Loading...
HomeMy WebLinkAboutExhibit 56-2 - Att A - ULS Fact Sheet 2025 updateUNIT LOT SUBDIVISIONS FACT SHEET | JULY 2025 Unit Lot Subdivisions State Law Requirements In 2023, Washington State Legislature amended RCW 58.17.060 to require all cities, towns, and counties to include unit lot subdivision procedures in short plat regulations. RCW 58.17.060(3), established by Engrossed Second Substitute Senate Bill (ESSSB) 5258 (Chapter 337, 2023 Laws), states: “All cities, towns, and counties shall include in their short plat regulations procedures for unit lot subdivisions allowing division of a parent lot into separately owned unit lots. Portions of the parent lot not subdivided for individual unit lots shall be owned in common by the owners of the individual unit lots, or by a homeowners’ association comprised of the owner s of the individual unit lots.” In 2025, the legislature amended RCW 58.17.020 to define unit lot subdivision (ULS) terms and RCW 58.17.060 to provide unit lot subdivision requirements. This factsheet provides information and recommendations for all cities and towns located in a county planning under RCW 36.70A.040, required to adopt ULS, to consider in adopting local unit lot subdivision regulations. The Resources section, at the end of this Fact Sheet, provides links to several adopted codes, a model code, and other references. Jurisdictions are encouraged to review different approaches and adopt what works best for their local context to implement land use and housing policies. Adoption Deadlines Jurisdictions required to submit their next comprehensive plan periodic update in 2027 must include unit lot subdivision provisions as part of their update. All other cities and towns must implement the requirements within two years of the effective date of the bill, which was May 20, 2025. After the applicable deadline, a city or We strengthen communities Agency contact Lilith Vespier INFILL HOUSING MANAGER Local Government Division Lilith.Vespier@commerce.wa.gov Phone: 509-606-3530 CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 2 town must accept, process and approve an application, consistent with RCW 58.17.060. About Unit Lot Subdivisions A ULS creates new lots much like a typical subdivision, except a ULS allows flexible application of dimensional standards. In a ULS, the development as a whole is on the “parent lot” which conforms to the zoning dimensional standards while individual “unit lots” are not required to. Unit lots (also called child lots) are individual, sellable, legal lots of record with their own tax or parcel identification number. Options for ownership The ULS bill included an intent statement to “[increase] the supply and affordability of condominium units and townhouses as an option for homeownership.” Unit lot subdivisions are one method for dividing multiple housing units on a parcel into individual unit lots for sale to individual owners, providing fee simple homeownership opportunities. This is important to allow smaller units on smaller lots, allowing for a more attainable ownership unit. Homeowners can then gain equity on the home. Standards State law provides that a ULS shall be included as a short plat process. This means a maximum of four to nine unit lots may be developed, depending on how many lots the jurisdiction allows in a short plat process and the number of housing units zoning permits on the parent lot. See the “Number of Unit Lots” section below for more information. State law also provides that portions of the parent lot not subdivided for individual unit lots shall be owned in common by the owners of the individual unit lots, or by a homeowners’ association. See the “Common areas” section below for more information. While state law does not provide any additional ULS guidance, a key benefit of the unit lot subdivision concept is the flexible application of zoning dimensional standards. See the “Dimensional standards” section below for details. Example unit lot subdivision with three unit lots and a tract held in common. CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 3 Comparison of condominium and ULS Unit lot subdivision is different from or an alternative to condominium ownership. The primary differences between a ULS and condominium creation are described in the following table: Unit Lot Subdivision Condominium Options for ownership of underlying land • Individual • Combination of individual and common interest • Common interest Options for management of common area(s) • HOA • Other formal common agreement, including plat notes • HOA Allows separate ownership of stacked unit(s) No Yes Allows separate ownership of ADUs Yes Yes Warranty Not required Four-year implied warranty of quality Processing Short plat through jurisdiction State process with notice to county auditor May require jurisdiction process* Typical Processing Steps City/county platting process: • Application • Notice, if applicable • Preliminary approval • Final approval • Recording • Check with local jurisdiction for any processing requirements • Housing code inspection • Issuance of a Notice of Condominium Conversion • Public offering statement • Selling units to individual buyers • Filing a declaration with the local government * Some jurisdictions require condominium conversions to be reviewed through a local process, such as a binding site plan. The application and review processes should be clearly defined in a jurisdiction’s code. A condominium and ULS can also be combined in cases where a unit lot has stacked units and separate unit ownership is desired. Considerations for ULS development regulations Unit lot subdivision can be used with any type of attached or detached housing. If the goal is individual ownership of each dwelling, the housing units cannot be stacked, as a ULS divides the land. Where units are stacked, a condominium arrangement is the tool that can provide for separate sale. CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 4 Left to right: Townhouses in Spokane, cottage housing in Kirkland, and a fourplex built behind an existing single-family residence in Seattle The following examples illustrate how setbacks apply to a parent lot and unit lots. 1. Preserved single-family house with three attached units built in the back yard. 2. A cottage cluster development with a shared open space. 3. A townhouse development with a shared driveway. 4. A duplex with an accessory dwelling unit (ADU) on its own unit lot. Special considerations for ULS with specific housing types are discussed below. Middle housing For jurisdictions required to allow middle housing under RCW 36.70A.635, and those seeking to promote middle housing and homeownership, ULS is a valuable tool. While ULS’s have been popular in Washington for townhomes and cottage housing, jurisdictions must allow a zero-lot line short subdivision where the number of lots created is equal to the unit density for middle housing. ULS is the tool for separating middle housing types including, but not limited to, townhomes, cottage housing, duplexes, triplexes, fourplexes, fiveplexes, and sixplexes. CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 5 Accessory Dwelling Units (ADUs) Unit lot subdivisions may also be used to create individual unit lots for accessory dwelling units, in attached or detached forms. Note that RCW 36.70A.681(1)(c) requires jurisdictions to allow at least two accessory dwelling units (ADUs) on all “lots” that are located in all zoning districts within an urban growth area that allow for single-family homes. The reference to “lots” in RCW 36.70A.681(1)(c) means parent lots that meet the minimum lot size, and not unit lots. This is further emphasized by RCW 36.70A.681(1)(e) which states that the ADU provisions apply to lots that meet the minimum lot size required for a principal housing unit. RCW 36.70A.681(1)(k) also states that a city or county may not prohibit the sale or other conveyance of a condominium unit independently of a principal unit solely on the grounds that the condominium unit was originally built as an accessory dwelling unit. This is clear that ADUs are intended for separate sale as condominiums, and by extension, unit lot subdivisions. Detached houses Unit lot subdivisions can also be used for detached single-family residences. This could come in multiple forms to provide ownership opportunities, including: • Preserving an existing home and adding infill housing (new middle housing and/or ADUs depending on zoning provisions of the jurisdiction) elsewhere on the parent lot. • Developing a new detached home together with new middle housing and/or ADUs on the parent lot. • Developing multiple detached units, such as cottage housing, on a parent lot, if allowed by a jurisdiction. Dimensional standards A key benefit of a ULS is the flexible application of zoning dimensional standards. In a ULS, the development as a whole on the parent lot must comply with applicable dimensional standards. However, individual unit lots are not subject to dimensional standards that apply to the parent lot, such as (if applicable): • Lot area, depth, and width • Setbacks (front, side, rear, etc.) and setback projections • Floor area ratio (FAR) • Lot coverage (or building coverage) • Impervious surface coverage • Landscaped area minimum • Any other standard based on the size or dimensions of the lot or distance from lot lines Other dimensional standards, such as maximum building height, not related to the lot size and lot lines continue to apply to individual unit lots. Also, note that ULS is not intended to permit land uses or densities that are not otherwise allowed in the zone in which a ULS is proposed. Example: A cottage housing development uses ULS to accommodate ownership of individual cottage lots. The zone allows 60% maximum impervious surface coverage. The development as a whole is constructed with 55% impervious coverage on the parent lot, but some individual unit lots have impervious surface coverage of 80% or more (balanced by a large landscaped open space in the common area). Owners of individual unit lots may increase their impervious surface coverage further (for example, by expanding the unit or creating a paved patio) as long as the development’s entire impervious surface coverage does not exceed 60%. Commerce recommends that jurisdictions require notes on the plat stating subsequent additions or modifications to CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 6 structure(s) shall not create a nonconformity of the parent lot. Covenants, conditions and restrictions (CC&Rs) and/or ULS bylaws should clearly identify procedures for property owners to address changes affecting the conformity of the parent lot. While unit lots do not have minimum area or dimensions, some jurisdictions provide minimum standards. The City of Everett requires unit lots be “large enough” to contain a dwelling unit and accessory improvements such as decks, fences, driveways and parking, and private yard areas. The City of Spokane allows a unit lot to be as small as the footprint of the building situated upon it, subject to the requirements of the building and fire code. Common areas RCW 58.17.060(3) provides a standard for ownership and management of common areas: “Portions of the parent lot not subdivided for individual unit lots shall be owned in common by the owners of the individual unit lots, or by a homeowners’ association comprised of the owners of the individual unit lots.” Common area lots, parcels, or tracts are also legal lots of record. Management topics for common areas include how they are used by residents, procedures for maintenance and repairs, and responsibilities for utility bills and property taxes. Homeowner associations Homeowner associations (HOAs) organize decision-making with formal processes. The HOA may also provide standards or oversight on new development or changes within the parent lot/plat. They are most often associated with larger residential developments or projects with common maintenance needs. Typically, an HOA requires owners to pay monthly or yearly dues to cover upkeep and insurance costs. HOAs are regulated by RCW 64.38 where the community is made up of homeowners owning individual lots and regulated by RCW 64.90 where there are condominium units on a single lot. Common ownership State law requires that “owned in common” arrangements be permitted as an alternative to HOAs for managing common areas. This can include condominiums (RCW 64.34), common interest communities (RCW 64.90), associations of apartment owners (RCW 64.32), retirement communities, co-ops, and timeshares. It can also mean there is no formal organization of owners and that matters of common interest are managed informally, which can be a risky arrangement when one or more owners are resistant to make decisions or pay their share of common costs. Agreements Access easements, joint use and maintenance agreements, and CC&Rs identify the rights and responsibilities of property owners and/or the bylaws of an ownership association may be executed for the use and maintenance of common areas and features. These may cover topics such as: A common area in Cully Green, a courtyard apartment development in Portland, OR. Source: MAKERS. CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 7 • Garages, automobile and bicycle parking, and vehicle access areas • Common yards, courts, landscaping, and recreational elements • Shared interior walls • Exterior building facades and roofs • Sheds and other accessory structures • Solid waste collection areas • Mailboxes • Utility infrastructure and payments Commerce recommends that jurisdictions require ULS to record agreements for the ownership and management of common areas with the county auditor, along with the ULS. Off-street parking Within the parent lot, Commerce recommends providing the flexibility for required off-street vehicle parking to be located in a common area or on a different unit lot than the lot with the associated dwelling unit. This arrangement can be formalized with an easement. This option provides greater design flexibility, especially for infill development on small lots where it may be impractical for every dwelling unit to have an adjacent private parking space or garage. Removing off-street parking requirements for residential development can also increase design flexibility and streamline the administration of unit lot subdivisions. Administration Parent lot size Unit lot subdivisions should not have a minimum parent lot size separate from the zoning minimum lot size. ULS is primarily intended for smaller site developments and individual ownership of infill housing opportunities, such as middle housing, which cannot be accomplished by another process due to site size, building configurations, or development regulations. However, ULS can also be used on large sites. It is not intended to replace land division processes or function as a type of planned unit development. These examples are when a unit lot subdivision are ideal: • Existing lot, meeting the minimum lot size, with more than one dwelling unit attached or detached • Existing lot, larger than the minimum lot size, but not large enough to short plat • Existing lot, larger than the minimum lot size, but not able to short plat without removal of an existing dwelling(s) • Existing lot, regardless of size, developed with cottage housing or townhomes meeting the local development regulations Number of unit lots RCW 58.17.060(3) requires that ULS regulations be adopted within “short plat” procedures. Under RCW 58.17.020 “short plat” is the map or representation of a short subdivision. A “short subdivision” is defined as: "Short subdivision" is the division or redivision of land into four or fewer lots, tracts, parcels, sites, or divisions for the purpose of sale, lease, or transfer of ownership. However, the legislative authority of any city or town may by local ordinance increase the number of lots, tracts, or parcels to be regulated as short subdivisions to a maximum of nine. The legislative authority of any county planning under RCW 36.70A.040 that has adopted a comprehensive plan and development regulations in compliance with chapter 36.70A RCW may by ordinance increase the number of lots, tracts, or parcels to be regulated as short subdivisions to a maximum of nine in any urban growth area. CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 8 Setting the number of lots, tracts, or parcels to be regulated as short subdivisions to a maximum of nine, as allowed by the RCW, has the benefit of allowing more lots for residential development to be approved administratively and promote infill development in urban growth areas. Note that “Tier 1” middle housing cities subject to RCW 36.70A.635(1)(b) should allow unit lot short subdivisions of at least six unit lots to be consistent with the number of middle housing units that must be allowed. See more information in Commerce’s User Guide for Middle Housing Model Ordinances. The requirement in RCW 58.17.060(3) is specific to including ULS procedures in short plat regulations. However, cities, towns, and counties may also, if they choose, adopt ULS procedures in their subdivision procedures, sometimes referred to as regular, major, or long subdivisions. For example, see Wenatchee Municipal Code 11.32.080(3) and Anacortes Municipal Code 19.32.050(D)(1). Utilities When developing ULS criteria, utility purveyors should be consulted for the best or preferred practices. These practices may vary if a ULS is proposed for a new development or an existing or older developed lot; regardless, it may be beneficial to include an administrative option to deviate from the preferred practice to expedite processing. Utility purveyors (cities, special districts, and private purveyors) should consider flexible options for the design of water, sewer, electrical, and other connections to buildings in unit lot subdivisions. There are advantages and disadvantages to centralized and shared lateral connections and metering, as well as different ownership arrangements. Each option will have cost implications, and other reasons that require a variety of approaches which may be codified or administratively approved. For example: • A single-family dwelling with one or two accessory dwelling units should have the flexibility to record a unit lot subdivision without changing the existing utilities. • A townhouse developer could have an option to choose between a private master meter maintained by a homeowner’s association and having separate meters for each unit. Permit application and approval The statute requires that unit lot subdivisions be “logically integrated with the application, review, and approval procedures that apply to the underlying unit lot housing development project to the greatest extent feasible.” After the adoption deadlines, no city or town may decline to accept, process, or approve an application for a ULS, consistent with the procedural requirements of state statute, solely based on the city’s or town’s incomplete adoption or enactment of the state requirements. Timing The local code should be clear about what documents are required for a ULS and the standards of review. Allowing flexible timing in the ULS application process, such as accepting applications both before construction begins and after completion, can benefit property owners and developers. For example, the owner of an existing detached single-family residence could use a ULS to sell their backyard to a developer who then builds an accessory dwelling unit or duplex on one unit lot, while the owner retains ownership of the existing CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 9 residence on another unit lot. In another example, a townhouse development might first be developed as rental housing under single ownership and later converted to ownership units with each townhouse unit sitting on its own unit lot. Applications Additional items to consider requiring for ULS and with final plat applications may include: • A site plan where each unit lot is uniquely labeled on the plat (such as Unit Lot A, Unit Lot B, etc.), showing access, utilities, parking, setbacks, as would be required for a short subdivision • The legal description, parcel number, and/or street address (existing and modified, if applicable) of the original parent lot and for the new unit lots • Access easements and easements for existing or new utility connections • Joint use and maintenance agreements, and covenants, conditions and restrictions (CC&Rs) identifying the rights and responsibilities of property owners and/or an ownership association for use and maintenance of common areas and features Processing considerations A ULS must be noticed following RCW 36.70B.110, notice of application to the community and property owners withing 250 feet of the ULS including through notice posted on the closest public sidewalk or roadway. Comments are provided to the administrative decision maker who is tasked with making a decision based on “clear and objective design and development standards” within the time periods established for local government actions, as set forth in RCW 36.70B.080, unless extended pursuant to project -specific mutual agreement. The administrator may apply public health, safety, building code, and environmental permitting requirements to a project development. Additionally, the Administrator may limit or prohibit a unit lot subdivision in a location where development is restricted under other laws, rules or ordinances, such as in locations where development is limited as a result of physical proximity to on-site sewage system infrastructure, critical areas, or other unsuitable physical characteristics of a property. Finalizing and recording Unit lot subdivisions, being a type of short plat, will follow the same approval procedures (including the same decision-maker) and recording procedures as subdivisions. Any access easements, joint use and maintenance agreements, and CC&Rs should be recorded with the county auditor. Notes on the face of the plat should be required to identify the development as a unit lot subdivision. Examples of required notes: • The title of the plat shall include the phrase “Unit Lot Subdivision” • Approval of the development on each unit lot was granted by review of the development, as a whole, on the parent lot. • Subsequent platting actions and additions or modifications to structure(s) shall not create a nonconformity of the parent lot. • Unit lots are not separate buildable lots independent of the overall development on the parent lot; and additional development of individual unit lots may be limited as a result of the application of development standards to the parent lot. CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 10 Resources Code examples The following list links to adopted ULS standards from Washington cities. The list is ordered roughly from least complex codes to more complex codes. • Shoreline Municipal Code 20.30.410(B)(4) (adopted 2020) – a ULS may be used for “mixed single-family attached” development. • Seattle Municipal Code 23.24.045 for short subdivision and 23.22.062 for subdivisions (adopted 2020) – ULS may be used for detached single-family residences, townhouses, rowhouses, and cottage housing. • Spokane Municipal Code 17G.080.065 (adopted 2023) – ULS may be used in any development with two or more dwelling units (including accessory dwelling units) and where the parent lot is two acres or less. Accessory dwelling units have special standards for utilities and recording. The general recording requirements provide more plat note requirements than most jurisdictions. • Snohomish County Code 30.41B.205 for short subdivision and 30.41A.205 for subdivision (adopted 2017) – ULS may be used for townhouses, mixed townhouses, and cottage housing. Two separate codes depending on the number of unit lots proposed. • Wenatchee Municipal Code 11.32.080 (adopted 2023) – ULS may be used for duplexes, courtyard housing, townhouses, and cottage housing. There are clear references to short subdivisions and major subdivisions depending on the number of unit lots proposed. There are special requirements for final approval. • Snohomish Municipal Code 14.215.125 (adopted 2024) – ULS may be used for detached single-family residences, accessory dwelling units, duplexes, townhouses, cottage housing, and manufactured home parks. There are specific requirements for minimum open space and utility connections. • Everett Municipal Code 19.27 (adopted 2020) – ULS may be used for detached single-family residences, cottage housing, and townhouses. Provides special procedures for existing condominium buildings to subdivide into unit lots. Common areas may be owned in common or by a homeowner’s association. Informational resources Example of ULS information provided by Washington cities: • Tacoma – Unit Lot Subdivision Summary Sheet • Snohomish – Unit Lot Subdivision Handout • Seattle – Land Use / Master User Permit – Plat (see Tip 213A) • Bellevue – Unit Lot Subdivision amendment information page Examples of ULS short plats for a variety of cities and housing types are available here. Model code This model code provides an example of basic provisions for unit lot subdivisions. Modifications of this model code will be needed depending on each jurisdiction’s existing code organization, land division regulations, and desired approach to unit lot subdivisions. X. Unit lot subdivisions. A lot may be divided into separately owned unit lots and common areas, provided the following standards are met. 1. Process. Unit lot subdivisions shall follow the application, review, and approval procedures for a short subdivision or subdivision, depending on the number of lots. CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 11 a. Nothing prohibits a city or town from applying public health, safety, building code, and environmental permitting requirements to a development project that is subject to or integrated with a unit lot subdivision process. b. Nothing requires a city or town to authorize a development project or a unit lot subdivision in a location where development is restricted under other laws, rules or ordinances, such as in locations where development is limited as a result of physical proximity to on-site sewage system infrastructure, critical areas, or other unsuitable physical characteristics of a property. 2. Applicability. A lot to be developed with middle housing or multiple detached single -family residences, in which no dwelling units are stacked on another dwelling unit or other use, may be subdivided into individual unit lots as provided herein. 3. Development as a whole on the parent lot, rather than individual unit lots, shall comply with applicable design and development standards. 4. Subsequent platting actions and additions or modifications to structure(s) may not create or increase any nonconformity of the parent lot. 5. Access easements, joint use and maintenance agreements, and covenants, conditions and restrictions (CC&Rs) identifying the rights and responsibilities of property owners and/or the homeowners’ association shall be executed for use and maintenance of common garage, parking, and vehicle access areas; bike parking; solid waste collection areas; underground utilities; common open space; shared interior walls; exterior building facades and roofs; and other similar features shall be recorded with the county auditor. 6. Portions of the parent lot not subdivided for individual unit lots shall be owned in common by the owners of the individual unit lots, or by a homeowners’ association comprised of the owners of the individual unit lots. 7. Notes shall be prominently placed on the face of the plat or short plat as recorded with the county auditor to state the following: a. The title of the plat shall include the phrase “Unit Lot Subdivision.” b. Approval of the development (design and layout) on each unit lot was granted by the review of the development, as a whole, on the parent lot under file #_________________. c. Subsequent subdivision actions, additions, or modifications to the unit lot housing development, including all structures, may not create or increase any nonconformity of the parent lot as a whole, and shall conform to the approved unit lot housing develop ment project or to the land use and development standards. d. If a structure or portion of a structure within the unit lot housing development project has been damaged or destroyed, any repair, reconstruction, or replacement of any structure shall conform to the approved unit lot housing development project or to the land use and development standards in effect at the time the proposed repair, reconstruction, or replacement project’s permit application becomes vested. e. Additional development or redevelopment of the individual unit lots may be limited as a result of the application of development standards to the parent lot. CA received 09/16/25 EXHIBIT 56-2 UNIT LOT SUBDIVISIONS FACT SHEET – JULY 2025 12 8. Effect of Preliminary Approval. Preliminary approval constitutes authorization for the applicant to develop the required facilities and improvements, upon review and approval of construction drawings by the public works department. All development shall be subject to any conditions imposed by the city on the preliminary approval. a. By June 30, 2026, all unit lot subdivisions shall require notification to purchasers of their legal status as further described in RCW 58.17.060. 9. Revision and Expiration. Unit lot subdivisions follow the revision and expiration procedures for a short subdivision. 10. Definitions. a. “Lot, parent” means a residential lot that is subdivided into unit lots through the unit lot subdivision process. b. “Lot, unit” means a subdivided lot within a residential development as created from a parent lot and approved through the unit lot subdivision process. c. “Unit lot subdivision” means a subdivision or short subdivision proposed as part of a residential development project that meets the development standards applicable to the parent lot at the time the application is vested, but which may result in development on one or more indiv idual unit lots becoming nonconforming as to specified land use and development standards based on the analysis of the individual unit lot. d. “Clear and objective design and development standards” means locally adopted development regulations that involve no personal or subjective judgment by a public official, and are ascertainable by reference to measurable written or graphic criteria available and knowable to the permit applicant, the public, and public officials prior to submittal. 11. Process procedures. a. No public pre-decision meeting or hearing, nor any design review other than administrative design review, except for those required to comply with state law, including chapter 90.58 RCW , the Shoreline Management Act, when applicable. b. All property owners and the community within 250’ of the unit lot subdivision shall be provided notice, consistent with RCW 36.70B.110, including through notice posted on the closest public sidewalk or roadway indicating how to provide written comments to the administrative decision maker, c. The review and approval of a unit lot subdivision shall be logically integrated with the application, review and approval procedures for the underlying housing development project, to the greatest extent possible. d. Review of a unit lot subdivision shall be subject to the maximum time period for local government actions as set forth in RCW 36.70B.080, unless extended pursuant to project -specific mutual agreement as permitted by RCW 36.70B.080. CA received 09/16/25 EXHIBIT 56-2