A recent Oregon Land Use Board of Appeals (LUBA) decision could significantly affect the siting of standalone battery energy storage systems (BESS) on exclusive farm use (EFU) land. In Remington BESS, LLC v. Marion County, LUBA reversed Marion County’s denial of a proposed 199 MW BESS project and provided important guidance on how Oregon counties must evaluate these facilities under state land use laws.

Summary

The central issue was whether a standalone BESS qualifies as a “utility facility necessary for public service” under ORS 215.283(1)(c). LUBA rejected Marion County’s position that a utility facility must directly deliver electricity to customers, concluding that a standalone BESS can qualify because of its role within the utility system.

The decision also provides guidance on the reasonable alternatives analysis under ORS 215.275(2), emphasizing that the focus is on whether a viable non-EFU alternative exists. In addition, LUBA held that the farm impacts test under ORS 215.296 does not apply to utility facilities that are permitted outright under ORS 215.283(1).

Key Takeaways

  • A standalone BESS can qualify as a “utility facility necessary for public service” under ORS 215.283(1)(c).
  • Counties must evaluate reasonable alternatives by determining whether a viable non-EFU site exists, rather than simply questioning the suitability of the proposed EFU site.
  • The farm impacts test under ORS 215.296 does not apply to utility facilities permitted outright in the EFU zone.

Read the full article for additional analysis of LUBA’s decision and its potential impact on BESS siting and utility facility approvals on EFU land across Oregon.  You can read the full case here: Remington BESS, LLC v. Marion County, LUBA No. 2026-030.

Photo of Sarah Stauffer Curtiss Sarah Stauffer Curtiss

Sarah Stauffer Curtiss helps clients understand and comply with environmental and land use laws, navigate complex permitting processes, and develop compliance solutions that enhance business opportunities. On Oregon land use matters, Sarah helps clients secure permits from local governments. She has worked with…

Sarah Stauffer Curtiss helps clients understand and comply with environmental and land use laws, navigate complex permitting processes, and develop compliance solutions that enhance business opportunities. On Oregon land use matters, Sarah helps clients secure permits from local governments. She has worked with city and county planning departments throughout Oregon, and regularly represents clients before local governing bodies and the Oregon Land Use Board of Appeals. She also represents energy and utility clients on permitting and compliance matters related to project development and expansion through the Oregon Energy Facility Siting Council (EFSC). Her federal environmental expertise covers a myriad of environmental laws.

Click here for Sarah Stauffer Curtiss’ full bio.

Photo of Emily Schimelpfenig Emily Schimelpfenig

Emily Schimelpfenig is an associate in Stoel Rives’ Environment, Land Use & Natural Resources group, where she focuses on permitting before state and local governments. Emily advises and advocates for clients across multiple industries, including energy generation and residential, commercial, and industrial development.…

Emily Schimelpfenig is an associate in Stoel Rives’ Environment, Land Use & Natural Resources group, where she focuses on permitting before state and local governments. Emily advises and advocates for clients across multiple industries, including energy generation and residential, commercial, and industrial development.

Emily also has experience assisting with OSHA and MSHA compliance and counseling clients on issues that affect their mining operations.

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Photo of Ariel Stavitsky Ariel Stavitsky

Ariel Stavitsky is an associate in Stoel Rives’ Environment, Land Use and Natural Resources group, with focuses in environmental and natural resource-related litigation, project permitting, and regulatory compliance counseling. She advises and advocates for clients across multiple industries, including energy generation, natural resource…

Ariel Stavitsky is an associate in Stoel Rives’ Environment, Land Use and Natural Resources group, with focuses in environmental and natural resource-related litigation, project permitting, and regulatory compliance counseling. She advises and advocates for clients across multiple industries, including energy generation, natural resource production, and manufacturing.

Click here for Ariel Stavitsky’s full bio.