HomeMy WebLinkAboutGlen Cove Infrastructure Extension_Draft
Prepared For:
Jefferson County, Washington
Prepared By:
SCJ Alliance
8730 Tallon Lane NE, Suite 200
Lacey, WA 98516
360.352.1465
May 2025 DRAFT REPORT
Glen Cove Infrastructure Extension Analysis
Existing Utility Conditions
and Infrastructure
Extension Analysis
DRAFT REPORT
IN PROGRESS
DRAFT
DRAFT
Glen Cove Infrastructure Extension Analysis
Existing Utility Conditions and
Infrastructure Extension Analysis
Project Information
Project:
Glen Cove Infrastructure Extension Analysis
Strategy Development Grant
Prepared for:
Jefferson County Board of Commissioners
Reviewing Agencies
Jurisdictions: Jefferson County, WA
City of Port Townsend, WA
Project Representative
Prepared by: SCJ Alliance
8730 Tallon Lane NE, Suite 200
Lacey, WA 98516
360.352.1465
scjalliance.com
Contact:
Project Reference: SCJ #24-000379
Path: N:\Projects\0726 Jefferson County\24-
000379 Glen Cove Infrastructure Extension
Plan\Civil\Existing Information\2025-0210
Existing Utility Conditions Report.docx
SCJ Alliance 5/12/2025 | Page i
Table of Contents
1 Introduction ............................................................................................................... 1
2 Planning Requirements for Infrasture Expansion Alternatives...................................... 5
2.1 Alternative 1: Extension of Infrastructure to the Glen Cove Area ........................................ 5
2.2 Alternative 2: Expand the Glen Cove LAMIRD ..................................................................... 11
2.3 Alternative 3: Conventional Amendment of the UGA Boundary ....................................... 16
2.4 Alternative 4: UGA Boundary Swap..................................................................................... 20
2.5 Glen Cove Planning Alternative Comparison ...................................................................... 23
2.6 Infrastructure Considerations ............................................................................................. 26
3 Existing Utility Conditions ......................................................................................... 28
3.1 Power................................................................................................................................... 28
3.2 Telecommunications ........................................................................................................... 29
3.3 Natural Gas .......................................................................................................................... 29
3.4 Water ................................................................................................................................... 30
3.5 Sewer ................................................................................................................................... 43
3.6 Stormwater .......................................................................................................................... 50
4 Summary… ...................................................................... Error! Bookmark not defined.
4.1 Level 2 ......................................................................................Error! Bookmark not defined.
5 Next Steps… .................................................................... Error! Bookmark not defined.
5.1 Level 2 ......................................................................................Error! Bookmark not defined.
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List of Figures
Figure 1 Glen Cove Industrial Area LAMIRD Map .................................................................................... 2
Figure 2 UGA Public Map ......................................................................................................................... 3
Figure 3 Study Area Map .......................................................................................................................... 4
Figure 4 Water Study Area Map ............................................................................................................. 30
Figure 5 Key Fire Locations Map ............................................................................................................ 35
List of Tables
Table 1 UGA Alternatives – Key Differences ................................................Error! Bookmark not defined.
List of Appendices
Appendix 1 - Power
Appendix 2 - Telecommunications
Appendix 3 - Natural Gas
Appendix 4 - Water
Appendix 5 - Sewer
Appendix 6 - Stormwater
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1 Introduction
The Clallam County Board of Commissioners, as the Lead Applicant for the North Olympic Peninsula
Recompete Coalition (NOPRC), has authorized the Strategy Development Grant funding for a project
focused on reviewing an extension of the infrastructure to the Glen Cove area located within Jefferson
County, Washington. In 2023, Clallam County received federal funding from the Federal Economic
Development Administration (EDA) under the Distressed Area Recompete Program to conduct a
Strategy Development Grant. Among the initiatives identified through this effort, extending
infrastructure to the Glen Cove area emerged as a critical regional priority to support industrial
development and long-term economic growth.
This report outlines the early phases of the Glen Cove Infrastructure Study. While initial scoping
included consideration of potential Urban Growth Area (UGA) adjustments, the project team has since
pivoted to focus on the extension of infrastructure to the Glen Cove Limited Area of More Intensive
Rural Development (LAMIRD)—without modifying the existing UGA boundary. This approach is
alignment with the interests of the community, and is intended to support existing industrial activity,
improve utility service reliability, and leverage recent state and federal infrastructure investments.
Project Goals:
The primary goal of this project is to strengthen the Glen Cove industrial zone by supporting the
development capacity of existing businesses and enabling future job-generating uses. Glen Cove is one
of the few industrial areas in rural Jefferson County. Its proximity to the City of Port Townsend presents
a unique opportunity to connect to municipal infrastructure—particularly sewer, water, and stormwater
systems—and maximize the return on existing public investments.
Strategic extension of urban-level services will allow the County and City to address health and safety
constraints, improve service delivery, and advance local economic development objectives without
inducing unplanned urban growth. Notably, nearby investments such as the City of Port Townsend’s
Evans Vista Lift Station and a Public Infrastructure Fund (PIF) grant signal strong regional support for
infrastructure readiness in this area.
Project Activities:
The project comprises three primary activities designed to evaluate the infrastructure needs and
potential for expansion of the Glen Cove industrial zone:
1. Analysis of Planning Requirements: A comprehensive review of planning and zoning
frameworks, including the Washington State Growth Management Act (GMA), to determine
how infrastructure expansion or UGA adjustments must align with state and local policies.
2. Stakeholder Engagement: Coordination with local businesses, landowners, public agencies, and
community groups to identify priorities, concerns, and shared goals for the future of Glen Cove..
3. Documentation of County/City Collaboration: This activity will focus on the collaboration
between Jefferson County and the City of Port Townsend. As mandated by the Growth
Management Act (GMA) both agencies are required to complete the Periodic Update of the
Comprehensive Plans and development regulations by December 2025. The collaboration
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between the county and city will play a critical role in planning for future population growth and
addressing the economic development and infrastructure needs of the Glen Cove area.
Planning Context: Glen Cove Industrial Zone
The Glen Cove Industrial Area is designated as a Limited Area of More Intensive Rural Development
(LAMIRD) in the 2018 Jefferson County Comprehensive Plan. (See Figure 1.) The area is zoned for Light
Industrial and Light Industrial/Commercial uses and currently supports a variety of employment-
generating activities. However, gaps in sewer, water, and stormwater infrastructure have limited the
area’s development potential.
Recent actions, including Jefferson County’s 2024 adoption of Ordinance 09-1209-24—which expanded
the Port Townsend UGA by 32.72 acres of public land—demonstrate ongoing regional efforts to revisit
growth boundaries. However, the Glen Cove project is not pursuing UGA expansion at this time; instead,
it emphasizes infrastructure improvements within the LAMIRD boundary. (See Figure 2 for a map of the
recent UGA expansion.)
Figure 1 Glen Cove Industrial Area LAMIRD Map
Source: Jefferson County 2018 Comprehensive Plan
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Figure 2 UGA Expansion Map
The study area (refer to Figure 3 for the study area map) is encompassed by:
• Port Townsend UGA expansion area, and Port Townsend city limits to the north,
• South Jacob Miller Road, Elizabeth Street, Pebble Lane, State Routes 20 and 19 to the west,
• Arrow Lumber and Hardware parcel, Whiskey Road, Old Fort Townsend Road, and parcels along
Fredericks Street, Mill Road to the south, and
• Thomas Street, Port Townsend Paper Company (PTPC) ponds and Port Townsend Bay to the
east.
PTPC, under new ownership, owns a significant amount of land within the north portion of the study
area.
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Figure 3 Study Area Map
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2 Planning Requirements for Infrastructure Expansion
Alternatives
This report evaluates planning options and regulatory considerations for infrastructure improvements in
the Glen Cove area of Jefferson County. Initial discussions focused on potential adjustments to the
Urban Growth Area (UGA), including expansion and boundary swaps. However, in response to feedback
from the community, the preferred approach is to pursue the extension of infrastructure to the Glen
Cove Limited Area of More Intensive Rural Development (LAMIRD). This strategy is intended to address
existing service limitations, support existing development, and avoid inducing urban growth in rural
areas, consistent with the Growth Management Act (GMA).
While the infrastructure extension to the LAMIRD is now the primary focus, the report retains analysis of
other growth-related planning actions for potential future consideration. With the infrastructure
extension included and explained as Option 1, the four alternatives described in this report are as
follows:
1. Extension of infrastructure to the LAMIRD without altering its boundary (preferred approach)
2. An expansion of the existing LAMIRD
3. A conventional amendment of the UGA boundary
4. A UGA swap involving the exchange of areas within and outside the Port Townsend UGA
Each alternative presents different implications for land use, environmental review, infrastructure
funding, and regulatory compliance. The sections that follow provide a detailed assessment of these
alternatives, including planning processes, SEPA considerations, and public engagement requirements.
This information is intended to support a coordinated decision-making process between Jefferson
County and the City of Port Townsend, and to ensure that future growth aligns with community values
and state planning requirements.
The following analysis elevates the infrastructure extension alternative to reflect the current direction of
the community while preserving the broader context of possible long-term options.
2.1 Extension of Infrastructure to the Glen Cove LAMIRD
The alternative being pursued for supporting the Glen Cove industrial area involves the extension of
infrastructure to the existing LAMIRD, without any modification to its established boundary.
Comprehensive Plan amendments may be necessary to support this extension. Unlike a LAMIRD
boundary expansion, which is a GMA action, extending infrastructure is a public facilities and services
decision that must be consistent with GMA, as well as comply with local development regulations. The
GMA generally discourages urban-level infrastructure in rural areas unless it is necessary to support
existing development, or address an environmental public health matter, without inducing urbanization.
Extending infrastructure to the Glen Cove LAMIRD could enhance service delivery while maintaining its
existing boundaries and rural designation. Improved infrastructure—particularly related to water,
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sewer, and stormwater systems—would support the area’s existing Light Industrial and Light
Industrial/Commercial uses, including warehousing, light manufacturing, and software development.
While the area is not intended to be pedestrian-oriented in the urban sense, addressing current
limitations in septic systems, stormwater management, and water availability is critical to ensuring the
safe operation of facilities that handle industrial materials and equipment. Enhancements that improve
internal circulation and mitigate risks—such as those posed by hazardous materials, large vehicle access,
or site-specific pedestrian safety for workers—would strengthen the area's overall functionality. This
targeted infrastructure investment may also offer a cost-effective alternative to expanding the UGA
boundary, particularly when evaluated in terms of job retention, industrial efficiency, and long-term
economic productivity. Comparable models may include other light industrial zones in rural areas that
are characterized by focused, employment-driven activity with minimal residential or commercial foot
traffic.
This approach aligns with Goal LU-G-24 and Policy LU-P-24.2 of Jefferson County’s Comprehensive Plan,
which emphasizes the importance of planning discussions between Jefferson County and the City of Port
Townsend regarding infrastructure at Glen Cove. Potential solutions such as Large On-Site Sewage
Systems (LOSS) or other innovative infrastructure technologies could address septic limitations while
supporting the area’s industrial and commercial activities. Additionally, Policy LU-P-24.3 encourages
integrating renewable energy systems, which could enhance economic resiliency and provide
sustainable energy solutions for local industries. The extension of infrastructure is further supported by
RCW 36.70A.070(5)(d).
2.1.1 Planning Process
Phase 1: Preliminary Research & Justification (6-12 months)
The first phase involves identifying the specific infrastructure needs and ensuring compliance with the
Growth Management Act. This includes determining what services are proposed for extension – such as
water, sewer, roads, or broadband – and assessing whether the extension is intended to support
existing development or could inadvertently enable new urban-style growth. A thorough review of
applicable GMA provisions, particularly RCW 36.70A.110 and 36.70A.070(5), is essential to ensure that
urban services are used solely to address existing public health or safety concerns in rural areas, and not
to induce inappropriate urbanization outside the UGA.
Early and inclusive stakeholder engagement is critical at this stage. Key participants include city and
county officials, Jefferson County PUD, affected property owners, the Department of Health, and the
Department of Ecology (if water or sewer services are involved). The Washington State Department of
Commerce should be engaged early to ensure alignment with GMA requirements and to advise on
potential regulatory or procedural considerations. Additionally, if the project seeks state or federal
funding, early coordination with potential funding partners—such as the Community Economic
Revitalization Board (CERB)—can help shape the scope, funding eligibility, and long-term viability of
infrastructure investments.
As part of the preliminary assessment, this phase will also outline procedural and interjurisdictional
steps necessary to move the project forward, including evaluating the potential need for an Interlocal
Agreement (ILA) between Jefferson County and the City of Port Townsend. Such an agreement would
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be used to define service terms, cost-sharing, and maintenance responsibilities, etc. Items for
consideration when developing an interlocal agreement include the following:
• Identify Infrastructure Need:
o What service is being extended? (e.g., water, sewer, roads, broadband).
o Is it needed to support existing development, or does it enable new development?
• Check GMA Compliance (RCW 36.70A.110 & 36.70A.070(5)):
o Urban services (like sewer) cannot promote new urban-style development outside
UGAs.
o Services should only support existing development or correct public health/safety
issues.
• Engage Key Stakeholders: City officials (utility providers), Jefferson County planning staff,
affected property owners, Department of Health, Department of Ecology (if water/sewer
involved). If state or federal funding is involved, early coordination is needed.
• Determine if an Interlocal Agreement (ILA) is Required:
o Cities providing infrastructure outside their boundaries often require an ILA with the
county.
o ILAs define service terms, cost-sharing, and maintenance responsibilities.
Phase 2: Planning & Environmental Review
Following the completion of preliminary research, the planning and environmental review phase begins.
At this stage, any proposed infrastructure extensions must be incorporated into the City and County
Capital Facilities Plans (CFPs), which may also require amendments to the Comprehensive Plan—
particularly if the extension involves water or sewer services that extend beyond city boundaries.
In addition to CFP consistency, compliance with Jefferson County’s Countywide Planning Policies (CPPs)
is essential. If the CPPs do not explicitly allow for infrastructure extensions to rural areas under the
proposed circumstances, an amendment process may be necessary. Depending on the type of
infrastructure involved, project approvals from the Washington State Department of Ecology or
Department of Health may also be required.
Key Planning Considerations:
• Capital Facilities Planning:
o Ensure the infrastructure extension is included in both the City and County CFPs.
o Amendments to the Comprehensive Plan may be required if extending services beyond
city limits.
• Countywide Planning Policies (CPPs):
o CPPs should provide a framework for infrastructure extension to rural areas under
defined conditions.
o If not, a formal amendment to the CPPs may be needed.
• Regulatory Approvals:
o Projects involving water or sewer infrastructure may require approvals from the
Department of Ecology and/or Department of Health.
• Department of Commerce Review:
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o If updates to the CFP are adopted as part of the Comprehensive Plan, Jefferson County
must provide a minimum 60-day notice to the Washington State Department of
Commerce, as required under RCW 36.70A.106.
Phase 3: State Environmental Policy Act (SEPA) Review
Given that extending infrastructure to the Glen Cove LAMIRD is the preferred alternative, SEPA
compliance will focus on the infrastructure action itself, rather than a broader land use amendment.
Because this is a project-level action, the appropriate environmental review will be conducted under
SEPA as a “project action,” with specific attention to the proposed infrastructure elements and their
locations.
The first step is to prepare a project-level Environmental Checklist, with a high level of detail regarding
the nature and location of infrastructure extensions. This includes identifying impacts related to water
and sewer lines, grading, construction corridors, and utility easements. Specific elements of the
environment likely to be of greatest relevance include:
• Earth (grading, excavation, and soils),
• Water (surface water impacts, stormwater discharge),
• Plants and Animals (critical areas, habitat disruption),
• Environmental Health (especially hazardous materials),
• Land Use Compatibility (industrial context within rural zoning),
• Historic and Cultural Resources (potential excavation impacts),
• Transportation (construction-related traffic and access), and
• Public Services and Utilities (service capacity and service area consistency).
The SEPA Responsible Official will review the Environmental Checklist to issue a threshold
determination. If no significant environmental impacts are identified, the Responsible Official may issue
a Determination of Non-significance (DNS) or, if minor mitigation is required, a Mitigated DNS (MDNS).
Either determination requires a 14-day public comment period and publication in the SEPA Register.
While it is possible for infrastructure extensions to occur without causing significant impacts, this
alternative is the most likely of the four options analyzed to require an EIS. The steps in the EIS process
are:
• Issue a Determination of Significance, which starts the scoping period,
• Conduct a scoping comment period of 21 to 30 days to solicit input from the public, other
agencies, and Tribes on alternatives, elements of the environment to include in the EIS, and
potential mitigation measures,
• Conduct analysis on the affected environment, potential impacts, and mitigation measures,
• Write the Draft EIS,
• Publish the Draft EIS and hold a 30-day (minimum) comment period, which will likely require a
public meeting,
• Revise the EIS, if required based on comments received,
• Respond to all comments in the revised EIS, and
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• Publish the Final EIS.
Action can be taken seven days after the final EIS has been issued. At least 6 to 9 months should be
included in the schedule for an EIS, though they can potentially take longer depending on the details of
the specific action being analyzed.
Note: SEPA analysis for infrastructure extension is distinct from the non-project SEPA review required
for UGA boundary or LAMIRD expansion alternatives. Those actions are reviewed at a programmatic
level and do not substitute for project-level SEPA review, which must occur prior to construction or
permitting of specific infrastructure
Phase 4: Public Review & Hearings
Public participation is a key component of this phase. If the infrastructure extension necessitates
updates to the Comprehensive Plan or Capital Facilities Plan (CFP), public notice and comment periods
are required. In addition, any updates to functional plans—such as utility or transportation plans—may
be needed to ensure consistency across planning documents. For the City of Port Townsend,
infrastructure-related amendments may need to be scheduled as part of the annual Comprehensive
Plan amendment cycle, subject to local docketing procedures.
The County Planning Commission will hold at least one public hearing to review the proposal for
consistency with the GMA, SEPA, and county policies. Following the hearing, the Commission will issue
a recommendation to the Board of County Commissioners (BOCC) for final consideration.
With the City of Port Townsend is the infrastructure provider, its City Council must also approve the
proposed extension. Alternatively, if a special purpose district (such as a water or sewer district) is the
responsible agency, approval must be granted by its Board of Commissioners.
Unlike LAMIRD boundary expansions, which require Growth Management Hearings Board (GMHB)
review, infrastructure extensions projects primarily need utility provider approvals, functional plan
amendments and amendments to capital facility planning documents.
Key steps include:
• Public Notice & Comment Period: If part of a Comprehensive Plan amendment or CFP update,
public notice is required.
• Planning Commission Review: The County Planning Commission holds at least one public
hearing.
o Reviews compliance with GMA, SEPA, and county policies.
o Issues a recommendation to BOCC.
• City Council or Utility District Approval:
o If the infrastructure is provided by Port Townsend, its City Council must approve the
extension.
o If a special district (e.g., a water/sewer district) provides the service, its Board of
Commissioners must authorize the extension.
• Note: While LAMIRD expansions alter zoning boundaries and require a Growth Board review,
infrastructure projects need utility provider approval and Capital Facilities Plan amendments but
may not require Growth Board involvement.
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Phase 5: Board of County Commissioners Review
If the proposed infrastructure extension requires amendments to the Comprehensive Plan, the Capital
Facilities Element, the Capital Improvement Program (CIP), or the Countywide Planning Policies (CPPs),
the Board of County Commissioners (BOCC) will review the proposed changes, hold public hearings, and
vote on whether to adopt, deny, or modify the amendments. These are legislative actions, and BOCC
involvement is limited to plan-level decisions, not project-specific permitting.
In parallel, the owner of the infrastructure—typically the City of Port Townsend or Jefferson County
PUD—must formally approve the extension. Their review ensures alignment with system capacity,
financial planning, and service obligations. If a special purpose district is responsible for providing the
service, its governing board must also authorize the extension through its own approval process.
This phase ensures that both policy-level frameworks and infrastructure provider commitments are
aligned before implementation proceeds.
Phase 6: Final Approvals, Construction, and Appeals
The final phase involves securing all necessary regulatory approvals and preparing for construction. If
the infrastructure extension involves water or sewer systems that impact public health or environmental
standards, approvals may be required from the Washington State Department of Health and/or the
Department of Ecology.
If the infrastructure crosses private property, additional right-of-way acquisition and easement
negotiations may be needed. Before construction can begin, detailed engineering studies and refined
cost estimates must be completed. For grant-funded projects, all associated environmental conditions,
permitting requirements, and contractual obligations must be satisfied.
The process and venue for appeals will vary based on the nature of the action:
• If the project involves legislative actions—such as amending the Comprehensive Plan, Capital
Facilities Plan, or Countywide Planning Policies—any appeal would be directed to the Growth
Management Hearings Board (GMHB), per GMA procedures.
• If the infrastructure extension proceeds as a permit or quasi-judicial decision, appeal procedures
are governed by the Jefferson County Unified Development Code (UDC), Chapter 18.40.330:
o Type I permits may be appealed directly to Superior Court.
o Type II and Type III permits, as well as SEPA determinations, may be appealed to the
County Hearing Examiner.
It is important to identify the applicable permit classification early to determine the appropriate appeal
track. While infrastructure extensions do not typically require state-level approval unless tied to a GMA
plan amendment, they can still be challenged if perceived to induce urban development outside the
UGA.
Timeline/Potential Challenges
The timeline for implementing this alternative can be lengthy, and is dependent on the complexity of
environmental review, permitting, public engagement, and interagency coordination.
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Several challenges may affect the project’s schedule and feasibility:
• Regulatory Compliance: Demonstrating full consistency with the Growth Management Act
(GMA) is critical, particularly ensuring that the infrastructure extension does not induce urban
growth in rural areas.
• Funding Constraints: Securing state or federal grant funding may be difficult due to eligibility
criteria, matching fund requirements, and competitive application processes.
• Stakeholder and Community Buy-In: Gaining support from residents, property owners, and
service providers may be challenging, especially where concerns exist around cost-sharing
agreements, long-term tax implications, or perceived development pressures.
• Environmental Constraints: The presence of critical areas, wetlands, or archaeological resources
may require additional studies, design adjustments, or mitigation measures, increasing both
cost and timeline.
• Legal Risk: Infrastructure extensions may face legal challenges from interest groups or property
owners—particularly if the project is perceived to conflict with GMA provisions or local land use
goals. Such challenges could lead to appeals and delays in implementation.
Careful sequencing of permitting, early stakeholder engagement, and proactive planning will be
essential to managing these risks and maintaining project momentum.
2.2 Alternative 2 : Expand the LAMIRD
With respect to land use zoning, the Glen Cove Light Industrial/Commercial Area is a Limited Area of
More Intensive Rural Development (LAMIRD) in the GMA framework. Expanding the LAMIRD in the Glen
Cove area would involve increasing its boundary to accommodate additional growth. This option must
be carefully evaluated to determine if further expansion aligns with GMA regulations, which typically
limit LAMIRD expansions. According to RCW 36.70A.070(5)(d), expansions must be consistent with the
existing character of development and cannot lead to urban growth patterns inappropriate for rural
areas. WAC 365-196-425(6) provides further guidance, stating that LAMIRD boundaries should be
defined by logical outer boundaries, supported by existing infrastructure, and documented as meeting
the criteria outlined in the GMA. Unlike UGA expansions, LAMIRD expansions cannot be justified by
projected growth but must instead be based on existing development patterns.
2.2.1 Planning Process
Planning steps toward expanding the LAMIRD include defining the new boundaries of the LAMIRD,
conducting a land capacity analysis to justify the need for expansion, considering potential
intensification of uses within the LAMIRD, and updating the Comprehensive Plan land use map to reflect
the updated boundaries. Amendments to the use table in Jefferson County’s Unified Development Code
may be necessary to accommodate new or intensified uses. Public outreach will also be essential to
address community concerns.
Jefferson County’s Comprehensive Plan notes that the Glen Cove Industrial Area’s zoning supports a
wide variety of light industrial and commercial uses, but broader commercial designations are restricted
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to mitigate traffic and safety concerns. Any expansion proposal must carefully navigate these constraints
and ensure alignment with local and regional goals.
Goals LU-G-24 and LU-G-25 of Jefferson County’s Comprehensive Plan provide additional guidance for
LAMIRD expansions. LU-G-24 emphasizes the containment of industrial development within defined
boundaries, allowing limited infill. Policy LU-P-24.2 encourages ongoing planning discussions with the
City of Port Townsend to explore infrastructure solutions that could support Glen Cove’s growth, such as
extension of city sewer and water. These goals reinforce the importance of maintaining consistency with
RCW 36.70A.070(5)(d) while addressing infrastructure needs and supporting economic opportunities.
LU-G-25 highlights the potential to align expansions with natural resource-based industries, ensuring
compatibility with existing resource lands and fostering employment opportunities.
The area’s existing uses (e.g., industrial parks, light manufacturing, and software development) align
well with economic development goals. Expansion could focus on accommodating additional industries
that support local employment while ensuring land use compatibility. Additionally, past challenges
regarding pedestrian safety and hazardous materials suggest that expansion proposals should include
strategies for mitigation.
Phase 1: Preliminary Research & Justification
As with the UGA expansion and most other land use actions, the first step in planning a LAMIRD
expansion is conducting preliminary research to justify the expansion and confirm compliance with GMA
requirements. This involves identifying the rationale for expansion, analyzing the historical built
environment to demonstrate that the area is already intensively developed, and conducting an
environmental constraints analysis to assess potential impacts on wetlands, floodplains, and other
critical areas. LAMIRD expansions must meet strict “infill, development, or redevelopment” criteria and
cannot be based on future growth needs like a UGA.
Early engagement with property owners, community groups, and county planning staff is also essential
to gauge stakeholder concerns and support.
Phase 2: Comprehensive Plan & Zoning Amendment Proposal
The next step in the process involves formally proposing amendments to the Comprehensive Plan and
zoning regulations to reflect the expanded LAMIRD boundary. This begins with submitting a docket
request, as LAMIRD expansions require inclusion in the county’s annual docket for review. County
planning staff must then prepare a report evaluating whether the expansion aligns with GMA
requirements, demonstrating that the area meets the criteria for historic development and does not
encourage urbanization of rural lands. If approved, updates must be made to both the County Zoning
Map and Future Land Use Map to incorporate the expanded boundary. Unlike UGA expansions, which
focus on accommodating projected population and employment growth, LAMIRD expansions must rely
on historical development patterns as their justification.
• Submit Docket Request: LAMIRD expansions require a Comprehensive Plan amendment, which
must be added to the county’s annual docket for review.
• Develop Planning Staff Report: County staff must evaluate whether the request meets GMA
requirements.
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• Zoning & Future Land Use Map Updates: If approved, the County Zoning Map and Future Land
Use Map must be updated to reflect the expanded boundary.
• Note: while UGA expansions focus on providing urban services and accommodating
population/employment growth, LAMIRD expansions must prove historic development and
prevent urbanization of rural lands.
Phase 3: State Environmental Policy Act (SEPA) Review
This section describes the SEPA process and the decisions to be made throughout the process as a
general guide. Note that the specific SEPA strategy and approach chosen should be discussed with legal
counsel for agency-specific guidance.
Under WAC 197-11, the first step of the SEPA process is to prepare an environmental checklist. Because
amending the UGA boundary is a non-project action, Section D of the Checklist (“Supplemental sheet for
non-project actions”) needs to be filled out. Elements of the environment that are most relevant to the
proposed action and therefore may require the most analysis and detail in the Checklist, are land use
and utilities. To the extent possible, the SEPA review should also acknowledge the potential impacts of
actions that would take place pursuant to the UGA Boundary amendment, such as infrastructure
extensions.
The SEPA Responsible Official will review the Checklist and use the information included as the basis for
a threshold determination, which is the formal decision as to whether the project is likely to cause a
significant adverse environmental impact. According to WAC 197-11-794, significant means “a
reasonable likelihood of more than a moderate adverse impact on environmental quality.”
If the determination is that the action would not have a significant impact, then the next step will be to
prepare a Determination of Non-significance (DNS). If the action would have a significant impact but
that impact could be mitigated to the degree that it is not significant, a Mitigated DNS (MDNS) can be
issued. For either a DNS or an MDNS, the document will need to be distributed to interest parties, public
notice will need to be given, and the document will need to be posted to Ecology’s SEPA Register.
Both a DNS and an MDNS require a 14-day comment period. The SEPA Responsible Official will need to
consider all comments made within the comment period and then choose to retain the DNS, issue a
revised DNS (for example, if new mitigation measures need to be applied), or withdraw the DNS and
issue a determination of significance. After the completion of the comment period, if the DNS is
retained, then the action can be taken.
If the threshold determination is that the action would have significant impacts, then a determination of
significance (DS) needs to be issued. If the SEPA Responsible Official determines at the beginning of the
process that the action is likely to have significant impacts, it is possible to skip the preparation of the
Checklist and begin the process with a DS. The DS initiates an Environmental Impact Statement (EIS)
process. An EIS is a longer and more detailed document than a Checklist and it requires consideration of
alternatives. The EIS also has greater requirements for public involvement. The EIS process can take six
to nine months, or longer depending on the complexity of the environmental analysis required.
Phase 4: Public Outreach & Hearings
Public engagement plays a critical role in the LAMIRD expansion process. The county must notify
affected property owners and conduct a public comment period to gather feedback. At least one public
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hearing is held by the Planning Commission to review the proposal, during which stakeholders can voice
their support or concerns. Following the hearing, the Planning Commission makes a recommendation to
the Board of County Commissioners (BOCC). Based on public input and legal review, refinements to the
expansion proposal may be necessary before it moves forward. LAMIRD expansions often face greater
opposition from rural preservation groups, who argue that increased development pressure threatens
rural character and environmental resources. Addressing these concerns through clear justification and
mitigation strategies is essential to moving the proposal forward.
• Public Notification & Comment Period: The county notifies affected property owners and holds a
public comment period.
• County Planning Commission Hearings:
o The Planning Commission holds at least one public hearing to review the proposal.
o It then makes a recommendation to the BOCC.
• Revisions & Refinements: Adjustments based on public input and legal review.
• Note: LAMIRD expansions often face more opposition from rural preservation groups because
they increase development pressure in rural areas.
Phase 5: Board of County Commissioners Consideration and Action
Following completion of the Planning Commission review and public outreach process, the proposal to
expand the LAMIRD advances to the Board of County Commissioners (BOCC) for legislative
consideration. As the final decision-making body, the BOCC conducts at least one public hearing to
evaluate the proposal, drawing from the public record, SEPA documentation, staff recommendations,
and legal and policy analyses developed during prior phases.
In reviewing a LAMIRD expansion, the BOCC must determine whether the proposal is consistent with the
Growth Management Act (GMA)—particularly the requirements in RCW 36.70A.070(5)(d)—as well as
aligned with the Jefferson County Comprehensive Plan and Countywide Planning Policies. Key
considerations include whether the proposed expansion:
• Reflects the existing pattern and scale of rural development as of July 1, 1990,
• Maintains a logical outer boundary,
• Avoids enabling urban-level development or sprawl, and
• Serves a demonstrated rural or natural resource-based economic function.
Based on its findings, the BOCC may vote to approve, modify, or deny the proposed expansion. If
approved, the expansion is adopted by ordinance and supported by formal findings of fact
demonstrating compliance with GMA provisions specific to rural development, as well as local policy
objectives.
Step 6: State Review & Final Approval
Following local adoption, the amendment is submitted to the Washington State Department of
Commerce for a mandatory 60-day review period, during which the state may provide comments or
choose to file an appeal—but does not take formal action to approve or finalize the amendment. If no
appeal is filed by Commerce or any other party, the amendment moves forward for local
implementation.
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A 60-day appeal window also begins following adoption, during which interested parties may challenge
the amendment before the Growth Management Hearings Board (GMHB). While appeals can occur for
any land use change under GMA, LAMIRD expansions are more frequently contested by environmental
advocacy or rural preservation groups, particularly where concerns exist about rural sprawl. If appealed,
the county may be required to defend the amendment through GMHB proceedings, which could lead to
modification or remand. If no appeal is filed, the expanded LAMIRD is officially recognized, and the new
boundaries are incorporated into the county’s zoning and development regulations.
Key Steps Include:
• Washington State Department of Commerce Review (60 days):
o The adopted amendment is submitted to Commerce for review.
o The state may provide comments or file an appeal but does not take action to approve
or deny.
• Appeal Period (60 days after adoption):
o Any party may challenge the amendment before the Growth Management Hearings
Board (GMHB).
o If appealed, the county may need to need to defend or revise the amendment during
the hearing process.
• Final Implementation:
o If no appeal, the expanded LAMIRD is officially recognized in county zoning and
development regulations.
Note: LAMIRD expansions tend to face greater scrutiny from groups concerned with rural sprawl, while
UGA amendments are more often challenged based on growth capacity and infrastructure planning
issues.
Timeline/Potential Challenges
LAMIRD expansions are subject to more stringent constraints under the GMA than UGA expansions, as
they must be justified based on historic patterns of development rather than future growth projections.
The most significant challenge is demonstrating that the area proposed for expansion was physically
developed as of July 1, 1990, as required by RCW 36.70A.070(5)(d). Without sufficient historical
evidence—such as building records, aerial photos, or utility connections—the expansion may not
withstand regulatory or legal scrutiny.
Public opposition is also a recurring challenge, particularly from rural conservation or environmental
groups that argue against development intensification in rural areas. Concerns typically center on
potential environmental degradation, increased traffic, and the risk of incremental urbanization beyond
the original intent of the LAMIRD designation.
Infrastructure availability poses an additional hurdle. While UGAs are expected to be served by
centralized urban services like sewer and water, LAMIRDs must maintain rural-scaled infrastructure. This
creates challenges in areas where existing or expanded industrial activity may require more robust
systems—particularly for wastewater treatment. In these cases, Large On-Site Sewage Systems (LOSS)
may offer a viable solution that preserves rural character while meeting environmental health
standards. Use of a LOSS system generally does not require coordination with the City of Port Townsend,
unless the facility would cross jurisdictional boundaries or affect shared utility systems. Regulatory
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oversight from the Department of Health and/or the Department of Ecology may be required depending
on system design and scale.
Finally, legal challenges are a real possibility. GMA compliance watchdogs frequently scrutinize LAMIRD
expansions for signs of rural sprawl or inadequate justification. If appealed to the Growth Management
Hearings Board (GMHB), the county must be able to clearly demonstrate that the proposed expansion
aligns with statutory criteria and does not establish a precedent for circumventing rural development
protections.
Key Points:
• LAMIRD expansions must be based on pre-1990 development patterns.
• Public and environmental opposition is common.
• LOSS systems may be necessary where enhanced services are needed—but must retain rural
scale.
• Legal appeals to the GMHB are likely if the expansion is not well-supported by data and GMA
policy.
2.3 Alternative 3 : Conventional Amendment of UGA Boundary
While not currently under consideration, an amendment to the Urban Growth Area (UGA) boundary
remains a potential long-term option that could be revisited in the future. Sections 2.3 and 2.4 are
included in this report for informational purposes only, to outline the procedural steps and planning
requirements that would apply if a UGA expansion or boundary swap were to be pursued at a later
date—particularly with support from community members or in response to evolving regional needs.
Expanding a UGA boundary represents a significant undertaking under the Growth Management Act
(GMA) and must be approached with careful analysis of long-term impacts on land use patterns,
infrastructure investment, and the provision of public services. As reinforced in RCW 36.70A.130(3)(a),
counties are required to periodically review not only the boundaries of their designated UGAs, but also
the patterns of development and permitted densities within both incorporated and unincorporated
portions.
Any proposed UGA amendment must also comply with RCW 36.70A.130(2)(b), which requires that
amendments be considered concurrently to evaluate their cumulative impact. Guidance on related
requirements—such as land capacity analysis, urban services availability, and density thresholds—is
outlined in WAC 365-196-310(2)(e) and WAC 365-196-325(1)(b), which jurisdictions must consult during
the review process.
Public engagement is a critical component, ensuring that community concerns and perspectives are
incorporated into the decision-making process. If the amendment is approved, the Comprehensive Plan
and associated development regulations must be updated to reflect the revised boundary.
The planning process typically includes the following phases:
2.3.1 Planning Process
Key planning steps for a conventional UGA amendment are outlined below.
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Phase 1: Preliminary Research & Justification
The process begins with a comprehensive assessment of population forecasts, housing and
employment trends and current land uses to determine whether an expansion of the Urban Growth
Area (UGA) is needed to meet the 20-year planning horizon. The local jurisdiction—Jefferson County
and/or the City of Port Townsend—must demonstrate a clear and data-supported rationale for why
the current UGA boundary is no longer sufficient.
Common justifications for UGA boundary amendment include:
• Population Growth Projections – If updated population forecasts (from the Office of Financial
Management or a jurisdiction’s own study) indicate that the existing UGA cannot accommodate
anticipated growth over the planning horizon (typically 20 years), expansion may be justified.
• Infrastructure Availability – Areas outside the UGA that can feasibly be served by urban
infrastructure (e.g., sewer, water, transportation) and are well-suited for infill or new
development.
• Economic Development Needs – lack of available land to meet commercial or industrial
demand, particularly where expansion supports job creation and employment targets.
• Environmental Health Remediation: The need to address failing septic systems, groundwater
contamination, or other environmental harms through extension of sewer or stormwater
systems may support expansion when linked to existing development or public health risks.
• Existing Urban-Level Development: Areas already characterized by urban growth—through lot
sizes, densities, or infrastructure—may warrant inclusion in the UGA to ensure consistency with
GMA planning principles.
• Annexation Agreements or Interlocal Agreements – Formal agreements between the City and
County that identify future annexation areas, service provision responsibilities, or financial
terms may support UGA expansion. These may take the form of pre-annexation or revenue-
sharing agreements, which often include provisions for delayed annexation, utility rate
surcharges, tax revenue sharing, or infrastructure cost allocations. Such agreements help
clarify governance and service expectations and can mitigate concerns from stakeholders who
are hesitant about annexation..
• Current Economic Assessment: Market analyses that identify gaps in industrial, residential, or
mixed-use capacity that cannot be addressed within the current boundary.
A land capacity analysis is then conducted in accordance with GMA guidance and Commerce’s WAC
standards. This analysis evaluates how much developable land remains within the existing UGA, how it is
used, and whether it can accommodate projected growth through infill or redevelopment.
The preliminary analysis must also address consistency with the Jefferson County Comprehensive Plan,
Countywide Planning Policies (CPPs), and state GMA requirements. Early coordination with
stakeholders—including landowners, service providers, city and county staff—is essential to evaluate
site-specific feasibility and build a foundation for community and interjurisdictional support.
Phase 2: Comprehensive Plan Amendment Proposal
Once the need for expansion is justified and consistency with regulatory requirements is confirmed, a
proposal to amend the Comprehensive Plan is initiated. Urban Growth Area (UGA) expansions require a
formal amendment to the Comprehensive Plan, typically submitted through Jefferson County’s annual
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docket process or as part of a GMA-mandated periodic update. While the Washington State Department
of Commerce has expressed a preference for UGA expansions to occur during periodic updates, there is
no statutory prohibition against considering such amendments at other times.
Planning staff prepare a report outlining the rationale for expansion—drawing from growth forecasts,
infrastructure assessments, and land capacity analysis conducted in Phase 1—and present it for review
by the County Planning Commission. The Planning Commission evaluates the proposal’s consistency
with the Growth Management Act (GMA), the Jefferson County Comprehensive Plan, and Countywide
Planning Policies, and may recommend revisions or move it forward for further consideration.
Phase 3: State Environmental Policy Act (SEPA) Review
As part of the Comprehensive Plan Amendment Proposal, a SEPA review must be conducted to evaluate
the potential environmental impacts of the Urban Growth Area (UBA) boundary amendment. Because
this would be a non-project (or programmatic) action, the review would generally be focused on broad
policy-level impacts rather than site-specific development details.
SEPA considerations for Alternative 3 are the same as for Alternative 2.
Local Practice – SEPA Addendum Process:
In Jefferson County, it is typical to issue a SEPA Addendum in connection with the staff report during the
annual Comprehensive Plan amendment cycle. This approach builds upon existing environmental
documentation—most notably, the 1998 Final Environmental Impact Statement (FEIS) prepared for the
initial GMA Comprehensive Plan adoption.
Glen Cove-Specific Consideration:
In addition to the 1998 FEIS, the Glen Cove–Tri-Area Special Study (circa 1999) included an EIS specific to
the Glen Cove industrial area. If relevant, the County may choose to issue a SEPA Addendum or a
Supplemental EIS (SEIS) to build upon that prior analysis. The decision to issue an Addendum vs. a new
threshold determination would depend on the degree to which new information, impacts, or
alternatives are identified.
Note: Future actions, such as extending infrastructure within the newly expanded UGA, would not be
covered by the non-project SEPA analysis and would require its own project-level SEPA compliance
process if the action is not SEPA-exempt. In the non-project SEPA documentation, information about
future related actions should be described in as much detail as is available.
Phase 4: Public Outreach & Hearings
This phase begins once the proposal is ready for public review. The Jefferson County Planning
Commission typically leads this stage by hosting public meetings and workshops to gather feedback
from residents, stakeholders, and property owners regarding the proposed UGA swap or expansion.
These forums offer important opportunities to address concerns related to land use, environmental
impacts, infrastructure, and community character.
At least one formal public hearing is conducted by the County Planning Commission, which may result in
recommendations for revisions based on community input, environmental analysis, or legal review.
Because UGA modifications carry implications for urban service delivery, the City of Port Townsend’s
Planning Commission and City Council may also participate in the review process. While the County
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controls UGA designation, the City is ultimately responsible for serving the expanded UGA area. As such,
interjurisdictional meetings or joint study sessions are often necessary to:
• Evaluate the feasibility of extending services (e.g., sewer, water, transportation),
• Confirm alignment with the City’s Comprehensive Plan and Capital Facilities Plan,
• Discuss annexation timing, sequencing, or conditions, and
• Build policy alignment between the City and County.
This collaborative approach ensures that UGA decisions are fully informed by both jurisdictions, support
long-term growth management strategies, and reflect shared infrastructure responsibilities
Phase 5: Board of County Commissioners Review
Following completion of the Planning Commission process and public outreach, the proposal advances
to the Board of County Commissioners (BOCC) for final review. As the legislative decision-making body,
the BOCC holds at least one public hearing to consider the proposed amendment, supported by the
public record developed during previous phases.
Based on public testimony, staff recommendations, and policy consistency, the BOCC may choose to
approve, modify, or deny the amendment. If approved, the UGA modification is formally adopted by
ordinance, along with findings of fact that demonstrate consistency with the Growth Management Act,
the Jefferson County Comprehensive Plan, and Countywide Planning Policies.
Phase 6: State Review & Final Approval
Following approval by the Board of County Commissioners (BOCC), Jefferson County must submit the
proposed amendment to the Washington State Department of Commerce for a minimum 60-day review
period prior to formal adoption, as required under RCW 36.70A.106. During this pre-adoption review
period, Commerce may provide advisory comments but does not approve or deny the amendment.
Once the amendment is formally adopted by the County, it is subject to a 60-day appeal period, which
begins upon publication of the notice of adoption in the County’s newspaper of record. During this time,
any party with standing may file a petition for review with the Growth Management Hearings Board
(GMHB).
Note: Under RCW 36.70A.290(2) and related provisions, certain actions—such as UGA boundary
expansions—do not take effect until the 60th day following publication, unless appealed. If an appeal is
filed, the amendment’s effective date may be delayed pending the outcome of GMHB proceedings. If no
appeal is filed, the amendment takes effect and is incorporated into the County’s Comprehensive Plan,
Zoning Code, and Development Regulations.
Timeline/Potential Challenges
The overall timeline for completing a UGA swap depends on the complexity of the land exchange,
coordination between jurisdictions, and level of public interest or opposition. While the procedural
steps mirror those of a conventional UGA expansion, several unique challenges may arise:
• Landowner Resistance in Removal Areas: Property owners proposed for removal from the UGA
may express concerns about reduced development potential, property devaluation, or loss of
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planned infrastructure access. These concerns can lead to public opposition and require clear
justification and outreach to address.
• Coordination of Deannexation or Service Withdrawals: If removal involves land within City
limits, a deannexation petition may be required, which can add time and legal complexity.
• Demonstrating Capacity Neutrality: The County and City must demonstrate that the land added
is of equal or greater urban suitability than the land removed. This requires detailed land
capacity and infrastructure analysis and can invite additional scrutiny from Commerce or
watchdog groups.
• Interjurisdictional Negotiations: Crafting or updating interlocal agreements, revenue-sharing
provisions, or pre-annexation terms may require extended negotiation between Jefferson
County and City of Port Townsend, particularly around service responsibilities and cost
allocation.
• Legal Appeals: As with any GMA action, UGA swaps are subject to a 60-day appeal period. If
challenged before the Growth Management Hearings Board, the process may be extended by 6
to 12 months or more, depending on case complexity.
2.4 Alternative 4: UGA Boundary Swap
The fourth alternative - not currently under consideration, but which has been provided for
informational purposes - is a UGA boundary swap. This approach involves removing one area from the
existing Urban Growth Area (UGA) while designating another area for inclusion, thereby maintaining the
overall size and population capacity of the UGA. A boundary swap may be used to better align the UGA
with infrastructure availability, environmental constraints, or long-term development goals, without
increasing the total urban growth footprint.
Although the legislative process for a boundary swap generally follows the same procedural steps as a
standard UGA amendment (e.g., Comprehensive Plan update, SEPA review, public hearings), the
substantive requirements differ. Unlike a conventional UGA expansion, a swap does not require a
demonstration of additional population or employment capacity needs. Instead, the County and City
must show that the land proposed for addition is of equal or greater suitability for accommodating
planned urban development than the land being removed. This includes consideration of factors such as
infrastructure feasibility, land constraints, development readiness, and alignment with adopted planning
policies.
2.4.1 Planning Process
Below is a step-by-step breakdown with a rough timeline and key differences from a standard UGA
expansion.
Phase 1: Preliminary Research & Justification
As with a standard UGA amendment, the boundary swap process begins by identifying the rationale for
exchanging areas within and outside of the Urban Growth Area (UGA). Swaps are typically considered to
better align urban growth with infrastructure capacity, long-range planning goals, or environmental
constraints—without increasing the total UGA acreage.
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A key procedural distinction from conventional UGA expansion is that swaps involve both removal and
addition of land. To initiate the process, particularly when removal involves land within city limits, a
deannexation petition may be required from affected property owners. For designated farmland or
resource land, this deannexation can occur without a public vote, per state law. Such a petition would
typically trigger the initiation of the County's annual Comprehensive Plan amendment docket.
Early in the process, the County and City should evaluate whether Interlocal Agreements (ILAs) or
annexation-related agreements are needed to coordinate roles, responsibilities, and long-term service
expectations. For areas proposed to be removed from the UGA or deannexed, agreements may outline
how the transition will be managed, including the withdrawal of urban services. For areas proposed to
be added, agreements may establish expectations for infrastructure extension, revenue sharing, and
annexation timing or conditions. These agreements help prevent service gaps, clarify cost allocation, and
ensure compliance with Growth Management Act (GMA) objectives.
Once potential areas for removal and addition are identified, a land capacity analysis must be conducted
to confirm that the exchange maintains adequate residential, employment, and infrastructure capacity
to meet growth targets. This growth-neutral approach distinguishes a swap from expansion, as no net
increase in capacity is anticipated.
Justification must be provided for the land that would be added to the UGA as part of the swap as well
as the land that would be removed. Under the GMA0F
1, a county must demonstrate that the land no
longer meets the criteria for inclusion in the UGA. Justifications for UGA removal may include:
• Farmland or Resource Land Protection: If land meets the criteria for agricultural, forest, or
mineral resource lands (RCW 36.70A.170) and the county determines it should be preserved for
these purposes, it can be removed from the UGA.
• Landowner Consensus: A group of property owners can petition the county to be removed
from the UGA, typically if they can demonstrate that urban services are not needed nor
feasible.
• Growth Capacity Analysis: Excess developable land identified in a Buildable Lands Report (RCW
36.70A.215) may justify downsizing.
• Inability to Provide Urban Services: If a city or county determines that urban services (sewer,
water, roads, etc.) cannot be extended cost-effectively, land can be removed.
• Environmental Constraints: Critical areas (e.g., wetlands, steep slopes) limiting urban
development potential may justify removal.
• Existing or Updated Interlocal Agreement: Agreements may support realignment of the UGA
boundary to reflect service capacity or jurisdictional changes.
The proposal must then be evaluated for consistency with the Jefferson County Comprehensive Plan,
Countywide Planning Policies, and GMA requirements. Early engagement with affected landowners,
local jurisdictions, and the general public is essential to refine the proposal and address potential
concerns.
1 RCW 36.70A.110 and .130
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A critical distinction between a swap and a conventional expansion is that a swap requires the County
and City to demonstrate that the land being added is of equal or greater suitability for accommodating
planned urban development than the land being removed—preserving long-term urban capacity while
avoiding sprawl.
Phase 2: Comprehensive Plan Amendment Proposal
The Comprehensive Plan amendment process for Alternative 4 is the same as for Alternative 3.
Phase 3: State Environmental Policy Act (SEPA) Review
SEPA considerations for Alternative 4 are the same as for Alternative 3.
Phase 4: Public Outreach & Hearings
This step closely mirrors the Public Outreach and Hearings process used for conventional UGA
amendment, as outline in Alternative 2.3 above. However, UGA swaps introduce unique sensitivities,
particularly for property owners in the removal area, who may be concerned about reduced
development potential or property value impacts.
To navigate these dynamics, transparent communication and early engagement are essential—
especially to explain the rationale for the swap, the criteria for land suitability, and the implications for
urban services and future development rights. The County Planning Commission leads this phase by
hosting public meetings and at least one formal hearing, with opportunities for both oral and written
testimony.
Coordinated messaging between the County and City of Port Townsend is especially important to
reinforce a shared vision and build public trust in the process.
Phase 5: Board of County Commissioners Review
The BOCC review process for Alternative 4 is the same as for Alternative 3.
Phase 6: State Review & Final Approval
As with Alternative 3, following approval by the Board of County Commissioners (BOCC), Jefferson
County must submit the proposed UGA boundary swap to the Washington State Department of
Commerce for a minimum 60-day review period prior to formal adoption, in accordance with RCW
36.70A.106. During this review period, Commerce may issue advisory comments regarding GMA
consistency but does not approve or deny the amendment.
Once the swap is formally adopted by the County, it is subject to a 60-day appeal period, which begins
upon publication of the notice of adoption in the County’s newspaper of record. During this time, any
party with standing—including property owners, environmental groups, or other stakeholders—may file
a petition for review with the Growth Management Hearings Board (GMHB).
Note: Under RCW 36.70A.290(2) and related provisions, UGA amendments—including swaps—do not
take effect until the 60th day following publication, unless appealed. If an appeal is filed, the
amendment’s effective date may be delayed pending the outcome of GMHB proceedings.
Although a UGA swap does not increase overall urban capacity, it often invites additional scrutiny due to
its dual action of adding and removing land. The County must demonstrate that the swap:
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• Maintains overall UGA acreage and growth capacity,
• Aligns with regional planning goals, and
• Does not encourage urban sprawl or disproportionately benefit specific landowners.
If no appeal is filed, the UGA swap becomes effective on the 61st day following adoption and is formally
incorporated into the County’s Comprehensive Plan and Zoning Code.
Timeline/Potential Challenges
The total timeline for completing a UGA boundary swap depends on project complexity, public
response, and legal review. While the procedural steps largely mirror those of a conventional UGA
amendment, swaps introduce several additional challenges that can impact the schedule and outcome:
• Landowner Resistance and Equity Concerns: Property owners proposed for removal from the
UGA may oppose the change due to concerns about reduced development potential, property
value impacts, or loss of access to future infrastructure improvements. These concerns can
generate political and legal pressure, requiring proactive outreach, detailed justification, and
sometimes compensation mechanisms.
• Deannexation Logistics: If land within City limits is proposed for removal, a deannexation
petition must be filed by affected property owners. This procedural step can add time, legal
complexity, and coordination challenges between jurisdictions.
• Land Suitability and Capacity Neutrality: Demonstrating that the land added to the UGA is of
equal or greater urban suitability than the land removed is a core requirement of a valid swap.
This includes conducting a detailed land capacity and infrastructure feasibility analysis, and it
may invite heightened scrutiny from Commerce, regional planning organizations, or watchdog
groups.
• Public Perception and Legal Risk: Because swaps change both the geography and potential
value of affected properties, they can be perceived as favoring or disadvantaging specific
stakeholders. This increases the risk of public controversy or appeal to the Growth Management
Hearings Board, particularly if the rationale for inclusion/removal is not clearly articulated.
• Interjurisdictional Coordination: As with other UGA changes, boundary swaps require
alignment between Jefferson County and the City of Port Townsend on land use goals,
infrastructure responsibilities, and future annexation potential. Crafting or updating interlocal
agreements, service extension terms, and revenue-sharing provisions may involve complex
negotiations.
• Environmental Review and Constraints: If the land proposed for addition has critical areas,
steep slopes, or other environmental constraints, the County may face barriers under SEPA or
public opposition due to perceived environmental risks or development pressure.
• Appeal Delays: After adoption, the 60-day appeal period provides an opportunity for affected
parties to challenge the amendment. If appealed, resolution through the GMHB may take an
additional 6 to 12 months, delaying implementation.
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While a swap offers a growth-neutral planning option, it requires careful justification, robust public
engagement, and interagency cooperation to succeed. Strategic communication and legal defensibility
will be critical to navigating potential barriers and preserving regional growth integrity.
2.5 Glen Cove Planning Alternatives Comparison
A summary comparison of the four alternatives outlined in the previous sections is provided in Table 1.
Table 1 UGA Alternatives – Key Differences at a Glance
Criteria Infrastructure
Extension to
LAMIRD
LAMIRD
Expansion
UGA Amendment
(Expansion)
UGA Swap
(Boundary
Adjustment)
Description Extend urban
services (e.g.,
water, sewer,
broadband) to an
existing LAMIRD
without changing
its boundary.
Expand the
LAMIRD
boundary to
allow additional
development in
historically
developed rural
areas.
Expand the UGA
boundary to
accommodate
additional urban
growth.
Reallocate existing
UGA area by
removing and
adding land of
comparable
development
suitability.
Justification
Needs
Must
demonstrate that
service extension
addresses existing
development or
public
health/safety—
not intended to
support new
urban
development.
Must prove that
development
existed as of July
1, 1990; cannot
be based on
projected
growth.
Must
demonstrate
growth-related
need
(population,
housing, or
employment),
land capacity
shortfall, and
infrastructure
feasibility.
Must maintain
total UGA acreage
and show that
added area is at
least as suitable for
planned urban
development as
the area removed.
Legal Basis RCW 36.70A.110
(urban services
limited in rural
areas).
RCW
36.70A.070(5)(d)
and WAC 365-
196-425 (rural
development
standards).
RCW 36.70A.110
and RCW
36.70A.130 (UGA
designation and
amendment
criteria).
Same statutory
basis as expansion;
must follow
concurrency and
capacity neutrality
principles.
GMA
Compliance
Focus
Urban services
may be extended
to correct
deficiencies but
must not induce
new urban
development
outside UGA
boundaries.
Must maintain
rural scale and
character; cannot
increase allowed
densities or
induce urban
patterns.
Must justify need
based on 20-year
growth forecasts
and land capacity
analysis.
Must ensure no net
increase in total
UGA capacity;
justification
focuses on spatial
efficiency, not
growth need.
Approval
Process
• Capital Facilities
Plan (CFP) update
• Comprehensive
Plan amendment
• Comprehensive
Plan amendment
• Comprehensive
Plan amendment
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• Interlocal
Agreement (if
services are
provided by City)
• SEPA review
• County/utility
provider approval
• Possible
DOH/DOE review
(for sewer/water)
• SEPA review
• Planning
Commission and
BOCC review and
adoption
• Commerce 60-
day pre-adoption
review
• 60-day appeal
period
• SEPA review
• Planning
Commission and
BOCC review and
adoption
• Commerce 60-
day pre-adoption
review
• 60-day appeal
period (RCW
36.70A.290)
• SEPA review
• Planning
Commission and
BOCC review and
adoption
• Commerce 60-
day pre-adoption
review
• 60-day appeal
period
State Agency
Involvement
Department of
Health and/or
Department of
Ecology for utility
approvals;
WSDOT if road
network impacts;
Commerce for
related plan
updates.
Department of
Commerce (GMA
consistency),
Department of
Ecology (SEPA),
Growth
Management
Hearings Board
(if appealed).
Department of
Commerce (GMA
consistency),
Department of
Ecology (SEPA),
Growth
Management
Hearings Board
(if appealed).
Same as UGA
amendment.
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2.6 Infrastructure Considerations
Section 3.0 of this report provides detailed information about the existing utilities within the study area.
Existing infrastructure is generally limited in the study area and supports the existing development. For
sewer and water, individual septic systems and wells are common for existing development. To allow for
anticipated growth in the study area, infrastructure capacity will need to be increased to meet
developer requirements and meet regulatory requirements such as fire flow. In general, it appears that
the surrounding area currently has utilities that can be extended into the study area to allow for future
growth. For example, water and sewer from the City of Port Townsend will need to be extended south
into study area, and the use of septic systems and private wells will decrease with growth.
Each of the alternatives presented above has a different potential “boundary” associated with it. After
reviewing these boundaries relative to utility purveyors, it was noted that the specific purveyors
involved would likely be the same no matter which alternative was selected. Furthermore, the general
process for extending utilities into the resulting growth areas would be the same regardless of the
alternative. Therefore, this report considered the largest “potential” boundary when looking at the
existing utility infrastructure.
Power is available in and around the study area including single- and three-phase. There is a significant
utility easement for power transmission that runs generally north/south through the study area. This
easement includes other utilities and the capacity to add additional utilities to this easement is
potentially limited. Once the final boundary is established and the specific nature of future development
(future loads, etc.) is determined, additional coordination and planning with the purveyor will be
needed.
The study area has potential access to three different telecommunication purveyors in the area. Once
the final boundary is established, additional coordination and planning with each purveyor will be
needed.
For water service, the study area falls within the City of Port Townsend water service area. Therefore, no
changes to the water service area will be required. The City’s Water System Plan also includes discussion
about extending the water system into the study area and highlights some of the improvements
needed. Fire protection is noted as an area of particular concern in the study area. Once the final
boundary is established and the specific nature of future development is determined, an update to the
Water System Plan may be needed.
Sewer service for the study area would be provided by the City of Port Townsend. The City has
designated the Glen Cove area for possible inclusion in the City’s wastewater service area. The 2024 City
of Port Townsend General Sewer Plan (GSP) discusses this potential in more detail. The City’s sewer
service area and GSP will likely need to be updated once the final boundary is established and the
specific nature of future development is determined.
Stormwater will likely be handled on a project-by-project basis. However, a regional stormwater facility
could potentially be provided to help streamline the development process within the study area and
even provide recreational opportunities, such as parks or walking trails. However, regional stormwater
facilities increase the initial capital investment by the jurisdiction and put more of the operation and
maintenance burden on the jurisdiction.
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Transportation impacts must also be analyzed, and collaborations with relevant agencies are needed to
implement improvements.
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3 Existing Utility Conditions
Availability of existing utility services in and around the study area is described in the following
subsections. The information is based on information provided by each of the utility purveyors. Some of
the information received may not reflect the exact current condition if upgrades or modifications have
been completed and are not yet incorporated into the documents we received. Field verification of this
information was not conducted.
3.1 Power
Power for the study area is provided by Jefferson County Public Utility District (JPUD) No. 1. The
following is a summary of the information received from JPUD:
• Existing transmission lines are utilized in the study area: starting in the City of Port Townsend to
the north, located along Thomas Street and Mill Road, then continuing south in a utility corridor
located east of and parallel to North Otto Street, parallel to State Route 20, and crossing State
Route 19 while continuing to the south.
• Existing three phase primary overhead and underground lines are located within the utility
corridor and throughout the Glen Cove Industrial Park area: along Denny Avenue, Glen Cove
Road, North Otto Street, Otto Street, Fredericks Street, Bayview Street, Seton Road, and State
Route 19.
• Existing single phase primary overhead and underground lines are located within the utility
corridor: along Mill Road, Glen Cove Road, Carroll Avenue, South 8th Street, South 6th Street,
North Otto Street, Otto Street, Fredericks Street, Bayview Street, Seton Road, Old Fort
Townsend Road, and State Route 20. Existing single phase secondary overhead and
underground lines extend beyond these rights-of-way into private properties.
• Existing 2/3 phase primary overhead lines are found in two locations within the study area:
along Thomas Street and Julian Street.
• Available voltages:
o Transmission: 115 kV
o Distribution: 7.2/12.47Y kV
o Three Phase: 120/208Y V, 277/480Y V
o Single Phase: 120/240V
• JPUD has proposed a new Port Townsend substation to be located within the study area.
Discussions between JPUD and Jefferson County are underway for property paralleling the utility
corridor to resolve right-of-way issues (some land is owned by PTPC; some is right-of-way). JPUD does
not know if there is physical capacity to add more utilities to the utility corridor or if there are
restrictions around the utility corridor easement.
Refer to Appendix A-1 for power maps and associated power information.
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3.2 Telecommunications
Telecommunications in the study area is provided by JPUD, Astound Business Solutions, and
Lumen/Century Link.
The following is a summary of the information received from JPUD:
• GIS shows existing fiber systems (overhead and underground) utilized throughout the study
area.
• Port Townsend Business District (within the study area): located along Mill Road, Thomas Street,
South 8th Street, Glen Cove Road, North Otto Street, Otto Street, Seton Road, the west end of
Old Fort Townsend Road, State Route 20, and State Route 19.
• Jefferson North District (south of the study area): located along State Route 20 and State Route
19.
The following is a summary of the information received from Astound Business Solutions:
• Existing fiber systems are utilized throughout the study area: starting in the City of Port
Townsend to the north, then continue south in a utility corridor located east of and parallel to
North Otto Street.
• Existing coax systems are utilized throughout the study area: starting in the City of Port
Townsend to the north, Glen Cove Road, in a utility corridor located east of and parallel to North
Otto Street, and in the Glen Cove Industrial Park area.
The following is a summary of the information received from Lumen/Century Link:
• Existing fiber systems are utilized throughout the study area: located crossing the Larry Scott
Trail, along Frederick Street, Otto Street, Seton Road, State Route 20, and State Route 19.
• Existing coax systems are utilized throughout the study area: located along Thomas Street, Mill
Road, South 8th Street, Glen Cove Road, Carroll Avenue, South 6th Street, Frederick Street,
North Otto Street, Otto Street, Seton Road, Old Fort Townsend Road, State Route 20, and State
Route 19.
Refer to Appendix A-2 for telecommunication maps.
3.3 Natural Gas
Per discussions with Jefferson County, no gas services are available in the study or surrounding areas.
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3.4 Water
Water in the study area is provided by private wells and the City of Port Townsend; refer to Figure 4
below for a water study area map. The southern portion of the study area is located in a future water
service area of JPUD.
Figure 4 Water Study Area Map
According to Jefferson County, there are 6 existing private wells in the study area, most located near the
intersection of Glen Cove Road and South 8th Street. It is our understanding that these wells are not
associated with any of the water purveyors.
The following is a summary of the information received from the 2019 City of Port Townsend Water
System Plan Update:
• The study area is located within the City of Port Townsend Water Retail Service Area designated
as High Zone:
o An existing 30-inch diameter Olympic Gravity Water System (OGWS) Pipeline parallels State
Route 20 to the east in a utility corridor. The OGWS pipeline is capable of transporting
approximately 20 million gallons per day (MGD) of raw water to the City’s Water Treatment
Facility (WTF) and the PTPC.
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o The City owns the 30-inch diameter OGWS pipeline and has an easement for the pipeline
but doesn’t have a right-of-way for access. As noted in the Power section above: discussions
between JPUD and Jefferson County are underway for property paralleling the utility
corridor to resolve right-of-way issues (some land is owned by PTPC, some is right-of-way).
JPUD does not know if there is physical capacity to add more utilities to the utility corridor
or if there are restrictions around the utility corridor easement.
o An existing raw water metered connection off of the 30 inch OGWS pipeline provides raw
water to the PTPC for industrial purposes.. The raw water metered connection provides the
PTPC with up to 11 MGD average day annual consumption In the event of a water shortage,
the City has first priority for the available water and the PTPC must cut production or
conserve water to deliver the contracted volumes of water to the City. The City’s current
peak draw on raw water is approximately 2 MGD during the summer peaks. The PTPC also
has a domestic water service from the City via a meter on Thomas Street.
o Raw water may be available for future business subject to City and PTPC approval and as a
result of conservation measures by the City and PTPC.
o Existing 10” water main comes from the City of Port Townsend: along Discovery Road at the
southern City boundary, along South 2nd Street, Boren Avenue, Railroad Avenue, North
Otto Street, Frederick Street, Otto Street, Seton Road, and State Route 20. Existing 8” and 4”
water pipes connect to the 10” at various locations in the study area.
o Existing hydrants are present throughout the study area. Majority of existing hydrants are
orange with fire flow of 500-999 gpm.
o Fire Flow: Simulation shows that the extreme south end (south end of Glen Cove) is
substantially deficient with respect to available fire flow (AFF), which is below required fire
flow (RFF). In fact, the area within Glen Cove south of Seton Road contains the highest
service elevation within the distribution system (Elevation 281 ft) and was found to have a
tendency to unduly restrict AFF throughout the southern portion of the distribution system.
The City Water System plan has a goal of 2,000 gpm identified for Glen Cove light industrial
area. This may need to be increased given light industry typically requires higher fire flows.
o Future Conditions: The existing system, without expansion of the High Zone, was modeled
under future (2026 and 2036) peak hour demand (PHD) conditions. There are projected to
be no distribution system service pressures less than 30 psi within the 20-year planning
horizon, Under future (2026 and 2036) PHD conditions, no pipe velocities in the model
exceed 8 fps.
o The following excerpts from the 2019 City of Port Townsend Water System Plan Update
show the metrics used in the demand forecast:
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• Summary of System Needs and Concerns:
o Water rights are sufficient to meet instantaneous and annual demands within the 20-year
planning period. The City has a pending water right application for an additional 150 gpm
instantaneous withdrawal at the Port Townsend Golf Course, exclusively for irrigation
purposes. This water right, if approved, will further benefit the City by reducing the quantity
of water currently treated and used to irrigate the golf course, which is the City’s largest
user of water for irrigation.
o Sources are able to meet demands throughout the planning period.
o Storage facilities are able to meet storage requirements throughout the planning period.
o No control system or generator deficiencies have been identified.
o A booster pump station deficiency has been identified in the study area:
BP-02 – South Glen Cove Booster Station (Cost: $200,000): In order to improve available
fire flow by preventing system pressures in at the far south end of Glen Cove from
dropping below 20 psi in the event of a fire elsewhere in the water service area, the City
could install a small pump station in the vicinity of Seton Road and Otto Street to boost
system pressures in this vicinity. This pump station should include a fire bypass to be
used in the event of a fire in this area.
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o Replacing the 30-inch raw water transmission main constructed in 1928 between City Lake
and the Port Townsend City limits is proposed (all sections are planned to be replaced within
the next 20-years):
T-01 – (Cost: $23,512,908): replace approximately 30,100 lineal feet of 30-inch water
transmission main (Section S).
o Distribution system piping is insufficient throughout the planning period: twenty-one
different pipeline improvement projects totaling approximately 41,000 LF of new pipeline
ranging in size from 8 to 16 inches are proposed in order to improve available fire flow
throughout the system and replace aging and/or undersized AC pipe. Capital improvement
distribution system projects are proposed within the study area accordingly:
Figure 5 Key Fire Locations Map
D-06 - Glen Cove (3,740 LF 16-Inch Pipe) (Cost: $1,123,000): This improvement targets
Key Fire Flow Locations 5 and 20; refer to Figure 5 for key fire locations map. It
provides an additional source of supply to Glen Cove. It would improve system
redundancy, circulation, and available fire flow to the Glen Cove area. It is comprised of
new 16-inch pipeline connecting to the existing 16-inch pipeline on the distribution
system side of the old City Valve Shack just north of the southern City limit (at the
south extension of Howard Street), extending southwest along the existing OGWS
pipeline corridor to its intersection with Glen Cove Road, and extending west along
Glen Cove Road to north Otto Street.
D-21 - Southwest Improvements (4,970 LF 8-Inch Pipe) (Cost: $1,246,000): This project
targets Key Fire Flow Locations 5 and 20 (refer to Figure 5 for key fire locations map),
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though with less effect than improvement D-6. It would provide service to a currently
undeveloped area outside city limits along South Jacob Miller Road, as well as
improving available fire flow and providing a redundant source of supply to the Glen
Cove area. It should be considered if a significant amount of higher-density
development occurs along South Jacob Miller Road.
The following is a summary of the information received from JPUD:
• The future JPUD water system located in the southern portion of the study area is called the
Quimper Water Service Area. Existing water information for the Quimper Water Service Area
provided by JPUD includes:
o GIS shows Quimper Water Service Area (Group A) existing water pipes along Parkridge Drive
and south of Fort Townsend Historical State Park in the Kala Point neighborhood.
o GIS shows existing pipes as: 8” C900, 8” PVC, 6” PVC (some looped), 4” PVC, and 2” PVC.
o GIS shows existing hydrants present throughout the water system. Majority of existing
hydrants are orange with fire flow of 500-999 gallons per minute (gpm). There is one green
existing hydrant with fire flow of 1000-1499 gpm.
• JPUD treats nearly all their groundwater wells for iron and manganese (common minerals in
groundwater sources in this area) via a combined chemical cation exchange and mechanical
process that requires very little chemicals (called ATEC). JPUD also uses chlorine in most of their
systems to adequately disinfect the water; chlorine also aids in the removal of iron and
manganese. JPUD does not treat for arsenic, but there are traces of naturally occurring arsenic
in almost all local waters. In January 2001, the Environmental Protection Agency (EPA, Drinking
Water Regulations: https://www.epa.gov/dwreginfo/drinking-water-regulations) lowered the
maximum contaminant limit of arsenic to 0.01 mg/l or 10 ppb. Under the Clean Drinking Water
Act, JPUD is required to test on a regular schedule for certain potential contaminants. The water
quality test results performed for compliance with state and federal regulations are posted on
the WA State Department of Health’s Sentry Internet Database. Samples, from sources located
within the study area, that tested over the maximum contaminant level are as follows:
o Source 5: Quimper: Port Hadlock/Irondale/Chimacum: iron, manganese, lead, sodium.
o Source 6: Quimper: Port Hadlock/Irondale/Marrowstone Island/Oak Bay/Eagle Ridge: iron,
manganese, sodium, arsenic.
o Source 10: Quimper: Airport: iron, manganese, lead, sodium, arsenic.
o Source 11: Quimper: Woodland Hills: iron, manganese, sodium, arsenic, mercury.
o Source 12: Quimper: Eagle Ridge: iron, manganese.
o Source 18: Quimper: Kala Point: iron, manganese, lead, sodium, arsenic, mercury.
o Source 19: Quimper: Kala Point: iron, manganese, lead, sodium, mercury.
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The JPUD 2021 Water System Plan Update (WSPU) was reviewed and the following items from the
Capacity Analysis Summary within the Quimper Water Service Area were noted:
• The following excerpts from the 2021 JPUD WSPU show the metrics used in the Quimper
demand forecast:
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• Quimper holds Department of Ecology certified water rights to annually withdraw 1.727.2 acre-
feet of groundwater per year, with a maximum instantaneous withdrawal of 3,158 gpm. The
Department of Health Water Rights Self-Assessment Form is presented in Table 5-11, which
indicates that water rights are sufficient to meet instantaneous and annual demands within the
20 year planning period.
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• Sources are able to meet demands throughout the planning period, except for the Ocean Grove
Booster Pump Station (BPS) fire flow deficiency which can be resolved by adding additional
larger sized duty pumps or a dedicated fire pump to meet maximum day demand (MDD) plus
fire flow. A fire pump was scheduled to be added to the Ocean Grove BPS within the Quimper
water service area in 2024:
o R-P-1 – Addition of fire pump to Ocean Grove BPS, $95,000
• Storage facilities are able to meet storage requirements throughout the planning period.
• Distribution system piping is insufficient throughout the planning period: several minor fire flow
deficiencies across the system are related to pipe sizing and insufficient pressure through
storage and booster stations. Capital improvement projects are proposed accordingly:
o R-S-1 – New Glen Cove Storage Tank, 2028-2029, $4,650,000
o R-D-4 – Upsizing 8” to 12” (3,700 linear feet (LF)) to support higher flows from new Glen
Cove Storage Tank.
Jefferson County’s Coordinated Water System Plan (CWSP) was prepared in 1997; the County closed a
request for proposal on 11/7/24 for a 2025 coordinated water system plan update, which has not yet
been completed. The study area encompasses portions of JPUD, City of Port Townsend, and Kala Point
existing water systems. Per the 1997 CWSP:
• Expansion of the UGA into Glen Cove is addressed in the CWSP and is included in Jefferson
County Planning Area No. 2: Quimper. The Quimper area’s water systems have the capacity and
water rights to serve only about 75 percent of the anticipated population increase. Without new
water rights and capacity, 25 percent of the projected new growth will occur on small public
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systems or private individual wells. The JPUD has water rights that can mitigate some projected
deficiencies.
• The City of Port Townsend is included in Jefferson County Planning Area No. 1. The City receives
water from the Big Quilcene and Little Quilcene Rivers through a 30-inch diameter raw water
OGWS transmission main. The Little Quilcene River is used as an emergency or supplemental
water source. This system provides water to the City, PTPC, and to some areas adjacent to the
City.
o The City has substantial water rights and acts as a water “wholesaler” by contracting to
supply water to other entities. The following is a summary of the City’s water rights:
30.0 cfs (19.39 MGD) from the Big Quilcene River (perfected, primary water right)
9.56 cfs (6.18 MGD) from the Little Quilcene River (perfected, low flow restricted,
seasonally restricted, water right)
50.0 cfs (32.32 MGD) from the Dosewallips River (application only, not a perfected
water right)
5.46 cfs (3.53 MGD) from the Chimacum Valley in the form of groundwater (perfected
water rights).
The combined surface water rights equal 25.57 MGD and groundwater rights equal 3.53
MGD for a total of 29.1 MGD. Supply to the City and PTPC is restricted by the existing
pipeline capacity (19.4 MGD). The available average supply is a combination of the pipeline
capacity (19.4 MGD) and Chimacum Valley groundwater pumping and treatment capacity
(0.900 MGD) for a total of 20.3 MGD.
The City is under contract to supply 14.9 MGD of its water as follows:
The City has a surface water withdrawal right of up to 25.57 MGD; however, pipeline
capacity is limited to 19.4 MGD.
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o Key issues which potentially affect water supply for the City are those relating to instream
flows in the Quilcene River System and the contract with PTPC. Optimistically, the City will
continue to work with PTPC to achieve a reduction in water demand for the facility and
renegotiate a contract to “free” some of the supply; the mill has demonstrated its ability to
operate with less than the contracted amount of 14.4 MGD.
o The City has transitioned a portion of its supply to groundwater wells.
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Jefferson County’s Community Wildfire Protection Plan (CWPP, June 2024) was reviewed for fire
prevention strategies as the study area is substantially wooded. The study area is currently served by
East Jefferson Fire Rescue District.
• The CWPP classifies most of the study area as having High and/or Extreme Composite Risk-
Hazard and an “Area of Concern.” The County is comprised of vegetative fuels that historically
and naturally would burn every 50 years to over 1,000 years. Efforts to restore and maintain
landscapes should focus on vegetation management and hazardous fuel reduction. Many of the
recommendations listed can be implemented at the homeowner or community level.
Refer to Appendix A-4 for water maps and associated water and fire information.
Cost of Service Analysis
3.5 Sewer
Sewer in the study area would be provided by the City of Port Townsend (City). Existing sewer in the
northernmost portion of the study area is located within the city limits of the City. The surrounding
areas of unincorporated Jefferson County (County) do not have sewer service, and wastewater is
managed with on-site septic systems, community drain fields, or alternative sewage treatment
technologies.
The following is a summary of information from Jefferson County Environmental Public Health:
• Jefferson County Environmental Public Health is the permitting agency for new septic systems.
Existing septic systems are utilized throughout the study area: located mostly north of Old Fort
Townsend Road, west of Julian Street, along Frederick Street, west of and along South 6th
Street, and along Glen Cove Road.
The following is a summary of information from the 2024 City of Port Townsend General Sewer Plan
(GSP):
• The existing City Island Vista Lift Station outlets into a system of existing 8" gravity main (mostly
reinforced concrete and PVC) within the Sims Way sewer drainage basin.
• The City has one existing wastewater treatment plant (WWTP).
• The PTPC just south of the City limits has one existing private WWTP for domestic wastewater
purposes.
• The PTPC also has an industrial discharge permit for the paper production wastewater.
• The Glen Cove area located southwest of the City limits has been designated as a Special Study
Area for possible future inclusion in the City’s service area. The primary basis for allowing this
area to be potentially included into the City sewer service area is based on the following four
factors:
1. The Glen Cove industrial area is a Type 3 Local Area of More Intense Rural Development
(LAMIRD) intended for light industrial and limited commercial use that could benefit from
the presence of sewer. Currently, all uses in this area are required to have an on-site septic
system, which may be limiting industrial activities and potentially resulting in environmental
degradation. LAMIRDs are permitted to be served by sanitary sewer per the Growth
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Management Act (Washington Administrative Code (WAC) 365-196-425(6)(c), Rural
Element).
2. In this area, the PTPC currently has an industrial waste treatment system and a domestic
waste treatment system, both of which discharge to Port Townsend Bay. The City may
consider allowing the domestic system to connect to the City’s sewer system for the
environmental benefit of eliminating a discharge to Port Townsend Bay. This option needs
to be approved by Ecology and the Department of Commerce before executing a sewer
service agreement for the PTPC.
3. Incorporation of the LAMIRD through a UGA expansion or swap in cooperation with the
County. Based on existing, more intense development patterns, the Glen Cove Area may be
deemed a key area to serve existing and future uses to support the local economy given the
lack of industrially zoned properties and the need for housing within the City. An additional
20-acre parcel directly adjacent to the City is owned by the County and is serving as a
homeless shelter. This parcel serves key public needs of providing for the poor and infirm.
Sewer service to this property may be of great benefit to the community and may serve as a
basis for a UGA expansion.
4. A portion of the area within the Glen Cove drainage basin is already in the City limits and
does not have access to sewer without the installation of a sewer lift station. Therefore,
locating a sewer lift station in an appropriate area that keeps options open will allow the
City to make sewer service available for unsewered areas within the City limits while
allowing Factors 1 through 3 above to be considered.
o All four of these factors involve the City and County working closely together to evaluate
impacts of sewer extension. The purpose of the Special Study Area is to document the sewer
basin planning process performed in 2012 as outlined in the Mill Road Pump Station and
Force Main Predesign Report (GSP Appendix B). The City has funding to site a lift station in
the Mill Road area to serve the current UGA – public investment of approximately $4
million.
• The following excerpts from the 2024 City GSP show the metrics used in the demand forecast:
o Table ES-1 presents the land uses within the future wastewater service area. Regarding
population projections and designated land use within the City’s planning area: the
City’s 2021 population was 10,220 people, which is expected to grow to 13,300 people
by 2043. The City’s residential areas largely are comprised of single-family homes, with
approximately 75 percent of the housing units being single-family residences. The 2021
sewer service population is estimated at approximately 9,829 people. The City’s sewer
system population is expected to grow to 12,720 people in 2033 and to 15,242 people
by 2043. The residential population estimate is based on an average single-family
household size of 1.9 persons per household in the City.
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o The Special Study Area expansion will extend service to two new sewer basins already
inside the City limits and could serve the Glen Cove LAMIRD just outside the City limits.
For the purposes of estimating demand on the sewer system, an equivalent population
for the industrial area was estimated. The additional population outside of the City
limits this expansion would introduce to the sewer service area is included in Table 3-3
under the assumption the expansion would start in 2025. Note, the actual population
growth would be considerably less given business customers do not necessarily add
more population to the City.
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• The existing Island Vista Lift Station is not forecast to have a capacity shortfall. The station
handling most of the new population growth will be the proposed Mill Lift Station. Predesign
studies show that a 1,062 gpm capacity is required. Capacity upgrades are needed for the Mill
Lift Station to come online.
• Hydraulic Analyses Results: Hydraulic analyses were performed based on the existing flow rates
(2018), as well as projected flow rates for 2028, 2033, and 2043. In the evaluation, the criteria
for listing an existing sewer pipe as deficient is that the upstream maintenance hole is
surcharged more than 1 foot during the estimated peak hour flow (PHF). Currently, the existing
gravity sewers do not have deficient conveyance capacity. The primary driver of gravity main
capacity improvements for the 5-year, 6- to 10-year, and 11- to 20-year planning periods are the
projected flows from the proposed development of the Mill site. Fortunately, this flow will be
conveyed by gravity to the existing City WWTF following discharge from the proposed Mill Lift
Station force main. Existing lift stations will not be taxed by these additional flows; however,
substantial investment in the upsizing of existing pipelines will be required over the next 20
years to convey these flows to the existing City WWTF.
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• Growth in Flow and Loading: The projected 2043 flow and biochemical oxygen demand (BOD)
loading is very near to the permitted capacity of the WWTF. Further, the projected 2033 BOD
loading exceeds 85 percent of the rated capacity. The City’s NPDES Permit requires the City to
begin planning for an expansion of facility capacity when flow and loading exceeds 85 percent of
the permitted maximum month value for 3 consecutive months. It takes considerable time (up
to 10 years) to properly plan for and permit major treatment plant expansion, and as such, it is
recommended that the City begin planning for such an expansion in the first 5 years of the
planning period. In general, the existing WWTF infrastructure occupies most of the area
included in the City parcels and there is not sufficient available space on these parcels to plan
for a major expansion of the WWTF.
• Capital Improvement Plan:
o 5-Year System Improvements
CIP WW4 – Mill Lift Station (Cost: $6,300,000)
Deficiency: Currently, there is no sewer service at the Mill site. This lift station and force
main will allow for development of the Mill site to its potential.
Improvement: Procure property and construct a submersible lift station with an
ultimate firm capacity of 1,062 gallons per minute. The station is to include backup
power generation and a 4,500-foot-long, 10-inch-diameter force main as shown in GSP
Figure 10-1. Costs also include gravity piping in the area to supply the lift station.
CIP SM1 – Sims Way Crossing and Wilson Street Realignment (Cost: $1,212,000)
Deficiency: The concrete gravity sewer main in W Sims Way and Wilson Street lacks the
hydraulic capacity to convey the projected 5-year flows from the proposed Mill Lift
Station. Furthermore, portions of this pipeline pass beneath an existing residence.
Improvement: Replace approximately 786 LF of existing 8-inch gravity pipe with new 18-
inch gravity sewer in a different alignment on an easement to be procured. This project
must be completed concurrently with the construction of the Mill Lift Station (CIP
WW4).
o 6- to 10-Year System Improvements
CIP SM2 – Howard Street and S Park Avenue (Cost: $1,578,000)
Deficiency: The gravity sewer main in Howard Street and S Park Avenue has hydraulic
capacity deficiencies, and a portion of these sewer mains need to be upsized.
Improvement: Replace approximately 1,079 LF of existing 8-inch gravity pipe with new
15-inch gravity sewer pipe by open-cut methods as shown in GSP Figure 10-1.
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CIP SM3 – Sims Way, 3rd Street, and Gise Street (Cost: $1,186,000)
Deficiency: The gravity sewer mains in Sims Way, 3rd Street, and Gise Street have
hydraulic capacity deficiencies, and a portion of these sewer mains need to be upsized.
Improvement: Replace approximately 273 LF of existing 8-inch gravity pipe with new 18-
inch gravity sewer pipe and replace approximately 523 LF of existing 8-inch gravity pipe
with new 15-inch gravity sewer pipe by open-cut methods as shown in GSP Figure 10-1.
CIP SM4 – Holcomb Street (Cost: $819,000)
Deficiency: The gravity sewer main in Holcomb Street has hydraulic capacity deficiencies
and a portion of the sewer main needs to be upsized.
Improvement: Replace approximately 531 LF of existing 12-inch gravity pipe with new
18-inch gravity sewer pipe by open-cut methods as shown in GSP Figure 10-1.
CIP SM5 – Howard Street, S Park Avenue, and McPherson Street (Cost: $2,463,000)
Deficiency: The gravity sewer mains in Howard Street, S Park Avenue, and McPherson
Street have hydraulic capacity deficiencies, and a portion of these sewer mains need to
be upsized.
Improvement: Replace approximately 1,685 LF of existing 8-inch sewer with new 15-
inch gravity sewer pipe by open-cut methods as shown in GSP Figure 10-1.
o 11- to 20-Year System Improvements (Long-Term Planning Capital Improvements)
CIP SM6 – West Sims Way and 3rd Street (Cost: $1,679,000)
Deficiency: The existing 8-inch concrete gravity sewer mains in West Sims Way and 3rd
Street have hydraulic capacity deficiencies, and a portion of these sewer mains need to
be upsized.
Improvement: Replace approximately 1,150 LF of existing 8-inch concrete sewer main
with new 15-inch gravity sewer pipe by open-cut methods as shown in GSP Figure 10-1.
Per the Port Townsend Leader newspaper articles:
• The WA State Department of Ecology held a public hearing on December 4, 2024 for the Port
Townsend Paper Corporation’s Draft National Pollutant Discharge Elimination System permit
(NPDES). The existing NPDES permit has expired but has been administratively extended ever
since via a letter from Ecology dated April 6, 2018. PTPC operates a large industrial wastewater
treatment plant and a small sanitary wastewater treatment plant that discharge treated
wastewater into Port Townsend Bay. Limits at the sanitary plant are the same in the current
permit and the proposed draft permit.
Refer to Appendix A-5 for sewer maps and associated sewer information.
Wastewater Discharge Permit for Industrial Uses
Cost of Service Analysis
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3.6 Stormwater
Jefferson County is the permitting agency for new stormwater systems in the study area, outside of the
City of Port Townsend city limits:
• Jefferson County has adopted the 2024 WA State Department of Ecology Stormwater
Management Manual for Western Washington and the 2005 Low Impact Development
Technical Guidance Manual for Puget Sound (Puget Sound Partnership).
• Portions of the study area are located within a Susceptible (SUSC) Critical Aquifer Recharge
Area: critical area with geologic and hydrologic conditions that promote rapid infiltration of
recharge waters to groundwater aquifers; areas vulnerable to contamination of drinking water.
• Portions of the study area are located within erosion, slope, seismic, and landslide hazard areas.
• Existing drainage patterns include….
Per the 2019 City of Port Townsend Stormwater Management Plan:
• The City of Port Townsend has adopted the 2005 WA State Department of Ecology Stormwater
Management Manual for Western Washington (SWMMWW).
• The City has areas with platted lots, often 5,000 square feet in size and rights-of-way that are
not developed. Proposed development or redevelopment of these lots may or may not exceed
SWMMWW thresholds for stormwater control. Uncontrolled development of these areas does
result in increased flows and can cause impacts: existing wetland boundaries expand and
capacity of existing pipes and ditches is exceeded relative to both peak flow and velocity. The
calculations for future runoff do not consider the benefits of stormwater measures required by
the SWMMWW, thus the results are conservative and more protective than the standard.
Development and buildout of individual lots are generally under the stormwater control
requirement thresholds in the SWMMWW, although City code will require infiltration and
control to the maximum extent practicable, therefore these results are also conservative.
Reductions in allowable land use changes or changed thresholds for required stormwater
controls are other measures the City can take to control future stormwater impact potential.
• Two capital improvement projects that discharge into the study area were underway in 2019:
o Rainier Street Regional Stormwater Project
o Logan Street Stormwater Pond Overflow
The soil map shows the majority of the study area as hydrologic soil group A with saturated hydraulic
conductivity being high to very high and groundwater at greater than 6.7 feet deep; these areas typically
have the potential to infiltrate stormwater.
Per meeting notes: The City has had conversations about possible connection to the PTPC for release of
non-industrial stormwater. The feasibility of this is unknown.
Refer to Appendix A-6 for stormwater maps and associated stormwater information.
National Pollutant Discharge Elimination System (NPDES)
Stormwater Management Options
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4 Transportation
Appendix 1
Power
Appendix 2
Telecommunications
Appendix 3
Natural Gas
Not Used
Appendix 4
Water
Appendix 5
Sewer
Appendix 6
Stormwater