HomeMy WebLinkAboutResolution No. 4926
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COUNCIL RESOLUTION NO. 4926
A RESOLUTION DENYING A MEASURE 37
CLAIM OF CHARLES WIPER, INC. FOR
PROPERTY IDENTIFIED AS ASSESSOR'S MAP
18-03-18-00, TAX LOT 300.
PASSED: 6:1
REJECTED:
OPPOSED: Solomon
ABSENT: Clark
RECUSED:
CONSIDERED: February 11, 2008
RESOLUTION NO. 4926
A RESOLUTION DENYING A MEASURE 37 CLAIM OF CHARLES
WIPER, INC. FOR PROPERTY IDENTIFIED AS ASSESSOR'S MAP 18-
03-18-00, TAX LOT 300.
The City Council of the City of Eugene finds that:
A. Charles Wiper, Inc. (Claimant) submitted a claim to the City under ORS 197.352
(Ballot Measure 37 (2004)) seeking either a waiver of regulations or compensation for alleged
reduction in fair market value to the property identified as Assessor's Map 18-03-18-00, Tax Lot
300. The property consists of approximately 71.6 acres, 20.5 of which are developed for
cemetery purposes and known as Rest-Haven Memorial Park; the remainder of the subject
property is vacant.
B. Claimant seeks waiver of any and all land use regulations that restrict the use of
the property, including: Eugene Code Chapters 6 and 9; the Eugene-Springfield Metropolitan
Area General Plan (Metro Plan); all relevant refinement plans, such as the South Hills Study,
TransPlan, and the Eugene-Springfield Metropolitan Area Public Facilities and Services Plan; all
relevant land use policies, such as the Housing Dispersal Policy; all relevant studies and reports,
such as various Goal 5 studies, the Eugene-Springfield Metropolitan Area Residential Land and
Housing Study and the Eugene-Springfield Metropolitan Area Public Facilities Plan Technical
Background Report; all implementing regulations and standards, such as the Stormwater Manual;
and all restrictions and conditions included in the Conditional Use Permit (CUP) currently
applicable to the subject property. Claimant alleges that the value of its real property has been
diminished by $3,520,000 as a result of application of restrictive land use regulations to the
property by the City of Eugene.
C. This claim was scheduled for a public hearing before the Council in May 2007.
Shortly before the date scheduled for that hearing the Legislature amended Measure 37 to extend
the time for acting on claims. In June of 2007, the Legislature referred to the voters a measure to
revise Measure 37. The referral, Measure 49, was approved by the voters in November 2007 and
became effective December 6, 2007. On December 26, 2007 the Lane County Circuit Court
ordered the City Council to adopt a resolution approving or denying this claim, and to do so
based on Measure 37 as it existed on May 30, 2007 without taking into consideration the
provisions of Measure 49.
D. The City Manager has caused an investigation of the claim to be made and has
submitted to the City Council a Report and Recommendation on the claim. Based on the
analysis and discussion set forth in the Report and Recommendation, the City Manager
recommends denial of the claim.
NOW, THEREFORE,
Resolution - 1
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF EUGENE, a
Municipal Corporation of the State of Oregon, as follows:
Section 1. Based on the above findings, the analysis, findings and conclusions contained
in the Report and Recommendation of the City Manager, and the additional findings contained in
Attachment A to this Resolution, all of which are adopted and incorporated herein, the City
Council concurs with the recommendation of the City Manager and denies the Measure 37 Claim
of Charles Wiper, Inc. for the property identified as Assessor's Map 18-03-18-00, Tax Lot 300.
Section 2. A copy of this Resolution shall be forwarded to Charles Wiper, Inc., at its
mailing address of: Rohn Roberts and Michael Reeder, Arnold Gallagher Saydack Percell
Roberts & Potter PC, 800 Willamette Street, Suite 800, Eugene, Oregon 97401.
Section 3. This Resolution shall become effective immediately upon its adoption.
The foregoing Resolution adopted the 11 th day of February, 2008.
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Resolution - 2
ATTACHMENT A
ADDITIONAL FINDINGS IN SUPPORT OF DECISION OF CITY COUNCIL
DENYING WIPER MEASURE 37 CLAIM
1. Land Use Regulations
The Reeder Letter asserts that the city manager's interpretation of the term "land use
regulation" under Measure 37 is under inclusive. The plain language of Measure 37 limited the
definition of "land use regulation" as applied to local governments, to "[l]ocal government
comprehensive plans, zoning ordinances, land division ordinances, and transportation
ordinances." Measure 3 7 did not create an entitlement to relief for reduction in property values
caused by laws and regulations that are not "land use regulations." To the extent that Claimant's
claim is based on those provisions of the Eugene Code or other regulations or provisions which
did not constitute land use regulations under Measure 3 7, the claim lacks merit.
2. Enactment or Enforcement
The Reeder letter asserts that the City's interpretation of the plain language of Measure
37 fails for four reasons. First, no other jurisdiction has made the distinction between enactment
and enforcement of a land use regulation, and the state has clearly rejected such a distinction.
Second, the City's interpretation of Measure 37 as related to the Wiper claim is inconsistent with
the City's previous decisions on the Lane Plywood and DMB Green claims. Third, the City's
interpretation of the language of Measure 37 is unreasonable under PGE v. BOLl. Fourth and
finally, the City has enforced various land use regulations against the property through litigation.
Each of these arguments is addressed below.
a. No Other Jurisdiction Has Advanced Such an Argument
The Reeder letter provides no support for its assertion that no other jurisdiction has made
a distinction between "enactment" and "enforcement." There are literally thousands of claims
and decisions related to Measure 37, and the letter does not purport to review all of those to
determine whether such a distinction was made. The Reeder letter also references two decisions
on two claims by the State Department of Land Conservation and Development (DLCD) and
asserts that the decisions show that the state "cleady rejects" the Report and Recommendation's
distinction between enactment and enforcement of a land use regulation. Claimant misreads the
referenced DLCD decisions. In neither decision did DLCD explicitly reject the distinction made
by the Report and Recommendation. Most importantly, the Reeder letter fails to explain why
interpretations by other jurisdictions or DLCD are relevant to how a court would interpret
Measure 37. And, as explained below, the plain language of the measure demonstrates that such
a distinction exists.
b. Previous Waivers
The Reeder letter asserts that the City's differentiation between enactment and
enforcement of a land use regulation is inconsistent with its previous decisions related to the
Lane Plywood and DMB Green claims. Not only are the situations different, but even if they
were not, the prior decisions would not be controlling. The situations are different because in the
prior situations, the City concluded that actions had been taken that would constitute some level
of enforcement. Here, the claimant has failed to provide any evidence of any enforcement
following the effective date of measure 37, which is what measure 37 requires.
c. Meaning of "Enforce"
Claimant's argument that the mere existence of a land use regulation constitutes
"enforcement" of that regulation cannot stand in light of the plain language of Measure 37.
Measure 37 provided that a property owner might have a valid claim if a public entity "enacts or
enforces a new land use regulation or enforces a land use regulation enacted prior to [the
effective date of Measure 37]." If the mere existence of a land use regulation was sufficient, as
claimant asserts, then Measure 37 would not have drawn the distinction between "new"
regulations, and those enacted prior to the effective date of Measure 37. Claimant's
interpretation of Measure 37 gives no effect to that distinction or the words actually used in the
measure.
d. Enforcement through Litigation
Finally, Claimant asserts that the City has in fact enforced land use regulations on the
subject property through conditional use permit CU 81-6, a modification of CU 81-6, MD 95-13,
and conditional use permit CU 95-2. Claimant also asserts that the City has enforced land use
regulations against the subject property "in no less than two Court of Appeals cases and a variety
of Land Use Board of Appeals ("LUBA") cases." This argument again ignores the actual words
of Measure 37. For regulations that existed prior to the effective date of Measure 37, the
measure provided that a property owner had a valid claim if a public body "enforces a land use
regulation enacted prior to December 2,2004 . . .." By using the term "enforces" Measure 37
clearly contemplated government action enforcing a regulation after December 2, 2004, the
effective date of Measure 37. Action on the conditional use permits referred to in the letter took
place well before December 2, 2004. All the decisions rendered in the litigation referred to by
Claimant were also made before December 2, 2004. Thus, all of the "enforcement" actions
referred to by Claimant took place before the effective date of Measure 37 and therefore do not
constitute enforcement of a land use regulation under the plain language of the measure.
3. Restriction on Use: The Conditional Use Agreement
Claimant argues that the conditional use permit or agreement (CUP) applicable to the
property is a de facto land use regulation because it is the culmination of many land use
regulations. The plain language of Measure 37 does not support Claimant's argument. Measure
37 does not recognize defacto land use regulations. Measure 37 defines "land use regulation" as
"[l]ocal government comprehensive plans, zoning ordinances, land division ordinances, and
transportation ordinances." The CUP is not a comprehensive plan, zoning ordinance, land
division ordinance, nor a transportation ordinance.
As acknowledged by Claimant, the CUP is in fact a contract. Near the beginning of the
conditional use agreement, Claimant agreed, in part, that:
"Development of the project in strict compliance with the plans as submitted
and approved is necessary to protect the public health, safety and welfare.
Therefore, the public interest requires the City obtain from the Developer an
enforceable covenant to develop in accordance with the plans as submitted and
approved." (Emphasis added.)
N ear the end of the conditional use agreement, Claimant also agreed that:
"This Agreement shall be binding upon the heirs, executors, administrators and
assigns of both parties and is a condition and covenant running with the land and
binding upon the above-described areas of real property."
Claimant next argues that even if the CUP is not a land use regulation, it may some day
be amended or rescinded, at which time the City's land use regulations will return to force and
restrict the use of the subject property. While that may be a possibility, Claimant has no right to
have the agreement amended. In fact, Claimant obtained a financial benefit from the conditional
use permit and agreement, and is now seeking to keep the benefit of the agreement without
having to honor the burden of the agreement. Measure 37 does not apply to such agreements.
Claimant also argues that the CUP does not restrict 15 acres of the property. Claimant
ignores not only the specific provisions of the agreement in making that argument, but also the
"quid pro quo" to which Claimant agreed in order to get the benefits that Claimant sought from
the CUP. When the hearings official reviewed and ultimately approved the plans and application
Claimant submitted in order to obtain the conditional permit, the hearings official explained that
he was approving the CUP, in part, because of the buffer that would be left between the cemetery
and the neighbors - what the Claimant here is calling the "unplanned" acres. The hearings
official wrote:
"One approach might be to require as a condition of approval the retention of a
100 foot buffer area along the entire southern boundary but this may not be
necessary with more detail made available concerning the vegetation that exists
and will be retained in the buffer area and proposed location of the tombs and
fence. Without that information, if the buffer is to be less than 100 feet in depth,
it is impossible to determine whether the proposed use will be compatible with the
adjacent residences.
"* * * * [T]o be reasonably compatible, the cemetery use must be designed to
recognize the existing wooded character of this area of Eugene to the extent of
allowing a meaningful buffer area between the cemetery use and the residential
uses.
"In that the approval is for a two phased development, with the southern portion
being developed only after development of the area of the cemetery within the
proposed roads, there will be adequate time to address the details of the buffer
area and for the applicant to seek approval of a plan in that regard."
In light of those concerns related to compatibility with the adjacent properties, the
hearings official imposed as a condition of approval a requirement that the proposed buffer zone
in the southern portion of the site be a minimum of75 feet in width. That condition of approval
was carried forward in the Conditional Use Agreement that Claimant signed. Thus, contrary to
Claimant's suggestion that 15 acres of property are not covered by the CUP, all of the property is
covered. Moreover, if one compares the tax lot information included with the measure 37 claim,
to the tax lot information included in the CUP materials, it is clear that all of the property
covered by the measure 37 claim is included within, and restricted by, the CUP that Claimant
applied for and voluntarily signed.
4. Reduction in Value
Claimant asserts that the appraisal included in the claim is valid and was performed by
qualified and licensed appraisers. The appraisal, however, is based on removal of all of the
regulations included in the claim from the subject property so that it has the same potential for
development today as it had on Claimant's date of acquisition in 1929. As noted above and in
the Report and Recommendation, not all of the complained of regulations are "land use
regulations" under Measure 37; some are exempt; and some do not meet other requirements of
Measure 37. Unless a land use regulation meets every requirement under Measure 37, the
regulation does not give rise to a Measure 37 claim. The appraisal evidence submitted by
Claimant is based on the assumption that every regulation that applies to the property is
removed, including those regulations that, for example, protect public health and safety. The
true reduction in value, if any, as the result of regulations that actually meet all of Measure 37's
requirements is not discernable from either the claim or the appraisal.
5. Exemptions
Although the wording of this section is confusing, Claimant seems to be asserting that
even if some of the challenged regulations do fall into Measure 37's exemptions (prohibition of
public nuisances, protection of health and safety, compliance with federal law, etc.) the
remainder of the claim is valid. Claimant fails to analyze the regulations included within its
claim to determine or explain how the regulations avoid those exemptions. Claimant also fails to
explain why the CUP, even assuming that it would meet the definition of a "land use regulation",
would not be exempt given the language in the CUP that states that development in strict
compliance with the CUP "is necessary to protect the public health, safety, and welfare."