HomeMy WebLinkAboutMLA18-00102 Williamson HE final reportCJ
ING JEFFERSON COUNTY
621 Sheridan Street
Port Townsend, WA 98368
OFFICE OF THE HEARING EXAMINER
FILE NO.:
APPLICANT/OWNER:
2wdilltd, 43
SUMMARY OF REQUEST:
JEFFERSON COUNTY
REPORT AND DECISION
MLA18-000102 — ZON18-00039
TYPE III CONDITIONAL USE PERMIT (CUP)
Tracy Williamson
2005 N.W. Peterson Road
Poulsbo, WA 98370
David Wayne Johnson, Associate Planner
Conditional use permit and cottage industry permit to process cannabis and a conditional
use permit to produce cannabis on a 5.48 acre parcel under State License Number
416544. The project includes two, 5,000 square foot buildings (100 x 50 feet) and one, 840
square foot (14 x 60 feet) maintenance building. 2,000 square feet will be used for
processing cannabis and 8,000 square feet will be used for production (growing) of
cannabis. The application is for parcel number 601-105-013 in Section 10, Township 26N,
Range 1 W, WM, Woodway Large Lot Subdivision Lot 3, located at 9790 Coyle Road,
Quilcene.
SUMMARY OF DECISION:
PUBLIC HEARING:
All requests denied without prejudice.
After reviewing the Jefferson County Department of Community Development Staff Report
and examining available information on file with the application, the Examiner conducted a
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public hearing on the request as follows:
The hearing was opened on February 25, 2020, at 5:00 p.m.
Parties wishing to testify were sworn in by the Examiner.
The following exhibits were submitted and made a part of the record as follows:
SEE ATTACHED INDEX LIST
The Minutes of the Public Hearing set forth below are not the official record and are
provided for the convenience of the parties. The official record is the recording of
the hearing that can be transcribed for purposes of appeal.
DAVID JOHNSON appeared, presented the Department of Community Development Staff
Report, and introduced Exhibit 35, a Certificate of Mailing. He then reviewed the law and
the procedure of how we got here. The regulatory requirements are the conditional use
permit (CUP) criteria. Staff finds that the application meets the code and will not have an
adverse impact on the area. The applicant is requesting approval of a cottage industry and
a CUP, and submitted a completed application for both on March 4, 2019. The Staff
Report and applicant's submission cover the concerns of the neighbors. The Jefferson
County Code was amended to eliminate the criterion that prohibited uses that violate
Federal law. The County does not enforce CCRs. He then discussed the CUP criteria and
noted that the project is consistent with the cottage industry criteria as it is an allowed use
in the applicable zone. Vegetation will screen the buildings from view, and the use is an
approved use in a higher density zone, i.e. RR1:5. Mr. Johnson visited the site of another
facility and could not see it, heard no noise, and smelled nothing. In the present case no
one will see the buildings with the proposed screening and landscaping. The traffic
associated with the business will not impact the roads. Concerning noise, he recommends
a condition of approval that the applicant provide a noise study following commencement
of operations. ORCAA has approved the odor control plan. Staff recommends approval
subject to compliance with conditions. Upon questioning byALEX SIDLES, attorney at law
representing Chris Wilson, Mr. Johnson referred to the proposals of hand watering and
best management practices for industrial uses. However, nothing is in the record.
Concerning forestry, because the applicant is clearing less than two acres, they do not
need a forest practices permit. If more than two acres are cleared, then they do need the
permit. However, only .68 acres were cleared. He is unsure of the number of board feet
harvested. DNR indicated that it would be substantially less than 5,000 board feet. Upon
questioning by AUSTIN WATKINS, deputy prosecuting attorney, Mr. Johnson responded
that Condition 6 prohibits hydroponic growing. Conditions 2, 3, 4, and 8 are from
environmental health.
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TRACY WILLIAMSON appeared and testified that in 2013 she had to find a new career.
They currently operate a marijuana business in an industrial area, but rents continue to
rise. They cannot afford a commercial space for growing. They purchased this parcel for
use as a home and a marijuana growing and processing business. That's why they
request a cottage industry. Marijuana is the most regulated of all agricultural crops.
Marijuana is similar to any other nursery and she then described their business. They will
abide by all conditions of approval. Upon questioning by MR. SIDLES, Ms. Williamson
testified that they have been upfront since they purchased the property. They would not
have purchased the property if they couldn't use it for a marijuana business. They propose
a flower based business only, although their license allows oils and extracts. They don't
have the expertise for the later. Marijuana plants do not like a lot of water.
LUKE WILLIAMSON appeared and read his statement into the record. He and Jessie will
work fulltime at the business.
JESSIE WILLIAMSON appeared and read her statement into the record. They have found
that having their business in an industrial area is very expensive. Agricultural crops do not
belong in an industrial area. Here, they found that they can build a house and that the
zoning is consistent. Light pollution will not occur as all lighting will be inside.
ADAM JENKINS appeared and testified that he was retained by the applicant to provide a
ventilation strategy. The noise analysis was conducted in accordance with WAC 173-60.
Agricultural uses are classified as Class C and the adjacent, residential parcels as Class A.
The sound level limits for the business are 60 dB(A) during the day and 50 at night. They
took ambient noise levels near the south property line for three days. The ambient
readings were 60 dB(A) during the day and 49 at night, which is consistent with the WAC
standard. They reviewed fans and considered other options before settling on the present
proposal. They applied the mitigation and found that the highest dB(A) reading is 47 at the
south property line, which is less than the required 50. He also considered the noticeable
noise increase of three dB(A) and found no compliance issues. Upon questioning by MR.
SIDLES, Mr. Jenkins testified that the use will require ventilation and the agricultural use
meets the definition of Class C. They will use the site for an agricultural use. He was not
aware of the residential uses, but they are Class A. However, such does not change the
EDNA.
AUSTIN WATKINS then appeared and testified that the Class A to Class A is based on the
zoning of parcels, which would be 55 to 45. The Willamsons do have a residential use, but
the County defaults to the use proposed, which is agriculture.
MR. JENKINS then testified in answer to Mr. Sidles questions that page 9, Table 7, of his
report shows that if the site were LOS A, they would need a 45 dB(A) limit. Here they have
a 47 plus or minus three. It is unlikely, but possible that it would get as high as 50. They
will use a gas fired heater or internal fans that he was not aware of. The eight, exterior
fans will create all of the noise, but other internal fans could increase the noise. They are
working off the blueprints of the building. Page 11 consists of the only drawing. It does not
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show the wall materials and doesn't account for any of the noise absorption by the building
walls. Upon questioning by DEE BOUGHTON, attorney at law representing the applicant,
Mr. Jenkins testified that the change of two to three dB(A) is not noticeable by people. A
five to six dB(A) change is substantial. Concerning the building walls, no equipment within
the building generates sound. They are getting the noise from the fans outside of the
building. The applicant proposes four fans per building, two drawing air in and two pulling
air out.
COLIN McKINLEY appeared and testified that he owns and operates a cannabis business
within the RR zone. He has run the business for five years and has no employees. He
and his wife run the business and have no impacts on the neighbors. He is familiar with
fans and noise and believes it preposterous that fans within the building could impact the
neighbors. Their neighbors can hear a lawnmower, but do not hear their fans. One cannot
hear the fans outside of the building. Concerning water, he previously harvested water
from his house and used it on his farm. He abandoned this method as the farm doesn't
need that much water for the plants. An indoor, hydroponic farm needs about ten percent
of the spray used for irrigation. The neighbors will not know this farm is operating. An
industrial area for a marijuana business is not good as the plants suck up contaminants.
Cannabis has grown all around us for years, but we did not know it because it was illegal.
Concerning waste material, ecology told him to distribute it all around the parcel.
GENE BALL appeared and testified that the nutrients used for agricultural crops are
expensive and are not used in excess. An indoor farm produces no wastewater pollution.
Concerning devaluation of property values, we can believe things, but we need substantive
facts to show the reduction. According to real estate brokers, property values are
increasing. The County encourages this type of use, as we need more rural land uses.
This is an extremely remote area, served by a one way road, and not in the center of town.
His dishwasher has a low noise rating of 46 dB(A). He is unsure as to when it is running.
He supports agricultural uses and RR businesses. Industrial area soils create a
disadvantage.
JERRY LILLY, acoustical consultant for 30 years, appeared and testified that he had
reviewed the applicant's noise study. He noted that the noise ordinance is based on the
zoning of a parcel and not its use. A residential dwelling built in a commercial zone does
not get the benefit of the residential use. It is his opinion that the maximum dB(A) is 55 day
and 45 night. The applicant's study shows an evaluation of noise levels for three days at a
site near Coyle Road. Such location over estimates the noise level in the area. People
won't build near the road, as most existing homes are 300 to 500 feet away. The ambient
noise level could therefore be lower. In the middle of the night the ambient level would be
in the 30s, which affects the hourly average levels. The ambient dB(A) will be quite a bit
lower than in the report. There is insufficient information in the report for him to verify the
noise level. They measured noise from two supply fans and two exhaust fans. They will
need a mechanical engineer to ensure negative pressure as proposed. They don't know
how the building will be constructed. For Austin Smith they evaluated noise levels for all
openings. If the building is steel and air tight, they could measure the noise from the fans.
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He referred to the colored pictures where two fans are shown on the sides of the building.
They probably have one fan within 25 feet from the property line. A fan 25 feet from the
property line generating only 45 dB(A) is not realistic. In Smith, they had negative pressure
with fans on the opposite side of the building. Here, they obtained the fan noise data from
the manufacturer and were only given one set of data. No one fan will make the same
amount of noise at different locations. Also, manufactures test their fans in the laboratory.
Fans create two types of noise: the exhaust from the building and the supply into the
building. The exhaust can be three to five decibels louder. Upon questioning by MR.
BOUGHTON, Mr. Lilly responded that he was hired by Mr. Sidles and that Mr. Sidles'
clients oppose the project. The average distance from the road to existing houses is 300
to 500 feet. He went to Google Earth and got the dimensions. He did not visit the site and
made no measurements. He went to the manufacturer's website, called the manufacturer,
and saw photographs. We must test fans on the site and not in the lab to obtain an
accurate reading. Fans will make a different amount of noise. There is noway to show the
Examiner how much noise will awaken people. A condition of approval requires a noise
study. It is not impossible to obtain the noise readings now. Upon questioning by MR.
WATKINS, Mr. Lilly testified that he routinely interprets the WAC regulations in his way. An
agricultural use is allowed outright in the zone.
MR. JENKINS reappeared and testified that the road is close to the warehouse, and
therefore he made his readings closer to the road. Fan noise readings reduce over
distance at a faster level, but traffic noise remains louder for a longer distance. Fans get
quieter faster, almost twice as fast as vehicles. He took his measurements at the location
where the fans are the loudest. He could supplement his report with greater distance
measurements. Concerning the negative pressure, the mechanical engineer in his firm
adequately sized the fans to ensure negative pressure.
JOMAIN EGGERT appeared and testified that she resides on Coyle Road and is a five
year resident. She can smell marijuana from processing areas. Why not locate the
business in an industrial zone? Here, we have different regulations. People who buy
homes in the RR zone have certain expectations. A cottage industry is not a subordinate
use. The applicants wanted a cottage industry all along. Concerning the odor permit,
there are no regulations as to how to report a violation. The problem is with permit
compliance. She and her neighbors want clear air, water, and quiet.
STEVE BATE who resides downhill from the project appeared and testified that he cannot
see the other pot farm due to its location in an area below a 60 foot drop from the road.
This site abuts DNR property. At night he can hear owls and wildlife in the bay. The area
is rich in wildlife. He travels to his home along Ken's Way. This farm will set a precedent
for others and will allow an industrial use in the area. Approval will move an industrial use
into a rural area where there is little enforcement. The site is 30 minutes from the fire
department and a longer distance from the police department. It will attract criminal activity
far away from any government enforcement.
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CHRIS WILSON appeared and testified that Mr. Sidles represents him and his wife. Mr.
Johnson has been diligent in reviewing the application in accordance with the process. He
reviewed the ORCAA approval in Exhibit 16 and found that it does not represent a
complete approval. ORCAA's expectation of the location of the buildings as far as possible
from the property line is not met by their location at the southeast corner. The adjoining
property owner may wish to retain a residential use at that site. ORCAA also assumes air
tight buildings. He noted four exhibits addressing property values to include Exhibit 28,
pages 1 and 2 that show loss of property values and the fact that odors discourage home
buyers. Exhibit 30, page 2 shows that 27 percent of grow houses have difficulty in selling
their parcels, and 33 percent have difficulty where recreational marijuana was grown.
Some others made no disclosure.
VICTORIA GALONTI appeared and testified that it is good to see more businesses,
including those where people live, but she questions the industrial category. She noted
odor up and down Coyle Road, and felt that there must be a large number of skunks being
hit on the road. However, it was the odor from the existing marijuana operation. She can
smell the odor at the current location. She questioned whether the applicant will respond
to complaints and to whom residents would direct their complaints.
DR. JAMES OLSON appeared and testified that the business will create multiple hazards.
Ten thousand square feet of building is not a cottage industry. How can it compare with a
vegetable stand that needs adequate noise, light, water, and odor mitigation? Marijuana
odors are a combination of rotten eggs and skunk cabbage. Who will respond to enforce
the odor issues? Other issues include truck traffic, attractive nuisance, vandalism, and loss
of property values. He believes people were misinformed about the project, and most
listened to what the applicants had to say.
RYAN SCHROEDER appeared and testified that he cares deeply about the land and has
spent his entire life protecting it. The applicants propose an industrial activity, not a cottage
industry. He passes grow operations and can smell the odor hundreds of yards away. The
wind travels in various directions due to the water. No system exists that will protect them
from the odor.
CHUCK DOLAND appeared and testified that he resides approximately three miles from
the site. He is affected as a resident in the rural zoned area. It was the intent of GMA to
reduce sprawl. The applicants are moving to a residential area only to save money. While
the applicants assert that the building will be air tight, it will have significant ventilation.
They propose inserting an industrial use into the area. It will draw the criminal element that
break in to add to their supply. The parcel is 50 minutes from the nearest police station.
BONNIE STORY appeared and testified that she is the closest resident to the project. She
does not want the door open for this project. She referred to the CCRs, and that she
complies with both the CCRs and the code. This use is way out of character for the area.
It is a warehouse, not an agricultural use. It is not a barn, does not grow vegetables, and is
not a fruit orchard. It does not match the rural character and represents a large, land use
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change. It is not a cottage industry. She has four specific concerns regarding the project.
It is not now a great smelling place. She can smell marijuana even with the windows up.
The other marijuana use is located on about 40 acres. It is properly sited due to the
distance from the road, and creates no noise, and no odor control is needed. It is a model.
The proposed business will affect her property values. It will be a grow house not another
house in the neighborhood. They are not in compliance with ORCAA. The buildings are
not as far away from the property line as possible, but are close to both the property line
and the road. The business will create crime and the police department cannot get there
within an hour. People will try to break into the place, and it will be a magnet. DCD has led
these applicants down the primrose path.
JONNIE TOWNHALL appeared and questioned the amount of pesticides and herbicides
the applicants will use. It is beyond belief that ecology told them to spread the growings
around the ground. Pollutants will eventually drain into Hood Canal.
GARY WILLIAMS appeared and testified that he resides across Coyle Road from the
project. He referred to JCC 18.40.530 that sets forth the CUP criteria and allows approval
only if all criteria are met. One criteria requires that the use be harmonious and
appropriate with other uses in the area. Nothing is harmonious about it. It is proposed for
a RR zoned area. The RR zone covers beautiful areas in the County that are also fragile.
Uses like this will cause a loss of market value. Also, the CUP cannot have a substantial
adverse impact. Nothing is harmonious and appropriate for this use. The use will create
an attractive nuisance which the County Commissioners recognized. The use will also
violate Federal law and therefore the County can't issue a permit. The next door lot is for
sale, but no one will buy it for residential purposes.
VICKI NIEZEREM appeared and testified that she owns an adjacent parcel and
recommends denial as the project does not meet the criteria. The cottage industry criteria
requires an applicant to reside at the site. They are not residents. The outreach to the
community was performed because of a recommendation from the County. They will not
use the site as a home, and the proposed use is not appropriate. Beautiful homes exist in
the area and this use will become a blight. Her concerns include odor, because pot stinks.
They cannot mask the odor and it will permeate everything. Neighbors of other marijuana
grow operations have strong objection to the smells. The noise will be bad as fans create
a roar. The applicants must know that crime will occur as they are required to construct an
eight foot tall fence between buildings that look like a box. The project will affect property
values as no one will buy any lots. The articles that talk about the marijuana parcel do not
consider surrounding parcels. The business represents an injustice to the neighborhood.
The CUP is proceeding without ownership of a home on the site.
VIGO HENDERSON appeared and testified that the Marrowstone building was 150 feet
from Flager Road. This building is 25 feet from Coyle Road. Concerning emergency
access, the police department is 22.2 miles away and it takes them 32 minutes to get to
the site. Officers can't go much faster on the roads. Concerning property values, the
neighboring property owner to the south of the Flager Road project could not sell her
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property. When the applicant abandoned that site, the property sold immediately. He
talked to appraisers and real estate brokers regarding property values and the difficulty in
selling parcels near a marijuana grow operation. They would not testify, but agreed that
property values will fall.
CARL GONNELLA appeared and testified that he has no objection to the applicants'
business, but it can't be run from a home in the RR zone. The ordinance lists marijuana as
an agriculture use, but it is a mixture of agriculture and industrial. 75 percent of the
property in the County allows marijuana business outright. DCD did not take into
consideration property values, but the CUP criteria requires that they do so. This use is
commercial and is not meant for agricultural property. Studies about retail marijuana sales
and dispensaries are irrelevant. Another study shows that home values within .5 mile of a
marijuana grow operation have lower values. This neighborhood is the least desirable
option for such a business. A buyer on Marrowstone bought an adjacent property after the
appeal period had run. No one wants to live next to a smelly, noisy facility. The applicants
have not satisfied the property value issue.
KATHLEEN WALDRON appeared and testified that they have tried to change the JCC, but
have not succeeded. This project will set a precedent as others will want to locate on RR
sites.
CAROL WORKMAN appeared and read her statement into the record that included issues
regarding crime.
JESSIE WILLIAMSON reappeared and testified that they do not compost any materials on
site. They use airtight bags. They shred the plants, mix them with soil, and take them to a
landfill. They located the buildings based upon the topography of the site. If they move
them farther back, they move them into a steep ravine. The plants are grown on a table,
and they capture and reuse all of the water. They will have a maximum of four employees.
MR. JOHNSON reappeared and testified that the County does have a code compliance
officer to respond to odor issues. They have received no odor complaints from the public
for any marijuana grow facility. They can't respond if there is no odor complaint. However,
if violations occur, they can revoke the permit. They rely on neighbors to advise them of
odor issues. Marijuana growing is an agriculture use. Page 2 of the ordinance refers to it
as a type of agriculture use. The County does not regulate property values directly. Staff
agrees that the EDNA is not residential. It is a Class C EDNA agriculture use. No
evidence from the Sheriff's Office shows that these type of uses are crime magnets. A
robbery at a retail shop did occur, but allegations of crime associated with this business
amounts to fear and speculation. The County does prohibit relocating an existing
business.
MR. BOUGHTON reappeared and testified that the applicants are requesting a CUP and
cottage industry permit. The project meets the CUP criteria. It creates no harm. The use is
agriculture and the zoning is rural. The residence is a permitted use. They propose a rural
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use and nothing is better than a farming use in a rural area. The use is different as to the
type of farming. It is similar to a greenhouse, but marijuana has an historical stigma. The
building setbacks are 100 feet and 25 feet from the side yards, 43 feet from the road, and
250 feet from the rear yard. The use will not be seen, heard, or smelled. They have
obtained ORCAA approval and submitted a noise study. Mr. Jenkins testified that the
structure was designed by a mechanical engineer in his firm and that the building will have
negative pressure. The mechanical engineer assured of that, and not him. Mr. Lilly
testified that they can tell what the noise levels will be. He agrees and notes the Staff
Report condition that requires a noise study. Concerning movement from an industrial
area, nothing in the County code restricts the selection of property. They desire a place for
Luke to live and provide for himself. The agriculture use is perfect. The house is well
under construction as the structure has a roof, siding, and windows. They have a
legitimate building permit in hand. He has no objection to a condition requiring the final
permit and occupancy of the home. Concerning Condition 9, he has no problem with three
off site employees on the site unless approved by the Health Department. He can support
Condition 11.
MR. SIDLES reappeared and testified concerning the cottage industry that the Examiner
cannot approve a cottage industry without anyone living there, and that a cottage industry
is separate from the CUP. There is no such thing as obtaining code compliance with a
condition. They must meet it now, today. He referred to the Austin Smith decision and the
Decision on Reconsideration that are relevant here. Smith had a single-family residence
on site, but no evidence showed that Mr. Smith was a resident. We must apply the same
level of scrutiny here. Time is needed to establish residency. A one month residence does
not show "full time", and in Smith the Examiner required six months, as the LCB
requirement is six months. Concerning the CUP, Mr. Lilly provided a written report of Mr.
Jenkins' study. The EDNA Class C allows significant noise. The primary use is residential,
and the balance is agriculture. The proposed use puts it in a Class A EDNA. No
evaluation of sound through the walls or of the interior fans were considered. Exhibit 16 is
the odor control plan which requires them to change filters. The wastewater must meet
ECY guidelines on marijuana. They can't say that they will not have an accidental spill, as
they want to discharge to the on -site sewer. When they spray, they will need a permit from
ECY or the Feds. Residents have concerns regarding forest land conversions and whether
the applicant needs a forest practices permit. Mr. Johnson indicates that the standard is
two acres, but it also requires less than 5,000 board feet. It is unknown where the two acre
standard came from. The WAC refers to a parcel size of less than two acres. A forest
land conversion requires SEPA review.
No one spoke further in this matter. The Examiner left the record open for two weeks for
closing arguments by the parties.
NOTE: A complete record of this hearing is available in the office of Jefferson
County Department of Community Development.
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FINDINGS. CONCLUSIONS, AND DECISION:
FINDINGS:
1 The Hearing Examiner has heard testimony, admitted documentary evidence into
the record, and taken this matter under advisement.
2. State Environmental Policy Act (SEPA) Review: The project is categorically exempt
from SEPA review pursuant to Section 197-11-800(1)(b)(iii) and Section
18.40.750(1)(c) of the Jefferson County Code (JCC) (flexible minor construction
exemption), as the buildings are for agricultural use and under 30,000 square feet.
Alternatively, this project is exempt pursuant to WAC 197-11-800(1)(d) and JCC
18.40.750(1)(d) if any part of the application is interpreted to be a commercial use.
As construction of the buildings are exempt, the land use action is also exempt
pursuant to WAC 197-11-800(6)(a).
3. Notice of Application mailed to adjacent property owners and agencies: March 12,
2019 (Exhibit 8);
Posting of Notice on -site by Staff: March 12, 2019 (Exhibit 9);
Publication of Legal Notices: March 13, 2019 (Port Townsend -Jefferson County
Leader);
The record was left open for 14 calendar days from March 13, 2019 until March 27,
2019 at 4:30 p.m. for written closing arguments.
4. The applicant, Tracy Williamson, representing the Williamson family, has acquired a
possessory ownership interest in a generally rectangular, 5.48 acre parcel abutting
the west side of Coyle Road, north of its intersection with Kens Way and Blueberry
Hill Drive on the Toandos Peninsula in unincorporated Jefferson County. The
rectangular portion of the property proposed for development abuts Coyle Road for
approximately 264 linear feet and expands to 273 feet at the west property line.
The parcel measures 806 feet in depth. A triangular portion of the parcel that
extends approximately 170 feet to the north along Coyle Road and Old Coyle Road
will remain unimproved. The Williamson family consists of parents, Mark and Tracy
Williamson; son, Luke Williamson; and daughter, Jessie Williamson.
5. The applicant requests approval of three separate applications to allow
establishment of two separate uses combined into one business on the site as
follows:
A. Approval of a conditional use permit to allow a marijuana production
(growing) business;
B. A conditional use permit to allow a marijuana processing business;
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C. A cottage industry permit to allow said marijuana processing business.
The marijuana production business would occur within a 5,000 square foot, 14 foot
tall building; and 3,000 square feet of a second, 5,000 square foot, 14 foot tall
building. The marijuana processing use would occur in 2,000 square feet of one of
the buildings. The applicant also proposes a 14 foot by 60 foot (840 square foot)
maintenance building adjacent to the southern structure.
6. The site plan (Exhibit 12) shows access to the site provided by one driveway near
the north portion of the rectangular area of the parcel that extends to the southwest.
The driveway splits near the center of the parcel. The northern extension provides
access to a 32 foot by 24 foot (768 square foot) single-family residential dwelling
currently under construction and located 32 feet from the north property line. The
southern extension of the driveway provides access to the two marijuana buildings
and the maintenance building. The site plan shows an existing, waterwell between
the maintenance building and Coyle Road. Onsite septic disposal primary and
reserve drainfield areas consisting of 13,659 square feet are located between and
to the west of the marijuana buildings. Marijuana building No. 1 and the
maintenance building are oriented in a north -south direction and will measure 25
feet from the south property line. Building No. 1 will measure 50 feet by 100 feet.
The second building, shown as No. 2, is located to the northwest of Building 1. The
southeast corner of said building will touch the northwest corner of Building 1.
Building 2 is oriented in an east -west direction and also measures 50 feet by 100
feet. All of said improvements will be located in the eastern 40 percent of the
parcel, and the western 60 percent will remain vacant and unimproved.
7. The parcel is located within the Woodway large lot subdivision as are abutting
parcels to the north and south. Said subdivision is subject to covenants, conditions,
and restrictions (CCRs) that may or may not prohibit the applicant's use of the
parcel or the size of the residential structure currently under construction. However,
Jefferson County does not enforce private covenants.
8. The applicant's parcel and abutting parcels to the south and east across Coyle
Road are located within the Rural Residential 1:20 (RR-20) zone classification of the
JCC. Abutting parcels to the north and west are located within either the
Commercial Forest, Rural Forest, or in Holding Forest zone classifications. No
mapped or observed critical areas are located on the site.
9. Section 18.20.295(2)(B) JCC defines "Marijuana processor" as follows:
"Marijuana processor" means a person licensed by the State Liquor
Control Board [now State Liquor and Cannabis Board] to process
marijuana into usable marijuana and marijuana -infused products,
package and label useable marijuana and marijuana -infused products
for sale in retail outlets, and sell usable marijuana and marijuana-
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infused products at wholesale to marijuana retailers. Marijuana
processing for the purpose of this section may or may not include
drying, trimming and bagging of a recreational marijuana product.
Section 18.20.295(3)(b) JCC authorizes marijuana processing as an outright
permitted use in the Rural Industrial and Urban Industrial zones, and as a
conditional discretionary use with cottage industry permit in Rural Residential zones
to include the RR-20. In addition to the cottage industry standards set forth in JCC
18.20.170, an applicant must also meet the standards set forth in JCC 18.20.295
that address recreational marijuana activities. Finally, an applicant must show that
the application satisfies conditional use permit standards set forth in JCC 18.40.530.
10. Section 18.10.030 JCC defines "Cottage industry" as follows:
"Cottage industry" means a commercial or manufacturing activity
conducted in whole or in part in either the resident's single-family
dwelling unit or in an accessory building, but is of a scale larger than a
home occupation or home business. A cottage industry is a limited,
small-scale commercial or industrial activity, including fabrication, with
limited retail sales, that can be conducted without substantial adverse
impact on the residential character in the vicinity.
Section 18.10.170(1) JCC sets forth the purpose of a cottage industry as follows:
(1) Purpose. To provide for small-scale economic development
activities on residential parcels, subordinate to the primary residential
use, if the administrator finds that such activities can be conducted
without substantial adverse impact on the residential environment and
rural character in the vicinity. The scale and intensity of cottage
industries are typically greater than could be accommodated as a
home business, but less than would require a land use district
designation of commercial or industrial.
The 2,000 square foot marijuana processing business requires a cottage industry
permit. Based upon its size and general lack of impacts to the neighboring
community, the proposed processing business fits with the list of uses allowed as
cottage industries set forth in JCC 18.20.170(2). Such includes iron working or
blacksmith shops; furniture repair or refinishing; small equipment repair; auto and
truck repair and service; and excavating contractors. However, both the definition
and purpose of the cottage industry require that such businesses are subordinate to
an existing, primary, residential use. In the present case the applicant has not
established that a primary, residential use exists on the site.
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11. The first criterion that a cottage industry applicant must meet is set forth in JCC
18.20.170(4)(a) and reads as follows:
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.
In the present case the applicant, staff, and residents in opposition agree that no
full-time, bona -fide resident lives on the site. While the applicant has secured a
building permit for a single-family residential dwelling and is in the process of
constructing said residence, at present no one lives on the parcel full-time.
12. The intent of the above quoted code sections is that an existing landowner/resident
apply for a cottage industry permit. The code does not contemplate or allow a
scenario where the owner of an existing business makes application for a cottage
industry/conditional use permit prior to becoming a bona -fide resident of the parcel.
However, once becoming a bona -fide resident, the JCC provides no guidance as to
the length of time residency must occur.
13. In the present case the Williamson family owns and operates a marijuana
production and processing business located within the Glen Cove Light Industrial
area at 71 Eisenbeis Avenue, Port Townsend. The Williamsons readily
acknowledge that they cannot continue a successful business in a
commercial/industrial area due to the high rental cost. They acknowledge that they
would not have purchased the property if they could not use it for their marijuana
business. Thus, the Williamsons are not establishing a new cottage industry
business, but moving an existing business from a commercial/industrial area to an
RR-20 area. Assuming the applicant's proposed use is allowed (subject to
acquisition of a conditional use permit), it must meet all criteria for a cottage industry
before relocating the business to the proposed site. The applicant has not done so
as no bona -fide resident resides thereon.
14. Therefore, the application for a cottage industry and conditional use permit to allow
the marijuana processing business must be denied.
15. Section 2.30.120(3) JCC provides as follows:
The Examiner may: (a) approve the requested permit or decision; (b)
deny the requested permit of decision; (c) modify the requested
permit or decision.... The examiner may grant part of the requested
action, but deny another part of the requested action. The examiner
may deny the requested permit or decision with prejudice
(reapplication or resubmittal is not permitted for one year) or without
prejudice (reapplication or resubmittal is permitted)....
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In the present case it is not appropriate to approve a marijuana production use and
deny a marijuana processing use operated by the same applicant on the same site
and in the same building(s). Reasons include the possibility of new conditions or
revised conditions covering the single business that would not allow public
comment. Other issues not discussed include security for the site since no one
would live there, and preparation and transport of plants to a processing facility.
Finally, no monitoring of the site and equipment could occur during the critical
evening hours.
16. After review of the noise study, its critique, expert testimony, and the Austin Smith
Reports and Decisions, if the applicant decides to submit a new application, the
Williamson family and/or their experts should be prepared to address the following
issues:
A. Noise.
No evidence was presented regarding the noise of the fans starting
and stopping; the length of time the fans would be used; whether the
fans would operate at the same time; and noise generated by interior
fans and heaters.
2. Preparation of structural drawings showing the size of openings for
fans, the material used in construction to include wall thickness and
installation. Mr. Adam Jenkins in the Austin Smith hearing on March
29, 2018, recommended evaluation of the density of the walls in his
testimony.
3. An evaluation of the noise requirements and the odor requirements.
Do they conflict?
4. What is the size of the applicant's present business? Does it use the
same number and types of fans? If so, have they measured the noise
to determine the actual dB(A)?
5. In the Austin Smith matter the originally proposed Shaffer fans were
replaced by American Cool Air fans as they were considered the
quietest on the market. The applicant proposes a FanTech FKD 14
and FKD 16. How does the noise from these fans compare with the
Shaffer Fans and American Cool Air fans?
B. An analysis of the impacts of marijuana production with impacts of potential
small-scale, agricultural uses of the site and other uses allowed outright in
the RR-20 zone. See Hanson v. Chelan County, 81 Wn. App. 133 (1996), @
139. 140. For example, a comparison of the impacts of livestock, chickens
(roosters), and various farm activities to include planting, harvesting,
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spraying, irrigation, etc., with the applicant's proposed business.
C. Odor. A statement from ORCAA that it agrees or disagrees with the
proposed Building No. 1's location of 25 feet from the south property line.
Does the applicant's existing business generate odor?
D. The applicant either has or must show compliance with all standards
addressing wastewater disposal, water usage, timber harvest, lighting, and
traffic.
CONCLUSIONS:
The Hearing Examiner has jurisdiction to consider and decide the issues presented
by this request.
2. The applicant's request for a cottage industry permit to allow establishment of a
marijuana processing business does not meet the criteria therefor as a bona -fide
resident does not live at the site. The request for a conditional use permit to allow
marijuana production (growing) facility at the site is so closely interrelated to the
processing business that it cannot be separated and therefore must also be denied.
3. The denial should be without prejudice as the applicant has acquired a building
permit for a single-family residential structure and is in the process of constructing a
residential home.
DECISION:
The request for a conditional use permit and cottage industry permit to allow processing of
recreational cannabis and the request for a conditional use permit to produce recreational
cannabis at a site located at 9790 Coyle Road, Quilcene, is hereby denied without
prejudice
ORDERED this 1st day of April, 2020.
E HEN K. CAUSSEA , JR.
Hearing Examiner
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