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2023-138-Minutes for Meeting March 29,2023 Recorded 5/1/2023 BOARD OF COMMISSIONERS 1300 NW Wall Street, Bend, Oregon (541) 388-6570 9:00 AM Recorded in Deschutes County CJ2023-138 Steve Dennison, County Clerk Commissioners' Journal 05/01 /2023 2:41 :22 PM 2023-138 FOR RECORDING STAMP ONLY BOCC MEETING MINUTES WEDNESDAY March 29, 2023 Barnes Sawyer Rooms Live Streamed Video Present were Commissioners Anthony DeBone, Patti Adair and Phil Chang. Also present were Nick Lelack, County Administrator; Kim Riley, Assistant County Counsel; and Brenda Fritsvold, BOCC Executive Assistant. This meeting was audio and video recorded and can be accessed at the Deschutes County Meeting Portal website www.deschutes.org/meetings. CALL TO ORDER: Chair DeBone called the meeting to order at 9:00 a.m. PLEDGE OF ALLEGIANCE CITIZEN INPUT: None CONSENT AGENDA: Before the Board was Consideration of the Consent Agenda. CHANG: Move Board approval of the Consent Agenda after removing item #2 for separate consideration ADAIR: Second Chair DeBone noted a change to the minutes of March 8tn clarifying that the Bethlehem Inn referred to is the organization's facility in Redmond. In addition, he noted a change to the minutes of March 22d to make clear that the recent Wildfire Leadership Council tour he traveled to Klamath Falls for was conducted virtually due to inclement weather. BOCC MEETING MARCH 29, 2023 PAGE 1 OF 11 3. 4. 5. 6. 7. 2. VOTE: ADAI R: Yes CHANG: Yes DEBONE: Chair votes yes. Motion Carried Consideration of Approval of Board Order No. 2023-012 to authorize a loan assumption, and to authorize the Deschutes County Property Manager to execute the necessary documents to complete the loan assumption Consideration of Document No. 2023-330, Amendment No. 3 to an Intergovernmental Agreement with the Oregon Department of Transportation for the US20: Tumalo - Cooley Road Project Second Amendment to Ground Lease with Mountain View Community Development Consideration of Board Signature on letter appointing Jim Starnes for service on the Deschutes County Facility Project Review Committee. Approval of Minutes of the March 8 and 20, 2023 BOCC Meetings Approval of Minutes of the March 10 and 17, 2023 Legislative Update Meetings Notice of Intent to Award for juvenile justice Remodel In response to a question, Lee Randall, Facilities Director, said the final amount of this contract is still being negotiated due to the County's having identified potential cost -saving opportunities; the Notice of Intent to Award will serve to establish the protest period and communicate the County's intention to award the contract to the apparent low bidder. Randall explained that some alternate bids were solicited relating to accessibility upgrades, and confirmed that the final contract will be routed for Board signatures after the protest period has expired. ADAIR: Move to authorize Chair signature of the Notice of Intent to Award a contract for the juvenile justice Remodel project CHANG: Second VOTE: ADAI R: Yes CHANG: Yes DEBONE: Chair votes yes. Motion Carried BOCC MEETING MARCH 29, 2023 PAGE 2 OF 11 ACTION ITEMS: 8. Final Decision for a Commercial Activity in Conjunction with Farm Use (Meadery) in the Exclusive Farm Use Zone Nathaniel Miller, Associate Planner, presented the final decision before the Board on this matter following the public hearing on January 25t" and Board deliberations on March 81h. Miller noted the draft decision was submitted last week and called attention to two edits, the first of which removes the following sentence from page 15: "According to the applicant in Craven, their farm -to -table meals both sell the farm products in a prepared form and aid the farm operation in processing and marketing crops to the public." The second edit, on page 14, revises the first sentence in the "FINDING" section to correctly reference two components rather than three: "The Board finds the use permitted conditionally under this paragraph includes threetwocomponents:..." CHANG: Move Board approval of Order No. 2023-011, issuing a final decision regarding commercial activity in conjunction with farm use (Meadery) in the Exclusive Farm Use Zone for property on Highway 126 near Sisters ADAIR: Second VOTE: ADAI R: Yes CHANG: Yes DEBONE: Chair votes yes. Motion Carried Commissioner Adair said it was unfortunate that the business is not allowed to host weddings, although it can have other events. Commissioner DeBone noted the possibility of a modification being sought in the future to change this. Commissioner Chang expressed his appreciation for the regenerative agriculture which will occur on the property. 9. Consideration of Approval of Board Order No 2023-014, authorizing the sale of an 8.35-acre property in Redmond known as Map and Tax Lot 151329BB00300 to the City of Redmond, and authorizing the Deschutes County Property Manager to execute the documents associated with the sale Kristie Bollinger, Property Manager, reviewed the background of the County's acquisition of this property from ODOT in 2002. In 2021 and 2022, the County negotiated to sell the property to the City of Redmond for affordable housing. BOCC MEETING MARCH 29, 2023 PAGE 3 OF 11 John Roberts, City Manager for the City of Redmond, said the City has secured CDBG funds for this purchase. He confirmed that HUD will require that the housing be affordable in perpetuity. Commissioner Chang asked about plans for the three acres which have been determined to be undevelopable. Roberts responded these will be used for passive or perhaps active open space. Roberts added that the housing will not be multi- family; instead, the City plans to build 22 to 30 separate cottages or townhomes on the five acres that will be developed. Commissioner Chang asked if a higher density could be achieved —perhaps eight or ten units per acre. Roberts replied that the City must balance the number of units built with infrastructure costs; the underlying zoning will also be a factor. Responding to Commissioner Adair, Roberts said the City envisions completing the project in four or five years. ADAIR: Move Board approval of Order No. 2023-014, authorizing the sale of an 8.35-acre property in Redmond (Map and Tax Lot 151329BB00300) to the City of Redmond, and authorizing the Deschutes County Property Manager to execute the documents associated with the sale CHANG: Second VOTE: ADAI R: Yes CHANG: Yes DEBONE: Chair votes yes. Motion Carried 10. Deliberations: Board Review of Two Appeals for a Modification Request to the Thornburgh Destination Resort's Fish & Wildlife Mitigation Plan Caroline House, Senior Planner, reported that six comments were submitted on this matter after the close of the public hearing. The Board was in consensus that none of the comments received after the close of the public hearing will be considered as the Board makes it decisions. Continuing, House shared that appellant Annunziata Gould has, via her attorney, objected to the inclusion of eight documents in the record which were submitted as rebuttal. Stephanie Marshall, Assistant Legal Counsel, explained that the objections refer to the timing of submittal of those documents; however, there is no requirement that all relevant information must be submitted before the opportunity for rebuttal BOCC MEETING MARCH 29, 2023 PAGE 4 OF 11 arises. Marshall added that while the Board has broad discretion to allow rebuttal testimony, if it determines that any of the submitted material constitutes new evidence not responsive to arguments made by Appellant or other participants, the Board may exclude that from consideration or reopen the record. Marshall described each of the eight documents which were objected to by Appellant Gould. Assistant Legal Counsel Kim Riley advised that the Board can decide to allow all of the evidence into the record and assign it as much or as little weight as the Board deems appropriate. Marshall summarized that the Board can decide to exclude the eight documents, or reopen the record, or keep these eight documents as part of the record and either allow or do not allow a response to them. ADAIR: Move to deny Appellant Gould's motion to exclude the documents referenced by the applicant in rebuttal, and deny the request to reopen the public hearing to allow for a response to those documents DEBONE: Second VOTE: ADAI R: Yes CHANG: No DEBONE: Chair votes yes. Motion Carried 2 - 1 Continuing, House then presented the matrix of decision points before the Board, as follows (not every decision point was taken up in order of the matrix): 2. Did the applicant present more credible and/or persuasive evidence to demonstrate that the "no net loss" standard is met? Following discussion, a majority of the Board was in consensus that the applicant presented sufficient credible and/or persuasive evidence to demonstrate that the "no net loss" standard is met. 3. Does compliance with the OWRD Ground Water Mitigation Program ensure the applicant's 2022 FWMP meets the "no net loss" standard? Following discussion, a majority of the Board was in consensus that compliance with the OWRD Ground Water Mitigation Program ensures that the applicant's 2022 FWMP meets the "no net loss" standard. BOCC MEETING MARCH 29, 2023 PAGE 5 OF 11 4. Is ODFW approval of the 2022 FWMP required and/or a substantial consideration when determining if the "no net loss" standard is met? Following discussion, a majority of the Board was in consensus that ODFW approval of the 2022 FWMP is not required when determining if the "no net loss" standard is met. 5. Is the Confederated Tribes of Warm Springs approval of the 2022 FWMP required and/or a substantial consideration when determining if the "no net loss" standard is met? Following discussion, a majority of the Board was in consensus that Confederated Tribes of Warm Springs approval of the 2022 FWMP is not required when determining if the "no net loss" standard is met. 6. Are Thornburgh's water rights considered "reliable" and/or "wet water" for the purpose of evaluating the "no net loss" standard? Following discussion, a majority of the Board was in consensus that Thornburgh's water rights are considered "reliable" and/or "wet water" for the purpose of evaluating the "no net loss" standard. 7. Have the "no net loss" mitigation requirements been met for Whychus Creek? Following discussion, a majority of the Board was in consensus that the the "no net loss" mitigation requirements have been met for Whychus Creek. 8. Does the Board find the "excess mitigation" measures in the 2022 FWMP provide additional mitigation beyond the Resort's "no net loss" requirements? Following discussion, a majority of the Board was in consensus to acknowledge but not require the "excess mitigation" measures in the 2022 FWMP offered by the applicant for the purpose of providing additional mitigation beyond the Resort's "no net loss" requirements. 1. Does the applicant's 2022 FWMP ensure the "no net loss" standard is met? Following discussion, a majority of the Board was in consensus that the applicant's 2022 FWMP ensures the "no net loss" standard is met. 10. Are the proposed water rights that will be used for the Resort's water supply and mitigation reasonably certain to be approved for transfer by the OWRD? BOCC MEETING MARCH 29, 2023 PAGE 6 OF 11 Following discussion, a majority of the Board was in consensus that the proposed water rights that will be used for the Resort's water supply and mitigation are reasonably certain to be approved for transfer by the OWRD. 11. Does the 2022 FWMP ensure the proposed mitigation water will be permanently protected in stream? Following discussion, a majority of the Board was in consensus that the 2022 FWMP ensures the proposed mitigation water will be permanently protected in stream. 12. Do the applicant's proposed FWP conditions 38 and 40 ensure ongoing compliance with the "no net loss" standard? Following discussion, a majority of the Board was in consensus to approve the applicant's proposed FWP Condition 38, as revised, and new Condition 40 to ensure ongoing compliance with the "no net loss" standard with the direction that the second sentence of Condition 40 be removed and only the first sentence retained such that Condition 40 will read, in its entirety: "Thornburgh shall comply with the 2022 Fish and Wildlife Mitigation Plan, including its compliance and reporting mechanisms found in Section II of that plan." 9. Does the FWMP ensure ongoing compliance and sufficient monitoring? Following discussion, a majority of the Board was in consensus that the FWMP with the revised Condition 38 and the new Condition 40 (as edited) ensures ongoing compliance and sufficient monitoring. 13. Does the applicant's proposal impact the water availability CMP/EMP criteria? Following discussion, a majority of the Board was in consensus that the applicant's proposal does not impact the water availability CMP/EMP criteria. 14. Is Thornburgh's CMP void? A majority of the Board was in consensus that Thornburgh's CMP is not void. 15. Is the applicant's proposal a'substantial change" to the original CMP? Following discussion, a majority of the Board was in consensus that the applicant's proposal is not a'substantial change" to the original CMP. 16. Are the "surrounding properties" when considering impacts associated with a modification request limited to adjacent properties? BOCC MEETING MARCH 29, 2023 PAGE 7 OF 11 Following discussion, a majority of the Board was in consensus that what constitutes "surrounding properties" when considering impacts associated with a modification request are specific to the request and not necessarily limited to adjacent properties. 17. Does the County's newspaper notice need to be published 20 days prior to, not including the day of, the initial hearing? Following discussion, a majority of the Board was in consensus that the County's newspaper notice need to be published 20 days prior to, not including the day of, the hearing being advertised. ADAI R: Move to affirm the applicant's appeal, Appeal No. 247-22-000984-A DEBONE: Second VOTE: ADAI R: Yes CHANG: No DEBONE: Chair votes yes. Motion Carried 2 - 1 ADAI R: Move to approve the request to modify its Final Maser Plan approval, File No. 247-22-00678-MC DEBONE: Second VOTE: ADAI R: Yes CHANG: No DEBONE: Chair votes yes. Motion Carried 2 - 1 ADAIR: Move to revise FMP Condition 38 and add a new FMP Condition 40 as decided during today's deliberations DEBONE: Second VOTE: ADAI R: Yes CHANG: Yes DEBONE: Chair votes yes. Motion Carried ADAI R: Move to deny the appeal filed by Annunziata Gould, Appeal No. 247-23-000003-A DEBONE: Second VOTE: ADAI R: Yes CHANG: No DEBONE: Chair votes yes. Motion Carried 2 - 1 BOCC MEETING MARCH 29, 2023 PAGE 8 OF 11 House confirmed that the written decision on this matter will be brought to the Board for its review and approval. She noted the decision must be issued by April 10t" unless the applicant agrees to extend that deadline. Commissioner Chang clarified his statements which appeared in an article published on this matter and said while the 2022 FWMP may be a significant improvement over the 2008 proposal, he wished to see this validated via monitoring and documentation and hoped that the applicant will work to further the provision of such assurances. Commissioner DeBone noted several typos or suggested edits to the FWMP, specifically to pages 6, 9, 20 and 21. Chair DeBone announced a break at 12:59 pm. The meeting reconvened at 1:30 pm. OTHER ITEMS: County Administrator Nick Lelack relayed an opportunity for the Board to submit a no -cost advertisement regarding the Tower Theatre's Stage the Change program, which the BOCC previously sponsored via an Arts and Culture grant. Lelack noted Sally Russell's transition on the Deschutes Collaborative Forest Project Steering Committee from a seat representing local government to an at -large seat. Saying that he occupies the other local government seat on this committee, Commissioner Chang explained current projects and shared that Anthony Broadman from the City of Bend has expressed interest in being appointed to the seat vacated by Russell. Commissioner Adair said that Kathryn Osborne from the City of Redmond could also fill this role. Chair DeBone clarified that this appointment is not made by Deschutes County. Commissioner DeBone reported on the Coffee with a Commissioner event yesterday in Bend and said the Friends of Oregon's Land Use Leadership Initiative will hold its end -of -year training session at the County building next Monday. Commissioner DeBone shared that The Bend Bulletin is celebrating 120 years of publication tomorrow and commented on a mountain biking exhibit opening up at the historical society. Commissioner Adair reported that Horse and Rider magazine recently featured a four -page spread on Sisters and Black Butte. BOCC MEETING MARCH 29, 2023 PAGE 9 OF 11 Commissioner Adair commented on the Helping Hands tour next Thursday and the possibility of that program expanding to Deschutes County. She relayed objections that commissioners aren't on the Multi -Agency Coordinating group (MAC) and shared plans to meet with Andrea Bell, Executive Director of Oregon Housing and Community Services. Commissioner Chang and Commissioner DeBone attended the Council on Aging ribbon -cutting at the new Senior Services Center last week. EXECUTIVE SESSION: At 1:45 p.m., the Board went into Executive Session to discuss Real Property Negotiations under ORS 192.660 (2) (e). At 1:51 p.m., the Board moved out of Executive Session to take the following action: ADAIR: Move to authorize the sale of a 2.95-acre lot at the southeast corner of CW Reeves Lane and Mitts Way in La Pine, and authorize the Property Manager to execute the purchase and sale agreement and all necessary documents to close the transaction CHANG: Second VOTE: ADAI R: Yes CHANG: Yes DEBONE: Chair votes yes. Motion Carried ADJOURN: Being no further items to come before the Board, the meeting was adjourned at 1:52 p.m. DATED this l Day of / l 2023 for the Deschutes County Board of Commissioners. ANTHONY DEBONE, CHAIR 4"--- PATTI ADAIR, VICE CHAIR BOCC MEETING MARCH 29, 2023 PAGE 10 OF 11 ATTEST: PHIL CHANG, COMMISSIONER RECORDING SECRETARY BOCC MEETING MARCH 29, 2023 PAGE 11 OF 11 1�vI E S co BOAR® OF COMMISSIONERS MEETING DATE: March 29, 2023 SUBJECT: Final Decision for a Commercial Activity in Conjunction with Farm Use (Meadery) in the Exclusive Farm Use Zone (File nos. 247-22-000024-CU, 025-SP, 757-A, 914- A) RECOMMENDED MOTION: Move approval of final decision for file nos. 247-22-000024-CU, 025-SP, 757-A, 914-A. BACKGROUND AND POLICY IMPLICATIONS: During deliberations on March 8, 2023, the Board of County Commissioners "Board" approved a Commercial Activity in Conjunction with farm use (Meadery) in the Exclusive Farm Use Zone. Eight (8) issue areas were discussed and are summarized below: • Is the subject property currently engaged in farm activities with the intent to make a profit in money? Yes, the Board found that the subject property is currently engaged in farm activities with the intent to make a profit in money. • Is the Meadery incidental and subordinate to the farm use on the property? Yes, the Board found that the Meadery is incidental and subordinate to the farm use on the property. • Does the application fully satisfy the requirements of the Farm Impacts Test? Yes, the Board found that the application fully satisfies the requirements of the Farm Impacts Test. • Can the transportation System Development Charges (SDCs) be reduced based upon the revised site traffic report? Yes, the Board found that the SDCs can be updated in the Board's decision. • Should the January 25, 2023, Matt Cohen email be treated as a hearing exhibit and excluded from the record, or should the record be reopened to allow participants to address the email as a record item? The Board found that emai► should be included in the record. • Can the 25% requirement for Mead honey to be produced on site be removed? Yes, the Board found that the 25% production requirement can be removed. • Is a Meadery allowed in the Exclusive Farm Use Zone? Yes, the Board found that a Meadery is allowed in the Exclusive Farm Use Zone. • Can the Applicant's Conditions of Approval be adopted into a Decision? Yes, the Board found that the Applicant's Conditions of Approval be adopted into the decision. Based upon the Board's direction, Planning Staff has prepared the decision for final approval and signatures. Staff notes that the decision was reviewed by Deschutes County Lega► Counse►. Attachment A: BOCC Decision for File Nos. 247-22-000024-CU, 025-SP, 757-A, 914-A BUDGET IMPACTS: None ATTENDANCE: Nathaniel Miler, Associate Planner Jacob Ripper, Principal Planner REVIEWED LEGAL COUNSEL For Recording Stamp Only DECISON OF THE DESCHUTES COUNTY BOARD OF COUNTY COMMISIONERS FILE NUMBER: 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22- 000914-A SUBJECT PROPERTY/ OWNER: Mailing Name: HERMAN, JOHN & RENEE ET AL Map and Taxlot: 1510100000700 Account: 135891 Situs Address: 68540 HWY 20, SISTERS, OR 97759 APPLICANT: John Herman ATTORNEY FOR APPLICANT: Liz Fancher 2465 NW Sacagawea Lane Bend, OR 97703 STAFF REVIEWER: Nathaniel Miller, AICP, Associate Planner REQUEST: The applicant request a Conditional Use Permit for commercial activities in conjunction with farm use to establish a Meadery (Honey Winery) with associated uses. The request also includes a Site Plan Review for the Meadery. APPLICABLE CRITERIA Title 18 of the Deschutes County Code, the County Zoning Ordinance: Chapter 18.04, Title, Purpose and Definitions Chapter 18.16, Exclusive Farm Use Zones (EFU) Chapter 18.80, Airport Safety Combining Zone (AS) Chapter 18.84, Landscape Management Combining Zone (LM) Chapter 18.56, Surface Mining Impact Area Combining Zone (SMIA) 117 NW Lafayette Avenue, Bend, Oregon 97703 1 P.O. Box 6005, Bend, OR 97708-6005 `q (541) 388-6575 @cdd9deschutes.org @www.deschutes.org/cd Chapter 18.116, Supplementary Provisions Chapter 18.120, Exceptions Chapter 18.124, Site Plan Review Chapter 18.128, Conditional Use Title 22, Deschutes County Development Procedures Ordinance II. BASIC FINDINGS LOT OF RECORD: The subject property is a legal lot of record being platted Parcel 1 of Minor Partition MP-02-44. SITE DESCRIPTION: The subject 83.48-acre property is a developed ranch with 2 single-family dwellings, farm buildings, and supporting ranch infrastructure. The majority of the property is pastureland on the northwest and southeast sides. The developed portion of the property is along the southwest property line which abuts Highway 20. There is a light cover of Ponderosa Pine trees and other vegetation at the northeast, southeast, and around the ranch houses and barns. The property is irregular in shape, and fronts on Highway 20 to the southwest and Highway 126 to the northeast. The grade of the property is relatively even across the parcel. The subject property is depicted in Image One below. Image One - Subject Property 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 2 of 86 PROPOSAL: The applicant requests a Conditional Use Permit for commercial activities in conjunction with farm use to establish a Meadery (Honey Winery) with associated uses. The Meadery will operate similarly to a small grape winery [ORS 215.452 & DCC 18.16.038(B)(2)] combining wine production and onsite sales, events, consumption, and education but with additional limitations prescribed by conditions of approval. As outlined below, the proposed Meadery as the commercial activity includes the following associated uses (actions) and subordinate features: Associated Uses (Actions) 1. Mead Production, Aging, & Packaging 2. Market and sell wine produced in conjunction with the winery and directly related activities only' Subordinate Features (Limited to 25 percent of the gross income from the on -site retail sale of wine produced in conjunction with the winery) 1. Market and sell items directly related to the sale or promotion of wine produced in conjunction with the winery including food sales 2. 10 Winery Related Events2 excluding weddings The proposed Meadery use will occur in an existing 3,000-square-foot farm building which will be converted to the "Winery Building." The production, parking, tasting area and food cart adjoin, or are in close proximity to, the Winery Building. The Winery Related Events will be staged in the same general area but include a lawn and stage area to the northwest, as well as additional parking to the north and east. As the Associated Uses (Actions) and Subordinate Features differ with respect to characteristics, function, and location on the site, the Board classifies the uses into the following three aspects for the purposes of this review: I. Mead Production Mead Production, Aging, & Packaging II. Winery Operations Winery Indoor & Outdoor Tasting Area & Wine Sales Up to 1 Food Cart 111. Winery Related Events Events (10 Events Annually) • Up to 2 Additional Food Carts The application also includes a Site Plan Review for the Meadery. The general location of the Meadery including the Winery Building is depicted in Image Two below. The Meadery application proposes to conduct certain activities allowed and as limited by ORS 215.452, while recognizing that a meadery (honey winery) is similar to, but operates differently than, a small grape winery. Certain of these activities are further limited by the conditions of approval of this decision. The applicant did not seek approval of an ORS 215.452 winery because it does not have a vineyard. z The term "Winery Related Events" is the same as "agri-tourism and other commercial events" allowed by ORS 215.452(5) for grape wineries. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 3 of 86 Image Two - Meadery (General Location) The Winery Related Events will be located at the Meadery location and will include additional parking spaces to the east and the lawn area to the northwest. The general location of the Meadery with the location of Winery Related Events is depicted in Image Three below. Image Three - Meadery with Winery Related Events Area (General Location) The general site plan for the Meadery (Mead Production & Winery Operations) and the site plan for the Meadery with Winery Related Events is included with the decision as Attachment A and 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 4 of 86 Attachment B. The applicant proposes to use the existing 3,000-square-foot building for the Winery Building. No new substantial development is currently proposed. SURROUNDING LAND USES: Immediately surrounding properties to the north, west, south and east are all EFU-zoned lots in relatively similar sizes to the subject property. These surrounding properties are predominately pastureland. The neighboring properties to the east are developed with a single-family dwellings. Farm uses are visible from aerial imagery for the majority of properties abutting the subject parcel. LAND USE HISTORY: • MP-02-44: Minor Partition creates property as Parcel 1 with 83.48 acres • FPA-04-16: Final Plat Approval for MP-02-44 • 247-22-000024-CU, 247-22-000025-SP: Subject review for a Conditional Use Permit and Site Plan approval for a Meadery Property records contain additional land use approvals that pre -date the creation of the subject parcel. These land use documents can be accessed through Deschutes County's land information website Dial: https://dial.deschutes.org/Search/General. PUBLIC AGENCY COMMENTS: The Planning Division mailed notice on January 28, 2022, to several public agencies and received the following comments: Deschutes County Building Division, Randy Scheid NOTICE: The Deschutes County Building Safety Divisions code mandates that Access, Egress, Setbacks, Fire & Life Safety, Fire Fighting Water Supplies, etc. must be specifically addressed during the appropriate plan review process with regard to any proposed structures and occupancies. Accordingly, all Building Code required items will be addressed, when a specific structure, occupancy, and type of construction is proposed and submitted for plan review. Deschutes County Senior Transportation Planner, Peter Russell A Trip Generation Forecast was included with the response to the Incomplete Letter that was submitted to the Planning Division on March 8, 2022. In response to the submittal, Peter Russell provided the following comment: The trip generation letter is acceptable and answers the transportation questions. Thanks for sending it along. At staffs request, Peter Russell provided updated SDC rates for the current fiscal year on July 21, 2022: 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 5 of 86 Here are the updated talcs using the new SDC rate of $5,080 per peak hour trip. Board Resolution 2013-020 sets the transportation system development charge (SDC) amount and the applicant initially used an outdated rate of $4,757 per peak hour trip. In the provided Trip Generation Forecast, it was considered that since the tasting room would be closed 2 out of 5 weekdays, the average weekday traffic would not be accurately calculated by directly applying an Institute of Traffic Engineers (ITE) trip generation rate. The average rate was calculated as shown in Table 4 below: Table 4 — Final Trip Generation Forecast ITE Land Use Size (units) PM Peak Hour Trip Ends In out Total Daily Wine Tasting Room 970 1.537 t.s.f. 3 4 7 42 Manufacturing 1.40 1.463 t.s.f. 0 1 1 7 Food Carl Pad 926 Food Carts See wine -fasting below Wine Tasting Room 970 Internal Trips for Employees Living in Site (50 percent of Manufacturing trips) 0.096 t.s.f. 0 0 1 0 1 0 4 -4 Su 6total -- Eidemal Trips 3 6 9 49 Poss-by trips for Tasting Room (25 percent) 1 1 2 11 Total Non-Passb Tri 2 5 7 39 Also, the food cart would not attract traffic at this location as a stand-alone operation. To account for this, it was considered to be a small -kitchen extension of the wine -tasting operation. The resulting forecast was 9 p.m. peak hour trips and for 49 daily trips, of which 7 p.m. peak hour trips and 39 daily trips would be non -pass -by, aka site -generated, trips. This is a reasonably conservative approach considering that the family would also work on the site, which would eliminate some work trips - and that some of the trips would likely be pass - by trips for people driving between Bend and Sisters. At this level of weekday traffic generation, no further traffic studies are needed under Deschutes County Code (DCC) 18.116.310(C)(a). The resulting SDC is $35,560 ($5,080 X 7). The SDC is due prior to issuance of certificate of occupancy; if a certificate of occupancy is not applicable, then the SDC is due within 60 days of the land use decision becoming final. The County has both an SDC appeal process and a 10-year payment plan option; however, if the 10-year payment plan is used, the County becomes the holder of a first -place lien. THE PROVIDED SDC AMOUNT IS ONLY VALID UNTIL JUNE 30, 2023. DESCHUTES COUNTY'S SDC RATE IS INDEXED AND RESETS EVERYJULY 1. WHEN PAYING AN SDC, THE ACTUAL AMOUNT DUE IS DETERMINED BY USING THE CURRENT SDC RATE AT THE DATE THE BUILDING PERMIT IS PULLED. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 6 of 86 Oregon Department of Agriculture - Food Safety Program, Jon Harrang To Whom it May Concern, Food/beverage processing facilities such as those that produce Mead (honey wine) must be licensed and inspected by ODA Food Safety Program. A tasting room associated with the production facility would also be subject to licensing and inspection. The processing facility must comply with the minimum standards set forth in 21 CFR 117. The tasting room would be subject to the Retail Food Code, OAR 603 Division 25. An adequate supply of potable water is required. In addition, the firm must demonstrate that solid and liquid waste are being properly disposed of. A septic authorization letter from Deschutes County Environmental Health or the equivalent approval from DEQ would be needed as a prerequisite for licensing, depending on which agency has the jurisdiction in this matter. Please note that OLCC and TTB may have additional requirements which relate to production, sales, and serving of alcoholic beverages to the public. Food cart licensing and inspection would be handled by Deschutes County Environmental Health Department. Please contact me if Deschutes County Planning Staff or the applicant should have any questions and/or if further discussion or clarification are needed. Deschutes County Health Services, Eric Mone I received this Notice of Application for a Conditional Use permit at 68540 HWY 20, Sisters. Thanks for sending. A few considerations: - if this property is served by a private well, it needs to be reviewed and approved as a Public Water System by either Oregon Dept of Ag (ODA) or our EH dept - Licensure of Meadery will depend on their predominant activity (sales, tasting room, foodservice); that will determine whether Licensure required by ODA or EH - Mobile Food Units (MFU, e.g. carts) will all require licensure by EH - Not sure if the MFU's will only be on site for events a few times per year or permanent. If permanent, it would be best for Public Health purposes if they were tied into the on -site septic system, the well, and a power source on site. - Todd's team is reviewing septic system so that will be a major consideration As this application process moves forward, please let me know if you have any questions. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 7 of 86 Oregon Department of State Lands (DSL), Mathew Unitis We have completed our review of the Wetland Land Use Notification that was prepared for John Herman - John Herman The WLUN form was submitted to the Department for review/response and given the file number WN2022-0080 The results and conclusions from that review are explained in the attached pdf documents. If the attached documents are illegible or difficult to open, you may contact the Department and request paper copies. Otherwise, please review the attachments carefully and direct any questions or comments to jurisdiction Coordinator, Matthew Unitis at 503-986-5262 or Matthew.Unitis@dsl.oregon.gov. Thank you for your interest in the project. Additional resources that may be helpful: DSL Coordinator List (https://www.oregon.gov/dsl/ww/pages/wwstaff.a5px) R/F Fee Schedule (https://www.oregon.gov/dsl/WW/Documents/RemovalFiliFees.pdf) Aquatic Resource Management Program Oregon Department of State Lands 775 Summer St. NE, Ste. 100 Salem, OR 97301-1279 Fax: (503) 378-4844 https://www.oregon.gov/dsl/Pages/index.aspx The Wetland Land Use Notice Response includes the following comments: Wetland/Waterway/Other Water Features [x] There are/ may be wetlands, waterways or other water features on the property that are subject to the State Removal- Fill Law based upon a review of wetland maps, the county soil survey and other available information. [x] The National Wetlands Inventory shows wetland, waterway or other water features on the property Your Activity [x] A state permit will not be required for the proposed project because, based on the submitted site plan, the project avoids impacts to jurisdictional wetlands, waterways, or other waters. The full DSL Wetland Land Use Notice Response is included as Attachment C. The following agencies did not respond to the notice: Deschutes County Assessor, Three Sisters Irrigation, Deschutes County Environmental Soils Division, Sisters -Camp Sherman Fire District, Deschutes County Road Department, Oregon Department of Fish and Wildlife, Oregon Department of Transportation, and US Fish and Wildlife Service. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 8 of 86 PUBLIC COMMENTS: The Planning Division mailed notice of the conditional use application to all property owners within 750 feet of the subject property on December 12, 2021. The applicant also complied with the posted notice requirements of Section 22.24.030(B) of Title 22. The applicant submitted a Land Use Action Sign Affidavit indicating the applicant posted notice of the land use action on January 28, 2022. Public comments were received and are included in the record. Central Oregon LandWatch, Kristy Sabo January 28, 2022 Concern over Application 247-22-000024-CU. While we are still reviewing the applications and all of the issues, we are initially concerned that the Conditional Use application for a Meadery in Conjunction with Farm Use does not meet all of the applicable criteria/ that the burden of proof is not satisfied for all criteria, specifically under DCC 18.128. Thank you for your attention to these views, and please keep us informed of any decisions in this matter. The Boards notes that Central Oregon LanclWatch submitted the following comments on January 25, 2023 specific to the project's revised operational scope and conditions of approvals: Hello Nathaniel and Will, Central Oregon LandWatch submits this comment to the Board of County Commissioners for today's hearing on Application File Nos. 247-22-000024-CU and 247-22-000025-SP. LanclWatch does not oppose the application so long as the applicant's proposed conditions of approval are adopted in a final decision by the Board. If the applicant's proposed conditions of approval are not adopted in a final decision by the Board, then LandWatch renews its comments against this application, which the Hearings Officer agreed with, attached here. Regards, Rory Isbell As addressed below in this decision, the Board applies the revised conditions of approval as proposed by the applicant. Neighbor. Matt Cohen February 14, 2022 The applicant within the burden of proof did not address the "Change of Use" forthe existing driveway that is currently served and accessed via the State Highway Connection. Based on 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 9 of 86 information contained in the application the applicant is requesting a conditional use be approved for "Commercial Activities in Conjunction with Farm Use." The existing driveway is not presently approved for Commercial Activity, and as such a modification will require the approval of the Oregon Department of Transportation in compliance with the permitting process for a Private Approach to a State Highway in compliance with ORS 374. Furthermore, the applicant within the burden of Proof has not provided a TIA such that the traffic impacts of the conditional use being proposed can be properly evaluated. For the record, I am not opposed to this Conditional Use, but I am concerned about how the existing access points off of Highway 20 can safely accommodate the proposed volume of traffic. Assuming the bulk of the traffic that will be visiting the site will result from trips generated in the City of Sisters, it means drivers will be forced to make a left hand turn across an active lane of a state highway without the safety and protection of a center turn lane, this is furthermore complicated by the fact the existing driveway is located on a curve with limited site distance, giving drivers approaching from the west an unreasonable amount of time to react to a vehicle stopped in the highway awaiting a break in traffic to make a turn. I reside at 16165 Jordan Road Oust 1/8 mile to the east) and I am forced to make the same turn into our driveway approach off of Highway 20. We experience close calls at this intersection on a daily basis and tragically a motorcyclist was killed at this intersection in July 2020 when another vehicle failed to stop for a vehicle that was stopped making a left hand turn across traffic. i recognize that ultimately ODOT is responsible for the safety and access of our State Highways and will evaluate the application in compliance with all Engineering standards and if required identify any modifications or improvements necessary to protect the public interest. However as a member of the public using this section of the Highway I want to be sure the Conditional Use Application considers and takes into account the ODOT access standards and that this information is presented as findings to the public for review and comment before a decision is issued by the County. No comments were received from the Oregon Department of Transportation expressing any concerns regarding the subject property's existing access to Highway 20. The Board notes that this decision requires the applicant to obtain additional governmental approvals, if any, required to conduct approved land uses. ODOT access standards are not land use approval criteria for the applicant's site plan or conditional use application. County transportation planner Peter Russell has reviewed this application and has not expressed concern about highway safety or compliance with any conditional use or site plan approval criteria. The applicant's transportation system letter shows that the volume of traffic associated with the winery will be very low and, therefore, will have no more than a negligible impact on traffic safety, if any. On September 7, 2022, the Deschutes County Planning Division issued an administrative decision. That decision was appealed by Central Oregon LandWatch. A hearing was conducted by a county 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 10 of 86 hearings officer who issued a decision mailed November 18, 2022 denying the application for two reasons. These reasons were that the hearings officer found that the applicant failed to provide sufficient evidence of compliance with the "incidental and subordinate" and "farm impacts" tests. John Herman appealed the hearings officer's decision to the Board of Commissioners on November 29, 2022. On December 21 2022, the Board agreed to hear the appeal de novo and waived the transcript requirement. BOCC Order No. 2023-02. A hearing regarding the Herman appeal was held by the Board on January 25, 2023. During the hearing, a comment was e-mailed to planner Nathaniel Miller by Matt Cohen and received by the County's computer server prior to the close of the hearing. The Cohen e-mail was not presented to the Board prior to the close of the record at the end of the January 25, 2023 hearing nor was it marked as a hearing exhibit. The applicant objected to inclusion of this e-mail in the record because it was not received as an exhibit during the land use hearing following the procedures of DCC 22.24.090 and was not available for review by the public at the hearing as required by DCC 22.24.120(G). The Board allowed this e-mail to be included in the record because it was a "record item" due to its receipt bythe County's server - an item that is not required to be filed in the manner specified for hearings exhibits in DCC 22.24.090. The Board makes the following findings regarding the issues raised in Mr. Cohen's January 25, 2023 e-mail: A. Mr. Cohen claims "[p]ursuant to DCC 18.144.040, part D item #12 and #13, the applicant has not demonstrated ADA access to all proposed facilities." He also claims the waiver of the requirement to pave parking areas does not provide for ADA accessible paths. The Board finds that Mr. Cohen meant to refer to DCC 18.124.040(D)(12) and (13). DCC 18.124.040(D) is a list of information required to provide a complete site plan. It does not specify relevant approval criteria. It does not provide a basis for denial of the Herman site plan application. Notwithstanding approval of the waiver of paving requirements and Condition of Approval S, the Board finds that applicant may pave any graveled area required to be paved if required to do so by Building Division ADA review. B. Mr. Cohen argues that the applicant has failed to demonstrate compliance with ORS 374.305 which he claims requires "anyone wanting to construct a new approach or change the use of an existing connection to a State Highway to first obtain written permission from ODOT." ORS 374.305 is not a land use requirement. It requires that a change in the manner of using an approach road be approved by ODOT. ODOT has interpreted that requirement in administrative rules to apply only to certain changes of use and has not requested that Mr. Herman obtain approval of a change the use of his access to Highway 20 as a condition of approval of this application. C. Mr. Cohen claims that egress lighting will be required by the Building Division. The Board finds that Condition FF of this decision anticipates this possibility and requires compliance with all relevant site plan criteria related to lighting. Mr. Cohen also requested a photometric light study to show compliance with DCC 18.124.040(D)(11) and a public review of compliance. As determined in item A above, DCC 18.124.040(D) does not supply relevant 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 11 of 86 approval criteria. The only applicable approval criterion that addresses exterior lighting requirements for the Herman property is DCC 18.124.0600). It requires that "[a]II exterior lighting shall be shielded so that direct light does not project off site." Compliance with DCC 18.124.060a) has been assured by the imposition of Condition of Approval FF which requires compliance with that standard. The application of this standard to outdoor lighting does not require the exercise of discretion by the County and, therefore, the public does not have a right to insist on a post -approval review to assure compliance. Furthermore, if exterior lighting is required for the winery building and is provided, Mr. Cohen will be able to determine whether the requirements of DCC 18.124.060a) are or are not met by looking at the lights. If a violation occurs, it may be rectified by enforcement of the condition of approval. A review of photometric light studies is not required to determine compliance. Ill. FINDINGS & CONCLUSIONS Title 18 of the Deschutes County Code, County Zoning Chapter 18.16, Exclusive Farm Use Zones (EFU) Section 18.16.020 Uses Permitted Outright. A. Farm use as defined in DCC Title 1& FINDING: DCC 18.04.030 defines "farm use" as the following: "Farm use" means the current employment of land for the primary purpose of obtaining a profit in money by raising, harvesting and selling crops or by the feeding, breeding, management and sale of, or the produce of, livestock, poultry, fur -bearing animals or honeybees or for dairying and the sale of dairy products or any other agricultural or horticultural use or animal husbandry or any combination thereof. "Farm use" includes the preparation, storage and disposal by marketing or otherwise of the products or by-products raised on such land for human or animal use. "Farm Use" also includes the current employment of the land for the primary purpose of obtaining a profit in money by stabling or training equines, including but not limited to, providing riding lessons, training clinics and schooling shows. "Farm use" also includes the propagation, cultivation, maintenance and harvesting of aquatic species and bird and animal species to the extent allowed by the rules adopted by the State Fish and Wildlife Commission. "Farm use" includes the on -site construction and maintenance of equipment and facilities used for the activities described above. "Farm use" does not include the use of land subject to the provisions of ORS chapter 321, except land used exclusively for growing cultured Christmas trees as defined in ORS 215.203(3). Current employment of the land for farm use also includes those uses listed under ORS 215.203(2)(b). The applicant provided the following response in the Burden of Proof: The subject property is employed in farm use. Our current revenue streams are from the 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 12 of 86 sale of bee colonies (sold out both the 2021 and 2022 seasons,), hive sponsorships, the boarding of horses (since purchasing the ranch in mid 2020), and strategic crop share agreements with local graziers for the production and sale of beef. We also hayed a field in 2021 and 2022 in order to feed our boarded horses and sell. We do all of these farm uses with the intention of making a profit in money. So far, we have reinvested all profits back into these farming ventures with the intention of generating a greater profit in money. Meanwhile, we continue to invest financially in our Regenerative Bee Pastures (bi-annual seeding, irrigation, cultivation) and apiaries (equipment and off-season feed) with the goal of generating a profit in money. This year we have more than doubled both our bee and honey sales, and have more than tripled the size of our apiary, as well as doubled the amount of grazing days possible by beef cattle. In 2022, our farm grossed $31,405 in income from these farm uses, and produced an additional $10,000 to $12,000 worth of honey we are stockpiling to make mead. This income is expected to increase in 2023 or 2024 when we plant an additional 22 acres of bee pastures to support the growth of our apiary. (See Exhibit S) Furthermore, the term "current employment of land for farm use" is defined by ORS 215.203(b)(C) to include the subject property which includes "land planted in orchards or other perennials prior to maturity." Our Regenerative Bee Pastures contain a dramatic combination of establishing perennials, including such flora as alfalfa, nine types of clover, sainfoin, vetch, plantain, and drought tolerant grasses such as Sorghum Sudan. As noted in the application, we currently have over 30 acres of Regenerative Bee Pastures, with 22 more acres planned for production this or the following season. These Regenerative Bee Pastures exponentially increase our ability to proliferate bee colonies for sale, harvest plant nectar in the form of honey, harvest hay, and graze cattle for the sale of beef. John Herman is the owner of two companies, and moved from part time to full time development/operation of the bee ranch in January of 2021. Lazy Z Ranch LLC is the single - member LLC which cultivates the land for bee and honey production for a profit in money (as well as runs the horse boarding facility and assists with high density grazing operations). Once approved, Lazy Z Meadery LLC is the company that will run the Meadery, instantly creating an additional market for the bee and honey business operated on the subject property by Lazy Z Ranch LLC and for other Central Oregon beekeepers, such as Jimmy at Broadus Bees, Devon at Prescott Apiaries, and Matt at Apricot Apiaries. All ingredients in mead are grown/cultivated/harvested on farms and our commitment to creating a uniquely Central Oregon mead as Lazy Z Meadery LLC's value-added farm product bolsters farm use profitability for all farmers involved, including Lazy Z Ranch LLC (See Exhibit U). In addition, we only sell our bees to people in the Sisters area, and maintain these relationships to ensure the proliferation of more pollination and honey production, benefitting not only the profitability of our ranch and future winery, but farms and ranches for miles in every direction. The Board finds the subject property is actively engaged in farm use as defined by County code and 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 13 of 86 ORS 215.203(1). Section 18.16.030. Conditional Uses Permitted- High Value and Non -high Value Farmland The following uses may be allowed in the Exclusive Farm Use zones on either high value farmland or non -high value farmland subject to applicable provisions of the Comprehensive Plan, DCC 18.16.040 and 18.16.050, and other applicable sections of DCC Title 18. E. Commercial activities that are in conjunction with farm use, but not including the processing of farm crops as described in DCC 18.16.025. FINDING: The Board finds the use permitted conditionally under this paragraph includes Varee. 4 W 0 components: (1) it must be a "commercial' activity;" (2) it must be "in conjunction with farm use." The processing of farm crops is allowed by Section 18.16.025 is not a conditional use and does not require approval as a commercial activity in conjunction with farm use. Mead Production, Winery Operations, and Winery Related events are all authorized by approval of the proposed commercial activity in conjunction with farm use. Operational Characteristics I. Winery Operations The Winery Operations will have the following characteristics: • Located 'in, and outside adjacent to, the Winery Building • Open Year Round • Open from 12:00pm to 10:00pm Thursday to Sunday, and on Holidays which fall on a Monday when Mead Production is not open. Mead production will typically occur when the winery is closed. • Up to 4 Employees • Up to 126 Weekly Visitors during "Off Season" and up to 246 Weekly Visitors during "Peak Season" • 1 Food Cart • Occurs on less than 2% of the subject property (includes Mead Production location) Ill. Winery Related Events The Winery Related Events will have the following characteristics and be in addition to the above - mentioned Mead Production and Winery Operations: • Located at the Winery Building and Lawn/Stage Area • Open Year Round (Primarily May - October) • Open from 10:00am to 10:00pm • Up to 5 Employees • 5 Events of Up to 250 Visitors Per Event • 5 Events of Up to 150 Visitors Per Event • Up to 2 Additional Food Carts o Hours from 10:00am to 10:00pm 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 14 of 86 • Occurs on less than 3% of the subject property (includes Winery Operations location) The employee count includes the applicant as the owner/operator and excludes the 1 food cart employee for Winery Operations and the 2 food cart employees during a Winery Related Event. The Oregon Court of Appeals has developed a test for evaluating commercial activities in conjunction with farm use. Friends of Yamhill County v. Yamhill County, 255 Or App 636, 298 P3d 586 (2013). It requires four findings: 1. The use relates to a farm use occurring on the subject property; and 2. Any commercial activity beyond processing and selling farm products must be incidental and subordinate to the farm use (frequency and intensity when compared to the farm use on site, spatially, operating hours); and 3. The use enhances the quality of the agricultural enterprises of the local agricultural community; and 4. The use promotes the policy of preserving farm land for farm use The use approved by Yamhill County was characterized as an "event venue and commercial food service facility" by opponents. It was proposed in conjunction with a winery. The Court of Appeals rejected the argument that these uses cannot be considered "in conjunction with farm use." Instead, it found that the Supreme Court decision in Craven v. Jackson County, 308 Or 281, 779 P2d 1011 (1989) merited approval of the use. In Craven, the courts upheld that a commercial activity in conjunction with farm use is one that assists farms in processing and marketing crops as well as one that aluS farmers in producing Crops. n ^rr!inrr to the applicant ;n ! rri are 4— r Me-a0s; be-th. sell. the fl-a.r.m.. products in a prepared form and aid the far.m. eperatiOR in processing a -Rd marl<oting crops to the public The following findings address how the various aspects of the applicant's proposal meet the Friends of Yamhill County test: Related to Farm Use A honey winery is related to the production of honey and bee pastures and pollinator gardens that have been established on the subject property. The production of mead involves the processing of honey, a farm product produced on site, for sale at the proposed winery. As a result, the proposed commercial activity in conjunction with farm use that includes both the production and sale of wine relates to a farm use occurring on the subject property. The applicant also proposes one food cart to serve food while the Winery is open. To demonstrate how the food cart is related to the farm uses on the site, the applicant provided the following statement: All food carts will offer honey to patrons as a condiment for food sold at the cart and/or feature honey in at least one food item offered at the food cart. The food carts will, from time -to -time, sell beef. The ranch relies on targeted, ultra -high density cattle grazing to improve the health of the soil in its bee pastures. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 15 of 86 There will be a maximum of one food cart on site except on the limited number of days when events will occur on the property. The purpose of the single food cart is to highlight honey in another capacity (ingredient in food), provide food with mead to lessen the impact of consuming alcohol, and to make consuming mead more enjoyable - hence increasing sales of mead made from honey produced by one of the farm uses occurring on -site. The purpose of the food carts for events is to meet the food needs of guests. The primary purpose of events is to raise awareness and sales of mead in the tasting room and in off -site retail locations if/when retail sales occur in the future. This decision also authorizes a maximum of ten agri-tourism or commercial events per year, events referred to as Winery Related Events. The Winery Related Events support the Meadery/Winery. The application materials state: "The purpose of having the events is to bolster the marketing/sale/brand of the Meadery/Winery. Events will be selected based on their commitment to feature Lazy Z products. All listed examples arejust that: examples of the type of events that would support the Meadery/Winery through customer engagement and differentiated experience of our products." The property is engaged in several farm uses in addition to the production of honey such as the sale of bee colonies, hive sponsorships, horse boarding, crop share agreements with local graziers for the production and sale of beef, growing and selling pumpkins, and hay production and sales. To demonstrate how Winery Related Events are related to the farm uses on the site, the applicant provided the following statement: "The tasting room facility will remain open at events and ranch wines will be featured at all events. Examples include mead/wine festivals, family gatherings that feature our wine products, concerts that raise awareness for pollinator habitat, etc. The bee ranch/farmhouse meadery "theme" would be present at all events. All events would point back to the ranch mead, pollinators, and/or regenerative farming. Promotional materials for events will typically include information advertising the winery and ranch. Events are an accepted practice at any winery for the purpose of increasing sales of wine as well as generating income to help support farming operations. The ranch also raises hay. Hay bales can be used as decorations at events, if necessary, to promote the sale of hay. The ranch boards horses and raises goats. The events will raise awareness of the horse boarding operation and goat products. The ranch also grazes cattle to enhance the productivity of its regenerative bee pastures. Grass-fed beef will be featured at the events in at least one of the three food carts." The applicant also proposes up to two food carts to serve food during a Winery Related Event. To demonstrate how the food cart is related to the farm uses on the site, the applicant provided the following statement: "All food carts will offer honey to patrons as a condiment for food sold at the cart and/or feature honey in at least one food item offered at the food cart. The food carts will, from 247-22-000024-CU, 247-22-000025-sP, 247-22-000757-A, 247-22-000914-A Page 16 of 86 time -to -time, sell beef. The ranch relies on targeted, ultra -high density cattle grazing to improve the health of the soil in its bee pastures. There will be a maximum of one food cart on site except on the limited number of days when events will occur on the property. The purpose of the single food cart is to highlight honey in another capacity (ingredient in food), provide food with mead to lessen the impact of consuming alcohol, and to make consuming mead more enjoyable - hence increasing sales of mead made from honey produced by one of the farm uses occurring on -site. The purpose of the food carts for events is to meet the food needs of guests. The primary purpose of events is to raise awareness and sales of mead in the tasting room and in off -site retail locations if/when retail sales occur in the future." Based on the above findings, the Board finds the food carts to be related to the farm uses on the site. To ensure compliance with this requirement and the incidental and subordinate test discussed below, the following condition of approval is imposed: Food Carts A maximum of one food cart is allowed to provide food for tasting room visitors. A maximum of two additional food carts may be allowed at events. All food carts shall offer honey as a condiment and shall have at least one food item featuring honey on the menu. Based on the above, the Board finds the Winery Related Events and food carts to be related to the farm uses on the site. Activity is incidental and subordinate The farm use of the Herman property is raising honey bees to produce honey, cultivating regenerative bee pastures, growing crops (pumpkins and berries), grazing livestock, and boarding horses. The law allows the Board to approve the winery as a commercial activity in conjunction with farm use. DCC 18.16.030(E). When a winery is approved as a commercial activity in conjunction with farm use, the following "incidental and subordinate" test applies: "[A]ny commercial activity beyond the direct processing and selling of wine must, to be approved as a commercial activity in conjunction with the farm use of viticulture, [must be] both incidental and subordinate to the processing and selling activities of the winery." Friends of Yamhill County v. Yamhill County, 255 Or App 636, 650-651, 298 P3d 586 (2013) discussing Craven v. Jackson County, 308 Or 281, 779 P2d 1011 (1989). The processing and selling of wine is a part of the farm use. It is not subject to the "incidental and subordinate" test. Only other commercial activities associated with a winery require approval as a conditional use in conjunction with farm use. In Craven, this included the incidental sale of items such as t-shirts, wine glasses and cork screws. As determined by the appealed Staff Decision, the 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 17 of 86 incidental and subordinate test applies to "any commercial activity beyond processing and selling farm products." Staff Decision 247-22-000024-CU/-25-SP, p. 16. Mr. Herman is harvesting honey from his apiary to use in making wine. Under the Craven analysis the making and sale of wine is a part of or accessory to farm use. Honey is the sugar of the plants being cultivated in the regenerative bee pastures. Mr. Herman has established over 30 acres of regenerative bee pastures. They produce abundant and high -quality honey that he will use to make honey wine. This decision imposes the following condition of approval: "The gross income of the winery from any activity other than the production or sale of wine may not exceed 25 percent of the gross income from the on -site retail sale of wine produced in conjunction with the winery. The gross income of a winery does not include income received by third parties unaffiliated with the winery." This condition, in addition to other elements of the applicant's proposal, acts to achieves compliance with the incidental and subordinate test of Craven. Mr. Herman's application also achieves compliance with the incidental and subordinate test by confining winery activities to those allowed for small wineries by ORS 215.452 and imposing additional restrictions in the conditions of approval of this decision. The following is a summary of the additional restrictions that achieve compliance with the incidental and subordinate test: • 30 acres of the winery property must be maintained as bee pasture. • Honey will be produced on site and sold or used to make wine. • Agritourism and other commercial events are reduced to ten days per year. Attendance is capped at 150 persons for five events and 250 persons for five events. • The winery must gross $40,000 from the on -site retail sale of wine produced in conjunction with the winery prior to conducting agritourism and other commercial events. • Annual reporting of compliance with the 25% gross sales rule of ORS 215.246. A violation of this requirement in two consecutive years renders this approval void. • All honey must be produced in Oregon and 90% of the honey used to make mead must come from a subset of Oregon counties. • Annual reporting of compliance with the honey source condition of approval. A violation of this requirement in two consecutive years renders this approval void. • Limits on the number and operation of food carts. Further, this Decision assures compatibility with area farm uses by imposing conditions on events of the type that may be imposed to achieve subordinance for ORS 215.452 wineries. These include limits on the number of event attendees, hours of operation, access, parking, and noise. Other limits imposed that aid in achieving compliance with the incidental and subordinate test include limits on lighting, visual impacts from Highway 20, size of outdoor seating, and landscaping. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 18 of 86 Finally, the hearings officer raised a concern regarding the number of employees that might be employed by the winery. He did not, however, account for the fact that most of the time spent by these employees will be spent to produce and sell wine - activities not subject to the incidental and subordinate test. Additionally, the hearings officer did not recognize the fact that a considerable amount of farm labor is required. It is provided by the Hermans, friends and family of the Hermans, independent contractors (work in bee pastures), and by the owner of the cattle that graze in the regenerative bee pastures.' Almost all visitors will be coming to the Herman property to buy or taste wine. Most employee time will be spent producing and selling wine; not engaging in activities subject to the incidental and subordinate test such as selling/preparing food or selling promotional items. Additionally, the Herman farm requires labor from contractors (bee pasture preparation), family and friends, and the rancher whose cattle graze on the Herman property. The nature and intensity of the farm use occurring on the Herman property makes it clear that the farm use is the primary and dominant use of the property. A large part of the subject property is devoted to crop, bee pasture and livestock production (currently 76%) and horse boarding (currently 6%). These activities are all labor-intensive. Livestock grazing prepares the bee pastures for annual planting. The Winery Related Events will include the sale of wine and farm goods, wine tasting, commercial and recreational functions, and educational opportunities. These uses will occur within the 3,000- square-foot Winery Building, an outdoor area that is approximately 2,500 square feet, and an outdoor lawn area of approximately 13,000 square feet for a total of approximately 0.43 acres. in contrast, the regenerative bee pastures and apiaries cover an area of approximately 30 acres, with additional bee pastured planned to occur in the near future. The Winery Related Events are limited to 10 events/10 days per year. The bee pastures will be operational 365 days per year. For these reasons, the areas of operation and operating days of events will be incidental and subordinate to the bee pastures, associated livestock grazing and apiaries, as well as to wine production and sales. Based on the above, and as conditioned, the Board finds that Winery Related Events will be incidental and subordinate to the farm use on the property. Enhance farm enterprises of the local agricultural community The Burden of Proof States: "The proposed use will enhance the quality of the agricultural enterprise by providing a market for farm products used to make honey wine (honey and other farm produce used in various honey wines). It will provide income to allow the Hermans to expand their bee pastures and pollinator gardens and the number of hives kept on their property. The winery will also support the agricultural enterprise of beekeeping by developing and selling hives to other area farmers, providing a valuable on -ranch educational experience regarding the 3Income from cattle is shared and only that part earned by the Herman family is stated as the income from farm use on the Herman property. Mr. Herman assists with the care of the cattle when they are grazing on his property. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 19 of 86 importance of pollinators/pollination, as well as the acquisition of additional honey from other local beekeepers for winemaking. It will also support the broader agricultural community dependent on bees to pollinate farm crops and the growth of and establishment of commercial beekeepers in the area". The Board agrees with the applicant's findings. The local agricultural community includes commercial apiaries, including Broadus Bees. They will be able to market honey to the Herman winery. The existence of an expanded market for honey will also provide an incentive for area farms to raise bees and produce honey for sale to the winery. The winery also supports the maintenance and development of bee pastures, with associated livestock grazing, on the subject property. The associated livestock grazing operation occurs both on the subject property and on other lands in the local agricultural community. As noted by the Hearings Officer, The Craven decision is informative in this regard. It found that a winery improves the local agricultural community because it provides a local market outlet for grapes of other growers in the area. The Court also noted that it helps transform a hayfield into a vineyard, which increases the intensity and value of agricultural products. LUBA has also found in City of Sandy v. Clackamas County that to demonstrate an activity enhances the local agricultural community, "a commercial activity in conjunction with farm use must be either exclusively or primarily a customer or supplier of farm uses."' In this case, the Herman Meadery/winery is primarily a customer of honey, a farm product produced by the Herman farm and other area farms. We agree with the Hearings Officer finding that the Applicant's proposal here is nearly identical to the situation in Craven and City of Sandy v. Clackamas County. Specifically, the Applicant proposes to purchase honey from other farmers and to consume honey it produces on its property. The Applicant also proposes to develop regenerative bee pastures which enrich the soils and, ultimately, increase the intensity and value of agricultural honey products. The Applicant's proposal, therefore, enhances farm enterprises in the local farm community. Events at the Winery will help promote the sale of mead, honey, meat and vegetables from Lazy Z Ranch. The sale of farm products by the ranch is a use permitted outright in the EFU-SC zoning district. Events, therefore, will support both winery and farm uses occurring on -site, increasing profitability for the Ranch as a whole. This marketing strategy should increase revenue for the Meadery and the Herman family. This additional revenue will enable the applicant to maintain and improve the ranch. Promotes the policy of preserving farm land for farm use Wineries promote the preservation of farm land for farm use by creating a strong demand for the farm products used to make wine (grapes or honey). The activities associated with winemaking help market wine and help make it profitable to do so. Most farms in Deschutes County are unprofitable and the cost of acquiring land is high making it necessary for farmers to engage in commercial activities in conjunction with farm use or similar activities to achieve a profit. Making farms 4 City ofSandy v. Clackamas County, 28 Or LUBA 316, 321 (1994). 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 20 of 86 profitable is of key importance in assuring that the land will remain in farm use rather than be allowed to fall into disuse. The production and on -ranch sale of mead provides a viable path to profitability on behalf of the farm use of pollinator habitat and bee ranching. Winery Related Events promote the Meadery and farm products sold at the ranch. As discussed above, and as the application materials note, this enables the applicant to create a more financially viable farm operation and preserves the land for farm use. The promotion of wine and farm products (meat, crops, honey) at events promotes the policy of preserving farm land for farm use by supporting the continued operation of the farm. Conditions of approval have been imposed to assure that events fulfill this purpose. Based on the information and analysis above, the Board finds the proposed commercial activity in conjunction with a farm use, as conditioned, meets each of the four (4) factors established by Friends of Vomhill County (2013). Section 18.16.040. Limitations on Conditional Uses. A. Conditional uses permitted by DCC 18.16.030, 1 & 16.031, and 18.16.033 may be established subject to ORS 215.296, applicable provisions in DCC 18.128, and upon a finding by the Planning Director or Hearings Body that the proposed use: 1. Will not force a significant change in accepted farm or forest practices as defined in ORS 215.203(2)(c) on surrounding lands devoted to farm or forest uses, and 2. Will not significantly increase the cost of accep "red farm or forest practices on surrounding lands devoted to farm or forest use, and FINDING: Addressing the criteria above, the applicant provided findings for the entire scope of the Meadery including the Mead Production, Winery Operations, and Winery Related Events. The applicant inventoried the farm uses and farm practices occurring within a one mile of the subject property boundary. An extensive, lot -by -lot analysis of Farm Impacts Test has been conducted and was attached as Exhibit Q of the applicant's revised burden of proof. The specific findings provided therein provide the factual basis for the findings provided below. The applicant studied an area within a one -mile radius of the winery. This area exceeds the area that might be impacted by any aspect of the approval of this application because properties on the perimeter are not within sight or sound of the winery property and traffic associated with the use is negligible. All properties in this area zoned EFU, MUA, Surface Mining, Flood Plain, or Forestry were inventoried. There are rural residential areas within the one -mile radius. Those not engaged in farm or forest use were not included in the inventory. Land in the City of Sisters was also not included because it is not engaged in farm or forest uses. The one -mile distance was selected because it is the same area used by Deschutes County to assess the impacts of nonfarm dwellings on farm practices and costs. The properties and uses in the one -mile area are listed below. The applicant provided the following analysis in the revised Burden of Proof: 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 21 of 86 Tax Lot Name Use 1510000001400 USA Open space, National Forest managed by USFS 1510000001401 William Smith Properties Single family dwelling, Livestock operation 1510020000100 Deggendorfer Irrigated permanent pasture, Livestock operation 1510020000200 Bradley Irrigated permanent pasture, Livestock operation 1510020000300 Bradley Single family dwelling, No farm use 1510020000400 Smith & Hefter Single family dwelling, No farm use 1510020000500 May Single family dwelling, No farm use 1510090001002 City of Sisters Open space, No farm or forestry use 1510100000400 Rognlien Single family dwelling, No farm use 1510100000500 Parker Single family dwelling, No farm use 1510100000702 Amestoy Single family dwelling, Irrigated permanent pasture, Livestock operation 1510100000704 City of Sisters Livestock operation 1510100000705 Jaros Single family dwelling, Livestock operation 1510100000706 Hawks Haven Irrigated permanent pasture 1510100000708 Plank Single family dwelling, No farm use 1510100000800 Willitts Single family dwelling, Livestock operation 1510110000199 Central Electric Power Lines, No farm use 1510110000200 Hannemann Single family dwelling, No farm use 1510110000202 Pulver Single family dwelling, Livestock operation 1510110000203 OR Dept. of Forestry OR Dept. of Forestry Office, No farm use 1510110000300 Kauffman No farm use 1510110000400 Leonard Single family dwelling, Livestock operation 1510110000500 Leonard Single family dwelling, Livestock operation 1510110000501 Leonard Single family dwelling, Livestock operation 1510110000600 Pearce Single family dwelling, No farm use 1510110000601 Madron Single family dwelling, No farm use 1510110000602 Schlieter Single family dwelling, No farm use 1510110000603 Aldinger Single family dwelling, No farm use 1510110000604 Pike Single family dwelling, No farm use 1510110000605 Pike Single family dwelling, No farm use 1510110000606 Graves Single family dwelling, No farm use 1510110000607 Smith Single family dwelling, No farm use 1510110000608 Smith Single family dwelling, No farm use 1510110000609 Pearce Single family dwelling, No farm use 1510110000610 Henderson Single family dwelling, No farm use 1510110000800 Devries Investment Single family dwelling, Livestock operation 1510110000801 Collins Single family dwelling, No farm use 1510110000900 CFC Group Single family dwelling, No farm use 1510110000901 Kirk Single family dwelling, No farm use 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 22 of 86 1510110000902 Smith Single family dwelling, No farm use 1510110001000 Tewalt Single family dwelling, No farm use 1510110001001 Corning and Estey Single family dwelling, Irrigated permanent pasture 1510110001100 State of Oregon ODOT Maintenance Station, No farm use 1510110001200 Helm No farm use 1510110001201 Helm Single family dwelling, No farm use 1510110001202 Davis Single family dwelling, No farm use 1510110001300 Morrow Single family dwelling, Irrigated Permanent Pasture, Livestock operation 1510110001301 Partipilo Single family dwelling, No farm use 1510110001302 Mostek Single family dwelling, No farm use 1510110001400 Gardner Single family dwelling, Livestock operation 1510140000300 Defoe Single family dwelling, No farm use 1510140000400 Shake, Log and Timber Single family dwelling, No farm use 1510140000600 Brittain Single family dwelling, No farm use 1510140000601 Anderson Single family dwelling, No farm use 1510140000700 TSID Three Sisters Irrigation District 1510140001800 Gardner Livestock operation 1510140001900 MAC Trust Single family dwelling, Irrigated permanent pasture, Livestock Operation 1510140001901 Wigle Single family dwelling, No farm use 15310140001902 Ingelse Single family dwelling, No farm use 1510150000100 Green No farm use 1510150000101 Restrepo Single family dwelling, No farm use 1510150000200 City of Sisters Effluent water disposal, Irrigated permanent pasture 1510150000300 1 Marshall No farm use FINDINGS: 18.16.040(A)(1) & (2), ...will not force a significant change in, or significantly increase the cost of, accepted farm or forest practices... This criterion is the local codification of the Farm Impacts Test from ORS 215.296(I). The Farm Impacts Test requires a farm -by -farm and farm practice -by -farm practice analysis. See Stop the Dump Coal v. Yamhill Cty., 364 Or 432, 445 (2017). However, the test is relevant only to farm and forest uses and farm and forest practices. ORS 215.203(2)(a) defines "farm use" as "the current employment of land for the primary purpose of obtaining a profit in money..." (underline added). The same is true for an "accepted farm practice" which is defined as "a mode of operation that is common to farms of a similar nature, necessary for the operation of such farms to obtain a profit in money, and customarily utilized in conjunction with farm use." ORS 215.203(2)(c) (underline added). The Code parallels these definitions. It may be noted, that according to the USDA's 2017 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 23 of 86 Census of Agriculture for Oregon, the net income from farm operations in Deschutes County was a loss of over $19 million. The first inquiry in analyzing farm and forest impacts is to evaluate the applicant's proposal (the non -farm use) and its potential impacts. Second, in reviewing impacts, it must be determined whether surrounding properties are in fact engaged in farm use. In an excess of caution, we have identified and assessed impacts herein and on the applicant's Exhibit Q without regard to whether the property owner is seeking to obtain a profit in money from farm or forest activities. Third, the proposal is reviewed for whether its impact will "force a significant change" in the accepted farm or forest practice and/or force a significant increase in cost of that accepted farm or forest practice. Analyzing Potential Farm and Forest Impacts of the Meadery and Meadery Related Events Potential farm and forest impacts of a meadery and winery related events could be visual (outdoor lighting), auditory (outdoor sound/music), traffic and/or dust (from additional vehicles), complaints regarding farm and forest practices, and/or trespass (from additional people). Methodology for Identifying Farm Uses and Practices To perform the Farm Impacts Test, all tax lots within one (1) mile of the subject property were queried from county GiS data, yielding 63 tax lots. This is a significant number of tax lots. Many lots are small lots developed with single-family homes or other nonfarm uses that are not used for any agricultural activity. The following analysis: (1) describes the farm and forest practices on surrounding lands devoted to farm use; (2) explains why the proposed winery and winery related events will not force a significant change in those practices; and (3) explains why the proposed winery and winery related events will not significantly increase the cost of those practices. To describe farm practices used by the identified surrounding properties, a combination of methods was employed. First, tax lots were surveyed using satellite images available on DIAL and Google Earth to visually establish whether a particular property was engaged in any farm use. Second, the applicant drove to each and every identified property to further clarify and resolve which properties are engaged in farm uses. The applicant also met with many neighbors to specifically discuss their various uses, which is described in further detail in Exhibit Q. Exhibit Q also contains the complete list of 63 tax lots where the Farm Impacts Test and analysis was conducted. The farm practices occurring on those properties engaged in farm use are typical of other similar operations. The farm practices that might be conducted by certain farm uses have been identified by Oregon State University on sheets that are provided to persons who seek to site nonfarm dwellings on lands zoned EFU. This information was used to assure that all accepted farm uses that might occur on any farm property were included in the analysis 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 24 of 86 below and on Exhibit Q. A copy of that list is included as Exhibit P of the final revised burden of proof. Forest practices are identified and correctly addressed on Exhibit Q of the final revised burden of proof. General Analysis The subject property is surrounded by properties zoned EFU, MUA, Forestry, Flood Plain, Surface Mining, Rural Residential, and the City of Sisters. Only properties zoned EFU, MUA, Surface Mining, Flood Plain, or Forestry were inventoried. There are rural residential exception areas within the one -mile radius, but they are not engaged in farm or forest use, so they are not included on the inventory. Land in the City of Sisters was also not included for the same reason. The one -mile distance was selected because it is the same area used by Deschutes County to assess the impacts of nonfarm dwellings on farm practices and costs. Many lots in this area are so far away from the Herman property that it is evident that the winery will have no impact on farm or forest uses. The farm uses and agricultural uses that exist in the area are best categorized as either livestock uses (predominantly cattle or horse operations) or permanent pasture operations. The farm practices and their potential impacts for these farm uses are identified by OSU in Exhibit P. Within the study area are a combination of grass hay, permanent pasture, forest, bare land, and/or residential uses. Winery operations will not force a significant change in, or increase the cost of, any surrounding farm or forest practices due to siting of the proposed commercial activities on the subject property. Distance from the proposed uses to surrounding farm or forest properties, existing onsite property features, and permanent features adjacent to the subject property will act as buffers to any potential impacts on neighboring farm and forest practices. For example, properties to the south will be buffered by Highway 20. Farm uses to the east and northeast are more than .25 miles from the proposed winery location and will be buffered by on -site farm fields and existing buildings. There is only one property zoned EFU directly north or northwest within 1 mile; all others are residentially -zoned lands. The city limits of Sisters and farm and forest properties to the west are more than .25 miles from the proposed winery location and are buffered by existing on -site dwellings, farm buildings, and farm fields. With respect to a potential for noise to create a significant change in accepted farming or forest practices on adjoining lands from the meadery, there could be a slight yet imperceptible increase in noise from the vehicles traveling to and from the applicant's property, as well as the additional visitors to the site as meadery and/or event patrons and the playing of music. The subject property is located on Highway 20, and the noise created by a typical highway is 70-80 dBa at a distance of 50 ft. This constant wall of traffic sound is already accepted by all adjoining farm and forest land. The meaderywill have a small outdoor speaker in the Outdoor Seating & Garden area playing music at a level at or below the level of noise generated by the highway. This noise will be 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 25 of 86 reduced, also, the sunken topography of the site. The winery will have occasional outdoor music for some of the 10 (maximum) agri-tourism and commercial events. The applicant proposed a maximum decibel level of 100 dBA on the Lawn Event Site. The Board has found, however, that measuring event and winery noise at the property line of the site is preferable. It has considered State of Oregon noise regulations and has considered the sound level of the highway and finds that the following condition of approval will assure that winery noise will not force a significant change in accepted farm and forest practices on adjoining lands: Speaker Noise Level All outdoor speakers shall be set so that the maximum dBA level of winery noise, as measured from right angles from the source of the noise, does not exceed 65 dBA at all property lines with the exception of the southwest property line abutting Highway 20. At 65 dBA, no change to or increase in the cost of accepted farm practices will occur.s All sources of sound, including people, vehicles, and/or music will be completely absent by 10pm and will not resume again until the opening of business the next day. The following additional condition has been imposed to address potential noise complaints: Winery Related Events Applicant/owner shall have a representative at the site during all Winery Related Events involving outdoor amplified noise/music. That representative shall have the authority and responsibility to immediately respond to noise complaints and to ensure immediate correction occurs. With respect to a potential for light to create a significant change in accepted farming or forest practices on adjoining lands from the meadery, all additional outdoor sources of light will be directed downward and away from property lines. Even given this consideration, the highway is a constant source of headlights at night, and all adjoining farm practices are already well accustomed to far more intrusive and direct light sources. No area farm practices have incurred additional costs due to existing light impacts from the highway, and no area farm practices will incur additional costs from the minimal additional indirect lighting created by the winery. One possible result of the proposed winery uses would be a slight increase in traffic on Highway 20 directly in front of the subject property. The subject property is accessed directly off of Highway 20, and is more than 1,900 feet from the next closest highway access to the east Qordan Rd), and 2,100 feet from the next closest highway access to the west (faros property). This distance gives ample opportunity for ingress/egress from the winery without impacting other farmers' ingress/egress points on Highway 20. As outlined in the attached 5 Neither the Oregon Statutes nor Oregon Administrative Rules ("OAR") specify a maximum noise level for events or concerts to ensure minimization of noise impacts on noise sensitive uses such residential uses. The appealed staff decision looked to OAR 340-035-0030, Noise Regulations for In -Use Motor Vehicles, and 340-035-0045, Noise Control Regulations for Airports, as being instructive. They are not instructive, however, because agricultural uses are not noise sensitive uses and all uses occurring adjacent to the boundaries of the Herman property are agricultural uses. OAR 340-035-0010(38). The 50 dBA auxiliary equipment noise level relied on by the staff decision applies between 10:00 pm and 7:00 am. This permit will allow no amplified sound during that time period. The airport noise standard of OAR 340-035-0045 is not comparable because it is an "Annual Average Day -Night Airport Noise Level" which would allow for averaging event noise with other noise generated by the property over the course of a year rather than measuring noise at any one point in time at a property boundary. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 26 of 86 Trip Generation Forecast (Exhibit K), the meadery is projected to max out at 7 non-passby p.m. peak hour trips and 39 daily non-passby trips. Over the course of a full afternoon/evening, this is a minimal addition of new traffic to Highway 20. Winery related events are few and far between, and will be mitigated using on -site traffic control. Occasional deliveries will increase traffic use as well. Given that most farming practices involving use of the highway already occur at slower speeds (eg: tractors, cattle trucks, excavation equipment) and during normal work hours (or earlier), the vast majority of the new non-passby trips will not overlap with or impact already -minimal neighboring farm traffic. Hypothetically, increased traffic could impede highway -eligible pasture machinery and/or livestock haulers by slowing their ability to get to and from a permanent pasture farm use. Possible additional costs could be additional hourly pay to a haying company bringing equipment to the property via Highway 20. At most, the proposed uses will only minimally increase these impacting factors (in reality, adding a maximum of a couple minutes, total); more than likely, the proposed uses will create no additional impact at all. Regular farm -related traffic impacts are already occurring to and from the subject property using the Highway 20 service drive (eg., tractor and farm implement transportation, cattle trucks, horse trailer transportation, freight deliveries, hay trailers, etc.), and are not negatively impacting and/or increasing the cost of neighboring farm or forestry uses and practices nor negatively impacted (change use or increase cost) by non -farm traffic. Because there will be only minimal and inconsequential additional traffic impacts, the proposed winery will certainly not increase the costs of the identified neighboring farm practices. All service drives and parking areas will be maintained gravel, eliminating the possibility of dust kicking up and impacting neighboring farm uses. Given that all neighboring properties are a minimum of 0.25 miles from the winery and winery related events area of the Herman farm - with the exception of the City of Sisters` parcel directly across Highway 20 - nothing even potentially kicked up in the air by the winery uses will travel far enough to impact neighboring farm practices in any way. Therefore, no costs of these farm practices will be impacted by any additional dust created by the proposed winery. The however -slight increase in human activity on the subject property might increase the possibility for trespass onto neighboring properties, and negatively impact animal farm practices if an animal were scared by an uninvited/unexpected human. Because of the aforementioned distance from the winery uses to all property lines, given that the winery service drives do not connect to other neighboring properties and the winery use area is fenced off from the rest of the Herman property, and given that the winery uses are buffered by regenerative bee pastures and highways, it is highly unlikely that any trespass will occur or that it will impact farm practices on neighboring farms. Therefore, given the de minimis potential for impact resulting from additional human trespass, it is reasonable to conclude that this proposed use will not significantly increase the cost of neighboring farm practices. Another potential impact to neighboring farm practices would be solid waste generated by winery operations and events. The subject property has already been approved with an extensive septic assessment completed by Deschutes County Staff, ensuring waste created by winery operations will not negatively impact neighboring farm practices. When possible, 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 27 of 86 the winery intends to buffer winery waste and land -apply, positively impacting soil health and closing a sustainability loop. When portable restrooms are used for winery related events, the waste created will be removed from the property by the portable restroom service, ensuring it does not negatively impact neighboring farm practices in any way. Therefore, given the de minimis potential for impact resulting from additional waste production, it is reasonable to conclude that this proposed use will not significantly increase the cost of neighboring farm practices. The most common farm uses within the subject area are livestock and crop operations. Livestock (exclusively cow/calf operations and/or horse operations) involve some combination of the potentially year-round farm practices of grazing, dry lot feeding, and/or moving livestock to or through unvegetated area. As demonstrated above, all potential visual, auditory, traffic, waste, trespass, and/or dust impacts created by the winery will have no impact on these typical farming practices. Given that the subject property is also involved in these farm uses and practices provides further evidence that the proposed winery uses will not negatively impact neighboring farm uses. The proposed use is not predicated on - nor will it require - any neighboring livestock farm practices to be discontinued and/or changed in any way. Given the de minimis impact of the proposed use, it is reasonable to conclude that the proposed use will not significantly increase the cost of neighboring livestock and all associated practices and potential impacts. Crop operations (almost exclusively permanent pasture) involve some combination of the farm practices of re -seeding (Spring, during the daytime), ground spraying of herbicides for weed control (Spring and Summer, during the daytime), harvesting/bailing for hay (July and August, early morning before the sun is up or later in the day), spreading of manure for fertilizer (Spring, during the daytime), and/or irrigation (April to September). As demonstrated above, all potential visual, auditory, traffic, waste, trespass, and/or dust impacts created by the winery will have no impact on these typical farming practices. Given that the subject property is also involved in this farm use and many of these farm practices should further evidence that the proposed winery uses will not negatively impact neighboring farm uses, and the proposed use is not predicated on - nor will it require - any neighboring crop farm practices to be discontinued and/or changed in any way. Given the de minimis impact of the proposed use, it is reasonable to conclude that the proposed use will not significantly increase the cost of neighboring crop operations and all associated practices and potential impacts. There are six parcels immediately adjacent to the Lazy Z Ranch. A map with distances from the proposed winery and outdoor space is included as Exhibit F of our application. Adjacent properties bordering the south and southwest are owned by the City of Sisters and are used for effluent water disposal and leased for cold -season grazing of horses owned by Black Butte Stables. There is only one field currently in permanent pasture production on this property and it is more than 1,800 feet from the proposed winery uses. Further out in 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 28 of 86 these directions are forestland owned by the USA and a private property owner. No active farm practices are occurring on the large USA forest lot and no current active forest practices were observed occurring at this time. Exhibit Q, however, addresses potential impacts on future forest practices on this distant property and demonstrates that approval of the winery will not result in a substantial change or increase in cost of conducting future forest practices. The privately owned property is used to keep horses and is not in farm use. The property is separated from the proposed winery activities by Highway 20 and land owned by the City of Sisters uses seasonally for grazing horses. The impact analysis for the City of Sisters property which is closer to the winery than this forest -zoned property demonstrates compliance with the farm impacts test. Therefore, for all the aforementioned reasons, the winery should not significantly change or increase the cost of any of the accepted farm or forest practices for our neighbor to the south. The farm property adjacent to the east of the subject property is the Amestoy property. It is engaged in farm use, primarily permanent pasture, and the occasional short-term grazing of livestock. Farm practices include grazing, moving livestock to or through unvegetated area, re -seeding, ground spraying of herbicides, harvesting/baling of hay, and irrigation. This property's farm uses are separated from the proposed winery activities by approximately 0.25 mile, the Lazy Z corrals, our own 18-acre regenerative bee pasture, and wooden fencing. Therefore, for all the aforementioned reasons, the winery will not significantly change or increase the cost of any accepted farm practices for our neighbor to the east. The Morrow and Plank properties briefly border the subject property across Jordan Road to the southeast. The Morrow property's farm uses of permanent pasture and iivestock (horse and cow/calf) operations, exist more than 1,700 feet from the proposed use, and are buffered by the entirety of the Amestoy property and Jordan Road. The Plank property is not in farm use. Therefore, for all the aforementioned reasons, the winery will not significantly change or increase the cost of any accepted farm practices for our neighbors to the southeast. The adjacent property to the west of the subject property is the Hawk's Haven property. They maintain a permanent pasture. This property is approximately 0.25 to 0.5 miles away from the proposed location of the winery activities. It is buffered by our own dwellings, farm buildings, 12 acres of regenerative bee pasture, and a 20-acre field that will eventually become regenerative bee pasture. Therefore, for all the aforementioned reasons and those mentioned on Exhibit Q, the winery will not significantly change or increase the cost of any of the accepted farm practices for our neighbor to the west. The split -zoned property bordering the north is owned by the Parker Living Trust (EFU, FP and RR10) and is not in farm use. The property is separated from the proposed winery activities by farm buildings, 12 acres of regenerative bee pasture, a 20-acre field that will eventually become regenerative bee pasture, and Highway 126. Therefore, for all the aforementioned reasons, the winery should not significantly change or increase the cost of any of the accepted farm or forest practices for our neighbor to the north. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 29 of 86 All additional farm and forest use properties inventoried for this study area are engaged in some combination of the same farm or forestry uses and practices, have the same potential impacts, and exist at an even further distance from the proposed winery. For these reasons we find that the application will not force a change in or increase the costs of accepted farm or forest practices in the area. The Board finds, due to the distances to neighboring properties engaged in farm use, existing activity from Highway 20, and with the above -referenced conditions of approval, the proposed use will not force a significant change or increase the cost of accepted farm uses on surrounding lands. It also will not cause a significant change or increase the cost of accepted forest practices occurring on forest lands within the one -mile radius area studied by the applicant on his Exhibit Q. 3. That the actual site on which the use is to be located is the least suitable for the production of farm crops or livestock. FINDING: Addressing the criterion above, the applicant provided findings for the entire scope of the Meadery including the Mead Production, Winery Operations, and Winery Related Events. The Burden of Proof states: FINDINGS: 18.16.040(A)(3), ...least suitable for the production of farm crops or livestock. The proposed winery, parking lot(s), food cart(s), indoor tasting room, outdoor tasting area, and garden seating will be sited either within the existing farm building on the south side of the property at its approximate east -west center near Highway 20, or on the large, graveled area surrounding it. The proposed lawn seating, lawn games area, and stage will be sited on an existing grass lawn within the developed portion of the property adjacent to the existing driveway and barn. These site features already exist as non -irrigable farmland that is not suitable for livestock. All proposed activity, including expanded space for 10 annual events, is located on less than 2.4% of the subject property and has been long developed as the site least suitable for the production of farm crops or livestock. Thus, the proposed winery and commercial activities site is the least suitable part of the property for the production of farm crops or livestock. Repurposing the selected area will avoid new negative impacts to ongoing farm or forest uses, practices, and/or costs of such practices both onsite and within the surrounding area. The Board concurs with the applicant's analysis and finds that the Meadery site is located on previously disturbed terrain and is the least suitable for the productions of farm crops or livestock. This criterion is met. B. A commercial activity allowed under DCC 18.16.030(E) shall be associated with a farm use occurring on the parcel where the commercial use is proposed. The commercial activity may use, process, store or market farm products produced outside of Deschutes County. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 30 of 86 FINDING: Addressing the criteria above, the applicant provided findings for the entire scope of the Meadery including the Mead Production, Winery Operations, and Winery Related Events. The Burden of Proof states: All commercial activities proposed are related to the proposed winery, existing beekeeping, and other farm uses taking place on the same parcel as the proposed commercial activities. The winery will produce and store mead made from honey produced on the Lazy Z Ranch. The tasting room and other proposed facilities will facilitate the marketing of the farm's mead, honey and other farm crops and livestock. The Board concurs with the applicant's analysis. As noted above under DCC 18.16.025, the Meadery will potentially use honey from outside Deschutes County but limits on the source of honey have been imposed in the conditions of approval to address concerns raised by Central Oregon LanclWatch. Section 18.16.060. Dimensional Standards. E. Building height. No building or structure shall be erected or enlarged to exceed 30 feet in height, except as allowed under DCC 1&120.040. FINDING: The proposal does not include a request for any new structural development. The proposed indoor area of the Meadery will be located in the existing 3,000 square foot building. The site plan does include a stage, but the applicant is undecided it the stage will be constructed permanently or be a temporary stage. To ensure compliance, The Board includes the following conditions of approval: Height Standard No building or structure shall be erected or enlarged to exceed 30 feet in height, except as allowed by DCC 18.120.040. Section 18.16.070. Yards. A. The front yard shall be a minimum of.• 40 feet from a property line fronting on a local street, 60 feet from a property line fronting on a collector street, and 100 feet from a property line fronting on an arterial street. B. Each side yard shall be a minimum of 25 feet, except that for a nonfarm dwelling proposed on property with side yards adjacent to property currently employed in farm use, and receiving special assessment for farm use, the side yard shall be a minimum of 100 feet. C. Rear yards shall be a minimum of 25 feet, except that for a nonfarm dwelling proposed on property with a rear yard adjacent to property currently employed in farm use, and receiving special assessment for farm use, the rear yard shall be a minimum of 100 feet. D. The setback from the north lot line shall meet the solar setback requirements in 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 31 of 86 Section 18.116.180. E. In addition to the setbacks set forth herein, any greater setbacks required by applicable building or structural codes adopted by the State of Oregon and/or the County under DCC 15.04 shall be met. FINDING: The proposal does not include a request for any new structural development, with the possible exception of the stage. To ensure compliance, the Board includes the following conditions of approval: Zoning Setbacks Any proposed development shall comply with the setbacks set forth in the Exclusive Farm Use Zone as prescribed in DCC 18.16.070 (A-D). General Setbacks In addition to the setbacks set forth herein, any greater setbacks required by applicable building or structural codes adopted by the State of Oregon and/or the County under DCC 15.04 shall be met. Section 18.16.080. Stream Setbacks. To permit better light, air, vision, stream pollution control, protection of fish and wildlife areas and preservation of natural scenic amenities and vistas along streams and lakes, the following setbacks shall apply. A. All sewage disposal installations, such as septic tanks and septic drainfields, shall be set back from the ordinary high water mark along all streams or lakes a minimum of 100 feet, measured at right angles to the ordinary high water mark. In those cases where practical difficulties preclude the location of the facilities at a distance of 100 feet and the County Sanitarian finds that a closer location will not endanger health, the Planning Director or Hearings Body may permit the location of these facilities closer to the stream or lake, but in no case closer than 25 feet. B. All structures, buildings or similar permanent fixtures shall be set back from the ordinary high water mark along all streams or lakes a minimum of 100 feet measured at right angles to the ordinary high water mark. FINDING: There are no streams or lakes in the project vicinity. Section18.16.090. Rimrock Setback. Notwithstanding the provisions of DCC 18.16.070, setbacks from rimrock shall be as provided in DCC 18.116.160 or 18.84.090, whichever is applicable. FINDING: There is no rimrock in the project vicinity. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 32 of 86 Chapter 18.56, Surface Mining Impact Area Combining Zone (SMIA) FINDING: The subject property is located within the SMIA Zone in association with mine site 277. Section 18.56.080. Use Limitations. No dwellings or additions to dwellings or other noise sensitive or dust sensitive uses or structures shall be erected in any SMIA Zone without first obtaining site plan approval under the standards and criteria set forth in DCC 18.56.090 through 18.56.120. FINDING: The proposed Meadery and related events are not noise -sensitive or dust -sensitive uses. The provisions of DCC 18.56 do not apply to this review. Chapter 18.80, Airport Safety Combining Zone (AS) Section 18.80.020. Application of Provisions. The provisions of DCC 18.80.020 shall only apply to unincorporated areas located under airport imaginary surfaces and zones, including approach surfaces, transitional surfaces, horizontal surfaces, conical surfaces and runway protection zones. While DCC 18.80 identifies dimensions for the entire imaginary surface and zone, parts of the surfaces andforzones do not apply within the Redmond, Bend or Sisters urban Growth Boundaries. The Redmond Airport is owned and operated by the City of Redmond, and located wholly within the Redmond City Limits. Imaginary surface dimensions vary for each airport covered by DCC 18.80.020. Based on the classification of each individual airport, only those portions (of the AS Zone) that overlay existing County zones are relevant. Public use airports covered by DCC 18.80.020 include Redmond Municipal, Bend Municipal, Sunriver and Sisters Eagle Air. Although it is a public -use airport, due to its size and other factors, the County treats land uses surrounding the Sisters Eagle Air Airport based on the ORS 836.608 requirements for private -use airports. The Oregon Department of Aviation is still studying what land use requirements will ultimately be applied to Sisters. However, contrary to the requirements of ORS 836.608, as will all public -use airports, federal law requires that the FAA Part 77 surfaces must be applied. The private -use airports covered by DCC 18.80.020 include Cline Falls Airpark and Juniper Airpark. FINDING: The proposed Meadery is located beneath the conical surface for the Sisters Eagle Air Airport. Therefore, the provisions of this chapter apply. Section 18.80.028. Height Limitations. All uses permitted by the underlying zone shall comply with the height limitations in DCC 18.80.028. When height limitations of the underlying zone are more restrictive than those 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 33 of 86 of this overlay zone, the underlying zone height limitations shall control. [ORS 836.619, OAR 660-013-0070] A. Except as provided in DCC 18.80.028(B) and (C), no structure or tree, plant or other object of natural growth shall penetrate an airport imaginary surface. [ORS 836.619, OAR 660-013-0070(1)] B. For areas within airport imaginary surfaces but outside the approach and transition surfaces, where the terrain is at higher elevations than the airport runway surfaces such that existing structures and permitted development penetrate or would penetrate the airport imaginary surfaces, a local government may authorize structures up to 35 feet in height. C. Other height exceptions or variances may be permitted when supported in writing by the airport sponsor, the Department of Aviation and the FAA. Applications for height variances shall follow the procedures for other variances and shall be subject to such conditions and terms as recommended by the Department of Aviation and the FAA (for Redmond, Bend and Sunriver.) FINDING: The proposed Meadery is under the Conical Surface for the Sisters Eagle Air Airport. The Burden of Proof states that no new development is in included in the proposal. However, the Board notes that the site plan includes a stage and that the proposal may include supporting infrastructure in the future that is not yet known, or understood to require a building permit. The application materials also indicate that the Winery Building could be renovated at a later date. As such this decision provides the following analysis. The highest elevation at the Meadery location, which is under the Conical Surface, is approximately 3,171 feet. Pursuant to DCC 18.16.060, no building or structure shall be erected or enlarged to exceed 30 feet in height. As conditioned above, no new future development will exceed 30 feet and will therefore not rise above 3,201 feet in elevation. The closest point at which the Conical Surface crosses the Meadery, the imaginary surface will be at an elevation of approximately 3,501 feet. Therefore, the Board finds that, as conditioned, any future development will not penetrate the imaginary surface. This criterion will be met. Section 18.80.044. Land Use Compatibility. Applications for land use or building permits for properties within the boundaries of this overlay zone shall comply with the requirements of DCC 18.80 as provided herein. When compatibility issues arise, the Planning Director or Hearings Body is required to take actions that eliminate or minimize the incompatibility by choosing the most compatible location or design for the boundary or use. Where compatibility issues persist, despite actions or conditions intended to eliminate or minimize the incompatibility, the Planning Director or Hearings Body may disallow the use or expansion, except where the action results in loss of current operational levels and/or the ability of the airport to grow to meet future community needs. Reasonable conditions to protect the public safety may be imposed by the Planning Director or Hearings Body. [ORS 836.619, ORS 836.623(1), OAR 660- 013-0080] A. Noise. Within airport noise impact boundaries, land uses shall be established consistent with the levels identified in OAR 660, Division 13, Exhibit 5 (Table 2 of DCC 18.80). Applicants for any subdivision or partition approval or other land use approval or building permit affecting land within airport noise impact boundaries, 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 34 of 86 shall sign and record in the Deschutes County Book of Records, a Declaration of Anticipated Noise declaring that the applicant and his successors will not now, or in the future complain about the allowed airport activities at the adjacent airport. In areas where the noise level is anticipated to be at or above 55 Ldn, prior to issuance of a building permit for construction of a noise sensitive land use (real property normally used for sleeping or as a school, church, hospital, public library or similar use), the permit applicant shall be required to demonstrate that a noise abatement strategy will be incorporated into the building design that will achieve an indoor noise level equal to or less than 55 Ldn. [NOTE. FAA Order 5100.38A, Chapter 7 provides that interior noise levels should not exceed 45 decibels in all habitable zones.] FINDING: The subject property is not within the noise impact boundary associated with the Airport. This criterion does not apply. B. Outdoor lighting. No new or expanded industrial, commercial or recreational use shall project lighting directly onto an existing runway or taxiway or into existing airport approach surfaces except where necessary for safe and convenient air travel. Lighting for these uses shall incorporate shielding in their designs to reflect light away from airport approach surfaces. No use shall imitate airport lighting or impede the ability of pilots to distinguish between airport lighting and other lighting. FINDING: The proposed use is a commercial and recreational use. This criterion requires that no use shall imitate airport lighting or impede the ability of pilots to distinguish between airport lighting and other lighting. To ensure compliance, a condition of approval has been added. This criterion will be met. Lighting in the Airport Safety Combining Zone No Meadery development, or any of the associated Meadery uses, shall imitate airport lighting or impede the ability of pilots to distinguish between airport lighting and other lighting. C. Glare. No glare producing material, including but not limited to unpainted metal or reflective glass, shall be used on the exterior of structures located within an approach surface or on nearby lands where glare could impede a pilot's vision. FINDING: To ensure compliance, a condition of approval has been added. This criterion will be met. Glare Producing Materials in the Airport Safety Combining Zone No glare producing material, including but not limited to unpainted metal or reflective glass, shall be used on the exterior of structures located within an approach surface or on nearby lands where glare could impede a pilot's vision. D. Industrial emissions. No new industrial, mining or similar use, or expansion of an existing industrial, mining or similar use, shall, as part of its regular operations, 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 35 of 86 cause emissions of smoke, dust or steam that could obscure visibility within airport approach surfaces, except upon demonstration, supported by substantial evidence, that mitigation measures imposed as approval conditions will reduce the potential for safety risk or incompatibility with airport operations to an insignificant level. The review authority shall impose such conditions as necessary to ensure that the use does not obscure visibility. FINDING: The proposed use is not an industrial, mining or similar use, or expansion of an existing industrial, mining or similar use. This criterion does not apply. E. Communications Facilities and Electrical Interference. No use shall cause or create electrical interference with navigational signals or radio communications between an airport and aircraft. Proposals for the location of new or expanded radio, radiotelephone, and television transmission facilities and electrical transmission lines within this overlay zone shall be coordinated with the Department of Aviation and the FAA prior to approval. Approval of cellular and other telephone or radio communication towers on leased property located within airport imaginary surfaces shall be conditioned to require their removal within 90 days following the expiration of the lease agreement. A bond or other security shall be required to ensure this result. FINDING: The proposed use will not cause or create electrical interference. This criterion is met. F. Limitations and Restrictions on Allowed Uses in the RPZ, Transitional Surface, Approach Surface, and Airport Direct and Secondary Impact Areas. For the Redmond, Bend, Sunriver, and Sisters airports, the land uses identified in DCC 18.80 Table 1, and their accessory uses, are permitted, permitted under limited circumstances, or prohibited in the manner therein described. In the event of conflict with the underlying zone, the more restrictive provisions shall control. As used in DCC 18.80.044, a limited use means a use that is allowed subject to special standards specific to that use. FINDING: The proposed structure(s) will not be located within/beneath one of the identified surfaces. This criterion is met. 18.80.054 Conditional Uses Uses permitted conditionally shall be those identified as conditional uses in the underlying zone with which the AS Zone is combined, and shall be subject to all conditions of the underlying zone except as provided in DCC 18.80.044. FINDING: The proposed use is a conditional use in the underlying zone. Above, the Board addressed the applicable criteria under DCC 18.80.044. Therefore, the proposed use is allowed as a conditional use in the AS Combining Zone. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 36 of 86 Chapter 18.84, Landscape Management Combining Zone (LM) Section 18.84.020. Application of Provisions. The provisions of DCC 18.84 shall apply to all areas within one-fourth mile of roads identified as landscape management corridors in the Comprehensive Plan and the County Zoning Map. The provisions of DCC 18.84 shall also apply to all areas within the boundaries of a State scenic waterway or Federal wild and scenic river corridor and all areas within 660 feet of rivers and streams otherwise identified as landscape management corridors in the comprehensive plan and the County Zoning Map. The distance specified above shall be measured horizontally from the center line of designated landscape management roadways or from the nearest ordinary high water mark of a designated landscape management river or stream. The limitations in DCC 18.84.20 shall not unduly restrict accepted agricultural practices. FINDING: Highway 20 is identified on the County Zoning Map as the landscape management feature(s). The subject property falls within the Landscape Management Combining Zone for this/these feature(s), therefore, the provisions of this chapter apply. Section 18.84.050. Use limitations. A. Any new structure or substantial exterior alteration of a structure requiring a building permit or an agricultural structure within an LM Zone shall obtain site plan approval in accordance with DCC 18.84 prior to construction. As used in DCC 18.84 substantial exterior alteration consists of an alteration which exceeds 25 percent in the size or 25 percent of the assessed value of the structure. B. Structures which are not visible from the designated roadway, river or stream and which are assured of remaining not visible because of vegetation, topography or existing development are exempt from the provisions of DCC 18.84.080 (Design Review Standards) and DCC 18.84.090 (Setbacks). An applicant for site plan review in the LM Zone shall conform with the provisions of DCC 18.84, or may submit evidence that the proposed structure will not be visible from the designated road, river or stream. Structures not visible from the designated road, river or stream must meet setback standards of the underlying zone. FINDING: As noted above, with the possible exception of the stage and future improvements, no new development is included in the proposal. Based upon a site visit, staff noted that any new future development will be visible from Highway 20 due to its close proximity and lack of significant vegetative buffering or topographical changes. As such, the Board includes the following condition of approval: Future Meadery Development in the Landscape Management Combining Zone The applicant shall apply for a Landscape Management Review for any new structure or substantial exterior alteration of a structure requiring a building permit. A substantial exterior alteration is defined as exceeding 25 percent in the size or 25 percent of the assessed value of the structure. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 37 of 86 Chapter 18.116, Supplementary Provisions Section 18.116.020 Clear Vision Areas. A. in all zones, a clear vision area shall be maintained on the corners of all property at the intersection of two streets or a street and a railroad. A clear vision area shall contain no planting, fence, wall, structure, or temporary or permanent obstruction exceeding three and one-half feet in height, measured from the top of the curb or, where no curb exists, from the established street centerline grade, except that trees exceeding this height may be located in this area provided all branches and foliage are removed to a height of eight feet above the grade. FINDING: As explained in greater detail under DCC 18.116.030(F)(7), the subject property has a required clear vision area located at the intersection of the service drive and Highway 20. As proposed, this area will contain no planting, fence, wall, structure, or temporary or permanent obstruction exceeding three and one-half feet in height. By staffs assessment, the existing)uniper tree is in the clear vision area and is subject to the provision above. As a condition of approval, the clear vision area shall be maintained in accordance with DCC 18.116.020(A). Clear Vision Area The clear vision area located at the intersection of the service drive/driveway and Highway 20 shall be maintained in accordance with DCC 18.116.020(A). All branches and foliage of the existingJuniper tree are to be removed I loved to a height of eight feet above the grade vVithin 3v days of thi,�.a de�i.ciivn becoming final. B. A clear vision area shall consist of a triangular area on the corner of a lot at the intersection of two streets or a street and a railroad. Two sides of the triangle are sections of the lot lines adjoining the street or railroad measured from the corner to a distance specified in DCC 18.116.020(8)(1) and (2). Where lot lines have rounded corners, the specified distance is measured from a point determined by the extension of the lot lines to a point of intersection. The third side of the triangle is the line connecting the ends of the measured sections of the street lot lines. The following measurements shall establish clear vision areas within the County. 1. in an agricultural, forestry or industrial zone, the minimum distance shall be 30 feet or at intersections including an alley, 10 feet. 2. in all other zones, the minimum distance shall be in relationship to street and road right of way widths as follows: Right of way Width Clear vision 80 feet or more 20 feet 60 feet 30 feet 50 feet and less 40 feet 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 38 of 86 FINDING: As noted above, the proposal has a clear vision area at the intersection of the service drive/driveway and Highway 20. As conditioned, the proposal will meet this criterion. Section 18.116.030, Off street Parking and Loading. A. Compliance. No building or other permit shall be issued until plans and evidence are presented to show how the off street parking and loading requirements are to be met and that property is and will be available for exclusive use as off-street parking and loading. The subsequent use of the property for which the permit is issued shall be conditional upon the unqualified continuance and availability of the amount of parking and loading space required by DCC Title 18. FINDING: The Burden of Proof states: Proposed off-street parking is depicted on site plans (Exhibit Q. Three parking areas are proposed for guest/customer/employee use. Loading/unloading of equipment or supplies will be completed adjacent to the proposed Winery Building. The Board concurs with the applicant's statement. B. Off -Street Loading. Every use for which a building is erected or structurally altered to the extent of increasing the floor area to equal a minimum floor area required to provide loading space and which will require the receipt or distribution of materials or merchandise by truck or similar vehicle, shall provide off-street loading space on the basis of minimum requirements as follows: 1. Commercial, industrial and public utility uses which have a gross floor area of 5,000 square feet or more shall provide truck loading or unloading berths subject to the following table: Sq. Ft. of Floor Area No. of Berths Required Less than 5,000 0 5,000-30,000 1 30,000-100,000 2 100,000 and Over 3 FINDING: As noted above, the existing Winery Building is 3,000 sq. ft. Therefore, no loading berth is required. C. Off -Street Parking. Off-street parking spaces shall be provided and maintained as set forth in DCC 18.116.030 for all uses in all zoning districts. Such off-street parking spaces shall be provided at the time a new building is hereafter erected or enlarged or the use of a building existing on the effective date of DCC Title 18 is changed. FINDING: The Board finds this criterion requires parking be provided and maintained for all uses. As a condition of approval, required parking facilities shall be provided prior to or concurrently with 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 39 of 86 construction and/or initiation of the proposed use. Meadery Parking Required parking facilities shall be provided prior to or concurrently with construction and/or initiation of the proposed use. D. Number of Spaces Required. Off-street parking shall be provided as follows: 9. Other uses not specifically listed above shall be provided with adequate parking as required by the Planning Director or Hearings Body. The above list shall be used as a guide for determining requirements for said other uses. FINDING: As noted above, the proposed Meadery has three aspects: Mead Production, Winery Operations, and Winery Related Events. For addressing this criterion, and the specific parking categories of the code, this decision addresses the parking standards according to each specific aspect of the proposal. Mead Production For Mead Production, the Board finds the closest applicable parking standard to be industrial. 7. Industrial. Use Requirements Manufacturing 1 space per employee on the Iestablishment I largest working shift As noted above, the Mead Production facility will employee up to 3 persons. The applicant proposes for himself to be included in the number of employees and that parking for him will be provided at his residence. As such, 2 parking spaces are required. The total required amount of vehicle parking for Mead Production is 2 spaces. Winery Operations For Winery Operations, the Board finds the closest applicable parking standards to be commercial. 6. Commercial. Use Requirements Eating or drinking 1 space per 100 sq. establishments ft. of gross floor area. According to the application materials, the proposed tasting room will be 1,560 square feet. The applicant also proposes an additional 300 square feet of outdoor seating which results in a total of 1,860 square feet. Therefore, the required parking spaces is 18.6, or 19 spaces. To ensure a compliance with the parking standards, the Board includes the following condition of approval: 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 40 of 86 Indoor and Outdoor Serving/ Seating Areas During open hours for Winery Operations, the indoor serving and seating area shall not exceed 1,560 square feet and the outside serving and seating area shall not exceed 300 square feet. Food Cart/Mobile Food Units (MFUs) Up to 1 food cart will be on site during business hours for the Winery Operations. Parking for the food carts is accounted for in the food cart parking area which contains 3 parking spaces. The Board identifies the food cart area which is separated from the normal parking areas and excludes the food cart employee and vehicle from the calculation. The total required amount of vehicle parking for Winery Operations is 19 spaces. Winery Related Events Within DCC 18.116.030, there are no parking requirement standards for events. The applicant has proposed a total number of 250 maximum attendees per event. In consultation with the Senior Transportation Planner, and using an occupancy rate of 2.5 persons per vehicle, planning staff calculated that 100 parking spaces are needed. The Winery Related Events of the Meadery will employ up to 5 persons. The applicant proposes for himself to be included in the number of employees and that parking for him will be provided at his residence. As such, 4 more parking spaces are required. Therefore, the total required vehicle parking for Winery Related Events is 104 spaces. Food Cart/Mobile Food Units (MFUs) Up to 2 additional food carts will be on site during business hours for the Winery Events. Parking for the food carts is accounted for in the food cart parking area which contains 3 parking spaces. The Board identifies the food cart area which is separated from the normal parking areas and excludes the food cart employees and vehicles from the calculation. The total required amount of vehicle parking for Winery Related Events is 104 spaces. As the Mead Production will not be open at the same time as the Winery Operations, the Board uses the number of parking spaces of Winery Operations in combination with Winery Related Events to eliminate redundancy. Therefore, the Board finds that a minimum of 19 spaces are required to be available on site under normal operating hours for the Winery Operations and an additional 104 parking spaces are required to be available on site when a Winery Related Event is scheduled. Therefore, the total required parking requirement when a Winery Related Event is scheduled during the open hours for the Winery Operations, is 123 parking spaces. Proposed Parking Winery Operations/ Normal Hours On the revised Site Plan for Subject Use which was submitted on July 15, 2022, the applicant has identified two parking lots to be used for the Meadery. In accordance with the minimum parking stall dimensions of 9' x 20', the applicant proposes two parking lots with sufficient area for 18 spaces, 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 41 of 86 plus 1 ADA Space for a total of 19 spaces. Winery Related Events On the revised Exhibit H: Event Map, which was submitted on July 15, 2022, the applicant has identified 9 additional parking areas, and expanded the lots for Winery Operations to be used for the Meadery, during an event. In accordance with the minimum parking stall dimensions of 9' x 20', the applicant proposes these parking locations with sufficient area for an additional 104 spaces. Combined with the required parking spaces for Winery Operations, the Board calculates the total number of required parking spaces to be 123. The Board finds the number of proposed parking spaces proposed (19 + 104 = 123) complies with the number of spaces required by this criterion. E. General Provisions. Off -Street Parking. 1. More Than One Use on One or More Parcels. In the event several uses occupy a single structure or parcel of land, the total requirement for off-street parking shall be the sum of requirements of the several uses computed separately. FINDING: According to the application materials, there is a residential use and a farm use alongside the proposed Meadery. The residential use and farm use parking is independent of the proposed Meadery and the existing parking locations for these uses are located outside the area identified for the Meadery. Per DCC 18.116.030(D)(1), 2 spaces are required for the residential use. The Board finds parking for the 2 required spaces associated with residence can be accommodated in and around the dwelling. DCC 18.116 does t rrking stanarfr farm uses. unopovideapaddoAg to the applicant, Lazy Z Ranch employs no staff other than the farm operator who lives in the dwelling on the property. These parking spaces are accounted for next to the dwelling. As detailed above, required parking for the Meadery, Winery Operations and Winery Related Events will be accommodated in the various parking areas on the site which contain 123 parking spaces. Based on the above, the Board finds all required parking for the existing and proposed uses will be accommodated on -site. 2. joint Use of Facilities. The off-street parking requirements of two or more uses, structures or parcels of land may be satisfied by the same parking or loading space used jointly to the extent that it can be shown by the owners or operators of the uses, structures or parcels that their operations and parking needs do not overlap at any point of time. If the uses, structures or parcels are under separate ownership, the right to joint use of the parking space must be evidence by a deed, lease, contract or other appropriate written document to establish the joint use. FINDING: As noted above, the subject property has a residential use and a farm use. The applicant considers himself to be an employee of the Meadery and has proposed that the existing parking space at the residence be applied toward his parking requirement. Parking for the residence is to the northwest of the proposed Meadery and has designated parking for the residential use. As noted above, no other individuals are employed at the farm other than the farm operator who lives 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 42 of 86 in the dwelling on the property. For the purposes of addressing this criterion, the parking for the farm use and the residential use are the same. The parking areas for the residential/farm use and the Meadery use are in separate locations and will not overlap. This criterion is met. 3. Location of Parking Facilities. Off-street parking spaces for dwellings shall be located on the same lot with the dwelling. Other required parking spaces shall be located on the same parcel or another parcel not farther than 500 feet from the building or use they are intended to serve, measured in a straight line from the building in a commercial or industrial zone. Such parking shall be located in a safe and functional manner as determined during site plan approval. The burden of proving the existence of such off - premise parking arrangements rests upon the applicant. FINDING: The proposed required parking spaces are be located on the same parcel. 4. Use of Parking Facilities. Required parking space shall be available for the parking of operable passenger automobiles of residents, customers, patrons and employees only and shall not be used for the storage of vehicles or materials or for the parking of trucks used in conducting the business or used in conducting the business or use. FINDING: The Board includes this criterion as a condition of approval. Meadery Parkin Required parking space shall be available for the parking of operable passenger automobiles of residents, customers, patrons and employees only and shall not be used for the storage of vehicles or materials or for the parking of trucks used in conducting the business or used in conducting the business or use. S. Parking, Front Yard. Required parking and loading spaces for multi family dwellings or commercial and industrial uses shall not be located in a required front yard, except in the Sunriver UUC Business Park (BP) District, Airport Development (AD) Zone, and properties fronting Spring River Road in the Spring River Rural Commercial Zone, but such space may be located within a required side or rear yard. FINDING: As outlined in DCC 18.04 a commercial use is defined as: "Commercial use" means the use of land primarily for the retail sale of products or services, including offices. It does not include factories, warehouses, freight terminals or wholesale distribution centers. As noted above, the primary use of the land is farming. The proposed Meadery is incidental and subordinate to the existing farm use. The Board finds the proposed Meadery is a "commercial event or activity." As outlined in DCC 18.04, a commercial event or activity is defined as: 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 43 of 86 "Commercial event or activity" means any meeting, celebratory gathering, wedding, party, or similar uses consisting of any assembly of persons and the sale of goods or services. It does not include agri-tourism. In DCC 18.16.042, a commercial event or activity shall be related to and supportive of agriculture. As the proposed Meadery is not a commercial use, this criterion is not applicable. 6. On -Street Parking Credit. Notwithstanding DCC 18.116.030(G)(2), within commercial zones in the La Pine Planning Area and the Terrebonne and Tumalo unincorporated communities, the amount of required off-street parking can be reduced by one off-street parking space for every allowed on - street parking space adjacent to a property up to 30% of the required off- street parking. On -street parking shall follow the established configurations in the parking design standards under DCC 18.116.030 Table 1. To be considered for the parking credit, the proposed parking surface, along the street frontage under review, must have a defined curb line and improved as required under DCC 17.48, with existing pavement, or an engineered gravel surface. For purposes of establishing credit, the following constitutes an on - street parking space: a. Parallel parking (0 degree), each 20 feet of uninterrupted curb; b. Diagonal parking (60 degree), each with 11 feet of curb; C. Perpendicular parking (90 degree), each with 10 feet of curb; d. Curb space must be connected to the lot that contains the use, e. Parking spaces that would not obstruct a required clear vision area, nor any other parking that violates any law or street standard, and f. On -street parking spaces credited for a specific use may not be used exclusively by that use, but shall be available forgeneral public use at all times. No signs or actions limiting general public use of on -street spaces are permitted. FINDING: No on -street parking is proposed. F. Development and Maintenance Standards for Off -Street Parking Areas. Every parcel of land hereafter used as a public or private parking area, including commercial parking lots, shall be developed as follows: 1. Except for parking to serve residential uses, an off-street parking area for more than five vehicles shall be effectively screened by a sight obscuring fence when adjacent to residential uses, unless effectively screened or buffered by landscaping or structures. FINDING: The Burden of Proof states: The proposed winery location is not adjacent to residential uses. The closest residential uses in the area are over 1,600 feet from proposed parking areas, and they do not abut the subject property. The applicant believes nearby residential uses will be effectively screened 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 44 of 86 by distance, existing onsite buildings, existing onsite trees, and existing wetland vegetation surrounding the large pond adjacent to Highway 20. The Board concurs with the applicant's statement. 2. Any lighting used to illuminate off-street parking areas shall be so arranged that it will not project light rays directly upon any adjoining property in a residential zone. FINDING: There are no adjoining properties in a residential zone. 3. Groups of more than two parking spaces shall be located and designed to prevent the need to back vehicles into a street or right of way other than an alley. FINDING: Given the service drive distance from Highway 20 to the parking lots, the Board finds the parking spaces are located and designed to prevent the need to back vehicles into a street or right of way other than an alley. 4. Areas used for standing and maneuvering of vehicles shall be paved surfaces adequately maintained for all weather use and so drained as to contain any flow of water on the site. An exception may be made to the paving requirements by the Planning Director or Hearings Body upon finding that. a, A high water table in the area necessitates a permeable su ;face to reduce surface water runoff problems; or b. The subject use is located outside of an unincorporated community and the proposed surfacing will be maintained in a manner which will not create dust problems for neighboring properties; or C. The subject use will be in a Rural Industrial Zone or an Industrial District in an unincorporated community and dust control measures will occur on a continuous basis which will mitigate any adverse impacts on surrounding properties. FINDING: The Burden of Proof states: The subject property is outside of an unincorporated community, and is zoned Exclusive Farm Use. We are requesting an exception to the paving requirement because we are located outside of an unincorporated community. With the exception of a paved skirt extending off of Highway 20 to our property line, all parking areas and service drives have been gravel surfaces for decades and appropriately maintained by regular re -graveling and grading as needed (see Exhibit J). With the exception of the City of Sisters' farm parcel located across Highway 20, there are no properties within a quarter mile of all parking spaces and service drives, and we are the only ones who would have to deal with our dust, which does not exist due to gravel type and maintenance. The Board finds that the proposed use is located outside of an unincorporated community and is 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 45 of 86 eligible for an exemption to the paved surface requirement pursuant to this criterion. As depicted in the site plan and on Exhibit), the areas identified as parking or services drives are required to be adequately maintained with gravel surfaces. This applies to parking for Mead Production, Winery Operations, and Winery Related Events. The Board notes the applicant has submitted a Maintained Gravel Map which is included as an Attachment D. The Board includes a condition of approval that these areas will be graveled prior to the initiation of use and be maintained at all times. The gravel surfacing requirements of this condition may also be met by paving if paving is required by Building Division review. Graveled Surface for Standing and Maneuvering of Vehicles Prior to the initiation of use, the applicant shall gravel all areas for the standing and maneuvering of vehicles onsite as depicted on the Maintained Gravel Map. This includes the individual parking areas as proposed and all service drives which provide access for Mead Production, Winery Operation, and Winery Related Events. At all times, the graveled surfaces shall be maintained in a manner which will not create dust problems for neighboring properties. 5. Access aisles shall be of sufficient width for all vehicular turning and maneuvering. FINDING: The applicant proposes one-way and two-way access aisles, which requires a minimum width of 12 feet and 24 feet, respectively. Normal mead/winery operations and events are analyzed independently under this criterion. Mead Production and Winery Operations As illustrated on the site plan, the access aisles will be 24 feet in width for 2-way access aisles. The proposed access aisles are of sufficient width for all vehicular turning and maneuvering and comply with standards for parking lot design under sub -section (G), below. The Meadery service drives map for Mead Production and Winery Operations is included as Attachment E. Winery Related Events As illustrated on the site plan, the access aisles will be 12 feet for one-way access aisles and 24 feet in width for two-way access aisles. The proposed access aisles are of sufficient width for all vehicular turning and maneuvering and comply with standards for parking lot design under sub -section (G), below. The Meadery service drives map for Winery Related Events is included as Attachment F. 6. Service drives to off-street parking areas shall be designed and constructed to facilitate the flow of traffic, provide maximum safety of traffic access and egress and maximum safety of pedestrians and vehicular traffic on the site. The number of service drives shall be limited to the minimum that will accommodate and serve the traffic anticipated. Service drives shall be clearly and permanently marked and defined through the use of rails, fences, walls or other barriers or markers. Service drives to drive in establishments shall be designed to avoid backing movements or other maneuvering within a street other than an alley. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 46 of 86 FINDING: For the purposes of this decision, the Board finds a "service drive" includes any vehicle maneuvering surface that connects to a road or street, but is not immediately adjacent to a parking space. The Burden of Proof states: The entrance service drive to the parking area is fenced and gated. It is a wide area that allows for a flow of two-way traffic into and out the site and designated parking areas (Exhibit G). The drive is marked with fencing. It is designed to avoid backing movements onto Highway 20. There is only one service drive for the meadery. It is clearly and permanently marked and defined by natural and physical barriers. On the entrance from the highway, white vinyl fencing ushers the customer onto the property. Once through the gate, the service drive is barriered to the west by the parking spaces and the pond, and to the east by the ADA parking spot and the winery building itself. Directly to the north is the barn, which will have a sign to enhance the natural funnel to the northeast parking spaces. The service drive at this section is barriered to the north by metal panel fencing and to the south by the winery building. The driveway to the dwellings located to the northwest of the service drive will have a permanent "private driveway" sign and blocked by a rope during open hours. All service drives for the additional 18 annual events are bound by fencing. Additional permanent structures and/or barriers are unnecessary for clarity, and have potential to render the space unusable for the maneuvering of cattle trucks and other farm implements when the Meadery is closed to the public. Normal mead/winery operations and events are analyzed independently under this criterion. Mead Production and Winery Operations For Mead Production and Winery Operations, the proposed parking plan and services drives are sufficient for providing access throughout the site as proposed. The area around the Winery Building is clear of obstructions and visibility will be maintained by the use of large graveled surfaces. As identified in the applicant's response, the use of natural features, fences, and structures to direct vehicular and pedestrian traffic are acceptable to meet this criterion provided that directions are clear to both vehicle drivers and pedestrians on site. However, as noted below under 18.124.160(E), the intermixing of vehicle and pedestrian traffic in an open area could potentially create confusion and conflict in an undefined space. The response in the application does not address pedestrian walkways and if they are sufficiently separated from drive aisles by distance, curbing, or landscaping. The submitted site plan and application materials do not indicate if pedestrian crosswalks in parking lots will be marked. The Board notes that the applicant proposes signage to articulate traffic direction. As such, the Board includes a condition of approval to ensure that appropriate sign locations, sign messaging, and demarcations, are utilized to provide a safe environment for vehicle and pedestrian traffic and ensure compliance with this criterion. This condition of approval will be satisfied through a sign plan submitted to the Planning Division to demonstrate how vehicular and pedestrian traffic will be coordinated to provide a safe environment. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 47 of 86 Winery Related Events For Winery Related Events, the proposed parking plan and services drives are sufficient for providing access throughout the site as proposed. The area around the Winery Building and "Lawn Event Site" are clear of obstructions and visibility will be maintained by the use of large, graveled surfaces. As identified in the applicant's response, the use of natural features, fences, and structures to direct vehicular and pedestrian traffic are acceptable to meet this criterion provided that directions are clear to both vehicle drivers and pedestrians on site. The same concerns were raised by staff, and elevated, by the fact that the number of vehicles and pedestrians will be dramatically increased when compared to day-to-day operations at the Meadery. As illustrated on the site plan, additional parking spaces and service drives will be active with vehicles and pedestrians. Moreover, as noted in the application materials, more vendors, entertainers with vehicles and equipment, as well as temporary infrastructure will also be on site. In the chance of an emergency situation, a defined and articulated space is even more necessary to ensure safety. As such, the Board includes elements specific to temporary Winery Related Events which will be included in the sign plan. Safety of Traffic Access & Egress, and Pedestrians and Vehicular Traffic for the Meadery Prior to the Initiation of Use, the applicant shall submit a sign plan to the Planning Division illustrating that the site, with the installation of signage throughout, is adequate for providing safety of traffic access and egress, as well as safety for pedestrians and vehicular traffic. 1. Mead Production and Winery Operations in Accordance with Meadery Site Plan/Sign Plan: ■ Appropriate sign locations, sign messaging, and demarcations, are utilized to provide a safe environment for vehicle and pedestrian traffic throughout the site. 2. Winery Related Events in Accordance with the Meadery Events Site Plan/Sign Plan: ■ In addition to Mead Production and Winery Operations, appropriate temporary sign locations, sign messaging, and demarcations, are utilized to provide a safe environment for vehicle and pedestrian traffic throughout the site. ■ Highlight areas of significance (e.g. portable toilets & pedestrian only areas) during temporary Winery Related Events. No "drive-in" establishment is proposed. As conditioned, the proposal will meet this criterion. 7. Service drives shall have a minimum vision clearance area formed by the intersection of the driveway centerline, the street right of way line and a straight line joining said lines through points 30 feet from their intersection. FINDING: For the purposes of this decision, the Board finds a "Service drive" includes any vehicle maneuvering surface that connects to a road or street, but is not immediately adjacent to a parking space. The Board finds "vision clearance area" became "clear vision area" in 1991 (Ord 91-038) but that this reference was not updated. For the purposes of this decision, the Board uses "vision clearance area" and "clear vision area" as the equivalent. The subject property has a required service drive clear vision area located at the intersection of 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 48 of 86 Highway 20 and the Meadery entrance. As proposed, this area will contain no planting, fence, wall, structure, or temporary or permanent obstruction exceeding three and one-half feet in height. As a condition of approval, the service drive clearvision area shall be maintained in accordance with DCC 18.116.020(A). 8. Parking spaces along the outer boundaries of a parking area shall be contained by a curb or bumper rail placed to prevent a motor vehicle from extending over an adjacent property line or a street right of way. FINDING: The Board finds a curb or bumper rail are only needed under this criterion where needed to prevent a motor vehicle from extending over an adjacent property line or a street right of way. No parking area is immediately adjacent to a property line or a street right of way. G. Off -Street Parking Lot Design. All off-street parking lots shall be designed subject to County standards for stalls and aisles as set forth in the following drawings and table: (SEE TABLE 1 AT END OF CHAPTER 18.116) 1. For one row of stalls use "C" + "D" as minimum bay width. 2. Public alley width may be included as part of dimension "D," but all parking stalls must be on private property, off the public right of way. 3. For estimating available parking area, use 300-325 square feet per vehicle for stall, aisle and access areas. 4. For large parking lots exceeding 20 stalls, alternate rows may be designed for compact cars provided that the compact stalls do not exceed 30 percent of the total required stalls. A compact stall shall be eight feet in width and 17 feet in length with appropriate aisle width. FINDING: The proposed parking lot has been designed subject to County standards. Section 18.116.031, Bicycle Parking. New development and any construction, renovation or alteration of an existing use requiring a site plan review under DCC Title 18 for which planning approval is applied for after the effective date of Ordinance 93-005 shall comply with the provisions of DCC 18.116.031. A. Number and Type of Bicycle Parking Spaces Required. 1. General Minimum Standard. a. All uses that require off-street motor vehicle parking shall, except as specifically noted, provide one bicycle parking space for every five required motor vehicle parking spaces. b. Except as specifically set forth herein, all such parking facilities shall include at least two sheltered parking spaces or, where more than 10 bicycle spaces are required, at least 50 percent of the bicycle parking spaces shall be sheltered. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 49 of 86 FINDING: As noted above, the proposed use requires vehicular parking spaces. As noted below, the applicant requests an exception to the requirement of bicycle parking. C. When the proposed use is located outside of an unincorporated community, a destination resort, and a rural commercial zone, exceptions to the bicycle parking standards may be authorized by the Planning Director or Hearings Body if the applicant demonstrates one or more of the following. i The proposed use is in a location accessed by roads with no bikeways and bicycle use by customers or employees is unlikely. ii. The proposed use generates less than 50 vehicle trips per day. iii. No existing buildings on the site will accommodate bicycle parking and no new buildings are proposed. iv. The size, weight, or dimensions of the goods sold at the site makes transporting them by bicycle impractical or unlikely. V. The use of the site requires equipment that makes it unlikely that a bicycle would be used to access the site. Representative examples would include, but not be limited to, paintball parks, golf courses, shooting ranges, etc. FINDING: The Burden of Proof states: 19 required parking spaces are proposed (Exhibit Q. The applicant requests an exception to the bicycle parking standards for the proposed use for the following reasons: The owners and all employees will drive to and from the property. The applicant believes Highway 20 is too dangerous for bicycle use. It has no bikeways making it highly unlikely bicycles will be used by customers or employees. • The subject property is located outside of an unincorporated community, a destination resort, or a rural commercial zone where bike use is common. • It is anticipated that all customers will arrive and leave the property by vehicle and will not use bicycles. It is not practical to transport materials used in winemaking to the site via bicycle. No new buildings are proposed. The Board concurs with the applicant's analysis that Highway 20 has no bikeways making it highly unlikely bicycles will be used by customers or employees. Further, the subject property is not within an unincorporated community, destination resort or rural commercial zone. For these reasons, the Board grants an exception to the bicycle parking requirements. Section 18.116.310 Traffic Impact Studies C. Guidelines for Traffic Impact Studies 1. All traffic impact studies shall be stamped and signed by the registered 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 50 of 86 professional engineer who is licensed in the State of Oregon and is otherwise qualified to prepare traffic studies. 2. The County Engineer shall determine when the report has satisfied all the requirements of the development's impact analysis. Incomplete reports shall be returned for completion. 3. The following vehicle trip generation thresholds shall determine the level and scope of transportation analysis required for a new or expanded development. a. No Report is required if there are fewer than 50 trips per day generated during a weekday. b. Site Traffic Report (STR): If the development or change in use will cause the site to generate 50-200 daily trip ends, and less than 20 peak hour trips, a Site Traffic Report may be required at the discretion of the County Engineer. C. Traffic Impact Analysis (TIA): If the development or change in use will generate more than 200 trip ends and 20 or more peak hour trips, then a Traffic Impact Analysis (TIA) shall be required. 4. The peak hour shall be the highest continuous hour of traffic measured between 4:00 and 6:00 PM, unless site trip generation characteristics warrant consideration of alternative periods as determined by the County Engineer. (An example would be a use with a high 7:00 and 9:00 AM peak and a low PM peak such as a school.) FINDING: The Burden of Proof states: The site's sole access is to Highway 20, and no county roads are involved. In coordination with the Senior Transportation Planner, Peter Russell, we commissioned a Trip Generation Forecast from Professional Engineer Scott Ferguson of Ferguson & Associates, Inc. The completed Forecast is attached (Exhibit K) and demonstrates that the land use proposed in our application is forecast to generate less than 50 weekday trips, and therefore a Site Traffic Report (STR) is not necessary. The trip generation letter was evaluated by Deschutes County Senior Transportation Planner, Peter Russell. His comments are in included above and no Site Traffic Report (STR) is required for the proposal. Chapter 18.120, Exceptions Section 18.120.010. Nonconforming Uses. Except as otherwise provided in DCC Title 18, the lawful use of a building, structure or land existing on the effective date of DCC Title 18, any amendment thereto or any ordinance codified therein may be continued although such use or structure does not conform with the standards for new development specified in DCC Title 18. A nonconforming use or 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 51 of 86 structure may be altered, restored or replaced subject to DCC 18.120.010. No nonconforming use or structure may be resumed after a one-year period of interruption or abandonment unless the resumed use conforms with the provisions of DCC Title 18 in effect at the time of the proposed resumption. A. Expansion or Replacement of a Nonconforming Structure. 1. Nonconforming Structure. For the purposes of DCC 18.120.010, a nonconforming structure is one that was lawfully established and violates current setbacks of DCC Title 18 but conforms with respect to use. 2. Replacement or Expansion without Additional Encroachment in Setback Area. A nonconforming structure may be replaced with a new structure of the same size on the same footprint as the preexisting nonconforming structure or may be expanded with an addition that does not project into the required setback area at any point, subject to all other applicable provisions of DCC Title 18. 3. Replacement or Expansion with Additional Encroachment in Setback Area. Replacement or expansion of a nonconforming structure that would involve an additional projection into the front, side or rear yard setback area at any point along the footprint of the existing or preexisting structure may be allowed provided such additional projection into the setback area (1) does not exceed 900 square feet; (2) does not exceed the floor space of the existing or preexisting structure, (3) does not cause the structure to project further toward the front, side or rear property lines than the closest point of the existing or preexisting structure, and (4) meets the variance approval standards set forth in DCC 18.132.025(A)(1) through (4). FINDING: The Burden of Proof states: Deschutes County Assessor's records indicate the existing 3,000 square foot farm building (described therein as a shop/machine shed) was constructed in 1970 (see attached Assessor's Improvement Summary, Exhibit Q. There were no zoning regulations or building permit requirements in effect in 1970. However, evidence exists that this building is much older than 1970, including the photos and map from a 1959 farm insurance policy provided by a previous owner (Exhibit M). This building has been part of the farm use on the Herman property since its construction. It is within 100' of Highway 20, approximately 75' from the property line. The applicant proposes no additions to the building. However, on the exterior, new siding and roofing is proposed to make it more appealing and compatible with the proposed wine production/tasting facility. The interior layout will be altered as depicted in the attached sample winery building site plan. Additionally, the winery will be connected to an existing onsite well for potable water, and a new onsite septic system will be installed for waste treatment (see attached site plan, Exhibit Q. The building in question is surrounded by a gravel area that has been used as a driveway and outdoor storage area since construction of the nonconforming farm building under 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 52 of 86 discussion. The applicant proposes to alter the use of this existing gravel area to site some of the proposed commercial activities in conjunction with farm use. This will concentrate uses associated with the proposed winery within close proximity to the winery building on previously -developed portions of the farm, thus limiting new impacts to necessary farm fields and portions of the property devoted to livestock. Uses proposed in this location are depicted on this application's site plans (Exhibit C) and include food truck(s) east of the winery building, outdoor garden seating (e.g., picnic tables) to the south that may, seasonally, include a tent. The Board concurs with the applicant's analysis. According to Deschutes County records, the existing 3,000-square-foot farm building predates county zoning permitting program which was established in 1973. The Board finds that the farm building is a lawfully established and non- conforming structure. Pursuant to DCC 18.120.010(D), general maintenance is permitted on a non- conforming structure. The applicant proposed interior changes for the Meadery and exterior renovations which included siding and roofing. The Board considers these changes minor in nature and appropriately classified as maintenance. However, if any changes are made to the building which change either the footprint or height of the building, an alteration of a non -conforming structure approval is required from the Planning Division. The Board includes the following conditions of approval: Alteration of a Non -Conforming Structure The applicant shall receive approval for a non -conforming use alteration if any changes to height or footprint of the 3,000-square-foot farm building/Meadery building are proposed. Renovation Permitting For the proposed renovations to the Meadery building, the applicant shall obtain all the appropriate permitting from the Deschutes County Building Division and the Environmental Soils Division. Chapter 18.124, Site Plan Review Section 18.124.030. Approval Required. A. No building, grading, parking, land use, sign or other required permit shall be issued for a use subject to DCC 18.124.030, nor shall such a use be commenced, enlarged, altered or changed until a final site plan is approved according to DCC Title 22, the Uniform Development Procedures Ordinance. B. The provisions of DCC 18.124.030 shall apply to the following. 1. All conditional use permits where a site plan is a condition of approval, 2. Multiple family dwellings with more than three units, 3. All commercial uses that require parking facilities, 4. All industrial uses, S. All other uses that serve the general public or that otherwise require parking facilities, including, but not limited to, landfills, schools, utility facilities, 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 53 of 86 churches, community buildings, cemeteries, mausoleums, crematories, airports, parks and recreation facilities and livestock sales yards, and 6. As specified for Flood Plain Zones (FP) and Surface Mining Impact Area Combining Zones (SMIA). 7. Non-commercial wind energy system generating greater than 15 to 100 kW of electricity. C. The provisions of DCC 18.124.030 shall not apply to uses involving the stabling and training of equine in the EFU zone, noncommercial stables and horse events not requiring a conditional use permit. D. Noncompliance with a final approved site plan shall be a zoning ordinance violation. E. As a condition of approval of any action not included in DCC 18.124.030(B), the Planning Director or Hearings Body may require site plan approval prior to the issuance of any permits. FINDING: The proposed use requires actions described in section (A), above, and falls within a use category described in section (B). Site plan review is required. Section 18.124.060. Approval Criteria. Approval of a site plan shall be based on the following criteria; A. The proposed development shall relate harmoniously to the natural environment and existing development, minimizing visual impacts and preserving natural features including views and topographical features. FINDING: In Father's House, files 247-18-000061-CU, 247-18-000062-SP, 247-18-000624-A, and 247- 18-000643-A, the Board of County Commissioners (Board) made the following finding regarding this standard. The Board agrees that DCC 18.124.060(A) is subjective and, at times, difficult to apply as the Hearings Officer observed. However, as the Board interprets the provision, DCC 18.124.060(A) does not require a particularly onerous exercise. It requires an applicant to show that its proposed site plan relates "harmoniously" to the natural environment and existing development. Unlike the conditional use standards of DCC 18.128.015(B), this standard does not indicate harmony achieved with "surrounding properties." However, the Board understands that the standard implies that the proposed development shall relate harmoniously on and off the subject property and generally speaking, in the vicinity, by "minimizing visual impacts and preserving natural features including views and topographical features." The code does not define what it means to "relate harmoniously." The Hearings Officer reported that the online Oxford Living Dictionary defines "harmoniously" to mean arranging something "in a way that forms a pleasing or consistent whole." Both parties in this case, provided various interpretations of the term "harmonious." The Board is not adopting one interpretation of the term over another as each contributes equally to this evaluation. The Board concurs with the Hearings Officer that there is no "particularly useful case law defining 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 54 of 86 or applying this term." In addition, the Board agrees, that the Hearings Officer is correct that a site plan should be approved in light of this meaning of "harmonious," so long as the proposed site plan does not create "more disharmony than other uses allowed by right or conditionally in the MUA-10 zone." In this regard, the Board finds that this standard presumes the use is approved and evaluates only whether the site plan for the use "relates harmoniously." The Board finds that the proposed church site plan meets the standard set forth in DCC 18.124.060(A). Specifically, the Board interprets DCC 18.124.060(A) to mean that an applicant must demonstrate that the site plan has arranged the development in a way that evaluates the natural environment and existing development in the area and in the process has minimized visual impacts and reasonably preserved natural features including views and topographic features. Minimizing visual impact, as with this case, may include introduced landscaping, design layout, and specific design elements such as siding and roofing color and material. In doing so, this enables the County decision maker to find that the site plan's impacts create no more disharmony than other uses allowed by right or conditionally in the MUA Zone. The Board agrees, in part, with the Hearings Officer that this standard is considered differently when compared to the term "compatibility" and its associated standard of DCC 18.128.015(B). The chief differences between the two standards is that the DCC 18.128.015(B) compatibility standard evaluates the compatibility of the proposed use on existing and projected uses of surrounding properties and does so in light of specific factors that are not reproduced in DCC 18.124.060(A). The DCC 18.124.060(A) "harmonious" standard evaluates whether a proposed site plan "relates harmoniously to existing development and the natural environment" considering whether the site plan shows that the applicant has reasonably mitigated its impacts and reasonably preserved views. The Board observes that not every use that requires site plan approval also requires a conditional use permit. However, the Board finds that it is possible that a permitted or approved use is arranged so poorly on a site, that a proposed site plan must be denied under this standard. That is not the case here. The Board's findings, cited above, make it clear that the use itself is not the subject of review under this criterion. Rather, this criterion only evaluates whether the site plan for the use "relates harmoniously." The Board reads Father's House to require a demonstration, "...the site plan has arranged the development in a way that evaluates the natural environment and existing development in the area and in the process has minimized visual impacts and reasonably preserved natural features including views and topographic features." The Burden of Proof States: The proposed winery and commercial activities in conjunction with farm use will be sited on previously -developed portions of the property so as to avoid new impacts to the natural environment, thus respecting it. No new structures are proposed, rather existing ones will be used. This will respect existing development by avoiding unnecessary crowding and fully utilizing existing structures. Parking areas are proposed in locations that have been altered 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 55 of 86 by a history of farm vehicle use and are of a size and design that will facilitate safe flow of vehicular and pedestrian traffic within and around existing development. The visual impact of proposed use will be minimized by location. All proposed outdoor activities will be buffered from surrounding uses by existing buildings, vegetation and distance. Since these activities will be integrally related to and dependent upon the existing farm use of the subject property, the applicant believes the proposed winery and commercial activities in conjunction with farm use will relate harmoniously to the natural environment and existing development. The Board concurs with the applicant's analysis. The proposed site plan demonstrates a design scheme that utilizes previously disturbed ground and proposed activities that are in sheltered areas where the natural and existing features are incorporated and enhanced. Further, because the only new structure proposed is a ground -level stage, no impacts to any scenic views will occur. This criterion will be met. B. The landscape and existing topography shall be preserved to the greatest extent possible, considering development constraints and suitability of the landscape and topography. Preserved trees and shrubs shall be protected. FINDING: Given the limited new development, the Board finds the landscape and existing topography will be preserved to the greatest extent possible, considering development constraints and suitability of the landscape and topography. No significant changes to topography are proposed. The Board finds all trees and shrubs existing on -site, not removed by necessity of the proposed development, are "preserved trees and shrubs." The Board includes the following condition of approval: Preservation of Landscape and Existing Topography All trees and shrubs existing on -site, not removed by necessity of the proposed development, shall be protected, unless lawfully changed/removed by outright uses (such as farm use) or such change/removal is approved by future land use approvals. C. The site plan shall be designed to provide a safe environment, while offering appropriate opportunities for privacy and transition from public to private spaces. FINDING: The Burden of Proof states: The proposed winery and commercial activities in conjunction with farm use will be centered around the existing farm building and its surrounding gravel area. Occasional events will be held on an existing lawn area adjacent to the old barn. Farm uses and other private portions of the property will be separated from these areas by existing fencing and distance. Site plans have been designed to provide a safe environment by separating proposed parking areas and driveways from pedestrian areas (Exhibit Q. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 56 of 86 Safe Environment The Board finds this criterion requires demonstration the site is designed to address common safety hazards, including fire safety, and to address any site -specific natural hazards. The Board finds pedestrian, bicycle, and vehicle safety is addressed under sub -sections (E) and (K) of this section. With regard to natural hazards, none have been identified on the site. The proposed Meadery includes food and beverage sales onsite. As such, staff included comments from Eric Mone from Deschutes County Health Services under this criterion and comments from Jon Harrang from the Oregon Department of Agriculture in the administrative decision that are quoted below. Specific conditions of approval related to these comments are included in the comment text. Deschutes County Health Services, Eric Mone I received this Notice of Application for a Conditional Use permit at 68540 HWY 20, Sisters. Thanks for sending. A few considerations: (1) - if this property is served by a private well, it needs to be reviewed and approved as a Public Water System by either Oregon Dept of Ag (ODA) or our EH dept The Meadery will be served by a private well and this decision includes the following condition of approval: Private Well Prior to the Initiation of Use of any Aspect of the Meadery, the property owners shall have the well, which provides water to the property and use, reviewed and approved as a Public Water System by either the Oregon Department of Agriculture (ODA) or the Deschutes County Environmental Health Department. (2) - Licensure of Meadery will depend on their predominant activity (sales, tasting room, food service); that will determine whether licensure required by ODA or EH The Board includes the following condition of approval: Meadery Licensing From Deschutes County Environmental Health Department Prior to the Initiation of Use of any Aspect of the Meadery, the property owner shall obtain all necessary permits from the Deschutes County Environmental Health Department. (3) - Mobile Food Units (MFU, e.g. carts) will all require licensure by EH The Board includes the following condition of approval: 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 57 of 86 Meadery Food Cart/ Mobile Food Unit Licensing Prior to the Initiation of Service of the Mobile Food Units (MFUs), the property owner shall obtain all necessary permits from the Deschutes County Environmental Health Department for the Mobile Food Units (MFUs) operating on the property. (4) - Not sure if the MFU's will only be on site for events a few times per year or permanent. If permanent, it would be best for Public Health purposes if they were tied into the on -site septic system, the well, and a power source on site. The Board notes the proposal included one food cart to be operational when the Winery Building and Winery Operations are open to the public. One food cart will be permanent. Up to two more food carts are planned to be in use and open to the public only during an event. As such the Board considers these two food carts to be temporary. The Board includes the following condition of approval: Permanent Food Cart Utility Servicing Prior to the Initiation of Service of the Permanent Mobile Food Unit (MFU), the permanent Food Cart (MFU) shall be connected to the on -site septic system, the well, and a power source on site while providing food and beverage service at the Meadery. (5) - Todd's team is reviewing septic system so that will be a major consideration The Board includes the following conditions of approval: Meadery Septic System • Prior to the Initiation of Use for the Mead Production, the property owner shall obtain all necessary permits from the Deschutes County Onsite Wastewater Division for the Mead Production facilities. Prior to the Initiation of Use for the Winery Operations, the property owner shall obtain all necessary permits from the Deschutes County Onsite Wastewater Division specific to the Winery Operations. • Prior to the Initiation of Use for the Winery Related Events, the property owner shall obtain all necessary permits from the Deschutes County Onsite Wastewater Division for the Winery Related Events including any temporary facilities that will be operational on site. Oregon Department of Agriculture - Food Safety Program, Jon Harrang To Whom it May Concern, Food/beverage processing facilities such as those that produce Mead (honey wine) must be licensed and inspected by ODA Food Safety Program. A tasting room associated with the production facility would also be subject to licensing and inspection. The processing facility 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 58 of 86 must comply with the minimum standards set forth in 21 CFR 117. The tasting room would be subject to the Retail Food Code, OAR 603 Division 25. An adequate supply of potable water is required. In addition, the firm must demonstrate that solid and liquid waste are being properly disposed of. A septic authorization letter from Deschutes County Environmental Health or the equivalent approval from DEQ would be needed as a prerequisite for licensing, depending on which agency has the jurisdiction in this matter. Please note that OLCC and TTB may have additional requirements which relate to production, sales, and serving of alcoholic beverages to the public. Food cart licensing and inspection would be handled by Deschutes County Environmental Health Department. Please contact me if Deschutes County Planning Staff or the applicant should have any questions and/or if further discussion or clarification are needed. Based upon the comments from Jon Harrang, the Board includes the following conditions of approval: Meadery Licensing From the Oregon Department of Agriculture Prior to the Initiation of Use of any Aspect of the Meadery, the property owner shall obtain all necessary permits and approvals from the Oregon Department of Agriculture Food Safety Program for the Mead Production, Winery Operations, and Winery Related Events. Meadery Licensing From the Oregon Liquor and Cannabis Commission (OLCC) Prior to the Initiation of Use of any Aspect of the Meadery, the property owner shall obtain all necessary permits and approvals from the Oregon Liquor and Cannabis Commission for the Mead Production, Winery Operations, and Winery Related Events. Meadery Licensing From the US Alcohol and Tobacco Tax and Trade Bureau (TTB) Prior to the Initiation of Use of any Aspect of the Meadery, the property owner shall obtain all necessary permits and approvals from the US Alcohol and Tobacco Tax and Trade Bureau for the Mead Production, Winery Operations, and Winery Related Events. Transition from Public to Private Space As noted in the applicant's response, the site has a residential use. The Board concurs that sufficient distance and space exist and create a natural buffer between the residential use and the Meadery. With the exception of the Meadery tours that include a survey of the regenerative bee pastures, the Meadery is adequately separated from the on -site residential use. Regarding those private spaces and residential uses which surround the subject property, the Board finds that the existing buildings and vegetation, along with substantial distances from the proposed use, create a sufficient buffer. D. When appropriate, the site plan shall provide for the special needs of disabled persons, such as ramps for wheelchairs and Braille signs. FINDING: The Deschutes County Building Division was sent a request for comment on this 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 59 of 86 application. In the State of Oregon, ORS 455.720 and 447.210 through 447.992 are administered by the Deschutes County Building Safety Division. Deschutes County Building Safety Division is required to determine if a structure is an Affected Building and if so, apply the appropriate sections of Chapter 11 and the American National Standards Institute code A117.1-2009. Consequently, the structures will comply with state and federal ADA requirements. If an Affected Building is approved, inspected and finaled by the Deschutes County Building Safety Division, it meets all code requirements as an accessible structure. The Board finds that such a review is required prior to the issuance of building permits. As conditioned above under 18.120.010(A)(1-3), the Meadery building will comply with this criterion. E. The location and number of points of access to the site, interior circulation patterns, separations between pedestrians and moving and parked vehicles, and the arrangement of parking areas in relation to buildings and structures shall be harmonious with proposed and neighboring buildings and structures. FINDING: The Burden of Proof States: No new structures are proposed. The proposed development will not alter existing driveways or the one point of access to the site from Highway 20. The site plan has been designed to maintain sufficient and safe interior circulation patterns, separation between pedestrians and moving and parked vehicles, and arrangement of parking areas in relation to buildings and structures (Exhibit Q. The applicant believes that existing and proposed features will continue to be harmonious with the site's ongoing farm use and neighboring buildings and structures. The Board concurs with the applicant's analysis that the use of existing buildings contributes to the ongoing harmony with the surrounding properties. With no new substantial development proposed for the Meadery, the Board finds that there will not be any significantly adverse impacts on -site and/or neighboring proposed and existing buildings and structures. County staff has advised that it is unaware of any buildings and structures proposed for neighboring properties. As noted above under 18.116.030(F)(6), the Meadery's large parking areas and intermixing of vehicle and pedestrian traffic raises safety concerns for normal operation and events. The applicant proposes the use of built features, natural features and signage around Meadery building to ensure safety and circulation. In accordance with this proposed action, the Board includes a condition of approval that a sign plan be submitted to the Planning Division which confirms safety for interior circulation patterns. As conditioned above, this criterion will be met. F. Surface drainage systems shall be designed to prevent adverse impacts on neighboring properties, streets, or surface and subsurface water quality. FINDING: The subject proposal does not include impervious surfaces such as paving or new development, with the possible exception of the stage. Given its small size in comparison to the size of the property, the Board does not anticipate adverse drainage impacts on neighboring properties, streets, or surface and subsurface water quality. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 60 of 86 G. Areas, structures and facilities for storage, machinery and equipment, services (mail, refuse, utility wires, and the like), loading and parking and similar accessory areas and structures shall be designed, located and buffered or screened to minimize adverse impacts on the site and neighboring properties. FINDING: The Burden of Proof states: No new structures are proposed. The exterior of the existing farm building to house the proposed winery is weathered and in need of maintenance. It will be repaired and updated with new siding in earth -tone colors to make it more functional, natural looking, and visually appealing. All production and storage facilities are proposed inside the winery building, which will screen machinery and equipment. Parking areas, food cart(s), refuse containers, and temporary toilet facilities are proposed and will be located at least 100' from Highway 20 and will be located so that they are screened from the remainder of the site and neighboring properties by existing onsite buildings, fencing, and landscaping (Exhibit C, Site Plans). No adverse impacts from the proposed winery and commercial activities in conjunction with farm use are anticipated to the site or neighboring properties. The Board concurs with the applicant's analysis. H. All above ground utility installations shall be located to minimize adverse visual impacts on the site and neighboring properties. FINDING: The applicant has not proposed above ground utility installations as a part of this project. 1. Specific criteria are outlined for each zone and shall be a required part of the site plan (e.g. lot setbacks, etc.). FINDING: Specific criteria for each zone mapped on the subject property have been addressed above. J. All exterior lighting shall be shielded so that direct light does not project off site. FINDING: The applicant has not proposed exterior lighting as a part of this project. As a condition of approval, all exterior lighting shall be shielded so that direct light does not project off site. Exterior Lighting All exterior lighting shall be shielded so that direct light does not project off site. K. Transportation access to the site shall be adequate for the use. 1. Where applicable, issues including, but not limited to, sight distance, turn and acceleration/deceleration lanes, right-of-way, roadway surfacing and widening, and bicycle and pedestrian connections, shall be identified. 2. Mitigation for transportation -related impacts shall be required. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 61 of 86 3. Mitigation shall meet applicable County standards in DCC 18.116.310, applicable Oregon Department of Transportation (ODOT) mobility and access standards, and applicable American Association of State Highway and Transportation Officials (AASHTO) standards. FINDING: The Deschutes County Road Department, Deschutes County Transportation Planner, and the Oregon Department of Transportation were sent a request for comment on this application. Comments from the Senior Transportation Planner are included above. No infrastructure concerns and no required improvements are identified in the record. Section 18.124.070. Required Minimum Standards. A. Private or shared outdoor recreation areas in residential developments. 1. Private Areas. Other than a development in the Sunriver UUC Town Center District, each ground level living unit in a residential development subject to site plan approval shall have an accessible outdoor private space of not less than 48 square feet in area. The area shall be enclosed, screened or otherwise designed to provide privacy for unit residents and theirguests. FINDING: No residential development subject to site plan approval is proposed. 2. Shared Areas. Usable outdoor recreation space shall be provided for the shared use of residents and their guests in any apartment residential development, as follows: a. Units with one or two bedrooms: 200 square feet per unit. b. Units with three or more bedrooms: 300 square feet per unit. FINDING: No apartment residential development is proposed. 3. Usable outdoor recreation space shall be provided in the Sunriver UUC Town Center District on a district -wide basis as follows: a. A minimum of one hundred square feet of outdoor recreation space per Multi family Dwelling unit or Townhome that is accessible to residents or guests staying in Multi family Dwelling or Townhome units. b. Outdoor recreation spaces may include bicycle paths, plazas, play areas, water features, ice rinks, pools and similar amenities that are located outdoors. C. Outdoor recreation space must include recreation for children who are district residents, such as a maintained playground area with approved equipment such as swings or slides. FINDING: The proposal is not located in the Sunriver UUC Town Center District. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 62 of 86 4. Storage. In residential developments, convenient areas shall be provided for the storage of articles such as bicycles, barbecues, luggage, outdoor furniture, etc. These areas shall be entirely enclosed. FINDING: No residential development is proposed. B. Required Landscaped Areas. 1. The following landscape requirements are established for multi family, commercial and industrial developments, subject to site plan approval. a. A minimum of 15 percent of the lot area shall be landscaped. b. All areas subject to the final site plan and not otherwise improved shall be landscaped. FINDING: The Burden of Proof states: The proposed winery and commercial activities in conjunction with farm use is not a multi- family or industrial use requiring landscaping. A multi -family development is not proposed. Commercial and industrial uses are defined in DCC 18.04 as follows, "Commercial use" means the use of land primarily for the retail sale of products or services, including offices. It does not include factories, warehouses, freight terminals or wholesale distribution centers. "Industrial use" means the use of land primarily for the manufacture, processing, storage or wholesale distribution of products, goods or materials. It does not include commercial uses. As noted above, the primary use on the parcel is a farm use. The proposed commercial activities are in conjunction with this farm use, and will be incidental and subordinate to the farm use. For these reasons, the Board finds the proposal is not for residential, commercial, or industrial development. These criteria do not apply. 2. In addition to the requirement of DCC 18.124.070(B)(1)(a), the following landscape requirements shall apply to parking and loading areas: a. A parking or loading area shall be required to be improved with defined landscaped areas totaling no less than 25 square feet per parking space. b. In addition to the landscaping required by DCC 18.124.070(B)(2)(a), a parking or loading area shall be separated from any lot line adjacent to a roadway by a landscaped strip at least 10 feet in width, and from any other lot line by a landscaped strip at least five feet in width. C. A landscaped strip separating a parking or loading area from a street shall contain: 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 63 of 86 1) Trees spaced as appropriate to the species, not to exceed 35 feet apart on the average. 2) Low shrubs not to reach a height greater than three feet zero inches, spaced no more than eight feet apart on the average. 3) Vegetative ground cover. d. Landscaping in a parking or loading area shall be located in defined landscaped areas which are uniformly distributed throughout the parking or loading area. e. The landscaping in a parking area shall have a width of not less than five feet. f. Provision shall be made for watering planting areas where such care is required. g. Required landscaping shall be continuously maintained and kept alive and attractive. h. Maximum height of tree species shall be considered when planting under overhead utility lines. FINDING: The Burden of Proof states: This information is provided on the site plans filed with the County. Our proposal is to provide permanent parking areas for the tasting room and daily operations. Event parking will be similar to that allowed for events authorized by a temporary event permit such as in the Downs decision issued by the Board of Commissioners and for Pole Creek Ranch's events - without all of the features required for year-round uses. The creation of a permanent parking area for events that meets all of these requirements would harm farm use of the property as the event parking area could be needed for farm vehicle use and/or strategic movement of animals on almost every day of the year - except event days. The landscaped areas shown on the site plan exceed 25 square feet per parking space for the meadery. The parking lot is separated from a road way by a landscaped strip of 10' feet. The parking area does not adjoin and is not close to any other property line and is separated from those lot lines by buildings and natural landscaped areas and cultivated farm fields. The landscape strip separating the parking area from the street (the area west of the driveway) contains numerous trees with spacing that does not exceed 35 feet apart, shrubs, and vegetative ground cover. The outdoor seating area is proposed on the east side of the driveway so parking lot landscaping is not required. A landscaped area is, however, proposed to screen the outdoor seating area from the highway. If necessary, it could be landscaped to landscaped strip standards - standards that can be met during development of the site. The landscaping in the parking area is appropriately distributed throughout the permanent parking areas. If these areas are determined to be required for event parking, we propose using plants in planters to serve as temporary landscaping that can be moved to avoid obstructing farm vehicle and/or animal traffic on the property at all other times. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 64 of 86 Landscaped areas will be at least 5 feet wide. The applicant will water plants that require watering and will continuously maintain landscaping. Landscape area trees will not be located under overhead utility lines. It should also be noted that this is an 83 acre rural farm, not an urban development. As such, the entirety of the commercial operations are surrounded by acres and acres of landscaping and farmland, including trees, shrubs, ponds, lawns, gardens, row -crops, regenerative bee pastures, etc, in addition to all of the existing and proposed parking lot landscaping mentioned above and in our Burden of Proof. Landscaping requirements are intended to maintain nature within an urban environment. Our ranch is under zero risk of being turned into a concrete jungle, and our very existence as a business is predicated on the cultivation of nature. As such, any requirement to cultivate additional landscaping mere feet from acres and acres of managed nature seems rather unnecessary for our specific application, and misses the spirit of the requirement. Our customers want to visit a rural bee ranch/farmhouse meadery with a rural bee ranch/farmhouse meadery parking lot, not an urban development with an urban development parking lot. The Board finds that proposed landscaping, as presented on the site plan (Mead Production and Winery Operations (Exhibit Q, complies with the criteria above. For 123 parking spaces, 3,075 square feet of landscaping is required. According to staff calculations, and as presented on the site plan, the applicant proposes more than 3,500 square feet in the landscaped strip separating the use from Highway 20 alone. This strip is identified on the site plan as being 25 feet in width. Other proposed landscaping areas distributed around the site will increase this figure to substantially exceed this requirement. Staff noted in its administrative decision that the temporary parking for Winery Related Events is addressed by the same standards and the extended parking to the southeast is set back behind a field. As the delineated landscaped areas do not indicate specific plantings or dimensions, and to ensure compliance with the above criteria, the Board includes the following conditions of approval: Meadery Landscaping - General Standards The landscaping for the Meadery as presented as Exhibit C in the application materials, shall comply with the following standards: • The landscaping in a parking area shall have a width of not less than five feet. • Provision shall be made for watering planting areas where such care is required. • Required landscaping shall be continuously maintained and kept alive and attractive. • Maximum height of tree species shall be considered when planting under overhead utility lines. Meadery Landscaping - Landscaping Strip along Highway 20 The landscaping strip between Meadery parking and Highways 20, as presented as Exhibit C in the application materials, shall contain: • Trees spaced as appropriate to the species, not to exceed 35 feet apart on the average. • Low shrubs not to reach a height greater than three feet zero inches, spaced no more than eight feet apart on the average. • Vegetative ground cover. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 65 of 86 C. Non -motorized Access. 1. Bicycle Parking. The development shall provide the number and type of bicycle parking facilities as required in DCC M 116.031 and 1 & 116.035. The location and design of bicycle parking facilities shall be indicated on the site plan. FINDING: The applicant has requested an exception to the bicycle parking requirements. This criterion is not applicable. 2. Pedestrian Access and Circulation: a. Internal pedestrian circulation shall be provided in new commercial, office and multi family residential developments through the clustering of buildings, construction of hard surface pedestrian walkways, and similar techniques. b. Pedestrian walkways shall connect building entrances to one another and from building entrances to public streets and existing or planned transit facilities. On site walkways shall connect with walkways, sidewalks, bikeways, and other pedestrian or bicycle connections on adjacent properties planned or used for commercial, multi family, public or park use. C. Walkways shall be at least five feet in paved unobstructed width. Walkways which border parking spaces shall be at least seven feet wide unless concrete bumpers or curbing and landscaping or other similar improvements are provided which prevent parked vehicies from obstructing the walkway. Walkways shall be as direct as possible. d. Driveway crossings by walkways shall be minimized. Where the walkway system crosses driveways, parking areas and loading areas, the walkway must be clearly identifiable through the use of elevation changes, speed bumps, a different paving material or other similar method. e. To comply with the Americans with Disabilities Act, the primary building entrance and any walkway that connects a transit stop to building entrances shall have a maximum slope of five percent. Walkways up to eight percent slope are permitted, but are treated as ramps with special standards for railings and landings. FINDING: The Board finds that no new commercial development is proposed. The applicant proposes a commercial activity in conjunction with the existing farm use on the subject property. Therefore, no new pedestrian walkways are required. The only building in use will be the Winery Building and the applicant has submitted a Burden of Proof and Site Plans in support of a safe environment for internal vehicular and pedestrian traffic. The Board notes that no pedestrian walkways or bicycle lanes currently exist on Highway 20 and efforts to connect the Winery Building, or other locations on site, would be impractical. The Winery Building is existing, and as sited, will concentrate activity at and around the structure. Internal pedestrian circulation, safety, and ADA 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 66 of 86 requirements are addressed above. These criteria are met. D. Commercial Development Standards: 1. New commercial buildings shall be sited at the front yard setback line for lots with one frontage, and at both front yard setback lines for corner lots, and oriented to at least one of these streets, except in the Sunriver UUC Business Park (BP) District and Town Center (TC) District and properties fronting Spring River Road in the Spring River Rural Commercial Zone. The building(s) and any eaves, overhangs or awnings shall not interfere with the required clear vision area at corners or driveways. FINDING: No new commercial buildings are proposed. 2. To meet the standard in paragraph (1) of this subsection, buildings developed as part of a shopping complex, as defined by this title, and planned for the interior, rear or non -street side of the complex may be located and oriented toward private interior streets within the development if consistent with all other standards of paragraph (1) above and this paragraph. Interior streets used to satisfy this standard may have on -street parking and shall have sidewalks along the street in front of the building. Such sidewalks shall connect to existing or future sidewalks on public streets accessing the site. The master plan for the shopping complex shall demonstrate that at least one half of the exterior perimeter of the site that abuts each public street, will be developed with buildings meeting the standards of paragraphs (D)(1) or (D)(3) of this subsection. FINDING: No shopping complex is proposed. 3. An increase in the front yard setback may be allowed where the applicant can demonstrate that one or more of the following factors makes it desirable to site the new building beyond the minimum street setback. a. Existing development on the site, b. Lot configuration; C. Topography of the lot; d. Significant trees or other vegetative features that could be retained by allowing a greater setback; e. Location of driveway access. Such an increase in the front yard shall be the minimum necessary to accommodate the reason for the increase. f. Architectural features, driveways, landscaping areas equal to or greater than the depth of the structure, and outdoor commercial areas, when at least one half of the structure meets the minimum street setback. FINDING: No increase in the front yard setback has been requested. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 67 of 86 4. Off street motor vehicle parking for new commercial developments in excess of 10,000 square feet shall be located at the side or behind the building(s), except in the Sunriver UUC Business Park (BP) District and Town Center (TC) District. Off-street parking proposed with a shopping complex, as defined by this title, and intended to serve buildings located in the interior or rear of the complex may have parking in front of the building provided the overall master plan for the site satisfies paragraph (2) of this subsection. FINDING: No off street motor vehicle parking for new commercial developments in excess of 10,000 square feet is proposed. Chapter 18.128, Conditional Use Section 18.128.010, Operation. A. A conditional use listed in DCC Title 18 shall be permitted, altered or denied in accordance with the standards and procedures of this title, DCC Title 22, the Uniform Development Procedures Ordinance, and the Comprehensive Plan. B. in the case of a use existing prior to the effective date of DCC Title 18 and classified in DCC Title 18 as a conditional use, any change in use or lot area or an alteration of structure shall conform with the requirements for a conditional use. FINDING: The proposed conditional use is reviewed in accordance with the standards and procedures of this title; DCC Title 22, the Uniform Development Procedures Ordinance; and the Comprehensive Plan. No prior use now classified as a conditional use is being modified by this proposal. Section 18.128.015, General Standards Governing Conditional Uses. Except for those conditional uses permitting individual single family dwellings, conditional uses shall comply with the following standards in addition to the standards of the zone in which the conditional use is located and any other applicable standards of the chapter: FINDING: The use subject to conditional use review is a commercial activity in conjunction with farm use. A. The site under consideration shall be determined to be suitable for the proposed use based on the following factors: 1. Site, design and operating characteristics of the use, FINDING: The Burden of Proof States: FINDINGS: Site: The subject property is a working farm including cattle/horses/bees on irrigated and non -irrigated fields and pastures, a large pond, two dwellings, and multiple 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 68 of 86 agricultural buildings. The property is located in the EFU zone. It is surrounded by similar farms. Farm crops and honey produced onsite will be used to produce and market mead in the proposed winery. All proposed commercial activities will be dependent upon and related to the property's farm use. The applicant believes the site is suitable for the proposed use and that it will be compatible with the farm uses in the area. Design: The applicant proposes to remodel an existing building to accommodate the proposed winery and associated commercial activities. Outdoor seating, food and lawn areas are proposed adjacent to and nearby the proposed winery. Graveled parking areas and as - needed temporary sanitation units will also be clustered near the winery. The applicant believes the design of the proposed use is suitable for the site and will be compatible with its surrounding development. Operating Characteristics: The proposed winery preparation, production, and storage will occur inside a remodeled shop building. Most other proposed activities will revolve around the winery. The site has ample space within existing developed areas for the proposed uses with parking, access, driveways, and outdoor lawn area and garden areas for patrons to enjoy the wine and outdoor atmosphere. The applicant believes that this working farm is a suitable site for the proposed uses. The Board concurs with the applicant's analysis finds that nothing about the site which would preclude locating the project in this area. The site and farm property is suitable. The Board also finds the design of the proposal and the operating characteristics are suitable to the farm property. 2. Adequacy of transportation access to the site, and FINDING: Transportation access to the site is addressed in the comments by Peter Russell, Senior Planner. Comments from the Deschutes County Road Department and Deschutes County Transportation Planner did not identify any transportation infrastructure deficiencies. Comments from other agencies and the general public, other than high traffic volumes on Highway 20, did not identify any transportation infrastructure deficiencies. The Board finds, as conditioned, the site is suitable for the proposed use based on adequacy of transportation access to the site. 3. The natural and physical features of the site, including, but not limited to, general topography, natural hazards and natural resource values. FINDING: The Burden of Proof states: The proposed winery and commercial activities in conjunction with farm use will be sited within and near an existing building in the only developed portion of the property. This area of the site is level and has no topographical constraints. The site is a working farm with no known natural hazards (e.g. flood plain) or natural resource values (e.g. wildlife habitat, wetlands). The applicant believes the site is suitable for the proposed use based on the natural and physical features of the site. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 69 of 86 The site is generally level and presents no topographical constraints on the proposed use. The Deschutes County Natural Hazards Mitigation Plan (2015) identifies drought, earthquake, flood, landslide, volcanic, wildfire, windstorm, and winter storm hazards in the County. Of these, wildfire is of special concern regarding the suitability of the use. Natural resource values typically include agricultural soils, forest lands, wildlife and their habitats, wetlands, and natural water features. The Board finds the only natural resource value to be preserved are the agricultural soils on -site. As discussed previously, the Board finds the development will preserve the existing farmland by utilizing an existing building and previously disturbed areas. Comments from agencies and the general public did not identify any site unsuitability due to general topography, natural hazards, or natural resource values. Based on the above, the Board finds the site is suitable considering the natural and physical features of the site. B. The proposed use shall be compatible with existing and projected uses on surrounding properties based on the factors listed in DCC 18.128.015(A). FINDING: The Burden of Proof states: Some properties surrounding the subject site are in farm use, primarily cattle, horses, and pasture. Scattered dwellings are present within 0.25 to 1 mile of the property. There is also undeveloped land that is not being farmed directly across Highway 20 from the developed portion of the subject property where the winery and commercial activities in conjunction with farm use are proposed. These activities will be dependent upon and related to the ongoing farm use on the subject property. Future farm uses and dwellings may be possible on adjacent properties, however, these would be limited by EFU zoning restrictions and the availability of water rights for irrigation. No changes to topography are proposed, no known natural hazards are present, and no impacts are anticipated to agricultural land in the surrounding area. Therefore, the applicant believes the proposed winery and commercial activities in conjunction with farm use will not adversely impact adjacent properties or uses. The Board finds this criterion requires that the proposed use must be compatible with existing and projected uses on surrounding properties. The Board finds "surrounding properties" are those that might be significantly adversely impacted by their proximity to the proposed use. Existing uses on surrounding properties include primarily farm uses. The only exception would be the property to the south which is owned by the City of Sisters. Projected uses on surrounding properties are those that have received approvals, or are allowed outright and are typical of development of the areas. No recent land use approval on the adjacent properties indicate other potential uses other than farming. The Board finds existing uses are a reasonable representation of uses allowed in the underlying zones of surrounding properties. For this reason, the Board finds projected uses are likely to be similar to existing uses. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 70 of 86 (A)(1). Site, design and operating characteristics of the use, The Board finds the proposed use would be unsuitable if the siting, design and operating characteristics of the use significantly adversely impacted existing and projected uses on surrounding properties. Typically, potential adverse impacts could include visual, noise, dust, and odor impacts. The proposal, as sited on the southern property line of the property and designed to be integrated into the existing farm use, ensures compatibility with the existing farm uses on the surrounding properties. As noted in the application materials, the distance to neighboring properties, along with intervening vegetation and structures, contribute to compatibility between the proposed Meadery and surrounding uses by reducing potential visual, noise, and dust impacts. The proximity to Highway 20 and its existing traffic noise, along with conditions of approval related to number of events and decibel levels, will further mitigate noise impacts. For these reasons, the Board finds the site, design and operating characteristics of the Meadery will be compatibility with surrounding land uses. (A)(2). Adequacy of transportation access to the site, and The Board finds the proposed use would be unsuitable if access to the site would significantly adversely impact existing and projected uses on surrounding properties. Highway 20 is classified as a Rural Arterial and under the jurisdiction of the Oregon Department of Transportation (ODOT). No adverse comments were received from ODOT. Further, no comments indicating impacts to any nearby county roads were raised by the County's Senior Transportation Planner or the Road Department. For these reasons, the Board finds the subject proposal will not adversely impact transportation access to surrounding properties. Furthermore, the existing access to the site provides adequate access to the winery. (A)(3). The natural and physical features of the site, including, but not limited to, general topography, natural hazards and natural resource values. The Board finds the proposed use would be unsuitable if it significantly adversely impacted off -site topography, natural hazards, or natural resource values. The Deschutes County Natural Hazards Mitigation Plan (2015) identifies drought, earthquake, flood, landslide, volcanic, wildfire, windstorm, and winter storm hazards in the County. Of these, wildfire is of special concern regarding the suitability of the use. Natural resource values typically include agricultural soils, forest lands, wildlife and their habitats, wetlands, and natural water features. Natural resource values on surrounding properties include pasture land and native vegetation typical of this area. Comments from agencies and the general public did not identify concerns to surrounding properties related to general topography, natural hazards, or natural resource values. Further, the Board finds the operating characteristics of the use would not result in impacts to the natural and physical features on surrounding properties. C. These standards and any other standards of DCC 18.128 may be met by the imposition of conditions calculated to insure that the standard will be met. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 71 of 86 FINDING: To the extent this decision is conditioned under DCC 18.128 criterion, the Board notes such conditions are authorized by this criterion. Section 18.128.020, Conditions. In addition to the standards and conditions set forth in a specific zone or in DCC M 124, the Planning Director or the Hearings Body may impose the following conditions upon a finding that additional restrictions are warranted. A. Require a limitation on manner in which the use is conducted, including restriction of hours of operation and restraints to minimize environmental effects such as noise, vibrations, air pollution, glare or odor. B. Require a special yard or other open space or a change in lot area or lot dimension. C. Require a limitation on the height, size or location of a structure. D. Specify the size, number, location and nature of vehicle access points. E. Increase the required street dedication, roadway width or require additional improvements within the street right of way. F. Designate the size, location, screening, drainage, surfacing or other improvement of a parking or loading area. G. Limit or specify the number, size, location, height and lighting of signs. H. Limit the location and intensity of outdoor lighting and require shielding, 1. Specify requirements for diking, screening, landscaping or other methods to protect adjacent or nearby property and specify standards for installation and maintenance. J. Specify the size, height and location of any materials to be used for fencing. K. Require protection and preservation of existing trees, vegetation, water resources, wildlife habitat or other significant natural resources. L. Require that a site plan be prepared in conformance with DCC 18.124. FINDING: To the extent that any conditions of approval contained in this decision require improvement to the site beyond the minimum standards of DCC Title 18, the Board finds such conditions are authorized by this section. Section 18.128.040, Specific Use Standards. A conditional use shall comply with the standards of the zone in which it is located and with the standards and conditions set forth in DCC 18.128.045 through DCC 18.128.370. FINDING: As described herein, the proposed conditional use complies with the standards of the zone in which it is located and with the standards and conditions set forth in DCC 18.128.045 through DCC 18.128.370, as applicable. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 72 of 86 SYSTEM DEVELOPMENT CHARGE Board Resolution 2013-020 sets the transportation system development charge (SDC) amount and the applicant initially used an outdated rate of $4,757 per peak hour trip. In the provided Trip Generation Forecast, it was considered that since the tasting room would be closed 2 out of 5 weekdays, the average weekday traffic would not be accurately calculated by directly applying an Institute of Traffic Engineers (ITE) trip generation rate. The average rate was calculated as shown in Table 4 above. Also, the food cart would not attract traffic at this location as a stand-alone operation. To account for this, it was considered to be a small -kitchen extension of the wine -tasting operation. The resulting forecast was 9 p.m. peak hour trips and for 49 daily trips, of which 7 p.m. peak hour trips and 39 daily trips would be non-passby, aka site -generated, trips. This is a reasonably conservative approach considering that the family would also work on the site, which would eliminate some work trips - and that some of the trips would likely be pass -by trips for people driving between Bend and Sisters. At this level of weekday traffic generation, no further traffic studies are needed under Deschutes County Code (DCC) 18.116.310(C)(a). The resulting SDC is $35,560 ($5,080 X 7). The SDC is due prior to issuance of certificate of occupancy; if a certificate of occupancy is not applicable, then the SDC is due within 60 days of the land use decision becoming final. The County has both an SDC appeal process and a 10-year payment plan option; however, if the 10-year payment plan is used, the County becomes the holder of a first -place lien. THE PROVIDED SDC AMOUNT IS ONLY VALID UNTIL JUNE 30, 2023. DESCHUTES COUNTY'S SDC RATE IS INDEXED AND RESETS EVERY JULY 1. WHEN PAYING AN SDC, THE ACTUAL AMOUNT DUE IS DETERMINED BY USING THE CURRENT SDC RATE AT THE DATE THE BUILDING PERMIT IS PULLED. IV. CONCLUSION Based on the foregoing findings, the Board of Commissioners concludes that the proposed use can comply with the applicable standards and criteria of the Deschutes County zoning ordinance if conditions of approval are met. Other permits may be required. The applicants are responsible for obtaining any necessary permits from the Deschutes County Building Division and Deschutes County Environmental Soils Division as well as any required state and federal permits. V. DECISION APPROVAL, subject to the following conditions of approval. VI. CONDITIONS OF APPROVAL A. This approval is based upon the application, site plan, specifications, and supporting documentation submitted by the applicant. Any substantial change in this approved use will require review through a new land use application. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 73 of 86 B. The applicant shall obtain any necessary permits from the Deschutes County Building Division and Environmental Soils Division. C. Annual Reporting_- Incidental and Subordinate/Honey Sourcing The gross income of the winery from any activity other than the production or sale of wine may not exceed 25 percent of the gross income from the on -site retail sale of wine produced in conjunction with the winery. The gross income of a winery does not include income received by third parties unaffiliated with the winery. Failure of the landowner to demonstrate compliance with the 25% requirement for two consecutive years shall cause the commercial activities in conjunction with farm use permit to become void. 2. 90% of honey used to produce mead or other honey products must come from Deschutes County, adjoining counties, high desert counties (Wasco and Grant) and Marion, Jackson and Douglas counties. 100% of honey used to produce mead or other honey products must come from Oregon. Failure of the landowner to demonstrate compliance with this requirement for two consecutive years shall cause the commercial activities in conjunction with farm use permit to become void. 3. The winery shall submit reports of compliance with items 1 and 2 above, by April 30 of each year. D. Farm Use - incidental and Subordinate This approval is based on the continued existence of at least 30 acres of bee pasture on the winery property and the production on site of honey by bees. All honey produced on -site shall be used to make wine or be sold as honey to the public. E. Food Carts A maximum of one food cart is allowed to provide food for tasting room visitors. A maximum of two additional food carts may be allowed at events. All food carts shall offer honey as a condiment and shall have at least one food item featuring honey on the menu. F. Winery Related Events All Winery Related Events (agritourism and other commercial events) shall be in support of and associated with the Meadery and the promotion of the Lazy Z Ranch. Winery Related Events are limited to 10 days or fewer in a calendar year. Maximum attendance shall be capped at 250 persons for five events and 150 for five events. Weddings shall not be allowed. Winery related events may not commence until the winery submits to the County a written statement that is prepared by a certified public accountant certifying that the winery has reached $40,000 in gross income from the on -site retail sale of wine produced in conjunction with the winery. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 74 of 86 G. Winery Related Events Applicant/owner shall have a representative at the site during all Winery Related Events involving outdoor amplified noise/music. That representative shall have the authority and responsibility to immediately respond to noise complaints and to ensure immediate correction occurs. H. Speaker Noise Level All outdoor speakers shall be set so that the maximum dBA level of winery noise, as measured from right angles from the source of the noise, does not exceed 65 dBA at all property lines with the exception of the southwest property line abutting Highway 20. I. Height Standard No building or structure shall be erected or enlarged to exceed 30 feet in height, except as allowed by DCC 18.120.040. j. Zoning Setbacks Any proposed development shall comply with the setbacks set forth in the Exclusive Farm Use Zone as prescribed in DCC 18.16.070 (A-D) K. General Setbacks In addition to the setbacks set forth herein, any greater setbacks required by applicable building or structural codes adopted by the State of Oregon and/or the County under DCC 15.04 shall be met. L. Lighting in the Airport Safety Combining Zone No Meadery development, or any of the associated Meadery uses, shall imitate airport lighting or impede the ability of pilots to distinguish between airport lighting and other lighting. M. Glare Producing Materials in the Airport Safety Combining Zone No glare producing material, including but not limited to unpainted metal or reflective glass, shall be used on the exterior of structures located within an approach surface or on nearby lands where glare could impede a pilot's vision. N. Future Meadery Development in the Landscape Management Combining Zone The applicant shall apply for a Landscape Management Review for any new structure or substantial exterior alteration of a structure requiring a building permit. A substantial exterior alteration is defined as exceeding 25 percent in the size or 25 percent of the assessed value of the structure. O. Clear Vision Area The clear vision area located at the intersection of the service drive/driveway and Highway 20 shall be maintained in accordance with DCC 18.116.020(A). All branches and foliage of the existing juniper tree are to be removed to a height of eight feet above the grade within 30 days of this decision becoming final. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 75 of 86 P. Meadery Parking Required parking facilities shall be provided priorto or concurrently with construction and/or initiation of the proposed use. Q. Indoor and Outdoor Serving/ Seating Areas During open hours for Winery Operations, the indoor serving and seating area shall not exceed 1,560 square feet and the outside serving and seating area shall not exceed 300 square feet. R. Meadery ParkioZ Required parking space shall be available for the parking of operable passenger automobiles of residents, customers, patrons and employees only and shall not be used for the storage of vehicles or materials or for the parking of trucks used in conducting the business or used in conducting the business or use. S. Graveled Surface for Standing and Maneuvering of Vehicles Prior to the initiation of use, the applicant shall gravel all areas for the standing and maneuvering of vehicles onsite as depicted on the Maintained Gravel Map. This includes the individual parking areas as proposed and all service drives which provide access for Mead Production, Winery Operation, and Winery Related Events. At all times, the graveled surfaces shall be maintained in a manner which will not create dust problems for neighboring properties. T. Safety of Traffic Access & Egress, and Pedestrians and Vehicular Traffic for the Meadery Prior to the Initiation of Use, the applicant shall submit a sign plan to the Planning Division illustrating that the site, with the installation of signage throughout, is adequate for providing safety of traffic access and egress, as well as safety for pedestrians and vehicular traffic. Mead Production and Winery Operations in Accordance with Meadery Site Plan/ Sign Plan: ■ Appropriate sign locations, sign messaging, and demarcations, are utilized to provide a safe environment for vehicle and pedestrian traffic throughout the site. 2. Winery Related Events in Accordance with the Meadery Events Site Plan/ Sign Plan: ■ In addition to Mead Production and Winery Operations, appropriate temporary sign locations, sign messaging, and demarcations, are utilized to provide a safe environment for vehicle and pedestrian traffic throughout the site. ■ Highlight areas of significance (e.g. portable toilets & pedestrian only areas) during temporary Winery Related Events. U. Alteration of a Non -Conforming Structure The applicant shall receive approval for a non -conforming use alteration if any changes to height or footprint of the 3,000 square foot farm building/ Meadery building are proposed. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 76 of 86 V. Renovation Permitting For the proposed renovations to the Meadery building, the applicant shall obtain all the appropriate permitting from the Deschutes County Building Division and the Environmental Soils Division. W. Preservation of Landscape and Existing Topography All trees and shrubs existing on -site, not removed by necessity of the proposed development, shall be protected, unless lawfully changed/removed by outright uses (such as farm use) or such change/removal is approved by future land use approvals. X. Private Well Prior to the Initiation of Use of any Aspect of the Meadery, the property owners shall have the well, which provides water to the property and use, reviewed and approved as a Public Water System by either the Oregon Department of Agriculture (ODA) or the Deschutes County Environmental Health Department. Y. Meadery Licensing From Deschutes County Environmental Health Department Prior to the Initiation of Use of any Aspect of the Meadery, the property owner shall obtain all necessary permits from the Deschutes County Environmental Health Department. Z. Meadery Food Cart/ Mobile Food Unit Licensing Prior to the Initiation of Service of the Mobile Food Units (MFUs), the property owner shall obtain all necessary permits from the Deschutes County Environmental Health Department for the Mobile Food Units (MFUs) operating on the property. AA. Permanent Food Cart Utility Servicing Prior to the Initiation of Service of the Permanent Mobile Food Unit (MFU), the permanent Food Cart (MFU) shall be connected to the on -site septic system, the well, and a power source on site while providing food and beverage service at the Meadery. BB. Meadery Septic System Permitting From Deschutes County Onsite Wastewater Division • Prior to the Initiation of Use for the Mead Production, the property owner shall obtain all necessary permits from the Deschutes County Onsite Wastewater Division for the Mead Production facilities. • Prior to the Initiation of Use for the Winery Operations, the property owner shall obtain all necessary permits from the Deschutes County Onsite Wastewater Division specific to the Winery Operations. • Prior to the Initiation of Use for the Winery Related Events, the property owner shall obtain all necessary permits from the Deschutes County Onsite Wastewater Division for the Winery Related Events including any temporary facilities that will be operational on site. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 77 of 86 CC. Meadery Licensing From the Oregon Department of Agriculture Prior to the Initiation of Use of any Aspect of the Meadery, the property owner shall obtain all necessary permits and approvals from the Oregon Department of Agriculture Food Safety Program for the Mead Production, Winery Operations, and Winery Related Events. DD. Meadery Licensing From the Oregon Liquor and Cannabis Commission (OLCC) Prior to the Initiation of Use of any Aspect of the Meadery, the property owner shall obtain all necessary permits and approvals from the Oregon Liquor and Cannabis Commission for the Mead Production, Winery Operations, and Winery Related Events. EE. Meadery Licensing From the US Alcohol and Tobacco Tax and Trade Bureau (TTB) Prior to the Initiation of Use of any Aspect of the Meadery, the property owner shall obtain all necessary permits and approvals from the US Alcohol and Tobacco Tax and Trade Bureau for the Mead Production, Winery Operations, and Winery Related Events. FF. Exterior Lighting All exterior lighting shall be shielded so that direct light does not project off site. GG. Meadery Landscaping - General Standards The landscaping for the Meadery as presented as Exhibit C in the application materials, shall comply with the following standards: • The landscaping in a parking area shall have a width of not less than five feet. • Provision shall be made for watering planting areas where such care is required. • Required landscaping shall be continuously maintained and kept alive and attractive. • Maximum height of tree species shall be considered when planting under overhead utility lines. HH. Meadery Landscaping - Landscaping Strip along Highway 20 The landscaping strip between Meadery parking and Highways 20, as presented as Exhibit C in the application materials, shall contain: • Trees spaced as appropriate to the species, not to exceed 35 feet apart on the average. • Low shrubs not to reach a height greater than three feet zero inches, spaced no more than eight feet apart on the average. • Vegetative ground cover. VI I. DURATION OF APPROVAL NOTICE AND APPEALS The applicant shall initiate the use for the proposed development within two (2) years of the date this decision becomes final, or obtain approval of an extension under Title 22 of the County Code, or this approval shall be void. This decision becomes final twelve (12) days after the date mailed, unless appealed by a party of interest. To appeal, it is necessary to submit a Notice of Appeal, the appeal fee of $250.00 and a statement raising any issue relied upon for appeal with sufficient specificity to afford the Hearings Body an adequate opportunity to respond to and resolve each issue. 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 78 of 86 Copies of the application, all documents and evidence submitted by or on behalf of the applicant and applicable criteria are available for inspection at no cost. Copies can be purchased for 25 cents per page. NOTICE TO MORTGAGEE, LIEN HOLDER, VENDOR OR SELLER: ORS CHAPTER 215 REQUIRES THAT IF YOU RECEIVE THIS NOTICE, IT MUST BE PROMPTLY FORWARDED TO THE PURCHASER. Attachment A: Site Plan for Mead Production and Winery Operations Attachment B: Site Plan for Winery Related Events Attachment C: DSL Wetland Land Use Notice Response Attachment D: Maintained Gravel Map Attachment E: Site Plan for Meadery Service Drives Attachment F: Site Plan for Winery Related Events Service Drives 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 79 of 86 Site Plan for Mead Production and Winery Operations - Attachment A Exhibit C: SITE PLANS 'z*a 5 Rrjr� w 4-4Z I v ♦ tr . 4I Cis IL 4 a 411 5 �-� 46 • 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 80 of 86 Site Plan for Winery Related Events - Attachment B Exhibit H: EVENT MAP 'ta SFa�1Y.ncea' +3h{�.�l.:aa • I54¢��rAcirvl<era + 1 tftiv:\p,:G Ra:A"N�+c'1:5G.8:r.: + ld:ruc • nb+:rWnl Li:ItNraa i4e�ai In>ivk iLw3-+ Example of Portable Toilet Trailer for Winery -Related Events 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 81 of 86 DSL Wetland Land Use Notice Response - Attachment C Response Page Department of State Lands �DSL) WN#* Responsible Jurisdiction Staff Contact Jurisdiction Type Municipality tla9naniel Miller Coj,jnty Deschutes Local case file # County 247-22-000024,CU, 025-SP Deschutes Activity Location Township Range Section Q4 section Tax Lot(s) i 5 10 10 Tt,tJ 685AD Hwy 27 r _out 97759 Dearhutes Latitude Longitude 44,281642 -121 522798 Wettand/Waterway/Other Water Features There arelmay be wetlands, waterways or rather water features art the property that are subject to tilt State Removal - Fill Law based upon a review of wetland maps, the county soil survey and other available Infomwation. The National Wetlands Inventory shows wetland., waterway or other water features on the property Your Activity A state permit will not be required for the proposed project because, based on the submitted site plan, the project avoid%irrpacts tad jucisdiCtiOnal wetlands, walemays, or other walet". Applicable Oregon Removal -Fall Permit Requirement(s) 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 82 of 86 A state permit is required for 50 cubic yards or more of fill removal or other ground alteration in wetlands, below ordinary high water of waterways, Mthin other tvalors of the state, W below highest measured tide. Closing information 21 Additional Comments Please note that the ponds unsito may bo lunsdichonal to removaAil law. if SO c=.rbic. yards or mcfe of disturbance are proposed in this area: a state parrot may be needed: This is a preliminary jurisdictional determination and is advisory only. This report is for the State Reniovat�. Fill taw onty. City or County penwts may be required for the prorosed activity. Contact Information • For rr.tormation tiDn permitting: rase of a state-owned warier, wetland determinWcDn or rfehneati-an report requiremems pleaso e tar.t c:t trio re!�poctive DSL Aquah,. Rceso trce, Pmprie-,taty or Jurisidiction Caordr13Mor for the site cixaAy. Tho ru,rent list is found at: htip:Tha w i.orcren..goertdsl,'v vwe pagesj'v"istafi.aspx • The cuuent RernovFI-Fill permit arrzflar Wet aud, Del Hermon report fee schedule is found r�k. h;4tas:tvew�r.tiaegari.gnu'clsif'v"��d�'tf r�turr3ents,+F €rr a:ui-Fill! res.pdf Response Date Response by: Response Phone, Matthew urritts 503--936.5262 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 83 of 86 Maintained Gravel Map - Attachment D 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 84 of 86 Meadery Service Drive - Attachment E 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 85 of 86 Service Drives for Events - Attachment F M", 247-22-000024-CU, 247-22-000025-SP, 247-22-000757-A, 247-22-000914-A Page 86 of 86 RECOMMENDED MOTIONS Option 1 (Approval): I move: COMMUNITY DEVELOPMENT March 29, 2023 a) To affirm the Applicant's appeal, Appeal No. 247-22-000984-A; b) To approve the Applicant's request to modify its Final Master Plan approval, File No. 247-22- 000678-MC; c) To revise FMP Condition 38 and odd a new FMP Condition 40 as decided at today's deliberations; and d) To den/the appeal filed by Annunziata Gould, Appeal No. 247-23-000003-A. Option 2 (Denial): I move: a) To deny the Applicant's appeal, Appeal No. 247-22-000984-A; b) To deny the Applicant's request to modify its Final Master Plan approval, File No 247-22- 000678-MC; and c) Too irm the appeal filed by Annunziata Gould, Appeal No. 247-23-000003-A. 117 NW Lafayette Avenue, Bend, Oregon 97703 ( P.O. Box 6005, Bend, OR 97708-6005 Q (541) 388 6575 @ cdd@deschutes.org @ www.deschutes.org/cd MEETING DATE: OAR OF March 29, 2023 SUBJECT: Deliberations; Board Review of Two Appeals for a Modification Request to the Thornburgh Destination Resort's Fish & Wildlife Mitigation Plan ("FWMP") RECOMMENDED MOTIONS: To be determined. BACKGROUND AND POLICY IMPLICATIONS: On March 29, 2023, the Board of County Commissioners will conduct deliberations to reach a final decision on the Board's review of two appeals of a Hearing Officer's decision denying a Modification request to the Thornburgh Destination Resort's FWMP. *Please see the attached Staff Memorandum. BUDGET IMPACTS: None. ATTENDANCE: Caroline House, Senior Planner Stephanie Marshall, Assistant Legal Counsel Peter Gutowsky, CDD Director MEMORANDUM TO: Deschutes County Board of County Commissioners ("Board") FROM: Caroline House, Senior Planner DATE: March 22, 2023 RE: Deliberations: Board Review of Two Appeals for a Modification Request to the Thornburgh Destination Resort's Fish & Wildlife Mitigation Plan ("FWMP"). On March 29, 2023, the Board will conduct deliberations to reach a final decision on the Board's review of two appeals of a Hearing Officer's decision denying a Modification request to the Thornburgh Destination Resort's FWMP. 1. BACKGROUND In August 2022, the developer of the Resort ("Applicant") applied for a Modification to replace the 2008 FWMP with a new FWMP ("2022 FWMP"). A Hearings Officer denied the Applicant's request and, subsequently, two appeals of the Hearings Officer's decision were received. The Board agreed to hearthe appeals and held a de novo appeal hearing on February 1, 2023. The record is now closed and includes over 800 submittals for the Board's consideration. 11. SUMMARY Please see the attached Decision Matrix for the deliberation issues and related summaries. III. 150-DAY LAND USE CLOCK The 150th day on which the County must take final action on this review is April 10, 2023. Once deliberations are complete, a decision will be drafted and staff will present the draft to the Board on April 10, 2023. 117 NW Lafayette Avenue, Bend, Oregon 97703 1 P.O. Box 6005, Bend, OR 97708-6005 Qi (541) 388-6575 @cdd@deschutes.org @www.deschutes.org/cd IV. RECORD The record for the subject application and appeals is as presented at the following Deschutes County Community Development Department website: https://www.deschutes.org/cd/page/247-22-000678-mc-thornburgh-destination-resort- modification-cmpfmpfwmp Attachments: Decision Matrix Applicant's Final Argument 247-22-000678-MC / 247-22-000984-A / 247-23-000003-A Page 2 of 2 O z L o V1 OJ 4 a, E u Q N O r6 N i j Ln •� Ul 6 m v O L.J 00 o°o n N C o f o 'o N p u p u c N a N o Y vi 3 Y v o t y @ c)- L Op m in C v p rV C O 'C C C N@ N p o C O -p O O N vi C C o E L oE Y Q a '; a C 2 -c o CNvc ov. 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O p. 0 N E Q — V cc c v Q E a ° O a m L � � N O C C .— N N V . a) N G C v by a V 6 � N C v Vn O C v7 Y � C N � � @ L — c � a O m 0 3 Q L — N v (u C u 7 Y V 7• � w N O by v C L Q L p V ru Q Q Y I N Q LL v y N L N N N � N 7 C 7 v by O Q O a a to O T i O C Y N Y O7 C v v C @ C Q N L Q C N Q 0 b v E --I--Q o h Q V cu N 4- 0 m � VI Qj v B :3 O ^' ro W > O -W Q (6 ^� r6 L � Vu N O = O L C LA C. cu N N N N L1 a v VI v VI Vf 'p aN o °N `o 0 LL 0 L N N V t Gp N C a t 4,�.� o� Lo N 6 Q L v L N N y0 O v C i U 7 Q bD C C O 2 E 7 j a .0 N O @ O p O bq V 9 t v V- v Q V i a U v•y 3 o O O c a o� Z lcoo•� �c c v v N C L -p y •C v a) v v a 2 O Cc: O v LI V Qj C) vi v v �6 Y L C) 0 o N N C C v v E E N v v Q• a o � _o 6 v O L a In a) Q v Q 3 u v v v C O O N N - Q Q 7 C C Q O N v n3 v C Q -O L -0 L Y v v v a1 V1 E Q a bQ N a N O C Y O Y O V (uV a) a) Q'— Q c E IVE a) Y L V U C C w C ai O @ O > O C N •� N v N N N b V .O = v (u v C v 7 v 7 Q D- N Y v ate.+ iJ t N v o aNi o Y b7o bco b7Lo aco bo to N .0 .0 .— a) L 6 N � C v C � O r L N O Q .� Q .0 N N V V o 0 Schwabe WILLIAMSON & WYATT(k March 15, 2023 VIA E-MAIL Board of County Commissioners c/o Caroline House, Senior Planner PO Box 6005 Attn: BoCC Bend, OR 97708-6005 Kenneth Katzaroff Admitted in Washington and Oregon T:206-405-1985 C:206-755-2011 KKatzaroff@schwabe.com RE: File No. 247-22-000678-MC; 247-22-000984-A; 247-23-000003-A; Applicant's Final Legal Argument Our File No.: 135849-262760 Chair Adair, Commissioners DeBone and Chang: Enclosed is Applicant's Final Legal Argument provided in the form of a proposed final decision and attachments. Exhibit A is a chart of issues which must be included and generally responds to all substantive issues related to the no net loss criteria. Exhibit B is the final 2022 FWMP. We request that, besides potential clerical changes, the Board adopt this draft decision and attachments. Sincerely, SCHWABE, WILLIAMSON & WYATT, P.C. 11 Kenneth Katzaroff � Enclosures P DX\ 13 5 849\262760U KKA\3 6207208.1 DRAFT: For Consideration as Applicant's Final Legal Argument DECISION OF THE DESCHUTES COUNTY BOARD OF COUNTY COMMISSIONERS File Number: 247-22-000678-MC; 247-22-000984-A; 247-23-000003-A Subject Property: The entirety of the Thornburgh Destination Resort located at: Address Deschutes Co. Assessor Map ,& Tax Lot Number 11800 Eagle Crest Blvd, Redmond, OR 97756 15-12-00, TL 5000 11810 Eagle Crest Blvd, Redmond, OR 97756 15-12-00, TL 5001 11820 Eagle Crest Blvd, Redmond, OR 97756 15-12-00, TL 5002 67205 Cline Falls Rd, Redmond, OR 97756 15-12-00, TL 7700 67705 Cline Falls Rd, Redmond, OR 97756 15-12-00, TL 7701 67555 Cline Falls Rd, Redmond, OR 97756 15-12-00, TL 7800 67525 Cline Falls Rd, Redmond, OR 97756 15-12-00, TL 7801* 67545 Cline Falls Rd, Redmond, OR 97756 15-12-00, TL 7900 67400 Barr Rd, Redmond, OR 97756 15-12-00, TL 8000** * A portion of this tax lot is not included in the FMP. ** Portions of this tax lot are not included in the FMP. Owners/Applicants: Central Land & Cattle Company, LLC, Kameron DeLashmutt, Pinnacle Utilities, LLC (collectively "Applicant") Applicant's Attorneys: J. Kenneth Katzaroff— Schwabe Williamson & Wyatt Liz Fancher — Attorney at Law Staff Contact: Caroline House, Senior Planner — Deschutes County Record: The official record was maintained by Deschutes County and accessible online through aproject-specific website at: https://www.deschutes.org/ed/page/247-22-000678-mc- thornburgh-destination-resort-modification-cmpfmpfwmp Proposal: Applicant seeks to modify a discrete aspect of its final master plan ("FMP") approval, namely the mitigation measures found in its Fish and Wildlife Mitigation Plan ("FWMP"). Applicant also seeks to modify FMP conditions to reflect that change and ensure compliance with the new FWMP. The proposal is referred to as the "Application." I. Applicable Criteria Deschutes County Code ("DCC") Title 18, Deschutes County Zoning Ordinance: 1- PDX\I 35849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicatst's Final _ Legal Argument Chapter 18.113, Destination Resorts Zone Title 22, Deschutes County Development Procedures Ordinance: Chapter 22.04, Introduction & Definitions Chapter 22.08, General Provisions Chapter 22.20, Review of Land Use Action Procedures Chapter 22.28, Land Use Action Decisions Chapter 22.36, Limitation on Approvals H. Basic Findings As described below (see Resort Land Use History), the Thornburgh Destination Resort ("Thornburgh" or the "Resort") has been litigated for nearly 20 years. During that time period, the Board of County Commissioners ("Board") has heard numerous appeals related to the Resort. The current Application seeks to modify a discrete supporting document to the Resort's FMP. However, multiple parties have raised additional issues that are either outside of the scope of the Application, are not relevant approval criteria, have already been decided in prior proceedings and are binding, or otherwise do not provide a basis for denial of the Application. These arguments are addressed in detail in Exhibit A, which is expressly adopted as part of this decision and is meant to supplement the findings herein. When referenced and unless otherwise noted the "Staff Report" refers to the Staff Report issued by Caroline House on October 17, 2022, in advance of the public hearing before the Hearings Officer. A. Lot of Record The Subject Property has been verified as a legal lot(s) of record in previous land use decisions including the Board's 2006 decision approving the Resort's CMP. B. Location and Site Description The Thornburgh Destination Resort ("Thornburgh" or "Resort) is comprised of, generally, a large tract of land +/- 1,970 acres in size and includes several tax lots as identified above. The Subject Property is approximately 3 miles west-southwest of the City of Redmond. The Subject Property includes variable topography, native vegetation, rock outcroppings and ridge tops. At this time, the Subject Property is largely undeveloped land. However, the Applicant has started construction of access roads, other infrastructure improvements (i.e., community water system, community sewer system, etc.), and a golf course pursuant to final land use approvals. In addition, the Applicant has applied for and been granted building permits for utility facilities with additional permits pending. The southeastern corner of the subject property is bisected by Cline Falls Road and Barr Road bisects the southwest corner of the Resort tract. C. Resort Land Use History 2- PDX\ 135849\262760V KKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument The hearings officer adequately captured the prior land use history related to the Resort. Since the hearings officer made his decision, two additional decisions were denied review by the Supreme Court of Oregon. Gould v. Deschutes County, _ Or LUBA _ (LUBA No. 2022-013, June 1, 2022), aff'd 322 Or App 11 (2022) ("Gould OLUU ), rev den, _ Or _ (S069882). Gould v. Deschutes County, _ Or LUBA App 383, rev den, Or _ (S069813). D. Public Agency Comments (LUBA No. 2022-011), aff'd without op, 322 Or The Staff Report contained a summary of public agency comments submitted in to the record as of the date of that Staff Report. Additional comments from the Oregon Department of Fish & Wildlife ("ODFW") were received during the appeal hearing before the Board and are addressed under relevant finding or in Exhibit A. E. Public Comments, Testimony, and Record Submissions As with any Thornburgh application, robust public participation occurred throughout the review of the Application. Relevant testimony is addressed under relevant findings and in Exhibit A. F. Review Period and Procedure The hearings officer detailed the proceeding before him. Both Thornburgh and Appellant Gould appealed his decision, and the Board accepted de novo review. After a hearing on February I" before the Board, the open record period was left open for 14-days until February 15th. Following a joint request of the Applicant and the Confederated Tribes of the Warm Springs Reservation ("Tribe")', the open record period was extended until March 1st, 2023. A rebuttal period was allowed consistent with the original record procedure for seven days until March 81h, with final legal argument due on March 151h. The Board issued an order updating these time periods. Accounting for all waived time agreed to by the Applicant, the County's 150-day clock is set to expire on April 1 oth, 2023. G. Summary of Application The Applicant seeks to replace the 2008 FWMP document with an updated 2022 FWMP.2 A copy of the proposed 2022 FWMP in its final form is attached as Exhibit B. The Board understands that this is the final document has imposed a condition of approval that requires compliance with this document. The 2022 FWMP relies on Condition 39 of the FMP (TSID I The Confederated Tribes of the Warm Springs Reservation refer to themselves as the "Tribe" and so we do the same. '- The 2008 FWMP is comprised of two documents, the April 21, 2008 Fish and Wildlife Mitigation Plan Addendum Relating to Potential Impacts of Ground Water Withdrawals on Fish Habitat and the August 11, 2008 letter from attorney Martha Pagel committing to take certain actions related to Whychus Creek. 3- PDX\ 135849\262760\JKKA\3621093 5.1 DRAFT: For Consideration as Applicant's Final Legal Argument mitigation project) to achieve compliance with the no net loss/degradation standard of DCC 18.113.070(D) for Whychus Creek. The Whychus Creek supplement to the 2008 FWMP is not modified by the 2022 FWMP. The Applicant, in response to concerns expressed in the hearings officer's decision, also asks the Board to modify FMP Condition 38 and to impose a new FMP Condition 40 to clarify what constitutes compliance with the 2022 FWMP. Current FMP Condition 38: "[Thornburgh] shall abide by the April 2008 Wildlife Mitigation Plan, the August 2008 Supplement, and all agreements with the BLM and ODFW for management of offsite mitigation efforts. Consistent with the plan, [Thornburgh] shall submit an annual report to the county detailing mitigation activities that have occurred over the previous year. The mitigation measures include removal of existing wells on the subject property, and coordination with ODFW to model stream temperatures in Whychus Creek." Proposed Revised FMP Condition 38: "Thornburgh shall abide by the April 2008 Wildlife Mitigation Plan (excluding the April 21, 2008 FWMP addendum to that plan and its addenda), and all agreements with the BLM and ODFW for management of offsite mitigation efforts. Consistent with the plan, Thornburgh shall submit an annual report to the county detailing mitigation activities that have occurred over the previous year. Proposed NEW FMP Condition 40: Thornburgh shall comply with the 2022 Fish and Wildlife Mitigation Plan, including its compliance and reporting mechanisms found in Section II of that plan If Thnrnhm-gh proposes to further change the cnilrce: of water or mitigation it may do so during a land use proceeding as part of a third stage development application under DCC 18.113.040.0 so long as evidence in the record shows that the change will not result in a violation of the no net loss standard. H. Standard of Review — Substantial Evidence Before addressing specific applicable criteria, the Board notes that the standard it must review the evidence under is the "substantial evidence" standard. Substantial evidence is evidence a reasonable person would rely on in drawing inferences and reaching a decision. City of Portland v. Bureau of Labor & Indus., 298 Or 104, 119, 690 P2d 475 (1984). Substantial evidence includes, but is not limited to: staff reports/statements by staff, expert testimony addressing relevant issues, and technical reports. See, e.g. Scott v. City of Portland, 17 Or LUBA 197, 202 (1988); Oberdorfer v. Harney County, 64 OR LUBA 47, 50-51 (2011); Boucot v. City of Corvallis, 64 Or LUBA 131, 138-39 (2011). Bare assertions are not substantial evidence, and LUBA will affirm a county's decision where opponents cite to no evidence in the record to support their assertions. See Comden v. Coos County, 56 Or LUBA 214, 228 (2008). Additionally, when it comes to technical questions something more than lay testimony is necessary to rebut an expert's testimony, and `mere statement of a party's attorney does not provide the required evidentiary foundation necessary to support conclusions regarding such technical questions. See, e.g., Oregon Coast Alliance v. City of Brookings, 72 Or LUBA 222, 232-33 (2015). 4- P DX\ 13 5 849\262760\J KKA\3 621093 5.1 DRAFT: For Consideration as Applicant's Final Legal Argument In many instances, as have been discussed in Exhibit A or below, project opponents including Appellant Gould, ODFW, and the Confederated Tribes of Warm Springs (the "Tribe") have chosen not to provide evidence and, instead, simply critique matters of statewide water policy or the conclusions of Thornburgh's technical evidence. The Board is bound to makes its decision based upon evidence in the record and if the only evidence shows compliance with applicable law and critiques are insubstantial, the Board must approve an application. The technical expertise provided by Thornburgh's team is vast. We agree with the hearings officer that Thornburgh's technical evidence was prepared by credentialed experts who provided an extreme level of analysis and detail. Additionally, Thornburgh's team of experts includes experts with significant experience working in analyzing waterways in the Deschutes Basin; something Ms. Gould's experts lack. The Board finds that Appellant Gould's experts are less credible and not nearly as comprehensive. For example, Appellant Gould's attorneys (Ms. Bragar and Mr. Anuta) are not technical experts. And, while Mr. Lambie may be a CWRE and engineer, he is not a fish biologist nor does he have any wildlife or habitat related credentials. The opposite is true for Thornburgh's slate of experts, which include PH.ds in biology with special certifications in fisheries. See Table 2: Comparison of Experts. We find that the resumes included related to the Thornburgh's experts is persuasive as to their subject matter and technical expertise. Similarly, ODFW and the Tribe have generally not provided expert opinion or analysis related to habitat impacts. As discussed below, most arguments or issues raised related to the 2022 FWMP meeting the No Net Loss Standard do not present biological or habitat related argument; they raise issues related to statewide water policy. This is addressed further below and in Exhibit A. 5- PDX\ 135849\262760\3KKA\36210935.1 DRAFT: For ConsideratIOD as Applicant's Final Legal Argurnent Table 2: Comparison of Expert Testimony ODFW Expert Goulds Expert Tribes Expert Subject Thornburgh Expert Testimony Testimony Testimony Testimony Dr. Kellie Vache, Ph.D, Water Resource Engineering. Has over 20 yrs experince, has modeled the Lower, Middle and Upper Deschutes and Lower Crooked Rivers and authored 60 scientific journals, articles, or books. Mr. Joe Eilers, Master of Science in Water Quality Management w/over 40 years of experience. A hydrologist who Mr. Lambie The Tribes has authored 40 scientific journals and ODFW provided no provided memo provided no completed modeling on the Lower, expert testimony from E-Pur that expert testimony Middle and Upper Deschutes River on water in any dealt with on water in any respect. elements of the respect GSFlow modeling. Dr. Pradeep Mugunthan, Ph. D, Civil & Environmental Engineering with 20 yrs of experience. He is an expert at modeling groundwater -surface water interactions and modeling the effects of How and water quality changes on aquatic habitat. He has authored 14 scientific papers, journals or publications. ODFW provided no Mr. John Lambie, The Tribes Water Mr. Jim Newton, Certified Water Rights expert testimony Certified Water provided no Rights & Examiner, Registered Geologist, expert testimony on water rights or Rights Examiner, Mitigation Registered Engineer. Over 20 years of on water rights or the OWRD Registered Program experience with groundwater and related mitigation rules. Geologist. the OWRD -elements in the Deschutes Basin. mitigation rules. Dr. Lucius Caldwell, Ph. D. Biological Mr, Gerald Sciences, and Certified Fisheries George, ODFW Professional w/13 yrs of experience District Fish regarding the instrearn flow and fish Biologist. Fish and habitat disciplines, and has designed, led, Unaware of any NONE NONE Fish Habitat or participated in dozens of studies and specific education projects focusing on Pacific salmonids. but have assumed Mr. Joe Eilers, in addition to his expertise Mr. George has on water quality listed above Mr- Eilers is such for fish. a Certified Fisheries Biologist, and a .Certified Lake Manager. Dr. Tim Deboodt, Ph- D. Natural Resource Manager for Crook County. Formerly with OSU Extension service. NONE NONE NONE Leading expert on Juniper trees and the relation to surface and ground water resources. 6- PDX\1 35849\262760\JKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument III. Findings & Conclusions Where relevant, the Board specifically incorporates and adopts additional findings found in Exhibit A hereto. All parties appear to agree that the most relevant criterion related to the Application is found at DCC 18.113.070(D) which provides that in order to approve a destination resort substantial evidence must be provided that "any negative impact on fish and wildlife resources will be completely mitigated so that there is no net loss or net degradation of the resource." This is referred to as the "No Net Loss Standard." It is undisputed that the 2008 FWMP met that standard. 3 Because the No Net Loss Standard is the most relevant to this Application we address it first. A. DCC 18.113.070 Approval Criteria In order to approve a destination resort, the Planning Director or Hearings Body shall find from substantial evidence in the record that: D. Any negative impact on fish and wildlife resources will be completely mitigated so that there is no net loss or net degradation of the resource. For all of the reasons described below and in Exhibit A, the Board finds that the Application meets the No Net Loss Standard. Thornburgh provided a substantial amount of technical analysis and reports that we find persuasive. Of note, included in the technical analysis was a comprehensive summary of the impacts on fish habitat by Lucius Caldwell, PhD, FP-C, who concluded: "In conclusion, the findings presented above indicate that the combination of planned groundwater pumping at Thornburgh Resort, and the associated mitigation planned to offset this pumping as described in the 2022 Fish and Wildlife Mitigation Plan (NCI 2008; Newton 2022), appear to be a net benefit for both fish habitat quantity and quality at all sites evaluated and would result in no net loss of fish habitat quantity or quality. " The Board finds that statement is, while not determinative in the outcome of this case, relevant and persuasive. This statement was made during the open record period and no party has provided expert testimony to rebut it, including ODFW. Interpreting the Scope of the No Net Loss Provision The Court of Appeals has previously interpreted the scope of the No Net Loss Standard. See Gould v. Deschutes County, 233 Or App 623, 633 (2010). That decision found that the standard "may be satisfied by a plan that will completely mitigate any impact on the habitat that supports fish and wildlife, without showing that each individual species will be maintained or replaced on a one-to-one basis." The same is logically true for each individual stretch of river, stream, or waterway; so long as there is evidence in the record to support a finding that the impacts are mitigated such that overall, there is no net loss or degradation. 3 The 2008 FWMP only dealt with mitigation related to water habitat and was not intended to address terrestrial habitat. Terrestrial habitat is addressed through a separate plan that is not disturbed by the current Application. 7- PDX\135849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument. As it relates to that standard, the 2008 FWMP was found to meet it despite showing temperature increases in certain stretches of the Deschutes river of up to an increase of 0.1 degree C, with an average increase in temperature of 0.07-degree C4. Here, the evidence provided by Thornburgh through vast quantities of technical data, modeling, and reports, shows that Thornburgh's 2022 FWMP increases flows and decreases temperature, an average of (0.01 degree C), which improves fisheries habitat quality and quantity.5 Extensive technical analysis was completed on the Deschutes River, the Crooked River and Whychus Creek, that included: i) complete modeling of surface water flows resulting from changes to groundwater discharge in the 2022 FWMP using the USGS GSFIow model, ii) detailed analysis of the thermal impacts resulting from the changes in flow using the QUAL2Kw model, iii) analysis of changes in flow and temperature, employing both GSFIow and QUAL2Kw in 7 specific spring locations requested by ODFW, iv) further detailed thermal modeling of specific locations around springs in Whychus Creek, v) an analysis of the effects on fish habitat in each of 3 water ways, followed by a Comprehensive Summary of the 2022 FWMP as it pertains to fish habitat. In addition to his conclusions on the entire plan quoted above, Dr. Caldwell assessed the individual streams reaching the following conclusions on each of the following streams: Deschutes River: "Overall, the combined effects of planned groundwater pumping and mitigation appear to be a net benefit for both habitat quantity and quality within the Deschutes River, throughout the vast majority of the irrigation season. " Crooked River: "Overall, the combined effects of planned groundwater pumping and mitigation appear to vary seasonally within the Crooked River. During the spring and fall, a net impact is expected for fish habitat quantity and a net benefit for fish habitat quality. During the summer, a net benefit is expected for fish habitat quantity and a net impact for fish habitat quality. " Whychus Creek: "Overall, the combined effects of planned groundwater pumping and mitigation appear to be a net benefit for both fish habitat quantity and quality within Whychus Creek, throughout the vast majority of the irrigation season. " Little Deschutes River: Overall, the effects ofplanned groundwater pumping and mitigation appear to be one of a habitat quantity benefit throughout the irrigation season, and variable, very small impacts or benefits to habitat quality that vary throughout the irrigation season. Dr. Caldwell's report was submitted during the open record period. There was no response in the rebuttal period provided by a biologist related to habitat impacts to rebut his report. No party, including ODFW, rebutted his findings. 4 Thornburgh's 2022 FWMP results in reduced temperatures versus increased temperatures in the 2008 plan that were found to meet the No Net Loss Standard. 5 The modeled negative impacts are so small as to be immeasurable and of no biological significance and are far less than the 0.1 degree increase that was previously determined to meet the standard when it approved the 2008 FWMP. 8- P DX\ 13 5 849\262760\J KKA\3 621093 5.1 DRAFT: For Consideration as Applicant's Final Legal Argument According to the science and technical reports, there is generally no scientific or biological significance in the impacts' under the 2022 FWMP and that as a whole the plan provides benefits to habitat for fish and aquatic species.. Given this context, we find that the 2022 FWMP plan meets the No Net Loss Standard. Nothing in the No Net Loss Standard or our previous application of it requires that Thornburgh receive "approval" from ODFW. In fact, as recently as 2018, this Board declined to impose additional mitigation requirements proposed by ODFW related to other destination resorts. a) Drought and Outside Impacts Many of the arguments and issues related to Thornburgh's 2022 FWMP are related to drought and regional well decline. Opponents assert that these are relevant issues and should lead to denial. We disagree in large part. The No Net Loss Standard requires a resort to mitigate its own impacts, not the cumulative impacts of drought or other basin -wide water policy and management issues. The no net loss/degradation test is limited to addressing potential negative impacts of resort development. Impacts to habitat caused by other persons or environmental conditions are not attributable to Thornburgh's use of water or the impacts of Thornburgh's use. Thornburgh has quantified its impacts on water quality and quantity and the locations where these impacts will occur. It has studied waterway conditions in a typical year, and it has also provided expert evidence that shows the benefits of mitigation are enhanced during periods of drought. This approach properly accounts for issues of drought and the low flow conditions opponents argue make the results of Thornburgh's expert analysis of aquatic habitat unreliable. Opponents, including the Tribe and ODFW, have also raised issues that pending litigation regarding flow requirements and the Habitat Conservation Plan ("HCP") related to the Spotted Frog may lead to additional constraints on live flows. These issues are outside of the scope of the Thornburgh's impacts and Thornburgh is not required to mitigate for them. Thornburgh must mitigate for its impacts, alone. Further, Thornburgh's plan relies primarily upon groundwater water sources, and its technical analysis shows that the 2022 FWMP will result in increased surface flows which are beneficial to fish and wildlife. Thornburgh has also provided expert testimony that its plan will not result in negative impacts to the spotted frog, which we find persuasive. b) Regional Well Decline A large amount of testimony was received regarding regional well declines. This issue has no bearing on whether Thornburgh mitigates its own water use to ensure no net loss or degradation of habitat. Moreover, the record includes evidence that overall groundwater recharge in the Deschutes Basin far exceeds groundwater withdrawals. 2. No Net Loss Standard does not Prescribe Methods; Water Policy Issues 6 Substantial evidence shows that virtually all flow and temperature changes, while mostly all beneficial are too small to measure with equipment currently available. Even ODFW notes that impacts to the Crooked River, for example, are "noise." 9- PDX\ 135849\262760U KKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument Appellant Gould, ODFW, the Tribe, and others all assert that the only way to meet the No Net Loss Standard is through "legally protected" instream water — and more particularly, that legal protection can only occur by providing an instream transfer. We do not agree. OWRD has established mitigation rules for the Deschutes Basin which include several different methods of providing legally protected flows. See e.g., OAR 690-505-0605; OAR 690-505-0610. Additionally, other actions may also achieve compliance with the no net loss test, as demonstrated by ODFW's approval of the Eagle Crest mitigation plan that involves the acquisition and nonuse of Swalley Irrigation District water rights and pumping of some of the rights in a different, more environmentally beneficial location. In reality, the arguments made by opponents relate primarily to issues related to water policy and management, an issue outside of our control and under the sole discretion of OWRD. Here, many of the issues ODFW or others have raised are related to OWRD and have little to nothing to do with Thornburgh. For example, ODFW argues that ORS 537.270 does not assure water is actually available. However, that statute specifically provides to the contrary. In particular, ODFW takes issue with the "reliability" of certain water rights included in the 2022 FWMP. ODFW asserts that unless Thornburgh can show that the water right has been used to its full extent for 8 of the past 10 years, then any benefit it provides under the 2022 FWMP should not accrue or should be substantially discounted (to 20% of the water right) because the water is already remaining in stream instead of being used. That position is devoid of merit. Testimony to this record makes it clear that no "new" water rights are being created in the Deschutes Basin; all water use must already be certificated or mitigated for by retiring existing rights. This means that if Thnm nrgh does not use the water rights, it is reasonable to assume they w ll be sold and used by someone else.' They do not just remain in stream. Moreover, Oregon water law only requires use to the full appropriation once every five years. ODFW's subjective discounting of water rights is not consistent with the law. There is no factual basis for applying such a draconian discount to any water rights and no actual relationship to the efficacy of the proposed mitigation. Opponents, notably ODFW, claim on one hand that groundwater discharge is important to them to protect fisheries habitat, but when presented with the 2022 FWMP that is focused on the direct restoration of groundwater to replace reduced groundwater discharge question the "transfer strategy" and how it provides benefits. Several comments claimed it was complex, or too difficult to understand but this is due to the fact the issues are ones that must be addressed by qualified experts. Thornburgh stated that the 2022 FWMP is based on simple, well -established principles that provide in -kind mitigation, largely increasing cool groundwater discharge to replace the loss of the same, and, replacing the groundwater discharges in -proximity to where the impacts would occur, and doing so in advance of when any pumping occurs. We concur with the Applicant and find the technical analysis to be persuasive. Thornburgh provided expert testimony from its CWRE, as well as expert technical analysis in the form of temperature and flow information that transferring the proposed water (following the 2022 FWMP) would result in additional flows and cooling temperatures, generally. There was scant technical rebuttal to Thornburgh's expert testimony. For example, as it relates to changes in 7 Multiple parties testified that the Tree Farm water right was acquired by Thornburgh underwent competitive bidding processes with multiple buyers vying for the water right and so could be used by others. 10- PDX\ 135849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's final Legal Argument flow the only technical materials submitted in opposition were by Ms. Gould's consultant, Mr. Lambie. Mr. Lambie submitted technical reports including flow information on the Crooked River, also derived from the USGS GSFlow model; the same model relied upon by Thornburgh's expert. Mr. Lambie's technical information confirmed what Thornburgh's experts stated, that there was a reduction in flow, although slight on the Crooked River. Mr. Lambie provided no opposing data pertaining to the changes in flow in any other reach, which are largely areas Thornburgh's expert analysis showed increased flow. There was no technical analysis of the thermal impacts or expert testimony provided on such by any opponents. And, as noted above, there was no rebuttal or expert testimony disputing Dr. Caldwell's summary of the effects on fish habitat. We find this information to be persuasive. We note that opposition arguments criticize water law and OWRD on one hand and rely on it in others.$ For example, in ODFW's March 1st letter, it takes issue with OWRD's water management and existing water law. At the same time, it claims that a single method of mitigation allowed by the Deschutes Basin Groundwater Programinstream water transfers —is the only acceptable form of mitigation and that is must be discounted by 20% in certain circumstances. This sort of consultation and comment is unhelpful as it implies a bias to only specific measures and rejection of all others without addressing the overall technical or scientific impacts of other measures that also provide habitat benefits. In fact, Thornburgh pointed out that many of the factual assertions that underlay ODFW's March 1" letter were incorrect and it did so two days before the rebuttal period closed by sending its comments to ODFW directly. ODFW chose not to respond or to correct the factual errors in its testimony that led to its recommendation. This fact supports the Board's conclusion that ODFW's testimony is less reliable and less credible than Thornburgh's. Nothing in our No Net Loss Standard prescribes any method to meet it. Theoretically, a project applicant could meet it without taking any single mitigation measure, so long as that was supported by substantial evidence. For example, a developer could propose a resort that significantly improves terrestrial or avian habitats that far outweigh any aquatic impacts such that no fish mitigation is required. As relevant and applicable to the Application at hand, however, is that Thornburgh has prescribed measures in its 2022 FWMP which result in meeting the No Net Loss Standard for aquatic habitat alone, as testified to by multiple technical experts of various disciplines. The 2022 FWMP describes that Thornburgh, who already owns approximately 1,211 acre-feet of water rights, intends to use those rights in a variety of ways to grant it the right to pump water at the Resort, each of which their experts claim will provide similar benefits. The different methods of use include: a) Transferring the water rights from their existing points of appropriation to wells at the Thornburgh Resort, b) Transferring the surface water rights to instream water rights, and c) Cancelling the water right in -lieu of mitigation. 8 Although we only specifically address ODFW's comments here, many other commenters argued that the only method of mitigation that is efficacious is instream water rights that are transferred to a governmental entity. That is not the law. 11- PDX\1 35849\262760\JKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument Of the three, opponents claim that (b) is the only acceptable method. Thornburgh provided substantial evidence that all three methods were appropriate and acceptable. Mr. Anuta, Gould's attorney and others claim that there is no "Cancellation in -lieu of Mitigation" program or strenuously and repeatedly claimed cancelling would not protect the water instream, and that anyone else (more junior user) could simply grab the water so there is no benefit. Thornburgh's experts disputed those claims. Mr. Lambie, Gould's expert provided testimony that the formal name for what applicant refers to as cancellation in -lieu of mitigation is the "Offset Voluntary Mitigation Option" which is an acceptable form of mitigation and. as the evidence shows, does result in protected instream water under the OWRD mitigation rules. OAR 690-505-0610. We find Thornburgh's experts to be knowledgeable and reliable. Water Law vs. the No Net Loss Standard ODFW and the Tribes have expressed concern over what they see as shortcomings between OWRD water law and the no net loss standard, i.e.: that water law will not ensure compliance with the No Net Loss Standard. At the same time the opponents raise concerns about the shortcomings of water law, they embrace the use of legally protected instream water rights as the only way to comply with the same standard. and the applicant has shown that Oregon water law and additional assurances in its 2022 FWMP will be reasonably likely to achieve compliance with the no net loss standard. 4. ODFW Reliability of Water Rights As noted above, ODFW disagrees with elements of OWRD water law and desires to create a new standard related to the reliability of water rights that is outside of typical water law, particularly for these Thornburgh proceedings and to impose that standard on Thornburgh. This could put Deschutes County into the position of determining aspects of water law that have been delegated to OWRD and not to counties. We decline to take that approach. Thornburgh has provided substantial evidence of pumping records, aerial photos, affidavits of use for individual water rights that indicate substantial use and that rights will provide actual benefits to impacted waterways. Additionally, as Thornburgh has pointed out, ORS 537.270 directly relates to whether certificated water rights are evidence of water priority and appropriation or use. We find that where Thornburgh has (or is planning to use) certificated or permitted water that the amount of appropriation, duty and priority govern here. Compliance with the 2022 FWMP The hearings officer faulted Thornburgh for not providing clearer compliance requirements. ODFW also expressed similar concerns. The hearings officer cited compliance language in Thornburgh's burden of proof in questioning whether that should or should not be included. That language provided the basis for the addition of compliance language in the amended FWMP. The evidence shows that Thornburgh worked with ODFW to further develop language acceptable to ODFW which was incorporated as Section D in the amended FWMP. ODFW 9 There is no evidence that shows ODFW has requested any similar rules for any other resort projects in Deschutes County, nor evidence that shows any other project has been held to similar rules. 12- PDX\ 135849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument provided a letter at the hearing stating the language was acceptable. 'Thornburgh also provided language for a proposed condition 40, that we are accepting to enforce compliance. In addition, there was concerns the 2022 FWMP would create conflict with existing FMP Condition 38. Thornburgh has requested amending the language to that condition and we also accept that change. Both conditions are below and are imposed: Revised FMP Condition 38: "Thornburgh shall abide by the April 2008 Wildlife Mitigation Plan (excluding the April 21, 2008 FWMP addendum to that plan and its addenda), and all agreements with the BLM and ODFW for management of offsite mitigation efforts. Consistent with the plan, Thornburgh shall submit an annual report to the county detailing mitigation activities that have occurred over the previous year. FMP Condition 40: Thornburgh shall comply with the 2022 Fish and Wildlife Mitigation Plan, including its compliance and reporting mechanisms found in Section II of that plan. If Thornburgh proposes to further change the source of water or mitigation it may do so during a land use proceeding as part of a third stage development application under DCC 18.113.040.0 so long as evidence in the record shows that the change will not result in a violation of the no net loss standard. 6. Advance Mitigation Thornburgh has secured, by purchase, all of the water rights described in the 2022 FWMP. The rights will not be pumped regardless of the outcome of transfers or other actions. If a transfer is not approved, the mitigation water created by the cessation of pumping the water right will still provide actual benefits to streamflow, and aquatic habitat. That is what is needed to meet the no net loss test. In addition, the evidence shows that Thornburgh has ceased pumping all the water, with the majority of it already providing mitigation as defined in the FWMP. Thornburgh has been providing mitigation under the individual right, in some cases, for more than a decade. While the Board is not relying upon the advanced mitigation to meet the No Net Loss Standard once its benefits no longer exist, it is meaningful until that time.. Ultimately, our decision finds compliance with the No Net Loss Standard based upon all measures described by the 2022 FWMP. 7. Whychus Creek Whychus Creek was the subject of intense litigation that was resolve with the approval of the FMP. The FMP required mitigation restoring into Whychus Creek of 1.51 cfs (a minimum of 106 acre-feet) of conserved water from the Three Sister Irrigation District. The Whychus Creek mitigation is final and past all appeals. As there is no change to this segment of the FWMP any attack against the plan in an impermissible collateral attack on the FMP. Further the evidence shows that Thornburgh has completed the requirements pertaining to the Whychus Creek Mitigation and that the water has been permanently transferred instream. In addition, Thornburgh is canceling the Dutch Pacific water right that will provide additional groundwater discharge to Whychus Creek. Reduction of Water Consumption. 13- PDX\135849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument Thornburgh has taken the substantial step to reduce its water consumption by roughly 35%. This in turn reduces all impacts on stream flows and leaves more water in the regional aquifer. As Thornburgh stated, it reduced water use in direct response to opponents' calls to do so. This is a positive action. 9. Other Beneficial Actions Table 1. Chart of MRigation A. Benefits calculated to meet compliance with no net loss # Groundwater 7F AF Type Owrnemitip MR: Action Date i BFR Deep Canyon-Terrebonne 614.8 Irrigation TRC Thornburgh stopped pumping leaving water 2022 2 BFR Groundwater- Terrebonne 18.9 Irrigation TRC in aquifer to be discharged via seeps and 2021 3 Dutch Pacific - Sisters 49.5 Irrigation TRC springs into the river as noted in the GSFIow 2019 4 Tree Farm - Bend 327.5 Quasi -Muni TRC & QUAL21(w modeling. 2021 Surface water In 2021 Thornburgh placed water temp. instream. In 2022 provided water to NUID. 5 LeBeau - LaPine 200 Irrigation TRC Will do temp transfer instream in 2023. 2021 Water will increase flow from POD to LBC. Permanent transfer pending. :Permanent Instream Transfer of 1.51 cfs accomplished by 6 TSID Sisters-1.51 cfs Conserved 106 canal piping. Funding for project provided by Thornburgh. 2012 Water Project is complete satisfying Condition 39. Total 1316.7 NOTE: Provides a net benefit to fish habitat, quality and quantity. B. Benefits not included in compliance with no net loss (extra) # Other Mitigation I Action Date Benefit Provide mit water before pumping or Leaving water 24,654 AF (1-6 above) in the 7 Provide � io in e- of dg .^.n.,igrt ^^ advance- before impacts are realized in stream 2012 on aquifer or stream prior to impacts benefits creating impacts flow. fish habitat, equals 17yrs of pumping Up to 912 AF of water savings will improve 8 Juniper Thinning on Thornburgh and Thin Juniper trees on 1,000 of acres of 2024-2039 (soil moisture, planting and groundwater BLM Land Redmond BLM and Thornburgh Lands. recharge Clear Juniper in cooperation with Clear and remove 1,050 acres of 210 AF of water savings will improve soil 9 Crooked River Watershed Council Juniper in Crooked River Watershed �029-2038 moisture, planting, groundwater recharge Fund $5,000 for nitrogen study in Determine cause of Nitrogen levels in river 10 Fund CRWC Nitrogen study cooperation with the CRWC 2024 to create options to reduce nitrogen in order to improve fish habitat. '...Crooked River restoration &riparian Will provide over $400,000 for riparian Will improve fish habitat throughout it it improvements w/CRWC restoration action in the lower &restora 2024-2033 miles ofthe IowerCrooked River. Crooked River 12 DRC mitigation Credits Provided 6 AF of DRC mitigation credits 2103 on Provides 6 AF of stream flow 10. Other Issues and Comments. There were numerous other comments and issues raised. Applicant has created a chart included as Exhibit A that is incorporated into this decision. 14- PDX\ I35849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument Ultimately, we find that Thornburgh's 2022 FWMP meets the No Net Loss Standard. We find that the measures identified in the 2022 FWMP are reasonably likely to succeed. Gould v. Deschutes County, 233 Or App 623, 227 Pad 758 (2010).10 K. Adequate water will be available for all proposed uses at the destination resort, based upon the water study and a proposed water conservation plan. Water use will not reduce the availability of water in the water impact areas identified in the water study considering existing uses and potential development previously approved in the affected area. Water sources shall not include any perched water table. Water shall only be taken from the regional aquifer. Where a perched water table is pierced to access the regional aquifer, the well must be sealed off from the perched water table. Opponents argue that Thornburgh has no water right, that G-17036 has expired or is no longer valid, or that water is otherwise unavailable such that the current Application must be denied. The Board finds that this issue was settled by approval of the FMP. The Board also finds that compliance with DCC 18.113.070(K) was settled by the CMP and is addressed by FMP Condition 10 which is not implicated in a review of the FWMP. Furthermore, CMP Condition 37 (now met) required that the applicant "demonstrate compliance with DCC 18.113.070(D) by submitting a wildlife mitigation plan to the County as part of its application for Final master plan review." This makes it clear that the No Net Loss Standard and not DCC 18.113.070(K) apply to our review of the Resort's wildlife plans. This criterion is interpreted to relate only to consumptive water to be used and the Deschutes Basin Groundwater mitigation required by OWRD. The plain text of the criterion makes this clear. It uses language such as "all proposed uses at the destination resort" and "existing uses and potential development previously approved in the affected area" and describes where water can be appropriated from. Nothing in this criterion relates to the fish or wildlife habitat mitigation measures required to meet the No Net Loss Standard. This interpretation is consistent with that which has been routinely adopted by LUBA and the Courts. For example, see Gould v. Deschutes County, 322 Or App 11 (2022) (Gould OLO. In a well -reasoned opinion, the Court of Appeals, again, firmly rejected the argument presented by opponents that Thornburgh had no water available to it for consumptive use by the Resort. The Court said: "We address each of petitioner's challenges in turn, conclude that LUBA did not err, and therefore affirm. Petitioner's arguments in her first assignment of error turn on LUBA's interpretations of both FMP Conditions 10 and 38, which we review as a matter of law. As noted, several of those interpretative issues have been decided in previous LUBA orders that have been affirmed on judicial review and that we therefore do not consider here. Beck v. Tillamook, 313 Ore. 148, 153, 831 P2d 678 (1992) (A 10 This is especially true because the ultimate backstop for the plan is to not pump water and thereby have no impact. No mitigation is required if no water use or pumping occurs. 15- PDX\ 135849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument party is not entitled to relitigate issues that have been resolved on review of previous phases of the same land use litigation). LUBA has previously held, in orders that we have affirmed without opinion, that the requirements of FMP Condition 10 were satisfied by the documentation provided by Thornburgh, including documentation of the continued existence of Permit G-17036 and mitigation data. Gould VIII; Gould Golf. Thus, we decline to consider petitioner's contention in her first assignment that Thornburgh has failed to show that it holds a valid water permit or that it has not presented sufficient data on mitigation. And we decline to consider petitioner's argument, resolved in previous litigation, that FMP Condition 10 requires proof, at this stage, of the availability of actual water behind Thornburgh's water right. Thus, all of petitioner's arguments relating to FMP Condition 10 have previously been rejected and we reject them here. Most of petitioner's arguments in her first assignment of error relating to FMP Condition 38 have also been previously addressed and rejected by LUBA in earlier orders. Petitioner's primary argument is that the requirement in FMP Condition 38 that Thornburgh "abide by" "the April 2008 Wildlife Mitigation Plan, the August 2008 Supplement, and agreements with the BLM and ODFW for management of off -site mitigation efforts" means that petitioner must prove, at every approval stage, that it has fulfilled those requirements, which are set forth in the FWMP. LUBA noted in its order that "the plain meaning of 'abide by' is 'to act or behave in accordance with or obedience to (as a rule or promise) * * *: conform to.' Webster's Third New Intl Dictionary (unabridged ed 2002). The opposite of'conform to' is'deviate from."' (Omission LUBA's.) LUBA agreed with petitioner's contention that the requirement that Thornburgh abide by the requirements of the FWMP at every stage means that it must comply with the FWMP at every stage. But LUBA noted that it has held, in an order that we have affirmed without opinion on judicial review, Gould VIII, that neither the FWMP nor FMP Condition 38 requires pre -development mitigation, and that the requirement to "abide by" the FWMP in FMP Condition 38 is satisfied by the reports filed by Thornburgh that address the requirements of the FWMP. As interpreted by the county and affirmed by LUBA, compliance with FMP Condition 38 is measured by annual reporting filed after water use has begun. We are satisfied that, in light of the requirements of the FWMP, with which FMP Condition 38 requires compliance and which imposes no requirement for pre - development mitigation, LUBA's interpretation of FMP Condition 38 is correct as a matter of law. We therefore reject that portion of petitioner's first assignment of error." Gould v. Deschutes County, 322 Or. App. 11, 23-24, 518 P.3d 978 (2022)(Gould OLO. Further, as in other County decisions approving Thornburgh development approvals, Thornburgh again provided evidence that G-17036 is a valid and non -cancelled permit. The Board finds that this criterion, if relevant, is met. Opponents misconstrue the County's previous approval of the CMP and FMP; nothing in either approval requires Thornburgh to utilize a specific permit or application for consumptive water use. The CMP contains no findings of fact that rely upon any specific water permit. 16- PDX\ 135849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argutent Instead, the CMP contains general findings that the source of water for Resort uses would be ground water drawn from wells on the Thornburgh property. The "source" of the groundwater is not, as claimed by opponents, a specific OWRD water right permit which authorizes pumping from the source, the regional aquifer. This is easily demonstrated by a review of the CMP Document, CU-05-20 that is included in this record. These findings include for instance: Under DCC 18.113.070(K) ("adequate water will be available...") o p. 79: "The source of water for the project is ground water from the regional aquifer of the Deschutes Basin." t I o p. 83: Under "Source of water": "In comments submitted in response to the BOP and rebuttal materials, Gould contends that Applicant failed to explain in sufficient detail where it is to obtain water for this development. The Board finds Applicant has shown that water for the project will be provided by ground water, to be pumped from wells that will be constructed on the project property." Deschutes County has never made findings that Thornburgh is bound to a single application to serve for consumptive water; it has consistently determined that water for Resort use purposes is ground water — a finding that remains unchanged. To the extent opponents argue that Condition 10 required a specific water right we reject that contention. Nothing in the CMP or FMP decision so noted or required. And, even if opponents were to be correct, nothing prevents the County from processing or approving an amendment that would change it. The same is true with regards to other destination resorts in Deschutes County. For example, the approval of Pronghorn Resort (now Juniper Reserve) identified multiple potential sources of water. It changed its water supply without being required to modify its CMP or FMP. Similarly, Eagle Crest (as recently as last year) was permitted to add additional wells and well capacity not specifically authorized by its CMP or FMP without modifying its CMP or FMP. Deschutes County declines to require Thornburgh to meet a higher standard related to water availability. The Board finds that so long as the Resort can show, consistent with FMP Condition 10, that a groundwater right remains in a valid and non -cancelled status that may serve the Resort that this criterion is not violated and FMP Condition 10 is satisfied. Having addressed the substantive arguments found in DCC Title 18 we now address the procedural arguments. B. Procedural Arguments Throughout the proceedings below and before the Board, several parties including Appellant Gould made several procedural claims or arguments that must be addressed. "Void CMP" Argument I On the same page, the BOCC also interpreted DCC 18.113.070(K). That interpretation stands. 17- P D X\ 13 5 849\262760\J KKA\3 621093 5.1 DRAFT: For C'onsidera.tion as Applicant's Final Legal Argument Opponents claim that LUBA held in Central Land and Cattle Co. v. Deschutes County, 74 Or LUBA 326 (2016) land use decision ("LUBA FMP 2016 Decision") that the Thornburgh conceptual master plan or "CMP" is void. In reality, LUBA held that the FMP "has effectively incorporated and displaced the CMP approval." LUBA FMP 2016 Decision at 346. LUBA did not find that the CMP is void. Furthermore, as is detailed in that case, the County's hearings officer rejected Appellant Gould's argument in that case that the CMP was void and LUBA affirmed that decision. Therefore, this argument is an impermissible collateral attack on the resolution of this issue by the LUBA FMP 2016 Decision. It is also settled and binding under Gould v. Deschutes County, Or LUBA (LUBA No. 2022-013, June 1, 2022), aff'd 322 Or App 11, 23 (2022) (explaining a party may not relitigate issues resolved in previous phases of development), rev den, _ Or _ (S069882). Opponents go on to claim that the CMP is void because Thornburgh failed to seek and the County failed to hold a hearing on remand in Gould v. Deschutes County, 72 Or LUBA 258 (2015) within the statutory timeline under ORS 215.435. This issue is an impermissible collateral attack on LUBA's finding that the CMP has been incorporated into the FMP. Furthermore, the provision of ORS 215.435 that terminates an application if a review on remand is not requested within 180 days of the final resolution of judicial review was not effective until after LUBA issued its remand decision. This law may not be applied retroactively because to do so would prejudice the Applicant in that case by voiding that application. Furthermore, the case in question did not find that the CMP is void and that was not its legal effect. LUBA approved the FMP thereafter finding that it incorporated the CMP and that decision is final. The Board finds that Thornburgh's CMP is not void. Moreover, the Board notes that the CMP required creation of a FWMP to meet the No Net Loss Standard at FMP approval stage, not during CMP review. Therefore, the CMP is not implicated or altered by this Application; there is no change to the CMP and findings from the CMP are altered. 2. Interaction between the CMP and FMP There is some confusion regarding the County's resort application process and the relation, if any, between a CMP and FMP. Opponents to the Application argue that the CMP and FMP are not one document and the Hearings Officer found that the CMP and the FMP are two separate documents. The Applicant has stated they are one document. We find that the issue is largely irrelevant because the FMP "incorporated and displaced" the CMP, as stated by LUBA. We agree with the Applicant that they are both a part of a single document — one part being the CMP and the other being the FMP. As outlined in DCC Chapter 18.113, a destination resort is subject to a three -stage approval process. After a CMP is approved, a more refined FMP must be approved. Finally, each phase receives final approval, which is much more specific, at the individual site plan or tentative plan stage. Up and until a third -stage application, fluidity in a resort's plan is warranted and provided for in the Code and in the Board's 2006 decision approving the CMP.. 18- PDX\ 135849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument For example, DCC 18.113.090 requires general locations and descriptions to be included in the FMP. DCC 18.113.1OO.A then requires the FMP to be adjudged against the CMP criteria and standards. Once a FMP is approved, third -stage development applications may be made and compliance is adjudged against the FMP. DCC 18.113.040.C. The purpose and relevancy of the CMP now, is for context related to a modification of the FMP approval. The hearings officer erred in finding that modifying the FMP may, in this case, require modification of the first -phase CMP document. Here, no change to the CMP is required. The final version of Thornburgh's CMP included Condition 37. It replaced CMP Condition 28, which was rejected by the Oregon Court of Appeals. CMP Condition 37 required the applicant to demonstrate compliance with DCC 18.113.070(D)(no net loss/degradation) by filing a wildlife mitigation plan as a part of its application seeking approval of the FMP. It also required that a public hearing be held with the same participatory rights allowed for approval of the CMP. While CMP Condition 37 applied to the review of the Resort's initial FWMP during the review of the FMP, it also applies to any changes made to the FMP that involve revisions to the FWMP. The Applicant has complied with CMP Condition 37 by seeking the required public review for an amendment of the FWMP part of the FMP. Furthermore, no finding in the CMP considers, relies on or addresses any of the provision of the 2008 FWMP so no change of the CMP is required in order to approve changes to the FWMP. This interpretation of our Code and the Thornburgh CMP and FMP decisions is consistent with previous decisions by LUBA and the courts. LUBA previously found that "[a]ll requirements of the CMP approval are now requirements of the county's FMP approval. The FMP approval has effectively incorporated and displaced the CMP approval." Central Land and Cattle Co., v. Deschutes County, 74 Or LUBA 326, 346 (2016). Emphasis added. This makes sense given that third -stage development applications are no longer required to find compliance with the CMP and are instead reviewed for compliance with the FMP which incorporates CMP requirements. DCC 18.113.040. Substantial Change — Code and Conditions Opponents argue that the Application seeks a substantial change to the approved CMP and FMP and that such a change requires a new application or a consideration of substantive criteria other than DCC 18.113.070(K), including all criteria related to the original CMP approval. These arguments are largely based upon the term "substantial change" as it is used in various provisions of the Code or specific conditions. While the hearings officer attempted to harmonize these requirements, the decision below was at times conflicting. We take this opportunity to clarify and interpret our code as it relates to "substantial changes" in the context of this Application. a) DCC 18.113.080 Opponents have argued that the Application is a "substantial change" as that term is used in DCC 18.113.080 and so the Application must be reviewed against all criterion related to CMP approval. They argue that the Application's proposed reduction in water use and or deletion of an 19- P DX\ 13 5 849\262760U KKA\3 621093 5.1 DRAFT: For Consideration as Applicant's Final Legal Argument optional golf course changes/alters the "type, scale, location, phasing or other characteristic of the proposed development." The Board disagrees. DCC 18.113.080 states: "Any substantial change, as determined by the Planning Director, proposed to an approved CMP shall be reviewed in the same manner as the original CMP. An insubstantial change may be approved by the Planning Director. Substantial change to an approved CMP, as used in DCC 18.113.080, means an alteration in the type, scale, location, phasing or other characteristic of the proposed development such that findings of fact on which the original approval was based would be materially affected." As noted below by the Applicant and by the Tribe in comments filed with the Board, the CMP and FMP do not commit the Applicant to using all of the water authorized by approval of the FMP or to develop more than one golf course. Consequently, a commitment not to use all allowed water, or to not build a golf course that was optional and not required, does not alter the scale of the Resort in any way such that findings of fact of the original CMP approval would be materially affected. Only one golf course is required and the other two are optional. This means that the third golf course that the Applicant has agreed not to build is not required to be built, even if the impacts of this potential golf course were identified, studied and mitigated. Choosing not to construct it is not a substantial change given that it was not required in the first instance. As a result, the Board finds that limitations on water use and golf course development are not a Subgtantial change to the approved CMP, The hearings officer correctly determined that the DCC 18.113.080 definition of "substantial change" has a second requirement (in addition to the "alteration" requirement addressed above). That is, the hearings officer is correct that Applicant's proposal to modify the CMP/FMP water usage or elimination of an optional golf course are not "substantial changes" under DCC 18.113.080 because the changes would not require an alteration of the findings of the original approval. However, we disagree with the hearings officer interpretation of the Code in that the hearings officer determined that changing mitigation from the 2008 FWMP to the 2022 FWMP is changing a characteristic of the proposed development. We agree with the Applicant that the changes in the source of mitigation water from the 2008 FWMP to the 2022 FWMP is merely a change to a plan that mitigates for the impacts of the proposed development. It does not change the proposed development or the characteristics of it beyond placing a greater restriction on the maximum amount of water used and the number of optional golf courses that may be developed. Approval of the proposed amendment does not require any change in the findings of the CMP as none address the provisions of the 2008 FWMP. Further, the hearings officer's determination that an amendment to the FWMP would materially affect the findings of compliance with the No Net Loss Standard in the FMP because it modifies mitigation measures and so is a DCC 18.113.080 "substantial change," is incorrect. DCC 18.113.080 asks whether a proposed change to an "approved CMP" is a substantial change. The 20 - PDX\ 135849\262760\JKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument approved CMP is the CMP approved by the Board in DC Document No. 2006-151 as modified by DC Document No. 2008-51. No finding of the approved CMP addresses the particulars of the 2008 FWMP. Instead, Condition 37 of the approved CMP requires the filing and public review of an FWMP with the FMP application. The requested modification of the FWMP has been reviewed in the manner required by Condition 37 of the approved CMP, which is through a land use application review. Opponents have also argued that DCC 18.113.080's requirement that any substantial change "be reviewed in the same manner as the original CMP" requires an entirely new CMP. That is not the case. The Code merely requires that a substantial change be reviewed "in the same manner" as the original CMP, which is to say that it proceed through land use review in the same way as the original CMP in that case. Even though the Board finds that no substantial change is proposed here, the land use review has afforded the same process provided during the original CMP, which was review before a hearings officer and then the Board of Commissioners. The Board finds that the Application does not need to meet all criteria related to CMP approval and, as already discussed herein, the CMP is not implicated by the Application. The Board further finds that the Application does not represent a substantial change as that term is used in DCC 18.113.080. b) CMP and FMP Condition 1 — New Application & Substantial Change Opponents argue that CMP and FMP Condition 1 are relevant and that they require a new resort application. These conditions are identical and are addressed herein as "FMP Condition L" FMP Condition 1 provides that "approval is based upon the submitted plan. Any substantial change to the approved plan will require a new application." The Board disagrees with opponents that a "new application" means a new CMP or new FMP. The reference to a "new application" means a new land use application and land use review, which has occurred here. It does not mean a new CMP or FMP application. This is the most reasonable interpretation of this language as the condition uses a term, "substantial change," defined by and assigned consequences by the Resort code. There is nothing in the text of Condition 1 to suggest that a different and more stringent rule is being applied by the CMP and FMP decisions. Applying an interpretation that is different than the Code would effectively repeal the relevant Code criteria regarding substantial change. The CMP originally imposed Condition 1, which states that "Approval is based upon the submitted plan. Any substantial change to the approved plan will require a new application." Upon FMP approval, the hearings officer carried through the condition to ensure compliance with the original CMP. The condition means the same in both contexts, and neither require that an application for a new CMP or new FMP be sought, only that a modification application be filed and then reviewed in the same manner as the original approval. This interpretation is consistent with the Board's previous findings in Thornburgh's CMP decision in 2006. In our 2006 Decision, the Board determined that the substantial change of converting Phase A Overnight Lodging Units to single-family homes would require "a modification of this conceptual master plan" — not approval of a new CMP. DC Document 21- PDX\135849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument 2006-151, p. 46. This finding is contained in the same decision that created Condition 1. If a new CMP were required to make a substantial change such as this to the CMP, Condition 1 would surely have said so. Additionally, Condition 1 does not say that a substantial change renders the approved CMP or FMP void. It only requires a "new application" which the BOCC's CMP findings indicate is an application for modification of the conceptual plan. With regards to whether the Application is a Condition 1 "substantial change," the hearings officer determined that LUBA had held in a previous modification that the application of DCC 18.113.080's "substantial change" definition to define the meaning of FMP Condition 1 was appropriate and so the Application is an FMP Condition 1 "substantial change" because he determined a DCC 18.113.080 "substantial change" was requested. As already noted above, the Board disagrees that the Application is a DCC 18.113.080 "substantial change" because it involves no change to the approved CMP. The Board agrees with the hearings officer that DCC 18.113.080 defines the meaning of "substantial change" in FMP Condition 1. The Board, however, finds that the Application is not a "substantial change" for the purpose of FMP Condition 1. As we determined earlier, it is not a change of CMP Condition 1. While FMP Condition 1 relates to the FMP that includes the 2008 FWMP, the 2022 FWMP will not modify or authorize additional development so it will not impose significant additional impacts on surrounding properties. It is not a "substantially new [destination resort] proposal." The 2008 FWMP is a discrete and minor part of the FMP that addresses one code criterion of many — DCC 18.113.070(D). It serves a narrow purpose of mitigating the impacts of resort development. It is not, itself, resort development or a plan for resort development. FMP Condition 1 was imposed to apply to the entire FMP and all supporting documents, not to a discrete singular mitigation plan. Instead, FMP Condition 38 was imposed for compliance with the FWMP, which is exactly what the Application seeks to modify. We agree with the hearings officer's findings of compliance with DCC 22. 22.36.040(C) that find that the FWMP is a minor part of the approved FMP. Changing this one element or part is not a substantially new destination resort proposal. We find that this is permitted and that such a modification is not a "substantial change" for the purposes of FMP Condition 1. Opponents argue that approval of the FMP and 2008 FWMP relied upon findings of fact that the Resort had obtained OWRD water right permit G-17036 and that that permit has since expired. We disagree that the FMP and FWMP relied upon that permit, and, that argument has been routinely rejected by appellate bodies. We have further addressed this issue above related to water availability and in Exhibit A. The record includes OWRD records that show that G-17036 remains "non -cancelled." LUBA and the Oregon Court of Appeals have affirmed County findings in approvals of Resort development that G-17036 has not expired. Gould v. Deschutes County, 322 Or App 11 (2022), rev den [CITE] ("Gould OLUU). The Oregon Court of Appeals has also found that "there is no requirement in the FWMP that the water rights and mitigation can only be satisfied through Permit G-17036." Gould OLU at p. 22, fn 7. LUBA has also found that "[i]n calling for `updated 22 - PDX\135849\262760\JKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument documentation for each phase of development, the text of FMP Condition 10 suggests that water sources and permits for the destination resort could potentially change following FMP approval." Gould v. Deschutes County, Or LUBA _ (Or LUBA No. 2021-066, p. 13). We agree with the Court of Appeals and LUBA. 4. DCC 18.113,100 and Modifications of FMPs Our Code specifically permits the modifications of any land use decision, including FMPs and, to the extent necessary, CMPs. DCC 18.113.100 makes it clear that any provision of an FMP, including an amended FMP, that is a substantial change from an approved CMP may be approved as a modification or amendment. And, contrary to the claims of the opponents, nothing in our Code requires that these processes happen in sequential fashion; they can occur in tandem and during the same application process, so long as the change is reviewed in the same manner as the original CMP. DCC 18.113.080. We interpret DCC 18.113.100 to permit modifications to an FMP and that if such a modification is a substantial change that it must (and may) also be approved at the same time as a modification to the underlying CMP. Harmonizing DCC 18.113.080, Condition 1, and Modifications of FMPs Both DCC 18.113.080 and FMP Condition 1 require a new application in the event of a substantial change of the CMP. FMP Condition 1 requires that the Application does not represent a substantial change and we make such a finding. We also find that, even if the Applicant had proposed a "substantial change" that the "new application" referred to in both rritorin nnly means a new land use application reviewed in the same manner as the original approval — it does not require a brand new proposal, merely an application to amend or modify the proposal. The review of the modified FWMP conducted by the County is the same review required for substantial modifications. Opponents also argue that modification necessarily implicates the CMP. While that may be the case in certain circumstances, that is not the case here. The CMP imposed CMP Condition 37, which says: "Applicant shall demonstrate compliance with DCC 18.113.070(D) by submitting a wildlife mitigation plan to the County as part of its application for Final master plan approval. The County shall consider the wildlife mitigation plan at a public hearing with the same participatory rights as those allowed in the CMP approval hearing." Therefore, while CMP Condition 37 may be the base against which changes are measured, we find that no substantial change to the CMP itself is required because the CMP does not contain the 2008 FWMP. Given that CMP Condition 37 imposes a requirement to review an FWMP through a public hearing, even if the CMP was implicated, we find that Thornburgh has complied with the requirement of CMP Condition 37 when seeking review of a modification of the FWMP because the Application was been reviewed through a public hearing process and the requirements of CMP Condition 37 have been met. Logically, this condition applies both to a modification of an FMP modification as well as to the initial plan. To read it as ineffective 23 - PDX\ 13 5849\262760V KKA\3 6210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument during the review of an FMP modification and instead give effect to former CMP Condition 27 which was replaced by CMP Condition 37, would remove the assurance of public review of the FWMP needed to assure that the CMP was a valid approval. It would also be a collaterally attack against the final decision. 6. DCC 22.36.040 — General Modification Criteria Our Code also imposes general modification criteria that apply to all land use applications that apply except to the extent that other more specific requirements, such as those provided in DCC Chapter 18.113, that authorize the approval of substantial modifications, apply. a) DCC 22.36.040 — "surrounding properties" Opponents argued that for the purpose of defining "surrounding properties" under DCC 22.36.040, "surrounding properties" is not just adjoining properties but includes substantially more lands including any land connected by river flows, irrigation wells, drinking water, or water as a whole. The Board disagrees and declines to make an application -specific definition or interpretation of the Code. The Board believes a more pragmatic approach, which interprets the Code as it may be applied to any modification request is both more prudent and plausible. To that end, we agree with the hearings officer, that "surrounding properties," as used in DCC 22. 36.040(C), literally means the real property ownerships that are directly adjacent to (surrounding) the Subject Property. Given the fact the Resort adjoins large tracts of land owned by governmental entities and one 80-acre property owned by a private owner, this is a reasonable imnnr.t area to use to assess the impact of changes if an application- specific definition of "surrounding area" were applied by the Board. Even assuming that "surrounding properties" includes the undefined broader area mentioned by opponents, the impacts of the modification of the FWMP in these areas is not "significant." Imposing a limit on the Resort's water use may, at best, offer a slight benefit to area properties beyond adjoining properties by having a lesser impact on groundwater wells than authorized by the FMP, but this is not a "significant additional impact." If the "surrounding properties" includes all streams and rivers benefitted by the mitigation plan and riverfront properties, the temperature and flow impacts of water transfers and mitigation is so low as to be immeasurable so is not a "significant additional impact." DCC 22.36.040(C). This is well documented by Thornburgh's expert technical reports, which we find to be credible and persuasive. The same is true for any water declines in the area that would be caused by pumping at Thornburgh. b) DCC 22.36.040.13 — "substantially new proposal" DCC 22.36.040.13 provides: "Unless otherwise specified in a particular zoning ordinance provision, the grounds for filing a modification shall be that a change of circumstances since the issuance of the approval makes it desirable to make changes to the proposal, as approved. A modification shall not be filed as a substitute for an appeal or to 24 - PDX\ 135849\262760UKKA\3621093 5.1 DRAFT: For Consideration as Applicant's Final Legal Argument apply for a substantially new proposal or one that would have significant additional impacts on surrounding properties." The Board finds that changes in circumstances exist such that it is desirable to make changes to the 2008 FWMP. Among others, this includes the robust technical analysis provided by Applicant's experts that the 2022 FWMP will result in increased stream flows and decreased stream temperatures. Opponents argue that the 2022 FWMP is a "substantially new proposal" which cannot be approved. We disagree. DCC 22.36.040.13 relates to whether the modification modifies the actual approved use, in this case, the Resort as a whole. It relates primarily to the approved FMP and, because the Application only proposes an updated FWMP without substantially changing the actual required development contemplated by the FMP, we cannot find the proposal to be a "substantially new proposal." We also agree with the Applicant that many elements of the 2022 FWMP remain the same as from the 2008 FWMP, including the purchase of Big Falls Ranch water rights and the TSID mitigation for Whychus Creek. The Application proposes no new infrastructure, housing units, or other actual development. The Application also proposes no "significant additional impacts on surrounding properties." Therefore, we find that the Application is permitted as a modification under DCC 22.36.040.B. c) DCC 22.36.040.0 — "discrete aspect" nCr ??'16 non "An application to modify an approval shall be directed to one or more discrete aspects of the approval, the modification of which would not amount to approval of a substantially new proposal or one that would have significant additional impacts on surrounding properties. Any proposed modification, as defined in DCC 22.36.040, shall be reviewed only under the criteria applicable to that particular aspect of the proposal. Proposals that would modify an approval in a scope greater than allowable as a modification shall be treated as an application for a new proposal." The modification proposal will not have "significant additional impacts on surrounding properties." It is not, based on findings for "surrounding properties" and DCC 22.36.040.B., a "substantially new proposal." Applicant's proposed modification of the use of water, elimination of one (of three) golf courses and changing the source of FWMP mitigation water are "discrete" aspects of the FMP approval. We find that the Application is not greater in scope than allowable as a modification. 7. Modification of Application During Review Arguments Both before the hearings officer and again before the Board, Appellant Gould and others argued that Thornburgh had modified its Application by submitting additional evidence in response to 25 - PDX\ 135849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument comments made or information requested by ODFW and others such that Thornburgh the 150- day clock should be restarted. These arguments generally related to the DCC 22.20.055 or procedural requirements of ORS 197.797. We have previously interpreted our modification Code when Appellant Gould raised the same arguments during review and approval of the CMP and we decline to reinterpret them here. These findings are included in the record and are found at page 89 of CU-05-20. In essence, a modification only may be found if the additional information requires the application of new criteria to the proposal, such that the findings of fact would require change. Thornburgh providing response or additional evidence to support its Application does not change the applicable criteria. As such, the Board finds that no modification occurred. Appellant Gould requested and was granted a de novo hearing before the Board on all issues. It is not error for an Applicant to submit additional response evidence during a de novo hearing of her appeal. ORS 197.797 has Not Been Violated Appellant Gould argues that the County has violated ORS 197.797 because it permitted the Applicant to submit additional evidence to support the Application during the public review process. We find this argument to be unpersuasive and contrary to the plain text of the statute. ORS 197.797(4)(a) requires that "All documents or evidence relied upon by the applicant shall be submitted to the Inc -al government and made available to the, public." Appellant Gould argued that by the Applicant putting in any supporting evidence including a revised FWMP document, this law is violated. This is not a correct reading of that law. All that law requires is that documents be available, which they clearly are given that Appellant Gould specifically commented or provided rebuttal argument and evidence related to them. ORS 197.797(4) does not prevent an applicant from submitting additional information or evidence, and, actually expressly permits additional evidence. ORS 197.797(4)(b).12 Furthermore, ORS 197.797(5)-(7) and (9) govern the receipt of evidence at and after the conclusion of a land use hearing and an initial land use hearing. None of these provisions prohibit an applicant from providing evidence at a land use hearing or during a post -hearing comment period. Additionally, ORS 1979.797(6)(c) says that "[a]ny participant" may request an opportunity to respond to new evidence filed during the post -hearing comment period; making it clear that an applicant is not prohibited from providing rebuttal evidence for consideration by the Board. Similarly, Appellant Gould's arguments that ORS 197.797(3) has been violated is without merit. That section only requires that the County to mail notice within 20-days of the hearing. The fact that Thornburgh has provided additional evidence to respond to Appellant Gould and others does not mean that the County has violated procedural requirements of the statute. To the extent Appellant Gould has argued that the inclusion of additional evidence or updates to the 2022 12 ORS 197.797(4) also likely does not apply to post -hearing record periods. Those periods are controlled by ORS 197.797(6). 26 - PDX\ 135849\262760UKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument FWMP makes it unrealistic for the public to understand the application under consideration, we find little merit in that argument. Thornburgh has clearly applied to modify the FMP by replacing the 2008 FWMP with the 2022 FWMP to meet the No Net Loss Standard and the mitigation measures proposed by that plan to meet the standard are those proposed by the initial Application with only minor adjustments made to address objections to the Application. Appellant Gould makes additional arguments before the Board that ORS 197.797(6) is violated. Again, we disagree. ORS 197.797(6) only applies to the initial evidentiary hearing and not to an appeal hearing before the Board. Even still, as discussed in response to Appellant Gould's objection during the rebuttal period, we find that Thornburgh providing additional technical evidence in response to evidence or comments made by Appellant Gould, ODFW, or any other participant is not a violation of ORS 197.797(6). 9. Rebuttal Objection Appellant Gould also argued, after the record was closed, that Thornburgh improperly provided testimony that it "should have or could have" submitted earlier. This argument is based upon her claim that the "structure of ORS 197.797(6) is to provide opponents the last word on evidence[.]" We disagree. Nothing in the statute provides project opponents with the ability to provide "the last word on evidence" and the statute specifically allows "any person" or "any participant" to submit new evidence during a post -hearing comment period. Moreover, by its terms, ORS 197.797(6) only applies to an initial evidentiary hearing and not to a de novo appeal hearing before the Board. The Board has reviewed the objection by Appellant Gould and filed on March 10, 2023, and the response provided by Thornburgh on March 13, 2023, and agree with Thornburgh. All evidence provided by Thornburgh is responsive to evidence, issues, or claims provided by opponents during the open record period. For those reasons, the Board denies Appellant Gould's request. C. Miscellaneous Argument and Arguments Outside of the Scope of the Proceeding Opponents have raised a number of issues that have no relevancy to the Application. We have generally addressed those in Exhibit A. Changes to Physical Layout Warrants Additional Modification Staff and opponents have questioned whether Thornburgh's plan to remove an optional golf course is a substantial "on the ground" change that warrants a broader modification of the Resort's CMP and FMP. We find that it does not. The scope of the Application relates only to the modification of the Resort's FWMP and our decision is generally limited to the scope of the present Application. The Application supports a reduction of water use by removing an optional golf course. Given that the golf course is optional, it is clear that the CMP and FMP approvals contemplated that changes in the number of golf courses might occur. It is worth noting that the Resort has already 27 - PDX\ 135849\262760\J KKA\3621093 5.1 DRAFT: For Consideration as Applicant's Final Legal Argument received various approvals including a golf course site plan, two tentative plans, and various site plans, that have already updated the physical layout of the Resort. Those decisions cannot be collaterally attacked during this proceeding or any proceeding in the future. Further, the Board finds that it is entirely appropriate to make reasonable revisions to the FMP layouts during third -stage review under DCC 18.113.040.C. The FMP approval criterion at DCC 18.113.090 are only meant to provide general, preliminary, or descriptions of later applications; they are not set in stone and unable to change. An FMP does not require legal descriptions or accurate surveying and monumenting, it is a general plan. That process is reserved for the requirements of individual site plans and tentative plans. The Board finds that DCC 18.113.040 and the three -stage application process specifically allows "on the ground changes" or updates but does not require that a CMP or FMP be modified for each change unless the specific impacts of the change proposed in a DCC 18.113.040.0 application would result in substantially different or substantially increased impacts to surrounding property owners. For context and illustration, this could mean moving a resort concert or event venue from one side of the resort to the other and next to a noise sensitive use that pose impacts not assessed during review of the CMP or FMP. 2. G-17036 is Required under Condition 38 and the 2008 FWMP Argument Opponents argue that the 2008 FWMP and the findings of fact related to FMP Condition 38 relied upon the specific impacts of G-17036 and the permit's mitigation sources to ensure the mitigation plan met the No Net Loss Standard. This argument has been made and rejected numerous times, incI ding at the Court of Appeals. Gould v. Deschutes County, 322 Or ADD 11, 22 fn 7 (2022) (Gould OLU). We agree with the Court's analysis, nothing in the previous 2008 FWMP or in the FMP requires use of G-17036 by the Resort, nor were findings of facts based upon it. The only findings regarding the source of consumptive water included in the FWMP are that water be appropriated from the Deschutes Basin regional aquifer. Regardless, we find that the No Net Loss Standard only requires a showing that specific measures ensure that the Resort's groundwater pumping will result in no net loss or degradation of wildlife habitat. This is detailed more above. Neither that standard nor the FMP nor the 2008 FWMP require use of a specific groundwater permit. Alleged Code Violations and Well Indemnity Agreement Opponents have argued that the Application cannot be approved due to alleged violations under DCC 22.20.015. We have previously interpreted that code provision (which is in this record) and decline to do so again. Under our previous interpretations, which have been upheld on appeal, we are not required to address alleged code violations during this proceeding unless the Subject Property has been adjudicated to have existing code violations. There are no adjudicated code violations. Further, these arguments are mostly based upon opponents' "void CMP" argument, which we have already addressed and rejected. Appellant Gould also argues that Thornburgh is in violation because the well indemnification agreements required by CMP Condition 11 were offered by a different and now inactive LLC. 28 - PDX\ 135849\262760\JKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument We disagree for three reasons. First, CMP Condition 11 required the "Applicant" of the Resort to provide such agreements. Deschutes County did not condition the CMP or FMP approvals to apply to any particular entity or to prohibit assignment of development rights by Thornburgh Resort Company, LLC to Central Land and Cattle Company, LLC. This issue was settled against Appellant Gould during the FMP litigation. See Central Land and Cattle Company, LLC v. Deschutes County, _ Or LUBA _ (LUBA No. 2015-107, September 23, 2006)(Cross Petition Issue Q. Thornburgh remains bound to provide the well agreements because Central Land and Cattle Company, LLC has assumed all development rights and obligations of Thornburgh Resort Company, LLC and because the resort approvals and their conditions run with the land and apply to development by any developer. Second, this issue has no bearing on whether the Resort meets the No Net Loss Standard, and so it is not a relevant approval criterion. Lastly, the issue is not ripe because Thornburgh has not begun pumping water for Resort uses. Therefore, compliance with the well indemnity requirements is not yet required and no violation of CMP Condition 11 has occurred.13 4. Housing Affordability and ORS 197.455 Opponents argue that approval of the Application will have negative impacts on housing affordability or that the Resort will not be able to pay employees enough, thereby exacerbating affordability issues. These arguments are in no way applicable to the Application and we decline to further address them. Appellant Gould argues that ORS 197.455 precludes Thornburgh from providing residential housing. This is simply incorrect and has been routinely rejected by LUBA and the Courts. See Gould v. Deschutes County, _ Or LUBA _ (LUBA No. 2022-011, June 16, 2022)(slip op 15- 17), aff'd without opinion, 311 Or App 383 (2022). Further, it has no bearing on the application at hand. 5. Claims of Streams or Wetlands on Subject Property and DSL Coordination Appellant Gould claims that streams exist on the Subject Property. That is simply not the case, as stated Hickman Williams & Associates. Further, Department of State Land ("DSL") staff advised planning staff that notice to DSL was not necessary because no wetlands or streams exist on the property. 6. Adequate Sewer Flow Appellant Gould and her technical expert Mr. Lambie argue that the Thornburgh must also update its Sewer System Master Plan. This argument is based upon Thornburgh's decision to not build an optional golf course. The Board finds that the Sewer Master Plan is not implicated by changes to the 2022 FWMP, nor does it supply applicable criteria for the review of this application. Nothing in the 2008 FWMP implicates the Sewer System Master Plan, either. 13 To the extent relevant to Appellant Gould's argument, the Board finds that CMP Condition 11 required a showing of "actual well interference as a result of Applicants [sic] water use." Actual well interference requires a finding of such by OWRD, who assisted in developing the well indemnification agreements. See CMP Condition 11. 29 - PDX\135849\262760AJKKA\36210935.1 DRAFT: For Consideration as Applicant's Final Legal Argument Additionally, the Sewer System Master Plan found that only 34.5 acres of land are needed in the south basin to apply treated effluent to. The south basin is the southern half of the Resort that received approval for two golf courses but where only one will be built. Based upon the size of the approved golf course and other open space and landscaped areas already approved by previous decisions, there is more than enough land to apply the effluent contemplated by the Sewer Master Plan. Thornburgh has also provided a technical response to this issue, which is persuasive. Thornburgh's sewer system is subject to approval to the Oregon Department of Environmental Quality ("DEQ"). That body is the correct body that approves construction drawings and requirements. This argument provides no basis for denial. 7. Adequate Water for Uses and Fire Flow Opponents argue that there is not sufficient water flow to ensure fire suppression for resort uses. This is not applicable criteria or relevant to whether or not the 2022 FWMP meets the No Net Loss Standard. Thornburgh has provided a technical response from Hickman Williams & Associates that refutes this argument, which is persuasive. The County's building official, Randy Scheid, also weighed in. He stated that specific fire flow requirements will are to be addressed during the building permit stage for any proposed structure or occupancy. It is also worth noting that the resort's Water System Master Plan14 found that: "After approval of the final master plan for the resort, the water distribution network will be modeled to determine the final locations of the reservoirs and to determine which zones will require booster pump station in order to maintain adequate pressure and flow for domestic and fire protection uses." Therefore, water and fire flow capacity and flow requirements are properly deferred until specific application of use consistent with the building official's statements and the Water System Master Plan. Opponents also argue that building without water places the County's population at risk. This argument is unrelated to the Applicant's request to modify the FWMP. Further, we find that the Applicant is not building without water — it has a valid and non -cancelled water right and has obtained approval of a temporary transfer of the Tree Farm Water right. Drought Conditions Warrant Denial of the Application Many commenters to the record note that Deschutes County remains in a drought. While that may be true, there is no legal authority for us to deny this Application on the basis of a drought. Thornburgh is required to show that the impact of its own water use does not create a net loss or 14 This further supports our finding that on the ground changes will occur at the third -stage development application stage under DCC 18.113.040.C. 30 - PDX\ 13 5849\262760UKKA\3621093 5.1 DRAFT: For Consideration as Applicant's Final Legal Argument degradation of wildlife habitat, independent of drought conditions. Importantly, Thornburgh has provided expert testimony that shows that even in drought conditions, the 2022 FWMP meets the No Net Loss Standard, which we find persuasive. Further, as a whole this Board generally agrees with many of the assertions made by Commissioner Chang in his recent February 27, 2023 guest column. Oregon land use law and the land use process provides limited tools to address drought. This is an issue that must be dealt with on a more system approach in collaboration with the largest water users in the basin. As noted in that column, current domestic use of water is only about 45,000 acre feet per year, as opposed to nearly 725,000 acre feet of irrigation use. Thornburgh's overall water use is not substantial in this greater context. Limiting its total water use to a maximum of 1,460 acre feet as required by the 2022 FWMP ensures that its impact will remain minimal. 9. Additional Crooked River Program and Juniper Thinning At the request of the Tribe, with consultation with the Crooked River Watershed Council ("CRWC"), Thornburgh designed an additional benefit package related to the Crooked River. Thornburgh also provided additional evidence that its juniper tree thinning would be beneficial to stream flows. While the Board is appreciative of both of these measures, the Board finds that these measures are additive and are not necessary nor relied upon to establish that the Application meet the No Net Loss Standard. That standard, as articulated above, is met by the 2022 FWMP and does not include the additive thinning or CRWC measures. Thornburgh expert Eilers and participant Tim DeBoot also provided comment that Thornburgh's existing juniper thinning efforts are likely to lead to water conservation of 300+ acre-feet of water. IV. Decision The Application is APPROVED. The 2008 FWMP is replaced in its entirety by the 2022 FWMP. IMP Condition 38 is modified per Thornburgh's request. IMP Condition 40 is imposed, as proposed by the Applicant, to ensure compliance with the 2022 FWMP. Conditions: Revised IMP Condition 38: "Thornburgh shall abide by the April 2008 Wildlife Mitigation Plan (excluding the April 21, 2008 FWMP addendum to that plan and its addenda), and all agreements with the BLM and ODFW for management of offsite mitigation efforts. Consistent with the plan, Thornburgh shall submit an annual report to the county detailing mitigation activities that have occurred over the previous year. 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N > a) a) w 'a -a -a p +' Q tUit m m C u. m O on � O C m t V) 3 v I--° m .O u Z .16 () E �c 0 kn Q. m m J J L L bn @ m m a) OC O p N +1 ' L a1 'a Q>L) Cm ' m a) 4z E fl_ O° a C U 'a E L O Q m CLp ai a 4p- N a) N L O U 4J C Z, m ++ O a) n V U G H 'bn 4 3 p O O .L +, :p c� bA ._ .� w Q n L 4' p `- p O L= ) = Q E m 3 N O 'aO> O C' m O -a a) ° 3a) E JW Q C CLn Q� a) n a) aJ u 'Q m> bA a) m CL L 3 3 p W 3 J ca c ai N U T Q Q ^ .v tan C ut O 0 bn ° Q Q Co L. U m C a) fU0 C U O W L.L Q m U u , cpi v •Q +a,) cNa v W U N o L > In C C C m L 3 E W cu L E -- cr Q s -0 a) Q O p O t m CC t 3 �- m ._ 0 m to +, ¢-0 0 U u Ln O v bA a c 0 C in O U N OU U1 -p O L O 0 L O � m m % Q C) Y L s Q w O U c UJ -p � ,� � Q c -O +N+ '�' Y O UJ -c aJ `� f0 �., O aJ m N aJ L U1 L �_ N UJ N s Lao .� N CL N L O. Y O U O O a QJ aJ = C }, aJ O 'c (0 O— L '^ aJ N ++ N O. 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X aj -c L° O 4- n V a) L= ( L= *' v a..� c O W s � ) —_ L O is a-� >` Ul a) c L ca LS E N 3 v f0 ._ E a! 7 o 4+ cu N a1 to +� L v 7= a-' Q 'O • V � ++ o'n >- 4, O O +� -c- 7 •u CL Q Q- -0 2 m ca cca O E 3 U vY- .� U s-0 v m C o c v , = ns `a O- m E A i 3 a, a O '`'.' L L v � M a� t aJ Q a.+ Or ��L ON r z U +L+ u a; °J =� bA i Ou ._ _v C ~ V N `- N a1 .� C L G >% m ?> 3 a1 4- O Q L w a1 c a) V c O "° Ln aJ U! N +c 4� oN + 0 .G c Q- 'a a E ° �' +' n - 0_ .� ;° CL `^ ° .N a, °1 Y � c o a`, y -a c� a E 0 +� 'v E m v +� v� �, 3 CL a' 3 °� +� v, 0 o O Q mu p o 0— c Q o 3 o ° E E— c n c m Q u- ° E r Z c M- s� n 4 J m L v, ,� e•1 e--I t u u Ci C CC G > J a) N a) a) O C Q O () V) O nNi ° c N v a oN >, v 3 > t Ln Y >- +' c a1 f0 L bn c O O Ln t -C Ln a., n aJ u h O w v, ca i fa 0 a- � 'o (a M ° Q 4-1 ate. - L1 Y 0 ate+ ra •(a c m aJ y O = bD 0 .E O u L 4' a- "a �„ Cr E a L N ++ m v c Q- CL a c a, 3 ^ 0 c n o v c a +a a, v- L V =_ a1 N C ro O. aJ ° 5 3 u a, c p m U E a ' O> a, v c 7 c o " c o Q a, 3 c o 0 0 a a .� Q 0 Z m cca v ICT LA O a> 04 fa d c O C 'tn O U Q V a -O Q L f0 L o m co ° O C Q v n L LE a w O U C � s E ns in a an 4-1c n = a -� a @ a +' on V) O L t 3 o cN0 o ;� M a c `� m a = N '`�' vU, �6 3 L cab to bA T +' U ai -a 'O U- c •-^ a = v m V c (O a; -O O +, U a O N U U L LL 'a _� m N M a O U � E n a s ti v T c .v L7 a 4@ N O 3 +J N U 00 N 3 'O X O v) 4a � a a L O N u ) 3 a O cb vNi N> O bn to N a O L L a s ate- O 4- O O Cr a O N U C.to 4-1 � ate•+ 41 N O n— N m N a (O a+ t ac -a 3 o-0 p_ v a' F- v 3° 1 Q- ° u a +1 ° 3 o a C m a o `o > n m a= u M c L a a - 3 a a L 3 L a +, O o T a •`-" c v a ba ns L- 3 a a a o L N E _ +� V) ate' o� +� a at a c to 0 -0m a; ° to _ ~ v o-a 0 a., ra Y o -a n E> r � „m = nbn ( a L v O :a vN ca O'a ' -a m 3 v> o vu c an i3 �, aj O E U O N Q >- E c Oa � m v> E o -OY E a Laj -0m - ai -- 0J a O j >- 0 psLL CO ' v�p Y a > O N o c o ++ O 0 .U;+ N a 4- E 0 ur- ° c o° a aio 4- a o 0Mcc n'c c +' o v° L. •O Y u N c n a a a a- E +� c = O ( A p= a 0 M= Q- LP 4� ai• ° , s E EL x0 a L aL4-1 c -0 � a.P a o +, +,�a U Zn E Y En 3L +� a 00 = aa-0 ++ s a a N - V a Vte U +d a O E E N O a L+- o - a M v O ++ a a .Q 00 N a + O 'O a N N E O° Eo m = ` _ m 0a+-oU> LE +,a c O E ja3 c * E a a a O`_ LL to 4 o O a)v0te 6>a- Na a a p a VL 3vO M 4, N°+ O 6 O O >U a ava', cr + - vLl- E V > ++ iV 4 I O a a +, O T L > a ++ ° ro N U O=> m a O@ }' v- p 4-1 3-0 Q a in LO s a a ca a O vai p ns = u N ON U p " +� a "i c N +' a— a a > V +J u> a>. G c ns c m a a `n O a 3 o aEi vai ai 4 o v° o v v c s> o a c v) +� +• 3 3 s ° f 6 ° `° 3 u o E b +1 a +� a M O c a O> > a .= v, U-= O Q o a � Q FL- O s= a L L bn bn CO J m m J 00 Qn �1 Y O �' Q O O a a a U 0 O 0r a N 4L 4' ° as E a 0 3 > ca a o E a > ° @ U 7 ++ (UN v as W a N U 0 � u ate•+ a N M � a L L.L ? 3 j W. ate+ > o -a � `v 41 Q ai = +� a = o �, a �. o� E �n c p 3 3 3 -a a Q) 0 3 O y a m +' cap ,n in 3 vi T c O in 4� o0 a p -O m= a' L c Qro�� ._ O +� 3 L-. - U !6 3 L O- co o C:' LL 3 bn Q a > cu aE a3 00 oO Q'> a E E °U o O 0 r1i 0 R* Ln 0 00 a bn n3 n. _ O o_ oV a1 •'O 0 L 0 L ° m m m° o O •- ¢ v 4� L n w o U C a) O a) Ln a) O N N ti L ¢ L a) ++ C _ai E ° 3 v ° LC�Ii v v o ,} L 3 L '2 _ L C= w p L C = p i- L L T O aL••+ > O a) '�0 ��' L .r ccL >� G N > Vf ° �p '� N '� N W N 4- U' f6 O cu a) O *' N> -0 4— = a) a) m� O m ai L p O} , i a1 N V N w L Q p V7 4! v� bm W N 0 a1 = C L N L �, +1 n O L t"'i N O N_ u M> >O OL i O a O f \1 > +' ° Lpp -i = N O a"'' L, n. p a) L dA = 4 + L v ro 3 4- O O = +J U L 6 ++ Q) nz Cn 30 Q) v 3 cLo @ U aj a'3 ° CL Q- 3= M W o m m v E °J 3 M L N L L Ul O a-• Q Q W - 4L M .Q @ ` 'p > +., O O° al N v Lo � O r, p V a) O O L 5 on c° x o= a) 3 = aZ 4• OL.O a) f0 O C a) = a) L r' 3 O (0 Oaj a) O— O U p ;G O.^ '�"' C L p a) L a; p , p a) 0 -0 L +•� 3 a) U p i i WAD O f6 0 > W = (6 F-• ° T '� y U U u V) `� M 3 +J L a) L` a) 'a 4p L M Q O rZ 6 _ o c t 0 of ii m v o 3° v a°, 3 E N c o m o �, — O. u v -a — v OD v w 41 a W W T 3 c N o a o = '0 a aa)) '6 v E 3 u v �, v o o '0 ° N= L° E E ° ..= ~ L p p L Q a) (6 a to a) s a) O = 3 a1 of O Q N a) a) co Cn 3 u m '� c v p Y 3 c N o m v v '> +, a v� o '.T•+ °_ N v E ai N U N W +1 ° = com 1.. �` L �n aI co Ln �' aJ � cv o aJ 3 E ,E v f0 o OD s L N � m � � !n � N 3 L O � •ate' u=n au' T � ,a� 3 Y @ � ¢ .� o = L � 3 � ai aJ L � v L G c� V E m —__ N ON _ 3 p a L ° o ca o O� E v� O 6 N Ln M j L1 v + O°_ o 0 ° > _ a 00 o L; a) o o v s O ° `° �a 3= L +L -0 = T¢ W L o o ®°c v Q .� A< o c: 3 v an �; Q n 3 3° v a) E I ,+_' `� N (30 . O VO a ra = -C U E E N = L = ZO O 6 a) L = E° N v ° L w 7 n= u to bLA cC 4, ca -p L v nz n3 o T L co aL, +, -0 o W ro 3 aJ = Q O tea c a) > rt a) � a) 4, u c 3° O +J +� 4+ ° ;G v n °) o Lv 0_ Q a �° c¢ 2 3_ v a, m •ono o aa) v ° L >, +.+ O a L a) �_ Q �6 > ° E •Fu T >T O L @ _� N U_ E '- v U -p L L T ++ +1 CO Q n, �° ° ohm v => -0=.-� 3 Lhn �•N N � u � _ E0 a om� cm 41 N� L h IUO O J L LL iC J aO+ ° L +J L L.L .b, p �-+ N +J = ` = c O O c 41 N p a) 0 C CU a) m 3 N t L M a) O 4) O L t 4 v ° o ns + _ a a� a o u 0 ca h- f— u +i L u H +, o c hn N a) !6 E r-I �--I M VH E to 0 L i L i N L i O 'n E Ln CL J o bn Jp- = J v \ L a)N L > L N 4A E _O J LL Gn U- do m u 0 z.Su 0 OmJ OJ C m¢ N O�-•� 3 a) p L .y 0 a) _ y bn U o -p a) O -0 m L) M s N > L +J ON O aa)) •m N M _ •- ro co ra co •N W L L Q oCU v v Q. � 3 = 3° m 3 x = ,V) ai m N ° E O °) O LO p >� v i, 0 Q) p m= 0 a p O L c .Q CL + N W > m > 0 0 0 V) N O Q- O.. O u O u > -p = _ _= m= 0 a) Z m¢ it L L Ln Ln 0 M a) to co a L L aJ N Y 4- aj N •= aJ O d y L _ N >.3 O +.+ ono °J t U-v 3 (U :EU- — P w o ai N cLco Lnn v m v N o o aQj � = U w o __ o a, — o aJ s v t +, ++ -C +, ++ a+ m O N v Y O Q OU OL 'O -0 U Q 0 :G E Okn -0N 6= �� aJ C• O = U 0 N N = L E(� O L L 4— O aajj C N O fU0 =" Q aJ .0 � 0 E s O a-T+ �' -0 T � > a 4- >_ ++ 3� dA — N a _� 7 aJ O• LE v O aJ -a ai 3 N +J caJ n E O N O O 4' M— � M Q 4- U n3 O. O > uC0 .Q Q ++ 3 = N L O _ = v +J L L Q 'O aJ vi N a- CCm 0+5.+ � aJ aJ s dA N cL6 ro aj L CL v0- co ` N a�,1 N 7 c-O G Q O y aQJ u uL- d ON 0 o o 0 W c, �L aaJ aJ .Q Q N = CLL M M W U F, m 0>0 a O U � _O� O= aJ Oa O u- O U L a U a 4.> Q �aO 0 " O N bA C E 4- 0 NN Ln aJ E aJ n � pEa v O ai n tw O N ° =+O >MLL cc _ °O 'p O o aJ > O o � aj u aj 4. • N = 3 s aJ v L aJ aJ in LE `+- UA d -p Q � ++ � N � � N `-' O E -C M +.+ O G .O aJ vi u 4-1 aJ = E+ C 3 Y cC aJ +J >_ n bL0 a T N O E E L t 3 v _ cr o u Q �' a s >° U > N E cu Q) m +� n a LL w m> v v° c Q+�, -6 N 3= v 3 a E 3 Q C m N LJ O N- d C v J 0 i1 OA qp Q- N aJ M o N > -a GJ aJ i 0 L ON LJ O aJ dA _n O >, +1 0 l6 -_ 0 :'= = 4 L f6 O v L F- O N X aj aJ O = ~ tA v '�'' v�i ,>_ O 0 > -u (n N c LL av+ O � v O = L1 p- N +N.� aJ �. O C c0 V = O LL Z Q. E .0 aJ v tp aLJ Lj O O +' Ln O = vi aJ "6 to OO 0 M C +'NNN.+ Q N O +N+ O m +a+J ` 72 Ev Q o 3� 3 LL ai c O `E� JQ tio cu > Ln4- - ? aJ M -� a E� ro 6aJ O aaL= aj aJ LaL ate = M aJ -a cr C i O L++ - Qj L'+aL.+ >3>aN� a >4 s >v Lai N O tT� > O•p 1-r-aroJOa) aJ O -OC1 r `° N LL > o -G aJ L T rn c �LL `'w o `F Q icLL3n0 N h0 c aJ in aJ aJ +••� 4, *co „ O O O a O . LL n a) O U O� N v �aL3 = -0 c O M=� +,> � � NV V o UNN N j Cm L cL d"i a @ O 4- •aON+ ErN 1 E , > aJ m O_ E O L E U = O NL O Z cL i� a O (a U O +.f-n +., N f c-I > J i O fO U (6 ra L � L f0 m LL �+ m m O J N N > 4- aJ T O N 4� a) (6 = N L N _ 0 v E s tin ns a- fl 4- O 4 _ 4� �aJCU > m aJ O +�- _ Q > OL + > 4+ v O E ❑ O N _ L aJ ++ 3 Y = Q aJ � L c T L L N �•�� a, E Y a�J ns L LL3 c to ns 3 a p a, o > O m v v° s v aEJ o O U-a - CL C c vOi .� Q o En Ln O O ri on m a aJ aJ v aJ c O aJ v- aJ H O -0 v >- N C � {- aJ N L f6 �- CU ° +� t�6 a aJ ° !6 L — E U n M � — t Q N f6 t' aJ 4-1 (6 -a C O 4-. n3 ° L x aJ c6 C Q m c f6 aJ 4J +� C O .0 -0 '� aJ 3 ° S a' Q 3 i (D UJ �+ Q E +,M p CU N O L" O -a O 4-1 0 a) Q t C� v6n +_ +� L ra o> • 3 v° o a v c m •� +� O aJ 6 Ln n3 = O E 3 t6 '� Q O O +' C D l6 aJ aJ L L rL6 -0 v aJ w _ a-+ ^ N = 4 3 Q t uEL >c cca CU � 4aL o s=(A o u tE +' Q O 76 _ � o o Q °J 'a C a,at u Q c E o + aJ 3 Us aJ OY O O c aJ a aQ ENLL +, DO QLa 00 CL aJ E ` E ` x E t =-0 E o ° a A u , V3° O o E O CL oNvO YO> N v -aJ 4aO+, =M mx 'a E u� O aa -a v°0 , v 4 a o '�CN 4� a y :Q ut c > ai U—E C> ma m (6 N O fl L O E bbD aJ U 3 C c6 O i aJ aJ C U N E aJ 3 bD Q -0 3 c O O c6 c Q E °' `° ++ c a aJ t6 o v 3 0 T_ L N = w , •� c = l6 a, 'a +' LJ aJ _ m O O = L Q N v U Q 3 v. N ai n3 L CO m .� s� Q �— 0 in 3 s6A aJ -a a 6J - aJ V) ,= Mn 3 N LJ U Q O CL _ aJ L L O 4- z Z. a) aJ Lf +� U c6 Q > H 6A i 4O '� Y E of � m m m +�+ O @ Q ?�. N u C 41 T 3 .Q i C ++ ,C O (L6 N +, .A ,= C U C vi O � -O 3 r }' C aJ m aJ mC N 3 Q Ln L aJ Q O 7A O c -0 L u Q 4� 4. bo �+ '° m ..0 'a X a) (n O i, c6 f6 LM ° of V v = U L U vi Qc. Q = dQ aJ Q .L aJ •bO a) L -a N = to = L t6 +� N (AVf +_' 0 aJ O (6 3 W>G Q s- +~ m E c aJ -a +- ++ -a O N Q O 4-1 Q of Q aJ = E aJ O aJ =° N a' a, Q 3 O > +� ° 0 � u° C 3 O v - -0 � P1 v E v bA G N c N 3 +�+ L .� Q 3 ° v -0 _ = v c - �O 3 a, LL o ai O= m v 4- 'G +, o > O _ aJ vi 'O Q O N aJ ate, � m U_ Q 'O L 3 of N ni LV, .0 o ocn Q- t c a c v —_ � c `° O v axi v v E o— aani E N i- o N M w 0 c6 3 n3 V, E �, — a, +, 4-1 4� Y O C Q n r`c Ln O N E y aJ a .`, m Q> C (6 L .0 V V t v- L ° L LQ _ V) i-+ 3 u� v +� n• w � = •U Q Q aJ m V Q= aJ a Q) Q v+'i c O O o 3 V v_ c 3 aJ +J U s cca .�' c °c C E o° o aJ = 'E 3 aJ a s a .T O 4- 3 aci "a _ u�-0 a, v m " 0 v Q v 3 aJ Q v N v i, o 'A O w l -a �' m �j �-0c wav(SF-+ f6 o�v�a�. i O vt V) L-C -0E-E-LLmmm L C — C ��3o r-I r-1 a-i ri u L Ci C ccL G CCL G cc C 0 0 v 0� 0� O O O °i ai O v C V) nn i 4�L. V 4- O N aJ v OD v O V) 3 U L o 0 m 4� c- ._ 'E aJ V) u N� = o V) V1 v 3 aJ L y- o o n 3cu -a -0 -0 v a--O 3 L O _ 4= L 3 > �_° . �' L f6 w0 E> E v t6 v E c6 N +� C o o Q 0 Ln "a 3 r 41 3 H v M N C U L u O 3m +n co E O _ C 01 CL U° N+ = 3 Q 4- aJ Q Q aJ ,y C ^o 'N aJ iJ o o o c .E L u p cy Q cu n° w ° N 3 oo M -a t o E .41 6cn . aa) 3 Q E L = L a) Q ro V C O •L = VI +.+ m +,� U� +,Ln 0 Ln E V) m O Zr- O O O '^ Ln Q a! 3 V) n 3 tom- Q 3 0 v tin w v) u 2 a- E v O c O c 'in o 'u N QU a) -p Q L 0 L o !6 m CO 0 o •— Q +� a L a w O U C — E n= ° a) ate+ o cca o M a v o c> a v c aco 3 a u O ocn v '� v o v o o a' v p -0 O 4-1 `6 ° v= x `~ a o° E c u ` a) a nz ~ u a) o '� Z LL a, �� a) aJ npn ate) O_ " - -a cca acr ) O `� O O 3 Q O o L C a a, a) s +' 3 a o ti N a ate) M v M o a, cu t a) a>, f v v \ c N 3 (L6 C O U, N V) a U N a) > p U �� a) L a, oo s rl N > M T O r--4 o 0 3 O L v E a) '> c O LL a) o aci m a c 4-1 Q m a) O i+ O M `° y t N O a O Ov Q Y O N bn o c c CL a) r c c 3 3 obn a ._, v v E "a CU 'X c �- + M a c (O L +�+ o 3 ca � +� a, c a) to a) ° 4 � p i ,a; O v to U O u — o n3 N y O@ E� v a a) M a a c a 3 c `M f° -0 c u a 3 3 c � t QbuO � Q) o O Cu CU p d U' m OA + U O— n3 v p O ao V sO n-0V, c a nU M o Q EE} c n vcn, O -O a) M aa = ) O LL L a O U N 3 on ao 3 t N v c n~ 1 v M `� M a v� �� uN 'o v w f° m tin c +' 3— .N 3 LL B° °Q o o � u 3 ns a) o a c c a ai O M M a) v_i ° i a v 1 LL c O MQj Q L •o v° 9; a a, o a u Q v nn 'N +° c a') on a°Jo E bA T c v a) Ln O Q— CA 3 c c O O I O o� v •� � 'O W c M 6 c v u �, c an c t v +� O 0 v, c o c `� _ Q Q v a o v u c c -a M c a) Z3 o C O V1 v p c M U v 0 N t a-' 2 'a Li- O C v� -O c o v c y `n O N N � a) N — U' O vi ,V aJ a) X L) ++ a1 bbD •L O -p � c - O '�'' -O 3 a) al -O V M w L ca �n U vi an lL0 L `6 .p cn 'x M m aJ W M 3 ,� O to o ,� .c 00 in a) V > p ti s u t v° *' u c _� LLon o men �a c a) c a, m ca L L v, M 3 a) 3 v a c Q) — c O p i a) .� a) Q ca � `C° - v 3 f @ -0 c O t 1 ' � Z •f6 E Q) c L M a '� o v � On p +� a) c0 14 3 N :e 7 L O ++ E� N w O n o o O y o .v c o f CO a. '� Q c co c° U- ou 0 ) H° H .= H Q u`a v ° ° O i' vO i Q U f° Q cca c I t-i On L t i i f0 M a G CM G = L 2 J L J \ L MV (0 (0 w O ate) 0-j co m m c v c p vi — O Q M pp - U ul M t M'�, M +, M m Z v U m° O a o E ++ a, f0 N F OC 'a M Ln O a1 > LAf— C T 4! E �O > Orq > v M a CC N C y 'p 4- y N a) Q- '> N y 3 i a) M E U '> a E NO 3 c c E 6 co v o Z CU aj c ai o Z Y a OO N a) • c )v 3 ° o > E 0 O' v cM LL o �, v .�+�o � ; u u � ° 0 o p av o vuoQ c O c v, o Z v, ) U a) -p Q L -0 N L O � m CO - c o Q v 4� � L s Q w p U c > t = c c bcA u N V, fb a) m O s 7 f6 N cu h i O v, v m N a) ++ O L `° O c N O -c Q a) bA a) 41 x s m J v v o c bn v a, C c ++ L (b N +•o M yL+•+ =,Z a) c .Q o aU -a i N s v r,E>- a cu a) �O m L�OO E On L Q ai �o + Oro +•' N U O ) >Q U O 'O O '>+ } a) E p ) OL O (6 O c s c L L 41 Q. � E � (n � � o v °) a) E v 1. c a) p c s g a)GJ E s a`a, v V Q s- O p > c s v N tm?: "+'+ " O a ON LL a) ") N O U.-' .�c cN m E ai 0iN EO —4 w c uby-0ua)v a) (6 0 (b I 3 c Q (O z Z N c O o a) s N 3 L Q Q c a, ._ M O O W 0> a, a, 3 °' ~ c c 00o v bQj cn ON 0- >;-G E O O O 4 bA 4-a O= v ba U 'a pL m c N Q a) O cco pL v L f6 ,, u a+ O m �Q E � bo 0 a) U Zi aJ E cu L Q) � CU Q U) aN) N O L a U Q O ++ 4- O i L v bA L E a) a) o s to cr L O -c bA '- 4- -6 O O c L N L O O -p L M O > v cb v c +- a m ._^ O c m c 'O '> N a) +� �^ ca c M s s a) L U- v a j o N o v 0 m� o N v Ln o c - v +� v `� a" Q E L p u o 0 L, s aai E a c, U- o -a s .�, N 3 G' o v 'co L a; ra o �L a) m -a }, `� -O Q U > 3 o a) E -a v +, ,., Ln a a>c N O c tb +,, ,�, aJ t C7 a) O- m m O +_ s +�+ a) U> O o f i-+ cu c o .E E •r- 3 a m¢ c v N c `L c> N E a) l7 N s m E p L -c E O a-+ ;° O O i Q) c m w O N> Q :G ® U 7 c ,C a) L a) m s N l6 Q) to a) > N a) a"' N> c L O H m +, U J Q Q O U N= L1 ~ s N c f0 > o U Cos o c = a) X Q U --•i ++ u o0 0- a c O p rt M +' s° a, m 5 a > N a) O M ++ "L'S 'O N N a) ++ ; c a1 N r a) c N w p N 7 o ccb bcn = c E o p c c N 3 c c U 4° Lo ai G O o °) c c O d .c N +' V .N a) O no .c Q > ° s O N > to c ra a) c c Q@ a) -� s O m Q c N U 7 c a) O +, c s c a) oc � Q v a) U a) 7 t O a) s 3 a) E > Q J s> a) s c_, ^ t�A t 7 Q T 0_0 c s O a) O 4- U s I- o L > a) O v I- IL L }+ V1 L U Cr cr N N M N s s s .Q E ci G ci G LL Ci G LL LL J m M >Li- L V (6 co m� ( E N .Q E _Q E m ro L nz L 0 a) L L (a t L M m m L m m O J m CO J m J J m -p L >, cb L O p c co N v O c c 'co +, m 3 E +� n L a) L >. rr a) +_ -p N +•' 4+ > O O fD c u M a) c +, O Vi L O ++ u > �b ,,� c a) Q +' r +, c O c O >, O cma Q O c6 c N Z E N E O Y E p Q" ` �b E T- c c bn bA E v+'-, n J �0 V f6 N +J c o f `�_ L c L a, °M° c a) m a) N G: D b4 a O- ,C o M Q +' c E E 0) 0--o E °J L V u° +J bA o v c c oc N W a, E .Q o °-' a) O a) a) c c ' O N W U l6 m a Cl } u L �' p a) E O Q t p f6 c c Q= H +. 4- c ,, c t6 fb O E c c O O a) N4� -O = .,a.; a)O v cc ba Q E U ba O N = 0 a a' O v Q O E OL } U `v c LL �' ? @tm .N �^ (u Ea 'f 6 tY6 ' E lfl p QU' `M' +N+ u v O a, ° ^ Q c •� Q > a) `� 0 ,i 4a� v fL6 > m +_+ c c L O 4. rl `� H u ns v CL bA N C) a, c u bA E Co o E o° w o: o v> cu Z m af i "O 'F E 'ro > v E cusan v �- V) Q {n N_ V Q J U U Q o i _ V U LL a) F N 0 _ Rr Ln 4- O M bD ro a C O _ 'N O 'v U Q L 0 L ° �m m o +, a v +� L °0_ W O U C a) > s 4) a) � N a) aJ O V a) ro a) a = N +- t140 O = is ° s Q) � 41 ON O N Q)+, = CW = a _ _ Q 4' O L _ +o G Q E a ++ m o o aJ p ° a) aNi T s = ' N t m Y � °' = n ° o CL ate') = 3 - 0 +,Ln (o 4, Q L +.+ 4-1 T W a) _ � N ,1-+ _ '= LL N N � Ncu a) aJ aixv N a) = T in 3 "v o ao C • i a >. (, 'O L i fl N Q a41 aN N a) m. = o oQv = N v o o p O fn o °; o a, O N '° O a, ot° to oA o 0 a p O •> u N !6 N a) Ud O p La v . �' -0 U+. a) o i '-P >.O O a L H � a) a) U N a) C =a X4-1 U w -_ _ aj v O Y V L1 L1 M�� +�+ _ a) ca s N n (La O a) a= N O a) N (O a) .(., 0- N ++ dA O O = _ U LL H L N ( ~ ai +� �•, p = Q a C O -p '� (n -p L1 �+ 1— aJ L LO N -° �, N >LJ +L•, O W LJ Q1 CT a) N 41 _ -6 bn N i N E W s -0v p bD a) ca c s a) > Q 3 p L L (^_I T- ai N N s a) _ ( N 0 +�' = _ ~ = i) T 4-1 0 4� a p N U O _ v- M Q) 0 = QJ Q) _ `^. Q% _ > a) O Q = y -0 m O cli ° � i Y O L1 = v O Q 0 a) O N C) >` � -0 - U a) O v -0 Q Q O +� O � <o U dA O ro L L ^� 3 ° 3 � L N N .@ a y, N S� o a +, L ° — a) Q m Y N o s E a) v Q °= - Q 0 +ro OU N> a E O> L in u o u s -= f- 3= O N N s a) v- H 0 o a) t a) L nu N 4+ N -C N -C N N -= N -= N L-0 L -0 L .p L-0 L-0 i -0 LL. LL LL i.i_ O LL LL L a) L a) L T L Q) E L a) L a) E E E co E Q to m E f E (3 m J n3 m J m J CO J J m J m J N a) L -a a) E a) `' N ai fa Q to a) _ i- O U- , N +, E -0 L L N N o 0 3 a; T U L = 3 E U m (U L a) L s N 0 �C > " Q L' � U U U a) T ro L co (n � L= 3 E +•+ N ° c O .� m y v p c=o 3a E UO � `L° u 3 >°L 4� u _ ro = w U o ° a� ° O 3 en ° L ° E O (o aU+ N > p Q L N io O __ 0_ fc E Q � > co Co , n a) O 4, LM 7 L to E 6 U L .� ° T Q L u- a) N i° E u a � m °) v Lo 3 N a o w ? 4� v @ n ° a' -o a) �r 4-' � W 4- N U tin :'G 3 ° o cu U O co N 3 = C -0 p a) 3 p N s a ° 0 > m Y v m E m 'L _ +fa •I-j U O o s =-0 n �e E C o U Q L a v C N o �' u _v = L '>o ,G (� L E Q) .= fo � .� aa)) O L Z Q 0 41 0 O L Z O. �— U J {— t U 0 O a) J cr C 0 c 'v, o V oV v -o Q L 0 L O m CIO O 41 Q v L Q w 0 U C O v) -6 'n E o �; m L cr- - O O N aJ L a a, v 'an v � a .p l7 ^ a v ar > N Ln 4 0 3 ; m a) Q t C O O N 7 n3 C 0 N +' Ln O `ti L O .0 Ln a, L G in Qj N vi a1 O O � �1 0 i L C +, O =0 i N >` m aJ °1c oN E `" 3 3 o v tea, u 3 '� o tea, o v U- v y a a, N V1 i a) i -O a`, o v M Vf s �0) a Ln L Z QJ L =— a, in + L c o v o + f6 s v Q w v � o C 3 p 3 +j' E v dJ aJ t a1 O Ln V)�° .a a a Ln N n ++ M -o '''' +� +� M� C L L � o y t y 3 L O a (� O tin C L -C aJ a O N CD o t Lau "6 C m I CG, O 0 U a) M W � N c � m O U O o 4 .Z O N�} a°10 (n aJ — m f6 a n 41 = " 'i.'i p O a) UrL' N VI -L L a 4Ln r i- (6 C � In N � L ai Y ai � Q H a) aJ O a-+ +�y.+ QLJ �• \ i a) 3 41 U C -r _ C .O ? M E O U N v Q (L6 ,� a 3 N aJ s O L > ' U V) > t O (II a) ' i^ p m O ° O O o a1 N L L QJ +.+ 0 O O 4 •1 + ° C L J L O 0 0 a 0 >j O CC (6 m 0 c� Y vm ca p N ._ -� aJ s C �,L 3 o ca 3 �..i .= L �, t r, +� ". _ L Z� a., O 0 o p Q w a> is +, C 0 O in v 'A W Q v M v O o 1 v C do O w 4- -- In aJ 1-0 3 O ai r- a 4 L O m cy O 'to U, T co V�1 '^ c� O ' Op L a, a N L Ln -0 O o O N o t O . O Ln 'O a1 Q1 41 H O � � u� a) in C � -.p �- on ,n p a) fl. ca m, w o vi E c U c Yp G v +v, � N v n3 0 t -°p m N °' o ° - , ° a' � a n 0C oLn a E>U n -o E �, R L Ln .N o 'u a v a, O a 3 0 0- 3 al' O 'n m E O (u ° v N o O °r nz aJ v Q O a1 O U v� v� L L, n M V U t M ns z M a) X w a W 0 vOi a `- 3 E ti n C a1 p �� .� aJ i .� i O °n' y c o> + a.., p = vi J � t 4 O 41 r1 O^ W a t N C O 0- 0- v� 3 t ai v n +''�'� ;° c` s N > — L � �_ �-+ cn -Q n� �-+ do g, .,. O •� G 7 w vOi a-° `ti O O .�^ C aJ _ L vi O O a1 O O •- a1 uj v m N Ln •� v C �O•+ ca C� > 'G C ao c O O a �, a) 4 +� Ln l9 +' o -a s a, 3 H x = ra n3 Ln Q N 0 O-0 a, Ln CL a = 3 L 0 0 O -� -a U U Y M 0 L C CU U °' J °' N 'a _� �' }_mil �' v Q�) •N •a) 4-1 c.7 0 C Lw 75 (B E a) v �, C• p 3 + -o ° a O a, °u -^ +� 0 E D v E 0 0 cm E a n �' a z ~ �' n v 3 3 0 '� CJ U '�n F- U ro .-i rl L -C CL C CCL G � a) cu F- O °; O m E E v a) a) a)N o a E Y a, C o L v U S > L L o o C 3 E m E U 0 m> L Q -C U a) u f° C O L Q m C M 3 V � O- N C L ai C N" ha +' i 3 u c aj @ a v -a u� .� o cu mM 4 tO v C p E 2 w n cr LE�° oC M 3 bn u n f 6 �' c Ll m M '� cu N Ln p J a1 -O -� +"' E o N O O Q E O U J O 4E U "C U A 4+ +� +0 0 O E `' O tin C Lnh 0 0 m V = O Q CCU N s a1 N O w av o= 3vao �� o° o o='v a m 0 0a Ev Eui�� 3 °1 v.E a .E a Ln 0 Ln ei GA ns a _ O o U � 0 U v -p Q L 0 L O m m o s 4 Q 0) +� ca L a w O U _ V) _^ O _ cE o N +' _ o a, ) O W o � oo I -a u = o N +, E N v E ,-i -01 �, v C w > cu _ O ELL = v -a a, _ o o u a, a u ai Q LL ° E ° ai '� �, u lZ a X a C tu0 CU - L E o a U L 0 N 0Xi N a i• ai aj _ •H a~i v� s t 3— t 3 o v LIP a ai v 3 m °- E _ E N 3 3 ai v on 3 �, 'a o> v o 4' o _ O ° m o 'w am_ ~+ ,E m c 'a c m .L m CL L c p L a-+ _ +m L �n 01 m 4- a O aJ — u 0 v rS3o wIn lD > L M O C > rD = ° 'T O E O O dA ca O O U N r+Oa O� Q O O a) _ C C � V C$ �+ 'Q 3 0 o f Q o 0 °� aJ v •J'••' M> r=a CU l7 E a n r a Z t:� v O Q 0 W M a G C m °�L° v CL f° -°Ja O O �a o 3 2 CL - °1 u ° E V` = tw C > _ '^ 4� n o w �6 'a m 42 m m Q. i C7 CL Y ° aJ aa)i "a O O E O Q ° ❑m pp a O p Qj =_ N�_, L a o nn s E Q OOi.+ aLO O i .LV -0 W J ,1O a) v ° ° W E LOa M c 0C w•4v°+ 4-1 Ln a .—j a) Ec=a� toW a4 v o o o o v O a ; -°+53 p c a _ u;oa-0 o o w a w w 0 0 a'O v E � _3 Em L O 4J m , a= U °M 4+ � = LnM =3 4, M oa, aiai 4-10 m _ O O -O O OO °m O ryiLL J to, = N '� a -a> OO a ra -O Ln LL N G a) O w H r>o Qr a1 cc— w °�° m w E a� 3= o 0 O j, m a i- u aJ O E Q OL L = -a aU C Ln u= v +� a H t +� o= p v +° CL 3 rc Qj u a)-u a) 6 -0 U O O O� 2 u N w - d u�� O o avJ _ E o a! a ^H 0 = 2)0mL aj o a) -0 mf L LE N N!EO 6 v H m>-0 aj LLw_ a a O N4' p•, H aJ o ++ - cu a "O f- LS O m O _= Q w ra I—aJ Z 1C L J ri L LL � b0 on 0 N i m ra O L rSO m m Q) L O > > O on m bA m O 0 CL m m u uu ca O = O m ° ° 3 _ _ ro of ra m a! ( to = aJ ;� u a E O V) Y v Z L o 0 ra a m o a - U i= � ° O •1-- aJ = O a d= u O u L p; u= m O m +�� a) 3 °� Ln m QJ U O 4N O= u (d i kUi Q V L O m = M 0 (a Y CU 0 v L a L C >> Q ca E M+ = L (U a a L ao O N v m W p o O p .= p Z o 3 L 0 (D a s I— v a u 3 � _ Ln nn R' Ln O w W m a c O C 'V) O U � 0 V a) Q 0 L 0 L O m CO ° O Q vGi +� c = L a W O U C L O n t 4� c aJ -Q v o c t ++ v- V) -a -1 L O Q N t Ln C b!J N (A m a)t6 c �'cu N 7 Ln L N 0 aJ aJ N �„ > Ou M p N o) co m @ 3 - u C 0 _0 aiN t0 C � E a) 0A m .Ca) 4• N 7 t.+ +' N "a C to N +, N O buO E p !6 O a) p� x N to a) m Q (O a) +•+ i L +' C> M C a) U L c� }r a) � c bn >, n. M i a) c u_ m t H aJ E 41 O NCU 3 N L Q ) cN > J a i m Q . � . CL m� c 3 m� aaii -0 N E N 0A ) > U � )+1 OC +' pc° p G Q E E cu cta) LaO Wc QQ N N v p C � L C O-0 o on v M L N N +' aJ N 7 .? aN) LJ 4C 4= I j N to aJ N O +' tD � � -a O W v Y ,c t v tIA E V aJ N M >` c m a)Y bA >` cr to j +' 0A O 'O -Q E M N O aJ 4� +, C +, U N ('J � E a O 4N o c0 3 t6 'E Ccu -Q v L +' ++ 4. s a) 0A > p N aa)i +' Q N N 4, o +Qj O C L N L C co C N N C p L m n C `� a C Q o° O p m Q _u a- a) +•+ aJ N E ,� u N O C a) f° N° 0 t o f c O N W tIA c C N l>0 �• CIA - o L •— _L 0 wJ .a) o 4-1v CU c p acA m- o a) +� a) c 3 t3 Q -Q N (0 LJ N cu .x O = a) a aa0) •� M \ N +"C., LA fD oLn N C ° N p c c a o +, c a) N 3 L Q Q +� — w o v —_ L O — ++ C _ - C O E 4-1 L aJ aJ c _p .�.� aJ i a W EA v1 N N w > C i r' v -0 C c m � N p (B a 4� c .p c 0 ti O N u ^ 6 ^ U 'c 0 ai 0 _^ N c ,v a 0LA v o 3 aJ .G ' aJ to 'o Q u L t M " O. L O t :}cJ r E t O t a) -C N a1 n H +� m H ca i— L L L L SL > t6 �°y L G G y G L Q L LL-O Li-Q Q ) u C t>>�i a a) aJ �a) Q E w O cc O O O O N ° m tLa _ .-i N O >, aJ M N Z-P N t Q tts a, N t0 O a) 4N a) -0 m '6 L aO+ H aJ U N@ N M c N +� a) a) rya U — c U O U ra `+- -c aJ ++ N N C o.vcmai N �o_v� aJ EUL��cv N>� ac3 E ' '6 W c U O to iZ to �- .c O t' a) Q p Y aJ � t6 cl CIA -0 O aJ +� .p E N a) Q -Q L �- ra `) •L tt) 40 N m m J .0 CIA c ai O 'c ° E O a) aJ c O O@ aJ aO+ U cu c V1 c m L � c> W@, a a) L aj -p E L Q cu ° 3 > .y N to a C C > to C F- Q R UA U — c O c E m N u p -o v `) o f 6 N N c *" 3 a- p u v m N E p v" c o v ra N -° a; +� Q" o `c° u L o Q o O' to N N U >� t0 i- Q r_ Q a Ocu L Q L C Z +•i m a) N 3 Q c c '� c° v u ° 3 a E N a aci •LUl o N C v L c E 'E - c "—' aJ 3 3 '�, 0 u Q- v > '*°, 0 L �= L O 'N p +- a) rB u OCL > v N�� a) O O a) O +' 0 c 4v Z C 'C -0 ++ a) Q o O u L c-I a) V N C t C o U u C F a fO 3 a) L c m a) aJ p V > tc a) +J c E a) ° W 7 0 O C > QOop O_ twv a a)p> O La) M l7 O N UN@ E u N u N L v A 00 M 7C-0 a+ M A C U C U N W N N Ln O N rl aJ UA n3 a c O O o'v Q -Q p L 0 0 L ° m m O a_ U Y Q 0 L :EQ w O U _ U 4- Y LC_A a) b.0 'O L.L+ Q O ai Q Inv� 2 p O 4- N mO L L s (O �` L Q = U QJ T = Y -0 4- N Q Y _ = v'kn °Uo '0 Q a E m > a a=)sp 0))�� a) ,,`- O = = — U U C< .Q -0 • 'O CL Q L f6 !6 O N m .0 ° p Q O .E Y Q cQ- C S Y -C �O Q Ln in Y a) Q ° i' C cu N a" U- O •Ln : 3 N d0 >- to 00 Q Q YO Y 'Q Q O -p � s �•• C C-a Q lD Q L U Q p U 3 3 .N _Q Y W O Y -p = N (n O V as O O O s O Ln v, N U- Q Q as Q_ E E 3 +-' >' N � Y to i° Y 0 Q a)= ca m T> Q E?= n N a; c L; U � c, Q �, O06T aRi T Y E 3� E a- sa m � Li-O o ra O = o 'n_ = m = Q Z t Nm OO H `+- U N Ya o m N o = 3 �n o> ° °- yN a) > 3 v •� cu o°> N L c a°) as Ln O L vi -0 Q Q a) � Q L O a) L �` a) Y 3 U > O � LL (� +' Q > O _ m x U -0 fl_ Y Y �M L z Y _ w e = p L Q fl- C YO O "_ L `� Q to a) = m M y L CA = i m rp Q T Q > Q p 'O = Q Q Q -_ -0 Y Q ate-+ O 1 O O Y T ri 41 N O O= 'N o� � a n� °° 3 0 3 v 0 0 0 ti v c .M v MU U a) > Y m ° = Q- 'p -0 m Y Q ?' L as o> Q L -acm O O Q 3 v s f0 N O O Q Y (6 x +� = M ca .�., Q O Q O 3 y O +Q) -p O a) Q Q V 3 v f0 >, to swo ,y °; ° = w L p C7 a o v " ° N m 3 ° v s ° 'E + -0 -° Qc 3 In C y- (LO (n Y E . V L a)) ai T ..Q " p � _ •� I� Y C > N C s N c 06 Q C -° m C O O OU > vi L °= . N = Y i� Q ate•+ O Q = . �' u Q U N i .x n3 O = Q ® u Y s @ . 3 U o ( Q -0 � ns Q a) _ m o N aQ, oo Q C)) _a Y .ai E 'O - .Q Q .� U cQc 4) V7 QC a) .> �; = Q Q Q a s O s .L Q L Fn CQC 3 Y aO Q = Q Y s Y In = C t Y C = 3 Y L U •L un VI ai 0 C M U Y f0 T Q a) Q Y Ln Q Lns = L� Vf = V1 C 0)N .In >+ O Q Q O CL Q Q p n 7 O O L Q o a rr Q -o u m > eu i y cL0 M Q hA Q U 'L b0 _ _ ul 1l Q N M V1 L Y O M 1 v- �n Q m_= > Z -a N vi S }, Y (n -Q Y p Y Q i v r O Y Y Q Y _ 4O '�•+ VI M s Y `n Q � O 3 3 = •� T= Q O O Q = N � J c O o T = m -0 -0 `n -Q M Y Q (6 = � � � s a— ° = Y � O � 3 � Q Q p L � Q� o2S E__ ° Q Q= O .`-' Q Y +, O Y v c Q "a 'n OU Q M O O E 0 L —_ N L O ,� m Ln o Q � ..0 p° O s 0 H O O Q m L U in Q Q O C C Q p= O O> U Q s O Y 3 In m U Q ,n c > Q ra Q M = cn .G In s Q L s O> .--i m V% F" L In .� Y Y H i-1 ri r-1 i i i i a 0 #' p p #'. p 1" O O °; O O J = Y a) T N oA V) 7 .G N Q O N ° = Q 4T = @ 'Q Q '6 Q _ �^ •� = T V1 = n V1 O � — c >' O l0 n E O Y = " m f6 4-1Q f0 L 0)Q a) a) d0 4-1m Q p -O to to a)O c 'Q �, Y cn > Se •- c� t+ N U ai C L Y p Q > N a) Q n O 6 Q c- ro '6 Q 4- = 4-1= M 3 Y a) Q > � CL Q Y Q !O Q > o m "c 0 0-0 'p Q .= ,N f6 c Z3 Q Q LbJi t- Y f6 s N L Q O4-1 L _C 7 Q L ° Q Q OL O Q Q > c Q a) U L ° O Q J . U- O in 'a _ VIuo =O > -0° 0 U L4-1 3 0 O 11' � 3 m H YE Q°� N o o �, O• �, v 0 m u° ¢ v Ln O 00 l" m a a _ E N C a C +� U a a0 > -6 a 3 to U t Q +o a' > O a E' o V) -° Q°° t' LL s +� CL 0t 'i o a Q C CL •N 'O i CL C a CL 0 asi L O_ m 0N QCU 4-1 U v- a O 3 'N = CL a O L •� n'1 -Q °U a C t a L N a s@ a a o 0 0 0 c a b°n (n 3 LC_ CU C Q O "a = in L.= .Q O L U Q {3/1 a O tA ° o ° O >. > a a- L.L � .ai 4- Cr X a c > O o U C O. U o }o Q L°=i s +1 OD Q o a; CL c E E av°v ° � ° a on COa 4 QC O +' O +'+'u M a 0> v = M n C= = Qj a) O aaOm +' t o +,a O a > _ O a Q tO +' +' LM LnL a a U v — •= a u >. C4 �' a v O O 'n m > O a O 3 a 3 af6i -a `G cc '' a=i = o m a' c n bn ° :4= o g Ln4- CL -a v a a>i >, a _� 3 (� (n `O O Ln = fO E� � bn O a a -� bn a L' t- a a >- N 3 +' m E m s c => E a Q ° a +' (n c m u .N W ;= M'A `° .0 � v H °c o a m aci 0 t c v a ._ E m O- (U >m Ln _� c U 'U O CL ++ m G u U-t' O E U ai U ca E O° _� C � a Q a > a -0 x 0 U >Q a X 4-1 L = (n v a n N >O a U O_ = vi a of 0 a U +' a C -Q 4-1 'in L a a bD c=a L � Q-0 a c6 a L m L u O i"I N L +' a L �% c Ln t' C a N N 'Q o (fin = M a O t s Q a L p 0 N -6 a U ,0 m C 0 Lr U\ >, � ++ C J U m Y m U a U .0 CJ N _O (n a -p -a a ° LL •> .N m L `^ ,`-^ L ami o a (b O aUi - .a H +� m E a a a m O ° c a aa) a L v� E 3 -p b°n c �' aon v u- v - L QJ Q. OD (n o N B `� 41 bn = L bD U a L" "O C •, n a.' aan C = a c •_ bn v v '� c" 3 3 c 3 .= g a= a� @ == v= 0 ((n M (n +' n m -a a a a >- = �� O ° 3 'O •�' U +' p i t +� c U E U E C _ L n Q m O O O a s + s a_0 a = m +' O 3 ° m O a o a 4, _ v a CL v' U U m C a O u c `� O c 3 H L O c '' O C 4- a i U '6 T fL6 -p F N ±' O O ++ 4� a bA U ca V 'N CO N y a a N L>° v O bA >O U C 7 0 7 vi Ln a a E U c a N �- U � O N t +' � 'n 6� (n L , m c 4-- Q. CL ° L +7+ m L a 0 0 a 'Q a ..0 -C OL O= b�,O m L O s Q 7 a L >. L a a L O a O m 3 c CL L O-0 a L I••- i- '6 (n U C I— U (n H w O .Q L L LL +' bn U L m U a L a L bn L bA L bA LL Q O O m m 0 v v m m m N L bn DO L a � m VI >` bn on Ln u V)0 3 Ln _ m N c c O n m ° L U u O cu O C u- Q O O C .� O Q� ° O E a a t>a � bA O C LY E C.7 >i' r a to 'G O = Q' +' W ° an m a c 4-1 n U E m Q CL C7 L a c a U m bD a a a a w E C ban C CL :3c Q c C C)ai m v 3° E " a Ln U c U �a f° Fa o ° n >- a 0 N 3 0 v n N '� v� c 3 :G Ln a 3 bA ti- Z Q a c a an ,� ON E a C> m OL a, 0 C a C c O LL u0 m U C 2 (n L N N v Q -1 N v4' o a s 0 Q = m a m w (n m a cV Q- m (n n L -0 O m 7 O LJ bn Vf U v3i U J .(^ H N r,4 m U- V) V) ._ Ln 0 bn C. c O = N_ O U N Q.0 v � Q L _o O ca co � o •� +, a v 4, L t Q LU p U _ C G �• +p cu y E a;S O twU- f�6 0 ,� = -O = 41 y U A N 3 L °+' 0 3 E 0 o 3 0 to ._ t = f6 o o 4- U !O t= U 'o v -0 4 + L v 4-+ _ 0 o = U f6 N 3 J = dA N N 'L >T E ,� L O t +_+ L +, r, N c a O O tL -0 -p +J N m +1 ° a) c , N a) _ O E v a bA a , L = +' .L ° _ °c _ CL vi C) N f6 y N = = iZ tS 3 L Q -0 � O .p L m v `� N= O U (B N L !6 _0 to o to to 3 "'O fa aA m 4_ U O p = -O �+ c L o =a) ,Nu to ++ l0 N .3 0 > o ai O cu .+� = to/1 0 i _0 � +' o o v n° i.5 u c to O> v CL y0 n M o U a o co v 0 c� N a CCA to CL O °-0 0 o m m v 0 3 `o U@ 0 >- 3 y o _ N O t=o aJ +, N t a; aci — m 3 L) c= Ln a) N == f6 c a) a a)° fl ca (Y) L t a Nv a' E 4- ++ o L -0 Q �� N O N c 0 U Q to 3 a) v _ +, an v N v ° a 4, v v v Mo a a) " CU U n o c ai M °- M 3 "= c v E s 3 v N v un o a ai U +, 3 CL N t =o 0 c� m a O v iZ tL tw O C7 L Q +, t=u _ N H bn CL E +� m N �-+ U= O O E N o �' `� v > L a-+ = O f6 ° E 4' i= c E 0 -0 G L N N tU > = rn t O 3 U N o -O 0) v 4� tv 0 L Ln ° z o v 3 o L a) m o c c to o c +_ `° Q v 3 ai > N O ul v> _ U v •� tt) c LL to E > a = N c tli 0 E N Oy L v ) 3 0 0 m Op O ) C -6 J fU N C N Q; O Q R to U i ® ° N N NL J p +�o +, O O t +'F V bA N " N= E U E U> a) L u-0 0 0 � a v 0 '� ¢ uA m a) v co +, Q L! L LJ (iji � tOLn w CU � ai LJ U-0 V �LL- f0 O QJ Q. 41 N 0 >- O �'- O 'O 2 E w p O O O J v = a) C C v C y U N U 0 y E N L U o a L, ._ 0, > o +, p= tv fO 0 a) = 0 + J = o f = +cu a-+ N C C bn W 'a E N CV to v a a i a=i 0- -a tli c -0 U L +� v 3 to > N '� E N tU 'v to �� M 0 7 r6 N 3 N @ 4- O Y o -0 = ¢ O L C iz t o tw 3 4- aJ 0 t w _ t tZ N 3 ¢ w z m L f- U f0 L w ++ N N a., L N +•� A) -0 E J L L L L L L tw tw u4 tw tw w m m m m m m v y p N > Q _0 0 a) �+ +, 0 + cr tV N (U N M O c cr U N 0 = = y o N o ,uf n L .� .-i 3 ON f0 V j Q > �V1 4. -_ !6 v a�i >. a '3 c o c c U 4- O-0 0 '� C o _ (6 N = 0 +, 4- ro Q a+ Y e m- co "O y o c Ey Q- c m E a) _ + = N tL tU E c O a) w c N = C N c m 11 uA p c -j tL L f6 N c) L sZ tw r6 tw i O o 7 o `F O m N •r- M > O T u L o 0 _ O QU1 O N y > 0. U L U N cac = y O U = ° CL r 4. 0, c N L S c +_ G N LL M c m > 4- O .� U CJ L W _ E °; ra '� °tw v 3 `u 3 `-' .°G ^ ° � a c = oCL oc �' c v m L m O aL+ vOi uA +,, m tZ U a fl_ >0 cM -0 ° L liJ n. > N a) E tU .v > tv s v 3 = to o. a M ._ to to v L M" v n •- Z a- v •c 0 n u o '� a -0 7 a) 7 L "M ai= S i CL L N N N C7 iZ to 3 L to 3 c a) . L U +, M LL +, ¢ M L L 3 ^ co — N m a' Ln O O N m CL C O C •in o 'u U O L -0 m L O m m CO O O •� Y Q aYi Y m L w 0 u c L o 4_ a ° @ an LA CA U c v L Q< Q u4A m LE 3 C O Y f = >+ V U- a p > O 6 E 01 Q L C m C � H _ y� S� ai 5a ` VI � IO a o C L V7 Q) Y tO m O m -p U C E CL cn i) +n, N a) N 0 N C ° v ai o �' a U o-0 0 O Y 3 v a `� V O a) L +J Cn '� i a) c +�+ to C cr ate+ 4J C 4� aj 4-1 C .= 4) V - C =O u VO G - Q 4- 4-1 Q. N =a_ a) •j'•� .O L Y i I� N� L 0 > M o > c O I— 3 : '3 E+> o _ No a) ° v fl rn > v v a) .3 ° 3 a v o p E •� v 4.1 aj _ 0 v s +O- Q U C p N L> N} Q v m� p C E C v $ �— 0 6 c m m `� D L O '^ 3 LL u 'ca 4� > > µ- tin O V O a, _ �' v v v c v L �+ E 3 °c m O C QJ +' Y u J v (O U N +' = 'p L a) m L t to In O O p v Y C CL C: N m m iz Q1 C = a) L L m Q• '+'' = O_ L V1 Q. Q. •= '�'� G u C a v 3 v ° cu E Y c = }' a) E Y v N = a_E) aa)) �+ CL —> +_ m coo ° T= c N a1 3 V 'f LL L +' C O > .N = i a) O +, LL t N t)0 = p= N CL o E _ C:CL 4� ao m oo m S� 'L a) vUl N a) p CL Q p CL p N in u H N 3 u_ ° = = M on s O Y O> �' +� cu t m Q O> v c o = 0 m I� 3- m +' a) +' C Y i n= m ao = 0 o O p p y U C m �� O L o a=i c 0 a) ° Y CL ca Q_ O m C C U a) m E p Q� Y 3 a N tw� °' n o 0 :a = m c u o to Y � o� �� v w� Q m E CL Q ro m L N = CL .0 CL 4m- _ °Q) 0 0 = u 0 Y U= 3= N v V) L< u v Q m _ 3� N o c u 0 w m _ M .o acc .� 42 - -a v Q L CL Lo u `" L = > .N a= m N m �, o .°1 cac > E = t t a) = bn -1 m � �, C Q" o J m � L .0 L F- — .L � .� G a) u Q G u 3 3 �' t � n� _ _ Ll— s 3 L H .0 .0 m �— �— � u .0 F C m ao m —i hn m L O CO on m bn m Cn m hn m tw m mL u mL mL mL mL CD m "O N N E C p >-a) _m L C n m p in a) a) @ N m _ ` O �L) O u = � N> Y m(n O L>. b CL u > a) m O _4-` @ E CL i]. "O a) ° E a w ) Oa 6 a a n , m 4-1 4- 4-1hA Y w (U c L a) - M p p c _ Q O m C I� L m = m = c do vi L 4-CU Y O} v Q 0) m V m m m [V LL � O m N a) 44 0 0> u Gu m 4� ma) O 4- o Q- 3 Qj .(,6 +Ul nCL v. Cv O > nn Y = _ d Qm Ym aY) Ma vU o J C uO Q m LL E L : L' +=.0 o o° N a) a)v nn 5 u u m m m 3 _ c Q N 3 u 3 m Y Ln 4- O N m CL O o 'u N O U v -p 0 L 0 L ° f6 Co CO v •— Q tea}) L a w o u c v o t N > t N N v = a) .� E O L CL Ln+ N 7 a m a) C �+�- = > v o 0 o N O M (n 0 M = > O 0 = L L U C cu 4' 0 0 04� > O j O ate- N = Q) O 'a N v � = 41 -p (O v a) � L v, N '^ co 3 c v _ 7 p (N6 a) o -0fb Cl N 41 m u ° *' m ^ O L 0 ..= L 7 O a o 0 a) E 'p O °oy 4-1 o= °�� Q = � CL O N �' LZ. .N O aJ R "� N E s t m 3 a) F- L1 LJ {'' by (n L p. p E N Q o L a) t ++ _ lb M L i 4- f6 � 0 ) _ O O _ a a) > O� cu > L C N M ++ 4 N Ca c ai O N -1 f6 C = N O E t a m a; o ° E a) 0 3 O LW .S �' -0 c= o u+ ° v c = ° l6 i N U- !Lb Cl (b L U .L) N O u j� O �+ N .p O fb L m" _ _ a) _ a1 L a) a) +� N a CL LZ -0 —-0 Q +, -6 N Q p H v- O t �6 N ) a) i1 a) CL (U_ E N> a) L +, Q CD m EA 3 u a) 4' � O Q L N a1 O N O 1+ O}° o. L L 3 �b C2 C N E ++ w N N w O 7 bbn 4-1 M � N ) t OD 4 i Q x N Y N C1 !C v LL +J U O 4 ?� -C = o> = a) a) L= a! = .� o .v O N~ p' N N V O to O N O a) -p 40 a) 4O > N o tea) � �, ns w L a v 3 (U ° t o ° -C o v° v o°= m O 3 Z mv Z H U- = C2 02 4+ !— U v to o Q- v a) E ra � i o0 L L w L (� L b. bA rLb w tLb WA t J O _ J O b.0 co 0o co co U m U co by N a1 t L +' a)'' t N W C: o Q 3 4, 3 v Y 3 = o E L = > ° 3 > 'p p m v_ 4. U + E ) 1 E ("u, -°[6 ro E L1 0- •.V U 3twM O O N• O ° U u ° 1 CS > O v�NN�a)G L -6 v; + 0 0 'Lb 0 W O v- 0M�-0+� 'O `^ CL a)00 " 'p di U L, ice., _ 4 = �O cb a L a) O M L1 ci N N ]C = a) p f6 a) N a) O 0 M +' > o U U +, a) 4- v a) _ 'p 4J W N CL 4= +, N O V > O O +, v CL u a) i v to nz �O � U- Cl. CL m _- m c 0 .� m O LJ 4- o 3 rb C N N l6 N G c G L 4-1 a 4-1 a)Q ?� D. '� o .� U O b=A � i 00 N ca oo N 4� a) 'p v N 0 � N 7 N U> U tub ° N oC E LL CL D .� > N a>) 'a O CL E 1— 0 N 0 Q 0 N V E 4- U f6 >.Z N L ++ .— _ 0 c of _O U N Q U aJ Q L -0 m L ° m m CO O •C: +- Q aJ 4. m L 'F Q W O U C pn +' v '3 � v aJ vi 3 o aJ °J On = to c .� @ �, + 4. = 4- c aJ c = O +J = `� L O m m 3 LL Q +� a) 4. 3 _ Q.� o �3�*'� bn L ?_' = EO aJ =�,, 4J aJ aJ N �6 N a c t aJ ° +' 4• a aJ O 'i o m m ° cG O a1 t o n 4- - ai N L v C Q as- CL v L .� M_ Y aJ c tlo 'F N � \ ° u a ° 0 v L :G O > `�° n °� c L 2 > = p u ° L _ _ 3 o L m aJ ° ++ u m N CU iJ m m-0 +1 aJ +A� - Q aEi 4- U a t t o 3 +N L ® aJ m aN+ r m O' 3 i O= O a1 N =cu � C U m N U u � > O aJ v aJ c36 m :� dA , O. Q ' cU0 +- � N N LL .G U v- aJ a O E O N c O w aJ p m ._ L aJ c Q C N m m on aJ O s N U L a1 LS c 0 F+ 7 aJ L C 4. CL 's.. t O �-•� E aJ N = O E ,+ �! 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N a) O a) O _ O t L O u N E cc E _0 a O a) -a -p o '^ ro bA OD CL =v (6 +' O N c _ CO O_ U O c O ++ N 7 O �� OL � � m •> � `~ V p O O 4- 0 O L p bD O- L -0 E cc N L a) a) 'O +� O o u c '- _ i- Q- 0 7 0 N (0 L T L Q H > c lC G 4A c L) >- -0 N ,N +J >, c +_ O ++ N Q c a± 4- O c N ,r a) 0 c a) O U f0 , O- a) 0 N O O m -0 N (O ,a1 > a) C) ai c ,N N Q CO L U 4-1 N 3 a) O L .> 0 n s ai y� E o i 7 OC N (6 N T o O— '�.I ++ acn ° 3 °� '� c f 3 o O Uo o - 3 0 c o v w� v 3 l6 O T �+ y p CL + (0 U O— a) O 'L c+ a) 0 tw c0 a _� � t .c ¢ a n a) c-3a o o N dA c a) 0 U N c a) a 3 a -0 a O cB L> o V a) N p E co a-+ a Q c co ^ L .�_^ p a) d O D �O a) O c N N L t+o a) = a) .c O c a) 3 c L O E Q) +� a) N v a) a a) v O aa) +, 7 -0 7 a) L a) O U i L U v N aJ f6 (6 a) O a) L L (6 a) N i v- t a> c v i v L N by y_ m L O {— L f6 E Q U .c .c 4• N l6 N -c O �-•� % a) L Q (6 LL }/ 4. N — a) L 4• a L tO O T � � I � O � L O U L - lcc6 G a, L ca -0 E c0 f0 a) V o O J CO J N CO CO a) L O L N a) L 0 a-+ � p O 0 4-1 -0 U + CL 41 a) O- O c L L E a) O N w L o o N_ � N CL u C N V O >i ai a) bD c 0 >� p L� c -O m E Lc O a L1 O i L Q- N Q- c L .4-1 v E pC 0 a) a) O c QJ H V o L O � 0> 0- N a) i•+ c a) o E a) 0 CL O Q E �) c° (d c +' 0 Q L 0 a - o Q 3 co oE> °1 CL a) a O E 0 0 E o`n v U +, 0 E E L f6 = L L m O a, -O Ln O N tw l0 a C: 0 a, p r6 0 00 0 C: 0 Q O U O > a! > v C Ln X aJ .N a) N +' L1 O c c vi C O N 4�aJ 4 O_ cvi N O O O O "a ro cu� +� a1 O> 7 p L a 4! O� v � by U O +� bA N ro N aJ N c i + .� 3 U- N O v L +J w 3 N i v ra 0 c 6 p i " (lf 3 U f6 W O W �•' U 41 L O a.,, ro N p rw o u ° L 3>- a - 3 c �' CU LL>> L 0 M a) r�6 m LO > p LL i Q 3 > O M 'N 0 = a — U CU bA 'L O p o aJ 41 h0 O c O 4+ _c ate+ a a- t > fO N a..+ O p Q. O O N N a- 4- ,,,� M U QJ L N O aJ O _o N O U U N i aJ O aJ CL > O 3 N 3 mO ro 'O a) ro LA�-- 3 E i w E O L a) O U ?' 4-1 N L L i m a'' rD m t = L L a1 w U w LnU a c 4-Ln a LL} N a1 N L L UJ L Lnr0 > ° N \� ai E E lu O ii O o v a�� i°- =wN 0�s _ (6 •N +, a) O LL bA c c b�0 N c> L co c 4- .an O E "O .� j O° E cu M a) 0 'a' U O 'L ° O c 0 N _N +' > +� O 4�aJ ro d N = O O _ L U r6 O • r6 ro M 0 LI) Ln 0 (aa ai `v } CL o-°c-0p0uO c "i- 3 cu In ;G H aJ a! bA : a O- .� CU O U bA bA E C N OU E ro -a E c -� •� -� L 'L o Q °' lao p o v 0 0 0 °' v ai c E CL u �a acu ci c aj E cc a aj .- s N 0 4a1 0 `- c a U Q +J to ca 0 c c o^ 3 0 +� '� 0 c� a 3 3 L O L O L _C O L 7 aA c O z a -0c;-- 3 3 CL-0O m a u m m O O 4. N O ai a s c a) ra by a-+ L O C O 0 `6 Li-o 4- L -0p O v 3 U O N -O 1 O N 4- +J � O O T c aJ ++ O t a O +' rD >a1 01+ �- w+CU L > Y CU o ;>-O N a1 L4,1 O LL O CLO In o .N N O C. E N u ° c co CL hOA 4' -0 p CCC nn O O aJ O O p c O o O LL> n 4� u p oN N a. 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Y f6 E O O ._ CL m '� L 0 of ut = L .� 4+ �' 4� aj c - LJ -p a1 L Y= 0) N C E LOLOYc O > ut aJ to O ^ fE6 E a1 D aJ L +L Up L () p a) E Q �? li0 L = 0 'r + = bD t o a1 O- O O bA n �O p m '" a) L -° a) > ns Q- O �' O ra n = a) L a Y 6 a v°__ O L c ~ c v, o c ° a� v_, L v N +� E o to N E of C (6 Q U (0 c L Y E Cl Cl aL c 7 O L COr-1 i L aJ -� C E G > �U 'i o 'Td }i L U = a1 L c OA aJ -� V) •Q L bA Cl V) m U L 7 -p a= co VI ci v �„' O O Q N N '0 Q = 4, i .� L = 4— a) i-i = Vl t, O O G L Y Q ° ao bn -0 a, 3 0> c u =° E m ° U o v v O coo .� +s -p L L L O ns to UO L c O c U (6 a1 � Z a -0 •b-LA U @ n3 W v L >� Y 'r, Q O a p = o �-' L Q L in (C L '> _ O Q > O Y E > p- L N E N L buo '> co VI Qj L O E _ � V) Y � Q U aJ -p iJ .N O 4- = O .p aJ Y ut aJ Y (6 OU 'a aJ V - U M O Y p 'n V' p LM E aJ i• CL vYi v O c f6 p= 3 > U . c Q v Y dJ c c o Y c n .= � o = CL v a� E 3 L a, -= a! v _ nn Y 'O c O N Y aJ Q f6 v L (0 v L O (6 Y N s- C2 .- L N m aJ v v Y O co L O p Z= '> L o 3 Y to u U 3 O Q. � c = c E a) Ln i L o LL v c c> �- U L G c -p z o 3° a> > +, O .fO .- " s a a aa) m o 3 'p z ut ?r •'n aJ .� L L L i �+ -6 U = C2' L i •1� >H - O E v. i L n3 Y — L Q L `° a aci L> C `° G Qi v `° ° '� E -0 ai �' W CL o E E a) -p N = .4' CL p•0 L L U Y W O (E Y 3 O = U L Q a) C �'• ��+ 3 -Q VI @ v -Q 0 0 N U N ,U " 3 ` ns L E U tC N 'Q Y N t,, _ Q p „ U E Y° m �, 3 a, ca O 'n 0 c o" U V, = ) co U� v ro aj t6 c c - 0 a, a c U Q o Q c *—' +, m 4- M O J +L+ O O N p 3 Y a) �+ L L O to N W m= D CL n vOi I- O Z = V) n L `G u Y-0 t— >- 'n p� d Y p d ti m= P1 N h a) Y +-' '6 H a) O -6 m Q O= lu U > O LL a1 L a) c L c -p c >. }' aJ = L .E = tLo = al c X= O a L Y O "6 aO Z O= O w c O L ° L '� a) a, L ? ® '� = N N v L L a, .N M •i-+ c a) O 3 c C1 o v v i IC p tB •T-'' c E iO E v aJ > ° m o ;E �, v v _o v o c m E is E c o`6n p O G aci •� CL 3 O -n >� L a E c O '-' c i i in N c N c U L p L CL U Y c a1 in m 'a rp a1 U �i U m m O- E L L m o Y > t- u 4! L a) Y e6 m U E a U 3 l7 U .E E to rl -1 00 00 L L L L ci G CCCCi G G G J a yO w OD cu O O -j m m 3 o v = _ 3 E Y O /1 Y ,n v c° w 0 = p c M p '. 3 an; p a) mG m m 4 + U aJ E o O o = 4� U a -"- o = + p � " c a`, v a=i wo E 3 `6 E c° oA 0 •"- 3 0} °Y' v cLo Q m 'O O Q O Q O m Ln Y L 3 L O " a>, = o c c c 0 L M o ?� 0 0 Y L� 3 .� v= c E Qj aJ '> ow Y a! L - z U O p 'Q aJ L U c Q 0A i c E M Y l0 U CL c m L Cl p ►- m 0 Y O c v LM O w N W w f0 CL Cn V1 +J N a n +J Q 41 Q a-+ aJ — > L O = Q t 'L a O N aJ a i ° 3 Q ca � N t bA +, ro a lV CU n O= >. 4r a a v a O in D N O 4, a C 0 O p = O_ N 4 =ta J C -0, = v 4_ La _ O 3 $ 3 0 E Q)- v aJ fO Q 3 ° L ai Ln aJ Q. = aLJ o a 'n =_ c Q fa a = _ ._ cu = a E a to a= O L Q L U a s " J O = aJ 4. -a t O 4. U ro in aJ uo = E 'cc' a) O G U o _ cu +.+ _ � N a '�, = +, - = __ 'p a 3 E tC +, O_ E N O. 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L 0 a 41 '.r 3 a) to T C m-0 i� a � t- E co E aJ y L O _ -C U U a a E .° > on N L t uLn a O onLa`J at Q=a ra 3 ° v a 3 =v +' bn z c _cU)=a) a 3 o � cu o,, 41 ; E a) o aNa '-C - a • spa"Uco cYJ ) a v a c O u ° 3 E a � a > = +� � O a = on > L on � O ,� L O.P v 3 a ° c -Y Y (6 (6 = O an 4- O Q° Q_ L = Q' VI �-•� O O L >• '(,j l�6 L �,, a �+ l0 +J 4- L N = O U- �-+ U 0 N ..i� L E= N a N U a .= L hn = Q i/ r ~ N L_ c0 N N a i 41 CU = ns a E in a s ±:' c t co p-C= e t a 3 L `° 3 :p = 3 ° E L `° ° _ 0 o 3 4Z t o H M M �— N {— = co aJ H +� vJ +� U H v, 00 00 00 00 u u i i U U U L cu c G co m cc C m CC C L tin L to ro en m m Q m w t Gi a ° a) L Q W N ca +, ++ E 4�- _ i c v_a 0 3 to a ° o (A_a3 o a E � o +1 U La � O O co o �+L� Ha LanJ m c W N Jr m Lt} N L c� a+ ,r- J Lv .p= C O CU p o 3 Mv L- °t °`c te=a °E Q)o a EE00 "a o Y3 =a) a m L a_U L = N O_ vm 0 +O N4-1 Ln L O N 2 Q C N L = 4•1 � ° E (6 Ln aJ QQ E +J v N a) !n v L _ F+ = a a +-i oac@ V, Vl vm = c° J(Li a ° ' +,o o =o a E 3a = v M 4. �' c0 °_aL z O c=o 4 o 'C � Q o 3 R* Ln O N N bo ro a Q) v a) s m Q) = N •��-' _ m m Q c O u v LLn m +1n O Q) E c Y o T !- CU U CL Q) Y O fl- Y E Q O tip m L L a, i) 0 Q N �, Ln Y O m O -C w 3 O C L U Y N Y 4- C bz C� tm m CL C w Q) s 0 -0 p O M O C E v 'i Q1 N p QJ u Q) Q1 L O 6 Y i1 C Q) m- O C 00 Q E c s L Y s v Y s Q) Q) C o L O c c v-0 a, E oL w Y Q1 p 3 L Y o Q! Q) m LD 0 > p O E m Y 'p Q O _ ..p 00 0 i m — O O O > `° F- > _p O m Q) cn f6 N s a) a-' u � — L a 3 dA m LL O •0 Q s c c }, _ cco E °Y' c O c a) O (v +' 3 `° cLa 3 c E aaj Q) Q v aci ° -0 -p 0 O QJ m a v as+ U O SQL) W 4-1 a) a) E L cF s L o u 0_ `6 c aa)) ° o t E Q Q~i 3 o c N c .� a, - E -0 a) v> L to +� (U E s o 4' o p c a° Q c aY) -a -6 + v ° p a) 4 '� 'Q u v E Ln o c o a ° a v> v v Y Qj a) o : s L o v = in y U O Q) s — 0 m m O n 4O C O O O O Y s Y .� Q) ~ vi c v O O aJ v bLA Qj °o `^ Q Ea)a, ° a; s ^_ p v N v -p 0 +� '^ C c s U c v° a) � Y„ 0 6 0 c v= 4-; n +' is -0 v m Q �' 3 v-C .O L Y E = N a) J✓ A O m O 'C: Y O O >, c Y Q) L E L O m N O Y I N Q- O 40 O c •i L Q) •M ti .� m N Q Q Q) L1 O O E a, O +' N U L� Q) Q) Q) O L v m C Y C C L 1 ° '6 ;G 00 Q) m = LO U 3 O t u n Q) O> +' a) Q) s 3 EO >` 16 v .0 L Y Q E Q Q) m C v O s Y m U 7 Y L m .� L L Q) O Q) Li- 1 m Q E O 6 OL O 4- o U .0 s tw c 6 .- 3 L Q) Y c v Q) c E '6 O U o tiA v s c ~ Ln 3 L .0 'L 0 c E Q) Ln U o = m C CL L Q) C s � O L p `n Q1 >� •- Y Q) 'C 7 Q) O 4-1 O Q) to Q) Q O O N LCL C° O? Q m p 4c i CO = �?! 3 aU+ m ate- C U Q) " 0 s Y Q) .m bn U E '� m C a) > 0 '�+ -0 L m '6 a) um .D . Q) 6 in -0 Q) Q) o .f Q) � L Q N G N 5. -0 Q Q N ° CO 6 Q Q O Q) 3 LE 6 m n o a o 0 Y N 3 .� o E c s c m � c : E E Q) E c i m= � L > L I- p Q) Q = E m m LM .� Q m 1 ct p Y s H p U s L E- -0 O U m Y 0 G Q m _° E c Q Q .� > m a 00 00 00 00 00 s s L s s s U ci G CC a CCL C cci G G L bD L bn to b m Y CO cn m m m Q Ln cc to � v s Y N G in L o Q) C a) Q) O N ,� a)o° F,, ° Q) ami aco o :E o o 3 Q) m C E o w v Q n° m Q) v 4-1 Q) Y Q)00 L —_ _6 — Q- wE () M c `Q° 0 1 0 4� E 3 Q E v v o ca Y Y s +� s y Q) cn C z C p = Y O s Y to N 7 C L aj E Ln LA s on _ O Q) 0 c 'u O 'n O c Y ° C Q) t as m Q) m ,- Y 3 L o =� a, o� E s 0 c C� ��uo1 N Ln m Li c 3� A OU °_ 0 3 E N v c O m rn aa)) m t a m O-0 Y c o V) v 0 Q to c o v c c o Y c� � ,n M +� N Ws 'c i- N N u E N L •E Y' ,ro Q OG 3 Y an L v L O m y -6 .- N C O O U E Y U- v Y -6 N •�•� _ -0 Q Q C O== Q) m� p- m O L c 0 Q) s E v s -p 0 ' 0 m m O Y Q) V) m m U v F- ,_ rq Q) u 0 U H - Y L_ 0 3 m 3° c ICT Ln 0 00 N a un m a VI Y i V L Ya) !L6 Y Y Y r6 i- ° �„� -C(� Y O = C aJ = s E L O L O —' 4- (n U '� a C i bA a 'L ro to N =>_: ° aL °(A p S QfL0ja .aCte+ UL _ °S NNv } E O0 =a1 > � 4, N ra Q L v� O U m v L bbn p v• U N U •�a 'Y+c_6•+ 0C p > O C +• O a 4-- J vi w M _0Q. = m 3: ° CU _ 0 p to a O at= a1 •L 'O N NaLLo U N�p m' cu N L 0 aJ — cb _ N Q O 3 aJ O bA N L O L = N .Q Q (n = a' Q - L > = a) Q L Y Y U t t Y bA a) rO z -O i f- C O L ro Y M QU L C L� C a1 2 0 CC N> Q Q 075 i v ,r- Q) ate,,, m LI)hA O �O-0 �_ (n Y cb C U=A v r=a G t v c w c U u W (n a ° O +, 3 C a) (n L a E L- w C __ bLa to ro O_ p fl. _ O E U Y L Y _ 'O 5 o +J ld ti - = C E L aJ N L L, w t Y Y 3 t w i3 cO LL aJ O O.. a) f6 U O w a-' N E Q: w > O = O a) :r+ L- -0 S E Y_8 L .E -Q +' p w C O C7,, a c a! m 3 cn 0= Q, .Q (p U E cu u E Y E >° E a`� L a r=a `L° J •� o ,i O 3 aN oCL o Q L O aJ 00 a Q = U = ) +, " ^_ O O Y =_M �Y Y p `^ o in CL >, cu 0 .H 4-1 p Q,oE ° OD bA m = (n Ln EY CU Ln ., YQ Y /1 L U v } L u �•. 3 cL6 N -� Y= _a CL -0VI `L° > i=+ ; aJ O C C ° ° w 4-1 -a L 4-1 aip - Y L 6 3 (Tn Q, c O. 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O E a' _ •r-+ v N r6 [b Ln rO Q L CL of QJ a Ln O cn N a; bA ca a C 0 C 'V) O U C) U v -a Q L -0 N L ° co 0 m 0 m + _ C U •- 4� -o a v WQ L - o t a w 0 U C Qj N E v N s (U _ C O 'a s.: ` m = a) �-1 bA a � � +' to o ++ O a ° � N p E .N +v v 0 4-1 v t +L' N L E a 3 bn• E v t'o B y a ° E a v c 00 3 3 v +' v= _ai a) = L t m a L f° N Lc N a =O -� _ 41 = �- 3 0 > -0 C LO 3 �, s O LL-Q C! a N v o f � o C •� u u_ •N a N -a aJ a `° a a CL s c L N N O a ^ N C to O W a O C f0 c� a1 v@ ,� E �, 3 v *' � o c 0 v aJ a aJ 3 +•+ +, N ns v L +, N E bA N dl° L N N N % V 0 4- i-+ E N N N v V v 4..� o tin o v O m E E Q o .c +� L c Ln a1 � � � � �_ s j o � O N N af6, .? a m � J N N E +sue, +N '� 4F > .� a� � `~ � L .N c � � ._ � � U 41 C "a d ay, :� +3 C L E •(E C w .- ' a1 L C f6 4-1 . 0 `6 L +' c am~ n3 ns U a1 =p C .N N .— N d = � L U +' 3 � m 'p 0 CU U N f6 bA -0 U E 0 4= � W m 3 o `L U aC, a O C a, N -_ � N u bA aJ 4-1 o CU N L .fl" Y N -a -0 N a1 bA = Q- LCL '� j t -= •L m m +'' aJ = L a••+ a E o °a s N 0 MC (p `= L C o i Q 3° a c aL°1n m a v v Oa 3 E t a) v° v aj `—a"A' v LI) o m� a a 3 -0 a s E° N o +_ m CL~ +� bb +=J ai ;� _ 3 0 J C 3 aj '° a v-0 = o L Z O C a a +� C N o a) aJ " N> U U 3 40., +' � O a E_ +J p CL a 2i O C 0 cCL ate+ 41 - " _ cCL a � C '� a) O tw � l6 3 a! cci G N-0 _ =� L o m L G a) In a +•+ Q) E N N (� N a) V) ai C +, 0- a N 0 t a U F' E +N' jy ++ 3 v O N L 2 0 cu a O t C N iJ � i N 0 C OD Z-) N O bA a 0 L O Oa N C O O O O +' f 0 C nA c.c E `° Q_ L° a u°° •� 3 W__ v C UCA 3 o U L a n3 - a, p C 'r- E f6 L N to C C +, v +, O t t 41 ai L O— Z _ N O E O 0 N o 2 O-o° v a �� N c > t � +� bA > O 'O — O c=o $ v °; v 3 C 3 '� ca + o- N a1 N n. tw 4- L w 4' 41 ,�„ +� C .0 @ 4' C C ci G bA m 4" ba a 3 3 "6 C= aJ b.0 -= p m O N L= _U O X •a, O 40 .N .5 > U L1 U OL. Q O > a.•� .�, 'j_.+ N ai a u 4-1 (O N N w 2 0 E 'a +•+ +•+ O- aJ N O @ N p O E 0 a1 a1 3 0 .�"-I > b`n 3 P- n o .s Q n� �' 3 °, � H �° v +� H� 0 3 E a m 00 00 bo L L L m c� G ccc G CC G 4� � 4� O 7 7 C C C a a a L 3 E aJ U � _g-_ . 0 (p fb bA 4 O N O L > C N (6 3 N E N E a a o a V) p u L ++ 1 v c� O a rL N v � ns + CU0 C N 4 N 3 L L o s m= c E C O y a) a bA `- O a v v 3 a 3 +' c° E s^ bjD 3 C � 4, M °c 0 cEa +_ °; v v E U- U U -a a1 N bA C L N .M _ � .E 3 O >- 0 N° co C> a C L a; C p M� i 3 0 O= 0 E o O C a) 0 r o N O s Z-- _ Q" E C `� a-•� p aNi CL O ° Q Ln U _ m 4- w O O H bA V � N a) ca (6 4+ C 0 to w C I— bA cG E Z4t c q* to O 0 M a7 bA m a +� p o �, = a) N @ ai m = L N 7 = a) (O U 3 L N O L 6 o v- U t•+ Q° to U t6 "6 a U N L aJ U +.' � 4-1O L L C N O C '�, 0 v 3 4- N A U s a =_ aU U �° '� L v 6* t 00 O° D 4-1 c0 3 O V) a) o n 3 m -0 ;G tin v v 3 a) V) E o c >> ao o N ;� v y o 3 .c oo o o u a v LO OA 3 .`^ Q N L m .� (6 O Q N O V 7 LM Q m a) 4- a1 T-+ O N (6 m O a) O-C N E N U 1- aJ E OD O LL M •� N `� U N +' N in m cm w w O N +' 4-1 a••+ a•+ (O Q � O 4 + � O p v � ° � > N � bA N � G = � O = a) (6 _ (6 _ .Q N L rl y r0 a =.- IN6 N� v Q w C O 0 CU _ ° x v C 'U o o N L aj ro yyam+ N,, 4. a= U U N fl.. 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O= >� N L tB O N Q M aJ O V _ E C L " i N cc N O 00 = -' a1 s N O = 0 v v 0 Y — v = tin O U tin (6 _N � N a, a, -0 n3 r0 U 3 L � °o v N (i m = c c O 3 -0 v v o = X w o .� ° u v 3 'x 0 a, U •- � Q. v o a o ° Qj o o N 3 L CU E C n ° .^ v LA_ ai ' ° ° L Ln Ln U- N m0 aJ E {•� U O. cu L N L '� Y 4' Y t wQ) a6J L O ++ E L '� O E N cu L O= ++ 4- O -a L U L CL N L Y — O N J +••+ '' U N ..0 = U +••+ a) Q) a f v= aa) '0 o .__ +' o v o o o � v w U ._ N W > a O N O Q a, = E > a '+� v Q vOi O U M OOA N O s to @ 4' L ) m o o° � -0 E� 0 3 �, O W E E v= o° 4� a, v n y O v- a, L C Q L Q 0 C N +' L Q L} O _0 E L" aJ N � U_ E W a! _ _ O N N m +••+ L N 'N Q Q N 'A C O ++ aJ -0 W 0 j t J L N aa)) 75 v O O> t .ai O N (6 v v N Q> N O N 0 4- + i 0 O O i> N aJ O E a 4• v n E Q_ L do �1 Q M N Ln M 00 00 00 00 L L (c6 fccD (cc6 C G CCN G G a) i a Z _N LB .O .Q E E E E J J J J O Y = aJ = O 4M 41 U L 40 a _ +� •� 3 Y v o a v Ln (6 = M � M N O v a v ° O_ 0 Za+N Oa) V N O E O L CL N++ O L m I— = m Y U O 3 +�o M ++ L L V) . = aN > of bD N o w0j a, L = tin o a °; ca N° pn L Y ° U '6 0 0 o c —_ c — 3 �+- v to C:) v O `r- i C a, aJ N 3^ 3 N o o .N a) 0 o m L L L to U (6 U' S -O = L O +� f— a1 W +•i 4- O >� U a L O o N a) v Q H p F aJ >- a N 'O Ln = +- v Q E M v +- W c u = O v c`o •`-L° v a"i I- ai +�- C j .� v= m-0 fl M m v v4-1 °_° .N > o c v 0 cu w °_° O +� .Q N V, a aa) .n a a> '0 U a) O v v •G mm >• U aJ 6.PaL p Q o U aJ>rp 0 m w QOOU N O OON'G U O o O a o U vcU'° O " +NmNN mEv m W U CoMZ L O L 'a U0 a) >, Q U I L2 C -O L� E E oaL V' Ln 0 N M a; b4 (6 d a O C c a O +' +' .Q O o ba.0 0 O 41 L i� a V) -a > C v u 3 a o �' C: Ln u o m C L ++ 4J .0 U m >� Un cu E i O a = Ln •_ •L -p O a m C O ((O 41 m v p L � O C m a a in f6 in 3 Q. 0 C a 4• 7 0 >, p +J L L m n C Q N a O. cLa �, m >j t " Q p a 41 +J a 72 +p+ C cu 4- O J a p U v= >. v) m Q O C +' N v C a i C O a) O O U Y O n a _ 0 ai C:m N m � a 4 J U L � Y N E a o 3 o v > � Ua -0 m o o 'v .� U o p o a E v 3 o E a; ai �, n= a� +, b a Ln j C)O aj O Ln +; Ln a 4-m a 'i s bn O 'O — O 3 i Y ,a; v CL bn O p O L O O> O N a N di O N m m a = a .4 � 3 `L° 6 — a n m a a) C- bn a Y Ln O a cn O a) O O O �'0O 0 Q W N ZrN> = m a ra a s a a y rr 41°o co f a E � 30+b � s a) N °� ° a O O= � 6 a E O o In a) bn J m Q_0 aa C N O> L0 O O a a 2Ev O W m c 0� u bn �fu S_�Q 0 C) + = �+Q N aDj- a > m +., ma m O m L a L® i C L '- C '' O a v Q. 0 n U 'O U m O U I- U 4- S H 4 + a . I- U bn .- Q- 4- to v, u ao bo 00 00 00 00 u u (cc6 fcc6 fcc0 cN G cm G G G G cm G a a a a a a -0 T5 z Q E E E E E E J J J J J J 0 O C ~ O p O . N a O y m }' 3 a L s O C m +� > +, v p as Y U Yi, L c 3 a 3 c U a o V)� m 3 N O O Y U ECL O -p o C Ln a� + N O C CC -aC O "Cu E .poo 'm y Ln tw a). -0 bn a O O a C_ > o dA Q 4., ° m v, a +a 4- 4+ a Osbn >` a sa Q= E Q LnQN � E > OO 'm Om U .1 m ) C• C Ln U t E N O O 6 =O N a bn u V)c N O n:3 O a ++ 0a LY O E N 4- m C L C O U m a 'p > of m O = `� L E o = m E� a = �� 3 'O n E 3 v a a U 3� �� a > m a U O a " y-+ O m H 0. L O 'O m 3 O •r L1 a C a U m C m C 'O -p a Ln m ' C .0 U m C = 4' a j 4� s a O Q a a m a++ t O O ++ `° c a-+ h L) m-D N C O U a a o a`) v E aE) CL 3 3 u v —° v O O O� Y VI o L O t U- + 4O Y O. a C a N N i vi m > o U N •= u C va-. 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E 0 a) m N 0 aJ = ` L o(u >cL a E° E a E 0 a; v o o c `n m (n E c v O 3 �� o 4° E ° m ai a)-0 c-0= 3e m= c 3 +1 v vim$ 3 E >-0 m ° Tona)� (rn C" 4- m o m �' >, v� m U s o v n c+o v m N (c C L +, U ++ 4 ° C "� •> +p mM N C m Q LnC C }+ � 4- U L E> i o a) a) N o CIO ° o V, 3 E° �- ° O E° (n c 3 o s m n O E en Fl, Q� L L a) m a) v m o p �G N O L o o C 0 v> L (La Gi CL <:5 �.=oo v�E3c a) Z c v� a) -6 0 v, m m 4t O C c m m E -C m a I- L o ++ aJ w Ln O Ln M a) en m a C O _ Vn O 'v Q 'v aJ Q L N L ° m m O V - Q aJ 72 L L Q X L W O V C N Y t v O aJ = _ LO _a to aJ m C- aJ co O = Y = .E = Y o U V 'N UJ U bA V O i � .= Q aJ O Y C In O N Q= = Q 4O = a) Li- O i ro 3 f6 O O N t y O N . N =� V O L Y Y N vi n� = p 00 p Y (6 Y N +1 N O Q — l6 U L U LA bAa '` '> YO v� bLo + LJ L In 4' C Y o ,..� Q co Y f6 @ E L a) 4- 0 _Qj v° ra +' o aai °' Q G p °' o c v a n° °Y' o a, v L 4-- E O O � .+>-, N u =- = v� 0 N aJ t v� aJ L a `n Ln aJ T _u a1 Ln {Vn ° � CO Y O am f0 Q _ (n bLA 4- 4- 4- V) f0 aJ L = Q N O aJ L aJ m aY+ N C O. Q> v 4- N O O aJ W +, r, of j +O C + Y M aj N v V Y 3 v Y y- w Y L -a s V) v N a U U (Lj ___ Ll N o Y m L a1 '' v L tB N () O @ = aJ UA In C i� +' l0 = to 'a tB l6 > O N S L Y = Y L a c ya1 aJ -0 'O !n L +- = tLa 'A to N O CL E p _ = m .Q U- H a� T +.I = n O O -O " L 0t'�°LaJ L U C Y— E d- UrNo 0NQ Y a_aJJ E� O E 0 m c m m t saJsO + v Y°p 4 c o Yt4 = > O N>u+' Cra.Q ? N>. = Y in i = O i� O N W a) O VO blO QN a) ti O M -° N O° G E O O v O yE Y) N ° ° T— OTNQ ++ CL E pO Ev ' N _ COM n 6 N p L = "ClOVIM Ym o f Y m +' tin m E O a=+ m- ,- N >C J o �a -° m 0 0 3 a, O °= 3 v N °' O aJ c �' Q = v s c s>= a y° L a, N t n x m Y 3 Q Y E = _ E Ln _ Y O Y O •- O = Y _ Y _ •D _ =O L a E aJ -a ate•+ N N of O -a +�., L -a L > cL6 = ._ a E Y O Y N L1 O L E aJ Z aJ O- aJ OL Y= LM > V1 Y W = T-+ L 'n J dA '= V) E +•+ 0 N Vf �, f6 Q Ln aJ ° ai c aJ = ea aJ C, N E aJ v= LE m m m- N m E o aa) (A cu � M� Q L Lo to aj " aJ E O Y aJ Q cn Y N oN L > L E E = a, rIn a a, +' a � v° ns O �_ , aJ = +, of .Y •� -a aJ (O n = aJ s �'' ".' (0 aJ co '� to = E to m aJ +, �,, G u a"J = = ai �+ a) t = E E OU v H LA .3 u z Q 3 O ® H - 3 E L ° o aJ � aJ -O t on 'S� cj a, O c6 L .E Li a=J .� In Y W Y� � f6 J L ii Y 00 00 ao V L V L V L m (a (0 a > > v aJ a, E E E m J f6 J f6 J bn L ai = o a N~ v +`n•� V aJ c E v = ns p t a +�- G LJ N Q >' O aJ O' -E a N u ' co aJ E Y , c E a�+J >� n o aJ > v a) ° O _ a �� N n L J OV n > O Q N v y E v n p v v M M- a)v Q 0 3 o N CDY aJ o = aJ 3 f0 aJ L.:i -0 Q = t aJ \ = co bLA V > a N v L = ` 5 O M O v n L O -a M L-0 t m O n E to 4- Y Q Cr O a a.Y '41 3 N 5 Y Y to bn a) Ln V U N v aJ E C 3 � L-a Moo N �„1 °° Qaj L � vQi u E o MaLLn O Ov d v on N n Ln Ln o= I C� O Y N v Y 0 0 0 +' u U m= m 0 + E U U-0 ° z m E o ate c q* Ln O W M aJ qA a 0 .__ N •N Y 0 a , a c -2 ou c N ~ 4� 4-u L. O 3 a) a O O_ 0 p -O a) +O� +N a) -0 -j N N a O OU 0 h�aQ v i cU) co tNa � �"•� v p0 � >� O c v G= 'a C *' � m aN S 0 4- Q 3 E a) c c O O E i y- N a) p L L u a, -0 a1 a1 C cp N W } v U� C O O_ L pn 0 0_ v to � L v O co a) m •N E C s a) L �O L cNa v'� to LL > O c i h co a= a) t L E a) o3 a +� a) co a) I- 0 L) L N ._ •r O Y U �+ `_' U 3 N= i a) �O dA � N `L QJ c m v L a- u'' E o o •Q 0 O E a) 0 ° ^ 7 > v '� C ^ c6 a) S s a c ^ L c v T 3 co .L c co can co ;� E LL 00 (6 N -o N +1 L u � y,+ N v L 3 v �••+ Un O '6 N v 'Q i o L -0 qn i v v a, E L % N 'O v +., U � O Q 4- v o C 3 L U co m a 3 +� ,�., ,� N c o 4- c a� L L 4- +� -6 N a) Q- +� v '�'' E o NO �° t Q' 7 ca G -Zi 4�- a) N 0 a) O 3 N U N _CJ C N c v a) E L -°a N co 4L 0 p c o v 4$ —_ Q+ E c -0 v° �, c 41 O �a c ra L w L1 L (Q fp > '- a) L 0 N �2 N L LL -o 4' 0 c6 Q 4O a) s t6 N O c N 0- E L U 3 N O v O O 3 a) N-0 •@ 4- a) cu c N O_ O N O N LO }' O O 00 O N c0 0 Y ,` cu v 0 a N t cr +, 0 C to .0 ++ aJ N Y ++ N L 3 4, a) O N c to L +, c i O U p +, aJ c E L 'O E O Ln p -0 E N +' dQ 'O a) O U N +r a) 0 -O adC 0C-- c L O O 0 C t O c T 7 ca L u a) L I— i "� -6 T N i `G u a) t+•+a L u c L N G G •0 •L U c�.� Q= N +N•+ a1 `P � Q 'o E E a" E L � c +•+ -0 Ou oA L > O >' i L 3 T a) L c a) to i L L 4" L on p aJ c N O +, L •E u C L a) LL L O a) > L +, O ac L N a T +' Q. aJ N O_ of 0 L a) L >` L 0-0 +•+ (6 a) 4F a) a) a) Q N bA -0 a) +' N 4' O _ �— L O L N a) +, N �, a ->>c +.+ O O O L .0 N ++ L ++ .L i— f6 a) O> O v 0 N L ai > qn c CL > E io i 7 L a) 4- z co u O N 3 ,� E -0 E Q cr 4-1 f- tB to G L a) O > .� �) m C 0= a) U +L N 0 c — M O a) L a) a N N c L C v u m O N a a) a) a) j E co +'cu a N Y V i Y $+ Y 3� a) p a c (O > > O- L O a) +J N N M N a) a)Qj a-J -0 "O 5-2 L> >. > LL C a 4- ) c LL N a) a) 'O N +� Naj N G i+ 0 0 C L cD +L L LL C co v O +, N i "p N U a) n3 Q. U ++ U c LL u 0 N Q. ro > c dD N a"' c 0 CU LL O_ j tip � m O 00 O N N O +_N L 'O N C} L N L 7 ` c6 v a-i t LO M M on c6 �"' :a_+ 'E o- O> N> O= c 0 cM , O O 3 bcn mO O O tea, u U 3 cu E 0 E v o .N . N a .Q 0 On NQ 41 t m � c j a) L +� U wD a a) to G s O aL' � = m O 0= 0 O E .� a) a1 O t a) .� m m m M M N N N N N co 00 L i L u B m : m m :3 m ::3 f O f6 a) LL a) LL a) LL a) LL a) LL E E E E E E E J J J J J J J M 0 m O N U 4= N �_ O' O 4- +.+ >� C> � j o N O ON c0 a u dp0 N E L u -0 C: a) aN+ +•�4 'O a) O O O Q. 3 cca —' E c ai c_ O o f6 °N) v no •'v L v C = oLn � o 3 _ m O x u u 'N n � c N (U +J L 'O V'f Y N > �? '> a) O co � N i O N L1 0 C O C O 4- `- " 3 c 0 L O LL aL..+ U E ,N bA N �_ -O 0 a) -p v ~ Q N N N 7 M N '� C cB N _ U i 4- Y, a) a) T i 4' N N O C +J L c V T = a c c 0 i N .0 i u co N p +' E 4- 0 N O -c c N a u co a) tUo — N O Q) v r5� w 3 a o a 3> a) a N � au) -0 a N a) M V) c c 4J c p G ono c v c O L� — 3 C L> O a) m E L `� a LL c�a (10 v LL 'Q a v L on a, a a on o m No E v E L t v `o L1 c :.c ,.G E 3 a o o .O H LL F N u LL 0 cr c I� 40- R* Ln 0 N M O hn a +, = 4, U N u v O O O L QJ a)0 aJ CL y m CO -C4. 4, w L QJ coo 3 Ln Q1 +� _ = L V1 {/� .i., 4, .= .Q m 4-+ Q. N L ++ Ln i O CL cu L +� s t 3 ° a, Q N V QJ aJ L y, L t -Cv t bA m Q1 L co O an L aJ t C N a, 4' > a� � p 3 o ao C — + .� a� m v Li a� = CO O OU = @ _ o 'P Q H U p ^ l.L m O m O Q> aJ +, L -p — -O iJ O n O m •G +Q,J N -° Q +, p= d C � aJ L E o v_- } n n aJ w w w aJ m u a) � p � C , m aJ aJ 4N Q U N � O am, aJ 7 m= t m a1 = a w O a-+ C aJ X Q- m O w E L = Q Q_ DO c-1 U L U a) uL U Q = o O L QJ LL t u +,, m +m, u O m O +' aJ aJ '° Q � -.p +1•+ O p v c-I V ® 111 L Ln ate, a) •� — cu aJ O �+ U N -O bA m >, = bA N _ +' a1 ',�-+ _ t 4-1 v 4- y i. N L c�6 tin aJ o ate-, 3 E _ >, aJ a,aj _ � N u s 4O 4� +, V - I- t LL a, > t u -0 Ln Q ai 4 '- v N o o _ -= N LA Q O a) +' oA L _0° = o cn m -_ �— u ° QJ >� ° c > +, Ln = CL +, m '� O v N Q v x O L E = •C Q1 m U N QJ 4' i G LL 'n vl C L -_ = E aJ OL = Q p Q +�, U aJ v i mco N aJ t 3> O 4-U tN6 n` n i -0 O aJ +L, _ °_ N t ++ O cu C n Q) O 0 i> U. N N m > L ti- ._ -° LO aJ N O aJ _ >� L L QJ *, a= m ° E QJ -p > N 4' a' op E �, bA v +�, E -a +, 42 E r, = a i aJ o O m o O C *' E O aJ , 72 +s-+ O C Q m = = v E CU > ,� 3> N W o n p v E Q kn Q_ O—J _° 3 `L° ++ m > L cu o > v aJ 'Q = 6 L i , Q LLLn = -r 3 4- O O O U p a1 > Q c G V m V U +, = a1 Q O en a! N > a) U4L- E en Y n rj � p N m L� Q Q1 U O" O@_ `- 4O N >[ Q> v aJ L1 CC vLi aJ O O QQ `n 0 U C O +�, c'`J O 4! -Q N QJ aJ '�', Q=_ -0 '� N ° O O aJ {., = E N v ,= +, p 3 v u N Q. 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Q O L M n ° 0 n O O n 'L O u 41 E O Ln c a)= Q N a) O �w 3 N Q m c a) G aJ .E -0 t O `CJ °= o CCU ~-0 o O 3 0 3 O cuAo p 0 `H O 0 N N > p L v +J .0 4' ai N a, L L C bA m .= O C 0 v C L aj i- C m L p Q (n —_ •= a) 0 aJ u to a) O E L @ a, bA t = O V a' E a) a, o > .v 4" 0 41a) -0 a, tn O u �— c0 +J o y' C p + N ai V E _ OQ "6 LL LnOD In f�6 fQ0 N ° i H O n O Y v y m to 0 (6 f6 y Q Mp J= Q V bn _ U L m i v -O {n a, > Q Q o � i lD -0 r- O= bA 0 +' _ aj LL n r u a) L :t x O O -0 .= L dA +, C �; O N C M aJ ° Q a, N L = > o r, aJ a) Ln M y +' tL = C O ^ .0 _u Q O dA t>C v +' aJ O 0CL = rp 4� rV-I E Q O� N tLo '�' C 0 Q a) E _ U t a, v a F- O O E a, {n = 0' L 0 L u ° E a O u0 O i bA L a1 = aJ . 0 vi p C +, O bD L w v o O a) (O > m M "0 > _0 (a Q E 3 C p � u N _a O X v u n a, +, >= a, t30 L aJ +' ns .N U- O 3 a= E v v 3 v a) L 0 �6 O U L i N Cf, L •� t6 s +, .� `v >- Q v v °J ® a v Ln E a eoo a=i m 41 o = O O a, `� "0 = 3= E QJ L CO 0 u, C E O L C "� CL O in c •� 3 Q- m t a) " 0- ±' 'A u aJ u v m a, v a, `^ N v ca oLE a a, a v m= a, a E _= O c=o o ^ E Q a, 3 ao v `6 o cu o +� U L +� E I— o C +� O L m+� +-+ O O O O _ v a) a) a U- U- E E E E ° =3 J C C O i cr to w u O O i- > u O w nA •L LL m m Q o O a� L Q a) E i a, a, •� 'Li @ o c ,E 3 +�+ U ++ o (�0 +'' LL +'' ++ } = C 0- cbD 4-1° = >U V a) toa 00 co L}l O I� t6 L V i i a) t O U CL Q 0 0_C 4-1 cu H v f° o ai c L 3 o m No rn Ln CL -1 M 4' +; ca o v NN = t4 — s O E v= o - aJ c n3 a) v aJ +J n 5 3 ° O 'p p _ L .c O = aJ a) n 0 a J +' +' N + L E +J s '� 0 3$ '^ L 0) aJ tin OA _ a, OJ + Q > o O C 0 +� a) cr aJ " E c�a c=o = ° N L c = °) .Ln .v = v n ° � v 3 �° >. > u aJ N 3 = :3 c c Lo ° a, s 3 v„ v c0 " O R +, ,-� 3 axi o Y ra ca a`ni c�v E= L o 0 CU �+ v v° f6 a^i 3 +' m O v v- v a, u a= a) a, ° L a, u C.p n N L E u Q N— QJ m 0 to - aJ 0 to o= LJ (A u a) a, u > u Q. -C v _� cLo W O v ai v O 4-1 v 3 �' 3 3 a, c=a E (Va ++ � LA O fLE bLA M ++ a, C � `n Q m ° a) 3 o v o m LO a ° o v v r o a`) 3 t C u L N-0 _cu a, L vi •�' f6 L a) u a) C C -0 ao = > O aajj m v o C +J 3 L y L to V1 '> ++ = Q O "0 L aj 3 f�6 3° Q E U L Q ^ p N s O o Q_— O 7 aJ O Q E 0 O Q o p 0 0 O m L 3 °' F .`n o .� E uJ 2 E o a`n 3 3= o° a—� a u °° a 4* LA O 00 CI' 0 hA ra o_ N L O 4 N Ln =O = L L N p +r a) U •�-,, ,bA Q on H vi V = •` LL C -Q m L O Q a) O LL a i V m O ++ m a) c � N 3 O 3 Q O L 3 3 = �c � N.� ma- a) c 0 E O cc c O" v V O 4' = s 3 m aJ aJ s �, O s s E +� 4-1 2Ln o O v N 4- m LJ 6 O N O aJ a) L in�' 0 0 N m = O a) = C = N > ,n O tV Q O 'O Ln ++ + ' v v +� ON N •� _ a) Q a) L a) L +(U a + N 4-1 U m N U 'f'' _ = w U f0 E L = bn 7 ++ N S O +- N +� N 4' u , 4 4+ +' 44 ul O +•+ L = = s LO E a) O O ` O N V a) m ,U m O ++ �; d v N N = = U a) .� a1 O Q O O O i- LA vOi L 4+ L ++ O a) a) m C = t Q lap 4-1 = t a) O C N Ep m Q o Mami > > •0 ~ E vmi L s u H u a a 3 CLEso s° L N w e -a ° o a) c m m aCLO m o v e a) 3 n 3 M N m 3 LE +' toM 3 v Ln Q = L 3 o O c Q ul N O— _> m U E a) qp s= O N L m E V) = E C C N O v O O " N Ln N aJ m CO N = N 'AV a) s O 'AV 4-1 a, L -1 N m m O L N C (n = 4-- _ fl) a) a) 4L N a) aJ 4 t t 3 c c - c E v w v� +� u N � a>i L m Q N_ ++ N E s _C ++ v L Q O s c- L O Ln 4 O 3 4� LL LL H O �a F- > m (A —i - L L L m m m -I L i U U a) aJ a) m m LL. 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V = L� V Q V aJ SZ N O Q 0 L U v L Q + 4- > C O O m— O Q L 4�- N N fo a) +•1 E E'' c� 3 �� 41 f O v o c s O tt to U CL t6 v=� •E o= L •0 m ++ 75 V 3a = `f' M 4� E L (6 �--I +•I N �O t Y a) L Q by s 'L — - = V N .� 0 a -a +' O o O �; 3 v a) en 3 N o m E o a) = `- m+ Ls' __ -a c v a) v 7 O a m N Q 3 m O Q m G Q °� u a >, m 3 c a) +' a f6 c m +� M -_ bO s �- m p O L v m m aJ � s 4s a) -p O N 3 p => m 3 bn t6 ' L aj > -0 LL i> m E N N c v Q u N Q 0 a) '5 u Q E Mm m a, a) m 0 a) 4' a) a) m +' C O m m E o L O +' 7 a) L v C +� a1 a1 Q +� Q m a) — E o O +N+ L E O CO (Li u CU to s - E m 0 .^ 3 3 m a tEo vOi 3 Is— f—co ao v tQo 3 tQo aa") J (ENS :' u LM O m to a) n_ C O C in O U N Q U a -a Q L M L ° CIO M O m o •- 4. ..o Q a +. 4� L - o t n w o u C v "a ai '6 N -O 4O a v�i O O C a u >, Q }' v r,4 a vi � -=F, C > ate-+ _a) to m m M in O � a p C O E 7 E� m c a .0 m 'i p tYa O 4 J OA t a= C n p m T a `� U L Q= Q Q a +�.+ 3 @ vim- O av+ ,�, U "p a = N 7= O O -p a -_ C L O M m .0 .2 > L a +' __ •,�,� m u ++ O L a 3 H a => _ ° m m L� '�'' 4m, E O U a m OL p O y 'p w a 7 M U v i kn m= a 3 a v •-E N = Q 4! N C M �„� 3 m a O C f4 *' V ° a1 L L v +.� �^ T M N ++ (O N -a C (6 m of a c° 5 O� T L w a = _} a O c bp 4+ O v a 3 a) u �+ n cLn m ° � � � W u 4- L M ,OG ° �T+ � C U = � = O +J a i C C m vi 'a N N v O O 4-1 m `n = ' ip E a 3 m 4- m a N Q C Q 3 m+ O L > E m L a C N Q O a L s a o v O a kn O O a �- m -0 n N L a �, a m L .� Q) a 3= L E m N 4. > L 4., N a �. 0 V) —_ L LM C O L a� Q In O a= +J m C a L it UO O 0 O a a> w a L m In m v- o +� - a 3 a; +, O L a o s n a o E X +-� 0 a° � t 4.1 „= v `� p •V1 �, � ° +j L +J m -o +� L m u rLo U' a •�., m t 3 '''' a 0O a 'a m -a C N Y v = > C L L m m ° a N 3 X -� p� a C 'a w 00 a o m p t .� I- Ln L1 N U a a O a sm E ate-+ a' Q U a s O c s C) L �O (O n a L v _ C N m 0 QCL i. >�+' L + j 6 O -a a m TA " O L; ti •' L >vv 41 0 °n ' ti v o ov a� a t t v o � + m� 0 4-1 � ~ c a � CU L aj a aj -a c , 4-- o° o,�@ Qs °Q f m . oo o mm f v° C n o° o n Q3,, a=' v a v L a Q. mN E O_ N n a O +� co a ai a E n n 41 t om= B 'E t o O E E u m c .° p +J p H on N 00 .Q E is �' +� O m a Ln C H a N O a a) a a) -a E} _� +- 3 O •V a r cn a-+ ++ a M a-.' m O a to N C m N 'U O Q + `� -0 c v ami 3 u o a 0 o= '� _ ° �, c=o L aii - c as a u N a 'uA o @ o axi L L m C _T L +1 a -a m O C E .0 O L t N L L �+ C i +� a m m > Q Q a +, +- O a a m M t .0 f- F- C T X a m u .3 t a H C m E Q. m C m C C O C t I- v� a c p +� c +J a H T v� .- -0 ._ ._ u i C L s L L u L cm G CCm G CCm G cM G cmm G a a a a a L a LA mai- N E 3 �_ O L L m 3 V) Y •a C L VI a 0 m O w N a a-+ Vf a-_ p o O a v �_0 L- p E m °_) .1 v 3 v a+�) v L cu O _ 0 C 4-1 o> .� m 3 V, E o o O +, a in v a0 m v- O m Q m a= L O C .E Q- lD ? a a C w p vL- .N m +, E c-i Y M 4"4T O = p O p `n *' a a a v a m L a m 3 -a u > m p m m a � '� m n ° a) `� � o� c a a) _ 3 3 m m +, a a E C� _ > O C 3 0 0 O 4+ = 0 4-1O vi i- a > O `n y N v n n a a a c 41 3 -P n tin C > O u m u 0 a E E a 4 o c C C L a o _ w 3 a) L I- a`) n c m v 0 L a a C m a s v a a a a 4� R O N C o U - p C oO u� m (D a 0 Q 4* In O 0 Ln a m a c O O 'U N QU aJ -p 0ra L -0 0 L O � m O o CO O c 4 v +� ra L - p ..c Q X L W p U c L o 0 3 a C L a 4- Q, a) ° an o o f E �— a LP O +' Cu m E v v acu 0 c v, c c tw O -a Q1 (U O t ns aJ = � O c Q c f6 c 4� +� 3 N a, -a o u i v o w c +� = o 4- 4- +1 CU 3 a E Ln o 41 o `, -0 a>i 41 a c 0° 0 3 °' 41 a>i L o E an E L N C ��— 4-1 a, 0 o- U L% cu v m= c Q- v m O i E Ocu � H m N C m c c t a� i1 E L ,N U bn O U N a) 0 a Q - C cu E 7 -� y co v c ON +� O _0 c `� O w rl O 4� fl- c w qA 4n E cct- > tVo QJ In QJ ++ U c ++ c c O Lf1 a� O bcA L U O •] c L C U N Q '''' m bA U 4J f6 O N QJ 4� •i Q1 }, a W v on c Q L E a, ro = rf v y v a-0 aci E 3 .4� v � •Q Y m n m E -0" Sao >, o +� = v t O o U c v epn Q1 L L 1+ 'O U v0 C C C �p 4-1 :L' X U pp a) O ? 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O > C tA n '� E a = L O-0 CL � c u -0 C: U- � O Q O > C Q ° C N i�O 4E O p Z O O ?O ai N u 4+ CL CL Z_ O U C O 1 OZ o 0 -a N Q- v C CL � v a) o o O + O 'O o ) O 4 U a m Q N CL E> ' N CLN to a)O M o ° Q .° a L ,v- a •> uo O 4-1v o+Nb_aL•)A ° E) a14' 0>O Ln Ntb a) j m a) C: ) N LL a) O U ) O Q- - CmO + m C O —1 >, O a iNcCNb a) CL E 41 � C b -Q E -0 �oNN O y+ Cu C O O CL o 0 0 00 O aL O O a) O N O cQ� Q -1 'C O LL C ) i U 'a U N CL cb d• fn O M 1n v w m CL c O c 'in O U N a) U 0 0 L 0 L O � m O O CO 4� O 4 Q +• 4M� Q L - o Xa X L W O U C ICT Ln O Ln bn M a EXHIBIT B Page 1 of 27 THORNBURGH RESORT FISH AND WILDLIFE MITIGATION PLAN ADDENDUM #2 (2022 FWMP) RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT ��D PROF—% ���NE�F, \S f115 g Renews: 1/1/2025 Prepared for: Renews: 5/1/2023 Central Land and Cattle Company, LLC 67525 SW Cline Falls Hwy Redmond, Oregon 97756 Prepared by: Cascade Geoengineering, LLC 21145 Scottsdale Drive Bend, Oregon 97701 August 16, 2022 As reorganized on January 31, 2023 Project: Thornburgh Resort EXHIBIT B Page 2 of 27 FISH AND WILDLIFE MITIGATION PLAN -ADDENDUM #2 (2022 FWMP) 2 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) Introduction This report was prepared by Jim Newton, PE, RG, CWRE, Principal of Cascade Geoengineering ("CGE") on behalf of Central Land and Cattle Company, LLC, owner, and developer of the Thornburgh Resort ("Thornburgh") as an Addendum to the Thornburgh Resort and Wildlife Mitigation Plan regarding potential impacts on fisheries and aquatic habitat and the specific measures to mitigate for any negative impacts. It incorporates elements of and replaces the "Addendum Relating to Potential Impacts of Ground Water Withdrawals on Fish Habitat" dated April 21, 2008 (the "FWMP") developed by Newton Consultants, Inc. ("NCI") and supplements thereto. The mitigation requirements and enforcement measures are set out in Section II, below. The following section discusses the results of the mitigation measures. The remainder of the document provides background information and scientific analysis based of thermal modeling and analysis by highly qualified experts and an expert analysis of the effects of pumping and mitigation on fish and other wildlife that are dependent on the quality or quantity of Deschutes Basin rivers and streams. II. Thornburgh Mitigation: DCC 18.113.070(D) - The No Net Loss/Degradation Standard ("No Net Loss"). The proposed mitigation measures are designed to ensure No Net Loss of habitat quantity or quality and net benefits to the resource and are comprised of four categories including: A) Reduce water use and thus reduce impacts on the aquatic habitat (Item 1 below): 1. limit groundwater pumping to a maximum of 1,460 AF annually, which is more than a 30% reduction in originally approved water usage. B) Comply with the No Net Loss standard of DCC 18.113.070 (D) (Items 2-5 below): 2. Use 1,211 AF of existing water rights described herein to authorize pumping of groundwater from wells on the Thornburgh property by transfer, cancellation or other permanent mitigation (e.g., mitigation credits). 3. Comply with requirements for Water Right Permits, Certificates, or Transfers of water rights described herein, or others hereinafter acquired. Provide mitigation when needed in advance of pumping as required by OWRD mitigation rules. 4. For additional supply or mitigation over the water rights specifically identified in this plan, use mitigation credits, COID mitigation, BFR surface water, BFR ground water, or any other water source in the Deschutes General Zone of Impact that will discharge water into (or leave it in) the Deschutes or Crooked Rivers or their tributaries, to supply or mitigate for any unmet needs the resort will have. The amount of water needed is the 1,460 AF of total pumping less the amount of water transferred, cancelled, or converted to mitigation credits, and: 5. Thornburgh has provided 1.51 cfs of water in a quantity of no less than 106 AF of mitigation in Whychus Creek from the TSID diversion downstream by funding the completed TSID piping project called for by the 2008 FWMP that completely mitigates all impacts to Whychus Creek. Nothing more is required here. Cascade Geoengineeiing, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 3 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (2022 FWMP) 3 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) C) Provide advance or excess mitigation which is not required to meet DCC 18.113.070(D)(items 6-7 below). 6. Let unused water rights remain in the groundwater or stream to increase flows and reduce temperatures of the streams in advance of creating impacts except as provided to others for drought relief at Thornburgh's sole discretion. 7. Thin thousands of acres of Juniper forests onsite and on BLM Lands. D) Compliance and Reporting measures. 8. Detail what constitutes compliance with this FWMP and what reporting actions are required and who will be entitled to receive them. Section A: 1. Limit Pumping To 1,460 AF Annually: Groundwater pumping for the resort does not exceed a maximum combined volume of 1,460 AF. This is more than a 30% reduction in the amount of water Thornburgh is currently approved to use. This will dramatically reduce the level of potential impacts, creating less demand and strain on the region's water resources. Section B: 2. Use OWRD Water Rights Certificates, Permits & Transfers for Pumping or Mitigation: For the purposes of this FWMP ("2022 FWMP") and compliance with DCC 18.113.070(D), it is assumed the certificated water rights in #a-d below will be transferred to and used at the Thornburgh property. Certificate 89259 (#e, below) is being cancelled in -lieu of mitigation for any Thornburgh groundwater permit granted by OWRD. The Temporary Credit from Deschutes Resource Conservancy (f) have been leased since 2013 and may continue until such time that Thornburgh does not require them, and the Three Sisters Mitigation water (g) has been transferred instream in Whychus Creek. None of these water rights require additional OWRD mitigation under OWRD's mitigation program. Thornburgh presently owns items a-e which are existing water rights. Rights a-d are being transferred from their original point of appropriation (POA), which would be a groundwater well, or point of diversion (POD), which would be a diversion from surface water, to wells at the Thornburgh property, while e is being cancelled in lieu of mitigation consistent with the Deschutes Basin Groundwater Mitigation rules. Transferring a certificated water right does not require OWRD mitigation, as it eliminates the use of this transferred water right in its former location and allows it to be used, instead, on the Resort's property. Cancelling a right is done as mitigation and results in placing water back in the system by cancelling the legal right to use the water at the original point of appropriation. While OWRD requires no mitigation for transfers, as they only change the point of appropriation ("POA"), or point of diversion ("POD"), transfers can change the point of impact where the withdrawals will be felt in the stream from one location to the other. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.coin EXHIBIT B Wage 4 of 27 FISH AND WILDLIFE MITIGATION PLAN -ADDENDUM ##2 (2022 FWMP) 4 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) The change from where the stream was impacted under the original POA to the points of impact from the Thornburgh wells is the only element that could affect the No Net Loss standard and compliance with DCC 18.113.070(D). As such, CGE assessed whether changes in the POA would change the location where impacts are felt in the stream, and if so, how and to what degree that change could affect the no net loss standard and compliance with DCC 18.113.070(D). a. Surface Water Certificate 95746 (4/30/1902) and Transfer application T-13857 (LeBeau) —Thornburgh owns this certificate authorizing the use of 4 acre-feet per acre of irrigated land of surface water from the Little Deschutes River, a tributary of the Deschutes River, to irrigate 50 acres of land, for a total authorized use of 200 AF of water. An application for a permanent transfer, T-13857, has requested the POD of this right currently at River Mile 56 on the Little Deschutes arm of the Deschutes River to be transferred to a POA on wells located at the Thornburgh Resort, located generally west of RM 143, roughly 105' river miles from the point on the Deschutes River closest to the Thornburgh Resort. These proposed changes to the certificated water right do not require OWRD mitigation. Pumping has ceased and this water is currently in the river to flow from its point of diversion all the way to Lake Billy Chinook, about 137.7 river milesz. See Map 2. The added flow will provide thermal benefits that cool the Little Deschutes arm of the Deschutes River and the Deschutes River throughout those reaches. Compliance with this is certificate occurs as described in Section D Compliance, 1(b) below dealing with surface water. b. Surface Water Certificates 96192 and 96190 (4/13/1967) and Transfer T-12651 to Groundwater POA — Big Falls Ranch ("BFR") (Deep Canyon Creek Groundwater POA). Applicant currently owns this certificated water that presently authorizes the use of 4 acre-feet of surface water per acre of irrigated lands from Deep Canyon Creek onto of 153.7 acres of land, for a total volume of 614.8 AF of water. This certificated water requires no OWRD mitigation. The POAs of this water are wells located at Big Falls Ranch. Pumping was stopped on 90 acres of this water in September 2021 and the water was assigned to Thornburgh on September 23, 2021. Pumping was stopped on the remaining 63.7 acres in 2022 and a deed conveying this water to Pinnacle Utilities, LLC, was executed on November 30, 2022. (See Exhibit A.) An application has been filed to transfer all 153.7 acres of water to wells at the Thornburgh Resort. Compliance with the FWMP has been achieved. All 153.7 acres of this water is in the ground at Big Falls Ranch to increase flows of 11 degree C groundwater into the stream reaches affected by the BFR wells that are also impacted by Thornburgh Pumping. This is increased flow of cool groundwater r The Little Deschutes arm, merges into the Deschutes River at RM 192.5 on the Deschutes River. LeBeau POD is at RM 56 on the Little Deschutes arm, which is roughly at the equivalent of Deschutes RM 246.5. The Thornburgh POA is west of Deschutes RM 143. Round Butte Dam is roughly 137.7 miles from the LeBeau POD. z In 2021 Thornburgh this water placed this water instream (lease) to benefit fisheries habitat. In 2022 it was temporarily transferred to North Unit Irrigation District to provide drought relief to farmers. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineeiing.com EXHIBIT B Page 5 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (2022 FWMP) 5 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) provides thermal benefits cooling the rivers and creeks. While our analysis does not rely on the flows provided by Deep Canyon Creek to achieve compliance with the No Net Loss standard, changing the mitigation source from 13-degree surface water flows in the creek (2008) to 11 degrees C groundwater flows (2022 FWMP) into areas waterways is clearly beneficial. Also not accounted for is the fact that pumping from Deep Canyon Creek has completely ceased, allowing Deep Canyon Creek to flow to the Deschutes River. In the alternative, if not approved for transfer, this water right could be cancelled in lieu of mitigation for any groundwater permit or Limited License application to serve the Resort. Cancelling a groundwater certificate leaves the water in the aquifer so it can return to streams and rivers. Lastly, the POA could be returned to a POD in Deep Canyon Creek from where it could be transferred to an instream right with mitigation credits issued groundwater or limited license applications. Also, if this proposed transfer is not approved, and the transfer of the water below in c. is approved, Thornburgh will replace this water with more of the BFR groundwater rights that are not Deep Canyon Creek rights. Similarly, if the transfer in c. below is not approved, but this transfer is approved, Thornburgh may replace the water in c. with this water in (b). As both are being pumped from the same ground wells, there is no effect which certificate is used to appropriate the water. This water can also be cancelled in lieu of mitigation, or it can be transferred to instream use for mitigation of permit G-17036, or the alternate permit. Neither action impacts the efficacy of this plan. Compliance with this FWMP regarding these certificates appropriated from the ground is completed as described in Section D: Compliance, 1(a). c) Ground Water Certificate 87558 (BFR) — Applicant currently owns 18.9 AF of this certificate authorizing the appropriation of groundwater from wells located at Big Falls Ranch to irrigate 6.3 acres. A quantity deed conveying this water to Pinnacle Utilities, LLC, was executed on November 30, 2022. An application for transfer has been filed to transfer all 18.9 AF to wells at the Thornburgh Resort. Thornburgh has filed an application to transfer all 18.9 AF to wells at the Thornburgh Resort. This certificated water requires no OWRD mitigation. Leaving this 11 degree C groundwater in the ground at Big Falls Ranch has increased flows in the same manner as the BFR water in (b) above. As noted above it cannot be converted to an instream right the same way surface water rights can although it could be cancelled in lieu of mitigation for any GW permit serving the resort as described in (b) above. Compliance with this FWMP regarding this certificate appropriated from the ground is completed as described in Section D: Compliance, 1(a). d) Ground Water Certificate 94948 (1/30/1995), Transfer T-13703 (Tree Farm) — Applicant currently owns roughly 327.5 AF of water authorizing the appropriation of 0.453 cfs Year -Round for Quasi -Municipal. This certificated water right does not require mitigation. A temporary transfer T-13703 was approved by OWRD which Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.caseadegeoengineering.com EXHIBIT B Page 6 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (2.022 FWMP) 6 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 20231) changed the POA of this water right from wells located in the Tree Farm subdivision west of Mt. Washington Drive in Bend to wells on the Thornburgh property. It also changed the Point of Use (POU) from the Tree Farm subdivision to Thornburgh wells. A permanent transfer has also been applied for and is in process. Pumping ceased in 2021 increasing the flow of cold 11 degrees C groundwater into the streams. The Final Order approving this transfer was issued on December 7, 2021. At present it can be used per the transfer order, or in the alternative it could be cancelled in lieu of mitigation for any groundwater permit or Limited License serving the resort. Compliance with this FWMP regarding this certificate appropriated from the ground is completed as described in Section D: Compliance, 1(a). e) Ground Water Certificate 89259 (3/18/1998) — Dutch Pacific — Applicant currently owns this certificated water right allowing the use of 3 AF of water to irrigate 16.5 acres or 49.5 acre-feet of ground water pumped from a well in Sisters. This is a certificated water right that doesn't require mitigation. The place of impact from pumping at this location is in Whychus Creek and Indian Ford Creek that flows into Whychus Creek near Sisters. Pumping ceased in 2019 allowing all 49.5 AF of water to remain inground to flow to Indian Ford Creek and into Whychus Creek. It is presently being cancelled in -lieu of mitigation. This 16.5 acres of irrigation (49.5 AF) of cool water will provide thermal benefits to the stream that will cool the creek and mitigate for most all the impacts to Whychus Creek from Thornburgh pumping (see Table 8 above). Leaving this water in the stream is like leaving the 106 AF (f below) of Three Sisters Irrigation District (TSID) water (13 degrees C) in the creek in the same area. The TSID mitigation was shown to cool Whychus Creek from its point of diversion to the Mouth. Compliance with this FWMP regarding this certificate appropriated from the ground is completed as described in Section D: Compliance, 1(a). f) Temporary Mitigation Credits (DRC) — 6 acre-feet of temporary mitigation credits from the Deschutes Resource Conservancy have been in place since 2013. For nearly 10 years these credits have increased flow to the Deschutes River in advance of pumping groundwater as mitigation for permit G-17036. Excess mitigation has been accumulating since then, further discussed in Section C page 8 below. Thornburgh may cancel the use of these temporary credits at some point in the future, although that is not required by this plan. They are not considered in the efficacy of this 2022 FWMP in meeting the No Net Loss standard. Compliance with this FWMP regarding these credits are completed. g) Three Sisters Irrigation District ("TSID") Mitigation Water: Applicant has already completed the arrangements leaving 106 acre-feet (1.51 cfs) of Whychus Creek irrigation water (surface) permanently in Whychus Creek. This is surface water diverted at the TSID diversion near the town of Sisters. See Map 2, pp., 5. It has Cascade Geoengineeiing, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 7 Of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (2022 FWMP) 7 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) been permanently transferred instream at that point and is providing flow and thermal benefits of the cool 13 degrees C surface water to Whychus Creek all the way to the Deschutes River and then downward into Lake Billy Chinook. The TSID mitigation is 1.51 cfs of flow that is left in the creek for a portion of the irrigation season. In low flow years that may only be 90 days. In heavy flow years that may be 150 days or so. Depending on the flow in Whychus Creek, the actual volume of mitigation water from the rights being purchased by Thornburgh could be as high as 200-300 AF, instead of the 106 AF required to mitigate as determined by Yinger 2008. As noted above, the 106 AF need was determined by Yinger who modeled stream impacts using 2,355 AF' of water at 100% consumptive use whereas Thornburgh's current plan reduces pumping to 1,460 AF and consumptive use to 882 AF. The TSID water was shown to mitigate for the full impact of 106 AF of stream reduction at Whychus Creek. As noted above, Thornburgh has completed the required arrangements and this TSID mitigation is presently in the creek. Compliance with this FWMP regarding this certificate is completed. 3. Comply w/OWRD Mitigation Rules: Provide Mitigation Before Pumping: Mitigation required for any groundwater permit that appropriates water from wells at the Thornburgh property, will be provided prior to pumping water under that permit, as required by OWRD rules. Mitigation, when or if needed, will be provided by either cancellation of water rights in lieu of mitigation, or transferring the existing surface water rights to instream rights. By providing mitigation water from the conversion or transfer of existing water rights, Thornburgh will be restoring natural stream or groundwater flows to the system at or above an area of impact from Thornburgh wells, much of which will occur during the time period when stream flows are typically the lowest and temperatures are warmest. 4. For Remaining Water Use BFR, COID, or Other Water Benefitting Deschutes or Crooked Rivers: The water rights described in Section II-2. above will provide up to 1,217 AF of the resort's total water needs of 1,460 AF leaving at least 243 AF of additional water needed. For any additional water needed over and above the 1,217 AF, Thornburgh will use some combination of: i) BFR surface water (Deep Canyon or Makenzie Canyon); ii) BFR ground water; iii) COID mitigation water or credits; iv) Temporary credits such as the 6 AF from Deschutes River Conservancy ("DRC"), or v) other ground or surface water or credits that discharge water into either the Crooked River or Deschutes River or its tributaries and meet the requirements of the OWRD mitigation program. Analysis by Cascade Geoengineering, LLC shows: i) using additional BFR water with groundwater points of appropriation will comply with the no net loss standard and have no impact to fish habitat; and ii) the transfer of other groundwater rights that discharge cool groundwater into area streams and rivers will provide thermal Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 8 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (7.022 FWMP) 8 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WI1 NDRAINALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) benefits to the rivers and streams; and iii) other surface water placed instream above areas of concern will provide thermal mass that will serve to cause cooling during the critical summertime period when stream temperatures are highest and flows the lowest. 5. Provide 106 AF of Additional Whychus Creek Mitigation (TSID): Thornburgh will provide 106 AF of Three Sisters Irrigation District water for additional mitigation in Whychus Creek. This was required by Condition #39 of the FMP approval. Thornburgh has provided documentation evidencing the funding arrangements required, satisfying condition #39. TSID has completed the project and the water is permanently protected in Whychus Creek. This mitigation was previously proven to result in thermal and flow benefits from the TSID diversion above Sisters throughout Whychus Creek. With the extra water from Certificate 89259, flows are further increased, which is expected to lower temperatures further throughout Whychus Creek and in the Deschutes River onward to Lake Billy Chinook. Collectively, the measures in 1.-S. above will demonstrate Thornburgh Resort's continual compliance with Deschutes County's No Net Loss standard in DCC 18.113.070(D), specifically as it pertains to impacts to fisheries and aquatic habitat. The measures discussed in 6.-8. below will provide excess mitigation that provide additional net benefits to the fisheries resources. Section C. 6. Leave Water Rights Instream or In the Aquifer Until Needed for Resort Uses: Thornburgh intends to pump water only as needed. When not needed, it will allow water to flow in the stream, or leave it in the ground, providing advance benefits for impacts to occur at some point in the future. Advance or excess mitigation accumulates from providing mitigation prior to pumping but also during the transient period before impacts are fully realized in the stream. The CGE memo dated August 12, 2022, discusses the accumulation of excess mitigation. Table 5A of that memo shows that Thornburgh, between now and 2071, will provide "mitigation" benefits of 71,771 AF while reducing streamflow by 47,117 AF. This creates excess "mitigation" benefits of 24,674 AF (or more) or the equivalent of roughly 17 years of full pumping of 1,460 AF. Of that excess mitigation, more than 17,000 AF, or nearly 12 years of full pumping by the resort is provided from groundwater. During periods of severe water shortage, Thornburgh may work with OWRD as to request usage of excess mitigation water that may be used to benefit farmers in significantly impacted irrigation districts, including the North Unit Irrigation District that supports up to 58,000 acres of farmed land in Jefferson County. Thornburgh will request OWRD concurrence and permission from the County to periodically allow it to use its excess mitigation water to provide drought relief to farmers impacted by water shortages resulting from drought, the Habitat Conservation Plan, Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineeiing.coin EXHIBIT B Page 9 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (�022 FWMP) 9 RELATING TO POTENTIAL IMPACTS OF THORNBU;RGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) or other extraordinary circumstances causing water shortages for farmers. As discussed above, Thornburgh has applied to temporarily transfer 200 AF of water to the North Unit Irrigation District. Under this exception, until the water rights are pumped by Thornburgh or used as mitigation, Thornburgh would like to be allowed to offer free use of its water to farmers severely impacted. Thornburgh does not intend this as a business, rather it is envisioned as an act of goodwill and a benefit to actual farm uses in the area. Further, any water excesses provided by Thornburgh is purely excess mitigation water that is not needed to mitigate for Thornburgh pumping. As such it will not have a negative impact on fisheries habitat although it could have a very positive impact on farmers. This temporary usage by others may be accomplished by temporary transfers on an annual basis when excess mitigation may be available. 7. Thin Juniper Forests Onsite and On BLM Lands. Thornburgh is thinning substantial areas of Juniper forests both on site and on BLM managed lands. Juniper is a native species that, with an increase in European settlement in Oregon, has increase substantially throughout Oregon as a result of increased human settlement within Oregon. With this increased human settlement, and the associated changes to the environment through agricultural and livestock grazing practices, Juniper is now often seen as invasive by means of a likely 10-fold increase in prevalence that has been shown to reduce water capture, retention, and recharge to the area surrounding these increased stands of Juniper. Studies show a strong correlation between Juniper removal and increased spring discharges with estimates that may be upwards of 1 acre-foot of increased discharge resulting from the removal 4-5 acres of Juniper forests. Over the last 100 years there has been large expansion in the acres covered by Juniper, which may be impacting water levels. Deschutes and Crook Counties are both looking at Juniper removal as a method to benefit water. Deschutes County has received Federal funding for Juniper removal and is promoting residents to utilize the funding to remove Junipers. Crook County is looking at the construction and operation of a biomass plant to facility the removal of some of the 600,000 acres of Juniper increases since the 1930's. Over the same time, Crook County officials report an estimated reduction in water flow of 160,000 AF. Experts, such as Tim DeBoodt, Crook County Natural Resource Policy Coordinator, report that the reduction of between 4-5 acres of Juniper trees can save, or return 1 AF of water, ideally in the form of increased ground seepage that may result in increases in spring flow. Crook County hopes to reduce Juniper coverage and subsequently increase stream flows and return some of the 160,000 AF that has been lost from Crooker River flows. Thornburgh, as part of its development and wildlife mitigation plans, will thin up to 5,000 acres of Juniper forests, returning the land to the condition of the historic old growth forest that was prevalent in the 1930's. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 10 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (2022 .=WIMP) 10 RELATING TO POTENTIAL IMPACTS OF ?-HORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HAB17:AT August 16, 2022 (As reorganized on January 31; 2023) Section D: Compliance: The purpose of this section is to clarify what constitutes compliance with this updated 2022 FWMP, whether during the review of Resort land use applications, as reported as part of annual monitoring, or for any other purpose. As noted above Thornburgh owns 1,211 AF of water rights to be used for pumping or mitigation and pumping at the point of diversion or appropriation of the certificate has been discontinued. For the reasons discussed herein compliance with this FWMP has been met for rights b-f, and will be met for the TSID water (g) in the manner discussed in this Section, 1b below. For any additional water rights that are acquired compliance will be met as described herein. 1. Compliance with this FWMP will occur differently for water appropriated from a surface water Point of Diversion (POD) versus a groundwater Point of Appropriation (POA) or for a mitigation credit as follows: a. POA — Groundwater: For any future rights that may be acquired, compliance occurs upon the cessation of pumping of the rights and along with any of the following: deed evidencing the transfer of ownership, a submittal to OWRD of any of the following: (i) an assignment of the water right to Thornburgh, (ii) an application that seeks OWRD approval of a transfer to pump at the Resort property, or (iii) a cancellation in -lieu of mitigation. b. POD — Surface Water: Once acquired, Compliance occurs upon the cessation of pumping at the source and submittal to OWRD, and OWRD issues a final order (or its equivalent) approving any of the following: (i) an application that transfers to pump at the Resort property, (ii) an application that transfers the water to an in -stream lease, (iii) the cancellation in -lieu of mitigation, or (iv) an application to transfer to obtain mitigation credits, permanent or temporary. c. Mitigation Credit: In the event that Thornburgh acquires mitigation credits, compliance occurs when Thornburgh provides proof of ownership or proof of submittal to OWRD to use the credits as mitigation. Thornburgh also agrees to the following measures to provide mitigation benefits over and above the benefits achieved by the mandatory measures described above. Noncompliance with these measures shall not, however, be grounds for declining approval of a Resort development permit because these measures are not required to meet any Resort approval criterion, including the no net loss standard: 2. Thornburgh will discontinue the exempt use of all three exempt wells located on the Resort property (referred to as the Kern, Bennet and Price wells) prior to the completion of Phase A-1. Where required for development purposes any of these wells may be physically abandoned and sealed but that is not required for compliance with this FWMP. 3 Pinnacle Utilities, LLC an affiliated company is the Resort's water provider. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com FISH AND WILDLIFE MITIGATION PLAN -ADDENDUM #2 (202,2 i=WMP) RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUNDWATER WITHDRAWALS ON FISH HABiTli T August 16, 2022 (As reorganized on January 31, 202 ) EXHIBIT B Page 11 of 27 11 3. Discontinue the use of all purchased water rights listed in Section B2 a-e above (Pg. 3-6) until they are used by the Resort as a transferred water right or as mitigation for pumping groundwater for Resort uses. The following exceptions apply: (1) purchased rights may be pumped if necessary to avoid forfeiture; and (2) purchased rights may be transferred for use by farmers, including those in the North Unit Irrigation District or other party if used for farm use purposes as defined by ORS 215.203 (whether in an exclusive farm use zone or otherwise), if OWRD authorizes a temporary transfer to help address the needs of farmers. Currently, such transfers may be allowed by Executive Order of the Governor declaring a State of Drought Emergency. 4. The Resort has already committed in its FMP to remove and/or thin thousands of acres of Juniper trees from the Resort property and BLM lands to enhance wildlife habitat values. The thinning and removal of Juniper trees can have a dramatic reduction on the consumption of water, potentially saving hundreds of AF of water per year. Reporting: In addition to any reporting required by OWRD pertaining to water use or mitigation, Thornburgh will provide annual reporting (no later than December 31't of each year) to Deschutes County, with a copy to ODFW's local field office, of the following information: 1. The status of each of the certificated water rights discussed in Section 11-62, including the status of any transfer or cancellation applications affecting any of those rights. 2. Copies of any annual reporting filed with OWRD. 3. An accounting of the total amount of water pumped under any of the water rights discussed in Section II-B (2) between November 1— October 31 of the prior year. 4. An accounting of the total amount of a) groundwater left in ground, b) surface water left instream (permanent or temporary), or c) water held as mitigation credits (permanent or temporary) in accordance with this Section D, paragraphs a, b & c. 5. The accounting referred to in #'s 3 and 4 of this section will be maintained both annually, and on a cumulative basis. 6. An accounting of the amount and certificate # of any water provided to farmers for drought relief. 7. The amount and source of any OWRD mitigation used to mitigate for the pumping in #3 of this section. 8. Any change in the status of any of the three exempt wells including whether they have been abandoned to date. 9. Consistent with the 2008 FWMP, no additional reporting is required during the review of any land use application related to the Resort. III. 2022 FWMP Results Results of Section 11-A: Item 1. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.caseadegeoengineeiing.com EXHIBIT B Page 12 of 27 FISH AND WILDLIFE MITIGATiOIN` PLAN - AUDENDUP"I #2 (2022 FMOP) _12 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITA7" August 16, 2022 (As reorganized on January 31, 2023) Thornburgh, after listening to the concerns of its neighbors as they pertain to water, has taken dramatic steps to reduce its water footprint. The main point of this 2022 FWMP, is that Thornburgh is voluntarily reducing it water usage from 2,129 AF annually to 1,460 AF annually, a reduction of more than 31%. This reduction reduces every impact that Thornburgh's water usage could create and is the driving principle behind this amended 2022 FWMP. Results of Section 11-13: Items 2-5. Implementation of the elements of this FWMP described in 2.-5. above and the related OWRD requirements as described herein are expected to result in replacement flow, or mitigation of more than the resorts consumptive use of 882 AF per year at full build -out and to fully mitigate for all impacts to the fisheries resource in accordance with the No Net Loss standard of DCC 18.113.070 (D). At least 1,323 AF (1,211 owned, 6 AF leased and at least 106 AF transferred instream) of this replacement or mitigation water is already owned or leased by Thornburgh, who has ceased pumping all of the water from its original place of appropriation. Where needed Thornburgh has already filed transfers to change the POAs, the PODs, and the places of use of the water rights presently owned. 1,123 AF of this water is already providing the FWMP mitigation called for in this FWMP in advance of pumping. Thornburgh retained experts to complete and exhaustive analysis of the impacts to stream flow, along with the thermal impacts from Thornburgh's pumping on fisheries habitat and commissioned over 15 technical reports or memo's detailing that analysis. A summary of results includes a. Provide a net increase in the discharge of cold ground water via seeps and springs stream flow in the Deschutes River from Crane Prairie reservoir downstream to Culver, including at two spring locations of concern to ODFW above and below the mouth of Whychus Creek, b. Provide a net increase in the discharge of cold ground water via seeps and springs in Whychus Creek from Sisters to the mouth, including at important "ODFW" spring locations at Alder Springs and the mouth, c. Add cold groundwater discharge versus the 2008 FWMP to the Crooked River, including in important "ODFW" spring areas near Osborne Canyon and Opal Springs, d. Increase net flows in the Little Deschutes River from south of LaPine into the Deschutes River, e. Increase net flows of the Deschutes River from the confluence with the Little Deschutes onto Lake Billy Chinook, f. In most cases reduce net stream temperatures in the Deschutes River4, g. Increase net flows of Whychus Creek from Sisters to the mouth, h. Reduce net stream temperatures of Whychus Creek as noted in "g" above, i. Increase habitat quantity in the Little Deschutes River, 4 Thornburgh's 2008 mitigation measures estimated an increase in temperature change of 0.00 degrees C at Lower Bridge, 0.10 degrees C at Steelhead Falls, and 0.1 degrees C below the mouth of Whychus Creek. The hearing officer approved these increases which is DEQ's legal threshold for measurable change. Cascade Geoengineeiing, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 13 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (2022 FWMP) 13 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) j. Increase habitat quantity and improve habitat quality in virtually all areas of Whychus Creek and the Deschutes River, and: k. Reduce the thermal impacts in the Crooked River as compared to the 2008 FWMP to levels immeasurable, including in spring areas noted by ODFW, and not likely to cause a change in the quality or quantity of fish habitat. These elements a-k, above are based on steady state conditions, the point in the future when 100% of the impacts from Thornburgh pumping have been realized in the form of streamflow reductions which may not occur for decades into the future after Thornburgh's pumping begins. Measure C below discusses the excess or advance mitigation being provided to the fisheries resource. Results of Section C: Items 6-7. Excess Mitigation: The net results described in Section B above assume steady state conditions, the point in time when full pumping is occurring and the reductions in groundwater discharge into the streams are fully realized. As noted above and in the CGE memo, steady state conditions will not occur for as long as 95 years or more.' Until then, Thornburgh will provide substantial amounts of excess mitigation, likely resulting in un-required benefits during this timeframe. Assuming it will only take 50 years for steady state conditions to occur, Cascade has calculated that Thornburgh will discharge 71,771 AF of water into the system while creating impacts/withdrawals on the system of 47,117 AF, and excess benefit/discharges of 24,654 AF additional water over impacts in that transient than required. In sum the benefits provided are over 52% greater than the impacts created in the first 50 years of this 2022 FWMP, and equal nearly 17 years of full pumping of 1,460 AF. This situation will be most pronounced (nearly 100% excess) in the early years and gradually narrow as the difference between benefits and impacts narrows until steady state conditions are attained. Juniper Thinning: As the resort is developed it will both clear and thin Junipers from the Thornburgh lands. It will also thin in conjunction with the BLM, approximately 3,400 acres of Junipers on BLM lands.' The benefits to the watershed from Juniper reductions can be substantial and there are concerted efforts to reduce human induced Juniper expansion that has occurred in many areas of the west, including Deschutes and Crook Counties. Many of these efforts are supported and financed by Federal funding. While it is difficult to quantify the exact benefit to the watershed in terms of increased stream flows, the reduction in Juniper coverage has been shown to be positive. When studies show the possibility to save up to 1 AF for every 4- 5 acres of Juniper reduction, thinning thousands of acres could provide a significant benefit to nearby stream flows. 5 The 2004 USGS model estimated impacts of 100% were reached in year 80 after full pumping is begun. It will take at least 15 years, and perhaps 20-25 years until Thornburgh is fully occupied and pumping at those levels. ' Thornburgh will thin roughly 3.5 acres of Junipers for every acre of land it develops on the Thornburgh site. At the time of the WMP Thornburgh estimated that about 900 acres would be developed. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineeing.com EXHIBIT B Page 14 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (2022 FWMP) 14 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) A technical report issued by Resource Specialists, Inc. dated January 31, 2023 estimated Thornburgh's removal and thinning of Juniper trees could save as much as 304 AF of water annually from when thinning occurred. See Exhibit B. Comparison of Thornburgh's 2008 FWMP vs. the 2022 FWMP. All the OWRD mitigation in the prior FWMP was surface water flows benefitting only Whychus creek from Sister to the Deschutes River and the Deschutes River between Bend to Lake Billy Chinook. Of that mitigation water 0% was groundwater (coldest), while 62% (was 13 degrees C) Deep Canyon Creek water, with the remaining 38% being warmer, (26 degrees C) surface water from COID that provides little thermal benefits. The average temperature of the 2008 mitigation was 18 degrees C. By contrast, this 2022 FWMP is comprised of roughly 84% cold groundwater (11 degrees C), and 200 AF of LeBeau surface water (20.4 degrees C) for an average of 12.5 degrees C'. The current plan, like the 2008 FWMP, leaves cool water in the stream to mitigate for thermal impacts from the reductions of groundwater discharge into the river. The current plan, however, substantially increases the percentage of cool water mitigation from 62% to 84% and provides benefits into the affected streams, including Whychus and Deschutes included in the 2008 FWMP but also the Little Deschutes River, Indian Ford Creek, and the Crooked River that received no benefits in the prior FWMP. In short, the current plan will increase summertime flows in the critical areas while at the same reducing average stream temperatures. Regardless of where the remaining 243+/- AF (1,460- 1,217) of water rights or mitigation comes from this plan has already mitigated for the full impacts to seeps and springs.' IV. Background and Baseline The Thornburgh Resort (the "Resort" or "Thornburgh") will have no direct impact on natural surface waters; there are no such resources on the property and the proposed source of water for the Resort is ground water pumped from wells on the Resort property, to be appropriated under a series of water rights approved by the Oregon Water Resources Department ("OWRD"). Use of ground water by the Resort is expected to indirectly impact flows in the Deschutes River because of a determination of hydraulic connection between surface and ground waters in the Deschutes Basin. This determination was made by OWRD in connection with its evaluation and approval of Thornburgh's original water right authorizing the appropriation of 2,129 acre-feet of ground water for the Resort. As a result of the determination of hydraulic connection, Thornburgh was required to provide mitigation to offset projected flow reductions in the "zone of impact" identified by OWRD, in 7 206 AF of surface water including the 6 AF of DRC credits. Both plans have an additional 1.51 cfs (at least 106 AF) of cool 13 degree C TSID surface water. S If all 249 AF of additional water was from a surface water source the resulting % of total mitigation comprised of groundwater would be 69.2%, still greater than the 0% of groundwater and 61.7% of cool Deep Canyon water in the 2008 FWMP. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.caseadegeoengineering.com EXHIBIT B Page 15 of 27 FISH AND WILDLIFE MITIGATION PLAN ADDENDUM #2 (2022 FWMP) 1S RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) this case the "General Zone" of impact, consistent with OWRD's Deschutes Basin Groundwater Mitigation Program. Separate from this mitigation and, to meet Deschutes County's own No Net Loss standard found at DCC 18.133.070(D), Thornburgh voluntarily agreed to address both flow and water temperature concerns, which was to serve as a component of the mitigation measures for the original FWMP. Those measures are set out in Section V. Mitigation and Enhancement Measures of the FWMP. These and other measures added to the 2008 FWMP during the review of the Final Master Plan ("FMP") were determined to fully mitigate for any negative impacts on habitat and to achieve compliance with DCC 18.113.070(D).9 The core component of the 2008 FWMP was adding cooler water to the river upstream of areas that were important for fish habitat. Thornburgh identified Deep Canyon Creek as a source of this cooler water, which had a temperature of approximately 13 degrees C. This water, however, has historically been pumped directly from the creek for irrigation purposes before it reached the Deschutes River. Thornburgh committed to purchasing these water rights and placing them in stream to improve flows and to cool the river. In 2008, the use of this cool water made up just 62% of the total mitigation promised by the FWMP, but was found sufficient to fully mitigate for 100% of the thermal impacts to the Deschutes River (and to Whychus Creek as well according to Oregon Department of Fish and Wildlife ("ODFW")) attributable to Thornburgh's pumping. Additional impacts of 1.87 cfs10 to seeps and springs were identified in the 2008 FWMP, which planned mitigation by leaving 1.97 cfs (equal to 105% of the impacts) of the Deep Canyon water in the river upstream of areas identified as critical fish habitat. Additionally, this mitigation was determined by the ODFW to result in a net benefit to fisheries. Project opponents objected to the 2008 FWMP, claiming that no mitigation was provided to address a slight reduction in groundwater recharge to Lower Whychus Creek. Although Thornburgh and ODFW disagreed that mitigation was needed in this location, Thornburgh volunteered to provide additional mitigation specifically for Whychus Creek by funding a part of a Three Sisters Irrigation District project. The County's hearing officer accepted this offer. The Whychus Creek mitigation was opposed by a project opponent but proven to meet the No Net Loss standard and to provide additional benefits to habitat resources in Whychus Creek. This mitigation project has been completed. V. Resort Water Supply and OWRD Mitigation A. Resort Water Needs and Supply Thornburgh's water supply is groundwater from the General Zone of the Deschutes Basin Regional Aquifer and is pumped from numerous wells located within the Resort boundaries. This is a Deschutes County standard only. 11 The 1.87 cfs of impact was the total amount of impact to all seeps and springs in any location (Deschutes, Whychus, etc.) from Thornburgh pumping 2,129 AF of groundwater. Cascade Geoengineeing, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 16 Of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (2022 FWMP) 16 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) This has not changed since the Resort was first approved in 2006. The original plan anticipated 6 groundwater wells would be installed. Presently, there are 8 potential groundwater wells. However, changes to Resort infrastructure may require additional well locations to be added or moved. As was noted from David Newton in a memo dated August 24, 2021, (Exhibit C) the number or specific location of wells within the resort property has no bearing on the mitigation plan or the efficacy of mitigation to offset pumped groundwater from the Resort's property. Any well within the resort property will pump from the same regional aquifer to supply Thornburgh water for a variety of purposes, common among municipal and resort style communities in Central Oregon. Thornburgh uses to be served include domestic and commercial uses, golf course, park and landscape irrigation, reservoir/pond maintenance and fire protection. Collectively, these uses are defined by the OWRD as "quasi -municipal" uses. In 2008, the Resort's water needs at full build out were estimated at 2,129 AF per year, having consumptive use of 1,356 AF, and a maximum withdrawal rate of 9.28 cfs as shown below. As defined by OAR 690-505-0605(2), ""Consumptive use" means the Department's determination of the amount of a ground water appropriation that does not return to surface water flows in the Deschutes Basin due to transpiration, evaporation or movement to another basin." 1. Original Water Use Full Resort Build -Out WATER USE ANNUAL VOLUME CONSUMPTIVE USE Golf Courses 717 AF 645 AF Irrigation 195 AF 117 AF Reservoir Maint 246 AF 206 AF Other Q/M 971 AF 388 AF TOTALS9.28 CFS. 2,129 AF 1,356 AF Since the approval of the 2008 FWMP, issues regarding the use and conservation of water have become increasingly important to the region. As a result of this growing regional water awareness, Thornburgh has taken focused steps to reduce the Resort's water usage by roughly one third. This reduction of water use will be achieved by Thornburgh foregoing its right to develop some water intensive amenities and reducing irrigated landscaping for resort facilities and individual homes. The Resort will also implement the use of improvements in the type and method of fixtures used in Resort buildings. As a result of this Thornburgh is reducing its total water needs from 2,129 AF to 1,460 AF as shown in table 2 below. The source of Thornburgh water remains groundwater from the regional aquifer to be supplied via groundwater wells located on the Thornburgh property. All the wells Thornburgh will pump from are within the boundaries of the Resort and are pumping from the same regional aquifer, the Deschutes Formation Aquifer. The location of wells within the resort have no change to the potential effects of groundwater pumping. 2. Reduced Water Use at Full Resort Build -Out WATER USE ANNUAL VOLUME CONSUMPTIVE USE Golf Courses 501 AF 451 AF Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 17 of 27 FISH AND WILDLIFE MITIGATION PLAN -ADDENDUM #2 (2022 FWMP) 17 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUNDWATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) Irrigation 111 AF 66 AF Reservoir Maint 51 AF 43 AF Other Q/M 797 AF 319 AF TOTALS 1,460 AF 882 AF 3. OWRD Alternates to Transferring Thornburgh's Water Rights. Thornburgh has numerous applications, permits and other certificated water rights, as listed below for use as part of the Resort's water plans that may be used for consumptive water or mitigation water purposes. In addition to transferring certificated water rights to the Thornburgh property, alternatively, they can be used to mitigate for pumping of groundwater reported under any groundwater permits, or Limited License. OWRD mitigation must be in the form of legally protected water for instream use which can be accomplished in different ways acceptable to OWRD, including: i) transferring existing surface water rights for irrigation use into protected instream use; and ii) voluntary cancellation of either surface or groundwater permits in lieu of mitigation. Each method results in the full amount of pumped water allowed under the certificate to be protected permanently instream. OAR Chapter 690, Division 505 (the Deschutes Basin Groundwater Mitigation Program). Thornburgh can use a surface water certificate either way but can only cancel groundwater certificates "in -lieu" to create OWRD mitigation. Regardless of the methodology for meeting the mitigation obligation, the result is similar: the authority to pump water in one location ceases and allows water to be pumped from wells at the Thornburgh property. Mitigation is discussed in detail below. Using the certificated rights for mitigation by either cancelling the right in -lieu or transferring it instream provides at least equal benefits to streamflow and temperature as transferring the water to the Thornburgh property. Either method of providing OWRD mitigation will provide sufficient benefits to fish habitat such that there is no net loss or degradation of the resource. 4. Groundwater Permits, GW, and LL Applications: a. Ground Water Permit G-17036 — This permit authorizes up to 9.2 cfs and 2,129 AF for Quasi -Municipal uses including irrigation of golf courses, homes and commercial areas, and maintenance of reservoirs. Period of use is Year -Round except for the seasonal limits placed on irrigation use by the permit. The rate and volume are further limited by the corresponding mitigation provided. The maximum volume for irrigation of 320 acres of golf courses shall not exceed 717 AF annually. The amount of golf course irrigation specifically under this right is limited to a diversion of 2.24 AF for each acre irrigated during the irrigation season of each year. The amount of water allowed to be used for reservoirs under this permit is 246 AF. The fully developed Mitigation Obligation for this right is 1,356 AF annually, to be provided within the General Zone of Impact. Mitigation is to be provided prior to each stage of development under the permit. In 2013, Thornburgh posted 3.6 acre-feet of mitigation credits as the initial mitigation and the permit was issued. Due to unforeseen delays, Thornburgh was required to Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 18 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENOUM #2 (2022 FWMPJ 18 RELATING TO POTENTIAL IMPACTS OF TH ORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) apply for an extension of the permit, which was granted in 2018 with OWRD issuing a Proposed Final Order and Final Order granting approval. Ms. Gould subsequently filed suit against OWRD at the Oregon Court of Appeals. OWRD withdrew its final order and sent the approval (as noted in the Proposed Final Order (PFO)) to a contested case hearing. On July 26, 2022, OWRD issued a superseding proposed final order proposing denial of the extension, but the permit remains non -cancelled (valid) as of the date of this 2022 FWMP. Thornburgh has protested this PFO and is seeking a contested case hearing. Permit G-17036 is the first permit Thornburgh acquired. Due to litigation opposing the permit and the lengthy delays involved at OWRD, Thornburgh developed alternatives to pump groundwater from the Resort's wells with little reliance on this or other OWRD groundwater and limited license permits, or applications as described below. b. Ground Water Permit Application G-19139 (pending) —This permit application was for the use of 9.28 cfs of year-round Quasi -Municipal water having the same limitations and mitigation requirements as permit G-17036. It was filed at the suggestion of OWRD staff as a potential replacement to permit G-17036 pending the contested case by Ms. Gould. The POA of this application is 8 wells located on the Thornburgh property. The application is pending. If not approved, Thornburgh will file a petition for judicial review. C. Limited License Application LL-1879 -- This limited license application was for the use of 4.5 cfs of year-round water. The application was filed to provide preliminary use of some of the water permitted by G-17036 pending the resolution of the contested case on the extension. OWRD denied the application, and Pinnacle has filed a petition for judicial review in Deschutes County Circuit Court. If the limited license is approved, this will require mitigation for the life of the limited license, which can be done more informally than is required for permanent permits or certificates. d. Limited License Application LL-1917 (pending) —This limited license application was for the use of 0.453 cfs of year-round water. The amount requested is the same amount of water as will be transferred under the authority of T-13703. It was filed as an alternative to the use of the water in T-13703, as a challenge to the transfer is reviewed by the court system. The application is pending. If approved, this will require mitigation for the life of the limited license, which can be done more informally than required for permanent permits or certificates. The source of water pumped from groundwater wells located at Thornburgh is the regional aquifer residing under the Resort and throughout much of Central Oregon. The source and method of supply —or the impacts generated from withdrawal of water —does not change based upon which permit, or certificate(s) Thornburgh reports its groundwater pumping under (i.e., a transferred right, permit G-17036, or an alternate permit or certificate). OWRD rules and regulations govern the withdrawal of water from the aquifer regardless of permit or certificate number, and the impacts to that aquifer are the same regardless of the legal mechanism for withdrawal of the resource. Cascade Geoengineeiing, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineeiing.com EXHIBIT B Page 19 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUVi #2 (2022 FWPvir! 19 RELATING TO POTENTIAL IMPACTS OF THORNBURCjH'S REDUCED GROUND WATER WITI-10RAWALS ON FISH HABI r.AT August 16, 2022 (As reorganized on January 31, 2023) B. OWRD Mitigation Requirements for New Groundwater Permits Mitigation is required for new ground water permits in the Deschutes Basin under ORS 390.835 and related administrative rules in OAR 690-505-0500 et seq. This does not apply to certificated water rights that have been fully developed and need no further mitigation. The OWRD mitigation rules were adopted in response to a comprehensive study of ground water resources in the Deschutes Basin conducted by the United States Geological Survey ("USGS") and OWRD. (Ground Water Hydrology of the Upper Deschutes Basin, Oregon," USGS Water Resources Investigation Report 00-4162, 2001.) The study demonstrates hydraulic connection between the regional groundwater aquifer and surface water within the Deschutes Ground Water Study Area as shown on Figure 1. Under OWRD rules, all new ground water uses within the USGS study area are presumed to be in hydraulic connection with the Deschutes River system. The rules require mitigation to offset the impact of ground water pumping on surface water flows. In reviewing applications for new ground water rights, OWRD determines the total quantity of water to be diverted from groundwater and the amount of "consumptive use" associated with the proposed new use. The amount of mitigation required — or "mitigation obligation" — is equal to the annual amount of consumptive use. In addition to specifying the quantity of mitigation water required to offset consumptive use, OWRD identifies the "zone of impact" or location within the surface water system in which the impact of a proposed ground water use is expected to occur. Mitigation for any new groundwater permit used by Thornburgh is required in the "General Zone of Impact" which allows mitigation water to be obtained from any source in the Deschutes Basin above the Madras gage, located below Lake Billy Chinook. The broad geographic scope of the General Zone reflects findings in the USGS Study that most ground water within the basin flows toward the confluence area of the Crooked and Deschutes Rivers and discharges into the river and tributaries in an area just above Lake Billy Chinook. Initially, OWRD determined the consumptive use, and mitigation obligation of permit G-17036 to be 851.6 AF (40%, of 2,129 AF). Water Watch protested that determination and Thornburgh voluntarily agreed to increase the consumptive use of individual elements of the permit which raised the overall mitigation requirement to 1,356 AF. The application for the replacement permit, permit application G-19139 uses the same consumptive use rates applied by OWRD because of the settlement. Under OWRD rules, mitigation for new groundwater permits must be provided in advance for the full amount of water to be pumped under the new permit for each phase of development. C. Thornburgh OWRD Mitigation Plan Applicants proposing municipal or quasi -municipal water use have the option of providing mitigation in incremental units tied to specified phases of development; however, the mitigation obligation for each phase of development must be provided in full before water use may begin for that phase. Thornburgh submitted several versions of its "Incremental Mitigation Plan" Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 20 of 27 FISH .AND WILDLIFE MITIGATION PLAN - ADDENDUM #2 (2022 FWMP) 20 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) ("IMP") to OWRD as allowed by OWRD rules. Changes to the IMP may occur in the future without need for amending this plan. The IMP describes the proposed timing for meeting the mitigation obligation for Permit G-17036, developing the 2,129 AF of water uses and mitigation over several phases extending out to 2035. Because of extensive and protracted litigation and challenges to land use and water permit and transfer applications and the delays in processing the contested case on the extension of the permit, Thornburgh developed extensive additional water resources as noted in Section B above, that can be used to comply with the No Net Loss standard. Thornburgh completed funding for the TSID mitigation that has been determined to fully mitigate for groundwater reductions projected to occur to Whychus Creek based on the water use studied by Mark Yinger that overstated the water use of the Resort. This mitigation has already been provided by TSID and is described in B.6. above. At this point it is unclear how much water will be pumped from G-17036 or any alternate "NEW" groundwater or limited license permit." What is clear, however, is that the Resort has agreed to reduce its water use from 2,129 AF with a consumptive use of 1,356 AF to 1,460 AF with a consumptive use of approximately 88212 AF. More importantly, this FWMP has accounted for the maximum amount of pumping that could occur of 1,460 AF and is providing mitigation that meets or exceeds the no net loss standard. Thornburgh will be required to provide mitigation for this amount of water when due, which is before pumping consumptive water for an approved resort use. Thornburgh's maximum water use is capped to 1,460 AF, which is less than 1/100t" of 1% of all current water use (approximately 750,000 AF) in the Deschutes Basin. The certificated, fully mitigated water rights above, except for the Dutch Pacific water rights, have been or are being transferred to the Thornburgh wells. The transfers will change the place of appropriation and use. The first of these, Transfer T-13703, was approved transferring 327.5 AF of quasi -municipal water from a well in west Bend to the Thornburgh wells. The total amount of the planned transfers, including T-13703, if approved, is 1,161 AF. In the alternative the 1,161 AF of certificated water rights could be cancelled (both the groundwater and surface water rights) or transferred instream (just the surface water rights) for mitigation credits. All this water would comply with the OWRD mitigation rules if used in that manner.13 Certificate 89259 (2. E. above) for 49.5 AF is being cancelled in lieu of mitigation. When all the transfers or cancellations are done, Thornburgh will need to obtain a relatively small amount of additional water rights to transfer to its property or to use as mitigation. Because of the efficacy of the present plans, most critically is the fact that the 1,217 AF14 already mitigates for 119% (w/out the TSID or 198% with it) of the impacts to springs and seeps15, and that the source of remaining It is unnecessary to determine this at this time as the source of water must remain the same, the Deschutes Regional aquifer. DCC 18.113.070(K). However, the mitigation for impacts to habitat based upon withdrawal from that source are the subject of this document. 12 Applying OWRD standard practice of 40% to QM permits would result in consumptive use of 584 AF. This plan provides mitigation far more than that amount. 13 As the basic premise of the mitigation program was to halt expansion of water use in the Deschutes basin, it cannot allow for expansion of use and must instead be permanently instream. 14 Including the DRC credit. is This is regardless of how the water is used. The analysis of the ratio of cool water mitigation is provided below. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 21 of 27 F15H AND WILDLIFE_ MITIGATiON PLAN - ADDENDUM #2 (2022 FWMP) 21 RELATING TO POTENTIAL IMPAC'rS OF TI-1ORN3URGH'S REDUCED GROUND WATER WI rHDP,AWX1 LS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) water coming from within the General Zone of Impact will not create an adverse impact on the fisheries habitat. Of the certificated water rights described above, Thornburgh owns 1,211 AF16 that at the time of this report it is not pumping. 200 AF of that is surface water that is not being pumped from the river south of LaPine while 1,011 AF remains in the aquifer to flow to the streams, including the Deschutes River, Whychus Creek, and the Crooked River to increase flows and provide thermal benefits, long before the resort creates any impacts on the stream. This "advance" or "excess mitigation" accumulates for years until the impacts are fully felt in the stream. As is discussed in more detail below this excess mitigation accumulates to a substantial amount." D. Groundwater Withdrawals and Quality Mitigation In other resort approvals, OWRD mitigation only" was accepted as providing the entire mitigation needed to meet this standard for fish habitat. In the case of Thornburgh Resort, this standard has been redefined to require "water quality' mitigation. This was required despite the fact that all groundwater pumping in the Deschutes Basin affects groundwater discharges which impact stream flows. OWRD mitigation, by design, increases streamflow by either increasing groundwater discharge into the stream (groundwater mitigation) or by leaving water in the stream (surface water mitigation) which typically has the benefit of reducing river and creek temperatures. Increasing streamflow is the main purpose of the OWRD mitigation program. It is also a primary purpose of many of the basin's environmental actions and restoration programs. NCI noted this in the 2015-2017 remand of the FMP relating to TSID mitigation for Whychus Creek. Flow volumes in the upper Deschutes River are an important component of the current Habitat Conservation Plan for the Oregon Spotted Frog. Flow volume guarantees set to protect the frog have created substantial impacts on the operation of the basin's irrigation districts and a tremendous burden on some of farmers within the basin, including North Unit Irrigation District. Opponents of Thornburgh have typically focused on groundwater as it relates to its ability to affect streamflow, particularly the thermal conditions or "quality" of the remaining flow resulting from groundwater pumping. More specifically, opponents have focused on the location of the impacts to the area below Lower Bridge on the Deschutes River and lower Whychus Creek. However, these areas are where discharge of significant amounts of cold groundwater discharge into the Deschutes River, Crooked River and Whychus Creek, dramatically lowering stream temperatures and resulting in improved water quality. 16 The 937 AF currently left instream presently does not include the 106 AF of TSID water in Whychus Creek currently flowing from the TSID diversion to the mouth of the creek and into the Deschutes River. 17 Thornburgh may allow farmers affected by the Habitat Conservation Plan and/or drought conditions to use some portion of water it doesn't currently need to authorize pumping on a temporary basis. When providing water for farm drought relief, that portion of Thornburgh's water will not be instream. 11 Meaning standard mitigation credits issued in conjunction with the Deschutes Groundwater Mitigation program. Cascade Geoengineeiing, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 22 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM. #2 (2022 FLYMP) 22 RELATING TO POTENTIAL. IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) In the original FWMP, groundwater withdrawals were mitigated for by providing surface water in the Deschutes River and its Deep Canyon Creek and Whychus Creek tributaries. In the case of the Deep Canyon Creek mitigation, surface water mitigation was justified in the 2008 FWMP because the creek itself is spring fed. While it is true that this water is cool, the surface water is heated (from approximately 11 degrees to 13 degrees) as it flows down the creek prior to discharge into the Deschutes River. In 2008, Tetra Tech's Mass Balance Analysis19 reported minor thermal impacts (temperature increases) may occur in the Deschutes River. With Thornburgh's 2008 mitigation measures, Tetra Tech's analysis estimated a temperature change of 0.00 degrees. C at Lower Bridge, 0.10 degrees C at Steelhead Falls, and 0.1 degrees C below the mouth of Whychus Creek. Even though there was an 0.1 degree C increase in temperature (impact) in the critical fish habitat at Steelhead Falls and below Whychus Creek, the mitigation plan was approved as meeting the No Net Loss standard. In the case of Whychus Creek, project opponents argued that slight groundwater withdrawals that occurred in both the upper and lower parts of the Creek impacted lower Whychus Creek. Opponents claimed it to be an area of critical fish habitat because it receives substantial cold groundwater discharges from the regional aquifer. The 2008 hearings officer expressed concerns about the creek during the peak summertime temperatures. While Thornburgh disagreed that mitigation was needed for Whychus Creek, it offered a solution to increase flows with the use of surface water. The solution was to leave 106 AF of cool mountain water in the creek from a point south of Sisters that would otherwise be pumped by TSID. The use of this TSID mitigation was challenged by a single project opponent. It was, however, approved because it was shown to achieve compliance with the No Net Loss standard based on an analysis of the impact of TSID mitigation water on temperatures in lower Whychus Creek. This mitigation also provides substantial additional thermal benefits to the middle and upper parts of the creek that were not even considered to meet the standard due to the limited scope of the review on remand. The NCI memo from October 2017 shows the maximum thermal impacts to lower Whychus Creek without mitigation, during the peak summertime temperatures and the creek at its lowest flow, to be 0.0042 degrees C. This 4/1,000`ns of a degree is far less than what can be measured using technology available today. With the TSID surface water mitigation, the temperature was lowered in Whychus Creek (lowered by approximately 0.001 or 1/1,000th of a degree, again in an amount too small to be measured)20. Three Sisters Irrigation District has completed the project, and Thornburgh has fulfilled its agreement to provide this the water which is now instream. While Yinger 2008 noted roughly 13% of the flow reduction impacts would be felt in the Crooked River, neither Yinger nor ODFW voiced concerns about thermal impacts there. This may be because of the large groundwater discharges in the area and the fact that the temperatures of the groundwater discharging into the Crooked River at Opal Springs and 19 Tetra Tech overstated impacts by allocating 100% of the impacts of 1,356 AF consumption into the Deschutes River which was not accurate. Yinger 2008 report stated lower % impacts, and when corrected the result is lower thermal impact. 20 Since the amounts cannot be measured, they cannot be verified and are simply theoretical. As such, whether positive or negative they are considered as no change. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineeting.com EXHIBIT B Page 23 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM ##2 (2022 FWMP) 23 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) Osborne are warmer (between 11.6 and 13.7 degrees C21) than the discharges noted into the Deschutes or Whychus (around 11 degrees C). See Exhibit 6, OWRD Spring Temp. Still, to better understand any thermal impacts to the Crooked River from Thornburgh pumping, Newton undertook mass balance analysis of the 2008 mitigation plans comparing that to the current 2022 plans. In the CGE memo dated August 12, 2022, impacts to the Crooked River were analyzed based on the Yinger 2008 report using both the 2008 FWMP mitigation and Thornburgh's current plans. Both scenarios used the OWRD temp data, Yinger 2008 impacts, and recorded flows at Opal Springs and Osborne. The 2008 FWMP had no Crooked River mitigation. All mitigation was Deschutes River and Whychus Creek surface water mitigation. The 2008 plan resulted in very slight temperature increases of between 0.0001 to 0.0017 degrees C. The 2022 plan used the same inputs but included mitigation that came from the cessation of pumping BFR groundwater, some of which impacts the Crooked River. As a result, the 2022 plan results in even smaller temperature increases, ranging from between 0.0000 to 0.0004 degrees C. Although the 2008 FWMP allows more than 4 times the thermal impacts of this 2022 Plan, the thermal impacts range from between ZERO to 4/10,000th, of a degree C. None of these amounts can be measured and as such are considered as no change scientifically. They have been described as having no impact on fish habitat22. Subsequent analysis was done by Four Peaks and Newton to detail the impacts on the Crooked River. The resulting thermal impacts are 0.00 degrees C at both Opal Springs and Osborne Canyon. In both cases, the resulting benefits are too small to physically measure. E. Fish Habitat Potentially Affected by Ground Water Use During the consultation process in 2008, ODFW identified two specific concerns with respect to potential impacts of ground water pumping on fish habitat: First, the potential for flow reduction due to hydraulic connection that could impact flows necessary for fish and wildlife resources in the Deschutes River system; and second, the potential for an increase in water temperature as a result of flow reductions from ground water pumping. In preparation for this 2022 FWMP Thornburgh discussed the changes with ODFW to understand what areas would currently be of concern. While the area from Lower Bridge to Lake Billy Chinook on the Deschutes is still important, other areas were also of concern. This included flow limitations on the Deschutes River from Bend to Lower Bridge, on Whychus Creek from Camp Polk Road upstream to Sisters, and in Indian Ford Creek, that empties into Whychus Creek. This plan takes those areas into account. In the 2008 process, ODFW identified six species of fish that could potentially be impacted: Redband Trout, Bull Trout, Brown Trout, Mountain Whitefish, Summer Steelhead and Spring Chinook. While relevant to consider, more important is the habitat itself. In Gould v. Deschutes County, 233 Or App 623, 227 P3d 758 (2010) the Oregon Court of Appeals found that the no net loss standard refers to habitat, stating: 11 As recorded by OWRD staff and noted in Exhibit 6. 22 Tetra Tech in their 2017 report, page 8, cited the EPA 2003 report which noted that temperature changes less than 0.25 degrees C were of no consequence to fish. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 24 of 27 FISH AND WILDLIFE MITIGATION PLAN - ADDENDUM #2. (2022 FWMP) 24 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) "Thus, the context of DCC 18.113.070(D) strongly suggests that "fish and wildlife resources" refers not to species of fish and wildlife, but to the habitat that supports fish and wildlife. In light of that context, we conclude that DCC 18.113.070(D) allows a focus on fish and wildlife habitat to establish that "[a]ny negative impact on fish and wildlife resources will be completely mitigated so that there is no net loss or net degradation of the resource." That standard may be satisfied by a plan that will completely mitigate any negative impact on the habitat that supports fish and wildlife, without showing that each individual species will be maintained or replaced on a one-to-one basis." In its consultation with Thornburgh regarding these issues, ODFW recognized that the OWRD groundwater mitigation program was specifically designed to identify and mitigate for the impacts of flow reduction because of new groundwater pumping in the basin. Although the OWRD rules and USGS study on which the rules are based do not directly address temperature issues, ODFW also recognized that with the flow replacement required under OWRD rules the potential impact to temperature because of the Thornburgh project — or any similar individual project — is expected to be negligible. However, ODFW expressed a concern about the potential for cumulative impacts from on -going groundwater development in the basin, over time. Although cumulative impacts may be a concern, Thornburgh does not need to mitigate for the impacts of others in order to achieve compliance with the No Net Loss/Degradation standard. That standard is based solely on impacts created by Thornburgh's pumping which were acknowledged to be negligible in 2008. In early correspondence on this issue, ODFW identified concerns about potential impacts on cold water springs and seeps in the Whychus Creek sub -basin because of Thornburgh's groundwater use. Following consultations with OWRD staff and the Department of Environmental Quality and their own internal review, ODFW determined the type of habitat potentially affected by the Resort in Whychus Creek would be classified, for purposes of commenting on the Resort's FMP application, as Habitat Category 2. This conclusion was based on ODFW's determination that temperature impacts to stream flow, if present, can be mitigated with appropriate actions. As used in the ODFW Mitigation Policy, "Habitat Category 2" describes essential habitat for a fish or wildlife species. Mitigation goals for this category of habitat, standards that do not apply to the County's review of the FWMP, are no net loss of either habitat quantity or quality and to provide a net benefit of habitat quantity or quality. OAR 635- 415-0025(2). ODFW reviewed the 2008 FWMP and determined that it would, without placing TSID mitigation water in Whychus Creek, offer a net benefit for fish habitat. Nonetheless, TSID mitigation water was required by the County's hearings officer. This led to legal challenges from Annunziata Gould who claimed the mitigation water was "hot water" that would harm fish habitat in lower Whychus Creek. Ms. Gould also argued on appeal of the FMP and 2008 FWMP, without success, that temperature impacts (of .1 degree C) to the Deschutes River violated the no net loss standard. As a result of the Gould challenges, NCI undertook extensive mass balance analysis in 2015-2017 of the impacts on Whychus Creek without mitigation that showed maximum thermal impacts of 0.004 degrees C in Whychus Creek under the peak summertime temperatures and the lowest Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Page 25 of 27 FISH AND WILDLIFE MITIGATION PLAN- ADDENDUM #2 (2022 FWMP) 25 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) summertime flows. It also provided an analysis of the TSID mitigation. The analysis showed that keeping water instream in upper Whychus Creek offsets the thermal impact of groundwater pumping by the resort and slightly reduces the temperature of water in lower Whychus Creek, more than 15 miles downstreaM13. The NCI studies resulted in affirmance of the FWMP because it demonstrated compliance with the no net loss standard. The principle illustrated by the results of the 2015-2017 studies — that increasing the flow of rivers and streams upstream by not diverting for irrigation use both increases volume and lowers temperatures downstream — is also adopted in this 2022 FWMP. From the point that surface water withdrawals cease and aren't being pumped from surface water and from the point where previously pumped groundwater no longer being pumped is discharged into rivers and streams, increasing flows reduce thermal impacts, which in turn lowers stream temperatures from that point of discharge on downstream. VII. CONCLUSION DCC 18.113.070.D requires that any negative impact on fish and wildlife resources be completely mitigated so that there is no net loss or net degradation of the resource. This Addendum to the Thornburgh Wildlife Mitigation Plan, referred to as the 2022 FWMP, amends the 2008 FWMP (as it was updated) and addresses potential impacts to fishery resources because of ground water pumping and identifies specific mitigation measures. The potential for loss of habitat due to reduced surface water flows was quantified in connection with the OWRD review of Thornburgh's application for a water right permit. Under OWRD rules, Thornburgh is required to fully mitigate for consumptive use associated with Resort development. Consumptive use represents the amount of water not otherwise returned to the Deschutes River system after initial appropriation or diversion. The OWRD mitigation program is based on estimates of impact and modeling, the program is specifically intended to replace stream flows lost due to groundwater use. The 2008 FWMP was developed in consultation with ODFW to address two specific areas of concern regarding the potential for negative impacts: the potential for a loss of habitat due to reduced surface water flows in the impacted areas, and the potential for loss of habitat due to increased temperature from reduced stream flow or loss of inflow from springs. As part of the development of this plan, discussions with ODFW took place to understand the current priorities to ODFW to protect species and related habitat. While the area of the Deschutes River from Lower Bridge to Lake Billy Chinook remained important to ODFW, other issues presented concerns to the agency. ODFW expressed concern with limited flows of the Deschutes River between Bend and the Lower Bridge area, and of Whychus Creek between Sisters and Camp Polk Road and in Indian Ford Creek. Also important to ODFW was the distance in the stream the mitigation change will improve, as longer stream reaches are better. As described above this 2022 FWMP has numerous sources providing benefits and mitigation, several that provide benefits over a significant distance, including areas of concern to ODFW. 23 The TSID mitigation reduced temperatures slightly throughout Whychus Creek starting from the TSID diversion where the water was left in stream. Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT 3 Page 26 of 27 FISH AND WILDLIFE MITIGATLON FLAN - ADDENDUM #2 (2022 FWMP) 26 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S ,REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) For example: 1) the LeBeau water increases flow in the Deschutes River for 137.7 miles; 2) The Tree Farm water is cold groundwater discharges that increase flows in the Deschutes River from Bend downstream through the stretch of concern to ODFW and onto the lake; 3) The Dutch Pacific water is benefitting Indian Ford Creek and Whychus Creek around Sisters to the mouth; 4) TSID water adds cool surface water above Sisters to the mouth of Whychus Creek at the Deschutes River. All of these sources increase flows that add to the thermal mass which in turn reduces temperatures in their respective stream and river reaches, ultimately providing benefits down to Lake Billy Chinook. The potential for an increase in stream temperature resulting in a negative impact to fish and wildlife resources was also evaluated. Regarding Whychus Creek, the TSID water was shown to fully mitigate any potential peak temperature impact and lower the stream temperatures in not only Lower Whychus Creek, but throughout Whychus Creek to the mouth, which includes the area of concern to ODFW. Increasing the groundwater discharges from the Dutch Pacific water will further increase the reduction in temperature and the thermal benefits being provided to Whychus Creek. Regarding the Deschutes River, the 2008 FWMP increased flows between Bend and Lake Billy Chinook by adding warmer surface water in Bend and cooler surface water from Lower Bridge to Lake Billy Chinook. These additions resulted in temperature change of 0 degrees C above Lower Bridge down towards Steelhead Falls, and an increase in the temperature of 0.1 degrees C at Steelhead Falls to below Whychus Creek. Even with those slight increases in temperature providing cool water mitigation equal to 105% of the impacts to seeps and springs fully mitigated for any reduction in groundwater. Increasing the percentage of benefits to seeps and springs coming from cool water sources (includes groundwater, Deep Canyon Water, TSID water) to 195% presently from 155% in the 2008 FWMP naturally provides far greater benefits than previously approved. In developing recommendations for this plan, it was clear any potential change in stream temperature attributable to Thornburgh's proposed ground water use under steady state conditions, whether positive or negative, would be at levels not measurable with available equipment and technology. Although the changes being discussed will, in almost all cases, result in an increase in stream flows and a reduction in stream temperatures, they are not significant enough to result in any quantifiable negative impact to fish habitat at any time. However, the massive influx of excess flows provided during the transient period will further increase stream flows and further lower temperatures in all the affected reaches for decades into the future as the actual impacts to stream flows gradually increase from Thornburgh's groundwater pumping until steady state conditions are attained. By committing to fully utilize the water sources as described herein, and to comply with the conditions of this 2022 FWMP, any potential negative impacts to fish habitat resources because of the Thornburgh Resort development will be completely mitigated such that there is no net loss or degradation of habitat quantity or quality. In fact, it will likely provide a slight net benefit when steady state conditions are achieved many decades from now. During the transient period, Thornburgh will provide significant additional benefits to the quantity and quality of fish Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineering.com EXHIBIT B Rage 27 of 27 FISH AND WILDLIFE MITIGATION PLAN -ADDENDUM #2 (2022 FWMP) 27 RELATING TO POTENTIAL IMPACTS OF THORNBURGH'S REDUCED GROUND WATER WITHDRAWALS ON FISH HABITAT August 16, 2022 (As reorganized on January 31, 2023) and aquatic habitat. As such this 2022 FWMP will exceed the no net loss/degradation standard set by DCC 18.113.070(D). Cascade Geoengineering, LLC 21145 Scottsdale DR, Bend, Oregon 97701 360-907-4162 www.cascadegeoengineciing.com �h��v1 E S COG BOARD OF COMMISSIONERS BOARD OF COUNTY COMMISSIONERS MEETING 9:00 AM, WEDNESDAY, MARCH 29, 2023 Barnes Sawyer Rooms - Deschutes Services Bldg - 1300 NW Wall St - Bend (541) 388-6570 1 www.deschutes.org MEETING FORMAT: In accordance with Oregon state law, this meeting is open to the public and can be accessed and attended in person or remotely, with the exception of any executive session. Members of the public may view the meeting in real time via the public meeting portal at www.deschutes.org/meetings. To view the meeting via Zoom, see below. Citizen Input: The public may comment on any meeting topic that is not on the current agenda. To provide citizen input, submit an email to citizeninput@deschutes.org or leave a voice message at 541-385-1734. Citizen input received by noon on Tuesday will be included in the meeting record for topics that are not on the Wednesday agenda. If in -person comment from the public is allowed at the meeting, public comment will also be allowed via computer, phone or other virtual means. Zoom Meeting Information: This meeting may be accessed via Zoom using a phone or computer. • To join the meeting from a computer, copy and paste this link: bit.ly/3h3ogdD. • To join by phone, call 253-215-8782 and enter webinar ID # 899 4635 9970 followed by the passcode 013510. • If joining by a browser, use the raise hand icon to indicate you would like to provide public comment, if and when allowed. If using a phone, press *6 to indicate you would like to speak and *9 to unmute yourself when you are called on. 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, call (541) 388-6572 or email brenda.fritsvold@deschutes.org. CALL TO ORDER PLEDGE OF ALLEGIANCE CITIZEN INPUT: Citizen Input may be provided as comment on any topic that is not on the agenda. Note: In addition to the option of providing in -person comments at the meeting, citizen input comments may be emailed to citizeninput@deschutes.org or you may leave a brief voicemail at 541.385.1734. To be timely, citizen input must be received by noon on Tuesday in order to be included in the meeting record. CONSENT AGENDA 1. Consideration of Approval of Board Order No. 2023-012 to authorize a loan assumption, and to authorize the Deschutes County Property Manager to execute the necessary documents to complete the loan assumption 2. Notice of Intent to Award for Juvenile Justice Remodel 3. Consideration of Document No. 2023-330, Amendment No. 3 to an Intergovernmental Agreement with the Oregon Department of Transportation for the US20: Tumalo - Cooley Road Project 4. Second Amendment to Ground Lease with Mountain View Community Development 5. Consideration of Board Signature on letter appointing Jim Starnes for service on the Deschutes County Facility Project Review Committee. 6. Approval of Minutes of the March 8 and 20, 2023 BOCC Meetings 7. Approval of Minutes of the March 10 and 17, 2023 Legislative Update Meetings ACTION ITEMS 8. 9:10 AMFinal Decision for a Commercial Activity in Conjunction with Farm Use (Meadery) in the Exclusive Farm Use Zone (File nos. 247-22-000024-CU, 025-SP, 757-A, 914-A) 9. 9:25 AMConsideration of Approval of Board Order No 2023-014, to authorize the sale of an 8.35-acre property in Redmond nown as Map and Tax Lot 151329BB00300 to the City of Redmond, and to authorize the Deschutes County Property Manager to execute the documents associated with the sale. 10. 9:35 AMDeliberations: Board Review of Two Appeals for a Modification Request to the Thornburgh Destination Resort's Fish & Wildlife Mitigation Plan ("FWMP"). March 29, 2023 BOARD OF COUNTY COMMISSIONERS MEETING Page 2 of 3 LUNCH RECESS 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. EXECUTIVE SESSION At any time during the meeting, an executive session could be called to address issues relating to ORS 192.660(2)(e), real property negotiations, ORS 192.660(2)(h), litigation; ORS 192.660(2)(d), labor negotiations, ORS 192.660(2)(b), personnel issues, or other executive session categories. Executive sessions are closed to the public, however, with few exceptions and under specific guidelines, are open to the media. ADJOURN March 29, 2023 BOARD OF COUNTY COMMISSIONERS MEETING Page 3 of 3