HomeMy WebLinkAboutCAO Comment-Tricia SearsFrom: Sears, Tricia (DNR) <Tricia.Sears@dnr.wa.gov>
Sent: Tuesday, December 9, 2025 4:21 PM
To: Greg Ballard <GBallard@co.jefferson.wa.us>
Cc: Sears, Tricia (DNR) <Tricia.Sears@dnr.wa.gov>; Holman, Carol (COM)
<carol.holman@commerce.wa.gov>; DNR RE SEPACENTER <SEPACENTER@dnr.wa.gov>
Subject: Jefferson County’s Critical Areas Ordinance Amendments (2025-S-11180): WGS comments
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Hello Greg,
In keeping with the interagency correspondence principles, I am providing you with comments on
Jefferson County’s Critical Areas Ordinance Amendments (2025-S-11180).
For this proposal submitted via Planview, I looked at the proposal and focused on areas related to WGS
work. Of note, but not limited to, I look for language around the geologically hazardous areas, mineral
resource lands, mining, climate change, and natural hazards mitigation plans.
Specifically in this proposal, I reviewed the 2025 11 25 DCD CAO Draft 2025 11 24_clean.pdf, 2025 11 26
Environmental Checklist Final Signed, and 2025 11 26 SEPA DNS CAO Update Signed.
Kudos to you for working on your CAO! Overall, the provisions are thoughtful and detailed. Below I have
included comments and suggestions.
2025 11 25 DCD CAO Draft 2025 11 24_clean.pdf
On page 4 of the PDF, section 18.22.210 Identification and mapping of critical areas is nicely written. It
refers to maps on the Jefferson County GIS website but does not refer to other specific maps.
On page 4, section 18.22.220 Critical area review process, it states that “The department shall perform a
critical area review for any development application.” That is a clear statement, thank you.
Beginning on page 5, section 18.22.230 Exemptions from all types of critical area requirements, has a
long list of exemptions.
On page 13, section 18.22.270 Buffers physically separated and functionally isolated, is an interesting
section, particularly the language “The administrator may require a special report to determine whether
a critical area and its associated buffer is functionally isolated.”
On page 13, great to see section 18.22.280 Adaptive management, and the statement “The County looks
to improve processes, and, as funding and staffing allow, are interested in evaluating regulatory and
nonregulatory actions affecting critical area protections.”
On page 24, section 18.22.510 Classification/designation, great to see, for all hazards, the reference to
“Washington State Department of Natural Resources Geologic Hazard Maps” and the link included.
These maps, as noted on the WGS website, are on the Washington Geologic Information Portal. The
provisions note erosion hazards, landslide hazards, seismic hazards, and tsunami. The provisions
mention tsunami hazards as part of seismic hazards. Good to see that alluvial fans and debris flows are
mentioned.
On page 25, section 18.22.530 Protection standards, mentions geotechnical report or engineered
stormwater plan (special report); it does not say who does the report. It does require “an erosion and
sedimentation control plan prepared by a professional engineer licensed in the state of Washington.”
On page 29, a geotechnical report is mentioned again. Suggest including a code provision reference to
section 18.22.945 Geologically hazardous area reports so the reader knows that the code includes more
details in a later section.
In that same section, on page 28, it states, “Within a high risk CMZ, vegetation removal shall not be
allowed. Vegetation removal outside of a high risk CMZ shall not be reviewed under this article.” When
was CZM defined prior to this statement? I did a search of CZM and it did not locate related information
in this document. Suggest clarifying this information.
On pages 29-30, it is great to see the references to the Washington DNR tsunami maps and modeling.
On page 72, Article IX. Special Reports. Good to see this article.
On page 76, section 18.22.945 Geologically hazardous area reports. This is where the detailed
description is of the professional type, qualifications, and report/letters that are made. Great!
There were no provisions regarding physically marking the critical areas with signs, poles, fencing. And
no requirement to record to title that there is a critical area on the property except for the critical area
stewardship plan (CASP) which is applicable to the fish and wildlife habitat areas. Mitigation and
monitoring also seem to be limited to fish and wildlife, and wetlands. Many jurisdictions have codes that
have mitigation, monitoring, and maintenance provisions applicable to all critical areas. Many have
provisions that require physically marking critical areas and recording to title that the property has
critical areas. Suggest considering these provisions.
2025 11 26 Environmental Checklist Final Signed
On page 4 “Geologically hazardous areas are present in Jefferson County. This includes landslide
hazards, seismic hazards, tsunami hazards, and erosion hazards.” This document looks fine.
2025 11 26 SEPA DNS CAO Update Signed
This document looks fine.
Below, I include our usual language for this and future endeavors.
Recognizing the limitations of the current proposals, I want to mention that it would be great for you to
consider these in current or future work, be it in your comprehensive plan, development code, and SMP
updates, and in your work in general:
• Consider adding a reference to the definition of geologically hazardous areas, WAC 365-190-
120, in other areas besides the CAO. In addition, consider adding a reference to WAC 365-196-
480 for natural resource lands.
• Consider adding in other areas besides the CAO. If you have not checked our interactive
database, the Washington Geologic Information Portal, lately, you may wish to do so. Geologic
Information Portal | WA - DNR
• If you have not checked out our Geologic Planning page, you may wish to do so. Geologic
Planning | WA - DNR
Thank you for considering our comments. If you have any questions or need additional information,
please contact me. For your convenience, if there are no concerns or follow-up discussion, you may
consider these comments to be final as of the 60-day comment deadline of 1/25/26.
Have a great day!
Tricia
Tricia R. Sears (she/her/hers)
Geologic Planning Liaison
Washington Geological Survey (WGS)
Washington Department of Natural Resources (DNR)
Cell: 360-628-2867 | Email: tricia.sears@dnr.wa.gov