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HomeMy WebLinkAbout002Please put this in the PHMPR Comments file. Philip Philip C. Hunsucker Chief Civil Deputy Prosecuting Attorney Jefferson County Prosecuting Attorney’s Office P.O. Box 1220, Port Townsend, WA 98368 Ph: 360-385-9180 Fax: 360-385-0073 All e-mail sent to this address has been received by the Jefferson County e-mail system and is therefore subject to the Public Records Act, a state law found at RCW 42.56. Under the Public Records law the County must release this e-mail and its contents to any person who asks to obtain a copy (or for inspection) of this e-mail unless it is also exempt from production to the requester according to state law, including RCW 42.56 and other state laws. From: Philip Hunsucker Sent: Tuesday, January 02, 2018 3:08 PM To: 'Carol Morris' <carol_a_morris@msn.com> Cc: Ken Hugoniot <KHugoniot@co.jefferson.wa.us>; Laura Mikelson <lmikelson@co.jefferson.wa.us> Subject: RE: Joint Meeting of BOCC and Planning Commission -- Pleasant Harbor Ms. Morris: Attached is my substantive response to your emails. Philip Philip C. Hunsucker Chief Civil Deputy Prosecuting Attorney Jefferson County Prosecuting Attorney’s Office P.O. Box 1220, Port Townsend, WA 98368 Ph: 360-385-9180 Fax: 360-385-0073 All e-mail sent to this address has been received by the Jefferson County e-mail system and is therefore subject to the Public Records Act, a state law found at RCW 42.56. Under the Public Records law the County must release this e-mail and its contents to any person who asks to obtain a copy (or for inspection) of this e-mail unless it is also exempt from production to the requester according to state law, including RCW 42.56 and other state laws. From: Carol Morris [mailto:carol_a_morris@msn.com <mailto:carol_a_morris@msn.com> ] Sent: Friday, December 29, 2017 10:18 AM To: Philip Hunsucker <PHunsucker@co.jefferson.wa.us <mailto:PHunsucker@co.jefferson.wa.us> > Cc: Ken Hugoniot <KHugoniot@co.jefferson.wa.us <mailto:KHugoniot@co.jefferson.wa.us> > Subject: Re: Joint Meeting of BOCC and Planning Commission -- Pleasant Harbor Good morning: No need to respond other than to provide me with a copy of the latest version of the draft development agreement. Thank you and Happy Holidays. Carol Morris, Morris Law, P.C. 3304 Rosedale Street N.W., Suite 200 Gig Harbor, WA 98335 (253) 851-5090 F: (360) 850-1099 carol@carolmorrislaw.com <mailto:carol@carolmorrislaw.com> Website: carolmorrislaw.com This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, and/or attorney work production exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited. If you receive this message in error, or are not the named recipient(s), please notify the sender at either the e-mail address or telephone number above and delete this e-mail from your computer. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client product or other applicable privilege. Thank you. ________________________________ ________________________________ From: Philip Hunsucker <PHunsucker@co.jefferson.wa.us <mailto:PHunsucker@co.jefferson.wa.us> > Sent: Thursday, December 28, 2017 6:48 PM To: Carol Morris Cc: Ken Hugoniot Subject: RE: Joint Meeting of BOCC and Planning Commission -- Pleasant Harbor Ms. Morris: Thanks for your email confirming that the County has responded to your request. I will respond to the email below substantively by the end of next week, earlier if possible. Happy New Year. Philip Philip C. Hunsucker Chief Civil Deputy Prosecuting Attorney Jefferson County Prosecuting Attorney’s Office P.O. Box 1220, Port Townsend, WA 98368 Ph: 360-385-9180 Fax: 360-385-0073 All e-mail sent to this address has been received by the Jefferson County e-mail system and is therefore subject to the Public Records Act, a state law found at RCW 42.56. Under the Public Records law the County must release this e-mail and its contents to any person who asks to obtain a copy (or for inspection) of this e-mail unless it is also exempt from production to the requester according to state law, including RCW 42.56 and other state laws. From: Carol Morris [mailto:carol_a_morris@msn.com <mailto:carol_a_morris@msn.com> ] Sent: Thursday, December 28, 2017 4:47 PM To: Philip Hunsucker <PHunsucker@co.jefferson.wa.us <mailto:PHunsucker@co.jefferson.wa.us> > Cc: Ken Hugoniot <KHugoniot@co.jefferson.wa.us <mailto:KHugoniot@co.jefferson.wa.us> > Subject: Re: Joint Meeting of BOCC and Planning Commission -- Pleasant Harbor Good afternoon: Yes, it acknowledged my request. I want to be sure that the County doesn't continue to try to hide behind RCW 42.56.280 as an excuse for not providing the public with a copy of the draft development agreement submitted to the County by the developer, or the draft as it has been amended by the County after "negotiations" with the developer, for purposes of "discussion" (between the BOCC and the Planning Commission). As you are aware, RCW 36.70B.170(1) prohibits development agreements that are inconsistent with the County's adopted development regulations. The definition of "development regulations" in RCW 36.70A.030(7) includes the County's zoning ordinances, critical areas ordinances, official controls, etc. Therefore, if the County is attempting to amend its development regulations through a development agreement, it is thwarting the Growth Management Act's purposes, including but not limited to, the encouragement of citizen involvement in the planning process. RCW 36.70A.140 also requires that the County follow its public participation program in the adoption of amendments to the comprehensive plan and development regulations. There are no short cuts to such amendments through development agreements. When an applicant for a development approval submits an application to the County, the application materials are not exempt from disclosure under the Public Records Act. The County's staff report on whether or not the application materials comply with the County's code is not exempt from disclosure under the Act. If the County has prepared a draft of a development agreement that will modify the County's codes or comprehensive plan, and will be discussing it during an open meeting, the public must be provided a copy of this draft, well in advance of the meeting. The public should be able to review the draft prior to the meeting, so that the public, as well as all other participants, will be fully informed of the subject matter -- and can at least follow the discussion, if the County is too afraid to open the meeting up to public comment. The County is required by law to "provide for broad dissemination of proposals and alternatives, opportunity for written comments, public meetings after effective notice, provision for open discussion, communication programs, information services, and consideration of and response to public comments." It appears that the County wants to prevent the public from obtaining information about the County's "negotiations" with the developer, so that these "negotiations" may proceed in secret. Apparently, the County believes that it only owes the public one public hearing on a development agreement, which we expect will drastically deviate from the County's existing development regulations. Such surprise tactics violate GMA and procedural due process. Carol Morris, Morris Law, P.C. 3304 Rosedale Street N.W., Suite 200 Gig Harbor, WA 98335 (253) 851-5090 F: (360) 850-1099 carol@carolmorrislaw.com <mailto:carol@carolmorrislaw.com> Website: carolmorrislaw.com This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, and/or attorney work production exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited. If you receive this message in error, or are not the named recipient(s), please notify the sender at either the e-mail address or telephone number above and delete this e-mail from your computer. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client product or other applicable privilege. Thank you. ________________________________ ________________________________ From: Philip Hunsucker <PHunsucker@co.jefferson.wa.us <mailto:PHunsucker@co.jefferson.wa.us> > Sent: Wednesday, December 27, 2017 5:56 PM To: Carol Morris Cc: Ken Hugoniot Subject: RE: Joint Meeting of BOCC and Planning Commission -- Pleasant Harbor Ms. Morris: I received your public records request via another email earlier today. I understand that Jefferson County already has acknowledged receipt of your public records request. Philip Philip C. Hunsucker Chief Civil Deputy Prosecuting Attorney Jefferson County Prosecuting Attorney’s Office P.O. Box 1220, Port Townsend, WA 98368 Ph: 360-385-9180 Fax: 360-385-0073 All e-mail sent to this address has been received by the Jefferson County e-mail system and is therefore subject to the Public Records Act, a state law found at RCW 42.56. Under the Public Records law the County must release this e-mail and its contents to any person who asks to obtain a copy (or for inspection) of this e-mail unless it is also exempt from production to the requester according to state law, including RCW 42.56 and other state laws. From: Carol Morris [mailto:carol_a_morris@msn.com <mailto:carol_a_morris@msn.com> ] Sent: Wednesday, December 27, 2017 11:20 AM To: Philip Hunsucker <PHunsucker@co.jefferson.wa.us <mailto:PHunsucker@co.jefferson.wa.us> > Subject: Fw: Joint Meeting of BOCC and Planning Commission -- Pleasant Harbor Carol Morris, Morris Law, P.C. 3304 Rosedale Street N.W., Suite 200 Gig Harbor, WA 98335 (253) 851-5090 F: (360) 850-1099 carol@carolmorrislaw.com <mailto:carol@carolmorrislaw.com> Website: carolmorrislaw.com This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, and/or attorney work production exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited. If you receive this message in error, or are not the named recipient(s), please notify the sender at either the e-mail address or telephone number above and delete this e-mail from your computer. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client product or other applicable privilege. Thank you. ________________________________ ________________________________ From: Carol Morris <carol_a_morris@msn.com <mailto:carol_a_morris@msn.com> > Sent: Wednesday, December 27, 2017 10:46 AM To: mhass@co.jefferson.wa.us <mailto:mhass@co.jefferson.wa.us> ; mfarfan@jefferson.wa.us <mailto:mfarfan@jefferson.wa.us> Subject: Joint Meeting of BOCC and Planning Commission -- Pleasant Harbor Good morning: It is my understanding that there will be a joint meeting of the BOCC and the Planning Commission on the Pleasant Harbor proposed development agreement on January 16, 2017. Please send me a copy of this proposed development agreement. If the proposed development agreement will not be made available to the public prior to this meeting, I would appreciate a copy of the County's public participation program, as required by RCW 36.70A.140. If I need to make a public records request for the proposed development agreement, please let me know. The County certainly has no justification for withholding this proposed development agreement as a "draft," given that they have now cited to it in connection with the County's proposed action. See, RCW 42.56.280. Thank you. Carol Morris, Morris Law, P.C. 3304 Rosedale Street N.W., Suite 200 Gig Harbor, WA 98335 (253) 851-5090 F: (360) 850-1099 carol@carolmorrislaw.com <mailto:carol@carolmorrislaw.com> Website: carolmorrislaw.com This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, and/or attorney work production exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited. If you receive this message in error, or are not the named recipient(s), please notify the sender at either the e-mail address or telephone number above and delete this e-mail from your computer. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client product or other applicable privilege. Thank you. ________________________________ 䫺䩊