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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. as/cdd/
MEMORANDUM
DATE: June 1, 2010
TO: Board of County Commissioners
FROM: Cynthia Smidt, Associate Planner
Kevin Harrison, Principal Planner
RE:
Board consideration to initiate review of Hearings Officer's decision denying the
request to establish room and board arrangements for up to five unrelated persons
in an existing residence in the Exclusive Farm Use zone. File No.: CU -10-2.
BACKGROUND
Before the Board is the request for the Board to initiate review of Hearings Officer's decision of
CU -10-2 for Terry and Candice Anderson. The Andersons applied for overnight
accommodations in the Exclusive Farm Use (EFU) zone. During the preparation of the staff
report, Staff directed the Andersons to address the criteria for a "bed and breakfast inn"
because of similar characteristics to the proposed use of "room and board arrangements for up
to 5 unrelated persons," the use as listed in the EFU zone. The opponent to this application
pointed out that bed and breakfast inn is not a use listed in the EFU zone. Therefore, since the
EFU zone is a zoning district that comes directly from state statute and administrative rule, the
Hearings Officer correctly found that a bed and breakfast inn, as defined by County Code, is a
distinct use from room and board arrangements and could not be permitted. The Hearings
Officer also found that the application could otherwise be approved as submitted with
appropriate conditions of approval.
Because staff feels some responsibility for the adverse outcome for the applicants, and because
the applicants originally applied for the use as listed in the EFU zone, staff recommends that the
Board initiate review of this decision pursuant to DCC 22.28.050 and limit the issues on appeal
to those, which served as the Hearings Officers basis for denial. (See: DCC 22.32.027(B)(4))
REVIEW BY BOARD
As detailed in DCC 22.28.050, the Board may initiate an administrative action or a lower
Hearings Body's decision within 12 days of the date of the mailing of the final written decision.
The Board should review the Planning Division request to determine that it is sufficiently specific
so that the Board is able to respond to and resolve each issue in dispute.
File No.: CU -10-2 Page 1 of 2
Quality Services Per formed with Pride
If the Board decides to hear the appeal, the review shall be on the record unless the Board,
under its own motion, decides to hear the appeal de novo (DCC 22.32.027(B)(1) and (3)). As
noted above, the Planning staff has requested the Board limit the issues on appeal to those,
which served as the Hearings Officers basis for denial. Per DCC 22.32.027(B)(4), the Board,
may, at its discretion, determine that it will limit the issues on appeal to those listed in the notice
of appeal, or to one or more specific issues from among those listed on the notice of appeal.
DECLINING REVIEW
If the Board of County Commissioners decides that the Hearings Officer's decision shall be the
final decision of the County, then the Board shall not initiate review of the decision and parties of
interest may appeal the Hearings Officer's decision as provided by law. The decision on the
land use application becomes final within 12 days of the mailing of the Hearings Officer's
decision.
STAFF RECOMMENDATION
Staff recommends the Board initiate review of this decision because staff takes some::
responsibility for the adverse outcome for the applicants and that because the applicant,
originally applied for the use as listed in the EFU zone.
SCHEDULE
This item is scheduled for the Board's regular meeting on June 7, 2010. Please feel free to
contact me at your convenience with any questions or concerns.
Attachments:
1. Order 2010-032
2. Hearings Officer decision for file CU -10-2
File No.: CU -10-2 Page 2 of 2
REVIEWED
LEGAL COUNSEL
For Recording Stamp Only
BEFORE THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON
An Order Initiating Review of Hearings Officer's
Decision in File no. CU -10-2 * ORDER NO. 2010-032
WHEREAS, Applicants, Terry and Candice Anderson, requested overnight accommodations in the EI U
zone, which was denied by the Hearings Officer's in application number CU -10-2; and
WHEREAS, County Planning staff brought the Hearings Officer's decision to the Board ;or
consideration of whether or not to initiate review of the Hearings Officer's decision pursuant to DCC 22.28.050;
and
WHEREAS, the Board has given due consideration as to whether to initiate review of this application;
now, therefore,
THE BOARD OF COUNTY COMMISSIONERS OF DESCHUTES COUNTY, OREGON, HEREI3Y
ORDERS as follows:
Section 1. The Board hereby initiates review of application number CU -10-2 pursuant to DCC
22.28.050.
Section 2. The review of the Board shall be heard de novo, limited to the criteria on which the heari 1gs
officer based his denial of the application.
Section 3. All other issues shall be reviewed on the record with legal arguments but no new evidence
allowed for those issues.
Section 4. Staff shall set a hearing date and cause notice to be given to persons or parties entitled to
notice pursuant to DCC 22.24.030 and 22.32,030.
Dated this of , 2010 BOARD OF COUNTY COMMISSIONERS
OF DESCHUTES COUNTY, OREGON
ATTEST:
DENNIS R. LUKE, Chair
ALAN UNGER, Vice Chair
Recording Secretary TAMMY BANEY, Commissioner
PAGE 1 OF 1 - ORDER NO. 2010-032 (6/7/10)
DECISION OF DESCHUTES COUNTY HEARINGS OFFICER
FILE NUMBER:
APPLICANT/OWNER:
REQUEST:
STAFF CONTACT:
HEARING HELD:
RECORD CLOSED:
CU -10-2
Terry and Candice Anderson
18540 Plainview Road
Bend, Oregon 97701
The applicant is requesting a Conditional Use permit to
establish room and board arrangements for up to five
unrelated persons in an existing residence (bed and breakfast
inn). The subject property is within the Exclusive Farm Use
zone.
Cynthia Smidt, Associate Planner
March 30, 2010
April 23, 2010
I. APPLICABLE CRITERIA:
Title 18, Deschutes County Zoning Ordinance
A. Chapter 18.16, Exclusive Farm Use Zone
B. Chapter 18.128, Conditional Uses
Title 22, Deschutes County Development Procedures Ordinance
II. BASIC FINDINGS:
A. LOCATION: The property is located at 18540 Plainview Road, Bend and is
identified on Deschutes County Assessor's Map 15-11-34C as tax lot 500.
B. LOT OF RECORD: Deschutes County has recognized this subject property as a
legal lot of record pursuant to being Parcel 1 of Partition Plat 1995-35.
C. ZONING: The subject property is zoned Exclusive Farm Use — Sisters/Cloverdale
subzone (EFU-SC).
D. SITE DESCRIPTION: The subject property is approximately 39.82 acres in size
and irregularly shaped. The topography is relatively level for majority of the
property except in the north where the land steeply slopes at the base of a high
ridge. The site is vegetated with pasture grasses, native grasses and groundcover,
and scattered juniper trees. The subject property is currently developed with a
CU -10-2 (Anderson)
Hearings Officer Decision Page 1 of 16
7,851 square foot single-family dwelling (see file CU -97-31), a pole bam, loafing
shed, a paved driveway, and fenced irrigated horse pasture. The applicant indicated
that the property is served by a domestic well, an agricultural well for irrigation,
and a "1,500 gallon concrete tank and 600 feet of leach field." Plainview Road, a
county -maintained gravel road abuts the property to the south. According to the
applicant's Burden of Proof Statement, the closest paved roadway is Fryrear Road
located approximately .8 mile to the west. The structural development on the
property is located in the southeastern region of the property, approximately 150
feet west of the eastern boundary and 600 feet north of the road. The staff report
indicates that according to the Flood Insurance Rate Map (FIRM) for Deschutes
County and the National Wetlands Inventory, respectively, the subject property is
not located in the 100 -year flood plain or contains wetlands. The staff report
further indicates that these findings were verified by a staff site visit on February
23, 2010.
E. SURROUNDING LAND USES: The area surrounding the subject property
consists of rural residential and farm zoned parcels of varying sizes ranging from
five (5) acres to over 50 acres. Surrounding the property in all directions are
developed or vacant farm -zoned properties. Some properties have small-scale
(hobby) farm uses present while other properties are devoid of any agricultural
uses. To the northwest and west of the property, there are residentially zoned
subdivisions including Fryrear Ranch, Duke, and Sun Mountain Ranches and to the
south is the Snow Creek Ranch subdivision. Abutting the property in the north and
about 100 feet from the southeast property corner is large farm -zoned parcels under
the management of the United States Department of Interior's Bureau of Land
Management (BLM). Plainview Road, County maintained, abuts the property to
the south. Highway 20 lies to the southwest approximately 3,700 feet and the
closed paved road is Fryrear Road, approximately 4,000 feet to the west. The City
of Sisters is approximately seven (7) miles northwest of the property. Zoning in the
area is a mixture of Multiple Use Agricultural (MUA10), Exclusive Fann Use
(EFU), and Flood Plain (FP).
F. PROPOSAL: The applicant is proposing to establish room and board
arrangements for up to five unrelated persons in the existing single-family
residence (bed and breakfast inn). The applicant proposes to use three (3) rooms in
the existing dwelling for no more than 5 unrelated guests.' No structural
modifications to the dwelling are proposed for this use. The use will operate year-
round and breakfast will be the only meal served. Guest parking is available on -
The burden of proof initially submitted by the applicant requested use of four (4) rooms
in the existing dwelling. This was subsequently reduced by the applicant to the proposed
use of three (3) rooms in order to meet the requirements of Section 18.128.310 (Bed and
Breakfast Inn) of the Deschutes County Zoning as set forth in a letter regarding Incomplete
Application to the applicant from the Deschutes County Community Development
Department dated February 17, 2010.
CU -10-2 (Anderson)
Hearings Officer Decision Page 2 of 16
site as shown in the submitted site plan. The applicant has submitted a burden of
proof statement, and other documents, and a plot plan in support of this application.
G. PUBLIC AGENCY COMMENTS: The Planning Division mailed notice to
several agencies and received continents from the Deschutes County Building
Safety Division, the Deschutes County Environmental Health Division, and the
Deschutes County Road Department. Those comments are contained in the record
and are either summarized or set forth verbatim in the staff report. For this reason,
they are not repeated here. To the extent the comments pertain to the applicable
approval criteria, they are addressed in the findings. The following agencies did
not respond or had no comments: Cloverdale Fire Department, Deschutes County
Assessor's Department, Deschutes County Property Address Coordinator,
Deschutes County Transportation Planner, Oregon Department of Transportation,
and Watermaster — District 11.
H. PUBLIC COMMENTS: The Planning Division sent notice of this proposal to all
property owners within 750 feet of the subject property. Two neighboring property
owners, Ray Seidler and Tom and Mary Tomjack, submitted comments. Tom and
Mary Tomjack opposed the proposal and expressed concern about impacts to the
roads, property values, and rural character of the neighborhood. Ray Seidler raised
concerns about the impacts of the business on the shared domestic well. All
comments are incorporated in the record by reference and available for review.
Further testimony was provided by or on behalf of Seidler and Tomjack at the
public hearing on March 30, 2010. To the extent that testimony is relevant, it is
addressed in the findings below.
I. NOTICE REQUIREMENT: The applicant complied with the posted notice
requirements of Section 22.23.030(B) of Deschutes County Code (DCC) Title 22.
The applicant submitted a Land Use Action Sign Affidavit, dated January 10, 2010,
indicating the applicant posted notice of the land use action on January 27, 2009.
At the public hearing, applicant testified that the correct date for execution of the
affidavit should have been January 27, 2010, contemporaneously with the actual
posting of the Land Use Action Sign. The Hearings Officer notes that the Affidavit
also bears a notary's statement that it was "subscribed and sworn" on January 27,
2010. Correction of this scrivener's error is noted for the record.
J. REVIEW PERIOD: The application was submitted to the Planning Division on
January 22, 2010. An incomplete letter was sent on February 17, 2010 and the
applicant responded on February 24, 2010. Therefore, the Planning Division
deemed this application complete and accepted it for review on February 24, 2010.
Notification of the public hearing was posted in the Bend Bulletin Newspaper on
March 7, 2010. As of the date of the public hearing for this matter, March 30,
2010, staff estimated 116 days remained on the 150 -day review clock for this land
use application. Although the record was held open for a period of three weeks
subsequent to the hearing, and 3 additional days were allowed at the request of an
CU -10-2 (Anderson)
Hearings Officer Decision Page 3 of 16
opponent to supplement the record, the 150 -day period was not extended by those
actions. The 150 -day period therefore expires on Saturday, July 24, 2010.
III. CONCLUSIONARY FINDINGS:
As a practical matter, this application primarily raises two major issues: (1) whether a
"bed and breakfast inn" is an allowed conditional use in the EFU zone as a form of "room
and board arrangement" based upon 2009 changes to the Deschutes County Zoning
Ordinance at Section 18.16.030(T); and (2) whether the applicant can utilize a shared well
that is limited by agreement to domestic purposes and is under the ownership of a third
party, as the source of water for the room and board arrangements (bed and breakfast inn)
without the consent of that third party. Those issues, as well as numerous other matters of
lesser controversy, are addressed below under the specific criteria of the Deschutes County
Zoning Ordinance that are applicable to this request.
Title 18, Deschutes County Zoning Ordinance.
A. CHAPTER 18.16. EXCLUSIVE FARM USE ZONE.
1. Section 18.16.030. Conditional Uses Permitted — High Value and Nonhigh
Value Farmland.
The following uses may be allowed in the Exclusive Farm Use zones on either
high value farmland or nonhigh value farmland subject to applicable
provisions of the Comprehensive Plan, DCC 18.16.040 and 18.16.050, and
other applicable sections of DCC Title 18.
T. Room and board arrangements for a maximum of five unrelated persons
in an existing residence. If approved, this use is subject to the recording
of the statement listed in DCC 18.16.020(J)(6).
FINDING: The applicant proposes to establish room and board arrangements for a
maximum of five unrelated persons in an existing single-family residence. The applicant
proposes to use three (3) rooms in the existing dwelling. No modifications to the structure
are proposed. As indicated above, the proposed use is subject to DCC 18.16.040 and
18.16.050, and other applicable sections. Planning staff finds the proposed room and
board arrangements are in effect the same or similar to a Bed and Breakfast Inn,2 and takes
the position that the criteria for a bed and breakfast inn are also to be regarded as
2
Deschutes County Codc, Section 18.04, defines "Bcd and Breakfast Inn" to mean:
"Bed and breakfast inn" means a single-family dwelling unit where lodging and meals are
provided for compensation, in which no more than three guest rooms are provided for no
more than eight guests. A guest shall not rent for a time period longer than 30 consecutive
days.
CU -10-2 (Anderson)
Hearings Officer Decision Page 4 of 16
requirements of the "board and room arrangements" proposed by the applicant.3 Staff
appears to reach this position at least partially on the basis that DCC 18.16.030 also
subjects conditional uses to "other applicable sections of DCC Title 18," finding those
other sections to include the "bed and breakfast inn" provisions of DCC 18.128.310.
Significantly, the applicant either concurs in or at least accepts that analysis, since the
applicant's burden of proof addresses the separate requirements for a Bed and Breakfast
Inn set forth in the conditional use chapter, and indicates that the applicant will comply
with each of those criteria. Therefore, I will regard this application solely as an application
for a "bed and breakfast inn" as a form of room and board arrangements.
Opponent argues that the Bed and Breakfast Inn use was "repealed" in 2009 by Deschutes
County, which previously specifically allowed bed and breakfast inns as a conditional use
in the EFU zone.4 By letter dated March 30, 2010, attorney Liz Fancher, representing a
neighboring property owner, Mr. Seidler, based this argument on the premise that in other
Deschutes County land use cases, the county has interpreted situations where a use is
specifically authorized in one zone, but not specifically listed in another zone to imply that
the specific use is prohibited in zones where it is not specifically listed. Although Mr.
Seidler's attorney neglected to specify any Deschutes County land use cases for this
proposition, I concur that such an approach is consistent with general principles of
statutory construction and apply it here.5 In this case, a bed and breakfast inn continues to
be specifically listed in the general definitions section (DCC 18.04), the conditional use
section (DCC 18.318.320), the MUA zone (DCC 18.32.030(U), RR -10 zone (DCC
18.60.030(L), and a number of other zones in the Deschutes County Code. The continued
use of "bed and breakfast inn" elsewhere in the Deschutes County Code, coupled with its
explicit removal from the EFU ordinance in 2009, strongly implies that it is prohibited in
the EFU zone.
3 The applicant does not specifically identify the request as one for a "bed and breakfast
inn," although the applicant clearly regards the provisions governing bed and breakfast
inns in the conditional use chapter (DCC 18.128.310) to be applicable, and addresses how
those criteria will be met in the application. The staff report adds a parenthetical reference
to "bed and breakfast inn" in the staff report to the description of the request initially
submitted by the applicant.
4 With the adoption of Ordinance 2009-014, Deschutes County removed the prefatory
wording "bed and breakfast inn" from the list of conditional uses permitted on High Value
and Nonhigh Value farmland in the EFU zone under Deschutes County Code Section
18.16.030 (U), leaving the remainder of that section in place. The changes to Section
18.16.030(U) by Ordinance 2009-014 are as follows (deletions crossed out; additions
underlined): U,T. Bed and brcahfast inn, with Rt'oom and board arrangements for a
maximum of five unrelated persons in an existing residence. 1/ approved, this use is
subject to the recording of the statement listed in DCC 18.16.020(J)(6).
5 Opponent's attorney cites specifically to an appellate court decision from another county
for support for this proposition (Clatsop County v. Morgan, 19 Or App 173, 178-79, 526
P2d 1393 (1974)), but neglected to point out any Deschutes County land use case
involving that principal. Nonetheless, I concur that such an approach is consistent with
general principles of statutory construction and apply it here.
CU -10-2 (Anderson)
Hearings Officer Decision Page 5 of 16
As noted above, the applicant impliedly argues that a bed and breakfast inn is an allowed
conditional use in the EFU zone because it is a form of room and board arrangement.6
However, any argument that a bed and breakfast inn is a form of room and board
arrangement is made more complicated by the lack of clear definition for critical terms in
both Deschutes County ordinances and state law. State law describes those uses that may
be allowed by Deschutes County in the EFU Zone. Only those uses listed in ORS 215.283
and in OAR 660-033-0120 may be allowed by the county. Room and board arrangements
are an allowed conditional use in an EFU zone under both the Deschutes County Code and
applicable state law. Unfortunately, neither state law nor the Deschutes County Ordinance
defines what is meant by those arrangements. A "bed and breakfast inn" is not specifically
listed as a conditional use in the EFU zone under applicable state law or regulations (see,
ORS 215.283 and OAR 660-033-0120) or under the 2009 revisions to the Deschutes
County EFU zone ordinance. Although a "bed and breakfast inn" is defined in the
Deschutes County Code, that term is undefined in state law.7
The bottom line is that there is ambiguity in the meaning of those terms, and specifically it
is unclear from the text of the statutes and ordinances themselves whether a "bed and
breakfast inn" is a kind of "room and board arrangement" contemplated by either local
ordinances or state statutes. Moreover, in interpreting ambiguity in uses possibly allowed
in the EFU zone, it is important to keep in mind that the overarching purpose of the EFU
zone is "to preserve and maintain agricultural lands and to serve as a sanctuary for faun
uses." DCC 18.16.010(A). Under those circumstances, a narrow construction of allowable
conditional uses seems appropriate. I am persuaded that a "bed and breakfast inn" most
clearly contemplates short-tenn guest status that is commercial in character, while "board
and room arrangements" generally connotes longer-tenn arrangements that are essentially
residential in characters Thus, I find the terns do not have the same meaning, nor is a bed
and breakfast inn a fonn of room and board arrangements for purposes of the ordinance.
6 Opponents have asserted that the applicant must proceed, if at all, to seek conditional use
for a bed and breakfast inn as a "home occupation." I express no opinion as to whether
such a use would be allowed as a "home occupation," since the application was not
submitted or argued on that basis.
Provisions of the state's food service health code do define a similar tenn, "bed and
breakfast facility," for purposes of the health code. ORS 624.010(2).
8 While the Deschutes County Code clearly specifies that a "bed and breakfast inn"
involves stays of 30 days or less, it is silent with regard to the length of stays involved in
room and board arrangements. It is instructive to look elsewhere to see how these issues
are handled. For example, in the Marion County EFU zone, both bed and breakfast inns
and room and board arrangements are allowed as separate conditional uses. This supports
the idea that they are not the same thing. Similarly, Wasco County treats both Room and
Board or Bed and Breakfast arrangements as conditionally allowed "home occupations",
and specifically defines bed and breakfast arrangements as involving stays of 30 days or
less, and room and board arrangements to involve month-to-month rental.
CU -10-2 (Anderson)
Hearings Officer Decision Page 6 of 16
In sum, although it is possible to argue that the concept of "board and room arrangements"
is broad enough to encompass a "bed and breakfast inn", the elimination of that term from
the EFU zone provisions, the arguments advanced by opponents, the overarching purpose
of the EFU zone, and the text of applicable state statutes and regulations, lead me to
conclude that a bed and breakfast Inn is not allowed in the EFU zone as a conditional use
by either the Deschutes County Code, nor state law.
For the foregoing reasons, the Hearings Officer finds the applicant has failed to either
demonstrate that a Bed and Breakfast Inn is independently allowed in the EFU Zone
or that it is a kind of room and board arrangement" that is allowed in that zone.
Therefore, I find the applicant's proposal simply does not satisfy all applicable
approval criteria in DCC Section 18.16.030, that it is not capable of being satisfied
with conditions, and cannot be approved. Nevertheless, because this decision may be
appealed to the Board of County Commissioners (hereinafter sometimes referred to
as "board"), I include in this decision findings on the remaining approval criteria.
If this decision is appealed, and the finding above reversed on appeal, the requirements of
DCC 18.16.020(J)(6) are applicable according to the terms of DCC 18.16.030(T). If a
conditional use is approved, DCC 18.16.020(3)(6) requires the property owner to sign and
record a waiver of remonstrance, in the deed records for the County, binding the
landowner, and the landowner's successors in interest, prohibiting them from pursuing a
claim for relief or cause of action alleging injury from fanning or forest practices for which
no action or claim is allowed under ORS 30.936 or 30.937. Based on all of the foregoing,
1 find that if the board approves the applicant's proposal on appeal, such appeal should be
subject to a condition of approval requiring recording a waiver of remonstrance as
provided in DCC 18.16.020(J)(6).
2. Section 18.16.040. Limitations on Conditional Uses.
A. Conditional uses permitted by DCC 18.16.030 may be established subject
to ORS 215.296 and applicable provisions in DCC 18.128 and upon a
finding by the Planning Director or Hearings Body that the proposed use:
1. Will not force a significant change in accepted farm or forest practices
as defined in ORS 215.203(2)(c) on adjacent lands devoted to farm or
forest uses; and
2. Will not significantly increase the cost of accepted farm or forest
practices on surrounding lands devoted to farm or forest use; and
3. That the actual site on which the use is to be located is the least
suitable for the production of farm crops or livestock.
FINDING: The submitted application states, and as observed on a February 23, 2010 site
visit by staff, there are no forest uses in the area, as the only trees in the area are juniper
trees, which have no commercial timber value. Farm -zoned parcels of varying size,
ranging from five acres to over 50 acres, surround the property. Uses adjacent to the
subject property are a mixture of rural residential, open space, small-scale farm uses, and
an Alpaca farm. To the northwest and west there are residentially zoned subdivisions
including Fryrear Ranch, Duke, and Sun Mountain Ranches in which properties range in
CU -10-2 (Anderson)
Hearings Officer Decision Page 7 of 16
size from one (1) to 10 acres. In addition, south of the property is farm -zoned Snow Creek
Ranch subdivision. To the north and southeast, there are large BLM parcels. The farming
in the area appears to be generally irrigated pasture, livestock grazing, and grass hay. The
closest farming practice, an Alpaca farm, is located to the east on tax lot 100 of tax map
15-11-34C. The existing development on-site is located along the eastern boundary
approximately 600 feet north of Plainview Road and thus provides for expansive yard
setbacks to buffer the use from adjacent farm uses. Submitted comments from a
neighboring property owner raised concerns about the impact of this proposed business on
the farm use characteristics of this area and whether this proposed business would set a
precedent of future businesses. However, staff expressed the view that the proposed use
would not force a significant change in these farm practices nor significantly increase the
cost of accepted farming practices occurring on the adjacent lands. Based upon the
distances from the proposed Bed and Breakfast operation to surrounding agricultural uses,
as well as the size and scope of the proposed use, I concur in that analysis and specifically
find that the proposed use will not force a significant change in accepted farm or forest
practices as defined in ORS 215.203(2)(c) on adjacent lands devoted to farm or forest uses
and will not significantly increase the cost of accepted farm or forest practices on
surrounding lands devoted to farm or forest use. Further, the room and board
arrangements will occur in an existing single-family dwelling. I therefore also find that the
actual site of the proposed operation is the least suitable for the production of farm crops or
livestock since it is already devoted to residential use. For the foregoing reasons, the
criteria of DCC Section 18.16.040(A) are satisfied.
3. Section 18.16.070. Yards.
FINDING: The applicant is proposing no new structures for the site. Therefore, these
criteria are not applicable.
B. CHAPTER 18.128. CONDITIONAL USES
1. Section 18.128.015. General Standards Governing Conditional Uses.
Except for those conditional uses permitting individual single-family
dwellings, conditional uses shall comply with the following standards in
addition to the standards of the zone in which the conditional use is located
and any other applicable standards of the chapter:
A. The site under consideration shall be determined to be suitable for the
proposed use based on the following factors:
1. Site, design and operating characteristics of the use;
FINEIING: The site of the proposed bed and breakfast inn will be located in an existing
single-family dwelling. The subject property is 39.82 acres and is currently development
with a 7,851 square foot single-family dwelling, pole barn, and shed in the southeast region
of the property. The dwelling is approximately 150 feet west of the eastern boundary and
600 feet north of Plainview Road. According to the applicant, the nearest dwelling is 900
feet to the south. The property has a private paved driveway that leads to the dwelling and
barn. Guests would access the inn from Plainview Road and park on the property with the
CU -10-2 (Anderson)
Hearings Officer Decision Page 8 of 16
parking area located near the dwelling and barn. The inn would operate year-round and
breakfast will be the only meal served to the guests. Based on the description of the
existing development design and operating characteristics in the applicant's written
statement and the materials submitted with the application, staff expressed the view that
the site under consideration is suitable for the proposed bed and breakfast inn.
Opponent Seidler argues that the proposed use of water for the board and room
arrangements (bed and breakfast inn) from a shared well located on land belonging to Mr.
Seidler violates DCC 18.128.015(A)(1). DCC 18.128.015(A)(1) requires that the site be
suitable for the proposed use based on its site, design and operating characteristics. The
opponent asserts that both the existing well agreement affecting the property and other
restrictive covenants make it clear that such use is not permitted. There is no other
agreement between the parties that would allow such use. Opponents argue that in the
absence of an agreement between the parties for such use, the applicant will not have a
water supply that is appropriate for the use.9 The Hearings Officer does not typically
interpret private agreements, such as well agreements or restrictive covenants, when such
matters are at issue between private parties. Under the circumstances, I find that the
applicant has not met his burden of proof to establish that this criterion is satisfied.10
However, I also find this criterion can be satisfied with imposition of a condition of
approval requiring the applicant to either (a) enter into a specific agreement with the other
party(ies) to the well agreement allowing such use; (b) obtain a final enforceable judgment
from an appropriate court determining that the applicant has the right to use water from the
Seidler well for the proposed use; or (c) connect to another water source acceptable to
Deschutes County. For the foregoing reasons, 1 find if the board approves the applicant's
proposal on appeal, such approval should be subject to the recommended condition of
approval described above.
For the foregoing reasons, and with the imposition of the recommended condition of
approval described above, I find that the site under consideration is suitable for the
proposed use based on the site, design and operating characteristics of the use.
2. Adequacy of transportation access to the site; and
9 The County Environmental Health Division has indicated that it will require the well to
become a public water system if the proposed use is approved. Opponents further assert
that use of the Seidler well to supply water for the proposed use will also violate DCC
18.128.310 by creating an unreasonable disturbance to an area resident, Mr. Seidler by
requiring him to operate a public water system, purchase water rights, and assume legal
obligations that he does not wish to assume. Those arguments will be addressed separately
below.
1° See also the Hearings Officer's decision in CU -92-99, where the proposed use of a
shared well was rejected on the basis that it failed to meet the requirements of DCC
18.128.015(A)(1). While not dispositive in this case, I find the reasoning employed in that
earlier decision to be persuasive, and reach a similar conclusion here with regard to this
matter.
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FINDING: The proposed bed and breakfast inn would be accessed via Plainview Road
onto a paved driveway. The County classifies Plainview Road as a rural local road and
comments received from the Road Department indicates the roadway is a gravel surface of
20 feet wide and is County maintained. Staff observed on a February 23, 2010 site visit,
that the Plainview Road travel surface exceeds 20 feet in most places and is in good to
excellent graveled condition. Staff believes that having a condition of approval limiting
the number of guests to five, minimum road impacts can be expected to Plainview Road.
However, one neighbor expressed concern that traffic impacts from the bed and breakfast
would be detrimental to the roadway. The County Road Department concluded that the
application would generate approximately 28 weekday trips, which would not affect the
road, nor require any further dedication or road improvements. The applicant also notes
that the applicant raised a family of six children (only one of whom currently resides on
the property) on the site. It is difficult to envision that the number of trips likely to be
generated by the proposed use would exceed the use that might reasonably have been made
of the road by a larger single family, such as previously resided at the location. Based
upon all of the foregoing, I find that the subject property is suitable for the proposed use
considering transportation access.
3. The natural and physical features of the site, including, but not
limited to, general topography, natural hazards and natural resource
values.
FINDING: The proposed bed and breakfast inn will be located in an existing dwelling
and no improvements to the dwelling are required to accommodate the use. The natural
and physical features of the site are limited, as the property has been disturbed through the
development of the dwelling, driveway, barn, shed, and faun use including pasture and
fences. The staff report indicates that staff is unaware of any natural hazard on the site,
and no contrary evidence has been presented. For the foregoing reasons, I find the subject
property is suitable for the proposed use considering the natural and physical features of
the site, including but not limited to, general topography, natural hazards and natural
resource values.
B. The proposed use shall be compatible with existing and projected uses on
surrounding properties based on the factors listed in DCC 18.128.015(A).
FINDING: The proposed use would be located in an area surrounded by rural residential
and farm use properties of varying sizes. To the northwest and west of the property there
are residentially zoned subdivisions including Fryrear Ranch, Duke, and Sun Mountain
Ranches and to the south is the Snow Creek Ranch subdivision. To the north and
southeast, there are large BLM parcels. The subject property is approximately 39.82 acres
and developed with an existing dwelling, barn, shed, and irrigated pasture. The bed and
breakfast inn will occur in the existing dwelling, which is setback about 150 feet and 495
feet from the eastern and western boundary, respectively. The dwelling is setback 1,530
feet and 600 feet, respectively from the northern and southern boundaries. The closest
residences are each approximately 900 feet to the south. The next closest residence is
about 1,000 feet. Neighboring private properties are developed and undeveloped and are
CU -10-2 (Anderson)
Hearings Officer Decision Page 10 of 16
of greater distance to the subject property. The closest farming practice, an Alpaca farm, is
located to the east on tax lot 100 of tax map 15-11-34C.
Staff also expressed the view that the proposed use is compatible with the surrounding
properties because the existing development has sizable yard setbacks thus buffering the
neighbors in all directions. In addition, Plainview Road borders along the southern
boundary and thus providing a buffer to those properties to the south. Further, vehicular
access is taken from Plainview Road, an improved local rural County road, onto a paved
driveway that is located in the southeast corner of the property. The driveway location
provides for buffering from properties to the south, west, and east. Minimal traffic is
anticipated to be generated because the number of guests will be limited to five. Lastly,
the bed and breakfast inn will occur in an existing residence where no additional
improvements are required to accommodate the use.11
As stated in the findings above regarding Section 18.1.28.015(A), the applicant's reliance
upon use of a shared well means that the proposal fails to satisfy the criteria of DCC
18.128.015(A)(2) with regard the site, design and operating characteristics of the use. That
analysis is incorporated here with regard to the compatibility with existing and projected
uses on surrounding properties, specifically the property belonging to Mr. Seidler upon
which the shared well is located. Again, however, I find this criterion can be satisfied with
imposition of a condition of approval requiring the applicant to either (a) enter into a
specific agreement with the other party(ies) to the well agreement allowing such use; (b)
obtain a final enforceable judgment from an appropriate court determining that the
applicant has the right to use water from the Seidler well for the proposed use; or (c)
connect to another water source acceptable to Deschutes County. For the foregoing
reasons, I find if the board approves the applicants' proposal on appeal, such approval
should be subject to the recommended condition of approval described above.
With the imposition of the recommended condition of approval described above. 1 find
that the site under consideration is compatible with existing and projected uses on
surrounding properties based on the factors listed in DCC 18.128.015(A).
2. Section 18.128.310. Bed and Breakfast Inn.
The Hearings Officer acknowledges that comments were submitted into the record by
neighboring property owners reflecting concern that the proposed use would be a detriment
to the rural character of the area, including the roadway, and impact property values.
Neighboring property owners also expressed concern about the potential to set a precedent
with the conversion of resource and residential lands into commercial uses. The roadway
issue was addressed above under the topic of adequacy of transportation access to the site.
That analysis is incorporated here by reference. With regard to the other points raised by
opponents, no evidence was submitted by opponents to substantiate the opponent's
position with regard to those points (impact on rural character, property values, and
precedent for conversion into commercial uses), and therefore, I believe the applicant has
satisfied his burden of proof with regard to those matters.
CU -10-2 (Anderson)
Hearings Officer Decision Page 11 of 16
A. Bed and breakfast inns shall be restricted to owner -occupied single-family
residences.
FINDING: The proposed bed and breakfast will occur in an existing single-family
residence. The owner of the residence as listed on the County Assessor's records is Teny
Anderson who, according to the submitted application, lives at the dwelling along with his
wife, Candice Anderson, and one daughter. Terry and Candice Anderson will be operating
the bed and breakfast inn. I find that the provision of room and board arrangements (bed
and breakfast inn) will occur in an owner -occupied single-family dwelling and, thus, this
criterion is satisfied.
B. Bed and breakfast inns located in farm or forest zones shall utilize
existing dwellings or dwellings conforming to the requirements of those
zones relating to single-family dwellings.
FINDING: The proposed bed and breakfast inn will be located in the EFU zone and will
use the existing single-family dwelling on the property. This criterion is met.
C. No more than three sleeping rooms shall be available for the
accommodation of inn visitors.
FINDING: The proposal identifies three bedrooms in the existing dwelling that will be
used to accommodate the guests. To ensure compliance with this criterion, if the board
approves the applicant's proposal on appeal, such approval should be subject to a condition
of approval requiring that no more than three sleeping rooms shall be available for room
and board arrangements. As proposed to be conditioned, this criterion is satisfied.
D. No more than eight guests shall be accommodated at any one time.
FINDING: As previously discussed, the EFU zone limits the number of unrelated persons
having room and board arrangements to five. The applicant proposes to accommodate no
more than five guests at any one time. Staff recommended it be made a condition of any
approval that the applicant be prohibited from having more than five guests with room and
board arrangements at any one time. I concur. Therefore, if the board approves the
applicant's proposal on appeal, a condition of approval should be imposed prohibiting the
applicant from having more than five guests at any one time. As proposed to be
conditioned, this criterion is satisfied.
E. Occupancies shall be limited to not more than 30 consecutive days.
FINDING: The applicant indicates that guests will have a limited occupancy of 30
consecutive days or less. To ensure compliance with this criterion, staff recommended this
be added this as a condition of any approval. I concur in the staff's analysis. Therefore, if
the board approves the applicant's proposal on appeal, a condition of approval should be
imposed limiting occupancy by any person to not more than 30 consecutive days. As
proposed to be conditioned, this criterion is satisfied.
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Hearings Officer Decision Page 12 of 16
F. Breakfast shall be the only meal provided to inn guests.
FINDING: The application materials indicate that the applicant will provide breakfast to
guests as the only meal available. Staff recommended, as a condition of approval, that the
applicant be prohibited from serving any meal other than breakfast to guests with room and
board arrangements. I concur in that analysis. Therefore, if the board approves the
applicant's proposal on appeal, a condition of approval should be imposed prohibiting the
applicant from serving any meal other than breakfast to inn guests. As proposed to be
conditioned, this criterion is satisfied.
G. The exterior of the building shall maintain a residential appearance.
FINDING: The residential appearance of the existing dwelling will remain intact, as the
applicant proposes no changes to accommodate the use. Staff recommended, as a
condition of any approval, that the applicant be prohibited from making any changes to the
building exterior in connection with the proposed use. I concur in the staff
recommendation. Therefore, if the board approves the applicant's proposal on appeal, a
condition should be imposed prohibiting any changes to the building exterior in connection
with the proposed use. As proposed to be conditioned, this criterion is satisfied.
H. The bed and breakfast inn shall be operated in a way that will prevent
unreasonable disturbance to area residents.
FINDING: A disturbance is "something that disturbs."12 The term disturb can be further
defined, "to interfere with the arrangement, order, or harmony of; disarrange."13 Staff
expressed the view that the operation of a bed and breakfast inn would have minimal
disturbance to area residents for the reasons listed in the staff report. Those reasons
include the fact that the existing development has sizable yard setbacks that will buffer the
neighbors to the east, west, north and south. This buffering is further improved with
Plainview Road bordering along the southern boundary. Access is taken from Plainview
Road, an improved and maintained local rural County road, onto a paved driveway that is
located in the southeast corner and thus allowing a buffer from properties to the south,
west, and east. The proposed bed and breakfast inn anticipates minimal traffic generated
because the number of guests will be limited to five. Moreover, the bed and breakfast inn
will occur in an existing residence where no additional improvements are required to
accommodate the use. With regard to each of these points, I concur in the staff's analysis.
That does not, however, entirely resolve the matter.
There is one aspect of the operation of the proposed use that does create an "unreasonable
disturbance:" the use of a shared well as the proposed source of water. The County
Environmental Health Division has indicated that it will require the shared well to become
42 disturbance. Dictionary.com. Dictionary.com Unabridged. Random Nouse, Inc.
http://dictionary.reference.com/browse/disturbance (accessed: March 17, 2010).
13 disturb. Dictionary.com. Dictionary.com Unabridged. Random House, Inc.
http://dictionary.reference.com/browse/disturb (accessed: March 17, 2010).
CU -10-2 (Anderson)
Hearings Officer Decision Page 13 of 16
a public water system if the proposed use is approved.14 Opponents specifically assert that
use of the Seidler well to supply water for the proposed use will violate DCC 18.128.310
by creating an unreasonable disturbance to an area resident, Mr. Seidler, by requiring him
to operate a public water system, purchase water rights, and assume legal obligations that
he does not wish to assume. I find opponent's argument to be persuasive on this point.
For these reasons, I find that if the board approves the applicant's proposal on appeal, such
approval should be subject to a condition of approval requiring the applicant to either (a)
enter into a specific agreement with the other party(ies) to the well agreement allowing
such use; (b) obtain a final enforceable judgment from an appropriate court determining
that the applicant has the right to use water from the Seidler well for the proposed use; or
(c) connect to another water source acceptable to Deschutes County (and disconnect from
the Seidler well). As proposed to be conditioned, this criterion is capable of being
satisfied.15
I. One off-street parking space shall be provided for each guest room in
addition to parking required for the residence.
FINDING: The proposal includes three guest bedrooms to accommodate the inn guests.
Therefore, three off-street parking spaces are required. The site plan submitted with the
application shows a large gravel parking area in between the house and the pole barn at the
end of the driveway. Based on the record in this matter, this criterion is met.
J. Approval shall be conditioned upon compliance with all applicable state
building code requirements and state sanitation requirements.
FINDING: Comments received from the County's Environmental Health Division require
the applicant to obtain a septic authorization notice, a public water system certification,
and a Bed and Breakfast license. A comment from the County Building Safety Division
requires review for any change in occupancy. Staff recommended as a condition of any
approval, and before commencing operation of the bed and breakfast inn, that the applicant
be required to provide written documentation to the Planning Division that all applicable
state code requirements—including but not limited to building safety, septic, food
preparation, and domestic water- have been complied with. I concur in the staff
recommendation. For these reasons, I find that if the board approves the applicant's
proposal on appeal, such approval should be subject to a condition of approval requiring
14 Other arguments concerning use of the well are made above at the discussion of Section
18.128.015(A)(1) and are incorporated here by reference to the extent relevant.
's The Hearings Officer acknowledges that additional comments were also submitted into
the record indicating a concern that the proposed use would affect the rural character of the
area. It is unclear whether an "effect on the rural character of the area" is the kind of
"disturbance" to "area residents" contemplated by the ordinance. However, in any event, 1
find that those concerns are not well founded and that no evidence was submitted that the
"rural character" of the area would be disturbed, or that any disturbance would be
"unreasonable."
CU -10-2 (Anderson)
Hearings Officer Decision Page 14 of 16
the applicant to provide written documentation to the Planning Division that all applicable
state code requirements—including but not limited to building safety, septic, food
preparation, and domestic water have been complied with. As proposed to be
conditioned, I find that this criterion is satisfied.
K. Bed and breakfast inns in the Wildlife Area Combining Zone are subject
to the provisions of DCC 18.88.
FINDING: The proposed bed and breakfast inn is not located in the WA zone; therefore,
this criterion is not applicable.
IV. DECISION:
Based on the testimony and written evidence in the record, the foregoing Findings of Fact
and Conclusions of Law, the Hearings Officer hereby DENIES the applicant's request for
room and board arrangements (bed and breakfast inn).
If this decision is appealed to the Board of County Commissioners and the board approves
the application on appeal, the Hearings Officer RECOMMENDS SUCH APPROVAL
BE SUBJECT TO THE FOLLOWING CONDITIONS OF APPROVAL:
A. Except as described below, this approval is based on the submitted site plan and
narrative for the bed and breakfast inn. Any substantial changes to this proposal
will require a new application.
B. Prior to initiation of the use, the applicant shall either (a) enter into a specific
agreement with the other party(ies) to the well agreement allowing such use; (b)
obtain a final enforceable judgment from an appropriate court determining that the
applicant has the right to use water from the Seidler well for the proposed use; or
(c) connect to another water source acceptable to Deschutes County.
C. Prior to initiation of the use, the applicant shall obtain any necessary permits
from the Deschutes County Building Division. The applicant shall provide written
documentation to the Planning Division illustrating all applicable building codes
have been satisfied.
D. Prior to initiation of the use, the applicant shall obtain any necessary pennits and
plan review from the Deschutes County Environmental Health Division. The
applicant shall provide written documentation to the Planning Division illustrating
all applicable code requirements for septic, food preparation, and domestic water
have been met.
E. Prior to issuance of a building or septic permit, the property owner shall sign
and record a waiver, binding the property owner and the property owner' s
successors in interest, prohibiting them from pursuing a claim for relief or cause of
CU -10-2 (Anderson)
Hearings Officer Decision Page 15 of 16
action alleging injury from farming or forest practices for which not action or claim
is allowed under ORS 30.936 or 30.937.
F. Prior to the issuance of a building or septic permit, the property owner shall
record a condition of approval agreement that specifies that current and future
owners of the subject property shall comply with the approved bed and breakfast
inn. A copy of the recorded conditions of approval agreement shall be submitted to
the Planning Division. The conditions of approval agreement must state that the
applicant shall operate the bed and breakfast inn subject to the following
limitations:
1. No more than three guest rooms will be available and occupied at any one time.
2. No more than five guests will occupy the inn at any one time.
3. No guest shall stay at the inn for a period longer than 30 consecutive days.
4. No meal other than breakfast will be served to inn guests.
5. No changes to the exterior of the dwelling shall be made in connection with the
operation of the bed and breakfast inn.
G. All lighting on the subject property shall be required to comply with Chapter 15.10
of the Deschutes County Code, the Outdoor Lighting Control Ordinance. All
exterior lights shall be sited and shielded so that no direct light projects off-site.
V. DURATION OF APPROVAL:
If the decision is appealed to the Board of County Commissioners and the Board approves
the application on appeal, the Hearings Officer further recommends that approval be
subject to the following duration of approval:
The applicant shall meet all of the requirements to commence use, and actually commence
the approved use within two (2) years from the date this decision becomes final, or shall
obtain an extension of time pursuant to Section 22.36.010 of the Deschutes County Code,
or this approval shall be void.
Dated this 27`h day of May, 2010.
Mailed this 281h day of May, 2010.
ettcce.el
Gerald G. Watson, Hearings Officer
THIS DECISION IS FINAL UNLESS APPEALED WITHIN 12 DAYS OF MAILING.
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