Loading...
2018-496-Minutes for Meeting November 05,2018 Recorded 12/6/2018• BOARD OF COMMISSIONERS 1300 NW Wall Street, Bend, Oregon (541 ) 388-6570 1:30 PM Recorded in Deschutes County Nancy Blankenship, County Clerk Commissioners' Journal � 201$-496 CJ2018-496 12/06/2018 4:29:52 PM FOR RECORDING STAMP ONLY MONDAY, November 5, 2018 ALLEN CONFERENCE ROOM Present were Commissioners Phil Henderson and Anthony DeBone. Commissioner Tammy Baney was absent, excused. 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 no identified representatives of the media were in attendance. CALL TO ORDER: Chair DeBone called the meeting to order at 1:30 p.m. ACTION ITEMS 1. Consideration of Board Signature of Order No. 2018-068, Reopen Public Hearing Record Matt Martin, Community Development Department presented the Order for consideration. This Order is relative to reopening the public hearing record to allow tolling of the clock on the Diamond Forge land use application for marijuana production. Commissioner Henderson recommended a single language change to the Order. Mr. Martin will make recommended edit. HENDERSON: Move approval as amended DEBONE: Second BOCC WORK SESSION . NOVEMBER 5, 2018 PAGE 1 OF 4 VOTE: HENDERSON: Yes BAN EY: Absent, excused DEBONE: Chair votes yes. Motion Carried 2. Discussion: Record Materials for High Desert Nectar LLC Jacob Ripper, Community Development Department presented this item. This item was audio recorded. Mr. Ripper reviewed items from the record that were requested for further information. Nick Lelack, Community Development Director and Peter Gutowsky, Planning Manager were present for the discussion involving the definition and parameters of "Youth Activity Centers." 3. Historic ADU Amendments - HB 3012 Tanya Saltzman, Community Development Department presented the item for discussion. House Bill 3012 permits counties to allow a historic home located in a rural residential exception area to add an accessory dwelling unit to be constructed on the same lot or parcel. Commissioner DeBone expressed his interest to proceed. Peter Gutowsky, Planning Manager explained the Planning Commission would also need to review. Commissioner Henderson spoke on items that have been recently appealed. Nick Lelack, Community Development Department spoke on consistency with state law asked the Board if they want to send it the Planning Commission to review. Commissioner DeBone suggested sending this to Planning Commission for their review. Commissioner Henderson would rather have a joint meeting with the Planning Commission instead and would like to wait to see what happens in the next legislative session. Commissioner DeBone would be interested in a public hearing at the Planning Commission level to see what level of public input exists. Mr. Lelack reported the Planning Commission had also expressed interest in a joint BOCC WORK SESSION NOVEMBER 5, 2018 PAGE 2 OF 4 meeting in 2019. After that meeting, consideration of initiating text amendments will be revisited. 4. Potential Appeal of a Hearings Officer Decision for a Farm -Related Dwelling in the Exclusive Farm Use Zone Isabella Liu, Community Development Department presented the item for discussion. Ms. Liu explained the information on the subject property. The application was approved administratively, appealed by Central Oregon LanclWatch, and denied by the Hearings Officer. Commissioner Henderson stated unless there is a clear precedent he doesn't feel the Board should hear it but the appeal go to LUBA. The Board is not inclined to hear the .R Move to decline having the Board hear the appeal should one be filed. HENDERSON: Move approval of Order declining the hearing. DEBONE: Second VOTE: HENDERSON: Yes BAN EY: Absent, excused DEBONE: Chair votes yes. Motion Carried OTHER ITEMS: None COMMISSIONER UPDATES: None were reported BOCC WORK SESSION NOVEMBER 5, 2018 PAGE 3 OF 4 EXECUTIVE SESSION: At the time of 2:42 p.m., the Board met in Executive Session under ORS 192.660 (2) (h) Litigation. The Board came out of Executive Session at 2:50 p.m. Being no further items to come before the Board, the meeting was adjourned at 2:50 p.m. DATED this 5 Day of 2018 for the Deschutes County Board of Commissioners. alzl-21--"-�- BOCC WORK SESSION NOVEMBER 5, 2018 PAGE 4 OF 4 WORK SESSION AGENDA DESCHUTES COUNTY BOARD OF COMMISSIONERS 1:30 PM, MONDAY, NOVEMBER 5, 2018 Allen Conference Room - Deschutes Services Building, 2ND Floor - 1300 NW Wall Street - Bend Work Session, which are open to the public, allow the Board to gather information and give direction to staff. Public comment is not normally accepted. Written minutes are taken for the record 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 ACTION ITEMS 1. Consideration of Board Signature of Order No. 2018-068, Reopen Public Hearing Record - Matthew Martin, Associate Planner 2. Discussion: Record Materials for High Desert Nectar LLC -Jacob Ripper, Senior Planner 3. Historic ADU Amendments - HB 3012 -Tanya Saltzman, Associate Planner 4. Potential Appeal of a Hearings Officer Decision for a Farm -Related Dwelling in the Exclusive Farm Use Zone. - Isabella Liu, Associate Planner COMMISSIONER'S UPDATES EXECUTIVE SESSION Executive Sessions under ORS 192.660 (2) (h) Litigation Board of Commissioners Work session Agenda Monday, November 5, 2018 Page 1 of 2 At any time during the meeting an executive session could be called to address issues relating to ORS 192.5660(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 public. OTHER ITEMS These can be any items not included on the agenda that the Commissioners with to discuss as part of the meeting pursuant to ORS 192.640. 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.org/meetingcalendar Meeting dates and times are subject to change. if you have question, please call (541) 388-6572. Board of Commissioners Work Session Agenda Monday, November 5, 2018 Page 2 of 2 Q 'all ca ca CL cc t9 • VI Q) ca Z44Z Q) Q 'all � S Deschutes County Board of Commissioners ,t> 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 Work Session of November 5, 2018 DATE: October 31, 2018 FROM: Matthew Martin, Community Development, 541-330-4620 TITLE OF AGENDA ITEM: Consideration of Board Signature of Order No. 2018-068, Reopen Public Hearing Record ATTENDANCE: Matthew Martin, Associate Planner REVIEWED LEGAL COUNSEL For Recording Stamp Only BEFORE THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON An Order Re -opening the Public Hearing for the Submittal of Written Materials in the De Novo * ORDER NO. 2018-068 Hearing on File Numbers of 247 -18 -000361 -AD and 247-18-000766-A WHEREAS, Appellants, Todd and Denese Fitzmaurice, appealed the administrative decision in application number 247 -18 -000361 -AD; and Whereas, the Board of County Commissioners (`Board") agreed to hear this appeal de novo under Order No. 2018-062; and WHEREAS, the Board conducted public hearings and established post -hearing periods, for the submittals of written materials; and WHEREAS, Applicant, Andrew Anderson, requests a re -opening of the public hearing record for the submittal of written materials, and WHEREAS, the Board has determined that additional testimony and information regarding this matter is of paramount importance in this proceeding; and WHEREAS, the Board may at its discretion reopen the record in accordance with DCC 22.24.160; and, WHEREAS, Applicant, Andrew Anderson, agreed in writing to extend the 150 -day time limit to December 14, 2018, in accordance with DCC 22.24.160(A) therefore, THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON, HEREBY ORDERS as follows: Section 1. The written record on file numbers 247 -18 -000361 -AD and 247-18-000766-A shall be reopened for written evidence and argumentation. Section 2. The written record for all parties for new evidence and argumentation is extended to 5:00 p.m. November 13, 2018, but only for written evidence and argumentation. Section 3. The written record of all parties is extended to 5:00 p.m. November 20, 2018, but only for response to the evidence and argumentation per Section 2. Section 4. The written record for final argument by the applicant is extended to 5:00 p.m. November 27, 2018. 1H Page 1 of 2- ORDER NO. 2018-068 Section 5. The Planning Division shall give written notice to all parties that the record is being reopened, in accordance with DCC 22.24.160(B)(2). Dated this of , 2018 BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON ATTEST: Recording Secretary Page 2 of 2- ORDER NO. 2018-068 ANTHONY DEBONE, Chair PHIIP G. HENDERSON, Vice Chair TAMMY BANEY, Commissioner �-- h ES `` Deschutes County Board of Commissioners r fE r 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 Work Session of November 5, 2018 DATE: October 29, 2018 FROM: Jacob Ripper, Community Development, 541-385-1759 TITLE OF AGENDA ITEM: Discussion: Record Materials for High Desert Nectar LLC ATTENDANCE: Jacob Ripper, Senior Planner SUMMARY: This meeting will not include deliberations. It is intended for the Board to ask questions of staff regarding materials in the record. The Board may direct staff to contact the applicant and/or appellant with requests for additional information to be submitted during the open record period. STAFF MEMO Date: October 29, 2018 To: Board of County Commissioners From: Jacob Ripper, Senior Planner Re: High Desert Nectar Appeal Hearing Record discussion The Board of County Commissioners will conduct a work session on November 5th at 1:30 PM to meet with staff regarding the record and hearing for the appeal file 247-18-000792-A (appeal of file 247 -18 -000051 -AD). This meeting will not include deliberations. It is intended for the Board to ask questions of staff regarding materials in the record. The Board may direct staff to contact the applicant and/or appellant with requests for additional information to be submitted during the open record period. 1. Open Record The Board set out the following dates for the open record period. All materials are due by 5:00 p.m. on the specified date. • Tuesday, November 13th: New materials, evidence, and testimony • Tuesday, November 20th: Rebuttal • Tuesday, November 27th: Applicant's Final Argument II. Decision Timeline The open record period extends the 150 -day .decision timeline by 29 days. This makes the final decision deadline January 11, 2018. However, to ensure the current Board can render a decision on the current application, staff has suggested the following schedule. • Wednesday, December 5th: Deliberations • Wednesday, December 19th: Final Decision 11 17 N\,V L:(.;, eWe Avenue, Bend Cir �=,o n 1+7703 P.O.i.,cx 6005, Bend, OP ? 97708-6005 08-6005 t (` 3 7:'i @cdc 'clescY nesorg \)i ES C Deschutes County Board of Commissioners �w 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 Work Session of November 5, 2018 DATE: October 29, 2018 FROM: Tanya Saltzman, Community Development, TITLE OF AGENDA ITEM: Historic ADU Amendments - HB 3012 Discussion of potential approaches to HB 3012, which permits counties to allow a historic home located in a rural residential exception area to be converted to an accessory dwelling unit and a new single family dwelling to be constructed on the same lot or parcel. MEMORANDUM TO: Deschutes County Board of Commissioners FROM: Tanya Saltzman, Associate Planner DATE: October 29, 2018 SUBJECT: Historic ADU Amendments - HB 3012 I. OVERVIEW House Bill 3012 passed in 2017, authorizing—but not requiring—counties to allow a historic home located in a rural residential exception area to be converted to an accessory dwelling unit and a new single family dwelling to be constructed on the same lot or parcel. As described in the bill, the definition of "historic" means simply that the home was constructed in 1945 or before—not that the property is a designated Goal 5 resource. In addition, the language in the bill is permissive (i.e. "A county may allow construction of a new single-family dwelling..."); therefore, the Board may choose to adopt text amendments to the Deschutes County Code that reflect this bill, or it can choose not to adopt amendments that pertain to this bill. II. SUMMARY OF HB 3012 (2017) The enrolled HB 3012 text is as follows; it is also incorporated as ORS 215.501, Accessory dwelling units in rural residential zones: SECTION 1. Section 2 of this 2017 Act is added to and made a part of ORS chapter 215. SECTION 2. (1) As used in this section: (a) "Accessory dwelling unit" means a residential structure that is used in connection with or that is auxiliary to a single-family dwelling. (b) "Area zoned for rural residential use" means land that is not located inside an urban growth boundary as defined in ORS 195.060 and that is subject to an acknowledged exception to a statewide land use planning goal relating to farmland or forestland and planned and zoned by the county to allow residential use as a primary use. (c) "Historic home" means a single-family dwelling constructed between 1850 and 1945. (d) "New" means that the dwelling being constructed did not previously exist in residential or nonresidential form. "New" does not include the acquisition, alteration, renovation or remodeling of an existing structure. (e) "Single-family dwelling" means a residential structure designed as a residence for one family and sharing no common wall with another residence of any type. (2) Notwithstanding any local zoning or local regulation or ordinance pertaining to the siting of accessory dwelling units in areas zoned for rural residential use, a county may allow an owner of a lot or parcel within an area zoned for rural residential use to construct a new single-family dwelling on the lot or parcel, provided: (a) The lot or parcel is not located in an area designated as an urban reserve as defined in ORS 195.137; (b) The lot or parcel is at least two acres in size; (c) A historic home is sited on the lot or parcel; (d) The owner converts the historic home to an accessory dwelling unit upon completion of the new single-family dwelling; and (e) The accessory dwelling unit complies with all applicable laws and regulations relating to sanitation and wastewater disposal and treatment. (3) An owner that constructs a new single-family dwelling under subsection (2) of this section may n ot: (a) Subdivide, partition or otherwise divide the lot or parcel so that the new single-family dwelling is sifl rated on a different lot or parcel from the accessory dwelling unit. (b) Alter, renovate or remodel the accessory dwelling unit so that the square footage of the accessory dwelling unit is more than 120 percent of the historic home's square footage at the time construction of the new single-family dwelling commenced. (c) Rebuild the accessory dwelling unit if the structure is lost to fire. (d) Construct an additional accessory dwelling unit on the same lot or parcel. (4) A county may require that a new single-family dwelling constructed under this section be served by the same water supply source as the accessory dwelling unit. (5) A county may impose additional conditions of approval for construction of a new single-family dwelling or conversion of a historic home to an accessory dwelling unit under this section. III. DESCHUTES COUNTY ANALYSIS As noted during the Housekeeping Amendments process, during which HB 3012 was first discussed, staff prepared an analysis of the number of lots that could potentially utilize this law as written. It was determined that approximately 113 parcels in Deschutes County fall under the criteria of 1) being located in the MUA or RR -10 zoning districts; 2) property is two acres or more; and 3) property is built before 1946. Page 2 of 5 IV. ACTIONS TAKEN IN OTHER COUNTIES Staff research has indicated that several counties have adopted amendments pertaining to HB 3012. Some have adopted the amendments as is, and others have added additional conditions of approval, as illustrated in the examples below. Several counties have not adopted amendments pertaining to this bill, including Clatsop, Morrow, and Gilliam. Clackamas County • Clackamas County added the option of placing a manufactured home on the property to become the primary dwelling. In addition, it requires owner occupancy of either the primary or accessory dwelling (noted in italics). 843 ACCESSORY HISTORIC DWELLINGS 843.01 PROCEDURE An accessory historic dwelling requires review as a Type I application pursuant to Section 1307, Procedures. 843.02 MINIMUM LOT SIZE An accessory historic dwelling may only be permitted on a lot of record at least two acres in size 843.03 CONVERSION IN CONJUNCTION WITH NEW DWELLING A. A detached single-family dwelling legally built between 1850 and 1945 may be converted c.._.,.,. .�,, p1l;n to nn mrroccnry dwellin � innn cmmnlPtinn of a new detached [I U1 I I a pr hilar y uvvcnu IF, w — u�..�..�,„, y .g .,.�... - single-family dwelling, or the placement of a manufactured dwelling, on the same lot of record. B. As used in Subsections 843.03(A) and 843.04(A): 1. "New" means that the single-family dwelling being constructed did not previously exist in residential or nonresidential form; "new" does not include the acquisition, alteration, renovation, or remodeling of an existing structure; 2. 'Placement of a manufactured dwelling" means the placement of a manufactured dwelling that did not previously exist on the subject lot of record, it may include the placement of a manufactured dwelling that was previously used as a dwelling on another lot and moved to the subject lot of record. 843.04 ALTERATION AND REPLACEMENT A. An accessory historic dwelling may not be altered, renovated, or remodeled so that its square footage is more than 120 percent of its square footage at the time construction of the new detached single-family dwelling, or placement of a manufactured dwelling, commenced. B. An accessory historic dwelling may not be replaced if it is lost to fire, destroyed, or removed for any reason. 843.05 OWNER OCCUPANCY Page 3 of 5 Owner occupancy of either the accessory historic dwelling or the primary dwelling shall be required. A deed restriction requiring owner -occupancy of one of the dwelling units shall be recorded prior to issuance of a building or placement permit for the new primary dwelling. Coos County (draft text proposed for October 2018) • Coos County refines the description of zones in which the provisions of the bill are permitted (noted in italics). Accessory Dwelling units may be allowed on properties with historical dwellings in all non -resource zones that allow for single family dwellings. A historical dwelling maybe permitted as the accessory dwelling unit and a new primary single family dwelling shall be permitted. Accessory dwelling unit sizes and standards shall apply. If the new primary dwelling is proposed it shall be at least 25 percent larger than the historical dwelling to allow the historical dwelling to be considered accessory. Douglas County Douglas County added the use to Rural Residential zones as a use with standards, and refers to ORS 215 for standards. SECTION 3.8.075 Uses Permitted With Standards In the 5R Zone, the following uses and activities are permitted subject to specified standards and the general provisions and exceptions set forth by this Ordinance. One new single-family dwelling (SFD) on a lot or parcel at least two acres in size located outside of an urban growth boundary and containing a historic home (constructed between 1850 and 1945), which is to be converted to an "accessory dwelling unit" (ADU) upon completion of the new SFD, subject to the standards, limitations and restrictions of ORS 215 for the provision. Marion County (draft text proposed for late 2018) Marion County utilizes the text of HB 3012 nearly verbatim, with minor clarifying changes to the language. A dwelling constructed between 1850 and 1945 on a parcel at least two acres in size outside of any area designated as an urban reserve may remain on the parcel as an accessory dwelling unit if replaced by a new single-family dwelling on the parcel subject to the following conditions: a. The property owner shall obtain all required permits from Marion County Building Inspection to convert the existing residence to an accessory dwelling unit upon completion of the new single-family dwelling, including permits for sanitation and wastewater disposal and treatment. Page 4 of 5 b. The land containing the accessory dwelling cannot be divided from the land containing the new single-family dwelling. c. The accessory dwelling unit cannot be renovated or remodeled so that the square footage of the accessory dwelling unit is more than 120 percent of the historic home's square footage at the time construction of the new single-family dwelling commenced. d. The accessory dwelling cannot be rebuilt if the structure is lost to fire. e. The property owner shall record a declaratory statement acknowledging compliance with the conditions in (b), (c) and (d) above. OPTIONAL: The new single-family dwelling shall be served by the same water supply source as the accessory dwelling unit. V. NEXT STEPS Staff seeks Board direction and offers the following suggested approach for next steps: 1. Bring proposed amendments to Planning Commission for work session and public hearing (tentative hearing date: December 13). Proposed amendments may: A. Reproduce ORS 215.501 in its entirety with no changes B. Modify language to address items such as: i. Definition of "historic" - should this be linked to documented historic resources? ii. Manufactured homes iii. Zones permitted - rural residential iv. Water supply v. Owner occupancy vi. Other 2. Other action as determined by the Board. Page 5 of 5 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 Work Session of November 5, 2018 DATE: October 31, 2018 FROM: Isabella Liu, Community Development, TITLE OF AGENDA ITEM: Potential Appeal of a Hearings Officer Decision for a Farm -Related Dwelling in the Exclusive Farm Use Zone. ATTENDANCE: Izze Liu, Associate Planner SUMMARY: Before the Board of County Commissioners is a potential appeal of a Hearings Officer's decision denying a farm -related dwelling in the Exclusive Farm Use Zone. The Board will consider Order No. 2018-070 and decide if the Board will call up the review if the decision is appealed. RE IEWE LDNA COUNSEL BEFORE THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON An Order Accepting Review of Hearings Officer's Decision in File No. 247-18-000734-A ORDER NO. 2018-070 WHEREAS, on October 23, 2018, the Deschutes County Hearings Officer issued an approval of Application No. 247-18-000734-A; and WHEREAS, Section 22.28.050 of the Deschutes County Code authorizes the Board of County Commissioners ("Board") to initiate review of any administrative action or a Hearings Body's decision within 12 days of the date of mailing of the final written decision of the Planning Director or lower Hearings Body; and WHEREAS, the Board has given due consideration as to whether to review this application; now, therefore, THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON, HEREBY ORDERS as follows: Section 1. Should a timely appeal of Application No. 247-18-000734-A be filed, the Board of County Commissioners will serve as the hearings body for the appeal consistent with applicable provisions of DCC, including DCC 22.32.027(B)(4). Section 2. The review shall be heard de novo in order for the Board to interpret DCC 18.116.330 and other applicable provisions. Section 3. Staff shall set a hearing date and cause notice to be given to persons or parties entitled to notice pursuant to DCC 22.24.030 and 22.32.030. Dated this 5 of November, 2018 BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON ATTEST: Recording Secretary PAGE, 1 OF 1- ORDER No. 2018-070 ANTHONY DEBONE, Chair PHILIP G. HENDERSON, Vice Chair TAMMY BANEY, Commissioner Mailing Date: Tuesday, October 23, 2018 HEARINGS OFFICER DECISION FILE NUMBER: 247-18-000734-A (an appeal of 247 -18 -000381 -AD) APPLICANT/OWNER: Wayne & Susan Singhose PROPOSAL: The applicants request approval of a farm -related dwelling on non -high value farmland in the Exclusive Farm Use Zone. HEARING DATE: October 9, 2018 at 6 pm STAFF CONTACT: Izze Liu, Associate Planner HEARINGS OFFICER: Will Van Vactor The Hearings Officer adopts the findings made by staff in the Administrative Decision except as indicated under the heading "HEARINGS OFFICER". I. APPLICABLE CRITERIA Title 18, Deschutes County Zoning Ordinance Chanter 1816; Fxclusive Farm Use (EFU) Zone Title 22, Deschutes County Development Procedures Ordinance II. BASIC FINDINGS A. LOCATION: The subject property has an assigned address of 62485 County Line Road, Bend; and is identified on County Assessor Tax Map 17-14-25 as tax lot 700. B. LOT OF RECORD: The subject property is a legal lot of record because it was platted as Parcel 1 of PP1997-41. C. ZONING: The property is zoned EFU. D. PROPOSAL: The applicants are proposing to establish a new farm -related dwelling on the southwest portion of the subject property on non -high value farmland. E. SITE DESCRIPTION: The subject property is 143.20 acres in size and irregular in shape. The property is accessed from County Line Road, a rural local road. The topography is relatively level with a moderate cover of vegetation on the western half of the property. Of the 143 or acres, approximately 59 acres of the subject property are irrigated pasture land. The subject property is developed with an existing farm related accessory structure which is located in the northeast corner. Proposed Dwelling Location F. SOILS: According to the soils maps prepared by the National Resources Conservation Service (NRCS) of the U.S. Department of Agriculture, the subject property is composed of one soil type: 27A, Clovkamp loamy sand, 0 to 3 percent slopes. Clovkamp Loamy Sand soils consist of 85 percent Clovkamp soils and similar inclusions and 15 percent contrasting inclusions. The contrasting inclusions for the Clovkamp soils consist of Deskamp soils on side slopes. The major uses of this soil are irrigated cropland and livestock grazing. The agricultural capability ratings of this soil are 3s when irrigated and 6s when not irrigated. Section 18.04.030 of the DCC considers this soil type high-value farmland when irrigated. The entire parcel is made up of this soil type. G. PUBLIC AGENCY COMMENTS: The Planning Division mailed a Notice of Application and received comments from the following agencies: 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 2 of 13 1. Alfalfa Fire District: Ron Thompson, Fire Chief, provided the following comments on May 10, 2018: The following is input from the Alfalfa Fire District. • Address should be clearly visible from the primary access road. • Access gate should be at least 20 feet wide to provide access to fire apparatus. • Access roads and driveways should be able to support fire apparatus in all types of weather. • Exit doors should be clearly marked and unobstructed. • Onsite firefighting water supply should be clearly marked and be accessible to firefighters at all times. • Portable fire extinguishers should be located throughout the building and location clearly marked. • Facility should have a fire safety plan including exit plan and employee accountability system. This plan should be practiced by all employees on a regular basis. • Material Safety Data Sheets for all onsite hazardous materials should be keep on site and be accessible to fire department personnel at all times. • All hazardous material storage areas, tanks and containers should be clearly marked. • Firefighters should be able to coordinate with facility managers a building walk through for the purpose of training and emergency planning. 2. Deschutes County Building Division: Randy Scheid, Building Official, provided the following comments on May 15, 2018: The Deschutes County Building Safety Divisions code mandates that Access, Egress, Setbacks, Fire & Life Safety, Fire Fighting Water Supplies, etc. must be specifically addressed during the appropriate plan review process with regard to any proposed structures and occupancies. Accordingly, all Building Code required items will be addressed, when a specific structure, occupancy, and type of construction is proposed and submitted for plan review. 3. Deschutes County Planning Division: Peter Russell, Senior Transportation Planner, provided the following comments on July 28, 2017: I have reviewed the transmittal materials for 247 -18 -000381 -AD for a farm dwelling on 143 acers in the Exclusive Farm Use (EFU) zone at 62485 County Line Road, aka 17-14-25, Tax Lot 700. The most recent edition of the Institute of Traffic Engineers (ITE) Trip Generation Handbook indicates a single-family residence (Land Use 210) generates an average of approximately 10 daily weekday trips. Deschutes County Code (DCC) at 18.116.310(C)(3)(a) states no traffic analysis is required for any use that will generate less than 50 new weekday 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 3 of 13 trips. The proposed land use will not meet the minimum threshold for additional traffic analysis. The property was approved for a driveway permit on Nov. 5, 1997, under SW24531A97156 and thus complies with DCC 17.48.210(A). The application does discuss shifting the location of the access and any new driveway location must be approved by the County. Board Resolution 2013-020 sets a transportation system development charge (SDC) rate of $3,937 per p.m. peak hour trip. County staff has determined a local trip rate of 0.81 p.m. peak hour trips per single-family dwelling unit, therefore the applicable SDC is $3,189 ($3,937 X 0.81) per lot. The SDC is due prior to issuance of certificate of occupancy; if a certificate of occupancy is not applicable, then the SDC is due within 60 days of the land use decision becoming final. HEARINGS OFFICER: If this decision is appealed, and the Deschutes County Board of County Commissioners (the "BOCC") reverses, it should include a condition of approval requiring that the SDC be paid prior to issuance of a certificate of occupancy. 4. The following agencies did not respond: Deschutes County Assessor, Deschutes County Environmental Soils Division, Deschutes County Road Department, Central Oregon Irrigation District, and the Bureau of Land Management. H. PUBLIC COMMENTS: The Planning Division mailed a written notice of these applications to nrnnPrty owners within 750 feet of the subiect property on May 9, 2018. In addition, the applicant submitted a Land Use Sign Affidavit dated May 11, 2018, indicating a proposed land use action sign was posted on the property. One comment was received with concerns that the application would not meet all of the applicable criteria. Applicable criteria of the DCC are addressed below. I. REVIEW PERIOD: This application was submitted on April 30, 2018. It was deemed incomplete on May 30, 2018. After the applicant submitted additional information, the application was accepted and deemed complete on June 11, 2018. The 150th day on which the County must take final action on this application is November 8, 2018. J. HEARING: The Hearing was held on October 9, 2018 at 6 pm. The Hearings Officer made opening statements including disclosures regarding ex parte contacts, bias, and conflicts of interest. There were no objections to the Hearings Officer hearing the case. Neither party requested a continuance or an additional open record period, so at the conclusion of the hearing, the record was closed. III. FINDINGS: A. CHAPTER 18.16. EXCLUSIVE FARM ZONE 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 4 of 13 Section 18.16.025. Uses Permitted Subject to the Special Provisions Under DCC Section 18.16.038 and a Review under DCC Chapter 18.124 where applicable. A. Dwellings customarily provided in conjunction with farm use (farm -related dwellings), subject to DCC 18.16.050. FINDING: The applicant has applied for an approval of a farm -related dwelling on a 143.20 -acre farm in the EFU zone. The subject property contains approximately 59 acres of irrigated land that is used for the production of alfalfa hay. Irrigated lands occupy less than half of the size of the property. Section 18.16.038 has no criteria that apply to the proposed farm -related dwelling, and consequently no findings for the proposed dwelling are necessary under that section. The special provisions that apply to farm -related dwellings are found in DCC 18.16.050. 2. Section 18.16.050. Standards for dwellings in the EFU zones. Dwellings listed in DCC 18.16.025 and 18.16.030 may be allowed under the conditions set forth below for each kind of dwelling, and all dwellings are subject to the landowner for the property upon which the dwelling is placed, signing and recording in the deed records for the County, a document binding the landowner, and the landowner's successors in interest, prohibiting them from pursuing a claim for relief or cause of action alleging injury from farming or forest practices for which no action or claim is allowed under ORS 30.936 or 30.937. HEARINGS OFFICER: As noted below the, the Hearings Officer finds that the applicants do not meet all of the criteria. However, if this decision is appealed, and the BOCC disagrees with the Hearings Officer's conclusion, the Board should include a condition of approval that requires the property owners to sign and record a Farm and Forest Management Easement in the deed records for the County, as required by this code provision. A. Farm -related dwellings on non -high value farmland. A dwelling customarily provided in conjunction with farm use, as listed in DCC 18.16.030(A), may be approved if it satisfies any of the alternative tests set forth below. 3. Gross annual income test. a. On land not identified as high-value farmland, a dwelling, including a manufactured home in accordance with DCC 18.116.070, may be considered customarily provided in conjunction with farm use if.• The subject tract is currently employed for a farm use, and that the farm operator earned $32,500' in gross annual revenue in the last two years, three of the last five years, or based on the The gross annual income test for farm -related dwellings on non -high value farmland increased to $40,000 pursuant to OAR 660-033-0135(3). 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 5 of 13 average farm revenue earned on the tract in the highest three of the last five years. FINDING: According to the NRCS soil survey, the subject property contains 27A soils (high-value farmland when irrigated). The subject property has approximately 59 acres of irrigated land, which is less than 50 percent of the entire property, therefore; the subject property is not considered high- value farmland. The applicant has provided in their application materials, receipts from the sale of alfalfa for the past five years. In the last two years, the farm operator earned over $50,000 in gross annual revenue. These criteria are met. ii. There is no other dwelling on the subject tract, except as allowed under 18.16.020(K);2 HEARINGS OFFICER: In their Burden of Proof Statement dated April 25, 2018 ("BOP"), the applicants state that the subject property is owned by Wayne and Susan Singhose as husband and wife. BOP, pg. 4. They further state that with the exception of one lot, the surrounding contiguous properties are not in the same ownership. Id. The applicants also state that Tax Lot 1700, the only contiguous lot that is also owned by Wayne and Susan Singhose personally, contains no dwelling. Id. On appeal, Central Oregon LandWatch ("COLW") contends that the applicant does not meet this criterion because subject property is part of larger "tract" and that other dwellings exist on the tract, In s nInnrt of it-, argument. COLW contends that OAR 660-033-0135(3) applies. See Isbell Letter dated October 8, 2018 ("Isbell Ltr"), pg.1. COLW's argument can be summarized as follows: • The subject property (TL 700) is part of a larger "tract" (Id., pgs. 1-2); • The larger tract consists of nine separate tax lots (Id., pg. 5); • Four separate dwellings already exist on three separate tax lots already within the tract (Id.); Notwithstanding the fact the dwellings are located on tax lots owned by the Wayne & Susan Singhose Trust), because the applicants are also the trustees for the trust that owns those lots, the lots are all part of the same tract (/d., pg. 3). • The applicable OAR only allows one dwelling per farm or ranch operation. The applicants respond with the same arguments made in the BOP. They also contend that the owner is who is on record on the deed; a trust that owns property, the trustees own it as trustees, LLCs own property as LLC (not members), etc. (Hearing Recording ("Rec.") at 12:40). The applicants, as husband and wife, own two pieces of property. Rec. at 13:15. The two lots do not have primary farm dwellings. Rec. at 13:40. The County did not intend to say that any property owned by an agent is considered when reviewing an application. Rec. at 17:15. z DCC 18.16.020(x) allows replacement dwellings to be used in conjunction with farm use if the existing dwelling is listed on the National Register of Historic Places. 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 6 of 13 The issue presented here is whether conveying a parcel or parcels that are part of a farm operation to a trust controlled by the same individuals who own other parcels of the farm operation individually creates two or more tracts, or whether the parcels remain a single tract. Both COLW and the Applicants stated at the hearing that they believe this is an issue of first impression. Although the Hearings Officer encouraged the parties to provide legal research regarding this issue, neither party requested an opportunity to do so. In support of their respective arguments, the parties focus on the definition of "tract" and "owner". According to DCC 18.04, "Tract' as used in DCC 18.16 ...means one or more contiguous lots or parcels in the same ownership. (emphasis added) "Contiguous land" means "parcels of land under the same ownership which about ..." DCC 18.04. With the exception of the term "ownership", the term "tract" is unambiguous. There is no doubt that if title to the nine tax lots was held by the same people or entity, the nine tax lots would be considered a single tract. Thus, the question is what "ownership" means. Deschutes County Code does not include a definition of "ownership", but it does include a definition of "owner". According DCC 18.04, "'[o]wner' means the owner of real property or the authorized agent thereof or the contract purchaser of real property of record as shown on the last available complete tax assessment roll or County Recorder's records." Thus, there are three types of owners: 1) The owner of real property; 2) The authorized agent of the owner of real property; and 3) The contract purchaser of real property of record as shown in the tax assessment roll or County recorder's records. The Hearings Officer finds the second and third types do not apply. Specifically, the Hearings Officer agrees with the applicants that being trustee of a trust does not make them an authorized agent under this definition. And there is no contention that there is a contract purchaser. Thus, the meaning of "owner" boils down to what "owner of real property" means. The Hearings Officer finds that because the definition uses the word it is defining that the definition if of little use. The ambiguity or uncertainty created by the definition is underscored by the fact the real question is what "ownership" means, not "owner." Contrary to the applicants' contention that the term "owner" means "record owner" (Rec. at 12:40), it is not that simple. A record owner is only one type of owner. A "record owner" may not even be the actual owner since the "legal owner" may not have recorded the deed. Moreover, in addition to record and legal owners, there are "beneficial owners", such as the beneficiary under a trust. The Hearings Officer finds nothing in the County's code that limits the definition of "ownership" to the record owner This is consistent with case law where "ownership" is not to be changed by the conveyance from an individual to his or her trust. See e.g., Adams v. Jackson County, LUBA No. 2007- 004, n. 3 (Or LUBA 2007) (noting that the conveyance from an individual to his trust did not change ownership); see also Welch v. Yamhill County, LUBA No 2007-111 (Or LUBA 2008) ("The DLCD Order determines that the Kroos are the owners of the subject property for purposes of ORS 197.352, and 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 7 of 13 that the 2003 transfer of legal title to the property to a revocable trust was not a change in ownership for purposes of that statute.") The bottom line is that is not entirely clear that the term "ownership" distinguishes between individual ownership and trust ownership.' For the above reasons, the Hearings Officer finds the definition of "ownership" to be ambiguous and therefore looks to context. Importantly, Deschutes County's EFU zone implements OAR 660, division 033. See e.g., Central Oregon Landwatch v. Deschutes County, LUBA No. 2016-103). Consequently, ORS 215, including ORS 215.283(1)(e), and OAR 660-033-0135 provide context for interpreting the county's EFU zone, including DCC 18.16.050(A). Subject to ORS 215.279, dwellings in conjunction with farm use are permitted on EFU lands. ORS 215.283(1)(e). Second, ORS 215.279 provides the framework within which Land Conservation and Development Commission (LCDC) is to adopt the farm income standards. In ORS 215.279, the Oregon legislature used the term "tract", but does not refer to "owner" or "ownership", instead referring to "farm operator". This implies to the Hearings Officer that the legislature was more concerned with the overall farm operation than the separate ownership different portions of the farm. Additionally, the related LCDC rule that applies to dwellings in conjunction with farm use states, in part: (3) On land not identified as high-value farmland, a dwelling may be considered customarily in conjunction with farm use if: (a) The subject tract is currently employed for the farm use, as defined in ORS 215.203 ... (b) Except for seasonal farmworker housing approved prior to 2001, there is no other dwelling on lands designated for exclusive farm use pursuant to [ORS 215] or for mixed farm/forest use pursuant to OAR 660-006-0057 owned by the farm or ranch operator or on the farm or ranch operation; (c) The dwelling will be occupied by a person or persons who produced the commodities that grossed the income in subsection (a) of this section ... (emphasis added) In light of the context provided by the statute and administrative rule, the Hearings Officer finds "ownership" is not determined simply by identifying the record owner. If that were the case, then a farm operator could convey separate lots to different trusts or business entities, and so long as the operator can continue to meet the income test, he or she could place a house on each lot that is owned by a separate legal entity. The applicable state statutes and administrative rules make it clear that is not the intent. And even if the County intended DCC 18.16.050(A) to mean what the applicants claim it means, the Hearings Officer finds such interpretation to be unlawful. As noted above, the County's EFU zone implements ORS 215 and OAR 660-033. Under the Hearings Officer interpretation, a farm operator 3 These cases are not perfect guideposts, but tend to show that the definition of "ownership" in the land use context is not as simple as the applicants argue. 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 8 of 13 can only have one farm dwelling per farm operation. However, under the applicants' interpretation, a farm operator (as explained above) could have more than one dwelling. Thus, the applicants' interpretation would be less restrictive than the state statute and administrative rule. See Kenogy v. Benton County, 112 Or App 17, 20 n 2 (noting counties may adopt EFU zones that are more restrictive than statutory EFU zoning requirements, county may not adopt EFU zones that are less restrictive than statutory requirements). In addition to the statutory context, the Hearings Officer also reviewed the dictionary definition of "ownership". Black's Law Dictionary, defines "ownership" as "[t]he collection of rights allowing one to use and enjoy property, including the right to convey it other others." Abr. 7t" Ed. The applicants did not submit any evidence regarding the nature of the trust that owns the contiguous lots. The Hearings Officer finds there is not substantial evidence in the record to find that as the trustees of the trust, the rights for the Singhoses individually and as trustees varies in any way. As was the case with the conveyances to trust in the above cited cases, there is no basis to find ownership is different now simply because a trust owns the contiguous properties.4 As to the evidence in the record, the Hearings Officer finds it relevant that: 1) Although the some of the nine lots are owned by Wayne and Susan Singhose individually and other lots are owned by their trust, they are all part of the same farm operation. Rec. at 20:15 (noting if using "Singhose Ranches" on letterhead probably referring to entire farm operation including the lots owned by the trust). 2) There are multiple dwellings on the properties that comprise the farm operation. Regarding the dwelllnR located 62500 County Line Road, this is the dwelling in which the applicants currently resides It does not qualify as either seasonal farmworker housing ora replacement dwelling under DCC 18.16.020(K). As to the other dwellings, COLW submitted evidence that the dwellings exist, but the record is unclear who resides in them for determining if they might be seasonal farmworker housing. For the above reasons, the Hearings Officer finds that applicants do not meet this criterion. iii. The dwelling will be occupied by a person or persons who. produced the commodities which grossed the income in DCC 18.16.050(A)(3)(a)(i); and FINDING: The subject property is owned by Susan and Wayne Singhose, who produced the commodities which grossed the income. The applicant has represented that they will live in the dwelling. This criterion will be met. HEARINGS OFFICER: COLW contends that the applicants live across the street so this criterion cannot be met. The applicants respond by noting that they intend to live in the new dwelling that is 4 This analysis might change if, for example, the trust is irrevocable and the beneficiaries are not the Singhoses. 5 With additional evidence, it may be possible to meet this criterion. For example, if the applicants are willing to remove the dwelling at 62500 County Line Road and the Singhoses submit evidence that the two other dwellings are seasonal farm housing approved prior to 2001, as allowed, then it may be possible to meet this criterion. 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 9 of 13 the subject of this property. If the applicants live in the proposed dwelling, the Hearings Officer finds this criterion can be met. b. in determining gross revenue, the cost of purchased livestock shall be deducted from the totalgross revenue attributed to the tract. FINDING: The income used to qualify the property was derived from alfalfa sales. This criterion does not apply. C. Noncontiguous lots or parcels zoned for farm use in the same county or contiguous counties may be used to meet the gross revenue requirements. FINDING: The applicant did not include gross revenue from noncontiguous parcels. This criterion does not apply. d. Only gross revenue from land owned, not leased or rented, shall be counted, and gross farm revenue earned from a lot or parcel which has been used previously to qualify another lot or parcel for the construction or siting of a primary farm dwelling may not be used. FINDING: The applicant provided receipts to show the gross revenue of alfalfa hay grown on the subject property. The subject property is owned by Susan and Wayne Singhose, the farm operators. This criterion is met. e. Prior to a dwelling being approved under this section that requires one or more contiguous or noncontiguous lots or parcels of a farm or ranch operation to comply with the gross farm revenue requirements, the applicant shall provide evidence that the covenants, conditions and restrictions form attached to Chapter 98.96, has been recorded with the county clerk or counties where the property subject to the covenants, conditions and restrictions is located. 9. The covenants, conditions and restrictions shall be recorded for each lot or parcel subject to the application for primary farm dwelling and shall preclude: a. All future rights to construct a dwelling except for accessory farm dwellings, relative farm assistance dwellings, temporary hardship dwellings or replacement dwellings allowed under ORS Chapter 295; and b. The use of any gross farm revenue earned on the lots or parcels to qualify another lot or parcel for a primary farm dwelling,• C. The covenants, conditions and restrictions are irrevocable, unless a statement of release is signed by an authorized representative of the county or counties 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 10 of 13 where the property subject to the covenants, conditions and restrictions is located, d. The failure to follow the requirements of this section shall not affect the validity of the transfer of property or the legal remedies available to the buyers of property which is subject to the covenants, conditions and restrictions required by this section. FINDING: The applicant provided documents showing gross revenue from alfalfa hay sales from only the subject property. These criteria do not apply. 3. Section 18.16.060. Dimensional Standards. E. Building height. No building or structure shall be erected or enlarged to exceed 30 feet in height, except as allowed under DCC 18.120.040. HEARINGS OFFICER: If on appeal the Board finds that the farm dwelling can be approved, a condition of approval should be included to ensure compliance with this criterion. 4. Section 18.16.070. Yards. A. The front yard shall be a minimum of. 40 feet from a property line fronting on a local street, 60 feet from a property line fronting on a collector street, and 100 feet from a property line fronting on an arterial street. B. Each side yard shall be a minimum of 25 feet, except that for a nonfarm dwelling proposed on property with side yards adjacent to property currently employed in farm use, and receiving special assessment for farm use, the side yard shall be a minimum of 100 feet. C. Rear yards shall be a minimum of 25 feet, except that for a nonfarm dwelling proposed on property with a rear yard adjacent to property currently employed in farm use, and receiving special assessment for farm use, the rear yard shall be a minimum of 100 feet. D. In addition to the setbacks set forth herein, any greater setbacks required by applicable building or structural codes adopted by the State of Oregon and/or the County under DCC 15.04 shall be met. FINDING: The eastern boundary of the subject property abuts County Line Road, a rural local road, requiring a 40 -foot setback. The proposed farm -related dwelling must also be setback 25 feet from the northern, southern and western property boundaries. Based on the submitted application materials, the proposed farm -related dwelling will be setback more than 40 feet from the eastern boundary, approximately 250 feet from the southern boundary, approximately 540 feet from the western boundary and more than 1,000 feet from the northern property boundary. These comply with the setback standards of the EFU zone. The proposal also complies with solar setback standards of 18.116.180(B)(1). These criteria will be met. 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 11 of 13 5. Section 22.20.015. Code Enforcement and Land Use A. Except as described in (D) below, if any property is in violation of applicable land use regulations and/or the conditions of approval of any previous land use decisions or building permits previously issued by the County, the County shall not 1. Approval any application for land use development, 2. Make any other land use decisions, including land divisions and/or property line adjustment, 3. Issue a building permit. C. A violation means the property has been determined to not be in compliance either through a prior decision by the County or other tribunal, or through the review process of the current application, or through an acknowledgement by the alleged violated in a signed voluntary compliance agreement ("VCA"). HEARINGS OFFICER: COLW contends that "[i]t is not clear the existing accessory dwelling is in compliance with existing conditions of approval, and until it is brought into compliance, no further approvals are permitted under DCC 22.20.015." COLW's Appeal Application, pg. 2. And in its October 8, 2018, written submittal, COLW further explained that pursuant to A.D-12-5 (an accessory dwelling approval for TL 17142500-00800), the applicant argued that its farm tract was 1,084 in order to obtain approval of an accessory dwelling. Pg. 10. COLW notes that the applicant is now arguing that the subject property is not part of that tract. As a result, according to COLW, the applicant is no longer in compliance with conditions of approval for AD -12-5. The applicants respond by stating that COLW is accusing them of committing a crime without regard for their due process rights. The Hearings Officer notes that the language in DCC 22.20.015(C) could be interpreted as giving the County authority to review an alleged code violation concurrent with its. review of a pending land use application. However, the Hearings Officer believes that such interpretation is contrary to other more specific code enforcement procedures as stated in the Deschutes County Code and would violate the property owner's rights to participate in those code enforcement proceedings. Importantly, DCC 1.17 dictates the hearings procedure for code enforcement complaints. The code requires a "Notice of Violation" (DCC 1.17.050), "Service of Notice' (DCC 1.17.060 and 1.17.080), a hearing (DCC 1.17.070), discovery pursuant to ORS 135.805 to 135.873 (DCC 1.17.080). The Hearings Officer finds that denying the application under the facts of this case, where there was no Notice of Violation, Service of Notice, or discovery, would violate the applicant's rights afforded under DCC 1.17. Alternatively, the alleged violation appears to be tenuous, since even COLW only contends "it is not clear ..." As a result, even if the Hearings Officer were to find it appropriate to prosecute the allege code violation in this proceeding, there is not sufficient evidence to find that a violation exists. 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 12 of 13 IV. CONCLUSION Based on the foregoing findings, Hearings Officer concludes that the proposed farm -related dwelling does not comply with the applicable standards and criteria of the Deschutes County zoning ordinance. V. DECISION 1]111►111 This decision becomes final twelve (12) days after the date of mailing, unless appealed by a party of interest. Will Van Vactor, Hearings Officer Dated: October 23, 2018 247-18-000734-A (an appeal of 247 -18 -000381 -AD) Page 13 of 13 c c c c c c c 0 0 0 0 0 0 0 .N .N .N .M . .M •N Q v v v v 0 v v 0 0 0 0 0 0 0 w Z J Z O^ U U U_ U ZLn Z Z Z Z 0 0 0 0 0 0 y U m X = = = = O N =U V U U Lr)NO O J J J J co Lo 0 0- w w w w Z U Q Q V D Z w_ a � Z J Q Lu Z J = O w CL l7 ji LL, V) —i U 0 Q U i 0 < d Z N Y K c z Z w Z J Q Q 0 vi V Y> O 2 LL