HomeMy WebLinkAboutM121409
~~ co~
~~~fi
~f~~~~h~
ii!$' ~\
I""' ~ ~ -<,
.) 1
\ ! I
\~ ~J
'''~INqf)/
District No.1 Commissioner: Phil Johnson
District No.2 Commissioner: David W. Sullivan
District No.3 Commissioner: John Austin
County Administrator: Philip Morley
Clerk of the Board: Lorna Delaney
MINUTES
Week of December 14, 2009
The meeting was called to order by Chairman David Sullivan at the appointed time in the
presence of Commissioner Phil Johnson and Commissioner John Austin.
PUBLIC COMMENT PERIOD: The following comments were made by citizens in
attendance at the meeting: a citizen expressed his concern about protecting property owned by the State
Department of Natural Resources which may soon be put up for sale; a citizen stated he feels the County
needs to do economic development planning for Jefferson County; four (4) citizens thanked the Board for
continuing the "Public Comment Period" and expressed the importance of allowing citizens to speak; a
citizen stated that his comment made to the Board regarding possible vandalism to the Courthouse was mis-
quoted in an article in the "Leader" newspaper and that a correction will be published; a citizen presented
the Board with a letter asking ten (10) questions about the rules of procedure for "optional" public comment
period at the Board's weekly meetings; a citizen commented on the work being done by a local property
rights group to increase economic development and urged the Board to support their effort; a citizen stated
that he believes a certain amount of respect and decorum for the elected office of Commissioner is due to the
members; two (2) citizens encouraged those who are critical of the County's economic development effort
to attend Planning Commission meetings and other meetings where economic development is discussed; a
citizen commented that County officials need to follow public records laws to prevent the release of
personal information; a citizen stated that he believes County government censors information and restricts
free speech.
APPROVAL AND ADOPTION OF THE CONSENT AGENDA: Commissioner Johnson
moved to delete item #2 and approve the remaining items on the Consent Agenda as presented.
Commissioner Austin seconded the motion which carried by a unanimous vote.
I. RESOLUTION NO. 78-09 re: Closing County Administrative Offices at Noon on Christmas Eve
2009
2. DELETE: AGREEMENT reo 2010 Community Services Grant Funding; Gardiner Community Center Board
Approved later in Minutes
3. AGREEMENT re: Substance Abuse Treatment; Jefferson County Public Health; Safe Harbor
Recovery Center
4. AGREEMENT Amendment No.5 re: Quilcene-Snow Watershed Implementation Phase Four (4);
Water Resource Inventory Area (WRlA) 17 Planning Unit; Jefferson County Public Health;
Washington State Department of Ecology
5. AGREEMENT re: School-Based Mental Health Services; Jefferson County Public Health; Quilcene
School District
Page 1
Commissioners Meeting Minutes: Week of December 14, 2009
6. Authorization to Proceed with Right of Way Acquisition; Larry Scott Memorial Trail- Segment 4,
Parcel No. 001323019, $23,500; Jefferson County Public Works Project #CR1069; STPE-20l6(015
7. Advisory Board Appointment; Jefferson County Parks and Recreation Advisory Board, Distric~ No.
1; Two (2) Year Term Expiring December 14,2011; Nathanael O'Hara
8. Payment of Jefferson County Vouchers/Warrants Dated November 23, 2009 Totaling $696,691.43
9. Payment of Jefferson County Payroll Warrants Dated December 4, 2009 Totaling $729,696.52 and
AlP Warrants Done by Payroll Dated December 4, 2009 Totaling $562,819.45
COMMISSIONERS BRIEFING SESSION: The Commissioners reviewed their meeting
calendar and discussed various meetings they recently attended. County Administrator Philip Morley noted
that the County received a grant from the Washington State Historic Trust in the amount of $300,000 for
improvements to the courthouse roof.
APPROVAL OF MINUTES: Commissioner Austin moved to approve the minutes of
September 28,2009 and October 5, 12, 19 and 26, 2009 as presented. Commissioner Johnson seconded the
motion which carried by a unanimous vote.
AGREEMENT re: 2010 Community Services Grant Funding; Gardiner Community
Center Board: (Item #2 on the Consent Agenda) County Administrator Philip Morley clarified that the
correct amount of the agreement is $2.850. Commissioner Austin moved to approve the agreement as
corrected. Commissioner Johnson seconded the motion which carried by a unanimous vote.
Washington State Department of Natural Resources County Income Report and
Presentation on Forest Funds: Washington State Department of Natural Resources Acting-Regional
Manager Susan Trettevik reviewed budget and staffing. Since January the DNR has eliminated 479
positions. Ofthose, 223 were funded positions and the remaining positions were vacant due to a hiring
freeze. Of the funded positions, 176 were occupied by employees when they were eliminated. Some
employees retired or taken jobs elsewhere and approximately 75 employees were laid off. The Olympic
region had 124 employees in the 1990's. At the beginning of the biennium there were 104 employees and
now that number is down to 80 plus 6 seasonal employees. The land base to which the DNR is obligated
has not changed so they are having to prioritize and defer certain activities. She reviewed specific impacts
to the Olympic region which include layoffs and reductions in stafftime.
DNR staff has met with local governments, forest land owners and conservation groups about the
opportunity to review the asset management strategy for positioning ofDNR lands in East Jefferson COlmty.
No recommendations have been made to the Washington State Commissioner of Public Lands Peter
Goldmark. There are also discussions taking place with various groups about how parcels can be kept in
forest land even ifthey are not DNR managed forest lands. The East Jefferson exchange remains on hold.
Page 2
Commissioners Meeting Minutes: Week of December 14,2009
This is affecting timber sales because DNR is being asked to wait to harvest timber to allow time to find
ways for the land to be acquired and the value ofthe land is affected by whether or not it is harvested. DNR
representatives are taking the position that until those lands are actually transferred they still have a
responsibility to the Trust which receives the timber sale revenues.
Copies ofthe 3,d quarter County Income Report were provided. Jefferson County lands have generated
$513,425 in revenue and are projected to generate a total of $668,000 by the end of the year. This represents
a decrease of$ll,OOO from what was projected in July 2009. The decrease is probably due in large part to
the net value under contact for harvest in 2010 which is estimated at $15,000. She noted that earlier in the
year DNR was having difficulty selling timber harvest contracts, but, later in the year everything offered was
sold. Prices are also beginning to increase and if the sales and price trends remain unchanged, and DNR
keeps their budget reductions in place, then revenues will go up for the Trust and the Counties. That would
also allow DNR to begin to rebuild their fund account.
Acting-State Lands Assistant Drew Rosanbalm reviewed maps and spreadsheets ofthe Timber Sales Action
Plan for 2010 and 2011. He stated that DNR has sold approximately 1/3 of its volume for fiscal year 2010,
noting that it is typical to sell more volume in the 3,d and 4th quarters. Currently, there are 3 sales scheduled
to take place in Jefferson County in 2010 (1 in March and 2 in June). In 2011 there are also 3 sales
scheduled.
Assignment of Rights and Resolutions for Conservation Futures Easements: 1) Brown
Dairy; and 2) Finn River Farm: Environmental Health Specialist Tarni Pokorny explained that the Board is
being requested to approve 2 resolutions and Assignment of Rights for conservation easements on 2
properties known as Brown Dairy and Finn River Farm which are both located in Chimacum. Both of these
projects involve the purchase of conservation easements to protect these properties for agriculture in
perpetuity. Specifically, approval of the Assignments of Rights will allow the County to execute a purchase
and sale agreement for Brown Dairy and an option agreement for Finn River Farm. Approval of the
resolutions will designate persons \vith authority to sign documents and provide assurance to the State that
the Conservation Futures funding is in progress. Closing on these easements is anticipated for December
23,d. Jefferson County will be listed as the Grantee and the Jefferson Land Trust will be the Co-Grantee.
Jefferson Land Trust initiated these projects through conservation futures funding. Finn River received an
acquisition award of$203,500 in June 2008 while Brown Dairy was granted $77,500 for acquisition in
2009. Conservation Futures funding will provide no more than 50% of the total project cost for each
project. In partnership with the County the Jefferson Land Trust sought matching funds from the State
Recreation and Conservation Office. Jefferson Land Trust also independently found additional funding to
complete the Brown Dairy project.
Earlier this year the County hired Jefferson Land Trust to help carryout these acquisitions which included
hiring subcontractors, drafting easement language, preparing baseline reports and coordinating the overall
process.
Page 3
Commissioners Meeting Minutes: Week of December 14,2009
Sarah Spaeth, Jefferson Land Trust, added that together with the Land Works Collaborative they have been
working on these projects for several years. The fact that the land owners are interested in selling
development rights on these properties is a testament to their interest in seeing these lands remain as
agricultural lands forever. Both the Jefferson Land Trust and the Land Works Collaborative are interested in
seeing that the agricultural community remains a viable part of Jefferson County by providing local foods
and supporting the local economy. She added that Brown Dairy and Finn River Farm are signature
properties. Brown Dairy has a long history of being an active agricultural property which dates back to the
1850's. The Brown family is pleased to know that it will continue that legacy. Finn River is a newer farm
which provides a creative and innovative agricultural use ofthe land and is a great addition to the
community.
Commissioner Austin moved to approve the Assignments of Rights for Finn River Farm and Brown Dairy
projects. Commissioner Johnson seconded the motion which carried by a unanimous vote. Commissioner
Johnson moved to approve RESOLUTION NO. 79-09 in the matter of purchasing a conservation easement
on the Finn River Farm in Chimacum and designating persons with authority to sign documents, and
RESOLUTION NO. 80-09 in the matter of purchasing a conservation easement on the Brown Dairy Farm
in Chimacum and designating persons with authority to sign documents. Commissioner Austin seconded
the motion which carried by a unanimous vote.
Adoption of the 2010 Budget: County Administrator Philip Morley explained that a public
hearing was held on the 2010 budget on December 7, 2009. He reviewed corrections and presented an
updated recommended budget and budget resolutions for consideration.
After review, the Board unanimously approved the following resolutions.
RESOLUTION NO. 81-09 in the matter of adoption ofthe Annual Budget, Including the General Fund,
Public Works, Special Funds and Jefferson County Road Construction Program.
RESOLUTION NO. 82-09 in the matter of adopting a salary schedule for the FLSA and Union Exempt
Management and Professional Employees for 2010.
RESOLUTION NO. 83-09 in the matter of establishing new salaries for the elected offices of Jefferson
County.
RESOLUTION NO. 84-09 in the matter of continued workweek reduction in 2010 for specific County
departments.
Page 4
Commissioners Meeting Minutes: Week of December 14,2009
CONTINUATION OF HEARING (Continuedfrom December 7,2009) re: Port of Port
Townsend Rezone; MLA09-00077: Associate Planner David Wayne Johnson noted that at the conclusion of
the hearing on December 7th the Board directed staff to follow-up with State DOT representatives regarding
any concerns they might have regarding traffic impacts by this proposal. He read an e-mail from Dale
Severson with the DOT (see permanent record) which confirms that they do not have any objections to this
rezone application.
Chairman Sullivan opened the hearing for public testimony.
Larrv Crockett. Port of Port Townsend Manager submitted a letter responding to the comment letter from
the City of Port Townsend (See permanent record). He reminded the Board that the next step upon approval
would be a binding site plan for which the Port is in the process of getting federal grant money and will be
subject to a public process including hearings. The citizens of the community and adjacent property owners
will be involved and have an opportunity to comment before a plan is submitted to the Connty for approval.
In addition, every permit will be fully vetted.
Carolvn Lake. Attornev. Goodstein Law Group submitted a letter responding to the comment letter from the
City of Port Townsend. (See permanent record)
Bob Sokol. Port Townsend stated he is a former Port Commissioner and a former member of the Port
Townsend City Council. He urged the Board to adopt the 24 acre zoning for the Jefferson County
International Airport as soon as possible. The addition of up to 100 good industrial jobs in Jefferson County
must be of the highest priority in light of the current national and local economies, potential loss of the paper
mill, and the shortage of funds for County operations. It is time to move forward with this project. He also
submitted written comments. (See permanent record)
Joe Daubenberger. Port Townsend stated that he is against this upzone. The Growth Management Act
(GMA) went into effect in 1999 and down zoned a lot of commercial property and industrial property along
Four Corners Road, Rhody Drive and Glen Cove Road. To consider an upzone before the County considers
a rezone of property that was taken in 1999 would be an injustice for the taxpayers. This property was not
purchased by the Port until 2002 which is after the GMA was in place. There is an argument that this will
be an essential public facility for the Fire District. The Fire District, as an essential public facility can be
located virtually anywhere. He thinks it would be appropriate for the private sector to have an opportunity
to provide a location for the Fire District before it is given to the Port. The Port and all governmental
agencies including the City, County and State are competing with the private sector for leased properties.
The State has a woodworking school that could be located in Glen Cove. The Port has a number of
businesses that are not marine related and should be located in Glen Cove or the business park. Many
individuals in the private sector have paid taxes for commercial and light industrial property for many years
and that zoning was taken away from them. He added that he doesn't own any property that would benefit
from a rezone and he has nothing to gain.
Page 5
Commissioners Meeting Minutes: Week of December 14,2009
David Timmons. Port Townsend City Manager stated the City Council has directed him to express concerns
about the process of resolving this matter. He thanked the County Administrator and Port Officials for their
efforts in trying to achieve a consensus on this issue. He is not an expert on the Growth Management Act
(GMA) or this process so he relies on his experts to advise him on what is permissible and what is not. He
is an expert on economic development and has been in working in that field for 33 years. He gained
experience from past recessions and believes that rezoning land is not the answer to economic development.
There needs to be a plan and a market and needs assessment. From the City's perspective it is believed that
we need to stop and take the time to develop a comprehensive strategy and finish what we started. The
Hovee Study was done and began to address the needs, but never came to any final conclusion in terms of
specific needs and costs to develop the infrastructure to support those needs. That is a reasoned approach
and is supported by a variety of policies at the County, Port and City level.
A meeting was held recently between the City and County and one thing that came out of that meeting was
that we need to figure out how we can achieve a comprehensive solution and goal to work together toward
economic development. Of particular concern is the policy framework and that this process reflects little
incremental changes and decisions like a study he once read titled "The Art and Science of Muddling
Through". At one time we looked at possibly doing an Urban Growth Area (UGA) for the airport and that
didn't work. We couldn't do a stand alone Limited Area of More Intense Rural Development (LAMIRD).
Then we tried to look at a Major Industrial Development (MID) or an industrial land bank. Each of those
met a certain amount of resistance. Nobody is objecting to appropriate development of the airport. That is
why the City has been a party to these planning processes. The City would however, object to inappropriate
development of the airport. As this proposal is being characterized, some of the types of uses he thinks are
inappropriate based on the method that is being used to get those uses permitted. In this case, the proposal is
to expand the airport as part of the Essential Public Facility and then allow industrial uses to take place so
long as the only nexus is a financial nexus. The City does not feel that is appropriate or acting in the spirit
of developing an overall comprehensive assessment in partnership with the Port, City and County which
could potentially result in 500 jobs instead of 100 jobs. If the zoning as approved is modified and
conditioned so it is consistent with GMA, the City has no objection. It is the loosely defined interpretation
of that restriction that the City objects to.
He submitted and read the following City's draft language for a proposed condition ifthe rezone is
approved: "All uses, including any proposed non-aviation related light industrial uses, established within the
expanded Jefferson County International Airport Essential Public Facility (AEPF) district shall functionally
relate (i.e., be "primary" uses) or directly support (i.e., be an "accessory" use to) the operation ofthe airport.
Additionally, airport related uses may include light industrial and manufacturing uses that are airport
dependent (e.g., air and/or package delivery); dependent on overnight shipping (e.g., laboratories); and
similar uses." This would be an interim point until a more comprehensive study was done to determine if
other uses could be put there. (See permanent record)
Rick SeDler. City of Port Townsend Planning Director said that looking at the face of the application it looks
very compelling as 100 jobs are essential to the community. The City supports the creation of 100 jobs, but
the question is where? As compelling as it is, it needs to be developed with a sound basis. What is the basis
for 100 jobs? There is no assurance with those numbers.
Page 6
Commissioners Meeting Minutes: Week of December 14, 2009
Many uses have been put into the record for this site and it is confusing to try to understand what types of
uses are most appropriate and what uses would likely be sited there. We have heard there will be
warehouses with about five bathrooms. There is no assurance in the code that says that will be the outcome.
We have heard it might be an eco park and the press has quoted Port Commissioners and staff as saying it
may include solar manufacturing and a green park to do green energy and green development. However, in
the application there is no specific reference to any business and the Port has actually cited that it has not
agreed to any of those types of uses at this point. We heard at the last meeting that Lady Farmers might be
able to come and do agriculture uses on the site, or storage. lt might be good to ask the farmers if that is a
good site. It is his understanding from working with the Coop that they would prefer to have it on their own
farmland because the trucking costs make it very difficult for them to work at a centralized site. What about
marine related uses? Are they ok? Should uses from the boat haven be allowed to relocate to the airport?
He is certain it would be less expensive and probably more efficient next to two highways. But, would that
seriously erode the economic viability ofthe Port's property?
He knows the Port is going to say that they do not intend to do any of those things and that it wouldn't
disrupt it. He doesn't doubt that this group of individuals would try not to do that. However, we have no
assurance in the use table that is provided or in the project that is proposed, that anything would be off limits
for that site. Additionally, both the County's and Port's adopted plans refer to the development of design
standards which need to be put into the Uniform Development Code to ensure that uses which go onto the
site are compatible with surrounding uses. This is not done at the project level. A binding site plan
application does not let you go back and modifY your legislative code. That should be accompanying this
application. We should be discussing this now and those protections should be in place.
The City thinks that this application might be in the public interest, however it is premature and
inappropriate at this time. In order to be in the community interest we need to look at part of a coordinated
strategy that directs appropriate uses to the right places. Some uses are great by the boat haven, some are
perfect in Glen Cove and to be fair, some really belong by the airport. The City suggests that the agencies
get together and quickly determine where our eggs should be placed, rather than saying anything can go just
about anywhere.
Stenhen DiJulio. Attornev. Foster Penner. PLLC represents the City of Port Townsend and submitted
additional written comments and materials. He noted the zoning map of Port Townsend identifYing areas
for commercial districts and marine and manufacturing areas. Recent aerial photographs are also being
submitted which show mixed commercial and light manufacturing areas and demonstrates existing vacant
lands available for this purpose within Port Townsend. This proposal is to simply place an industrial land
classification on rural property. The central theme behind the Growth Management Act (GMA) is that
spontaneous and unstructured growth and development is wasteful of our natural resource base and costly in
the provision of public services and facilities. By managing growth and development the negative effect can
be minimized and benefits can be maximized. The GMA is built on the principle that cities, counties,
special purpose districts, and those agencies or jurisdictions involved in the delivery of public services will
coordinate their efforts consistent \\lith each other and the provisions of the GMA. These words he just
Page 7
Commissioners Meeting Minutes: Week of December 14,2009
spoke are not his, they are from the County-Wide Planning Policies. The call for coordination between
cities, counties and special purpose districts is not his argument, but rather is the County's own policy for
addressing these kinds of issues. He emphasized the provisions of County Ordinance # 16-1213-04 that call
for a process for consideration of what would happen at the airport. Not just on these 24 acres, but within
the airport generally.
The County is proceeding to simply put an industrial land designation on rural land without any
consideration of land capacity and demand and without finalizing the Hovee study that this jurisdiction and
its partners were engaged in earlier. The Port will enter a market already at risk and will be competing with
the private sector. That aspect is in contravention of the County's own planning policy. Specifically,
County-Wide Planning Policy #7.1 which reads "The private sector is primarily responsible for the creation
of economic opportunity in Jefferson County". The only difference in this application from any other
application for industrial development in a rural zone is that the property is owned by the Port of Port
Townsend. Any citizen can make the same argument that this area should be rezoned for industrial
purposes. What is not in dispute under this application is that we are not talking about an Essential Public
Facility, we are not talking about an aviation related facility, it is not within the fence as has been clearly set
forth in the materials and it is not subject to FAA regulation. Any land that the Port purchases should be
under the airport Essential Public Facility (AEPF) and not rezoned because it wants the [mancial
wherewithal to support the airport. The GMA provides that property should support the Essential Public
Facilities, not be used as some economic model to fund money to it. Any property that would funnel money
to the airport should be considered part ofthe AEPF.
The City has already expressed support for the finalization for a needs and market analysis regarding
industrial development in this community. It is a strategy that all 3 jurisdictions (County, City and Port)
should be engaged in. The City is not saying "no" in it's consideration ofthis matter. The City is saying
that the answer in this particular case is that until the study is done, to simply put an industrial land
development designation on this 24 acres is inconsistent with the County's own planning foundation
regarding industrial development in association with the AEPF.
The area south of the airport is currently located outside of the AEPF and only the 24 acre parcels is being
proposed for rezone. Under the Port's analysis, to buffer the airport from incompatible uses, what is to
prevent anybody else from coming along and making a proposal for industrial development in that area?
Why isn't that property located south ofthe airport any better suited to buffer the Port property than this 24
acres, and why is the Port different from a private property owner in that regard? The Port is saying they are
going to do more studies and the Department of Transportation wrote that they will wait and see what the
actually project is. But by approving this application the Board is opening the door to expansion of a
industrial designation without doing the analysis, study or planning that the County said it was going to do
when it adopted its ordinance in 2004. The City is not opposed to consideration of certain industrial uses at
the airport. But the foundation work needs to be completed. He requested the Board defer action on this
application until that study has been done. There is no penalty and nothing to prevent the County from
considering this further. Do the analysis in the first quarter of20l 0 to be sure that the County is making the
right decision and not jeopardizing the fundamental planning that has been laid out for the County. (See
permanent record)
Page 8
Commissioners Meeting Minutes: Week of December 14, 2009
Carolyn Lake. Attornev. Goodstein Law Group represents the Port of Port Townsend and stated that GMA
downzomng of commercial and industrial property is all the more reason to support this proposal which
provides an opportunity for economic growth where it can be legally located. The Port as a municipal entity
is not in competition with the private sector. The Port is a conduit for the private sector economic growth
and the private sector would benefit by this proposal if adopted. This proposal does precisely as envisioned
in the County's adopted Comprehensive Plan which was adopted in 2004 and has been under study since
that date.
She reviewed the submitted information from the legal counsel for the City and it appears to have 2 central
themes. First, it concedes that the Port in fact does have the authority, if the proposal is granted, to carryout
the uses the Port is requesting to be located there. Second, it makes policy arguments against the proposal.
She pointed out that it does not contain much legal analysis and noted that the policy choices are for the
Board to make and not lawyers. The City's legal counsel took time to restate what he believes to be the
Port's arguments in favor of this proposal. The Board heard the Port's arguments and the arguments as
restated by the City's legal counsel are not the Port's arguments. What was significant by its omission, is
that there was no citation or pointing to any authority, no legal criteria, no legal case, no legal statute cited
by the City's legal counsel that would prohibit the Board from moving forward with this opportunity for
economic growth. It brings to mind the adage that we should not set aside what is possible today in favor of
what might be a perfect future.
They stand by their conclusion which was made and presented in the previous hearing before the Board.
Those conclusions are continued in their written remarks which state that the proposal is consistent with
State law protections for Essential Public Facilities and for airports and is consistent with past actions of
Jefferson County. They disagree with the characterization that this analysis was muddled through, when in
fact the analysis was considered and thoughtful. There are no legal prohibitions on the expansion of the
Essential Public Facility to add supporting and complimentary uses to the regional airport uses. They urge
the Board's adoption of this proposal which is consistent with State law and gives the needed support for the
Port's State mandated mission for economic growth and job creation. (See permanent record)
Joe Daubenberger. Port Townsend stated that the properties which were downzoned in 1999 were taken
from the private sector and now we are considering giving it back to a public entity. That is what he
disagrees with. Ifhe owned the property next door would he get the same consideration for an upzone?
Joe D' Amico. Fort Discoverv said that he thinks the Board ought to approve this proposal. It is a great plan
and he thinks it will open the door for Fort Discovery to rezone some property industrial. He supports the
Board on a decision to approve this application.
Larrv Crockett. Port of Port Townsend Manager stated it is interesting to listen to other people put words in
your mouth that were never spoken. If you read the Port's letter that was submitted today, it will be
abundantly clear. Having been involved in this project for a decade, it bothers him personally that it is being
Page 9
Commissioners Meeting Minutes: Week of December 14, 2009
referred to spontaneous. This is not a spontaneous effort. Weare not talking about spontaneous growth.
The 1971 Airport Master Plan discusses economic growth in and around the airport. The 1994 Airport
Master Plan involved a public process with both the City and County, and specifically called out this parcel
to be purchased for future economics. The 2002/2003 Airport Master Plan clearly identifies this parcel for
future light industrial use.
Throughout this process the County, City and Port have been working together on this project and nobody
has ever protested, objected or appealed any ofthese efforts or ideas. He agrees that it is the private sector
that drives the economy. It is the private sector that is going to develop these parcels, not the Port. The Port
is simply going to put in the infrastructure like any government should be doing. The entrepreneurs need
places like this because they don't have a million dollars to buy 20 acres in the City to build anything. They
need the ability to get their feet under them and then buy parcels in Glen Cove or the City.
This effort has been cooperative and consistent with the County policies. By law, under the FAA mandate
the Airport Master Plan has to be consistent with the County's policies. Every step of the way has been
cooperative. There will be penalties for a delay because there are families that need jobs now and in the near
future.
Bill Miller. Port Townsend stated that he supports this process of changing the land itself. The Planning
Commission voted to change the zoning category. Anything that is built there will have to be reviewed by
the Planning Commission and go through the public hearing process to see ifit is appropriate. This is not
about approval of any buildings. It is about approving the potential. This is the time we need to start
building potential and he would appreciate it if the Board would support this proposal.
David Timmons. Port Townsend City Manager clarified his previous testimony and explained that it was not
a criticism, it was basically an observation of what he sees as a process that has been haunting the County,
City, Port and PUD because we take things on incremental. When Gordon Lindblom wrote the article "The
Art and Science of Muddling Through" he talked about the government decision making process and how it
goes based on the "root and branch" method. It continues to go along until it meets some type of impasse or
resistence and then it modifies and redirects itself. That is what we have been doing with our entire
economic strategy. For the decade that he has been with the City there has never been a coordinated effort
that really is a unified strategy that we all agree with. The City's concern about this is that it is putting the
cart before the horse. The policy is saying this is what we should do, but it is not asking if we should do it.
That is what is written in the County's own ordinance where it says you need to do this analysis first to
determine how to get this done. He thinks before this is implemented, the County should go back and
review that ordinance and ask if that analysis has been done.
The Airport Master Plan reads "Development of the property owned or acquired by the Port south of the
runway should be utilized for rural level development activities that directly or indirectly support the
operation of the airport as a self sustaining economic enterprise. This will not only reduce or eliminate the
need to operating subsidies, but will promote more compatible land uses and provide for further economic
development opportunities in the County. Future development plans should include provisions for
Page 10
Commissioners Meeting Minutes: Week of December 14, 2009
additional hangar space as well as job generating, light manufacturing industrial uses that generate revenues
to support airport operations. All development activities must be rural in character only requiring rural
levels of service and must comply with FAA safety requirements for height, lights, smoke, etc. All
supporting development activities must also comply with the provisions of the Jefferson County
Comprehensive Plan, Unified Development Code. A strict set of design standards shall be adopted to insure
compatibility with surrounding land uses and to further visually screen the low profile buildings." We
haven't received that information so we don't know what we are buying into to. The City is asking that this
information be compiled and tied into a broader economic strategy so they can help promote economic
development in the County.
Eric Toews. Cascadia Community Planning Services Consultant representing the Port of Port Townsend
clarified that what Mr. Timmons has read and outlined is precisely what the Port is proposing. It is for rural
light industrial use adjacent to the airport to help the airport be a more self sustaining enterprise. From 1988
to the present approximately $7 million in federal taxes have been expended to support infrastructure
improvements at the airport. This rezone, if approved and after development of a binding site plan and
private enterprise development of those created lots, will help reduce the Port's current operating deficit and
make the facility more self sustaining.
The standards that Mr. Timmons cites are in fact contained within the proposal. The proposal would
significantly reduce the amount of development coverage within this industrial area as compared to any
other industrial area located within Jefferson County or the City of Port Townsend. This project proposes
twenty-five percent maximum impervious surface coverage, thirty-five foot maximum building height, ten
thousand maximum square foot building sizes, stripped vegetative buffering and screening requirements as
well as the mandate that all future development utilize low impact development techniques. He thinks there
is a basic difference of opinion as to whether or not the prerequisite studies have been completed and
whether or not this complies with the process outlined in the Airport Master Plan and the County's
Comprehensive Plan. They would forcefully argue that it does comply and that the Port's proposal is
explicitly what was envisioned in both the Airport Master Plan and County's Comprehensive Plan
amendments in 2004.
John Watts. Port Townsend Citv Attornev stated that the Board has options. This is a legislative decision
and the Board is not required to approve this proposed rezone. If the Board does approve it there are options
in how it might be approved. There is no legal requirement for this matter to be adopted today or by the end
of the year. It can be carried over into the following year. It can be sent back to staff or the Planning
Commission for further analysis. Additional time might allow the parties to come to some understanding
that provides a compromise or possibly a MOD. He commended the County Administrator for attempting to
bridge the differences, but he feels more time might allow those differences to be further explored and
possibly even reconciled. The crux of the differences are very simple. The Port wants to be essentially able
to do any light industrial use on the proposed rezone area. The City seeks some limitations that might come
out of a study that would identifY appropriate uses for the airport given the needs throughout the County.
The City is also concerned about undermining the investment made by the City to develop light industrial
zoning in the City. We also heard today that the proposal might undermine the efforts of the private sector
Page 11
Commissioners Meeting Minutes: Week of December 14, 2009
in both the City and County. The Port's proposal is a speculative rezone. There are no uses or pending uses
seeking to locate on the site. This is not a rezone to accommodate a particular owner who wants to develop
a business. It is also speculative in terms of what it promises. As has been pointed out, there is no analysis
or study upon which to support or base a conclusion that this will provide 100 jobs. There is no basis to
support a conclusion that the proposed uses are going to be eco-friendly. There are no restrictions in the
proposed development regulations that would limit the uses to eco-friendly or say how they would be any
more eco-friendly than any other use that develops anywhere in the County that has to meet stormwater
requirements and buffering requirements.
He urged the Board to indicate that it would like to see a win/win/win in this matter, similar to what a Judge
does in a civil case before making a ruling. He believes this would benefit everyone and he urged the Board
to take more time to do an analysis to study the positive and negative impacts of this proposal. The City is
willing to participate in such a study both with staff resources and funding. He commented that it has been
stated that this is a programmatic rezone and that it will eventually result in a binding site plan. But, the
uses that would be allowed by the binding site plan are being determined today, in the sense that if you don't
limit the uses, then any use can be allowed under a binding site plan. This is not an Essential Public Facility
rezone in the sense of GMA saying that these certain uses trump local zoning and can be allowed even if
local zoning attempts to interfere with them. This is simply light industrial that is being brought in under the
framework of an Essential Public Facility, but it is not the kind of Essential Public Facility that is sanctioned
or under the protection of GMA.
Bill Marlow, Port Hadlock urged the Board to adopt this proposal today and not study it any longer. He has
participated in various planning meetings since 1988 to do more studies and more analysis and it has been
20 years already and the arguments are the same. The City talks about cooperation, but he can think of a
number of different instances where the City has sued the County and that is not the kind of cooperation the
County needs. Adopt the proposal as soon as possible.
Joe Daubenberger. Port Townsend stated that he is a developer and he has a pretty good idea how this
process works. He knows that there has not been any proforma done on this application. He has not
examined it, but today he is hearing talk about 8 sites, 10,000 square foot buildings and market rate. It will
be about $50 per square foot to build. That is $4 million, not counting the land. There will also be ground
work, septic systems, power and a lot of other issues that will come into play. Revenue from rent will bring
in approximately $32,000 gross at $.40 per square foot, which today you can't get.
There are a number of buildings at Glen Cove that are vacant. Specifically, there is a 6,000 square foot
warehouse that has been vacant for almost 2 years. The payment on $4 million at 5% interest, ifthey're able
to get an interest rate that low, will be approximately $4,300 per month. Without hardly any analysis, this
project will be upside down.
The private sector who pays the taxes to subsidize these projects and also has buildings to rent that are
vacant, will be competing against the market rate. When the Port is unable to get the $.40 per square foot,
they will rent it for $.30 per square foot because they have to get it rented. Then the private sector will be
Page 12
Commissioners Meeting Minutes: Week of December 14,2009
paying for it. You can talk all day long about how there is no competition with government, but there are
already many government buildings out there, such as Mountain View, that the private sector is competing
with. This doesn't work and it doesn't take very much analysis to figure it out. Give the zoning back to
Glen Cove.
George Yount. Port Townsend stated that this has been an interesting dialogue. He asked why this wasn't
discussed by all these parties 30 years ago when he was involved with the airport development? None of
these arguments were given. The mission of the Port is to provide incubator facilities to allow businesses to
develop and then to move on. He thinks this is the kind of activity that will happen here and he urges the
Board to support the rezone.
Bob Sokol. Port Townsend stated when he was a City Council-member he voted yes for the industrial park
located off of Sims Way. The proposal at that time was for office space only to support the industrial
businesses located there. If you drive through there today you will find a storage facility, dental office,
insurance office, a locksmith, a title company, and Jefferson Mental Health. That area is no longer an
industrial park. As a matter of fact, it is referred to all the time as the business park.
Another one of the requirements he voted in favor of was that at a certain buildout level the developer would
put in a stop light on Sims Way. The estimate at that time in the early 1990's was $250,000. Since that time
the opportunity has been there for that to develop into an industrial park, but it hasn't. Instead it has grown
as a business park. He is not saying it's not a good use ofthat property, he is saying that the industrial
nature of the park has totally changed.
One of the things about renting and occupying Port property that people don't understand is that tenants pay
a leasehold excise tax which is 12.85% of the rentable value of the property. It has nothing to do with the
amount of the rent, only the rentable value. The airport hangars are a good example of how public agencies
and the private sector can work together for the benefit ofthe County. For the most part the hangars are
privately owned. A group of eight hangars are similar to a condominium which sit on land that is rented.
The value of the hangar itself is directly taxed as property. This would be the same for any other
development that were to take place at the airport.
Nowhere in the plan does it say that if this is approved today that there will be ground breaking tomorrow.
But, if you don't approve it today there can't be ground breaking at all and this could be put off indefinitely.
The argument to say let's put this off is very "Port Townsend", but it is not very efficient or practical. He
has been involved in economic development for many years and in the time that he has been here there is
virtually nothing to show for what the Economic Development Council has accomplished. There have been
some programs to help people run a business, but the number of jobs created or saved is really hard to
quantifY. He urged the Board to take the first step in this process and approve the rezone.
Jim Pivamik. Port of Port Townsend Commissioner stated that the best example of economic development
in our County is the boat haven. The boat haven does not have a single square foot of available rentable
space. That model was built upon the same model currently being discussed which is the Port putting in the
Page 13
Commissioners Meeting Minutes: Week of December 14,2009
infrastructure to allow businesses to survive and expand. Now with Glen Cove with 20% occupancy and the
boat haven and Point Hudson fully occupied, some would dispute that the Port is undercutting the private
sector. He says the Port is charging market rate. The value of government providing infrastructure in a
central area to provide job creation and growth is a very important element that we do not have in the
County right now.
Hearing no further comments for or against the proposed airport rezone MLA09-00077 submitted by the
Port of Port Townsend, Chairman Sullivan closed the public hearing.
The Board agreed to review the testimony and discuss this matter further at a later date. After discussing
potential dates for scheduling a special meeting, Commissioner Johnson moved to schedule a special
meeting on Tuesday, December 15,2009 at 5:00 p.m. in the Commissioners' Chambers to continue
deliberations and possible decision on the airport rezone application submitted by the Port of Port
Townsend. Commissioner Austin seconded the motion which carried by a unanimous vote.
COUNTY ADMINISTRATOR'S BRIEFING SESSION: County Administrator Philip
Morley reviewed the following with the Commissioners:
. Treasurer's Software Conversion
. Discussion of 20 I 0 Work Program
. Calendar Coordination
. Miscellaneous Items
NOTICE OF ADJOURNMENT: Commissioner Austin moved to adjourn the meeting at
4:44 p.m. until the special meeting scheduled for 5:00 p.m on Tuesday, December 15,2009. In the absence
of Commissioner Johnson, Chairman Sullivan seconded the motion. The motion carried.
MEETING ADJOURNED
, i to- 'of \1 ........
, . _l,..>~
' , 1" "';".',
SEAL:, '. . 5 f · '-':'l "#\::\
~';~t ,,~~;,~~ I' \~:
"'"..." ' ,-,.",..,' .. . ,
~'{. . ( ,'"V.~ . :'j}~'j
'. -'. ", .. .. "j..1...) ~
'." . " .... J' <.7'1
II. . ~-- ....<; ./f
v'1;;,.~"'._)\,;~/
~ ,', .~ .;' "t v .. ,0
t:r~ST: " J .
[~i:~A~
Clerk ofthe Board
JEFFERSON COUNTY
BOARD JJf COMMI. S. SIONERS
// /; ~ ,
4d!~1////~~
DaVId sUllivan*i
>IiE~
Page 14
'~c "be i'J \"2.11'S loq
Regular Agenda
II:OOAM
JEFFERSON COUNTY
BOARD OF COUNTY COMMISSIONERS
AGENDA REQUEST
TO:
Board of County Commissioners (BoCC)
Philip Morley, County Administrator
THROUGH: Al Scalf, Director of Community Development
Stacie Hoskins, Planning Manager
FROM:
David Wayne Johnson, Associate Planner
DATE:
Agenda request for December 14, 2009
SUBJECT:
Continuation of BoCC public hearing of December 7, 2009 to hear testimony before
deliberation and decision on 2009 Comprehensive Plan Amendment application MLA09-
00077 Port of Port Townsend "Airport Rezone."
STATEMENT OF ISSUE: On November 16,2009, The BoCC made a motion to hold a public hearing
pursuant to JCC 18.45.080(2)(b) which requires a public hearing should the BoCC deem a change to the
Planning Commission's Comprehensive Plan Amendment recommendation necessary. The BoCC shall
conduct a public hearing to hear a Staff report and take public testimony before deliberating and making a
final decision to approve, approve with conditions or deny the application, MLA09-00077.
ANALYSIS: On December 7, 2009 the BoCC conducted the public hearing and made a motion to hold
the record open as requested by several parties to receive further oral and written testimony and
comments on potential transportation impacts from the State Department of Transportation on Monday,
December 14, 2009. Should the BoCC approve or approve with conditions, they are required under JCC
18.45.080(2)( d) to adopt the proposed Comp Plan Amendment by ordinance by the close of business on
the second regularly scheduled meeting of December, which is December 14, 2009.
ALTERNATIVES: After conducting the public hearing, the BoCC may adopt the Planning
Commission's recommendation, findings and conclusions to approve MLA09-00077, or they may develop
and adopt their own findings and conclusions using the same criteria as the Planning Commission set forth
under JCC 18.45.080( I)(b)&( c) to approve, approve with conditions or deny the application. Finding 55 in
the enclosed draft Ordinance has been recommended for inclusion in the findings by the Department of
Community Development.
FISCAL IMPACT/COST BENEFIT ANALYSIS: There is no fiscal impact by either accepting the
Planning Commission's recommendation or approving or denying the application. rfthe BoCC decides
to approve the application, the benefit to the County could be realized in terms of economic development
through increased employment.
; ",.
~--'
Regular Agenda
11:00AM
RECOMMENDATION: Staff recommends:
I) The BoCC approve the application MLA09-00077
2) Draft their own findings and conclusions
3) Direct Staff in preparing the adopting ordinance for signing on December 14, 2009
Should the Commissioners wish to approve MLA09-00077, a draft Ordinance is enclosed which the
Board may review and revise as appropriate after considering the testimony of the December 7 & 14
public hearing and the Board's own deliberations.
REVIEWED BY:
~ip-
Enclosure: Draft Ordinance Approving One Comprehensive Plan Amendment, File Number MLA09-
00077 Port of Port Townsend
,
STATE OF WASHINGTON
County of Jefferson
AN ORDINANCE APPROVING ONE
COMPREHENSIVE PLAN AMENDMENT,
FILE NUMBER:
Ordinance No.
MLA09-00077 Port of Port Townsend
}
}
}
}
}
WHEREAS, the Board of Jefferson County Commissioners ("the Board") has, as
required by the Growth Management Act ("the GMA"), as codified at RCW 36.70A.01O
et seq., set in motion and now properly completed professional review and public notice
and comment with respect to any and all proposed amendments to the County's
Comprehensive Plan originally adopted by Resolution No. 72-98 on August 28, 1998 and
as subsequently amended, and;
WHEREAS, as mandated by the GMA, the Board has reviewed and voted upon
the proposed amendments to the County's Comprehensive Plan ("CP") that composed the
2009 Comprehensive Plan Amendment Docket ("the Docket"), and;
WHEREAS, of the two (2) proposals that compose the Final Docket, one (1) was
withdrawn by the applicant; and one (1) was approved or approved with modification:
MLA09-000n (Port of Port Townsend), and the UDC amendment associated with Port
of Port Townsend MLA09-000n, and;
WHEREAS, an adopting Ordinance is required to formalize the Board's
legislative action, and;
WHEREAS, the Board makes the following Findings of Fact with respect to the
2009 Comprehensive Plan Amendment Cycle and these four amendments:
1. The County adopted its Comprehensive Plan in August 1998 and its development
regulations or Unified Development Code (UDC), Title 18 in the Jefferson County
Code (lCe) in December 2000. The CP was reviewed and updated in 2004.
I
2. The GMA, which mandates that Jefferson County generate and adopt a CP
requires that there be in place a process to amend the CPo
3. The amendment process for the CP must be available to the citizens of this County
[including corporations and other business entities] on a regular basis. In
accordance with RCW 36.70A.130, CP amendments can generally be considered
"no more frequently than once per year."
4. This particular amendment cycle began on or before March 1,2009, the deadline
for submission of a proposed CP amendment.
5. All of the amendment proposals were timely filed by March 1,2009.
6. Two formal site-specific amendments and one suggested amendments (for a total
of three) were placed on the Preliminary Docket through the CP amendment
process referenced at JCC Section 18.45.050.
7. All site-specific Comprehensive Plan amendments are included in the Final
Docket in accordance with JCC 18.45.060 (4)(b)(i).
8. The Department of Community Development (DCD) issued an Administrator's
Report on the Suggested Amendments on May 5, 2009, analyzing the proposed
suggested amendments on the Preliminary Docket and offering the
recommendation that only MLA07-104, Industrial Land Bank, not be docketed for
the 2009 amendment cycle.
9. The Planning Commission held a duly-noticed open public hearing on the
Preliminary Docket for all suggested amendments on May 20, 2009.
10. The Planning Commission completed its recommendation on the Preliminary
Docket on May 20,2009, recommending that suggested amendment MLA07-104,
Industrial Land Bank, be placed on the Final Docket.
11. The Board of County Commissioners held a duly noticed open public hearing on
the issue of the Final Docket on June 22,2009.
12. The Department of Community Development, the Department of Public Works,
Fire District #1 and Port of Port Townsend met on August 6,2009, to review the
amendments for possible transportation issues.
2
13. On June 22, 2009, the Board voted, that MLA07-104 not be included on the 2009
Final Docket but that the amendment application move forward to be reviewed
during the next amendment cycle in 2010.
14. The Final Docket was established by the BoCC on June 22, 2009. The Final
Docket for 2009 did not include any suggested amendments, and included only the
two site-specific amendment proposals.
15. On August 17,2009, application MLA09-00064 was withdrawn by the proponent
John Thomas Graham, leaving one site-specific amendment proposal.
16. The Planning Commission and the Board of County Commissioners held ajoint
workshop on September 2, 2009 to provide an opportunity for the site-specific CP
amendment applicant to make a public presentation on their proposal.
17. The Department of Community Development published the 2009 Comprehensive
Plan Amendment Docket, Staff Report and SEP A Addendum, an integrated Growth
Management Act and State Environmental Policy Act document on September 2,
2009. The report analyzes the proposal on the Final Docket and offered a
preliminary recommendation.
18. The proposed amendment has been subject to a SEP A analysis through the DCD
Staff Report and SEPA Addendum dated September 2,2009. The entire
amendment cycle shall now be'considered cumulatively with respect to a county-
wide environmental review of the associated impacts, if any, of these proposals.
19. The Planning Commission held a duly noticed open public hearing on September
16,2009. Oral public comment relating to the proposed amendment was taken
during the public hearing, and written comments were accepted through the close
of business October 5, 2009.
20. The text of the proposed amendments to the development regulations were made
available to the public no later than the publication date of the applicable Staff
Report, which was September 2, 2009, more than one month before public
comment period closed.
3
21. The Planning Commission deliberated on the proposed amendment on their
regularly scheduled meeting of October 7, 2009.
22. The above statements indicate that the proposed CP amendments were and are the
subject of "early and continuous" public participation as is required by GMA.
23. For the proposed amendment included in the 2009 Comprehensive Plan
Amendment Docket, the Planning Commission reviewed the growth management
indicators found at JCC 18.45.080 and JCC 18.45.050.
24. The Planning Commission recommendations were transmitted to the Board
through formal memoranda dated November 4, 2009, and are part of the record for
the legislative decision.
25. Incorporated by reference in the recommendation report were the meeting minutes
and audio recordings from Planning Commission meetings held on October 7,
2009, during which deliberations took place and the recommendation was
formulated, and on November 4,2009, during which a motion to rescind the vote
to recommend approval failed and the recommendation mernorandum was
finalized.
26. The Planning Commission recommended approval ofMLA09-00077 to rezone
approximately 24 acres from rural residential (RR I: 10) to Airport Essential
Public Facilities (AEPF) and to amend the UDC by creating an Airport Overlay III
underlCC 18.15.453 in Title 18.15 oftheJefferson County Code.
27. The Planning Commission found that the MLA09-00077 proposal is consistent
with the Growth Management Act, the County-wide planning policies, any other
inter-jurisdictional policies or agreements, and any other local, state or federal
laws.
28. The BoCC concurs with the Planning Commission and states that MLA09-00077,
as adopted, is consistent with the Growth Management Act, the County-wide
planning policies, any other inter-jurisdictional policies or agreements, and any
other local, state or federal laws.
4
29. With respect to the consistency between MLA09-00077 and certain provisions
found in Chapters 3, 7 and 9 of the current Comprehensive Plan, this finding
incorporates by reference the text found in the September 2, 2009 Staff Report at
pages 2-5 through 2-9 inclusive.
30. MLA 09-00077 is consistent with the Regional Transportation Plan propounded
by the Peninsula Regional Transportation Planning Organization because, in part,
the Comprehensive Plan and this amendment implementing portions of
Comprehensive Plan Chapters 3, 7 and 9 support "the economic vitality of airports
that are designated as Essential Public Facilities by identifying appropriate land
uses at and adjacent to airports in local Comprehensive Plans and development
regulations."
31. The Planning Commission approved and recommends the UDC amendment that is
associated with the Comprehensive Plan amendment in MLA09-00077.
32. The Planning Commission voted on the individual Comprehensive Plan
amendment considering the Growth Management Indicators in 18.45.080 JCC.
The Planning Commission also came to the conclusion that when applying the
Growth Management Indicators found in 18.45.050 JCC regarding "cumulative
impacts" of its decision on the site-specific amendment, they found no reason to
change the recommendation.
33. DCD staff recommendations remained unchanged from the September 2,2009
Staff Report throughout the process.
34. The Board made a motion to change the Planning Commission recommendation
on November 16, 2009, and hold a public hearing to hear testimony before
deliberating and making a decision to either approve, approve with conditions or
deny MLA09-00077.
35. All procedural and substantive requirements of the GMA, through the JCC (Title
18) and the Planning and Enabling Act (RCW 36.70), have been satisfied.
36. The Board deliberated on the proposed Comprehensive Plan amendment on
December 7, 2009 and made a motion to hold the record open until Monday,
5
December 14,2009, the required date on which any ordinance adopting any
amendment on the final docket shall be signed.
37. Pursuant to JCC Section 18.45.080(2)(c), for all adopted amendments the Board is
required to develop findings and conclusions which consider the growth
management indicators set forth in a) JCC Section 18.45.050(4)(b)(i) through
(vii), and b) items (i) through (iii) in JCC Section 18.45.080(1)(b).
38. JCC Section 18.45.080(1)(c), which contains eight criteria from which the Board
must generate findings, is applicable only to site-specific Comprehensive Plan
amendments.
39. Inquiry into the growth management indicators referenced above was begun for
the 2009 Docket through the DCD integrated Staff Report and SEPA Addendum
of September 2, 2009.
40. The Board adopts the Planning Commission's findings and conclusions with
respect to the growth management indicators as detailed in the Planning
Commission meeting minutes and audio recordings from October 7, 2009, and
November 4, 2009, during which deliberations took place and the
recommendations were formulated.
41. These findings are also augmented by the September 2, 2009 staff findings and
conclusions, except when and as noted below.
42. With respect to the individual amendments adopted by the Board, the Board enters
the following case-specific findings and conclusions:
43.
44. Specifically, the board adopts the staff Cumulative Impact Analysis in the staff
report, including the Growth Management Indicators, beginning on Page 2-9.
45. Furthermore, the Board incorporates here by reference Table 2 found in the DCD
Staff Report and SEPA Addendum of September 2,2009 at p. 1-9, particularly
that part of Table 2 containing inforrnation on the amount of acreage in the Rural
Residential designations RR 1: I O.
6
46. A review of that portion of Table 2 indicates that about 1/3 of the County's Rural
Residential land has a designation ofRR I :5, about 1/9'h of the County's Rural
Residential land has a designation of RR I: I 0 and the remainder, approximately
55-60% of the County's Rural Residential land holds the zoning designation of
RR 1:20.
47. Those rough proportions will not be changed in any significant manner by the
board's approval ofMLA09-000n and thus the County continues to have, even
after the adoption of this Comprehensive Plan amendment, the variety of rural
residential densities required by the GMA.
48. MLA09-000nfor APN 001-331-005 is submitted by the Port of Port Townsend.
The parcel is located approximately 1/3 mile east of the intersection of SR 20 and
Four Comers Road. The applicant seeks to rezone 24 acres from Rural Residential
to Airport Essential Public Facility (AEPF).
49. The Board adopts the map for MLA09-000n in Attachment "A" signed by the
Planning Commission chair on November 10,2009.
50. The Board also recognizes the needed change to the Unified Development Code in
association with the zoning change rnade in regard to MLA09-00077 to assure
consistency, and unanimously adopts the line-in/line-out changes ofMLA09-
ooon, shown in Attachment "B".
51. With respect to MLA09-000n [Port ofPT], the Board voted _ to
, concurring with, and adopting as if stated in full here, the
findings and conclusions in favor thereof of the Planning Commission (See
Findings of Fact ).
52. The Board unanimously approved the motion to direct staff to write an ordinance
to memorialize their actions.
53. Adoption of this Ordinance by the BoCC is authorized by both the Growth
Management Act and the general police powers provided to local governments by
Article XI, Section II of the State Constitution.
7
54. Adoption of this Ordinance furthers the health, safety and general welfare of the
populace of this County.
55. The current Jefferson County Comprehensive Plan at page 9-6 acknowledges "The
long-term economic viability of the airport, as well as the economic development
goals and policies contained in the Comprehensive Plan, support consideration of
the expansion of the airport uses to include appropriately scaled non-aviation
related industrial development, provided that such uses are consistent with GMA."
This is one reason why Staff has recommended approval.
NOW, THEREFORE, BE IT ORDAINED as follows:
Section One: Under MLA09-00077 [Port of Port Townsend], 24 acres identified as APN
001-331-005 which is located approximately 1/3 mile east of the intersection of SR 20
and Four Comers Road and directly abutting the southerly boundary of the Jefferson
County International Airport, Port Townsend, WA, shall be given in its entirety an
underlying land use designation of Airport Essential Public Facility depicted on the
corresponding map in "Attachment A".
Section Two: In concurrence with the Comprehensive Plan amendment under MLA09-
00077 (Port of Port Townsend), an amendment to the Unified Development Code,
Chapter 18 of the Jefferson County Code, is hereby adopted in accordance with the line-
in/line-out notations set forth in "Attachment B".
Section Three: Assessor's Parcel Number 001331005 shall be the location of the Airport
Overlay III.
Section Four: If any section of this Ordinance is deemed either non-compliant or invalid
pursuant to the Growth Management Act, then the development regulations and/or
underlying zoning designations applicable to that parcel or parcels prior to adoption of
8
the non-compliant or invalid section of this Ordinance shall be applicable to that parcel or
parcels.
Section Five: Ifany section of this Ordinance is deemed either non-compliant or invalid
pursuant to the Growth Management Act, such a finding of non-compliance or invalidity
shall not nullify or invalidate any other section of this Ordinance.
Section Six: The map is hereby incorporated by attachment (Attachment A).
Section Seven: This Ordinance becomes effective on the date it is executed.
APPROVED AND ADOPTED this
day of
,2009.
JEFFERSON COUNTY
BOARD OF COMMISSIONERS
SEAL:
David Sullivan, Chairman
ATTEST:
Phil Johnson
Erin Lundgren
Deputy Clerk of the Board
John Austin
Approved as to form
David Alvarez, Chief Civil DP A
9
.
\N.
\ ~~f
,
\ 3
\ 0-
~
'"
0
\ 0
\ <D
0
;0 -0 )>
;0 Ol -0
, ~ '2.
~ 0
0 CD C)"
iii Ol
;0 ::J
-
c -0
~ Ol
!!!. 0
;0 ~
CD
!II
Ii ",,,,
CD 111'
::J --
- ..co
iii' "",
=c
~i
>N 0 -0 ".
3 0 !1! CD 'C
'" 0 c: ~ 'C
~
::s \0 ~ ~ 0
p...n ~
3 0 <... a.
0 ::J
'" S ::J" CD ...
::S"d ::J ~ ':c;
'"
.... .... 0 (')
~g.. ." ::J"
)> ~.
"d '" !II
_::s !II
..... en 0
n ..... 0
~ -< or '"
.... '" m l'
..... '"0 ..
0 Jl
::s ...... '"
~ c
::s i
i
..
..
=
-
!!
~
,.
.",
--
-
~
'P
o
o
o
--.t
--.[
;0
;p
'"
m
-0
"
:l>
;0
c
~
!!!.
;0
CD
!II
Ii
CD
::J
-
~
m
en
!II
CD
::J
-
~
-0
c
2:
o'
"
Ol
g HJH~iFiP!'l-~
"" ~ t.-tli~_lq-ll 11.
~ :J> !!tH~h~,~Hi'i
j:g ::;' HILi r..P.fH~
~ l!~rl~;I~ ;f!I:'~
o ~-H "--!: -l ..
;::. pp-; 1l:. L '"
o ,it. t.. ~ ~-~
! ""n i ~ i~
~: ~ ..."
>i" :I
. f
i
;
,
o
8
.
~
.
OI'~
in
"'il>
1=
"
Attachment B:
Proposed Amendments to the Text of Chapter 18.15 of
the Jefferson County Code
Proposed Amendments to the Text of Title 18 the Jefferson County Code:
A. Amend JCC 18.15.1112. to read as follows:
18.15.1112 Purpose and intent.
The purpose and intent of this article is to regulate land uses within the
airport essential public facility district (AEPF) in order to encourage orderly
economic development in a manner compatible with the Jefferson Countv
International Airoort Master Plan. airport operations and adjacent properties,
and to protect the Countv's onlv existing general aviation public use airports
from conflicting or incompatible adjacent land uses or activities.
B. Amend JCC 18.15.1114. to read as follows:
18.15.1114 Permitted, conditional and prohibited uses.
New development within the AEPF district shall be restricted principally to
aviation support facilities and aviation-related manufacturingllight industrial
uses that elireotly or indireotly support its operation as on essential public
faoility. However, certain public and quasi-public nonovbtion related uses
and non-aviation-related ruralliaht industrial uses may be permitted as
specifically set forth in this section. and JCC 18.15.453. et sea.
C. Amend JCC 18.15.405. to read as follows:
18.15.405 Designation.
The JCIA has been identified as an essential public facility in the Jefferson
County Comprehensive Plans of 1998 and 2004. The airport represents a
valuable public asset. It provides both an important transportation service
and a vital asset to facilitate economic growth in the county. As such,
proteotion measures are needed to preserve the continued future viability of
the airport. Therefore, !we three airport overlays are hereby created, as
follows:
(1) Airport Overlay I. For the purpose of this section, the Airport Overlay I
is that geographic area affected by the airport and defined on the basis
of factors wf:lisl:l that include aircraft noise, aircraft flight patterns and
airport safety areas. It is based on the Noise Contour Interval Map
contained in the FAA-approved JCIA master plan, which projects the
55 DNL contour through the year 2022;
(2) Airport Overlay II. For the purpose of this section, the Airport Overlay II
is that geographic area that is affected by the FAA-mandated airport
traffic pattern for the JCIA and defined on the basis of aircraft flight
Appendix C
C-1
PORT PROPOSED JCIAlEPF
CODE AMENDMENTS
patterns and safety areas. It includes areas that lie adjacent and to the
south of Airport Overlay I and is based upon the Aircraft Accident
Safety Zone NO.6 contained in the "Airports and Compatible Land
Use" publication of the Washington State Department of
Transportation's Aviation Division (2/99), to the extent that Zone NO.6
correlates with the FAA-mandated airport traffic pattern for the JCIA as
set forth in the FAA-approved JCIA master piano: and
(3) Airoort Overlav III. For the purpose of this section. the Airoort Overlav
III is that aeoaraphic area that has been approved for inclusion in the
airoort essential public facility district throuah the Jefferson Countv
Comprehensive Plan text and land use amendment process. or other
applicable process. and which the Countv has determined is
appropriate for a limited ranae of non-aviation-related ruralliaht
industrial uses that foster the Port's abilitv to assure the lona-term
financial viabilitv of the AEPF. It is consistent with. and helps to
implement. the FAA-approved JCIA master plan. which anticipates
non-aviation-related industrial development to the south of the runwav
areas.
C. Add a new section JCC 18.15.453, "Airport Overlav III", to read as
follows:
18.15.453 Airoort Overlav III.
(1) PUrPose. The puroose of the Airport Overlav III is to orovide a
limited opportunity for rural scale non-aviation-related industrial
uses that contribute the lona-term financial viabilitv of the AEPF
and to enhance the economic vitalitv and aualitv of life for the
citizens of Jefferson Countv.
(2) Overlav Map. Jefferson County will prepare and maintain an
Airoort Overlav III map that identifies the parcels located within the
overlav.
(3) Permitted. conditional and prohibited uses. Notwithstandina the
permitted. conditional and prohibited use limitations set forth in JCC
18.15.1114 throuah 18.15.1112. the followina uses shall be
permitted within the Airoort Overlav III desianation:
(i) Non-aviation-related Iiaht industrial/rnanufacturina.
(4) Development standards. In addition to the standards for new
development in the AEPF district set forth JCC 18.15.1124 throuah
18.15.1132. the followina provisions shall apolv:
(a) Imoervious surface coveraae. buildina dimension and heiaht
restrictions.
(j) Total impervious surface coveraae shall not exceed
25%.
(ii) No structure shall exceed 10.000 sauare feet in size.
(iii) Notwithstandina JCC 18.15.1130. in no instance may
structures exceed 35' in heiaht.
Appendix C
C-2
PORT PROPOSED JCIAlEPF
CODE AMENDMENTS
Appendix C
(b) Veaetation retention and perimeter bufferina. Existina
veaetation should be maintained to the maximum extent
oracticable in order to reduce soil erosion. orovide habitat for
wildlife. screen liaht industrial uses from view. and maintain
the ore-develooment hvdroloaic reaime. Additionallv. the
Port shall maintain a minimum 50' wide buffer alona the
outer perimeter of each ownership Darcel (i.e.. not leasehold
parcels created throuah a future bindina site olan orocess)
within the overlav to screen industrial uses from view and
maintain the unincoroorated rural aesthetic values of the
locale.
(c) Low imoact develooment (L1m. Develooment occurrina
within the Airoort Overlav III shall incoroorate low imoact
develooment practices to the maximum extent feasible. The
most recent edition of the Low Imoact Oevelooment
Technical Guidance Manual for Puaet Sound (Mav 20051.
Develooed bv the Puaet Sound Action Team in collaboration
with the Washinaton State Deoartment of Ecoloav. shall be
used as a primarY source bv the countv in reviewina and
mitiaatina develooment occurrina within the overlav district.
C-3
PORT PROPOSED JCIAlEPF
CODE AMENDMENTS
(C l)cl) J
~occ
C.k
jeffbocc
\-z-In I O~
Page 1 of2
ij~ARING__RECO_RD__._~._.._....
From: ASM INC [starrettmansion@cablespeed.com]
Sent: Thursday. December 10. 2009 5:57 PM
To: jeffbocc
Cc: kinghyd@olypen.com; jmcmillien@cablespeed.com
Subject: rezone of the 24 acres
Commissioners Austin, Johnson and Sullivan:
12/8/09
Subject: Rezoning the 24 Acres Adjacent to Jefferson County International Airport (JCIA)
I urge you to adopt the 24 acre zoning change for JClA as soon as possible. The addition of up to 100 good
industrial jobs in Jefferson County must be of the highest priority in light of the current national and local
economies, potential loss of the paper mill, and the shortage of funds for county operations.
I have read the city objections in the Leader (9/23/09) and there is not a single valid comment.
Mr. Timmons apparently does not think the Port is able to be environmentally responsible yet I have first hand
knowledge the Port has an exemplary record of protecting the environment at the same time it has developed
infrastructure. The city claims that this proposal came out ofthe blue which is false because light industrial has
been talked about since the property was purchased and is included in the current FAA approved JCIA master
plan.
The PUD states that they have 800 water taps available for future development which is more than sufficient for
the 24 acres. Also, the Port and PUD built a standpipe and tunnel under the runway to assure water availability
and fire flow.
The area behind Goodwill was originally an industrial park with severely limited office and retail sales space
allowed when I, as a city council member, voted in favor of that project. It is now a business park with
numerous private and public entity offices and all real estate signs offer commercial property for sale
Glen Cove has had years to develop as an industrial area but has not due to zoning and permitting issues as well
as scare tactics by the likes of the People for a Livable Community. My research indicates the largest parcel
available is 1 y" acres which is hardly large enough for industrial development. A sewer does not exist in that
non-UGA area.
An industrial park with the focus on small, environmentally responsible businesses constructed as a
public/private partnership will provide good paying jobs, needed tax revenues to the county through real and
personal property taxes and real estate excise taxes. Incomes from those businesses will generate sales tax
revenues as well as additional businesses to serve the needs of the 100 employees. This could become a reality
without direct county investment of funds.
Side benefits will include providing local high school graduates with a place to earn a living and support a
family which could also help reverse the declining school census. Boat Haven industrial businesses without
need for direct water access could relocate to JCIA which would free up extremely limited marine trade space in
the Boat Haven.
Under GMA, the Growth Management Steering Committee was formed to develop countywide planning
policies. The law requires continuity between the county and UGAs. This committee was formed and has met
as needed over the years and I have had the pleasure of sitting on that committee. The city and the county each
have their own comprehensive plans and clear lines of jurisdiction. The city has no zoning authority in the
12/11/2009
Page 2 of2
county just as the county has no authority in the city. The countywide planning policies are criteria only. Final
jurisdiction on planning policies rests with you, the county commissioners and not at City Hall.
As a city resident, i~ is highly offensive to me that Port Townsend hired a very expensive law firm in an attempt
to force the county into their no growth agenda. It is my opinion that the city is only one of many with a
position on the 24 acre rezone and it is irresponsible to pit the city against the Port to "work out their
differences". The fact that the city lawyered up indicates to me that they want to kill the rezone and any
potential competition rather than compromise. This action also forces the Port and County to spend their scarce
funds on lawyers. As commissioners, it is your responsibility to make the hard decisions which will benefit
Jefferson County and not concede your responsibility to City Hall.
Again, I urge you to adopt the rezone of the 24 acres at JCIA as recommended by the Jefferson County
Planning Commission.
Sincerely,
Robert H. Sokol
Former City Council Member
Former Port of Port Townsend Commissioner
Cc: Philip Morley
D. W. Johnson
Larry Crockett
12/11/2009
(C \)C\) 12.1101oCj
A
HEARING RECORD
RECEIVED
Commissioners Austin, Johnson and Sullivan:
12/8/09
DEe 1 0 20ng
Subject: Rezoning the 24 Acres Adjacent to Jefferson County International Airport . .... .. T \.1
(JCIA) JEFFERSON COUN .
. f'nl\Jll\IIl~SlnNERS
I urge you to adopt the 24 acre zomng change for JClA as soori"li's)l"o\;!imre~ '11:1e a~(lftlOn
of up to 100 good industrial jobs in Jefferson County must be of the highest priority in
light of the current national and local economies, potential loss of the paper mill, and the
shortage of funds for county operations.
1 have read the city objections in the Leader (9/23/09) and there is not a single valid
comment.
Mr. Timmons apparently does not think the Port is able to be enviromnentally responsible
yet I have fIrst hand knowledge the Port has an exemplary record of protecting the
environment at the same time it has developed infrastructure. The city claims that this
proposal came out of the blue which is false because light industrial has been talked
about since the property was purchased and is included in the current FAA approved
JClA master plan.
The PUD states that they have 800 water taps available for future development which is
more than sufficient tor the 24 acres. Also, the Port and PUD built a standpipe and
tunnelllnder the rllnw~v to aS~I!re water availahilitv and fire flG\\
-- - . - ---- - -- --.I -~ -- - - -. . - - ---------'" - ~ - --
The area behind Goodwill was originally an industrial park with severely limited office
:1nrl-rctnll sales space allo\vcd \\'hcn T~ n3 a city conn(",11 member; voteD in favor of that
l ~- .:.~ ..... ,'.' ~.. ....
;::::;:;:':'.";1::: p:'h.".,:!-.f': :::;~~ >,;::+;1::-. 2n~-jt:i' r:ff;!~"".~ ;;-:;~ :;~~
real estate signs offer commercial property for sale
(~~~::n C~)ve
",-,.~,....>".c~ .."~_ A,.....,..,.1_"'..,... ."'''' ,..".,..,
g~f:n_ h:;~ I,::,_" ~""'""'~,..t,~,,,, h^';
permitting issues as well as scare tactics by the likes oftl1e People for a Livable
f'nmrrnmlty ~v1y r~~scarc:h 1ndientcs the larecst pnTccl availnhl~ -i~ 1 Ii. acres \vhich i~
L,tdly large enough for industri~l development. A sewer does not exist in that non-I In .A
area.
i\ .,_ : ~,-A, ,,-,~....:,-,l "".-,.....1. ".<~Il""
,._H _._.~!.,-,,-.;,c.,,-.j i''-'''''' .,~~u.,
C",-.,,,-, ,___yo.
-< "-,"--- '-~ -' ,-."
.,,~, ~,:,~,,'-"~'-;--~" '-,.'-"; .,ll~. """.~~,,-.-,..., .:,~1...1 ,-~ h, "__';''''''_::'':'''''''''''~
'-_._~l " .. ..'.". ,,-,.\ .,~u -~:f !,'~""l-!'-"-""'" \.._- L'UC"'.H-,-",',::'2>~_.~
constructed as a public/private partnership will provide good paying jobs, needed lax
rc:vc~nijC:~ to th~ (';onnhr thrn'iwh r~:1! :1no n;.~rs:cmn! nr0rn':rtv t:TXf';~ :lnd f[';:ll [';~tnt(". (;xci~c
.. ,,-' ..... .. - -'- ..... '"
taxe:;:_ Ineon'es fronllhose businesses will generate sales lax revenues as well as
:1drlitif)t1nl h-1Nin?~o;:.p:~ to .:;::~nrr. thf' nr-e:ds: nfthf': 100 f'fl1n!nV{':c's Thie;:; c{1~'rfd h,.....('omf';1
, .
:'e~_~ti~_y \..r~:}~(:-::: :-H-rec~ ~_~G~_~::~!_Y ~~-:'::~:...-::'~~~~nt f.f r:_~;-::-~~-:
Sidc bcncfits will includc providing local hig.'l school graduatcs witll a placc to carn a
". ';';~b w';.d ~UppG:t ~t fUTI~ily ....,b.i~h ~Guid uL.v help r~vt:r~t: the ~h:dining ~~hu01 ~en0t~::;,
. , ,.., -;. ',~. 1 r " ,. l 1 , ,.
;,iJU:;LrJaJ UU;'mH_::i.',C':--; \','lUIUUi lll;t:U .-Uf- -U1P.:;t;1. \...aL~r at:-~e~;:-. ~Ul.HU .t.;.i4.;;;..HL Hi
!!"'! ,A. ...~.:",.L ..,
,,.1..1 r:.._,,~ "',--.
Fk~;}t ~h:;.,~.;_"';-;
.
Under GMA, the Growth Management Steering Committee was formed to develop
countywide planning policies. The law requires continuity between the county and
UGAs. This committee was formed and has met as needed over the years and I have had
the pleasure of sitting on that committee. The city and the county each have their own
comprehensive plans and clear lines of jurisdiction. The city has no zoning authority in
the county just as the county has no authority in the city. The countywide plarming
policies are criteria only. Final jurisdiction on planning policies rests with you, the
county commissioners and not at City Hall.
As a city resident, it is highly offensive to me that Port Townsend hired a very expensive
law firm in an attempt to force the county into their no growth agenda. It is my opinion
that the city is only one of many with a position on the 24 acre rezone and it is
irresponsible to pit the city against the Port to ''work out their differences". The fact that
the city lawyered up indicates to me that they want to kill the rezone and any potential
competition rather than compromise. This action also forces the Port and County to spend
their scarce funds on lawyers. As commissioners, it is your responsibility to make the
hard decisions which will benefit Jefferson County and not concede your responsibility to
City Hall.
Again, I urge you to adopt the rezone of the 24 acres at JCIA as recommended by the
Jefferson County Planning Commission.
Sincerely,
~L-
~/~~~
Robert H. Sokol
Former City Council Member
Former Port of Port Townsend Commissioner
Cc: Philip Morley
D. W. Johnson
Larry Crockett
~~M;~~&;
~lRST WESTERN INVESTMENS
@JOOl
prBP LLC
ED;~~~tU!CEIVE 0
DEe I 4 2009
December 14c 2009
Board of COllTlt)" COl11missioners
PO Box 1221l
Pori TO"IlSCllllc Wflshin;,>ton 98368
JEFFERSON COUNTY'x
COMMISSIONERS
(360) 385..9382
Re: Jefferson County Site Specific Comprehensivc Plan Amendment MLA09-77
December 14.2009 Public Hc"ring
Dear C:Ol11miSSlOners:
As an owner of property zoned light industrial in the Cily of Port "rownsend, YVC \vould like to c.omment on
the above referenced proposal 10 add light industri"l at the airport. We own both devclopcd property (the
Port Townsend Business Park) and undeveloped property (vacant land on the south side of Sims at Howard
Street) The addition of ne\V LI zoning al: the airport: would undermine our significant invcstlncnt. in 1..1 land
av,ntable mthe Couuty. The rezone should not occur because (I) Ihe current supply of land is surlieient tor
the foreseeable (iJture, and (2) the proposed rezone area is not adequately served by the inil"astructlll"c nceded
Our compan)' has madc slgnlficanl'. illvcstnK~nts. in infrostrueturc (utilities and road.s) to develop the business
park. In tlLct, \VC arc currentl:,>/ in the process erfdeveloping the road and utilities to open the eastern portion
\lIthe business park In approximately three months, twcnty-thrce (23) more lots will be available for sale
and immediate development. ^ business \villjust need a building pennit to develop a new bLLilding~ 110
Curthcr infrastructure improvements \vOldd be required,
Since we purchased the business park in December of 1997c we have sold eighteen lots, tor an averagc of 1.5
lots sold per yeae Based on these results, the twcnt).'-t.hrcc lots coming avnilable carly next year represent a
land inventory of approximately fiHecn (15) years. (There are also ten other vacant lots not owned hy
existing users. vvhich represent another seven (7) 'years of land inventory, of,'vhich sixty percent are owned
by JctTerson Connty.) In addition. our vacant property on thc south side of Sims (when developccl) will
accOlnl1loda.t:c ~'lppro:Xllnatel~ thirt:\'-fivc (35) morc 101.s, another t\Vcnt},-thrcc (3) years of Ia.ndinvcntory at
current absorption rates.
If the POIt can ofFer land for tJ uses, or build out and offer rentable space, our investment at the business
park will be undermiIled. Uses tl1at might locate 31 the business park \voukl be more likel:)" to locale at the
airporL where rents \volJld hkcly be cheaper since the Port \vOldd not have to meet the: s.:ll'nc infrastructure
requircments as 1VO have had to meet to dcvelop within the tlG A. The P0l1 wi II bc able to oiTer below
market rents because it has its own financing sources, including taxation. The result would be an unlcvcl
ph:l~/ing field that \vould affect all competing propertv owners. including the Count)'.
There have been rumors of possible Ll uses at thc airport if the rezoue is approved, aU of which could be
acconl1l1od,Hecl within our business park. This direct, unnecessary cornpctit;on wlth the business park and
simila.r properties should not be allnwcd. Please consider the impact of the proposed rt,~zonc on a.fft~cted
propcrt~y owners stich as Jefferson County and ourselves.
SincGrcl\'.
~
Mar~;nger
PTBP LLC
Cl..", 2'~C c. ':; \ '2. \ I q \ oq
DC \) :)
David W. Johnson
HEARING RECORD
From:
Sent:
To:
Cc:
Subject:
Severson, Dale [SeversD@wsdotwa.gov]
Monday, December 14, 2009 9:42 AM
David W, Johnson
Jim Pearson; Maker. Debbie
SR 19 Jefferson County requested comments - Was: Comp Plan Amendment Transportation
Impacts
Airport Traffic Analysis.pdl; Traffic Analysis Cover Memo 09302009.doc; WSDOT Aviation
Comments.pdl; 2009 CPA Staff Report.pdl
Attachments:
Importance:
High
Good morning David,
After reviewing the attached documents WSDOT has no objections to the Comp Plan amendment. As I read the
documents the amendment is lor a 24 acre parcel being rezoned that will generate about 100 new employees or about 42
to 49 new PM Peak trips (demand model says 49 versus 42 per ITE).
WSDOT supports additional review and analysis at the time actual development is proposed. The Transpo memorandum
dated 9/29/09 second to last paragraph states "At which time a specific development Noposal is submitted. the County
will likely reauire subseauent analysis of possible traffic Impacts as part of the prolect level review. " II that is the case then
WSDOT has no objections to the amendment
Any questions please ask,
Thanks
Dale C. Severson, P.E.
Development Services Engineer
WSDOT, Olympic Region
Direct line: (360) 357-2736
Work cell: (360) 791-3105
Fax: (360) 357-2748
Email: seversd@wsdotwa.Qov
From: David W. Johnson [mailto:dwjohnson@co,jefferson.wa.us]
Sent: Tuesday, December 08, 2009 11:00 AM
To: Severson, Dale; Maker, Debbie
Subject: Comp Plan Amendment Transportation Impacts
Dale & Debbie,
Nice to talk with you today. Attached are the comments from Public Works with the Transpo Group Traffic Analysis
regarding the Airports proposed Comp Plan amendment. Also attached is the email from Carter Timmerman and
another copy of the Staff Report and SEPA Addendum.
Thanks in advance for any comments you can provide us before Monday the 14th.
Thanks again for your help!
David Wayne Johnson
1
Associate Planner - Port Ludlow Lead Planner
Department of Community Development
Jefferson County
360.379.4465
***
eSafe2 scanned this email for malicious content ***
IMPORTANT: Do not open attachments from unrecognized senders
***
2
***
-
/J#J.j/C1
<2c
S",/Jlk<.f! ~' 6:; ~tU'I((
?:::DC(... )
(A S \ z./ \ '-\ \09
OLD
(;~JM."'~S, h14JlILJ"< (ir,!)' ,-f' ?I'rr ?6 IU"l5eN'
HE:ARIN.e k"i!'."""'~\
. M rtt'!""URD
DRAFT City-proposed condition if rezone is approved
All uses, including any proposed non-aviation related light industrial uses,
established within the expanded Jefferson County International Airport Essential
Public Facility (AEPF) district shall functionally relate (Le., be .primary" uses) or
directly support (Le., be an "accessory" use to) the operation of the airport.
Additionally, airport related uses may include light industrial and manufacturing
uses that are airport dependent (e.g., air and/or package delivery); dependent on
overnight shipping (e.g., laboratories); and similar uses.
RECEIVED
ncr 1 4 2rrc
ut.,. 1. 0d,;
JEFFERSON COUNTY
COMMISSIONERS
-
PORT of4!) H~ING RECORD
PORT TOWNSEND
- -
P.O. Box 1180 Port Townsend, Washington 98368-4624
Administration: (360) 385-0656
o,n::CClVED
Fax: (360) 385-3988
Jefferson County
Board of County Commissioners
P.O. Box 1220
Port Townsend, WA 98368
DEe 1 4 2009
JEFFERSON COUNTyecember 14, 2009
COMMISSIONERS
RE: City of Port Townsend Comment Letter Concerning Proposed Jefferson County
International Airport (JCIA) Essential Public Facility (EPF) Rezone (MLA09-77)
Dear Commissioners_
The Port has reviewed the December 4,2009 comments from Mr. David Timmons, Port
Townsend City Manager to you. This letter seeks, once again, to address the City's
concerns.
The Port wishes to reiterate its sincere intent to cooperate and collaborate with the City,
County and PUD on economic development and water resource planning issues. On
November 23rd, the Port Commission adopted Resolution No. 528-09, again
demonstrating its good faith and desire to "promote comity between the County, City,
PUD and the Port" by offering to defer moving forward with permitting and
development of the rezone site, if approved. This proposed "time out" in the process was
intended to provide the parties with an opportunity to discuss, and hopefully, resolve their
differences regarding water resource availability and allocation. That said, the Port's
desire to make common cause in serving the public's interest should not be
misinterpreted as a willingness to simply accede to the City's position when the facts,
procedural history, and - based upon the advice of our counsel - the law, do not support it.
A brief review of the planning history of the Jefferson County International Airport
(JCIA) and industrial land in east Jefferson County is required to more fully understand
the context of the Port's current EPF expansion and overlay zoning request. As you
know, the County's initial GMA Comprehensive Plan designated the JCIA as an essential
public facility (EPF) (August 28, 1998). The Plan restricted uses to aviation support
facilities and aviation-related development. However, the plan also included policy
language indicating that non-aviation-related uses "that are compatible with the airport
Port of Port Townsend
Comment Letter
1
December 14, 2009
e-mail: Info@portofpt.com
website: www.portofpt.com
facility and surrounding area" would be evaluated in a subsequent planning process (EPP
2.2, page 9-8 of the Plan).
In 2001, the Port initiated a multi-year public process to update its Airport Master Plan
(AMP). Two advisory committees were established to assist in updating the AMP and to
coordinate airport planning at the local and County levels: the Airport Review
Committee (ARC), and the Community Review Committee (CRC). Together, the
committees included local government officials, aviation users, and interested citizens
and business community representatives. Notably, the CRC included representatives
from the City of Port Townsend and Jefferson County. The committees provided a forum
for citizens and local governments to participate in the JCIA planning process, provide
input regarding development priorities, and to recommend a "preferred" course of action
for future development.
In 2002, during the AMP process, but well before its adoption, the Port purchased the site
now the subject ofthe proposal before you. The property purchase was authorized
generally by Port Resolution No. 235-97 (June 18, 1997), which established the Port's
policy with regard to land acquisition in the vicinity ofthe JCIA. The purchase was also
consistent with the then applicable 1994 version of the AMP, which specifically
identified the area for potential future airport expansion and light industrial use. The
policy established by Resolution No. 235-97 directed that the Port investigate the
acquisition of properties adjacent to the JCIA to maintain and encourage a compatible
environment for airport operations and development. The Resolution outlined seven
objectives for the Port to pursue, as follows:
. To increase the economic benefits of the airport to Jefferson County.
. To prevent land use incompatibility and encroachment.
. To improve the sqfety and efficiency of aviation operations.
. To mitigate the noise impacts of airport activities.
. To encourage the financial self-sufficiency and compatible economic
development of the airport.
. To mitigate the wetland and stormwater impacts of airport development.
. To enhance connections to the surface transportation network.
(Emphasis added).
On December 22, 2003, the AMP was finally adopted. It was prepared in accordance
with FAA requirements, the County Comprehensive Plan, and the GMA. It provides
clear direction and guidance regarding future airport development priorities. With regard
to the Port's present proposal, the AMP states in pertinent part as follows:
"Development of property owned or acquired by the Port south of the nmway
should be utilized for rural level development activities that directly or indirectly
support the operation of the airport as a self-sustaining economic enterprise. This
will not only reduce or eliminate the need for operating subsidies, but will promote
more compatible land uses and provide forfurther economic development
opportunities in the County. Future development plans should include provisions
for additional hangar space as well as job generating, light manufacturing or
Port of Port Townsend
Comment Letter
2
December 14. 2009
industrial uses that generate revenues to support airport operations. All
development activities must be rural in character, only requiring rural levels of
service, and must comply with FAA safety requirements for height, light, smoke,
etc. All supportive development activities must also comply with the provisions of
the Jefferson County Comprehensive Plan and Unified Development Code."
(Airport Master Plan, page 7-6).
In addition to this language, the AMP included a FAA approved "Airport Layout Plan,"
which unambiguously identified the subject property for future JCIA expansion and light
industrial use. (Airport Master Plan, Chapter 9 - Airport Plan Drawings).
In 2004, and subject to a settlement agreement between the County and PUD
(WWGMHB Case No. 01-2-0016), Jefferson County undertook amendments to its
Comprehensive Plan to protect the long-term viability of the JCIA as an essential public
facility (EPF). The County used the AMP as the basis for its Comprehensive Plan
amendments, which took the form of expanded and revised language relating to the
JCIAlEPF via Ordinance #17-1213-04 (December 13, 2004). These prior planning
efforts provide a reasonable and rational basis, and wholly support, the County's approval
of the present EPF expansion request and overlay zone.
Despite these considerable planning efforts, the crux of the City's present position
appears to be that no additional land may be created for rural light industrial use,
anywhere in Jefferson County (except perhaps the City itself), without a comprehensive
study quantitatively documenting a precise need and allocation of industrial land base
between UGAs, limited areas of more intensive rural development (LAMIRDs), and
major industrial developments (MIDs), and by inference, the JCIA/EPF. The City seems
to confuse and conflate the statutory requirements for Industrial Land Banks
(ILBs)/Major Industrial Developments (Mills) to conclude that the draft ED. Hovee and
Company Study (July 2007) must be completed before any changes may occur at the
JCIA/EPF.
We disagree. The purpose of the Hovee study, abandoned in 2007 due to a lack of
financial resources, was to help provide the foundation for implementing the "Major
Industrial Development" (MID) provisions of the GMA under RCW 36.70A.367. The
statute allows the creation of up to two locations for "major industrial development"
outside UGAs. The Hovee study is germane to the master planning required to identifY
and designate MID locations under RCW 36.70A.367(2), but not the present proposal.
What is proposed by the Port in no way rises to the scale or intensity of development
contemplated under the statute for master planned MID locations. While the JCIA, and
areas in its proximity, have in the past been publicly discussed as possible future
locations for an industrial land bank, that is categoricallv not the type or magnitude of
development that would be permissible if the proposed amendments were approved.
What's more, our review of the Washington State Growth Management Act (GMA)
reveals no requirement that a countywide industrial lands study be completed precedent
to a modest airport EPF expansion that is supported by an adopted airport master plan
and explicit corollary enabling language within a county comprehensive plan. In the
Port of Port Townsend
Comment Letter
3
December 14. 2009
situation before you, the airport master plan itself contains the necessary data,
alternatives, and analysis to support your decision.
Clearly, not all industrial areas are created equal, and what is intended under the Port's
proposal is far less intensive than the development that may occur within any MID or
UGA. The standards proposed for the overlay (i.e., impervious surface coverage limits
(25% maximum), maximum building size limits (10,000 square feet maximum), height
standards (35 feet maximum) and buffering/vegetation retention standards) simply will
not permit "major" industrial/urban scale development. We contend that the proposed
overlay regulations will effectively limit the scale, intensity and amount of development
within the 24-acre area to a level significantly less than is allowed under the standards
applicable to the Glen Cove LAMIRD, or light industrial areas within the County's other
LAMIRDs, or the Marine-Related and Manufacturing districts within the City's UGA
(where gross floor areas range from 1 to 2 feet of floor area for every square foot oflot).
We firmly believe the proposal to be wholly consistent with, and appropriate to, an
airport essential public facility situated in a rural unincorporated area.
Also relevant to the Port's proposal is the complex history of the unincorporated Glen
Cove area. Authorized by County policy in the late 1980s, prior to the enactment of the
GMA, the area is presently designated as a LAMIRD by Jefferson County. But, at the
time of adoption of the initial GMA Comprehensive Plans of both the City and County,
the area was identified as a potential future urban growth area for the City of Port
Townsend. This was reflected in complimentary and consistent, if not mirror image,
language in both plans that directed ongoing study and evaluation of a potential UGA
expanslOn.
Importantly, the Joint Growth Management Committee (JGMC) collaboratively
designated this potential future UGA study area in June of 1995. At the time, a number
of nascent rationales were advanced (principally by the City) to justify considering an
expanded UGA, including the following:
. An ostensible shortage of commercial and industrial land in-City, especially to
serve a wider east Jefferson County employment base;
. The purported unsuitability of areas zoned for commercial and industrial use in-
City (i.e., too fragmented to support needed economic development);
. The claimed inappropriateness of other larger ownership parcels in the City for
industrial use due to the presence of environmentally sensitive areas or locations
remote from regional transportation corridors (i.e., S.R. 20);
. The present use and zoning of Glen Cove; and
. The desire to stem the tide of "retail sales leakage" and promote a more
balanced and vital economy in northeast Jefferson County.
This UGA study area effectively ceased to exist on January 6, 2003, when the City of
Port Townsend amended its Plan to eliminate all reference to a potential final UGA
expansion into Glen Cove (Port Townsend Ordinance No. 2825). The City took this
action unilaterally, as far as the Port is aware, without consulting the JGMC, and without
having conducted the very industrial land needs study it now asserts to be necessary for
Port of Port Townsend
Comment Letter
4
December 14, 2009
the County to create any additional industrial land. Perhaps our desire for consistency
and predictability in local planning efforts is unwarranted; as the old saying goes,
"consistency is the hobgoblin of small minds."
Now, as the City extends its own infrastructure in the southwestern portion of the
incorporated area, it appears to be re-examining the wisdom of its earlier judgment,
intimating that Glen Cove be reassessed for potential inclusion in an expanded UGA
This incipient change in City policy comes after both Jefferson County and the Port have
continued their respective planning efforts, investing tens of thousands of dollars in the
process, which factored the City's 2003 decision to call off the Glen Cove UGA study.
Still, it must be admitted that the City's officially adopted policy position remains one of
opposing any UGA expansion into Glen Cove (see Port Townsend Comprehensive Plan,
Land Use Element, "Port Townsend Urban Growth Area (UGA)" narrative discussion,
goal 16 and policies 16.1 through 16.4).
Strikingly, the City's own revised Plan narrative hints at a considerable statutory barrier
to expanding its UGA into Glen Cove. Specifically, "that no expansion of the City's
UGA is needed to accommodate the urban growth allocated to Port Townsend through
the year 2024" Under RCW 36.70A.ll0, counties and cities, based upon the growth
management population projections made by the Washington State Office of Financial
Management, must "include areas and densities sufficient to permit the urban growth
that is projected to occur in the county or city for the succeeding twenty-year period."
Under current zoning, the City has a population holding capacity of some 30,000 - more
than 20,000 over its present population - making a case for expanding the UGA
problematic, to say the very least.
In this broader planning context, the Port is having difficulty seeing what legitimate
public interest the City seeks to protect by opposing the proposed JCIAlEPF expansion
and overlay. The City baldly asserts that the "proposed airport rezone will undermine
the legitimate future consideration to rezone privately held light industrial land in the
City, the Tri-area urban growth area and Glen Cove" and that it will undermine
consideration of planning options. Given the relevant planning history, we are mystified
by this argument. Is the argument that, because the City is making investments in public
infrastructure, it alone should hold a monopoly on industrial land - regardless of its
character, intensity, location or statutory and local policy basis? While the Port agrees
with the City that urban industrial development should be strictly confined within UGAs
and Mills, we do not believe the GMA precludes all industrial development in the
unincorporated areas, particularly not at an airport EPF guided by its own specific
statutory and policy framework.
We laud the City for its investment in urban public infrastructure within its corporate
limits. These investments will create a more vital and attractive urban growth area, and
serve to spur much needed private sector development and investment in the coming
years. The Port of Port Townsend and its tenants will indirectly benefit from these
improvements. But fairness and logic also require that the County and City similarly
acknowledge the millions offederal taxpayer dollars that have supported the
Port of Port Townsend
Comment Letter
5
December 14, 2009
development of infrastructure at the JCIA over the past twenty years, and its status as an
EPF. Under the National Plan of Integrated Airport Systems (NPIAS), the FAA has
identified the JCIA as significant to the nation's air transportation system, and therefore
eligible to receive Federal grant funds under the Airport Improvement Program (AlP).
The NPIAS designation does not include all airports. Instead, it comprises commercial
service airports, reliever airports, and selected general aviation airports. The JCIA falls
into this last category. At the time of publication of the JCIAlAMP, some $4,446,099 in
federal grant assistance had been expended on infrastructure development at the airport
between 1988 and 2003. Over $3,000,000 in federal grant assistance has been provided
since then. Again, as a condition of receiving this federal grant assistance over the years,
the Port of Port Townsend was required by the FAA to provide grant assurances that it
would make every effort to maintain the JCIA as a self-sustaining facility. This federal
requirement is reflected in both AMP and County Comprehensive Plan language.
Significantly, these figures do not include funds expended to support operations and
maintenance of the facility, and between 1994 and 2003, the JCIA operated at a loss of
approximately $288,000. Addressing this operating loss and promoting a "cost-centers"
approach to Port facilities management is vital to ensuring that revenue streams generated
at other Port facilities will not be siphoned off to support JCIA operations. In turn,
eliminating this operating loss will indirectly support Port infrastructure development at
facilities it owns and maintains within the City (e.g., Boat Haven stormwater
improvements).
A number of specific claims in the City's December 4th letter are simply erroneous and
fundamentally misunderstand the role and purpose of the port districts under state law.
For instance, the City states:
"The current proposal will create unfair advantage since private owners will need
to meet urban standards with their investments and lack the same financing and
debt considerations as the Port. The result is an uneven playing field - an
undermining of the County and City investment in the UGA 's (sic). Under the
proposal, which allows ill!!! light industrial uses, there is nothing that prevents the
Port from re-locating marine trades in Port Townsend's Boat Haven and Point
Hudson to Port land located at the airport. "
Where do we begin? The proposed light industrial area will not unfairly disadvantage
industrial landowners in UGAs: industrial landowners in UGAs will be able to more
intensively develop their properties, and can avail themselves of a broader range of
potential uses due to the presence of urban water and wastewater services. Urban
industrial scale and intensity development will not be permitted at the JCIA. By way of
example, a 20,000 square foot food processing facility (e.g., brewery) would simply not
be allowed at the EPF: not only would such a use be too large, it would also require
water and wastewater infrastructure not available at the JCIA, and inappropriate to an
EPF situated in a rural unincorporated area. Similarly, a metal fabrication business that
involved metal plating would also be precluded - regardless of its size - due to its
demand for urban water and wastewater infrastructure.
Port of Port Townsend
Comment Letter
6
December 14. 2009
The misplaced notion that the financing and debt considerations available to the Port
create an unfair competitive advantage also demands correction. The reason the Port of
Port Townsend exists at all, like all port special districts under Title 53 RCW, is to
provide economic benefit to the locality and state. Ironically, the financing and debt
considerations that the City finds objectionable if put into practice at the JCIA are the
very characteristics that allow Port owned and managed facilities at the Boat Haven and
Point Hudson (both within the City) to be engines oflocal economic prosperity and
community identity. Does the City only object to the Port's special authority if used to
generate economic development opportunities within the unincorporated County? Or
does the logic of its objection extend to the Boat Haven and Point Hudson as well? If so,
the City may wish to take up its objections with the state legislature in the form of a
proposed repeal to RCW Title 53.
The stated fear that the Port will relocate marine trades to the JCIA is, to put it mildly,
wholly unfounded. Most of the marine-related uses at the Boat Haven and Point Hudson
are water-dependent and water-related and would either require a waterside location by
their intrinsic nature, or could not occur economically without proximity to the shoreline.
The Port has every interest in maintaining and supporting the local marine trades industry
within Port Townsend, and has no intention of moving marine trades five-miles out of
town to a landlocked location where they would not be viable.
In the larger economic context, the record before the Board of County Commissioners
has heretofore been silent as to the import of the current recession. As you doubtless are
aware, unemployment in Jefferson County has risen significantly over the course of the
past year. In 2008, the County's unemployment rate fluctuated from between 4.9% to
5.6% (i.e., anywhere from 660 to 770 unemployed persons). In 2009, after the onset of
the recession, the data show that the County's unemployment rate has ranged anywhere
from 7.3% to 9.4% (i.e., from between 980 and 1,310 persons). (Source: Washington
State Department of Employment Security). Clearly, there is a critical need to create
opportunities for business owners and entrepreneurs to generate additional employment
opportunities in our community and to diversifY the local economy. The proposed
JCIAlEPF expansion and overlay designation will not result in these new opportunities
being created overnight. However, it will prepare the way for 8-10 small manufacturing
businesses in the future, businesses that will help the EPF become more self-sustaining,
while also bolstering the strength and resiliency of our local economy.
Finally, with regard to the legal opinion offered by the lawyers of Foster Pepper on behalf
of the City, we must observe that the wrong questions appear to have been asked and
answered, and critical facts omitted from the analysis. We would suggest the following
questions as being more appropriate to your inquiry and final decision in this matter:
. Is expanding an airport EPF to include limited areas for future light industrial
development consistent with GMA provisions relating to EPFs if
o The airport expansion area in question is clearly delineated in a FAA
approved airport master plan (AMP);
Port of Port Townsend
Comment Letter
7
December 14. 2009
o The relevant local jurisdictions (i.e., city and county) participated in the
development of the AMP;
o The AMP served as the basis for corollary County Comprehensive Plan
amendments enabling the expansion; AND
o The expansion would help to make the facility more self-sustaining as
required under FAA grant assurances and County policy?
. Within the context of such a limited EPF expansion area, may limited, low-
intensity aviation as well as non-aviation-related light industrial uses be permitted
within the limits of an airport EPF situated in a rural unincorporated area if
o The scale and intensity of such uses is restricted to maintain the
surrounding rural character;
o The uses would not create a demand for urban services; AND
o Allowing limited non-aviation-related uses is necessary to ensure the
financial viability of the facility?
The record and the law support the Board of County Commissioners in answering, "YES"
to both ofthese questions. Accordingly, we strongly urge the County Commissioners,
based upon careful consideration of the entire record before you and the
recommendations of both the Planning Commission and DCD staff, and consistent with
the broad range of discretion and deference expressly afforded counties under RCW
36.70A.3201, to APPROVE the proposed EPF expansion and overlay zone.
Thank you in advance for your thoughtful consideration,
~7 c:-..<d 1'"
Larry Crockett, Director
Port of Port Townsend
----
Port of Port Townsend
Comment Letter
8
December 14. 2009
. ,
HEARING RECORD
GOODSTEIN
LAW GROUP
PLLC
100 I Pacific Ave, Ste 400
Tacoma, W A 98402
Fax: (253) 779-4411
Tel: (253) 779-4000
Carolyn A. Lake
Attorney at Law
clake@aoodsteinlaw.com
RECEIVED
14 December 2009
DEe 14 2009
Hand Delivered
Jefferson County Board of County Commissioners
1820 Jefferson Street
Port Townsend, WA 98368
JEFFERSON COUNTY
COMMISSIONERS
Re: Comprehensive Plan Amendment MLA 09-77, Port of Port Townsend - Rezone
Rural Residential 1 : IOta Airport Essential Public Facility/Airport Overlay III for
non-aviation-related light industrial/manufacturing.
Dear Commissioners:
This Firm represents the Port of Port Townsend in support of Comprehensive Plan
Amendment MLA 09-77, Port of Port Townsend - Rezone Rural Residential 1 : 10 to
Airport Essential Public Facility/ Airport Overlay III for non-aviation-related light
industrial/manufacturing. We urge the Commissioners' support for the Proposal. We
appreciate our opportunity to address the Board at its 7 December 2009 hearing on this
matter, in which we specifically addressed planning and legal aspects of the proposed
amendment.
We first thank the County Staff for their recommendation to approve the amendment. The
County Staff has spent much time considering the Proposal's impacts and benefits, and
consistency with the County policies and procedures.
Staff s approach, especially Mr Dave Johnson, has been thoughtful, thorough and
considered. We especially endorse the County's memo which addressees point by point
the issues raised by representatives of the City of Port Townsend. On behalf of the Port,
we endorse that response, and to extent it addresses legal issues - we add to it.
A. Authority iu Support of the County's
Comprehensive Plan Amendment MLA 09-77
Support for the County's adoption of the re-designation is found in several numerous
authorities:
. State Laws: As you likely are aware, numerous state laws call for the protection
and expansion of regional airports like Jefferson County International Airport, and
its essential public facility designation. These citations are almost too numerous to
list, we refer to RCW 14.07.010 (broad authority to acquire maintain and operate
municipal airport facilities, RCW 14.08.120 (broad authority to enlarge, improve,
. <
Jefferson County Board of County Commissioners
Support for Port of Port Townsend Re-designation
14 December, 2009 - 2 -
maintain and equip airport facilities), RCW 36.70.547 (comprehensive planning
requirements for airport and surrounding airport properties), RCW 36.70A.200
(GMA planning for Essential Public Facilities, such as airports), RCW 36.70A.510
(GMA planning for compatible uses surrounding airports), and WAC 35-195-340,
(planning requirements for Essential Public Facilities).
We also refer the Board to the September 7, 2004 notebook of authority on Airport
Planning, ("Protecting the Future of the Jefferson County International Airport
and an Essential Public Facility") authored and compiled by former Port attorney
Mary Winters, which we referred to by County Staff in a memo supporting the
Port's Proposal. We request that this treatise be included in the Board's record for
this proposal.
. Prior County Actions: We applaud Jefferson County for the steps it's taken to
carry out that state law mandate. These actions include:
. Designation of the airport as an essential public facility
. Adoption of overlay protection zones to protect this resource from
incompatible uses,
. The 2004 Settlement Agreement and Comprehensive Plan provisions which
laid the groundwork for the County's continued study with the goal of
strengthening the airport's economic viability - to include zoning of
compatible uses including appropriately scaled non aviation industrial and
commercial uses.
The County's commitment for future airport use study and action is found in Port-
County Settlement Agreement at page4, County Resolution 71-98, No 6 and the
County's Comprehensive Plan policies EPG 2.0 and 3.0 and EPP 2.2 and EPP 3.2
(pages 9-7 and 9-8) and Strategy B (page 9-11) which direct the County to
cooperate with the Port to develop a plan to guide future development at the JCIA
to include evaluation of non-aviation land uses and activities.
The Board's current consideration this proposed re-designation addresses that next
step envisioned in the Settlement agreement and the Country's past actions. Thus,
after acting to discourage INCOMPATIBLE uses, the County's companion piece is
to now act to allow for COMPATIBLE uses.
. Consistent with Port State Law Mandates: The uses proposed (light
industrial J. t~ S811Mn~1!ild) fit with the airport use, comply within state law
mandates, and carry oftf the Port's mandate to be a promoter of economic
growth for the county and region.
The consistency with county state and even federal support is borne out by the fact
that FAA already willing to issue a grant for JCIA industrial planning, as discussed
in depth by the remarks to the Board dated 7 December and 14 December 2009 of
Eric Toews and Larry Crockett, Port Executive Director.
091214. Itr. County BOC
28050
Jefferson County Board of County Commissioners
Support for Port of Port Townsend Re-designation
14 December, 2009 - 3 -
Most significantly, the Proposed Re-designation is consistent with the vital
and essential purpose the Port: to create jobs
The state Legislature has issued a specific charge to Ports to promote economic
development (see Title 53 RCW).
The Port of Port Townsend's adopted Mission is to "responsibly develop property
and facilities that encourage job creation, private investment, local economic
stability and diversity, and to better the quality oflife for citizens throughout
Jefferson county"
The Port's District encompasses all of Jefferson County, therefore the Port's
economic benefits are cast county wide.
. Lastly - we write to assure the Board there is no legal preclusion for the
Comprehensive Plan proposal
The City of Port Townsend has a flat out losing argument when it cites City of Des
Moines v. Port of Seattle (97 Wn. App. 920) as support for the notion that "only"
uses "necessary to support an EPF" are protected by state law. The city argues that
"Uses that are not necessary support activities, such as unrelated light industrial
uses, cannot be afforded the same protection." (Emphasis the City's). The City is
wrong.
The relevant portion of the Des Moines case makes it clear that the case stands for
just the opposite. In that case, the Growth Board found that cities could not
preclude siting of the Sea Tac Third runway, pursuant to RCW 36.70A.200(1) and
(5) 1 , which requires jurisdictions to provide a process for and not preclude the
siting of essential public facilities, such as airports.
The opposing Cities in Des Moines argued the third runway was an "expansion"
and not the siting of the airport, and therefore this protecting state law did not
1 RCW 36.70A.200:
(1) The comprehensive plan of each county and city that is planning under RCW 36.70A.040 shall
include a process for identifying and siting essential public facilities. Essential public facilities
include those facilities that are typically difficult to site, such as airports, state education facilities
and state or regional transportation facilities as defined in RCW 47.06.140, state and local
correctional facilities, solid waste handling facilities, and in-patient facilities including substance
abuse facilities, mental health facilities, group homes, and secure community transition facilities as
defined in RCW 71.09.020.
(2) Each county and city planning under RCW 36.70A.040 shall, not later than September 1,
2002, establish a process, or amend its existing process, for identifying and siting essential public
facilities and adopt or amend its development regulations as necessary to provide for the siting of
secure community transition facilities consistent with statutory requirements applicable to these
facilities.
...
(5) No local comprehensive plan or development regulation may preclude the siting of essential
public facilities.
091214.1tr. County BOC
28050
. '
Jefferson County Board of County Commissioners
Support for Port of Port Townsend Re-designation
14 December, 2009 - 4-
apply. The Growth Board rejected this claim, relying on WAC 365-195-340, which
directs that "the broadest view should be taken of what constitutes a public
facility." The Court on appeal upheld the Board's decision.
Even more damaging to the City's argument (and use of this case) is that the
project at issue in the Des Moines case, the Sea Tac third run way, pre-dated a
1998 legislative amendment which strengthened the protections and ability of
EPFs to expand.
In 1998, seven months after the Board considered the Sea Tac runway issue, the
Legislature enacted House Bill 1487, which added a new section, Section 7, to
RCW 47.06 (which states that "[i]mprovements to facilities and services of
state-wide si~nificance ... are essential state public facilities under RCW
36.70A.200."
RCW 47.06.140 provides in pertinent part that:
Improvements to facilities and services of statewide significance identified
in the statewide multimodal transportation plan, or to highways of
statewide significance designated by the legislature under chapter 47.05
RCW, are essential state public facilities under RCW 36.70A.200.
In turn, the statewide multimodal transportation plan refers to aviation planning:
WSDOT encourages ports, special districts, airport
sponsors, aviation interests, and local jurisdictions to
form partnerships and to work together to discourage
incompatible development. The Aviation Division provides
2 RCW 47.06.140: "Transportation facilities and services of statewide significance - Level of
service standards. (I) The legislature declares the following transportation facilities and services to
be of statewide significance: Highways of statewide significance as designated by the legislature
under chapter 47.05 RCW, the interstate highway system, interregional state principal arterials
including ferry connections that serve statewide travel, intercity passenger rail services, intercity
high-speed ground transportation, major passenger intermodal terminals excluding all airport
facilities and services, the freight railroad system, the Columbia/Snake navigable river system,
marine port facilities and services that are related solely to marine activities affecting international
and interstate trade, key freight transportation corridors serving these marine port facilities, and
high capacity transportation systems serving regions as defined in RCW 81.104.015. The
department, in cooperation with regional transportation planning organizations, counties, cities,
transit agencies, public ports, private railroad operators, and private transportation providers, as
appropriate, shall plan for improvements to transportation facilities and services of statewide
significance in the statewide multimodal transportation plan. Improvements to facilities and
services of statewide significance identified in the statewide multimodal transportation plan, or to
highways of statewide significance designated by the legislature under chapter 47.05 RCW, are
essential state public facilities under RCW 36.70A.200.
091214. Itr. County BOC
28050
, ' . '
Jefferson County Board of County Commissioners
Support for Port of Port Townsend Re-designation
14 December, 2009 - 5-
research documentation and best managemeut practices
and tools that cau be used by local jurisdictions and airports
to address land use compatibility adjacent to airports.
The Des Moines case discusses the amendment, but held it was uot directly relevant to that
fact situatiou, as the amendment occurred after the SeaTac activity.
Even without this strong legislative endorsement of expansion of EPFs, the Des Moines
Court held that "... the expansion of an existing EPF, including necessary support
activities associated with that expansion, is protected by RCW 36. 70A.200." The Des
Moines case makes clear that uot just "necessary support activities" are protected, but
instead any EPF expansion is protected, by the Court's language which describes
"necessary support activities" as a subset of the protected activity: "expansion of an
existing EPF". Relevant portions of the Des Moines case are attached in endnote i. i
B. Response to Foster Pepper Letter of 3 December 2009
The Port received a copy of the City's Memo and attached 3 December 2009 letter from
Foster Pepper Finn last 7 December 2009, and responded to it verbally at the 7 December
Commission meeting. We memorialize the Port's response below.
1. Foster Pepper Conclusions Based on Incorrect Premise.
Foster Pepper's initial description of the Proposal (rezone of property adjacent to an EPF)
is incorrect. Instead, the current Proposal is to expand EPF and within that EPF to allow
supporting non-aviation uses. The Law supports this in several ways:
WAC 365-195-340 directs that "the broadest view should be taken of what constitutes a
public facility." This law is further strengthened by the later enactment ofRCW
47.06.140, which specifically includes expansion uses which support EPFs as activity
protected from a local jurisdiction's action to preclude.
The comments received by the County from WSDOT support this point: where that state
agency endorses the re-designation and points out "light industrial uses are considered
compatible and ... complementary to aviation facilities".
2. Foster Pepper Challenges to County's SEP A process Also Unfounded - Both
Procedurally & Substantively.
(Procedurallv) - The County's SEP A determination is correctly in the form of an
addendum. Addendums are non-appealable decisions because they issue when a proposal
will not create significant changes to a prior determination. The review and studies
undertaken by the County show that to be correct, as explained below.
Substantivelv - Foster Pepper attacks SEP A on three grounds: water, transportation and
as improper piecemealing (project review segmentation). All are unfounded.
091214.1tr. County BOC
28050
Jefferson County Board of County Commissioners
Support for Port of Port Townsend Re-designation
14 December, 2009 - 6-
First, we will not address the water issues, as the County Staff rebuts this City claim
aptly in its 5 page response to City comments - where the City properly cites to reliance
on the water purveyors - the Jefferson County PUD which has expressed support for the
proposal and assures the county that adequate water supply exists. We also cite to the
remarks by the PUD's representative at the 7 December Board meeting as well, which left
no doubt as to water availability for this Proposal.
Second, the transportation study that focused on this proposal is complete, per Report
of traffic experts the Transpo Group dated 29 September 2009. The fact that this sub
element is part of a larger Transportation Plan (Quimper Peninsula Transportation Study)
which is not yet complete does not detract from this portion's viability.
3. Third, Foster Pepper counsel uses select numbers to challenge the Transpo
Group's traffic report, and cites them inaccurately.
The Foster Pepper letter claims that by 2031 (20 years hence) "four intersections with SR
19 will be at LOS F". Yet, the letter fails to disclose that the Traffic Study points out that
all four of these same intersections will be at LOS F with or WITHOUT the re-
designation. The Transpo Study also goes onto to conclude that "Any planned
improvement that would alleviate the "No action LOS F would likely alleviate 2031 With
Project impacts" at these intersections."
Thus, County's SEP A analysis & use of addendum is sound, based on the Traffic Study's
conclusion that: "No significant impacts are shown to take place due to the proposed land
use designation"
One additional traffic comment to add is, as these site-specific light industrial/commercial
Airport support proposals are planned and undergo their site specific environment review,
the Count's review process provides a vehicle to obtain any needed transportation
improvements as project mitigation. In contrast - the SEP A no action alternative leaves
the LOS F intersections unaddressed & unfunded.
4. Finally, fourth, Foster Pepper's "Piecemeal" Argument is unpersuasive.
The pertinent section of the SEP A regulations pertaining to "piece-mealing" is WAC
197-10-060(1) and (2), which provide in part:
(1) The proposal considered by . . . the lead agency during the threshold
determination and EIS preparation, shall be the total proposal including its
direct and indirect impacts. . . .
(2) The total proposal is the proposed action, together with all proposed activity
functionally related to it. Future activities are functionally related to the present
proposal if:
(a) The future activity is an expansion of the present proposal,
facilitates or is necessary to operation of the present proposal; or
091214.1tr. County BOC
28050
Jefferson County Board of County Commissioners
Support for Port ofport Townsend Re-designation
14 December, 2009 - 7 -
(b) The present proposal facilitates or is a necessary prerequisite to
future activities.
"Piecemeal review is permissible if the consequences of the ultimate development cannot
be initially assessed". Cathcart-Maltby-Clearview Comm'ty Coun. v. Snohomish Cy.. 96
Wn.2d 201, 210, 634 P.2d 853 (1981).
SEP A does not require that every speculative consequence of an action be included in a
project specific environmental review. Richland v. Franklin Cy. Boundary Review Bd.,
100 Wn.2d 864,868,676 P.2d 425 (1984).
A project is not "piecemeal" under SEP A, where as here, the County properly reviewed
the preliminary phase (here, this re-designation) because that action "does not preclude
meaningful and comprehensive review of the environmental effects of future development
that may occur at the site". The County's current programmatic non-project SEPA review
will be supplemented by project specific SEP A analysis as specific projects are planned,
details are known, and environmental impacts can be more meaningfully addressed.
Tugwell v. Kittitas County, 90 Wn. App. 1, 12,951 P.2d 272 (1997) tells us that without
site specific Project details, "Examination of [an anticipated development's] potential
impacts" is speculative (and therefore meaningless) since "there are no specific plans to
review and the impacts therefore are unknown." Here, the County's Traffic Report made
appropriate assumptions about impacts - which will appropriately be supplemented on a
site specific basis in the future as specific projects come on line and their environmental
impacts can addressed in more detail.
The Transpo traffic study points out this fact in its conclusion: "Subsequent analysis of
site specific traffic impacts should be evaluated during project level review" (page 3)
C. Conclusion
In conclusion, we urge the County Board's support of Comprehensive Plan Amendment
MLA 09-77, Port of Port Townsend - Rezone Rural Residential 1 : 1 0 to Airport Essential
Public Facility/ Airport Overlay III for non-aviation-related light industrial/manufacturing.
The Proposal is:
. Consistent with state law protection foe EPF and Airports
. Consistent with past steps by Jefferson County, embodied in Comp
Plan and iucluding its agreement with the Port
. Not legally prohibited as state law supports expausion of an EPF to
add supporting & what WSDOT called complimentary uses,
. Consistent both with state law on expansion of EPF aud gives needed
support for the Port's state mandated mission for ecouomic growth,
and job creation.
091214.ltr. County BOC
28050
Jefferson County Board of County Commissioners
Support for Port of Port Townsend Re-designation
14 December, 2009 - 8 -
We thank the Board for their consideration. Please contact us if there are any questions
regarding this matter. Thank you.
Sincerely,
Goodstein Law Group PLLC
Carolyn A. Lake
CAL:dkl
cc: Larry Crockett, Port of Port Townsend
Robert Goodstein, Port General Counsel
i Relevant portions of the Des Moines case are below. Note: the case refers to former RCW
36.70A.200(2), which now is codified at RCW 36.70A.200(5).
2. Application of RCW 36. 70A.200(2)
ill The Cities next contend that RCW 36.70A.200(2), which provides that "[n]o local
comprehensive plan or development regulation may preclude the siting of essential public
facilities," does not apply to the Sea- Tac expansion. The Cities concede that this provision
provides protection from local comprehensive plans that would preclude siting of essential public
facilities (EPFs), but they argue that RCW 36.70A.200(2) is inapplicable here because it does not
apply to expansions, nor to "remote, off-site 'necessary support activities,' " and that the Cities'
plan would not have "precluded"*844 the project. Relying on WAC 365-195-340, which directs
that "the broadest view should be taken of what constitutes a public facility," the Board rejected
this argument. FN7
FN7. We accord substantial weight to the Board's fmdings. See Northwest Steelhead & Salmon
Council of Trout Unlimited v. Department of Fisheries, 78 Wash.App. 778, 786-87, 896 P.2d 1292
(1995).
Whether RCW 36. 70A.200(2) Applies to Improvements or Expansions of EPFs
ill@RCW 36.70A.200(2) states that "[n]o local comprehensive plan or development
regulation may preclude the siting of essential public facilities," and RCW 36.70A.200(1) defines
essential public facilities as including "those facilities that are typically difficult to site, such as
airports." The Cities argue that because this provision makes no mention of "'expanding" or
"improving" EPFs which have already been sited, neither the Board nor the trial court was
authorized to expand the clear terms of the GMA. FK8 The Cities also argue that a recent legislative
enactment supports its claim that a significant difference exists between construction and
expansion. In 1998, seven months after the Board considered this issue, the Legislature enacted
House Bill 1487, which added a new section, Section 7, to RCW 47.06 which stated that
"[i]mprovements to facilities and services of state-wide significance ... are essential state public
facilities under RCW 36.70A.200." The Cities claim that this **33 amendment supports their
argument that prior to this amendment, improvements to airports were not considered EPFs.
091214.1tr. County BOC
28050
.0,
Jefferson County Board of County Commissioners
Support for Port of Port Townsend Re-designation
14 December, 2009 - 9-
FN8. The Cities point out that the Washington Supreme Court has indicated that the GMA does
not "contain the requirement that it be liberally construed."' Skagit Surveyors & Engineers v.
Friends of Skagit County, 135 Wash.2d 542,565,958 P.2d 962 (1998).
There are two problems with this argument. First, because of the political controversy
generated by the expansion, the bill's co-sponsor explained that the transportation committee had
to agree that the amendment would not deal with airports. Thus, the 1998 amendment specifically
excludes improvements to airports from the EPF defmition, *845 and this amendment has no
bearing on the Sea- Tac expansion. Second, the Cities do not acknowledge the likely possibility
that the amendment was a clarification, and not an alteration, of the previous law. As the
Washington Supreme Court has noted:
When an amendment clarifies existing law and where that amendment does not contravene
previous constructions of the law, the amendment may be deemed curative, remedial and
retroactive. This is particularly so where an amendment is enacted during a controversy regarding
the meaning of the law[[[[[[[[[[[[FN9]
FN9. Tomlinson v. Clarke. 118 Wash.2d 498,510-11,825 P.2d 706 (1992)(footnotes omitted).
If this amendment is a clarification, as the controversy surrounding the issue may suggest, then the
Port has a valid argument that HB 1487 simply explains that the Legislature had always intended
that improvements to EPFs should be protected under RCW 36.70A.200. Nevertheless, the trial
court correctly reasoned that because of the conflicting conclusions that can be drawn from this
amendment, "neither the rule of' expression unius est exclusio alterius' nor the argument that the
EPF definition has now been legislatively clarified to include airport improvements"' is available to
either party.
Deprived of its HB 1487 argument, the Cities are left with a claim that the plain language of
RCW 36.70A.200(2) says nothing about "expanding"' or "improving"' EPFs which have already
been sited. But the DCTED regulations, to which the Cities urge this court to defer on other points,
indicate that in "the identification of essential public facilities, the broadest view should be taken
of what constitutes a public facility."' FNIO Accordingly, the Board determined that the third runway
was an essential public facility. We defer to the Board's interpretation of the law and conclude, as
the trial court did, that "the requirements of RCW 36.70A.200(2) apply to all essential public
facilities (EPFs), *846 whether or not the EPF was in existence prior to the GMA."' This
conclusion comports with the fundamental reasoning behind identifYing EPFs and giving them
special significance under the GMA-the fact that cities are just as likely to oppose the siting of
necessary improvements to public facilities as they are the siting of new EPFs.
FNIO. WAC 365-l95-340(2)(a)(il.
Whether EPFs Include "Necessary Support Activities"
ru@l'W@fTheCities argue that even if the EPF provision applies to the Sea-Tac expansion,
the "critical issue"' before this court is "whether the trial court and the Growth Board erred in
determining that this provision is so expansive so as to cover remote, off-site <necessary support
activities.' "' The trial court affirmed the Growth Board's ruling that off-site dirt-hauling activities
conducted by the Port within Des Moines are protected under RCW 36.70A.200. The Cities claim
091214.ltr. CountyBOC 28050
.. l' ~ ~
Jefferson County Board of County Commissioners
Support for Port of Port Townsend Re-designation
14 December, 2009 - 10-
that because "support activities"' do not appear in the GMA, the Board and the trial court cannot
add them. But again, the DCTED regulations urge that an expansive view should be taken of
essential public facilities. WAC 365-l95-340(2)(a)(i) indicates that identification ofEPFs should
include "the full range of services"' provided both by government and by private entities. In
addition, section 340(2)(c) states that no comprehensive plan may "directly or indirectly"' preclude
the siting of an essential public facility. The legislative purpose of RCW 36.70A.200(2) would be
defeated iflocal governments could prevent the construction or operation of an EPF. Thus, if an
activity is indeed "necessary"' to an construction of an EPF, a local plan may not stop it from
occurring. The Port has convincingly demonstrated that the runway cannot be built without
constructing a site that is level with the existing airport, and that this construction**34 will require
hauling dirt through the cities surrounding Sea- Tac to the site itself. The Port will undoubtedly be
required to mitigate the impacts of this construction on the surrounding communities, but because
construction is impossible without these support activities, the Cities cannot stop them from
OCCUlTIng.
091214. ltr. County BOC
28050
cC
I) 6) oS
~A; 5
\Z/I'-1/cA
HEAR" i~~.'.I"""''''f''i\'''<<.f'\~'''''''
", " f"- ~ ';"\- ,;,~t-~"Il "-:, J J," :;
;."i" '. J, ''''''i~~'~.~i''i~U
1!0 Fa S T E R PEP PER '.U
Direct Phone (206) 447-7909
Direct Facsimile (206) 749-2093
E-Mail drums@foster.com
December 14,2009
K EIVE
Jefferson County
Board of County Commissioners
P.O. Box 1220
Port Townsend, W A 98368
DEe
J COll Y
'S"CION~(~! '....
i ..;)._H~
Re: Port of Port Townsend Rural Industrial Zoning Proposal
Dear Commissioners:
The City of Port Townsend appreciates the County's consideration of these further
comments. This correspondence briefly addresses questions raised during the recent hearing
regarding the Port of Port Townsend's proposed 24-acre zoning/comprehensive plan amendment
from a rural land designation, to authorize non-aviation, industrial uses ("Proposal").
1. The 2004 Comprehensive Plan Amendments Do Not Mandate The Proposed
Zone And Comprehensive Plan Amendments. Rather, The 2004
Amendments Direct A More Thorough Planning And Development Process.
The 2004 Comprehensive Plan amendments do not "mandate" the proposed legislation,
which would transform 24-acres of rural lands (currently designated R-lO), to a site for industrial
uses. Rather, the Plan recognizes future planning will occur, while also recognizing the
mechanism for siting industrial uses on Port property remains unresolved. In referring to future
amendments to implement County Ordinance No. 16-1213-04, the adopted staff report stated;
The amendments will address the future use and development of property owned or
acquired by the Port in the vicinity of the JCIA. . . .
The amendments may take the form of permitting non-aviation light industrial
uses at an appropriate scale within the AEPF, or amendments utilizing other
GMA-complianttools such as a major industrial development or an industrial
land bank (pursuant to RCW 36.70A.365 and RCW 36.70A.367), or urban growth
area (RCW 36.70A.llO).1
The Port also acknowledged this approach for a considered analysis of both use and
development when it submitted its 2004 proposal to the County. The Port listed the mechanisms
which could be considered to accomplish its goals. The Port listed not only zoning changes, but
also "designation of the JCIA [Jefferson County International Airport] and surrounding
I Ordinance No. 16-1213-04, Section 1, incorporating attachment (see pp. 3-4 ofattachroent, emphasis supplied).
lFI.: 206.447.4400 FAX: 206.447.9700 11L THJRD AVL~Ut:. SUTE 3400 SEATTLE, \,lASHI ,\fGTO~ ~iHOl-3299 w\v\v.FOSTER..ul\l
SEAfTLE WASJIL\lGTO'l SPOKANE W,\SHIJ'\GTO!\
December 14, 2009
Page 2
properties as part of a UGA; designation of the JCIA and surrounding properties as an industrial
land bank site; or designation as a major industrial development site."2
This statement is consistent with GMA, which recognizes that industrial uses, when not
properly sited, pose a risk for rural areas; and, trigger excessive costs when industrial uses
contribute to sprawl. Similarly, the Jefferson County planning policies recognize new industrial
uses should be sited in rural areas only where an existing UGA does not provide the preferred
location. "The rural element of the comprehensive plan will recognize existing industry located
outside UGAs, as well as establish a framework for the siting of industries, which due to their
size, resource dependence, or incompatibility with UGAs, would be better suited to locate in
rural areas."3
The County's SEPA analysis did not consider these issues, or other impacts, such as air
quality and water supply planning issues.4 Rather than being planned for, the proposed industrial
uses in the existing rural zone will require capital facilities and services, including stormwater,
water supply, and transportation. Those systems are inadequate to serve the proposed industrial
uses, as addressed in the City's previous correspondence.
As all parties at the time recognized, a future planning process (including consideration
of future development) would be required to address these issues. Consistent with the County-
wide planning polices, this process was not designed to be a "rubber stamp," but a considered,
GMA-compliant process which involves genuine City-County-Port consultation and
coordination.5 The process identified in 2004 has not been followed. Instead, the Port asks the
County to adopt, without further analysis, industrial zoning in a rural area of the County. The
County properly directed the course of review in 2004. That course has not been followed. As a
result, the Port's Proposal must be rejected.
2. The Port May Have Authority To Develop Non-Aviation Related Uses.
However, As The Port Has Stated, This Does Not Mean The Uses Are EPFS.
The Port has recognized that its ownership of the JCIA does not convert all property it
owns into an EPF. "The JCIA consists of approximately 316 acres ofland owned by the Port,
2 Port of Port Townsend, Protecting the Future of the Jefferson County International Airport as an Essential Public
Facility: Statement of Legal and Factual Position (September 7, 2004), pg. 33.
3 CPP 8(6).
4 See e.g. WAC 197-11-444; RCW 70.235.020. Attached documents include, power point, Meeting Future Demand
In the Quimper Water System (May 12, 2009); Chapter 173-517 WAC; and Growing Cooler - The Evidence on
Urban Development and Climate Change, Urban Land Institute (2008).
5 "Incorporated UGAs will coordinate with the County to assure joint review for addressing those development
activities of a regional nature, such as a regional shopping center or large industrial complex. The purpose of this
agreement is to insure impacts of a regional nature are addressed and the goals of the GMA are realized." CPP 3(5);
see a/so CPP 4(2) ("The County and incorporated UGAs will jointly develop specific siting criteria for siting
essential public facilities. The proposed criteria will be considered in the drafting the comprehensive plan policy
addressing this issue."); CPP 4(4) ("Criteria will be established that address the provision of services when siting an
essential public facility.").
December 14, 2009
Page 3
280 acres of which are part of the Essential Public Facility."6 The fact that the Port seeks to
rezone a portion of its holdings from rural uses (R-I0) to allow for industrial (non-aviation)
uses, does not mean it is "expanding" the Airport itself, or that the unidentified industrial uses
are necessary support activities for the Airport.
The Port has recognized the significance of a regional siting process, consistent with
analysis submitted to the City dated December 3, 2009, which was forwarded to the County. As
the Port stated, "[0 ]nce a regional decision has been made to site or expand an essential public
facility, the city or county must re-evaluate and/or amend its comprehensive plan to determine if
it still complies with the GMA."7 Here, no regional decision has been made to rezone 24 acres
for non-aviation related, industrial airport uses. Simply because an entity engages in economic
development does not convert proposed uses into EPF's. Such a rationale would support siting
any use (e.g., a Wal-Mart) as an EPF. GMA does not support such a broad interpretation of
EPFs.
It would be a better use of public tax dollars, and better serve economic development
objectives, to support infill and redevelopment within UGAs. GMA was enacted to address
precisely this type of situation, and reduce the costs of sprawling development.
3. Conclusion
The City urges the County to coordinate with the City to resolve these issues. The City is
willing to contribute financially to support responsible planning. We hope the City, Port, and
County are able to coordinate on a satisfactory resolution.
Sincerely,
FOSTER PEPPER PLLC
.7 r/? 1""'\0 /)
/-(.1f!6>/~JJ{>-L&~
P. Stephen DiJulio
Susan Drummond
cc: John Watts, Port Townsend City Attorney
Attachments
6 Port of Port Townsend, Protecting the Future of the Jefferson County International Airport as an Essential Public
Facility: Statement of Legal and Factual Position (September 7, 2004), pg. 4.
7 Id., pg. 9, citing to Central Puget Sound Transit Authority v. City ofTukwila, CPSGMHB No. 99-3-0003 (FDO
1999), pgs. 6-7 ("after the regional decision is made, the city then has a duty to accommodate the essential public
facility.").
ATTACHMENT 1
County-Wide Planning Policy
COUNTY-WIDE PLANNING POLICY
for
JEFFERSON OOUNTY. WASl:l1 NGTON
~.l:UTA
JEFFERSON COUNTY/CITY OF PORT TOWNSEND
STAT$<Q$tt 'WAS':HINQ"fON
In lha MatI/If 01 rhe Adoptioo }
01 County.wide Planning Policy )
COUNTY RESOUJTION HO.125-9~
CITY RESOLUTlOM NO. ~
WHEREAS. Chapter 3S.70A.l!1() FlC.W. (tIl.. Growll. Manageffl<mt Ad,
GMA) <ll,ecl. tho county. In cMperllljM will\" jl$ eill'!$. 10 d,!velQP a CO\Jl1ly.wioa
Planning PoHey 10 bl> used ... " polley <fl1l<fT","1>rk Imm which county an\! c!ly
compr"h"n.llla plao$ an 10 be dl>veloped and adopled: and
WHEREAS. hy jolnl m.OIYIIO" (County Re,olution No. ].07-91. City
~~,~<>!~l~...._t-IQ~:OJ :OO) ~",lt~~?(\-C~.J"iY_~I'l!!_:lfj!--~~W_-l>f f'~rtl"Q_W:J'\",!>"4; .Q~lr)i~~jj;hJ}~ ~
Growth M""3.goment CommIU.... 10 oYllrooe Ill.. devalopment of 1111$ policy: and
WHEREAS, 111.. County and City h'IV" jolnll)' developed !his polley <as a
loyndation Ir"", ",hloh w ju<!g" "",...i.lency between County and City "Qmpr"henslva
plans. and lh" raquit"",,,nl$ 01 GMA; and
~j,:J~1J'r;A:g.: J~(ff:~l;,,,,~f .~~.:tl\.'- i?:"" "*-"'061_",~~~, >th"''"ArO'~Aft'~~_?~:t;}.rtr_..,:J
CQmmitl~., con<l"otad. On Sepl"mber 21, 1992; a public hearing lor lhe adt>pllol'rof<lho
County.Wide Pllln61n9 f>oUcy; arid
WHEREAS. following the pvblie h".ring. and reviaw and dlseu$.iofl <>f lho
put;r.o l".'imony. lho County-wid" Plafl!"!li1g "oliey was r<lVised by thil' Growth
Management Commi<<.,,: and
WHEREAS. Ihe Growth Man.gem"nl Gommill... <li<i. on No""mbof 24,
19!/2. COnduc, ilS final ,,,viow olllle County'wide Pfanning P~licy, 00<1 by formel mOlion
,,,corMieMS !hat the Jafferson County Board 01 Commls$iQner. ""d 111" City Council
of 1"." City 01 Pon Townsend Joinlly adopt Ihese pollci.. con.i.tent wIth 1M
'equ"amenls 01 Ihl> OMA.
NdWTN~PlEFCJREr::9~ 1T'-f1_t;sDtV:15n t~l ~h~Ct'itlnJY~w1A!!>PI1lrUlft"!"
Polley, alll11c{1e<l M, e::x/1ibll A, I. ho(eby lldopled by Jeffe",on Cwnty ai'\d 100 City 01
Port TO.~~.:t'!'r~;;n' 10 1M joinl 'M"oIY~"" llOd/MI>te, 3ll.101\.210 Fl.C.W.
,,' ~, JlI ~ I
:. \" r AF:PRQVEO. AND SIGNED Ihis SL. day 01 \}lo\ ><JL . 1 fl92.
.. ~
,''''':'
$"-'It;t' \
'; !It _~_ \:;
Am::sT: .' "'--:'.,
{~cy:~,;jIJ1;~
Lorna L Oela",,)'. q
Cl,o.;;-k- _(\if ff't.!> 9,o$fr4
JGI"i=G"'SON COUNTY
~,;:~
""'$on. halrmal1
ATTeST:
/
APPROVED AND SIGNED Ihi"~d"y of A<, .l~ ,1992_
TOWNSEND
--
JfFFEfl::.ON COUNTYfCiTY OF PORT TOWNSE:NO
STATE OF WASHINGTON
INl1lEMATTE ROFafleso lu. 1'011 ."",nding1
CounW-wJdll Pla"ning l'".cy, County
Re.Qlu1tq" No. 128-11Z an" City
OOSOltJtl0n NQ.i92-",11Z;"IV'Lh.;,ugctho
<l..f,nll(Qtl 01 . affordablo hovslng.'
COUNTY RESOLtmON No, 112-9'
CITY RllSOLUl'lON NO. "J.in
WHEREAS, lhe pre.ont CQUllly.Wida f'iannlng Policy, roUe\" #G.l, .~1..~
'!"ol planning p"rl'o"" the ~efonltion ,,' 'sf!ofdablll'hOllslng' is: hou$ln ·
~\~~l~l1f(i:ft\r' plJtt,htf!!l,A'.orrQntto irn~lyfdu. 'm. _ i~~t,\M1tttflJl'
'~i){!'t.idl;'U'9'1!Y-{~PJ)r~;n;dPovenVI~y~J _ _ _ 9dt~rklMo/mOr()
J,eff~f~b~I€JQo/lty_;,antfwho'I'i _ cpS,t>$im lXtlaiti(f$:.: _wQuJd. :no{<exce
Qi-qSS'iOOqlT1(L"';:-and
WHEREAS.lhe Jelfllnl'>nCo""ly H(j\J
_ 16.' be changod to comply with the
Act 01 1993-, RC\lV43.18$il.010. wtdc "AI~
t-IV\;l';;to""~ ~1''?li''''>>'_'\-Qd~1__Q:~n~ciyy::~_pb'';''':g,ri ~f~
,s",lnc1t;J{ling,tjtHit1(3$ t}tflE~lc+~:a~ ,t(tl~p_hQJle)-:dQ'
hckt's:rrmntl1ty,. incQme..;,:~nd
wHEREAS, lhe eh.nge 01 dOlinitlQn was pro..l\led 1<.> tile "effe..".""
CQUfllY Growth Management Stoo,ing Commllle!' on Septernll.r 7, 1994; llnd l!:lev
lev,lewll<! and .greed to this chango: and
WHEREAS, tile J"ff.,,"on County t1oarOQt t;;0",",1$$1,0""," "Old . H".bll~'
he~'ing on $\>pt_ber 26, 191t4 where no publie testimony """$9''''''' for (l' llgalnsr
this ,,,oposed el18"O" and. motion was passod to .dopnhis chango.ln dllllni(ion;
<lnd
NOW THEREFDFlE i:lE tT Rl?SOLVED. thatlhe Counly,w,d. PlannIDiJ
PoliCY. poliey #8. L b. amended It> '<l<><l ". the definition $tal"d in ttm',Wa"l>in;llM
t,~~i0:9r(il-i~yAGl; b:f10DS.- A:CW1!:3.1n!?S',:OiJ'l.:39''\I:1;9tJ1'<'i$th~~r; ,', ,,'
"', ' ,---i'-II
APPROVED AND SlGNW this L'r-day 01 aft.{Mrl!~ . f994.'
Jl:FFEf1S0N COUNTY
BOAR!) OF COMMISSIONe/lS
a
APPROVED ANa SIGNED this
iJ~Iie"'~ 1994,
F ~ fiT TOWNSEND
AT\'l:ST:
jL)d~-,
P~vld J';;f'()YC~ lilty t.;lt;fJ{
o~\11t-oUp.~lli~\.9mi"ewPP\htIl;JijnO';flV1Illl
vtll 20 fit' 0 1.554
,JEFfERSON COU""TYICITV OF POJ;l.TTO\\1'lSEND
STATE OF W ASHINO'tON
In the Malterof Adding the
PUrl of l'on TowllSend OS'a
Vor/nll Momllet of the
JDinl GrDwth Managemelll
SteeringJ'2.l1tmtllttee
I
,
,
COlJNTI RESOLUTION NO. 41l-!11t
CITY RESOUJTIOl'! _'W. '19-0;10
\VHEREAS, by Jrnnt resolmion (County Resoluti<>n No. 107-9]
Co\lflty a,lld the City of POri TOV\'Xlsend est.~blished a GrQWth
devalol'ment of this, potiey: .nd
Wt%IlliAS, by joint re.olulil>n (Couoty Resolytion No, 1211.92 and Cily Resolution No. 92.112) the
Courtty .lId Cily,ol"l'ort To'vnsendjoinlly adoplCd Calmty'.wlde PlartnlJtI!'I'o!icl(J$ on l;"eemoor ..II. 1\I9~
Ms-a lbundaUonJr-otfl'!\.yhjch lt1jud~(vcoosistency het\Y~n;'C":~)uoty f):nd;eily:C(trnp:rehensh'eP-lJiut~;:ai)d
WHFREAS, both lile County ComprebtmSlVe Plan And the City "fl'ort 'fown,"nd COOIpreheM'vl' Plm1
com~j'l (;h.ptl'r~ Oil economic devdopnV:J11; and
WHf.:REAS. County.",vle Planning,l'ohc), #7 $Ubset:lion 5 ,tates thar the Pll,t I'or! TOWll~'l1d'5
le'l;i,J.1tive authority >hould be utilized as a tool to "nplemem industry and trade strntellie$; molndillg the
:~1l9t~'fi of;q~l1J~lp~'n1Yrtt,,'lI,p(~r~'4ni~<i:$; i1\*e~'Hli;{)lid4ttiQ:n .;m~..p~~~jit1J3; 9tp_l'9~' _-~:th,~
develol'JUl'llt of infr.:;tructure to meet the ""OOs of indmtry cons[Sl<lm with oolllprehensive pllUl$ and
d:evet@rn<:nt- n!![tII~t!ol)s~,-tll1d
WHER,EAS, the Joint urowili Manaboemenl Steermg Committee al tb~-ir AI>ril 7. 1'(9!l m~cotillg voted
ultllllimously to recommend (hat n public bearing be held in ""nsideranon of tlte Port of POrt T""'Xlserui
tlpt;U:Il~ttlg-a :yuuuM-ni~mhec
NOW, THEREFORE BE IT RESOLVED. lI",t the Port of POM TOW11"""G shall be lIlvited to rike a seil!
on the lolnt Growth Management Steering Cummit\ee and If the invitalion is ac<:epu:d shall be <""Mdcred
3v(Jt:io!5'meUlhn::L
Res'olutlcm: N{)o 40':99
APPROVE!)..uID SK1NED THIS
OF
SEAL
JEFFERSON COt,'NTY
BOARD Of COMMISSIONERS
.G(jc{
1<)<)<).
~~
Farr... Raruha..Mayar
() J/ /
14%1 "'flL~Ji!~
PalllclaKolllcy U
City Clcrk
Ro,OJuuon No. 4U.<)<)
-,~-,-'-;;-".~~''''"';~'=-=-~'---~--~=~~-~
COUNTY.WIIJE'. PLANNING POLlCleS
A Powey fRAMBWORK TO GUIDE Tlffi DEVELOPMBNT OF
COMPREHBNSIVE PLANS
INTRODUCTION:
The opening section of the Growth Mana/lel1lent Act {RCW 36. 70A) seL~ fortll the
following legislative fulding:
"uncoordinated and I1l1p1anned growth [oge!her with a lack of CQmmon
goals ~p)"essing rue pu.blicrs. interest in the conservatioll :md tile wise use
of our lan!;ls, lX'Se a threat to rue tlnvir(ll1l1lllllt. sustllillllble wonomic
develop.mllll.t. and the health, safety, and high ljuality of . life enjoyed by
,th~,_:tIWtId~nu:-ottb~ rliit,.e-.-_
The legislaOll"!: went on ILl develop. a stale-wide. growtll IXWlllgement stratllgy encompassing
tile fOllowing goals;
. tlrbiIR growth. Encourage devdopment in ur"ban .ar~ where ad~\Illte plW1:ic
facl.lit;e.~ lU'ld services .emt or call be f1wvlded ill an efficient mllllller.
Reduce splilwL Reduce me iIlllpptopria~ conversjon Of I1ndevlllOjl(ld l:md into
sprawJ~. low...aensity devlllopment
TrlllUiportlllioll- Encourag<:: efficient multimoch!l ~lUItion Sj'SI(lIlls that arc
based 011 regiollll1 priorities and coordinated willi c<lUnty IIfld City comprellensive
plans.
Housir!g. Bncollrage the livail!lblllly of .on:Iablli: honsing .to all eaonomfc
seglllilnts of the population of lhis stale, prom<l~ a variety of residential
densities and hOllsing typc:i, and encourage prnservatiOll ofciClstil1i! housing
stllCk,
Economic developlllellt. EncQu~e econo.mi!:<le~l'lllilnt thrOlJ!!inCllJt the stille
that iSCOllSi$tQljt with adop\ed eOlllprl!llelll!ive>pJ!lllS.. promateWOnOmic oppor-
~uuty for all citizens Qfthis ~te. ~ialIy for Illlelllptoyed atld foc disad-
Vllnl:lged persons. and CIlcollrage growth in .a~ m<:p:rienej~ lm;uffieienl
economic l:TOwth, all within we cllJl'lcities of !he stille's natllml resOll1'\:ilS, public
services, and pu~Jic facilities.
Property rights. Pnvaw. llmpeftysnall not I)e Illken fur pubU. .u~ wllllUU! just
compensation having \1ei:n made. '!'he property rights of bndoWllers shall be
protected from arIli~ary atld i1lscrlmitillirory actions.
Permits. Applications foc bolll stilte IIfld local government pmnit.~ sllould be
proc.essed in a timely and. fair manner to ensure predictability.
Natural resource lJiOllMlli\L Malnllllll will ",dIlUte" P..twaJ r,,~-ba3cd
IndUStries. including productive tllllW, agriQUltllf.lll, and fISheries industries.
Encourage tbe conserviltion of productive f(lre.~ l;md$ and productive agricultur:l.1
lantls. and discourage incomp:ltlllle uses-
.
.
.
.
.
.
.
.
Open space and re<;reatiOl1. Encourage the r"lentTon of open space lllltl
development of n:crealional opportunities, conse~ fish and wfllllife habitat.
in<:Tease access to natural resource lantls alld Water, arnJ develop par1(s,
Environment. Protect the environment and enhance the state's hlgtI quality of
lif., includinG air and watCr 'lual;ty, dlld tlte dVilililvllity uf water,
Citiun participation and coordination. Bncaurage the involvement ofdti~ens in
the praMi"g process and ensure coordination between commUnities and jurisdic.
tillllS tQ recQncile conflicts.
Public facilities and :services. Ensure tIlat tIlose public 1;1cifitles and services
ti~:~,~~ry ",.~9:$:~Pptr'ct, a~vet~p"M~_(lJ_4huU be,Q~eqU,4~C', to_$(;~~,:,:tl1:~" -"'!ycl{!pln~:ll{;~l
tile time tOO develapment is available for occupancy and IISC without llecreasillg
cutrent :servke levels below lotany established minimum mndards.
Historic pteserva:tioiJ, ldelllify and encourage tile pt"(l.Servation of lallds, sires. and
structures, that bave historical or archaeological significance.
.
.
.
.
The passage of the Growth Mallagemem ACl (GMAJ fundamenl;dly Wnged tlre way com-
prehensive land use planning is carried out in lI1e milL The :GMA requlrestllat cities iIIld
counties update'thelr comprcllensive land use plans cOllslstel!t with stat~de g1lals lUlU
minimumtequi.n::menls as est:Ibllshed by the statute and coordinate their 'plilnni"Z effoTts willi
each other.1he central llIeme behind tile Growth MiIIlllgelllent AcliS tIlal SjlolltallCOUS and
unstructured growth and development 15 Wtlsteful of mrr natural resourccbase'^^ ,;lnd cost.! Y in
lI1e proli'lsion of public sernces and facilities; and by managing gl"owt!l iIIld deVelopment, tb.
negative effects eanbe minimized and the benefits can be maldmized. .
The act is built 011 the principle tIlat Cities and Counties, sp.ooilll putp9se districts and
those agencies Or junsd:ictiolLS involved in the deli very of public services win coordinate their
efforts (ll)llSlstflllt with each otller and the provisiollS of the act. tnlUl effort to assure these
principles are carried out, the legislature passed complUlion legiSlation r Col.llltles iIIld
Cities to coordlltale the independent development of local comprelJensiw tbrollgl1 It set
of mutuallY aevllloped {.'Ounty,wide Planning Polici(l.S. These written polICY mlements. are to
address eigllt S1ll;;ject areas and are intend to be used liS a gllidillg frameWorK ror $Ublrequent
development and aiJopt1011 of comprellensive plans. The required County-wi'lle Planning Policy
Sllbject al'ea$ inefllt$t':
. !.be designation of Urban Growth Areas
I''' UlllVUVU vf WfIUguOtlS ana orl!erly aeve,lOpmel1l lmll t.lle PfoviSlon 01 ur~an
services to well development
joilll county and city phtrllling wilhin urban growlh areas
the siang of essential public faciliti(l.S of a county Of state wide sillni(lCaJIce
county-wide trllll:ijlOl'Ult:ion facilities and strlItegje.~
the 1Ie<;d tor "fforo..!Jlc hO\lMll!; rQ' all ~Q"tl",k ~grm::m$ uf tile ,ptlpUlaliull
coollty.wide ecooomic dewtlopr/1etlt and employment
1lIlJllysis ^Ctf fiscal impacl.
.
.
.
.
.
/.
In additioll to the eight required policy areas, the City of POrt iownscl1d and Jefferson
County l\~reed to ildd policies pertaining to rural areas and the COflleXI within which the
County.wide PJallning Pulicies are to Ix: used.
THE COUNTY,WIDE PLANNING PROCESS; .
The C:ouIlly.wide Planning Policies were developed through a cQlJahorntive process between
the Cily and County, puhlic service providers, utilities, special pUrpOse dislricts lIDd com.
munity orl!.aniz.atioDs, The develQpment of these policies has been overseen by a steeritlR
committee comprising the three Jeffensoo COunty COmmissioners (B.G. Brown, lQry
Dennison, and Richard Wl.!tt', tWQ Port Townsend City Council members (Jean Cam(leld and
Norma Owsley) lIDd POrt L9wllselld Mayor Jolm elise.
Background information leading up to the development of these policies is found in a
discussion .whitepape;r. paper titled County-Wide Planning Policies: A Str<ltegic Analysis,
TbJs .white paper' provides iln in-depth dlScussiOll of the legisla(i\le back grollnd, strategic
elemenlS or issuetl eOIlcerning local application lIDd polley cOll5ideratiollS for each or the
policy areas. Copies of the 'white paper. are availll"ble from the Office of the County
Commissioners, County CotlrtbOO$e. The 'white paper' is not adopted as pan of the
COunty-wide Plannillg PoliCle$.
The COlltlty-wide Pla.i:rning Policies represellt a cotllJlQSite framework, !lot a series of
indi vklllal, slllml-alollll roncepts. The ideas represented IIere balance each other to create an
oVllrall direction for development of individllal Qomprehmsi've plans. These policies establish
me fOUlldadtlll for determlnlng conSistency of IlnJivldwtl ptWll> WW, each ulIlCI .....I;! wiU. I1J.o
tenets of the Grow MllIlagemelll Act, as well as a meehanism to coordinate the provision
of public facilities and services throughout the community. Finally, these policies encompass
broad cdnc!lPlS encourJlginJ!; flexibility a..n<l innovation ill meOOnll the goals lllld intent of tbe
Growth Management Act and will. like the planning documents they lIr" intended to gIlide.,
:t';l'vlvt<_ov~f (i'rllC.
QI....TIQM,stUr OF COUNTY WIOE PI.AI':lNrlllG PQJ..lCIES TO ItltRRJM ~F.SOUR-
CE I..AND AND CRlTICAt. ARc.A O{l:DlNANCE:
The GMA envisions a process whereby resource lands lIDd critical areas are ide.lltified,
designated, classified, conserved llnd protected as a initial first step in the growth mll1lage-
ment process. Following tile adoption of these interim measures, comprehensive land UIle
pI ans wilt be updated to meet the goals and provisions of tile act. It is intended that these
inl~rim ""crt~etiv~ 'JU"."""~$ will be ,"""".tll.ltVl t1urine Ine Cnmprehensive Plan amendment
process and revised to comply with the plan as required by the GMA. The principles
encompassed by the planning policies will serve as a policy guide in the process of adjusting
the interim proteetive measures.
:)
POHCY III
POUC\' TO lMP16MENT RCW 36.70A.11O
URBAN GROWTH AREAS
I. Tile County and City wJlJ jointly prepll/1e a regional population forecast for growth
mill.llilgernentplannillg purposes. The forecast will use the Washington State Office of
Financial Manjlgement (OFM) population projection as the low or base projection, llnd
establish a medium and high range pmjecdon. This forecast will delineate a ten, twenty
and'fiff>'YM"n:ttim:;d~:pnrnjl~6on '~j:~t,tQA~d~::\JJ:~Jn<,th?:<pro'p~tionof~fi:tc,,)
utility and !rllII$pOrtatiOll plans and fur the capital improvement plans to implement the
same. To a.ssure coosi.'lient and coordinated !lmming boclrollS, !he populaUQll for~
will be designated a.~ !he official source tef~ll~ by the County and City, and utilized
when determining collSistenCY of ~ia.l purpose district service plans. TIle forecast Yl-
be reviewed and ll!Xhlled at leaS! eVery five: years.
2. For planning purposes, thc capacilyof Url>an Orowlh Areas {UGAs) will be sil.ed to
aCCOmmOdate at leaSt 10ll% of the low"base or OFM projected population growth and if
supported by an adopted capital facilitie,s plan, may be siud to accomll1<>date the locally
adopted medium and hlgb range populatioll projection. (Note: Tbe GMA does not dire(:(
where people llIay choose to !lye, however, it does require that urban development be;
accommodated within wi:latI growth areas. Tllis policy is forwarded to ensurl:: !hat UGAs
lU1d !bek attcrldan, fllCUiti"" "'" PJOl""ly ~;-.l UJ .I."'\mlluuwm, !\Im<<: VUJlUlal.iutl~.)
4
The site and delineation of boundaries of UOAs will be determined by the following
"'Mreri!!:
a<!equat.. amount of <lov<>l<>plIbl.. land to ac.c.omm<Xkt<> for.."""l",d growth ro.. (h"
next :20 yearn based on me jomt popu laticm forecast.
. sufficient developable liUld for residential, commercial and industrial uses to sustain
a beal1bcy local and regional ccOtlomy.
. lands within illctl'J'Drated city limits.
. f"M~ already cbar:u'Iflrb:ed by III11an devlllopment which are currently served or lITe
plantled ill be served by roads, water, W1iwry sewer and storm rlrairullle, scbools
and other urbanserviccs within tfu::. next twenty YClll:S; proVided mat such urban
services whICh are 1I0! yet in place are irn;:luded in a capita! facilities plan.
. tfu:: type and degree of cltistlng um!ll1 serviees nec;essary tn Stlppart urban develop-
ment at the m:lopted interim level of senricc SllllldlU"ds.
. sufficient area ftlr the deSignation of g=belts and q?eIl space corridots.
. topograplUca1 features (If enviromJlentdly scllSitive areas which may fOOl1 MIural
llOOndades Such as bays, watersllell$, livers 01 li(1ge lines.
4. Poft Radloick and Pon Ludlow are considered being 'chaneUlOz{Mj by urb!ll1 growth" for
the purJlOSC of de.ignating UOA in the unincQI"POrat<:d COUllty. The 1'ri-Area Community
Plilh lllld the Port Ludlow Master Plan will be utilized as Jl guide in the deline:allon of
UOA wm!tJwicl. l>""aJ QU U,e ccik;rla "troy,,_
~
S. Lll.IId use plans, regulalions and capital facility plans wil11in cach UOA will be desigr
to accommodate the projected population. Growth should be directed il!tO two tiers: first
tier - eJdstinll' commercial centers ami Ilrhanj71'A arPA< wll"".. ,.1>.. .,r (li) Y"'" c"pital
f"cilitles plm Is prepared to provide urban infraslrUCtUre; second tier - areas included
within th~ capital facilities plan to receive Ule full !"lInge of urban services within twenty
(20) y~. Infrastructure improvements necessary \0 support development in lite second
tier will be provided by the developer concurrent with development, or by public entities
as II result 1)f implementing all or a portion of Ule <lapital facilities plan.
6. UOA bmmdaries mey be changed whenever it can be shown that the criteria set forth
abOve tor me ana bOundary delineation may IlO longer be met, provided, said J!!xpansiOll
shlllJ only ocl:ur after l1le capital facilities plM is llpllaled and adopted assuring adeq1la
urban llcrvice to support the additional area.
Before adopting boundaries of UGAs, interim level of S/:l"Vice $tlllldard"li for pnblic services
_<I roeiUtiQ(! located m.id<> lU1d ou13,dc of U(lA'. will be ..doptod by th.. CQlmt;r MO it!
UOAs. !'tew"llrtlan public facilities will only be provided within and not be extended
'beyond UGAs. unless deemed lIS an essential public service to mitigate Ii threll! to the
public hl:alUl. afe!)' or general welfare.
8. UOAs will M separatM from each other hy oMigMted n.ttlll or rt!SOt1TCe lAnds. open
space corridor:s. or unique topographic fear:u.res such as a stre:<lID or ravine.
~
POLleY 112
POLlCY ON THE PROMOTION OF CONTIG1.JOLlS AND ORDI>RL Y DEVltLOI'MENT
AND TH13 pnOVIS10H or Ul"UlAN SI::fWiClils 1'0 SUCH Dli;\!'I;l-OPMnNT
1. The full flInge of governmental urban services af the adopt\W level or service .stalldards
,viI! \:>.. pl:!ll",..d for l\nd pr""ldod ,,,ithtn UCAs, <!IS d..r.,.."d
th"
no Utlle. 1'l...(\,
including community water, sanitary sewer, piped fire flow, and $l.Onn walllr liiystejlllii,
2. The County is the designated pllUllling agellcy lor Ilnineorporalild UGAs.
eiti:tl!ns
advisory eommi~ will be appointed for eacll (l1lim'~raItld UOA to $tilde dlWelopmmt
of a communit)' plan lor these areas. Said plan 'will include the flillowing elementS:
capilal :facilities, utl1ities, open space, ~tion. MQSi.llg, land IlSC and ~rtlIlion.
3. New dlllll::IOPmllnl will meet the adopted IlWel of service ~ emblislled for UGAs
as a. condition of project approval. Said .stanwds will include inter!nl provisiollS for
lhose urbanfaoilities identified in the capital fliCllilies plan bul not yet developed. New
de\lIMQpmllnt will Wlltribulc its pr<lpO!'lionate share towards provision of urban :facilities
identified in tile CIlpital facilities plan once adopted ill complilUlce with the Growth
MlUlagernent Act.
4. Urban services and fliCilities will nol be exteoded beyond UOA boun<Wies unless needed
to mitigate a threat to the public nealth or welfare, or to pro~t an area of .enyJron-
mental sensitivity. To avoid enoouraglng the spreading of urban developrtlellt outside of
7
UGAs. this policy shalf apply only to tllreats cl\used by existing development, and only
those existillg uses requirillg the service Of facility to mitigate the threal wlll be allowed
to book up to any ext;!:llded ~rviees.
5. Priority for the funding of new or expanded pUblic services and [acilities will first be
gIVen 10 those w!licll are responding to capacity deficiencies within UGAs or 10 those
wbiell provide an inducement for development within UQAs or to those responding to a
public he.tltJl tllreat.
6. Tlie minimum deliign capacity for all plmood capital facitiues will be based upon the total
populatio"
rOf I.l1e service iU"lla'ar tbe ernl Of me rwem:y year pertoo identIfied in
the adopted population forll""'5t.
7. Tile County will, in consultation with City of Pelt T<lwnse.nd, and the Jefferson COllllty
PUD, and other pubJj<: and private w"terpW'Veym-s, update the COllrditlated Water System
'. .-' '.:" ........
Plan (PWS'P). "..sed on lh<> joint popu14tion fw_ !ImI new Mta p"......i..."!: to future
Wllter supply and demand. The water supply and service provisions of 81I updated CWSP
may require revisiollS to land use elements <lod cllmmUllity plans. COIllpreheosive plans
sball irn::lude water quality !lOll water conservation polictes Iltld $lIll1dards. As the water
resouree management dlseussiQl!.S ktlOWll as the .Cbelan Agreement Process" proceed, any
agreemenlS arising frQm 'these discussiol!.S "\\-ill be irn::Qrpot'ated into local 111alJs and
policies.
Jl
POLICY 113
POLICY ON JOINT COUNTY AND CITY PLANNING
WITHIN URBAN GROWTH AREAS
(Note: Currently !here only one incorporated UOA within Jefferson County. the City of
Pun Tuwm~IIl.L A::, tbl.-'M: Jllall~!lll~ j.>\JlleiQ^ we ulleml<:ll tu guide 1.11" .s",,,)up1uem uf
comprehensive plans now and ill the future, they anticipate that additional areas maY'
incorporate in Jefferson County.)
1. Incorporated UOAs within the County and each provider of urban terviees within UGAs
wl.11 MSisf. the COWlty .in the planning;. CC>OMlmtt<m. and "ct@llshm,,"t of urb.... te.rvi"""
and facilities to serve the projected twenty year population.
2. The County lII1d mCOt"llOrated UGt\s will coordinate the development and implementation
of plans for !he provision of cOIl"Ilt;y-wide services iooluding public safety. transportation,
solid wa..<;le. storm drainage facilities. water and waste water utilities.
3. Incorporated UGA$ will work cooperatively with the CllUllty to identify alld protect open
:;pace corridors. 'This process will include:
. identification of open space conidors and l.lrbllll separators.
. identification of open space lands lUld corridors within UGAs.
9
. idelllification of implementation strategies and regulatory and nOIHegutatory
teclrniques to protecl !he corridors.
4. By illler!ocal agreement, Incorpo!1\ted urban areas and the County wilt establish a
fulmework for joint planning. SEPA environmental review and decision making for
uuima.JlVV'<!tetl ">HIM> l"",,,u!,.! wll1lln me IncolpO!1\lea url:lan area UUA..
5. !llcorporated UOAs will coordinate wilb the County to assure joint review f<lr adtlre~sing
thll5e development activities of a regional nalltre. such as a regional shopping center or
large indumial complex, The .purpose of thls agreemetlt is ro. insure impacts of a
""giQni!l natun> ...... ad.dr""....! ....<1 the 1';""1.. of tM OMA lire ...,..I~.
6. Due to the large scale nature aM the impacts associated with fully ronw.lned COll'Ul1unities,
:rueb developmellts should not be considered in the impellding update of the County
CumprebensivePl;ll1. After the plan has been adopted, a thorougb stIIdy of there types
of developmeut should be undenaken. If found 10 pc if. viable de\lel~ment option, the
rompreb.ellSIVc plan will be modified to lru;lude pwvisions for fully containe<l communitie;.
7. The County Mil each incorporated UGA which has a pending deveJopll'le:n~ proposal shall
ensure timely ctr<:t.I!ation of development applications for review IlIltl comment by other
agencies with jurisdiction.
10
POLJey 114
POUCY ON THE SITING OF ESSENTIAL PUBLIC FACILITIES
01' A COUNTY OR STATE WIDE SlONIFICANCe
L Essential pu~lk facUities are deflned as: 'Pul;Uc or priv3lely.owned facilities thaI are
....."i,w tv """.,,,,JnOdat,, ba.ic public .>=1>, j"cludu'!l tit""" r..ciliti"-'! that an:; l;rpicclly
difflcult to site, ineluding local waste handling and trealment facilities such as landfills,
drop-box sites and seW<lge treatmenl facilities, aiJports, state educationa:! facilities, essential
state public facilities, regional transpoItaliort and stonllwaler rlrninlIge, utility facUities, stale
and local ~orre;c:tional facilitie$, and in.patiem facilitie$ (incil,ding substance abuse facilities,
m"nt:tl h"altb fae!Jjti,,~ and woup 'l""Ill"')'
The County and incorpofllted UGAs will jointJ y develop $jleCiflc sitlng criteria f(lf siting
eI',SUntial p\l~1ic facititie$. Tire proposed criteria w!ll be considered in tile drafting of
cQmprellensive plan policy addressing this issue. Elements of siting criteria should
illclude. "but not be limited totlle followinlt:
. proximity tl} major trllnsporfation routes and essential ittfrastructute.
. land use compatibility \vim SU,T1Dunding area,
. potential envirolllllCl'ltal impacts.
. effects on resomce and critical are3.!:.
. proximity to UGA.
. public costs and benefits illcluding operation and ltIaintenam:-e.
. current capacity and location of equiva.lent facUities.
11
. the existence, within the community, of reasonable alternatives to the proposed
activity.
3. Comprebensive plilDS and developnrent regulations will not preclude thl) siting of essential
public faeilities, however standards may be generated 10 insure that reasonable con1-
patlbility with other land lISes <:an be achieved.
4. Essential PIlblic facillties sited outside of urban erowtlJ areas should be self,su]J!1Ort;ng "nn
not require the eJltension, construction, or maintenance of url>an services and facilities
unless liP practicable alternative exl:sts. Criteria 'i'lfn be: es!al:>liShed that address the
prO'Vision of services when slting an essential public facility. Essential publle facilities
sball not be located in resource lands or critical areas if incompatible.
III
POUC)' 115
POLlCY ON COllNTY-WIDE TRANSPORTATION
FACIl..lTlES AND STRATEGIES
I. The PenillSUla Regional Transportation Planning Oq).anizalion (PRTPO) wm develal' a
regional ttansportatJQo plan for tile Easlern Olympk and KllSap peninsula area. The City
and Count)' will each develop a trllftllpOrtatlOtl elemenl to the c.omprehensive pl'lD _that
emphasizes local ttansportation Deeds. In developing tiles:e trllftsportaDon elementS, s:pecif-
ie linkages with the regional plan will be unUertllJ(en 10 llSsure col"l.~l8lency tmWellil tile
twO documents.
2. Service standards for higbways:, arterial. Md trllft$lt ralites wilt be cooniinaled and adopled
at a cottnty~wit:le level. These lItandartlli roa y vary deFfldlng 011 tile type of development
pall"'" Hlll.lLip"tt;d (i.<::. Ill"." ... lmal) QC by tho sp<Xiil'le vo- .m""'ll"ment objoctivq,;
beIng eOllSidered. Wlren a variance m level of service sllI.ntlanls is established. it will be
clearly delineated ill the transportatiOll and land use elemenl of the eomprehellSive plan.
In developing the County's six year road program, the priority of focus: should be:
RtsA~ 1.:0. ..lflaintAin Qce;:;ptlrtde-"Apacity 'Witltinth~ tJl1A\t
. SllCOlld, to maintain or expand capacity for transportation to and from UGAs and
regional cenlers.
4. The land use and 't:rllnSpOrtllthm clelIlent!i of the comprehensive plan will be used by
Jefferson Transit as a guide in lhe development of ilS service delivery strategy. The
1:1
thrust of this strate.!lY is to increase ridersbip IInd expand transportatiOl1 options williin
UGAs, betWeen UGA5-, and between the OOtInt)' lIlld the region at large.
S. Jefferson International Airport wiD remain the public link to the larger air ttallsportanon
system. The Port <if Port Townsend will have the lead r~nslbiJit)' to develop a service
delivery strategy for lhis mode of l1artsportlltion conslst<mt will! the ttlIllSpol:/lltlon and lalld
use ellllNin19 of the Coont)' comprehensive pllln.
6. The d"evelq.ullenl or expau<5iOl1 of auy air-based {)f water-based transportation system will
require specific lillkage with the ground trllnSpQrtlItion system and compoubU.ity with me
lantl use eJem~1t 01 tIW comprehensive plans.
7. In establishing tile land use cI<:lmenl ofeomprellensive plans and the level of servk:e
standards for transportation S)'Slel"llS witllitl UGAs, the eit)' and Coont)' will ins\ll:ll that
use dellSilies, design' e1emoolS and deveJopmelll policies are supportive and make
nc..:qn'tnOO"tion f<;lf publi;: ~t and nDwmotofilMl form~ of trn.n~pol\ollo".
8. The transportatiOll eJemllflt of tlIe comprehensive plans wiD designed lIfOuM the 1'0110w10g
principles:
. llCClc to irwrease efficiency of !he existing ~tion system.
. ~1TlrMi:i?~lhf'" f'tlbv~*rh~gt<(1f_~r&!2J1ir,~ond~ firm.a:nd vehid~1';t :~..ennd,.
."
. encourage lUll! integrat~ nan-motorized modes amI lIigll occupancy vehicles in
transportation system design.
. encourage employers to implement Trall!;pOrtation Demand Management (TOM)
techniques, This is particularly true in the fCview of new ellrployment generators
lit a fixed IoclltlOO.
. seek 10 assure that the j"lmportionare share of c~tS new or upgradlld tr~spor-
tation facilities are oorne by those who create Ihe ne-ed for tOe facility, .as~well
those who benefit frQffi it,
The Transportation Pliln chlment wlll provide a summary and llllaIysis of pllUUling
mfOTmlltion lIlcllll1ing: .
. land ose assumptions trpon which the trllnsportalion element is based including:
population, employ1lrent by type, recreation. comprehensive llUll! nse designations,
and the densiIy of current and projected development including the ratio of single
and multi.f.tmily units to total housing units within UGAs.
level of """"lee stm>dard. for attl::rials ..00 ",,,li""'Ori:,
. an lllllilysis and forecast of future tnlnSpOttation needs,
. evaluate the operation and roainlellJUlCe of trallsportation facilities in II manner
which con.~iders present and future operation and maintenance costs.
. incorporate pedestrian and bicycle travel as part of the transportation element within
~ <""rdi ".,..<:1 "nl( "'".e,n",,\ ""~i., 11le bicycle lIDd pedestrian comj)Ooent shall be II
IS
part of the funding component of the capital improvement program for
tr"alLSpOrtatiOll improvements.
10. The adopllld level of :service $l.lU!dards will be used in c1Illluating COncurrency for long-
range transportation plalllling, development revi ew and programming of trallSjlOrtation
ulIplVwmelll.s.
16
POLICY #6
POLICY ON THE ~ROVISION OF AFFORDABLE HOUSING
For pluning purposes the definition of 'affordable !lousing" Thos~ houSing units
avllilabl'e for purebase or rent toindividuab or families witll a gross illCoTlle between the
federally recognizl!d poverty level and tile median income for W<;)r1dng famflles in Jefferson
County; and wbo's c~. Including utilities, would not e~eed S6'!1\ of gross: mcome.
'The provision of affordable !lousing is acknowledged as II general public ~ and will lle
addressl!d ill Jet'fuflJonQ)unty through private ;SeCtor progJ'ilffis alld projects. Local
gOVmtment should ootmsome a direct role in theownersbiPor admin1S'1tl!tioo of public
assisted housing to meet low income needs, ratlltlr this should be It!'ft to private. non-
profit or quasi-public cnnti elf.
J. The bousing Mdt or Iud use elements af comprellemiive plans will inclooe an aSSessment
of land av;Ulllble lIDd the process of siting special ~ hoosing, {SUCll as IlOmetess
shelters, group oom.es, etc.), lIJ ensure tbatSUcb !lousing call be necllmmodllted.
4. A sufficient quantity of land will be appropriately lOned or designated to accommodate"
wide !:!Ing.: of housing types, densities lllld mixtures. Multi.family hOl.l$ing should only be
locat<<! wlUtl1l UCiAS or ru!:!lt cerll:ers.
11
5. An affordable housing strnt~gy will be developed as part of the housing element of ti'
cotllprell~nsive plan. This affordable hOllsing strategy will ex.amine existing regulations
and policies to identiry oppol1Un!lies to encourage the provision of afftlrdable tlousing
mecha.nisms such as accC$Sory dwelling units ('mother-in-law") or efficiency lIPartments,
density bonuses, mitigation fees waivers, priority permit processing and the like.
6. Eacb UClA shall llCcolnOlQ(late its fair share of housing affordable to low and mOderate
income households according to its percentage share of the county population lIlld by
promoting II balanced mix of diverse hOllsing typeS.
1_ Umt"v"lo~ lwJ.d ownp<i by !he l,ublil.: cntit.iQ wlll Lc illvcllwrie<l MU thllli9 Illal <trIO
appropriattlylocaled should be considered for development of low income housing.
Coosldmltion of assembling these parcels for development by non-profit housing
organizations or private developers should be encouraged.
R TIll'! ho""i"8 element ""rn io'Iom.. ,.ri,Mi" fo, loe.ting highey .reosity cMid.."l,,,) "c.."'. "t'...c
public flIcil.lties lIlld ~ir.:es, commercial ~ices, arterial or within wa1lcing dlstllllce of
jobs or !rlllISit.
III
POLICY trI
POlley ON COUNTY-WIDE ECONOMIC DEVELOPMENT AND EMPLOYMENT
1. The private $eclor i~ prilllllli!y l"espoosible for the creation of <::alllolllic OjJportunity in
Jefferson Count}'. The responsibility of the public sectof is to asStlre thaI tIIese activities
life carried out. consistent with defined community and environmelll1l1 values. To t.his end,
comprel1el\Slve 1,lan should cIeMl)' identify these values in order that economic opportUnity
:~~ n()t:J<5$:t-~~ t:() eon:~i()~-'-O;f "~tl~b:i:Jiit'y():f- ~J:fi',P:~euhr:';):t;tf!'1ttioti ,"lit,} -~8iven
to the needs of non-service sector bllSinesses llXld industries a;> a strategy 10 increase wage
ea.mll"lg potential within the community.
2. An ecooomic development element should be prep<lfed and included in the County's Md
i1ll:orpotllll:d lttea:;' comprehel1S1ve plllI!. 11U.s element shonld idennlY and designate
aooquate areas fur COOlll1lilfcill1, retail, and indllStrial growt.ll necessary to sustain and meet
future popullltioo and employment forecasts. Tbe <::alllo.mic development element shall be
coordinated with the capital facility, land use lII!d utlllties elements of we cOll1preJIensiVe
plait.
3. Each UOA and rural center i~ considered tbe commercial and bu.~iness "hub" in their
rr;:spective area of We County. UClAs sMuld be viewed as regional service llXld retail
centen;. wIllie Ille rWol <.:eo= foc"," i. "" 19Q11 ",,,,,..nullity """II and ....-vice needs., and
transient accommodations.
w
4. Certain imlustries due 1.0 !heir siu or type of opet1ltion, or du<: to their dependance
the locaL resource base should not be located within the boundaries of UGAs. When
locating these typeS of activities outside of UGAs, ~iaJ attention IllUst be given to
l\l;sure that the activi~ wit! not promOte "urtJlUJ development" 1)f the surrounding area.
These ac!ivities will need 1.0 be self-supporting IUld not require the C\Xtell$ion of urban
services.
J. The Port of Port Townsend's legislative authorl~ should be utilized as a tool to
implelllent iJldustty lIlld trade strategies; including the promOOQll of employment
opportunities, the consolidation lUJd ~ling of property. lUId the development of
i!>l:I""U u<.:lUS ~ lU (0<%1. We ne<:<ls of industry cowisWtlt wilh q:ruUJrelleusi ye !'tillIS mu
development fegulatiOllS.
:1/"1
POLICY IS
POLICY ON RURAL AREAS
Rural areas are !hQ5e lands located outside Qf UGAs Md resource lands. ihese areM are
characteriw:! by low density development, open spilce&, minimal public liCrvice&. resource
dependent activities, and industries; II:l1d outdoor recreati\lllal facilities. Activities sileo lIS
rcgiofUll retaiI-COI11Ull:rciaI Illcilities. business uffice parks and similar high intensity land
uses are coosid1lred urban in nature and are illCons!ste.nt with rural area designations. The
rural elemellt of the comprehensive plan 'wID be designed tQ r~ognize and ttlllilllllin !he
unique character of individual n:tral areas with.out degmding !he environment or creating
lIle ,need ((lr urban leVel of sel"Vl.<;CS.
2. The concept of clustering or deDsity tranSfer is conSidered a positive tool in maintaining
the cbmd.er of n:tral areas. This concept assisCs in more efficient delivery of public
services, millirnlzes the !leed for additional lnft'astrucu.u-e, and lit tile liltll:\!ii time max.imiteS
land ayailable fo, nmoI~. Cluot~ of new dvvelopm<:on\ ,,, Fd"..-....J ,n <ural """"'.
3. Level (If Service SImldards will be adopted whicl1 identifies the type and scale of public
facility and infra..'itructure impro"l{ements anticipated for r\Ifltl areas and rural centers.
T)'Picallythcsc will include:
e_mgrs~ncy SmilC'es.
. transportation and roads.
21
. individual septic systems.
. individual Qf community water systems.
. storm water and walllr lluality.
:5. R Ill<ll centers are those existiug lJllincorpara!e<I places which serve the retail commercial
and service 1Iliecl5 of 1he local:area. These art1!lS will be delineated and rellOliIIl2cd in !he
eUlIlprel,,:uslvl:: pl"'l WIISl:;tl'llt WIEh level vf service staDtlanls. l..all~ m~ wl\lIl/l mese
centers include:
. shopping, employment, and services for residents, SlJpplles fQl' resource industries,
including commerclal, industrial, alId lOtlrism development at a scale !hat preserves
!he S!lfrolmding rura1 llhm'al;:t:erlstics.
. .......IlMfi.1 """,,1"1'_"', 1..",..<11"8 .m.I1~IOl: ",,,gb"'mily It"d ",,,lti.fA,,,ily; .M
mtxed.ose develQJlments.
. community facilities liDd St;I'Vices necessary to support the rural center and promote
pedC5ltiIltl mobility.
6. The 1"IlI"d! element of the comprehensive plan win rocogni<.e existing industry located
outside UGAs, as well 3S establish a framework fOr the siting of induslries which, due to
12
their size, resource dependence, or Incompatibility with UGAs, would be better suited ltl
locate ill ttI1"1il Ilreas. Provl.slollS will lle made to ellSllre that adjacent land uses are not
ll'IVI'VP.rted to'um::m H!tP..~th'l~ fr\'f:be:,pifl'!yJrrliry of dleQ~ c$p:v~l"Pri1pnn~ 'orfn'-in~stMJdu:rl'!!
neees'lllry to support them.
2:>
POLICY 119
POLICY ON FISCAL IMPACT ANALYSIS
1. Include a fiscal impact assessment on the provision of public capital facilities, lI1at are
intended to serve lI1e community, as an ongoing pllJ1 of tl1e comptebensive planning
process. nus assessment will mclode project revenues and e>:.petldijures and an analysis
of the cumulative fuclll impacts of providing govenunental ,services to accommodate the
targeted population. The pwpose of lIle fiscal as&eSsment is to llSsure that projectec1
capItal costs can be reasollabIy supported within the capabilities of the community.
2. Within 1h<; ",1",..",,1;'; of Ill", <;ofUl',,,,I>ens,v(; plau. i","""uVe/l llml 'lQu.,(;gUlllW'Y vl,llvll' wJll
be identified and developed as alternatives to regulam<y prOgrllDlS In the implementation
. .. . .. ,- .'. .' '.. .. ... ", .
comprebensive plan policy.
3. The City. any future incorporated UGA, md the County wifl address issues of laX
'''e!Vetllle:~~mng~ th~. . provision of #sion:dS>erVi~s... ~t;rn~~ti()~s:~' ~_od -$imH~>fis<i'jd
components throogb the development of interlocal Jlgreements.
'4
'^ ~'~~~",",~_,~""=,,C"'~'"
POLICY 110
POLlCY ON USE, MONITORING. REVIEW AND AMENDMENT
ne County-wide Planning Policies will be \lli!bed w:
. eStablish a framework for the development 1ll1d adojltiOll of comprehensive plans and
lWppottillg -regulations.
provide 1I foundation for eStablishing locally defined terJllS, and to d~et"mine
conststewz:y with the criteria of the Growln M"""$"mi>nl Art
. cooroWite and assurc ooll$istency among plllllS of theCOUllty, UGAs, SpeciaI
pt.ll1l6s:e d1strlet.s and service providers.
TIiCl Growth Management Sleermg Committee will s:etVe lIS II rCjl;lonal ov~gIll body
during the developmellt of the comprehensive pllllls. Once ullineorporated UGM lite iden-
tified, representatiOll of the unincorporated UOA will be illCluded OIl the steerint
committee. The committee will review draft plans for COIlsIStcllCj' with thliSe polities in
lW atl~ C<lpaclty ana repol1 ilS ttntlmgs w lIIe appmpfillle jurisdiction.
3. Tl:l~ policies sllall be periodically reviewed llIld may be amended ill tire following
maooer:
. the amendment is placed in writing and includes a brief cxplanatioo of why the
tuneridt:na'ti: i<, w~tcd.~ and
,&)
20
ATTACHMENT 2
Chapter 173-517 WAC
Chapter 173-517 WAC
WATER RESOURCES MANAGEMENT PROGRAM FOR THE QUILCENE-SNOW WATER
RESOURCE INVENTORY AREA (WRIA 17)
PART A - GENERAL PROVISIONS
NEW SECTION
WAC 173-517-010 Purpose and Introduction. (1) The purpose of
this chapter is to retain rivers, streams, lakes and ponds in the
Quilcene-Snow water resource inventory area (WRIA 17) with instream
flows and levels necessary to protect and preserve wildlife, fish,
stock water, scenic, aesthetic, recreation, water quality and other
environmental values and navigational values.
(2) WRIA 17 is located on the northeastern Olympic Peninsula
and includes portions of Jefferson and Clallam counties. This
chapter excludes part of the Clallam County portion of WRIA 17.
(3) This chapter sets forth the department of ecology's
(ecology) policies to guide the protection, use and management of
WRIA 17 surface water and ground water resources. It establishes
instream flows and closures, and sets forth a program for the
administration of future water appropriation and use. For the
Chimacum subbasin, where water availability is severely limited, a
small amount of water is reserved for restricted out of stream use
to provide a transition until alternative sources of water can be
developed.
(4) This chapter designates two types of management areas for
administering future water appropriation and use:
(a) Reserve management areas. This chapter establishes
reserves of water within specified reserve management areas.
(b) Coastal management areas. This chapter designates coastal
management areas.
(5) This chapter does not release anyone from complying with
other relevant laws and rules.
( 1 I
OTS-2234.8
NEW SECTION
WAC 173-517-020 Authority and applicability. (1) This
chapter is adopted under the authority of the Water Resources Act
of 1971 (chapter 90.54 RCW) , Minimum Water Flows and Levels Act
(chapter 90.22 RCW) , Watershed Planning Act (chapter 90.82 RCW) ,
Water code (chapter 90.03 RCW) , Regulation of public ground waters
(chapter 90.44 RCW) and the water resources management program rule
(chapter 173-500 WAC).
(2) Except as provided in subsection (3) of this section, this
chapter applies to the use and appropriation of:
(a) All surface waters within WRIA 17, including all streams,
and their tributaries, that drain to salt water; and
(b) All ground water within WRIA 17, including ground water
hydraulically connected to surface water bodies, as well as ground
water that drains to salt water.
(3) The following portion of WRIA 17 located in Clallam
County, as shown in Map B in WAC 173-517-070, will be addressed
through future rule making and is excluded from coverage under this
chapter:
. Johnson Creek;
. West Sequim Bay;
. Dean Creek;
. Jimmycomelately Creek;
. Chicken Coop Creek; and
. The portion of Miller Peninsula in Clallam County.
(4) This chapter shall not affect existing water rights,
including perfected riparian rights, or other appropriative rights,
unless otherwise provided for in the conditions of the water right
in question. An existing permit-exempt withdrawal is not subject
to the rule to the extent such withdrawal has been put to
beneficial use on the subject property for the purpose of use in
question.
(5) This chapter shall not affect federal or Indian reserved
rights. The Jamestown S' Klallam, Port Gamble S' Klallam, Lower
Elwha Klallam, and Skokomish Tribes reserve the right to claim a
treaty-derived off-reservation instream flow right with senior
priori ty. The extent of such rights can only be determined in
other forums outside of this chapter.
(6) This chapter does not limit ecology's
establish flow requirements or conditions under
including hydropower licensing under RCW 90.48.260.
authority to
other laws,
NEW SECTION
WAC 173-517-030 Defini tions. For the purposes of this
chapter, the following definitions apply. If these definitions
differ from those in related rules, the definitions presented here
[ 2 ]
OTS-2234.8
shall apply for this chapter:
(1) "Allocation" means the designating of specific amounts of
water.
(2) "Appropriation" means the process of legally acquiring the
right to specific amounts of water for beneficial uses, as
consistent with ground and surface water codes and other applicable
statutes. This term refers to both surface and ground water right
permits and to ground water withdrawals exempted from permit
requirements under RCW 90.44.050.
(3) "Commercial agriculture" means the production of crops for
sale, crops intended for widespread distribution (e.g., markets),
and nonfood crops such as hay and lavender. Commercial agriculture
includes livestock production and livestock grazing. Commercial
agriculture does not include crops grown for household consumption
(e.g., household vegetable gardens or fruit trees).
(4) "Consumptive use" means a beneficial use of water that
diminishes the amount or quality of water in the water source.
(5) "Domestic use" means use of water associated with human
health and welfare requirements, including water used for drinking,
bathing, sanitary requirements, cooking, laundering and other
incidental household uses, including potable domestic water
requirements associated with commercial and industrial purposes.
(6) "Ecology" means the Washington state department of
ecology.
(7) "Group domestic system" means domestic use of the ground
water exemption for two or more residences.
(8) "Hydraulically connected" means saturated conditions exist
that allow water to move between two or more sources of water,
either between surface water and ground water or between ground
water sources.
(9) "Individual user" means all uses on an individual parcel
or adjoining parcels under common ownership that do not qualify as
a group domestic system.
(10) "Instream flow" means a stream flow level set in rule to
protect and preserve wildlife, fish, scenic, aesthetic, recreation,
water quality and other environmental values, and navigational
values. The term "instream flow" means a base flow under chapter
90.54 RCW, a minimum flow under chapter 90.03 or 90.22 RCW, or a
minimum instream flow under chapter 90.82 RCW.
(11) "Interruptible use" means a use, authorized under a water
right, which must cease diversion or withdrawal when stream flows
fall below the instream flow levels established in this rule.
(12) "Mitigation plan" means a plan, submitted to and approved
by ecology, to offset the impacts of a proposed consumptive use.
A mitigation plan may address impacts to a stream, basin, reach, or
other area, for an individual withdrawal or for multiple
withdrawals in a subbasin.
(a) A mitigation plan must show that the proposed withdrawal
with mitigation in place, will not:
. Impair existing water rights, including instream flow
rights;
. Be detrimental to the public interest; or
[ 3 ]
OTS-2234.8
. Consume water from a closed source.
(b) The plan must include financial assurance, ensure
mitigation measures for the duration of the water use and prohibit
water provided for the purpose of mitigation from appropriation for
any other purpose.
(c) The plan must include a monitoring and reporting plan,
including a quality assurance/quality control plan.
(13) "Outdoor irrigation" means watering greenhouse or outdoor
plants, lawns, or gardens.
(14) "Permit-exempt withdrawals" or "permit-exempt well" means
a ground water withdrawal exempted from permit requirements under
RCW 90.44.050, but otherwise subject to the surface and ground
water statutes and other applicable laws, including this chapter.
(15) "Reserve" means a one-time, finite allocation of water
for future appropriations.
(16) "Stream management unit" means a stream segment, reach,
or tributary used to describe the part of the relevant stream to
which a particular instream flow level applies.
(17) "Subbasin" means a reserve management area or coastal
management area as shown on Map B in WAC 173-517-070.
(18) "Withdrawal" means the appropriation or use of ground
water, or the diversion or use of surface water. Withdrawal
includes both withdrawals under a water right permit and permit-
exempt withdrawals.
NEW SECTION
WAC 173-517-040 Compliance and enforcement. (1) In
accordance with RCW 90.03.605, to assist the public in complying
with this chapter, ecology shall prepare and distribute technical
and educational information regarding the scope and requirements of
this chapter.
(2) When ecology determines that a violation has occurred, it
shall:
(a) First attempt to achieve voluntary compliance. One method
is to offer information and technical assistance to the person, in
wri ting, showing one or more means to legally accomplish the
person's purposes.
(b) If education and technical assistance do not achieve
compliance, ecology may issue a notice of violation, a formal
administrative order under RCW 43.27A.190, or assess penalties
under RCW 43.83B.336, 90.03.400, 90.03.410, 90.03.600, 90.44.120,
and 90.44.130.
(3) Nothing in this section is intended to prevent ecology
from taking immediate action to cause a violation to be ceased
immediately if in the opinion of the department the nature of the
violation is causing harm to other water rights or to public or
tribal resources.
[ 4 ]
OTS-2234.8
NEW SECTION
WAC 173-517-050 Appeals. All of ecology's final written
decisions pertaining to permits, regulatory orders, and related
decisions made pursuant to this chapter may be appealed to the
pollution control hearings board in accordance with chapter 43.21B
RCW.
NEW SECTION
WAC 173-517-060 Regulation review. (1) Ecology reserves the
right to review and amend this rule as needed.
(2) Ecology, in consultation with the counties, the city of
Port Townsend, Jefferson County PUD #1, tribal governments, other
state agencies, and the WRIA 17 planning unit (if active), may
initiate a review, and if necessary a modification through rule
making, of this chapter as appropriate, including whenever:
. Applicable statutory changes are enacted.
. Significant new information becomes available.
. Significant changes in conditions such as population growth
trends, water service areas and ground water levels occur.
(3) Ecology, in consultation with the counties, Jefferson
County PUD #1, tribal governments and the WRIA 17 planning unit (if
active), will annually review the allocated and unallocated amounts
for each reserve management area.
NEW SECTION
WAC 173-517-070 Maps. For the purpose of administering this
chapter, two maps are provided. Map A shows the boundaries of the
stream management units and the control points. Map B shows
reserve management areas, coastal management areas, and the portion
of WRIA 17 not covered by this chapter.
[ 5 ]
OTS-2234.8
MapA
WRIA 17 Stream Management Units and Control Points
[ 6 I
OTS-2234.8
MapB
WRIA 17 Sub Basins
L~~J Coastal ManagementAreas
~. No Out<ioor Irrigation Reserve
r:::J Re;serve Management Areas
11!tH~1 Clallam CounlY Sub Basins
C County Bound:; CQvel':!tg" Pet'ilp01led}
2 Mites .[S~rQG
PART B - INSTREAM FLOWS AND CLOSURES
[ 7 ]
OTS-2234.8
NEW SECTION
WAC 173-517-080 Establishment of stream management units.
Ecology hereby establishes the following stream management units,
with accompanying control points. A control point is a designated
location on a stream used to set and measure instream flow levels.
Each control point location is identified by estimated river mile
and approximate latitude and longitude in Table 1. The control
points and boundaries of the stream management units are shown on
Map A in WAC 173-517-070.
Table 1
Stream ManaO"ement Unit Information
Control Point by
River Mile (Rl\I);
Stream Latitude North Stream
Management (Lat) and Longitude Management
Unit Name West (Long) Reach
Big Quilcene RM 0.4 From mouth to
River Lat 4r 49' 07" N, headwaters,
Long 1220 52' 17" W including
tributaries.
Chimacum RMO.3 From mouth to
Creek Lat 48003' 00" N, headwaters,
Long 122047' 07" W including
tributaries.
Donovan RM 0.4 From mouth to
Creek Lat 470 49' 58" N, headwaters,
Long 1220 51' 43" W including
tributaries.
Howe Creek RMO.5 From mouth to
Lat 470 52' 43" N, headwaters,
Long 1220 55' 24" W including
tributaries.
Leland Creek RMO.l From mouth to
Lat 47050' 18" N, headwaters,
Long 1220 53' 10" W including
tributaries.
Little RMO.8 From mouth to
Quilcene Lat 470 49' 48" N, headwaters,
River Long 1220 52' 30" W including
tributaries
except Leland
and Howe
creeks.
Ludlow Creek RMO.5 F fom mouth to
Lat 470 55' 00" N, headwaters,
Long 1220 43' 00" W including
tributaries.
[ 8 I
OTS-2234.8
Control Point by
River Mile (RM);
Stream Latitude North Stream
Management (Lat) and Longitude Management
Unit Name West (Lon!!) Reach
Piddling RMO.2 From mouth to
Creek Lat 47' 57' 27" N, headwaters,
#] 7.0200 Long 122' 41' 54" W including
tributaries.
Salmon Creek RMO.8 From mouth to
Lat 47' 58' 49" N, headwaters,
Long 122' 53' 49" W including
tributaries.
Snow Creek RMO.4 From mouth to
Lat 47' 59' 02" N, headwaters,
Long 122' 53' 12" W including
tributaries.
Spencer Creek RMO.O From mouth to
Lat 47' 44' 45" N, headwaters,
Long 122' 52' 33" W including
tributaries.
Tarboo Creek RMO.8 From mouth to
Lat 47' 52' 08" N, headwaters,
Long 122' 49' 03" W including
tributaries.
Thorndyke RM1.2 From mouth to
Creek Lat 470 49' 24" N, headwaters,
Long 122' 44' 23" W including
tributaries.
NEW SECTION
WAC 173-517-090 Instream flows. (1) Instream flows
established in this chapter are flow levels which protect and
preserve wildlife, fish, stock water, scenic, aesthetic,
recreation, water quality and other environmental values, and
navigational values.
(2) Instream flows established in this chapter are water
rights, which protect instream values from future consumptive
appropriations. The priority date of the instream flows is the
effective date of this chapter.
(3) Instream flows will be protected from impairment by any
new water rights commenced after the effective date of this chapter
and by all future changes and transfers of senior and junior water
rights, including both surface and ground water rights. The
following water rights are not subject to instream flows:
(a) Water rights existing before the effective date of this
chapter as explained in WAC 173-517-020(4).
[ 9 ]
OTS-2234.8
(b) Water rights appropriated from the reserves of water
established in WAC 173-517-150.
(c) Future withdrawals for environmental restoration purposes
under WAC 173-517-200, unless included as a permit condition.
(4) Instream flows are expressed in cubic feet per second
(cfs), and measured at the control points identified in WAC 173-
517-080.
(5) Instream flows are established in Tables 2 through 4
below, for the stream management units identified in WAC 173-517-
080.
Table 2
1nstream Flows (in cfs) for Big and Little Quilcene
Rivers, with Ecology Gauge Number and River Mile
(RM\
Big Quilcene Little Quilcene
River Ecology River Ecology
Gauge #17 A060 Gauge #17D060
Month RM 0.4 RMO.8
January 120 61
February 120 61
March 190 100
April 190 100
May 190 92
June 190 66
July 190 66
August 167 27
September 94 30
October 180 48
November 120 61
December 120 61
Table 3
Instream Flows (in cfs) for Named Creeks with Ecology Stream Gauges
{includinl! e:au!!e number and River Mile RM\\
Tarboo Creek
Chima cum Salmon Creek Snow Creek Ecology Thorndyke
Creek Ecology Ecology Gauge Ecology Gauge Gauge Creek Ecology
Gauge #178050 #17F060 #17E060 #17G060 Gauge #17H060
Month RMO.3 RMO.8 RM 0.4 RMO.8 RMI.2
January 25 21 35 20 24
February 25 21 35 20 24
March 46 40 50 25 45
April 46 35 50 16 45
May 32 26 50 8 30
June 10 26 35 8 30
July 10 9 17 8 12
August 10 9 15 8 12
September 17 9 20 8 12
October 20 12 35 8 12
[ 10 ]
OTS-2234.8
Tarboo Creek
Chimacum Salmon Creek Snow Creek Ecology Thorndyke
Creek Ecology Ecology Gauge Ecology Gauge Gauge Creek Ecology
Gauge #17B050 #17F060 #17E060 #17G060 Gauge #17H060
Month RM 0.3 RMO.8 RM 0.4 RMO.8 RM1.2
November 25 21 35 20 24
December 25 21 35 20 24
Table 4
Instream Flows (in cfs) for Other Named Creeks (includin!! River Mile (R'VI\
Donovan Leland Ludlow Piddling Spencer
Creek Howe Creek Creek . Creek Creek Creek
Month RM 0.4 RM 0.5 RJ'VIO.1 RMO.5 RMO.2 RM 0.0
January 15.5 17.1 33.1 32.1 5.8 13.3
February 10.2 11.3 21.8 21.2 3.8 8.8
March 29.8 32.6 58.3 56.8 12.4 26.1
April 29.8 32.6 58.3 56.8 12.4 26.1
May 19.7 21.5 38.5 37.9 8.2 17.2
June 19.7 21.5 38.5 37.9 8.2 17.2
July 6.1 6.8 13.9 13.5 2.1 5.2
August 6.1 6.8 13.9 13.5 2.1 5.2
September 6.1 6.8 13.9 13.5 2.1 5.2
October 6.1 6.8 13.9 13.5 2.1 5.2
November 15.5 17.1 33.1 32.1 5.8 13.3
December 15.5 17.1 33.1 32.1 5.8 13.3
NEW SECTION
WAC 173-517-100 Closures. (1) Based on past and current low
flows, ecology has determined that no waters are reliably available
for new consumptive uses from the streams and tributaries in WRIA
17 listed in Table 5, with the exception of certain times of year
in the Big Quilcene River and Chimacum Creek. Therefore, all
surface waters listed in Table 5 are closed to any further
consumptive appropriation, except as provided in WAC 173-517-110.
Ecology finds that there is some water available above the
instream flows at specific locations and times of year in the Big
Quilcene River and Chimacum Creek that could be appropriated for
storage or other projects that do not require year-round water
supplies. These withdrawals require a water right permit from
ecology and are subject to the seasonal restrictions in Table 5,
the instream flows established in WAC 173-517-090, and the
allocation limits defined in WAC 173-517-140.
(2) Closures in subsection (1) of this section include future
withdrawals from ground water that would have an adverse impact on
[ 11 ]
OTS-2234.8
closed surface water, including permit-exempt withdrawals.
(3) Exceptions to the closures are provided in WAC 173-517-
110.
Table 5
Surface Water Closures
Stream
Management
Unit Name Affected Reach Timing
Big Quilcene From mouth to June 16 to
River headwaters, November 15
including
tributaries.
Chimacum From mouth to March 1 to
Creek headwaters, November 30
including
tributaries.
Donovan Creek From mouth to All Year
headwaters,
including
tributaries.
Howe Creek From mouth to All Year
headwaters,
including
tributaries.
Leland Creek From mouth to All Year
headwaters,
including
tributaries.
Little Quilcene From mouth to All Year
River headwaters,
including
tributaries
except Leland
and Howe
creeks.
Ludlow Creek From mouth to All Year
headwaters,
including
tributaries.
Piddling Creek From mouth to All Year
#17.0200 headwaters,
including
tributaries.
Salmon Creek From mouth to All Year
headwaters,
including
tributaries.
Snow Creek From mouth to All Year
headwaters,
including
tributaries.
[ 12 ]
OTS-2234.8
Stream
Management
Unit Name Affected Reach Timing
Spencer Creek From mouth to All Year
headwaters,
including
tributaries.
Tarboo Creek From mouth to All Year
headwaters,
including
tributaries.
Thorndyke From mouth to All Year
Creek headwaters,
including
tributaries.
PART C - FUTURE NEW WATER USE
NEW SECTION
WAC 173-517-110 Future new water use--Generally. A new
surface or ground water appropriation (including any permit-exempt
ground water withdrawal) or other new use may occur only if
consistent with the surface and ground water statutes and the
applicable requirements of law and if anyone of the following
seven conditions (subsections (1) through (7) of this section)
apply:
(1) The proposed use is nonconsumptive.
(2) The proposed surface water appropriation would not have an
adverse effect on any of the surface waters closed in WAC 173-517-
100 (1) .
(3) The proposed ground water withdrawal is located where it
would not adversely affect any of the surface waters closed in WAC
173-517-100 (1), by meeting either condition (a) or (b) of this
subsection:
(a) The person or entity seeking to commence a proposed ground
water appropriation shows, through scientifically sound studies and
technical analysis, that the ground water use would not have an
adverse effect on any of the surface waters closed in WAC 173-517-
100(1), and receives approval of a water right.
(b) The proposed ground water appropriation occurs in a
coastal management area designated in Map B of WAC 173-517-070.
(4) The person or entity seeking to commence the new
appropriation submits a mitigation plan as defined in WAC 173-517-
[ 13 ]
OTS-2234.8
030(12), and such plan is approved by ecology. If monitoring shows
the mitigation is not effective, use of water under the
appropriation shall then be subject to the instream flows. In the
case of a closed basin, the use shall cease until an effective
mitigation plan, approved by ecology, is put in place.
(5) The proposed water appropriation qualifies as an
interruptible use and meets the criteria in WAC 173-517-140.
(6) The proposed water appropriation qualifies for the
reserves established and conditioned in WAC 173-517-150.
(7) The proposed water appropriation is for an environmental
restoration project and meets the criteria in WAC 173-517-200.
NEW SECTION
WAC 173-517-120 Conservation standard. Ecology has
determined that a conservation standard for new permit-exempt
withdrawals authorized under RCW 90.44.050 is necessary to conserve
available water and protect instream resources.
(1) For the purposes of this chapter the conservation standard
for permit-exempt withdrawals is defined as follows:
(a) Water use from a permit-exempt well must be consistent
with Jefferson County or ClallamCounty code, as applicable, and
other applicable laws, including the statute on permit exemptions,
RCW 90.44.050, and this rule.
(b) A permit-exempt well serving an individual user shall not
exceed a maximum of 500 gpd or an annual average more than 350 gpd,
for all permit-exempt uses authorized under RCW 90.44.050.
(c) A well serving a group domestic system shall not exceed a
maximum use of 500 gpd or an annual average more than 350 gpd, for
each residence, and shall not exceed a total use of 5,000 gpd for
the group. The design and construction of group domestic systems
must be consistent with applicable state department of health
requirements and applicable Jefferson County or Clallam County
requirements.
(2) New permit-exempt well use exceeding 500 gpd for an
individual use, including individual uses associated with a group
domestic withdrawal, may occur provided all of the following are
met:
(a) Water use greater than 500 gpd must be offset through
implementation of an approved mitigation plan as described in WAC
173-517-030(12). If monitoring of a mitigation plan shows the
mitigation is not effective, departmental approval of the
mitigation plan shall be suspended and the water use shall cease
until the department approves a new or revised mitigation plan; and
(b) Total water use shall not exceed 5,000 gpd.
(3) New permit-exempt withdrawals must measure water use in
accordance with WAC 173-517-180.
[ 14 ]
OTS-2234.8
NEW SECTION
WAC 173-517-140 Maximum future allocations for interruptible
use. (1) Ecology finds there may be water available in excess of
instream flows at certain times of year, which may be appropriated
for interruptible uses. This water is only available from the Big
Quilcene River from November 16 to June 15 and from Chimacum Creek
from December 1 to February 29.
(2) A person or entity seeking a new interruptible
appropriation must provide assurances that any negative effects on
surface water that may result from withdrawals will be limited to
the above locations and times.
(3) In no case shall total cumulative appropriations exceed
the allocation limit specified in Table 7 for each river. However,
ecology may lower these allocation limits on a case-by-case basis,
upon consultation with the state department of fish and wildlife
and tribes, whenever more protection of habitat-forming functions
is needed.
(4) Interruptible uses must not impair existing water rights
and instream flows set in WAC 173-517-090.
Table 7
'nen eriod and Allocation lmit
Allocation
Limit in Cubic
Feet Per Second
(cfs) and
Gallons Per
Water Source Ooen Period Dav (~pd)
Big Quilcene Open Period: Allocation
River November 16 to Limit: 15 cfs;
June 15 . 9.69 million gpd
Chimacum Open Period: Allocation
Creek December 1 to Limit: 3 cfs;
February 29 1.94 million gpd
o
p
L'
NEW SECTION
WAC 173-517-150 Reserves of water for future use. (1)
Ecology has weighed the public interest that supports reserving a
limi ted amount of water for new consumptive uses against the
potential for negative impact to instream resources. For the
subbasins discussed in this section ecology finds that the public
interest advanced by limited reserves clearly overrides the
potential for small negative impact to instream resources.
Based on this finding, ecology hereby allocates an amount of
water for each reserve management area as indicated in Table 8.
[ 15 ]
OTS-2234.8
These reserves of water are not subject to the instream flows
established in WAC 173-517-090 or closures established in WAC 173-
517-100. The priority date of an appropriation from a reserve is
the effective date of this chapter.
These reserves are available to a
set forth in this section are met,
requirements of law, including, but
resource laws and regulations.
(2) These reserves shall be available for use only after the
county with jurisdiction commits to ecology in writing confirming
that determinations of adequate potable water for building permits
and subdivision approvals will be consistent with this chapter.
(3) Permit-exempt well withdrawals from reserves may not occur
where a public water supplier can provide a connection in a timely
and reasonable manner. Determinations of what it means to provide
water service in a timely and reasonable manner shall be consistent
with public water system plans, if applicable, and applicable state
and local laws including, but not limited to, Jefferson County or
Clallam County code.
(4) Donovan, Ludlow, Piddling, Spencer, and Tarboo subbasins.
Withdrawals from the reserves of water in Donovan, Ludlow,
Piddling, Spencer, and Tarboo reserve management areas shall be
limited to permit-exempt well use consistent with the conservation
standard defined in WAC 173-517-120.
(5) Salmon and Snow subbasins. Withdrawals from the reserves
of water in Salmon and Snow reserve management areas shall be
limited to permit-exempt well use consistent with the conservation
standard defined in WAC 173-517-120, and the following: Up to
5,000 gallons per day of the Salmon Creek reserve, and up to 3,000
gallons per day of the Snow Creek reserve may be used for a permit-
exempt withdrawal for commercial agriculture.
(a) Each user must register with ecology or its designee
before water use for commercial irrigation begins.
(b) If the commercial agricultural use ceases, then the
balance of the water returns to the reserve and use of the well
shall be consistent with the conservation standard defined in WAC
173-517-120.
(6) Little Quilcene and Thorndyke subbasins. Withdrawals from
the reserves of water in Little Quilcene (includes Leland and Howe
creeks), and Thorndyke reserve management areas shall be limited to
permit-exempt well use consistent with the conservation standard
defined in WAC 173-517-120, and the uses listed below through
approval of a water right permit subject to a public interest
evaluation that takes into account water availability for future
domestic use in the subbasin:
(a) Municipal or community domestic water supply with domestic
hookups consistent with the conservation standard defined in WAC
173-517-120.
(b) Agricultural irrigation.
(c) Industrial.
(7) Big Quilcene subbasin. Withdrawals from the reserve of
water in the Big Quilcene reserve management area shall be limited
user only if the
as well as any
not limited to,
conditions
applicable
all water
16 ]
OTS-2234.8
to permit-exempt well use consistent with the conservation standard
defined in WAC 173-517-120, and the following:
(a) Permit exempt withdrawal for commercial agriculture.
(i) Each user is limited to 5,000 gpd as a permit-exempt well
under RCW 90.44.050.
(ii) Each user must register with ecology or its designee
before water use for commercial irrigation begins.
(iii) If the commercial agricultural use ceases, then the
balance of the water returns to the reserve and use of the well
shall be consistent with the conservation standard defined in WAC
173-517-120.
(b) The uses listed below through approval of a water right
permit subject to a public interest evaluation that takes into
account water availability for future domestic use in the subbasin:
Ii) Municipal or community domestic water supply with domestic
hookups consistent with the conservation standard defined in WAC
173-517-120.
(ii) Agricultural irrigation.
(iii) Industrial.
(8) Chimacum subbasin. Future withdrawals from the reserve of
water in the Chimacum reserve management area shall be limited to
domestic permit-exempt well use as defined in WAC 173-517-030(5),
and such use shall not include outdoor irrigation, except for the
following:
(a) When alternative water supply or a mitigation strategy is
approved by ecology and implemented, this limitation to domestic
use for the Chimacum basin no longer applies and permit-exempt well
use consistent with the conservation standard defined in WAC 173-
517-120 is allowed.
(b) If the report for U.S. Geological Survey ground water
model currently under construction for the Chima cum Creek subbasin
identifies specific areas within the Chimacum subbasin where new
well pumping will not have any effect on creek flows, withdrawals
from new wells in those areas will not be deducted from the reserve
and will not be subject to the restriction on outdoor irrigation.
Instead, use of new permit-exempt wells will be regulated by the
statutory permit exemption found in RCW 90 _ 44.050. If such a
change occurs, ecology shall notify the public of these findings
through publication of a Chimacum Creek Water Supply Bulletin.
(9) The place of use of water taken from the reserve is
limited to the reserve management area from which it is withdrawn
unless ecology, in consultation with the applicable county,
department of fish and wildlife, and tribes allow specific
transfers between subbasins. An applicant for a water right that
includes out of subbasin water use must comply with WAC 173-517-
210.
(10) When each reserve is fully appropriated, the applicable
reserve management areas are hereby closed to any further
consumptive appropriation. Under such circumstances water for new
uses may be available in accordance with WAC 173-517-110, such as:
. Mitigation is provided;
. The proposed use is nonconsumptive;
[ 17 ]
OTS-2234.8
. Alternative sources of water are available; or
. An existing water right can be changed or transferred.
Table 8
Reserve Mana ement Areas, Reserve Quantities and Allowed Uses
Reserve Management Area Reserve Quantity Maximum
Water Source (including Average Daily Use in Gallons
tributaries) (~nd) Allowed Uses of Reserve*
Big Quilcene 200,400 gpd . Permit-exempt uses under the
conservation standard per WAC 173-
517-120
. PermitMexempt withdrawals for
agriculture
. Water right pennits subject to
public interest test for domestic
availability
Chimacum 1.940 gpd . Permit-exempt withdrawals for
domestic use, no outdoor irrigation
Donovan 2,326 gpd . Permit-exempt uses under the
conservation standard per WAC 173-
517-120
Little Quilcene (includes Leland 38,800 gpd . Permit~exempt uses under the
and Howe creeks) conservation standard per WAC 173-
517.120
. Water right pennits subject to
public interest test for domestic
availability
Ludlow 7,830 gpd . Permit-exempt uses under the
conservation standard per WAC 173-
517.120
Piddling 1.845 gpd . Permit-exempt uses under the
conservation standard per WAC 173-
517-120
Salmon 9,050 gpd . Permit-exempt uses under the
conservation standard per WAC 173-
517-120
. Permit-exempt withdrawals for
agriculture
Snow 4.140 gpd . Permit-exempt uses under the
conservation standard per WAC 173-
517-120
. Permit-exempt withdrawals for
agriculture
Spencer 2,200 gpd . Permit-exempt uses under the
conservation standard per WAC 173-
517-120
Tarboo 7,110 gpd . Permit-exempt uses under the
conservation standard per WAC 173-
517-120
Thorndyke 31,670 gpd . Permit-exempt uses under the
conservation standard per WAC 173-
517-120
[ 18 ]
OTS-2234.8
Reserve Management Area Reserve Quantity Maximum
'Vater Source (including Average Daily Use in Gallons
tributaries) (gpd) Allowed Uses of Reserve*
. Water right pennits subject to
public interest test for domestic
availability
*This table lists the types of allowed uses. See the text of the rule for specific requirements for each use.
NEW SECTION
WAC 173-517-160 Accounting for use under the reserves. (1)
Ecology shall maintain a record of all appropriations from the
reserves.
(2) For an appropriation under a permit, ecology will account
for water use under the reserve based on authorized quantities
under water right permits or certificates, and metering data.
(3) For permit-exempt ground water appropriations from
reserves other than Chimacum subbasin, ecology will deduct a
standard amount of 250 gpd for each single domestic use. For a
permit-exempt agricultural use, ecology will deduct 5,000 gpd for
the Big Quilcene and Salmon Creek subbasins and 3,000 gpd for the
Snow Creek subbasin. The amounts deducted from the reserves may be
adjusted periodically by ecology, to reflect actual use during low
flow conditions based on metering data or other measurements.
(4) For permit-exempt ground water appropriations from the
Chimacum reserve, ecology will deduct a standard amount of 13 gpd
for each single domestic use.
(5) If a water user permanently ceases use of water, ecology
may credit the water to the appropriate reserve, upon
demonstration, through written certification, that the well or
surface water diversion has been decommissioned.
(6) Ecology shall notify the county (or counties) with
jurisdiction, and publish a public notice, when it determines that
fifty percent, seventy-five percent, and one hundred percent,
respectively, of a reserve is appropriated.
(7) If a new appropriation, located in a subbasin with a
reserve, is fully offset through implementation of an approved
mitigation plan as described in WAC 173-517-030(12), then ecology
will not deduct the amount of new water use from the reserve.
[ 19 ]
OTS-2234.8
NEW SECTION
WAC 173-517-170 Lakes and ponds. RCW 90.54.020 (3) (a)
requires, in part, that the quality of the natural environment
shall be protected, and where possible, enhanced, and that lakes
and ponds shall be retained substantially in their natural
condition.
Any withdrawal from a lake or pond in WRIA 17 requires a water
right permit from ecology, and must be consistent with the
provisions of this chapter.
NEW SECTION
WAC 173-517-180 Measuring water use. Each future new
appropriation of ground water or surface water, including permit-
exempt well use, is required to install and maintain a measuring
device (water meter) meeting specifications provided by ecology.
The user must report to ecology, by December 31 of each year, meter
readings demonstrating water use for the previous water year,
October 1 through September 30, or as directed by ecology.
NEW SECTION
WAC 173-517-200 Future surface water withdrawals for
environmental restoration. Ecology finds that the public interest
advanced by future withdrawals for environmental restoration
proj ects (ERPs), as defined and conditioned in this section,
clearly overrides the minimal negative impacts on instream flows.
(1) Ecology may approve a future withdrawal for an ERP only if
it meets all the following:
(a) The proposed water use is for a bypass flow for salmonid
habitat restoration, or for riparian planting, and the primary
purpose of the project is restoration of salmonids;
(b) The proposed project will result in aquatic habitat
benefits, and such benefits will exceed any detriment to aquatic
habi tat that may be caused by reductions in flow at specific
locations and times of withdrawal; and
(c) The proposed use qualifies for a temporary permit.
(2) Ecology, in consultation with the department of fish and
wildlife and tribes, will evaluate proposed ERPs. ERPs approved by
ecology are not subject to closures or instream flows set in this
chapter, unless otherwise conditioned by the permit.
[ 20 ]
OTS-2234.8
NEW SECTION
WAC 173-517-210 out of subbasin water use. (1) Ecology
recognizes that rainfall patterns, and the rain shadow effect of
the Olympic Mountains, affect water availability in WRIA 17. In
addition, population growth patterns in WRIA 17 have historically
shown highest growth in areas with less rainfall. For these
reasons, ecology recognizes that future water right applicants may
request using water from one subbasin in a different subbasin, and
that such out of subbasin water use may have lasting effects on the
community. Such use may occur only if consistent with all
applicable requirements of state and federal law.
(2) An applicant for a water right that includes out of
subbasin water use shall:
(a) Provide the public an opportunity to review and comment on
the proposed application. The applicant shall:
. Advertise and convene a public meeting to explain the
proposal; and
. Allow for public comment
use to be harmful to the public
(b) The applicant shall
identifies:
. Alternatives examined;
. Any alternatives/modifications that the applicant has
rejected and why; and
. Any alternatives/modifications that the applicant accepts
and, if relevant, have been made.
(c) The report in (b) of this subsection shall also summarize
the comments received through the public meeting in (a) of this
subsection on the potential for the proposed use to be harmful to
the public interest.
on the potential
interest.
provide ecology
for the proposed
a
report
which
[ 21 ]
OTS-2234.8
ATTACHMENT 3
Power Point Presentation/Water Supply
May 12, 2009
c E
I-IQ)
-c:J .......
C en
co~
E 1-
Q) Q)
0.......
co
Q) > Ii
1- >' ~
:J I
1- ;,
....... Q) I
:J 0..;
LL E I
0).-
C :J
:pO
Q) Q)
Q)..c
~.......
8
~
..00
-I-J
.- :J
(1) Co..
..c:J (j)
-1-1 ~ 0
og1::o
-1-1 .- :J N
'"0 CO....
(1)CUN
-1-1 co ,...;
co::: C ~
~r--..~co
(1),...;1-~
1- (1)
o..<(tt:
1-1(1)
O:::I'J
$
c
o
.-
........
ro
........
c
CIJ
(/)
(])
1-
a..
4-
o
........
c
(])
........
C
1--1
...(/)
o
>-=>
0.0...
0.Q)
:J.c
(/)-1-1
1-.c
Q)~
10s
SOl
C
ro.-
-1-11::
:Jro
0-1-1
..o(/)
ro"'"
C..-I
I 0 <(
~ -- t--f
! U) 0::::
I a$
I .5:!2 C
-a .-
roM]
Q) '61
iU ~ .
:ProC
.- 1- S
C-I-Io
I-l U)
.
o
c
.-
U)
Q) . -. Q) .
E Be ~x
.~ :p a3 .5:!2 2
r-T\ 19 0. >- C
_, C '" - 0
c 'v 0. U
:P ill (/) 0. >-
U) Q) 1- ::J O'l
ro 1-0 U)Q)
U 0. t: U)-I-I
Q) ... Q)'" ro
1- ... r"'\ 1-
o -aQ)L...J.j....J
4-- 1- _ :::> U)
-r-t ro..o 0... 1-
- 0 .- OJ
C ..0 U) Q).j....J
ro Q)U).cro
E .j....Jo.j....J>
. - 0... ::>
Q)..c 4--
C >...,...; Oro
"0 . - ::> \,J
1-(/):::: Q) Q)e
OJ ro >< E'-
.j....J..o ro.- '"
'" 4-- 0 'v
'v E .c (/) U) Q)
S U.- 1-
U) a :J Ol 9< <:(
U) E C ~...!..
ro . - 1-
a E >-E b ~
U) . - 1- -1-1 U) OJ
.-.c Q) 0 OJ
ou>zo:6
.
.
.
I..
cu
Q.
E
._ U)
:1.5
O'U)
c RS
.- .Q
I
U).Q
E :s
cu(/)
1;; E
>:s
U)u
I.. RS
B E
ta.-
~O
c:;n"C
C C
.- ta
...,
U)
.-
><
w
-
(1)
:e....
(1)0.
....'1-
_c 0
" .-
_c(1)l;'
In C 1.._
CN'sU,..:..
Cc~EE
N ._ Ioi- 0 (1)
C C a) I.....
.- 0 U) 'I- U)
1tJ:i:i ItJ ~ ~
(1) U .c .... I.
< (1) ~ ItJ (1)
I c~::Q.
'i: C Q. (1) E
.... 8 .... -'-
C 1tJ::::S
5 "C (1) U) 0'
.- (1) U (1) (1)
:: 't ~ O.c
"C ItJ __.c....
(1) ~ (1) :: 'E
.5 ~ ~5't
.g C = .;: ItJ
-- 1tJ'- ;:> Q.
.c->
.... :a (1) ~ ItJ
::::s ..., == ~....
O-.cLO
I.. (I) C 0 (1) C
CIJ (1) .s ~ U) >
Q.n:J>U)u Iii
E (1) 0 ::.- M C
.- I. U 0 Q.:t4: (1)
~c:(c~EO~
O'...!. (1) ItJ >::) ~
Qt:.G~O...l~
~ . . . . .
E
CIJ
t)
~
I..
CIJ
....,
RS
3:
.
8
E
(1)
....
Ul
>
(I)
I.
~ ~ ~ =
3:~E~Q.
"C~~(I) g
C VI I. I.
~~~!~
c1ijl.ltJ.......
~3:~3:~
U)....(1)3:"g3:
E 't E:'.... 1tJ_
C1JoociiiltJ
...., 0. (1)'- ..... ~
U)'I-~oc"C
>- 0 0. ItJ 'S;
U) >. 0.(1) 1tJ.-.-
1.."" -"C"C
CIJ .- ItJ ItJ C C
.cuu:::.::..........
c:> · · · · ·
.
U)
c
o
:p
CO
U
o
....J
-
-
(])
$:
'"0
C
CO
E
(])
-I-J
U}
>-- ".
(f)
1-
(])
-I-J
CO
$:
1-
(])
0-
E
.-
::J
a
&
~
. to
>< "0
o C C
a.. ._ =
Q.CI)o
Q.tO_
c:cm...
~:
ij
.n [1 .
;/
1
~
(~
.-'-.,.....--............
/"
.....~.,.'y.,.
\,~
~
co
.-
u
-_.-
tt:
o
c
::J
'--"
re>-
co)
o 0)
. - -I-'
-I-'re
CO ~
1--1-'
aJ(f)
0..0)
Ou
o:S
:::>0
c.. (f)
~
GJ
.-
..0
. 0 (/)
Clo::::"' "'Cl GJ 3:
c t).c:::.. C ~ :5 GJ
'(0 o.~ ro ::l 0 C
.I-J U Cl. (/) 0 ..0 ...........
W GJ E 1: (/) \.i- Ol
U l... >- Ol l... 0 .S
0- .- 2 .I-J Cl.
-g E8 ~ ro (;::. E
ro GJ c 2 3: GJ~~ ~
':>..e Ol ro GJ .c:::.. ~
~ ~'c 3: :6 ..00 GJ
::l l... GJ . 0 ro GJ........... .!::::!
u ro..o0:::::> c :5t: E
~ iO >- GJ 0.. W 0 GJ 'c
- > .I-J.I-J E .-
....ero> Ol.- E
C .I-J.I-J >- c"-" ro (/) c
.- (/) C GJ :.a.,.., (V) GJ . GJ 0 0
:0 ~ GJE "5 .~:t:l:: .N (2' ~ .l...>.I-J .
. - l... . - x - l... CJ):J >-.,.-::..,
X ::l c~ Q) Q) Q)<( 0 c 0l0l
,i ~ (/)0 e 3: .l-Ju 3: tJ ... ~ Q)Q) O.S
, .- Q) ro l... l... 0
I "'Cl > Q) Ol l... GJ .e l...
! "'Cl Q) C Z .I-J C ro.I-J C.I-J C ro
R (/) Q). O.-.e ro.- .e Cl.
ro::l ~ l..."I: U $ (/) ""0 U CJ)
(/) ""0 "'Cl > Cl. ro ro ro c 2.I-J
Q) C C:E "'Cl Cl. "'Cl Q) ...0 ro ro
~ roroo C~~(/)b~ 3:.e
::l Cl. Q)........... ro (/) GJ GJ (/)
o 0.> GJ .I-J ~ ~ ro ~ E C ro
~ GJ tJ Ol ~ ~ i::.e 0 0 ~~
> > Q)CU t:::l GJ~ GJt)=u
Q) oQ) tt=;= Q) 0 "'Cl (/) (/):J .I-J CU
Z GJ > 0.. (/) I-l...........:::::> u ::J...o
. .
.
.
.
.
OJ
en
co
--
>
OJ
--
..0
o
~
u
--
c..
E
~
o
"'0
c::
ro
-I-'
c::
~ro
CJ)1-
QJ en
10 ro
1- .c
-I-'CJ)
U> :J
o 0
:::) 1-
0-:6
~
! "I- E
i 0
;
i QJ
I QJ-I-'
- U>
E~
ro CJ)
X c::
QJ .-
1-
"'0
o
o
19
11 · ·
.- .
:JU>
erQJ
u-I-'
<(~
@
. ....
~-I-'E~
I roQJ cL
QJ .c -I-' 1-
1--I-'(/)U
UQJ>-ro
ro u(/)-
LJ') 1- 1- CO
_ :J QJ c::
N 0 0. 0
N ...(/) E E
....... .- "'0
E .~ ~ "'0
0. (/) "-' CO
en~QJ1-
OO"l-cJ2
LJ') 0 QJ ~
M-I-'(/)-
QJ:JO 0.
1- 0 -I-' 0. .
CO:::: "'0 CO ro
(/) c:: QJ >- b
1: ro (/) OJ -I-'
CJ)QJ:J9.~
.- ..c QJ - I
1- ..c=QJ
1- "'0 .- 1-
2-s:Q$:u
CO 0:J QJro
$ $ 8 $~
.. .
c..
o
o
-I
CJ)
O'l
C
--
-I-'
CJ)
ro
:c
..c
-I-'
:J
o
(f)
(V')
:t:t:
o
:::::>
....J
o
-1-1
0..
:J
M
::J:t::v>
Oc
=>0
.....1=
~ro
00)
~o
v>o
QjO
C~
, ~-......
! 00
! U Lt")
~ II
Ii ~~
I :J~
I~@
-1-1>-
roro
v>-o
~C>
roo
-1-10
o ...
=>~
o...N
.
...
(Y')
~
o
N
>-
..0
4-1
C
O)ul
E~
-1-10)
roC
O)~
~o
4-IU
~ ~
O):J
~o
IV u..
$~
v>0
-1-1
.- E
O)ro
-00)
ro~
~ -1-1
0) v>
o..C
::J$
00
4-1 -0
v>o
-0 v>
0)0
~-o
C~
LJE
.
J..
o E
1:!
.!5!~
c.tI)
...., J..
C OJ
OJ....,
.s~
ta
~ ~
...., c.
....,~E
1- c .- .-
O)OJU::2
E.s;:~
O)taOJ....,
oOJCM
-I-IbE%
wcOQ
>;:J:::>>
roO"C'"
...c .., OJ ....,
...c-cOJU
-1-1 ._ ~ OJ
.- >.:.:: c
$ 0 u C
J.. ta 0
o c..Q u
=>
0......
.
~
-1-1
V>
o
E
E
0)
0)
V>
.
EC
o
0).-
-1-1 -1-1
v> co
>--1-1
U')C
~O)
0) v>
o..~
Eo..
.- V>
:J.-
0:5
o~
-1-10
c~
0-0
.- w
uE
O):J
Cv>
Cv>
oro
Uv>
....-
>--0
O)c
tOro
E>-
.- 0)
~~
=>:=
.
~
,
en (])
..I-J ,-...., C
C M 0
::J:I:: +-'
OJ (/)
.a ""00 s
E c:::>
1.... 12-1 00
..I-J (]) La
0.. (/) '--'" L'T"'-I
.- l-I 0.. co co 'T"'-I (])
E en 0
1.... (])o+-, ~ 1....
E c 0.. COC 1....0.3
0 (]) o -I (]) ~-:J
. tl (/) (/) .
0 .- L(/) co \.I-
..I-J co+-, S Q)~ 1.... (/) +-' (])
U u u o C 0..2 +-'0_
,-....,. - C+-'..o
(]J 0.0 1....'- (]) co (]) co'Vi
.... :::> .!:Q LtlLS
en c EL(/)
-1""0 coco+-,
..I-J C '--'" ~:cC(]) (/)00
C (/)"'0 C.c (]) 2: (/) ~ 0..
0 (]) (V) 1....
(]J +-,(])
U uu o+-'E(]) ~*i:O
E , (/):J(/)(/)
1 'C C
~ COo:::
~ +-'co 1....0(/)0
en -0 ! ,!:Q C (]){/)~+-' -::::>(/)
I - +-'
en C Oli= CL(/)+-, :J C.
\.1--1 (/)
OJ co I SOCOC C(])C
.at:
0,,-..- (]) a'-Eo
en :.=(]) >- ""'"'"5 E o +-' ._
en PE \,00.- tJ
<( +-,'T"'-I\.I-;!:: +-,oE(])
:::>(/) Qj::J:I::coE :JLOEc
- (/) o..o.c E
0 CO(]) o ""0 0 C
u(/) o :J;!:: 0 ...ocuo
::> o(/) O:~s u <( ro~ u
-I co
--I . .
.
~
0'\
o
o
N
.........,
U)
C
o
1-
...,
U
CU
C
C
o
U
U)
CU
U)
I..
CU
>
U)
...,
C
CU
E
...,
I-
E
E
o
u
Ol.n'"
1.n\OI.n
OQ\N
MNM
II II II
I..
QJ
Q.
E
.-
::::J..-.,
0'....
I..:E:M
o "......
""'-"t1'
U) g 0
e._ _
0.......-
.- I.. ..J
1)QJ+
QJ Q. I..
e E QJ
e ._ Q.
o ::::J E
u 0'._
"0 I.. ::::J
~ 2 0'
O"O"t:J
I.. QJ QJ
Q.oIJ:t
Q. oIJ ._
ct'S E
J: E E
000
ouu
-
--ra
rara...,
..) ..L> oIJ 0
'~~~I-
. . .
..
QJ
I..
2
~
QJ
.c
I-
"
U)
e
....0
-.-
QJ1)
J!)QJ
.- e
I..e
QJo
~u
U)"O
CO)
0>
Uo
"t:J1..
-Q.
::::JQ.
Ora
==C\
0.5
::)ol?i
U)
0. .-
....><
MQJ
:t:I:e
00
::)"0
..Jcv
.cU)
...,ta
.-"Q
=="0
QJCV
.- :t
~.-
cvE
1:E
.- 0
CVu
==cu
B~
e
o
e
Q.
o
-
~
cv
"0
o
...,
o
::>
0.
cv
.c
...,
en
e
.-
...,
ta
>
.-
...,
o
E
(/)
.-
<C
C)
::)
ta
QJ
I..
<C
I
.-
I..
1-.
U)
CVQJ
.cu
..., I..
e::::J
taO
.cU)
..., -
ra
CVe
1..0
0._
E:!:
"0
.c"O
Uta
::::J
:t:
....
Q)
c
.am
U) I..
~<C
o.~
I.. I..
1..1-
fa-c
~c
QJ fa
I..Ml
B=I;i
::JQ!
LL.:::)
~...I
QJ
Z
-
<1J
$.+-J
<1J:J
~..o "'ell)
· '" C I..
.;::: >: = Q)
!- n""O 0 ....
~ · '" a.. Q)
0$ ~E
<1J!- ~~
0l<1J ....Q)
C -g .5 c
ro:J lI)M
..c a.. M
U CJ) ~ I
X'- OJ Q)
<1Je E1ij
<1J 0 N "'e
~:p 00
:Ju N....
o <1J I en
CJ)C .coo
ccoo
<1JOSON
cUO~b
.8 E"O o~
CJ) "'era
S20lc~
O CJ) C W VI
>-.-
cCJ)S. ·
1'000
:E.+-JCJ)
.
@
.
!-
<1J
Q.
E C
C 'S S
1'000 0
.+-J Lf') 0 C
C (V') .+-J ~
<1J C
CJ).+-J >- :J
<1J :J CJ) CJ)
!- 0 :J ._
Q...o 0
~roQ)~
"0 !- C 1'0
-OroE
:JQ).+-J
o 01 C Q)
sc19"O
!-roCJ)<(
Q) ..c.~ 19
> ~ "0 ::>
OQ)Q) 1'0
<1J Q) "0 Q)
01 U "0 !-
c!-ro<(
1'0 :J CJ) I
..c 0 !- 'C
uCJ)<1Jl-oj
(V') .+-J E Q)-
::t:I::co !--2
O ro.+-J :J._
.+-JCJ).+-J!-
::>CJ):J:Jro
--I .~ U u.. >
.
.
.... 00
0 0
LL n:s 0
.... (1) ('oJ
n:s ....
(1) <C /'-
>- I 0
.- 0
.... .... ('oJ
(1) .....
a. "C CD
0
U) c: 0
c: n:s ('oJ
0 ..c: LO
.- -+-' 0
-+-' :;j
0 0
(1) 0 ('oJ
c: en ...q-
c: (1) 0
0 > 0
o 0 ('oJ
'+-0 C"0
0 c: 0
0
.... (1) ('oJ
(1) -
..0 (!) ('oJ
E ~ 0
M 0
:;j =It: ('oJ
Z C
~
- ::> 0
n:s 0
-+-' ...J ('oJ
0
..... 0
0
0
('oJ
0 0 0 0 0 0 0
0 0 0 0 0 0
0 LO 0 LO 0 L.()
C"0 ('oJ ('oJ ~ ~
I' . _,,_'u___ ---- -- .----- ---
I
-----n--.---..--.-.--.-m~-.c==c::::c.:=::::::=c==::::=:-1-------------------.---.-..-.........-.-.-----1 8
1C'Cl C"0
. ~ ::j:j::
<((/)0
.~ 0 ::)
1-<.9--1
o II ~
L___.....__._._.___________.
-
tn
s:::
o
-
-
ctS
0>
-
s:::
o
.-
.....
(,)
Q)
s:::
s:::
o
U
s-
Q)
a..
Q)
tn
:::)
.......-...-.............-......------.-.-1
(V) co
~
::J:l:U)<c:
o 1"" I
:::J ......" . i::
--I <.9 f-'
I I I
l_ __...____.________.__.
000
L!) 0 L!)
""" """ (V)
0000000
o L!) 0 L!) 0 L!)
(v)NN~~
~co
"",'S
-- ~~
"'" \S
~ro
"'" 'S
~<::>
"",'S
~ix
"",\S
~':>
"'" \S
~~"'"
~
~,
"'" \S
~~
"'" 'S
@
c
o
.-
....,
U
GJ
C
C
o
U
I-
GJ
D-
GJ
U)
:)
@J
...
~(]) $
COOl 0
. 0.. ~ C
(])CO (]) (])... 0
l.... .j...I > 01 .j...I
<(2co c "'0
...!... CJ) 01 '0.. 0)
"-............c CO l.... ~
~ 2 '$ ~ ~ 0)
..c c ~ -g (j) ..0
~ (])(J) CO ~ c
E(J) (]) CO
(j) C ::J 0) (]) l.... U
.- "-..c E E CO co.
C (]).j...I 0 (J).j...Il....
> ::J CO (])
o 0 0 ..c (/) (]) "'0 0..
t 010 $ 5~ (])E
w WOW u W (j) .-
C ,,-..c c o..::J :::J
roU "-""0 rv
C CJ) O' o..l.... l....\,.J
o (j) ...j...I 0 O)l....
u"-'" -:::J 0.. .j...IO
W(J) 0)0 0>- ro~
Qj E~ :::J.j...I....J C S (j)
0.. 0 CO "'0:= (j) CO c:
.j...I 0.. ...c:::J 01 E . ('.. 0
C (J) ___ W ..0 C -.j...I .-
o ::J C::J 01 .- ro C 1:)
:p uc-Et) t)~OC row
0.. .j...I ::J ro ro :::J.- t: c:
E ~0>:6~ IroiU Oc:
::J 01 U C ::J - ..c u (]) 0.. 0
(j) l.... ....0 0 ro .j...I..oW "- E U
C ro CJ).j...I CJ) ...::J WU.- W
O-19U Wtl:: OCl.... (/)l....
u ...(J) CJ) ~ > 0 CJ) 0::::::- :.c 0
t) ill:::> c 0 01 ;:;;t ro .j...I E
W l.... ... 0 U C :ij: W 5 .~.s:
..c <( ~ u C W 0:::> CC CO(/) ..c>- ~
.01 .:.... ro l.... W > -
Il-z~l9(])....J8~s-g
. .
.
.
.
1--
l:
o
.-
....
o
~
"C
o
l..
0.-
)o,l..
Q) <1l
-~
>
.- l..
~ Q)
~ a.
Q)~
Z Q)
l..
(/l 0
~ <1l
--
a.
O'l
l:
.-
i:
<1l
a.
(/)
N
0
0
N
0 0 0 0 0 0 0
0 I/) 0 I/) 0 I/) 0
1'0 CO CO I/) I/) o::t o::t
00
o
o
N
1'0
o
o
N
co
o
o
N
I/)
o
o
N
o::t
o
o
N
M
o
o
N
@
to
ev
..., ....
-~.- ....
~OJ~ g
OJ 100 OJ N
:5V"C
.. to ~ .:
~Oo "C
O~~ .!
~""'OJ 'i
OUlV ..,
--c Ul
.Q to ._ c.
...., Ul .- C
UlO"C "'0
.:.:: .., c._
to a OJ ev ..,
OJCa SV
-._ C ..L.>:S
.......1: to tij"C
"Cto.c evO
OJ c. V 100 100
.., en c .., c.
5"C:S .'iloo
o c >-Ul >~
~ to G) ~ O"C
to >- e'S E ~
C~tOoOJc
::) > _.., 100
.- "C Ul OJ ..
+ ~ ev:S Uli
lI-cvOJ
"C 0.- C ~ ~
C Ul to._ ~
E.1:~~cv
ev a 100 to to!2
C .- OJ S....
100 Ul 100
II 100 to V "C OJ
ev.cc v
c .., c'- c:s
o to 0 0 to"C
._ ==.- 0' c ~
t = to e
:s to :s......--g
"C~"C"'~c.
o > 0 to ..,-
100 100 OJ .... ev
0. 0 0. C Z.c
. .. .
E
Q)
.....
U)
>.
en
s-
Q)
D..
s-
Q)
.....
~
s:
s-
o
LL
"'C
Q)
.....
s:::
:::s
o
(.)
(.)
~
s:::
::::>
.....
s:::
Q)
(.)
s-
Q)
D..
--r==~c;;.~~ - - -1 ~
~ ~ I
o ~ ~ ~,p I
:::J U "i:: "" -
..J C) t-, 0') CU
I I I j I I
_____________1
LO
(II')
o LO
(II') N
o
o
o
o N
o
N
LO
......
o LO
......
00
o
o
N
<.0
o
o
N
-.::t
o
o
N
N
o
o
N
I
i
I
I
,
j
____I
:::
1-
OJ
+-oJ
co
$
('\..
1-..c:
~cn
.-
-o..c:
OJ 0
t:(f)
::J~
o (f)
u .-
u>.
CO..c:
5$
::: I
"C
cu
(1)(1) ·
(l)fUC
~.c.!2
J.. "C Q.
OJ..fU
fU
~ "C Q.
o cO
OfU-
...-f...,cu
(1)(1)>
cu ..., cu
...,cu"C
fUCUJ..
"CEO
~ ..., cu
E(I)~
::s~
3:E~
.!2 J...... fU
I J..cu~
~ ,., ~ C
i w.w
..., :::.'-
fU;:>=
3:l..e
iti~1..
Q.cufU
._ ~ cu
.~ fU >
C~M
::SfUC
~~o
.
...,
C
cu::so
~o...,
~uu
fUu...,
cufUCU
.... .s i
E(I)o
cuE-
..., III-
(I),Bcu
> fA I..
r ~ v~._
VI >11I-
C (I) ....
o (I).~
._ :::. C
..., ;:>.-
::SOJ:
.c-(I)
. i: iti.:! ui
...,...,11I-(1)
(1).- ,., 0
.- '" -
Q -c.= cu
cul..-~
J: fU ....fU
...,-g~~
(l)fUOfU
fU...,:::.CU
(1);:>-
~,.......ocu
;:> -...,
o .....c fU
c~l..o
~ ........-~ .!!!
.
(l)
g,)
~~
ii~
~fU
.e.5 (I)
~...,cu
~(I)::s
.~ cu_
.ti >- fU
~m >
CIj .....
1...t;U)
()~Q
~ Q.. I..
~CLlcu
:::i 'S ~
CIj 0
~ .S: ~
tS~G
1:) ~ cu
s::~3:
(I) 01;1 (I) ·
fU~S~
J:::5I;""""
uC
Q~fUfU
::) "'1-0 U
Q. ~ \i:
ftii cu._
cu",(I)c
J:~~cu~
t- J: .-
...,(1)
.
G
~ 0'\ I..l"l I..l"l 0'\ (V)
(V') 1..0 1..0 ~ 1..0 0 01
0 '" (V) (V) ~ 1..0 <( c
N (V) ~ 19 :.p
=> "--
ro
N c ~
O"l CO 1..0 (V) (J)
U) 0'\ "'" 1..0 "'" CO ..c (J)
N CO "--
C (V) (V) "'" 0 ~ ro
0 0 N ~ ~ OJ
N (V) 0 >-
"--
,- 01 ~
...., c
U ~ 0 T"""'I I..l"l L.!) 1..0 ro OJ
CU (V) ~ N N ::::l :J
C N '" (V) (V) ~ 1..0 c 0-
0 CO c OJ
C (V) (J) .
N ro N
0 N .0 .,...;
~ :J
C 0
U OJ (J) N
O"l L.!) CO "'" U c
>llIt I..l"l "'" "-- :.p
,-l 0 N N OJ :R c
!:OM"""'" I..l"l T"""'I 0 N Cl.. 0 :J
0 (V) (V) "'" .,...;
.cQ~ N (V) ~ "--
,N '"' c OJ
""'No N OJ ~
ro
~ ,-t ;O"l ..c ~
c ~
O.c. CO I..l"l N I..l"l ro -0 C
:L.tn iO 0 CO 0 0'\ Cl.. c
CJ::J~ '0 N N ro U
f. 0'\ (V) (J)
, ~
00 IN T"""'I N .> L() >-
E:L.M , (J) N .0
I ~
.c '-"" c ~ -0
1- (J) 0
CU...., >- 1- ~ ..c L() OJ
...., -.... I >- ~ (J) ~ 2:
U) ~ -.... .... 0 (J)
> 1- ~ e 0.. 0 (J)
0 >- E .,...;
U') (V) 0 C'O 2: OJ
-.... T"""'I I :::l o . .0
~ U(J) ro
:L. I I 1- -I-J ~ -0 C
CU 0 u ~ C'Vi 0 .~
C'O M C'O C ~ ~
Co <IJ I (V") ~ I I:::l ::::l :J -0 CV)
E 1- *i:: 0 o 0 -0 :j:j:
<( M C'O ~ u~ ro 0
I- I U) 0 -I-J .S o c =>
::J .- U :::> ~ 0 +JOJ (J)
1- ..... U (J) ...J
0' I- 19 .....J :E I- .~ 01"-- E (J)
~ c OJ
.- 0.. :J OJ
. . . . . -0 (J) E
"-- .,...; (J) .
8-0 roO :J
.,...; (J)
U C ......0 ~
<(ro :;EN
. . .
cm~-=il------@
I B :1 I !
~ (9 .... I
I I- j
o II II
1_____.___
-
Q.) Q.)
E '" ~
j::l:,e
J.. .2 ~
Q.) ...., Q.)
> 0 '"
OQ.)-
l: Q.)
,el:~
~8~
o '+- ca
J.. 0 Q.)
(!)J..<i:
J.. Q.) I
Q.) ..0 . i:
o.EI-
E ::J ~
.- l: 0
::J_u)
o I":
C\I
I
i
1.______._..___.__._...____.._
000
000
o I!) 0
I!) o:::t o:::t
000 0
000 0
I!) 0 I!) 0
('1)('1) N N
C'C)
02-
LC)
o~
6'0
o~
<0
o~
-->'d
o~
C'o
o~
Lc
o~
6'L
02-
<L
02-
o
o~
o
o~
LL
o~
o 0 0 0 6.)
~ g 0 vQ I
~ ~ I!) ___._..:._1
n:s
eu
I-
<C
I
I-
I-
l-
e
l-
eu
01..1
~
.c
01..1
~
o
I-
~
-
n:s
::I
01..1
~
e
O'l
0
0
N
co 'It " 'I"'f
0 'It M \0 \0
0 00 M . .
N " \0 . " 'I"'f
'" 00 00 ,...,
0 M 00 00
0 00 'It . .
N " M " "
1.0 'It 'It' '"
0 0 0 00
0 00 00 N .
N " M "
l.() 00 " M
0 \0 \l) 00
0 ,..., 00 . .
N " M Pi Pi
'<T 0 M /"II
0 'It Ln 0\
0 '" M . .
N Pi 'It /"II Pi
(Y) '" ..t .-I
0 0\ M M
0 \0 /"II . .
N Pi M Pi Pi
N Ln
0 '"
0 \0
N Pi
Q)
>- 01
'- Vl Q) -r:: c
ro c u ro "U ro
~ 0 c ...., Q) .g) .c
:p (!) c>- (!) u
u '- (!) (!) en
...... ~ co c
0 (!) ~en c ro
c (!) c ::J ro '6
"U c Cl 0.. ro c: .c
c 0 .c c: u Q)
w U u <( :E
...,
c
cu
V
I.
cu
Q.
..-t~
~M
..-to
@N
.c
.ccn
..., ~
~ 0
o I.
I..c
~...,
EM
cu=l:l:
...,0
(I)::)
>....
(/).c
ta...,
cu.-
I. ~
<(
I
.-
I.
t-
cno 0
"\T'l:tLn'l""l\O\OO'l""l
(V')'l:t\OCO'l:toLnM
OCOMM 'l:tN'l:t
NN
(j)\OCON\OM;~
NN'l:t\O'l:tCONO
~~MM'l:t~ 'l:t
"\TLn'l""lLnLnLnO~
NNM'l:tNNMCO
O'l:tMM'l:tLnMM
NN M
(j)coLnCO'l:t~~fri
T""'IM'I""INONM\O
~~MM'l:tM M
NLn'l""lM
ocnocn
NM\ON
N M
Q)COLn
CDOCO
C!>cnN
rlJ'I""I
I
a..
>-
....... .
~ e
~ ~~ - e e
.....0 ta 0
'1""1""0'1""1 :JU e
I ()' I ~'tj.o
ta'l""lMO_CU
cu '1""1 -'-
< I:J:I:lt6taet6
.tnC ...., ....,
.- U ::>> I-l 0 cu 0
~~..I~I-C::I-
. . . .
. .
Vl
:J
C
E
~
.
~
.0
Eo
(1),-1
~,-1
>- '-"
Vl (I)
4- C
00
t:~
. ro S ..c:
00.0 ......
0...... t: S
,-1Oro e
(I),-1C~ CJ'l
"0 -
.- ro (I) "0 Ul
Ul......VlC :J
......O:J
:J ...... ro ro i5..
OVlUM Vl
......>-(1)""'- ......
cro..o,.,.. c
(j) S en 0 (j)E
u_ -.
'-roO--'
(j) 0...-1 Vl
o.~N E ID
,-1 B .c e ~
"OVl"O...... ro
CS(j)Vl E
roo............
<'-cc e
19lo5(j) ......
::)~u.s ~
C "0 ...... 'E C
.- C 0 (j)
..c:roZE E
...... . 0 ......
S (V) N U 'E
0*,-1_
'-ooro E
Ol::JNO 0
ro...-1>-...... U
:J E ..0 (j) . Vl
cOClo~(j)
C'-O 0"0
ro <i- :p ~ ,_ :J
......VlUCt)U
C ...... (j) (j) '" C
(j) C C .... ,_
U(j)CE~Vl
'-Eo...... ......
(j) .- 0 C
D..:!::uEu(j)
,-1 E (V) E J-< E
,,..., E * o~......
""": 0 U .-
...-l 8 ::J CJ'l -g E
CJ'l Vl ...-1 C ro E
.c (j) (j) 'eM 8
-e E E 'm * ro
o :J :J Eo ......
U Vl Vl (j)::J 0
~ ~ ~ ~...-1 I-
.... .
-----1 @
I
I
I
I
I
I
__.........._.,.._..__......___......___...____________mm___._____._~,______________.__.___.______.____._______,__'_..N "." _ _____ ______ '_00_
~n---n-nn n~1
o CJ) <('
'::> - () .~
l'C;~~~i
-.-..........--.--...-...----...-...-----------.....j
~
0
~
..
ca -
~ N
<f: ~
Q) 0
E .- N
~
.- l- e:
l- .-
~ ~ "'C
Q) 0 Q)
~
> CD "'C
0 . "'C
~
..c ca
~ U) M
3: e: ::J:I::
0 0 c
.-
~ ~ =>
C) (,)
Q) ...J
~ e:
Q) ..
c. e: Q)
0 I..
E Q)
(.) ..c
.-
:::s l.I- 3:
a 0
~ Q)
Q) tIJ
-
..a Q)
E
:::s
e:
-
0000000000
000000000
L()OL()OL()OL()OL()
-.:::t'-.:::t'C0C0NN...---...---
[I~
o~
L'~
O~
82
O~
<'2
O~
~2
O~
[12
O~
L'2
O~
6}
O~
<'L'
O~
S}
O~
C}
O~
L'L'
O~
80
(?~
@:
C'0
=I:t:
o
:::::>
--I
o
- ---. .-.-...._.._.__.__."'----_.._~---,...-..~.._...__..,....,-.....---.-
- ---------i-l
U) <e-
O .2-
CD .=
III 6iI
~f'l;)
- ~
tn ~,
s:::
0 ~
.- ~
...... J!]
(.) ~r'\;
Q) =
s::: OJ ~
s::: E ~'\;
0 .....
.- ~
(.) E
- ~
~ E
0 ~
s::: u ~~
Q) tn
E = ,
c&
...... .-
.- =
E .-
to ~
E E ~
0 OJ
U ~ 0
- ~
co ~
......
0 ~
I-
~f'l;)
~
~,
~
~Oj
~
r----.-.~-'-_.----_..--.,-._-.-..--...-.-
'E
o
o
<D
0:::
.
::2:
o
~~~~~~c:>~~c:>~
~~~c:>c:>c:>~~~~
C:>1O~1O~1OC:>1O~1O
lO"'<T"'<TC'0C'0NN...--...--
@
......,
......, -1-1 LL
LL I
-1-1 -1-1 I LL ~ E
.f-J LL u.. U I 0..
u.. U 01
I I <(
U U <( '<t
OJ N~
<( <( Lt1 "" . cXS
C s...... . OOu.
U 0 0 Lt1 .
0 N Oc::(
<( N l..D 0 ~~
.- N
+-J ~ ~ ~ -.. M
CO ~ ~ (f)
ro
::J a>
E
+-J ro
(f)
.- I
Cf) Z-
0
+-J ..c
..c ....,
:E E E E E E .~
01 C- o.. 0.. 0.. o..~
.- 01
0:::: 19 01 01 01~
0
i 0 0 0 0 o u
i- 0 0 ".t" Lt1 (J)~
OJ I N N ~ ~ l..D ro ....,
"Cl 0..
+-J N N -- E
E a>
CO I 0.. X
01<lJ
S >- 81
I - 0=
OJ - CJ)
g :s:
0 01 > Nr-.
C 0- I 1M
~ I ~
:J o- M U
- 'l:I: 0
a.. !0..- S (j') > 1'0 0'5
1'0 :::l ro
:E ......, -'I
0.. OJ U 0
(j') Z 19 0 r- . .
. . . . .
@
. ........
VI ~ +
c o en r-.. 0 ~
0 \O.-f N M M
.- "':0
.... 0 0 0
u NN N N N
Q) '"'"
:a.. C
Q) C
C.O
("-. C U ........
0 + + +
..I-J o Q,J (fLn ~ ~ ~
._ :a..
:J ~o .-fN M M M
E E \00 0 0 0
0 ....i N N N N
;,"" '"'"
VI Q)
C Ctn
o 0
u"" .
:J ::.s! C
C NO .-fCO
1- o~ 0
-ta U en en r-..N
li-Q,J Ii- Ln.-fLnO
(]) o~ 0 ..... ..... ..... ... N
M~~Ln .......
$ '0>- :a.. 0
0- Q) N
:a.. Q,J ~ c
c.~ E
- (V')
-0 'a_ ;, :j:j:
c= Z I I 0
ta :: ::>
C C C C ...J
:J C Q,J Q) C C C C l:l
0 .2 :: .... 0 0 0 0 <2 l:l
.... ~ U U U U ru
ta ... ...... ...... ...... ...... I Vl
S '= 5 'a"C'a'a ~ 0
> c.c.c.c. u ';::
(1)'- 0 tntntntn ru ru
Vl1j c
:a.. c OJ
C Q,J C.OOLnO 0 u
C o C C.Lnor-..Ln "0 Vl
U C taMMNN OJ ..c
OJ Vl ......
.co s@@@@ ru 0
....u co co
..c .-
s: c . . . . . .
$
en
c
o
.-
.......,
::::J
o
(f)
o
::J
0...
@
....
co
o
o
N
C
,,-....
>
~
o
"'0
(J)
.... 001---)
,,-.... - ro
,,-.... <IJ (J) (J)
1- 01 ~ .b
M (J) ro c
01 :> - CJ') -.
c [;:> ,,-.... aJ ~
:.c CJ') <IJ~E 0
ctl ctl.- 0 0 "'0
Cl.. ~ C-gNU (J)
(f) <( O~ c 1-~1O
"'0 I :P 0:::::... .- ::J .. I (J)
(J) . C ro u >- 0 01 1-"-:"
= I- .C .- "'0 LL C 001---) CJ')
. C E Cl.. ::J "'--" . - 1- 1-
"'0 1- ~ ._ E 001---) C '"'C J2 m
"'--" (J)::J >- CJ') 0 ctl
CJ') 001---) 001---) <IJ - ':>.' - Cl.. ':>. >-
001---) ctl::J.:::c.O...j:...1oo1---)(f)..j:..J1-
..c ~ ~ ro "'--" : = B "'--" U <IJ
01 (J) <IJ CJ') ..0 . - CJ') >
'C 4-0 ..I-J .- Cl.. 001---) ..c 0
CJ') ......c CJ') ..c 001---)
1- "-""::J ro Cl.. . - CJ')
~;:: MJ (J) 6 ~ (J) ro ,01 ~ b..
ro 0 u c:t::..- LL 001---) 1- 001---) E
~ N :J 1- 10 aJ "'--"..c 01 ~ (J)
C 0 ill 2:: ~ C .00.S 1-:Jj
01._ CJ') 001---) (J) .... 0 1- 001---) 001---)
C ro ~ .- CJ') C ro
~ ~ ~ $ ~ 10 aJ 'x 8 >-
._'_ (J) 0 ro .N 10 (J) c
~~~~~g~~~EE
t)(J)0Cl..1->-U}~1f::~"'--"
(J)..o (J) X 0 ::J (J) ill (J) 1-
If::- >w:Ecoozo.. ~~
.. I & .~ ~ · · · · · ...9 ~
.
.
.
@
t'\o. t'\o. 0
Q,J I.. Q,J .....
UI I.. .- .....
Q,J
Q,J t'\o. ..... ::s C Q,J
.cUI m ..... m ::s
.......... ~ ~ V C
~ UlV
I.. t'\o. .-
Q,J .....m C (I) 0 (I) .....
.- Q. .c C
C \l-e .- (I).c
m ..... (I) 0
(I) ......- ..... C t'\o. V .cc V
> ~~ UI (I) I.. I..m
::s .- ::s Q,J
0 I.. (1)- ==
I.. .....0 UI t'\o. "C ::s 0 >Q.
Q. Q,J- >"d' (I) ..... UI (l)C UI
Q. e\l- ..... ::s
=M V Q,J c.2 m
m Q,J~ mc (I) \I- "C
l/) J:'- ::SN C (I) .- 0..... (I)
:I: .c > '-m I..
Ve C C .....C'l ~
C 0 UI.- ._ I.. 0 ..... E m._
.....(1)
Q c:n.: Cd: V C Q. v..., C
__a_
0 .- 'E.e
=t'-. .:E 8m UI C .s 0
.- UI UI Q.(I) .-
-- ~! Q.> oC'l (I) 0 .....
........ E= - .- "C m.c m
.....c ..... -
l/) cm ::s.!2 (1)..2 I.. Q. (I) .......... ::s
0"C 0 0 N .c"C Q.t'\o.
Q...... - .-
OJ .- Q. .ce (I) - C'l-: OUl
1j::si m~ (I) .- .- ::s
m(l) I.. - ..... 1..0 Q.Q,J
(l)c 0 .c ::s V
:J Q,J..... Q,J..... ~~ ES
Cm! .....UI .cUI e m Q,J
c- ! m.c .- .c .......... ::So
a 1..> >
o Q.l Q,J::S (l)U) (I) mm .cUI
Vel I..UI .c m ~ ~.c V (I)
VUI qo. I.. 1..1..
I..(I)! .- (I) Q (I) m UI~
-m ::SQ. (1)1..
E ~..... j Q,J ::;) .c ...I I..
Ull "C= gE 0. c C (1)0 E!
(I) > ! CUI
0(1) .- 0 0 1..\1- Em
1- .....<<^ e~ C'l::S "C .- 0.- ::s==
ml.. .:0' c ..... UI
I.. U"C
QJ I..Q,J U)UI 1:(1) m m Q,J <<^(I)
eij ~m N ..... I..C cu<<^
.e- .-
I- Q.~ (I)<<^ m.c C Q,J ::sm .cCU
Q...... .- .- 0. O"C ......c
C'll.. ::;)C (1)0 U -
0 m C U-(I) -.....
en .....Q,J (1)'- (I)..... Q,J <<^ m (I)<<^ =c.
mQ. .c1j .c> .c Q,J V .c<<^ ~o
.cE .....(1) .....- ..... "C .....(1) -
C ~.- C...... -Q. - - ~ _v ~cu
=D. - - ::0 0>
.....::s me .- .- 0
0 <CO' UQ. 3:~ 3: 3: :I: 3:s. :I:~
....J . . . . . . . .
@)
("..
(.f)
..J-I
C
(])
E
E
o
u
("..
(.f)
c
o
.-
..J-I
(.f)
(])
:::J
CY
. .
~
..c
c
o
.-
+-J
CO
+-J
C
OJ
CJ)
OJ
1-
0...
...... cnN
::t:t: MO
g"C~~~
J.o.ltScn)(q
IV :>...9 <C C1J "C
C'loiJloIoo;:O:J
ItS cEo ~
~ :J :J ~.. CO C1J
E 11III:" UO U U U') ....,
..:. ItSOI@
ItSlVcE::a~
.c u 0 .- ItS M E
1tSJ."..c ItS
J.:Jt:uJ:_.c
~~~o~~~
:=IVIVMOMC'l
CCo::,.,No.__.c
Contents
CHAPTER 1
Overview
1
CHAPTER Z
Emerging Trends in Planning, Development, and Climate Change 17
CHAPTER 3
The VMT/COz/Climate Connection
37
CHAPTER 4
The Urban EnvironmenttVMT Connection
55
CHAPTER 5
Environmental Determinism versus Self Selection
91
CHAPTER 6
Induced Traffic and Induced Development
99
CHAPTER 7
The Residential Sector
107
CHAPTER 8
The Combined Effect of Compact Development,
Transportation Investments, and Road Pricing
113
CHAPTER 9
Policy and Program Recommendations
129
CHAPTER 10
Conclusion
155
Notes
157
References
159
Related ULI Publications
170
Overview
The phrase "you can't get there from here" has a new application.
For climate stabilization, a commonly accepted target for the year 2050 would require
the United States to cut its carbon dioxide (CO,) emissions by 60 to 80 percent below
1990 leveis. Carbon dioxide levels have been increasing rapidiy since 1990, and
so would have to level off and decline even more rapidly to reach this target level by
2050. This publication demonstrates that the U.S. transportation sector cannot do
its fair share to meet this target through vehicle and fuel technology alone. We have
to find a w~ to sharply reduce the growth in vehicle miles driven across the nation's
sprawling urban areas, reversing trends that go back decades.
This publication is based on an exhaustive review of existing research on the
relationship among urban development, travel, and the CO, emitted by motor vehicles.
It provides evidence on and insights into how much CO, savings can be expected with
compact development, how compact development is likely to be received by con.
sumers, and what policy changes will make compact development possible. Several
related Issues are not fully examined in this publication. These include the energy
savings from more efficient building types, the value of preserved forests as carbon
sinks, and the effectiveness of pricing strategies-such as tolls, parking charges,
and mileage-based fees-when used in conjunction with compact development and
expanded transportation alternatives.
The term "compact development" does not imply high-rise or even uniformly high
density, but rather higher average "blended" densities. Compact development also fea-
tures a mix of land uses, development of strong population and employment centers,
interconnection of streets, and the design of structures and spaces at a human scale.
THE BASICS
Scientific consensus now
exists that greenhouse gas
accumulations due to human
activities are contributing to
global warming with potentially
catastrophic consequences
(IPCC 2007). International
and domestic climate policy
discussions have gravitated
toward the goal of limiting the
temperature increase to 20C to
3'C by cutting greenhouse gas
emissions by 60 to 80 percent
below 1.990 levels. The primary
greenhouse gas is carbon
dioxide, and every gallon of
gasoline burned produces
about 20 pounds of CO,.
1
2 OVERVIEW
Driving Up CO2 Emissions
The United States is the largest emitter worldwide of the greenhouse gases (GHGs)
that cause global warming. Transportation accounts for a full third of CO, emissions
in the United States, and that share is growing, rising from 31 percent in 1990 to 33
percent today. It is hard to envision a "solution" to the global warming crisis that does
not involve slowing the growth of transportation CO, emissions in the United States.
The Three-Legged stool Needed to Reduce CO2 from Automobiles
Transportation CO, reduction can be viewed as a three-legged stool, with one leg
related to vehicle fuel economy, a second to the carbon content of the fuel itself, and
a third to the amount of driving or vehicle miles traveled (VMT). Energy and climate
policy initiatives at the federal and state levels
have pinned their hopes on shoring up the first
two legs of the stool, through the development
of more efficient vehicles (such as hybrid cars)
and lower-carbon fueis (such as biodiesel fuel).
Yet a stool cannot stand on only two legs.
As the research compiled in this publica-
tion makes clear, technological improvements
in vehicles and fuels are likely to be offset by
continuing, robust growth in VMT. Since 1980,
the number of miles Americans drive has grown
three times faster than the U,S. population, and
almost twice as fast as vehicle registrations
(see Figure 1-1). Average automobile com-
mute times in metropolitan areas have risen
steadily over the decades, and many Americans
now spend more time commuting than they do
vacationing.
This raises some questions, which this report addresses. Why do we drive so
much? Why is the total distance we drive growing so rapidly? And what can be done to
alter this trend in a manner that is effective, fair, and economically benign?
The growth in driving is due in large part to urban development, or what some
refer to as the built environment. Americans drive so much because we have given our-
selves little alternative. For 60 years, we have built homes ever farther from workplaces,
located schools far from the neighborhoods they serve, and isolated other destina-
tions-such as shopping-from work and home. From World War II until very recently,
nearly all new development has been planned and built on the assumption that people
will use calS f?Nery time they travel. As a larger and larger share of our built environ-
ment has become automobile dependent, car trips and distances have increased,
and walking and public transit use have declined. Population growth has been respon-
GROWING COOLER: THE EVIDENCE ON URaAN DEVELOPMENT AND CLIMATE CHANGE 3
sible for only a quarter of the increase in vehicle miles driven over the last couple of
decades. A larger share of the increase can be traced to the effects of a changing built
environment, namely to longer trips and peopie driving alone.
As with driving, land is being consumed for development at a rate almost three
times faster than population growth. This expansive development has caused CO,
emissions from cars to rise even as it has reduced the amount of forest land available
to absorb CO,.
How Growth in Driving Cancels Out Improved Vehicle Fuel Economy
Conventional pollutants can be reduced in automobile exhaust with sophisticated
emission control systems such as cataiytic converters, on-board computers, and
oxygen sensors. In contrast, CO, is a fundamental end product of burning fossil fuels;
there is no practical way to remove or capture it from moving vehicles. At this point
in time, the only way to reduce CO, emissions from vehicles Is to burn less gasoline
and diesel fuel.
An analysis by Steve Winkeiman of the Center for Clean Air Policy, one of
the coauthors of this publication, finds that CO, emissions will continue to rise,
despite technological advances, as the growth in driving is projected to overwhelm
planned improvements in vehicle efficiency and fuel carbon content from the Energy
Independence and Security Act of 2007 (U.S. Congress 2007). The act requires pas-
senger vehicle fuel economy improvements to at least 35 miles per gallon (mpg) for
new passenger vehicles by 2020, which would lead to a 34 percent increase in fleet-
wide fuel economy by 2030 (green line in Figure 1.2). The act also sets renewable
fuel requirements that Winkelman calculates would reduce Iifecycle GHG emissions
by 10 percent by 2025 (purple line). Absent growth in driving, these measures would
reduce CO, emissions from cars and light trucks by 23 percent below current levels.
4 OVERVIEW
Even when these more stringent standards for vehicles and fuels fully penetrate
the market, however, transportaUon-related emissions still would far exceed target
ievels for stabilizing the globai climate. The U.S. Department of Energy's Energy
InformaUon Administration (EIA) forecasts a 48 percent increase in driving between
2005 and 2030 (orange line in Figure 1-2), outpacing the projected 23 percent
increase in population (EIA 2008).' The rapid increase in driving would overwhelm
both the increase in vehicle fuel economy and the iower carbon fuel content required
by the Energy Independence and Security Act of 2007. Carbon dioxide emissions from
cars and light trucks would remain at 2005 ievels (blue line), or 26 percent above
1990 levels (light blue line) in 2030. For climate stabilization, the United States must
bring the CO, level to approximately 33 percent below 1990 levels by 2030 to be on
a path to a CO, reduction of 60 to 80 percent by 2050 (red line).
As the projecUons show, the Unned States cannot achieve such large reducUons
in transportaUon-related CO, emissions without sharpiy reducing the growth in the
number of miles driven.
Changing Development Patterns to Slow Global Warming
Recognizing the unsustainable growth in driving, the American AssociaUon of State
Highway and Transportation Officials (AASHTO), represenUng state departments of
transportation, is urging that the growth of vehicle miles driven be cut in half. How
does a growing country-one with 300 million residents and another 120 million on
the wirf by mid-century-slow the growth of vehicle miles driven? Aggressive measures
certainly are available, including imposing ever stiffer fees and taxes on driving and
parking or establishing no-drive zones or days. Some countries are experimenting with
such measures. However, many in this country would view these measures as puniUve,
given the reality that most Americans do not have a viable alternative to driving. The
body of research surveyed here shows that much of the rise in vehicle emissions can
be curbed simply by growing in a way that will make it easier for Americans to drive
less. in fact, the weight of the evidence shows that, with more compact development,
people drive 20 to 40 percent less, at minimal or reduced cost, while reaping other
fiscal and health benefits.
How Compact Development Helps Reduce the Need to Drive
Beller communny planning and more compact development help people live within
walking or bicycling distance of some of the desUnations they need to get to every
day-work, shops, schools, and parks, as well as transit stops. If they choose to use a
car, trips are short. Rather than building single.use subdivisions or office parks, com-
munnies can plan mixed-use developments that put housing within reach of these
other desUnations. The street network can be designed to interconnect, rather than
end in culs-de-sac and funnel traffic onto overused arterial roads. Individual streets
GROWING COOLER: THE EVIDENCE ON URBAN DEVelOPMENT AND CLIMATE CHANGE 5
fiGURE 1.3
Housing within One-Quarter Mile of Commercial Centers for Contrasting Developn.ellt Patterns ill Seattle
can be designed to be "complete; with safe and convenient places to walk, bicycle,
and wait for the bus. Finally, by building more homes as condominiums, townhouses,
or detached houses on smaller lots, and by building offices, stores and other destina-
tions "up" rather than "out; communities can shorten distances between destinations.
This makes neighborhood stores more economically viable, allows more frequent and
convenient transit service, and helps shorten car trips.
This type of development, which has seen a resurgence in recent years, goes by
many names, including "walkable communities; "new urbanist neighborhoods," and
"transit-oriented developments" (lODs). "Infill" and "brownfield" developments put
unused parcels in urban areas to new uses, taking advantage of existing infrastruc-
ture and nearby destinations. Some "lifestyle centers" are now replacing single-use
shopping malls with open-air shopping on connected streets with housing and office
space above stores. And many communtties have rediscovered and revitalized their
traditional town centers and downtowns, often adding more housing to the mix. These
varied development types are collectively referred to in this publication as "compact
development" or "smart growth."
How We Know That Compact Development
Will Make a Difference: The Evidence
As these forms of development have become more common, planning researchers
and practitioners have documented the fact that residents of compact, mixed-use,
transtt-served communities drive less than their counterparts in sprawling communi-
ties. Studies have looked at the issue from varying angles. They have:
SOURCE: A.V. Moudon, P.M. Hess, M.C.
Snyder, and K. Stanilov. "Effects of Site
Design on Pedestrian Travel in Mixed-Use,
Medium-Density Environments."
Transportation Research Record.
Vol. 1578, 1997. pp. 48-55.
6 OVERVIEW
"compared travel statistics for regions and neighborhoods of varying compact-
ness and auto orientation;
"anaiyzed the travel behavior of individual households in various settings; and
10 simulated the effects on travel of different future development scenanos at the
regional and project scales.
Regardless of the approach, researchers have found significant potential for compact
development to reduce the miles that residents drive.
A comprehensive sprawl index developed by coauthor Reid Ewing of the National
Center for Smart Growth at the University of Maryland ranked 83 of the largest met-
ropolitan areas in the United States by their degree of sprawl, measured in terms of
population and employment density, mix of land uses, strength of activity centers, and
connectedness of the street network (Ewing, Pendall, and Chen 2002,2003). Even
accounting for income and other socioeconomic differences, residents drove about 25
percent less in the more compact regions. In sprawling Atlanta and Raleigh, residents
racked up more than 30 miles driving each day for every person living in the region. In
more compact Boston and Portland, Oregon, residents drove less than 24 miles per
person per day.
This finding holds up in studies that focus on the travel habits of individual
households. The link between urban development patterns and individual or house-
hold travel has become the most heavily researched subject in urban planning, wtth
more than 100 rigorous empincal studies completed. These studies have been able to
account for factors such as the tendency of higher-income households to make more
and longer trips than lower-income families.
One of the most comprehensive studies, conducted in King County, Washington,
by Larry Frank of the University of British Columbia (Frank, Kavage, and Appleyard
2007), found that residents of the most walkable neighborhoods dnve 26 percent
fewer miles per day than those living in the most sprawling areas. A meta-analysis
of many of these types of studies shows that people living in places with twice the
density, diversity of uses, accessible destinations, and interconnected streets drive
about a third less than otherwise comparable residents of low-density sprawl.
Many studies have been conducted by or in partnership with public health re-
searchers interested in how the built environment can be better designed to encour-
age daily physical activity. These studies show that residents of communities designed
to be walkable both drive fewer miles and also make more trips by foot and bicycle,
which improves individual health. A recent literature review found that 17 of 20
studies, all dating from 2002 or later, have established statistically significant links
between some aspect of the built environment and obesity.
Two other types of studies also find strong associations between develop-
ment patterns and driving: simulations that predict the impacts of various growth
options for entire regions and simulations that predict the impacts of individual de-
velopment projects when stted and designed in different ways. In regional growth
GROWING COOLER: THE EVIDENCE ON URBAN DEVELOPMENT AND CLIMATE CHANGE 7
simulations, planners compare the effect of a
metropolitan-wide business-as-usual scenario
with more compact growth options. Coauthor
Keith Bartholomew of the University of Utah
analyzed 23 ofthese studies and found that
compact scenarios generate up to one-third
fewer miles driven than business-as-usual sce-
narios (Bartholomew 2005, 2007). The better-
performing scenarios are those with higher
degrees of land use mixing, infill development,
and population density, as well as a larger
amount of expected growth. Under a plausi-
ble set of assumptions, the reduction of miles
driven with compact development would be 18
percent by 2050. Even this may be on the low
side, since the travel models used in these stud-
ies only crudely account for travel within neigh-
borhoods and disregard walk and bike trips entirely. Atlantic Station today.
Of the project-level studies, one of the best known evaluated the impact of
building a very dense, mixed.use development at an abandoned steel mill sHe in
the heart of Atlanta versus spreading the equivalent amount of commercial space
and number of housing units in the prevailing patterns at three suburban loca-
tions. Analysis using travel models enhanced by coauthor Jerry Walters of Fehr &
Peers Associates (Walters, Ewing, and Allen 2000), and supplemented by the U.S.
Environmental Protection Agency's Smart Growth Index (to capture the effects of site
design) found that the infill iocation would generate about 36 percent less driving and
emissions than the outlying comparison sites. The results were so compelling that the
development was deemed a transportation control measure by the federal govern-
ment for the purpose of improving the region's air quality.
The Atlantic Station project in Midtown Atlanta has become a highly successful
reuse of central city industrial land. An early evaluation of travel by residents and
employees of Atlantic Station suggests even largerVMT reductions than projected
originally. On average,Atlantic Station residents are estimated to generate eightVMT
per day, and employees to generate 11 VMT per day. These estimates compare favor-
ably wHh a regional average VMT of more than 32 miles per person per day, among
the highest in the nation.
The Potential of Smart Growth
The potential of smart growth to curb the rise in GHG emissions will, of course, be
limited by the amount of new development and redevelopment that takes place over
8 OVERVIEW
WHAT SMART GROWTH WOULD lOt)l( LII([
How would this shift to compact development change U.S. communities? Many more developments would look
like the transit-oriented developments and new urbanist neighborhoods already going up in almost every city in
the country, and these developments would fill in vacant lots, replace failing strip shopping centers, and revita~
ize older town centers, rather than displacing forests or farmland. Most developments would no longer be single-
use subdivisions or office parks, but would mix shops, schools, and offices together with homes. They might
feature ground-floor stores and offices with living space above. or town homes within walking distance of a retail
center. Most developments would be built to connect seamlessly with the external street network.
The density increases requIred to achieve the changes proposed in this publication would be moderate. In
2003, the average density of residential development in U.S. urban areas was about 7.6 units per acre. As a result
of Shifting market demand, new developments between 2007 and 202S would average 13 units per acre, and
the average density of metropolitan areas overall would rise to approximately nine units per acre.
Two recent publications-This Is Smart Growth (Smart Growth Network 2006) and Visualizing Density
(Campoli and Maclean 2007)-provide a glimpse of what this future might look like.
the next few decades, and by the share of it that is compact in nature. A great deal
of new building will take place as the U.S. population grows to 420 million in 2050.
According to the best available analysis, by Arthur 'Chris' Nelson of Virginia Tech, 89
million new or replaced homes-and 190 billion square feet of new offices, institu-
tions, stores, and other nonresidential buildings-will be constructed through 2050. If
Nelson's forecasts are correct, two-thirds of the development on the ground in 2050
will be buin between 2007 and then. Pursuing smart growth is a low-cost climate
change strategy, because It involves shifting investments that have to be made anywWf.
Smart Growth Meets Growing Market Demand for Choice
There is no doubt that moving away from a fossil fuel-based economy will require
many difficult changes. Fortunately, smart growth Is a change that many Americans
will embrace. Americans are demanding more choices in where and how they live, and
changing demographics will accelerate this change in demand.
While prevailing zoning and development practices make sprawling development
easier to build, developers who make the effort to create compact communities are
encountering a responsive public. In 2003, for the first time in the country's history,
the sales price per square foot for attached housing-that is, condominiums and
townhouses-was higher than that of detached housing. The real estate analysis firm
Robert Charles Lesser & Co. has conducted a dozen consumer preference surveys
in suburban and urban locations' for a variety of builders to help them design their
projects. In every location examined, about one-third of respondents prefer smart
growth housing products and communities. Other studies by the Nalional Association
of Homebuilders, the National Association of Realtors, the Fannie Mae Foundation,
GROWING COOLER: THE EVIDENCE ON URBAN DEVELOPMENT AND CLIMATE CHANGE 9
high-production builders, and university researchers have corroborated these results-
some estimating even greater demand for smart growth housing products. When smart
growth also offers shorter commutes, it appeals to another one-quarter of the market,
because many people are willing to trade lot or house size for shorter commutes.
Because the demand is greater than the current supply-according to a study
by Chris Leinberger of the Brookings Institution-the price-per-square-foot values of
houses in mixed-use neighborhoods show price premiums ranging from 40 to 100
percent, compared to houses in nearby single-use subdivisions.
This market demand is only
expected to grow over the next
several decades, as the share
of households made up of older
Americans rises with the aging of
the baby boomers. Through 2025,
households without children will
account for close to 90 percent of
new housing demand, and single-
person households will account
for one-third. Nelson projects that
the demand for attached and
small-lot housing will exceed the
current supply by 35 million units
(71 percent), while the demand for
large-lot housing actually will fall
short of the current supply.
Total Estimated VMT Reduction and Total Climate Impact
When viewed in total, the evidence on land use and driving shows that compact devel-
opment will reduce the need to drive between 20 and 40 percent, as compared with
development at the outer suburban edge with isolated homes, workplaces, and other
destinations. So, as a rule of thumb, it is realistic to assume a 30 percent cut in VMT
with compact development.
Making reasonable assumptions about growth rates, the market share of com-
pact development, and the relationship between VMT and CO" smart growth could,
by itself, reduce total transportation-related CO, emissions from current trends by
7 to 10 percent in 2050. This reduction is achievable with land use changes alone.
It does not include additional reductions from complementary measures, such as
higher fuel prices and carbon taxes, peak-period road tolls, pay-as-you drive insur-
ance, paid parking, and other policies designed to make drivers pay more of the full
social costs of auto use.
10 OVERVIEW
This estimate also does not include the energy saved in buildings with compact
development, or the CO2-absorbing capacity of forests preserved by compact develop-
ment. Whatever the total savings, it is importantto remember that land use changes
provide a permanent climate benefit that would compound overtime. The second 50
years of smart growth would build on the base reduction from the first 50 years, and
so on into the future. More immediate strategies, such as gas tax increases, do not
have this degree of permanence.
The authors calculate that shifting 60 percent of new growth to compact patterns
would save 79 million metric tons of CO2 annually by 2030. The savings over that
period equate to a 28 percent increase in federal vehicle efficiency standards, gen-
erating one-half of the cumulative savings of the new 35 mpg CAFE standards. Every
resident of a compact neighborhood would provide the environmental benefit expected
from, say, driving one of today's efficient hybrid cars. This effect would be compounded,
of course, if the resident also drove such an efficient car whenever he or she chose to
make a vehicle trip. Smart growth would become an important "third leg" in the trans-
portation sector's fight against global warming, along with more efficient vehicles and
lower-carbon fuels.
A Climate-Sparing Strategy with Multiple Payoffs
Addressing climate change through smart growth is an attractive strategy because, in
addition to being in line with market demand, compact development provides many
other benefits. Documented co-benefits include preservation of farmland and open
space, protection of water quantity and quality, improvement of health by providing
more opportunities for physical activity, and reduction of road and other infrastruc-
ture costs. For example, the Envision Utah scenario planning process resulted in a
compact growth pian that will save the region about $4.5 billion in infrastructure
spending, leave 171 square miles of additional open space, and reduce per capita
water use by more than 10 percent.
Among the co-benefits of compact development, perhaps the most important is
greater energy security. Compact development uses less energy per capita than does
sprawl. As the world approaches and then passes peak production of conventional oil,
in the face of ever-rising demands, Americans in compact urban areas will be better
able to weather the economic storm of rapidly rising gasoline prices. Moreover, to
the degree that the United States makes the transition to compact development, the
country as a whole will be less dependent on regions of the world that are unstable,
hostile, and/or especially vulnerable to terrorist attacks.
Finally, unlike hydrogen and cellulosic ethanol, which get a lot of attention in the
climate change debate as substitutes for gasoline, the "technology" of compact, walk-
able communities exists today, as it has in one form or another for thousands of years.
We can begin using this technology in the service of a cooler planet right now.
GROWING COOLER: THE EVIDENCE ON URBAN DEVELOPMENT AND CLIMATE CHANGE 11
The Combined Effect of Compact Development,
Transportation Investments, and Road Pricing
Accurately forecasting the implications of compact development forVMT requires an
understanding of the network of interactive effects of population growth, land use,
transportation investments, and road pricing on driving patterns. Analyses of historical
data make It clear that VMT responds to a variety of forces in a complex w~. Growth
of metropolitan areas during the past 20 years has been characterized by an actual
decrease in population density, as urbanized areas have expanded faster than popu-
lation. This trend has started to reverse itself, but current conditions reflect the legacy
of this era of sprawl.
During this period, the emphasis in the majority of urbanized areas has been
on increasing highway capaCity and the result has been a steady rise in VMT that has
exceeded population growth (see Figure 1-2). Increases in average income during this
period have contributed to substantially greater use of and reliance on personal vehi-
cles. Rising personal income, while positive in other respects, has worked to promote
sprawl, discourage mass transit ridership, and increase VMT.
During the decade from 1985 to 1995, decreases in inflation-corrected gas
prices appear to have contributed to increases in VMT. During the past ten-year period,
however, gas prices have increased as has traffic congestion, and both of these forces
have begun to create pressures to reduce VMT.
Nationally, mass transit has contributed relatively little thus far to reducing reli-
ance on personal vehicle use in the majority of urbanized areas. increasingly, cities are
attempting to build more mass transit capacity, and it is clear that such a development
could act to reduce VMT if the right set of associated circumstances prevails. Internal
12 OVERVIEW
FIGURE 1.7
Urban VMT Reduction IInder a Low-Carbon Scenario (2030)
forces such as further increases in traffic congestion and delays, along with sustained
elevated fuel prices, can be expected to automatically produce reductions in VMT as
they affect personal decisions. A deliberate strategy of compact development and
smart growth has the potential to reverse historic trends to an even greater degree.
In Chapter 8, we mathematically model the interactions described above using
a statistical technique called structural equation modeling (SEM) and relying on his-
torical data for 84 urbanized areas. Two modeis were estimated with our combined
datasel: a cross-sectional model for 2005 and a iongitudinal model for the two
ten-year periodS between 1985 and 2005. The cross-sectional model was used to
capture long-term relationships between transportation and land use. Each urbanized
area has had decades to arrive at quasi equilibrium among density, road capacity,
transit capacity, and VMT. However, there is not enough spatial variation in fuel prices
across the United States to detect effects on VMT in a cross-sectional sample. So a
longitudinal analysis was required to capture short- and medium-term responses to
fuel price fluctuations.
Together, the cross-sectional and longitudinal models give us a sound basis
for deducing the elasticities of urban VMT with respect to different urban variables.
An elasticity is the percentage change in one variable, such as VMT, with respect to
a 1 percent change in another variable, such as density or average gasoline price.
Using reasonable assumptions about future density, average gasoline price, and other
variables, we project that under a trend scenario, urban VMT in the Untted States will
experience a rise of 48 percent by 2030 and 102 percent by 2050, leaving the nation
far off a climate-stabilizing CO, path. In contrast, under a low-carbon scenario of higher
densities, higher gasoline prices, less highway expansion, and more transit service, the
nation can come close to a climate-stabilizing CO, path by 2030 (see Figure 1-7).
Policy and Program Recommendations
Intentionally or not, many current public pOlicies increase sprawl, auto dependence and,
hence, GHG emissions. Many local zoning codes require low-density, single-use devel-
GROWING COOLER: THE EVIDENCE ON URBAN DEVELOPMENT AND CLIMATE CHANGE 13
opment Public spending frequentlY supports development at the urban fringe rather
than in already developed areas. Transportation policies remain focused on accom-
modating the automobile. Implementing an effective smart growth strategy for climate
stabilization will require reorienting these and many other policies and programs.
Here, we summarize key policy initiatives at each level of government that could
form the basis for this policy transformation. The speCifics of these initiatives can be
found in Chapter 9.
Federal Actions
Enact a "Green-TEA" Transportation Act. Beginning in 1991 with the Inter-
modal Surface Transportation Efficiency Act (known as ISTEA), federal surface
transportation acts have put increasing emphasis on alternatives to the automo-
bile, as well as on community involvement, environmental goals, and coordinated
planning. The next surface transportation bill, scheduled for adoption in 2009,
could bring yet another paradigm shift by emphasizing environmental performance,
climate protection, and green development. We refer to this proposed new legisla-
tion as "Green-TEA."
The key feature of Green-TEA would be a requirement that states and metro-
politan areas achieve articulated national goals when spending federal transportation
funds. These goals would include GHG emission reductions necessary for eventual
climate stabilization, "fix-rr-first" prioritization for transit and highway rehabilitation
and maintenance, and "complete streets" that provide for all transportation modes.
Other Green-TEA provisions would:
.. create state and metropolitan funding formulas with incentives for reducing
transportation demand instead of rewarding increased driving, as current
legislation does;
.. enm.lnate funding and procedural inequ'lties between highway and transit
projects;
" give deteriorating roads, bridges, and transrr systems priority in funding, lim-
iting highway expansion until existing facilities are brought up to reasonabie
standards;
II require any subsequent highway expansions to meet economic, transportation,
and climate performance standards;
II provide direct project funding for metropolrran planning organizations (MPOs)
instead of routing federal funds through state departments of transportation;
II provide technical assistance to MPOs and state and local governments,
including improved data, models, and scenario planning tools to help in devel-
oping and implementing smart growth solutions; and
"establish a new National Transportation System Administration to oversee a
national high-speed rail network and integrate that network with the nation's
aviation system.
14 OVERVIEW
Extend Transportation Conformity Requirements to GHGs. In Massachusetts
v. EPA, the U.S. Supreme Court affirmed the EPA's authority and duty to regulate GHG
emissions under the current federal Clean Air Act. The EPA could meet its obligation
by adopting national GHG reduction targets, requiring states to develop state imple-
mentation plans for meeting these targets, and mandating that state and metropolttan
transportation plans and programs conform to state implementation plans.
Use Cap and Trade to Support Smart Growth. Many Congressional proposals for
climate stabilization would authorize a national cap-and-trade market system similar
to those in use in Europe and under development in several states. The revenues
generated from auctioning allowances under these systems could be used to support
smart growth. Uses of funds might include providing technical assistance to MPOs and
state and local governments, including improved data, models, and scenario planning
tools; a "Smart Location Tax Credit" targeted at compact development; and support
for travel alternatives such as transit, bicycling, and pedestrian infrastructure that
are important complements to compact development. Although land development is
unlikely to become a regulated activity (like electrical power generation) under cap-
and-trade systems, it may have a role to play in "offset" markets. It could be included
as an allowable offset in any cap-and-trade climate legislation.
State Actions
Adopt and Suballocate VMT Reduction Targets. In the absence of federal
leadership, many states have adopted goals for GHG reduction. These goals could
be translated into VMT reduction targets. The targets could be proportionally allo-
cated to metropolitan regions within a state, and each MPO could be charged with
developing a plan for meeting its respective target. VMT targets could even be sub-
allocated to localities.
Align State Spending with Climate and Smart Growth Goals. After adopting
targets, states will want to ensure that funding programs-whether carried out directly
by the state or executed through grants to local governments-support such targets.
States can begin by analyzing the criteria used to distribute all state and federal funds
in housing, economic development, water and sewer infrastructure, schools, transpor-
tation, and recreation. States could earmark and distribute at least a portion of these
funds according to local performance in meeting GHG and VMT reduction targets.
Adopt a Statewide .Complete Streets" Policy and Funding Program.
A complete streets policy would require that pedestrian and bicycle facilities be
provided on all new and reconstructed streets and highways, and that pedestrian
and bicyclists' needs be considered in routine roadway operation and mainte-
nance. To create complete communities, the pOlicy might mandate that new streets
GROWING COOLER: THE EVIDENCE ON URBAN DEVELOPMENT AND CLIMATE CHANGE 15
be interconnected and culs-de-sac be discouraged so that travel distances for
pedestrians and bicyclists are minimized.
Regional Actions
GIve Funding Priority to Compact, Transit-Served Areas. By giving funding
priortty to compact, transit-served areas, MPOs can heip reduce GHG emissions. In
concert with local governments, MPOs would designate "priority funding areas" where
local governments have planned for compact development In addftion to receiving
prtority for public funds, areas could qualify for streamlined development approvals
and other financial incentives.
Establish a Regional Transfer of Development Rights Program. Transfer of
development rights (TOR) programs enable landowners to sell their development rights
to other landowners through a market-based system. Effectively crafted, TDR programs
can help reduce YMr by directing growth to compact, transft-served areas and away
from low-density greenfield sites, thus reducing the need for long-distance travel.
While lOR programs typically have been administered by local governments, a regional
lOR program likely would encompass more rural and urban areas, thereby providing
greater market opportunities forlOR transfers.
Create a Carbon Impact Fee for New Development. Suburban and exurban
development has a cost advantage over urban infill development because of low land
costs and subsidized infrastructure. Regulatory reforms alone cannot overcome this
advantage. For decades, governments have charged impact fees on new development
to offset the costs of schools, librartes, sewers, parks, and transportation. Creating and
implementing a regional CO, emissions impact fee would internalize carbon impacts
into development costs, thereby rewarding best development practices and raising
the price of carbon-inefficient development. Fee revenues could be used to help fund
transit, bicycling facilities, sidewalks and other pedestrian amenities, and similar proj-
ects in compact areas.
Local Actions
Change the Development Rules. Local regulations often prohibit the type of
climate-friendly, compact development discussed in this book. Outdated land de-
velopment codes-often from the 1970s or earlier-effectively mandate sprawl by re-
stricting the mix of land uses and requiring large amounts of parking as well as large
minimum building setbacks. Many localities have trted to address these issues on a
development-by-development basis, granting exceptions to the rules through arduous
review and approval processes. Instead, a better approach would be to amend local
policies and regulations-including general plans, zoning and subdivision ordinances,
parking standards, annexation rules, adequate public facilities requirements, and
16 OVERVIEW
design guidelines-to facilitate smart growth through normal approval processes.
They also should consider ways that permitting processes might be accelerated for
compact development projects that meet specified standards.
Channel Growth into Compact Development Areas. With surprising regularity,
MPOs and localities have settled on a common approach to VMT reduction-channeling
growth into dense, walkable areas that can be efficiently served by transtt, and giving
these areas priority for infrastructure funding. This Is the idea behind "smart growth
areas" In the San Diego region, "urban development areas" in Virginia, and "metro-
politan activity centers" in Orlando. Public infrastructure, amenities, and good urban
design will guarantee that such areas are attractive places to live, work, and shop.
Provide for Workforce Housing near Jobs. In most metropolitan areas, the cost of
housing declines with distance from job centers and other desired destinations, while
the cost of transportation increases. With gasoline costs rising, the financial tradeoff
between a longer commute and less-expensive housing is changing, and the potential
savings from living in a convenient location with transportation choices is becoming a
more important aspect of affordability. Locai governments could make the provision of
affordable "workforce" housing a condition of approval for large-scale residential and
commercial developments. In addition, localities could give priority to transit acces-
sibility when allocating housing assistance funds.
The Organization of this Book
Chapter by chapter, this book addresses the impacts of the following:
'" emerging market and policy trends on urban development
II vehicular travel on GHG emissions;
II urban development on vehicular travel;
.. residential preferences on urban development and travel;
" highway building on urban development and travel;
'" urban development on residential energy use;
" the combination of urban development, transtt enhancements, and roadway
pricing on vehicular travel; and, finally
.. policy options to encourage compact development and reduce vehicular travel.
0_Z
m
~
~
~
" ;~ ~~~I
~~?ll.Wi
l~~~ 0
' .,
in
" ~
i~ ~
~ i: i-oI
,"~ ("'l I
" ....
>
t""
N
o
Z
....
Z
~
i
DII~.~ 111111 f III1IJ
"? ~ "e"" ~::::?::
-oo~ ==flt}
~,!!i: ~! "@>: E; ft
~ tI; ~ <>- ::::::::::)d' i
g: ~.~ ? ~ 8. ~
:0 ~ g g... (j 8:
<> "" (Il :I: _ 3 g
f~... [q~
<> ~. Q; g ~ " ~
~e~';' i~e:s'
~ g~. E!i a" t: ""
"'!;l s." '& 0
1 ~ ~ i: a"
~ [ g
c:.. c: ~
i ~ ~
'" ,fg"
Iii
tI om I
~ ~_~~~.~ E
'< 0.'=::'"" ~ 0
i ~~0';;'~'
~ :g,i! -a fr
8: g~. 0 6"
?' so:? 00 ..,.
s:; ~ ~
~ ~-~.g ~
[ g [ ~ Q
, ""
3: o8:~i
ill ~ ~ ~ S'
,.., O! _:::J .
.... .g:~.;..,::;
f~Fg~
~ q e e
t ~t P' ;"
08 .~~E [
g. ~
i ii
n
I
,
('I ("1 ('I 0 ?
=.=::: Z [
:cg;r2.9-
5'~g~~.
::1.1'> eL 0 ~_
<>':i!.n3-
~ ~ 38-
3 '=' 3 (')
~ ~ ~. 3
iIi" ~ !!!. 3
- [ ~.
~
..i
~B
.'
2g~
~ 8: 9-
~ ~ ~.
3 ~
, ~
~. 3-
~8.
~ ir
~. ~.
~~
~. ~
~ ,
c ~
~ [
g Q
~ &
g g
-;N
"OJ 10 is is,
g a:: ~
',:; E. !
1f p..~' >-:l
~ ~ c,l ~
g~ a ~
- a
g; ..
-~
Jefferson County
Port Townsend
~
3:
g" 0
h
~ ~
0
" ....,
a d'
[ .,
.,
r oJ
'"
0 " ~
R ~
~ '"
" "
0
;c "
c "'-
~ g
.~ 5
~
-
~
" '-
~ n "
~ " ;fI
n
"
'" n
~
n g
o'
" n
"'-
e. 0
CJ "
n "
>0 n
~ 0 '<
.~ ;::
N
0
"
East Jefferson County
Vicinity Map
I Iflc!l= 1 Mile
December H. 2009