HomeMy WebLinkAboutBolken AppealDeschutes County Board of Commissioners
1300 NW Wall St., Suite 200, Bend, OR 97701-1960
(541) 388-6570 - Fax (541) 385-3202 - www.deschutes.org
AGENDA REQUEST & STAFF REPORT
For Board Business Meeting of July 7, 2008
Please see directions for completing this document on the next page.
DATE: June 19, 2008.
FROM: Chris Bedsaul, Associate Planner CDD 383-6719
TITLE OF AGENDA ITEM:
Consideration of signature of Order No. 2008-066 accepting or rejecting a review of the Hearings
Officer's denial of a Common Law Vested Right in File No. DR -07-11 regarding a Measure 37 claim S-
lot subdivision proposal for Olaf and Jannis Bolken.
PUBLIC HEARING ON THIS DATE? NO
BACKGROUND AND POLICY IMPLICATIONS:
Olaf and Jannis Bolken received approval of a Measure 37 waiver of land use regulations in 2006 from
Deschutes County and State of Oregon. The Bolken's submitted an application for a five (5) lot
subdivision in the Exclusive Farm Use — Terrebonne subzone (EFU-TE) that was accepted as complete
on September 24, 2007. The Hearings Officer conducted a public hearing and conditionally approved
the Bolken's subdivision request on November 14, 2007. Ballot Measure 49 was approved by the
voters on November 6, 2007 and became effective December 6, 2007. The County required all Measure
37 claimants to obtain a Declaratory Ruling by the County prior to proceeding with any further
development after December 6, 2007. The Hearings Officer conducted a public hearing for the
Bolken's DR -07-11 application on March 6, 2008. The Hearings Officer on May 27, 2008 denied the
Bolken's qualification for a Common Law Vested Right to proceed with the subdivision. The appeal
was filed in a timely manner. There are no policy implications in this application.
FISCAL IMPLICATIONS:
None
RECOMMENDATION & ACTION REQUESTED:
Staff recommends that the Board deny the request for a partial de novo hearing.
ATTENDANCE: Chris Bedsaul
DISTRIBUTION OF DOCUMENTS:
Copy of Order to Chris Bedsaul ASAP so any notice of public hearing, if any may be sent out.
June 19, 2008
Community Development Department
Planning Division Building Safety Division Environmental Health Division
117 NW Lafayette Avenue Bend Oregon 97701-1925
(541)388-6575 FAX (541)385-1764
http://www.co.deschutes.or.us/cdd/
MEMORANDUM
To: Deschutes Board of County Commissioners
From: Chris Bedsaul, Associate Planner
Subject: Appeal of Hearings Officer Denial of a Common Law Vested Right of a 5 -
lot subdivision for Olaf and Jannis Bolken, DR07-11/MA07-13 and TP07-
1000
BACKGROUND
Olaf and Jannis Bolken received approval of a Measure 37 waiver of land use
regulations from Deschutes County in Order No. 2006-157 recorded on November 7,
2006 and State of Oregon, Final Order for Claim No. M129491, dated December 4,
2006. The Bolken's originally submitted TP07-1000 and modified the application in MA -
07 -13 for a five (5) lot subdivision in the Exclusive Farm Use — Terrebonne subzone
(EFU-TE). MA -07-13 was submitted on August 28, 2007 and accepted by the county as
complete on September 24, 2007. The Hearings Officer conditionally approved MA -07-
13 on November 14, 2007. Ballot Measure 49 was approved by the voters on November
6, 2007 and became effective December 6, 2007. The County required all Measure 37
claimants to obtain a Declaratory Ruling by the County prior to proceeding with any
further development after December 6, 2007. The Bolken's believed their development
had commenced and elected to proceed with their previous subdivision approval under a
Common Law Vested Right.
A Declaratory Ruling (DR07-11) application was submitted by Olaf and Jannis Bolken on
December 21, 2007 and accepted as complete on February 11, 2008. The Bolken's
application requested a determination if a Common Law Vested Right has been
established to continue the development of a five (5) lot subdivision previously approved
under County CDD file MA -07-13. A public hearing was conducted by the Hearings
Officer for DR07-11 on March 6, 2008. The Hearings Officer's decision, dated May 27,
2008, denied that a Common Law Vested Right has been established by the Bolken's.
In summary, the Hearings Officer found that (1) the Bolken's do not have the right to
complete the proposed subdivision by application of ORS 215.427(3) and (2) disagreed
with the Bolken's to depart from the general rule that the cost of future dwellings should
be included in the ratio test and (3) the Bolken's do not have a common law vested right
in the approved subdivision MA-07-13/TP-07-1000 pursuant to Section 5(3) of Measure
49.
Quality Services Performed with Pride
The applicant's appeal asserts the Hearings Officer erred in (1) not accepting the
"goalpost" statute in ORS 215.427(3), (2) concluding that any expenses incurred after
June 15, 2007 were non -eligible and (3) the analysis of the criteria of common law vesting
particularly in light of its reintroduction into the land use arena by reason of Measure 49.
The applicant filed a timely appeal on June 10, 2008. The 150 -day decision period does
not apply.
REVIEW
Except as set forth in DCC 22.28.030, when there is an appeal of a land use action and
the Board of County Commissioners is the Hearings Body:
A. The Board may on a case-by-case basis or by standing order for a class of cases
decide at a public meeting that the decision of the lower Hearings Body of an individual
land use action or a class of land use action decisions shall be the final decision of the
County.
B. If the Board of County Commissioners decides that the lower Hearings Body decision
shall be the final decision of the County, then the Board shall not hear the appeal and
the party appealing may continue the appeal as provided by law. In such a case, the
County shall provide written notice of its decision to all parties. The decision on the
land use application becomes final upon mailing of the Board's decision to decline
review.
C. The decision of the Board of County Commissioners not to hear a land use action
appeal is entirely discretionary.
D. In determining whether to hear an appeal, the Board of County Commissioners may
consider only:
1. The record developed before the lower Hearings Body;
2. The notice of appeal; and
3. Recommendations of staff.
RECOMMENDATION
Staff recommends the Board deny the appeal and adopt the Hearings Officer's findings
and decision, dated May 27, 2008, for DR -07-11, because:
1. The applicant/appellant received a full and fair hearing before the Hearings Officer.
2. There are no local policy interpretations involved in this matter.
3. The Hearings Officers decision is reasonable and defensible.
REVIEWED
LEGAL COUNSEL
For Recording Stamp Only
BEFORE THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON
An Order Denying Review of Hearings Officer's
Decision in File no. DR -07-11 (A-08-10)
*
*
ORDER NO. 2008-066
WHEREAS, Applicant Olaf and Jannis Bolken appealed the Deschutes County Hearings Officer's
decision on application number DR -07-1 1; and
WHEREAS, Section 22.32.027 of the Deschutes County Code allows the Board of County
Commissioners (Board) discretion on whether to hear appeals of Hearings Officer's decisions; and
WHEREAS, the 150 -day clock does not apply in a Common Law Vested Right determination; and
WHEREAS, the Board has given due consideration as to whether to review this application on appeal;
now, therefore,
THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON, HEREBY
ORDERS as follows:
Section 1. The Board, hereby, denies review of the applicant's appeal for Case Number DR -07-11 (A-
08-10) pursuant to Title 22 of the Deschutes County Code and other applicable provisions of the County land
use ordinances.
Dated this of , 2008 BOARD OF COUNTY COMMISSIONERS
OF DESCHUTES COUNTY, OREGON
DENNIS R. LUKE, CHAIR
TAMMY MELTON, VICE CHAIR
ATTEST:
Recording Secretary MICHAEL M. DALY, COMMISSIONER
PAGE 1 OF 1 - ORDER NO. 2008-066
BRYANT
EMERSON
& FITCH, LLP
Attorneys at Law
June 10, 2008
HAND DELIVERED
Deschutes County
Community Development Department
117 NW Lafayette Avenue
Bend, OR 97701-1925
Re: Appeal Application of Olaf and Jannis Bolken - DR -07-11
Ladies/Gentlemen:
Ronald L. Bryant *
Craig P. Emerson
Edward P. Fitch
Steven D. Bryant
Michael R. McLane
Michael W. Flinn
Lisa D.T. Klemp
Alison M. Trimble
Tony F. De Alicante *
* Also admitted in Washington
Enclosed please find the Appeal Application filed on behalf of Olaf and Jannis Bolken as
referenced above, as well as a Notice of Appeal and Request for Partial De Novo Hearing,
and our check in the amount of $1,821.00 to cover the required fee.
Appellant is obtaining the CD containing the hearing and will have it transcribed. Appellant
anticipates they will be able to file the transcript within ten (10) days.
If you have any questions, please advise. Thank you.
Very truly yours,
Edward P. Fitch
EPF/mcm
Enclosures
cc: Olaf and Jannis Bolken(w/encl.)
G:\Clients\EPF\Bolken, OlafBolken,OlafDeschutes County Appeal Ltr.WPD(mcm)
888 S.W. Evergreen Ave. P.O. Box 457 Redmond, OR 97756-0103
(541) 548-2151 Fax (541) 548-1895 E-mail bef@redmond-lawyers.com
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J`la
Community Development Department
Planning Division
117 NW Lafayette Avenue, Bend, OR 97701-1925
(541) 388-6575 - Fax (541) 385-1764
http://www.deschutes.org/cdd
APPEAL APPLICATION
FEE: $1,821.00
EVERY NOTICE OF APPEAL SHALL INCLUDE:
1. A statement describing the specific reasons for the appeal.
2. If the Board of County Commissioners is the Hearings Body, a request for review by the Board stating
the reasons the Board should review the lower decision.
3. If the Board of County Commissioners is the Hearings Body and de novo review is desired, a request
for denovo review by the Board, stating the reasons the Board should provide the de novo review as
provided in Section 22.32.027 of Title 22.
It is the responsibility of the Appellant to complete a Notice of Appeal as set forth in Chapter 22.32 of the County
Code. The Notice of Appeal on the reverse side of this form must include the items listed above. Failure to complete
all of the above may render an appeal invalid. Any additional comments should be included on the Notice of Appeal.
Appellant's Name (print): Olaf and Jannis Bolken
Phone: ( 541) 548-3328
Mailing Address: 9721 N. Hwy.. 97 City/State/Zip: Terrebonne, OR 97760
Land Use Application Being Appealed:
Property Description: Township 14
Appellant's Signature:
Hearings Officer decision dated May 30, 2008 on Declaratory
Ruling Application
Ranee 13 Section 09 Tax Lot 1400
EXCEPT AS PROVIDED IN SECTION 22.32.024, APPELLANT SHALL PROVIDE A COMPLETE
TRANSCRIPT OF ANY HEARING APPEALED, FROM RECORDED MAGNETIC TAPES PROVIDED BY THE
PLANNING DIVISION UPON REQUEST (THERE IS A $5.00 FEE FOR EACH MAGNETIC TAPE RECORD).
APPELLANT SHALL SUBMIT THE TRANSCRIPT TO THE PLANNING DIVISION NO LATER THAN THE
CLOSE OF THE DAY FIVE (5) DAYS PRIOR TO THE DATE SET FOR THE DE NOVO HEARING OR, FOR
ON -THE -RECORD APPEALS, THE DATE SET FOR RECEIPT OF WRITTEN RECORDS.
(over)
1/07
BEFORE THE BOARD OF COMMISSIONERS
FOR DESCHUTES COUNTY
In re: Vesting Application of )
DR -07-11
OLAF BOLKEN and JANNIS BOLKEN ) NOTICE OF APPEAL AND REQUEST
FOR PARTIAL DE NOVO HEARING
NOTICE OF APPEAL
Comes now, OLAF BOLKEN and JANNIS BOLKEN, and appeals the hearings officer's
decision dated May 27, 2008, and mailed May 30, 2008, a copy of which is attached hereto as
Exhibit A. The hearings officer erred in the following respects:
1. This subdivision is vested pursuant to the goalpost statute described in ORS
215.427(3). The hearings officer concluded that the goalpost statute only applies to approval of a
land use application based upon the criteria in effect at the time the application was filed and does
not extend to the development pursuant to that approval. The hearings officer is clearly wrong by
the statutory language, the case law and in light of the interpretation and practice of local
jurisdictions of the goalpost statute. Further, the hearings officer's interpretation of the goalpost
statute, and his interpretation of DLCD v. Corey is in error.
2. This subdivision is vested under common law as provided for in subsection 5(3) of
Measure 49. The hearings officer erred by concluding that any expenses incurred after June 15, 2007,
were noneligible. The statute is clear that vesting activity could occur up through December 6, 2007.
Moreover, that interpretation, not only reasonable given the language of Measure 49, but has been
interpreted that way by numerous jurisdictions, developers, attorneys, etc. The issue here is not
whether the applicant is absolutely correct in his interpretation that he had until December 6th to
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engage in vesting activity. The question here is whether or not it was reasonable for the applicant
to conclude that he had until December 6, 2007, to engage in vesting activity. The hearings officer
also erred in his analysis of the criteria of the common law vesting particularly in light of its
reintroduction into the land use arena by reason of Measure 49 in the analysis of the factual basis of
this case.
3. Olaf and Jannis Bolken further request that the Board allow a partial de novo hearing.
The purpose of that de novo hearing would be twofold. The first is to allow confirmation that these
expenses were, in fact, incurred and when. The second is to provide factual support that the
conclusion that the goalpost statute applied not only to approval of an application based upon the
criteria in effect at the time the application is filed, but also the development thereunder. This factual
basis will be in the form of affidavits from various planning directors and counsel based upon
conversations with the Deschutes County Planning staff.
I. STATUTORY VESTING
The waivers issued by Deschutes County and the State of Oregon provided to the applicants
a protected property interest in the waiver. Corey v. Department of Land Conservation and
Development, 212 Or App 536, 159 P3d 327 (2008) citing Board of Regency of State Colleges v.
Robb, 408 US 564, 577, 92 S. Ct. 2701, 33 L.Ed. 211d 548 (1972). The decision in Corey did not
clearly define the scope of interest a Measure 37 claimant had in a waiver. A claimant's property
interest in a Measure 37 waiver is akin to an inchoate interest or a statutory license.
An inchoate interest is defined in Blacks Law Dictionary as "an interest in real estate which
is not a present interest, but which may ripen into a vested estate, if not barred, extinguished, or
divested."
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BRYANT, EMERSON & FITCH, LLP
ATTORNEYS AT LAW
888 S.W. EVERGREEN AVENUE
P.O. BOX 457
REDMOND, OREGON 97756-0103
TELEPHONE (541) 548-2151
FAX (541) 548-1895
This inchoate property interest was not transferable nor was it vested. However, this interest
became a vested property right that was transferable upon the preparation and filing of a specific land
use application consistent with all relevant land use standards; standards which took into account
waivers of regulations as evidenced by orders issued by the State of Oregon and Deschutes County
pursuant to ORS 197.352.
The waiver right established by ORS 197.352(8) can also be described as a statutory license
to proceed with a certain activity. For example, statutory licenses for the constructions of wharfs on
navigable rivers has been described in a number of court cases. In Montgomery v. Shafer, 40 Or 245,
66 P 923 (1901), the Oregon Supreme Court noted that the right to construct a wharf pursuant to the
statute (now ORS Chapter 780) constituted a license revocable at the pleasure of the legislature until
acted upon. Once acted upon, however, the right for that license becomes vested. This propriety of
this analysis was confirmed by the court in Port of Portland v. Reeder, et al, 203 Or 369, 288 P2d
324 (1965) and also cited in Brusco Towboat v. State Land Bd. , 284 Or 627, 589 P2d 712 (1978).
By way of analogy, once the statutory license evidenced by waivers issued pursuant to ORS
197.352(8) has been exercised by the filing of a land use application, that statutory license which was
permissive at first now becomes irrevocable and vested.
The State of Oregon has maintained since the passage of Measure 37 that waivers are
personal to the Measure 37 claimant. See, Opinion of the Attorney General, dated February24, 2005
(Rec. 273-280). However, the State has also recognized that once the property interest under a
Measure 37 waiver becomes vested, it is transferable. See, Attorney General Opinion; See,
Comments from the Attorney General to the Circuit Court in the case of Crook County v. All
Electors, Crook County Circuit Court Case No. 08CV0015. In the Crook County case, the State
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BRYANT, EMERSON & FITCH, LLP
ATTORNEYS AT LAW
888 S.W. EVERGREEN AVENUE
P.O. BOX 457
REDMOND, OREGON 97756-0103
TELEPHONE (541) 548-2151
FAX (541) 548-1895
made the following representation to the Circuit Court:
It is not really the State's position that a waiver is never transferable,
but under existing law there are existing statutes governing
nonconforming uses and under the Court's decision under the vested
rights principle when the development of a nonconforming use has
reached a certain stage, the property owner is said to have acquired a
vested right to continue the development and subsequently put the use
to its intended function. (APP -5)
In that case, Judge Neilson agreed that once a waiver became vested, it was transferable.
Prior to 1983, common law was the only avenue in which land use development could be
vested to withstand subsequent changes in the law. To establish a vested interest in a nonconforming
use under common law, a person must cause either substantial construction to be made thereon or
incur substantial liabilities relating directly thereto prior to the effective date of the regulation
making such use nonconforming. Yokley Zoning Law in Practice, 4t" Edition, pg. 15.
In 1983, however, the Oregon Legislature passed House Bill 2295, which included the
provisions now codified under ORS 215.427(3), otherwise known as the "goalpost statute." The
statute was intended to overturn the ruling in Gearhart v. Klamath County, 7 Or LUBA 27 (1982).
Under this legislation, a person no longer has to cause either substantial construction or incur
substantial liabilities in order to establish a vested interest in a particular use for that use to become
nonconforming. To establish a vested use now, a person need only prepare and file an application
for land use approval and meet all the substantive standards and criteria in effect at the time that
application is filed. Since 1983, therefore, there have been two avenues to establish a vested
property right in a particular use of property, one at common law and the other by statute. The
Oregon State Bar Continuing Legal Education treatise on land use notes on page 12-18, the
following:
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BRYANT, EMERSON & FITCH, LLP
ATTORNEYS AT LAW
888 S.W. EVERGREEN AVENUE
P.O. BOX 457
REDMOND, OREGON 97756-0103
TELEPHONE (541) 548-2151
FAX (541) 548-1895
It must be noted that the rules of the vested rights game have been
changed somewhat by the enactment of ORS 215.428(3) (now
215.427(3)) and 227.178(3). These statutes provide that approval or
denial of a land use application `shall be based upon the standards
and criteria that were applicable at the time the application was first
submitted.' An applicant now has a form of vested right to a
particular use solely because an application has been made assuming,
of course, the standards in effect at the time of the application can be
met. See Kirpal Light Satsang v. Douglas County, 96 Or App 207,
772 P2d 944 on recon., 97 Or App 614, rev.denied 308 Or 382 (1989)
The standards and criteria in effect at the time the land use application for a 5 -lot subdivision
was applied for by the applicants included State regulations and County regulations not specifically
waived. The regulations not waived included those types of subdivision requirements which
addressed health and safety issues, such as access, road widths, pavement, utilities, fire hydrants and
clear vision, etc. The standards and criteria in effect at the time of this application also included the
waiver of certain land use regulations effected since 1969 at both the State and local levels. As this
court noted in Davenport, supra the term "standards and criteria" in ORS 215.427(3) is not limited
to provisions that may be characterized as approval criteria in a local comprehensive plan or land use
regulation. The court noted,
the role that the terms play in the two statutes (ORS 227.178(3) and
ORS 215.427(3)) is to assure both proponents and opponents of an
application that the substantive factors that are actually applied and
that have a meaningful impact on the decision, permitting or denying
an application would remain constant throughout the proceedings.
In the present instance, the standards and criteria included the waivers that were issued by
the State of Oregon and by Deschutes County. To be consistent with ORS 215.427(3), therefore, the
application of those standards and criteria, including those waived, must remain constant throughout
the proceeding and subsequent development. This constancy was even acknowledged by the
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BRYANT, EMERSON & FITCH, LLP
ATTORNEYS AT LAW
888 S.W. EVERGREEN AVENUE
P.O. BOX 457
REDMOND, OREGON 97756-0103
TELEPHONE (541) 548-2151
FAX (541) 548-1895
Department of Land Conservation and Development (DLCD) before the Land Use Board of Appeals
wherein Richard Whitman on behalf of the DLCD noted "215.427(3) protects against changes in
law." (APP -7)
The basic premise of ORS 215.427(3), however, even as acknowledged by the State before
LUBA, is that there must remain a constancy of application of the standards and criteria once a land
use application is filed despite subsequent changes in the law. That constancy can only be
maintained if this property right is deemed vested once an application is filed (assuming the
application meets those standards).
By operation of law, therefore, the applicants' protected property interest in his waiver, while
perhaps at first an inchoate personal right or revocable license until exercised, became a vested
property right or irrevocable license upon submittal of the application for land use approval. As a
vested property right, that interest was transferable and could not be defeated by subsequent
legislative amendments to any of the standards and criteria that were in effect at the time the
application was submitted. (See DeMendoza v. Huffman, 334 Or 425, 51 P3d 1232 (2002) citing
Phillips v. Washington Legal Foundation, 524 US 156, 118 S.Ct 1925, 141 L.Ed 2nd 174 (1998)
wherein the court noted: "the evidence of a property interest is determined by reference to existing
rules or understandings that stem from an independent source such as state law" Phillips at 164).
In other words, a Measure 37 claimant has the same rights in a land use application as do
non -Measure 37 claimants under ORS 215.427(3). A Measure 37 claimant cannot be treated any
differently. Once the application is filed, it is vested by operation of law and cannot be divested as
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that inchoate property interest has now been transformed into a vested property right'.
The hearings officer in the present case committed error by concluding that the goalpost
statute only requires a City or County to approve an application based upon the criteria in effect as
of the date the application is filed. He concluded that the goalpost statute does not require a City or
County to allow development pursuant to that approval. The hearings officer's decision on this point
is in error for four basic reasons.
First, it is inconsistent with the statutory scheme. Indeed, in ORS 197.835, the goalpost
statute is reinforced. In subsection 10(a), LUBA is required to reverse a local government decision
if the Board finds the local government avoided the requirements of the goalpost statute.
Second, it is inconsistent with the case law. In Gagnier v. City of Gladstone, 38 LUBA 858,
2000 WL 33288036 (2000), the Land Use Board of Appeals held that the City of Gladstone was
required to issue a building permit under the goalpost statute and apply the same standards and
criteria that were applicable at the time the underlying variance application was submitted.
Third, the practice of both Deschutes County and other jurisdictions in Central Oregon has
been consistent with the Gagnier, supra, case. That is, if a person applies for a land use application,
even if it is just the day before a change in the land use ordinances is enacted, that application is
grandfathered in under the goalpost statute and, assuming it is approved consistent with those
criteria, development is allowed to occur consistent with that application and approval.
Fourth, the hearings officer's position does not make any sense. Why would anyone spend
1 It seems clear that a zoning ordinance which seeks summarily to terminate an existing use is
unlikely to accomplish that end. The probable result in any state will be that the intended affect will be
nullified by narrow construction or that the ordinance will be declared invalid because it is retroactive
and because it destroys a vested right." Andersons American Law of Zoning, 4th Edition, pg. 499.
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the time, energy and money to obtain a land use approval that could not be used. That is the result
of his reasoning that the goalpost statute only follows through to the point of approval, and that
approval cannot be used for any development. That position just does not make any sense.
Opponents may argue that the wavier is not the basis for the standards and criteria set forth
in ORS 215.427(3). The State is in error. In MacPherson, supra, the Supreme Court noted that "an
action by a governing body to modify, remove, or not ...apply certain such regulations in specific
situations ... is in effect an amendment of the land use regulations in those particulars. See
MacPherson, supra, page 132.
Opponents may argue that Measure 49 either amends or impliedly repeals ORS 215.427(3)
insofar as the Measure appears to require a common law vesting. Such an interpretation would
permit a subsequent legislative amendment to affect a current land use application that has already
vested. Subsequent legislative amendments, however, cannot act as a defeasance of a vested
property right or irrevocable license. (See DeMendoza, supra) Otherwise the State, at any time,
could adopt legislation defeating vested rights whether established by operation of statute or by
common law.
Opponents may also argue that OAR 660-401-0060 (DLCD's temporary administrative rule
for Measure 49) also negates this statutory vesting. In that rule, the DLCD attempts to "expire" all
Measure 37 waivers as of December 6, 2007. This rule suffers the same fate as Measure 49. That
is, the statutory rights of an applicant in a land use application pursuant to ORS 215.427(3) cannot
be extinguished by subsequent legislation. This principle was affirmed by Judge Richardson of the
Court of Appeals in Sunburst II Homeowners Assoc. v. City of West Linn, 101 Or App 458, 720 P2d
1213 (1990). Therein, he noted that
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888 S.W. EVERGREEN AVENUE
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Persons who file application before more restrictive legislation is
adopted are entitled to have the earlier law applied to their
applications. Otherwise, their rights under the pre-existing standards
would be permanent nullified. Sunburst, supra at 461.
Finally, this administrative rule is on appeal to the Court of Appeals in Wallbank v. Land
Conservation and Development Commission, A137926.
Opponents may argue that the County must follow the reasoning of the Land Use Board of
Appeals in DLCD v. Jefferson County, LUBA 2007-177 (2008). There are several reasons
why that should not be the case. First, that case is on appeal and it's validity is at issue. Second, the
issue in DLCD v. Jefferson County was whether or not the death of a claimant affected the goalpost
statute. While LUBA noted that it was a very close question, LUBA came to the conclusion that the
goalpost statute and Measure 37 were in conflict. Neither of the parties to that case thought that to
be the case. In fact, on appeal, the State acknowledged in oral argument to the Court of Appeals that
the goalpost statute and Measure 37 are not in conflict. LUBA did not address Measure 49 as
suggested by the hearings officer. On the contrary from the applicant's perspective, Measure 37 and
the goalpost statute work in tandem quite well. Measure 37's task is to address an issue of
compensation. It's principal purpose was not to address the continuing validity of substantive
criteria in a land use application once that application is filed. The task of Measure 37 rights
basically expires once a land use application is filed: then through the goalpost statute (statutory
vesting in that waiver or that criteria) the Measure 37 right becomes vested or irrevocable pursuant
to the provisions of the goalpost statute. Rather than being in conflict, they are actually in harmony
with each other.
Finally, there is a comprehensive statutory framework that supports reliance upon pre -
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existing substantive criteria for land use applications as well as approvals issued thereunder. For
example, as a general rule, tentative plans are binding upon the counties for the purposes of
preparation and review of final plats. (See Deschutes County Code, Section 17.16.090(B)) This
binding effect for applicants in the substantive criteria and approvals continues not only through the
approval process but also through the development of the property. Such is the case here. The
applicant's vested statutory rights in that application and the substantive criteria continue not only
through the approval but also through development.
B. Common Law Vesting
The factor or guidelines relevant to a vested right analysis are:
(1) The good faith of the property owner in making
expenditures to lawfully develop his property in a given manner;
(2) The amount of notice of any proposed re -zoning;
(3) The amount of reliance on the prior zoning classification
in purchasing the property and making expenditures to develop the
property;
(4) The extent to which the expenditures relate more to the
nonconforming use than to the conforming use;
(5) The extent of the nonconformity of the proposed use as
compared to the uses allowed in the subsequent zoning ordinances;
(6) Whether the expenditures made prior to the subsequent
zoning regulation show that the property owner has gone beyond
mere contemplated use and has committed the property to an actual
use which would in fact have been made but for the passage of the
new zoning regulation;
(7) The ratio of the prior expenditures to the total cost of the
proposed use.
Polk County v. Martin, 292 Or 69 at 81, citing Cable & Hauck, "The Property Owner's Shield,
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supra.
1. Good Faith.
In Polk County, supra the Supreme Court, in citing the Willamette Law Journal article
noted that the good faith factor focuses on whether or not the owner made expenditures in good faith
to lawfully develop the property. In the present case there was never any notice of rezoning. The
statute referred by the legislature noted that an applicant had until December 5th to make
expenditures to establish a common law vesting. Many local jurisdictions, as well as persons in the
development community, interpreted Measure 49 in that respect (e.g., Crook County, Jefferson
County). Deschutes staff, for example, facilitated expenditures and permits up through December
5th.
Indeed, the legislature could have picked an earlier date as a cutoff date for consideration of
investment activity which would contribute to the conclusion that a use has become vested. The
legislature could have chosen the date of adjournment for the 2007 legislative session. The
legislature could have picked the election date of November 6, 2007. Instead, the legislature
affirmatively picked the effective date, i.e., December 6, 2007. The applicant certainly acted in good
faith in relying upon that legislative choice in determining when investment in the use for purposes
of determining a vested right would be cutoff.
In reaction to this unusual language, many if not most, local jurisdictions determined that
they would continue to process land use applications, permits, etc., up through the effective date of
Measure 49. Indeed, many local governments specifically relied upon the December 6, 2007 date
in which to determine the level of vesting.
The State of Oregon has even weighed in and apparently has indicated the same. In the
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Measure 49 notices that were issued by the State, the State noted in its instruction sheet under
vesting that
Claimants who received a waiver prior to December 6, 2007, and
begun development of the use described in the waiver may be able to
continue and complete the use described in the waiver if they had
done enough to create a common law vested right as of December 6.,
2007.
This language came from the Department which authored Measure 49.
Attached to this memorandum is a copy of a hearings officer's decision from Yamhill County
concerning a 50 -lot subdivision that that hearings officer deemed vested. In that decision, the
hearings officer noted:
As noted, Section 5(3) of Ballot Measure 49 allows development of
sues, when the right to "complete" or "continue" development of
those uses "vested" prior to December 6, 2007. This and other text
and context in the measure supports a conclusion that the "good faith"
of the applicant in attempting to "complete" or "vest" her use prior to
that date was encouraged by the measure itself. As complex as the
rest of M49 is, the "common law vested right * * * to complete and
continue" is contained in a single sentence that twice refers to the
effective date of the act. This reading supports a conclusion that
applicant was given until December 6, 2007 to continue her efforts to
complete, or at least "vest" her uses. The legislature could just as
easily have used June 15 or some other date if it meant to discourage
or prevent property owners from continuing expenditures and efforts
to "vest" their sues up to and including the effective date of the Act.
This hearings officer's conclusion is certainly much more reasonable in light of the language
in Measure 49. Similarly„ Judge Alexander in the case of Campbell v. State of Oergon and
Clackamas County, CV 07120049 noted:
Plaintiffs have acted in good faith. Anyone who claims to be able to
predict the outcome of a vote on a ballot measure in Oregon should
buy a Megabucks ticket. It was reasonable for plaintiffs to continue
with development until Measure 49 actually became law
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If anything, the statement attributed to a key member of the
legislature would have induced plaintiffs to continue preliminary
work on the site even if measure 49 should pass.
The hearings officer in the present case concluded that any expenditures after June 15th were
inappropriate. The hearings officer's conclusion in the Deschutes County case was clearly in error.
The issue in this case is not whether December 6th is absolutely the correct date. The issue
here is, in light of all these indicators, could the claimant have believed they were proceeding in good
faith up to December 6th. The answer is unequivocally "Yes."
2. Mere Preparation
The factors or guidelines to determine a vested right are very broad, very flexible with
the goal of determining whether or not an owner had taken appropriate steps to dedicate the property
to a lawful use and has expended considerable monies toward that end. Further, the reference in the
form "guidelines" to "mere preparation of the land" refers to a 1972 Washington County case
wherein without any land use application or approval an owner merely went out and cleared some
brush and trees and then later claimed he had built an airport. The case as we have here is 180
degrees removed from that fact scenario.
3. All Expenditures are Attributable to the Development.
Under current zoning the applicants could not partition this property. Under Measure 49,
they could potentially get 1 additional parcel with a home. Neither of these potentially allowable
uses would involve 99.9% of the expenditures incurred by applicant. These partitions would not
require the road system. In fact, under Measure 49, the two parcels would have to be less than 2
acres in size and clustered adjacent to the road. These partitions would not involve the re -work of
the irrigation system. None of these partitions would require the extensive survey work, engineering
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work, laying out the 5 -lot subdivision. None of these partitions would require the level of work done
for the land use applications in conjunction with this subdivision.
There must be some element of common sense in this proceeding. No one would ask an
engineer to draft up plans for a road system to serve 5 homes when all they could do is one parcel.
No one in their right mind would engineer utility systems for 5 lots to achieve a partition for only
one parcel. No one would drill wells and have septic system tests for 5 lots to achieve a partition of
1 more lot.
4. The Development as a Use of Land .
When Measure 37 was adopted, the voters of Oregon approved a plan by which owners
would either receive compensation or a waiver. The waiver is described in subsection 8 of ORS
197.352. Therein, governmental agencies are authorized to remove, modify or not apply offending
land use regulations to allow the owner to use the land as they could have as of the date of their
acquisition. This waiver would have been given as a form of compensation, rather than a cash
amount.
The State of Oregon has interpreted ORS 197.352(8) as allowing the State to authorize a use
of the property such as described in the waivers in the present case. Those waivers authorize the
claimants to develop the property into a residential subdivision with a density of approximately 5
parcels. That use is for the development of a 5 -lot subdivision for residential purposes.
This use was then evidenced in the form of the land use application for the 5 -lot subdivision.
It is a use allowed under current law, together with the amendments to those land use regulations
exhibited in the waivers issued by Deschutes County and the State of Oregon. This use, then, that
is a planned unit development, is a use authorized by both Deschutes County and the State of
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Oregon.
This use then can be preserved by vesting either under the statute (ORS 215.427(3)) or by
reason of subsection (5)(3) of Measure 49, that is, establishing a common law vesting as of
December 6, 2007. The claimants have satisfied this use and the vesting thereof under both avenues.
This use of the property as a subdivision with streets, utilities, and residential parcels is, therefore,
a use that can be vested by reason of either the statute or under common law.
The cases cited by Central Oregon Land Watch are not particularly relevant. They concern
subdivisions that were platted and not developed for decades. Platted but undeveloped subdivisions
were under the court rulings in the 1970's deemed not to be continuing uses. In this case, the scope
of the uses allowed under ORS 197.352(8) and preserved through 215.427(3) (which did not exist
when the cases of Parks v. Tillamook Co. Comm./Spliid, 11 Or App 177, 501 P2d 85 (1972), or
Columbia Hills v. LCDC, 50 Or App 483, 624 P2d 157 ((1981), is clear: it is the subdivision of 9
residential parcels with a road and utilities is vested.
5. Scope of Project
The facts of this case shows that the owner articulated a defined and lawful use, to -wit: a S-
lot subdivision with a road, water wells and septic systems. The owner expended over $33,000
which represents approximately 34% of the total project cost for the subdivision. All of these costs
were made in reliance upon a final decision by Deschutes County which authorized this use as
lawful. There is no question that even under a vested rights analysis, this owner is entitled to
proceed with the development to its fruition.
Opponents in these vesting applications have argued that the costs of homes should be
included. The construction of homes is not part of this subdivision application. This subdivision
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is to create lots which have the capability of having homes constructed on them. This concept of
including the unknown price of homes comes from some discussion by Judge Tanzer in the case of
Webber v. Clackamas County, 42 Or App 151, 600 P2d 448 (1979). However, in a subsequent case
the Court of Appeals did not consider homes to be part of the ratio test. For example, in Cook v.
Clackamas County, 50 Or App 75, 622 P2d 1107 (1981), the court evaluated the common law test
in relation to some work done toward establishment of a mobile home park. In the Cook case, the
court did not consider the cost of the mobile homes as part of the evaluation for the ratio test in
establishing a vested right.
Also, inclusion of cost of homes does not make sense in light of the history of Measure
37/Measure 49. Measure 37 was passed by the voters in November, 2004. A number of persons,
including the claimants have filed written demands with the applicable governmental entities in
2005. However, there was an approximate 8 to 9 month period in which very little transpired under
Measure 37 because of MacPherson, supra. As the Board knows, the Circuit Court in Marion
County originally ruled Measure 37 to be unconstitutional. The State of Oregon did not process any
claims during the time that was on appeal. Finally, in 2006, the Supreme Court overruled the Circuit
Court and found Measure 37 to be constitutional. Because of that delay, there were very few, if any,
subdivision in the State of Oregon that were approved under Measure 37 and under construction
when the legislature considered Measure 49. By June, 2007, there were very few, if any,
subdivisions in the State of Oregon where homes were under construction. It would be illogical to
think that the legislature would provide a relief that was a sham. In other words, it would not be
anticipated that the legislature could consider the cost of homes to be included in the common law
vesting under Measure 37. One must remember that this vesting avenue under Section 5(3) of
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Measure 49 is an unusual mixture of both statutory and common law principles. The statute was
written in a form that if a person had done enough to obtain a form of common law vesting by the
effective date, the Measure 37 claimant would be entitled to that relief for compensation. It would
not be appropriate to find that the legislature wrote this with the intent that no one could qualify for
this relief. Based upon the circumstances "on the ground" in Oregon in June, 2007, it would be an
appropriate conclusion to find that those persons who in reliance and in compliance with the law had
expended a considerable amount of money to pursue a qualified development under Measure 37
would be entitled to retain the benefit of that right as opposed to those who merely received waivers
and did not take any action to pursue development thereunder.
Finally, what cost is used? Opponents set one figure. The cost of homes could be as low as
$100,000 (double wide manufactured homes). This practical element undermines a blanket figure
for inclusion of the cost of homes.
However, even with the inclusion of the cost of homes, this development is vested as the
investment to December 6th was $33,393. There is approximately $396,091 of the project cost
including homes (e.g., expenses incurred to date divided by 3 homes x $100,000 + subdivision costs.
This results in a 8.4% ratio. Note: There are two existing homes on the parcel.
DATED this /8 day of June, 2008.
Respectfully submitted
EDWARD P. FITCH, OSB 78202
Of Attorneys for Applicant
Bryant, Emerson & Fitch, LLP
P.O. Box 457, Redmond, OR 97756
Telephone: (541) 548-2151;Facsimile: (541) 548-1895
Efitch@redmond-lawyers.com
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Attachments
(1) Hearings Officer decision
(2) Gagnier v. City of Gladstone
(3) ORS 197.835
(4) Deschutes County Code Section 17.16.090
(5) Affidavit of Edward P. Fitch
(6) Affidavit of Jim Hendryx
(7) Affidavit of Bill Zelenka
(8) Shown Decision
(9) Hudspeth Decision
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DECISION OF TUE DESCHUTES COUNTY HEARINGS OFFICER
FILE NUMBER:
APPLICANT/
OWNER:
AGENT:
REQUEST:
DR -07-11
Olaf and Jannis Bolken
9721 North Highway 97
Terrebonne OR 97760
Ed Fitch
Bryant Emerson & Fitch, LLP
PO Box 457
Redmond OR 97756
An application for a Declaratory Ruling to determine whether
the applicant has a common law vested right to continue the
development of a five -lot subdivision approved under County
CDD files MA -07-13 and TP -07-1000.
HEARING DATE: March 6, 2008
STAFF CONTACT: Chris Bedsaul, Associate Planner
I. STANDARDS AND APPLICABLE CRITERIA:
Ballot Measure 49 (House Bill 3540), Oregon Revised Statutes Chapters 195, 197
Title 18, the Deschutes County Zoning Ordinance, oldie Deschutes County Code.
II. BASIC FINDINGS:
A. LOCATION: The subject property has an assigned. address of 9721 North
Highway 97 and on County Assessor's Map 14-13-09, as tax lot 1400.
B. ZONING: The subject property is zoned Exclusive Farm Use-Terrebonne Subzone
(EFUTE). The property is designated agriculture by the Deschutes County
Comprehensive Plan.
C. PROPOSAL: The application submitted is for a determination under Ballot
Measure 49 whether there is a common law vested right to continue development
of the subdivision, consisting of five (5) platted lots, each lot eligible for a
dwelling, approved under TP -07-1000 and MA -07-13.
D. SITE DESCRIPTION: The subject property is 31.40 acres in size and is located
west of Highway 97. The southern property boundary is adjacent to the
DR -07-11
Bolken
1
Terrebonne Unincorporated Community zone boundary. The property contains
two (2) existing single-family dwellings, two (2) farm accessory barns, shed and
detached garage with ground cover consisting of irrigated livestock pasture,
native vegetation, native grasses and juniper trees. The property contains 27 acres
of irrigation and is within the Central Oregon Irrigation District.
E. PUBLIC AGENCY COMMENTS: The Department of Land Conservation and
Development (DLCD) received the county's notice of a Declaratory Ruling
application for the above -referenced subdivision. DLCD responded in a letter
dated February 20, 2008 which discussed the department's view of the
inapplicability of ORS 215.427(3), and a statement on common law vested rights.
F. PUBLIC COMMENTS: The Planning Division sent notice of the proposed
Declaratory Ruling application (hearing) to all property owners within 750 feet of
the subject property. Staff did not receive any responses. At the hearing on
March 6, 2008, no other parties appeared to testily on the proposal other than the
applicant.
G. LOT OF RECORD: The subject property is a lot of record by previous issuance of
development permits (see B11443, B16873, S19649 and S52078).
IFI. REVIEW PERIOD: This Declaratory Ruling application was submitted on December
18, 2007 and an "Incomplete Application" letter, dated January 17, 2008 was moiled to
the applicant. The applicant provided supplemental information as requested and the
application was accepted as complete on February 11, 2008.
I. CO1VIMUNITY DEVELOPMENT DEPARTMENT PERMITS: The applicant
submitted costs associated with the proposed development. Staff has summarized these
costs in the following tables:
TABLE 1: Applicant Listed Measure 37 Related Expenses PRIOR to June 15.4
2007
Date of
Payment
Preliminary.
Development
Cost Item
Identification
Payment
Made To
Expense Paid
May 30, 2006
Deschutes County
Filing Fee
Deschutes County
$500.00
May 30, 2006
Title Search
Western Title
$200.00
TOTAL
PAYMENT
$700.00
TABLE 2: Applicant Listed Non -Construction Type and/or Preliminary Project
Expenses PRIOR to June 15, 2007
DR -07-11
Bolken
2
Date of
Payment
Preliminary
Development
Cost Item
Identification
Payment
Made To
Expense Paid
January 16, 2007
Steel Culvert — No
verified use
identified for
project
Swift Steel
$203.95
January 27, 2007
Fill Dirt — No
verified use
identified for
project
Dewey Dirt
Works
$125.00
April 20, 2007
Attorney Fee
Ed Fitch
$50.00
April 25, 2007
Planner Fee
Heidi Kennedy
$778.50
May 3, 2007
Title Search
Western Title
$150.00
May 17, 2007
Surveyor
Jeff Kern
$2,000.00
May 8, 2007 to
June 22,
2007/***July
16, 2007 and
July 31, 2007
Surveyor for
research, field
survey for
monuments and
topography and
prepare tentative
plat.
Note: Staff
Jeff Kern
$2,905.00
believes that this
work was
completed prior to
June 15, 2007.
TOTAL
PAYMENT
86,212.45
TABLE 3: Applicant Listed Preliminary Subdivision Development Preparation
Expenses AFTER June 15, 2007 and PRIOR to November 7, 2007
Date of Payment
Preliminary
Development
Cost Item
Identification
Payment
Made To
Expense Paid
June 26, 2007
Subdivision Filing
Fee
Deschutes County
$2,885.00
July 31, 2007
Planner Fee
Heidi Kennedy
$337.50
July 31, 2007
Surveyor
JeffKem
$905.00
DR -07-11
Bolken
August 24, 2007
Attorney Fee
Ed Fitch
$56.25
August 28, 2007
Subdivision
Hearing Fee
(Modification of
Application)
Deschutes County
$520.00
September
17,2007
Surveyor Fee
Jeff Kern
$967.00
October 2, 2007
Attorney Fee
Ed Fitch
$303.75
October 24, 2007
Well Drilling &
Casing
Abbas Well
Drilling
$8,424.00
October 28, 2007
Rock and dirt
moving
Dewy Dirt Works
$240.00
November 5,
2007
Access approach
to Highway 97
Note: Applicant
indicates that the
work was
completed in 1g
week in October
Knife River
Paving
$7,152.62
TOTAL
PAYMENT
$ 21,791.12
TABLE 4: Subdivision Development Expenses Paid AFTER November 7, 2007
and PRIOR to December 6, 2007
Date of
Payment
Preliminary
Development
Cost Item
Identification
Payment
Made To
Expense Paid
November 30,
2007
Attorney Fee
Ed Fitch
$113.70
December 1,
2007
Surveyor Fee for
work completed
between 11-17
and 11-28-2007
JeffKern
$2,277.00
TOTAL
PAYMENT
$ 2,390.00
DR -07-11
Bolken
4
TABLE 5: Subdivision Development Expenses Paid AFTER December 6, 2007
Date of
Payment
Preliminary
Development
Cost Item
Identification
Payment
Made To
Expense Paid
January 3, 2008
Planner Fee
Heidi Kennedy
$262.50
January 22,
2008
Engineering Fee
Central Electric
Coop
$500.00
January 28,
2008
Attorney Fee
Ed Fitch
$58.75
TOTAL
PAYMENT
$821.25
TABLE 6: ESTIMATED Subdivision Development Expenses Remaining AFTER
December 6, 2007 and Final Plat Approval
Development Cost
Item Identiification
Estimated Unpaid
Development Costs
Engineering -Road
Construction
$412.50
Engineering -Road
Construction
$3,995.00
Construction of
Road
$39,410.00
Well Installation
$8,500.00
Central Electric
Utility Installation
$9,275.00
Qwest Telephone
Utility Installation
$2,988.00*
* Note: No detailed
written cost estimate
from Qwest was
included with the
application exhibits.
Total Estimated
Development Cost
Remaining
AFTER December
6, 2007
864,580.50
DR -07-11
Bolken
5
J. APPLICANT INFORMATION: The applicant received a Measure 37 waiver from
the State of Oregon for Claim No. M129491 on December 4, 2006. This approval was preceded
by a similar approval from the Deschutes County Board of Commissioners in Order No. 2006-
157, issued November 6, 2006. Based on these waivers, the applicant conducted various site
preparation work and filed applications to permit a dwelling in conjunction with farm use on five
(5) lots to be created by a subdivision pursuant to MA-07-13/TP-07-1000. These applications
were approved and mailed on November 14, 2007.
III. FINDINGS OF FACT AND CONCLUSIONS OF LAW:
A. Legal Background - Measure 49 and Vested Rights
Recently, Hearings Officer Anne Corcoran Briggs has issued decisions in several declaratory
rulings applying the provisions of Measure 49 and common law vested rights. In these decisions,
the Hearings Officer describes the legal context for determining vested rights under Measure 49.
I agree with this legal analysis and quote it verbatim here:
"Legal Principles
1. Measure 37.
Measure 37 was approved by the Oregon voters in 2004. Measure 37, which is
codified in state law at ORS 197.352(2005), created a cause of action whereby
property owners/claimants could obtain compensation or waivers from land use
regulations that were adopted after the claimants acquired their property if the
regulations reduced their property values. Claims were submitted to local
governments and to the state, which evaluated the claims and, for the most part,
approved waivers to the devaluing regulations. Once property owners received
waivers from the county and/or state, the property owners applied for land
development approvals that effectuated developments permitted under the waivers.
Between December 2004 (the date Measure 37 became effective) and December
2007 (the date Measure 49 became effective), processing of the Measure 37
c aims was interrupted by appeals. As a result, many Measure 37 claims lapsed,
or were not finalized in a land use decision on the Measure 37 land use
application.'
2. Measure 49.2
On June 15, 2007, the Oregon Legislative Assembly referred Measure 49 to the
voters. Measure 49 was billed as a "modification" to Measure 37, but in fact
severely circumscribes both the nature and extent of development that can be
I Measure 37 claims that were pending or on appeal as of the effective date of Measure 49 are now moot.
Frank v. Department ofLand Coaervatio►n and Development, Or App _ (CA A134704, January 23,
2008).
2 Measure 49 is now codified at ORS 197300 et. seq. However, because much of the discussion pertaining
to Measures 37 and 49 refer to the Measure text rather than the statutory provisions, I refer to the text oldie
measures in this decision.
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approved under Measure 37 waivers. For instance, Measure 49 allows only
limited residential development on land that was otherwise available for any
number of lots and activities. In addition, Measure 49 requires that the waivers
granted under Measure 37 be re-evaluated by DLCD. DLCD must decide whether
the estimated loss in value asserted in the initial Measure 37 c aims is supported
by a uniform methodology for calculating loss in value. In addition, the
Department must work with property owners to determine whether the claimants
will receive an "express" waiver, which permits the development of up to three
parcels and three new dwelling units on property held by the claimants, or
whether the claimants are entitled to develop up to ten dwelling units on ten new
lots. It is generally understood that few, if any, of the claimants will be entitled to
develop ten dwelling units.
For those property owners who received Measure 37 waivers and who have a
"common law vested right" to develop as of December 6, 2007, development may
continue under the Measure 37 waivers and the claimants need not receive a
supplemental approval under Measure 49. See Measure 49, Section 5(3).
3. ORS 215.130(5).
This statute allows property owners to continue legally established
nonconforming uses and structures on properties, so long as the uses and
structures are not altered or abandoned. Further, ORS 215.130(5) permits
changes in ownership and occupancy without forfeiting the right to the
nonconforming use.
4. ORS 215.427 (Goalpost rule)
ORS 215.427(3)(a) provides:
"If the application was complete when first submitted or the applicant submits
the requested additional information within 180 days of the date the
application was first submitted and the county has a comprehensive plan and
land use regulations acknowledged under ORS 197.251, approval or denial
Alan be based upon the standards and criteria that were applicable at the time
the application was first submitted."
The type of vesting provided for in ORS 215.427(3Xa) is known as "an early
vesting rule." Its purpose is to establish a bright line standard from the onset, so
that the parties to a land use application understand which applicable approval
standards will govern the review of the application. In DLCD v. Jefferson County
(Burk), _ Or LUBA _ (LUBA No. 2007-177, January 24, 2008), appeal
pending _ Or App _ (2008), LUBA held that the provisions and limitations of
Measures 37 and 49 supersede ORS 215.427(3)(a), where an applicant dies prior
to a decision on a Measure 37 land use application. Under the reasoning in Burk,
3 ORS 215.130(5) provides, in relevant part The lawful use of any building, structure or land at the time of
the enactment or amendment of any zoning ordinance or regulation maybe continued. * * * A change of
ownership or occupancy shall be permitted "
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only the claimant/applicant has the right to proceed with a Measure 37 land use
application, because Measure 37 rights are personal to the claimant.4
5. Common Law Vested Rights.
"Vested rights" refers to the equitable principle that a party has the right to
develop property notwithstanding the adoption of more restrictive land use
regulations, if the party demonstrates that it has commenced the development in
good faith.5 In Clackamas County v. Holmes, 265 Or 193, 508 P2d 190
(1973XHolmes), the Oregon Supreme Court identified factors to be considered
when analyzing expenditures made in reliance on an assumed development
approval to decide (after the fact) whether a project has vested. The Court
adopted a requirement that includes consideration of the ratio of expenditures
incurred to the total costs of the project, but also included consideration of other
factors. The Court held:
"We believe that the ratio test should be only one of the factors to be considered.
Other factors which should be taken into consideration are the good faith of the
landowner, whether or not he had notice of any proposed zoning or amendatory
zoning before starting his improvements, the types of expenditures, i.e., whether
the expenditures have any relation to the completed project or could apply to
various other uses of the land, the kind of project, the location and ultimate cost.
Also, the acts of the landowner should rise beyond mere contemplated use or
preparation * * *." Holmes, 265 Or at 198-99.
Over the years, the Holmes analysis has been refined somewhat. In Union Oil Co.
v. Board of Co. Comm. of Clack. Co., 81 Or App 1, 724 P2d 341 (1986), the
Oregon Court of Appeals held that not all Holmes factors will come into play in
all cases, and that when they do, different weight may be accorded to those factors.
In addition:
a. Where a development includes both a land division and the development
of dwellings, the ratio test must include costs related to both. Webber v.
Clackamas County, 42 Or App 151,155 n 2, 600 P2d 448 (1979).
b. The ratio test should not include the property purchase price unless there is
evidence that the buyer/developer paid a premium to develop the site for
the particular use it now seeks to vest. Union Oil Co. v. Board of Co.
Comm. of Clack Co., 81 Or App at 7.
c. Costs must be incurred based on lawful permits. DLCD v. Curry County,
19 Or LUBA 237 (1990) (holding that costs incurred after Supreme Court
overturned county approval are not to be considered in vesting analysis);
4 The circumstances here are different than the facts in Burk. In Burp the claimant died before the county
approved his tentative subdivision plan. Here, the applicant is still living.
s The Oregon Court of Appeals has described "vested rights" as "inchoate nonconforming uses." See
Fountain Village Dev. Co. v. Multnomah County,176 Or App 2I3, 221, 31 Pad 458 (2001).
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Lung v. Marion County, 21 Or LURA 302 (1991)(expenditures incurred to
develop landscaping business cannot be included because they were
incurred without land use approvals); Crone v. Clackamas County, 21 Or
LUBA 1992 (1991)(expenses incurred to partition parcel could not be
considered where applicant had not applied for partition approval.)
d. Site preparation, engineering fees, and attorney fees incurred in obtaining
development approvals are allowable expenses to consider under the ratio
test. Cook v Clackamas County, 50 Or App 75, 84, 622 P2d 1107 (1981).
e. By themselves, land use approval and building permits for a development
do not create a vested right to develop that particular use. Twin Rocks
Watseco Defense Committee v. Sheets, 15 Or App 445 (1973); Columbia
Hills Development Co. v. Land Conservation and Development
Commission, 50 Or App 483, 624 P2d 157 (1981); and Mason v. Mountain
River Estates, Inc., 73 Or App 334, 698 P2d 529 (1985).6
£ Expenditures that commit the property to the particular use contemplated by the
developer may be included in the ratio analysis. Conversely, expenditures that can be
applied to other allowed uses may not be considered to be directed toward the
purported vested right. Eklund v. Clackamas County, 36 Or App 73, 583 P2d 567
(1978xdeveloper allowed to include costs to develop water system on site, because
the water system was directly related to residential subdivision, and not to the
agricultural uses of the property allowed by the zoning); Webber v. Clackamas
County, 42 Or App at 155 (where water system could be used to serve 5 -acre parcels,
applicant could not include costs incurred to install the water system to serve one-half
acre lots.)"
B. Application of Vested Rights rules to the Facts of this Application
1. Applicability of ORS 215.427(3)
In a letter dated February 19, 2008, the applicant argues that "[t]he waivers issued by Deschutes
County and the State of Oregon provided to Olaf Bolken a protected property interest in the
waiver." Based on this assertion, the applicant further argues that ORS 215.427(3) vests the
right, memorialized in DLCD's Measure 37 claim approval, to complete the proposed five lot
subdivision.
6 Twin Rocks and Columbia Hills were decided prior to the adoption of ORS 215.427 and its predecessor
statute, ORS 215.428. Mason was based on local code provisions that were adopted in 1980, also prior to
the adoption of the goalpost statute. Therefore, it is not clear whether those holdings have the same
prededential value in light of the goalpost statutes. See Kirpal Light Santsang v. Douglas County, 18 Or
LURA 651(1990) on remandfrom Court of Appeals, 96 Or App 207, 772 P2d 944 (1989)(based on ORS
215.428, an application to construct a boarding school and associated buildings submitted seven days
before the standards changed must be reviewed against the standards in place at the time the applies
was submitted, and not against the later -adopted conditional use standards.)
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On May 8, 2008, the Oregon Supreme Court conclusively dismissed this same argument in
Corey v. DLCD,_ Or (S0554995, May 8, 2008): The Court stated:
In the end, we hold only that plaintiffs' contention that Measure 49 does not affect
the rights of persons who already have obtained Measure 37 waivers is incorrect.
In fact, Measure 49 by its terms deprives Measure 37 waivers -- and all orders
disposing of Measure 37 claims -- of any continuing viability, with a single
exception that does not apply to plaintiffs' claim. Thus, after December 6, 2007
(the effective date of Measure 49), the final order at issue in the present case had
no legal effect.
Like the DLCD order discussed in Corey, the applicant's Measure 37 waivers from DLCD and
the Deschutes County Board of Commissioners have no legal effect. These waivers themselves
cannot constitute "standards and criteria" under ORS 215.427(3). Therefore, I find that the
applicant does not have the right to complete the proposed subdivision by application of ORS
215.427(3).
2. Common Law Vested Right
Section 5 of Measure 49 provides the exclusive means for completing development pursuant to
waivers granted under Measure 37. Section 5(3) of Measure 49 states:
A waiver issued before the effective date of this 2007 Act to the extent
that the claimant's use of the property complies with the waiver and the
claimant has a common law vested right on the effective date of this 2007
Act to complete and continue the use described in the waiver.
As discussed above, the determination of a vested right requires the application of the method
identified in Clackamas County v. Holmes and subsequent vested rights cases.
Consistent with the Hearings Officer's decisions in DR -07-12, DR -07-14 and DR -07-15, I find
that qualifying expenditures made prior to June 15, 2007 may be considered in comparing the
ratio of expenditures to total costs of the project under the test described in Holmes.
In considering these costs, staff has recommended, and I agree, that the $700 Measure 37 filing
fees identified in Table 1 above, should not be included because they are not directly related to
application for the proposed five lot subdivision. I find that all the expenditures identified in
Table 2 above, totaling $6212.45 are reasonably attributable to site preparation and planning
related to the proposed subdivision. These are the only costs that may be considered in the ratio
analysis.
The applicant asserts that expenditures through December 6, 2007 must be considered for the
ratio test. Mr. Bolken submitted written testimony on February 28, 2008, which in part
addresses the question of whether he was acting in good faith. He states, and I have no reason to
doubt the veracity of his statements, that he was unaware that Measure 49 had been referred to
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the voters on June 15, 2007. He further states and implies that the county should have notified
him to stop work on his proposed subdivision after Measure 49 was referred to the voters.
On the topic of good faith, I concur with the Hearings Officer's decision in DR -07-12.7 I would
only add that one of the components of the analysis described in Holmes is the question of when
the claimant may have received "notice" of a proposed change in land use rules. In a typical
vested rights case, a city or county proposes to amend the zoning or development code in a way
that limits the use of lands under certain zoning classifications. If a county proposes such a
legislative change today, it is required to provide notice under ORS 215.503 to potentially
effected property owners. This type of notice is one which would be properly recognized under
Holmes. Development and expenditures made after the date of such notice can reasonably be
considered at the risk of the property owner and "bad faith" actions in an equitable claim because
the owner was presumptively aware that applicable regulations were about to change. Notice in
the context of Measure 49 is different than the typical case, because HB 3540 was an act of the
Oregon Legislature referring the proposal to the voters. Neither the state nor Deschutes County
were under any affirmative legal duty to notify potentially effected property owners that their
previously approved Measure 37 waivers might be effected.
On the issue of total development costs, the applicant argues that the cost of the houses that
would eventually be built in the proposed subdivision should not be included. The applicant
sites Cooky. Clackamas County, 50 Or App 75 (1981), for the proposition that the cost of
proposed homes should not be included. However, in Cook, the development for which a vested
right was sought was a mobile home park — not a subdivision in which permanent homes would
be built. The court in Cook was not reviewing the trial court decision de novo, and therefore, the
reasons the trial court decided not to include the costs attributed to the mobile homes which
would be located in the park are not disclosed. However, it is reasonable to infer that since
mobile homes in a park are not generally a fixed asset legally attached to the land (as is a fee
simple single family home), and that the park owners do not generally own the mobile homes in
a park, that those costs could be excluded. For these reasons, I disagree with the applicant and
see no reason to depart from the general rule identified in Webber v. Clackamas County, 42 Or
App 151, 155 (1979) that the cost of future dwellings should be included in the ratio test.
In a March 4, 2008 letter, the applicant estimated that the total cost of completing the five lot
subdivision, including three new dwellings would be $697,974.07. The record shows eligible
expenditures of $6,212.45. Using these estimates, the ratio of expenditures to total costs is
DR -07-12, note 9 — "The legislative assembly adopted HB 3540, which referred Measure 49 to the voters
on June 15, 2007. The referral was widely known, and was sufficient to putt the holders of waivers on
notice that a decision to proceed with development was at the claimants' own risk. 1 reject the applicants'
assertion that at the earliest, the county should establish December 6, 2007 (the date Measure 49 became
effective) as the cut-off date, because the applicant reasonably expected the measure to be challenged
during the interim between voter approval and its effective date, and the applicants reasonably relied on
advice from their attorney, Oregonians in Action and others that December 6, 2007 was the good faith "cut
off" date. The case law on this, while relatively scant, leads to the conclusion that a developer does not
have a good faith belief that a use is lawful if a court or legislative action, such as a referendum, has
concluded otherwise. DLCD v. Curry County, 19 Or LUBA 237 (1990); see also County ofKauai v. Pacific
Standard Life Insurance Company, 65 Haw 318, 653 P2d 766 (1982xfiling of petition to refer a
development proposal to the voters is sufficient notice to the developer that further development is not in
good faith.)"
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approximately 1:112. The ratio in Holmes was approximately 1:14. A ratio of 1:112 is not
sufficient to demonstrate a vested right to continue the proposed subdivision.
IV. DECISION
For the reasons set forth above, I find that the applicant does not have a common law vested right
in the approved subdivision MA-07-13/TP-07-1000 pursuant to Section 5(3) of Measure 49. The
applicant may not develop the proposed lots and does not have the right convey any inchoate
Measure 37 interest that he may have to third parties.
DATED this 2 % day of May, 2008
MAILED this day of May, 2008
Kenneth D. Helm, Hearings Officer
THIS DECISION IS FINAL WITHIN 12 DAYS OF MAILING UNLESS APPEALED TO
THE BOARD OF COUNTY COMMISSIONERS
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