1. Proponent: Clallam County Fire District 3 c/o Stephen S. Vogel, Fire Chief 323 North 5th Ave. Sequim, WA 98362

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1 Comprehensive Plan and Zoning mendment REZ , Staff Report Clallam County Department of Community Development January 15, 2004 Prepared by the Clallam County Department of Community Development, Planning Division 223 East Fourth Street, Port ngeles (360) PROJECT INFORMTION 1. Proponent: Clallam County Fire District 3 c/o Stephen S. Vogel, Fire Chief 323 North 5th ve. Sequim, W gent: Louis. Torres, II 1620 W. 13th St. Port ngeles, W Request: The proposed action is a Type C Rezone to amend the Clallam County Comprehensive Plan Land Use Designation Map and Zoning Map for the property described below. pproval of the request would allow a change in the comprehensive plan and zoning map of approximately 9.25 acres of land from Carlsborg Residential (CR), to Public (P) within the Carlsborg Urban Growth rea (UG). The subject property is owned by Clallam County Fire District #3. 3. Location: The property is located on the west side of Carlsborg Road, north of Greywolf Elementary School, and approximately 100-feet east of Matriotti eek (Figures 1-3). The property is legally described as Parcel, as shown on BL Survey, recorded under Volume 50 of Surveys with the Clallam County uditor, Page 21, also being a portion of the NW1/4 of the NE1/4 of Section 22, Township 30 North, Range 4 West, W.M. It is referenced by ssessor's Tax Parcel Number Property Characteristics: Figure 2 provides an aerial view of the subject property taken in The property is approximately 9.25 acres in area, and currently vacant. The site is generally flat with only a slight grade sloping towards the west. Vegetation on the site consists primarily of grasses and low-lying shrubs (Figure 2). The eastern side of the property contains approximately 528 feet of frontage along Carlsborg Road, a county road facility. 5. Current Comprehensive Plan and Zoning Designation: The property is currently designated by the Comprehensive Plan Land Use Map as Carlsborg Residential (CR), is designated with the zoning district of the same name (CR), and is subject to the standards of the Zoning Code found under C.C.C through , as applicable to the CR zone. The 1

2 property is presently located within the Carlsborg Urban Growth rea (UG) of the Sequim-Dungeness Regional Planning rea (Figure 3). 6. Shoreline Designation: No portion of this site is within the jurisdiction of the Clallam County Shoreline Master Program. 7. Previous Permits: There are no development permits on file with the Department of Community Development for the subject property. 8. itical reas: The subject property is located within an area classified as a itical quifer Recharge rea pursuant to C.C.C ll new development will be subject to the standards of C.C.C Matriotti eek, a Type 3 stream, is located approximately 100-feet west of the subject property (Figure 2). The Clallam County itical reas Ordinance maintains a 200-foot jurisdiction around all natural features regulated by the Ordinance (including Type 3 streams). Future development of the site may be subject to the standards of C.C.C , as may be applicable. 9. Surrounding Land Uses and Zoning: Figures 1 and 2 show zoning and current land uses in the vicinity of the subject property. Lands bordering the subject property to the north, east, and west are zoned Carlsborg Urban Residential, similar to the subject property. Greywolf Elementary School is located to the south and is zoned Public Land (P), which is the same designation being requested by the applicant. The eastern property line abuts Carlsborg Road. Properties east of Carlsborg Road are characterized by residential development on lots generally ranging from 0.5 to 1 acre in size. There are five residential driveways leading to homes directly across Carlsborg Road from the 538 foot frontage of this parcel on that road. The property to the north is residential lands within the Carlsborg UG which have been partially developed for residential use. The property most immediately adjoining the subject property is vacant, but is currently the subject of a 32-lot subdivision with approval pending (LDV ). The western edge of the property abuts a parcel designated as a buffer area (i.e., not a building site) along Mattriotti eek (Figures 1 and 2). The designated buffer area was created though a short plat of the subject property and surrounding lands in The buffer is approximately 100 to 136 feet in width. Lands west of Matriotti eek are located outside of the Carlsborg UG and are designated as rural lands (Figures 1 and 3). The rural designation directly west of the creek and the subject property is Rural (R), which supports a maximum residential density of 1 dwelling unit per acre. The existing Carlsborg Fire Station is located near the subject property and contains the same comprehensive plan and zoning designation of Public Land as being requested for the subject property (Figure 1). The current 2

3 station consists of a combination three (3)-bay vehicle and equipment housing and office space. The "pparatus Bay" is approximately 1,625 square feet in area, and the "living area" is approximately 1,300 square feet in area, for a total of 3,125 square feet of structural improvement. The property is approximately 0.57 acres in area, and includes two lots (Lots 14 & 15, Sequim Valley Tracts, V. 5 of Plats, P. 72). 10. Public Services in rea: Public facilities serving the subject property include Qwest Telephone service and PUD #1 of Clallam County (water and electrical service). s shown in Figure 4, the applicant, Clallam County Fire District #3, provides fire and emergency protection services for rural and urban areas of eastern Clallam County. 11. Public Notice Dates: notice of any public hearing before the Planning Commission and Board of Commissioners will be required at a minimum of ten days before those respective hearings. Public notice will include mailings to adjacent property owners (within 300 feet of the subject property) and publication in a newspaper of general circulation. 12. SEP Review/Decision: The Clallam County Responsible Official issued a Mitigated Determination of Non-Significance (MDNS) on December 29, 2003 for the requested amendment and a phased project action review for future development of the subject property for a fire station and related support facilities. ppendix B contains the completed Environmental Checklist submitted with the application, the County s MDNS, comments received, and other related information pursuant to the County s review of the application under the State Environmental Policy ct (WC197-11) fourteen (14)-day comment period was granted to receive any pertinent comments regarding the proposal. Comments were received from the Clallam County Public Roads Department Clallam County Building Division, and Clallam County Natural Resources Division. Comments were also received from the Washington Department of Ecology after the comment period expired on January 21, The Fire District s environmental checklist submitted as part of the application notes that the intent is to relocate the existing Carlsborg Fire Station (Figure 2) and the district s maintenance and operations center to the subject property. The checklist further indicates that new fire station would be of larger scale and include development of fire suppression training areas. In total, it is anticipated that more than 70% of the 9.25 acre site will ultimately be made impervious due to placement of buildings and paving (concrete and/or asphalt) for parking and the training and practice area. The proposed new fire station facilities and services would include: an approximately 22,500 sq. ft. fire station, 8,000 sq. ft. maintenance and operations facility, 3,200 sq. ft. vehicle parking garage, 300 sq. ft., hose practice tower, 375 sq. ft. burn building, and 800 sq. ft. storage building. 3

4 Matriotti eek Figure 1 Vicinity Zoning REZ N CR CR R1 Carlsborg Rd. Subject Property CR P Greywolf Elementary CR Legend Fire District Property Highways Roads Parcels Streams (24K) UGs Zoning (Outline) Prepared by Clallam County Department of Community Development January, 2004 SR 101 P CGC Current Fire Station

5 N Existing Residentia l rea Figure 2 Vicinity irphoto REZ Proposed 32-Lot Subdivision (Currently in Process) Subject Property Carlsborg Rd Existing Residential rea Greywolf Elementary Legend Fire District Property Highways Roads Parcels Streams (24K) UGs Prepared by Clallam County Department of Community Development January, 2004 SR 101 Fueling Station Current Fire Station

6 The subject property is also targeted for development as a future practice and training location for District #3 personnel, with the possibility of other districts utilizing this site for that purpose in the future. Training facilities envisioned include large, open paved areas for suppression drills, equipment practice, burn building, oil and gas pans on flame pad (extinguisher/foam suppression), emergency vehicle accident prevention training, tower (stair, ladder and sprinkler practice), pump practice/testing use of drafting pond, hydrant/hose drills. The MDNS included three mitigation requirements for the project proposal described in the Checklist, including: Mitigation of road impacts by installing a left turn lane along Carlsborg Road; Mitigation of surface and ground water impacts by requiring an engineered drainage and erosion control plan that addresses water quality and quantity control of storm water; and Requiring suitable area abutting Carlsborg Road to accommodate future sidewalk improvements. The MDNS recognized the preliminary nature of the project proposal. For any substantial change from the proposal described in the Environmental Checklist and any subsequent permit application for the property, SEP would need to be revisited. 4

7 Bell River Gierin Cassalery Sequim Figure 3 Locater Map REZ Woodcock Rd N SR 101 Meadow br Matriotti Dungeness Taylor Cutoff Rd Old Olympic Hwy Subject Property Carlsborg Rd SR 101 tterberry Rd Matriotti Gold

8 SR 101 Figure 4 District 3 Boundary REZ N Strait of Juan de Fuca Dungeness Bay Sequim-Dungeness brook Bell Cassalery Gierin Meadow Dungeness River Woodcock Rd Old Olympic Hwy Matriotti Matriotti (/ 101 Subject Property Sequim d McDonald Pederson Sequim Bay Siebert Gold Frog Bagley Eagle McDonald Blue Mt. Rd Legend Dungeness Johnson East Bear urveyor Little Fork Dean Siebert Fire District 3 Fire District Property Highways Roads UGs Cities lately come West Fork Siebert Jimmy River Jimmy Caraco O'Brien Rd Kitchen Dick Rd E. Sequim Bay Rd SR 101 Diamond Pt. R Maiden Taylor Cutoff Rd Carlsborg Rd Bagley eek Rd Fork East comelately Prepared by Clallam County Department of Community Development February, 2003 Palo lto Rd Jimmy Pats

9 B. PLNNING DIVISION NLYSIS The Washington State Growth Management ct (GM) requires that amendments to comprehensive plans, occur no more frequently than once per year in order to allow communities to consider the cumulative impacts of proposed revisions (RCW (2)). Clallam County's comprehensive plan amendment process is also structured to comply with this requirement by requiring a consolidated review of all comprehensive plan and zoning amendment applications under one public hearing process, on an annual basis (C.C.C through.370). pplications for comprehensive plan and zoning amendments must be received by September 30th of a given calendar year for consideration in the following year. Clallam County received an application on September 29, 2003, to change the comprehensive plan land use and zoning designation for the subject property from Carlsborg Urban Residential (CR) to Public (P). Pursuant to CCC , the Department of Community Development reported to the Planning Commission in December 2003/January 2004 concerning amendment applications received in 2003 for consideration in The proposed change is now before the Clallam County Planning Commission for consideration. The Planning Commission must complete their review within nine (9) months, and forward a recommendation to the Board of Clallam County Commissioners (BOCC), following notice and a public hearing. The Planning Commission must include findings of fact and conclusions of law upon which its action is based regarding approval and denial of the amendment application. The BOCC must complete their review and render a final decision within ninety (90) days after receiving the recommendation of the Planning Commission, following notice and a public hearing (C.C.C ). Relationship to GM Review and Update Process The GM requires that Clallam County take legislative action to review and, if needed, revise its comprehensive plan and development regulations no later than December 1, 2004, and at least every seven years thereafter (RCW (1)). Clallam County is required by state law to establish a public participation program as part of this process. This state mandated review is intended to ensure that the plan and regulations continue to comply with the requirements and purpose of the GM. The required 2004 GM Update is a complex process that includes a wide scope of issues. The GM does not exempt any portion of a comprehensive plan or development regulation from being subject to review and evaluation. In contrast, the three (3), 2003 comprehensive plan and zoning amendment applications are much more limited in scope to the setting of the subject properties and land use issues related thereto. These are also applications for which private land owners have made formal requests for specific consideration, submitted all the necessary paper work, and paid application fees in order to receive this specific consideration. The BOCC has adopted a "Public Participation Plan, Clallam County 2004 Growth Management ct Update" on January 13, 2004 (Resolution No 15, 2004). The plan establishes the procedures and work schedule to guide the 2004 GM evaluation and update process. The work schedule set forth by the Public Participation Plan integrates review of the three comprehensive plan and zoning map amendment applications submitted 6

10 in 2003, including the application subject to this analysis (REZ ). Integration is necessary to comply with county and state requirements that all amendments to the comprehensive plan can occur no more frequently than once a year, as mentioned previously. Specifically, the public participation plan directs that the Planning Commission hold four regional public hearings in late-pril/may to gather and consider public input on: 1) the three 2003 comprehensive plan and zoning map amendment applications; 2) County compliance with the GM; and 3) any other proposed amendments to the comprehensive plan and development regulations. Listed below are the scheduled dates and locations for these regional public hearings: pril 28 - Carrie Blake Park, 202 N. Blake ve., Sequim May 5 - Clallam County Courthouse, 223 E. Fourth St., Port ngeles, Room 160 May 19 - Forks Middle School, 121 S. Spartan ve., Forks May 26 - Sekiu Community Center, 42 Rice St., Sekiu (ll Hearing Begin at 6:30 p.m.) The Clallam County Department of Community Development is preparing staff reports on the three amendment applications (includes this report), a growth monitoring report, and GM compliance checklists/reports, in preparation for these regional public hearings. The Department will also hold regional community open houses starting in late-february as part of the GM evaluation and update process. Following consideration of public comments received at the regional public hearings, the Planning Commission must forward their findings and recommendations to the BOCC. These findings and recommendations must address: 1) the three map amendment applications (including this application); 2) GM compliance; and 3) any identified recommended comprehensive plan and development regulation amendments based on their GM compliance review and public testimony received. ccording to the Public Participation Plan, the target date for forwarding Planning Commission findings and recommendations to the BOCC is June 16, The BOCC must hold at a minimum at least one public hearing to consider the recommendations of the Planning Commission. The Public Participation Plan indicates that BOCC review and hearings are targeted to occur in late-july/ugust. Required Showing for mendment In taking action on an application for a comprehensive plan land use and zoning amendment, the Board of County Commissioners makes policy decisions that not only directly impact the subject property owners, but directly and indirectly impact other property owners, both in the immediate area and throughout the County. Zoning designations control what uses are permitted or prohibited on a particular piece of property. While an applicant may have a specific use in mind that he or she is able to achieve through a change in zoning, the applicant is nevertheless under no obligation to limit land use activities to that 7

11 original plan. The applicant would in fact be eligible for any of the land uses listed as Permitted Outright in the underlying zoning district. For this reason, an evaluation of a comprehensive plan and zoning map amendment application must consider all possible uses allowed under the proposed zoning district. dditionally, a decision on a comprehensive plan and zoning amendment must be evaluated with respect to its application to other similarly situated properties. If the facts of a particular application approved by the Board of County Commissioners are present in a subsequent application, then the subsequent application should also be approved to be fair. For this reason, decisions on map amendments must be considered in a much larger context than only the subject property or the expressed land use intent indicated by the applicant. n evaluation of the cumulative effects of a decision to approve or deny a particular application must consider whether the rationale for the decision would be sustainable and consistent with adopted policies and standards if applied to similarly situated properties across the County. Even changes in zoning that result in relatively small conflicts with the Comprehensive Plan may cumulatively impact land use policy objectives if allowed to proliferate across the County. Therefore, any decision on a comprehensive plan and zoning amendment application must be made cognizant of this potential. In considering an application for a comprehensive plan land use and zoning amendment, the Planning Commission and Board of County Commissioners are required to evaluate the amendment with regard to five (5) specific criteria contained in Section of the Zoning Code, and Section of the Comprehensive Plan. These five (5) criteria, or "Required Showing for an mendment" provide the scope of consideration that the Planning Commission and Board must respond to in order to determine if a comprehensive plan and zoning map amendment is to be approved. The required showing includes the following: 1. That the proposed amendment is consistent with the spirit and intent of the Clallam County Comprehensive Plan. NLYSIS. The subject property is owned by Clallam County Fire District #3, which provides fire protection and emergency services for eastern Clallam County. Figure 4 shows the extent of service area boundaries for Fire District #3. The comprehensive plan states that the main station for the Fire District is within the City of Sequim, with other stations located at Carlsborg, Blyn, Diamond Point, Dungeness, Lost Mountain and R Corner. CCC (8). The application (ppendix ) indicates that the subject property is intended to be a replacement fire station for the existing Carlsborg Fire Station (Figure 2). The community of Carlsborg was designated by Clallam County as an urban growth area in key purpose of the County s comprehensive growth management plan is to identify urban areas where public facilities and services can be provided efficiently; ensure that public facilities and services keep pace with growth so that service levels are not diminished; and plan for where facilities and services will be located. CCC (2). Location of fire protection and suppression facilities within urban growth areas is supported by the comprehensive plan. CCC , CCC (4). Both the GM and comprehensive plan define urban services and public facilities to include fire protection and suppression services. RCW (12, 19), CCC (28, 8

12 35). Furthermore, the plan does support development of adequate fire protection services within UG, and directs that such facilities in urban areas should receive first priority. The applicant indicates in their application (ppendix ) that a public land designation would not be inconsistent with the other lands designated as Public Land. The Sequim- Dungeness Regional Comprehensive Plan establishes a Public Land designation pursuant to CCC , and indicates that such designation is for park land facilities. However, similar to other County planning areas, the adopted comprehensive land use and zoning map for the Carlsborg UG does contain non-park land facilities designated as Public Lands, including the existing Carlsborg Fire Station. Other properties designated Public Land inside the Carlsborg UG include Greywolf Elementary School (along south boundary of subject property), Clallam County Public Utility District (PUD) Operations Center, a PUD owned well-site, and a U.S. Post Office. Section (8)(C)(i), C.C.C., of the Sequim-Dungeness Regional Plan states that "[i]n order to help provide consistency and certainty for landowners, the Carlsborg UG shall not be comprehensively reevaluated for changes in land use designations for a period of ten (10) years from the date of adoption of this policy." The intent of this policy is to ensure that the UG as a whole is not continually reevaluated for large-scale land use and zoning changes in order to maintain stability and predictability with the current policies and regulations. The proposed change does not represent a comprehensive reevaluation in that it only applies to one individual parcel, which represents approximately 1.6% of the total area of the Carlsborg UG. It should be noted that another application for amendment of land use designations within the Carlsborg UG is also under consideration. This application, if approved, would result in removal of 1.17 acres of land from the Carlsborg UG. The two Carlsborg map amendment applications total 10.5 acres, or 1.8% of the Carlsborg UG, and affect two individual ownerships. For more information on the other Carlsborg UG land use and zoning change request is found in the staff report pertaining to this application (REZ ). Consideration of map amendments affecting less than 2% of the UG does not appear to constitute a comprehensive reevaluation. The subject property does, however, represent a change in land use designation from urban residential lands to public lands. The purpose of the current Carlsborg Urban Residential (CR) land use designation is to provide for areas of single-family and multi-family residential development that are generally free from encroachment of commercial and industrial activities CCC (9) (b) (i). Development of public facilities such as fire stations under the current Carlsborg Urban Residential land use and zoning designation is not specifically addressed by land use policies for the Carlsborg UG. s noted above, the location of fire stations and other public facilities and services inside of the Carlsborg UG is consistent with the overall policy intent to locate such facilities in UG s. The existing Carlsborg fire station is located directly across Carlsborg Road from Greywolf Elementary School and borders an established residential area to the north (Figure 2). The subject property exhibits similar circumstance in that the school site is located along its southern boundary and a 32-lot residential subdivision is currently under review to the north. The western boundary is bordered by a 100-foot buffer to protect Matriotti eek, which is planned for a future potential public trail to connect to the existing Olympic Discovery Trail that crosses the northern portion of the Carlsborg UG (Chapter 10, Carlsborg Capital Facilities Plan). 9

13 ppendix C contains excerpts of the Clallam County Comprehensive Plan that appear particularly applicable to this application. Comprehensive plan goals, policies, and land use map designations provide the framework for land use regulations (e.g., zoning) and decisions in Clallam County. 2. That the proposed amendment is consistent with the spirit and intent of the Zoning Code and all other County road, utility, land use and environmental plans and policies adopted by the County. NLYSIS. The applicant indicates (ppendix ) that provision of fire protection services within the Carlsborg UG is consistent with the spirit and intent of the comprehensive plan and zoning code applicable to Carlsborg, as well as the capital facilities needed for that area and the surrounding fire district. Consistency with the comprehensive plan was discussed under the previous criteria. This section addresses consistency with the zoning code and other County road, utility, land use and environmental plans and policies. Consistency with Zoning Code The spirit and intent of the Clallam County Zoning Code is best defined under the Purpose Statement of Section C.C.C. (ppendix C). This Section identifies a clear link between the Zoning Code and the Comprehensive Plan in that the Zoning Code is to: direct growth and development in the County consistent with the Comprehensive Plan (Subsection 2); and implement the goals and policies of the Comprehensive Plan in a manner which protects private property rights and in the least intrusive manner possible (Subsection 6). The Greywolf Elementary School site is located along the southern boundary of the subject property and is zoned Public Land (Figure 1). The Public Land zoning district extends eastward from the school property to include the existing Carlsborg Fire Station property located on the east-side of Carlsborg Road (Figures 1 and 2). pproval of this requested amendment would expand the current area of the Public (P) zone to include the 9.25 acre subject property. The purpose of the Public Lands zoning district is to identify properties used for public purposes such as public buildings, schools, cemeteries, parks, playgrounds and recreation areas (CCC ). key criteria of lands included within the Public Lands designation is that the property is used (emphasis added) for public purposes. lthough the land is currently vacant, the application meets this basic intent in that the property is owned by Clallam County Fire District #3, and according to the application materials and environmental checklist submitted by the applicant (ppendices and B), was purchased with the intent of relocating the existing Carlsborg Fire Station and expanding fire protection services on the subject property. The subject property and properties to the west, north and east are currently zoned Carlsborg Residential (CR). The purpose of the Carlsborg Residential (CR) zone is to " provide for areas of single and multifamily residential development that are generally free from encroachment of commercial and industrial activities (C.C.C (1))." Fire stations are not a listed use under the CR zoning district. The zoning code states that unclassified uses may be allowed through the issuance of a conditional use permit [CCC ]. 10

14 ll new public uses, including fire stations, within the Public Land zoning district are also considered conditional uses. This means that conditional use permit (CUP) approval would be required for a fire station under both the current CR zone and proposed Public Land designation. Public Land designation would clarify that public facilities and services such as a fire station are a use supported by the comprehensive plan and zoning code. The conditional use permit process requires a public hearing before the Clallam County Hearing Examiner. The Hearing Examiner may attach conditions to any permit approval to mitigate identified development impacts. Such conditions may include, but are not limited to: landscaping, noise abatement, site access, site size, structure height, siting of structures and improvements, strategies to minimize adverse environmental impacts, etc parking, etc., to assure any identifiable impacts can be mitigated and the development can be carried out in a manner consistent with the character of the neighborhood and intended purpose of the underlying zone. Requiring a CUP for all new uses within the Public Land zoning district provides the public a stronger voice on development of publicly-owned lands. It also recognizes that development of public lands may result in neighborhood impacts (traffic, noise, lighting, etc), which can be identified and appropriate mitigation measures applied through the CUP process. With the requirement for a CUP and the expectation of urban-level developments to occur within the UG, staff does not feel approval of this amendment request would be inconsistent with the spirit and intent of the Public Land zoning designation and the comprehensive plan. Consistency with Other Plans and Policies The comprehensive plan and Carlsborg Capital Facilities Plan contain policies and strategies for transportation and utility (sewage disposal, water supply, electric) provisions to serve the Carlsborg UG. These policies support location of urban land uses on the subject property. Section.12 of this report contains mitigation conditions for transportation, pedestrian, and water quality impacts determined pursuant to the State Environmental Policy ct and Clallam County Environmental Policy (CCC 27.01) related to the intended future development of a fire station and related support facilities. Water supply to serve any future development is available from the Clallam County Public Utility District, which is the preferred urban service provider of water within the Carlsborg UG. Other Clallam County policies pertaining to sewage disposal and protection of critical areas (see Section.8) will also apply to any future development (see Section.8). 3. That the proposed amendment will not be detrimental to the public health, safety and welfare. NLYSIS. The applicant s application (ppendix ) indicates that the proposed public uses will be no more, and potentially less detrimental to public health, safety and welfare than the potential of 18 residential home sites on the subject property that may be approved under the current Carlsborg Residential (CR) zoning. The applicant s environmental checklist (ppendix B) identifies and compares potential impacts under the current and proposed designation related to development of the site as a fire station. Whether future development would result in similar or potentially less detrimental impacts to public health, safety, and welfare depends on what impacts are being evaluated. 11

15 ny future development of the subject property under the Public Land designation will require approval through the conditional use permit process thereby allowing potential impacts to be identified and mitigating conditions imposed to further protect public health, safety and welfare that may be in addition to current building, environmental health, or environmental protection regulations. fire station proposed under the existing Carlsborg Urban Residential zoning designation would face similar CUP requirements. The property has been identified by the applicant (Fire District #3) as a preferred site for relocating the existing Carlsborg Fire Station and development of expanded fire protection facilities and services serving the UG and Fire District #3 service area (Figure 4). The new and relocated facility is intended to address existing and future fire protection needs and services to the public for the Carlsborg UG and Fire District #3 service area. The MDNS (see Section.12) issued for this non-project action and related project action showed that the potential adverse environmental impacts related to the future use of the site (proposed), can be mitigated through application of reasonable conditions. The environmental review document indicated that any substantial change from the development proposal indicated in the Environmental Checklist would require further review under the State Environmental Policy ct (SEP). Between this requirement for SEP review, and the requirement for the conditional use permit process, staff does not believe approval of the requested amendment would introduce or otherwise constitute any significant detriment to public health, safety or welfare. 4. That the proposed amendment is necessary due to changed conditions or circumstances from the time the property was given its present designation which warrants consideration of a different land use [and zoning] designation. NLYSIS. The applicant (ppendix ) indicates that three circumstances have changed since the time the property was originally designated Carlsborg Commercial (CR), which warrants consideration of the requested Public (P) zoning designation. These circumstance include: The property was originally owned by a private property owner, but is now owned by a public agency, being Clallam County Fire District #3, The needs of Fire District #3 for enhanced facilities has become more apparent as growth throughout the district has increased demand for the services provided by the District; and Suitable and strategic locations to ensure effective access and service throughout the district are becoming scarcer. The subject parcel effectively meets the access needs of the District. Providing fire protection services to the Fire District 3 service area (Figure 4) is the applicant's responsibility and area of expertise. The purchase of the subject property by Clallam County Fire District #3 does represent a changed circumstance. This changed circumstance alone would appear to merit consideration for public land designation given that the existing Carlsborg Fire Station and other lands containing public facilities Greywolf Elementary School, U.S. Post Office (Carlsborg Branch), Clallam County Public Utility District (PUD) Operations Center, and a PUD well site are designated as Public Land within the Carlsborg UG. 12

16 The comprehensive plan and Carlsborg Capital Facilities Plan (Ordinance 702, 2000) does not currently identify a need for new and expanded fire protection and suppression services within the Carlsborg UG. However, the applicant s environmental checklist (ppendix B) and other supporting information submitted identify a need for new and expanded fire protection services for Fire District #3. s Figure 4 shows, Fire District #3 provides fire and emergency protection for much of eastern Clallam County, including the communities of Carlsborg and Sequim. ppendix D contains a number of Fire District #3 documents dating from March 23, 1994 to March 21, 2002, highlighting the need for expanded service facilities. The following summarizes the facility demand issues contained in these documents in chronological order: Clallam County Fire Protection District 3, Facilities (March 23, 1994): Regarding the Sequim Fires Station, the document indicates " We are rapidly outgrowing this station. Parking is already inadequate. Sleeping quarters are nearly full and the classroom is too small. Storage is also overcrowded (page 1)." This document also addresses the adequacy of the present stations; indication the District should " consider [new] locations, property and buildings (page 2)." Clallam County Fire Protection District 3, 1994 Plan: Regarding the Sequim Fire Station, the document indicates " We are rapidly outgrowing this station (page 2, #3)." The document references the need for a maintenance shop (page 2, #4). dditional need is also indicated with respect to the Carlsborg Fire Station: " We may also want to look at adding resident quarters to this station also (page 3, #8)." Memorandum to Clallam County Fire District 3 Commissioners from Chief Lowe (December 19, 1995): The document reiterates concerns pertaining to the overcrowding of the Sequim Fire Station (page 1, #3). The document also indicates a budget allocation for a vehicle stall at the County's Grant Road Shop, but that an interlocal agreement with the road Department would first be necessary (page 2, #4). Letter to Chief Lowe from the Facilities Planning Committee (ugust 10, 1998): The letter recommends staffing for the Carlsborg Fire Station, and the need for the remodeling of the station to " meet current codes and operational needs." Clallam County Fire District 3, Goals Setting Workshop (March 21, 2002): This document outlined the results of the Goals Setting Workshop, which identified the need for a training facility as a District deficiency (page 1, #4). The Document includes a Five-Year Plan, which lists "eate training facility, possibly with other fire districts (page 2)" as a Group II Recommendation. 5. That the cumulative effects of proposed amendments have been assessed and determined to be consistent with the spirit and intent of the Clallam County Comprehensive Plan (C.C.C ). NLYSIS The applicant indicates in their application that the cumulative effects of proposed amendments will be determined by the review process to which this application is subjected. Staff concurs that any future development of the subject property will be subject to all applicable local, state and federal regulations. However, this criteria requires consideration of cumulative effects of amending the comprehensive 13

17 plan land use and zoning designation from Carlsborg Urban Residential to a Public Land designation. The cumulative effects of the proposed amendment include a range of probable adverse impacts as well as a range of probable benefits to the community. The possible uses allowed under the Public (P) zone include the whole array of government agency land use activities and developments, and are too numerous to list or even estimate. However, given the ownership of the subject property, future development is likely to be associated with the provision of fire protection services and related development. This assumption is supported by the future land use proposal detailed in the Environmental Checklist. Cumulative environmental impacts were considered in the issuance of the MDNS as described under Section.12 of this report. Location of new and expanded fire protection services within the Carlsborg UG is supported by the comprehensive plan (see also discussion under review criteria 1 above). The existing Carlsborg Fire Station site has very limited potential for expansion of fire protection services to continue to serve the steady residential and business growth within the service area of Fire District #4. Maintaining adequate fire protection services within the Carlsborg UG and along Carlsborg Road is important for a number or reasons: Provides for centralized fire protection services within the Fire District #4 (Figure 4). Provides for fire protection services to an area already characterized by a mix of urban land uses in close proximity to the proposed new fire station site. Provides for fire protection service within an area designated for urban growth. Provides for quick and controlled access (lighted intersection) to Highway 101, which is important to maintain fire and emergency service response time to properties within the service area of Fire District #3. Provides for main fire stations within both the Carlsborg and Sequim UG s, and also on both sides of the Dungeness River, which has limited crossing points that may be impacted during emergencies (accidents, flooding, bridge closures, etc ). The process required for any land use development in the Public (P) zone includes the requirement for conditional use permit approval (C.C.C ). This process ensures that any and all new development is reviewed in a public forum, and that impacts identified as part of the development proposal can be addressed and mitigated through application of reasonable conditions. This substantially reduces the likelihood that substantial cumulative impacts will ever be experienced should this amendment request be approved. Fire stations and other public uses on the subject property may be approved through a CUP under the current Carlsborg Urban Residential designation. Development of public facilities under the requested Public Lands designation would result in similar review of environmental impacts. change in designation to Public Land would be consistent with existing public land designations along the southern boundary or the subject property which contains a public elementary school, it would also establish a clear intent that public uses will be developed on the property, which should result in attracting growth to the UG due to planned improvements in fire protection services. 14

18 Designation of the subject property as Public Land would remove the potential for development of 18 residential units on this 9.25 acre parcel. However, this potential loss of 18 residential units is not anticipated to represent a significant impact to accommodating projected population growth within urban growth areas of eastern Clallam County, as required by the comprehensive plan and state Growth Management ct. The Fire District s intended relocation and expansion of fire district operations to the subject property related to the request for a Public Land designation would result in several other land use changes within the Carlsborg UG, if approved. First, the current Carlsborg Fire Station would no longer serve as a fire station. Second, the District would move its operations and maintenance equipment to the subject property. Fire District #3 currently leases 3,200 square feet of space on Savanna Lane (northern part of UG) to store this equipment. Relocating the fire station and moving equipment to the subject property may result in temporary vacancies of these existing public and commercial storage/warehousing buildings. Relationship to Other pplications The Clallam County Comprehensive Plan requires that comprehensive plan and zoning map amendments be reviewed only once per year " in order to allow communities to consider the cumulative impacts of the proposed revisions (C.C.C )." Three Type C map amendment applications, including the application (REZ ) subject to this staff report, were received in 2003, and are currently under consideration. These applications propose land use and zoning changes to approximately 14.2 acres and include: REZ Proposes changing 1.17 acres from the Carlsborg Industrial (CI) zone to the Rural Moderate (R2) zone; REZ (subject of this staff report). Proposes changing 9.25 acres from the Carlsborg Residential (CR) zone to the Public (P) zone; and REZ Proposes changing 3.78 acres from the Rural Limited Commercial (RLC) zone to the Rural (R1) zone. pproximately 5 acres are proposed to change from commercial/industrial land use and zoning designations to a rural residential designation. This potential change should not pose a significant impact to the availability of commercial and industrial land, and would appear to lessen potential overall environmental impact, for the following reasons: The 1.17 acres of industrial land proposed to change to rural residential designated land already contains a residential use. The 3.78 acres of commercial (RLC) designated land is located in close proximity to the Port ngeles Urban Growth rea, where adequate existing and potential commercial lands are already available. Potential environmental impacts from future development on the impacted lands should be lessened because the proposed change is from higher intensity preferred land uses (commercial and industrial) to a lower intensity preferred land use (rural residential). 15

19 The 9.25 acres of land within the Carlsborg Urban Growth rea proposed to change from urban residential to public lands would likely reduce land available for residential development within the Carlsborg UG. However, this potential reduction of 18 residential lots will not adversely impact the ability to accommodate projected population growth in eastern Clallam County, especially within the Sequim Urban Growth rea located approximately 1-mile east of Carlsborg. Mitigation of potential environment impacts related to development of public facilities on this property, if approved, will be addressed through the SEP and conditional use permit processes that are required for future development of the site under the requested zoning. further mitigating circumstance is that this site will likely be used for providing an essential public service (fire protection) to the Carlsborg UG and vicinity. C. DDITIONL CONSIDERTIONS The County s public land designation identifies lands currently used for public uses. Lands designated as Public cover a variety of uses within unincorporated Clallam County including, but not limited to: county and state park and recreation lands, Dungeness Wildlife Refuge, public schools, transportation facilities, and public buildings. ll lands currently designated as Public Land were already park land or contained existing public facilities or buildings at the time of designation. However, not all property that is publicly-owned, or contains public buildings and facilities, within unincorporated Clallam County, is currently designated as Public Land. The Public Land designation establishes a public process for identification of public lands needed for public facilities and uses. Except for schools and cemeteries, most public facilities and uses are not listed in the use tables applicable to County urban, rural and resource land zoning districts. Unclassified uses may be approved through a conditional use permit process. In this case, Fire District #3 has identified the subject property as a needed and desired location for future development of a new fire station and related support services to meet the fire protection needs of eastern Clallam County. Future relocation of the Carlsborg Fire Station to the subject property, if approved, may result in the need to re-evaluate the current Public Land designation for the existing fire station site (Figure 2). It is possible that the property and existing buildings could be used for other needed public uses, and a change would not be necessary. However, if the property is not to be used for public purposes, the County will need to determine an appropriate land use and zoning designation for this 0.57 acre site. Based on the previous analysis, staff identifies the following additional areas that Clallam County should consider as part of its future update to the Clallam County comprehensive plan and development regulations: Clallam County should update the Sequim-Dungeness Regional Comprehensive Plan to clarify goals, objectives and policy intent for the Public Land designation. lthough park and recreation areas are clearly identified as appropriate for public land designation (Reference), other public buildings and lands are not specifically addressed. Clallam County should update its zoning district use tables to more specifically reflect what public uses are allowed or conditionally allowed within County 16

20 adopted urban, rural, and resource land districts. This update should be coordinated with the intent of the Public Land designation. Clallam County should update the comprehensive plan to establish policies to guide removal of existing designated public lands from public ownership. Clallam County should evaluate whether other public lands, facilities, and uses not designated as Public Land should be designated as Public Land. Clallam County should work with the Clallam County Fire District #3 to update the Carlsborg Capital Facilities Plan (CFP) in terms of future fire protection needs. The Fire District s application (ppendix ), environmental checklist (ppendix B), and subsequently submitted materials related to facility needs (ppendix D) provide the baseline for this update. The above considerations are recommended to be considered as part of the County s scoping process to evaluate and determine necessary update of its comprehensive plan and development regulations that are currently underway (see Section B). D. FINDINGS ny recommendation of the Planning Commission on a comprehensive plan and zoning map amendment application must be based on Findings (C.C.C ). The following findings are recommended by Planning Staff in support of a decision to approve Comprehensive Plan Land Use and Zoning Map mendment pplication REZ Whenever necessity, convenience and general welfare require, the boundaries of the land use designations established on any comprehensive plan map of Title 31, and other provisions of this title may be amended consistent with the procedures and criteria of C.C.C pproval of the requested amendment application would be consistent with the goals and policies of the Comprehensive Plan and state Growth Management ct that require adequate urban services, including fire protection, to be available within urban growth areas to serve existing development and future development as it occurs. 3. pproval of the requested amendment application for the subject property would be consistent with the purpose and intent of the Public (P) zone, which is to " identify properties used for public purposes such as public buildings, schools, cemeteries, parks, playgrounds and recreational areas (C.C.C )." The ownership of the subject property by Clallam County Fire District #3 is consistent with this purpose, as future use of the site will likely include fire protection-related facilities. 4. Future development of the intended fire station or other public use on the subject property would require approval of a Conditional Use Permit pursuant to the Clallam County Zoning Code (C.C.C ). The conditional use permit process requires consideration of any identifiable impacts to neighboring properties and the community, and requires that reasonable 17