The 2023 Oregon legislative session was unlike any other. More than one-third of the legislators were new, and almost two-thirds had never been in the Capitol for a session due to the Covid-19 pandemic. Both the Senate and House had new leadership, the governor was new, and there was a six-week walkout by some Republican and Independent senators.
Nonetheless, together we succeeded in achieving passage of some excellent bills that will strengthen and move forward Oregon’s land use program – especially in the areas of housing, natural and working lands, and wildfire resilience. And we (mostly) succeeded in defeating bills that would harm the integrity of Oregon's land use program. A few bills, however, passed that weaken Oregon’s land use planning program. Other bills that we supported but that did not make it to the finish line are also listed, and we hope they will be back in future sessions. We’ve also included a partial list of bills that were introduced into this legislative session that would have weakened Oregon’s land use planning program – but with your help, they did not pass!
Because of the walkout, many individual bills that we supported were packaged into larger thematic bills so they could quickly move to the finish line, if the Senate achieved a quorum. Therefore, many bills that we and you were participating in this session did pass, but as part of a larger bill with a different bill number.
Below are highlights from the session.
Bills that passed and now support our land use system
Bills that passed and we are neutral on
Bills that passed and now threaten the land use system
Bills that passed & now support our land use system
Housing
HB 2001 Housing for All
SUPPORTED & PASSED
What it does: This bill establishes the Oregon Housing Needs Analysis (OHNA) framework and ensures that Oregon cities and the state enact a full set of land use tools, related investments, and other strategies to support building housing for all, in every neighborhood. (The OHNA was initially outlined under HB 2889, which is now a technical clean-up bill.)
Why it matters: OHNA is a long-overdue update to the way the state and cities plan for, invest in, and ensure housing production, so that every Oregonian has the opportunity for an affordable housing choice in every community, and we live up to land use Goal 10, Housing. It will also take pressure off our lands that produce food and fiber and provide clean air, water, and natural habitat.
HB 2984 Reuse Commercial Buildings for Workforce Housing
SUPPORTED & PASSED
What it does: This bill will allow, within UGBs, the conversion of buildings from commercial use to housing without a zone change or conditional-use permit. It prohibits local governments from requiring more parking and limits collection of system development charges.
Why it matters: It will open possibilities for reusing buildings that are well-located and soundly built, but for which there may no longer be viable commercial use, especially after pandemic-related changes to how and where we shop and work. These structures can still provide much-needed housing in our existing communities while preserving existing buildings.
HB 3151 Manufactured Dwellings and Parks
SUPPORTED & PASSED
What it does: This bill offers financial protections and incentives to tenants in manufactured home parks, expands the definition of affordable housing to include manufactured home parks, and expands the state’s loan authority to include constructing new parks (not just acquisition of existing parks).
Why it matters: This bill continues and expands Oregon’s commitment to one of the most affordable home ownership opportunities for Oregonians, and that can be developed fairly quickly: manufactured housing parks.
HB 3197 Clear and Objective Residential Development
SUPPORTED & PASSED
What it does: HB 3197 clarifies that clear and objective standards for residential development apply only inside urban growth boundaries (UGBs).
Why it matters: Residential development makes sense within our UGBs; it does not make sense outside UGBs, where the land is zoned mostly for farming, forestry, and natural resources. These areas are not residential zones. Instead, this is where housing is minimized, so as to support, and not conflict with, farming and forestry and not interfere with streams, habitat, wetlands, and other natural areas. In these areas, statutes and rules have properly given local governments discretion to weigh factors and consider conditions in deciding whether a residential use will adversely interfere with these resource uses.
HB 3309 Housing Accessibility
SUPPORTED & PASSED
What it does: This bill requires the Housing and Community Services Department to assess the amount of housing it funds that includes accessibility features, estimate the amount of unmet accessible units in the state, review rules and building code standards that are applicable to accessible units, and file a report with the legislature in September 2024 with its findings and any recommendations.
Why it matters: This bill aims to increase our overall supply of accessible housing in Oregon.
HB 3395 Housing Package
SUPPORTED & PASSED
What it does: HB 3395 contains many housing proposals that we supported, on some of which we were the lead advocates. Among other things, the bill:
- Makes it easier to use commercially zoned land inside urban growth boundaries (UGBs) for affordable housing.
- Requires all cities with populations over 2,500 to allow duplexes on all single-family lots in residential zones.
- Makes it easier to site emergency housing shelters inside UGBs.
- Allows residential developments of four or more attached units that share a common kitchen on residentially zoned lands.
- Directs grants for community housing supporting agricultural employees.
- Provides funding to local governments to support housing development efforts.
Why it matters: These provisions make it easier to develop a range of housing for all, including people with moderate and lower incomes, in all communities.
SB 406 Housing for All
SUPPORTED & PASSED
What it does: SB 406 adds the cities and certain unincorporated communities in Tillamook County to the list of cities around the state that must comply with the middle housing provisions of 2019’s HB 2001 (not to be confused with this year’s housing bill with the same number). That previous legislation was directed at cities with more than 10,000 people, of which there are none in Tillamook County.
Why it matters: With this bill, the seven incorporated cities and the named unincorporated communities in Tillamook County will have to allow middle housing in all their residential zones, and they will also be potentially eligible for funding and planning assistance from DLCD. We applaud the county and its cities for voluntarily choosing to participate in this program, to provide more diverse and affordable housing options for its residents and workers.
Jump to housing bills that did not pass
Natural & Working Lands, Food Systems, and Rural Climate Solutions
HB 3409 Natural & Working Lands Package
SUPPORTED & PASSED
What it does: This package bill contains many natural and working lands proposals that we supported, including some in which we were the lead advocates. Among other things, the bill:
- Includes the Natural Climate Solutions provisions, which will provide financial incentives and technical support to farmers, ranchers, and other land managers to voluntarily continue or adopt climate-friendly solutions, including soil-health practices, for such things as carbon sequestration.
- Establishes the community green infrastructure program to provide direct social, environmental, and economic benefits to communities across this state through green infrastructure, such as urban forestry, green stormwater-management systems, supporting native seed banks and native plant nurseries, replanting after wildfires, and more.
- Directs the Land Conservation & Development Commission (LCDC) to adopt administrative rules identifying low-conflict areas in eastern Oregon for the siting of large-scale solar facilities. LCDC will consider and adopt, as needed, with recommendations from a Rulemaking Advisory Committee, revisions to rules that implement Goal 2 (Exceptions Process), Goal 3 (Agricultural Land), Goal 4 (Forest Land), and Goal 5 (Natural Resources, Scenic and Historic Areas, and Open Spaces).
- Renames the Oregon Global Warming Commission to the Oregon Climate Action Commission, revises its makeup, and provides additional direction and support to the commission.
Why it matters: The bill recognizes the potential of working and natural lands to address climate change by sequestering carbon, and supports the land-stewardship activities of farmers and ranchers. It reinforces the reasons to protect farm and forest lands.
HB 3410 Rural Economic Development
SUPPORTED & PASSED
What it does: This bill provides funding for various rural economic-development opportunities around the state, including increased funding to the Department of Agriculture to support grant programs that assist meat processors in meeting the requirements of the new State Meat Inspection Program.
Why it matters: This funding will create new opportunities for Oregon ranchers to bring meat to the retail market.
SB 507 Updating the Farm Direct Marketing Law
SUPPORTED & PASSED
What it does: This bill updates Oregon’s Farm Direct Marketing law, by allowing farmers to bring certain low-risk, value-added products to farmers markets and their farm stands. This has strengthened local and regional food systems, as countless farmers and communities, particularly in rural Oregon, have benefited from the increased economic capital generated by farm-to-consumer sales.
Why it matters: By expanding the allowed product lines, the bill expands the economic benefits to growers from direct farm marketing.
SB 5506 Omnibus Funding Bill
SUPPORTED & PASSED
What it does: This bill includes funding for critical activities related to working lands, including:
- The Morrow and Umatilla Drought Relief Aquifer Recharge and Aquifer Storage and Recovery Project
- OSU Extension Service’s Center for Small Farms and Community Food Systems, which provides site-specific technical assistance and research to all farmers interested in incorporating climate-smart, healthy-soil practices
- The Oregon Community Food Systems Network o develop regional food-system infrastructure and support small-scale farms and ranches
- Oregon Farm to School grant program, supporting education, school food programs, and food producers across the state
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Transportation for All
HB 3014 Alternative Transportation Options for Schools
SUPPORTED & PASSED
What it does: This bill gives greater flexibility to school districts in funding multimodal, active transportation options for kids to get to school.
Why it matters: Providing safe ways for kids to get to school on foot, bike, and bus means healthier kids and fewer cars on the road.
Jump to transportation for all bills that did not pass
Climate
HB 3630 State Energy Strategy
SUPPORTED & PASSED
What it does: This bill requires the State Department of Energy to develop a comprehensive strategy to optimally achieve the state’s energy policy objectives, including renewable energy.
Why it matters: The current lack of a state-level energy plan significantly hinders integration of renewable energy needs with agricultural, natural resources, ranching, forestry, coastal resources, and community needs. This comprehensive state energy assessment and strategy will set the stage for a more coordinated, public-oriented system of energy generation and transmission.
SB 5506 CFEC Omnibus Funding
SUPPORTED & PASSED
What it does: This omnibus funding bill includes funding to continue implementation of LCDC’s Climate Friendly & Equitable Communities program by cities within the major urban areas of the state.
Why it matters: To reduce our transportation-related greenhouse gas emissions, it is critical that cities have funding to plan for climate-friendly neighborhoods, with housing and transportation choices.
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Wildfire Resilience & Preparedness
SB 80 State Hazard Mapping
SUPPORTED & PASSED
What it does: This bill reclassifies the state wildfire map as a hazard map (not risk) with three hazard levels and adds an “unclassified” category. It also focuses community outreach and education and preparedness and resiliency investments, assistance, and standards in high-hazard areas and areas with vulnerable populations.
SB 80 also establishes several funds and programs: the Landscape Resiliency Fund, Community Risk Reduction Fund, and Wildfire Home Preparedness Program for these purposes. The home-preparedness program will aid in the retrofitting and building of dwellings to be resistant and resilient to wildfire, focusing on economically and socially vulnerable communities.
Why it matters: Senate Bill 80 maintains the map’s scientific integrity of indicating the exposure to wildfire hazard that exists based on landscape-scale climate, weather, topography, and vegetation. This will enable the map to be more effectively used as originally intended: as a guide for where to focus investments, technical assistance, on-the-ground crews, infrastructure protection, evacuation planning, and appropriate regulations to make Oregon families and their communities more wildfire prepared and resilient.
SB 5506 Land Use & Wildfire Omnibus Funding
SUPPORTED & PASSED
What it does: This omnibus funding bill includes several provisions related to land use and wildfire:
- Funding for the Oregon Conservation Corps which, among others things, carries out defensible space work
- Funding for wildfire mitigation.
Jump to wildfire bills that did not pass
I-5 Bridge Replacement
HB 5005 Interstate Bridge Replacement Funding
MIXED SUPPORT & PASSED
What it does: There were several different policy attempts to fund Oregon’s portion of the I-5 Bridge Replacement Program, with HB 2098 being the policy bill heard in the Joint Committee on Transportation in the earlier part of the session. Several policy disagreements existed with that legislation, and it did not pass. This, combined with the walkout, left an unclear path forward on how Oregon was going to navigate this transportation funding question. In the last days of session, the legislature made an unprecedented move to pay for the entirety of this project from the general fund.
Why it matters:We support replacing the I-5 bridge with a seismically safe replacement that expands transportation options over the Columbia River. Our concerns have centered on how the current project design expands Interstate 5 in North Portland and Hayden Island. Highway expansions negatively impact the surrounding community’s air quality, induce more driving and greenhouse gas emissions, and dramatically increase the costs of this project, among other negative impacts. Given that major highway projects in Oregon continue to go over budget, it is concerning that we have now doubled down on using the general fund instead of transportation funding sources for this project, as the general fund is used for things like education and housing. ODOT as a whole is heading into a bleak economic outlook, so any bill that changes their financial picture and obligations is worthy of careful consideration.
Bills that did not pass
Housing
HB 2980 Housing Loan Fund
SUPPORTED & STALLED
What it does: This bill would have established a state revolving loan fund to fill financing gaps in developing housing for people with moderate incomes, available for housing for rent or ownership, multifamily or single family.
HB 2981 Housing Production Funding
SUPPORTED & STALLED
What it does: This bill would have provided three sensible solutions to alleviate identified barriers to producing housing for people with moderate incomes.
Why it matters: These resources are not available today and would rapidly boost housing production:
- Infrastructure Grant/Loan Fund
- Oregon Land Fund – capital for land acquisition and predevelopment costs
- Workforce Housing Construction Guarantee Fund, especially for rural markets.
HB 2983 Manufactured Dwellings and Parks
SUPPORTED & STALLED
What it does: This bill would have appropriated funding to acquire and rehabilitate manufactured home parks and to construct new ones, by nonprofit organizations, co-ops, and housing authorities. It also would have funded model codes for the development of manufactured dwelling parks and measures to ensure that cottage clusters may include manufactured dwellings. This would have expanded Oregon’s commitment to one of the most affordable, quick-to-build home ownership opportunities for Oregonians: manufactured housing parks that are owned by the residents, a nonprofit organization, or a co-op.
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Natural & Working Lands, Food Systems, and Rural Climate Solutions
HB 2728 Double Up Food Bucks Expansion
SUPPORTED & STALLED
What it does: This bill would have expanded Double Up Food Bucks Oregon, a matching program for recipients of supplemental nutrition assistance. Currently under the program, tor every dollar spent on SNAP-eligible foods at participating farmers markets, farm stands, CSA programs, and grocery stores, shoppers receive an additional dollar to spend on Oregon-grown fruits and vegetables.
HB 2998 Soils Health
SUPPORTED & STALLED
What it does: This bill would have expanded and leveraged existing programs to provide voluntary, incentive-based support for Oregon farmers to increase soil health through financial incentives, technical assistance, outreach and education, research, and other resources.
HB 3244 Agriculture Competitiveness Study
SUPPORTED & STALLED
What it does: This bill would have required a comprehensive study of competitiveness, strengths, and challenges of Oregon agriculture within the US domestic market.
HB 3366 Oregon Agricultural Heritage Program Funding
SUPPORTED & STALLED
What it does: This bill would have continued and expanded funding for the Oregon Agricultural Heritage Program (OAHP) through Oregon Watershed Enhancement Board. If fully implemented, OAHP would have provided transition planning services for farmers and ranchers and leveraged large amounts of federal funding to help willing families invest in permanent or long-term protection of their farms and ranches.
SB 437 Food Production in Planned Communities
SUPPORTED & STALLED
What it does: This bill would have allowed residents of planned communities to grow food, despite any covenants or homeowners association requirements to the contrary, a common-sense proposal.
Why it matters: Raising vegetables, growing fruit trees, raising chickens and honeybees, and other similar activities on one’s residential lot should be encouraged, not prohibited.
HB 2203 RVs on Exclusive Farm Use Land
OPPOSED & FAILED
What it does: This bill would have temporarily allowed a recreational vehicle to be placed on exclusive farm use (EFU) land, under the guise of providing security. This bill had no real safeguards to assure its temporary nature, and therefore could have become just another bill allowing dwellings on farmland that are not needed, and that increase conflicts with farming.
HB 2210 Splitting Farmland & Forest Lands into Small Parcels
OPPOSED & FAILED
What it does: This bill would have allowed farmland and forest lands to be split into smaller parcels.
Why it matters: Smaller parcels make it more challenging and expensive to engage in agriculture or forestry, including by making it very difficult to piece together enough land for a viable operation.
HB 2487 More Weddings & Events on Farmland
OPPOSED & FAILED
What it does: This bill would have allowed lands zoned for exclusive farm use east of the summit of the Cascade range to be used for weddings or events.
Why it matters: This would have inflicted yet another “cut” into the fabric of Oregon’s farm and ranch lands, adding to the already too-long list of nonfarm activities that are allowed on EFU land.
HB 2781 Salem-Area Bridge District
OPPOSED & FAILED
What it does: This bill would have authorized the creation of a bridge district in the Salem area as a first step toward building another bridge across the Willamette River in Salem. There are already local and regional transportation-planning processes through which a bridge or any other transportation projects should be evaluated.
Why it matters: This would have authorized the creation of an unnecessary, additional layer of transportation government.
SB 648 Vacation Rentals on Working Lands
OPPOSED & FAILED
What it does: This bill would have allowed vacation rentals in any residence on farm, forest, and farm/forest lands.
Why it matters: This would have created conflicts with working farm and forest lands, and in many regions, it would have exacerbated housing unaffordability by converting needed housing to short-term rentals.
SB 1087 Restaurants on Lane County Farmland
OPPOSED & FAILED
What it does: This bill would have allowed restaurants with 25-car parking lots and 5,000-square-foot seating areas on EFU land in Lane County, without the protections that the Land Conservation and Development Commission (LCDC) has already determined are necessary for food sales on farmland.
Why it matters: Although labeled as a “pilot project” in Lane County, it would have opened the door for allowing large restaurants on farmland across Oregon.
Jump to natural & working lands bills that passed & now support our land use system
Jump to natural & working lands bills that passed and now threaten our land use system
Transportation for All
HB 2619 Oregon Transportation Commission Reform
SUPPORTED & STALLED
What it does: This bill would have revised and expanded the Oregon Transportation Commission to ensure regional balance and equity. The current OTC has no requirements for geographic distribution, or specific seats for tribal communities or specific representation for those who are disabled, among other represented communities.
Why it matters: The OTC is the highest transportation decision-making body in Oregon. Its responsible for highway projects, tolling, our public transit strategy, and so much more. Ensuring voices from every corner and community in Oregon helps ensure better transportation outcomes for all.
HB 2677 Fix It First
SUPPORTED & STALLED
What it does: This bill would have placed ODOT’s Fix it First Maintenance policy in state statute. Fix it First implies that the agency maintains current roads before expanding and building new ones.
Why it matters: While ODOT maintains a Fix it First policy, maintenance budgets are still underfunded, and Oregon’s roadway system state of good repair has been declining. By placing this in state law, new road projects would have had to prove they have accounted for maintenance budgets, and wouldn’t harm the state’s ability to maintain the state of good repair on our roads.
HB 3484 Greenhouse Gas Modeling
SUPPORTED & STALLED
What it does: This bill would have directed the Environmental Quality Commission to set targets for reducing greenhouse gas emissions from transportation throughout Oregon, similar to policies passed by Colorado.
Why it matters: Transportation makes up 40 percent of greenhouse gas emissions in Oregon. Modeling and measuring emissions from transportation projects is a first step in allowing the state to plan our transportation investments in a way that systematically reduces emissions, and in turn meeting our state climate goals.
Jump to transportation for all bills that passed & now support our land use system
Climate
HB 2659 Throws out Climate Friendly & Equitable Communities Program
OPPOSED & FAILED
What it does: This bill would have repealed the climate rules adopted by LCDC that are applicable to Oregon’s eight major urban areas.
Why it matters: The Climate Friendly & Equitable Communities program is designed to reduce climate-damaging emissions by integrating land use and transportation planning to reduce the need to drive and increase safe, accessible walking, biking, and transit. The rules were adopted after extensive public engagement. We look forward to now moving ahead to implement this important program.
Jump to climate bills that passed & now support our land use system
Wildfire Resilience & Preparedness
SB 509 Make Oregon Communities More Wildfire Prepared and Resilient
SUPPORTED & STALLED
What it does: This bill would have continued and expanded next steps in a wildfire-resilient Oregon.
Why it matters: It would have established neighborhood risk-reduction programs to provide training, grants, and investments in community defensible space and home hardening, and it would have better coordinated and aligned state agencies and other entities to support wildfire-risk reduction. It also would have established the Home Hardening Assistance Fund, focusing those investments on people with higher vulnerabilities and lower incomes in high-risk areas.
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UGBs
HB 2795 Prohibiting Golf Courses from Designation as Buildable Land
OPPOSED & FAILED
What it does: This bill would have prohibited including any golf courses inside UGBs from being considered as “buildable” lands in a city’s buildable-lands inventory, which determines where housing can be built, even though golf courses have often been developed when the golf use no longer makes sense.
Why it matters: This bill would have meant omitting potentially buildable lands for housing, and adding pressure to expand UGBs, including onto productive farmland.
HB 3191 Premature Expansion of UGBs into Urban Reserves
OPPOSED & FAILED
What it does: HB 3191 would have allowed expansion of urban growth boundaries (UGBs) into urban reserves without application of the land use goals.
Why it matters: This bill would have undermined the purpose of urban reserves, by allowing premature UGB expansions into reserves without application of the land use goals, and under conditions that could be challenging to enforce and that risk deflecting city planning and investments away from lands already inside the UGB.
HB 3414 UGB Expansions Without Land Use Laws
OPPOSED & FAILED
What it does: The base bill that we initially supported would have established a Housing Production & Accountability Office in the Department of Land Conservation and Development (DLCD), and it would have required local governments to grant adjustments from certain local regulations for residential development. However, a late amendment, ultimately adopted, would have also allowed cities to expand their urban growth boundaries without the application of land use laws
Why it matters: The base bill was designed to make it easier to build housing on lands zoned for residential development inside UGBs – a good thing. But, the problem addition, crafted by housing developers, would have introduced two major problems: First, it would have undermined our state’s urban growth boundary system, including the publicly accountable process for establishing a UGB’s boundaries. Second, it would have spurred the building of mostly market-rate housing at the edge of our communities, rather than weaving affordable housing into our cities closest to where people already live, work, and access services. We already have ample land, well-located and available within our UGBs, where housing can best help meet people’s needs – and much of it needs infrastructure. We need to turn to land readiness.
SB 1051 Undermines UGBs and Urban Reserves
OPPOSED & FAILED
What it does: This was another bill that would have allowed UGB expansions into urban reserves without application of land use laws.
SB 656 UGB Expansion without Land Use Laws
OPPOSED & FAILED
What it does: This was yet another bill that would have allowed expansion of UGBs without application of statewide planning goals
Why it matters:This bill would have diverted public investments away from lands inside UGBs, where they should be focused to make existing urban land development-ready.
Rulemaking
SB 42 Agency Rulemaking
OPPOSED & FAILED
What it does: This bill would have thrown obstacles into normal agency rulemaking done to implement laws passed by the legislature.
Bills that passed & we are neutral on
Semiconductors
SB 4 Semiconductors
NEUTRAL & PASSED
What it does: SB 4 makes $210 million of state money available to assist Oregon’s semiconductor industry. It helps semiconductor companies compete for federal funding made available by the CHIPS and Science Act, and it supports higher-education institutions, workforce development, and site readiness for semiconductor expansions. The bill gives unprecedented authority to the governor to bring a certain number of sites, of specific sizes, into an urban growth boundary (UGB) by executive authority – only if there is no other available land for possible semiconductor expansion.
Why it matters: Semiconductors are one of Oregon’s major industries, and the bill’s financial and educational incentives will help grow our high-tech workforce for the future and bring existing industrial lands to full readiness. As Oregon assists this industry, we must also protect our other economic pillars, like agriculture, forestry, and tourism. The governor’s special executive authority expires at the end of 2024, and land brought inside a UGB under this law would be removed from the UGB if federal funding is not awarded for the project at hand. As a result of this SB 4 process, cities across the state have put forward industrial sites within their UGBs that are large and well-suited to high-tech development; we believe that the governor's executive authority will not be needed.
Bills that passed & now threaten the land use system
Natural & Working Lands, Food Systems, and Rural Climate Solutions
SB 70 More Houses on Eastern Oregon Farmland
OPPOSED & PASSED
What it does: Expands the farmland available to be rezoned to residential use for the 100 homes allowed under 2021’s SB 16. Those homes could be clustered or individually sited on some farmlands throughout the Eastern Oregon Border Region.
Why it matters: SB 70 now opens up farmland in irrigation districts and in the Snake River Valley viticulture area (AVA) to these homes, which are not related to farming or ranching.
HB 3382 Deep Draft Navigation Channels
OPPOSED & PASSED
What it does: In its original form, this bill would have allowed deep channel dredging and other activities in five Oregon ports, without application of statewide land use planning Goal 16, Estuaries. We and many other groups and leaders opposed this bill. Through our collective advocacy, the bill was amended to apply only to the Port of Coos Bay, and now requires an applicant to go through the land use “exceptions” process if the applicant wants to dredge the deep water channel and engage in certain other activities in that estuary. However, it also recognizes that such dredging and other activities can qualify for an exception.
Why it matters: While the amended bill is “less bad,” the process was unacceptable and the result may have unintended consequences. HB 3382, in effect, amended Goal 16 at the request of a single development interest, and without the thoughtful, transparent process that would normally have occurred in amending a land use goal or any related rule. And, it is not clear that a change to Goal 16 and the exceptions process was even needed for this project, since other developments in estuaries, including dredging, have been allowed – when they have gone through the appropriate evaluation and mitigation analysis required.
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