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Zoning Bulletin June 25, 2010 j Volume 4 j No. 12 <br />part of a single `farm unit,' the parcel is within the unit unless the appli- <br />cant can [show] circumstances ... that dictate a contrary result" —such as <br />if there was "a significant obstacle to resumed joint [farming] operation." <br />The court found that Garden Valley's 259-acre Parcel was "within" <br />the 590-acre "farm unit" —despite the 2005 cessation of joint use. Like <br />LUBA had, the court found there was "no possible dispute that the for- <br />mer ranch was a `farm unit' for purposes of [Goal 31." This was be- <br />cause: (1) there had been a "long and recent history of use for a hay/ <br />grazing operation" that included the Parcel; and (2) there had been no <br />significant changes to the total parcel's soil, water or forage that would . <br />preclude a resumed hay/grazing operation. The court also found that <br />Garden Valley could not show "a significant obstacle to resumed joint <br />[farming] operation" with the 590-acre parcel. <br />Since the Parcel was found to be within the "farm unit," it was "ag- <br />ricultural land" subject to the state land preservation goals of Goal 3. <br />See also: Department of Land Conservation and Development v. Curry <br />County, 132 Or. App. 393, 888 P.2d 592 (1995). <br />See also: Riggs v. Douglas County, 167 Or. App. 1, 1 P.3d 1042 (2000). <br />- Zoning News from Around the Nation <br />DELAWARE <br />Sussex County Council recently enacted a "six-month moratorium <br />on casino, gambling and gaming facility applications in unincorporated <br />areas of the county." The moratorium was reportedly enacted so as "to <br />allow staff more time to prepare a zoning ordinance specifically dealing <br />with zoning, regulations and restrictions relating to gambling venues." <br />Source: Cape Gazette; www.cabeeazette.com <br />MARYLAND <br />Howard County is expected to soon consider legislation that is "de- <br />signed to bring the county's referendum laws in line with the state's." <br />Among other things, the expected legislation would propose to remove <br />"a unique Howard County requirement that petitions include a disclo- <br />sure statement when circulated by people who are being paid." <br />Source: Columbia Flier; www.exvlorehoward.com <br />MASSACHUSETTS <br />Commonwealth officials recently designated 35 cities and towns as the <br />Commonwealth's "first official Green Communities." This designation <br />makes them eligible for "$8.1 million in grants for local renewable power <br />and energy -efficiency projects." In order to achieve this designation, the <br />© 2010 Thomson Reuters 11 <br />183 <br />