CONSERVANCY v. CITY OF GRESHAM. LUBA No. 2006-084 (Or. LUBA 9115/2006) (Or. LUSA, 2006) <br />which is within unincorporated Clackamas <br />County, and connect to SE Yellowhammer <br />Road. Accordingly, the city imposed Condition <br />of Approval 7 requiring that the applicant submit <br />as part of final plat documents: (1) a 20-foot <br />wide right of way or easement across the <br />residential lot within the Kingswood Heights <br />subdivision, dedicated to the county, (2) <br />construction plans for the access, and (3) a <br />county street construction permit. Before LUBA, <br />petitioners argued that there was no evidence in <br />the record that it was "feasible" to construct the <br />proposed secondary access, given that <br />Covenants, Conditions, and Restrictions <br />(CC&Rs) governing the Kingswood Heights <br />subdivision restrict all use of residential lots to <br />single-family dwellings and accessory <br />buildings.' According to petitioners, it is clear <br />under the Kingswood Heights CC&Rs that use <br />of a residential lot to construct a street or other <br />access for a neighboring subdivision is <br />prohibited. We remanded the city's initial <br />decision to address this issue. <br />On remand, the city adopted findings <br />concluding in relevant part that it is "feasible" to <br />construct the access road either because (1) the <br />CC&Rs can be reasonably interpreted to allow <br />roads that provide access to residential uses and <br />(2) in any case, the city has the legal authority to <br />condemn the right-of-way to provide secondary <br />access notwithstanding the CC&Rs. Petitioners <br />challenge those conclusions, arguing that the <br />CC&Rs are unambiguous <br />Page 4 <br />and clearly would prohibit the proposed access <br />road, and that the city lacks the legal authority to <br />condemn the right-of-way necessary to construct <br />the road. <br />A. Feasibility <br />As an initial matter, the city argues that the <br />legal requirement that local governments address <br />the feasibility of compliance with approval <br />criteria should be applied differently where, as <br />here, the issue raised regarding the feasibility of <br />compliance largely involves a legal question and <br />r <br />lastcse <br />the courts, not the city, have jurisdiction in the <br />final analysis to resolve that question. The city <br />recognizes that, in a line of cases based on <br />Meyer v. City of Portland, 67 Or App 274, 678 <br />P2d 741 (1984) and Rhyne v. Multnomah <br />County, 23 Or LUBA 442 (1992), the Court and <br />LUBA have held that, in a two-stage approval <br />process such as subdivision approval, where a <br />problem is identified that raises concerns <br />whether proposed development can comply with <br />applicable approval criteria, the local <br />government may, among other options, adopt <br />findings demonstrating that solutions to the <br />identified problem are "feasible," i. e., "possible, <br />likely and reasonably certain to succeed." <br />Meyer, 67 Or App at 280, n 5. In Rhyne, we <br />explained that: <br />"Assuming a local government finds <br />compliance, or feasibility of compliance, with <br />all approval criteria during a first stage (where <br />statutory notice and public hearing requirements <br />are observed), it is entirely appropriate to <br />impose conditions of approval to assure those <br />criteria are met and defer responsibility for <br />assuring compliance with those conditions to <br />planning and engineering staff as part of a <br />second stage. * * * <br />"Where the evidence presented during the <br />first stage approval proceedings raises questions <br />concerning whether a particular approval <br />criterion is satisfied, a local government <br />essentially has three options potentially <br />available. First, it may find that although the <br />evidence is conflicting, the evidence <br />nevertheless is sufficient to support a finding <br />that the standard is satisfied or that feasible <br />solutions to identified problems exist, and <br />impose conditions if necessary. Second, if the <br />local government determines there is insufficient <br />evidence to determine the feasibility of <br />compliance with the standard, it could on that <br />basis deny the application. Third, * * * instead <br />of finding that the standard is not met, it may <br />defer a determination concerning compliance <br />with the standard to the second stage. In <br />selecting this third option, the local government <br />is not finding all applicable approval standards <br />are complied <br />-2- <br />PC Agenda - Page 10 <br />