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HomeMy WebLinkAboutOrdinances - 2009-18 - Amending Ordinance 2008-07 Adopting Amendments to Douglas County Regional Shoreline Master Program, Changes required by the State Department of Ecology - RCW 36.70A.480(3)(a) - 11/24/2009CITY OF EAST WENATCHEE, WASHINGTON ORDINANCE NO. 2009-18 AN ORDINANCE OF THE CITY OF EAST WENATCHEE, WASHINGTON, AMENDING ORDINANCE 2008-07 AND ADOPTING AMENDMENTS TO THE DOUGLAS COUNTY REGIONAL SHORELINE MASTER PROGRAM; TO INCORPORATE THE CHANGES REQUIRED BY THE STATE DEPARTMENT OF ECOLOGY AND TO IMPLEMENT THE PROVISIONS OF RCW 36.70A.480(3)(a), CONTAINING A SEVERABILITY CLAUSE, AND ESTABLISHING AN EFFECTIVE DATE. THE CITY COUNCIL OF THE CITY OF EAST WENATCHEE DO ORDAIN AS FOLLOWS: Section 1: Purpose. (1) The East Wenatchee Planning Commission held a public hearing on May 28, 2008 and unanimously recommended approval of the Draft Douglas County Regional Shoreline Master Program ("SMP"), including revised appendices A — H, (dated May 16, 2008), and as amended by the planning commission on May 28, 2008. (2) On June 24, 2008, the East Wenatchee City Council ("City Council") held a public hearing to consider the recommendation of the planning commission. Following the public hearing, the City Council approved Ordinance 2008-07 adopting the Douglas County Regional Shoreline Master Program. (3) On July 18, 2008, the adopting ordinance and the Douglas County Regional Shoreline Master Program was submitted to the Washington State Department of Ecology ("DOE") (4) On March 10, 2009, DOE submitted a letter of conditional approval listing changes that were necessary in order for them to issue final approval of the SMP. (5) The City Council held a Special Public Meeting on March 31, 2009 to review DOE's required and recommended changes. At that meeting, City Council took action relative to either concurring with the changes or proposing alternatives. On April 13, 2009, correspondence was transmitted to DOE to address their conditional approval including acceptance of some of the changes proposed by DOE and offering alternatives for other changes proposed by DOE. (6) DOE submitted a letter and attachments on July 23, 2009 outlining the status of required and recommended changes, in response to the City's April 13, 2009 proposal, including: (a) A summary table of required changes on which DOE needs written notice of agreement from the City; and ORDINANCE NO. 2009-18 Page 1 of 4 (c) Documentation of changes that the City accepted or alternative proposed in the April 13, 2009 correspondence. (7) The City Council finds that it is in the best interests of the City and its citizens to amend the adopted SMP in accordance the conditional approval letter from DOE dated July 23, 2009. Section 2: Authority. (1) RCW 35A.11.020 and RCW 35A.12.190 authorize the City Council to adopt ordinances of all kinds to regulate its municipal affairs and appropriate to the good government of the City. (2) RCW 90.58 authorizes the City to adopt a shoreline master program consistent with the SMA. (3) RCW 36.70A.480(3)(a) states: "As of the date the department of ecology approves a local government's shoreline master program adopted under applicable shoreline guidelines, the protection of critical areas as defined by RCW 36.70A.030(5) within shorelines of the state shall be accomplished only through the local government's shoreline master program and shall not be subject to the procedural and substantive requirements of this chapter, except as provided in subsection (6) of this section." Section 3: Adoption. (1) Exhibit B of Ordinance No. 2008-07, adopted in Section 3 of the ordinance, is amended to incorporate the changes identified in Exhibit B and C of this Ordinance. (2) The DOE correspondence requested that the City notify them regarding the City's intention relative to Section 4.6 Regulation 16 of the SMP (Page 9 of Exhibit B). The City Council hereby notifies DOE that this ordinance adopts the alternative language proposed in the April 13, 2008 correspondence and does not accept the alternative language provided by the City of Bridgeport (3) The DOE correspondence requested that the City notify them regarding the City's intention relative Appendix H.3 Section 1 C.060(D) (pages 73 — 80 of Exhibit Q. The City accepts the language proposed by DOE. (4) In accordance with RCW 36.70A.480(3)(a), on the date of Department of Ecology approval of the Douglas County Regional Shoreline Master Program, adopted by Ordinance No. 2008-07 and amended herein, the protection of critical areas as defined by RCW 36.70A.030(5) within shorelines of the state shall not be regulated by the provisions of East Wenatchee Municipal Code Chapter 18.12 and Chapters 18.12A-18.12.F that apply to critical areas defined by RCW 36.70A.030(5). (5) The City Council directs the Community Development Director to incorporate the changes noted in Attachments B and C into the SMP. Section 4: Findings of Fact. (1) The City Council adopts by reference the findings of fact and conclusions as set forth in the attached Exhibit A. ORDINANCE NO. 2009-18 Page 2 of 4 (2) The Findings of Fact and Conclusions adopted in Ordinance No. 2008-07 remain timely and in order and are adopted by this reference. Section 5: Severability. If a court of competent jurisdiction declares any provision in this Ordinance to be contrary to law, such declaration shall not affect the validity of the other provisions of this Ordinance. Section 6: Publication. The City Council directs the City Clerk to publish a summary of this Ordinance. The summary shall consist of the title of this Ordinance. Section 7: Effective Date. In accordance with RCW 90.58.090 the effective date of the Douglas County Regional Shoreline Master Program shall be concurrent with the adoption of the Douglas County Regional Shoreline Master Program by the Washington State Department of Ecology which action also supersedes the 1975 Douglas County Shoreline Master Program. Passed by the City Council of East Wenatchee, at a regular meeting thereof on this 24th day of November, 2009. CITY OF EAST WENATCHEE, WASHINGTON By ( I Chuck Johnson, NPyor Pro-tem ATTEST: � 4v��� Dana Barnard, City Clerk Approv as to form ly: n De in Poulson, City Attorney FILED WITH THE CITY CLERK: 11/19/09 PASSED BY THE CITY COUNCIL: 11/24/09 PUBLISHED: 11/27/09 EFFECTIVE DATE: 12/02/09 ORDINANCE NO. 2009-18 Page 3 of 4 SUMMARY OF ORDINANCE NO. 2009-18 Of the City of East Wenatchee, Washington On the 24th day of November 2009, the City Council of the City of East Wenatchee, Washington, passed Ordinance No. 2009-18. A summary of the content of said Ordinance, consisting of the title, provides as follows: AN ORDINANCE OF THE CITY OF EAST WENATCHEE, WASHINGTON, AMENDING ORDINANCE 2008-07 AND ADOPTING AMENDMENTS TO THE DOUGLAS COUNTY REGIONAL SHORELINE MASTER PROGRAM; TO INCORPORATE THE CHANGES REQUIRED BY THE STATE DEPARTMENT OF ECOLOGY AND TO IMPLEMENT THE PROVISIONS OF RCW 36.70A.480(3)(a), CONTAINING A SEVERABILITY CLAUSE, AND ESTABLISHING AN EFFECTIVE DATE. The full text of this Ordinance will be mailed upon request. CITY CLERK, DANA BARNARD ORDINANCE NO. 2009-18 Page 4 of 4 EXHIBIT A FINDINGS OF FACT: 1. During review of Ordinance No. 2008-07, the Department of Ecology has noted revisions that are required and/or recommended. 2. The basis and rationale for the changes to Ordinance No. 2008-07, are stated within the correspondence submitted by the City of East Wenatchee to DOE on April 13, 2009, and in the correspondence from the Department of Ecology dated July 23, 2009. 3. The East Wenatchee City Council held a Special Public Meeting on March 31, 2009 to review DOE's required and recommended changes. At that meeting, City Council took action relative to either concurring with the changes or proposing alternatives. On April 13, 2009, correspondence was transmitted to DOE documenting the City Council's acceptance of some of the changes proposed by DOE and offering alternatives for other changes proposed by DOE. 4. On November 24, 2009, the City Council considered the requested changes proposed in DOE's July 23, 2009 correspondence. 5. All previous determinations issued and documents prepared pursuant to the State Environmental Policy Act of 1971 remain timely and in order. CONCLUSIONS: 1. The changes to Ordinance No. 2008-07, are necessary for consistency with and the implementation of RCW Chapter 90.58, the Shoreline Management Act, and WAC Chapter 173-26, State Master Program Approval/Amendment Procedures and Master Program Guidelines 2. The changes to Ordinance No. 2008-07, are necessary for the protection of the public health, safety and general welfare of the City of East Wenatchee. Exhibit A, Ordinance No. 20094 EXHIBIT B Douglas County RSMP Status Document Part 2.1— Required Changes — RSMP Part 2: Status of Required Changes On April 13, 2009, the local jurisdictions submitted a letter to Ecology agreeing to some of Ecology's required changes to the RSMP, and proposing alternatives for othersl. Ecology has approved the proposed alternatives that have been found to be consistent with the SMA and the SMP Guidelines. Following is an account of the status of each required change. Underlining indicates wording to be added. • StTikeext indicates wording to be deleted. Regional SMP (RSMP) Section 1.2 The Act recognizes that certain waters are so important to citizens as to necessitate a special status for classification and protection. These are "shorelines of statewide significance." WAC 173-18-040 further clarifies streams and rivers in eastern Washington are considered "shorelines of statewide significance." The Columbia River is a Shoreline of Statewide Significance. Ecology Rationale: Required change for compliance with WAC 173-26-171(1) in order to regulate "shorelines" and "shorelines of the state" the waterbodies must be clearly classified as required by RCW 90.58.020(7). The section of the SMP discusses what Douglas County's jurisdiction is and talks in general about what a `Shoreline of Statewide Significance' is, but never acknowledges that the Columbia River is a Shoreline of Statewide Significance. Chapter 9 deals with what shorelines are jurisdictional and what the Environment Designation is for each stretch of shoreline. Yet, no where can it be identified in the scope that development actions that occur on the Columbia River are under the specific mandates of WAC 173-26-251, and that particular attention for compliance with the SMP needs to be enforced so as not to convert resources into irreversible uses or detrimentally alter natural conditions characteristic of shorelines of statewide significance (WAC 173-26-251(3)). Local Response: Agreed to required change. Section 1.7 All proposed uses and development, including accessory structures, occurring within the shoreline jurisdiction must conform to Chapter 90.58 RCW, the Shoreline Management Act and this Program whether or not a permit or other form of authorization is required. 1 A separate document titled "DC - RSMP Chronological Discussion contains the details of informal discussions between the local jurisdiction(s) and Ecology. Any section for which more information is available will be noted with "See Chronological Discussion". July 22, 2009 Page 5 Douglas County RSMP Status Document Part 2.1 — Required Changes — RSMP Ecology Rationale: Required change because accessory structures/uses do not belong in critical areas or their buffers. Required to meet the WAC no net loss standard and WAC 173-26-221(5) (a, b), WAC 173-26-221(6) (b). Using the word "Authorized" indicates that even developments that are exempt from the requirement to obtain a shoreline permit must comply with this chapter because they are authorized under the RSMP. Through the public review process there was a misconception that Douglas County did not have regulatory authority over the placement of accessory structures, specifically septic systems. The explanation was provided that this placement authority was only through the Chelan -Douglas Health District and not through the regulatory authority of the SMP. Not only do the SMP Guidelines (WAC 173-26) provide this authority over septic system location, but also the On -site Sewage System (OSS) regulations (WAC 246-272A) allow a local health officer to issue a permit only when the proposed OSS meets the health district regulations AND other local regulations. Therefore, Douglas County does have the authority to issue a local regulation (SMP) that the health officer would be obliged to follow. "WAC 246-272A-0200(4) The local health officer shall: (c) Issue a permit when the information submitted under subsection (1) of this section meets the requirements contained in this chapter and in local regulations, " Local Response: Proposed alternative language (below). All proposed uses and development, inelu ing .,eeesser-y stfuet„fes, occurring within the shoreline jurisdiction must conform to Chapter 90.58 RCW, the Shoreline Management Act and this Program. . Ecology Response: Approves the proposed alternative language. [NOTE: Ecology approves of the proposed alternative language for Section 1.7 with the understanding that Douglas County and the cities of Bridgeport, East Wenatchee, and Rock Island agree to ensure that all proposed uses and development, including accessory and/or appurtenant development, must comply with policies and regulations set out in the RSMP and each individual jurisdiction's Appendix H Critical Area Protections, including the buffer standards. See RSMP Section 8, changes to Definitions - Accessory & Appurtenant.] Section 1.10 When th X . . ins ef d:iis ehapter- or- any ether- pr-evisiens ef this Pr-eg.Lr."11 f-"%, ..Li direet. eenfliet with eaeh ether- er- �� ether- federal er sta4e r-egulatiens, the pr-evisien that is the mes r-est-fiefive shall apply. -, -In the event the provisions of this Program conflict with provisions of federal, state, countor ci1�regulations, the provision that is the most protective of shoreline resources shall prevail, when consistent with policies set out in the SMA. July 22, 2009 Page 6 Douglas County RSMP Status Document Part 2.1 — Required Changes — RSMP Ecology Rationale: As provided for in RCW 90.58.900, the Act is exempted from the rule of strict construction; the Act and this Program shall be liberally construed to give full effect to the purposes, goals, objectives, and policies for which the Act and this Program were enacted and adopted, respectively. The SMA is an ecological shoreline management tool meant to result in a ` planned, rational, and concerted effort, jointly performed by federal, state, and local governments, to prevent the inherent harm in an uncoordinated and piecemeal development of the state's shorelines "(RCW 90.58.020) The alteration in wording is more in line with the guidelines goal of no net loss and protecting ecological functions while providing for compliance with RCW 90.58.900 in taking into consideration the whole intent of the SM4, which also include a preference for water -dependent shoreline uses and public access. Local Response: Agreed to required change. Section 2.2 (#2) Access to shorelines is encouraged and should be incorporated into both private and public shoreline development proposals. Private Aaccess developed for pr+vate residential development may be limited to owners within that development. Ecology Rationale: If it is planned that a residential access street shall become a County or City owned and maintained street, then private access does not apply. Local Response: Agreed to required change. Section 3.3 (4) Land uses that would substantially degrade the ecological functions or natural character of the shoreline area should not be allowed. Specifically, the following new uses shall not be allowed in areas designated natural environment: commercial or industrial uses, inon-water- oriented recreation,; or roads, utility corridors, and parking areas that can be located outside of natural designated shorelines. Ecology Rationale: Required for compliance with WAC 173-26-211(5) (a) (ii) (B). Replace commas with semi -colons and separate out that roads, utility corridors, and parking areas are not allowed if they can be located elsewhere, to provide clarity. Ecology acknowledges that Table 1, Section 3.10 reflects this policy. Local Response: Proposed Alterative Language (below). July 22, 2009 Page 7 Douglas County RSMP Status Document Part 2.1 — Required Changes — RSMP Land uses that would substantially degrade the ecological functions or natural character of the shoreline area should not be allowed. Specifically, the following new uses shall not be allowed in areas designated natural environment: • Commercial uses. • Industrial uses. • Non -water -oriented recreation. • Roads, utility corridors, and parking areas that can be located outside of "natural" designated shorelines. Ecology Response: Approves proposed alternative language. Section 4.6 (Policy 14) Recreational development should place a priority for public use and access to the water. Ecology Rationale: Required change for compliance with WAC 173-26-241(3)(i), move from RSMP Section 4.6 Regulation 2 to policy section, because language is more policy in nature. Local Response: Agreed to required change. Section 4.6 (Regulation 2) Public Access for commercial recreational development shall be consistent with the public access requirements of commercial development of this Master Proms Ecology Rationale: Move Section 4. 6(Reg 42) to create policy. Local Response: Agreed to required change. Section 4.6 (Regulation 6) Commercial and industrial development shall provide public access to the shoreline, or if not feasible ernEVe provide opportunities for public viewing of the shoreline, except as provided for in Section 4.6(l l -t.,,,enevor ,..r-aef;ea an safe-. Ecology Rationale: Required change for compliance with WAC 173-26-221(4) (d) (iii) and WAC 173-26-241(3) (d). July 22, 2009 Page 8 Douglas County RSMP Status Document Part 2.1— Required Changes — RSMP Local Response: Agreed to required change. Section 4.6 (Regulation 16) New streets, roads and highways which are located within two hundred feet of a shoreline of the state shall provide public access to the shoreline, whenever feasible, consistent with design and safety standards. Such facilities may include roadside paldfig area-, pathways, viewpoints or similar amenities. EcologE Rationale: Required Change for compliance with WAC: 173-26-241(3)(k) To specifically call out parking area as acceptable facility for public access is in direct conflict with this WAC. Local Response: Proposed alternative language (below). Douglas County's suggested alternative: New streets, roads and highways which are located within two hundred feet of a shoreline of the state shall provide public access to the shoreline, whenever feasible, consistent with design and safety standards. Such facilities may include pathways, viewpoints or similar amenities and accessory parking facilities incidental to those amenities. Bridgeport's suggested alternative: New streets, roads and highways which are located within two hundred feet of a shoreline of the state shall provide public access to the shoreline, whenever feasible, consistent with design and safety standards. Such facilities may include roadside pull-outs, pathways, viewpoints or similar amenities. Ecology Response: Approves both proposed alternatives. Note: Please notify Ecology in writing whether there is consensus on one proposed alternative. The proposed alternative submitted by Bridgeport is different from that proposed by the other jurisdictions. It is acceptable for Bridgeport to have different wording for the city SMP, but the local jurisdictions have all emphasized to Ecology that this was a Regional SMP and they wanted consistent language. Section 6.4 (Regulation 4) Either match the wording of Industrial Uses (RSMP Section 5.6(1)(c)) or add underlined language (below). July 22, 2009 Page 9 Douglas County RSMP Status Document Part 2.1 — Required Changes — RSMP Non -water -oriented commercial uses may be permitted where located on a site physically separated from the shoreline by another property in separate ownership, or by a public right- of-way, such that access for water -oriented use is precluded. All other non -water -oriented commercial uses are prohibited in the shoreline unless the use provides significant public benefit with respect to the objectives of the Act such as providing_ public access and ecological restoration, and the industrial use is: a. Part of a mixed use project that includes a water -dependent use; or b. Proposed on a site where navigability is severely limited. Ecology rationale: The RSMP can reword the WAC, but the full intent is not present. The objectives of the Act are specifically called out for commercial uses in WAC 173-26-241(3) (d). Local Response: Proposed alternative language (below). Non -water -oriented commercial uses may be permitted when physically separated from the shoreline by another property in separate ownership, or by a public right-of-way, such that access for water -oriented use is precluded. All other non -water -oriented commercial uses are prohibited in the shoreline unless the use provides significant public benefit with respect to the objectives of the Act such as providing public access and ecological restoration, and the commercial use is: a. Part of a mixed use project that includes a water -dependent use; or b. Proposed on a site where navigability is severely limited. Ecology Response: Approves proposed alternative language. ;.. Section 5.4( 7) Only those portions of water -dependent commercial uses that require over -water facilities shall be permitted to locate waterward of the OHWM, provided they are located on piling or other open-work structures, and they are limited to the minimum size necessary to support the structures intended use. Ecology Rationale: Required change to comply with WAC 173-26-211(5) (c) (ii) (B) & RSMP Section 3.9 Aquatic Policy 42 The size of new over -water structures should be limited to the minimum necessary to support the structure's intended use. July 22, 2009 Page 10 Douglas County RSMP Status Document Local Response: Agreed to required change. Section 5.6 Industry — Add regulations Part 2.1 — Required Changes — RSMP ADD 5.6 Reg. 45. Only those portions of water -dependent industrial uses that require over - water facilities shall be permitted to locate waterward of the OHWM, provided they are located on piling or other open-work structures, and they are limited to the minimum size necessary t�pport the structures intended use. Ecology Rationale: See RSMP Section 3.9 Aquatic Policies 41 & 2 and WAC 173-26- 211(5) (c) (ii) (A) & (B). There is a policy in Section 3.9, but no implementing regulation to be found. Local Response: Agreed to required change. Section 5.10 (Regulation 9) 9. In order to minimize impacts on near shore areas and avoid reduction in ambient light level: a. Pier and Ramp construction must meet the following standards: i) The width of piers and ramps, and f,^shall not exceed 4 feet in width, except where specific information on use patterns such as public or commercial docks may justify a greater width ii) The bottom of the fascia boards on a pier, or bottom of the landward edge of a ramp, must be elevated at least two (2) feet above the plane of OHWM. iii) skirtingpiers, ramps or floats is prohibited. iv) pier and/or ramp surfaces are made of either grating or clear translucent material. The open area of and grating material needs to be 60%, and clear translucent material has to have greater than 90% light transmittance, as rated by the manufacturer. Ma4efials that will a4lew light te pass dffieugh the deek may be reqtfir-ed where Wi o�,,,eoas 4 goo+ b. Float construction must meet the following standards: i) Float dimensions shall not exceed 8-feet by 20-feet. Only one float is allowed per dock project. Joint -use docks (as described above) are an exception and are allowed two floats. ii) The freeboard height on floats must be at least 10 inches. iii) Any float materials that are in contact with the water must be white or translucent. July 22, 2009 Page 11 Douglas County RSMP Status Document Part 2.1— Required Changes — RSMP iv) Flotation materials must be permanently encased to prevent breakup and release of small floatation pieces. v) Decking or surface area of the float must be grating or clear translucent material. Both types of material must cover at least 50% of the surface area of floats. The open area of grating needs to be at least 60% and clear translucent material needs to have greater than 90% light transmittance as rated by the manufacturer. vi) Floats cannot be located in shallow water habitat where they could ground or impede fish passage. The water depth under a permanent float must be at least: (1) 14 feet for permanent floats in the Rock Island and Rocky Reach reservoirs and 7 feet for temporary floats. (2) 18 feet for permanent floats in the Wells reservoir and 11 feet for temporary floats. (3) There is no specific depth standard in the Lake Rufus Woods pool or in lakes so these will be examined on a case -by -case basis. vii) "Temporary" floats shall not be located t in the water between March 1 and June 30. Permit conditions will identify whether a temporary or permanent float is associated with a project. Ecology Rationale: Required for compliance with WAC 173-26-231(3) (b) and WAC 173- 26-241(3) (c) (vi) and WAC 173-26-251(2) and RCW 90.58.020(2) as well as being at least as protective as current permitting practices. Without criteria to determine what "specific information on use patterns, such as public or commercial docks may justify a greater width, " additional size limits are needed to provide clarity on what the normal range of size to be considered should be. Standards herein are taken directly from Douglas County Multi Agency Permitting (MAP) Process - Conditioned Docks, Floats, Mooring Buoys and Watercraft Lifts, Part One: Multi Agency Permitting (MAP) Process. Local Response: Proposed alternative language (below). In order to minimize impacts on near shore areas and avoid reduction in ambient, light level: a. Pier and Ramp construction must meet the following standards: i. The width of piers and ramps shall not exceed 4 feet for single or joint -use docks. Greater widths may be permitted for community, public or commercial docks where use patterns can justify the increase; ii. The bottom of the pier or bottom of the landward edge of a ramp, must be elevated at least two (2) feet above the plane of OHWM. July 22, 2009 Page 12 Douglas County RSMP Status Document Part 2.1 — Required Changes — RSMP iii. Pier and/or ramp surfaces are to consist of either grating or clear translucent material; and iv. Pier and ramp construction shall meet or exceed the standards and/or requirements of the Washington State Departments of Ecology, Fish and Wildlife, and Natural Resources and the United States Army Corps of Engineers. b. Float construction must meet the following standards: i. Any float materials that are in contact with the water must be white or translucent. ii. Flotation materials must be permanently encased to prevent breakup and release of small floatation pieces. iii. Decking or surface area of the float must consist of either grating or clear translucent material; and iv. Floats cannot be located where they could impede fish passage. V. Float construction shall meet or exceed the standards and/or requirements of the Washington State Departments of Ecology, Fish and Wildlife, and Natural Resources and the United States Army Corps of Engineers. Ecology Response: Approves proposed alternative language. Section 5.11 (Regulation 4) Add Section 5.11 (Regulation 4). Commercial recreational facilities shall be consistent with the provisions of Section 5.4 Commercial Use. Ecology Rationale: Change required to establish regulatory requirement for existing Policy statement SMP Section 5.6 (411) and for compliance with WAC 173-26-221(4)(d)(iii) and WAC 173-2 6-241 (3) (d). Local Response: Accepted required change. NOTE: Local jurisdiction(s) need to re -number the remaining regulations in Section 5.11 after adding the new regulation. Section 5.11(Policy#11) Commercial recreational facilities should be consistent with the provisions of Section 5.4 Commercial Use. July 22, 2009 Page 13 Douglas County RSMP Status Document Part 2.1— Required Changes — RSMP Ecology Rationale: Change required for more consistent Policy language. Local Response: Agreed to required change. Section 5.11 (Regulation 3 ) 3. Commercial and public recreation areas or facilities on the shoreline shall provide public access (physical or visual) consistent with the er ter-i Section 4.6, Public Access. Ecology Rationale: Change required to establish regulatory requirement for existing Policy statement SMP Section 5.6 (411) and for compliance with WAC 173-26- 221(4) (d) (iii) and WAC 173-26-241(3) (d). Local Response: Agreed to required change. Section 5.11 (original Regulation 4) Recreational uses and facilities shall be designed to be primarily related to access to, enjoyment and use of the water and shorelines of the state and located to ensure no net loss of critical areas and shoreline ecological functions. Ecology rationale: Required change for compliance with WAC 173-26-241(3)(i). Local Response: Request to maintain original language. Recreational uses and facilities shall be designed and located to ensure no net loss of critical areas and shoreline ecological functions. Ecology Response: Approves of maintaining the original language based on the local jurisdiction's rationale that Section 2.4 Objective #1 combined with Section 5.11, Regulation #1 implement the objective of WAC 173-26-241(3)(i). Section 5.13 (Regulation 2) Bulk and dimensional standards shall be coordinated with locally adopted zoning and development standards to protect the natural character of the shoreline and ensure no net loss of shoreline ecological functions and processes consistent with the purpose of the July 22, 2009 Page 14 Douglas County RSMP Status Document Part 2.1 — Required Changes — RSMP environment designation. hn the e v erri=vrc"r"eenf liet with. In the event the provisions of this Program conflict with provisions of federal, state, county or cijy regulations, the more protective of shoreline resources shall prevail, when consistent with Shoreline Management Act policy. Ecology Rationale: Required for compliance with Authority set out in WA 173-26-171(1) and RCW 90.58.200. Local Response: Agreed to required change. Section 5.13(9) Urban density standards- Where permitted, multi -family development, duplexes, subdivisions and short plats within urban growth boundaries shall not exceed the following maximum density standards, in addition to compliance with all other applicable provisions of this Program: • Shoreline residential: 5 dwelling units per acre • Urban conservancy: 17 dwelling units per acre • High intensity & Mixed -Use: 26 dwelling units per acre • Natural: 1 dwelling unit per 10 acres Ecology Rationale: Required change because "Mixed -Use " density standard were not provided, Ecology inserted a number that matches High Intensity density. The Shoreline Advisory Group designed the Mixed Use designation to allow the intensity of development as "High Intensity", but restrict Industrial Uses within this Environment Designation. WAC 173-26-211 provides that density standards be established to assure no net loss of shoreline ecological functions. Local Response: Agreed to required change. Section 5.13(11) Table 2 Institutional: dimensions applicable to structures Building * 15 * 15 * 15 * 15 * 15 NA NA setback — July 22, 2009 Page 15 Douglas County RSMP Status Document Part 2.1 — Required Changes — RSMP Ecology Rationale: Required change as noted in SEPA review and Shoreline Advisory Committee review, building setbacks from buffers to be at 15 ft. Error in table had 5 ft. Local Response: Agreed to required change. Section 5.13(11) Strike all Asterisks from Table 2 — the asterisks are confusing. The double asterisk goes onto say the other setback does apply within City jurisdiction standafd listed applies within the eity jurisdiefiens. Ecology Rationale: Required Changes, Remove all asterisks. Ecology Rationale: The 15' structural setback from the landward edge of buffers shall apply to all jurisdictions. The RSMP did not make it clear what the City required for setbacks from Buffers even though it was clear at the citizen's advisory group meeting that citizens felt that a setback was necessary to protect buffer areas. Strike all double asterisks with 60 ft note - 15/'68 Ecology Rationale: Bulk Dimensional Standards (note Changes to Appendix H. 4) removed 60 foot structural setback requirement (for implementation of required larger buffers see Appendix H.4 comments) Larger buffers are required in Appendix H, the 60 foot setback would have sometimes placed development outside shoreline jurisdiction. Local Response: Agreed to required change. Section 6.8 1. Use restfiefiens may net be varied. Variances from the use regulations of the Program are prohibited. Ecology Rationale: WA 173-26-170 (5) Variances from the use regulations of the master program are prohibited Local Response: Agreed to required change. July 22, 2009 Page 16 Douglas County RSMP Status Document Part 2.1 — Required Changes — RSMP Section 8.0 Definitions 1. "Accessory" means any use or development incidental to and subordinate to a primary use of a shoreline site. The terms accessory and appurtenant are sue, ous. Ecology Rationale: Required change because the SMA and associated guidelines use the term `appurtenant' while local code uses the term `accessory'. The RSMP did not provide a definition of appurtenant. This change makes it clear that these two terms are considered synonymous. Local Response: Proposed alternative language (below). l ."Accessory" — Any structure or use incidental and subordinate to a primary authorized use or development. 2."Appurtenant" — A structure or development which is necessarily connected to the use and enjoyment of a single - family residence and is located landward of the ordinary high water mark. Ecology Response: Approves proposed alternative. 36. "Building" means any combination of materials constructed, placed or erected permanently or temporarily on the ground or attached to something having a permanent location on the ground, for the shelter, support or enclosure of persons, animals or property, or supporting any use, occupancy or function whether artificially built or composed of parts joined together in some definite manner, which could be installed on, above or below the surface of the ground or water. , residential fenees, retaining walls less than di:fee feet in height, reekefies and similffir- . The terms building and structure are synonymous. Ecology Rationale: This definition says that the definitions of building and structure are synonymous, Yet the definition found in 173-27-030: (1 S) "Structure" means a permanent or temporary edifice or building, or any piece of work artificially built or composed of parts joined together in some definite manner, whether installed on, above, or below the surface of the ground or water, except for vessels; The 2nd to the last sentence is struck because many times residential fences, retaining walls and other similar built structures meet the SDP dollar threshold and alter the natural character of the shoreline, this type of exclusion is too permissive. Whether or not a mobile home or RV are July 22, 2009 Page 17 Douglas County RSMP Status Document Part 2.1 — Required Changes — RSMP immobilized or not has no bearing on placement in the shoreline. They should be required to meet the RSMP Section 1.7 and fall under building/structure/development definitions. Local Response: Agreed to required change. 65. "Development" Means a use consisting of the construction or exterior alteration of structures; dredging; . drilling; dumping; filling; removal of any sand, gravel, or minerals; bulkheading; driving of piling; placing of obstructions; or any project of a permanent or temporary nature which interferes with the normal public use of the surface of the waters overlying lands subject to this Program at any state stage of water level. Ecology Rationale: Required meet definition WAC 173-2 7-03 0(6) Local Response: Agreed to required change. 165. "Mixed use development" Means a combination of uses within the same building or site as a part of an integrated development project with functional interrelationships and coherent physical design. Mixed use developments, which incorporate non -water oriented uses, must include water dependent use(s), except commercial uses complying with as provided for i WAC 173-26-241(3)(d). Ecology Rationale: Require to meet the intent of Mixed Use development— Intent of Regulations can be found: WAC 173-26-201(2) (d) (ii), WAC 173-26-211(5) (d) (ii) (A) & WAC 173-26-241(3) ()g, WAC 173-26-231(3) WAC 173-26-241(3) (d). Local Response: Agreed to required change. 251. "Utilities" Means any water, gas, sanitary or storm sewer, electrical, telephone, irrigation, drainage way, wire or television communication facility and/or service and all persons, companies or governmental agencies furnishing the same. On -site utility features serving a primary use, such as a water, sewer or gas line to a residence, are "accessory utilities" and shall be considered a part of the primM use. July 22, 2009 Page 18 Douglas County RSMP Status Document Part 2.1— Required Changes — RSMP Ecology Rationale: Required for compliance with WAC (WAC 173-26-241(3) (D. This is not addressed in RSMP Section 5.17, this wording could be added in Section 5.17 or added here under the definition of 'utilities'. Local Response: Agreed to required change.+ Section 9 Environmental designation site descriptions: Columbia River (south to north) is a Shoreline of Statewide Significance and is regulated under the SMP. Add the following at the beginning of the list of Lakes: Lakes listed here are shorelines of the state and are regulated under the SMP. Ecology Rationale: Required change for compliance with WAC 173-26-171(1) in order to regulate "shorelines" and "shorelines of the state" the waterbodies must be clearly classified as required by RCW 90.58.020(7). And as provided for in WA 173-22-050, as RSMP Section 9 becomes each jurisdiction's official list of regulated shorelines. Local Response: Agreed to required change. July 22, 2009 Page 19 EXHIBIT C Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee East Wenatchee On April 13, 2009, the City of East Wenatchee submitted a letter agreeing to some of Ecology's required changes to Appendices B, C, D & H, and proposing alternatives for others. Following is an account of the status of each required change. Appendix 13(5) Establish individual Restoration Goals and Policies for each city. Required change because individual Restoration Goals not identified as required by WAC 173- 26-186(8) (c) for counties and cities containing any shorelines with impaired ecological functions, master programs shall include goals and policies that provide for restoration of such impaired ecological functions Also found in WAC 173-26-201(2) (c). WAC 173-26-201(2) (0 AND; WAC 173-26-201(d)(i)(E), RCW 90.58.040, RCW 90.58.280, WAC 173-27-060 (3). Required change to comply with the above cited WACs. In communications regarding this change there seemed to be concerns over FERC regulated lands and PUD project development(s) arose, as well as identifying restoration opportunities that may be on private lands. PUD's are private entities operating either on their own lands or on public lands operating under a federal license. The city will have jurisdictional and regulatory authority for any non-federal projects that are proposed within their jurisdictional boundaries. Just like a privately owned parcel, any shoreline area that is owned or operated by the PUD means that you cannot go on to their private property and make them do restoration, but they may not develop that property without first coming to the city and requesting a project review. Any new I on -exempt development proposed by the any non-federal entity would need to comply with the SMP, SMP permitting and SMP mitigation requirements, which if on -site mitigation is not possible mitigation is derived straight from the restoration goals. Implementable regulations that would be applicable to PUD and other developments are noted below. As for restoration on private lands, identified goal such as `establishing riparian habitat' is a goal and any private or public entity could approach a private owner and initiate a discussion about riparian enhancement, the decision would still be up to the private landowner. If individual city restoration goals and policies are established, there is at least possibility of a net increase in the ecological functions and values of the shorelines. Local Response: Proposed Alternative Language (see below). Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee Add the following language: Page 1, B.1 Introduction in paragraph 3, first sentence. Change to read: This Plan establishes a restoration goal, objectives, and policy priorities to actively encourage and facilitate restoration in the county and cities. Page 16, B.5, the 3rd bullet in the "Policies" section. Change to read: The county and cities shall seek funding from state, federal, private and other sources to implement restoration, enhancement, and acquisition projects. Ecology approves the proposed alternative. Appendix C2, page 4, 3rd paragraph "The industrial activities are currently occurring are !a inside the old silicon plant and related facilities. ' , aMetrgThere is extensive shoreline alteration onsite." Ecology Rationale: Required change because a public commenter twice requested that this information be corrected establishing a current use of the site. Local Response: Agreed to required change. Appendix D In addition to project monitoring required for individual restoration and/or mitigation projects, the cities and the county should conduct system -wide monitoring of shoreline conditions and development activity, to the degree practical, recognizing that individual project monitoring does not provide an assessment of overall shoreline ecological health. The following three -prong approach shall be used: Ecology Rationale: The Ecology grant agreement with Douglas County Task 5.4 — Monitoring Program states —The participating jurisdiction will draft a program for monitoring shoreline activities, compliance with the SAWSMP and effectiveness of the SMP in achieving adopted goals. This Grant requirement was placed to meet the requirements of WAC 173-26-191-(2) (iii) (D) July 22, 2009 Page 64 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee Ecology presented two options to the City East Wenatchee: 1) Accept Ecology's required change and use the monitoring plan as in Appendix D; or 2) Develop a monitoring plan of their own. East Wenatchee chose to accept the above language change rather than developing a different monitoring plan for Appendix D. Appendix H.3 Section 1.035 Insert Section 1.035: Trails and trail -related facilities. Construction of commercial, public and private trails and trail -related facilities, such as picnic tables, benches, interpretive centers and signs, viewing platforms and campsites may be authorized within designated resource lands and critical areas, subject to the following minimum standards: A. Trail facilities shall, to the extent feasible, be placed on existingrad grades, utility corridors, or an, offer previously disturbed areas; B. Trail facilities shall minimize the removal of trees, shrubs, snags and important habitat features. Vegetation managementperformed in accordance with best managementpractices as part of ongoing maintenance to eliminate a hazard to trail users is considered consistent with this standard; C. Viewing platforms, interpretive centers, campsites, picnic areas, benches and their associated access shall be designed and located to minimize disturbance of wildlife and/or critical characteristics of the affected conservation area; D. All facilities shall be constructed with materials complementary to the surrounding environment; E. Trail facilities that parallel the shoreline may be located in the outer 25 percent of the buffer area; and, a. Commercial and Public trails shall not exceed 10 feet in width b. Private trails shall not exceed 4 feet in width, F. Trails that provide direct shoreline access shall not exceed 4 feet, or as allowed in Section 1 C.060(D), in width and shall be kept to the minimum number necessary to serve the intended purpose; and G. Review and analysis of a proposed trail facility shall demonstrate no net loss of ecological functions and values in conformance with this chapter. H. Trail facilities shall not be exempt from special report requirements, as may be required by this chapter. T„lxr 11 ')nno pacrA 4r% Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee Ecology Rationale: Required for compliance with: 173-26-211(5) (b) (ii) (A), 173-26- 211(5) (b) (ii) (D), 173-26-211(5) (b) (ii) (E), 173-26-221(4) (d) (iii) (C) (vi&v), 173-26-221(5) (a), 173-26-221(5) (b), WAC 173-26-241(3) (j), WAC 173-26-241(3) (j). There is no scientific basis for intruding on more than the outer 25% of wetlands and critical habitat buffers. As worded, the East Wenatchee places no standard widths on public or private trails. This could lead to the removal of excess shoreline vegetation. The addition of this regulatory language allows the jurisdiction to allow trails within a buffer area to provide public access to the shoreline, while also providing developers language that results in dependability and providing vegetation conservation measures as provided for in WAC. Local Response: Proposed alternative language (see below). 1.035 Trails and trail -related facilities. Construction of commercial, public and private trails and trail -related facilities, such as picnic tables, benches, interpretive centers and signs, viewing platforms and campsites may be authorized within designated resource lands and critical areas, subject to the following minimum standards: 1. Trail facilities shall, to the extent feasible, be placed on existing road grades, utility corridors, or any other previously disturbed areas; 2. Trail facilities shall minimize the removal of trees, shrubs, snags and important habitat features. Vegetation management performed in accordance with best management practices as part of ongoing maintenance to eliminate a hazard to trail users is considered consistent with this standard; 3. Viewing platforms, interpretive centers, campsites, picnic areas, benches and their associated access shall be designed and located to minimize disturbance of wildlife and/or critical characteristics of the affected conservation area; 4. All facilities shall be constructed with materials complementary to the surrounding environment; 5. Trail facilities that parallel the shoreline may be located in the outer 25 percent of the buffer area; and, a. The width of commercial and public trails shall be consistent with Section 1020.06(l) of the Washington State Department of Transportation Design Manual, as amended. b. Private trails shall not exceed 4 feet in width; 6. Except as provided in D.5 above, the width of commercial and public trails shall be consistent with Section 1020.06(1) of the Washington State Design Manual as in now exists or may hereafter be amended. 7. Trails that provide direct shoreline access shall not exceed 4 feet in width and shall be kept to the minimum number necessary to serve the intended purpose; and Julv 22.2009 Paize 66 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee 8. Review and analysis of a proposed trail facility shall demonstrate no net loss of ecological functions and values in conformance with this chapter. 9. Trail facilities shall not be exempt from special report requirements, as may be required by this chapter. " Ecology approves the proposed alternative. Section 1 B.033(C) Type I Wetlands. Activities and uses shall be prohibited in Type I wetlands, except as provided for in the public agency and utility exemptions, reasenable use , and variances sections of this Chapter. Persons seeking relief from the bulk and dimensional standards as set forth in the RSMP and Critical Area Regulations shall seek relief through the Conditional Use or Variance Permit Process set up in RSMP. Ecology Rationale: Required for intent and compliance RCW 90.58. 100(5) The SM4 and corresponding guidelines authorize conditional use and variance permits to ensure that strict implementation of a given master program will not create unnecessary hardships. The SMA makes no other specific `reasonable use' related provisions. Compliance with WAC 173-27-160 The -purpose of a conditional use permit is to provide a system within the master program which allows flexibility in the application of use regulations in a manner consistent with the policies of RCW 90.58.020. In authorizing a conditional use, special conditions may be attached to the permit by local government or the department to prevent undesirable effects of the proposed use and/or to assure consistency of the project with the act and the local master program. Compliance with WAC 173-27-170 The purpose of a variance permit is strictly limited to granting relief from specific bulk, dimensional or performance standards set forth in the applicable master program where there are extraordinary circumstances relating to the physical character or configuration of property such that the strict implementation of the master program will impose unnecessary hardships on the applicant or thwart the policies set forth in RCW 90.58.020. Local Response: Agreed to required change. T„ixi T) ')M4 Pa Ore 67 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee Section 1 B.050(B)(1) The width of a wetland buffer, as measured from the wetland edge established in the approved wetland boundary survey, shall be as follows: Wetland Type Low — Moderate Intensity Dev. High Intensity Development* Wetland Type 1 150 feet. 250 feet Wetland Type 2 100 feet 200 feet Wetland Type 3 75 feet 150 feet Wetland Type 4 50 feet 50 feet * For the purposes of Section 2.05013 of Appendix H. high intensity uses include: commercial, urban, industrial, institutional, retail sales, residential (more than 1 unit/acre), conversion from non-agricultural lands to high-intensit agriculture (dairies, nurseries and green houses, raising and harvesting of crops requiring annual tilling, raising and maintaining , animals , and high -intensity recreation (golf courses, ball fields). Low -moderate intensity development shall consist of development that does not meet the above description of high intensity development. Ecology rationale: Changes required to meet WA 173-26-201 (2) (a) using technical documents from Ecology. While this buffer size is the buffer size of the most currently adopted Critical Areas Ordinance (CAO), the last update to the City of East Wenatchee's Critical Areas Ordinance did not use Ecology's published guidance on wetland protection based on the best available science (Wetlands in Washington State, Volume 2: Managing and Protecting Wetlands, April 2005). This new guidance, along with the revised Washington State Wetland Rating System for Eastern Washington (August 2004), establishes buffer widths based on the wetland category, the intensity of the adjacent land use, and the functions provided by the wetland. This approach, referred to as "Alternative 3, "provides both flexibility for the City and predictability for applicants. Tu1v 22. 2009 Page 68 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee The wetland buffers in the current draft are too small to protect many wildlife functions from high intensity development (HID), based on Ecology's review of the best available science. While language in this section of the proposed ordinance allows the director the discretion to increase the buffers to accommodate impacts from HID, it is not mandated, and that is an unpredictable element for the land developer. Golf courses, ballfields, hobby farms, residential development at a density of more than one unit per acre, commercial ventures, parking lots, etc., are considered high density development. Many shoreline lots have been previously platted and in effect develop the landscape at a greater density than one residential dwelling per one acre. Therefore, it is extremely likely that high intensity development will be proposed routinely along the shorelines and in other locations. If a one -size -fits -all buffer strategy will be used in the ordinance, the buffer widths must be wide enough to provide certainty that wetland functions will be protected from high impact uses. This revision of the wetland buffer sizes ensures that the City is using the most current, accurate, and complete scientific and technical information available to protect its wetland resources. Ecology's guidance documents are viewed as "technical assistance materials produced by the department. " As WAC 173-26-201(2) goes on to state, "When relevant information is available and unless there is more current or specific information available, those technical assistance materials shall constitute an element of scientific and technical information as defined in these guidelines and the use of which is required by the act. " These wetland and wetland buffers and. mitigation ratios can be found in Washington State Wetland Rating System for Eastern Washington (August 2004), Appendix 8-C and Appendix 8-D. Local Proposed Alternative (see below). Section 1 B.050(B)(1) The width of a wetland buffer, as measured from the wetland edge established in the approved wetland boundary survey, shall be as follows: Category of Wetland Widths of Buffers I .250 feet II 200 feet III 150 feet IV 50 feet Julv 22. 2009 Nee 69 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee Ecology approves the proposed alternative. Section 1 B.050(C). Increased buffer widths. The width of the buffer shall be increased by the review authority for a development project on a case -by -case basis when a larger buffer is necessary to protect the designated wetland function and value. Ecology Rationale: Required change to meet the no net loss standard of SMA and corresponding guidelines. If functions and values of wetland would be lost due to not increasing buffer, then the administrator shall increase the buffer. Local Response: Agreed to required change. Section 1B.050(C)(3) Ecology rationale: Required change because high intensity uses are addressed in required changes of Section 1 B. 050(B) (1). Local Response: Disagreed with required change. Proposed keeping original language. Rationale: This section lists the criteria for increasing buffer widths when certain criteria are present. Since Ecology is changing the "may" to "shall" in this section (see above) it also seems appropriate to leave the reference to "high intensity land uses" since those types of land uses would seem to be the most appropriate instances when it would be necessary to require an increase in the buffer width. Ecology approves of maintaining the original language in Section 1 B.050(C)(3) based on the City's reasoning and that the City accepting a larger buffer size for all development in Section 1 B.050(B)(1) . Tuly 22. 2009 Pa ore 70 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee Section 1 B.060 Add Regulation #C: Water dependant uses, as defined by this Program, may be located within a wetland or wetland buffer when the applicant or property owner can demonstrate compliance with Section 1.10 A.080 of Appendix H. Developments authorized within a wetland buffer shall comply with the following minimum standards: a. Designated wetlands and their associated buffers shall be delineated and disclosed on final plats_, maps, documents, etc., as critical area tracts, non buildable lots, buffer areas or common areas. Ownership and control may be transferred to a homeowner's association or designated as an easement or covenant encumbering the property. b. All lots within a major subdivision, short plat or binding site plan shall have the outer edge of all required buffers clearly marked on site with permanent buffer edge markers. Buffer markers may be either buffer signs or steel posts painted with a standard color and label, as approved by the Administrator. The markers shall be field verified by the surveyor or biologist of record prior to final plat approval. Each lot shall contain a minimum of three buffer area markers located at the landward edge of the buffer perimeter for each habitat type; one located at each side property line and one midway between side property lines. Covenants for the subdivision shall incorporate a requirement stating that buffer area markers shall not be removed, or relocated, except as a may be gpproved by the Administrator. Ecology rationale: Required change to clarify that water dependent uses are allowed and preferred use within shoreline areas as provided for in the SMA, provided the applicant follows appropriate mitigation sequencing so as to result in not net loss of shoreline functions and values. RCW 90.58 and WAC 173-26. Local Response: Accepted the required change to Section 1 B.060 (Add Regulation #C), but noted an incorrect regulatory reference on Ecology's part (see below). Section 1B.060 (Add Regulation #C) Water dependant uses, as defined by this Program, may be located within a wetland or wetland buffer when the applicant or property owner can demonstrate compliance with Section 1B.035 of Appendix H. July 22.2009 Page 71 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee Developments authorized within a wetland buffer shall comply with the following minimum standards: a. Designated wetlands and their associated buffers shall be delineated and disclosed on final plats, maps, documents, etc., as critical area tracts, non buildable lots, buffer areas or common areas. Ownership and control may be transferred to a homeowner's association or designated as an easement or covenant encumbering the property. b. All lots within a major subdivision, short plat or binding site plan shall have the outer edge of all required buffers clearly marked on site with permanent buffer edge markers. Buffer markers may be either buffer signs or steel posts painted with a standard color and label, as approved by the Administrator. The markers shall be field verified by the surveyor or biologist of record prior to final plat approval. Each lot shall contain a minimum of three buffer area markers located at the landward edge of the buffer perimeter for each habitat type; one located at each side property line and one midway between side property lines. Covenants for the subdivision shall incorporate a requirement stating that buffer area markers shall not be removed, or relocated, except as a may be approved by the Administrator. Ecology Response: Ecology approves, and appreciates, the correct regulatory reference insertion. Section 1 C.037(G) The onsite mitigation ratio shall be at a minimum ratio of 1:1 (mitigation amount : disturbed area). Ecology Rationale: Change for clarity. Required mitigation amount is an "area" based equation (i.e. I sq. ft: 1 sq. ft�. Local Response: Agreed to required change. Section 1 C.050(C)(1) All buffers shall be measured from the habitat edge, as established by the approved habitat boundary survey. If no riparian habitat or its edge cannot be located, the buffers shall be measured from the OHWM. July 22. 2009 Page 72 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee Ecology Rationale: Change for clarity. Buffers are to be measured from habitat edge, if no riparian habitat exists on a site due to site characteristics unique to that site or due to previous disturbance (not a violation) this provides developers a known spot to measure from. Local Response: Agreed to required change. Section 1C.060 (add Regulation #B) Water dependant uses, as defined by this Program, may be located within a habitat conservation area or buffer when the applicant or property owner can demonstrate compliance with Section 1 C.037 of Appendix H. A. C. Developments authorized within ... Ecology Rationale: Both are required change to clarify that water dependent uses are allowed and preferred use within shoreline areas as provided for in the SMA, provided the applicant follows appropriate mitigation sequencing so as to result in not net loss of shoreline functions and values. RCW 90.58 and WAC 173-26. Re -letter section for clarity. Local Response: Agreed to required change. Section 1 C.060 (D) Strike Section , OR Incorporate Edits Section 1 C.060 (D ) Shoreline Restoration/Enhancement & Shoreline Access. Shoreline restoration/enhancement of degraded or limited function shoreline areas shall be encouraged consistent with the Douglas County Shoreline Restoration Plan, ... The access corridor and restoration/enhancement opportunity provided in this Section applies only to that portion of the shoreline zone that falls within the riparian buffer. ... Shoreline restoration/enhancement and access plans must address the following standards and provide the following application materials: 1) A Fish/Wildlife Habitat Management and Mitigation Plan shall be prepared pursuant to 1 C.037 for the access corridor and restoration/enhancement plan. The mitigation plan Tnly').?._ 7009 Page 73 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee shall demonstrate that the proposed restoration/enhancement plan shall result in a net increase in function of the shoreline. 2) Where consistent with the provisions of this Chapter, one single access corridor per lot within the buffer may be permitted through the implementation of a restoration/enhancement plan. Multiple access points, whether existing or proposed, shall not be permitted by this Section. The restoration/enhancement plan wetild shall provide mitigation for the installation of the access corridor (1av ,., gr-aa es)within the buffer. .. . 3) The access corridor and restoration/enhancement may only be implemented along shorelines where the existing function of the shoreline will not be decreased and the implementation of the restoration/enhancement plan would result in a net increase in function. This provision is limited to ineludes low functioning disturbed shoreline as well as low F9ffiget.i.flifig , ,that„ ffbe _sh rol;r,oc, that can be significantly improved by the implementation of a restoration/enhancement plan consisting of trees, shrubs and groundcover. ... 4) ... The installation of an access corridor and restoration/enhancement action shall avoid removing native vegetation, which shall be maintained and incorporated into the restoration/enhancement planting plan. Developed shoreline restoration/enhancement & access sites approved pursuant to this EWMC, are not eligible for view corridor provisions identified in EWMC 18.12C.060F (Correct code reference?). >>1 C.060(C)?. 5) ... no changes made/required 6) Working from the ordingU high water mark (OHWM) toward the landward edgeof the required buffer(s) found in Section 3.050 the followingshall hall apply: a. The access corridor width shall be limited to a maximum of four (4) feet within the first twen -five percent (25%) of the required buffer as measured OHWM, this area of the access corridor shall consist of native grasses or crushed rock. b. The use of pesticides and fertilizers shall not be permitted within 50 ft of the OHWM. The width of the access corridor may be tapered from 4ft up to a width of 10 ft within the first 25-174onext landward 50% of the r4parian-buffer, ,.,. east , ed !az,,awar-,a of the er-dinar-y high water mark ef the shoreline of the stfl�eet pr-epeA . The intent is for the shoreline restoration design to provide for significant blocks of habitat in close proximity to the shoreline; avoiding areas of existing native vegetation; and tapering use areas from a narrow access corridor at the OHWM to 4-the widest point located at the most tie landward edge of the buffer area. Where it is not feasible to avoid existing vegetation, the access corridor shall be limited to four 4 feet '' in width. er-e the aeeess path has been ex4eiided +1,, ettgl, exis ngyegetati , the This portion of the access path shall also consist of native grasses or crushed rock. c. The most landward twenty-five 25%) percent edge of the require buffer may include lawn grass, but applicants are encouraged to consider the use of native grass. Where lawn grass is planted in the access corridor area, measures shall be included to preclude the spread of the lawn grass into the restoration/enhancement areas or offsite to ad' o� ining buffer areas. Insert Illustration T„lv ?? ?009 Page 74 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee - -: - : : . :- :- WN :: .M -.:. - ffetus 7) No structures shall be constructed within the access corridor or buffer areas lawn grass. L Native grasses may extend to within 5 feet of the ordinary high water mark, as long as it can be installed in such a manner that prevents erosion. . The tise of pest;eides and feAifizer-s shall net be pei=fnitted within 50 feet of the erdinai=y high water- mark. 8) Mitigation (restoration/enhancement plan) for the access corridor shall be provided through the planting of native vegetation within the buffer. The area of the buffer that shall be available for the access corridor and the restoration/enhancement area shall be that area that is devoid of native vegetation or significant non-native trees or shrubs which provide habitat functions. Within this area that is devoid of native vegetation, the ratio of mitigation for installation of native grasses shall be 1.1, the ratio of mitigation to lawn grass shall be 2:1, the mitigation ratio for those areas where riparian or shrub steppe vegetation is removed shall be 2:1. In most cases the access corridor and the restoration plan shall not encompass the entire buffer, as some native riparian and shrub steppe species occur on most properties.... 9) no changes made/required 10) Areas designated for restoration/enhancement shall be cleared and grubbed and deconsolidated to a depth of at least 10 inches. Clearing and grubbing is defined as the removal of plant material, including the roots, which entails minimal ground disturbance. Restoration/enhancement areas soils shall be tested prior to planting to determine if soil amendments will be required. ... 11) Native planting within the restoration/enhancement area shall be planted with trees (spaced 10 feet on center), shrubs (spaced 3-5 feet on center based on shrub size) and groundcover (grasses, forbs, etc). The restoration/enhancement plan must contain all three layers of vegetation and include both riparian and shrub steppe species. 12) Species composition shall be determined based on the size of the restoration/enhancement area. For areas less than 500 square feet a minimum of 2 species of trees and 4 species of shrubs shall be installed. ... 13) ... no changes made/required 14) ... no changes made/required. Ecology rationale: Changes required for compliance with WAC: 173-26-211(5) (b) (ii) (A), 173- 26-211(5) (b) (ii) (D), 173-26-211(5) (b) (ii) (E), 173-26-221(4) (d) (iii) (C) (vi&v), 173-26-221(5) (a), 173-26-221(5) (b), WAC 173-26-241(3) (j), WAC 173-26-241(3) (j) and 173-26-201(2) (a) incorporation and use of the most current technical and scientific information. Upland habitat and Riparian areas and their established buffers are used to protect the ecological processes and functions performed by the habitat conservation area. Large areas of lawn grass fragments the T„Ax. 11 ')nno PaaP 75 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee vegetative corridor and thereby decreases the functions such as water quality improvement, riparian growths ability to stabilize banks thereby minimizing erosion, decreases ease of species movement, decreases nesting & breeding habitat, decrease in the amount of various insects and other benthic macro -invertebrates. Fragmenting the vegetative corridor decreases the functions such as water quality improvement, riparian growths ability to stabilize banks thereby minimizing erosion, increase ease of species movement, nesting & breeding habitat, food web via providing food in the form of various insects and other benthic macro -invertebrates. Ecology is thereby reducing the width of the access corridors (10 feet down to 4 feet) from residential development down to the shoreline in order to decrease fragmentation of shoreline vegetation thereby protecting the ecological processes and functions these areas offer, while trying to incorporate the wishes of local citizenry and local government to promote shoreline access yet still incorporating restoration goals. One of the reasons for this is when joint use docks are proposed, often home owners combine their currently allowed access paths (4ft.) to create an 8 foot wide path down to the water along the shared lot line. If the proposed ten (10) foot access plan were left in place a twenty 20 foot wide access path (10 on each side of the shared lot line) could occur. Which would, thereby increase vegetative fragmentation greater than what is currently permitted/allowed. Ecology is also limiting the term "Lawn" or "lawn grass"for two. reasons. First, Lawn/turf grasses native to Europe and Asia require double or triple the amount of precipitation than occurs in the arid region of Douglas County. The practice of installing "Kentucky bluegrass" strains puts unnecessary strain on limited water resources. Synthetic fertilizers and pesticides used to keep the grass green and weed free degrade water quality and harm non -target animals and plants. Ecology has replaced the term with "Native grasses'. Ecology has supplied a list of native grasses and sedges with hyperlinks below. The second reason Ecology has replaced the connotation of "lawn " in the buffer areas is the Ecology regulatory requirement of RCW 90.44.050, which exempts domestic wells from the permitting process, but places limits of withdrawal of public groundwaters for stock -watering purposes, or for the watering of a lawn or of a noncommercial garden not exceeding one-half acre in area, or for single or group domestic uses in an amount not exceeding five thousand gallons a day. Placing "lawn" which requires greater amounts of water than the climate of Douglas county provides taxes the water resources of Washington state. The installation of native grasses which require less water fits the no net loss requirements of the SMA. Ecology appreciates the incorporation of access areas, not restricting some uses is one of the principles granted by WAC 173-26-221(5) (b), and appreciates that restoration opportunities are providing for a varied plant species composition. Native Grasses and Sedges which seed can be blended to create a lawn -like planting of indigenous species while eliminating the need to apply fertilizer regularly, mow every week, and use herbicides. Lawns of nonnative species interrupt the natural landscape, breaking up the continuum of native habitats and contributing to the loss of biodiversity. The difference is creating a landscape that is sustainable. July 22. 2009 Page 76 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee WAC 173-26-221(5)(b) Current scientific evidence indicates that the length, width, and species composition of a shoreline vegetation community contribute substantively to the aquatic ecological functions. Likewise, the biota within the aquatic environment is essential to ecological functions of the adjacent upland vegetation. The ability of vegetated areas to provide critical ecological functions diminishes as the length and width of the vegetated area along shorelines is reduced. When shoreline vegetation is removed, the narrower the area of remaining vegetation, the greater the risk that the functions will not be performed. Local governments should identify which ecological processes and functions are important to the local aquatic and terrestrial ecology and conserve sufficient vegetation to maintain them. Such vegetation conservation areas are not necessarily intended to be closed to use and development but should provide for management of vegetation in a manner adequate to assure no net loss of shoreline ecological functions. Local Response: Accepted required changes, but made a few corrections to errors, and Ecology made some minor corrections too. (Both parties' corrections are reflected below.) Revised and corrected language: Section 1C.060(D) - Shoreline Restoration/Enhancement & Shoreline Access. Shoreline restoration/enhancement of degraded or limited function shoreline areas shall be encouraged consistent with the Douglas County Shoreline Restoration Plan, Appendix B. Where appropriate, opportunities for enhanced shoreline access, use and enjoyment may be offered as incentives to shoreline property owners to restore or enhance the functions of shoreline habitat. Access corridors provide physical access to the shoreline and water. The access corridor and restoration/enhancement opportunity provided in this Section applies only to that portion of the shoreline zone that falls within the riparian buffer. The application of this Section is to limited functioning shorelines and is not appropriate for shorelines with diverse habitat or functions. Shoreline restoration/enhancement and access plans must address the following standards and provide the following application materials: 1) A Fish/Wildlife Habitat Management and Mitigation Plan shall be prepared pursuant to 1C.037 for the access corridor and restoration/enhancement plan. The mitigation plan shall demonstrate that the proposed restoration/enhancement plan shall result in a net increase in function of the shoreline. 2) Where consistent with the provisions of this Chapter, one single access corridor per lot within the buffer may be permitted through the implementation of a restoration/enhancement plan. Multiple access points, whether existing or proposed, shall not be permitted by this Section. The restoration/enhancement plan shall provide Tnly 77_ 7009 Page 77 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee mitigation for the installation of the access corridor within the buffer. The access corridor shall be installed in such a manner that prevents erosion and results in no net loss of functions and values of the shoreline. 3) The access corridor and restoration/enhancement may only be implemented along shorelines where the existing function of the shoreline will not be decreased and the implementation of the restoration/enhancement plan would result in a net increase in function. This provision includes disturbed shoreline as well as low -functioning undisturbed shorelines that can be significantly improved by the implementation of a restoration/enhancement plan consisting of trees, shrubs and groundcover. This section El�is not appropriate for high functioning shorelines. 4) The access corridor shall be designed to provide access through the buffer to an area where an existing use occurs (docks, boatlifts, swim areas, etc). If no existing use is established, the access corridor shall take into account the existing native vegetation, shoreline slope, and any proposed uses (dock). The installation of an access corridor and restoration/enhancement action shall avoid removing native vegetation, which shall be maintained and incorporated into the restoration/enhancement planting plan. Developed shoreline restoration/enhancement & access sites approved pursuant to this section EWE, are not eligible for view corridor provisions identified in Section 1 C.060(C) or EWMC 18.12C.060F. 5) An access corridor shall be permitted at the same time as other shoreline permits whenever possible. 6) Working from the ordinary high water mark (OHWM) toward the landward edge of the required buffer(s) found in Section 1 C.050(B)(6) the following shall apply: a. The access corridor width shall be limited to a maximum of four (4) feet within the first twenty-five percent (25%) of the required buffer as measured OHWM, this area of the access corridor shall consist of native grasses or crushed rock. b. The use of pesticides and fertilizers shall not be permitted within 50 ft of the OHWM. The width of the access corridor shall be tapered from 4ft up to a width of 10 ft within the next 50% of the riparian buffer. The intent is for the shoreline restoration design to provide for significant blocks of habitat in close proximity to the shoreline; avoiding areas of existing native vegetation; and tapering use areas from a narrow access corridor at the OHWM to at the widest point located at the most to the landward edge of the buffer area. Where it is not feasible to avoid existing vegetation, the access corridor shall be limited to four (4) feet in width. The access path shall consist of native grasses or crushed rock. c. The most landward twenty-five (25%) percent edge of the require buffer may include lawn grass, but applicants are encouraged to consider the use of native grass. Where lawn grass is planted in the access corridor area, measures shall be included to preclude the spread of the lawn grass into the restoration/enhancement areas or offsite to adjoining buffer areas. 7) No structures shall be constructed within the access corridor or buffer areas. Native grasses may extend to within 5 feet of the ordinary high water mark, as long as it can be installed in such a manner that prevents erosion. 8) Mitigation (restoration/enhancement plan) for the access corridor shall be provided through the planting of native vegetation within the buffer. The area of the buffer that shall be available for the access corridor and the restoration/enhancement area shall be Julv 22.2009 Paiae 78 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee only that area that is devoid of native vegetation. Within this area that is devoid of native vegetation the ratio of mitigation to for installation of native grasses shall be 1:1, the ratio of installation of lawn grass shall be 2:1, the mitigation ratio for those areas where riparian or shrub steppe vegetation is removed shall be 2:1. In most cases the access corridor. and the restoration/enhancement plan shall not encompass the entire buffer, as some native riparian and shrub -steppe species occur on most properties. 9) Prior to work on the property, the biologist of record shall verify that the boundaries of disturbance have clearly been demarcated by silt fencing straw bales or other approved temporary erosion and sediment control device. Written verification from the biologist of record shall be required prior to work commencing. 10) Areas designated for restoration/enhancement shall be cleared and grubbed and deconsolidated to a depth of at least 10 inches. Clearing and grubbing is defined as the removal of plant material, including the roots, which entails minimal ground disturbance. Restoration/enhancement areas soils shall be tested prior to planting to determine if soil amendments will be required. Soil testing shall be verified by invoices from the installing contractor. Importing of gravel and/or soil amendments shall also be subject to approval from the Chelan County PUD, if such importing occurs waterward of the Exhibit G or K line. 11) Native planting within the restoration/enhancement area shall be planted with trees (spaced 10 feet on center), shrubs (spaced 3-5 feet on center based on shrub size) and groundcover (grasses, forbs, etc). The restoration/enhancement plan must contain all three layers of vegetation and include both riparian and shrub steppe species. 12) Species composition shall be determined based on the size of the restoration/enhancement area. For areas less than 500 square feet a minimum of 2 species of trees and 4 species of shrubs shall be installed. For areas between 500 and 2000 sq feet, a minimum of 3 species of trees and 6 species of shrubs shall be installed. For areas greater than 2000 square feet, a minimum of 4 species of trees and 8 species of shrubs shall be installed. 13) This section shall not be applied in the Natural Environment Designation. 14) Sites which had buffer widths reduced or modified, (buffer width averaging or administrative reduction), or by any prior action administered by the City shall not be eligible to use the provisions of this section. Sites which utilize this provision are not eligible for any future buffer width reductions under any provision of this Program, except as administered under Section 6.8 Variances, of this Program. Ecology Rationale: Ecology has added the underlined and highlighted words "Section IC 060C " to Section IC 060(D)(4). East Wenatchee noted in their April 13, 2009 letter in reference to Section IC 06O(D) (4) that the reference to EWMC 18.12C. 060 is a correct reference so that an applicant is only able to take advantage of one view corridor provision; one from the SMP or one from the City's Critical Area Provisions. Ecology's understanding was that that specific citation was so that only a single View Corridor or the Access corridor could be taken advantage of. Ecology has added the language "Section 1.C.060(C)" to clam this understanding. Julv 22.2009 Page 79 Douglas County RSMP Status Document Part 2.4 — Required Changes — East Wenatchee East Wenatchee agreed with Ecology's required changes to Section 1 C. 060(D), but made a reference in their response letter that the Section reference (Section 1 C. 060(D)) was incorrect. C. Case (ECI) placed a phone call to City planning staff Lori Barnett on 4122109 to ensure that Ecology had received the correct version of the RSMP Appendix, because in Ecology's version the section was I C. 060(D). Upon further inquiry Ms. Barnett found the section referenced by Ecology was correct. East Wenatchee also requested the above strikeout/underlined sections in IC.060(D)(3) and (D)(4) [EWMC' changed to `section') typographical errors be corrected from the version submitted to Ecology. The Native Grasses/Sedges list that was included in the written findings and conclusions was included only as curtsey to assist with the above changes by Ecology from the reference of "Lawn Grass" to native grass(es). Ecology needs written confirmation from the City that they accept the change to Section 1 C.060(D) by Ecology. Section 1 C.020(D) (Change requested by City) East Wenatchee requested the following typographical errors in the Appendix H.3 that was submitted to Ecology be corrected: Section 1C.020(D) - Identification and regulation of ephemeral or intermittent drainages which do not contain wetland or riparian habitat shall be in accordance with Chapter 1D - Critical Areas —Geologically Hazardous Areas and Chapter 15.44 15.48 EWMC - Flood Damage Prevention. Ecology approves the error correction. July 22, 2009 Page 80