Oregon Revised Statutes

Or. Rev. Stat. § 227.180 (2026)

Review of action on permit application; fees

✓ current as of May 2026
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      227.180 Review of action on permit application; fees. (1)(a) A party aggrieved by the action of a hearings officer may appeal the action to the planning commission or council of the city, or both, however the council prescribes. The appellate authority on its own motion may review the action. The procedure for such an appeal or review shall be prescribed by the council, but shall:

      (A) Not require that the appeal be filed within less than seven days after the date the governing body mails or delivers the decision of the hearings officer to the parties;

      (B) Require a hearing at least for argument; and

      (C) Require that upon appeal or review the appellate authority consider the record of the hearings officer’s action. That record need not set forth evidence verbatim.

      (b) Notwithstanding paragraph (a) of this subsection, the council may provide that the decision of a hearings officer or other decision-making authority in a proceeding for a discretionary permit or zone change is the final determination of the city.

      (c) The governing body may prescribe, by ordinance or regulation, fees to defray the costs incurred in acting upon an appeal from a hearings officer, planning commission or other designated person. The amount of the fee shall be reasonable and shall be no more than the average cost of such appeals or the actual cost of the appeal, excluding the cost of preparation of a written transcript. The governing body may establish a fee for the preparation of a written transcript. The fee shall be reasonable and shall not exceed the actual cost of preparing the transcript up to $500. In lieu of a transcript prepared by the governing body and the fee therefor, the governing body shall allow any party to an appeal proceeding held on the record to prepare a transcript of relevant portions of the proceedings conducted at a lower level at the party’s own expense. If an appellant prevails at a hearing or on appeal, the transcript fee shall be refunded.

      (2) A party aggrieved by the final determination in a proceeding for a discretionary permit or zone change may have the determination reviewed under ORS 197.830 to 197.845.

      (3) No decision or action of a planning commission or city governing body shall be invalid due to ex parte contact or bias resulting from ex parte contact with a member of the decision-making body, if the member of the decision-making body receiving the contact:

      (a) Places on the record the substance of any written or oral ex parte communications concerning the decision or action; and

      (b) Has a public announcement of the content of the communication and of the parties’ right to rebut the substance of the communication made at the first hearing following the communication where action will be considered or taken on the subject to which the communication related.

      (4) A communication between city staff and the planning commission or governing body shall not be considered an ex parte contact for the purposes of subsection (3) of this section.

      (5) Subsection (3) of this section does not apply to ex parte contact with a hearings officer. [1973 c.739 §§11,12; 1975 c.767 §9; 1979 c.772 §12; 1981 c.748 §43; 1983 c.656 §2; 1983 c.827 §25; 1991 c.817 §12]

Notes of Decisions
Cited in 18 cases (1 in the last 5 years), 1975–2026 · leading case: Willamette Oaks, LLC v. City of Eugene, 261 P.3d 85 (Or. Ct. App. 2011).
Willamette Oaks, LLC v. City of Eugene, 261 P.3d 85 (Or. Ct. App. 2011). · cites it 32× “Specifically, LUBA remanded the Willamette Oaks fee challenge to the city to take evidence on whether the fee violates the limit imposed by ORS 227.180(1)(c) on local land use appeal fees.”
Horizon Constr., Inc. v. City of Newberg, 834 P.2d 523 (Or. Ct. App. 1992). · cites it 6× “ORS 227.180(3) provides: “No decision or action of a planning commission or city governing body shall be invalid due to ex parte contact or bias resulting from ex parte contact with a member of the decision-making body, if the member of the decision-making body receiving the…”
Bienz v. City of Dayton, 566 P.2d 904 (Or. Ct. App. 1977). “ORS 227.180(1) provides: "A party aggrieved by the action of a hearings officer may appeal the action to the planning commission or council for the city, or both, however the council prescribes.”
State ex rel. Compass Corp. v. City of Lake Oswego, 878 P.2d 403 (Or. 1994). “178, which provides, in part: “(1) Except as provided in subsections (3) and (4) of this section, the governingbody of a city or its designate shall take final action on an application for a permit, limited land use decision or zone change, including resolution of all appeals…”
Trautman v. City of Eugene, 383 P.3d 420 (Or. Ct. App. 2016). · cites it 3× “]” Accordingly, the City of Eugene prescribes the procedure for an appeal to the planning commission in EC 9.”
Duddles v. City Council of West Linn, 535 P.2d 583 (Or. Ct. App. 1975). “⑦ ORS 227.180(4), enacted by Oregon Laws 1973, ch 739, §§ 11, 12, p 1773, is also conceivably relevant, although not raised in this appeal.”
Carlsen v. City of Portland, 8 P.3d 234 (Or. Ct. App. 2000). · cites it 3× “215M” A city’s final decision on a permit application is reviewable by LUBA as a land use decision, ORS 227.180(2), in the same manner that a decision applying a land use regulation is.”
Johns v. City of Lincoln City, 933 P.2d 978 (Or. Ct. App. 1997). “830(ll)(c) (specification of *600 issues to be reviewed required in petitions for review to LUBA); ORS 227.180(l)(a) (procedures for appeals to higher city bodies of permit decisions by city hearings officers may be prescribed by city governing bodies).”
Hillyer's Mid-City Ford, Inc. v. City of Woodburn, 965 P.2d 474 (Or. Ct. App. 1998). “160 to ORS 227.180. Correspondingly, there was no final land use decision approving or denying the applications that was — or could have been — before LUBA.”
Opp v. City of Portland, 955 P.2d 768 (Or. Ct. App. 1998). “See ORS 227.180(3). No disclosure was made of the contact with Cooley, and no opportunity for rebuttal was provided by the city in its proceedings on the application.”
Link v. City of Coos Bay, 543 P.2d 1082 (Or. Ct. App. 1975). “That body, without reviewing the proceedings before the commission, adopted a motion “that the Planning Commission had the power to take the action that they did in this case.”
Miller v. Council of City of Grants Pass, 592 P.2d 1088 (Or. Ct. App. 1979). · cites it 3× “Citing ORS 227.180(1) and Section 16 of the City of Grants Pass Land Use Hearing Rules, petitioners first contend that the council’s review was procedurally incorrect because it failed to consider the record of the proceedings before the hearings officer.”
— Or. Rev. Stat. § 227.180(1) — 3 cases
Bienz v. City of Dayton, 566 P.2d 904 (Or. Ct. App. 1977). “ORS 227.180(1) provides: "A party aggrieved by the action of a hearings officer may appeal the action to the planning commission or council for the city, or both, however the council prescribes.”
Miller v. Council of City of Grants Pass, 592 P.2d 1088 (Or. Ct. App. 1979). “Citing ORS 227.180(1) and Section 16 of the City of Grants Pass Land Use Hearing Rules, petitioners first contend that the council’s review was procedurally incorrect because it failed to consider the record of the proceedings before the hearings officer.”
Cann v. City of Portland, 720 P.2d 1348 (Or. Ct. App. 1986).
— Or. Rev. Stat. § 227.180(1)(c) — 1 case
Willamette Oaks, LLC v. City of Eugene, 261 P.3d 85 (Or. Ct. App. 2011). “Specifically, LUBA remanded the Willamette Oaks fee challenge to the city to take evidence on whether the fee violates the limit imposed by ORS 227.180(1)(c) on local land use appeal fees.”
— Or. Rev. Stat. § 227.180(2) — 2 cases
Carlsen v. City of Portland, 8 P.3d 234 (Or. Ct. App. 2000). “215M” A city’s final decision on a permit application is reviewable by LUBA as a land use decision, ORS 227.180(2), in the same manner that a decision applying a land use regulation is.”
— Or. Rev. Stat. § 227.180(3) — 5 cases
Horizon Constr., Inc. v. City of Newberg, 834 P.2d 523 (Or. Ct. App. 1992). “ORS 227.180(3) provides: “No decision or action of a planning commission or city governing body shall be invalid due to ex parte contact or bias resulting from ex parte contact with a member of the decision-making body, if the member of the decision-making body receiving the…”
Carlsen v. City of Portland, 8 P.3d 234 (Or. Ct. App. 2000). “215M” A city’s final decision on a permit application is reviewable by LUBA as a land use decision, ORS 227.180(2), in the same manner that a decision applying a land use regulation is.”
Opp v. City of Portland, 955 P.2d 768 (Or. Ct. App. 1998). “See ORS 227.180(3). No disclosure was made of the contact with Cooley, and no opportunity for rebuttal was provided by the city in its proceedings on the application.”
Opp v. City of Portland, 16 P.3d 520 (Or. Ct. App. 2000).
Dickas v. City of Beaverton, 757 P.2d 451 (Or. Ct. App. 1988).
— Or. Rev. Stat. § 227.180(3)(b) — 1 case
Horizon Constr., Inc. v. City of Newberg, 834 P.2d 523 (Or. Ct. App. 1992). “ORS 227.180(3) provides: “No decision or action of a planning commission or city governing body shall be invalid due to ex parte contact or bias resulting from ex parte contact with a member of the decision-making body, if the member of the decision-making body receiving the…”
— Or. Rev. Stat. § 227.180(4) — 3 cases
Duddles v. City Council of West Linn, 535 P.2d 583 (Or. Ct. App. 1975). “⑦ ORS 227.180(4), enacted by Oregon Laws 1973, ch 739, §§ 11, 12, p 1773, is also conceivably relevant, although not raised in this appeal.”
Link v. City of Coos Bay, 543 P.2d 1082 (Or. Ct. App. 1975). “That body, without reviewing the proceedings before the commission, adopted a motion “that the Planning Commission had the power to take the action that they did in this case.”
Dickas v. City of Beaverton, 757 P.2d 451 (Or. Ct. App. 1988).
— Or. Rev. Stat. § 227.180(l)(a) — 2 cases
Trautman v. City of Eugene, 383 P.3d 420 (Or. Ct. App. 2016). “]” Accordingly, the City of Eugene prescribes the procedure for an appeal to the planning commission in EC 9.”
Johns v. City of Lincoln City, 933 P.2d 978 (Or. Ct. App. 1997). “830(ll)(c) (specification of *600 issues to be reviewed required in petitions for review to LUBA); ORS 227.180(l)(a) (procedures for appeals to higher city bodies of permit decisions by city hearings officers may be prescribed by city governing bodies).”
— Or. Rev. Stat. § 227.180(l)(c) — 1 case
Willamette Oaks, LLC v. City of Eugene, 261 P.3d 85 (Or. Ct. App. 2011). “Specifically, LUBA remanded the Willamette Oaks fee challenge to the city to take evidence on whether the fee violates the limit imposed by ORS 227.180(1)(c) on local land use appeal fees.”
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