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Planning Division Building Safety Division Environmental Health Division
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MEMORANDUM
December 31, 2007
To: Deschutes Board of County Commissioners
From: Ruth Wahl, Associate Planner
Subject: Procedure for review of Conceptual Master Plan for Thornburgh
Resort following LUBA and Court of Appeals remands
BACKGROUND
On May 10, 2006, the Deschutes County Board of County Commissioners
("Board") approved the Conceptual Master Plan (CMP) for the Thornburgh
Resort (File No. CU -05-20). The County's final approval was appealed to the
Land Use Board of Appeals(LUBA) and portions of the LUBA decision were
appealed to the Oregon Court of Appeals. Ultimately the County's decision on
the CMP has been remanded back to the Board. The remands of these
decisions are outlined below.Because the Board of County Commissioners
(Board) were the final decision making body for this decision, the remand
findings are required to be made by the Board.
REVIEW
A Conceptual Master Plan provides the framework for the destination resort. The
purpose of the CMP'is to ensure that the requirements of the County Code are
met (DCC 18.113). There are many criteria set out in this portion of the code,
most of which have been met by the applicant. There were 6 main points on
which LUBA and the Court of Appeals remanded the decision back to Deschutes
County. It is the Board's responsibility to address these points and correct the
County's Findings. These 6 points are as follows:
1. OVERVIEW: The Deschutes County Code (DCC) 18.113.060 (D)(2),
specifies that a ratio of 2:1 be maintained for individually -owned residential
units to visitor -oriented overnight lodging. The Thornburgh phasing plan
shows a total of seven phases (Phase A through G) and indicates where
on the destination resort property each phase of construction would occur.
Each phase is made up of a number of pods and there are a total of 41
pods. To demonstrate that the development of each phase will maintain
the 2:1 ratio requirement, Thornburgh also prepared an Overnight Density
Calculations chart. If the destination resort is developed with the mix of
hotel, residential, overnight and residential units shown on the Overnight
and Density Calculations chart, the 2:1 ratio is maintained for each of the
seven phases. (First Assignment of Error, page 11 of the LUBA remand)
REMAND: LUBA remanded this portion of the CMP to Deschutes County
because there are several inconsistencies in the phasing plan and the
Overnight and Density Calculations chart.
SUGGESTED CONDITION OF APPROVAL: Thornburgh shall modify the
Overnight and Density Calculations chart presented to the Board at the
appeal hearing on December 20, 2005 by replacing it with the Overnight
and Density Calculations chart included at page 25 in Thornburgh's final
legal argument to the Board.
The 75 units of overnight lodging shown in the December 20, 2005
Overnight and Density Calculations table to be developed in Phase C shall
be shown in the table to and shall be developed in Phase B, for a total of
150 units in Phase B. The Overnight and Density Calculations table will
be corrected to show the. 50 hotel units will be developed in Phase D,
where the Phasing Plan already shows the hotel will be developed.
Additionally, the legend in the Phasing Plan will be corrected to show hotel
and residential overnight lodging uses in Phase D.
Thornburgh shall submit the corrected the Phasing Plan and Overnight
and Density Calculations chart, consistent with this condition, during the
Final Master Plan .approval process.
2. OVERVIEW: The Board found that Thornburgh could provide financial
assurances for the 150 units of overnight lodging prior to recording the
final plat for Phase A. This could mean that the applicant could potentially
financially assure all the overnight units for Phase A without actually
constructing them in Phase A. (Third Assignment of Error, page 21 of the
LUBA remand)
REMAND: The County's finding which allows the financial assurance of
the 150 overnight lodging units is inconsistent with ORS 197.445(4)(b)(B)
which requires that at least 50 of the overnight units "must be constructed
prior to the closure of sale of individual lots or unit"
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SUGGESTED CONDITION OF APPROVAL: Each phase of the
development shall be constructed such that the number of overnight
lodging units meets the 150 overnight lodging unit and 2:1 ratio of
individually owned units to overnight lodging units standard set out in DCC
18.113.060(A)(1) and 18.113.060(D)(2). Individually owned units shall be
considered visitor oriented lodging if they are available for overnight rental
use by general public for at least 45 weeks per calendar year through a
single central reservation and check-in service. As required by ORS
197.445(4)(b)(B), Thornburgh shall construct at least 50 units of overnight
lodging prior to the closure of sale of individual Tots or units in the first
phase.
3. OVERVIEW: The County failed to show that the phasing plan
demonstrates how the proposed destination resort will maintain the 2:1
ratio limitation in Phase D. The County was in error to approve the CMP
without requiring that the phasing plan be amended to reflect the 62.5
units that Thornburgh plans to construct in Phase D. (Fourth Assignment
of Error, page 24 of the LUBA remand)
REMAND: Provide a phasing plan which describes phases that are
consistent with the 2:1 ratio requirement.
SUGGESTED CONDITION OF APPROVAL: Thornburgh shall submit, at
the time of the FMP application, a corrected Phasing Plan to show that the
overnight dwelling units will be developed with the hotel units (in pod 30)
during Phase D.
4. OVERVIEW: Deschutes County's Code requires that "access within the
project shall be adequate to serve the project in a safe and efficient
manner for each phase of the project." (DCC18.113.070(G)(3)(b)
(Eighth Assignment of Error, page 39 of the LUBA remand)
REMAND: The County failed to make findings that the CMP complies
with DCC18.113.070(G)(3)(b).
SUGGESTION: The Board should review the revised Vehicular Access
and Circulation Plan in the record that illustrates how roads will provide
access throughout each phase of the project and make findings with
respect to if or how the new Plan meets the requirement of the Code.
5. OVERVIEW: Gould's Fifth Assignment of error was rejected by both
LUBA and the Court of Appeals. The petitioner contended that the County
violated the subsection (G) requirement that no lot shall exceed a project
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average of 22,000 square feet, where the County allowed lots over twice
that size and even larger than one acre. LUBA and the Court of Appeals,
however, added a discussion in response to Thornburgh's argument that
the code allows flexibility in lot sizes. Both agreed that the 22,000 square
foot lot size is an average maximum and the lot dimensions are a
minimum and not a maximum. Both said, however, that Thornburgh does
not have so much flexibility that it may, without amending the CMP,
change the the lot sizes so much that they go beyond the lot dimension
minimums established in the phaszing chart submitted into the record by
Thornburgh and approved by the County.
SUGGESTION: The Board should clarify that it does not allow
Thornburgh the flexibility to subdivide the property into whatever size Tots
it believes the terrain or high density housing type it desires, without first
amending the CMP to allow such different lot sizes if that flexibility causes
Thornburgh to go below the lot dimension minimums established in the
chart submitted into the record by Thornburgh and approved by the
County.
6. OVERVIEW: The Board adopted a finding that the applicant, "shall abide
at all times with the Memo of Understanding (MOU) with the Bureau of
Land Management (BLM), dated September 28, 2005, regarding
mitigation of impacts on surrounding federal lands, to include wildlife
mitigation and long-range trail planning and construction of a public trail
system. The mitigation plan adopted by the Applicant in consultation with
Tetra Tech, ODFW and the BLM shall be adopted and implemented
throughout,-. the`Iife of the resort". The Court of Appeals found that the
Thornburgh failed to include a Wildlife Mitigation Plan with the CMP so
that the public had sufficient evidence in the record to show that any
particular wildlife impact mitigation plan was feasible and that LUBA erred
in not requiring the county to specify a particular mitigation plan and
subject that plan to public notice and county hearing processes.
SUGGESTION: See discussion below under STAFF
RECOMMENDATION.
STAFF RECOMMENDATION
The county code requires that the county hold a hearing for any case remanded
to the county. The code, however, gives the Board flexibility in deciding what
issues are to be covered in that remand hearing and what type of hearing to hold.
Thus, the Board could hold either an On -the -Record or a limited de novo hearing
on all or one of the remand issues.
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Staff recommends that the Board of County Commissioners correct the remand
errors with an On -the -Record Hearing with one exception.
The Court of Appeals remanded the Wildlife Mitigation Plan on the basis that
"the County's findings were inadequate to establish the necessary and
likely content of any wildlife impact mitigation plan.... [And] code provision
requires that the content of the mitigation plan be based on `substantial
evidence in the record' not evidence outside the CMP record."
The Board can choose to hear the Wildlife Mitigation Plan two ways:
1. The Board can conduct a de novo public hearing on the Wildlife Mitigation
Plan only. The Court stated, as part of its decision, that, "without knowing
the specifics of any required mitigation measures, there can be no
effective evaluation of whether the project's effects on fish and wildlife
resources will be completely mitigated" as required by DCC 18.113.070
(D). ORS 215.416 (9) requires that the county's decision approving the
CMP explain "the justification for the decision based on the criteria,
standards and facts set forth" in the decision. Second, that code provision
requires that the content of the mitigation plan be based on "substantial
evidence in the record" not evidence outside the CMP record. In this case,
the particulars of the mitigation plan were to be based on future
negotiation and not county hearing process."
2. The Board can conduct an On -the -Record hearing on this issue and defer
the de novo public hearing on the Wildlife Mitigation Plan to the FMP
phase of the approval process. The court also provided in it's remand to
the County that, "The county's decision did not postpone determination
that the project complies with DCC 18.113.070(D). The county might
have, but did not, postpone determination of compliance with that
standard until the, final master plan approval step and infuse that process
with the same participatory rights as those allowed in the CMP approval
hearing."
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