HomeMy WebLinkAboutHearing Draft Comments 2026-05-1503 '-/
Joel Peterson
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Sears, Tricia (DNR) <Tricia.Sears@dnr.wa.gov>
Wednesday, April 22, 2026 2:29 PM
Joel Peterson
Sears, Tricia (DNR); Holman, Carol (COM)
Jefferson County's comprehensive plan amendments (2025-S-10974A): WGS comments
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Hello Joel,
In keeping with the interagency correspondence principles, I am providing you with comments on Jefferson County's
comprehensive plan amendments (2025-S-10974A).
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 plan.
Specifically in this proposal, for critical areas I reviewed the Foundation, Land Use, Natural Resources, Environment, and
Climate Element.
Kudos to you for making changes to the comprehensive plan. Overall the comp plan is thoughtful and well-written. It's
nice to see the action plan parts of these elements!
Foundation
Nicely written. Critical areas is mentioned twice. Consider mentioning critical areas and noting the specific ones that
Jefferson County has, the hazard mitigation plan, and other plans. It could be a mention that simply refers the reader to
other parts of the comprehensive plan for more details. Some comp plans list the related plans like the hazard mitigation
plan etc.
Land Use
Nice to have the description that the Land Use Element is arranged in four components. Good to see the three land use
typologies, including natural resource lands. Thank you for noting that additional information on natural resource lands
is found in the Natural Resources Element.
Great to see Goal LU-G-7 "Preserve the functions, values, and resiliency of ecologically sensitive areas and protect
development from the risks of environmental hazards." Goal LU-G-9 mentions hazard mitigation planning, that's the
only mention of it in this chapter. Suggest mentioning the hazard mitigation plan that Jefferson County has. Suggest
relating the hazard mitigation planning to all hazards, not just flooding. A word search shows that critical areas are
mentioned 21 times. Great! Consider adding a sentence that states clearly what the critical areas are in Jefferson
County. A word search shows that geologically is mentioned once, in LU-P-6.3 for geologically sensitive areas. Suggest
describing which of the geologically hazardous area hazards are found in Jefferson County. If these are described in
other parts of the code, please let the reader know that by mentioning and referring to those parts. Excellent to see a lot
1
of maps in the Land Use Element. Suggest having maps of critical areas too or noting that those maps will be in another
element.
Natural Resource
Good to see the connections described at the beginning, of this Natural Resources Element with other elements in the
comp plan. Great to see the description of mineral lands. Nice work on providing details on natural resource lands,
including goals and policies. This is one of the more detailed descriptions in a comp plan that I have seen, related to
natural resource lands. Of note, this is interesting, Policy NR-P-6.1 "Work with Washington Department of Natural
Resources to develop standards and guidelines to identify and address the impact of mining operations on adjoining
properties. Conditions placed on mining uses should not have the intent of rendering mining operations economically
unfeasible." Goal NR-G-7 is good.
Environment
Good to see the Designating and Protecting Critical Areas section. That section states there are geologically hazardous
areas but does not describe which of the hazards are in Jefferson County. In the Environment Plan section there is a
reference to 5-5 for geologically hazardous areas. The map shows landslide hazard, erosion hazard, seismic hazard, and
channel migration zones. Consider stating in the text that these are the geologically hazardous areas hazards, in this
element and the other elements. There is a section called Critical Areas Regulated Under the Critical Areas Ordinance
which includes goals and policies. Those look fine. As mentioned below, consider reviewing the Washington Geologic
Information Portal for best available science information.
Climate Element
Great to see this statement and the supporting statements, "The issues in the Climate Element are complex and
dynamic, and several other elements in the Comprehensive Plan interact with the Climate Element: ... " Suggest
mentioning critical areas and where in the comp plan elements that discussion and maps of the critical areas can be
found. Good to mention of links to other elements, a mention of the climate plan, resource lands, and health impacts.
Great to see the goals and policies, including those with emergency management. Good to see hazard mitigation
mentioned five times. Suggest also specifically stating the name of the relevant hazard mitigation plan.
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 I WA - DNR
• If you have not checked out our Geologic Planning page, you may wish to do so. Geologic Planning I 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 6/13/26.
Have a great day!
Tricia
Tricia R. Sears (she/her/hers)
Geologic Planning Liaison
Washington Geological Survey (WGS)
Washington Department of Natural Resources (DNR)
2
Joel Peterson
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Jeremy Williammee
Wednesday, April 29, 2026 11 :48 AM
Mark Rose
Joel Peterson; 2025 Comp Plan
FW: Comp Plan and BSAP
wawa_proposal_f - BR9.pdf
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Mark,
Thanks for reaching out, and for the comments on the Comp Plan draft. We are indeed full steam ahead on
completing that process. I am looping in Joel Peterson here, and our Comp Plan comment email, to ensure
your comments below are entered into the record - I highlighed those Comp Plan comments in yellow below.
As for the map. Despite a thorough search of DCD's files, the only map we've been able to locate is the
attached Figure BR-9 from the Brinnon Subarea Plan (which I believe is what you already have on the
brinnoninfo page). That map is marked 'proposed' but is reference in County Code explicitly. I've attached it
here for regerence just in case. County GIS mapping shows the underlying zoning of the convienance
crossroads around Yelviks and Rural Residential in the remainder of the WaWa point overlay. We do not
currently have a layer for this in GIS, but that is something to explore.
JCC 18.15.572 designates the Wawa Point area in Brinnon as the Small-Scale Recreation and Tourist (SRT)
Overlay. Its purpose is to support small-scale recreation and tourist development that fits the needs, scale,
and rural character of the BPA. Section (2) references Figure BR-9 of the Brinn on Subarea Plan:
(2) Applicability. This section shall apply to all small-scale recreation and tourist uses identified in Table
3-1 in JCC 18.15.040 and subject to the performance standards identified in JCC 18.20.350. The WaWa
Point SRT overlay district shall encompass those areas within the Brin non Planning Area identified on
Figure BR-9 of the Brin non Subarea Plan. The provisions of this section constitute an overlay district
(i.e., floating zone) over the underlying rural residential districts at WaWa Point. All other provisions of
this unified development code shall apply to such uses in the SRT overlay district unless otherwise
exempted by this section.
Best,
Jeremy
From: Mark Rose <mark@markrose.org>
Sent: Wednesday, April 29, 2026 8:39 AM
To: Jeremy Williammee <JWilliammee@co.jefferson.wa.us>
Subject: Comp Plan and BSAP
1
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Hi Jeremy:
I imagine you're embroiled in the sprint to finalize the Comp Plan, but I hope you can help us with a few items.
We formed a citizens group to study the Brinnon Subarea Plan, and we're looking into planning within the
Brinnon Planning Area. I have some comments on the Draft Comp Plan, as reflected here:
https://www .co. jefferson. wa. us/Docu mentCenter /View /24340/01-La nd-Use-H EARi NG-DRAFT
LAND USE ELEMENT
[COMP PLAN COMMENT] Page 1- 73 Is this correct? It discusses the SRT overlay, but it's not reflected on the
map.
We're trying to get a handle on the 16-acre SRT overlay at WaWa Point. It is discussed in detail for 10 pages
(33 - 43) in the 2002 Brin non Subarea plan. The only map I have is at the bottom of this page:
https://brinnoninfo.com/resources/
Do you have a more detailed map of the SRT Overlay? Right now, it is the only zoning outside the floodplain
that can be developed, and we'd like to see if we can make something happen there, since a significant
portion of BSAP is devoted to the SRT.
[COMP PLAN COMMENT] See pgs 1- 4 & 1- 5 - Growth Projections through 2045. Ryan, the project manager
for the MPR projects that the population of the Brin non Planning Area will double at the project's completion.
They have app. 25 more years to complete the development agreement. If that population projection is
correct, it has a dramatic impact on planning for Brin non over a 20-year horizon, per the Comp Plan. The
Comp Plan has projections for the RVC, but the projected doubling of the surrounding area will put significant
pressure on the RVC and the Planning area. Is there a way to discuss this in the Comp Plan? We'll be
addressing this in any review of BSAP.
[COMP PLAN COMMENT] See pages 1- 7 - If the population doubles and there is a resort at Black Point, could
it be that there's zero employment growth in Brinnon? Are we looking only at the RVC, not the surrounding
areas with home-based businesses and cottage industries? Where's the economic development promised with
a resort in the Brinnon Planning Area?
Thank you for all your help. We really appreciate it.
Mark
This is how Al defines the "Brinnon Planning Area.''
The Brinnon Planning Area is a designated region in southern Jefferson County, WA, covering the
unincorporated community of Brin non, located at the mouth of the Dosewallips River along Hood Canal.
Defined by the Brinnon Subarea Plan (adopted 2002), this area spans from Rainbow Campground to the
2
Jefferson County line, guiding development and conservation between the Olympic National Park and Hood
Canal. It is heavily focused on managing rural development, specifically the proposed Pleasant Harbor Master
Planned Resort (MPR} at Black Point.
Jefferson County, WA +4
Key details about the Brin non planning area include:
• Location & Geography: It extends north to south from Mount Walker to the Jefferson County line near
Triton Cove, including the communities of Seal Rock, Brin non, and Duckabush.
Jefferson County, WA +1
• Purpose: The Subarea Plan directs development, preserves rural character, and manages land use, with
a significant emphasis on tourism and forestry.
Jefferson County, WA +3
• Usage Examples/Developments:
o Master Planned Resort (MPR): The area is famous for the proposed Pleasant Harbor Marina
and Golf Resort, which plans to include 890+ residential units, a marina, a golf course, and
commercial space.
o Conservation/Recreation: The region is heavily forested, featuring Dosewallips State Park and
serving as a recreational base for hiking, biking, and water sports.
Jefferson County, WA +3
Mark Rose
360-301-2600
mark@markrose.org
3
03b
Joel Peterson
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Jeremy Williammee
Monday, May 11, 2026 11 :27 AM
2025 Comp Plan
Joel Peterson
FW: Comp Plan thoughts
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Comp Plan Update
-----Original Message-----
From: Scott Walker <walkers@olympus.net>
Sent: Sunday, May 10, 2026 7:27 PM
To: jeffbocc <jeffbocc@co.jefferson.wa.us>
Subject: Comp Plan thoughts
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Hi all,
In going through the plan, I may have missed what I'm about to whine about. If so, please forgive me for already having
a different full plate.
After my, admittedly, light perusal of the Comp Plan, I came away thinking the grand vision for a dense and walkable
future will not be realized without a couple of significant policy recommendation additions.
If residential density and walkability is a goal, then parking policy MUST be addressed so to greatly minimize the asphalt,
sprawl, and lack of walkability that parking policy currently mandates.
If a dense and walkable commercial core is a goal, then it is essential there be traditional mixed-use zoning. I only see
antiquated zoning that got us into the car-oriented mess.
Without these two changes, our county will continue its climate-killing, GHG heavy, car-oriented development pattern:
sprawled, unwalkable.
I strongly encourage you undertake these necessary changes.
Yours,
Scott G. Walker
1
May 13, 2026
Jefferson County Planning Commission
Jefferson County Department of Community Development - CP 2025 Comments
621 Sheridan Street
Port Townsend, WA 98368
RE: Written Comment in Support of Proposed UDC Amendments - 2025
Comprehensive Plan and UDC Periodic Review (PRRD Provisions)
Dear Planning Commissioners and Planning Staff,
We are writing in strong support of the proposed amendments to the Jefferson County
Unified Development Code (UDC) as presented in the April 2026 Staff Report for the
2025 Comprehensive Plan and UDC Periodic Review. As applicants and future
residents of a planned cohousing community in Jefferson County, we are particularly
encouraged by the updates to the Planned Rural Residential Development (PRRD)
provisions, which we believe represent meaningful and forward-looking progress for
affordable, environmentally sensitive, rural housing in this county.
We wish to highlight two specific amendments that are especially significant for our
project and, we believe, for the county's broader housing goals:
1. Recognition of Substandard Lots as Eligible for PRRD (JCC 18.15.485)
The addition of subsection (4) to JCC 18.15.485 - Minimum and Maximum Land Area
- Dwelling Unit Cap and Cluster Cap - is a significant and welcome change. Under the
prior code, substandard lots were effectively barred from participating in the PRRD
process, regardless of whether they were legally recognized lots of record. This created
an inequitable barrier for rural landowners who hold smaller but legally valid parcels.
The amended language now explicitly recognizes that substandard lots formally
recognized as legal lots of record are eligible to apply for a PRRD, provided the
proposal demonstrates that land area is sufficient to meet public health and
environmental protection standards, and that the application is accompanied by a
binding site plan. This is a thoughtful and appropriately conditioned expansion of PRRD
eligibility that balances development opportunity with continued protection of rural
character and public health standards.
For our project - a cohousing community proposed on three contiguous, legally
recognized substandard lots totaling 17 acres in the RR 1: 10 district - this amendment
is the foundational change that makes our development concept viable. Without it, the
PRRD framework would have remained inaccessible to us despite our lots being legally
established and our project goals being fully consistent with the intent of the PRRD
program: clustered, innovative housing design that preserves rural open space and
fosters community.
In addition, the insertion of the words "short or long subdivision" to subsection (1)
permits us to move forward, since we do not need a subdivision with our binding site
plan.
2. Increase of Maximum Bonus Density to 40% of the Allowed Limit (JCC
18.15.520)
The revision to JCC 18.15.520 - Modification of Permitted Densities - Density
Bonuses - increasing the maximum bonus density to 40% of the allowed limit is
equally important for projects like ours. In rural residential zoning districts such as RR
1: 10, base density yields are inherently limited by acreage. For smaller sites, the density
bonus is not merely an incentive - it is often the only mechanism by which a
meaningful cluster of housing can be achieved.
The increase to 40% reflects a realistic understanding of what is required to make
innovative rural housing viable. Our cohousing project, which includes a mix of existing
dwellings and proposed new duplexes, is designed specifically around the kinds of
public benefits the density bonus criteria are intended to reward: energy-efficient design,
clustered building footprints that minimize land disturbance, shared infrastructure,
preservation of open space, and a community governance model that promotes long-
term stewardship of the land.
We believe the updated 40% bonus threshold appropriately aligns incentive with
outcome. Projects that genuinely meet the bonus criteria - as evaluated by the hearing
examiner through a public process - should be able to achieve a density that makes
the project financially viable while remaining fully compatible with rural character. The
prior threshold did not reliably achieve this balance; the updated threshold does.
Conclusion
We commend the County for these amendments and encourage their adoption as
proposed. Taken together, the recognition of substandard lots under JCC 18.15.485
and the enhanced density bonus under JCC 18.15.520 create a more equitable, flexible,
and effective PRRD framework - one that is better aligned with Jefferson County's
housing goals and the realities of rural land ownership.
We look forward to participating in the public hearing process and to continuing our
work with county staff to bring this cohousing project forward in a manner that reflects
the values of both our community and Jefferson County.
Respectfully submitted,
Eva Holm, Jonathan Boughton, Denise Shephard, Anita Landino, and other members of
Newt Crossing Cohousing
www.newtcrossing.org
newt@olympus.net
360-301-2948
Joel Peterson
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2025 Comp Plan
Wednesday, May 13, 2026 11 :28 AM
Joel Peterson; Jeremy Williammee
FW: Comments from Cindy Jayne for Public Hearing
Comments on Jeff County Comp Plan Public Hearing Draft from CJayne.docx
Comp Plan Update
-Alex H
From: Cindy Jayne <cindyjaynept@gmail.com>
Sent: Wednesday, May 13, 2026 11:24
To: 2025 Comp Plan <2025compplan@co.jefferson.wa.us>
Subject: Comments from Cindy Jayne for Public Hearing
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Attached are comments from myself, and which also include some comments from the Climate Action Committee's
Food Systems Work group.
Thank you,
Cindy Jayne
Comments on Jefferson County Comprehensive Plan Public Hearing Draft from Cindy Jayne
Note: I am submitting this both as an individual, and also noting feedback that was from the Climate
Action Committee Food Systems group.
Policy CE-P-12.3 Increase housing diversity and supply within urban growth areas in places that
minimize harm to ecosystems, are at low risk for wildfire, 8-fand are outside of flood hazard areas.
Comments from CAC Food Systems work group, next 8 items (through CD-P-10.8):
Goal CE-G-10 Support sustainable local and regional food system practices, infrastructure, agricultural
workforce development,-aR4 policy and code that improve Jefferson County's resilience to climate
change impacts.
Policy CE-P-10.1 Increase local food security and support equitable food distribution and expansion of
the food-related economy to address climate impacts and increase access to healthy, affordable, and
climate-friendly foods.
Policy CE-P-10.2 Preserve land outside of urban growth areas for long-term agricultural use, recreation,
open spaces, forestry, mineral resources, and other uses consistent with rural character.
Policy CE-P-10.6 Consider a countywide food system security and resilience action plan, that prioritizes
sustainable agriculture and food systems practices and helps farmers and communities preserve food
for year-round access and use, while serving vulnerable populations. =>propose splitting it into:
Policy CE-P-10.6 Work toward Consider a countywide food system security and resilience action plan
that includes planning for emergencies.
Policy NEW: Prioritize sustainable agriculture and food systems practices and helps farmers and
communities preserve food for year-round access and use, while serving vulnerable populations,
through incentives, policies and updated code.
Policy CE-P-10.7 Support research, education and investments in climate adapted food system methods
and infrastructure suited to Jefferson County's soils, including collaborating collaboration wi#l-and
capacity building e.f.-with partners.
Policy CE-P-10.8 SeekConsider opportunities to reduce GHG emissions and increase carbon
sequestration in the agricultural sector.
Policy CE-P-15.8 Educate the public on wildfire smoke risks, vulnerable populations and measures to
reduce exposure. Comment: Not clear, are we educating public on vulnerable populations?
Policy CE-P-16.2 Design and site new and retrofit existing transportation infrastructure, including low-
lying roads, non-motorized trails, rail systems, and bridges vulnerable to coastal or inland flooding,
repetitive flooding and/or landslides, and sea level rise. Transportation infrastructure should ensure the
least possible adverse impacts on existing ecology and habitat restoration projects, limit impact on
public access (particularly for vulnerable and marginalized populations), and integrate future climate
projections into siting and design. [Comment: Not clear. Are you designing and siting outside of
vulnerable areas?]
Policy CE-P-18.2 Consider developing a countywide Climate Resilience Office to support the integration
of equity into climate change adaptation efforts, as well as !Q_promote, adaptation, mitigation and
planning for climate change across all county departments and with community partners including the
Climate Action Committee.
Comments on county action plan Exhibit 9-8:
- add to climate change outreach: "Partner with relevant stakeholders across the county to implement
the policies in this element. including the CAC Outreach group".
add to Support local economy: "Support the development of a county food system resilience plan by
collaborating with the CAC Food Systems group"
Joel Peterson
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Matt Sircely <mattsircely@gmail.com>
Wednesday, May 13, 2026 6:16 PM
2025 Comp Plan; Cynthia Koan; Joel Peterson
Vision Statement snafus
Screenshot 2026-05-13 at 5.55.37 PM.png; Screenshot 2026-05-13 at 5.54.09 PM.png
Comp Plan Update
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Hey Joel and everyone,
Glancing through the draft on laserfiche, I noticed these details just now.
Fort Worden is spelled wrong, and there are some clunky sentences in the attached segments.
Sometimes there aren't spaces after periods. Some sentences could be combined.
ut suddenly in 1911, Western Steel declared
bankruptcy, causing Irondale's collapse. After a brief period of operation
during World War I (1917-1919) to use up stockpiled raw materials, the
plant was dismantled. World War I was on the heels of this time,
starting in 1914.Jefferson County's geographical setting contributed to
strategic military installations on our shorelines and corresponding
economic development from World Wars I and II. The post-war
decommissioning of coastal defense systems at Forts Warden,
Townsend, and Flagler began a turn away from the military's
contribution to the economy; and the industrial facilities that
constructed them were largely gone.and the steel mill in Irondale
ceased operation in 1911. Western Mill and Lumber Co. had closed in
1907 when the bottom fell out of the lumber market. 1913 marked the
closure of the short-lived Alcohol Plant.
This seems like too long of a sentence - could be a good idea to give these ideas a little more
breathing room
While residents may be developing a new entrepreneurial idea,
just trying to get by and survive, or working to build a new future
together on the edge of this rural wilderness, they form a diverse
community with a distinctive and collective Jefferson County identity
forging a future together.
1
O Lf o
Joel Peterson
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Cynthia Koan <cynthia.koan@gmail.com>
Wednesday, May 13, 2026 8:10 PM
Matt Sircely
2025 Comp Plan; Joel Peterson
Re: Vision Statement snafus
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How about this:
"Residents of Jefferson County form a hard-working community of entrepreneurs, skilled artisans, tradespeople,
teachers, healthcare professionals, artists, maritime workers, service workers, nonprofit leaders, retirees, and
volunteers who contribute to the county's resilience and character."'
Thoughts?
Cynthia
Cynthia Koan
Computer Coach and Technician
Voice: 360-385-4234
Scheduling: www.schedulecynthia.com
On Wed, May 13, 2026 at 6:16 PM Matt Sircely <mattsircely@gmail.com> wrote:
Hey Joel and everyone,
Glancing through the draft on laserfiche, I noticed these details just now.
Fort Worden is spelled wrong, and there are some clunky sentences in the attached segments.
Sometimes there aren't spaces after periods. Some sentences could be combined.
ut suddenly in 1911, Western Steel declared
bankruptcy, causing Irondale's collapse. After a brief period of operation
during World War I (1917-1919) to use up stockpiled raw materials, the
plant was dismantled. World War I was on the heels of this time,
starting in 1914.Jefferson County's geographical setting contributed to
strategic military installations on our shorelines and corresponding
economic development from World Wars I and II. The post-war
decommissioning of coastal defense systems at Forts Warden,
Townsend, and Flagler began a turn away from the military's
contribution to the economy; and the industrial facilities that
constructed them were largely gone.and the steel mill in Irondale
ceased operation in 1911. Western Mill and Lumber Co. had closed in
1
1907 when the bottom fell out of the lumber market. 1913 marked the
closure of the short-lived Alcohol Plant.
This seems like too long of a sentence - could be a good idea to give these ideas a little more
breathing room
While residents may be developing a new entrepreneurial idea,
just trying to get by and survive, or working to build a new future
together on the edge of this rural wilderness, they form a diverse
community with a distinctive and collective Jefferson County identity
forging a future together.
2
Ot.f {
Joel Peterson
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To:
Cc:
Subject:
Attachments:
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DFW R6CSplanning < R6CSplanning@dfw.wa.gov>
Thursday, May 14, 2026 1 :36 PM
Joel Peterson; 2025 Comp Plan
Wourms, Lindsay (DFW); Bryant, Jessica (DFW); Spoon, Amy K (DFW); Robinson, William
(DFW); Samara, Adam (DFW); Henry, Carol A (DFW); Kohler, Kendall (DFW); Green, Brady
A (DFW); Storvick, Aleks E (DFW); Lentes, Gwendolen A (DFW); Whittaker, Kara A (DFW);
Berejikian, Marian (DFW); DFW R6CSplanning
WDFW Comment Letter for Jefferson County - 2025 Comprehensive Plan Update
2026.05.14_WDFW Letter For Jefferson County Comprehensive Plan 2026 Public Hearing
Version.pdf
Comp Plan Update
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Hi Joel,
Please see the attached WDFW comment letter on Jefferson County's 2025 Draft Comprehensive Plan update. We
respectfully request that these comments be considered and included in the public comment record for the update. For
your awareness, these comments have been added to Planview Submittal 2025-S-10974A.
If there are any questions or concerns regarding our comments, don't hesitate to reach out for clarity.
Thank you,
Jessica Bryant (she/her)
Regional Land Use Lead - Region 6
Washington Department of Fish and Wildlife
Jessica.Bryant@dfw.wa.gov
(564) 669-4755
1
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
May 14, 2026
Jefferson County
ATTN: Joel Peterson, Associate Planner, Department of Community Development
621 Sheridan Street
Port Townsend, WA 98368
Subject: WDFW Comments on the Jefferson County 2026 Draft Comprehensive Plan, Planview
Submittal 2025-S-10974A
Dear Joel Peterson,
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 for Jefferson County's 2026 Draft Comprehensive Plan version, 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.
Jefferson County Comprehensive Plan
Draft Policy Number and Language WDFW comment
(with WDFW suggestions in red)
Land Use Element - Goals and Policies
Policy LU-P-1.2: Establish future land use and WDFW suggests that the County consider including
zoning designations, densities, and intensities that a reference to the County's latest Hazard Mitigation
minimize and mitigate potential land use conflicts, Plan in this policy.
and displacement, and exposure to hazards.
Policy LU-PS.2: Site essential public facilities in an WDFW is supportive of this policy.
equitable manner with consideration for future
climate-related hazards and with appropriate
mitigation that balances local and regional
objectives.
Policy LU-P-6.3: Site transportation facilities in Land and habitat in Jefferson County provide critical
locations which minimize the disruption of natural habitat connectivity links for the state. The
habitat, floodplains, wetlands, geologically sensitive Washington Habitat Connectivitv Action Plan
areas, resource lands, and other priority systems. identifies a priority ecological connectivity zone in
Western Jefferson County on Highway 101 just
Page 2
north of the Hoh River, and two priority ecological
connectivity zones in eastern Jefferson County on
Highway 101. These connections should be
considered to align with WAC 365-190-130{3l{al(i).
Long-term Commercial Forestry, farmlands,
preserves, and other parklands contribute to
habitat connectivity and open space. Maintaining
~hese land uses provides multiple benefits including
habitat connectivity and preserving the rural
character of the county.
It is recommended to consider how to include
habitat connectivity into design plans where
possible. For examples of projects that can support
~he ecosystem by providing habitat connectivity
and movement corridors for both aquatic and
~errestrial wildlife, please reach out to WDFW and
review the resources provided below.
For resources for developing wildlife and open
space corridors, please see: Landscape Planning for
Washington's Wildlife: Managing for Biodiversitv in
Develooing Areas Land Use Planning for salmon,
steelhead and trout: A land use olanner's guide to
salmonid habitat orotection and recoverv
Washington Wildlife Habitat Connectivitv Working
Grouo. WDFW's Habitat at Home, and WDFW's
Habitat connectivity website.
Policy LU-P-7.6: Develop land use ordinances that WDFW is supportive of this policy. To support this
promote climate resiliency based on twork, WDFW recommends that the County take
comprehensive watershed and salmon recovery into consideration the resources provided by the
plans for the conservation, protection, and Agency's Priority Habitats and Species {PHS)
management of surface and ground waters, program. The PHS program is the Agency's primary
floodplains and estuaries, in order to maintain means of transferring fish and wildlife information
water quality and quantity, provide potable water, from our resource experts to local governments.
and to restore and protect fish habitat. The PHS program includes a list of management
recommendations for habitat and species.
Additionally, the County should consider reviewing
the resources provided in the Department of
Ecoloav's orotectina coastal communities
resources, and WDFW's climate change resources.
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
Page 3
Proiect Reoort 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.
Policy LU-P-7.7: Proactively steward natural WDFW is supportive of this policy. We encourage
systems and discourage development and land use local jurisdictions to use best available science
decisions that significantly adversely impact the (BAS), as defined in WAC 365-195-900, to pursue
natural environment and natural resources. efforts to create, maintain, and connect habitat
corridors where possible for wildlife to use to
prevent populations of species from isolation.
Wildlife corridors, which can be found on forest
lands, are important in promoting wildlife
movement and preventing habitat fragmentation.
When zoning amendments are proposed, WDFW
recommends adding that this review should be
conducted on a countywide basis to align with WAC
365-196-480 (2He). Ensuring that compatible zoning
classes are adjacent to each other prevents land use
conflicts.
Please see the resources provided in Policy LU-P-
6.3.
Policy LU-P-7.8: Manage built and natural WDFW supports this policy.
environments in the county for resiliency to reduce
Wildfire risk and impacts of climate change, such as
increased flooding, extreme heat, and droughts. to
infrastructure, the economy, natural resources. and
human health. Lead regional climate change and
greenhouse gas emission reduction efforts.
Policy LU-P-9.1: Periodically review and, if WDFW supports this policy. For assessing future
necessary, update the Jefferson County Flood climate-related conditions, WDFW recommends
Damage Prevention Ordinance to reflect such reviewing the Climate Mai::1i::1ing for a Resilient
things as climate change, and changes in federal, Washington.
state and local legislation, and hazard mitigation
planning.
Policy LU-P-9.4: Adopt land use policies and best Protecting and maintaining connected floodplains
management practices that increase the ability of and riparian systems can assist with safeguarding
natural systems, such as healthy, connected the built environment by providing benefits such as
floodplains and riparian systems, to respond to water storage, flood mitigation, and drought
droughts, changes in streamflow, and flooding. resilience. Utility infrastructure planning should
incorporate the benefits of these ecosystem
Page 4
services to enhance natural environmental
processes and long-term sustainability reducing
risk. Natural water infiltration and attenuation
processes help retain, cool, and filter water which
benefit salmonids and other species. Protecting and
restoring natural assets can be more cost-effective
than engineered solutions.
See WDFW's Landscage Planning for Washington's
Wildlife which outlines that all landscapes, from
the urban to forested areas, can contribute to
maintaining ecological health that benefits people
and wildlife.
As a resource, WDFW recommends that the City
consider evaluating the Department of Commerce's
Menu of Measures specifically item #83, when
implementing this policy.
Policy LU-P-9.5: Strengthen development ~s a resource, WDFW recommends that the City
regulations that promote compatible uses and consider evaluating the Department of Commerce's
protection of health and safety in critical areas Menu of Measures specifically items #99 and #196,
more prone to risks of extreme precipitation and when implementing this policy.
~looding.
Policy LU-P-11.3: Preserve the environmental WDFW supports this policy because it aligns with
functions of surface and ground water resources by our land-use glanning griorities and highlights the
retaining native vegetation and open spaces where use of low-impact development techniques as
Weasible and by requiring mitigation measures, mitigation measures for land-use activities.
including low impact development techniques, for
land use activities that may adversely impact
surface and ground water.
Policy LU-P-12.1: Take an active role in WDFW appreciates the inclusion of this policy, as it
implementing watershed plans for Water Resource demonstrates the County's commitment to
Inventory Area (WRIA) 16, 17, aRa 20 and 21, as watershed-scale planning and salmon recovery.
fundlng allows. Recognizing and integrating WRIA-based goals is an
important step toward protecting and restoring
habitat for salmon ids. However, WDFW
recommends that WRIA 21 be added to this list
since the County's Southwest section is included in
his WRIA.
Policy LU-P-13.2: Allow existing legal commercial WDFW recommends the County clearly state that
and industrial uses that became nonconforming these legally non-conforming infrastructures must
prior to the county's adoption of zoning regulations comply with GMA requirements of no net loss of
Page 5
in 1989 or prior to subsequent zoning changes or critical areas functions and values as outlined in
development regulations to expand or be replaced WAC 365-190-080 and WAC 365-196-830 when
in Rural Residential areas provided that they do not expansions or replacements would occur.
require additional urban levels of government
service and they do not impose uncompensated
additional costs to the taxpayers of Jefferson
County for the provision of infrastructure, its
replacement or improvement. Allow expansion or
replacement, provided they do not conflict with
natural resource industries or surrounding rural
uses and results in no further adverse
environmental impacts, including no net loss of
critical areas functions and values, or neighborhood
impacts, unless mitigated.
Policy LU-P-13.5: Allow and encourage a legal WDFW suggests adding "encourage" to this policy
existing nonconforming use to change to a for added support for non-conforming buildings to
conforming use allowed within the zone become conforming to current zoning
classification in which the use is located. requirements.
Rural - Goals and Policies
Policy LU-P-15.3: Locate designated open space WDFW supports this policy and recommends that
areas so as to provide connections with adjoining the County designate open spaces as a map overlay
open space areas, offer visual relief for both on and for the comprehensive zoning for the County. This
off-site residents, enhance habitat values, and, mapping overlay would show how the County is
Mthere appropriate, allow for recreational meeting the open space requirements outlined in
opportunities. WAC 365-196-335. The public benefits of
integrating open space and corridor planning
include increased opportunity for positive human-
wildlife interactions, better management of
stormwater, and more certainty for developers and
landowners about where habitats will be
designated as protected over the long term.
We recommend jurisdictions work with local
communities alongside intergovernmental and local
partners to ensure that local corridors connect to
regional corridors to support habitat connectivity
across jurisdictional boundaries.
For resources for developing wildlife and open
space corridors, please see: Landscape Planning for
Washington's Wildlife: Managing for Biodiversitv in
Develooina Areas Land Use Planning for salmon,
steelhead and trout: A land use olanner's guide to
salmonid habitat orotection and recoverv
Page 6
Washineton Wildlife Habitat Connectivitv Workina
Grouo. Washineton Habitat Connectivitv Action
e!ill1. WDFW's Habitat at Home, and WDFW's
Habitat connectivity website.
Policy LU-P-15.4: Establish visual corridors and WDW supports this policy and recommends that
orest corridors along suitable roadways in ~he County use the comments captured Policy LU-
Jefferson County. Encourage the extension of the P-15.3 as further recommendations and resources.
forest corridor concept from Port Townsend's City
limits south along SR 20 to Old Fort Townsend Road
o preserve and protect the forest corridor, and to
provide a visual buffer between the roadway and
new commercial and manufacturing development.
Policy LU-P-18.1: Encourage rural residential cluster WDFW supports the County finding ways to
subdivisions throughout the rural areas and ensure implement cluster development and requiring open
~he open space tracts in these planned rural space preservation. Maintaining low-density rural
residential development subdivisions are zones adjacent to open space lands is important for
permanently preserved. habitat protection and for reducing land use
conflicts, such as incompatible adjacent land uses.
~dditionally, WDFW recommends against upzoning
rural lands thereby ensuring growth is located
within an urban area to align with RCW 36.70a.110.
WDFW recommends that Policy LU-P17.1 be
updated to be similar to this policy.
Policy LU-P-18.3: Preserve and connect open space WDFW supports this policy. Similar to Policy LU-P-
corridors to provide for the aesthetic needs of the 6.3 and Policy LU-P-7.7, above, we do recommend
community, to protect critical areas including flood including "and connect" into this policy to support
prone lands, and to conserve fish and wildlife he intent of this policy.
habitat. Prioritize preserving open space corridors
in areas with vulnerable populations. Please see the resources provided in Policy LU-P-
6.3.
Policy LU-P-21.6: Explore opportunities for new When these opportunities occur, WDFW
appropriately sized Rural Village Centers. recommends the County visit the Agency's PHS for
the most recent maps to see how these centers
may interact with priority habitat and species
locations. Additionally, we recommend that the
County visit the Washington Habitat Connectivity
Action Plan website to see if any identified
connectivity would be affected by a new rural
village center. WDFW's Land-use planning priorities
and resources is another location to find a wide
array of information, ranging from best available
science guidance to enhancing habitat and wildlife
connectivity.
Page 7
Policy LU-P-23.3: Discourage any new urban or WDFW supports this policy.
suburban land uses within the immediate vicinity of
MP Rs outside of the designated MPR boundaries.
Urban Growth Areas - Goals and Policies
Policy LU-P-34.10: Minimize adverse stormwater WDFW suggests clarifying that both new and
impacts due to climate change and preserve aquifer retrofit projects should be developed following the
recharge by encouraging Low Impact Development ~reen infrastructure and low impact development
design strategies for both new and retrofit projects. (LID) standards. These types of projects can have
cumulative impacts across the County to improve
the urban environment while reducing impacts to
the natural environment. Please see the
Department of Commerce's Clean Building
Performance Standards and the Sustainable
Development Code website for removing code
barriers, creating incentives, and filling regulatory
gaps to support the pursuit of this policy. Please
also see the Department of Ecology's LID guidance.
For examples on how other jurisdictions are
pursuing green development efforts, please see the
City of Shoreline's Dee12 Green Incentive Program,
and the City of lssaquah's and the City of Bellevue's
clean building incentive programs.
Policy LU-P-36.1: Tie non-motorized transportation As mentioned in previous comments, WDFW is
planning to urban open space planning and supportive of the County identifying and protecting
consider connectivity of urban/rural greenways. open spaces and corridors.
Identify open space lands and corridors and urban
separators within urban growth areas, including
lands useful for recreation, wildlife habitat, trails,
and connection of critical areas per RCW
36.70A.160.
Draft Policy Number and Language WDFW comment
(with WDFW suggestions in red)
Natural Resources Element - Goals and Policies
Goal NR-G-1: Encourage the conservation and long- WDFW is supportive of this goal. WDFW specifically
term sustainable use of resource lands so their encourages the County to retain and protect
continued future use will not be precluded by other designated commercial forest lands from being
uses; and encourage the long-term sustainability of rezoned to a different land use type such as rural
natural resource-based economic activities residential. These areas can act as wildlife habitat
throughout Jefferson County. and corridors with a multitude of benefits for the
local ecosystem. We encourage local jurisdictions to
Page 8
use BAS to pursue efforts to create, maintain, and
connect habitat corridors where possible for
wildlife to use to prevent populations of species
from isolation.
For resources for developing wildlife and open
space corridors, please see WDFW comments for
Policy LU-P-6.3 and Policy LU-P-15.3.
Goal NR-G-2: Encourage resource-based economic WDFW supports this goal because it highlights that
activities, including markets for ecosystem services, ecosystem services play a vital role in the local
~hat are compatible with environmental quality. economy while being key in the local environment.
Goal NR-G-3: Conserve and protect Forest Resource WDFW is supportive of the County's goal. To
Lands for long-term economic use and support this goal, we suggest that the County
environmental and health benefits. consider reviewing and incorporating example
recommendations and policies from the
Department of Commerce's Menu of Measures to
support the long-term forest land ecosystems,
while identifying opportunities and expanding
incentives for forest landowners.
One specific example is number 90 from the Menu
of Measures that states, "Adopt a forest master
plan and implementing ordinances to maintain and
expand tree canopy cover, improve tree and
watershed health, prioritize carbon sequestration,
and build climate resilience.". We recommend
reviewing this example because it places an
emphasis on prioritizing retention of healthy trees
and tree canopy, working at a landscape-level
management level, and balancing the ecological
and economic impact tradeoffs these areas may
have.
Draft Policy Number and Language WDFW comment
(with WDFW suggestions in red)
O~en S~ace, Parks & Recreation, Historical & Cultural Preservation Element - Goals and Policies
Policy 0S-P-1.2 Establish, aRa conserve, and WDFW suggests including a statement about local
regionally connect a sustainable system of open and regional habitat connectivity policy. These
space corridors or separators to provide definition connections support open space requirements
between natural areas and urban land uses. outlined in WAC 365-196-335, while supporting the
protection of their functions and values of critical
Page 9
areas on a larger scale as discussed in WAC 365-
196-830(6).
Policy OS-P-1.4: Identify and conserve critical WDFW is supportive of this policy because it aligns
wildlife habitat, including nesting sites, foraging with our mission statement. Should the county
areas, and migration corridors within or adjacent to want to collaborate on this effort, please reach out
natural areas, open spaces, and developed urban to the WDFW local area habitat biologist.
areas. Preserve especially sensitive habitat sites
that support threatened species and wildlife habitat
in developed areas.
Policy OS-P-3.2: Review development proposals to WDFW recommends reviewing the Integrating
evaluate opportunities for multiple use of proposed Wildlife Habitat Connectivitv Into Local Government
open space. The open space should be of a quality, Planninz guidance for this County policy. This
quantity, and configuration which ensures that a guidance recommends clear development
suitable portion of the site is designated for standards in multiple use areas and provides
conservation, food plants and trees, passive information on zoning densities, open space
recreation, and, where appropriate, active connectivity, wildlife connectivity and example
recreation. plans and policies to consider.
Please also see our comments for Policy LU-P-6.3
regarding the Washington Habitat Connectivity
~ction Plan and additional resources to consider.
Draft Policy Number and Language WDFW comment
(with WDFW suggestions in red)
Climate Element - Goals and Policies
Goal CE-G-6: Ensure the protection of and support WDFW suggests expanding this goal to cover the
the recovery of ecosystems functions and values to functions and values of ecosystems to align with the
provide functioning habitats in a changing climate. Growth Management Act, WAC 362-196-830. To
support this work, WDFW recommends that the
County consider exploring and utilizing the
resources provided in our comments for Policy LU-
P-7.6 above.
Goal CE-G-7: Improve the health and resilience of WDFW supports this effort. The BAS emphasizes
the county's streams and rivers, including efforts to ~he importance of protecting all streams and their
mitigate climate change impacts such as flooding adjacent riparian areas to support full riparian
and drought. ecosystem functions and values. These critical areas
support the full ecosystem while providing
movement corridors for both aquatic and terrestrial
wildlife. WDFW recommends that jurisdictions
consider following the updates from Ecology's
WASHD program regarding the effort to create and
Page 10
sustain a complete statewide hydrography dataset.
This WASHD effort aims to update watercourse
mapping to help ensure all state streams and
associated riparian management zone (RMZ)
natural resources are accurately identified.
WDFW currently recommends using SPTH200 GIS
mannlnz tool to delineate where riparian
management zones (RMZ) are located.
Policy CE-P-7.2: Protect and restore streams, WDFW supports this policy. See WDFW's climate-
riparian zones, estuaries, wetlands, shorelines, change-resilient culvert webpage and Incorporating
floodplains and their ecological functions to achieve Climate Change into the Design of Water Crossing
healthy watersheds, ecosystems, and habitats that Structures: Final Proiect Reoort (2017) for resources
are resilient to climate change. on how to incorporate climate-resiliency into
culvert design and avoid future flooding.
Policy CE-P-15.1: Continue to develop long-term, WDFW supports this effort. Protecting connected
comprehensive flood hazard management plans in floodplains and riparian systems can protect the
cooperation with other applicable agencies and built environment by providing ecosystem service
persons that consider the potential climate change benefits such as water control, flood prevention,
impacts using projected flooding and sea-level rise and drought resistance. Utility infrastructure should
assessments. Plans should seek to minimize the incorporate ecosystem services provided by natural
likelihood of flood damage, maintain the natural environmental processes. Natural water infiltration
hydraulic capacity of streams and floodplains, and attenuation processes help retain, cool, and
protect human health and well-being, and conserve filter water which benefits, people, salmon ids, and
or restore valuable, limited resources such as fish other species. Protecting and restoring natural
habitat and floodplain connectivity water, soil, and assets can be more cost-effective compared to
recreation and scenic areas. engineered solutions.
Please see FEMA's guide Building Community
Resilience with Nature-based Solutions as well as
supporting Kitsap County's approach to quantifying
ecosystem services through the Kitsap Natural
Resources Asset Management Proiect.
Additionally, we suggest utilizing the Sound Choices Checklist in further review of all Comprehensive
Plan elements. This checklist utilizes broad priorities to help local jurisdictions protect and recover the
Puget Sound.
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
Page 11
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 G'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)
Kendall Kohler, Area Habitat Biologist (Kendall.Kohler@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)
Joel Peterson
From:
Sent:
To:
Cc:
Subject:
Attachments:
Categories:
Jeremy Williammee
Thursday, May 14, 2026 2:04 PM
Joel Peterson; Mo-chi Lindblad; Greg Ballard; Philip Hunsucker
2025 Comp Plan
FW: WSDOT Comment re Jefferson County Final Draft Comprehensive Plan
WSDOT _Commentletter_Jefferson_CompPlan_2026-05-12_FINAL.pdf
Comp Plan Update
FYI
From: Rinehart, Benjamin <benjamin.rinehart@wsdot.wa.gov>
Sent: Thursday, May 14, 2026 1:54 PM
To: Jeremy Williammee <JWilliammee@co.jefferson.wa.us>
Cc: Engelbrecht, Joshua (COM) <joshua.engelbrecht@commerce.wa.gov>; Parson, Amna <amnap@kitsaptransit.com>;
Clemens, Ryan <ryan.clemens@wsdot.wa.gov>; Mazur, George <george.mazur@wsdot.wa.gov>
Subject: WSDOT Comment re Jefferson County Final Draft Comprehensive Plan
ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are
not expecting them.
Hello Mr. Williammee.
Attached you will find WSDOT's official comment letter regarding Jefferson County's Final Draft Comprehensive Plan.
Please reach out if you have any questions or follow ups. Thank you for the opportunity to comment.
Best,
Benji
Benjamin Rinehart (he/him)
Multimodal Planner Ill (GMA)
WSDOT Olympic Region, Multimodal Planning
Benjamin.Rinehart@WSDOT.wa.gov
(360)-357-2664
Washington State
Department of Transportation
Olympic Region
7407 31st Ave NE, Lacey
P.O. Box 47440
Olympia, WA 98504-7440
360-357-2600 I Fax 360-357-2601
TTY: 1-800-833-6388
www.wsdot.wa.gov
May 14, 2026
Jeremy Willammee, Director
Jefferson County Department of Community Development
621 Sheridan Street Port Townsend, WA 98368
Dear Jeremy Williammee,
The Washington State Department of Transportation (WSDOT) appreciates the opportunity to
review and comment on the Jefferson County's 2025 Comprehensive Plan Update (Plan).
WSDOT has an interest in the Plan based on its transportation subject matter expert status and
statutory authority to plan, locate, design, construct, improve, repair, operate, and maintain the
state highway system (RCW 47.01.260(1)).
The Plan contains extensive discussion and policy language supporting responsible growth,
multi modal access, and active transportation. The plan also contains detailed analysis of the
impacts from planned growth on the local, regional, and state transportation system. The analysis
planned growth contributing to failing levels of service at four state highway intersections:
• SR-19 and Chimacum Rd
• SR-19 and SR 116 (Ness Corner Rd)
• SR-19 and Irondale Rd
• SR-19 and Prospect Ave
RCW 36.70A.070(6)(a) states that the Plan should provide "specific actions and requirements for
bringing into compliance transportation facilities or services that are below an established
multi modal level of service standard." These actions might include alternative land use
decisions, transportation demand strategies, targeted local road improvements, and if necessary,
state highway capital improvements. We did not identify any such proposed actions in the Plan.
As such, WSDOT does not view the Plan as sufficiently satisfying the environmental analysis
requirements for SEPA Categorical Exemptions on housing streamlining (RCW
43.2 l C.229(3)(b)) or any other situation in which WSDOT has statutory review or approval
authority. In such future situations, WSDOT will request detailed review of jurisdiction-wide
cumulative impacts from all long-term planned growth during each individual project's
development review phase.
Please contact us (orplanview@wsdot.wa.gov) if you need assistance or have questions. WSDOT
looks forward to continuing our coordination and partnership,
Sincerely,
George Mazur, P.E.
WSDOT Olympic Region Multimodal Planning Manager
cc: Joshua Engelbrecht, Washington State Department of Commerce
Amna Parson, Peninsula Regional Transportation Planning Organization
Ryan Clemens, WSDOT Tribal and Regional Integrated Planning
Joel Peterson
From:
Sent:
To:
Cc:
Subject:
Attachments:
Follow Up Flag:
Flag Status:
Categories:
Jeremy Williammee
Thursday, May 14, 2026 2:33 PM
Joel Peterson; 2025 Comp Plan
Mo-chi Lindblad; Greg Ballard
LAMIRDs and Public Sewer
Appendix 2 (2021) v 2025 PH Draft.pdf; .Pages from 01 0426 21 Adopting 4 Comp Plan
Amends.pdf; 05 14 2026 Comp Plan LAMIRD Housekeeping .docx
Follow up
Flagged
Comp Plan Update
Hi Joel,
As discussed earlier, I am including background information related to Ordinance 01-0426-21 that included
text amendments to the Comp Plan and JCC Title 18 intended to support sewer in the Brinnon LAMIRD (and
potentially relevant for other areas}.
The revised Policy CF-P-6.3 under Capital Facilities & Utilities, and some edits to the Rural Economy paragraph
in the Land Use Element, do not appear to be incorporated into the current 2025 public hearing draft. The
2021 amendments to JCC 18.30.040 were incorporated and are reflected in the current on line version of our
code.
I am attaching the relevant language from the Public Hearing drafts of Land Use (pg. 1-88} and Capital Facilities
(pg. 8-31} in a Word document with changes tracked for ease of review and correction.
I also included one new additional line to Policy CF-P-6.3 to accommodate the additional flexibilities from HB
2269 passed this year.
We might also want to do one last check to make sure there weren't any other lingering annual amendments
between 2019 and 2024 that might impact the updated Comp Plan language.
Thanks!
Jeremy
Jeremy Williammee
Director I Department of Community Development
Jefferson County I 621 Sheridan Street I Port Townsend, WA 98368
Phone: 360-379-4488 I Email: jwilliammee@co.iefferson.wa.us
1
Appendix 2 - Ordinance 01-0426-21
Capital Facilities & Utilities
Policy CF-P-6. 3 Ne~t wPban pwb,1,iE &@P¥iGes sanitary sewer
systems will only be provided within a UGA and !:!!.ll._not be
extended beyond a UGA unless~
-It is a necessary response to protect basic public
health. safety, and the environment; the sewer, extension,
or connection 1s financially supportable at rural
densities; and tile sewer, connection, or extension does
not permit urban development;
-It is necessary to support a L mited Area of More
Intensive Rural Development (LA~IRO) consistent with the
County-wide Planning Policies;
•lt is necessary to provide service to an essential public
facility if no practicable alternative exists to site the
essential public facility in an Urban Growth Area; or.
·It supports a rural school serving both rural and urban
student populations, consistent with state law.
fleuell ta tie ;rn esse11tial pwbJ.h sep~•i,e to 111;1.U,gate a tl1Peat
te 11wlllie lieal~, safety, 8F geAePal 11eHare.
Existing sanitary sewer treatment facility capacity will not
be used as a justification for expansion of a sewer system or
development inconsistent with County•wide Planning Policies
and the Comprehensive Plan.
Land Use - Rural Economy
GMA allows sanitary sewer Infrastructure In rural areas when: (11 it II abates"" public
health and environmental problem, does not induce ~lifttl .\!!ll!!l development, and
is affordable by the community that it serves· (21 it is necessary to support a LAl'vllRD
and it is consistent wlth the County-wide Plano Ing Policies: or (3) supports a school
los;ated in the rural area servlog both rural od urban students.
Jefferson Coun is investi atin sewerin the Brinnon LAMIRD usin the existin
Dosewalllps State Park sewer system. The Dosewallips State Park ~wer treatment plant
Is located In the 8rinnon LAMIRO and its llnesrun through the LAMIRO to the
Oosewalllps State Park. Sew"lng 8rinnon would alleviate known and potential
environmental problems associated with on•site sewage systems. considering that the
Brinn on LAMIRD is located within the 100.yearfloodzone and is adjacent to the Hood
Canal.
+Ile a11111ieali91'1 ef IRis allewaRE@ j5 B@iRII iR\1@5ti11alee IR the 8fiAR81\ AwFal Viliiljje
Gente,, ilJBjaeeRt to Qou ... alli11s Hate 11aFh's t1saste•uate, lreatmenl facilil•t• TR@ GowAt>,·
Is warl,ing lo a~Elrus reqwlm~eAts el GMP, while allawlAg llmllerJ ser,;lee ll·t lhe
Elese¼allips Stale park's S\<Slem. CwrnAIIY, 8FlflA8A Is seA•eEI @Alirely 8\1 sepli£ S'fSl@fflS.
+l>ese sepliE s•1stef'AS AS"@ EIIFF@At aml peteAlial p,eblems a11d so Me s~"~ems are
~UltAA&edliA@a
In a 2002 amendment to the GMA, the Washington State Legislature found that GMA is
intended to recognize the importance of rural lands and rural character to Washington's
economy, and find that rural lands and rural-based economies enhance the economic
desirability of the State of Washington. To retain and enhance the Job base in rural
areas, rural counties must have flexibility to create opportunities for business
development and to retain existing businesses and allow them to expand. The
legislature's findings close with:
Draft 2025 Comp Plan Public Hearing Draft
Capital Facilities & Utilities
Polley CF-P-6.3 New urban public services will only be provided within
a UGA and not be extended beyond the current boundary of a UGA
unless deemed to be an essential public service to mitigate a threat to
public health, safety, or general welfare.
Land Use - Rural Economy
Per WAC 36$-196 425(4)/b), the GMA allows sanitary sewer
infrastructure in rural areas if it is necessary to protect basic public
health and safety and the environment, does not induce sprawling
development, and is affordable by the community that it serves. The
application of this allowance is being investigated in the Brinnon Rural
Village Center, adjacent to Dosewallips State park's wastewater
treatment facility. The county is working to address requirements of the
GMA. while allowing limited service by the Dosewallips State park's
system. Currently, Brinnon is served entirely by on-site sewer systems.
These on-site sewer systems have current and potential problems, and
some systems are located within flood zones. Other infrastructure
improvements consistent with rural levels of service, such as
improvements to fire flow, could support additional development, but
improvements to existing commercial development and housing stock
are unlikely to occur if the necessary infrastructure upgrades cannot
take place.
In a 2002 amendment to the GMA. the Washington State Legislature
found that the GMA is intended to recognize the importance of rural
lands and rural character to Washington's economy and find that rural
lands and rural-based economies enhance the economic desirability of
the State of Washington. To retain and enhance the job base in rural
areas, rural counties must have flexibility to create opportunities for
business development and to retain existing businesses and allow
them to expand. The legislature's findings close with:
Appendix 2
MLA20-00116- Draft Proposed Text Amendments to Support
Sewering the Brinnon Limited Area of More intensive Rural
Developn1ent
CAPITAL FACILITIES & UTILITIES
0 Policy CF-P-5. 7 Work with purveyors to promote the use
of unaffected upland water sources and other alternative
supplies, where appropriate, to supply new and existing
development in affected areas.
a Policy CF-P-5. 8 Support implementation of conservation
strategies that reduce average annual and peak day water use
for public and individual water systems.
0 Policy CF-P-5. 9 Recognize the authority of Public
Utility District #1 pursuant to Title 54 RCW and other
applicable statutes. The County will cooperate with Public
Utility District #1 to develop final development regulations
consistent with that authority.
Sewer & Wastewater
Goal CF-G-6 Promote sanitary sewer systems that
accommodate growth, are cost-effective to
construct and operate, and are consistent with
the Comprehensive Plan.
0 Policy CF-P-6 .1 Plan sanitary sewer system sizing,
phasing, development, and expansion within urban growth areas
to accommodate the allocated population and planned urban
development to the greatest extent possible within the
current planning period; while also planning implementation
phases that provide service at the greatest cost-
effectiveness.
Q Policy CF-P-6. 2 Encourage development of community
septic systems in Rural Centers to protect public health, the
environment, and foster a reliable, integrated collection
system. In areas with water quality concerns that are or
appear to be related to problems associated with individual
septic systems, Jefferson County supports utilizing a range
of sewage treatment options, including community drainfields
and centralized systems, subject to State law.
Ci Policy CF-P-6. 3 New blrban J,lblbliE serviEe5 sanitary sewer
systems will only be provided within a UGA and will not be
extended beyond a UGA unless~
-It is a necessary response to protect basic public
health, safety, and the environment; the sewer, extension,
or connection is financially supportable at rural
densities; and the sewer, connection, or extension does
not permit urban development;
Jefferson County Comprehensive Plan
January 2021
8-30
CAPITAL FACILITIES & UTILITIES
-It is necessary to support a Limited Area of More
Intensive Rural Development (LAMIRD) consistent with the
County-wide Planning Policies;
-It is necessary to provide service to an essential public
facility if no practicable alternative exists to site the
essential public facility in an Urban Growth Area; or,
-It supports a rural school serving both rural and urban
student populations, consistent with state law.
~eeme~ te be aA esseAtial ~~blic service te mitigate a threat
te ~~blic health, safet¥, er geAeral ~1elfare.
Existing sanitary sewer treatment facility capacity will not
be used as a justification for expansion of a sewer system or
development inconsistent with County-wide Planning Policies
and the Comprehensive Plan.
Ci Policy CF-P-6.4 Encourage the use of water-conserving
fixtures with new systems or services.
Ci Policy CF-P-6. 5 Consider the full range of actions that
will enable urban development to occur in a UGA, including
urban development initially on Large Onsite Septic Systems to
accommodate growth, affordable housing, economic development,
and environmental protection in advance of an operational
sanitary sewer system.
Jefferson County Comprehensive Plan
January 2021
8-31
LAND USE
Since GMA's inception, the State of Washington Growth Management Hearings Board
(Hearings Board) has interpreted the GMA and its rules to local jurisdictions'
comprehensive plans. Over the years, a body of law has developed, which appears to
force counties to curtail innovation in rural area development, such as prescriptively
establishing rural and urban densities and requiring tightlined LOBs in LAMIRDs. This
imposes a difficult challenge when trying to meet affordable housing needs outside of
designated urban growth areas. Some LAMIRDs, such as Chimacum, do not fit neatly
within this urban rural dichotomy. This provides only two boxes, urban or rural for
solutions to complex land use issues. Solutions may require more in-between areas to
meet requirements, such as a greater focus on performance standards for some housing
developments over a prescriptive residential density.
Innovations to meet current housing crises is limited by GMA. If a county allows bonus
densities in a rural cluster the resulting density after applying the bonus must be a rural
density, which doesn't yield enough bonus density to enable the types of housing
developments that can meet the challenges of providing density for affordable housing,
even within a rural context. Jefferson County proposes to investigate provisions for
planned residential developments and investigate the feasibility of alternative
performance standards that could potentially increase rural residential density above
the current maximum rural density. Jefferson County is aware that these options require
a legislative amendment to the GMA.
Rural Economy
Jefferson County's rural economy has responded to economic conditions and market
forces pivoting towards tourism, agricultural businesses, and small businesses. Our
economy is similar to other rural economies, transitioning away from natural resource
industries. Our rural economy needs infrastructure to support its economic activities
and changes in modern infrastructure, such as the ability to scale wastewater
management solutions to meet small community needs is evolving.
Even though developments in infrastructure, such as small and innovative sanitary
sewer systems may be able to support the overarching planning goals of GMA, while
containing and controlling growth in rural areas, GMA generally precludes small and
innovative sanitary sewer systems in rural areas as they are defined as urban levels of
service. This ignores potential opportunities to provide modern, scaled treatment
facilities to support a variety of community needs such as housing and economic
development. Jefferson County is aware these rural infrastructure systems would
require a legislative amendment to the GMA.
Jefferson County
GMA allows sanitary sewer infrastructure in rural areas when: ( 1) it# abates al'¼ public
health and environmental problem, does not induce SJlrawliAg urban development, and
is affordable by the community that it serves; (2) it is necessary to support a LAMIRD
and it is consistent with the County-wide Planning Policies; or (3) supports a school
located in the rural area serving both rural and urban students.
Jefferson County is investigating sewering the Brin non LAMIRD, using the existing
Dosewallips State Park sewer system. The Dosewallips State Park sewer treatment plant
Jefferson County Comprehensive Plan
January 2021
1-79
LAND USE
is located in the Brinnon LAMIRD and its lines run through the LAMIRD to the
Dosewallips State Park. Sewering Brinnon would alleviate known and potential
environmental problems associated with on-site sewage systems, considering that the
Brin non LAMIRD is located within the 100-year floodzone and is adjacent to the Hood
Canal.
The apfillieatian af this allawanee is eeing in\•estigatea in the Brinnan Rural Village
Center, aajaeent ta 9asewallifils State filarl1's wastewater treatment faeility. The Caunty
is warl1ing te aaaress reeiuirements af GM.O., while allewing limites serYiee ey the
9esewallifils State filark's s1(stem. Currently, Brinnen is serves entirely ey sefiltie systems.
These septie systems haYe eurrent ans petential praelerns ans seme systems are
leeates within flees 2enes.
In a 2002 amendment to the GMA, the Washington State Legislature found that GMA is
intended to recognize the importance of rural lands and rural character to Washington's
economy, and find that rural lands and rural-based economies enhance the economic
desirability of the State of Washington. To retain and enhance the job base in rural
areas, rural counties must have flexibility to create opportunities for business
development and to retain existing businesses and allow them to expand. The
legislature's findings close with:
"[Tlhe legislature finds that in defining its rural element under RCW
36. l0A.070(5), a county should foster land use patterns and develop a local
vision of rural character that will: [h]elp preserve rural-based economies and
traditional rural lifestyles; encourage the economic prosperity of rural
residents; foster opportunities for small-scale, rural-based employment and
self-employment; permit the operation of rural-based agricultural,
commercial, recreational, and tourist businesses that are consistent with
existing and planned land use patterns; be compatible with the use of the land
by wildlife and for fish and wildlife habitat; foster the private stewardship of
the land and preservation of open space; and enhance the rural sense of
community and quality of life."
In summary, as Jefferson County reviews rural commercial areas, we explore ways to
meet GMA's fundamental purposes in flexible and meaningful manners. For example,
flexibility in designating LAMIRDs, while meeting the purpose and intent of GMA would
assist the County with contained and controlled development, enhanced rural
economies, additional housing, preservation of natural resources, enhanced open space
and parks, and enhanced rural character. The legislative findings for GMA include the
conservation and wise use of our lands, along with sharing economic development with
communities experiencing insufficient economic growth. GMA should not be a barrier
for rural counties, but a platform to encourage sustainable, coordinated, and controlled
growth and economic development in accordance with the public's interest.
Jefferson County Comprehensive Plan
January 2021
1-80
Jefferson County Code
DRAFT JAN 26, 2021 VI
Page 1/2
18.30.040 Sewage disposal.
(I) All development shall be provided with an individual, on-site septic system and drainfield approved by Jefferson
County public health in compliance with Chapter 8.15 JCC. unless Jefferson County public health determines that
public sewer is available which would then require connection to the approved public sewer.
(2) Design and constrnction standards for on-site sewage disposal shall conform to the requirements of Jefferson
County public health or the agency having regulatory responsibility for the system. [Ord. 14-18 § 4 (Exh. B); Ord. 8-
06 § l]
(3) Large on-site sewage systems (LOSS) and conununity drainfields are not considered a sanitary sewer svstem as
applied under the Growth Management Act. Jefferson County considers these systems a mral govennnental service.
( 4) New construction of a sanitarv sewer system, extension, or connection to a sanitary sewer system located outside
of an urban growth area mav only occur if:
(a) The new sanitacy sewer system. extension, or connection is a necessary response to protect basic public
health, safety. and the enviromnent: the sewer is financially supportable at mral densities: and. the sewer.
extension, or connection does not permit urban development;
(b) The new sanitary sewer system, extension, or co1mcction is necessary to support a Limited Arca of
More Intensive Rural Development (LAMlRD): the sewer is needed to mitigate a threat to the public
health, welfare, or to protect an area of environmental sensitivity caused by existing development: and the
sewer is limited to those properties or facilities needed to mitigate the threat to the public health. welfare. or
to protect an area of enviromnenlal sensitivity;
(c) The new sanitacy sewer svstcm, extension, or connection is neccssarv to provide service to an essential
public facility if no practicable alternative exists lo site the essential public facility in an Urban Gmwth
Arca; or.
(d) The new sanitary sewer system. extension, or connection suppo11s schools sited in a mral area that serve
students from a rural area and an urban area. when consistent with the Jefferson County Comprehensive
Plan, RCW 36.70A.213, and the following requirements:
(i) The applicable school district has adopted a policy addressing the school service area. facilitv
needs, and educational program requirements:
(ii) The applicable school district has made a finding. with the concurrence of the county
legislative authority and the legislative authorities of any affected cities. that the proposed site is
suitable to site the school and any associated recreational facilities that the applicable district has
determined cannot reasonably be collocated on an existing school site, taking into consideration
the extent to which vacant or developable land within an urban growth area meets those
requirements;
(iii) The countv and affected cities agree to the extension of sewer to serve the school sited in a
mral area tl1at serves urban and mral st11dents at the time of concurrence of subsection (4)(d)(ii);
(iv) Any impacts associated with the siting of the school are 1nitigated as required by the Stale
Environmental Policy Act. Chapter 43.2 lC RCW: and,
(v) Anv extension of the sewer bevond the urban growtl1 area is subject to the following:
The Jefferson County Code is current through Ordinance 08-20, passed November 16, 2020.
Jefferson County Code
DRAFT JAN 26, 202 I VI
Page 2/2
(I) Must only serve the applicable school and the costs of the extension must be borne by
the applicable school district based on a reasonable nexus to the impacts of the school.
(2) Any exception from subsection (4)(d)(v), when consistent with RCW 36.70A.110(4).
shall allow the sewer to serve a propertv or properties in addition to the school if the
property owner so requests, provided that the countv and affected cities agree with tl1e
request and provided that the property is located no further from the sewer than the
distance that. if the property were within the urban growth area, the propertv would be
required to connect to the sewer.
(3) If a property owner connects to tl1e sewer under subsection (4)(d)(v)(2). tl1e school
district may, for a period of time not to exceed 20 years. require reimbursement from a
requesting property owner for a proportional share of the constrnction costs incurred by
the school district for the extension of the sewer.
The Jefferson County Code is current through Ordinance 08-20, passed November 16, 2020.
05 14 2026 - Comprehensive Plan Housekeeping from Ordinance 01-0426-21
Capital Facilities & Utilities - Public Hearing Draft - April 2026 (pg. 8-31)
Policy CF-P-6.3 New urban public servicessanitary sewer systems will only be provided within a
UGA and will not be extended beyond the current boundary of a UGA unless; deemed to be an
essential public service to mitigate a threat to public health, safety, or general welfare.
• It is a necessary response to protect basic public health, safety, and the environment;
the sewer, extension, or connection is financially supportable at rural densities, and the
sewer, connection, or extension does not permit urban development;
• It is necessary to support a Limited Area of More Intensive Rural Development (LAMIRD)
consistent with the County-wide Planning Policies;
• It is necessary to provide service to an essential public facility if no practicable
alternative exists to site the essential public facility in an Urban Growth Area;
• It supports a rural school serving both rural and urban student populations, consistent
with state law; or,
• It is necessary to support state-authorized middle housing developments within a
designated Type 1 LAMIRD.[JWl]
Land Use - Public Hearing Draft - April 2026 (pg. 1-88)
Per WAC 365-196-425(4)(b), the GMA allows sanitary sewer infrastructure in rural areas when:
fil-# it abates a public health or environmental problem, is necessary to protect basic public
health and safety and the environment, does not induce sprawling urban development, and is
affordable by the community that it serves; (2) it is necessary to support a LAMIRD and it is
consistent County-wide Planning Policies; or (3) supports a school located in the rural area
serving both rural and urban students. The application of this allowance is being investigated in
the Brin non Rural Village Center, adjacent to Dosewallips State park's wastewater treatment
facility. The county is working to address requirements of the GMA, while allowing limited
service by the Dosewallips State park's system. Currently, Brinnon is served entirely by on-site
sewer systems. These on-site sewer systems have current and potential problems, and some
systems are located within the 100-year flood Rme-Splain and are adjacent to the Hood Canal.
Other infrastructure improvements consistent with rural levels of service, such as improvements
to fire flow, could support additional development, but improvements to existing commercial
development and housing stock are unlikely to occur if the necessary infrastructure upgrades
cannot take place
-
e;t(t.(
Joel Peterson
From:
Sent:
To:
Subject:
Categories:
2025 Comp Plan
Friday, May 15, 2026 9:29 AM
Joel Peterson; Jeremy Williammee
FW: Comment on the draft Comprehensive Plan and UDC Periodic Update
Comp Plan Update
-Alex H
From: Vicki Rhoades <nirupaml@comcast.net>
Sent: Friday, May 15, 2026 9:06
To: 2025 Comp Plan <2025compplan@co.jefferson.wa.us>
Subject: Comment on the draft Comprehensive Plan and UDC Periodic Update
ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are
not expecting them.
Dear Planning Commission.
Having skimmed through this, I support these plan changes overall. I realize that many of the figures
for rural v urban population growth presented on Wednesday evening are estimates; still, clear
targets for anticipated growth are vital to planning.
As a new resident to Jefferson County (coming from King County), trust me, the time to prepare for
population growth is well before it happens. I can appreciate the honest time and effort put in to plan
for this, kudos!
As a resident of a cohousing community (Quimper Village) I can attest to the value of cohousing in
providing density while preserving as much open area as possible. Many move here, I imagine, for
the quieter life. I have lived in a very rural area of WA state prior to King County and I know how
important peace and quiet is for many. I would rather hear the coyotes singing at night, than sirens.
I note that a new cohousing community is working hard to be permitted and built, in a more rural part
of Jefferson County. I refer to Newt Crossing. I understand that they are working with Chuck Durrett,
who also designed Quimper Village. He has a lot of experience designing cohousing communities,
decades worth, and I'm sure he will advise them appropriately for a good, well-built community.
There are some items in this draft comprehensive plan that are needed for Newt Crossing to move
forward, and I urge you to keep them to facilitate their construction and prepare for Jefferson County
population increases. They are:
- page 300, section 18.15.485: keep the added words "short or long subdivision" (paragraph 1) and
keep the added language about substandard lots (paragraph 4).
1
- page 306, section 18.15.520: keep the language about increasing density to 40% if certain
conditions are met (paragraph 3). I
I do appreciate the time you all spent on this proposed draft. I did not hear a lot of pushback on
Wednesday night and I know how important your work to date has been; and I hope that there are not
a lot of revisions overall. I look forward to being a solid citizen of Jefferson County.
I think there is another meeting next week to discuss public commentary? Perhaps you can respond
with the time and zoom link, thanks.
Vicki Rhoades, Quimper Village
2
Joel Peterson
From:
Sent:
To:
Cc:
Subject:
Attachments:
Categories:
Engelbrecht, Joshua (COM) <joshua.engelbrecht@commerce.wa.gov>
Friday, May 15, 2026 9:32 AM
Joel Peterson
Holman, Carol (COM)
Jefferson County Comprehensive Plan and U DC - Planview Submittal 2025-S-1097 4A -
Comments
2025-S-1097 4A_Draft_Commentletter.pdf
Comp Plan Update
ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are
not expecting them.
Good morning,
Thank you for all the work that you've put into Jefferson County's comprehensive plan and development
regulations!
Attached please find our draft comment letter with our recommendations for the comprehensive plan and
Unified Development Code.
As you review and digest, please feel free to discuss/ respond to any of the comments we've made.
Thanks again for all your work and please reach out with any questions you have.
All the best,
Joshua Engelbrecht, AICP (He/Him/His) I SENIOR PLANNER - WESTERN REGION
Growth Management Services I Washington State Department of Commerce
PO Box 42525
Olympia, WA 98504-2525
Office: 360-725-3046
www.commerce.wa.gov I Facebook I Twitter I Linkedln I Subscribe
Email communications with state employees are public records and may be subject to disctosure, pursuant to Ch 42. 56
RCW
1
STATE OF WASHINGTON
DEPARTMENT OF COMMERCE
1500 Jefferson Street SE I PO Box 42525 I Olympia, Washington 98501 I 360-725-4000
www.commerce.wa.gov
DRAFT
May 15, 2026
Board of County Commissioners
c/o Joel Peterson, Associate Planner
Jefferson County
615 Sheridan Street
Port Townsend, WA 98368
Sent Via Electronic Mail: jpeterson@co.jefferson.wa.us
Re: 2025-S-10974A Supplemental Planview Submittal - Periodic Update to Jefferson County's
Comprehensive Plan and Development Regulations.
Dear Commissioners:
Thank you for the opportunity to review and comment on Jefferson County's draft comprehensive plan
and development regulations. We appreciate the ongoing coordination with our agency as you work to
achieve the community's vision consistent with the goals and requirements of the Growth Management
Act (GMA). Growth Management Services received the proposed amendment on April 16, 2026, and
processed it with material identification number 2025-S-10974A.
We have reviewed your submittal using Commerce's Periodic Update Checklist, and Expanded Housing
Checklist. We encourage you and your community to consider the following as you finalize your drafts
prior to adoption:
1. Land Use Element
As part of our review, we did not find any policies or development regulations associated with
organic material management facilities. For consistency with RCW 36.70A.142, we recommend
explicitly allowing the siting organic material management facilities in areas identified by the
Jefferson County Solid Waste Management Plan.
2. Transportation Element
In our review, we noted two policies related to ADA Transition Plans but could not find direct
reference in the Transportation Element to the self-evaluation of current facilities. We did find
Jefferson County's existing ADA Transition Plan, outside of the Comprehensive Plan documents.
Page 1 of 3
Washington State Department of Commerce: Submittal ID 2025-S-10974A
For consistency with RCW 36.70A.070, we recommend referencing the existing Self-Evaluation
and Transition Plan within the Transportation Element.
3. Housing Element
Adequate Provisions
o In addition to the adequate provision work outlined in Appendix E and based on recent
GMHB cases, we also recommend identifying gaps in local funding needed to achieve
affordable housing needs and documenting which available local funding tools or
incentives are already being used.
o Guidance on this can be found in chapter 4 of Guidance for Updating Your Housing
Element (pg. 60-62) and Appendix B: Adequate provisions checklist.
4. Capital Facilities Element
While we did find inventories of existing capital facilities in our review of the Capital Facilities
element, we did not find any references or identification of green infrastructure owned by
public entities. For consistency with RCW 36.70A.070(3)(a), we recommend incorporating any
existing green infrastructure facilities into your inventory of capital facilities, or explicitly calling
out that none exist.
5. Development Regulations
a. ADUs - In our review of JCC18.20.020(2){e), we found that door locations are specifically limited
to one exterior entrance. For consistency with RCW 36. 70A.681(l){h), we recommend removing
or clarifying this provision so that AD Us are not more restrictive than those for principal units.
b. In our review, we found that the parking standards in JCC 18.30.100 that may require off-street
parking for several residential housing project types that should not have off-street parking
requirements. For consistency with RCW 36.70A.817, we recommend updating JCC 18.30.100 to
explicitly exempt the following housing projects from the County's parking standards:
i. Affordable housing.
ii. New construction or the retrofit of existing buildings meeting passive house
requirements.
iii. Modular construction.
iv. Mass timber construction.
Alternatively, RCW 36. 70A.817 includes an empirical study pathway for the County to pursue, if
you believe these projects should not be exempt from the parking standards in JCC 18.30.100.
Finally, this code change is not due until 6 months after your periodic update is complete.
c. In our review, we found that the height and setback standards outlined in JCC 18.18.050 and JCC
18.30.050 did not include provisions that would allow for the following flexibility:
Page 2 of 3
Washington State Department of Commerce: Submittal ID 2025-S-10974A
i. Allow for new construction or retrofits of existing buildings for residential housing to
project into required setbacks and exceed height limits by up to eight inches to
accommodate the addition of necessary insulation.
ii. Allow for buildings meeting passive house requirements to project into required
setbacks and exceed height limits by up to eight inches to accommodate the addition of
necessary insulation.
iii. Measure gross floor area must be from the interior face of the exterior walls.
iv. Allow a building to exceed maximum roof height limits by at least 48 inches to
accommodate a roof-mounted solar energy panel
For consistency with RCW 36. 70A.810, .812, and .813, we recommend incorporating the ability
to exceed height and setback standards in the above cases. Please note: This code change is not
due until 6 months after your periodic update is complete.
Finally, as a friendly reminder, copies of adopted plans and development regulations must be submitted
to Commerce within ten days after final adoption (RCW 36. 70A.106(2)).
Again, we appreciate the work your proposed amendments represent, and we wish you success in
meeting the goals of the Growth Management Act. We are available for technical assistance and, if
requested, can attend upcoming meetings with your Planning Commission and/or Council. If you wish to
discuss these comments, you may reach me at joshua.engelbrecht@commerce.wa.gov or 360-725-3046.
Sincerely,
fa~ e~dti,edv<
Joshua Engelbrecht, AICP
Senior Planner
Growth Management Services
cc: David Andersen, AICP, Managing Director, Growth Management Services
Valerie Smith, AICP, Deputy Managing Director, Growth Management Services
Ben Serr, AICP, Eastern Regional Manager, Growth Management Services
Carol Holman, MUP, Western Regional Manager, Growth Management Services
Anne Fritzel, AICP, Housing Section Manager, Growth Management Services
Laura Hodgson, Housing Planning and Data Manager, Growth Management Services
Page 3 of 3
.
JAMESTOWN S'KLALLAM TRIBE
1033 Old Blyn . hway. Sequim. A 1'163&2 360/il83-1109 FAX 360/661 643
Jeremy Williammee
Director of Community Development
Jefferson County Department of Community Development
621 Sheridan St.
Port Townsend, WA 98368
May 15, 2026
Dear Director Williamee,
On behalf of the Jamestown S'Klallam Tribe, we extend our appreciation for the opportunity
to engage with Jefferson County on the Comprehensive Plan update process. The wealth
and wellbeing of Jefferson County communities and the Jamestown S'Klallam Tribe (JST)
are intricately tied to our waters, lands and marine resources. The comprehensive plan is a
foundational document to provide guidance for land-use decisions in the coming
decade(s).
The following comments detail our specific recommendations for the current draft of the
Comprehensive Plan update. We appreciate your genuine review of our comments and
continued engagement with the Tribe throughout this process.
Sincerely,
Alex Scagliotti
Environmental Planner
Jamestown S'Klallam Tribe
Allie Taylor
Tribal Historic Preservation Officer
Jamestown S'Klallam Tribe
Natural Resources Comments
1. The plan refers to "Tribes" regularly but does not define which Tribes should be
engaged. The word "Tribes" should be defined and include not just Tribes whose
reservations fall within Jefferson County, but Tribes that have Usual and
Accustomed (U&A) areas within Jefferson County including the Jamestown
S'Klallam Tribe and the other signatory Tribes to the Point No Point Treaty and outer
coast treaties.
2. Section 2: Natural Resources
a. 2.2 Trends and Opportunities-Aquaculture (p. 7)
i. The sentence that reads "Aquaculture requires high water quality for
growing; however, this may impact the overall water quality, such as
increased nutrient loads." is incorrect and misleading. Shellfish
aquaculture reduces nutrient loads and generally improves water
quality due to filter feeding properties of shellfish. This sentence may
be referring to finfish aquaculture which is prohibited in all
Washington marine environments. We suggest either removing the
final two sentences of that paragraph or rewording to "Aquaculture
requires high water quality for growing and generally improves water
quality when growers follow standard practices."
ii. In the following paragraph, the sentence "In-water finfish farming is
conditionally allowed in some shoreline designations by the Jefferson
County Shoreline Master Program (SMP), though the SMP discourages
non-native finfish farming except in limited areas, and the State is
phasing out certain net pen uses." is also incorrect. Non-native finfish
farming is already illegal in Washington State per RCW 77.125.050
and 79.105.050. In addition, commercial finfish net pen aquaculture
is banned in all marine waters as per WAC 332-30-138. We suggest
either removing this sentence entirely or rewording to reflect the
current status of finfish net pens.
b. Policy NR-P-2.3 (p.24): Add the underlined wording to "Explore and
implement incentives that encourage compliance with 'best management
practices' by resource-based economic activities."
3. Section 5: Environment
a. Exhibit 5-7 has a bulleted point that should include the underlined wording
"Engage local Tribes with usual and accustomed areas in Jefferson County
environmental planning and sustainability efforts"
i. This is to include not just coastal Tribes with reservations in Jefferson
County but Tribes that also have a significant stake in the health of
ecosystems in Jefferson County that support tribal treaty rights. The
Jamestown S'Klallam Tribe owns several small parcels in Jefferson
County that County staff may not be aware of but the Tribe's usual
and accustomed area (U&A) encompasses all of eastern Jefferson
County and therefore should be included in watershed and salmon
recovery planning.
b. Section 5.2 Trends and Opportunities
i. While some of the other chapters reference treaty-protected
resources, Section 5 currently lacks this acknowledgment. Given the
Comprehensive Plan's role in guiding long-term growth, it is essential
that the Section 5 guiding principles on the environment include the
County's obligation to engage with Tribal nations. We suggest the
following underlined addition to the final paragraph of this section on
page 9:
1. Protection, rehabilitation, and enhancement of Jefferson
County's natural environment should allow for flexible and
innovative development or investment that meets
environmental and quality-of-life goals. To ensure this holistic
approach, the County's environmental. economic, and social
strategies will also recognize treaty-reserved rights and include
formal engagement with Tribal partners whenever County
actions such (as permitting or rulemaking) impact these
protected resources.
4. Section 9: Climate element
a. We recommend expanding the Plan's coastal resilience language to include
erosion-prone shorelines and bluffs alongside flooding. There are regular
references to implementing adaptive strategies for flood-prone areas but
none for shoreline infrastructure at risk of coastal erosion. Current guidance
for built infrastructure should be climate-informed for all coastal risks. Since
bluffs and low-bank shorelines serve a vital role in nearshore ecosystems
while also presenting significant hazards during storms and sea-level rise,
the Plan should apply the same restrictive and adaptive guidance to erosion-
prone coastal areas as it does to floodplains. We recommend locating
references to proactive flood protection measures and adding coastal
erosion in all relevant areas throughout the chapter, or establishing a new
section that specifically addresses adapting current and future infrastructure
to changing shorelines by increasing setbacks, restoring naturally protective
coastal shoreforms and other adaptive strategies.
i. As an example, policy CE-P-21 should be changed to include the
underlined addition: "Discourage new or expanded development,
including subdivisions, that would require flood control structures
due to their location at or near a stream, channel migration zone,
flood-prone area, or an area at risk of flooding, coastal erosion or sea
level rise due to climate change.
Cultural Resources Comments
1. Section 4: Open Space, Parks & Recreation, Historical & Cultural Preservation
a. 4.3 Historic & Cultural Resource Preservation
i. Much of this text is in past tense. Tribal people are still here today and
continue to access these resources and important areas. We
recommend Jefferson County update this text to present tense and only
use past tense where appropriate such as when discussing village site
locations.
ii. Jefferson County is home to many federally recognized tribes but visited
by other groups and tribes. Regarding the first sentence of the first
paragraph under this section on page 4-8, we recommend the
strikethrough edits and underlined additions to the following sentence:
"Prior to the arrival of European settlers and explorers, t Ihe area that is
now Jefferson Countywes is. home to and visited by many Native
American groups (First Peoples) including the Chemakum, Hoh,
S'Klallam/Klallam, Makah, Quileute, Quinault, Suquamish, and T'ifo'ana
skokcmtsn-e-ees peoples.
iii. There are many upland sites that were utilized by tribal peoples.
Regarding the second sentence of the first paragraph under this section
on page 4-8, we recommend the underlined additions to the following
sentence: "Permanent village sites and activity areas were
concentrated near ocean and riparian resources for food access and
mobility however, few villages were located in the upland river systems
for access to upland resources."
iv. Tribes not only collected food and medicinal plants but also manage
and cultivate these resources. Regarding the last sentence on page 4-8,
we recommend the strikethrough edits and underlined addition to the
following sentence: "They also hunted-land mammals and birds,
collected and manage food and medicinal plants ... "
v. Regarding the second sentence on the first full paragraph on page 4-9,
we recommend the strikethrough edits and underlined additions to the
following sentence: "Specialized activity sites, such as W6fk seasonal
camps and cedar cutting gathering areas can be found inland."
vi. The Jamestown S'Klallam Tribe have an agreement with Jefferson
County Historical Society for the use of tribal images. The top two
images on page 4-9 are associated with the Jamestown S'Klallam Tribe
in some way. We request Jefferson County ask permission prior to use
of these types of photos in such a widely shared document.
vii. The final sentence on page 4-9 paragraph two explaining the territory of
each Tribe is too simplified and incorrect in areas. We recommend a full
rewording of the sentence to reflect an accurate representation of each
of these Tribe's Usual and Accustomed areas and traditional use areas.
viii. The final two sentences of paragraph three on page 4-9 discuss the
importance of preserving cultural resource. We recommend Jefferson
County include language that clearly states cultural resources are non-
renewable and avoidance of impacts to cultural resources should be
added to the goals and policies of this Plan.
b. 4.4 Goals and Policies
i. The language of this section does not include any specific actions that
would assist in the avoidance, protection, and preservation of cultural
resources such as cultural resource surveys prior to development.
The Clallam County Shoreline Master Plan 35.25.160 provides
excellent protections to both known and unknown cultural resources.
The THPO recommends the Jefferson County add Policies 1, 2, and 3
from the Clallam County Shoreline Master Plan 35.25.160 listed
below with the following edits:
1. "(1) Sites and resources having known or suspected
archaeological, historic, or cultural value should be protected.
These sites/resources are important, nonrenewable resources
and many are in danger of being damaged or lost because of
ongoing development. Wherever possible, sites should be
permanently preserved for scientific study ancflor public
obserVBtion consistent with 36 CFR BOO and Chapter 27.53
RCW. If the presence of an archaeological site is unknown then
a survey should be conducted by an archaeologist.
2. (2) Proposed development on or adjacent to an identified
archaeological, historic, or cultural site should be designed
and operated to be compatible with continued protection of
the archaeological, historic, or cultural site.
3. (3) The location of historic, cultural, and/or archaeological
sites/resources should not be disclosed to the general public
unless adequate provisions can be put in place to ensure long-
term protection and preservation of such sites/resources."
ii. We recommend this section also reference cultural resource
regulations Jefferson County is required to follow including but not
limited to: Executive Order 21-02, SEPA, RCW27.53, RCW 68.60, WAC
25-48, WAC 25-46, RCW 42.56.300, RCW 27 .44, RCW 68.50, etc.
iii. Policy OS-P-5.1
1. We recommend the third bullet point add "through
consultation" at the end of the sentence.
iv. Policy OS-P-5.4
1. We recommend the word coordination be changed to
consultation in this policy.
General Comment
The term "BIPOC" is used throughout the planning document. Many Tribal communities
prefer using more specific language, as BIPOC fails to recognize the unique cultural and
political standing of Tribes in our region. While also problematic, we recommend using the
US Census Bureau's defined categories when discussing demographic data related to race
if it is not possible to use the name of the Tribe.
Joel Peterson
From:
Sent:
To:
Subject:
2025 Comp Plan
Monday, May 18, 2026 11 :56 AM
Joel Peterson; Jeremy Williammee
FW: Public comment
Categories: Comp Plan Update
-Alex H
From: Chris Hannon <ckjhannon@gmail.com>
Sent: Friday, May 15, 2026 15:58
To: 2025 Comp Plan <2025compplan@co.jefferson.wa.us>
Subject: Public comment
ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are
not expecting them.
While the plan does a strong job addressing land use, zoning, and affordability incentives, it does not appear to
sufficiently address a key constraint in Jefferson County: the availability of construction labor, higher transportation
costs, and longer project timelines.
In a rural setting like ours, limited contractor capacity and the high cost of bringing in builders or construction materials
from outside the region can significantly delay production or prevent housing developers from viewing the region as a
viable location for any projects. I encourage the County to explicitly analyze this constraint and incorporate strategies to
increase local construction capacity.
Without addressing these factors, I am concerned that there is a risk the planned efforts for housing development will
not translate into actual built units.
Separately, our housing issues will not be solved without collaboration with local landlords. Right now there is a lot of
hesitancy in the community around renting to low income households or those struggling with housing insecurities.
Other areas across the country have County funded or led efforts to create programs and outreach to build trust
between landlords, service providers, and provide safety nets against things such as damages or missed payments.
The plan incorporates exploring tenants advocacy which is sorely lacking and needed in our area. However with the level
of challenge we face in Jefferson County we leave out similar work with local landlords at our own peril.
-Chris Hannon
1
Joel Peterson
From:
Sent:
To:
Subject:
Attachments:
Categories:
2025 Comp Plan
Monday, May 18, 2026 11 :56 AM
Joel Peterson; Jeremy Williammee
FW: Bratz comments 2025CompPlan
BratzComments2025JeffCoCompPlanUpdate.xlsx
Comp Plan Update
-Alex H
From: Cyndy Bratz <cyndy.bratz@gmail.com>
Sent: Friday, May 15, 2026 14:18
To: 2025 Comp Plan <2025compplan@co.jefferson.wa.us>
Subject: Bratz comments 2025CompPlan
ALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are
not expecting them.
Hello Comp Planners
My comments are in the attached spreadsheet.
This version looks so much better than the previous version - thank you for your efforts!
Also, the County hired a good consultant team! (Nice work on Element 9.)
- Cyndy Bratz
1
2025 Jefferson County Comprehensive Plan Periodic Update Comments
15-May-26 Public Review Draft
Comments by Cyndy Bratz, Port Townsend
Member of Forest Working Group
Page or Section Comment Notes ........... ······························ ..... ! OUR VISION FOR 2045, ! First paragraph, part way through add: Residents and visitors alike enjoy Jefferson County's spectacular wildflower
first page j meadows and lush forests.
!Second page, second paragraph, third sentence add (edits in ALL CAPS for clarity): Sectors including food system
! development, marine trades and craftsmanship, HOSPITALITY AND TOURISM, healthcare and education, resource
! OUR VISION FOR 2045, management, high-tech and science-based trades; tG\ffism, art and cultural events, among others, support our robust
Vision Statement second page economy.
Plan Foundation p. ii Last paragraph, second sentence, delete repetitious word "in": "UGA zoning i~ . ..i.~ portions of Port Hadlock ... " ................
[Cornprehensive Plan Contents. After the bullet list, add to the end of the second paragraph: Note that the Goals and
'Policies in Element 9 (Climate) overlap significantly with other elements. We advise reviewing each element in
p.xxii ...... _conju_nction with the Climate Element. t Plan Foundation p. xiv Rural Character sidebar, 4th bullet, correct "nad" to read "and". .................................................. . .....
Element 5 - "Connection to the Vision Statement", edit as follows (edits in ALL CAPS for clarity): This element, IN COORDINATION
Environment p. 5-1 WITH ELEMENT 9- CLIMATE, supports the Vision Statement by addressing the conservation of open spaces, ...
Element 5 - 5.4 GOALS & POLICIES. To the end of the second paragraph, add: Note that there is considerable overlap between the
Environment P. 5-16 Goals and Policies in Chapter 9 - Climate and those presented below. A review of both sections is advised.
Element 9 - Climate p.36
[Exhibit 9-8 Climate Action Plan. To "Climate Science Updates", add a bullet under Sector Nexus called "Climate ,
!Modeling". Under Description, add: Climate Action Committee to organized qualified team to perform periodic countv-:
[wlde GHG modeling of sector-based emissions, and forest and trees GHG inventory.
, Exhibit 9-8 Climate Action Plan. To "Support Local Economy", add a bullet under Sector Nexus called "Promote Outdoor
Recreation". Under Description, add: Expand recreational opportunities by increasing hiking trails, campsites, and
associated amenities (shelters, picnic facilities). Provide signage for all improvements and guide brochures featuring Outdoor recreation/tourism is a large
Element 9 - Climate I p. 37 !accessible and short-hike options. portion of Jefferson County's economy.