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Begin forwarded message:
From: Janet and/or Willi <aloha@olympus.net>
Subject: Proposed Amendments to the UDC, Title 18
Date: November 12, 2018 at 10:13:36 PM PST
To: "PlannCom@co.jefferson.wa.us" <PlannCom@co.jefferson.wa.us>
Cc: "jeffbocc@co.jefferson.wa.us" <jeffbocc@co.jefferson.wa.us>, Philip
Hunsucker <PHunsucker@co.jefferson.wa.us>, Mark McCauley
<MMcCauley@co.jefferson.wa.us>, Michelle Farfan
<MFarfan@co.jefferson.wa.us>
Please consider my comments, attached.
Janet Welch
Fwd: Proposed Amendments to the UDC, Title 18
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To:
Janet and/or Willi <aloha@olympus.net>
Mon 11/12/2018 10:20 PM
Planning Commission Desk;
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Page 1 of 1Fwd: Proposed Amendments to the UDC, Title 18
11/13/2018https://owa.co.jefferson.wa.us/owa/
RE: Amendments to the UDC, Title 18 Relating to Shooting Facilities
To: Members of the Jefferson County Planning Commission, Jefferson County
Board of County Commissioners, Philip Hunsucker, Mark McCauley, Michelle
Farfan
From: Janet Welch, representative from District 2 on the Shooting Facility
Ordinance Committee
I have three areas on which I would like to comment regarding the proposed
revisions to Title 18.
Non-Commercial Shooting Facilities
I support the revisions of Title 18 that create consi stency with the new sections
of Title 8. However, I do not support the strategy of creating another class of
regulated shooting facilities called, in the draft, "non-commercial". These uses
would exist in addition to non-regulated private facilities. In our work on the
committee drafting the Commercial Shooting Facility Ordinance, we were
assured that private shooting facilities are largely exempt from regulatory or
enforcement involvement except when those activities result in 'reckless
endangerment".
This proposal would create a new category which is neither an activity where a
property owner is allowed to shoot on his/her own property (e.g. private) nor a
"Commercial Shooting Facility". Doing so would confuse the regulatory
environment because the distinctions are extremely vague but the regulatory
implications are significant. The desire to avoid the requirements of Title 8
would drive any applicant to try to frame their proposal as a "Non -Commercial
Shooting Facility. This is a disservice to the applicants, who deserve a
predictable regulatory environment, to county staff who need clear guidance,
and to the public who is supposed to be the beneficiary of regulations.
Please drop the idea of creating this loophole. This could be done by changing
the JCC 18.20.350(8) heading (currently "Outdoor Shooting Ranges") simply to
"Outdoor Commercial Shooting Facilities" as defined in Title 8. Furthermore, to
avoid inconsistency with Title 8, which greatly expands and clarifies the
standards for such facilities, most of the standards under 350(8) can--and
should--be deleted.
Putting Outdoor Commercial Shooting Facilities into the overall heading of
Commercial uses, as currently proposed, runs contrary to the assumption that
commercial uses (in commercial zones) don't need to be scrutinized for impact.
Because commercial uses are not generally allowed in zones other than
commercial, scrutiny isn't warranted. However, under this heading rural
residential and other rural uses would have no protection from impacts
generated by this kind of conditionally permitted commercial use.
This simple name change that I propose, and elimination of the subheadings of
350(8) would accomplish the need to dovetail the two sections of the code in the
very limited time that the Planning Commission has to do its work. In the long
run, however, I believe the county must address the permitting problems
inherent with the Small Scale and Tourist Related Use category. There is
simply too much ambiguity in the definitions and objectives of the category.
Those ambiguities will continue to expose the county to problems such as we
are currently trying to resolve concerning shooting facilities.
Indoor Facilities
On another subject, I have a significant problem with the zoning pro posal for
Indoor commercial Shooting Facilities.
The proposed changes to Table 3-1 would allow Indoor Commercial Shooting
Facilities in all rural residential and neighborhood commercial zones! The GMA
is quite clear that commercial activities must not be permitted in non commercial
zones. Opening rural residential zones to this kind of commercial use is a
terrible idea that would leave the county highly vulnerable to losing a hearings
board appeal. Likewise, there would be problems with allowing those uses in
the smaller commercial zones (convenience, crossroads, and neighborhood
crossroads). Those zones are defined in ways that limit the scale and type of
commercial uses that are permitted there. Commercial shooting facilities would
not be in compliance with those standards. Therefore, by the process of
elimination, the only zones where Indoor Commercial Shooting Facilities can be
allowed and be GMA compliant would be UGA and Light Industrial/Commercial,
and possibly Rural Village Center.
Clearer Definitions
Finally, even if the poorly conceived idea of creating a land use called Non-
commercial Shooting Facility is eliminated (which I fervently hope), I remain
concerned that there is still a gray area when distinguishing between a
Commercial Shooting Facility and an unregulated private facility. The ordinance
language needs to provide unambiguous distinctions between private and
commercial shooting facilities, which I believe it does not yet do. The most
significant gap I foresee is where shooting is associated with a home business
or cottage industry.
It isn't possible to expand the definition of the "exceptions to..." clause of the
Commercial Shooting Facilities , proposed JCC 18.10.030(b)
without creating an inconsistency with Title 8. Therefore, the remedy must
happen elsewhere. I propose revisions to both home business and cottage
industry chapters.
Article 18.20.200(2), which limits the scope of what can be considered a home
business, should be amended to say
(2) Permitted home businesses do not include the following:
(d) Uses which are associated with shooting activities and/or tactical
defense practice.
The revision to the cottage industry section must be slightly different because
the prohibition section 18.20.170(3) is subject to exemptions. This can be
resolved by revising instead the standards for cottage industries. I suggest for
your consideration the following wording (underlined):
18.20.170(4) Standards for Cottage Industries
Where shooting is associated with a cottage industry, or where the other
uses of the property either facilitate shooting practice or are related to
shooting activities and/or tactical defense practice, such property shall be
considered a commercial shooting facility.
I hope that the commission will give these suggestions due consideration in your
deliberations.
Sincerely
Janet Welch
Nordland, WA