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2020-35-Minutes for Meeting December 18,2019 Recorded 1/29/2020BOARD O; COMMISSIONERS 1300 NW Wall Street, Bend, Oregon (541) 388-6570 Recorded in Deschutes County CJ2020-35 Nancy Blankenship, County Clerk Commissioners' ,journal 01 /29/2020 10:45:34 AM co .: 2020-3iiminumuiuuuu FOR RECORDING STAMP ONLY �:00 AM WEDNESDAY, December 18,2019 BARNES & SAWYER ROOMS Present were Commissioners Phil Henderson, Patti Adair, 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 identified 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.iqm2.com/Citizens/Default.aspx CALL TO ORDER: Chair Henderson called the meeting to order at 9:00 a.m. PLEDGE OF ALLEGIANCE: CITIZEN INPUT: None presented CONSENT AGENDA: Before the Board was Consideration of Approval of the Consent Agenda. Commissioner Adair asked to pull item 4 for discussion and Commissioner DeBone acknowledged he hadn't reviewed the minutes, listed as items 6 and 7. BOCC MEETING DECEMBER 18, 2019 PAGE 1 OF 8 ADAIR: Move approval of Consent Agenda minutes Items #4, 6, and 7 DEBONE: Second VOTE: ADAIR: Yes DEBONE: Yes HENDERSON: Chair votes yes. Motion Carried Consent Agenda Items: 1. Consideration of Chair Signature of Document No. 2019-601, Amendment to Medcor, Inc. Services 2. Consideration of Chair Signature of Document No. 2019-602, Amendment to Pharmacy Agreement with Premise Health 3. Consideration of Board Signature of Document No. 2019-762, Crisis and Transition Services Contract with Youth Villages 4. Consideration of Chair Signature of Document No. 2019-805, Oregon Health Authority Grant Agreement 5. Consideration of Board Signature of Reappointment of Mike Maier to the Deschutes County Budget Committees 6. Approval of Minutes of the December 2, 2019 BOCC Meeting 7. Approval of Minutes of the December 5, 2019 BOCC Meeting ACTION ITEMS: Consent Agenda Item 4 as pulled for discussion: Consideration of Chair Signature of Document No. 2019-805, Oregon Health Authority Grant Agreement Health Services Director Janice Garceau presented this item and explained the services that would be covered by the grant funding. DEBONE: Move Chair Signature of Document No. 2019-805 ADAIR: Second VOTE: DEBONE: Yes ADAIR: Yes HENDERSON: Chair votes yes. Motion Carried BOCC MEETING DECEMBER 18, 2019 PAGE 2 OF 8 8. Consideration of County Administrator Signature of Document No. 2019-839, Cohesive Strategy Coordinator Contract County Forester Ed Keith and Central Oregon Cohesive Strategy Coordinator Allison Green presented the document and scope of work. The contract period renews the effort for an additional year covering work for five counties. Each county provides funding for the contract services along with the US Forest Service. Mr. Keith contacted the five counties for input on the scope of work and they would support the contract but would look for additional participation. Ms. Green reported on work with the US Forest Service, Deschutes Forest Collaborative Project and the scope of work and highlights with Cohesive Strategy. Commissioner Henderson inquired on her progress of seeking out grant funding for fire prevention/fuels reduction. Ms. Green replied she has been working with the joint Chiefs Group and Ochoco Collaborative providing input during their grant applications. Commissioner Henderson encourages efforts for grant funding. Commissioner DeBone noted the importance to advocate for private industry for biomass. ADAIR: Move approval of Document No. 2019-839 DEBONE: Second VOTE: ADAIR: Yes DEBONE: Yes HENDERSON: Chair votes yes. Motion Carried 9. Consideration of Board Signature of Document No. 2019-847, Land Donation Agreement with the City of Redmond County Administrator Tom Anderson presented this item along with Property Manager James Lewis. DEBONE: Move approval of Document No. 2019-847 ADAIR: Second BOCC MEETING DECEMBER 18, 2019 PAGE 3 OF 8 VOTE: DEBONE: Yes ADAI R: Yes HENDERSON: Chair votes yes. Motion Carried 10.Department of Land Conservation and Development Technical Assistance Grant Award Tanya Saltzman, Community Development Department presented the grant award. Ms. Saltzman reported the scope of work will be drafted with the Oregon Department of Fish and Wildlife and bring to the Board for consideration. Community Development Director Nick Lelack stated when the grant award notification was received, DLCD recognized the leadership and work of Deschutes County was a factor of the award. 11.PUBLIC HEARING: Consideration of Signature of Board Order No. 2019- 048, Assigning the Name Nary Lane to a Public Road Peter Russell, Senior Transportation Planner, presented the Order for consideration and outlined the hearing procedure and provided the staff report. Commissioner Henderson opened the public hearing. Heidi Narver, property owner reported the name Nary Lane was chosen in honor of her deceased brother as Nary was his nickname. Mr. Russell explained the timelines and process of naming a public road. ADAIR: Move approval of Order No. 2019-048 DEBONE: Second VOTE: ADAIR: Yes DEBONE: Yes HENDERSON: Chair votes yes. Motion Carried BOCC MEETING DECEMBER 18, 2019 PAGE 4 OF 8 COMMISSIONER UPDATES • Commissioner Adair attended the Health Council meeting on Thursday and on Monday met the Sheriff's Office and District Attorney's Office regarding funding through criminal justice department. Commissioner Adair attended the Oregon Transportation Commissioner Workshop yesterday in Lebanon. • Commissioners Henderson and DeBone attended the Oregon Business Summit in Portland on Monday. • The Commissioners attended the Habitat for Humanity ribbon cutting event for Putney Place on Saturday. • Commissioner Henderson attended the 9-1-1 Executive Board meeting yesterday as well as a meeting on a proposed Veterans tiny home housing development. • Commissioner Henderson reported the warming shelter opening went well yesterday. Commissioner DeBone hopes for this process setting direction for an organization to take the responsibility of services for the future winter seasons. • County Administrator Anderson reported on a request for naming springs at Tumalo Creek and contract with Central Oregon Visitors Association calls for an annual report and should be scheduled in January. RECESS: At the time of 10:18 a.m. the Board went into recess to attend the Oregon Youth Challenge graduation ceremony at the Fair & Expo Center in Redmond and will reconvene at 2:00 p.m. RECONVENE: At the time of 2:02 p.m., Commissioner Henderson reconvened the meeting. The Commissioners attended the Oregon Youth Challenge Graduation ceremony during the recess. BOCC MEETING DECEMBER 18, 2019 PAGE 5 OF 8 OTHER ITEMs: Commissioner DeBone brought forward the meeting minutes from this morning's Consent Agenda. • Consent Agenda Item 6: Approval of Minutes of the December 2, 2019 BOCC Meeting • Consent Agenda Item 7: Approval of Minutes of the December 4, 2019 BOCC Meeting DEBONE: Move approval of Consent Agenda Items 6 and 7 ADAIR: Second VOTE: DEBONE: Yes ADAI R: Yes HENDERSON: Chair votes yes. Motion Carried 12.DELIBERATIONS: Lower Bridge Planned Development Community Development Department, Will Groves, presented the deliberations. The Commissioners considered the approval criteria on relevant topics. Staff will coordinate with counsel for the applicant and generate draft Findings and Decision for consideration and approval by the Board (prior to January 28). RECESS: At the time of 3:49 p.m. a recess was taken and the meeting was reconvened at 4:02 p.m. BOCC MEETING DECEMBER 18, 2019 PAGE 6 OF 8 13.Terrebonne Refinement Plan Discussion Commissioner Henderson reported on discussions with the Oregon Department of Transportation and on input received from the public. The most recent input from the Terrebonne community shows support for the interchange design option. Commissioner Henderson noted the strength of the timeline is in reviewing the appropriate design choice. Commissioner Adair reported on the discussions at the Oregon Transportation Commission Workshop yesterday. She expressed concerns for safety and the importance of maintaining the community of Terrebonne. Commissioner Adair supported the design interchange option 2 and somehow to place the 4 lanes up on the agenda to design Highway 97 correctly. Commissioner DeBone reported on traffic count data published October 2019. Commissioner Henderson is also in support of design interchange option 2. Commissioner DeBone spoke on the Terrebonne Community Plan and the documented resistance of a 5 lane option. Commissioner Adair recommending a plan to route visitors to Smith Rock to use an alternate route. An off -ramp was also considered for Highway 97. Peter Russell, Senior Transportation Planner, reported the Deschutes County transportation plan already has an interchange design in the planning document. The Board supported the ODOT Option 2 Interchange with additional safety enhancements. County Counsel Doyle suggested a document (Letter of Support) for the Board to consider at the BOCC Meeting on December 23, 2019. Commissioner Henderson recommended a citizen advisory committee. Commissioner DeBone stated Deschutes County was planning to provide funding for improvements. Commissioner Adair asks for safety improvements. Road Department Director Chris Doty confirmed that at some point in the process an Intergovernmental Agreement between ODOT and the County will come before the Board. HENDERSON: Move approval to draft a letter of support on the Terrebonne Road Improvements and Incorporate Option 2 with safety features. BOCC MEETING DECEMBER 18, 2019 PAGE 7 OF 8 ADAIR: Second VOTE: HENDERSON: ADAIR: DEBONE: Chair votes yes. Motion Carried Yes Yes Being no further items to come before the Board, the meeting was adjourned at 4:31 p.m. TTI A AI e VICE CHAIR ANTHONY DEBONE, COMMISSIONER BOCC MEETING DECEMBER 18, 2019 PAGE 8 OF 8 \)I ES COG Lv� ` 2-A o Deschutes County Board of Commissioners 1300 NW Wall St, Bend, OR 97703 (541) 388-6570 - www.deschutes.org BOCC MEETING AGENDA DESCHUTES COUNTY BOARD OF COMMISSIONERS 9:00 AM, WEDNESDAY, DECEMBER 18, 2019 Barnes Sawyer Rooms - Deschutes Services Center - 1300 NW Wall Street - Bend This meeting is open to the public, and allows 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. Item start times are estimated and subject to change 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 Consideration of Chair Signature of Document No. 2019-601, Amendment to Medcor, Inc. Services Contract 2012-622 Board of Commissioners BOCC Meeting Agenda Wednesday, December 18, 2019 Page 1 of 3 2. Consideration of Chair Signature of Document No. 2019-602, Amendment to Pharmacy Agreement with Premise Health 3. Consideration of Board Signature of Document No. 2019-762, Crisis and Transition Services Contract with Youth Villages 4. Consideration of Chair Signature of Document No. 2019-805, Oregon Health Authority Grant Agreement 5. Consideration of Board Signature of Reappointment of Mike Maier to the Deschutes County Budget Committees 6. Approval of Minutes of the December 2, 2019 BOCC Meeting 7. Approval of Minutes of the December 4, 2019 BOCC Meeting ACTION ITEMS 8. 9:10 AM Consideration of County Administrator Signature of Document No. 2019-839, Cohesive Strategy Coordinator Contract - Ed Keith, Forester 9. 9:25 AM Consideration of Board Signature of Document No. 2019-847, Land Donation Agreement with the City of Redmond - Tom Anderson, County Administrator 10. 9:45 AM Department of Land Conservation and Development Technical Assistance Grant Award - Tanya Saltzman, Associate Planner 11. 10:00 AM PUBLIC HEARING: Consideration of Signature of Board Order No. 2019-048 Assigning the Name Nary Lane to a Public Road - Peter Russell, Senior Planner RECESS: 10:15 am - 2:00 pm ACTION ITEMS Continued: RECONVENE 2:00 p.m. 12. 2:00 PM DELIBERATIONS: Lower Bridge Planned Development - William Groves, Senior Planner 13. 4:00 PM Terrebonne Refinement Plan Discussion Board of Commissioners BOCC Meeting Agenda Wednesday, December 18, 2019 Page 2 of 3 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. ADJOURN To watch this meeting on line, go to: www.deschutes.org/meetings Please note that the video will not show up until recording begins. You can also view past meetings on video by selecting the date shown on the website calendar. Deschutes County encourages persons with disabilities to participate in all programs and activities. This event/location is accessible to people with disabilities. If you need accommodations to make participation possible, please call (541) 617-4747. FUTURE MEETINGS: Additional meeting dates available at www.deschutes.org/meetingcalendar (Please note: Meeting dates and times are subject to change. All meetings take place in the Board of Commissioners' meeting rooms at 1300 NW Wall St., Bend, unless otherwise indicated. If you have questions regarding a meeting, please call 388-6572.) Board of Commissioners BOCC Meeting Agenda Wednesday, December 18, 2019 Page 3 of 3 E S CMG 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 BOCC Wednesday Meeting of December 18, 2019 DATE: December 12, 2019 FROM: Peter Russell, Community Development, 541-383-6718 TITLE OF AGENDA ITEM: PUBLIC HEARING: Consideration of Signature of Board Order No. 2019-048 Assigning the Name Nary Lane to a Public Road RECOMMENDATION & ACTION REQUESTED: Open hearing to receive public comment BACKGROUND AND POLICY IMPLICATIONS: Deschutes County Code (DCC) Chapter 16.16. governs the naming of roads. Heidi Narver, an adjacent property owner, submitted an application (247-19-000574-RN) to name a 30-foot- wide public road as Narv. The road would be used to access her property. Staff has approved the application and discussed the matter with the Board at a December 9 work session. Board Order 2019-048 and its exhibits implements the staff decision.. FISCAL IMPLICATIONS: None ATTENDANCE: Peter Russell, Senior Transportation Planner, CDD -A TO: Board of County Commissioners FROM: Peter Russell, Senior Transportation Planner DATE: December 12, 2019 RE: December 18 hearing on Board Order 2019-048, proposed road name of Nary Lane (file 247-19-000574-RN) Background Heidi Narver owns the property at 2965 Walker Road, aka County Assessor Map 17-14-34AA, Tax Lot 100. A 30-foot-wide public road runs along the property's eastern edge south of Walker Road for approximately 1,125 feet. Ms. Narver has safety concerns about using Walker as her driveway access and checking her mail. She would prefer to take her access from the unnamed public road along the property's eastern edge, which requires the public road be named. The Board held a work session on December 9 regarding the name, discussing the pros and cons. Staff decision Ms. Narver, in accordance with Deschutes County Code 16.16 (Road Naming), submitted an application (file 247-19-000574-RN) to name the public road. The Property Address Coordinator and staff reviewed the four proposed names and selected Narv. Under DCC 16.16.030(E)(2)(d) roads of reduced width shall be called lanes or terraces; staff selected lane. Staff queried the applicant for the reason for the name and Ms. Narver explained Nary was a family nickname and this name would be in tribute to her late brother. She also did not want her full last name used. As of this writing, staff has not received any written opposition or appeals on the proposed name from those who meet the requirements of DCC 16.16.030(B) and (G). The applicant has confirmed with staff her preference for the name Nary Lane. Under DCC 16.16.030(B) public comments on the proposed road name are limited to those owning property abutting the affected road or having an address on the affected road. Next steps The 10-day appeal period ended December 12 and DCC 16.16.030(I) requires the Board to hold a public hearing within 10 days of the appeal period's end. The December 18 public hearing for Board Order 2019-048, which implements the approval of Nary Lane under file 247-19-000574-RN, complies with the required timeline. 1 1 7 NW Lafayette Avenue, Bend, Oregon 97703 i P.O. Box 6005, Bend, OR 97708-6005 Q (541) 388-6575 @ cdd@deschutes.org @ www,deschutes.org/cd The Board will open the public hearing and receive any public testimony on Nary Lane. Staff is available for any questions. Enclosures: Board Order 2019-048 Board Order 2019-048 Exhibit A, Map showing Nary Lane Board Order 2019-048, Exhibit B, staff decision approving file 247-19-000574-RN (Nary Lane) Page 2 of 2 � e % \000 � `\CL | Li� cn JS3 a I 4 // I 0;" :3 V) V) ® E u C1J .ter �J V Vl u L to 0 > � > 1 Ln 0 QJ V) u ® E >� u (� QJ V1 > s- E > 0 E M L w r ��1 �' �; �; i, �; �:... �.w� Sharon Keith From: Chris Doty Sent: Wednesday, December 18, 2019 12:26 PM To: Sharon Keith Cc: Tom Anderson Subject: FW: Sale of Vactor to Deschutes County Attachments: Vactor - Intent to Purchase 12-17-19.docx SK The City put the wrong VIN number on the prior letter that Tom signed and they have asked that we sign a corrected letter. Could you get Tom's signature and send me a scanned copy at your convenience. Thanks! Chris Doty, PE I Director DESCHU ES COUNTY ROAD DEPARTRAENT 61150 SE 271h Street I Bend, Oregon 97702 Tel: (541) 322-7105 1 Fax: (541) 388-2719 1 Cell: (541) 279-1134 Email: Chris.Doty@deschutes.org Website: www.deschutes.org/road From: Randy McCulley <Randy.McCulley@deschutes.org> Sent: Wednesday, December 18, 2019 12:23 PM To: Chris Doty <Chris.Doty@deschutes.org> Subject: Fwd: Sale of Vactor to Deschutes County Get Outlook for Android From: Rick Albeck <ralbeck bendoreRon.gov> Sent: Wednesday, December 18, 2019 11:09:51 AM To: Randy McCulley <Randy.McCulley@deschutes.org> Subject: FW: Sale of Vactor to Deschutes County [EXTERNAL EMAIL] Randy, Here's the updated letter with the correct equip/VIN. Please have it signed and return to me ... thanks! Rick Albeck I Fleet Director 0: 541-317-3023 1 M: 541-550-6481 CITY OF BEND �� �� ( J ,I �t —4/ 7.. From: Brenda Mingus <bmingus@bendoregon.gov> Sent: Wednesday, December 18, 2019 11:01 AM To: Rick Albeck <ra I beck@ bendoregon_gov>; Gwen Chapman <gchapman@bendoregon.goy> Cc: Elizabeth Oshel <eoshel@bendore, .gov> Subject: Sale of Vactor to Deschutes County Rick and Gwen, See attached revised Letter of Intent which identifies the correct vehicle. Brenda Mingus I Legal & Risk Program Manager O 541-693 2129 F 541-385-6676 F., CITY" OF BLIND PUBLIC RECORDS LAW DISCLOSURE: Emails are generally public records and therefore subject to public disclosure unless exempt from disclosure under Oregon Public Records Law. Emails can be sent inadvertently to unintended recipients and contain confidential or privileged information. If you are not the intended recipient (or authorized to receive for the recipient), please advise by return email and delete immediately without reading or forwarding to others. Thank you. LETTER OF INTENT TO PURCHASE This Letter of Intent to Purchase, effective December 10, 2019, is between the City of Bend, and Oregon municipal corporation (City), and Deschutes County, a political subdivision of the State of Oregon (County). 1. City owns a vacuum -style excavation unit used to clean sewers, vehicle identification no. 2FZAAWDCX4AN009325, known in the City's records as equipment no. 1302 ("Vactor 1302"). 2. Vactor 1302 is surplus to the City's needs, the City having replaced Vactor 1302 with a new vacuum -style excavation unit. 3. City wishes to sell, pursuant to Bend Municipal Code 1.55.090.F, and County wishes to purchase Vactor 1302 from the City, upon the approval of the County budget for fiscal year 2020. County budget approval is anticipated to occur on or before July 1, 2020. 4. Prior to such budget approval, the parties wish for County to lease Vactor 1302 from City, on terms established in a separate lease agreement. 5. County will pay to City $100,000.00 on or before July 15, 2020, as final payment for Vactor 1302. If the County does not approve funds for this purchase in its fiscal year 2020 budget, no sale will occur, and City may sell Vactor 1302 to any other entity it wishes, subject to the terms of any lease agreement between the parties for Vactor 1302. 6. County will take possession of Vactor 1302 when funds for the full purchase price are received by City. 7. City will provide County with title to Vactor 1302 when funds for the full purchase price are received by City. 8. The terms in this Letter are an outline of the agreement for sale of Vactor 1302 between City and County. The terms in this Letter are not comprehensive and the parties may add additional terms and/or change or delete existing terms. These terms do not create a binding agreement between City and County and will not be enforceable. Only the lease agreement and any future sale agreement, executed by City and County, will be enforceable. The terms and conditions of any future sale agreement will supersede any terms and conditions in this Letter. 9. This Letter of Intent replaces the letter of Intent dated December 10, 2019, which identified the wrong vehicle. Name: Eric King, City Manager Title: City of Bend Deschutes County Date: Date: Page 1 of 1 - LETTER OF INTENT TO PURCHASE BUT E S CO o ` 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 BOCC Wednesday Meeting of December 18, 2019 DATE: December 11, 2019 FROM: Tanya Saltzman, Community Development, TITLE OF AGENDA ITEM: Department of Land Conservation and Development Technical Assistance Grant Award Overview of DLCD Technical Assistance (TA) Grant Award, which provides a basis for evaluating rural growth and development through a multi -faceted lens, taking into consideration its effect on resource lands, wildlife, natural hazards, economic development, housing, transportation, public facilities, and rural communities. MEMORANDUM TO: Deschutes County Board of Commissioners FROM: Nick Lelack, AICP, Director Peter Gutowsky, AICP, Planning Manager Tanya Saltzman, AICP, Associate Planner DATE: December 12, 2019 SUBJECT: Department of Land Conservation and Development / Technical Assistance Grant Award On December 2, 2019, the Department of Land Conservation and Development (DLCD) notified Deschutes County that it received an 18-month $25,000 Technical Assistance (TA) Grant to: 1) incorporate Wildfire Mitigation Advisory Committee recommendations into the Comprehensive Plan and development code; and 2) begin updating Goal 5 wildlife habitat inventories (Attachment 1). This award provides assistance for two of the four goals submitted by the County in the grant application. Staff requests Board of County Commissioners support to begin drafting a scope of work and grant contract that will be reviewed by the Board in January. I. TA Grant Application On September 30, 2019, the Board finalized a DLCD TA Grant Application that provides a basis for evaluating rural growth and development through a multi -faceted lens, taking into consideration its effect on resource lands, wildlife, natural hazards, economic development, housing, transportation, public facilities, and rural communities.' Staff structured the grant application so that it would give Deschutes County the resources to evaluate land use interrelationships as part of a Comprehensive Plan update, Deschutes County 2040. County staff could then engage residents and stakeholders in a separate, multi -year public process to update the Comprehensive Plan holistically. As noted in the grant application, Deschutes County is undertaking several keystone projects that provide the foundation for a formal update to the Comprehensive Plan. They include: • Bend Airport Master Plan refinement • Day Care and Nursey amendments • Flood Plain Zone amendments • Historic Inventory update • Housing Strategies Report • Religious institution amendments • Terrebonne sewer feasibility study • Transportation System Plan update • Wildfire Mitigation Advisory Committee 1 See Action Item #6. http://deschutescountyor igm2.com/Citizens/FileOpen.aspx?Tvpe=1&ID=2152&lnline=True The TA Grant proposed leveraging in -kind and reserve funds to elevate the following four projects: Housing Strategies Report Convene a Housing Strategies Committee to understand housing conditions and opportunities. This will lead to the development of a housing report of existing conditions for unincorporated areas, including housing supply, rural vacant residential lands analysis, and estimated housing need. Staff will then develop goals and policies, as well as financial, regulatory, and county -land ownership strategies based on the Housing Report that inform amendments to the Comprehensive Plan (Chapter 3 — Rural Growth Management and Chapter 4 — Urban Growth Management). Finally, staff will create an implementation plan, including development code amendments, partnerships with cities, housing organizations, and others to create and/or preserve affordable and other needed housing. Terrebonne Sewer Feasibility Study Develop a wastewater feasibility study and engage Terrebonne residents in a process to evaluate wastewater systems and costs to protect public health and water quality and select a preferred alternative. The study may require updating the Terrebonne Community Plan (Comprehensive Plan Chapter 4 — Urban Growth Management) and revising the development code (DCC Title 18.66). Lastly, this experience could lead to the development of an implementation guide for other communities, e.g., Tumalo, and/or clusters of property owners in the county. Updating Wildlife Inventories Evaluate new wildlife inventories from the Oregon Department of Fish and Wildlife (ODFW) to implement the procedures and requirements for complying with Goal 5 (OAR 660, Division 23). This will entail engaging ODFW and a DLCD Goal 5 Coordinator to mutually understand the methodology of the agency's updated wildlife inventories, conflicting uses and the range of options for protecting wildlife habitat. Staff proposes to develop wildlife protection scenarios that could be incorporated into an Economic, Social, Environmental, and Energy (ESEE) analysis and ultimately, the Comprehensive Plan and development code. An implementation plan would be created, identifying work tasks to be initiated after the TA grant, including budget, timeline, community engagement, ESEE Analysis, amendments to the comprehensive plan and development codes, and a post acknowledge plan amendment (PAPA). Wildfire Mitigation Advisory Committee (WMAC) Following the WMAC's process and recommendations in early 2020, initiate a community involvement plan to inform the public on the recommendations to reduce losses from wildfires in the county. Based on public input, staff will develop goals and policies for the Comprehensive Plan (Chapter 3 Rural Growth Management - Section 3.5 Natural Hazards) and amendments to the Comprehensive Plan Map, Zoning Map, and development code to reflect an updated Wildfire Hazard Zone map. 11. TA Grant Award DLCD informed staff early in the grant application process that the two year, 2019-2021 TA grant cycle was anticipated to be the most competitive TA grant to date largely due to funding commitments to municipalities -2- to implement HB 2001.2 Despite this challenge, DLCD notified Deschutes County on December 2 that it will receive a partial state grant of $25,000 for two elements of our application proposal: incorporating Wildfire Mitigation Advisory Committee recommendations into the Comprehensive Plan and development code ($10,000 with County in -kind match of $10,000) and updating Goal 5 wildlife habitat inventories ($15,000 with County in -kind match of $25,000). III. Developing a Scope of Work With the Board's support, staff will begin drafting a scope of work and grant contract to be reviewed and signed by our DLCD regional representative, after which point reimbursable work may begin. As outlined in the grant application, the scope of work for both tasks will include a combination of data collection, consultant work (which may encompass technical analysis as well as public facilitation), community meetings throughout the county over the course of the summer and fall, inter -agency coordination, drafting of Comprehensive Plan and development code changes, and coordination with the Deschutes County Planning Commission and Board. IV. Next Steps Staff expects to coordinate internally as well as conduct scoping meetings with DLCD and ODFW to develop a detailed scope of work for discussion with the Board in January. Upon Board approval, staff with work with DLCD to complete the grant contract and begin work. Attachment 1. DLCD TA Grant Award Letter 2 HB 2001 requires cities with populations between 10,000 and 25,000 to allow duplexes on any lot zoned for single-family dwellings. In addition, in cities with populations over 25,000, the bill mandates that local governments allow multi -family development up to quadplexes in any areas zoned for single-family dwellings. The smaller cities must make these zoning changes by June 30, 2021, and the larger cities must make these zoning changes by June 30, 2022 -3- OF O tJregon Kate Brown, Govenor December 2, 2019 Department of Land Conservation and Development 635 Capitol Street NE, Suite 150 Salem, Oregon 97301-2540 Nick Lelack, Community Development Director Deschutes County SENT VIA E-MAIL 117 NW Lafayette Avenue PO Box 6005 Bend, Oregon 97708 RE: Notice of DLCD Technical Assistance grant award Dear Nick Lelack: Phone: 503-373-0050 Fax: 503-378-5518 www.oregon.gov/LCD (W) I am very pleased to offer Deschutes County a Technical Assistance grant award for 2019-2021. Your application was selected from among 48 proposals submitted to the Department of Land Conservation and Development for this biennium. Your proposal aligns well with the priorities established in the Land Conservation and Development Commission's Grants Allocation Plan and other approval criteria. The department is prepared to fund the Comprehensive Plan Update, Deschutes County 2040 project for $25,000 toward the following two components of the grant application proposal: • Goal 1 — Incorporate Wildfire Mitigation Advisory Committee (WMAC) recommendations into the Comprehensive Plan and development code - $10,000 • Goal 4 — Coordinate with the Oregon Department of Fish and Wildlife (ODFW) to begin updating the County's Goal 5 wildlife inventories - $15,000 Please work with your DLCD regional representative to complete a scope of work and grant contract. Once a grant contract is signed by both parties, reimbursable work on the project may begin. Oregon's current budget provides funding to support the Technical Assistance grant program. Please note, however, in the event of a significant change in state revenue we may be required to limit a portion of the grant award. If you have any questions about the award, please contact Scott Edelman, your DLCD regional representative, at (541) 306-8530 or scott.edelmankstate.or.us, or me at (503) 934-0034 or gordon.howardk state. or.us. Thanks for your interest, and compliments on your successful application. We look forward to working with you on the project. Yours truly, Gordon Howard Community Services Division Manager TA Grant Award (2019-2021) December 2, 2019 Page 2 of 2 cc: Senator Tim Knopp Senator Cliff Bentz Senator Dennis Linthicum Representative Cheri Helt Representative Jack Zika Representative Daniel Bonham Representative Vikki Breese Iverson Annette Liebe, Regional Solutions Team Coordinator Scott Edelman, DLCD Regional Representative Angela Williamson, DLCD Grants Administrative Specialist pF r, �7 �►Oregon •.i899 .-�Kali•Dro�,r. Co�crr.,: December 17, 2019 Deschutes County Board of Commissioners 1300 NW Wall Street, 2"d Floor Bend, Oregon 97703 Jefferson County Board of Commissioners 66 SE D Street Suite A Madras, Oregon 97741 Department of Transportation RE: Recommendations on the US 97 Terrebonne Refinement Plan Deschutes County and Jefferson County Commissioners, Region Manager 63055 N. Hwy 97 Bldg. K Bend, Oregon 97703 Phone: (541) 388-6252 On behalf of ODOT I thank you for partnering with us on development of a US 97 Refinement Plan for the Terrebonne / Lower Bridge Way area. In the spirit of our partnership, I recommend we draw to a close on the Refinement Planning work, and begin taking action toward implementation of transportation improvements for the area. Within this Planning effort, I appreciate the very many who have worked long and hard on the issues, gaining perspectives, providing input, and adding ideas which have been incorporated. I acknowledge the Advisory Committee, School District, Deschutes County Planning Commission, Crooked River Ranch C&MA Board of Directors, and many others who have recommended Couplet adoption into the TSP. I also fully recognize, understand, and appreciate the fact that many within Terrebonne are opposed to the proposed Couplet adoption, especially given their hard work to make sure concerns and impacts are shared and well understood, reinforcing the point that full consensus among all stakeholders has not been achieved. Given the fact that we have not been able to reach full public consensus, I also recognize and appreciate how complex and challenging the decision making is, particularly for Deschutes County in support of their variously affected constituents. To this end, here are my specific recommended options: December 16, 2019 Deschutes County & Jefferson County BOC's Page 2 of 3 Option 1 Deschutes County adopt the Couplet into the TSP, per the Draft Findings to Amend Deschutes County Transportation System Plan to Add U.S. 97 Couplet in Terrebonne, and move we forward with design and construction phases accordingly. As I have communicated with each of you, I believe this is the best option, all things considered including the most current public involvement, direction provided in the current Deschutes County TSP for Terrebonne, and direction provided in the Terrebonne Community Plan. Option 2 If the Deschutes County Board as a whole is not ready to support Couplet adoption into the TSP, my recommendation is to defer any decisions on amendments to the TSP at this time, and for the benefit of all parties I would fully support moving forward with the following: - Interchange. In reference to page 165 of the Deschutes County TSP (The intersection of Lower Bridge Way/US 97 will have either a simple overpass or a grade -separated interchange), design and construct a grade -separated interchange to serve the intersection of US 97 and Lower Bridge Way/S 1111 Street. Per the TSP, this design will be based on the goals and objectives of the adopted Terrebonne Community Plan, the goals and objectives of the Oregon Highway Plan, and additional public input and outreach; while minimizing property impacts, minimizing HB 2017 funding related costs, and allowing for adaptability to all long-term options and future decisions for US 97 in Terrebonne. The cost range is—$12-14 Million for the interchange (see Enclosed concept drawing). Safety Improvements. Analyze, Propose, Design, and Construct additional improvements within Terrebonne that address safe speeds, access, circulation, and pedestrian needs (per TSP and Terrebonne Community Plan expectations), such as Rapid Flashing Beacon for pedestrian crossing, U-turn options, 11th Street upgrades and other circulation -related local road improvements, curb and sidewalk infill, and curb extensions at intersections for pedestrian safety. Such improvements would be a very important safety complement to the interchange, and will be based on the Refinement Planning goals and objectives, as well as the goals and objectives of the adopted Terrebonne Community Plan, the goals and objectives of the Oregon Highway Plan, and additional public input and outreach; while allowing for adaptability of all long-term options and future decisions for US 97 in Terrebonne. The Design would be closely coordinated and timed with the Interchange Construction in —2021-2022 for maximized efficiency and minimized impacts, and for coordination and consideration of appropriate uses of HB 2017 funding and any potential County funding. December 16, 2019 Deschutes County & Jefferson County BOC's Page 3 of 3 Let me reassure you that we at ODOT will continue comprehensive and transparent public involvement with decision -making during the project development and construction phases of this effort, in partnership with both Deschutes County and Jefferson County. This will include addressing safe and reasonable access, circulation, and parking needs, as well as other viability impacts and needs for properties, businesses, and utilities. I would very much appreciate receiving a response from both of you (each Board) on these recommended options, including how you would like to proceed, by early in January 2020. This will allow us to proceed on the expected schedule for HB 2017 funding. In the meantime, please let me know if you have follow-up questions or need for additional information, or if you would like to meet in a joint work session to address my recommendations. Again, I would like to thank you for partnering with us on this refinement plan, and for the long standing relationship of collaboration we have maintained among our three jurisdictions over many years. Re a tfully, Ga arnsworth O T Region 4 Manager Deschutes County & Jefferson County BOC's ENCLOSURE - Interchange Only Concept* hip d .r u M f 4� us 97 - DaWs Cali roa Hw1't, 14 , t St ! *Concept Drawing represents traffic movement and general configuration. Specific interchange location, access points, sidewalk infill, and lane layouts to be determined during design. Traffic count data per ODOT's 2018 Transportation Volume Tables Published October 2019 US 97 at Jefferson County line 13,200 US 97 in Terrebonne: 17,900 vehicles per day US 97 in La Pine: 9,900 at First Street US 20 in Sisters: 12,300 to 15,200 in city limits US 20 in Tumalo: 13,600 US 20 West of Bend: 9,300 ES CMG � Z Deschutes County Board of Commissioners raaru 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 BOCC Wednesday Meeting of December 18, 2019 DATE: December 13, 2019 FROM: William Groves, Community Development, 541-388-6518 TITLE OF AGENDA ITEM: DELIBERATIONS: Lower Bridge Planned Development BACKGROUND AND POLICY IMPLICATIONS: The Board will conduct deliberations for the Lower Bridge Planned Development on December 18, 2019. Staff will conduct a work session to orient the Board to anticipated topics for Board deliberations. FISCAL IMPLICATIONS: None. ATTENDANCE: Will Groves, Legal. STAFF MEMORANDUM Date: November 2, 2019 To: Board of County Commissioners From: Will Groves, Senior Planner Re: Deliberation - Appeal of Hearings Officer Decision (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) The Board of County Commissioners (Board) will conduct deliberations on December 18, 2019, at 1:00 PM, on appeals of a Hearings Officer's decision denying a conditional use, tentative subdivision plan, and Surface Mining Impact Area ("SMIA") site plan review. 1. Application The Applicant requested conditional use, tentative subdivision plan, and SMIA site plan approval to establish a 19-lot residential planned unit development ("PUD") on the Subject Property. The residential lots would range in size from 2 to 5 acres, would comprise a total of 42.5 acres, and would have access from Lower Bridge Way via private roads. The subdivision would include 2 common area tracts comprising 0.9 acres, 5 open space tracts comprising 94.1 acres, 4.4 acres of private road, and 2.8 acres of right-of-way dedication for the abutting segment of Lower Bridge Way. No development is proposed to occur within the Flood Plain Zone of the Deschutes River Canyon area. The present application is significantly similar to a 2015 application denied by a Hearings Officer and withdrawn by the Applicant before the Board. This is referred to as the "2015 decision". II. Decision The Hearings Officer denied the application and the decision was mailed on September 24, 2019. The Hearing Officer's decision quoted extensively from the 2015 decision. The 2019 application was denied because: 117 NW Lafayette Avenue, Bend, Oregon 97703 1 P.O. Box 6005, Bend, OR 97708-6005 � (541) 388-6575 @cdd@deschutes.org @ www.deschutes.org/cd • The Applicant did not provide required proof that sufficient financing exists to assure the proposed development will be substantially completed within four years of approval. • The Applicant had requested to impermissibly defer compatibility analysis with two adjacent, non -active surface mines. The 2019 denial differed from the 2015 denial in several important ways. • It reevaluated the code provisions relating to including Flood Plain zoned lands in a PUD and concluded that this was permissible. Additionally, the 2019 decision found that Flood Plain zoned lands could be included in lot density calculations for the PUD. • It found that compliance with rimrock setbacks could be made conditions of the approval. • It found that the lot sizes were adequate for the proposed residential use, given applicable setbacks and other constraints. • It found potential dust impacts from adjacent Surface Mining zoned properties could be addressed through a condition of approval. • It found that environmental concerns raised by the mine's long history were adequately addressed, for the purposes of this PUD, through recent Department of Environmental Quality and Oregon Health Authority letters. III. 150-day Issuance of a Final Local Decision The 150-day period for issuance of a final local decision is currently January 28, 2020. IV. Appeal The Applicant filed an appeal of the Hearings Officer's decision concerning both reasons for denial, listed above. Calfa Holdings, LLC appealed the Hearings Officer's decision for the following reasons: • The Hearings Officer erred in concluding that Flood Plain zoned areas can be used as open space tracts in a PUD subdivision. This has authorized a density transfer to the upland portions of any PUD or cluster development using flood plain zoned land. File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 2 of 20 This decision has circumvented the County's requirement to perform an economic, social, energy and environmental ("ESEE") analysis, consistent with Goal 5, which the County had in fact done in the preliminary stages of the 2019 legislative process. • The minimum lot size for Flood Plain Zone has not been met in this case. The required minimum lot size is 80 acres for "areas which have not received an exception to the Statewide Planning Goals" for resource uses. The Flood Plain Zone portion of this subject property is Surface Mine Designated and has not received an exception to resource goals (Goals 3 and 4). • The Hearings Officer erred in concluding that the applicant can defer until building permit stage to show that Landscape Management Zone rimrock setbacks of 50 feet will be met. III. KEY ISSUES The Board will likely be asked to deliberate and decide on the several matters. This deliberation summary of party positions is largely composed of direct quotes from record materials. Some quotes have been edited for brevity, clarity, or issue focus. 1. Is a Planned Development application allowed in the Flood Plain zone? Issue Summary: This application includes the creation of open space lots in the Flood Plain (FP) Zone, where "Planned Development" ("PUD") is not one of the listed uses. The proposed use of FP zoned lands is the creation of lots through subdivision for the preservation of open space, as part of a PUD. "Subdivision" is an allowed use in the zone. The 2015 and 2019 Hearings Officers disagreed on this question. 2015 Hearings Officer: "Neither "cluster development" nor "planned development" is a use permitted outright or conditionally in the FP Zone. The Hearings Officer finds the text and context of the provisions of Title 18 defining and governing the three types of subdivisions make clear they have different characteristics and are intended to be reviewed and approved under different substantive standards. While it may seem counterintuitive not to permit use of FP -zoned land for open space within a planned development where such use would protect these areas consistent with the purpose of the FP Zone, I find the plain language of the FP Zone does not allow such development." Calfa Holdings: ... nowhere in the Code does it state that PUD or cluster developments are allowed. A PUD is wholly different from a standard subdivision, which has its own approval criteria and process. The fact that "subdividing" land is permitted in the flood plain zone does not mean PUDs are permitted. Applying general principles of legal interpretation, one must necessarily conclude that the Code's omission of "PUD" or "cluster" subdivision from the conditionally permitted use table is illustrative and diapositive as to whether flood plain areas within PUDs can be used as open space. Similarly, the Code's express inclusion of the separately and clearly defined File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 3 of 20 "subdividing" of land, which is wholly distinct from PUDs, is illustrative and dispositive as to whether flood plain areas within PUDs can be used as open space. 2019 Hearings Officer: "The Hearings Officer disagrees with the 2015 Land Use Decision comment that "I find the plain language of the FP Zone does not allow such a development" referring to a "cluster" and/or a "planned" development. The Hearings Officer, in this case, believes the language used in DCC 18.96.040 is clear, plain and unambiguous. The 2015 Land Use Decision findings for DCC 18.96.040 characterizes "cluster developments" and "planned developments "as something separate and distinct from the act of subdividing. This Hearings Officer, in this case, finds that "cluster developments" and "planned developments" are subdivisions. Applicant Final Argument: Staff notes that the Applicant agrees with the 2019 Hearings Officer decision and has included the following additional argument. The record shows the Flood Plain zone was adopted based on the Flood Insurance Study maps for Deschutes County prepared by FEMA and the subject property is located within Zone A on the Flood Insurance Rate Map ("FIRM") map. The record further shows a cluster subdivision like the one proposed in the present case is consistent with the FEMA Guidelines for development within a Zone A area. 2. is open space associated for a planned development permitted outright in the FP zone? Issue Summary: Planned Developments are required to have sixty-five percent open space. The Applicant has proposed to use FP zoned lands as part of the open space acreage. "Open space" is an outright use in the FP zone. Generally, proponents and the 2019 Hearings Officer argue that PUDs are allowed conditionally in the FP zone and that the outright use of "open space" is further evidence of the code's allowance for the PUDs with open space in the flood plain. Generally, opponents and the 2015 Hearings Officer argue that the proposed use is PUD and that the outright use "open space" is irrelevant. 2015 Hearings Officer: The Hearings Officer finds that although "open space" is listed as an outright permitted use in the FP Zone, and the proposed CC&Rs provide protection for such areas consistent with the purpose of the FP Zone, the applicant's proposed open space is not a stand-alone use. Rather, it consists of open space lots and uses within a PUD which is not a use permitted outright in the FP Zone. In other words, the open space use is dependent upon the rest of the PUD use. Calfa Holdings: Although "open space" is an outright permitted use in the flood plain zone, "open space" within a PUD is not. A PUD or cluster subdivision is not an outright permitted or conditionally permitted use in the flood plain zone, and thus, by the Code's plain language, using flood plain zoned land within a PUD or cluster subdivision as open space is not permitted. File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 4 of 20 ...this Board is now in the position to set the policy for the County going forward. The Board should be analyzing this issue not just in the context of this present case, but all future decisions going forward. Deschutes County Code § 18.96.040 provides that "open space" is an outright permitted use in the flood plain zone. But neither PUD nor cluster subdivisions are outright permitted or conditionally permitted uses in the flood plain zone. See DCC 18.96.030-.040. The 'open space" being applied in this context is within a PUD, and if a PUD cannot be permitted in the flood plain zone, then the open space within that PUD cannot be permitted either. Friends of Lower Bridger ("FOLB") Rebuttal: Section 18.96.030 defines "open space." It states clearly that it must be "preserved and continued in its present use." Applicant claims that by using Flood Plain land as "open space" this standard is not violated. Yet Open Space in a Cluster Development is intended to be communal land, used in replacement for what would otherwise be individualized large tracts compatible with surrounding uses. This land is heavily used already, just not by humans. Flood Plain land is very rare in our climate and elevation. It is properly preserved, not "double counted" so the application for more homes can be approved. 2019 Hearings Officer: DCC 18.96.030 lists the uses permitted outright in the Flood Plain zone. One of those uses is "Open Space". The Hearings Officer in this case finds that Tracts C and E would meet the definition of Open Space because the Tracts would be "preserved and continued in its [their] present use" and would conserve and enhance natural resources, would protect streams, promote conservation of wetlands and enhance recreation opportunities. Applicant Final Argument (Hearings Officer): Staff notes that the Applicant agrees with the 2019 Hearings Officer decision and has included the following additional argument. The Flood Plain Zone is the only zone in the County where "open space" is a listed use. Because property owners typically do not seek or need a permit to leave or conserve land in its present use, the drafters must have intended to allow "open space" associated with some other use when they included this as a specifically listed use in the Flood Plain Zone. 3. Does the FP zoned land count towards PUD housing density and density bonuses? Issue Summarv: Planned Developments use an "equivalent overall density factor" rather than a minimum lot size. This affords a housing density bonus from one unit per 10 acres to one unit per 7.5 acres in the Rural Residential 10 ("RR10") zone, increasing the number of allowed units in the development. Unlike the RR10 zone, no density bonus is included in the FP lot size standards. The PUD proposal relies on RR10 and FP zoned land together for the density calculation to allow for 19 residential lots. File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 5 of 20 2015 Hearings Officer: "The Hearings Officer has found the proposed PUD is not a use permitted outright or conditionally in that zone. Therefore, I find the approximately 30 acres of FP -zoned land included in the subject property cannot be included in the density calculation." 2019 Hearings Officer: The Hearings Officer, in this case ... determined that the area designated Open Space including area with the Flood Plan Zone, should be included in the computation of the PUD acreage. Staff understands the Hearings Officer to reason that, since open space is allowed in the FP zone and since open space is a required component of a PUD, that the density calculation should be performed against the whole PUD, including the FP zoned lands proposed for open space use, and the RR10 zoned lands proposed for lot development and open space use. Calfa Holdings: ... the Hearings Officer's purported reliance on the definition of "open space," which is land "that would, if preserved and continued in its present use enhance natural or scenic resources," is misguided. By definition, the flood plain zoned lands being used as "open space" within the PUD are not being "continued in its present use'; there is now increased density directly adjacent to those lands. The definition of "open space" does not provide any express authority for flood plain zoned lands to be used as open space in a PUD, nor does actual, practical impacts of that interpretation comport with the Code's limited definition of "open space." Applicant Final Argument: Staff notes that the Applicant agrees with the 2019 Hearings Officer decision and has included the following additional arguments. Open space is a listed use in the Flood Plan Zone and the listing of open space as a use allowed in that zone means open space associated with a planned development in an adjacent zone. The County has historically allowed Flood Plain zoned acreage to be included as open space in cluster and planned developments. The County Code expressly allows for gross area calculations to determine density and lot sizes. The idea that the Applicant is supposed to subtract the Flood Plain zoned land from the project area calculations for purposes of determining density or lot sizes is not supported by the County Code or historical practice. 4. Does sufficient financing exist to assure the proposed development will be substantially completed within four years of approval? Issue summary: The Planned Development code requires a demonstration of existing financing to complete the project, as proposed. The applicant had not provided detailed cost or financial information until the current hearing before the Board. File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 6 of 20 2015 Hearings Officer: "The applicant did not submit any evidence supporting this statement. The Hearings Officer finds a simple conclusory statement does not constitute sufficient evidence to demonstrate compliance with this conditional use approval criterion." 2019 Hearings Officer: "The Hearings Officer finds this criterion is not satisfied by the simple statement that "the applicant has the financial resources and demonstrated capacity to complete the development." The Hearings Officer finds Applicant must provide something more that such a conclusionary statement." FOLB Rebuttal: FOLB makes extensive arguments in their rebuttal submittal dated November 13, 2019 that the sufficient financing issue has not been sufficiently resolved. Staff summarizes these as follows: • Applicant's cost estimates do not address additional environmental concerns raised by FOLB. • How Applicant can be flush with cash in a money market account, but require approval of the east side development to fund the west side? Both cannot be true. • "Applicant" is Lower Bridge Road, LLC. However, "Applicant" is not the signer of the application or holder of the money market account offered as assurance of financial stability to complete the proposed project in 4 years. It is critical to determine who owns the property, who controls the property, and what financial means are available to the Applicant itself. • FLOB describes a number of lawsuits directed at members of the development team. [A] suit, if successful, will wipe out the money market fund offered for financial security of the project. Thus, with one event, the feasibility of this project is destroyed. Applicant Final Argument: The Applicant submitted a cost estimate prepared by a registered civil engineer to complete the subdivision, including both soft and hard costs and a 10% contingency. The Applicant also submitted a letter from the CFO of Realvest as the entity responsible for financing the project together with a money market statement, demonstrating funds sufficient to and committed to building the project. Finally, in response to opponents evidence of past bankruptcy filings, the Applicant submitted evidence demonstrating the Realvest Chapter 11 Plan for reorganization was accepted and was fully completed in 2010. 5. Has the Flood Plain zoned land received an exception to the resource use acreage standards? (Goal 3) Issue summary: Minimum lot sizes in resourced zoned lands are 80 acres, with certain exceptions, as part of the State Goal 3 program to preserve and protect farm uses. The Flood Plain zone, accordingly, has a minimum lot size of 80 acres, where land has not "received an exception to the Statewide Planning Goals for resource uses". Flood Plain zoned lands that have received an exception have a minimum lot size of 10 acres. File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 7 of 20 On the subject property, the Flood Plain zone holds a "Surface Mining" comprehensive plan designation. Does that designation count as an exception? 2015 Hearings Officer: "The Board's 2008 plan amendment and zone change decision did not include any FP -zoned land. Because the FP Zone was not modified and it is not considered a "resource" zone, the Hearings Officer finds no goal exception was or is required, and therefore the creation of new lots in the FP -zoned portions of property is subject to a 10-acre minimum lot size." 2019 Hearings Officer: "The Hearings Officer finds that no Goal 5 exception is required in this case and therefore the minimum lot size is ten (10) acres." Staff Comment: It appears that the 2019 Hearings Officer did not directly address "resource use" and Goal 3. Calfa Holdings: The Hearings Officer erred in finding that the minimum lot size for flood plain zone has been met in this case. DCC 18.96.110(C) requires a minimum lot size of 80 acres for "areas which have not received an exception to the Statewide Planning Goals" for resource uses. Specifically, the flood plain zoned portion of this property has not received an exception to resource goals (Goals 3 and 4). LanclWatch: The Hearing Officer misinterpreted and misapplied the code by not applying the 80-acre minimum lot size where no exception has been taken to the statewide planning goals. DCC 18.96.110(C). The provision implements the County's Program to Achieve Goal 5 for riparian areas and wetlands in Ordinance No. 94-007, which requires a minimum lot size of 80 acres for Flood Plain -zoned properties in order to prevent an "increase in density of residential lots in or adjacent to riparian areas" that "could result in a decrease of habitat effectiveness because of disturbance to wildlife." Applicant Final Argument: Opponents argue the minimum lot size for parcels on the Flood Plain zone is 80 acres, not 10 acres, because the subject property did not receive an exception to the Statewide Planning Goals for resource uses. The record shows the subject property was rezoned from Surface Mining to RR-10 in 2008 through the non -resource designation process, which is an alternative method to the goal exception process. That 2008 Zone Change Decision concluded there are no Goal 3, 4 or 5 resources on the subject property and is the equivalent of a goal exception. The County Flood Plain zone was drafted and historically applied as if it were an overlay or combining zone. This minimum lot size provision was adopted to allow 10 acre minimum lot sizes in FP zoned areas combined with, or in this case split -zoned with, County exception lands (RR-10, SR 2 1/2, MUA-10) and 80 acre minimum lot sizes in FP zoned areas combined with County resource lands (EFU, Forest). Because the subject property received a nonresource zone change in 2008 and that decision specifically found there to be no Goal 3, 4 or 5 resources on the subject property, the 10 acre minimum lot size applies to the Flood Plain zoned portions of the property. File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 8 of 20 6. Has the environmental history at the mine been adequately addressed and resolved? Issue Summary: The subject property consists primarily of that portion of the former Oremite mine site east of Lower Bridge Road. This 113-acre area was previously used primarily for aggregate mining and hot -mix asphalt plant operations. Diatomite mining and processing was conducted primarily on an adjacent larger property on the west side of Lower Bridge Road. 2019 Hearings Officer: The Hearings Officer finds the DEQ and OHA are State agencies that possess technical and scientific expertise in matters relating to the environment including, but not limited to ground, water and air pollution/contamination. The Hearings Officer finds Applicant participated in the DEQ's VCP and the OHA review processes. The Hearings Officer finds the DEQ process is a public process and that opponents of this application had the right to participate. The Hearings Officer that the DEQ and OHA determinations should be considered "expert" evidence in this case. The Hearings Officer finds, based upon the evidence in the record of this case (which supplements evidence that was in the record of the 2015 Land Use Decision) that the Applicant has demonstrated that the Subject Property is suitable for the proposed residential PUD considering man-made and natural hazards. Specifically, the Hearings Officer finds that Applicant, through [DEQ and OHA determinations, Geotechnical/groundwater reports, and 2015 DEQ reports] have demonstrated that environmental clean-up activities at the Subject Property have been completed and the Subject Property "environmental conditions are currently protective of public health". FOLB Open Record: The Department of Environmental Quality No Further Action ("NFA") letter before the Board excludes the west 30 acres. Applicant requires the west 30 acres be included in this tentative plan to meet required open space. Since not all the land being "used" is released pursuant to the NFA, this condition is not met. The OHA letter is based on the NFA letter. Since the No Further Action Letter from DEQ doesn't release the 30 acres from environmental contamination concerns, the OHA letter cannot make findings of "No Apparent Health Hazard" either. FOLB Rebuttal: FOLB makes extensive arguments in their rebuttal submittal dated November 13, 2019 that the environmental contamination issues have not been sufficiently resolved. Staff summarizes these as follows: • No evidence and Applicant has offered no proof of supervised disposal of the hazardous and radioactive materials knows to have been stored on the site and poured into the fractures reaching groundwater levels. • Liquids such as the Boeing solvents were reportedly poured directly into the lagoons, where they were free to sink through the vertical fissures into the groundwater table and the sources of the Deschutes River itself. • The NFA letter issued by DEQ is not based on DEQ's testing, or even independent scientific study. It is based on incomplete information from the current owners, omitting the timeline information and decades of knowledge File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 9 of 20 about what happened on the site. Because the NFA letter is based on incomplete information, the NFA letter issued is not reliable. • The NFA Letter does not cover the entire subject property. • The DEQ internal memo for the NFA submitted by FOLB on 11.6.19 notes that the east side uses being evaluated are aggregate mining and hot mix asphalt plant only. We now know thatthe site also served as a Deschutes County dump site 1966-1972, with no record of its removal. Because of the Owner's failure to disclose the dump's existence, the DEQ NFA, and consequently the OHA Letter relying on the DEQ NFA, are properly deemed unreliable. Because these "assurances" are no longer reliable, the 2008 Conditions are not met. • FOLB argues that significant discrepancies in well sampling information cast those results into doubt. • The NFA letter foundation is erroneous so subject to withdrawal. • Processed DE, because of the length of time it was made on site ... is a particular concern. The October 30 hearing testimony indicated there was dispute about the nature and potential harm of this material. [Submitted]... reports describe the health -threatening nature of the material cooked for over 20 years on the subject property, including dumping of waste on the site. Applicant Final Argument: The environmental clean-up for East Area is complete and both DEQ and OHA have issued letters verifying it is safe for residential use. The Applicant and DEQ have submitted additional evidence demonstrating those environmental certifications apply to the entire area which is the subject of this application, including the 29 acres west of Lower Bridge Road, and including an analysis of the West area sufficient to establish it poses no environmental hazard to residential use on the East area. The testimony of the opponents on the historical uses of the property for solid and hazardous waste disposal have been addressed through the DEQ and OHA certification process in which the opponents participated. DEQ and OHA are the agencies with the expertise to certify the environmental condition of the property and ... the evidence from DEQ and OHA that the property is safe for residential use [is] both credible and persuasive. 7. Will scenic resources be adequately protected? Issue Summary: The Planned Development code requires that, "Adequate provision is made for the preservation of natural resources such as bodies of water, natural vegetation and special terrain features." Parties disagree whether the proposed plan adequately protects the scenic resources of the Deschutes River canyon. 2015 Hearings Officer: Deschutes River and Canyon. "...if the proposed PUD is approved on appeal, it should be subject to a condition of approval prohibiting the construction of any structure, whether or not it requires a building permit, closer than 50 feet from any rimrock on each PUD residential lot." File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 10 of 20 Deschutes River Scenic Waterway. "...As discussed in the findings above, the Hearings Officer has found that if the proposed PUD is approved on appeal, it should be subject to conditions of approval requiring that all dwellings within the PUD be set back a minimum of 100 feet from the OHWM of the Deschutes River and at least 50 feet from any rimrock, and that all structures be prohibited within the Deschutes River canyon." Scenic Views. 'The Hearings Officer finds that dwellings in the proposed PUD will not block or interfere with views of the river or the Cascade Mountains from adjacent or nearby properties to the east and north. Opponents who live across the Deschutes River east of the proposed PUD object to having to look at dwellings on the subject property. However, I find that with the 2008 rezoning of the subject property to RR-10, opponents no longer had reasonable expectations that the subject property would remain undeveloped." 2019 Hearings Officer: Deschutes River and Canyon. The Hearings Officer found that under the Riparian Area Management Plan and associated conditions of approval, this resource would be adequately protected. Deschutes River Scenic Waterway. The Hearings Officer found that, with per -structure review of homes by Oregon Parks and Recreation ("OPRD"), this resource would be adequately protected. Scenic Views. The Hearings Officer finds that with conditions requiring setbacks from the Deschutes River and rimrock, a prohibition upon Applicant seeking exceptions to the County rimrock standards or LM review standards, and a prohibition upon Applicant seeking Scenic Waterway exceptions this issue has been adequately addressed. Oregon Parks and Recreation Department: The proposed development at Lower Bridge Road is incompatible with Middle Deschutes Scenic Waterway "Scenic River Area" category, and as such a 1 Not riverfront housing development might not be granted approval by the Oregon State Parks and Recreation Commission. Such development is not in line with the existing agricultural and low -density development, and would require significant vegetation screening and rim rock setbacks to ensure that the structures do not intrude on the view from the river. The proposed subdivision lies within an area categorized as "Scenic River Area," defined in the Middle Deschutes Management Plan as: "Areas [that] may be accessible by roads, but are largely undeveloped and primitive except for agriculture and grazing. River segments considered 'Scenic'are managed to maintain or enhance their high scenic quality, recreation value, fishery and wildlife habitat. The intent is to preserve their largely undeveloped character while allowing continued agricultural land use". File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 11 of 20 The Lower Bridge Road, LLC development plan lots are designed to maximize the housing density on the upper plateau overlooking the river; from the river's edge, this would be visible as a high -density housing development. The proposed density and clustering along the river would deplete the river corridor's "relatively pristine condition", and our preliminary assessment is this would undermine the values the Scenic Waterway designation was established to protect. An actual, detailed review would be conducted after receiving the required notification from the property owner prior to development, but it seems wise to raise this concern as early as possible to provide the property owner a chance to adjust their plans now in a way that makes eventual compliance with scenic waterway rules easier. Applicant Final Argument: Oregon State Parks has raised issues regarding the State Scenic Waterway designation and compliance with the State Scenic Waterway rules. The County implements scenic protections through the Landscape Management Combining Zone, which applies to the subject property and which requires individualized review of each proposed dwelling through a land use process prior to building permit approval. LM review is required for each lot in this case and is a condition of tentative plan approval. The Applicant has demonstrated, through the submission of Exhibits and testimony, it can meet the setbacks for the LM zone. Scenic Waterway review, through Oregon State Parks, is also required for each proposed dwelling prior to the issuance of a building permit and is also a condition of land use approval. These review processes are in place to protect scenic resources and adequately protect the scenic area of the river. The issues State Parks raises with regard to the Scenic Waterway designation are not related to review criteria for this subdivision request. 8. Will riparian habitats associated with the Deschutes River and nearby rimrock be adequately protected? Issue Summary: The Planned Development code requires that, "Adequate provision is made for the preservation of natural resources such as bodies of water, natural vegetation and special terrain features." Parties disagree whether the proposed plan adequately protects the riparian habitats of the Deschutes River and associated rimrock habitats. 2015 Hearings Officer: Fish and Wildlife. The Hearings Officer found that, with conditions of approval, this resource would be adequately protected. Borden Beck Wildlife Preserve. "The applicant proposes to protect all flood plain areas, wetlands, riparian habitat and canyon associated with the Deschutes River by including such areas within open space Tracts C and E, both of which are located across the river from the Borden Beck Wildlife Preserve. I find the design of the proposed PUD, and implementation of these setbacks and LM review, will minimize impacts on the wildlife habitat." File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 12 of 20 2019 Hearings Officer: Fish and Wildlife. The Hearings Officer found that, with conditions of approval, this resource would be adequately protected. (See Borden Beck discussion, below). Borden Beck Wildlife Preserve. The Hearings Officer finds that with conditions requiring setbacks from the Deschutes River and rimrock, a prohibition upon Applicant seeking exceptions to the County rimrock standards or LM review standards, a prohibition upon Applicant seeking Scenic Waterway exceptions, and modification of the CC&R's to reflect ODFW's request to "ban the feeding of wildlife and require "wildlife friendly fencing" (DCC 18.88.070), the Applicant has adequately addressed this issue. Gould: The proposed drilling exempt domestic wells for the 19 new lots should not adversely impact the federally listed Threatened Bull Trout or the Steelhead Trout now 10j reintroduced species above Pelton Round Butte Dam. Since exempt wells are exempt from the Deschutes Basin Mitigation Program obligation, this does not mean the water withdrawal from those wells does not have an adverse impact on the natural resources of the abutting Deschutes River, it's fish habitat and/or on the rejuvenating spring recharges that bring life at cold water refugia along and in the Federally designated Wild and Scenic Middle Deschutes River. Beard: Along with the following organizations, we believe the Goal 5 wildlife objectives and riparian area protections are not being properly met or addressed for this PUD. • Oregon Department of Fish and Wildlife (ODFW) • Oregon Parks and Recreation Department (OPRD) • Redmond Area Park and Recreation District (RAPRD) • Central Oregon Land Watch (COLW) • Oregon Land and Water Alliance (OLAWA) The intent of PUD's is to enhance wildlife protection by "clustering" development, and therefore, allowing larger open spaces. However, this intent is circumvented whenever development abuts a riparian area --as the most desirable home sites are always nearest the waterway. In these instances a PUD places houses and human activity as close as possible to wildlife habitat and maximizes all of the negative impacts. Oregon Parks and Recreation Department: because the "Riparian Area Management Plan" (RAMP) was completed during the winter season (December 14, 2018), the natural resource values identified are unlikely to accurately represent the abundance of wildlife and flora present along the riparian area. Because of the riparian area was surveyed during dormancy, it is not an adequate baseline to measure the existing condition or set standards to preserve the integrity and biodiversity of the riparian ecosystem at this stretch of the Middle Deschutes Scenic Waterway. Oregon Department of Fish and Wildlife: (Staff summary of Heath/Walsh hearing testimony) Elements of the RAMP are good, but the development will impact the riparian habitats. It is difficult to mitigate habitat impacts. Trails are proposed and will bring people, dogs, and File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 13 of 20 associated habitat impacts into the riparian habitats. Any increased use of this area will compound effects. ODFW has the following concerns: • The project as proposed will negatively affect mule deer winter range and does not meet mitigation criteria. • The project as proposed will negatively affect habitat in the narrow riparian corridor despite the Riparian Area Management Plan. • The project as proposed will negatively affect potential nesting habitat for Golden Eagles and other sensitive species. ODFW recommends that the County ensure there is a sufficient compensatory mitigation plan to address all three of the Category 2 habitats outlined above prior to approving the application. ODFW urges the county to implement stringent setback standards for any future development of the property. If this development is approved, ODFW recommends CC&R's that ban the feeding of wildlife, and require wildlife friendly fencing in accordance with DCC 18.88.070 throughout the development. Due to the change in land use, ODFW will not respond to any wildlife damage complaints within this development. Applicant Final Argument: The comprehensive Riparian Area Management Plan was prepared by a professional biologist and contains prohibitions on any development in the Flood Plain and riparian areas, with stringent and cohesive management strategies designed to protect and monitor these areas. The proposed CC&Rs contain funding, enforcement and review provisions to ensure the plans are carried out and progress is monitored by biologist review. This proposed development plan, even with the additional density allowed by the planned/cluster form of development, provides more protection for the scenic and riparian resources than a standard subdivision. This area is a former abandoned mine with little native vegetation, not a pristine forested or protected area. The Applicant's efforts to remediate and reuse the former mine site and the proposal to develop the 19 lot subdivision with 94.1 acres of protected, cohesively managed open space will be a significant improvement to the scenic and riparian areas on the subject property. 9. Has the Applicant adequately addressed Surface Mining Impact Area ("SMIA") zone criteria? 2019 Hearings Officer: The Hearings Officer finds SMIA review, in this case, is required to be conducted as part of the PUD subdivision process. The Hearings Officer finds the Applicant deferred the SMIA review until the building permit process for dwellings on each proposed lot. The Hearings Officer finds that Applicant's failure to seek SMIA Site Plan approval at this stage (PUD/tentative plan approval stage) results in this criterion not being met. Applicant Final Argument: The Applicant clarified and the record shows the Applicant did apply for SMIA review, paid the requisite fee, submitted the subdivision and builder's envelope plans for site plan review, and the application was properly noticed. The Applicant File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 14 of 20 submitted further evidence on Appeal establishing that all proposed buildable areas were over 250' from the two nearby Surface Mine zones. The Applicant also agreed to record, as a condition of final plat approval, the requisite Waiver of Remonstrance against all lots in the proposed subdivision. 10. Is demonstration of compliance with rimrock standards required in this decision? 2019 Hearings Officer: The Hearings Officer, in this case, finds that the rimrock setback standards are part of the Design review process of DCC 18,84.080 which itself is part of the LM Site Plan review process. The Hearings Officer has previously found that LM Site Plan review is required for new structures and certain alterations to structures. The Hearings Officer found the LM Site Plan review is required at the building permit stage for the new/altered structures and not at the PUD review stage. The Hearings Officer finds the most appropriate time to consider the rimrock setback standards will be upon the LM Site Plan review for new structures/altered structures. While the Hearings Officer may concur with Staff and many opponents of this proposal that in the past "rimrock may have been buried"the Hearings Officer also believes that Applicant's proposed PUD subdivision application in this case is to be judged on the current condition of the Subject Property and under the current laws/codes. FOLB Rebuttal: Determination of the location of the true rim is critical to protection of the habitat, the river, and the soil stability. That's why rimrock is protected. FOLB asks this Board to require a rimrock survey before a site plan is approved, so that true site dimensions may be determined for feasibility analysis. Without County determination of where the rimrock is located, the setback dependent upon it cannot be fixed, and building envelopes cannot be determined. And without building envelopes, feasibility of development on each site cannot be assured. LanclWatch: The Hearing Officer further erred in finding that the applicant can defer until the building permit stage a showing that the Landscape Management Zone rimrock set backs of 50 feet, DCC 18.84.090(D), will be met. When a development proposal omits or otherwise defers until a future determination whether an approval standard will be met, the application must be denied, made more certain, or postponed. Applicant Final Argument: Staff understands the Applicant to concur with the 2019 Hearings Officer. 11. Are the proposed lots developable, given applicable constraints on the building lots? Issue Summary: DCC 17.36.170 requires: "The size, width and orientation of lots or parcels shall be appropriate for the location of the land division and for the type of development and use contemplated..." This provision is intended to prevent the creation of new lots that would not be ultimately developable. The decision maker must find that the lot layout would allow each lot to be developed with a house, well, and septic system, considering all File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 15 of 20 applicable constraints. Opponents have argued that the small lots, often with significant acreage down the canyon slope, are not feasible to develop, given constraints such as rimrock setbacks and well -to -septic separation requirements. 2015 Hearings Officer: "...the applicant has failed to demonstrate the size and configuration of each proposed PUD lot will allow the siting of dwellings, on -site septic systems and individual wells consistent with the 50-foot setback from any rimrock and all other applicable yard and setback requirements." 2019 Hearings Officer: The Hearings Officer finds that with conditions set forth in the findings for DCC 18.96.110(C), DCC 18.128.015(A), DCC 18.128.210(A) this approval criterion can be met. FLOB Open Record: The required setbacks and dimensional standards applicable to the site are quite restrictive, as is appropriate in such a complex location. Rimrock determination will be particularly complex. Determination of the location of the true rim is critical to protection of the habitat, the river, and the soil stability. FOLB asks this Board to require a rimrock survey before a site plan is approved, so that true site dimensions may be determined for feasibility analysis. Applicant Final Argument: The record includes the Applicant's conceptual building envelopes and a typical residential building plan for a 4,000 square foot home, well, septic and reserve to demonstrate there is ample area on each lotto site a dwelling and all necessary residential components and meet the required setbacks. This evidence is supported by the testimony, both oral and written, of a local builder who reviewed the evidence and attested to the fact that all lots contain ample area to site a residence and all necessary infrastructure. 12. Do old roads undermine acreage calculations? Issue Summary: The subject property has several public rights of way in proposed open space that have not been shown on development figures to date. Do these right of ways count toward the sixty-five percent open space acreage requirements? If not, the application falls below required acreage standards. Gould: Applicant does not show 3 public ROW's that traverse taxlot 502 where the project proposes Open Space in Tract E and Tract F of the Cluster Development. Applicant has appropriately removed the ROW acreage for Lower Bridge Way 2.8 acres per their 5-14- 2019 tentative subdivision plan' but has not removed the ROW acreages for the Roy L Kidder Road' which has a 60' wide ROW, the Willamette and Cascade Mountain Military Wagon Road and the Lambert Road; the latter being also known as the 1909 Lower Bridge Road. Road Department: Ms. Gould is correct that right of ways for Kidder Rd, Willamette Valley Wagon Rd, and Lower Bridge (Lambert) Rd exist over the subject property and that the applicant's current tentative plan does not appear to show these right of ways. Road File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 16 of 20 Department will defer to Community Development Department as to whether or not the applicant has deducted or should deduct these areas from their proposed open space area. Staff: These road areas are allowed to be counted as part of the area of the property, per the DCC 18.04.030 definition of lot area, in relevant part, "...the Planning Director or Hearings Body shall include in gross lot areas all streets, roads, and easement of access to other property that would accrue to that lot if the road, street or easement were vacated..." 13. Is the Applicant authorized to make this application? Issue Summary: Paul Christensen, as the President of Realvest LLC, signed the application. Realvest Corporation Is the sole member of LBR Manager, LLC, which is the manager for Lower Bridge Road, LLC, which is the property owner. Under DCC 22.08.010, applications must "be submitted by the property owner or a person who has written authorization from the property owner". FOLB Rebuttal: The actual ownership of the subject property is split, and that the application made to the County lacks full authority of the land's ownership to be processed and approved. All mineral rights were split off the ownership of the subject property, and are presently held by an Oregon Corporation that has been dissolved, Central Oregon Diatamaceous [sic] Earth, Inc. Staff: The context of the word "the" as used in Section 22.08.010 is within a definition of property ownership for purposes of submitting a land use application in an environment where it is not unusual for there to be multiple property owners - e.g., fee owners, contract purchasers, and easement holders. In this context, staff believes it is not reasonable to read the word "the" as meaning a particular owner. Rather, staff believes the most reasonable interpretation is that the word "the" is a synonym for "a" or "an." In other words, as used in Section 22.08.010, the term "the property owner" means "a property owner"- i.e., at least one property owner if there are more than one. 14. Does "transferring' density from FP zoned land to residential zone lands act as a plan amendment with widespread impacts on infrastructure, housing, and Goal 5 inventoried resources? Issue Summary: Opponents argue that the 2019 Hearing Officer's decision allows undevelopable land in the Flood Plain to be credited towards new additional residential density in upland areas. Since these additional residential units were not accounted for when analyses of housing demand, infrastructure requirements, and protection of Goal 5 resources were conducted, this change in code interpretation undermines the assumptions and conclusions of those analyses. Specifically, opponents argue that approval of this proposal would act in many ways like a post -acknowledgment plan amendment ("PAPA"), and an economic, social, energy and environmental ("ESEE") analysis should be required. File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 17 of 20 Hearings Officers: This issue was not argued in 2015 and staff believes that the 2019 Hearings Officer's decision does not directly address this issue. Calfa Holdings: The Hearings Officer's interpretation allows for increased density near and adjacent to flood plain lands and inventoried resources, and thus, requires an ESEE analysis. Effectively, the Hearings Officer has authorized a density transfer of the upland portions of any PUD or cluster development using flood plain zoned land, since the flood plain zoned areas within that development can now be used toward open space and still count toward the total acreage under which the development's density is calculated. This interpretation allows for the upzoning of developable property adjacent to flood plain zoned lands by shifting density from the "undevelopable" portion (flood plain) to the "developable" portion. Consequently, this interpretation is a wholesale shift in policy that implicates the comprehensive plan provisions with respect to development in or near inventoried resources, like flood plain areas, infrastructure to support development, and compatibility of new uses with surrounding existing land uses and resources. Because this shift in policy acts in many ways like a post -acknowledgment plan amendment ("PAPA"), an economic, social, energy and environmental ("ESEE") analysis is required pursuant to state law to evaluate and ascertain the conflicting uses with inventoried resource lands. This Board's review of the Hearings Officer's decision goes beyond the present development application under appeal; the Board's decision will set in place a policy for the County regarding Goal 5 inventoried resources. Upholding the Hearings Officer's interpretation on the use of flood plains as open space in PUDs, without an attendant ESEE analysis, presents several errors under the state's Goal 5 procedure and process. Applicant Final Argument: Open space is a listed use in the Flood Plan Zone and the listing of open space as a use allowed in that zone means open space associated with a planned development in an adjacent zone. Such code language was in place at the time of adoption and acknowledgment of the Goal 5 program and remains in place today. The County has historically allowed Flood Plain zoned acreage to be included as open space in cluster and planned subdivisions and the 2015 Hearings Officer decision ruling otherwise is not binding and is, in fact, the only County decision ever making such interpretation. The record shows the Flood Plain zone was adopted based on the Flood Insurance Study maps for Deschutes County prepared by FEMA and the subject property is located within Zone A on the FIRM map. The record further shows a cluster subdivision like the one proposed in the present case is consistent with the FEMA Guidelines for development within a Zone A area. The use of Flood Plain zoned acreage as open space in the present request, with a cohesive stewardship plan prohibiting any development in the Flood Plain, is consistent with the Goal 5 program and does not authorize a new conflicting use. 111111. NEXT STEPS Deliberations are scheduled for December 18, 2019. File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 18 of 20 DESCHUTES COUNTY PLANNING DIVISION f Z4 Will Groves, Senior Planner Attachments: Binder 4 Item No. 2019-12-04 Staff Memo 142 2019-12-04 Decision Matrix 141 2019-11-20 Lower Bridge Applicants Final Argument 140 2019-11-13 Rebuttal Testimony L Dickson 139 2019-11-13 Rebuttal Testimony T Lewis 138 2019-11-13 Rebuttal Testimony N Gould 137 2019-11-10 Rebuttal Testimony C Smith (Road Dept) 136 2019-11-06 Open Record Period 1 N Gould Testimony with exhibits 135 2019-11-06 Open Record Period 1 L Dickson Testimony with exhibits 134 2019-11-06 Open Record Period 1 J Berreen, E Beard, D Jenkins testimony 133 2019-11-06 Open Record Period 1 D Lozito, James Taylor & Janis Taylor testimony 132 2019-11-06 Open Record Period 1 D Lozito Testimony 131 2019-11-06 Open Record Period 1 Applicant Testimony 130 2019-10-30 Hearing Exhibit Sheet 129 2019-10-30 Hearing Exhibit A -Staff Presentation 128 2019-10-30 Hearing Exhibit B - Calfa Holdings Testimony 127 2019-10-30 Hearing Exhibit Cl - Life of the Mine (D. Jenkins) 126 2019-10-30 Hearing Exhibit C2 - 2016-03-07 US Dept of Interior Itr. to Mr. Jenkins 125 2019-10-30 Hearing Exhibit C3 - 1969 EPA report on Public Dumps (D. Jenkins) 124 2019-10-30 Hearing Exhibit C4 - Closing Open Dumps EPA Report (D. Jenkins) 123 2019-10-30 Hearing Exhibit C5 - 2008-08-14 Bulletin Article (D. Jenkins) 122 2019-10-30 Hearing Exhibit C6 - Oversize posters (Converted for Printing) (D. Jenkins) 121 2019-10-30 Hearing Exhibit D - Various Maps (D. Lozito) 120 2019-10-30 Hearing Exhibit E - Map (E Beard) 119 2019-10-30 Hearing Exhibit F - Oversize USGS map (N Gould) 118 2019-10-30 Hearing Exhibit G - Oversized Maps (Applicant) 117 2019-10-30 Hearing Exhibit H - Applicant Power Point 116 2019-10-30 Hearing Exhibit I - COLW Comments (Carol MacBeth) 115 2019-10-30 Hearing Exhibit J - Request to Speak forms (various) 114 2019-10-29 OPRD Submittal 113 Binder 3 2019-10-29 Calfa Holdings Appeal Memo 112 2019-10-28 T Lewis Supplemental Information 111 File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 19 of 20 2019-10-28 T DeBone Photos 110 2019-10-28 Lower Bridge Pre -Hearing BoCC Work Session 109 2019-10-28 Lower Bridge BoCC Work Session Memo 108 2019-10-27 P Lipscomb Testimony (OLAWA) 107 2019-10-27 D Lozito testimony 106 2019-10-24 J Sifuentes testimony 105 2019-10-23 B Schwarz testimony 104 2019-10-23 S Redfield testimony 103 File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A Page 20 of 20 Decision Matrix: (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) - Lower Bridge Is a Planned • "Planned development" is not a use • The language used in DCC 18.96.040 is • Contrasting Hearing Officer decisions highlight Is a Planned Development Development permitted outright or conditionally in clear, plain and unambiguous. "Planned an important code interpretative issue. application allowed in the Flood application allowed the FP Zone. developments" are subdivisions. Plain zone? in the Flood Plain In the face of code ambiguity, parties argue at zone? • The fact that "subdividing" land is • Proposed subdivision is consistent with length if this use should be allowed. This is a. If yes, continue deciding permitted in the flood plain zone does FEMA guidelines. addressed in subsequent deliberation other criteria. (DCC 18,96.030, 040) not mean PUDs are permitted. questions. b. If no, the proposal does not • Outright "open space" use in FP zone comply with the allowed uses The three types of subdivisions corroborates this interpretation. • No flood hazard/loss impacts anticipated in DCC 18.96. No further 1 ("subdivision", planned, cluster) make under this proposal. direction is necessary, or clear they have different Matches 1999-2015 county approach to i. Deny the application and characteristics and are intended to be this interpretation. continue deciding other reviewed and approved under criteria. different substantive standards. Legislative code amendment is a better process to resolve this question. Is open space • Although "open space" is listed as an • The Flood Plain tracts would be • Planned Developments are required to have Is open space associated for a associated for a outright permitted use in the FP Zone "preserved and continued in its [their] sixty-five percent open space. planned development permitted planned the applicant's proposed open space present use" and would conserve and outright in the FP zone? development is open space lots within a PUD which enhance natural resources, would Proposal to use FP zoned lands as part of the permitted in the FP is not a use permitted outright in the protect streams, promote open space acreage. a. If yes, continue deciding zone? FP Zone. conservation of wetlands and • First deliberative question likely determines other criteria. b. If no, either: (DCC 18.96.030, 040) . If a PUD cannot be permitted in the enhance recreation opportunities. answer to this question. i. Deny the application. No flood plain zone, then the open space • Flood Plain Zone is the only zone in further action is 2 within that PUD cannot be permitted the County where "open space" is a necessary; or either. listed use. No permit needed to ii. Deny the application and conserve land in its present use. Code continue deciding other • The definition of "open space" does drafters must have intended to allow criteria. not provide any express authority for "open space" associated PUDs flood plain zoned lands to be used as specifically listed use in the Flood open space in a PUD. Plain Zone. (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) Page 1 of 10 Decision Matrix: (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) - Lower Bridge Does the FP zoned PUD is not a use permitted in the FP land count towards zone. Therefore, FP -zoned land PUD housing density included in the subject property and density cannot be included in the density bonuses? calculation. (DCC 18.128.210(D)(3), "In an RR 10 Zone... planned and 18.60.060(C), cluster developments shall be allowed 3 18.96.110) an equivalent density of one unit per 7.5 acres." 4 • Unlike RR10 code, no PUD density bonus listed in FP lot size requirements. • The listing of open space as a use allowed in that zone means open space associated with a planned development in an adjacent zone. • The County has historically allowed Flood Plain zoned acreage to be included as open space in cluster and planned developments. • Code expressly allows for gross area calculations to determine density and lot sizes. Including FP acreage is supported by the County Code and historical practice. Does sufficient • Cost estimates do not address The Applicant submitted a cost financing exist to additional environmental concerns. estimate prepared by a registered assure the proposed civil engineer to complete the development will be • How can the Applicant can be flush subdivision, including both soft and substantially with cash in a money market account, hard costs and a 10% contingency. completed within but require approval of the east side four years of development to fund the west side? The Applicant also submitted a letter approval? from the CFO of Realvest as the entity "Applicant" is Lower Bridge Road, LLC. responsible for financing the project (DCC 18.128.210(B)(6)) However, "Applicant" is not the signer together with a money market of the application or holder of the statement, demonstrating funds money market account offered as sufficient to and committed to assurance of financial stability. Who building the project. owns the property, who controls the property, and what financial means The Applicant submitted evidence are available to the Applicant itself? demonstrating the Realvest Chapter 11 Plan for reorganization was • A number of lawsuits directed at accepted and was fully completed in members of the development team. 2010. [A] suit, if successful, will wipe out the money market fund offered for financial security of the project. • Planned Developments get a housing density bonus from one unit per 10 acres to one unit per 7.5 acres in the RR10 zone, increasing the number of allowed units in the development. • The PUD proposal relies on RR10 and FP zoned land together for the density calculation to allow for 19 residential lots. • Planned Development code requires a demonstration of existing financing to complete the project, as proposed. • The applicant had not provided detailed cost or financial information until the current hearing before the Board. Does the FP zoned land count towards PUD housing density and density bonuses? a. If yes, continue reviewing the application. b. If no, i. Deny the application. No further action is necessary; or ii. Deny the application and continue deciding other criteria. Has the applicant demonstrated compliance with DCC 18.128.210(B)(6)? a. If yes, continue reviewing the application. b. If no, either: i. Deny the application. No further action is necessary; or ii. Deny the application and continue deciding other criteria. (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) Page 2 of 10 Has the Flood Plain zoned land received an exception to the resource use acreage standards (Goal 3)? (DCC 18.96.110(C)) 5 Has the environmental history at the mine been adequately addressed and resolved? (DCC 18.128.015) 6 Decision Matrix: (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) - Lower Bridge • DCC 18.96.110(C) requires a • The subject property was rezoned minimum lot size of 80 acres for from Surface Mining to RR-10 in 2008 "areas which have not received an through the non -resource designation exception to the Statewide process, which is an alternative Planning Goals" for resource uses. method to the goal exception • The flood plain zoned portion of this property has not received an exception to resource goals (Goals 3 and 4). • The NFA letter foundation is erroneous so subject to withdrawal. • The NFA Letter does not cover the entire subject property. • The NFA letter issued by DEQ is not based on DEQ's testing, or even independent scientific study. Because the NFA letter is based on incomplete information, the NFA letter issued is not reliable. • Proper waste disposal, potential waste seepage, potential dump usage of the property are of concern are not adequately resolved. process. • That 2008 Zone Change Decision concluded there are no Goal 3, 4 or 5 resources on the subject property and is the equivalent of a goal exception. • DEQ and OHA are State agencies that possess technical and scientific expertise in matters relating to the environment. • The DEQ process was a public process and that opponents of this application had the right to participate. • Environmental clean-up activities at the Subject Property have been completed and the Subject Property "environmental conditions are currently protective of public health" • Reviewed area includes 29 acres west of Lower Bridge Road • Minimum lot sizes in resourced zoned Has the Flood Plain zoned land lands are 80 acres, with certain exceptions, received an exception to the as part of the State Goal 3 program to resource use acreage standards preserve and protect farm uses. (Goal 3)? • The Flood Plain zone, accordingly, has a a. If yes, continue reviewing the minimum lot size of 80 acres, where land application. has not "received an exception to the b. If no, either: Statewide Planning Goals for resource i. Deny the application. No uses". Flood Plain zoned lands that have further action is received an exception have a minimum lot necessary; or size of 10 acres. ii. Deny the application and continue deciding other • On the subject property, the Flood Plain criteria. zone holds a "Surface Mining' comprehensive plan designation. • This 113-acre area was previously used Has the environmental history at primarily for aggregate mining and hot -mix the mine been adequately asphalt plant operations. addressed and resolved? • Diatomite mining and processing was conducted primarily on an adjacent larger property on the west side of Lower Bridge Road. • DEQ and OHA have declared the site safe for residential use. • Condition to consider: Shared public water supply system that will be subject to periodic water quality testing to protect drinking water. (DCC 17.36.300) a. If yes, continue reviewing the application. b. If no, either: i. Condition approval to achieve compliance; ii. Deny the application. No further action is necessary; or iii. Deny the application and continue deciding other criteria. (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) Page 3 of 10 7 Decision Matrix: (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) - Lower Bridge Will scenic resources A 19-lot riverfront housing Hearings Officer found that with be adequately development might not be granted conditions requiring setbacks from protected? approval by the Oregon State the Deschutes River and rimrock, a (DCC Parks and Recreation Commission. prohibition upon Applicant seeking 18.128.2010(B)(8)) Such development is not in line exceptions rimrock standards or LM with the existing agricultural and review standards, and a prohibition low -density development, and upon Applicant seeking Scenic would require significant Waterway exceptions this issue has vegetation screening and rim rock been adequately addressed. setbacks to ensure that the structures do not intrude on the The County implements scenic view from the river. protections through the Landscape Management Combining Zone, which • The proposed density and applies to the subject property and clustering along the river would which requires individualized review deplete the river corridor's of each proposed dwelling through a "relatively pristine condition", and land use process prior to building OPRD's preliminary assessment is permit approval. this would undermine the values the Scenic Waterway designation Scenic Waterway review, through was established to protect. Oregon State Parks, is also required for each proposed dwelling prior to the issuance of a building permit and is also a condition of land use approval. • The issues State Parks raises with regard to the Scenic Waterway designation are not related to review criteria for this subdivision request. • The proposed development at Lower Bridge Road is located in the Middle Deschutes Scenic Waterway "Scenic River Area" category. Will scenic resources be adequately protected? a. • Planned Development code requires that, b "Adequate provision is made for the preservation of natural resources such as bodies of water, natural vegetation and special terrain features." • Condition to consider: Additional structural setback from canyon rim, regardless of "rimrock". If yes, continue reviewing the application. If no, either: i. Condition approval to achieve compliance; ii. Deny the application. No further action is necessary; or iii. Deny the application and continue deciding other criteria. (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) Page 4 of 10 8 Decision Matrix: (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) - Lower Bridge Will riparian The intent of PUD's is to enhance Hearings Officer found that with Planned Development code requires that, Will riparian habitats associated habitats associated wildlife protection by "clustering" conditions requiring setbacks from "Adequate provision is made for the with the Deschutes River and with the Deschutes development and allowing larger the Deschutes River and rimrock, a preservation of natural resources such as nearby rimrock be adequately River and nearby open spaces. prohibition upon Applicant seeking bodies of water, natural vegetation and protected?? rimrock be exceptions to the County rimrock special terrain features." adequately This intent is circumvented standards or LM review standards, a a. If yes, continue reviewing the protected? whenever development abuts a prohibition upon Applicant seeking Condition to consider: Prohibition on new application. (DCC riparian area --as the most Scenic Waterway exceptions, and trails in the RAMP area. b. If no, either: 18.128.2010(B)(8)) desirable home sites are always modification of the CC&R's to reflect i. Condition approval to nearest the waterway. This PUD ODFW's request to "ban the feeding achieve compliance; places houses and human activity of wildlife and require "wildlife ii. Deny the application. No as close as possible to wildlife friendly fencing" (DCC 18.88.070), and further action is habitat and maximizes all of the the RAMP, the Applicant has necessary; or negative impacts. adequately addressed this issue. iii. Deny the application and continue deciding other • ODFW recommends that the • The RAMP was prepared by a criteria. County ensure there is a sufficient professional biologist and contains compensatory mitigation plan to prohibitions on any development in address [riparian, deer, and eagle the Flood Plain and riparian areas, impacts] prior to approving the with stringent and cohesive application. management strategies designed to protect and monitor these areas. • ODFW urges the county to implement stringent setback The proposed CC&Rs contain funding, standards for any future enforcement and review provisions to development of the property. ensure the plans are carried out and progress is monitored by biologist • The riparian area was surveyed review. during dormancy, it is not an adequate baseline to measure the This proposed development plan, existing condition or set standards even with the additional density to preserve the integrity and provides more protection for the biodiversity of the riparian scenic and riparian resources than a ecosystem. standard subdivision. (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) Page 5 of 10 9 Decision Matrix: (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) - Lower Bridge Has the Applicant The Applicant clarified and the record The Hearings Officer found that Applicant's adequately shows the Applicant did apply for failure to seek SMIA Site Plan approval at addressed SMIA SMIA review, paid the requisite fee, this stage (PUD/tentative plan approval Criteria? submitted the subdivision and stage) results in this criterion not being builder's envelope plans. met. • The Applicant submitted further Applicant provided evidence to confirm evidence on Appeal establishing that compliance with SMIA requirements. all proposed buildable areas were over 250' from the two nearby Surface Mine zones. • The Applicant also agreed to record, as a condition of final plat approval, the requisite Waiver of Remonstrance against all lots in the proposed subdivision. Has the Applicant adequately addressed SMIA Criteria? a. If yes, continue reviewing the application. b. If no, either: i. Deny the application. No further action is necessary; or ii. Deny the application and continue deciding other criteria. (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) Page 6 of 10 10 Decision Matrix: (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) - Lower Bridge Is demonstration of The applicant cannot defer until • The rimrock setback standards are compliance with the building permit stage a part of the Design review process of rimrock standards showing that the rimrock set backs DCC 18.84.080 which itself is part of required in this will be met. When a development the LM Site Plan review process. decision? proposal omits or otherwise defers • The Hearings Officer found the most (DCC 18.84.080) until a future determination appropriate time to consider the whether an approval standard will rimrock setback standards will be be met, the application must be upon the LM Site Plan review for new denied, made more certain, or structures/altered structures. postponed. Applicant's proposed PUD subdivision application in this case is to be judged • Without County determination of on the current condition of the where the rimrock is located, the Subject Property and under the setback dependent upon it cannot current laws/codes. The Hearings be fixed, and building envelopes Officer does not believe, in this case cannot be determined. And proceeding, that the Hearings Officer, without building envelopes, or even the Board has authority to feasibility of development on each require previously "buried rimrock" be site cannot be assured. "unburied". • Rimrock setback determination are Is demonstration of compliance required as part of Landscape with rimrock standards required in Management site plan review, prior to this decision? building permits. This is a public process. The rimrock review is not impermissibly a. If no, continue reviewing the deferred. application. b. If yes, either: i. Deny the application. No further action is necessary; or ii. Deny the application and continue deciding other criteria. (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) Page 7 of 10 Decision Matrix: (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) - Lower Bridge Are the proposed Small lots, often with significant The Hearings Officer found that with DCC 17.36.170 requires: "The size, width Are the proposed lots developable, lots developable, acreage down the canyon slope, conditions set forth in the findings for and orientation of lots or parcels shall be given applicable constraints on the given applicable are not feasible to develop, given DCC 18.96.110(C), DCC 18.128.015(A), appropriate for the location of the land building lots? constraints on the constraints such as rimrock DCC 18.128.210(A) this approval division and for the type of development building lots? setbacks and well -to -septic criterion can be met. and use contemplated..." a. If no, continue reviewing the (DCC 17.36.170) separation requirements. • This provision is intended to prevent the application. • The Applicant's conceptual building creation of new lots that would not be b. If yes, either: • The required setbacks and envelopes and a typical residential ultimately developable. i. Condition approval to dimensional standards are quite building plan for a 4,000 square foot • The decision maker must find that the lot achieve compliance; restrictive. Rimrock determination home, well, septic and reserve to layout would allow each lot to be ii. Deny the application. No 11 will be particularly complex. demonstrate there is ample area on developed with a house, well, and septic further action is Determination of the location of each lot to site a dwelling and all system, considering all applicable necessary; or the true rim is critical to protection necessary residential components constraints. iii. Deny the application and of the habitat, the river, and the and meet the required setbacks. continue deciding other soil stability. criteria. • A local builder reviewed the evidence • The Board should require a and attested to the fact that all lots rimrock survey before a site plan is contain ample area to site a residence approved, so that true site and all necessary infrastructure. dimensions may be determined for feasibility analysis. Do old roads • Applicant does not show 3 public Kidder Rd, Willamette Valley Wagon Rd, Do old roads undermine acreage undermine acreage ROW's that traverse taxlot 502 and Lower Bridge (Lambert) Rd exist over calculations? calculations? where the project proposes Open the subject property and that the (DCC 18.04.030) Space in Tract E and Tract F of the applicant's current tentative plan does not a. If no, continue reviewing the Cluster Development. appear to show these right of ways. application. b. If yes, either: • Do these right of ways count These road areas are allowed to be ii. Deny the application. No toward the sixty-five percent open counted as part of the area of the further action is 12 space acreage requirements? If property, per the DCC 18.04.030 definition necessary; or not, the application falls below of lot area, in relevant part, "...the Planning iii. Deny the application and required acreage standards. Director or Hearings Body shall include in continue deciding other gross lot areas all streets, roads, and criteria. easement of access to other property that would accrue to that lot if the road, street or easement were vacated..." (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) Page 8 of 10 Decision Matrix: (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) - Lower Bridge Is the Applicant The actual ownership of the Paul Christensen, as the President of The context of the word "the" as used in Is the Applicant authorized to make authorized to make subject property is split, and that Realvest LLC, signed the application. Section 22.08.010 is within a definition of this application? this application? the application made to the County Realvest Corporation Is the sole property ownership for purposes of lacks full authority of the land's member of LBR Manager, LLC, which submitting a land use application in an a. If yes, continue reviewing ownership to be processed and is the manager for Lower Bridge environment where it is not unusual for the application. approved. Road, LLC, which is the property there to be multiple property owners - e.g., b. If no, either: 13 • All mineral rights were split off the owner. Under DCC 22.08.010, fee owners, contract purchasers, and i. Deny the application. No ownership of the subject property, applications must "be submitted by easement holders. In this context, staff further action is and are presently held by an the property owner or a person who believes it is not reasonable to read the necessary; or Oregon Corporation that has been has written authorization from the word "the" as meaning a particular owner. ii. Deny the application and dissolved, Central Oregon property owner". Rather, staff believes the most reasonable continue deciding other Diatamaceous [sic] Earth, Inc. interpretation is that the word "the" is a criteria. synonym for "a" or "an." (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) Page 9 of 10 14 Decision Matrix: (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) - Lower Bridge Does "transferring' Proposal allows undevelopable Open space is a listed use in the Flood Staff is unaware of any case law regarding Does "transferring' density from FP density from FP land in the Flood Plain to be Plan Zone and the listing of open a quasi-judicial application acting as a de zoned land to residential zone zoned land to credited towards new additional space as a use allowed in that zone facto plan amendment. lands act as a plan amendment? residential zone residential density in upland areas. means open space associated with a lands act as a plan These additional residential units planned development in an adjacent a. If no, continue reviewing amendment? were not accounted for when zone. the application. analyses of housing, infrastructure, b. If yes, either: and protection of Goal 5 resources Such code language was in place at i. Deny the application. No were conducted, this change in the time of adoption and further action is code interpretation undermines acknowledgment of the Goal 5 necessary; or the assumptions and conclusions program and remains in place today. ii. Deny the application and of those analyses. continue deciding other • The use of Flood Plain zoned acreage criteria. • Proposal would acts like a post- as open space in the present request, acknowledgment plan amendment with a cohesive stewardship plan ("PAPA"), and an economic, social, prohibiting any development in the energy and environmental ("ESEE") Flood Plain, is consistent with the analysis should be required. Goal 5 program and does not authorize a new conflicting use. • This interpretation allows for the upzoning of developable property adjacent to flood plain zoned lands by shifting density from the "undevelopable" portion (flood plain) to the "developable" portion. (File Nos. 247-19-000405-CU, 406-TP, 407-SMA, 741-A, 757-A) Page 10 of 10