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Board orders de novo review of Tumalo text amendment allowing RV parks; schedules full hearing
Summary
The Deschutes County Board of Commissioners accepted a hearings officer recommendation and voted to call up a proposed text amendment that would allow RV parks in the Tumalo Commercial District, triggering a de novo board hearing and a 100-day procedural timeline.
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The Deschutes County Board of Commissioners voted on Sept. 3 to accept review of a hearings officer recommendation and to hold a de novo hearing on a pending text amendment that would allow RV parks as a conditional use in the Tumalo Commercial District.
Audrey Stewart, associate planner in the county’s planning division, told the board the application had qualities of both quasi-judicial and legislative amendments and that the hearings officer recommended approval but left some matters for the board to resolve. Staff recommended the board initiate review to avoid procedural uncertainty and to provide additional public input.
Will Groves, planning manager, told commissioners RV parks and campgrounds are defined differently under state statute: campgrounds generally have short-occupancy limits while RV parks—if allowed for long-term occupancy—function like a type of manufactured-home park and can be used for permanent residency. Groves said rural density limits (one unit per 10 acres in some zones) and other code constraints limit how widely the RV-park allowance might spread in county rural lands.
The applicant’s attorney, Adam Smith, urged the board to call up the case to reduce the risk of procedural appeals. County counsel and staff recommended the same. The hearings officer who presided over the initial proceeding was identified in the record as Tommy Brooks; staff said the officer issued a recommendation rather than a final decision.
The board approved board order number 2025-040, initiating its own review and directing staff to schedule a full de novo board hearing and to publish notice. The board clerk confirmed a 100-day statutory timeframe applies to the matter.
Commissioners discussed related policy questions during the session, including whether allowing RV parks in Tumalo might encourage other text-amendment requests and how RV parks differ from campgrounds and short-term rentals. Staff noted short-term rentals currently have no county density cap outside resource zones. Legal counsel said calling up the case would reduce procedural risk and the chance of appeals focused on process rather than project merits.
The board did not resolve the substantive merits of the amendment at the Sept. 3 meeting; scheduling and public-notice steps were to follow.

