August 24, 2022

Haleigh King, Associate Planner
Deschutes County Community Development 117 NW Lafayette Avenue
Bend, Oregon 97703

Re: Deschutes County File Nos. 247-21-001043-PA and 247-21-001044-ZC DLCD County Amendment ID No. 28242/Deschutes County Amendment 001-22

Dear Ms. King,

My name is Ian Isaacson and I am the Board Co-Chair for the Oregon Chapter of Backcountry Hunters & Anglers (OR BHA). Our organization seeks to ensure Oregon’s outdoor heritage of hunting and angling in a natural setting, through the education and work on behalf of wild public lands, waters, and wildlife. Representing OR BHA, our 300+ members in Deschutes County, and myself as a resident of this county, I would like to submit the following comments regarding Deschutes County File Nos. 247-21-001043-PA and 247-21-001044-ZC.

We understand that the applicant is requesting to change the designation of 710 acres from Agriculture to Rural Residential Exception Area and change the zoning of the same property from Exclusive Farm Use Terrebonne Subzone to Rural Residential with a ten-acre minimum parcel size.

As hunters and conservationists living in Deschutes County, our members have seen firsthand the dramatic decline in our mule deer herds. ODFW highlights the fact that in our Central Oregon Wildlife Management Units, of which the subject property lies within, low survival rates in both fawns and adult deer continues to push populations below management objective in all units.

A decision allowing the change in designation of the subject property would set forth a precedent – by enabling the re-zoning of farm land for development – that would only further the loss of critical habitat for Deschutes County’s wildlife. Approval of these applications for zoning exception would provide a road map for future habitat fragmentation and increased disturbance in undeveloped farmland and rangeland. The open space provided by Exclusive Farm Use lands is not only important in maintaining the historical and rural characteristics of these lands in Central Oregon, but also in preserving the wildlife habitat function and ecosystem values provided by such lands.

Thank you again for the opportunity to provide comments. Based on our review of the application materials, we believe that the applicant has not met – and is unlikely to be able to meet – the burden of proof required to obtain a zoning exception. As such their application for new zoning dedication should be denied. The request in this application is not justified by the facts on the ground.

Ultimately, our wildlife, – especially our mule deer herds – are already markedly threatened by continued development and growth in Deschutes County, even when that growth follows in accord with longstanding policy. The last thing our local wildlife habitats need are broad-scale exceptions to existing zoning laws, exceptions that would prioritize development over the health of the native animals that also call our county home.

Thank you,

Ian Isaacson | Co-Chair, Oregon Chapter of Backcountry Hunters & Anglers