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HomeMy WebLinkAboutOLD Jefferson County Draft PR Checklist_2020_1125 Shoreline Master Program Periodic Review Checklist 1 July 2019 Jefferson County | Draft | November 25, 2020 SHORELINE MASTER PROGRAM PERIODIC REVIEW Periodic Review Checklist This document is intended for use by counties, cities and towns subject to the Shoreline Management Act (SMA) to conduct the “periodic review” of their Shoreline Master Programs (SMPs). This review is intended to keep SMPs current with amendments to state laws or rules, changes to local plans and regulations, and changes to address local circumstances, new information or improved data. The review is required under the SMA at RCW 90.58.080(4). Ecology’s rule outlining procedures for conducting these reviews is at WAC 173-26-090. This checklist summarizes amendments to state law, rules and applicable updated guidance adopted between 2007 and 2019 that may trigger the need for local SMP amendments during periodic reviews. How to use this checklist See the associated Periodic Review Checklist Guidance for a description of each item, relevant links, review considerations, and example language. At the beginning of the periodic review, use the review column to document review considerations and determine if local amendments are needed to maintain compliance. See WAC 173-26-090(3)(b)(i). Ecology recommends reviewing all items on the checklist. Some items on the checklist prior to the local SMP adoption may be relevant. At the end of your review process, use the checklist as a final summary identifying your final action, indicating where the SMP addresses applicable amended laws, or indicate where no action is needed. See WAC 173-26-090(3)(d)(ii)(D), and WAC 173-26-110(9)(b). Local governments should coordinate with their assigned Ecology regional planner for more information on how to use this checklist and conduct the periodic review. Shoreline Master Program Periodic Review Checklist 2 July 2019 Jefferson County | Draft | November 25, 2020 Prepared By Jurisdiction Date draft Jefferson County 11/25/2020 Row Summary of change Review Action 2019 a. OFM adjusted the cost threshold for building freshwater docks JCC 18.25.560 Exemptions Listed #9 reads: “Residential Docks. … The private dock exemption applies to dock construction cost as specified in RCW 90.58.030(3)(e).” No action required b. The Legislature removed the requirement for a shoreline permit for disposal of dredged materials at Dredged Material Management Program sites (applies to 9 jurisdictions) JCC 18.25.360 Dredging Dredge Disposal Regulation #4.d reads: “When consistent with this program, disposal of dredged materials in water areas other than PSDDA sites may only be allowed for the following reasons: (i) To restore or enhance habitat; or (ii) To reestablish substrates for fish and shellfish resources; or (iii) To nourish beaches that are starved for sediment; or (iv) To remediate contaminated sediments.” DMMP not applicable to Jefferson County No action required c. The Legislature added restoring native kelp, eelgrass beds and native oysters as fish habitat enhancement projects. JCC 18.25.560 Exemptions Listed #18 reads: “A public or private project, the primary purpose of which is to improve fish or wildlife habitat or fish passage, when all of the following apply: (a) The project has been approved in writing by the Department of Fish and Wildlife as necessary for the improvement of the habitat or passage and appropriately designed and sited to No action required. Per Ecology, consider the expanded language at WAC 173-27-040(2)(p) with the more explicit citation to RCW 77.55.181. Change proposed to cross reference 173-27-040(2)(p). Shoreline Master Program Periodic Review Checklist 3 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action accomplish the intended purpose; (b) The project received hydraulic project approval by the Department of Fish and Wildlife pursuant to Chapter 75.20 RCW; and (c) The administrator has determined that the project is consistent with this program. The administrator shall make such determination in a timely manner and provide it by letter to the project proponent. [Ord. 7-13 Exh. A (Art. IX § 3)]” 2017 a. OFM adjusted the cost threshold for substantial development to $7,047. JCC 18.25.100 Definition #19.tt reads: “Substantial Development…$5,718 or as adjusted by the state legislature…” JCC 18.25.560 Exemptions Listed #1. Fair Market Value reads: “…does not exceed $6,416 or as adjusted by WAC 173-27-040…” No action required. Optional revision to replace both outdated figures with current value of $7,047 for clarity & document improvement. Ecology suggests changing value or changing to citation; approach up to County but Ecology would require a change. Change proposed to add new value. b. Ecology permit rules clarified the definition of “development” does not include dismantling or removing structures. JCC 18.25.100 Definition #4.g reads: “(g) ***“Development” means a use consisting of the construction or exterior alteration of structures; dredging; drilling; dumping; filling; removal of any sand, gravel, or minerals; bulkheading; driving of piling; placing of obstructions; or any project of a permanent or temporary nature which interferes with the normal No action required. Optional revision to add text “Development” does not include dismantling or removing structures if there is no other associated development or re- development for clarity & document improvement. Change added to draft SMP revisions. Shoreline Master Program Periodic Review Checklist 4 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action public use of the surface of the waters overlying lands subject to this program at any state of water level.” c. Ecology adopted rules clarifying exceptions to local review under the SMA. JCC 18.25 does not address these exceptions from WAC 173-27-044 No action required - the exceptions apply regardless of SMP inclusion. Optional text revision to add the example language for clarity and to ensure consistent implementation: Developments not required to obtain shoreline permits or local reviews. Requirements to obtain a substantial development permit, conditional use permit, variance, letter of exemption, or other review to implement the Shoreline Management Act do not apply to the following: (i) Remedial actions. Pursuant to RCW 90.58.355, any person conducting a remedial action at a facility pursuant to a consent decree, order, or agreed order issued pursuant to chapter 70.105D RCW, or to the department of ecology when it conducts a remedial action under chapter 70.105D RCW. (ii) Boatyard improvements to meet NPDES permit requirements. Pursuant to RCW 90.58.355, any person installing site improvements for storm water treatment in an existing boatyard facility to meet requirements of a national pollutant discharge elimination system storm water general permit. Shoreline Master Program Periodic Review Checklist 5 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action (iii) WSDOT facility maintenance and safety improvements. Pursuant to RCW 90.58.356, Washington State Department of Transportation projects and activities meeting the conditions of RCW 90.58.356 are not required to obtain a substantial development permit, conditional use permit, variance, letter of exemption, or other local review. (iv) Projects consistent with an environmental excellence program agreement pursuant to RCW 90.58.045. (v) Projects authorized through the Energy Facility Site Evaluation Council process, pursuant to chapter 80.50 RCW. Change added to draft SMP revisions. d. Ecology amended rules clarifying permit filing procedures consistent with a 2011 statute. JCC 18.25.750 Notice of decision, reconsideration and appeal. #1. A notice of decision for action on a shoreline substantial development permit, shoreline variance, or shoreline conditional use permit shall be provided to the applicant/proponent and any party of record in accordance with the procedures of Chapter 18.40 JCC and at least 10 days prior to filing such decisions with the Department of Ecology pursuant to WAC 173-27-130. Decisions filed with the Department of Ecology shall Revision required to clarify current standards for date of filing by permit type, concurrent filings, ECY notice by phone/email & written, and submittal to ECY by return receipt requested. Incorporate example language: After all local permit administrative appeals or reconsideration periods are complete and the permit documents are amended to incorporate any resulting changes, the County will mail the permit using return receipt requested mail to the Department of Ecology regional office and the Office of the Attorney General. Shoreline Master Program Periodic Review Checklist 6 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action contain the following information: (a) A copy of the complete application; (b) Findings and conclusions that establish the basis for the decision including but not limited to identification of shoreline environment designation, applicable master program policies and regulations and the consistency of the project with appropriate review criteria for the type of permit(s); (c) The final decision of the local government; (d) Where applicable, local government shall also file the applicable documents required by SEPA, or in lieu thereof, a statement summarizing the actions and dates of such actions taken under Chapter 43.21C RCW; and (e) When the project has been modified in the course of the local review process, plans or text shall be provided that clearly indicate the final approved plan. JCC 18.25.760 Initiation of Development #2 “Date of Filing. “Date of filing” of a substantial development permit is the date of actual receipt of the decision by the Department of Ecology. The “date of filing” for a shoreline variance or shoreline conditional use permit shall mean the date the permit decision rendered by the Department of Ecology is Projects that require both Conditional Use Permits and or Variances shall be mailed simultaneously with any Substantial Development Permits for the project. (i) The permit and documentation of the final local decision will be mailed together with the complete permit application; a findings and conclusions letter; a permit data form (cover sheet); and applicable SEPA documents. (ii) Consistent with RCW 90.58.140(6), the state’s Shorelines Hearings Board twentyone (21) day appeal period starts with the date of filing, which is defined below: (A) For projects that only require a Substantial Development Permit: the date that Ecology receives the County decision. (B) For a Conditional Use Permit (CUP) or Variance: the date that Ecology’s decision on the CUP or Variance is transmitted to the applicant and the County. (C) For SDPs simultaneously mailed with a CUP or VAR to Ecology: the date that Ecology’s decision on the CUP or Variance is transmitted to the applicant and the County. Change added to draft SMP revisions. Shoreline Master Program Periodic Review Checklist 7 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action transmitted by the Department of Ecology to the county and the applicant/proponent. [Ord. 7- 13 Exh. A (Art. X § 17)]” e. Ecology amended forestry use regulations to clarify that forest practices that only involves timber cutting are not SMA “developments” and do not require SDPs. JCC 18.25.460 Forest Practices Regulation #4.b. “Except as provided in subsections (4)(c) and (d) of this section, timber harvesting and forest practices activities that do not meet the definition of development in Article II of this chapter shall not be regulated by this program and shall not require a shoreline permit.” … #4.e “Other activities associated with timber harvesting, such as filling, excavation, and building roads and structures, that meet the definition of development shall be regulated according to the general provisions (Article VI of this chapter), shoreline modification provisions (Article VII of this chapter) and/or the other applicable use-specific provisions (this article) of this program and shall require a shoreline substantial development permit or conditional use permit as specified in this program.” No action required. Optional text revision to incorporate example language: A forest practice that only involves timber cutting is not a development under the act and does not require a shoreline substantial development permit or a shoreline exemption. A forest practice that includes activities other than timber cutting may be a development under the act and may require a substantial development permit, as required by WAC 222-50-020. Change added to draft SMP revisions. f. Ecology clarified the SMA does not apply to lands under exclusive federal jurisdiction JCC 18.25.020 Applicability #4. This program shall apply to: (a) All of the lands and waters of Jefferson County that fall under the jurisdiction of Chapter 90.58 RCW; and (b) Every person, individual, firm, partnership, association, organization, local or state Exclusive Federal Jurisdicition in Olympic National Park per RCW 37.08.210) is not explicitly addressd. Optional text revision for clarity to add example language: Shoreline Master Program Periodic Review Checklist 8 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action governmental agency, public or municipal corporation, or other nonfederal entity; and (c) All nonfederal uses and developments undertaken on federal lands and on lands subject to nonfederal ownership, lease, or easement, even though such lands may fall within the external boundaries of federally owned lands (Footnote1)*. *Wording from WAC 173-27- 060(3). Areas and uses in those areas that are under exclusive federal jurisdiction as established through federal or state statutes are not subject to the jurisdiction of chapter 90.58 RCW, including Olympic National Park. Per Ecology: Olympic National Park is one of two such locations established by statute and County is encouraged to address this issue, likely in JCC 18.25.020 Applicability. Change added to draft SMP revisions. g. Ecology clarified “default” provisions for nonconforming uses and development. JCC 18.25.660 No action required due to State rule. This rule is a default rule that only applies if a local government has no provisions in its local SMP addressing nonconforming uses. h. Ecology adopted rule amendments to clarify the scope and process for conducting periodic reviews. JCC 18.25.840 Master program amendments does not address periodic review. No action required – the periodic review requirements apply regardless of SMP inclusion. Optional text revision to add example language for clarity: The County will conduct the SMP periodic review process consistent with requirements of RCW 90.58.080 and WAC 173-26-090. Change added to draft SMP revisions. i. Ecology adopted a new rule creating an optional SMP amendment process that allows for a shared local/state public comment period. JCC 18.25.840 Master program amendments does not address the optional joint review process. No action required – the optional joint review process per WAC 173-26-104 applies regardless of SMP inclusion. Shoreline Master Program Periodic Review Checklist 9 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action j. Submittal to Ecology of proposed SMP amendments. JCC 18.25 does not address Ecology submittal requirements. No action required – the submittal requirements of WAC 173-26-110 and -120 apply regardless of SMP inclusion. 2016 a. The Legislature created a new shoreline permit exemption for retrofitting existing structure to comply with the Americans with Disabilities Act. JCC 18.25.560 Exemptions Listed does not include the new ADA exemption. No action required – the SDP exemption applies regardless of SMP inclusion. Ecology suggests including in full like other exemptions or changing to citations. Jefferson County can determine approach. Change of some kind would likely be required. Optional text revision for clarity to add example language: The external or internal retrofitting of an existing structure with the exclusive purpose of compliance with the Americans with Disabilities Act of 1990 (42 U.S.C. Sec. 12101 et seq.) or to otherwise provide physical access to the structure by individuals with disabilities. Change added to draft SMP revisions. b. Ecology updated wetlands critical areas guidance including implementation guidance for the 2014 wetlands rating system. 18.25.060: SMP adopts critical areas regulations by reference (as of date of adoption) with some exceptions. JCC adequately reflects the most current technical guidance. • JCC 18.22.710Hi (1) references RCW 36.70A.175 regarding federal manual. • JCC 18.22.710 (2) references 2014 manual – determine if edit need since SMP references CAO. Shoreline Master Program Periodic Review Checklist 10 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action • JCC Buffers in Table 18.22.730(1)(a) matches Ecology CAO comment letter 1/21/20 page 2. • Buffer reduction criteria JCC Table 18.22.730(1)(b) matches Ecology CAO comment letter 1/21/20 page 4. 2015 a. The Legislature adopted a 90-day target for local review of Washington State Department of Transportation (WSDOT) projects. Neither JCC 18.25.520 Transportation nor JCC 18.25.650 Notice of application and permit application review specify this timeline target. No action required – the review timeline target applies regardless of SMP inclusion. Optional text revision to add example language. Special procedures for WSDOT projects. (i) Permit review time for projects on a state highway. Pursuant to RCW 47.01.485, the Legislature established a target of 90 days review time for local governments. (ii) Optional process allowing construction to commence twenty-one days after date of filing. Pursuant to RCW 90.58.140, Washington State Department of Transportation projects that address significant public safety risks may begin twenty-one days after the date of filing if all components of the project will achieve no net loss of shoreline ecological functions. Change added to draft SMP revisions. 2014 a. The Legislature created a new definition and policy for floating on-water residences legally established before 7/1/2014. JCC 18.25.220 Use Table does not specify Floating Homes or FOWRs, but does prohibit Single-Family Residential use (including appurtenances & No action required. Optional text revision to sync up terms used and Definitions with RCW 90.58.270. Shoreline Master Program Periodic Review Checklist 11 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action accessory structures), in both the Priority Aquactic and the Aquatic SEDs. JCC 18.25.100 Definition #6.m. “Floating house” means any floating structure that is designed, or has been substantially and structurally remodeled or redesigned, to serve primarily as a residence. “Floating houses” include house boats, house barges, or any floating structures that serve primarily as a residence and do not qualify as a vessel. A floating structure that is used as a residence and is capable of navigation, but is not designed primarily for navigation, nor is normally capable of self propulsion and use as a means of transportation, is a floating house, not a vessel per WAC 332-30-103. "Floating home" means a single-family dwelling unit constructed on a float, that is moored, anchored, or otherwise secured in waters, and is not a vessel, even though it may be capable of being towed. "Floating on-water residence" means any floating structure other than a floating home, that: (i) Is designed or used primarily as a residence on the water and has detachable utilities; and (ii) whose owner or primary occupant has held an ownership interest in space in a marina, or has held a lease or sublease to use space in a marina, since a date prior to July 1, 2014. Per Ecology, though none exist and the SMP prohibits new residential in/over water, County may want to revise the existing term ‘floating house’ and definitions to reflect these terms defined by statute/WAC. Change added to draft SMP revisions. 2012 a. The Legislature amended the SMA to clarify SMP appeal procedures. JCC 18.25.840 Master program amendments. Pursuant to RCW 90.58.190 and 36.70A.280, a decision by the Jefferson County board of county commissioners to amend this master program shall not constitute a final appealable decision until the Department of Ecology has made a decision to approve, No action required – the statutory & rule requirements apply regardless of SMP inclusion. Shoreline Master Program Periodic Review Checklist 12 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action reject, or modify the proposed amendment. Following the decision of the Department of Ecology regarding the proposed amendment, the decision may be appealed to the Western Washington Growth Management Hearings Board. [Ord. 7-13 Exh. A (Art. X § 25)] 2011 a. Ecology adopted a rule requiring that wetlands be delineated in accordance with the approved federal wetland delineation manual. 18.25.060: SMP adopts critical areas regulations by reference (as of date of adoption) with some exceptions. See 2016 b. b. Ecology adopted rules for new commercial geoduck aquaculture. JCC 18.25.100 Definitions #2.t “Bottom culture” means all aquaculture systems that are set on or securely and rigidly attached to the tidelands or bedlands and do not extend higher than six feet from the bottom (excluding hoists and similar apparatus). Bottom culture includes but is not limited to geoduck tubes, oyster longlines, clam netting, oyster rack and bags, and clam bags. Bottom culture does not include aquaculture suspended from rafts or buoys or contained in floating net pens. JCC 18.25.220 Use Table Geoduck aquaculture is allowed in both the Priority Aquatic and Aquatic SEDs, requires an SDP when adjacent to High Intensity SED, and requires a CUP when adjacent to Natural, Conservancy, and Shoreline Residential SEDS. JCC 18.25.220 and -440 have been revised to require a CUP for new commercial geoduck aquaculture and to add supporting regulations governing commercial geoduck aquaculture per WAC 173-26-241(3)(b)(ii-iv) Shoreline Master Program Periodic Review Checklist 13 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action JCC 18.25.440 Aquaculture. General Regulations 4.a-f apply, including: • initial siting/planting SDP 5- yr limit + 1-yr extension; • ongoing operations allowance; • 25% / 10-yr expansion limit; • activities allowed w/o SDP, unless public use interference, structures, mechanical dredging, or filling; • JARPA & SEPA submittals to allow case-by-case assessment of use interference w/ exceptions; • Standards e(i – xv) re: adverse impacts, cumulative effects, nonWO structures, OW sleeping quarters, height limits, visual impacts, interference w/ Nav, Public Access, Tribal harvest, 600 - 1500 from NWR/other protected areas, shading kelp, helical anchors, compensate use of public facilities, predator control methods, chemicals/GMOs, non-Nav lighting, waste disposal; • f. “Prior to approving a permit for floating/hanging aquaculture’ use and development or bottom culture involving structures, the county may require a visual analysis prepared by the applicant/proponent describing effects on nearby uses and aesthetic qualities of the shoreline. The analysis shall demonstrate that adverse impacts on the Shoreline Master Program Periodic Review Checklist 14 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action character of those areas are effectively mitigated.” c. The Legislature created a new definition and policy for floating homes permitted or legally established prior to January 1, 2011. See 2014.a above See 2014.a above d. The Legislature authorizing a new option to classify existing structures as conforming. JCC 18.25.660 Nonconforming development. JCC 18.25.500 Residential. No action required. Optional revision to add text implementing WAC 173-26- 241(3.j) at (6.A) Change added. 2010 a. The Legislature adopted Growth Management Act – Shoreline Management Act clarifications. No action required 2009 a. The Legislature created new “relief” procedures for instances in which a shoreline restoration project within a UGA creates a shift in Ordinary High Water Mark. JCC 18.25.170 Restoration and enhancement – Purpose & Goals JCC 18.25.400 Restoration Separate but related: JCC 18.25.270 Critical areas, shoreline buffers, and ecological protection – Regulations #2.g allows an advance restoration credit No action required – the process may be used regardless of SMP inclusion. Optional text revision to add either version of example language (i.w. option 1 below): The County may grant relief from shoreline master program development standards and use regulations resulting from shoreline restoration projects within urban growth areas consistent with criteria and procedures in WAC 173-27-215. Change added to draft SMP revisions - see new section JCC 18.25.605. b. Ecology adopted a rule for certifying wetland mitigation banks. Referenced potential for wetland mitigation bank in SMP at JCC 18.25.270 (h). Fee in lieu is rereferenced in CAO. Language in JCC 18.25.270(2)(h) meets the Ecology requirement; it could be improved by adding the Shoreline Master Program Periodic Review Checklist 15 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action word ‘certified’ (i.e., …certified mitigation banks,…). c. The Legislature added moratoria authority and procedures to the SMA. JCC 18.25 does not address moratoria No action required – the statutory provisions apply regardless of SMP inclusion. 2007 a. The Legislature clarified options for defining "floodway" as either the area that has been established in FEMA maps, or the floodway criteria set in the SMA. JCC 18.25.100 Definitions #6.r. “Floodway” means the area of a river valley that conveys flood waters with reasonable regularity, although not necessarily annually. At a minimum, the floodway is that which has been established in Federal Emergency Management Act flood insurance rate maps or Federal Emergency Management Act floodway maps. Other data and information, including topography, changes in soil or vegetation, and other indicators of past flooding, may be used to define and map a floodway that meets the objectives of the Shoreline Management Act, Chapter 90.58 RCW. The floodway shall not include those lands that can reasonably be expected to be protected from 100-year flood waters by flood control devices maintained by or maintained under license from the federal government, the state, or a political subdivision of the state. The adopted SMP definition is similar to Ecology example language Option 1. Made edits to be identical. b. Ecology amended rules to clarify that comprehensively updated SMPs shall include a list and map of streams and lakes that are in shoreline jurisdiction. JCC 18.25.870 Official Shoreline Map ICR List of Waterbodies? No action required Shoreline Master Program Periodic Review Checklist 16 July 2019 Jefferson County | Draft | November 25, 2020 Row Summary of change Review Action c. Ecology’s rule listing statutory exemptions from the requirement for an SDP was amended to include fish habitat enhancement projects that conform to the provisions of RCW 77.55.181. JCC 18.25.560 Exemptions Listed #18 “A public or private project, the primary purpose of which is to improve fish or wildlife habitat or fish passage, when all of the following apply: …” No action required Additional amendments Modify this section, as needed, to reflect additional review issues and related amendments. The summary of change could be about Comprehensive Plan and Development regulations, changes to local circumstance, new information, or improved data. Two example formats: SMP section Summary of change Review Action County-Proposed Edits: SMP Task Force SMP Section Summary of change Discussion 18.25.660 (8) (9) (10) Task Force A: Maintain protective standards to achieve no-net-loss of shoreline ecological function, but reduce unnecessary CUPs/variances. Potentially adjust administrative versus discretionary CUPs. Examples include but are not limited to: existing single family home expansions and septic systems. Meet environmental protection and address regulatory reform. Result: Removed some CUP limitations on beach access structures. Table 18.25.220, 18.25.350 Task Force B: Review permit type and standards for buoys compared to other shoreline facilities for boating. Consider where there are good locations for buoys. Review buoy standards versus anchoring, and unintended consequences of SMP regulations. Clarify permitting standards surrounding eelgrass beds, including differences Clarify SMP. Allow best practices that minimize environmental impact. Address regulatory reform. Result: Shifted buoys from CUP to SDP in SR and C environments. Minimally addressed eelgrass and proposed limit on number of buoys per residential lot to two (DNR allows second buoy to help secure moorage to first buoy). Shoreline Master Program Periodic Review Checklist 17 July 2019 Jefferson County | Draft | November 25, 2020 SMP Section Summary of change Discussion between areas with eelgrass patches and full eelgrass coverage. Consider appropriate number or density of buoys. 18.25.120, 18.25.180, 18.25.190, 18.25.300, 18.25.410(5)(e), 18.25.430, 18.25.520 Task Force C: Add in Comprehensive Plan climate policies like Option 1. Plus, strive for consistency with Port Townsend’s SMP. Ensure that policies and permit standards do not limit projects that are proactively addressing projections in sea level rise due to climate change. Consider elevation, not just distance from the ordinary highwater mark, for shoreline permitting. Proactively address climate change and sea-level rise particularly for activities with long-life. Result: Most Comprehensive Plan policies added into SMP. Opportunity to request a CUP to add height in response to sea-level rise. Added policy on retreat, accommodate, and protect. Table 18.25.220, 18.25.450 Task Force D: Marine trades and economic development. Ensure SMP permitting process does not unduly burden marine trades. Recognize important sectors that support economy and water oriented uses. Result: Reviewed current use matrix; most uses addressed appropriately. Also see edits to bouys and launches. Also added reference to maritime trades definition and maritime education/training as a scientific and educational activity subject to commercial standards. Table 18.25.220, 18.25.350 Task Force E: Encourage development of new public boat launches and improvement of existing boat launches in SMP. Lack of boat launches, condition of existing. Result: Changed CUP to P for public boat launches in Conservancy. This should assist with new launches and modifications/expansions/improvements of existing launches. After conversation with WDFW, added reference to WAC design standards to be used to extent feasible. 18.25.250 Review how Shoreline Management Act purposes are carried out with use allowances and permitting. Clarify how SMP is carried out on shorelines identified for optimal implementation of SMP. Result: Addressed policy updates which should apply to all permits. Shoreline Master Program Periodic Review Checklist 18 July 2019 Jefferson County | Draft | November 25, 2020 County Proposed SMP Edits: Staff Docket/Code Interpretations SMP Section Summary of Change Discussion 18.25.660 Non-conforming uses/development clarification Clarify with revised definition of nonconforming in Article II,18.25.100. 18.25.270(4)(a)(i) SMP/Critical Area clarification This subsection was intended to mean that critical area regulations in Chapter 18.22 are to be used, but where there are discrepancies (such as those pertaining to buffers, nonconforming development, etc.), then the SMP prevails. Clarify how the SMP subsections pertaining to critical areas interact with critical area regulations in Chapter 18.22. Shoreline Designations for State Parks Review all shoreline designations for State Parks considering designation (conservancy or natural) and shoreline access for conditions and revise where warranted. 18.25.440(4)(d) References subsection (3)(c), but reference for interference should be (4)(c). Change reference to (3)(c) to (4)(c)(i) 18.25.620 & .630 JCC 18.25.630(18) & (19) should be in 18.25.620 as (7) and (8) Move subsections (18) & (19) of 18.25.630 to 18.25.620 and re-number as subsections (7) & (8) Parcel #921000001 on Indian Island is State DNR Land, but does not have a shoreline designation. Appears to have been lumped in with N/A for Federal Exempt Lands. SMP considers Conservancy a default when an area is undesignated. Anticipate collecting information per WAC to assign designation of Conservancy. 18.25.210(3) Clarify that west end rivers are aquatic below OHWM Review and revise where warranted. JCC 18.25.100(19)(w)(i),(ii) and (iv) and JCC 18.25.240 Definition of Shoreline of Statewide Significance are duplicates in JCC 18.25.100(19)(w)(i) and (ii). JC 18.25.100(19)(vii) refers to both (i)and (ii), should ensure the correct subsections are reflected. Delete subsection 18.25.100(w)(ii) and re- number subsequent subsections. Delete reference to (ii) in subsection (vii) (to be new subsection (vi) after re-numbering). Shorelines of statewide significance should be verbatim from WAC 18.25.440(4)(e): 'not' is consistent with (4)(c) and reference change Aquaculture: clarify when a SDP is needed. Review in concert with SMP Periodic Review Checklist. Consider deleting reference to (1) from (4)e to just read (b). Shoreline Master Program Periodic Review Checklist 19 July 2019 Jefferson County | Draft | November 25, 2020 SMP Section Summary of Change Discussion from (1)(b) to say (4)(b) Delete text "or conditional use permit (CUP)" 18.25.100(14)(h), and possibly 18.25.270(5)(a) and (b) Revise nonconforming lot definition from "…minimum lot size…" to "minimum lot depth…", and check how it is used relative to the modest home provision and the common line buffer. Clarify with revised definition of nonconforming in Article II,18.25.100. Change the text "size" to "depth." Incorporate Code Interpretation regarding non-conforming lot if warranted. 18.25.410 Clarify that the applicant must demonstrate erosion from wave energy to approve soft shore stabilization; also, revise policies to include soft shore stabilization. Add soft shore stabilization regulations. Geotechnical report should suffice. 18.25.560(15), (16), and (17) Revise watershed restoration exemptions to be consistent with state law. Exemptions 15 and 17 are definitions, not exemptions. Clarify that exemption 16 has no shoreline permitting fee, per RCW 90.58.515. Revise 18.25.560 Exemptions to consolidate subsections (15), (16) & (17). 18.25.270 Specify report requirements for NNL; consider referencing requirements for CAO report requirements in 18.22. Consultant recommendations: A stand- alone NNL report is not necessary. If desired, it could be limited to CUPs and Variances – and then it should focus on the specific ecological effects, if any (and how they are mitigated), of the conditional use or variance beyond those that would have resulted either without the variance or from another allowed/non-CUP use. The CUP and Variance criteria require applicants to demonstrate no adverse effects, which appears to address NNL. Otherwise, compliance with the SMP, including the mitigation sequencing provisions, should satisfy NNL as was demonstrated in the original Cumulative Impacts Analysis. 18.25.440((4)(b)(i) Clarify area included in 25% increase for both in-water and above OHWM development. Add text, "This applies to both in-water and above OHWM development." Shoreline Master Program Periodic Review Checklist 20 July 2019 Jefferson County | Draft | November 25, 2020 SMP Section Summary of Change Discussion JCC 18.25.410(5)(iii) JCC 18.25.410(5)(iii) has wrong code reference to flood regulations. Change text reference in JCC 18.25.410(5)(c)(iii) from "JCC 18.30.070" to "JCC 15.15." JCC 18.25.410(6)(h) Review if text should reference fewer than 4 residential lots as it would otherwise be inconsistent. Change text reference in JCC 18.25.410(6)(h) from "more" to "less." Provide guidance on requirements and/or evaluating aesthetic reports. Add text to 18.25.440(6)(b) "including what views in the vicinity would be altered or obstructed and propose measures to reduce impacts," after "aesthetic qualities of the shoreline." JCC 18.25.650 Why is section is silent on notices for Type II permits, but spells out process on Type I and III permits? Add text "II &" to 18.25.650(1)(b) "Type III project permit…". Permit procedures should reference other processes in UDC and not duplicate or create new. JCC 18.25.300(2)(b) Side yard setback language is confusing. SMP does not establish side yard setbacks, and JCC 18.30 does not identify side yard setbacks based off of zoning which makes it confusing for in water. Replace text in 18.25.300(2)(b), "Five feet of the total required side yard setbacks may be provided on one side and the balance on the other side," with, "The standard side yard setback is five feet." Review for consistency with zoning. JCC 18.25.620 Unclear if C(a) permit and SSDP requires a Type III process. What is the process for stand-alone SSDP (yes use, but SSDP required)? JCC 18.25.620(3) & (4) are clear that C(a) and C(d) are processed as Type IIs. Add new subsection that SDPs shall be processed as a Type I permit. Delete text "substantial development permits and," from 18.25.620(2). Re-number existing subsections to include new subsection. JCC 18.25.100 Consider adding in definitions in for waterward and lateral as associated with implementing code language. Add definition under 18.25.100(12) for "Lateral," to define expansion in relation to the OHWM. JCC 18.25.310 Provide clarification on vegetation maintenance requirements and how it is applicable to clearing for new development, such as a single family residence, or just for views. Delete "new" from 18.25.310(2)(d). JCC 18.25.270(4)(l) Revise CASP from a Type III to a Type I process and when it is used in shoreline jurisdiction - current language is awkward. Replace text of last sentence in 18.25.270(4)(l) to read, "such buffer modification shall require a Type I Shoreline Master Program Periodic Review Checklist 21 July 2019 Jefferson County | Draft | November 25, 2020 SMP Section Summary of Change Discussion Substantial Development Permit (SDP).” Address consistency with CAO. JCC 18.25.660(9) Clarify if non-conforming lateral expansion is a C(a) or a C(d) Replace text in 18.25.660(9) that reads, "with a Conditional Use Permit," to read," with a Type I Substantial Development Permit (SDP)" JCC 18.25.660 Non-conforming expansion: change foundation walls to roof line to (8) and (10), and consider adding similar roof line language to (9). Revise text in 18.25.660(8)(b) that reads, "beyond the existing structures' foundation walls," to read, " beyond the structures' legally permitted development footprint." Add revised text above to 18.25.660(9), and revise same to 18.25.660(10)(a). JCC 18.25.270(5) Clarify that expansions to existing residential development can use the modest home provisions; not just new SFR development. Delete the text "New" under 18.25.270(5)(a). JCC 18.25.600; possibly, JCC 18.25.100(3)(q) Clarify if an unclassified conditional use is a C, C(a), or C(d). If it is determined to be a C (i.e., Type III), then the CUP definition in JCC 18.25.100(3)(q) needs to be revised. If there is no C (Type III) in the shoreline regulations, that should be clarified in JCC 18.25.600. Revise text in 18.25.600 that reads, "may be authorized as conditional uses…" to read, "may be authorized as a Discretionary Conditional Use "C(d)" permit, provided…" JCC 18.25.270(4)(i) Need to add a definition for "active use" within the shoreline buffer. Create definition for "active use" in 18.25.100(1) JCC 18.25.270(5)(a)(iii) Revise to say …common-line buffer, if applicable... Addition text to 18.25.270(5)(a)(iii) to read, "common-line buffer, if applicable; and" JCC 18.25.440(4)(d) Change reference from 3(c) to 4(c) (page 18-168.26) Replace "(3)" in 18.25.440(4)(d) to "(4)." JCC 18.25.340(2) and (4)(j) These two sections contradict each other. If new beach access is prohibited in marine feeder bluffs, why would it be allowed if the project is shown not to adversely affect? Possibly the intent is to allow these structures on feeder bluffs if geotech Redefine "feeder bluff" under 18.25.100(6)(d). Delete subsections 18.25.340(2) and (4)(d)(ii). Revisit the prohibitions for feeder bluffs. Shoreline Master Program Periodic Review Checklist 22 July 2019 Jefferson County | Draft | November 25, 2020 SMP Section Summary of Change Discussion says there is no adverse impact. 340(2) is too restrictive. JCC 18.25.270(4)e(iii) Clarify if all streams requires a 150- foot buffer in all shoreline environments or if it is only those identified as "shorelines" in 90.58 RCW (>20cfs) Shoreline buffers apply to S type streams only. Add text to 18.25.270(4)(e)(iii) to read "Stream/River (mean annual flows greater than 20 cubic feet per second) Shores." Similarly, added note to clarify lakes 20 acres or larger have shoreline buffers. JCC 18.25.310(2)(d) Maintenance trimming seems to only be allowed for "new" shoreline uses. Should also extend to existing uses. Delete the text "new" under 18.25.310(2)(d). JCC 18.25.560 and Appurtenance definitions Exempt ADU's as appurtenances. Add the text "Accessory Dwelling Units (ADU)," to 18.25.100(1)(aa). City of Bonney Lake is doing this for example. JCC 18.25.660(8) & (9) JCC 18.25.660(8)(9) planting plan needs to be more explicit re: if a habitat management plan by a biologist is required. Define what is needed in a "planting plan" in subsections 18.25.660(8) & (9).Clarify planting plan related to other SMP standards and definitions with attention to regulatory reform to address implementation needs and avoid unnecessary paperwork and expense. Other: Staff discussions and clarifications In limited locations flagged in corresponding SMP edits, made clarifications to respond to staff experience and questions regarding implementation. Various.