2025-420-Order No. 2025-057 Recorded 12/10/2025REVIEWED
LEGAL COUNSEL
I
Recorded in Deschutes County CJ2025-420
Steve Dennison, County Clerk
Commissioners' Journal 12/10/2025 11:12:10 AM
c 2025-420
For Recording Stamp Only
BEFORE THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON
An Order Consenting to the City of Bend
Sequential Urban Growth Boundary * ORDER NO. 2025-057
Components Review Process
WHEREAS, State law requires cities to provide 20-year supplies of buildable land for needed
housing and economic opportunities in their urban growth boundaries (UGB); and
WHEREAS, the evaluation of a UGB's capacity for both needed housing and economic
opportunities must be based upon 20-year population forecasts per OAR 660-024-0040, and
related analyses, including the Housing Capacity Analysis and Economic Opportunities Analysis,
which must be approved by the Oregon Department of Land Conservation and Development
(DLCD); and
WHEREAS, a city of more than 2,500 in population that estimates a UGB amendment of
greater than 50 acres may request and coordinate with the Director of DLCD to schedule work
tasks in a manner that allows DLCD to review those tasks sequentially and either approve or
remand each, per ORS 197.626(3) and OAR 660-025-0185; and
WHEREAS, OAR 660-025-0185 requires the county to consent to the sequential review
process and the department work plan and submit a written notice of election; and
WHEREAS, the City of Bend's current population exceeds 104,000 people, and a future UGB
amendment is estimated to require land for both needed housing and economic opportunities
that exceed 50 acres in size, based on the 2023 Draft Housing Capacity Analysis funded by a grant
from DLCD; and
WHEREAS, the proposed work program for DLCD, attached as Exhibit A, outlines the
recommended division of work tasks into packages to update the Buildable Lands Inventory,
Economic Opportunities Analysis, and Housing Capacity Analysis, and obtain DLCD approval of
ORDER No. 25-057
each document sequentially to build on each report and ultimately update the Bend
Comprehensive Plan policies and adopt a UGB amendment to support Bend's growth from 2029-
2049; and
WHEREAS, the Bend City Council adopted Resolution No. 3454 on November 19, 2025,
opting to use the Sequential UGB process as provided in ORS 197.626(3) and OAR 660-025-0185,
and proposes the draft work program attached as Exhibit A; and
WHEREAS, the City of Bend has requested that Deschutes County adopt an order
consenting to the use of the Sequential UGB process and participation in a joint notice of election
to DLCD; now therefore
THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON, HEREBY
ORDERS as follows:
Section 1. Deschutes County consents to the Sequential UGB Process proposed by the
City of Bend, as provided in ORS 197.626(3) and OAR 660-025-0185, and in the draft work program
attached as Exhibit A.
Section 2. County staff are directed to undertake all steps necessary to implement this
decision, including joint submittal of the notice of election, and participation in prescribed work
plan tasks.
DATED this day of • , 2025.
ATTEST:
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BOARD OF COUNTY COMMISSIONERS
ANTHONY DeBONE, Chair
PATTI ADAIR, Vice Chair
PHIL CHANG, Commissioner
ORDER No. 25-057
BD
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CITY OF BEND
EXHIBIT A
Proposed Work Plan and Planning Period for OAR 660-025-0185
Sequential UGB Components Review
City of Bend and Deschutes County
Proposed Planning Period
The City is proposing 2029-2049 as the 20-year planning period for Urban Growth Boundary
(UGB) assessment and amendment. The overall work program includes five Adoption Packages
of which two will be electing sequential approvals. The Adoption Packages are:
• Adoption Package 1— Contextualized Housing Needs Analysis (CHNA)
• Adoption Package 2 — Buildable Lands Inventory (BLI), Economic Opportunities
Analysis (EOA), Housing Capacity Analysis (HCA) Phase 1
• Adoption Package 3 — HCA Phase 2, Efficiency Measures (including designation of
Climate Friendly Areas) and UGB Amendment
• Adoption Package 4 — Housing Production Strategy (HPS)
• Adoption Package 5—Transportation System Plan (TSP)
The items highlighted in bold and underlined above are detailed below in the sequential
approval work program. The work to be completed under this work plan will be fully consistent
with applicable rules and statutes as of January 1, 2026.
Proposed Sequential Review Work Program
1. Adoption Package 2 deliverables: BLI, OAR 660-024-0050; EOA, Oregon Revised Statute (ORS)
197.712(2); OAR Chapter 660, Division 009 and HCA Phase 1, OAR 660-008-0045, ORS
197A.270(1)-(4)
Proposed timeline (included for reference; not part of the work plan OAR 660-025-0185(2)):
Begin by 04/01/2026, adopt and submit to DLCD for approval by 09/30/27
a. City
o BLI - Complete appropriate modeling analysis to determine available land in a
combined residential and employment lands inventory.
• The residential lands BLI will include a development -ready lands inventory, as
required by the forthcoming Oregon Housing Needs Analysis (OHNA) rules at
ela ..1 11: $ :1
Exhibit "A" to Resolution
M
CITY OF BEND
o EOA -Identify the City's need for employment land and sites in alignment with
adopted 2025 Target Sector Analysis. This will include the land needs for public
facilities that serve as places of employment.
o HCA Phase 1- Determine the baseline housing capacity of the existing Urban Growth
Boundary (UGB) and potential capacity shortfall consistent with ORS 197A.270(1)-(4)
and OAR 660-008. This includes a housing needs projection, inventory of buildable
lands (see BLI above), determination of capacity based on historical density analysis,
development trends, market factors, and assumptions, and evaluation of trends,
impacts and efficiency measures, and determination of housing types that are likely
to be affordable to current and future households. The HCA will consider the future
land needs for public facilities located in residential areas such as schools and parks.
o The work plan includes a CHNA, beginning by 04/01/2026 with local adoption by
03/30/27. The CHNA is anticipated to be reviewed by DLCD under a segmented
review, prior to the adoption of a housing capacity analysis and housing production
strategy, as allowed under OAR 660-008-0080(2).
o Notice to DLCD pursuant to OAR 660-025-0140 and OAR 660-025-0185(5).
o Update appropriate Comprehensive Plan text, policies, and technical appendices
related to adoption products.
o Review BLI, EOA and HCA phase 1 prior to Local Adoption.
o DLCD Director review within 90 days pursuant to OAR-660-025-0150.
2. Adoption Package 3 deliverables: HCA Phase 2, OAR 660-008-0045, ORS 197A.270(5-6);
Efficiency Measures including Climate Friendly Area designation and UGB evaluation, ORS
197A.285, OAR 660-024.
Proposed timeline (included for reference; not part of the work program per OAR 660-025-
0185(2)): Begin by 01/01/2027, adoption and submittal to DLCD for review by 03/31/2029
a. City
o HCA Phase 2 - Identify the actions needed to accommodate allocated housing
need for which there is insufficient capacity.
o UGB Study - Perform land evaluation and use combined land need analysis from
previous tasks to determine scope of potential UGB expansion pursuant to OAR
660-024-0067.
o UGB Scenarios - Identify efficiency measures, including designating Climate
Friendly Areas, and potential UGB expansion areas to provide for needed housing,
Exhibit "A" to Resolution
0
CITY OF BEND
employment, and other urban uses such as public facilities (streets and roads,
schools, parks, and open space) over the 20-year planning period.
o Notice to DLCD pursuant to OAR 660-025-0140 and OAR 660-025-0185(5)
o Complete UGB Amendment
■ Complies with Statewide Goals, Statutes, and Rules.
■ Develop Framework Plan for UGB lands with Comprehensive Plan Map
designations and proposed land uses.
■ Revise and update remaining Comprehensive Plan chapters.
■ Post Acknowledgement Plan Amendment to Comprehensive Plan and
development code adoption by Bend City Council via ordinance.
b. County
o Adoption of City UGB amendment into County Comprehensive Plan pursuant to
ORS 197.628 to ORS 197.650 and OAR 660-025-0175.
c. DLCD
o Review HCA Phase 2 and UGB land evaluation, preferred scenario, CFA
designations, Comprehensive Plan text and policies.
Exhibit "A" to Resolution
City of Bend, Oregon
Deschutes County, Oregon
Written Notice to Use the Sequential UGB Components Review Process
Under ORS 197.626(3) and OAR 660-025-0185
Introduction
ORS 197.626(3) and OAR 660-025-0185(1) & (2) provide the framework for "sequential
review" relevant to Urban Growth Boundary (UGB) amendment components. These
provisions allow the City of Bend to submit the necessary deliverables for a UGB
amendment separately to the Department of Land Conservation and Development
(DLCD) for their review and approval one at a time and undertake a UGB amendment at
the end, based on the approved deliverables.
This document is the Joint Notice of Election from the City of Bend and Deschutes
County and proposes a planning period and work program as required by OAR 660-
025-0185.
Findings to Support City's and County's Decision to Use Sequential Review.
A city and a county that desire to use the sequential review process must show that the
following conditions under OAR 660-025-0185 have been met.
9. The City and County must concur that the final UGB amendment is likely to
exceed 50 acres.
FINDING: The City of Bend, working with ECO Northwest, completed a draft Housing
Capacity Analysis in 20231. This analysis concluded that the City would have a deficit of
240 to 700 acres of land to accommodate the 20,218 units of needed housing identified
at the time of the study, based on scenarios with different proportions of middle and
multi -unit housing. This land need estimate for housing could be greater given the
Oregon Housing Needs Analysis (OHNA) updated projection identifies 33,763 units of
housing needed in Bend over the next 20 years which accounts for growth,
underproduction, second homes, and units needed for the unhoused population.
1 The draft report can be found online here -
https://www.bendorecion.gov/home/showpublisheddocument/56418/638252019592070000. City staff
presented the results to the City Council at their July 19, 2023, meeting. The Power Point Slides can be
found here: https://bend.granicus.com/MetaViewer.php?view id=9&clip id=758&meta id=69013
The presentation recording can be found here: https://bend.granicus.com/player/clip/758?meta id=69011.
In addition, the City has adopted changes to its Comprehensive Plan and Zoning Map
that have reduced the number of acres planned and zoned for industrial and other
employment uses in the Southeast Expansion Area. In 2021, the City Council approved
the Southeast Area Plan, which resulted in 38 acres of industrial land and 28.5 acres of
commercial land being re -designated for other uses. The City committed through Policy
6-23 in Chapter 6, Economy, and Policies 11-103 and 11-104 of Chapter 11, Growth
Management, of the Bend Comprehensive Plan to re-evaluate whether these acres of
industrial and commercial land are still needed and must be replaced during an update
to the City's Economic Opportunities Analysis. The City and the County find that the final
UGB amendment supported by this sequential process will likely exceed 50 acres.
2. The City and County must submit written notice of election to use the
sequential process in OAR 660-025-0185 to DLCD prior to submitting any
component for review.
FINDING: The City of Bend adopted Resolution 3454 to use the Sequential Approval
process on November 19, 2025. Deschutes County adopted Order 2025-057 on
December 3, 2025, supporting use of Sequential Review. No component has yet been
submitted to DLCD for review. By the signature of their authorized representatives
below, the City and County jointly elect to use the sequential process in OAR 660-025-
0185 to obtain approval of components needed to support an amendment to the Bend
UGB.
3. The Notice of Election must propose the planning period for the amendment
and include a draft work program.
FINDING: The City understands that, based on OAR 660-025-0185, DLCD will prepare
a final work program following submission of this joint written notice of election. The City
proposes 2029-2049 as the planning period for the potential UGB amendment. A draft
work program is included as Exhibit A.
Authorized City Representative
Eric King, City Manager
City of Bend
Authorized County Representative
r
Nick Lelac , CountyAdminis ator
Deschutes County
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BOARD OF
COMMISSIONERS
MEETING DATE: December 3, 2025
SUBJECT: Consideration of Order 2025-057: Consent to City of Bend Sequential Review
UGB Process
RECOMMENDED MOTION:
Move to adopt Order No. 2025-057 consenting to the City of Bend Sequential Review
process for Urban Growth Boundary Amendment Components.
BACKGROUND AND POLICY IMPLICATIONS:
Staff will present Order No. 2025-057 to the Board of County Commissioners for its
consideration.
BUDGET IMPACTS:
None
ATTENDANCE:
Nicole Mardell, AICP, Senior Planner
Damian Syrnyk, AICP, Senior Planner - City of Bend
ol ES C G
COMMUNITY DEVELOPMENT
MEMORANDUM
TO: Deschutes County Board of Commissioners
FROM: Nicole Mardell, AICP, Senior Planner
Will Groves, Planning Manager
DATE: December 3, 2025
SUBJECT: Consideration of Order 2025-057: Consent to City of Bend Sequential Review
UGB Process
On December 3, 2025, staff will present Order No. 2025-057 to the Board of County
Commissioners (Board) for consideration. The City of Bend is requesting consent to elect to
use Sequential Review for components of the City's Urban Growth Boundary (UGB)
Amendment process.
1. BACKGROUND
The City of Bend is initiating an update to its growth plan and a UGB amendment to support
the next 20 years of growth in Bend. The City is proposing a sequential review work plan to
the Oregon Department of Land Conservation and Development (DLCD) for completion of
the reports and analysis needed to support a UGB expansion and land uses needed to
support the next 20 years of growth in Bend.
City staff presented on sequential review to a joint meeting of the City Council and the Board
of County Commissioners on September 29, 2025. Attached to this memorandum is an issue
summary from the City of Bend summarizing the proposed process.
Bend City Council approved Resolution No. 3454 to move forward with the notice of election
on November 19, 2025: City staff is requesting Board approval of Order 2025-057, consenting
to the election of sequential review and directing county staff to support submittal of the
Notice and work plan to DLCD. The draft Notice to DLCD and work plan are attached. Once
submitted, the Director of DLCD has 120 days within which to approve the work plan.
II. NEXT STEPS
If approved, CDD staff will work with City of Bend staff to submit the joint notice of election
to DLCD to formally initiate the sequential review process.
Attachments:
City Issue Summary
Order No. 2025-057
Exhibit A - Proposed Work Plan
Draft Notice to DLCD
Page 2 of 2
't
CITY OF It
City Council Issue Summary
Subject: Adopt a resolution authorizing use of Sequential Review of Urban Growth Boundary
(UGB) Amendment Components by the Department of Land Conservation and Development.
Staff Member, Department: Damian Syrnyk, Community Development
Meeting Date: 11/19/2025
Action(s) Required:
❑ Consent Agenda ❑Ordinance First Reading [I Public Hearing
❑Information/Direction ❑Ordinance Second Reading ®Resolution
❑ Motion
Recommended Motion
I move to adopt a resolution authorizing the use of the Sequential Review process for certain Urban
Growth Boundary Amendment Components, and authorizing City staff, in coordination with Deschutes
County, to submit a notice and proposed work plan to the Oregon Department of Land Conservation
and Development.
Issue/Council Decision & Discussion Points
• Cities in Oregon are required to maintain 20-year supplies of buildable land for needed housing
and economic opportunities.
• Bend is preparing to complete studies needed under state law to update the Bend
Comprehensive Plan and prepare for this 20-year supply of land, which will include evaluating
the capacity of the urban growth boundary (UGB) for future needed housing and employment,
designating Climate Friendly Areas, and making other land use changes to accommodate
housing and employment within the existing UGB (aka Land Use Efficiency Measures).
• City and County staff have coordinated and presented this proposal at a joint meeting of the
City Council and Board of County Commissioners on September 29, 2025.
• Using the Sequential Review process will result in the required work being completed through
an adoption process that will provide more certainty to residents and policy makers by
obtaining the State's approval of a land inventory and a land need analysis before spending
public resources on the work involved on efficiency measures and a UGB expansion.
Background
The City Council's Housing Goal for 2025-2027 includes the strategy of "Accelerate complete
neighborhoods" and the following action item:
Adopt elements of a 20-year plan for housing and jobs (Bend's growth plan) emphasizing
policies that create walkable and complete neighborhoods and transition Bend to form based
development codes.
This resolution is the first step toward completing this action item, by proposing a sequential review
work plan to the Oregon Department of Land Conservation and Development (DLCD) for completion of
the reports and analysis needed to support a UGB expansion and land uses needed to support the next
20 years of growth in Bend. Staff presented on sequential review to a joint meeting of the City Council
and the Board of County Commissioners on September 29, 2025.
State law provides a process for a city and a county to request sequential review and approval from
DLCD of components that would support a UGB amendment of more than 50 acres. Oregon Revised
Statutes (ORS) 197.626(3) and Oregon Administrative Rules (OAR) 660-025-0185 allow a city and a
county to notify DLCD of their election to use the sequential review process for a land inventory, a land
need analysis, and a response to a land deficiency. This sequential review process is available in
situations where a city has estimated a future UGB expansion of more than 50 acres will be needed for
one or more land needs. Prior analysis of future land need, including the City's 2023 Draft Housing
Capacity Analysis, in addition to new 20-year housing needs for Bend through the Oregon Housing
Needs Analysis, suggest a future UGB amendment will exceed 50 acres.
A city and county proposed draft work plan through which one or more deliverables (reports or
components) required to support a future UGB expansion can be submitted sequentially for
Department review and approval. One of the more significant advantages to using the sequential
review process is to obtain Department approval of the land need deliverables (land inventory and
need analyses) prior to proceeding with work to identify how to meet these needs through Climate
Friendly Areas, land use efficiency measures, and a UGB amendment.
This resolution directs City staff to submit a notice and work plan to DLCD for approval under the
Sequential UGB Components review rules (See OAR 660-025-0185).
Staff presented the Growth Plan work plan to the City Council at the September 29, 2025, Joint
Meeting with Deschutes County. The total work plan includes five (5) adoption packages, two of which
will be submitted to DLCD for sequential review:
• Package 2 (Q2 2026 to Q3 2027) includes the following deliverables:
o Buildable Lands Inventory
o Housing Capacity Analysis Phase 1, primarily determining housing capacity and housing
as required under ORS 197A.270(1)-(4)
2
o Economic Opportunities Analysis
Package 3 (Q1 2027 to Q1 2029) includes the following deliverables:
o Housing Capacity Analysis Phase 2, addressing the Land Use Efficiency Measures
(LUEMs) and UGB expansion, as required under ORS 197A.270(5)-(6)
o Climate Friendly Areas
o UGB Amendment
After City Council approves the resolution, City staff will coordinate with County staff on Board of
Commissioners' approval of an Order that provides similar direction to County staff and supports the
submittal of the Notice and work plan to DLCD. The draft Notice to DLCD and work plan are attached.
Once submitted, the Director of DLCD has 120 days within which to approve the work plan.
Budget and Financial Impacts
The City's adopted biennial budget for 2025-2027 includes funding for staff and consultant time to
complete the elements of the Growth Plan scheduled for this biennium.
Community Outreach Process and Potential Impacts
The development of the Growth Plan and Comprehensive Plan update will include significant
community engagement. Engagement will include, but is not limited to, a committee of
representatives from the various City committees, public meetings with the Bend City Council, direct
engagement with the public in their neighborhoods (e.g., at schools, parks, events), and coordinating
with both stakeholders and agencies. The proposed Sequential Review work plan focuses on the
Department's (DLCD) review of several work products and does not reduce the amount of engagement
the City will undertake.
Department Director Review: Colin Stephens
Financial Review: Samantha Nelson
Legal Review: Elizabeth Oshel
Attachments
Resolution
o Exhibit A— Proposed Work Plan
3
Sequential Review Draft Notice to DLCD
Draft Housing Capacity Analysis
Language Assistance Services & Accommodation Information for People with Disabilities
You can obtain this information in alternate formats such as Braille, electronic format, etc. Free language
assistance services are also available. Please contact Damian Syrnyk, Senior Planner at (541) 312-4919 or
dsyrnyk@bendoregon.gov. Relay Users Dial 7-1-1.
Servicios de asistencia linguistica a informacion sobre alojamiento para personas con
discapacidad
Puede obtener esta informacion en formatos alternativos como Braille, formato electrbnico, etc. Tambien
disponemos de servicios gratuitos de asistencia linguistica. Pongase en contacto con Damian Syrnyk, Senior
Planner en dsyrnyk@bendoregon.gov o (541) 312-4919. Los usuarios del servicio de retransmision deben marcar
el 7-1-1.
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