HomeMy WebLinkAboutSouthard Type III Full Release of 6 year development moratorium,
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 1 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
Before Hearing Examiner
Gary N. McLean
BEFORE THE HEARING EXAMINER
FOR JEFFERSON COUNTY
Application for a “Full Release” from a 6-year
development moratorium set to expire in
December of 2023, originally placed on
property in connection with timber harvest on
the site, which is subject to a Type III quasi-
judicial process before the Hearing Examiner,
submitted by:
CHARLES AND HEATHER SOUTHARD,
Applicants/Property Owners
(Location: a10.3-acre site located inland to the east
of Discovery Bay, south of 4 Corners Road,
addressed as 155 Night Owl Road, Parcel No.
001334021, in unincorporated Jefferson County)
_________________________________
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
File Nos. MLA22-00065 and
FPA2022-00001
FINDINGS OF FACT,
CONCLUSIONS OF LAW AND
DECISION APPROVING
FULL RELEASE FROM MORATORIUM
I. SUMMARY OF DECISION.
The applicants presented a preponderance of evidence establishing that their pending
application merits approval, subject to conditions.
II. BACKGROUND.
There is no dispute that the 10+ acre property at issue in this application is subject to
a six-year development moratorium set to expire in December of 2023, based upon approval
granted to a previous property owner in late 2017 allowing for the harvest of timber on about
9-acres of the site. (Staff Report, page 8). The current property owners, Charles and Heather
Southard, purchased the property in April of 2018, after the timber harvest occurred, and
claim that they were unaware of the development moratorium. In any event, County Codes
allow parties to seek a “Full Release” of such development moratorium through a Type III
quasi-judicial process before the County’s hearing examiner. (See JCC 18.20.160(5)(c)(iii)).
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 2 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
III. APPLICABLE LAW.
As noted above, the applicants’ request for a Full Release of the current development
moratorium placed on their property is subject to a Type III quasi-judicial process, and the
County Code vests the Hearing Examiner with jurisdiction and authority to hear and issue
final decisions on applications for Type III land use decisions. (See JCC 18.40.040,
explaining Project permit application framework, Table 8-1, types of permits, decisions
required, and Table 8-2, showing final decision made by the Hearing Examiner on Type III
land use matters; and JCC 18.20.160(5)(c)(iii)).
IV. RECORD.
All exhibits entered into evidence as part of the record, and an audio recording of the
public hearing, are maintained by the County, and may be examined or reviewed by
contacting the County’s public records officer.
Exhibits:
Staff Report, recommending approval subject to conditions, prepared by Assistant
County Planner Helena Smith, listed as Ex. 1 below, for the Hearing Examiner, with
17 pages, and the following list of other exhibits included in the project file for this
matter:
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 3 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
Testimony: The public hearing for this matter was conducted using an online audio/video
platform coordinated by County staff, accessible to parties and members of the public using
sign-in details provided in public notices. The following persons provided testimony under
oath as part of the record during the open-record hearing held on February 17, 2023.
1. Helena Smith, Assistant Planner, coordinated preparation of Staff Report and primary Staff
representative through the public hearing, for Jefferson County Department of Community
Development. Credibly summarized the review process, key issues analyzed in the Staff
Report, and her recommendation to approve the pending application, subject to specific
conditions of approval, highlighting applicants’ plans to re-forest areas not being developed
with the new home, and how the applicants will comply with the County’s inadvertent
discovery plan during ground disturbance work;
2. Charles Southard, owner of the property at issue, the applicant, accepted the Staff Report
analysis and recommended conditions of approval without any objection or requests for
changes.
No individuals or organizations submitted written comments or testimony before or
during the public hearing in opposition to the pending request.
//
//
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 4 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
II. FINDINGS OF FACT.
Based on the record, and following consideration of all the evidence, testimony,
codes, policies, regulations, and other information included therein, the undersigned issues
the following findings of fact:
1. All statements of fact included in previous or following sections of this Decision that
are deemed to be findings of fact are incorporated by reference into this section as findings
of fact issued by the Hearing Examiner. Captions used in this Decision are for the
convenience of the reader and should not be read to modify the meaning of any particular
finding.
2. The application at issue in this Type III quasi-judicial hearing process is for a “Full
Release” of a mandatory six-year development moratorium placed on the subject property
after a previous owner obtained a Forest Practices Application (FPA) timber harvest approval
from the state Department of Natural Resources (DNR). (Staff Report, page 1, Background
Summary).
3. Under JCC 18.60.160(4)(b), captioned “Mandatory Six-Year Development
Moratorium,” for six years after the date of an FPA timber harvest application, “the county
shall deny any and all applications for permits or approvals, including building permits and
subdivision approvals, relating to or for nonforestry uses of land subject to the application
(RCW 76.09.060(3)(b)(i), (ii), and (iii)).”
4. JCC 18.20.160(5)(c) provides potential relief from the mandatory six-year
development moratorium as follows:
(iii) A “full release” from a moratorium shall be subject to a Type III quasi-judicial process; and
(iv) A release of development moratorium is subject to the following findings:
(A) The person requesting the release did not attempt to avoid the county review or
restrictions of a conversion forest practices application, as evidenced by a transfer of
property;
(B) Critical areas and their buffers, and shoreline area as set forth in this code and the
shoreline master program were not damaged in the forest practice operation, or that any such
damage is repairable with restoration; and
(C) Corrective action can be undertaken to provide for compliance with applicable
conversion standards established by this section.
5. The Staff Report explains that the current landowners, Charles and Heather Southard,
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 5 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
the applicants in this matter, acquired their property on April 4, 2018, after a timber harvest
took place. One of the previous landowners, Daniel Hay, applied for the FPA Harvest
application, which was approved on December 27, 2017. Jefferson County placed a
development moratorium on the property, which expires on or about December 27, 2023,
after receiving notification from the Department of Natural Resources of the approved Class
II (non-conversion class) FPA. On December 19, 2017, Daniel Hay sold the property to
Cedarland Forest Resources LLC, which harvested approximately nine acres of timber. On
April 4, 2018, Cedarland Forest Resources LLC sold the property to current owners Charles
and Heather Southard. It appears as though the applicants claim that they did not know that
the property was under a moratorium – but were notified of the moratorium – at some point
after they purchased the property. (Staff Report, page 8).
6. Any legal claims that the applicants might have related to their lack of knowledge
about the existing development moratorium on their property should not be directed at the
County or any of its agents, but instead the current owners’ title company or seller, both of
whom knew or should have known about the moratorium imposed on the property after
timber was harvested on the site. A mandatory moratorium under County codes and state
law is not a casual matter, and a release from the terms of such moratorium is discretionary,
not a matter of right. In other words, the County is not required to shorten or withdraw an
FPA-related moratorium until such time as its term expires.
7. In this application for a Full Release of the existing moratorium, equitable
considerations, however compelling, true, or viable – including without limitation “innocent
landowner” arguments – are not listed among the applicable approval criteria and do not
provide any basis to approve such request. Washington case law has long established that a
Hearing Examiner only holds specific authority and jurisdiction over matters as specified in
ordinances and resolutions adopted by the local government. The Jefferson County Code does
not grant explicit or implied powers for any hearing examiner to grant equitable relief to
landowners who claim they were unaware of a forestry-related development moratorium until
after they purchased their property. See Chaussee v. Snohomish County Council, 38 Wn.App.
630 (Wash. Ct. App. 1984)(A hearing examiner lacked jurisdiction to consider the issue of
equitable relief; the Court ruled that the Examiner had no discretion to exempt a landowner
from specific code requirements based on possible equitable considerations).
8. Fortunately, for this applicant, the record shows that the applicants can satisfy
applicable criteria for approval, subject to appropriate conditions of approval.
9. The applicants’ property is a mostly unimproved, 10.3-acre site, located inland to the
east of Discovery Bay, south of 4 Corners Road, addressed as 155 Night Owl Road, Parcel
No. 001334021, in unincorporated Jefferson County.
10. The Southards hope to develop their property, which was previously used for forestry
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 6 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
operations, with one single-family residence and associated utilities. (Staff Report, page 6).
11. There is no dispute that such proposed development qualifies as a conversion of land
from a previous forestry use to a non-forestry use.
12. The Staff Report credibly explains that the applicants’ parcel is designated as Rural
Residential (RR) 1:20, with all surrounding parcels zoned either RR 1:5 [one dwelling unit
per five acres] or RR 1:20 [one residential unit per twenty acres]. (See Staff Report, on page
3).
13. As explained in the procedural summary and details provided on pages 3-5 of the
Staff Report, this application has been subject to a thorough review process, with ample
public notice and opportunities for members of the public and relevant agencies to offer
comments. Written comments from agencies received before the public hearing are credibly
summarized and addressed in the Staff Report. The Department did not receive any written
comments from neighboring property owners or other members of the public. No one offered
written comments or testimony at the public hearing questioning or opposing the pending
application. No one submitted evidence or testimony to rebut the analysis and findings in the
Staff Report, which establishes how the pending application satisfies applicable codes and
requirements and merits approval, subject to appropriate conditions.
14. Most significantly, as explained in the unrebutted Staff Report, proposed conversions
of land from forestry to non-forestry use require environmental review under County and
State SEPA regulations. (Staff Report, page 3, citing JCC 18.20.160, re: Conversions of
Land to Non-forestry Use). The original timber harvest occurred under a Class III Forest
Practices Permit (FPA Number 2615192). The current owner requests the area be removed
out of forestry use and converted to a non-forestry use. SEPA review is required for “Lands
that have been or are being converted to non-forestry use,” per JCC 18.20.160(4)(a) and
(b)(i). Consistent with JCC 18.40.780, and in accord with WAC 197-11-355, DCD Staff
followed the optional DNS process. The SEPA Responsible Official issued a Final
Determination of Non-Significance (DNS) on November 29, 2022. No one appealed the
SEPA DNS issued for this application, so the DNS stands as issued for purposes of issuing
this Decision. (Staff Report, SEPA review summary on page 3).
15. The Staff Report credibly explains how the applicants’ request, as conditioned, will
comply with all applicable County Comprehensive Plan goals and policies and County
development codes, including without limitation those addressing Critical Area protections,
stormwater requirements, right to farm and forestry provisions, protection of cultural
resources, and the like. (Staff Report, pages 5-16).
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 7 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
Jefferson County Comprehensive Plan.
16. As credibly explained in the detailed Staff Report, prepared by Assistant Planner,
Helena Smith, this request for a Full Release from the current FPA moratorium is subject to
applicable provisions of the Jefferson County Comprehensive Plan (“Comprehensive Plan”),
including without limitation the following goals and policies that relate to maintaining rural
character and encouraging the continuation of forest practices. Additional findings, derived
from the unrebutted discussion and analysis included on pages 5-7 of the Staff Report, are
included beneath several key Comprehensive Plan provisions addressed below:
A. Continuation of Forest Practices: Encourage the continuation of forestry on lands which are
not designated as commercial forest resource lands (NR-G-5).
Finding: The proposed release is on property that is zoned RR 1:20 and is not zoned as
commercial or rural forest land. The release of the six-year moratorium may be authorized under
JCC18.20.160 to allow a property owner to develop a single-family residence and associated
utilities on land previously used in forestry operations. This proposal to release the parcel from
forestry use will not significantly discourage forestry use, largely because the applicant proposes
to replant and retain approximately 6-7 acres in native plants and commercially viable timber,
which would continue the forestry use on a parcel that is not zoned for commercial forestry.
B. Policy LU-P-7.1: Ensure that land use decisions consider climate change and are based on
land use ordinances that are in compliance with the Critical Areas Ordinance and all applicable
state environmental laws.
Finding: Staff thoroughly reviewed this application for compliance with the County’s
Critical Areas Ordinance (CAO) and the State Environmental Policy Act (SEPA). Ultimately,
Staff determined that the request to lift the moratorium and grant a stormwater permit is consistent
with, or can be conditioned to, comply with the CAO and SEPA. The SEPA DNS was not
appealed and stands as issued. This request, as conditioned, will not result in significant
environmental impacts on the surrounding area, and the proposed residence is to be situated so it
will not be at significant risk from any mapped critical areas.
C. Policy LU-P-7.2: Allow residential, commercial, and industrial development in a manner that
minimizes risk from flooding, earth movement, shoreline erosion, sea level rise, and other natural
hazards.
Finding: The proposed residential development is in a mapped seismic hazard area,
addressed in the applicants’ geotechnical report, which found limited risk from potential earth
movement (See Exhibit 5, geotech report). There is no regulated flood risk on the parcel and the
parcel is not located near a shoreline at risk for shoreline erosion or sea level rise.
D. Policy LU-P-7.11: Continue to ensure that landslide, erosion, and seismic hazard areas are
appropriately designated and that measures protecting public health and safety are implemented
for hazardous areas under the Critical Areas Ordinance. Continue to periodically review and
update CAO regulations relating to geologic hazard areas, including best available science.
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 8 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
Finding: The mapped seismic hazard area was addressed in a 2022 geotechnical report,
so the findings must be recorded in a Notice to Title prior to the county issuing any development
permits on this property. The geotechnical report’s suggestions must be followed as condition(s)
imposed on development permits that may be issued for the applicants’ property, including
without limitation the single-family home and associated structures addressed in the application
materials for this Full Release request.
E. Policy LU-P-8.1: Encourage increased coordination between stormwater requirements of
Forest Practices and Jefferson County stormwater requirements to reduce potential impacts to
off-site residential development, and encourage the preservation of natural drainage systems.
Finding: FPA 2615192 (the approval authorizing timber harvesting on the applicants’
property) was exempt from stormwater review. The proposed conversion from forestry to
residential use was reviewed under Jefferson County Code 18.30.070 Stormwater Management
Standards. The project follows the County’s 2019 stormwater management manual requirements.
Per the engineered stormwater management plan, stormwater from the proposed development will
be treated using downspout dispersion trenches and sheet flow dispersion trenches, both leading
to permanently maintained vegetated flow paths.
Zoning and Protections for Forestry Activities.
17. There is no dispute that the applicants’ proposed residential use is an allowed use in
the zone assigned to the subject property (RR 1:20), subject to expiration of the current
moratorium on the site, or approval of this request for a Full Release of such moratorium.
18. The Staff Report credibly explains that the proposed development of a single-family
residence on the applicants’ property is consistent with allowed development in the RR 1:20
zone that applies to the site and does not prematurely convert the property to a higher
residential density. (Staff Report, page 7). Accordingly, it is consistent with County Code
provisions intended to appropriately buffer areas near UGAs and forest lands, including
without limitation JCC 18.15.015, captioned “Rural Lands.”
19. The applicants’ property is subject to compliance with the County’s codes and
policies that support farming and forestry activities, including without limitation those found
in JCC 18.15.095, captioned “Right to Farm and Forestry Provisions”. Accordingly, this
Decision includes a condition of approval to effectuate this policy. (See Condition No. 10;
Staff Report, analysis and discussion on pages 7-8).
20. Again, the unrebutted Staff Report credibly explains how the pending request for a
Full Release from the FPA development moratorium on the subject property is, or can be
conditioned to be, compliant or consistent with all applicable state and county codes and
policies addressing Critical Areas, Aquifer Recharge Areas, Stormwater Management,
Geologic Hazards, and Grading, among other things. (See Staff Report, pages 10-15;
Conditions of Approval).
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 9 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
As conditioned, the request for a Full Release from the existing FPA moratorium, satisfies
applicable approval criteria.
21. JCC 18.20.160 addresses proposed conversion of land from forestry uses to non-
forestry uses. Subsection 5(c)(iv) of this provision includes specific criteria that must be
satisfied in order to approve a request to grant a release of forestry-related moratorium
imposed on a particular property, such as the one at issue in this matter. Each of the criteria
are listed below, with specific findings provided in italics, based upon the credible and
unrebutted Staff Report issued for this application.
JCC 18.20.160(5)(c)(iv) – A release of development moratorium is subject to the following
findings:
(A) The person requesting the release did not attempt to avoid the county review or restrictions of
a conversion forest practices application, as evidenced by a transfer of property;
Finding: There is no evidence in this record to establish that the current landowners and
applicants attempted to avoid review or restrictions placed upon their property, so this criteria is
satisfied. There is evidence in the record that implies that prior landowners may not have been
candid with the applicants regarding the six-year moratorium that attached to the subject
property as a result of the timber harvest approval issued in 2017. Ignorance of the law is no
excuse. In any event, the applicants submitted this request for a Full Release of the existing
moratorium and appear to have conducted themselves in good faith, following the process and
submitting materials needed to facilitate review of this application.
(B) Critical areas and their buffers, and shoreline area as set forth in this code and the shoreline
master program were not damaged in the forest practice operation, or that any such damage is
repairable with restoration;
Finding: Staff reviewed current mapping resources and identified the following potential
Critical Areas on the subject property: Non-Fish Habitat Stream, Seismic Hazard Area, and a
Susceptible Special Aquifer Recharge Protection Area. Relying on information provided by Ross
Forester, WA DNR Forest Practices Forester, on or about May 1, 2019, Staff determined that
there is no stream on the subject property. The Geotechnical Engineering Report by GeoTest
Services Inc., dated July of 2022, found no geologically hazardous areas or associated buffers on
the parcel. No buffers or mitigation are required for the Susceptible Special Aquifer Recharge
Protection Area. Future development proposals will be subject to a new Critical Area review and
conditions may be added if new Critical Areas are found to exist on the property.
(C) Corrective action can be undertaken to provide for compliance with applicable conversion
standards established by this section.
Finding: The application materials include a proposed Stormwater Plan, reviewed and
approved by the Department. Conditions of approval mandate compliance with all provisions of
such plan, which is included in the Record as Exhibit 6.
The Staff Report (and previous findings in this Decision) establish that the Department
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 10 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
reviewed the pending application proposal in accord with applicable SEPA and Stormwater
management requirements, and all other applicable County codes and policies. As noted above,
the County issued its SEPA threshold determination (a Determination of Non-Significance) for
this application on or about November 29, 2022, in association with the pending stormwater and
full release applications. No one appealed the SEPA DNS, so it stands as issued for purposes of
issuing this Decision.
The applicants’ proposal is required to address stormwater run-off that would occur from
the timber harvest activities and residential conversion. The current landowners are proposing to
develop a single-family residence with associated residential development on approximately 4
acres of the 10.32-acre parcel. They propose to replant approximately six to seven acres with
natural and commercially viable timber. All stormwater management practices will follow Best
Management Practice (BMP) T5.10B Downspout Dispersion. A dispersion trench will treat the
stormwater from all roof areas. The location of the dispersion trench is northeast of the proposed
single-family residence. The splash blocks are on the north side of the proposed shop. The
dispersion trench shall be 17 lineal feet for the single- family residence of 1,666 square feet with
a 25-foot vegetated flow path. The downspout splash blocks lead to a 50-foot vegetated flow path.
A 2-foot wide drainage gravel transition zone with a 10-foot vegetated flow path will address
stormwater from the gravel driveway. All stormwater management work must be consistent with
the 2019 Department of Ecology Stormwater Management Manual for Western Washington.
The proposal must address stormwater run-off that would occur from developing four
acres of the parcel as a single-family residence. All stormwater management practices will follow
Best Management Practice (BMP) T5.10B Downspout Dispersion. The roof areas will be
dispersed via a dispersion trench positioned to the northeast of the proposed single-family
residence and splash blocks on the north side of the proposed shop. The dispersion trench shall
be 17 lineal feet for the single-family residence of 1,666 leading to a 25-foot vegetated flow path.
The downspout splash block leads to a 50 vegetated flow path. Stormwater from the driveway is
treated by a 2-foot wide driveway transition zone to a 10-foot vegetated flow path. Again, all
stormwater management proposals are consistent with the 2019 Department of Ecology
Stormwater Management Manual for Western Washington.
Jefferson County will require additional permits for all future development, including but
not limited to: site development review with legal lot of record determination, septic permits, well
review, road approach permits, and building permits for all proposals. These permits will not be
issued until the moratorium is released consistent with JCC 18.20.160(5)(b).
22. Based on more than a preponderance of unrebutted evidence in the record, including
all findings above, the Examiner finds and concludes that, as conditioned, the pending request
for a Full Release of an existing Forest Practices development moratorium on the Southard’s
property satisfied all applicable approval criteria for such release, including without
limitation those set forth in JCC 18.20.160. Except as modified in this Decision, the Staff
Report’s analysis and explanation of how the pending application complies with such criteria
are incorporated herein as findings of the Hearing Examiner supporting the Full Release from
the development moratorium now imposed on the applicants’ property, subject to conditions.
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 11 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
V. CONCLUSIONS OF LAW.
1. As explained above, the record includes a preponderance of evidence establishing that
the pending application satisfies all applicable decision criteria specified in the County’s code
and merits approval, subject to conditions of approval.
2. Any finding or other statement contained in this Decision that is deemed to be a
Conclusion of Law is hereby adopted as such and incorporated by reference.
VI. DECISION.
Based upon the preceding Findings of Fact and Conclusions of Law, evidence
presented through the course of the open record hearing, all materials contained in the
contents of the record, the undersigned Examiner APPROVES the Type III Full Release from
the mandatory six-year development moratorium imposed on the applicants’ property, now
set to expire in December of 2023, as identified and described in File Nos. MLA22-
00065/FPA2022-00001, subject to the attached Conditions of Approval that are incorporated
by reference as part of this Decision.
ISSUED this 7th Day of April, 2023
_____________________________
Gary N. McLean
Hearing Examiner
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 12 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
CONDITIONS OF APPROVAL
FULL RELEASE
OF FPA DEVELOPMENT MORATORIUM
[FILE NOS. MLA22-00065/FPA2022-00001]
(Location: a10.3-acre site addressed as 155 Night Owl Road, Parcel No. 001334021)
1. This Decision approves and grants the applicants’ pending request for a Full Release
of the six-year development moratorium on the above-referenced property, now set
to expire on or about December 27, 2023, after taking effect in December of 2017
based upon a previous property owner’s timber harvest approval issued under FPA
2615192. All subsequent development activity or use of the site that requires permits
or approvals from the County, State, or other government agencies shall be subject
to reviews, approvals, permits, or conditions, by such entities, and compliance with
applicable development regulations, codes, policies, and ordinances in effect at the
time of such proposal(s).
2. The applicants’ Stormwater Plan, included in the record as Exhibit 6, prepared by the
applicant’s engineer, Rachel Weinberg, has been reviewed and approved by the
Department of Community Development. All development activities on the subject
property shall be in accord with and fully implement the provisions of the approved
Stormwater plan. A Certificate of Occupancy will not be issued for any building
permit until the Department receives a letter from Rachel Weinberg, PE, verifying
compliance with applicable provisions of the approved Stormwater Plan. No clearing
for roadways or utilities shall occur on the project site until clearing necessary for the
installation of temporary sedimentation and erosion control measures have been
completed.
3. A Geotechnical Report by GeoTest Services Inc., dated July 8, 2022, was submitted
in conjunction with this application on July 25, 2022. The report addressed the
stability of the geologic hazard area and is included in the record as Exhibit 5. All
recommendations in the report must be followed. The report was submitted in
compliance with Jefferson County Code (JCC) 18.22.550: Recording and disclosure
for geotechnical reports. Accordingly, the geotech report, Ex. 5, must be recorded
with the Jefferson County Auditor before this Full Release will take effect. The
Auditor File Number (aka recording number) must be submitted to the Jefferson
County DCD, who will then issue a letter confirming the effective date of this Full
Release.
4. The applicant shall replant six acres of the site. The planting shall be completed prior
to building occupancy and the planted trees will be expected to have a 90% survival
at the three-year mark. Monitoring reports will be required to be submitted yearly to
the Jefferson County Department of Community Development for review, and
possible replanting/replacement requirements or corrective action measures imposed
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 13 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
by the Director, to effectuate this condition and assure plant survival objectives are
achieved.
5. The applicant proposed and is approved to treat roof area stormwater with downspout
dispersion, requiring at least a 50-foot vegetated flow path from the downspout splash
block to the downstream property line, and at least a 25-foot vegetated flow path
between the trench outlet and any property line. Sheet flow dispersion is approved
for the driveway stormwater treatment, requiring a 2-foot wide driveway transition
zone to a minimum 10-foot vegetated flow path. The vegetation shall be permanently
maintained to treat stormwater runoff.
6. The project shall adhere to all applicable Best Management Practices (BMPs) to
control stormwater, erosion, and sediment during construction. BMPs shall address
permanent measures to stabilize soil exposed during construction, and in the design
and operation of stormwater and drainage control systems.
7. Fill used in this project must comply with International Building Code standards and
Jefferson County Building Department Requirements.
8. All contractors and personnel shall be familiar with the County’s Inadvertent
Discovery Plan (IDP) that applies to this proposal and all ground disturbance
activities on the subject property, a copy of which shall be maintained in the County’s
project file for this matter. If any possible historic, archaeological and/or cultural
artifacts are inadvertently discovered, the applicant shall immediately stop all work
on the project and shall notify the Washington Department of Archaeology and
Historic Preservation, Jefferson County Department of Community Development,
and affected tribes.
9. All development activities or uses on the subject property shall be subject to
compliance with all applicable local, state, and federal permitting requirements,
statutes, and regulations.
10. Jefferson County has determined that the use of real property for agriculture and
forestry operations is a high priority and favored use in the County. Consistent with
County codes and policies that support farming and forestry activities, including
without limitation those found in JCC 18.15.095, captioned “Right to Farm and
Forestry Provisions”, the County will not consider to be a nuisance those
inconveniences or discomforts arising from such operations, if such operations are
consistent with commonly accepted best management practices in compliance with
local, state, and federal laws. Real property within five hundred (500) feet of lands
designated as Rural Residential 1:10 or 1:20, Rural Industrial, Rural Commercial,
Agriculture, or Forestry, may be subject to inconveniences or discomforts arising
from such farming and forestry operations, including but not limited to noise, tree
removal, odors, flies, fumes, dust, smoke, the operation of farm and forestry
machinery during any 24-hour period, the storage and disposal or manure, and the
application of permitted fertilizers and permitted pesticides. One or more of these
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 14 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
inconveniences may occur as a result of agricultural and forestry operations which
are in conformance with existing laws and regulations.
11. No construction or site development activities may be undertaken on the subject
property until required County approvals become effective, and the County or other
regulatory authorities with jurisdiction issue applicable permits or approvals.
12. The applicant shall comply with all professional report conclusions and
recommendations submitted in connection with this application review, as approved
and/or amended by the County, including without limitation the Geotechnical Report
included in the record as Exhibit 5, and the Stormwater Report and Plan included in
the record as Exhibit 6.
13. The property owner(s) shall be responsible for consulting with state and federal
agencies, and tribal entities with jurisdiction (if any) for applicable permit or other
regulatory requirements. Approval of this Full Release from a development
moratorium does not limit the applicant’s responsibility to obtain any required
permit, license or approval from a state, federal, or other regulatory body.
14. All construction, development, activities, and uses on the subject property shall
comply with all applicable provisions of the Jefferson County Code, whether or not
such provisions are enumerated or referenced in these Conditions or the staff report.
The burden is on the applicant/property owner to show compliance with applicable
provisions of the JCC at every stage of future development.
15. Approval of this Full Release from a development moratorium will not and does
not constitute, nor does it imply any expectation of, approval of any
administrative, quasi-judicial, or other permit or subsequent reviews that may
be required for construction or other activities on any portion of the subject
property.
FINDINGS OF FACT, CONCLUSIONS OF LAW AND
DECISION – APPROVING FULL RELEASE FROM
MORATORIUM – SOUTHARD PROPERTY, FILE NO.
MLA22-00065/FPA2022-00001
Page 15 of 15
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
JEFFERSON COUNTY HEARING EXAMINER
621 SHERIDAN STREET
PORT TOWNSEND, WA 98368
Final Decision,
Request for Reconsideration or Clarification,
Appeal Rights
The Hearing Examiner is authorized to issue Final Decisions for matters listed in JCC 2.30.080(2).
Decisions of the Hearing Examiner may be subject to a request for reconsideration or clarification, by parties with standing
and in the time and manner specified in the Jefferson County Hearing Examiner Rules of Procedure, including without
limitation HEx Rules 6.5 and 6.6.
Final Decisions of the Hearing Examiner are subject to appeal as explained in HEx Rule 6.7, and JCC 18.40.340, which
reads as follows:
(1) Time to File Judicial Appeal. The applicant or any aggrieved party may appeal from the final decision of the
administrator or hearing examiner to a court of competent jurisdiction in a manner consistent with state law. All
appellants must timely exhaust all administrative remedies prior to filing a judicial appeal.
(2) Service of Appeal. Notice of appeal and any other pleadings required to be filed with the court shall be served
by delivery to the county auditor (see RCW 4.28.080), and all persons identified in RCW 36.70C.040, within the
applicable time period.
(3) Cost of Appeal. The appellant shall be responsible for the cost of transcribing and preparing all records ordered
certified by the court or desired by the appellant for the appeal. Prior to the preparation of any records, the appellant
shall post an advance fee deposit in an amount specified by the county auditor with the county auditor. Any
overage will be promptly returned to the appellant.
State law provides short deadlines and strict procedures for appeals and failure to timely comply with filing and service
requirements may result in dismissal of any appeal. Persons seeking to file an appeal are encouraged to promptly review
appeal deadlines and procedural requirements and confer with advisors of their choosing, possibly including a private
attorney.