HomeMy WebLinkAboutCSFO SEPA Checklist CompleteJefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
SEPA ENVIRONMENTAL CHECKLIST FOR
PROPOSED AMENDMENTS TO THE JEFFERSON
COUNTY CODE, TITLE 8 AND TITLE 18, RELATING
TO COMMERCIAL SHOOTING FACILITIES IN
UNINCORPORATED JEFFERSON COUNTY
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Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
Table of Contents
Table of Contents .......................................................................................................................................... i
A. Background .......................................................................................................................................... 1
1. Name of proposed project, if applicable ............................................................................................ 1
2. Name of applicant ............................................................................................................................. 1
3. Address and phone number of applicant and contact person ........................................................... 2
4. Date checklist prepared .................................................................................................................... 2
5. Agency requesting checklist ............................................................................................................. 2
6. Proposed timing or schedule (including phasing, if applicable) ........................................................ 2
7. Do you have any plans for future additions, expansion, or further activity related to or connected
with this proposal? If yes, explain. ................................................................................................ 2
8. List any environmental information you know about that has been prepared, or will be prepared,
directly related to this proposal. .................................................................................................... 2
9. Do you know whether applications are pending for governmental approvals of other proposals
directly affecting the property covered by your proposal? If yes, explain. ...................................... 2
10. List any government approvals or permits that will be needed for your proposal, if known. .......... 2
11. Give brief, complete description of your proposal, including the proposed uses and the size of the
project and site. There are several questions later in this checklist that ask you to describe certain
aspects of your proposal. You do not need to repeat those answers on this page. (Lead agencies
may modify this form to include additional specific information on project description.) ................ 3
12. Location of the proposal. Give sufficient information for a person to understand the precise
location of your proposed project, including a street address, if any, and section, township, and
range, if known. If a proposal would occur over a range of area, provide the range or boundaries
of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if
reasonably available. While you should submit any plans required by the agency, you are not
required to duplicate maps or detailed plans submitted with any permit applications related to this
checklist. .................................................................................................................................... 15
B. ENVIRONMENTAL ELEMENTS ....................................................................................................... 15
1. Earth ............................................................................................................................................... 15
2. Air ................................................................................................................................................... 20
3. Water .............................................................................................................................................. 22
4. Plants .............................................................................................................................................. 34
5. Animals ........................................................................................................................................... 37
6. Energy and Natural Resources ....................................................................................................... 39
7. Environmental Health ..................................................................................................................... 40
8. Land and Shoreline Use ................................................................................................................. 48
9. Housing .......................................................................................................................................... 57
10. Aesthetics ................................................................................................................................... 58
11. Light and Glare ........................................................................................................................... 61
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Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
12. Recreation .................................................................................................................................. 63
13. Historic and cultural preservation ................................................................................................ 64
14. Transportation ............................................................................................................................. 69
15. Public Services ........................................................................................................................... 74
16. Utilities ........................................................................................................................................ 75
C. Signature ............................................................................................................................................ 77
D. Supplemental Sheet for Nonproject Actions ....................................................................................... 78
1. How would the proposal be likely to increase discharge to water; emissions to air; production,
storage, or release of toxic or hazardous substances; or production of noise? ........................... 78
2. How would the proposal be likely to affect plants, animals, fish, or marine life? .............................. 83
3. How would the proposal be likely to deplete energy or natural resources? ..................................... 86
4. How would the proposal be likely to use or affect environmentally sensitive areas or areas
designated (or eligible or under study) for governmental protection; such as parks, wilderness,
wild and scenic rivers, threatened or endangered species habitat, historic or cultural sites,
wetlands, floodplains, or prime farmlands? ................................................................................. 88
5. How would the proposal be likely to affect land and shoreline use, including whether it would allow
or encourage land or shoreline uses incompatible with existing plans? ...................................... 90
6. How would the proposal be likely to increase demands on transportation or public services and
utilities? ....................................................................................................................................... 92
7. Identify, if possible, whether the proposal may conflict with local, state, or federal laws or
requirements for the protection of the environment. .................................................................... 95
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Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
SEPA ENVIRONMENTAL CHECKLIST FOR
PROPOSED AMENDMENTS TO THE JEFFERSON COUNTY CODE,
TITLE 8 AND TITLE 18, RELATING TO COMMERCIAL SHOOTING FACILITIES
IN UNINCORPORATED JEFFERSON COUNTY
Purpose of checklist:
Governmental agencies use this checklist to help determine whether the environmental impacts of your
proposal are significant. This information is also helpful to determine if available avoidance, minimization or
compensatory mitigation measures will address the probable significant impacts or if an environmental
impact statement will be prepared to further analyze the proposal.
Instructions for applicants:
This environmental checklist asks you to describe some basic information about your proposal. Please
answer each question accurately and carefully, to the best of your knowledge. You may need to consult with
an agency specialist or private consultant for some questions. You may use “not applicable” or "does not
apply" only when you can explain why it does not apply and not when the answer is unknown. You may also
attach or incorporate by reference additional studies or reports. Complete and accurate answers to these
questions often avoid delays with the SEPA process as well as later in the decision-making process.
The checklist questions apply to all parts of your proposal, even if you plan to do them over a period of time
or on different parcels of land. Attach any additional information that will help describe your proposal or its
environmental effects. The agency to which you submit this checklist may ask you to explain your answers
or provide additional information reasonably related to determining if there may be significant adverse
impact.
Instructions for Lead Agencies:
Please adjust the format of this template as needed. Additional information may be necessary to evaluate
the existing environment, all interrelated aspects of the proposal and an analysis of adverse impacts. The
checklist is considered the first but not necessarily the only source of information needed to make an
adequate threshold determination. Once a threshold determination is made, the lead agency is responsible
for the completeness and accuracy of the checklist and other supporting documents.
Use of checklist for nonproject proposals: [help]
For nonproject proposals (such as ordinances, regulations, plans and programs), complete the applicable
parts of sections A and B plus the SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS (part D).
Please completely answer all questions that apply and note that the words "project," "applicant," and
"property or site" should be read as "proposal," "proponent," and "affected geographic area," respectively.
The lead agency may exclude (for non-projects) questions in Part B - Environmental Elements –that do not
contribute meaningfully to the analysis of the proposal.
A. Background [help]
1. Name of proposed project, if applicable: [help]
RESPONSE: Non-project legislation with proposed Amendments to the Jefferson County Code
(JCC), Title 8 and Title 18, Relating to Commercial Shooting Facilities in Unincorporated Jefferson
County.
2. Name of applicant: [help]
RESPONSE: Jefferson County Department of Community Development.
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Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
3. Address and phone number of applicant and contact person: [help]
RESPONSE: 621 Sheridan St. Port Townsend WA 98368; Michelle Farfan, 360-379-4463.
4. Date checklist prepared: [help]
RESPONSE: December 30, 2019.
5. Agency requesting checklist: [help]
RESPONSE: Jefferson County Board of Commissioners.
6. Proposed timing or schedule (including phasing, if applicable): [help]
RESPONSE: Legislative action anticipated in early 2020.
7. Do you have any plans for future additions, expansion, or further activity related to or
connected with this proposal? If yes, explain. [help]
RESPONSE: Legislative action anticipated in early 2020.
8. List any environmental information you know about that has been prepared or will be
prepared, directly related to this proposal. [help]
RESPONSE: No additional environmental information has been prepared beyond this SEPA
Environmental Checklist. Any future projects under the proposal must comply with all applicable laws
and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article X JCC
(SEPA Implementation).
9. Do you know whether applications are pending for governmental approvals of other
proposals directly affecting the property covered by your proposal? If yes, explain. [help]
RESPONSE: Not applicable to this non-project legislation.
10. List any government approvals or permits that will be needed for your proposal, if known.
[help]
RESPONSE:
a. Public hearing and recommendation from the Jefferson County Planning Commission: Completed
on December 3, 2019.
b. Review by the Washington State Department of Commerce and other agencies, per the Growth
Management Act: To be completed.
c. Adoption by the Jefferson County Board of County Commissioners, after a public hearing and
deliberations: To be completed.
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Environmental checklist (WAC 197-11-960)
January 6, 2020
11. Give brief, complete description of your proposal, including the proposed uses and the size
of the project and site. There are several questions later in this checklist that ask you to
describe certain aspects of your proposal. You do not need to repeat those answers on
this page. (Lead agencies may modify this form to include additional specific information
on project description.) [help]
RESPONSE:
a. Not a Project Proposal: There is no “project” or “site” for this proposal.
b. Description of Legislation: The legislation is a comprehensive set of health and safety regulations
(Title 8 Ordinance) and development regulations (Title 18 Ordinance) that are designed to uniformly
regulate indoor and outdoor commercial shooting facilities (CSFs) within unincorporated Jefferson
County. The Title 8 Ordinance requires an operating permit for existing and new CSFs. The Title 18
Ordinance contains development regulations relating to zoning, siting, compatibility, shoreline, and
critical area impacts for CSFs that do not qualify as a legal nonconforming use under JCC 18.20.260.
Overview of Title 8 Ordinance:
i. Not a development regulation under Chapter 36.70A RCW (Growth Management Act);
ii. Regulates the operation, but not siting or development, of existing and future CSFs;
iii. Requires an operating permit with an operational environmental health and safety plan with
components for operations and safety for all existing and new CSFs;
iv. Requires compliance with environmental Best Management Practices (BMPs) for operation
of CSFs;
v. Requires consistency with the 2012 National Rifle Association Range Source Book (NRA
Range Source Book) for minimizing noise, increasing safety, and increasing environmental
protection during operations of a CSF;
vi. Operating permit to be reviewed by a qualified shooting range evaluator and approved by
the Jefferson County Environmental Health Division of the Department of Public Health; and,
vii. Provides for administrative review of permit decisions under Jefferson County’s Hearing
Examiner Code and Rules of Procedure.
Overview of the Title 18 Ordinance
i. Development regulation under Chapter 36.70A RCW (Growth Management Act);
ii. Regulates siting and development of CSFs that do not qualify for a legal, non-conforming
use under the JCC 18.20.260.
iii. Fixes use loopholes in cottage industry and home business sections clarifying that CSFs
cannot be a cottage industry or home business;
iv. Closes definitional loopholes for Small-Scale Recreation or Tourist Uses standards;
v. Closes an unnamed use loophole by indicating that the text of Table 3-1 and 3A-1 control
and naming shooting facilities as a named use;
vi. Requires for forest resource lands:
A. A Conditional Use Permit (CUP) consistent with Jefferson County’s 12 conditional use
approval criteria;
B. Review by a qualified shooting range evaluator; and,
C. Approval of the CUP by the Jefferson County Department of Community Development;
vii. Adds performance and use standards for the siting and development of CSFs:
A. Requires a facility plan;
B. Requires consistency with the NRA Range Source Book for minimizing noise, increasing
safety, and increasing environmental protection;
C. Requires compliance with environmental operational Best Management Practices
(BMPs); and,
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Environmental checklist (WAC 197-11-960)
January 6, 2020
D. Establishes minimum standards for required security, containment, professional
evaluation, and protection of critical areas and shorelines.
viii. Provides for administrative review of permit decisions under Jefferson County’s Hearing
Examiner Code and Rules of Procedure; and,
ix. Five legislation alternatives are under consideration for Title 18 in this proposal. The five
legislation alternatives are compared to a “no action” alternative below:
A. No action alternative: Under the no-action alternative, the Jefferson County Code in
existence before November 2018 will remain in effect. The pre-November 2018 Jefferson
County Code will be much less protective of human health, safety and the environment
than any of the five legislation alternatives because:
(1) There was no uniform, comprehensive regulatory scheme for CSFs.
(2) “Outdoor shooting ranges” could be permitted with a conditional use permit (CUP)
in forest resource lands as “Small-Scale Recreation or Tourist Uses,” previously
defined as “‘Small-scale recreation or tourist uses’ meaning those isolated uses
which are leisure or recreational in nature; are reliant upon a rural setting or
location; do not include any new residential development beyond that allowed
in the underlying land use district, and otherwise meet the performance
standards in JCC 18.20.350. See RCW 36.70A.070(5)(d)(ii).” JCC 18.20.350
(emphasis added). “Small-scale” was defined as “of a size or intensity which has
minimal impacts on the surrounding area and which makes minimal demands on
the existing infrastructure.” JCC 18.20.350 (emphasis added).
(3) It would have been difficult, if not impossible, to enforce JCC 18.20.350(8) related
to shooting facilities because of missing terms related to the definitions of “small
scale” and “small-scale recreation or tourist uses:”
(a) “Small-scale” used the terms “isolated uses,” “leisure,” and “recreational,”
none of which was defined. See respectively JCC Sections 18.10.090,
18.10.120, and 18.10.180.
(b) Small-scale recreation or tourist uses” used the terms “minimal impacts” and
“minimal demands,” neither of which was defined. See JCC Section
18.10.130.
(4) JCC 18.20.350(8) contained the only regulations related to “outdoor shooting
ranges.” But it would have been difficult, if not impossible, to enforce JCC
18.20.350(8) related to shooting facilities because of missing terms or vague
terms:
(a) “Outdoor shooting ranges” was defined to mean “shooting ranges.” JCC
Section 18.10.150. “Shooting range” was defined as “a facility specifically
designed and used for safe shooting practice with firearms and/or for
archery practice, with individual or group firing positions for specific
weaponry.” See JCC 18.10.190 (emphasis added).
(b) There was no definition of “firearms” (See JCC 18.10.060), even though that
term is used in the definition of “shooting range” in JCC 18.10.190.
(c) There was no definition of “safe shooting practice” (See JCC 18.10.060),
even though that term is used in the definition of “shooting range” in JCC
18.10.190.
(d) There was no definition of “group firing positions” (See JCC 18.10.070), even
though that term is used in the definition of “shooting range” in JCC
18.10.190.
(e) There was no definition of “specific weaponry” (See JCC 18.10.190), even
though that term is used in the definition of “shooting range” in JCC
18.10.190.
(5) JCC 18.20.350(8)(a) required that shooting ranges be “located, designed,
constructed and operated to prevent the likelihood of discharge of ammunition
beyond the boundaries of the parcel where they occur.” (Emphasis added). But
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Environmental checklist (WAC 197-11-960)
January 6, 2020
“ammunition” was nowhere defined. See JCC 18.10.010. And, firearms shoot
bullets or projectiles, not ammunition.
(6) There was reliance on existing laws that:
(a) Require compliance with critical area, shoreline and wetlands buffers;
(b) Limit nuisance noise;
(c) Limit reckless shooting of firearms (RCW 9.36.050 and RCW 9.41.230);
(d) Limit the discharge of a machine gun as that term is defined in 26 U.S.C.
Section 5845(b) or RCW 9.41.010(17);
(e) Limit the discharge of a short-barreled rifle or a short-barreled shotgun as
those terms are defined in RCW 9.41.010; and,
(f) Prohibit discharge of a destructive device as that term is defined in 25 U.S.C.
Section 5845(f) and any explosive as that term is defined in RCW
70.74.010(5).
(7) Compliance with all 12 conditional use approval criteria listed below:
(1) The county may approve or approve with modifications an application for a
conditional use permit (i.e., uses listed in Table 3-1 in JCC 18.15.040 as “C(a),” “C(d)”
or “C”) if all of the following criteria are satisfied:
(a) The conditional use is harmonious and appropriate in design,
character, and appearance with the existing or intended character
and quality of development in the vicinity of the subject property and
with the physical characteristics of the subject property;
(b) The conditional use will be served by adequate infrastructure
including roads, fire protection, water, wastewater disposal, and
stormwater control;
(c) The conditional use will not be materially detrimental to uses or
property in the vicinity of the subject parcel;
(d) The conditional use will not introduce noise, smoke, dust, fumes,
vibrations, odors, or other conditions or which unreasonably impact
existing uses in the vicinity of the subject parcel;
(e) The location, size, and height of buildings, structures, walls and
fences, and screening vegetation for the conditional use will not
unreasonably interfere with allowable development or use of
neighboring properties;
(f) The pedestrian and vehicular traffic associated with the conditional
use will not be hazardous to existing and anticipated traffic in the
vicinity of the subject parcel;
(g) The conditional use complies with all other applicable criteria and
standards of this title and any other applicable provisions of the
Jefferson County Code or state law; and more specifically, conforms
to the standards contained in Chapters 18.20 and 18.30 JCC;
(h) The proposed conditional use will not result in the siting of an
incompatible use adjacent to an airport or airfield;
(i) The conditional use will not cause significant adverse impacts on
the human or natural environments that cannot be mitigated through
conditions of approval;
(j) The conditional use has merit and value for the community as a
whole;
(k) The conditional use is consistent with all relevant goals and
policies of the Jefferson County Comprehensive Plan; and
(l) The public interest suffers no substantial detrimental effect.
Consideration shall be given to the cumulative effect of similar actions
in the area.
(2) In instances where all of the above findings cannot be made, the
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Environmental checklist (WAC 197-11-960)
January 6, 2020
application shall be denied.
JCC 18.40.530 (Exhibit 1) (emphasis added).
(8) If a shooting facility was larger than the vaguely defined Small-Scale Recreation
or Tourist Uses, it could have been classified as an “unnamed use,” which have
been allowed in any zone compliance with the discretionary use criteria listed
below:
(2) Discretionary Uses. Discretionary uses are certain named and all
unnamed uses which may be allowed subject to the applicable
development and performance standards
(Chapters 18.20 and 18.30 JCC) and an administrative review of
potential impacts are designated by a “D” (for “discretionary”). On the
basis of the administrative review, the administrator may classify the
proposed “D” use as either an allowed use, a prohibited use, or a
conditional use in the particular land use district affected.
Discretionary, “D,” uses are subject to a Type II administrative review
as specified in Chapter 18.40 JCC. Decisions classifying “D” uses
made under this section may be appealed to the hearing examiner
(see Chapter 18.40 JCC). The administrator may classify the
discretionary use as an allowed “Yes” use in the particular district
affected, only if the proposed development:
(a) Complies with the applicable development standards of
Chapter 18.30 JCC;
(b) Complies with the performance and use-specific standards unique
to the proposed use specified in Chapter 18.20 JCC;
(c) Is appropriate in design, character, and appearance with the goals
and policies for the land use designation and district in which the
proposed use is located;
(d) Is consistent with the goals and policies of the Comprehensive
Plan and the applicable regulations of the Shoreline Master Program
if the application involves property located within the jurisdiction of the
state Shoreline Management Act, but does not require a shoreline
permit;
(e) Will be served by adequate facilities including access, fire
protection, water, and sewer facilities (municipal, community, or on-
site systems);
(f) Does not include any use or activity that would result in the siting
of an incompatible use adjacent to an airport or airfield
(Chapter 36.70 RCW);
(g) Shall not adversely impact the public health, safety and general
welfare of the residents of the county;
(h) Shares characteristics common with but not of significantly greater
intensity, density or that generates more environmental impact than
those uses allowed in the district in which it is to be located; and
(i) Will not result in impacts on the human or natural environments
determined by the administrator to require review as a conditional
use.
If the preceding conditions are not met to the satisfaction of the
administrator, the administrator may either prohibit the use or require
a conditional use permit.
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January 6, 2020
JCC 18.15.045 (Exhibit 2).
(9) Shooting ranges could have been permitted as part of a cottage industry in all
zones, except resource-based industrial, heavy industrial, and parks, preserves
and recreation zones, pursuant to JCC 18.20.170 (Exhibit 3) and Table 3-1
(Exhibit 4).
(10) Shooting ranges could have been permitted as part of a home business in all
zones, except resource-based industrial, heavy industrial, and parks, preserves
and recreation zones, pursuant to 18.20.200 and Table 3-1 (Exhibit 4).
(11) Shooting ranges could have been permitted on Forest Resource Lands1,
provided there was compliance with the forest resource districts protections, as
follows:
(1) Residential Density. There shall be no subdivision of land
designated commercial forest or rural forest for residential purposes.
However, nothing in this code shall be construed to prevent the owner
of designated commercial or rural forest land from living on his/her
land; provided, that applicable building requirements are met.
(2) Subdivisions and Use Limitations. Subdivision of commercial and
rural forest lands for construction or installation of nonresidential
purposes, as allowed in Table 3-1 in JCC 18.15.040, shall be at least
80 acres in size within the commercial forest designation and 40 acres
in size within the rural forest designation and must meet the following
criteria:
(a) The facility cannot otherwise be suitably located on undesignated
land;
(b) The installation cannot otherwise be accomplished without
subdivision;
(c) The facility is to be located on the lowest feasible grade of forest
land; and
(d) The facility removes as little land as possible from timber
production.
(3) Setback Requirements for Adjacent Development. New structures
proposed to be located on parcels adjacent to designated forest lands
shall:
1 Per Jefferson County Code 18.15.020, “Forest Resource Lands (FOR)” are:
“(a) Commercial Forest (CF-80). The purpose of the commercial forest district is to ensure large tracts of forest lands
of long-term significance are protected from incompatible uses thereby sustaining the ability of forest resource
extraction activities to be maintained as a viable commercial activity.
(b) Rural Forest (RF-40). The purpose of the rural forest district is to ensure forest lands of long-term significance are
protected from incompatible uses thereby sustaining the ability of forest resource extraction activities to be maintained
as a viable commercial activity, while allowing for diversity in the size of forest tracts.
(c) Inholding Forest (IF). This district encompasses parcels at least 20 acres in size that are entirely surrounded by
designated forest resource lands and that are not vested for development under Washington State law.”
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(a) Establish and maintain a minimum 250-foot building setback
adjacent to commercial forest lands and 100 feet adjacent to the rural
forest lands designation, which shall serve as a resource protection
area, as measured from the property boundaries of adjacent forest
lands except as follows:
(i) If the size, shape, and/or physical site constraints of an existing
legal lot do not allow a setback of 250 feet adjacent to commercial
forest lands and 100 feet adjacent to the rural forest lands
designation, then the new structure shall maintain the maximum
setback possible; or
(ii) If the owner of the land on which the new structure is proposed
and the owner of the adjacent forest land each sign and file for record,
in the manner required by law for covenants running with the land, a
document which establishes an alternative setback for one or both of
the properties, a setback of less than 250 feet adjacent to commercial
forest lands and 100 feet adjacent to rural forest lands may be
maintained;
(b) Provide adequate access for fire vehicles; and
(c) If the proposed structure is located within 250 feet of the boundary
of commercial forest lands or within 100 feet of rural forest lands, in
the area where the setback is to be applied, the property owner shall
survey the property boundaries that abut forest land in the area where
the setback is to be applied, locate the property boundaries on the
ground, and submit a record of survey, or other means deemed
acceptable to the administrator, with a building permit application.
(4) Setback Requirements on Designated Forest Lands. Builders of
new structures proposed to be located on parcels designated
commercial, rural, or inholding forest shall:
(a) Establish and maintain a minimum 250-foot setback, which shall
be a resource protection area, from the property boundaries of
adjacent commercial and rural forest lands except as follows:
(i) If the size, shape, and/or physical site constraints of an existing
legal lot do not allow a setback of 250 feet, the new structure shall
maintain the maximum setback possible.
(5) Establishment of Resource Protection Areas. Subdivisions, short
subdivisions and rural cluster subdivisions of parcels adjacent to
forest land shall establish a resource protection area of a minimum
250-foot width along commercial forest land boundaries and 100-foot
width along rural forest and inholding forest land boundaries.
JCC 18.15.150 (Exhibit 3).
(12) No generally accepted environmental best management practices (BMPs) for
operation of shooting ranges were required.
(13) No generally accepted environmental best management practices (BMPs) for
siting and development of shooting ranges were required.
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(14) No express minimum standards for operation of a CSF were required.
(15) No express minimum standards for siting and design of a CSF were required.
(16) No liability insurance requirements for operation of a CSF were required.
(17) No facilities design plan was required.
(18) No safety plan was required.
(19) No operations plan was required.
(20) No environmental plan was required.
(21) No noise abatement plan was required.
(22) No initial inspection was required.
(23) No annual inspection was required.
(24) No professional review of a permit application by a qualified shooting range
evaluator was required.
(25) No compliance certification under oath by the owner or operator was required.
(26) There were no specified consequences for non-compliance with an issued
permit, including no authority to suspend or cancel a permit.
B. Alternative 1:
(1) Allows outdoor CSFs in forest resource lands only with a CUP, subject to the 12
CUP approval criteria in JCC 18.40.530 (Exhibit 1) and the forest resource district
protections in JCC 18.15.150 (Exhibit 3) and Table 3-1 (Exhibit 4).
(2) Allows indoor CSFs with a CUP only in rural/urban growth area (UGA)
commercial and industrial zoning (excluding resource-based industrial zoning),
subject to the 12 CUP approval criteria in JCC 18.40.530.
(3) Continues to rely on existing laws that: (a) Require compliance with critical area,
shoreline and wetlands buffers; (b) Limit nuisance noise; (c) Limit dangerous
shooting of firearms; (d) Limit the types of weapons that can be used; and, (e)
Prohibit the use of any explosive devices.
(4) Fixes the ambiguities identified in the no-action alternative items (2) to (5),
discussed above.
(5) Fixes the loopholes identified in the no-action alternative items (8) to (10),
discussed above.
(6) Adds the protections noted as missing in the no-action alternative items (11) to
(23), including the standards and Best Management Practices described below.
Alternative 1 is legislation passed by the Board of County Commissioners in
2018, namely Ordinance 12-1102-18 adopted on November 2, 2018 (Title 8
Health and Safety Ordinance) (Exhibit 5) and Ordinance No. 15-1214-18 (Title 18
Land Use Ordinance) adopted on December 14, 2018 (Exhibit 6). A SEPA
categorical exemption was relied upon for the Title 8 Ordinance. A Determination
of Non-Significance (DNS) (Exhibit 7) for the Title 18 Ordinance was reviewed by
the Department of Commerce in 2018 and was not challenged. The Growth
Management Hearings Board determined that the Title 8 Ordinance was a
development regulation, requiring compliance with public participation and SEPA
requirements for a development regulation and that the Title 18 Ordinance was
closely related to the Title 8 Ordinance that both were invalid under Chapter
36.70A RCW (the Growth Management Act). Jefferson County has appealed the
Growth Management Board’s decision on the Title 18 Ordinance under Chapter
34.05 RCW (the Administrative Procedure Act).
C. Alternative 2:
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(1) Allows outdoor CSFs in forest resource lands only with a CUP, subject to the 12
CUP approval criteria in JCC 18.40.530 (Exhibit 1) and the forest resource district
protections in JCC 18.15.150 (Exhibit 3) and Table 3-1 (Exhibit 4).
(2) Limits outdoor CSFs to only forest resource lands for projects that qualify as
Small-Scale Recreation or Tourist Uses. Small-Scale Recreation or Tourist Uses
are limited by JCC 18.20.350(3) (Exhibit 8) as follows:
(1) Small-Scale Recreation and Tourist Uses. Small-scale recreational and tourist
uses rely on a rural location and setting and provide opportunities to diversify the
economy of rural Jefferson County by utilizing the county’s abundant recreational
opportunities and scenic and natural amenities in an environmentally sensitive
manner consistent with the rural character of the county. Upon approval pursuant
to this code, these types of uses may be conducted in the land use districts
specified in Table 3-1 in JCC 18.15.040 and as provided for in small-scale
recreation and tourist (SRT) overlay districts under JCC 18.15.470 and
18.15.572. Agritourism on designated agricultural lands is regulated in JCC
18.20.030, agricultural activities and accessory uses. The following list of uses is
not intended to be exhaustive, but rather is intended to be illustrative of the types
of small-scale recreation or tourist uses:
(a) Small-scale recreation or tourist uses may include limited and
commensurately scaled commercial facilities intended to serve those small-scale
recreational or tourist uses (e.g., a gift shop, delicatessen, convenience store, or
associated retail sales and services); provided, that the applicant can
demonstrate the following to the satisfaction of the approving authority that:
(i) The principal demand for the commercial facilities is derived from the principal
recreational or tourist use and not the existing and projected rural population;
(ii) The associated commercial activities shall be clearly accessory to and
dependent upon the primary recreational or tourist uses;
(iii) The associated commercial activities, in addition to the principal recreational
or tourist use, will not have a measurable detrimental traffic, noise, visual or public
safety impact on adjacent properties;
(iv) The use and associated structure is clearly appropriate and compatible in
scale, size, design, and function with surrounding uses and environment;
(v) The use will not constitute new urban development in a rural area;
(vi) The public facilities and services provided are limited to those necessary to
serve the associated commercial activities and the principal small-scale
recreational or tourist use in a manner that does not permit low-density sprawl;
and
(vii) All other applicable requirements and standards in this UDC are met.
(b) Unless a larger parcel size is specified, minimum lot size shall be five acres,
except that no minimum lot size is required for parcels that include a historic site,
structure or landmark.
(c) Only one small-scale recreational or tourist use shall be allowed per legal lot
of record, with the exception of rural restaurants.
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(d) Only those buildings or areas specifically approved by the county may be used
in the conduct of the business.
(e) Parking shall be contained on-site and provided in conformance with this
code, including JCC 18.30.100 and 18.30.130.
(f) All activities shall, at a minimum, be screened from the view of adjacent
residential uses subject to the landscaping and screening requirements of JCC
18.30.130 and set back a sufficient distance from all rear and side property lines
to protect the character of adjacent and surrounding properties and uses. The
approving authority may authorize variations to the setbacks established in Table
6-1 in JCC 18.30.050 to ensure that any small-scale recreation or tourist use or
structure, when proposed in or adjacent to a rural residential (RR) district, shall
be compatible with and not disruptive to the character of existing and anticipated
future uses in the district.
(g) All small-scale recreation or tourist uses shall utilize local access or minor
collector roads for primary access whenever practicable. Access off state routes,
arterials, or major collector roads may be allowed if access improvements or a
traffic analysis assure mobility is not degraded.
(h) Structures shall comply with the landscape, lighting, site coverage, and design
standards set forth in Chapter 18.30 JCC.
(i) Any small-scale recreational or tourist use development allowed under this
section that proposes to include permanent occupancy on-site residential
development may only be permitted subject to:
i. The underlying rural residential density;
ii. A master planned resort (MPR) district designation subject to a legislative
action to amend the Comprehensive Plan; or
iii. That necessary for on-site management (e.g., a caretaker’s residence).
(j) For any small-scale recreation or tourist use, the county shall impose such
reasonable conditions (e.g., location and size restrictions, design standards,
landscape buffers, setbacks, etc.) as are found necessary by the approving
authority to ensure that the activity or use, due to proximity, location or intensity:
i. Is compatible with the rural character of adjacent lands and shorelines,
including forestry, agriculture, and mineral lands of long-term commercial
significance;
ii. Does not disrupt the character of any surrounding permitted uses;
iii. Is adequately served by public facilities and services (including roadway
level of service and minimum fire flow requirements) without the need to
extend those services in a manner that promotes low density sprawl;
iv. Adequately protects critical areas including surface and groundwater
resources; and
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v. Would not cumulatively, in combination with the effects of existing
development (or given the probable development of subsequent projects
with similar effects) in the vicinity (i.e., within one mile) of the proposed use,
create a development pattern that constitutes low density sprawl; require
the extension of public facilities or expansion of public services in a manner
that promotes low density sprawl, or be otherwise incompatible with or
injurious to the rural character of the area;
vi. For designated agricultural lands, converts as little land with prime
agricultural soils as practicable into nonagricultural use.
(k) If the preceding conditions (in subsection (3)(j) of this section) cannot be met
to the satisfaction of the approving authority, the use shall be denied.
(3) Limits outdoor CSFs in forest resource lands with a quota (approximately 150
acres total in the 328,785 acres of forest resource lands throughout the county).
(4) Allows indoor CSFs with a CUP in rural/urban growth area (UGA) commercial
and industrial zoning (excluding resource-based industrial zoning), subject to the
12 CUP approval criteria in JCC 18.40.530.
(7) Continues to rely on existing laws that: (a) Require compliance with critical area,
shoreline and wetlands buffers; (b) Limit nuisance noise; (c) Limit dangerous
shooting of firearms; (d) Limit the types of weapons that can be used; and, (e)
Prohibit the use of any explosive devices.
(8) Fixes the ambiguities identified in the no-action alternative items (2) to (5),
discussed above.
(9) Fixes the loopholes identified in the no-action alternative items (8) to (10),
discussed above.
(10) Adds the protections noted as missing in the no-action alternative items (11) to
(23), including the standards and Best Management Practices described below.
Alternative 2 is legislation recommended to the Jefferson County Planning
Commission by Jefferson County Staff on October 16, 2019.
D. Alternative 3:
(1) Allows outdoor CSFs in forest resource lands only with a CUP, subject to the 12
CUP approval criteria in JCC 18.40.530 (Exhibit 1) and the forest resource district
protections in JCC 18.15.150 (Exhibit 3) and Table 3-1 (Exhibit 4).
(2) Limits outdoor CSFs in forest resource lands for projects that qualify as Small-
Scale Recreation or Tourist Uses. Small-Scale Recreation or Tourist Uses are
limited by JCC 18.20.350(3) (Exhibit 8).
(3) Requires bright-line rules including (a) a limit of one conditional use per parcel;
(b) Prohibiting use of CSFs by military, paramilitary, National Guard, Homeland
Security or non-local law enforcement; (c) Maximum of 5 firing points per parcel;
(d) No shooting from aircraft; (e) No drone or helicopter flights within the parcel;
(f) No machine guns, mortars, rocket launchers, etc.; (g) Noise standard at
property boundaries of a maximum of 40db; or, (h) 500-yard setback from
shorelines (streams and lakes) and additional wetlands/wetland-buffers.
(4) Does not use a quota to limit outdoor CSFs in forest resource lands.
(5) Allows indoor CSFs with a CUP in rural/ UGA commercial and industrial zoning
(excluding resource-based industrial zoning).
(6) Fixes the ambiguities identified in the no-action alternative items (2) to (5),
discussed above.
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(7) Fixes the loopholes identified in the no-action alternative items (8) to (10),
discussed above.
(8) Adds the protections noted as missing in the no-action alternative items (9) to
(23), including the standards and Best Management Practices described below.
Alternative 3 was proposed by members of the public during the public
participation process with the Jefferson County Planning Commission. Jefferson
County Staff does not recommend this alternative because it may not comply with
constitutional requirements, including under the Second Amendment to the U.S.
Constitution.
E. Alternative 4:
(1) Prohibits outdoor CSFs in all zoning districts.
(2) Indoor CSFs allowed only as a discretionary use (without additional bright-line
rules) in all rural/UGA commercial and industrial zoning (excluding resource-
based industrial zoning).
(3) Defines “Indoor shooting facility” to include “lawful incidental sales of firearms,
ammunition, component parts, and accessories.”
(4) Fixes the ambiguities identified in the no-action alternative items (2) to (5),
discussed above.
(5) Fixes the loopholes identified in the no-action alternative items (8) to (10),
discussed above.
(6) Adds the protections noted as missing in the no-action alternative items (11) to
(23), including the standards and Best Management Practices described below.
Alternative 4 is the December 3, 2019 recommendation of the Jefferson County
Planning Commission to the Board of County Commissioners, made after
conducting a public hearing as part of the public participation process.
F. Alternative 5:
(1) Prohibits outdoor CSFs.
(2) Allows indoor CSFs allowed as a discretionary use in all rural/UGA commercial
and industrial zoning (excluding resource-based industrial zoning).
(3) Allows indoor CSFs in forest resource lands only with a CUP, subject to the 12
CUP approval criteria in JCC 18.40.530 (Exhibit 1) and the forest resource district
protections in JCC 18.15.150 (Exhibit 3) and Table 3-1 (Exhibit 4).
(4) Limits indoor CSFs in forest resource lands for projects that qualify as Small-
Scale Recreation or Tourist Uses. Small-Scale Recreation or Tourist Uses are
limited by JCC 18.20.350(3) (Exhibit 8)
(5) Limits indoor CSFs in forest resource lands with a quota (approximately 150
acres total in the 328,785 acres of forest resource lands throughout the county).
(6) Defines “Indoor shooting facility” to include “lawful incidental sales of firearms,
ammunition, component parts, and accessories.”
(7) Fixes the ambiguities identified in the no-action alternative items (2) to (5),
discussed above.
(8) Fixes the loopholes identified in the no-action alternative items (8) to (10),
discussed above.
(9) Adds the protections noted as missing in the no-action alternative items (11) to
(23), including the standards and Best Management Practices described below.
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Alternative 5 is proposed as potentially necessary to ensure compliance with
constitutional requirements, including under the Second Amendment to the U.S.
Constitution.
G. Environmental, Health, Noise and Safety Standards or Best Management
Practices Added:
(1) Operations—Title 8 Ordinance for Alternatives 1 through 5:
(a) Requires a safety and environmental health plan for operations at a CSF;
(b) Requires operations BMPs for the collection and disposal of bullets,
cartridges, and shotgun wadding;
(c) Requires operations BMPs for lead at outdoor CSFs as recommended by
USEPA Region 2 in its 2005 publication entitled Best Management Practices
for Outdoor Shooting Ranges, as it exists now or later is amended;
(d) Requires operations BMPs for lead at indoor CSFs as recommended by the
National Institute for Occupational Safety and Health (NIOSH) in its 2009
publication entitled NIOSH Alert – Preventing Exposures to Lead and Noise
at Indoor Firing Ranges, as it exists now or later is amended;
(e) Requires an operations plan for compliance with requirements under existing
law for the handling and closure of facilities for storage or use of the
hazardous substance or hazardous waste other than lead;
(f) Requires an operations plan for financial assurance consistent with existing
law for addressing any remediation of hazardous substances or hazardous
waste, other than lead resulting from operations at a CSF;
(g) Requires BMPs to maximize sound suppression for operations consistent
with the NRA Range Source Book and Chapter 8.70 JCC (noise control);
(h) Requires that operations not create a public nuisance;
(i) Contains enforcement procedures;
(j) Requires that the owner or operator maintain comprehensive general liability
insurance coverage, with a minimum coverage amount of one million dollars
for each occurrence and combined single limit and two million in the
aggregate during operation of the CSF;
(k) Requires an annual report with a current statement of general liability
insurance and any monitoring data required by an operating permit; and,
(l) Requires pre-operation, annual, and compliance inspections.
(2) Siting and Development—Title 18 Ordinance—All Alternatives:
(a) Limits the zones where a CSF can be located by, among other things,
prohibiting CSFs as part of a home business use, as part of a cottage industry
use, or as an unnamed use.
(b) Requires that all CSFs be designed to be consistent with the NRA Range
Source Book standards for shooting range design;
(c) Requires that all CSFs be designed so that when firearms are operating in
accordance with the new definition of rules and regulations (“with reference
to a CSF means requirements used for the safe operation of a CSF”), all
projectiles are kept from leaving any shooting range or the CSF;
(d) Requires a facilities plan that describes the locations of all hazardous material
storage and use, per a hazardous substance or hazardous waste
management plan, if needed;
(e) Requires that all CSFs comply with every applicable provision of the JCC
related to protection of critical areas and shorelines (and buffers for all such
areas, including but not limited to the buffers required in Chapter 18.22 JCC
(Critical Areas) and Chapter 18.25 JCC (Shoreline Master Program).
(3) Siting and Development—Title 18 Ordinance—Alternatives 1, 2, 3, and 5 (in
addition to those in Item (2)):
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(a) Allows CSFs in forest resource lands with a CUP, subject to the 12 CUP
approval criteria in JCC 18.40.530.
(b) Limits CSFs in forest resource lands to projects that qualify as Small-Scale
Recreation or Tourist Uses.
(4) Siting and Development—Title 18 Ordinance—Alternatives 1, 2, and 5 (in
addition to those in Items (2) and (3):
(a) Limits CSFs in forest resource lands with a quota (approximately 150 acres
total in the 328,785 acres of forest resource lands throughout the county).
(5) Siting and Development—Title 18 Ordinance—Alternatives 4 and 5 only:
(a) Prohibits outdoor CSFs, except for those with that qualify for as a legal
nonconforming use under JCC 18.20.260.
This SEPA Environmental Checklist discusses all of the alternatives listed above. All alternatives or a
combination of them are actively being considered under this proposal. However, Alternative 2 and
Alternative 4 are the drafted versions of the proposal. Alternative 2 is the initial staff recommendation to the
Jefferson County Planning Commission and Alternative 4 is the Jefferson County Planning Commission
recommendation to the Board of County Commissioners. For the purposes of this Environmental Checklist,
all alternatives are considered part of the proposal.
12. Location of the proposal. Give sufficient information for a person to understand the precise
location of your proposed project, including a street address if any, and section, township,
and range, if known. If a proposal would occur over a range of area, provide the range or
boundaries of the site(s). Provide a legal description, site plan, vicinity map, and
topographic map, if reasonably available. While you should submit any plans required by
the agency, you are not required to duplicate maps or detailed plans submitted with any
permit applications related to this checklist. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This proposal is a non-
project proposal for legislation that amends the Jefferson County Code.
B. Area of Proposal: The Jefferson County Code applies in all unincorporated areas of Jefferson
County. The only incorporated area in Jefferson County is the City of Port Townsend.
C. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief & Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and 18.30
JCC for development and performance standards. For all future projects JCC 18.40.530 with the
12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria (Exhibit
2) will apply.
D. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief & Complete Discussion in response to Question A.11, above.
B. ENVIRONMENTAL ELEMENTS [help]
1. Earth [help]
a. General description of the site: [help]
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(circle one): Flat, rolling, hilly, steep slopes, mountainous, other
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
ii. Site Description: A site for a project will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief & Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and
Chapter 18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC
(Shoreline Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide
substantive development standards that control siting and mitigate impacts. Chapters 18.15,
18.20 and 18.30 JCC for development and performance standards. For all future projects
JCC 18.40.530 with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the
discretionary use criteria (Exhibit 2) will apply.
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
b. What is the steepest slope on the site (approximate percent slope)? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the JCC.
ii. Steepest Slope: Slope angle will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and
Chapter 18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC
(Shoreline Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide
substantive development standards that control siting and mitigate impacts. Chapters 18.15,
18.20 and 18.30 JCC for development and performance standards. For all future projects
JCC 18.40.530 with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the
discretionary use criteria (Exhibit 2) will apply.
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
c. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If you
know the classification of agricultural soils, specify them, and note any agricultural land of long-term
commercial significance and whether the proposal results in removing any of these soils. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
ii. Types of Soils: Types of soils will be discussed future project-level SEPA checklist.
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iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief & Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and
18.30 JCC for development and performance standards. For all future projects JCC 18.40.530
with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria
(Exhibit 2) will apply.
v. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
ii. Unstable Soils in Vicinity: Unstable soils in the immediate vicinity on a site will be discussed in
a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.10, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and
18.30 JCC for development and performance standards. For all future projects JCC 18.40.530
with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria
(Exhibit 2) will apply.
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
e. Describe the purpose, type, total area, and approximate quantities and total affected area of any filling,
excavation, and grading proposed. Indicate source of fill. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
ii. Filling, Excavation, And Grading: Filling, excavation, and grading on a site will be discussed in
a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.10, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and
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18.30 JCC for development and performance standards. For all future projects JCC 18.40.530
with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria
(Exhibit 2) will apply.
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection of Surface Water at the Project Level: If work on any future project is within 200 feet
of waters of the state, either Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22
JCC (Critical Areas Ordinance) will provide substantive development standards that control
siting and mitigate impacts. In particular, JCC 18.25.320(2)(d) prohibits discharging solid
wastes, liquid wastes, and untreated effluents to any groundwater or surface water or to be
discharged onto land. In addition, all future project applications must be evaluated independently
under JCC 18.30.070 that requires compliance with the Department of Ecology’s Stormwater
Management Manual for Western Washington.
vi. Protection for Filling and Excavation at the Project Level. Protection standards for filling and
excavation are contained in JCC 18.25.370.
vii. Protection for Drainage and Erosion Control at the Project Level: Protection standards, including
drainage and erosion control are contained in JCC 18.22.160 and 18.22.170 for geologically
hazardous areas, JCC 18.25.320 for shorelines, JCC 18.22.270 for fish, wildlife habitat
conservation areas, JCC 18.22.330 for wetlands, JCC 18.25.370 for filling and excavation, and
JCC 18.30.060 provides for grading and excavation.
f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
ii. Erosion as a Result of Clearing, Construction, or Use: Potential erosion as a result of clearing,
construction, or use of a site will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and
Chapter 18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC
(Shoreline Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide
substantive development standards that control siting and mitigate impacts. Chapters 18.15,
18.20 and 18.30 JCC for development and performance standards. For all future projects JCC
18.40.530 with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the
discretionary use criteria (Exhibit 2) will apply.
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection for Filling and Excavation at the Project Level. Protection standards for filling and
excavation are contained in JCC 18.25.370.
i. Protection for Drainage and Erosion Control at the Project Level: Protection standards,
including drainage and erosion control are contained in JCC 18.22.160 and 18.22.170 for
geologically hazardous areas, JCC 18.25.320 for shorelines, JCC 18.22.270 for fish, wildlife
habitat conservation areas, JCC 18.22.330 for wetlands, JCC 18.25.370 for filling and
excavation, and JCC 18.30.060 provides for grading and excavation.
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g. About what percent of the site will be covered with impervious surfaces after project construction (for
example, asphalt or buildings)? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
ii. Percentage of Impervious Surfaces After Project Construction: Percentage of impervious
surfaces after project construction will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and
Chapter 18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC
(Shoreline Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide
substantive development standards that control siting and mitigate impacts. Chapters 18.15,
18.20 and 18.30 JCC for development and performance standards. For all future projects
JCC 18.40.530 with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the
discretionary use criteria (Exhibit 2) will apply.
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Regulations on Impervious Surfaces at the Project Level: JCC 18.30.050 and JCC
18.30.070(5) contain impervious surface regulations.
h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal.
ii. Proposed Measures to Reduce or Control Erosion or Other Impacts to the Earth: Proposed
measures to reduce or control erosion, or other impacts to the earth will be discussed in a future
project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and
18.30 JCC for development and performance standards. For all future projects JCC 18.40.530
with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria
(Exhibit 2) will apply.
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection of Surface Water at the Project Level: If work on any future project is within 200 feet
of waters of the state, either Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22
JCC (Critical Areas Ordinance) will provide substantive development standards that control
siting and mitigate impacts. In particular, JCC 18.25.320(2)(d) prohibits discharging solid
wastes, liquid wastes, and untreated effluents to any groundwater or surface water or to be
discharged onto land. In addition, all future project applications must be evaluated independently
Page 20 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
under JCC 18.30.070 that requires compliance with the Department of Ecology’s Stormwater
Management Manual for Western Washington.
vi. Protection for Filling and Excavation at the Project Level. Protection standards for filling and
excavation are contained in JCC 18.25.370.
i. Protection for Drainage and Erosion Control at the Project Level: Protection standards, including
drainage and erosion control are contained in JCC 18.22.160 and 18.22.170 for geologically
hazardous areas, JCC 18.25.320 for shorelines, JCC 18.22.270 for fish, wildlife habitat
conservation areas, JCC 18.22.330 for wetlands, JCC 18.25.370 for filling and excavation, and
JCC 18.30.060 provides for grading and excavation.
2. Air [help]
a. What types of emissions to the air would result from the proposal during construction, operation, and
maintenance when the project is completed? If any, generally describe and give approximate quantities
if known. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
ii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and
18.30 JCC for development and performance standards. For all future projects JCC 18.40.530
with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria
(Exhibit 2) will apply.
iii. Relevant Conditional Use Approval Criteria that Must be Applied at the Project Level: For future
CSF projects subject to the conditional use approval criteria, including JCC 18.40.530(1)(d) that
requires: “The conditional use will not introduce noise, smoke, dust, fumes, vibrations, odors, or
other conditions or which unreasonably impact existing uses in the vicinity of the subject parcel.”
(Emphasis added.)
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Additional Protection of Outdoor Air Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead dust ingestion by
animals or humans. However, a future project applicant is required to comply with USEPA
Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9). The
BMPs require that the CSF control and contain the lead dust, that they prevent migration, that
they remove and recycle the lead, and that they document activities and keep records.
vi. Additional Protection of Indoor Air Required by the Proposal at the Project Level: If an alternative
is selected which allows indoor CSFs there is a risk of lead and other chemical exposure to
humans through the indoor air. However, Title 8 will require all new indoor CSFs to comply with
BMPs as recommended by the National Institute for Occupational Safety and Health (NIOSH)
in its 2009 publication entitled NIOSH Alert – Preventing Exposures to Lead and Noise at Indoor
Firing Ranges (Exhibit 10). This includes heating ventilation and air condition (HVAC) systems
to filter lead and other chemicals from the air.
Page 21 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally
describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal, so it is not possible to discuss
“off-site” sources of emissions or odor that may affect the proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline Master Program)
or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive development standards
that control siting and mitigate impacts. Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. For all future projects JCC 18.40.530 with the 12 CUP approval criteria
(Exhibit 1) or JCC 18.15.045 with the discretionary use criteria (Exhibit 2) will apply.
iii. Relevant Conditional Use Approval Criteria that Must be Applied at the Project Level: For future CSF
projects subject to the conditional use approval criteria, including JCC 18.40.530(1)(d) that requires:
“The conditional use will not introduce noise, smoke, dust, fumes, vibrations, odors, or other
conditions or which unreasonably impact existing uses in the vicinity of the subject parcel.”
(Emphasis added.)
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for human
health and the environment for Alternatives 1 through 5, compared to the no-action alternative, in the
form of BMPs or standards specific to future CSF projects are described in detail in the Brief &
Complete Discussion in response to Question A.11, above.
v. Additional Protection of Outdoor Air Required by the Proposal at the Project Level: If an alternative
is selected which allows outdoor CSF, there is a possibility of lead dust ingestion by animals or
humans. However, a future project applicant is required to comply with USEPA Region 2 Best
Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9). The BMPs require that the
CSF control and contain the lead dust, that they prevent migration, that they remove and recycle the
lead, and that they document activities and keep records.
vi. Additional Protection of Indoor Air Required by the Proposal at the Project Level: If an alternative is
selected which allows indoor CSFs there is a risk of lead and other chemical exposure to humans
through the indoor air. However, Title 8 will require all new indoor CSFs to comply with BMPs as
recommended by the National Institute for Occupational Safety and Health (NIOSH) in its 2009
publication entitled NIOSH Alert – Preventing Exposures to Lead and Noise at Indoor Firing Ranges
(Exhibit 10). This includes heating ventilation and air condition (HVAC) systems to filter lead and
other chemicals from the air.
c. Proposed measures to reduce or control emissions or other impacts to air, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” and no “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
ii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and 18.30
JCC for development and performance standards. For all future projects JCC 18.40.530 with the
Page 22 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria (Exhibit
2) will apply.
iii. Relevant Conditional Use Approval Criteria that Must be Applied at the Project Level: For future
CSF projects subject to the conditional use approval criteria, including JCC 18.40.530(1)(d) that
requires: “The conditional use will not introduce noise, smoke, dust, fumes, vibrations, odors, or
other conditions or which unreasonably impact existing uses in the vicinity of the subject parcel.”
(Emphasis added.)
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Additional Protection of Outdoor Air Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead dust ingestion by
animals or humans. However, a future project applicant is required to comply with USEPA
Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9). The
BMPs require that the CSF control and contain the lead dust, that they prevent migration, that
they remove and recycle the lead, and that they document activities and keep records.
vi. Additional Protection of Indoor Air Required by the Proposal at the Project Level: If an alternative
is selected which allows indoor CSFs there is a risk of lead and other chemical exposure to
humans through the indoor air. However, Title 8 will require all new indoor CSFs to comply with
BMPs as recommended by the National Institute for Occupational Safety and Health (NIOSH) in
its 2009 publication entitled NIOSH Alert – Preventing Exposures to Lead and Noise at Indoor
Firing Ranges (Exhibit 10). This includes heating ventilation and air condition (HVAC) systems
to filter lead and other chemicals from the air.
3. Water [help]
a. Surface Water:
1) Is there any surface water body on or in the immediate vicinity of the site (including year-round and
seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If
appropriate, state what stream or river it flows into. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief & Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and 18.30
JCC for development and performance standards. For all future projects JCC 18.40.530 with the
12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria (Exhibit
2) will apply.
A. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
B. Protection of Surface Water at the Project Level: If work on any future project is within 200 feet
of waters of the state, either Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22
JCC (Critical Areas Ordinance) will provide substantive development standards that control siting
and mitigate impacts. In particular, JCC 18.25.320(2)(d) prohibits discharging solid wastes, liquid
Page 23 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
wastes, and untreated effluents to any groundwater or surface water or to be discharged onto
land. In addition, all future project applications must be evaluated independently under JCC
18.30.070 that requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington.
C. Protection for Filling and Excavation at the Project Level. Protection standards for filling and
excavation are contained in JCC 18.25.370.
A. Protection for Drainage and Erosion Control at the Project Level: Protection standards, including
drainage and erosion control are contained in JCC 18.22.160 and 18.22.170 for geologically
hazardous areas, JCC 18.25.320 for shorelines, JCC 18.22.270 for fish, wildlife habitat
conservation areas, JCC 18.22.330 for wetlands, JCC 18.25.370 for filling and excavation, and
JCC 18.30.060 provides for grading and excavation.
B. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “For any small-scale recreation or tourist use, the county shall impose
such reasonable conditions (e.g., location and size restrictions, design standards, landscape
buffers, setbacks, etc.) as are found necessary by the approving authority to ensure that the
activity or use, due to proximity, location or intensity: … (iv) Adequately protects critical areas
including surface and groundwater resources …” (Emphasis added.) JCC 18.20.350(3)(a)(v)
requires that the applicant demonstrate to the satisfaction of the approving authority that: “If the
preceding conditions (in subsection (3)(j) of this section) cannot be met to the satisfaction of the
approving authority, the use shall be denied.”
C. Additional Protection of Surface Water Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead discharge through
stormwater runoff into surface waters (if the proposal is close enough to surface waters) or
ingestion by animals or humans. However, a future project applicant is required to comply with
USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9).
The BMPs require that the CSF control and contain the lead, that they prevent migration, that
they remove and recycle the lead, and that they document activities and keep records.
2) Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If
yes, please describe and attach available plans. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and 18.30
JCC for development and performance standards. For all future projects JCC 18.40.530 with the
12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria (Exhibit
2) will apply.
C. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
D. Protection of Surface Water at the Project Level: If work on any future project is within 200 feet
of waters of the state, either Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22
JCC (Critical Areas Ordinance) will provide substantive development standards that control siting
Page 24 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
and mitigate impacts. In particular, JCC 18.25.320(2)(d) prohibits discharging solid wastes, liquid
wastes, and untreated effluents to any groundwater or surface water or to be discharged onto
land. In addition, all future project applications must be evaluated independently under JCC
18.30.070 that requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington.
E. Protection for Filling and Excavation at the Project Level. Protection standards for filling and
excavation are contained in JCC 18.25.370.
F. Protection for Drainage and Erosion Control at the Project Level: Protection standards, including
drainage and erosion control are contained in JCC 18.22.160 and 18.22.170 for geologically
hazardous areas, JCC 18.25.320 for shorelines, JCC 18.22.270 for fish, wildlife habitat
conservation areas, JCC 18.22.330 for wetlands, JCC 18.25.370 for filling and excavation, and
JCC 18.30.060 provides for grading and excavation.
G. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “For any small-scale recreation or tourist use, the county shall impose
such reasonable conditions (e.g., location and size restrictions, design standards, landscape
buffers, setbacks, etc.) as are found necessary by the approving authority to ensure that the
activity or use, due to proximity, location or intensity: … (iv) Adequately protects critical areas
including surface and groundwater resources …” (Emphasis added.) JCC 18.20.350(3)(a)(v)
requires that the applicant demonstrate to the satisfaction of the approving authority that: “If the
preceding conditions (in subsection (3)(j) of this section) cannot be met to the satisfaction of the
approving authority, the use shall be denied.”
H. Additional Protection of Surface Water Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead discharge through
stormwater runoff into surface waters (if the proposal is close enough to surface waters) or
ingestion by animals or humans. However, a future project applicant is required to comply with
USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9).
The BMPs require that the CSF control and contain the lead, that they prevent migration, that
they remove and recycle the lead, and that they document activities and keep records.
3) Estimate the amount of fill and dredge material that would be placed in or removed from surface
water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill
material. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and 18.30
JCC for development and performance standards. For all future projects JCC 18.40.530 with the
12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria (Exhibit
2) will apply.
C. Relevant Conditional Use Approval Criteria that Must be Applied at the Project Level For future
CSF projects subject to the conditional use approval criteria, including JCC 18.40.530(1)(b) that
requires: “The conditional use will be served by adequate infrastructure including roads, fire
protection, water, wastewater disposal, and stormwater control.” (Emphasis added.)
Page 25 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
D. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
E. Protection for Dredging at the Project Level. Protection standards for filling and excavation are
contained in JCC 18.25.360.
F. Protection for Filling and Excavation at the Project Level. Protection standards for filling and
excavation are contained in JCC 18.25.370.
G. Protection for Drainage and Erosion Control at the Project Level: Protection standards, including
drainage and erosion control are contained in JCC 18.22.160 and 18.22.170 for geologically
hazardous areas, JCC 18.25.320 for shorelines, JCC 18.22.270 for fish, wildlife habitat
conservation areas, JCC 18.22.330 for wetlands, JCC 18.25.370 for filling and excavation, and
JCC 18.30.060 provides for grading and excavation.
H. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “For any small-scale recreation or tourist use, the county shall impose
such reasonable conditions (e.g., location and size restrictions, design standards, landscape
buffers, setbacks, etc.) as are found necessary by the approving authority to ensure that the
activity or use, due to proximity, location or intensity: … (iv) Adequately protects critical areas
including surface and groundwater resources …” (Emphasis added.) JCC 18.20.350(3)(a)(v)
requires that the applicant demonstrate to the satisfaction of the approving authority that: “If the
preceding conditions (in subsection (3)(j) of this section) cannot be met to the satisfaction of the
approving authority, the use shall be denied.”
4) Will the proposal require surface water withdrawals or diversions? Give general description,
purpose, and approximate quantities if known. [help]
RESPONSE:
A. No Surface Water Withdrawals or Diversions Required: The proposal does not require surface
water withdrawals or diversions.
B. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
C. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and 18.30
JCC for development and performance standards. For all future projects JCC 18.40.530 with the
12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria (Exhibit
2) will apply.
D. Relevant Conditional Use Approval Criteria that Must be Applied at the Project Level For future
CSF projects subject to the conditional use approval criteria, including JCC 18.40.530(1)(b) that
requires: “The conditional use will be served by adequate infrastructure including roads, fire
protection, water, wastewater disposal, and stormwater control.” (Emphasis added.)
E. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
F. Protection Related to Surface Water Withdrawals or Diversions at the Project Level: JCC
18.25.390 provides protection standards for surface water withdrawals and diversion structures.
Page 26 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
Future projects that are required to be Small Scale Tourist or Recreational Uses, must
adequately protect critical areas including surface and groundwater resources. JCC
18.20.350(3)(j)(iv).
G. Protection of Surface Water at the Project Level: If work on any future project is within 200 feet
of waters of the state, either Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22
JCC (Critical Areas Ordinance) will provide substantive development standards that control siting
and mitigate impacts. In particular, JCC 18.25.320(2)(d) prohibits discharging solid wastes, liquid
wastes and untreated effluents to any groundwater or surface water or to be discharged onto
land. In addition, all future project applications must be evaluated independently under JCC
18.30.070 that requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington.
H. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “For any small-scale recreation or tourist use, the county shall impose
such reasonable conditions (e.g., location and size restrictions, design standards, landscape
buffers, setbacks, etc.) as are found necessary by the approving authority to ensure that the
activity or use, due to proximity, location or intensity: … (iv) Adequately protects critical areas
including surface and groundwater resources …” (Emphasis added.) JCC 18.20.350(3)(a)(v)
requires that the applicant demonstrate to the satisfaction of the approving authority that: “If the
preceding conditions (in subsection (3)(j) of this section) cannot be met to the satisfaction of the
approving authority, the use shall be denied.”
5) Does the proposal lie within a 100-year floodplain? If so, note location on the site plan. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and 18.30
JCC for development and performance standards. For all future projects JCC 18.40.530 with the
12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria (Exhibit
2) will apply.
C. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
D. Protection Related to 100-year Floodplain at the Project Level: If any new CSF proposal is within
a 100-year floodplain, Chapter 15.15 JCC (Flood Protection) will apply.
6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the
type of waste and anticipated volume of discharge. [help]
RESPONSE:
A. No Discharges of Waste Materials to Surface Waters: The proposal does not involve any
discharges of waste materials to surface waters.
Page 27 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
B. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
C. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and
18.30 JCC for development and performance standards. For all future projects JCC 18.40.530
with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria
(Exhibit 2) will apply.
D. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
E. Protection of Surface Water at the Project Level: If work on any future project is within 200 feet
of waters of the state, either Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22
JCC (Critical Areas Ordinance) will provide substantive development standards that control
siting and mitigate impacts. In particular, JCC 18.25.320(2)(d) prohibits discharging solid
wastes, liquid wastes, and untreated effluents to any groundwater or surface water or to be
discharged onto land. In addition, all future project applications must be evaluated
independently under JCC 18.30.070 that requires compliance with the Department of
Ecology’s Stormwater Management Manual for Western Washington.
F. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist
approval criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction
of the approving authority that: “For any small-scale recreation or tourist use, the county shall
impose such reasonable conditions (e.g., location and size restrictions, design standards,
landscape buffers, setbacks, etc.) as are found necessary by the approving authority to ensure
that the activity or use, due to proximity, location or intensity: … (iv) Adequately protects critical
areas including surface and groundwater resources …” (Emphasis added.) JCC
18.20.350(3)(a)(v) requires that the applicant demonstrate to the satisfaction of the approving
authority that: “If the preceding conditions (in subsection (3)(j) of this section) cannot be met to
the satisfaction of the approving authority, the use shall be denied.”
G. Additional Protection of Surface Water Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead discharge through
stormwater runoff into surface waters (if the proposal is close enough to surface waters) or
ingestion by animals or humans. However, a future project applicant is required to comply with
USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit
9). The BMPs require that the CSF control and contain the lead, that they prevent migration,
that they remove and recycle the lead, and that they document activities and keep records.
b. Ground Water:
1) Will groundwater be withdrawn from a well for drinking water or other purposes? If so, give a
general description of the well, proposed uses and approximate quantities withdrawn from the well.
Will water be discharged to groundwater? Give general description, purpose, and approximate
quantities if known. [help]
RESPONSE:
i. No Groundwater Withdrawal: The proposal does not include withdrawing groundwater from a
well.
Page 28 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
ii. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). Specifically, either Chapter 18.25 JCC (Shoreline
Master Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Chapters 18.15, 18.20 and
18.30 JCC for development and performance standards. For all future projects JCC 18.40.530
with the 12 CUP approval criteria (Exhibit 1) or JCC 18.15.045 with the discretionary use criteria
(Exhibit 2) will apply.
iv. Additional Protections for CSF Projects in Alternatives 1 through 5: Additional protections for
human health and the environment for Alternatives 1 through 5, compared to the no-action
alternative, in the form of BMPs or standards specific to future CSF projects are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection of Groundwater at the Project Level: JCC 18.25.320(2)(d) prohibits discharging solid
wastes, liquid wastes and untreated effluents to any groundwater or surface water or to be
discharged onto land. All future project applications must be evaluated independently under
JCC 18.30.070 that requires compliance with the Department of Ecology’s Stormwater
Management Manual for Western Washington. JCC 18.22.130 provides protection standards
for groundwater in susceptible aquifer recharge and special aquifer protection areas. JCC
18.30.060(1)(a) requires all grading and clearing activities to be conducted so as to minimize
potential adverse effects of these activities on forested lands, surface water quality and
quantity, groundwater recharge, and fish and wildlife habitat, adjacent properties, and
downstream drainage channels. If work on any future project is within 200 feet of waters of the
state, either Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22 JCC (Critical
Areas Ordinance) will provide substantive development standards that control siting and
mitigate impacts. Future projects that are required to be Small Scale Tourist or Recreational
Uses, must adequately protect critical areas including surface and groundwater resources.
JCC 18.20.350(3)(j)(iv).
vi. Protection of Water Supply at the Project Level: JCC 18.30.030 provides protection standards
for water supply.
vii. Protection for Sewage Disposal at the Project Level: JCC 18.30.040 and 18.30.080 provide
protection standards for sewage disposal. Specifically, Jefferson County Code 18.30.040(1)
requires that: “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.”
viii. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist
approval criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction
of the approving authority that: “For any small-scale recreation or tourist use, the county shall
impose such reasonable conditions (e.g., location and size restrictions, design standards,
landscape buffers, setbacks, etc.) as are found necessary by the approving authority to ensure
that the activity or use, due to proximity, location or intensity: … (iv) Adequately protects critical
areas including surface and groundwater resources …” (Emphasis added.) JCC
18.20.350(3)(a)(v) requires that the applicant demonstrate to the satisfaction of the approving
authority that: “If the preceding conditions (in subsection (3)(j) of this section) cannot be met to
the satisfaction of the approving authority, the use shall be denied.”
2) Describe waste material that will be discharged into the ground from septic tanks or other sources,
if any (for example: Domestic sewage; industrial, containing the following chemicals. . . ;
agricultural; etc.). Describe the general size of the system, the number of such systems, the
Page 29 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
number of houses to be served (if applicable), or the number of animals or humans the system(s)
are expected to serve. [help]
RESPONSE:
A. No Waste Material Discharged into the Ground from Septic Tanks or Other Sources: This
proposal does not include waste material that will be discharged into the ground from septic
tanks or other sources.
B. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
C. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for
development and performance standards. See also JCC 18.40.530 for the 12 CUP approval
criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
D. Additional Protections in Alternatives 1 through 5: Additional protections for human health and
the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11, above.
E. Protection of Groundwater at the Project Level: JCC 18.25.320(2)(d) prohibits discharging solid
wastes, liquid wastes and untreated effluents to any groundwater or surface water or to be
discharged onto land. All future project applications must be evaluated independently under
JCC 18.30.070 that requires compliance with the Department of Ecology’s Stormwater
Management Manual for Western Washington. JCC 18.22.130 provides protection standards
for groundwater in susceptible aquifer recharge and special aquifer protection areas. JCC
18.30.060(1)(a) requires all grading and clearing activities to be conducted so as to minimize
potential adverse effects of these activities on forested lands, surface water quality and
quantity, groundwater recharge, and fish and wildlife habitat, adjacent properties, and
downstream drainage channels. If work on any future project is within 200 feet of waters of the
state, either Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22 JCC (Critical
Areas Ordinance) will provide substantive development standards that control siting and
mitigate impacts. Future projects that are required to be Small Scale Tourist or Recreational
Uses, must adequately protect critical areas including surface and groundwater resources.
JCC 18.20.350(3)(j)(iv).
F. Protection of Water Supply at the Project Level: JCC 18.30.030 provides protection standards
for water supply.
G. Protection for Sewage Disposal at the Project Level: JCC 18.30.040 and 18.30.080 provide
protection standards for sewage disposal. Specifically, Jefferson County Code 18.30.040(1)
requires that: “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.”
H. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist
approval criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction
of the approving authority that: “For any small-scale recreation or tourist use, the county shall
impose such reasonable conditions (e.g., location and size restrictions, design standards,
landscape buffers, setbacks, etc.) as are found necessary by the approving authority to ensure
that the activity or use, due to proximity, location or intensity: … (iv) Adequately protects critical
areas including surface and groundwater resources …” (Emphasis added.) JCC
18.20.350(3)(a)(v) requires that the applicant demonstrate to the satisfaction of the approving
authority that: “If the preceding conditions (in subsection (3)(j) of this section) cannot be met to
the satisfaction of the approving authority, the use shall be denied.”
Page 30 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
c. Water runoff (including stormwater):
1) Describe the source of runoff (including stormwater) and method of collection and disposal, if any
(include quantities, if known). Where will this water flow? Will this water flow into other waters? If
so, describe. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11,
above, including the no-action alternative, each new CSF project proposal must comply
with all applicable laws and regulations, including SEPA and its implementing regulations,
and Chapter 18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and
18.30 JCC for development and performance standards. See also JCC 18.40.530 for the
12 CUP approval criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria
(Exhibit 2).
C. Relevant Conditional Use Approval Criteria that Must be Applied at the Project Level For
future CSF projects subject to the conditional use approval criteria, including JCC
18.40.530(1)(b) that requires: “The conditional use will be served by adequate
infrastructure including roads, fire protection, water, wastewater disposal, and stormwater
control.” (Emphasis added.)
D. Additional Protections in Alternatives 1 through 5: Additional protections for human health
and the environment for Alternatives 1 through 5, compared to the no-action alternative,
are described in detail in the Brief and Complete Discussion in response to Question A.11,
above.
E. Protection of Surface Water at the Project Level: JCC 18.25.320(2)(d) prohibits discharging
solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water or
to be discharged onto land. All future project applications must be evaluated independently
under JCC 18.30.070 that requires compliance with the Department of Ecology’s
Stormwater Management Manual for Western Washington. JCC 18.30.060(1)(a) requires
all grading and clearing activities to be conducted so as to minimize potential adverse
effects of these activities on forested lands, surface water quality and quantity, groundwater
recharge, and fish and wildlife habitat, adjacent properties, and downstream drainage
channels. If work on any future project is within 200 feet of waters of the state, either
Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22 JCC (Critical Areas
Ordinance) will provide substantive development standards that control siting and mitigate
impacts. Future projects that are required to be Small Scale Tourist or Recreational Uses,
must adequately protect critical areas including surface and groundwater resources. JCC
18.20.350(3)(j)(iv).
F. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in
Forest Resource Zones: For future CSF projects subject to the small-scale recreation or
tourist approval criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “For any small-scale recreation or tourist use,
the county shall impose such reasonable conditions (e.g., location and size restrictions,
design standards, landscape buffers, setbacks, etc.) as are found necessary by the
approving authority to ensure that the activity or use, due to proximity, location or intensity:
… (iv) Adequately protects critical areas including surface and groundwater resources …”
(Emphasis added.) JCC 18.20.350(3)(a)(v) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “If the preceding conditions (in subsection (3)(j)
of this section) cannot be met to the satisfaction of the approving authority, the use shall
be denied.”
G. Additional Protection of Surface Water Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead discharge
Page 31 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
through stormwater runoff into surface waters (if the proposal is close enough to surface
waters) or ingestion by animals or humans. However, a future project applicant is required
to comply with USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting
Ranges (Exhibit 9). The BMPs require that the CSF control and contain the lead, that they
prevent migration, that they remove and recycle the lead, and that they document activities
and keep records.
2) Could waste materials enter ground or surface waters? If so, generally describe. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11,
above, including the no-action alternative, each new CSF project proposal must comply
with all applicable laws and regulations, including SEPA and its implementing regulations,
and Chapter 18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and
18.30 JCC for development and performance standards. See also JCC 18.40.530 for the
12 CUP approval criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria
(Exhibit 2).
C. Relevant Conditional Use Approval Criteria that Must be Applied at the Project Level For
future CSF projects subject to the conditional use approval criteria, including JCC
18.40.530(1)(b) that requires: “The conditional use will be served by adequate
infrastructure including roads, fire protection, water, wastewater disposal, and stormwater
control.” (Emphasis added.)
D. Additional Protections in Alternatives 1 through 5: Additional protections for human health
and the environment for Alternatives 1 through 5, compared to the no-action alternative,
are described in detail in the Brief and Complete Discussion in response to Question A.11,
above.
E. Protection of Groundwater at the Project Level: JCC 18.25.320(2)(d) prohibits discharging
solid wastes, liquid wastes and untreated effluents to any groundwater or surface water or
to be discharged onto land. All future project applications must be evaluated independently
under JCC 18.30.070 that requires compliance with the Department of Ecology’s
Stormwater Management Manual for Western Washington. JCC 18.22.130 provides
protection standards for groundwater in susceptible aquifer recharge and special aquifer
protection areas. JCC 18.30.060(1)(a) requires all grading and clearing activities to be
conducted so as to minimize potential adverse effects of these activities on forested lands,
surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels. If work on any future project is
within 200 feet of waters of the state, either Chapter 18.25 JCC (Shoreline Master Program)
or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive development
standards that control siting and mitigate impacts. Future projects that are required to be
Small Scale Tourist or Recreational Uses, must adequately protect critical areas including
surface and groundwater resources. JCC 18.20.350(3)(j)(iv).
F. Protection of Surface Water at the Project Level: JCC 18.25.320(2)(d) prohibits discharging
solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water or
to be discharged onto land. All future project applications must be evaluated independently
under JCC 18.30.070 that requires compliance with the Department of Ecology’s
Stormwater Management Manual for Western Washington. JCC 18.30.060(1)(a) requires
all grading and clearing activities to be conducted so as to minimize potential adverse
effects of these activities on forested lands, surface water quality and quantity, groundwater
recharge, and fish and wildlife habitat, adjacent properties, and downstream drainage
channels. If work on any future project is within 200 feet of waters of the state, either
Page 32 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22 JCC (Critical Areas
Ordinance) will provide substantive development standards that control siting and mitigate
impacts. Future projects that are required to be Small Scale Tourist or Recreational Uses,
must adequately protect critical areas including surface and groundwater resources. JCC
18.20.350(3)(j)(iv).
G. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in
Forest Resource Zones: For future CSF projects subject to the small-scale recreation or
tourist approval criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “For any small-scale recreation or tourist use,
the county shall impose such reasonable conditions (e.g., location and size restrictions,
design standards, landscape buffers, setbacks, etc.) as are found necessary by the
approving authority to ensure that the activity or use, due to proximity, location or intensity:
… (iv) Adequately protects critical areas including surface and groundwater resources …”
(Emphasis added.) JCC 18.20.350(3)(a)(v) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “If the preceding conditions (in subsection (3)(j)
of this section) cannot be met to the satisfaction of the approving authority, the use shall
be denied.”
H. Additional Protection of Surface Water Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead discharge
through stormwater runoff into surface waters (if the proposal is close enough to surface
waters) or ingestion by animals or humans. However, a future project applicant is required
to comply with USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting
Ranges (Exhibit 9). The BMPs require that the CSF control and contain the lead, that they
prevent migration, that they remove and recycle the lead, and that they document activities
and keep records.
3) Does the proposal alter or otherwise affect drainage patterns in the vicinity of the site? If so,
describe. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11,
above, including the no-action alternative, each new CSF project proposal must comply
with all applicable laws and regulations, including SEPA and its implementing regulations,
and Chapter 18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and
18.30 JCC for development and performance standards. See also JCC 18.40.530 for the
12 CUP approval criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria
(Exhibit 2).
C. Relevant Conditional Use Approval Criteria that Must be Applied at the Project Level For
future CSF projects subject to the conditional use approval criteria, including JCC
18.40.530(1)(b) that requires: “The conditional use will be served by adequate
infrastructure including roads, fire protection, water, wastewater disposal, and stormwater
control.” (Emphasis added.)
D. Additional Protections in Alternatives 1 through 5: Additional protections for human health
and the environment for Alternatives 1 through 5, compared to the no-action alternative,
are described in detail in the Brief and Complete Discussion in response to Question A.11,
above.
E. Protection for Filling and Excavation at the Project Level. Protection standards for filling
and excavation are contained in JCC 18.25.370.
F. Protection for Drainage and Erosion Control at the Project Level: Protection standards,
including drainage and erosion control are contained in JCC 18.22.160 and 18.22.170 for
Page 33 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
geologically hazardous areas, JCC 18.25.320 for shorelines, JCC 18.22.270 for fish,
wildlife habitat conservation areas, JCC 18.22.330 for wetlands, JCC 18.25.370 for filling
and excavation, and JCC 18.30.060 provides for grading and excavation.
G. Protection of Surface Water at the Project Level: JCC 18.25.320(2)(d) prohibits discharging
solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water or
to be discharged onto land. All future project applications must be evaluated independently
under JCC 18.30.070 that requires compliance with the Department of Ecology’s
Stormwater Management Manual for Western Washington. JCC 18.30.060(1)(a) requires
all grading and clearing activities to be conducted so as to minimize potential adverse
effects of these activities on forested lands, surface water quality and quantity, groundwater
recharge, and fish and wildlife habitat, adjacent properties, and downstream drainage
channels. If work on any future project is within 200 feet of waters of the state, either
Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22 JCC (Critical Areas
Ordinance) will provide substantive development standards that control siting and mitigate
impacts. Future projects that are required to be Small Scale Tourist or Recreational Uses,
must adequately protect critical areas including surface and groundwater resources. JCC
18.20.350(3)(j)(iv).
H. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in
Forest Resource Zones: For future CSF projects subject to the small-scale recreation or
tourist approval criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “For any small-scale recreation or tourist use,
the county shall impose such reasonable conditions (e.g., location and size restrictions,
design standards, landscape buffers, setbacks, etc.) as are found necessary by the
approving authority to ensure that the activity or use, due to proximity, location or intensity:
… (iv) Adequately protects critical areas including surface and groundwater resources …”
(Emphasis added.) JCC 18.20.350(3)(a)(v) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “If the preceding conditions (in subsection (3)(j)
of this section) cannot be met to the satisfaction of the approving authority, the use shall
be denied.”
I. Additional Protection of Surface Water Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead discharge
through stormwater runoff into surface waters (if the proposal is close enough to surface
waters) or ingestion by animals or humans. However, a future project applicant is required
to comply with USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting
Ranges (Exhibit 9). The BMPs require that the CSF control and contain the lead, that they
prevent migration, that they remove and recycle the lead, and that they document activities
and keep records.
d. Proposed measures to reduce or control surface, ground, and runoff water, and drainage pattern
impacts, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
ii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for
development and performance standards. See also JCC 18.40.530 for the 12 CUP approval
criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iii. Relevant Conditional Use Approval Criteria that Must be Applied at the Project Level For future
CSF projects subject to the conditional use approval criteria, including JCC 18.40.530(1)(b)
Page 34 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
that requires: “The conditional use will be served by adequate infrastructure including roads,
fire protection, water, wastewater disposal, and stormwater control.” (Emphasis added.)
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and
the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection for Filling and Excavation at the Project Level. Protection standards for filling and
excavation are contained in JCC 18.25.370.
vi. Protection for Drainage and Erosion Control at the Project Level: Protection standards,
including drainage and erosion control are contained in JCC 18.22.160 and 18.22.170 for
geologically hazardous areas, JCC 18.25.320 for shorelines, JCC 18.22.270 for fish, wildlife
habitat conservation areas, JCC 18.22.330 for wetlands, JCC 18.25.370 for filling and
excavation, and JCC 18.30.060 provides for grading and excavation.
vii. Protection of Surface Water at the Project Level: JCC 18.25.320(2)(d) prohibits discharging
solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water or to
be discharged onto land. All future project applications must be evaluated independently under
JCC 18.30.070 that requires compliance with the Department of Ecology’s Stormwater
Management Manual for Western Washington. JCC 18.30.060(1)(a) requires all grading and
clearing activities to be conducted so as to minimize potential adverse effects of these activities
on forested lands, surface water quality and quantity, groundwater recharge, and fish and
wildlife habitat, adjacent properties, and downstream drainage channels. If work on any future
project is within 200 feet of waters of the state, either Chapter 18.25 JCC (Shoreline Master
Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Future projects that are
required to be Small Scale Tourist or Recreational Uses, must adequately protect critical areas
including surface and groundwater resources. JCC 18.20.350(3)(j)(iv).
viii. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist
approval criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction
of the approving authority that: “For any small-scale recreation or tourist use, the county shall
impose such reasonable conditions (e.g., location and size restrictions, design standards,
landscape buffers, setbacks, etc.) as are found necessary by the approving authority to ensure
that the activity or use, due to proximity, location or intensity: … (iv) Adequately protects critical
areas including surface and groundwater resources …” (Emphasis added.) JCC
18.20.350(3)(a)(v) requires that the applicant demonstrate to the satisfaction of the approving
authority that: “If the preceding conditions (in subsection (3)(j) of this section) cannot be met to
the satisfaction of the approving authority, the use shall be denied.”
ix. Additional Protection of Surface Water Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead discharge through
stormwater runoff into surface waters (if the proposal is close enough to surface waters) or
ingestion by animals or humans. However, a future project applicant is required to comply with
USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit
9). The BMPs require that the CSF control and contain the lead, that they prevent migration,
that they remove and recycle the lead, and that they document activities and keep records.
4. Plants [help]
e. Check the types of vegetation found on the site: [help]
deciduous tree: alder, maple, aspen, other
evergreen tree: fir, cedar, pine, other
shrubs
grass
pasture
crop or grain
Orchards, vineyards or other permanent crops.
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wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other
water plants: water lily, eelgrass, milfoil, other
other types of vegetation
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Plants Described at the Project Level: Plants on a site only can be discussed in a future project-level
SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
f. What kind and amount of vegetation will be removed or altered? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Vegetation Removal or Alteration Described at the Project Level: Vegetation removal or alteration
on a site only can be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection Related to Vegetation Removal at the Project Level: JCC 18.22.170(4) requires
vegetation retention for any Fish and Wildlife Habitat Conservation Area and its buffer. JCC
18.22.270(4) requires vegetation retention for geologically hazardous areas. JCC 18.25.270(3)(h)
requires vegetation maintenance in shoreline buffers. JCC 18.25.310 contains vegetation
conservation regulations for shorelines. JCC 18.25.390(3)(i) contains limitations on removal of
vegetation related to in-stream structures.
g. List threatened and endangered species known to be on or near the site. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Known Threatened or Endangered Species Described at the Project Level. Known threatened or
endangered species on a site will be discussed in a future project-level SEPA checklist.
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January 6, 2020
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection of Fish and Wildlife at the Project Level: JCC 18.22.270 provides protection standards for
fish and wildlife habitat conservation areas.
h. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on
the site, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Proposed Landscaping or Use of Native Plants Described at the Project Level. Proposed
landscaping, use of native plants, or other measures to preserve or enhance vegetation on a site will
be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection Related to Measures to Preserve or Enhance Vegetation Required at the Project Level:
JCC 18.22.170(4) requires vegetation retention for any Fish and Wildlife Habitat Conservation Area
and its buffer. JCC 18.22.270(4) requires vegetation retention for geologically hazardous areas. JCC
18.25.270(3)(h) requires vegetation maintenance in shoreline buffers. JCC 18.25.310 contains
vegetation conservation regulations for shorelines. JCC 18.25.390(3)(i) contains limitations on
removal of vegetation related to in-stream structures.
vi. Protection Related to Landscaping at the Project Level: JCC 18.30.130 regulates landscaping and
screening at the project level.
i. List all noxious weeds and invasive species known to be on or near the site. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Known Noxious Weeds or Invasive Species Described at the Project Level. Noxious weeds and
invasive species on a site will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
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January 6, 2020
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Relevant Conditional Use Approval Criteria for CSF Projects: For future CSF projects subject to the
conditional use approval criteria, including JCC 18.40.530(1)(i) that requires: “The conditional use
will not cause significant adverse impacts on the human or natural environments that cannot be
mitigated through conditions of approval.”
v. Relevant Discretionary Use Approval Criteria for CSFs Projects: For future CSF projects subject to
the discretionary use approval criteria, including JCC 18.15.045(2)(a) requires that the project: “Will
not result in impacts on the human or natural environments determined by the administrator to require
review as a conditional use.”
vi. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
vii. Protections Against Noxious Weeds and Invasive Species at the Project Level. Jefferson County has
a Noxious Weed Board funded by JCC 3.65.030 organized under Chapter 17.10 RCW to coordinate
the management of noxious weeds to prevent, control, or mitigate the spread of these species to protect
human health, livestock, wildlife, native habitat, and ecosystem functioning in ecological as well as
economical terms.
5. Animals [help]
a. List any birds and other animals which have been observed on or near the site or are known to be on or
near the site. [help]
Examples include:
birds: hawk, heron, eagle, songbirds, other: mammals: deer, bear, elk, beaver, other:
fish: bass, salmon, trout, herring, shellfish, other
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Birds or Other Animals Observed Described at the Project Level. Birds and other animals which have
been observed on or near a site will be discussed in a future project-level SEPA checklist.
iii. Current SEPA and Regulatory Protection Described at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
b. List any threatened and endangered species known to be on or near the site. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Threatened or Endangered Species Described at the Project Level. Threatened and endangered
species known to be on or near a site will be discussed in a future project-level SEPA checklist.
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January 6, 2020
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
c. Is the site part of a migration route? If so, explain. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Known Migration Route Described at the Project Level. Migration routes on a site will be discussed
in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
d. Proposed measures to preserve or enhance wildlife, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Measures to Preserve or Enhance Wildlife Described at the Project Level. Measures to preserve or
enhance wildlife on a site will be discussed in a future project-level SEPA checklist.
iii. Current SEPA and Regulatory Protection Described at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
e. List any invasive animal species known to be on or near the site. [help]
RESPONSE:
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i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Known Invasive Animal Species Described at the Project Level. Invasive animal species on a site
will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
6. Energy and Natural Resources [help]
a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the completed
project's energy needs? Describe whether it will be used for heating, manufacturing, etc. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Energy Needs Described at the Project Level. Energy needs on a site will be discussed in a future
project-level SEPA checklist.
iii. Current SEPA and Regulatory Protection Described at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally
describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Use of Solar Energy Described at the Project Level. Solar energy use on a site will be discussed in
a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
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January 6, 2020
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
c. What kinds of energy conservation features are included in the plans of this proposal? List other
proposed measures to reduce or control energy impacts, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Energy Conservation Will be Discussed at the Project Level. Energy conservation on a site will be
discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
7. Environmental Health [help]
Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and
explosion, spill, or hazardous waste, that could occur as a result of this proposal? If so, describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Known Environmental Health Hazards, including Exposure to Toxic Chemicals, Risk of Fire and
Explosion, Spill, or Hazardous Waste will be Discussed at the Project Level. Environmental health
hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste
on a site will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Relevant Conditional Use Approval Criteria for CSF Projects: For future CSF projects subject to
the conditional use approval criteria, including JCC 18.40.530(1)(b) that requires: “The conditional
use will be served by adequate infrastructure including roads, fire protection, water, wastewater
disposal, and stormwater control” and JCC 18.40.530(1)(i) that requires: “The conditional use will
not cause significant adverse impacts on the human or natural environments that cannot be
mitigated through conditions of approval.” (Emphasis added.)
v. Relevant Discretionary Use Approval Criteria for CSFs Projects: For future CSF projects subject
to the discretionary use approval criteria, including JCC 18.15.045(2)(e) requires that the project
will “be served by adequate facilities including access, fire protection, water and sewer facilities
(municipal, community, or on-site systems)” and JCC 18.15.045(2)(a) requires that the project:
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January 6, 2020
“Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.” (Emphasis added.)
vi. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
vii. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “For any small-scale recreation or tourist use, the county shall impose
such reasonable conditions (e.g., location and size restrictions, design standards, landscape
buffers, setbacks, etc.) as are found necessary by the approving authority to ensure that the activity
or use, due to proximity, location or intensity: … (iv) Adequately protects critical areas including
surface and groundwater resources …” (Emphasis added.) JCC 18.20.350(3)(a)(v) requires that
the applicant demonstrate to the satisfaction of the approving authority that: “If the preceding
conditions (in subsection (3)(j) of this section) cannot be met to the satisfaction of the approving
authority, the use shall be denied.”
viii. Additional Protection of Outdoor Air Required by the Proposal at the Project Level: If an alternative
is selected which allows outdoor CSF, there is a possibility of lead dust discharge into stormwater
runoff, then into surface waters (if the proposal is close enough to surface waters) or lead dust
ingestion by animals or humans. However, a future project applicant is required to comply with
USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9).
The BMPs require that the CSF control and contain the lead dust, that they prevent migration, that
they remove and recycle the lead, and that they document activities and keep records.
ix. Additional Protection of Indoor Air Required by the Proposal at the Project Level: If an alternative
is selected which allows indoor CSFs there is a risk of lead and other chemical exposure to humans
through the indoor air. However, Title 8 will require all new indoor CSFs to comply with BMPs as
recommended by the National Institute for Occupational Safety and Health (NIOSH) in its 2009
publication entitled NIOSH Alert – Preventing Exposures to Lead and Noise at Indoor Firing
Ranges (Exhibit 10). This includes heating ventilation and air condition (HVAC) systems to filter
lead and other chemicals from the air.
x. Additional Protection of Surface Water Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead discharge through
stormwater runoff into surface waters (if the proposal is close enough to surface waters) or
ingestion by animals or humans. However, a future project applicant is required to comply with
USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9).
The BMPs require that the CSF control and contain the lead, that they prevent migration, that they
remove and recycle the lead, and that they document activities and keep records.
1) Describe any known or possible contamination at the site from present or past uses. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the JCC.
B. Known or Possible Contamination Will be Discussed at the Project Level. Known or possible
contamination on a site will be discussed in a future project-level SEPA checklist.
C. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for
development and performance standards. See also JCC 18.40.530 for the 12 CUP approval
criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
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January 6, 2020
D. Additional Protections in Alternatives 1 through 5: Additional protections for human health and
the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11, above.
2) Describe existing hazardous chemicals/conditions that might affect project development and
design. This includes underground hazardous liquid and gas transmission pipelines located within the
project area and in the vicinity. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. Known Existing Hazardous Chemicals/Conditions Described at the Project Level. Existing
hazardous chemicals/conditions on a site will be discussed in a future project-level SEPA
checklist.
C. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for
development and performance standards. See also JCC 18.40.530 for the 12 CUP approval
criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
D. Additional Protections in Alternatives 1 through 5: Additional protections for human health and
the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11, above.
3) Describe any toxic or hazardous chemicals that might be stored, used, or produced during the
project's development or construction, or at any time during the operating life of the project
4) . [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. Known Toxic or Hazardous Chemicals that Might be Stored, Used, or Produced Described at
the Project Level. Toxic or hazardous chemicals that might be stored, used, or produced during
a project's development or construction, or at any time during the operating life of the project
on a site will be discussed in a future project-level SEPA checklist.
C. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for
development and performance standards. See also JCC 18.40.530 for the 12 CUP approval
criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
D. Additional Protections in Alternatives 1 through 5: Additional protections for human health and
the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11, above.
E. Protection of Groundwater at the Project Level: JCC 18.25.320(2)(d) prohibits discharging solid
wastes, liquid wastes and untreated effluents to any groundwater or surface water or to be
discharged onto land. All future project applications must be evaluated independently under
JCC 18.30.070 that requires compliance with the Department of Ecology’s Stormwater
Management Manual for Western Washington. JCC 18.22.130 provides protection standards
for groundwater in susceptible aquifer recharge and special aquifer protection areas. JCC
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18.30.060(1)(a) requires all grading and clearing activities to be conducted so as to minimize
potential adverse effects of these activities on forested lands, surface water quality and
quantity, groundwater recharge, and fish and wildlife habitat, adjacent properties, and
downstream drainage channels. If work on any future project is within 200 feet of waters of the
state, either Chapter 18.25 JCC (Shoreline Master Program) or Chapter 18.22 JCC (Critical
Areas Ordinance) will provide substantive development standards that control siting and
mitigate impacts. Future projects that are required to be Small Scale Tourist or Recreational
Uses, must adequately protect critical areas including surface and groundwater resources.
JCC 18.20.350(3)(j)(iv).
F. Protection of Surface Water at the Project Level: JCC 18.25.320(2)(d) prohibits discharging
solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water or to
be discharged onto land. All future project applications must be evaluated independently under
JCC 18.30.070 that requires compliance with the Department of Ecology’s Stormwater
Management Manual for Western Washington. JCC 18.30.060(1)(a) requires all grading and
clearing activities to be conducted so as to minimize potential adverse effects of these activities
on forested lands, surface water quality and quantity, groundwater recharge, and fish and
wildlife habitat, adjacent properties, and downstream drainage channels. If work on any future
project is within 200 feet of waters of the state, either Chapter 18.25 JCC (Shoreline Master
Program) or Chapter 18.22 JCC (Critical Areas Ordinance) will provide substantive
development standards that control siting and mitigate impacts. Future projects that are
required to be Small Scale Tourist or Recreational Uses, must adequately protect critical areas
including surface and groundwater resources. JCC 18.20.350(3)(j)(iv).
G. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist
approval criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “For any small-scale recreation or tourist use, the
county shall impose such reasonable conditions (e.g., location and size restrictions, design
standards, landscape buffers, setbacks, etc.) as are found necessary by the approving
authority to ensure that the activity or use, due to proximity, location or intensity: … (iv)
Adequately protects critical areas including surface and groundwater resources …”
(Emphasis added.) JCC 18.20.350(3)(a)(v) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “If the preceding conditions (in subsection (3)(j) of
this section) cannot be met to the satisfaction of the approving authority, the use shall be
denied.”
H. Additional Protection of Surface Water Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead discharge through
stormwater runoff into surface waters (if the proposal is close enough to surface waters) or
ingestion by animals or humans. However, a future project applicant is required to comply with
USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit
9). The BMPs require that the CSF control and contain the lead, that they prevent migration,
that they remove and recycle the lead, and that they document activities and keep records.
I. Additional Protection of Outdoor Air Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead dust discharge
into stormwater runoff, then into surface waters (if the proposal is close enough to surface
waters) or lead dust ingestion by animals or humans. However, a future project applicant is
required to comply with USEPA Region 2 Best Management Practices for Lead at Outdoor
Shooting Ranges (Exhibit 9). The BMPs require that the CSF control and contain the lead dust,
that they prevent migration, that they remove and recycle the lead, and that they document
activities and keep records.
J. Additional Protection of Indoor Air Required by the Proposal at the Project Level: If an
alternative is selected which allows indoor CSFs there is a risk of lead and other chemical
exposure to humans through the indoor air. However, Title 8 will require all new indoor CSFs
to comply with BMPs as recommended by the National Institute for Occupational Safety and
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January 6, 2020
Health (NIOSH) in its 2009 publication entitled NIOSH Alert – Preventing Exposures to Lead
and Noise at Indoor Firing Ranges (Exhibit 10). This includes heating ventilation and air
condition (HVAC) systems to filter lead and other chemicals from the air
5) Describe special emergency services that might be required. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. Special Emergency Services that Might be Required Described at the Project Level. Special
emergency services that might be required on a site will be discussed in a future project-level
SEPA checklist.
C. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for
development and performance standards. See also JCC 18.40.530 for the 12 CUP approval
criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
D. Relevant Conditional Use Approval Criteria for CSF Projects: For future CSF projects subject
to the conditional use approval criteria, including JCC 18.40.530(1)(b) that requires: “The
conditional use will be served by adequate infrastructure including roads, fire protection, water,
wastewater disposal, and stormwater control.” (Emphasis added.)
E. Relevant Discretionary Use Approval Criteria for CSFs Projects: For future CSF projects
subject to the discretionary use approval criteria, including JCC 18.15.045(2)(e) requires that
the project will “be served by adequate facilities including access, fire protection, water, and
sewer facilities (municipal, community, or on-site systems).” (Emphasis added.)
F. Additional Protections in Alternatives 1 through 5: Additional protections for human health and
the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11, above.
6) Proposed measures to reduce or control environmental health hazards, if any: [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. Proposed Measures to Reduce or Control Environmental Health Hazards Described at the
Project Level. Proposed measures to reduce or control environmental health hazards on a site
will be discussed in a future project-level SEPA checklist.
C. Current SEPA and Regulatory Protection at the Project Level: Under each of the alternatives
listed in the Brief and Complete Discussion in response to Question A.11, above, including the
no-action alternative, each new CSF project proposal must comply with all applicable laws and
regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article X JCC
(SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
D. Relevant Conditional Use Approval Criteria for CSF Projects: For future CSF projects subject to
the conditional use approval criteria, including JCC 18.40.530(1)(b) that requires: “The
conditional use will be served by adequate infrastructure including roads, fire protection, water,
wastewater disposal, and stormwater control.” (Emphasis added.)
E. Relevant Discretionary Use Approval Criteria for CSFs Projects: For future CSF projects subject
to the discretionary use approval criteria, including JCC 18.15.045(2)(e) requires that the project
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will “be served by adequate facilities including access, fire protection, water, and sewer facilities
(municipal, community, or on-site systems).” (Emphasis added.)
F. Additional Protections in Alternatives 1 through 5: Additional protections for human health and
the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11, above.
G. Protection of Water Supply at the Project Level: JCC 18.30.030 provides protection standards
for water supply.
H. Protection for Sewage Disposal at the Project Level: JCC 18.30.040 and 18.30.080 provide
protection standards for sewage disposal. Specifically, Jefferson County Code 18.30.040(1)
requires that: “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.”
I. Additional Protection of Surface Water Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead discharge through
stormwater runoff into surface waters (if the proposal is close enough to surface waters) or
ingestion by animals or humans. However, a future project applicant is required to comply with
USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9).
The BMPs require that the CSF control and contain the lead, that they prevent migration, that
they remove and recycle the lead, and that they document activities and keep records.
J. Additional Protection of Outdoor Air Required by the Proposal at the Project Level: If an
alternative is selected which allows outdoor CSF, there is a possibility of lead dust lead dust
ingestion by animals or humans. However, a future project applicant is required to comply with
USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9).
The BMPs require that the CSF control and contain the lead dust, that they prevent migration,
that they remove and recycle the lead, and that they document activities and keep records.
K. Additional Protection of Indoor Air Required by the Proposal at the Project Level: If an alternative
is selected which allows indoor CSFs there is a risk of lead and other chemical exposure to
humans through the indoor air. However, Title 8 will require all new indoor CSFs to comply with
BMPs as recommended by the National Institute for Occupational Safety and Health (NIOSH) in
its 2009 publication entitled NIOSH Alert – Preventing Exposures to Lead and Noise at Indoor
Firing Ranges (Exhibit 10). This includes heating ventilation and air condition (HVAC) systems
to filter lead and other chemicals from the air.
j. Noise [help]
k. What types of noise exist in the area which may affect your project (for example traffic, equipment,
operation, other)? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Noise in the Area Evaluated at the Project Level: Noise in the area of a project will be discussed in
a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Relevant Conditional Use Approval Criteria for CSF Projects: For future CSF projects subject to the
conditional use approval criteria, including JCC 18.40.530(1)(d) that requires: “The conditional use
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January 6, 2020
will not introduce noise, smoke, dust, fumes, vibrations, odors, or other conditions or which
unreasonably impact existing uses in the vicinity of the subject parcel.”
v. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
vi. Protection from Noise at the Project Level: JCC 18.30.190 incorporates noise mitigation
requirements in the State Environmental Policy Act, Chapter 43.21C RCW, related to noise
abatement, and provides that noise shall not exceed the requirements in Chapter 8.70 JCC and
Chapter 173-60 WAC, as they exist now or may be amended in the future.
vii. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(a)(iii) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “The associated commercial activities, in addition to the principal
recreational or tourist use, will not have a measurable detrimental traffic, noise, visual or public
safety impact on adjacent properties.” (Emphasis added.
viii. Additional Protection for Noise at Outdoor CSFs Required by the Proposal at the Project Level: If
an alternative is selected which allows outdoor CSF, Requires BMPs to maximize sound
suppression for operations consistent with Chapter 8.70 JCC (noise control) and the NRA Range
Source Book. These design requirements and BMPs require design to reduce noise impacts to
users and require protective ear coverings. Outdoor CSFs will be a conditional use, which requires
compliance with all 12 CUP approval criteria in the Jefferson County Code. Of importance, the
following CUP approval criteria states: “(d) The conditional use will not introduce noise, smoke,
dust, fumes, vibrations, odors, or other conditions or which unreasonably impact existing uses in
the vicinity of the subject parcel”. JCC 18.40.530(1)(d). The applicant will have to prove that their
BMPs, design features, and operational aspects must comply with the 12 CUP approval criteria in
the Jefferson County Code. Further, noise will be evaluated under individual SEPA Environmental
Checklists (unless the project is exempt).
ix. Additional Protection for Noise at Indoor CSFs Required by the Proposal at the Project Level: If an
alternative is selected which allows indoor CSFs, the indoor CSFs must comply with BMPs
consistent with Chapter 8.70 JCC (noise control), the NRA Range Source Book, and the National
Institute for Occupational Safety and Health (NIOSH) in its 2009 publication entitled NIOSH Alert –
Preventing Exposures to Lead and Noise at Indoor Firing Ranges (Exhibit 10). These design
requirements and BMPs require design to reduce noise impacts to users and require protective ear
coverings. The applicant will have to prove that their BMPs, design features, and operational
aspects must comply with the 12 CUP approval criteria in the Jefferson County Code. Further,
noise will be evaluated under individual SEPA Environmental Checklists (unless the project is
exempt).
2) What types and levels of noise would be created by or associated with the project on a short-
term or a long-term basis (for example traffic, construction, operation, other)? Indicate what hours
noise would come from the site. [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. Levels of Noise that Would be Created by or Associated with a Project on a Short-term or a
Long-term Basis Described at the Project Level. Levels of noise that would be created by or
associated with a project on a short-term or a long-term basis on a site will be discussed in a
future project-level SEPA checklist.
C. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and
Chapter 18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30
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JCC for development and performance standards. See also JCC 18.40.530 for the 12 CUP
approval criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
D. Additional Protections in Alternatives 1 through 5: Additional protections for human health
and the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11,
above.
E. Protection from Noise at the Project Level: JCC 18.30.190 incorporates noise mitigation
requirements in the State Environmental Policy Act, Chapter 43.21C RCW, related to noise
abatement, and provides that noise shall not exceed the requirements in Chapter 8.70 JCC
and Chapter 173-60 WAC, as they exist now or may be amended in the future.
F. Additional Protection for Noise at Outdoor CSFs Required by the Proposal at the Project
Level: If an alternative is selected which allows outdoor CSF, Requires BMPs to maximize
sound suppression for operations consistent with Chapter 8.70 JCC (noise control) and the
NRA Range Source Book. These design requirements and BMPs require design to reduce
noise impacts to users and require protective ear coverings. Outdoor CSFs will be a
conditional use, requiring compliance with all 12 CUP approval criteria in the Jefferson
County Code. Of importance the following CUP approval criteria states: “(d) The conditional
use will not introduce noise, smoke, dust, fumes, vibrations, odors, or other conditions or
which unreasonably impact existing uses in the vicinity of the subject parcel”. JCC
18.40.530(1)(d). The applicant will have to prove that their BMPs, design features, and
operational aspects must comply with the 12 CUP approval criteria in the Jefferson County
Code. Further, noise will be evaluated under individual SEPA Environmental Checklists
(unless the project is exempt).
G. Additional Protection for Noise at Indoor CSFs Required by the Proposal at the Project Level:
If an alternative is selected which allows indoor CSFs, the indoor CSFs must comply with
BMPs consistent with Chapter 8.70 JCC (noise control), the NRA Range Source Book, and
the National Institute for Occupational Safety and Health (NIOSH) in its 2009 publication
entitled NIOSH Alert – Preventing Exposures to Lead and Noise at Indoor Firing Ranges
(Exhibit 10). These design requirements and BMPs require design to reduce noise impacts
to users and require protective ear coverings. The applicant will have to prove that their
BMPs, design features, and operational aspects must comply with the 12 CUP approval
criteria in the Jefferson County Code. Further, noise will be evaluated under individual SEPA
Environmental Checklists (unless the project is exempt).
3) Proposed measures to reduce or control noise impacts, if any: [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. Proposed Measures to Reduce or Control Noise Impacts Described at the Project Level.
Proposed measures to reduce or control noise impacts a project on a short-term or a long-term
basis on a site will be discussed in a future project-level SEPA checklist.
C. Current SEPA and Regulatory Protection at the Project Level: Under each of the alternatives
listed in the Brief and Complete Discussion in response to Question A.11, above, including the
no-action alternative, each new CSF project proposal must comply with all applicable laws and
regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article X
JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1)
and JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
D. Relevant Conditional Use Approval Criteria for CSF Projects: For future CSF projects subject
to the conditional use approval criteria, including JCC 18.40.530(1)(d) that requires: “The
conditional use will not introduce noise, smoke, dust, fumes, vibrations, odors, or other
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January 6, 2020
conditions or which unreasonably impact existing uses in the vicinity of the subject parcel.”
(Emphasis added.)
E. Additional Protections in Alternatives 1 through 5: Additional protections for human health and
the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11, above.
F. Protection from Noise at the Project Level: JCC 18.30.190 incorporates noise mitigation
requirements in the State Environmental Policy Act, Chapter 43.21C RCW, related to noise
abatement, and provides that noise shall not exceed the requirements in Chapter 8.70 JCC
and Chapter 173-60 WAC, as they exist now or may be amended in the future.
G. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist
approval criteria, JCC 18.20.350(3)(a)(iii) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “The associated commercial activities, in addition
to the principal recreational or tourist use, will not have a measurable detrimental traffic, noise,
visual or public safety impact on adjacent properties.” (Emphasis added.)
H. Additional Protection for Noise at Outdoor CSFs Required by the Proposal at the Project Level:
If an alternative is selected which allows outdoor CSF, Requires BMPs to maximize sound
suppression for operations consistent with Chapter 8.70 JCC (noise control) and the NRA
Range Source Book. These design requirements and BMPs require design to reduce noise
impacts to users and require protective ear coverings. Outdoor CSFs will be a conditional use,
requiring compliance with all 12 CUP approval criteria in the Jefferson County Code. Of
importance, the following CUP approval criteria states: “(d) The conditional use will not
introduce noise, smoke, dust, fumes, vibrations, odors, or other conditions or which
unreasonably impact existing uses in the vicinity of the subject parcel”. JCC 18.40.530(1)(d).
The applicant will have to prove that their BMPs, design features, and operational aspects
must comply with the 12 CUP approval criteria in the Jefferson County Code. Further, noise
will be evaluated under individual SEPA Environmental Checklists (unless the project is
exempt).
I. Additional Protection for Noise at Indoor CSFs Required by the Proposal at the Project Level:
If an alternative is selected which allows indoor CSFs, the indoor CSFs must comply with BMPs
consistent with Chapter 8.70 JCC (noise control), the NRA Range Source Book, and the
National Institute for Occupational Safety and Health (NIOSH) in its 2009 publication entitled
NIOSH Alert – Preventing Exposures to Lead and Noise at Indoor Firing Ranges (Exhibit 10).
These design requirements and BMPs require design to reduce noise impacts to users and
require protective ear coverings. The applicant will have to prove that their BMPs, design
features, and operational aspects must comply with the 12 CUP approval criteria in the
Jefferson County Code. Further, noise will be evaluated under individual SEPA Environmental
Checklists (unless the project is exempt).
8. Land and Shoreline Use [help]
a. What is the current use of the site and adjacent properties? Will the proposal affect current land uses on
nearby or adjacent properties? If so, describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Current Use of a Site and Adjacent Properties Will be Discussed at the Project Level. The current
use of site and adjacent properties on a site will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
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January 6, 2020
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
b. Has the project site been used as working farmlands or working forest lands? If so, describe. How much
agricultural or forest land of long-term commercial significance will be converted to other uses as a result
of the proposal if any? If resource lands have not been designated, how many acres in farmland or forest
land tax status will be converted to nonfarm or nonforest use? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
ii. Farmland will not be Affected by this Proposal: Farmland will not be affected by this proposal
because CSFs will not be authorized in agricultural resource zones.
iii. Any Use of Working Forest Lands Discussed at the Project Level. Any use of working forest
lands on a site will be discussed in a future project-level SEPA checklist.
iv. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for
development and performance standards. See also JCC 18.40.530 for the 12 CUP approval
criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
v. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist
approval criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction
of the approving authority that: “For any small-scale recreation or tourist use, the county shall
impose such reasonable conditions (e.g., location and size restrictions, design standards,
landscape buffers, setbacks, etc.) as are found necessary by the approving authority to ensure
that the activity or use, due to proximity, location or intensity: (i) Is compatible with the rural
character of adjacent lands and shorelines, including forestry, agriculture, and mineral lands of
long-term commercial significance; (ii) Does not disrupt the character of any surrounding
permitted uses; (iii) Is adequately served by public facilities and services (including roadway
level of service and minimum fire flow requirements) without the need to extend those services
in a manner that promotes low density sprawl; (iv) Adequately protects critical areas including
surface and groundwater resources; (v) Would not cumulatively, in combination with the effects
of existing development (or given the probable development of subsequent projects with similar
effects) in the vicinity (i.e., within one mile) of the proposed use, create a development pattern
that constitutes low density sprawl; require the extension of public facilities or expansion of
public services in a manner that promotes low density sprawl; or be otherwise incompatible with
or injurious to the rural character of the area; (vi) For designated agricultural lands, converts as
little land with prime agricultural soils as practicable into nonagricultural use.” JCC
18.20.350(3)(a)(v) requires that the applicant demonstrate to the satisfaction of the approving
authority that: “If the preceding conditions (in subsection (3)(j) of this section) cannot be met to
the satisfaction of the approving authority, the use shall be denied.” (Emphasis added.)
vi. Additional Protections in Alternatives 1 through 5: Additional protections for human health and
the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11, above.
vii. Additional Protections for Forest Lands under the Project: Under Alternatives 1, 2, 3 and 5,
indoor and outdoor CSFs would be permitted with a CUP. This may result in the conversion of
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forest resource lands to nonforest uses. However, under Alternatives 1, 2, and 5, a quota would
apply to all new indoor and outdoor CSFs in forest resource lands. The quota would limit CSFs
to 0.05 percent of all forest lands. This amounts to approximately 150 acres. Jefferson County
has approximately 328,785 acres of forest resource lands. This quota, in addition to the Small-
Scale Recreation or Tourist Uses standards ensure the longevity of Jefferson County forest
resource lands. Further, the Small-Scale Recreation or Tourist Uses standards are designed to
ensure that uses can co-exist with the useful production of forest resource lands. Alternatives
1, 2, 3, 4 and 5 all are more protective than the no-action alternative, because under the no-
action alternative, the “unnamed use” loophole may allow shooting facilities at a scale and
intensity that is inconsistent with forest resource lands. For example, a large-scale shooting
facility, if is not classified as a Small-Scale Recreation and Tourist Use, then the use may be
allowed by right, allowed with a CUP, or not permitted.
1) Will the proposal affect or be affected by surrounding working farm or forest land normal business
operations, such as oversize equipment access, the application of pesticides, tilling, and harvesting?
If so, how: [help]
RESPONSE:
A. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project
proposal for legislation that amends the Jefferson County Code.
B. Farmland will not be Affected by this Proposal: Farmland will not be affected by this proposal
because CSFs will not be authorized in agricultural resource zones.
C. Any Effect on A Site by Surrounding Working Farm or Working Forest Lands Discussed at the
Project Level. Any effect of surrounding working farm or forest land on a site will be discussed in
a future project-level SEPA checklist.
D. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter
18.40, Article X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for
development and performance standards. See also JCC 18.40.530 for the 12 CUP approval
criteria (Exhibit 1) and JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
E. Additional Protections in Alternatives 1 through 5: Additional protections for human health and
the environment for Alternatives 1 through 5, compared to the no-action alternative, are
described in detail in the Brief and Complete Discussion in response to Question A.11, above.
F. Additional Protections for Forest Lands under the Project: Under Alternatives 1, 2, 3 and 5, indoor
and outdoor CSFs would be permitted with a CUP. This may result in the conversion of forest
resource lands to nonforest uses. However, under Alternatives 1, 2, and 5, a quota would apply
to all new indoor and outdoor CSFs in forest resource lands. The quota would limit CSFs to 0.05
percent of all forest lands. This amounts to approximately 150 acres. Jefferson County has
approximately 328,785 acres of forest resource lands. This quota, in addition to the Small-Scale
Recreation or Tourist Uses standards ensure the longevity of Jefferson County forest resource
lands. Further, the Small-Scale Recreation or Tourist Uses standards are designed to ensure
that uses can co-exist with the useful production of forest resource lands. Alternatives 1, 2, 3, 4
and 5 all are more protective than the no-action alternative, because under the no-action
alternative, the “unnamed use” loophole may allow shooting facilities at a scale and intensity that
is inconsistent with forest resource lands. For example, a large-scale shooting facility, if is not
classified as a Small-Scale Recreation and Tourist Use, then the use may be allowed by right,
allowed with a CUP, or not permitted.
c. Describe any structures on the site. [help]
RESPONSE:
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i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Structures at a Site Will be Discussed at the Project Level: Structures at a site will be discussed in a
future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
d. Will any structures be demolished? If so, what? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Structures at a Site Will be Discussed at the Project Level: Structures at a site will be discussed in a
future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
e. What is the current zoning classification of the site? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Zoning Classifications Under the Proposal.
A. Alternative 1: Allows outdoor CSFs in forest resource lands only with a CUP, subject to the 12
CUP approval criteria in JCC 18.40.530 (Exhibit 1) and the forest resource district protections in
JCC 18.15.150 (Exhibit 3) and Table 3-1 (Exhibit 4). Allows indoor CSFs with a CUP only in
rural/urban growth area (UGA) commercial and industrial zoning (excluding resource-based
industrial zoning), subject to the 12 CUP approval criteria in JCC 18.40.530.
B. Alternative 2: Allows outdoor CSFs in forest resource lands only with a CUP, subject to the 12
CUP approval criteria in JCC 18.40.530 (Exhibit 1) and the forest resource district protections in
JCC 18.15.150 (Exhibit 3) and Table 3-1 (Exhibit 4). Allows indoor CSFs with a CUP in
rural/urban growth area (UGA) commercial and industrial zoning (excluding resource-based
industrial zoning), subject to the 12 CUP approval criteria in JCC 18.40.530.
C. Alternative 3: Allows outdoor CSFs in forest resource lands only with a CUP, subject to the 12
CUP approval criteria in JCC 18.40.530 (Exhibit 1) and the forest resource district protections in
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January 6, 2020
JCC 18.15.150 (Exhibit 3) and Table 3-1 (Exhibit 4). Allows indoor CSFs with a CUP in
rural/urban growth area (UGA) commercial and industrial zoning (excluding resource-based
industrial zoning), subject to the 12 CUP approval criteria in JCC 18.40.530.
D. Alternative 4: Indoor CSFs allowed only as a discretionary use (without additional bright-line
rules) in all rural/UGA commercial and industrial zoning (excluding resource-based industrial
zoning).
E. Alternative 5: Allows indoor CSFs allowed as a discretionary use in all rural/UGA commercial
and industrial zoning (excluding resource-based industrial zoning). Allows indoor CSFs in forest
resource lands only with a CUP, subject to the 12 CUP approval criteria in JCC 18.40.530 (Exhibit
1) and the forest resource district protections in JCC 18.15.150 (Exhibit 3) and Table 3-1 (Exhibit
4).
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
f. What is the current comprehensive plan designation of the site? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Comprehensive Plan Designation Will be Discussed at the Project Level. Comprehensive Plan
designation for a site will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
g. If applicable, what is the current shoreline master program designation of the site? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Shoreline Master Program Designation Will be Discussed at the Project Level. Shoreline Master
Program designation for a site will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
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January 6, 2020
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
h. Has any part of the site been classified as a critical area by the city or county? If so, specify. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Classification as a Critical Area Will be Discussed at the Project Level. Classification of any part of a
site as a critical area will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
i. Approximately how many people would reside or work in the completed project? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. An estimate of How Many People Would Reside or Work Will be Discussed at the Project Level.
How many people would reside or work at a completed project will be discussed in a future project-
level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
j. Approximately how many people would the completed project displace? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
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ii. An estimate of How Many People Would be Displaced Will be Discussed at the Project Level. How
many people would be displaced by a completed project will be discussed in a future project-level
SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
k. Proposed measures to avoid or reduce displacement impacts, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Measures to Avoid or Reduce Displacement Impacts Will be Discussed at the Project Level.
Measures to avoid or reduce displacement impacts will be discussed in a future project-level SEPA
checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
l. Proposed measures to ensure the proposal is compatible with existing and projected land uses and
plans if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iii. Relevant Conditional Use Approval Criteria for CSF Projects: For future CSF projects subject to the
conditional use approval criteria, including JCC 18.40.530(1)(a) that requires: “The conditional use
is harmonious and appropriate in design, character and appearance with the existing or intended
character and quality of development in the vicinity of the subject property and with the physical
characteristics of the subject property,” JCC 18.40.530(1)(c) that requires: “The conditional use will
not be materially detrimental to uses or property in the vicinity of the subject parcel,” JCC
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January 6, 2020
18.40.530(1)(e) that requires: “The location, size, and height of buildings, structures, walls and
fences, and screening vegetation for the conditional use will not unreasonably interfere with allowable
development or use of neighboring properties,” JCC 18.40.530(1)(g) that requires: “The conditional
use complies with all other applicable criteria and standards of this title and any other applicable
provisions JCC or state law; and more specifically, conforms to the standards contained in
Chapters 18.20 and 18.30 JCC,” JCC 18.40.530(1)(k) that requires: “The conditional use is
consistent with all relevant goals and policies of the Jefferson County Comprehensive Plan,” and
JCC 18.40.530(1)(l) that requires: “The public interest suffers no substantial detrimental effect.
Consideration shall be given to the cumulative effect of similar actions in the area.”
iv. Relevant Discretionary Use Approval Criteria for CSFs Projects: For future CSF projects subject to
the discretionary use approval criteria, including JCC 18.15.045(2)(a) that requires compliance “with
the applicable development standards of Chapter 18.30 JCC,” JCC 18.15.045(2)(b) that requires
compliance “with the performance and use-specific standards unique to the proposed use specified
in Chapter 18.20 JCC,” JCC 18.15.045(2)(c) that requires the project to be “appropriate in design,
character, and appearance with the goals and policies for the land use designation and district in
which the proposed use is located,” and JCC 18.15.045(2)(d) that requires the project to be
“consistent with the goals and policies of the Comprehensive Plan and the applicable regulations of
the Shoreline Master Program if the application involves property located within the jurisdiction of the
state Shoreline Management Act, but does not require a shoreline permit.”
v. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
vi. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(a)(i) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “The principal demand for the commercial facilities is derived from the
principal recreational or tourist use and not the existing and projected rural population,” JCC
18.20.350(3)(a)(ii) requires that the applicant demonstrate to the satisfaction of the approving
authority that: “The associated commercial activities shall be clearly accessory to and dependent
upon the primary recreational or tourist uses,” JCC 18.20.350(3)(a)(vi) requires that the applicant
demonstrate to the satisfaction of the approving authority that: “The public facilities and services
provided are limited to those necessary to serve the associated commercial activities and the
principal small-scale recreational or tourist use in a manner that does not permit low-density sprawl,”
JCC 18.20.350(3)(d) requires that the applicant demonstrate to the satisfaction of the approving
authority that: “Only those buildings or areas specifically approved by the county may be used in the
conduct of the business,” and JCC 18.20.350(3)(i) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “Any small-scale recreational or tourist use development
allowed under this section that proposes to include permanent occupancy on-site residential
development may only be permitted subject to: (i) The underlying rural residential density; (ii) A
master planned resort (MPR) district designation subject to a legislative action to amend the
Comprehensive Plan; or (iii) That necessary for on-site management (e.g., a caretaker’s residence).
vii. Measures to Ensure the Proposal is Compatible with Existing and Projected Land Use and Plans:
Measures to ensure the proposal is compatible with existing and projected land uses and plans are:
A. Farmland will not be affected by this proposal because CSFs will not be authorized in agricultural
resource zones.
B. Allows outdoor CSFs in forest resource lands only with a CUP, subject to the 12 CUP approval
criteria in JCC 18.40.530 (Exhibit 1) and the forest resource district protections in JCC 18.15.150
(Exhibit 3) and Table 3-1 (Exhibit 4).
C. Limits outdoor CSFs to only forest resource lands for projects that qualify as Small-Scale
Recreation or Tourist Uses. Small-Scale Recreation or Tourist Uses are limited by JCC
18.20.350(3) (Exhibit 8).
D. Limits outdoor CSFs in forest resource lands with a quota (approximately 150 acres total in the
328,785 acres of forest resource lands throughout the county).
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January 6, 2020
E. Allows indoor CSFs with a CUP in rural/urban growth area (UGA) commercial and industrial
zoning (excluding resource-based industrial zoning), subject to the 12 CUP approval criteria in
JCC 18.40.530.
F. Continues to rely on existing laws that: (a) Require compliance with critical area, shoreline and
wetlands buffers; (b) Limit nuisance noise; (c) Limit dangerous shooting of firearms; (d) Limit the
types of weapons that can be used; and, (e) Prohibit the use of any explosive devices.
G. Fixes the ambiguities identified in the no-action alternative items (2) to (5), discussed above in
response to Question A. 11.
H. Fixes the loopholes identified in the no-action alternative items (8) to (10), discussed above in
response to Question A. 11.
I. Adds the protections noted as missing in the no-action alternative items (11) to (23), including
the standards and Best Management Practices described below.
m. Proposed measures to reduce or control impacts to agricultural and forest lands of long-term commercial
significance, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Farmland will not be Affected by this Proposal: Farmland will not be affected by this proposal because
CSFs will not be authorized in agricultural resource zones.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Additional Protections for Forest Lands under the Project: Under Alternatives 1, 2, 3 and 5, indoor
and outdoor CSFs would be permitted with a CUP. This may result in the conversion of forest
resource lands to nonforest uses. However, under Alternatives 1, 2, and 5, a quota would apply to
all new indoor and outdoor CSFs in forest resource lands. The quota would limit CSFs to 0.05 percent
of all forest lands. This amounts to approximately 150 acres. Jefferson County has approximately
328,785 acres of forest resource lands. This quota, in addition to the Small-Scale Recreation or
Tourist Uses standards ensure the longevity of Jefferson County forest resource lands. Further, the
Small-Scale Recreation or Tourist Uses standards are designed to ensure that uses can co-exist
with the useful production of forest resource lands. Alternatives 1, 2, 3, 4 and 5 all are more protective
than the no-action alternative, because under the no-action alternative, the “unnamed use” loophole
may allow shooting facilities at a scale and intensity that is inconsistent with forest resource lands.
For example, a large-scale shooting facility, if it is not classified as a Small-Scale Recreation and
Tourist Use, then the use may be allowed by right, allowed with a CUP, or not permitted.
vi. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(j) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “For any small-scale recreation or tourist use, the county shall impose such
reasonable conditions (e.g., location and size restrictions, design standards, landscape buffers,
setbacks, etc.) as are found necessary by the approving authority to ensure that the activity or use,
due to proximity, location or intensity: (i) Is compatible with the rural character of adjacent lands and
shorelines, including forestry, agriculture, and mineral lands of long-term commercial significance;
(ii) Does not disrupt the character of any surrounding permitted uses; (iii) Is adequately served by
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public facilities and services (including roadway level-of-service and minimum fire flow requirements)
without the need to extend those services in a manner that promotes low density sprawl; (iv)
Adequately protects critical areas including surface and groundwater resources; (v) Would not
cumulatively, in combination with the effects of existing development (or given the probable
development of subsequent projects with similar effects) in the vicinity (i.e., within one mile) of the
proposed use, create a development pattern that constitutes low density sprawl; require the
extension of public facilities or expansion of public services in a manner that promotes low density
sprawl; or be otherwise incompatible with or injurious to the rural character of the area; (vi) For
designated agricultural lands, converts as little land with prime agricultural soils as practicable into
nonagricultural use.” JCC 18.20.350(3)(a)(v) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “If the preceding conditions (in subsection (3)(j) of this
section) cannot be met to the satisfaction of the approving authority, the use shall be denied.”
(Emphasis added.)
vii. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
viii. Measures to Reduce or Control Impacts to Forest Lands of Long-Term Significance: Measures to
reduce or control impacts to forest lands of long-term significance are:
A. Allows outdoor CSFs in forest resource lands only with a CUP, subject to the 12 CUP approval
criteria in JCC 18.40.530 (Exhibit 1) and the forest resource district protections in JCC 18.15.150
(Exhibit 3) and Table 3-1 (Exhibit 4).
B. Limits outdoor CSFs to only forest resource lands for projects that qualify as Small-Scale
Recreation or Tourist Uses. Small-Scale Recreation or Tourist Uses are limited by JCC
18.20.350(3) (Exhibit 8).
C. Limits outdoor CSFs in forest resource lands with a quota (approximately 150 acres total in the
328,785 acres of forest resource lands throughout the county).
D. Allows indoor CSFs with a CUP in rural/urban growth area (UGA) commercial and industrial
zoning (excluding resource-based industrial zoning), subject to the 12 CUP approval criteria in
JCC 18.40.530.
E. Continues to rely on existing laws that: (a) Require compliance with critical area, shoreline, and
wetlands buffers; (b) Limit nuisance noise; (c) Limit dangerous shooting of firearms; (d) Limit the
types of weapons that can be used; and, (e) Prohibit the use of any explosive devices.
F. Fixes the ambiguities identified in the no-action alternative items (2) to (5), discussed above in
response to Question A. 11.
G. Fixes the loopholes identified in the no-action alternative items (8) to (10), discussed above in
response to Question A. 11.
H. Adds the protections noted as missing in the no-action alternative items (11) to (23), including
the standards and Best Management Practices described below.
9. Housing [help]
a. Approximately how many units would be provided if any? Indicate whether high, middle, or low-income
housing. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Housing Units to be Provided, if any, Discussed at the Project Level. Housing units to be provided
will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
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January 6, 2020
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low-
income housing. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Housing Units to be Eliminated, if any, Discussed at the Project Level. Housing units to be eliminated
will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
c. Proposed measures to reduce or control housing impacts, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Proposed Measures to Reduce or Control Housing Impacts Discussed at the Project Level.
Proposed measures to reduce or control housing impacts will be discussed in a future project-level
SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
10. Aesthetics [help]
a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal
exterior building material(s) proposed? [help]
RESPONSE:
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January 6, 2020
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Tallest Height and Exterior Building Materials Discussed at the Project Level. Tallest height and
exterior building materials on a site will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Relevant Conditional Use Approval Criteria for CSF Projects: For future CSF projects subject to the
conditional use approval criteria, JCC 18.40.530(1)(e) that requires: “The location, size, and height
of buildings, structures, walls and fences, and screening vegetation for the conditional use will not
unreasonably interfere with allowable development or use of neighboring properties.”
v. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
b. What views in the immediate vicinity would be altered or obstructed? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Views Altered or Obstructed Discussed at the Project Level. Views altered or obstructed in the
immediate vicinity of a site will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Relevant Conditional Use Approval Criteria for CSF Projects: For future CSF projects subject to the
conditional use approval criteria, including JCC 18.40.530(1)(e) that requires: “The location, size,
and height of buildings, structures, walls and fences, and screening vegetation for the conditional
use will not unreasonably interfere with allowable development or use of neighboring properties.”
v. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(a)(iii) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “The associated commercial activities, in addition to the principal
recreational or tourist use, will not have a measurable detrimental traffic, noise, visual or public safety
impact on adjacent properties” and JCC 18.20.350(3)(f) requires that the applicant demonstrate to
the satisfaction of the approving authority that: “All activities shall, at a minimum, be screened from
the view of adjacent residential uses subject to the landscaping and screening requirements of JCC
18.30.130 and set back a sufficient distance from all rear and side property lines to protect the
character of adjacent and surrounding properties and uses. The approving authority may authorize
variations to the setbacks established in Table 6-1 in JCC 18.30.050 in order to ensure that any
small-scale recreation or tourist use or structure, when proposed in or adjacent to a rural residential
(RR) district, shall be compatible with and not disruptive to the character of existing and anticipated
future uses in the district.” (Emphasis added.)
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January 6, 2020
i. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
i. Protection Views at the Project Level: JCC 18.25.300(2) Requires building height limits when such
a height will obstruct the view of a substantial number of residences on or adjoining such shorelines.
JCC 18.25.310(2)(c) requires vegetation management to maintain views at shorelines.
c. Proposed measures to reduce or control aesthetic impacts, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Measures to Reduce or Control Aesthetic Impacts Discussed at the Project Level. Measures to
reduce or control aesthetic impacts will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Relevant Conditional Use Approval Criteria for CSF Projects: For future CSF projects subject to the
conditional use approval criteria, including JCC 18.40.530(1)(e) that requires: “The location, size,
and height of buildings, structures, walls and fences, and screening vegetation for the conditional
use will not unreasonably interfere with allowable development or use of neighboring properties,”
JCC 18.40.530(1)(j) that requires: “The conditional use has merit and value for the community as a
whole,” JCC 18.40.530(1)(k) that requires: “The conditional use is consistent with all relevant goals
and policies of the Jefferson County Comprehensive Plan,” and, JCC 18.40.530(1)(l) that requires:
“The public interest suffers no substantial detrimental effect. Consideration shall be given to the
cumulative effect of similar actions in the area.”
v. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(a)(iii) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “The associated commercial activities, in addition to the principal
recreational or tourist use, will not have a measurable detrimental traffic, noise, visual or public safety
impact on adjacent properties” and JCC 18.20.350(3)(f) requires that the applicant demonstrate to
the satisfaction of the approving authority that: “All activities shall, at a minimum, be screened from
the view of adjacent residential uses subject to the landscaping and screening requirements of JCC
18.30.130 and set back a sufficient distance from all rear and side property lines to protect the
character of adjacent and surrounding properties and uses. The approving authority may authorize
variations to the setbacks established in Table 6-1 in JCC 18.30.050 to ensure that any small-scale
recreation or tourist use or structure, when proposed in or adjacent to a rural residential (RR) district,
shall be compatible with and not disruptive to the character of existing and anticipated future uses in
the district.” (Emphasis added.)
vi. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
vii. Protection Aesthetic Impacts at the Project Level: JCC 18.25.300(2) Requires building height limits
when such a height will obstruct the view of a substantial number of residences on or adjoining such
shorelines. JCC 18.25.310(2)(c) requires vegetation management to maintain views at shorelines.
Page 61 of 95
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January 6, 2020
11. Light and Glare [help]
a. What type of light or glare will the proposal produce? What time of day would it mainly occur? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Light or Glare Discussed at the Project Level. The type of light or glare a proposal produces will be
discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(h) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “(h) Structures shall comply with the landscape, lighting, site coverage, and
design standards set forth in Chapter 18.30 JCC.” (Emphasis added.)
i. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
ii. Protection Against Light or Glare Impacts at the Project Level: JCC 18.30.140 contains Jefferson
County’s lighting regulations.
b. Could light or glare from the finished project be a safety hazard or interfere with views? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Light or Glare Discussed at the Project Level. The type of light or glare a proposal produces will be
discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
v. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(h) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “(h) Structures shall comply with the landscape, lighting, site coverage, and
design standards set forth in Chapter 18.30 JCC.” (Emphasis added.)
iii. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
iv. Protection Against Light or Glare Impacts at the Project Level: JCC 18.30.140 contains Jefferson
County’s lighting regulations.
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Environmental checklist (WAC 197-11-960)
January 6, 2020
c. What existing off-site sources of light or glare may affect your proposal? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Light or Glare Discussed at the Project Level. The type of light or glare a proposal produces will be
discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
vi. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(h) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “(h) Structures shall comply with the landscape, lighting, site coverage, and
design standards set forth in Chapter 18.30 JCC.” (Emphasis added.)
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
iv. Protection Against Light or Glare Impacts at the Project Level: JCC 18.30.140 contains Jefferson
County’s lighting regulations.
d. Proposed measures to reduce or control light and glare impacts, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Light or Glare Discussed at the Project Level. The type of light or glare a proposal produces will be
discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
vii. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(h) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “(h) Structures shall comply with the landscape, lighting, site coverage, and
design standards set forth in Chapter 18.30 JCC.” (Emphasis added.)
v. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
iv. Protection Against Light or Glare Impacts at the Project Level: JCC 18.30.140 contains Jefferson
County’s lighting regulations.
Page 63 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
12. Recreation [help]
a. What designated and informal recreational opportunities are in the immediate vicinity? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Designated and Informal Recreational Opportunities Discussed at the Project Level. Designated and
informal recreational opportunities will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
b. Would the proposed project displace any existing recreational uses? If so, describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Displacement of Recreational Opportunities Discussed at the Project Level. Displacement of
recreational opportunities will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
c. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be
provided by the project or applicant, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Measures to Reduce or Control Impacts On Recreation Discussed at the Project Level. Measures to
reduce or control impacts on recreation will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
Page 64 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection of Recreation at the Project Level: Flood control structure regulations: (a) Prohibit flood
control structures and stream channelization projects that damage fish and wildlife resources,
recreation, or aesthetic resources, or create high flood stages and velocities. Jefferson County Code
18.25.380(3)(e); and, (b) Require that flood control structures not adversely affect valuable recreation
resources and aesthetic values such as point and channel bars, islands, and braided banks.
Jefferson County Code 18.25.380(3)(g).
vi. Additional Protection for Impacts to Recreation Required by the Proposal at the Project Level: All
alternatives, excluding the no-action alternative, include extensive measures to ensure that the
projectiles at CSFs are fully contained and have no adverse impact on surrounding recreation within
forest resource lands. First, the proposal requires that CSFs must be designed and operated so that
when firearms are operating in accordance with rules and regulations approved as part of an
application for operation of a CSF under the Title 8 Ordinance and for siting and design of a CSF
under the Title 18 Ordinance, all projectiles must be kept from leaving any shooting range or the
CSF. Second, compliance with the NRA Range Source Book is required, which contains extensive
substantive standards relating to the containment of projectiles at CSFs and measures to prevent
stray bullets. Third, compliance with environmental BMPs is required. Finally, any noise impacts on
recreation should be evaluated and mitigated under the discretionary use or CUP approval process.
13. Historic and cultural preservation [help]
a. Are there any buildings, structures, or sites, located on or near the site that are over 45 years old listed
in or eligible for listing in national, state, or local preservation registers? If so, specifically describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Buildings, Structures or Sites Over 45 Years Old Listed in or Eligible for Listing in Preservation
Registers: Any buildings, structures, or sites, located on or near the site that are over 45 years old
listed in or eligible for listing in national, state, or local preservation registers will be discussed in a
future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Historic and Cultural Preservation at the Project Level: Jefferson County’s Archaeological and
Historic Resources Regulation, JCC 18.30.160 requires:
(1) When an application for a permit is received for an area known to contain archaeological
artifacts and data as identified by appropriate state, federal or tribal agencies, the county
shall not take action on the application and shall inform the applicant thereof, and the
applicant shall not initiate any excavation or development activity until the site has been
inspected and a written evaluation is provided by a qualified archaeologist. Significant
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Environmental checklist (WAC 197-11-960)
January 6, 2020
archaeological data or artifacts must be recovered before work begins or resumes on a
project. No application will be delayed more than 10 working days for such an inspection. If
the application is approved by the county, conditions shall be attached reflecting the
recommendations of the archaeologist regarding preservation or protection of the site.
(2) All permits shall contain a special provision advising the permit holder that if during
excavation or development of the site an area of potential archaeological significance is
uncovered, all activity in the immediate vicinity of the find must be halted immediately and
the administrator must be notified at once. Activities authorized by the permit will not be
delayed more than five working days for a finding of significance by the administrator,
following the administrator’s receipt of notification, unless the permit holder agrees to an
extension of that time period.
(3) All development proposed for location adjacent to sites which are listed or are determined
by the appropriate state or federal authority to be eligible for listing in the state or national
registers of historic places must be located so as to complement the historic site.
Development which degrades or destroys the historical character of such sites is not
permitted.
(4) Archaeological sites are subject to Chapter 27.44 RCW (Indian Graves and Records) and
Chapter 27.53 RCW (Archaeological Sites and Records) and must comply with Chapter 25-
48 WAC (Archaeological Excavation and Removal Permit). Archaeological excavations are
allowed subject to applicable state laws.
(5) Identified historical or archaeological resources must be considered in site planning for
public parks, public open space, and public access and site planning, with access to such
areas designed and managed so as to give maximum protection to the resource.
When individual projects are analyzed to ensure compliance with Jefferson County’s Archaeological and
Historic Resources Regulation, the County: (a) will utilize GIS, surveys, and databases; and, (b) as
necessary, consult with the tribes and Washington Department of Archeology and Historic Preservation.
b. Are there any landmarks, features, or other evidence of Indian or historic use or occupation? This may
include human burials or old cemeteries. Are there any material evidence, artifacts, or areas of cultural
importance on or near the site? Please list any professional studies conducted at the site to identify such
resources. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Landmarks, Features, or Other Evidence of Indian or Historic Use or Occupation: Any landmarks,
features, or other evidence of Indian or historic use or occupation will be discussed in a future project-
level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
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Environmental checklist (WAC 197-11-960)
January 6, 2020
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Historic and Cultural Preservation at the Project Level: Jefferson County’s Archaeological and
Historic Resources Regulation, JCC 18.30.160 requires:
(1) When an application for a permit is received for an area known to contain archaeological
artifacts and data as identified by appropriate state, federal or tribal agencies, the county
shall not take action on the application and shall inform the applicant thereof, and the
applicant shall not initiate any excavation or development activity until the site has been
inspected and a written evaluation is provided by a qualified archaeologist. Significant
archaeological data or artifacts must be recovered before work begins or resumes on a
project. No application will be delayed more than 10 working days for such an inspection. If
the application is approved by the county, conditions shall be attached reflecting the
recommendations of the archaeologist regarding preservation or protection of the site.
(2) All permits shall contain a special provision advising the permit holder that if during
excavation or development of the site an area of potential archaeological significance is
uncovered, all activity in the immediate vicinity of the find must be halted immediately and
the administrator must be notified at once. Activities authorized by the permit will not be
delayed more than five working days for a finding of significance by the administrator,
following the administrator’s receipt of notification, unless the permit holder agrees to an
extension of that time period.
(3) All development proposed for location adjacent to sites which are listed or are determined
by the appropriate state or federal authority to be eligible for listing in the state or national
registers of historic places must be located so as to complement the historic site.
Development which degrades or destroys the historical character of such sites is not
permitted.
(4) Archaeological sites are subject to Chapter 27.44 RCW (Indian Graves and Records) and
Chapter 27.53 RCW (Archaeological Sites and Records) and must comply with Chapter 25-
48 WAC (Archaeological Excavation and Removal Permit). Archaeological excavations are
allowed subject to applicable state laws.
(5) Identified historical or archaeological resources must be considered in site planning for
public parks, public open space, and public access and site planning, with access to such
areas designed and managed so as to give maximum protection to the resource.
When individual projects are analyzed to ensure compliance with Jefferson County’s Archaeological and
Historic Resources Regulation, the County: (a) will utilize GIS, surveys, and databases; and, (b) As
necessary, consult with the tribes and Washington Department of Archeology and Historic Preservation.
c. Describe the methods used to assess the potential impacts to cultural and historic resources on or near
the project site. Examples include consultation with tribes and the department of archeology and historic
preservation, archaeological surveys, historic maps, GIS data, etc. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
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ii. Methods Used to Assess the Potential Impacts to Cultural and Historic Resources on or Near the
Project Site. Methods used to assess the potential impacts to cultural and historic resources on or
near a project site will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Historic and Cultural Preservation at the Project Level: Jefferson County’s Archaeological and
Historic Resources Regulation, JCC 18.30.160 requires:
(1) When an application for a permit is received for an area known to contain archaeological
artifacts and data as identified by appropriate state, federal or tribal agencies, the county
shall not take action on the application and shall inform the applicant thereof, and the
applicant shall not initiate any excavation or development activity until the site has been
inspected and a written evaluation is provided by a qualified archaeologist. Significant
archaeological data or artifacts must be recovered before work begins or resumes on a
project. No application will be delayed more than 10 working days for such an inspection. If
the application is approved by the county, conditions shall be attached reflecting the
recommendations of the archaeologist regarding preservation or protection of the site.
(2) All permits shall contain a special provision advising the permit holder that if during
excavation or development of the site an area of potential archaeological significance is
uncovered, all activity in the immediate vicinity of the find must be halted immediately and
the administrator must be notified at once. Activities authorized by the permit will not be
delayed more than five working days for a finding of significance by the administrator,
following the administrator’s receipt of notification, unless the permit holder agrees to an
extension of that time period.
(3) All development proposed for location adjacent to sites which are listed or are determined
by the appropriate state or federal authority to be eligible for listing in the state or national
registers of historic places must be located so as to complement the historic site.
Development which degrades or destroys the historical character of such sites is not
permitted.
(4) Archaeological sites are subject to Chapter 27.44 RCW (Indian Graves and Records) and
Chapter 27.53 RCW (Archaeological Sites and Records) and must comply with Chapter 25-
48 WAC (Archaeological Excavation and Removal Permit). Archaeological excavations are
allowed subject to applicable state laws.
(5) Identified historical or archaeological resources must be considered in site planning for
public parks, public open space, and public access and site planning, with access to such
areas designed and managed so as to give maximum protection to the resource.
When individual projects are analyzed to ensure compliance with Jefferson County’s Archaeological and
Historic Resources Regulation, the County: (a) will utilize GIS, surveys, and databases; and, (b) As
necessary, consult with the tribes and Washington Department of Archeology and Historic Preservation.
Page 68 of 95
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Environmental checklist (WAC 197-11-960)
January 6, 2020
d. Proposed measures to avoid, minimize, or compensate for loss, changes to, and disturbance to
resources. Please include plans for the above and any permits that may be required. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Measures to Avoid, Minimize, or Compensate for Loss, Changes to, and Disturbance to Cultural and
Historic Resources on or Near the Project Site. Proposed measures to avoid, minimize, or
compensate for loss, changes to, and disturbance to resources on or near a project site will be
discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Historic and Cultural Preservation at the Project Level: Jefferson County’s Archaeological and
Historic Resources Regulation, JCC 18.30.160 requires:
(1) When an application for a permit is received for an area known to contain archaeological
artifacts and data as identified by appropriate state, federal or tribal agencies, the county
shall not take action on the application and shall inform the applicant thereof, and the
applicant shall not initiate any excavation or development activity until the site has been
inspected and a written evaluation is provided by a qualified archaeologist. Significant
archaeological data or artifacts must be recovered before work begins or resumes on a
project. No application will be delayed more than 10 working days for such an inspection. If
the application is approved by the county, conditions shall be attached reflecting the
recommendations of the archaeologist regarding preservation or protection of the site.
(2) All permits shall contain a special provision advising the permit holder that if during
excavation or development of the site an area of potential archaeological significance is
uncovered, all activity in the immediate vicinity of the find must be halted immediately and
the administrator must be notified at once. Activities authorized by the permit will not be
delayed more than five working days for a finding of significance by the administrator,
following the administrator’s receipt of notification, unless the permit holder agrees to an
extension of that time period.
(3) All development proposed for location adjacent to sites which are listed or are determined
by the appropriate state or federal authority to be eligible for listing in the state or national
registers of historic places must be located so as to complement the historic site.
Development which degrades or destroys the historical character of such sites is not
permitted.
(4) Archaeological sites are subject to Chapter 27.44 RCW (Indian Graves and Records) and
Chapter 27.53 RCW (Archaeological Sites and Records) and must comply with Chapter 25-
48 WAC (Archaeological Excavation and Removal Permit). Archaeological excavations are
allowed subject to applicable state laws.
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Environmental checklist (WAC 197-11-960)
January 6, 2020
(5) Identified historical or archaeological resources must be considered in site planning for
public parks, public open space, and public access and site planning, with access to such
areas designed and managed so as to give maximum protection to the resource.
When individual projects are analyzed to ensure compliance with Jefferson County’s Archaeological and
Historic Resources Regulation, the County: (a) will utilize GIS, surveys, and databases; and, (b) As
necessary, consult with the tribes and Washington Department of Archeology and Historic Preservation.
14. Transportation [help]
a. Identify public streets and highways serving the site or affected geographic area and describe proposed
access to the existing street system. Show on-site plans, if any. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Public Streets and Highways Serving the Site or Affected Geographic Area and Proposed Access to
Existing Street System Discussed at the Project Level. Public streets and highways serving a site or
affected geographic area and proposed access to the existing street system on a site will be
discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(g) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “All small-scale recreation or tourist uses shall use local access or minor
collector roads for primary access whenever practicable. Access off of state routes, arterials, or major
collector roads may be allowed if access improvements or a traffic analysis assure mobility is not
degraded.” (Emphasis added.)
i. Requirements for Transportation at the Project Level: JCC 18.30.020(5) requires:
All land use activities shall be served by appropriate transportation facilities. Transportation
facilities shall be adequate to meet the level of service standards adopted in the Jefferson
County Comprehensive Plan and the appropriate design standards referenced in
JCC 18.30.080(1)(a). If transportation facilities would become inadequate, the applicant shall
be required to provide necessary improvements and/or implement alternative measures such
as transportation demand management (TDM), project phasing, or other measures
acceptable to Jefferson County that will maintain the adopted level of service standards and
meet design standards. If transportation facilities are not adequate, Jefferson County shall
not approve the proposed development. Transportation facilities shall be deemed adequate
if necessary, improvements are planned and designated funding is secured in the Jefferson
County Six-Year Transportation Improvement Program.
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January 6, 2020
b. Is the site or affected geographic area currently served by public transit? If so, generally describe. If not,
what is the approximate distance to the nearest transit stop? [help]
RESPONSE:
v. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
vi. Service by Public Transportation. Service by public transportation on a site or an affected
geographical area will be discussed in a future project-level SEPA checklist.
vii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
viii. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
ix. Requirements for Transportation at the Project Level: JCC 18.30.020(5) requires:
All land use activities shall be served by appropriate transportation facilities. Transportation
facilities shall be adequate to meet the level of service standards adopted in the Jefferson
County Comprehensive Plan and the appropriate design standards referenced in
JCC 18.30.080(1)(a). If transportation facilities would become inadequate, the applicant shall
be required to provide necessary improvements and/or implement alternative measures such
as transportation demand management (TDM), project phasing, or other measures
acceptable to Jefferson County that will maintain the adopted level of service standards and
meet design standards. If transportation facilities are not adequate, Jefferson County shall
not approve the proposed development. Transportation facilities shall be deemed adequate
if necessary, improvements are planned and designated funding is secured in the Jefferson
County Six-Year Transportation Improvement Program.
c. How many additional parking spaces would the completed project or non-project proposal have? How
many would the project or proposal eliminate? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Parking Spaces. Parking spaces will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(e) requires that the applicant demonstrate to the satisfaction of the
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Environmental checklist (WAC 197-11-960)
January 6, 2020
approving authority that: “Parking shall be contained on-site and provided in conformance with this
code, including JCC 18.30.100 and 18.30.130.”
i. Requirements for Parking at the Project Level: JCC 18.30.020(3) requires: “No part of a yard, or
other open space, or off-street parking or loading space required about or in connection with any
building for the purpose of complying with this chapter, shall be included as part of a yard, open
space or off-street parking or loading space similarly required for any other building or structure”
d. Will the proposal require any new or improvements to existing roads, streets, pedestrian, bicycle or state
transportation facilities, not including driveways? If so, generally describe (indicate whether public or
private). [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Required New or Improvements to Existing Roads, Streets, Pedestrian, Bicycle or State
Transportation Facilities Discussed at the Project Level. Any required new or improvements to
existing roads, streets, pedestrian, bicycle or state transportation facilities will be discussed in a future
project-level SEPA checklist. Several segments of state routes in unincorporated Jefferson County
have exceeded their accepted level of service. See Jefferson County Comprehensive Plan, pg. 6-
10. However, these areas are limited and discrete. Since CSFs are not listed use in the ITE Trip
Generation Manual, a traffic study will likely be required for new CSFs as a part of the CUP or
discretionary use process and/or SEPA review.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(g) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “All small-scale recreation or tourist uses shall utilize local access or minor
collector roads for primary access whenever practicable. Access off of state routes, arterials, or major
collector roads may be allowed if access improvements or a traffic analysis assure mobility is not
degraded.” (Emphasis added.)
v. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
vi. Requirements for Transportation at the Project Level: JCC 18.30.020(5) requires:
All land use activities shall be served by appropriate transportation facilities. Transportation
facilities shall be adequate to meet the level of service standards adopted in the Jefferson
County Comprehensive Plan and the appropriate design standards referenced in
JCC 18.30.080(1)(a). If transportation facilities would become inadequate, the applicant shall
be required to provide necessary improvements and/or implement alternative measures such
as transportation demand management (TDM), project phasing, or other measures
acceptable to Jefferson County that will maintain the adopted level of service standards and
meet design standards. If transportation facilities are not adequate, Jefferson County shall
not approve the proposed development. Transportation facilities shall be deemed adequate
if necessary, improvements are planned and designated funding is secured in the Jefferson
County Six-Year Transportation Improvement Program.
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Environmental checklist (WAC 197-11-960)
January 6, 2020
e. Will the project or proposal use (or occur in the immediate vicinity of) water, rail, or air transportation? If
so, generally describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Use of Water, Rail or Air Transportation Discussed at the Project Level: Use of water, rail or air
transportation for a project will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Requirements for Transportation at the Project Level: JCC 18.30.020(5) requires:
All land use activities shall be served by appropriate transportation facilities. Transportation
facilities shall be adequate to meet the level of service standards adopted in the Jefferson
County Comprehensive Plan and the appropriate design standards referenced in
JCC 18.30.080(1)(a). If transportation facilities would become inadequate, the applicant shall
be required to provide necessary improvements and/or implement alternative measures such
as transportation demand management (TDM), project phasing, or other measures
acceptable to Jefferson County that will maintain the adopted level of service standards and
meet design standards. If transportation facilities are not adequate, Jefferson County shall
not approve the proposed development. Transportation facilities shall be deemed adequate
if necessary, improvements are planned and designated funding is secured in the Jefferson
County Six-Year Transportation Improvement Program.
f. How many vehicular trips per day would be generated by the completed project or proposal? If known,
indicate when peak volumes would occur and what percentage of the volume would be trucks (such as
commercial and nonpassenger vehicles). What data or transportation models were used to make these
estimates? [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Vehicular Trips per Day Discussed at the Project Level. Vehicular trips per day for a project will be
discussed in a future project-level SEPA checklist. CSFs are not listed use in the ITE Trip Generation
Manual; a traffic study will likely be required for new CSFs as a part of the CUP or discretionary use
process and/or SEPA review.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
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Environmental checklist (WAC 197-11-960)
January 6, 2020
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
g. Will the proposal interfere with, affect, or be affected by the movement of agricultural and forest products
on roads or streets in the area? If so, generally describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Interference or Affect by Movement of Agricultural and Forest Products: Any interference or effect
on a project by the movement of agricultural and forest products on roads or streets in the area will
be discussed in a future project-level SEPA checklist. CSFs are not listed use in the ITE Trip
Generation Manual, a traffic study will likely be required for new CSFs as a part of the CUP or
discretionary use process and/or SEPA review.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria, JCC 18.20.350(3)(g) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “All small-scale recreation or tourist uses shall utilize local access or minor
collector roads for primary access whenever practicable. Access off of state routes, arterials, or major
collector roads may be allowed if access improvements or a traffic analysis assure mobility is not
degraded.”
h. Proposed measures to reduce or control transportation impacts, if any: [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Measures to Reduce or Control Transportation Impacts Discussed at the Project Level: Any
measures to reduce or control transportation impacts will be discussed in a future project-level SEPA
checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
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January 6, 2020
15. Public Services [help]
a. Would the project result in an increased need for public services (for example fire protection, police
protection, public transit, health care, schools, other)? If so, generally describe. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Increased Need for Public Services Discussed at the Project Level: Any increased need for public
services for a project will be discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria: (a) JCC 18.20.350(3)(a)(vi) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “The public facilities and services provided are limited to those necessary
to serve the associated commercial activities and the principal small-scale recreational or tourist use
in a manner that does not permit low-density sprawl;” and, (b) JCC 18.20.350(3)(j) requires that the
applicant demonstrate to the satisfaction of the approving authority that: “For any small-scale
recreation or tourist use, the county shall impose such reasonable conditions (e.g., location and size
restrictions, design standards, landscape buffers, setbacks, etc.) as are found necessary by the
approving authority to ensure that the activity or use, due to proximity, location or intensity: … (iii) Is
adequately served by public facilities and services (including roadway level of service and minimum
fire flow requirements) without the need to extend those services in a manner that promotes low
density sprawl; … (v) Would not cumulatively, in combination with the effects of existing development
(or given the probable development of subsequent projects with similar effects) in the vicinity (i.e.,
within one mile) of the proposed use, create a development pattern that constitutes low density
sprawl; require the extension of public facilities or expansion of public services in a manner that
promotes low density sprawl, or be otherwise incompatible with or injurious to the rural character of
the area.” JCC 18.20.350(3)(a)(v) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “If the preceding conditions (in subsection (3)(j) of this section) cannot be
met to the satisfaction of the approving authority, the use shall be denied.” (Emphasis added.)
v. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
vi. It is anticipated that CSFs may require fire protection, police protection, and public transit. Given the
quota and development regulations imposed in all the alternatives (excluding the no-action), it is
unlikely that any additional need will result in decreased levels of service or response times.
b. Proposed measures to reduce or control direct impacts on public services, if any. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
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Environmental checklist (WAC 197-11-960)
January 6, 2020
ii. Measures to Reduce or Control Direct Impacts on Public Services Discussed at the Project Level:
Any measures to reduce or control direct impacts on public services for a project will be discussed
in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Relevant Small-Scale Recreation or Tourist Use Approval Criteria for CSF Projects in Forest
Resource Zones: For future CSF projects subject to the small-scale recreation or tourist approval
criteria: (a) JCC 18.20.350(3)(a)(vi) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “The public facilities and services provided are limited to those necessary
to serve the associated commercial activities and the principal small-scale recreational or tourist use
in a manner that does not permit low-density sprawl;” and, (b) JCC 18.20.350(3)(j) requires that the
applicant demonstrate to the satisfaction of the approving authority that: “For any small-scale
recreation or tourist use, the county shall impose such reasonable conditions (e.g., location and size
restrictions, design standards, landscape buffers, setbacks, etc.) as are found necessary by the
approving authority to ensure that the activity or use, due to proximity, location or intensity: … (iii) Is
adequately served by public facilities and services (including roadway level of service and minimum
fire flow requirements) without the need to extend those services in a manner that promotes low
density sprawl; … (v) Would not cumulatively, in combination with the effects of existing development
(or given the probable development of subsequent projects with similar effects) in the vicinity (i.e.,
within one mile) of the proposed use, create a development pattern that constitutes low density
sprawl; require the extension of public facilities or expansion of public services in a manner that
promotes low density sprawl, or be otherwise incompatible with or injurious to the rural character of
the area.” JCC 18.20.350(3)(a)(v) requires that the applicant demonstrate to the satisfaction of the
approving authority that: “If the preceding conditions (in subsection (3)(j) of this section) cannot be
met to the satisfaction of the approving authority, the use shall be denied.” (Emphasis added.)
v. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above. Specifically, BMPs
and development regulations will limit the direct impact on public services by designing and running
a safe CSF. For example, the legislative alternative will require containment of the CSF, compliance
with the 2012 NRS Range Source Book, and that the CSF develop and implement rules and
regulations for end users of the CSF.
16. Utilities [help]
a. Circle utilities currently available at the site: [help]
electricity, natural gas, water, refuse service, telephone, sanitary sewer, septic system, other
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Utilities Currently Available Discussed at the Project Level: Any utilities available for a site will be
discussed in a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
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performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection Related to Utilities at the Project Level: JCC 18.25.320(2)(b) requires that to avoid water
quality degradation by malfunctioning or failing septic systems, on-site sewage systems shall be
located and designed to meet all applicable water quality, utility, and health standards.
b. Describe the utilities that are proposed for the project, the utility providing the service, and the general
construction activities on the site or in the immediate vicinity which might be needed. [help]
RESPONSE:
i. Not a Project Proposal: There is no “project” or “site” for this proposal. This is a non-project proposal
for legislation that amends the Jefferson County Code.
ii. Utilities Proposed Described at the Project Level. Utilities proposed for a project will be discussed in
a future project-level SEPA checklist.
iii. SEPA Review and Regulatory Protection Required at the Project Level: Under each of the
alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). See Chapters 18.15, 18.20 and 18.30 JCC for development and
performance standards. See also JCC 18.40.530 for the 12 CUP approval criteria (Exhibit 1) and
JCC 18.15.045 for the discretionary use criteria (Exhibit 2).
iv. Additional Protections in Alternatives 1 through 5: Additional protections for human health and the
environment for Alternatives 1 through 5, compared to the no-action alternative, are described in
detail in the Brief and Complete Discussion in response to Question A.11, above.
v. Protection Related to Utilities at the Project Level: JCC 18.25.320(2)(b) requires that to avoid water
quality degradation by malfunctioning or failing septic systems, on-site sewage systems shall be
located and designed to meet all applicable water quality, utility, and health standards.
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D. Supplemental Sheet for Nonproject Actions [help]
(IT IS NOT NECESSARY to use this sheet for project actions)
Because these questions are very general, it may be helpful to read them in conjunction with the list
of the elements of the environment.
When answering these questions, be aware of the extent the proposal, or the types of activities likely
to result from the proposal, would affect the item at a greater intensity or at a faster rate than if the
proposal were not implemented. Respond briefly and in general terms.
1. How would the proposal be likely to increase discharge to water; emissions to air;
production, storage, or release of toxic or hazardous substances; or production of noise?
RESPONSE:
Whether the Proposal Likely Would Result in an Increase Discharge to Water:
Under each of the alternatives listed in the Brief and Complete Discussion in response to Question A.11,
above, including the no-action alternative, there is a possibility of increase of discharges to water.
Alternatives 1 through 5 allow indoor or outdoor CSFs in certain zoning districts, either as a discretionary
use, or pursuant to a CUP. Development of individual CSF projects may result in additional impervious
square footage which typically increases stormwater runoff. However, any impacts will be mitigated because
each new CSF project proposal must comply with all applicable laws and regulations, including SEPA and
its implementing regulations, and Chapter 18.40, Article X JCC (SEPA Implementation). A summary of the
protections afforded in the Jefferson County Code is attached as Exhibit 11. Specifically, the proposal
requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance), including JCC 18.22.130, which provides protection
standards for groundwater in susceptible aquifer recharge and special aquifer protection areas.
Alternatives 1 through 5 do not propose any changes to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program), including JCC 18.25.320(2)(d), which prohibits
discharging solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water
or to be discharged onto land. Alternatives 1 through 5 do not propose any changes to the Shoreline
Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels and JCC 18.30.050 and JCC 18.30.070(5),
which contain impervious surface regulations.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
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For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
Whether the Proposal Likely Would Result in an Increase Emissions to Air:
Under each of the alternatives listed in the Brief and Complete Discussion in response to Question A.11,
above, including the no-action alternative, there likely will be an increase in air emissions, mostly from
automobile vehicle trips and possibly from the gases produced from igniting the cap in a cartridge in a firearm
at a CSF. At this time, the project details are unknown, so it is not possible to accurately forecast the
emissions as the vehicle count for any CSF or from the igniting caps in cartridges in a firearm at a CSF.
When a cartridge is shot, and before the projectile leaves the gun, all the powder grains should be completely
burnt; however, if this ideal case does not happen, it is possible to find unburnt or partially burnt powder
particles. K.-M. Pun, A. Gallusser, Macroscopic observation of the morphological characteristics of the
ammunition gunpowder, Forensic Sci. Int.; 175(2-3), 179-185 (2008) (Pun and Gallusser 2008). Firing a
weapon produces combustion of both the primer and powder of the cartridge. Gunpowder or “black powder”
is no longer used in modern firearms. The powder used in modern ammunition is known as smokeless
powder. Smokeless power mostly is made of nitrocellulose, also known as cellulose nitrate, guncotton, and
NC. There also may be trace amounts of other chemicals in smokeless powder. For handguns and shotgun
loads nitrocellulose is enhanced with nitroglycerin. The residue of the combustion products, called gunshot
residue (GSR), can consist of both burned and unburned primer or powder components, combined with
additional residues from the surface of the bullet, surface of the cartridge case, and lubricants used on the
firearm. Residues can be either inorganic or organic in nature. C. Vachon and M. Martinez, Understanding
Gunshot Residue Evidence and Its Role in Forensic Science, Am J Forensic Med Pathol (2019); 40: 210–
219 (Vachon and Martinez, 2019). Residues most often derive from the primer cap, which typically contains
a mixture of components: the shock-sensitive explosive lead styphnate, oxidizer barium nitrate, and
antimony sulfide fuel. Thus, the most commonly encountered residue metals are lead (Pb), barium (Ba), and
antimony (Sb). (Vachon and Martinez, 2019). Less common elements in GSR include aluminum (Al), sulfur
(S), tin (Sn), calcium (Ca), potassium (K), chlorine (Cl), copper (Cu), strontium (Sr), zinc (Zn), titanium (Ti),
or silicon (Si). How much GSR is produced depends upon a number of factors including, the size and
geometry of the powder grains, the variability of the color of the powder, the length of the barrel and the type
of base of the bullet. (Pun and Gallusser 2008). However, it should be noted that the rural/UGA commercial
and industrial zoning districts permit similar development patterns which would result in similar air emission
impacts regardless of this proposal. Further, any impacts will be mitigated because each new CSF project
proposal must comply with all applicable laws and regulations, including SEPA and its implementing
regulations, and Chapter 18.40, Article X JCC (SEPA Implementation). A summary of the protections
afforded in the Jefferson County Code is attached as Exhibit 11. Specifically, the proposal requires
compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance). Alternatives 1 through 5 do not propose any changes
to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program). Alternatives 1 through 5 do not propose any
changes to the Shoreline Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
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For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) that requires:
“The conditional use will not cause significant adverse impacts on the human or natural environments that
cannot be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
If an alternative is selected which allows outdoor CSF, there is a possibility of lead dust ingestion by animals
or humans. However, a future project applicant is required to comply with USEPA Region 2 Best
Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9). The BMPs require that the CSF
control and contain the lead dust, that they prevent migration, that they remove and recycle the lead, and
that they document activities and keep records.
Whether the Proposal Likely Would Result in Production or Release of Toxic or Hazardous Substances:
Under each of the alternatives listed in the Brief and Complete Discussion in response to Question A.11,
above, including the no-action alternative, there likely will be the discharge of hazardous materials into the
surrounding environment. Lead is the primary environmental concern from indoor and outdoor CSFs. A 2017
National Institute of Health Journal Article reviewed existing scientific studies concluding that users of
shooting ranges had lead exposure above the US Center for Disease Control (CDC) recommended blood
levels. Lead Exposure at Firing Ranges – A Review, Environmental Health, National Institutes of Health,
available at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5379568/. Generally, lead can be introduced into
the environment in the following three ways:
Lead oxides when exposed to air and dissolves when exposed to acidic water or soil;
Lead bullets, bullet particles, or dissolved lead can be moved by stormwater runoff; and,
Dissolved lead can migrate through soils to groundwater.
However, any impacts will be mitigated because each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). A summary of the protections afforded in the Jefferson County Code is
attached as Exhibit 11. Specifically, the proposal requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance), including JCC 18.22.130, which provides protection
standards for groundwater in susceptible aquifer recharge and special aquifer protection areas.
Alternatives 1 through 5 do not propose any changes to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program), including JCC 18.25.320(2)(d), which prohibits
discharging solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water
or to be discharged onto land. Alternatives 1 through 5 do not propose any changes to the Shoreline
Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
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For future CSF projects subject to the conditional use approval criteria, Jefferson County Code
18.40.530(1)(i) requires: “The conditional use will not cause significant adverse impacts on the human or
natural environments that cannot be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, Jefferson County Code
18.15.045(2)(a) requires that the project: “Will not result in impacts on the human or natural environments
determined by the administrator to require review as a conditional use.”
If an alternative is selected which allows outdoor CSF, there is a possibility of lead discharge through
stormwater runoff into surface waters (if the proposal is close enough to surface waters) or ingestion by
animals or humans. However, a future project applicant is required to comply with USEPA Region 2 Best
Management Practices for Lead at Outdoor Shooting Ranges (Exhibit 9). The BMPs require that the CSF
control and contain the lead, that they prevent migration, that they remove and recycle the lead, and that
they document activities and keep records. See Exhibit 9, USEPA Region 2 Best Management Practices for
Lead at Outdoor Shooting Ranges. Range workers may be exposed to lead dust while performing routine
maintenance or by direct contact with lead. Id. However “[t]he relative risk of lead exposure to people in a
well-managed facility is low.” Id. Lead exposure and environmental contamination at outdoor shooting
ranges will be mitigated through BMPs. This BMP states “[t]he relative risk of lead exposure to people in a
well-managed facility is low.”
Figure 3-1, above, describes the lead management BMPs for outdoor shooting ranges. The proposal
requires compliance with these BMPs. These BMPs should reduce lead exposure to human, animals,
stormwater runoff, and groundwater to levels which will not have an adverse impact on the environment.
See Exhibit 9.
Lead exposure and environmental contamination for indoor CSFs will be mitigated through BMPs. The
National Institute for Occupational Safety and Health (NIOSH) in its 2009 publication entitled NIOSH Alert –
Preventing Exposures to Lead and Noise at Indoor Firing Ranges issued BMPs for lead exposure at indoor
CSFs. These BMPs require several lead mitigation actions, such as providing information and training on
lead exposure, establishing effective engineering and administrative controls, and recommends that
protective covering is worn (e.g., full outer clothing, respirators, and eye protection). The BMPs require well-
designed heating, ventilation, and air condition (HVAC) controls. See Exhibit 10.
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Whether the Proposal Likely Would Result in Production Noise:
Under all the alternatives, CSFs likely would result in the production of noise. A 2011 study by the Centers
for Disease Control, observed peak noise levels of 160 dba when discharging certain types of weapons.
Noise and Lead Exposures at an Outdoor Firing Range – California, Centers for Disease Control and
Prevention, National Institute for Occupational Safety and Health, available at
https://www.cdc.gov/niosh/hhe/reports/pdfs/2011-0069-3140.pdf. Noise impacts at outdoor CSFs likely will
impact human users, nearby animals, and potentially surrounding properties. Noise impacts at indoor CSFs
will impact human users. Noise impacts to animals and surrounding properties is not expected for indoor
CSFs. However, any impacts will be mitigated because each new CSF project proposal must comply with
all applicable laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40,
Article X JCC (SEPA Implementation). A summary of the protections afforded in the Jefferson County Code
is attached as Exhibit 11. Specifically, the proposal requires compliance with:
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.190, which incorporates noise mitigation requirements in the State Environmental Policy Act,
Chapter 43.21C RCW, related to noise abatement, and provides that noise shall not exceed the
requirements in Chapter 8.70 JCC and Chapter 173-60 WAC, as they exist now or may be amended
in the future.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
If an alternative is selected which allows outdoor CSFs, the proposal and alternatives require BMPs to
maximize sound suppression for operations, siting, and design consistent with Chapter 8.70 JCC (noise
control) and the NRA Range Source Book, including requiring protective ear coverings. Outdoor CSFs will
be a conditional use, which requires compliance with all 12 CUP approval criteria in the Jefferson County
Code. Of importance, the following CUP approval criteria states: “(d) The conditional use will not introduce
noise, smoke, dust, fumes, vibrations, odors, or other conditions or which unreasonably impact existing uses
in the vicinity of the subject parcel.” JCC 18.40.530(1)(d) (emphasis added).
If an alternative is selected which allows indoor CSFs, the indoor CSFs must comply with BMPs consistent
with Chapter 8.70 JCC (noise control), the NRA Range Source Book, and the National Institute for
Occupational Safety and Health (NIOSH) in its 2009 publication entitled NIOSH Alert – Preventing
Exposures to Lead and Noise at Indoor Firing Ranges. (Exhibit 10). This BMP suggests several techniques
to reduce the transmission of noise including sealing all physical leaks (electrical outlets, spaces around
doors, etc.), installing acoustical absorptive materials, and requiring users and workers to wear protective
ear coverings. The applicable manuals, in addition to the requirement that the CSFs maintain rules and
regulations should ensure that users and range workers will use protective ear coverings.
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Under Alternatives 1, 2, 3, and 4, some CSFs will require a CUP. The following CUP approval criteria states
“[t]he conditional use will not introduce noise, smoke, dust, fumes, vibrations, odors, or other conditions or
which unreasonably impact existing uses in the vicinity of the subject parcel”. JCC 18.40.530(1)(d).
(Emphasis added). This CUP criteria requires that the applicant demonstrate by a preponderance of the
evidence that noise impacts will not “unreasonably impact existing uses in the vicinity of the subject parcel”.
This will likely require individual, in-depth noise studies to demonstrate compliance with this regulation. This
analysis will be completed at the project level. Further, Jefferson County has authority to impose additional
conditions on CUPs to ensure that noise is properly abated when issuing the CUP. Under JCC 18.40.540,
the CUP may “[c]ontain restrictions or provisions deemed necessary to establish parity with uses permitted
in the same zone with respect to avoid nuisance generating features in matters of noise, odors, air pollution,
wastes, vibration, traffic, and physical hazards.” (Emphasis added.) If all 12 of the applicable CUP approval
criteria cannot be met by a preponderance of the evidence, the application must be denied. Further,
individual projects will be subject to SEPA review, including the substantive SEPA authority under an MDNS,
unless the project is exempt from SEPA review. SEPA review includes analysis of noise impacts.
Future CSF projects in forest resource lands will be subject to the small-scale recreation or tourist approval
criteria. JCC 18.20.350(3)(a)(iii) requires that the applicant demonstrate to the satisfaction of the approving
authority that: “The associated commercial activities, in addition to the principal recreational or tourist use,
will not have a measurable detrimental traffic, noise, visual or public safety impact on adjacent properties.”
(Emphasis added.)
2. How would the proposal be likely to affect plants, animals, fish, or marine life?
RESPONSE:
Whether the Proposal Likely Affects Plants:
CSFs may affect plants. However, any affects will be mitigated because each new CSF project proposal
must comply with all applicable laws and regulations, including SEPA and its implementing regulations, and
Chapter 18.40, Article X JCC (SEPA Implementation). A summary of the protections afforded in the Jefferson
County Code is attached as Exhibit 11. Specifically, the proposal requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance), including JCC 18.22.265, which requires a habitat
management plan; JCC 18.22.270, which provides protection standards on drainage and erosion
control for fish, wildlife habitat conservation areas; JCC 18.22.270(4), which requires vegetation
retention for any Fish and Wildlife Habitat Conservation Area and its buffer; JCC 18.22.310;
18.22.330; and, 18.22.350, which require wetland protection, buffers and mitigation. Alternatives 1
through 5 do not propose any changes to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program), including JCC 18.25.270(3)(h), which requires
vegetation maintenance in shoreline buffers; JCC 18.25.310, which contains vegetation conservation
regulations for shorelines; JCC 18.25.390(3)(i), which contains limitations on removal of vegetation
related to in-stream structures; and, JCC 18.25.320(2)(d), which prohibits discharging solid wastes,
liquid wastes and untreated effluents to any groundwater or surface water or to be discharged onto
land. Alternatives 1 through 5 do not propose any changes to the Shoreline Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
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Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
Whether the Proposal Likely Affects Animals:
CSFs may affect animals. First, stray bullets from a CSF could endanger animals. Second, USEPA Region
2 Best Management Practices for Lead at Outdoor Shooting Ranges states “[d]etrimental effects due to
elevated lead levels can also be found in animals. Excessive exposure to lead, primarily from ingestion, can
cause increased mortality rates in cattle, sheep, and waterfowl.” Third, noise from a CSF could affect
animals. However, any effects will be mitigated by the proposal because each new CSF project proposal
must comply with all applicable laws and regulations, including SEPA and its implementing regulations, and
Chapter 18.40, Article X JCC (SEPA Implementation). A summary of the protections afforded in the Jefferson
County Code is attached as Exhibit 11. Specifically, the proposal requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance), including JCC 18.22.265, which requires a habitat
management plan; JCC 18.22.270, which provides protection standards on drainage and erosion
control for fish, wildlife habitat conservation areas; JCC 18.22.270(4), which requires vegetation
retention for any Fish and Wildlife Habitat Conservation Area and its buffer; JCC 18.22.310;
18.22.330; and, 18.22.350, which require wetland protection, buffers, and mitigation. Alternatives 1
through 5 do not propose any changes to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program), including JCC 18.25.320(2)(d), which prohibits
discharging solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water
or to be discharged onto land. Alternatives 1 through 5 do not propose any changes to the Shoreline
Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
Alternatives 1 through 5 of the proposal require that CSFs:
Contain Stray Bullets: CSFs must be designed and operated so that when firearms are operating in
accordance with rules and regulations approved as part of an application for operation of a CSF
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under the Title 8 Ordinance and for siting and design of a CSF under the Title 18 Ordinance, all
projectiles must be kept from leaving any shooting range or the CSF.
Comply with Added Environmental, Health, Noise, and Safety Standards or Best Management
Practices: CSFs must comply with the Environmental, Health, Noise and Safety Standards or Best
Management Practices added in the proposal, discussed above in response to Question A.
Mitigate Noise: CSFs must mitigate noise, as discussed in response to Question D.1, above.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
Whether the Proposal Likely Affects Fish:
CSFs may affect fish. However, any effects will be mitigated by the proposal because each new CSF project
proposal must comply with all applicable laws and regulations, including SEPA and its implementing
regulations, and Chapter 18.40, Article X JCC (SEPA Implementation). A summary of the protections
afforded in the Jefferson County Code is attached as Exhibit 11. Specifically, the proposal requires
compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance), including JCC 18.22.265, which requires a habitat
management plan; JCC 18.22.270, which provides protection standards on drainage and erosion
control for fish, wildlife habitat conservation areas; JCC 18.22.270(4), which requires vegetation
retention for any Fish and Wildlife Habitat Conservation Area and its buffer; JCC 18.22.310;
18.22.330; and, 18.22.350, which require wetland protection, buffers, and mitigation. Alternatives 1
through 5 do not propose any changes to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program), including JCC 18.25.320(2)(d), which prohibits
discharging solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water
or to be discharged onto land. Alternatives 1 through 5 do not propose any changes to the Shoreline
Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
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For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
Whether the Proposal Likely Would Affect Marine Life:
CSFs may affect marine life. However, any effects will be mitigated by the proposal because each new CSF
project proposal must comply with all applicable laws and regulations, including SEPA and its implementing
regulations, and Chapter 18.40, Article X JCC (SEPA Implementation). A summary of the protections
afforded in the Jefferson County Code is attached as Exhibit 11. Specifically, the proposal requires
compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance), including JCC 18.22.265, which requires a habitat
management plan; JCC 18.22.270(4), which requires vegetation retention for any Fish and Wildlife
Habitat Conservation Area and its buffer; JCC 18.22.310; 18.22.330, and 18.22.350, which require
wetland protection, buffers, and mitigation. Alternatives 1 through 5 do not propose any changes to
the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program), including JCC 18.25.320(2)(d), which prohibits
discharging solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water
or to be discharged onto land. Alternatives 1 through 5 do not propose any changes to the Shoreline
Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
3. How would the proposal be likely to deplete energy or natural resources?
RESPONSE:
Whether the Proposal Likely Depletes Energy Resources:
CSFs may deplete energy resources. However, any effects will be mitigated by the proposal because under
each of the alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable laws and
regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article X JCC (SEPA
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Implementation). A summary of the protections afforded in the Jefferson County Code is attached as Exhibit
11. Specifically, the proposal requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance). Alternatives 1 through 5 do not propose any changes
to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program). Alternatives 1 through 5 do not propose any
changes to the Shoreline Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
Whether the Proposal Likely Deplete Natural Resources:
CSFs may deplete natural resources. However, any effects will be mitigated by the proposal because under
each of the alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable laws and
regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article X JCC (SEPA
Implementation). A summary of the protections afforded in the Jefferson County Code is attached as Exhibit
11. Specifically, the proposal requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance), including JCC 18.22.130, which provides protection
standards for groundwater in susceptible aquifer recharge and special aquifer protection areas.
Alternatives 1 through 5 do not propose any changes to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program), including JCC 18.25.320(2)(d), which prohibits
discharging solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water
or to be discharged onto land. Alternatives 1 through 5 do not propose any changes to the Shoreline
Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
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For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
If an alternative is selected which allows outdoor and/or indoor CSFs in forest resource lands, this non-forest
use may result in a use which reduces forest resource lands as the portion of the land dedicated to ranges
and/or supporting structures will likely not be capable of harvesting trees. Below is a summary of the zoning
of forest resource lands in Jefferson County.
Zoned Land in Jefferson County Acres Percentage
of Total
Percentage of
Forest
Resource Lands
Reference
Total Zoned Land 430,110 100.00% - 2018 Comp Plan, 1-17
Forest Resource Lands (IF-20, RF-40, and CF-80) 328,785 76.44% 100.00% 2018 Comp Plan, 1-17
Forest Resource Lands IF-20 Only 7,250 1.69% 100.00% 2018 Comp Plan, 2-12
Forest Resource Lands CF-80 Only 309,493 71.96% 100.00% 2018 Comp Plan, 2-12
Forest Resource Lands RF-40 Only 12,204 2.84% 100.00% 2018 Comp Plan, 2-12
As discussed above, Alternatives 1, 2 and 4 permit CSFs with a CUP in forest resource lands. Under all of
these alternatives, a quota would apply to all new indoor and outdoor CSFs in forest resource lands. The
quota would limit CSFs to 0.05 percent of all forest lands. This amounts to approximately 150 acres.
Jefferson County has approximately 328,785 acres of forest resource lands. This quota, in addition to the
Small-Scale Recreation or Tourist Uses standards ensure the longevity of Jefferson County forest resource
lands. Further, the Small-Scale Recreation or Tourist Uses standards are designed to ensure that uses can
co-exist with the useful production of forest resource lands. Under Alternatives 1-5, all new CSF proposals
would likely be treated as a conditional use in forest resource lands.
Under Alternatives 1 through 4 (but not the no-action alternative), loopholes in Title 18 relating to the siting
of indoor and outdoor CSFs are closed. Without this legislation, there is an argument that CSFs may be
permitted as an allowed use, CUP, or not permitted under the unnamed use loophole, which may allow
CSFs in forest resource lands.
4. How would the proposal be likely to use or affect environmentally sensitive areas or areas
designated (or eligible or under study) for governmental protection; such as parks,
wilderness, wild and scenic rivers, threatened or endangered species habitat, historic or
cultural sites, wetlands, floodplains, or prime farmlands?
RESPONSE:
Whether the Proposal Likely Would Use or Affect Environmentally Sensitive Areas:
CSFs may use or affect environmentally sensitive areas. However, any effects will be mitigated by the
proposal because the proposal would limit use or effect on environmentally sensitive areas because, under
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each of the alternatives listed in the Brief and Complete Discussion in response to Question A.11, above,
including the no-action alternative, each new CSF project proposal must comply with all applicable laws and
regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article X JCC (SEPA
Implementation). A summary of the protections afforded in the Jefferson County Code is attached as Exhibit
11. Specifically, the proposal requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance), including JCC 18.22.130, which provides protection
standards for environmentally sensitive areas, such as wetlands. Alternatives 1 through 5 do not
propose any changes to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program), including JCC 18.25.320(2)(d), which prohibits
discharging solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water
or to be discharged onto land. Alternatives 1 through 5 do not propose any changes to the Shoreline
Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
Whether the Proposal Likely Would Use or Affect Areas Designated for Environmental Protection:
CSFs may affect areas designated (or eligible or under study) for governmental protection; such as parks,
wilderness, wild and scenic rivers, threatened or endangered species habitat, historic or cultural sites,
wetlands, floodplains, or prime farmlands. However, any effects will be mitigated by the proposal because
under each new CSF project proposal must comply with all applicable laws and regulations, including SEPA
and its implementing regulations, and Chapter 18.40, Article X JCC (SEPA Implementation). A summary of
the protections afforded in the Jefferson County Code is attached as Exhibit 11. Specifically, the proposal
requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance), including JCC 18.22.130, which provides protection
standards for fish and wildlife habitat conservation areas. Alternatives 1 through 5 do not propose
any changes to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program), including JCC 18.25.320(2)(d), which prohibits
discharging solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water
or to be discharged onto land. Alternatives 1 through 5 do not propose any changes to the Shoreline
Master Program.
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Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
5. How would the proposal be likely to affect land and shoreline use, including whether it
would allow or encourage land or shoreline uses incompatible with existing plans?
RESPONSE:
Whether the Proposal Likely Would Affect Land Use, Including Use Incompatible with Existing
Plans:
CSFs may affect land use, including not allowing or encouraging land uses incompatible with existing plans
and land use. However, any effects will be mitigated by the proposal because each new CSF project
proposal must comply with all applicable laws and regulations, including SEPA and its implementing
regulations, and Chapter 18.40, Article X JCC (SEPA Implementation). A summary of the protections
afforded in the Jefferson County Code is attached as Exhibit 11. Specifically, the proposal requires
compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance). Alternatives 1 through 5 do not propose any changes
to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program). Alternatives 1 through 5 do not propose any
changes to the Shoreline Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a).
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
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Measures to Ensure the Proposal is Compatible with Existing and Projected Land Use and Plans in the
Proposal: Measures to ensure the proposal is compatible with existing and projected land uses and plans
are:
Allows outdoor CSFs in forest resource lands only with a CUP, subject to the 12 CUP approval
criteria in Jefferson County Code 18.40.530 (Exhibit 3) and the forest resource district protections in
Jefferson County Code 18.15.150 (Exhibit 9).
Limits outdoor CSFs to only forest resource lands for projects that qualify as Small-Scale Recreation
or Tourist Uses. Small-Scale Recreation or Tourist Uses are limited by Jefferson County Code
18.20.350(3) (Exhibit 8).
Limits outdoor CSFs in forest resource lands with a quota (approximately 150 acres total in the
328,785 acres of forest resource lands throughout the county).
Allows indoor CSFs with a CUP in rural/urban growth area (UGA) commercial and industrial zoning
(excluding resource-based industrial zoning), subject to the 12 CUP approval criteria in Jefferson
County Code 18.40.530.
Continues to rely on existing laws that: (a) Require compliance with critical area, shoreline, and
wetlands buffers; (b) Limit nuisance noise; (c) Limit dangerous shooting of firearms; (d) Limit the
types of weapons that can be used; and, (e) Prohibit the use of any explosive devices.
Fixes the ambiguities identified in the no-action alternative items (2) and (5), discussed above in
response to Question A. 11.
Fixes the loopholes identified in the no-action alternative items (8) to (10), discussed above in
response to Question A. 11.
Adds the protections noted as missing in the no-action alternative items (11) to (23), including the
standards and Best Management Practices discussed above in response to Question A. 11.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
Whether the Proposal Likely Would Affect Shoreline Use, Including Use Incompatible with Existing
Plans:
CSFs may affect shoreline use, including not allowing or encouraging shoreline uses incompatible with
existing shoreline environmental designations. However, any effects will be mitigated by the proposal
because under each of the alternatives listed in the Brief and Complete Discussion in response to Question
A.11, above, including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). A summary of the protections afforded in the Jefferson County Code is
attached as Exhibit 11. Specifically, the proposal requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance). Alternatives 1 through 5 do not propose any changes
to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program). Under the Shoreline Master Plan, CSFs may be
characterized as an unclassified use requiring a shoreline conditional use permit or as a non-water
oriented commercial use. A non-water oriented commercial use, if allowed in the shoreline
environmental designation, may require a shoreline conditional use permit with the Department of
Ecology approval. Shoreline jurisdiction applies when there is a use or development within those
lands extending landward for 200 feet in all directions as measured on a horizontal plane from and
perpendicular to the ordinary high water mark; floodways and contiguous floodplain areas landward
200 feet from such floodways; and all wetlands and river deltas associated with the streams, lakes
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and tidal waters which are subject to the provisions of Chapter 173-22 WAC, as may be amended;
the same to be designated as to location by the Department of Ecology, as defined by Chapter 90.58
RCW. Alternatives 1 through 5 do not propose any changes to the Shoreline Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
6. How would the proposal be likely to increase demands on transportation or public services
and utilities?
RESPONSE:
Whether the Proposal Likely Would Increase Demands on Transportation:
It is not expected that additional traffic impacts will result from CSFs, as the impact of the zoning to the
transportation network was analyzed under the Comprehensive Plan’s Environmental Impact Statement. If
roadway or other improvements are required for a CSF, the Jefferson County Code and Comprehensive
Plan will apply. Roadway improvements then would be a condition of approval for CSFs under most
alternatives, if warranted. Furthermore, any effects will be mitigated by the proposal because increase
demands on transportation because under each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article X JCC
(SEPA Implementation). A summary of the protections afforded in the Jefferson County Code is attached as
Exhibit 11. Specifically, the proposal requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance). Alternatives 1 through 5 do not propose any changes
to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program). Alternatives 1 through 5 do not propose any
changes to the Shoreline Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC apply. This
includes JCC 18.30.020(5), which requires:
All land use activities shall be served by appropriate transportation facilities.
Transportation facilities shall be adequate to meet the level of service standards adopted
in the Jefferson County Comprehensive Plan and the appropriate design standards
referenced in JCC 18.30.080(1)(a). If transportation facilities would become inadequate,
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the applicant shall be required to provide necessary improvements and/or implement
alternative measures such as transportation demand management (TDM), project
phasing, or other measures acceptable to Jefferson County that will maintain the adopted
level of service standards and meet design standards. If transportation facilities are not
adequate, Jefferson County shall not approve the proposed development. Transportation
facilities shall be deemed adequate if necessary, improvements are planned and
designated funding is secured in the Jefferson County Six-Year Transportation
Improvement Program.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
Whether the Proposal Likely Would Increase Demands on Public Services:
CSFs may increase demands on public services. However, any effects will be mitigated by the proposal
because under each of the alternatives listed in the Brief and Complete Discussion in response to Question
A.11, above, including the no-action alternative, each new CSF project proposal must comply with all
applicable laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article
X JCC (SEPA Implementation). A summary of the protections afforded in the Jefferson County Code is
attached as Exhibit 11. Specifically, the proposal requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance), including JCC 18.22.130, which provides protection
standards for groundwater in susceptible aquifer recharge and special aquifer protection areas.
Alternatives 1 through 5 do not propose any changes to the Critical Areas Ordinance.
Chapter 18.25 JCC (Shoreline Master Program), including JCC 18.25.320(2)(d), which prohibits
discharging solid wastes, liquid wastes, and untreated effluents to any groundwater or surface water
or to be discharged onto land. Alternatives 1 through 5 do not propose any changes to the Shoreline
Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC, including JCC
18.30.070, which requires compliance with the Department of Ecology’s Stormwater Management
Manual for Western Washington and JCC 18.30.060(1)(a), which requires all grading and clearing
activities to be conducted so as to minimize potential adverse effects of these activities on forested
lands, surface water quality and quantity, groundwater recharge, and fish and wildlife habitat,
adjacent properties, and downstream drainage channels.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
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For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
Future CSF projects in forest resource lands would be subject to the small-scale recreation or tourist
approval criteria: (a) JCC 18.20.350(3)(a)(vi) requires that the applicant demonstrate to the satisfaction of
the approving authority that: “The public facilities and services provided are limited to those necessary to
serve the associated commercial activities and the principal small-scale recreational or tourist use in a
manner that does not permit low-density sprawl;” and, (b) JCC 18.20.350(3)(j) requires that the applicant
demonstrate to the satisfaction of the approving authority that: “For any small-scale recreation or tourist
use, the county shall impose such reasonable conditions (e.g., location and size restrictions, design
standards, landscape buffers, setbacks, etc.) as are found necessary by the approving authority to ensure
that the activity or use, due to proximity, location or intensity: … (iii) Is adequately served by public facilities
and services (including roadway level of service and minimum fire flow requirements) without the need to
extend those services in a manner that promotes low density sprawl; … (v) Would not cumulatively, in
combination with the effects of existing development (or given the probable development of subsequent
projects with similar effects) in the vicinity (i.e., within one mile) of the proposed use, create a development
pattern that constitutes low density sprawl; require the extension of public facilities or expansion of public
services in a manner that promotes low density sprawl, or be otherwise incompatible with or injurious to
the rural character of the area.” JCC 18.20.350(3)(a)(v) requires that the applicant demonstrate to the
satisfaction of the approving authority that: “If the preceding conditions (in subsection (3)(j) of this section)
cannot be met to the satisfaction of the approving authority, the use shall be denied.” (Emphasis added.)
Whether the Proposal Likely Would Increase Demands on Utilities:
CSFs may increase demands on utilities. However, any effects will be mitigated by the proposal because
under each of the alternatives listed in the Brief and Complete Discussion in response to Question A.11,
above, including the no-action alternative, each new CSF project proposal must comply with all applicable
laws and regulations, including SEPA and its implementing regulations, and Chapter 18.40, Article X JCC
(SEPA Implementation). A summary of the protections afforded in the Jefferson County Code is attached as
Exhibit 11. Specifically, the proposal requires compliance with:
Chapter 18.22 JCC (Critical Areas Ordinance).Alternatives 1 through 5 do not propose any changes
to the Critical Areas Ordinance. Chapter 18.25 JCC (Shoreline Master Program). Alternatives 1
through 5 do not propose any changes to the Shoreline Master Program.
Development and performance standards in Chapters 18.15, 18.20 and 18.30 JCC.
12 CUP approval criteria in JCC 18.40.530 (Exhibit 1) or the discretionary use criteria in JCC
18.15.045 (Exhibit 2).
Small-scale recreation or tourist approval criteria, JCC 18.20.350(3)(a)(i) for future CSF projects in
forest resource lands.
Substantive standards and best management practices required by the proposal that would mitigate
these types of impacts.
SEPA, which requires analysis of these impacts at the project level.
For future CSF projects subject to the conditional use approval criteria, JCC 18.40.530(1)(i) requires: “The
conditional use will not cause significant adverse impacts on the human or natural environments that cannot
be mitigated through conditions of approval.”
Page 95 of 95
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960)
January 6, 2020
For future CSF projects subject to the discretionary use approval criteria, JCC 18.15.045(2)(a) requires that
the project: “Will not result in impacts on the human or natural environments determined by the administrator
to require review as a conditional use.”
7. Identify, if possible, whether the proposal may conflict with local, state, or federal laws or
requirements for the protection of the environment.
RESPONSE:
Whether the Proposal May Conflict with Local, State or Federal Laws or Requirements for the
Protection of the Environment:
The proposal likely would not conflict with local, state or federal laws or requirements for the protection of
the environment. The proposal recognizes the Supremacy Principal described in WAC 365-196-725(1) in
the findings of Title 8 and Title 18 Ordinances. Under the Supremacy Principle, state statutes and regulations
cannot conflict with the United States Constitution, the Washington Constitution, and federal laws; and, local
ordinances and regulations cannot conflict with the United States Constitution, federal laws, the Washington
Constitution, or state laws.
Under the proposal, each new CSF project proposal must comply with all applicable laws and regulations,
including SEPA and its implementing regulations, and Chapter 18.40, Article X JCC (SEPA Implementation).
A summary of the protections afforded in the Jefferson County Code is attached as Exhibit 11.
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 1
Exhibit 1
Jefferson County Code 18.40.530 – Conditional Use Approval Criteria
12 CUP approval criteria listed are below:
(1) The county may approve or approve with modifications an application for a conditional use permit (i.e., uses
listed in Table 3-1 in JCC 18.15.040 as “C(a),” “C(d)” or “C”) if all of the following criteria are satisfied:
(a) The conditional use is harmonious and appropriate in design, character, and appearance with the
existing or intended character and quality of development in the vicinity of the subject property and with
the physical characteristics of the subject property;
(b) The conditional use will be served by adequate infrastructure including roads, fire protection, water,
wastewater disposal, and stormwater control;
(c) The conditional use will not be materially detrimental to uses or property in the vicinity of the subject
parcel;
(d) The conditional use will not introduce noise, smoke, dust, fumes, vibrations, odors, or other conditions
or which unreasonably impact existing uses in the vicinity of the subject parcel;
(e) The location, size, and height of buildings, structures, walls and fences, and screening vegetation for
the conditional use will not unreasonably interfere with allowable development or use of neighboring
properties;
(f) The pedestrian and vehicular traffic associated with the conditional use will not be hazardous to
existing and anticipated traffic in the vicinity of the subject parcel;
(g) The conditional use complies with all other applicable criteria and standards of this title and any other
applicable provisions of the Jefferson County Code or state law; and more specifically, conforms to the
standards contained in Chapters 18.20 and 18.30 JCC;
(h) The proposed conditional use will not result in the siting of an incompatible use adjacent to an airport
or airfield;
(i) The conditional use will not cause significant adverse impacts on the human or natural environments
that cannot be mitigated through conditions of approval;
(j) The conditional use has merit and value for the community as a whole;
(k) The conditional use is consistent with all relevant goals and policies of the Jefferson County
Comprehensive Plan; and
(l) The public interest suffers no substantial detrimental effect. Consideration shall be given to the
cumulative effect of similar actions in the area.
(2) In instances where all of the above findings cannot be made, the application shall be denied.
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 2
Exhibit 2
Jefferson County Code 18.15.045 – Discretionary Use Approval Criteria
The discretionary use criteria are listed below:
(2) Discretionary Uses. Discretionary uses are certain named and all unnamed uses which may be allowed
subject to the applicable development and performance standards (Chapters 18.20 and 18.30 JCC) and an
administrative review of potential impacts are designated by a “D” (for “discretionary”). On the basis of the
administrative review, the administrator may classify the proposed “D” use as either an allowed use, a
prohibited use, or a conditional use in the particular land use district affected.
Discretionary, “D,” uses are subject to a Type II administrative review as specified in Chapter 18.40 JCC.
Decisions classifying “D” uses made under this section may be appealed to the hearing examiner (see
Chapter 18.40 JCC). The administrator may classify the discretionary use as an allowed “Yes” use in the
particular district affected, only if the proposed development:
(a) Complies with the applicable development standards of Chapter 18.30 JCC;
(b) Complies with the performance and use-specific standards unique to the proposed use specified in
Chapter 18.20 JCC;
(c) Is appropriate in design, character, and appearance with the goals and policies for the land use
designation and district in which the proposed use is located;
(d) Is consistent with the goals and policies of the Comprehensive Plan and the applicable regulations of the
Shoreline Master Program if the application involves property located within the jurisdiction of the state
Shoreline Management Act, but does not require a shoreline permit;
(e) Will be served by adequate facilities including access, fire protection, water, and sewer facilities
(municipal, community, or on-site systems);
(f) Does not include any use or activity that would result in the siting of an incompatible use adjacent to an
airport or airfield (Chapter 36.70 RCW);
(g) Shall not adversely impact the public health, safety and general welfare of the residents of the county;
(h) Shares characteristics common with but not of significantly greater intensity, density or that generates
more environmental impact than those uses allowed in the district in which it is to be located; and
(i) Will not result in impacts on the human or natural environments determined by the administrator to require
review as a conditional use.
If the preceding conditions are not met to the satisfaction of the administrator, the administrator may either
prohibit the use or require a conditional use permit.
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 3
Exhibit 3
Forest District Development Regulations
Jefferson County Code 18.15.150
Development in Forest Resource Land is limited by Jefferson County Code 18.15.150 as follows:
(1) Residential Density. There shall be no subdivision of land designated commercial forest or rural forest
for residential purposes. However, nothing in this code shall be construed to prevent the owner of designated
commercial or rural forest land from living on his/her land; provided, that applicable building requirements
are met.
(2) Subdivisions and Use Limitations. Subdivision of commercial and rural forest lands for construction or
installation of nonresidential purposes, as allowed in Table 3-1 in JCC 18.15.040, shall be at least 80 acres
in size within the commercial forest designation and 40 acres in size within the rural forest designation and
must meet the following criteria:
(a) The facility cannot otherwise be suitably located on undesignated land;
(b) The installation cannot otherwise be accomplished without subdivision;
(c) The facility is to be located on the lowest feasible grade of forest land; and
(d) The facility removes as little land as possible from timber production.
(3) Setback Requirements for Adjacent Development. New structures proposed to be located on parcels
adjacent to designated forest lands shall:
(a) Establish and maintain a minimum 250-foot building setback adjacent to commercial forest lands and
100 feet adjacent to the rural forest lands designation, which shall serve as a resource protection area, as
measured from the property boundaries of adjacent forest lands except as follows:
(i) If the size, shape, and/or physical site constraints of an existing legal lot do not allow a setback of 250 feet
adjacent to commercial forest lands and 100 feet adjacent to the rural forest lands designation, then the new
structure shall maintain the maximum setback possible; or
(ii) If the owner of the land on which the new structure is proposed and the owner of the adjacent forest land
each sign and file for record, in the manner required by law for covenants running with the land, a document
which establishes an alternative setback for one or both of the properties, a setback of less than 250 feet
adjacent to commercial forest lands and 100 feet adjacent to rural forest lands may be maintained;
(b) Provide adequate access for fire vehicles; and
(c) If the proposed structure is located within 250 feet of the boundary of commercial forest lands or within
100 feet of rural forest lands, in the area where the setback is to be applied, the property owner shall survey
the property boundaries that abut forest land in the area where the setback is to be applied, locate the
property boundaries on the ground, and submit a record of survey, or other means deemed acceptable to
the administrator, with a building permit application.
(4) Setback Requirements on Designated Forest Lands. Builders of new structures proposed to be located
on parcels designated commercial, rural, or inholding forest shall:
(a) Establish and maintain a minimum 250-foot setback, which shall be a resource protection area, from the
property boundaries of adjacent commercial and rural forest lands except as follows:
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 3
(i) If the size, shape, and/or physical site constraints of an existing legal lot do not allow a setback of 250
feet, the new structure shall maintain the maximum setback possible.
(5) Establishment of Resource Protection Areas. Subdivisions, short subdivisions and rural cluster
subdivisions of parcels adjacent to forest land shall establish a resource protection area of a minimum 250-
foot width along commercial forest land boundaries and 100-foot width along rural forest and inholding
forest land boundaries.
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 4
Exhibit 4
Forest District Development Regulations
Jefferson County Code Table 3-1
Table 3-1. Allowable and Prohibited Uses
How To Use This Table
Table 3-1 displays the classifications of uses for land use districts, except for land
use and zoning districts in the Irondale and Port Hadlock UGA which are specified
in Chapter 18.18 JCC.
The allowability and classification of uses as represented in the table are further
modified by the following:
The location may have a multiple designation. This would be true of the Shoreline
Master Program, a subarea plan, or an overlay district applied to the location. The
Shoreline Master Program (SMP) should be consulted if the location of interest is
subject to the SMP jurisdiction. See also Notes 1 to 3 to this table.
All regulations in this code apply to the uses in these tables. To determine whether
a particular use or activity can occur in a particular land use district and location, all
relevant regulations must also be consulted in addition to this table.
Categories of Uses
Yes = Uses allowed subject to the provisions of this code, including meeting
applicable performance standards (Chapter 18.20 JCC) and
development standards (Chapter 18.30 JCC); if a building or other
development permit is required, this use is also subject to project permit
approval; see Chapter 18.40 JCC.
D = Discretionary uses are certain named and all unnamed uses which may
be allowed subject to administrative approval and consistency with the
UDC, unless the administrator prohibits the use or requires a conditional
use permit based on project impacts; see JCC 18.15.040(2) and
Chapter 18.40 JCC.
C = Conditional uses, subject to criteria, public notice, written public
comment and public hearing procedure; see Article VIII of
Chapter 18.40 JCC.
C(a) = Conditional uses, subject to criteria, public notice, written public
comment, and an administrative approval procedure, but not a public
hearing; see Article VIII of Chapter 18.40 JCC.
C(d) = Conditional uses, subject to criteria, public notice, written public
comment and, at the discretion of the administrator, a public hearing
procedure, if warranted, based on the project’s potential impacts, size or
complexity, according to criteria in JCC 18.40.520; see Article VIII of
Chapter 18.40 JCC.
No = Prohibited use.
NOTES:
1. All uses must be consistent with the purpose of the land use district in which they are proposed to occur; see the Land Use Element of the Comprehensive Plan. All land uses in all districts must meet the general regulations in Article III of this chapter unless otherwise
stated herein.
2. A land use or development proposed to be located entirely or partly within 200 feet of the ordinary high water mark of a regulated shoreline is within the jurisdiction of the Shoreline Master Program, and is subject to the applicable provisions of this chapter and of the
SMP, as well as the applicable provisions and permit requirements indicated in this table. Please refer to the Shoreline Master Program for specific use regulations and regulations by shoreline environment.
3. Overlay districts provide policies and regulations in addition to those of the underlying land use districts for certain land areas and for uses that warrant specific recognition and management. For any land use or development proposed to be located entirely or partly
within an overlay district, or within the jurisdiction of a subarea plan, the applicable provisions of the overlay district or subarea plan as provided in Articles VI and VII of this chapter shall prevail over any conflicting provisions of the UDC.
4. The assignment of allowed or prohibited uses may not directly or indirectly preclude the siting of “essential public facilities” (as designated in the Comprehensive Plan) within the county. See JCC 18.15.110.
5. Outright uses are land uses or activities which are exempt from the provisions of this Unified Development Code.
6. Land Use Districts:
AG Agricultural Resource Lands I Rural Industrial
AP-20 Prime Agricultural Land RI Resource Industrial
AL-20 Agricultural Land of Local Importance LI/C Light Industrial/Commercial (Glen Cove)
LI Light Industrial (Glen Cove)
F Forest Resource Lands LI/M Light Industrial/Manufacturing
CF-80 Commercial Forest HI Heavy Industrial
RF-40 Rural Forest
IF Inholding Forest P Public
PPR Parks, Preserves and Recreation
RR Rural Residential
RR 1:5 Rural Residential – 1 DU/5 Acres UGA Urban Growth Area
RR 1:10 Rural Residential – 1 DU/10 Acres [See Chapter 18.18 JCC]
RR 1:20 Rural Residential – 1 DU/20 Acres
RC Rural Commercial
RVC Rural Village Center
CC Convenience Crossroads
NC Neighborhood/Visitor Crossroads
GC General Crossroads
7. Forest practices (including timber harvesting), except for Class IV, general (see JCC 18.20.160) are regulated by the Washington Department of Natural Resources.
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Residential Uses
See
Chapter 18.18 JCC
Single-Family Housing
Accessory dwellings units Yes Yes Yes Yes Yes Yes No No No No Yes Yes No No No
Caretaker residence (public
parks)
No No No No No No No No No No No No No No C(a)
Co-housing/intentional
communities (subject to
PRRD overlay in RR districts)
Yes No Yes Yes Yes Yes No No No No No No No No No
Manufactured/mobile home
parks (subject to PRRD
overlay in RR districts)
No No Yes Yes Yes Yes No Yes Yes No No No No No No
Single-family residences Yes Yes Yes Yes Yes Yes No No No No No No No No No
Transient rental of residence
or accessory dwelling unit
Yes Yes Yes Yes Yes Yes No No No No No No No No No
Duplexes (subject to meeting
underlying density
requirements)
Yes Yes Yes Yes Yes Yes No No No No No No No No No
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Farm worker housing See
JCC 18.20.030
No No No No No No No No No No No No No No
Multifamily Housing
Multifamily residential units
(3+ units)
No No No No No Yes No Yes Yes No No No No No No
Residential care facilities with
up to 5 persons
No No Yes Yes Yes Yes No No Yes No No No No No No
Residential care facilities with
6 to 20 persons
No No C C C Yes No No No No No No No No No
Nursing/convalescent/assisted
living facilities
No No C C C Yes No Yes Yes No No No No No No
See
Chapter 18.18 JCC
Unnamed residential uses No No D D D D No D D No No No No No No
Accessory Uses
Home businesses Yes Yes Yes Yes Yes Yes No Yes Yes No Yes Yes Yes No No
Cottage industry (not
including recreational
marijuana)
C(a) C(a) C(d) C(d) C(d) Yes No Yes Yes No Yes Yes Yes No No
Hobby kennel Yes Yes Yes Yes Yes No No No No No No No No No No
Commercial Uses
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Animal commercial kennels
and catteries
See
JCC 18.20.030
C(d) C(d) C(d) C(d) C(d) No No C(d) No No No No No No
Automotive service and repair No No No No No Yes No Yes Yes No Yes Yes Yes No No
Automotive service and repair
(with subordinate auto sales)
No No No No No Yes No No Yes No No No No No No
Bed and breakfast inn (4 to 6
rooms)
Yes No C(a) C(a) C(a) Yes No Yes Yes No No No No No No
Bed and breakfast residence
(1 to 3 rooms)
Yes Yes Yes Yes Yes Yes Yes Yes Yes No No No No No No
Boat storage, commercial
(outside of SMP)
No No No No No Yes No No Yes No Yes Yes Yes No No
Boat building and repair,
commercial
No No No No No C No No No No Yes Yes Yes Yes No
Clinics (medical, dental, and
vision)
No No No No No Yes No Yes Yes No No No No No No
Convenience and video stores No No No No No Yes Yes Yes Yes No No No No No No
Day care, commercial C No No No No Yes No Yes Yes No No No No No No
Drinking establishment No No No No No Yes No Yes Yes No No No No No No
Eating establishment No No No No No Yes Yes Yes Yes No C No No No No
Sexually oriented businesses No No No No No C C No C No C No No No No
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Small equipment repair, sales
and rental services
See
JCC 18.20.030
No No No No Yes No Yes Yes No Yes Yes Yes No No
See
Chapter 18.18 JCC
Construction contractor,
commercial
No No No No No Yes No No/
Yes1
Yes No Yes Yes Yes No No
Food and beverage stands No No No No No Yes Yes Yes Yes No Yes Yes Yes Yes No
Gas stations No No No No No Yes Yes Yes Yes No No No No No No
Golf courses and driving
ranges
No No C C C No No No No No No No No No C
Grocery stores and gift shops No No No No No Yes No Yes Yes No No No No No No
Hotel/motel No No No No No Yes No No2 C No No No No No No
Indoor entertainment or
recreational facility
No No No No No Yes No Yes Yes No No No No No No
Liquor stores No No No No No Yes No Yes Yes No No No No No No
Lumber yards/building supply
and materials
No No No No No Yes No No C No Yes Yes Yes No No
Marijuana recreational retailer C(d) No No No No Yes No Yes Yes Yes Yes Yes Yes Yes No
Mini-storage facilities No No No No No Yes No C/
Yes3
Yes No Yes No Yes No No
Personal and professional
services
No No No No No Yes D D Yes No No No No No No
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Resorts, master planned
(new)
See Article IV of Chapter 18.15 JCC
Retail sales and services (not
including recreational
marijuana retail)
See
JCC 18.20.030
No No No No Yes D D Yes No No No No No No
Vehicle sales, new and used
retail (auto and RV)
No No No No No C(a) No No No/
C(a)4
No No No No No No
Veterinary clinics and
hospitals
See
JCC 18.20.030
See
Chapter 18.18 JCC
Unnamed commercial uses No No No No No D D D D No D No No No No
Industrial Uses
Bulk plant or terminal facilities No No No No No No No No No No C C C C No
Asphalt and concrete batch
plants
No C No No No No No No No No No No No Yes No
Heavy equipment sales and
rental services
No No No No No C(a) No No C(a) No Yes Yes Yes No No
Heavy industrial, resource-
based
No No No No No No No No No C(a) No No No Yes No
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Light industrial/manufacturing
(not including recreational
marijuana processing)
See
JCC 18.20.030
No No No No No No No No C(a) Yes Yes Yes No No
Food or beverage bottling
and/or packaging
See
JCC 18.20.030
No No No No No No No No No Yes Yes Yes No No
Outdoor storage yards See
JCC 18.20.030
No No No No No No No No C(a) Yes Yes Yes Yes No
Recycling center See
JCC 18.20.030
No No No No No No No/C5 No/C6 No Yes Yes Yes No No
Marijuana recreational
processor
C(d) C(d) C(d) C(d) C(d) No No No No Yes Yes Yes Yes Yes No
Mineral extraction activities
(without MRL overlay)
Yes Yes C C C No No No No No No No No No No
Mineral extraction activities
(w/MRL overlay) (10-acre min.
lot size)
Yes Yes Yes Yes Yes No No No No No No No No No No
Mineral processing accessory
to extraction operations
(without MRL overlay)
C C C C C No No No No Yes C C C Yes No
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Mineral processing accessory
to extraction operations
(w/MRL overlay)
Yes Yes C C C No No No No Yes No No No Yes No
Warehouse/wholesale
distribution center
See
JCC 18.20.030
No No No No No No No No No Yes Yes Yes No No
See
Chapter 18.18 JCC
(Automobile) wrecking yards
and junk (or salvage) yards
No No No No No No No No/
Yes7
No/
Yes8
No No No Yes Yes No
Unnamed industrial uses No No No No No No No No No D D D D D No
Institutional Uses
Essential Public Facilities9 See JCC 18.15.110
Airports (w/o airport EPF
overlay)
No No No No No No No No No No No No No No No
Educational facilities (state
owned)
No No C C C C No C C C C C C No No
Large-scale regional
transportation facilities (state
owned) (e.g., freeways, ferry
terminals)
No No C C C C No C C C C C C C No
Correctional facilities No No C C C C No C C C C C C C No
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Solid waste handling and
disposal facilities
No No C C C C No C C C C C C C No
Inpatient substance abuse
and mental health facilities
No No C C C C No C C No No No No No No
Unnamed essential public
facilities
See
JCC 18.20.030
No C C C C C C C C
Public Purpose Facilities
Animal shelter C(d) C(d) C(d) C(d) C(d) C(d) C(d) C(d) C(d) No No No No C(d) C(d)
Assembly facilities See
JCC 18.20.030
No C(d) C(d) C(d) Yes No C(a) C(a) No No No No No No
College or technical
school/adult education facility
(not state owned)
See
JCC 18.20.030
No No No No C No C C No No No No No No
Emergency services (police,
fire, EMS)
C C C C C C C C C C C C C C C
See
Chapter 18.18 JCC
Government offices No No No No No Yes No Yes Yes No No No No No C(a)
Library No No No No No Yes No Yes Yes No No No No No No
Museum No No No No No Yes No Yes Yes No No No No No C(d)
Parks and playfields C C Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Post office No No No No No Yes Yes Yes Yes No No No No No No
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Public works
maintenance/equipment
storage shops
C C C(d) C(d) C(d) Yes Yes Yes Yes Yes Yes Yes Yes Yes No
Recreational facilities C C Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Recycling collection facilities See
JCC 18.20.030
C(a) C(a) C(a) C(a) Yes Yes Yes Yes Yes Yes Yes Yes Yes C(a)
School, primary and
secondary
See
JCC 18.20.030
No C C C C No No C No No No No No No
Visitor/interpretive center No C(d) C(d) C(d) C(d) C(d) No C(d) C(d) No No No No No C(d)
Water/wastewater treatment
facilities
No No C(d) C(d) C(d) Yes Yes Yes Yes Yes Yes Yes Yes Yes C(d)
Cemeteries No No C(d) C(d) C(d) No No No No No No No No No No
Religious assembly facility No No C(d) C(d) C(d) C(a) No C(a) C(a) No No No No No No
Unnamed institutional uses No No D D D D D D D D D D D D D
Small-Scale Recreation and
Tourist Uses
Aerial recreational activities
(e.g., balloon rides, gliders)
No No C(d) C(d) C(d) C(d) No No No No No No No No No
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Animal preserves and game
farms with dangerous wild
animals
No No C(d) C(d) C(d) No No No No No No No No No No
See
Chapter 18.18 JCC
Animal tourist farms with
domestic and nondangerous
wild animals
See
JCC 18.20.030
Agritourism See
JCC 18.20.030
Campgrounds and camping
facilities, new
See
JCC 18.20.030
C(d) C(d) C(d) C(d) No No No No No No No No No Yes
Campgrounds, camping
facilities and small-scale
resorts; expansion of existing
facilities
See
JCC 18.20.030
C(d) C(d) C(d) C(d) No No No No No No No No No Yes
Cultural festival and historic
sites, permanent
C(d) C(d) C(d) C(d) C(d) C(d) No C(d) C(d) No No No No No Yes
Equestrian centers C(d) C(d) C(d) C(d) C(d) No No No No No No No No No No
Outdoor commercial
amusement facilities
See
JCC 18.20.030
No C C C Yes No No Yes No No No No No No
Outdoor archery ranges No C(d) C(d) C(d) C(d) No No No No No No No No No No
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Recreational, cultural or
religious conference
center/retreat facilities
See
JCC 18.20.030
No C C C C(d) No No C(d) No No No No No No
Recreational vehicle parks No C(d) C(d) C(d) C(d) Yes No No Yes No No No No No No
Outdoor shooting ranges No C No No No No No No No No No No No No No
Outdoor recreational
equipment rental and/or guide
services
See
JCC 18.20.030
No C(d) C(d) C(d) Yes No Yes Yes No No No No No No
Public display gardens C(d) C(d) C(d) C(d) C(d) Yes No No No No No No No No Yes
Rural restaurant, only when
associated with a primary
recreational or tourist use
See
JCC 18.20.030
No C(d) C(d) C(d) N/A N/A N/A N/A No No No No No No
See
Chapter 18.18 JCC
Recreational off-road vehicle
(ORV) and all-terrain vehicle
(ATV) parks and recreational
areas
No C No No No No No No No No No No No No No
Rural recreational lodging or
cabins for transient rental
See
JCC 18.20.030
No C C C N/A N/A N/A N/A No No No No No No
Unnamed small-scale
recreation and tourist uses
See
JCC 18.20.030
No C(d) C(d) C(d) D D D D No No No No No D
Temporary Uses
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Seasonal roadside stands See JCC 18.20.330
Temporary festivals See JCC 18.20.390
Temporary outdoor uses See JCC 18.20.380
Transportation Uses
Park and ride lots/transit
facilities
C(d) C(d) C(d) C(d) C(d) Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Roads, public or private Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Trails and paths, public or
private
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Unnamed transportation uses D D D D D D D D D D D D D D D
Utilities Uses
Commercial communication
facilities
See JCC 18.20.130
Utility developments, major C C C C C C C C C C C C C C C
Utility developments, minor C(a) C(a) C(a) C(a) C(a) C(a) C(a) C(a) C(a) C(a) C(a) C(a) C(a) C(a) C(a)
Unnamed utility uses D D D D D D D D D D D D D D D See
Chapter 18.18 JCC Agricultural and Forestry
Uses
Resource Lands Rural Residential Rural Commercial Rural Industrial Public UGA
Agricultural –
Prime and
Local
Forest –
Commercial,
Rural
and
Inholding
1
DU/5
Acres
1
DU/10
Acres
1
DU/20
Acres
Rural
Village
Center
Convenience
Crossroad
Neighborhood/Visitor
Crossroad
General
Crossroad
Resource-
Based
Industrial
Light
Industrial/Commercial
(Glen Cove)
Light
Industrial
(Glen
Cove)
Light
Industrial/Manufacturing
(Quilcene and Eastview)
Heavy
Industrial
Parks,
Preserves
and
Recreation
Irondale and Port
Hadlock
Urban Growth
Area
Specific Land Use AG CF/RF/IF
RR
1:5
RR
1:10
RR
1:20 RVC CC NC GC RI LI/C LI LI/M HI PPR UGA
Agricultural activities and
accessory uses
See JCC 18.20.030
Aquacultural uses and
activities (outside of shoreline
jurisdiction)
Yes No Yes Yes Yes No No No No No No No No No No
Aquatic plant and animal
processing and storage
See
JCC 18.20.030
No No No No No No No No No Yes Yes Yes Yes No
Lumber mills and associated
forestry processing activities
and uses
See
JCC 18.20.030
C(a) No No No No No No No Yes No No No Yes No
Marijuana Recreational
Producer
Yes C(d) C(d) C(d) C(d) No No No No Yes Yes Yes Yes Yes No
Nurseries Yes Yes C(d) C(d) C(d) Yes No Yes Yes No No No No No No
Unnamed agricultural and
forestry uses
D D D D D No No No No No No No No No No
1
Four Corners only
2
Hotel/motels are not allowed in NC districts, except for Discovery Bay
3
Chimacum and Four Corners, existing only
4
SR 19/20 only
5
Four Corners only
6
Ness Corner only
7
Four Corners, existing only
8
Ness Corner, existing only
9 Classification of EPF uses within appropriate districts are advisory only, subject to provisions of Article V of Chapter 18.15 JCC
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 5
Exhibit 5
Ordinance 12-1102-18 adopted on November 2, 2018 (Title 8 Health and Safety Ordinance)
code
COUNTY OF JEFFERSON
STATE OF WASHINGTON
An Ordinance on Commercial Shooting Facilities } ORDINANCE NO. 12-1102-18
in Unincorporated Areas of Jefferson County }
WHEREAS, the Washington Constitution, Article XI, Section 11, confers upon county
legislative authorities the police power to adopt regulations necessary to protect the health, safety,
and well-being of its residents; and,
WHEREAS, RCW 36.32.120(7) provides that the county legislative authorities shall make
and enforce, by appropriate resolutions or ordinances, all such police and sanitary regulations as
are not in conflict with state law; and,
WHEREAS, RCW 9.41.290 provides that the State of Washington fully occupies and
preempts the entire field of firearms regulations within its boundaries, and counties may only enact
ordinances as expressly authorized by RCW 9.41.300; and,
WHEREAS, RCW 9.41.300(2)(a) provides an exception to RCW 9.41.290 under which a
county may, by ordinance, restrict the discharge of firearms in any portion of its jurisdiction where
there is a reasonable likelihood that humans, domestic animals, or property will be jeopardized so
long as such ordinance shall not abridge the right of the individual guaranteed by Article I, section
24 of the Washington Constitution to bear arms in defense of self or others; and,
WHEREAS, local governments have considerable latitude in exercising police powers and
a regulation is reasonable if it promotes public safety, health, or welfare, and bears a reasonable
and substantial relation to accomplishing the purpose being pursued;' and,
WHEREAS, due to the amount of land in Jefferson County owned by the federal and state
governments, areas of protected shorelines, and limited water and septic capacity in other areas of
Jefferson County, there are limited areas where residents can live; and,
WHEREAS, Jefferson County has experienced a substantial increase in population density
in areas proximate to its established commercial shooting facilities and Jefferson County has an
interest in ensuring the compatibility ofcommercial shooting facilities with their surroundings and
in minimizing potential safety hazards created by the operation of commercial shooting facilities;
and,
WHEREAS, public complaints about lack of safety and land use compatibility issues
arising from the operation of commercial shooting facilities in unincorporated Jefferson County
have called on the scarce resources of Jefferson County's emergency management system and the
Sheriffs Office, which has the effect of diminishing the availability of these resources for
emergency services; and,
City ofSeattle v. Montana, 129 Wash.2d 583,591-92 (1996).
1 of 41
WHEREAS, Jefferson County has rural areas where commercial shooting facilities may
be appropriate, but where emergency services are scarce and adopting a commercial shooting
ordinance would promote public safety and preserve precious emergency services; and,
WHEREAS, commercial shooting facilities benefit Jefferson County by providing its
residents and law enforcement the opportunity to learn firearm safety, to practice shooting, and to
participate in amateur recreational firearm sports in a safe, controlled setting; and,
WHEREAS, the Jefferson County Board of Commissioners (BoCC) finds it is in the
public interest to protect and preserve the continued viability of commercial shooting facilities in
Jefferson County in the face of increasing population pressure and density of conflicting land uses;
and,
WHEREAS, the BoCC finds that uniform requirements for the establishment and
operation of all commercial shooting facilities in unincorporated Jefferson County would provide
assurance of the safe conduct of recreational and educational shooting activities in Jefferson
County, provided the regulation: (1) provides for and promotes safety by establishing a permitting
procedure and rules for the siting, design and operation of commercial shooting range facilities
that safeguards participants, spectators, neighboring properties and the public; (2) does not prohibit
or expressly regulate the discharge of firearms; (3) involves measures designed to make the
discharge of firearms safe; (4) protects the environment; (5) ensures compatibility with
neighboring land use; and, (6) promotes the continued availability of shooting facilities for firearm
education, practice in the safe use of firearms, and recreational firearm sports; and,
WHEREAS, on December 18, 2017, the BoCC adopted Ordinance No. 05-1218-17, an
Ordinance Establishing a Moratorium on Commercial Shooting Facilities in Unincorporated Areas
of Jefferson County (the Moratorium); and,
WHEREAS, Ordinance No. 05-1218-17 was amended by Ordinance No. 01-0220-18 to
allow noise testing during the Moratorium; and,
WHEREAS, the BoCC finds that resident and property owner input and careful analysis
of the uniform requirements for commercial shooting facilities should be obtained before
legislation imposing uniform requirements on commercial shooting facilities can be adopted by
the BoCC; and,
WHEREAS, as required by the work plan in Section 6 of the Moratorium and with the
assistance of the Review Committee established by the Moratorium staff timely has provided to
the BoCC a draft ordinance for consideration; and,
WHEREAS, the BoCC has held a hearing and has received public comment on the draft
ordinance proposed by staff that was prepared with the assistance of the Review Committee; and,
WHEREAS, in response to the public comment and testimony, additional improvements
to the draft ordinance have been made,
2 of 41
NOW, THEREFORE, be it ordained by the BoCC as follows:
Section 1. Modification of Chapter 8.50 JCC.
a. Chapter 8.50 JCC shall be renamed from "No Shooing Areas" to "Shooting in the County."
b. Article I, Chapter 8.50 JCC shall be renamed from "Establishment Procedures" to
Establishment Procedures for No Shooting Areas."
C. Article II, Chapter 8.50 JCC shall be renamed from "Boundary Descriptions" to "Boundary
Descriptions for No Shooting Areas."
d. JCC 8.50.020 shall be amended to add a new subsection (5) exception as follows: (5) The
operation of an indoor commercial shooting facility which has obtained an operating permit
or provisional operating pursuant to Article III of Chapter 8.50 JCC.
e. JCC 8.50.020 shall be amended to add a new subsection (6) exception as follows: (6) The
operation of a commercial shooting facility sited in accordance with Title 18 JCC that has
an operating permit or a provisional operating permit issued pursuant to Article III, of
Chapter 8.50 JCC.
f. The exception in JCC 8.50.020(5) shall be amended to become JCC 8.50.020(7) and shall
then state: (7) The continued operation of legally established private or public gun club
facilities that are not commercial shooting facilities as defined in Article III of Chapter 8.50
JCC, and which were established and operating prior to the enactment of the no shooting
area ordinance or the development of outdoor ranges constructed in compliance with JCC
18.20.350(8).
g. The definition of "firearm" in JCC 8.50.40 shall be changed to:
Firearm" means a weapon or device from which a projectile or projectiles may be fired
by an explosive such as gunpowder. The definition of "firearm" includes the terms pistol,
rifle, short -barreled rifle, shotgun, short -barreled shotgun, machine gun, and antique
firearm as those terms are defined in RCW 9.41.010. The term "firearm" shall not include:
a) devices, including but not limited to "nail guns," which are used as tools in the
construction or building industries and which would otherwise fall within this definition;
or, (b) a "destructive device" as defined in 18 U.S.C. §921(a)(2).
h. Wherever the words "this chapter" appears in Article I or Article II of JCC 8.50 when not
preceded by the words "Article I," these words shall be changed to "articles I and II of this
3 of 41
chapter." Without limitation, this change shall be made in JCC 8.50.010, JCC 8.50.030,
JCC 8.50.060(1), JCC 8.50.070, and JCC 8.50.080.
i. Consistent with the above, Chapters I and 11 of Chapter 8.50 JCC shall be amended as
shown in Appendix A.
j. Article III of Chapter 8.50 JCC shall be added as set forth in Appendix B.
Section 2. Conflicts with JCC. 18.20.350(8). If any provision of this article conflicts with JCC
18.20.350(8), the provisions of this article shall prevail.
Section 3. Effect on the Moratorium. The moratorium is continued pending completion of the
Planning Commission consideration of proposed changes to Title 18 JCC and BoCC consideration
of changes to Article 2, Chapter 8.50 JCC (No Shooting Areas) and Chapter 8.70 JCC (Noise
Control).
Section 4. Duration of the Moratorium. Unless subsequently extended by the BoCC pursuant to
state law, the moratorium adopted by Ordinance No. 05-1218-17 shall remain in effect not longer
than one year from its adoption, consistent with the work plan detailed in Section 6 of Ordinance
No. 05-1218-17.
Section 5. Findings. The BoCC hereby adopts the above recitals (the "WHEREAS" statements)
as its findings of fact in support of this Ordinance.
Section 6. Severability. The provisions of this Ordinance are declared separate and severable. If
any provision of this Ordinance or its application to any person or circumstances is held invalid,
then the remainder of this Ordinance or application of its provisions to other persons or
circumstances shall remain valid and unaffected.
Section 7. Establishment of a Fee. The department shall charge a fee base fee of $450 plus actual
costs incurred (including consultant work) for processing an application for a commercial shooting
facility. This fee shall be added to the Appendix Fee Schedule for the department.
Section 8. SEPA Categorical Exemption. This ordinance is categorically exempt from the State
Environmental Policy Act under WAC 197-11-800(13)(c) and WAC 197-11-800(19).
Section 9. Effective Date. This ordinance is effective immediately upon adoption.
SIGNATURES FOLLOW ON NEXT PAGE)
4 of 41
ADOPTED this 2nd day of November 2018, at a:Sp p.m.
ATTEST:
Carolyn Ilaway,
Deputy Clerk of the Board
5 of 41
JEFFERSON COUNTY
BOARD OF TY O MISSIONERS
David Sul ivan, air
Kathleen Kler, Member
Voted A aginst)
Kate Dean, Member
APPROVED AS TO FORM:
j -:'r ///z
Philip C. Hunsucker, ate
Chief Civil Deputy Prosecuting Attorney
Sections:
APPENDIX A
Modifications to Current Articles I and II of Chapter 8.50 JCC]
Chapter 8.50
NO SHOOTING ARE SHOOTING IN THE COUNTY
Article I. Establishment Procedures for No Shooting Areas
8.50.010 Purpose.
8.50.020 Exemptions.
8.50.030 Prohibited.
8.50.040 Firearms defined.
8.50.050 Creation, alteration or dissolution of a no shooting area.
8.50.060 Violations — Misdemeanors — Penalty — Arrest.
8.50.070 Enforcement officers and procedures.
8.50.080 Interpretation.
Article II. Boundary Descriptions for No Shooting
8.50.100 Kala Point.
8.50.110 Port Ludlow.
8.50.120 Brinnon — Black Point.
8.50.130 Brinnon.
8.50.140 Brinnon — Triton Cove.
8.50.150 Brinnon — Olympic Canal Tracts.
8.50.160 South Coyle Peninsula.
8.50.170 Paradise Bay.
8.50.180 Chimacum Creek.
8.50.190 Tala Shore.
8.50.200 Ocean Grove.
Article III. Commercial Shooting Facilities
8.50.210 Purpose.
8.20.220 Definitions.
8.50.230 Operating Permit Required.
8.50.240 Application for a Commercial ShootingFyOperating Permit.
8.50.250 Minimum Standards.
8.50.260 Administrative Remedy for Decisions Made by the Director.
8.50.270 Judicial Appeals.
8.50.280 Safe Harbor for Owners and Operators.
8.50.290 Reports of Violations of this Article.
8.50.300 Review Committee.
6 of 41
8.50.3 10 Conflicts with JCC 18.20.350(8) and Limitations on the Applicability of this
Article.
8.50.320 Warning and Disclaimer of Liability.
Article I. Establishment Procedures for No Shooting Areas
8.50.010 Purpose.
The purpose of articles I and II of this chapter is to establish a process for the establishment,
alteration, or dissolution of "no shooting" areas in unincorporated Jefferson County and to
provide regulation of the discharge of firearms in such areas as provided in articles I and II of
this chapter. The creation of a no shooting area shall be considered in accordance with RCW
9.41.300(2)(a) wherein counties are authorized to enact laws and ordinances restricting the
discharge of firearms "where there is a reasonable likelihood that humans, domestic animals, or
property may be jeopardized." County officials shall endeavor to facilitate solutions within
communities to resolve concerns leading to petitions for no shooting areas. Areas considered for
creation, alteration, or dissolution of a no shooting area shall be considered on an individual
basis to adequately assess the motivation for the proposal and to resolve existing differences
regarding an area. Creation of a no shooting area must be realistically enforceable in the area
designated. [Ord. 2-07 § 1 ]
8.50.020 Exemptions.
The designation of a no shooting area shall continue to allow:
1) The use of firearms by citizens pursuant to RCW 16.08.020 regarding dogs, or other animals,
endangering livestock.
2) The lawful use of a firearm by a law enforcement officer in the performance of their duties.
3) The use of firearms to lawfully slaughter farm animals.
4) The lawful use of force by citizens.
5) The operation of an indoor commercial shootingfacilityacility which has obtained an operating
permit or provisional operating pursuant to Article III of Chapter 8.50 JCC.
6) The operation of a commercial shootingfacility sited in accordance with Title 18 JCC that
has an operating permit or a provisional operating permit issued pursuant to Article III, of
Chapter 8.50 JCC.
5)(7) The continued operation of legally established private or public gun club facilities or
commercial shooting ranges that are not commercial shooting facilities as defined in Article III
of Chapter 8.50 JCC, and which were established and operating prior to the enactment of the no
shooting area or the development of outdoor ranges constructed in compliance with JCC
18.20.350(8). [Ord. 2-07 § 2]
8.50.030 Prohibited.
It is unlawful for any person to discharge any firearm or to propel from any portion of Jefferson
County any projectile discharged from any firearm across, in or into a no shooting area
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established by Jefferson County. Articles I and II of Tthis chapter shall not abridge the right of
the individual guaranteed by Article I, Section 24 of the State Constitution to bear arms in
defense of self or others. [Ord. 2-17; Ord. 2-07 § 3]
8.50.040 Firearms defined.
Fir-eann," as used in this ehapter-, shall be defined as &-,y deviee that fir -es or- diseharges a
pistols, o „ lvers shotguns and ,.:rfos [Ord. 2 07-§41 "Firearm" means a weapon or device from
which a projectile or projectiles may be fired by an explosive such as gunpowder. The definition
of "firearm" includes the terms pistol, rifle, short -barreled rifle, shotgun, short -barreled shotgun,
machine gun, and antique firearm as those terms are defined in RCW 9.41.010. The term
firearm" shall not include: (a) devices, including but not limited to "nail guns," which are used
as tools in the construction or building industries and which would otherwise fall within this
definition; or, (b) a "destructive device" as defined in 18 U.S.C. Section 921(a)(2).
8.50.050 Creation, alteration, or dissolution of a no shooting area.
1) The process for the creation, alteration, or dissolution of a no shooting area can be initiated in
accordance with RCW 9.41.300, wherein counties are authorized to enact laws and ordinances
restricting the discharge of firearms "where there is a reasonable likelihood that humans,
domestic animals, or property may be jeopardized," by either:
a) A petition filed by residents containing the signatures of at least 20 elector -residents of each
voting precinct in the area under consideration; or
b) A majority vote of the board of county commissioners.
2) Petitions or requests for the creation of a no shooting area or to alter or dissolve an existing
no shooting area by the Jefferson County board of commissioners shall be filed with the clerk of
the board of county commissioners. The petition or request must be based on a definable threat
to the public health, safety or general welfare.
3) The petition or request must include a legal description of the proposed boundaries with: a
map showing the proposed area, a written statement explaining the reasons for the petition, and a
statement, where applicable, of reported incidence involving firearms in the petition area.
4) After petition signatures have been verified by the Jefferson County auditor -elections and the
board of county commissioners finds the petition warrants consideration, the county
commissioners shall hold a public hearing regarding the petition or may choose to facilitate an
amicable solution within the proposed area or may assign a review committee to consider the
merit of the petition specific to the area under consideration. The county commissioners may
have the review committee consider the petition before establishing a date for the public hearing.
Treaty tribes will be contacted by the county to identify any concerns and invite their
participation.
a) The review committee shall consist of:
i) The county sheriff or his designee.
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ii) The director of the department of community development, or his designee.
iii) Three residents -at -large to be appointed by the county commissioners.
iv) At least one representative of tribal interests will be invited.
v) Representative stakeholders from the petition area as determined by the county
commissioners, with the goal of including persons from all sides of any contended or
questionable issue.
b) The review committee shall consider, but is not limited to consideration of, the location,
terrain and surrounding land use of the petition area. The committee shall also consider any
additional instructions given by the county commissioners at the assignment of the committee.
The county commissioners shall hold a public hearing on the review committee's
recommendations soon after they are received by the commission.
5) Legal notice of the public hearing shall be published one time in the official newspaper of the
county at least 10 days prior to the hearing.
6) If the county commissioners find the formation, alteration, or dissolution of the petitioned
area to be beneficial to the public health, safety or general welfare, the area shall be established,
altered, or dissolved as a no shooting area by ordinance. The board of commissioners shall
consider, but is not limited to considerations of, the location, terrain and surrounding land use of
the petitioned area. The board of commissioners shall determine the final boundaries for the
creation of a no shooting area.
7) Public works may post signs along public roads indicating a no shooting area boundary
where deemed necessary. The department of community development shall inform development
and permit applicants if a parcel is within a no shooting area. [Ord. 2-07 § 5]
8.50.060 Violations — Misdemeanors — Penalty — Arrest.
1) Any person discharging a firearm in a no shooting area is guilty of a misdemeanor. It shall
not be a violation of articles I and II of this chapter when a person discharges a firearm in
accordance with the provisions of RCW 9A.16.020.
2) Any law enforcement officer having probable cause to believe that a person has committed a
violation of articles I and II of this chapter has the authority to arrest the person.
3) The first offense for violation of article I or II of this chapter constitutes a civil penalty not to
exceed $100.00. Consecutive offenses are punishable, upon conviction, by a fine not to exceed
250.00 or by confinement in the county jail for a period of not more than 90 days. [Ord. 2-07 §
6]
8.50.070 Enforcement officers and procedures.
Enforcement of articles I and II ofthis chapter may be by any state or county law enforcement
officer, state game officer, or state fish and wildlife officer. All such enforcement officers are
empowered to issue citations to and/or arrest without warrant persons violating the provisions of
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this chapter. Said enforcement officers may serve and execute all warrants, citations and other
process issued by the courts.
In addition, mailing by registered mail of such warrant, citation or other process to the last
known place of residence of the offender shall be deemed as personal service upon the person
charged. Said enforcement officers may seize and hold as evidence the weapon and ammunition
of any person violating the provisions of this chapter. [Ord. 2-07 § 7]
8.50.080 Interpretation.
In the event any other county ordinance, whether or not codified, is in conflict with any of the
terms of articles I and II of this chapter, the more stringent shall be construed as applicable. [Ord.
2-07 § 8]
Article II. Boundary Descriptions for No Shooting Areas
8.50.100 Kala Point.
The area described below is hereby established as a no shooting area as provided in Article I of
this chapter:
Bordered on the West by Airport Cutoff Road; on the North by Old Fort Townsend Road and the
Old Fort Townsend State Park boundary; on the South by Prospect Avenue extending to Port
Townsend Bay; and on the East by the Shoreline of Port Townsend Bay.
Ord. 12-95]
8.50.110 Port Ludlow.
The area described below is hereby established as a no shooting area as provided in Article I of
this chapter:
The northern boundary begins at the Admiralty Inlet Shoreline adjacent to northern property
lines of lots in Port Ludlow #5 at the northern end of Montgomery Lane. The boundary then
moves westward across the properties mentioned above along their northern property lines,
crosses Oak Bay Road and continues westward along the fire hall northern property line and on
west along the northern property lines of Port Ludlow #2, Area 3, at the northern end of Keefe
Lane.
At the NW corner of Lot #75 on Keefe Lane the No Shooting boundary turns south along the
western side of Jefferson Avenue to the northern property lines of Port Ludlow #2, Area 3 lots
along Fleet Drive. The boundary then moves west and then south around the cemetery, across
Swansonville Road and continues south along the western side of Talbot Way to the junction of
Talbot Way and Walker Way. Here the boundary turns west along the north side of Walker Way
and continues as Walker Way becomes a gravel road to the NW corner of the properties in Port
Ludlow #6.
The boundary then heads generally south along the western property lines of Port Ludlow #6 to
Oak Bay Road. It then turns west along the north side of Oak Bay Road, then south and then east
around the Port Ludlow RV Park and commercial area to Paradise Bay Road. The boundary then
turns south along the western side of Paradise Bay Road to a point opposite the end of Camber
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Lane, it then heads SW picking up the outside of the fairways of the Port Ludlow Golf Course
staying at the outside fairway points entirely around the western, southern and the eastern
portions ofthe golf course to the southern property lines of Fairwood Village.
The boundary then heads east along the south side of Springwood Drive and across Teal Lake
Road. It then swings NE along the property lines of Teal Lake Village on the south side of
Outlook Lane. The boundary then heads north along the eastern side of the Osprey Conservation
Tract, which is east of the eastern property lines of Teal Lake Village lots at the end of Clear
View Place and Seaway Place to Paradise Bay Road. The boundary then continues north across
Paradise Bay Road along the eastern property lines of Bay View Village, Divisions 1 and 2 to
Ludlow Bay Road. The boundary then turns NE along the SE side of Ludlow Bay Road to the
end of Ludlow Beach Tracts #2. It then turns NW to the shoreline of Ludlow Bay.
Ord. 4-96]
8.50.120 Brinnon — Black Point.
The area described below is hereby established as a no shooting area as provided in Article I of
this chapter:
The northern boundary begins at and includes the old and new Pleasant Harbor Marinas at mile
marker #308 on Highway 101. The boundary then moves southwesterly along the highway to the
first Duckabush River Bridge at mile marker #310. The boundary includes all of Black Point
surrounded by Hood Canal, to the East of Highway 101 between the above referenced mile
markers EXCEPT that portion along the southern boundary known as the Duckabush Flats which
is along the Duckabush River Estuary below the shoreline bluff.
Ord. 5-97]
8.50.130 Brinnon.
The area described below is hereby established as a no shooting area as provided in Article I of
this chapter:
The area bordered on the east by Highway 101; on the north by the Dosewallips Road; on the
west by the power line; and on the south by the Dosewallips River.
Ord. 3-99]
8.50.140 Brinnon — Triton Cove.
The area described below is hereby established as a no shooting area as provided in Article I of
this chapter:
The area bordered on the north by an unnamed year around creek from the Hood Canal to the
Bonneville power lines (the area under the power lines is to be included in the No Shooting
zone); on the West by the far side of the power lines; the East by Hood Canal; and on the South
by the Jefferson County line.
Ord. 7-00]
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8.50.150 Brinnon — Olympic Canal Tracts.
The area described below is hereby established as a "No Shooting" zone as provided in Article I
of this chapter. The no shooting area is encompassed by the following description:
Beginning at the point of intersection of the centerline of U.S. Highway 101 and the centerline of
Duckabush Road;
Thence northwesterly along the centerline of Duckabush Road to the intersection with the most
westerly line of the Bonneville power lines;
Thence southwesterly along the most westerly line of the Bonneville power lines to the
intersection of said power lines with McDonald Creek;
Thence southeasterly along McDonald Creek to the shoreline of Hood Canal;
Thence northerly along the shoreline of Hood Canal to the tidal area at the mouth ofthe
Duckabush River;
Thence northerly along the shoreline to a point along the shoreline that is due west of the
intersection ofthe centerline of U.S. Highway 101 and the centerline of Duckabush Road;
Thence west to the point of beginning.
Said property being portions of Sections 15, 16, 17, 20, 21, 28 and 29 all in Township 25 North,
Range 2 West; Willamette Meridian.
All lying in Jefferson County, state of Washington.
Ord. 12-02]
8.50.160 South Coyle Peninsula.
The area described below is hereby established as a "No Shooting" zone as provided in Article I
of this chapter. The no shooting area is encompassed by the following description:
That portion of Sections 2, 3, 4 and 5 of Township 25 North, Range 1 West, Willamette
Meridian, and Sections 27, 28, 29, 32, 33, 34 and 35 of Township 26 North, Range 1 West,
Willamette Meridian, described as follows:
Beginning at the Southeast corner of Tax 1 as described under Parcel A in Auditor File Number
488422, Section 28 Township 26 North, Range 1 West Willamette Meridian;
Thence continuing along the extension of the South line of said Tax 1 to the centerline of said
Payne Road and the TRUE POINT OF BEGINNING;
Thence Westerly along the extension of the South line and along the South line of said Tax 1 to
the Northeasterly corner of Tax 2 as described under Auditor's File Number 422414;
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Thence Southerly and Westerly along the Easterly and Southerly boundary of the parcel
identified under said Auditor's File Number 422414;
Thence continuing Westerly along the extension of the Southerly line of said parcel to the 0.0
low tide mark in Dabob Bay;
Thence Southerly along the 0.0 low tide mark of Dabob Bay, and Northerly and Easterly along
the 0.0 low tide mark of Hood Canal to the point of intersection of the centerline of East Go-
onna Beach Drive extended Easterly from the most Easterly point of said centerline located in
the Southwest 1/4 of Section 27, Township 26 North, Range 1 West, Willamette Meridian, and
said 0.0 low tide mark of Hood Canal;
Thence Westerly along said extension and the centerline of East Go-onna Beach Drive to the
intersection of said East Go-onna Beach Drive with the centerline of Coyle Road;
Thence Northerly and Easterly along the centerline of Coyle Road to the intersection of said road
with the centerline of Payne Road;
Thence Westerly and Southerly along the centerline of Payne Road to the TRUE POINT OF
BEGINNING;
EXCEPTING THEREFROM any portion of the following described parcels that lie within the
above described bounds and that do not lie within the Northerly and Easterly 200 foot setback
from the centerline of Zelatched Point Road, within the Northerly and Westerly 200 foot setback
from the centerline Coyle Road or within the Southerly and Easterly 200 foot setback from the
centerline Payne Road:
The South one half of the Southeast quarter of Section 28, Township 26 North, Range 1 West,
Willamette Meridian, lying Southerly and Easterly of Payne Road;
The Northeast quarter of Section 33, Township 26 North, Range 1 West, Willamette Meridian,
lying Northerly and Westerly of Coyle Road;
The South one half of the Northwest of Section 33, Township 26 North, Range 1 West,
Willamette Meridian, lying Northerly and Easterly of Zelatched Road; and
The Northwest quarter of the Southeast quarter of Section 33, Township 26 North, Range 1
West, Willamette Meridian, lying Northerly and Easterly of Zelatched Road and Northerly and
Westerly of Coyle Road;
Situate in Jefferson County, Washington.
Ord. 12-14 § 1; Ord. 20-02]
8.50.170 Paradise Bay.
The area described below is hereby established as a no shooting area as provided in Article I of
this chapter.
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All of the land lying within the following bounds:
Beginning at the intersection of the most northerly line of Tract A of the Plat of Woodridge
Village Division 1 as recorded in Volume 7 Pages 47 through 50 of Plats, Jefferson County, state
of Washington and the easterly margin of Teal Lake Road;
Thence northeasterly along said northerly line of said Tract A to the intersection of said line with
the southerly margin of Crestview Drive as recorded in the Plat Amendment to Teal Lake
Village Volume 6 Pages 186 through 197 of Plats, Jefferson County, state of Washington;
Thence in a straight line northeasterly to the intersection of said line with a point located at the
intersection of the southerly boundary of Tract C of the said plat of Woodridge Village Division
1 and the northerly margin of said Crestview Drive;
Thence northerly along the northerly margin of said Crestview Drive, said margin also being the
westerly boundary of said Tract C, to the southerly margin of Outlook Lane as recorded in said
plat of Amendment to Teal Lake Village, said line also being the northerly line of said Tract C;
Thence easterly along the northerly boundary of said Tract C to the intersection of said line with
the most easterly boundary of said plat of Amendment to Teal Lake Village;
Thence northerly along the easterly boundary of said plat of Amendment to Teal Lake Village to
the intersection of said line with the southerly margin of Paradise Bay Road;
Thence along said southerly and westerly margin in an easterly and southerly direction to the
intersection of said westerly margin of Paradise Bay Road with the North line of Section 22,
Township 28 North, Range 1 East, W.M.;
Thence easterly along the North line of said Section 22 to the mean lower low water boundary of
Hood Canal;
Thence southeasterly and easterly along said mean lower low water boundary to Point Hannon
and the easterly mean lower low water boundary of Hood Canal in Section 25, Township 28
North, Range 1 East, W.M.;
Thence following the mean lower low water boundary of Hood Canal through Sections 25, 26,
35 and 36, all lying in Township 28 North, Range 1 East, and Section 2, Township 27 North,
Range 1 East, W.M., to the intersection with the northerly margin of State Route 104 with said
mean lower low water boundary of Hood Canal;
Thence northwesterly along the north margin of State Route 104 to the intersection of said
margin with the easterly margin ofParadise Bay Road;
Thence northerly and northwesterly along the easterly margin ofParadise Bay Road to the south
line of Section 23, Township 28 North, Range 1 East, W.M.;
Thence westerly along said south line of Section 23 to the intersection with the westerly margin
of Paradise Bay Road;
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Thence southerly along the westerly margin of Paradise Bay Road to the intersection with the
northerly margin of Andy Cooper Road;
Thence westerly along the northerly margin of said Andy Cooper Road to the intersection with
the easterly margin of Teal Lake Road;
Thence northwesterly along the easterly margin of Teal Lake Road to the point of beginning of
this description.
All situated within Jefferson County, Washington.
Ord. 4-08 § 1 ]
8.50.180 Chimacum Creek.
The area described below is hereby established as a no shooting area as provided in Article I of
this chapter.
All of the following described lands, being a portion of Sections 34 and 35, Township 30 North,
Range 1 West, W.M., and Sections 2 and 3, Township 29 North, Range 1 West, W.M., lying
within the following bounds:
Beginning at the intersection of centerline of as -built Prospect Avenue extended Easterly to the
westerly shoreline of Port Townsend Bay said point being the True Point of Beginning of this
description;
Thence Westerly along the centerline of as -built Prospect Avenue to the intersection of said road
with the centerline of State Route 19, also known as Airport -Cutoff Road;
Thence Southeasterly along the centerline of said State Route 19 to the intersection with the
centerline of Irondale Road;
Thence Easterly along the centerline of Irondale Road to the intersection with the centerline of
platted Market Street as said road is platted in the plat of Harrisburg recorded in Volume 1 Page
16 records of Jefferson County, Washington;
Thence Easterly along said centerline of Market Street to the centerline of Maple Street as
platted on said plat;
Thence continuing Easterly along the centerline of platted Market Street lying North of Block 40
and Reserve A, as platted in the plat of Irondale, recorded in Volume 3 Page 5 records of
Jefferson County, Washington and the extension of said Market Street to the Westerly shoreline
of Port Townsend Bay;
Thence Northerly and Westerly, upland of the 0.0 low tide mark with a line at the mouth of
Chimacum Creek between the following coordinates: -122.771 48.049D DD to -122.771.48.049
DD, within Port Townsend Bay to the True Point of Beginning.
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All lying and being in Jefferson County, Washington.
Ord. 3-17 § 1; Ord. 11-08 § 1]
8.50.190 Tala Shore.
The area described below is hereby established as a no shooting area as provided in Article I of
this chapter.
That portion of Section 15, Township 28 North, Range 1 East, W.M., Jefferson County,
Washington, encompassed within the following described boundary:
Beginning at the intersection of the South Section line of Section 15, Township 28 North, Range
1 East, W.M. Jefferson County, State of Washington and the centerline of a private road known
as East Ludlow Ridge Road, as said private road is described in Auditor File Number 285012
records of Jefferson County, Washington; Thence Northerly along said private road centerline to
the North line ofthe Southeast Quarter ofthe Northwest Quarter of Sections 15, Township 28
North, Range 1 East; Thence Easterly along said North line of the Southeast Quarter of the
Northwest Quarter of Sections 15 to the Northwest corner of Government Lot 4; Thence Easterly
along the North line of Government Lot 4 and the Easterly extension of the North line of
Government Lot 4 to the 0.0 low tide mark within Hood Canal,
Thence Southerly along said 0.0 low tide mark within Hood Canal to the intersection of said 0.0
low tide mark with the Easterly extension of the South section line of said Section 15; Thence
West along said Easterly extension of said South section line and the South section line of
Section 15, Township 28 North, Range 1 East, to the intersection of said South line and the
centerline of the private road known as East Ludlow Ridge Road said point being the point of
beginning of this description.
TOGETHER WITH:
All of Section 10, Township 28 North, Range 1 East, W.M. Jefferson County, State of
Washington.
All situated in Jefferson County, State of Washington.
Ord. 6-14 §§ 1, 2]
8.50.200 Ocean Grove.
The area described below is hereby established as a no shooting area as provided in Article I of
this chapter.
Albert Balch and Harry Cotton's Ocean Grove Estates, as per plat recorded in Volume 4 of Plats,
Page 20, records of Jefferson County, Washington;
TOGETHER WITH Albert Balch and Harry Cotton's Ocean Grove Estates No. 2, as per plat
recorded in Volume 4 of Plats, Page 27, records of Jefferson County, Washington;
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TOGETHER WITH that portion of Government Lot 4, Section 24, Township 30 North, Range 2
West, W.M., not included in said Albert Balch and Harry Cotton's Ocean Grove Estates and in
Albert Balch and Harry Cotton's Ocean Grove Estates No. 2.
TOGETHER WITH that portion of Lot 5 of survey recorded in Volume 11 of Surveys, Page 54,
under Auditor's File Number 328912, located within Government Lot 5, Section 24, Township
30 North, Range 2 West, W.M., described as follows:
Beginning at the Northwest corner of said Lot 5;
Thence proceeding on a bearing of S 88° 30' 34" East 67.21 feet along the North line of said Lot
5 to the Southwest corner of Lot 12, plat of Ocean Grove No. 2, Volume 4 of Plats, Page 27,
records of Jefferson County;
Thence continuing South 88° 30' 34" East 76.22 feet to the Southeast corner of said Lot 12;
Thence turning South 26° 34' 58" West 166.11 feet to a rebar and cap marked "Parrish, LS
29535";
Thence continuing South 26° 34' 58" West 9.07 feet;
Thence North 83° 52' 04" West 69.36 feet to the West boundary of said Lot 5;
Thence North 01° 29' 25" East 8.53 feet to a rebar and cap marked "Parrish, LS 29535" and the
West line of said Lot 5;
Thence along the West line of Lot 5 North 01' 29' 25" East 144.51 feet to the Point of
Beginning;
TOGETHER WITH Albert Balch and Harry Cotton's Ocean Grove Estates No. 3, as per plat
recorded in Volume 4 of Plats, Page 31 and amended in Volume 6 of Plats, Page 138-139,
records of Jefferson County, Washington.
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APPENDIX B
Article III. Commercial Shooting Facilities
8.50.210 Purpose.
The purpose of this article is to provide uniform requirements for the establishment and
operation of all commercial shooting facilities in unincorporated parts of the county. These
requirements include provisions that:
1) Establish a permitting procedure and rules for the siting, design and operation of commercial
shooting facilities that protect participants, spectators, neighboring properties and the public;
2) Include appropriate measures designed to make the discharge of firearms safe;
3) Protect the environment;
4) Ensure compatibility with neighboring land uses as regulated in Title 18 JCC; and,
5) Promote the continued availability in the county of shooting facilities for firearm education,
training, and practice in the safe use of firearms, and firearm sports, without prohibiting or
expressly regulating the discharge of firearms.
8.20.220 Definitions.
The following definitions shall apply in the interpretation and enforcement of the ordinance
codified in this article:
1) "Aggrieved party" means a person or persons who can demonstrate that a decision by the
director or a hearing examiner will prejudice them or their interests that are protected by
federal or state law or JCC.
2) "Annual inspection" means the annual inspection required by JCC 8.50.230(5)(c).
3) "Applicant" means a person applying for an operating permit.
4) "Armed forces" means the armed forces of the United States or of the National Guard or
organized reserves.
5) "Backstop" means a barrier that stops or redirects bullets fired on a shooting range, usually
directly behind the target line.
6) "Baffles" means barriers constructed to contain bullets or to reduce, redirect or suppress
sound waves.
7) "Ballistic trauma" means wounds to humans or domestic animals or property damage from
the discharge of firearms.
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8) "Berm" means an embankment used for restricting bullets to a given area, as a protective
or dividing wall between shooting areas, or for noise abatement.
9) "BMP" means best management practice or practices.
10) "Bullet" means a single projectile fired from a firearm.
11) "Buffer zone" has the same meaning as in JCC 18.10.20B and includes but is not limited
to buffer zones required by Chapter 18.22 JCC (the critical areas ordinance) or Chapter
18.25 JCC (the shoreline master program ordinance), federal or state law.
12) "Cartridge" means a self-contained unitized round of ammunition that is made up of a case,
a primer, powder, and a bullet. The case usually is made of brass but may be steel, metal
alloy or plastic.
13) "CFR" means the Code of Federal Regulations, as it now exists or is later amended.
14) "Cold Range" means a shooting range open to the public on which all firearms are to be
unloaded at all times, unless instructed otherwise by a range master or a range officer.
15) "Commercial shooting facility" means an indoor facility or outdoor facility designed and
specifically designated for safe shooting practice with firearms, whether open to the public,
open only to private membership, open to organizational training for law enforcement
officers or organizational training for members of the armed forces, or any combination of
the above that for the use of the commercial shooting facility requires a contract, charges
a fee or other compensation, or requires membership. There may be one or more shooting
ranges located at a commercial shooting facility. The term commercial shooting facility
does not include:
a) Shooting facilities that are both owned and operated by any instrumentality of the
United States, the State of Washington, or any political subdivision of the State of
Washington;
b) Any portion of a privately owned property used for lawful shooting practice solely by
its owner or the owner's guests without payment of any compensation to the owner of
the privately owned property or to any other person. For the avoidance of doubt, where
privately owned property is used primarily for lawful shooting practice for guests of
the owner, and where the other uses of the property either facilitate shooting practice
or are incidental, intermittent or occasional, it is presumed that the privately owned
property used for lawful shooting practices is a commercial shooting facility.
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16) "Cowboy action shooting" means a type of match using one or a combination of firearms in
Old West themed" courses of fire for time and accuracy.
17) "Critical areas" mean critical areas as defined in Chapter 18.22 JCC.
18) "Department" means the county department of community development.
19) "Director" means the director of the county department of community development.
20) "Environmental Plan" means a plan for mitigating the environmental impacts of commercial
shooting facilities as required by JCC 8.50.240(5).
21) "Expansion" means any proposed change that increases the existing activities and uses
permitted for a commercial shooting facility, including expansions of a commercial shooting
facility lawfully operating as of the effective date of the ordinance codified in this article.
Examples of expansions include but are not limited to additional firing positions, lengthened
periods of operations, increases in permitted firearm caliber or range, or increased size of
shot fall or direct fire zones. Modifications made solely through routine maintenance of a
commercial shooting facility, such as the installation of sewer, water or other utilities,
pavement of a parking lot, the installation of safety baffles, construction of side or backstop
berms, or the construction or remodeling of a clubhouse, shall not be considered an
expansion.
22) "Exploding target" means a target that explodes when hit by a projectile.
23) "Explode" means burst or shatter violently and noisily from rapid combustion,
decomposition, excessive internal pressure, or other process, typically scattering fragments
widely.
24) "Facility Design Plan" means the written procedures or policies of a commercial shooting
facility that specifically define the facility design requirements for the commercial shooting
facility as required by JCC 8.50.240(2).
25) "False Report" means a report of violation that results in the dispatch of the department, the
sheriff or emergency services for a violation of this article when, in fact, there was no
violation of this article and no reasonable belief there was a violation of this article.
26) "Firearm" has the same meaning as in JCC 8.50.040.
27) "Firing line" means a line parallel to the targets from which firearms are discharged.
28) "Firing point" means a location from which one individual fires at an associated target
located down range.
29) "Five -stand shooting" means a shotgun shooting sport where there are five stations or stands
on the firing line and multiple strategically placed target throwers that throw targets in front
of the firing line.
30) "Hazardous substance" means any liquid, solid, gas, or sludge, including any material,
substance, product, commodity, or waste, regardless of quantity, that exhibits any of the
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physical, chemical, or biological properties described in WAC 173-303-090 or WAC 173-
303-100.
31) "Hazardous waste" means those solid wastes designated by 40 CFR Part 261 and regulated
as hazardous and/or mixed waste by the United States EPA.
32) "Hot Range" means a shooting range on which all firearms are allowed to be loaded at all
times.
33) "Impact area" means the area in a backstop or bullet trap directly behind the target where
bullets are expected to impact or the area downrange where bullets will impact if not
captured by a backstop or bullet trap.
34) "Indoor facility" means a commercial shooting facility within a fully enclosed structure.
35) "JCC" means the Jefferson County Code, as it now exists or is later amended.
36) "Law enforcement officer" means "federal peace officer" as defined in RCW 10.93.20(6),
general authority Washington peace officer" as defined in RCW 10.93.20(3), "law
enforcement' officer as defined in RCW 9.41.010 (12), "peace officer" as defined in RCW
43.101.010(,11), "limited authority Washington peace officer" as defined in RCW
10.93.20(4), "qualified law enforcement officer" as defined in 18 U.S.C. Section 928B(c)
and, "specially commissioned Washington peace officer" as defined in RCW 10.93.20(5).
For the avoidance of doubt, "law enforcement officer" includes federal, tribal, state, and
local members of law enforcement organizations certified by their jurisdiction to enforce the
laws of that jurisdiction.
37) "Life safety incident' means an incident that causes ballistic trauma to humans, domestic
animals, or property.
38) "Member of the armed forces" means a member of the armed forces, when on duty.
39) "NRA Range Source Book" means the most current version of The NRA Range Source
Book published by the National Rifle Association.
40) "Operations Plan" means the written procedures or policies ofa commercial shooting facility
that specifically define the operations requirements for the commercial shooting facility as
required by JCC 8.50.240(4).
41) "Operator" means the person operating the commercial shooting facility.
42) "Operating Permit' means the operating permit required by this article.
43) "Or" means both or and and/or.
44) "Other Reports of Violations" means reports of violations that are not life safety incidents
or threats to humans, domestic animals or property.
45) "Outdoor facility" means a commercial shooting facility that is not an indoor facility.
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46) "Owner" means the holder of title to the real property on which a commercial shooting
facility is located.
47) "Person" means person as that term is defined in RCW 1.16.080.
48) "Physical containment" means the use of physical barriers that are sufficient to contain the
projectile from the highest power firearm used on a shooting range when the shooting range
is used in accordance with its operating permit. Physical containment may include, but is
not limited to baffles, sidewalls, backstops and berms of adequate design, quantity, and
location to ensure that projectiles cannot escape the commercial shooting facility.
49) "Practical shooting" means a sport that challenges an individual's ability to shoot rapidly
and accurately with a firearm. To do this, shooters take on obstacle -laden shooting courses
called stages, some requiring many shots to complete, and others just a few. While scoring
systems vary between practical shooting organizations, each measures the speed with which
the stage is completed, with penalties for inaccurate shooting.
50) "Projectile" means an object fired from a firearm.
51) "Provisional operating permit" means a provisional operating permit issued pursuant to JCC
8.50.230(4)(c).
52) "Qualified Shooting Range Evaluator" means a person who has been an NRA range
technical team advisor or who is a professional engineer with expertise in the design of
shooting ranges.
53) "Range master" or "range officer" means a person or persons trained and appointed by the
operators of a commercial shooting facility to oversee the safe discharge of firearms in
accordance with the requirements of this article and any additional safety specifications that
may be adopted by the operators of the commercial shooting facility. At a minimum, a range
master or a range officer shall complete the necessary training and obtain certification to be
a range master or range officer from the National Rifle Association, the NROI National
Range Officer Institute, the IDPA International Defensive Pistol Association, the SASS
Single Action Shooters Society, the CMP Civilian Marksmans Program, the Washington
State Criminal Justice Commission, an armed forces or, as determined by the director, other
training equivalent to the National Rifle Association training for certification as a range
master or range officer.
54) "RCW" means the Revised Code of Washington, as it now exists or is later amended.
55) "Report of Violation" means a report of a violation of this article received by the department
or the sheriff.
56) "Routine maintenance" means repair of structures or property maintenance for which
permits are not required or repair of berms.
57) "Rules and regulations" means requirements used in the operation of a commercial shooting
facility.
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58) "Safety fan" means all areas in or outside a shooting range where projectiles may impact or
ricochet when firearms are operated in accordance with rules and regulations (as defined
above). The safety fan extends to the maximum range of the most powerful cartridge and
firearm used on the shooting range unless adequate physical containment is provided. When
physical containment is adequate, the safety fan is limited to the area within the containment.
59) "Safety plan" means the written procedures or policies ofa commercial shooting facility that
specifically define the safety requirements for the commercial shooting facility as required
by JCC 8.50.240(3).
60) "Sheriff' means the elected sheriff of Jefferson County or designee.
61) "Shooting range" consists of a firing line or firing points, and an impact area. A commercial
shooting facility may include multiple shooting ranges.
62) "Skeet shooting" means a shotgun shooting sport where the shooter is on the firing line and
shoots at targets launched from two skeet houses in somewhat sideways paths that intersect
in front of the shooter.
63) "Sporting clays" means a form of clay pigeon shooting that consists of multiple shooting
stations laid out over natural terrain such that target presentations simulate the
unpredictability of live quarry shooting.
64) "Target" means a mark to shoot at.
65) "Target line" means the line where targets are placed.
66) "Threatened Harm" mean a reasonable likelihood that humans, domestic animals, or
property have been or will be jeopardized by the operations of the commercial shooting
facility.
67) "Tracer or incendiary ammunition" means any ammunition causing or designed to cause
fires and includes a projectile or shell that traces its own course in the air with a trail of
smoke, chemical incandescence, or fire to facilitate adjustment of the aim of a firearm.
68) "Trap shooting" means a shotgun shooting sport where a shooter on the firing line shoots at
targets launched from a single launching point and generally away from the shooter.
69) "U.S.C." means the United States Code, as it now exists or is later amended.
70) "WAC" means the Washington Administrative Code, as it now exists or is later amended.
8.50.230 Operating Permit Required.
1) Commercial shooting facilities shall be authorized and operated in accordance with an
operating permit issued by the department. No proposed or established commercial shooting
facility may operate without an operating permit. Failure to obtain an operating permit shall
result in closure of the commercial shooting facility until such time a permit is obtained.
Commercial shooting facilities that operate without an operating permit are subject to
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enforcement, including but not limited to injunctive relief. The operating permit shall govern
the scope of operations of each commercial shooting facility, and shall be issued, denied, or
conditioned based upon the standards set forth in this article.
2) The operating permit is not intended to alter the legal nonconforming use status and rights of
established commercial shooting facilities, which are governed by Title 18 JCC and the
common law, nor shall the operating permit authorize expansion of commercial shooting
facility uses that otherwise require approval pursuant to a conditional use permit or other land
use permits per Title 18 JCC.
3) New Commercial Shooting Facilities. The owner or operator of a proposed new commercial
shooting facility shall apply for an operating permit at the time of the conditional use permit
application. A hearing examiner considering a conditional use permit application pursuant to
Title 18 JCC shall review the operating permit application as part of the review of the
conditional use permit application.
4) Established Commercial Shooting Facilities.
a) The owner or operator of an established commercial shooting facility in active use on the
effective date of the ordinance codified in this article shall apply for an operating permit
not later than one hundred eighty (180) days after the effective date of the ordinance
codified in this article or within such other period as established by the director in
consultation with the applicant.
b) Subject to JCC 8.50.230(4)(c), an established commercial shooting facility must obtain an
operating permit within one year of the application required by JCC 8.50.230(4)(a).
c) If the professional evaluation (JCC 8.50.240 (7)) does not demonstrate full compliance with
this article, then a provisional operating permit may be issued by the director, provided:
i. Life Safety Deficiencies. All life safety deficiencies identified in the professional
evaluation must be corrected prior to issuance of the provisional operating permit.
ii. Critical Area Deficiencies. Any proposed operation that likely threatens to cause a
detrimental impact to a critical area must be addressed to remove that threat prior
to issuance ofthe provisional operating permit.
iii. Other Deficiencies.
A. In consultation with the owner or operator, the Qualified Shooting Range
Evaluator who performed the professional evaluation and the director will
establish a timeline for remedying all the other deficiencies noted in the
professional evaluation that are not life safety deficiencies or critical area
deficiencies.
B. If the director concludes that agreement on the timeline for correction of the
other deficiencies cannot be reached, the director shall provide written notice
of agreement to attend mediation to the applicant to be concluded within 60
days, along with a proposed timeline for correction of the other deficiencies.
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C. If the applicant does not agree to mediation within 7 days after the director
sends written notice, the timeline for correction of the other deficiencies
proposed by the director pursuant to JCC 8.50.230(4)(c)(iii)(B) shall be
established.
D. The applicant may appeal the establishment of the timeline for correction of the
other deficiencies established pursuant to subsection JCC 8.50.230(4)(c)
iii)(C) to the hearing examiner pursuant to JCC 8.50.260.
E. The provisional operating permit shall be issued only on the condition of
acceptance by the applicant of the timeline established for correction of the
other deficiencies.
F. Failure to adhere to the timeline for correction of the other deficiencies may
result in a notice of correction served by the department on the owner or
operator of the commercial shooting facility.
G. Following a notice of correction, the director and the owner or operator of the
commercial shooting facility may meet to develop a compliance plan. The
compliance plan shall establish a reasonable and specific time frame for
compliance with the timeline for correction of the other deficiencies. The
voluntary correction process is optional as deemed by the director. If the
director believes that the requirements of a voluntary correction plan are not
being met, the director shall revoke the provisional operating permit.
H. Failure to adhere to the timeline for correction of the other deficiencies 30 days
after issuance of the notice of correction or after failure to adhere to a
compliance plan shall constitute sufficient grounds for the director to terminate
immediately the provisional operating permit.
I. Termination of a provisional operating permit by the director may be appealed
pursuant to JCC 8.50.260.
J. When all other deficiencies have been corrected, the director shall issue an
operating permit.
5) Inspections and Annual Report Required.
a) Pre -Operation Inspection. Prior to issuing any operating permit or provisional operating
permit, the department shall inspect the commercial shooting facility to determine that the
commercial shooting facility complies with any applicable conditional use provisions
required by Title 18 JCC and all the requirements in the approved operating permit
application.
b) Annual report. The holder of the operating permit shall submit a report to the department
on an annual basis in a form required by the department. The annual report is due each
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year on the last day of the same month the operating permit was issued. The annual report
shall include:
i. A written statement by the owner of the commercial shooting facility declaring that the
commercial shooting facility is compliant with the initial operating permit approval;
ii. A statement of any changes to the plans required by JCC 8.50.240(1)(a) -(e), as
submitted in the application; and,
iii. A current statement of general liability insurance and any monitoring data required by
an operating permit or any applicable conditional use permit issued pursuant to Title
18 JCC.
c) Annual Inspection. After issuance of an operating permit, commercial shooting facilities
shall be subject to an annual inspection by the department following submission of the
annual report required by this section. The department shall develop a checklist for an
annual inspection. The checklist for the annual inspection shall be provided to the operator
at the time the operating permit is issued and shall be effective during the term of the
operating permit.
d) Noncompliance Inspection. A noncompliance inspection shall be triggered upon receipt
by the director of any of the following claims:
i. A claim of noncompliance with the operating permit; or,
ii. A claim that there exists either a life safety incident or threatened harm.
For noncompliance inspections:
The department shall have the authority to establish procedures for noncompliance
inspections.
ii. The department shall contact the commercial shooting facility within one business day
after receipt by the department of a claim pursuant to subsection (d) and shall give the
commercial shooting facility a written notice ofthe claim; and,
iii. The owner or operator shall make the commercial shooting facility available for
inspection not later than two business days after receiving a request for an inspection
from the department.
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e) Following an annual inspection or a noncompliance inspection:
The department shall inform the owner or operator in writing of any deficiencies or
corrective actions to be taken, which may include any of the actions authorized by
subsection (f);
ii. The owner or operator shall take corrective action within a reasonable time, as
determined by the department in consultation with the operator; and,
iii. The owner or operator shall allow the department to conduct follow-up inspections to
verify that corrective action has been taken.
f) Life Safety Incident. If the director determines there was a life safety incident:
i. The director may suspend or modify the operating permit, close the commercial
shooting facility or a shooting range, or modify shooting range operations;
ii. The director shall provide the owner or operator a written notice that shall set forth
each claimed life safety incident with a specific reference to applicable violation of this
article or operating permit and the corrective measures to be taken;
iii. The owner or operator shall respond in writing to the written notice provided by the
director and shall take any necessary corrective measures within a reasonable time, as
determined by the department in consultation with the operator;
iv. The owner or operator shall allow the department to conduct follow-up inspections to
verify that corrective action has been taken;
V. The department shall verify that corrective action has been taken; and,
vi. Until the corrective measures are completed and verified, the director's determination
in JCC 8.50.230(5)(f)(i). shall remain in effect.
g) Effect of a Suspension of an Operating Permit. An operating permit that has been
suspended requires the commercial shooting facility to cease any firing activities until the
permit has been reinstated by the director.
6) In addition to the operating permit required by this article, land use permit applications may
be required. Land use permit applications for a commercial shooting facility shall be governed
by Title 18 JCC.
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8.50.240 Application for a Commercial Shooting Facility Operating Permit.
1) Required Components. The application for a commercial shooting facility operating permit
shall contain the following components with the information required in the subsections that
follow:
a) Facility Design Plan;
b) Safety Plan;
c) Operations Plan;
d) Environmental Plan;
e) Noise Abatement Plan;
f) Professional Evaluation;
g) Certification; and,
h) A list of all property owners prepared by a title company within the distance of the safety
fan, but no less than one mile.
2) Facility Design Plan.
a) The Facility Design Plan for all indoor and outdoor commercial shooting facilities shall
contain the following elements:
Locations and dimensions of all walkways;
ii. Locations of all hazardous material storage and use, per a hazardous substance or
hazardous waste management plan, if needed; and,
iii. The component parts for each shooting range.
b) The Facility Design Plan for all outdoor commercial shooting facilities:
Locations and dimensions of firing lines or firing points, target lines and impact
areas including all related buildings;
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ii. Locations, dimensions and slope of all backstops and side berms, whether natural
feature or manmade and the volume, source, and type of all materials of which they
are comprised;
iii. Locations and specifications of all baffles and containment structures;
iv. Location of all security measures specified in JCC 8.50.250(1);
V. The safety fan for each shooting range proposed;
vi. Approximate location of buildings on adjoining property;
vii. Approximate location of any stream, river, lake, or other body ofwater within 500
yards of the commercial shooting facility.
viii. Dimensional drawings of physical layout for each of the items listed in this
subsection, drawn at an engineering scale appropriate for the drawings;
ix. Horizontal drawings of the baffles and containment structures, and a description of
the materials to be used for them;
X. For rifle and pistol shooting ranges:
A. Longitudinal cross-sections, with elevations, of that portion of each shooting
range from 10 feet behind each firing line to 10 feet beyond the downrange
terminus of each direct fire zone, 10 feet beyond the back toe of each backstop
if manmade, or if natural, 20 feet beyond the front edge of the backstop, as
applicable; and,
B. Latitudinal cross-sections, from 10 feet outside all side berms or the edge of
each safety fan, of typical areas between each firing line and backstop or
downrange terminus of the direct fire zone.
xi. For five -stand shooting, skeet shooting, sport clay shooting and trap shooting
ranges, the location and dimension of the shot fall zones and component parts; and,
xii. Elevations of all shooting ranges showing target area, backstops and berms.
3) Safety Plan. The Safety Plan shall contain at least the following elements:
a) Sign -in procedures, rules and regulations, and protocols for the use of shooting ranges;
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b) An emergency plan, to include provision for immediate notification to 911 of any life
safety incident and on the next business day to the department;
c) Methods for documenting the accidental or unintended release of a bullet anywhere at or
from the commercial shooting facility, which documentation shall be transmitted to the
department within 7 days of the release;
d) Provisions for the safe loading and unloading of firearms;
e) A requirement that range masters and range officers shall complete the necessary training
and obtain certification to be a range master or range officer;
f) A requirement that at least one range master or range officer be present when shooting is
occurring whenever the commercial shooting facility is open to the public;
g) A requirement that when the commercial shooting facility is closed to the public, a
commercial shooting facility member who has passed the minimum training requirements
of the range shall be present;
h) Provision for specific safety requirements for all cowboy action shooting, practical
shooting, and similar sports shooting matches at any shooting range;
i) Rules and regulations for changing the use of shooting ranges from cold ranges to hot
ranges or vice versa;
0) A means for participants and spectators to readily contact emergency services such as fare
or emergency medical services; and,
k) Provision for emergency services access by vehicle or air transport.
1) A requirement prohibiting the use of alcohol, Cannabis or other drugs at the commercial
shooting facility when it is open to the public or shooting is occurring.
m)A requirement that drones may not be flown by anyone on the commercial shooting
facility when open to the public or while shooting is being conducted.
n) A requirement that no shooting take place after dark, except for law enforcement officers
or members of the armed forces provided such shooting after dark for law enforcement
officers or members of the armed forces does not occur after 10 p.m., shooting does not
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exceed four hours, and the maximum days shooting after dark is allowed does not exceed
one day per week.
4) Operations Plan. The Operations Plan shall contain at least the following elements:
a) The days of the week and the hours of operations;
b) Whether the commercial shooting facility will be open to the public, open only to private
membership, open to organizational training for law enforcement officers, open to
organizational training for members ofthe armed forces, or any combination of these;
c) A description of any activities that would not be overseen by the owner or operator and
how the owner or operator will obtain compliance with the operating permit for these
activities.
d) The types and largest caliber of firearms and ammunition to be allowed on each shooting
range;
e) Type of shooting proposed on each shooting range;
f) Whether exploding targets are to be used. If so, a plan for mitigation of noise impacts on
neighbors;
g) A requirement that the owner or operator maintain comprehensive general liability
insurance coverage, with a minimum coverage amount of one million dollars for each
occurrence and combined single limit and two million in the aggregate during operation
of the commercial shooting facility;
h) A requirement that certificates of insurance for all policies that provide insurance
coverage for the commercial shooting facility be provided to the department evidencing
continuous insurance coverage required by the Operations Plan within fifteen (15) days
of approval of the Operations Permit that include:
i. The limits of coverage;
ii. The names and addresses of all certificate holders; and,
iii. A statement that the insurance policy shall not be canceled or allowed to expire
except on thirty (30) days prior written notice to the department.
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i) A requirement that the department be notified of any change in the insurance required by
the Operations Plan.
5) Environmental Plan. Each commercial shooting facility operator shall develop and submit an
environmental plan with the following minimum requirements:
a) BMPs for the collection and disposal of bullets, cartridges, and shotgun wadding.
b) At indoor facilities, BMPs for lead as recommended by the National Institute for
Occupational Safety and Health (NIOSH) in its 2009 publication entitled NIOSH Alert —
Preventing Exposures to Lead and Noise at Indoor Firing Ranges, as it exists now or later
is amended.
c) At outdoor facilities, BMPs for lead as recommended by USEPA Region 2 in its 2005
publication entitled Best Management Practices for Outdoor Shooting Ranges, as it exists
now or later is amended.
d) If, other than lead, any hazardous substance or hazardous waste will be stored at the
commercial shooting facility, the Environmental Plan shall also include:
i. A plan for compliance with requirements under existing law for the handling and
closure of facilities for storage or use of the hazardous substance or hazardous waste;
and,
ii. A plan for financial assurance consistent with existing law for addressing any
remediation of hazardous substances or hazardous waste.
e) For the avoidance of doubt, this article neither seeks to set nor does set any substantive
environmental standards, including but not limited to standards for any hazardous
substance or hazardous waste, including but not limited to lead.
6) Noise Abatement Plan. Each commercial shooting facility operator shall develop and submit
a noise abatement plan. The minimum requirements for a noise abatement plan are:
a) Identify potential noise issues and potential solutions to those issues;
b) Describe sound abatement methodologies and technologies proposed for the facility;
c) Provide a description of how the noise abatement program will be integrated into yearly
planning; and,
d) Contain BMPs to minimize noise nuisance consistent with the NRA Source Book and
Chapter 8.70 JCC (noise control).
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7) Professional Evaluation.
a) The Professional Evaluation shall be the responsibility of the county under the direction
of the director and shall be performed by a qualified shooting range evaluator.
b) If requested, the applicant shall allow for an inspection of the site of the new or
established commercial shooting facility by the qualified shooting range evaluator.
c) The Professional Evaluation shall contain an evaluation of the operating permit
application that shall be performed by a qualified shooting range evaluator (as defined
above) that meets the following minimum requirements:
The evaluation shall discuss any safety issues not addressed by the operating
permit application;
ii. The evaluation shall discuss any proposed uses that are inconsistent with the NRA
Range Source Book for facility designs and institutional controls;
iii. The evaluation shall include the commercial shooting facility's uses and
institutional controls described in the application for an operating permit;
iv. The evaluation shall be in written form and signed by the qualified shooting range
evaluator;
V. For new commercial shooting facilities, the evaluation shall certify that the
operating permit application satisfies all the requirements of this article.
vi. For established commercial shooting facilities, the evaluation shall classify the
ways in which the facility is currently non-compliant with this article according to
the following priorities:
A. Life safety issues or critical area deficiencies that must be remedied prior to
issuance of an operating permit;
B. Facility design components that do not meet the safety objectives of this
article; and,
C. Facility design components that do not mitigate detrimental effects of the
facility on critical areas.
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d) The applicant shall reimburse the county for the actual costs incurred (including
consultant work) of the evaluation. No operating permit shall be issued until
reimbursement to the county is made.
e) The applicant may challenge the evaluation by appealing the professional evaluation to
the hearing examiner pursuant to JCC 8.50.260.
8) Certification.
a) Every application for an operating permit for a new commercial shooting facility shall be
accompanied by a notarized certification by the operator that specifies the commercial
shooting facility:
i. Complies with this article;
ii. Meets commonly accepted shooting facility safety and design practices; and,
iii. Shall be operated in a manner that protects the safety of all persons present at the
commercial shooting facility and persons on neighboring properties.
b) Every application for an operating permit for an established commercial shooting facility
shall be accompanied by a notarized certification by the operator that specifies the
following:
i. The operator will abide by the improvement plan agreed upon as a condition ofthe
issuance of the operating permit;
ii. Areas of non-compliance at the commercial shooting facility will not increase over
time;
iii. That as much as possible the facility meets commonly accepted shooting facility
safety and design practices; and,
iv. That the facility shall be operated in a manner that protects the safety of all persons
present at the commercial shooting facility and persons on neighboring properties.
9) Notice and Comment.
a) The director shall issue a notice of application for on all commercial shooting facilities.
b) The notice of application shall include the following:
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i. The name and address of the applicant or the applicant's representative;
ii. The date of application, the date of the notice of completion for the application, and
the date of the notice of application;
iii. The street address location of the project or, if unavailable, a description of the
subject property reasonably sufficient to inform the public of its location, which may
include a vicinity location (map), the location in reference to roadway intersections,
or a written description (rural route box or subdivision lot and block alone are not
sufficient);
iv. The identification of state, federal or other permits required by other agencies with
jurisdiction not included in the application, to the extent known by the county;
V. The name and phone number of the person at the department evaluating the
application;
vi. A statement of the limits of the public comment period, which shall be 30 calendar
days following the date of the notice of application;
vii. Statements of the right of any person to comment on the application, receive notice of
and participate in any hearings, request a copy of the decision once made, and any
appeal rights;
viii. A statement of the preliminary determination, if one has been made at the time of the
notice of application, of the proposed commercial shooting facility's consistency with
this article;
ix. The date, time, place of hearing, if applicable, and if scheduled prior to the date of
the notice of application;
X. A statement of when and where a copy ofthe application, all supporting
documentation and evidence relied upon by the applicant, and applicable
development regulations may be available for public inspection;
xi. A statement that a copy of any staff report will be available for inspection at no cost
to the public at least 7 calendar days prior to any public hearing (if applicable); and,
xii. Any other information the administrator determines appropriate.
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c) The director shall issue the notice within 14 calendar days of receipt of an application for
a commercial shooting facility.
d) The notice of application shall be sent by mail to the applicant and to all property owners
identified in JCC 8.50.240(h).
e) The notice of application shall also be published in the official county newspaper at least
once. Published notice shall include the proposed commercial shooting facility's road or
street address or location, type(s) of permit(s) all applied for concerning the commercial
shooting facility, comment period dates, and location where the complete application and
notice of application may be reviewed.
f) The department shall be responsible for preparation of the list of all property owners
identified in JCC 8.50.240(h); provided, that the director retains the authority to require
the applicant to supply and certify the list of all property owners identified in JCC
8.50.240(h) in circumstances where the information is not readily available to the county.
The department shall obtain addresses for mailed notice from the county's geographic
information system (GIS) or real property tax records. The director shall make a notation
in the file affirming mailing of notice to all persons entitled to notice under this article.
g) All public notices shall be deemed to have been provided or received on the date the
notice is deposited in the mail or personally delivered, whichever occurs first.
h) Failure to send notice by mail shall not invalidate such proceedings where the owner
appears at the hearing or receives actual notice.
i) As optional methods of providing public notice of any operating permits, the county may:
i. Notify the public or private groups with known interest in a certain proposal or in the
type of proposal being considered;
ii. Notify the news media;
iii. Place notices in appropriate regional or neighborhood newspapers or trade journals;
iv. Place public notice in agency newsletters or send notice to agency mailing lists, either
general lists or lists for specific proposals or subject areas;
V. Mail to neighboring property owners; or,
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vi. Place notices on the Internet.
0) The county's failure to provide the optional notice as described above shall not be
grounds for invalidation of any operating permit decision.
k) The comment period shall be 30 calendar days from the date of the published notice of
application.
1) Comments may be mailed, personally delivered or sent by facsimile.
m)Comments shall be as specific as possible.
n) The director will receive public comments during regular business hours any time up to
and during the open record hearing, if any, or if there is no pre -decision hearing, prior to
the decision on the operating permit.
o) The county may not issue a decision or recommendation on the operating permit until the
expiration of the public comment period on the notice of application.
p) The applicant shall reimburse the county for the actual costs incurred for providing
notice. No operating permit shall be issued until reimbursement to the county is made.
8.50.250 Minimum Standards.
1) Required Security. Commercial shooting facilities shall provide security measures to deter
unauthorized entry to any shooting range, such as barriers, berms, cameras, gates, fencing, on-
site security personnel, physical limits, or signage.
2) Containment. Commercial shooting facilities shall be designed and operated so that when
firearms are operating in accordance with the rules and regulations (as defined above) all
projectiles are kept from leaving any shooting range or the commercial shooting facility.
3) Critical Areas. Commercial shooting facilities shall be designed and operated to prevent
adverse public health or environmental impacts to critical areas.
8.50.260 Administrative Remedy for Decisions Made by the Director.
When a decision is made by the director pursuant to the provisions of this article, an applicant or
any aggrieved party may appeal the decision to the hearing examiner pursuant to the procedures
in JCC 18.05.080 and JCC 18.05.085 by providing written notice of appeal to the director within
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14 calendar days of the decision. The fee for such appeal shall be as set forth in the Jefferson
County fee ordinance and must be paid by the appellant at the time of filing the notice of appeal.
8.50.270 Judicial Appeals.
1) Time to File Judicial Appeal. Within 21 calendar days of the date the decision or action
becomes final, the applicant or any aggrieved party may appeal the final decision of the
director or the hearing examiner to a court ofcompetent jurisdiction in a manner consistent
with state law.
2) All appellants and aggrieved persons must timely exhaust all administrative remedies prior to
filing a judicial appeal.
3) Service of Appeal. Notice of appeal and any other pleadings required to be filed with the
court shall be served by delivery to the county auditor (see RCW 4.28.080), and all persons
identified in JCC 8.50.240(1)(h), within the applicable time period. This requirement is
jurisdictional.
4) Cost of Appeal. The person who filed the notice of appeal shall be responsible for the cost of
transcribing and preparing all records ordered certified by a court or desired by the person
who filed the notice of appeal. Prior to the preparation of any records, the person who filed
the notice of appeal shall post with the county auditor an advance fee deposit in an amount
specified by the county auditor. Any overage will be promptly returned.
8.50.280 Safe Harbor for Owners and Operators.
Full compliance with an operating permit creates a rebuttable presumption that the commercial
shooting facility is not being operated as a nuisance. For the avoidance of doubt, the burden of
proving full compliance is on the owner or operator.
8.50.290 Reports of Violations of this Article.
1) Creation of a Form. The director, in consultation with the sheriff, shall develop a form for
receipt of reports of violations of this article.
2) Provided to the Owner or Operator. All reports of violation shall be provided to the owner or
operator of the commercial shooting facility as soon as possible, but no later than two
business days from the receipt of the report of violation.
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3) Maintenance of Reports. The director shall maintain a copy of all reports of violation for at
least two years following receipt of a report of violation.
4) Discussion During Annual Inspection. During the annual inspection, all reports of violation
shall be addressed by the department and the owner or operator of a commercial shooting
facility.
5) Response to Reports of Violation.
a) Name of Informant. All reports of violation shall be encouraged to include the name of
an informant with current contact information for use in the investigation.
b) Expedited Response. The sheriff shall respond to reports of life safety incidents or
threatened harm that violate this article as soon as practical, considering the nature ofthe
report of violation and the other operational demands on the sheriff at the time the report
of violation is received.
c) Routine Response. Other reports of violation shall be evaluated by the department for
investigation. In consultation with the sheriff, the department shall develop a procedure
for addressing other reports of violation.
d) Noise Only Response. When the report of violation is limited to a claim of noise
nuisance, the report of violation shall be addressed by the sheriff under Chapter 8.70 JCC
Noise Control).
8.50.300 Review Committee.
The county board of commissioners may require the director to establish a review committee to
evaluate proposed revisions to this article. The review committee shall consist of. (a) the director
of the department of community development or the director's designee (chair); (b) Jefferson
County Sheriff or the Sheriff's designee; (c) Jefferson County Director of Environmental Health
or the director's designee; (c) a representative of each current commercial shooting facility in
unincorporated Jefferson County; (d) a resident or property owner from each of the three districts
of Jefferson County; (e) one representative of tribal interests, if interested; and (f) one at large
Jefferson County resident or property owner appointed by the county board of commissioners.
The Jefferson County Prosecuting Attorney (or designee) shall be an ex officio member of the
review committee but shall not be required to attend every meeting of the review committee. All
Review Committee meetings shall be subject to the requirements of the Open Public Meetings
Act, Chapter 42.30 RCW.
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8.50.310 Conflicts with JCC 18.20.350(8) and Limitations on the Applicability of this Article.
1) If any provision of this article conflicts with JCC 18.20.350(8), the provisions of this article
shall prevail.
2) Nothing in article shall be construed as:
a) Authorizing an application or a permit for a commercial shooting facility to be located in
whole or in part in an area designated as an area where the discharge of firearms is
prohibited under Chapter 8.50 JCC. Shooting ranges in such areas are expressly prohibited.
b) Permitting the discharge of firearms, the ownership or possession of which is otherwise
prohibited by law.
c) Permitting the use or possession of a firearm by an individual who is otherwise prohibited
by law from owning or possessing that firearm.
d) Allowing or authorizing the discharge of firearms otherwise prohibited by state or federal
law.
e) Allowing or authorizing the discharge of tracer or incendiary ammunition.
f) Allowing or authorizing the discharge of a destructive device as that term is defined in 25
U.S.C. Section 5845(8 or any explosive as that term is defined in RCW 70.74.010(5).
g) Allowing or authorizing the discharge of a machine gun as that term is defined in 26 U.S.C.
Section 5845(b) or RCW 9.41.010(17), unless specifically authorized under RCW
9.41.190(3).
h) Allowing or authorizing the discharge of a short -barreled rifle or a short -barreled shotgun
as those terms are defined in RCW 9.41.010, unless specifically authorized under RCW
9.41.190(3).
i) Permitting a commercial shooting facility to maintain or create a public nuisance as defined
in Chapter 7.48 RCW, JCC 5.10.050, JCC 8.20.140, JCC 8.30.020, JCC 8.55.070, Chapter
8.70 JCC, JCC 15.05.100, or Title 18 JCC.
j) Abridging or altering the rights of action by the state, by the county or by persons, which
exist in equity, common law, or other statutes to abate pollution or to abate a nuisance.
k) Limiting a court of competent jurisdiction from:
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i. Ruling that a commercial shooting facility is a public nuisance; or,
ii. Requiring additional noise, environmental or safety controls as a condition of continued
operation of a commercial shooting facility.
1) Nullifying or rendering void the terms of any existing or future injunctive order issued by
a court of competent jurisdiction pertaining to operations or activities at a shooting range
or commercial shooting facility.
8.50.320 Warning and Disclaimer of Liability.
The degree of protection required by this article for commercial shooting facilities is reasonable
for regulatory purposes and is based on available information. This article does not imply that
commercial shooting facilities will be free from risk of bodily injury or property damage, even if
operated consistently with an operating permit. This article does not create liability on the part of
the county or any officer or employee of the county for any bodily injury or property damage that
results from reliance on this article, or any administrative decision made lawfully under this article,
including but not limited to the decision to approve the application for an operating permit. By
regulating commercial shooting facilities, the county is attempting to address obvious safety and
environmental issues at commercial shooting facilities. Neither this article nor an operating permit
issued pursuant to this article may be relied upon as a determination that operation of a commercial
shooting facility consistent with an operating permit renders the commercial shooting facility free
from the risk of bodily injury or property damage.
41 of 41
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 6
Exhibit 6
Ordinance No. 15-1214-18 adopted December 14, 2018 (Title 18 Land Use Ordinance)
0- 1. -D C-
C
Cede COUNTY OF JEFFERSON
STATE OF WASHINGTON
An Ordinance Harmonizing Title 18 JCC }
with the Commercial Shooting Facilities } ORDINANCE NO. 15-1214-18
Ordinance No. 12-1102-18 }
WHEREAS, on December 18, 2017, the Board of County Commissioners (BoCC)
adopted Ordinance No. 05-1218-17, an Ordinance Establishing a Moratorium on Commercial
Shooting Facilities in Unincorporated Areas of Jefferson County (the Moratorium); and,
WHEREAS, in the Moratorium Ordinance, the BoCC established a review committee
Review Committee) to advise the County as the County developed a draft ordinance for the
permitting, development and operation of commercial shooting facilities that: (1) provides for and
promotes safety by establishing a permitting procedure and rules for the siting, design and
operation of commercial shooting range facilities that safeguards participants, spectators,
neighboring properties and the public; (2) does not prohibit or expressly regulate the discharge of
firearms; (3) involves measures designed to make the discharge of firearms safe; (4) protects the
environment; (5) ensures compatibility with neighboring land use; and, (6) promotes the continued
availability of shooting facilities for firearm education, practice in the safe use of firearms, and
recreational firearm sports; and,
WHEREAS, the Review Committee included persons with diverse viewpoints about
regulation of shooting ranges in the County; and,
WHEREAS, the Review Committee sometimes engaged in spirited discussions, but the
discussions were always respectful of opposing viewpoints, even when there were areas of
disagreement; and,
WHEREAS, every person on the Review Committee participated actively and provided
invaluable input to the development of the draft ordinance;
WHEREAS, the Review Committee diligently followed the direction from the BoCC in
Section 6.6 of the Moratorium Ordinance that it shall: (a) study the safety, environmental and land
use impacts of commercial shooting facilities and reasonable measures to address those impacts,
including among other measures whether there should be an amendment to the No Shooting Areas
Ordinance, Chapter 8.50 JCC to allow indoor commercial shooting facilities in No Shooting Areas;
and, (b) shall provide input to the County as the County generates and recommends a draft
ordinance; and,
WHEREAS, the Review Committee met fifteen times in open public meetings, usually for
3 or more hours, in the BoCC's Chambers on May 9, 2018, May 16, 2018, May 23, 2018, June 6,
2018, June 13, 2018, June 20, 2018, June 28, 2018, July 11, 2018, July 19, 2018, July 25, 2018,
August 1, 2018, August 8, 2018, August 15, 2018, August 17, 2018 and August 23, 2018. and all
the meetings of the Review Committee can be viewed on the County's AVCapture All system;
and,
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WHEREAS, the Review Committee's work satisfied well the BoCC's finding in the
Moratorium Ordinance that "resident and property owner input and careful analysis of the uniform
requirements for commercial shooting facilities should be obtained before legislation imposing
uniform requirements on commercial shooting facilities can be adopted by the BoCC;"
WHEREAS, on August 23, 2018, staff forwarded a staff report, including a draft
commercial shooting facility ordinance, recommending to the BoCC that proposed to amend Title
8 JCC, the Health and Safety Code that would add a new Article III, Chapter 8.50 JCC;
WHEREAS, staff recommended changes to Title 18 JCC in order to harmonize Title 18
JCC with the new draft Article III, Chapter 8.50 JCC; and,
WHEREAS, the Planning Commission has held a hearing and has received public
comment on the draft ordinance proposed by staff that would revise Title 18 JCC in light of the
new Article III, Chapter 8.50 JCC; and,
WHEREAS, on November 2, 2018 the Board of County Commissioners adopted
Ordinance 12-1102-18, amending Title 8 JCC, the Health and Safety Code, adding a new Article
III to Chapter 8.50 JCC; and,
WHEREAS, the Planning Commission has forwarded its recommendations to the BoCC
regarding the draft ordinance proposed by staff that would revise Title 18 JCC in light of the new
Article III, Chapter 8.50 JCC; and,
WHEREAS, following the Planning Commission's consideration of the draft ordinance
recommended by the Planning Commission that would revise Title 18 JCC in light of the new
Article III, Chapter 8.50 JCC, the BoCC has held a hearing and has received public comment on
the draft ordinance recommended by the Planning Commission that would revise to Title 18 JCC
in light of the new Article III, Chapter 8.50 JCC; and,
WHEREAS, in response to the public comment and testimony, additional improvements
to the proposed ordinance recommended by the Planning Commission that would revise Title 18
JCC in light of with the new Article III, Chapter 8.50 JCC have been made; and,
NOW, THEREFORE, be it ordained that:
Section 1. Modification of Title 18 JCC. Title 18 JCC shall be modified as set forth in Appendix
A.
Section 2. Findings. The BoCC hereby adopts the above recitals (the "WHEREAS" statements)
as its findings of fact in support of this Ordinance.
Section 3. Severability. The provisions of this Ordinance are declared separate and severable. If
any provision of this Ordinance or its application to any person or circumstances is held invalid,
then the remainder of this Ordinance or application of its provisions to other persons or
circumstances shall remain valid and unaffected.
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Section 4. Repeal and Amend. The changes authorized above are to repeal JCC 18.20.350(8) and
amend other relevant provisions in Title 18 JCC. However, legal nonconforming uses established
prior to the adoption of this Ordinance shall continue to be bound by the requirements in JCC
18.20.350(8) as it existed prior to the effective date of this ordinance.
Section 5. SEPA Compliance. The Jefferson County Department of Community Development
prepared an environmental checklist detailing the proposed ordinance and its potential impacts for
compliance with the State Environmental Policy Act (SEPA). After review of the environmental
checklist, proposal, available information, and applicable regulations, Jefferson County's SEPA
Responsible Official issued a Determination of Non -Significance (DNS) on October 31, 2018
under WAC 197-11-340(2). The DNS was published on October 31, 2018 in the PT Leader and
was sent to affected government agencies, tribal governments, and other parties. Jefferson County
had a SEPA comment period from October 24 until November 16, 2018. The comment period
was originally published in the PT Leader on October 24, 2018. After a review of the public and
agency comments received during the comment period, the SEPA Responsible Official retained
the DNS. Jefferson County submitted the proposed UDC amendments to the Washington State
Department of Commerce for review, as required by the Growth Management Act. On November
8, 2018 the Washington State Department of Commerce concluded its review under its expedited
review authority.
Section 6. Effective Date. This ordinance is effective immediately upon adoption.
ADOPTED this 14 day of D o g Rm b e r 2018, at 4: 2 9 p.m.
64An
Carolynkiallaway,
Deputy Clerk of the Board
3 of 9
JEFFERSON COUNTY
BOARD O OUN Y COMMISSIONERS
David ullivan, Chair
lVe
Kathleen Kler, Member
Voted Against)
Kate Dean, Member
APPROVED AZ72Z//,//& M:
0", 0,
Philip C. Hunsucker, Date
Chief Civil Deputy Prosecuting Attorney
APPENDIX A
ADDITIONS OR DELETIONS TO DEFINITIONS:
18.10.030 C definitions.
Commercial shootin fgacility" has the same meaning as in JCC 8.50.220(15).
18.10.060 F definitions.
Firearm" has the same meaning as in JCC 8.50.040.
18.10.090 I definitions.
Indoor commercial shootin facility" acility" means has the same meaning as "indoor facility" in JCC
8.50.220(34).
18.10.130 M definitions.
Minimal impacts" means impacts that do not cause adverse impacts on the human or natural
environments that cannot be mitigated by conditions of approval.
Minimal demands on existing infrastructure" means demands that do not cause the need for
additional infrastructure, including but not limited to roads, fire protection, water, wastewater
disposal or stormwater control that is not provided b t pplicant.
18.10.140 N definitions.
NRA Range Source Book" has the same meaning as in JCC 8.50.220(39).
18.10.150 O definitions.
Outdoor shooting_ facility means any use that includes a shooting range whether or not it is an
outdoor commercial shooting facility. However, outdoor shootingf acility does not include
shooting ranges that meet the exceptions for a commercial shootingfacility in JCC
8.50.220(.15)(a) or (b).
Outdoor commercial shooting facility" has the same meaning as outdoor facility in JCC
8.50.220(45).
18.10.160 P definitions.
Projectile" has the same meaning as in JCC 8.50.220(50).
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18.10.180 R definitions.
Recreational uses" means those activities of a voluntM and leisure time nature that aid in
promoting entertainment, pleasure, play, relaxation, or instruction.
18.10.190 S definitions.
Shooting range" means a ftwility speeifieally desiened-md used for- safe sheetine i3r-aetiee VVM
fir-ea..ms and/or- f ar-e o .,etiee ;+1 individual or -fir -i positions o-r Peeife
has the same meaning as in JCC 8.50.220(61).
Small-scale recreation or tourist uses" means recreational uses or tourist uses that are reliant
upon a rural setting or location; do not include any new residential development beyond that
allowed in the underlying land use district; and otherwise meet the performance standards in JCC
18.20.350.
8.10.200 T definitions.
Tourist uses" means used by persons traveling for pleasure or culture.
CHANGES TO JCC 18.20.170(4):
JCC 18.20.170(4) Standards for Cottage Industries
4) All cottage industries shall be subject to the following standards, except as provided for in the
West End Planning Area and Brinnon Planning Area — Remote Rural overlay districts as
specified in Article VI -L of Chapter 18.15 JCC, Remote Rural Overlay Districts for the West
End Planning Area and the Brinnon Planning Area.
a) The cottage industry shall be operated by at least one full-time, bona fide resident in a single-
family residence of the parcel on which the proposed use is being requested.
b) The cottage industry may not employ more than four employees on the site who reside off the
subject property. Auto and truck repair shall only employ two persons on the site who reside off
the subject property.
c) Only those buildings or areas as specifically approved by the county may be utilized in the
conduct of business.
d) Any business requiring customers to visit the site shall provide adequate on-site parking
spaces, in addition to one for each full-time equivalent employee who resides off the subject
property, and two for the owners of the property. All parking spaces shall meet the standards of
JCC 18.30.100.
e) All structures and outside activities shall be so located or screened from adjacent properties to
avoid disturbances through glare, noise, dirt or other nuisances or hazards.
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f) All activity related to the conduct of the business or industry, except for activities related to
the growing and storing of plants, shall be conducted within an enclosed structure or be
sufficiently screened from view of adjacent residences.
g) All cottage industry activities shall be sufficiently screened from view of adjacent residences,
using site location, topography, landscaping, fencing, the retention of native vegetation, or a
combination thereof necessary to meet the Type A screening requirements of JCC 18.30.130.
h) Traffic generated by the cottage industry shall not exceed the level of service adopted for the
public roadway which accesses the use, nor generate significant traffic in excess of that normally
generated by typical uses found within the particular district.
i) No business may provide drive-through service.
0) Cottage industries shall be limited in their hours of operation. No business on-site customer
service shall be conducted before 8:00 a.m. or after 8:00 p.m., Monday through Friday, and
before 9:00 a.m. or after 6:00 p.m., Saturday and Sunday.
k) The administrator may attach additional conditions or requirements, or may make
modifications to the site plan where necessary to protect the health, safety and welfare of the
public.
1) The granting of the proposed cottage industry use shall not constitute a rezone. No expansions
of approved cottage industries are permitted, except as specified in Article VI -L of
Chapter 18.15 JCC, Remote Rural Overlay Districts for the West End Planning Area and the
Brinnon Planning Area, concerning the rural remote overlay districts.
m) No exterior display of goods for sale shall be allowed.
n) The cottage enterprise is an accessory use to the residential use of a dwelling unit, and the
residential function of the buildings and property shall be maintained.
o) Any new structure constructed to accommodate the cottage industry shall be limited in scale
so that it is in character with neighboring properties. In no case shall more than 5,000 square feet
of total building area on the property be devoted to the cottage industry.
p) No more than one sign is allowed, consistent with the sign standards in JCC 18.30.150.
q) No on-site direct retail sales of products not produced on-site are allowed, except for items
collected, traded and occasionally sold by hobbyists, such as coins, stamps and antiques, and
their accessories.
r) Minimum parcel size shall be one acre gross site area.
s) No use shall be made of equipment or material which produces unreasonable vibration, noise,
dust, smoke, odor, or electrical interference to the detriment of the quiet use and enjoyment of
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adjoining and surrounding property. Any after-hours business activities shall not have noise
impacts discernible beyond the property boundaries.
t) Not more than one cottage industry shall be allowed in or on the same premises.
u) The proposed cottage industry shall comply with the standards and requirements of the
Jefferson County environmental health department.
v) Where shooting firearms is associated with a cottage industry at a property, such property
shall be considered a commercial shooting facility.
CHANGES TO JCC 18.20.200(2):
JCC 18.20.200(2) on Permitted Home Businesses
2) Permitted home businesses do not include the following:
a) Veterinary clinic or hospital:;
d) Uses which are associated with shooting firearms.
REPEAL OF JCC 18.20.350(8):
JCC 18.20.350(8) on Outdoor Shooting Ranges—REPEALED
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ori
eers?*e rrrrs!MM OM!er.1
uraywffn
CHANGES TO THE USE TABLE:
Table 3-1. Allowable and Prohibited Uses shall be modified to be consistent with the following:
8 of 9
Resource Lands Other Zones Types
Forest — Other Zones Where Only Other Zones Where
Agricultural Commercial, Indoor Commercial No Shooting Facility
Prime and Rural Shooting Facility Allowed Allowed
Local and
Inholdin
Specific Land AG CF/RF/IF Convenience Crossroad Rural Residential —1
Use CC), General Crossroad DU/5 Acres (RR 1:5),
GC), Heavy Industrial Rural Residential —1
HI), Industrial, Light DU/10 Acres (RR
Industrial/Commercial 1:10), Rural
LI/C), Light Industrial Residential —1 DU/20
LI), Light Acres (RR 1:20),
Industrial/Manufacturing
LI/M), Irondale and
Port Hadlock Urban
Growth Area (UGA),
Neighborhood/Visitor
Crossroads (NC), Parks,
Preserves and Recreation
PRR), Rural Village
Center (RVC), Resource -
Based Industrial RI
8 of 9
Indoor No C C No
commercial
shooting facilit
Outdoor No C No No
shootiniz
facilit
9 of 9
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 7
Exhibit 7
SEPA Determination of Non-Significance (DNS) for the Title 18 Ordinance
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 8
Exhibit 8
Small-Scale Recreation or Tourist Uses Regulations
Jefferson County Code 18.20.350(1)-(3)
Small-Scale Recreation or Tourist Uses are limited by Jefferson County Code 18.20.350(3) as follows:
(1) Small-Scale Recreation and Tourist Uses. Small-scale recreational and tourist uses rely on a
rural location and setting and provide opportunities to diversify the economy of rural Jefferson County
by utilizing the county’s abundant recreational opportunities and scenic and natural amenities in an
environmentally sensitive manner consistent with the rural character of the county. Upon approval
pursuant to this code, these types of uses may be conducted in the land use districts specified in
Table 3-1 in JCC 18.15.040 and as provided for in small-scale recreation and tourist (SRT) overlay
districts under JCC 18.15.470 and 18.15.572. Agritourism on designated agricultural lands is
regulated in JCC 18.20.030, agricultural activities and accessory uses. The following list of uses is
not intended to be exhaustive, but rather is intended to be illustrative of the types of small-scale
recreation or tourist uses:
(a) Small-scale recreation or tourist uses may include limited and commensurately scaled commercial
facilities intended to serve those small-scale recreational or tourist uses (e.g., a gift shop, delicatessen,
convenience store, or associated retail sales and services); provided, that the applicant can demonstrate
the following to the satisfaction of the approving authority that:
(i) The principal demand for the commercial facilities is derived from the principal recreational or
tourist use and not the existing and projected rural population;
(ii) The associated commercial activities shall be clearly accessory to and dependent upon the
primary recreational or tourist uses;
(iii) The associated commercial activities, in addition to the principal recreational or tourist use, will
not have a measurable detrimental traffic, noise, visual or public safety impact on adjacent properties;
(iv) The use and associated structure is clearly appropriate and compatible in scale, size, design,
and function with surrounding uses and environment;
(v) The use will not constitute new urban development in a rural area;
(vi) The public facilities and services provided are limited to those necessary to serve the associated
commercial activities and the principal small-scale recreational or tourist use in a manner that does
not permit low-density sprawl; and
(vii) All other applicable requirements and standards in this UDC are met.
(b) Unless a larger parcel size is specified, minimum lot size shall be five acres, except that no minimum
lot size is required for parcels that include a historic site, structure or landmark.
(c) Only one small-scale recreational or tourist use shall be allowed per legal lot of record, with the
exception of rural restaurants.
(d) Only those buildings or areas specifically approved by the county may be used in the conduct of the
business.
(e) Parking shall be contained on-site and provided in conformance with this code, including JCC
18.30.100 and 18.30.130.
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 8
(f) All activities shall, at a minimum, be screened from the view of adjacent residential uses subject to
the landscaping and screening requirements of JCC 18.30.130 and set back a sufficient distance from
all rear and side property lines to protect the character of adjacent and surrounding properties and uses.
The approving authority may authorize variations to the setbacks established in Table 6-1 in JCC
18.30.050 in order to ensure that any small-scale recreation or tourist use or structure, when proposed
in or adjacent to a rural residential (RR) district, shall be compatible with and not disruptive to the
character of existing and anticipated future uses in the district.
(g) All small-scale recreation or tourist uses shall utilize local access or minor collector roads for primary
access whenever practicable. Access off of state routes, arterials, or major collector roads may be
allowed if access improvements or a traffic analysis assures mobility is not degraded.
(h) Structures shall comply with the landscape, lighting, site coverage, and design standards set forth in
Chapter 18.30 JCC.
(i) Any small-scale recreational or tourist use development allowed under this section that proposes to
include permanent occupancy on-site residential development may only be permitted subject to:
(i) The underlying rural residential density;
(ii) A master planned resort (MPR) district designation subject to a legislative action to amend the
Comprehensive Plan; or
(iii) That necessary for on-site management (e.g., a caretaker’s residence).
(j) For any small-scale recreation or tourist use, the county shall impose such reasonable conditions
(e.g., location and size restrictions, design standards, landscape buffers, setbacks, etc.) as are found
necessary by the approving authority to ensure that the activity or use, due to proximity, location or
intensity:
(i) Is compatible with the rural character of adjacent lands and shorelines, including forestry, agriculture,
and mineral lands of long-term commercial significance;
(ii) Does not disrupt the character of any surrounding permitted uses;
(iii) Is adequately served by public facilities and services (including roadway level of service and
minimum fire flow requirements) without the need to extend those services in a manner that promotes
low density sprawl;
(iv) Adequately protects critical areas including surface and groundwater resources; and
(v) Would not cumulatively, in combination with the effects of existing development (or given the
probable development of subsequent projects with similar effects) in the vicinity (i.e., within one mile)
of the proposed use, create a development pattern that constitutes low density sprawl; require the
extension of public facilities or expansion of public services in a manner that promotes low density
sprawl; or be otherwise incompatible with or injurious to the rural character of the area;
(vi) For designated agricultural lands, converts as little land with prime agricultural soils as practicable
into nonagricultural use.
(2) If the preceding conditions (in subsection (3)(j) of this section) cannot be met to the satisfaction
of the approving authority, the use shall be denied.
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 8
(3) A small-scale recreation or tourist use shall meet the requirements of this code (except as
provided for in SRT overlay districts per JCC 18.15.470 and 18.15.572), including the
provisions of JCC 18.20.290, Recreational developments, JCC 18.20.140, Commercial uses –
Standards for site development, and the following standards:
(a) Small-scale recreation or tourist uses may include limited and commensurately scaled
commercial facilities intended to serve those small-scale recreational or tourist uses (e.g., a gift
shop, delicatessen, convenience store, or associated retail sales and services); provided, that
the applicant can demonstrate the following to the satisfaction of the approving authority that:
(i) The principal demand for the commercial facilities is derived from the principal
recreational or tourist use and not the existing and projected rural population;
(ii) The associated commercial activities shall be clearly accessory to and dependent upon
the primary recreational or tourist uses;
(iii) The associated commercial activities, in addition to the principal recreational or tourist
use, will not have a measurable detrimental traffic, noise, visual or public safety impact on
adjacent properties;
(iv) The use and associated structure is clearly appropriate and compatible in scale, size,
design and function with surrounding uses and environment;
(v) The use will not constitute new urban development in a rural area;
(vi) The public facilities and services provided are limited to those necessary to serve the
associated commercial activities and the principal small-scale recreational or tourist use in
a manner that does not permit low-density sprawl; and
(vii) All other applicable requirements and standards in this UDC are met.
(b) Unless a larger parcel size is specified, minimum lot size shall be five acres, except that no
minimum lot size is required for parcels that include a historic site, structure or landmark.
(c) Only one small-scale recreational or tourist use shall be allowed per legal lot of record, with
the exception of rural restaurants.
(d) Only those buildings or areas specifically approved by the county may be used in the
conduct of the business.
(e) Parking shall be contained on-site and provided in conformance with this code, including
JCC 18.30.100 and 18.30.130.
(f) All activities shall, at a minimum, be screened from the view of adjacent residential uses
subject to the landscaping and screening requirements of JCC 18.30.130 and set back a
sufficient distance from all rear and side property lines to protect the character of adjacent and
surrounding properties and uses. The approving authority may authorize variations to the
setbacks established in Table 6-1 in JCC 18.30.050 in order to ensure that any small-scale
recreation or tourist use or structure, when proposed in or adjacent to a rural residential (RR)
district, shall be compatible with and not disruptive to the character of existing and anticipated
future uses in the district.
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 8
(g) All small-scale recreation or tourist uses shall utilize local access or minor collector roads for
primary access whenever practicable. Access off of state routes, arterials, or major collector
roads may be allowed if access improvements or a traffic analysis assures mobility is not
degraded.
(h) Structures shall comply with the landscape, lighting, site coverage, and design standards
set forth in Chapter 18.30 JCC.
(i) Any small-scale recreational or tourist use development allowed under this section that
proposes to include permanent occupancy on-site residential development may only be
permitted subject to:
(i) The underlying rural residential density;
(ii) A master planned resort (MPR) district designation subject to a legislative action to
amend the Comprehensive Plan; or
(iii) That necessary for on-site management (e.g., a caretaker’s residence).
(j) For any small-scale recreation or tourist use, the county shall impose such reasonable
conditions (e.g., location and size restrictions, design standards, landscape buffers,
setbacks, etc.) as are found necessary by the approving authority to ensure that the activity
or use, due to proximity, location or intensity:
(i) Is compatible with the rural character of adjacent lands and shorelines, including forestry,
agriculture, and mineral lands of long-term commercial significance;
(ii) Does not disrupt the character of any surrounding permitted uses;
(iii) Is adequately served by public facilities and services (including roadway level of service
and minimum fire flow requirements) without the need to extend those services in a manner
that promotes low density sprawl;
(iv) Adequately protects critical areas including surface and groundwater resources; and
(v) Would not cumulatively, in combination with the effects of existing development (or
given the probable development of subsequent projects with similar effects) in the vicinity
(i.e., within one mile) of the proposed use, create a development pattern that constitutes
low density sprawl; require the extension of public facilities or expansion of public services
in a manner that promotes low density sprawl; or be otherwise incompatible with or
injurious to the rural character of the area;
(vi) For designated agricultural lands, converts as little land with prime agricultural soils as
practicable into nonagricultural use.
(k) If the preceding conditions (in subsection (3)(j) of this section) cannot be met to the
satisfaction of the approving authority, the use shall be denied.
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 9
Exhibit 9
USEPA Region 2 Best Management Practices for Lead at Outdoor Shooting Ranges
Best Management Practices for
Lead at Outdoor Shooting
Ranges
EPA-902-B-01-001
Revised June 2005
Region 2
United States
Environmental Protection
Agency
For additional copies of this manual, please contact:
United States Environmental Protection Agency
Division of Enforcement and Compliance Assistance
RCRA Compliance Branch
290 Broadway, 22nd Fl.
New York, New York 10007-1866
Tel: 212-637-4145
Fax: 212-637-4949
Copies of this manual along with any additions or updates can also be obtained on-line at:
http://www.epa.gov/region2/waste/leadshot
Copying and Reprinting
This document is in the public domain and may be freely copied or reprinted.
Fourth Printing, June 2005
BMP for Lead at Outdoor Shooting Ranges
Best Management Practices
for Lead
at Outdoor Shooting Ranges
Notice
This manual is intended to provide useful general information to shooting range owners/operators.
The United States Environmental Protection Agency (EPA) does not certify or approve ranges,
range design or lead management practices. While every effort has been made to provide up-to-
date technical information, this manual is not to be used as a substitute for consultation with scien-
tists, engineers, attorneys, and other appropriate professionals who should be called upon to make
specific recommendations for individual range design and lead management.
Any variation between applicable regulations and the summaries contained in this guidance docu-
ment are unintentional, and, in the case of such variations, the requirements of the regulations
govern.
This guidance was developed by EPA Region 2 in cooperation with a few states as well as many
EPA offices. In addition, EPA, with the assistance of the Association of State and Territorial Solid
Waste Management Officials (ASTSWMO) provided all 50 states with an opportunity to review the
RCRA regulatory portion of the guidance. At the time of printing, about 40 states had contacted the
EPA and given their support and concurrence. EPA is continuing to get the agreement of the re-
maining states. Therefore, it appears that most, if not all, states will share the same view as to how
lead shot is regulated.
Following the steps set forth in this guidance should result in compliance with applicable regulations.
EPA does not make any guarantee or assume any liability with respect to the use of any information
or recommendations contained in this document.
This guidance does not constitute rulemaking by the EPA and may not be relied on to create a
substantive or procedural right or benefit enforceable, at law or in equity, by any person.
Notice
BMP for Lead at Outdoor Shooting Ranges
Acknowledgements
The USEPA would like to acknowledge the support of:
•The National Rifle Association of America
•The National Shooting Sports Foundation
•The Wildlife Management Institute
•Mark Begley of the Massachusetts Department of Environmental Protection
•Mr. Dick Peddicord of Dick Peddicord and Company, Inc.
These participants provided valuable information and assistance as peer reviewers in the develop-
ment of the manual and their efforts are truly appreciated. EPA also wishes to give special thanks to
Dr. Charles W. Sever of Okie Environmental Consulting, L.L.C., Inc., Mr. Mike Warminsky of Brice
Environmental Services Corp., and Mr. Victor Ordija of Sporting Goods Properties.The EPA also
wishes to acknowledge and thank the many others who provided important comments and insight,
and especially those individuals who took the time to meet with us in person or on the phone.
Acknowledgements
Cover photo by: Mr. Jack Hoyt, EPA Region 2
BMP for Lead at Outdoor Shooting Ranges
Statement of Goals
The goals of this manual are:
to inform shooting ranges :
that the United States Environmental Protection Agency’s (EPA)
purpose in developing and distributing this manual is to assist range
owners and operators to operate in an environmentally protective
manner.
to promote an understanding of:
why lead is an environmental, public and regulatory concern,
what laws and regulations apply,
the benefits of applying good management practices,
what can be done to successfully manage lead,
why implementing lead best management practices is an integral part
of environmental stewardship,
how to minimize litigation risk.
to promote action by ranges to:
adopt and implement best management practices for managing lead,
recycle a finite natural resource,
become a model for other ranges through proper
lead management,
advocate environmental stewardship.
Statement of Goals
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BMP for Lead at Outdoor Shooting Ranges
EPA Statement on National Guidance
EPA Statement on National Guidance
BMP for Lead at Outdoor Shooting Ranges
EPA Statement on National Guidance
Table of Contents - i
BMP for Lead at Outdoor Shooting Ranges
Best Management Practices for Lead at
Outdoor Shooting Ranges
Table of Contents
Page
List of Figures ...................................................................................................................ii
List of Tables .....................................................................................................................ii
Introduction .......................................................................................................................iii
Chapter I - Environmental and Regulatory Concerns at the Shooting Range ................ I-1
1.0 Background ...............................................................................................I-1
1.1 Lead Contamination’s Impact on Human Health and the Environment ......I-2
1.2 Legal Requirements & Court Rulings ........................................................I-6
1.3 Benefits of Minimizing Lead’s Environmental Impact ...............................I-12
Chapter II - Range Characteristics & Activities to Consider When
Implementing BMPs ................................................................................. II-1
2.0 Background .............................................................................................II-1
2.1 Physical Characteristics...........................................................................II-1
2.2 Operational Aspects .................................................................................II-4
2.3 Planning a New Range .............................................................................II-4
Chapter III - BMPs for Outdoor Ranges....................................................................... III-1
3.0 Background .............................................................................................III-1
3.1 Bullet and Shot Containment Techniques (Step 1)...................................III-1
3.2 BMPs to Prevent Lead Migration (Step 2)................................................III-5
3.3 Lead Removal and Recycling (Step 3)..................................................III-11
3.4 Documenting Activities and Record Keeping (Step 4)...........................III-17
3.5 Additional Economic Considerations .....................................................III-18
3.6 Summary of Key BMPs for Shooting Ranges ........................................III-18
3.7 Certificate of Recognition.......................................................................III-18
References
Appendix A - Resources
Appendix B - Lead Shot Alternatives
Appendix C - Sample Bullet Containment Devices
Appendix D - RCRA Regulatory Requirements and Interpretations
Appendix E - Template for an Environmental Stewardship Plan
for Management of Lead Shot/Bullets
Lists of Figures and Tables - ii
BMP for Lead at Outdoor Shooting Ranges
Figure Number
1-1 Effects on the Human Body from Excessive Exposure to Lead
2-1 pH Scale
3-1 Four Steps to Build a Successful Lead Management Program
Utilizing a Variety of BMPs
3-2 Sample Filter Bed System
3-3 Examples of Common Lead Reclamation Equipment
Table Number
1-1 Application of Key Terms to Outdoor Ranges
2-1 Common Physical Characteristics at Ranges - Potential Risks
and Benefits Associated with Range Operations
3-1 Summary of Key BMPs
3-2 Calculating Weight of Lime to Increase Soil pH Values
Page
I-5
II-1
III-1
III-10
III-11
Page
I-10
II-3
III-19
III-6
List of Figures
List of Tables
Introduction
This manual provides owners and operators of
outdoor rifle, pistol, trap, skeet and sporting clay
ranges with information on lead management at
their ranges. This manual serves as a reference
guide and presents best management practices
(BMPs) available to the shooting range
community. The practices have been proven to
effectively reduce or eliminate lead
contamination and may also be economically
beneficial to the range owner/operator. Since
each range is unique in both the type of shooting
activity and its environmental setting, specific
solutions are not provided in this manual.
Rather, a range owner or operator may use this
manual to identify and select the most
appropriate BMP(s) for their facility. Other
information on environmental aspects of
management at outdoor shooting ranges can be
found in the National Shooting Sports
Foundation’s Environmental Aspects of
Construction and Management of Outdoor
Shooting Ranges.
The manual does not address range layout or
design to meet range safety or competition
requirements. For information on range safety
and competition requirements, range owners/
operators are directed to other comprehensive
reference materials available on that subject,
such as the National Rifle Association’s Range
Source Book, and the National Association of
Shooting Range’s website (www.rangeinfo.org).
Owners/operators of ranges may want to
assign the use of this BMP Manual to a
specific team or committee. Delegating this
responsibility to a specific team or group
helps to assure that the BMP’s are identified
and implemented.
The manual is organized as follows:
• Chapter I provides the background on why
lead is of concern to human health and the
environment. It includes a discussion of how
environmental laws impact shooting ranges
and the importance of an integrated BMP
program to manage lead.
• Chapter II discusses physical and
operational characteristics to be considered
when selecting a successful BMP program.
• Chapter III addresses best management
techniques for rifle/pistol ranges, skeet and
trap ranges, and sporting clay ranges. In this
chapter, the manual explores possible
solutions to prevent, reduce and/or remove
lead contamination for each type of range.
• The Appendices provide current (as of June
2005) contacts for lead reclamation and
recycling companies, vendors that provide
prevention and/or remediation techniques and
shooting organizations that have additional
information on the lead issue. Additionally,
the Appendices provide information on
alternatives to lead, diagrams of bullet trap
designs, summaries of regulatory
requirements and interpretations, and a
sample Environmental Stewardship Plan.
EPA is very interested in any suggestions you
have about practices included in this manual
which have proven effective in controlling lead
contamination or recycling lead bullets/shot.
Please send such information to the address
below. Also, for additional information, or to be
added to the list of lead reclaimers or
remediation contractors, contact the National
Rifle Association (NRA), the National Shooting
Sports Foundation (NSSF) or:
Lead Shot Coordinator
RCRA Compliance Branch
U.S. Environmental Protection Agency
Region 2
290 Broadway
New York, New York 10007-1866
Telephone: (212)637-4145
E-Mail: Leadshot.Region2@epa.gov
Introduction - iii
BMP for Lead at Outdoor Shooting Ranges
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Chapter I - Page I-1
BMP for Lead at Outdoor Shooting Ranges
Chapter I:
Environmental and Regulatory
Concerns at the Shooting Range
(CDCP), and a large number of states have
identified human exposure to all forms of lead as
a major health concern in the United States.
Lead management practices at ranges across
the United States remain inconsistent. Some
range owners/operators have examined the
impact of range operations on human health and
the environment and have implemented
procedures to manage and/or remove
accumulated lead from ranges. Other range
owners/operators are just beginning to
characterize and investigate their ranges in
order to design an environmental risk prevention
and/or remediation program(s) specific to their
sites. A third group of ranges has adopted a
“wait and see” policy – taking no action until
specifically required to do so by law or clear
guidance is in place. Finally, a fourth, small, but
important group of range owners/operators
remain unaware of lead’s potential to harm
human health and the environment, and of
existing federal and state laws.
To manage lead, many owners and operators
have successfully implemented Best
Management Practices (BMPs) at their ranges.
These range owners and operators have
realized many benefits from sound lead
management including:
- stewardship of the environment, natural
resources and wildlife,
- improved community relations,
- improved aesthetics of the range/good
business practices,
- increased profitability through recovery/
recycling lead, a valuable and finite resource,
and
- reduced public scrutiny.
Shooting sports organizations [e.g., National
Rifle Association (NRA) and the National
Shooting Sports Foundation (NSSF)] promote
lead management throughout the United States.
These organizations have researched different
methods to effectively address potential and
actual lead mobility and exposure without
detracting from the enjoyment of the sport. The
NRA, NSSF, and a number of other shooting
sports organizations strongly encourage range
1.0 Background
Outdoor shooting ranges provide recreational
facilities for millions of shooting sports
enthusiasts in the United States. Recently, there
has been a growing public concern about the
potential negative environmental and health
effects of range operations. In particular, the
public is concerned about potential risks
associated with the historical and continued use
of lead shot and bullets at outdoor ranges.
This concern is not unfounded. An estimated
9,000 non-military outdoor ranges exist in the
United States, collectively shooting millions of
pounds of lead annually. Some ranges have
operated for as long as several generations.
Historical operations at ranges involved leaving
expended lead bullets and shot uncollected on
ranges. Many of these ranges continue to
operate in the same manner as in the past.
It is estimated that approximately four percent
(4%) (80,000 tons/year) of all the lead produced
in the United States in the late 1990’s (about 2
million tons/year), is made into bullets and shot.
Taking into account rounds used off-range, and
rounds used at indoor ranges, it is clear that
much of this 160,000,000 pounds of lead shot/
bullets finds its way into the environment at
ranges.
Since the mid-1980’s, citizen groups have
brought several lawsuits against range owners
and have urged federal and state agencies to
take action against owners and operators of
outdoor shooting ranges. The citizen groups
argued that range owners improperly managed
discharged lead bullets and shot. Federal courts
have supported parts of these suits, requiring
range owners/operators to clean up lead-
contaminated areas. Concurrent with the
increased citizen suit activity, the federal EPA,
the Centers for Disease Control and Prevention
Chapter I - Page I-2
BMP for Lead at Outdoor Shooting Ranges
owners/operators to develop a BMP program
that contains elements discussed later in this
manual. Contact the NRA and NSSF for
additional guidance materials available on lead
management practices.
By implementing appropriate lead management
at outdoor shooting ranges, range owners and
operators can reduce the environmental and
health risks associated with lead deposition,
meet legal requirements and realize quantifiable
benefits.
1.1 Lead Contamination’s Impact
on Human Health and the
Environment
Exposure Routes
Historically, the three major sources for human
exposure to lead are lead-based paint, lead in
dust and soil and lead in drinking water.
Typically, human exposure occurs through
ingestion, which is the consumption of lead or
lead-contaminated materials, or by inhalation.
The main human exposure to lead associated
with shooting ranges is through lead-
contaminated soil. However, other pathways are
discussed below, along with lead’s detrimental
effects on humans and animals.
Lead can be introduced into the environment at
shooting ranges in one or more of the following
ways. Each of these pathways is site-specific
and may or may not occur at each individual
range:
•Lead oxidizes when exposed to air and
dissolves when exposed to acidic water or
soil.
•Lead bullets, bullet particles, or dissolved
lead can be moved by storm water runoff.
•Dissolved lead can migrate through soils to
groundwater.
Lead oxidizes when exposed to air and
dissolves when exposed to acidic water or soil
When lead is exposed to acidic water and/or
soil, it breaks down by weathering into lead
oxides, carbonates, and other soluble
compounds. With each rainfall, these
compounds may be dissolved, and the lead may
move in solution in the storm runoff waters.
Decreases in water acidity (i.e., increases in its
pH) will cause dissolved lead to precipitate out of
solution. Lead concentrations in solution are
reduced by this precipitation. At pHs above 7.5,
very little lead remains in solution. Increased
time of contact between lead and acidic water
generally results in an increase in the amount of
dissolved lead in the storm runoff water. The five
factors which most influence the dissolving of
lead in water are summarized below:
Annual Precipitation Rate - The higher the
annual precipitation rate, the faster the lead
weathers. Also, during prolonged rains, the
contact time between water and lead is
increased. In general, the higher the
precipitation rate, the higher the potential risk of
lead migration off-site in solution.
pH of Rain and Surface Water - The acidity of
the rainwater decreases as basic (alkaline)
minerals in the soil are dissolved. If sufficient
minerals such as calcium, magnesium, and iron
are present in local soils, then the lead may
quickly precipitate out of solution entirely as
these other minerals are dissolved. The pH of
shallow surface water is an indicator of the
presence or absence of basic minerals in the
local soil and in gravel within the stream beds
through which the water has moved. The water
in deeper streams and lakes is more likely to be
composed of acidic rainwater that is not
neutralized.
Contact Time - The contact time between
acidic surface water and lead is a factor in the
amount of lead that is dissolved. For example,
lead shot deposited directly into a lake has a
longer contact time then lead shot deposited in
upland areas.
Soil Cover - Organic material will absorb lead
and remove it from a water solution. The thicker
the organic leaf and peat cover on the soil, the
lower the lead content in solution in water leaving
the shot area. Organic material has a strong
Chapter I - Page I-3
BMP for Lead at Outdoor Shooting Ranges
ability to extract lead out of solution in water.
pH of Groundwater - During periods of no
rainfall, the water flowing within most streams
comes from groundwater discharging into the
stream channel. Therefore, the acidity of the
groundwater affects the acidity of the surface
water, and hence, affects the solubility of any
lead particles carried into the stream during
storm runoff.
Lead bullets, bullet particles or dissolved lead
can be moved by storm water runoff
The ability of water to transport lead is influenced
by two factors: velocity of the water and weight
or size of the lead fragment. Water’s capacity to
carry small particles is proportional to the square
of the water’s velocity. Clear water moving at a
velocity of 100 feet per minute can carry a lead
particle 10,000 times heavier than water moving
at a velocity of 10 feet per minute. Muddy water
can carry even larger particles. The five factors
that most influence velocity of runoff are
described below:
Rainfall Intensity - The greater the volume of
rainfall during a short period of time, the faster
the velocity created to carry the rainfall off-site.
The higher the annual rainfall, the greater the
number of periods of heavy rainfall.
Topographic Slope - Generally, the steeper the
topographic slope, the faster the velocity of
stormwater runoff.
Soil Type - More rainfall will soak into sandy
soils then into clay soils. Hence, for a given
rainfall intensity, the volume of runoff will be
greater from areas underlain by clays or other
low permeable soils than from permeable sandy
soil.
Velocity - Velocity tends to decrease as stream
width increases. Merging streams, eddy
currents, and curves in streams are other factors
that may reduce the velocity. Generally, the
shorter the distance from the lead deposit to the
property line, the more likely it is that the lead
fragments in suspension will be transported off-
site.
Vegetative Cover and Man-made Structures -
Structures such as dams and dikes reduce the
water’s velocity and greatly reduce the size and
weight of the lead particles the water can carry.
Since lead particles are heavy compared to the
other suspended particles of similar size, they
are more likely to be deposited under the
influence of anything that reduces velocity of the
storm runoff. Grass and other vegetation
reduce runoff velocity and act as a filter to
remove suspended solids from the water.
Dissolved lead can migrate through soils to
groundwater
Acidic rainwater may dissolve weathered lead
compounds. A portion of the lead may be
transported in solution in groundwater beneath
land surfaces. Groundwater may transport lead
in solution from the higher topographic areas to
the lower areas such as valleys, where it is
discharged and becomes part of the surface
water flow. If the water flowing underground
passes through rocks containing calcium,
magnesium, iron, or other minerals more soluble
then lead, or through minerals that raise the pH
of the water, then the lead in solution may be
replaced (removed) from the solution by these
other metals. However, if the soil is a clean
silica sand and gravel, fractured granite, or
similar type material, then the lead may move
long distances in solution. The factors most
likely to affect the amount of lead carried by the
groundwater in solution are discussed below:
Annual Precipitation - Generally, high
precipitation rates result in heavy dew, more
frequent rainfall, numerous streams, shallow
depth to groundwater, shorter distance of travel,
and more rapid rates of groundwater flow. Also,
the greater volumes of rainfall over geologic time
probably have reduced the amount of calcium
and other soluble basic minerals that could raise
the water pH and cause lead to precipitate
(settle) out of solution from the groundwater.
Soil Types - Clays have a high ionic lead
bonding capacity and more surface area to
which the lead can bond. Also, groundwater
movement in clay is very slow, which increases
the contact time for lead to bond to the clay.
Chapter I - Page I-4
BMP for Lead at Outdoor Shooting Ranges
Low permeability reduces the amount of
historical leaching and increases the probability
of the presence of basic (pH-increasing)
minerals that can precipitate out of solution in
groundwater or cause the lead to bond to the
clay. All of the basic calcium and related
minerals generally will have been removed from
the clean silica sand and gravel soils, so the
lead in solution in groundwater in these type
soils can move long distances (miles) through
the ground relatively unchanged.
Soil Chemistry - The more basic minerals like
calcium and magnesium that are present in soils
along the pathways through which the
groundwater moves, the greater the lead
precipitation (removal) rate. Lead should move
in solution only a short distance (a few feet)
through a sand composed of calcium shell
fragments, but could move in solution long
distances (miles) through clean quartz sand.
Depth to Groundwater - In areas of
groundwater discharge such as river flood plains
and most flat areas, the groundwater surface is
often a few feet below the surface. Remember,
the shorter the distance traveled, the greater the
risk that the lead will migrate into the
environment. Shallow depth to groundwater is
indicative of higher risk for lead to reach the
water.
pH of Groundwater - Although other factors
influence solubility of lead in water, a good rule of
thumb is that lead will precipitate out of solution
when the pH or alkalinity of water is greater then
about 7.5. But, lead dissolved in acid
groundwater may travel many miles without
change.
Health Effects of Lead Exposure on Ranges
Lead poisoning is a serious health risk. At
higher concentrations, it is dangerous to people
of all ages, leading to convulsions, coma and
even death. At even very low concentrations, it
is dangerous to infants and young children,
damaging the developing brain and resulting in
both learning and behavioral problems. Figure 1-
1 describes the effects of exposure to lead on
children and adults.
Federal, state and local actions, including bans
on lead in gasoline, paint, solder and many other
lead-containing products, have resulted in
significant reductions in average blood-lead
levels. Despite these advances, the number of
lead-poisoned children remains alarmingly high.
Children living in older homes may be exposed
to lead in peeling paint or paint dust. Children
can also come in contact with lead in soil and
with lead dust carried home on the clothing of
parents.
On ranges, inhalation is one pathway for lead
exposure since shooters are exposed to lead
dust during the firing of their guns. Because
wind is unlikely to move heavy lead particles
very far, airborne dust is generally considered a
potential threat only when there are significant
structures that block air flow on the firing line.
Under such conditions, the hygiene and other
practices proposed by the NRA for indoor
shooting ranges in their “Source Book” are
applicable to outdoor ranges.
Range workers may also be exposed to lead
dust while performing routine maintenance
operations, such as raking or cleaning out bullet
traps. Owners/operators may want to protect
these workers by requiring them to wear the
proper protective equipment or dampening the
soil prior to work.
Another exposure route for lead at outdoor
ranges is ingestion by direct contact with lead or
lead particles. For example, lead particles
generated by the discharge of a firearm can
collect on the hands of a shooter. These
particles can be ingested if a shooter eats or
smokes prior to washing his/her hands after
shooting. The relative risk of lead exposure to
people in a well managed facility is low.
Detrimental effects due to elevated lead levels
can also be found in animals. Excessive
exposure to lead, primarily from ingestion, can
cause increased mortality rates in cattle, sheep
and waterfowl. For example, waterfowl and
other birds can ingest the shot, mistaking it for
food or grit. Waterfowl, in particular, are highly
susceptible to lead ingestion. This is a concern
at ranges where shooting occurs into or over
Chapter I - Page I-5
BMP for Lead at Outdoor Shooting Ranges
Effects on the Human Body from Excessive Exposure to Lead
If not detected early, children with relatively low levels of lead (as low as 10
microgram/deciliter for children) in their bodies can suffer from:
- damage to the brain and nervous system,
- behavior and learning problems (such as hyperactivity and aggressiveness),
- slowed growth,
- hearing problems,
- headaches, and
- impairment of vision and motor skills.
Adults can suffer from:
- difficulties during pregnancy,
- reproductive problems in both men and women (such as low birth
weight, birth defects and decreased fertility),
- high blood pressure,
- digestive problems,
- neurological disorders,
- memory and concentration problems,
- muscle and joint pain, and
- kidney dysfunction.
Brain or Nerve Damage
Slowed Growth
Hearing Problems
Digestive Problems
Reproductive Problems
(Adults)
Lead affects the
body in many ways
Figure 1-1: Effects on the Human Body from Excessive Exposure to Lead
Chapter I - Page I-6
BMP for Lead at Outdoor Shooting Ranges
understand the legal issues and requirements.
1.2.1 Resource Conservation and
Recovery Act (RCRA)
RCRA provides the framework for the nation’s
solid and hazardous waste management
program. Under RCRA, EPA developed a
“cradle-to-grave” system to ensure the
protection of human health and the environment
when generating, transporting, storing, treating
and disposing of hazardous waste. RCRA
potentially applies to many phases of range
operation because lead bullets/shot, if
abandoned, may be a solid and/or a hazardous
waste and may present an actual or potential
imminent and substantial endangerment.
Connecticut Coastal Fishermen’s
Association v. Remington Arms Company, et
al.
In the late 1980s, the Connecticut Coastal
Fishermen’s Association filed a lawsuit against
Remington Arms Company as the owner of the
Lordship Gun Club. The Lordship Gun Club
(a.k.a. Remington Gun Club) is a 30-acre site in
Stratford, Connecticut, located on the Long
Island Sound at the mouth of the Housatonic
River. In the mid-1960s, the Lordship Gun Club
was reconstructed to its final configuration of 12
combined trap and skeet fields and one
additional trap field. Over the years, the
Lordship Gun Club became known as one of the
premier shooting facilities on the East Coast.
The Connecticut Coastal Fishermen’s
Association filed a lawsuit, alleging that lead shot
and clay targets are hazardous waste under
RCRA. The Complaint alleged that because the
lead shot and clay targets were hazardous
wastes, the gun club was a hazardous waste
storage and disposal facility subject to RCRA
requirements. The plaintiff also sought civil
penalties and attorney’s fees.
Remington moved for a summary judgment
dismissing the complaint, and the Connecticut
Coastal Fisherman’s Association cross-moved
for a partial summary judgment on the issue of
liability. On September 11, 1991, the United
water. Many of the legal and government actions
that have been brought against ranges are
based on elevated levels of lead and increased
mortality in waterfowl. For example, in one case,
an upland area of a range became a temporary
pond after a thunderstorm. Waterfowl used the
pond to feed and shortly thereafter, there was a
waterfowl die-off (increase in bird mortality),
apparently from lead ingestion.
1.2 Legal Requirements & Court
Rulings
To date, most litigation concerns have been at
shotgun ranges where the shotfall zone impacts
water or wetland areas. The potential
environmental and human health risks are
greater at these ranges. However, all ranges,
including those not located near water bodies,
may be subject to legal and government action if
proper range management programs are not
implemented. Range owners/operators should
expect greater scrutiny as ranges become more
visible to regulators, environmental groups and
the general public.
Citizen groups have been the driving force
behind most legal actions taken against outdoor
ranges. These groups have sued range owners/
operators under federal environmental laws. Two
of EPA’s most comprehensive environmental
laws, the Resource Conservation and Recovery
Act (RCRA) and the Clean Water Act (CWA),
specifically provide citizens with the right to sue
in cases in which the environment and human
health are threatened. These citizen suits have
been highly effective in changing the way ranges
operate, even when out-of-court settlements
have been reached. The decisions of the United
States Court of Appeals for the Second Circuit in
Remington Arms and New York Athletic Club set
a legal precedent in the application of RCRA
and/or the CWA to outdoor ranges. Lead
management programs at outdoor ranges must
comply with both laws. Actions have also been
taken under the Comprehensive Environmental
Response, Compensation and Liability Act
(CERCLA) commonly know as Superfund.
State and local statutes and regulations may
also apply. To ensure environmental laws are
being followed, range owners/operators must
Chapter I - Page I-7
BMP for Lead at Outdoor Shooting Ranges
States District Court for the District of
Connecticut ruled on the case.
Regarding the plaintiff’s claims under RCRA, the
District Court ruled in favor of the Connecticut
Coastal Fishermen’s Association, holding that
the lead shot and clay targets were “discarded
materials” and were “solid waste;” therefore, the
materials were subject to regulation under
RCRA. The court further stated that the
discharged lead shot was a “hazardous waste,”
but declined to rule on whether the clay target
fragments were also hazardous waste.
Remington petitioned the United States Court of
Appeals for the Second Circuit Court to review
the lower court’s ruling.
On June 11, 1992, both parties presented oral
arguments before the court. Subsequent to oral
arguments, the appellate court requested that
EPA file an amicus brief “addressing whether
lead shot and clay target debris deposited on
land and in the water in the normal course of
trap and skeet shooting is ‘discarded material’...
so as to constitute ‘solid waste’ under RCRA.”
On March 29, 1993, the United States Court of
Appeals for the Second Circuit reached its
decision. With respect to RCRA, the court both
reversed and affirmed the lower court’s opinion
in part.
Briefly, the decision affects currently operating
and future gun clubs, and the following key
points are of primary concern:
1.With respect to RCRA, the court agreed
with EPA’s amicus brief, which had argued that
shooting at gun clubs is not subject to regulatory
(as opposed to statutory) requirements. In other
words, during routine operations, gun clubs are
not viewed as facilities that manage hazardous
wastes subject to RCRA regulations and, as
such, do not require RCRA permits.
2.Another argument in the EPA’s amicus
brief with which the court agreed was the view
that the RCRA statute allows citizen suits to be
brought if a gun club’s shooting activities pose
an “imminent and substantial endangerment to
health or the environment.” Although gun clubs
are not subject to RCRA regulations, EPA or any
state, municipality, or citizen group can take
legal action under the statutory provisions of
RCRA against gun clubs for actual or potential
environmental damage occurring during, or even
after, the operation of the club. Under RCRA,
the plaintiff would be eligible to recover its legal
fees as well.
3.The court concluded that lead shot and
clay targets meet the statutory definition of solid
waste because these materials were “discarded
(i.e. abandoned)” and “left to accumulate long
after they have served their intended purpose.”
Further, the court concluded that based upon
toxicity testing and evidence of lead
contamination, the lead shot was a hazardous
waste subject to RCRA.
The important point to consider here is that if
lead shot and clay target debris are discarded
(i.e. abandoned), these materials are considered
a solid waste as defined in the statute and the
facility may be subject to governmental or citizen
suits.
If, on the other hand, the discharged lead shot is
recovered or reclaimed on a regular basis, no
statutory solid waste (or hazardous waste)
would be present and imminent hazard suits
would be avoided.
Thus, the Remington Arms case is an important
legal precedent. Even though regulations have
not been issued regarding gun club operations
and environmental protection, gun clubs are still
at risk of legal action under RCRA if they fail to
routinely recover and reclaim lead, do not take
steps to minimize lead release or migration, or if
they abandon lead in berms.
Gun clubs where there is shooting into water,
wetlands, rivers, creeks, and other sensitive
environments have the highest degree of
litigation risk. Conversely, gun clubs that have
the lowest risk of environmental litigation or
government action are those clubs that do not
shoot into water or wetlands and which have an
active program to recover lead.
The following describes how RCRA may apply
to outdoor shooting ranges.
Chapter I - Page I-8
BMP for Lead at Outdoor Shooting Ranges
How is Lead Shot Regulated Under
RCRA?
Lead shot is not considered a hazardous waste
subject to RCRA at the time it is discharged
from a firearm because it is used for its intended
purpose. As such, shooting lead shot (or
bullets) is not regulated nor is a RCRA permit
required to operate a shooting range. However,
spent lead shot (or bullets), left in the
environment, is subject to the broader definition
of solid waste written by Congress and used in
sections 7002 and 7003 of the RCRA statute.
With reference to reclaiming and recycling lead
shot, the following points should serve as
guidance in understanding RCRA and how it
applies to your range. (A more detailed
discussion of the underlying RCRA rules
applicable to lead shot removal at ranges is
included in Appendix D)
•Removal contractors or reclaimers should
apply standard best management
practices, mentioned in this manual, to
separate the lead from soil. The soil, if
then placed back on the range, is exempt
from RCRA. However, if the soil is to be
removed off-site, then it would require
testing to determine if it is a RCRA
hazardous waste.
•Lead, if recycled or reused, is considered
a scrap metal and is, therefore, excluded
from RCRA.
•Collected lead shot and bullets are excluded
from RCRA regulation, and need not have a
manifest, nor does a range need to obtain a
RCRA generator number (i.e., the range is
not a hazardous waste “generator”), provided
that the lead is recycled or re-used. The
reclaimer does not need to be a RCRA
transporter. However, it is recommended
that ranges retain records of shipments of
lead to the receiving facilities in order to
demonstrate that the lead was recycled.
Records should also be kept whenever
the lead is reused (as in reloading.) The
range should be aware that it ultimately
may be responsible for the lead sent for
reclamation. Therefore, only reputable
reclaimers should be utilized.
• Lead from ranges destined for recycling may
be temporarily stored on range property after
separation from soil if the lead is stored in
closed, sealed containers, the containers are
stored in a secure location and routinely
inspected by range staff, and records of
inspections are maintained.
• Sections 7002 and 7003 of the RCRA statute
allow EPA, states or citizens to use civil
lawsuits, to compel cleanup of or other action
for “solid waste” (e.g., spent lead shot) posing
actual or potential imminent and substantial
endangerment. Such actions can be sought
whether the range is in operation or closed,
and is based solely on a determination that
harm is being posed or may be posed by the
range to public health and/or the environment.
Since the risk of lead migrating increases with
time, making ranges that have not removed
lead more likely candidates for government
action or citizen lawsuits under RCRA Section
7002 and 7003, ranges are advised to
maintain a schedule of regular lead removal.
• With time, lead in soil can become less
desirable to reclaimers and smelters, thereby
potentially reducing or eliminating financial
returns from lead removal. Moreover, such
soil may be subject to more expensive
treatment to separate the lead for recycling.
• Lead removal will allow the range to: avoid
contamination of the site and potential impacts
to human health and the environment; reduce
liability with regard to potential government
agency or citizen suit action; and, possibly,
benefit economically from the recycling of
lead. Additional guidance on reclaiming lead
is provided in other parts of this manual.
• Soil from berms and shotfall zones may be
moved to another area of the range for such
reasons as addressing potential
environmental impacts (e.g., runoff), altering
the layout to address safety concerns or
allowing different types of shooting activities,
or adding or removing shooting positions.
However, removal of lead prior to such
Chapter I - Page I-9
BMP for Lead at Outdoor Shooting Ranges
movement of soil is normal practice and
highly advised because it extends the usable
life of the materials and reduces the
possibility of release of lead into the
environment. If lead is not first removed, it
will be further dispersed and will be more
difficult to remove in future reclamation.
Written records of all such activity should be
maintained indefinitely, as they will be
necessary in subsequent construction or
range closure.
• This RCRA summary applies to operating
and non-operating ranges, and the use of
BMPs at operating ranges is highly
recommended. However, because of
increased risk if lead is not actively managed,
such application may not preclude the need
for remediation, as appropriate and/or as
required by states’ regulations, when a range
is permanently closed, on-site lead is
abandoned, or the land use changes.
Introductory guidance for remediation can be
found at www.epa.gov/epaoswer/osw or
www.epa.gov/superfund. Look under the
sections “Cleanup” or “Resources,” or use
the Search function.
1.2.2 - Clean Water Act
The goal of the Clean Water Act (CWA) is to
“restore and maintain the chemical, physical,
and biological integrity of the Nation’s waters.”
The most common allegation against ranges by
the EPA and citizen groups, is that they violate
the CWA if they do not have permits that allow
spent ammunition to be discharged into water.
The CWA prohibits “the discharge of any
pollutant by any person” into the waters of the
United States without a National Pollution
Discharge and Elimination System (NPDES)
permit. There have been two court cases that
have applied the provisions of the CWA to
civilian shooting ranges. To understand how the
CWA can apply to shooting ranges, a summary
of the cases follows. Also see Table 1-1.
To understand the application of the CWA to
outdoor ranges, one must know the definitions of
key terms and how they have been applied to
shooting activities. See Table 1-1.
In the Remington Arms and the New York
Athletic Club lawsuits, citizen groups argued that
the defendants violated the CWA by discharging
pollutants from point sources into the Long
Island Sound without a NPDES permit.
Application of the CWA requires the violations to
be ongoing. Consequently, the court in
Remington Arms dismissed the CWA charge
against the range because it had ceased
operating before the lawsuit was filed.
However, in the New York Athletic Club case,
the club was still in operation during the time of
litigation, but had switched to steel shot. EPA’s
opinion on this case also addressed the CWA
violation. EPA argued that certain trap/skeet
ranges can convey pollutants, via point sources,
to water in violation of the CWA if a NPDES
permit is not obtained. Although some shooting
organizations have disagreed with the EPA
position, the United States District Court for the
Southern District of New York specifically found
that:
• The mechanized target throwers, the
concrete shooting platforms, and the
shooting range itself are considered point
sources as defined by the CWA;
• Expended shot and target debris, including
non-toxic shot, such as steel shot, left in
water, are pollutants as defined by the CWA.
Although the New York district court’s decision in
the New York Athletic Club case is not
controlling in any other district, range owners
and operators of outdoor ranges that shoot over
or into wetlands or other navigable waters of the
United States should be aware of it.
Based on the court’s decision in the New York
Athletic Club case, any range whose shot,
bullets or target debris enter the “waters of the
United States” could be subject to permitting
requirements as well as governmental or citizen
suits. “Waters of the United States” or
“navigable waters of the United States” are
waters of the United States, including territorial
seas that include any body of water that has any
connection to, or impact on, interstate waters or
commerce. The waters may include lakes,
Chapter I - Page I-10
BMP for Lead at Outdoor Shooting Ranges
Table 1-1: Application of Key Terms to Outdoor Ranges
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Chapter I - Page I-11
BMP for Lead at Outdoor Shooting Ranges
1 The term “land” in this instance refers specifically to terrain
recognized as “non-wetland” areas.
ponds, rivers, streams, wetlands, or even guts
that are frequently dry, which may not be
obvious to range owners/operators. These
ranges may be required to remediate
contaminated sediments and soils, which could
be both difficult and expensive, and to cease
operations over waters and wetlands. It is
essential that these ranges change the
direction of shooting, to avoid shooting over
or into wetlands or other navigable waters of
the United States, and initiate lead removal
and recycling activities, where feasible.
In addition, these ranges can cause a
substantial impact on wildlife and wetlands,
which range owners/operators may be required
to restore under other federal laws (e.g.,
CERCLA, discussed below). Lead shot
entering a water body substantially increases
the potential risk of contaminating surface and
groundwater which, in turn, threatens human
health and the environment. Finally, as New
York Athletic Club, Remington Arms and similar
cases show, neighbors have the most leverage
when range activity affects wetlands and
waterways.
For ranges located away from coastal areas or
whose operating areas are situated wholly over
land, compliance with the CWA can be achieved
by obtaining a NPDES permit for piped or
channeled runoff from the range into water1.
Shooting ranges impacting wetland areas may
be subject to other regulations found in Section
404 of the CWA. This section is the principal
federal regulatory program protecting the
Nation’s remaining wetland resources. Any plan
by range owners/operators to dredge and/or fill
wetlands may require a permit and will come
under close scrutiny by federal, state and local
governments and citizen groups. Owners and
operators must comply with the CWA for range
design, redesign, construction, reclamation or
remediation occurring in wetland areas.
1.2.3 Comprehensive Environmental
Response, Compensation, and
Liability Act (CERCLA)
The Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA),
imposes liability on past and present owners or
operators of properties where a release of a
hazardous substance into the environment
exists. CERCLA is used to ensure that an
owner/operator cleans a contaminated site or to
seek reimbursement from past owners/operators
or disposers (potentially responsible parties or
PRPs) when a party, either the government or
private party, has cleaned up the contamination.
Under CERCLA, lead is considered a hazardous
substance.
EPA has the authority to order a PRP to clean up
a site or conduct the cleanup and recover its
costs from the PRP under CERCLA.
Responsible parties may be held liable for all
cleanup costs, which can be substantial. Under
CERCLA, shooting ranges may be liable for
government costs incurred during the cleanup
of ranges, natural resources damages, and
health assessments and/or health effects
studies. The following two examples illustrate
how shooting ranges (including one operated by
the federal government) can be affected by
CERCLA.
Southern Lakes Trap and Skeet Club Site,
Lake Geneva, Wisconsin, et al.
In 1992, the US Fish and Wildlife Service
(USFWS) began an investigation to determine
the cause of death of over 200 Canada geese.
The geese died as a result of acute lead
poisoning after ingesting lead shot, which
research indicated came from the Southern
Lakes Trap and Skeet Club. The USFWS, in its
role as Natural Resource Trustee, took action to
recover the cost of damage to the natural
resources (i.e., migratory geese) under
CERCLA. In addition, EPA pursued a separate
action under the Agency’s CERCLA response
authority. The club had leased the property from
the property owners to operate a shooting range.
Shortly after EPA sent out the notice of potential
liability to the current and former owners and
Chapter I - Page I-12
BMP for Lead at Outdoor Shooting Ranges
operators of the club site, the club closed
permanently.
In 1994, EPA issued an Administrative Order on
Consent (AOC) against one current and one
former owner of the property where the now
closed Southern Lakes Trap and Skeet Club was
located. The AOC required the owners to
perform a site assessment, which included an
evaluation of the costs to restore the wetlands.
In 1998, EPA completed activities to clean up the
site and restore some of the natural resources
and wetlands. In a negotiated settlement, EPA
recovered $1 million of the cost of the cleanup.
Walter L. Kamb v. United States Coast Guard,
et al.
In another CERCLA action, Mr. Kamb (court
appointed property guardian) sued the U.S.
Coast Guard, California Highway Patrol, City of
Fort Bragg, and the County of Mendocino (the
defendants) for recovery of cleanup costs under
CERCLA. Mr. Kamb had been appointed by the
Mendocino County Superior Court to sell the
property on behalf of the property owners. The
property was formerly used by defendants as a
rifle, pistol and trap range. Soil analysis
indicated the presence of lead in the form of
leadshot, bullets, pellets, and dust. The court
found the defendants were “responsible parties”
(liable for cleanup costs) under CERCLA. No
apportionment of liability was made and the final
determination of each parties’ pro rata share of
the response cost was deferred.
This case shows that range activity need not
affect a water body to trigger CERCLA liability.
CERCLA is a powerful statutory authority that
can greatly impact current and former range
owners/operators. The statute allows for
recovery of damages to natural resources, the
cost of any health assessment studies and all
cleanup costs. Liability may extend to past
owners and operators long after a range ceases
operation.
1.2.4 Additional Laws and Regulations
Shooting ranges may also be subject to state
and local laws and regulations. Many states
have adopted their own environmental laws,
which are based on federal laws. Specifically,
these states have laws and regulations that
mirror the CWA and RCRA program laws. EPA-
approved state program laws must be as
stringent as the federal laws and may be more
stringent. Activities at shooting ranges may also
be subject to local laws, ordinances and
regulations addressing issues such as noise,
zoning, traffic, wetlands and nuisance. Often,
citizens or neighbors of outdoor shooting ranges
can initiate noise nuisance claims against
range owners/operators. Because many states
have passed legislation protecting ranges from
noise nuisance lawsuits, these may turn into
claims of environmental violations under the
laws discussed above due to the presence of
lead and other products at ranges.
1.3 Benefits of Minimizing
Lead’s Environmental Impact
All ranges will benefit from proactively
implementing successful BMPs. Even if range
activities currently do not cause adverse public
health and environmental impacts, by developing
and promoting active lead management
programs, ranges will benefit in the following
ways:
•Through a sound lead management
program, shooting sports enthusiasts can
reduce the potential of lead exposure and
contamination to humans, animals and the
environment.
•A lead management program will result in
improved public relations for the range
and the shooting sports. Ranges can
promote and publicize their successful BMP
programs to improve their public image.
Since many of the legal and governmental
actions begin with or are due to citizen
groups, an active lead management program
may improve the public image of the range
with these citizen groups.
•The removal of spent lead from the range
presents a clean, well maintained facility,
which will increase customer satisfaction.
Chapter I - Page I-13
BMP for Lead at Outdoor Shooting Ranges
•Lead is a recyclable and finite resource
and can be recovered from the active
portion of ranges and sold to lead
reclaimers. Frequently, reclaimers do not
charge range owners/operators to recover
lead from ranges, and owners and operators
may receive a percentage of the profit from
the sale of reclaimed lead. This factor drives
recycling efforts at many ranges.
•By reducing or eliminating a potential
source of lead migration in soil, surface
water and groundwater, range owners/
operators may avoid costly and lengthy
future remediation activities.
•Finally, implementing a BMP program for
lead may eliminate or greatly reduce the
risk of citizen lawsuits and the legal costs
associated with these lawsuits. Through
management and removal practices, lead
may no longer represent a threat upon which
citizen lawsuits are based.
Range owners/operators may question whether
the benefits of a regular and timely BMP program
outweigh the efforts of implementing and
maintaining a program. The questions may arise
especially for ranges at which shooting activities
involve waterways, since national attention has
focused on ranges located adjacent to water
(e.g., Remington Arms and the New York Athletic
Club). However, all outdoor ranges may be
subject to legal actions under RCRA and
CERCLA authority. All of the benefits for
adopting best management practices are
available and worthwhile for every range owner
and operator.
The following sections provide information that
will assist the range owner or operator in
implementing a BMP program for recovery and
recycling of lead shots and bullets.
This page intentionally left blank
Chapter II - Page II-1
BMP for Lead at Outdoor Shooting Ranges
2.1 Physical Characteristics
Physical characteristics of ranges, relative to
lead management issues, are discussed below.
Range Size
Shotgun range design and type affects the ease
of lead shot collection. Larger ranges typically
tend to have lead shot that is dispersed over a
wider area, while smaller ranges tend to
concentrate lead shot in a smaller area.
Reducing the area of the shotfall zone will
concentrate the shot within a smaller area,
allowing for easier cleanup and reclamation.
BMP techniques for reducing the shotfall zone at
trap and skeet ranges, as well as sporting clay
ranges, are discussed in Chapter III.
Soil Characteristics
Spent lead bullets and shot are most often
deposited directly on and into soil during
shooting. When lead is exposed to air and water,
it may oxidize and form one of several
compounds. The specific compounds created,
and their rate of migration, are greatly influenced
by soil characteristics, such as pH and soil
types. Knowing the soil characteristics of an
existing range site is a key component to
developing an effective lead management
plan.
Soil pH
Figure 2-1 – pH scale
Soil acidity is measured as pH on a scale
(illustrated as Figure 2-1) between 1 (most
acidic) and 14 (most alkaline, or basic), where 7
is termed neutral. Ideal soil pH for shooting
ranges is 6.5 to 8.5.1
Chapter II:
Range Characteristics &
Activities to Consider When
Implementing Best Management
Practices (BMP)
2.0 Background
Since each firing range site is unique, BMPs
for lead must be selected to meet site-
specific conditions in order to achieve
maximum success. A range’s physical
characteristics and the operational aspects (e.g.,
volume of shooting, shooting patterns and
operating schedules) will effect which BMPs
may apply and how they will be implemented.
Accordingly, whether designing a new outdoor
range or operating an existing range, it is
important that BMPs incorporate techniques
appropriate for the range’s individual
characteristics.
Section 2.1 of this chapter identifies the physical
characteristics that must be considered when
evaluating your range. A summary of common
physical characteristics at ranges is also
presented in Table 2-1. These factors include:
•Range Size (primarily for shotgun ranges)
•Soil Characteristics
•Topography/Runoff Direction
•Annual Precipitation
•Ground and Surface Water
•Vegetation
•Accessibility
Section 2.2 discusses the operational aspects
that must be considered. These factors include:
•Lead Volume
•Size of Shot/Bullets
•Operating Schedule
•Shooting Direction and Pattern
•Range Life Expectancy
In addition, Section 2.3 discusses issues that
are specific to implementing BMPs when
planning a new range.
= Ideal Soil Range
1 National Shooting Sports Foundation, “Environmental Aspects
of Construction and Management of Outdoor Shooting Ranges,”
June 1997.
1234567891011121314
Acidic Neutral Alkaline
Chapter II - Page II-2
BMP for Lead at Outdoor Shooting Ranges
arid regions. This is especially true of outdoor
ranges using “Steel Bullet Traps.”
Steel bullet traps build up a layer of lead residue;
these particles are extremely small and more
easily transported by rain/water. Also, the
smaller the particle, the quicker it will degrade. A
bullet trap needs to have a means to collect
contact water, or be covered to prevent water
from reaching it, and to minimize releases and
degradation.
Topography/Runoff Directions
The topography of your range impacts both the
ease of lead reclamation and the mobility of the
lead. For example, lead reclamation is more
successful at ranges where the shotfall zone is
relatively flat, since many lead reclamation
companies use heavy machinery that cannot
operate on slopes or steep hills.
Another important characteristic is the direction
in which your range topography slopes. During
and after periods of rain, stormwater runoff may
wash lead particles or lead compounds off the
range. If there are surface water bodies such as
lakes, rivers, or wetlands downgradient, the
potential for lead to adversely affect the
surrounding environment is even greater.
Therefore, it is important to identify and control
the direction of surface water runoff at your
range. BMPs for modifying and controlling runoff
are described in detail in Chapter III.
Groundwater
Groundwater depth should be considered
when developing a lead management plan
since the closer the groundwater is to the
surface, the greater the potential for
dissolved lead to reach it.
Vegetation
Vegetative ground covers can impact the
mobility of lead and lead compounds.
Vegetation absorbs rainwater, thereby reducing
2 Heavy annual rainfall is anything in excess of the average annual
rainfall, which for the northeast United States (e.g. New York, New
Jersey) is between 40 and 45 inches.
Lead reacts more readily and may become more
mobile under acidic (pH < 6) or higher alkaline
(pH>8) conditions. This means that spent lead
shot left in or on such soils may eventually break
down and contaminate underlying soil. In
moderately alkaline soils (pH 7 - 8.5), the lead
precipitates out of solution and binds to the soil.
This “binding” effect prevents the lead from
migrating to the subsurface. In general, soils in
the eastern part of the United States tend to be
acidic, whereas western soils tend to be more
alkaline.
Soil Physical Characteristics
The migration rate of specific lead compounds is
affected by the physical characteristics of soil.
For example, dense soils, consisting of heavy
clays, will prevent the lead compound from
moving quickly through the subsurface. Any
“free” lead ions become attached to clay
particles, with this bond helping to prevent
migration. However, with denser soils, the
amount of surface runoff increases.
Although clay soils inhibit migration, lead
reclamation by contemporary removal
machinery tends to be more difficult in clayey
conditions. Clayey soils tend to clog the
screens and “bind” with shot and bullets. This
situation may require additional traditional
screening, or perhaps screening using water to
enhance separation.
In contrast, sandy soils or gravel may not
impede migration because the open pores of
these soils allow lead compounds to percolate
quickly. Fortunately, lead reclamation activities
are more easily conducted in sandy soils. With
this in mind, ranges located in sandy soils
should remove lead more frequently.
Annual Precipitation
One of the most important factors that influences
lead degradation (i.e., chemical reactions) and
migration is precipitation. Water, most often in
the form of rain, provides the means by which
lead is transported. In general, ranges located in
areas with high annual/seasonal rainfall2 have a
higher risk of lead migration than those located in
Chapter II - Page II-3
BMP for Lead at Outdoor Shooting Ranges
Table 2-1 – Common Physical Characteristics at Ranges – Potential Risks
and Benefits Associated with Range Operations
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Chapter II - Page II-4
BMP for Lead at Outdoor Shooting Ranges
Shooting Direction and Patterns
Shooting directions and patterns are
important to consider when determining the
effectiveness of bullet containment devices.
For example, many bullet traps are effective in
containing bullets fired from specific directions.
It is vital that you utilize bullet containment
devices that match your range’s specific
shooting patterns and manufacturers
specifications. Understanding the shooting
direction and patterns will also help to correctly
identify the shotfall zone at trap and skeet
ranges.
Shooting into Water Bodies
Shooting into water bodies or wetlands
should not occur. Besides the environmental
impacts discussed previously, the introduction of
lead to surface water bodies will likely cause a
range to be susceptible to litigation and/or
governmental action. Shooting into water bodies
or wetlands is NOT an option for ranges that
want to survive in the future.
Range Life Expectancy and Closure
The life span of your range may be impacted by
many factors, including financial and
environmental issues, noise, and encroachment
on residential areas. If your range is slated for
closure, contact your local state or EPA
representatives for guidance.
2.3 Planning a New Range
As discussed in the previous sections, site
characteristics and operational aspects affect
lead migration, degradation and reclamation
activities at ranges. If you are planning on
opening a new range, you should select and/
or design a site in consideration of the
factors discussed in this manual. This will
allow you to minimize the potential of lead
impacting your site or adjacent properties. A
new range owner has the advantage of being
able to design a successful lead management
program in full consideration of the site
characteristics and recommended BMPs. This
advanced understanding of operational aspects
the time that the lead is in contact with water.
Vegetation also slows down surface water
runoff, preventing the lead from migrating off-site.
However, excessively wooded areas (such as
those often used for sporting clay ranges) inhibit
lead reclamation by making the soils
inaccessible to some large, lead-removal
machinery. Understanding the type,
concentration and variety of vegetation on your
range is necessary for developing your lead
management program and implementing BMPs
at your range.
Accessibility
Accessibility to shotfall zones and backstops
is extremely important for lead reclamation
activities. A range that is not accessible to
reclamation equipment will have difficulty
implementing lead reclamation practices.
2.2 Operational Aspects
Operating practices can have a great affect on
the volume and dispersion of lead at your range.
Lead Volume
Keeping records of the number of rounds
fired over time at your range is important.
The number of rounds fired provides a realistic
estimate of the quantity of lead available for
reclamation. This information helps to determine
when reclamation is necessary in order to
prevent accumulation of excess amounts of
lead, thereby decreasing the potential for the
lead to migrate off-site.
Size of Shot/Bullets
Knowledge of the size shot/bullets used on
your range may be helpful. Lead reclamation
companies generally use physical screening
techniques to separate lead shot and bullets
from soil. These screens come in a variety of
sizes. Knowing what size shot/bullets have
been used at your range will allow the reclaimer
to maximize the yield of lead shot/bullets at your
range.
Chapter II - Page II-5
BMP for Lead at Outdoor Shooting Ranges
and requirements will allow you to minimize the
potential for lead migration prior to opening.
The most important site selection criteria to
consider when selecting a new range
location include: topography; surface water
flow patterns; and depth to groundwater. If
possible, ranges should be developed on flat
terrain, as it facilitates reclamation and reduces
the chance of off-site migration due to surface
water runoff as compared with highly sloped
terrain. When considering a prospective location
for a range, ask yourself: What is the direction of
surface water runoff? Does the site drain to
surface water (e.g., streams, rivers) on-site?
Off-site? Can the range design be modified to
minimize potential runoff? Is reclaimation
equipment accessible to the area to clean the
range?
By selecting an appropriate location and
designing a lead management program in
consideration of site characteristics, new
shooting ranges can be developed to
minimize the potential for lead
contamination. Other important site
characteristics can be modified. For example, a
new shotgun range can be designed to
concentrate the shotfall area, vegetation can be
added or altered, and the most advantageous
shooting direction can be selected. These
modifications are BMPs, and are discussed in
further detail in Chapter III.
This page intentionally left blank
Chapter III - Page III-1
BMP for Lead at Outdoor Shooting Ranges
Figure 3-1 – 4 Steps to Build a Successful Lead Management Program Utilizing a Variety of BMPs
Chapter III:
Best Management Practices
(BMPs) For Outdoor Ranges
3.0 Background
To operate an outdoor range that is
environmentally protective requires
implementing an integrated lead management
program, which incorporates a variety of
appropriate BMPs. These BMPs create a four
step approach to lead management:
Step 1 - Control and contain lead bullets
and bullet fragments
Step 2 - Prevent migration of lead to the
subsurface and surrounding surface
water bodies
Step 3 - Remove the lead from the range
and recycle
Step 4 - Documenting activities and
keeping records
An effective lead management program requires
implementing and evaluating BMPs from each
of the four steps identified above and illustrated
as Figure 3-1. The BMPs discussed in Sections
3.1 and 3.2 should not be considered
alternatives to lead reclamation, but rather
practices that should be followed between lead
reclamation events.
It is important to note that the cost and
complexity of these BMPs vary significantly. It is
your range’s individual characteristics that
will determine which BMPs should be
implemented. The specific BMPs are described
more fully below.
3.1 Bullet and Shot Containment
Techniques (Step 1)
3.1.1 Bullet Containment
Knowing where spent lead is allows the
appropriate BMP to be used. The single
most effective BMP for managing lead in
these areas is by bullet containment.
Owners/operators should employ a
containment system that allows for the
maximum containment of lead on-site. The
containment systems mentioned in this section
are for reference only. Each containment design
for a range is site specific. Each owner/operator
must look at the various factors in determining
which containment system is best for his or her
range. Some factors include: overhead, cost of
installation, maintenance (e.g., creation of lead
dust from steel containment systems). Range
owner/operators should consult with various
contractors to determine which containment
system is best for their range.
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BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-2
1. National Rifle Association, “The NRA Range Source
Book: A Guide to Planning and Construction,” June
1998
This section discusses BMPs for controlling
spent lead bullets and fragments in a
“controlled” and well-defined area behind the
target area. Containing bullets and bullet
fragments is critical to successfully managing
lead.
There are a variety of containment device
options available that serve as BMPs to control
lead. The principle behind all of them is trapping
and containing the actual bullet. They include:
Earthen Berms and Backstops
Sand Traps
Steel Traps
Lamella or Rubber Granule Traps
Shock Absorbing Concrete
For each type of trap, design variations have
been developed to fit the specific needs of an
individual range. Below are discussions of each
general category of trap. Some bullet
containment devices are so comprehensive that
they virtually eliminate lead’s contact with the
environment.
However, it is important to discuss all types of
bullet containment devices because they are
part of comprehensive BMPs for managing lead
at rifle and pistol ranges.
EPA does not endorse any bullet containment
design as being “better” than another. Different
containment designs attempt to eliminate lead’s
contact with the environment, however,
additional BMPs may be required for lead
management.
EPA recommends that you discuss your
range’s bullet containment needs with a
variety of vendors before deciding what type
of containment device to use. This manual
does identify the possible advantages and
disadvantages associated with each
containment device in Table 3-1, at the back of
this chapter.
Earthen Berms and Backstops
Perhaps the most common bullet containment
system at rifle and pistol ranges is the earthen
backstop (earthen material, i.e., sand, soil, etc.,
which is located directly behind the targets).
The earthen backstop is generally between 15
and 20 feet high with a recommended slope as
steep as possible1. In many instances,
backstops may be naturally occurring hillsides.
When using an earthen berm or backstop,
ensure that the uppermost layer (to a depth of
one to two feet) exposed to the shooting activity
is free of large rocks and other debris. These
materials tend to increase ricochet and bullet
fragmentation, which will, in turn, make lead
reclamation activities more difficult, not to
mention possible safety issues.
Removal of lead from earthen backstops may
require lengthy reclamation (see Section 3.3) of
the soil to remove the lead. Continued use of
the backstop without removing the lead may
result in increased ricochet of bullets and
fragments. In addition, the backstop may lose
its slope integrity because of “impact pockets”
that develop. Once the lead has been removed
from the earthen backstop, the soil can be
placed back on the range and used again.
Adding lime and phosphate during the rebuilding
process is recommended as appropriate (see
Section 3.2). However, other bullet containment
techniques, including those listed below, should
be considered prior to reestablishing an earthen
backstop.
Sand Traps
A variation of the earthen backstop is the sand
trap. Sand traps range from those that are
simply mounds of sand or soil located directly
behind the bullet targets, which serve as
backstops to a sand trap that employs a system
designed to contain, collect and control lead and
contact water. This sand trap uses a grade of
sand that is ballistically acceptable. Regular
maintenance must be performed to remove
larger particles (bullets) from the impact area.
These traps are placed so that bullets fired
across the range pass through the targets and
become embedded in the sand. These traps
are typically 15 to 20 feet high with a slope as
Chapter III - Page III-3
BMP for Lead at Outdoor Shooting Ranges
steep as possible. The most important design
criterion for these traps is that the uppermost
layer (to a depth of 1 to 2 feet) be free of large
rocks and other debris to reduce ricochet and
bullet fragmentation, and to facilitate reclamation
efforts. There may also be an impermeable
layer (e.g., clay or liner) under the sand to
prevent lead from contacting the soil underlaying
the trap.
Sand traps come in various designs and levels
of complexity. The sand trap may be ballistic
grade sand contained in a high backstop, or a
more complex “Pit and Plate” system. The Pit
and Plate system uses an angled, steel
deflection plate cover that helps to direct bullets
and bullet fragments to the top layer of sand
only. Some of the more sophisticated sand
traps incorporate lead recovery devices.
However, the Pit and Plate may increase the
surface-to-mass ratio of the bullet splatter and,
therefore, may increase environmental risk of
lead migration.
Regardless of the type of sand trap that is used,
the traps become saturated with bullets/bullet
fragments. Once this happens, the sand must
be sifted (see Section 3.3) to remove the bullets.
The recovered bullets can then be sold to a lead
recycler (this is discussed in more detail later in
the chapter). After sifting, the sand can be
returned to the trap. Continued use of the trap,
without removing the lead, may result in an
increased risk of ricocheting off the backstop
and thus creating an increased safety hazard.
Furthermore, the sand trap will become unstable
over time. Sand traps may be located over an
impermeable liner, to prevent lead from
contacting soil underlying the trap. This will
provide additional protection to soil and
groundwater.
Steel Traps
Steel traps are located directly behind the
targets so that expended bullets, along with
bullet particles, are directed into some form of
deceleration chamber. Once inside the
chamber, the bullets decelerate until the bullets/
bullet particles fall into collection trays at the
bottom of the deceleration chamber. When the
trap is full, or on a more frequent basis, the spent
lead can easily be reclaimed for recycling.
With some steel traps, expended lead bullets
may not come in direct contact with soils,
thereby possibly minimizing lead’s contact with
the environment. Consequently, the need for
other BMPs (e.g., lime spreading, and/or
engineering controls), such as those required at
ranges with unlined earthen backstops or
unlined sand traps, may be avoided if this trap
design is selected for the range’s bullet
containment device. In addition, bullet removal
is somewhat easier than from a sand trap, and
may only require emptying the bucket or tray
containing the bullets and/or bullet fragments.
However, an increase of lead dust and
fragmented lead may be an additional
environmental concern. Therefore,
understanding the amount of lead dust and
fragments is important to a successful lead
management program. Also, some steel trap
designs are not intended for shooting at different
angles, therefore limiting the shooter to shooting
straight on (no action shooting).
As with sand traps, steel traps vary in design
and complexity. For example, the Escalator
Trap has an upward sloping deflection plate that
directs bullets into a spiral containment area at
the top. The Vertical Swirl Trap is a modular,
free standing trap with four steel plates that
funnel the bullets into a vertical aperture in
which they spin, decelerate, and become
trapped in a bullet collection container. The Wet
Passive Bullet Trap is equipped with steel
deflection plates that slope both upward and
downward. The upwardly sloped deflection
plate is covered with an oil/water mixture to help
reduce the occurrence of ricochet and bullet
fragmentation. The bullet follows its own path in
the round deceleration chamber for bullet
recycling.
Lamella and Rubber Granule Traps
The Lamella Trap uses tightly-hanging, vertical
strips of rubber with a steel backing to stop
bullets. This trap is located directly behind the
targets and, in many cases, the targets may
actually be mounted to the trap. Lead removal
BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-4
requires mining the bullets from the rubber. The
Rubber Granule Trap uses shredded rubber
granules, housed between a solid rubber front
and a steel backing, to stop bullets once they
pass through the target. For both traps, the
bullets remain intact, thus eliminating lead dust
and preventing lead and jacket back splatter.
Depending on the design of the rubber trap, the
bullet either remains embedded in the rubber
strip or falls to the bottom of the trap, from which
the bullets are removed for recycling.
These traps, when properly installed, are
intended to increase safety by decreasing the
occurrence of back splatter and eliminating the
introduction of the lead dust into the air and
ground. However, there are several concerns
over their use, since they may:
require additional maintenance;
in some cases, present a fire threat under
extremely high volume use (due to heat from
friction created upon bullet impact);
not withstand weather elements over the
long term; and
cause the rubber particles to melt to the lead
bullets, making reclamation more difficult.
With the availability of fire-resistant rubber and
gels (see Appendix A), these issues are becom-
ing less of a concern than in earlier models.
Shock Absorbing Concrete
In addition to the bullet containment devices
discussed above, there are new designs and
innovations continually being developed. One of
these innovative bullet containment devices is
Shock Absorbing Concrete (SACON). SACON,
which has been used as a bullet containment
device since the 1980s and was extensively
field tested by the military, has become
commercially available in the past several years
as a backstop material for small arms ranges.
For conventional rifle and pistol ranges, SACON
may provide a means to easily reclaim lead.
Additionally, crushed, lead-free SACON can be
recycled (recasted) after bullet fragments have
been removed by adding it to other concrete
mixtures for use as sidewalks, curbs, etc.
3.1.2 Shot Containment
Reducing the Shotfall Zone
Unlike rifle and pistol ranges, the area impacted
by lead shot fired at trap, skeet and sporting
clays ranges is spread out and remains primarily
on the surface. Knowing where spent lead is
allows the appropriate BMP to be used. The
single most effective BMP for managing lead
in these areas is reducing shotfall zones.
Concentrating the lead shot in a smaller area by
modifying the shooting direction facilitates lead
management by providing a smaller and more
dense area of lead to both manage in-place and
reclaim, thereby making the management and
reclamation process simpler and more effective.
Sporting Clays Courses
Technologies have been developed to assist in
reducing the range size of trap and skeet, and
sporting clays facilities. The National Sporting
Clays Association (NSCA) supports and
promotes the Five-Stand Sporting Clays
compact course design for shooting sporting
clay targets, invented by Raymond Forman of
Clay-Sport International, Cochrane, Alberta,
Canada. The targets are directed over a smaller
area than in English Style Sporting Clays
(conventional sporting clays). It was originally
designed to be overlaid on a conventional trap or
skeet field and to be an alternative to earlier
designs, which cover a much larger area.
Another design, known as the National Rifle
Association (NRA) Clays, is a portable target
throwing unit which concentrates 15 rail-
mounted machines on a two-story flatbed trailer.
The NRA has also developed “compact
sporting,” which is specifically for sporting clay
facilities. This practice alters the angle that the
target is thrown to concentrate the shotfall zone.
Skeet Fields
The typical single skeet field has a shotfall zone
that is fan-shaped. For skeet fields with multiple
stands side-by-side, the shotfall zones would
overlap creating a shotfall zone that has a
concentration of shot near the center of the fan.
Chapter III - Page III-5
BMP for Lead at Outdoor Shooting Ranges
2 National Shooting Sports Foundation, “Environ-
mental Aspects of Construction and Management of
Outdoor Shooting Ranges,” June 1997
Trap Fields
One way to reduce the shotfall zone at trap
fields is to build the fields at an angle to one
another. This will make the shape of the
shooting dispersal pattern smaller and more
concentrated. However, if you do decide to
choose this option, be aware of safety issues
when designing the overlapping shotfall zones.
For a range with only one trap field, one way to
minimize the shotfall zone is to keep trap
machines set in as few holes as possible (e.g.,
the number two or three hole setting). This
reduces the area of lead concentration by
limiting the angles for pigeon throwing, and
therefore the area for lead shot fall. However,
when two or more trap fields are positioned side
by side, the shotfall zone will be continuous
regardless of the “hole” setting.
Shot Curtains
Another method to consider for concentrating
lead shot is the use of a shot curtain. This
device is emerging as a potentially effective tool
to keep lead shot out of selected areas of the
range and, thereby, reduce the size of the
shotfall zone and corresponding cost of
reclamation. Different designs and material have
been utilized in shot curtains and a number are
in operation. The effectiveness of shot curtains
is site specific and their long term viability and
expense have yet to be fully determined.
3.2 BMPs to Prevent Lead
Migration (Step 2)
This section discusses BMPs for preventing lead
migration. These BMPs include:
Monitoring and adjusting soil pH
Immobilizing lead
Controlling runoff
These BMPs are important for all outdoor
ranges.
3.2.1 Monitoring and Adjusting Soil pH and
Binding Lead
Lime Addition
The BMP for monitoring and adjusting soil pH is
an important range program that can effect lead
migration. Of particular concern are soils with
low pH values (i.e., acidic conditions), because
lead mobility increases in acidic conditions since
the acid of the soils contributes to the lead break
down. The ideal soil pH value for shooting
ranges is between 6.5 and 8.5. This BMP is
important because many soils in the eastern
United States have pH values lower than 6.2
To determine the pH of your soil, purchase a pH
meter at a lawn and garden center. The pH
meters are relatively inexpensive but valuable
tools in the management of lead at your range.
If the soil pH is determined to be below 6, the
pH should be raised by spreading lime. It is
recommended that the pH be checked
annually.
One way to control lead migration is by
spreading lime around the earthen backstops,
sand traps, trap and skeet shotfall zones,
sporting clays courses and any other areas
where the bullets/shots or lead fragments/dust
accumulate. For example, lead mobilized in
rainwater from the lead that spatters in front of
backstops after bullet impacts can be effectively
controlled by extending a limestone sand layer
out about 15 feet in front of the backstop.
Likewise, spreading lime over the shotfall zone
will help to raise the pH of the very top soil layer
to a pH closer to ideal levels and reduce the
migration potential of lead. This is an easy, low
cost method. Spreading lime neutralizes the
acidic soils, thus minimizing the potential for the
lead to degrade. Lime can be easily spread by
using a lawn fertilizer drop spreader available at
any lawn and garden center.
Smaller forms of limestone (powdered,
pelletized, and granular) are better suited
BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-6
Table 3-2 – Calculating Weight of Lime to Increase Soil pH Values*
* Lime requirements stated as pounds of lime/100 square foot of problem area
for clay soils in temperate climates (i.e., Mid-Atlantic/Northeast US).
because they dissolve and enter the soil more
quickly then larger forms. However, the smaller
forms of lime must be replenished more often.
Conversely, limestone rock dissolves more
slowly but does not need to be replenished as
often. The larger rock form is better suited for
drainage ditches, where it can decrease lead
mobility by raising the pH of the storm water
runoff.
Another way to control lead migration in earthen
backstops is to break the capillarity within the
base of the backstop. Most porosity in the soil
material used in backstop is of capillary size,
and, as a result, water is pulled upward into a
capillary fringe within the base of the backstop.
The height to which the water will rise in an
earthen backstop depends on the soil material in
the backstop. Water will rise more then 6 feet in
clay, 3.3 feet in silt, 1.3 feet in fine sand, 5
inches in coarse sand, and only 2 inches in
gravel.
Because of capillarity, the spent bullets may be
in contact with acidic rainwater for a longer
period of time, hence more lead is dissolved.
Breaking the capillarity by adding a layer of
limestone or gravel to the base of the backstop
should reduce the rate of deterioration of spent
bullets, the erosion of the backstop, and the
amount of lead going into solution in the water in
the backstop. Also, any lead dissolved should
precipitate out of solution as the acids are
neutralized and the pH raised from the water
passing through and reacting with the limestone.
Lime spreading is an especially important
method for implementing this BMP at sporting
clays ranges where heavily wooded areas are
less accessible to conventional lead removal
equipment. These types of ranges also tend to
have more detritus (e.g., leaves, twigs, etc.) on
the ground, which can increase soil acidity as
they decompose. In these areas, semiannual
monitoring of the soil pH levels is
suggested.
Spreading bags of 50 pounds (at ranges with
sandy soils) or 100 pounds (at ranges with
clayey soils) per 1,000 square feet of range will
raise the pH approximately one pH unit for a
period of between one and four years,
respectively. The market price of lime in either
the granular or pelletized form commonly ranges
from approximately $2.00 to $4.00 per fifty pound
bag.
Table 3-2 provides information for raising pH
levels of clay soils in temperate climates (i.e.,
Mid-Atlantic/Northeast). Additional information
on the amount of lime to apply may also be
found on the bags of the purchased lime and/or
from the local lawn and garden center. It should
be noted that if the soil pH is below 4.5, the
addition of lime may only raise the soil pH to
approximately 5. In this situation, other BMPs
should be used as well. If the soil pH is above
the ideal range upper value (8.5), do not add
lime. Adding lime to a soil of this pH could result
in mobilization of the lead. Lime spreading may
be done at anytime during the year, except
when the ground is frozen.
Additionally, it is important to remember to
monitor the soil pH annually, as the
effectiveness of the lime decreases over time.
Additional routine applications will be necessary
throughout the life span of most ranges.
HptnerruC
0.4 3.4 5.4 8.4 0.5 5.5 0.6 5.6
deriseD
Hp
0.6-0.54111853---
5.8-5.6 ---0271117-
Chapter III - Page III-7
BMP for Lead at Outdoor Shooting Ranges
Phosphate Addition
In addition to lime spreading, another way to
control lead migration is phosphate spreading.
This method is recommended where lead is
widely dispersed in range soils, a range is
closing, or there is a high potential for vertical
lead transport to groundwater (e.g., low soil pH,
shallow water table). Under these
circumstances, range soils may benefit from
phosphate treatment. Unlike lime spreading, the
main purpose of phosphate spreading is not to
adjust soil pH but to bind the lead particles. This
process also decreases the potential amount of
lead that can migrate off-site or into the
subsurface. Phosphate spreading can be done
either separately or in conjunction with lime
spreading. Generally, 15 to 20 pounds of
phosphate per 1,000 square feet will effectively
control the lead.
Phosphate spreading is especially
recommended for sporting clays ranges and
those parts of ranges not easily accessible by
reclamation equipment. Phosphate spreading
should be repeated frequently during the range’s
lifetime. See pilot testing under “Other Ways to
Bind Lead” below for proper frequency for
replacing phosphate.
You can purchase phosphate either in its pure
form, as phosphate rock, or as lawn fertilizer.
The average lawn fertilizer costs approximately
$7.00 per 40 pound bag. If you purchase lawn
fertilizer, remember to check the bag for the
actual percentage of phosphate. Most fertilizers
contain 25% phosphate, so that if you purchase
a 40 pound bag of fertilizer that contains 25%
phosphate (i.e., 10 pounds of phosphate) you
will need to spread 80 pounds of fertilizer per
1,000 square feet of the backstop. A typical
fertilizer drop spreader can be used for
distributing the phosphate. Like lime, phosphate
should not be spread when the ground is frozen.
In addition, it is not advised to use phosphate
near water bodies since it contributes to algal
blooms. Rock phosphate is a better choice if
water is nearby.
Other Ways to Bind Lead
Although it may be possible to minimize lead’s
mobility by spreading fertilizers that contain
phosphate at impacted areas of the range, a
more comprehensive procedure for immobilizing
leachable lead in soils, by using pure phosphate
in rock form or a ground phosphate rock [Triple
Super Phosphate (TSP)], was developed and
patented by the U.S. EPA/Ohio State University
Research Foundation and RHEOX, Inc. This
procedure used a three step approach to
minimize lead’s mobility. The first step was to
identify the boundaries of the area of the range to
be treated. This included not only determining
the length and width of the range area, but also
the depth of lead within the area.
Depth was determined by taking sample cores
of the area, which also identified “hot spots”
where lead accumulation was greatest. Once
the area was identified, the second step was to
treat the area with TSP. Pure phosphate rock
was used rather then fertilizers, as this
phosphate is insoluble in water and will not
cause an increase in phosphate runoff.
In this step, pilot testing was conducted. Here,
various amounts (in increasing percentages by
weight) of TSP were added to the affected soil
areas, then the area was tested according to an
EPA test method that identified the amount of
leachable lead in a given soil sample. This test
is called the Toxicity Characteristic Leaching
Procedure, or TCLP. Separate TCLP testing of
the range’s hot spots was conducted.
Upon completion of the pilot testing, which
determined the amount of TSP needed at the
range, the third step was to begin actual
treatment of the range. Where the depth of the
lead accumulation was shallow (less than two
feet), then standard yard equipment, such as
tillers, seed/fertilizer spreaders, and plows were
used to mix TSP with the affected soil. Where
the affected area’s lead accumulation was
deeper than two feet, an auger was required to
mix the TSP with the affected soil. Random
testing of the range ensured the effectiveness of
the treatment level.
BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-8
3.2.2 Controlling Runoff
The BMPs for controlling soil erosion and
surface water runoff are important to preventing
lead from migrating off-site. There are two
factors that influence the amount of lead
transported off-site by surface water runoff: the
amount of lead fragments left on the range and
the velocity of the runoff.
The velocity of the water can successfully be
controlled at outdoor ranges by: (1) using
vegetative, organic, removable and/or
permanent ground covers; and (2) implementing
engineered controls which slow down surface
water runoff and prevent or minimize the
chances of lead migrating off-site. Bear in mind
that safety considerations and potential
ricochets need to be considered when
implementing any engineered controls.
Vegetative Ground Cover
Planting vegetative ground cover (such as
grass) is an important and easy erosion control
method. Vegetation provides several benefits
by minimizing the amount of lead that will run off
the land surface during heavy rainfall. It is
important to use a mixture of grass seeds to
ensure that the cover will last into the future (i.e.,
annual rye grass lasts one year and dies and
perennial rye grass lasts three to four years,
then dies off). Fescue grasses form useful mats
that are effective in controlling erosion.
Ground cover absorbs rainwater, which reduces
the amount of water the lead is in contact with,
as well as the time that the lead is in contact
with the water. Furthermore, the ground cover
will divert and slow down surface water runoff,
thus helping to prevent lead from migrating off-
site.
Grasses yield the greatest benefit at rifle and
pistol ranges where the bullet impact areas are
sloped, and water runoff and soil erosion may
be more likely. Specific recommendations are
to:
Utilize quick growing turf grass (such as
fescue and rye grass) for the grass covering
of backstops, which can be removed prior to
reclamation and replanted thereafter;
Avoid vegetation that attracts birds and other
wildlife to prevent potential ingestion of lead
by wildlife; and
Use grass to direct surface water drainage
away from the target area (e.g., planting
them at the top of the backstop or sand trap).
This will minimize the water’s contact with
lead bullet fragments, minimizing the
potential for lead migration.
Grass is not impermeable; however, it does slow
down the rate of flow and reduce the amount of
lead entering the soil via rainwater. Remember,
grass requires periodic maintenance (i.e.,
mowing) to maintain its effectiveness as well as
for aesthetic reasons.
Mulches and Compost
Mulches and composts can reduce the amount
of water that comes in contact with the lead
fragments. In addition, mulches and compost
contain hermic acid, which is a natural lead
chelating agent that actually sorbs lead out of
solution and reduces its mobility. At a minimum,
the material should be two inches thick. These
materials can be spread over any impacted area
and/or low lying areas where runoff and lead
may accumulate. Like vegetative covers,
organic surface covers are not impermeable. In
addition, the organic material needs periodic
replacement to maintain effectiveness and
aesthetic integrity. Furthermore, these materials
should be removed prior to any lead removal
event, as they may impede sifting or screening.
Note that these materials tend to be acidic
(especially during decomposition), so, if low
pH is a concern at your range, this option
may not be appropriate. Again, however,
lime may be used to control pH (see Section
3.1.1)
Surface Covers
Removable Surface Covers
Removable surface covers may be effective at
outdoor trap and skeet ranges. In this case,
impermeable materials (e.g., plastic liners) are
Chapter III - Page III-9
BMP for Lead at Outdoor Shooting Ranges
placed over the shotfall zone during non-use
periods. This provides the range with two
benefits during periods of rainfall: (1) the shotfall
zone is protected from erosion; and (2) the spent
lead shot is contained in the shotfall zone and
does not come in contact with rainwater.
Permanent Surface Covers
For outdoor rifle and pistol ranges, impact
backstops and target areas can also be covered
with roofed covers or other permanent covers to
prevent rainwater from contacting berms.
However, this method may be less desirable
because of the cost to install the roof, which
must be carefully designed to avoid safety
issues with ricochets, etc.
For shotgun and other ranges, synthetic liners
(e.g., asphalt, AstroturfTM, rubber, other synthetic
liners) can also be used beneath the shotfall
zone to effectively prevent rainwater or runoff
from filtering through lead and lead
contaminated soil. Synthetic liners will generate
increased runoff, which must be managed,
however. No single type of liner is suitable for all
situations based on site characteristics.
Therefore, liners must be chosen on a site-
specific basis, bearing in mind the site’s unique
characteristics, such as soil type, pH level,
rainfall intensity, organic content of soil, and
surface water drainage patterns.
Engineered Runoff Controls
Runoff control may be of greatest concern when
a range is located in an area of heavy annual
rainfall because of an increased risk of lead
migration due to heavy rainfall events. A “hard”
engineered runoff control may be needed in this
situation. A heavy rainfall event is defined as
rainfall that occurs at such a rate that it cannot
be absorbed into the ground and causes an
increase in the volume and velocity of surface
runoff. The impacts of rainfall are greater in
rolling or sloped terrain (increases velocity of
runoff) or where surface water bodies are
located on, or immediately adjacent to, the
range.
Examples of “hard” controls include:
Filter beds
Containment Traps and Detention Ponds
Dams and Dikes
Ground Contouring.
Designing and implementing these “hard”
engineering controls may require the assistance
of a licensed professional civil engineer. They
are included in this manual to offer the reader a
general understanding of these BMP options.
However, this manual does not offer specific
instructions for construction and operation of
these controls. For information about designing
and implementing any of these controls, or
assistance with other range design questions,
contact a licensed professional civil engineer
having applicable experience or the NRA Range
Department, at (800) 672-3888, ext. 1417. The
National Sports Shooting Foundation (NSSF)
may be contacted at (203) 426-1320 for specific
references regarding the use and design of
these controls.
Filter Beds
Filter beds are engineering controls built into an
outdoor range to collect and filter surface water
runoff from the target range. The collected
runoff water is routed to a filtering system, which
screens out larger lead particles, raises the pH
of the water (thus reducing the potential for
further lead dissolution), and drains the water
from the range area. This technique may not
completely prevent lead from entering the
subsurface, since lead bullets, fragments and
large particles may still remain on the range.
Filter beds should be established at the base of
the backstop (see Figure 3-2). In addition to
mitigating off-site migration, the filter beds work
to raise the pH of the rainwater, which has fallen
on the target range, to reduce lead dissolution,
and to strain small lead particles out of the
rainwater. The filters typically consist of two
layers: a fine-grained sand bed underlain by
limestone gravel or other neutralization material.
By design, the backstops and berms direct the
runoff so that it drains from the range to the
filters. The collected water then soaks through
the top sand layer into the neutralization material,
BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-10
Figure 3-2 – Sample Filter Bed System (Adapted from Proceedings for National Shooting, Range Symposium,
October 17-19, 1993, North American Hunting Club and Wildlife Forever)
which raises the pH of the filtrate. The lead
particles in the rainwater are collected on the
sand, while the pH-adjusted water drains
through the filter to a perforated drainage pipe
located within the limestone gravel.
Filter beds are designed to capture fine particles
of lead transported in surface water runoff.
They are not designed to capture bullets. The
operation and maintenance requirements of filter
beds are minimal. Maintenance activity is limited
to periodic removal of debris (such as litter,
leaves, etc.) and occasional replenishment of
the limestone.
The use of filter beds is most effective on sites
with open, rolling terrain where surface water
runoff is directed to them. At existing rifle and
pistol ranges, a limited system of trenches and
filters can be installed at the base of natural soil
backstops or at natural drainage depressions.
Containment Traps and Detention Ponds
Containment traps and detention ponds are
designed to settle out lead particles during
heavy rainfall. Typically, they are depressions
or holes in the range’s drainage paths. Here,
the lead-containing runoff passes through the
trap or pond, allowing the lead bullet fragments
to settle out. Vegetative cover can be placed in
the drainage path to increase the effectiveness
of containment traps and ponds by further
reducing the velocity of runoff and allowing for
more lead fragments to settle from the runoff. It
is important to regularly collect the lead and send
this lead to a recycler.
Dams and Dikes
At shotgun ranges, dams and dikes can also be
used to reduce the velocity of surface water
runoff. Dams and dikes must be positioned
perpendicular to the direction of runoff to slow
the flow of surface water runoff. To accomplish
this, determine the direction of the range’s
surface water runoff. This will be particularly
obvious at ranges with sloped terrain. The dams
or dikes should be constructed using mounds of
dirt that are approximately a foot high. These
mounds should transect the entire range
perpendicular to the stormwater runoff direction.
These runoff controls are most important at
ranges at which off-site runoff is a potential
problem, such as ranges where the lead
accumulation areas are located upgradient of a
surface water body or an adjacent property.
Since lead particles are heavier than most other
suspended particles, slowing the velocity of
surface water runoff can reduce the amount of
lead transported in runoff.
Chapter III - Page III-11
BMP for Lead at Outdoor Shooting Ranges
Figure 3-3 – Examples of Common Lead Reclamation Equipment
Example of final separation device
(Patented Pneumatic Separation
Unit) used with a Shaker System.
Courtesy of MARCOR.
Example of shaker system.
Courtesy of National Range Recovery
Ground Contouring
Another mechanism to slow runoff and prevent
lead from being transported off site is ground
contouring. By altering drainage patterns, the
velocity of the runoff can be reduced.
Furthermore, in areas where pH is high
(resulting in a lower potential for lead
dissolution), the soil can be graded or aerated to
increase the infiltration rate of precipitation, so
that rainwater is more easily absorbed into the
soil. This slows down or prevents surface water
runoff and off-site migration. It should be
pointed out that this design, in effect, collects
lead in the surface soils. Therefore, range
operation and maintenance plans should include
lead reclamation as well as adjusting the pH, and
adding phosphate.
3.3 Lead Removal and Recycling
(Step 3)
To successfully minimize lead migration, the
most important BMP for lead management is
lead reclamation. Implementing a regular
reclamation program will allow you to avoid
expensive remediation and potential litigation
costs. Ranges in regions with high precipitation
and/or with acidic soil conditions may require
more frequent lead recovery since the potential
for lead migration is greater. In regions with little
precipitation and/or where the soil is somewhat
alkaline, spent bullets may be allowed to
accumulate on the soil for a longer time between
reclamation events. It should be noted that to
ensure that lead is not considered “discarded” or
“abandoned” on your range within the meaning
of the RCRA statute (i.e., a hazardous waste),
periodic lead removal activities should be
planned for and conducted. This typically
requires one or more of the following:
Hand Raking and Sifting
Screening
Vacuuming
Soil Washing (Wet Screening,
Gravity Separation, Pneumatic Separation)
These methods are discussed in detail below.
Figure 3-3 provides examples of common lead
reclamation equipment.
BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-12
Also, it is important to be aware that state
regulations may require that the material being
sent for recycling have a minimum lead content
in order to qualify as a scrap metal that can be
shipped under a bill of lading (i.e., exempt from
RCRA).
3.3.1 Hand Raking and Sifting
A simple BMP that can be done by club
members, particularly at small ranges, is raking
and/or sifting bullet fragments from the soil.
Sifting and raking activities should be
concentrated at the surface layer. This is a low-
technology and low-cost management
alternative for lead reclamation. Once collected,
the lead must be taken to a recycler or reused.
Arrangement with a recycler should be made
prior to collecting any spent lead to avoid having
to store the lead and avoid potential health,
safety and regulatory concerns associated with
storing lead.
At trap and skeet ranges, conducting sifting and
raking activities in the shot fall zone
(approximately 125 - 150 yards from the
shooting stations) will yield the most lead. For
sporting clay ranges, these activities should be
conducted around tree bases, where lead shot
tends to collect. Basically, the process consists
of raking with a yard rake the topsoil in the shot
fall areas into piles, as if you were raking leaves,
removing any large debris (e.g., rocks, twigs,
leaves, etc.), and then sifting the soil using
screens.
Once the soil has been raked and collected,
pass it through a standard 3/16 inch screen to
remove the large particles. This process will
allow the lead shot sized particles to pass
through the screen. The sifted material (those
not captured by the 3/16 inch screen) should be
passed through a 5/100 inch screen to capture
the lead and lead fragments. This process will
also allow sand and other small sediment to
pass through the screen. Screens can be
purchased at many local hardware stores. The
screens should be mounted on a frame for
support. The frame size will vary based on the
technique used by each range. For example, if
one person is holding the framed screen, it may
be better to use a smaller frame (2 feet by 2 feet)
whereas, if several people are holding the
framed screen, it can be larger.
Raking and sifting can be performed by club
members on a volunteer basis. Some clubs
provide incentives, such as reduced fees, to
members who assist with the lead removal
process. Other clubs have hired college
students during the summer. A number of small
clubs have found that reloaders will volunteer to
rake in exchange for collected shot.
Hand sifting and raking are cost effective lead
removal techniques for small ranges, or low
shooting volume ranges. However, these
techniques may not be appropriate for situations
in which there is a large volume of lead on the
range. In this instance, reclamation machinery
may be more appropriate.
Note: Those conducting the hand raking and
sifting reclamation at ranges should protect
themselves from exposure to lead. Proper
protective gear and breathing apparatus
should be worn. The Occupational Safety
and Health Administration (OSHA) or an
appropriate health professional should be
contacted to learn about proper protection.
3.3.2 Purchasing/Renting Mechanical
Separation Machinery
Reclamation equipment may be rented from
local equipment rental services. One type of
machine that it may be possible to rent for lead
shot reclamation is known as a screening
machine (also referred to as a mobile shaker,
gravel sizer, or potato sizer). This device uses a
series of stacked vibrating screens (usually two
screens) of different mesh sizes and allows the
user to sift the lead shot-containing soil
[gathered by hand raking, sweeping, or
vacuuming (discussed above)]. The uppermost
screen (approximately 3/16 inch mesh) collects
larger than lead shot particles, and allows the
smaller particles to pass through to the second
screen. The second screen (approximately 5/
100 inch mesh) captures lead shot, while
allowing smaller particles to pass through to the
ground. The lead shot is then conveyed to a
Chapter III - Page III-13
BMP for Lead at Outdoor Shooting Ranges
container such as a five gallon bucket. In the
Northeastern United States, the typical rental
cost for this equipment is between $500 and
$4,500 a week, depending on the size shaker
desired. It may be possible to get more
information on rentals for this type of equipment
from heavy equipment rental companies.
Another possible option is to rent a vacuum
system that will collect the lead shot-containing
soil from the range. Here, vacuuming takes the
place of hand raking or sweeping. A vacuum
machine is used to collect the lead shot-
containing soil. Once collected, the lead shot-
containing soil must be sifted through a
screening system (either a rental screening
machine, or a series of home made framed
screen sets). You may be able to obtain more
information about renting vacuums or
vacuuming services (e.g., it may include a
person to operate the machinery) from heavy
equipment rental companies.
Some clubs have found that performing their
own lead reclamation to be very time
consuming. Part of the reason these
reclamations took so long is that the soils were
wet. Reclamation is much easier under dry soil
conditions. For example, one club reclaimed
lead from their range using equipment they
modified themselves. Twenty-five tons of lead
were collected but the reclamation took over two
years. Another club took a year to reclaim 10
tons of lead. A more preferable option may be to
hire a reclamation company.
3.3.3 Hiring a Professional Reclamation
Company
Another option for lead removal is to hire a
professional reclaimer. Lead reclamation
companies claim to recover 75%-95% of the
lead in the soils. Generally, with reclamation
companies there is no minimum range size
requirement for lead reclamation. Concentration
of lead is more important than quantity spread
over a field, especially if it is a difficult range for
reclamation (e.g., hilly, rocky, a lot of clay in the
soil).
Please note that reclamation companies tend to
be in high demand — it may take over a year for
the company to start at your club. Therefore, it is
wise to plan ahead and make the call to the
reclamation company as early as possible.
Some reclamation companies require a site visit
to view the topography, the soil composition, and
amount of lead observed on the ground. During
the visit, some companies may even do a site
analysis to determine whether or not it is
feasible to reclaim. This analysis identifies the
location of lead, the expected recovery amount,
and the depth lead reaches into the soils.
3.3.4 Reclamation Activities
Using machinery to reclaim lead usually requires
that the area be clear of scrub vegetation.
Grass, mulch, or compost is generally removed
or destroyed during the reclamation process.
Some reclamation companies have no problem
beginning reclamation on a grassy field. Other
reclamation companies will remove grass before
or during reclamation (by burning it, if allowed
locally, leaving behind the lead shot), and still
others require that all vegetation be removed
before they arrive at the range. Some
companies will re-seed the area once the
reclamation is completed.
Since sporting clay ranges generally have many
trees, removal of vegetation as discussed above
may not directly apply to existing sporting clay
ranges. At these ranges, the focus is on
removing vegetative debris (i.e., fallen limbs,
tree bark, etc.) prior to reclamation. This may
include removing some trees to gain better
access with the reclamation machinery. Of
course, when designing a new sporting clay
range, steps to facilitate lead reclamation should
be taken into account. For example, less and
more widely spaced trees will facilitate lead
reclamation.
Reclamation companies use several types of
machinery to reclaim lead. Some companies
drive their separation machinery over the site.
The lead-laden soil is picked up, processed and
then returned to the ground after most of the lead
BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-14
is removed. Other companies scrape off the top
several inches of soil from the ground, using a
front-end loader to bring the soil/lead to
stationary reclamation machines, and then return
the soil to the field after reclamation. Many
companies till the top two to five inches of soil
and grass immediately prior to reclamation to
facilitate the process (some companies may
require this to be done prior to arrival on the
range).
Regardless of how it is collected, the actual
reclamation of the lead follows the same general
pattern. Most often, it is sifted through a series
of shaking screens. The lead and soil pass
through shaking screens (usually at least two
screens) of decreasing mesh (hole) size, with
the topmost screen having the largest mesh.
This part of the reclamation machinery is usually
adapted from machinery used for potato or
gravel sizing.
Any soil/debris automatically screened out as
being too big or too small is either returned to
the field or re-screened to ensure no lead is
caught in the debris. This procedure is why
moist, clay soils are more difficult to reclaim.
The moist, clay soils can bind together into shot-
sized pellets producing more “product” for the
second part of the reclamation. The wet soils
can also clog the screens.
For some reclamation companies, their process
ends after sifting the soil and returning it to the
ground. However, some companies take
reclamation one step further. After screening,
the resulting lead, soil, and other lead-sized
particles enter a blowing system. Here the lead
shot is easily separated from the soil and other
debris by the blowing air. The lead is much
more dense than the soil and other lead-sized
debris so that it falls out first. Figure 3-3 depict
examples of actual lead reclamation machinery.
Some lead reclamation companies will perform
the reclamation during club off-hours so that
club activities are not interrupted. Additionally,
some perform the reclamation on a field-by-field
basis, to minimize any disruptions to club
activities. However, others companies require
the club to shut down during the reclamation.
Reclamation time varies depending on weather,
site accessibility, range size, and number of
personnel assigned to perform the reclamation.
Reclamation activities may generate dust,
especially in drier western locations. To prevent
or minimize dust from traveling off the range and
causing complaints from neighbors, reclamation
activities generating dust should only be
conducted during periods of no wind. In
addition, such activities should be completed as
quickly as possible.
Vacuuming
For ranges that are located on hilly, rocky, and/or
densely vegetated terrain, several reclamation
companies employ a vacuum system that
collects the lead shot (and soil and other
detritus). The resulting mix is then placed into
the reclamation machinery discussed above.
This method is especially effective for sporting
clay ranges where lead shot tends to pile up
around tree bases.
Vacuuming has traditionally been used for
removal of lead shot from trap, skeet and
sporting clay ranges. Another way to apply this
method involves removing the top layer of an
earthen backstop or sand trap with shovels. It is
then spread thinly over an impermeable material
such as plywood. A vacuuming device is then
used to collect the materials that are lighter than
lead (e.g., sand or soil), while leaving behind the
heavier materials (i.e., lead bullets/shots and
fragments). The soil can then be returned to the
range. This process is most efficient for dry,
sandy soils without a lot of organic material. A
more recent innovation is the use of a high
suction vacuum. This vacuum itself does not
have to be moved about, since a very long hose
(up to 600 feet) is used to move in and around
trees during the collection of lead shot at trap
and skeet ranges.
Soil Washing (Physical and Gravity
Separation)
Soil washing is a proven technology and another
lead reclamation method used by some
reclaimers to separate the lead particles from
Chapter III - Page III-15
BMP for Lead at Outdoor Shooting Ranges
the soils. Soil washing is the separation of soils
into its constituent particles of gravel, sand, silt
and clay. Because of the much higher surface
area and surface binding properties of clay, most
lead contaminants tend to adhere to the clay
particles.
Soil washing, therefore, attempts to generate a
clean sand and gravel fraction by removing any
fines adhering to the larger soil particles and, if
necessary, to transfer contaminants bound to
the surface of the larger particles to the smaller
soil particles. Typically, the soils are first
excavated from the range and then mixed into a
water-based wash solution. The wet soil is then
separated using either wet screening or gravity
separation techniques. One benefit of this
system of reclamation is that it does not require
that soils be dry.
In addition, soil washing may be able to recover
all or almost all lead particles through a
combination of wet screen sizing and density
separation. This technique is an option for
remediation of a range being closed and may
compare favorably from an economic standpoint
with the disposal option.
Soils treated using this method have been
shown to be below 5 mg/L TCLP and to have up
to 99% of particulate lead removed. Treatment
costs are site specific, but can range from less
then $40 per ton (1999 levels) for simple
physical/gravity separation up to about $100 per
ton for processes involving leaching. Credits for
recycled lead help offset the treatment cost and
the cost of recycling any treatment sludges and
concentrated soil fines. Water used in soil
washing is from a closed loop system and
should only be disposed at completion of
cleanup. Experience shows the water to not be
a RCRA regulated hazardous waste, therefore
probably allowing disposal to a local wastewater
treatment plant.
Wet Screening
With this method, particles larger and smaller
than the surrounding soils are passed through a
series of large-mesh to small-mesh screens.
Each time the mixture passes through a screen,
the volume of the soil mixture is reduced. Large
particles such as lead shot/bullets and
fragments are screened out of the soil/wash
mixture early in the process and can be taken
off-site for recycling - allowing the soil to be
placed back on-site.
Gravity Separation
This technique can be used in cases where the
lead particles are the same size as surrounding
soil particles. The wet soil/wash mixture is
passed through equipment, which allows the
more dense materials (i.e., lead materials) to
settle to the bottom of unit and separate out of
the soil/wash mixture.
Pneumatic Separation
Pneumatic separation (see figure 3-3) is an
effective means to enhance the traditional
screening results. Traditional screening cannot
separate shot and bullets from other shot and
bullet sized material, i.e., rocks, stones, roots,
and various debris. A recycling facility considers
non-lead items as “contaminants” which
drastically reduces the value of the recycled
lead. Pneumatic separation utilizes an air
stream, and specific density analysis, to
effectively separate the shot/bullets from the
other shot/bullet sized material.
3.3.5 BMPs to Assist Lead Reclamation
and Recycling
There are several operational activities that
should be conducted throughout the year to
facilitate reclamation. The following is a
discussion of these activities.
Frequency of Lead Removal
It is important to perform lead removal at a
frequency appropriate for your site. The
frequency is dependent on several factors.
These include:
Number of rounds fired
Soil pH
Annual precipitation
Soil Type
Depth to groundwater.
BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-16
4. National Rifle Association, “Metallic “Bullets” lead
Deposits on Outdoor and Indoor Firing Ranges” 1991
Lead quantity, as estimated by the number of
rounds fired, is a factor in determining the
appropriate frequency of reclamation at ranges.
It also assists in determining the cost of
reclamation. One reclamation company
indicated that reclamation was most cost
effective when it contains at least 20 pounds of
lead per square foot of backstop. Another
source indicated that a minimum of 100,000
rounds per firing lane should be allowed before
lead reclamation occurs. This would ensure
good range operation and maintenance, while
minimizing the cost per quantity of lead
recovered.
For shotgun ranges, tracking the number of
targets thrown can help indicate when the lead
shot should be reclaimed. For example,
considering environmental issues, the
market for scrap lead and common cleanup
methods, one source indicated that when a
range has thrown at least 250,000 to 1,000,000
targets, depending on the shooting area,
reclamation of the lead shot is encouraged.
Another reclaimer indicated that if at least two
pounds of lead per square foot have
accumulated on the range, reclamation is
recommended.
Because the number of rounds fired is important
to know, establishing record keeping procedures
to monitor the number of rounds fired is
recommended. This can be accomplished by
maintaining logbooks and asking shooters to list
the number of rounds shot and the type/size of
shot/bullets they use. This should be done by
lane and by stand.
There are many ranges at which lead removal
has not occurred for many years. Many of these
ranges are used extensively. Such ranges are
especially good candidates for lead removal and
recycling. Subsequent removal frequency
depends on range use and environmental
factors. The NRA recommends a frequency of
one to five years for lead cleanup, even on
ranges with minimal use4. One possible
approach to reducing the cost of reclamation
more cost effective is for a number of ranges in
the same geographical area to work together in
organizing coordinated removals at their ranges.
This will reduce the reclaimer travel and
mobilization cost for each range.
Minimization of Vegetation
As discussed previously, vegetation is useful
both for controlling the amount of runoff and
erosion from the range and inhibiting lead
mobility. However, excessive or
unmaintained vegetative cover can interfere
with reclamation activities. For example, large
amounts of vegetation impedes the screening
and sifting processes used by many reclamation
companies. Therefore, prior to reclamation
activities, it is best to remove, reduce, or mow
excessive vegetation from the area. Once the
reclamation has been conducted, quick-growing
vegetation such as a rye/fescue grass mix
should be replanted. This process should be
repeated for each reclamation event.
In addition, heavily wooded areas may inhibit
lead reclamation because they are less
accessible by heavy reclamation machinery.
For ranges that are heavily wooded, it is
recommended that you minimize the vegetation
or modify the range design to allow lead
reclamation equipment access to the range.
Access to the impact area should be developed
to facilitate reclamation. Make sure that the
pathways do not present a safety risk.
Innovative Landscaping
Some new ranges are landscaping their ranges
to include a sand track (an area the size of the
shotfall zone that is only sand) located behind
some aesthetically pleasing shrubs. This allows
the spent shot to concentrate on the sand,
making it very easy to perform reclamation
because there is no interference by vegetation.
Selecting a Lead Reclaimer
In ensuring that the reclamation is conducted
appropriately, selecting a reclaimer that is right
for your range is extremely important. Some
lead reclamation companies will travel to your
range and assess the range prior to conducting
Chapter III - Page III-17
BMP for Lead at Outdoor Shooting Ranges
lead collection activities. This assessment trip
allows the reclamation company to confirm
information gained during initial discussions, as
well as to assist in appropriately estimating
costs, time required, and the estimated volume
of lead at the range. Conducting this pre-
assessment also allows you to determine which
reclaimer is right for your situation.
Questions Commonly asked by the Reclaimer
When you contact a reclamation company, it is
likely that the reclaimer will ask several general
questions. Typical questions include:
When was the last reclamation conducted?
How many rounds have been shot since
that last reclamation?
What is the use frequency of the range?
What are the site characteristics and soil
types?
What type of bullet containment device is
used at the range?
Answering these questions will be a lot easier if
you have maintained good records, as is
suggested above.
Questions to ask the reclaimer
When choosing a reclaimer be sure to ask the
general questions about prior cleanups (past
projects), insurance to cover company and
cleanup (general liability insurance, pollution
insurance, bonding, etc.), and site plans to
ensure health and safety of workers and range
personnel. Other questions you may want to ask
the reclaimer include:
Can the reclamation take place outside
normal hours of range operation?
What costs are involved?
How long will the reclamation take?
Does vegetation at the range need to be
removed?
Economic Considerations
Lead removal costs may vary dramatically
depending upon the type and volume of soil or
sediments, topography, amount of lead, location,
and reclamation company and technique used.
Because the economics vary due to many
factors, this manual does not provide specific
estimates. However, it is important to
understand that lead reclamation will generally
require an expenditure by the range, even when
considering any monetary returns from selling
reclaimed lead. By tracking the range use and
using the criteria discussed earlier (see
Frequency of Lead Removal), the reclamation
costs per quantity of lead can be optimized. For
long term range management, routine lead
removal will help future cost avoidance by
minimizing the need for costly site remediation
Some reclaimers bid the lowest flat fee with all
the lead provided to the range for selling. The
range owners/operators must then consider the
transportation costs and recycling fee
associated with sending the reclaimed shot and
bullets to a recycling company. Alternatively,
the reclaimer will use the economic return of lead
sold for recycling, based on the volume
reclaimed and the current value of lead, to
reduce the total cost of reclamation and
recycling. Although the value of lead varies, the
scrap value of reclaimed lead typically falls
between $.06 and $.25 per pound, excluding
transportation cost. See the appendix for
contact information regarding lead reclamation
companies that specialize in lead removal at
outdoor ranges.
3.4 Documenting Activities and
Record Keeping (Step 4)
Documenting activities and keeping good
records is of paramount importance for an
effective lead management program at a range.
Owners/operators should document all activities
done at the range with respect to BMPs and
recycling of lead. Records should be kept on
when services were provided and who provided
them.
Owners/operators may want to document what
type of BMP(s) were implemented to control
lead migration, the date of service, and who did
the services. The records should be kept for the
life of the range. Records may be used to show
that owners/operators are doing their part to
BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-18
help prevent lead migration off-site and show
that they are doing their part to be stewards of
the environment.
3.5 Additional Economic
Considerations
Not all BMPs need to be implemented at once.
Many can be phased in over time. However, it
is important to begin implementing BMPs,
especially lead reclamation and recycling, as
soon as possible. Implementing the most
appropriate BMPs for your range requires
consideration of your range characteristics and
costs associated with implementing the BMPs.
This manual provides a large selection of BMPs
that vary in both cost and sophistication. In
selecting BMPs for your range, it is important to
look at all costs and all the benefits (or potential
problems) associated with each BMP.
3.6 Summary of Key BMPs for
Shooting Ranges
There are several BMPs that are highly
recommended to be implemented, if applicable
to your range. Table 3-1 identifies the
advantages and disadvantages of all BMPs
discussed in this chapter. This table serves as a
quick reference guide for potential BMPs.
Readers should refer back to the detailed
discussions above for further information
regarding these BMPs.
3.7 Certificate of Recognition
EPA has established a voluntary process
whereby a shooting range may apply for a
“Certificate of Recognition.” The Certificate is
intended to be awarded to ranges that have
certified that they have prepared and intend to
implement, or have implemented, a written
Environmental Stewardship Plan that is
consistent with the EPA Best Management
Practices for Lead at Outdoor Shooting Ranges
manual. To assist in this process, Appendix E
contains a template for an Environmental
Stewardship Plan, an electronic copy of which is
available on EPA’s shooting range website
(http://www.epa.gov/region2/leadshot) in several
formats. This template, combined with
information provided throughout this manual,
other resources and guidance, and site-
specific factors, will help in guiding the
process of evaluating relevant information
about your facility and determining which
BMP(s) might be appropriate for your
ranges. EPA’s template was adapted from
Appendix C of the National Shooting Sports
Foundation’s manual, Environmental
Aspects of Construction and Management of
Outdoor Shooting Ranges (the NSSF
manual.) Accordingly, use of that template
would also be acceptable for use in EPA’s
Certificate of Recognition program.
In order to request this certificate, a range
must submit a notice to the Lead Shot
Coordinator in EPA Region 2 stating that
they have completed an Environmental
Stewardship Plan as indicated above and
are intending to implement it within six
months. The certificate is intended to
convey, to all that may see it, that the range
has declared its intention to properly manage
lead shot and bullets. However, it must be
noted that a certificate is not a permit to
operate and provides no additional
operational approval, implied or otherwise.
Chapter III - Page III-19
BMP for Lead at Outdoor Shooting Ranges
Table 3-1 – Summary of Key BMPs
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BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-20
Table 3-1 – Continued
1 Much of this information was obtained from Action Target’s Bullet Containment Trap Technologies video.
Reference to various pros and cons of individual bullet containment devices is included in this manual for
informational purposes only. The USEPA does not endorse any particular bullet containment device, design,
or product.
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Chapter III - Page III-21
BMP for Lead at Outdoor Shooting Ranges
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BMP for Lead at Outdoor Shooting Ranges
Chapter III - Page III-22
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References - 1
BMP for Lead at Outdoor Shooting Ranges
Battelle Memorial Institute, Field Demonstration of a Sieving and Stabilization Technology
on Lead-Contaminated Soils at a Small Arms Range at Mayport Naval Air Station, Colum-
bus, Ohio, February 1991
Brister, B. The Speed Factor, Field and Stream, January 1995
Connecticut Coastal Fisherman's Ass'n v. Remington Arms Co., Inc., 989 F.2d 1305
(2d Cir. 1993)
George, C.J., Joachim, A., and Le, Phu Trong, Long-Buried Lead Shot: Its Stability, Possible
Transport by Waterfowl and Reexposure by Hydraulic Dredging at Collins Lake, Department
of Biological Sciences, Union College, Schenectady, NY, June 1991
Long Island Soundkeeper Fund, Inc. v. New York Athletic Club of the City of New
York, 1996 U.S. Dist. LEXIS 3383 (S.D.N.Y. 1996)
Magdits, Louis J., Recycling Regulations, Proceeding from the Third National Shooting
Range Symposium, June 23-25, 1996, Orlando, Florida
Middleton, J.R., Development of Toxic Free Ammunition, U.S. Armament Research,
Development and Engineering Center
National Rifle Association of America, Lead Article, Risk Issues in Health and Safety -
Volume I, Pages 6-8, Winter 1990
National Rifle Association of America, Metallic “Bullets” Lead Deposits on Outdoor and
Indoor Firing Ranges, 1991
National Rifle Association, The NRA Range Source Book: A Guide to Planning and
Construction, June 1998
National Shooting Sports Foundation, Environmental Aspects of Construction and
Management of Outdoor Shooting Ranges, June 1998
Ordija, Victor, Lessons from Lordship, Proceedings from the National Shooting Range
Symposium, October 17-19, 1993, Salt Lake City, Utah
Peddicord, Richard K., Lead Mobility in Soils, Proceedings from the Third National Shooting
Range Symposium, June 23-25, 1996, Orlando, Florida
References
References - 2
BMP for Lead at Outdoor Shooting Ranges
Sever, C.W., Lead and Outdoor Ranges, Proceedings from the National Range Symposium,
October 17-19, 1993, Salt Lake City, Utah
Sporting Arms and Ammunition Manufacturers Institute, Inc., Lead Mobility at Shooting
Ranges, Newtown, CT, 1996
Stansley, W., Widjeskog, L., and Roscoe, D.E., Lead Contamination and Mobility in Surface
Water Trap and Skeet Ranges, Bulletin of Environmental Contamination Toxicology,
Springer-Verlag, New York, NY, 1992
U.S. Department of the Interior, Pollution Prevention Handbook -- Firing Ranges,
Department of the Interior, Office of Environmental Affairs, Washington, D.C.
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
Washington, D.C., Directive 9355.4-12, Revised Interim Soil Lead Guidance for CERCLA
Sites and RCRA Corrective Action Facilities, July 14 1994
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
Washington D.C., A Citizen's Guide to Soil Washing, EPA 542-F-96-002. , April 1996.
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
Washington, D.C. Physical/Chemical Treatment Technology Resource Guide, EPA 542-B-
94-008. September 1994.
Appendix A - Page A-1
BMP for Lead at Outdoor Shooting Ranges
This manual provides contacts for lead reclamation companies, lead
recycling companies, bullet trap manufacturers, and organizations that
provide prevention and/or remediation techniques to assist clubs and firing
ranges in implementing Best Management Practices for shooting ranges.
The list was updated for the June 2005 printing. Vendors who are
interested in being added to the list of lead reclaimers or remediation
contractors should contact:
Lead Shot Coordinator
RCRA Compliance Branch
US EPA Region 2
290 Broadway
New York, NY 10007-1866
Telephone: (212)637-4145
E-mail: Leadshot.Region2@epa.gov
Appendix A:
Resources
Appendix A - Page A-2
BMP for Lead at Outdoor Shooting Ranges
Lead Recycling Companies
Below is a list of recycling companies for lead in soils and spent lead shot/bullets that were
contacted during the writing of this manual. Lead recycling companies smelt lead. It is not inclusive
and is included for informational purposes only. Local scrap metal recyclers may also accept spent
lead shot or spent bullets. Mention of these companies does not serve as an endorsement by the
EPA.
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Appendix A - Page A-3
BMP for Lead at Outdoor Shooting Ranges
Lead Reclamation Companies
Below is a list of reclamation companies for lead in soils and spent lead shot/bullets that were
contacted during the writing of this manual. Lead reclamation companies reclaim lead from ranges.
It is not inclusive and is included for informational purposes only. Mention of these companies does
not serve as an endorsement by the EPA.
latnemnorivnEecirB
,tSllehS0023
,02537xoB.O.P
70799KA,sknabriaF
senoJgiarC
5591-654-709
moc.cniecirb.www
morfyliramirpsmialceR
dnasdnaspotskcabnehtrae
.spart
.cnI,egnaR·nE
.tSht92WN6233
0136-24133LF,imaiM
rolyaT.MsamohT
5699-999-503
5468-536-503xaF
moc.oohay@1egnarne:liamE
moc.egnar-ne.www
dnanoitamalcerdaelsedivorP
dnalatnemnorivnerehto
.secivresecnanetniam
tcatnE
truoCevitucexE0101
082etiuS
95506LI,tnomtseW
0092-689-036
moc.tcatne.www
folavomerlacisyhpsmrofreP
,spotskcabmorfdaeleht
sliosfotnemtaertlacimehc
ehtotliossnruterdna
.potskcab
.cnI,setaicossA&lraK
daoRkcuaL02
04591AP,notnhoM
IIIlraKdnumdE
0077-658-016
-dimehtehtniyliramirpskroW
gniniatnoc-daeL.aeracitnaltA
dnadevomeryllacisyhpsilios
setislasopsiddesnecilottnes
.seitilicafgnilcycerdesnecilro
ROCRAM
daoRellivsyekcoC642
03012DM,yellaVtnuH
sregnuJevaD
1000-587-014
moc.rocram.www
noitarapescitamuenpasesU
morfdaelevomerottinu
staertdnaliosdetanimatnoc
.PLCTssapotlios
tnemtaerTslateM
TM(CLL,seigolonhceT 2)
eunevAht94tseW14421
3etiuS
33008OC,egdiRtaehW
lehtraBmiJ
7796-654-303
moc.ttslatem.www
dnaliosmorfdaelsevomeR
fosepytllatasliosstaert
.segnar
ynapmoCgnikcurTsraeS
83xoB.O.P
63037KO,oneRlE
sraeSdnalraG
4133-225-008
1182-262-504xaF
morfdaelsevomeryllacisyhP
.segnarteeksdnaparttaslios
oS rocul .dtL,seirtsudnIp
daoRkcayNtseW052
49901YN,kcayNtseW
acuLeDekiM
3332-326-548
7894-326-548xaF
moc.loa@sbmproculos:liamE
moc.dtlproculos.www
gnisuliosstaertdnasevomeR
gnidnoBraluceloMrieht
)SBM(metsyS lios
.ygolonhcetnoitazilibats
lavomeRdaeLnrehtuoS
5462xoB.O.P
51123LF,hcaeBanotyaD
tsirhcliGniveK
5110-367-683
1996-167-683xaF
dnaroodnimorfdaelsevomeR
.ylnosegnarlotsiproodtuo
secivreSgnitoohStropS
766xoB.O.P
62323LF,ellivdrofwarC
reyTdE
5737-629-058
2310-492-058enohplleC
moc.loa@egnarorivne:liamE
nehtraemorfdaelsevomeR
dnarekahsasesu,smreb
etarapesotmetsysneercs
stner,sliosmorfdael
dna,tnempiuqegnineercs
,ngisedegnarnostlusnoc
.adirolFniyliramirp
.dtL,secruoseRarreT
1139xoB4CH
54699KA,remlaP
dooWyrraL
1894-647-709
9505-232)709(:enohplleC
0894-647-709:xaF
moc.hsawarret.www
otssecorpcirtemivargsesU
dnadaeletarapes
hsaWarreT MT gnihsawlios
.ygolonhcet
,snoituloSgnilcyceRetsaW
.cnI
211etuoR0581
36711YN,drofdeM
tnediserP,aibarAymmoT
1183-456-136
otmetsysmuucavasesU
dnapartmorfdaelevomer
.segnarteeks
Appendix A - Page A-4
BMP for Lead at Outdoor Shooting Ranges
Other Resources
Below is a list of additional phone numbers that may be of use if you have general questions includ-
ing questions on range construction, design, and implementing BMPs.
ecivreSefildliWdnahsiF.S.U
xafriaFhtroN1044
30222AV,notgnilrA
6512-853/307
/vog.swf.www//:ptth:etisbeW
cnI,seitsudnIgnilcyceRparcSfoetutitsnI .
0001etiuS,WN,teertSG5231
4013-50002CD,notgnihsaW
0771-737/202
/gro.irsi.www//:ptth:etisbeW
.cnI,noitaicossAseirtsudnIdaeL
teertSniaM31
17870JN,atrapS
)3235-627/379(DAEL-627/379
4844-627/379:xaf
moc.ofnidael.www//:ptth:etisbeW
aciremAfonoitaicossAelfiRlanoitaN
daoRslliMselpaW05211
03022AV,xafriaF
8883-ARN/008
gro.arn.www//:ptth:etisbeW
dnanoitadnuoFstropSgnitoohSlanoitaN
segnaRgnitoohSfonoitaicossAlanoitaN
daoRlliHeliM11
07460TC,nwotweN
0231-624/302
gro.fssn.www//:ptth:etisbewFSSN
gro.ofniegnar.www//:ptth:etisbewRSAN
noitinummAdnasmrAgnitropS
.cnI,etutitsnI'srerutcafunaM
retneCeciffOegdiRkcoltnilF
daoRlliHeliM11
9532-07460TC,nwotweN
8534-624/302
gro.imaas.www//:ptth:etisbeW
etutitsnItnemeganaMefildliW
108etiuS.W.N,teertSht411011
50002CD,notgnihsaW
8081-173/202
:etisbeW
gro.etutitsnitnemeganamefildliw.www//:ptth
Appendix A - Page A-5
BMP for Lead at Outdoor Shooting Ranges
Web Resources
setiSbeWlufesU
noitpircseD sserddAbeW
setiStnemnrevoGlaredeF
egnaRgnitoohSroodtuOs'APE.S.U
egaPemoH
/tohsdael/etsaw/2noiger/vog.ape.www//:ptth
eluRsnoitinuMyratiliM–APE.S.U /yratilim/etsawzah/rewsoape/vog.ape.www//:ptth
mth.noitinumer/sdriht/wsmlabirt/vog.ape.www//:ptth
htlaeHdnaytefaSlanoitapuccO.S.U
)AHSO(noitartsinimdA
/vog.ahso.www//:ptth
lanoitapuccOrofetutitsnIlanoitaN
)HSOIN(htlaeHdnaytefaS
/hsoin/vog.cdc.www//:ptth
setiStnemnrevoGetatS
segnaRgnitoohSrofsPMB:adirolF /egnar_gnitoohs/seirogetac/etsaw/su.lf.etats.ped.www//:ptth
ehtnitohSdaeL:sttesuhcassaM
tnemnorivnE
mth.tohs_bp/tohsbp/selif/ped/su.am.etats.www//:ptth
egnaRgniriF"rofretsoP:atosenniM
"sdrazaH
lmth.selbanm/hsoin/vog.cdc.www//:ptth
tsilsremialceRtohSdaeL:oihO mth.ycerdael/mwhd/vog.oiho.ape.www//:ptth
tsiLsrelcyceRdaeL:gnimoyW mth.dael/hcaertuo/su.yw.etats.qed//:ptth
snoisiceDtruoC
s'nemrehsiFlatsaoCtucitcennoC
smrAnotgnimeR.vnoitaicossA
mth.arcr/remmus/ude.tif.lladeud.www//:ptth
YNdnadnuFrepeekdnuoSdnalsIgnoL
kroYweN.v.cossAs'nemrehsiFlatsaoC
bulCcitelhtA
mth.caynfsil/tohsdael/etsaw/20noiger/vog.ape.www//:ptth
hcraeseRdnaselcitrA
taslioSninoitanimatnoCdaeL-FASU
segnaRgniriFsmrAllamSyratiliM
psa.a89enuj/tcaf/tca-orp/lim.fa.skoorb.eecfa.www//:ptth
llamS–)CEA(retneC.vnEymrA.S.U
ygolonhceTegnaRsmrA
lmth.30snoitarepo/egnar/ceasu/lim.ymra.cea//:ptth
lmth.30ixxegnar/ygolonhcet/ceasu/lim.ymra.cea//:ptth
mth.egnar/79niw/etadpu/sriaffacilbup/ceasu/lim.ymra.cea//:ptth
stelluBneerG–CEA lmth.20yticilbup/sriaffacilbup/ceasu/lim.ymra.cea//:ptth
lmth.a00ixxegnar/ygolonhcet/ceasu/lim.ymra.cea//:ptth
mth.stellub/79rps/etadpu/sriaffacilbup/ceasu/lim.ymra.cea//:ptth
parcSegnaRgniriFfognilcyceR-CEA mth.1199rps/99rps/etadpu/sriaffacilbup/ceasu/lim.ymra.cea//:ptth
suodrazaHdnadiloSrofretneCadirolF
tnemeganaMetsaW
/gro.retnecadirolf.www//:ptth
gnitoohSfonoitaicossAlanoitaN
yrarbiLecnerefeR'segnaR
/tnmgnm_ytilicaf/yrarbil_ecruoser/gro.ofniegnar.www//:ptth
Appendix A - Page A-6
BMP for Lead at Outdoor Shooting Ranges
Bullet Trap Manufacturers1
1EPA does not endorse any particular bullet containment device or product. Information on this table is offered toreaders for a general understanding of some common bullet trap options and is based on vendor marketing literature.parTtelluBrerutcafunaMelbaliavAsngiseDfotsoCdetamitsEparTecirPsedulcnItoNdedulcnIecirPnifoegasUparTnoitpircseDstnemmoClareneGtegraTnoitcA3308-773)108(:tcatnoCOEC,sitruCnhoJmoc.tegratnoitcatnemniatnoClatoT)TCT(parT008,1$ot006,1$toofraenil/notnedneped()detcelesserutaeffoesahcruPtnempiuqEnoitallatsnIyrevileDthgierF()dedulcnielfiRlotsiP-romrA*gnicreipnosdneped*foepyt-romragnicreiptahtpartelyts-lennufasiTCTehTwoltadetnuomsetalpleetssesuaotnistellubtceridotselgnawolehT.rebmahcnoitarelecedehtfopukaerbtneverpselgna,rebmahcehthcaeryehtlitnustellubdnaygreneesolstellubehterehwegarotselbaevomerotnipordtsudlanoitponA.sreniatnoclufrewopasesutinunoitcellocdnatsuddaelevomerotmuucavnoitcellocehtmorfselcitrapenifrehto.rebmahcrofdengisedsiTCTehTroodtuodnaroodnihtobebyamtI.snoitacilppa,snugdnahhtiwylefasdesu-hgihdna,snugtohssahdna,selfirderewopdetsetyllufsseccusneebrebilac-05htiwdesudna.eriftegraTnoitcA).tnoC(evobasliatedeesmreBrebbuR)TBR(parTtoofrenil/0011$noitallatsnIyrevileDdnaroelfiR.lotsiP-romrA.gnicreipesutonnaCyraidnecni.sdnuordnamrofniralimisyrevsiTBRehTrodnaslanoitidartaotnoitcnufsuoivboehthtiw,partmrebnehtraedeppohcfoesuehtgniebecnereffidasadnasfodaetsnirebburotniderifstelluB.muidemnoitcellocrebburehtybdebrosbaerapartehtnoitamalcerlitnuerehtniamerdna.partehtmorfdaelfogninimhguorhtretfosasirebburesuaceBstellub,muidemnoitcellocsselhtiwderutpacebnac.noitatnemgarfdnapu-kaerbninoitcudergnitluserehTsisleveltsuddaelnilaicifenebyllaicepsetifenebsihT.segnarroodnieromsadesaercedsiehtnietalumuccasdnuorderifylwengnisuac,partstellubtcapmiotstellub.partehtniydaerla
Appendix A - Page A-7
BMP for Lead at Outdoor Shooting Ranges
Bullet Trap Manufacturers Con’t.1
parTtelluBrerutcafunaMsngiseDelbaliavAfotsoCdetamitsEparTecirPsedulcnIdedulcnItoNecirPniparTfoegasUnoitpircseDstnemmoClareneGsuipoCstnatlusnoC9847-387)615(:tcatnoCsuipoCgiarC/tnemniatnoCyrevoceRmetsySmorfsegnaRottoofraenil/006$toofraenil/000,1$htiwseiravecirP(ngisedcificeps)detcelesfoesahcruPtnempiuqEgnippihSelfiRlotsiPnugenihcaMnugtohSehtfonoitacifidomasisihTyravseziS.potskcabdnassdeenehtnognidnepedehtfoscitsiretcarahcdnaegareva,revewoh;egnardna'21-'01sithgieh.'41-'21sihtdiwegarevacitsillabsezilitupartehTstellubpartotdnasedarganistnemgarftellubdnametsysehT.metsysdelaesdnanoitcellocsniatnocesaeotsmetsysnoitartlifetanimilednanoitamalcer.daelfonoitargimetis-ffodednemmocercificepSehtnodesabsiparttellub:gniwollofytitnauq,egasufoepyT)1.cte,egasufoyrtnuocninoitacoL)2seussilatnemnorivnE)3araennoitacol,.g.e()ydobretawehtnodnepedlliwecirP.detpodangisedtahtsierutaefeuqinuenOynatarucconacgnitoohs.elgnaesnefeDttiggeMsmetsySllewsaC1026-607)216(:tcatnoCnosleinaDnairBralunarGtelluBrebbuRsparTraenil/003,1$ot049$tooffoepytnotnedneped(serutaefrehtodnapart)detcelesfoesahcruPtnempiuqEnoitallatsnIyrevileDthgierF()dedulcnilotsiPelfiRgnicreiP-romrAnugtohSnugenihcaMkaepS(srecarT).peRselaSotstellubsbrosbapartehTroelgnaynamorfderifleetsdesopxeoN.ecnatsidtonerastellub;secafrusehT.detnemgarfnidesulairetamdetalunargrevodenrutebnacpartehttnepsehtrevocerotylkciuq.sdnuordnaroodnirofelbatiuS.segnarroodtuospartfosepytthgiE.elbaliava.spartsdliubmotsuCcificeps-etissedivorP.detseuqerfi,ngisedsinoitamalceRretfadednemmocer000,09yletamixorppaderifneebevahsdnuor).epytpartnognidneped(1EPA does not endorse any particular bullet containment device or product. Information on this table is offered toreaders for a general understanding of some common bullet trap options and is based on vendor marketing literature.
Appendix A - Page A-8
BMP for Lead at Outdoor Shooting Ranges
Bullet Trap Manufacturers Con’t.1
1EPA does not endorse any particular bullet containment device or product. Information on this table is offered toreaders for a general understanding of some common bullet trap options and is based on vendor marketing literature.parTtelluBrerutcafunaMsngiseDelbaliavAfotsoCdetamitsEparTecirPsedulcnInidedulcnItoNecirPfoegasUparTnoitpircseDstnemmoClareneGsmetsySegnaR7121-999)888(0029-335)367(:tcatnoCsamohTevetSmoc.smetsys-egnarrotalusacnEparTcolBMTrotalusacnEralunarGparTMTtfraenil/052,1$-008$htiwseiravecirP(dnaairetircngised)noitcelestcudorpfoesahcruPtnempiuqEnoitallatsnIthgierFlotsiPelfiRtohs(nugtohS)sgulsdnaerasparttellubehTmumixamrofdetcurtsnocmumunimhtiwnoitnetertellubtellubehT.tsocdnaecapsetanimileyllautrivspart.daelenrobriadnatehcocirgnitoohsecivreslluFmorfredivorpegnarotgnireenignednangiseddnanoitcurtsnoc.ecnanetniamhtiwsparttliub-motsuCrebburdetnetapevisulcxe.ygolonhcetegnaRegavaSsmetsyS1007-865)314(:tcatnoCrekcurDnaoJmoc.spartliansLIANSehTMTparT:spartfosepytowT:teWlotsiPtfraenil/052,2$:yrDlotsiPtfraenil/051,2$:teWelfiRtfraenil/004,2$:yrDelfiRtfraenil/003,2$foesahcruPtnempiuqEgnippihSnoitallatsnIelfiRlac05.otpu()GMBlotsiPdengisedsipartLIANSehTecnartneelgnawolhtiwotnitellubehtediugotspmarnoitarelecedralucricehtehtgnirracstuohtiwrebmahcfollasesoltellubehT.etalprebmahcehtniygrenestinoitcellocaotnisporddnaretawfoesuehT.metsysehtsniatnocliocitehtnysdna,tsuddnasetalucitrapdaelehtnonoitcirfseziminimdna.setalpdnaroodnirofegasU.segnarroodtuohtiwdedivorpeboslanaCtahtmetsysecnayevnocaelgnisaottellubehtspord-55,.g.e(tniopnoitcelloc.gnilcycerrof)murdnollagmetsysecnanetniam-woL
Appendix A - Page A-9
BMP for Lead at Outdoor Shooting Ranges
Bullet Trap Manufacturers Con’t.1
1EPA does not endorse any particular bullet containment device or product. Information on this table is offered toreaders for a general understanding of some common bullet trap options and is based on vendor marketing literature.parTtelluBrerutcafunaMsngiseDelbaliavAfotsoCdetamitsEparTecirPsedulcnInidedulcnItoNecirPegasUparTfonoitpircseDstnemmoClareneG,CBEppatSdetaroprocnI3229-932)307(:tcatnoC,ikswoksiCttaM.E.PdaoRxO1018,noitatSxafriaF93022AV:xaF4229-932)307(moc.rehctactellubtelluBPPATSrehctaCcificepsybseiraVderusaem(ngised)tooferauqsybfoesahcruPtnempiuqEnoitallatsnIyrevileD)thgierF(&lotsiPelfiRroftseb(srebilacotpu)mm21naCeldnahdetekcajsdnuordnasrecartrehctactellubPPATSehTrebburmottobafognitsisnoc(rebbur,riovreserepipniard,renilforeyalrevocdna,llifelunargynadnadaelstcelloc)rebbur.ffonurtuohtiwretawgnitartlifnirevodetcurtsnocsimetsysehTebnacdnamrebnehtraenaegnarynaotdeifidomeraselitcejorP.noitarugifnocehtybdetcellocyletelpmoclaminimhtiwrehctactellubgnidnuorrusehT.noitatnemgarfnevefoorp-tehcocirsierutcurtsemertxetsomehtrednu.serutarepmet.detpadaetiserasngiseDybdemrofrepebnacnoitamalceR.lennosrepegnarybroCBEppatS:liamEten.nozirev@crt-ikswoksicm
Appendix A - Page A-10
BMP for Lead at Outdoor Shooting Ranges
Bullet Trap Manufacturers Con’t.1
1EPA does not endorse any particular bullet containment device or product. Information on this table is offered toreaders for a general understanding of some common bullet trap options and is based on vendor marketing literature.parTtelluBrerutcafunaMsngiseDelbaliavAfotsoCdetamitsEparTecirPsedulcnIdedulcnItoNecirPniparTfoegasUnoitpircseDstnemmoClareneG.cnIparTrepuS0449-637)159(:tcatnoC,nesnarFtrA.D.S.A.L,deriteRtSecremmoC106108829AC,anoroC:xaF0549-637)159(:liamEmoc.partrepus@ofnimoc.partrepusroC-leGMT-eriF,AssalCrebbuRdetaRsparTtelluBRIxILEMTgnitoohSlacitcaTsegnaRparTrepuS®egnaRspotskcaBNOCAS®retemireP,sllaW,seitilicaFseliT&skcolBot025$xorppAtoofraenilrep006,1$,ngisedybseiraV:gnidulcniroodni-roodtuo-noitadnuof-partfohtdiw-foesahcruPtnempiuqEnoitallatsnIgniniarTgnippihSlliwecirP(nodneped)noitanitsedlotsiP&elfiRdnaotpu(05.gnidulcni)lacnuGenihcaMgnicreiPromrA&recarTyraidnecnInoitinummA:oslA&elbignarFnetsgnuT&lanoitidarTlacitcaTgnitoohSlacitcatnisezilaicepsITSgnirifehT.segnargnitoohsdnaserutpacmetsysegnar,elohwstellubsniatnocralunarg,detaertagnisudelcycerfoaidemcitsillab-eneryts(RBSerupfoeerf,)rebbureneidatubrebifdnaleetslladluoctahtstnanimatnocotserifwollayllamron.etingi01sierutcurtsarfniehTdnaleetsdezinavlageguagelffabnoitcelfed/reppohehtelfirleets005RA”8/3si).roodtuodnaroodni(detarehT:segnaRroodtuOseilyllacipytesabpotskcabehttamrebdedarganoelgnaetairporppadnaresuehtybdenimreted.ffatsITSNOCAS®stellubbrosbanacdaeltneverpdnagnicalper,noitanimatnockcirb,sgol,seitdaorliaretercnocdnasllaw.segnargnirifnoserusolcnesmetsysparttellubs’ITSsuodrazahsetanimilenoitanimatnocslairetam,)mpp1wolebstsetPLCT(gnitneverpotnoitiddani-hsalpsdaeldnastehcocir.kcabsinoitamalceRretfadednemmocerot000,001yletamixorppatf4repsdnuor000,031foepytnodesab,enaldnanoitisopretoohscitats(yrtegratfotuoyaldaeL).cimanyd.svdemrofrepsinoitamalcerriamuucavagnisumetsysrotarapesytisnedsiaidemrebburdna.desuerylsuounitnocrebburdelcycerfoesUyampartehtniaidemegnarehtyfilauqtnargroftnemevorpmilanoigertcatnoC.gnidnufrofsnoitaicossagnilcycer.noitamrofnieromxisnahteromsreffoITSlacitcaTfosnoisrevllewsa,segnaRgnitoohS.sparttliubmotsucsa
Appendix B - Page B-1
BMP for Lead at Outdoor Shooting Ranges
Another method of preventing lead contamination at pistol, rifle, trap, skeet, or sporting
clays ranges is to use less toxic or non-lead ammunition.
Much progress has been made in the development of alternatives to lead shot for hunting
uses. Information gathered since 1976 on lead poisoning of endangered and non-
endangered migratory birds due to lead shot ingestion led the United States Fish and
Wildlife Service (USFWS) to consider several alternatives to eliminate lead poisoning
among migratory waterfowl birds. A ban on lead shot for water fowl hunting was phased in
beginning in 1986 and finalized in 1991. Lead shot is also now banned for shotgun hunting
occurring near wetlands in national wildlife refuges. Starting in the fall of 1998, the USFWS
banned the use of lead shot in waterfowl production areas. Additionally, many state-
managed hunting areas require non-toxic shot for upland/small game hunting.
There are several alternatives to lead shot on the market today and still more alternatives
are being developed. Before being used for waterfowl hunting, these alternatives must be
approved by the USFWS. Bismuth, steel, tungsten/iron, and tungsten/polymer shots have
been approved by the USFWS and additional alternative shot materials are in the USFWS
approval process. Most of the ammunition manufacturers in the United States, as well as
the military, have developed non-toxic alternatives to lead. Research in Europe may also
result in additional non-toxic shot alternatives from which U.S. shooters may choose in the
future. The following pages compare lead shot to non-toxic, alternative shot.
Appendix B:
Lead Shot Alternatives
Appendix B - Page B-2
BMP for Lead at Outdoor Shooting Ranges
Summary of Lead Shot Alternatives†† Product reference within this table is not an endorsement by EPA.* Approved by USFWS for migratory waterfowl hunting.1 Costs will vary from store to store and were valid at the time of manual development.lairetaMtohSlairetaMtohSlairetaMtohSlairetaMtohSlairetaMtohS52reptsoCetamixorppA52reptsoCetamixorppA52reptsoCetamixorppA52reptsoCetamixorppA52reptsoCetamixorppAxoBdnuoRxoBdnuoRxoBdnuoRxoBdnuoRxoBdnuoR11111ecnamrofrePcitsillaBecnamrofrePcitsillaBecnamrofrePcitsillaBecnamrofrePcitsillaBecnamrofrePcitsillaBytilibaliavAytilibaliavAytilibaliavAytilibaliavAytilibaliavAstnemmoCstnemmoCstnemmoCstnemmoCstnemmoCdaeLdaeLdaeLdaeLdaeLxob/00.5$dedaolerfoxob/00.4$-00.3$sllehssevitanretlallahcihwotdradnatSderapmoceraelbaliavaylidaeRelbaellamdnayvaehsidaeL*htumsiB*htumsiB*htumsiB*htumsiB*htumsiB/htumsiB%79nit%3nidekcaperasllehshtumsiB-00.51$@sexobdnuor01xobdnuor01/00.52$daelotralimiSdlrowdetimiLhtumsibfoylppusdlogdnadaelfotcudorpybasihtumsiB,sesuynamyltnerruceraerehT.gninim,)lomsiB-otpeP(enicidem:gnidulcni.tohsnugtohsdna,stnemgip,scitemsoceromhtumsibsekamnitfonoitiddaehT.ytilibignarfsecuderdnaelbaellamredloniesuotefassitohshtumsiB.smraerif
Appendix B - Page B-3
BMP for Lead at Outdoor Shooting Ranges
Summary of Lead Shot Alternatives – Continued†† Product reference within this table is not an endorsement by EPA.* Approved by USFWS for migratory waterfowl hunting.1 Costs will vary from store to store and were valid at the time of manual development.lairetaMtohSreptsoCetamixorppAxoBdnuoR521ecnamrofrePcitsillaBytilibaliavAstnemmoCleetS*xob/59.21$-00.8$dedaolerfoxob/00.6$sllehs-reppoc(xob/00.51$)detalpehtybecnamrofreptsetnInaciremAhtroNevitarepooCmargorPnoitacudEnugtohSon,snoitautisgnitnuhni)PESNOC(dnuoferewsecnereffidtnacifingistatohsleetsdnadaelneewtebsidaeL.secnatsidelbanosaer.segnarregnoltaevitceffeerommorfelbaliavaylidaeRdnacitsemodhtob.secruosdetropminehtrethgil%33tuobasitohsleetSyticolevlaitinieht,eroferehT.daelegnarnwodtahtosdesaercniebtsumnI.ralimissniamerygrenetelleperoferehtdna,regral,snoitautisgnitnuhweF.desusitohsleets,reivaehtohsleetswollasnoititepmocgnitoohssirebmunehttub,tniopsihtta.gnisaercni,elbaliavaerasdaoltegratleetselihWlliwleetstahtnoitpecrepretoohsgnirocsdnasnugtceffaylesrevdanirotcafgnitimilehtebotsmeestegratroftohsleetsfoecnatpecca.gnitoohsrewenegamadtonlliwtohsleetSnieglubgniresuacyamtub,snugsiekohcthgityrevafisnugredloneebsahmelborpsihT.desuehthtiwsnugrewenehtnidevloser.sekohcni-wercsfoesu
Appendix B - Page B-4
BMP for Lead at Outdoor Shooting Ranges
Summary of Lead Shot Alternatives – Contiued†† Product reference within this table is not an endorsement by EPA.* Approved by USFWS for migratory waterfowl hunting.1 Costs will vary from store to store and were valid at the time of manual development.lairetaMtohSlairetaMtohSlairetaMtohSlairetaMtohSlairetaMtohS52reptsoCetamixorppA52reptsoCetamixorppA52reptsoCetamixorppA52reptsoCetamixorppA52reptsoCetamixorppAxoBdnuoRxoBdnuoRxoBdnuoRxoBdnuoRxoBdnuoR11111ecnamrofrePcitsillaBecnamrofrePcitsillaBecnamrofrePcitsillaBecnamrofrePcitsillaBecnamrofrePcitsillaBytilibaliavAytilibaliavAytilibaliavAytilibaliavAytilibaliavAstnemmoCstnemmoCstnemmoCstnemmoCstnemmoCleetSleetSleetSleetSleetS*****).tnoc().tnoc().tnoc().tnoc().tnoc(.ytefassitohsleetshtiwnrecnocrehtonAelbaellamsselhcumsileetsesuaceBfitehcocirotylekilsitohsleets,daelnehtno,tohsdaeL.drahgnihtemossekirtsti.nettalfdnamrofedlliw,dnahrehtoehtrofdennabsitohsleets,eporuEnIemocebnactiesuacebgnitnuhnitohsleetsehT.seertnideddebmeegamadesuacnacrebmulroftucseertsnrecnocesiardnatnempiuqellimwasot.ytefasrekrowtuoba,dedaolerebnactohsleetshguohtlA.elbaliavaylidaertonerastnenopmocnorI/netsgnuT*/netsgnut%04nori%06nori/netsgnut(xob/05.26$01nidekcaperastohs01/00.52$@sexobdnuor)xobdnuortahtetacidnistroperyranimilerPsaevitceffesasitohsnori/netsgnutfotnuomaeht,revewoH.tohsdaelyltnacifingissiegdirtrachcaenitohssegdirtracdaellacipytninehtsselytisnedehT.segdirtracleetsnevero.daelfotaht%49sinori/netsgnutfoelbaliavaylidaeRelbaliavayltnerructohsnori/netsgnutehT,erofereht,dluowtI.leetsnahtredrahsi.snugredlootegamadralimisesuac
Appendix B - Page B-5
BMP for Lead at Outdoor Shooting Ranges
Summary of Lead Shot Alternatives – Continued††Product reference within this table is not an endorsement by EPA.1Costs will vary from store to store and were valid at the time of manual development.lairetaMtohSreptsoCetamixorppAxoBdnuoR521ecnamrofrePcitsillaBytilibaliavAstnemmoC/netsgnuTremylop*srerutcafunamsuoiraVlanifdeviecerevahSWFSUehtmorflavorppafoepytsihttekramot.tohsteyelbaliavatoNnori/netsgnutotelbarapmoCelbaliavatonyltnerruCerasrerutcafunamnoitinummaowTremylop/netsgnutgnicudorpyltnerrucnahtelbaellameromsitohssihT.tohs,dluowdnayollanori/netsgnutehtotgnigamadsseleb,erofereht.snugtohsynapmoctnempoleveddnahcraeserAremylop/netsgnutadepolevedsahstillanidaelrofetutitsbusasalairetamsti,ynapmocsihtotgnidroccA.sesuotdetalumrofebnacremylop/netsgnutehtnognidneped,ffitsroelbixelfebneebsahlairetamsihT.noitacilppa,selitcejorpniymrASUehtybdetseterutcafunamotdesuneebtonsahtubsahynapmoceht,revewoH.tohsehtotgniylppafossecorpehtdetaitinisalairetamsihtfolavorpparofSWFSU.tohscixot-non
Appendix B - Page B-6
BMP for Lead at Outdoor Shooting Ranges
Summary of Lead Shot Alternatives – Continued†Other materials that are currently being experimented with as alternatives to lead are molybdenum and zinc. Not enough informationis available to have included these alternatives in the above table.† Product reference within this table is not an endorsement by EPA.lairetaMtohSlairetaMtohSlairetaMtohSlairetaMtohSlairetaMtohS52reptsoCetamixorppA52reptsoCetamixorppA52reptsoCetamixorppA52reptsoCetamixorppA52reptsoCetamixorppAxoBdnuoRxoBdnuoRxoBdnuoRxoBdnuoRxoBdnuoR11111ecnamrofrePcitsillaBecnamrofrePcitsillaBecnamrofrePcitsillaBecnamrofrePcitsillaBecnamrofrePcitsillaBytilibaliavAytilibaliavAytilibaliavAytilibaliavAytilibaliavAstnemmoCstnemmoCstnemmoCstnemmoCstnemmoCleets/netsgnuTleets/netsgnuTleets/netsgnuTleets/netsgnuTleets/netsgnuTnorI/netsgnutsaemaSniTniTniTniTniTyraropmetdetnargSWFSU0002-9991roflavorppanosaesgnitnuhteyelbaliavatoNsadepolevedgniebtsujsinitecniSecnamrofrep,daelotevitanretlana.elbaliavateytonsinoitamrofnisinitfoytisnedehtecnis,revewoHebyamecnamrofrep,leetsnahtssel.leetsnahtevitceffesselelbaliavatonyltnerruCsadepolevedgniebtsujsilairetamsihTsahti,revewoH.evitanretlatohsdaelasititahtnileetssasmelborpralimis.daelnehtrethgiletutitsnIhcraeseRniTlanoitanretnIehT.tcudorpsihtgnipolevedsidnalgneni
Appendix B - Page B-7
BMP for Lead at Outdoor Shooting Ranges
Summary of Lead Shot Alternatives -
Conclusions
The table clearly illustrates that a number of non-toxic alternatives to lead shot exist such as
steel and tungsten as well as alloys and synthetic polymers. As demand for shot from these
metals increases from migratory waterfowl hunters, it is anticipated that the costs will come
down. However, alternatives currently cost approximately two to twenty times more than
lead shot.
The ban on lead shot in hunting situations impacts target shooting. The alternatives to lead
shot that are now being developed for or are already approved by the USFWS for migratory
bird hunting could be considered for use by target shooters.
Although alternatives to lead shot are now being used by hunters, it is rare that the alterna-
tives are used by target shooters. The limiting factors appear to be the expense and perfor-
mance. All the alternatives to lead are much more expensive, some prohibitively. Unfortu-
nately, the least expensive alternative, steel, is also perceived to be less effective.
To encourage use of lead shot alternatives, some ranges sponsor shooting competitions
using lead-free ammunition, but these are rare. The use of steel or other alternative shot is
a recommended BMP in established sporting clays areas at which reclamation of lead shot
is difficult to impossible.
Note: Switching to non-toxic shot may create additional issues. For instance, steel
has an increased risk of ricochet. Switching to steel may require additional safety
features and/or operating procedures.
Appendix B - Page B-8
BMP for Lead at Outdoor Shooting Ranges
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Appendix C - Page C-1
BMP for Lead at Outdoor Shooting Ranges
The bullet containment designs in this appendix are sample designs for the
containment systems mentioned in this manual. Design systems may vary from
different manufacturers. Reference to various individual bullet containment
devices is included in this manual for informational purposes only. EPA does
not endorse any particular bullet containment device, design, or product.
Rubber Granule Trap (Adapted from: Bullet Trap
Feasibility Assessment and Implementation Plan: Technology
Identification Final Report, U.S. Army Environmental Center,
March 1996)
Appendix C:
Sample Bullet Containment
Devices
Sand Trap
Target
Sand
Direction
of Fire
Bullets impact and are
contained in the sand
Appendix C - Page C-2
BMP for Lead at Outdoor Shooting Ranges
Escalator Trap (Adapted from: Bullet Trap Technologies, Action Target Educational Video Series)
Gel-Cor Bullet TrapTM (Provided by Super Trap, Inc.)
Appendix C - Page C-3
BMP for Lead at Outdoor Shooting Ranges
Vertical Swirl Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final
Report, U.S. Army Environmental Center, March 1996)
Wet Passive Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final
Report, U.S. Army Environmental Center, March 1996)
Pitt and Plate (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final Report,
U.S. Army Environmental Center, March 1996)
Appendix C - Page C-4
BMP for Lead at Outdoor Shooting Ranges
Lamella Trap (Adapted from: Bullet Trap Feasibility Assessment and Implementation Plan: Technology Identification Final Report,
U.S. Army Environmental Center, March 1996)
Steel Bullet Trap (Adapted from: Bullet Trap Technologies, Action Target Educational Video Series)
Appendix D - Page D-1
BMP for Lead at Outdoor Shooting Ranges
Appendix D:
RCRA Regulatory Requirements
and Interpretations
Timely separation of lead shot and bullets from soil at active ranges, recycling of the lead,
and subsequent redeposition of the soil on the active range is exempt from RCRA regula-
tion.
1. Reclaiming and Recycling Lead Shot
EPA’s Office of Solid Waste issued guidance in 1997 indicating that lead shot, when
recycled, is considered a scrap metal and is therefore exempt from RCRA regulation. A
copy of the March 17, 1997 letter with this guidance is attached. Under the RCRA Subtitle
C hazardous waste management regulations, lead shot would be considered scrap metal,
which is exempt from hazardous waste regulations if it is recycled (see 40 CFR
261.6(a)(3)(ii)). Although storage of scrap metal being recycled is not affected by specific
time limits such as the speculative accumulation provision (40 CFR 261.1(b)(8)), the scrap
metal must legitimately be recycled to remain exempt under this provision. It should also be
noted that lead shot may be subject to the authority of RCRA 7003, which addresses
imminent hazards. However, use of best management practices is likely to prevent
situations which would present an imminent hazard. Using such practices, together with
following a clear, written policy governing the facility’s recycling efforts, should also assist in
assuring that the facility’s practices can be demonstrated to be legitimate recycling.
2. Storage of Lead on Shooting Ranges Prior to Recycling
Some ranges have indicated that it may be desirable to store recovered lead shot
and bullets on the range property for some periods of time prior to sale for recycling.
Provided that best management practices are followed in terms of storing and
recycling the sorted lead, a range that follows such practices, and engages in legitimate
recycling, should be able to store such material prior to recycling without RCRA regulatory
controls (see discussion below). Best practices would suggest that the sorted lead, at a
minimum, should not be exposed to the elements and should be managed so as to prevent
releases to the environment. Best practices also indicate that the sorted lead should be
stored in containers in good condition, regular inspections of the container condition should
be conducted, and the records of inspections should be maintained and be readily
available. Further, best practices also suggest that the sorted lead should be recycled in a
timely manner and storage times should not exceed the time-frames or goals articulated in a
clear, written policy.
Appendix D - Page D-2
BMP for Lead at Outdoor Shooting Ranges
3. Placement of Soil After Removal of Lead
For soil placed back on an active range after a BMP has been applied to remove the
lead, the following regulatory approach has been followed. On February 12, 1997, EPA
published the RCRA Subtitle C Military Munitions Rule in the Federal Register (62 Fed.
Reg. 6621). The Military Munitions Rule considers range management to be a necessary
part of the safe use of munitions for their intended purpose. Thus, the range clearance
activity (recovery of lead shot and bullets) is an intrinsic part of the range operation.
Therefore, the rule excludes range clearance activities (including the placement of soil back
on the range) from RCRA Subtitle C regulation. Although the Military Munitions Rule did not
apply to non-military ranges, EPA, in its response to comments on the proposed rule, clearly
stated that “it felt that the ‘range clearance’ interpretation in the final Military Munitions Rule
is consistent with the EPA’s interpretations for non-military ranges.” In addition, the EPA’s
Director of the Office of Solid Waste sent the New York State Department of Environmental
Conservation a letter dated April 29,1997, confirming that the Military Munitions Rule range
clearance principles apply equally to non-military ranges. A copy of the letter is attached.
4. Relocation of Backstop and Shotfall Zone Soil
Some ranges have indicated to the EPA that it may be desirable to transport and/or
relocate a backstop in order to reorient or modify their range. This may occur when there is
a need to reorient the range due to environmental concerns (e.g., shooting over water
(wetland, stream, pond) or excessive runoff), alter the layout to improve shooter safety, or
redesign to modify shooting conditions (e.g., adjusting number of shooting positions,
increasing or decreasing target distance.) In some cases backstop material would not be
moved off the range property, but to another area on the range property.
EPA’s position is that range backstop materials are part of the range and are not
wastes when they are moved or relocated, as long as the range continues to be used as a
range and the backstop materials continue to be used as backstop materials. Hence,
backstop materials that are still in use are not subject to the RCRA hazardous waste
management regulations and need not be tested for hazardous waste characteristics.
However, removal of lead from backstop materials that are to be relocated or moved is a
normal practice of good range management in that it extends the usable life of the materials
and reduces the possibility of releases of lead into the environment. If lead removal does
not occur before moving the backstop material, the lead will become more dispersed
throughout the material during movement and will thus be more difficult to recover in future
reclamation events.
As a range management practice, it is environmentally preferable to use soil that may
already contain lead and is on an active portion of the range, which will therefore undergo
regular lead reclamation in the future, than to leave such soil in place and construct a new
backstop with lead-free soil. Records of all movements of berm and shotfall zone soils,
along with corresponding site plans, should be maintained indefinitely, as they will be
necessary in evaluating cleanup needs during subsequent construction or range closure.
Appendix D - Page D-3
BMP for Lead at Outdoor Shooting Ranges
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
March 17, 1997
Mr. Duncan Campbell
Environmental Protection Agency, Region V
RCRA Enforcement
77 West Jackson Boulevard
Chicago, Illinois 60604-3507
Dear Mr. Campbell:
Enclosed please find a memorandum on the regulatory status of lead shot, which includes
a general discussion on the regulatory status of lead shot as scrap metal. I hope that this
information is sufficient to address your specific concerns as they relate to the pile of lead
shot at the Saxon Metals facility.
If you have any questions or would like to discuss this matter further, please contact me at
(703) 308-8826.
Sincerely,
Jeffery S. Hannapel
Office of Solid Waste
Enclosure
To: Duncan Campbell, EPA Region V
From: Jeff Hannapel, EPA Office of Solid Waste
Date: March 13, 1997
Re: Regulatory Status of Lead Shot
Based on our conversations, it is my understanding that Saxon Metals received for recycling
a shipment of approximately 30,000 pounds of lead shot from a commercial indoor shooting
range. Smokeless gun powder is, presumably, commingled with the lead shot. The mixture
appears to exhibit the ignitability characteristic of hazardous waste (as evidenced by the
incident in which the material ignited when Saxon Metals was attempting to load it into the
furnace with a front-end loader). You have asked our office to provide you with guidance on
the regulatory status of the lead shot portion of the mixture, specifically whether it is consid-
ered a spent material or scrap metal.
The Agency has taken the position that the discharge of ammunition or lead shot does not
constitute hazardous waste disposal because the Agency does not consider the rounds
from the weapons to be “discarded.” As you know, discard is a necessary criterion to be met
Appendix D - Page D-4
BMP for Lead at Outdoor Shooting Ranges
before a material can be considered a solid waste and subsequently a hazardous waste.
(40 CFR §261.2(a).) The Agency’s interpretation regarding discard is based on the fact that
shooting is in the normal and expected use pattern of the manufactured product, i.e., the
lead shot. Enclosed for your information is a September 6, 1988 letter from EPA to IDEM on
this particular point.
In the federal regulations, the term, “scrap metal,” is defined as “bits and pieces of metal
parts (e.g., bars, turnings, rods, sheets, wire) or metal pieces that may be combined together
with bolts or soldering (e.g., radiators, scrap automobiles, railroad box cars), which when
worn or superfluous can be recycled.” (40 C.F.R. §261.1.) In the Federal Register preamble
for the final regulations on the definition of solid waste, EPA indicated that “scrap metal is
defined as products made of metal that become worn out (or are off-specification) and are
recycled to recover their metal content, or metal pieces that are generated from machine
operations (i.e., turnings, stampings, etc.) which are recycled to recover metal.” (50 Fed. Reg.
614, 624 (1985).) The lead shot portion of the Saxon Metals pile would be considered scrap
metal pursuant to the regulatory definition of scrap metal.
EPA provided further clarification on the regulatory status of scrap metal in the Federal
Register preamble to the definition of solid waste final regulations:
[a]t proposal, scrap metal that was generated as a result of use by consumers (copper
wire scrap, for example) was defined as a spent material. (This type of scrap is usually referred
to as “obsolete scrap.”) Scrap from metal processing, on the other hand (such as turnings from
machining operations) was defined as a by-product. (It is usually called “prompt scrap.”) Yet the
scrap metal in both cases is physically identical (i.e., the composition and hazard of both
by-product and spent scrap is essentially the same) and, when recycled is recycled in the
same way - by being utilized for metal recovery (generally in a secondary smelting operation).
In light of the physical similarity and identical means of recycling of prompt scrap and obsolete
scrap, the Agency has determined that all scrap metal should be classified the same way for
regulatory purposes. Rather than squeeze scrap metal into either the spent material or
by-product category, we have placed it in its own category.
(50 Fed. Reg. at p. 624) Based on these regulatory passages, the lead shot portion of the
pile would be considered scrap metal, and not a spent material. The lead shot is a product
that is made of metal that can be recycled to recover metal content. Furthermore, the lead
shot has not been “discarded” by virtue of its discharge at the shooting range, because the
discharge is within the normal and expected use pattern of the manufactured product. Ac-
cordingly, lead shot would be considered scrap metal for regulatory purposes. Scrap metal
is a solid waste, but it is exempt from the regulatory requirements of Subtitle C when it is
recycled. (40 C.F.R. §261.6(a)(3)(ii).) As part of the Phase IV land disposal restrictions
supplemental rulemaking (which was proposed January 25, 1996 and is expected to be
finalized in April 1997), processed scrap metal and two categories of unprocessed scrap
metal that is being recycled would be excluded from RCRA jurisdiction.
Appendix D - Page D-5
BMP for Lead at Outdoor Shooting Ranges
Please note that this discussion of the regulatory status is limited to the lead shot portion of
the pile as you requested. To the extent that the entire pile exhibits the ignitability or reactive
characteristic of hazardous waste, the mixture of materials would be considered hazardous
waste and not scrap metal. The scrap metal designation for the lead shot would be appli-
cable only to the extent that the lead shot could be segregated from the other materials in
the pile.
I hope that this guidance on the regulatory status of lead shot recovered from shooting
ranges provides you with the clarification that you needed. If you have any questions or
would like to discuss this matter further, please contact me.
Appendix D - Page D-6
BMP for Lead at Outdoor Shooting Ranges
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Appendix D - Page D-7
BMP for Lead at Outdoor Shooting Ranges
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
APR 29 1997
Mr. John P.Cahill
Acting Commissioner
State of New York
Department of Environmental Conservation
Albany, New York 12233-1010
Dear Mr. Cahill:
Thank you for your letter of April 3, 1997 to Administrator Browner requesting a
clarification of the Environmental Protection Agency (EPA) Final Military Munitions Rule
regarding the extension of its range clearance principles to non-military ranges. Although
the final rule addresses only military ranges, we agree with your view that the range clear-
ance principles apply equally to non-military ranges [see comment no. 5 on page 36 of the
enclosed excerpt from the Military Munitions Final Rule Response to Comments Back-
ground Document].
We are aware of the State of New York’s active leadership role in the clean-up of
private firing ranges. We appreciate your writing in support of the range clearance aspects
of the final Military Munitions Rule and we will consider your suggestions that we issue
broader guidance on the applicability of its principles to non-military ranges.
Sincerely yours,
Elizabeth Cotsworth, Acting Director
Office of Solid Waste
Enclosure
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Appendix E - Page E-1
BMP for Lead at Outdoor Shooting Ranges
Appendix E:
Template for an Environmental
Stewardship Plan for Management
of Lead Shot/Bullets
Instructions
EPA encourages outdoor shooting ranges to adopt and implement the Best Management
Practices (BMPs) found in this manual. To this end, it is recommended that ranges first
prepare an Environmental Stewardship Plan (ESP or Plan), which gathers information
about, and guides evaluation of, site specific conditions of each range. As such, the ESP
assists in selection of appropriate BMPs.
This document serves as a template that may be used by sportsmen’s clubs and shooting
ranges in their preparation of an ESP. This template was adapted from Appendix C of the
National Shooting Sports Foundation’s manual, Environmental Aspects of Construction and
Management of Outdoor Shooting Ranges (the NSSF manual.) This template is only a tool
to assist in making ESP preparation easier and can, and in some cases should, be modified
to incorporate specific information relative to your club and its ranges. It is intended to be
used in conjunction with a full understanding of the NSSF, U.S. Environmental Protection
Agency (EPA) and, for ranges in Florida, Florida Department of Environmental Protection
(DEP) manuals for the safe management of lead at outdoor shooting ranges. This template
is intended to encourage ranges to prepare ESPs and submit them to EPA or NSSF to
obtain a Certificate of Recognition from EPA. In this regard, either the following template or
the NSSF template is recommended for use in conjunction with EPA’s Certificate of
Recognition program.
An electronic copy of this template is available on EPA’s shooting range website
(http://www.epa.gov/region2/leadshot) in several formats.
Disclaimer: This template does not serve as a substitute for understanding the concepts and
techniques discussed in the EPA manual or other manuals. This template is not to be used
as a substitute for consultation with scientists, engineers, attorneys, other professionals, or
U.S. EPA.
Appendix E - Page E-2
BMP for Lead at Outdoor Shooting Ranges
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Appendix E - Page E-3
BMP for Lead at Outdoor Shooting Ranges
Environmental Stewardship Plan for Management of
Lead/Bullets at Outdoor Shooting Ranges
Club Name
Address
City/Town, State & Zip Code
Phone #:
Date
Appendix E - Page E-4
BMP for Lead at Outdoor Shooting Ranges
Table of Contents
❑Introduction
•Mission Statement
•Purpose
•Goal
•Delete
❑Site Assessment
•Description of Ranges and Support Facilities
•Existing Environmental Conditions
- Trap and Skeet Fields
- Sporting Clays Course
- Rifle and Black Powder Range(s)
- Outdoor Handgun Range(s)
❑Trap and Skeet Fields
•Action Plan
- Potential Management Options
- Selection of Management Options to be Implemented
- Options Selected
a) Management Actions
b) Operational Actions
c) Construction Actions
•Plan Implementation
- Schedule for Implementation
- Responsibilities
❑Rifle, Black Powder, and Outdoor Handgun Ranges
•Action Plan
- Potential Management Options………………………………...
- Selection of Management Options to be Implemented………...
- Options Selected……………………………………………….
a) Management Actions…………………………………………...
b) Operational Actions…………………………………………….
c) Construction Actions…………………………………………...
•Plan Implementation………………………………………………………..
- Schedule for Implementation……………………………………….
- Responsibilities……………………………………………………..
Appendix E - Page E-5
BMP for Lead at Outdoor Shooting Ranges
Table of Contents (continued)
❑Sporting Clays Course…………………………………………………………….
•Action Plan………………………………………………………………….
- Potential Management Options………………………………...
- Selection of Management Options to be Implemented………...
- Options Selected……………………………………………….
a) Management Actions……………………………………...
b) Operational Actions……………………………………….
c) Construction Actions……………………………………...
•Plan Implementation………………………………………………………..
- Schedule for Implementation……………………………………….
- Responsibilities……………………………………………………..
❑Measuring Success………………………………………………………………...
•Vegetation…………………………………………………………………..
•Soil and Runoff pH…………………………………………………………
•Erosion……………………………………………………………………...
❑Plan Review and Revisions………………………………………………………
Figures
Figure 1: Site Location Map
Figure 2: Facilities Diagram
(Additional figures, as appropriate)
Tables
Table 1:
Table 2:
Appendices
Appendix A:
Appendix B:
(Additional Appendices, as appropriate)
Appendix E - Page E-6
BMP for Lead at Outdoor Shooting Ranges
Introduction
The XYZ Club, Inc. is located at 123 X Road in Anytown, USA…
Mission Statement
The XYZ Club, Inc. is committed to…
- Purpose:
The Purpose of this Environmental Stewardship Plan (i.e., the Plan) is to:
•Identify potential environmental concerns that may exist;
•Identify, evaluate, and prioritize appropriate actions to manage lead shot and bullets
safely, as well as identifying and addressing environmental concerns;
•List short- and long-term steps needed for implementation;
•Develop an implementation schedule;
•Identify ways to measure the Plan’s success;
•Evaluate annual progress made towards achieving environmental stewardship goals;
•etc.
- Goal – To minimize the release of lead into the environment.
Activities to Reach Goal:
Examples include:
Avoid shooting over and into water and wetlands.
Prevent off-site migration of lead through groundwater and surface water runoff.
Conduct lead recovery.
Discourage ingestion of lead by wildlife.
Maintain soil pH between 6.5 and 8.5 in the shotfall zone.
Site Assessment
Description of Ranges and Support Facilities
The XYZ Club has an x position Trap Range, a y position Skeet Range, a z position Sporting Clays
Course, and a q position Small Arms Range. These ranges are located in a rural setting and are
oriented away from residential areas and surface water bodies.
[Briefly describe each range, its dimensions, orientation, vegetative cover, numbers of shooters and
targets used per year, wildlife usage, etc.]
Existing Environmental Conditions
[Describe any known environmental conditions associated with the ranges. This might include type
of soil, depth to groundwater, soil pH, drainage to surface water, unique animal or bird populations,
etc. Refer to figures, tables, the results of surveys, inspections, professional opinions, etc.]
Appendix E - Page E-7
BMP for Lead at Outdoor Shooting Ranges
- Trap and Skeet Fields
- Sporting Clays Course
- Rifle and Black Powder Range(s)
- Outdoor Handgun Range(s)
Trap and Skeet Fields
Action Plan
[Briefly describe the management options selected.]
- Potentially Applicable Management Options
[See EPA or NSSF guidance manual for full listing of options]
Examples include:
- Vegetate sparse grass area of trap/skeet field.
- Reorient trap field to avoid lead shot entering wetlands.
- Reorient sporting clays stations to maximize the overlap of falling shot into the open field where
it can be more easily recovered for recycling.
- Limit use of the trap/skeet range to only those stations that do not have wetland area within the
shotfall zone.
- Apply lime to shotfall zones if soil test results indicate this would be beneficial.
- Prepare fields for lead reclamation.
- Get bids for lead reclamation project.
- Conduct lead reclamation within the trap/skeet shotfall zones.
- Change mowing frequency to closely mow grass in shotfall zones.
- Construct lean-tos at backstop berms.
- Construct a lime lined drainage swale for stormwater management.
- List additional Best Management Practices that may be appropriate to your club.
In addition to appropriate site-specific management options, the list should always include conduct-
ing lead reclamation within the berm for rifle and pistol ranges and conducting lead reclamation within
the trap, skeet, and sporting clays shotfall zones.
- Selection of Management Options to be Implemented
Option x:
Option y:
Option z:
[Describe why the above options were selected and the general roles of club officers, the member-
ship, and outside consultants, as applicable, in implementation.]
Appendix E - Page E-8
BMP for Lead at Outdoor Shooting Ranges
In order to implement the options selected, the following actions are necessary.
a) Management Actions: [Examples include: assign personnel responsible for initiating,
conducting, and completing the alternatives selected above.]
b) Operational Actions: [Examples include: collect soil samples for pH analysis, consult with
USDA’s Natural Resources Conservation Service and/or the county Cooperative Extension
Service regarding best suited vegetative management recommendations.]
c) Construction Actions: [Examples include: do site preparation work, get bids, institute mowing
and vegetative management recommendations, reorient shooting position as appropriate.]
Plan Implementation
- Schedule for Implementation
Winter/Spring: [Examples include: pH survey, contact local officials for vegetation management
recommendations, reorient shooting positions as appropriate, realign shooting positions as appropri-
ate.]
Summer/Fall: [Examples include: prepare site for reclamation project, apply lime/fertilizer/seed, get
bids for berm lean-tos/reclamation. As a rule of thumb, 50 pounds of lime per 1,000 square feet
should raise soil pH by 1 once the residual acidity is overcome.]
- Responsibilities
[Specific duties (i.e., the trap/skeet chairman/chairmen will…, The club treasurer will…, The mem-
bership will provide the labor to…)]
Rifle, Black Powder, and Outdoor Handgun Range(s)
Action Plan
[Briefly describe the management options selected.]
Potentially Applicable Management Options
[See EPA or NSSF guidance manual for full listing of options]
Examples include:
- Culvert the stream through the shooting ranges.
- Vegetate the backstop berm(s) to minimize erosion.
- Construct a lime lined drainage swale for stormwater management.
- Apply lime to the berm and foreground if pH test determines it is necessary.
- Begin planning a lead reclamation project.
- Construct lean-tos at berms.
- List additional Best Management Practices that may be appropriate to your club.
Appendix E - Page E-9
BMP for Lead at Outdoor Shooting Ranges
Selection of Management Options to be Implemented
Option x:
Option y:
Option z:
[Describe why the above options were selected and the general roles of club officers, the member-
ship, and outside consultants, as applicable, in implementation.]
In order to implement the options selected, the following actions are necessary.
a) Management Actions: [examples include: assign personnel responsible for initiating,
conducting, and completing the alternatives selected above.]
b) Operational Actions: [examples include: collect soil samples for pH analysis, consult with
USDA’s Natural Resources Conservation Service and/or the county Service Forester
regarding best suited vegetative management recommendations.]
c) Construction Actions: [examples include: do site preparation work, get bids, institute mowing
and vegetative management recommendations, reorient shooting position as appropriate.]
Plan Implementation
- Schedule for Implementation
Winter/Spring: [examples include: pH survey, contact local officials for vegetation management
recommendations, reorient shooting positions as appropriate, realign shooting positions as appropri-
ate.]
Summer/Fall: [examples include: prepare site for reclamation project, apply lime/fertilizer/seed, get
bids for berm lean-tos/reclamation.]
- Responsibilities
[Specific duties (i.e.: the small arms range chairman/chairmen will…,The club treasurer will…, The
membership will provide the labor to…)]
Sporting Clays Course
Action Plan
- Potentially Applicable Management Options
[See EPA or NSSF guidance manual for full listing of options]
- Selection of Management Options to be Implemented
- Options Selected
Appendix E - Page E-10
BMP for Lead at Outdoor Shooting Ranges
Plan Implementation
- Schedule for Implementation
- Responsibilities
Measuring Success
By monitoring the success of the Plan, the club is best prepared to make whatever changes may be
necessary to reinforce success and make the most of environmental stewardship efforts. Below
are some examples of areas to monitor:
Lead Recovery
[Document the quantity (pounds) of lead recovered and recycled, along with the cost of conducting
the activities.]
Vegetation
[The density of vegetation growth should be measured throughout the growing season, especially in
areas of sparse growth where steps have been taken to increase the vegetative cover. This is can
be done by taking periodic photographs (e.g., once a month) from the same places to document the
impact of the Plan.]
Wildlife
[Keep a log of visual observations made regarding the frequency of range usage by the variety of
species in your area.]
Soil and Runoff pH
[Track soil and runoff pH through semiannual monitoring and adjust the amount of lime applied to
different areas of the range to maintain a pH level that will prevent lead from dissolving (i.e., a pH of
6.5-8.5).]
Erosion
[Again, keeping a photographic record of problem areas best prepares your club to document
achievements and adjust the Plan as appropriate.]
Plan Review and Revisions
Review the Plan on an annual basis. Update the Plan as needed and schedule activities for subse-
quent years. Make recommendations for future club officers to consider when updating the Plan and
designating future activities to be conducted (tell them what worked, what didn’t work, and what still
needs to be done.)
Appendix E - Page E-11
BMP for Lead at Outdoor Shooting Ranges
FIGURES
Figure 1
Facility diagrams
Figure 2
Resource maps (USGS topographic map, wetlands maps, soil survey maps, FEMA
floodplain map, etc.)
Figure 3 (Optional)
Site photographs
Figure 4 (Optional)
Aerial photo of range and surrounding area
Appendix A
(Optional)
Appendix B
(Optional)
Appendix E - Page E-12
BMP for Lead at Outdoor Shooting Ranges
[Insert other figures as necessary to support the text]
Other figures may include an aerial photograph, and sketches of the
Club property in general and/or specific ranges in particular.
Example:
Appendix E - Page E-13
BMP for Lead at Outdoor Shooting Ranges
[Insert Site Location Map Here]
Typically, a Site Location Map is cut from a USGS Topographic Map of you Club’s area. The Club
should be centered on the map. Indicate the property boundaries and layout of the range.
Appendix E - Page E-14
BMP for Lead at Outdoor Shooting Ranges
Appendix A
Information from USDA, Natural Resources
Conservation Service [and/or county Cooperative
Extension Service]
[concerning soil and vegetation management recommendations]
Appendix E - Page E-15
BMP for Lead at Outdoor Shooting Ranges
Appendix B (etc.)
[For other supporting documentation as needed.]
United States Environmental Protection Agency290 BroadwayNew York, NY 10007-1866Official BusinessPenalty for Private Use $300Forwarding and AddressCorrection RequestedEPA-902-B-01-001Revised June 2005FIRST-CLASS MAILU.S. POSTAGEPAIDMAILED FROM ZIP CODE 10007PERMIT NO. G-35U.S. EnvironmentalProtection AgencyRegion 2
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 10
Exhibit 10
National Institute for Occupational Safety and Health (NIOSH) Alert –
Preventing Exposures to Lead and Noise at Indoor Firing Ranges
This document is in the public domain and may be freely copied
or reprinted.
DISCLAIMER
The findings and recommendations in this document were developed by the National
Institute for Occupational Safety and Health (NIOSH) in its role of conducting re-
search and making recommendations to prevent work-related illnesses and injuries.
They are designed to protect the health and safety of persons employed at firing
ranges, and the health and safety of shooters who use the range in a job-related ca-
pacity, such as law enforcement officers or others for whom training in the handling of
firearms is a condition or factor of employment.
Mention of any company or product does not constitute endorsement by NIOSH. In
addition, citations to Web sites external to NIOSH do not constitute NIOSH endorse-
ment of the sponsoring organizations or their programs or products. Furthermore,
NIOSH is not responsible for the content of these Web sites.
ORDERING INFORMATION
To receive NIOSH documents or more information about occupational safety and
health topics, contact NIOSH at
1–800–CDC–INFO (1–800–232–4636)
TTY: 1–888–232–6348
E-mail: cdcinfo@cdc.gov
or visit the NIOSH Web site at www.cdc.gov/niosh.
For a monthly update on news at NIOSH, subscribe to NIOSH
eNews by visiting www.cdc.gov/niosh/eNews.
DHHS (NIOSH) Publication Number 2009–136
April 2009
Safer • Healthier • People™
Insert Employer Factsheet
Preventing Occupational Exposures to Lead
and Noise at Indoor Firing Ranges
WARNING!
Workers at indoor firing ranges may be exposed to hazardous
lead concentrations and noise levels.
Employers and firing range operators should
take the following steps to protect their
workers and shooters from exposure to haz-
ardous lead concentrations and noise levels
at indoor firing ranges:
1. Provide workers and shooters with infor-
mation about hazards and appropriate
training to prevent hazardous exposures.
Provide general information and specific hazard
warnings through workplace postings and tar-
geted training programs.
State the precautions and hygiene practices re-
quired of the firing range workers and shooters.
Train workers and shooters on the actions and
means available to eliminate or limit potential
exposures.
Inform workers and shooters about symptoms
that may indicate a health problem. Also inform
workers that elevated lead levels can occur
without overt symptoms and that a blood lead
level test should be done if there is concern
about an exposure to lead.
Inform pregnant workers and shooters, or those
considering pregnancy, about the possible ad-
verse health effects to the fetus.
2. Establish effective engineering and
administrative controls.
If feasible, provide workers with cleaning facilities
and lockers and develop a mandatory washing
and hygiene program for shooters and workers
to limit personal and take-home contamination.
Install a well-designed supply air and exhaust
ventilation system.
Maintain and replace air filters regularly.
Design and maintain the firing range structure
to limit the transmission of harmful noise levels
to adjacent areas.
Incorporate effective administrative controls in the
workers’ schedules to limit their exposure time
and ensure safe and clean working conditions.
3. Provide workers and shooters with person-
al protective equipment and other protec-
tive measures.
Provide a variety of hearing protection devices
including earplugs and earmuffs.
Provide skin protection, eye protection, and NIOSH
approved respirators for workers involved in clean-
ing lead-contaminated surfaces and areas.
Provide floor mats, knee pads, and shoe cov-
ers when necessary to limit transfer of lead to
clothing.
4. Provide workers with health and medical
monitoring.
Provide workers with initial and periodic medi-
cal monitoring as required by the OSHA lead
standard (29 CFR 1910.25(d)).
Best medical management practices, from or-
ganizations such as the Association of Occu-
pational and Environmental Clinics or those
provided in the journal Environmental Health
Perspectives [Kosnett et al. 2007] should
be recommended for all lead-exposed adults
(workers and shooters).
Provide workers with audiometric evaluations
as required by OSHA noise standard (29 CFR
1910.95(d)(e)(g)(h)).
For additional information, see NIOSH
Alert: Preventing Occupational Expo-
sures to Lead and Noise at Indoor Fir-
ing Ranges [DHHS (NIOSH) Publication
No. 2009–136]. Single copies of the Alert
are available free from the following:
1–800–CDC–INFO (1–800–232–4636)
TTY: 1–888–232–6348
E-mail: cdcinfo@cdc.gov
or visit the NIOSH Web site at
www.cdc.gov/niosh.
For a monthly update on news at
NIOSH, subscribe to NIOSH eNews by
visiting www.cdc.gov/niosh/eNews.
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Disease Control and Prevention
National Institute for Occupational Safety and Health
Preventing Occupational Exposures to Lead
and Noise at Indoor Firing Ranges
WARNING!
Workers at indoor firing ranges may be exposed to hazardous
lead concentrations and noise levels.
Employers and firing range operators should
take the following steps to protect their
workers and shooters from exposure to haz-
ardous lead concentrations and noise levels
at indoor firing ranges:
1. Provide workers and shooters with infor-
mation about hazards and appropriate
training to prevent hazardous exposures.
Provide general information and specific hazard
warnings through workplace postings and tar-
geted training programs.
State the precautions and hygiene practices re-
quired of the firing range workers and shooters.
Train workers and shooters on the actions and
means available to eliminate or limit potential
exposures.
Inform workers and shooters about symptoms
that may indicate a health problem. Also inform
workers that elevated lead levels can occur
without overt symptoms and that a blood lead
level test should be done if there is concern
about an exposure to lead.
Inform pregnant workers and shooters, or those
considering pregnancy, about the possible ad-
verse health effects to the fetus.
2. Establish effective engineering and
administrative controls.
If feasible, provide workers with cleaning facilities
and lockers and develop a mandatory washing
and hygiene program for shooters and workers
to limit personal and take-home contamination.
Install a well-designed supply air and exhaust
ventilation system.
Maintain and replace air filters regularly.
Design and maintain the firing range structure
to limit the transmission of harmful noise levels
to adjacent areas.
Incorporate effective administrative controls in the
workers’ schedules to limit their exposure time
and ensure safe and clean working conditions.
3. Provide workers and shooters with person-
al protective equipment and other protec-
tive measures.
Provide a variety of hearing protection devices
including earplugs and earmuffs.
Provide skin protection, eye protection, and NIOSH
approved respirators for workers involved in clean-
ing lead-contaminated surfaces and areas.
Provide floor mats, knee pads, and shoe cov-
ers when necessary to limit transfer of lead to
clothing.
4. Provide workers with health and medical
monitoring.
Provide workers with initial and periodic medi-
cal monitoring as required by the OSHA lead
standard (29 CFR 1910.25(d)).
Best medical management practices, from or-
ganizations such as the Association of Occu-
pational and Environmental Clinics or those
provided in the journal Environmental Health
Perspectives [Kosnett et al. 2007] should
be recommended for all lead-exposed adults
(workers and shooters).
Provide workers with audiometric evaluations
as required by OSHA noise standard (29 CFR
1910.95(d)(e)(g)(h)).
For additional information, see NIOSH
Alert: Preventing Occupational Expo-
sures to Lead and Noise at Indoor Fir-
ing Ranges [DHHS (NIOSH) Publication
No. 2009–136]. Single copies of the Alert
are available free from the following:
1–800–CDC–INFO (1–800–232–4636)
TTY: 1–888–232–6348
E-mail: cdcinfo@cdc.gov
or visit the NIOSH Web site at
www.cdc.gov/niosh.
For a monthly update on news at
NIOSH, subscribe to NIOSH eNews by
visiting www.cdc.gov/niosh/eNews.
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Disease Control and Prevention
National Institute for Occupational Safety and Health
Insert Worker Factsheet
Preventing Occupational Exposures to Lead
and Noise at Indoor Firing Ranges
WARNING!
Workers at indoor firing ranges may be exposed to hazardous
lead concentrations and noise levels.
Workers should take the following steps to
reduce exposure to hazardous lead con-
centrations and noise levels at indoor firing
ranges:
1. Stay informed.
Understand the safety issues and health hazards
associated with lead and noise exposures.
Follow safe work practices identified by your
employer or range operator.
Participate in all safety training and health
monitoring programs offered by your employer
or range operator.
2. Protect yourself.
Use double hearing protection (earplugs and
earmuffs) whenever possible.
Wear respirators and full protective outer cloth-
ing when performing range maintenance.
Wear gloves and eye protection when using
chemicals to clean weapons or firing range sur-
faces.
3. Use good work practices and personal hygiene.
Wash hands, forearms, and face before eating,
drinking, smoking, or contact with other people.
Change clothes and shoes before leaving the
firing range facilities.
Wash clothes or uniforms used at the firing
range separately from family’s clothing.
4. Know and report symptoms.
Common symptoms of lead poisoning in adults
include nausea, diarrhea, vomiting, poor ap-
petite, weight loss, anemia, excess lethargy or
hyperactivity, headaches, abdominal pain, and
kidney problems.
If you suspect you may have been exposed to
lead, even if you have no symptoms, ask about
having a blood lead level test done.
Exposure to high levels of noise can lead to
hearing loss, tinnitus (ringing in the ear), stress,
anxiety, high blood pressure, gastro-intestinal
problems, and chronic fatigue.
Report any of these symptoms to your employer
or range operator.
Seek medical attention when appropriate.
For additional information, see NIOSH
Alert: Preventing Occupational Expo-
sures to Lead and Noise at Indoor Fir-
ing Ranges [DHHS (NIOSH) Publication
No. 2009–136]. Single copies of the Alert
are available free from the following:
1–800–CDC–INFO (1–800–232–4636)
TTY: 1–888–232–6348
E-mail: cdcinfo@cdc.gov
or visit the NIOSH Web site at
www.cdc.gov/niosh.
For a monthly update on news at
NIOSH, subscribe to NIOSH eNews by
visiting www.cdc.gov/niosh/eNews.
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Disease Control and Prevention
National Institute for Occupational Safety and Health
Preventing Occupational Exposures to Lead
and Noise at Indoor Firing Ranges
WARNING!
Workers at indoor firing ranges may be exposed to hazardous
lead concentrations and noise levels.
Workers should take the following steps to
reduce exposure to hazardous lead con-
centrations and noise levels at indoor firing
ranges:
1. Stay informed.
Understand the safety issues and health hazards
associated with lead and noise exposures.
Follow safe work practices identified by your
employer or range operator.
Participate in all safety training and health
monitoring programs offered by your employer
or range operator.
2. Protect yourself.
Use double hearing protection (earplugs and
earmuffs) whenever possible.
Wear respirators and full protective outer cloth-
ing when performing range maintenance.
Wear gloves and eye protection when using
chemicals to clean weapons or firing range sur-
faces.
3. Use good work practices and personal hygiene.
Wash hands, forearms, and face before eating,
drinking, smoking, or contact with other people.
Change clothes and shoes before leaving the
firing range facilities.
Wash clothes or uniforms used at the firing
range separately from family’s clothing.
4. Know and report symptoms.
Common symptoms of lead poisoning in adults
include nausea, diarrhea, vomiting, poor ap-
petite, weight loss, anemia, excess lethargy or
hyperactivity, headaches, abdominal pain, and
kidney problems.
If you suspect you may have been exposed to
lead, even if you have no symptoms, ask about
having a blood lead level test done.
Exposure to high levels of noise can lead to
hearing loss, tinnitus (ringing in the ear), stress,
anxiety, high blood pressure, gastro-intestinal
problems, and chronic fatigue.
Report any of these symptoms to your employer
or range operator.
Seek medical attention when appropriate.
For additional information, see NIOSH
Alert: Preventing Occupational Expo-
sures to Lead and Noise at Indoor Fir-
ing Ranges [DHHS (NIOSH) Publication
No. 2009–136]. Single copies of the Alert
are available free from the following:
1–800–CDC–INFO (1–800–232–4636)
TTY: 1–888–232–6348
E-mail: cdcinfo@cdc.gov
or visit the NIOSH Web site at
www.cdc.gov/niosh.
For a monthly update on news at
NIOSH, subscribe to NIOSH eNews by
visiting www.cdc.gov/niosh/eNews.
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Disease Control and Prevention
National Institute for Occupational Safety and Health
1
Preventing Occupational Exposures to
Lead and Noise at Indoor Firing Ranges
WARNING!
Workers at indoor firing ranges may be exposed to hazardous
lead concentrations and noise levels.
The National Institute for Occupational
Safety and Health (NIOSH) requests help
in preventing injury and illness in work-
ers at indoor firing ranges in the United
States. Workers are potentially exposed
to hazardous amounts of lead and noise
at these ranges. They include thousands
of employees at the firing ranges as well
as more than a million Federal, State,
and local law officers who train regu-
larly at these facilities. In addition to
workers, 20 million active target shoot-
ers are potentially exposed to lead and
noise hazards at indoor firing ranges.
This Alert presents five case reports that
document lead and noise exposures of
law enforcement officers and students.
The Alert examines firing range opera-
tions, exposure assessment and control
methods, existing regulations, and ex-
posure standards and guidelines.
NIOSH requests that the recommenda-
tions in this Alert be brought to the at-
tention of all firing range owners, op-
erators, workers, and users as well as
safety and health officials, industry as-
sociations, unions, and editors of trade
journals.
BACKGROUND
The Bureau of Justice Statistics estimates
that 105,000 Federal law enforcement of-
ficers and more than 1 million State and lo-
cal police officers are employed in the Unit-
ed States [DOJ 2004]. These officers are
required to train regularly in the accurate
and proficient use of firearms. Indoor fir-
ing ranges have gained wide appeal among
law enforcement agencies because they
offer protection from inclement weather
conditions and can be operated around the
clock under controlled environmental condi-
tions. The National Shooting Sports Foun-
dation estimates that there are 20 million
active target shooters in the United States.
Of those, 13.8 million are rifle shooters
and 10.7 million participate in handgun
target shooting [NSSF 2006]. NIOSH esti-
mates that 16,000 to 18,000 firing ranges
Firing Ranges
2 Firing Ranges
operate in the United States. Some are op-
erated without the benefit of sufficient envi-
ronmental and occupational health controls
in place to effectively protect the health of
shooters and firing range personnel from the
adverse effects of exposure to lead, noise,
and other contaminants. The hazards from
exposure to lead (airborne, ingestion, and
skin), noise, and other contaminants at in-
door firing ranges have been widely inves-
tigated [Valway et al. 1989; Novotny et al.
1987; Price 1989]. Some of these inves-
tigations have documented elevated blood
lead levels and hearing loss—particularly
among employees and instructors.
During the last 2 decades, NIOSH has per-
formed numerous Health Hazard Evaluations
(HHEs) of indoor firing ranges and docu-
mented the hazards of exposure to lead and
noise among firing range operators, workers,
and shooters. In 1975, NIOSH published a
technical document titled Lead Exposure
and Design Considerations for Indoor Fir-
ing Ranges to provide recommendations for
reducing or eliminating hazards associated
with indoor firing ranges [NIOSH 1975].
This Alert highlights the issues inherent in
operating such facilities and addresses ad-
vances in exposure assessment methods,
control technologies, and new regulations
and exposure guidelines.
Although the scope of this Alert is specifi-
cally targeted at indoor firing ranges, overex-
posures to lead and noise at outdoor firing
ranges have been documented in several
studies [Tripathi et al. 1991; Goldberg et al.
1991; Murphy 2007]. Many of the recom-
mendations that are outlined in this Alert
can also be applied to protecting workers
and shooters who use outdoor and covered
firing ranges.
CURRENT REGULATIONS,
RECOMMENDATIONS, AND
OTHER GUIDELINES
The primary sources of exposure standards
and guidelines for the U.S. workplace are
the Occupational Safety and Health Admin-
istration (OSHA) permissible exposure limits
(PELs) (29 CFR* 1910) and the NIOSH rec-
ommended exposure limits (RELs) [NIOSH
1992a]. Most employers are mandated to
follow the OSHA standards; however, since
current standards and regulations are based
on outdated medical information, employ-
ers are encouraged to follow the most pro-
tective criteria.
OSHA Regulations
The Federal OSHA General Industry Lead
Standard (29 CFR 1910.1025) establishes
specific airborne lead exposure levels for
employees working in areas where airborne
lead is present. Lead exposure is determined
through air sampling that measures the con-
centration of lead in the air (the number of
micrograms of lead present in a cubic meter
of air). The standard creates two levels of
exposure, the action level and the PEL. The
action level for airborne lead exposure is 30
micrograms per cubic meter (µg/m3) of air
as an 8-hour time-weighted average (TWA).
If it is determined that airborne lead con-
centrations exceed the action level for more
than 30 days per year, an employer must
provide a medical surveillance program to
the worker consisting of biological monitor-
ing and medical examinations and consulta-
tions. Should a worker’s average blood lead
level (BLL) meet or exceed 50 micrograms
of lead per deciliter (µg/dL) of blood, the
employer is required to temporarily remove
*Code of Federal Regulations. See CFR in references.
3Firing Ranges
the worker from the work area. The OSHA
standard does provide for economic protec-
tion for such medically removed workers.
Medically removed workers cannot return to
jobs involving lead exposure until their BLLs
are below 40 µg/dL. Benefits must be pro-
vided during the period of temporary medi-
cal removal—i.e., the employee continues
to receive the same earnings, seniority, and
other rights and benefits he or she would
have had if they had not been removed. The
OSHA PEL for airborne exposure to lead is
50 µg/m3 as an 8-hour TWA. The PEL is re-
duced for shifts greater than 8 hours using
the formula:
maximum PEL in µg/m3 = 400 / hours
worked per day
If airborne lead levels exceed the PEL for
more than 30 days per year, then an em-
ployer is required to implement additional
monitoring and management activities.
Currently, 24 States and 2 territories ad-
minister and enforce their own occupational
safety and health programs. A list of these
“State Plan States” can be obtained by
contacting the appropriate authority in the
State where the firing range is operated or
through the OSHA Web site at www.osha.
gov. It is important to note that State Plans
must be at least as protective as the Federal
OSHA standards.
For noise exposure, the Federal OSHA stan-
dard for occupational noise exposure (29
CFR 1910.95) specifies a maximum PEL
of 90 decibels, A-weighted (dBA), averaged
over an 8-hour time period. Noise gener-
ated from weapons is classified as impulse
noise. The OSHA standard states that ex-
posure to impulse noise should not exceed
140 decibels (dB) sound pressure level
(SPL). The regulation uses a 5-dB exchange
rate. This means that when the noise level
is increased by 5 dBA, the amount of time
a person can be exposed is cut in half. For
example, a person who is exposed to noise
levels of 95 dBA can be exposed to only
4 hours in order to be within the daily OSHA
PEL. The OSHA standard has an action level
of 85 dBA, which stipulates that an employer
shall administer a continuing, effective hear-
ing conservation program when the 8-hour
TWA equals or exceeds the action level. The
program must include exposure monitoring,
employee notification, observation, an au-
diometric testing program, hearing protec-
tion, training programs, and maintenance of
records. The standard also states that when
workers are exposed to noise levels in ex-
cess of the OSHA PEL of 90 dBA (8-hour
TWA), feasible engineering or administrative
controls shall be implemented to reduce
workers’ exposure levels.
NIOSH Recommendations
The NIOSH REL for airborne lead is 50 µg/ m3
as an 8-hr TWA; airborne concentrations
should be maintained so that a worker’s BLL
remains below 60 µg lead / 100 g of whole
blood [NIOSH 1992a].
In addition to inhalation exposures, lead
from contaminated surfaces and from
firearms discharge can be transferred to
people’s skin, especially the hands. Lead-
contaminated hands can contribute to in-
gestion while handling food, beverages, and
other items that contact the mouth. Skin
exposures often result from hidden hazards
that are not anticipated or recognized, and
hence are inadequately controlled. Con-
trolling lead- contaminated surfaces (and
skin contamination) is highly dependent on
anticipation and identification of lead con-
tamination on surfaces; strict attention and
4 Firing Ranges
adherence to personal hygiene practices;
and appropriate administrative controls
(e.g., hazard communication). Currently,
there are no Federal occupational exposure
limits for lead contamination of surfaces.
However, NIOSH researchers have investi-
gated surface and skin contamination from
lead in a variety of occupational settings and
developed two analytical methods for iden-
tifying lead contamination. NIOSH Method
9100 is a surface-wipe collection method
that can be used to quantitatively determine
surface lead concentrations to a detection
limit of 0.1 µg per sample. Method 9105 is
an instant qualitative wipe method that was
initially designed to detect the presence of
lead on workers’ skin with a limit of identi-
fication of 15 µg per sample. The method
is commercially available under the brand
name Full Disclosure for Lead (US Patent
6,248,593) and can be used for identifying
the presence of lead contamination on en-
vironmental surfaces [NIOSH 1994]. Both
methods are practical and appropriate for
identifying workplace surface lead contami-
nation and evaluating the effectiveness of
skin and surface decontamination for the
purpose of reducing exposure risks. Both
methods will detect the presence of lead
contamination and lead from residues emit-
ted from firearms usage.
NIOSH research shows that washing hands
with soap and water is not completely effec-
tive in removing lead (and other toxic metals)
from the surface of the skin [NIOSH 1992b;
NIOSH 1996; NIOSH 1999]. To remove lead
from skin, NIOSH researchers recently devel-
oped a novel and highly effective skin decon-
tamination/cleansing method [Esswein and
Boeniger 2005].
Regarding noise, the NIOSH REL for noise
(8-hour TWA) is 85 dBA using a 3-dB ex-
change rate (see OSHA regulations in previous
section for an explanation of exchange rates).
NIOSH also recommends that no exposure be
allowed above 140 dB SPL [NIOSH 1998].
Other Guidelines and Best
Management Practices
In addition to the standards and guidelines
identified above, U.S. government agencies
(including the Department of Defense), the
firearm industry, and shooting-sports orga-
nizations have created guidance documents
and best management practices for firing
ranges. Furthermore, the U.S. government
and several professional organizations have
general guidance documents concerning
occupational exposure to lead and noise.
U.S. Government Agencies/Military
Industrial Hygiene Standards and
Guidelines for Firing Ranges
The U.S. Department of Justice (DOJ), Immi-
gration and Naturalization Service† published
a document titled INS/NFU Firing Range De-
sign Standard, which focuses on necessary
considerations for both indoor and outdoor
firing ranges that meet the needs of DOJ
training criteria. These considerations in-
clude lead and noise exposure controls and
evaluations of environmental, occupational
health, and training issues at existing firing
ranges. The standard is intended as a sup-
plemental guide to the U.S. Border Patrol
Facilities Design Guide [DOJ 2002].
The U.S. Environmental Protection Agency
(EPA) Best Management Practices at Out-
door Shooting Ranges, while targeted for
outdoor ranges, provides owners and opera-
tors of outdoor firing ranges with information
†Immigration and Naturalization Service is now called
the U.S. Citizenship and Immigration Services and is
part of the U.S. Department of Homeland Security.
5Firing Ranges
on lead management and recommenda-
tions for reducing lead contamination [EPA
2005].
The U.S. military operates more than 3,000
indoor firing ranges. The U.S. Navy Envi-
ronmental Health Center developed a ref-
erence guide titled Indoor Firing Ranges
Industrial Hygiene Guide to provide firing
range operators, industrial hygienists, safety
professionals, and technicians with guide-
lines and recommendations on firing range
operation and maintenance [USN 2002]. In
addition, the U.S. Army Corps of Engineers
published Design Manual for Indoor Firing
Ranges in 1990 to provide guidance for
new design considerations, retrofitting ex-
isting indoor firing ranges, and safety and
maintenance requirements for Department
of Defense range facilities [USACE 1990].
Although these publications discuss numer-
ous issues involved with firing range opera-
tion, they do not represent a comprehensive
listing of the material available from govern-
ment agencies and the military.
Firearm Industry Guidelines
The National Association of Shooting Ranges
(NASR), a division of the National Shooting
Sports Foundation (NSSF), has developed a
manual titled Lead Management and OSHA
Compliance for Indoor Shooting Ranges
[NASR 2004]. This manual addresses the
potential of lead exposure at firing ranges
and presents methods for managing expo-
sures as well as compliance with the OSHA
lead standard 29 CFR 1910.1025. This
document was developed in partnership
with OSHA and NIOSH.
Shooting Sports Organizations
The National Rifle Association (NRA) man-
ual titled The NRA Source Book: A Guide
to Planning and Construction provides basic
and advanced guidance to assist in plan-
ning, designing, constructing, and maintain-
ing shooting range facilities [NRA 1999].
General Guidance Concerning Occupa-
tional Exposure to Lead and Noise from
the U.S. Government and Professional
Organizations
Department of Health and Human
Services
The Department of Health and Human Ser-
vices (DHHS) identified occupational lead
exposure as one of the national health ob-
jectives. In its publication Healthy People
2010, the DHHS proposed the elimination
of occupational lead exposures that result
in workers having blood lead concentrations
greater than 25 µg/dL, and encouraged
health departments to make elevated BLLs
in children and adults a notifiable condition
nationwide [DHHS 2000].
American Conference of Governmental
Industrial Hygienists (ACGIH)
The American Conference of Governmen-
tal Industrial Hygienists (ACGIH) has ad-
opted a threshold limit value (TLV) for lead
of 50 µg/ m3 (8-hour TWA), with worker BLLs
to be controlled at or below 30 µg/dL. The
ACGIH has designated lead a confirmed ani-
mal carcinogen [ACGIH 2006]. The ACGIH
also states that evidence suggests expo-
sure during pregnancy to BLLs in excess of
10 µ g / dL results in developmental effects
such as depressed intellectual development
in children [ACGIH 2001].
The ACGIH TLV for noise is 85 dBA (8-hour
TWA) with a 3-dB exchange rate and
140 dB SPL as a maximum exposure limit.
The ACGIH states that exposure to certain
6 Firing Ranges
chemicals may result in hearing loss. In
settings where workers might be exposed
to noise as well as organic solvents (e.g.,
toluene, styrene, or xylene), heavy metals
(e.g., lead, manganese, or organo-tin com-
pounds), or other compounds (e.g., n-butyl
alcohol or carbon monoxide), periodic au-
diograms are advised and should be care-
fully reviewed. The ACGIH also states that
evidence suggests noise exposure in excess
of a C-weighted, 8-hour TWA of 115 dB or a
peak exposure of C-weighted 155 dB to the
abdomen of pregnant workers beyond the
fifth month of pregnancy may cause hearing
loss in the fetus.
Association of Occupational and
Environmental Clinics
The Association of Occupational and Envi-
ronmental Clinics (AOEC) has reviewed cur-
rent literature concerning lead exposure and
health effects [AOEC 2007]. The AOEC has
determined that the evidence provided by
current health effects studies calls for an
update of guidance for professionals in-
volved with medical assessment and treat-
ment of lead-exposed workers. Among other
provisions in their guidance, the AOEC has
determined that current evidence supports
the need for: 1) qualitative assessment of
the need for inclusion in a medical surveil-
lance program for lead workers in addition to
inclusion in a medical surveillance program
based on documentation of exposure to
airborne lead at a concentration above the
OSHA action level; 2) increased frequency
of BLL testing; 3) removal from exposure
to lead for workers with BLL of 30 µg/dL
or more; and 4) education of workers con-
cerning occupational exposure to lead and
provision of necessary personal protective
equipment and administrative measures to
prevent both occupational and take-home
exposure to lead.
Environmental Health Perspectives
Mini-Monograph
The March 2007 edition of Environmental
Health Perspectives included a Mini-Mono-
graph on adult lead exposure. Recommenda-
tions in this document include the following:
1) medical surveillance for all lead-exposed
workers should include quarterly BLL testing
for individuals with blood lead concentrations
between 10 and 19 µg / dL, and semiannual
testing when sustained blood lead concen-
trations are < 10 µg/dL; 2) pregnant wom-
en should avoid occupational or avocational
lead exposure that would result in blood
lead concentrations > 5 µg/ dL; 3) removal
from exposure to lead for workers with BLL
of 30 µg/dL or more or if a worker has a sus-
tained BLL above 20 µg/dL; and 4) annual
education of lead workers concerning occu-
pational exposure to, and control of, lead
hazards as well as ongoing access to health
counseling regarding lead-related health
risks to prevent both occupational and take-
home exposure to lead [EHP 2007].
CASE REPORTS
Many studies have shown health risks to
workers from lead and noise exposures at
firing ranges. The five case reports present-
ed here describe the causes of these expo-
sures and methods for controlling them.
Case 1—Lead exposures of law
enforcement trainees
Seventeen law enforcement trainees were
studied for 3 months during firearms instruc-
tion at an indoor firing range to determine
their risk from lead exposure [Valway et al.
1989]. BLLs were measured before train-
ing began and every 4 weeks during the
7Firing Ranges
training. Airborne lead concentrations were
measured three times during the instruction
period. BLLs rose from a pre-training mean
of 6.5 to 50.4 µg/dL post training. Mean
airborne lead concentrations were greater
than 2,000 µg/m3, more than 40 times the
OSHA PEL of 50 µg/m3. During the study,
two changes were made to the ventilation
system. The first corrected the positive pres-
sure inside the range that had allowed lead-
contaminated air to flow from the range into
other parts of the building whenever the
range door was opened. The second change
consisted of placing fins on the air supply
grille to cause smoother air flow across the
firing line and to decrease air turbulence. The
adjustments resulted in a large decrease of
airborne lead concentrations, depending on
booth location. Airborne lead concentrations
dropped to below detectable levels in the
control room and classroom after the first
adjustment. Airborne lead concentrations
were reduced substantially (94% to 97%)
by using ammunition that had nylon-coated
and copper-jacketed bullets.
Case 2—Lead exposures of
school rifle teams
The Alaska Environmental Public Health Pro-
gram initiated a statewide review of school-
sponsored rifle teams after a team coach was
found to have an elevated BLL of 44 µg / dL
[State of Alaska 2003]. The review initial-
ly examined six rifle teams using three in-
door firing ranges. Thirty-six students and
35 adults (including family members and
6 coaches) participated in the blood lead
Figure 1. A law enforcement agency five-booth indoor firing range.
8 Firing Ranges
testing. Two teams used a firing range that
observed a regularly scheduled cleaning
procedure and had a written protocol for
maintenance and lead concentration moni-
toring. The geometric mean BLL measure-
ments for those two teams were not elevated
(1.3 µg / dL and 3.9 µg/dL, respectively).
One team used a firing range-multi-use area
that for 11 years had not been evaluated
for lead. The student shooters showed small
but measurable lead exposure with a geo-
metric mean of 8.1 µg/dL.
The other three teams used a firing range
that was later documented to have extensive
lead contamination. The teams showed el-
evated blood levels with geometric means of
27.9 µ g / dL, 12.0 µg/dL, and 12.2 µg/dL re-
spectively. The coaches of the 3 teams had
BLLs with a geometric mean of 12.4 µg / dL;
the highest level was 31 µg/dL, which is above
the level considered elevated (≥ 25 µg/dL)
for adults. That firing range was voluntarily
closed and arrangements were made for a
thorough environmental evaluation.
Case 3—Lead exposures of police
officers
A NIOSH Health Hazard Evaluation [NIOSH
1997] was conducted in a five-booth indoor
firing range to examine potential exposure to
lead among 30 police officers who used the
firing range for training and firearms quali-
fication (Figure 1). The firing range, which
was located in a police department building,
was used by other area police departments
as well. The firing range ventilation system
was independent of the rest of the building,
but most of the firing range’s exhaust air was
recirculated through 90% to 95% efficient
filters before being directed back into the
firing range. Users cleaned the firing range
by dry sweeping and collecting shell casings
from the floor by hand. The bullet trap was
cleaned every 2–3 years. Average airborne
lead concentrations were 144 µg/m3 and
230 µg/m3 on 2 separate survey dates. Area
airborne lead samples detected lead in the
control room, in a hallway outside the firing
range, and at the rooftop air handling unit.
Inspection of the HVAC system on the first
survey found several filters missing, but were
in place during the second survey. NIOSH
found that the firing range was under posi-
tive pressure, with the smell of gun smoke
noticeable immediately when firing started
on the firing range. The measurements of
supply air and exhaust air-flow rates were
much lower than designed and yielded an
average air velocity of 25 feet per minute
(fpm) or 0.127 meters per second (m/s) at
the firing line. Pressure gauges on the HVAC
system did not appear to be working proper-
ly. Smoke tests revealed backflow patterns
even when no one was standing at the fir-
ing line. NIOSH recommended changes in
the ventilation system, a standard operat-
ing procedure for maintenance, improved
clean-up and personal hygiene practices, a
written respiratory protection program, am-
munition substitution, and BLL monitoring.
Case 4—Lead, take-home lead,
and noise exposures of Federal
law enforcement students
NIOSH and the National Center for Envi-
ronmental Health (NCEH) participated in a
series of collaborative evaluations of indoor
and outdoor firing ranges and related facili-
ties at the FBI Firearms Training Unit (FTU)
[NIOSH 1991]. FTU facilities consisted of
an indoor training range with 23 shooting
booths, a one-booth firearms testing range,
and seven outdoor training ranges. The eval-
uations included lead and noise exposures
during firearms training among firing range
9Firing Ranges
technicians, gunsmiths, and firing range in-
structors. The evaluations also included the
potential for take-home lead contamination
of workers’ vehicles and homes, and for ex-
posure of their families.
Sixteen full-time firearms instructors spent
approximately 30 hours per week on the fir-
ing ranges. Sixty-one personal breathing zone
samples and 30 area samples were collected
to measure airborne lead. Airborne lead con-
centrations ranged up to 51.7 µg/m3 for the
instructors, 2.7 µg/m3 for firing range techni-
cians, and 4.5 µg/m3 for gunsmiths. Short-
term exposures while the custodians cleaned
the firing range were as high as 220 µg/m3.
Results of carpet dust sampling collected in
14 dormitory rooms used by FBI students
and 14 rooms used by non-students showed
that significantly higher lead concentrations
were found in the students’ rooms (means
of 214 µg/g and 65 µg/g respectively). The
presence of lead in carpet samples suggests
that FBI students unknowingly contaminated
their living quarters with lead residues brought
back to their quarters from the firing range.
The baseline and the most recent audiomet-
ric testing results were available for 14 of
the 16 FBI instructors. Evaluations of the au-
diograms revealed that 9 of the 14 instruc-
tors (64%) had hearing losses that met the
OSHA standard threshold shift criterion (i.e.,
changes relative to baseline of 10 decibels
or more in the average hearing level at 2000,
3000, and 4000 Hz). Audiometric testing
results were only available for one of the six
firing range technicians, and this worker’s re-
sults also met the OSHA standard threshold
shift criterion. No audiometric testing results
were available for the gunsmiths.
NIOSH recommended modifications to
the indoor firing range ventilation system,
Figure 2. Noise and lead exposure assessment of law enforcement officers at a 20-lane indoor firing range.
10 Firing Ranges
improved personal hygiene practices, am-
munition substitution, using double hearing
protection devices, establishing a hearing
conservation program for workers exposed
to gunfire, and continued BLL monitoring.
Case 5—Noise exposures
of Federal and local law
enforcement officers
NIOSH investigators conducted live-fire noise
exposure evaluations [Kardous et al. 2003;
NIOSH 2003; Murphy 2007] of Federal and
local law enforcement officers at indoor and
outdoor firing ranges to characterize salient
acoustic parameters associated with weap-
ons noise and to provide guidelines for safe
exposure (Figure 3). Measurements were
conducted on a representative cross sec-
tion of law enforcement firearms (the Ber-
etta .40-caliber pistol, Remington 12-gauge
shotgun, and Bushmaster M4 .223-caliber
assault rifle). Indoor and outdoor measure-
ments were also obtained for the Smith
and Wesson .357-caliber revolver, the Colt
.45-caliber and 9-mm pistols, the Glock
.40-caliber pistol, the Heckler & Koch H&K
53 and H&K 36 assault rifles, and Colt AR15
.223-caliber rifles. Measurements were con-
ducted using a ¼-inch Bruel & Kjaer model
4136 microphone, digital audio tape record-
ers with a 48 kHz sampling rate or were ac-
quired directly to a computer laptop using 96
kHz data acquisition board. Analyses on the
digitized waveforms were conducted using
software tools built in Matlab. Peak sound
pressure levels ranged from 155–168 dB
SPL. Figure 4 shows the peak sound pres-
sure levels generated from various weap-
ons at an indoor firing ranges. A-weighted,
equivalent (averaged) levels ranged from
124–128 dBA. Hearing protectors were
Figure 3. Emissions from the discharge of firearms.
11Firing Ranges
evaluated using the Institut de Saint-Louis
(ISL) artificial head mannequin built specifi-
cally for measuring impact and impulse noise.
Earmuffs with safety glasses had a peak re-
duction of 18 dB. The mean peak reduction
for earmuffs was 26 dB, while earplugs alone
provided a mean peak reduction of 24 dB.
The mean peak reduction for the combined
earmuff and earplugs was 44 dB.
NIOSH recommended several noise abate-
ment strategies and modifications to the fir-
ing range structure to reduce the transmission
of airborne and structural borne sounds; the
use of double-hearing protection to ensure
maximum protection against impulsive noise,
improper fitting and other incompatibility with
other protective equipment; and the estab-
lishment of a hearing conservation program.
workers’ and patrons’ exposures to lead. En-
vironmental factors include the type of ven-
tilation system used at the firing range, the
types of ammunition used, and the length of
time that shooting occurs. Exposure risk fac-
tors include the type and frequency of work
practices conducted at the range, particularly
those involving cleaning the firing range and
other maintenance activities.
As demonstrated by the case studies, prop-
er ventilation, good housekeeping practices,
and basic personal hygiene practices will
limit or eliminate the risk of lead exposure.
In addition to lead exposure, the discharge
of firearms produces peak noise levels that
exceed the occupational health limits of
140 dB SPL. The case studies illustrate
the need to assess impulse noise exposure
correctly by using proper sound measuring
instruments and techniques, and the im-
portance of using double hearing protection
while shooting as part of an overall hearing
conservation program.
Potential health problems from exposure to
lead and noise can be reduced or prevented
by following the recommendations outlined
in this Alert.
RECOMMENDATIONS
Controlling exposures to occupational haz-
ards is the fundamental method of protect-
ing workers. Traditionally, NIOSH uses a hier-
archy of controls as a means of determining
how to implement feasible and effective
solutions to reduce or eliminate workplace
hazards. One representation of this hierar-
chy can be summarized as follows:
Elimination or substitution
0.45Colt 1991A1ParOrdinance P10Glock 22Glock 27Remington 1187Remington 870Sig Sauer P228Colt Pocket 9Smith & Wesson 586Smith & Wesson 686175
170
165
160
155
150
145 0.40
Weapon CaliberPeak Impulse Level (dB SPL)12Ga 9 mm 0.357
CONCLUSIONS
The case reports described in this Alert sug-
gest that employers, workers, and the gener-
al public may have an increased likelihood of
exposure to lead through inhalation, skin con-
tamination, and ingestion, and therefore the
increased risks associated with the potential
toxic health effects from lead. Numerous fac-
tors and routes of exposure can contribute to
Figure 4. Peak noise levels from various small firearms.
12 Firing Ranges
Engineering controls
Administrative controls
Personal protective equipment
Control methods high on the list above are
potentially more effective and protective
than those appearing lower. Following the
hierarchy normally leads to the implemen-
tation of inherently safer systems that sub-
stantially reduce the risk of illness or injury.
The elimination and substitution control
methods are most effective at reducing haz-
ards, but they are also the most difficult to
implement within an existing process. If the
process is still at the design or development
stage, elimination and substitution of haz-
ards might be inexpensive and simple to im-
plement. Engineering controls are used to
remove a hazard or place a barrier between
the worker and the hazard. Well-designed
engineering controls can be highly effec-
tive in protecting workers and are typically
independent of worker interactions. Admin-
istrative controls and personal protective
equipment are frequently used with existing
processes where hazards are not particularly
well controlled.
In addition to the previous control methods,
employer and worker education and training
are an essential part of any comprehensive
management program.
Pursuant to OSHA’s lead standard, worker
exposure monitoring is covered under 29
CFR 1910.1025(d), and the medical surveil-
lance provisions of the standard are covered
at 29 CFR 1910.1025(j). Medical removal
protection is covered in paragraph (k).
Controlling lead and noise hazards at in-
door firing ranges may present unique and
different challenges depending on several
factors. These include appropriate design,
construction, and maintenance of the range,
appropriate and engineered ventilation sys-
tems, proper management, adequate and
proper housekeeping and personal hygiene
practices to limit exposures to lead.
Ammunition substitution
The substitution of less-toxic materials in the
workplace is a primary preventive measure
in occupational health. The primary sourc-
es of lead exposure at indoor firing ranges
are lead bullets and cartridge primers. Lead
fumes and dust are emitted from the ex-
posed base of an unjacketed bullet due to
contact with hot propellant gases and the
physical effects of heat and friction acting
on the bearing surface of an unjacketed bul-
let passing through the bore at high velocity.
The use of jacketed (both base and bearing
surface) or non-lead bullets are shown to
reduce lead emissions at the firing range by
as much as 80%.
It is important to note that product substi-
tution is not necessarily an effective solu-
tion for indoor firing ranges due to certain
training restrictions and operational require-
ments. Issues such as differences in trajec-
tory, unknown reliability, increased cost of
non-lead primers and bullets, and increased
barrel wear can play a major role in deter-
mining whether substitution is a viable so-
lution. Further, mixing spent lead bullets
with metals from non-lead alternatives may
render the material unfit for recycling and
therefore require costly and otherwise un-
necessary disposal of the spent ammunition
as a hazardous waste.
Firing range operators should consider the
following recommendations when assessing
ammunition substitution:
13Firing Ranges
Use non-lead primers designed specifi-
cally for firing ranges. Cartridges already
loaded with non-lead primers are com-
mercially available for the most popular
calibers.
Jacketed or non-lead bullets should
be used to help reduce lead exposure
[NIOSH 1986; NIOSH 1995].‡ When se-
lecting copper-jacketed bullets, the firing
range operator should ensure that the
jacket covers the base and the bearing
surface of the bullet. Some “full-metal
jacket” bullets (sometimes called “ball
ammunition”) have a lead-exposed base
that is not visible in a loaded cartridge.
This type of bullet emits lead fume due to
contact with hot propellant gases. Also,
some companies manufacture half jack-
eted bullets that have a lead-exposed
bearing surface. These bullets emit lead
particles from the mechanical effects of
passing through the bore. It is important
to note that while some jacketed bullets
present no airborne lead hazard, at the
firing line, impact with the bullet trap may
generate lead dust at the trap. This lead
dust may present a source of lead expo-
sure to workers performing range main-
tenance, cleaning of traps, and removing
and disposing of spent bullets.
Use jacketed lead bullets (as opposed to
dip-coated copper plating) to minimize
lead exposure in firing ranges. Most com-
mercially available copper coatings are
generally too thin or too soft to effectively
isolate lead from the firing process.
Zinc bullets should not be used without
a careful assessment of safety hazards
caused by their propensity to “bounce
back” from the bullet traps in some firing
‡NIOSH examined potential hazardous exposure to
copper and zinc oxide ammunition substitutes and
found levels to be far below the OSHA PEL.
ranges. Also, firing range operators should
consider the potential for zinc bullets to
damage concrete and steel surfaces in fir-
ing ranges. Operators might instead con-
sider using frangible ammunition which
can be be ideal for use with steel outdoor
targets or portable “shoot houses.”
Firing range operators who depend on
using lead substitutes for reducing lead
exposure should ensure that firing rang-
es and firearms previously used with lead
ammunition are appropriately cleaned
and evaluated before being used in the
firing range.
Electronic simulation systems using guns
equipped with lasers can provide an al-
ternative solution for training new recruits
in effective gun handling and marksman-
ship without using live ammunition.
Engineering controls
Ventilation is the most important engineering
control for protection against primary lead
exposure in indoor firing ranges (Figure 3).
Well-designed supply air and exhaust venti-
lation systems have been shown to control
exposures to lead fumes and dust in firing
ranges [NASR 2004]. Monitoring and con-
trol systems that ensure proper operation of
ventilation systems are also important parts
of this engineering control. These systems
check the operating parameters of the ven-
tilation systems, alert firing range operators,
and prevent use of the firing range when
systems are not operating within specifica-
tions. When automatic control systems are
not used to monitor the effective operation
of the ventilation systems, OSHA requires
that measurements that demonstrate the
effectiveness of the systems in controlling
exposure, such as capture velocity, duct
velocity, or static pressure be made every
3 months. In addition, measurements of
14 Firing Ranges
the system’s effectiveness must be made
within 5 days of any change in the opera-
tion of the firing range, and/or engineering
control which might result in a change in
employee exposure to lead.
The following recommendations are based
on NIOSH research and are intended to
show the range of solutions that may be
implemented by firing range operators, de-
pending on cost and availability of resources
[Crouch et al. 1991].
Lead
Supply Ventilation System Recommen-
dations:
Ensure that supply air systems are de-
signed to distribute air evenly across the
area of the firing range, floor to ceiling
and wall to wall. If the supply air is not
evenly distributed, air flow at the firing
line will likely contain regions of reverse
flow, causing lead and other contami-
nants to be carried back into the shoot-
er’s breathing zone.
Introduce supply air as far up range as
possible. A perforated wall plenum has
been shown to provide uniform air distri-
bution at the firing line. Perforated radial
air diffusers mounted at ceiling height
have been tested and demonstrated ef-
fective in meeting established industry
and regulatory airflow criteria. Diffusers
that produce jets of air can create turbu-
lence at the firing line.
Airflow along the firing line should be
no more than 75 fpm (0.381 m/s) with
a minimum acceptable flow of 50 fpm
(0.254 m/s) [NIOSH 1976]. If it is de-
sired to minimize fall-out of gun emis-
sions downrange of the firing line, down-
range airflow should be maintained at
a minimum of 30 fpm (0.152 m/s) and
should be evenly distributed.
There should be no obstructions (e.g.,
target or ammunition storage cabinets) to
the airflow between the supply air inlets
and the firing line so that the supply air
is distributed uniformly across the width
(cross-sectional area) of the firing range.
Exhaust Ventilation System
Recommendations:
The total or combined exhaust airflow
for the firing range should always be
greater than the total supply airflow to
ensure the firing range is maintained
under negative pressure, and to prevent
migration of lead-contaminated air from
the firing range to the surrounding en-
vironment. Exhausting slightly more air
than supplied is a general recommenda-
tion for maintaining appropriate nega-
tive pressure in the firing range. If the
building envelope is not sealed, negative
pressure within the building can create
undesirable drafts through unplanned air
pathways entering through openings in
the building structure. These drafts can
result in back flow at the firing line, which
defeats the purpose of the ventilation
system. Unplanned pathways can also
result in a higher mechanical operating
cost (requiring additional heating or air-
conditioning). The magnitude of the neg-
ative pressure should be just sufficient to
produce an inflow of air at openings such
as windows and doors between the firing
range and adjacent areas or surrounding
environment. This can easily be evalu-
ated using a chemical smoke tube to
visually evaluate pressurization at doors,
windows, etc. that are slightly open to
the flow of air.
15Firing Ranges
The air should be exhausted at or behind
the bullet trap. Some firing ranges are
designed to have multiple exhaust points
downrange to maintain downrange flow
and desired velocities at the firing line.
The exhaust system should be designed
to provide minimum duct air velocities
of 2500–3000 fpm (12.7–15.24 m/s)
(Industrial Ventilation Manual, 24th Edi-
tion, Table 3–2) [ACGIH 2004]. Exces-
sively high duct velocities are unneces-
sary, waste energy, and may cause rapid
abrasion of ductwork.
The ventilation system that serves the
range area should be completely separat-
ed from any ventilation for the rest of the
building. The exhaust air from the range
should not feed into air supplies for offic-
es, meeting rooms, or other businesses.
Air Filtration Recommendations:
All air filtration systems should be in-
stalled in a location where they can be
easily serviced.
Air exhausted from the firing range should
be appropriately filtered or the area near
the outside vent be managed to prevent
access and lead mobility in accordance
with EPA best management practices
[EPA 2005]. If lead-contaminated air is
released outside the building and left un-
managed, the exterior walls of the build-
ing and surrounding grounds and water-
ways can become contaminated. Lead
released outdoors can be re-aerosolized
and result in subsequent contamination
of the firing range or other buildings, and
present unwanted hazards to humans if
the range is in a populated area.
The minimum filtration recommended is
high-efficiency particulate air (HEPA) fil-
tration or a minimum efficiency reporting
value (MERV) of 18–19. The Institute of
Environmental Sciences and Technology
specifies that a certified HEPA filter must
capture a minimum 99.97% of contami-
nants at 0.3 micron in size. This filter spec-
ification is also endorsed by the American
Society of Heating, Refrigerating and Air-
Conditioning Engineers (ASHRAE).
All filters potentially exposed to lead-con-
taminated air should be equipped with
side and face gaskets to eliminate filter
bypass, and air passing between the fil-
ters and the filter racks. Filter racks should
also be engineered and tested to ensure
that leaks do not occur after installation.
The filtration system should be located
as close to the firing range as possible
to minimize the distance that lead dust
needs to travel in the exhaust system
before it passes through the filter. Fil-
ter systems should always be located
upstream of the exhaust fan to prevent
contaminating the fan with lead.
Filter System Maintenance Recommen-
dations:
Filter end-of-service life is indicated by a
high-pressure drop (more resistance to air
flow) across the filter bank. Filters should
be changed according to the static pres-
sure guidelines provided by the manufac-
turer. Since pre-filters are the first to en-
counter contaminated exhaust air from
the firing range, they will load fastest.
Therefore, pre-filters require more frequent
change-outs than HEPA-rated filters.
Filter change-out should be performed
by personnel trained in the removal and
disposal of dirty filters and in lead safety.
They should use appropriate personal
protective equipment and environmental
precautions. Loaded filters will likely con-
tain lead in sufficient quantity to classify
16 Firing Ranges
the used filter as a hazardous waste un-
der the Resource Conservation and Re-
covery Act (RCRA) (40 CFR 260–279). A
Toxicity Characteristics Leaching Proce-
dure (TCLP) test will determine whether
the filter is a regulated hazardous waste
under the RCRA regulation. If the filter
does not meet the criteria of a hazardous
waste, it can be disposed of as normal
solid waste. However, if the filter does
have sufficient lead to be considered a
hazardous waste, there are two options:
first is to recycle or reuse the filter, in
which case it is not considered a waste
(RCRA recycling exemption 40 CFR
261.4(a)(13)) and there are no hazard-
ous waste handling procedures required.
If the filter is not recycled, and it fails the
TCLP, then it must be transported and
disposed of properly in accordance with
Federal, State and local regulations.
Control System Recommendations:
A warning light should be added to warn
shooters and the firing range operator
that a critical system has been inactivat-
ed by a safety interlock system. Modern
computer-operated firing ranges can in-
corporate specific warning indicators in
the computer programming.
Exhaust and supply fans should be inter-
locked so that all fan systems operate at
the same time during active range use. Air
flow from the fans should be monitored
and interlocked with a critical firing range
operating system to disable the firing range
and alert the firing range officer when the
air flow from any fan is inadequate.
Filter access doors should be interlocked
with the fan system to deactivate the
fans when the door is opened.
Pressure gauges on HVAC systems should
be maintained and calibrated regularly.
The pressure drop across each filter should
be monitored and checked regularly.
Exhaust air from the firing range should not
be recirculated back into the range when
economically feasible. However, exhaust air
may be recirculated if a real-time particle
detection system is installed downstream
of the filter system. It must be demonstrat-
ed that the particle detection system is
sensitive enough to detect any aerosol size
range and number concentration combi-
nation of lead particles that might exceed
the OSHA PEL. ANSI/ASHRAE Standard
62.1-2007, Ventilation for Acceptable
Indoor Air Quality, [ANSI/ASHRAE 2007]
provides dilution ventilation guidelines for
recirculating clean and breathable air in an
energy-efficient manner.
Noise
Effective noise control measures are impera-
tive to reducing noise-induced hearing loss
among firing range operators, employees,
and users. It is important to understand
that noise control of high intensity impulse
sounds might help reduce overall noise levels
inside a firing range and adjacent facilities,
but it has limited effect on the noise expo-
sure of the person firing the weapon. There
is no noise control that alleviates the require-
ment for wearing hearing protection because
the primary source of noise exposure is the
weapon itself. Noise control measures should
be compatible with ventilation requirements
and meet fire and building codes. Noise con-
trols typically address the primary two com-
ponents of noise transmission—airborne and
structural-borne sounds:
To reduce transmission of airborne
sounds, no leaks can exist between the
firing range and adjacent spaces. Small
openings such as electrical outlets, spac-
es around doors, and joints at the walls,
17Firing Ranges
ceiling, and floor should be sealed with
insulation and/or weather stripping as
needed. Ventilation ducts that provide a
direct acoustic path into adjacent spac-
es can be fitted with acoustic absorptive
materials, both to remediate vibrations in
the walls of the duct and to absorb noise
transmitted along the duct. Special care
must be paid to the maintenance and
handling of acoustic absorptive materials
to prevent lead dust accumulation. The
design of walls can minimize transmis-
sion of airborne sounds through com-
binations of gaps, absorptive materials,
and different wall thicknesses.
To reduce the transmission of structural-
borne sounds and vibration, acoustical
absorptive materials should be applied to
walls, windows, doors, ventilation ducts,
and ceilings. Use special care when ap-
plying acoustical absorptive materials to
prevent them from damage or becom-
ing dust-laden. Typical metal or wooden
stud construction has wall cavities that
can be filled with insulation material.
Walls that separate the firing range from
adjacent parts of the building should be
double thickness with offset studs. They
should provide an air gap as well as in-
sulation on the inside of one of the walls.
The interior surface of firing range walls
should be treated to minimize absorption
of airborne particulates, to make clean-
ing easier, and to resist lead and nitrate
penetration. Doors should be made of
metal with a foam core to reduce vibra-
tion caused by impulsive noise. The en-
trance to the firing range should be a 4–6
foot passageway with self-closing doors
at both ends. The passageway provides
an additional gap to reduce noise emis-
sions. Observation room windows should
be designed to withstand bullet impacts
and to maximize sound reduction. The
glass should be laminated and certi-
fied as bullet-impact resistant. If double
panes of glass are used, then the glass
that is in the firing range should be bullet-
impact resistant and of a different thick-
ness than the interior pane to increase
noise reduction.
Recently, state-of-the-art systems and train-
ing equipment designed to reduce lead and
noise exposures have been introduced and
are gaining wide acceptance among firing
range operators and law enforcement agen-
cies. Specifically, new backstop systems are
available that eliminate bullet fragmentation
and airborne lead by capturing whole, intact
bullets into their rubber media. These back-
stops also reduce noise exposures com-
pared to steel backstops.
Work practice and administrative
controls
When engineering controls are not feasible or
are inadequate, supplemental work practice
and administrative controls may be needed
to limit noise and lead exposures. Work prac-
tice controls are procedures or actions firing
range users can take themselves to ensure
their own safety and health. Administrative
controls, on the other hand, are those gen-
erally implemented by management or firing
range operators to safeguard the shooters.
The following work practice and administra-
tive recommendations are offered:
Preventing the potential for lead
exposure by ingestion and by avoidance
of skin contamination and appropriate
decontamination
Eating, drinking, and smoking should be
prohibited in the firing range.
All personnel should wash their hands, fore-
arms, and faces before eating, drinking,
18 Firing Ranges
smoking, or having any hand contact with
the face or with other people. Hands should
be washed with soap and water or cleaned
with lead decontamination wipes after
shooting, handling spent cartridge cases,
or cleaning weapons. Wipes for cleaning
skin without water are commercially avail-
able and should be used if access to soap
and water is limited.
Skin contact with spent cartridges should
be avoided whenever possible. Dispos-
able gloves should be worn when remov-
ing larger objects that cannot be removed
with a HEPA vacuum cleaner.
Floor and horizontal surfaces inside the
firing range should be cleaned routinely
with a detergent, or in some specific and
tough cases, a cleanser designed for
lead decontamination. EPA studies show
that general all-purpose cleaners are
adequate for both general cleaning and
post-intervention cleaning [EPA 1997,
Lewis et al. 2006].
Reducing lead contamination inside the
firing range
The ventilation system should be operat-
ing at all times while the firing range is in
use and during clean-up.
The firing range operator should require
that all shooters immediately discontinue
shooting and place their weapons in safe
mode whenever the firing range opera-
tion is inactivated by a monitor. All non-
essential persons should leave the firing
range until the problem is fixed.
Carpeting should not be used anywhere
inside a firing range or in rooms adjacent
to the range. Accumulation of lead dust
in carpets is a health hazard, and accu-
mulation of unspent primer in carpets is
a fire hazard.
The firing range should be equipped with
automatic target retrieval systems to
allow shooters to examine their perfor-
mance without crossing the firing line.
After use, the floor of the firing range
should be thoroughly cleaned with an
explosion-proof HEPA vacuum cleaner de-
signed to collect lead dust. Dry sweeping
should never be used in the firing range.
Preventing “take-home” lead exposure
Shooters using a kneeling or prone po-
sition over lead contaminated surfaces
should place a sheet of paper or other
disposable material on the ground be-
neath them to minimize accumulation
of leaded dust on their outer garments.
Knee pads or mats may be used to re-
duce lead contamination but they should
be cleaned after each use.
Shooters and workers should shower,
whenever possible, and change clothes
at firing range facilities after shooting or
performing maintenance or cleaning ac-
tivities at the range.
Provide workers with two lockers to al-
low them to separate street clothes from
lead-contaminated work clothes.
Workers’ non-disposable outer protec-
tive clothing should be laundered by the
employer or a contractor. It should not
be laundered by the employee at home.
Non-employees who take contaminated
clothing home should bag the clothes
before leaving the range. Contaminated
clothing should be washed separately
from the family’s clothing.
Leave shoes worn on the firing range
at the range or bag them before leav-
ing the range to prevent lead from being
tracked into cars and onto home floors
19Firing Ranges
and carpets. As an alternative, use step-
off cleaning pads at the exit of the firing
range to help reduce the amount of lead
contamination on shoes. Disposable
shoe coverings can also be used while
firing and cleaning, then discarded upon
leaving the range.
Administrative control of noise and lead ex-
posure can be accomplished by limiting the
length of time shooters and employees use
the firing range, by assignment and work
rotation, and by providing quiet and clean
lunch and break areas to give periodic relief
from noise. The firing range should also be
cleaned at least weekly.
Personal protective equipment
Provide personal protective equipment to
workers and indoor range users to protect
against the potential effects of exposure to
lead and noise.
All workers and shooters should be re-
quired to use dual hearing protection de-
vices (earmuffs and earplugs) when the
range is in use. For shooters requiring
improved communication, NIOSH recom-
mends using electronic level-limiting or
sound restoration earmuffs with passive
earplugs. In addition to the electronic ear-
muffs, commercially available communi-
cation headsets exist that would permit
the range master to transmit instructions
via short range radio to the shooter’s
headset. Shooters should also be en-
couraged to wear eye protection in the
form of safety glasses or goggles that are
compatible with hearing and other head
protection devices. NIOSH research has
shown that wearing earmuffs on top of
safety glasses created a leakage in the
seal of the earmuff cushions with the ear
and reduced the effectiveness and peak
noise level reduction of the earmuffs.
NIOSH recommends that shooters wear
the safety glasses over the top of the
earmuff cushions, or use glasses with
a strap or low profile stem. Ideally, the
safety glasses should be an integral part
of the earmuff or other head protection
devices. A training program in the appro-
priate use and fitting of hearing and eye
protection should be implemented by fir-
ing range training staff.
Personnel performing lead clean-up at
the trap should wear appropriate NIOSH-
certified respiratory protection and full
protective outer clothing (which may
be disposable). If respirators are part of
the lead management plan, firing range
operators must develop and implement
a respiratory protection program that
meets the requirements of the OSHA
respiratory protection standard [29 CFR
1910.134] and document it in writing.
Personnel cleaning weapons should
be encouraged to use chemical-resis-
tant gloves and tight- fitting goggles for
skin and eye protection against poten-
tial chemical hazards. Range operators
should provide specific guidance about
proper and appropriate use of skin and
eye protection.
Employer and worker education
Firing range operators and employers should
be fully aware of the potential for hazardous
lead and noise exposures in their facilities,
and they must communicate this informa-
tion to workers to ensure safe and healthful
working conditions.
Inform workers about the potential for ex-
posure to lead, noise, and other toxicants
and tell them the nature of the hazard.
20 Firing Ranges
Provide general information and specific
hazard warnings through workplace post-
ings, training, and stating the precau-
tions and hygiene practices required of
firing range users.
Train workers regarding the means avail-
able at the firing range to eliminate or
limit exposure and the actions that limit
potential exposures for themselves and
fellow workers.
Inform workers about symptoms that
may indicate a health problem. Although
not all exposed workers may show overt
symptoms, common symptoms of lead
poisoning in adults include nausea, diar-
rhea, vomiting, poor appetite, weight loss,
anemia, excess lethargy or hyperactivity,
headaches, abdominal pain, and kidney
problems. Exposure to high noise lev-
els can cause hearing problems, stress,
poor concentration, insomnia, nervous-
ness, anxiety, and depression. It can also
cause accelerated heartbeat, high blood
pressure, gastro-intestinal problems and
chronic fatigue. Employers should advise
employees to report these symptoms to
their supervisors and physicians.
Inform pregnant workers and shooters,
or those considering pregnancy, about
the possible adverse health effects to
the fetus from exposure to lead and
noise. A fetus can be poisoned in utero.
Studies show that fetal blood contains
approximately 80% of the blood lead
concentration of the mother. Pregnant
workers and shooters, or those consider-
ing pregnancy, also need to know about
the increased chance of miscarriage at
blood lead levels > 5 µg/dL. Evidence
also suggests that exposure to peak
sound pressure levels above 155 dBC
can cause hearing loss in the fetus be-
yond the fifth month of pregnancy. The
evidence of whether the particular noise
exposure associated with firing ranges
is harmful to the developing fetus and
warrants removal of the pregnant woman
from exposure is ambiguous. This issue
is further complicated because female
workers may be exposed to lead and
noise even before they know they are
pregnant. Firing ranges might wish to es-
tablish guidelines for pregnant workers
exposed to lead and noise.
Worker exposure and medical
health monitoring
OSHA’s lead standard requires each em-
ployer who operates a firing range to deter-
mine if any workers may be exposed to lead
at or above the action level (30 µg/m3 as
an 8-hour TWA). Worker exposure is defined
as that exposure which would occur if the
workers were not using a respirator.
The results of initial and periodic monitoring
determine whether subsequent monitoring
is necessary. Monitoring also determines
whether other protective provisions of the
standard need to be implemented.
If the initial determination or subsequent de-
terminations reveal workers’ exposure to be
at or above the action level but at or below
the PEL, the employer is required to perform
monitoring at least every 6 months. If the
initial determination reveals that workers’
exposure is above the PEL, the employer
must perform monitoring at least quarter-
ly. If any worker is determined by the initial
monitoring to be exposed to lead below the
action level, then no further monitoring is
required for that worker, except where fir-
ing range operations or controls change that
could result in additional exposure.
21Firing Ranges
Exposure monitoring
Monitoring procedures should be spe-
cifically defined to ensure consistency.
Instrumentation, calibration, measure-
ment parameters, and methods for link-
ing results to worker records should be
clearly outlined.
Exposure assessment should be con-
ducted under the direction of a certi-
fied industrial hygienist or other safety
and health professional with appropriate
training and expertise.
Workers should be permitted and encour-
aged to observe and participate in moni-
toring activities as long as they do not in-
terfere with monitoring procedures. Their
participation will help ensure valid results.
Monitoring should be repeated periodi-
cally to ensure continued effectiveness
of worker protection measures and to
help identify changes in noise controls,
work practices, equipment, and mainte-
nance procedures.
Perform wipe sampling on surfaces in the
firing range on a regular basis. Wipe sam-
pling can provide information about how
well these surfaces are being cleaned,
whether lead is being transported from
the firing range to other parts of the facil-
ity, and about the potential for lead expo-
sure. See information about the NIOSH
wipe sampling methods in Current Regu-
lations, Recommendations, and Other
Guidelines section of this Alert.
Employers should notify workers of any
hazardous exposure levels determined
for their particular jobs and provide infor-
mation about the health risks associated
with such exposures.
Worker health monitoring
Blood lead levels are currently the best in-
dicator of personal lead exposure. Workers
potentially exposed to lead should there-
fore be monitored for the presence of lead
in blood. This assessment is necessary to
ensure that engineering controls, personal
hygiene practices, and PPE are preventing
lead exposure. It is recommended that the
employer’s medical monitoring program be
supervised by a physician trained and expe-
rienced in occupational medicine.
The OSHA general industry lead standard
contains provisions for the medical mon-
itoring of workers exposed to lead (29
CFR 1910.1025(j)). NIOSH supports us-
ing these provisions for firing range work-
ers, especially those who routinely use or
work at these ranges, but acknowledg-
es that current understanding of health
risks associated with lead exposure may
require updated/additional provisions for
medical surveillance. Recommendations
from the March 2007 edition of Environ-
mental Health Perspectives’ Mini-Mono-
graph on adult lead exposure and from
the Association of Occupational and En-
vironmental Clinics (AOEC) include the
following elements:
Informing workers and shooters that —
levels of lead once thought safe are
now known to be harmful. Advise
that blood lead levels be kept below
10 µg/dL of blood.
Informing pregnant workers and —
shooters, or those considering preg-
nancy, about the possible adverse
health effects to the fetus as well as
the increased chance of miscarriage
at blood lead levels > 5 µg/dL.
22 Firing Ranges
Workers should be included in a med- —
ical surveillance program whenever
they are handling or distributing ma-
terials with lead content that could
potentially cause exposure through
inhalation or ingestion.
New employees and those newly as- —
signed to work in areas with potential
lead exposures should have a pre-
placement lead medical examination
and a BLL test, followed by periodic
BLL monitoring, blood pressure test-
ing, and health status review.
Monthly BLL testing is recommended —
for the first three months of employ-
ment in order to assess the adequacy
of exposure control measures.
Testing frequency can be reduced to —
every six months as long as BLLs re-
main below 10 µg/dL or quarterly for
individuals with blood lead concentra-
tions between 10 and 19 µg/dL.
Any increase in BLLs of 5 µg/dL or —
greater should trigger a re-examination
of control measures.
Workers with BLLs of 30 µg/dL or —
more, or ones with a sustained BLL
above 20 µg/dL should be removed
from lead exposure.
All lead-exposed workers should re- —
ceive, annually, educational materi-
als and prevention information about
the health effects of exposure to lead
from a clinician and the employer, and
they should be provided necessary
protections including protective cloth-
ing, clean eating areas, and hygiene
measures such as wash facilities and/
or showers to prevent both ingestion
and take-home exposures.
The OSHA noise exposure standard (29
CFR 1910.95(d)(e)(g)(h)) requires the
employer to establish a monitoring pro-
gram and provide audiometric testing to
all employees whose exposures equal or
exceed an 8-hour TWA of 85 dBA under
the action level monitoring criteria. All
workers with regular exposure to weap-
ons firing should undergo annual audio-
metric monitoring at test frequencies of
500, 1000, 2000, 3000, 4000, and
6000 Hz. Annual audiograms should be
compared to a baseline audiogram to
determine if hearing loss is occurring. If
a standard threshold shift (STS), defined
as a change in the pure-tone average of
more than 10 dB at 2000, 3000, and
4000 Hz, occurs in either ear, the em-
ployer must follow certain procedures
outlined in the standard, including notify-
ing the affected employee in writing. Oc-
cupational exposure to lead can have an
additive or potentiating effect on the au-
ditory system and increase the potential
for hearing loss. Pure-tone audiometric
testing may conceal certain hearing dif-
ficulties caused by exposure to lead or
other chemicals. Professionals who re-
view the audiometric results should be
alerted to this issue and should consider
a referral for further testing and medical
evaluation [Morata, 2007].
ACKNOWLEDGMENTS
The principal contributors to this Alert were
Chucri A. Kardous, MS, PE; Bradley F. King,
MS, CIH; Amir Khan; Elizabeth A. Whelan,
Ph.D.; Randy L. Tubbs, Ph.D.; Michael E.
Barsan, REHS-RS; Keith G. Crouch, Ph.D.;
William J. Murphy, Ph.D.; Robert D. Will-
son, MS, CIH, Eric J. Esswein, MSPH, CIH,
CIAQP; and Mark F. Boeniger, MS, CIH.
23Firing Ranges
Sue Afanuh, Vanessa Becks, Diana Camp-
bell, Gino Fazio, and Anne Votaw provided
editorial and production services.
Please direct any comments, questions, or
requests for additional information to the
following:
W. Gregory Lotz, Ph.D.
Director, Division of Applied Research
and Technology
National Institute for Occupational Safety
and Health
4676 Columbia Parkway
Cincinnati, OH 45226
Telephone: 513–533–8462; or call
CDC–INFO (1–800–232–4636)
TTY: 1–888–232–6348
E-mail: cdcinfo@cdc.gov
We greatly appreciate your assistance in
protecting the health of U.S. workers.
Christine M. Branche, Ph.D.
Acting Director, National Institute for
Occupational Safety and Health
Centers for Disease Control and
Prevention
REFERENCES
ACGIH [2001]. Documentation of the threshold limit
values and biological exposure indices, 7th Edition.
Cincinnati, OH: American Conference of Governmen-
tal Industrial Hygienists.
ACGIH [2004]. Industrial ventilation: a manual of
recommended practice, 25th Edition. Cincinnati, OH:
American Conference of Governmental Industrial Hy-
gienists.
ACGIH [2006]. 2006 TLVs and BEIs: threshold limit
values for chemical substances and physical agents.
Cincinnati, OH: American Conference of Governmen-
tal Industrial Hygienists.
AOEC [2007]. Medical management guidelines for
lead-exposed adults, revised 04/24/07 [http://www.
aoec.org/documents/ positions/MMG_FINAL.pdf].
ASHRAE [2007]. ANSI/ASHRAE 62.1: Ventilation for
Acceptable Indoor Air Quality. Atlanta, GA: American
Society of Heating, Refrigerating, and Air Condition-
ing Engineers.
CFR. Code of Federal regulations. Washington, DC:
U.S. Government Printing Office, Officer of the Fed-
eral Register.
Crouch KG, Peng T, Murdoch DJ [1991]. Ventilation
control of lead in indoor firing ranges: inlet configura-
tion and booth and fluctuating flow contributions. Am
Ind Hyg Assoc J 52(2):81–91
DHHS [2000]. Healthy people 2010. 2nd ed. With
Understanding and Improving Health and Objectives
for Improving Health. 2 vols. Washington, DC: U.S.
Government Printing Office.
DOJ [2002]. Immigration and Naturalization Service.
INS/NFU Firing Range Design Standard. U.S. Depart-
ment of Justice.
DOJ [2004]. Law Enforcement Statistics. Washing-
ton, DC: U.S. Department of Justice, Office of Justice
Programs. [www.ojp.usdoj.gov/]
EHP [2007]. Mini-Monograph. Environmental Health
Perspectives, 115(3): 451–492.
EPA [1997]. Laboratory Study of Lead-Cleaning Ef-
ficacy, March 1997 (EPA 747–R–97–002).
EPA [2005]. Best management practices for lead
at outdoor shooting ranges. EPA–901–B–01–001.
[www.epa.gov/region2/waste/leadshot].
Esswein EJ, Boeniger MF [2005]. Preventing the
toxic hand-off. Occupational Hazards. September
2005, pp. 53–61.
24 Firing Ranges
Goldberg RL, Hicks AM, O’Leary LM, London S
[1991]. Lead exposure at uncovered outdoor firing
ranges. J Occup Med. 33(6):718–719
Kardous CA, Willson RD, Hayden CS, Szlapa P, Mur-
phy WJ, Reeves ER [2003]. Noise exposure assess-
ment and abatement strategies at an indoor firing
range. Appl Occup Environ Hyg 18(8):629–636.
Kosnett MJ, Wedeen RP, Rothenberg SJ, Hipkins KL,
Materna BL, Schwartz BS, Hu H, Woolf A. [2007].
Recommendations for Medical Management of Adult
Lead Exposure. Environmental Health Perspectives,
115(3):463-471. [http://www.ehponline.org/mem-
bers/2006/9784/9784.html].
Lalande NM, Hetu R, Lambert J [1986]. Is occupa-
tional noise exposure during pregnancy a risk factor
of damage to the auditory system of the fetus? Am J
Ind Med 10(4):427–435.
Levin SM, Goldberg M [2000]. Clinical Evaluation
and Management of Lead-Exposed Construction
Workers. Am J Ind Med 37(1):23–43.
Lewis RD, Condoor S, Batek J, Ong KH, Backer D,
Sterling D, Siria J, Cheng JJ, Ashley P [2006]. Re-
moval of Lead Contaminated Dust from Hard Sur-
faces. Env Sci Technol 40(2):590–594.
Morata, TC [2007]. Promoting hearing health and
the combined risk of noise-induced hearing loss and
ototoxicity. Audiological Medicine, 5(1): 33–40.
Murphy WJ, Tubbs RL [2007]. Assessment of Noise
Exposure for an Indoor and Outdoor Firing Range. J
Occup Env Hyg 4:688–697.
NASR [2004]. Lead management and OSHA compli-
ance for indoor shooting ranges. National Associa-
tion of Shooting Ranges, Newtown CT.
Niemtzow RC [1993]. Loud noise and pregnancy.
Military Medicine 158(1):10–12.
Novotny T, Cook M, Hughes J, Lee S [1987]. Lead
exposure in a firing range. Am J Public Health
77:1225–1226.
NRA [1999]. The NRA range source book: a guide to
planning and construction. Fairfax, VA: National Rifle
Association, Range Department, Field Operations Di-
vision.
NSSF [2006]. National Shooting Sports Foundation.
Newton, CT. [www.nssf.org/IndustryResearch/index.
cfm]
NIOSH [1975]. Lead exposure and design consider-
ations for indoor firing ranges. Cincinnati, OH: U.S.
Department of Health, Education, and Welfare, Cen-
ters for Disease Control and Prevention, National In-
stitute for Occupational Safety and Health, NIOSH
HEW NO. 76–130.
NIOSH [1986]. Health Hazard Evaluation and Tech-
nical Assistance Report: Federal Reserve Bank. Cin-
cinnati, OH: U.S. Department of Health and Human
Services, Public Health Service, Center for Disease
Control, National Institute for Occupational Safety and
Health, NIOSH HETA Report No. 86–0269–1812.
NIOSH [1991]. Health Hazard Evaluation and Tech-
nical Assistance Report: FBI Academy, Quantico,
VA. Cincinnati, OH: U.S. Department of Health and
Human Services, Public Health Service, Center
for Disease Control, National Institute for Occupa-
tional Safety and Health, NIOSH HETA Report No.
91–0346–2572.
NIOSH [1992a]. Recommendations for occupational
safety and health: compendium of policy documents
and statements. Cincinnati, OH: U.S. Department of
Health and Human Services, Public Health Service,
Centers for Disease Control and Prevention, National
Institute for Occupational Safety and Health, DHHS
(NIOSH) Publication No. 92–100.
NIOSH [1992b]. Health Hazard Evaluation Report,
Delaware County Resource Recovery Facility, Ches-
ter, Pennsylvania. Cincinnati, OH: U.S. Department of
Health and Human Services, Public Health Service,
Centers for Disease Control and Prevention, National
Institute for Occupational Safety and Health, NIOSH
HETA Report No. 91–0366–2453.
NIOSH [1994]. NIOSH Manual of Analytical Methods
(NMAM®). 4th ed. Cincinnati, OH: U.S. Department of
Health and Human Services, Public Health Service,
Centers for Disease Control and Prevention, National
25Firing Ranges
Institute for Occupational Safety and Health, DHHS
(NIOSH) Publication No. 94–113.
NIOSH [1995]. Health Hazard Evaluation and Tech-
nical Assistance Report: Colorado State Patrol Train-
ing Academy. Cincinnati, OH: U.S. Department of
Health and Human Services, Public Health Service,
Centers for Disease Control and Prevention, National
Institute for Occupational Safety and Health, NIOSH
HETA Report No. 95–0290–9221.
NIOSH [1996]. Health Hazard Evaluation Report,
Standard Industries, San Antonio Texas. Cincinnati,
OH: U.S. Department of Health and Human Ser-
vices, Public Health Service, Centers for Disease
Control and Prevention, National Institute for Occu-
pational Safety and Health, NIOSH HETA Report No.
94–0268–2618.
NIOSH [1997]. Health Hazard Evaluation and Tech-
nical Assistance Report: Forest Park Police Depart-
ment, Forest Park, OH. Cincinnati, OH: U.S. Depart-
ment of Health and Human Services, Public Health
Service, Centers for Disease Control and Prevention,
National Institute for Occupational Safety and Health,
NIOSH HETA Report No. 97–0255–2735.
NIOSH [1998]. Criteria for a recommended stan-
dard—Occupational noise exposure (revised criteria
1998). Cincinnati, OH: U.S. Department of Health
and Human Services, Public Health Service, Centers
for Disease Control and Prevention, National Institute
for Occupational Safety and Health, DHHS (NIOSH)
Publication No. 98–126.
NIOSH [1999]. Interim Health Hazard Evaluation
Report, Yuasa Inc. Sumpter South Carolina. Cincin-
nati, OH: U.S. Department of Health and Human
Services, Public Health Service, Centers for Disease
Control and Prevention, National Institute for Occu-
pational Safety and Health, NIOSH HETA Report No.
99–0188.
NIOSH [2003]. Health Hazard Evaluation and Tech-
nical Assistance Report: Fort Collins Police Services,
Fort Collins, CO. Cincinnati, OH: U.S. Department of
Health and Human Services, Public Health Service,
Centers for Disease Control and Prevention, National
Institute for Occupational Safety and Health, NIOSH
HETA No. 2002–0131–2898.
NIOSH [2004]. Research to Practice. www.cdc.gov/
niosh/r2p/. Accessed June 20, 2006.
Price GR [1989]. Hazard from weapons impulses:
Histological and electrophysiological evidence. J
Acoust Soc Am 85(3):1245–1254.
State of Alaska [2003]. School rifle teams exposed
to lead at indoor firing ranges, Bulletin No. 1, An-
chorage, AK: State of Alaska, Department of Health
and Social Services, Epidemiology Bulletin.
Tripathi RK, Sherertz PC, Llewellyn GC, Armstrong CW
[1991]. Lead exposure in outdoor firearm instruc-
tors. Am J Public Health. 81(6): 753–755
USACE [1990]. Design manual for indoor firing rang-
es. CEHND 1110–1–18, Huntsville, AL: U.S. Army
Corps of Engineers.
USN [2002]. U.S. Navy Environmental Health Cen-
ter. Indoor Firing Ranges Industrial Hygiene Techni-
cal Guide. Technical Manual NEHC–TM6290.99–10.
Portsmouth, VA: U.S. Department of Defense, De-
partment of the Navy.
Valway SE, Martyny JW, Miller JR, Cook M, Mangione
EJ [1989]. Lead absorption in indoor firing range us-
ers. Am J Public Health, 79:1029–1032.
To receive NIOSH documents or more information about occupational safety and health topics, contact NIOSH at1–800–CDC–INFO (1–800–232–4636)TTY: 1–888–232–6348E-mail: cdcinfo@cdc.govor visit the NIOSH Web site at www.cdc.gov/niosh.For a monthly update on news at NIOSH, subscribe to NIOSH eNews by visiting www.cdc.gov/niosh/eNews.DHHS (NIOSH) Publication No. 2009–136safer • healthier • people™Delivering on the Nation’s promise: safety and health at work for all people through research and preventionDEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Disease Control and Prevention
National Institute for Occupational Safety and Health
4676 Columbia Parkway
Cincinnati, Ohio 45226–1998
Official Business
Penalty for Private Use $300
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 11
Exhibit 11
Existing Protections
in Chapters 18.15, 18.20, 18.22, 18.25, and 18.30 of the Jefferson County Code
i
Exhibit 11
Existing Protections
in Chapters 18.15, 18.20, 18.22, 18.25, and 18.30 of the Jefferson County Code
TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................................... i
CHAPTER 18.15 JEFFERSON COUNTY CODE LAND USE DISTRICTS ................................. 1
Archaeological and Historical Site Regulations. Jefferson County Code 18.15.090. ....... 1
Forest Resource Districts Regulations. Jefferson County Code 18.15.150. .................... 1
CHAPTER 18.20 JEFFERSON COUNTY CODE PERFORMANCE AND USE SPECIFIC
STANDARDS ............................................................................................................................. 1
Small-scale Recreation and Tourist Use Regulations. Jefferson County Code 18.20.350:
1
CHAPTER 18.22 JEFFERSON COUNTY CODE CRITICAL AREAS ......................................... 4
Aquifer Recharge Area Report Requlations. Jefferson County Code 18.22.120. ............ 4
Susceptible Aquifer Recharge Areas and Special Aquifer Protection Areas Regulations.
Jefferson County Code 18.22.130. ......................................................................................... 4
Geologically Hazardous Area or its Buffer Protection Regulations. Jefferson County Code
18.22.170. .............................................................................................................................. 5
Habitat Management Plan Regulations. Jefferson County Code 18.22.265. .................... 5
Fish and Wildlife Habitat Conservation Area (FWHCA) and its Buffer Regulations.
Jefferson County Code 18.22.270 .......................................................................................... 6
Wetland Buffer Regulations. Jefferson County Code 18.22.310. .................................... 6
Wetland Protection Regulations. Jefferson County Code 18.22.330. .............................. 6
Wetland Mitigation Regulations. Jefferson County Code 18.22.350. ............................... 6
CHAPTER 18.25 JEFFERSON COUNTY CODE SHORELINE MASTER PROGRAM ............... 6
Use Regulations in Each Shoreline Environment Designation. Jefferson County Code
18.25.220. .............................................................................................................................. 6
Critical Areas, Shoreline Buffers, and Ecological Regulation. Jefferson County Code
18.25.270. .............................................................................................................................. 6
Historic, Archaeological, Cultural, Scientific and Educational Resources Protection.
Jefferson County Code 18.25.280. ......................................................................................... 7
Shoreline Setbacks and Height Regulations. Jefferson County Code 18.25.300. ........... 8
Vegetation Conservation Regulations. Jefferson County Code 18.25.310. ..................... 8
Water Quality and Quantity Regulations. Jefferson County Code 18.25.320. ................. 8
Dredging Regulations. Jefferson County Code 18.25.360. ............................................. 9
Filling and Excavation Regulations. Jefferson County Code 18.25.370. ......................... 9
Flood Control Structure Regulations. Jefferson County Code 18.25.380. ....................... 9
ii
In-stream Structure Regulations. Jefferson County Code 18.25.390. ............................11
Shoreline Restoration Regulations. Jefferson County Code 18.25.400. .........................12
Structural Shoreline Armoring and Shoreline Stabilization Regulations. Jefferson County
Code 18.25.410. ....................................................................................................................12
General Development Standards. Jefferson County Code 18.30.020: ...........................13
Water Supplies Regulations. Jefferson County Code 18.30.030: ...................................14
Sewage Disposal Regulation. Jefferson County Code 18.30.040: .................................14
Density, Dimension, and Open Space Standards. Jefferson County Code 18.30.050. ..15
Grading and Excavation Standards. Jefferson County Code 18.30.060.........................15
Stormwater Management Standards. Jefferson County Code 18.30.070. ......................15
Archaeological and Historic Resources Regulation. Jefferson County Code 18.30.160: 16
On-site Sewage Disposal Best Management Practices in Critical Aquifer Recharge
Areas. Jefferson County Code 18.30.180. ............................................................................17
Noise Regulation. Jefferson County Code 18.30.190: ...................................................17
1
CHAPTER 18.15 JEFFERSON COUNTY CODE LAND USE DISTRICTS
Archaeological and Historical Site Regulations. Jefferson County Code 18.15.090.
• For applications for development for an area known to be archaeologically or historically
significant, no action shall be taken on the application and the applicant shall not initiate
any excavation or development activity until the site has been inspected by a qualified
archaeologist, historian, or architect, as appropriate. Jefferson County Code
18.15.090(1).
• If during excavation or development of a site an area of potential archaeological
significance is uncovered, all activity in the immediate vicinity shall be halted, and the
administrator shall be notified at once. Jefferson County Code 18.15.090(2).
Forest Resource Districts Regulations. Jefferson County Code 18.15.150.
• Subdivision of commercial and rural forest lands for construction or installation of
nonresidential purposes must be at least 80 acres in size within the commercial forest
designation and 40 acres in size within the rural forest designation and: (i) Facility cannot
otherwise be suitably located on undesignated land; (ii) Installation cannot otherwise be
accomplished without subdivision; (iii)Facility must be located on the lowest feasible grade
of forest land; and (iv) Facility must remove as little land as possible from timber
production. Jefferson County Code 18.15.150(2).
• 250-foot building setback required for new structures proposed to the located on parcels
adjacent to designated forest lands, where adjacent to commercial forest lands and 100
feet adjacent to the rural forest lands designation, with limited exceptions. Jefferson
County Code 18.15.150(3)(a).
• New structures proposed to the located on parcels adjacent to designated forest lands
must provide adequate access for fire vehicles. Jefferson County Code 18.15.150(3)(b).
CHAPTER 18.20 JEFFERSON COUNTY CODE PERFORMANCE AND USE SPECIFIC
STANDARDS
Small-scale Recreation and Tourist Use Regulations. Jefferson County Code 18.20.350:
(1) Small-Scale Recreation and Tourist Uses. Small-scale recreational and tourist
uses rely on a rural location and setting and provide opportunities to diversify the
economy of rural Jefferson County by utilizing the county’s abundant recreational
opportunities and scenic and natural amenities in an environmentally sensitive
manner consistent with the rural character of the county. Upon approval pursuant to
this code, these types of uses may be conducted in the land use districts specified in
Table 3-1 in JCC 18.15.040 and as provided for in small-scale recreation and tourist
(SRT) overlay districts under JCC 18.15.470 and 18.15.572. Agritourism on
designated agricultural lands is regulated in JCC 18.20.030, agricultural activities and
accessory uses. The following list of uses is not intended to be exhaustive, but rather
is intended to be illustrative of the types of small-scale recreation or tourist uses:
(a) Small-scale recreation or tourist uses may include limited and
commensurately scaled commercial facilities intended to serve those small-scale
recreational or tourist uses (e.g., a gift shop, delicatessen, convenience store, or
2
associated retail sales and services); provided, that the applicant can
demonstrate the following to the satisfaction of the approving authority that:
(i) The principal demand for the commercial facilities is derived from the
principal recreational or tourist use and not the existing and projected rural
population;
(ii) The associated commercial activities shall be clearly accessory to and
dependent upon the primary recreational or tourist uses;
(iii) The associated commercial activities, in addition to the principal
recreational or tourist use, will not have a measurable detrimental traffic,
noise, visual or public safety impact on adjacent properties;
(iv) The use and associated structure are clearly appropriate and compatible
in scale, size, design and function with surrounding uses and environment;
(v) The use will not constitute new urban development in a rural area;
(vi) The public facilities and services provided are limited to those necessary
to serve the associated commercial activities and the principal small-scale
recreational or tourist use in a manner that does not permit low-density
sprawl; and
(vii) All other applicable requirements and standards in this UDC are met.
(b) Unless a larger parcel size is specified, minimum lot size shall be five acres,
except that no minimum lot size is required for parcels that include a historic site,
structure, or landmark.
(c) Only one small-scale recreational or tourist use shall be allowed per legal lot
of record, with the exception of rural restaurants.
(d) Only those buildings or areas specifically approved by the county may be used
in the conduct of the business.
(e) Parking shall be contained on-site and provided in conformance with this
code, including JCC 18.30.100 and 18.30.130.
(f) All activities shall, at a minimum, be screened from the view of adjacent
residential uses subject to the landscaping and screening requirements of JCC
18.30.130 and set back a sufficient distance from all rear and side property lines
to protect the character of adjacent and surrounding properties and uses. The
approving authority may authorize variations to the setbacks established in Table
6-1 in JCC 18.30.050 in order to ensure that any small-scale recreation or tourist
use or structure, when proposed in or adjacent to a rural residential (RR) district,
shall be compatible with and not disruptive to the character of existing and
anticipated future uses in the district.
(g) All small-scale recreation or tourist uses shall utilize local access or minor
collector roads for primary access whenever practicable. Access off of state
3
routes, arterials, or major collector roads may be allowed if access improvements
or a traffic analysis assures mobility is not degraded.
(h) Structures shall comply with the landscape, lighting, site coverage, and design
standards set forth in Chapter 18.30 JCC.
(i) Any small-scale recreational or tourist use development allowed under this
section that proposes to include permanent occupancy on-site residential
development may only be permitted subject to:
(i) The underlying rural residential density;
(ii) A master planned resort (MPR) district designation subject to a legislative
action to amend the Comprehensive Plan; or
(iii) That necessary for on-site management (e.g., a caretaker’s residence).
(j) For any small-scale recreation or tourist use, the county shall impose such
reasonable conditions (e.g., location and size restrictions, design standards,
landscape buffers, setbacks, etc.) as are found necessary by the approving
authority to ensure that the activity or use, due to proximity, location or intensity:
(i) Is compatible with the rural character of adjacent lands and shorelines,
including forestry, agriculture, and mineral lands of long-term commercial
significance;
(ii) Does not disrupt the character of any surrounding permitted uses;
(iii) Is adequately served by public facilities and services (including roadway
level of service and minimum fire flow requirements) without the need to
extend those services in a manner that promotes low density sprawl;
(iv) Adequately protects critical areas including surface and groundwater
resources; and
(v) Would not cumulatively, in combination with the effects of existing
development (or given the probable development of subsequent projects with
similar effects) in the vicinity (i.e., within one mile) of the proposed use, create
a development pattern that constitutes low density sprawl; require the
extension of public facilities or expansion of public services in a manner that
promotes low density sprawl; or be otherwise incompatible with or injurious
to the rural character of the area;
(vi) For designated agricultural lands, converts as little land with prime
agricultural soils as practicable into nonagricultural use.
(2) If the preceding conditions (in subsection (3)(j) of this section) cannot be met
to the satisfaction of the approving authority, the use shall be denied.
4
CHAPTER 18.22 JEFFERSON COUNTY CODE CRITICAL AREAS
Chapter 18.22 Jefferson County Code protects critical areas using the following key provisions:
Aquifer Recharge Area Report Regulations. Jefferson County Code 18.22.120.
Aquifer recharge area report required for uses that include the following activities that could
apply to a CSF: (i) Hazardous waste treatment, storage, and disposal facilities. Jefferson
County Code 18.22.120(1)(d) (ii) Storage tanks for petroleum products or other hazardous
substances. 18.22.120(1)(f). Detailed requirements for an aquifer recharge area report are
contained in Jefferson County Code 18.22.400.
Susceptible Aquifer Recharge Areas and Special Aquifer Protection Areas Regulations.
Jefferson County Code 18.22.130.
• “In all critical aquifer recharge areas, stormwater runoff shall be controlled and treated in
accordance with best management practices and facility design standards as identified
and defined in the Stormwater Management Manual for the Puget Sound Basin, as
amended, and the stormwater provisions contained in Chapter 18.30 Jefferson County
Code.” Jefferson County Code 18.22.130(2).
• “All land uses identified in Jefferson County Code 18.22.120 and special aquifer recharge
protection areas that are also classified as susceptible aquifer recharge areas (as defined
in this article) shall be designated areas of special concern pursuant to WAC Title 246.”
Jefferson County Code 18.22.130(3)(a). “Such designation shall identify minimum land
area and best management practices for nitrogen removal as design parameters
necessary for the protection of public health and groundwater quality.” Jefferson County
Code 18.22.130(3)(b).
• “Above-ground and underground storage tanks shall be fabricated, constructed, installed,
used and operated in a manner which prevents the release of hazardous substances to
the ground or groundwater and be consistent with the Department of Ecology’s standards
for construction and installation under Chapter 173-360 WAC.” Jefferson County Code
18.22.130(5).
• “Land use activities that generate hazardous waste, which are not prohibited outright
under this code, and which are conditionally exempt from regulation by the Washington
Department of Ecology under WAC 173-303-100, or which use, store, or handle
hazardous substances, shall be required to prepare and submit a hazardous materials
management plan that demonstrates that the development will not have an adverse
impact on groundwater quality. The facility owner must update the hazardous materials
management plan annually.” Jefferson County Code 18.22.130(7).
• “The administrator may require additional mitigating conditions, as needed, to provide
protection to all critical aquifer recharge areas to ensure that the subject land or water use
action will not pose a risk of significant adverse groundwater quality impacts. The
determination of significant adverse groundwater quality impacts will be based on the anti-
degradation policy included in Chapter 173-200 WAC.” Jefferson County Code
18.22.130(9).
• “The Washington State Department of Ecology regulates well drilling pursuant to the
Water Well Construction Act. Proposed wells, including those exempt from permitting
requirements, must be sited at least 100 feet from ‘known or potential sources of
contamination,’ which include “sea-salt water intrusion areas” (WAC 178-160-171), unless
5
a variance is obtained from Ecology per WAC 173-160-106. Jefferson County Code
18.22.130(8).
Geologically Hazardous Area or its Buffer Protection Regulations. Jefferson County Code
18.22.170.
• Requires a drainage and erosion control plan “when the project application involves either
of the following: (i) The alteration of a geologically hazardous area or its buffer; or (ii) The
creation of a new parcel within a known geologically hazardous area.” Jefferson County
Code 18.22.170(2)(a). Drainage and erosion control plans “shall discuss, evaluate and
recommend methods to minimize sedimentation of adjacent properties during and after
construction.” Jefferson County Code 18.22.170(2)(b). Detailed requirements for a
drainage and erosion control plan are contained in Jefferson County Code 18.22.410.
• Requires additional clearing and grading protections for geologically hazardous areas in
addition to general clearing and grading provisions in Chapter 18.30 Jefferson County
Code. Jefferson County Code 18.22.170(3).
• Requires vegetation retention for geologically hazardous areas. Jefferson County Code
18.22.170(4).
• Requires buffers and buffer marking for geologically hazardous areas. Jefferson County
Code 18.22.170(5) and Jefferson County Code 18.22.170(6).
• Requires a geotechnical report “when the application involves either of the following: (i)
The alteration of a landslide hazard area or its buffer. (ii) The creation of a new parcel
within a known landslide hazard area. (iii) The construction of a publicly owned facility in
a designated seismic hazard area.” Jefferson County Code 18.22.170(9)(a). A project
cannot be approved if a geotechnical report does not certify all of the following: “(i) There
is minimal landslide hazard as proven by a lack of evidence of landslide activity in the
vicinity in the past; (ii) An analysis of slope stability indicates that the proposal will not be
subject to risk of landslide, or the proposal or the landslide hazard area can be modified
so that hazards are eliminated; (iii) The proposal will not increase surface water discharge
or sedimentation to adjacent properties beyond predevelopment conditions; (iv) The
proposal will not decrease slope stability on adjacent properties; and (v) All newly created
building sites will be stable under normal geologic and hydrogeologic conditions (if
applicable).” Jefferson County Code 18.22.170(9)(b). “Where a geotechnical report is
required for a seismic hazard area, the project application shall not be approved unless
the geotechnical report demonstrates that the proposed project will adequately protect the
public safety.” Jefferson County Code 18.22.170(9)(c). Detailed requirements for a
geotechnical report are contained in Jefferson County Code 18.22.420.
• Protects species and habitats of local importance, including wildlife corridors, that are not
covered by the federal and state sensitive, threatened, or endangered species regulations.
CC 18.22.220.
Habitat Management Plan Regulations. Jefferson County Code 18.22.265.
Habitat management plan required, “When a development proposal is located on lands which
may contain a habitat for a protected species other than bald eagle nesting territories, or when
the applicant proposes to alter, decrease or average the standard buffer, a habitat
management plan (HMP) shall be required, consistent with the requirements of Jefferson
County Code 18.22.440.” Detailed requirements for a habitat management plan report are
contained in Jefferson County Code18.22.440.
6
Fish and Wildlife Habitat Conservation Area (FWHCA) and its Buffer Regulations. Jefferson
County Code 18.22.270.
• Requires a drainage and erosion control plan for any Fish and Wildlife Habitat
Conservation Area and its buffer. Jefferson County Code 18.22.270(2). Detailed
requirements for a drainage and erosion control plan are contained in Jefferson County
Code 18.22.410.
• Requires a grading plan for any Fish and Wildlife Habitat Conservation Area and its buffer.
Jefferson County Code 18.22.270(3). Detailed requirements for a grading plan are
contained in Jefferson County Code 18.22.430.
• Requires vegetation retention for any Fish and Wildlife Habitat Conservation Area and its
buffer. Jefferson County Code 18.22.270(4).
• Requires buffers for any Fish and Wildlife Habitat Conservation Area and its buffer.
Jefferson County Code 18.22.270(5).
• Requires buffer marking for any Fish and Wildlife Habitat Conservation Area and its buffer.
Jefferson County Code 18.22.270(8).
Wetland Buffer Regulations. Jefferson County Code 18.22.310.
Wetland Protection Regulations. Jefferson County Code 18.22.330.
• Wetland delineation required. Jefferson County Code 18.22.330(2). Detailed
requirements for a wetland delineation report are contained in Jefferson County Code
18.22.450.
• Provides wetland buffer standard requirements. Jefferson County Code 18.22.330(3) and
Jefferson County Code 18.22.330(6).
• Requires a drainage and erosion control plan. Jefferson County Code 18.22.330(4).
• Requires buffer marking. Jefferson County Code 18.22.330(5).
Wetland Mitigation Regulations. Jefferson County Code 18.22.350.
CHAPTER 18.25 JEFFERSON COUNTY CODE SHORELINE MASTER PROGRAM
Chapter 18.25 Jefferson County Code protects shorelines using the following key provisions:
Use Regulations in Each Shoreline Environment Designation. Jefferson County Code
18.25.220.
These regulations enforce policies described in Jefferson County Code 18.25.210.
Critical Areas, Shoreline Buffers, and Ecological Regulation. Jefferson County Code
18.25.270.
• Requires all shoreline use and development to be located, designed, constructed,
conducted, and maintained in a manner that maintains shoreline ecological processes and
functions. Jefferson County Code 18.25.270(2)(a).
• Prohibits any use or development that causes the future ecological condition to become
worse than current condition. Jefferson County Code 18.25.270(2)(b).
7
• Requires proponents of new shoreline use and development to employ measures to
mitigate adverse impacts on shoreline functions and processes. Jefferson County Code
18.25.270(2)(c).
• Requires consideration of the cumulative impacts of individual uses and developments,
including preferred uses and uses that are exempt from permit requirements, when
determining whether a proposed use or development could cause a net loss of ecological
functions. Jefferson County Code 18.25.270(3)(a).
• Authorizes the county to require the applicant/proponent of shoreline uses to prepare
special studies, assessments and analyses as necessary to identify and address
cumulative impacts including, but not limited to, impacts on fish and wildlife habitat, public
access/use, aesthetics, and other shoreline attributes. Jefferson County Code
18.25.270(3)(b).
• Requires a minimum shoreline buffer of 150 feet for marine shores and stream/river
shores and 100 feet for lake shores. Jefferson County Code 18.25.270(3)(c).
• Requires vegetation maintenance in shoreline buffers. Jefferson County Code
18.25.270(3)(h).
• Requires increased shoreline buffers where the development would be: (i) Susceptible to
severe erosion resulting in adverse impacts to the shoreline; (ii) Susceptible to health and
safety risks caused by stream or river channel migration; (iii) Susceptible to health and
safety risks caused by flooding – from sea, river/stream; or, (iv) On steeply sloped (greater
than 25 percent) land adjacent to the ordinary high water mark. Jefferson County Code
18.25.270(3)(k).
Historic, Archaeological, Cultural, Scientific and Educational Resources Protection. Jefferson
County Code 18.25.280.
• Requires preservation and protection of shoreline historic, archaeological, and cultural
resources that are recorded by the Washington State Department of Archaeology and
Historic Preservation and resources that are inadvertently discovered during use or
development activities. Jefferson County Code 18.25.280(2)(a).
• Requires that all feasible means shall be employed to ensure that fore shorelines. data,
structures, and sites having historical, archaeological, cultural, scientific, or educational
significance are preserved, extracted, or used in a manner commensurate with their
importance. Jefferson County Code 18.25.280(2)(b).
• Requires prohibition or postponement of a shoreline use for any use or development that
poses a threat to historic, archaeological, cultural, scientific, and educational resources.
Jefferson County Code 18.25.280(2)(d).
• For shoreline properties within 500 feet of a known or probable historic, archaeological, or
cultural site: (i) Requires notification to affected tribes and agencies such as the State
Department of Archaeology and Historic Preservation of the proposed activity including
timing, location, scope, and resources affected; and, (ii) Requires the applicant to provide
a cultural resource site assessment prior to development unless the administrator
determines that the proposed development activities do not include any ground disturbing
activities and will not impact a known historic, archaeological, cultural, scientific and
educational resources. Jefferson County Code 18.25.280(3)(a).
• Requires a detailed cultural resources management plan for shoreline development where
a cultural resource site assessment identifies the presence of significant historic or
archaeological resources. historic, archaeological, cultural, scientific, and educational
resources. Jefferson County Code 18.25.280(3)(b).
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Shoreline Setbacks and Height Regulations. Jefferson County Code 18.25.300.
• Requires building and sideyard setbacks from shoreline buffer. Jefferson County Code
18.25.300(2).
• Requires building height limits when such a height will obstruct the view of a substantial
number of residences on or adjoining such shorelines. Jefferson County Code
18.25.300(2).
Vegetation Conservation Regulations. Jefferson County Code 18.25.310.
• Requires demonstration with the policy requirements in Jefferson County Code
18.25.310(1). Jefferson County Code 18.25.310(2)(b).
• Requires vegetation management to maintain views. Jefferson County Code
18.25.310(2)(c).
• Vegetation management proposals may be denied if they result in an adverse effect to:
(A) Slope stability; (B) Habitat value; (C) Health of surrounding vegetation; (D) Risk of wind
damage to surrounding vegetation; (E) Nearby surface or ground water; or, (F) Water
quality of a nearby water body. Jefferson County Code 18.25.310(2)(c).
• Requires maintenance of existing shoreline vegetation to the maximum extent possible,
with limited exceptions. Jefferson County Code 18.25.310(2)(d).
• Requires restoration or enhancement of shoreline vegetation using native species
approved by the county that are of a similar diversity, density, and type to that occurring
in the general vicinity of the site prior to any shoreline alteration. Jefferson County Code
18.25.310(2)(f).
• Requires management of vegetative debris. Jefferson County Code 18.25.310(2)(i).
Water Quality and Quantity Regulations. Jefferson County Code 18.25.320.
• Requires that all shoreline uses and activities to use effective erosion control methods
during both project construction and operation. At a minimum, effective erosion control
methods shall require compliance with the current edition of the Department of Ecology’s
Stormwater Management Manual, NPDES General Permit requirements, and the
stormwater management provisions of JCC 18.30.070. Jefferson County Code
18.25.320(2)(a).
• To avoid water quality degradation by malfunctioning or failing septic systems, requires
that on-site sewage systems shall be located and designed to meet all applicable water
quality, utility, and health standards. Jefferson County Code 18.25.320(2)(b).
• Prohibits use of materials they may come into contact with water to non-toxic materials.
Jefferson County Code 18.25.320(2)(c).
• Requires that materials used for decking or other structural components be approved by
applicable state agencies for contact with water to avoid discharge of pollutants from wave
splash, rain, or runoff. Jefferson County Code 18.25.320(2)(c).
• Prohibits wood treated with creosote, copper chromium arsenate or pentachlorophenol in
shoreline water bodies. Jefferson County Code 18.25.320(2)(c).
• Prohibits discharging solid wastes, liquid wastes and untreated effluents to any ground
water or surface water or to be discharged onto land. Jefferson County Code
18.25.320(2)(d).
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• Prohibits the release of oil, chemicals, genetically modified organisms, or hazardous
materials onto land or into the water. Jefferson County Code 18.25.320(2)(d).
Dredging Regulations. Jefferson County Code 18.25.360.
• Limits dredging to specific approved uses. Jefferson County Code 18.25.360(3)(c).
• Prohibits dredging for flood management purposes, except in limited circumstances.
Jefferson County Code 18.25.360(3)(d).
• Prohibits dredging for the primary purpose of obtaining material for landfill, upland
construction, or beach nourishment. Jefferson County Code 18.25.360(3)(f).
• Prohibits maintenance dredging except within the existing footprint in accordance with
previous approved plans. Jefferson County Code 18.25.360(3)(g).
• Regulates dredge disposal. Jefferson County Code 18.25.360(4) .
Filling and Excavation Regulations. Jefferson County Code 18.25.370.
• Prohibits filling and excavation at on shorelines unless part of an approved shoreline use
or development activity, subject to the requirements of the primary use or development.
Jefferson County Code 18.25.370(3)(a).
• When allowed, requires that filling and/or excavation shall be located, designed, and
carried out in a manner that: (i) Minimize adverse impacts on the shoreline environment;
(ii) Blend in physically and visually with natural topography, so as not to interfere with
appropriate use, impede public access, or degrade the aesthetic qualities of the shoreline;
and, (iii) Does not require shoreline armoring or stabilization to protect materials placed
unless it is part of an approved shoreline restoration project and shoreline armoring or
stabilization measures are needed to keep the material in place. Jefferson County Code
18.25.370(3)(c).
• Requires fill materials placed within shoreline jurisdiction shall be from an approved source
and shall consist of clean sand, gravel, soil, rock, or similar material. Jefferson County
Code 18.25.370(3)(d).
• Prohibits the use of contaminated material or construction debris. Jefferson County Code
18.25.370(3)(d).
• Prohibits fill placed waterward of the ordinary high water mark when alternatives are
infeasible and then only in limited circumstances. Jefferson County Code 18.25.370(3)(e).
• Unless the county determines that fill or excavation issues are adequately addressed via
another regulatory review process, all proposals for filling or excavation must provide the
following information: (i) A description of the proposed use of the fill area; (ii) A description
of the fill material, including its source, and physical, chemical and biological
characteristics; (iii) A description of the method of placement and compaction; (iv) A
description of the location of the fill relative to natural and/or existing drainage patterns;
(v) A description and map of the fill area and depth relative to the ordinary high water
mark; (vi) A description of proposed means to control erosion and stabilize the fill; (vii) A
temporary erosion and sediment control (TESC) plan; and, (viii) A description of proposed
surface runoff control measures. Jefferson County Code 18.25.370(3)(g).
Flood Control Structure Regulations. Jefferson County Code 18.25.380.
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• Where not prohibited, flood control structures require a shoreline conditional use permit.
Jefferson County Code. 18.25.380(2).
• Flood control structures prohibited, unless there is credible engineering and scientific
evidence that: (i) They are necessary to protect existing, lawfully established
development; (ii) They are consistent with Chapters 15.15 and 18.30 JCC and the county
Comprehensive Plan; (iii) Nonstructural flood hazard reduction measures are infeasible;
and, (iv) Proposed measures are consistent with an adopted comprehensive flood hazard
management plan if available. Jefferson County Code 18.25.380(3)(a).
• When permitted, requires that flood control structures be: (i) Constructed and maintained
in a manner that does not degrade the quality of affected waters or the habitat value
associated with the in-stream and riparian area; (ii) Placed landward of the OHWM except
for weirs, current deflectors and similar structures whose primary purpose is to protect
public bridges and roads; (iii) Placed landward of associated wetlands and designated
habitat conservation areas, except for structures whose primary purpose is to improve
ecological functions; (iv) Designed based on engineering and scientific analyses that
provide the highest degree of protection to shoreline ecological functions or processes;
(v) Designed to allow for normal ground water movement and surface runoff. Natural in-
stream features such as snags, uprooted trees, or stumps should be left in place unless
they are actually causing bank erosion or higher flood stages; and, (vi) Designed to allow
streams to maintain point bars and associated aquatic habitat through normal accretion
so that the stream can maintain normal meander progression and maintain most of its
natural storage capacity. Jefferson County Code 18.25.380(3)(b).
• When permitted, requires that dikes and levees be limited to that height required to protect
adjacent lands from the predictable annual flood unless it can be demonstrated through
hydraulic modeling that a greater height is needed and will not adversely impact shoreline
ecological functions and processes. Jefferson County Code 18.25.380(3)(c).
• Prohibits flood control works on estuary or embayment shores, on point and channel bars,
and in salmon and trout spawning areas, except for the purpose of fish or wildlife habitat
enhancement or restoration. Jefferson County Code 18.25.380(3)(d).
• Prohibits flood control structures and stream channelization projects that damage fish and
wildlife resources, recreation, or aesthetic resources, or create high flood stages and
velocities. Jefferson County Code 18.25.380(3)(e).
• Prohibits use of solid waste such as motor vehicles, derelict vessels, appliances, or
demolition debris; construction of flood control works. Jefferson County Code
18.25.380(3)(f).
• Requires that flood control structures not adversely affect valuable recreation resources
and aesthetic values such as point and channel bars, islands, and braided banks.
Jefferson County Code 18.25.380(3)(g).
• Requires flood control structures to be professionally engineered and designed prior to
final approval. Jefferson County Code 18.25.380(3)(h).
• Requires the design be consistent with the Department of Fish and Wildlife Aquatic Habitat
Guidelines and other applicable guidance and regulatory requirements. Jefferson County
Code 18.25.380(3)(h).
• Requires flood control structures be installed or constructed without the developer having
obtained all applicable federal, state, and local permits and approvals, including but not
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limited to a Hydraulic Project Approval from the Department of Fish and Wildlife. Jefferson
County Code 18.25.380(3)(i).
• Requires that for removal of beaver dams to control or limit flooding shall be allowed that
the project proponent coordinate with the Department of Fish and Wildlife and obtain all
necessary permits and approvals from the state. Jefferson County Code 18.25.380(3)(j).
• Authorizes the county to require the proponent to prepare a mitigation plan that describes
measures for protecting shoreline and in-stream resources during construction and
operation of a flood control structure. Jefferson County Code 18.25.380(3)(l).
In-stream Structure Regulations. Jefferson County Code 18.25.390.
• Where not prohibited, in-stream structures require a shoreline conditional use permit.
Jefferson County Code. Jefferson County Code 18.25.390(2).
• Prohibits dams and associated power generating facilities, except in the rare instance
where there is clear evidence that the benefits to county residents outweigh any potential
adverse ecological impacts. Jefferson County Code 18.25.390(3)(a).
• When permitted, requires in-stream structures and their support facilities to be: (i)
Constructed and maintained in a manner that does not degrade the quality of affected
waters or the habitat value associated with the in-stream and riparian area; and, (ii)
Located and designed based on reach analysis to avoid the need for structural shoreline
armoring. Jefferson County Code 18.25.390(3)(c).
• Requires all in-water diversion structures be designed to permit the natural transport of
bedload materials. Jefferson County Code 18.25.390(3)(d).
• Requires all debris, overburden and other waste materials from construction shall be
disposed of in such a manner that prevents their entry into a water body. Jefferson County
Code 18.25.390(3)(d).
• In-stream structures shall not impede upstream or downstream migration of anadromous
fish. Jefferson County Code 18.25.390(3)(e).
• Prohibits placement of small-scale power generating microturbines in streams, unless they
do not create impoundments and there are no adverse effects on shoreline functions and
processes, including but not limited to, stream flow, habitat structure, temperature, and/or
water quality. Jefferson County Code 18.25.390(3)(f).
• Requires that the county l take appropriate measures and precautions to prevent the
proliferation of small-scale power generating apparatus as necessary to prevent
cumulative adverse impacts. Jefferson County Code 18.25.390(3)(f).
• Requires that any proposed in-stream structure to be professionally engineered and
designed prior to final approval. Jefferson County Code 18.25.390(3)(g).
• Prohibits installation of any in-stream structure without the developer having obtained all
applicable federal, state, and local permits and approvals, including but not limited to a
Hydraulic Project Approval (HPA) from the State Department of Fish and Wildlife.
Jefferson County Code 18.25.390(3)(h).
• Unless the county determines that in-stream structure proposal issues are adequately
addressed via another regulatory review process, the proponent of any in-stream structure
proposal to provide the following information prior to final approval: (i) A site suitability
analysis that provides the rationale and justification for the proposed structure. The
analysis shall include a description and analysis of alternative sites, and a thorough
discussion of the environmental impacts of each; (ii) A hydraulic analysis prepared by a
licensed professional engineer that describes anticipated effects of the project on stream
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hydraulics, including potential increases in base flood elevation, changes in stream
velocity, and the potential for redirection of the normal flow of the affected stream; (iii)A
biological resource inventory and analysis prepared by a qualified professional biologist
that describes the anticipated effects of the project on fish and wildlife resources; (iv)For
hydropower facilities, the proposed location and design of powerhouses, penstocks,
accessory structures and access and service roads; (v) Proposed provisions for
accommodating public access to and along the affected shoreline, as well as any
proposed on-site recreational features; (vi) A description of any plans to remove
vegetation and/or revegetate the site following construction; and proposed mitigation plan
that describes, in detail, provisions for protecting in-stream resources during construction
and operation, and measures to compensate for impacts that resources that cannot be
avoided; and, (vii) A description of sites proposed for the depositing of debris, overburden,
and other waste materials generated during construction. Jefferson County Code
18.25.390(3)(i).
Shoreline Restoration Regulations. Jefferson County Code 18.25.400.
• Where not prohibited, in-shoreline restoration requires a shoreline conditional use permit.
Jefferson County Code 18.25.400(2).
• Shoreline restoration “must be carried out in accordance with an approved restoration plan
and in accordance with the policies and regulations of this program.” Jefferson County
Code 18.25.400(3).
Structural Shoreline Armoring and Shoreline Stabilization Regulations. Jefferson County
Code 18.25.410.
• Prohibits replacement of existing nature shoreline armoring in kind, unless there is a
demonstrated need to protect public transportation infrastructure, essential public
facilities, and primary structures from erosion caused by currents, tidal action, or waves
and all of the following apply: (i) The replacement structure is designed, located, sized,
and constructed to assure no net loss of ecological functions; (ii) The replacement
structure performs the same stabilization function of the existing structure and does not
require additions to or increases in size; and, (iii) The replacement structure shall not
encroach waterward of the ordinary high water mark or existing structure unless the
residence was occupied prior to January 1, 1992, and there are overriding safety or
environmental concerns. In such cases, the replacement structure shall abut the existing
shoreline stabilization structure. Jefferson County Code 18.25.410(3)(a).
• Requires removal of older structures as new ones are put in place, unless removal would
cause more ecological disturbance than leaving the remnant structure in place. Jefferson
County Code 18.25.410(3)(b).
• Land subdivisions shall be designed to assure that future development or use of the
established lots will not require structural shoreline armoring. Jefferson County Code
18.25.410(4)(a).
• Prohibits use of a bulkhead, revetment or similar shoreline armoring to protect a platted
lot where no primary use or structure presently exists. Jefferson County Code
18.25.410(4)(b).
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• Prohibits structural shoreline armoring for the sole purpose of leveling or extending
property or creating or preserving residential lawns, yards, or landscaping. Jefferson
County Code 18.25.410(4)(c).
• Prohibits structural shoreline armoring in or adjacent to lakes and other low energy
environments such as bays and accreting marine shores. Jefferson County Code
18.25.410(5)(a).
• New structural shoreline armoring may be permitted and existing structural shoreline
armoring may be expanded only when one or more of the following apply: (i) When
necessary to support a project whose primary purpose is enhancing or restoring ecological
functions; (ii) As part of an effort to remediate hazardous substances pursuant to Chapter
70.105 RCW; (iii) When necessary to protect public transportation infrastructure or
essential public facilities and other options are infeasible; and,(iv) When necessary to
protect an existing, lawfully established primary water-oriented use, including a residence
but not including a boathouse or other accessory structure, that is in imminent danger of
loss or substantial damage from erosion caused by tidal action, currents, or waves.
Jefferson County Code 18.25.410(5)(b). Proposals for new or expanded shoreline
armoring also must clearly demonstrate all of the following: (i) The erosion is not being
caused by upland conditions, such as the loss of vegetation or poor drainage; (ii) The
structural shoreline armoring design is the least environmentally damaging alternative; (iii)
The shoreline armoring complies with the flood damage prevention regulations in JCC
18.30.070; (iv) Adverse impacts are fully mitigated according to the prescribed mitigation
sequence such that there is no net loss of shoreline ecological functions or processes;
and, (v) Alternatives to structural shoreline armoring including vegetative shoreline
stabilization, flexible/natural materials and methods, beach nourishment and other forms
of bioengineering are determined to be infeasible or insufficient. Jefferson County Code
18.25.410(5)(c).
• Requires compliance with shoreline armoring design standards. Jefferson County Code
18.25.410(6).
• Requires compliance with bulkhead standards. Jefferson County Code 18.25.410(7).
• Requires compliance with revetment standards. Jefferson County Code 18.25.410(8).
• Requires compliance with breakwater, jetty and seawall standards. Jefferson County
Code 18.25.410(8).
Chapter 18.30 DEVELOPMENT STANDARDS
General Development Standards. Jefferson County Code 18.30.020:
(1) No building, structure or part thereof shall hereafter be erected, constructed,
reconstructed, moved, or structurally altered unless in conformity with all of the
regulations specified in this chapter for the land use district in which it is located;
(2) No building or structure shall encroach on any public right-of-way; no building
or structure shall encroach on any private easement or right-of-way unless written
permission is obtained from the easement grantee or right-of-way owner;
(3) No part of a yard, or other open space, or off-street parking or loading space
required about or in connection with any building for the purpose of complying with
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this chapter, shall be included as part of a yard, open space or off-street parking
or loading space similarly required for any other building or structure;
(4) Except as may be specifically provided elsewhere in this code, only one
dwelling unit and one accessory dwelling unit per lot is allowed in those districts
that permit residential uses; and
(5) All land use activities shall be served by appropriate transportation facilities.
Transportation facilities shall be adequate to meet the level of service standards
adopted in the Jefferson County Comprehensive Plan and the appropriate design
standards referenced in JCC 18.30.080(1)(a). If transportation facilities would
become inadequate, the applicant shall be required to provide necessary
improvements and/or implement alternative measures such as transportation
demand management (TDM), project phasing, or other measures acceptable to
Jefferson County that will maintain the adopted level of service standards and meet
design standards. If transportation facilities are not adequate, Jefferson County
shall not approve the proposed development. Transportation facilities shall be
deemed adequate if necessary, improvements are planned and designated
funding is secured in the Jefferson County Six-Year Transportation Improvement
Program.
Water Supplies Regulations. Jefferson County Code 18.30.030:
When the development or redevelopment of land requires the availability of a
supply of potable water as determined by the administrator, potable water shall be
delivered by a means approved by the Washington Department of Health and/or
Jefferson County public health.
(1) All development must conform to the requirements of Jefferson County public
health and the Jefferson County coordinated water system plan regarding the
availability and provision of water.
(2) Water supply facilities shall be adequate to provide potable water from a public
or community water supply source and shall be constructed in conformity to
standards of the jurisdictional governmental authority, unless Jefferson County
public health approves the use of individual, on-site water supply wells.
(3) Water sources and facilities adequate for fire protection purposes shall be
provided in all developments to the satisfaction of the Jefferson County fire
marshal. Fire flow shall be determined in accordance with the provisions of JCC
Title 15, as amended.
Sewage Disposal Regulation. Jefferson County Code 18.30.040:
(1) 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.
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(2) Design and construction 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.
Density, Dimension, and Open Space Standards. Jefferson County Code 18.30.050.
Density, dimension, and open space standards are listed in this section and its Table 6-1 for
each zone. There are specific standards in each zone for:
• Minimum Rear and Side Setbacks.
• Maximum Building Dimensions.
• Building Height.
• Area of Impervious Surface Coverage.
• Area of Building Coverage.
• Maximum Building Size.
Grading and Excavation Standards. Jefferson County Code 18.30.060.
• Requires all grading and clearing activities to be conducted so as to minimize potential
adverse effects of these activities on forested lands, surface water quality and quantity,
groundwater recharge, and fish and wildlife habitat, adjacent properties, and downstream
drainage channels. Jefferson County Code 18.30.060(1)(a).
• Requires drainage and erosion control for all grading activities. Jefferson County Code
18.30.060(2).
• Requires use of Best Management Practices (BMPs) from the currently adopted
Stormwater Management Manual for Western Washington (WWSMM) (see
JCC 18.30.070) or as specified by the county engineer shall be employed in the control of
erosion and sediment during construction, to permanently stabilize soil exposed during
construction, and in the design and operation of stormwater and drainage control systems.
Jefferson County Code 18.30.060(3).
• Requires SEPA review for project or building permits which involve grading of 500 or
more cubic yards are subject to environmental review under the State Environmental
Policy Act (SEPA) (see Article X of Chapter 18.40 JCC) unless the grading is SEPA-
exempt under WAC 197-11-800. Jefferson County Code 18.30.060(5)(a).
• Requires a stormwater management permit when grading involves 500 cubic yards or
more, with limited exceptions. Jefferson County Code 18.30.060(5)(b).
Stormwater Management Standards. Jefferson County Code 18.30.070.
• Requires all new development and redevelopment must conform to the standards and
minimum requirements set by the most current version of the Washington Department of
Ecology Stormwater Management Manual for Western Washington (SMM) and obtain a
stormwater management permit if required by subsection (5) of this section. The
administrator may require additional measures as indicated by the environmental review
or other site plan review. Jefferson County Code 18.30.070.
• Requires a stormwater management permit for all grading of 500 cubic yards or more (not
exempted under JCC 18.30.060(5)(b)), land-disturbing activities of 7,000 square feet or
16
more, or creation of 2,000 square feet or more of impervious surface shall be subject to a
stormwater management permit. Jefferson County Code 18.30.070(5).
• Applications for a stormwater management permit must contain the following information:
(i) Source of fill material and deposition of excess material; (ii) Physical characteristics of
fill material; (iii) Proposed methods of placement and compaction consistent with the
applicable standards in of the International Building Code;
• (iv) Proposed surfacing material; (v) Proposed method(s) of drainage and erosion control;
(vi) Methods for restoration of the site; (vii) Demonstration that in-stream flow of water will
remain unobstructed; (viii) Demonstration that erosion and sedimentation from outflow
channels will be minimized by vegetation or other means; and, (ix) Demonstration that
pond runoff will be controlled to protect adjacent property from damage.
Landscaping/Screening Regulation. Jefferson County Code 18.30.130.
Landscaping and screening regulations are in Jefferson County Code 18.30.130.
Lighting Regulation. Jefferson County Code 18.30.140.
Lighting regulations are in Jefferson County Code 18.30.140.
Archaeological and Historic Resources Regulation. Jefferson County Code 18.30.160:
(1) When an application for a permit is received for an area known to contain
archaeological artifacts and data as identified by appropriate state, federal or tribal
agencies, the county shall not take action on the application and shall inform the
applicant thereof, and the applicant shall not initiate any excavation or
development activity until the site has been inspected and a written evaluation is
provided by a qualified archaeologist. Significant archaeological data or artifacts
must be recovered before work begins or resumes on a project. No application will
be delayed more than 10 working days for such an inspection. If the application is
approved by the county, conditions shall be attached reflecting the
recommendations of the archaeologist regarding preservation or protection of the
site.
(2) All permits shall contain a special provision advising the permit holder that if
during excavation or development of the site an area of potential archaeological
significance is uncovered, all activity in the immediate vicinity of the find must be
halted immediately and the administrator must be notified at once. Activities
authorized by the permit will not be delayed more than five working days for a
finding of significance by the administrator, following the administrator’s receipt of
notification, unless the permit holder agrees to an extension of that time period.
(3) All development proposed for location adjacent to sites which are listed or are
determined by the appropriate state or federal authority to be eligible for listing in
the state or national registers of historic places, must be located so as to
complement the historic site. Development which degrades or destroys the
historical character of such sites is not permitted.
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(4) Archaeological sites are subject to Chapter 27.44 RCW (Indian Graves and
Records) and Chapter 27.53 RCW (Archaeological Sites and Records) and must
comply with Chapter 25-48 WAC (Archaeological Excavation and Removal
Permit). Archaeological excavations are allowed subject to applicable state laws.
(5) Identified historical or archaeological resources must be considered in site
planning for public parks, public open space, and public access and site planning,
with access to such areas designed and managed so as to give maximum
protection to the resource.
On-site Sewage Disposal Best Management Practices in Critical Aquifer Recharge Areas.
Jefferson County Code 18.30.180.
• Requires compliance with Best Management Practices (BMPs) listed in the section.
Jefferson County Code 18.30.180.
• Requires use of Tables 1 and 2 to determine the type of on-site sewage disposal system
required and the minimum lot size in different soil types where public water is available.
Lot size requirements are taken from the Washington State On-Site Sewage Code,
Chapter 246-272A WAC, Table X. Soil textural classifications and minimum standards for
methods of effluent distribution for soil types and depths are taken from Chapter 246-
272A WAC, Tables V and VI, respectively. Jefferson County Code 18.30.180(2)(a).
• Prohibits on-site sewage permits in critical aquifer recharge areas where public water
systems are not available on lots less than one acre, except when lots sizes do not meet
the area requirements specified in Tables 1 and 2, and lot consolidation is impracticable,
then an approved composting toilet and greywater treatment system may be permitted.
Jefferson County Code 18.30.180(2)(b) and (c).
• Requires that permits for composting toilets shall include a condition requiring further
treatment of toilet waste at the Port Townsend composting facility or other approved site.
Jefferson County Code 18.30.180(2)(c).
• Prohibits on-site use or disposal of the toilet-generated compost. Jefferson County Code
18.30.180(2)(c).
Noise Regulation. Jefferson County Code 18.30.190:
Subject to any noise mitigation requirements in the State Environmental Policy Act,
Chapter 43.21C RCW, related to noise abatement, noise shall not exceed the
requirements in Chapter 8.70 JCC and Chapter 173-60 WAC, as they exist now or
may be amended in the future.
Jefferson County’s Responses to SEPA
Environmental checklist (WAC 197-11-960) January 6, 2020 Exhibit 11