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Home My WebLink About06242026 PC Regular Meeting Agenda PacketREGULAR MEETING AGENDA PLANNING COMMISSION June 24, 2026 6:00 - 8:00 PM Notice is hereby given that the Port Angeles Planning Commission will meet on Wednesday, June 24, 2026 located at 321 E. 5th Street, Port Angeles, WA. This meeting will be conducted as a hybrid meeting. In hybrid meetings, members of the public, Committee members, and City staff may attend in person at City Hall or remotely via the Webex virtual meeting platform. For those planning to attend remotely, learn how to watch the meeting live and participate during the public comment period by visiting: https://www.cityofpa.us/Live-Virtual-Meetings For audio only, please call: 1-844-992-4726 Use access code: 2554 635 3731 Webinar password: PC06242026 (72062420 when dialing from a phone or video system) Once connected, press *3 to raise your virtual hand if you wish to make a comment or public testimony. You will be notified when it is your turn to speak. This access code will work for the June 24, 2026 meeting only. If you are joining the meeting through the Webex link and wish to make a comment or provide public testimony, please use the “raise your hand” feature in Webex. You will be notified when it is your turn to speak. Virtual Webex Meeting Link: https://cityofpa.webex.com/cityofpa/j.php?MTID=m0d5beda4dfe932e1396f8c4a563a4e5f The meeting is open to the public. I.CALL TO ORDER II.ROLL CALL III.PUBLIC COMMENT IV. APPROVAL OF MINUTES Minutes of the May 27, 2026 Meeting V. ACTION/DISCUSSION ITEMS 1.Discussion: MCA 26-0090 Critical Areas Ordinance Update. Staff presentation and Planning Commission discussion of Phase 2 of the development code updates to Titles 11, 13, and 15 of the municipal code. VI.STAFF UPDATES 1.Monthly Customer Service Report 2. Monthly Type 0/OTC Report 3. Monthly 5290 Report 4. Monthly Affordable Housing Report 5.Monthly Natural Resources Verbal Report 6.Monthly Land Use and Permitting Verbal Report 7.Monthly Building Report VII.REPORTS OF COMMISSION MEMBERS VIII.PUBLIC COMMENT IX. ADJOURNMENT PLANNING COMMISSION MEETING Port Angeles, Washington May 27, 2026 This meeting was conducted as a hybrid meeting. CALL TO ORDER - REGULAR MEETING Chair Steiger called the regular meeting of the Port Angeles Planning Commission to order at 6:00 p.m. ROLL CALL Planning Commission Chair Steiger, Commissioners: Schorr, Mellema, Vogel, Vanderlugt. Members Absent: Vice Chair Kiedrowski Staff Present: Community and Economic Development Manager Shannen Cartmel, Planning Supervisor Ben Braudrick, Housing Administrator Jalyn Boado, Natural Resources and Grant Administrator Courtney Bornsworth, Licensing Administrator and Building Inspector Chris Jackson, and CED Tech II Triston Carlstrom. PUBLIC COMMENT John R., Resident, spoke about the 8th and Peabody driver’s license building. AGENDA ITEMS 1.Action Item: Approve the April 22, 2026, Minutes It was moved by Shorr and seconded by Vogel to: Approve the April 22, 2026, Planning Commission minutes. Motion carried 5-0 2.Action Item: Façade Grant 26-0001 Clallam County Genealogical Society. Staff gave the Planning Commission a presentation to review of façade grant proposal for a mural at the Clallam County Genealogical Society, 403 E 8th St, Port Angeles, WA 98362. It was moved by Shorr and seconded by Vanderlugt to: Motion to approve the façade grant award in the amount of $10,000 towards the rehabilitation of the façade of the building located at 403 E 8th St (Grant No. 26-0001). Motion carried 5-0. 3. Discussion: Critical Areas Ordinance Update. Staff introduction of Phase 2 of the development code updates to Titles 11, 13, and and 15 of the municipal code. The Planning Commission discussed the critical areas ordinance in broad terms and touched on areas for improvement. STAFF UPDATES Customer Service Report Community Development Technician II Carlstrom gave a brief update on the number of customer service interactions in April 2026. Planning Commission Meeting June 24, 2026 1 Page 2 of 2 CITY OF PORT ANGELES PLANNING COMMISSION – May 27, 2026 Monthly Type 0/Over the Counter Report Community Development Technician II Carlstrom reported that 125 over-the-counter permits have been issued to date. Monthly 5290 Report Licensing Administrator and Building Inspector Jackson gave a brief report on the 5290 permitting timelines for April 2026. Monthly Affordable Housing Report Housing Administrator Boado gave a brief update about affordable housing programs. A NICE grant of $21,000 and a Sales and Use Tax grant for affordable housing of $9,000 were awarded in April 2026. Monthly Natural Resources Report Natural Resources and Grant Administrator Bornsworth gave a verbal update on the downtown seaplane and float project Shoreline Substantial Development permit and SEPA checklist. Monthly Land Use Permitting and Economic Development Report Planning Supervisor Braudrick highlighted the newly developed economic development two-pager. Monthly Building Report Licensing Administrator and Building Inspector Jackson gave the April 2026 building report, which showed 42 building permits were issued. COMMISSION REPORTS Chair Steiger, No report. Commissioner Schorr, the Utility Adviso ry Commission, is working on redoing the Bonneville Power contract. Commissioner Vanderlugt, No report. Vice Chair Kiedrowski, absent. Commissioner Mellema, No report. Commissioner Vogel, what is happening on Marine Drive, and where is the cleanup happening? SECOND PUBLIC COMMENT John R., a resident, would like to be involved in the critical area ordinance update and be informed of the GIS mapping. A former staff member, during a prior environmental update, went above and beyond the state-mandated requirement, which is a concern. Expressed that the critical areas ordinance updates should follow the state-mandated updates. ADJOURNMENT Chair Steiger motioned to adjourn the meeting at 7:03 p.m. _____________________________________ _______________________________ Chair Steiger, Chair Jalyn Boado, Secretary Planning Commission Meeting June 24, 2026 2 MCA 26-0090 Phase 2 Fish and Wildlife Habitat Audit Memo Page 1 DATE: June 24, 2026 TO: Planning Commission FROM: Planning Division RE: Phase 2 Municipal Development Code Audit – Fish and Wildlife Habitat Analysis SUMMARY Existing Port Angeles Municipal Code (PAMC) Chapter 15.20 is reasonably strong at protecting individual habitat sites, but modern Washington Department of Fish and Wildlife (WDFW) Best Available Science (BAS) has shifted toward protecting ecological networks, connected populations, and landscape-scale ecosystem processes. That shift creates the most signiﬁcant and defensible gaps between Chapter 15.20 and current ﬁsh and wildlife habitat science. Table 1 provides an overview of the various environmental protections standards set by the Washington Department of Fish and Wildlife, speciﬁc to their Priority Habitats and Species (PHS) list. Through this analysis, existing code was evaluated for consistency with the BAS found in the WDFW Riparian Ecosystems, Volume 2: Management Recommendations. Topics that were rated as having “strong” consistency were present throughout existing code and will require minimum amendments to meet BAS requirements. No recommendations for next steps have been provided for items with strong consistency because no next steps are necessary. “Potential Deﬁciency” was identiﬁed as being present in existing code but may need some updates to meet BAS standards. “Moderate Deﬁciency” was identiﬁed as lacking in context and “signiﬁcant deﬁciency” was either missing entirely or was only mentioned but did not contain signiﬁcant protection standards for protection. This analysis will be the driving factor for targeting those deﬁciencies as described below, with heavy emphasis on the signiﬁcant and moderate deﬁciencies. Potential deﬁciencies will be addressed if needed, and those with strong consistency with BAS will be amended to improve clarity and readability if needed. Many of the topics identiﬁed under this analysis apply to protection standards that can be used for other critical areas, such as geologically hazardous areas and frequently ﬂooded areas as these areas frequently overlap in our region. Critical Aquifer Recharge Areas, while mentioned as an environmentally sensitive area in current regulation, have no development standards associated with them, and were not analyzed. Moving forward, if Planning Commission Meeting June 24, 2026 3 MCA 26-0090 Phase 2 Fish and Wildlife Habitat Audit Memo Page 2 Port Angeles chooses to shift towards utilizing groundwater as a potable water source, it would be wise to include development standards and protection of these areas in this code update. Table 1: Gap Analysis by Environmental Protection Consideration | Source – WDFW Riparian Ecosystems, Vol. 2 Management Recommendations. HABITAT CONNECTIVITY, WILDLIFE CORRIDORS, AND LANDSCAPE SCALE CONSERVATION Analysis: One of WDFW's most explicit planning priorities is maintaining viable, connected populations over the long term through habitat and wildlife connectivity. WDFW's PHS program treats connectivity as a foundational conservation principle rather than an optional consideration. Chapter 15.20 currently recognizes: • ﬁsh habitat, • wildlife habitat, Environmental Topics BAS Consistency Observation Priority Species Protection Strong Present Protection Potential Deﬁciency Present Signiﬁcant Deﬁciency Core BAS Principle Signiﬁcant Deﬁciency Core BAS Principle Conservation Signiﬁcant Deﬁciency Core BAS Principle Moderate Deﬁciency Explicit Goal Protection Potential Deﬁciency Special Consideration Required Moderate Deﬁciency Increasing BAS Emphasis Potential Deﬁciency Recommended Signiﬁcant Deﬁciency Increasingly Incorporated in newly adopted CAOs Planning Commission Meeting June 24, 2026 4 MCA 26-0090 Phase 2 Fish and Wildlife Habitat Audit Memo Page 3 • stream corridors, • riparian habitat, • priority species habitat. The code primarily protects habitat as discrete sites with no requirements to evaluate: • corridor function, • habitat linkage areas, • wildlife movement pathways, • fragmentation effects, • migration routes, • dispersal corridors, • breeding movement pathways, • connectivity between habitat patches, • landscape permeability. Deﬁciency or Concern: This is the largest BAS gap in the entire chapter, as it relates to multiple management strategies and protection standards. Current environmentally sensitive area provisions protect habitat patches but lacks standards for identifying, maintaining, or restoring habitat connectivity necessary to support viable wildlife populations and movement across the landscape. The objective is to maintain functioning ecological systems rather than isolated habitat fragments. Chapter 15.20 PAMC largely assumes habitat can be protected by protecting the immediate site. Modern BAS indicates that many species decline even when habitat patches remain intact if movement pathways are severed. The chapter does not provide regulatory mechanisms for preserving wildlife movement corridors despite substantial scientiﬁc evidence that connectivity is necessary for long-term population persistence. Recommendations: Suggested edits would include the development of a monitoring and adaptive management program to ensure goals, policies and regulations are effectively protecting these areas. The establishment of a monitoring system would allow the City to better determine if protection standards lead to habitat connectivity and wildlife corridor preservation in the long-term. Systems need to be viewed as a whole rather than fragmented across the landscape, and development standards need to be updated to reﬂect the BAS as provided by WDFW. Wildlife corridors are closely related to habitat connectivity. The proposed code could reference the Washington Habitat Connectivity Action Plan to ﬁnd speciﬁc recommendations for improving connectivity across the landscape. Planning Commission Meeting June 24, 2026 5 MCA 26-0090 Phase 2 Fish and Wildlife Habitat Audit Memo Page 4 Landscape-scale protection measures should incorporate full protection within one SPTH, identiﬁed using the site potential tree height (SPTH) mapping tool. This will protect Riparian Management Zones at the landscape scale, rather than on a parcel-by-parcel level, even if applications are reviewed on a parcel level. Additional recommendations for landscape- scale habitat conservation should utilize the Washington Habitat Connectivity Action Plan. While the City of Port Angeles alone may be too small to consider Landscape-Scale Habitat Conservation, efforts should be made to think about how the City connects to the UGA, and therefore the County, as well as the proximity to the landscape to the South (Olympic National Park). POPULATION VIABILITY Analysis: A major objective of the Priority Habitat Species program is maintaining healthy populations over time rather than simply preventing local habitat destruction. WDFW explicitly references maintaining or enhancing populations within current and historic ranges. The ordinance protects habitat but does not appear to require evaluation of whether: • local populations remain viable, • breeding populations remain connected, • cumulative habitat loss threatens population persistence. Deﬁciency or Concern: Habitat protection is treated as an end in itself rather than a means of sustaining populations. Chapter 15.20 PAMC lacks mechanisms for evaluating whether habitat protection results in viable populations of ﬁsh and wildlife. Recommendations: The establishment of a monitoring and adaptive management program would allow the City to evaluate whether the protection measures established are sufficient to maintain viable ﬁsh and wildlife populations over the long term. Without a monitoring program, there is no way to track viable populations. This would be a good opportunity to partner with local organizations who focus on habitat recovery in our region, as many of them already have monitoring programs in place. RIPARIAN HABITAT PROTECTION Analysis: Modern WDFW science views riparian habitat as ecological systems rather than simply stream buffers and places enormous emphasis on riparian functions such as: • shade, • large woody debris recruitment, • nutrient inputs, • bank stability, Planning Commission Meeting June 24, 2026 6 MCA 26-0090 Phase 2 Fish and Wildlife Habitat Audit Memo Page 5 • ﬂoodplain interaction, • wildlife movement. Chapter 15.20 PAMC contains protective guidance regarding: • stream temperature, • sedimentation, • woody debris recruitment, • streambank stability, • aquatic habitat. Deﬁciency or Concern: The code recognizes riparian functions but does not fully incorporate more recent riparian ecosystem science emphasizing: • ﬂoodplain connectivity, • riparian ecosystem processes, • site-potential tree height concepts, • watershed-scale function. Riparian protections generally align with BAS but do not fully incorporate modern riparian ecosystem management approaches developed since ordinance adoption. Recommendations: Protection standards will need to be updated to reﬂect BAS, speciﬁcally for maintaining riparian ecosystem processes using SPTH. This science can be applied to multiple critical areas protection standards, including geologically hazardous areas, ﬁsh and wildlife habitat conservation areas, and critical aquifer recharge areas. Full protection within one SPTH as determined by using the SPTH mapping tool is recommended. The City’s GIS layers will be updated through implementation to align with the SPTH map, primarily for ﬁsh and wildlife habitat conservation areas, and geologically hazardous areas, as the two generally overlap. ANADROMOUS FISH Analysis: Under the Growth Management Act, local governments must give special consideration to habitat associated with anadromous ﬁsheries. WDFW repeatedly emphasizes salmonid habitat protection. The chapter contains extensive ﬁndings regarding: • spawning habitat, • ﬁsh eggs, • stream temperatures, • sedimentation, • aquatic habitat. Planning Commission Meeting June 24, 2026 7 MCA 26-0090 Phase 2 Fish and Wildlife Habitat Audit Memo Page 6 Deﬁciency or Concern: The code generally addresses salmonid concerns but predates many advances in salmon recovery science and recognizes salmonid habitat functions in the ﬁndings of the chapter. It does not fully incorporate current watershed-based salmon recovery strategies. Recommendations: Anadromous ﬁsh habitat includes the nearshore marine ecosystem, Port Angeles Harbor, and the six urban stream corridors found within the City. The protection and enhancement of these areas will involve incorporating management practices for anadromous ﬁsh habitat to be pulled from the WDFW Riparian Ecosystems, Volume 2: Management Recommendations. No net loss of ecological functions or values will be the foundational pillar for determining which management practices are included in development standards for all ﬁsh and wildlife habitat conservation areas, including habitat for anadromous ﬁsh. CUMULATIVE IMPACTS Analysis: Modern habitat science increasingly recognizes cumulative degradation as a major driver of species decline. The current ordinance is largely permit- and project-based with little evidence for requirements for: • cumulative habitat accounting, • cumulative fragmentation analysis, • watershed-level degradation assessments. Deﬁciency or Concern: The ordinance lacks procedures for evaluating cumulative habitat losses and fragmentation effects resulting from multiple development actions over time. Recommendations: Through the development of a monitoring and adaptive management program, the City will be able to better manage for the cumulative effects of habitat degradation and protection. Noting that fragmented landscapes lead to cumulative habitat loss, the best way to monitor the efforts of critical areas protection is through a monitoring and adaptive management program. Adaptive management relies on scientiﬁc methods to evaluate how well regulatory and nonregulatory actions achieve their objectives, and adjusts those programs accordingly. CLIMATE RESILIENCE Analysis: Although not prominent in the original PHS manuals, current WDFW conservation planning increasingly considers: • climate adaptation, Planning Commission Meeting June 24, 2026 8 MCA 26-0090 Phase 2 Fish and Wildlife Habitat Audit Memo Page 7 • shifting species distributions, • drought impacts, • thermal refugia, • resilience corridors. There is currently no mention or guidance on climate resiliency, hazard mitigation or adaptation provisions in Chapter 15.20 PAMC. Deﬁciency or Concern: The ordinance predates the City’s current Climate Resiliency Implementation Plan. The ordinance does not address climate-driven changes in habitat conditions, species distributions, hydrology, or ecosystem resilience. Recommendations: Incorporate climate-related speciﬁcs in the ﬁndings and purpose of the chapter. These can be pulled from the Climate Resiliency Action Plan as well as the Climate Resiliency and Hazard Mitigation Element of the 2025 Comprehensive Plan. Management strategies should also reﬂect BAS to protect and restore ecosystems to increase the resilience of species, habitats, and communities to climate change. Guidance from the Department of Commerce on Climate Resiliency efforts should be incorporated into the regulations and standards to ensure concurrency with long range environmental planning efforts. References: WA Department of Fish and Wildlife Riparian Ecosystems, Volume 1: Science Synthesis and Management Implications (https://wdfw.wa.gov/sites/default/ﬁles/publications/01987/wdfw01987.pdf) WA Department of Fish and Wildlife Riparian Ecosystems, Volume 2: Management Recommendations (https://wdfw.wa.gov/sites/default/ﬁles/publications/01988/wdfw01988.pdf) WA Department of Transportation and WA Department of Fish and Wildlife, Washington Habitat Connectivity Action Plan (https://wdfw.wa.gov/sites/default/ﬁles/publications/02630/wdfw02630.pdf) WDFW Riparian Management Zone Checklist for Critical Areas Ordinance – Addendum (https://wdfw.wa.gov/sites/default/ﬁles/2023-08/rmr-cao-checklistaddendum.pdf) Planning Commission Meeting June 24, 2026 9 MCA 26-0090 Phase 2 Wetlands Audit Memo Page 1 DATE: June 24, 2026 TO: Planning Commission FROM: Planning Division RE: Phase 2 Municipal Development Code Audit – Wetlands Analysis SUMMARY In 2017, the City amended Port Angeles Municipal Code (PAMC) Chapter 15.24 - Wetlands to expressly adopt the Washington Department of Ecology wetland rating system requiring the use of the latest Ecology rating procedures. Speciﬁcally, Chapter 15.24.040(D)(3) PAMC states that the City "shall apply the latest version" of Ecology's Wetland Rating System and Field Methodology. In auditing the chapter using the Department of Ecology Wetland Guidance for Critical Areas demonstrated that there are still several areas where the code appears to be vulnerable from a Best Available Science (BAS) perspective. The strongest argument is that the current ordinance remains largely site-scale and project-scale, while contemporary wetland BAS increasingly requires protection of landscape-scale ecological processes, particularly habitat connectivity, cumulative impacts, and long-term resilience. Those are the areas where the gap between the ordinance and current science are most pronounced and will be the primary focus of the amendments moving forward. Any consistency that was found to be “Strong” was not analyzed further as no recommended changes were deemed necessary. “Moderate” deﬁciencies contain some standards that are still relevant, but do not reﬂect current science in its entirety. “Signiﬁcant” deﬁciencies are either lacking entirely from the ordinance or are present but do not meet current standards. Those deﬁciencies that were identiﬁed as signiﬁcant will have the most recommendations for amendments moving forward, with moderate deﬁciencies requiring minimal amendments to meet current standards. Planning Commission Meeting June 24, 2026 10 MCA 26-0090 Phase 2 Wetlands Audit Memo Page 2 Environmental Topic BAS Consistency Observation Ecology Rating System Adoption Mitigation Sequencing Avoidance → minimization → rectiﬁcation → Delineation Standards Functional Assessment System Deﬁciency Wetland Buffers Deﬁciency assumptions and not clearly tied to Ecology's current buffer framework. Habitat Connectivity Signiﬁcant Deﬁciency Climate Resilience Signiﬁcant Deﬁciency Mitigation Deﬁciency than current functional assessment tools Category I Wetlands Deﬁciency Cumulative Impacts Signiﬁcant Deﬁciency Little discussion of cumulative effects Table 1: Best Available Science Gap Analysis | Source: Department of Ecology Wetland Guidance for Critical Areas (2022). FUNCTIONAL ASSESSMENT SYSTEM Analysis: The most obvious BAS issue is in Section 15.24.045 PAMC. Although the City adopts Ecology's rating system, it simultaneously retains a local hydrology classiﬁcation framework (Type 1, Type 2, Type 3, etc.) and a locally developed functional assessment methodology intended to align with Clallam County's approach. Wetlands are classiﬁed based on hydrology types and local habitat criteria in addition to Ecology's categories. Section 15.24.045 PAMC evaluates: • habitat diversity, • habitat types, • adjacent upland conditions, • documented species use, • management modiﬁcations. However, the 2014 Ecology Wetland Rating System places much greater emphasis on: Planning Commission Meeting June 24, 2026 11 MCA 26-0090 Phase 2 Wetlands Audit Memo Page 3 • landscape position, • watershed connectivity, • habitat corridors, • adjacent habitat integrity, • landscape context. Deﬁciency or Concern: Current wetland science increasingly recognizes that wetland value is strongly inﬂuenced by landscape-scale relationships rather than solely on-site conditions. The Port Angeles code appears largely parcel-oriented. The 2014 Ecology Wetland Rating System was speciﬁcally developed to replace many locally developed functional assessment methods because: • ratings are calibrated statewide, • functions are scored consistently, • buffers are linked to ecological performance, • habitat scores are standardized. A Growth Management Hearings Board challenge could argue that retaining parallel local functional assessment methods introduces subjectivity and potentially departs from Ecology's scientiﬁcally vetted methodology. Recommendation: Remove the City’s Local Functional Assessment System (15.24.045), adopt the state’s 2014 Wetland Rating System as the standard for functional assessments moving forward, and focus more on the science provided by Ecology that focuses on landscape-scale relationships. WETLAND BUFFERS Analysis: Port Angeles does use Category I-IV wetlands and applies associated buffer standards. However, the code largely relies on ﬁxed regulatory categories and does not appear to require a project-speciﬁc analysis of: • landscape connectivity, • amphibian movement, • species-speciﬁc habitat requirements, • ecological network integrity. Chapter 15.24 PAMC protects wetlands primarily through category-based buffer assignments rather than through a comprehensive evaluation of habitat-function and connectivity considerations reﬂected in Ecology's current wetland rating methodology. Planning Commission Meeting June 24, 2026 12 MCA 26-0090 Phase 2 Wetlands Audit Memo Page 4 Deﬁciency or Concern: Existing buffer widths do not meet the current standards as deﬁned in July 2018 Modiﬁed Habitat Score Ranges. Recommendation: Update the buffer standards using the Buffer Alternative 3 method as outlined in the July 2018 Modiﬁed Habitat Score Ranges prepared by the Department of Ecology. This method determines the buffer width based on the wetland category, intensity of impacts, wetland functions, or special characteristics. Table 2 shows the existing buffer regulations under PAMC and the recommended buffer widths following Buffer Alternative 3. Wetland Category Current Buffer Widths by Intensity Buffer Alternative 3 Widths by Intensity Category I Low Intensity - 200 ft High Intensity - 300 ft 150 ft Medium Impact - 225 ft High Impact - 300 ft Category II 100 ft High Intensity - 200 ft 150 ft Medium Impact - 225 ft High Impact - 300 ft Category III Low Intensity - 50 ft High Intensity - 100 ft 75 ft Medium Impact - 110 ft High Impact - 150 ft Category IV Low Intensity - 25 ft High Intensity - 25 ft 25 ft Medium Impact - 40 ft High Impact - 50 ft Table 2: Buffer Widths Analysis using Buffer Alternative 3 method, by intensity. For the purposes of buffer determination, land use intensity ratings must be established. Currently, the City does not deﬁne land use intensity ratings for buffer requirements, which can lead to subjective decisions being made. Examples of some proposed land uses associated with each intensity rating are listed below. High Intensity – Commercial, Industrial, Residential development with >1 unit/acre, High- intensity Recreation. Medium Intensity – Residential development <1 unit/acre, moderate-intensity open space, paved trails, utility corridors with ongoing maintenance needs. Low Intensity – Low-intensity open space, unpaved trails, utility corridors with little or no vegetation management needs. Planning Commission Meeting June 24, 2026 13 MCA 26-0090 Phase 2 Wetlands Audit Memo Page 5 HABITAT CONNECTIVITY Analysis: The current Wetlands chapter lacks any explicit reference to habitat connectivity standards. Modern ecology guidance and peer-reviewed wetland science emphasize: • wildlife movement corridors, • connected wetland complexes, • amphibian migration routes, • salmon-supporting wetland networks, • regional biodiversity connectivity. Chapter 15.24 PAMC discusses habitat functions but there are no requirements for evaluating: • corridor fragmentation, • connectivity loss, • barrier effects, • regional habitat network degradation. Deﬁciency or Concern: This is one of the strongest BAS deﬁciencies because connectivity science has advanced substantially since many portions of the chapter were originally written. Recommendation: Modify reporting requirements to include habitat connectivity science in order to better evaluate fragmentation, connectivity loss and regional habitat network degradation from development. CLIMATE RESILIENCY Analysis: Climate resiliency and hazard mitigation are entirely absent, and the code provides no references to: • climate adaptation, • changing hydrology, • sea-level rise, • drought resilience, • increased storm intensity, • carbon sequestration functions. Deﬁciency or Concern: While Chapter 15.24 PAMC predates much of Washington's climate-resilience guidance, modern BAS increasingly identiﬁes wetlands as critical climate infrastructure. This is becoming a common criticism of older critical areas ordinances. Planning Commission Meeting June 24, 2026 14 MCA 26-0090 Phase 2 Wetlands Audit Memo Page 6 Recommendation: Incorporate into the purpose the importance of wetland protection from a climate resiliency standpoint. Existing plans and policies point to their importance; the integration just needs to happen to align protections standards. MITIGATION Analysis: Section 15.24.070 PAMC relies heavily on: "best professional judgment of a qualiﬁed wetland ecologist" for determining functional replacement and mitigation success. Deﬁciency or Concern: Modern Ecology guidance increasingly favors: • standardized function assessment, • watershed-based mitigation planning, • mitigation banking, • in-lieu fee programs, • measurable performance standards. Reliance on professional judgment alone may create inconsistency. Recommendation: Provide guidelines for the “professional judgement” and reporting requirements that reﬂect the above concerns. Stricter reporting requirements for mitigation plans that meet current standards should be integrated. CATEGORY I WETLANDS Analysis: Ecology's 2014 rating system places strong emphasis on wetlands that are: • difficult to replace, • rare, • exceptionally high functioning, • of high conservation value. Port Angeles recognizes Category I wetlands, but much of the ordinance language still reﬂects the older "replace equivalent functions" framework rather than explicitly acknowledging that some wetlands cannot realistically be replaced. Deﬁciency or Concern: Replacement-based mitigation is often scientiﬁcally controversial for mature forested wetlands and rare wetland systems, such as those that meet the criteria of Category I and II wetlands. Recommendation: Update the wetland categories, especially Category I and II wetlands to reﬂect the current wetland types that are used by Ecology, and protection standards for Planning Commission Meeting June 24, 2026 15 MCA 26-0090 Phase 2 Wetlands Audit Memo Page 7 both that highlight their importance. Update the buffer requirements for Category I and II as deﬁned in Table 2 to ensure the wetlands and their buffers remain intact. CUMULATIVE IMPACTS Analysis: The chapter is heavily focused on individual permit impacts. No comprehensive requirement to evaluate: • incremental wetland losses, • cumulative watershed degradation, • regional habitat fragmentation, • multiple buffer reductions, • repeated minor encroachments. Deﬁciency or Concern: Washington courts and Growth Management Hearings Boards increasingly recognize cumulative impacts as a BAS consideration. The code primarily evaluates project-by-project effects. Recommendation: Update the reporting requirements to include the cumulative impacts of development. Include mapping language and other ways of tracking and monitoring watershed degradation and incremental wetlands losses. Set the baseline for monitoring into the future. References: WA Department of Ecology Wetland Guidance for Critical Areas Ordinance Updates (https://apps.ecology.wa.gov/publications/documents/2206014.pdf) WA Department of Ecology Washington State Wetland Rating System for Western Washington (https://apps.ecology.wa.gov/publications/documents/1406029.pdf) WA Department of Ecology Wetlands in Washington State Vol. 2: Guidance for Protecting and Managing Wetlands, July 2018 Modiﬁed Habitat Score Ranges (https://apps.ecology.wa.gov/publications/parts/0506008part3.pdf) WA Department of Ecology Characterizing Wetland Buffers in Washington State (https://apps.ecology.wa.gov/publications/documents/1706008.pdf) Planning Commission Meeting June 24, 2026 16 DATE: June 24, 2026 TO: Planning Commission FROM: Planning Division RE: Phase 2 Municipal Development Code Audit – Relevant Resources Frequently Flooded Areas WAC 365-190-110 – Frequently ﬂooded areas https://apps.leg.wa.gov/WAC/default.aspx?cite=365-190-110 Department of Ecology guidance for ﬂoodplains https://ecology.wa.gov/regulations-permits/guidance-technical-assistance/guidance-for- ﬂoodplains-critical-areas-ordinanc Fish and Wildlife Habitat Conservation Areas WA Department of Fish and Wildlife Riparian Ecosystems, Volume 1: Science Synthesis and Management Implications (https://wdfw.wa.gov/sites/default/ﬁles/publications/01987/wdfw01987.pdf) WA Department of Fish and Wildlife Riparian Ecosystems, Volume 2: Management Recommendations (https://wdfw.wa.gov/sites/default/ﬁles/publications/01988/wdfw01988.pdf) WA Department of Transportation and WA Department of Fish and Wildlife, Washington Habitat Connectivity Action Plan (https://wdfw.wa.gov/sites/default/ﬁles/publications/02630/wdfw02630.pdf) WDFW Riparian Management Zone Checklist for Critical Areas Ordinance – Addendum (https://wdfw.wa.gov/sites/default/ﬁles/2023-08/rmr-cao-checklistaddendum.pdf) Geologically Hazardous Areas WA Department of Fish and Wildlife Riparian Ecosystems, Volume 2: Management Recommendations (https://wdfw.wa.gov/sites/default/ﬁles/publications/01988/wdfw01988.pdf) Planning Commission Meeting June 24, 2026 17 WA DNR Geologic Information Portal (https://dnr.wa.gov/washington-geological- survey/publications-and-data/geologic-information-portal) Critical Aquifer Recharge Areas https://apps.ecology.wa.gov/publications/summarypages/0510028.html https://app.leg.wa.gov/wac/default.aspx?cite=365-190-100 Wetlands WA Department of Ecology Wetland Guidance for Critical Areas Ordinance Updates (https://apps.ecology.wa.gov/publications/documents/2206014.pdf) WA Department of Ecology Washington State Wetland Rating System for Western Washington (https://apps.ecology.wa.gov/publications/documents/1406029.pdf) WA Department of Ecology Wetlands in Washington State Vol. 2: Guidance for Protecting and Managing Wetlands, July 2018 Modiﬁed Habitat Score Ranges (https://apps.ecology.wa.gov/publications/parts/0506008part3.pdf) WA Department of Ecology Characterizing Wetland Buffers in Washington State (https://apps.ecology.wa.gov/publications/documents/1706008.pdf) Comparable Jurisdictions Anacortes Critical Areas Ordinance Arlington Critical Areas Ordinance Bellingham Critical Areas Ordinance Gig Harbor Critical Areas Ordinance Mill Creek Critical Areas Ordinance Oak Harbor Critical Areas Ordinance Port Townsend Critical Areas Ordinance Tumwater Critical Areas Ordinance Planning Commission Meeting June 24, 2026 18 Total Engagements YTD:% Change vs Last Year:% Timely Responses: Counter Visits = In-person front desk visits. Emails Sent = Messages sent through the permits inbox to applicants. Phone Calls = Customer phone calls logged. Timely Responses = Customer inquiries that receive a response within two business days of the initial contact. The CED Technicians have managed over 3,000 interactions so far this year, with nearly 98% of inquiries responded to within 2 business days. CED Customer Service Report - May 2026 +0.3%3,040 Avg Daily Engagements YTD: 20.1 97.5% 30% 55% 15% Customer Engagement Counter Visits Emails Sent Phone Calls 671 1559 810 COUNTER VISITS EMAILS SENT PHONE CALLS Engagement Type –YTD 2026 YTD Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2025 464 553 640 644 730 594 617 571 690 750 526 668 2026 473 542 550 772 703 400 500 600 700 800 To t a l I n t e r a c t i o n s Monthly Engagment Trend 0 100 200 300 400 500 600 700 800 900 Jan Feb Mar Apr May Timely Response Rate -YTD Total Interactions Timely Responses Planning Commission Meeting June 24, 2026 19 Total Permits YTD:% Change vs Last Year:% Same-Day Processing YTD:% Timely Issuance YTD: Over-the-Counter permits are completed quickly averaging less than 1 business day from intake to issuance with nearly 82% processed the same day Same-Day Processing = Measures the time from when an application is received until fees are sent. Counted as “Same-Day” if fees are sent the same business day. Timely Issuance = Measures the time from when payment is received until the permit is issued. Counted as “Timely” if issued within one business day of payment. Note: Customer payment delays are not included in these times. CED Over-the-Counter Permit Report – May 2026 185 +43.4%81.6%96.8% 60 3 2 2 27 64 0 10 20 30 40 50 60 70 Vendor Inspection Only Fire Solar Plumbing Re-Roof/Re-Side Mechanical Permits by Type -YTD 92%100% 86%83%83%88%88% 0% 20% 40% 60% 80% 100% Same-Day Processing Rate 17 28 27 28 29 35 32 51 28 27 27 23 27 40 27 31 60 JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Permits Issued by Month Permits 2025 Permits 2026 0.0 0.2 0.4 0.6 0.8 1.0 1.2 Average Staff Time by Type (Days) Planning Commission Meeting June 24, 2026 20 *If we ask for more information about a project and the applicant takes longer than 60 days to respond, the City may add up to 30 extra days to the overall review time for the application, as allowed under Port Angeles Municipal Code (PAMC) 18.02.170(G) and (H). CED SB 5290 Report - May 2026 TYPE I - Allowed, Permitted, or Accessory Uses Not Requiring Notice of Application; Building Permits Categorically Exempt from SEPA; Business Licenses; Clearing and Grading Permits; Critical Area Exemptions; Director's Determinations¹; Electrical Permits; Environmentally Sensitive Area Permits and Extensions; Fee Waivers; Final Binding Site Plans; Final Boundary Line Adjustments; Final Overlay Zones; Final Planned Residential Development (PRD); Final Plats; Final Short Plats; Final Unit Lot Subdivisions; Fire Alarm Permits; Fire Permits – Any Other Approval Provided by the Fire Department – Office of the Fire Marshal; Fire Sprinkler Permits; Flood Development Permits; Home Businesses/Home Occupation Permit; Land-Use Verification; Minor Amendments to an Approved Plat, Binding Site Plan, or Planned Residential Development; Minor Deviations Up to 20%; Minor Mobile or Itinerant Vendor Hosting Site Plan Review; NICE Grants; Preliminary Boundary Line Adjustments; Preliminary Short Plats; Regulatory Mobile or Itinerant Vendor Permit; Reasonable Use Exceptions; Right- of-Way Construction Permits; Sales and Use Tax Grants; Shoreline Exemptions; Sign Permits; Short-Term Lodging Licenses; Site Plan Review; Temporary Uses Up to One Year; Utility Feasibility Requests; Wetland Permit Extension; Wetland Temporary Emergency Permit. TYPE II - Administrative Conditional Use Permits; Administrative Conditional Use Permits Required for Transitional Housing Facilities 1–4 Units; Building Permits Requiring SEPA; Cottage Industries; Discretionary Conditional Use Permits; Major Mobile or Itinerant Vendor Hosting Site Plan Review; Minor Plat Amendment; Minor Variances; Preliminary Binding Site Plan; Preliminary Unit Lot Subdivision; SEPA Review (Not Associated with a Public Hearing); Shoreline Substantial Development Permits²; Temporary Housing Facilities; Wetland Permits. TYPE III - Conditional Use Permits; Conditional Use Permits Required for Transitional Housing Facilities 5+ Units; Major Amendments to an Approved Plat or Planned Residential Development; Major Variances; Minor Deviations 21–30%; Plat Vacation; Preliminary Overlay Zones; Preliminary Plats; Preliminary Planned Residential Development (PRD); SEPA Review (Associated with a Public Hearing); Shoreline Conditional Uses; Shoreline Substantial Development Permits³; Shoreline Variances; Temporary Uses – One to Five Years; Unclassified Use – TYPE IV - Site S ecific Rezones. TYPE V - Amendments to Development Regulations; Amendments to the Port Angeles Municipal Code; Annexations; Area-Wide Rezones; Comprehensive Plan Amendments; Development Agreements; Master Land Use, Subarea, Functional, and/or Utility Plans and Amendments; Shoreline Master Program Adoption and Amendments. NOTES: 1. See PAMC 18.02.240 for applicable procedures. 2. Only if the application is for a permitted use and receives a threshold determination of non-significance. 3. Except for Type II shoreline substantial development permits. 13 22 3 0 0 0 5 10 15 20 25 <14 Days 15-30 Days 31-65 Days 66-100 Days 101-170 Days Nu m b e r o f P e r m i t s I s s u e d Total Number of Days for Permit Review Permit Type I (65 Day Deadline*) 0 0 2 0 0 0 1 2 3 4 5 <14 Days 15-30 Days 31-65 Days 66-100 Days 101-170 Days Nu m b e r o f P e r m i t s I s s u e d Total Number of Days for Permit Review Permit Type II (100 Day Deadline*) 0 0 0 0 0 0 1 2 3 4 5 <14 Days 15-30 Days 31-65 Days 66-100 Days 101-170 Days Nu m b e r o f P e r m i t s I s s u e d Total Number of Days for Permit Review Permit Type III (170 Day Deadline*) 0 0 0 0 0 0 1 2 3 4 5 <14 Days 15-30 Days 31-65 Days 66-100 Days 101-170 DaysNu m b e r o f P e r m i t s I s s u e d Total Number of Days for Permit Review Permit Type IV (170 Day Deadline*) 0 0 0 0 0 0 1 2 3 4 5 <14 Days 15-30 Days 31-65 Days 66-100 Days 101-170 DaysNu m b e r o f P e r m i t s I s s u e d Total Number of Days for Permit Review Permit Type V (No Deadline*) Planning Commission Meeting June 24, 2026 21 CED Affordable Housing Report - May 2026 Type JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 2026 YTD 2025 YTD SUT - HB 1406 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 SUT - HB 1590 $0.00 $0.00 $0.00 $9,000.00 $91,006.37 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $100,006.37 $50,000.00 FWP $97,226.99 $1,065.00 $31,983.63 $0.00 $35,265.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $165,540.62 $57,111.48 NICE- Small Scale $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 NICE - Medium Scale $0.00 $0.00 $0.00 $21,000.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $21,000.00 $0.00 NICE - Large Scale $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 TOTAL CITY INVESTMENTS $97,226.99 $1,065.00 $31,983.63 $30,000.00 $126,271.37 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $286,546.99 $107,111.48 PRP 4 2 2 2 0 0 0 0 0 0 0 0 10 4 MFTE 0 4 0 0 0 0 0 0 0 0 0 0 4 0 Key SUT- HB 1406 SUT- HB 1590 FWP NICE - Small Scale NICE - Medium Scale NICE - Large Scale PRP MFTE Multi Family Tax Exemption. Contracts are shown in the month they were executed between developer and City, minimum number of estimated new dwelling units listed. Final dwelling unit counts will be determined at permitting/approval phase, and will be detailed on Please Note: City staff invest considerable time to proactively engage with prospective housing developers in order to amplify these critical City programs. This report only includes one stage of this important process. New Improvements for Community Enhancement of Neighborhoods Projects (≤ $14,999). Grants are shown in the month that the contract was fully executed between the developer and the City. New Improvements for Community Enhancement of Neighborhoods Projects ($15,000-$24,999). Grants are shown in the month that the contract was fully executed between the developer and the City. New Improvements for Community Enhancement of Neighborhoods Projects (≥ $25,000). Grants are shown in the month that the contract was fully executed between the developer and the City. Permit Ready Plans. Plans are shown in the month they were shared with prospective developer, minimum number of estimated new dwelling units listed. Final dwelling unit counts will be determined at permitting/approval phase, and will be detailed on the monthly Planning Commission Meeting June 24, 2026 22 CED Building Report - May 2026 JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 2025 YTD 0 0 1 0 1 0 0 0 0 0 0 0 3 $0.00 $0.00 $3,000.00 $0.00 $8,268.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $1,068,722.00 2 2 6 9 7 0 0 0 0 0 0 0 29 $8,007.00 $11,713.00 $116,130.00 $841,149.00 $151,714.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $1,014,000.00 Certificate of Occupancy 1 0 0 0 0 0 0 0 0 0 0 0 N/A 1 0 1 1 0 0 0 0 0 0 0 0 0 $7,000,000.00 $0.00 $1,019,685.00 $3,100,000.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 0 0 1 0 0 0 0 0 0 0 0 0 2 $0.00 $0.00 $4,500,000.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $2,702,099.00 Certificate of Occupancy 0 0 0 0 0 0 0 0 0 0 0 0 N/A 0 0 0 0 0 0 0 0 0 0 0 0 1 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $56,000,000.00 0 0 0 0 0 0 0 0 0 0 0 0 4 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $1,021,000.00 Certificate of Occupancy 0 0 0 0 0 0 0 0 0 0 0 0 N/A 4 0 2 0 1 0 0 0 0 0 0 0 2 $2,120,000.00 $0.00 $327,936.00 $0.00 $680,190.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $800,000.00 2 2 0 0 2 0 0 0 0 0 0 0 5 $407,313.00 $130,000.00 $0.00 $0.00 $267,680.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $857,354.00 1 0 4 0 1 0 0 0 0 0 0 0 5 $224,352.00 $0.00 $515,807.00 $0.00 $400,000.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $1,409,554.00 1 0 2 1 2 0 0 0 0 0 0 0 4 $170,517.00 $0.00 $86,690.00 $20,000.00 $105,552.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $377,224.00 19 32 18 31 29 0 0 0 0 0 0 0 136 $251,345.00 $322,685.00 $201,849.00 $557,995.00 $753,323.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $2,074,528.00 Certificate of Occupancy 2 0 0 0 0 0 0 0 0 0 0 0 N/A Comm 0 0 2 0 1 0 0 0 0 0 0 0 3 Res $0.00 $0.00 $15,200.00 $0.00 $7,734.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $31,500.00 30 36 37 42 44 0 0 0 0 0 0 0 194 $10,181,534.00 $464,398.00 $6,786,297.00 $4,519,144.00 $2,374,461.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $67,355,981.00 $106,793.40 $20,095.63 $100,441.68 $89,033.73 $44,118.65 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $720,953.95 3 2 4 2 3 0 0 0 0 0 0 0 15 0 0 1 0 1 0 0 0 0 0 0 0 2 6 2 8 0 4 0 2 0 0 0 0 0 0 0 14 8 4 1 0 4 0 1 0 0 0 0 0 0 0 6 2 5 2 2 0 0 2 0 0 0 0 0 0 0 6 7 5 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 11 2 9 0 6 0 0 0 0 0 0 0 28 23 16 Comm Ind Public New Construction New Construction Repair and Alteration Repair and Alteration New Single Family New Accessory Structure Res Dwelling Units - Duplex New Construction New Multi Family New Manufactured Home Business Certificate of Occupancy Permit Fees Paid Total Permits Issued Total Construction Valuation Repair and Alteration italics are at various stages of staff review. Additionally, not all applicants have submitted a complete application at this time. While we expect the majority to advance through the review process, it is possible that some may experience the need for additional review. Total Dwelling Units 2026 YTD 2 $11,268.00 1 26 $1,128,713.00 3 $11,119,685.00 0 0 $4,500,000.00 1 6 $382,759.00 2 $0.00 0 0 $0.00 7 $3,128,126.00 6 $804,993.00 6 $1,140,159.00 14 Demolition and Moving Repair and Alteration 129 $2,087,197.00 $360,483.09 $24,325,834.00 3 $22,934.00 189 Planning Commission Meeting June 24, 2026 23 Muni Development Code Amendments Phase Two: Critical Areas Ordinance & Urban Forestry Phase 2 Code Audit 2 Audit Documents 3 Chapter 15.20 – ESA’s WDFW Riparian Ecosystems Vol. 2: Management Recommendations Chater 15.24 – Wetlands Department of Ecology Wetland Guidance for Critical Areas Audit Terminology 4 Analysis: Simple synopsis of existing code and/or BAS. BAS Consistency: Strong, Potential Deficiency, Moderate Deficiency, Significant Deficiency. Deficiency/Concern: Issue needing potential remedy. Recommendation: Steps in codification or implementation that will support BAS in the CAO. Chapter 15.20 Audit Findings 5 Environmental Topics BAS Consistency Observation Priority Species Protection Strong Present Riparian Habitat Protection Potential Deficiency Present Habitat Connectivity Significant Deficiency Core BAS Principle Wildlife Corridors Significant Deficiency Core BAS Principle Landscape-Scale Conservation Significant Deficiency Core BAS Principle Chapter 15.20 Audit Findings 6 Environmental Topics BAS Consistency Observation Population Viability Moderate Deficiency Explicit Goal Anadromous Fish Protection Potential Deficiency Special Consideration Required Cumulative Impacts Moderate Deficiency Increasing BAS Emphasis Adaptive Management Potential Deficiency Recommended Climate Resilience Significant Deficiency Increasingly Incorporated in newly adopted CAOs Habitat Connectivity, Wildlife Corridors and Landscape Conservation 7 Analysis: Code is project based and there is little monitoring. BAS Consistency: Significant Deficiency. Deficiency/Concern: No standards for identifying, maintaining, or restoring habitat connectivity. Recommendation: Development of monitoring or adaptive management program. Population Viability 8 Analysis: Ordinance protects habitat but does not require evaluation of cumulative impacts and habitat connectivity. BAS Consistency: Moderate Deficiency. Deficiency/Concern: Habitat protection should involve evaluation of level of protection for viable populations. Recommendation: Development of monitoring or adaptive management program. Riparian Habitat Protection 9 Analysis: Habitat includes more complexity than buffers. BAS Consistency: Potential Deficiency. Deficiency/Concern: No current inclusion of more complex ecosystem science. Recommendation: Development of standards that reflect BAS using site potential tree height. Anadromous Fish 10 Analysis: Code does not reflect landscape scale protections. BAS Consistency: Potential Deficiency. Deficiency/Concern: The code does not reflect BAS for salmon recovery. Recommendation: Maintain no net loss of ecosystem function and reflect BAS using site potential tree height. Cumulative Impacts 11 Analysis: Current code does not recognize cumulative degradation as a drive of species decline. BAS Consistency: Moderate Deficiency. Deficiency/Concern: The code only evaluates impact on a project-by-project basis. Recommendation: Development of monitoring or adaptive management program. Climate Resiliency 12 Analysis: Although just emerging as a basis for best available science guidance, the code is silent on climate resiliency. BAS Consistency: Significant Deficiency. Deficiency/Concern: The code predates the 2022 CRP Recommendation: Incorporate climate-related specifics in findings and purpose statement. Chapter 15.24 Audit Findings 13 Environmental Topic BAS Consistency Observation Ecology Rating System Adoption Strong City adopts Ecology rating system. Mitigation Sequencing Strong Avoidance → minimization → rectification → compensation hierarchy is incorporated. Delineation Standards Strong Uses Ecology delineation manual. Functional Assessment System Moderate Deficiency Local methodology retained alongside Ecology system. Chapter 15.24 Audit Findings 14 Environmental Topic BAS Consistency Observation Wetland Buffers Moderate Deficiency Several provisions appear tied to older assumptions and not clearly tied to Ecology's current buffer framework. Habitat Connectivity Significant Deficiency Little evidence of modern landscape- scale connectivity analysis. Climate Resilience Significant Deficiency No climate resilience provisions. Chapter 15.24 Audit Findings 15 Environmental Topic BAS Consistency Observation Mitigation Moderate Deficiency Uses "best professional judgment" rather than current functional assessment tools and watershed approaches. Category I Wetlands Moderate Deficiency Less detailed than Ecology's modern emphasis on irreplaceable wetlands. Cumulative Impacts Significant Deficiency Little discussion of cumulative effects analysis. Functional Assessment System 16 Analysis: Local methodology retained alongside Ecology system. BAS Consistency: Moderate Deficiency. Deficiency/Concern: BAS recognizes wetland value influenced by landscape scale relationships, not on-site. Recommendation: Remove 15.24.045 and adopt the states 2014 wetland rating system for functional assessments. Wetland Buffers 17 Analysis: Code uses wetland rating but also relies on fixed rating system that is inflexible. BAS Consistency: Moderate Deficiency. Deficiency/Concern: Existing buffer widths do not meet current 2018 modified habitat score ranges. Recommendation: Update the buffer standards using the Buffer Alternative 3 method using land use intensity ratings. Habitat Connectivity 18 Analysis: Older code has not kept up with modern larger scale evaluation of greater habitat connectivity. BAS Consistency: Significant Deficiency. Deficiency/Concern: BAS has advanced past the most recent update and needs to be amended to reflect BAS. Recommendation: Modify reporting requirements to include habitat connectivity science. Climate Resiliency 19 Analysis: Although just emerging as a basis for best available science guidance, the code is silent on climate resiliency. BAS Consistency: Significant Deficiency. Deficiency/Concern: The code predates the 2022 CRP Recommendation: Incorporate climate-related specifics in findings and purpose statement. Mitigation 20 Analysis: Current code relies heavily on “professional judgement” for determining wetland function. BAS Consistency: Moderate Deficiency. Deficiency/Concern: Relying on professional judgement can create inconsistencies. Recommendation: Development of more robust guidelines for professional judgement and reporting. Category 1 Wetlands 21 Analysis: Current code does not reflect new emphasis on the fact that some wetlands are irreplaceable. BAS Consistency: Moderate Deficiency. Deficiency/Concern: Replacement methodologies are controversial for mature forest wetlands. Recommendation: Update wetland categories to reflect BAS in protection standards. Cumulative Impacts 22 Analysis: Current code is heavily focused on individual permitting impacts. BAS Consistency: Moderate Deficiency. Deficiency/Concern: WGMHB increasingly recognizes cumulative impacts as a BAS consideration. Recommendation: Update reporting requirements and internal implementation of CAO mapping. General Takeaways & Recommendations 23 The Ordinance Should Include: 1.Reference to the Washington Habitat Connectivity Action Plan. 2.Better monitoring and reporting requirements that consider larger habitat impacts. 3.Site potential tree height considerations. 4.References to the Climate Resiliency Plan. 5.Updated Wetland buffer standards that match BAS and remove inconsistency. General Takeaways & Recommendations 24 Implementation Should Include: 1.Better City led mapping that focuses on landscape scale habitat connectivity and incorporates continual monitoring to track cumulative impacts. 2.Development of monitoring or adaptive management program. 3.Guidance documents that assist property owners in navigating onsite critical areas. Future CAO Public Meetings July 22: PC Discussion on amendments made to-date. August 25: Council Work Session August 26: PC Discussion on amendments made to-date and responses to comments from previous meetings. September 23: PC Public Hearing. October: Council 1st Reading November: Council 2nd Reading and Adoption 25 Discussion 26