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HomeMy WebLinkAboutCA07 MSJ Response RECEIVED JUL 0 7 2025 JEFFERSON COUNTY COMMISSIONERS EXHIBIT#U -a-7 BEFORE THE LAND USE HEARING EXAMINER IN AND FOR JEFFERSON COUNTY In re Appeal of Rathvon Shoreline APPLICANT'S RESPONSE TO Conditional Use Permit, DCD File No. APPELLANT'S MOTION FOR SDP2023-00020 SUMMARY JUDGMENT APPLICANTS' RESPONSE TO MOTION FOR SUMMARY SCHWABE,ILoL eMySONs ATT,P.C. Att at Law JUDGMENT- i 1420Sea5th tt e,WA,8101 Suite 3400 Teleohone 206-622-1711 143646\288596\48463766.v4 APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT - 1 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48463766.v4 I. EVIDENCE RELIED UPON Applicants’ Response to Appellants’ Motion for Summary Judgment (“Response”) is supported by the Declaration of Dan McShane, L.E.G. (“McShane Decl.”), the Declaration of Richard Rathvon, (“Rathvon Decl.”) and the Declaration of Larry Dean Richert (“Richert Decl.”) and the exhibits attached to these Declarations. II. COUNTERSTATEMENT OF FACTS Applicant adopts the above-cited Declarations by reference as if fully stated herein. To summarize: Mr. McShane is a licensed engineering geologist and geologist who has performed over 500 geologic hazard assessments in Jefferson County. His opinion is that Appellants have grossly mischaracterized the slope of Twana Way and its proximity to both the shoreline bluff and shoreline. McShane Decl. ¶¶3-4, 6-9. On page 3 of Appellants’ Motion, Appellants claim that Twana Way rises more than 600 feet over one-eight of a mile. One eighth of a mile is approximately 660 feet. First, the elevation of Twana Way at its intersection with Toandos Road, is only 575 feet, which is the highest elevation on Twana Way. Second, if Twana Way rose 600 feet in 660 feet, it would have a slope of approximately 91%. McShane Decl., ¶¶6-7. Using Jefferson County GIS data, Mr. McShane determined that the elevation change from where Twana Way begins its descent near the southeast corner of the Oliver property to the Rathvon property line is 310 feet over a distance of 2,741 feet yielding an average gradient of about 11% -13%. McShane Decl., ¶8. Appellants also claim that Twana Way is located immediately adjacent to a steep embankment down to Dabob Bay. Appellants’ Motion, p. 3; McShane Decl., ¶9. The steepest slopes immediately adjacent to Twana Way are 66% where Twana Way crosses the Von Bargen property. Mr. McShane assessed the stability of this slope and concluded that the slope is stable and not at risk from landslides. Id. “At its closest, Twana Way is 192 feet from the top edge of the shoreline bluff. The closest Twana Way comes to the shoreline is 338 feet. Nowhere is Twana Way located within the Shoreline Management Act’s 200-foot jurisdictional boundary.” McShane Decl., ¶9 APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT - 2 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48463766.v4 (emphasis added). Mr. McShane reviewed photographs of construction vehicles using Twana Way to construct residences on the Walker and Von Bargen properties including cement trucks, a roofing truck, a crane, and other equipment. Id., McShane Decl. ¶11. He has conducted slope stability analysis on the Von Bargen property, and his firm, the Stratum Group, prepared the February 25, 2025 Geologic Hazard Assessment for Twana Way that was provided to the County as part of the Rathvon administrative shoreline conditional use permit (“SCUP”) review. Id., ¶12-13. Based on his analysis, Mr. McShane’s professional opinion is that Twana Way is constructed on good bearing soils and can be used for construction vehicle access to the Rathvon property without impacts to the road’s stability or the shoreline environment. Id., 17-25. In his declaration, Mr. Rathvon explains that there are six homes located past the Oliver home on Twana Way and that the road is not impassible. Rathvon Decl., ¶2. He also obtained photographs from Ms. Walker and Mr. Von Bargen showing construction vehicles, including cement trucks, a roofing truck, crane, and excavator that used Twana Way to construct their respective homes. Id., ¶¶4-8. Mr. Rathvon explained that, in his earlier meeting with his neighbors, he did not propose extensive road improvements to Twana Way, but instead intended to present some possible ideas to his neighbors and start a discussion to formalize a neighborhood road improvement and maintenance plan. Ultimately, there was no agreement on forming this neighborhood effort, and the matter was dropped. Id., ¶¶10-14. Mr. Rathvon and his general contractor, Mr. Richert have not selected the final techniques for constructing the Rathvon residence, and at this time, they have no plans to alter Twana Way. Rathvon Decl., ¶17; Richert Decl., ¶4-5. Mr. Richert has thirty-one years of experience building homes in Jefferson County. Richert Decl., ¶2. In his declaration, Mr. Richert explained that there a variety of construction techniques and sizes of construction vehicles that can be used to construct the Rathvon residence. Id., ¶4. At this time, he and Mr. Rathvon have not determined that there is a need to APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT - 3 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48463766.v4 alter Twana Way. Richert Decl., ¶¶3-5; Rathvon Decl., ¶17. In the future, if maintenance or improvement to Twana Way were determined to be desirable or necessary, Mr. Richert and Mr. Rathvon would follow appropriate County regulatory process for that proposed scope of work. Richert Decl., ¶5, Rathvon Decl., ¶17. III. LEGAL ARGUMENT A. Standard of Review-Material Issues of Fact Preclude Summary Judgment in this Case. To obtain summary judgment, Appellants bear the burden of proving that no genuine issues of material fact exist and that Appellants are entitled to judgment as a matter of law. CR 56(c); Zoenebloem, LLC v. Blue Bay Holdings, LLC, 200 Wn. App. 178, 182, 401 P.3d 468 (2017). A fact is material if it effects the outcome of the case. Keck v. Collins, 184 Wn.2d 358, 370, n.8 (2015). In ruling on Appellants’ Motion, all facts and reasonable inferences are viewed in the light most favorable to the Rathvons, as the nonmoving party. Sherman v. State, 128 Wn.2d 164, 183, 905 P.2d 355 (1995). Summary judgment must be denied when there is a material factual dispute. Smith v. Safeco Ins. Co., 150 Wn.2d 478, 485–86, 78 P.3d 1274, 1277 (2003). Here, the McShane, Rathvon, and Richert Declarations demonstrate that Appellants’ Motion for summary judgement is not factually accurate; that Twana Way is not located in the shoreline jurisdiction; that during the permitting process, the County was provided with a geotechnical analysis demonstrating the stability of Twana Way; that Twana Way has been used for construction access in the past; that such access was, and can be, accomplished without impacts to the shoreline environment; and that the Rathvons’ contractor has no current plans to alter Twana Way. For purposes of Appellants’ Motion, all of these facts must be viewed in the light most favorable to the Rathvons, and the declarations raise material issues of fact that preclude summary judgment. B. Twana Way is Not Within the Shoreline Jurisdiction, and It is Not Part of the Rathvon’s Proposed Development. 1. The Rathvons’ Shoreline Conditional Use Permit Complies with the SMA and JCC Ch. 18.25. APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT - 4 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48463766.v4 The Rathvons’ propose construction is a single family residence on a 5.5 acre parcel (pacel 701164005) located at 660 Twana Way in Quilcene, Washington. April 14, 2025 Amended Staff Report (“Staff Report”), p. 1.1 The County properly granted Rathvons’ shoreline conditional use permit (“SCUP”) under the Shoreline Management Act (“SMA”), RCW Ch. 90.58, and the County’s Shoreline Master Program (“SMP”). JCC Ch. 18.25. The Rathvons’ single-family residence is an expressly allowed use in the SMP’s Natural shoreline environment, with an administrative conditional use permit. JCC 18.25.500(3)(a). The Rathvons’ development would be located within 200 feet of the ordinary high water mark (“OHWM”), but outside of the 150-shoreline buffer and 10-foot building setback. Staff Report, p. 3. Staff found that the project will “avoid[] impacts to the shoreline environment to the extent possible” and “no adverse impacts to the shoreline are expected,” provided that the Rathvons follows required best management practices for erosion control. Id. at 6-7. The SCUP was conditioned to ensure no sediment or pollutants reach Dabob Bay – for example, a silt fence must be installed landward of the 150-foot buffer before any other work is begun. Id. at 8. Additionally, construction activity and equipment staging must occur outside of the 150-foot buffer. Id. Appellants’ incorrectly claim that it is undisputed that the Rathvons never submitted a report to DCD evaluating the stability of Twana Way or the potential for heavy construction traffic on the road to adversely impact the Dabob Bay shoreline environment. Appellants’ Motion, p. 6. Appellants’ claim is contradicted by the County’s Staff Report which acknowledges receipt of a report on the stability of Twana Way: Applicant submitted a Geology Hazard Assessment for Twana Way Improvements. Road improvements are not proposed within shoreline jurisdiction or at the parking area on Rathvon parcel so this report is beyond the scope of this proposal to construct a single-family residence. Staff Report, p. 4. In short, the County’s uncontroverted findings establish that the project as approved 1A copy of the County’s Staff Report is appended as Exhibit E to the Telegin Decl. filed in support of Appellants’ Motion. APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT - 5 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48463766.v4 “will not cause adverse effects to the shoreline environment” and is consistent with all SMA policies and SMP regulations. Id. at 8. Appellants’ attempt to invalidate this lawfully issued permit rests entirely on a misguided legal theory about the scope of SMA jurisdiction. In general, RCW 90.58.030(2)(d) defines “Shorelands” or “shoreland areas” as those lands extending landward for two hundred feet in all directions as measured on a horizontal plane from the OHWM.2 The extent of Jefferson County’s shoreline jurisdiction is established by the Jefferson County Shoreline Master Program (“SMP” ). SMP Appendix A is the County’s Official Shoreline Map. It shows the general location and approximate extent of the regulated shorelines. SMP, Art. 4 (Shoreline Jurisdiction and Environmental Designations), pp. 4-1 and 4.2. The Official Map is for planning purposes and does not depict the precise lateral extent of the shoreline jurisdiction or associated wetlands. Id. The lateral extent of the shoreline jurisdiction at the parcel level is determined on a case- by-case basis at the time a shoreline development is proposed. SMP Art. 4(1)(B). The County uses its GIS database to determine the lateral extent of shoreline jurisdiction on a parcel-by- parcel basis. SMP Art. 4(1)(C). The County’s Official Shoreline Map shows that Twana Way is not within the shoreline jurisdiction. See annotated Official Shoreline Map appended to this Response as Appendix I. In relevant part, the SMP defines “Building Envelope” as “the building area of a lot tract or parcel after all applicable setbacks, buffers, easements and other restrictions on the lot, tract or parcel are taken into account.” SMP Art. 2, p. 2-7. The SMP defines “Buffer or buffer zone, strip, or area” as the area adjacent to a shoreline or critical area that separates and protects the area from adverse impacts associated with adjacent land uses. A buffer is measured horizontally and perpendicularly from the ordinary high water mark, and includes the three- dimensional airspace above.” Emphasis added. 2 The definition also includes “floodways and contiguous floodplain areas landward two hundred feet from such floodways; and all wetlands and river deltas associated with the streams, lakes, and tidal waters which are subject to the provisions of this chapter; the same to be designated as to location by the department of ecology.” APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT - 6 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48463766.v4 Here, the Staff Report explains the development on Rathvons’ property that is regulated under the SMP: This permit is a shoreline conditional use application for residential development on property located at 660 Twana Way that incorporates a stormwater permit to construct a parking area on the property, just outside of shoreline jurisdiction. Road improvements are beyond the scope of this proposal and this permit for residential development does not authorize any modifications to Twana Way. Staff Report, pp. 2-3. The Rathvons’ administrative SCUP also specifically conditions the scope of the permitted development and excludes work on Twana Way: 6. This shoreline permit is for construction of a new single-family residence and development on the subject property is limited to that shown on the approved site plan. SCUP, p. 1 (emphasis added). 7. This permit does not authorize any modifications to the existing access road. It is the responsibility of the permittee to obtain any required permits. SCUP, p. 1 (emphasis added). Thus, the SCUP is consistent with the SMA and SMP; it defines the extent of the permitted shoreline jurisdiction development; and it specifically excludes Twana Way, which is located outside of the SMP shoreline jurisdiction. SMP Appendix A; McShane Decl., ¶9. 2. The SMA’s 200-Foot Jurisdictional Limit Excludes Twana Way from Shoreline Permit Review. Appellants’ Motion is predicated on the erroneous assertion that the SMA obligates the County to evaluate the use of Twana Way for construction vehicle access, even though the road is located outside of the SMP shoreline jurisdiction. This theory contravenes the SMA’s plain jurisdictional limits. The SMA regulates development only within defined shoreline areas – generally, lands within 200 feet of the OHWM. Uplands lying beyond 200 feet from the OHWM are outside “shoreline jurisdiction” as a matter of law. RCW 90.58.030(2)(e). Citing RCW 90.58.080, Appellants concede that the SMA requires cities and counties to adopt SMPs “to regulate development within the 200-foot shoreline area….” Appellants Motion, p. 8. Appellants seek to expand the shoreline jurisdiction to areas (i) that are not covered by the SMP and (ii) that are specifically excluded from the County’s administrative SCUP. Appellants’ attempt to artificially expand the reach of the SMP beyond the designated APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT - 7 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48463766.v4 development on Rathvons’ property by arguing that “construction” is an all-inclusive term that includes ancillary activities that are far removed from the actual shoreline. Appellants’ Motion, p. 8. Appellants’ assertions are contradicted by the McShane Decl. McShane Decl. ¶¶9, 16, 18-20, 21-24. Mr. McShane has written over 500 geologic assessments in Jefferson County. Thus, he is very familiar with geology in Jefferson County, slope stability, and construction in and near the shoreline environment. McShane Decl., ¶4. Mr. McShane explains that Twana Way is not in the shoreline environment, and, in his professional opinion, he concludes that construction vehicle use of Twana Way will not result in the speculative shoreline impacts that Appellants allege. McShane Decl., ¶¶11, 17-25. Here, it is undisputed that Twana Way lies over 338 from the Dabob Bay shoreline. McShane Decl., ¶9; Staff Report, p. 4. Accordingly, use of Twana Way for construction access is not part of the regulated shoreline development and was properly treated by the County as “outside the scope of the shoreline application” that would be subject to other County permit requirements if altered. Staff Report, p. 4; SCUP Condition 7. Washington courts have consistently recognized that the SMA’s jurisdictional reach is confined to development within the 200-foot shoreline area, and they have rejected attempts to impose shoreline permit requirements on activities outside that area. In Weyerhaeuser Co. v. King County, the Washington Supreme Court held that “[o]nly those developments within the shorelines are subject to regulation by [shoreline] permits.” 91 Wn.2d 721, 736, 592 P.2d 1108 (1979) (emphasis added). In Weyerhaeuser, King County sought to use a shoreline substantial development permit to regulate logging practices on upland lands. The Court rejected that approach, ruling that “logging practices outside the shoreline cannot be regulated by means of [a shoreline] permit for developments within the shoreline” because the SMA’s structure and language limit direct regulatory authority to the shoreline area itself. Id. See also, Clam Shacks of Am., Inc. v. Skagit Cnty., 45 Wn. App. 346, 352, 725 P.2d 459 (1986), aff'd, 109 Wn.2d 91 (1987). APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT - 8 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48463766.v4 (“Weyerhaeuser holds that the SMA regulates developments within the shorelines of this state, but does not regulate developments that are outside the “shorelines” as defined by the Act.”). Thus, Weyerhaeuser’s directive is that, while a project applicant must obtain the appropriate permits for work within the shoreline jurisdiction, the County cannot use the SMA to reach outside the statute’s jurisdiction to police ancillary activities on upland properties. Here, Appellants urge exactly what Weyerhaeuser forbids – to use the SCUP to regulate traffic on an upland road, on separate property, that is beyond the SMA’s 200-foot jurisdictional line. Appellants reliance on Merkel v. Port of Brownsville, 8 Wn. App. 844, 509 P.2d 390 (1973) is equally misplaced. In Merkel, the Court of Appeals enjoined a port district from proceeding with upland land-clearing for an integrated marina redevelopment until the port had obtained the required SMA permits (in addition to multiple other missing permits) for the in-water and shoreline portions of the project. Merkel addressed an integrated project where the actual development included both shoreline and upland components. While the Merkel court does say that irreparable damage would flow from not permitting that project under the SMA, Appellants’ analysis leaves out the inconvenient fact that the Merkel project was inside the 200-foot shoreline jurisdiction area and did not have a permit under the SMA. Id. at 851-852. Merkel stands for the proposition that an applicant cannot evade the SMA by segmenting a project and starting construction on the uplands before securing necessary shoreline permits. Merkel did not hold that off-site upland work itself falls under the SMA’s permit jurisdiction. See also Manza v. Shorelines Hearings Bd., 128 Wn. App. 1023 (2005) (explaining Merkel prohibited clearing and grading the upland portion of a project site before the shoreline permit had been obtained for the unified project). Finally, Appellants rely upon Citizens to Stop the SR 169 Asphalt Plant v. King County, SHB No. 22-007 (Apr. 12, 2023). There, the Shorelines Hearings Board (“SHB”) reiterated that a shoreline permit application should describe the “full, unified, and integrated” project, including elements both within and outside shoreline jurisdiction, so the local government may APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT - 9 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48463766.v4 determine whether off-site components “may adversely impact the shoreline.” Id. at 8. That general principle simply guards against piecemeal environmental review; it does not purport to enlarge the SMA’s jurisdictional reach beyond 200 feet. In Citizens, unlike here, the off-site element in question (relocating an access road for an asphalt plant) was physically connected to the shoreline development and part of the same overall project under review. Here, Twana Way is completely outside the SMA’s shoreline jurisdiction, Mr. Rathvon and his contractor have stated that they have no present intention to alter the road, and the County has conditioned the SCUP to require appropriate permits if they decided to do so in the future. SCUP, Cond. 7, Rathvon Decl., ¶17, Richert Decl. ¶¶3-5. Additionally, the Rathvons provided the County with the Stratum Group’s February 25, 2025 Geologic Hazard Assessment for Twana Way, which demonstrated that the road is geologically stable and could be improved without impact to the shoreline environment. Rathvon Decl. Ex. 5, McShane Decl. ¶¶13-16, 18-25. Nothing in Citizens or the SHB’s “full project” policy dictates a different result on these facts. Weyerhaeuser’s pronouncement – that off-site activities cannot be regulated via a shoreline permit for shoreline development – is controlling law. The SMA allowance for liberal construction (RCW 90.58.900) cannot be distorted into a license to exceed the Act’s clear jurisdictional limits. The Legislature drew a line at 200 feet from the OHWM, and both the County and the Examiner must respect that jurisdictional boundary. The Hearing Examiner should reject Appellants’ attempt to transform a straightforward shoreline permit review into a catch-all referendum on hypothetical and speculative alleged impacts to an upland road located outside of the project site. The SMA simply does not extend that far and there are other County permitting processes (e.g. a grading permit) that address potential road alteration, should it be proposed in the future. 3. The Examiner Lacks Jurisdiction Over Twana Way Access Issues Outside the Shoreline Area. The Hearing Examiner lacks legal authority to grant the Appellants’ requested relief. APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT - 10 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48463766.v4 An administrative tribunal’s jurisdiction is limited to the powers expressly conferred by statute or necessarily implied therefrom. Here, the Examiner’s charge is to decide whether the SCUP was properly issued under the SMA and SMP. There is no provision in RCW Ch. 90.58 or the JCC that empowers the Examiner to adjudicate matters of private road usage or impose conditions for off-site traffic impacts beyond the shoreline jurisdiction. See, e.g., Skagit Surveyors & Engineers, LLC v. Friends of Skagit County, 135 Wn.2d 542, 558, 958 P.2d 962 (1998) (an administrative body has only such adjudicatory authority as is granted by statute, and relief not “clearly set forth” in the statute cannot be implied). The County’s SCUP does not authorize any alteration to Twana Way. Staff Report, 4; SCUP, p. 1, Cond. 7. Reaching outside the SMA’s geographic and legal scope to address alleged impacts that are not part of the SCUP for the project would exceed the Examiner’s jurisdiction and contravene the fundamental principle that shoreline review must remain tethered to shoreline impacts and regulations. IV. CONCLUSION Appellants’ Motion should be denied. Controlling case law does not support unfettered extension of Shoreline Management Act jurisdiction, and the McShane, Rathvon, and Richert declarations, which must be accepted as true for purposes of this summary judgment motion, demonstrate that the road is located outside of the SMA jurisdiction; that there are no current plans to alter Twana Way, that the road is stable, and that the road may be used for construction access without impact to the road or the shoreline environment. Dated this 7th day of July, 2025. SCHWABE, WILLIAMSON & WYATT, P.C. By: /s/ Patrick J. Mullaney Patrick J. Mullaney, WSBA #21982 Email: pmullaney@schwabe.com 1420 5th Avenue, Suite 3400 Seattle, WA 98101 206-622-1711 Attorneys for Applicants APPENDIX I - 1 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 APPENDIX I Excerpt from the County’s Official Shoreline Map (SMP Appendix A) CERTIFICATE OF SERVICE - 1 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 CERTIFICATE OF SERVICE The undersigned declares under penalty of perjury, under the laws of the State of Washington, that the following is true and correct: I hereby certify that on the 7th day of July, 2025, I caused to be served the foregoing APPLICANTS’ RESPONSE TO MOTION FOR SUMMARY JUDGMENT on the following parties via E-Mail: Bryan Telegin, WSBA #46686 Telegin Law PLLC 216 6th Street Bremerton, WA 98337 bryan@teleginlaw.com Greg Ballard Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, WA 98368 gballard@co.jefferson.wa.us Tara Roberts, Legal Assistant