By Mary Kyle McCurdy | 6.5-minute read
Several attempts are currently underway to open up rural areas, including farm and forest lands, wildlife habitat areas, rural hamlets, and other areas outside our towns and cities to housing and commercial development. These proposed changes are likely to cause conflicts and increased costs for working farms and ranches and adversely impact rural towns.
Today we are going to focus on unincorporated communities. We will explain what this issue is, why it matters, and provide information for how you can share your concerns with decision-makers.
How we got here
In April, the Land Conservation and Development Commission (LCDC) began a months-long process to evaluate whether and how to allow more residential and employment development in Oregon’s unincorporated communities. They are also exploring whether it should be easier for unincorporated communities to expand their current boundaries—which would directly impact working lands and natural areas.
LCDC appointed a Rules Advisory Committee (RAC) to provide input to any changes needed to the existing rules on Unincorporated Communities. 1000 Friends is a member of the RAC. LCDC’s directions to the RAC encompass both housing and economic development.
After two RAC meetings, the staff of the Department of Land Conservation and Development (DLCD) published a draft set of administrative rules for Unincorporated Communities. 1000 Friends has many concerns about the draft rules, which we shared orally and in writing with the RAC and DLCD. Our main concerns are summarized below; you can read our full comments here.
Our two overarching concerns:
- The draft rules are not focused on the housing needs of those who live and work in rural Oregon—instead, they are focused on outside people and businesses who want to build second homes and vacation rentals and develop commercial uses that take advantage of access to nearby water or energy, but could overrun the rural arealike data centers.
- The draft rules would also create competition between unincorporated communities and nearby rural towns and cities for scarce public funding for infrastructure. Rural cities across Oregon need funding to upgrade existing water and sewer systems and to repair roads, so they can provide for more housing and economic development—inside their urban growth boundaries (UGBs). These are the places that have stores, schools, and jobs. Oregon should support and reinforce these cities and towns, not set up an uneven playing field.
The DLCD staff plans to issue a second set of draft rules—which we hope will be responsive to the concerns we and others raised—and then open up a public comment period on Sunday, November 1. LCDC plans to adopt new rules guiding development in UCs at its meeting in February 2027.
When the second set of draft rules is released, we will send out a summary, talking points, and how you can share your concerns officially with LCDC.
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You can also take important actions now. Your county commissioners and county planning director need to hear from you now about any concerns you have about the current set of draft rules. Copy your state Senator and Representative with your letter.
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What are unincorporated communities?
Oregon has over 200 unincorporated communities (UCs), scattered across the state, most of which have existed for many decades. You can see the official list here, by county.
These communities are located outside the UGBs of the state's towns and cities and have chosen not to incorporate as cities. Unincorporated communities range widely in size, population, and in the mix of existing uses. UCs are categorized in existing rules into one of four types: Rural Service Area, Rural Unincorporated Community, Urban Unincorporated Community, and Resorts.
UCs are most often served by rural roads, wells, septic systems, or rural water districts. Many have lands available for development. But some interests are pushing to allow more housing and commercial growth in Oregon’s rural UCs—not related to rural needs or economies—mainly by making it easier for at least some UCs to expand onto surrounding farm and forest lands.
Oregon should focus on ensuring that those who need to live in rural areas—such as those who work on farms and ranches and in forestry, in rural-based industries, and in places that process Oregon's bounty and transport it to our tables—have affordable housing available in rural communities and towns. These draft rules are going in the opposite direction.
What’s wrong with the draft rules?
Although a stated rationale behind this rulemaking was to increase housing for those who live and work in rural areas, the draft rules have strayed far from these principles. Following are our main comments about the rules; for more details please see our written testimony.
- The Commission has not provided any facts about any of the UCs in question, or even a fair sampling of them. No information has been provided regarding the buildable lands, infrastructure, density, mix of uses, incomes, maps of the UCs, or any reasonable sampling of them.
- However, we do have some information that 1000 Friends brought forth, bringing into question whether any rulemaking is needed at all. For example, a Deschutes County report provides clear evidence that the county already has more than enough vacant residential parcels than it is projected to need for the next 20 years, based on the county’s thorough evaluation of existing residential opportunities for housing outside all UGBs—and inside the rural communities, resorts, and rural residential areas of the county. This is a clear example of why the Commission should pause this rulemaking until basic data is gathered about the status of existing UCs, and what if anything is needed to increase housing opportunities for those who live and work in these rural areas.
- The proposed rules create a “city lite” option with no obligation for counties to actually plan for, and invest in, the housing rural workers and residents need. The proposed rules allow counties to designate and expand the community boundaries of urban unincorporated communities (UUCs) and some rural communities (RCs) for housing, without holding them to the same housing standards that cities must meet. There is no obligation to assess the incomes, ages, and housing needs of those in the rural area and then tie those needs to the housing proposed to be allowed in the UUCs or RCs.
- This puts UCs and nearby incorporated cities and towns on an uneven and unfair playing field. Cities and towns have assessed their housing needs, provided land, and prepared and invested in public facilities to meet their current and future housing needs. These places are where schools, stores, and jobs are primarily located. Many of these rural towns and cities need and would like housing and economic development. If LCDC and other decision makers actually want to produce more housing more quickly, these cities and towns are where scarce public investments in infrastructure should be made.
- The draft rules opens up many UCs and RCs to become places for second homes and short term rentals, further pricing out those who actually need to live in rural Oregon.
- The draft rules allow a UC to expand based simply on “growth capacity,” not on actual rural need. What does “capacity” mean? Capacity of what, for what? For example, if an area has enough water and/or electrical capacity for a data center, can a data center be located there? Or any other large industrial user who is looking for easy access to water or power.
Oregon should focus on ensuring that those who need to live in rural areas—such as those who work on farms and ranches and in forestry, in rural-based industries, and in places that process Oregon's bounty and transport it to our tables—have affordable housing available in rural communities and towns. These draft rules are going in the opposite direction.
To meet the actual housing needs of most Oregonians, we should invest in the towns and cities in these same rural areas—not compete with them. From Baker City to Coos Bay, from Pendleton to Ontario, from Lakeview to Grants Pass, Oregon’s rural towns and cities have the land to support more housing and jobs, but they need funding for infrastructure including new and upgraded roads, water and wastewater systems, and broadband/fiber access.