Commentary: Kitsap County Comprehensive Plan Update

In order to establish a baseline for comments to The County Comprehensive Plan Update, we requested from the County that they provide us with the requirements being imposed on us by outside agencies. This would allow us to identify what was under county control and what was being directed.

March 28, 2016

Honorable Commissioners,

What are the change, if any, being mandated by the following Departments in Kitsap County’s New Comprehensive Plan and what are their justifications? Please explain and show the reasoning behind the changes.

Dept. of Commerce
Dept. of Ecology
Dept. of Fish and Wild Life
Dept. of Natural Resources
Army Corps of Engineers
Environmental Protection Agency
Puget Sound Regional Council
Puget Sound Partnership
Washington State Legislature

Thank you for your prompt response. We appreciate the complexity of the task and believe these clarifications will enable better understanding by County officials who administer the plan as well as Kitsap citizens.


Jackie Rossworn, Executive Director,
Kitsap Alliance of Property Owners

This is the answer that we received:

April 20, 2016

Jackie Rossworn, Executive Director
Kitsap Alliance of Property Owners
PO Box 1861
Poulsbo, WA 98370

Dear Ms Rossworn:

Thank you for your letter dated March 28, 2016 regarding the periodic update to Kitsap County’s Comprehensive Plan. Your letter specifically states “What are the change (sic), If any, being mandated by the following Departments in Kitsap County’s New Comprehensive Plan and what are their justifications? Please explain and show the reasoning behind the changes.” We understand your letter to be asking what changes to Kitsap County’s 2006 Comprehensive Plan relate to mandates by the letter’s listed state and federal agencies, as well as the Washington State Legislature. Kitsap County is currently in the process of updating its 2006 Comprehensive Plan as required by RCW 36.70A.130(5)(b). In accordance with RCW 36.70A.130(5}(b), Kitsap County must review and revise its Comprehensive Plan by June 30, 2016 to ensure continued compliance with the Growth Management Act (GMA). Thus, the majority of proposed changes to the Draft Comprehensive Plan including, but not limited to, the revised goals, policies, and strategies; the changes in the urban growth area (UGA) boundaries; and zoning changes are reflective of the Washington State legislature’s mandates as provided in the GMA. Additionally, the proposed changes to the Comprehensive Plan reflect the Growth Management Hearings Board’s (GMHB) decisions since the last update, which Kitsap County is also required to comply with. GMHB’s decisions are available at

The following Is a list of existing mandates and related changes, If any, from the letters listed agencies:

WA Dept. of Commerce – No mandates but a ‘GMA checklist’ to submit for review, and guidelines for Kitsap County’s Comprehensive plan update found in Chapter 365-196 WAC.

WA Dept. of Ecology – The Washington State Wetland Rating System for Western Washington was updated by Ecology In 2014. The County’s Critical Areas Ordinance (CAO) relies on this system for determining wetland ratings, and thus will be revised to reflect the 2014 update.

WA Dept. of Fish and Wildlife – No mandates and no changes.

WA Dept. of Natural Resources No mandates and no changes.

Army Corps of Engineers No mandates and no changes.

Environmental Protection Agency No mandates and no changes.

Puget Sound Partnership No mandates and no changes.

Puget Sound Regional Council As required by the GMA, Kitsap County must plan for growth in coordination with other regional cities and counties. One way this is accomplished is through consistency in Kitsap County’s planning with PSRC’s VISION 2040. Additional information about PSRC and VISION 2040 can be found at

FEMA No mandates and no changes relative to the Comprehensive Plan. Note: FEMA is in the process of updating its Flood Insurance Rate Studies and Flood Insurance Rate Maps, which the County relies on for continued participation in the National Flood Insurance Program.

We are thankful that you appreciate the complexity associated with this required periodic update to Kitsap County’s Comprehensive Plan. The Board of County Commissioners directed county departments, including the Department of Community Development. To cooperatively create an updated Plan that is measurable, results-oriented and more accountable than previous years’ Plans. Public and private groups are critically important to the County creating a balanced, objective and results-oriented Plan and we encourage your continued involvement in the update process If you have any additional questions or need additional information, please contact David Greetham, Planning Supervisor at 360-337-4641 .


Jeffrey L. Rowe, CBO, CFM
Acting Director

Opinion: This response obscures and minimizes the issue implying that the entire Comprensive Plan Update is of Kitsap County origin. The plan states “The Plan describes how residents want the County to look in the future.”

The PSRC Vision 2040 is adopted in it’s entirety by reference:

Plan Review Manual (10 Pages)

A set of materials, compiled in a Plan Review Manual, provides details on the policy and plan review and certification process, background, and framework. The manual also provides guidance and checklists for aligning plans and policies with VISION 2040 and Growth Management Act requirements.

Certification Status

Certification is a requirement for jurisdictions and agencies that intend to apply for PSRC funding or proceed with projects submitted into the Regional Transportation Improvement Program. PSRC maintains a report of the certification status of each jurisdiction along with each jurisdiction’s most recent certification report.

Vision 2040 Transportation Goals:

MPP-T-23: Emphasize transportation investments that provide and encourage alternatives to single-occupancy vehicle travel and increase travel options, especially to and within centers and along corridors connecting centers.

MPP-T-28: Avoid construction of major roads and capacity expansion on existing roads in rural and resource areas.

MPP-T-33: Promote transportation financing methods, such as user fees, tolls, and pricing, that sustain maintenance, preservation, and operation of facilities and reflect the costs imposed by users.

As the county shifts to more and more electric cars highway infrastructure currently dependent on gasoline tax will require new sources. Items under investigation are tolling all major arterials and annual tax on all miles traveled.

Strategy 4 – Compliance reporting for FEMA.

Programs or Projects / Measuring, Monitoring, and Evaluation: Submit required annual report to Federal Emergency Management Agency regarding Kitsap County’s status on review of projects for compliance with the National Flood Insurance Program Biological Opinion Puget Sound, as well as progress towards achieving programmatic compliance.

National Marine Fisheries Service’s Biological Opinion (BiOp) on the National Flood Insurance Program (NFIP)

  1. Allow no development in the Riparian Buffer Zone (RBZ, identified as the greater of the channel migration zone plus a 50-foot buffer, the riparian buffer width specified by stream type, and the floodway), OR
  2. Local jurisdiction must demonstrate to FEMA that proposed RBZ development does not adversely affect salmon habitat needs.
  3. In addition to either 1 or 2 above, either:
  4. a) Prohibit development in the 100 yr floodplain, OR
  5. b) Avoid, rectify or compensate for any loss of floodplain storage and fish habitat from development in the 100 yr floodplain (outside RBZ). Any development allowed must use Low Impact Development methods to minimize or avoid stormwater effects. Any indirect adverse effects must be mitigated.
  6. c) Structural improvements/repairs resulting in greater than 10% increase in structure footprint must mitigate adverse effects to fish or their habitat.

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