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MEMORANDUM
To: Board of County Commissioners
From: Nick Lelack, AICP, Planning Director
Date: April 13, 2011
Re: Work Session: Development Approval Extensions
SUMMARY
The purpose of this work session is to seek Board direction on whether the County should
initiate a text amendment to the Deschutes County Code (DCC) to allow additional development
approval extensions beyond the normal approval and extension periods for non-resource
approvals such as site plan reviews, subdivisions, partitions and lot line adjustments. There has
been interest from the development community to continue to keep planning approvals active
until the market allows them the financial ability to submit their building permits, pay their SDCs
and commence construction.
DISCUSSION
DCC Chapter 22.36 (B) and (C) establish the duration of land use permit approvals for two
years, and authorize the Planning Director to grant up to three 1-year extensions for approvals
where a development has not been initiated.1 Land use permit approvals subject to this time
frame include site plan reviews, conditional use permits, subdivisions, partitions, lot line
adjustments, etc. Deschutes County’s 5-year timeframe to initiate a development is one of the
longest development approval timelines for both cities and counties in Oregon. The Exclusive
Farm Use and Forest Use Zones have separate duration of approvals and extensions as
established by state law.2
1 Per DCC 22.36.020 Initiation of Use, development action under a land use approval has been “initiated”
if it is determined that: 1. The proposed use has lawfully occurred; 2. Substantial construction toward
completion of the land use approval has taken place; or 3. Where construction is not required by the
approval, the conditions of a permit or approval have been substantially exercised and any failure to fully
comply with the conditions is not the fault of the applicant.
2 The approval period for the following dwellings in the EFU and Forest Use Zones is 4 years
(replacement dwelling, nonfarm dwelling, lot of record dwelling, large tract dwelling, and template
dwelling). Up to two 2-year extensions may be granted by the Planning Director for such dwellings.
The Community Development Department has been approached about providing additional land
use permit extensions due to the extended economic downturn. Similar requests have been
made and approved throughout Central Oregon. For example, the cities of Bend, Redmond and
Sisters, and Crook County, have all approved additional land use permit extensions, and
typically for 2 additional years.
The table below shows the number of development approval extension requests by year
between January 1, 2000 and March 31, 2011.
Table 1. Development Approval Extension Requests
Year Number of Extension Requests
2000 35
2001 51
2002 65
2003 39
2004 33
2005 24
2006 51
2007 49
2008 73
2009 70
2010 85
2011 (1st Quarter) 24
TOTAL 600
The table shows a significant increase in extension requests beginning in 2008. Specifically, it
shows that 252, or 42%, of the 600 development approval requests since 2000 have been
submitted since the start of 2008. Moreover, 2011 is on pace for nearly 100 extension requests
with 24 already submitted in the first quarter.
The reason land use permits have expiration dates is to ensure development proposals comply
with current standards. Approval extensions are available so applicants can request additional
time to begin or continue a development or meet conditions of approval regardless of whether
the applicable standards have changed. Applicants are required to submit a written request for
an extension prior to the expiration of approval, state the reasons for the additional time, and
submit a fee of $310.
The Planning Director approves the extension request if it can be determined that the applicant
was not responsible for the delay, including, but not limited to, delay by a state or federal
agency in issuing a required permit.
OPTIONS / DIRECTION
Staff seeks Board direction on which of the following courses of action, if any, to take related to
development approval extensions:
1. Determine that the current development approval time period and opportunity to apply for up
to three 1-year extensions is sufficient time to initiate a development.
2. Direct staff to initiate a text amendment to allow additional extensions for land use permits
unless such an extension would violate any time limitation on the permit imposed by Oregon
state law. If the Board directs staff to pursue this course of action, then the following issues
also need to be discussed:
a. Does the extension automatically extend all applicable permits or are applicants
required to apply for additional extensions? Jurisdictions with shorter approval and
extension periods than Deschutes County tend to automatically extend all applicable
permits because the majority of permits expire in the same general time frames.
However, Deschutes County’s 5-year approval and extension period creates significant
variations in the time frame for expirations of approvals and extensions. An automatic
extension would be significantly more complicated to administer than extending or
expanding the current system of applicant initiated 1-year extensions in Deschutes
County. Staff recommends an applicant initiated 1-year or 2-year extension process be
considered rather than an automatic or “blanket” extension.
b. What is the time limit for additional extensions? Does it follow the current 1-year
extension process or is it a different period of time, such as 2-year extensions? Many of
the jurisdictions granting extensions are doing so for 2-year periods. Staff recommends
one 2-year extension.
c. If applicants are required to apply for extension requests, how many additional
extension requests may be allowed? Some jurisdictions, including Bend and Crook
County, are allowing one extension for 2-years, and then determining at that time
whether additional extensions should be authorized. Similar to b. above, staff
recommends granting applicants one 2-year extension.
d. Is there a sunset date on the text amendment? Jurisdictions are approving additional
permit extensions due to the current economic situation with sunset dates. Crook
County and Bend have approved extensions for two years. Staff recommends the text
amendment sunset 2-3 years following adoption. The Board will need to make a finding
to support the text amendment. It will be a more defensible finding if the text
amendment is for a limited duration. For example, the Board may make a determination
that there is a county-wide need for such extensions because the current state of the
economy is not conducive to property development and the Board desires to save land
owners with land use approvals the expense of reapplying based on the continuing
economic downturn for a period of a “X” years.
If the Board supports initiating such a text amendment, staff will recommend the ordinance be
adopted by emergency based on the findings made to support the ordinance.