2/27/06City of Yelm
Planning Commission
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AGENDA
Yelm Planning Commission
Monday, February 27, 2006
4:00 P.M.
Yelm City Hall
105 Yelm Avenue West
Call to Order and Roll Call
Approval of Minutes: January 23, 2006
Public Communications not associated with agenda items
Public Hearings: None Scheduled
Other
a. Growth Management Plan Update 2006 Work Program
Kathy McCormick, Thurston Regional Planning Council
b. 2006 Flood Event Overview
Jim Gibson, P.E., Community Development Department
Adjourn
Next regular meeting
Monday, March 20, 2006 - 4:00 P.M.
Yelm City Hall Council Chambers
Enclosures are available to non-Commission members upon request.
It is the City of Yelm's policy to provide reasonable accommodations for people with disabilities. If you are a person
with a disability in need of accommodations to conduct business, or to participate in government processes or
activities, please contact Agnes Bennick, at 360-458-8404 at least four (4) working days prior to the scheduled event.
All Planning Commission meetings are audio taped. For information on obtaining a copy, please call the Community
Development Department at (360) 458-3835.
YELM PLANNING COMMISSION MINUTES
JANUARY 23, 2006 4:00 P.M.
YELM CITY HALL
John Thomson called the meeting to order at 4:04 PM
Members present: John Thomson, Norm Allard, Greg Mattocks, Terry Kaminski, and
Glen Cunningham.
Staff: Grant Beck and Tami Merriman
Members Absent: John Graver, and Carlos Perez unexcused
Motion No.
Approval of Minutes:
06-01 MOTION MADE BY NORM ALLARD, SECONDED BY GLEN CUNNINGHAM TO
APPROVE THE MINUTES FROM THE NOVEMBER 21, 2005 MEETING. MOTION
CARRIED.
Public Communications:
Mr. Steve Klein shared with the Commission his presentation to City Council that
population numbers used for budgeting purposed did not match the numbers as stated in
a Tacoma News Tribune article, and that he urges the City to reopen the budget planning
to rework the numbers.
Public Hearing -None
Elections of Officers:
Mr. Beck suggested to the Commission a way to elect officers yearly, to assure
Commission members are all given the opportunity to sit as chair, and realize the
importance of the position and duties.
Mr. Thomson agreed with Mr. Beck and stated that he felt it is unhealthy to have
leadership that never changes.
Mr. Beck suggested that the Vice Chair automatically be moved to the Chair position,
after the previous term of Vice Chair, and that the Commission then vote for a new Vice
Chair. The following year, the new Vice Chair would automatically move up to Chair.
06-02 MOTION MADE BY GREG MATTOCKS, SECONDED BY NORM ALLARD TO
ACCEPT THE NEW ELECTION OF OFFICERS POLICY. MOTION CARRIED.
Nominations of John Graver, and Norm Allard for Vice Chair. A vote was held, with one
(1) vote for John Graver, and four (4) votes for Norm Allard.
The 2006 Planning Commission Chair is Glen Cunningham, and the 2006 Planning
Commission Vice Chair is Norm Allard.
Other:
Mr. Beck provided the commission with an update of residential development in Yelm,
and updated the Commission on the Walmart application. A Land Use Petition was filed
Yelm Planning Commission
January 23, 2006
Page 1
is Superior Court appealing the City Councils decision to uphold the Hearing Examiners
Decision.
Mr. Beck informed the Commission that the City Council is planning their yearly retreat,
and that Mr. Beck would like to arrange for the Planning Commissions participation in the
tour of the City.
Mr. Beck gave a summary of the Growth Management Act Appeal with Thurston County.
The county is now researching alternatives for the down-zoning of property in the rural
County areas, as well as looking at whether the urban growth areas of the cities are too
large or too small.
06-03 MOTION MADE BY GREG MATTOCKS, SECONDED BY NORM ALLARD TO
ADJOURN. MEETING ADJOURNED AT 4:45 P.M.
Respectfully submitted,
Tami Merriman, Assistant Planner
John Thomson, Chair Date
Yelm Planning Commission
January 23, 2006
Page 2
~o~T>~ MEMORAND UM
~s
City of Yelm
WAaNINOTON
Community Development Department
To: Yelm Planning Commission
From: Grant Beck, Director of Community Development
Date: December 15, 2004
Subj: GMA Consistency Review
The Growth Management Act requires periodic review of the Comprehensive Plan in
order to ensure that it remains compliant with the GMA. Although some jurisdictions
have taken the opportunity to revisit the basic policy directions in the comprehensive
plan, the City of Yelm is simply reviewing its plan to ensure it is consistent with the
GMA, including updates to the GMA by the Legislature.
The review process includes three basic steps: review relevant plans and regulations;
analyze the need for revisions; and adopt an appropriate resolution if compliance is
found or amendments are needed for compliance.
The policies and regulations to review include those for:
• Urban densities
• Urban growth areas
• Critical areas
• Natural resource lands
• Essential public facilities
• Affordable housing for all income levels
• Transportation, including levels of service and concurrency
• Public facilities and services to meet future needs
• Shoreline Master Program
The City of Yelm has approached the consistency review as an evaluation of the
policies and regulations listed above to ensure they remain consistent with the Growth
Management Act rather than a reconsideration of the polices themselves.
Included in this review is an analysis of all new requirements of the Growth
Management Act that have been adopted by the legislature since 1994.
Urban Densities
GMA Goal -Encourage development in urban areas where adequate public facilities
and services exist or can be provided in an efficient manner [RCW 36.70A.020 (1 )].
GMA Goal -Reduce the inappropriate conversion of undeveloped land into sprawling,
low-density development [RCW 36070A.020 (2)].
GMA Requirement - Provide a range of urban densities and land uses. Urban being
development which is incompatible with natural resources or rural lands and require
urban services such as community water and sewer systems.
GMA Requirement -Provide minimum densities of four units per acre.
Yelm Comprehensive Plan Policies
The Yelm Comprehensive Plan manages sprawl within the unincorporated portion of the
Urban Growth Area by limiting development to one home to 5 acres until annexation
and urban services are provided. The Comprehensive Plan includes future zoning of
the unincorporated UGA to establish urban densities upon annexation.
The Yelm Comprehensive Plan provides for residential densities ranging from 4 units
per acre to 14 units per acre in residential districts. Within the higher density districts, a
range of housing types is allowed. A residential component is allowed as part of a
mixed use development in most commercial districts.
Yelm Development Regulation Requirements
The Comprehensive Ptan Map and Zoning Code establish the following areas with the
area of the Yelm UGA that is incorporated.
Density
units/ ross acre
District Residential Allowed Minimum Maximum Area
Low Densi Residential SFD/Du lex N/A 4 471
Moderate Densit Residential U to a 6 lex 3 6 463
Hi h Densit Residential Multi-Famil 6 14 127
Central Business District Multi-Famil 6 16 57
Commercial Multi-Family (60% of N/A 16 386
a mixed use
develo ment
Heavy Commercial Multi-Family (60% of N/A 16 33
a mixed use
develo ment
Large Lot Commercial Multi-Family (60% of N/A 16 56
a mixed use
December 15, 2004 Page 2 of 16
develo ment
Industrial N/A 190
O en S ace/Institutional N/A 118
Master Planned Community Any type consistent
with Comprehensive
Plan N/A N/A 1,555
Analysis
The Comprehensive Plan and Zoning Code clearly allow and require urban level
densities. Recent development trends have seen an achieved density of approximately
6 units per acre within developments providing single family dwelling lots. Infill within
the central business district has been occurring with many duplex units on urban lots.
Conclusions
Yelm's Comprehensive Plan and Development Regulations are consistent with the
Growth Management Act.
December 15, 2004 Page 3 of 16
Urban Growth Areas
GMA Goal -Encourage development
facilities and services exist or can be
36.70A.020 (1 )].
n urban areas where adequate public
provided in an efficient manner [RCW
GMA Requirement -Define growth areas that include the cities and their
adjacent urban and urbanizing lands. The growth areas must provide adequate
areas and densities to accommodate the urban growth expected for them in the
succeeding twenty years.
GMA Requirement -The adequacy of these growth areas be re-evaluated and
adjusted if needed at least every seven years, five in those counties required to
prepare buildable lands reports.
GMA Requirement -Cities and counties are obliged to conduct their planning
using population forecasts that are consistent with those developed for their
county by the Office of Financial Management. This means that the forecasts
used by each county must fall within the range of the High, Intermediate, and
Low OFM series.
Yelm Comprehensive Plan Policies
The Yelm Comprehensive Plan identifies the urban growth area and based the size of
the UGA on the OFM population forecast.
The unincorporated Yelm Urban Growth Area is managed as an `urban reserve' with
residential densities of one home per 5 acres until the property is annexed to the City
and urban services become available.
Yelm/Thurston County Development Regulation Requirements
Pursuant to the County-wide planning policies and the policies of the Comprehensive
Plan, Thurston County has zoned the residential areas of the unincorporated Yelm
Urban Growth Area as Residential 1/5, which allows a density of one unit per five acres,
which preserves the ability to redevelop at urban densities upon annexation and the
provision of urban services.
Analysis
Thurston County and all the cities and towns delegated population forecasting
and buildable lands analysis to the Thurston Regional Planning Council.
In its County-Wide Planning Policies, Thurston County determines what forecast
to use within the OFM range by relying on the forecasts of the Thurston Regional
Planning Council. Likewise, the County relies on TRPC to determine realistic
allocations, in consultation with the cities.
December 15, 2004 Page 4 of 16
The most recent TRPC forecast was completed in 1999. The most recent OFM
forecasts were released in January 2002, incorporating information from the 2000
Census. For Thurston County, the OFM Intermediate Series forecast is virtually identical
to the 1999 TRPC Medium Scenario-it differs by one percent or less in each of the
forecast years.
Because the TRPC and OFM forecasts for Thurston County are consistent, it is also not
necessary to re-evaluate the population growth allocation targets for Yelm until Thurston
County's UGA review based on the Buildable Lands analysis.
Conclusions
The Yelm Urban Growth Area is consistent with the requirements of the Growth
Management Act.
December 15, 2004 Page 5 of 16
Critical Areas
GMA Goal -Critical areas include the following areas and ecosystems: (a) Wetlands;
(b) areas with a critical recharging effect on aquifers used for potable water; (c) fish and
wildlife habitat conservation areas; (d) frequently flooded areas; and (e) geologically
hazardous areas." [RCW 36.70A.030 (5)]
GMA Goal -Protect the environment and enhance the state's high quality of life,
including air and water quality, and the availability of water." [RCW 36.70A.020 (10)]
GMA Requirement - Protect environmentally sensitive areas with development
regulations.
GMA Requirement -Critical Areas Codes should incorporate "Best Available Science"
(BAS), with special consideration to measures needed to protect or enhance
anadromous fisheries.
Yelm Comprehensive Plan Policies
The Yelm Comprehensive Plan at Chapter 12 provides policies that relate to the
environment. The policies note that Yelm contains limited critical areas which include a
critical aquifer recharge area, the floodplains associated with Yelm and Thompson
Creeks, and limited wetlands primarily associated with Yelm and Thompson Creeks.
The policies do not reference the use of best available science.
Yelm Development Regulation Requirements
The Yelm Critical Area Code, Chapter 14.08 YMC was first adopted in 1995, but has
seen no major changes since that time. It does address the major requirements of the
Growth Management Act, however it does not utilize best available science in the
establishment of wetland buffers or stream buffers.
Because of the nature of Yelm and Thompson Creeks, they are intermittent `prairie'
streams that have no in-stream flow much of the year, the floodplain regulations are
typically more stringent and serve as the actual stream buffers.
The City conducted a comprehensive assessment of Yelm Creek and it's associated
floodplain in 2001. The Yelm Creek Comprehensive Flood Hazard Management Plan
contains analysis of the causes of flooding along Yelm Creek as well as identifying
projects which both reduce flood hazard and restores habitat.
Yelm participated in the adoption of the Nisqually Watershed Management Plan (WRIA
11), which contains a number of goals and policies related to managing the Nisqually
watershed in a comprehensive manner.
The City has adopted a wellhead protection program as part of its Comprehensive
Water System Plan update, whicih provides a policy basis for the adoption of wellhead
December 15, 2004 Page 6 of 16
protection standards. This document is adopted by reference in the Comprehensive
Plan.
Analysis
The state Office of Community Development adopted new rules for what constitutes
best available science in 2000 and Yelm has not updated its regulations.
The Comprehensive Plan should be amended to include a policy that critical areas
regulations be based on best available science.
The Critical Areas Code needs to be updated to bring it into compliance.
Conclusions
The Yelm Critical Areas Code should be updated to comply with the best available
science requirements of the Growth Management Act in the areas of wetland and
stream buffers.
The Yelm Creek Comprehensive Flood Management Plan and it's recommendations
should be adopted as an appendix to the Comprehensive Pan.
The Nisqually Watershed Management Plan should be adopted as an appendix to the
Comprehensive Plan.
December 15, 2004 Page 7 of 16
Resource Lands
GMA Goal -Natural resource industries. Maintain and enhance natural resource-based
industries, including productive timber, agricultural, and fisheries industries. Encourage
the conservation of productive forest lands and productive agricultural lands, and
discourage incompatible uses." [RCW 36.70A.020 (8)]
GMA Requirement -Classify and protect farm, forestry, and mining areas from
incompatible development. The guidelines for classifying natural resource lands are
based on whether the land is currently in such uses, and whether the lands have long-
term commercial significance. Long term commercial significance includes a
consideration of the proximity of urban, suburban, or rural settlements. Thus these
provisions are focused mainly on rural areas substantially devoted to farming, forestry,
and mining.
GMA Requirement -Lands designated for long-term natural resource use must be
protected from the adverse impact of development on or near the resource lands.
Yelm Comprehensive Plan Policies
As there are no resource lands of long term commercial significance within the
Yelm Urban Growth Area, Thurston County has not designated any resource
lands within 5 miles of the Yelm Urban Growth Area.
Yelm Development Regulation Requirements
N/A
Analysis
Resource lands of long-term commercial significance are not found in urban
areas, although the City and County have coordinated through the County Wide
Planning Policies to ensure that the urban area has no impact on such lands
within the County.
Conclusions
The Yelm Comprehensive Plan is consistent with the requirements of the Growth
Management Act relating to resource lands.
December 15, 2004 Page 8 of 16
Essential Public Facilities
GMA Goal -Essential public facilities include those facilities that are typically difficult to
site, such as airports, state education facilities and state or regional transportation
facilities as defined in RCW 47.06.140, state and local correctional facilities, solid waste
handling facilities, and in-patient facilities including substance abuse facilities, mental
health facilities, group homes, and secure community transition facilities as defined in
RCW 71.09.020." [RCW 36.70A.200]
GMA Requirement - Include a process to identify and site essential public facilities, in
both their comprehensive plan and their development regulations.
GMA Requirement - No local comprehensive plan or development regulation may
preclude the siting of essential public facilities.
GMA Requirement -Provide for the siting of secure community transition facilities.
Yelm Comprehensive Plan Policies
Chapter 9 of the Yelm Comprehensive Plan provides a policy framework for the
location of both local and state wide essential public facilities.
Additionally, elements of the Comprehensive Plan include the Essential Public
Facilities Comprehensive Plan, the Comprehensive Water Plan, the
Comprehensive Sewer Plan, and the Comprehensive Transportation Plan.
Yelm Development Regulation Requirements
The Yelm Zoning Code allows essential public facilities in all zoning districts in
the City provided they are consistent with capital facilities plans for the service
provider. The Zoning Code was amended in 2002 to provide for the location of
secure community transitional facilities within Yelm.
Analysis
The Compressive Plan and Zoning Code both allow for the siting of essential
public facilities, including secure community transitional facilities. The City may
consider an amendment to the Zoning Code to streamline the permitting process
for essential public facilities that are identified in an approved Capital Facilities
Plan
Conclusions
The Yelm Comprehensive Plan is consistent with the Growth Management
requirements for the siting of essential public facilities, although the City may consider
streamlining the approval process for facilities identified in an adopted Capital Facilities
Plan.
December 15, 2004 Page 9 of 16
Affordable Housing
GMA Goal -Encourage the availability of affordable housing to all economic segments
of the population of this state, promote a variety of residential densities and housing
types, and encourage preservation of existing housing stock.
GMA Requirement - Include a housing element in their comprehensive plans which:
• Includes an inventory and analysis of existing and projected housing needs;
• includes a statement of goals, policies, objectives, and mandatory provisions for
the preservation, improvement, and development of housing, including single-
family residences;
• identifies sufficient land for housing, including, but not limited to, government-
assisted housing, housing for low-income families, manufactured housing,
multifamily housing, and group homes and foster care facilities; and
• makes adequate provisions for existing and projected needs of all economic
segments of the community." (RCW 36.70A.070)
Yelm Comprehensive Plan Policies
The required inventory of existing housing and analysis of projected housing needs is
located in Chapter Four of the Yelm Comprehensive Plan. This chapter projects the
need for affordable housing and establishes policies that promote such housing through
encouraging a variety of housing types and densities and conserving and improving the
existing housing stock and neighborhoods.
The housing inventory is somewhat out of date, but the projections are still valid, as
verified by the latest buildable lands report from the Thurston Regional Planning
Council, as noted in the urban growth area section.
Yelm Development Regulation Requirements
The Yelm Zoning Code allows a range of housing densities from 4 units per acre
to 16 units per acre in a range of housing styles from single family dwellings to
multi-family. The Code also allows manufactured housing on any residential lot
and contains provisions for the siting of new manufactured housing communities.
Analysis
Although the inventory of housing
information and the buildable land
Council, the Comprehensive Plan
promote affordable housing in Yelm
should be updated with the latest census
s report from the Thurston Regional Planning
and Development Regulations do allow and
December 15, 2004 Page 10 of 16
The amount of affordable housing that the City of Yelm and Thurston County
targets to provide is still valid as it is a function of the population distribution as
part of the population forecasts. As noted before, the latest information from the
US Census and the Thurston Regional Planning Council validate the population
forecasts in the original Comprehensive Plan.
Conclusions
The Comprehensive Plan is consistent with the provisions of the Growth
Management Act as they relate to affordable housing. The housing inventory
should be updated with more current information that is available now.
December 15, 2004 Page 11 of 16
Transportation
GMA Goal -Encourage efficient multimodal transportation systems that are based on
regional priorities and coordinated with county and city comprehensive plans.
GMA Requirement - A transportation element of the Comprehensive Plan which:
• includes land use assumptions used in estimating travel
• estimates local traffic impacts on state-owned transportation facilities
• identifies facility and services needs, including: an inventory of facilities; level of
service standards (LOS); specific actions needed to bring into compliance any
local facilities that are below the relevant LOS; forecasts of traffic for at least ten
years; and identification of state and local system needs to meet current and
future demands
• includes amulti-year financing plan, including a discussion of what to do if
probable funding falls short of identified needs
• promotes intergovernmental coordination efforts
• identifies demand-management strategies
GMA Requirement -Adopt concurrency regulations. These regulations prohibit
approval of new development unless there will be adequate transportation facilities to
accommodate them concurrent with the development.
Yelm Comprehensive Plan Policies
The Comprehensive Plan at Chapter six adopts the level of service for the street system
with the Yelm Urban Growth Area. Adopted as part of the Comprehensive Plan, as
exhibits and appendices are the Regional Transportation Improvement Plan, which was
updated by the Thurston Regional Planning Council in 2004 and the Yelm
Comprehensive Transportation Plan, which was updated in 2001.
The land use assumptions used for travel forecasting are found in Chapter 3, Land Use.
Along with the land use assumptions of the other jurisdictions in Thurston County, they
form the basis for the travel demand modeling of the TRPC Regional Transportation
Plan (RTP). This county-wide model is used by all the local jurisdictions, which all use
each others' land use plans and zoning to define a common and integrated county-wide
set of modeling assumptions. The RTP addresses freeways, major arterials, collectors,
and transit service. This modeling also addresses impacts of local traffic on state
facilities, such as State Route 507 and State route 510 in Yelm.
The inventory of facilities is found in the Comprehensive Transportation Plan. The
accepted level of service standards are listed in the policies of the plan. There are no
local facilities currently failing to meet their adopted level of service.
December 15, 2004 Page 12 of 16
Intergovernmental coordination is accomplished mainly through using a common area-
wide transportation planning program, the Regional Transportation Plan.
Yelm Development Regulation Requirements
Chapter 15.40 Yelm Municipal Code contains concurrency requirements for the
transportation system. A traffic facilities charge is required for all new
development, as is street frontage improvements and off-site improvements
attributable to impacts from a proposed development.
The City annually adopts asix-year transportation improvement plan, based on
the Transportation Comprehensive Plan.
Conclusions
The Comprehensive Plan is consistent with the transportation requirements of
the Growth Management Act.
December 15, 2004 Page 13 of 16
Public Facilities
GMA Goal -Ensure that those public facilities and services necessary to support
development shall be adequate to serve the development at the time the development
is available for occupancy and use without decreasing current service levels below
locally established minimum standards.
GMA Requirement -Identify facility needs, the costs to provide them, and how to
finance them. The Capital Facilities Element of the Plan must include:
• An inventory of existing capital facilities owned by public entities, showing the
locations and capacities of the capital facilities;
• a forecast of the future needs for such capital facilities;
• the proposed locations and capacities of expanded or new capital facilities;
• at least asix-year plan that will finance such capital facilities within projected
funding capacities and clearly identifies sources of public money for such
purposes; and
• a requirement to reassess the land use element if probable funding falls short of
meeting existing needs and to ensure that the land use element, capital facilities
plan element, and financing plan within the capital facilities plan element are
coordinated and consistent. Park and recreation facilities shall be included in the
capital facilities plan element.
Yelm Comprehensive Plan Policies
The Yelm Comprehensive Plan at Chapter 5 identifies public facilities, including
municipal sewer and water infrastructure, private utilities such as natural gas and
telephone, and schools. Further, the Comprehensive Plan adopts as Appendices
the following documents, which contain inventories and improvement plans for
the specific utility:
• Yelm Comprehensive Water Plan, amended in 2002
• Yelm Comprehensive Sewer Plan
• Yelm Parks Plan
Chapter 10 of the Comprehensive Plan is the Capital Facilities Plan.
Yelm Development Regulation Requirements
Annual capital facility planning and budgeting implements the policies of the
Comprehensive Plan as they relate to public facilities.
December 15, 2004 Page 14 of 16
Analysis
The City has adopted concurrency management as Chapter 15.40 YMC. This
chapter requires a finding of concurrency for sewer, water, parks, and schools
before a development may be approved.
The Parks Plan and the Capital Facilities Chapter of the Comprehensive Plan
should be updated. The City is working towards adopting a Comprehensive
Reclaimed Water Plan.
Conclusions
The Yelm Comprehensive Plan is consistent with the provisions of the Growth
Management Act relating to public facilities.
December 15, 2004 Page 15 of 16
Shoreline Master Program
GMA Requirement -The goals of the Shoreline Management Act are adopted as goals
of the Growth Management Act. The goals and policies of the local Shoreline Master
Programs to be part of local GMA comprehensive plans. The regulations of the local
Shoreline Master Programs are also considered by state law to be development
regulations of the local communities.
GMA Requirement -Adoption or amendment of Shoreline Master Programs must also
be conducted pursuant to the Shoreline Management Act (RCW 90.58), rather than the
Growth Management Act (RCW 36.70A).
GMA Requirement -The State Department of Ecology has issued guidelines for
updating and amending local Shoreline Master Programs. Thurston County and the
cities within must update their Shoreline Master Programs by a deadline of 2011.
Yelm Comprehensive Plan Policies
The Comprehensive Plan at Chapter 12 indicates that Yelm Creek should not be
designated a shoreline of the state and that the Centralia power canal should. Neither
the City or Washington Department of Ecology has initiated a review of these two water
bodies to determine if they are appropriately designated.
Yelm Development Regulation Requirements
Yelm has adopted the Shoreline Master Program for the Thurston Region,
adopted in 1990. Yelm Creek is the only shoreline of the state identified within
the Yelm Urban Growth Area.
Conclusions
The Comprehensive Plan is currently consistent with the requirements of the
Growth Management Act as they relate to shorelines, as updates to the
Shoreline Master Program are not due until 2011. The City should request the
Department of Ecology review Yelm Creek to determine if it meets the minimum
flows fora shoreline of the state.
December 15, 2004 Page 16 of 16
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STATE OF WASHINGTON
DEPARTMENT OF COMMUNITY, TRADE AND ECONOMIC DEVELOPMENT
128 - 10th avenue SW • PO Box 42525 • 0/ympia, Washington 98504-2525 • (360) 725-4000
May 4, 2005
The Honorable Adam Rivas
Mayor of Yelm
Post Office Box 479
Yelm, Washington 98597
Received
MAY g 2005
RE: Proposed resolution declaring that for purposes of the 2004 update requirement, the comprehensive
plan and development regulations are GMA compliant, with the exception of the critical areas ordinance
which will be updated
Dear Mayor Rivas:
Thank you for sending the Washington State Department of Community, Trade and Economic
Development (CTED) the proposed resolution that we received on March 1, 2005. We recognize the
substantial investment of time, energy, and resources that this document represents.
We especially tike the following:
In general, Ye1m's comprehensive plan is thorough, well-structured, and effective in articulating your
community's vision, goals, and policies. It is clear that Yehn has actively engaged in planning since
the passage of the Growth Management Act (GMA) in 1990, going above and beyond basic GMA
requirements. For example, Yelm adopted Parks/Open Space, Economic Development, Visioning,
Environment, and Historic Preservation elements, none of which are currently required. This
demonstrates a positive, proactive attitude toward planning for Yelm's fiiture.
We are impressed by Yelm's use of anumber offorward-thinking planning approaches. The Land Use
Element includes well-crafted policies for mixed-use development, and policies for development of a
Transfer of Development Rights program to conserve important natural and/or cultural resources. The
Housing Element includes a policy calling for permitting accessory dwelling units in all residential
zones within the city, which will increase the diversity of Yelm's housing supply. The Environment
Element includes policies calling nat only for protection., but also for restoration and enhancement of
the city's streams, as well as the direction to view wetlands, rivers, streams, ponds, and lakes as
systems and not as isolated units. We commend you for incorporating these and other positive policies
in your plan.
• We are pleased to note that Yelm's comprehensive plan includes policies calling for the use of best
available science in the designation and protection of critical areas.
We have concerns about the following that you should address before you conclude your 2004 GMA
update process. Our concerns relate to your proposed strategy of adopting a resolution ending Yelm's 2004
update without making any changes to reflect current conditions and recent GMA amendments. The
~~~
The Honorable Adam Rivas
May 4, 2005
Page 2
required GMA update is an invaluable opportunity to take stock that no community can afford to miss-
especially rapidly growing communities like Yelm. Good planning decisions must be grounded in reality
rather than speculation, and to accomplish this you need current and accurate information on conditions,
growth trends and laws. Though communities are constantly working to be up-to-date, the GMA update
represents one point every seven years when communities are required to gather current information and to
conduct an open, broad, and fact-based public discourse on growth issues. We commend you for the steps
you've taken so far, and urge you to address the following concerns as part of Yelm's 2004 update.
An effective and open planning process requires consultation with adjacent jurisdictions, state agencies,
and other stakeholders, as well as ample opportunity for members of the public to provide comment.
Although Yelm has taken steps including holding public meetings and submitting this resolution to
CTED, the record does not show that Yelm has actively consulted with stakeholders including
Thurston County, neighboring jurisdictions, and other interested state agencies. We urge to you do so.
Furthermore, as you move forward you should build a strong record of your process. A thorough
record of the public participation, consultation, and analysis that underlies the decisions you ultimately
make is essential in making the process transparent, accountable, and open.
Yelm's current plan covers a planning period ranging from 1995 to 2015-only ten years from the
present. We are concerned that this period does not look ahead far enough to meet the GMA's
requirement to ensure that projected future growth can be adequately accommodated. RCW
36.70A.110(2) requires local governments to utilize the state Office of Financial Management's (OFM)
growth management population projections for the succeeding 20 _yeczr period' and to ensure the areas
and densities included in the urban growth area (UGA) are sufficient to accommodate that growth. As
you know, Thurston Regional Planning Council (TRPC) makes growth projections for individual
Thurston County cities. TRPC's projections of continuing rapid development in Yelm highlight the
importance of taking this opportunity to make sure projected growth can be accommodated by
available land, facilities, and services.
Including the latest growth projections is not just an academic exercise; it's a vital step that is at the
crux of managing growth. Matching projected growth with land supply and densities, and with future
availability of facilities and services, enables an accurate understanding of the implications of future
growth. Without this analysis, the consequences of today's decisions cannot be accurately understood
or communicated to decision-makers and the public. We urge you to take this opportunity to
incorporate the latest dat~TRPC's 20-year growth projections-and to analyze their implications for
Yelm's policies and regulations.
Yelm's current UGA boundaries were set nearly ten years ago in 199, and are based on 1995 to 2015
population projections. We advise you to reassess the size and development capacity of your UGA as
part of your 2004 update. A core requirement of the GMA is to ensure that the city will be able to
accommodate the expected growth and still provide adequate public facilities. To do so, the city will
need to analyze its available land supply and densities. Doing this work ties logically into an
assessment of the size and capacity of Yeim's UGA.
The GIv1A requires UGAs to be assessed once every ten years, but it does not require the UGA
assessment to occur on the same schedule as the seven-year GMA updates. Since Yelm adopted its
current UGA boundaries in 1995, arguably you could choose to push the UGA assessment into your
2005 comprehensive plan docket. However, we advise you to review Yelm's UGA boundaries as part
of your 2004 update. If you take our advice, you will already be doing much of that work as part of
your update. Also, because of the interconnectedness of the issues, doing this simultaneously is
The Honorable Adam Rivas
May 4, 2005
Page 3
probably the most logical and transparent approach from the perspective of citizens and other
stakeholders. You will note that this is the approach taken by the other'Thurston County jurisdictions,
which can serve as useful local examples.
According to Thurston County Countywide Planning Policies (CWPPs), Thurston County cities have
the role of initiating review of UGA boundaries, while the county has ultimate decision authority. We
recommend that you initiate discussion with the county on this matter very soon. Since the county has
already completed its 2004 comprehensive plan update, it will not be able to take final action on
Yelm's UGA until it acts on its 2005 comprehensive plan docket (typically in November or December).
This gives Yelm some time to work with county staff to conduct its UGA analysis and be ready in time
for the county to take action this year. We are enclosing a CTED publication titled The Art and Science
of Designati~zg UGAs that we hope will be of assistance to you in assessing your UGA.
Yelm's plan does not include a current summary of planned capital facilities expenditures over at least
the following six years. To ensure the capital facilities plan will be effective, the GMA requires local
governments to adopt asix-year plan (at least) showing how they wilt finance planned capital facilities
within projected funding capacities, and that clearly identifies sources of public money for such
purposes. We advise you to develop and adopt an up-to-date six-year (or more) summary. We note
that Yelm has adopted separate functional capital facilities fiscal plans in the relatively recent
Comprehensive Transportation, Water and Parks Plans. However, presenting a current summary of
Yelnn's capital facilities planning in the Capital Facilities Element will make the information clear,
explicit, and complete, and thus effective in demonstrating that the numbers add up and the plan will
work.
Broadly speaking, we urge you to take this opportunity to ensure that the Land Use and the Capital
Facilities elements are fundamentally linked. The GMA requires that capital budget decisions be made
consistent with the comprehensive plan, and that public facilities keep up with the pace of
development. In particular, the Capital Facilities Element and the Land Use Element work together to
ensure that finances can keep up with growth-related expenses. All capital facilities decisions must
rely upon the growth projections in the Land Use Element in order to estimate the need for future
facilities and services. For that reason, the GMA requires that local governments reassess the Land Use
Element if probable funding falls short of meeting existing needs, and take any other necessary
measures to ensure that the Land Use Element, Capital Facilities Element, and financing plan within
the Capital Facilities Element are coordinated and consistent. Taking time to step back and make sure
this is happening now can bring your community both savings later, and can preserve future
opportunities to accomplish community goals.
Yelm's current Housing Element does not include an up-to-date housing inventory. Goal 4 of the
GMA calls on each community to encourage the availability of affordable housing to all economic
segments of the population of this state, promote a variety of residential densities and housing types,
and encourage preservation of existing housing stock. To accomplish this goal, each community must
include an inventory and analysis of existing and projected housing needs as a result of population
growth over the planning period. We urge you to conduct any data gathering and analysis necessary to
produce a current housing inventory, and to include it in your housing element.
• In 2004 the GMA was amended to add two new requirements for communities adjacent to a military
base employing 100 or more personnel, and operated by the U.S. Department of Defense. Because of
Yelm's adjacency with Fort Lewis, RCW 36.70A.530 requires the city to adopt policies, land use
designations, and zoning to discourage the siting of incompatible uses adjacent to military bases. It
The Honorable Adam Rivas
May 4, 2005
Page 4
also requires the jurisdiction to notify the base commander of any amendments to comprehensive plan
and development regulations on lands adjacent to the base. The protection of military installations
from incompatible development of land is vital to Washington's economy and quality of life. We urge
you to draft and include such policies in your comprehensive plan, and to actively consult with Fort
Lewis' base commander as you continue your update process.
Yelm's current plan includes a policy in the Environment Element that the city will utilize the Army
Corps of Engineers' definition of wetlands (see EP 1 S, page XII-S). We advise you to use Washington
State Department of Ecology's {Ecology) wetland defmitions. RCW 36.70A.030(20) directs local
governments to utilize Ecology's wetland definitions, and RCW 36.70A.175 requires the use of
Ecology's wetland delineation standards. Ecology's system was tailored to fit the GMA's best
available science requirement, and is an excellent source of science for Washington jurisdictions.
We have some suggestions for strengthening your plan and development regulation amendments that we
encourage you to consider either in these or future amendments:
• Currently, Yelm's regulations include one residential zoning district, which covers a large area of the
city, with a density range from 0 to four dwelling units per acre. We suggest you consider increasing
the maximum permitted density, as well as adopting a minimum density, in this zone in order to
achieve the benefits of more compact development. Under the GMA, there is a clear intent that urban
services be available to development that is urban in nature. Developing land in urban areas at higher
densities allows the city to more cost-effectively provide urban services, allows for more amenities,
promotes walking and other non-motorized forms of transportation, and conserves open space. This
supports a number of GMA goals, as well as many of Yelm's comprehensive plan goals. Also,
increasing permitted densities would raise Yelm's development capacity, and thus influence your
assessment of Yelm's UGA boundaries.
Many communities, including smaller ones, have found that increasing density to reasonable urban
levels helps them to achieve their community's vision for the future.' The GMA does not spell out
exactly what constitutes an urban density, and to date the Western Washington Growth Management
Hearings Board (which would hear any GMA appeals in Yelm) has not clarified that issue. However,
Yelm can look to the Central Puget Sound Hearings Board for some guidance, and that board has
indicated that in general four dwelling units per net acre should be considered the minimum urban
density.'` We would be glad to provide information on context sensitive approaches to accommodating
higher densities.
• Yelm's current comprehensive plan includes references to short -and long-term UGA boundaries as a
method of phasing growth. Having tvvo different UGA boundaries is not consistent with Thurston
County's adopted comprehensive plan, which indicates only one UGA boundary. However, growth
phasing is an innovative practice that can provide benefits including preventing leapfrog development
and facilitating a more rational and efficient program of infrastructure extension. We suggest you take
this opportunity to consider approaches to putting growth phasing into practice. One approach could
involve modifying the development regulations affecting the unincorporated UGA. We suggest you
initiate discussions with Thurston County on this, as the body administering land use decisions in that
area. Another approach could be modifications to Yelm's policies for annexations and extensions of
For additional infonnaflon, we are enclosing a recent Urban Land Institute publication on the benefits of higher
density development, titled Higher Density Development, Myth and Fact.
z For more information on residential densities, see CTED Guidance Paper: Urban Densities-Central Puget Sound
Edition, available online at tivti+~e~.cted.wn.gov/growth_
The Honorable Adam Rivas
May 4, 2005
Page 5
services through the capital facilities program. Please let us la~ow if we can provide assistance or
examples of effective growth phasing programs.
To clarify procedures for amending the comprehensive plan, we suggest that you add a policy that
Yelm will follow the amendment procedures as spelled out in RCW 36.70A.130. Also, we suggest
setting out a procedure for adopting emergency amendments, along with a definition of what
constitutes an emergency, justifying a comprehensive plan amendment outside of the standard
docketing procedures [see RCW 36.70A.130(2)(b}]. Adding citations of these state requirements
would clarify the process for citizens and other interested parties.
Congratulations to you and your staff for the good work this amendment embodies. If you have any
questions or concen~s about our comments or any other growth management issues, please call me at
(360) 725-3057. We extend our continued support to tl~e City of Yelm in achieving the goals of growth
management.
Sincerely,
Elliott Barnett
Grotivth Nlanagemer~t Planner
Growth Management Services
EB:Iw
Enclosures
cc: Grant Beck, City Planner
3ennifer Hayes, Associate Planner, Thurston County
Leonard Bauer, AICP, Managing Director, Growth Management Services, CTED
David Andersen, AICP, Planning Review Team. Manager, Growth Management Services, CTED