out that it's not that we can't enforce it. But property rights
are one of the things that everyone has and values, the right to use your own
property. The courts are very hesitant to move into that arena unless they can be
shown that it is a violation and not just a neighbor against neighbor type of thing.
So it takes time. We had a guy with all kinds of cars up on Whispering Pines, and
he ended up being in jail and then his wife gave us permission to haul the cars
away. But he was in court, and they would give an order and he wouldn't follow it.
The laws that we have through code enforcement, and you've seen our code
enforcement officer and if he came to my house, I'd do what he told me to do,
people don't have to be cited. They often say, I'll take care of that and I don't want
a problem and I'll fix that. But you will get people, and I assume this is one of
them, where laws mean nothing to them anyway. Those always take longer
because of the process involved, the due process.
MCCONNELL:
One thing I noticed down here, the maximum size of the floor area for the
occupation, under type 3, how big is that accessory building?
Minutes of Public Hearing Page 28 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
I don't know. There is no restriction like on the other one, where you've got 25%
with a maximum of 1500 square feet. There's no maximum square footage on a
type 3, and that's a concern to me.
SYRNYK:
It could be any size.
DEWOLF:
He's got an accessory building that I think he was attempting to add on to.
MCCONNELL:
He enclosed it, and his noise is a problem still.
LUKE:
Is his land an acre?
BEBE:
It's only an acre.
LUKE:
Then type 3 wouldn't be allowed in that anyway. Type 2 wouldn't, either.
DEWOLF:
This is a pure and simple code violation. Absolutely.
MCCONNELL:
Under type 2, it says one-half acre of land.
SYRNYK:
Under type 2, you have to start with a minimum property size of one-half acre.
But there's no size requirement under a type 3, as proposed.
LUKE:
Anything else?
MCCONNELL:
We'll see what happens on the 71h
Minutes of Public Hearing Page 29 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LUKE:
Thank you very much. Is there a Frank Pennock here? Are you still president of
the Deschutes River Woods Homeowners' Association?
FRANK PENNOCK:
I'm in my ninth year. My name is Frank Pennock, and I'm president of the
Deschutes River Woods Homeowners' Association. And you've just about
discussed the same thing just previous, with this thing on the junk automobiles.
And I'm told that they will tell you that they are restoring those cars.
So I'm wondering how many automobiles are allowed on the property, and if you
can ever change the code enforcement to where you could get rid of these things
when they are in total violation. They won't even fit any one of the three criteria
that you've got up there. How long would it take if you were able to enforce it to
evict the guy and the automobiles, and so on. It sounds to me like you've got to
change the laws or open up more courts or give every deputy one day off to be a
code enforcement officer. One day.
DEWOLF:
We'll let you talk with the Sheriff about that one, Frank.
PENNOCK:
Another thing. About the signs, I think somebody mentioned here that someone
has a business down the street, let's say a welder. Then I see at an intersection that
it says "welding" and an arrow points down the street. And you just go down the
street until you find his sign. Are there restrictions on that? Or will there be?
LUKE:
Off-site signs require a permit in Deschutes County.
SYRNYK:
Actually, any kind of a sign requires a permit. But the County sign code only
allows signs on property where someone is actually advertising what they are
doing. So, as proposed, if somebody wanted to have a sign, they could have it on
their property, but they couldn't have a sign off-site that said "welder, this way".
LUKE:
Now, what he is talking about, if there is a sign off-site, according to the home
occupation that is already used, that off-site sign is probably in violation of the
current code.
Minutes of Public Hearing Page 30 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
SYRNYK:
That's right.
PENNOCK:
And I've been told by Gary Judd (of the Road Department) when he goes around
and cleans up some of the signs, like the old real estate signs and that type of thing,
that basically you are stealing them if you pick them up.
DALY:
Real estate signs are allowed, I'm sure.
DEWOLF:
They are so often located in the road right-of-way, that it is beyond belief. But it's
the same thing with political signs during an election season. They get them in
right-of-way all the time.
What about if somebody has a sign on top of their car, and parks their car down the
road? I mean, right up here there's that trailer where the Thai food is, next to the
car lube shop. There's the car with the sign that says, Thai food, enter from alley.
Now that is a city example, but in the County, do people do that? They're not
pounding it into the ground. It's on top of their car, or a magnetic sign on their car,
but they are essentially doing the same thing. Is that allowed?
SYRNKY:
That's a question that I don't remember the answer to. What I'd have to do is look
it up in the code. There is an answer, but I just can't remember it right now. But I
can find it.
PENNOCK:
One other thing on the sign business. If there's a business permitted, can they
advertise in the newspaper or on television, even though they can have one sign in
front of their property. Is there any restriction on the continuous advertising in the
newspapers or television?
SYRNYK:
There's nothing in the proposal that would restrict somebody's ability to advertise.
Minutes of Public Hearing Page 31 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LUKE:
You could be in the yellow pages or whatever you want. If you violate the number
of cars that are coming in because of that advertising -- I mean, if you are only
allowed five trips a day, or even ten, it doesn't pay to advertise. That doesn't do it.
Why would you do that.
DALY:
I'm sure we would not control advertising in newspapers or whatever.
DEWOLF:
I think we ought to start trampling on the first amendment. That would be a good
challenge to take on.
PENNOCK:
One further comment about this. I don't know how many of you people have seen
the Deschutes County code enforcement officer, but he could play offensive tackle
and guard on anybody's professional team at one time. He's big. And one time we
had him as a speaker at our homeowners' meeting, and I said that sometimes I go
out China Hat Road and there will be an abandoned car on the side of the road that
is getting less and less all the time because the parts are being removed. I said,
supposed one of those parts fits in my car, can I take it? And he said that's
stealing, even though the car is abandoned.
LUKE:
Frank, have you had discussions at your homeowners' meeting about this, and what
kinds of concerns were raised? Do you think the code needs to be changed, or do
you like anything that has been presented tonight? What's your thoughts on this?
PENNOCK:
From what I can hear tonight, the concerns we have out there now would never
take place. They would never be able to put anything in. Like the ones that are
already there, and like these people described, with the piles of auto parts. The
problem is that there are some, as we know, that are already there. How do we get
rid of them, and how long will it take?
And as you said, Commissioner, there are people who have absolutely no regard
for any law or authority. Something has got to be done, but how are you going to
do it? I don't know. I just suggested something, to give every deputy one day off
regular work to be code enforcement officers and go see these people. That would
probably cover everything in one day.
Minutes of Public Hearing Page 32 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
How you would enforce it, that's the question. And how long. And I heard about
that one out there where the guy was in jail. That took how long, about two or
three years?
LUKE:
That happened before I came here. Thank you.
FRANK BRYAN:
My name is Frank Bryan, and I live out on Young Avenue. I'm going to read from
prepared text. And some of this would have changed, based on Damian's
statements tonight. I was at the first meeting, and I was at the work session on
Monday, so some of what is in here has changed, but I will read this to you and
give it to you.
LUKE:
Were you comfortable with the process, and do you believe the Planning
Commission took the time they needed to go through this?
BRYAN:
I've addressed this in here, if that's okay.
DEWOLF:
Where you live, what size of acreage are we talking about.
BRYAN:
I live on forty acres.
DEWOLF:
And is that the standard in the area?
BRYAN:
No, actually a great portion of what you gentlemen are fighting I am sure is the
hodge-podge nature of the zoning that has gone on in the past, where you will have
rural residential and EFU and MUA and all of this all stacked right next to one
another. And somebody has flatulence and everybody knows about it. So, I mean,
it is a real problem. And my first paragraph is to commend you for trying to make
some sense out of the current regulations. I can read the words without a problem,
but I cannot understand what it means.
Minutes of Public Hearing Page 33 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
Welcome to government.
BRYAN:
That's why I move here. Here we go. (He then read his four page statement, a
copy of which is attached as Exhibit A)
LUKE:
About the notification; was it announced at the first hearing when the next hearing
would be, or was it recessed? How was that handled?
What I seem to recall, and I'd actually have to check the minutes to know, I think
the Planning Commission did announce that they were going to continue it to
January 9, and I'd have to check the file, but I thought we sent a notice for the
hearing. I know we did not send the notice to the work sessions. In part, we don't
normally notify folks of work sessions because they are primarily public meetings
where the Planning Commission deliberates. They are open to the public, and we
notify the general media of work sessions, but we don't typically notify everybody
as a practice.
LUKE:
This isn't even close to being a final ordinance. This is going to take some work
and discussions amongst the Commissioners. That's one reason we are taking this
public testimony.
BRYAN:
And I appreciate it. Part of the reason I am here tonight is so I can voice my
opinion about that, and so far Damian has been great. I have no problem with
him.
s)"
It's one of the reasons the Planning Commission has most of its meetings in the
evenings, so more people can attend. It's the same reason we started this one at
5:30.
Sure. And I appreciate the time that takes away from your lives and all that.
Minutes of Public Hearing Page 34 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
Do you put the agendas for the Planning Commission on line, in advance of the
meetings?
SYRNYK:
Usually we do.
DEWOLF:
There's no question that we can always do a better j ob with communications. We
try to keep things up to date and on line.
W
Honestly, you'd be surprised at how many people I've talked to who believe county
government doesn't exist.
DEWOLF:
Well, that helps us, and we'd prefer that the city be on the front page instead of us.
MIKE MCFARLAND:
My name is Mike McFarland, and I've been in business for myself for about 23
years. I started out in the trucking business and moved into the excavation
businesses, and worked pretty much all over the state. I just got into residential
work here eight or ten years ago, in Terrebonne. I run a small excavation business.
I don't meet people at my home. I usually meet them on the site where they want
the excavation done. My equipment is stored at home, and I do drive a big truck
along with a one -ton.
LUKE:
What's the gross vehicle weight?
MCFARLAND:
It's 8,600. And the gross vehicle weight on the other one is 80,000. I need this
truck to move my equipment and haul rock and stuff. I have a trailer, too.
LUKE:
How big a parcel are you on?
Minutes of Public Hearing Page 35 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
MCFARLAND:
About thirteen acres. And it's in the unincorporated Terrebonne area. A building
big enough to put my stuff inside, which I'd love to do, is probably $35,000 to
$40,000. And I'm not sure it would get all of it inside. I have trees on both sides, a
church is on one side, my neighbor sits halfway in and he has thirteen acres, too.
There's another seven or eight acre piece on the other side of me, the north side,
with a guy with a house on one acre, and then Terrebonne is across there.
I've done work for all of my neighbors. I keep the road up, keep it graveled. I'm in
and out of there from early in the morning until late at night. A lot of people call
me on weekends because that's when they're home. They'd like a load of gravel or
a ditch dug, or a big rock moved. I really don't have the hours of eight to five,
Monday through Friday. And there's probably no way that that would work.
LUKE:
Have you had any complaints filed against you?
MCFARLAND:
Not yet, but that's why I'm interested in what's going to happen here. Because if
one of the places sells and my neighbors raised heck about it, I can't afford to
move. And I can't afford to go to town and buy some commercial ground to run
this business from. I've lived there for fifteen years without a complaint. And I
just kind of wonder where this is going to put me. Is there any such thing as
grandfathering it in?
LUKE:
I don't recall that. How can you be grandfathered in if you don't have a permit to
be there to start with? That's the question, I guess.
SYRNYK:
That's a question that Mr. Bryan raised in terms of how this would affect existing
uses. If I could digress for just a minute, or I guess interrupt, if someone has an
approved conditional use for a home occupation, there are going to be covered by
the permit and the laws that were in place when they applied.
If somebody came in the day the ordinance took effect, they'd be under the laws
that were essentially adopted then. If someone is in business now but without
some kind of home occupation permit, that's a different question. We might have
to look at whether they were lawfully established or in place as a non -conforming
use. But that can be a gray area sometimes.
Minutes of Public Hearing Page 36 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DALY:
Is what he is describing in any way fit into the type 3?
DEWOLF:
No, it's not twenty acres.
I07:v"
I know. If the twenty acres was adjusted to a smaller acreage, I question as to
whether or not this is even a home occupation. If you're not really working at
home.
SYRNYK:
That's a question I think the Board should consider.
DEWOLF:
How do people reach you if they want your services?
MCFARLAND:
Usually on my cell phone, or my phone in the house. My briefcase is in my
pickup.
DEWOLF:
This is exactly the kind of unintended consequences that I want us to be really
aware of.
[KOW:: 1 ►I0
There is one other thing I need to say. I applied for a shop building on this, and
they will not give you a commercial shop building on a rural residential deal. And
they will not give you an agricultural building permit on this twelve acres. So I am
kind of in limbo of what I can even do.
DEWOLF:
What's the zoning?
MCFARLAND:
It's RR -5.
SYRNYK:
In Terrebonne there's a five -acre residential district.
Minutes of Public Hearing Page 37 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
MCFARLAND:
The only other thing I have to say is that for small guys like me, I have no
employees, and if I have to go to town and rent a shop or something, they run from
$800 to $2,800 or more for an area large enough to park this equipment and stuff.
And that is something that I would have to charge to even move. A lot of times it's
hard enough just to make your house payment and your business payments, and
not be a burden on anybody else.
DALY:
Mike, how many other folks do you know who might be in the same situation as
you?
MCFARLAND:
Probably thirty in the surrounding area, maybe more.
DALY:
All of them non -conforming uses?
MCFARLAND:
Sure. Just like me. But they've been there a long time, too. Thank you.
VERN BJURK:
My name is Vern Bjurk and I live on Smokey Ridge Road, which is west of town,
just two miles past Tumalo. I have just under ten acres.
Mainly I'm here to pose a hypothetical question. Looking at the types 1, 2 and 3,
they seem fine to me. But let's say you meet the criteria of a type 2 or type 3, and
you were actually on the low end of the usage. So you thought, well, I qualify for
that, it shouldn't be a problem. But you have a neighbor that thinks I'm too good
looking for him or something, and he doesn't like me. And so he is going to create
a stir just because of that, even though I meet the criteria that is so far proposed.
Just how much trouble can someone make for you?
LUKE:
Any land use application allows people to use their right to raise objections. Those
objections, though, have to be based on the ordinance; the person who does the
evaluation will decide if the use meets the criteria of the ordinance. So it will be
based on the law. If they raise objections that are violations of the ordinance, then
there's an opportunity for those to hold weight.
Minutes of Public Hearing Page 38 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
BJURK:
Okay.
CRAGHEAD:
There's also the issue of whether, say it's a type 1 use permitted outright, it would
be a matter of code enforcement, simply a matter of you receiving a notice of
violation from code enforcement. You would then come in and talk with code
enforcement staff.
I'm just saying, it's hypothetical really. But in my case, as a small contractor, I'm
looking at type 2 and thinking that's not a problem for me. But I'm just wondering,
because I went through this on a bed and breakfast conditional use permit starting
in 1988 which took until 1995, before any of you guys were here. But Tom
Throop was, and my neighbor was a friend of Mr. Throop.
DEWOLF:
And that didn't help.
It cost me thousands of dollars. We ended up winning our case because by that
time the ordinances were in effect for bed and breakfast inns. We're the people
who opened the can of worms on the use permits for this. But I'm saying, because
of this, even though we met all of the criteria after they were established, it still
took a long time and a lot of legal costs for us because one neighbor and one
Commissioner were friends, and it caused a lot of grief.
We ended up getting a letter of apology from the County with an approval, like a
month after Mr. Throop went to Wyoming. I don't want this to happen again, and
that's why I pose the question. I could foresee it happening, even though we met
all of the criteria, just how much grief can be caused if we meet the criteria of the
established ordinance.
DEWOLF:
They have the right in any land use decision to appeal. And they have to appeal
according to certain criteria. And if they appeal to this Board, then we have to
make a decision about whether we want to hear it. Let's say we don't. It could
potentially go to the Land Use Board of Appeals at the state.
Minutes of Public Hearing Page 39 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
There's no question that neighbors can cause neighbors a lot of grief, time and
money. But within the confines of the law, there's no question that if people think
that what you are going to do is something they don't want to see happening, they
have the right to appeal that.
BJURK:
I'm aware of that. I guess that's my question. Because I look at the type 2 and I
know that abiding by those rules, we would have no problem getting a conditional
use permit. We went to the Land Use Board of Appeals twice before, but there
were some mistakes made by the County and some legal counsel, so it took a lot
longer. Anyway, that's my concern. I think rules and regulations are good, and
these appear to be good. In my case especially, and that's what I'm concerned
about. I just wanted to pose that question. That's really all I had, thanks.
TINA LYONS:
I agree with everything everybody has said up to this point. I live on a half -acre in
La Pine. There's an electrical contractor on my street who runs a business, but he
goes off-site and just stores his equipment there and has small trucks. And I don't
find that a problem. My other neighbor wants to move from a hair salon in La Pine
where she does nails to her home. And she has done this before, and for some
reason she decided to move back downtown.
So she's been there for a couple of years, but now wants to move back home. It's
about sixteen cars a day. I bought, like everyone else in a rural area, for the
privacy. And I personally have a small business; I'm a massage therapist. I pay for
commercial space to do my business, and then I come home to the sanctuary of
rural residential. And I really firmly believe that commercial areas should be
commercial and residential areas should be residential.
LUKE:
How big a piece do you have?
LYONS:
We have two acres. The typical lot is a half -acre. So I was curious why this is
being looked at. I personally like the regulations the way they are because when
she wanted to open the nail salon next door to us, I told her she needed a
conditional use permit, and she came to the County and they told her she did. And
that stopped her, and that was good. But now we are enemies. And that's not
good.
Minutes of Public Hearing Page 40 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LUKE:
Damian, under the current rules, a hair salon would not be allowed?
SYRNYK:
Under the current rules, it could be. We look at these on a case-by-case basis.
Wei 114
On a half -acre, residential lot with sixteen trips a day.
SYRNYK:
Now, the sixteen trips a day I can't give you a firm answer on. A person could
apply, but we'd be looking at these on a case-by-case basis.
LYONS:
But if she does apply for it, and I do get notified, I have suggested that I would
complain to County code enforcement, you really take your life in your hands
sometimes if you do complain to the County. Which is unfortunate. That's to keep
people working together. I think the way the law is now is very restrictive and
makes everyone who wants a home business legally apply for a conditional use
permit. That's the proper way to do it.
DEWOLF:
I'm not sure that I agree with that. And I want to ask you about this. I don't think
that what we have now is very clear at all. Consequently, I don't think it's very
restrictive. I think that under the proposal I don't think your neighbor would be
able to fit into any one of the three types. I think under the current regulations, she
could. There's nothing regulating the number of trips in the current regulations, but
in this it certainly wouldn't work with a type 1. In type 2, she's limited to ten trips
per day; and type 3, she'd have to have twenty acres.
LYONS:
That's a point I was going to get to later. Let's talk about that now. If you look at
type 1, it doesn't say anything about the number of trips. It doesn't say anything
about the hours.
DEWOLF:
Five trips per day in type 1.
Minutes of Public Hearing Page 41 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LYONS:
Okay.
DAILY:
Are we talking about the electrical contractor now?
DEWOLF:
No, the nail lady.
LYONS:
I guess I stand corrected then. But it doesn't say anything about the hours of
operation. I just found the type 2 and type 3 are more restrictive than type 1.
DEWOLF:
Yes. They are. But there is a limit of five trips per day under type 1.
SYRNYK:
Let me go over the descriptions again. Under type 2, you can create up to ten trips
per day for employees or customers. You are limited to the hours of 8 a.m. to 5
p.m., Monday through Friday. Under type 3, you can create up to twenty trips per
day and the number of hours you work would be approved with the conditional use
permit. We would ask someone to make a proposal as part of the application
process, and we would notify the neighbors and solicit their comments, and see if it
would be compatible with the neighborhood.
LYONS:
I had that discussion with my neighbor about how it adversely affects me, and
that's what you have to do on the code enforcement complaint form. And the only
real leg I had to stand on was that it's not a rural use, it's a commercial use. She
said it's just like having my family come over, one every half-hour all day long. I
told her that if it's her family, they have that right, but this is not that.
So the type 1 doesn't have any inspections required? And they added on to a
1950's single -wide trailer that has a hitch. They added on twice, and didn't get a
building permit for it. And then they put their garage on County land with no
setback. And I had every opportunity to complain but I tried not to bother them.
was live and let live.
Minutes of Public Hearing Page 42 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LUKE:
Is it still on County land?
LYONS:
Yes.
DALY:
We own a garage.
LYONS:
Not a very nice garage. They put a washer and dryer in, and it goes into a dry well.
It's not hooked up to their septic. They added on a deck that right on top of the
septic tank. With no inspections being required for type 1, there's a lot of illegal
things in La Pine like that, that I think if you do go ahead with this, that's
something that should be addressed. That type 1 should have inspections. And the
hours of operation should be limited.
And parking is allowed on County roads; I talked with Gary Judd this morning.
He said you are supposed to leave two ten -foot wide lanes. So I guess if they can't
leave those lanes they can't park on County roads. But our road isn't that wide.
That brings me to another issue, which is --
DEWOLF:
If I'm a painter, and I paint at home and that's my home occupation, there are no
trips involved, how would anybody even know that I have a home occupation?
How would we as a County perform inspections? The point of having a type 1 is
to keep government out of the hair of people who are so minimally impacting their
neighbors. Say I write for a soap opera, and I use my computer and e-mail stuff
out. There are people who do this here. They certainly don't have an impact on
their neighbors unless their neighbors watch soap operas.
LYONS:
I do understand what you are saying. I agree with keeping government out.
However, I just think there are going to be situations where they will consider
themselves type 1, and then they have more trips than they should, and then the
neighbor --
Minutes of Public Hearing Page 43 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
You've nailed it right on the head. Then you want to complain about it, and what
you do is create an enemy for life. Here you've got somebody who's doing like six
different code violations, if all you said is accurate. All of them are bad, like
potential damage to the groundwater that we are trying so hard to protect down in
that area, that has nothing to do with the fact of whether they are a type 1 or not.
They still wouldn't be allowed to drain a washing machine into a sinkhole. They
wouldn't be allowed to put a deck over a septic tank.
LYONS:
I appreciate what you are saying. I don't want type 1, type 2 and type 3. I'd prefer
to keep it the way it is and/or clarify it. When Damian said these are permitted
outright, aren't those actually in the code?
SYRNYK:
they are in the code right now, but they are limited to unincorporated communities
like La Pine, Terrebonne and Tumalo, in residential districts, for example, where
we allow homes.
LYONS:
So that is the code now.
LUKE:
It's not allowed outside of those areas now.
LYONS:
So she can't right now, because of this.
DEWOLF:
Not if she is serving clients on site.
LYONS:
That is the most restrictive it can be. And to keep the rural residential areas rural,
that's the way to do it in my opinion. I think it is actually spelled out very well
because I already kind of fought it. And the way the conditional use permits are
now, it's hard to get and costs about $1,000, and a long process, so someone has to
be serious. That's what we want, someone who is going to abide by the law. But I
don't think they belong in rural areas.
Minutes of Public Hearing Page 44 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DALY:
Are we still talking about the lady who does nails? I think you are more concerned
about the other code violations.
DEWOLF:
Plus the sixteen trips per day that takes away her privacy, she says.
DALY:
What I hear is all of these other code violations are a lot worse.
LYONS:
No, I have not complained. Not formally to the County. They do bother me, but
not enough to make an enemy. I have dogs and sometimes my dogs will leave the
yard. And that's illegal. And I need a little forgiveness once in a while, too, and
I'm not perfect. I'm trying to get along, live and let live, and not turn them into the
County, although I've threatened. Which has stopped her form working at the
house, but it's not a pleasant situation.
LUKE:
You show a post office box here. What's your street?
LYONS:
We're on Barton Way, but the main road is Rim Drive. It's west of La Pine, across
the river, off Dorrance Meadow. There are so many small business people like her,
that if it is allowed to go into the rural areas, they will. And we'll lose some of the
economic development that we have in town. That's another issue.
Regarding the signs in type 2 and type 3, they are required to have a sign permit.
So does that mean they can be neon?
SYRNYK:
No. right now, what's proposed for signs is ground mounted or wall signs, and not
illuminated.
LYONS:
would the neighbors be notified first?
SYRNYK:
Not a type 1; but for type 2 and type 3. There's no signage allowed for a type 1.
Minutes of Public Hearing Page 45 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LYONS:
Why was this even addressed if there have only been 57 applications for the
conditional use permits have been applied for in the past ten years?
SYRNYK:
It was at the Board's direction, because of input from folks her participated in some
of the conditional use permits you've heard about tonight, like the well driller and
the landscaper.
DEWOLF:
We had so many neighbor to neighbor battles like this that were creating so much
turmoil that these rules didn't clarify enough so that people could agree on what
was allowed and not allowed. We wanted some clarification of this. I'm not
saying that this type 1, 2 and 3 gets where we thought we were going, but that's
what started this.
LYONS:
I almost didn't come tonight because it did seem like maybe it was a slam-dunk.
I'm glad you are considering this. I suggest that you have hearings in the various
outlying communities.
LUKE:
We actually do that a few times a year. We'll be down in May for a meeting.
LYONS:
I missed the notice I got in my taxes. I went to my file and there it was. I guess I
didn't pay attention. More people need to know about it; if they did know about it,
there would be more here. I think if they voted on it, they would vote against
businesses in rural residential areas.
LUKE:
Sending it with the tax bill made it affordable. It had to go to property owners all
over the County.
ELISE LOWE:
I live just on the outskirts of the Bend city limits, east, someday to be annexed in.
My lot is two and one-half acres. Just for some background, we're operating
illegally. We have one employee, which I didn't mention last time I was here.
Minutes of Public Hearing Page 46 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
However, we are moving to Sisters, and Sisters allows one employee. I'm going to
fess up now, because I'm telling you, right now, unless you want to be rural and
poor, if I lived next to any of these people, these code enforcement issues, my
money that I make in this town and pay taxes on would partially be spent on a
lawyer. They would be in court, and it would have never gone on this long.
We run an invisible business. We do virtually no client or customer stuff here.
We work nationwide, and have a seminar and education business that teaches
advanced massage therapy techniques and treatment routines to people around the
country. We also publish books, and have been published; we have a newsletter;
and we all do this out of our garage which, when we built our home, we added on.
We simply built into the attic of the garage. The house is completely permitted,
but we don't have a home occupation permit.
And the reason that we did this, and probably the reason why you've only had so
many permits requested in the last ten years, is because the gentleman back here
spent eight years. You don't have the money to enforce and you don't have the
money to get CUP's processed in an orderly time; so do we wait for years to do
this? Nobody even knows that we function. We're on two and one-half acres, but
quite honestly we could function on a small lot in downtown Bend, and nobody
would know.
That is something I'd like to talk about. I just wanted to let you to know that.
Because what we bring to this town -- what is happening to Central Oregon
unfortunately and fortunately in a lot of different ways is that we are moving from
a farm, agricultural environment or history to a young, rural, professional coming
into town. And gentlemen like this who have legitimate businesses, and twenty
years ago Joe the farmer next door with his trucks didn't bother anybody. Quite
frankly, he wouldn't bother me.
But we are in this transition period. I think some public meetings on this would be
really good. Because what you are getting, everybody who had a complaint
tonight had legitimate complaints, but they were code enforcement issues. There
hasn't been one complaint about these tonight that would have not met a code
enforcement issue here. But we don't have the money to do that.
Minutes of Public Hearing Page 47 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
Which brings me to my first issue. Basically when you are talking about home
businesses, what you are most concerned about, if you just put the water on and let
the silt regurgitate down to the bottom, you would have, what is the neighborhood
impact. Period. How are we impacting the people around us. Their values in the
property, their ability to enjoy their property, or sleep at night in some cases; that
goes down to everything.
The noise, dust, odor; there's a code, pretty clear. Maintaining neighborhood
appearance and values; controlling traffic and vehicle storage. If you just reduce
this whole thing down to that, and include a few extra things, you would have all
of the code enforcement rules you would need.
What we have here -- and I really want to applaud the people who put their time
and energy into this, because I'm not knocking it completely -- I'm just saying, it's
a lot. And when you start saying that you're going to do inspections, CUP's, how
many people want to pay more taxes? None of us do, right. So, let's get to
enforcement, then. Let's spend our money on enforcement.
One of the things that you can put in an enforcement code is language like this --
and I spent the last three months since we had the last meeting doing research on
the web, out of my home business -- studying what other counties and cities around
the country have done.
And here's some language. Reactive enforcement: responsibility of the
homeowners to bring offenders to the attention of the planning and zoning
department and homeowners' associations for determination enforcement. You
could do that anonymously; you don't have to be in a war with your neighbors.
DEWOLF AND LUKE:
Actually, you can't.
DEWOLF:
That's one of the problems.
LUKE:
They are anonymous in most cases until you have to go to court. Once you are in
court, it then becomes a public record.
Minutes of Public Hearing Page 48 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
It's not logical always, but it's the law. There are times when we do our best to try
to protect those relationships. I've actually filed complaints for people for the code
enforcement people to go check something out. Our code enforcement people, if
they drive by and see something that is obviously an unpermitted building, it's not
like they wouldn't react to that.
IIlE;i�i
If a building inspector is going down the road, and sees a building going up that he
knows is not permitted, he cannot enter that private property. Government
officials cannot enter private property without permission or a warrant.
DEWOLF:
He can still turn that over to code enforcement.
memo
Who still can't enter that property without permission.
LOWE:
Let me get down to some of the specific things I had. I think smoke, vibration and
heat need to be added to type 1-C. I did notice that in this one versus the one that I
took off the website did include that. So that may be redundant.
DALY:
Smoke, vibration and heat?
LOWE:
Who knows, somebody who does smeltering or something. That was on a lot of
the county codes that I saw around the country, believe it or not. Smoke for sure,
because if you have somebody who decides to do something and basically burning
every single day, that could be a problem.
And vibration may have taken care of the driving in and out, the traffic. If you
have a property where you are getting a ton of people coming and going, and
perhaps they meet all of the other type 1, 2 and 3 qualifications, but the noise
produced from that traffic is enough to be bothersome to the neighbors, then that is
a code violation. And vibration, because road noise produces vibration.
DALY:
You are saying that we ought to add all of this stuff?
Minutes of Public Hearing Page 49 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LOWE:
Vibration and heat and smoke, to the noise, odor, yeah.
DALY:
How do you measure those?
LOWE:
I don't know what you are asking me.
DALY:
Well, I mean, vibration that bothers you might not bother me at all.
LOWE:
How do you measure odor and noise?
DALY:
Same thing. How do you?
LUKE:
The City of Bend did that.
LOWE:
You know what, all of this is, I mean if you want to talk about that, then this is all
tossed out the window, because all of this is subjective.
DALY:
I mean, if you are going to put it in the code, then there ought to be some way to
measure it.
DEWOLF:
That's what she's saying. But how do you measure odor? We're not putting a
certain number of decibels for noise and we're not going to go buy a decibel meter.
LOWE:
I'm just suggesting these are other problems that someone could have a problem
with, and not be able to come back to the County on.
I think the acreage divisions between a lot and a half -acre are confusing. I don't
understand them. Somebody who is living on Reed Market Road on a half -acre
has --
Minutes of Public Hearing Page 50 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LUKE:
Reed Market is in the city.
LOWE:
Okay, a half -acre on Bear Creek Road. I mean, we have a lot of small subdivisions
going in on county land.
DALY:
Not any more.
LOWE:
Is that going to be limited? Is the County going to change the rules?
DALY:
We haven't done that for years.
LOWE:
You're not doing any half -acre or any lower than half -acre lots?
LUKE:
The County will not divide any more ground for subdivisions except La Pine and
unincorporated communities. All subdivisions outside of urban growth boundaries
have already been created.
LOWE:
Okay, then, what does type 1 refer to then?
SYRNYK:
Somebody working out of their home, and there's no minimum acreage.
LOWE:
So anybody can apply for that.
SYRNYK:
They wouldn't have to apply; it's an outright use.
Minutes of Public Hearing Page 51 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
If I want to be a painter and paint at home, and that's where I do my business, and I
don't generate any trips because I mail to a museum and do my business on line
and through the mail, I don't have to get anybody's permission.
DAILY:
It sounds like your business is a type 1.
LOWE:
We have an employee. This is something else that my husband is going to discuss,
the employee issue. Can somebody explain to me how an employee makes less of
an impact on the neighbors than a family member?
DEWOLF:
I can't. You've got one employee who shows up at 8 in the morning and leaves at
5. I mean, my kids used to come and go twelve times a day, with their friends. So,
I don't know.
LOWE:
But I could have an eighteen year-old playing rap music loudly in his car. When I
first made these comments, my employee could be my housekeeper, and be there
all day long, and maybe not answer my phones, but there's nothing limiting the
hours that person spends at my home, right? Or, if they were somebody
caretaking, because I had a physical disability. There would be no limits. So, are
these not employees?
SYRNYK:
As is proposed?
LOWE:
I mean, just in terms of what is an employee. I think that limiting type 1 to having
no employees, my biggest issue is that it is discriminatory. If there's a medical
reason that you haven't had children, you are going to be punished. And then you
are put in this CUP drama, permits for type 2. Personally I think it should be
completely deleted out of type 2.
Minutes of Public Hearing Page 52 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
If you want a CUP for ten or more acres so that this gentleman and other people
who have a business like that can function, then do that. But I think quite frankly
that you should merge type 2 and type 2. And then reduce the acreage size so that
this gentleman can operate legally, just like he was able to do fifty years ago. And
rely on basic codes, like does not produce odor, dust, glare, flashing lights or noise,
as your enforcement codes.
I'll submit this. There are numerous problems in type 1. I have 5 pages where I
have addressed this. (A copy of her written statement is attached as Exhibit B.)
LUKE:
If all code violations that we handle were based upon complaints -- if you
completely converted your house to some business and were not living there, and a
neighbor complained, there would be an inspection, with permission or a warrant.
Again, as we mentioned when we first started, there are people who obey the law.
If it's written down, they do their best to obey the law.
There are some people who simply do not obey the law, and then there are some
that try to go a little bit each way. So, you have to rely -- there aren't enough
police in the world -- most good citizens follow the rules as they are written.
LOWE:
Which makes me want to question numerous items in here.
DEWOLF:
You've got to wonder. The one employee, we're going to find example why this
doesn't work all over the place. I don't know why 25% of the dwelling is in type 1.
What do I care? If it's not an intrusion on the neighbors, and I'm a writer, and I
have a laptop and one day I feel most comfortable in my back yard, and the next
day I'm in my kitchen, then my office off my bedroom, and so on, what do I care
that my whole house is my space for the kind of work that I do. It doesn't intrude
on anybody. And what do I care if, as part of being that writer, I have a
proofreader, an employee, who comes to my house and works. How does that
impact anybody?
SYRNYK:
That's a valid question.
LOWE:
Minutes of Public Hearing Page 53 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
I think starting this diatribe with enforcement is what it all melts down to. Because
if we want to reduce bureaucracy and impact on people, what today has shown is
that the people who have complaints have legitimate, current complaints based on
the code today. And if we only added a few more little things, instead of making it
so complex, I think the vast majority of people, and in terms of your time and
certainly the people who work for the county, in terms of their time, it just seems
streamlining it would be a lot easier.
Regarding rural residential. There's no reason why this person should have to
move to a farm. I think we are seeing more and more smaller lots. Maybe there
isn't supposed to be a reduction of lot size, but we are seeing that all over the place.
And I think the next ten years we will lose some of our farm zoning to residential
rural land zoning.
LUKE:
Not unless there is a major change in the legislature. I was there, and I'll tell you
that that is one of the hardest things you can ever do.
LOWE:
It looks like it's on its way, though.
LUKE:
I wouldn't count on it.
LOWE:
Really. I don't know. It's pretty scary.
DALY:
Possibly we might get some kind of designation on this side of the mountains.
LOWE:
I'm not necessarily for that. But I think in a case like this, EFU --
LUKE:
He's a very good neighbor. He takes care of the road and does things for his
neighbors. But we've had a person who had a log truck. And that log truck
cranked up somewhere between 3:30 and 4:00 every single morning in a rural
residential area, and had to idle for a half-hour or more.
Minutes of Public Hearing Page 54 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
Now, my question is, why do you even have zoning if you let those kinds of things
happen. Why do you have a rural residential zone if you are going to allow
commercial uses there? And so we have to look at both sides of this. That is their
home. If they choose to live on a one -acre site instead of a little, dinky lot in the
city, where that stuff wouldn't happen, that's their choice. But they shouldn't be
subjected to commercial activity that is not regulated.
LOWE:
And I agree with that completely. I think if in the language of your definition of
home occupation, commercial uses such as that were more defined perhaps, but
also because we live in a rural area where land use values are extraordinarily high
right now, the reasonable expectation that somebody like this gentleman can go out
and rent space is ludicrous. He's already living in Terrebonne.
But, I think, again you go back to the meltdown. Noise, vibration, dust, odor, what
is the impact on the neighborhood? Certainly as a home occupation, we are
extremely sensitive to our neighbors. We're an advantage to our community, too,
because we care and we live there all day long, and we know who's coming and
going, and we're part of a little neighborhood watch. But I think by limiting the
EFU that type 3, is a problem. Because there is more and more acreage that isn't
EFU. That's all I have today.
SYRNYK:
Could I ask you a quick question? When you talk about type 3, is it the number of
employees?
LOWE:
Yes, thank you for adding that in. Because I'm with you. Who cares whether there
are five employees on EFU.
LUKE:
State law does.
LOWE:
Yeah, okay, up to five. Two to five, whether it's rural residential ten acre or EFU
ten acre. Limiting employees is limiting occupation allowance. If we didn't have
our employee, we wouldn't be renting space. We'd just cut back on our business.
We won't pay $120 a square foot. Thank you very much.
Minutes of Public Hearing Page 55 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
WHITNEY LOWE:
I live on Scottsdale Drive in Bend. Most have my issues have been addressed. I
just have a few short additions.
First of all, I think it's really good that that County is looking at trying to tighten up
some of these restrictions that are listed in here. That's because I think there are a
lot of special conditions because of the way this was brought from a number of the
cases that have happened in the past. I would like you to encourage you, however,
to not go overboard in attempting to make the regulations and guidelines here.
That's one of the things I see in the way that it is currently put together, and I think
we've heard a number of different examples in ways in which these proposed
changes may be very difficult to accurately interpret.
To give one other example, we heard tonight from a couple of people who gave
examples of businesses that would fall within in the type 1 category, who might be
a private person doing some kind of consulting activity, and perhaps having eight
people come to their house during an eight-hour work day, or something like that.
If they have a neighbor who doesn't get along with them and who is counting car
trips, and there is no other impact on what is going on, they are going to fall
outside that five -trip rule. That could become a serious problem.
I would encourage you to try to look at these things and see where you need to get
more specific with the regulations, and where also might you be getting too
specific with this. You should allow a proper degree of flexibility in this for
interpretation, for the wide variety of home occupations that we have here. That's
all that I have.
BILL KUHN:
I live in the Tumalo winter deer range, which is a forest zone, between Bend and
Sisters. I have been an investment adviser for thirty-three years. My type of
business is scrutinized by many different levels of government. I have operated
out of my home for thirty-three years.
I spoke with Community Development back when we were applying for our
landscape management plan. Both my wife and I spoke with CDD, where you
give your design of your house and all. And we specified that we both work out of
our house. And in our plans we clearly identified a portion of our house as office
space. We asked both Mark Shipman and Denise McGriff, who were the CDD
staff members at that time, if any permits were necessary to have a business out of
our home. We were told that there were none.
Minutes of Public Hearing Page 56 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
I do believe that the documents we received from Denise McGriff at that time did
say something about conditional use for home offices. But, as I said, nothing was
indicated to us as to what was required. We didn't have to apply for anything,
whatever.
LUKE:
May I ask you, Bill, do you have any employees?
KUHN:
I have had employees; I do not at the present time have employees.
LUKE:
Do you have customers coming to your residence?
KUHN:
I will be covering that. In 1997, in January, we began having difficulties with a
land partner. And one of our neighbors at that time suggested that I go back to the
County and again ask if there were any problems with my business. I cannot
afford to be doing something that is illegal. When I did ask at CDD in January
1997, I was gain assured that there were no issues regarding a home office.
Because my wife and I both work out of our home, we generally generate zero
business trips per day. The only reason we leave our property is to spend money,
to participate in various non-profit benefits to the County -- my wife is a SMART
reader and I have been involved in various non-profit organizations during my
many years in Bend -- and to, of course, attend public hearings.
I have received calls as late as midnight, and because the markets open roughly at
5 a.m., I sometimes get calls that early. We were operating our businesses before
there were any neighbors. In depositions regarding two civil cases that we have
been involved in with our land partners, our land partners had counter -claimed that
our businesses didn't have proper permits. When asked during the deposition
process what the objections were, they couldn't come up with any. Hence, those
particular counter -claims were dropped from there case.
We generate no lights, no signs, no smoke, no vibration, no noise, no heat, no odor.
As I said, we have had employees, but do not have employees at the present time.
I do have a contractual arrangement with a gentleman who lives in Missoula,
Montana. He does do work for me via electronic transfer of information.
Minutes of Public Hearing Page 57 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
Can I interrupt for just a second? There's a clarification that I'd like, Damian. That
brings up an interesting point. It says maximum number of employees, only
members of the family residing in the dwelling, under a type 1. If you've got an
employee in Missoula, Montana, who has zero impact, but is not a family member
residing in the dwelling.
KUHN:
Legally he's not an employee because he's on contract.
DEWOLF:
I'm just trying to raise this example. This is another issue that is a little unclear.
SYRNYK:
It is unclear. It raises a good question. I don't think it was intended to eliminate
someone from being allowed a type 1, even if they had a business partner who
worked off site. It's something to keep in mind.
KUHN:
My clients are located throughout the country. I have a total of roughly thirty-five
clients. During the seventeen years we've been in the Bend area, clients have come
to our house, our office, our residence. But these people have been my clients for
over twenty years. They are not just clients; they are friends. They stay at our
house. As I say, we generate zero business trips per day.
We very much appreciate the statements of Commissioner Luke, especially when
he said that there are people who abide by the law and respect their neighbors, and
there are people who don't. If there were some way to simply wave a wand, and
say, you're disrespecting your neighbor, shame on you, we would like that. We
would very much appreciate it.
During the course of time that we have been residents in the Tumalo winter deer
range, there have been numerous times when tenants in the structure next to us
have had semi -trucks in the driveway that they run, it seems like all night long.
This in the Tumalo winter deer range. Wildlife is supposed to be protected there. I
don't want to go into that now. Thank you. I appreciate the opportunity to speak.
DEWOLF:
I do have one question. Are you under the impression that currently you are at risk
of not operating legally, your business in your home, or that this may impact that?
Minutes of Public Hearing Page 58 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
KUHN:
I'm here to give testimony so that you will take into consideration what I'm saying.
Whether or not I'm at risk, I don't know. I believe that there needs to be some way
of respecting the neighborhood, of respecting neighbors. And I don't know how
else to do it. I would prefer to have fewer laws, fewer regulations. I would prefer
having neighborhood associations that could help deal with this type of situation.
If we all had neighborhood watches or neighborhood agreements, we probably
wouldn't need this kind of a law.
BRADLEY THOMAS:
I currently live in an RR -10 zone. I live on an acre of land. My problem is,
because right now I'm a type 1, a sole proprietor, no employees, everything is done
off-site. I move everybody in town. I do nothing on my site. The only trips that I
generate are when I leave and come home.
The discrimination that I feel is that if I'd like to have an employee, I would have
to go to type 2, apply for a conditional use permit, and that's probably fine. But
what's not allowed on type 2 is businesses that store or use vehicles or equipment
of a gross vehicle weight of greater than 10,000. I need you to clarify that for me.
DALY:
You have a moving truck?
THOMAS:
No, not yet. Let me just bring this to you. (At this time, he showed some photos of
trucks to the Commissioners.)
This is what they sell at Bob Thomas every day. It's 3500 crew cab pickup, dually.
It's going to weight more than 10,000 pounds. It weights 11,500. And I'm going to
be out of the box no matter if I drive a regular fleetside pickup with a one -ton
motor; if I go to the extended cab, it's 11,400. Same with the crew cab. If it's only
10,000 pounds, I'm toast. I can't operate, so therefore I can't work.
If a contractor puts any kind of equipment inside that truck, he's illegal. If I put my
butt in that truck, I'm illegal. Right now I've been working inside Deschutes River
Woods for eight years. We've never had any complaints generated by our
neighbors, and we've never had any problems.
Minutes of Public Hearing Page 59 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
Three years ago I constructed a building in my backyard so I could my vehicles
inside so they wouldn't have any visual impact on my neighbors. Now, because I
can only have a building that is so big, part of that isn't going to be able to be used
for putting my vehicles inside.
LUKE:
Currently you are a type 1.
DEWOLF:
But that gets back to this whole thing about having an employee; what does that
one or two or five matter. It's the kind of impact that they'd be having on their
neighbors. And if they are having none --
THOMAS:
The only impact I have on my neighbors is when they come to my house to ask me
to help them move a refrigerator or something. That is the only thing that I would
refer to as a negative comment, because I'd like to be home with my family versus
over there hiking a refrigerator into their house, for free. It's kind of hard to tell
your neighbors that you get paid for this.
LUKE:
What would you like to see done?
THOMAS:
I'd like you to allow a little bit fatter vehicles. Something a little more than 10,000
pounds. I think whoever investigated the vehicle weight did no investigation
whatsoever. Because any of the crew cab pickups that you have, if you have a
dually, you're in violation. If you have a single rear -wheel drive pickup, that's a
3505 if you put a lumber rack on it, you're in violation. If you put tools inside,
you're in violation.
I checked with each and every vehicle manufacturer here in town, Dodge, Chevy,
Ford, any of them. If you drive a one -ton, if it has dual rear wheels, you're in
violation of type 2 and 3. If I go to type 3, then I have to have twenty acres.
You're telling me that in order to have a vehicle that size I must have twenty acres.
It's all I could do to get the acre I live on now.
DALY:
I'd like to ask staff a question. Damian, the 10,000 pound weight limit, how did
that come about? Was it just arbitrary?
Minutes of Public Hearing Page 60 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
SYRNYK:
That's something we investigated with a standard in Clackamas County. I
understood that the goal was to prohibit big equipment in an area, such as a crane
or logging trucks.
DALY:
The pickup I drive is a Ford 350, and is probably over 10,000 pounds.
DEWOLF:
Especially when you're in it.
(Laughter.)
DALY:
Thanks, Tom.
DEWOLF:
You opened that door and walked right into it.
DALY:
I agree; the pickups have gotten much bigger.
THOMAS:
And the way the tax laws are written, the small businessman gets a discount if the
vehicle is over 6,500 pounds. That's the only way to get the big exclusion where
you can write off $18,000 or more the first year. So I think this is discriminatory
to guys like me who provide a service, who are picking up heavy stuff.
DEWOLF:
We'll fix it.
LUKE:
We appreciate you bringing this up.
DEWOLF:
And I think if you did a survey here, the size of vehicles has got to be triple the
average size of a vehicle in Clackamas County.
Minutes of Public Hearing Page 61 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
THOMAS:
We used to live on the west side. And the reason we moved to Deschutes River
Woods is partly because of the length of the driveway. My truck wouldn't back
into the driveway and make it to from the garage to the street without sticking out.
So we moved to an acre.
And to build exactly what I have in my back yard, on a commercial site here in
town, would cost me $212,000 just for the land, not counting the building, and
another $208,000 for the building. To do the same thing that I'm doing from my
house right now that isn't making an impact on anyone.
DALY:
Biggest mistake I ever made. I built my garage, and then I measured my truck.
That actually happened.
(Laughter.)
LUKE:
There's only one more person signed up to testify. I think Frank had one more
question, too.
ROBERT FISH:
First, I'd like to commend you on your integrity in the way this seems to be going
tonight. There has been a lot of testimony on specific instances, but we have to
look at this with a large view of everything. It would be really easy to
micromanage and try to fit every little instance into a code, but as you guys know,
we can't do that. We have to keep it pretty simple and so it allows people to use
their property that they own, that's part of their identity. Part of American is
actually owning property and being able to utilize it as we can.
DEWOLF:
What size lot do you live on? And what kind of property? Or is that even relevant?
FISH:
It's really not. I have a fairly good size lot. I've got an office and a small pickup
truck. I'm not doing this as a personal thing. We need to make sure people can
still utilize their property, and there are enough regulations and requirements
already, like landscape management, like height restrictions. Let us do what we
can. We can't live in a utopia where everything is happy and nobody is going to
affect me.
Minutes of Public Hearing Page 62 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
Just the other night I opened my window to sleep and there was smoke. I don't
know if it was from my neighbor's house or from controlled burns down south, but
I had to make a decision. Do I have the window open and live with the smoke, or
close the window? So, it was a choice. There are things that we have to do, and
we have to give a little bit sometimes. We can't all be happy all of the time. There
are going to be things that inconvenience us, there are going to be drivers who
don't use their turn signals, there's going to be people who don't start quick enough
from a stoplight.
But we can't regulate everything, and we've got to be able to allow us to do the
things that we can do on our properties. I'm sure there are things that go on in my
property in a normal day that could offend some people. I've got three boys, and
the youngest is five and is very active outside.
I guess I'm just trying to let my words be heard that as a property owner, we need
to have rights and freedoms and abilities to utilize our properties to a point to
where it is not limiting our potential for the American dream. Being an
entrepreneur, being an independent businessman, being able to pursue the dream of
someday having to move from my home business to a big business place because
my business is just too big now. That's about it for me.
LUKE:
Any thoughts on the ordinance, on how it could be improved or changed?
FISH:
I think it's too wordy. I think the whole goal was to -- I'm guessing at this -- clarify
some of the wording in the current ordinance. And it just kind of snowballed, and
got too complicated. We're unique here. We've got a mindset of people who have
lived here for a long time that it's mine, let me do what I want to do.
DEWOLF:
That's true, but all day long we hear from people like the folks earlier, where "let
me do what I want with my property" ends up with piles of differentials and
seventeen cars. And I'm getting telephone calls from someone who has a neighbor
who thinks he can shoot his rifle off at 5 a.m. There's got to be some balance here.
If you want to have washing machines in your backyard that don't work, yikes.
Minutes of Public Hearing Page 63 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
FISH:
You're right, the word balance. And I feel like the County is going pretty well
towards balance, especially with this meeting tonight. And just encourage that this
be in the forefront of everyone's minds, the balance. It would be really easy to go
overboard on the restrictions and regulations.
LUKE:
This proposed ordinance is actually easing regulations, allowing things that aren't
allowed now.
FRANK PENNOCK:
Should all of these things be ironed out to everybody's satisfaction, these rules and
regulations, would the people who are in total violation be required now to come in
and get a permit, and would the permit be denied until they clean up their act? It
probably still comes under code enforcement.
LUKE:
Absolutely. It would be a code enforcement issue.
PENNOCK:
Now would you put a closed sign on their door right now?
LUKE:
Not without a court order.
PENNOCK:
That would be my question, it might be the way to get rid of some of these
eighteen differentials piled up.
TINA LYONS:
The County road that we're on is privately maintained by the people who live on it.
Can you have commercial activity on a privately maintained road?
LUKE:
There are different types of roads. We have County -maintained roads, which are
typically asphalt. We have roads that are dedicated to the public inside
subdivisions, which are public roads but not necessarily maintained by the County.
And then there are private roads.
Minutes of Public Hearing Page 64 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
CRAGHEAD:
If it's a public road, there's no restriction on what can go across that road.
LYONS:
But is it fair to have commercial activity on a road that's privately maintained?
DEWOLF:
Fair isn't the issue.
DALY:
The road doesn't really matter. It's the zoning for the property.
DEWOLF:
There are lots of things that are legal that don't seem fair. I don't know if you are
familiar with the west side of Bend, out where the Mt. Bachelor parking lot is. The
Hearings Officer designed traffic control devices because neighbors were so vocal
about not wanting traffic down Columbia Avenue, they created this monster of a
thing out in the middle of the road so that people can't make a right turn out of the
parking lot. They still can, and I can't believe someone didn't appeal that. It makes
no sense, but it's there. It's not logical or fair, but it's legal.
LYONS:
Well, then, perhaps we should include road maintenance as a part of having
commercial activity.
LUKE:
If it's not type 1, if it requires additional use, sometimes that would be part of the
input on a conditional use.
LYONS:
The bigger the rig, the harder it is on the road. There are only five people on our
road who pay now.
DEWOLF:
Then you've got the guy with the seventeen -year-old son, spinning his wheels and
causing more problems than the guy with the heavy rig.
LYONS:
This can be a problem for the local residents, though.
Minutes of Public Hearing Page 65 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
BRYAN:
I have a comment more than a question, and maybe a request. And that is that
maybe you are aware, or maybe you don't want to be aware, of how many
businesses actually operate in the County that nobody knows about or cares about.
Most of them are pretty benign, and many of them provide a tremendous service to
the local community. I do want to suggest that you take those into consideration.
The impact on those businesses could be life-threatening for those folks.
DEWOLF:
I want to assure you that my interest is to watch out for unintended consequences
of what we do here. I respect the process that has taken place so far, and what the
Planning Commission has come up with. The three of us will argue and hassle and
yadda yadda and come up with something. That's why we get elected, and this is
where the buck stops.
When we pass something that people are upset about, they aren't going to call the
Planning Commissioners; they're calling us. So we do try to be very careful and
place close attention on how things impact folks, and try to anticipate for folks who
aren't here and the impact that it could have on them.
BRYAN:
I also noticed the other day when I here that with some of the questions you had for
the young lady who was sitting here, you folks actually take the time to read all
this stuff. Thank you.
ELISE LOWE:
Could it be a zoning permit instead of a CUP, maybe for type 2 and type 3?
SYRNYK:
That's a good question. I think this is something that the Planning Commission
considered for type 2, instead of going a gradation of permitted outright, CUP.
They might look at something that under our code is called a development action,
where essentially you fill out a form, if it's clear you meet all the criteria you get
your permit, and that's it. There's no public comment and no appeal. But there's a
record that you described your business operating a certain way.
Minutes of Public Hearing Page 66 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
I wondered, too, this sort of one size fits all deal. Is there some logic to looking at
different types within different zones. I mean, how different is EFU from RR -10?
I don't know.
SYRNYK:
That's why we're having the hearing; to try to get all of these questions on the
table.
DEWOLF:
Now that they are all here, how are we going to answer them, Damian?
SYRNYK:
That's also a good question.
(Laughter.)
LUKE:
The problem is that people currently have home and businesses by and large
weren't there when they bought them, and you're asking to change the code to
allow people to move in with a different type of activity than was there before.
And that's the dilemma we're facing.
Small business runs this county; there's no question about that. Less than ten
employees, it's a great base, and does a lot better during a recession usually than
larger businesses, and provide good jobs and good income. But you also have
people who have property rights of their own in the homes and neighborhoods. So
we have to weigh those things.
DALY:
On the reverse side of what he just said, we also have a lot of existing businesses
that are out there, and they could be illegal now and may be illegal when we pass
this. But at least this is an attempt for them to become legal, as long as they aren't
causing a big problem. My biggest fear is that we pass something that puts people
out of business. That's not what I want to see happen.
SYRNYK:
Is the hearing closed now, or is the record being left open?
Minutes of Public Hearing Page 67 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
LUKE:
We need to leave the record open in case somebody comes up with another
question or other ideas.
SYRNYK:
What would you like to do?
LUKE:
Has everybody signed up who wants to have things mailed to them, about meetings
or whatever? If you want to be notified of future meetings or decisions, please put
your name and mailing address on the sheet.
DEWOLF:
If anyone has suggestions, please, let us know. As you can tell, we are far from
convinced that what is presented here is what ought to be.
LUKE:
Testimony should come to Damian (Syrnyk); he's the maintainer of the record. He
will share e-mails or written testimony with the Commissioners.
SYRNYK:
Do you have a deadline of when you'd like comments in?
CRAGHEAD:
May I get a clarification? Are you continuing the hearing, or are you closing the
oral testimony but leaving the written record open?
LUKE:
I don't believe we are done.
DALY:
I don't either.
DEWOLF:
I kind of don't even think we're close.
LUKE:
I wouldn't mind continuing this. I'm not going to close the oral testimony, no.
iviinutes of rublic Heanng Page 68 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
CRAGHEAD:
Do you want to set a date certain for the next meeting?
LUKE:
We are meeting two weeks from Wednesday.
DEWOLF:
I'm just not sure about this. If we can get together in a couple of weeks and
consider any additional testimony, it may be that we want to maybe not go back to
the drawing board, but maybe modify things enough that we'd want to have
additional input on the next version. The difficulty is, since this is impacting so
much, we need to keep continuing this to a date certain so we avoid having to do
the full notice to every taxpayer or property owner in the County.
LUKE:
Right. Again, we have a list and there's some from the Planning Commission
meetings. When we're ready to put out something we have modified or worked on,
we could have another evening hearing like this, and allow people to see it before
we move on it. Even though we will meet two weeks from Wednesday, we'll
discuss it and it would come back out for a public hearing. You would be notified
before the adoption.
SYRNYK:
Let me ask a question about timeline. In two weeks, you'll be meeting the week of
May 5th, and I'll be on vacation that week.
DEWOLF:
What about May 12th, a Monday? The work session?
LUKE:
Two Commissioners might not be in town that day.
MORROW:
You can have a discussion without Damian being present. I can cover for him.
Since it's apparent that you will be having considerable discussion about this, you
don't have to adjust your scheduled around Damian's vacation.
Minutes of Public Hearing Page 69 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
CRAGHEAD:
Regarding your comment about noticing everyone, that's what has been called the
Measure 56 notice. I don't believe that it has to be done on a subsequent hearing
because it talks about needing to do it before the initial hearing, before the first
hearing of the ordinance, to do the broad mailing.
LUKE:
So mailing to the people who have signed up and participated is adequate?
DEWOLF:
How sure are you of that?
CRAGHEAD:
Right here in the statute, in ORS 215.5031, it talks about the notice needing to go to
twenty days but not more than forty days before the date of the first hearing on the
ordinance. The Planning Commission hearing would have been that.
LUKE:
If we close the written record for May 12th, and have a discussion on the 14th, will
that work?
DEWOLF:
That's fine. It kind of depends on what else ends up on our agenda. But my guess
is that at our next meeting what we are going to do is kind of see where we're at
and how we'd like to proceed.
LUKE:
Why don't we meet at 9:00 a.m. on May 14th, before the regular meeting, to discuss
what has come in. No decision would be made that day; it would be just a work
session.
DEWOLF:
It would be a work session for us to kind of gather what you all have put in. And
we'll decide at that point where we go from here. It won't be a matter of us
making a decision that day. That's a ways off.
LUKE:
The next meeting that the Commissioners will discuss this is 9:00 a.m. on May
14th. It will be a work session, and you can sit through it if you want.
Minutes of Public Hearing Page 70 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
DEWOLF:
Whoever signed up tonight or previously, when we establish another hearing date,
if that's what we do; we'll mail that out to you.
CRAGHEAD:
Since this is a legislative matter, ex parte contact is not a problem. You can
receive contact from the public at any time, on an individual basis.
LUKE:
We are requesting that letters come in by 5:00 p.m. on Wednesday, May 7, to
Damian, who will provide copies to the Commissioners. On Wednesday, May 14,
at 9:00 a.m. the Commissioners will have a work session to discuss what has come
in. We'll try to clarify things with staff and review what has been presented
already and what has come in.
SYRNYK:
And maybe at the work session you might be able to come up with a hearing date
so we can give notice.
LUKE:
That might happen, but it may also provide an opportunity for another work
session.
DEWOLF:
So we're continuing this right now until May whenever, right?
WIK"
No, we're closing the public hearing and leaving the written record open. We don't
have to renotice; we'll just mail to the people on the list.
CRAGHEAD:
And you'll just have another hearing.
LUKE:
At the advice of legal counsel, I'm going to close the public hearing and leave the
written record until May 7th at 5 p.m.
Minutes of Public Hearing Page 71 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
Being no further discussion or comments offered, Chair Luke adjourned the
meeting at 8:50 p.m.
DATED this 23rd Day of April 2003 for the Deschutes County Board of
Commissioners.
Dennis R. Luke, Chair
Tom DeWolf, er
4NM!i�fia-el
ATTEST: M. Daly, C issioner
Recording Secretary
Attachments:
Exhibit A: Frank Brian's written testimony
Exhibit B: Whitney and Elise Lowe's written testimony
Minutes of Public Hearing Page 72 of 72 Pages Wednesday, April 23, 2003
Proposed Changes to Code and Zoning re: Land Use Regulations for Home Business Occupations
FRANK BRIAN
21255 SW YOUNG AVENUE
BEND, OR 97701
(541) 389-4120
**Also Presented Orally at Hearing**
On April 23, 2003 at 5:30 P.M.
April 23, 2003
Deschutes County Board of Commissioners
1130 NW Harriman Street
Bend, OR 97701
Subject: Ordinance 2003-003, Proposed Changes to County Zoning regulations
on Home Occupations (File No. TA -02-12)
Re: Staff Report Dated April 16, 2003—Planning Commission Recommendation
to Board of County Commissioners
Gentlemen:
I commend you on your efforts to clarify a very murky situation in your desire to
consolidate 17 zoning districts into a single one -size -fits -all Home Occupation
Ordinance.
As you are well aware, our society generates wealth (money) via the means of
some occupation. Almost no wealth is produced through the harvesting of that
elusive natural resource—money trees. Everyone has to work somewhere in
order not to be a burden on society. By the application of their occupation, an
individual then contributes to society. Participation is through the exchange of
their wealth for the goods and services of another and the payment of taxes.
Our country was founded on a bedrock of freedom and the ability to profit from
one's own hard work.
This recommendation has many areas that need further clarification in order to
make this a successful cohesive ordinance that when adopted will help to bring
harmony to the community rather than being a divisive instrument.
This proposed ordinance still does not contain a definition of what a Home
Occupation is. How can citizens fully understand its impact without defining
who and what it applies to? How can the County enforce it?
• Is a home office a home occupation?
Page 1 of 4.
E_�v L6C t �
Exhibit f t
Page 1 0f yf
• Is an employee driving a work vehicle home a home occupation?
• Does advertising make it a home occupation?
• Does a business listing in the phone book make it a home occupation?
If the County already has criterion that it uses to define a home occupation,
please make that clear by including it in the ordinance itself.
The recommendation gives no analysis of the impact the proposed changes
will have on home occupations with an existing conditional use permit,
nor on the impact that it will have on existing business operations
within the County. Will these be grandfathered in? Does the County even
know how many home based occupations there are currently in the County and
under what circumstances they operate?
Also, this ordinance is proposed as 18.116.280 of the County Code. Chapter
18.116 is titled Supplementary Provisions. As it now stands, the public does
not know which parts of the existing ordinance will be combined with the
proposed changes to form the new regulation. This would probably be
inappropriate and would add to the public's perception of a misleading stealth
County government.
The following are a selected few of the obvious problems that are likely to affect
the most people.
Type 1
Item c of Type 1 of the recommendation states,"Does not produce odor,
dust, glare, flashing lights, or noise." Is thisa zero tolerance threshold?
How can you do an)9hing that does not produce air odor, dust, glare, flashing
lights or noise? Is a professional photographer taking flash pictures in violation
of the rules? Does this mean not at the property line?
Is it possible a home occupation that would cause consternation on a half -acre
parcel would be appropriate on a five -acre parcel?
For example, a sign painter or commercial artist may use paints that give off an
odor. On a five -acre parcel this would probably not be noticeable but on a half -
acre parcel may be cause for complaint.
Item a of Type 1 states that it will be "carried on within a dwelling". Why
would it matter whether it was conducted within a garage or an accessory
building if it had no impact on the neighbors?
This restriction seems intrusive on the owners' property rights. For example an
author who uses a computer to ply her craft elects to work in the sanctuary of an
accessory building so as not to be subject to the distractions of the normal
Page 2 of 4 Exhibit _ A
Page off= of
P ,
household. A professional artist paints using the natural sunlight in his backyard.
Or an accountant elects to put a computer in the corner of his garage. These
would not be allowed as a Type 1 under the current recommendation.
And didn't Bill Gates and Steve Jobs start out in their garage?
Type 2
Item h states that the operation of the home occupation will be "limited to
the hours of 8:00 a.m. to 5:00 p.m., Monday through Friday." A home
occupation most likely will offer goods or services to the local community. To
limit the hours of operation from 8 am to 5 pm, Monday through Friday renders
it almost useless to the local working community. It also makes it more difficult
for the fledgling entrepreneur who must work elsewhere as an employee to
pursue a start-up operation in her spare time. It would be more reasonable to
limit the hours from 7 am to 9 pm any day of the week.
Item n --iv., v., and vi. specifically exclude appliance repair, catering,
welding or machine shops from Type 2 home occupations. These appear to
be fairly innocuous home occupations. Why are they being excluded? The
Planning Department stated that it was excluded in another county that they had
studied. Is that sufficient reason to exclude them here in our county?
To specifically exclude any business from Type 2 without taking into
consideration the parcel size, the scope of business activity, or the placement of
the activity on property adds an unreasonable burden. It also limits its viability
by adding to the start up costs because most people will need an attorney in
order to not get bogged down in the morass of the Planning Department.
Type 3
Unless you are zoned EFU or in a Forest Zone, the maximum number of
employees you are allowed to have on site is two period, it doesn't
matter if you apply for a conditional use permit and hire an attorney. Many
successful businesses in America started out as home-based businesses. Two
employees is usually not enough to reach the critical mass required in order to
be able to afford the additional overhead of renting space elsewhere. The
number of employees should be higher or should be judged on a case by case
basis depending on the size of the parcel and where the activity is located on the
site.
I attended the November 14, 2002 Planning Commission hearing on this matter.
Notice of that hearing was sent out with last fall's property tax bills. There was a
good turnout for that hearing. At that hearing there was a sign-up sheet for
people who wished to be put on a mailing list to receive further information. I
put my name and address on the list as did many others.
Page 3 of 4
Exhibit A
Page 3 of
I falsely assumed that I would be notified so that I could be involved in the
process of forming these proposed regulations. Wrong assumption! The
Planning Commission had another hearing on January 9, 2003 and three
different work sessions on this matter! The only notice I did get from having nny
name on that list was notice of this hearing tonight.
To his credit, Damian Syrnyk, Senior Planner for the Deschutes County Planning
Division, has been very helpful in promptly returning phone calls and answering
my questions about the proposed ordinance.
However, to have your name on a list in order to be kept informed and then to
not be notified until it is almost a finalized regulation is misleading at best, and at
worst was intentional misdirection.
This staff report reflects the Planning Commission's outrageous bias and is an
excellent example of why the economy in Central Oregon is so bad. You would
think the County would be trying to generate new business activity to increase
revenue rather than adding to the burden of those currently employed. Be
advised, a raise in taxes affects all citizens not just the taxpayer.
Sincerely,
Frank Brian
Cc: The Bend Bulletin
Cc: Lars Larson
Page 4 of 4 Exhibit A
Page 4 of— q-
Whitney and Elise Lowe
21115 Scottsdale Dr.
Bend, OR 97701
Community Development Department
Deschutes County
117 NW Lafayette Ave.
Bend, OR 97701-1925
To whom It May Concern: 4/23/03
We appreciate your considering changes in the regulation of home occupations.
We have reviewed the proposed changes to the county code and are providing the
following comments.
First, we would like to acknowledge the thought and hard work that evidently went
into developing these proposed changes. We are impressed with the level of detail and
the ideas proposed. We do, however, have some concerns.
Thank you for considering these comments.
Whitney and Elise Lowe
Exhibit 3
Page /of �
Comments regarding the new Home Occupation zoning rules:
After much research and investigation, there appears to be three (3) primary concerns
regarding home occupations.
Those three basic concerns are:
1) Disturbance of neighbors
2) Maintaining neighborhood appearance and values
3) Controlling traffic
We find that these basic goals may be met simply without overburdening our
bureaucratic process and belaboring our county workers.
Simply put, we believe these new rules are just too much, too detailed, and verge on
micromanagement.
Enforcement of these rules will be impossible, costly, and time intensive. Who will go to
all these places? How many will wind up in our local courts?
We suggest the following:
1) Remove Section Type 2 and merge with Type 1. Eliminate acreage divisions. There is
no difference between a lot and a'/z to 5 acre property. Have one additional section for 20
plus acreas only.
2) ncrease employees to 1-3 and specify "equivalent of full-time". 7—
( f o2--
3) Add "smoke, vibration, and heat" to Type I. c
4) Delete 4 square footage requirement entirely from all sections. This is virtually
unenforceable and who really cares? Does this mean a painter who sells paintings should
only paint in one room? What is the point?
5) Delete CUP requirement . Again, what does this accomplish except
spending taxpayer money. Perhaps a zoning permit would be less burdensome.
6) Virtually all of the detailed itemized things would be addressed by simply making
rules based on the above 3 basic concerns.
7) Eliminate vehicle trip counts — again noise and disturbance rules would fix this.
8) Add an enforcement rule such as, "reactive enforcement, ... responsibility of the;
homeowners to bring offenders to the attention of the planning and zoning department or
homeowners association for determination and enforcement."
Exhibit 0 2
Page a of h
1. Type 1. a: Family only employees.
We strongly disagree with this limitation
1. Requiring only family members to work in a home occupation is
discriminatory. Those of us who for some reason, either medical or otherwise,
who do not have families are punished for not having children to work for us.
2. This rule contradicts other home employee uses, such as maids, house cleaners,
live-in caretakers, etc.
3. Appears to benefit no one. Who does this benefit? What possible harm could
come from, say 1 employee, versus a son or daughter performing home tasks?
4. Since this is the only code that allows a home business on less than a'/z to 20
plus acres, it does not benefit or work to encourage home occupations.
umerous county subdivisions are going in that are NOT '/z acre or larger.
at about these potential taxpayers and small businesses?
�ister's code allows non -family workers, the county should be even less strict.
7 Buying acreage will be out of the financial means of many pretty soon. Does
fie county want small internet, mail-order, real estate agents with assistants,
consultants with assistants, or other non -impactful businesses to only reside on '/2
acre or more.
.'eems less impactful than Type 1. b. section which allows up to 5 trips per day
o the site by clients or customers.
&Iow is an employee different from a family member in terms of the
occupation?
10. Why is having an employee on a small lot more of a disturbance than a family
member?
. Type.1 b: 5 trips per day to onsite servicing of clients o �t
-- Needs more clarification.
1. Are you saying clients may come to the home up to 5 times per day or that the
business owner should make trips from the home only 5 times per day?
2. Does this mean one can serve clients in the home?
- — "3
Exhibit 1
Page 3 of ((
2. Type 2. General Question:
Does CUP approval require neighborhood approval? If so we strongly disagree with
this whole section and the CUP requirement.
1. How many on the county board have completely friendly, gracious
relationships with their neighbors.
2. Requiring neighbors to approve home occupation approval sets up small
businesses for failure.
a. Some people would disagree with about anything, even if they never saw you.
Our current neighbors have shown themselves to be unfriendly to about anyone
around them. Getting their approval would be impossible for us. And I am certain
we are not alone.
Section needs to include similar language as 1. Type.1 c. "Does not produce odor,
dust, glare, flashing lights, or noise."
2. Type 2. a. '/z acre size requirement
We disagree with this limitation and believe it has little purpose.
1. What is the purpose of this rule?
2. What does it aim to prevent?
3. 1/2 acre properties, as well as larger acreages, are becoming hard to find and
expensive.
2. Type 2. c. 2 employees requirement
Needs clarification and purpose.
1. Are those 2 part-time or full-time employees?
2. If only 2 part-time employees, what is the harm in having a third'?
3. Why is having an employee on a 1/z acre lot less of a disturbance`'
Exhibit 13 4
Page of (o
2. Type 2. d. Floor area requirement.
This is confusing and contradicts Type 1. requirements.
1. Why should an attached garage not be included in floor area requirements in
Type 1. d, but IS included in this section.
2. Are you meaning to require that home occupation owners build accessory
buildings on their'/2 acre properties?
2. Type 2. e. 10 trips to site by customers
Please explain the purpose of this rule.
1. 10 trips per day from customers and employees seems like a lot.
2. A'/z acre parcel is still part of a neighborhood and if we lived next door to
someone who had people coming and going all day, we'd be upset.
2. Type 2. j. Materials or mechanical equipment and noise.
Needs to include "Does not produce odor, dust, glare, flashing lights, or noise."
1. What if the noise they produce is not from a material or machine? There is no
recourse for neighbors in this rule.
2. Type 2. n. Not allowed uses.
Please include dog kennels, animal hospitals, etc. here.
1. The notation in the introductory section says home occupations are not subject
to the CUP requirements of 18.128 which speaks specifically about dog kennels.
Exhibit B
Page of L
a
FA
3. Type 3. b. General comments.
We do not understand the purpose of this section or how it differs from Type 1 or 2.
(Except in its referral to 20 plus acreages and employees).
1. What are the size limitations for this CUP? The other sections have size
limitations, this one does not.
2. Preferential treatment to farms is apparently given. What about someone who
has 20 acres but not in the EFU Zone?
3. Needs to specify whom it would apply to.
3. Type 3. b. Employees.
We disagree with the limitation of 2 employees on property. Ditto above comments.
1. Why would a farm or EFU Zone be allowed 5 employees but another use, such
as a professional artist or mailing service also on 20 acres not be allowed 5
employees?
2. The county needs to be more progressive than this.
3. Type 3. c. 35% area
Why the difference?
3. Type 3. e. "nearby land uses"
This language is very confusing and extremely vague.
1. Who will decide? A court?
2. What or to whom does "disturbance" relate to?
Do you mean to say, "disturbance or inconvenience to nearby" neighbors?
Or, must the "disturbance or inconvenience" actually interfere with
another's USE of their property — a critical difference.
3. Does this mean anyone on large acreage can have a full blown business and
have as much traffic as they want?
4. Please define ""disturbance or inconvenience."
Exhibit r(3 6
Page CP of Co