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HomeMy WebLinkAboutCA-26 Respondents Reply Motion to Dismiss (COUNTY 072925)RESPONDENTS’ REPLY ON MOTION TO DISMISS Page 1 of 9 Jefferson County Prosecuting Attorney 1820 Jefferson Street/P.O. Box 1220 Port Townsend, WA 98368 360-385-9180 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BEFORE THE JEFFERSON COUNTY HEARING EXAMINER MARILYN SHOWALTER and JAN WOLD Appellants, vs. JEFFERSON COUNTY, Respondent, and ROCK ISLAND SHELLFISH; ROBERT CARSON, Respondent. Case No.: 072525 (SDP2024-00006) RESPONDENTS’ REPLY ON MOTION TO DISMISS I.Introduction Neither Ms. Showalter nor Ms. Wold submitted comments on the environmental impacts of Rock Island Shellfish’s proposed oyster farm (“Proposal”) as required by JCC 18.40.330, which specifically defines and limits the ability to file appeals of a mitigated determination of nonsignificance (“MDNS”). Appellants’ contentions that they nonetheless are entitled to appeal the MDNS are legally and factually meritless. Thus, Appellants’ MDNS appeal must be dismissed. II.Authority and Argument A.Appellants Misconstrue JCC 18.40.330. Appellants contend JCC 18.40.330 does not bar their MDNS appeal, arguing CA received 07/29/25 EXHIBIT CA-26 RESPONDENTS’ REPLY ON MOTION TO DISMISS Page 2 of 9 Jefferson County Prosecuting Attorney 1820 Jefferson Street/P.O. Box 1220 Port Townsend, WA 98368 360-385-9180 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 this code section is entirely permissive and not restrictive. Appellants’ Response to County/Applicants’ Motion to Dismiss (“Response”) at 6. Appellants are incorrect. The first sentence of JCC 18.40.330 makes clear that it is restrictive, not merely permissive: “In the absence of a specific right of appeal authorized under this UDC, there shall be no right to administrative appeals.” JCC 18.40.330(3)(a) specifically authorizes the right to appeal an MDNS and limits it to “the applicant or anyone commenting on the environmental impacts of the proposal (as further set forth in JCC 18.40.780).” Even absent the restrictive language in the first sentence, the explicit listing of specific individuals who have a right to appeal an MDNS in JCC 18.40.330(3)(a) would operate to exclude all other individuals under expressio unius est exclusio alterius. State ex rel. Port of Seattle v. Dep’t of Pub. Serv., 1 Wn.2d 102, 113, 95 P.2d 1007 (1939) (where a statute enumerates specific persons or things to be affected by it, there is an implied exclusion of all others). Appellants do not dispute that the deadline for commenting on the environmental impacts of the Proposal as set forth in JCC 18.44.780 was August 9, 2024. Respondents’ Motion to Dismiss (“Motion”) at 3; First Frostholm Decl., Ex. A. Nor do they dispute that they failed to provide environmental comments on the Proposal during the comment period. Motion at 3; First Frostholm Decl., ⁋ 10. Accordingly, they are not authorized to administratively appeal the MDNS, and their appeal must be dismissed. B.Appellants Do Not Have a Right to Appeal an MDNS Under Other Sections of Title 18. Appellants contend that they have a right to appeal the MDNS pursuant to other provisions of Title 18, specifically JCC 18.40.810(3) and (6), and JCC 18.10.160(P). Response at 4-6. This contention is legally and factually meritless. Legally, none of these provisions authorize administrative appeals of an MDNS. JCC 18.40.810(3) authorizes only administrative appeals of a DNS, not an CA received 07/29/25 EXHIBIT CA-26 RESPONDENTS’ REPLY ON MOTION TO DISMISS Page 3 of 9 Jefferson County Prosecuting Attorney 1820 Jefferson Street/P.O. Box 1220 Port Townsend, WA 98368 360-385-9180 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MDNS. JCC 18.40.810(3) (The decision of the responsible official on Type III permits making a threshold determination of a DNS . . . may be appealed to the hearing examiner”). These are distinct decisions, and the County knows how to authorize administrative appeals of an MDNS when it desires and intends to do so. In fact, it did so in the very preceding subsection, JCC 18.40.810(2), which authorizes administrative appeals of “[t]he decision of the responsible official on Type II permits making a threshold determination of a DNS or MDNS …”1 It also did so in JCC 18.40.330(3)(a), discussed above (authorizing appeals of “[t]he responsible official’s DNS or MDNS”). Well-established rules of statutory interpretation prohibit courts from adding words to unambiguous statutes when the legislature has chosen not to include them, even when courts feel a term was omitted in error.2 State v. Kintz, 169 Wn.2d 537, 550, 238 P.3d 470 (2010). JCC 18.40.810(6) also does not authorize appeals of an MDNS, or any other specific type of SEPA decision for that matter. It simply states that an applicant or other party of record “may file a SEPA appeal as provided in this article.” JCC 18.40.810(6) (emphasis added). As discussed above, however, Article X of JCC Chapter 18.40 provides for administrative appeals of a DNS, but not an MDNS, associated with a Type III permit. JCC 18.10.160(P) (“Parties of record”) does not authorize appeals of any type of SEPA decision. It simply defines “Parties of record.” While this definition is important when Title 18 of the Code authorizes parties of record to appeal an MDNS for a Type III permit, as just discussed, no provision of Title 18 does so. 1 JCC 18.40.810(2) does not apply, because the Proposal’s SDP is a Type III permit. JCC 18.40.040. 2 There is no indication that the omission of “MDNS” in JCC 18.40.810(3) was in error. Given the County knew how to, and did, identify an MDNS as an appealable decision elsewhere in Chapter 18.40 JCC, this omission in JCC 18.40.810(3) must be considered deliberate and respected. CA received 07/29/25 EXHIBIT CA-26 RESPONDENTS’ REPLY ON MOTION TO DISMISS Page 4 of 9 Jefferson County Prosecuting Attorney 1820 Jefferson Street/P.O. Box 1220 Port Townsend, WA 98368 360-385-9180 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Factually, even if Title 18 authorized parties of record to administratively appeal an MDNS, which it does not, the record demonstrates that Appellants do not qualify as parties of record.3 Parties of record are limited to: [P]ersons or entities who wish to receive a copy of the hearing examiner’s decision and notice of upcoming hearings. “Parties of record” includes the applicant, appellant, petitioner, respondent, their agents and representatives, the county, and persons or entities who: indicate on a sign-up sheet, at a public hearing, that they wish to become a party of record; or for public hearings specifically advised the examiner’s office by individual written letter or electronic mail of their desire to become a party of record. Persons who only signed petitions or mechanically produced form letters may be excluded as parties of record. JCC 18.10.160(P) (“Parties of record”). This definition of “parties of record” is very deliberate and specific, striking a balance between competing interests of allowing members of the public to be considered parties for a particular project and preventing undue administrative burdens on the County associated with granting people status as a party of record. The bare minimum requirement to be considered a party of record is to notify the County of an interest in a specific project. Even then, not everyone is considered a party of record; people who sign petitions or mechanically produced letters may be excluded as parties of record. Id. Rather, only those who request to receive a copy of the hearing examiner’s decision (e.g., on a sign-up sheet at a public hearing) and notice of upcoming hearings (by specifically advising the examiner’s office by individual letter or email) are parties of record. Id. 3 As discussed in Respondents’ Motion, state law (WAC 197-11-545(2)) provides that a member of the public’s failure to provide timely comments is construed as lack of objection and precludes them from appealing a SEPA decision. Motion at 4-5. Thus, to prevent a conflict between state and local law (whereby local law would allow something—appeal of a SEPA decision by someone who failed to provide comments—that state law forbids), parties of record would also need to provide comments on the environmental impacts of a proposal in order to file a SEPA appeal. Parkland Light v. Bd. of Health, 151 Wn.2d 428, 433, 90 P.3d 37 (2004). CA received 07/29/25 EXHIBIT CA-26 RESPONDENTS’ REPLY ON MOTION TO DISMISS Page 5 of 9 Jefferson County Prosecuting Attorney 1820 Jefferson Street/P.O. Box 1220 Port Townsend, WA 98368 360-385-9180 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The undisputed facts demonstrate that Appellants did not take the required steps to gain status as a party of record for the Proposal. Appellants admit that Ms. Wold submitted no requests that would grant her party of record status, Response at 6, and they identify only one request that purportedly grants Ms. Showalter such status – an email message from Ms. Showalter to Donna Frostholm within the County’s Department of Community Development (“DCD”) in which Ms. Showalter asks “to be notified of any permit processes associated with aquaculture on [] parcels” 965100009, 965100010, and 965100011 , Response at 5, 13.4 This email fails to satisfy the requirements to obtain party of record status for a particular project. It does not request to receive a copy of the examiner’s decision on the Proposal or to be notified of public hearings on the Proposal. Id. In fact, it fails the bare minimum requirement of asking to be notified of anything specific to the Proposal (or, for that matter, any other particular project). Id. This is despite the fact that Ms. Showalter knew of Rock Island’s desire to operate the Proposal, as evidenced by the full text of Ms. Showalter’s November 30 email and other materials, including the Proposal’s pre-application from. Id. at 10-13. Ms. Showalter easily could have, but failed to, become a party of record for the Proposal by submitting a request to be to receive a copy of the examiner’s decision for the Proposal or to be notified of upcoming hearings for the Proposal (the latter request, however, would have needed to have been made to the examiner’s office, not DCD). JCC 18.10.160(P). Instead, she submitted a very general request to be notified of “any permit processes associated with aquaculture on these parcels.” Response at 13. This request covers multiple parcels, is not specific to any type of 4 Page 13 corresponds to the PDF page number when viewing Appellants’ Response in electronic form. This is represented as an email from Ms. Showalter to Ms. Frostholm dated November 30, 2023. There is no exhibit or attachment number asso ciated with this email, nor is it attached to a declaration stating what it is and that it is a true and accurate copy of the original. Notwit hstanding these shortcomings, Respondents assume that it is accurate, albeit with some highlighting added, presumably by Ms. Showalter. CA received 07/29/25 EXHIBIT CA-26 RESPONDENTS’ REPLY ON MOTION TO DISMISS Page 6 of 9 Jefferson County Prosecuting Attorney 1820 Jefferson Street/P.O. Box 1220 Port Townsend, WA 98368 360-385-9180 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 permit, is not limited to any type of aquaculture project, and has no temporal limit. Id. If this request suffices to make her a party of record for the Proposal, it would equally grant her this status for any and all future aquaculture projects at any of these parcels at any time in the future, including 10, 20, or 30-plus years down the line. DCD would be required to spend extensive resources keeping track of managing Ms. Showalter’s perpetual request, not to mention doing the same thing for additional, subsequent requests submitted to the County once this dangerous precedent is set for acquiring status as a party of record. This is an absurd and strained result, is inconsistent with the plain language of JCC 18.10.160(P), and undermines the balance the County struck in carefully defining “parties of record.” Fraternal Order of Eagles, Tenino Aerie No. 564 v. Grand Aerie of Fraternal Order of Eagles, 148 Wn.2d 224, 239, 59 P.3d 655 (2002). It must therefore be rejected. Because no section of Title 18 grants a “party of record” authority to administratively appeal the Proposal’s MDNS, and Appellants do not even qualify as parties of record, their MDNS appeal is unauthorized and must be dismissed. C.Appellants’ Notice Deficiency Arguments Are Meritless. Beyond their mistaken arguments that they are entitled to administratively appeal the MDNS pursuant to JCC 18.40.330, JCC 18.40.810(3) and (6), and JCC 18.10.160(P), Appellants claim public notices for the Proposal were inadequate. Response at 2-4, 7-8. Given this claim is not specifically tied to compliance with the foregoing provisions that purportedly authorize Appellants to appeal the MDNS, this claim is irrelevant and may be disregarded. It also substantively incorrect. The County’s notice of application (“NOA”) requirements are set forth at JCC 18.40.210 and consist of (1) publishing the NOA in the official County newspaper, (2) posting the NOA “on the property,” and (3) mailing the NOA to property owners within 300 feet of the Property. DCD published, posted, and mailed the NOA in accordance with JCC 18.40.210. First Frostholm Decl., Ex. C CA received 07/29/25 EXHIBIT CA-26 RESPONDENTS’ REPLY ON MOTION TO DISMISS Page 7 of 9 Jefferson County Prosecuting Attorney 1820 Jefferson Street/P.O. Box 1220 Port Townsend, WA 98368 360-385-9180 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 (affidavit of publication); First Carson Decl., Ex. A (property posting); First Frostholm Decl., Ex. B (affidavit of posting); Third Frostholm Decl. ⁋ 5-6; First Frostholm Decl., Ex. A (certificate of mailing). Appellants critique the Property posting, Response at 2-4, but fail to prove noncompliance with the posting requirements, specified at JCC 18.40.210(2)(a)-(e). The posting (a) consisted of a notice board on the site road frontage, (c) the notice board was constructed and installed in accordance with normal county practice, (d) the notice board was in good condition, legible and in place for at least 15 calendar days, and (e) the affidavit of posting was timely provided as reflected. First Frostholm Decl., Ex. B; First Carson Decl. Ex. A; Third Frostholm Decl. ⁋ 5-6. While subsection (b) authorizes DCD to have additional notice boards posted where a site does not abut a public road, it does not require this, and DCD did not do so in this case. JCC 18.40.210(2)(b). Contrary to Appellants’ characterization, the road is not closed to public traffic, and there are no “No Trespassing” or other signs preventing or directing the public from driving on the road. Response at 2-4. Appellants’ claim that “no one saw the poster,” Response at 2, is unsupported speculation. Instead, the sign “was visible from Killapie Beach Road,” Third Frostholm Decl. ⁋ 5, and there is a good reason for posting the sign at the Property rather than on Shine Road as Appellants request, Response at 4; doing so ensures the public is clear where the Proposal would be located. Third Frostholm Decl. ⁋ 6. Beyond the notice requirements in JCC 18.40.210, JCC 18.40.780(1)(a) provides one additional, limited requirement, stating the NOA and SEPA checklist must be sent to “anyone requesting a copy of the environmental checklist for the specific proposal.” Appellants could have easily submitted such a request, but as forth above, they submitted no requests specific to the Proposal, including requests for the environmental checklist. Supra § II.B; Third Frostholm Decl. ⁋ 7. Appellants also argue reasonable notice was not provided pursuant to WAC CA received 07/29/25 EXHIBIT CA-26 RESPONDENTS’ REPLY ON MOTION TO DISMISS Page 8 of 9 Jefferson County Prosecuting Attorney 1820 Jefferson Street/P.O. Box 1220 Port Townsend, WA 98368 360-385-9180 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 197-11-545(2), contending it was unreasonable not to send notice to Ms. Showalter given her general information request. Response at 7 -8. But WAC 197-11-545(2) and WAC 197-11-510 (which is cross-referenced in -545) simply list notifying interested individual as an example of a reasonable notification method. Such notice is not required, and regardless Appellants failed to a request information specific to the Proposal. Supra § II.B. Further, WAC 197-11-510(2) requires each agency to specify its method of public notice in its SEPA procedures. The County did so at JCC 18.40.210, and DCD complied with them. Finally, Appellants complain that the NOA has missing or incorrect information. Response at 8. As set forth in Respondents’ response to Appellants’ motion to dismiss, Appellants failed to demonstrate that any error was committed; any errors that were made were inconsequential and harmless; and many alleged errors do not relate to SEPA compliance. Respondents’ Response to Appellants’ Motion to Dismiss at 4-7. Importantly, Appellants do not contend (let alone substantiate) that they were in fact confused or misled by the alleged errors in the NOA. Response at 2-4, 7-8. Rather, their concerns are premised on potential or hypothetical confusion and broader grievances with the County’s notification process. The County’s processes, however, comply with state law and even provide opportunities for Appellants and other members of the public to obtain specialized notice of the Proposal. JCC 18.40.210; JCC 18.40.780(2)(a); WAC 197 -11-510. Appellants failed to avail themselves of these opportunities, however, or demonstrate that the County did not comply with its established procedures. D.Appellants’ Request to Dismiss on the Basis of Appellants’ Motion is Baseless. Last, Appellants contend that the MDNS and SEPA appeal are “moot” on the basis that the NOA is flawed. Response at 1-4. Appellants’ argument appears to be that the Hearing Examiner can reverse and remand the MDNS due to CA received 07/29/25 EXHIBIT CA-26 RESPONDENTS’ REPLY ON MOTION TO DISMISS Page 9 of 9 Jefferson County Prosecuting Attorney 1820 Jefferson Street/P.O. Box 1220 Port Townsend, WA 98368 360-385-9180 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Appellants’ claims that the NOA had errors, even if Appellants do not have authority to administratively appeal the MDNS. Id. at 1-2. Appellants’ argument is baseless. As set forth in Respondents’ Motion to Dismiss, dismissal of Appellants’ MDNS appeal is the only appropriate remedy given they are not authorized to administratively appeal the MDNS. Respondents’ Motion to Dismiss at 5; Kaiser Aluminum & Chem. Corp. v. Dep’t of Labor & Indus., 121 Wn.2d 776, 787, 854 P.2d 611 (1993); ZDI Gaming, Inc. v. Wash. State Gambling Comm’n, 173 Wn.2d 608, 631, 268 P.3d 929 (2012).5 Thus, Appellants’ lack of authority to bring the MDNS appeal cannot be ignored or disregarded, and their MDNS appeal must be dismissed. III.Conclusion For the reasons set forth above and in Respondents’ Motion to Dismiss, the Hearing Examiner should dismiss Appellants’ appeal and affirm the MDNS. RESPECTFULLY SUMBITTED this 29th day of July, 2025. JAMES KENNEDY Jefferson County Prosecuting Attorney ______________________________ Ariel Speser, WSBA #44125 Civil Deputy Prosecuting Attorney Jefferson County PLAUCHÉ & CARR LLP By: /s/Jesse DeNike Jesse DeNike, WSBA #39526 1218 Third Avenue, Suite 2000 Seattle, WA 98101 Phone: 206-588-4188 Email: jesse@plauchecarr.com Attorney for Rock Island Shellfish 5 For reasons set forth in Respondents’ Response to Appellants’ Motion to Dismiss and above, Appellants’ contentions in their Motion to Dismiss fail on substantive and other grounds, and hence their Motion to Dismiss should be denied even if they were authorized to bring an administrative appeal of the MDNS, which they are not. CA received 07/29/25 EXHIBIT CA-26