2018-468-Minutes for Meeting October 15,2018 Recorded 11/2/2018`�vTES COG f
BOARD OF
E COMMISSIONERS
1300 NW Wall Street, Bend, Oregon
(541 ) 388-6570
' § <
10:00 AM
Recorded in Deschutes County ,1 0
Nancy Blankenship, County Clerk CJ2018-468
Commissioners, Journal 11/02/2018 3:49:37 PM
77r
2018-468
FOR RECORDING STAMP ONLY
Present were Commissioners Tammy Baney, Phil Henderson and Anthony DeBone. Also present were
Tom Anderson, County Administrator; Erik Kropp, Deputy County Administrator; David Doyle, County
Counsel; and Sharon Keith, Board Executive Assistant. Several citizens and representatives of the media
were in attendance.
This meeting was audio and video recorded and can be accessed at the Deschutes County
Meeting Portal website http://deschutescountyor.igm2.com/Citizens/Default.aspx
CALL TO ORDER: Chair DeBone called the meeting to order at 10:03 a.m.
PLEDGE OF ALLEGIANCE
CITIZEN INPUT: None was offered.
CONSENT AGENDA: Before the Board was Consideration of Approval of the
Consent Agenda. Commissioner Baney requested to pull the Consent Agenda
items for further review.
BOCC BUSINESS MEETING OCTOBER 15, 2018 PAGE 1 OF 3
Consent Agenda Items:
1. Approval of Minutes of the August 23, 2018 Special Business Meeting
2. Approval of Minutes of the August 27, 2018 Business Meeting
3. Approval of Minutes of the August 27, 2018 Work Session
4. Approval of Minutes of the August 28, 2018 Public Hearing
5. Approval of Minutes of the August 29, 2018 Business Meeting
6. Approval of Minutes of the August 29, 2018 Work Session
OTHER ITEMS:
Letter to Oregon State Historic Preservation Office:
Zechariah Heck, Community Development Department presented a letter for the
Board's consideration of their input on the Central Oregon Canal historic district
nomination for national register of historic places and the deadline is this
Wednesday. The nomination is for the Ward Road to Gosney Road segment of the
Central Oregon Canal.
BAN EY: Move to approve Board's signature
HENDERSON: Second
VOTE: BAN EY: Yes
HENDERSON: Yes
DEBONE: Chair votes yes. Motion Carried
ACTION ITEMS
7. DELIBERATIONS: Caldera Springs Expansion
Anthony Raguine, Community Development Department presented the item
and the decision matrix for the Board's consideration for deliberation. Adam
Smith, Assistant Legal Counsel presented history on the case. The Board
expressed their preferred method to proceed.
BOCC BUSINESS MEETING OCTOBER 15, 2018 PAGE 2 OF 3
RECESS: A short recess was taken at 10:39 a.m. to access additional materials
and the meeting was reconvened at 10:48 a.m.
Mr. Raguine presented an email communication from the applicant that staff
presented for the Board for consideration. Both parties are comfortable with all
testimony to be considered by the Board today.
The decision matrix was reviewed addressing the key issues with discussion and
decision points.
A draft decision will be presented to the Board for consideration based on the
discussion at today's deliberation.
Being no further items to come before the Board, the meeting was adjourned at 12:02 p.m.
DATED this Day ofoc)�L,2018 for the Deschutes County Board of
Commissioners.
ANTHONYE E® CHAIR
PHILIP G. 4NDERSON, VICE CHAIR
BOCC BUSINESS MEETING OCTOBER 15, 2018 PAGE 3 OF 3
01 E S COG
Deschutes County Board of Commissioners
1300 NW Wall St, Bend, OR 97703
(541) 388-6570 — www.deschutes.org
BUSINESS MEETING AGENDA
DESCHUTES COUNTY BOARD OF COMMISSIONERS
10:00 AM, MONDAY, OCTOBER 15, 2018
Barnes Sawyer Rooms - Deschutes Services Center - 1300 NW Wall Street - Bend
This meeting is open to the public. To watch it online, visit www.deschutes.org/meetings. Business Meetings are
usually streamed live online and video recorded.
Pursuant to ORS 192.640, this agenda includes a list of the main topics that are anticipated to be considered or
discussed. This notice does not limit the Board's ability to address other topics.
Meetings are subject to cancellation without notice.
CALL TO ORDER
PLEDGE OF ALLEGIANCE
CITIZEN INPUT
This is the time provided for individuals wishing to address the Board, at the Board's discretion, regarding issues
that are not already on the agenda. Please complete a sign-up card (provided), and give the card to the
Recording Secretary. Use the microphone and clearly state your name when the Board Chair calls on you to
speak. PLEASE NOTE. Citizen input regarding matters that are or have been the subject of a public hearing not
being conducted as a part of this meeting will NOT be included in the official record of that hearing.
If you offer or display to the Board any written documents, photographs or other printed matter as part of your
testimony during a public hearing, please be advised that staff is required to retain those documents as part of the
permanent record of that hearing.
CONSENT AGENDA
1. Approval of Minutes of the August 23, 2018 Special Business Meeting
2. Approval of Minutes of the August 27, 2018 Business Meeting
Board of Commissioners Business Meeting Agenda Monday, October 15, 2018 Page 1
of 2
3. Approval of Minutes of the August 27, 2018 Work Session
4. Approval of Minutes of the August 28, 2018 Public Hearing
5. Approval of Minutes of the August 29, 2018 Business Meeting
6. Approval of Minutes of the August 29, 2018 Work Session
ACTION ITEMS
7. DELIBERATIONS: Caldera Springs Expansion -Jacob Ripper, Senior Planner
OTHER ITEMS
These can be any items not included on the agenda that the Commissioners wish to discuss as part of
the meeting, pursuant to ORS 192.640.
At any time during the meeting, an executive session could be called to address issues relating to ORS
192.660(2)(e), real property negotiations ORS 192.660(2)(h), litigation; ORS 192.660(2)(d), labor
negotiations, ORS 192.660(2)(b), personnel issues, or other executive session categories.
Executive sessions are closed to the public, however, with few exceptions and under specific guidelines,
are open to the media.
ADJOURN
Deschutes County encourages persons with disabilities to participate in all programs and activities. To
request this information in an alternate format please call (541) 617-4747.
FUTURE MEETINGS:
Additional meeting dates available at www.deschutes.or /meetingcolendar
Meeting dates and times are subject to change. If you have question, please call (541) 388-6572.
Board of Commissioners Business Meeting Agenda Monday, October 15, 2018 Page 2
of 2
Deschutes County Board of Commissioners
1300 NW Wall St, Bend, OR 97703
(541) 388-6570 - Fax (541) 385-3202 - https://www.deschutes.org/
AGENDA REQUEST & STAFF REPORT
For Board of Commissioners Business Meeting of October 15, 2018
DATE: October 8, 2018
FROM: Jacob Ripper, Community Development, 541-385-1759
TITLE OF AGENDA ITEM:
DELIBERATIONS: Caldera Springs Expansion
RECOMMENDATION & ACTION REQUESTED:
Pursuant to LUBA and Court of Appeals decisions, the applicant, Pine Forest Development,
LLC, requested the Board of County Commissioners ("BoCC") consider the remand of the
proposed Caldera Springs Destination Resort Expansion. On remand, the BoCC must
determine whether the expansion area will be operated in a manner that is integral to the
existing resort, and whether the existing Caldera cabins qualify as overnight lodging units.
As part of the remand review, the Applicant proposes to modify the site layout of the
expansion area, including the relocation of the Wildlife Mitigation Tract, and the access at
Vandevert Road.
ATTENDANCE: Anthony Raguine, Senior Planner
MEMORANDUM
DATE: October 8, 2018
TO: Deschutes Board of County Commissioners ("BoCC")
FROM: Anthony Raguine, Senior Planner
RE: Deliberations - Caldera Springs Destination Resort (247 -15 -000464 -CU, 247-
18-000009-A)
Pine Forest Development, LLC ("Applicant") requests approval to expand the existing Caldera
Springs Destination Resort ("Resort"). As the BoCC is aware, this application is on remand
from the Land Use Board of Appeals ("LUBA") pursuant to LUBA and Court of Appeals
("Court") decisions which required the County to determine:
1. Will the expansion property be operated and situated in a manner that is integral to
the existing Resort?; and
2. Do the existing Caldera Springs "Lock Off' units qualify as "separate" units for
purposes of the overnight lodging unit ("OLU") definition?
To address the remand issues and the Applicant's desire to expand and relocate the Wildlife
Mitigation Tract ("Wildlife Tract"), the BoCC conducted a public hearing on August 29, 2018.
Written evidence and testimony was submitted into the record prior to the hearing, at the
hearing, and during the post -hearing open written record period. Said evidence and
testimony is detailed in the Exhibit list at the end of this memo.
PRELIMINARY PROCEDURAL ISSUE
In response to the LUBA remand, the Applicant requested the BoCC reopen the
record to allow the Applicant to submit new evidence regarding the LUBA remand
issues and relocation of the Wildlife Tract. Pursuant to BoCC Order ("Order") No.
2018-050, the BoCC agreed to reopen the record and limit new evidence to:
1. Whether the OLUs are "individual units;"
2. Whether the Caldera Springs annexation area will be operated in a manner
"integral" to the remainder of the resort; and
247 -15 -000464 -CU, 247-18-000009-A Page 1
3. The relocation of the Wildlife Tract within the Caldera Springs annexation area.
Subsequent to the Order, the applicant submitted supplemental application
materials. Included was a request to modify the Resort access onto Vandevert Road,
as discussed in greater detail below. This issue was not specifically opened for
consideration under the Order.
Similarly, as discussed in greater detail below, the Applicant argues that SROA has
impermissibly challenged the sewer and water analysis beyond the scope of DCC
22.34.040(C)'. Additionally, other issues beyond the scope of the Order were
addressed in either written comments or as testimony presented at the hearing.
BOCC DECISION
Staff believes evidence and testimony was received that is arguably beyond the scope
of the Order and DCC 22.34.040(C). The BoCC must determine whether and to what
extent to accept and consider said evidence and testimony. Staff believes it would be
prudent to accept and consider all evidence and testimony received to minimize
potential procedural error.
11. INTEGRAL TO THE RESORT
Pursuant to Deschutes County Code ("DCC") 18.113.025(B),
If the applicant chooses to support its proposal with any part of the existing
development, ��licant shall demonstrate that the proposed expansion will be
situated and managed in a manner that it will be integral to the remainder of the
resort. (emphasis added)
LUBA found that the Hearings Officer failed to make specific findings that the
expansion property will be situated and managed in a manner that that will be
integral to the remainder of the Resort. The Applicant proposes the following findings
to address this criterion.Z
The Annexation Area of Caldera Springs will be operated entirely in
conjunction with the operation of the existing resort. In fact, both areas will
comprise a single, unified resort, with existing and new amenities available
to residents and guests of the entire resort. A guest can elect to golf at the
existing Caldera Links and then recreate, eat or relax in the new resort core
area proposed for the Annexation Area. Similarly, guests and residents can
1 If additional testimony is required to comply with the remand, parties may raise new, unresolved
issues that relate to new evidence directed toward the issue on remand. Other issues that were
resolved by the LUBA appeal or that were not appealed shall be deemed to be waived and may not
be reopened.
z The Applicant refers to the expansion property as'Annexation Area' in their findings.
247 -15 -000464 -CU, 247-18-000009-A Page 2
utilize trails in both areas as a part of their experience. In terms of residents,
the Annexation Area will be subject to the same overall CC&Rs that currently
govern Caldera Springs. Residents too may elect to utilize recreational
features in both areas. Management of the visitor oriented
accommodations (e.g., pools, restaurants, meeting areas) will be handled
by the same management company. In many ways, the Annexation Area
and the existing resort are mirror images of each other, with the entire
resort operated as a single, unitary resort. Like Sunriver Resort, which has
facilities spread throughout the Sunriver community, Caldera Springs'
facilities are situated throughout the entire resort, but operated by one
entity. Given that the recreation facilities and Visitor Oriented
Accommodations will be located within a single resort area, with connecting
roads, paths and open space areas, the County can find that the resort is
"situated" in a manner that is integral to the remainder of the resort.
Similarly, given that the Annexation Area and the Visitor Oriented
Accommodations will be managed by the same entity and that the
residences will all be subject to the same CC&Rs, the County can find that
the Annexation Area will be "managed" in a manner that is integral to the
resort.
BOCC DECISION
The BoCC must determine if the expansion property will be situated and managed in
a manner that that will be integral to the remainder of the Resort.
Ill. OLUS AS'SEPARATELY RENTABLE UNITS'
Both LUBA and the Court held that for the County to determine that the existing OLUs
qualify as "separate rentable units" under ORS 197.435(5)(b)3, individually -owned
units "must be, as a factual matter, an accommodation that is both its own separate
unit that is rentable separately from other units." Staff addresses both prongs of the
LU BA/Court test below.
3 197.435 Definitions for ORS 197.435 to 197.467. As used in ORS 197.435 to 197.467:
(5) "Overnight lodgings" means:
(b) With respect to lands in eastern Oregon, as defined in ORS 321.805, permanent, separately
rentable accommodations that are not available for residential use, including hotel or motel rooms,
cabins and time-share units. Individually owned units may be considered overnight lodgings if they
are available for overnight rental use by the general public for at least 38 weeks per calendar year
through a central reservation system operated by the destination resort or by a real estate property
manager, as defined in ORS 696.010. Tent sites, recreational vehicle parks, manufactured dwellings,
dormitory rooms and similar accommodations do not qualify as overnight lodgings for the purpose
of this definition.
247 -15 -000464 -CU, 247-18-000009-A Page 3
Separate Unit
Currently, the 45 existing Caldera cabins include a total of 196 lock -off rooms. These
lock -off rooms were approved as the OLUs to meet the minimum requirement of 150
OLUs and the minimum 2.5:1 ratio of residential dwelling units to OLUs.
With respect to an OLU meeting the test as a'separate unit,' the Court explained that
it is a,
...factual determination of whether the rentable unit is actually a separate unit.
Further, we note that 'separate' means 'not shared with another. INDIVIDUAL,
SINGLEor'existingbyitself.AUTONOMOUS, INDEPENDENT. LUBA II, slip op 8.
Following the Court's decision, LUBA found that the existing OLUs do not meet the
test of 'separate unit.' Specifically, LUBA found that the Hearings Officer made no
factual determination that the separately rentable cabin lock -off rooms are actually
separate units rather than bedrooms in a single cabin. LUBA goes on to state,
The Court of Appeals, with the benefit of legislative history regarding the statutes,
was unwilling to go so for as to say the overnight rental 'units'..cannot be lock -off
rooms in a single-family vacation residence. We therefore are unwilling to adopt
that reading of the statues as well. Nevertheless, given the factors articulated by
the Court of Appeals and discussed above, we have difficulty imagining what
conditions or modifications might allow the individual cabin lock -off rooms, as
currently proposed, to qualify as the individual 'units' described in ORS
197.435(5)(b) and ORS 197.445(4). The only thing that is clear is that cabin
bedrooms that, are in theory separately rentable and happen to have their own
bathroom and lockable inside and outside entrances, but for which there is no
evidence have ever been rented separately from the other bedrooms in the cabin,
are not appropriately viewed as individual 'units.' Something more will be required
to ensure that they are in fact individual units.
In response, the applicant argues that the existing OLUs are separate units based on
the following additional evidence:
Separate key, room number and television for each unit;
• Separate entrances and keys allow the occupant of each unit to remain
separate from other guests in other units in the same structure;
Each unit is provided a parking space;
Each unit includes all the elements of a transient accommodation or a
"sleeping unit" as defined by the Oregon Structural Specialty Code (,,OSSC")4;
4 A room or space in which people sleep, which can also include permanent provisions for living,
eating, and either sanitation or kitchen facilities, but not both.
247 -15 -000464 -CU, 247-18-000009-A Page 4
For these reasons, the applicant argues each existing OLU is "not shared with
another" and "exists by itself' independent from other units in the same structure.
The applicant states there is no functional or practical difference between two
adjoining OLUs and two adjoining hotel rooms. The applicant notes that existing non -
Goal 8 resorts use lock -off units. In each instance, the applicant states, lock -off rooms
maybe rented separately or combined with the adjoining unit to meet a particular
guest's needs.
In opposition to the Applicant's rationale, the Sunriver Owners Association ("SROX)
reiterates the Court's holding that there is a difference between hotel/motel rooms
and the lock -off bedrooms. Specifically, the bedrooms in a single-family residence,
whether locked -off or not, are available for residential use and, therefore, cannot
qualify as OLUs. SROA also points out that the Applicant uses the same arguments
that have already been rejected by LUBA and the Court. For these reasons, SROA
argues it would be difficult to arrive at a different conclusion from LUBA and the
Court.
BOCC DECISION
The BoCC must determine, based on evidence in the record, if the existing lock -off
rooms in the Resort cabins are a 'separate unit' for the purposes of complying with
ORS 197.435(5)(b). If the BoCC determines the lock -off rooms qualify as separate
units, then the BoCC must determine whether said lock -off rooms are separately
rentable, as discussed below.
However, should the BoCC determine that the existing lock -off rooms do not qualify
as OLUs because they are not separate units, then the existing overnight
accommodations in the Resort cannot be used to meet the minimum 150-OLU
requirement for the expansion project. The BoCC can either deny the expansion
request or impose a condition of approval requiring the Applicant to ensure at least
150 OLUs within the Resort.
As noted above, the 45 existing Caldera cabins include 196 lock -off rooms. Should
the BoCC determine that these lock -off rooms do not qualify as OLUs, then each cabin
would be counted as an OLU rather than each lock -off room counted as an OLU. The
Applicant would be required to build an additional 105 OLUs within the expansion
area to reach the 150-OLU minimum (45 existing cabins as OLUs plus 105 additional
OLUs). This would be tied to an equal reduction in the total number of residential
units allowed in the expansion area. This reduction would allow the total number of
new units (residential and OLU) to remain consistent with the conclusions of the
traffic, sewer and water studies.
247 -15 -000464 -CU, 247-18-000009-A Page 5
Separately Rentable
LUBA found that there is no evidence that the existing OLUs have ever been rented
separately. To address this issue, the applicant included a spreadsheet identifying
instances where Caldera OLUs have been rented separately from each other. The
Applicant's burden of proof ("BoP") explains,
"Master Reservations" are instances where the entire Caldera cabin is rented
through a corporate, golf package, reunion or othergroup. The guests in the cabin,
however, [have] their own unique reservation number and charging privileges. For
example, if a large corporate group were to rent all 45 cabins as part of a group
retreat for 196 of its employees, the company would hold the master reservation,
but each employee would have their own unique reservation number, OLU, and
charging privileges associated with their unique suite. Similarly, in a family reunion
setting, one family member may reserve several cabins, but each family member
would have their own unique reservation number, their OLU accommodation and
charging privileges. Over the past 7 years, shared reservations have accounted for
an average of 15% of all stays, with a range of 4% to 30%. Whether a single guest
reserves all 196 OLUs or whether 196 separate guests book the OLUs, the some
number of guests can be accommodated in the existing Caldera Springs overnight
units.
Additionally, the applicant points out the Resort website allows individual OLUs to be
rented in any combination desired by a guest - whether it be a single unit or multiple
units. Further, the BoP includes an affidavit from Sunriver Resort which demonstrates
that the 196 OLUs managed by the Sunriver Resort are individually rentable through
the central reservation service established by Sunriver Resort for Caldera Springs.
BOCC DECISION
The BoCC must determine whether the existing OLUs at the Resort are separately
rentable.
Condition of Approval
If the BoCC finds the existing lock -off rooms in the Resort are both separate units and
are separately rentable, then these rooms qualify as OLUs and the applicant will meet
the required 150-OLU minimum for the expansion project. Understanding that a
BoCC finding that the existing lock -off rooms qualify as OLUs could be overturned on
appeal, the Applicant proposes the following condition of approval to assure the
Resort meets the 150-OLU minimum:
If the County's decision is appealed and an appellate body determines that the
existing overnight lodging units located in the 45 completed cabins at Caldera
Springs do not qualify as "separate rentable units" or an appellate body otherwise
247 -15 -000464 -CU, 247-18-000009-A Page 6
concludes that Caldera Springs includes less than 150 overnight lodging units, then
the applicant shall, as a part of its final master plan submission, increase the
number of overnight lodging units proposed in the expansion area by 105 units
(150 required OLUs minus 45 existing cabins = 105 additional overnight lodging
units), and decrease the number of single family units by a corresponding amount.
The county shall process the final master plan as a Type // administrative decision
with notice and an opportunity to appear and appeal the county's decision. As part
of the county's final master plan decision the county shall make specific findings
and impose any necessary conditions of approval to ensure that the final master
plan, as it may be amended, continues to meet DCC 18.113.025(B)(applicability to
existing resorts).
Should the Applicant be required to construct additional, non -lock -off, 01 -Us in the
expansion area, it is unclear to staff how, or if, this changes the sewer and water
analysis submitted by the Applicant. (see discussion below)
IV. SEWER AND WATER ANALYSIS
The relevant approval criteria regarding sewer and water are found under DCC
18.113.070, as follows:
K. Adequate water will be available for all proposed uses at the destination resort,
based upon the water study and a proposed water conservation plan. Water use
will not reduce the availability of water in the water impact areas identified in the
water study considering existing uses and potential development previously
approved in the affected area. Water sources shall not include any perched water
table. Water shall only betaken from the regional aquifer. Where a perched water
table is pierced to access the regional aquifer, the well must be sealed off from the
perched water table.
L. The wastewater disposal plan includes beneficial use to the maximum extent
practicable. Approval of the CMP shall be conditioned on applicant's making
application to DEQ for a Water Pollution Control Facility (WPCF) permit consistent
with such an approved wastewater disposal plan. Approval shall also be
conditioned upon applicant's compliance with applicable Oregon Administrative
Rules regarding beneficial use of waste water, as determined by DEQ. Applicant
shall receive approval of a WPCF permit consistent with this provision prior to
applying for approval for its Final Master Plan under DCC 18.113.
0. The resort will be served by an on site sewage system approved by DEQ and a water
system approved by the Oregon State Health Division except where connection to
an existing public sewer or water system is allowed by the County Comprehensive
Plan, such service will be provided to the resort.
With these criteria in mind, staff attempts to summarize the arguments on both sides
247 -15 -000464 -CU, 247-18-000009-A Page 7
SROA argues the Applicant's modification of the Conceptual Master Plan and updated
sewer and water analyses allow the BoCC to reconsider the adequacy of sewer and
water service to the expansion area. SROA further argues the evidence in the record
clearly shows that the existing sewer and water systems have acknowledged
deficiencies that call into question the ability of Sunriver Water and Sunriver
Environmental to provide adequate service to the expansion area, and the impact the
proposed expansion would have on water availability and sewer capacity for existing
users. For this reason, SROA argues that fire flows and sewer and water capacity must
be evaluated again. Additionally, SROA argues that the Applicant has not provided an
evidentiary basis for the 0.5 equivalent dwelling unit ("EDU") 5 ratio assigned to OLUs.
Further, because LUBA and the Court determined that the existing lock -off rooms do
not qualify as OLUs, the Applicant must address how the LUBA/Court finding affects
the EDU estimate.
To address these concerns, SROA recommends the following conditions of approval:
Documentation from an independent third -party professional engineering
firm demonstrating that the as -built system meets the existing and projected
[through build out of the plat phase] demand for Sunriver, Crosswater and
Caldera and the projected demand for the Resort expansion final plat phase,
or that system upgrades are planned as part of the final plat phase;
2. Documentation that the sewer system has completed upgrades required by
DEQ and any such upgrades are reflected in an as -built sewer and water
capacity study;
3. Any sewer and water system upgrades that are necessaryto meet existing and
projected [through build out of the plat phase) demand for Sunriver,
Crosswater and Caldera and the projected demand for the Resort expansion
final plat phase shall be financially assured, or require the Applicant to submit
proof of approval from the Oregon Public Utilities Commission to expand
Sunriver Water's service territory to include the expanded Resort; and
4. Documentation that the Applicant has obtained a water right from the Oregon
Water Resources Department, including any mitigation requirements, in an
amount necessary to meet the Resort expansion water supply demand.
The Applicant responds that DCC 22.23.040(C)6 limits the BoCC's consideration to
evidence and testimony directly related to new evidence submitted by the Applicant
5 For the purposes of estimating sewer and water demand, the sewer and water analysis assumes 1
EDU for each residential unit and 0.5 EDU for each OLU.
6 If additional testimony is required to comply with the remand, parties may raise new, unresolved
issues that relate to new evidence directed toward the issue on remand. Other issues that were
247 -15 -000464 -CU, 247-18-000009-A Page 8
on remand. The Applicant acknowledges that the updated sewer and water analyses
include one additional EDU. For this reason, the Applicant argues that SROA's
challenge should be limited to the evidentiary basis for the 0.5 EDU factor assigned
to OLUs and the impact of 1 additional OLU to the sewer and water system. The
Applicant points out that Parametria' assigns a 0.5 EDU factor for OLUs based on
historic water usage, which is directly related to wastewater production, and that
OLUs typically use less water than residential units due to eating out more often,
fewer dishes, and less frequent laundry.
The Applicant notes that the adequacy of sewer and water capacity was argued by
SROA in 2015, addressed by the Hearings Officer, and not remanded by LUBA. For
this reason, the Applicant argues SROA may not relitigate the entire sewer and water
analysis on remand.
With regard to SROA's request forthird-party sewer and water analyses, the Applicant
responds that there is no expert testimony to refute the conclusions reached by
Parametrix. Additionally, the Applicant objects to a condition of approval requiring
the Applicant to financially assure any upgrades by that must be constructed by
Sunriver Water or Sunriver Environmental.
While the Applicant generally disagrees with SROA's arguments, the Applicant
acknowledges SROA's concerns and proposes to address them with the following
conditions of approval:
1. Prior to recording the first final plat within the Caldera Springs expansion area,
the applicant shall submit a copy of the OPUC order or ruling approving the
expansion of Sunriver Water LLC's service territory to include the area
proposed to be platted. In no event shall the applicant be permitted to record
any final plat within the expansion area if the expansion area has not been
.included in Sunriver Water LLC's service territory.
2. The applicant shall be permitted to construct residential and overnight lodging
units in an amount not to exceed 100 EDUs (residential unit = 1 EDU; overnight
lodging unit = 0.5 EDU) prior to any upgrades to the current wastewater
treatment plant. The county shall not issue any certificates of occupancy for
any structure beyond 100 EDUs until the applicant has submitted evidence
that Sunriver Environmental has completed the treatment plant upgrades
identified in the September 18, 2018 email from DEQ and that DEQ has issued
an appropriate WPCF permit, amendment or supplement authorizing the
operation of upgraded wastewater treatment facilities serving the expansion
area.
resolved by the LUBA appeal or that were not appealed shall be deemed to be waived and my not be
reopened.
Reference Applicant's September 12, 2018 rebuttal testimony, which includes the September 12,
2018 Parametrix letter.
247 -15 -000464 -CU, 247-18-000009-A Page 9
BOCC DECISION
The BoCC must determine if the information is the record is sufficient to find that the
Applicant has met its burden of proof regarding DCC 18.113.070(L), (K) and (N), as
detailed above. If no, does the BoCC wish to impose conditions of approval to ensure
compliance?
Conditions of Approval
As noted above, both SROA and the Applicant propose conditions of approval to
address sewer and water availability and capacity. Staff recommends the following
conditions of approval:
1. Concurrent with each tentative plat application, the Applicant shall provide
proof of Oregon Public Utilities Commission approval of the expansion of the
Sunriver Water LLC service territory to include the land and uses subject to the
tentative plat application.
2. Concurrent with each tentative plat application, the Applicant shall provide
proof that Sunriver Environmental LLC has completed the necessary upgrades
and has capacity to serve the land and uses subject to the tentative plat
application.
V. VANDEVERT ROAD ACCESS
Pursuant to DCC 18.113.070(G) if the Resort expansion will significantly affect a
transportation facility, the decision maker must assure that the development is
consistent with the identified function, capacity and level of service of the facility.
Pursuant to the Hearings Officer's decision in land use file 247 -14 -000464 -CU, the
Resort access at Vandevert Road was conditioned to be limited to construction -
related traffic during development of the roads and infrastructure, then gated for
emergency -only access thereafter. This condition was added to address concerns
regarding vehicles attempting to proceed northbound on Highway 97 from Vandevert
Road. As a consequence of the condition, vehicles would be more likely to access
northbound Highway 97 from South Century Drive rather than Vandevert Road.
Included with the remand application materials is a request from the Applicant to
modify the Vandevert access to allow resident -only access, but restrict left -out
movements onto eastbound Vandevert Road. This, in turn, would reduce the number
of vehicles attempting to proceed northbound onto Highway 97 from Vandevert and
direct the bulk of the Resort traffic to South Century Drive. The revised 2018 Traffic
Impact Analysis ("TIA") concludes the Vandevert Road access modification would not
create significant impacts on the transportation system.
247 -15 -000464 -CU, 247-18-000009-A Page 10
SROA argues the conclusions of the 2018 revised TIA are not consistent with the 2015
TIA. Specifically, SROA notes that the 2015 TIA recommends site traffic be diverted
from the Vandevert/Highway 97 intersection until said intersection is closed. Further,
the 2015 TIA proposes three options to divert traffic from Vandevert/Highway 97.
One of these options was to limit access from the Resort onto Vandevert to
construction traffic only.' Additionally, SROA argues the 2018 TIA should have
analyzed the effect of the change in site layout on trip distribution.
The Applicant responds that the modified expansion proposal does not add any
additional trips beyond what was contemplated and reviewed in the original
application. The Applicant argues that the Hearings Officer's condition to limit access
onto Vandevert to construction and emergency access only is unwarranted. To
illustrate this point, the Applicant points out that the 2015 TIA includes an option to
restrict outbound left -turn movements from the Resort onto Vandevert as a
mitigation measure to reduce traffic at the Vandevert/Highway 97 intersection.
Further, the Applicant notes that in the Oregon Department of Transportation's
("ODOT") 2015 comments, they agreed with either restricting the ResortNandevert
access to construction and emergency only, or restricting left -out movements at the
ResortNandevert access. Finally, the Applicant states that the 2018 revised TIA
included a'sensitivity analysis' which routed 40% of trips through the Vandevert Road
access. The 2018 revised TIA concluded that even routing 40% of trips through
Vandevert, which is more trips than actually anticipated, there would be no change to
the findings and conclusions of the 2015 TIA.
Both the County Engineer and the Senior Transportation Planner agree with the
methodology and conclusions of the 2018 revised TIA. No comments were received
from ODOT.
BOCC DECISION
The proposed modification of the ResortNandevert access was not specifically
reopened per the BoCC's Order on remand. The BoCC must determine if this issue
can be addressed and whether the proposed modification will assure no significant
impacts to nearby transportation systems.
VI. SUNRIVER BUSINESS PARK
The record includes concerns regarding increased traffic within and adjacent to the
Sunriver Business Park. While the Applicant acknowledges there will be an increase
in traffic to the area, the Applicant points out that the 2018 revised TIA concludes that
intersections near the Sunriver Business Park will continue to operate consistent with
county transportation standards. Neither the County Engineer nor the Senior
8 Staff notes that the second option in the 2015 TIA was to restrict left -out movements at the
ResortNandevert access, similar to the current proposed modification.
247 -15 -000464 -CU, 247-18-000009-A Page 11
Transportation Planner identified any deficiency with regard to nearby Sunriver
Business Park intersections.
BOCC DECISION
Transportation impacts to nearby Sunriver Business Park intersections was not
specifically reopened per the BoCC's Order on remand. The BoCC must determine if
this issue can be addressed and whether the proposed expansion will result in any
significant impact to Sunriver Business Park intersections.
VII. CONSERVATION EASEMENT
Central Oregon Landwatch ("LandWatch") has requested that the County accept a
conservation easement over the Tract to both protect the tract and provide an
enforcement and monitoring mechanism for the Applicant's wildlife -related
commitments. The Applicant agrees to this condition of approval.
In the Hearings Officer's decision on 247 -15 -000464 -CU, this issue was raised by
LandWatch. The Hearings Officer concluded that a conservation easement is not
required under DCC 18.113.120.
BOCC DECISION
The BoCC must determine if it is appropriate to include a condition of approval
requiring a conservation easement for the Tract. If yes, staff recommends the
condition require the Applicant to submit the draft easement as part of the Final
Master Plan application package for review and approval by Planning and Legal
Counsel.
VIII. EXTERIOR SETBACKS
DCC 18.113.060(D)(2) requires a 250 -foot setback from property boundaries to OLUs.
The modified expansion map appears to allow OLUs within the required setback. The
Applicant agrees to a condition of approval prohibiting OLUs from being sited within
the 250 -foot setback.
BOCC DECISION
The BoCC must determine if a condition of approval is appropriate to ensure
compliance with the 250 -foot setback.
IX. WILDLIFE PASSGE PAYMENT
Oregon Department of Fish and Wildlife ("ODFW") submitted comments requesting a
onetime payment of $50,000 to be used by ODFW or other state agency to improve
247 -15 -000464 -CU, 247-18-000009-A Page 12
wildlife passage in the vicinity of the resort pursuant to the "no net loss or net
degradation of the resource" standard under DCC 18.113.07(D). The Applicant agrees
to this condition.
BOCC DECISION
The BoCC must determine if a condition of approval is appropriate to address the "no
net loss or net degradation" standard.
X. WILDLIFE FEEDING
Included with ODFW's comments was a request to prohibit feeding of wildlife in the
Tract, with the exception of songbirds. The Applicant agrees to this condition of
approval.
BOCC DECISION
The BoCC must determine if a condition of approval is appropriate.
XI. 120 -DAY CLOCK
Pursuant to ORS 197.860 and 215.435, the 120 -day clockfor final action by the County
on remand may be extended up to 365 days if the parties enter into mediation. Per
the applicant's burden of proof, the parties entered into mediation from December
17, 2017 to the submittal date of the supplemental application on July 11, 2018.
Therefore, the County calculates the first day of the 120 -day deadline beginning on
July 12, 2018. The date of the BoCC's deliberations, October 8, 2018, is day 94 of the
120 -day clock.
EXHIBITS
Evidence and testimony submitted prior to or at the public hearing'
A. Steven Hultberg email dated August 27, 2018 re: WA Zone setback
B. Steven Hultberg email dated August 27, 2018 re: wildlife passage payment
C. Steven Hultberg email dated August 27, 2018 re: wildlife feeding prohibition
D. Steven Hultberg email dated August 27, 2018 re: 250 -foot OLU setback
E. Ellen Grover email dated August 28, 2018 re: SROA concerns
F. Steven Hultberg email dated August 28, 2018 re: conservation easement
Post -hearing new evidence and testimony
G. Doug Westley email dated September 3, 2018 re: concerns
9 For the purposes of this memo, staff lists and attaches those comments not already addressed in
the Staff Report.
247 -15 -000464 -CU, 247-18-000009-A Page 13
H. Paul Dewey email dated September 8, 2018 re: conservation easement
I. Ellen Grover email dated September 12, 2018 re: SROA concerns
J. Steven Hultberg email dated September 12, 2018 re: Applicant responses
Post -hearing rebuttal evidence and testimony
K. Cody Smith email dated September 14, 2018 re: Road Department responses
L. Peter Russell email dated September 17, 2018 re: Transportation Planner
responses
M. Steven Hultberg email dated September 19, 2018 re: Applicant rebuttal
N. Steven Hultberg email dated September 19, 2018 re: SROA Board Minutes
Post -hearing Applicant final legal argument
O. Steven Hultberg email dated September 26, 2018 re: Applicant final legal
argument
Staff submittal
P. Decision Matrix
247 -15 -000464 -CU, 247-18-000009-A Page 14
Decision Matrix - Caldera Springs Expansion
Issue
Description
Opposition Comments
Applicant Comments
Discussion and Decision Points
The following issue areas are arguably beyond
Staff believes it would be prudent to accept and
the scope of the Order:
consider all evidence and testimony received to
BoCC Order 2018-050 limited the
1. Ability of sewer and water service to be
minimize potential procedural error.
remand review to the LUBA-
provided to the expansion area.
Should the BoCC accept and consider all
identified issues of'integral' and
evidence and testimony submitted to the
1. Scope
'OLUs', along with the relocation of
2. Traffic impacts in and around the Sunriver
I Modification of the ResortNandevertsccess is
record?
of
the Wildlife Mitigation Tract.
Business Park.
arguably beyond the scope of the Order.
Review
Certain evidence and testimony
1. If yes, then the BoCC can continue reviewing
submitted to the record is
3. Conservation easement for the Wildlife
the proposal.
arguably beyond the scope of the
Mitigation Tract.
Order.
2. If no, then BoCC must determine which
4. Feeding of wildlife in the Tract.
evidence and testimony to reject as outside
5. Onetime wildlife passage payment.
the scope of the Order.
Will the expansion area be situated and
DCC 18.113.025(B): "If the
managed in a manner that will be integral to the
Existing and new amenities will be available to
remainder of the Resort?
applicant chooses to support its
guests and residents of the entire resort.
proposal with any part of the
i
Expansion area will be governed by the same
1. If yes, then the BoCC can continue reviewing
existing development, applicant
overall CC&Rs that govern the existing Resort.
the expansion.
2. Integral to
shall demonstrate that the
None.
Management of visitor -oriented amenities and
Resort
proposed expansion will
accommodations will be handled by the same
2. If no, then the BoCC must either:
a
situated and managed in a
management company. Existing Resort and
manner that it will integral to
expansion area will be connected by roads,
a. Deny the expansion; or
the remainder of thea resort."
paths and open space areas.
(emphasis added)
b. Craft conditions of approval to ensure
compliance with this standard.
Issue
Description
Opposition Comments
Applicant Comments
Discussion and Decision Points
Each OLU has its own lockable entrance, key,
room number, television, and parking space.
Are the existing lock -off rooms in the Caldera
Each OLU meets the definition of 'sleeping unit'
Springs cabins separate units?
under the OSSC. No difference between 2
Pursuant to Court and LUBA
LUBA and the Court held that the Legislature
adjoining OLUs and 2 adjoining hotel rooms. If
1. If yes, then the Board can continue reviewing
decisions, OLUs must be separate
made a policy decision that because individual
a hotel room qualifies under the statutes as a
the proposal.
units. Per the Court, this is a
rooms (lock -offs) in a cabin or dwelling are
separate rentable unit, then the existing
3. Existing
factual determination. Further,
available for residential use, they are not the
Caldera OLUs are also separate rentable units.
2. If no, then the Board must either:
OLUs as
'separate' means not shared with
same as hotel or motel rooms. The applicant
Separate
another, or existing by itself. LUBA
,
offers the same arguments that have already
Should the BoCC determine the existing OLUs
a. Deny the expansion; or
Units
ruled bedrooms that are, in
been rejected by LUBA and the Court. For these
are not separate units, or if an affirmative
theory, separately rentable and
reasons, the existing Caldera cabins are not
decision by the BoCC is overturned on appeal,
b. Include a condition of approval to ensure
have their own bathroom and
separate units.
the Applicant recommends a condition of
compliance with the 150-OLU minimum
lockable entrance are not
approval requiring the Applicant to construct
and compliance with the single-family
individual units.
an additional 105 non -lock -off OLUs in the
dwelling unit to OLU ratio. (The Applicant
expansion area. This would be accompanied by
proposes a 2.3:1 ratio where a maximum
an equal reduction in residential units in the
ratio of 2.5:1 is allowed.)
expansion area.
Are the existing individual lock -off rooms
Master Reservations include rental of the
separately rentable?
entire cabin or cabins. In these cases, guests in
1. If yes, then the Board can continue
lock -off rooms have their own reservation
reviewing the proposal.
4. Existing
number and charging privileges. In this sense,
OLUs are
LUBA found that there is no
evidence that the existing OLUs
None.
each lock -off room is separately rentable. Over
2. If no, then the Board must either:
Separately
have ever been rented separately.
the past 7 years, these types of shared
Rentable
reservations accounted for an average of 15%
a. Deny the expansion; or
of all stays. Additionally, the Resort website
allows individual OLUs to be rented in any
b. Include a condition of approval to ensure
combination by a guest.
the individual lock -off rooms are available
to be separately rented.
Issue
Description
Opposition Comments
Applicant Comments
Discussion and Decision Points
Applicant's updated sewer and water analyses
SROA's challenge should be limited to the
allow BoCC to reconsider the adequacy of
evidentiary basis for the 0.5 EDU factor
The Hearings Officer ruled that
sewer and water service to the expansion area.
assigned to OLUs and the impact of 1
sewer and water service can be
Evidence in the record clearly shows that the
additional OLU to the sewer and water system.
Is the Hearings Officer's condition of approval
available to the expansion area. A
existing sewer and water systems have
Parametrix provided a rationale for the 0.5
requiring the Applicant to submit signed sewer
condition of approval required the
acknowledged deficiencies. Fire flows and
EDU factor assigned to OLUs. No expert
and water agreements sufficient to ensure
Applicant to submit signed sewer
sewer and water capacity must be evaluated
testimony to refute the conclusions reached by
connection to a public sewer system and
and water agreements as part of
again. No evidentiary basis for the 0.5 EDU
Parametrix.
adequate provision of water service?
Final Master Plan review.
ratio assigned to OLUs. Because LUBA and the
SROA may not relitigate the entire sewer and
4. Sewer and
Should the BoCC determine
Court determined that the existing lock -off
water analysis on remand because this issue
1. If yes, then the BoCC can continue its review.
Water
Analysis
additional information is
rooms do not qualify as OLUs, the Applicant
must address how the LUBA/Court finding
was not remanded by LUBA.
2. If no, then the BoCC must either:
necessary to ensure adequate
sewer and water capacity, staff
affects the EDU estimate.
Applicant objects to a condition of approval
a. Deny the expansion; or
recommends conditions of
SROA recommends conditions of approval
requiring the Applicant to financially assure any
approval requiring the Applicant
requiring the Applicant to submit third -party
upgrades by that must be constructed by
b. Include conditions of approval to ensure
to submit information on sewer
analysis of as -built sewer and water systems;
Sunriver Water or Sunriver Environmental.
connection to a public sewer system and
and water system capacity
updates as part of each tentative
documentation of completed sewer upgrades
Applicant recommends conditions of approval
adequate provision of water.
plat application.
required by DEQ; proof of OPUC approval of
related to OPUC approval of water service
water service territory expansion; and
territory expansion and limiting the initial
documentation of water rights.
phase to 100 EDUs to address sewer capacity.
Does the BoCC agree with the Applicant that
the proposed modifications at the
Applicant modification to allow resident access.
Resort/Vandevert access will have no
The Hearings Officer included a
The Hearings Officer's condition of approval
significant impacts on the transportation
condition of approval limiting
limiting access to construction and emergency
system?
traffic at the
SROA argues the 2015 TIA recommends traffic
only is not warranted. 2015 TIA included a
tion a
o construction
Road access to construction and
be diverted from the Vandevert/Highway 97
mitigation option to restrict left -out
1. If yes, then the BoCC can continue its review.
5. t
emergency vehicle only.
intersection. The 2015 TIA included three
movements.
Road Access
Road Access
options to divert traffic, one of which was to
2. If no, then the BoCC must either:
County Road Department and
limit access to construction only.
The modified access would restrict left -out
Senior Transportation Planner
movements. The 2018 revised TIA finds this
a. Deny the expansion; or
agree with 2018 revised TIA
modification would not have any significant
methodology and conclusions.
impact to existing transportation systems.
b. Include a condition of approval to ensure
no significant impact to transportation
facilites.
Issue
Description
Opposition Comments
Applicant Comments
Discussion and Decision Points
Does the BoCC agree with the Applicant that
the proposed expansion will have no significant
The proposed expansion will
impact on transportation facilities in and
increase traffic in the area,
around the Sunriver Business Park?
including within and around the
6. Sunriver
Sunriver Business Park.
Concerns were expressed regarding the impact
The 2018 revised TIA concludes that
1. If yes, then the BoCC can continue its review.
Business
of additional traffic from the expansion on
intersections near the Sunriver Business Park
Park Traffic
Neither the County Engineer nor
roadways in and around the Sunriver Business
will continue to operate consistent with county
2. If no, then the BoCC must either:
Impacts
the Senior Transportation Planner
park.
transportation standards.
identified any deficiency with
a. Deny the expansion; or
regard to nearby Sunriver
Business Park intersections as a
b. Include a condition of approval to ensure
result of the expansion.
no significant impact to transportation
facilities.
The Hearings Officer ruled that a
conservation easement is not
required pursuant to DCC
18.113.120 because the expansion
Is it appropriate to include a condition of
area is not within the Deer
LandWatch requests a condition of approval
approval requiring a conservation easement
Migration Priority Area.
g y
requiring the Applicant to record a
for the Wildlife Mitigation Tract?
7. Conservation
conservation easement over the Wildlife
Applicant agrees to a condition of approval
Easement
Should the BoCC include a
Mitigation Tract to both protect the Tract and
requiring the conservation easement.
q g
1. If es, then include a condition of approval.
y pp
condition of approval requiring
provide an enforcement and monitoring
the easement, staff recommends
mechanism for the Applicant's wildlife -related
2. If no, then affirm the Hearings Officer's
the condition requiring the
commitments.
finding.
Applicant to submit a draft
easement as part of Final Master
Plan for review by Planning and
Legal
Issue
Description
Opposition Comments
Applicant Comments
Discussion and Decision Points
Should a condition of approval be included to
DCC 18.113.060(D)(2) requires a
require 01-Us to comply with the 250-foot
250-foot setback from 01-Us to
exterior property line setback?
8. Exterior
exterior property lines. The
Applicant agrees to a condition of approval to
Setbacks
modified Conceptual Master Plan
None.
ensure compliance with the 250-foot setback.
1. If yes, then include a condition of approval.
map shows the potential to site
01-Us inside of this setback.
2. In no, then do not include a condition of
approval.
ODFW requests a condition of
Should a condition of approval be included to
approval for a onetime payment
require a onetime wildlife passage payment to
of $50,000 to be used by ODFW or
ODFW?
9. Wildlife
other state agency to improve
Applicant agrees to a condition of approval to
Passage
wildlife passage in the vicinity of
None.
require the onetime payment.
1. If yes, then include a condition of approval.
Payment
the resort pursuant to the "no net
loss or net degradation of the
2. In no, then do not include a condition of
resource" standard under DCC
approval.
18.113.07(D).
Should a condition of approval be included to
prohibit feeding of wildlife in the Tract, with the
ODFW requests a condition of
exception of songbirds?
10.Wildlife
approval to prohibit feeding of
Applicant agrees to a condition of approval
Feeding
wildlife in the Wildlife Mitigation
None.
restricting feeding of wildlife in the Tract.
1. If yes, then include a condition of approval.
Tract, with the exception of
songbirds.
2. In no, then do not include a condition of
approval.
Adam Smith
From:
Anthony Raguine
Sent:
Thursday, October 4, 2018 12:58 PM
To:
'Steven Hultberg'
Cc:
Adam Smith
Subject:
RE: Caldera Remand
That sounds like a good solution, and one that I'm much more comfortable with.
Anthony Raguine I Senior Planner
Deschutes County Cog's mun�ty Deve9opment
117 NW Lafayette Ave I Bend, Oregon 97703
Tel: (541) 617-4739
KJOB
Let us know how we're doing: Customer Feedback Survey
From: Steven Hultberg
Sent: Thursday, October 4, 2018 12:33 PM
To: Anthony Raguine
Cc: Adam Smith
Subject: Caldera Remand
Anthony,
After speaking with Adam, I propose the following: That the staff memo explain to the Board that there were two
general areas where the issues and evidence may have exceeded the scope of the board's order re -opening the record,
the Vandevert access and the SROA's challenges to the sewer and water systems. Under DCC 22.34.040(A) the "Board
shall have the discretion to reopen the record in instances which it deems to be appropriate." Here, because both the
applicant and the opponents have raised issues that arguably fall outside the scope of the Board's order and both have
submitted evidence to the record in support of their arguments, it would be most appropriate for the Board to use its
discretion under DCC 22.34.040(A) to reopen the record to allow for submission of the evidence and testimony currently
in the record. This does not mean that the board is technically "reopening" the record at this point. It is merely a
reflection by the Board that materials currently in the record and the related testimony will be considered by the Board
and are properly part of the record.
Does that make sense?
Regards,
Steve
Steven P. Hultberg
PO Box 2007
Bend, Oregon 97709
P 541.585.3697 C 541.420.1024
E shultberg(aradlerwhite.com