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HomeMy WebLinkAboutCode Consistency Report 146 N Canal Street, Suite 111 • Seattle, WA 98103 • www.confenv.com To: Donna Frostholm, Jefferson County Department of Community Development (DCD) From: Marlene Meaders, Confluence Environmental Company Jesse DeNike, Plauché & Carr Date: May 31, 2024 Re: Code Consistency Analysis for the Rock Island Shellfish Project: Technical Memorandum 1.0 INTRODUCTION The purpose of this technical memorandum is to analyze consistency of the proposed Rock Island Shellfish Project (the Project) with applicable policies and regulations of the Jefferson County Critical Areas Ordinance (Jefferson County Code [JCC] Chapter 18.22) and Shoreline Management Program (SMP) (JCC Chapter 18.25). The Project is a proposal to continue shellfish farming activities on private tidelands in North Hood Canal owned by Robert Carson, the owner of Rock Island Shellfish Company, on Jefferson County parcel numbers 965100009, 965100010, and 965100011 (Figure 1). These privately-owned tidelands have been subject to commercial shellfish aquaculture since the 1950s using a variety of on- and off-bottom cultivation methods. The purpose of the proposed Project is to grow Kumamoto oysters (Crassostrea sikamea) in intertidal waters using a near- bottom culture system called SEAPA® baskets. The proposed Project involves installation, maintenance, and operation of a SEAPA basket system in North Hood Canal between +4 feet to -4.2 feet mean lower low water (MLLW). SEAPA baskets will be stocked with seed oysters and raised to full growth prior to harvesting and selling commercially. The SEAPA baskets will occupy a culture area of approximately 2 acres of a 6-acre site, including 16.5-foot buffers from native eelgrass (Zostera marina) beds. The information below analyzes how the proposed Project is in compliance with relevant Jefferson County policies and regulations. This analysis was requested during the pre- application conference (PRE2024-00005) on March 26, 2024. Ms. Frostholm May 31, 2024 www.confenv.com page 2 of 13 Figure 1. Project site layout. Ms. Frostholm May 31, 2024 www.confenv.com page 3 of 13 2.0 CODE CONSISTENCY ANALYSIS The information below reviews the following Jefferson County Code:  Land Use Districts (JCC Chapter 18.15)  Critical Areas Ordinance (JCC Chapter 18.22)  Shoreline Master Plan (JCC Chapter 18.25) 2.1 Land Use Districts (JCC Chapter 18.15) The upland parcels owned by Robert Carson are zoned as Rural Residential One Unit/5 Acres (RR 1:5). The RR 1:5 Zone is intended to allow for continued residential development in areas of Jefferson County consisting of relatively high density pre-existing patterns of development, along the County’s coastal areas, and within areas within or adjacent to rural centers and rural crossroads. In addition, this district seeks to support and foster Jefferson County’s existing rural residential landscape and character by restricting new land divisions to a base density of one unit per five acres. Aquaculture uses and activities (outside of shoreline jurisdiction) is an approved use of the RR 1:5 Zone (JCC 18.15.040 Table 3-1). However, no activities for the proposed Project within the RR 1:5 Zone are outside of the shoreline jurisdiction. Therefore, there is no further review of land use districts. 2.2 Critical Areas Ordinance (JCC Chapter 18.22) The Critical Areas Ordinance identifies critical areas and provides policies for minimizing and managing adverse environmental impacts from development within or abutting these areas. The Project overlaps with fish and wildlife habitat conservation areas (FWHCAs), wetlands, geologically hazardous areas, a seawater intrusion protection zone (SIPZ), and frequently flooded areas (Zone VE) (Jefferson County 2024). The Project is consistent with the Critical Areas Ordinance, and Project compliance with these critical areas is addressed below. 2.2.1 Article III – Critical Aquifer Recharge Areas (CARAs) and Seawater Intrusion Protection Zones (SIPZs) (JCC 18.22.300 through 18.22.330) The property is not mapped as a CARA but is mapped as a SIPZ (Jefferson County 2024). The proposal is not expected to affect the SIPZ, and the JCC does not require a report for shellfish operations within a SIPZ. 2.2.2 Article IV – Frequently Flooded Areas (JCC 18.22.400 through 18.22.430) The proposed Project will occur within a Federal Emergency Management Agency (FEMA)- mapped floodplain (Jefferson County 2024). The Project is in the process of being approved by the U.S. Army Corps of Engineers (Corps) under the existing programmatic consultation for Ms. Frostholm May 31, 2024 www.confenv.com page 4 of 13 shellfish aquaculture in Washington State (USFWS 2016; NMFS 2016). The programmatic consultation provides measures to avoid and minimize potential impacts to Endangered Species Act (ESA) listed species, designated critical habitat, and essential fish habitat (EFH). Rock Island Shellfish will comply with all terms, conditions, and conservation measures from that programmatic consultation. The Corps approval has been delayed pending resolution of Jefferson County permitting requirements. Rock Island Shellfish is hoping to resolve this issue soon so that it can move forward expeditiously with planting its shellfish crops and removing gear remaining from Sea Garden’s operations. Based on this information, no Habitat Assessment will be required but additional information is needed to provide to the Corps to move the process forward. 2.2.3 Article V – Geologically Hazardous Areas (JCC 18.22.500 through 18.22.550) The shoreline above ordinary high water mark (OHWM) is mapped as a geologically hazardous area (Jefferson County 2024). There will be no clearing, grading, or other ground-disturbing activities above OHWM associated with putting the shellfish aquaculture gear together or other activities associated with the farm. Therefore, no impacts to geologically hazardous areas will occur from the proposed Project and this critical area will not be addressed further. 2.2.4 Articles VI – Fish and Wildlife Habitat Conservation Areas (JCC 18.22.600 through 18.22.660) As defined by the code, FWHCAs are “areas that serve a critical role in sustaining needed habitats and species for the functional integrity of the ecosystem, and which, if altered, may reduce the likelihood that the species will persist over the long term” (JCC 18.22.610). Relevant species that are supported by these FWHCAs were thoroughly reviewed in the Habitat Management Plan (HMP; Confluence 2024). The Project does not result in significant impacts to the surrounding environment and is able to maintain the functions and values of FWHCAs. The only portion of the FWHCA code that resulted in a change from typical conditions identified in the regulatory literature is related to the buffer distance from eelgrass areas. A standard buffer from eelgrass and kelp under JCC 18.22.630(5)(b)(iii) is identified as 22 feet. The buffer deemed conservative to protect eelgrass from shellfish aquaculture activities is 16 feet (Corps 2015; USFWS 2016; NMFS 2016). Effects reviewed by the federal resource agencies to determine an appropriate buffer distance included activities such as mechanical harvest of shellfish and disturbance of sediment that are not part of the proposed Project. There is only a nominal amount of sedimentation anticipated from the proposed shellfish aquaculture gear, as described in the HMP (Confluence 2024). This minor sedimentation is well within the range of natural disturbances and would have no effect on adjacent eelgrass beds. According to JCC 18.22.640(1)(b), a buffer reduction of 25% can be used when appropriate, which would result in Ms. Frostholm May 31, 2024 www.confenv.com page 5 of 13 a buffer of 16.5 feet. This buffer distance is slightly more conservative than standards developed by federal agencies based on a state-wide review of shellfish aquaculture activities (many of which include actions that generate more sedimentation and turbidity than the proposed project). A 16.5-foot buffer is consistent with the policies identified in the JCC, and there are no effects from the proposed Project that would impact eelgrass that would warrant a longer distance. Thus, a buffer distance of 16.5 feet will be used for the proposed Project. Additional requirements identified under JCC 18.22.650 (Habitat Management Reports) are thoroughly addressed in the HMP (Confluence 2024). Compensatory mitigation is not required per JCC 18.22.660 because no buffers were reduced greater than 25%, the Project does not result in impacts to FWHCAs, and the Project will use minimization and avoidance measures (i.e., mitigation sequencing) consistent with the programmatic consultation (Corps 2015; USFWS 2016; NMFS 2016). Therefore, the Project complies with the policies and regulations of JCC 18.22.600 through 18.22.660. 2.2.5 Article VII – Wetlands (JCC 18.22.700 through 18.22.740) The Project site falls within a continuous stretch of estuarine and marine wetland habitat covering 386.87 acres that follows the shoreline from Squamish Harbor north to Port Ludlow (USFWS 2024). This habitat is characterized by having deepwater tidal habitats adjacent to tidal wetlands, presence of ocean water mixing with freshwater runoff, substrate that is flooded and exposed by tides daily, and an unconsolidated shore that has less than 75% areal cover of stones, boulders, or bedrock and less than 50% areal cover of vegetation. These conditions are consistent with eelgrass and macroalgae areas within intertidal marine habitats. A report produced by Marine Surveys & Assessments (MSA) provides details of a survey from June 2023 that complies with the requirements of a special report under JCC 18.22.905 (MSA 2023). The survey reported that the Project site supports a variety of seagrass (MSA 2023). The seagrass bed closest to the shore within the Project site is dominated by dwarf eelgrass (0-613 shoots/m2), which transitions to a mixed bed of dwarf and native eelgrass a few hundred feet into the water (0-1333.3 shoots/m2). At about 500 ft offshore, there is a seagrass bed composed of only native eelgrass (0-128 shoots/m2). Laminaria and macroalgae coverage in the Project site begin about 300 feet offshore and increase with distance from shore in the surveyed area. A cumulative impacts assessment addresses potential impacts to eelgrass and macroalgae, as discussed in the HMP prepared for the proposed Project (Confluence 2024). Therefore, the Project complies with the policies and regulations of JCC 18.22.700 through 18.22.740. Ms. Frostholm May 31, 2024 www.confenv.com page 6 of 13 2.2.6 Article IX – Special Reports (JCC 18.22.900 through 18.22.965) The purpose of special reports is to provide environmental information and to present proposed strategies for maintaining, protecting, or mitigating impacts to critical areas. The special report should:  Demonstrate that the submitted proposal is consistent with the purposes and specific standards of Article IX;  Describe all relevant aspects of the development proposal and critical areas adversely affected by the proposal and assess impacts on the critical area from activities and uses proposed;  Where impacts are unavoidable, demonstrate through an alternatives analysis that no other feasible alternative exists; and  Consider the cumulative impacts of the proposed action that includes past, present, and reasonably foreseeable future actions to facilitate the goal of no net loss of critical areas. Such impacts shall include those to wildlife, habitat, and migration corridors; water quality and quantity; and other geologic or watershed processes that relate to critical area condition, process, or service. An HMP was developed for the proposed Project (Confluence 2024). The HMP is consistent with the requirements identified in Table 1. Ms. Frostholm May 31, 2024 www.confenv.com page 7 of 13 Table 1. Project compliance with special reports per JCC 18.22.905. Code Reference Code Language Assessment (1) When Special Reports Are Required. The administrator may require a special report or reports if any portion of a proposed development or use has the potential to negatively impact a critical area or encroach upon a buffer, and that impact or encroachment requires mitigation, consistent with the standards found in this chapter. An HMP was created for the proposed Project as a special report to address potential impacts to SIPZs, frequently flooded areas, geologically hazardous areas, FWHCAs, and wetlands (Confluence 2024). (2) Standard Requirements. Special reports shall be prepared for review and approval by the administrator. In addition to specific requirements of particular special reports described in this article, each special report shall describe narratively and show graphically, if applicable, the following: (a) The proposed activity, location and dimensions; (b) Existing site conditions and property boundaries preferably on a scaled site plan with structures, features and geographic location described and graphically depicted; (c) All critical areas and their buffers on the project site; (d) Assess potential impacts to critical areas function and values per the specific requirements described in this article for each critical area type; (e) Propose mitigation for unavoidable losses and impacts to critical areas; (f) Identify amount of and limits of clearing, grading, and impervious surface on a stormwater calculation worksheet, if applicable; and (g) Present photographs of the project site. (a) The proposed activity, location, and dimensions are identified in the HMP. (b) Existing site conditions and property boundaries are provided as a figure in the HMP. Features of the site and the geographic location are described in the HMP. (c) Critical areas relevant to the proposed Project are identified on the Project site. The main critical area is eelgrass habitat. (d) An assessment of potential impacts to critical area function and values is provided in the HMP. The primary critical area address is FWHCAs. (e) No unavoidable losses and impacts to critical areas were identified, and so no mitigation was required. (f) No clearing, grading, and impervious surface is proposed as part of the Project. (g) Photographs are provided in Attachment 1 (3) Special reports shall be valid for five years from the date the report was prepared and report validity may be extended by the administrator; provided, critical area conditions, including buffer conditions, have not changed since the special report was written. The administrator shall have the authority to require a revised special report, as needed, to satisfy all the provisions of this chapter. Noted. Ms. Frostholm May 31, 2024 www.confenv.com page 8 of 13 2.3 Shoreline Master Plan (JCC Chapter 18.25) The Shoreline Master Plan (SMP) provides policies for the protection of the shoreline, which includes those areas within 200 feet of the OHWM of designated shorelines in the County or lands within 200 feet from floodways, contiguous floodplain areas, and all marshes, bogs, swamps and river deltas associated with streams, lakes and tidal waters. The shoreline associated with the Project is designated as natural above the OHWM and aquatic below the OHWM. The Project is an allowed use with a shoreline substantial development permit (SSDP) approval, using a Type III permitting process. The Project is within marine waters of North Hood Canal and is regulated by the SMP. As described below, the Project is consistent with the Jefferson County SMP. 2.3.1 Aquaculture (JCC 18.25.440) According to JCC 18.25.440(1)(a), “Aquaculture is a preferred, water-dependent use of regional and statewide interest that is important to the long-term economic viability, cultural heritage and environmental health of Jefferson County.” The Project is in compliance with other requirements and regulations identified under JCC 18.25.440 as discussed in Table 2. The table addresses the code that is relevant to the proposed Project. Because this is an intertidal shellfish aquaculture operation, regulations associated with finfish aquaculture are not discussed. In addition, JCC 18.25.440(6) Regulations – Application Requirements are not addressed in the table. These requirements are noted but have not been requested by the County. 2.3.2 Substantial Development Criteria (JCC 18.25.540) The proposed Project will be planned and carried out in a manner that is consistent with this program and the policy of the Shoreline Management Act as required by RCW 90.58.140(1), regardless of whether a shoreline permit, statement of exemption, shoreline variance, or shoreline conditional use permit is required. 2.3.3 Article V – Shorelines of Statewide Significance (JCC 18.25.230 through 18.25.250) The proposed Project is located below OHWM in North Hood Canal and is identified as a shorelines of statewide significance. The Project will comply with the use preferences identified under JCC 18.25.250. Specifically, state and federal resource agencies, as appropriate, are being consulted and permits and authorizations are being obtained. The proposed Project is a sustainable use of the shoreline and does not deplete natural resources, as described in the HMP (Confluence 2024). The Project will provide long-term benefits to water quality and potentially fish prey resources. Finally, the proposed Project is a water-dependent use of the shoreline that does not significantly interfere with public use or access. Therefore, the Project complies with the policies and regulations of JCC 18.25.230 through 18.25.250. Ms. Frostholm May 31, 2024 www.confenv.com page 9 of 13 Table 2. Project compliance with special reports per JCC 18.25.440. Code Reference Code Language Assessment (1) Policies. (a) Aquaculture is a preferred, water-dependent use of regional and statewide interest that is important to the long-term economic viability, cultural heritage and environmental health of Jefferson County. (b) The county should support aquaculture uses and developments that: (i) Protect and improve water quality; and (ii) Minimize damage to important nearshore habitats; and (iii) Minimize interference with navigation and normal public use of surface waters; and (iv) Minimize the potential for cumulative adverse impacts, such as those resulting from in-water structures/apparatus/equipment, land-based facilities, and substrate disturbance/modification (including rate, frequency, and spatial extent). Policies (c) through (p) are not relevant or are related to County responsibilities. The HMP (Confluence 2024) provides a discussion of how the proposed Project meets the requirements identified for aquaculture projects that should be supported by the County. (3) Shoreline Environment Regulations. The shoreline designation for the proposed Project is Natural above OHWM; Aquatic below OHWM. (b) Aquatic. Aquaculture activities may be allowed subject to the use and development regulations of the adjacent upland shoreline environment. (c) Natural. Aquaculture activities, except for geoduck aquaculture, may be allowed subject to policies and regulations of this program…[other portions of this code are not relevant]. (b) The proposed Project is an allowed use of an aquatic shoreline designation. (c) The proposed Project is an allowed use of a natural shoreline designation. (4) Regulations – General. (a) When a shoreline permit is issued for a new aquaculture use or development, that permit shall apply to the initial siting, construction, and/or planting or stocking of the facility or farm. If the initial approval is a shoreline substantial development permit, it shall be valid for a period of five years with a possible one-year extension. If the initial approval is a conditional use permit, it shall be valid for the period specified in the permit. (b) Ongoing maintenance, harvest, replanting, restocking of or changing the species cultivated in any existing or permitted aquaculture operation is not considered new use/development, and shall not require a new permit, unless or until: (i) The physical extent of the facility or farm is expanded by more than 25 percent or more than 25 percent of the facility/farm changes operational/cultivation methods compared to the conditions that existed as of the effective date of this program or any amendment thereto. If the amount of expansion or change in cultivation method exceeds 25 percent in any 10-year period, the entire operation shall be considered new aquaculture and shall be subject to applicable permit requirements of this section; or (a) The proposed Project is applying for a shoreline substantial development permit (SSDP). (b) Noted. Ms. Frostholm May 31, 2024 www.confenv.com page 10 of 13 Code Reference Code Language Assessment (ii) The facility proposes to cultivate species not previously cultivated in the state of Washington. (c) Aquaculture uses and activities involving hatching, seeding, planting, cultivating, raising and/or harvesting of planted or naturally occurring shellfish shall not be considered development, as defined in Article II of this chapter, and shall not require a shoreline substantial development permit, unless: (i) The activity substantially interferes with normal public use of surface waters; or (ii) The activity involves placement of any structures as defined in Article II of this chapter; or (iii) The activity involves dredging using mechanical equipment such as clamshell, dipper, or scraper; or (iv) The activity involves filling of tidelands or bedlands. (d) The county shall assess the potential for interference described in subsection (3)(c) of this section on a case-by-case basis. All proposed new aquaculture uses or developments shall submit a joint aquatic permit application (JARPA) and SEPA checklist to enable assessment by the county. Activities shall not be considered to substantially interfere with normal public use of surface waters, unless: (i) They occur in, adjacent to or in the immediate vicinity of public tidelands; and (ii) They involve the use of floating ropes, markers, barges, floats, or similar apparatus on a regular basis and in a manner that substantially obstructs public access, or passage from public facilities such as parks or boat ramps; or they exclude the public from more than one acre of surface water on an ongoing or permanent basis. (e) Aquaculture activities not listed in subsection (4)(c) of this section and listed activities that fail to meet any of the criteria in subsection (1)(b) of this section shall require a shoreline substantial development permit (SDP) or conditional use permit (CUP), and shall be subject to all of the following regulations: (i) through (xv). (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 character of those areas are effectively mitigated. (c) Noted. There will be no other activities proposed that would require a new SSDP. (d) A JARPA and SEPA checklist will be submitted to the County for review. No activities that are part of the proposed Project will interfere with normal public use of surface waters as described in the code. (e) The HMP developed for the proposed Project addresses the regulations identified and provide a cumulative impacts and no net loss analysis of ecological functions (Confluence 2024). (f) Noted. Ms. Frostholm May 31, 2024 www.confenv.com page 11 of 13 2.3.4 Article VI – General Policies (JCC 18.25.270 through 18.25.320) The policies and regulations identified in JCC 18.25.270 related to critical areas, shoreline buffers, and ecological protection are addressed in the HMP for the proposed Project (Confluence 2024). The Project will protect and improve water quality, minimize damage to important nearshore habitats, and minimize interference with navigation and public use of surface waters. Overall, the proposed Project in North Hood Canal would result in no cumulative impacts and a no net loss of ecological functions. The policies and regulations identified in JCC 18.25.280 are not required to be addressed at the time of application. If comments are received by the Washington Department of Archaeology and Historic Preservation or the Tribes during noticing that indicates archaeological or cultural resources may be affected, then a report may be required. The policies and regulations identified in JCC 18.25.290 related to public access and navigation were addressed in the HMP for the proposed Project (Confluence 2024). Hood Canal is a relatively deep body of water (88% subtidal), but shellfish aquaculture is predominantly located in shallow, intertidal areas. There are several public access points through state and local parks, marinas, and resorts (Ecology 2024). However, there are no examples of navigational conflicts, even with the U.S. Navy vessels in the northern end. Ensuring communication about culture bed locations and channels helps to minimize potential adverse interactions. Conservation measures, low-profile gear, and responsible farming effectively avoid and minimize potential conflicts. The policies and regulations identified in JCC 18.25.300 related to shoreline setbacks and height are not relevant to the proposed Project. The policies and regulations identified in JCC 18.25.310 related to vegetation conservation, specifically eelgrass and macroalgae, were addressed in the HMP for the proposed Project (Confluence 2024). There will be no effects to eelgrass and macroalgae from the proposed Project because of the avoidance measure of using 16.5-foot buffers between proposed shellfish aquaculture gear and mapped native eelgrass areas based on the MSA (2023) survey. The policies and regulations identified in JCC 18.25.320 related to water quality and quantity were addressed in the HMP for the proposed Project (Confluence 2024). Shellfish aquaculture is recognized for both positive and negative effects on water quality. Most of Hood Canal is considered approved for shellfish harvest activities by WDOH (WDOH 2024), indicating good water quality conditions. Shellfish growers are heavily involved in water quality projects, which creates lasting improvements such as reducing the potential for eutrophication within an estuary. Finally, there are several avoidance and minimization measures identified in the PBA Ms. Frostholm May 31, 2024 www.confenv.com page 12 of 13 (Corps 2015) used to improve and maintain water quality within Washington state. No upland changes will occur as part of the proposed Project and stormwater regulations are not relevant. As described above, the Project complies with the policies and regulations of JCC 18.25.270 through 18.25.320. 3.0 SUMMARY Shellfish aquaculture is a preferred, water-dependent use of Jefferson County shorelines (JCC 18.25.440). The proposed Project is consistent with the policies of the Jefferson County critical areas ordinance and SMP, incorporates effective avoidance and minimization measures, will not result in cumulative impacts, and will result in a no net loss of ecological functions. Standard BMPs and the conservation measures in the Corps (2015) PBA, which the Project will follow, help to avoid or minimize potential impacts, thereby eliminating the need for further mitigation. Consistency with the relevant codes will be accomplished by preparing the Project in compliance with regulatory requirements and by submitting permit applications, site plan, and environmental information for review by the permitting authorities and revising plans per agency direction through an SSDP application process. The Project is an allowed use with a SSDP approval, using a Type III permitting process. 4.0 REFERENCES Confluence (Confluence Environmental Company). 2024. Rock Island Shellfish: Habitat Management Plan. Prepared for Plauché & Carr, Seattle, Washington, by Confluence, Seattle, Washington. Corps (U.S. Army Corps of Engineers). 2015. Programmatic biological assessment: shellfish activities in Washington State inland marine waters. U.S. Army Corps of Engineers Regulatory Program, Seattle, WA. Ecology (Washington State Department of Ecology). 2024. Coastal Atlas - Map | Online Data. https://apps.ecology.wa.gov/coastalatlasmap (accessed on May 3, 2024). Jefferson County. 2024. Public Land Records | Online Map. https://gisweb.jeffcowa.us/LandRecords/ (accessed on May 3, 2024). MSA (Marine Surveys and Assessments). 2023. Carson Habitat Report. Marine Surveys & Assessments, Port Townsend, WA. NMFS (National Marine Fisheries Service). 2016. Endangered Species Act (ESA) Section 7(a)(2) Biological Programmatic Opinion and Magnuson-Stevens Fishery Conservation and Ms. Frostholm May 31, 2024 www.confenv.com page 13 of 13 Management Act Essential Fish Habitat Consultation: Washington State Commercial Shellfish Aquaculture and Restoration Programmatic. NOAA, NMFS, West Coast Region, NMFS Consultation Number WCR-2014-1502, Seattle, Washington. USFWS (U.S. Fish and Wildlife Service). 2016. Biological Opinion: Programmatic consultation for shellfish activities in Washington State inland marine waters. U.S. Fish and Wildlife Service, 01EWFW00-2016-F-0121, Lacey, WA. USFWS. 2024. National Wetlands Inventory | Online Data. https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/ (accessed on May 3, 2024). WDOH (Washington Department of Health). 2024. Office of Environmental Health and Safety | Commercial Shellfish Map Viewer. https://fortress.wa.gov/doh/oswpviewer/index.html (accessed on May 3, 2024).