Urban Growth Boundary Amendment FAQs

Each Oregon city is surrounded by an urban growth boundary (UGB); a line drawn on planning maps to designate the area within which a city expects to grow over a 20-year period. The purpose of UGBs in Oregon is to protect the state’s farmland and forests from the pressures of urbanization and sprawl - the UGB is where the city ends and the farms and forests begin. Within a city’s UGB, growth can occur in the form of new houses, industrial facilities, businesses, or public facilities such as parks and utilities. Restrictions on land outside of a UGB protect farmland and forests and prohibit urban development.

Generally speaking, city limits are the municipal boundaries where city zoning applies and where city services are provided. The UGB is typically an area larger than the city limits that is designated for future urban uses and is intended to provide a 20-year supply of land to accommodate future growth. Land in the UGB remains in Deschutes County until such time that the property owner petitions the city for annexation of the land into the city.

Currently, the Sisters UGB is the same as the Sisters City Limits – meaning that there is no unannexed land inside the Sisters UGB that can be brought into the City for urban uses.

In Oregon, cities may expand or amend their UGB if it can be shown that existing land within the existing UGB is not sufficient to support new homes, businesses, and other development projected over the next 20 years. Most cities in Oregon are required to rely on population forecasts conducted by Portland State University’s Population Research Center (PRC) to estimate how much future growth is anticipated to occur within the city. As described in the latest report for communities in Deschutes County, the City of Sisters is expected to experience significant growth over the next 20 years.[1] Recent technical analysis conducted by the City shows that there is insufficient land to meet future housing demand within the existing UGB.[2] This is true even when accounting for zone changes enacted in 2021 intended to increase the efficiency of land to help accommodate growth in the City.

The process for changing the UGB is governed by State statute and administrative rules. Any proposed UGB amendment will be coordinated with the County government and ultimately must be reviewed and acknowledged by the Oregon Department of Land Conservation and Development (DLCD).

The development process for rural land has many steps and opportunities for planning. The City has prepared a graphic explaining the process - Click here.

What work has been done so far?

The City regularly updates adopted and City-council acknowledged long-range planning documents to reflect changing conditions and new regulatory requirements. For the past five years Sisters has been systematically studying the impacts of growth on the City’s economy, housing supply, utilities, and community.  The findings from this work are found in the following documents (which can be accessed via Comprehensive Plan):

• 2019 – Sisters Housing Needs Analysis
• 2021 – Sisters 2040 Comprehensive Plan
• 2021 – Updated Housing Needs Analysis
• 2021 – Economic Opportunities Analysis
• 2021 – Buildable Lands Inventory
• 2021 – Urban Growth Boundary Sufficiency Analysis
• 2023 – Land Use Efficiency Measures Report
• 2023 – Updated Sisters Housing Plan
• 2023 – Updated Urban Growth Boundary Sufficiency Analysis

The current UGB Expansion process is a direct outgrowth of these past planning efforts, and these documents will comprise much of the factual base for an eventual UGB decision.

How is this work being paid for?

The process of amending the UGB will require technical analysis and a robust community conversation. The City of Sisters has received a $100,000 grant from DLCD that will fund part of this effort. The remainder will be paid for from the City’s general fund budgeted for this purpose. The City has hired the consulting firm MIG to assist with this work, which benefits from and builds on previous planning work that first started in 2019. The City also will use its own resources to dedicate City staff time to support this effort.

Communities in Oregon often accommodate growth by expanding into their UGBs through annexation. However, Sisters does not have any additional land outside of its city limits that is part of its UGB. Now that the Sisters City Council has directed staff to pursue an amendment to the Sisters UGB, we are required to study land in the vicinity of the existing UGB to identify new areas of growth. Oregon Administrative Rules (OAR) 660, Division 24 provides direction about establishing a study area and evaluating UGB alternatives which the City is required to follow.

Cities must prioritize land within the study area, as follows:

First Priority: Urban reserves,[3] exception land,[4] and non-resource land.[5]

Second Priority: “Marginal land” (an outdated term, not applicable to Sisters).

Third Priority: Forest land or farm land that is not predominantly high-value.

Fourth Priority: Agricultural land that is predominantly high-value.

Once these areas have been identified, the City will determine if there is enough land in a higher priority category to meet the total expansion need before considering lands in a lower priority category. If there is insufficient land in the “First Priority” category to meet the needs of future growth, the evaluation can move on to “Second Priority,” and so on. In looking at these lands, the City is allowed to discount areas that are considered unbuildable or incompatible with future urban development.

Once the City has identified potential expansion areas, given the categories of lands described above, it must evaluate the relative suitability of each alternative expansion area based on the following criteria:

1. Efficient accommodation of identified land needs;
2. Orderly and economic provision of public facilities and services;
3. Comparative environmental, energy, economic and social consequences; and
4. Compatibility of the proposed urban uses with nearby agricultural and forest activities occurring on farm and forest land outside the UGB.

In conducting this evaluation, the City must show that all the factors were considered and balanced. The process of identifying and evaluating land for inclusion in a UGB expansion is a relatively complex undertaking; it typically does not hinge on a single characteristic or factor but involves consideration of multiple issues.

The City of Sisters has facilitated a community conversation about these factors through the Project Steering Committee, Planning Commission, City Council, and in person and online open houses. See below for more information.

Any future proposal to expand the UGB will be jointly reviewed and decided upon by the City of Sisters and Deschutes County based on an application prepared by the City. This process is defined in an existing agreement between the City and the County. If the City and County support the proposed expansion and it is approved by the County Board of Commissioners, the next step is review by DLCD for their review. Upon receipt of the proposal, DLCD will 1) approve the local decision; 2) deny the decision and return it to the local government for revision; or 3) refer it to the Land Conservation and Development Commission for their review and decision.

The size of the ultimate boundary will depend on many factors, but the City's 2023 UGB Sufficiency Analysis indicates the need for roughly 250 developable acres of land to accommodate new homes, jobs, parks, and infrastructure. Ultimately, the expansion area will be larger than 250 acres because some of the land in the expansion area will be constrained by a variety of factors and not completely developable. 2023 – Updated Urban Growth Boundary Sufficiency Analysis

The State of Oregon lays out rules for the study area and priority of land for potential inclusion in a UGB. In the City of Sisters, the study area includes all land within 1/2 mile of the current UGB, and all land that is not zoned for farm or forest use up to 1 mile from the current UGB. The study area is further divided into several "priorities" based on zoning and other factors.

The City has created several UGB alternatives to be evaluated through this process. More information about these alternatives can be found in the draft Alternatives Analysis report here. 

The City of Sisters held a community open house on Monday, December 9, 2024, to engage the public in a conversation about growth and alternatives for expansion of the Sisters Urban Growth Boundary (UGB). An online open house was prepared to provide an opportunity for people who could not attend the in-person event to provide feedback on the same topics. The in-person open house was held from 6 PM to 8 PM and included informal review of UGB concept boards, a presentation by the project team, and small group discussions. Over 200 people attended the open house. The online open house remained open from December 9, 2024 to January 10, 2025, and received 389 participants who answered at least one question.

Participants gave input on their priorities for expansion areas and evaluated several alternative future UGB locations.

A detailed summary of the events is available on the city's website: Link

There will be many opportunities to get involved in the project. To keep up to date with the latest, please sign up for the project email list. For more information, contact Scott Woodford, swoodford [at] ci.sisters.or.us (swoodford[at]ci[dot]sisters[dot]or[dot]us)

Members and representatives of the following groups and organizations are also expected to be involved and play a significant role in guiding the project:

• The UGB Steering Committee
• Sisters Planning Commission
• Sisters City Council
• City of Sisters residents and businessowners
• Sisters Country residents and businessowners
• Central Oregon Land Watch and 1,000 Friends of Oregon
• Oregon Homebuilders Association

No, these properties are in Deschutes County and thus the application to request approval of a  rezone of these properties from Forest Use 2 (F2) to Multiple-Use Agricultural (MUA) was submitted to the Deschutes County Community Development Department. County planning staff will review the application and provide the results of their review to a County Hearing’s Officer who will provide a written recommendation to the Board of County Commissioners. The process will include public hearings with both the Hearings Officer and the Board of County Commissioners to follow.   The City of Sisters does not have any role in this application request and all comments should be directed to Deschutes County 

https://www.deschutes.org/cd/page/247-24-000839-pa-840-zc-mckenzie-meadow-village-llc-comprehensive-plan-amendment-and-zone

(Staff Contact – Haleigh King, email: Haleigh.King [at] deschutes.org (Haleigh[dot]King[at]deschutes[dot]org)).  

Currently, the City of Sisters is undergoing a process to expand its UGB and has created a Study Area that prioritizes the lands that are the first to be considered for inclusion into the expanded UGB (called Priority 1 lands).  The lands subject to the rezone request owned by McKenzie Meadows Village, LLC are considered Priority 3 lands because they are currently zoned Forest and lands that are zoned Forest or Farm are the lowest priority land for inclusion into a UGB.  However, if this property were to be successfully rezoned to MUA, then it would become part of the Priority 1 lands and, thus could be evaluated alongside the other Priority 1 lands and considered on a more equal footing with those areas for potential inclusion into the Sisters UGB.

Much of the land surrounding the City of Sisters consists of National Forest System Lands owned and managed by the US Forest Service. The City has been in conversation with USFS representatives about the long-term future of these lands.

Land Conveyance from the USFS to a city or private property owner can occur under the “Townsite Act of 1906,” which allows cities to acquire up to 640 acres for townsite purposes. Oregon is among the states eligible for this process, and communities can submit applications and required studies of the land to justify acquisition. Conveyance under these rules was used to create the city's wastewater treatment plant previously.

This process would be a discretionary decision on the part of the USFS, and the City would have to show that no alternative sites are available to meet its identified land needs. The City would also have to demonstrate that this action is in the best interests of the federal government. Such a process could take many years and include periods for public comment, tribal consultation, and environmental studies.

The USFS also previously transferred ownership of portions of its administrative land holdings within the City limits of Sisters to the City and other property owners. The USFS retained only a small amount of land for administrative purposes subsequent to that land exchange and as a result, this process is not expected to be a viable option in the Sisters area again in the future. 

Sisters Eagle Airport lies at the center of UGB Study Area's Priority 1 land. The Oregon Department of Aviation (ODA) provides guidance on land use allowances and design of building near airports, including height restrictions adjacent to the runway and land use compatibility guidelines for areas near the runway (in the "Runway Protection Zone" and "Transitional Zone"). These areas extend approximately 1,500 feet from the airport runway in Sisters. Residences, places of public assembly, sports fields, and golf courses are among the land uses listed as incompatible for these zones. In addition, building heights must be limited in these areas, with limits varying based on the distance from the runway.

These guidelines suggest that the City should consider locating compatible uses in the transitional area (commercial, industrial, and parks); limit building heights in the runway protection and transitional areas; and coordinate with ODA and Sisters Eagle Airport on the topic of future land use planning & development for areas adjacent to airport. Beyond the boundaries of the Runway Protection Zone and Transitional Zone, the City and property owners have significant flexibility in terms of the type and scale of development that can occur.

This UGB expansion is based on the process and requirements of OAR (Oregon Administrative Rules) 660 Division 24, which is separate from the new process outlined in Senate Bill 1537. Subsequent to the current expansion process, the City may consider such a one-time addition under this new legislation if it meets the eligibility requirements associated with the new rule.

Senate Bill 1537 states that:

• Cities must demonstrate the need for additional land for market rate and affordable housing, based on the criteria in SB 1537 Section 52(1)(b) and 52(2)(a).
• Section 52(2)(a) requires that a city must also have “a greater percentage of severely cost-burdened households than the average for this state based on the Comprehensive Housing Affordability Strategy data from the United States Department of Housing and Urban Development.”
• SB 1537 Section 52(2)(a) also requires at least 75% of previous UGB expansion lands have been developed or have a comprehensive plan designation in preparation for annexation and a public facilities plan and associated financing plan. 

 In addition, a one-time expansion in the Sisters area would be limited to a maximum size of 50 acres.

These provisions are likely to make a one-time UGB addition under SB 1537 very difficult for the City of Sisters to justify and implement within the short to medium term (e.g., 1-5 or more years) following its current UGB process.

[1]Deschutes County Coordinated Population Forecast, 2022 Through 2072. June 30, 2022.  https://www.pdx.edu/population-research/sites/g/files/znldhr3261/files/…

[2] 2023 Urban Growth Boundary Sufficiency Analysis. November 21, 2023. https://www.ci.sisters.or.us/sites/default/files/fileattachments/commun…

[3] Cities may designate land outside their UGB as “Urban Reserves” intended for urbanization in the ~50-year timeframe. The City of Sisters does not have any designated urban reserves currently.

[4] Exception Land is called such due to an existing “exception” to statewide planning goals. This land is typically land already zoned for rural residential development that lies outside an existing UGB.

[5] Non-resource land is not designated for farm, forest, or mineral use.