HomeMy WebLinkAboutCAO Comment - Jessica Bryant State of Washington DEPARTMENT OF FISH AND WILDLIFE
Coastal Region • Region 6 • 48 Devonshire Road, Montesano, WA 98563-9618 Telephone: (360) 249-4628 • Fax: (360) 249-1229
December 16, 2025
Jefferson County
ATTN: Greg Ballard, Development Code Administrator, SEPA Responsible Official
621 Sheridan Street
Port Townsend, WA 98368
Subject: WDFW Comments on Jefferson County’s 2025 Draft Critical Areas Ordinance Update,
Planview Submittal 2025-S-11180
Dear Greg Ballard,
The Washington Department of Fish and Wildlife (WDFW) is dedicated to preserving, protecting, and
perpetuating the state’s fish, wildlife, and ecosystems while providing sustainable fish and wildlife
recreational and commercial opportunities. In recognition of our responsibilities, we submit the
following comments on the 11-24-2025 draft critical areas ordinance update for Jefferson County as part
of the current periodic update under the Growth Management Act (GMA), acknowledging that other
comments may be offered in the future. We strive to maintain contact throughout this update process
and look forward to future engagement opportunities.
Chapter 18.22 – Critical Areas
Table 1. WDFW recommended changes to the proposed CAO language. Policy language suggestions and
their legal implications should be vetted by the jurisdiction receiving them.
Policy Number Policy Language
(with WDFW suggestions in red)
WDFW comment
Chapter 18.22 – General Provisions
18.22.200 (5)
Applicability,
Conflicts with
other provisions
of this code and
Requests
When one type of critical area or its
associated buffer adjoins or overlaps
another type of critical area or its
associated buffer, the wider, more
protective restrictive standard shall apply.
WDFW recommends updating the code to
clearly state that when two buffers overlap, the
larger, more protective buffer should be used.
18.22.230 (1)
Exemptions
from all types of
Requirement for frequently flooded areas.
Any development or land disturbing
activity proposed within frequently
flooded areas (i.e., 100-year floodplains or
For assessing future climate-related conditions,
WDFW recommends reviewing the Climate
Mapping for a Resilient Washington, as well as
FEMA’s Resilience Analysis and Planning Tool
Page 2
critical area
requirements.
floodway) shall also require a flood permit
application to be submitted to DCD. This
requirement applies to the proposed
exemptions listed in subsection (3) of this
section.
(RAPT). With the limitation of FEMA’s Flood
Insurance Rate Map (FIRM) modeling not
considering climate change projections, we
suggest supplementing FIRM maps and related
regulations with the best available science.
18.22.230 (3) (q)
Exemptions
from all types of
critical area
requirements.
Tree removal within FWHCA, wetlands and
moderate or high landslide areas may
occur if ecological functions and values are
not impacted. All tree removal within
FWHCA, wetlands, and moderate or high
landslide hazardous areas or their
associated buffers are exempt; provided
DCD also may require:
(i) A tree removal permit;
(ii) A special report from a certified
arborist to determine if the tree is
dead, diseased or a threat to
habitable or accessory structures,
or where people congregate;
(iii)A habitat management plan or a
mitigation plan; (iv) A restoration plan to ensure that
there is adequate native tree or
native shrub cover in areas where
a tree or trees are removed;
(v) If tree removal is proposed in a
moderate or high landslide hazard
landslide hazard area, DCD may
require a geotechnical report if
tree removal could destabilize the
slope;
WDFW suggest adding criteria outlining how tree
removal within a critical area buffer zone will not
diminish habitat quality or ecological function of
that area to protect against no net loss of
ecosystem functions and values as outlined in
WAC 365-190-080. WDFW requests clarification
on what requirements for exemption must be
met, not may, prior to removal of a tree or trees.
WDFW is supportive of keeping old and
damaged trees within critical areas as snags
where possible since these trees serve as
valuable habitat for wildlife. Please see WDFW
guidance on protecting snags.
18.22.240 (4)
Nonconforming
uses and
structures.
A legal nonconforming use or structure
that has been damaged or destroyed may
be restored to a lawfully established prior
condition and the immediately previous
use may be resumed in accordance with
nonconforming provisions of JCC
18.20.260.
WDFW asks the County to consider incorporating
a time limit into this code to provide clarity and
prevent its unintended application to long-
damaged or destroyed structures. While the
complexity is different, an example of a time
limit could be taken from WAC 220-660-380
(3)(c) that states: The structure must have been
usable at the site within the past 12 months of
the time of application submittal to be
considered a replacement structure. Usable
means no major deterioration or section loss in
critical structural components is present.
Page 3
18.22.270
Buffers physical
separated and
functionally
isolated.
(1) Critical area buffers that are both
physically separated and
functionally isolated from a critical
area and do not protect the critical
area from adverse impacts shall be
excluded from critical areas
requirements of this chapter.
Physical separated and functional
isolation can occur due to
anthropogenic physical conditions
such as an existing impervious
public road, or structures of
sufficient size to eliminate buffer
functions, vertical separating, or
any other relevant physical
characteristic. The administrator
shall evaluate whether the
interruption affects the entirety of
the buffer. Individual structures
that do not fully interrupt all
ecological functions and values or
protective measures provided by
the buffer functions shall be
limited in scope to just the portion
of the buffer that is affected.
(2) Functional isolation shall be
limited to landslide hazard,
wetland and FWHCA, and their
associated buffers only.
(3) Special Report May Should Be
Required. The administrator may
should require a special report to
determine whether a critical area
and its associated buffer is
functionally isolated.
When determining whether a buffer is
functionally disconnected, the decision should
be based on a comprehensive assessment of all
ecological functions and values that the buffer
still provides, rather than specific development
types. WDFW cautions against vague statements
regarding critical areas being physically
separated or functionally isolated since critical
areas often serve a multitude of ecosystem
benefits across their full area. For instance, a
gravel road separating a home from a stream
does not fully block all riparian functions and
values. Infiltration can still occur, and trees on
the other side of the road may continue to
provide shade and contribute large wood. Other
functions that can span “barriers” include
habitat and habitat connectivity and pollution
removal (underground). A habitat management
plan prepared by a qualified professional should
be a prerequisite for approval of unmitigated
buffer exclusion.
WDFW highly encourages the County to require
a special report as detailed in Jefferson County
municipal code (JCMC) 18.22.905, such as a
habitat management report, to be required
before determining if an area is physically
separated or functionally isolated from a critical
area. These reports would follow the full
standard requirements outlined in JCMC
18.22.905 (3), and include evaluating of the
critical area and its associated buffer, buffer
impacts, and any mitigation that may be needed
for this those impacts.
18.22.280
Adaptive
management.
Adaptive management is an ongoing
process if of assessing critical area policies,
regulations, and procedures and this
process is intended to identify ways of
improving critical area protection.
Monitoring of process improvements leads
to a feedback loop that can be used to
continuously make improvements.
Monitoring includes assessing if permits
followed all applicable regulations, if
regulations are implemented consistently
over time, and if regulations are effectively
WDFW supports this code, and its alignment
with WAC 365-196-660 (2). We recommend
reviewing the Department of Commerce’s
Critical Areas Handbook, Chapter 7, for how to
establish a formal monitoring and adaptive
management program at the jurisdictional scale
for assessing no net loss.
Page 4
resulting in no net loss of critical area
functions. The County looks to improve
processes, and, as funding and staffing
allow, are interested in evaluating
regulatory and nonregulatory actions
affecting critical area protections.
18.22.950 (3) (i)
(ii)
Habitat
management
reports
A table identifying impact areas (in square
feet) and functions affected for each
FWHCA and its associated buffer that also
identifies mitigation areas (in square feet)
and functions. The table shall clearly show
a link between potential impacts (area and
function) and proposed mitigation (area
and function).
WDFW is supportive of this detail being included
in a habitat management report because it
emphasizes both the impact and mitigation
areas along with the functions tied to those
areas.
Policy Number Policy Language
(with WDFW suggestions in red)
WDFW comment
18.22 - Fish and Wildlife Conservation Areas (FWHCAs)
18.22.600 (2)
Purpose
Protect valuable aquatic and terrestrial
habitats, including lakes, ponds, rivers, and
streams and their associated riparian
areas, corridors for WDFW Priority Species,
including state or federally listed species,
and the ecosystem processes on which
these areas depend.
WDFW suggests that the County include a direct
reference to our Agency’s Priority Habitats and
Species (PHS) program. The PHS program is the
Agency’s primary means of transferring fish and
wildlife information from our resource experts to
local governments, landowners and others to
protect habitat. This resource includes coverage
of state- and federally listed species, as well as
state sensitive and candidate species.
18.22.600 (4)
Purpose
Maintain the natural geographic
distribution, connectivity, and quality of
fish and wildlife habitat and ensure no net
loss of ecological functions and values of
such important habitats, including net
losses through cumulative impacts.
WDFW recommends the proposed rewrite to
align with the WAC 365-190-080 and WAC 365-
196-830 for the protection of all critical areas
functions and values.
The Washington Habitat Connectivity Action Plan
(WAHCAP) should be reviewed and referenced
for areas that may serve as critical habitat
connectivity links across the County. The
WAHCAP website has interactive maps and
planning resources available, and WDFW can
provide technical assistance with these
resources.
WDFW also encourages the County to integrate
the multiple salmon recovery plans within
Page 5
Jefferson County into the CAO - WRIA 16 -
Skokomish/Dosewallips, WRIA 17 -
Quilcene/Snow, WRIA 20 - Sol Duc/Hoh, and the
WRIA 21 - Queets/Quinault. Salmon recovery
plans provide a road map for the recovery of
Washington salmonids and local governing
bodies of the regional organizations that are
implementing each plan’s progress.
Implementing actions identified in restoration
and salmon recovery and watershed plans help
to improve the climate resilience of streams and
watersheds, which is a goal outlined by the
Department of Commerce’s Menu of Measures
#195.
18.22.610
Classification
and designation.
FWHCAs are areas that serve a critical role
in sustaining needed habitats and species
for the functional integrity of the
ecosystem, and which, if altered, may
reduce the likelihood that the species will
persist over the long term. FWHCAs may
include, but are not limited to, rare or
vulnerable ecological systems,
communities, habitat or habitat elements
including seasonal ranges, breeding
habitat, winter range, and movement
corridors; and, areas with high relative
population density or species richness…
WDFW recommends that the complete
definition from WAC 365-190-030 (6)(a) be
captured in the County’s classification of
FWHCAs.
18.22.610 (1) (a)
Classification
and designation
Areas where federally listed species
(endangered and threatened) and state-
listed species (endangered, threatened,
and sensitive, and candidate species as
listed on WDFW Priority Habitats and
Species) have a primary association;
WDFW requests a direct reference to our
Agency’s PHS program in this code to ensure
that all PHS types are captured in the County’s
FWHCA designation.
18.22.610 (3) (b)
Classification
and designation
Washington State Department water type
maps
The County’s CAO utilizes the State Interim
Forest Practice Water Typing in WAC 222-16-030
to define stream types. WAC 222 is for forest
practices and is intended to be used for water
typing in forested areas of the state. The maps
developed for these water types may be
unreliable within urban areas due to different
land uses and how other applicable local or state
code requirements are defined or applied. WAC
365-190-130 (4)(f)(i) states that jurisdictions
should not rely solely on WAC 222-16-030 or -
Page 6
031 for the mapping of stream types for the
purpose of regulating land uses under the GMA.
Although there is currently not a single best
statewide hydrography data set that WDFW can
recommend at this time, we do highly encourage
jurisdictions to begin discussing a more reliable
alternative. WDFW encourages the County to
following the updates from Ecology’s
Washington State Hydrography Dataset Program
(WASHD). More information about this effort to
create and sustain a consistent and complete
statewide hydrography data set can be found
here. This WASHD effort aims to update the
National Hydrography Dataset (NHD) for
watercourse mapping to help ensure all state
streams and associated riparian management
zone (RMZ) natural resources are accurately
identified.
In lieu of a single best statewide hydrography
data set, for riparian buffer widths in particular,
one effective approach is to use WDFW’s Site
Potential Tree Height (SPTH200) GIS mapping tool,
which are based on NHD data. The SPTH200 tool
reflects the best available science and aligns with
WDFW’s Volume 2: Management
Recommendations, supporting the protection of
the full range of functions and values for all
streams provided by RMZs. Additional SPTH200
resources can be found on WDFW’s PHS
publications page.
18.22.630 (2) (c)
Protection
standards.
Enhancement Plan. An enhancement plan
of degraded FWHCA or its associated
buffer may be prepared by a qualified
professional individual, agency, or wildlife
biologist. The plan shall be reviewed and
approved by DCD;
WDFW recommends the County revise this code
to be consistent with other references of a
qualified professional throughout this chapter.
Please also see WDFW’s recommended
definition for qualified professional in our
comments for JCMC 18.10.170.
18.22.630 (4) (d)
Protection
standards.
Record a notice to title on the property
with the Jefferson County Auditor prior to
approval of the application, if the location
of the critical area or its associated buffer
is not identified in the development
application or on the County’s GIS mapping
system. This is intended to disclose to
WDFW is supportive of this code. This protection
is especially important in cases of buffer
averaging, where a future owner may not be
aware that the expanded/wider part of the
buffer must remain protected.
Page 7
future buyers the existence of critical areas
and their associated buffers.
18.22.630 (5) (a)
(iii)
Protection
standards.
Buffers shall be retained in their natural
condition; however, minor pruning of
vegetation to enhance views or provide
access may be permitted as long as the
function and character of the buffer are
not diminished.
WDFW recommends that the County provide
clarity on the sideboards of what minor pruning
is for this code.
Given the many benefits that trees provide, we
suggest that the County establish a limit on tree
topping associated with view enhancement and
encourage vista pruning instead. Selective
pruning allows for trees to continue to provide
habitat for wildlife without compromised tree
integrity. Please see tree topping resources by
the City of Tacoma, WSU, and the Department of
Natural Resources.
WDFW is supportive of keeping snags where
possible since these trees serve as valuable
habitat for wildlife. Please see WDFW guidance
on protecting snags.
18.22.630 (5) (b)
(ii)
Protection
standards.
The standard buffer shall be measured
landward horizontally from the ordinary
high-water mark (OHWM), channel
migration zone (CMZ), or from the outer
edge of the FWHCA as identified in the
field. The following standard buffer width
requirements are established for streams;
provided, portions of streams that flow
underground may be exempt from these
buffer standards at the administrator’s
discretion when it can be demonstrated
that no adverse effects on aquatic species
will occur.
WDFW recommends including CMZs into the
standard buffer measurement for determining a
protection area along with clarifying the outer
edge should be where those measurements are
taken. These refined additions to the code would
align with recommendations found in WDFW’s
Volume 2: Management Recommendations.
18.22.630 (5) (b)
(ii)
Protection
standards.
Table 18.22.630 (1): Required Buffer
Widths for Stream Types*
Stream Type Buffer Width
(feet)
Type “S” –
Shoreline Streams
150
Type “F” – Fish
Habitat Streams
•Urban Growth
Areas: 150
•LAMIRDs: 150
•Other County
Areas: 200
The best available science (BAS) emphasizes the
importance of protecting all streams and their
adjacent riparian areas to support full riparian
ecosystem values and function. These critical
areas also providing important movement
corridors for both aquatic and terrestrial wildlife.
As noted in our comment for JCMC 18.22.610 (3)
(b) above, WDFW highly recommends that
jurisdictions consider following the updates from
Ecology’s WASHD program.
Page 8
Type “Np”– Non-
Fish Habitat
Perennial Streams
100
Type “Ns” – Non-
Fish Habitat
Seasonal Streams
*Note:
(a) The buffers above shall apply to
culverted streams.
(b) The buffers above shall not apply to
lawfully established piped streams. The
burden of proof is on the applicant to
show that the pipe was lawfully
established; failure to demonstrate
compliance with this requirement shall
result in buffers being required.
(c) Stream type shall be determined
using the criteria in WAC 222-16-030, or
as amended.
WDFW currently recommends that the SPTH200
GIS mapping tool be used for delineating where
RMZs are located. The currently proposed code
updates fall short of WDFW’s primary
recommendation to delineate RMZ widths at
SPTH200. Where SPTH200 cannot be achieved, an
RMZ width of 100 feet is needed to achieve the
95% pollution removal function, though other
riparian functions may be compromised at this
minimum width, depending on the SPTH200 value
at a given site.
18.22.630 (5) (b)
(iii)
Protection
standards.
Table 18.22.630 (2): Required Buffers for
Other FWHCAs Types
FWHCA Type Buffer
Requirement
Kelp and Eelgrass
Beds
Buffers apply to
areas where native
kelp and eelgrass
species occur only,
and buffers shall
extend 22 feet
from each patch.
There is no buffer
for nonnative kelp
and eelgrass beds.
During WDFW Hydraulic Project Approval (HPAs)
reviews, our agency follows the outline provided
in WAC 220-660-380 (3)(b)(iii)(A) regarding
buffers for seagrass and kelp beds. This WAC
states: Structures must be located at least 25
feet (measured horizontally from the nearest
edge of the structure) and four vertical feet
away from seagrass and kelp beds (measured at
extreme low water). Please reach out to the
WDFW local area habitat biologist for HPA
coordination.
18.22.630 (6)
Protection
standards.
When buffer averaging may be allowed.
(a) The administrator shall have the
authority to average buffers in a FWHCA
area up to 25 percent when all of the
following criteria are met:
(i) The specific standards for
mitigation sequencing in JCC 18.22.640
have been applied during the siting and
design of the proposed project. To the
extent practicable, that may include
WDFW does not recommend buffer width
averaging for RMZs. Buffer averaging does not
align with WDFW’s recommendations found in
Vol. 2 because the RMZ represents the minimum
width required to provide all ecological values
and functions, including water quality, wildlife
habitat, and flood mitigation. Reducing the
buffer in any area below the RMZ width may
result in a net loss of these critical functions if
the widened part of the buffer doesn’t fully
Page 9
consideration all of the following
avoidance and minimization measures:
offset them. See RMZ widths via WDFW’s
mapping resource.
However, WDFW is encouraged to see the
substantially stronger protections included in the
revised buffer-averaging code compared to the
current County code. Limiting potential
reductions from 75% to 25% provides greater
protection for FWHCAs, increases the likelihood
that full mitigation requirements in JCMC
18.22.640 are met, and that buffer averaging
does not reduce the functions or values of the
FWHCA. All of which, are key elements WDFW is
supportive of if the County moves forward with
buffer averaging.
18.22.630 (6)
Protection
standards
(b) The administrator shall have the
authority to average buffers in a FWHCA
area up to 50 percent when all of the
following requirements are met:
(iv) Separates development from potential
flooding impacts taking climate resilience
measures into consideration;
(vi) The buffer averaging does not reduce
the functions or values of the FWHCA or
riparian habitat and protects important
wildlife habitat components for species
dependent or associated with wetland,
marine, and riverine environments;
(vii) (vii) Protects wildlife movement
corridors; and
WDFW recommends adding in the criteria found
in JCC 18.22.630 (6) (a) (iii) that ensures that the
buffer averaging does not reduce the functions
or values of the FWHCA to align with the
protection requirements of WAC 365-190-080.
WDFW also encourages the County to include
climate change information into the
considerations for the buffer averaging.
We also encourage the County to expand the
statement about protecting wildlife movement
corridors where possible to help promote
wildlife movement and prevent habitat
fragmentation.
For resources for developing wildlife and open
space corridors, please see: Landscape Planning
for Washington’s Wildlife: Managing for
Biodiversity in Developing Areas, Land Use
Planning for salmon, steelhead and trout: A land
use planner’s guide to salmonid habitat
protection and recovery, Washington Wildlife
Habitat Connectivity Working Group,
Washington Habitat Connectivity Action Plan,
WDFW’s Habitat at Home, and WDFW’s Habitat
connectivity website.
18.22.630 (8)
Protection
standards
Increasing Buffer Widths. Buffer widths
may be increased on a case-by-case basis,
as determined by the administrator, to
protect the functions and values of a
WDFW recommends adding a statement that
buffer widths may be increased for FWHCAs if
there is an established wetland buffer that
overlaps with the FWHCA. The widest buffer
Page 10
FWHCA. Supporting documents that may
be used to support this determination
include but are not limited to:
(a) The FWHCA is used by, or has
habitat features that could be used
by, state or federally listed
threatened or endangered species;
(b) The FWHCA serves as nesting or
foraging habitat for raptors or
great blue herons;
(c) The area adjacent to the FWHCA is
susceptible to erosion or landslide;
or
(d) The area adjacent to the FWHCA
has minimal deep rooting, native
vegetation or the slopes are
greater than 30 percent
(e) When the wetland buffers are
greater than riparian buffers, the
wider, more protective buffer
should apply.
between the two buffers that are often found
together should be applied so that the full
functions and values of both critical areas are
protected.
18.22.630 (9)
Protection
standards
Voluntary Restoration. FWHCAs and their
associated buffers that have been
previously altered such that the functions,
values, and natural processes have been
diminished are encouraged to be restored
to conditions that existed prior to the
alteration.
WDFW recommends reviewing the SPTH200 GIS
mapping tool as a resource to be utilized for
supporting voluntary restoration. The SPTH200
area could be used as a base for determining
where and how large restoration projects should
be to achieve full riparian function. In addition,
Chapter 4 of WDFW Vol 2 is focused on restoring
riparian ecosystems and may also be helpful in
these voluntary efforts.
18.22.630 (10)
(c)
Protection
standards
The design of stream crossings shall meet
the requirements of the Washington State
Department of Fish and Wildlife Water
Crossing Design Guidelines as amended.
Fish passage shall be provided restored if
necessary to address manmade
obstructions on site. Other alternatives
may be allowed upon a showing that, for
the site under review, the alternatives
would be less disruptive to the habitat or
that the necessary building foundations
were not feasible;
In addition to WDFW’s Water Crossing Design
Guidelines, WDFW also recommends that
jurisdictions review the WDFW’s climate-change-
resilient culvert webpage and Incorporating
Climate Change into the Design of Water
Crossing Structures: Final Project Report for
resources on how to incorporate climate-
resiliency into water crossing designs. These
resources should be used during the
development of future water crossing designs.
Additionally, while planning water crossings, it’s
recommended to also plan for how terrestrial
and aquatic wildlife can use these spaces. As the
built environment continues to grow, it is
essential to plan ways that anticipate how the
Page 11
built and natural environments may interact and
provide benefits for humans and wildlife while
preventing conflicts. Multiple-use open spaces
can serve a multitude of human activities while
also providing areas for wildlife movement.
For resources for developing wildlife and open
space corridors, please see the resources
provide in JCMC 18.22.630 (6). WDFW also
recommends reviewing the Washington
Department of Transportation’s resources on
wildlife habitat connectivity considerations in
fish barrier correction projects.
18.22.630 (12)
(b)
Protection
standards
A habitat management plan and site plan
shall be submitted that show the impacts
to the FWHCA and its buffer are
minimized, that any disturbed areas shall
be immediately restored, and the
enhanced enhancement of the site with
through the establishment of native
vegetation;
WDFW recommends the suggested rewrite to
increase clarity.
18.22.630 (15)
(e) and (f)
Protection
standards
(e) Private trails, serving one parcel or legal
lot of record, may be permitted within the
buffer provided that they do not exceed
three feet in width and are designed to
minimize the impact to FWHCAs wetlands
and their associated buffers. Trails serving
multiple parcels or subdivision shall not
exceed six 6 feet in width in the buffer.
Trails shall be constructed with pervious
surfaces or boardwalks and shall not be
utilized by motorized vehicles;
(f) The size, configuration, and surfacing of
regional and public trails within a buffer
shall be determined through a Type II
Variance. Regional trails shall be limited to
a maximum of 12-foot-wide paved surface
6-foot-wide gravel shoulders for non-
motorized public access. This shall also
include the submission of a mitigation plan
prepared by a qualified professional
wetlands specialist addressing the impacts
to the FWHCA and its buffer are
minimized, so that any disturbed areas
shall be immediately restored, and the
WDFW recommends editorial updates to align
with JCMC Chapter 18.22 and match previous
mentions that only qualified professionals should
complete reports.
Page 12
enhanced enhancement of the site with
through the establishment of native
vegetation.
18.22.640
Impact
Assessment and
Mitigation
The overall goal of mitigation shall be no
net loss of ecological functions or values,
natural processes, value, and area within a
FWHCA or its associated buffer.
WDFW recommends the proposed rewrite to
align with the WAC 365-190-080 and WAC 365-
196-830 for the protection of all critical areas
functions and values.
*Although WDFW recognizes that Jefferson County may not be revising Chapter 18.10, the associated
definitions section, as part of this update, the agency has identified two definitions that warrant
consideration based on our review. WDFW offers these suggestions for the County’s awareness and
potential consideration in either this update or as part of a future code amendment.
Policy Number Policy Language
(with WDFW suggestions in red)
WDFW comment
Chapter 18.10 – Definitions*
18.10.170 Q
Definitions -
NEW
Qualified professional: A qualified
scientific expert with expertise appropriate
to the relevant critical areas is determined
by the person's professional credentials
and/or certification, any advanced degrees
earned in the pertinent scientific discipline
from a recognized university, the number
of years of experience in the pertinent
scientific discipline, recognized leadership
in the discipline of interest, formal training
in the specific area of expertise, and field
and/or laboratory experience with
evidence of the ability to produce peer-
reviewed publications or other
professional literature. No one factor is
determinative in deciding whether a
person is a qualified scientific expert.
Where pertinent scientific information
implicates multiple scientific disciplines,
counties and cities are encouraged to
consult a team of qualified scientific
experts representing the various
disciplines to ensure the identification and
inclusion of the best available science.
WDFW recommends the jurisdiction add a
definition for qualified professional since this
term is used throughout Chapter 18 but is not
currently defined in Chapter 18.10. This
suggested definition is pulled from WAC 365-
195-905 (4).
18.10.080 H
Definitions -
NEW
Hazard Tree: A tree that a jurisdiction’s
building official or other recognized
professional (e.g., certified arborist,
WDFW recommends adding a definition for
hazard tree since this term is used throughout
Chapter 18 but does not currently have a
Page 13
registered landscape architect, or certified
forester) has determined poses a near-
term hazard to public safety or to an
existing permanent structure or public
utility.
definition in Chapter 18.10. This suggested
definition is provided by WDFW Vol 2.
Thank you for taking the time to consider our recommendations for your critical areas ordinance update
to better reflect the best available science for fish and wildlife habitat and ecosystem functions and
values.
Thank you for taking the time to consider our recommendations for your comprehensive plan to better
reflect the best available science for fish and wildlife habitat and ecosystems. We value the relationship
we have with your jurisdiction and the opportunity to work collaboratively with you throughout this
periodic update cycle. If you have any questions, need our technical assistance or resources at any time
during this process, please don’t hesitate to contact me at 360-701-7705 or at
Lindsay.Wourms@dfw.wa.gov, or Region 6’s Regional Land Use Lead, Jessica Bryant,
Jessica.Bryant@dfw.wa.gov.
Sincerely,
Lindsay Wourms
Assistant Regional Habitat Program Manager
450 Port Orchard Blvd., Suite 290
Port Orchard, WA 98366
Cc: Amy Spoon, Assistant Regional Habitat Program Manager (Amy.Spoon@dfw.wa.gov)
Jessica Bryant, Regional Land Use Lead (Jessica.Bryant@dfw.wa.gov)
William Robinson, Area Habitat Biologist (William.Robinson@dfw.wa.gov)
Adam Samara, Area Habitat Biologist (Adam.Samara@dfw.wa.gov)
Carol Henry, Area Habitat Biologist (Carol.Henry@dfw.wa.gov)
Brady Green, Habitat Biologist (Brady.Green@dfw.wa.gov)
Aleks Storvick, Habitat Biologist (Aleks.Storvick@dfw.wa.gov)
Gwen Lentes, Regional Habitat Program Manager (Gwendolen.Lentes@dfw.wa.gov)
Kara Whittaker, LUCP Section Manager (Kara.Whittaker@dfw.wa.gov)
Marian Berejikian, Environmental Planner (Marian.Berejikian@dfw.wa.gov)