HomeMy WebLinkAbout07-15-2020 PC Agenda PacketJefferson County Planning Commission
MEETING AGENDA Virtual Meeting (no in-person attendance allowed per Gov. Inslee’s Proclamation 20-28) Log-in information located at the bottom of this agenda July 15, 2020 P: 360-379-4450 621 Sheridan St. F: 360-379-4451 Port Townsend WA 98368 plancomm@co.jefferson.wa.us
Regular Meeting
5:30pm Welcome (chair) and Overview Presentation
• Call to Order/Roll Call
• Approval of Agenda
• Approval of previous Meeting Minutes, if available
• Planning Commissioner Updates
• Update from County Commissioner Greg Brotherton
• Director’s Update, if available 5:35pm Observer Comment
See Observer Comment Conduct, below. Regular Meeting Business
• Review and discuss Planning Commission By-Laws ..................... Mike Nilssen, Chair
• Overview of 2020 Annual Docket Process – Resolution 25-20 .............. Linda Paralez
• Port Hadlock Sewer ................................................................................ Linda Paralez
• Site Specific Rezone ............................................................................. David Johnson
• Project management overview – SMP periodic update ....................... David Johnson Adjournment
Thank you for coming and participating in your government at work! Observer Comment Conduct: When the Chair recognizes you to speak, please begin by stating your name
and address. Please be aware that the observer comment period is …
1) An optional time period dedicated to listening to the
public, not a question and answer session. The
Planning Commission is not required to provide
response;
2) Offered at the Chair’s discretion when there is time;
3) Not a public hearing – comments made during this time
will not be part of any hearing record;
4) May be structured with a three-minute per person time
limit.
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C
JEFFERSON COUNTY
STATE OF WASHINGTON
IN THE MATTER OF ESTABLISHING I
THE 2020 COMPREHENSIVE PLAN } RESOLUTION NO. 25-20
AMENDMENT DOCKET AND }
ESTABLISHING DEADLINES FOR }
LEGISLATIVE ACTION }
WHEREAS, on February 29, 2020, Governor Jay Inslee declared a State of Emergency in
all Counties in Washington State due to the public health emergency caused by the COVID-19
virus; and
WHEREAS, on March 10, 2020, the Jefferson County Health Officer issued a Public
Health Order to control and prevent the spread of the COVID-19 virus; and
WHEREAS, on March 16, 2020, the World Health Organization declared the outbreak of
COVID-19 to be a pandemic; and
WHEREAS, on March 16, 2020, the Jefferson County Board of Commissioners ("BoCC")
approved a Declaration of Emergency due to the COVID-19 Pandemic; and
WHEREAS, on March 23, 2020, Governor Jay Inslee signed a proclamation (20-25)
declaring that a State of Emergency continues to exist in all counties in Washington State due to
COVID-19; and that his prior proclamations are amended and superseded by proclamation to
impose a Stay Home — Stay Healthy Order throughout Washington State, which prohibits all
people in Washington State from leaving their homes or participating in social, spiritual and
recreational gatherings of any kind regardless of the number of participants, and all non-essential
business in Washington State from conducting business, within the limitations provided in
Proclamation 20-25; and
WHEREAS, on April 4, 2020, Governor Jay Inslee extended through May 4, 2020, his
Stay Home — Stay Healthy Order throughout Washington State; and
WHEREAS, on March 23, 2020, the BoCC approved a Resolution Adopting a Temporary
Policy for a Limited Period of Time to Grant "Emergency Paid Administrative Leave";
Authorize Telecommuting; and Authorize Sick Leave Advancement for employees due to the
COVID-19 Pandemic through April 24, 2020; and
WHEREAS, on April 13, 2020, the BoCC approved a Resolution Adopting a Second
Temporary County Policy Based on Emergency Response to the COVID-19 Pandemic
authorizing telecommuting, temporary expanded use of employer provided sick leave, temporary
sick leave advancement and expanded family and medical leave through May 4, 2020; and
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WHEREAS, on March 23, 2020, the BoCC approved a Resolution Temporarily Limiting
Access to County Buildings and Offices Due to the COVID-19 Pandemic until April 24, 2020;
and
WHEREAS, on April 13, 2020, the BoCC approved a Resolution Extending the Order
Temporarily Limiting Access to County Buildings and Offices due to the COVID-19 Pandemic
through May 4, 2020 or for as long as the Governor's Stay Home — Stay Healthy Order is in
effect; and
WHEREAS, on March 24, 2020, Governor Jay Inslee signed a proclamation (20-28)
which temporarily prohibits in-person public attendance at meetings subject to the Open Public
Meetings Act and directs public agencies to conduct open public meetings through: (1)
telephonic access or electronic/internet means of remote access; and (2) provides the ability for
all persons attending the meeting to hear each other at the same time.
WHEREAS, Jefferson County has postponed non -urgent public meetings or has
transitioned to telephone or electronic/remote access meetings to comply with Governor Inslee's
Stay Home — Stay Healthy Order; and
WHEREAS, the Jefferson County Department of Community Development ("DCD") is
experiencing staffing impacts due to COVID-19, including the temporary reassignment of the
DCD Director for COVID-19 activities; and
WHEREAS, RCW 3 6.70A. 13 0(2)(a) and WAC 365-196-640(6)(a) require Jefferson
County to allow interested persons to suggest amendments to the Jefferson County
Comprehensive Plan or its development regulations during annual amendment cycles; and
WHEREAS, RCW 36.70A. 130(2)(a) requires that local governments consider their annual
amendments, together, no more than one-time per year; and
WHEREAS, the Jefferson County Comprehensive Plan's Plan Foundation and Chapter
18.45 Jefferson County Code ("JCC") incorporates the requirement to allow interested persons to
suggest amendments to the Jefferson County Comprehensive Plan or its development regulations
during the annual amendment cycle; and
WHEREAS, Chapter 18.45 JCC establishes a preliminary and final docketing process for
the annual amendment cycle; and
WHEREAS, JCC 18.45.050 establishes a preliminary docket which requires the following
proposed amendments to be placed on the preliminary docket: (1) formal site-specific
amendments and (2) suggested text or site-specific amendments; and
WHEREAS, JCC 18.45.040 requires that suggested amendments be submitted to DCD no
later than March 1St of each year for consideration in the final docket; and
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WHEREAS, JCC 18.45.050(3) requires that applications for formal site-specific
amendments be automatically placed on the final docket, and DCD received one complete formal
site-specific application; and
WHEREAS, RCW 36.70A.070(3) requires that comprehensive plans contain a capital
facilities element, including a 6 -year financing plan for capital facilities needed within the next
6 -years; and
WHEREAS, Jefferson County is in the process of updating the Port Hadlock Sewer Plan,
including its 6 -year financing plan; and
WHEREAS, revisions to the Port Hadlock Sewer Plan likely will require an amendment to
the Comprehensive Plan's Capital Facilities Element and DCD staff recommends that this docket
item be included in the 2020 final docket; and
WHEREAS, the revisions to the Port Hadlock Sewer Plan are critical to the economic
development and public health of Jefferson County and are critical to the implementation of the
Port Hadlock Urban Growth Area; and
WHEREAS, it is in the best interest of County residents and businesses to place the
revisions to the Port Hadlock Sewer Plan on the 2020 final docket; and
WHEREAS, the DCD Director has prepared a report pursuant to JCC 18.45.060,
recommending that only the one timely reported staff suggested amendment to the
Comprehensive Plan's Capital Facilities Element for the updated Port Hadlock Sewer Plan and
that the one timely formal site-specific application should be placed on the final docket for
consideration during the annual amendment process; and
WHEREAS, adoption of the final docket does not constitute a decision or
recommendation that the substance of any docket item should be adopted by the BoCC; and
WHEREAS, it is in the best interest of the County, considering COVID-19 and its impacts
on residents, businesses and DCD staff to suspend all remaining deadlines regarding the review,
recommendation and final adoption of 2020 docket items for DCD staff, Planning Commission
and BoCC;
NOW, THEREFORE, BE IT RESOLVED, by the Jefferson County Board of County
Commissioners that in response to the COVID-19 pandemic state of emergency, the 2020
Comprehensive Plan Amendment Cycle shall be revised as follows:
1. All deadlines in Chapter 18.45 JCC for the processing and adoption of 2020 docket
items, which occur after the adoption of this resolution, are suspended; and
2. The Planning Commission hearing, report and recommendation required by JCC
18.45.060(3) shall continue to be required before the BoCC takes action to adopt the
2020 final docket, to be further processed pursuant to JCC 18.45.070 and JCC 18.45.080;
and
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3. The Planning Commission shall consider recommending to the BoCC that only the staff
suggested amendment to the Comprehensive Plan's Capital Facilities Element for the
updated Port Hadlock Sewer Plan should be placed on the final docket's suggested
amendments for consideration during the 2020 annual amendment process, along with the
one formal site-specific application that automatically is on the final docket; and
4. Pursuant to JCC 18.45.050(3), the one timely formal site specific amendment shall
automatically be placed on the final docket; and
5. The BoCC shall take final legislative action on 2020 docket items by February 26, 2021,
unless extended by the BoCC consistent with WAC 365-196-640(3)(a).
APPROVED this 27th day of April, 2020
SEAL: l
ATTEST:
Carol Gallaway
Deputy Clerk of the Board
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COUTNY
Greg Brbfherton, Chair
Dean, Member
David Sullivan, Member
Regular Agenda
JEFFERSON COUNTY
BOARD OF COUNTY COMMISSIONERS
AGENDA REQUEST
TO: Board of Commissioners
FROM: Linda Paralez, Acting DCD Director
DATE: April 24, 2020
RE: Modification of the Comprehensive Plan Docket Schedule in Chapter 18.45. JCC Due
to the COVED -19 Pandemic Emergency
STATEMENT OF ISSUE: Chapter 18.45 JCC contains a process for the annual Comprehensive
Plan docket (docket). Due to the COVID-19 pandemic emergency, that schedule cannot be met. The
Board of County Commissioners (BoCC) will consider adopting a resolution suspending deadlines in the
Chapter 18.45 JCC schedule for the docket, with required final Board of County Commissioners'
legislative action on 2020 docket items by February 26, 2021, unless extended by the BoCC consistent
with WAC 365-196-640(3)(a). In addition, because of the COVID-19 pandemic and related budget
issues, the docket should be limited.
ANALYSIS: On February 29, 2020, Governor Jay Inslee declared a State of Emergency due to the
COVID-19 pandemic. On March 24, 2020, Governor Inslee signed a proclamation (20-28) declaring that
a State of Emergency continues to exist in all Counties in Washington State due to COVID-19; and that
portions of RCW 42.30 and RCW 42.56 that require in-person meetings or contact are waived and
suspended until midnight on April 23, 2020. This has since been extended to May 4, 2020 and likely will
be extended again. This COVID-19 pandemic and the Governor's orders have severely impacted the
Jefferson County Department of Community Development (DCD) staffing schedules, including the need
to reassign the DCD director to be Jefferson County's COVID-19 Finance Section Chief, consistent with
the emergency powers granted by RCW 38.52.070(2). The pandemic and the Governor's orders also
creates major barriers to the public participation process required for considering Comprehensive Plan
amendments through the annual docket process. Accordingly, the schedule for the docket cannot be met.
A draft resolution is attached to: (1) suspend pending deadlines while retaining normal docket procedures;
2) suggest limiting the items on the docket; and, (3) postpone the deadline for County Commissioner
final legislative action on the docket items until February 26, 2021 after a planning commission hearing.
FISCAL IMPACT: No significant impact.
RECOMMENDATION: Consider and adopt the attached resolution.
REVIEWED BY:
Philip Morley, mmis ra or Date
STATE OF WASHINGTON
JEFFERSON COUNTY
JEFFERSON COUNTY BOARD OF HEALTH
A JOINT RESOLUTION OF THE BOARD OF }
COUNTY COMMISSIONERS AND THE } RESOLUTION NO. 17-19
JEFFERSON COUNTY BOARD OF HEALTH }
ESTABLISHING A REGULATORY REFORM }
PROGRAM FOR JEFFERSON COUNTY }
The Jefferson County Board of Commissioners and the Jefferson County Board of Health
are adopting a Joint Resolution to establish a Regulatory Reform Program for the County,
including directing the Department of Community Development and the Environmental Public
Health Division to propose a work program and schedule by July 1, 2019 for carrying out
regulatory reform within each of their programs.
In passing this Joint Resolution, we recognize the following prior work, current
conditions and future opportunities that set the stage for regulatory reform:
1. Jefferson County adopted an updated Comprehensive Plan on December 10, 2018,
consistent with Washington's Growth Management Act, that outlines a vision, and goals
and policies, that help define, direct and guide future growth and development throughout
the county through the year 2038, emphasizing economic development, affordable housing
and residential development, while protecting the environmental quality of unincorporated
areas.
2. The Jefferson County Comprehensive Plan recognizes the importance of regulatory reform
for economic development, affordable housing, residential development, and
environmental protection and adaptation to climate change through its goals, policies,
action plans, and supporting narrative, such as Framework Goal III Enhancement of the
Rural Economy, Framework Goal IV Housing Variety and Affordability, and goals LU -G-14
and ED -G-8 advocating for responsive, fair, and efficient permit processing.
3. Over time, Jefferson County's development and environmental health regulations and
procedures have evolved incrementally. A program of regulatory reform can reduce the
inadvertent complexity, inconsistencies and unpredictable permitting paths that exist
today, while continuing to protect public health and the environment, assist the County in
adapting to climate change, and make it easier, less time consuming and cheaper for
applicants to comply and for County staff to administer.
Page 1 of 5
4. Streamlining regulations and permit review procedures supports job creation and wage
growth, economic development, affordable housing, environmental protection and the
public's health related to Environmental Public Health, all of which are contributing factors to
lifting citizens out of poverty, supporting public services, and promoting social equity in
Jefferson County.
5. Numerous structures have been built and operated in Jefferson County without permits;
and many customers who seek permit information from the Department of Community
Development and from Environmental Public Health do not subsequently submit permit
applications. The cost, lengthy timeframe and complexity of County regulations and permit
processes appear to be significant deterrents to complying voluntarily and a contributing
factor to an abundance of code violations which endanger public health, public safety and
the environment.
6. Starting in 2019, the Jefferson County Board of Commissioners have enhanced funding for
an on-going staffed Code Compliance program to help citizens comply with the County
health, safety and environmental protections, help ensure that Jefferson County regulations
are fairly and consistently applied, and reduce the incidence of non-compliant development
and activities that can negatively impact surrounding properties. Regulatory Reform of
County regulations and procedures will enhance and support the Code Compliance
program.
7. Affordable housing, economic development, public health and environmental protection
are of significant concern to the County, its residents, and its businesses.
8. It is in the best interest of the County's residents, its businesses, and governmental
efficiency to commit to regulatory reform to clarify and streamline County regulations and
create efficient development practices and permitting paths, in order to facilitate economic
development, jobs and an increase in the supply of affordable housing, while protecting the
environment and public health.
9. Exercising the County's police powers and delegated authority through regulatory reform
will benefit Jefferson County, its residents, and its businesses, by better balancing economic
development, affordable housing, residential development, environmental protection and
the ability to adapt to climate change.
10. Jefferson County, particularly, Community Development and Environmental Public Health
are transitioning to a modern permitting system, EnerGov, which will provide increased
transparency, improved accountability, more efficient review procedures, and more
consistent permitting paths.
11. Jefferson County is updating two major development regulations: the Critical Areas
Ordinance in 2019, and the Shoreline Master Program in 2020. These are important
opportunities to undertake regulatory reform with environmental protection.
Page 2 of 5
12. Together, the recent update to the County's Comprehensive Plan and development
regulations, new permitting system, upcoming update of the Critical Areas Ordinance and
Shoreline Master Program, and ongoing updates to several Washington State health and
safety codes provide an opportunity to holistically analyze and reform County regulations
and procedures providing for efficient development practices and permitting paths
increasing economic development, affordable housing, residential development,
environmental protection and public health.
THEREFORE, IT IS RESOLVED, that the Jefferson County Board of County Commissioners
and the Jefferson County Board of Health have determined that it is in the public interest to
undertake a regulatory reform program of the County's current regulatory structure and
associated permitting processes to promote the public welfare and improve regulatory
compliance with public health protection, environmental protection and public safety, while
reducing the cost and barriers to economic development and affordable housing, consistent
with state law.
IT IS FURTHER RESOLVED, that the County Commissioners and Board of Health direct
Community Development and Environmental Public Health to develop a regulatory reform
work program and schedule, consistent with appropriations available within the County's
budget, and forward them to the Board of County Commissioners and Board of Health by July 1,
2019 for review and approval.
IT IS FURTHER RESOLVED, that the regulatory reform program be designed to
accomplish the following goals:
Protect Jefferson County's environment and public health;
Streamline and simplify the structure of County Code to make it
understandable and efficient to comply with and to administer;
Assess required professional studies to identify overly burdensome and
costly barriers in the code and permit review process;
Allow County departments greater flexibility to allow minor exceptions that
retain environmental protections and public safety;
Streamline permit review procedures; and
Enhance transparency and accountability for timely reviews.
IT IS FURTHER RESOLVED, that Community Development and Public Environmental
Health shall develop an early and continuous public participation program for the regulatory
reform program.
IT IS FURTHER RESOLVED, that for the Department of Community Development, the
regulatory reform work program shall sequence the program with the new permitting system
EnerGov, updates to the Critical Areas Ordinance, updates to the Shoreline Master Program,
followed by an update to the remainder of the Unified Development Code, and associated
review procedures.
Page 3 of 5
IT IS FURTHER RESOLVED, that for the Environmental Public Health Division, the
regulatory reform work program shall sequence the program with the new permitting system
EnerGov, and Washington State's updates to its On -Site Sewage Systems Code, Food Safety
Code, and Solid Waste Code; identify and evaluate sections of the County's environmental
health code that are more stringent than State law and evaluate the efficacy of those
provisions.
IT IS FURTHER RESOLVED, that the regulatory reform work program shall analyze
holistically development and non -development regulations and procedures reducing the
implementation burden of county staff and customers, rebalancing regulatory schemes
consistent with the recent update of the County's Comprehensive Plan focusing on a balance of
economic development, residential development, affordable housing, environmental
protection, adaptation to climate change, public health, and provide regulatory flexibility in
administering the updated regulations.
IT IS FURTHER RESOLVED, that the County Commissioners and Board of Health expect
the departments to produce and accomplish measurable results and outcomes as described in
the work program. Periodic briefings and other accountability reviews are expected on
regulatory reform progress for the duration of the program.
APPROVED thisX2 'day of March, 2019.
Attest:
Carolyn allaway,
Deputy Clerk of the Board
JEFFERSON COUNTY
BOARD OF COUNTY COMMISSIONERS
Oce
Kate Dean, Ch '
r,?
f
David ullivan, Member
Greg Brotherton, Member
Page 4 of 5
JEFFERSON COUNTY
BOARD OF HEALTH
Kees Kolff, Chair
Sheila Wester an, Vice Chair
David Sullivan, Member
L r ---
Kate Dean, M4ynber
rton, Member
Parpela Adams, M*ber
Denis Stearns, Mdfnber
Page 5 of 5
JEFFERSON COUNTY
BOARD OF COUNTY COMMISSIONERS
AGENDA REQUEST
TO: Board of County Commissioners
FROM: Philip Morley, County Administrator
Patty Charnas, Director, Department of Com nity De el ment
Stuart Whitford, Director, Environmental Public Health Division
DATE: March 25, 2019
RE: Joint Resolution with the Board of Health Establishing a Regulatory Reform Program
for Jefferson County
STATEMENT OF ISSUE: The Board of County Commissioners (BoCC) will consider adopting will a
Joint Resolution with the Board of Health to establish a Regulatory Reform Program for
Jefferson County, centered in the Department of Community Development and Environmental
Public Health Division. The Joint Resolution is attached to this Agenda Request.
The Joint Resolution memorializes in writing policy direction that the County Commissioners
have previously expressed that the County undertake Regulatory Reform.
The Board of Health is responsible for setting policy for Environmental Public Health, and voted
to approve the Joint Resolution at its meeting on March 21, 2019.
ANALYSIS: The County Commissioners previously held a briefing on a draft of the Joint
Resolution for Regulatory Reform on February 19, 2019. The Board of Health also held a
briefing on the Joint Resolution at its meeting on February 21, 2019.
The Board of County Commissioners recently adopted an updated Comprehensive Plan in
December of 2018. In shaping and adopting the Comprehensive Plan, the Board recognized the
importance of regulatory reform for economic development, affordable housing, residential
development, and environmental protection and adaptation to climate change.
Jefferson County's development and environmental health regulations and procedures have
evolved incrementally over the years. A program of regulatory reform can reduce the
inadvertent complexity, inconsistencies and unpredictable permitting paths that exist today,
while continuing to protect public health and the environment, assist the County in adapting to
climate change, and make it easier, less time consuming and cheaper for applicants to comply
and for County staff to administer.
As the Commissioners have previously noted, streamlining regulations and permit review
procedures will support economic development, job creation and wage growth, affordable
housing, environmental protection and public health, all of which can help lift citizens out of
poverty, support public services, and promote social equity in Jefferson County.
Regulatory reform can make it more attractive to comply voluntarily with health, safety and
environmental protections, support the County's new Code Compliance effort, and reduce the
incidence of non-compliant development and activities that can negatively impact surrounding
properties.
The Joint Resolution of the Jefferson County Board of County Commissioners and the Jefferson
County Board of Health would:
Initiate a Regulatory Reform Program of the County's current regulatory structure and
associated permitting processes to promote the public welfare and improve regulatory
compliance with public health protection, environmental protection and public safety,
while reducing the cost and barriers to economic development, and affordable housing,
consistent with state law;
Define the goals of the Regulatory Reform Program as:
o Protect Jefferson County's environment;
o Streamline and simplify the structure of County Code to make it understandable
and efficient to comply with and to administer;
o Reduce the Code and permit review reliance on burdensome and costly
professional studies;
o Allow County departments greater flexibility to allow minor exceptions that
retain environmental protections and public safety;
o Streamline permit review procedures; and
o Enhance transparency and accountability for timely reviews;
Direct Community Development and Environmental Public Health to develop a
regulatory reform work program and schedule to be presented to the County
Commissioners and the Board of Health by July 1, 2019. The work program and
schedule should be designed to implement and sequence regulatory reform with:
o a new permitting system EnerGov, and scheduled updates to the County's
Critical Areas Ordinance and Shoreline Master Program, followed by an update
to the remainder of the Unified Development Code;
o reflecting Washington State's pending updates to the state's On -Site Sewage
Systems Code, Food Safety Code, and Solid Waste Code; identifying and
evaluating where the County's environmental health code may be more
stringent than State law and evaluate the efficacy of those provisions; and
10)
Direct Community Development and Environmental Public Health to develop an early
and continuous public participation program for the regulatory reform program
The Joint Resolution has already be adopted by the Board of Health on March 21, 2019. The
Joint Resolution now before the BoCC for adoption includes edits requested by the
Commissioners in February, and is in a more readable format, as suggested by the Board of
Health at their briefing in February.
FISCAL IMPACT: Implementing a Regulatory Reform Program will require dedication of existing
staff time, and depending on work -load capacity, may also require future budget
appropriations.
RECOMMENDATION: Adopt the Joint Resolution, as already approved by the Board of Health
3
3
Date
Port
Hadlock
Wastewater
System
Planning Commission Presentation for Comprehensive Plan Docket
Agenda
PURPOSE AND OVERVIEW
OF PROJECT
COMPREHENSIVE PLAN
UPDATE CHANGES NEEDED
QUESTIONS AND
SCHEDULE
Purpose and
Overview
Why does Port Hadlock need a sewer system?
Housing
Commercial
Septic Systems
What areas will get sewer?
What type of sewer is it?
https://www.co.jefferson.wa.us/1399/Frequently-Asked-
Questions-FAQs
Housing
Housing: in best-case scenario, current zoning supports 3 houses per acre if the property had been subdivided into minimum sized lots of 12,500 square feet prior to GMA.
Alternatively, with sanitary sewer, Port Hadlock has residential zoning making multifamily and apartment units possible in the MDR and HDR zones.
Low Density Residential (LDR 4-6 dwelling units per acre),
Moderate Density Residential (MDR 7 to 12 units per acre) or
High Density Residential (HDR 13 to 18 units per acre).
Commercial
Urban Commercial zoning with
sewer:
Building size is dictated by site
conditions with no specified maximum
building size, and building height can
be up to 70 feet to allow for and
accommodate increased densities.
Some Urban Light Industrial zoning in
part of the UGA once a sewer is
available.
Septic
Systems
Failing older septic systems, eventual
replacement of septic systems for all property
owners
Increased costs and requirements for
alternative septic systems
Prompting significant interest in UGA for a
sanitary sewer facility
Core
Area
Map
Type of Sewer
Current Status
Jefferson County has since been
engaging with a newly formed
Sewer Working Group (SWG) made
up of stakeholders in the Core Area
to find ways to advance the project.
https://www.co.jefferson.wa.us/1405
/Sewer-Working-Group-Meetings
Comprehensive
Plan
Amendment
A Comprehensive Plan amendment is required
for the proposed revisions to Jefferson County’s
2008 Port Hadlock Urban Growth Area Sewer
Facility Plan
Public participation and State Environmental
Policy Act (“SEPA”) compliance also are
required.
Six year financing plan for capital facilities
Next Steps
Determine PW and DCD lead
Define the scope and timeline
Gather the relevant data and conduct workplan
Complete Planning Commission Review and
Hearings
Recommendations to BoCC for Comprehensive
Plan Amendment
Questions and
Comments
JEFFERSON COUNTY
DEPARTMENT OF COMMUNITY DEVELOPMENT
621 Sheridan Street | Port Townsend, WA 98368
360-379-4450 | email: dcd@co.jefferson.wa.us
http://www.co.jefferson.wa.us/260/Community-Development
Page 1 of 9
DEPARTMENT OF COMMUNITY DEVELOPMENT 2020-2021 WORK PROGRAM
Related to Long-range Planning Projects
2020 and 2021 Comprehensive Plan Amendment Preliminary Docket
and Other High-priority Initiatives
TO: Jefferson County Board of Commissioners, County Administrator, Planning Commission, and
Interested Parties
FROM: Patty Charnas, Director, Department of Community Development
DATE: March, 2020
Under Chapter 18.45 of the Jefferson County Code (JCC), the Jefferson County Department of Community
Development (DCD) annually accepts applications for formal site-specific Comprehensive Plan amendments (re-
zones) and suggested text amendments to the Jefferson County Comprehensive Plan and Unified Development
Code (UDC) for inclusion in the annual Comprehensive Plan amendment preliminary docket. DCD accepts
applications for each cycle’s docket until March 1st.
DCD abides by the County’s new, biennial budget cycle and, as such, plans and manages projects and other work
programs in the two-year framework. As of the writing of this memorandum (memo), there have been no formal
submittals of formal site-specific amendments or proposed text amendments to the Jefferson County
Comprehensive Plan or to the Unified Development Code (UDC). The purpose of this memo is to review a list of
various activities that provide measurable actions in response to current community situations and that
implement the goals and policies of the Jefferson County Comprehensive Plan.
The Jefferson County Comprehensive Plan recognizes the importance of providing for economic development,
affordable housing, residential development, sustainable agriculture and regulatory reform through its goals,
policies and supporting narrative including:
• Framework Goal III Enhancement of the Rural Economy
• Framework Goal IV Housing Variety and Affordability
• Goals LU-G-14 and ED-G-8 advocating for responsive, fair and efficient permit processing.
Chapter 18.45 of the JCC requires that the preliminary docket be reviewed by DCD, the Planning Commission,
and the Jefferson County Board of County Commissioners (BoCC) prior to adoption of the final docket. During
this process DCD reviews and recommends whether a suggested text amendment should be included in the final
docket. Under JCC 18.45.060, DCD’s review and recommendation includes the following factors:
a) Need;
b) Urgency;
c) Likelihood of Success;
d) DCD staff capacity to substantively review and manage the suggested text amendments; and
e) Anticipated DCD cost and budget for processing the suggested amendments.
2020 Preliminary Docket
DRAFT
March 11, 2020 Page 2 of 9
DCD has extremely limited staff capacity for any additional Comprehensive Plan or suggested UDC text
amendments beyond the on-going and planned 2020-2021 updates including: Critical Areas Ordinance,
Shoreline Master Program, Regulatory Reform updates (Onsite Septic/Water/Building and Land Use), and Code
Enforcement. Placement of any suggested text amendments on the final docket will likely result in significant
requests for outside consultant services or potential substantial increases in land use and building permitting
processing times. The cost estimates appearing below each project, therefore, are based on using consultant
services. In addition, where indicated, those high visibility and/or controversial projects include additional
general fund support to address higher departmental and prosecuting attorney levels of involvement.
If any suggested text amendments are docketed on the final docket (see Figure 1), DCD requests supplemental
budget authority to support the docket work. As DCD relies on a combination of on-going general fund, project
specific general fund, and grant dollars to support all long-range planning work, DCD’s existing budget cannot
support any suggested text amendments without supplemental budget authority.
Figure 1 – 2020 Process and Proposed Timeline for Preliminary Docket to Final Docket
Date Activity
March 18, 2020 Staff distributes the Department of Community Development’s review and
recommendation on the 2020 Comprehensive Plan amendment preliminary docket.
April 1, 2020 Staff cooperatively reviews and discusses preliminary docket with the Planning
Commission.
April 17, 2019 Planning Commission holds public hearing on suggested text amendments on the
preliminary docket. (can schedule Special Meeting for public hearing April 22nd )
May 4, 2020 Planning Commission prepares a report and recommendation to the BoCC on the
preliminary docket. (can schedule Special Meeting for deliberations April 29th)
May 11, 2020* BoCC considers the preliminary docket, including the Staff’s and Planning Commission’s
report and recommendations by the second regular BoCC meeting in May.
July 6, 2020* Possible BoCC hearing on the preliminary docket if BoCC decides to modify the Planning
Commission’s recommended preliminary docket. Hearing to be held no later than the
first BoCC meeting in July.
July 2020 BoCC adopts final docket consisting of suggested text amendments which the BoCC
elects to consider and all formal site-specific amendments.
*Scheduled as required by Chapter 18.45 JCC
2020 Formal Site-Specific Amendment (Automatically Included in the Final Docket)
1. MLA20-00039. Bruce Seton, Jr. Parcel #001281002. Requests a rezone of 22.15-acre parcel from Rural
Residential 1 dwelling per 10 acres (RR1:10) to Rural Residential 1 dwelling per 5 acres (RR1:5) to enable
a 4-lot short plat.
2. MLA20-00038. Shauna Coleman (business owner), Tom McClanahan (property owner). Request to
rezone 9.13-acre parcel zoned rural residential to rural commercial to support local business
development. Parcel has been used commercially since 1979.
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Potential Comprehensive Plan and Site-Specific Amendments (Staff Proposals)
3. Port Hadlock Sewer Redesign Comprehensive Plan Amendment. A value engineering report completed
in 2019 studied alternatives to the existing Port Hadlock UGA Sewer Facility Plan and recommended
revisions, including a reduced initial service area. Amending the Comprehensive Plan with the relevant
sewer redesign aspects will avoid inconsistencies in the plans published intent and in its
implementation.
• Need:
o This is needed. Jefferson County’s Comprehensive Plan must be updated so that the
sewer redesign is consistent with the Plan’s capital facilities element.
• Urgency:
o This project is urgent. The sewer redesign is connected with substantial implementation
funds for this year.
• Likelihood of Success:
o High likelihood of success. This project allows for the sewer redesign to comply with the
Comprehensive Plan and, once municipal sewerage is constructed, the Hadlock Urban
Growth Area can have the full suite of urban development, housing types, densities and
levels of service.
• DCD Staff Capacity:
o DCD staff lacks the capacity to efficiently process this suggested amendment.
• Cost:
o Estimated level of effort: 25 hours
o Estimated cost: $3,800.00 (25 hours @ $140 per hour consultant services
and $300 in prorated administrative costs, such as printing and legal ads)
4. Glen Cove Industrial Area. Glen Cove Industrial Area is one of the very few areas of light
industrial/commercially zoned lands in unincorporated Jefferson County. State law allows for
“associated commercial and retail uses” in industrial land designations. Discussions of sharing levels of
urban services with the incorporated City of Port Townsend have languished without any positive
results. Glen Cove lacks key infrastructure, namely municipal wastewater treatment which is
endangering the viability of existing commercial and industrial businesses and severely limiting any
growth or redevelopment of this key rural employment center. A study would address Glen Cove’s
existing conditions, growth and sustainability limitations and provide alternatives, including state
legislative options, that respond to local employment needs.
• Need:
o This is needed. Jefferson County continues to deal with unemployment rates higher than
state averages. Glen Cove’s job base provides sustainable family wage jobs. It is close to
public transit and adjacent to services.
• Urgency:
o This project is important and from an employment base retention view is also urgent.
The potential for an economic recession could result in permanent losses of industrial
and commercial jobs and the tax base that these businesses provide.
• Likelihood of Success:
o Low likelihood of success. This project allows for an objective review and development
of realistic alternatives. The political tension for the area to be annexed to the City of
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Port Townsend will be high and there may be substantial pressure to designate it as an
associated urban growth area first.
• DCD Staff Capacity:
o DCD staff lacks the capacity to efficiently process this suggested amendment.
• Cost:
o Estimated level of effort: 120 hours
o Estimated cost: $18,300.00 (120 hours @ $140 per hour and $1,500 in
prorated administrative costs, departmental and prosecutor’s involvement)
Suggested Rural Communities Planning
5. Port Hadlock Urban Core Revitalization Subarea Plan
With the potential for the Port Hadlock Urban Growth Area to be allowed to grow and develop as an
UGA, this planning effort would focus on the initial service area for the redesigned sewer system, which
includes the existing retail businesses and professional services along Ness Corner Road. The advent of
municipal wastewater treatment will allow these businesses to grow and/or redevelop. There is a need
to ensure that the existing zones and uses envisioned for the Port Hadlock UGA in planning documents
prepared over a decade ago still apply and are still relevant. There is a likelihood that those zones and
uses can be revised to reflect current conditions and aspirations for an attractive urban core, complete
with design standards and considerations of developing public amenities such as multi-modal trails and
sidewalks, outdoor recreation areas and areas for future residential and commercial development with
an emphasis on environmental sustainability.
• Need:
o This is project would be needed if the redesigned sewer system is able to be constructed
and if the area citizens support a subarea plan investment for the core business district.
• Urgency:
o This project is not urgent but may provide important motivation to creating and
supporting a L.I.D.
• Likelihood of Success:
o Moderate likelihood of success. This project allows for a pathway to revitalize the Port
Hadlock area if it is able to become a fully operating urban growth area and this project
may stimulate local investment to create and maintain an exciting new urban area for
Jefferson County. There will be political pitfalls should large portions of affected areas
become concerned about potential displacements or properties becoming unaffordable.
• DCD Staff Capacity:
o DCD staff lacks the capacity to efficiently process this suggested plan.
• Cost:
o Estimated level of effort: 90 hours
o Estimated cost: $13,800.00 (90 hours @ $140 per hour consultant services
and $1,500 in prorated administrative costs, departmental and prosecutor’s
involvement)
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6. Highway Commuter Tourist Zone at Junction of State Highways 19 and 104
The Washington State Department of Transportation (WSDOT) is studying a traffic-calming
roundabout at the junction of State Highway 104 (the principle east-west route across the Olympic
Peninsula) and State Highway 19 (the principle north-south route to Port Townsend through
Jefferson County). While this study is primarily to address acute vehicular safety issues at this
intersection, the roundabout concept can become part of a land use planning study to analyze
potential future commercial opportunities that would be immediately adjacent to the proposed
roundabout. During the Jefferson County Comprehensive Plan periodic update, it was recognized
that Highway 104 supports 19,000 to 25,000 vehicular trips per day and that no supportive highway
tourist-commuter services exist such as a commercial/retail enterprise alongside a major
roundabout at the Highway 104-19 intersection. This project would address the feasibility of
rezoning and developing selected areas under a new, highway-tourist-commuter zone and prepare
an economic analysis of potential outcomes.
• Need:
o This is project is needed to address commercial and retail services that are noticeably
lacking along the Highway 104 and 19 intersection area.
• Urgency:
o This project is somewhat urgent; the WSDOT roundabout study could provide timely
planning and design information for this land use planning project.
• Likelihood of Success:
o Moderate likelihood of success. This project allows the County to potentially diversify
job and tax base needs in a modest, environmentally sustainable way. Potential
challenges under Growth Management exist yet establishing rural commercial areas is
not without precedent elsewhere in the County.
• DCD Staff Capacity:
o DCD staff lacks the capacity to efficiently process this suggested plan.
• Cost:
o Estimated level of effort: 72 hours
o Estimated cost: $11,080.00 (72 hours @ $140 per hour consultant services
and $1,000 in prorated administrative costs, departmental and prosecutor’s
involvement)
7. Jefferson Rural Communities Subarea Planning (not prioritized for 2020 docket)
a. South Discovery Bay
A study and land use planning effort to look into enhancing existing and creating new commercial
and retail establishments in this small existing hamlet that would potentially be created as a
highway tourist commuter zone and consider short term lodging development.
b. Quilcene LAMIRD Business and Residential Development Plan
An effort to extend existing or create new limited areas of more intensive rural development
(LAMIRD) that would address much needed business and commerce uses and development.
Suggested Text Amendments
A. Customer Service Delivery Enhancements
In consultation with the Department of Public Health and the County Administrator, cooperatively
review and revise customer service issues and opportunities for improvements in permit processing and
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customer experience for permit applicants jointly applying for septic/water/building and land use
permits. Code development may not necessarily need to go on the annual docket. Additional
cooperative service delivery enhancements are available by partnering water quality monitoring and
natural resources/salmon recovery projects with Shoreline Master Program updates, Critical Areas
Agricultural Code implementation and general joint issues of land use, drinking water supply and water
quality. Directly engage permit processing staff, permit stakeholders and involve the Jefferson County
Health Officer and Board of Health as appropriate for code revisions and policy approvals. Jointly
implement critical areas agricultural code in cooperation with environmental public health and
conservation district. Cooperatively set processing improvement goals and output benchmarks along
with code revision and integration targets. Create continuous process improvement and adaptive
management frameworks.
• Need:
o This is needed. Jefferson County elected and departmental officials continue to hear
from residential, commercial and agricultural customers and citizens about permit
processing issues, conflicts in code applications and permit timeliness and
reasonableness.
• Urgency:
o This project is urgent on an on-going basis. While the permit processing partnership
between DCD and Environmental Public Health is positive and constructive, a more
concerted effort is needed to address customer service delivery and permit issuance
issues that ultimately affect single family residential housing and commercial
development.
• Likelihood of Success:
o High likelihood of success. A dedicated level of effort with a cooperatively developed
and approved work plan that has benchmarks for success will increase the likelihood of
success.
• DCD Staff Capacity:
o DCD possesses the staff capacity to efficiently process this suggested project provided
certain joint workload assignments and work program planning are done so that
sufficient time and attention is allowed for this important project.
• Cost:
o Estimated level of effort: 122 hours
o Estimated cost: $14,012.00 (122 hours @ $96 per staff-hourly rate; $2,300
modest consultant services and prorated administrative costs and prosecutor’s
involvement)
B. Brinnon Subarea-Wastewater Treatment Development Regulations
The Dosewallips State Park sewer system has been shown to possess sufficient capacity to connect much
needed, high priority locations in Brinnon to the sewer system. This will address significant water quality
concerns arising from failing onsite septic systems. While some Washington State jurisdictions have
been able to extend limited sewer service from a designated urban area to immediately adjacent rural
areas, the extension of sewer service to selected locations and properties requires specific code
development to address the standards by which these additional connections can be made outside of
the state park service area.
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• Need:
o This is needed. Jefferson County continues to deal with substantial degradations in
shoreline water quality and closures of shellfish beds to recreational and commercial
harvest due to contamination of failing septic systems.
• Urgency:
o This project is urgent. The State Park desires to work cooperatively with the County to
provide for these sewer service extensions. Septic system failures are a chronic problem
along the shorelines of Brinnon.
• Likelihood of success:
o High likelihood of success. This project ensures long term consistent application of
standards for sewer connections in Brinnon. There will be, however, substantial
pressure to extend connections to private individual residential and commercial
properties which may create compliance issues under the Growth Management.
• DCD Staff capacity:
o DCD lacks the capacity at present to efficiently process this suggested amendment. Staff
capacity could be created with funding to allow for workload shifts.
• Cost:
o Estimated level of effort: 35 hours
o Estimated cost: $6,700.00 (35 hours @ $140 per hour consultant services
and $1,800 in prorated administrative costs, departmental and prosecutor’s
involvement)
C. Countywide Update to Geologically Hazardous Areas Mapping. DCD and Jefferson County Planning
Commission suggests a specific follow up to the Critical Areas Ordinance that improves the geographic,
mapped information relating to geologically hazardous areas. New development standards related to
geologically hazardous areas create a critical need for modern, up-to-date data and mapping regarding
landslide, erosion, seismic and other hazards. Recent, high-resolution land data exists but needs staff
time and resources are highly needed to install, reconcile metadata sets and to validate accuracy. This is
a responsive project to regulatory reform directives.
• Need:
o This is a very high need. Permitting customers are preparing expensive geotechnical
reports when largely they are not necessary because on-site data is lacking in mapped
formats.
• Urgency:
o This suggestion is of high urgency. With the advent of implementing an updated Critical
Areas Ordinance, this substantively addresses an urgent need in current planning and
permitting.
• Likelihood of Success:
o High likelihood of success. If docketed and implemented this suggestion likely will result
in immediate benefits to permit processing times, customer expense and staff
limitations regarding geotechnical issues.
• DCD Staff Capacity:
o DCD staff possess partial staff capacity to efficiently process this project but likely would
rely upon the County geographic information system experts.
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• Cost:
o Estimated level of effort: 50 hours
o Estimated cost: $5100.00 (50 hours @ $96 per hour and $300 in prorated
administrative costs, such as printing and legal ads)
D. JCC 18.20.295 Recreational Marijuana. Jefferson County Planning Commission may suggest a review and
amendment of JCC 18.20.295 Recreational Marijuana addressing community concerns regarding land
use issues experienced with recreational marijuana production in rural residential zones.
• Need:
o Review of these code sections is needed to address community concern over
implementation of marijuana grow, production, and processing in rural residential
zones.
• Urgency:
o This a low-to-modestly urgent suggestion. This topic was identified during the periodic
review and update of the Comprehensive Plan and Unified Development Code and has
been the subject of fairly consistent citizen concern.
• Likelihood of Success:
o Moderate likelihood of success. This suggested amendment provides specific code
updates; however, the proposed code updates may be limiting in nature. Multiple policy
options exist to address community concerns not suggested by this amendment. The
proposal requires substantial DCD staff time and resources.
• DCD Staff Capacity:
o DCD staff lacks the capacity to efficiently process this suggested amendment.
• Cost:
o Estimated level of effort: 101 hours
o Estimated cost: $9,996.00 (101 hours @ $96 per hour and $300 in prorated
administrative costs, such as printing and legal ads)
E. New regulations for “Eco-ADUs.” Jefferson County Planning Commission may resubmit 2019 suggested
development of new regulations using “Eco-ADU” as a method for permitting multiple Accessory
Dwelling Units (ADUs) per parcel. The suggestion would allow the existing square footage of ADUs to be
allotted over multiple ADUs per parcel when certain “eco” performance standards are met.
• Need:
o Innovative affordable housing options are needed to address housing affordability and
homelessness within Jefferson County.
• Urgency:
o This an urgent suggestion. However, substantial compliance issues are noted.
• Likelihood of Success:
o Low to Moderate Likelihood of Success. This proposal touches on existing broad
Comprehensive Plan goals. However, substantial compliance issues with Washington’s
Growth Management Act are present. The suggestion, as drafted, has high
implementation and monitoring costs, including a review board and appeal processes
outside of existing code procedures. The suggestion requires substantial staff time and
resources.
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• DCD Staff Capacity:
o DCD staff lacks the capacity to efficiently process this suggested amendment.
• Cost:
o Estimated level of effort: 184 hours
o Estimated cost: $18,264.00 (184 hours @ $96 per hour and $600 in
prorated administrative costs, such as printing and legal
ads)
F. New regulations for “green burials.” Jefferson Land Trust has submitted a request for a text amendment
to develop and adopt standards for “green burials.” Additional information regarding feasibility,
urgency, and likelihood of success is attached to this memo.
Department of Community Development Work Program and Docket Recommendations
DCD recommends the following prioritization for the 2020-2021 work program.
• MLA20-00038 and 00039 Site Specific Rezones
• Onsite Septic/Water code development (with linkage to Title 18) – existing DCD and EPH staff
• CAO/SMP - existing staff time and resources with limited consultant services
• Geohazards Mapping – outside consulting services
• Transitory Housing Ordinance – existing staff with limited outside consultant services
• Pt Hadlock Sewer Redesign Comprehensive Plan Amendment – existing staff assisted by consultant
services
• Brinnon Wastewater Treatment Development Regulations – existing staff and consultant services
DCD further recommends for years beyond current biennium (2022-24)
• Onsite Septic/Water/Building and Land Use cooperative programs – existing DCD and EPH staff
• Development regulations for “green burials”
• Pt Hadlock Business Core Subarea Plan and Design Guidelines – consultant services
• Glen Cove Industrial LAMIRD update – consultant services
• Quilcene Business and Residential Centers Plan – consultant services
• South Discovery Bay Economic Revitalization Plan – consultant services
DCD wishes to defer for further analysis
• Eco-ADU Affordable Housing Concept
• Land use code development on marijuana growing and processing
SMP Presentation to Planning Commission – July 15, 2020
• February 21, 2020 – six-year anniversary of current SMP “roll-out.” Comprehensive update since
our SMP hadn’t been updated since the initial version in 1989.
• We are required to update the SMP every seven/eight years. This update will be a “Periodic
Review Update” – since there wouldn’t be near the heavy lifting we did last time, but definitely
some important changes.
• Deadline for final approval of review is June 30, 2021.
• Similar to the Comp Plan, but that’s GMA and the Shoreline Program is what? Yes, SMA –
Shoreline Management Act 1971.
• Michelle McConnell was the County Planner and Project Manager for comprehensive update,
and fortunately for us, she is now our Regional Shoreline Planner with Ecology and will be
working very closely with me through a “Optional Joint Review” process with Ecology, who, as
you may know, has final SMP approval authority.
• We have been approved for a $84k Grant from Ecology. The grant is made up of six Tasks, one of
which is not necessary unless we were making major changes, which we are not. Task 1 is
Project Oversight: Coordination, Management and Administration. Task 2: Secure Consultant
Services, if needed. Task 3: Public Participation. Task 4: Review Master Shoreline Program and
Draft Revisions. Task 5: Final Draft SMP. Task 6: optional/additional only if need – major changes
– N/A.
• Ecology has created a joint or consolidated review process. Instead of us publishing notice,
taking comments and holding a public hearing, and then Ecology doing the same thing again for
their review, we simply consolidate those steps and do them together. That public review
process will take place in Task 5 with PC public hearing and recommendation. WAC 173-26-104
• One of the tools Ecology gives us is the Periodic Review Checklist. It’s a list of all the changes
made to the SMA (RCW) or WAC that need to be addressed in the SMP.
• Over the past six years of using the current code we have complied a “docket” of about sixty
items or “errors, or things that need to get fixed.” Most are very minor, and simply need to be
corrected. Some of these have required a code interpretation to “fix” until we could amend the
code. The time to amend is now.
• One of the things we are always trying to do is simplify the language so it is more “user-friendly”
to the citizens, and not just a code manual for planners.
• Most used section of the code was the conditional use permit process to expand existing legal
non-conforming SFRs in the new 150 foot shoreline buffer. We (Greg, Patty and Me) met with
Ecology’s SMP people in February and discovered that Jefferson County has issued more
shoreline CUPs than any other County. That said there is something wrong with our code. Too
much expense and time to process simple expansions. We can do it administratively without
CUP as long as “No Net Loss.” Also Mooring Buoys. Why a CUP? We used to do them as
exemptions.
• We also need to do something about the restrictions on Beach Access Structures, or Stairs to the
Beach. Feeder Bluff. They are prohibited on Feeder Bluffs. Probably need to redefine and use
Geotech to determine feasibility.
• These changes to simplify the processing are consistent with Resolution 17-19 “Regulatory
Reform.”
• Of course, public participation (Task 3 or P3) is key and throughout the entire process we will be
reaching out to get feedback, evaluating comments and analyzing and assessing additions or
revisions to the code. We are assembling a Task Force similar to the one for CAO, to be
facilitated by a consultant to help determine the basic scope of the review and which areas of
the code my need to be changed due to a change in circumstance or new information or data.
We expect a member of the Planning Commission to be part of the Task Force.
• Timeline:
o Ecology Grant Agreement signed and active June 22, 2020.
o Task 1: project management - ongoing
o Task 2: Consultant contract signed by August 30, 2020. One proposal received June 30,
2020.
o Task 3: Public Participation Plan due July 13, 2020.
o Task 4: Current Periodic Review Checklist Proposed Draft Revisions due September 30,
2020.
o Task 5: SMP final draft amendment or Findings of Adequacy due January 30, 2021.
o Close out report on Final SMP Revisions due June 30, 2021.
o These due dates and Task budget items a subject to monitoring, adjustment and
revision as needed in conjunction with Ecology.
• I will provide PC and Public with Gantt Chart that will show all tasks and track progress, will
probably also be on-line for public access.
• Any questions?