Overview

Sarah Stauffer Curtiss is a trusted advisor to clients navigating complex project permitting. She helps clients develop creative environmental and land use compliance solutions that enhance business opportunities. With a focus on energy and infrastructure project development and operation, her federal environmental expertise covers a myriad of environmental laws, with an emphasis on protected species issues under the Endangered Species Act (ESA), the Bald and Golden Eagle Protection Act (BGEPA), and the Migratory Bird Treaty Act (MBTA), as well as federal environmental review issues under the National Environmental Policy Act (NEPA).

Sarah has deep experience in permitting complex projects on farm- and forest-zoned lands. She represents energy and utility clients on siting and compliance matters related to project development, expansion, and amendment through the Oregon Energy Facility Siting Council (EFSC). She also represents clients before local city and county planning departments, governing bodies, and the Oregon Land Use Board of Appeals.

Licensed to practice in Oregon and Washington, Sarah prides herself in helping clients develop innovative solutions to problems and on working collaboratively with clients, consultants, and agency staff.

Education

Lewis & Clark College Law School, J.D., 2007, cum laude; Associate Editor, Environmental Law, 2006-2007; Certificate in Environmental and Natural Resources Law

University of Chicago, M.A. Humanities, 2001

Pacific Lutheran University, B.A. History, 2000, magna cum laude

Admissions

Oregon

Washington

United States District Court for the District of Oregon

United States U.S. Court of Appeals for the Ninth Circuit

Experience

State Energy Facility Siting

Regularly represents energy and utility clients on permitting and compliance matters related to project development and expansion through the Oregon Energy Facility Siting Council (EFSC).

  • Represented multiple renewable energy operators and developers on applications for site certificates or amendments to site certificates including 1700 MW of solar and 400 MW of wind.
  • Represented client on application for site certificate for new transmission line.
  • Secured site certificate for three solar energy facilities, including the first solar facility permitted through the Oregon EFSC.
  • Obtained site certificate amendments for modifications to four existing wind projects to facilitate repowering.
  • Secured site certificate amendments to add solar and battery storage to permitted wind facilities.
  • Secured site certificate amendments to modify and expand existing wind and solar facilities.
  • Represented multiple wind energy developers and operators on site certificate transfers and facility bifurcations.

Local Land Use

Represents property owners in connection with development applications, including post-acknowledgment comprehensive plan amendments, zone changes, subdivisions, partitions, property line adjustments, conditional use permits, adjustments, variances, site plan reviews, historic resource reviews, design reviews, and environmental reviews.

  • Obtained conditional use permit and Statewide Planning Goal 4 exception from Klamath County for a solar and battery energy storage project located on forest-zoned land.
  • Secured conditional use approval from Deschutes County for community center on farm-zoned land.
  • Obtained comprehensive plan amendment and conditional use permits from Morrow and Umatilla Counties for aggregate facilities on farm-zoned land.
  • Successfully appealed Clackamas County’s initial denial of an application for a winery under ORS 215.452, the statutory provision that permits some wineries on exclusive farm-zoned land.
  • Secured site design and development review approvals for multiple wineries and ancillary tasting rooms in the Willamette Valley.

Federal Environmental Permitting and Compliance

Represents clients across the country on Endangered Species Act (ESA), Migratory Bird Treaty Act (MBTA) and Bald and Golden Eagle Protection Act (BGEPA) compliance issues, including advising on the risk of enforcement and/or prosecution; assisting with the development of conservation plans and strategies; helping clients navigate the incidental take permitting process; and advising on related National Environmental Policy Act (NEPA) issues. Sarah’s experience includes assisting clients with eagle incidental take permits and compliance strategies in more than half of the US Fish and Wildlife Service Regions.

  • Advises clients on BGEPA permitting and compliance strategies for projects around the country, including the development of eagle conservation plans to support the issuance of eagle incidental take permits. Currently assisting energy and utility clients with eagle incidental take permit applications and BGEPA compliance strategies in USFWS Regions 1, 2, 3, 6, and 8.
  • Advises clients on ESA compliance strategies, including the development of voluntary habitat conservation plans (HCP) and conservation benefit agreements (safe harbor agreements and candidate conservation agreements). Currently assisting clients with Endangered Species Act incidental take permit applications in USFWS Regions 1, 3, and 8.
  • Represents landowners and project operators on protected species investigation and enforcement matters involving the U.S. Fish and Wildlife Service’s (USFWS) Office of Law Enforcement.
  • Counsels on MBTA liability and related compliance issues (e.g., nest removal).
  • Secured Bureau of Land Management right-of-way grants for transmission line and access road to accommodate solar facility on private land.
  • Secured a special use permit (SF 299) from the U.S. Forest Service for a hydropower facility on National Forest System Lands.

Insights

Insights & Presentations

  • “U.S. Department of Interior Directs U.S. Fish and Wildlife Service to Audit Eagle Permitting Program, Signals Potential for Increased Enforcement for Wind Energy Projects” (co-author), Stoel Rives Renewable + Law Blog, August 11, 2025
  • “New Department of Interior Review May Heighten Scrutiny and Lengthen Permitting Timelines for Some Wind and Solar Projects” (co-author), Stoel Rives Renewable + Law Blog, July 21, 2025
  • “Oregon EFSC Proposes Rule Changes to Energy Facility Site Certificate Amendment Process” (co-author), Stoel Rives Renewable + Law Blog, July 17, 2025
  • Presenter, “Hot Topics in Environmental and Natural Resources Enforcement and Regulation,” Deeply Rooted Timberlands Summit, May 2025
  • Presenter and Panelist, “Navigating Environmental Permitting and Compliance in the Trump Era,” American Clean Power Siting & Permitting Conference, April 2025
  • Co-Chair, Protected Wildlife and Project Development Special Institute, Foundation for Natural Resources and Energy Law, October 2024
  • Presenter, “Endangered Species Act at 50 Years,” Pacific Northwest Timberlands Management, The Seminar Group, March 2024
  • “Oregon Court of Appeals Says City Not Precluded from Rejecting Redevelopment Application” (co-author), Oregon Real Estate and Land Use Digest, July 2022
  • Presenter, “Renewable Energy Development,” Pacific Northwest Timberlands Management, The Seminar Group, March 2022
  • Presenter, “Habitat Conservation Plans in Oregon, 23rd Annual Oregon Land Use Law Seminar, December 2019
  • Presenter, “Bald and Golden Eagle Act Prohibitions and Permits, Rocky Mountain Mineral Law Foundation: Endangered Species and Other Wildlife, November 2019.
  • Presenter and Panelist, “The Anatomy of a Wind Farm: Decommissioning,” American Wind Energy Association Wind Project Siting and Environmental Compliance Conference, April 2019
  • Presenter, “Solar Energy and Agricultural Lands,” 22nd Annual Oregon Land Use Law Seminar, December 2018
  • Presenter, “Enforcement Actions under MBTA and BGEPA: Civil Settlement Agreements to Resolve Past Eagle Take,” MBTA & BGEPA Conference, December 2017
  • Presenter and Panelist, “Using Innovative Solutions to Tailor Protected Species Compliance Strategies,” American Wind Energy Association Wind Project Siting & Environmental Compliance Conference, March 2017
  • Presenter, “Floodplain Regulation in Flux: Biological Opinion on the National Flood Insurance Program in Oregon,” Oregon APA Chapter Legal Issues Workshop, December 2016
  • “Mining on 10 Million Acres in Six States Impacted by BLM’s Proposed Withdrawal to Protect Sage-Grouse Habitat” (co-author), ABA Mining and Mineral Extraction Committee Newsletter, September 2016
  • Panelist, “Special Rules Under Section 4(d)—Conservation or Compromise?” Rocky Mountain Mineral Law Foundation Special Institute on the Endangered Species Act, November 2015
  • “A Necessary Tool for Conservation: The Case for Section 4(d) of the Endangered Species Act” Endangered Species Act: Current and Emerging Issues Affecting Resource Development, Paper 7C (Rock Mt. Min. L. Fdn. 2015)

Speaking Engagements

Special Reports

Podcasts

Recognition

  • Named to Daily Journal of Commerce’s Women of Vision, 2024
  • Selected as one of “America’s Leading Lawyers for Business” (Oregon) by Chambers USA (Real Estate: Zoning/Land Use), 2022–present
  • Included in The Best Lawyers in America® (Land Use and Zoning Law), 2022–present
  • Listed among Rising Stars (Land Use/Zoning), Oregon Super Lawyers®, 2013–2017
  • Selected by the Portland Business Journal as a Forty Under 40 honoree, 2016

Affiliations

Professional

  • Executive Committee, Real Estate and Land Use Section, Oregon State Bar (2013-2022)
  • Luncheon Committee, Real Estate and Land Use Section, Oregon State Bar, Member (2013-present)
  • Chair, Real Estate and Land Use Section, Oregon State Bar (2020)

  • As noted by land use and zoning clients, “Sarah is one of the best attorneys I have had the pleasure to work with. She consistently delivers the highest quality service and products within tight project timelines.”

  • “Sarah is an outstanding legal resource for our permitting teams.”

    Chambers USA
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