HomeMy WebLinkAboutHO Decision - Tree Farm 4DECI II
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APPLICANT
PROP
R
ERTY O'
APPLICANT'S
ATTORNEY:
OPPON
ATTO
REQ
ENTSY
.
EYS: Myles A. Conway - Marten Law
404 S.W. Columbia Street, Suite 212
Bend, Oregon 97702
Attorney for Rio Lobo Investments'
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SITES CO
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'TY H
EAR
GS OFFICER
5: 247 -14 -000240 -CU. 247 -14 -000249 -TP
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The Tree Farm LLC
409 N.W. Franklin Avenu
Bend, Oregon 97701
e
R: Miller Tree Farm
110 N.E. Greer rood Avenue
Bend, Oregon 97701
effrey G. Condit Miller Nash LLP
S.W. 5th Avenue, Suite 3400
nd, Oregon 97204
111
Portia
UEST:
Paul Dewey - Central Oregon Land' atch
50 S.W. Bond Street, Ste, 4
Bend, Oregon 97702
Attorney for Central Oregon Landatch
The applicant requests conditional use, tentative plan and site
plan approval for a ten -lot cluster/planned unit development (PUD)
on a 109.5 -acre parcel in the UAR-10, RR -10 and WA Zones
north of Skylin€ers Road and west of Skyline Ranch Road on the
west side of Bend, This proposal is identified as "Tree
Farm 4." It, is part of a proposed 50 -lot cluster/PUD on five
contiguous legal lots totaling approximately 533 acres, identified
as "The Tree Farm." The applicant submitted'' four other
applications, for The Tree Farm (Tree Farms 1, 2, 3 and 5), with
the following file numbers:
Tree Farm 1: 247 -14 -000242 -CU, 247 -14 -000243 -TP
Tree Farm 2: 247 -14 -000244 -CU, 247 -14 -000245 -TP
Tree Fare 3: 247 -14 -000243 -CLU 247-14-000247-T'
Tree Farm 5: 247 -14 -000250 -CU, 247 -14 -000251 -TP.
STAFF REVIEWER; '.Arthorly Rogaine'Senior I;tanner
HEARING DATES: November 6 and 2
RECORD CLOS
T
e Fs'
ED: January 13, 2015
4, 247 -14 -000248 -CU
247-14-000249-T €
0, 201
4
Pa
e
1 of 117
APPLICABLE STANDARDS AND CRITERIA:
Title 17 of the Deschutes
1. Cha
pter 17.0
8,
*<Section 17,0
0LEf
ty Cod
e, the Subdivision/Partition Ordinances
Definitions and`1
8 03
nterpretation of Lan
0, Definitions Generally
Chapter 17.16, Approval of Su
Development plana
*'Section 17,16,100, Required Firs
u
age
bdivision Tentative plans and
dings for Approval
* Section 17.16.100, Access to Subdivisions
*'Section 17.16.116, Traffic Impact Stud
. Ch
pter 17.3
6,
Dea$g
n Stand
and
es
* Section 17.36.020, Streets
* Section 17.36.040, Existing Streets
* Section 17.36.060, Continuation of Streets
17.36°060,
17, 36.070,
17.36.060,
*'Section
* Section
* Section
* Section
*'Section
* Section
*'Section
* Section
* Section
* Section
*'Section
*'Section
* Section
* Section
* Section
* Section
* Section
*'Section
* Section
* Section
Cha
Minimum Right -ref -Way
Future Resubdivision
Future Extension of Streets
17.36.100, Frontage Roads
17.36.110, Streets Adjacent'to Railroa
17.36.120, Street Names
17.36.130, Sidewalks
17.36.140, Bicycle, pedestrian and Transit Flew"
17.36.160, Blocks
17.36.160, Easements
17.36.170, Lots;— Size and Shape
17.36.160, Frontage
17°36°190, Through Lots,
17.36.200, Corner Lots
170360210, Solar Access Performance
17.36.220, Underground Facilities
17.36.260, Fire Hazards
17°36,290, Water and Sewer Lines
17.36.290, Individual' Wells
17036.300, public Water System
nd Road ay Width
ds, Freeways', a
pter 17A4,
* Section
* Section
p
ark Development
17.44.01 0', Ded
kation of Land
17.4400201, Fee
n Lieu of Ded
kation
Chapter 17A8, Design and Construction Specific.tions
* Section 17.46.140, Bikeways
* Section 17.490160, Road Dev&l
opment
aster
nd Parkways
rements
Requirements — Standard
Tree Fare 4, 247 -14 -000248 -CU, 247 -14 -000249 -TP Page sof 1.17
* Section 17.43.130, Private Roa
*Section 17.48.190, Drainage
d
Title 18 of the Deschutes County Code, the Deschutes C unty Zoning Ord
t
hapter 18 04, Title , Purpose and
* 'Section 13.04.030,
Cha
pter 18.6
* Section 18.6
* Section 13,6
*'Section 18.6
3. Chapter 18.8
De
finitlkns
D
eflrrlti ns
Rural Residential Zone ® RR -1
0
0.030, Conditional Uses Permitted'
0.040, Yard and Setback Requirements
0.060,
Dim! en
mora
I Sta
nd
and
s
8, Wildlife Area Combining Zone — WA
*'Section 18.88.010, Purpose
* Section 18.88.020, Application of Provisions,
* Section 18.88.040, Uses Permitted Conditiony
* Section 18.88.050, Dimensional Standards
*Section 18.88.060, Siting Standards
* Section 18.88.070, Fence Standards
Cha
pter 18.128, Conditional U
ses
*Section 18.128M15, General Standards Governing Con
*'Section 18.138.040, Specific Use Standards
* Section 18.128.200, Cluster Development (Slagle -Family
Only)
Section 18.128.210, Planned Dev&loprnant
dltiona
es
in
Uses
ance:
d ntial Uses
Title 19 of the Deschutes County Code, the Bend Urban Area Zoning Ordinance
1, Ch
pter 19.12
Urban Area Res
erve Zone — UAR 10
*>.Section 19.1 .030, Conditional Uses
*Section 10.12.€ 40, Height Re uirremen
*>Section 19.12.060, Lot Requirements
Chapter 19.76, Site Plan Review
* Section 10.70.070,
* Section 19.76.080,
is
Site Plan Criteria
Required Minkrium Standards
Chapter 19.100, Conditional Use Permits
* Section 19.100.030, General Conditional Use Criteria
Chapter 19.104, Planned U
nit
,* Section 19.104.010, Purpose
Development A
ppr sval`,
Tree F rrm 4, 247 -14 -000248 -CU, 247 -14 -000249 -TP Page 3 of 117
*Section 15.104.040, Minimum Size for Planned Unit Dave!
*>Section 19.104.070, Standards for Approval
*Section 19.014.080, Standards and Requirements
Title 22
f the Deschutes County Cod
Chapter 22.04,
*'''Section
e, th
e Deve
iopmen
ntroduction and Definitions
22,04,020, Definitions
2. Chapter 22.08, General Provisions
*Section 22.08
*>Section 22.08
.020, Acceptance of Application
0020, incomplete Applications
0.020, False Statements on A plic
* Section 22.0
Documents
* Section 22',08 070, Time Computation
tp
raked
3. Chapter
* Section 22.20.05
22,20, Review of
Land U
se .Asti,
6, Modification of Ap
Chapter 22.24, Land
* Section
n Appl
plication
Use Action Hearings
22.24.140 Conti
nua
nee
Deschutes County Comprehensive Plan
Chapter 2, Resou
Bend Area General Plan
1. Chap
ter
5, H
rce Ma
nag
s a
errient
nd
Re
()using and Residential Land
Oregon Administrative ' R
Development Comrnlission
a
es (OA
R)
5
h
ation
dations
ord Extens
Chapter 660,
1. Division 4, Goal 2 Exceptions Process
La
rid
ns
pm
nts
es Ord
is
nd Su
rice
pportin
Conservation a
nd
* OAR 050-004-0040(7), Application of Goal 14 (Urbanization) to Rural
Residential Areas
2. Division 11, Pu
* OAR 660-011
blic Facilities Planni
0065, Water Seri
ce to Rural Lan
d
5
Tree Farm 4, 247 -14 -000248 -CU, 247-14-000249-T
Pag
e4 of 11;
F
N
DIN
GS O
F FACT:
Location: The Tree Farm including Tree Farm 4 has an assigned address of 18900
B yliners Road, Bend, The Tree Farm consists of Tax Lots 6202, 6205, 6207, 6208,
6209, 6210, 6211 and 6213 on Deschutes County Assessor's Map 17-11,
B. Zoning and Pan Designation: The westernapproximately 393 acres of The Tree, Farm
are zoned Rural Residential (RR -10) and Wildlife Area Combining,' Zone (WA) associated
with the Tumalo Deer Winter Range, and are designated'' Rural'' Residential Exception
Area (RREA) on the Deschutes County Comprehensive Flan map. The eastern
approximately 140 acres of The Tree Farm are zoned Urban Area Reserve (UAR-10)
and are designated Urban Area Reserve (UAR) on the Bend Area General >>Plan map.
Tree Farm 4 is zoned UAR-10, RR -10 and WA<and is designated UAR and RREA.
C. Site Description: The Tree Farm, of which the proposed Tree Farre 4 is a part, i
approximately 533 acres in size, irregular in shape, vacant, and with varying topography,,
The dominant topographical feature of The Tree Farm property is a ridge running from
southwest to northeast forming the southeast rim of Tumalo Creek Canyon. The top of
this ridge is generally flat to rolling, with steeper slopes in the northwest where it drops
off, toward Turalo Creels, and also on the southeast -facing slopes in the middle of the
property. There are views of the Cascade Mountains from the western part of this centra
ridge and views of Bend from the southeast side of the central ridge. The property has
scattered rock outcrops. Elevation ranges from approximately 3,700 feet above mean
sea level (AMSL) on the east side of the property to approximately 4,000 feet AMSL in
the center of the property. The western part of the property drains west to Turalo Creek;
the eastern part drains east to the Deschutes River,
The western portion of The Tree Far€1 is covered with a mature forest consisting of
ponderosa pine and western juniper trees and native brush and grasses. The record
indicates The Tree Farm property has been managed for timber production. The
applicant's burden of proof states, and the Hearings Officer's site visit observations
confirmed, that there is very little old growth timber on The Tree Farm. Much of the
eastern part of The Tree Farm is covered with sage -steppe vegetation and few trees.,
This part of the property was burned in the 1900 Awbrey Hail Fire. Portions of the
burned area have been replanted with trees, although my site visit observations
confirmed these trees are too smail to be harvested. The property is traversed by dirt
roads that were part of a logging road network. These roads can be seen on aerial
photographs included in the record and I observed them during my site visit, The
applicant proposes to obliterate much of this dirt road network and to revegetate the old
road beds. The property has wire fencing, most of which would be removed
Tree Farm 4 is 109.5 acres in size and is In the western portion of The Tree Farm. It
abuts Tree Farms 2 and 3 on the east, Tree Farm 5 on the south, Shevlin Park on the
west, and undeveloped UAR-10 zoned property on the north and northeast.
The Tree Farm topography is described in detail it the Hearings Officer's s,te visit report ted
December 8. 2014, and included in the record.
1 ree Farm 4, 247 -14 -000248 -CU, 247-14-0 249TP
'age 5 of
17
Surroun
di
ng Zoning and La
nd U
ses:
West Abutting The Tree Farm on the west is Shevlin Park, a 652 -acre regional park
consisting of open space, an extensive trail network, and some developed >.amenities.
Shevlin Park is owned and managed by the Bend Metropolitan Park and Recreation
District (park district), and is zoned Open Space and Conservation (OS&C). Near the
southwest corner of the subject property is the City of Bead's Outback Water Facility,
consisting of groundwater wells, pumps, above -ground water storage facilities, and
water pipes conveying water into the city. Existing utility poles and overhead li€nes run
along the north side of Skyliners Road to serve this facility. To the west and southwest
across Skyliners Road is public forest land zoned Forest Use (F-1) and managed by the
USFS as part of the Deschutes National Forest (DNF). West of Shevlin Park is private
forest land zoned F-1. As of the date the record in this matter closed, the largest part of
this private forest land, approximately 33,000 acres, in multiple tax lots, was owned and
managed by Cascade Timberlands Oregon LLC (Cascade Timberlands). Other private
forest -zoned parcels to the northwest of Shevlin Park are much smaller.
North. To the north of The Tree "Fara is a 37wacrs
and owned by Rio Lobo investments LLC (Rio Lobo)
act of vaca
nt land
zoned UA
R-10
East, To the east are Tree Farms 1, 2 and 3, and vacant land owned by Miller Tree
Fara and zoned UAR-10. Farther east are three public schools within'the Bend-LaPine
School District (school district) --u Miller Elementary School, Pacific Crest Middle School
(under construction}, and Summit High School. The schools are located within the Bend
Urban Growth Boundary (UGB) and city limits and are zoned Public Facilities (PF). Also
to the east within the Bend UGB is NorthWest Crossing, a mixed-use development
including residential, commercial, industrial, and public facility uses on land within
multiple city zoning districts.
South, To the southeast across Skyliners Road is The Highlands at Broken Top PUD.
zoned UART10' and developed with thirty-seven roughly 10 -acre lots with dwellings.
Farther southeast is the Tetherow Destination Resort developed with dwellings, a golf''
course, and a lodge.
Land Use i istory: The Tree Farm property has been owned by the Miller family since
the 1950's. The record indicates this property historically was managed for timber
production as part of the larger Miller Tree Farm, including periodic harvesting and
thinning, activities. The eastern portion of Tree Farm 4 was in the path of the 1990
Awbrey Hall Fire which burned several'' thousand acres between the northern edge of
Sheviin Park and U.S. Highway 97 to the southeast.
In June 2014, the applicant obtained lot -of -record'' determinations for The Tree Fara
property, recognizing five legal lots of record (LR -14-16, LR -14-17, LR -14-18, LR -14-19,
LR -14-20). The applicant also obtained approval of ten lot line adjustments reconfiguring
boundaries for the five legal', lots of record (LL -14-17' through LL414n26). Deeds reflecting`''
the adjusted boundaries of the five lega ots were recorded on October 17, 2014,
Procedural History The Tree Farm applications were submitted on August 5, 2014.
The Planning Division sent the applicant an incomplete letter on September 9, 2014.
identifying certain r issing,information; and allowing the applicant 30 days to submit,
additional information. The applicant submitted the missing information on
Tree Far a:>4, 247 -14 -000248 -CU, 247 -14 -000249 -TP Page of 117
September 19, 2014. However, the staff report states that because the incom
was riot provided to the applicant within 30 days of the date the applications were
submitted, as required by ORS 215.42 (2) and Section 22.08.030 of the Development
Procedures Ordinance, the county considers the applications to have been deemed
completeon September 5, 2014. Therefore, the 150 -day period for issuance of a >finel
local land use decision under ORS 215.427 wo €ld have expired on February 2, 2014,
piete tetter
A consolidated public hearing on the five Tree Farm applications was scheduled for
November 6, 2014. On November 4, 2014, the Hearings Officer conducted a site visit to
he subject property, acco€n€panied by Senior Planner Anthony Raguine, Due to work
occurring on the nearby utility lines, some roads adjacent to and within the Tree Farm
were not accessible, o the site visit was terr€ inated.
By a letter dated November 4, 2014, the applicant requested that the hearing be
continued to November 20, 2014. At the November 6; 2014, hearing the Hearings Officer
disclosed my limited observations from the abbreviated site visit, received testimony and
evidence, and cant hued the hearing to November 20, 2014. At the continued public
hearing, the Hearings Officer announced my intention to conduct another site visit and to
issue a written site visit report. 1 also received testimony and evidence, left' the written
evidentiary record open through December 23, 2014, and allowed the applicant through
December 30, 2014 to submit final argument pursuant to ORS 197.763.
On December 3, 2€ 14 the, Hearings Officer conducted another site visit to the subject
property and vicinity; again accompanied by Mr. Raguine, and on December 8, 2€ 14,
issued a written site visit report. On December 19, 2015, Mr. Raguine issued a staff
memorandum addressing the status of the proposed private roads in the Tree Farm. By
a letter dated December 22, 2014, the applicant requested that the written record be
extended to allow additional time to respond to the staff memorandum By an order
dated December 23, '2014; the Hearings Officer extended the written evidentiary record
through January 6, 2015, and allowed the applicant to submit final argument through
January 13, 2015. The applicant submitted final argument on January 13, 2015 and the
record closed on that date.
Because the applicant requested that the public hea -€ng be continued from November 6
to November 20, 2013 (a period of 14 days), and agreed to leave the written record open
from November 20, 2014, through January 13, 2015 (a period of 54 days), under Section
22:24.140 the 150 -day period was tolled for 68 days and now expires on April 13, 2015,2
As of the date of this decision there remain 27 days in the extended 15€0 -day period.
Proposal; The applicant requests conditional use, site plan, and tentative plan approval
to establish a 50 -lot cluster/PUD to be called The Tree Farm € on approximately > 533 acres
west of the Bend UGB. The Tree Farm would include five contiguous Bluster/PDDs with
a total of 100 acres of residential''' lots, 422.8 acres of open space tracts, and 10.6 acres
of road right-of-way. The boundaries of the five clusteriPUDs coincide with the
boundaries of the five legal lots of record recently reconfigured through the
aforementioned lot line adjustments. Each cls€ster!Pt_UD would have ten accre residential
lots, an open space tract, segments of the public and private road system, and mixed -
se trails connecting to trails in Shevlin Park and the DNF. Tree Farms 1 through 4
Because the 10t day falls
weekends and holidays are exci
on Saturday Apr 11, 2015, and because under Section 22.08.070
•
uded from time computations, the 150th day is April 1 a; 2015.
Tree Farrn 4, 247 -14 -000248 -CU€, 247.14 -000249 -TP'
Page 7 of 117
would include and in the UAR-10, RR -10 and WA Zones. Tree Farm 5 would
entirely within the RR -10 and WA Zones.
be located
The subject application is for Tree Farm 4, consisting of 109.5 acres with ten dwellings
on ten 2 -acre oats (Lots 31-40) clustered in the eastern potion of Tree Farm 4 and in the
western portion of The Tree Farm, Tree Farm 4 would have an 8T7 -acre open space
tract and 1.7 acres of right-of-way.3 The residential lots would have access to Skyliners
Road, a county collector road, via two new private roads, Golden' Mantle Loop and Tree
Farm Drive, over which the applicant proposes to dedicate permanent public access
easements. Tree Farm Drive, Golden Mantle Loop and Ridgeline Drive in Tree Farms 1,
2 and 3 would, comprise the main PUD road. The >applicant proposes to dev=elop Tree
Farms 1, 2 and 3 concurrently to establish this road.
The applicant also proposes to construct a gated temporary emergency access road on
an easement extending from the southern terminus of Sage Steppe Drive at the
southern boundary of Tree Farm 1 south across the adjacent Miller Tree Farm property
to Crosby Drive, a public street within the Bend UGB that connects to Skyliners Road.
The emergency access would operate' until the Miller Tree Farm property is developed
with public roads to which Sage Steppe Drive would connect.
4
Lots in Tree Farm 4 would' be served by on-site sewage disposal systems. They would'
receive domestic water from one of three alternative sources:, (1) extension of and
connection to the City of Bend water system; (2) service from Avion Water Company; or
(3) water pumped from one or more private groundwater wells on The Tree Farm and/or
the adjacent Miller Tree Farm property. Tree Farm 4 dwellings would have fire protection
from the Bend Fire Department and police protection from the Desch u es County Sheriff.
The applicant proposes that the entire Tree Farm >development would comply with the
"Firewise Community" standards for fire prevention. The Tree Farm 4 open space tract
would be subject to deed restrictions preventing future development thereon.
Public/Private Agency Comments: The Planning Division sent notice of the applicant's
proposal to a number of public and private agencies and received responses from: the
Deschutes County Road Department (road department), Property Address Coordinator.
Building Division, Senior Transportation Planner, and Forester; the City of Bend Fire
Department (fire department); the park district; and the Oregon Department of Fish and
------------------
Tree Farms 1, 2, 3 and 5 would have the following characteristics:
Tree Farm 1: Lots 1-10; 105.3 acres total; 31.1 acres of open space, of which 39.9 acres would
be in the RR-10/WA Zones; and 4.2 acres of right -of -
Tree Farm 2: Lots 11-20; 104.2 acres total; 82.8 acres of open space, of which 67.7 acres would
be in the RR-1Oi+,r'VA Zones; and 1.4 acres of right-of-way;
Tree Farm 3: Lots 21-30; 106.9 acres total; 83.3 acres of open space, of which 82 acres would be
in the RR-10ANA Zones, and 3.1 acres of right-of-way; and
Tree Farm 5: Lots 41-50; 107.6 acres total; 87.1 acres of open space, all of which would be in the
RR-la/WA a/WA Zan:: ; and :.2...acres of right-of-way.
4 The tentative plan for Tree Farm 1 also shows potential right-of-way for for future extension of Skyline
Ranch Road, a designated county collector road that has been dedicated and improved in segments
north and south of the Miller Tree Farm and Rio Lobo properties. The potential right-of-way would extend
north from Crosby Drive through the Miller Tree Farm property and the northeast corner of Tree Farm 1
and onto the Rio Lobo property.
Tree Farm 4, 247, -14 -000243 -CU, 247 -14 -000249 -TP' Page
of 117
Wildlife (ODFW). These comments are set forth verbatim at pages 3-9 of the Tree Farm
4 staff report and are included in the record. The following agencies either did'' not
respond to the request for comments or submitted "no comment" responses: the
Deschutes County Environmental Soils Division, Assessor, and Surveyor; the City of
Bend Planning Division, Engineering Division, and Public Works Department (public
works); the UFS DNF; the Oregon Department of Water Resources, Waterm€asterT
District 1 1 ; the school district: Bend Broadband; Cascade Natural Gas; CenturyLink; and
Pacific Power. Agency comments are addressed in the findings below.
Public Comments The Planning Division mailed individual written notice of the
applicant's proposal and the initial public hearing to the owners of record of all property
located within 250 feet of the subject property's boundaries. The record indicates this
notice was mailed to the owners of twenty-six ax lots. In addition, notic of the initial
public hearing was published in the Bend "Bullet n" newspaper, and the subject property
was posted with a notice of proposed land use ction sign. As of the date the record in
this matter dosed, the county had received thirteen letters from the public in response to
these notices. In addition, four members of the public testified at the continued public
hearing. Public comments are addressed in the findings below.
Lot of Record; The county determined Tree Farm 4 is a legal lot of record pursuant to a
2014 lot -of -record determination (LRT14-19). The current configuration of Tree Farm 4 is
the result of a series of 2014 lot line adjustments (LL-14-17'''through LL -14-26),
CONCLUSIONS OF LA!
SU
MMARY:
The Hearings Officer has found that with two significant exceptions, Tree Farm 4 satisfies, or
with imposition of conditions of approval will satisfy, the applicable approval criteria in the
relevant administrative rules and the provisions of Titles 17, 18, 19 and 22 of the Deschutes
County Code. l have found the applicant has not demonstrated'' compliance with a number of
criteria related to wildlife habitat and wildfire risks. Specifically, I have found the, applicant's
proposed Wildlife Assessment and Management Plan (MAP) and Wildfire Protection and
Management Plan (wildfire plan) are not adequate, and cannot be made adequate through
imposition of conditions of approval, to demonstrate the risk of wildfire, can be reduced to an,
acceptable level while' protecting winter deer range habitat. For these reasons, I cannot approve
the application for Tree Farm 4. However, I anticipate this decision will be appealed to the Board
of County Commissioners (board). Therefore, in order to assist the board and county staff in the
event of such appeal, I have included in this decision findings of fact and conclusions of law on
all applicable standards and criteria, as well as recommended conditions of approval.
B. PR
ELI
M
NARY IS
Com
pieta
s
u
ES:
ness a
nd States
s of Application:
FINDINGS- In June of 2014. the county issued lot -of -record determinations written by Associate
Planner Cynthia Smidt and confirming the existence of five legal lots of record comprising, The
Tree Farm ((LR -14-16 through LR -14-2O). Ms. Smidt also issued a series of decisions approving;,
lot line adjustments for the five legal lots of record creating the current configurations of the five
Tree Farm developments (LL. -14-17 through LL -14426). Each of the lot -line -adjustment
Tree F 4, 247-14-OOO248--CLJ, 247--14-000249-TP
Page 9 of 117'
decisions Included the following six conditions for final approval: (a) obtaining approval of a lot
line adjustments; (b) obtaining surveys of the reconfigured lots and filing the surveys with the
Deschutes County Surveyor; (3) submitting to the Planning Division legal descriptions of the
newly reconfigured lots; (4) recording new deeds reflecting the new lot configurations; (5) paying
all property taxes for the affected tax lots; and (6) complying with all development setbacks from
tree reconfigured lot lines, The record does not indicate whether or to what extent these
conditions of approval had been met at the time The Tree Fan applications were filed and the
record for the applications dosed,,
The record Indicates the deeds required pursuant to Condition 4 of the lot -line -adjustment
decisions were recorded on October 17, 2014, nearly ten weeks after the applicant submitted its
Tree Farm applications and nearly six weeks after the applications were deemed complete. Mr'
Ra uine's September 9, 2014 incomplete letter for The Tree Farm applications does not refer to
compliance with the lot -line -adjustment conditions of approval. The record does Include a copy
of an October 29, 2014 electronic mail message from the applicant's representative Romy
Mortensen to Ms. Smidt, copied to Mr, R guine, stating the deeds had been recorded,
The burden of proof for each of the five Tree Farm applications states the property subject to
the application is a legal lot of record as configured on the submitted tentative plan. However,
those statements were not correct because not all lot line adjustment conditions of approval had
been satisfied and therefore the lot line adjustments were not final. The question is whether
these misstatements affect the Hearings Officer's consideration of The Tree Farm applications.
Section 22.08 035 of the devel
opment procedures ordinance states,:
If the applicant or the applicant's representative or apparent representative rakes,
a misstatement of fact on the application regarding property ownership, authority
to submit the application acreage, or any other fact material to the acceptance or
approval of the application, and such misstatement is relied upon by the Planning
Director or Hearings Body in making a decision whether to accept or approve the,
application, the Planning Director may upon notice to the applicant and subject to
an applicant's right to a hearing declare the application void
The Hearings Officer finds the applicant's aisatatements concern facts material to acceptance
or approval of the Tree Farm applications — i.e.; the legal status and configuration of the five lots
comprising the five proposed Tree Farm developments. However, the record indicates all five
Tree Farm applications were deemed complete as required by law. Moreover, the Planning
Director has not declared the applications void, and I find he is not likely to do so since he
referred The Tree Farm applications for a hearing, and the required deeds were recorded before
the record closed. For these reasons, I find 1 may consider The Tree Farm applicatlions.
Nevertheless, 1 find that to assure all lot -fine -adjustment conditions of approval are satisfied, the
applicant will be required as a condition of approval, and before submitting the final plat of any
Tree Fare development for approval, to demonstrate to the Planning Division that all such
conditions have been met«
lodifi atio a; cif Application.
FINDINGS: As discussed in the findings below concerning compliance with the PUD
requirements in Title 19, the applicant has requested approval of a number of exceptions to the
standard regulations for Tree Farm 4. Several exceptions were identified in the applicant's
Tree Farre 4, 247 -14 -000248 -CR , 247.14-
249 -TP Page 10 of 11 a
burden of proof, and several additional exceptions were
correspondence from the applicant.
eguested throug
h subsequent
Section 22.20€.0 5 allows an applicant to modify an application up to the close of the record, but
prohibits the Hearings'' Officer from considering a modification without the fil ng of a modification
appllication. Section 22.20.055(D) authorizes me to determine whether an applicant's
submission constitutes a modification. defined in Section 22.04.020 as.
* the applicant's submittal of new information after an application has been
deemed complete and prior to the chose of the record on a pending application,
that would modify a development proposal by changing one or more of the
following previously described components: proposed uses, operating,
characteristics, intensity, scale, site layout (including but not limited to changes in
setbacks, access points, building design, size or orientation, parking, traffic, or
pedestrian circulation plans), or landsc ping, '''in a manner that requires the
application of new criteria to the proposalor that would require the findings of
fact to be changed. It does not mean an applicant's submission of new evidence
that merely clarifies or supports the pending application.
The Hearings Officer finds the applicant's requests for exceptions, and its arguments in support
thereof, submitted following the date the application was deemed complete do not constitute
modifications. That is because they do not change the developmen proposal. Rather, they seek
approval of various aspects of the applicant's proposal as shown n the tentative plans and in
the burden of proof statements, l also find they constitute new evidence that clarifies and
supports the applicant's proposal. Therefore, I find l can consider all of the applicant's requested
exceptions without the need for modification applications.
3. Effect of S
pllt Zoni
n
go
FINDINGS. Tree Farm 4 includes land in three,,, zones -- UAR-10, RR -10 and WA -- established'
and governed by two separate zoning ordinances ww Title 18 (RR -10 and WA) and Title 19
(UAR-1 g). As discussed below, the Hearings 'Officer previously has considered development
applications on split -zoned property. However, because of the complexity of The Tree Farm
applications and the large number of applicable standards - I find it is appropriate at the outset
to address how these zones will be applied to Tree Farm 4.
Permitted Lises. Sections 18 .60.0€ 0(E) and (F)
Zone "planned development" and "cluster develr
respective
pment," defi
y, permit conditionally in the RFS -10
ned in Section 18 04.030 as:
"Cluster development" means a development permitting the clustering of single
or multi -family residences on a part of the property, with individual lots of not less
than two acres in size and not exceeding three acres in size. No commercial or
industrial uses not allowed by the applicable zonl'ng ordinance are permitted.
"Planned development"' means the development of an area of land at least 40
ares in stze or number—offdwelling >units, corn inercia —or—industrial—uses,
according to a plan which does not necessarily correspond hi lot sizes bulk or
type of dwelling, density, lot coverage, or required open space to the standard
regulations otherwise required''' by DCC Title 18, and usually, featuring a clustering
of residential units.
Tree Farm 4, 24 4 -000248 -CU 247 -14 -000249 -TP Page 11 of 117
"Planned
Section 18.88
Zone is coin
un
d
eveloprnent," see "planned d
evelop
en
.040 provides that uses permitted conditionally in the zone with which the WA
bined are permitted conditionally in the WA Zone.
Section 19.12.03
defined in Section 19
i(N
permits conditiona
.04.040 as follows:
"Panned unit developrnen
entity for a number of unit
ly in the UAR-10 Zone "planned uni
developen
t,"
means the development of an area of land as a single
s or a number of uses, according to a pian which does
d in lot size, bulk or type of dwelling, density, lot
dard regulations otherwise required
not necessarily correspon
coverage or required open space to the sten
by DCC Title 19.
Although "'planned unit dev lopm€ent" in the UAR-10 Zone does not expressly permit' clustering
of dwellings, the Hearings ifticer finds clustering is the type of deviation from standard
regulations contemplated in a PUD
All proposed Tree Farm lots will be at least two acres in size, and all; five Tree Farm
developments will be at least 40 acres in size. As discussed in the findings below, the applicant
has requested cluster/PUD approval in order to deviate in several respects from the standard
regulations under Titles 18 and 19.
For the foregoing reasons, the Hearings Officer finds Tree Farm 4 falls within he definitions of
'cluster development,'"''planned development," and "planned unit development" in Titles 18 and
19. Because the proposed cluster/PUDs are permitted conditionally in all three zones, l find the
split -zoning does not preclude approval of Tree Farm 4 on the subject property. Sae: Sofa Glen
Neighborhood Assoc. v. City of Salem, 25 Or LUBA 672 (1 93) (residential subdivision allowed
on property's split rural residential and rural agricultural zones where use permitted in ''both
zones); Roth v. 4Jackson County, 38 Or LURA 894 (2000) (winery allowed on split -zoned
property's agricultural zone, but not on its suburban residential zone where winery is not a
permitted use).
Effect of Zone Boundaries. Tree Farms 1 through 4 straddle the boundary between the UAR-
0 and RR-10/WA Zones which is the line between Sections ''33 and 34. As a result'
proposed;, lots, open space tracts, roads, and trails are located in all three zones.5 As a gee era'I
rule, regulations applicable to a specific zone are not applied outside the boundaries of that
zone. The Hearings Officer finds application of that general rule is particularly appropriate in the
case of overly or combining zones established to, protect identified resources with specific
geographic or site boundaries, such as the WA Zone As discussed in the findings below under
the WA Zone, Section 18.88.020 applies that zone to areas designated "winter deer range,': an
identified resource with mapped boundaries. The WA Zone provisions are directed at protecting
It
appears from the aforementioned lot -line -adjustment decisions khat this split zon
(`r ( nant.4 u et c./n of the five legal lots of record i:.ornarm; w'q The T r'e Farm,.
ing
fisted
in the
Examples of similar geographically specific overlay or combining zones an Title 18 are; (a) the
Landscape €vlanagererit (LM) Zone in Chapter 18.84 (protecting designated scenic roads and
waterways (b) the Sensitive Bird and Mammal Habitat (SB€MH) Zone in Chapter 18 90 (protecting bird
nests and breeding grounds); and (c) the Airport Safety (AS) Zone in Chapter 118.80 (protecting airport
approach zones).
Tree Farm 4, 247 -14 -000248 -CU
247 -14 -000249 -TP Page 12 of 117
that specific habitat and minimizing conflicting uses 'therewit
regulations do not apply to the areas of Tree Farm 4 located''o
h. Therefore, I find the WA Zone
utside the WA Zone boundaries.
With respect to base zones such as the RR -10 and UAR-10 Zones, the Hearings Officer finds
there are circumstances in which application of the general rule, that zoning regulations do not
apply outside the zone boundaries, may not be appropriate, For example, in Eola Glen, cited
above, LURA appears to have found that because the proposed residential subdivision was
permitted in both zones on the property, review and approval of the proposal could be based on
application of requirements in both zones. This Hearings Officer reached a simi ar cornclusi€ n €n
my 2006 decision in » Hodgert (CU -06-53, SP -06-19, LM -06-73, LL06-48). In that case, the
applicant requested conditional use and site plan approval to establish aprivate fishing lodge on
property zoned F-1 and F-2. The applicant also requested a lot line adjustment that id
create a split -zoned parcel on which some of the fishing lodge facilities would be located. !'
made the following relevant findings:
"Split zoning generally is not favored because it may complicate application of
land use regulations to development on the property. However, where, as here,
the regulations governing the F-1 and F-2 Zones are verb sir, ril r the proposed
private fik laing accommodations are allowed conditionally in both zones, and the
standards for this conditional use are identical in each zone, the Hearings Officer
finds such split zoning is appropriate."
As in Hodgert, The Tree Farm applications propose clustertPUDs permitted in both the UAR-10
and RR -10 Zones. The general conditional use standards applicable to clusteriPUDs under
Sections 10.128.015 and 19.100.030 are very similar. However, as discussed below, the
specific conditional use standards applicable to cluster developments and PUDs in Title 18 differ
in many respects from the specific PUD standards in Title 1. Therefore, the question is whether
applying the standards in Titles 18 and 19 only to those portions of Tree Farms 1 through 4
located within the RR -10 and UARw10 Zones, respectively, would allow meaningful review of
each cluster/PUD as a whole.' The Hearings Officer finds it would not because such segmented
review vwould artificially segregate portions of these developments based solely on the location
of a section line, and without regard to the nature and scope of the standards applicable to
clusteriPUDs, Accordingly, I, find that to the extent feasible,>;l will apply the applicable provisions
of the RR -10 and UAR-10 Zones to the proposed Tree Farm 4 in its entirety.
ADMINISTRATIVE RULES
Oregon Adm
Commission
iistra
e Rules, Ch
pte
660, Land Conservation
Division 4, Goal 2 Exceptions Process
OAR 66
(1)
0.0
04-0
040, Application of Goa
14
to Rura
a
nd
Development
Resid
entia
Areas
The purpose of this rule is to specify how Statewide Planning
Goat 14, Urbanization, applies to rural lands in acknowledged
exception areas planned for residential uses.
' As noted above, Tree Farm 5 is not split zoned as it is located entirely within the R-10 Zone.
Tree Farm 4. 247• -14 -000248 -CU, 247-14-00
0249 -TP Page 13 of 1`'1
(2)
(a) This rade appl s to lands that are not within an urban
growth boundary, that are planned and zoned primarily', for
residential uses, and for which an exception€ to Statewide
Planning Goal 3 (Agricultural Lands), Goal 4 (Forest Lands),
or both has been taken. Such lands are referred to in this as
rural residential areas.
(b) Sections (1) to (8) of this rule do not apply to the creation
of a lot or parcel, or to the development or use of one sirslgle
family home on such lot or parcel, where the application for
partition or subdivision was filed with the local government
and deemed to be complete in accordance vvith ORS
215A27(3) before the effective date of Section (1) to (8) of this
rule.
(c) This rule does not apply
through (H) of this subsection;
(A)
(6)
(C)
(
to types o
and Inside n ackno€l
boundary,
d
f land his
ted
n (A)
ed urban growth
land inside an acknowledged
community boundary established
Chapter 660, Division 022;
unincorporated
pursuant to OAR
and hi an acknowled+ ed urban reserve area
established pursuant to OAR ChapteChapter 660, Division
021;
0) land in acknowledged destination resort established
pursuant to applicable land use statutes and goals;
E)
(F)
(G)
resource
and
as defined
resource la
in OAR
rid, as define
marginal land, as d
Edition;'
(H) land plan
commercial or pu
ned and
6
60-0
d in OAR 6
efined in ORS
04-00
6
05(2);
0-004-0005(3);
197 247 1991
zoned primarily for rural industrial,
blic use.
FINDINGS: The applicant and staff identified this administrative rule as applicable to Tree Farm
4 because the proposed cluster/PUD is on land located outside the Bend UGB, zoned UAR-1O
RR -10 and WA, and designated UAR and RR .A. The Hearings Officer is aware the county's
if1-10 zoned lands were acknow=i d ed as exception ares at the time the county's
comprehensive plan initially was acknowledged in 1979. Therefore, l find the RR -10 zoned land
within The Tree Farm constitutes a 'rural residential area' subject to this administrative rule
because it is not included in any of the exceptions in Paragraph (2) (c)
Tree Farm 4, 247-14-000248 CU 247-14.000249 TP
Page 14
1
''ith respect to land within Tree Farm 4 zoned UART10, the record indicates this urban reserve
area was acknowledged but was not established pursuant to Division 21 of OAR Chapter 660,
in 2003, forrner county hearings officer Tia Lewis issued a decision approving the nearby The
Highlands at Broken Top PUD on UAR-10 zoned land (Cascade Highlands (GU-0-73iTP»g2
931)). Ms. Lew s concluded this administrative rule was applicable to the UAR-10 Zone west of
Bend based on the following findings:
"The Hearings Officer agrees with Staff that the subject property is located
neither inside an >acknowledged urban growth boundar/ nor it side an
acknowledged unincorporated community. In addition, although located in the
urban reserve area, the record indicates that the bounty's urban reserve area
. astr
379 the Stele reguirir ack t>I< / .?dtime a' of urban
reserve areas. Further, the land is not an acknowledged destination resort,
resource land, nonresource land, marginal or zoned ` for rural industrial,
commercial or public use. Therefore, the Hearings Officer finds this rule is
applicable to the applicant's proposal.' (Emphasis added.)
The Hearings Officer agrees with Ms. Lewis' analysis and finds this
applicable to the portion of Tree Farm 4 zoned and designated UAR,
(7)
ad inistristive rule also is
(a) The creation of any new lot or parcel smaller than two
acres in a rural residential area shall be considered'' an urban
use. Such a lot or parcel may be created only if an exception
to Goal 14 is taken. This subsection shall not be construed to
imply that creation of new lots or parcels two acres or larger
always complies with Goal, 14. The question of whether the
creation of such lots or parcels complies with Goal 14
depends upon compliance v+iith ail provisions of this rule.
(b) Each local government must specify a minimum area for
any new lot or parcel that is to be created in a rural residential
area. For the purposes of this rule, that min um area shall
be referred to as the min mum lot size.
(c) if, on the effective date of this rule,, a local government's
land use regulations specify a minimum lot size of two acres
or more, the area of any new lot or parcel shall equal or
exceed that Minimum lot size which is already in effect.
(d) lf, on the effective date of this rue, a local government's
land use regulations specify a minimum lot size smaller than
two acres, the area of any new lot or parcel created shall
equal or exceed two acres.
(e) A local government may authorize planned''' unit,
develops ent (PUUD), e size of lots or parcels by
averaging density across a parent parcel, or allow clustering
of new dwellings in a rural residential area only if all
conditions set forth in paragraphs (7)(e)(A) through (7)(e)(H)
are met:
Tree Farm 4, 247 -14 -00024$ -CU, 247-14-€ 0 }24c4 -TP Page 15 of 11
The number of new dwelling units to be clutered or
developedas a PUD does not exceed 10.
FINDINGS: Each of the ten proposed residential lots in Tree Farm 4 would be at least, two acres
in size. and the lots would be, clustered in the southeastern part of Tree Farm 4 and in the north.
central part of The Tree Farm. As discussed above, Tree Farm 4 would be one of five
contiguous clustdr?PUDs comprising The Tree Farm, and establishing a total of 50 dwellings on
approximately 533 acres.
The applicant's five burden of proof statements assert each subdivision can be approved as a
stand-alone development; The Hearings Officer disagrees. l find the five cluster/PUDs
effectively would function as a single development because each cluster/PUD is dependent on
one or more of the other cluster/PUDs for roads and other infrastructure. For example, Tree
Farm 4 lots will not have access to Sk liners Road without concurrent development of Tree
Farms 1, 2, and 3 which will create the main PUD road, and the applicants proposed utility plan
shows city water service connections to Tree Farre 4 lots must be made through Tree Farms
and 5.
The applicant appears to have chosen to develop The Tree Farre, through five separate
cluster/PUDs in order to maximize the number of dwellings on the property. Although this
approach is somewhat unconventional, the Hearings Officer finds nothing in the county's land
use regulations that prohibits;, it. Each individual'' Tree Farm development''' is a legal lot of record,8
and the applicant as entitled to develop each legal lot of record consistent with applicable zoning
ordinance(s) and the subdivisionlp rtition ordinance. I am not aware of any code provision that
requires the applicant to consolidate its five legal lots as a prerequisite to cluster9PUD
development. Neither have l; found any prohibition against developing a cluster/PUD where, as,
here, roads and other infrastructure necessary to serve the new subdivision lots are dependent
upon extension of and connection to such facilities on contiguous or nearby land, In such cases,
subdivision approval may be, conditioned, on extension of and connection to existing roads and>'
other infrastructure before final plat approval
For the foregoing reasons, the 'Hearing s Office
maximum number of dwelling units for a cluster Pt~
r finds Tree Farm 4 does not exceed the
D under this administrative rule.
B. The number of new lots or parcels
not exceed 10.
t
e crea
dry
oes
FINDINGS: The applicant proposes ten new residential lots in Tree Farm 4. Staff questioned
whether the applicant's proposed open space tract must be counted as a lot for purposes of the
maximum density calculation. Staff discussed this question with the »applicant and with Jon
Jinnings, Community Services Specialist with the Department of Land Conservation and
Development (DLCD), Based on those conversations, staff concluded the ten -lot rr^€aximum
applies only to new residential lots and not to the proposed open space;. tract. In an October 27,
2014 electronic mall message, the applicant's attorneyJeffrey Condit agreed with staff's
interpretation, offering the following analysis;
As discussed above, the Hearings Officer has found the applicant will be required as a condition of
approval to demonstrate to the Planning Division that all conditions of approval for the lot line adjustments
creating the proposed configurations for Tree Farms 1 through 5 have been met before final plat approval
for any of the Tree Farm, developments.
Tree Farm 4, 247-14-
4 CU, 47 -14 -000249 -TP
Fag
e 16 af 117
(here are two rules of stat€.,tory construction that come into play: First, a statute
is construed based upon text and context (i.e. its relationship to other provisions
in the ordinance). Second, ,,if possible. a statute should be construed to avoid a
conflict rather than create one. The rule ('subsection r(e)) allows up to ten
dvwerlinps on up to ten ne lots, so that assirrnes that there can be up to ten
buildable lots. The rule (subsection 7(h)) also contemplates that there could''' be
an 'open space lot, parcel, or tract.' if the open space tract is as counted as a lot
for the purposes of subsection 7(e)(B), then an applicant will never be able to
construct more than 9 dwellings, which will violate the express text of the rule. It
will be possible, of course, to include the common area within the boundary of
one of the ten' parcels, and limit the development on the open space portion via
covenant, but what is the policy basis for allowing that and not allowing the open
space to be located on a separate unit of land as long as it can't be developed?
(Particularly considering that the latter arguably provides better long-term
protection to the open space parcel.) l' think the better reading, which doesn't
create a conflict or a distinction without, a difference, is that the ten parcel limit ir-n
Subsection 7(e) (B), when read in context with the 7(e) (A) dwelling unit limit, was
intended as a limit of up to ten buildable parcels, and that subsection 7(h) allows'
an additional unbuildable 'lot, parcel or tract' restricted to open space as long', as
the requirements in that section are met. This is the only interpretation that
reconciles potential conflicts and makes overall sense when read in context,
I think similar reasoning applies to the County Code interpretation. The issue
arose in the context of Tree Farm #1, which is proposed for a 105 acre property
Under the existing UAR-10 zoning, the property could be divided into ten lots'
each with a house on it. The Tree Farm's proposal under the county PUD statute
is to cluster this development on ton two -acre >lots and preserve the remainder of
the property as open space in a separate tract, * * * First, the express purpose of
the PUD is to allow exceptions from the standard requirements of the zone in
order to 'accrue benefits to the County and the general public in terms of need.
convenience, service and appearance,' DCC 19.104.070. The preservation of they
vast majority of the property in an open space tract is the chief public benefit Haat
justifies the exception to the standard. Second, DCC 19,104.070 provides that
'[a] planned unit development shall not be approved in any R zone if the housing
density of the proposed development will result in an intensity of land use greater
than permitted by the Comprehensive Plan.' As the underscored language
indicates, the PUD ordinance is not concerned about number of parcels, but
about overall housing density. Under the current zoning, no more than ten
dwelling units can be sited on the 105 -acre property, Under the PUD as
proposed in Tree Farm 1, no more than ten dwelling units can be sited on the
105 -acre property. The fact that the open space is being preserved in a separate
tract does not affect compliance with the requirements of the PUD Code (and is a
very common practice in planned developments)."
The Hearings Officer concurs with Mr. Condit's>;analysis. 1 find the proposed Leen space tract in
Tree Farm -4 -is -not -counted -in -the -ten -lot -maxi and therefore thee -applicant's proposal for
ten residential lots does not exceed that maximum.
C. None of the n
two
Tree Farm ' -4, 247 -14 -00024,8 -CU, 247-14- 00249 -TP
ew lots o
pa
cel'
be smaller tha
h
Page 17 of '117
FI
N
DI
NOS: All resid
en
ial lots in Tree Farm 4 will be t
L acre
in size, satisfying this cnterion
The development is not to be served by a
community sewer system.
The development is not to be served by any new
extension of a sewer system from within an urban
growth boundary or from within an unincorporated
community.
FINDINGS: The applicant proposes to serve the ten residential lots in Tree Farm 4 >. sith
indiv du l on-site septic systems, therefore satisfying these criterial.
F The overall density of the development will not exceed
one dwelling for each unit of acreage specified in the
local government's land use regulations on the
effective date of this rule as the minimum lot size for
the area
FINING : The RR -10 and UAR-10 Zones in which Tree Farm 4 is located establis
density of one lot per ten acres through Sections 18.60.60 and 19.12.50, res
zones permit higher density for clusteriPUDs through Sect arts 18.60.00
respectively. As discussed above, the Hearings Officer has found
the administrative rule applies to residential lots and does not include open s
Therefore, l find the applicant's proposal complies with this requirement.
h a general
pectively. Both
and 19,104,040,
the 10 -tat maximum density in,
pace tracts.
FIND
NGS:
Any group or cluster of two or more dwelling units will
not force a significant change in accepted farm or
forest practices on nearby lands devoted to farm or
forest use and will not significantly increase the cost
of accepted farm or forest practices there.
Farm Use. The record indicates there are no nearby lands devoted to farm use and no farm
practices occurring on nearby lands. Therefore, the Hearings Officer finds Tree Farm 4 will not
force a significant change in, or significantly increase the cost of, accepted farm practices on
nearby lands devoted to farm use.
Forest Use.
Required Analysis. The Hearings Officer finds this paragraph requires me to determine: (1)
whether nearby forest -zoned land is "devoted to forest use;' (2) if so, what is the nature of that
forest use; and (3) whether that forest use conflicts, or has the potential to conflict, with
residential uses in the proposed clusteriPUD to the degree that the residential uses will
significantly affect, or significantly increase the cost ofaccepted forest practices on the nearby
forest -zoned lands.9
8 Section 18.04.030 aefi€yes "forest lends" and "forest uses' as follows;
"Forest lands"` means lands which are suitable for co rr#r erciai forest uses including
Tree Farm 4, 247 -114.000248 -CU 247 4 -000249 -TP
Faye '1 f of 117
Study Area. The record indicates public forest and in the DNF is located southwest across
Skyliners Road. In addition. private forest land is located west and northwest of Shevlin Park.
The DN ' forest lands are managed by the USFS and extend west to the crest of the Cascade
Mountains. The private forest lands west and northwest of >Shevlin Park were once part of the
"Bull Springs Block" of public forest land conveyed by the UFS to private owners. The largest,
of these private forest land holdings was owned and managed by Cascade Timberlands, and
according, to Assessor's data consists of 17 ''tax lots totaling approximately 33,000 acres.'`'
Assessor's data indicate there are several smaller private forest -zoned parcels northwest of
Shevlin Park, some of which have dwellings.
The Hearings Officer finds I gust establish a "study area" for the analysis required by this rule. I'
agree with the argument presented by Central Oregon LandWatch (LandWatch), that because
impacts from certain forest practices, such as smoke from prescribed burns, can extend beyond
adjacent properties, the appropriate study area should include both DNF lands and private
forest lands west and northwest of Shevlin Park. However, the administrative rule requires an
analysis of impacts on "nearby" lands devoted to forest use; The ordinary definitions of "nearby'
and "near' are: "chase at hand;" "at a short distance in space or time; close in distance or time;
close in relationship," Webster's New World Dictionary and Thesaurus, Second Edition. In light
of these definitions, I >.find the appropriate study area should include public and private forest -
zoned parcels located in whole or in part within one mile of the western boundary of The Tree
Farm.12 The record indicates that because of the large size of these parcels, this study area
includes thousands of forested acres in public and private €ownership.
Accepted Forest
Practices on Nearby Lands Devoted
to Forest Use.
1. Deschutes National Forest. The applicant's burden of proof for Tree Farm, 4 notes the
portion of the DNF southwest of The Tree Farm includes the heavily -used "Phil's Trail" mountain
biking trai network. The burden of proof goes on to state:
"The 1990 Deschutes National Forest plan (as amended) identifies the lands
adjacent to The Tree Farm property as Management Area 9 Scenic Views. the
goal of this management area is to provide visitors ,pith scenic vistas
adjacent or nearby lands which are necessary to permit forest operations or practices and
other forested lands that maintain soil, air, water and fish and wildlife resources;
"Forest uses" include production of trees and the %processing of forest products; open
space; buffers from noise and visual separation of conflicting uses; watershed protection
and wildlife and fisheries habitat; soil protection from wind and water, maintenance of
clean air and water; outdoor recreational activity and related support services and
wilderness values compatible with these uses; and grazing for livestock;
The Hearings Officer is aware that after the close of the record Cascade Timberlands sold
Deschutes County holdings. I will continue to refer to these ;ands as Cascade Timberlands property.
its
11 The Hearings Officer finds I may take official notice of data collected and a€ntaaned by the Deschutes
County Assessor concerning real property in Deschutes County.
12 This study area is equivalent to Inc county's one -mile -radius study area for non-farm dwelling
conditional use approval requiring a similar analys€s of the impact from such a dwelling on accepted farm
practices in the surrounding area
Tree Farm 4. 247 -14 -000248 -CU, 247 -14.00O249 -TP
Page 0- of 117
representing the natural character of central Oregon. Specifically, landscapes,
which are visible from selected travel''' routes and places which are frequently
visited will he managed to maintain or enhance their appearance. The proposed
trail network will provide a variety of scenic vistas for visitors. The proposed
horrresites in The Tree Farm project overall and in Tree Farm 1 specifically are all
located well away frorrr the travel corridor of Skyliners Road within the Deschutes
National Forest, and thus will have no negative visual impact on the forest use
identified in the Forest Plan. In addition, use of the PUD to cluster development'
allows homesites to be sited at a further distance from the boundaiy than w,wouid
development of ten -acre lots. The open space tract rnust remain in that state and
will be subject to deed restrictions;
The Hearings Officer finds that under the broad definition of "forest use" In Title 18, the DNF is
land s`devoted to forest use." I find the uses occurring on and planned for that land
recreational, and preservation of open space and scenic vistas — are of relatively low intensity'
compared with timber harvesting. I also find the nature of these existing and planned uses for
this portion of the DNF reflects the land's proximity to the Bend urban area and its function as a
gateway to millions of acres of public recreational land west of Bend, Nevertheless, in his
November 21, 2014 comments on the applicant's proposal, County Forester Ed Ke stated:
"I would note that the Forest Service does have an approved protect called West
Bend' that will be active for the coming several years on lands immediately west
of the property. Planned activities include commercial and non-commercial
thinning, brush mowing, pile and broadcast burning."
In his December 10, 2014 comments in support of the applicant's proposal attached to Jeffrey,
Gond'€t's December 11, 2014 letter, Gary Marshall, former City of Bend Fre Marshal, stated the
UFS has begun implementing the "West Bend Plan" which he descries as involving the
restoration of 26,000 acres of the DNF adjacent to The Tree Farm for the dual purposes of
improving wildlife habitat and reducing wildfire risk. Mr. Marshall stated the methods utilized in
the "Wes Bend Plan" are essentially the same as those previously employed, and proposed to
be continued, on The Tree Farm property,
Based on this information, the Hearings Officer find it appropriate to assume these nearby DNF
lands also will be managed for forest health and fire prevention through periodic thinning by,
logging and controlled''' burns, impacts from these higher -intensity forest practices would include
noise from tree cutting, noise and drifting dust from log truck traffic on unpaved roads, and
drifting of chemicals and smoke from prescribed' burns and pileislash burns,
On behalf of LandWatch, Paul Dewey claims the presence of homes in
cause the DNF to abandon forest practices su
suppression techniques." He cites research pape
Economics, included in the record as Exhibit "E"
submission. This paper is based
The Tree Farm will
h as "aggressive fuel treatment and fire
r on wildfire risks from Headwaters
o Mr. Dewey's November 19, 2014
on case studies of eight communities, none of which includes
Bend or Central Oregon. Altho€agh these studies provide useful general Information, the
Hearings OfficeHindstley are not -a substitute -for -site -specific -analysis o the impact' of -the -ten
proposed dwellings in Tree Farm 4 on DNF lands within the study area. Moreover, the evidence
in this record does not support Mr Dewey's assertion that the DNF is undertaking, or planning
to undertake, "aggressive fuel treatment and fire suppression techniques." 'r. Dewey
acknowledges that since the management plan for the DNF lands closest to The Tree Farm
includes preservation of scenery, any logging wi
I be done in a more visually sensitive way * * *
Tree Fara 4. 247 -14 -000248 --CU, 247 -14 -000249 -TP Page 2
of 117
than in the General Forest," which the record indicates i
southwest of The Tree Farm 13 Finally, Mr. Keith stated that i
located approxi'
his opinion:
ately'
five miles
x # * rather than restricting management because of development, This project
["West Bend']>is going on because of development and the recognition of task
that the current condition of these lands pose to the greater Bend area."
Existing development near the DNF includes both Bhevlin Park and tiro large rural residential
developments — The Highlands at Broken Top and Tetherow. Based on Mr, Keith's comments,
the Hearings Officer believes it is appropriate to assume the management plans for the nearby
DNF ands already have been influenced to a significant degree by the presence of these land
uses, as well as nearby developments within the Bend UGB
The record indicates that at ts closest points, the portions of the DNF engaged in, and planned
for, scenic preservation and recreation are located between 3,000 and 4,000 feet from Tree
Farm 4 Lot 40, the most southwestern lot. The staff report suggests, and the Hearings Officer
agrees, that because of the combination of the intervening distance and the low -intensity uses
on the nearest DNF lands, current and planned management practices on nearby DNF lands
will result in few if any impacts on Tree Farm 4 residential uses: 1 find the lack of comment on
The Tree Fara from the UBFS 'strongly suggests it has no concerns about the impact of
dwellings in Tree Farm 4 on it management practices.
For the foregoing reasons, the Hearings Officer finds Tree Farm;, 4 and its residential uses wil
not force 'a significant change in, or significantly increase the cost of, accepted forest pract
on FJNF lands in the study area.
ices
Private Forest Land, The private forest lands west and northwest of Bhevlin Park are part of
the "Bull Springs Block" that was once part of the DNF, These lands were transferred to Crown
Pacific, and following its bankruptcy were conveyed to other owners including Cascade
Timberlands. They form much of the forest land visible to the west of Bend. The record indicates
that before Cascade Timberlands sold its Deschutes County holdings, the company and other
stakeholders had discussed long-term planning for this land — referred to as "Skyline Forest"
to include a combination of preserve ion of open space and scenic v€ews, recreat€on, and
sustainable timber production, not unlike the plan for nearby DNF lands.
The record does not indicate what types of uses currently are occurring on the Cascade
Timberlands property or on the s€nailer private forest -zoned parcels northwest of The Tree
Farm. in the Hearings Officer's previous decision in Taylor (MP -05-31, CU -05-106, SMA -05-41,
MA -06-1, MA -06-8), involving an application for a large -tract dwelling on a forest -zoned parcel
northwest of The Tree Farm, i made the following findings concerning accepted forest practices
on'the Cascade Timberlands property:
"
andWatch argues that although current forest practices in the study area are of
Io intensity, the Hearings Officer should include within the `accepted forest
practices' in the study area>rruch more intensive practices drat could occur in the
future iif'reforestation ' occurs on a large ''scale and maturetrees s 'arE harvested in
greater numbers. L.andWatch's predecessor Sisters Forest Planning Committee
13 Included as Exhibit "H' tc Mr. Condit's December 11, 2014 letter is a color -coded map depicting the
DNF west and southwest of The Tree Farm, and showing the more distant location of the DNF 'General
Forest" — i.e., the area planned for timber production.
Tree Far rh 4, 247-14-000248-C11, 247 -14 -000249 -TP
Page 21 of 117'
(SFPC) rr ade the same argument Hogensen, 1r that decision. I r : de the
following pertinent findings:
The Hearings Officer concurs with the appellant that it is reasonable to
asorrne the Terni `accepted' forest practices includes not only those
practices currently taking place, but lh€ se that could occur in the future.
Nevertheless 1 find it is not reasonable to speculate from this record that
ail land in the study area will be reforested and harvested to the most
intense degree possible — particularly where,as here, the record indicates
Crown Pacific [the predecessor of Cascade Timberlands] has been
selling tracts of its forest -zoned land for residential development purposes
rather than for timber management and harvest. Therefore, l firm' it
appropriate to evaluate the impacts of the proposed dwelling on those
forest practices that are most prevalent currently and in the recent past -
Le., selective harvesting' of trees, long hauling, slash and pre,.prescribed
burning, and some chemical spraying,
These findings were challenged by SFPC and upheld on appeal. Sisters Forest
Planning Committee v. Deschutes County. The Hearings Officer adheres to
these findings here."
On appeal of the Hearings Officer's decision in Taylor (Central Oregon LandWa'lch v. Deschutes
County 53 Or LUBA 290 (2007), LUBA found that the scope and intensity of accepted forest
practices is a "fact -specific inquiry," and upheld my findings. There is no evidence in this record
that Cascade Timberlands continued its predecessor's practice of selling individual forest -zoned
parcels for residential use. However, it appears from this record that in the ten years since my
Taylor decision the general nature of accepted forest practices on the Cascade Timberlands
property has not changed. Therefore, I find it is appropriate to assume accepted forest practices
on these lands would' include selective harvesting of trees, log hauling, slash and prescrbed
burning, and some chemical spraying. have found potential impacts from such uses include
noise from logging, noise and drifting dust from operating log trucks on unpaved roads, drifting
of chemicals, and drifting of smoke from prescribed burns and pile/slash burns.
The tentative plan for Tree Farris 4 shows its most western lots, Lots 39 and 40, would be
located more than 4,500 feet from the nearest point on the Cascade Timberlands land and
farther from the nearest smaller private forest -zoned parcels to the northwest. The intervening
land includes' large open space tracts in the western portion of The Tree Fara as well as
Shevlin Park. As with the nearby DNF lands, the Hearings Officer finds it is likely the presence
of Shevlin Park has influenced, and will continue to influence, the intensity of forest practices on
the nearby private forest lands. l find impacts, if any, on Tree Farm 4 from forest practices on
the nearby private forest lands would be significantly attenuated by distance and intervening
open space.
For the foregoing reasons, the Hearings Officer finds Tree Farm 4 will not force a significant
change in, or significantly increase the cost of, accepted forest practices on the nearby private
forest lands. Therefore, I find the applicant's proposal satisfies this rule requirement,
11
For any open spec e or common area provided as
part of the cluster or planned unit development under
this subsection, the owner shall submit proof of
nonrevocable deed restrictions recorded in the deed
Tree Farm 4, '141-1 -000248-CU, 247-14-000249-T'
Page 22
117
records. The deed
rights to construct a dm
tract designated as open
estri
long as the lot, parcel,
urban growth boundary,
ctions shall preclude all future
�ael'ling on the lot, parcel, or
space or common area for as
or tract remains outside an
FINDING. The applicant proposes to make the Tree Farr€ 4 open space tract subject to deed
restrictions as depicted in '''Exhibit "L" to its burden of proof. '''However, the sample deed
restrictions included in this exhibit do not state they would permanently prohibit development of
the open space tracts. Rather, they use language similar to that set forth above in Paragraph
(H) — i.e., development of the, open space tract would be prohibited for so long as the property is,
outside the Bend UGB. As discussed in findings throughout this decision, the applicant > has,
stated it intends that The Tree Farm and Tree Farm 4 never will be included in the Bend UGB,
and has proposed that the development ` create a "permanent" transition area between urban
uses to the east and S evlin>.Park and forest land to the west.
Accordingly, the Hearings Officer finds the applicant will be required as a condition of approval
to record nonrevocable deed restrictions for the Tree Farm 4 open space tract stating that no
portion of the open space tract will be used for a dwelling or any other use in perpetuity. In
addition, the applicant wil be required as a condition of approval, and prior to submitting for final
approval any plat for Tree Farre development, to provide to the Planning Division for county
review and approval a copy of the required deed restrictions, as well as copies of the recorded
deed restrictions after recording. l' find that with imposition of these conditions of approval the
applicant's intent will be accomplished' and the open space tract in Tree Farm 4 will be
preserved as open space as required by this paragraph.
{f Except as provided in subsection (e) of this section, a local
government shall not allow more than one permanent single-
family dwelling to be placed on a lot or parcel in a rural'
residential area. Where a medical hardship creates a need for
a second household to reside temporarily on a lot or parcel,
where one dwelling already exists, a local government may
authorize the temporary placement of a manufactured
dwelling or recreational vehicle.
FINDINGS: The applicant proposes one single-farn,ily dwelling per residential lot,, therefore
satisfying this criterion:
2 Dlvision 11, Pu
OAR 6
1) As
(b
blic Facilities Planning
60-01
100
065, VVate
Service to Ru
al
nd
a
used in this rule, unless the context requi
res otherwise..
"Establishment' means the creation of a new water system
and all as o dated physical components, incl d)„ systems
provided by public or private entities,
"Extension of a water system" means the extension of a pipe,
conduit, pipeline, main, or other physical component from or
to an existing water system rn order to provide service to a
Tree Fara 4, 247-14-00 24
-CI.E, 247-14-Of30249-TP
Page2:3cf117
use that was not served by the system on the applicable date
of this rule, regardless of whether the use is inside the
service boundaries of the public or private service provider.
(c) "Water system" shall have the same meaning as provided in
Goal 11, and includes all pipe, conduit, pipeline, mains, or
other physl cal components of such a system.
(2) Consistent with Goal 11, local land €sae ray s latlos s alicable to
lands that are outside urban growth boundaries and
un ncor prat d communit:: boundarle shall not:
(a)
(b)
(c)
Allow en„i crease €n a Jantstkritalty in a residential zone due
to the availability) of sere ce from watersystem;
Allow a hi
er sys
or
t
m tha
for residential development served by
n will be authorized without such service;
Allow an increase in the allowable density of residential
development due to the presence, establishment,, or
extension of a water system.
) Applicable provisions of this rule, rather than conflicting
provisions of local acknowledged' zoning ordinances, shall
immediately apply to local land use decisions filed subsequent
to the effective date of this rule. . (Emphasis added.)
FINDINGS° The applicant proposes to provide domestic water to the Tree Farm 4 lots through
one of three options: (1) extension of City' of Bend water service; (2) securing water service from
Avian Water Company; or (3) pumping, water from one or more wells on The Tree Farm or
adjacent property. The Hearings Officer finds both Bend's and Avion's water systems constitute
"water systems" for purposes of this rule.
The base density of the UAR-10 Zone will allow the creation of up to ten new residential lots in
Tree Farm 4, as proposed by the applicant. The Hearings Officer finds the applicant's proposal
will not allow an increase in the UAR-10 base density, allow higher residential density than
would be authorized without water service, or allow an increase in allowable density due to the
presence or extension of a water system€. Therefore, I find the applicant's proposal satisfies this
criterion.
For the foregoing reasons, the Hearings Officer finds the applicant's proposal satisfies, or with
imposition of the conditions of approval described above will satisfy, all applicable provisions of
the administrative rules in Divisions 4 and 11 of OAR Chapter 660.
C. Title 16 of the Deschutes County Cod, the Deschutes County Zoning Ordinance
ce
RR -10 ZONE STANDAR
DS
1, Chapter 18 60, Rural Residential
Tree Fa14, 24T-14-0 024
CU, 247-14-00024
9 -TP
Zone ® R
R-10
Pag
e24of117
Section 18.6
0.0
0, Con
t
itional Uses Perm
fitted
The following uses may be allowed subject to D
Cluster development.
CC
8128:
FINDINGS: : The Tree Farm 4 tentative plan shows most of the proposed, open space tract would
be located within the RR 10, Zone. The Hearings Officer has found the proposed cluster/PUD is
a use permitted conditionally in both tine RR 10 and UARL10 Zones under Sections'
18.60.030(E) and (F) and 19.12.030(N), respectively. The staff report states the RR 10 Zone
provisions applicable to residential lots are not applicable to Tree Farm 4 because its residential
lots are not located in the RR -10 Zone. However, as discussed above, l`> have found that to the
extent feasible, I' Will apply the provisions of both the RR -10 and UAR-10''Zones to Tree Farms 1
through 4 in their entirety rather than segmenting my review based on the zone boundaries:
Therefore, I find the provisions of the RR -18 Zone are applicable to Tree Fenn 4 as a whole.
The proposal's compliance with the provisions of Chapter 18.128 is discussed in findings below
under that chapter.
b. Section 18.6
0.040, Yard a
nd
Seth
0
k Requirer
In an RR -10 Zone, the followmg yard and setbacks shall be
maintained`
A. The front setback shall be a minimum of 20 feet from a
property line fronting on a local street right-of-way, 30 feet
from a property line fronting on a collector right-of-way' and
50 feet from an arterial right-of-way.
There shall be a rninimurrr side yard of 10 feet for all uses,
except on the street side of a corner ot the side yard shall be
20 feet.
Th
e mini
rear yard shall be 2
0 feet.
D. The setback from the north lot line shall
setback requirements in DCC 18110180.
Beet t
he solar
In addition to the setbacks set forth here€r, any greater
setbacks required by applicable building or structural codes
adopted by the State of Oregon and/or the County under DCC
15.04 shall be met.
INDINGS: The tentative plan for Tree Farre 4 shows all residential lots Mill front on kcal road
rights-of-way, and therefore the minimum front yard setbos.k for dwellings is 10 feet Section
18.04.030 defines "corner lot"' as
* a lot adjoining two or more streets, other than alleys, at their intersection
provided the angle of the intersection of the adjoining streets does, not exceed, 135
degrees.
Tree Farm 4. 247-14 O0O2,
-CU, 247 -14 -000249 -TP Page 25 of 11
The tentative plan shows Tree Fare 4 Lots 31 and 32 constitute "corner lots" because they are
located at the intersection of Golden Mantle Loop and Ridgeline Drive. Therefore, the minimum
side yards for these two lots are 20 feet, and the minimum side yard for the other eight lots i
feet. The minimum rear yard for all lots is 20 feet. The Hearings Officer finds the applica
be required as a condition of approval to assure dwellings on the Tree Farm 4 lots meet these
minimum setbacks and yards.
Section 18.60.0
60. Dimensional Standards
n an RR4O Zo
<* *
e thefo
llo
ing di r ension
Minimum lot size shall
cluster developments shall
al
anda
rd
ss
hall ap
be 10 acres, except planned' and
be allowed an equivalent density
ned and cluster development
ed urban growth >>boundary',
mum lot size or eguivalent
of o
with
shall
d
a
e unit ' per 7.5 acres. Plan
n one mile of an aoknoled
be allowed a five acre min
ensity. For
n exernptio
pa
ns
reels se
hall be
parated by new arterial rights of way,
ranted pursuant to DCC 18.120.020.
g
FINDINGS: The Hearings Officer has found the applicant's proposal satisfies the maximum
density under OAR 660-004-0040, which allows lots as s€mall as two acres. The applicant'
proposes ten 2 -acre residential Tots and ane 87.7 -acre open space tract for Tree Farm 4. As
discussed in the findings below under the WA Zone, Section 18.88.050 requires that all
residential lots within the WA Zone be Blustered and a minimum of 80 -percent open space be
preserved. The burden of proof for Tree Farre 4 states the applicant chose to plat all residential
lots in The Tree Farm € --- including all lots in Tree Farms 1, 2, and, 3, and Lots 31-36 and 38 in
Tree Farm 4 in the UAR-10 Zone -- at 'two acres In size, and to duster the residential lots, in
order to maximize open space and to create a consistent development pattern throughout The
Tree Farm in spite of its split zoning.
For the foregoing reasons th
applicable criteria in the RR -10
WA ZONE STANDARDS
e Hearings Officer fin
Zone.
d
the a
pplioan
t propose l satisfies al'l
2. Chapter 18.88, Wildlife Area Combining Zone — WA
a. Section 18.88.010, Purpose
The purpose of the Wildlife Area Combining Zone is to conserve
important wildlife areas in Deschutes County; to protect an
important environmental, social and economic element of the
area; ;,and to permit development compatible with the protection
of the >Wildlife resource,>
Sectio
n 18.8
8.020, Application of provisions
The provisions of DCC 18.88 shall apply to all areas identified in
the Com rehensive plan as a winter deer range, significant ells
Tree Farris 4, 247-14-0002 -CU, 247 -14 -000249 -TP Page 26 of 117
habitat, antelope range or deer miration corridor.
ll nincorporated communities are exempt from the provisions of
DCC 1&88. (Emphasis added.)'
FINDINGS: The tentative plan for The Tree Farms shows the western 3 f "the entire
development, and the western 88.5 acres of Tree Farm 4; are within the WA Zone associated;
with Tumalo deer winter range. The Hearings Officer has found that because the WA Zone is an
overlay zone protecting a specific geographicall'y-defined and mapped resource, l wai apply the
WA Zone only to those portions of Tree Farms 1 through 4 located within the WA Zone.14
Therefore, 1 find the WA Zone provisions apply only to the portion of Tree Fara 4 located in the
WA Zone, consisting of Lots 37, 39 and 40, open space, a segment of Golden Mantle Loop, and
a portion of the recreational trail system.
b. 5
ecti
on 18.8 .040,, U
ses Perrrrn'itted Conditionally
"
Except as provided in DCC 18,88,040{1 )p in a zone with which
the WA Zone is combined, the conditional uses permitted
shell be those permitted conditionally by the underlying zone
subject to the provisions of the Comprehensive Plan, DCC
18.128 and other applicable sections of this title.
FINDINGS: Cluster developments are permitted conditionally in the RR -10 Zone and therefore
they are allowed conditionally in the WA Zone, Compliance with the specific cluster
development standards in Chapter 18.128 is addressed in the findings below.
Section 18.8
8.0
5
0. Dimensional Standard
sr
l'rn aVVA Zon
e, the follow
g d'!
mensional s
tan
da
rd
s shall a
pply:
A. In the Tumalo, M tollus, North Pauline and Grizzly deer whiter
ranges designated in the Comprehensive Plan Resource
Element, the minin a an n lot size for ne+ : arc 1s shall be 40
acres except as provided in DCC 18,88,050(D).
FINDINGS: Section 18.04.0 30 defines "parcel" as "a unit of land created by a partitioning of
an€d." The applicant does not propose the creation of any new parcels, and therefore the
Hearings' Officer finds this criterion as not applicable, in any case, Tree Farm 4 would be 109.5
acres in size, and the portion of Tree Farm 4 in the WA Zone would be 88.5 acres, exceeding
the minimum lot size for new parcels.
D. 'Residential land divisions, including partitions, in deer winter
range where the underlying, zone is IRR -10 or MUA.-10, shall
not be permitted except as a plan ed development or cluster
development conforming to the following standards:
FINDINGS: The a=nppllcant propose a residential land division co € sisting of t €lot.
cluster, PUD on property zoned RR -10 and UAR-10, therefore satisfying this criterion:
d As noted above, Tree Farms ''1, 2, an 3 slsc have spaat zoning between t.EAR-1nd RR-10/14VA.
Tref
4, 247-14-00024
-c'
, 247 -14 -000249 -TP
Pay
e 27 of 117
FINDINGS: According to the subm
acres, 88 5 acres of which; would
minimum area standard.56''
The minimum area for a planned or du
development shall be at least 40 acres.
e r
fitted'' tentative plan, Tree Farm 4 would consist of 109.5
be located within the WA Zone, therefore satisfying this
The planned or cluster development shall,' r
minimum of 80 percent open space and conform with
the provisions of DCC 18.1 8.00or 210.
am a
FINDINGS: Accord€ng, to the submitted tentative plan, Tree Farm 4 would have 20 acres of
residential lots (ten 2 -acre lots), 87.E acres of open space, and 1.7 acres of right -cit -gray. The
tentative plan shows 857 acres of the open space and 0.8 acres of the right-of-way would be
located within the WA,Zone; Based on this acreage, 80 percent of the entire Tree Farm 4, and
approximately 98 percent of the WA -zoned portion of Tree Farm 4, would be open space. The
applicant's burden of proof states the 80 -percent open space should be calculated including
only the WA -zoned land, based on, the following analysis:
"Overall the 5 separate PUD/Cluster Development proposal withir 'The Tree,
Farm will result' in fifty 2 -acre hor esites totaling 100.1 acres on 533.5 combined
acres. Open space will comprise 422.8 total acres, or 79% of the total project
(the remaining 10.6 acres are within the new street rights of way.). While this is,
just under 80% open space for the entire project, the applicant notes that only
2. 1f s oUr+g pr o u" 1 rA , zoned R 1.0 (VA and rubiPot to thr- 80%
reaurrerr rrt the rar arrr€1cr bora f z IP.c A 1 rt i had 2Q a rc# .§P§Sific
open space requirement. Of the 393 acres in the RR-10(WA). 362.7 acres (92%)
will be preserved as permanent open space., This is accomplished' by
concentrating the developed homesites in the UAR-10 portion of the property in
order to nnaxirize the amount of open space to be preserved in the deer winter
range."
The Hearings Officer agrees with the applicant that land outside the WA Zone is not included in
the open space calculation, and therefore I find Tree Farm 4 satisfies the minimum 80 percent
open space requirement in the WA Zone.
Notwithstanding the provisions of DCC 18.128.200 or
210, or ' DCC 18.60.060(C), the Natal number of
residences in a chaster development may not exceed
the density permitted in the underlying' zone,
FINDINGS: The general density in, the RR -10 Zone is one dwelling per ten acres. The applicant
proposes that the 109.5 -acre Tree Farm 4 be developed with ten residential lots and one open
space tract. The Hearings Officer has found the open space tract is not included in the
residential' density calculation, and therefore Tree Farm 4 satisfies' this standard
1
5 The Hearings Officer add
proposed creation of
linil g (SM). section
quoted language mea
language establishing
Is Ile in Taylor,
Tree F'n 4, .47-14-0
sed a similar issue in my T ylor-decision, cited above. There, the applicant
parcel comprised of 40 acres zoned F-1 and 40 acres zoned Surface
stablishes an 80 -acre rminimum lot size "in the F-1 Zone." I held the
e rhinimurm lot size must be met entirely within the , -1'' Zone. The
1 lot size in the A gone is identical to the language in F-1 Zone at
00248-
tl
247-1 4 -000240 -TP
Page 28 o
:117
da Section 18.88.060, Siting Stand
ards
A. Setbacks shall be those described in the and
with which the WA Zone is combined,
erlyin
g zone
FINDINGS: The Hearings Officer 'finds this provision applies to setbacks between structures
and lot lines. Three of the residential lots in Tree Farm 4 — Lots 37, 39 and 40 — would be
located in the WA Zone. Therefore, l find this criterion applies to those lots. I find that as
condition of approval the applicant will be required to assure compliance with the applicable
setbacks in the RR -10 Zone, set forth in the findings above.
B. The footprint, including decks and porches, for new dwellings,
shall be located entirely within 300 feet of public roads,
private roads or recorded, easements for vehicular access
existing as of August 5, 1992 unless it can be found, that:
1. Habitat values (i.e., browse, forage, cover, access to
water) and migration corridors are afforded equal or
greater protection through a different development
pattern; or,
The siting within 300>.feet of such roads or easements
for vehicular access will` force the dwelling to be
located on irrigated land, in which case, the dwelling
shall be located to provide the least possible impact
on wildlife habitat considering browse, forage, cover,
access to water and migration corridors, and
minimizing length of new access roads and driveways;
or,
The dwell'
ed
g
ng is set back no more than 50 feet from the
e of a d
For purposes of
D
riveway that existed as of August 5, 1992.,
CC 18.8
8.0
60(B):
1. A private road, easement for vehicular access or
driveway will conclusively be regarded as having
existed prior to, August 5, 1992 if the applicant submits
any of the following:
a. A copy of an easement regarded, with the
County Clerk' prior to August 5, 1992
establishing a right of ingress and egress for
vehicular use;
An aerial photograph with proof that It was
taken prior to August 5, 1992 on which the mead,
easement or driveway allowing, vehicular
access is visible;
Tree Farm;. 4, 247.14 -000248 -CU, 247-14-0 -TP
Page 29 of t 1
A map published prior to August 5, 1992 or
assessors map froth prior to August 5, 1992
showing the road (but not shoing a mere trail
or footpath).
An applicant may submit any other evidence thought
to establish the existence of a private road, easement
for vehicular access or driveway as of August 5,'1992
which evidence need not be regarded as conclisiv .
FINDINGS: Section 18.04.030 defines "road" as "a public or private way created to provide
ingress or egress to one or more lots, parcels, areas or tracts of land." The applicant's burden of
proof for Tree Farm 4 states the building envelopes for Lots 37, 39 and 40 are located entirely
within 300 feet of roads that were in place prior to August 5, 1992. in support of that statement
the applicant submitted as part of its VVMP in Exhibit `"I°' to the Tree Farm 4 burden of proof two
aerial photos of The Tree Farm property dated July 28, 1990. These photos show a network of
dirt roads on the property referred to in the burden of proof as former logging roads. in addition,
the WMP includes a diagram prepared by the applicant's engineer WH Pacific that
superimposes the dirt ,roads on the Tree Farm 4 lots, The Hearings Officer has examined these,
photos and diagram and i find they provide conclusive evidence that the building envelopes on
Lots 37, 39 and 40 in Tree Farm 4 are located within 300 feet of one or more dirt' roads that
appear in the 1990 photographs, and therefore dwellings on those lots can be constructed in
compliance with this paragraph 16' For these reasons, i find Tree Farm 4 satisfies the criteria in
this section;
Section 1
8.070
Fence Stand
and
5
The following fencing provisions shall apply as a condition of
approval for any new fences constructed as a part of development'
of a property in conjunction with a conditional use permit or site
plan review.
New fences in the Wild!'€fe Area Combining; Zone shall be
designed to permit wildlife passage. The following standards
and guidelines shall apply €,Mess an alternative fence design
which provides equivalent wildlife passage is approved by
the County after consultation with the Oregon Department of
Fish andWildlife:'
The d
lista
nce between the grou
strand or board of the fence shall
nd and the bottom
be at least 15 inches.
The height of the fence shall not exceed 48 inches
above ground level,
16 Ail ten proposed residential lots in Tree Farm 5 would be located within the WA Zone. In the Hearings
Officer's decision in Tree Farm 5, l found the building envelopes :or two of the Tree Farm 5 lots, Lots 41
and 42, would not be located within 300 feet of an ;,existing road. However, 1 found based on the W€vtp
that the placement of Lots 41 and 42 farther than 300 feet from one of the former logging roads satisfies
this criterion because habitat values (1 e., browse, forage, cover, access to water) and >migration corridors
are afforded equal or greater protection through this alternate development pattern;
Tree Faro's 4, 247 -14 -000248 -CU 247 4--000249-TP'
Page 30 of 1 17
Smooth wire and wooden fences that allow passage of
wildlife are preferred. Woven wire fences are
discou
ra
g
ed.
Exemptions:
1. Fences encompassing less than 10,000 square feet
which surround or are adjacent to residences or
structures are exempt from the above fencing
standards.
2. Corrals used for workins livestock,
FINDINGS: The applicant does not propose any new fencing for Tree Farm 4, and therefore the
Hearings Officer finds these criteria are not applicable. However, to assure compliance with
these standards, E find that as a condition of approval the applicant will be required to install any
fencing in the VVA-zoned portion of Tree Farm 4 in accordance with these standards. As noted
above, the applicant proposes to remove most of the >exist ing wire fencing on The Tree Farm.
For the foregoing reasons, the Heart
standards, in the WA Zone
gs Officer find
CONDITIONAL USE APPROVAL CRITERIA
Chapter 18.128, Conditional Us
Section 18.128.010, 0
pera
tions
s Tree
Farm 4 satisfies all a
p
plic ble
A. A conditional use listed in DCC Table 18 shall be permitted,
altered or denied hi accordance with the standards and
procedures of this title; DCC Title 22, the Uniform
Development Procedures Ordinance; and the Comprehensive
P la
ne
Section 18.128.015, General Standards 0
overn ng
c
and
itional Uses
Except for those conditional uses permitting individual single
dwellings, conditional uses shall comply with the fol
standards h addition to the standards of the zone in whi
conditiona
chapter:
use is located and any other a
pplicab
fails
lowing
ch the
e standards of the
FINDINGS: The applicant argues the general conditional use standards in this section do not
apply to Tree Farm 4 because the proposal ''includes individual" single-family dwellings. The
Ilea in x=Officer disagrees." I find these' criteria are applicable to Tree Farm 4 because the
proposed conditional use is a chaster development, not an "individual single-family
The applicant did not address these critena in its burden of proof for Tree Fara 4, but in>>response to
the staff report sLibrnitted>. a memorandum dated October 29, 2014, addressing the critena:
Tree Farm 4, 247-1r -000218-CU
247-14-000249
Pa 31 of 117
A. The site under consideration shall be d
suitable for the proposed use based on the to
eterrnined to be
lowing factors:
FINDINGS: At the outset, staff questions what constitutes the "site" for purposes of the
suitability analysis under this paragraph in light of the split zoning of Tree Farm, 4. As discussed
above, the Hearings Officer has found that in order to conduct a meaningful review of Tree
Farm 4 as a whole, I will apply the standards in both Title 18 and 19 -- with the exception of the
WA Zone in Title 18 -- to the entire cluster/PUD, Therefore, I find the site for evaluation of the
proposed cluster/PUD is the entire Tree Farm 4,
1. Ste, desig
n and o
Perating pha
ra
cte
risti
of the us
Site. Tree Farm 4 would be 109.5 acres in sire. It is very irregular in shape, the result of the
irregular shape of The Tree Farm and the configuration of its five legal lots of record. The
topographical information on The Tree Farm tentative plans shows the configuration of Tree
Farms 1 through 5 generally follows the contours of the property, and in particular the central
ridge that runs generally in a southwest -to -northeast direction. Tree Farm 4 is in the western
half of The Tree Farm. It extends from the most northern point of The Tree Farm in a generally
southwest direction to the northern border of Tree Farre 5. The topography of Tree Farm 4
varies from higher, relatively level ground in its northeastern area where the residential ots are
proposed to steeper slopes in the rest of the site and within the open space tract. Vegetation in
Tree Farms 4 consists almost entirely of mature forest with some shrub steppe vegetation in the
northeastern portion where the residential lots are proposed, Tree Farm 4 does not have
frontage on Skyl ners Road: it is separated from the road by the most southwestern portions of
Tree Farms 2, 3 and 5. Tree Farm 4 is separated from the Bend UGB by Tree Farms 1, 2 and 3
and a vacant parcel owned by Miller Tree Farm.
Design and Operating Characteristics. The proposed ten residential lots in Tree Farm
world be clustered in the north -central portion of The Tree Farm on higher, relatively level
ground. All lots would have frontage on 'Ridgeline Drive and/or Golden Mantle Loop. Ridg line'
Drive intersects with Golden Mantle Loop and extends southwest through Tree Farms 2 and 3
to connect with Tree Farm Drive, the primary PUD road which intersects with Skyliners Road at
the southern property boundary. The applicant proposes to develop Tree Farms 1, 2 and
concurrently to provide access from Skylivers Road to the ots in those three cluster/PUDs.
Construction of Tree Farm Drive in Tree Farms 1, 2 and 3 would allow the connection to Golden
Mantle Loop in Tree Farrn 4. The topographical information on the tentative plans shows the
private roads will be constructed primarily on the centra ridge, thus minimizing steep road cuts
and,, grades,.
A gated temporary emergency access road would extend from the southern terminus of Sage
Steppe Drive in Tree ''Farm 1 south across the adjacent Miller Tree Farm property to Crosby
Drive in the Bend UGB. This secondary access would be in place until the adjacent Miller Tree
Farrn property is developed with paved streets to which Sage Steppe Drive could connectSage
Steppe Drive would be a dedicated public road with 60 feet of right-of-way and would be
stubbed off at the northern boundary of Tree Farm 1 to provide future road access to the
adjacent Rio Lobo property. W. {ith 'development'` of Tree Farms 1, 2 and 3, lots in Tree Farm
world have a connection to the secondary access road. The applicant proposes that each
dwelling would be constructed within a designated building envelope, would be served by an
onsite septic system, and would receive water from the City of Bend, Avon `dater Company, or
one or more groundwater wells.
Tree Fara 4, 247-:4-00 248 -CU
4-o0
4249 -TP
Pag
e32of117
The majority of Tree Farm 4 (87.7 '' acres) would be set aside as permanent open space. The
public would have access to this, open, space through a combination of a permanent trail
easement on the primary trails within The Tree Farm and a license granted by The Tree Farm
homeowners' association (HOA) for use of trails within the residential lot areas. The multi -use
paths and recreation/mountain bike trails in Tree Farris 4 would connect with trails in the rest of
The Tree Farm and Shevlin Park and the DNF to the west and southwest.
The Hearings Officer finds the site for Tree Farm 4 is suitable for the proposed ten -lot
cluster/FUD because of the nature of the site and the design and operating characteristics of
the proposed development, I find the property is large enough to accommodate the proposed
residential lots, open space tract and private roads. I find the clustering of dwellings in the
northeastern part of Tree Farm 4 will preserve the maximum amount of open space and will
allow the dwellings to be sited on the only level ground on Tree Farm 4; !find the design of the
private roads in Tree Farm 4 has taken into account the site's topography so the roads can be
constructed without steep slopes or road cuts and tight curves. As discussed in the findings
immediately below, 1 have found soils on the site are suitable for installation of on-site septic
systems. I also have found the proposed dwellings will have adequate access to Skyliners Road
with concurrent developnnent of Tree Far rr€s 1. 2 and 3.
For the foregoing reasons, the Hearings Officer finds the site of Tree Farm 4 is suitable for the
proposed ten -lot cluster/PUD considering the site and the design and operating characteristics
of the proposed development.
2. Aden
ua
y of tra
nsportation a
ccess to the site; and
FIND NG : Access to Tree Farm 4 will be from Skyliners Road via <a system of public and
private roads. The main access road, Tree Farm Drive, will connect with all other Tree Farm
roads at an intersection in Tree Farm 3. The segment of Tree Farm Drive from Skyliners Road
north to a point near this intersection would be improved with a 6 -foot -wide paved surface to,
accommodate both vehicular and pedestrianbicycle traffic. The remaining segment of Tree
Farm Drive and the other Tree Farm Roads would be improved with 20' feet of paved surface.
The applicant proposes a gated temporary emergency access road from the southern end of
Sage Steppe Drive, a dedicated public road, in Tree Farm 1 south through the adjacent Miller
Tree Fara property to Crosby Drive, a dedicated public street within the Bend UGB, This
secondary access would be in place until the adjacent Miller Tree Fara property is developed
with paved streets to which Sage Steppe Drive could connect.
Traffic Study. In support of The Tree Farm proposal, the applicant s€. bmitted a traffic impact
analysis ("traffic study") prepared by Kittelson€ & Associates, dated July, 2014, and 'included in
the record as Exhibit "H" to the burden of proof statement for Tree Farm 4. The traffic study
indicates the Institute of Transportation Engineers Trip Generation Manua, 9th Edition (ITE
Manual) predicts each single-family dwelling will generate 9.5 average daily vehicle trips
(ADTs). Accordingly, the traffic study predicts the 50 single-family dwellings proposed for entire
Tree Farm would generate 476 ADTs, of which 50 would be during the p.m. peak hour (4:00
p.m. to 6:00 p.m. weekdays). s). The traffic study analyzed the '''impact of this traffic on the
proposed > Skyliners RcadITree Farm Drive intersection. and found sight distance at this
intersection would be adequate in both directions. The traffic study recommended the
placement of a stop sign on Tree Farm Drive at Skyliners Road and maintenance of clear vision
areas at this intersection
4 247- -0
00248 -CU, 247 14-OOO249-T
Page 33 of 117
The traffic study also analyzed' Tree
intersections on the west side of Bend:
Fa
rrn
ra
Skyliners Road and Crosby Drive;
6 Skyliners Road and Skyline Ranch Road;
6 Skyliners, Road and Mt. Washington Drive;
6 Mt. Washington Drive and Northwest Crossin
Mt, Washington Drive and Simpson Avenue.
g
p5
Drive; and
on the foil win
g five
existin
g
The traffic study found these existing intersections currently operate at acceptable levels of
service, and that with the addition traffic generated by The Tree Farm, and including traffic
volume growth of three percent and additional traffic anticipated from development in progress
(including the new Pacific Crest Middle' School and a large church under construction, and
continuing development of Northwest Crossing), these intersections will continue to operate at
acceptable levels of service in 2017 and 2022. In its comments on the applicant's pr€oposal,, the
road department did not identify any concerns or recommend any it provements to Skyliners
Road or other existing roads to handle traffic generated by The Tree Farm. In his August 29,
2014 comments on the applicant's proposal, Senior Transportation Planner Peter Russell stated
he had reviewed the applicant's traffic study and agreed with its methodology and conclusions.<
Several opponents argued traffic from The Tree Farm would cause unacceptable levels of
congestion on affected streets and intersections on the west side of Bend, and would cause,
serious deterioration to Skyliners Road. The Hearings Officer finds no merit to these arguments
in light of the traffic study's conclusions' and the lack of road improvement recommendations'
from the road department.
Opponent Connie Peterson suggested the traffic study should have included in its analysis
traffic generated from a future Oregon State University (OSU) Cascades campus near the Mt.
Washington Drive/Simpson Avenue intersection. The Hearings Officer is aware the city's
approval of a ten -acre OSU Cascades campus is on appeal, to LURA and the approval therefore
is not final. For this reason, l find the OSU development and its potential traffic impacts are too
speculative to be included in The Tree Farm traffic study. Opponent Rio Lobo submitted a
memorandum dated December 11, 2014 from its, traffic engineer, Lancaster Engineering,
suggesting the applicant's traffic study was deficient in failing to include projected traffic from
urban -density development of the adjacent 376 acre Rio ''Lobo property. Rio Lobo's engineer
pred cted up to '1,100 dwellings could be developed on the property, and they would generate
over 0,000 ADTs and 948 p.m, peak hour trips. The Rio Lobo property is outside the Bend UGB,
has no county land use approvals for the type of low-density residential' development permitted
in the UAR-10 Zone i.e., up to 37 dwellings - and has limited road access.18 Therefore, ''1 find
potential traffic impacts from urban -density development of the Rio Lobo property also are too
speculative to be included in the traffic analysis' for The Tree Farm.
Emergency Access. The applicant proposes a gated temporary emergency access road from
the southern terminus of Sage Steppe Drive south through the adjacent Miller Tree Farm
property to Crosby Drive, a public street in the Bend UGB. Sage Steppe Drive vould be a public
road within a dedicated 00 -foot right-of-way and improved with a 20 -foot -wide paved surface.
The emergency access road would be gated at both ends, and constructed with an all-weather
,is December 1 +, 2014 cornrents on the applicant': proposal, Peter Russell correctly noted that
any land use approvals ear current applications for development of the Rio Lobo property, °the
trip generation from the Rio Lobo property is zero."
Tree Farm 4, 247 -14-
0248 -CU, 2
41.14.000240 -TP
Page04of 117
surface meeting the fire department's standards for emergency vehicles. The temporary access
road would provide a means of ingress and egress for Tree Farm 4 lots following construction of
the, private roads in Tree Farms 1, 2 and 3. In his November 20, 2014 comments on the
applicants proposal, County Engineer George Kolb stated the emergency access road must'
have a 24 -foot -wide surface, and on that date, the applicant submitted a revised tentative plan,
for Tree Farm 1 showing the emergency access road would be 24 feet wide.
Crosby Drive provides access to the three nearby public schools — Summit High School, 1 e
Elementary School, and the new Pacific Crest middle school under construction. The tentative
pan for Tree Farm 1 shows the proposed route of this emergency access road across the
adjacent property, and the topographical information on the tentative plan indicates that for the
most part the route would be on level or slightly sloping ground. The exception is a>;s€mall area
just north of S yliners Road where there is a steep ridge. However, the proposed road
al'€gnment>;appears to skirt the steepest part of that ridge. In an October 31, 2014 electronic mail
message, the applicant stated the emergency access road will be constructed with grades not
exceeding 8.5 percent, less than the 12 -percent maximum slope permitted for emergency
vehicle access. In his November 20, 2014 comments, George Kolb stated the proposed
emergency access would require a county gate permit,
At the public hearing, the Hearings Officer questioned how the locked access gates would
operate and whether residents and guests would be able to open the gates. Gary Marshall
stated such gates generally are designed to be operated by the fire department with "Knox"
locks, but that additional options are available for "residential access,' including special keys,
key codes and automatic gates. I find the applicant will be required as a condition of approval to
install one or more of these "residential access" measures on the Tree Farm side of the gate at,,
the southern terminus of Sage Steppe Drive.
At the public hearing, the Hearings Officer also questioned whether the proximity of the three
schools would cause >.Crosby Drive to become so congested during a large-scale emergency
evacuation, such as for a wildfire, that Tree Farm residents would not be able to use the
emergency road for egress, In his January 6, 2015 submission, Mr. Dewey stated the
applicant's proposed secondary emergency access is "fundamentally inadequate" for
evacuations because it must be assumed all three schools and all Tree Farm residents will be
evacuated at the same time. Mr. Marshall responded to these concerns in a letter dated
December 10, 2014, included in the record as Exhibit "B" to Mr, Condit's December 11, 2014
letter. Mr. Marshall stated that in his opinion such congestion would not occur because it is
highly €w€nRely every person in the three schools and every resident in The Tree Farm would
evacuate at the same time and by the same roads. The Hearings Officer agrees with Mr.
Marshall's assessment. The Tree Farm would have two points of egress u-- Tree Farm Drive and
the secondary emergency road rw and the record indicates the schools have several points of
access. I find the existence of multiple points of egress for The T ee Fara and for the schools
would serve to reduce congestion in the event all three schools and The Tree Farm were
evacuated simultaneously. Moreover, I find that in light of Mr. Marshall's extensive experience,
including dealing with wildfires on the west side of Bend, his opinion concerning I'ikely
evacuation scenarios is credllble and reliable.
In a November 4, 2014 letter, included in the record as Exhibit ,'F" to Paul Dewey's November
19, 2014 submission, LandWatch's fire expert Addison Johnson suggested the secondary
emergency access road should be constructed to run in the opposite direction from the main
PUD access road i.e., to the northeast. However. as discussed elsewhere in this decision, the
tentative plan for Tree Farm 1 shows there is steep terrain northeast of Tree Farm 1, and there
Tree Farm 4, 247-14-000248-C
U, 247-14- 0024 TP
Page 35of117
are no existing public roads with which such a secondary access road could connect. Therefore,
I find an emergency access road to the northeast likely would not be feasible.
Skyline Ranch Road, The tentative plan for Tree Farm 1 shows "potential future Skyline Ranch
Road right-of-way" running from Crosby Drive ;,north and northwest across the adjacent i €flier'
Tree Farm property and the northeast corner of Tree Farm 1 east of the cul-de-sac bulb for
Ridgeline Drive. In the Hearings Officer's decision in Tree Farm ''1, I discussed concerns
expressed by county staff and Rio Lobo about the location of this right-of-way. I held''' the
applicant will be required as a condition of approval for Tree Farm 1 to include a notation on the
Tree Farm 1 final plat stating possible adjustments to the open space and right-of-way
calculations if a segment of Skyline Ranch Road is dedicated in Tree Farm 1.
For the foregoing reasons, and with innpoition of the condition of approval described above, the
Hearings Officer finds Tree Farm 4 is suitable for the proposed ten -lot clusteriPUD considering
the adequacy of transportation access to the site,
F
lII
G
3. The
but
and
natural and physical features of the site, including,
not limited to, general topography, natural hazards
natural resource values.
General Topography. The Tree Farm 4 tentative plan shows, and the Hearings Officer's site
visit' observations confirmed, that the Tree Farm 4 site has varying topography. The dominant
feature of Tree Farm 4 is the central ridge running from southwest to northeast. The applicant's
burden of proof states, and my site visit observations confirmed, that the higher ground atop this
ridge is relatively level to rolling, with steeper slopes in the northwest where the terrain drops
toward Tumalo Creek. The tentative plan for Tree Fa r€ € 4 shows, the proposed residential lots
would be located atop this ridge. Topographical information for The Tree Farm indicates the
central ridge in Tree Farm 4 slopes down to the west at grades ranging from 10 to 20 percent;
One of the Tree Farm 4 lots --r Lot 37 — would be located above this slope. As discussed in the
findings below concerning natural hazards, the, Hearings Officer has found the steeper slopes in
this part of Tree Farm 4 and below Lot 37 may increase the risk of wildfire, and the applicant's
wildfire plan does not adequately address this additional risk. For this reason, I' find the applicant
has not demonstrated the site for Tree Farm 4 is suitable for the proposed cluster development
considering its topography.
Natural Hazards. The identified natural hazard affecting The Tree Farm is wildfire. There is no
dispute The Tree Farm is in a wildfire hazard area.' It is located in the "ildland Urban
Interface"'''' (' rU1) i.e;, the transition area between human development and wildland, in this
case forest lands. The eastern half of The Tree Farm was in the path of the 1990 Awbrey Hall
fire that burned approximately 3,500 acres from the north end of Shevlin Park southeast to
point hear Highway 97. The June, 2014 Two Bulls Fire burned several thousand acres of
Cascade Timberlands property west and northwest of Shevlin Park. The Hearings € fficer'finds
The parties disagree as to the degree of that hazard. Paul ;;Dewey describes it as "extreme. The
applicant notes the Greater Bend CWPP (Community Wildfire Protection Plan) Boundary Map, included in
the record in Exhibit , 0' to Mr. Dewey's November 19, 2014 submission, categorizes The Tree Farm and
surrounding and as "high risk" the lowest category of risk -- while other areas on the map are
categorized as higher risk -- a.e.; ''extreme" and high density extreme."
Tree Farm 4, 247.1€4 -000248 -CU, 247 -14 -000249 --TP
Page
3of1
the nature of the wildfire hazard is two -fold: (a) residential uses in The Tree Farm could ignite a
fire that spreads to adjacent land; and (b) wildfire ignited elsewhere in the WUl, such as in the
DNF, could spread to residential uses in The Tree Farm, diverting fire -fighting resources to The
Tree Farrrn,
The applicant's burden of proof states the Awbrey Hall Fire removed much of the forest
overstory in the eastern part of The Tree Farm including the eastern part of Tree Farm 4,
resulting in that area having fewer trees and primarily shrub steppe vegetation. The applicant
states that since the Awbrey Hall Fire, Miller Tree Farm has worked with the Oregon
Department of Forestry (ODF) and others to reduce fire fuels on the entire Tree Farm property,
including tree thinning and brush removal. I observed evidence of this thinning activity during my
site visit. However, as I noted in my site visit report, I observed that the forested part of The
Tree Fara retains a relatively dense tree cover, visible in aerial photographs in the record.2° The
photos show the inte€face between the denser forest and the more open shrub steppe runs
roughly along the line between Sections 33 and 34 and the RR -10 and UA' -1O Zones. The
denser forest also covers a small portion of UAR-1 O zoned property in Tree Fares 2 and 3 and
the most southwestern portion of Tree Farm 1, The shrub steppe vegetation in Tree Farms 1,
and 3 continues north onto the Rio Lobo property and east onto the Miller Tree Farm property.
LandWatch argues that no part of The Tree Farm property or Tree Farm 4 is suitable for the
proposed clusteriPUDs considering the risk of wildfire. Paul'' Dewey describes The Tree Farm as
"not a safe place to build and "an inappropriate place for people to live." He states further
development in theWUI is not appropriate because "no development can be made 'safe' in the
face of catastrophic wildfires, '" In support of his position, Mr. Dewey submitted into the record
several letters from LandWatch's fire expert AddisonJohnson, as well as dozens of pages of
articles, studies, and research papers discussing the risks of wildfire in the WUI.
In response, Mr. Condit argues in his December 30, 2014 letter that 'The Tree Farm properties
are zoned for rural development and the applicable criteria have to be construed in, that
context." In his January 6, 2015 final argument, Mr. Condit stated:
'While [the applicant's proposed wildfire plan], will obviously not eliminate all risk
from wildfires, it does not, however, follow that all development should be
prohibited. Deschutes County regulates developments in areas subject to natural
hazards (including wildfires) pursuant to Statewide Land Use Planning Goal 7,
which provides that ?Vocal governments shall adopt comprehensive plans x' * to
reduce risk to people and property from natural hazards.' There is, no
requirement that all risk be elirninated.3'''
Indeed . such risk would be impossible to eliminate ire the Bend' area. 'The greater Bend
area Community Wildfire Protection Plan Boundary, attached as the last page of Exhibit
0 to LandWatch's November 19, 2014, submittal shows that The Tree Farm properties,
the territory within the City of Bend, and most of the surrounding territory are rated bigh'
for wildfire risk, And there are significant areas near the City rated 'extreme' or 'high-
density extreme` for wildfire risk. The fire hazard risk within the City and on most of the
surrounding territories is thus the same or even higher than on she ree Fara;
properties. "
M
r. Condit gt
tat
c E,g., the Tree Farm f €este
Plan, Exhibit "A" to the Tree Farm 4 burden of proof,
Tree Farm 4, 247-14-000 4$ CLJ, 247-14-OOO249-TP
Page 37 of r
'By requesting and obtaining an exception to Goais and 4 to designate The
Tree Farm properties as Rural Residential or Urban Area Reserve in 1988, the
County made the policy decision that these are developable lands. This decision,
was acknowledged to be in compliance with the State Land Use Planning Gods,
including Goal 7. That doesn't mean The Tree Farm doesn't have to comply with
the applicable criteria; See PGE/Gaines cited in the applicant's prior testimony,
lr. Dewey argues that, because the Applicant cannot guarantee absolute
protection from wildfires, no development should be allowed. Such z reading
would swallow the Code."
The Hearings Officer agrees the county made a policy decision that the B.P.-1 Of'VVA zoned lands
west of the Bend UGB are developable. Any change to the uses permitted in the RR -10 and
UAR 10 Zoned west of Bend - e.g., eliminating dwellings due to fire risk -- would require
legislative action by the county, such as a text amendment to Titles 18 and 19, and cannot be
accomplished through individual quasi-judicial land use decisions.
However, The Tree Farm proposal'' includes land divisions providing for multiple dwellings, and
therefore is subject to the subjective and discretionary standards in Title 17 - e,g., contributing
to "orderly development" — and the equally subjective and discretionary conditional use and
cluster/PUID standards in Titles 18 and 19. Section 18 128.010 (A), set forth above, makes dear
the county may deny a conditional use application if it finds the proposal does not satisfy the
applicable' approval criteria. In addition, Section 18.128.020 authorizes the county to impose
conditions of approval in order to assure compliance with the approval' criteria. Nevertheless,
the Hearings Officer finds nothing in Title 18, 19, or 22 that requires the county to impose
conditions in order to make a proposed conditional use approvable. ,Accordingly, I find the
question before me is not whether the residential development should be prohibited on The
Tree Farm or Tree Farm 4 site, Rather, it is whether the site for Tree Farm 4 is suitable for the
proposed cluster/PUD considering the wildfire hazard.
The unusual configuration of Tree Farm 4 restricts placement of dwellings to the higher ground
near the northern property boundary where there are significant views. The applicant proposes
to cluster the dwellings on the high ground, and to address wildfire risk through its wildfire plan
included in the record as Exhibit "J" to the Tree Farm 4 burden of proof. The Hearings Officer
agrees with Mr. Condit that in order to find compliance with this conditional use approval
criterion l need not find the wildfire plan eliminates all fire risk for these dwellings. Rather, I must
determine whether the wildfire plan, in its design and implementation, will reduce that risk to a
sufficient degree that the Tree Farm 4 site and configuration are suitable for the proposed 10 -)rat
cluster/PUD considering the risk of wildfire.
The applicant's wildfire plan consists of a two-page narrative to which are attached nine pages
of information concerning the "Firewise Communities Program" (Firewise) and the "Fire Adapted
Communities Program;" The narrative describes the wildfire plan's goals as:
further reduction of ladder fue
s;
thinning of juniper and small ponderosa trees:
development of a fi
re a
daptive ecosystem to preserve old
growth;
Tree Farm 4, 247 -14 -000248 -CU, 247.14 -€O00249 -T' Page 3
a
maintenance of a healthy tree stand and reduction of the threat o
damag
ed trees; and
enhancement of
su
pport wild
life.
the landscape with native g
asse.
for a natura
beetle
kill and fire
landscape and to,
The wildfire plan identifies the following means to accomplish these goals:
1. wildland fuel treatments completed by the current property owner will continue to be
maintained by the developer and future HOA through a requirement written into the community's
governing documents and guidelines, and will "enhance open space, structure survivability, and
firefighter safety;"
2. The Tree Farm will comply with all applicable criteria in the Deschutes County code relative to
community safety from fire;
3. The Tree Farm will become a nationally recognized Firewise/USA Community viewed as a
model HOA -managed neighborhood that uses \ ildfire mitigation 'principles to manage
combustible vegetation and incorporates structure fire resistant features and materials to reduce
the threat and intensity of wildfire to persona property and the adjacent forest;
4. The Tree Farm will incorporate into its governing documents and architectural and landscape
guidelines the requirement j.tge fire resistant'' building materials and landsga e trt' atr nt to
reduce the threat of wildfire within the boundaries of the neighborhood and to create a fuel
bredk to slow or stop an approaching wildfire to adjacent properties;
5. The Tree Farm developer and HOA will make an annual commitment to
as a Firewise/UA Community;
6. residents and visitors will be familiar withthe county's Wildfire Fire Evacuation Pan. in
addition to The Tree Farm Evacuation Plan; and
nition
7, The Tree Faris governing
prohibit burning of debris and t
documents will address sources of human caused ignitions a
he use of fireworks, (Emphasis added)
n
d
In his written public hearing testimony, Gary Marshall stated the applicant proposes to use the
National Fire Protection Association (NFPA) standards in conjunction with regulations from the
Oregon Fire Code (OFC) and the Oregon State Residential Code to "greatly reduce the risk of
home ignition from wildfire." Attached to this testimony are several NFPA and Firewise
documents, including the 34 -page, NFPA "Standards for Reducing Structure Ignition Hazards
from Wildland Fire." However, Mr. Marshall's testimony does not indicate which of the Flrewise
or NFPA standards would apply to The Tree Farm, or when, how, where, or by whom they
would be implemented. And indicated in the above -underlined language, most of the wildfire
plan's proposed implementation measures are general and aspirational.,
LandWatch questions the effectiveness of the applicant's wildfire plan for two principle reasons,
each of which is, addressed in the findings below.
1. Reliance on Firewise and NFPA Standards. In his November 21, 2104 comments on the
applicant's proposal, Ed Keith noted that to obtain Firewise recognition, The Tree Farm would`
need to obtain a wildfire risk assessment from ODF or the Bend Fire Department. form a board
Tree Far rn 4, 247-14 000 48 -CU, 47-14 00249 -TP P
e cif 117'
or committee to identify priorities, and create and implementan action plan. Mr. Keith stated that
":since communities are dynamic and vegetation grows back" Firewise recognition must be
renewed annually "so the community shows they are continually working on their priority'
issues." For these reasons, LandWatch argues Firewise recognition does not constitute a
meaningful wildfire plan for The Tree Farm,
With respect to NFPA standards, in; his December 11, 2014 submission, Mr. Dewey notes these
standards begin with disclaimers concerning the need for local evaluation of "products, designs,
or installations" and local enforcement. He also notes, and the Hearings Officer agrees. that the
NFPA standards included ' in the record are extensive, technical, and detailed. However,
applicant's wildfire plan does not identify which NFPA standards apply to The Tree Farm,
where, when, how, or by whom the NFPA standards would be implemented". or how and by
whom they would be enforced and their effectiveness evaluated.
Although >Mr.Marshall's written testimony, provided in several letters, does include some
specific reconnrnendations for implementation of the Firewise program and NFPA standards,
these recommendations are not described in the applicant's submitted wildfire plan. Rather, the
plan appears merely to incorporate the Firewise program and NFPA standards by reference,
The Hearings Officer finds that is not sufficient to meet the applicant's burden of demonstrating
compliance with this conditional use approval criterion. I also find it is not my responsibility, nor
that, of planning staff or interested parties, to search through Mr.Marshall's extensive materials
— which he describes as "a plethora of fire safety standards" mm in order to identify relevant
standards and to craft a comprehensive and coherent wildfire plan therefrom. Neither do the
wildfire plan's mere references to Fireise and the NFPA provide a sufficient basis for rrid to
impose clear and objective conditions of approval., I cannot simply condition approval
compliance with the Firewise Community recognition process and the NFPA standards. See,
Sisters Forest Planning Comm. v. Deschutes County, 48 LUBA 78 (2004), 198 Or App 311, 108
P3d 1175 (2005)Y1 Finally, the wi dfire plan's narrative summaries state the developer and the
HOA will undertake certain wildfire plan activities, but they do not clarify if/when the developer
would bow out and the HOA would'' take over.
For the foregoing reasons, the Hearings Officer finds the applicant's wildfire plan is not sufficient
to demonstrate compliance with this conditional use approval criterion because it simply does
not include a meaningful action plan or an explanation of how, when, or by whom the plan' will
be implemented. And it addresses The Tree Farm as a whole although the record indicates
92there is considerable variation in location, topography, and vegetation in The Tree Farm >lots,
However, because the Firewise and NFPA standards are nationally recognized, comprehensive
and, detailed, l believe it is feasible for the applicant to create an adequate wildfire plan based
on those standards that includes the critical information missing from the submitted plan. I'''find
such a plan must include, at a minimum, the following information:
on
identification of each residential lot building envelope, the extent and nature of the
defensible space around each dwelling, and fire fuel treatments on the building envelope
and the rest of the lot;
it setback from the upper edge of the slop ets) for eachbu ilding envelope and d welling;
21 in tha
req u
reco
Tree Far
appeal filed by
impiementation
LandWatch's predecessor, the Court of Appeals held a condition of approval
of the applicant's expert's recommendations was improper where, the
precise, confusing, hypothetical, and/or in conflict with county code provisions
4, 247.14 -000248 -CU, 247-14-000249-T '
Page 40of117
• the fuel treatment,
will occur on open
drainage, and on wi
ny, on any slope below each dwelling, and if such fuel treatment
pace, what impact it will have on that open space, on surface water
di fe habitat for lots in the WA Zone;
whether and where decks and outbuilding
wou
ld
be,'perrr'lifted on each lot;
what specific eonstru€ction € rethods and building material
dwelling to meet specific, identified NFPA standards;
a detailed description of how and by whom the wildfire
monitored, and enforced, with particular;. attention to the tran
and the HOA;
will be required for ea
plan will be implemented,
tion between the developer
a specific, mapped evacuation plan for The Tree Farm and each of the five Tree Farm
developments, including directions for operation of the gate on Sage Steppe Drive, and
a detailed description of when and how residents and guests will be inform ed
wildfire plan requirements and the evacuation plan..
of the
2. hiadequate Recognition of Fire Behavior. The parties disagree as to whether the proposed
design and configuration of Tree Farm 4 adequately' recognize and address wildfire behavior:
For example, Mr. Johnson argues placement of dwellings on the central' ridge and upland areas
above slopes increases wildfire risk because the dwellings would' be both up&lope and
downwind from a wind -driven wildfire starting in the 'public and private forest lands or Shevlin
Park to the west. Mr. Johnson also argues placement'' of dwellings in the shrub steppe
vegetation on the eastern half of The Tree Farm does not reduce the fire risk because fire in
that vegetation can produce flame lengths of 10-12 feet. He claims the previously burned
portion of The Tree Farm, including the eastern part of Tree Farm 4, does not create a fuel
break between the forested western half of The Tree Farm and the urban and urbanizable lands
to the east, as claimed by the applicant, because the Awbrey Hall Fire only changed the type of
fuel, reducing the fire risk from 'extremely intense to merely intense." As discussed elsewhere in
this decision, Mr. Johnson also argues the proposed secondary emergency access road will not
allow timely and efficient evacuation of The Tree Farm in the event of afire and should be in a
different location. Finally, Mr. Johnson questions the adequacy of water available for fire
suppression in light of the uncertainty of The Tree Farm's water supply and pressure.
The applicant responds that The Tree Farm configuration and its wildfire plan adequately
address and minimize the risk of wildfire. The applicant notes that in his comments on The Tree
Farm, Ed Keith stated that he doesn't consider the 10-20 percent slopes on the west side of the
central ridge to be particularly steep, and that many local subdivisions have been developed on
steeper ground. He stated he believes fire risk can be reduced by setting dwellings and decks
well back from the top of the slopes. The applicant also submitted several letters from Mr.
Marshall, discussed in the findings above, identifying measures to be implemented in The Tree
Farm. However, as discussed above, the Hearings Officer has found the applicant's wildfire plan,
does not adequately identify what NFPAslandards are applicable to Tree Farm lots and
dwellings,, how and by whom those standards will be implemented and enforced, and what
would be the relative role of the developer and the HOA in implementing the wildfire plan.
Tre
Farm 4 is o
ne of
most dense vegeta
the two roost weste
on in The Tree Farm. D
the cluste
ellings e€�€
Tree Farm 4, 247 -14 -000248 -CU. 247`-'14--000249-TP
r developments and has some of the
Lots 37, 39 and 40 in Tree Farm 4
Pace 4l of 117
would be located farther west than dwellings In the nearby Highlands at Broken Top PUD. They
also would be farther west than dwellings in the Saddleback Subdivision, just north of Shevlin
Park, which was evacuated during the 2014 Two Bu is Fire, The building envelope for Lot 37
would be ''located at the top of a slope. For these reasons, and in the absence of an adequate
wildfire plan, the Hearings Officer finds applicant has not demonstrated the site and;;%
configuration of Tree Farm 4 sufficiently address predicted wildfire behavior affecting residential
lots and dwellings. I also find it is neither feasible nor appropriate for me to craft conditions in an
effort to make the applicant's proposal approvable.
For the foregoin
g
demonstrate the si
hazards.
reasons, the H
to for Tree Farm 4
earings Officer finds the applicant has failed
is suitable for the proposed use considering nate
to
ral
Natural Resource Values.'The Hearings Officer finds natural resources on the site of Tree
Farm 4 consist of native vegetation including predominantly shrub -steppe vegetation, scattered
rock outcrops, and wildlife habitat including the Turalo winter deer range in the most
southwestern portion of the site within the RR 10 and WA Zones.
a. Vegetation. The majority of the site (78%) will be maintained in permanent open space. As
discussed above, the record indicates the applicant has undertaken regular brush cutting and
tree thinning for purposes of fire fuel reduction and intends that such vegetation management'
will continue within the Tree Farm 4 open space tract. In addition, the applicant proposes that
each lot in Tree Farm 4 will have a designated building envelope in which the dwelling must be
constructed, preserving native vegetation on the residential`'' lots outside the building envelopes
As discussed in the findings below, the applicant's wildlife expert testified that in her opinion,
management of vegetation on Tree Farm 4 for fire fuel reduction can and will be accomplished
in a manner consistent with preservation of wildlife habitat.
b. Rimock and Rock Outcrops. At the outset, the Hearings Officer finds it is not dear any
rock outcrops in Tree Farm 4 qualify as "rimrock," defined in Section 18.04.030 as ,,a ledge or
outcropping of rock that 'forms a face in excess of 45 degrees." In any case, the submitted
tentative plan and burden of proof statement for Tree Farm 4 indicate the applicant does not
intend to remove or alter existing rirnrock or rock outcrops.
c. Wildlife Habitat. The Hearings Officer finds Tree Farm 4 contains what are essentially two
categories of wildlife habitat. The western 88.5 acres are located in t Tumalo winter deer
range and are subject to the WA Zone established to protect it. The remaining 21 acres of Tree
Farm 4 provide wildlife habitat typical of undeveloped land west of Bend, but this habitat is not
designated for special protection. Nevertheless, the applicant proposes to protect this typical
habitat in a manner similar to that required in the WA Zone. Specifically, the ten Tree Farm 4
residential lots would be clustered'' along or near the northern border of the site, all dwellings
would be built within a designated building envelope so as to preserve the rest of the residential
lots in a natural'' state, and no new fences would be established: in addition, the Tree Farm 4
burden of proof states the applicant has removed some wire fencing and intends to remove
rnost of the remaining wire fencing, and intends to eradicate and revegetate most of the existing
network of dirt logging roads. The Hearings Officer find: that with these protective measures,
the portion of Tree Farm 4 outside the ' WA Zone is suitable for Tree Farm 4 considering the
typical wildlife habitat outside the winter deer range.
The tentative pia
winter deer rang
n for Tree Farm 4 shows that all of the 88.5 acres within theA Zone and the
e would be maintained'' in permanent open space with the exce
Tree ee Farm>.4, 247-14-00€024
8 -CU. 247-14-0002 9-T P
ption of 0.8
Page 42 of
acres of right-of-way for a small segment of Golden Mantle Loop. Three Tree Farm 4 residential'
lots --- Lots 37, 39 and 40 — and a portion of the recreation trail system would be located in this
part of Tree Farm 4.. As noted in the findings above under the WA Zone, the stated purpose of
that zone in Section 13.88.010 is to, "conserve important wildlife areas" vvhile permitting,,
":development compatible with the protection of the wildlife resource_" Therefore, the Hearings
Officer finds the protective measures established in the WA Zone are intended to accomplish
those dual purposes,
As discussed in the WA Zone findings above, the Hearings Officer has found Tree, Farm 4 will
satisfy all applicable WA Zone criteria. Nevertheless, in its August 19 and December 11, 2014
comments on the applicant's proposal, ODFW argued The Tree Farm will' not protect the
Tumalo winter deer range for the following reasons
development of residences in the winter deer range will convert native forest arid
upland habitats into built structures, including roads, resulting hi permanent loss of
habitat;
ho
ners
ill be allowed to rem
deer migration corrid
sive habitat o
n th
ors will be blocked by dwellings:
eir>.hor eites;,'
trails and open space will promote low impact recreational use — e.g., bicycling,
walking, and wildlife viewing - that v>#iil interfere with deer use of winter range if they
are not sufficiently dispersed in the Tree Farm; and
the applicant has n
habitat pursuant to 0
ot
identified mitigation measures demonstrating "no net loss" sof
DFW's administrative rules.`
The Hearings Officer finds ODF V's habitat mitigation policy, which includes the no net loss"
standard, does not establish' approval criteria for quasi-judicial land use decisions ranless they
involve local government land use regulations that require ''habitat mitigation, or proposed ,plan
amendments or zone changes relating to habitat protection. OAR 635-415-0015 and OAR 635-
415-0020.
35-41h-0020.1 find neither exception applies here. 1 also find ODP 's concerns >sabout>. low -impact
recreational use on trails are of greater relevance to Tree Farms 4 and 5 than they are to Tree
Farms 1, 2 and 3 because all of Tree Farm 5 and most of Tree Farm 4 are located in the winter
deer range. Consequently,'''1 find the relevant wildlife issues include development of dwellings,
roads, and trails, and the vegetation removal required for those features and for fire fuel
reduction
La
en
ndWatch submitted an article from the USPS Pacific No fest Research Station (PIPS)
titled "Science Findings" generally addressing the potentia impact of residential development
eer winter range and migration corridors. The article reviews the work of Jeff Kline, a
orester with PN' RS, on general deer migration patterns in Deschutes County, and in
particular on anticipated effects on deer migration from potential future development of the
Cascade Timberlands property west of The Tree Farm. The article concludes by listing "'land
rrsanagerent im€pli ations" for such development, including reco€nrrsendations that resource
managers work with landowners to consider protective measure; such as conservation
easements to protect winter deer range and migration corridors,
on mule d
research t
2.?
ODFW also raised concerns about a proposed pond in The Tree Farm. H
October 10, 2014, Dr. Wente stated the pond has been removed from The Tree Farm
in
propo
ted''
Tree Farm 4. 24i;-14-00€ 249 -CU, 247; -14 -009249 -TP Page 43 of 117
The Hearings Officer finds the applicant's proposal addresses the specific winter range qualities
on The Tree Farm property including specific migration corridors, and identifies protective,
measures similar to conservation easements for both the vvinter range and migration corridors.
The WMP, dated May 19, 2014, and attached to the Tree Farm 4 burden of proof as Exhibit "l,"
wa prepared by Dr. Wendy Wente, an ecologist and biologist with Mason, Bruce and Girard
Natural Resource Consultants (MB&G). The WMP includes an overview of The Tree Farm
property, Dr. Wente's methods for investigation and identification of existing wildlife habitat and
use, her assessment of the wildlife uses thereon based on her investigation, a number of
specific mitigation and conservation measures, and her opinion regarding wildlife habitat on the
portion of The Tree Farm zoned WA, including residential lots and open space tracts.
At page 8'' of the VVMP, Dr. iVente''id
The Tree Farm in relevant part as fol
entified s`g
ows.
'Mule Deer Habitat and Migration Co
eneral wildlife c
rridor.,
tilization trends" for mule d
Deschutes County has designated the Tree Farm West property+,, [the part of The
Tree Farm located in the WA Zone] within the PSA (The Tree Farm] (Figure 1) as
a mule deer winterrange (WA' Zone), and deer are also known to migrate
through the area Throughout the field investigation, the MB&G biologist''
observed signs of diffuse migration through the respective ,,understories of
Ponderosa Pine Forests West and East. Wildlife species, especially ungulates,
frequently use, the PSA in its entirety as evidenced by the presence of deer signs
at sample plots and other areas throughout the property These forested habitats
provided minimal evidence of bedding, but they showed signs of significant
wildlife use as foraging and corridor habitat. Numerous signs of up-gradiant and
down -radiant trails/tracks suggest that forested areas within and throughout the
PSA serve as diffuse corridors for traveling to resources 'located outside of the
PSA and for accessing forage and possibly water resources. Key areas identified
as travel corridors for deer included the dry draw and parallel minor ridges
running northeast to southwest between plots I-18 and H9 (Figure 2), This corridor
extends northward along the property boundary where it parallels Tumalo Creek.
Deer are also likely using corridors where they would experience lower gradients,
such as along the existing mad to the south of plot H7, to move between the
Tumalo >>Creek riparian corridor and upland areas to the east (outside of the WA
Zone) that provide bunch sass and antelope bitterbrush forage. Therefore, the
MB&G biologist was able to corroborate the WA Zone designation within the PSA
relative to mule deer habitat and use."
eer on
Based on the figures and photographs in the WMP, the Hearings ,Officer understands Dr. Werste
to conclude mule deer habitat use and travel corridors are sufficiently diffuse on The Tree Farm
property that deer currently move across rhe Tree Fara
Dr. Wente also submitted a letter dated
relevant part as fellows:
October 10, 2014 responding to 0
DF 's
oncerns €r
"ODFW commented that the deer migration corridors `could' be corrrpletolyr
eradicated or substantially cut-off [sic}, forcing deer to move through the
development * * ".' The Tree Parra RR -1O parcel, which is overlain by the deer
winter range WA zone, is approximately 393 acres in size. The development plan
Tree Ferrer 4, 247-14-00024
-CU. 247-114-00
249 -TP
Page 44 of 117
proposes approximately 30 acres of lots and road right-of-way (combined) within
the RR -1O parcel. This maintains the remaining approximately 363 acres (92%)
as designated open space. The DCC 18.88.050(D)(2) requires the retention of
80% of an RR -10 zoned area with a WA Zone' as open space, thus this
development far exceeds the proportion of open space required by the code for a
cluster development within a WA Zone. in addition to providing more open space
than required by the code for deer winter range on RR p, the development team
selected a design configuration that would maintain wildlife corridors throughout
the open space. The plan' provides an extensive corridor along the western
boundary, preserving an area where deer would be expected to continue utilizing"
the Tum to Creek drainage. The two pods of the cluster development that fall
within (TF5) or partially within (TF4) the RR -10 zone are also configured to
provide an additional north/south corridor following the natural lay of the land,
Finally, the configuration of the development plan supports east/west deer
movement patterns along the southern portion of the -10 zone. This area
is clearly maintained as a corridor of habitat between the road [Skyiiners
Road] and the southernmost cluster [in Tree Farms 3 and 9. These
corridors, and the open space in general, will continue to provide space for
deer to move across and to utilize the wildlife habitat provided by the WA
zone on the _10," (Bold' emphasis added.)
The Hearings Officer understands the, above -emphasized language, to mean Dr, Wente
concluded the proposed roads and trails, open space tract, and dwellings in Tree Farm 4 would
not create a barrier to deer movement or habitat use in that area. Each of these developfn
features is discussed in the findings below,
ent
(1) Roads and Trails,, As discussed in the findings above, there are a number of existing dirt
roads on The Tree Farm site. The record indicates these roads and dirt trails in The Tree Farm
have been, arid continue to be, used by members of the public. The applicants WMP states
with respect to roads and trails in Tree Farm 4:
"Where proposed access roads intersect the planned [north -south] corridor, there
will be reduced speed signs and signage indicating wildlife' crossings."
Considering historic human use of these roads and trails. the relatively low volume of traffic
predicted for The Tree Farm Drive in general at buildout,- 476 ADTs m and the very low traffic
volume on the segment of Golden Mantle Drive providing access to residential' lots in Tree Farm
4, the Hearings Officer finds that with these measures, the presence of roads and trails within
Tree Farm 4 will not interfere with use of winter deer range in general or in particular
migration corridors the PUD roads and trails will cross.
(2), Open Space Tract. At the public hearing, the Hearings Officer questioned whether ongoing,,
fire fuel management in The Tree Farrn and the open space tracts can be undertaken consistent
with the consersration of the Turnalo winter deer range. In response, the applicant submitted a
letter dated December 5, 2014 from Dr. Wente stating the ' MP and the applicant's fire plan
'are designed to provi i a coordinated solution to serve two goats that can in some oases be in
conflict: maintaining the quality of wildlife habitat while also reducing the risk of wildfire." Dr.
Wente noted that the fuel reduction treatments proposed for The Tree Farm's open space tracts
are a continuation of the treatments already practiced on The Tree Farm property. Dr. ''' ente
stated that in her opinion the proposed fuel' reduction treatments would not interfere with
conservation of the winter deer range for three reasons: (1) The Tree Farm open space
with
Tree Farm >.4, 247-14--000248-CU, 247-14-0 249 -TP Page 45 of 117
provides good winter deer range habitat in spite of historic and ongoing fuel reduction
treatments thereon; (2) the fuels management techniques will simulate the effects of small-scale
wildlife which is an important component of a healthy ponderosa pine ecosystem; and (3)
regular brush cutting and removal of Juniper trees encourages the, growth of forbs that make up
h of the winter forage for deer.
Dr. dente's opinion would support a finding that the applicant's proposed fire fuels management
will be consistent with conservation of the Tumalo winter deer range in Tree Farm 4. However,
as discussed in the findings above, the Hearings Officer has found the record, including the
applicant's wildfire plan evidence, suggests that in order to adequately address predicted
wildfire behavior it may be necessary to remove significant vegetation downslope from
dwellings, including from the adjacent open space tract(s). It is not clear that Dr. Wente
considered removal of vegetation beyond historic fire fuel''' treatments in forming her opinion
about impacts on the winter deer range. Moreover, as discussed above, i have found ` the
applicant's wildfire plan is inadequate because, among other deficiencies, it does not specify,
what fuel treatments vwill be required to reduce the fire risk for dwellings on each Tree Farm lot.
3) Dwellings. The Hearings Officer finds the configuration of Tree Farm 4, with its clustering of
dwellings as required in the WA Zone, preserves large swaths of open space as well as leaving
the existing migration corridors intact. The WMP states in relevant' part;
"The ct.rrrently,proposed lot configuration also allows for a north/south deer and
other wildlife movement corridor within the residential deveiopnent, providing
connectivity along the eastern edge of Tree Farm West, the portion of the
property within the WA Zone. This wildlife corridor is located between lots 43 [in,
Tree Farm 5]and 37 [in Tree Farm 4] on its northern terminus as depicted in the
conceptual site plan (Appendix A). * *' * The corridor is designed to provide at
least a '100 -meter -wide passage between structures and should be sufficient for
mule deer given the minor topographic relief and habitat type (Sperger 2006);
The corridor is also sited to take advantage of natural break in the topography at
its northern outlet. Deer likely already use this break in the northwestern ridge to
access the flatter portions of the property to the east, and the development
corridor f ,rill allow them to continue this movement pattern."
The proposed Tree Farm 4 configuration with three residential lots the winter range will intensify
human activity over more recent human use in this habitat consisting of low -intensity recreation,
tree and brush thinning, and historical logging. In contrast to these mostly seasonal activities,
dwellings would create year-round human activity.Opponents question whether developing
Tree Farm 4 at the proposed density will create too great an impact on the winter range
compared with lower density development, or no development at all. The applicant's WMP"does
not address this issue, which I find may well be relevant in the context of this very general`
"suitability" approval criterion;
The WMP includes at pages 9-12 a nur-nber of habitat mitigation and conservation measures,
These address factors including dwelling siting and fencing consistent with the WA Zone
requirement;a discussed above, not allowing uses prohibited by i itle 18, and several specific
measures addressing vegetation monitoring, removal of non-native species and juniper,
preserving ponderosa pine trees and downed logs. and keeping dogs on leash. However, the
Hearings Officer finds the VVMP suffers from the same lack of detail and clarity as does the
wildfire plan as to how, when, where, and by whom these measures will be undertaken, how
Tree Farm 4, 247-14 000248 -CU, 247-14-00024TP < Page 46 of 117
their success wi'
states simply th
be measured, and how and by whoa they will be enforced. Rather, the Wl s'lP'
comply." For example, the WMP states:
at certain things "will be done" or "wi
'During development, the developer will be responsible for managing the open
space that encompasses Me wildlife management area. Upon completion,
management of the open space will ultimately be transferred to either a home
owner's association or a non-profit or other public entity.
The VVMP does not explain the meaning of the terms 'development" and "'completion" in this
context. They could signify that once all, Tree Farm infrastructure has been completed by The
Tree Farm LLC, management of The Tree Farm open space and habitat shifts to the HOA,
which at that point might only exist on paper.
As is the case with the applicant's wildfire plan, the Hearings Officer finds that to be effective,
the VVMP' must include more detail, such as an action plan that identifies specific measures
addressing each residential lot in the WA Zone, as well as roles, responsibilities, and timing of
measures to implement the action plan. And as with the wildfire plan, l find it is neither feasible
nor appropriate for me to craft conditions of approval in an effort to make the applicant's
proposal approvable.
,,
For the foregoing reasons, the Hearings Officer finds the applicant has failed to
demonstrate the site for Tree Farm 4 is suitable for the proposed use considering natural
resource values.
Fl
ND
l
GS:
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)
Existing and Projected Uses. Existing and
discussed in the findings below
projected uses on surroun
d
g
perties are
1, East: To the east of Tree Farms 1, 2 and 3 is vacant land zoned UAR-1O and owned by Miller
Tree Farm. The Hearings Officer finds that in the short term this property could be developed
with ten -acre residential lots or with smaller' lots through PUD approval. In the longer term,
because this property is included in the urban area reserve, it may be brought into the Bend
llGB and developed with urban -density residential uses. Farther to the east within the Bend
UGB and city limits are three public schools and Northwest Crossing, a mixed-use developrnent
including urban -density residential, commercial<, and light industrial development. The Hearings
Officer finds these uses will continue in the future. The applicant's burden of proof states,; and
agree, that the design of The Tree Farm. with its clustering of dwellings and large swaths of
open space, will be compatible with surrounding lands to the east by placing the dwellings
closest to the UGB ' and by serving as a permanent transition between the urban and
urban€zable lands to the east and Shevlin Park and forest lands the west.
2. West, immediately to the nest is Shevlin Park, a $52a2:€e regional park owned end managed
by the park district and which includes developed amenities, large areas of open space, and an
extensive trail system. To the southwest is the portion of the DNF planned and managed for
scenic views and recreation, including the "Phil's 'Trail"' mountain biking trail network. The
Hearings Officer finds it is reasonable to assume these uses will continue in the future. Farther
to the west and northwest are private forest lands including the approximately 33 000 -acre
Tree Farm 4, 247-14-00 248 -CU, 247' -14 -000249 -TP
Page 47 of 117
Cascade Timberlands property and several smaller parcels,,, Evidence in the record concerning
current uses on these lands i scant, so have found it appropriate for purposes of the suitability
analysis to assume existing uses 'include those permitted outright in the F-1 Zone, including
some Umber harvest, However, l am aware long-term plans for the Cascade Timberlands`
I oldings have included a mix of timber production, protection of scenic views, and recreation,
The Hearings Officer has found Tree Farm 4 will not cause a significant change
significantly increase the cost of, accepted forest practices on nearby lands devoted to forest
use. However, as discussed in the findings above, l have found the applicant failed to
demonstrate the site for Tree Farm 4 is suitable for the proposed cluster/PUD considering
natural hazards and natural resource values due to deficiencies in the wildlife plan and wildfire
plan. The question, then, is whether those suitability findings mean Tree Farm 4 will be
incompatible with current and projected uses on public and private forest landsto the west and
southwest. 1 find the primary concerns about incompatibility are the risk of a fire spreading into
and from The Tree Farm, and the lack of an adequate wildfire plan and implementation of that
plan making that risk, higher, 1 believe it is feasible for the applicant to develop an adequate
wildfire plan, but unless and until the applicant does so, 1 find Tree Farm 4 is not compatible with
existing and proposed uses on Shevlin Park and nearby forest lands.
3. South., To the south across Skyliners Road is The Highlands at Broken Top PUD zoned
UAR-1O and including ' 7 ten -acre residential lots and open space Farther to the south is the
Tetherow destination resort including residential lots, open space, a golf course and clubhouse.
The Hearings Officer finds these uses will continue in the future, although because it is zoned
UAR-10, The Highlands at Broken Top has the potential to be brought into the Bend UGB and
redeveloped at urban density 1 find Tree Farm 4 will be compatible with surrounding lands to
the south because they are developed with uses similar to what is proposed for The Tree Farm
i.e., rural residential subdivisions.
n
3. North. To the north are large vacant parcels zoned UAR-10, one of which is 376 acres in size
and owned by Rio Lobo. The Hearings Officer finds that in the short term these lands could be
developed with ten -acre lots or with smaller lots through >.PUD approval. In the longer terra,
because these lands are included" €n the urban area reserve, they may eventually be brought
into the Bend UGB and developed' at urban density.
Rio Lobo argues The Tree Farm and Tree Farm 4 are not compatible with future development of
its property for two reasonsFirst, in his letter dated December 11, 2014, Rio Lobo's attorney
Myles Conway stated the applicant's proposal to create a private road system in The Tree
Farm, and to stub off Sage Steppe, Drive in Tree Farm 1 at the boundary of Rio Lobo's property,
will not be sufficient to support additional through traffic generated by future development of Rio
Lobo's land, As discussed in the findings above addressing the adequacy of transportation
access, Rio Lobo's traffic engineer predicted that buildout of Rio Lobo's 376 acre property at
urban density would include 1,100 dwellings units generating over 9,000 ADTs, Mr. Conway
argues Section 17.36.020(B) requires the applicant to dedicate and construct a public road from
The Tree Farm's shared boundary with Rio Lobo's property to Skyliners''"Road to facilitate future
development of Rio Lobo's property. As discussed in the Hearings Officer's decision in Tree
I
arm 1 and in the subdivision and PUD fir ctin below. 1 have found the applicant is permitted
to develop The Tree Farm with private roads. In addition, 1''"have found Section 17.36.020(B) of
the subdivision ordinance does not require the applicant to dedicate or construct a public road
between the Rio Lobo property and Sky{hirers Road because none is necessary to
Tree Farm 4, 247 -`14.000248 -CU, 247 -14 -000249 -TP
Page 48 of '117
accommodate present and future through traffic generated by The Tree Far ,rn a
development of Rio Lobo's property with its current UAR-10 zoning, 23
ndlor
Second, Mr. Conway argues The Tree Farm, is not, compatible with projected uses on Rio
Lobo's property because the majority of Tree Farm dwellings are proposed to be clustered
along or near Rio Lobo's southern boundary, and the applicant proposes only one street
connection between the properties, the future extension of Sage Steppe Drive. in his January 6,
2015 submission, Mr. Conway asserts this configure ion will "adversely affect future
development of the Rio Lobo property" and these proposed Tree Farm homesites "should be
subjected to additional, setbacks from applicant's northern property boundary to compliance with
the compatibility provisions," Mr. Conway argues Tree Farms 1 through 4 must be reconfigured
to provide a future road connection at least every 400 feet along the Rio Lobo property
boundary, relying on Section 17.36.140(8)(3)(c). However, as discussed in the findings below,
the Hearings Officer has found Section 17, 6.140(B)(3)(c) of the subdivision ordinance is not
applicable' to Tree Farm 4, and therefore the applicant is not required to provide more than one
future road connection along, the northern boundary of The Tree Farm
Rio Lobo's property and the vacant Miller Tree Farm property east of Tree Farm 1 are zoned
UARn10 and abut the Bend UGB. Consequently, the Hearings >>Officer finds the nature and
timing of development > on these two properties likely will depend on whether and when they are
brought into the UGB and when Skyline Ranch Road, a designated collector, is dedicated and
developed north of its current terminus near Skyliners Road. Annexation of these properties into
the UGB could allow the urban -density development contemplated in Rio Lobo's traffic study.
However, I find that as long as the properties remain in the urban area reserve, development'
willl be at much lower density. The applicant's burden of proof states The Tree Farm was
conceived as a permanent transition area between urban and urbanizable land to the east and
Shevlin Park and large areas of forest to the west, That transition is created by clustering most
of the dwellings in the UAR-10 zoned portion of The Tree Farm, including seven of the dwellings
in Tree Farm 4 and placing most of the open space on the RR-10NVA zoned property near
Shevlin Park and forest lands. For these reasons, I find that regardless of the ultimate'
development density on the Rio Lobo and iVIiller Tree Farm properties, the transition area
created by The Tree Farm chaster/PUDs will be compatible with their development
LandWatch argues the applicant mischaracterizes The Tree Farm as a "transition area"
because 'there are no urban uses for a substantial distance to the east," and therefore the
applicant's proposal represents "an isolated pocket subdivision that doesn't provide a transition
to anything." The Hearings Officer disagrees. The properties east and north of The Tree Farr
are zoned UAR-10 and are planned and zoned for eventual inclusion in the Fend UGB. That
these properties are undeveloped does not change the fact that they are urbanizable lands > and
ultimately may be developed at much higher density than The Tree Fara. Accordingly, I find the
characterization of proposed The Tree Farm as a "transition area' is accurate,
lr? 1 -t>er dated €D c.ernber. �, x,014 Cryariey rer reser}hg M}Her Tide i-ann LLC „Aaatilat W cul t
tae wvilling'to commit to the dedication of public road right--of-way in a mutually agreed upon on
across the adjacent Miller Tree Farm property in the event Rio Lobo obtains county land use approval for
either a destination resort or a 37 -lot subdivision or PUD on its adjacent property. That dedication would
be to allow Rio Lobo to construct the segment of Skyline Ranch Road from the Rio Lobo property across
the Miller Tree Farm property to the recently constructed NorthWest Crossing, Drive/Skyline Ranch road
intersection adjacent to the new Pacific Crest Middle School.
Tree Fara 4, 247414--000248-CU, 247 -14 -00024, -TP Page 49 of 31',
For the foregoing reasons, the Hearings Officer finds Tree Farm 4 will be compatible with,
existing and projected uses on surrounding lands to the north, east and south, but will not be
compatible with Shevlin Park and forest lands to the west because of deficiencies in the
applicant's wildfire plan and WMP.
C. These standards and any other standards of DCC 18.128 may
be met by the imposition of Gond`€tions calculated' to inure
that the standard will be mete
FINDINGS: As discussed throughout this decision, the Hearings Officer has recommended that
f the applicant's proposal is approved on appeal; such approval should be subject to conditions
of approval designed to assure compliance with applicable standards and criteria:
1. Section 18 128.040
Specific Use Standards
A conditional use shall comply with the standa
which it is located and with the standards and co
DCC 10.128.045 through DCC 18 128.370.
res of
d`€tion
FINDINGS: Compliance with the specific use standards for cluster d vela
18 128.200 is addressed in the findings immediately below.
Sectio. 18.1 .200, Cluster Levet,
Uses Only)
A. Such
con
pment (Single
uses may'be authorized as >a cond
sideration of the foilowing factors:
he zone
set forth
n
n
p€ents in Section
Family Reid
nti
al`
itional use only after
FIND NGS: The Hearings Officer finds the language of this paragraph means the factors
discussed in the findings below do not establish specific approval standards for Tree Farm 4,
but rather identify issues I must consider.
1+ Need for residential uses
proposed development.
in the
rmr
late area oaf the
FIND The applicant addressed this factor by submitting as Exhibit "k" to its burden of
proof reports identifying the homes, lots and land currently for sale, pending 'sales, and actual
saps during the past 12 months in developments in close proximity to The Tree Farm. These
developments include' Northwest' Crossing, Shevlin Commons, The Highlands at Broken;;, Top,
Tetherow, and Shevlin Meadows. The report also includes a copy of the June 12, 2014 "Bratton
Report," a monthly compilation of data on residential sales complied by the Bratton Appraisal''
Group. The staff report summarizes the reports in Exhibit "K" as follows
'Out of a total`>of 131 listings, 81 lots have sold In the past year and nine sales
are pending. This translates to 7.5 sales per month. As of the time of the reports,
the applicant indicates a standing inventory of 41 properties on the market, or
list unddi 5 74 months inventory. The a )icanl notes that since \lathoty 2014,
the number of sales and pending sales has increased to an average of nearly ten
per month. Assuming current activity levels, the applicant concludes there is just
over a 4`>month supply of inventory on the rr arket;'
Tree Farrr 4, 247;..14-00024 - 'U!, 247-14-O 249TTP Page 50 of 117
Out of a total of 178 single-family hot listings priced up to ,000,00€ , 116
homes have sold in the past year, and 29 are pending, absorbing inventory at just'
over 12 sales per month. Standing inventory includes 33 homes on the market --
a dozen of which are either ander construction or to -be -built providing fewer
than three months of single-farnily homes on the market."
Opponents Connie Peterson and Christine Herrick argue the applicant should have identified
and addressed the need for affordable housing. The Hearings Officer understands these
concerns. However, 1 find use of the broad term "'residential uses" in this factor does not specify,
or require analysis of any particular types of housing;
For the foregoing reasons, the Hearings Officer finds the applicant has demonstrated there is a
need for residential uses in the immediate area of The Tree Farm, and the proposed dwellings
in Tree Farm 4 will address that need;
Fl
N
Di
NGS:
Environmental, social
and economic impacts likely to
lncludig impacts on
s and roads.
result from the development,
public faciilities such as school
Emaronmentai>t pactsTree Farm 4 is configured so that, seven of the ten proposed dwellings
are clustered on relatively level land in the north -central part of The Tree Farm in the UAR-1 i
Zone. The WA -zoned part of Tree Farm 4 would have the remaining three residential lots, most
of the open space tract, a segment of Golden Mantle Loop, and a segment of the
recreationalimountain bike trailThe applicant proposes to establish building envelopes on each
residential lot in which dwellings must be constructed, Remaining land on the residential lots
and the open space tract world be maintained in its natural state except for periodic removal of
juniper trees and brush cutting required for fire fuel reduction. As discussed in the findings
above, the Hearings Officer has found Tree Farm 4 will not interfere, and wi'lI be compatible,
with accepted forest practices on nearby public and private forest lands. l have also found that
without an adequate wildfire plan the applicant has not demonstrated The Tree Farm and Tree
Farm 4 will be compatible with current and projected uses on Shevlin Park and nearby forest
lands to the west.
!n his December 11, 2014 fetter, Paul Dewey argues the Hearings Officer should not consider
environmental impacts based on a comparison of the impacts of clustering vs. development of
The Tree Farm property with the five dwellings' that would be permitted under its current zoning,
or with alternate development patterns such as a traditional subdivision with 1 0 -acre lots and
dwellings spread throughout the 533 -acre property. His letter goes on to state:
"There are apparently only five >lots, so the current alternative would be five
houses. Though the zoning allows a house on a 10 -acre parcel, there is no_ basis
to coracirade that 50 10 --acre lots can be created here." (Underscored emphasis
added.),
The Hearings Officer disagrees. There are reasons to find a traditional subdivision with ten 1 0-
acre lots could' be approved on each of the five Tree Farm legal lots. First, a si€hilar
development The Highlands at Broken Top -- was approved immediately south of The Tree
Tree Far4,247-14-000248-CU, 247.14 -000249 -TP
Page 51
117
Farm. Although this subdivision technically is a PUD,24 it was approved with 37 mostly ten -acre
lots on land zoned UAR-10 and adjacent to a large open space area abutting the DNF. Second,,
traditional subdivisions do not require conditional use approval in the RR 10 and UA' -10,
Zones. They are subject to the 10 -acre minimum lot size in those zones, and to the subdivision
standards in Title 17. As discussed in the findings below concerning compliance with Title 17,
the vast majority of those standards are clear and objective design standards. The exceptions
are the subjective and discretionary standards in Section 17.16 100 that require the developer
to demonstrate the subdivision would establish orderly development and land use patterns in;,
the area, provide for the preservation of natural features and resources, and not create
excessive demand on public facilities and services, and utilities. I find it is ,possible for the
applicant to satisfy those standards with conditions of approval and with the above-described''
revisions to its wildfire' plan and WMP. Accordingly, 1 find there is nothing improper in comparing
the propose cluster/PUDs to the alternative of a traditional subdivision when weighing the
environmental impacts of The Tree Farm ;.and Tree Farrn 4.
LandWatch also argues the applicant has failed to demonstrate' The Tree Farm will not have
negative environmental impacts on Tumalo Creek. Again, the Hearings Officer disagreesI find
potential impacts on Tunnalo Creek would be limited to erosion and runoff from the west side of
the central ridge into the creek, and 1 find the applicant's drainage plan, discussed in detail
elsewhere in this decision, demonstrates runoff will be contained on site.
Because the Hearings Officer has found the applicant failed to demonstrate the site for Tree
Farm 4 is suitable for the proposed cluster!PUD considering wildlife habitat and wildfire risk, I
also find the applicant failed to demonstrate Tree Farm 4 adequately considers and addresses
this cluster development factor.
Social Imp cts. The Hearings Officer has found the applicant demonstrated a need for
additional residential uses on the west side of Bend that The Tree Farm will address. Tree Farm
4 will cluster ten residential' dots and dwellings in the north central part of The Tree Farm, with,
seven lots located in the UAR-10 Zone and three lots located in the WA Zone. All of the lots
would have access to Skyli€vers Road and thereby to the three public schools and commercial'
and light -industrial uses in NorthWest Crossing, and possible future urban -density development
on the adjacent Rio Lobo and Miller Tree Farm properties. The configuration will place
approximately 98 percent of the Tree Farm 4 open space in the RR -10 and WA -Zones closest'
to Shevlin Park and the public and private forest lands to the west. As discussed above, I have
found the proposed configuration of Tree Farm 4 will provide a transition between the Bend
urban area and the vast forested land to the west. 1 find the proximity of Tree Farm 4 to Shevlin
Park and to the extensive "Phil's Trail" mountain biking trail network in the DNF will facilitate use
of these resources by Tree Farm residents.
LandWatch argues The Tree Farm will have negative social impacts on Shevlin Park. The
Hearings Officer finds this argument ignores the record. The park district submitted several
comments in support of The Tree Farm. The only concerns the park district expressed were the
need to refine the proposed trail alignments between The Tree Farm and Shevlin Park, and the
need to provide for off—street parking for trail access. In his December 11, 2014 corner rents,
Steve Jorgensen, the park district's Park and Trail Planner, stated that increasing public access
tri the south portion of Sheviin Park 'is a positive development' th t will rel3>eve sortie Of the
24 The Cascade Highlands decision, included in the record as an attachment to Anthony Ragu ne`s
November 17, 2014 memorandum, states 'the 37 lots are all about 1C€ acres in size (with the exception of
proposed Lot 22 that will be 18.05 acres)," and ''the rerrsaining acreage [approximately 20 acres; " * will
he platted as a separate lot" and designated 'not a part" of the subdivision.
Tree Farren 4, 247-14-00€248-C>U, 241 -14 -000249 -Tp
Page 52 of 117
current and future demands on the limited parking
will serve to discourage transient camps on the SOL
areas at, the north end of
hern portion of the park.
Shevlin Park an
Mr. Jorgensen recommended several measures to facilitate trail access and off-street parking.
These would occur on the adjacent Miller Tree Farm property. Specifically;,, Mr. Jorgensen
recommended the applicant dedicate a 2O' -wide "re -locatable 'floating' public trail easement" to
the park district that abuts and runs parallel to the Sky{liners Road right-of-way between Crosby
Drive and the proposed intersection between Tree Farm Drive and Skyliners Road. He also
recommended the applicant improve a new mountain''' bike trail within that easement in order to
provide a connection between the existing West Bend Trail'' along Skylir e€ -s Road that,
terminates on the east side of Crosby Drive and the proposed trail system in The Tree Farrn,
The, Hearings Officer finds that because it appears from the tentative plan for Tree Farm 1 that
this easement and the recommended improvements thereto would be located entirely within the
adjacent Miller Tree Farm property, ! lack authority to require the easement and improvements
as a condition of approval for Tree Farm 4.
Economic facts. The applicant argues, and the clearings Officer agrees, that The Tree
Farm's clustered development pattern is the most cost-efficient manner in which to develop a
large rural tract, and much more efficient than providing public facilities and services to widely
dispersed ten -acre lots. For example, clustering of dwellings requires shorter extensions of
streets and utilities required to serve residential lots In addition, ! find that if the applicant is able
to secure domestic water through connection to the City of Bend water system or the Avion
Water Company there will be no need for individual on-site wells.25
Puu !ic Facilities. Comments on the applicant's proposal from Peter Russell and George Kolb
indicate no improvements to existing streets or intersections are necessary. No comments on
road improvements were received from the city's public works department. As discussed in the
findings above concerning i. the adequacy of transportation access to The Tree Farm, the
Hearings Officer has found the development' will not create an undue burden on affected
transportation facilities. Finally, as discussed in the findings below, incorporated by reference
herein, the Hearings Officer has found that providing domestic water to The Tree Farm and Tree
Farm 4 will not place an undue burden on city water facilities.
Schools. The UAR 1O zoned portion of Tree Farm 4, and Lots 30-36 and 38, are located within
the boundaries of the Bend -La Pine School District.26 As discussed above, three of the district's
schools -- Miller Elementary, Suit High School, and the new Pacific Crest Middle School
under construction — are located within a mile of Tree Farm 4. The record indicates neither the
Bend-L.aPine or Redmond school districts were asked to comment on The Tree Farm proposal:
However, the Hearings Officer is aware the school district responds to growth in student
populations by expanding school capacity and/or adjusting school boundaries, and typically
requests that private subdivision streets be subject to public access easements to facilitate
25 The applicant argues The Tree Farm also' viii provide economic benefits by having the HOA own and
maintain PUD roads, thereby relieving the county of such maintenance expenses. However, in his
:: i'{r":3enti on theapplicants proposal George Kolb noted that the county no ionger is accepting 0,1ads
into its road maintenance network.
26 The record indicates' the RR -13 zoned portion of the Tree Farm is 'located` in the Redrnond School
District. The applicant's burden of proof states the applicant will request that the Bend and Redmond
school districts allow the thirteen Tree Farm homesites in the Redmond School District to be trans erred
to the Bend -La Pine Scnool District.
Tree Farm 4, 247 -14 -000243 -CU, 247 -14 -000249 -TP
Page d3 of 117
school bus travel thereon. As discussed above, the applicant proposes to dedicate public
access easements over all private Tree Farm roads,
For the foregoing reasons, the Hearings Officer finds Tree Farm 4 will have positive socia and
economic impacts, but in the absence of an adequate wildfire plan and WMP, the applicant, has
not demonstrated Tree Farm 4 will have entirely positive environmental impacts.
3. Effect of the development on the rural character of>the
a
r••ea.
FINDINGS: Tree Farm 4 is located in a rural area west of the Bend UGB that is characterized
by: (a) large vacant parcels zoned UA -1 O to the east and north; (b) large UARw1 g zoned,
parcels to the south across Skyliners Road with low-density residential development (The
Highlands at Broken Top) and a destination resort (Tetherow); (c, Shevlin Park; and (d) tens of
thousands of acres of public and private forest lands to the west. The Hearings Officer has
found The Tree Farm will provide a transition between the urban and urbanzable lands to the
east and the vast resource lands to the west. The overall density of development in The Tree
Farm will be the same as in The Highlands at Broken Top. The proposed configuration of The
Tree Farm will cluster the majority, of dwellings in the UAR-1 g Zone and will locate the majority
of open space in the RR 10 and WA Zones. For these reasons, I find Tree Farm 4 will be
consistent with the rural character of the area,
4. Effect of the development on agricultural, fores
wildlife or other natural resource uses in the area.
try,
FINDINGS: The record indicates there are no agricultural use in the area. As discussed in the
findings above, incorporated by reference herein, the Hearings Officer has found Tree Farm 4
willl not force a significant change in, or significantly increase the cost of, accepted forest
practices on nearby land devoted to forest use, and will be compatible with such uses. With the
exception of vegetation management for fire fuel red rction,,,the applicant proposes tri retain€ all
existing vegetation on The Tree Farm open space tracts as well as on the portions of the two -
acre residential lots outside the designated building envelopes. The applicant proposes to site
dwellings on relatively level' ground, thus, minimizing the need for significant excavation and fill,
and to site the private roads to minimize steep slopes and road cuts. Finally, as also discussed
above, the Hearings Officer has found Tree Farm 4 will comply with all applicable requirements
in the WA Zone. However, I have found that in the absence of an adequate wildlife habitat
management and wildfire plans, the applicant has not demonstrated The Tree Farm and Tree
Farm 4 will be compatible with nearby forest lands or with the Tumalo winter deer range.
For the foregoing reasons, the Hearings Officer finds Tree Farm 4>'vvill not have a negative effect
on agriculture or forestry. But I have found the applicant has failed to demonstrate Tree Farm€
will not have a negative effect on wildlife habitat in the winter deer range. Therefore, I find Tree
Farm 4 does not satisfy this criterion,
B.
The cond
findings
Clonal use shall not be granted unless the folio it
re made:
All development and alterations of the natural
landscape, will be limited to 35 percent of the land and
at least 65 percent shall be kept in, open space. In
cases where the natural landscape has been altered or
Tree Farm 4, 247 14 -000248 -CU, 247--14-000249-TP
Page 54 of 117
destroyed by a prior and use, such as surface Training,,
dam construction or timber removal, the County may
allow reclamation and enhancement of the open space
area if enhancement creates or improves wetlands,,
creates or improves wildlife habitat,, restores native
vegetation or provides for agriculturalor forestry use
of the property after raclaraaation.
FINDINGS: The Hearings Officer has found the WA Zone's 80 percent open space requirement
must be met entirely within the WA -zoned portion of Tree Farm . Because 85.7 acres of the
88.7 acres of Tree Farm 4 in the WA Zone will be preserved as permanent open space, the
applicant's proposal satisfies the WA Zone standards. +'ith respect to the 65 -percent open
space requirement in this paragraph, the applicant's burden of proof states 87.7 acres of the
109.5 -acre Tree Farm 4 (80 percent of the site) will be in open space, satisfying this standard.
2. The area not dedicated to open space or common use
may be platted as residential dwelling lots or parcels
that are a minimum of two acres and a maximum of
three acres in size. Their use shall be restricted to
single-family use. Single-family use may include'
accessory uses and County authorized home
occupations. Uses permitted in the open space area
may include the management of natural resources,
trail systems or other outdoor uses that are consistent
with the character of the natural landscape.
FINDINGS: The applicant proposes that Tree Farm 4 will have ten 2 -acre residential lots' w€th
single-family dwellings constructed within designated building envelopes. The appicant
proposes that the dedicated open space tracts will be managed for trail systems, wildlife habitat,
and forest management consistent with preservation of wildlife habitat and the reduction of fire
fuels. For these reasons, the Hearings Officer finds Tree Farm 4 satisfies this criterion.
In the Wildlife Area >>Combining, Zone, in addition to
compliance with the 1 A zone development
restrictions, uses and activities must be consistent,
with the required Wildlife Management Pan. The Plan
shall be approved if it proposes all of the following in
the required open space area:
FINDINGS: As discussed in detail''' in the findings above, the Hearings Officer has found the WA
Zone requirements apply only to the portion of Tree Farm 4 zoned WA. Therefore, I find it is
applicable only to the 88,5 acres of open space and road right-of-way in Tree Farm 4 zoned
WA. The applicant's WMP proposes that uses in the open space tracts in Tree Farm 4 will be
limited to management of vegetation for fire fuel reduction and winter range habitat conservation
as well as low -intensity recreation uses such as pedestrian and bicycle, trails. Therefore, I, find
he proposed uses and activities in the open ,,pace tract will be consistent with the VA/1‘,./1P.
However, as discussed above, I have found the WMP does notl adequately address potential
impacts on wildlife habitat from more aggressive fire fuel reduction that may be required to
protect ridgetop dwellings from wildland fire,
Farm 4, 247-14.0€ 0248 -CU, 247' -14 -000249 -TP Paye 55 o 117
av Preserves, protects and enhances, wildlife
habitat for WA zone protected species as
specified in the County Comprehensive Plan
(DCC Title 23); and
FINDINGS: The portion of Tree Fare 4 in the WA Zone consists of 87,7 acres of open space
and 0.8 acres of right-of-way for Golden Mantle Loop. As discussed in detail in the findings
above, incorporated by reference herein, the Hearings Officer has found the applicant failed to
demonstrate the site for Tree Farm 4 is suitable for the proposed cluster/PUD considering
wildlife habitat because the WMP is deficient in not addressing potential impacts on habitat from
more aggressive fire fuel treatments that may be required for ridgetop dwellings to reduce the
risk of fire, However, l have found on the basis of the WMP that deer will continue to use the
habitat in the open space area for browsing, and the segment of Tree Farm Drive will not
obstruct the existing deer migration corridor across the southern portion of Tree Farm 4.
FINDINGS: The only developed
b.
recreationa
Prohibits golf courses, tennis courts, swimming
pools, marinas, sk runs or other developed,'
recreational uses of similar intensity, Low
intensity recreational uses such as properly
located bicycle, equestrian and pedestrian
trails, wildlife viewing areas and fitness courses
may be permitted; and
pedestrian/bicycle trail''' system, a
use on the Tree Farm 4 open space wd
uld be
he
low -intensity use permitted by this paragraph.
c. Provides a supplemental,, private open space
area on home lots by imposing special yard
setback of 100 feet on yards adjacent to
required open space areas. In this yard, no
structures other than fences consistent with
DCC 1 B,8&070 may be constructed. The size of
the yard may be reduced during development
review if the County finds that, through the
review of the wildlife management plan, natural
landscape protection or wildlife values will
achieve equal' or greater protection through the
approval of a reduced setback. In granting an
adjustment, the County may require that
specific building envelope be shown on the
final plat or may impose other conditions that
assure the natural resource values relied upon
to justify the exception to the special yard,
requirements will be protected.
F1€' t $< The tentative plan for. Tree Fafill 4 show Lots 36 through0 are adjacent to the
open space within the WA Zone. As discussed above, the applicant has proposed building
envelopes for ail residential lots in The Tree Farm including the ten lots in Tree Farm 4. Those
building envelopes show setbacks of at least 100 feet between the adjacent'' WA -zoned open
space and the building envelope,
Tree Far
4, 247 14--000248-CU, 247 -14 -00024, -TP Page 56 of 117
d. Off-road motor vehic
rnthe o
e use shall be pro
pen space area,
hi
bited
FINDINGS: The applicant's burden of proof states no off-road motor vehicle use wi11' be
permitted in the open space tracts. The Hearings Officer finds the applicant gill, be required;, as a
condition of approval to prohibit off-road vehicle use on the Tree Farre 4 open space tract, and
to enforce that prohibition, through the development's CC&Rs.
Ad quate corridors on the chaster prope
allow for wildlife passage throug
developnient.<
h
y to
the
FINDINGS; As, discussed i€ the findings above concerning compliance with the general,'
conditional use standards in Chapter 18.128, the applicant's WMP identified several existing
nnigration corridors in the winter deer range, including north -south corridors in the western
portion of Tree Farm 4 and an east -west corridor along the southern part of Tree Farm 4
running parallel to Skyliners Road. Based on the WMP. the Hearings Officer has found the open
space tract and the segment of Golden Mantle Loop in the WA -zoned portion of Tree Farm 4
mill i not create a barrier to deer migration along this existing corridor. Therefore, I find this
existing corridor will allow wildlife passage.
4. Ail lots within the development shall be contiguous to
one another except for occasional corridors to allow
for human passage31 wildlife travel, natural features
Brach as a stream or 'bluff or development of property
divided by a public road which shall not be wider than
the average lot width, u
Hearings Body finds that special circumstances
warrant a wider corridor.,
Mess the Planning Director or
FINDINGS: The tentative plan for Tree Farm 4 she v s most of the residential lots will be
contiguous except for the intervening right-of-way for Golden, Mantle Loop. However, the
tentative plan shows a gap between Lots 37 and 38 and Lots 39 and 40 in Tree Fara 4 and Lot
43 in Tree Farm 5. The VVMP states this gap was proposed to recognize and protect a natural
topographic break and existing wildlife corridor between Turnalo Creek and the higher ground
on Tree Farms 4 and 5. Therefore, the Hearings Officer finds Tree Farm 4 satisfies this criterion.
5. All applicable subdivision or partition requirements
contained in DCC Title 17, the SubdivlsionIPar°titioa
Ordinance, shall be met.
Fl
D
GS:
orpllance with the criteria in Title 17 is addressed in the finding
below.
The total number of units shall be established b
reference to the lot size standards of the applicabl
zoning district and combining zones.
FINDINGS; The RR 10, UAR-1 O and WA Zones establish a gen
ten acres. The applicant proposes ten residential lots on the 10
therefore satisfying these standards.
Tree Far-rn 4, 247 -14 -000248 -CU, 247-14 100240--1-P
y
e,
eral density of one dwelling per
9,5 -acre Tree Farm 4 property,
Pa
57of1
7
The open space of the proposed development shall be
platted as a separate parcel or In common ownership
of some or all of the clustered lots or parcels. For any
open space or common area provided as a part of the
clyster development, the owner shall submit proof of
deed restrictions recorded in the County records. The
deed restrictions shall preclude, all future rights to
construct a residential dwelling on the lot, parcel or
tract designated as open space or common area for as
long as the lot, parcel or tract remains outside an
urban growth boundary. The deed shall also assure,
that the use of the open space shall be continued ire
the use allowed by the approved cluster development
plan, unless the whole development is brought inside
an urban growth boundary. if open space is to be
owned by a homeowner's association or if private
roads are approved, a homeowner's association must
be formed to manage the open space andlor road
areas. The bylaws of the as.ociation must be recorded
prior to or concurrent with the filling of the final plate if
the open space is located within the Wildlife Area
Combining Zone, the management plan for the open
space nnut be recorded with the deed restrictions or
bylaws of the homeowner's association.
FINDINGS: The tentative plan for Tree Farm 4 shows the 87.7 acres of open space would be
platted as a separate tract. The Hearings Officer the applicant will be required to show the Tree
Fara 4 open space as a separate tract on the final plot as a condition of approval.
The applicant submitted as Exhibit "L" to, its burden of proof a draft set of deed restrictions far
the open space tracts in The Tree Farm. Those deed restrictions would prohibit development
within the open space tracts for as long as The Tree Farm is located outside the Bend UGB. As
discussed' in the findings above under the administrative rules, the Hearings Officer has foul €
that to carry out the applicant's intent to prevent development on The Tree Farm open space
tracts in perpetuity, the applicant will be required as a condition of approval, and prior to
submitting for final approval'' any plat for Tree Farm development, to provide' to the Planning
Division for county review and approval a copy of the required deed restrictions, and to provide
to the Panning Division copies of the recorded deed restrictions after recording.
The applicant also proposes, and will be;,req uired as conditions of approval, to record the WMP
along with the required deed restrictions,, to form an HOA to own and manage the open space
tracts and roads within The Tree Farre, and to develop bylaws for the HOA.27
xhibit " ' to the a 4i 3nt t, burden of proof indicates the appiicant has doss: u s.id;potenti l acquisition
of the most western open space tracts in The Tree Farm by the Trust for Public Lands to facilitate future
transfer of these tracts to a public entity such as the park district or the USFS. Tree Farm open space not
so transferred would continue to be managed by the HOA The Hearings Officer finds that because it is
likely any transfer of Tree Farm open space to another entity will require some type of land use approval
-- e.g., lot line adjustment, modification of conditions — I need not address in this decision the legal effect
of such a transfer on conditional use approval of Tree Farm 4.
Tree Farm 4, 247 -`l4 -000248 -CU, 247-14 U00249 TP
Page of
Fl
a.
h
NDI
Notwithstanding any provialon to the contrary in other
parts of the County's land use regulations, roads
within a cluster development may be privateroads and
lots or parcels may be created that front on private
roads only. These roads must meet the private road
standards of DCC Title 17, and are not subject to
public road standards under DCC Title 17. An
agreement acceptable to the Road Department and,
County Leg& 'Counsel shall be required for the
maintenance of private roads. Pub lc' roads may be
required where street continuation standards of DCC
Title 17 call for street connections and the County
finds that the benefits of street extension are
significant and needed In the future, given the
established pattern of street development on adjoining
properdes and transportation distribution needs. The
area dedicated for public road rights of way within or
adjacent to a planned or duster development or
required by the County during duster development
review shall be subtracted from the gross acreage of
the duster development prior to calculating
compliance with open space requirements.,
NOS; The Hearings Officer finds this subsection establishes the following'
private roads, are permitted in Tree Farm 4;
private PUD roads must meet the county's private road standards;
c. a road maintenance agreement acceptab
d, p
IIIc roads may be re
g
uired in the su
e to the county
bdivision where;
ust be executed; and
street continuation standards in Title 17 call for street connections; and
0 the county finds the benefits of street extension are ,significant and needed in the future,
given the established pattern of street development on adjoining properties and
transportation distribution needs.
The apps cant proposes to construct a private road, Golden Mantle Loop, in Tree Farm 4, and to
improve this road to the applicable county standards for local private roads including 20 feet of
paved surface. In addition, the applicant proposes to dedicate to the public 60 feet of right-of-
way for Sage Steppe Drive in Tree Farm 1 in order to provide future public road access to the
adjoining ''Rio Lobo property to the north and to provide an emergency access road through the
adjoining;, Miller Tree Farm property to the south. Ridgeline Drive will connect with Tree Farm
Drive in Tree Farms 1, 2 and 3 to provide access to Skyliners Road for the residential lots in
Tree Farms 1, '2 and 3, and to create a connection to Golden Mantle Loop and Canopy Court
which would provide access to the lots in Tree Farms 4 and 5. The applicant proposes that all
Tree Farm roads will be owned and managed by The Tree Farm HOA, The Hearings Officer
finds the applicant will be required as a condition of approval to execute a road maintenance
Tree Farm 4, 247-14-00 24 -Ct.�, 247 -14 -00024Q -TP Page 59 of 11
7
agreement acceptableto the county and to record such agreement prior to submitting for
approval the final plat for any Tree Farm development.
The record indicates there are no existing streets on surrounding lands for which a connection
to allow continuation of such street Is required. Section 17,36,02O(B) provides that planned
developments shall include public streets "where necessary to accommodate present and future
through traffic." However, as discussed in detail in the findings below, incorporated by, reference
herein, the Hearings Officer has found this section does not require the applicant to dedicate or
construct a public road from Rio Lobo's property to Skylhnere Road because such a public road
is not necessary to accommodate present and future through traffic within The Tree Farm or
from the Rio Lobo property.
Based on the foregoing findings, the Hearings Officer finds that with impositioi s of the conditions'
of approval described above, Tree Farre 4 will satisfy this criterion.
9. Ail service corn ectioi s .shall be the m
necessary and underground where feasi
inimum length
ble.
FINDINGS: The preliminary utility plan for Tree Farm 4, Exhibit "E» to the burden of proof,
shows all new utility services will be ''located underground within road rights-of-way, The
Hearings Officer finds this proposal will assure service connections are the minimum length
necessary, therefore satisfying this criterion,
10. The number of rye=
not exceed 10.
11. The number of new
not exceed 10.
dwel
€x
ng units to be cluste
S
Parcels to
b
red d
e created d
0
es
oes
FINDINGS: The applicant proposes ten residential; lots in Tree Farm 4 clustered near the
southeast corner of the development and the north -central part of The Tree Farm, therefore
satisfying these criteria.
12. The development is not to be served by a new
community sewer system or by any new extension of a
sewer system from within an urban growth boundary,
or from within an unincorporated community.
FINDINGS: : Applicant proposes to serve the resid
site septic systems, therefore satisfying this criteria
ential lots in Tree Farrn 4 with individual on -
n.
13. The development will not force
accepted fa
devoted to
increase t
there,
a significant change in
rm or forest practices on nearby lands
farm or forest use, and will not significantly
he cost of accepted farm or forest practices
FINDINGS: As discussed in detail in the findings above concerning compliance with the
applicable administrative rules in OAR 60-004-040 and the general conditional use standards
in Chapter 18.128, incorporated by reference herein,''the Hearings Officer finds Tree Farm 4 will
F
m 4, 247-14-0 0248 -CU, 247E 14 -000249 -TF
Papa 60 of 117
not force a significant change in, or significantly increase the cost of, accepted far€ cr forest
practices on nearby lands devoted to farm or forest use.
14. Ali dwellings €n a cluster developmentmust be
setback a minimum of 100 feet from the boundary line
of an adjacent lot zoned Exclusive Farm Use that is
receiving special assessment for farm use.
FINDINGS: The Hearings Officer finds this criterion is not applicable because there are no lands
zoned Exclusive Farm Use ( FU) adjacent to the subject property:,,
C. Al l
fol
applications, shall be accompanied by a plan , ith the
swing information:
A plat map meeting
DCC Title 17, the Su
all the subdivision requirements of
bdiv'isionIPartition Ordinance.
A draft of the deed restrictions requ ed' by ''ICC'
18.128.200(B)(7).
FINDINGS: The applicant submitted a tentative plan for Tree Farm 4 including a plat map
showing ail information required under Title 17. In addition, the applicant submitted > as Exhibit
"L" to the burden of proof draft deed restriction language for the open space tract As discussed
n the findings above, the Hearings Officer has found the applicant ' will be required to submit for
county review, and to record, deed restrictions that permanently prohibit development on these
tracts. For these reasons, and with imposition of the conditions of approval described above,
find Tree Fain 4 satisfies this criterion.
FINDINGS: The applicant su
A written document establis'
hcri
common property,
document shall incliid
owners asocl
ging an acceptable
Lien assuring the maintenance of
if any, in the development. The
e a method for the resolution of
disputes by the association mem
included as part of the
bylaws.
bership, and shall be
brr•€itted as part of Exhibit °'L' to the Tree Farr
4 burden of
roof
CC Rs and HOA bylaws, therefore satisfying this criterion,
4'a In the WA Combining Zone, the applicant shall submit,
an evaluation of the property with Wildlife
Management Pan for the open space area, prepared
by a wildlife biologist that <includes the following:
A description of the condition of the property
and the current ability; of the property to
support of the open space area'by wildlife
protected by the applicable WA zone during the
periods specified in the comprehensive plan;
and
Tree Fara 4, 2 7' 14-0 248-C!J, ,47 -14 -000249 -TP
Page 61 of 117
b A description of the protected species and
periods of protection identified by the
eomprehensive plan and the current use of the
open space area; and
A nanagaent plan that contains prescriptions
that vvill achieve compliance with the wildlife
protection guidelines hi the comprehensive
plan. In overlay zones that are keyed to seasons
or particular times of the year, restrictions or
protections may vary based on the time of year.
The management plan may also propose
protections or enhancements of benefit to other
types of wildlife that may be considered in
weighing ' use impacts versus plan benefits.
FINDINGS: The applicant submitted a WMP as Exhibit 1" to the Tree Farm 4 burden of proof.
Based on the findings above, incorporated by reference herein, the Hearings Officer finds the
WMP oo tains the information required in this subsection
a, Photographs and a narrative description of the natural
landscape' features of the open space areas of the
subject property. If the features are to be removed or
developed R the applicant shall explain why remove is
appropriate.,
FINDINGS: The applicant's burden of proof includes aerial photographs of The Tree Fang and
surrounding property as well as a narrative description of the natural <landscape features and
proposed open space areas in Tree Farm 4. The applicant does not propose to introduce any
landscaping, or to remove any existing landscape features in the open space areas except as
necessary for ongoing fire fuels treatment. However. as discussed in the findings above the
Hearings 'Officer has found the ' 'MP is deficient in not addressing potential impacts to wildlife
habitat from more aggressive fire fuel treatments that may be necessary to protect ridgetop
dwellings. Therefore, I find the applicant has not fully satisfied this criterion.
r A description of the forestry
proposed, if any.
FINDING: The, applicant's burden of proof states no agricultural use
Farm 4, and that the only forestry uses proposed are fire fuels reduc
wildfire risk and to improve wildlife habitat
For the foregoing reasons, the Hearings Of
information required by these criteria.
Tree Farrn 4, 247
er find
he
Tre
or agricultural uses
are proposed
e Farm 4
n tretm
for Tree
ent to reduce
,proposal provides all
Dimensional Standards:
Setbacks and height limitations shall be as prescribed"
in the zone in which the development is proposed
unless adequate justification for variation is provided
the Planning Director or Hearings Body.
4 -000248 -CU, 247-14-00 249-`
Page 62 of 117
FINDINGS: The setback and height limitations in the RR -10 and UAR-1O Zones are discussed
in the findings above and below. The Hearings Officer has found the applicant will be required''
as a condition of approval to meet these standards for the dwellings in Tree Farm 4.,
. Minimum area for a cluster d
determined by the zone in which
eveloprent sh
it is proposed.
all
be
FINDINGS: The 109.5 -acre Tree Farm 4 meets the 40 -acre minimum size for a cluster
development in the WA Zone. The RR -10 Zone does not establish a minim a€ size for cluster''
developments. As discussed in the findings below, Tree Farm 4 satisfies the five -acre minimum
size for a planned unit development in the UAR-1 O Zone.
E. Conditions for phased development shall be specified and
performance bonds shall be required by the Planning Director
or Hearings Body to assure completion of the project as
stipulated, if required improvements are not completed prior'
to platting,
FINDINGS: : The applicant does not propose to develop Tree Farm 4 in phases, and therefore
the Hearings Officer finds this criterion is not applicable. However; as discussed above, the
applicant ;,proposes to develop Tree Farris 1, 2'' and 3 concurrently to provide road access for all
residential lots in those developments. 1 have found such concurrent development will be
required as a condition of approval for Tree Farms 1, 2 and 3
F' Developments with private roads shall provide bicycle and
pedestrian facilities that comply with the private road
requirements of Title 17.
FINDING: The applicant proposes to accommodate bicycle and pedestrian traffic via a
network of paved multi -use trails and native surface recreational/mountain biking trails. The
applicant proposes that only the southern portion of Tree Farm Drive would be designed to
accommodate bicycle traffic on its paved surface. All other paved paths would run parallel to,
but be separate from, the PUD roads; The applicant proposes, and will be required as a
condition of approval,' to construct all subdivisirn roads with the applicable standards in Title 17
for focal public and private roads.
G. Bicycle and pedestrian connections shall be
ends of cul-de-sacs, at m
etc., in the following
foot right of way, wit
shall be as straight as possible, and s
400 feet Tonga
provided at the
id -block, between subdivision plats,
situations. Connections shall have a 20-
h>,at least a 10 -foot wide useable surface,
Fall n€ot be more than
Where the addition of a connection;, will reduce the
walking or cycling distance to an existing 'o r planned <"
transit stop, school, shopping center, or neighborhood
park by 400 feet and by at least > 50 percent >.over other
available routes.
Tree Farrn",.4, 247 -14 -000248 -CEJ, 247-14-C 0249 -TP Page 63 of 11.
FINDINGS: The applicant submitted
Plan" that shows four types of trail
For schools or commercial uses where the addition of
a connection will reduce the walking or cycling
distance to an existing or planned transit stop, school,
shopping center, or neighborhood park by 200 feet or
by at east 0 percent over other available routes.
For cul de sacs or dead end streets where a street
connection is determined by the Haring. Officer or
Planning Director to be unfeasible or inappropriate
provided that a bicycle or pedestrian connection is not
required where the logical extension of the road that
terminates in a cul de sac or dead end street to the
nearest boundary of the development will not create a
direct connection tai an area street, sidewalk or
bikeway.
The County may approve a cluster development
without bicycle or pedestrian connections if
connections interfere with, wildlife passage through
the subdivision, harm wildlife habitat or alter
landscape approved for protection in its natural state,
as Exhibit "C" to its burden of proof for Tree Farm 4 a 'Trai'l
s with
n the Tree Farm:
1, a 10 -foot -wide paved section of Tree Farm Drive from S
3;
kyliners load
to a point in, Tree Farm
2. several 8 foot> -wide `"neighborhood trails" running along the private Tree Fa
rr i roads;
3. recreation/mountain bike trails leading across the open space in the 'RFS-1O./WA zoned portion
of The Tree Farm and connecting with the existing trail system in Shevlin Park;, and
4. existing "perimeter trails"'' with native surface" traversing the open space in the RR-10/WA
zoned portion of The Tree Farm between Shevlin Park and the top of the central ridge on The
Tree Fara property.
The tentative plan for Tree Farre 4 shows no cul-de-sacs. Therefore, the Hearings Officer finds
no raid -block bicycle connections are required in Tree Farm 4. l found in my Tree Farm 1
decision that construction of a bicycle and pedestrian connection from the cul-de-sac on
Ridgeline Court to the nearby schools and beyond to the retail and park uses in >.Florth'et
Crossing would require crossing the adjacent Miller Tree Farm property to the southeast which
is not a part of the proposed Tree Farre development. For this reason, i found in my Tree Farm
1 decision that a bicycle and pedestrian connection at the end of Ridgeline Court is infeasible
and inappropriate. In my decision in Tree Farm 3, l found a bicycle and pedestrian connection at
the cul-de-sac end of Canopy Court is infeasible and inappropriate; in light of the lack of through -
et connections in the vicinity`. However, I note the proposed trail system in The Tree Farm
t the Canopy Court cul-de-sac to Shevlin Park and to the DNF to the west.
Tree Farm 4, 247.14-00024€ CU, 247 -14 -000249 -TP
Fag
64 of 117
A Conditions of Appr av l Agreement for the ci
development shall be recorded prior to or concu
final plat for the development.
FINDINGS: The Hearings Officer finds the applicant will be req
to record a Conditions of Approval Agreement in accordance wit
uired as a condition
h this paragraph,
uster
rith the
pproval'
For the foregoing reasons, the Hearings Officer has failed to demonstrate Tree Fara 4 will
satisfy all applicable conditional use criteria in Chapter 18.128.
D. Tifl
e 19 of the Des
Ordinance
cl
rotes County Cod
e
the Ben
d Urban Growth Bou
UAR-10 ZONE STANDARDS
Chapter 19 12, Urban Area Reserve Zone UAR 1 O
Section t 9.12.10 Purpose
nd
ary Zonin
g
To serve a ' a holding category and to provide opportunity for tax
differentials as urban growth takes place elsewhere in the planning
area, and to be preserved as long as passible as useful open space
until needed for orderly growths
FINDINGS: Opponent Christine Herrick argues the applicant's proposal conflicts with the
purpose statement for the UAR-10 Zone which she believes requires the portion of The Tree
Farm located in the UAR-10 Zone to remain in open space "as long as possible." The Hearings
Officer disagrees, Zoning ordinance purpose statements do not establish approval criteria for
quasi-judicial land use ,applications where such statements are aspirational, or where nothing in
the text or context of the purpose statement >.suggests it was intended to establish approval
criteria. SE1U v. City of Happy Valley, 5 Or LUBA 261 (2009). The Hearings Officer finds there
is nothing, in this purpose statement that suggests it was intended to apply to quasi-judicial land
use applications or to prohibit uses permitted outright or conditionally in the UAR-10 Zone.
b.
Section 1912.03
0, Con
ditiona
I Uses
FINDINGS: Opponents Christine Herrick and Ruth Zdanowicz argue that conditional uses in the
UA _10 Zone "must comply', with the Statewide Goals for land use." They are mistaken, The
statewide goals are implemented through the county's acknowledged comprehensive plans and
zoning ordinances, and therefore are not directly applicable to the applicant's quasi-judicial land
use application.
Fl
* the development of an area of land as a single entity for a number of units or
a number of uses, according to, a plan which does not necessarily correspond hi
lot >size, ''bulk or type of dwelling, density, lot coverage or required open space to
the standard regulations otherwise required by DCC Title 19.
The applicant proposes that Tree Farm 4 be approved as a stand-alone subdivision with ten 2 -
acre residential lots, an 87.7 -acre open space tract, and segments of private roads and € uiti-
use panes. However, the Hearings Officer has found that none of the individual Tree Farm
cluster!FUDs can function independently of one another. And the applicant proposes that Tree
Farms 1, 2 and 3 be developed'''' concurrently to assure access to Skyliners Road for all
residential lots in those PUDs. As discussed elsewhere in this decision, the applicant has,
requested approval to deviate in several respects from the standard regulations for subdivisions.
For these reasons, l find Tree Farm 4 meets the definition of PUD and therefore is permitted
conditionally in the UAR-10 Zone. And as discussed in the findings above, I have found that in
order to conduct a meaningful review of Tree 'arra 4 as a whole, l will apply the provisions of
Tit e 19 to the entire Tree Fara 4 and not just to those portions of the development zoned UAR-
10 Compliance with Chapters 19.76 19.100, and 19.104 is addressed in the findings below,
Section 19.12.040, Height Regulations
No building or structure shall
structurally altered to exceed 30
be hereafter erecte
feet in height.
d, enla
g
ed
FINDING. The Hearings Officer finds the applicant will be required as a condition of approval
to assure all dwellings in Tree Farm 4 meet the 30 -foot height limitation, find building height will
be verified at the time of building plan review, permitting and inspections.
Vit. Section 19.12.050, Lot Reg
The follo in
g req
uira€
uirements s
A. Lot Area, Each lot s
ants
hall be observed°
hall
have a mini
Lot Width. Each lot shall
300 feet with a minimum s
"sm u
a
rea of 10 acres.
have a minimum average width of
treet frontage, of 150 feet.
Front Yard. The front yard shall be a minimum of 50 feet from
the existing street right of way line or the ultimate street right
of way as adopted on the Comprehensive ''Flan or Official
Map, except that any lot of record less than one acre in size
lawfully created prior to (effect date of this title) shall have a
minimum front yard of 30 feet.
Side``' Ya
rd. There shall
be a mi
um sid
eyard of10f
Rear Yard. There shall be a minimum rear yard of 5
Solar Setback. The
DCC 19,88,210.
Tree Farm 4, 247-14-000248-C , 24T14- 024 TP
solar setba
0 feet.
ck shahl be as prescri
bed in
Page 66of117
FINDINGS: The applicant proposes exceptions to minimum lot area, average lot width. and
street frontage requirements pursuant to the PUD standards in Chapter 19.104. As discussed in
the findings below, the Hearings Officer has found the requested exceptions are lusflfied by the
benefits provided by The Tree Farm cluster/PUDs.
For the foregoing reasons, the Hearings Officer find
standards in the UART10 Zone in Chapter 19.12.
SITE
FI
D
PLAN REVIEW
NGS: As
c
ha
pter 19.76, Site Plan Review
s Tree
Section 19.76.070, Site Plan Criteria
th above, Section 19.12.030 states PU
A
pproval of a site
plan s
Far
4 satisfies all a
pplioable
Ds are subject to site plan rev€ew,
hall be based o
n the followir
g trite
ria:
A. Safety and Privacy. Residential site plans shall be designed
to provide a safe living environment while offering
appropriate opportunities for privacy and transitions from
public to private spaces.
FINDINGS. As discussed in detail in the finings above. incorporated by reference herein, the
Hearings Officer has found the applicant failed to demonstrate the site for Tree Farm 4 is
suitable for the proposed cluster/PUD considering wildfire risk. For those same reasons, l`>find
the applicant has not demonstrated the site plan for Tree Farm 4 is designed to provide a safe
living env€ronrent. Therefore, l find Tree Farm 4 does not satisfy this criterion
E; Special Needs of Disabled. When deemed appropriate, the
site plan shall provide for the special needs of disabled
persons, such as ramps for wheelchairs, drop curbs and
disabled parking stall'.
FINDINGS: The applicant's burden of proof states the paved bicycle/pedestrian path along Tree
Farm Drive and the neighborhood trails within The Tree Farm and Tree Farm 4 will be designed
and constructed in accordance with applicable requirements of the Americans ith Disabilities
Act (ADA) to the extent practicable and where required, to ensure adequate access., The
Hearings Officer understands these private paths may not be inspected for ADA compliance.
However, I am aware ADA compliance for dwellings and accessory structures will be,
determined and verified at the time of building, permit plan, review, permitting, and inspections.
For these reasons, l find Tree Farm 4 satisfies this criterion.
Ca
Preservation of Natural 'Landscape. The landscape and
existing grade shall be preserved to the maximum practical
degree, considering development constraints and suitability
of the landscape or grade to serve the, applicant's functions.
Preserved trees and shrubs shall be protected during;,
construct€o .
Tree Farm>4. 247 -14 -000248 -CU 247` 14 -000249 -TP
Pace 6i of 117
FINDINGS: The applicant proposes to preserve 87.7 acres of the 109,5 -acre Tree Farm 4 as
open space with the only development therein being a s€ -hall segment of Tree Farm Drive. The
tentative ,; plans for Tree Farms 1 through 5 show most of the road rights-of-way have been
proposed in locations and alignments where they will follow existing topography. The tentative
plans also show the residential lots will be located primarily atop the central ridge running
through The Tree Farm or on other relatively level areas. The dwellings in Tree Farm 4 would
be clustered near the northeastern corner of the cluster/PUD on relatively levelground. Finally,
the applicant proposes to preserve existing vegetation within the open space tract except where
removal or modification of vegetation is required as part of fire fuels treatment or to improve
wildlife habitat. However, as, discussed in the findings above, the Hearings Officer has found
neither the applicant's wildfire plan nor VVMP adequately addresses the need for, or impacts
from, more aggressive fire fuel treatments that may be required on lots and in open space tracts
in order to reduce the fire hazards for ridgetop dwellings such that Tree Farm 4 is suitable for
the proposed clusteriPUD and is compatible with surrounding properties. Therefore, I find the
applicant has not demonstrated compliance with this criterion.
D. Pedestrian and Vehicular Circulation and Parking. The
location and number of points of access to the site, the
interior circulation patterns, designs of parking areas and the
separation between pedestrians, and moving and parked
'vehicles shall be designed to promote safety and avoid
congestion on adjacent streets.
FINDINGS: : The Tree Farm tentative plans show the development will have access from
Skyliners Road via Tree Farm Drive, improved with a 26 -foot -wide paved surface, and with a
system of public and private roads connecting with Tree Farm Drive and developed with a 20-
footTwide paved surface and parallel eight- and ten -foot wide paved multi -use paths. The
applicant also proposes a gated temporary secondary access road from the southern end of
Sage Steppe Drive south across the adjoining Miller Tree Farm property to Crosby Drive. This
temporary access will be in place until the adjoining Miller Tree Farm property is developed' with
paved streets to which Sage Steppe Drive can connect. In addition, Sage Steppe Drive would
be stubbed at the northern boundary of Tree Farm ''1 to provide a future road connection to the
vacant Rio Lobo property to the north. Parking would be prohibited on Tree Farm roads, and all
off-street parking would be provided on the residential lots. The Hearings Officer finds the
proposed vehicular and pedestrian circulation plan will provide separation between vehicles,
bicycles and pedestrians. will promote safety, and will avoid road congestion, therefore
sati
lying this criterion.
Buffering and Screening. Areas, structures and facilities for
storage, machinery and equipment, services (mail, refuse,
utility wires and the like), 'loading and parking and similar
accessory areas and structures shall be designed, located,
buffered or screened to minimize adverse impacts to the site
and neighboring properties.
FINDINGS: "'he applicant's burden of proof ani tent :tive` plans inv icate none of tlx : above-
described structures or uses is proposed for Tree Farm 4. Therefore, the Hearings Officer finds
this criterion is not applicable.
Tree Farm 4, 247-14-00024
-CU 247 14 -000249 -TP
Pao
68 of 117
Utilities. All utility installations above ground, if such are
allowed, shall be located so as to minimize adverse impacts
on the site and neighboring properties.
FINDINGS: The record indicates, and the HearingsOfficer's site visit observations confirmed,
that there is an existing above -ground electrical facility running east -west near the Tree Farm's
southern boundary and serving the city's Outback Water Facility. However, the tentative plan
shows no part of that facility is located in Tree Farm 4. The applicant proposes that all new
utilities be located underground. Therefore, I find this criterion is not applicable to Tree Farm 4.
G. Public Facilities. The proposed use shall not be an undue
burden on public facilities, such as the street, sewer or water
system.
FINDINGS:
Streets. As discussed in the findings above, the applicant's traffic study, included in the record
as Exhibit "H" to the applicant's burden of proof for Tree Farm 4, shows traffic predicted to be
generated by The Tree Farm will not cause affected transportation facilities to operate below
acceptable levels of service. The road department, the county's transportation planner, and the
city's public works department did not recommend improvements to existing transportation
facilities to accommodate Tree Farm traffic.
Sewage Disposal. The Tree Farm will be served by individual on-site septic disposal systems.
No connection to the city's sewer system Is proposed. The applicant submitted as Exhibit "F" to
the Tree Farm 4 burden of proof a septic suitability study demonstrating soils on The Tree Farm
and Tree Farm 4 are suitable for on-site sewage disposal.
Water. The applicant proposes to provide domestic water to The Tree Farm residential lots
through one of three sources: (1) extension of and connection to the City, of Bend water system;
(2) extension of and connection to Avion Water Company's system; or (3) use of one or more
wells on The Tree Farm and/or the adjacent Miller Tree Farm € property. The applicant expressed
a preference for city water service, and requested that the city perform a water analysis for
serving The Tree Farm with city water. That analysis and supporting documents, ated August
1, 2014, are included in the record as Exhibit "G"' to the Tree Farm 4 burden of proof. In
addition, two diagrams labeled "Preliminary Utility Plan' are included in Exhibit "E, to the Tree
Farm 3 burden of proof. One of those diagrams is a version of the diagram included in Exhibit
"G" and the other is a copy of the applicant's submitted "Preliminary Utility Plan."
The city's water analysis states the Tree Farm can be served by city water facilities with a
development agreement between the applicant > and the city. The analysis states the nearest city
water infrastructure is the Outback Water Facility located near the southwest corner of The Tree
Farm and described by the applicant as "the primary storage and treatment area for he City's
surface water and [that] also contains several of the City's groundwater weds." The analysis
ate s water for The Tree Farm could be provided from the Outback facility through a new
r nectian and installation of 12 -inch and 24 inch diameter water mains within The Tree Farm.
However, the analysis cautioned no such water connection could be made r.€ntil the city's
0 tback Membrane Water Facility" is constructed and operational, and the Bend City Council"
approves extension of city water service outside the Bend UGB through a public process. 28
The Hearings Officer understands this facility was unde
h
en this record closed.
Tree F 4, 24S -14 -000248 -CU, 247-14-0[1 249 -TP" Page 63 of 117
The city's water system analysis states city standards require the following
pressure and flow for domestic use:
m
40
20
2.0
psi (pounds per square inch)
psi residual pressure; and
00 gpm (gallons per minute)
press
ure at peak p
for fire f
iods;
€€n€€mourn water
The color -coded diagrams included in Exhibits "E' and "G" to the Tree Farm 4 burden of proof
show that most of the water mains in The Tree Farm could be 24 inches in diameter, but that
the mains would need to be 12 inches in diameter along the upper segment of Golden Mantle
Loop, and along the segment of Ridgeline Drive east of Sage Steppe Drive. to provide adequate
pressure in those areas, The diagrams show all Tree Farm lots would have at least 2,000 gpm
for fire flow, but only the ten lots in Tree Farm 1 would have water pr. ire meeting the 40 psi
and 20 psi minimum standards. The other Tree Farm lots would have peak period and residual
water pressure falling belowthose minimum standards.
The city's water analysis states the city cannot;. guarantee a<specifijc water pressure or flow, and
that any water sery€ce agreement between the city and the applicant must clearly identify areas
of substandard pressure and/or fire flow. The analysis goes on to state that if the property owner
finds the available water pressure unsatisfactory, the property owner may install a pressure
pump on the downstream side of the city's water meter, at the property owner's own expense
and responsibility The applicant's ''' Preliminary Utility Plan in Exhibit "E' includes a notation that
"al homes incl, services with booster pumps." The Hearings understands this note to mean the
applicant proposes that water service for each residential lot will have a pump boosting pressure
to achieve the minimum psi established in the city's minimum standards.
Based on the city's water analysis. the Hearings Officer finds that if water is provided to Tree
Farm 3 through extension of city water service as proposed by the applicant and with necessary
city approvals, Tree Farm 4 will not place an undue burden on the city's water facilities
n his December 11, 2014 letter on behalf of LandWatch, Paul Dewey stated
'Even the uncertainty as to the eventual source of water and whether all of the
possible sources will have adequate pressure, the Applicant should be required
provide more specific information and the public be given the opportunity to
n it.' ,1
The Hearings Officer finds the applicant has submitted sufficient information about water service
from the City of Bend for me to find that providing water to Tree Farm 4 will not place an undue
burden on the city's water facilities, The applicant did not submit a will -serve letter from Avion
Water Company. In a memorandum dated December 29, 2014, the applicant's engineer Niall
Boggs from WH Pacific stated Avian or another private water purveyor would provide water to
The Tree Farm through the city's existing 14 -inch or16-inch water lines. However, Mr. Boggs
stated this system may require a 'booster pump station" to provide sufficient water pressure for
all Tree Fano lots, And he noted use of the city's water system by a private water purveyor like'
Avion would require an agreement with the city.
The applicant submitted well logs for surrounding properties, included as Exhibit "Ml" to the
burden of proof for Tree Farm 4 that demonstrate groundwater is available in the surrounding
area. Mr. Boggs stated in his memorandum that individual wells for Tree Farm lots would
Tre
=aria 4. 2477-14-000249a l.l, 247 -14 -000249 -TP" Page 70 of 117
require the lot developer or owner to provide the pipe, power and, pump. However, Mr. Boggs
did not analyze or determine whether such wells could produce sufficient water pressure or fire
flow to meet the minimum standards identified by the city.79 Finally, Mr. Boggs noted Filler Tree
Farm as a quasi -municipal water right for 350 gpm for property including The Tree Fare. He,
stated that in order for the applicantto use this water right to create an operational water system
for Th Tree Fara, water from the, well or wells > would have to be ,pumped to a reservoir site at
the highest point on The Tree Farm property near proposed Lot 50 in Tree Farm 5. Water would
then go through a community booster pump station before being distributed to residential lots.
Mr. Boggs stated such a system would be "feasible" but would require significantly more capital
investment. He did not state whether this quasi-municipa system could produce sufficient
pressure and fire flow for the residential lots.
For the foregoing reasons, the Hearings Officer finds that if the applicant elects, or is required
to, provide water to The Tree Farre through means other than extension of city water service,
the applicant will be required as a condition of approval for Tree Farm 4, and before submitting
for approval the final plat for any Tree Farm development, to provide to the Panning Division a
water analysis performed by a registered professional engineer demonstrating that water
service from the alternative domestic water source will provide at each residential lot water
pressure of at east 40 psi during, peak demand periods; 20 psi residual pressure, and 2,000
gpm for fire flow.
For the foregoing reasons, and with imposition of the conditions of approval described above,
the Hearings Officer finds Tree Farm 4 satisfies this criterion,
Section 19.76.080, Required Minimum Standards
A. Minimum Landscaping Standards. All developents subject
to site plan approval shall meet the following minimum
standards for land
1
soaping:
A minimum of 15 percent of the area of a project shall
be landscaped for multifamily, commercial and
ludustrial developments, subject to site plan approval
and the following requirements . .
FINDINGS: The Hearings, Officer finds the 15 -percent
Subsection (1) is not applicable to Tree Farm 4 because it is
industrial use,
landscape area requirement in
not a multi -family, commercial or
Street Trees. The placement, spacing and pruning of
street trees shall be as follows, although the Planning
Director or Hearings Body may adjust the placement
standard for special site conditions .
FINDINGS: The applicant requests an exception to the street tree requirement under Chapter
19.104 As discussed in the findings b slew, the l-lesr€ngs''Off€cer has found this exception is
justified by the benefits provided by The Tree Farm.
9 The record indicates the 37 lots
served by individual on-site wells:.
in The Highlands at BrcKen Top south across kyii'rs Road are
Tree Farm 4, 247-14- 248 -CU, 247 -14 -000249 -TP Page 7 1 cf 112
3, Areas of commercial and industrial zones used for
vehicle maneuvering, parking, loading or storage shall
be landscaped and screened as follows:. , o
FINDINGS: The Hearings Officer finds this criterion i
does not include multi -family,, commercial or Industria
Required la
maintained.
s not applica
uses.
ndsca
bie to Tree Farm 4 because it
ping s
hall
continuously
Vegetation planted in accordance with an approved
site plan shall be maintained by the owner, any heir or
assignee. Plants or trees that die or are damaged shall`
be replaced and maintained.
FINDINGS: The, applicant has requested an exception to these requirements under Ch
19.104. As discussed in in the findings below, the Hearings Officer has found this except
justified by the benefits provided by The Tree Farre.
apter
on is
Shared Areas. Usable outdoor recreation space, shaft be
provided for the shared use of residents and their guests in
any apartment residential development as follows
FIND The Hearings Officer finds this criterion is not applicable to Tree Farm 4 because it
is not an apartment residential development.
C. Storage. Areas shall be provided in residential developments
for the storage of articles such as bicycles, barbecues,
luggage, outdoor furniture, etc.
F'INDINGS; The applicant's burden of proof did not address this criterion. However, the
Hearings Officer finds adequate storage for the lusted items could be provided on each
residential lot within each dwelling, garage, and/or accessory structure. Therefore, 1 find the
applicant's proposal satisfies this criterion
D. D
rai
nage. Surface d
raina
ge s
h
II be contained on site.
FINDINGS: The applicant's submitted site plan and burden of proof for Tree Farre 4 show
surface water drainage scald be contained on site through, use of vegetated'''swales, roadside
ditches, culverts, and natural' drainage ways. Specifically, the applicant states runoff would shed
to vegetated s ales' with 3:1 slopes for on-site infiltration, or runoff would enter a natural
drainage way via a roadside ditch and culvert. Because of the site's topography, natural
drainage patterns on The Tree Farre generally are toward Tumalo Creek to the west and to the
undeveloped open space to the east. However, the applicant's burden of proof states none of
the runoff from impervious areas such as roads and driveways will create any additional
drainagecontributions`to Tumalo Creek as no surface' water' will be disposed of off-site.
Finally, the applicant has proposed that if hydrological calculations determine additional runoff
storage is needed, the applicant will construct a catch basin near the main entry to The Tree
Farm at Skyliners Road, which appears to be the lowest point in The Tree Farm. The Hearings
Officerfound in my decision in Tree Farm 1 that the applicant will be required as a condition o
Tree Farm 4, 247` 14-0i 248 -CU, 247' 14 -000249 -TP Page 72 of 117
approva and prior to submitting the final plat for any part of The Tree Farm for approval, to
submit to the Planning Division a statement from a registered professional engineer stating
whether an additional runoff storage basin is necessary, and if such a facility is necessary, the
applicant will be required as a condition of approval for Tree Farm 1 to show it on the finalplat
for Tree Farm 1, and to construct it as part of Tree Farm 1 or in such other location as
determined by a registered professional engineer.
Bicycle Parking. The development shall provide the number
and type of bicycle parking facility as required in DCC
19080.080 and 19.80,090, The location and design of bicycle
parking facilities shall be shown on the site plan,
FINDINGS: The Hearings Officer finds Tree Farm 4 is not required to provide bicycle parking
because it is not subject to Sections 19.80.080 and 19.80.090. That is because off-street bicycle
parking is not required for single-family dwellings, and Tree Farm 4 will, not include any of the
uses for which off-street bicycle parking is required.
F. Internal Pedestrian Circulation. Internal pedestrian circulation
shall be provided in new office parks and commercial
developments through the clustering of buildings,,
construction of hard surface pedestrian walkway, and similar
techniques.
Walkways shall connect building entrances to one another
and from building entrances to public street' and existing or
planned transit stops. On site walkways shall connect with
walkways, sidewalks, bikeways, and other pedestrian or
bicycle connection on adjacent properties planned or used
for commercial, multifamily, institutional or park use.,
FINDINGS: The Hearings Officer finds these criteria are not applicable to Tree Farm 4 because
it is not a new office park or commercial development,
Publ c Transit Orientation. New retail, o and institutional
buildings on parcels within 600 feet of existing or planned
transit routes shall provide preferential access to transit
through the following measures „
FINDING : The Hearings Officer finds this crit ion is not applicable to Tree F r€ n 4 because it
is not a new retail, office or institutional use; .
For the foregoing reasons, the Hearings Office
bove
the conditions of approval describe
under Title 19:,
da
URBAN AREA'CON, CONDITIONAL USE CRITERIA
Chapter 19.10
Inds Tree F
satisfy, al
0, Conditional Use
Permits
Section 19.100,00, General Gond
Tree F 4, 247.14 -000248 -CU, 247 14 -€000249 -TFC"
m 4 satisfies, or with imposition of
applicable site plan requirements
itional Use Criteria
Page 73 of 11€ 7
Fl
DING,
A conditional use permit may be granted offly upon findings by the
Planning Director or Hearings Body that the proposal meets ail of
the criteria In DCC 19.100.030, as well as all other applicable criteria
contained hi DCC Title 19. The genera criteria are:
A. That the location, size. design and operating characteristics
of the proposed use are ,such, that it will have ial''
adverse impact on the property value, livability and,
permissible development of the surrounding area,
Consideration shall be given to compatibility in terms of
scale, coverage and density with the alteration of traffic
patterns and the capacity of surrounding streets and to any
other 'relevent impact of the proposed use.
Location. Tree Farm 4 is located north of Skyliners Road an property zoned UAR-10 and RR-
10 and located'' approximately 4,500 feet west of the Bend UGB and approximately 2,000 feet
east of Shevlin Park,
Size. Tree Farm 4 i 109.5 acres in size and is west of Tree Farms 1 2 and 3, Tree Farm 4
would be developed ,ith 20 acres of residential lots, 87.7 acres of open space, and 1.7 acres of
road right-of-way.
Operating Ch racterist€c , The proposed ten residential hats, in Tree Farm 4 would be
clustered near the northeast corner of the chaster/PUD and in the north -central part of The Tree
Farm on higher, relatively level ground. All lots would' have frontage on Golden Mantle Loop, a
private road developed to the county's private local road standards. Golden Mantle Loop would
connect with Ridgeline Drive northeast of Lots 21 and 30 in Tree Farm 2, and would connect
with Tree Farm Drive -- the primary PUD road that intersects with Skylin rs Road -- west of Lots
2 ` and 26 in Tree Farm 3. The applicant proposes to develop Tree Farms 1, 2 and
concurrently to provide access from Skyliners Road for all lots in those developments.
The tentative plans show the private roads will be constructed primarily on the central ridge,
thus minimizing steep road cuts and grades. A gated temporary emergency access road would
extend from the southern terminus of Sage Steppe Drive in Tree Farm 1 south across the
adjacent Miller Tree Farm property to Crosby Drive in the Bend UGB. This secondary access
would be in place until the adjacent Miller Tree Farm property is developed with paved streets to
which Sage Steppe Drive could connect. Sage Steppe Drive would be stubbed at the northern
boundary of Tree Farm 1 to provide a future road connection to the adjacent Rio Lobo property
to the north. The applicant proposes that each dwelling would be constructed within a
designated building envelope, would be served by an on-site septic system, and would receive
water from the City of Bend, Avon ater Company, or one or €-nore groundwater wells.
The €-najority of Tree Fara 4 (87.7 acres) would be set aside as permanent open space. The
public would have access to this open space through a coil!onatorta permanent trail
easement on the primary, trails within The Tree Farm and a license granted by The Tree Fenn
HOA for use of trails within the residential lot areas in Tree Farm 4. The path and trail system
would connect ,rith trails in Shevlin Park and the DNF to the west and southwest.
Tree Far4, 247 -14 -000248 -CU, 247-14-O 0249 -TP" Page 74 of 117
Compatibility. This criterion requires the applicant to demonstrate Tree Farrn 4 will have
"minimal adverse impact on the property value, livability and permissible development of the
surrounding area" considering "scale, coverageand density," "alteration of traffic patterns and',
the capacity of surrounding streets;" and "any other relevant impact of the proposed use.„
1. Scale, Coverage and Density. The applicant has proposed five cluster!PUDs for The Tree
Farm in order to provide a transition area between urban and urbani able lands to the east and
Shevlin Park and public and private forest lands to the west. The configuraton of The Tree
Farm would cluster most of the dwellings in the UAR-10 Zone, limit residential development to
100 acres (fifty 2 -acre lots), and preserve almost 423 acres in permanent open space. The
overall density of The Tree '''Farm would be one lot per 10 acres, similar to The Highlands at
Broken Top PUD located across Skyliners Road, The applicant proposes that each residential
lot would have a designated building envelope in which the dwellings would be built, with the
rest of the residential lots retained in native vegetation.
Opponent Rio Lobo asserts the proposed configuration of The Tree Farm will negatively impact
future development of its adjacent 376 -acre UAR-°i 0 zoned parcel because it will not provide a
public road from Rio Lobo's' southern boundary to Skyliners Road to facilitate through traffic
from Rio Lobo's property, and because most Tree Farm dwellings' would be clustered along or
near Rio Lobo's southern boundary with only one road connection provided along that
boundary. As discussed in the findings below, the Hearings Officer has found the applicant is
not required to dedicate a public road between the Rio Lobo property and Skyliners Road to
facilitate through traffic for Rio Lobo, and The Tree Farm configuration will not preclude Rio
Lobo from developing its property at urban or urban reserve densities in the future.
LandWatch and other' opponents argue the site for Tree Farm 4 is not suitable' for the proposed
cluster/PUD considering irnpacts on wildlife habitat and the risk of wildfire. As discussed in the
findings above, incorporated by reference herein, the Hearings Officer has found the applicant
has failed' to demonstrate the site for Tree Farm 4 is suitable for the proposed cluster/PUD
considering wildlife habitat and wildfire risk. For the same reasons, l find the applicant has not
demonstrated The Tree Farm will be compatible with Shevlin Park and the public and priva e
forest lands to the west considering wildfire risk, and therefore it does not satisfy this criterion.
2. Traffic Patterns and Street Capacity, As discussed above, the Hearings Officer has found
from the applicant's traffic study, and the lack of any recommendations from the city or county
for additional right-of-way or road improvements, that traffic generated from the entire Tree
Farrn developrernt will not cause affected transportation facilities to operate below acceptable'
levels of service, and the Tree Farm 4 site will be suitable for the proposed cluster/PUD
considering the adequacy of transportation access. For the same reasons, 1 find Tree Farm
will have minimal if any adverse rpacts on property value, livability and permissible
development of the surrounding area considering traffic patterns and street capacity.
For the forego
in
g'
reasons, the Hearings Officer find
s Tree Farm 4 satisfies this criterion.
B. That the site planning of the proposed use will, as far as
reasonably possible, provide an aesthetically pleasing and
functional environment to the highest degree >consistent with
the nature of the use and the given setting.
FINDINGS: The design of Tree Farm 4 includes two -acre residential'' bats clustered near the
northeast corner of the cluster/PUD and in the north -central part of The Tree Farm and well
away from Skyliners Road. The residential lots would be located atop the central ridge, with all
Tree Fara 4, 247` -14 -00024$ -CU, 247-14-- 249 -TP
Page 75 of 117
of the remaining acreage, except the road rights-of-way, permanently preserved as open space.
Existing vegetation in the open space tracts and on the residential lots outside of the designated
building envelopes would be retained except where removal is necessary for fire fuel treatments
or to enhance wildlifehabitat. The applicant proposes to create a system of paved multi -use
paths and recreational trails within The Tree Farm that would connect will the existing trail
network in Shevlin Park and the DNF to the west. The cluster/PUD would have a system of
public and private roads that generally would follow the existing terrain to minimize road cuts
and steep slopes. The road system would include a gated temporary emergency access road
from Tree Farm 1 south to Skyliners Road through the adjacent Miller Tree Farm property.
The Hearings Officer finds the site planning for Tree Farm 4 will provide an aesthetically
pleasing environment for cluster/PUD residents and for the general public. Based on my site
visit observations. 1 find the Tree Farm 4 dwellings would be substantially screened from
Skyliners Road by existing topography and vegetation. Most of Tree Farm 4 would remain in a
natural state. Roads and trails would provide a functional circulation system for residents and
guests, and the property's proximity to the Bend UGB would allow easy access to schools and
other urban uses. Finally, l;, have found that with imposition of conditions of approval described
above, all necessary facilities and services will be available to residential lots in Tree Farm 4.
For the foregoing reasons, the Hearings Officer f
nds Tree Farm 4 satisfies this criterion.
C. That if the use is permitted outright in another zone, there is;
substantial reason for locating the use in an area €here it is
only conditionally allowed, as opposed to an area where it is
permitted outright.
FINDINGS: : The Hearings Officer finds no other zones allow a reside
permitted
use.
ntial PU
D as an outright
That the proposed use will be consistent with the purposes of
DCC Title 19, the Comprehensive Plan, Statewide Goals and
any other applicable statutes, ordinances or policies.
FINDINGS: The Hearings Officer has found the purpose statement for the UAR 10 Zone in
Section 19.12.010 does not constitute an approval criterion for quasi-judicial land use
applications. Section 19.04.020 identifies several purposes for Title 19. including providing the
principle means for implementing the Bend Area General Plan, and providing a means of
classifying, designating and regulating development in the Bend urban area. The purpose
statement uses a number of aspirational terms, such as to "encourage," "conserve" and
"facilitate" various goals for the Bend urban area. For these reasons, the Hearings Officer finds
the Title' 19 purpose statement does not contain applicable approval criteria for Tree Farm 4
Compliance with the applicable administrative rules is addressed in the findings above.
Compliance with applicable comprehensive plan policies is addressed in the findings below.
have found the Statewide Land Use Planning Goals are not directly applicable to the applicant's
proposal. Finally, compl€once with Title 19 is the finthngs above and below.
For the foregoing reasons, the Hearings Officer finds Tree Farm 4 satisfies, or with imposition of
the conditions of approval described above will satisfy, all UAR-10 Zone conditional use
approval criteria.
Tre
4, 247`; -14 -.00248 -Cts, 247x14- O0249 -TP Page 76 of 11
PUD S T`A NDA
4.
RDS
Chapter 19.104, PlannedUn
5
ecti
on 19.104,010,
it'Develb
P
urpose
rnen<
The purpose of planned, unit development approval is to allow and to
make 1possible greater variety and diversification in the relationships
between buildings and open spaces in planned building groups,
while ensuring compliance with the purposes and objectives of the
various zoning regulations and the intent and purpose of DCC Title
19.
FINDINGS: As, discussed above, unless the text or context of a purpose statement indicates
otherwise, such statement does not establish approval standards for quasi-judicial and use
applications. The Hearings Officer finds use of the terms "make possible, ensuring
compliance," and "intent and purpose" indicates the PUD purpose statement is aspirational and
therefore does not establish approval criteria for Tree Farm 4.
Section 19 104,040, Minimum Size for Planned Unit Developments
No application shall be accepted for an area of less than five acres
in any R zone, or for an area of ess than four acres in any other
zone.
FINDINGS: Each Tree Farm development in
therefore satisfying this standa
rd.
Section 19.1104.070, 5
u€ding
tandard
Tree Parr
s for Ap
4 is at leas
proal'
04 acres in size,
In granting approval for planned unit' development, the Hearings
Body or Planning Director shall be guided by the following
Whether applicant has, through Investigation, planning and
programming, demonstrated tl e soundness of the proposal
and an ability to carry out the project as proposed, and
whether the construction shall begin wilt lin six months of the
conclusion of any necessary action by the County, or within
such longer period of time as may be established by the,
Hearings Body or Planning director.
FINDINGS: The Hearings Officer finds that read in the context of the rest of thus paragraph, the
term "soundness" connotes, the feasibility financial and physical — of developing The Tree
Farm and Tree Farm 4. The applicant's burden of proof states, and the Hearings Officer agrees,
that the applicant has demonstrated the soundness of its proposal through its tentative plans,
detailed narrative, will -serve letters from utilities and the City of Bend, the city's water analysis,,
the septic feasibility analysis, and the background of the development team. The team includes
several experienced developers such as Brooks Resources, and Slogl ner TWS, LLC, whose'''
members include Michael Tennant, Ron White, and Kirk 'Schu€eler, each with many years of
successful local development experience1 ars aware Brooks and Tennant together developed'
NorthWest Crossing.
Tree Fara 4, 247 -14 -000248 -CU, 247>-14-00024 -TP Page 77 of 117
The burden of proof states the applicant's intent is to initiate development of Tree Farms 1, 2
and 3 i€ €r ediat&ly upon gaining land use approval. However, because of the size of The Tree
Farm, the applicant has requested approval to commence construction of Tree Farms 4 and 5
two years after commencement of construction for Tree Farms 1, 2 and 3. Accordingly, < the
Hearings Officer' finds the applicant will be required as a condition of approval to complete all
conditions of approval' and appy for final plat'' approval from the Planning division for Tree
Farms 4 and 5 within four years of the date this decision becomes final, or obtain an extension
in accordance with the provisions of Title 22. vv$ith imposition of this condition of approval, 1 <find
the applicant's proposal satisfies this criterion;
Whether the proposal conforms with the general plans of the
County in terms of location and general development
standards..
FINDING: The Hearings Officer finds Tree Farm 4 is proposed for land designated and zoned
for residential development and in which residential clu€ster/PUDs are permitted'' conditionally. In
addition, as discussed in the findings below, l have found Tree Farm 4 is, consistent with
applicable plan policies. Therefore, 1 find Tree Farm 4 conforms to the city and county
comprehensive plans.,
Whether the project wiil accrue benefits to the County and the
general public in terms of need, convenience, service and,
appearance sufficient to justify any necessary exceptions to
the regulations of the zoning and subdivision ordinances.
FINDINGS: The applicant has req
The Tree Farm and Tree Farm 4:
uested exceptions to the following
1 . two -acre residential lot size rather than the five -acre
18.60.060 or the ten -acre minimum lot size under Section 19
2. thirty-foot
19.12.€00;
3.
minimu
.12.050:
front yard setbacks rather than the 'fife -foot front ya
ess than fifty fee
17.3
6.180;
redu
19.12.0
of
stye
ction in the minin-€ur
50 for Lot 1 in Tree Farm
et fronta
g
e for Lot
in Tree Fara€
stand
ards applicable to
lot size under Section
d setback under Section
as required by Section
lot width and street frontage standard
5, no street trees rether than street trees as required by Section 19.76.0
6. no introduced' landscaping or maintenance thereof;
7, eight-foot-wid
required by Sect
e bicycle and pedestrian
ion 19,104,080(F); and
8
under Section
multi -use paths rather than ten -foot wide
paths as
8. no road/bicycle path connections at 400 -foot intervals along The Tree Farm" s borders with
adjacent Rio Lobo and Miller Tree Farm properties.
Tree Farm 4, 247--14-000248-CLE, 247 -14 -000249 -TP
Page 78 of
The ap
plicant argues The Tree Farr
county
and the general public
and Tree
Farm 4 wil
crue
he
olio
ing
benefits to the
1, creating two -acre residential lots rather than five- or ten -acre ots and clustering lots on 100
acres of The Tree Farm€, and 20 acres of Tree Farm 4;
2. preserving over 87 acres
Tree Farm as a whole;
of open
pa
ce in Tree Farre 4 and 423 acres of open space in The
3. making the PUD roads accessible to th
4. creating
licenses,
the DNF;
e public through pu
blic access easements;
a network of trails accessible to the public through public access easements and
nd link ng The Tree Farm and Tree Farm 4 to the trail systems in Shevlin Park and
5, minimizing impacts to habitat in the Tumalo winter deer range through small, clustered
residential lots, large open space tracts, preservation of most native vegetation, and reduction in
fire fuels;
6. providing a do
The Tree Farm;
estic
vater
y
em fo
the d elling
s
nd
fire hydrants to aid fire
protection on
7 designing and managing The Tree Farm and Tree Farm 4 as a "Fire 'else Community" tc
reduce wildfire risk;,
8. configuring The Tree Farm and Tree Farm 4 to establ
area between urban and urbanizable lards to the east a
public and private forest lands to the west; and
h a permanent low-density transition
9. providing 50' new dwellings to a
Bend.
d
nd Shevlln Park and the extensive
dress the demand for new
esites on the west sid
e of
LandWatch again argues the analys€s required by this section should not compare tl e
applicant's proposed cluster/FUD with alternative subdivision configurations such as a
traditional subdivision with 10 acre lots and dwellings spread throughout the 533 -acre property,
in his December 11, 2014 letter, Paul Dewey states.
'There are apparently only five lots, so the current alter ative w i ld be five
houses. Though the zoning allows a house on, a 10 acre parcel, there is no basis
to conclude that 50 10 acre lots can be created here." (Underscored emphasis
added.)
As discussed above, the Heanngs Officer has found there are reasons to conclude a traditional
subdivision with ten 10 acre lots could be approved on each of the five Tree Farm legal' lots,
including the fact that the county approved a very similar development, The highlands at Broken
Top, immediately south of The Tree Farm with 37 mostly ten -acre lots and large open space
areas on land zoned UARy10 that is close to the DIF, In addition, traditional 10 -acre lot'
subdivisions in the UAR-10 and RR -10 Zones do not require conditional use approval; but rather
are subject only to the subdivision standards in Title 17. For this reason, I find there is nothing;,
improper In comparing the proposed cluster/PUDs to the alternative of a traditional subdivision
tree Fang 4, 247-14-000248- U, 247.14-0002
49 -TP
Pag
of 11'7
when weighingthe
exceptions.
benefits of
he proposed Tree Farm devei
opn
ent again
t the requested
The Hearings Officer finds many of the above-described benefits of developing the subject
property with cluster/PUDs justify the requested exceptions. In particular, I find the requested
two -acre lot sizes, the clustering of dwellings, the preservation of large swaths of open space in
the WA Zone, and the creation of a trail system connecting with trails in Shevlin Park and the
DNF will provide significant benefits to the corrr€€nity. For these reasons, I find Tree Farm 4
satisfies this criterion.
Whether the project will satisfactorily take care of the traffic it
generates by means of adequate off street parking; access
points, additional street right of way and improvements and
any other traffic facilities required.
FINDINGS: : The Heanngs Officer has found on the basis of the applicant's traffic study that the
addition of traffic generated by The Tree Farm wi I not exceed the capacity of affected
transportation facilities, and no additional' right-of-way, or improvements are required. I also have
found the intersection of Skyliners Road and Tree Farm Drive will have adequate sight distance
in both directions, and that the proposed gated secondary access road will provide an
appropriate second point of access for evacuations and emergency vehicles. No on -street
parking will be allowed; all off-street parking will be accommodated on each homesite. For these
reasons, I find Tree Farm 4 satisfies this criterion.
E. Whether the project will be compatible with adjacent
developments and will not adversely affect the character of
the area,
FINDINGS: The Hearings Officer has addressed virtually identical criteria in the findings above
under Section '13,128.015(3)(B), Based on those findings, incorporated by reference herein,
find Tree Farm 4 satisfies this criterion with respect compatibility with the rural character of the
area, and with adjacent property to the north, east and south. However, have found that in the
absence of an adequate wildfire plan the applicant has not demonstrated The Tree Farm or
Tree Farm 4 will be compatible with Shevlin Park and forest lands to the west.
Fl
N
DIN
GS:
Whether the project will satisfactorily take
water needs consistent with the Bend Ur
Plan.
care of sewer and
ban Area General
Sewer. The applicant proposes that each dwelling be served by an on-site septic system, and
provided as Exhibit "" to the Tree Farm 4 burden of proof a Preliminary Soils and Percolation
Investigation prepared by FEI Testing and Inspection based on the analysis of 27 test pits and
sample percolation testing. The study found the soils The Tree Farm and Tree Farm 4 are
sufficiently deep (18 -60 -inches) -and well -drained to accommodate either standard -or -capping -fill
on-site septic systems on each of The Tree Farm lots. The Hearings Officer finds that as a
condition of approval the applicant will be required to obtain from the county an approved septic
site evaluation for each Tree Farm 4 lot.
ree Farm 4, 247 -14 -000248 -CU, 247 -14 -000249 -TP Fag
e80of117
Water; The applicant proposes to provide domestic water to each dwelling in The Tree Farm
through one of three methods. (1) extending and connecting to city water service; (2) extending
and, connecting to service from Avion Water Company; or (3) through one or more groundwater
wells. The applicant provided as Exhibit "E"to its burden of proof a Water System Analysis, and
as Exhibit ,sG' to the burden of proof a will-serveletter from the City of Bend indicating the city's
water system has sufficient capacity to serve the 50 hornesites in The Tree Farm. The applicant
also submitted as Exhibit `NI" to its burden of proof well logs on surrounding properties showing;,
water is available. The applicants burden of proof also indicates there is an existing quasi-
municipal well on the adjacent Miller Tree Farm Property to the east.
The applicant did not submit `>a will -serve letter from Avion. Therefore, the Hearings Officer has
found that if the applicant elects, or is required to, provide water to The Tree Farm through
means other than extension of city water service, the applicant will be required as a condition of
approval, and before submitting for approval the final plat for any Tree Farm development, to
provide to the Planning Division a water system analysis performed by a registered professional
engineer and demonstrating, water service from the >alternative domestic water source(s) will
provide to each residential lot water pressure of at least 40 psi during peak demand periods and
at Nast 20 psi residual pressure, as well as fire flow of at least 2,000 gpm.
Based on the foregoing findings, the Hearings Officer finds Tree Farm 4 satisfies, or with
imposition of the conditions of approval described above will satisfy, this criterion.
G. A planned unit development' shall rest be approved in any R
zone if the housing density of the proposed development will
result in an intensity of land use greater than permitted by the
Comprehensive Plane
FINDINGS: S: The proposed density of each Tree Farm development including Tree Farm 4 will
not exceed one dwelling per ten acres, consistent with the general density permitted in the RR-
10 and UAR-10 Zones, therefore satisfying this criterion,
Section 19 104 080, Standards and Req
uirements
guest for a planned unit> development is dependent
bmisron of an acceptable plan and satisfactory
be carried out The following minimum
nts shall apply;
Approval of a re.
upon the su
assurance that it
standards and requirer~
A. A dwelling use permitted i
planned unit development.
FINDINGS; The applic
in the UAR-10 Zone.
nt prop
Os
n any zone may be permitted>.in a
es ten residential lots for singlewfmily d +uellings, a use allowed
A manufactured home may be permitted in a planned unit
development. However, manufactured home parks shalt'' not,,
be allowed in any commercial or industrial zone.
FINDINGS: The Hearings Officer finds this criterion is not applicable because the applicant
does not propose any manufactured homes or manufactured home parks.
Tree Farre 4, 247-14-0 24 -CU, 247 -14 -000249 -TP
Page
of 117
C. Developments which either provide for or contemplate private
streets and ways and common areas whichwill be or are
proposed to be maintained by the owners of units or ots
within a development must organize and maintain an owners'
association. The owners' association shall consist of all, the
owners of units or lots within the development ' and
rnemership In the ,association must be required of all
owners; adopt and record bylaws as provided by ORS 94.625;
adopt bylaws that contain the provisions required by ORS
94.635; and have the power to create a''ilen upon the unit or
lot for services. labor or >material lawfully chargeable as
common expenses as provided in ORS 94,789. The
association's power to create such a lien shallI exist whether
or not the property is subject to the Oregon planned''
Community' Act (ORS 94.565 through 94.785.)
FINDINGS- The Tree Farm iI1 include private roads, a public road, multi -use paths,, recreation
trails, and open space that w#II be owned and managed by an HOA. The applicant's burden of
proof for Tree Farm 4 states at HOA will be established, organized and €na€ntined pursuant to
applicable provisions of ORS Chapter 94. As discussed in the findings above, the applicant
submitted as Exhibit '°L' to its burden of proof a sample set of CC&R's and HOA bylaws that will
serve as the template' for The Tree Farm CC&R's and HOA bylaws. The Hearings Officer finds
the applicant will be required as a condition of approve to record CC&Rs and HOA bylaws prior'
to s bmitting for approval the final plat for any Tree Farm development. I find that with
imposition of this condition of approval, Tree Farm 4 will satisfy this criterion!
DI.
If the property is not subject to the Unit Ownership Law, the
association shall also create, by contract, the right,to claim a
lien upon any unit or lot for services, labor or material
chargeable as common expenses. This lien may be created
by covenants between the association and the property
owners and shall supplement the lien created by DCC
19.104.090(C) and require all owners of units or lots within the
development to consent to and pay the reasonable value of
services, labor or material expended by the County for
common expenses where such county expenditures, are
made because the owners or the owners' association does
not provide the necessary services, labor or material'' for
comm
on expenses.
FIND : The applicant's > burden of proof states the statutory references in this criterion no
longe. are correct because the Oregon Unit Ownership Law was substantially amended in 1977
and 1981 and renamed the "Oregon Condominium Act." (1977 Oregon Laws Chapter 484; 1981
Or Laws Chapter 841.) The burden of proof notes that in 1989 the Oregon Condominium Act
was relocated to OR ' Chapter 100. Because of these changes, the applicant argues, and the
Hearings >Officer agrees, that The-'' Tree Farm and Tree Farm 4 are not subject -to -the Oregon
Condominium Act (ORS 10€9.105 to 100.910), and therefore Section 19.104 08 (C) and (D) are
applicable to this development.
E. Streets and roads in planned unit development designated
developments shall be public roads and ways developed to
Tree Farm >:4, 247-14-000248-C
U, 247,,14-00€ 249 -TF
Page
2 of 117
county standards or be private roads of a minimum 14 feet
wide paved surface for one way traffic, minimum 20 feet wide
paved surface for two way traffic, and parallel parking as
permitted shall require minimum additional eight feet of width
for each side of parking, if pedestrian walkways or bikeways
are included in the road, an additional five feet of pavement
width on each side of the roadway shall be provided and
striped to separate such use from motor vehicle traffic and
parking. In addition to these requirements, the Panning
Director or Hearings Body may specify other requirements
including, but not limited to increased or decreased
pavement width.
FINDINGS: The applicant proposes that the private road in Tree Farm 4 will be improved with
20 feet of pavement, and no on -street parking will be permitted. All private Tree Farm roads will
be owned and maintained by The Tree Farm HOA but will be subject to public access
easements. As discussed in the findings above, the applicant proposes to provide separate
pedestrian/bicycle paths according to the plan included in the record as Exhibit "C' to the
applicant's burden of proof. The pedestrian/bicycle path will be included in a 10 -foot -wide space
on the southern portion of Tree Farm Drive within Tree Farm 4, and on separate eight- and ten -
foot -wide paved pathways running parallel to the rest of The Tree Farm roads,
County staff and opponent ',Rio Lobo argue that under Section 1736020(B) the applicant is
required to dedicate and improve a public road between the southern boundary of the Rio Lobo
property and Skyliners Road to provide for through traffic from future development of the Rio
Lobo property. However, as discussed in the findings below, incorporated by reference herein,
the Hearings Officer finds that section does ;,not require dedication of a public road in the
circumstances presented here,
For the foregoing reasons, the Hearings Officer fi
nds Tree Farm 4 s
atisfies this
criterion.
F. Pedestrian walkways, and,; bikeways shall be provided, for
adequate pedestrian and bicycle traffic, and shall connect to
any adjacent existing or planned sidewalks, bikeways, access
corridors, or public trails. Off street pedestrian walkways and
bikeways shall' be at least 10 feet in width to accommodate
two way traffic and shall be constructed with portland cement
or asphaltic concrete to county standards, except as varied
by the provisions of DCC 19.104 080 or by the Planning;
Director or Hearings Body.
FINDINGS r The applicant proposes a system of paved multi -use paths and natural surface
recreation trails throughout The Tree Fara and within Tree Farm 4 designed to accommodate
pedestrians and bicycles. According to the trail plan, Exhibit "C" to the appl'icant's burden of
proof for Tree Farm 4, four types of trails are proposed: (1) main connection trails; (2);,;
neighborhood trails, (3) proposed recreation/mountain bike trails; and (4) existing perimeter
trails. The applicant proposes that the main connection trails would consist of ten -foot -wide
paved multi -use paths paralleling Tree Farm Drive from its intersection with Skyliners Road to
the point where the path splits to go west to Shevlin Park. The neighborhood trails would extend,
from that point east to the Golden Mantle Loop/Ridgeline Drive intersection and along the rest of
Tree Fara 4, 247-14-0 248 -CU, 14.000249 -TP Page 83 of 11
the roads in The Tree Farm. These paths would be paved tee a width of eight feet and would
roughly parallel the internal road network in The Tree 'Farm»
The applicant has requested an exception to the ten -foot width requirement for the multi -use
neighborhood paths for the reason that they will serve a lower -use function for
bicycle/pedestrian access within the homesite area. The applicant notes there are only 50 lots in
The Tree Farm, so traffic volume on the neighborhood paths would be low.In addition, the,
applicant suggests, and the Hearings Officer agrees, that most of the trail use near The Tree
Farm homesites will be by residents. Finally, the applicant notes the proposed paths will be
relatively flat and will have adequate sight distance to avoid the opposite -direction traffic
conflicts that ten. -foot wide paths are intended to address. As discussed above, I have found this
requested exception ''is justified by the significant con n€ €unity{, '''benefits from the proposed
ciuster/PUD,
Forth
Fl
N
e foreg
oir
reasons, the H
Barin
9
Officer find
s Tree Farm 4 satisfies this criterion
G. Ali utility facilities shall be installed
accordance with County standards.
DINGS: The applic
criterion.
nt proposes that al
new utilities will be install
and
erground and in
ed tnderground. satisfying
The design of all planned' unit development projects shall
provide direct access for all units and lots to open space
areas and facilities. Open space areas and facilities include
such things as landscaped areas, natural areas, golf courses,
and other recreational facilities, but do not include streets,
sidewalks, bikeways, access corridors or trails.
FINDINGS: The tentative plan for Tree Farm 4 shows each residential lot will have direct access
to the proposed open areas throughout The Tree Farm via the network of multi -use paths and
recreation trails, therefore satisfying this criterion.
F
ND
A statement must be submitted relative to the solar access to
b
ep
rnvided by the plan
ned
unit development.
NGS: The applicant 's,>burden of proof includes the following statement on solar access.
'Ai! of the lots rif i i The Tree Farm will be at least 2 acres in size with setbacks
on all lot lines of no less than 20 feet. This alone will provide ample solar access
to the lots. However, many of the open ridge top lots in Tree Farm 1, 2 and will
have nearly ideal solar access."
30 The proposed recreation/mountain biking trails would be soft -surface trails developed to the mountain
bike trail standards in Section 17.48.140(E). -these trails would connect with the trail network in Sheviin
Park. The applicant's burden of proof states the existing perimeter trails within the western open space
tracts are composed primarily of old roads that will be converted to trail use and will have native dirt
surfaces.
Tree Farr 4, 247-`14.0 248 -CU 247 -14 -000249 -TP
Page 84 of 11
The Hearings Officer finds that the size and configuration of the ten T
can be sited on each lot in compliance with
will assure a dwelling
stand
and under Sectio
ns 18.6
0 040(0) a
rid
9,12.050(F).
ree Farm 4 residential lots
the required solar access
For the foregoing reasons, the Hearings Officer finds Tree Farm 4 ,satisfies, or with iposition of
the conditions of approval described above Will satisfy, all <applicable urban area PUD
standards.
. Title 17o
f the Deschutes County Cod
he ubdivisio /Partition Ordinance
SUBDIVISION STANDARD
1, Chapter 17.16, Approval of Subdivision Tentative P
Development Plans
Fl NDl
N
GS:
Section 17.16,100 Required Findings for
pproval,
ans and 'faster
A tentative plan for a proposed sdbdivisibrs shall not be approved
unless the Planning ,,Director or Hearings Body finds that the
subdivision as proposed or modified will meet the requirements of
this title and Titles 18 through 21 of this code, and is in compliance
with the comprehensive plan. Such findings shall include, but not be
limited to, the following
A, The subdivision contributes to orderly development and and
use patterns in the area, and provides for the preservation of,
natural features and resources such as streams, lakes,
natural vegetation, special terrain features, agricultural and
forest lands and other natural resources.
Orderly Development and Land Use Patterns in the Area, The applicant proposes to develop
Tree Farm 4 as cl€uster6PUD with an overall density of one dwelling per ten acres as permitted in
the RR -10 and UAR-10 Zones. This density is the same as that in The Highlands at Broken Top
P1 D located south across Skyliners Road. However, unlike that development with 37 ten -acre
lots and dwellings scattered throughout' the 390 -acre site, Tree Farm 4 would have 2 -acre
residential lots clustered in the north -central part of The Tree Farm in order to preserve a large
tract of open spaceTree Farm dwellings would be sited within designated building, envelope,
retaining the rest of the lots in native vegetation. As discussed above, the applicant intends The
Tree Farm to provide a permanent transition between urban and urbanizable land to the east
and Shevlin Park and vast public and private forest lands to the west. The also applicant intends
that The Tree Farm never will be annexed into the Bend UGB or redeveloped, >.PUD roads Would`>
connect s, ith Skyliners Road, and eventually with roads developed on the Rio Lobo property to
the north and the Miller Tree Farm property to the east. As also discussed above, the Hearings
Officer has found affected transportation facilities Will continue to operate at acceptable levels of
service w€th the addition of traffic generated by The Tree Farm€. Each residential lot will be
served by n on-site septic system and domestic water from the City of Bend, Avian, or
groundwater wellsFor these reasons, l find Tree Farm 4 will contribute to orderly development
and land use patterns in the area.
Tree Fara 4, 24i -14 -000248 -CU, 247 -14=000249 -TP
Page 85of117
Presenfation of Natural Features and ResourcesNatural features and resources on Tree
Farm 4 consist of topography, native vegetation, and wildlife habitat. As discussed above, the
applicant has proposed cluster/PUDs in order to maximize open space and to preserve native
vegetation. Residential lots will be >located an relatively level >.land on or near the central ridge on
the property, minimizing the need for grading and filling, and PUD roads will follow the site's
existing contours minimizing the need for steep road cuts or slopes. As also dliscussed above,
the applicant proposes to protect the deer winter range habitat on The Tree Farm and Tree
Farm 4 by clustering most of the dwellings outside the winter range, creating gaps between
clusters of dwellings where there are existing deer migration corridors, and preserving native
vegetation except where removal or modification is necessary for fire fuel 'treatments or to
enhance wildlife habitat. However, as discussed in the findings above, the Hearings Officer has
found the applicant failed to demonstrate The Tree Fara and Tree Farm 4 will be compatible
with Shevlin Park and forest lands to the west because its wildfire plan is inadequate. l'' also
have found the applicant failed to demonstrate The Tree Farm and Tree Farre 4 will adequately'
protect winter deer range if more aggressive fire fuel treatments, such as clearing of slopes on
the lots and/or in the open space tracts, are required to reduce the risk of fire for ridgetop
dwellings such that Tree Farm 4 is suitable for the proposed;;, cluster; PUD'' and is compatible with
surrounding lands. For the same reasons, I find the applicant has not demonstrated Tree Farm
4 will provide for the preservation of natural features and resources.
B. The subdivision will not create excessive demand on public
facilities and services, and utilities required to serve the
development.
FINDINGS: The public facilities and services required by Tree Farm 4 include sewage
treatment, water, roads, electricity, natural gas, telephone and cable service, and police and fire
protection. Each of these is addressed below,
Sewage Treatment. The applicant proposes to serve the residential lots with individual orf -site
septic systems. The applicant submitted as Exhibit `F" to the Tree Fara 4 burden of proof a
septic suitabiity study showing the soils on Tree Farm 4 are suitable for installation of on-site
septic systems. The Hearings Officer finds the applicant will be required as a condition of
approval to obtain an approved septic site evaluation for each residential lot in Tree Farm 4 prior
to final plat approval,
Water. The applicant proposes to provide domestic water to the residential lots in Tree Farm 4
through one of three options: (1), extending and connecting to City of Bend water service os
proposed in the applicant's Preliminary Utility Man, (2) extending and connecting to Avion Water
Company facilities; or (3) utilizing;, one or more individual wells on The Tree Farm property
and/or the adjacent Miller Tree Farm property. As discussed in the findings above, incorporated
by reference herein, the Hearings Officer has found the city's water system will have adequate
capacity to serve the residential lots in Tree Farm 4, and with the water facilities proposed by
the applicant, including 12 inch and 24 -inch water mains and pressure pumps at each lot, the
city's water system will provide adequate pressure and ire flood at each lot. Therefore, I find
providing domestic water to The Tree Farm and Tree Farm 4 will not create excessive demand
on the city's water system, However, l have found that if the applicant does not obtain city water
service for The Tree Farm, it will be required as a condition of approval, and before submitting
for approval the final plat for any Tree Fara development, to provide to the Planning Division a
water system analysis prepared by a registered professional engineer, demonstrating whatever
alternate source of domestic water is chosen will provide each residential lot with at least 40 psi
Tre
Farm 4, 247-14-000248-C
U, 247-14-OOO249-T,P Page 86 of 11
of water pre
fire flow,
at peak
periods, 20 ps
es€dual water pressure, and a
eas
2,000 gpm for
Roads. As discussed in the findings above, incorporated by reference herein, the, Hearings
Officer has found from the applicant's traffic study that the addition of traffic generated by the 50
proposed dwellings for The ''Tree Farm will not cause any affected transportation facilities to
operate below acceptable levels of service at buildout,, and in the years 2017 and 2022 with the
addition of future traffic. Neither the road department nor the city identified the need for
additional right-of-way or improvements to affected transportation facilities.
Electricity. The applicant submitted a will -serve
Exhibit "G' to the Tree Farm 4 burden of proof.
letter from Pacific Power for electric service
Natural Gas. The applicant submitted a will -serve letter from Cascade Natural Gas for gas,
service in Exhibit "G„ to the Tree Farm 4 burden of proof.
Telephone. The applicant submitted a will -serve letter from CenturyLink for telephone, service in
Exhibit "G" to the Tree Farm 4 burden of proof.
Cable. The applicant submitted a will -serve
Exhibit 'G" to the Tree Farm 4 burden of proof.
Police. police protection will,
Fire Protection. Fire protect
September 2, 2014 comment
Larry Medina identified
er fror
B
end
Broadband for cable service in
be provided by the Deschutes County S
h
en
f.
on will be provided by the City of Bend Fire Department. In his
n the applicant's proposal, Deputy Bend Fire Chief/Fire Marshal'
a number of Oregon Fire Code (OFC) provisions applicable to The Tree
be suar€zed as follows:
Farm. These comments can
1. Standards for fire apparatus access roads. The OFC requires that fire apparatus access
roads: (a) extend within 150 feet of all buildings; (b) have an unobstructed width of at least 20
feet; (c) have unobstructed vertical clearance of at least 13 feet 6 inches; (d) be designed and
maintained with an all-weather surface tha can support vehicles' weighing 60,000 pounds; (e)
have a grade not exceeding 10 percent; and (f) if gated, have a "Knox Key Switch" operable by
the fire department. The Hearings Officer f rids the applicant will be required as a condition of
approval to design and construct all roads in Tree Farm 3 and the gated temporary emergency
access road in compliance with these standards.
2. Standards for fire protection water supplies. The OFC requires that The Tree Farm have
an approved water supply capable of supplying the required fire flow for fire protection to
buildings, the adequacy to be determined 'by an approved method." The OFC also requires that
the applicant provide documentation of adequate fire flow to the fire department prior to final
approval of the water supply system. The OFC states installation of fire hydrants along fire
apparatus access roads may be required by the fire code official. Finally, the OFC states that if
fire hydrants are installed they must be no farther than 400 feet apart;
As discussed in detail in the findings above. incorporated ' by reference herein, the Hearings
Officer has found the city's water supply analysis shows extension of and connection to its water
facilities can provide fire flow of 2,000 gpm at each residential lot, the minimum flow prescribed
by the city. In addition, the applicant's Preliminary Utility Ilan diagram, included in Exhibit "E" to
the Tree Farm 4 burden of proof, shows fire hydrants placed at 410 -foot intervals along all PUD
Far
4, 247.14-000248 CU, 247 14 -000249 -TP
Page 87 of 117
roads abutting the residential lots. As also discussed above, the Hearings Officer has found that
if the applicant does not secure city water service for The Tree Farm, the applicant will be
required as a condition of approval, and priorto submitting for approval the final plat for any
Tree Farm development, to 'provide to the Planning Division a water system analysis from a
registered professlonal engineer demonstrating the alternate water system will provide at each
residential' lot water pressure of 40 psi during peak periods, 20 psi residua water pressure, and
at least 2,000 gprn for fire flow.
3. Other fire service features. The OFC requires that each dwel'ling in Tree Fer€n'4 have an
address number placed on a monument, pole or other sign so that it is, plainly visible from the
private road. The Hearings Officer finds the applicant will be required as a condition of approval
to provide address numbers as required by the QFC'.
For the foregoing reasons, and with imposition of the conditions of approval described above,
the Hearings Officer finds Tree Farr€ 4 will not create excessive demand on public facilities,
services and utilities required to serve the development.
C. The tentative plan for the proposed subdivision meets the
requirements of Oregon Revised Statutes Section 92.090.
FINDINGS: ORS 92.090(1) states a new subdivision can only use the same name if it is a
continuation of an existing subdivision, with a sequential numbering system, and must either be
platted by the same party or have the consent of the previous party. The applicant is requesting
approval of five separate but interconnected ten -lot cluster/PUDs to be known as Tree Farms '1'
through 5, with the overall pro ect to be known as The Tree Farm. The Hearings Officer finds
this subdivision name plan con orms to Subsection (1) of the statute.
Subsection (2) of this statute equires that roads be laid out to conform with existing pats on
adjoining,, property, that streets and roads held for private use are clearly indicated on the
tentative pan, and that all reservations or restrictions relating to such private roads and streets
are set forth on the plat. The Hearings Officer finds there are no adjoining plats with which The
Tree Farm must conform. As d scussed above, Sage Steppe Drive is proposed to be dedicated
to the public in order to provide a future road connection with the undeveloped LIAR -zoned
parcels to the north. The remainder of the PUD roads would be private but would be subject to
public access easements. The Hearings Officer finds the applicant will be required as a
condition of approval to show all public easements on the final plat for Tree Farm 4. I find that
with imposition of this condition of approval, Tree Farm 4 will comply with Subsection (2).
Subsections (3), (4) and (5) of the statute
to Tree Farm 4,
rel'
fine
platting and therefore are not applicable
For subdivisions or portions thereof proposed within a
Surface Mining Impact) Area (SMA) zone under Title 18 of the
Deschutes County Code .
FINDINGS: The Hearings Officer finds'' this criterion Is not applicable because the subje
property is not located within a
'SIA Zone.
E. The su
Surveyo
bdivision name ha
r.
been ap
proved by the County
Tree Farm 4, 24.7 -14 -300248 -CU, 247-14-00 249 -TP Page
of 1
7
FINDINGS: Exhibit ;?„ to the Tree Farm 4 burden of proof indicates the proposed names for
The Tree Farm cluster/PUDs have been approved by the County Surveyor, therefore satisfying
this criterion.
Section 17.1 05, Access to Subdivisi
No proposed subdivision shall be approved unless 'it will be
accessed by roads constructed to County standards and by roads
accepted for rtahitenance responsibility by a unit of local or state
government This standard is met if the s bdi ision will have direct
access to an improved, collector or arterial, or in cases where the
subdivision' has no direct access to such a collector or arterial, buy
demonstrating that the road accessing the subdivision from a
collector or arterial meets relevant County standards and has been
accepted for maintenance purposes.
FINDINGS: Access to Tree Farm 4 will be from Skyl €hers Road, a designated county collector
road unproved to the county's collector road standards and maintained by the county, therefore
satisfying this criterion.
ce Section 17.16.1 5, Traffic
pact S
to
dies
Gu Wanes for Traffic Impact Studies
The following vehicle trip generation thresholds shall
determine the level and scope of transportation
analysis required for a new or expanded development.
Traffic Impact Analysis (TIA) If the
development or change in use will generate
more than 200 trip ends and 20 or more PM
peak hour trips, then a Traffic Impact Analysis
(TIA) shall be required . r
FINDINGS: The applicant subrnitted a traffic study prepared by Kittelson & Associates, included
in the record as Exhibit "H" to the burden of proof for Tree Farm 4. The traffic study was
submitted ' because the applicant's traffic engineer predicted traffic generated by the 50 dwellings
in The Tree Farm would generate over 400 trip ends. The traffic study, concludes traffic
generated by The Tree Farm will not exceed the capacity of affected transportation facilities at
buildout, or in 2017 and 2022 with the addition of other traffic from -the surrounding area. The
traffic study also found that no additional right-of-way or improvements are required, and neither
the road department nor the city indicated the need for addition right-of-way' or improvements,
Therefore, the Hearings Officer finds the applicant's proposal satisfies this criterion.
2. C
hapter 17.36, Doig
n Standards
Tree Far 4, 247=14 -000248 -CU, 247 -14 -000249 -TP
Page 89 of 117
Sectio
n 17,36 .0
20,Streets
The location, width and grade of streets shallbe considered'
n their relation to existing and planned streets, topographical
conditions,public convenience and safety, and the proposed
use of land to be served by the streets. The street system
shall' assure an adequate traffic circulation system for all
modes of transportation, including pedestrians, bicycles and
automobiles, with intersection angles, grades, tangents and
curves appropriate for the traffic to be carried, considering
the terrain. The subdivision or partition shall provide or the
continuation of the principal streets existing in the oining
subdivision or partition or of their property projection when,
adjnlraing property which is not subdivided, and such streets
shall be of "a width not less than the minimum requirements
for streets set forth in DCC 17.36.
FINDINGS: The applicant proposes to construct all Tree Farm roads in conformance with the
applicable county local road standards — i.e., the public local road standards for Sage Steppe
Drive, and the private local road standards for the private roads in Tree Farm 4. The proposed
road layout generally follows the topographical contours of The Tree Farm and Tree Farm 4,
and wall provide direct access to each proposed residential lot. Separate multi -use paths are
proposed along all new roads to provide adequate circulation for bicycles and pedestrians and
adequate separation from vehicular traffic, There are no principal streets in adjoining partitions
or subdivisions that require the continuation of those streets into Tree Farm 4. No alterations to
road layout or design were identified by the road department. For, these, reasons, the Hearings
Officer finds Tree Fara 4 satisfies this criterion.
Streets in subdivisions shall be dedicated to the public,
unless located in a destination resort, planned community or
planned or cluster development, where roads can be privately
owned. Planned devblo:•: cents shall include ubllc streets
where necessary to accommpdatepresent and, fa tes ,througl
traffic. (Emphasis added.)
FINDINGS: With the exception of Sage Steppe Drive, the roads in The Tree Farm would be
private roads as permitted for cluster/PUUDs. Sage Steppe Drive would have a dedicated b0> -foot
right-of-way to facilitate a future public road connection between the Rio Lobo property and
Skyliners Road or Crosby Road at such time as the Miller Tree Farm property is developed. The
applicant'' has proposed an interim gated secondary emergency access road from the southern
terminus of Sage Steppe Drive through the adjacent Miller Tree Farm property to Crosby Drive.
The applicant states ail private roads within The Tree Farm will' be subject to public access
easements to be shown on the final plats for The Tree Farm.-
''
in his January 6, 2015 letter on behalf of Rio Lobo, Mlles Conway states the applicant is offering only a
"temporary" public access easement over the system of Tree Farrn roads, and therefore The Tree Farm
HOA, which would own and manage the subdivision roads, could erect barriers to "through traffic' within
the `<subdivision. Mr. Conway is mistaken The applicant's burden proof for Tree Farm 4 makes clear the
public access easements for Tree Farm roads will be permanent. For example, the Tree Farm 1 burden of
proof states at page 54 that the private streets would have "public access to be dedicated with the_final
Tree Fara 4, 247-14-000243- U, 24 7 14 -000249 -TP
Page 9
0of'l17
In his August 28, 2014 comments on the applicant's proposal, George Kolb stated that
Paragraph (B) of this section requires the applicant to dedicate 60 feet of right-of-way for, and
improve to the county's public road standards, a public road from the northern'' boundary of The
Tree Farm to Skyliners Road, This argument also was made by Peter Russell and by Miles
Conway on behalf of opponent Rio Lobo. In his December 19, 2014 memorandum, Mr. Russell
suggested the applicant be required to dedicate to the public and improve to public road
standards all of Tree Farm Drive. the southern portion of Golden Mantle Loop, and all of
RidgelineDrive as the "primary access road" for The Tree Farm. Mr, Conway argued that this
paragraph requires the applicant to dedicate to the public not only to provide for through traffic
from development on the Rio Lobo property, but also to accommodate through traffic within The
Tree Farm itself.
Both Mr. Conway and Mr, Russell argue the language in Paragraph (B) provides no discretion to
deviate from the public road dedication requirement. The Hearings Officer disagrees. I find the
plain language of this paragraph makes dear the public road requirement is contingent on a
finding that such a road is "necessary to accommodate present and future through traffic." In his
December 30, 2014 memorandum, Jeffrey Condit argued the dedication of public road right -of-
way does not meet this "necessityn test.
+fir Condit argues a requirement that all PUD roads, and/or the proposed secondary access
road, be dedicated to the public would constitute an unconstitutional `'taking" under the Fifth
Amendment to the U.S. Constitution as interpreted in Nollan v. California Coastal Commission
483 US 825, 107 8 Ct 3141, 97 L Ed 2d 677 (1987), Dolan v. City of Tigard, 512 US 374, 114
Ct 2309, 129 L Ed 2d 304 (1994), and Schultz v. City of Grants Pass, 133 S et 2586, 186 L Ed
2d 697 (2013). Specifically, he argues such a requirement would not meet the, "essential
nexus/roughly proportional" test articulated in the above cases. He also asserts the county
cannot require public road dedication through the adjacent Miller Tree Farm property because
the county has no jurisdiction over that propertyIn response, LandWatch argues the Miller Tree
Farm property is subject to the county's jurisdiction because the applicant proposed the
secondary emergency access road across that property, and Miller Tree Farm owns both the
adjacent property and The Tree FarmThe Hearings Officer disagrees. The applicant proposed
off-site road improvements to which the off-site property owner consented. I find that proposal
does not confer jurisdiction on the county to require public dedication and improvement of that
off-site road without the off-site property owner's consent. At most, I have authority to deny an
application if I find an off-site road improvement were required for the proposal to meet the
applicable approval criteria and no such off-site improvement were proposed,
Even assuming for purposes of discussion that the Hearings Officer has jurisdiction to require
the public dedication of the proposed secondary access road, I agree with Mr. Condit that such
a requirement — or a requirement to dedicate to the public the Tree Farm Roads identified by
Mr. Russell ww does not have a sufficient nexus with, and is not roughly proportional to, traffic
impacts from The Tree Farm development. I agree with Mr. Condit's analysis, set forth in his
December 30, 2014 letter as follows;
'A public street is
be generated by developme t oflie Rio Lobo property under the existing UAR-
ecessary to accommodate the through traffic that would
lat." (Emphasis added.) It is the
err ergency access road' that vaili be 'inter
with public roads that will connect Sage St.
oss the tiller Tree Farm property for the secondary
ime as the Miler Tree Farm property is developed
e Drive and Skyliners Road.
Tree Farr: 4, 24 -14- a0 248 -CU, 247-14x0
249 -TP
Page 91 of 117
10 zoningAttached as Exhibit 4 is a December 29, 2014 analysis provided by
Joe Bessran, PE, of Kittelson responding to Rio Lobo's December 11, 2014,
testimony prepared by Marten Law and Lancaster Engineering ('Kittelson
Memo). The Kittelson Memo confirms that the local' street system proposed by
the Applicant is more than sufficient to accommodate the development of up to
37 single-family home sites on the Rio Lobo Property.'
As the County notes,
`jtJhe transportation effects fon the surrounding street system] of such nominal
development would be de minimis'
r
Rio Lobo argues that `future through traffic' has to include consideration of fl a
potential development of the Rio Lobo properly as a destination resort or
urban development. The County correctly rejects such development as too
speculative to require the Applicant to address it as part of this application.
Development of the Rio Lobo properly as destination resort would require
compliance with the multiple criteria of DCC Chapter 19.106, wh ch, at a
irrrmrm, would require a new traffic impact analysis and approval of a Master
Most significantly, as noted in the , ittelson Memo, DCC 19.106.0060(C)
requires all destination resorts to 'have direct access onto a state, county, or city
arterial or collector roadway as designated by the Bend Area General Plan.' As
discussed in more detail below, the only designated collector or arterial to which
the Rio Lobo property currently has direct access is the future extension of
Skyline Ranch Road. A destination resort on the Rio Lobo property would be
prohibited from taking indirect access via a Sage Steppe road extension over
The Tree Farm and Miller Properties unless and until Rio Lobo seeks and obtains
an amendment to the Bend Area General Plan to designate such a roadway as a
collector." Because such an amendment would have to be based on a
demonstrated need, at a minimum it would have to occur in conjunction with an
actual application for a destination resort. Rio Lobo has submitted no evidence
that such an application is imminent, viable, or would otherwise be compliance
with Chapter 19.106.
Although LIAR -10 zoning does anticipate eventual urbanization, urbanization of
the Rio Lobo properly requires subsequent legislature decisions by the City and
the County in compliance with state law, and would bring the property under the
City's transportation surisdiction. 11 also, as noted by Kittelson, would require an
amendment to the BUAGP transportation system plan, which would require a
needs analysis for urbanization of all the newly added properties.'6 There are
thus rnr ftipie future opportunities to obtain the necessary connections in the
event the properties are added to the U B.
Such speculative future development does not justify imposition
requiring the Applicant to dedicate additional right-of-way or cons.
under the County Code or the Takings Ciause as interpreted in Schultz. s tae
Applicant has addressed the impacts on future connectivity that arise
development by providing, for and dedicating Sage Steppe right -of -v.
right-of-way will be available for use at such time as Rio Lobo andibr Miller Tree
Parra properties are developed and the requirement for its dedication and
construction can be imposed at that time. The fact that Rio Lobo may have to
await development of the Miller Property for the connection to Skyliners Road to
Tree Farm 4, 247 -14 -000248 -CU, 247 -14 -000249 -TP` Page 92 of 117
be dedicated and constructed puts Rio Lobo in no different position than it is in
rrdw. indeed, the dedication of Sage Steppe ensures that a connection will occur
at this point pursuant to DCC 17.36.020(B) when doveio, .nett of the Miller
Property occurs, For these reasons, dedication of the Sage Steppe right-of-way
by the Applicant addresses the future connectivity impacts on surrounding
properties that arise from the development of the Tree Farm property. No
additional exactions are warranted under the Takings Clause,
13indeed, the County is only requesting dedication of additional right-of-way: it is not
requesting any change in the construction of the street system. The requirements -
focal public streets and local private streets are virtually the same. See DCC Chapter
Table A.
''8Given tine
Anderson Ranch
relative location of the Rio Lobo property visa -vis the Miller Property and the
ty [located north of the Rio Lobo property], which are directly
adiacent to tr':e c urgent Bend city limits, the Rio Lobo property i r.nlil sly to be added to
the Bend UGB unless or until (or after) the Miller and Anderson Ranch properties are
added."
The Hearings Officer finds Section 17.6.020() does not require the applicant to dedicate a
public road --- either off-site or within The Tree Farm - as part of The Tree Farre development in
order to provide access from the Rio Lobo property to Skyliners Road.
b. Section 17.6.040, Existing Streets
Whenever existing streets, ''adjacent to or within a tract, are of
inadequate width to accommodate the increase in traffic, expected
from the subdivision or partition by the county roadway network
plan, additional rights of way shall be provided at the time of the
land division by the applicants During consideration of the tentative
plan for the subdivision or partition, the Planning Director or
Hearings Body, together with the Public Works' Director, shall
determine whether irovemernts to existing streets adjacent to or
within the tract, are required, if so determined, such improvements
shall be required''' as a condition of approval for the tentative plan.
Improvements to adjacent streets shall be required where traffic ori
such streets will be directly affected by the proposed subdivision or
partition.
FINDINGS: There are, no existing streets adjacent to Tree Farm 4, and therefore the Hearings,
Officer finds this criterion is not applicable to Tree Farm 4.
c. Section 17.6.00,
Continuatio
n of Street
Subdivision or partition streets whic
streets in contiguous territory s
centerlines coincide.
h constitute the
hall
FINDINGS: The Hearings Officer finds this criterion is not applic
no streets that would constitute a continuation of other streets.
d
Section
17.3
6.0
60, Minimum Ri
Tree Farni 4, 247'i4 -000248 -CU, .47 -14 -000249 -TP
be aligned
ontinuation of
so that their
ble because Tree Fara 4 has
ht of Way and Roadway Width
Pace 9
of 117
The street right of way and roadway surfacing widths shall be in
conformance with standards and specifications set forth in chapter
17.48 of this title, Where chapter 17,48 refers to street standards
found hi a zoning ordinance, the standards in the zoning ordinance
shall prevail;
FINDINGS: The applicant proposes to improve ail >.PUD roads to the county's standards for
public and private local roads and to improve them with 20 feet of paved surface as provided in
Table A of Title 17. As discussed above, the applicant proposes that ai'l'' private PUD roads be
subject to public access easements, and the Hearings Officer has found that as a condition of
approval the applicant will be required to show those easements on the final plats for The Tree
Farre. For these reasons, I find Tree Farm 4 satisfies this criterion.
Section 17.36.070, Future
Reser
bd
sion
Where a tract of <land ,,is divided into
more, the Hearings Body may requ
parcels and streets such as to pe
conformity to the street requirements con
ots or parcels of an acre or
re an arrangement of lots or
rrnit future resubdivision in
tamed in this title,
FINDINGS: The applicant's burden of proof for Tree Farm 4 states the applicant intends that
The Tree Farm never will be annexed into the Bend UGB or redeveloped. The applicant has
proposed deed restrictions for The Tree Farm open, space tracts that would preclude further
division or development thereof. However, as discussed in the findings above, the Hearings
Officer has required the applicant as a condition of approval to provide to the Planning Division
for its review, and to record, revised deed restrictions that provide for permanent preservation of
The Tree Farm open space tracts; For these reasons, and with imposition of that condition of
approval, ''i find it is not necessary or appropriate to require an arrangement of lots in Tree Farm
4 permitting future resubdivision,
Section 17036>O80, Future Extension of Streets
When necessary to give access to o
division of adjoining land, streets shat
of the subdivision) or partition
permit a satisfactory future
be extended, to the boundary
FINDINGS: : Sage Steppe Drive will be dedicated to the public and will be stubbed off at the
northern boundary of Tree Farm 1 in order to provide a future road connection to the vacant
UAR-10 Rio Lobo property to the north, The ' Hearings Officer has found the applicant is not
required to dedicate and improve other public roads within The Tree Farm, or the proposed off-
site secondary emergency access road, to accommodate future through traffic from the, Rio
Lobo property. For these reasons, i' find Tree Farm 4 satisfies this criterion.
g
Section 17.36.160, Frontage Roads
If a land division abuts, or contains an existing,,or proposed collector'''
or arterial street, the Planning ,Director or Hearings Body may
require frontage roads, reverse frontage lots or parcels with suitable
depth, screen planting contained in a non -access reservation along
the rear or side property line, or other treatment necessary for
Tree Farm = , 247-14 000248 -CU, 247 -14 -000249 -Tl
Page 94 of
7
adequate protection of residential properties and to afford
separations sof through and local traffic; AH frontage roads shall,
comply with the applicable standards of Table A of DCC Title 17,
unless specifications included in a particular zone provide other
standards applicable to frontage roads,
FINDINGS; Tree Farm 4 does not abut Skyliners Road, a designated county collector
therefore the Hearings Officer finds this criterion is not applicable to Tree Farm 4.
h. Section 17.36.110
s
treets Adjacent
to Rail
roads, F
ree
oad
and
ys an
d`
Parkways
When the area to be divided adjoins or contains a railroad, freeway
or parkway, provision may be required for a street approximately
parallel to and on each side of such right of way at a distance
suitable for use of the and between the street and railroad, freeway
or parkway. In the case of a railroad, there shall be a land strip of not
less than 25 feet in width adjacent and along the railroad right of
way and residential property. If the intervening property between
such parallel streets and a freeway or a parkway is less than 80 feet
in width, such intervening property shall be dedicated to park or
thoroughfare use. The intersections of such parallel streets, where
they intersect with streets that cross a railroad, shall be determined
with due consideration at cross streets of <a minimum distance
required for approach grades to a future grade separation and right
of way widths of the cross street,.
FINDINGS: The Hearings Officer finds this criterion is not applicable because The Tre
and Tree Farm 4 are not adjacent to a railroad, freeway or parkway.
Fl
N
ci3
Section 1x.36 120, Street Names
Exce
used
Farm
pt for extensions of existing , streets, no street name shall be
which will duplicate or be confused with the name of an
a nearby city or in the County. Street names and
nform to the established pattern in the County,
existing street in
numbers shall co
DINGS: Exhibit "Cr to the Tree Farm 4 burden of proof indicates the applicant has received
my approval for all'' Tree Farm road names, therefore satisfying this criterion.
Section 17.36.130, Sidewalks
A. `Within an urban growth boundary, sidewalks shall be
installed on both sides of a public road or street' any in any
special pedestrian way within the subdivision or partition,
and -\: any 2.on\o.\ and a te.3\. I' 2\,roved
accordance with<the subdivision or partition.
FINDINGS: The Hearings Office r fin
not located within the Bend UGB.
T re
d
s this criterion is not ap
Farm 4, 247 -14 -000248 -CU, 247 -14 -000249 -TP
plica
!Die because Tree Farm 4
is
Pae 95of117
Within an urban area, sidewalks shall be ,required along,;
frontage roads only on the side of the frontage road abutting
the development.
FlN ING ; The Hearings Officer finds this criterion is not applicable' because there are � o
frontage roads in Tree Farm 4.
C. Sidewalk requirements for areas outside of urban area are set
forth in section 17A8.175. In the absence of a special
requirement set forth by the Road Department Director under
DCC 1748.630,, sidewalks and curbs are never required in
rura areas outside unincorporated communities as, that term
is defined in Title 18.
FINDING: The Hearings Officer finds no sidewalks are required
located in a rura area outside unincorporated communities.
n Tree Far rr 4 because it is
Section 36.140 Bicycle. Pedestrian and Transit Requirements
Ped
estrian and
Bicycle Circulation withi
n Subd
ivisio
rt,
1< The tentative plan for a proposed subdivision shall
provide fuer bicycle and pedestrian routes, facilities
and improvements within the subdivision and to
nearby existing or planned neighborhood activity
centers, such as schools, shopping areas and parks in
a manner that will (a) nlinimize such interference from
automobile traffic that wit's discourage pedestrian or
cycle travel for short trips, (b) provide a direct route of
travel between destinations within the subdivision and
existing or planned neighborhood activity centers, and
(c) otherwise meet the needs of cyclists and
pedestrians, considering the destination and length of
trip.
FINDINGS: The Tree Farm would include a Illu ti -use path systemincluding eight- and ten -foot -
wide paved paths that would run parallel to all subdivision roads. The multi -use paths will
provide access to Skyliners Road and beyond to Northwest Crossing, the three nearby public
schools, and the rest of the Bend urban area. The applicant also proposes >a number of soft-
surface recreationiontain bike trails within the open space tracts and linking with trails in
Shevlin Park and the DNF to the west. For these reasons, the Hearings Officer finds Tree Farm
4 satisfies this criterion.
B. Subdivision Layout
Cul-de-sacs or dead-end streets shall be allowed only
where, due to topographical or environmental
constraints, the size;, and shape of the, parcel, or a lack
of through -street connections in the area, a street
connection is determined by the Planning Director or
Hearings Body to be infeasible or inappropriate, In
Tree Farre 4, 247 "#4 -000248 -CU, 24714.0002.49 -TP
Page 96 of 117
such instances, where applicable and feasible, there
shall be a bicycle and pedestrian connection
connecting the ends of 'cul-de-sacsto streets, or
neighborhood activity' centers on the opposite side of
the block,
FINDINGS: The applit••ant proposes cul-de-sacs at the eastern terminus of Ridgeline Court in
Tree Farm 1 and at the western tern elms of Canopy Court in Tree 'Farre . The Hearings Officer
has found that ''these cul-de-sacs are justified by topography and the lack of through -street
connections,
2. Bicycle and pedestrian connections between streets
shall be provided at mid -block where the addition of a
connection will reduce the walling or cycling distance
to an existing or planned neighborhood activity center
by 400 feet and by at least 50 percent over other
available routes.
FINDINGS: The Hearings Officer finds this criterion is not applicable to Tree arm 4 because
there are no existing or planned neighborhood activity centers for which, mid -block connections
are warranted or necessary.
FINDING
Local roads shall align and connect with themselves
across collectors and arterials. Connect€tins to
existent ., of rlannd atreets and undevel
roer°ties shall be provided at no greater than 400
foot intervals.
r Connections shall nrat be more than 400 feet' I n_g_an
shall be as straight as possible,
Fac il Iles and linprovements
Bikeways may be provided by either a separate paved
path or an on -street bike ane, consistent with the
requirements of DCC Title, 17.
S: The Hearings Office
across S
I e. y l i n e r s Road.
Pedestrian access may be provided by sidewalks or a
separate paved path, consistent with the requirements
of DCC Title 17.
Connectr, ns shall have a,20 -
least a 1O foot usable'surt o
Inds there are no
existing
loch
est right-of-way. with
(Emphasis added.)......
ds that mu
st be aligned
The parties and county staff disagree as to the meaning of the above -underscored language.
Miles Conway argues on behalf of Rio Lobo that this'language requires the applicant to provide
stubbed road connections at least 400 feet long and at 400 -foot intervals along the northern
boundary of The Tree Farm to provide future connections to the undeveloped Rio Lobo
property. Peter Russell responded in his December 11, 2014 emorandum that the
Tree Fara.°4, 247-14-0
024 -GU. 247 -14 -000249 -TP
Page s i of 11
underscored language must be read in the context of the title of this section -- "E3icycle,
Pedestrian and Transit Requirem nts's -- and the rest of the section which addresses bicycle
and 'pedestrian connections. In particular, Mr. Russell notes the terms "connections" in Paragraph
(C)(3) of this section clearly refers to bicycle/pedestrian paths because it requires a minimum
paved width of 10 feet, far less than minimum 20 -foot pavement >.width required for roads, For
this reason, Mr. Russell argues the better reading of the underscored languageis that, at most
it establishes a requirement, of 10 -foot -wide paved bicycle/pedestrian connections at 400 -foot
intervals along the Tree Farm's borders with adjacent undeveloped, property.
In his December 30, 2014 letter,; Mr, Condit agreed with Mr. Russell'' interpretation of the
connection requirement, but argues this requirement should not be applied to rural subdivisions
because it would produce an absurd result. For example, he notes that if The Tree Farm lots
along the Rio Lobo border were 10 acres in size, the 400-foot-intervali400-foot-long connections
would bisect the lots and create paths 'leading to nowhere."32 Mr, Condit also argues that if this
connection requirement is applicable to Tree Farms 1, 2 and 3, it also would apply to the
adjacent undeveloped Miller Tree Farm property and therefore to the entire border between that
property and Tree Farm 1. Since most of the land in Tree Farms 1, 2 and 3 is less than 400 feet
wide. co€m€pl€ante with the connection requirement would not be feasible in Tree Farms 1, 2 and
3. Mr. Condit also notes the county did not apply this bicycle path connection requirement to
prior approvals for three rural PVDs on nearby properties: Tumalo Creek Development (CU-05-
17,
CU-0 -17, TP -05-958) (adjacent to the Rio Lobo property on the north); Cascade Highlands (CEJ -02-73,,
TP -02-931) (The Highlands at Broken Top subdivision across Skyliners Road to the south): and
Sheviin Heights (Anderson Ranch) (ZC 0O 5, U-00-112, TR -00-916) (north of the Rio Lobo
property). A review of these decisions indicates the connection standard was not applied to
these PLIDs based on findings that there were no existing or planned neighborhood activity
centers in the vicinity, and/or that the standard does not apply to private roads. Finally, Mr.
Condit argues that if the Hearings Officer concludes the bicycldipedestrian€ path connection
requirement is applicable to The Tree Farre, I should grant an exception under Section
19.104,070(C), discussed in the findings above, in light of The Tree Farm's demonstrated
benefits in general, and the extensive multi -use path/trail system proposed for The Tree Farm,
The Hearings Officer agrees with "r, Russell that read in context, the 'connections" required by
Section 1' 7.36 140(B)(3) and (4) are bicycle/pedestrian path connections and not road
connections, also agree with Mr. Condit that application of this requirement to rural
subdivisions including The Tree Farm would be inappropriate and infeasible. Finally, I find the
applicant has demonstrated an exception to this requirement is justified by the benefits provided
by The Tree Farm, particularly the extensive multi -use pathitrail system,
For the foregoing reasons, the Heari
approval of the exception described a
ngs Officer finds Tree Farm 4 satisfies these criteria'with
bove.
Section 17.36.150, Bloc
Pis
A, General. The length, width and shape of blocks shall
accommodate the need for adequate building size, street
width, and direct trawl routes for pedestrians and cyclists
through the subdivision and to nearby neighborhood activity
centers, and shall be compatible with the limitations of the
topography.
32 As noted in the findings above under the UAR-10 Zone, the
n rnu
lot width in
zon
is 300 feet.
Tree Farm >4, 247-14 0 0248 > , 247-14- 00249 -TP Page 98 of 117
FINDINGS: Section 17.08.030 defines "block" as "an area of land bounded by streets or by a
combination of streets and public parks, cemeteries, railroad rights of way, lines or shorelines or
waterways, or corporate boundary tines of a city." The Hearings Officer finds Tree Farm 4 does
not contain any 'blocks" inasmuch as no area of land within the proposed development is
bounded by streets or the other listed features.
Within an urban growth boundary, no block shall 'be longer
than 1,200'' feet between street centerlines, in blocks over 800,
feet in length, there shall be a cross connection consistent
with the provisions of DCC 17,36,10.,
FINDINGS: Tree Farm 4 is not located
finds this criterion is not applicable.
Sect
ithin the Ben
on 17.36,160 Eas
ements
d UB, Th
erefore,
e Hearings Officer
A, Utility easements. Easements shall be provided along
property lines when necessary for the placement of overhead
or underground utilities, and to provide the subdivision or
partition with electric power, communication <facilities, street
lighting, sewer lines, water lines, gas lines or drainage. Such
easements shall be labeled "Public Utility Easement" on the
tentative and final plat; they shall be at least 12 feet in width
and centered on lot lines where possible, except utility pole
guyline easements along the rear of lots or parcels adjacent
to unsubdivided,,land may be reduced to 10 feet in width,
FINDINGS; ; The Tree Farm 4 burden of proof states the applicantintends to locate all utilities in
roadside trenches, either within the private road rights-of-way or within multiple use easements
(MUEs) paralleling the rights-of-way, as shown on the Preliminary Water Flan included in the
record as Exhibit '.E" to the burden of proof, The Hearings Officer finds that as a condition of
proval the applicant will be required to show all MUEs on the final plat for Tree Farm 4.
ap
Drainage. If a tract s traversed by a watercourse such as a
dratnageway, channel or stream, there shall be provided a
stormwater easerne it or drainage right of way conforming
substantially with the lines of the watercourse, or in such
further width as will be adequate for the purpose. Streets or
parkways parallel to major watercourses or drainageways
may be required.
FINDINGS: The Hearings Office€r••' finds this criterion is n
property is not traversed by a watercourse.
Section 17,6.170,
Lots
Size 'a
0
nd Sha
a
police
pe
The size,, width and orientation of lots
appropriate for the location of the land divi
development and use contemplated, and sha
Tree Fa ra€ 4, 247-14-e 0248 CU. 247. -14.000249 -Tl
ble
be
e the subject
or parcels shall be
ion and/or the type of
be consistent with the
Page
of 11,
lot or
parcel size provisi
the fol
A.
ons of Titles 16 through 21
of this code, with
lowing exceptions:
in areas not to be served bY a public sewer, minimum ot and
parcel sizes shall permit compliance with the requ rements of
the Department of Environmental Quality and the County
Sanitarian, and shall be sufficient to permit adequate sewage
disposal. Any problems posed by soil' structure and water
table > and related to sewage disposal by septic tank shall be
addressed and resolved in the applicant's initial plan.
FINDINGS: : The;, proposed residential lots in Tree Farm 4 will be two acres in size. The applicant
submitted a septic suitability study, included in the record as Exhibit "F" to the Tree Farm 4
burden of proof, indicating the soils on the subject property are suitable for on-site septic'
systems. In addition, the applicant > proposes to estab ish building envelopes on each lot within
which dwellings must be constructed, As discussed above, 1 have granted an exception to the
minimum 'lot width for Lot 1 in Tree Farm 1. And 1 have found the applicant will be required as a
condition of approval to obtain an approved septic site evaluation for each residential lot in Tree
Farm 4 prior to final plat approval. For these reasons, the Hearings Officer finds the size, width
and orientation of the proposed lots are appropriate for the proposed planned development,
consistent with the minimum lot sizes in the RR -10 and UAR-10 Zones, and large enough to
accommodate on-site septic systems.
Section 1736,16
0, F.
n
tag
e
A. Each lot or parcel shaIl abut upon a public road, or when
located in a planned development or cluster development,
private road, for at lest 50 feet, except for lots or parcels
fronting on the bulb of a cul de sac, then the, minimum
frontage shall be 30 feet, and except for partitions off of U,S,
Forest Service or Bureau of Land Management roads.
Frontage for partitions off U.S. Forest Service or Bureau of
Land Management roads shall be decided on a case by case
basis based on the location of the property, the condition of
the road, and the orientation of the proposed parcels, but
shall be at least 20 feet. in the La Pine Neighborhood
Planning Area Residential Center District, lot' widths may be
less than 50 feet in with, as specified in DCC 13.61, Table 2:
La Pine Neighborhood Planning Area Zoning Standards.
Road frontage standards, in destination resorts shall be
subject to review in the conceptual master plan.
An side lot liras shall be at right angles to street
radial to curved streets wherever practical,
nes or
FINDINGS: With the exception of Lot 1 in Tree Farm 1, all proposed residential lots in The Tree
Farm will have at least 50 feet of road frontage, or at least 30 feet of road frontage for those lots
located on a cul-de-sac. In the Hearings Officer's decision in Tree Farre 1, l approved an
exception to the 50 -foot road frontage requirement for Lot 1 based on my finding that the
benefits of the proposed oldster/PUDs justify the requested exceptions. Generally, Tree Farm 4
lot lanes are at right angles to Golden Mantle Loop. For the foregoing reasons,1 find Tree Farm
4 satisfies this criterion.
Tree Farm »4. 247 14 -000248 -CU, 247 -14 -000249 -TP Page 100 of 117
Section 17,36,190. Throug
h Lots
Lots or parcels with double frontage should be avoided except
where they are essential to provide separation of residential
development from major street or adjacent nonresidential activities
to overcome specific disadvantages of topography and orientation.
A planting screen easement of at least 10 feet in width and across
which there shall be no rightof access may be required along the
lines of lits or parcels abutting such a traffic artery or other
incompatible use
FINDINGS: Section 17.03,030 defines "through lot' ds "an interior lot having frontage on two
streets," The Tree Farm 4 tentative plan shows Lots 31 and 32 will have frontage on both
Golden Mantle Loop and Ridgeline Drive, However, I find no planting screen easement is
required on these lots' in order to prevent road access' across these bats.
g. Section 17,36.20
0 Corner Lots
Within an urban growth boundary, corner lots or parcels shall be a
minimum of five feet more in width than other lots or parcels, and
also >shalI have sufficient extra width to meet the additional side yard
requirements of the zoning district in which they are located,
FINDINGS: The Hearings Officer finds this criterion is not applicable because Tree Farre 4 is
located outside the Bend U B.
Section 17.36.210, Soar Access Performance
A. As much alar access as feasible' shall'' be provided each lot
or parcel in every new subdivision or partition, considering,
topography, development pattern and existing vegetation,
The 'lot lines of bats or parcels, as far as feasible, shall be
oriented to provide solar access at ground level at the
southern building line two hours before and after the soar
zenith from September 22nd to March 21st. If it is not feasible
to provide soar access to the southern building line, then
soar access, if feasible, shall be provided at 10 feet above
ground level at the southern building line two hours before
and after the solar zenith from September 22nd to March 21st,
and three hours before and after the solar zenith from March
22nd to September 21st,
This solar access shall be protected by solar height
restrictions on burdened properties for the benefit of lots or
parcels receiving the solar access`
if the solar access for any lot or parcel, either at the southern
building line or at 10 feet above the southern building >line,
required by this performance standard is not feasible,
supporting information must be flied with the, application,
Tree Farm 4, 247 -14 -000248 -CU 247'-14-Q0 249 -TP Page 101 of 117
FINDINGS: : The Hearings Officer finds the size, shape and orientation of the residential lots in
Tree Farm 4 will`>allow for the dwellings on these lots to meet the solar access standards.
Section 17.36.220, Underground Facilities
Within an urban growth boundary, all permanent utility services to
lots or parcels in a subdivision or partition shall he provided from
underground facilities„ provided, however, the Flearings Body may
allow overhead utilities if the surrounding area is already served by
overhead utilities and the proposed subdivision or partition will,
create less than, ten lots, The subdivision or partition shall be
responsible for complying with requirements of this section and
shall.
FINDINGS: The Hearings Officer finds this section is not applicable because the property is
located outside the Bend UGB.
Section 17,36 260
, Fare Hazards
Whenever possible, a minimum of two points of access to the
subdivision or partition shall be provided to provide assured access
for emergency vehkes and ease resident evacuation.
FINDINGS: The applicant proposes two points of access to The Tree Farm and Tree Farm 4 --
the' main PUD road that intersects with Skyliners Road at the southern boundary of Tree Farm
1, and the proposed secondary emergency access road running from the southern terminus of
Sage Steppe Drive in Tree Farm 1 south through the adjacent Miller Tree Farm property to
Crosby Drive. As discussed in the findings above, the Hearings Officer has found the secondary
access road will provide an adequate means of evacuation and emergency vehicle access with
imposition of conditions of approval requiring the road to be improved to the fire department's
standards for such roads, and with installation of a gate/lock system that allows the gate to be
opened by residents and guests. I also have found the applicant will be required to develop Tree,
Farms 1, 2 and 3 concurrently to assure' access to the residential lots. >> Such access will allow
use of the emergency access by lots in Tree Farms 4 and 5.
Section 17,36.280, Water and Sewer Lines
Where required by the applicable zoning ordinance, water and sewer
lines shall be constructed to County and city standards and
specifications. Required water mains and service lines shall' be
installed prior to the curbing and paving of new streets in all new
subdivisions or partitions.
FINDINGS: No new sewer lines are proposed because residential lots in Tree Farm 4 would be
served by on-site septic systems. The Hearings Officer finds that if these residential lots are
connected to the City of Bend water facilities, the applicant will be required as a condition of
approval to construct> all required water lines in compliance with the city's stanards''and
specifications therefor.
Section
7,g,9O'
rad
ividual Wells
Tree Farm 4, 247-14-0 0248 -CU, 247-14-000249-T
F
Page 102 of 117
In any subdivision or partition where individual wells are proposed,
the applicant shall provide documentation of the depth and quantity
of potable water available from a minimum of two wells within one
mile of the proposed land division. Notwithstanding DCC 17.3$ 300,
individual wells for subdivisions are allowed when parcels are larger
than 10 acres.
FINDINGS: > The applicant ha 's stated its preferred alternative for providing domestic water to the
residential bats in Tree Farm 4 is the extension of City of Bend water service. However, if that
connection is not possible, and the applicant does not obtain water service from Avian Water
Company, the applicant proposes to provide domestic water through one or more groundwater
wells. The applicant submitted as Exhibit "lel" to the Tree Farm 4 burden of proof well lags for
two wells on property in the vicinity of the subject property demonstrating that water is available
in the area. Therefore, the Hearings Officer finds Tree Farm 4 satisfies this criterion.
Section 17.3
6
30
0Q Public Wa
ter System
In any subdivision or partition where a public water system is
required or proposed, plans for the water system shall be submitted
and approved by the appropriate state or federal.
FINDINGS: The Hearings Officer finds that if the residential lots in Tree Farm 4 are served by
City of Bend or Avion water service, compliance vitt this criterion will be accomplished through
the, city's or Avian`s compliance with applicable public water system requirements.
3. Chapter 17.44, Park Devblopm
en
Section 17.4.010. Dedication of Land
For subdivisions or partitions outside of an urban growth
boundary, the developer shall set aside a minimum area of
the development equal to $350 per dwelling unit within the
development, if the land is suitable and adaptable for such
purposes and is generally', located in an area planned for
parks.
For either DCC ``'17.44.010 (A) or (B), the developer shall either
dedicate the land set aside to the public or develop and
provide maintenance for the land set aside as a private park
open to the public,
The Panning Director or Hearings Body shall determine
whether or not such land is suitable for park purposes
if the developer dedicates the land set aside in accordance
with DCC '17.44.010(A) or (B), any approval by the Planning
Director or Hearings Body shal be subject to the condition
that the County or appropriate park district accept the deed
dedicating such land.
Tree Farm 4, 247 -14 -000248 -CU, 24i -14 -000249 -TP
Pace 103 0
7
DCC 17.44.010 shell not apply to the subdivision or partition
of lands Iodated within the boundaries of the Bend Metro Park
and Recreation D strict or the Central Oregon Park and
Recreation ,>District
FINDINGS: The record indicates ail proposed residents
the boundaries of the;, park district, and therefore the H
are not applicable
a lots in Tree Farrn 4 are i€ c ted within
eerinps Officer finds these requirements
b. Section 17,44,0 0,, Fee in Lieu, of Dedication
A.
In the event there is no suitable park or recreation area or site
in the proposed subdivision or partition, or adjacent thereto,
then the developer shall, in lieu of setting aside and, pay Into
a park acquisition and development fund a >;sum of money
equal to the fair market value of the land that ill have been
donated under DCC 17.440010 above,, For the purpose of
determining the fair market value, the latest value of the land,,,
unpltted and without improvements,as shown on the
County Assessor's tax roil shell be used. The sum so
contributed shell be deposited with the County Treasurer and
be used for acquisition of suitable area for park and
recreation purposes or for the development of recreation
facilities, Such expenditures shell be made for neighborhood,
or community facilities at the discretion of the Board and/or>
applicable park district.
DCC 17,44.020 shell not apply to subd
ivision or partition of
lends located within the boundaries of the Bend Metro Park
and ,Recreation Distr,ct or the 'Central Oregon Park and
Recreation District.
FIND 1NGS: The Hearings Officer finds that because all proposed residential lots
are located within the boundaries of the park district, this section does not apply,
Cha
p
ter 17.48, Design a
rid Construction
Section 17,48140, Bi
keways
General Design Grlte
1
r€
pecifications
in Tree Fera 4
Bikeways shall" be designed in accordance with the
current standards and guidelines of the Oregon
(ODOT) Bicycle and Pedestrian Flan, the American
Association of State Highway Transportation Officials
(AASHTO) Guide for Development of New Bicycle'
Facilities, and the Deschutes County', Bicycle Master
Plan, See DCC 17,48 Table B
All collectors and arterials shown on the County
Transportation Plan map shall be constructed t€
Tree Farre 4, 247-14-00248 GU. 247 14-0
0
0249 -TP
Page 1
04 of 117
M
include bikeways as defined by the Deschutes County
Bicycle Master Pan.
If interim road standards are used, interim bikeways
andlor walkways shall be provided. These interim
facilities shall be adequate to serve bicyclists and
pedestrians until the flare of road upgrade.
"-use Path
Multi -use paths shall be used where, aesthetic,
recreation and safety concerns are primary and a
direct route with few intersections can be established
If private roads are constructed to a width of less than
28 feet, multi -use paths shall be provided,
Multi -use paths are two way facilities with a standard
width of 10 feet, but with a 12 foot width if they are
subjected to high use by multiple users. These paths,
shall meet County multi -use path standards and shall
connect with bike facilities on public roads,
FINDINGS: : The applicant proposes to provide multi -use paths in The Tree Farm through
additional width on a segment of Tree Farm Drive, and eight- or ten -foot -wide mufti -use paths
along the rest of the PUD roads. A ten -foot -wide multi -use path, is proposed to parallel Tree
Farm Drive from its intersection with Skyliners Road to the point where the path splits to go to
Shevlin Park to the west. From that point to the intersection of Golden Mantle Loop and
Ridgeline Drive, and throughout the rest of The Tree Farm, the m€uIti-use, paths are proposed to
be eight feet wide. The Hearings Officer has approved an exception to allow reduced width from
ten to eight feet for neighborhood multi -use paths, requested by the applicant because of
ected low traffic volumes, based on my finding that the benefits from The Tree Farm justify
ption. For these reasons, and with the exception granted for the eight -foot path, i find
rn 4 satisfies these criteria.
proj
the exce
Tree Far
Br Bi
con
ke Lanes. Six foot bike lanes shall be used on new
D. 5
struction of curbed arterials and
houlder Bikeways.
collectors
Shoulder bikeways shall be used on new constru
of uncurbed arterials and collectors.
ction
Shoulder' bikeways shall be at least four 'feat wide.
Where the travel lane on an existing arterial or
collector is not greater than eleven feet, the bikeway
shall be a'''rnsnsrhum of four feet wade.
FINDINGS: : The Hearings Officer finds these criteria are not, applicable because no new
collectors or arterials are proposed.
Tree Faris 4, 247 -14 -000248 -CU, 247-14-000249-T'
Page 105 of 117
Mountain Bi
ke Trails.
Mountain '''bike (dirt or other unpaved surface trails
may be used as recreational or interim transportation
facilities.
Trails used for transportation shall have a two foot
minimum tread width and a six foot minimurn clearing,
width centered over the trail, and a minimum overhead
clearance of seven feet. Trails used solely' for
recreational use may be narrower with less clearing of
vegetation.
FINDINGS: As shown on Exhibit ',C" to the Tree Farm 4 burden of proof, the applicant) proposes
a network of soft -surface recreation/mountain bike trails linking with trails in Sheviin Park and in
the DNF to the west. A segment of one of these trails would traverse the open space tract in
Tree Farm 4, Therefore, the Hearings Officer finds these criteria are applicable to Tree Fara 4
The applicants Tree Farm 4 burden of proof states the proposed recreation/mountain bike trails
will satisfy, these standards, and l find the applicant will be required as a condition of approval to
do so.
Section 17A8.160, Road Development
Requirements - Standards
A. Subdivision Standards. An roads in new subdivisions shall
either be constructed to a standard acceptable for inclusion,
in the county maintained system or the subdivision shall be
part of a special road district or homeowners assoclation»in a
planned unit development.
FINDING: The applicant proposes to dedicate to the public and to improve Sage Steppe Drive
i€ compliance with the county's standards for public rural roads, and to improve all public and
private PUD roads with 20 feet of paved surface as provided in Table "A" to Title 17. The
applicant' also proposes that all Tree Farm roads Will be maintained by the HOA. As noted
above, the record indicates the county is not accepting new roads into its road maintenance
system. For these reasons, the Hearings Officer finds Tree Farm 4 satisfies this criterion,,
B.
provements of Public Rig
its of Way,
The developer of a subdivision or partition will be
required to improve all public ways that are adjacent
or within the land dev&loprr ent.
A11 ''improvements within public rights of way shalt
conform to the improvement standards designated in
DCC Title 17 for the applicable road classification,
except where a zoning ordinance- sets forth different
standards for a;,;,particular zone.
FINDINGS: The only public' right-of-way adjacent to the subject property is Skyliners Road, an
improved county collector. As discussed above, the road department did not identify any
necessary improvements to Skyliners Road. The applicant proposes to, improve all PUD roads
Tref: Far 4, 247 -14 -000248 -CU 247-14-00 249 -TP
Page 106 of 117
to the to the county's standards for local public and private roads, including 20 feet of paved
surface. Therefore, the Hearings Officer finds Tree Farm 4 satisfies this criterion,
Primary Access Roads. The primary access road for any new
subdivision shall be improved to the applicable standard set
forth in Table A (or the appl cable standard set forth in a
zoning ordinance). The applicable standard shall be
determined with reference to he road's classification under
the relevant trarsporttion plan. For the purposes of this
section a primary access road s a road ''leading to the
subdivision from an existing paved county, city or state
maintained''' road that provides the primary access to the
subdivision from such a road.
FINDINGS: The primary access road to The Tree Farm consists of Tree Farm Drive, Golden'
Mantle Loop, and Ridgelln€e Drive. The Hearings Officer finds the applicant will be required as a
condition of approval to improve the segments of these roads within Tree Farm 4 to the county's
standards for local private roads in Table "A4 to Title 17. In addition, as discussed in the findings
above, l have found the applicant will be required as a condition of approval to develop Tree
Farms 1, 2 and 3 concurrently to assure the primary access road is in place to serve all oafs in
those developments.
Secondary Access Roads. When deemed necessary by the
County Road Department or Dommur ity Development,
Department, a secondary access road shall be constructed to
the subdivision. Construction shall be to the se standard
used for roads within the subdivision,
FINDINGS: The road department did riot identify the need for a secondary access road,
However, the applicant proposes to construct a temporary emergency access road from the
southern terminus of Sage Steppe Drive south through the adjacent Miller Tree Farm property
to Crosby Drive. The applicant proposes to improve this emergency access road to the fire
department's standards for fire apparatus access roads, including a 24 -foot -wide all-weather
surface. As discussed above, this ernergency access road will be an interim access until' the
Miller Tree Farm property is developed with public roads to which Sage Steppe Drive can
connect. Under these circumstances, the Hearings Officer finds the proposed level of
improvement is appropriate for the secondary access road,33
Stubbed Roads. Any proposed road that terminates at a
development boundary shall' be constructed with a paved cul-
de -sac bub.,,
FINDINGS: The, Hearings Officer finds this criterion Is not applicable to
cul-de-sacs are proposed for Tree Farrn 4,
33 The burden of roof for Tree Farm 4 states the applicant would request a variance to the requirement
tnat the secondary access road be paved. However, in an e-mail message dated August 15, 2014, the
applicant's representative Rorny Mortensen clarified, the applicant, is not seeking a variance and does not
helve -ye one is required.
Tree Farm 4 bec
e n
0
Tree Farm 4, 247`'14 -OO 248 C1�, 247.14-00 249 -TP
Page 107 of 11
Cul-de-sacs. Cul-de-sacs shall have a tenth of less than 600
feet, unles a longer length is approved by the applicable fire
protection district, and more than 100 feet from the center of
the bulb to the intersection with the main road, The maximum,
grade on the bulb shall be four percent.
FINDINGS. No cul-de-sacs are proposed in Tree F r€ n 4, and therefore the Hearings Officer
finds this criterion is not applicable. As discussed above, I have found the cul-de-sacs proposed
for he eastern end of'''Ridgeline Court in Tree Farm 1 and the western end of Canopy Court in
Tree Farm 3 are justified by the topography and/or lack of through street connections in the
vicinity, However, because the proposed cul-de-sac at the end of Canopy Court is longer than
600 feet, 'l found in my Tree Farm 3 decision that the applicant will be required as a condition of
approval to obtain and submit to the Planning Division written documentation from the fire
department that it has approved the length of Canopy Court.
c.
Section 17.48.180, 'private Roads
The following minim
um road standards shall ap
A. The minimum paved roadway width
planned unit developments and cl
two -foot wide gravel shoulders,
ply for private roads:
shall be 20 feet in
uster developments with
Minimum radius of curvature, 50 feet;
Makin
um
ra
de, 12
perces:
t;,
FINDINGS: The applicant's burden of proof for Tree Farm 4 states the private roads will meet
these standards, and the Hearings Officer finds the applicant will be required' to construct the
PUD's private roads in compliance with these standards as a condition of approval.
D. At east one road
intersection for each
name sign $
road;
be provided' at each
FINDINGS: The Hearings Officer finds the applicant will be required and€t€ors of approval
to comply with this criterion.
A method for continuing road mantenance acceptable to the
County
FINDINGS: The applicant proposes that The Tree Farm HOA will own and maintain all tree farm
roads. The Hearings Officer finds the applicant will be required as a condition of approval to
execute a road maintenance agreement with the county that is acceptable to the county.
Private road systems shall include provisions for bicycle and
pedestrian traffic. In cluster and planned developments
limited to ten dwelling units, the bicycle and pedestrian traffic
can be accommodated within the 20 -foot wide road. In other
developants, shoulder bikeways .shall be a minimum of four
feet wide, paved and striped, with no ort -street parking,,
allowed within the bikeway, and when private roads are
Tree Farm 4, 247.14-000248 CU, 247 -14 -000249 -TP Face 108 of 117
develo
const
ped to a width of less than 28 feet, bike pa
meted to County 'standards shall be required.
the
FINDINGS: As discussed in findings throughout this decision. the applicant proposes to
accommodate bicycle and pedestrian traffic in The Tree Farm through a system of paved multi-
use paths running parallel to PUD roads. The segment of Tree Farm Drive in Tree Farm 3 would''
have a 26 -foo -wide paved surface to its intersection with Golden Mantle Loop, and all other
public and private road segments would have a 20 -foot paved width with adjacent) or nearby
eight- or ten -foot -wide paved bicycle/pedestrian paths. For these reasons, the Hearings Officer
finds Tree Farm 4 satisfies this criterion.
d. Secti
on 17.4 .190, Dra
nage
Mini um Requirements.
Drainage facilities shall be designed and constructed
to receive and/or transport at mast a design storm as
defined in the current Central Oregon Stormwater
Manual created by Central Oregon Intergovernmental'
Council and all surface drainage water corning to
and/or passing through the development or roadway
The system shell be
development.
desig
ned for maimu
allowa
ble
FINDINGS: The applicant proposes a surface water drainage plan'' for The Tree Farm that would
contain surface water on site through use of vegetated swales, roadside ditches, culverts, and
natural drainage ways, According to this plan, runoff would shed to vegetated shales with 3:1
slopes for on-site infiltration, or would enter a natural drainage way via a roadside ditch and
culvert. The applicant states these culverts will be designed for a ten-year storm event, and
nfiltrat€on facilities will be designed for a fifty-year storm event. The drainage plan notes that
because of the site's topography, natural drainage patterns on The Tree Farm generally are
toward Turnalo Creek to the west and to the undeveloped open space to the east, However, the
applicant states none of the runoff from impervious areas such as roads and driveways will
create any additional drainage contributions to Tumalo Creek as no surface water will be
disposed of off-site. The applicant also proposes that if hydrological calculations determine
additional runoff storage is needed, the applicant will construct a catch basin near the main
entry to The Tree Farm at Skyliners Road.
The Hearings Officer has found that prior to submitting for approval the final plat for any part of
The Tree Farm the 'applicant will be required as a condition of approval to submit to the
Planning Division a statement from a registered professional engineer stating whether an
additional',' runoff storage basin is necessary, and if such a facility is determined to be necessary,
the applicant will be required as a condition of approval to show it on the final plat for Tree Farm
4 and to construct it. l find that with imposition of this condition of approval Tree f=arm 4 will
satisfy this criterion.
Finally, the Hearings Officer finds, the drainage plan'' for Tree Farm 4 need not be designed to
serve the site with 'maximum allowable development" --- i.e.; urban -density development on the
UAR-10 zoned portion of the site — inasmuch as the applicant intends that The Tree Farm never
will be annexed into the Bend UGB, and the applicant will be required as a condition of approval`
Tree Farm 4, 247 -14 -000248 -CU, 247--14-000249-T
Pa±e109of
17
to record deed restrictions permanently prohibiting
tracts.
Noncurbed
ections
development on The Tree Farre open space
Road culverts shall be concrete or
minimum design life of 50 years.
All cross >;culverts shad
larger.
be 18 inches'
with a
in diameter or
Culverts shall be placed in natural drainage areas and
shall provide positive drainage.
FIi DINGS: The applicant's burden of proof for Tree Farm 4 states culverts used for The Tree
Farm will be corrugated metal pipe with a minimum fifty-year design life, and that two 18 -inch
culverts and one 24 -inch culvert will be installed, The Hearings Officer finds the applicant will be
required as a condition of approval to place ail culverts in natural drainage areas and provide
positive drainage.
FINDINGS: The applicant's
Drainage Swales. The Design Engineer is responsible to,
design a drainage Swale adequate to control <a design storm
as defined in the Central Oregon Stormwater``''Manual created
by Central Oregon Intergovernmental Council:
burd
en of proof for Tree Farm 4 states the drainage swales will be
t. Therefore, the Hearings Officer finds Tree Farm 4 satisfies
designed for a 0 -year storm even
this criterion:
., Drainage Plans. A complete set of drai,r€age plans including
hydraulic and hydrologic calculations shall be incorporated
in all road improvement plans,
FINDINGS: The applicant's burden of proof for Tree Farm 4 includes a narrative description of
its proposed drainage plan, and states complete modelling, will be performed and incorporated
into the storm disposal infrastructure ' design during engineering and construction 'plan'
development. The Hearings Officer finds the applicant'' will be required as a condition of approval
to incorporate the drainage plan for Tree Farm 4 into the road improvement plan for Tree Fara
4, and to provide to the Planning Division a copy of that plan before submitting the Tree Farm 4
final plat for approval'.
Drill H
oleso Dril'
holes are
prohibited.
G. lr jection wells (drywells) are pro
way.
hibited in the public right -of -
FINDING: The Hearings Officer finds the applicant's proposal' court
because no drill holes or injection wells are proposed.
For the foregoing reasons,,, the Hearings Officer finds Tree Fa
conditions of approval described above will satisfy, all applicable criteria in Titl
hese crite
ria
r€n 4 satisfies. or €€t'h the
Tree Farm >4. 247-14-00024 - 247 -14 -000249 -TP
e 17.
Page 110 of 117
COMPREHENSIVE PLANS
FINDINGS: Comprehensive plans can be a potential source of approval standards for quasi-
judicial land use applications. The Flight Shop v. Deschutes County, Or LUBA (LUBA No.
2013-073,, January 10, 2014). Even if a comprehensive plan provision does not constitute an
independently applicable mandatory approval criterion, it may nonetheless represent a relevant
and necessary consideration that must` be reviewed and balanced with other relevant plan
provisions pursuant to ordinances that require that the proposed land use be consistent 'with
applicable plan provisions. See, Bot .man v. City of Eugene, 51 Or LUA 426 (2006). Therefore,
the Hearings Officer finds that whether the county's comprehensive plans app y to Tree Farm 4
depends on whether their text and context indicates they include mandatory standards,
requirements, and/or considerations applicable to quasi-judicial development approvals.
FI'
DIN
Desc
hu
tes Co
d
my Corn
prehensive P
Ian
GS The applicant and staff identified the following
1. Chapter 2 Resource
ana
9
men
plan provisions as applica
t Section
Gaal 1, Maintain and enhance a diversity of wildlife and habitats.,,
Policy 2.6.8, Balance protection of wildlife with vvildland fi
prvate ands in the desinatedWildiand Urban Interface;
b'
re midge.
t
o
r;
FINDINGS: The Hearings Officer finds this goal and policy are written in aspirational terms and
appear directed at the county rather than to applicants for land use approval. Therefore, I find
these provisions are not applicable to Tree Farm 4.
2. Chapter 3, Rural Gro asa th Man
Goa
Is a
nd Polio
es
Goal 1 Maintain the rural charas
Deschutes County.
Poi'
cy 3.3.1. The mini
be 10 acres.
m r
rpt
er and
ety of
parcel size for new ru
housing in unincorporated
I residential parcels s
hal
FINDINGS: : The Hearings Officer finds this policy is written''' n mandatory terry s suggesting it
applicable to Tree Farm 4. I have found Tree Farm 4 complies with the ten -acre minimum size
for lots or parcels in the RR -10 and UAR-10 Zones, and therefore 1 find It also is consistent with
this;, plan policy.,,
Policy 3.3.4. Encourage new subdivisions
development patterns, such as cluster development, tha
community and environmental ipacts.
to incorporate alternative
t raid
FINDINGS: The Hearings Offi
For the foregoing reasons, the Hearings Officer finds 1_ree Farm 4 is consistent aiapplicable
county comprehensive plan goals and policies identified by planning staff.
G'.
Bend Area General tlan34
1. Chapter 5: Rousing and Residential Lands
3
6. Sidewalks shall be required in all new residential developments.
Separated sidewalks shall be required, as practical, on streets that
provide or will provide access to schools, parks, or commercial
areas. However, an alternative system of walkways and trails that
provide adequate pedestrian circulation may be approved.
FINDINGS: The Hearings Officer finds this plan provision is written in mandatory terms,
suggesting it is applicable to Tree Farm 4. However, as discussed in the findings above, the
applicant does not propose sidewalks, and I have found they are not required in rural areas
under Title 17. instead, the applicant proposes a network of paved multi -use paths along all new
PUD roads. I find this path network constitutes an alternate system that will provide adequate
pedestrian access within Tree Farm 4, and therefore it is consistent with this plan policy.
2
Cha
pter 8: Pu
ilio Facilities and Services
15. Dry wells or storm drains with appropriate water quality treatment
using landscaping, retention ponds or other approved treatment
controls shall be used for surface drainage control.
16.
The preservation and use of natural drainage ways
drainage shall be required in new developments as
possible.
for storm
much as
20. Developments shall be designed to meet appropriate drainage
quantity and quality requirements (e.g., meeting the requirements of
the City's National Pollutant Discharge Elimination System MS4
Stormwater Permit, the City's Stormwater Master Plan and
Integrated Stormwate Management Plan, and Total Maximum Dally
Load requirements). Low impact site designs shall be encouraged.
27. Development on slopes in excess of 10 percent shall require special
consideration to prevent construction -related and post -cons truction
erosion.
34 The Bend Area General Plan applies to is
nds within the Bend urban area
rye.,
r . 247-14 }00248 -Cu, 247 4 -000249 -TP Pag
e 12 of 117
FINDINGS: The Hearings Officer finds these plan provisions are written in mandatory terms
suggesting they are applicable to public facilities and services in Tree Farm 4. As discussed in
the findings above, incorporated by reference herein, the Hearings 'Officer has ''found the
applicant's proposed drainage plan will dispose of stormwater through the use of vegetated
swales, roadside ditches, culverts, and natural drainage ways. I find these methods will assure
that starmwater runoff infiltrates into native soil to the maximum degree possible and does not
run off into TurRalo Creek or onto other off-site areas. For the foregoing reasons; I find the
drainage plan for Tree Farm 4 is consistent with these plan policies.
For the foregoing reasons, the Hearings Officer finds Tree Farm 4 ''is consistent with the
applicable urban area comprehensive plan policies identified by planning staff.
IV.
DEC
IS ON:
Based on the foregoing Findings of Fact and Conclusions of Law, the Hearings Officer hereby
DEMES the applicant's proposed conditional use, tentative plan, and site plan for a cluster
development/PUD on the subject property, to be called Tree Farm 4.
In the event this d
ecision is appealed to the Board of County Commissioners, and the Board
peal and approves the applicant's proposal on appeal, the Hearings Office
such approval be SUBJECT TO THE FOLLOWING CONDITIONS 0
elects to hear the ap
RECOMMENDS
APPROVAL:
r
F
1. This approval for Tree Farm 4 is based upon the applicant submitted tentative plan,
site plan, burden of proof statements, and written and oral testimony,;, Any 'substantia'
change to the approved plan will require new land use applications and approvals.
PRIOR TO SU
B
WTI
NG THE FI
NAL SUBDIVISION,' PLAT FOR AP
2. The appUcant/owner shall
approval'' for The Tree Farr}
demonstrate to the Planrrin
g
of line adjustments have been met.
PROVAL:
Division that conditions of
The applicant/owner shall submit to the Planning Division an updated title report for Tree
Farm 4.
The applicant/owner shall submit to the Planning Division for review and approval a copy
of nonrevocabie deed restrictions for the Tree Farm 4 open space tract, stating that no
portion of that tract shall be developed ; with a dwelling or other non -open space use in
perpetuity, and that off-road motor vehicle use is prohibited After county approval, the
applicant/owner shall record these nonrevocabie deed restrictions and shall provide
copies of the recorded deed restrictions to the <Planning Division.
The applicant/owner shall record with the D
homeown
er's a
The applicant/owner shall record with the
conditions and restrictions for Tree Fara 4.
The applicant/owner shall
Tree Farm 4,
execute and
Tree Farm 4, 247 -14 -000248 -CU, 247-14-00249-TP249-TP
Deschutes Coun
ecord
ty Clerk th
e covenants,
Conditions of Approval Agreem
ent for
Page 11 of 117
The applicant/owner shall execute and record with the Deschutes County Clerk a
development agreement for the private roads in Tree Farm 4 on a form approved by
Deschutes County Legal Counsel. The development agreement shall', incorporate the
drainage plan for Tree Farm 4. The applicant shall provide a copy of the recorded
development agreement to the Planning Division.
The applicant/owner shall submit to the Deschutes County Road Department for its
review and approval a draft Road Maintenance Agreement outlining the maintenance
responsibilities for all;; new roads in Tree Farrn 4, and following road department approval'
the applicant/owner shall record the Road Maintenance Agreement with the Deschutes
County Clerk,
10. The applicant/owner shall record with the Deschutes County Clerk the wildfire plan and
WMP for the Tree Farm 4 open space tract. The applicant/owner shall provide copses of
these recorded management agreements to the Planning Division,
11. The applicant/owner shat
lot in Tree Farrn 4.
12. The a
obtain an ap
proved septic site evaluation for each residential
pplicantlowner shall obtain from the Deschutes County Road Department an
access permit for the new road connection to Skyliners Road in Tree Farm 1.
The applicant/owner shall obtain from the Deschutes County Road Department a gate
permit for the gates on the new secondary emergency access road for The Tree Farm.
14. The applicantiowner shall submit to the 'Planning Division proof of City of Bend approval>
to extend domestic water service to Tree Fara 4. If City of Bend water is not available,
prior to final plat approval for any Tree Farm development the applicant shall submit to
the Planning Division proof that domestic water is available via the alternative means
identified by the applicant.
15, If the applicant/owner elects, or is required to, provide water to The Tree Farm through
means other than extension of city water service, the applicant/owner' shall provide to
the Planning Division ' a water system analysis performed by a registered professional
engineer and demonstrating water service from the alternative domestic water source
will provide at each residential lot water pressure of at least 40 psi during peak demand
periods, 20 psi residual pressure, and 2,000 gpm for fire flow.
16, The applicant/owner shall provide to the Planning Division a statement from a registered
professional engineer indicating whether a runoff storage basin is necessary.
17. The applicant/owner shall subs €it to the Planning
Bend Fire Department that all standards for subd
emergency access road, have been met
18. The appllcant!owner shall
Division written
verification from the
vision roads, incl€
ding the secondary
pay aII taxes for Tree Farm 4 in accordance with ORS 92.095.
Tree Farm 4, 247 -14 -000248 -CU. 247 -14 -000249 -TP
Pa
ge
4 of 117
WITH OR ON THE FINAL SU
20
DIVISION;, P
LAT:
The applicant/owner shall prepare the fi
17of the Deschutes County Code, inc
Section 17.24.060.
nal plat for Tree Farm 4 in accordance with Title
ud"€ng all the necessary info rmation required by
The applicant/owner shall show the folloyving on the final pi
a
fo
Tree
r 4:
the exact lot size of each residential lot, and of the open space tract which shall
be platted as a separate tract,
the
build
mg envelope for each
all easements of record and existing rights-of-way;;;;
a statement of we
e. all utilityeasements;
f. all
g>•
p
rig
hts a
s required
ublic access easements; and
by ORS 92.120;
if a runoff storage basin is necessary, the location of the storage basin.
211. The surveyor or registered ,Iprof essional engineer sub€fitting the final plat for Tree Farm
4 shall submit' information to the Deschutes County Road Department showing the
location of any existing roads in relationship to the road right-of-way; This 'information'
can be submitted on a worksheet and does not necessarily have to be on the final plat.
All existing road facilities and new road improvements are to be located within legally
established or dedicated right-of-ways. in no case shall a road improvement be located
outside of a dedicated road right-of-way. If research reveals that inadequate right-of-way
exists or, that the existing roadway is outside of the legally established or dedicated right-
of-way, additional right-of-way will be dedicated as directed by the Deschutes County
Road Department to meet current county standards.
22_ The final plat for Tree Farm 4 shall be signed by all persons with an ownership interest
PRIOR
23
the property, as well as the Deschutes County Assessor and Tax Collector,
TO0
R WITH CONSTR
u
CTION:
The applicantJowner shall obtain from the Deschutes County Road Department approve
of all construction plans for all required road improvements prior to commencement o
any construction.
24 All private road designs shall be in accordance with the standards in
Table "A" of the Deschutes County Code for rural local private roads,
25. All private roads constructed in Tree Farm 4 shall include bicycle
as proposed on the tentative subdivision, plan and burden of proof.
26. The applicant/owner shat
approval of the, Desch
construct all road
tes County Road De
Tree Farm` 4, 247 -14 -000248 -CU. 247-14-000249-Tf
a
lapter 17.48 a
nd ped
es
nd
n path
s
improvements under the inspection and
partment. The road department may accept
Page 11€ 5 of 11'i
27.
28
29
certification of improver ents
92.097.
by
registered professional engineer
The applicant/owner shall assure that all road im
surveyed and staked in accordance with DCC 17.48.2
pursuant to ORS
provements in Tree Farre 4 are
00
The applicant/owner shall place all culverts in natural drainage areas and provide
positive drainage.
If a runoff storage basin is determined to be necessary, the, applicant/owner shall
construct such a basin at the lowest point in "free 'amn 1. or in such other location as
determined to be appropriate by a registered professional engineer'
30. The applicant/owner shall install all utilities underg
31
The applicant/0
each road.
r shall insta
at
round.
least one road na
me
at each intersection for
32. If the applicant/owner provides domestic' water service to Tree Farm 4 through extension
of and connection to the City of Bend water system, the applicant/owner shall construct
all required water lines to the city's standards and specifications therefor:
33. The applicant/owner shall install on the residential lot side of the gate at the southern
terminus of Sage Steppe Drive at least one means of opening the gate by Tree Farm
residents and guests, such as special keys, key codes and/or automatic gates,
34. The applicant/owner shall construct all recreation/mountain bike rails with a two -foot
minimum tread width and a six foot minimum clearing width centered over the trail, and a
rnirimur overhead clearance of seven feet.
FO
LLOW1N
G FII
NAL PLAT APPR
OVAL:
35. The applicant/owner shall begin constrc:
of the date this decision becomes fdna
Director may allow;
AT ALL TIME
S
36 The applicant/owner shall satisfy a
protection within Tree Farm 4
n of Tree aurins 1, 2 al
or such longer period of
requirements of the Bend Fire l epartment for fire
37. The applicant/own e'r shall lirr€it uses permitted in the Tree Farm 4 open space tract to
management of natural resources, trail systems, and low -intensity outdoor recreation
uses, and shall prohibit golf' courses, tennis courts, swimming pools, marinas, ski runs or
other developed recreational uses of similar intensity and off-road vehicle use on the
open space tract. The applicant/owner shall enforce these open space restrictions and
prohibitions through the Tree Farm 4 covenants, conditions and restrictions.
The applicant/owner shall install any fencing in the WA -zoned portion of Tree
accordance with the WA Zone standards therefor.
Tree 'Farre 4, 247.14 -000248 -CU, 247 -14 -000249 -TP
Farm 4
n'
Page l 16 of 117
The applicant/co aner shall assure the building height and setback standards in the UAR-
10, RR -10 and A-10 Zones are met for dwellings in Tree Farm 4.
40, The applicant/owner shall assure that address numbrs are, provided for each delling in
Tree Farm 4 as required by the Oregon Fire Code.
D
u
RATIO
N OF APP
ROVAL:
41'. The applicant/owner ' shall complete al ll conditions of approval and apply for final plat
approval from the Planning Division for Tree Farms 1, 2 and 3 within two (2) years of the
date this decision becomes final, or obtain an extension the approval in this decision in
accordance with the ,provisions of Title 22 of the County Code, or the approval shall be
void.
42.
The applicant/owner shall complete all conditions of approval and appy for final pat
approval from the Planning Division for Tree 'Farms 4 and 5 within four (4) years of the
date this decision becomes final, or obtain an extension in accordance with the
provisions of Title 22 of the Deschutes County Code
Dated this 18th day of March , 2015 Mailed this 18 day of I Iarch, 2015
Karen H. Green, Hearings Officer
THIS DECISION BECOMES E FINAL TW
UNLESS APPEALED BY A' PARTY OF I
ELVE (12) DAYS
NTE
REST
Tree 'Farre 4, 247 4 -000248 -CU, 247 -14 -000249 -TP
AFTER TH
E DATE OF 11AILING,
Page '117 of;
Co
munity Developrri
eat
Mop
art
m
e
of
Planning Diviskrn Building Safety Division Environmental Division
Did ision
ocu
CE
F<w. Box 6005 117 NW Lafayette Avenue Bend, Oregon 97700-6005
(541):3.68-6575 FAX (541)385-1764
RTIFICATE OF MAILING
ALE NU
BERS: 247 -14 -000242 -CU, 243 -TP
'INTENTS MM
MAP/TAX LOT
N
UM
LE
BE
RS:
certify that on the 18th day of
March 10, 2015, was/were nailed by fig;
address(es) set forth on the attached list.
C
Ronny Mortensen
The Tree Farm, LLC
(
409 NW Franklin Avenue
Bend, OR 07701,
Ken Pirie
a ker Macy
1 SW Oak St #200
Portland; OP 7204
rey Condit
Miller Nash LLP
3400 US Bancorp Tower
11 SW Fifth Avenue
1
Portland, OR 07204-3S9
9
247 -14 -000244 -CU, 245 -TP
247 -14 -000246 -CU, 247 -TP
247 -14 -000248 -CU, 249 -TP
247 -14 -000250 -CU, 251 -TP''
H
earing
s Office
r Dec
si
ons Tree Farms 1
thru
17-11-35D00-0400; 17.11-6002, 6205, 6207,
6208, 6209, 6210, 6211, 6212 and 6213
015, the attached notice(s)/report(s), dated
postage prepaid, to the person(s) and
Dated this 18th day March„ 2015.
UNITY D
EV LOP
E
NT DEPARTMENT
By: +1oonli ht B
Per
P
hariey Miller
}tiller Tree Farm
110 NE reenwood Avenue
Bend, OR 97701
Ron Hand
VVHPacific
123 SW Columbia Street
Bend,; OR 97702
Dale Van Vaikenburg
Brooks Resources Corpdratior
409 NW Franklin Avenue
Bend, OR 97701
d with1 i
Connie Peterson
2203 NW C eam ter Drive
Bend, OR 97701-2203>
Doug Wickham
61971 Ki'Idonan Court
Bend, OR 97702
Corey Heath & Nancy Bruener
Oregon Department of Fish '& Wildlife
61374 Darrell Road
Bend, OR 97702
l iachelle Healy & Steve Jorgensen
Bend Metro Parks and Recreation District'
799 SW Columbia Street
Bend, OR 97702
�yies Conway
Marten Law
404 SW o umbia
Bend, OR 97702
Street, Suite 212
A J€ hnson
2522 NW Grassing Drive
Bend, OR 97701
Kelly Esterbrook
16322 S yliners Ro
Bend, OR 97701
ad
Paul Dewey
1539 NW Vicksburg Avenue
Bend, OR 97701
Christine Herrick
2281 NW High Lakes Loop
Bend, OR 97701
Larry Medina
Bend Fire Department
1212 SW Simpson, Suite
Bend, OR 97702
Jennifer Taylor & Ch
19001 Squirreitail Loop
Bend, , OR 97701
ristmne Pollard
George Weurtnner
P.O. Box 8359
Bend, OR 97708
Edward & Lynn Funk
2138 Toussaint Drive
Bend, OR 97701
Deschutes County
Ed Keith, Forester
George Kolb, Road Dad rtr en
Peter Russell, CDD