HomeMy WebLinkAbout01- Public Comment 09.15.2022From:lizanne coker
To:Planning Commission Desk
Cc:Brent Butler; Josh Peters; Joel Peterson; Greg Brotherton; Kate Dean; Heidi Eisenhour
Subject:Legal Lot of record Clark County 2016
Date:Wednesday, September 14, 2022 8:08:47 AM
Attachments:lot-determination CLARK.pdf
ALERT:BE CAUTIOUS This email originated outside the organization. Do not open
attachments or click on links if you are not expecting them.
Dear Members of the Planning Commission,
Please see the attached Legal Review created by Clark County regarding the
Legal Lot of Record back in 2016. The following 3 points are clearly supported
by the RCW, which I feel Jefferson needs to clearly adhere to.
A legal lot is a parcel of land that is consistent with the zoning and
platting laws that were in place when it was originally created.
If a parcel meets the requirements in place when originally created, and
doesn’t change, it will remain a legal lot, even if the requirements
change later
If a parcel was part of a subdivision or short plat that was reviewed and
approved by the county, and hasn’t changed since approval, it is
considered a legal lot. If a parcel hasn’t changed since 1969, it is a legal
lot.
In your DRAFT there is some mention of Lots Created that didn’t adhere to the
planning code in place “ at the time of creation”. If your planning department
believes that past County members failed to adhere to planning codes, the DCD
needs to present these examples prior to the adoption of this Draft. Obviously,
these statements within the draft itself, suggest the existence of these illegally
created lots.
More importantly, you are mistaking in your attempt to define Legal Lots as
separate from a Lot of record.
Again, A legal lot is a parcel of land that is consistent with the zoning and
platting laws that were in place when it was originally created.
Lizanne Coker
Director
Jefferson County Home Builders Association
360-821-9688
Legal Lot Determination
Revised 11/10/16
Community Development
1300 Franklin Street, Vancouver, Washington
Phone: (360) 397-2375 Fax: (360) 397-2011
www.clark.wa.gov/community-development
For an alternate format,
contact the Clark County
ADA Compliance Office.
Phone: (360)397-2322
Relay: 711 or (800) 833-6384
E-mail: ADA@clark.wa.gov
What is a legal lot?
A legal lot is a parcel of land that is
consistent with the zoning and platting laws
that were in place when it was originally
created. Zoning standards specify the
minimum lot size and dimensional
requirements that apply to all properties,
depending upon their location. Platting
standards specify the type of county review
process required to legally create new lots.
If a parcel meets the requirements in place
when originally created, and doesn’t
change, it will remain a legal lot, even if the
requirements change later.
The majority of parcels in Clark County are
legal lots, even those smaller than current
zoning requirements. Owners of lots of
record are eligible to apply for building
permits or other development applications,
unless they are prevented from doing so by
a court or Growth Management Hearings
Board order.
What is the purpose of these
requirements?
State law requires that counties and cities
have platting review processes and
minimum zoning standards in place.
However, the particular processes and
standards are left up to the local
government. State law also prohibits local
governments from issuing any permits on
illegally created lots.
Platting laws create a review process to
ensure that newly created lots have
adequate provisions for roads, sewer, water
and other services before they are sold.
Zoning laws create minimum lot sizes so
that development patterns and densities in
particular areas are generally compatible.
Larger lot size standards in the rural area
ensure that the area retains a rural
character and that opportunities for
farming, forestry, etc., continue to exist as
the county grows.
Aren’t all parcels for which taxes are
paid legal lots?
No, not necessarily. Under Washington law,
the county assessor is required to honor any
taxpayer’s request to segregate any portion
of their property, even if the portion is too
small or otherwise inconsistent with land
use requirements. After the property is
segregated, the assessor is obligated to treat
it as a separate tax parcel. The assessor does
not require compliance with any land use
laws.
How can I tell if a particular parcel is a
legal lot?
Here are a few shortcuts. If a parcel has a
house or mobile home on it, there will be a
legal lot of record if the owner obtained
necessary building and/or placement
permits, and the parcel hasn’t been changed
since that time.
If a parcel was part of a subdivision or short
plat that was reviewed and approved by the
county, and hasn’t changed since approval,
it is considered a legal lot. If a parcel hasn’t
changed since 1969, it is a legal lot.
If parcels can’t be determined through these
shortcuts, they are probably legal lots. The
key factor is to know when the parcel was
created, and what the zoning and platting
requirements were in place at the time of
creation.
Legal Lot Determination Land Use Review
Revised 11/10/16 Page 2 of 7
If the above shortcuts are insufficient to
prove a lot was legally created, a check of
the sales deed history is required. You, or
the seller, may already have previous
recorded sales deeds along with other
ownership documents. The county auditor
keeps records of all recorded sales in the
county. Or, for a small fee, a private title
company can provide you with a recorded
sales history for any parcel. Permit Center
staff can help explain and identify the
issues, but it does not keep records of
private sales or transfers.
Can the county tell me if a parcel is a
legal lot?
It depends on how much information can
be provided about the parcel. You can call
or visit the Permit Center staff located at
the Public Services Center, 1300 Franklin
Street, first floor, Vancouver, Washington,
to get free, informal information about a
parcel’s legal lot status, depending on the
time of creation. You can also apply for a
formal legal lot determination that will
provide a written, binding letter of proof
about the parcel’s status. In either case,
information will need to be provided when
the parcel was created.
Are Legal Lot Determination fees
assessed on Building Permit
Applications?
Yes, on historical lots originally created
through tax segregation or other process
that wasn’t reviewed. Fees will be assessed
for placement or replacement of homes or
other primary structures. No fee is required
for building permits on lots created through
a platted land division or other process in
which lot status was reviewed. Fees also
won’t be assessed for home remodels,
expansions, or grading permits.
How can I find out what requirements
were in place at the time my parcel
was created?
Zoning and platting laws have changed over
time. The changes listed below may help
determine the applicable requirements:
Zoning - the minimum lot size and
dimension requirements
Prior to 1980, almost all rural areas had
a 1-acre minimum lot size.
In 1980, new rural zones were
established ranging from a 1-acre
minimum to 20-acre minimum.
In December 1994, new rural zones were
established ranging from a 5-acre
minimum to 80-acre minimum.
Call or visit the Permit Center for
mapping of previous zoning
requirements for specific properties.
Platting - the required review process for
creating new lots
Prior to August 21, 1969, a tax
segregation recorded at the assessor’s
office is accepted as a legal lot.
After August 21, 1969, creating lots of
less than five acres, as part of land
divisions of five or more lots, required
county subdivision review and approval.
After July 1, 1976, creating lots of less
than five acres, as part of land divisions
of four or fewer lots, required county
short plat review and approval.
After April 19, 1993, creating lots of less
than 20 acres as part of any land
division required county short plat or
subdivision review and approval.
What should I do if I’m considering
buying a parcel of land?
Although most parcels are legal lots, the
status should be determined before
purchase. Ask the seller for information
about the parcel’s status, sales history,
previous building permits or county
approvals that may have been obtained. You
may also want to talk with county staff, or
condition the sales agreement on a formal
Legal Lot Determination Land Use Review
Revised 11/10/16 Page 3 of 7
legal lot determination or issuance of a
building permit.
Transfer or sale of properties created in
violation of land division laws is illegal
under state law. If you have purchased
property that is not a legal lot, you may
wish to consult with an attorney to review
your options. In such cases, state law allows
you to rescind the sale or seek damages
from the seller, including the costs of
investigation and legal fees. You may also
discuss possible remedial measures with
county staff.
What if I already bought a parcel of
land that was illegally created?
If your lot is determined to be illegally
created (e.g., through a legal lot
determination application), you may be
eligible for an exception. The county does
provide exceptions to the legal lot approval
process, if certain criteria are met. There
are three types of exceptions that include:
Innocent Purchaser
Public Interest
Public Interest, Mandatory
Public Interest, Discretionary
Innocent Purchaser. The innocent
purchaser exception requires the subject
parcel to meet minimum zoning
requirements currently in effect or in effect
at the time the parcel was created. The
current owner must have purchased the
property in good faith, and did not have
knowledge that the property was divided
from a larger parcel after the following
dates:
August 21, 1969, in the case of
subdivisions.
After July 1, 1976, in the case of short
plats.
After April 19, 1993, in the case of any
segregation resulting in parcels of 5
acres or larger.
Public Interest Exception,
Mandatory. To meet this exception the
following applies:
The parcel must have been created
before January 1, 1995.
Zoning - The parcel must meet the
minimum zoning dimensional
requirements currently in effect,
including lot size, dimensions and
frontage width.
Platting – The improvements or
conditions of approval, which would
have been imposed if the parcel had
been established through platting, are
already present and completed or the
property owner completes conditions of
approval that the planning director
determines would otherwise be imposed
if the parcel had been established
through platting under current
standards.
Types of improvements that may be
required to be constructed by the
property owner include, but are not
limited to, street and sidewalk
improvements and stormwater facilities.
In the urban area, extension of public
water and sewer service may also be
required.
Preliminary and final submittal plans
shall be required where applicable.
Such plans may require a professional
engineer.
Public Interest Exception,
Discretionary. The county may, but is not
obligated to, determine that parcels
meeting the following criteria are legal lots:
Zoning - The parcel lacks sufficient area
or dimension to meet current zoning
requirements but meets minimum
zoning dimensional requirements,
including lot size, dimensions and
frontage width in effect at the time the
parcel was created.
Platting – one of the following must be
met.
Legal Lot Determination Land Use Review
Revised 11/10/16 Page 4 of 7
(a) The conditions of approval which
would have been imposed if the
parcel been established through
platting under current standards are
already present on the land.
(b) The property owner completes
conditions of approval that the
planning director determines would
otherwise be imposed if the parcel
had been established through
platting under current standards.
Types of improvements that may be
required to be constructed by the
property owner include, but are not
limited to, street and sidewalk
improvements and stormwater
facilities. In the urban area,
extension of public water and sewer
service may also be required.
The planning director shall apply the
following factors in making a lot of
record determination under the
discretionary public interest exception.
The parcel size is generally
consistent with surrounding lots of
record within 1000 feet.
Recognition that the parcel does not
adversely impact health or safety.
Recognition that the parcel does not
adversely affect or interfere with the
implementation of the
comprehensive plan.
The parcel purchase value and
subsequent tax assessments are
consistent with a buildable legal lot.
Recognition of legal lot status based on the
public interest exception shall be valid for
five years from the date of legal lot
determination or review in which the
determination was made. If a building or
other development permit is not sought
within that time, the determination will
expire. Applications for development or
legal lot recognition submitted after five
years shall require compliance with
applicable standards at that time.
Note: This handout is not a substitute
for county code. For more detailed
information, please refer to Clark
County Code Section 40.520.010
Legal Lot Determination
Legal Lot Determination Land Use Review
Revised 11/10/16 Page 5 of 7
Submittal requirements
Legal Lot Determination
The following checklist identifies information to be included with the Application. All items
with a bold underlined space (i.e., ___) must be submitted before the application will be
considered Counter Complete. All items with a checkbox must be submitted before the
application will be determined Fully Complete.
1. __ Application form
The Development Review Application form shall be completed and original signed in ink by the
applicant.
2. __ Application fee
The fee for a Legal Lot Determination shall accompany the application. The check is to be made
payable to Clark County Community Development.
3. __ Legal description
A full and complete legal description of the property must be submitted, available from a title
company or surveyor.
4. __ Sales history
A sales history of each parcel since 1969 must be submitted, and shall include the following:
Copies of all deeds or real estate contracts showing previous owners or division for the
original parcel
Prior segregation requests
Prior recorded surveys
Other information demonstrating compliance with the approval criteria
Fee schedule
Legal Lot Determination
The following fees are required to be paid
when the application is submitted.
Legal Lot Determination $350
Each additional lot $150
Issuance $53
Legal Lot Determination Land Use Review
Revised 11/10/16 Page 6 of 7
Submittal requirements
Innocent purchaser exception, public interest exception, mandatory or public
interest exception, discretionary information
The following checklist identifies information to be included with the Application. All items
with a bold underlined space (i.e., ___) must be submitted before the application will be
considered Counter Complete. All items with a checkbox must be submitted before the
application will be determined Fully Complete.
1. __ Application form
The Development Review Application form shall be completed and original signed in ink by the
applicant.
2. __ Application fee
The fee for a Legal Lot Determination shall accompany the application. The check is to be made
payable to Clark County Community Development.
3. __ Legal description
A full and complete legal description of the property must be submitted, available from a title
company or surveyor.
4. __ Sales history
A sales history of each parcel since 1969 must be submitted, and shall include the following:
Copies of all deeds or real estate contracts showing previous owners or division for the
original parcel
Prior segregation requests
Prior recorded surveys
Other information demonstrating compliance with the approval criteria
5. __ Narrative
Requests must include a written explanation of the circumstances surrounding the purchase of
the property that demonstrates compliance with the innocent purchaser criteria. See CCC
40.520.010F).
6. __ Submittal copies
The applicant must select Option A or B below and proceed as follows:
Option A
Submit a CD in PDF format, with a paper copy of the full application package. Any special
studies shall also be included on the CD. The proposed plans submitted must be scanned to an
engineer's scale. The CD shall be organized as follows:
The application submittal shall be organized in the same order as the table of contents, with
a separate PDF document for each separate item.
The PDF document must be organized into separate files. Each PDF file must be labeled
with a number followed by a name (example):
1. Cover and table of contents
2. Application form
Legal Lot Determination Land Use Review
Revised 11/10/16 Page 7 of 7
3. Application fee
4. etc.
Option B
___ One copy of the main submittal package with original signatures, bound by a jumbo clip
or rubber band
___ Five copies of application with a full size set of plans
___ Separately bound copy of any special studies, such as wetland, floodplain, etc., as
identified below:
One original and three copies - Traffic Study and Road Modification requests
One original and two copies of all other special studies or permits to include: Critical
Aquifer Recharge Areas (CARA) floodplain, geo-hazard, habitat, shoreline, stormwater,
erosion control plan, and wetland
___ Two reduced copies of 11” x 17” for all sheets larger than 11” x 17”.
Fee schedule
Innocent purchaser exception, public
interest exception, mandatory or
public interest exception,
discretionary information
The following fees are required to be paid
when the application is submitted.
Innocent Purchaser Exception $883
Issuance $53
Legal Lot Determination $350
Plus per lot over two $150
Plus the proportional share of allocable fees to the
lots in question where the responsible official
determines that additional environmental or plan
submittals are necessary.
Public Interest Exception $3,628
Issuance $53
Fire Marshal $434
In a limited number of cases Development
Engineering review is necessary.
Engineering deposit $200
Issuance $53
Engineering will bill at an hourly rate which must
be fully paid before application is approved or
finalized.