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HomeMy WebLinkAbout03-11-2026 YPC PacketThe meeting will also be recorded and posted on the Y-PAC website. Visit the Yakima Planning Commission webpage for more information, including agenda packets and minutes. DEPARTMENT OF COMMUNITY DEVELOPMENT Bill Preston, P.E., Director Trevor Martin, AICP, Manager Planning Division 129 North Second Street, 2nd Floor Yakima, Washington 98901 Phone (509) 575-6183 • Fax (509) 575-6105 • Email: ask.planning@yakimawa.gov CITY OF YAKIMA PLANNING COMMISSION Yakima City Hall Council Chambers 129 N 2nd Street, Yakima, WA 98901 March 11, 2026 3:00 p.m. – 5:00 p.m. YPC MEMBERS: Chair Mary Place, Vice-Chair Charles Hitchcock, Jeff Baker, Roy Gondo, Leanne Hughes-Mickel, Anne Knapp, Colleda Monick, Philip Ostriem, Kevin Rangel, Frieda Stephens, and Shelley White City Council Liaison: Matt Brown, Felisa Gonzalez CITY PLANNING STAFF: Bill Preston (Community Development Director), Lisa Maxey (Admin. Assistant), Trevor Martin (Planning Manager), Eric Crowell (Senior Planner), Jason Radtke (Senior Planner), Connor Kennedy (Associate Planner), Eva Rivera (Planning Technician) AGENDA I.Call to Order II.Roll Call III.Staff Announcements IV.Approval of Minutes – February 25, 2026, Meeting V.Public Comment VI.Review of Critical Areas Ordinance VII.January & February 2026 Building Permit Reports VIII.Other Business IX.Meeting Recap X.Adjourn Next Meeting: March 25, 2026 - 1 - 02/25/2026 YPC Minutes City of Yakima Planning Commission (YPC) Meeting Minutes February 25, 2026 Call to Order Chair Place called the meeting to order at 3:00 p.m. Roll Call YPC Members Present: Chair Mary Place, Vice-Chair Charles Hitchcock, Roy Gondo, Anne Knapp, Colleda Monick, Philip Ostriem, Frieda Stephens, Shelley White YPC Members Absent: Jeff Baker, Kevin Rangel, Leanne Hughes-Mickel (all excused) Staff Present: Trevor Martin; Planning Manager City Council Liaison: Matt Brown Staff Announcements – Trevor talked about how the first monthly Coffee with Codes event went at Northtown Coffee House. Approval of Minutes from January 28 & February 11, 2026- Commissioner Gondo moved to approve the meeting minutes from January 28, 2026, Commissioner Hitchcock seconded the motion. Chair Place abstained from voting. The motion carried unanimously. Commissioner Gondo moved to approve the meeting minutes from February 11, 2026, Commissioner Knapp seconded the motion. The motion carried unanimously. Public Comment – None Review Housing Data with BERK – Kevin Ramsey and Oneyza, consultants from BERK, joined virtually and reviewed the Housing Element with the Commission. January 2026 Building Permit Statistics- Because the meeting ran out of time, the Commission did not review the Building Permit Report for January. The item will be carried forward to a future agenda Other Business – None Meeting Recap – Action Items & Decisions: • Right of way assessments for vacant buildings will be explored. • Study session on road standards will be held. • Capacity analysis and setbacks will be reviewed without BERK’s participation. Outstanding Action Items • Establish a method for capturing and tracking action items. • Transit ridership information will be provided. • An EV charging station policy will be integrated into the Comprehensive Plan. • The elements of the Comp Plan rough drafts will be reviewed in January or February. • Implementation measures in the Comp Plan. • Alphabetize Table 4.1 by category. • Pg. 23 parking space extends to 9 feet. 2 of 83 - 2 - 02/25/2026 YPC Minutes • A link of the survey will be emailed. • The commission will go through the comprehensive plan page by page. • The Land Capacity Analysis currently under review by the Transpo group will be provided. • A new section for congregant living will be added to the code and reviewed by the Commission. Future Items • Staff will notify and update the Commission when the countywide policies are completed. • Downtown Action Plan - staff will determine if the Planning Commission will be involved. • Staff will coordinate a future roundtable with experts to discuss design standards. A motion to adjourn to March 11, 2026, was passed with a unanimous vote. The meeting adjourned at approximately 4:59 p.m. Chair Place Date This meeting was filmed by YPAC. Minutes for this meeting submitted by: Eva Rivera, Planning Technician. 3 of 83 perteet.com 2707 COLBY AVENUE, SUITE 900 EVERETT, WA 98201 425.252.7700 YAKIMA CRITICAL AREAS ORDINANCE (COA) PERIODIC UPDATE GAP ANALYSIS & BEST AVAILABLE SCIENCE REVIEW Submitted to City of Yakima, WA October 2025 4 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 1 TABLE OF CONTENTS 1.0 INTRODUCTION ........................................................................................................................................... 3 1.1 CORRELATION TO SMP & RIPARIAN PROTECTION AREAS .............................................................................. 3 2.0 CRITICAL AREAS - OVERALL REQUIREMENTS ........................................................................................ 4 2.1 APPLICABILITY ............................................................................................................................................... 4 2.2 DESIGNATION ............................................................................................................................................... 4 2.3 DEFINITIONS ................................................................................................................................................. 5 2.4 PROTECTION ................................................................................................................................................ 5 2.5 BEST AVAILABLE SCIENCE .............................................................................................................................. 6 2.6 NO NET LOSS ............................................................................................................................................... 6 2.7 REASONABLE USE EXCEPTION ........................................................................................................................ 7 3.0 FREQUENTLY FLOODED AREAS ................................................................................................................ 7 3.1 DEFINITION & CLASSIFICATION ....................................................................................................................... 7 3.2 PROTECTION ................................................................................................................................................. 7 3.3 FREEBOARDING ............................................................................................................................................. 8 3.4 FLOODWAY FRINGE / FLOODWAY USES ........................................................................................................ 8 4.0 FISH & WILDLIFE HABITAT AREAS ............................................................................................................. 9 4.1 CLASSIFICATION ........................................................................................................................................... 9 4.1.1 DEFINITIONS ......................................................................................................................................... 9 4.1.2 DESIGNATIONS .................................................................................................................................... 10 4.2 FEDERAL, STATE, & LOCAL ........................................................................................................................... 11 4.3 PROTECTION ................................................................................................................................................ 11 4.3.1 BUFFERS & SETBACKS .......................................................................................................................... 11 4.3.2 RIPARIAN MANAGEMENT ZONE ............................................................................................................. 11 4.3.3 ANADROMOUS FISHERIES .................................................................................................................... 12 4.3.4 SHRUB-STEPPE .................................................................................................................................... 13 4.3.5 FOREST PRACTICES ............................................................................................................................. 13 4.3.6 HAZARDOUS TREE REMOVAL .............................................................................................................. 14 5.0 WETLANDS ................................................................................................................................................... 14 5.1 DEFINITION & CLASSIFICATION .................................................................................................................... 14 5.2 DELINEATION & RATINGS ............................................................................................................................. 15 6.0 GEOLOGICALLY HAZARDOUS AREAS ................................................................................................... 15 6.1 DESIGNATION & CLASSIFICATION ................................................................................................................. 16 6.2 PROTECTION & REPORTING ......................................................................................................................... 17 6.3 MAPPING ..................................................................................................................................................... 17 7.0 CRITICAL AQUIFER RECHARGE AREAS ................................................................................................... 17 7.1 DEFINITION, CLASSIFICATION, & PROTECTION .............................................................................................. 17 7.2 QUALITY & QUANTITY ................................................................................................................................ 17 5 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 2 7.3 WELL HEAD PROTECTION AREAS .................................................................................................................. 17 7.4 MAPPING & REPORTING ............................................................................................................................... 17 8.0 REFERENCES ................................................................................................................................................ 17 LIST OF TABLES TABLE 1. YAKIMA CAO, CHAPTER 15.27 CONTENTS........................................................................................................ 3 TABLE 2. OVERALL RECOMMENDATIONS. ....................................................................................................................... 4 TABLE 3. FLOOD HAZARD AREA RECOMMENDATIONS...................................................................................................... 7 TABLE 4. FWHCA RECOMMENDATIONS. ....................................................................................................................... 9 TABLE 5. WETLAND RECOMMENDATIONS. ..................................................................................................................... 14 TABLE 6. GEOLOGICALLY HAZARDOUS AREAS RECOMMENDATIONS. ............................................................................. 15 TABLE 7. CARA RECOMMENDATIONS. .......................................................................................................................... 17 LIST OF APPENDICES APPENDIX A WA Dept. of Commerce Critical Areas Checklist APPENDIX B WDFW Riparian Management Zone Checklist 6 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 3 1.0 INTRODUCTION Pursuant to the Growth Management Act (GMA) and the Revised Code of Washington (RCW) 36.70A.170, local jurisdictions must establish a critical areas ordinance incorporating the designation and protections of critical areas, including wetlands, critical aquifer recharge areas, fish and wildlife habitat conservation areas, frequently flooded areas, and geologically hazardous areas (RCW 36.70A.030(12). Other natural resource lands as noted in RCW 36.70A.170 are intermittently discussed in this report to ensure compliance. This report addresses gaps and inconsistencies that call for updates to the City of Yakima’s Critical Area Ordinance (CAO) to comply with the required GMA’s process for the 2026 Comprehensive Plan Periodic Update cycle. The report also incorporates Best Available Science (BAS) guidance as directed by RCW 36.70A.172. The Department of Commerce (Commerce) Critical Area Checklist (May 2024) is attached to this report for reference as Appendix A. On the Critical Area Checklist applicable code sections of the City of Yakima’s CAO are referenced and are also referenced throughout this report. Recommendations made as a result of this Gap Analysis are shown in tables under each section. Table 1. Yakima CAO , Chapter 15.27 Contents Chapter Part Code Sections Part One. General Provisions 15.27.100 – 15.27.170 Part Two. Definitions 15.27.200 Part Three. Application and Review Procedures 15.27.300 – 15.27.321 Part Four. Flood Hazard Areas 15.27.400 – 15.27.437 Part Five. Fish and Wildlife Habitat Conservation Areas 15.27.500 – 15.27.517 Part Six. Wetlands 15.27.600 – 15.27.605 Part Seven. Geologically Hazardous Areas 15.27.700 – 15.27.704 1.1 Correlation to Shoreline Master Program (SMP) & Ripa rian Protection Areas Pursuant to WAC 173-26-221(1) and effective through the establishment of the Washington State Shoreline Management Act (SMA), Shoreline Management Programs (SMP) are required to contain policies and regulations for the management of critical areas, as designated in RCW 36.70A.170(1)(d), that are located with shorelines of the state. The resulting SMP policies and regulations are provided to ensure no net loss of ecological function or value within the shorelines of the state. For continuity, references to the City of Yakima’s SMP are also included on the attached Critical Areas Checklist (Appendix A). A comprehensive compliance review of the City of Yakima’s SMP is not included in the current periodic updated efforts regarding the Yakima’s Comprehensive Plan and Critical Areas Ordinance. Alternatively, a comparative review of the Washington Department of Fish & Wildlife’s (WDFW) Riparian Management Zone Checklist was made to support of continuity between the subject COA gap analysis and future compliance review efforts of the City to Yakima’s SMP. Additionally, a separate technical memorandum will be drafted in relation to the Washington Department of Fish and Wildlife (WDFW) riparian management guidance, specifically Riparian Management Zones (RMZs) and Site Potential Tree Height (SPTH), including consideration of alternatives used by other local jurisdictions where implementation of BAS warrant a flexible approach. For more details, see the 7 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 4 WDFW Riparian Management Zone (RMZ) Checklist attached as Appendix B, as well as the separately issued technical memorandum for WDFW Riparian Management Guidance. 2.0 CRITICAL AREAS – OVERALL REQUIREMENTS Table 2. Overall Recommendations Code Section Reason/Consistency Recommendation 15.27.150(B) – Applicability Consistency & Clarity Consider revising ‘relevant regulations’ to include “as amended”. 15.27.200 – Definitions Generally. Consistency & Clarity Consider moving the definition for Geologically Hazardous Areas from YMC 15.27.700(A) – Purpose and intent, to YMC 15.27.200. 15.27.314 – Critical Area Report Requirements Consistency with WAC 365-195- 915(c) Consider adding language that proclaims required criteria for departing from science- based recommendations. 15.27.314(J) – Critical Area Report Requirements WAC 197-11-768 Consider adding language noting that critical area reporting and analysis must utilize mitigation sequencing as shown in YMC 15.27.307 (Mitigation Requirements). 15.27.315 – Supplemental report requirements for specific critical areas. Clarity and Continuity Consider splitting and moving supplemental requirements into their respective critical area subsections. 15.27.605 – Compensatory mitigation Clarity & Reduce Repetitiveness Consider removing mitigation sequencing language in YMC 15.27.605 (Compensatory Mitigation.) and referencing back to existing YMC 15.27.307 (Mitigation Requirements.) 2.1 Applicability Applicability of Chapter 15.27 in the Yakima Municipal Code (YMC) is adequately addressed, but it is unclear to the average reader if amended versions of the critical areas ordinance and flood hazard ordinance are also applicable. While each of these ordinances have legally binding adoption and/or effective dates, the removal of specific dates of ordinances under ‘relevant regulations’ (YMC 15.27.150(B) supports consistency and continuity. Recommendation: Consider clarifying under YMC 15.27.150(B) that amended versions of the listed ordinances are applicable (“as amended”). 2.2 Designation The designation of Critical Areas within the Yakima Municipal Code (YMC) is adequately addressed in Chapter 15.27 – Part One General Provisions, where the City of Yakima’s authority, purpose, intent, and applicability is expressed in accordance with RCW 36.70A.060. 8 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 5 2.3 Definitions The YMC 15.27.200 contains applicable designated critical area definitions for Wetlands, Critical Aquifer Recharge Area, Fish & Wildlife Habitat Conservation, and Special Flood Hazard Area. For consistency and consolidation, consider moving the definition for Geologically Hazardous Areas from YMC 15.27.700(A) – Purpose and intent, to YMC 15.27.200. YMC 15.27.200: • “Wetland” means areas that are inundated or saturated by surface water or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas. Wetlands do not include those artificial wetlands intentionally created from nonwetland sites, including, but not limited to, irrigation and drainage ditches, grass-lined swales, canals, detention facilities, wastewater treatment facilities, farm ponds, and landscape amenities, or those wetlands created after July 1, 1990, that were unintentionally created as a result of the construction of a road, street, or highway. Wetlands may include those artificial wetlands intentionally created from nonwetland areas created to mitigate conversion of wetlands. • “Critical aquifer recharge area” means an area with a critical recharging effect on an aquifer(s) used for potable water or areas where a drinking water aquifer is vulnerable to contamination that would affect the potability of the water. • “Fish and wildlife habitat conservation” means land management for maintaining populations of species in suitable habitats within their natural geographic distribution so that the habitat available is sufficient to support viable populations over the long term and isolated subpopulations are not created. This does not mean maintaining all individuals of all species at all times, but it does mean not degrading or reducing populations or habitats so that they are no longer viable over the long term. Counties and cities should engage in cooperative planning and coordination to help assure long-term population viability. • “Special flood hazard area” means the land in the floodplain identified by the Federal Emergency Management Agency that is subject to a one percent or greater chance of flooding in any given year, commonly known as the one-hundred-year floodplain. YMC 15.27.700: • “A. Geologically hazardous areas include those areas susceptible to erosion, sliding, earthquake, or other geological events. These areas pose a threat to the health and safety of the city of Yakima’s citizens when incompatible development is sited in significantly hazardous areas. When mitigation is not feasible, development within geologically hazardous areas should be avoided.” 2.4 Protection General protective measures for critical areas are expressed in YMC 15.27.321, with additional protective measures also expressed in each corresponding critical area’s Part subsection of the YMC Chapter 15.27 as follows: • Part Four. Flood Hazard Areas – Article II. Flood Hazard Protection Standards, o YMC 15.27.407-15.27.408, • Part Five. Fish and Wildlife Habitat Conservation Areas – Article I. Introduction, o YMC 15.27.501, • Part Six. Wetlands, o YMC 15.27.602, • Part Seven. Geologically Hazardous Areas, 9 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 6 o YMC 15.27.702, • Part Eight. Critical Aquifer Recharge Areas (CARA), o YMC 15.27.820. Critical Area Reports are a founded methods of ensuring protective measures are considered, assessed, and/or implemented according to the purposes and standards for the Chapter. Recommendation: To support clarity and continuity, consider splitting and moving YMC 15.27.315 (Supplemental report requirements for specific critical areas.) to their respective and associated critical areas section within the Chapter. 2.5 Best Available Science The inclusion of BAS consistency is appropriately referenced in YMC 15.27.150 – Science and Protection of Anadromous Fish. Additional locations within the CAO include: • Qualified professional to prepare the report consistent with BAS, o YMC 15.27.314(B) – Critical areas report requirements, • Fish and Wildlife Habitat Conservation Areas, o YMC 15.27.500(A), and YMC 15.27.501(2), • Wetland Buffer Requirements and Alternative Mitigation Plans, o YMC 15.27.604(A), and YMC 15.27.605(I)(7). Recommendation: In accordance with WAC 365-195-915(c), consider adding language that proclaims required decision criteria for any non-science-based information used as a basis for recommending protection of critical area functions and values, and for departing from science-based critical area policies and regulations. 2.6 No Net Loss ‘No Net Loss’ provisions ensure ecological function remains unchanged over time, preventing new adverse impacts from development. When impacts are proposed, mitigation sequencing should be implemented to ensure corrective measures, monitoring, and compensatory mitigation measures offset when/where critical area functions and values are harmed or impacted by development activity. Accordingly, YMC 15.27.130 addresses the allowance of development options within designated critical areas where no net loss of function and value are obtainable, and no incompatibilities are present. The YMC sections 15.27.314 through 15.27.321 address the avoidance of potential adverse impacts through critical area reporting criteria, performance measures for site delineation and mitigation plans, and declaration of the administrative official’s authority to reject or request revisions in reporting when critical area impacts are incomplete, inaccurate, or not fully addressed. Mitigation sequencing is mentioned in YMC 15.27.315(B)(4)(b) (Supplemental report requirements for specific critical areas.) regarding wetland critical area reporting, YMC 15.27.317(C)(3) (Adjustments) regarding vegetative buffer averaging, YMC 15.27.509(N) (General policies and standards.) regarding activity within a FWHCA, and then fully repeated and referenced under YMC 15.27.605 (Compensatory Mitigation). Although reporting criteria, performance measures, mitigation sequencing, and authority to require reassessment of impacts are mentioned, existing language under YMC 15.27.314 does not clearly depict the use of mitigation sequencing when mitigation is required for all critical areas (Ecology, 2022) 10 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 7 Recommendation: Consider adding language in YMC 15.27.314 (Critical area report requirements.) that all critical area reporting should present mitigation sequencing in accordance with YMC 15.27.307 (Mitigation requirements.) when mitigation is required. Recommendation: Consider removing mitigation sequencing language in YMC 15.27.605 (Compensatory Mitigation.) and referencing back to existing YMC 15.27.307 (Mitigation Requirements.) 2.7 Reasonable Use Exception In cases where adverse impacts to critical areas would presume no reasonable use of a property, a Reasonable Use Exception permit review process is noted in YMC 15.27.318. 3.0 FREQUENTLY FLOODED AREAS Table 3. Floodplains Recommendations Code Section Reason/Consistency Recommendation YMC 15.27.315(D) & YMC 15.27.418(H) WA State Model Ordinance (Ecology, 2021) Consider adding provisions requiring an elevation Certificate for projects that may affect the floodplain or require a hydrologic and hydraulic (no-rise) study YMC 15.27.408(A) – Specific Standards Federal Flood Risk Management Standards, Exec. Order # 13690 Consider increasing freeboarding to a two-foot above BFE for new or substantially improved residential structures Article III – Floodway Fringe Uses & Article IV – Floodway Uses WA State Model Ordinance (Ecology, 2021) Consider re-evaluation of floodway fringe uses and floodway uses according to the WA State Model Ordinance and FEMA regulations 3.1 Definition & Classification Special Flood Hazard Areas are defined and designated through YMC 15.27.200, with a supplemental reporting requirements provision in YMC 15.27.315 noting an engineering report to be prepared by a licensed engineer for establishing any new flood elevations. 3.2 Protection The City updated YMC 15.27 Part Four (Flood Hazard Areas) in 2021 (Ord. 2021-021), amending and adding sections related to the identification and establishment of flood hazard areas (YMC 15.27.400), Methods of Reducing Flood Losses (YMC 15.27.403), and amending sections related to Penalties, Liabilities, Variances, New Construction, General Standards for Construction Techniques, Floodproofing Certificates, Storage of Materials, Critical Facilities, Livestock Sanctuary Areas, and Specific Standards for Residential and Nonresidential Construction, Manufactured Homes, Enclosed Areas, areas with or without established base flood elevations / floodways, Shallow Flooding Areas, Structure Drainage, Recreational Vehicles, and Permit Application / Review Process. 11 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 8 Yakima County adopted The Upper Yakima River Comprehensive Flood Hazard Management Plan in 1998, as amended in 2007 and 2018, in which the study area includes the majority of the City of Yakima’s jurisdiction. The City of Yakima has also adopted the City of Yakima Hazard Mitigation Plan in 2015 as an attachment to the Yakima County Multi-jurisdictional Hazard Mitigation Plan. The adoption and attachment of the city-specific hazard mitigation plan supports the city’s continued effort to be part of the National Flood Insurance Program allowing for federal funding eligibility. The city also provides funding for community outreach and education through the Yakima County Flood Control District. 3.3 Freeboard ing Integrated Floodplain Management is an approach method for acknowledging collaboration based on shared values across the many types of ecological and economic benefits of managing floodplains. Most commonly notable, this approach supports the combined effort in reduction of flood damage, support for riparian habitats, and the preservation of agriculture and open spaces. Resiliency practices further support this effort through minimizing encroachments within floodways and floodplains, as well as bolstering design standards to maximize structural integrity during and after a flood event. Recommendation: Consider increasing freeboarding to a two-foot above BFE for new or substantially improved residential structures, providing for added resilience during future flood conditions or extreme weather events. (YMC 15.27.408(A) – Specific Standards). 3.4 Flood way Fringe / Floodway Uses Portions of the floodplain that are inundated by floodwater but no within a defined floodway are considered temporary storage for floodwaters and referred to as floodway fringe areas. These areas are predominantly identified through the use of BFEs, as depicted in city GIS databases. Areas identified with BFEs must demonstrate that the cumulative effects of the proposed development combined with other existing and anticipated development cannot increase the base flood by more than one foot anywhere within the community. Articles III & IV of Part Four of the YMC Chapter 15.27 reference permitted and prohibited uses regarding floodway fringe areas and floodways. The language in both articles is very similar to each other but suggest opposing protective measures not aligned with the WA State Model Ordinance for floodplain management (Ecology, 2021). Article III does not permit substantial residential improvements when located in the floodway fringe area without a hydrologic and hydraulic (no-rise) study, while this is commonly applied as floodway regulations. Article IV permits mining, utility lines, roads, and water dependent utilities within the floodway without a hydrologic and hydraulic (no-rise) study, when these studies are a primary protective measure for these uses within the floodway. Recommendation: Consider re-evaluation of floodway fringe uses and floodway uses according to the WA State Model Ordinance and FEMA regulations for applicability permitted and prohibited development activity. Recommendation: Consider adding provisions requiring an elevation certificate for projects that may affect the floodplain or require a hydrologic and hydraulic (no-rise) study (YMC 15.27.315(D) & YMC 15.27.418(H). 12 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 9 4.0 FISH & WILDLIFE HABITAT CONSERVATION AREAS (FWHCAS) Table 4. FWHCA Recommendations Code Section Reason/Consistency Recommendation 15.27.150 – Science and Protection of Anadromous Fish Clarity Consider adding reference to consultation of federal, state, and regional salmon recovery plans. 15.27.315(A)(1) – Supplemental Report Requirements for Specific Critical Areas Update Terminology Consider revising ‘habitat and native vegetation conservation strategy’ to Habitat Management Plan. 15.27.502(3) – Designation Clarity Consider specifying when a Critical Area Report is required under this critical area designation. 15.27.502 – Designation Clarity Consider noting Sensitive Fish Species listed in the Natural Environment Element of the Comprehensive Plan. 15.27.505 – Water Typing System WAC 222-16-030 Update from current Interim Water Typing System classifications (WAC 222-16-031) to Permanent Water Typing System classifications (WAC 222-16-030). 15.27.507 – Mapping Clarity Consider revising GIS geodatabase nomenclature from ‘wildlife priority habitats’ to Priority Habitat Species. 15.27.507(B) – Mapping Clarity Consider including a reference to WDFW PHS informational maps. Article V. Land Modification Development Standards RCW 36.70A.570 Consider addressing forest practices by providing protection measures for forested ecosystems in relations to land-disturbing activities. 4.1 Classification FWHCAs provide resources and habitat sufficient to support viable fish and wildlife populations over the long term (WAC 365-190-130). These areas are critical for preserving biodiversity, maintaining ecological connectivity, and supporting salmonid survival across all life stages. Functions provided by riparian habitats include shade and temperature regulation, large woody material recruitment, nutrient cycling, bank stabilization, water quality protection, and wildlife movement corridors. 4.1.1 Definitions YMC 15.27.200: • “Priority habitat” means a habitat type with unique or significant value to one or more species. An area classified and mapped as priority habitat must have one or more of the following attributes: comparatively high fish or wildlife density, comparatively high fish or wildlife species diversity, fish spawning habitat, important wildlife habitat, important fish or wildlife seasonal range, important fish or 13 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 10 wildlife movement corridor, rearing and foraging habitat, refuge, limited availability, high vulnerability to habitat alteration, unique or dependent species, or shellfish bed. A priority habitat may be described by a unique vegetation type or by a dominant plant species that is of primary importance to fish and wildlife. A priority habitat may also be described by a successional stage. Alternatively, a priority habitat may consist of a specific habitat element (such as talus slopes, caves, or snags) of key value to fish and wildlife. A priority habitat may contain priority and/or nonpriority fish and wildlife. • “Priority species” means species requiring protective measures and/or management guidelines to ensure their persistence at genetically viable population levels. Priority species are those that meet any of the criteria listed below: A. Washington State (State) Listed or State-Proposed Species. State-listed species are those native fish and wildlife species legally designated as endangered (WAC 232-12-014), threatened (WAC 232-12- 011), or sensitive (WAC 232-12-011). State-proposed species are those fish and wildlife species that will be reviewed by WDFW (POL-M-6001) for possible listing as endangered, threatened, or sensitive according to the process and criteria defined in WAC 232-12-297. B. Vulnerable Aggregations. Vulnerable aggregations include those species or groups of animals susceptible to significant population declines, within a specific area or statewide, by virtue of their inclination to congregate. C. Species of Recreational, Commercial, and/or Tribal Importance. Native and nonnative fish, shellfish, and wildlife species of recreational or commercial importance and recognized species used for tribal ceremonial and subsistence purposes that are vulnerable to habitat loss or degradation. D. Species listed under the federal Endangered Species Act as either proposed, threatened, or endangered. • “Riparian vegetation” means the terrestrial vegetation that grows beside rivers, streams, and other freshwater bodies and that depends on these water sources for soil moisture greater than would otherwise be available from local precipitation. • “Species of local importance” are those species that are of local concern due to their population status or their sensitivity to habitat alteration or that are game species. • “Stream” means water contained within a channel either perennial, intermittent, or ephemeral. Streams include both natural watercourses or those modified by man (example: stream flow manipulation, channelization, and relocation of the channel). They do not include irrigation ditches, wasteways, drains, outfalls, operational spillways, canals, stormwater runoff facilities, or other artificial watercourses except those that are located within existing wetland or streams. • “Vegetative buffer” or “buffer” means an area extending landward from the ordinary high water mark of a lake or stream and/or from the edge of a wetland which is maintained or otherwise allowed to provide support for the performance of the basic functional properties of a fish and wildlife habitat conservation area and wetlands as set forth in YMC 15.27.504 and 15.27.603. • “Wildlife habitat” means an area of climate, soils, vegetation, relationship to water, location and/or other physical properties which are identified as having a critical importance to the maintenance of wildlife species. 4.1.2 Designations The YMC 15.27.502 includes designation of FWHCAs in accordance with WAC 365-190-130, with the exception of marine related habitats. 14 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 11 4.2 Federal, State, & Local YMC 15.27.502 note designations of FWHCAs based on locations identified by federal, state, and local authorities, including but not limited to Federally endangered/threatened/sensitive species, Federal Emergency Management Agency mapped floodplains, WDFW’s Priority Habitats and Species (PHS) program, Waters of the State, government or tribal stocked aquatic features, and ‘Habitats of Local Importance’. 4.3 Protection The protection of fish and wildlife habitat conservation areas are expressed in YMC 15.27.501 (Protection Approach) and designated through YMC 15.27.502 (Designation) and YMC 15.27.507 (Maps). Recommendation: Consider specifically noting the requirement of a Critical Area Report based on listed designation listed within YMC 15.27.502. Recommendation: Consider revising terminology used in YMC 15.27.315(A)(1) to require a Habitat Management Plan (HMP) instead of a ‘habitat and native vegetation conservation strategy.’ 4.3.1 Buffers & Setbacks Yakima Municipal Code (YMC 15.27, Part Five) regulates FWHCAs by establishing fixed buffer widths measured horizontally from the ordinary high-water mark (OHWM), varying by stream type. The code (YMC 15.27.505) still references the interim water typing system (Types 1–5), which has been replaced by the permanent water system (Type S, F, Np, and Ns classifications) under WAC 222-16-030. Recommendation: Consider updating stream typing according to WAC 222-16-030 Water Typing Systems, which applies Type S, F, Np/s, and subsequently updating references to Designated Type 2 Stream Corridors in Appendix B. 4.3.2 Riparian Management Zone The WDFW has published multiple BAS resources and guidance related to RMZs, including but not limited to: • Riparian Ecosystems Vol. 1 (Quinn, 2020): Identifies BAS regarding ecological functions of riparian areas and management measures necessary to maintain them. o Riparian Ecosystems Vol. 2 (Rentz et al., 2020): Identifies recommendations for how local governments can include BAS in protecting riparian ecosystems and associated aquatic habitats. • Site Potential Tree Height Guidelines (2025): Recommends implementation of riparian management zones (RMZ) through utilizing arboreal species-specific site-potential tree heights (SPTH200) or the extent of native riparian vegetation, whichever is greater, along with a 100-foot minimum to ensure pollutant-removal functions. • Riparian Management Zone Checklist (2023): Details performance measures and additional protective measures for CAO updates. While the provisions for stream buffering/setbacks and channel migration zones provide a baseline level of protection, they do not align with WDFW’s 2020 Riparian Ecosystems BAS (Quinn, 2020), the 2020 Site Potential Tree Height (SPTH) guidance (WDFW, 2025), or the 2023 RMZ Checklist. 15 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 12 Recent WDFW guidance on SPTH (WDFW, 2025) recommends that additional protections to designate riparian ecosystems should be considered based on associated arboreal/forested systems and WDFW RMZ recommendations (Rentz et al., 2020). Designation of riparian ecosystems/habitats as a FWHCA through the use of RMZs ensures protection of the ecological functions of aquatic habitats, further supporting both fish- bearing riparian habitats (anadromous fish habitats) and non-fish-bearing habitats. Protection of these habitats support temperature regulation, nutrient cycling, pollution prevention, bank stabilization, water quality protection, terrestrial wildlife movement corridors, and climate resilience. The functional properties listed in YMC 15.27.504 support RMZs related to site specific circumstances where the protection of riparian function and values necessitate a larger buffer as a protective measure, such as poor soil conditions, steep slopes or stormwater runoff that can contribute to and deposit pollutants within riverine habitats. WDFW’s Riparian Ecosystems guidance, Vol. 2, Section 2.3.5 (Rentz et al., 2020) indicates that while site- potential tree height (SPTH) may apply in the limited areas of the Columbia Plateau where tall riparian trees occur, this condition is uncommon. In most dryland settings, riparian management zones are more appropriately delineated based on the extent of riparian vegetation and the pollution-removal functions they provide, with a minimum 100-foot width generally cited as necessary to achieve effective pollutant reduction. In Yakima, FWHCAs occur in a semi-arid shrub-steppe landscapes characteristic of the Columbia Plateau. Riparian systems along the Yakima River, Naches River, and tributaries provide essential functions even in the absence of tall coniferous forests. This setting requires a regulatory framework that predominantly emphasizes pollutant removal, water quality protection, and habitat connectivity over tree-height–based metrics that are not ecologically applicable in shrub-steppe habitats due to a lack of tall forested systems. Specifically, standard SPTH buffers at a minimum of 200-feet, with the arboreal species-specific tree heights ranging from 123 to 300-feet , may not be a suitable measure for the riparian habitats of the semi-arid shrub- steppe landscape of the Columbia Plateau. Alternatively, the absence of tall forested systems along Yakima’s riparian areas could be supported by the designation of FWHCA RMZs based on WDFW recommendations (Rentz et all., 2020). Comprehensively, these guidance documents establish that while SPTH is the preferred scientific measure, BAS supports a flexible approach where ecological conditions (e.g., shrub-steppe) make implementation of SPTH standard buffers inapplicable. Due to the unique complexities of Yakima’s regional and localized ecosystems as well as potential socioeconomic impacts within the City of Yakima, a separate technical memorandum will be drafted specifically addressing impacts resulting from the implementation of RMZs according to recent WDFW BAS as well as supporting case studies alternatives. 4.3.3 Anadromous Fisheries The protection of anadromous fish is noted in YMC 15.27.150 with references to GMA required BAS designations and procedural criteria. Additional references to anadromous fish are only found in YMC 15.27.603 (Wetlands functions and rating.). 16 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 13 Recommendation: For clarity, consider adding language in YMC 15.27.502 specifically noting the ‘Sensitive Fish Species Identified in the City’s Streams and Rivers’ listed in the Natural Environment Element of the Yakima Comprehensive Plan. Recommendation: Consider including a reference to YMC 15.27.150 regarding consultation with federal, state, and regional salmon recovery plans as recommended by WAC 365-190-130(4). 4.3.4 Shrub s teppe Since the previous periodic review and update of Yakima’s COA, shrub-steppe habitats areas as designated by WDFW have changed geospatially as well as in classification. The Washington Shrubsteppe Restoration and Resiliency Initiative (WSRRI) issued a Long-Term Strategy for 2024-2054 (WDFW-Shrubsteppe, 2024). The extent of the Shrubsteppe habitat has varied historically and in order to defend, grow, and connect the habitat areas for the future, the WSRRI’s strategy has derived spatial priority classifications for reaching conservation targets regarding dry (xeric) and wet (mesic) habitats as well as the greater sage-grouse, a species of highest conservation concern. These spatial priority areas are mapped online for reference. While WDFW PHS designations are available online and also designated as FWHCAs through YMC 15.27.502, it is important to note both, the changes recently made in WDFW PHS designation of shrubsteppe areas, as well as the above referenced strategy plan related to shrubsteppe habitats. Shrubsteppe habitats are no longer identified as close to city limits boundaries as they previously were, but Yakima still plays a role in habitat connectivity as an applicable function of the adjacent priority habitats. Alternatively, much of the area previously designated as shrubsteppe has changed to Urban Natural Open Space, and WSRRI’s strategic plans further identifies spatial priority areas for dry (xeric) habitat priorities partially within and surrounding the City of Yakima. WSRRI xeric habitat priority classifications nearest the City of Yakima include xeric habitat core, xeric habitat corridors, and other xeric habitats. Recommendation: To create consistency, consider revising ‘wildlife priority habitats’ as referenced by the city’s GIS geodatabase nomenclature to more clearly be identify with WDFW PHS terminology. Recommendation: Consider including a reference in YMC 15.27.507(B) to WDFW PHS maps and supplemental WDFW informational maps. 4.3.5 Forest Practices While references to forest practices are included in Chapters 7.82 (Construction Stormwater Runoff) and 7.83 (Post-construction stormwater runoff), the addition and inclusion of forest practices regulations as required by RCW 76.09.240 and related to critical area functions and values should be included in the city’s CAO under Chapter 15.27. Existing references support acknowledgement of land disturbing activities including Class IV general forest practices in relation with stormwater management in the event of new development, but these chapters also express that forest practices regulated under Title 222 of the Washington Administrative Code (WAC) are exempted from applicability of the chapters. Recommendation: Consider addressing forest practices as required under RCW 36.70A.570 and as stipulated by RCW 76.09.240, by addressing protection of public resources, appropriate approvals for conversion of forestlands, guided by planning goals in RCW 36.70A.202, and are consistent with or supplement development regulations that protect critical areas. 17 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 14 Additionally, due to the city recent efforts in establishing an Urban Foresty Management Plan that was “…designed to guide the City’s efforts in nurturing and expanding its green infrastructure…”, this action could be referenced as addressing protection of public resources. Provisions related to forest practices already existing within the city’s SMP regulations, similar provisions would support habitat functions and values across habitats not already covered by the SMP. 4.3.6 Hazardous Tree Removal Hazard trees can pose public safety concerns, both for the jurisdiction in and around publicly accessible areas, and for private property owners in proximity to or at the edge of habitat buffers. Dead trees and snags also provide habitat functions for wildlife and should be preserved if not hazardous. Chapter 8.77 (Public Tree Ordinance) of the YMC addresses public tree management as part of the city’s urban tree program. Provisions of this Chapter also cover ‘dead and diseased tree removal on private property’ and also defines ‘hazard tree’ according to tree hazard evaluation standards by the International Society of Arboriculture. This Chapter does not contain provisions for addressing hazard trees in relation to critical areas in general nor riparian habitat areas. Recommendation: Consider addressing hazard tree removal within riparian habitats in consideration of Forest Practice Rules (WAC 222-21-010[4]) for both public and private benefits, along with provisions that prevent damage to remaining trees and vegetation within riparian habitats. 5.0 WETLANDS Table 5 . We tl and Recommendations Code Section Reason/Consistency Recommendation 15.27.603 – Wetland Functions & Rating WA Ecology, Wetland Guidance for CAP Updates: Western & Eastern Washington (Ecology, 2022) Consider incorporating references to climate-mitigation and resiliency. 15.27.603 – Wetland Functions & Rating WA Ecology, Wetland Guidance for CAP Updates: Western & Eastern Washington (Ecology, 2022) Consider incorporating language regarding disconnected buffers. 5.1 Definition, & Classification Wetlands provide water-quality improvement (nutrient, sediment, metals/toxics retention and transformation), hydrologic regulation (flood attenuation, erosion reduction, groundwater recharge), and habitat functions (for invertebrates, amphibians, fish, birds, mammals). In Yakima, wetlands occur along riverine corridors, springs/seeps, seasonal depressions, and areas influenced by shallow groundwater or irrigation return flows, and they interconnect with other critical areas (FWHCAs, frequently flooded areas). Under the Growth Management Act and SEPA, wetland protection is grounded in federal and state definitions and Best Available Science (BAS). Ecology emphasizes that wetland loss/degradation increases flood risk, degrades water quality, and reduces ecosystem services that carry real public and private costs. 18 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 15 5.2 Delin eation & Ratings The YMC 15.27.600–.605 establishes purpose and intent, designation/delineation (use of the 1987 Corps Manual + Regional Supplements), functions and rating (Ecology 2014 Eastern WA rating system), buffers (category- and habitat-score–based tables with required impact minimization measures and corridor provisions), buffer averaging, and compensatory mitigation (sequencing, banks/ILF, and credit/debit option for Eastern WA). Buffers must be vegetated with native plant communities; wider if overlapping buffers applies; signs/fencing and long-term stewardship are addressed. Overall, YMC Chapter 15.27 – Part Six Wetlands, already tracks closely with Ecology’s model guidance for Eastern Washington and is substantially aligned with GMA requirements and other BAS guidance. The 2022 Guidance for CAO Updates clarifies buffer approaches for Eastern Washington (Appendix D), updates minimization measures, and incorporates climate change considerations (e.g., carbon sequestration) . The guidance emphasizes watershed-based planning and use of updated rating systems. Recommendation: Consider incorporating climate-mitigation and resiliency (carbon Sequestration). Recommendation: Consider incorporating language regarding disconnected buffer as recommended by Ecology’s Wetland Guidance for CAP Updates: Western & Eastern Washington (Ecology, 2022). 6.0 GEOLOGICALLY HAZARDOUS AREAS Table 6. Geologically Hazardous Areas Recommendations Code Section Reason/Consistency Recommendation 15.27.701 – Mapping and Designation WAC 365-190-120(4) Consider assessing geologically hazardous areas based on three classifications; Known/Suspect, No Known, Unknown. 15.27.701 – Mapping and Designation WAC 365-190-120(5) Consider including references to US Dept. of Ag. NRSC soil type classifications for identification and assessment of erosion hazard areas. 15.27.701 – Mapping and Designation WAC 365-190-120(6) (a) through (h) Consider referencing the combination of potential geological, topographical, and hydrologic factors for identification and assessment of landslide hazard areas. 15.27.701 – Mapping and Designation WAC 365-190-120(7) Consider referencing the combination of historical evidence, settlement, faulting, and liquefication susceptibility for identification and assessment of seismic hazard areas. 15.27.701 – Mapping and Designation Clarity Consider updating references to city maps sources generally to allow for updates and additions. 19 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 16 15.27.701 – Mapping and Designation Clarity Consider referencing the Dept. of Natural Resource Geologic Information Portal as a source for geological, topographical, and hydrological information. 6.1 Designation & Classification Geologically Hazardous Areas are defined and designated through YMC 15.27.701, with an added provision noting lands located outside of mapped designations are not implied without risk. Fourteen additional sub- classifications are designated through city mapping mechanisms with the exception of Volcanic hazard areas due to geologic limitations. • Landslide Hazard Areas o LS3, LS2, and Low Risk • Oversteepened Slope Hazard Area o OS3, OS2, and Low Risk • Alluvial Fan/Flash Flooding hazard Areas (AF) • Avalanche Risk Hazard Areas (AR) • Stream Undercutting Hazard Areas o SU3, SU2, and SU1 • Earthquake Activity Hazard Area (EA) • Suspect Geological Hazard Areas (SUS) • Risk Unknown Hazard Areas (UNK) Recommendation: Pursuant to WAC 365-190-120(4) consider assessing geologically hazardous areas based on three risk classifications; Known or suspected risk, No known risk, or Risk Unknown. Recommendation: Pursuant to WAC 365-190-120(5), consider including references to the US Department of Agriculture Natural Resource Conservation Service (NRSC) regarding soil type classification to help administrators identify and classify potential erosion hazards areas. Recommendation: Consider directly referencing the combination of potential geologic, topographic, and hydrologic factors as listed in WAC 365-190-120(6)(a) through (h), to be used in assessing landslide hazard areas. Recommendation: Consider directly referencing the combination of historical earthquake damage, underlain settlement, surface faulting and soil liquefaction susceptibility factors as listed in WAC 365-190-120(7), to be used in assessing seismic hazard areas. Importantly, in order to ensure the risk classification as previously recommended (known or suspected risk, no known risk, or risk unknown) are appropriately designated geospatially, a professionally licensed Geologist and/or Hydrogeologist should be consulted prior to designating specific areas. A licensed Geologist and/or Hydrogeologist should also be consulted on designating erosion, landslide, or seismic hazards as recommended above. The above recommendations can be sought in addition to the existing designations as geospatially identified in existing city mapping mechanisms. 20 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 17 6.2 Protection & Reporting Avoiding disturbance of geologic hazards areas is the predominant protective approach, but WAC 365-190- 080(4) notes that some geological hazard can be mitigated through engineering, design, modified construction and mining practices resulting in acceptable risks to health and safety. The YMC 15.27.702 supplements protective measures for erosion hazards areas through implementation of regulatory standards aligned with the best management practices (BMPs) in the Stormwater Management Manual for Eastern Washington (Ecology, No. 04-10-076). Stream Undercutting Hazard Areas are also supplemented with provisions requiring critical area review in context with flood hazards and streams. Development review procedures help to minimize risks through requiring critical are development authorizations and Geological Hazard Reports as required by the administrative official. 6.3 Mapping While YMC 15.27.701 references the city’s “Erosion Hazards Areas of the City of Yakima” and “Geologically Hazardous Areas of the City of Yakima”, these maps are were not found to be available online. Alternatively, the city provides an online webmap with a geological Hazards layer available for reviewing five of the fourteen mentioned geological hazard classification; Landslide Intermediate Risk (LS2), Landslide High Risk (LS3), Oversteepend Slopes Intermediate Risk (OS2), Oversteepend Slopes High Risk (OS3), and Other. Recommendation: For clarity and to avoid referring to outdated maps, consider revising YMC 15.27.701 (Mapping and designation) to generally reference city maps as available to allow for updates and/or additions to mapped geological hazard areas. Recommendation: Pursuant to WAC 365-190-120(6), consider referencing the Department of Natural Resource’s Geologic Information Portal as a source for assessing landslide seismic hazards areas based on geological, topographic, and hydrologic factors. 7.0 CRITICAL AQUIFER RECHARGE AREAS Table 7. CARA Recommendations Code Section Reason/Consistency Recommendation 15.27.200 – Definitions generally. WAC 365-190-030 Consider including reference to susceptibility to reduced recharge to definition. 15.27.315(E)(2) – Supplemental report requirements for specific critical areas. RCW 36.70A.142 Consider including the siting of organic material management facilities to require Level Two Hydrological Assessment requirement. 15.27.810(C) – Guidance Documents Clarity Consider revising reference to include specific website addresses. 7.1 Definition , Classification , & Protection CARAs are defined in YMC 15.27. 200 according to WAC 365-190-030 but is missing the reference to the ‘susceptibility to reduced recharge’. Wellhead protection zones are appropriately classified according to the 21 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 18 Washington Department of Health (DOH) Wellhead Protection Program, Washington Office of Drinking Water, and Source Water Assessment Program (SWAP) Mapping Application. Specific prohibited activities are listed in YMC 15.27.820(B), and extensive performance standards are noted in YMC 15.27.820(C) including but not limited to secondary containment, vehicle fueling, stormwater infiltration, construction practices, fill materials, protection wells, and underground hydraulic systems. Recommendation: Consider revising the definition for CARAs to include the referencing drinking water source susceptibility to reduced recharge. 7.2 Quality & Quantity The city’s Part Eight of YMC Chapter 15.27 is found to address the protective measures used for characterizing groundwater resources by identification, susceptibility, inventorying, classification, designation, contamination protection, implementation of BMPS, and management of groundwater withdrawals. 7.3 Wellhead Protection Areas The DOH administers the wellhead protection program, with requirements applying to all Group A and Group B water systems. The city owns and operates 4 wells for the Water Resources Division treatment plant. Each wellhead protection area contains a unique analytically derived area of influence. In addition to Part Eight of YMC Chapter 15.27, the city supports protection of these critical areas with the City of Yakima 2017 Water System Plan. 7.5 Mapping & Reporting Supplemental report requirements for CARAs are noted in YMC 15.27.315, with provisions requiring a licensed geologist, hydrogeologist, or engineer to prepare a CARA report including surface reconnaissance, safety and appropriateness of proposed activities, construction practices, monitoring, mitigation, as well as requiring coordinated assessment with other potentially associated critical areas. Two levels of hydrological assessment are noted, with each level directly related to the proposed use’s level of influence and potential for impact. Pursuant to RCW 36.70A.142, County’s must regulate the siting of organic materials management facilities to ensure their establishment of organic materials management volumetric capacities. While this state requirement is applicable specifically to County’s, it would benefit the City of Yakima to address the same topic as a preventative measure for minimizing incompatible uses and potential impacts to residential areas. Recommendation: Consider including a reference to the siting of organic materials management facilities under YMC 15.27.315(E)(2) (Level Two Hydrological Assessment) as a proposed activity qualifying for additional reporting requirements. Recommendation : Consider revising YMC 15.27.810(C) (Guidance Documents) to not include specific website addresses, instead general reference these resources so that updates or reissuance does not warrant amendments to the code section. 8.0 REFERENCES 8.1 Critical Areas – Overall Requirements 22 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 19 City of Yakima, WA. Yakima Municipal Code, Chapter 15.27 – Critical Areas Ordinance. First accessed February 2025 at : https://www.codepublishing.com/WA/Yakima/#!/YakimaNT.html (Yakima Municipal Code). Department of Commerce. 2018. Summary of Critical Areas WAC Amendments. December 2018. Washington Department of Commerce. Olympia, WA. Department of Commerce. 2023. Critical Areas Handbook, A Handbook for Reviewing Critical Areas Regulations, Version 3. Washington Department of Commerce. Olympia, WA. Department of Commerce. 2024. Critical Area Checklist, A Technical Assistance Tool from Growth Management Services. Updated May 2024. Washington Department of Commerce. Olympia, WA. Department of Fish and Wildlife. 2023. Riparian Management Zone Checklist for Critical Areas Ordinances. Olympia, WA. 8.2 Frequently Flood ed Areas Ecology. 2021. (Ecology, 2021)WA State Model Ordinance, Version 2/24/2021, Evaluation Sheet. Washington State Department of Ecology. Olympia, WA Ecology. 2021. (Ecology, 2021-B)Comprehensive Planning for Flood Hazard management: A Guidebook. Washington State Department of Ecology. Publication #21-06-019. Olympia, WA 8.3 Fish & Wildlife Habitat Conservation Areas WDFW. 2025. (WDFW, 2025) Guidelines for Determining Site Potential Tree Height from Field Measurements. Olympia, WA. WDFW. 2025. PHS on the Web, Online webmap. Olympia, WA. First accessed August 2025 at: https://geodataservices.wdfw.wa.gov/hp/phs/ (PHS on the Web). WDFW. 2008. Priority Habitat and Species List, Updated June 2023. Olympia, WA. 291pp. WDFW. 2020. (Quinn, 2020) Riparian Ecosystems, Volume 1: Science synthesis and management implications. Timothy Quinn, George Wilhere and Kirk Krueger, (Managing Editors). A Priority Habitat and Species Document of the Washington Department of Fish and Wildlife, Olympia, Washington. WDFW. 2020. (Rentz et al., 2020) Riparian Ecosystems, Volume 2: Management Recommendations. Amy Windrope, Timothy Quinn, Keith Folkerts, and Terra Rentz. A Priority Habitat and Species Document of the Washington Department of Fish and Wildlife, Olympia, Washington. WDFW (Washington Department of Fish and Wildlife, Washington State Department of Natural Resources, Washington State Conservation Commission). (WDFW-Shrubsteppe, 2024). March 2024. Washington Shrubsteppe Restoration and Resiliency Initiative: Long-Term Strategy 2024-2054. Olympia, Washington. 23 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 20 8.4 Wetlands Environmental Laboratory. 1987. Corps of Engineers Wetland Delineation Manual. Technical Report Y-87-1. Environmental Laboratory, Department of the Army, Corps Waterways Experiment Station, Vicksburg, MS. Granger, Terri, Thomas Hruby, Andy McMillan, D. Peters, J. Rubey, Dianne Sheldon, S. Stanley, E. Stockdale. April 2005. Wetlands in Washington State - Volume 2: Guidance for Protecting and Managing Wetlands. Washington State Department of Ecology. Publication #05-06-008. Olympia, WA. Hruby, T. 2012. Calculating Credits and Debits for Compensatory Mitigation in Western Washington – Final Report. Washington Department of Ecology. Publication #10-06-011. Olympia, WA. 110 pp + App. Hruby, Thomas, Donna Bunten, Amy Yahnke and Jerry Franklin. 2017. Characterizing Wetland Buffer in Washington State. Washington Department of Ecology. Publication #17-06-008. Olympia, WA. 118 pp + App. Hruby, T., K. Harper, and S. Stanley. 2017. Selecting Wetland Mitigation Sites Using a Watershed Approach (Western Washington). Washington Department of Ecology. Publication #09-06-032. Olympia, WA. 34 pp + App. Hruby, Thomas. 2014. Washington State Wetland Rating System for Western Washington: 2014 Update. Washington Department of Ecology. Publication #14-06-029. Olympia, WA. 118 pp + App. Hruby, Thomas. 2014. Washington State Wetland Rating System for Western Washington: 2023 Update. Washington Department of Ecology. Publication #23-06-009. Olympia, WA. 147 pp + App. Hruby, Thomas. 2013. Update on Wetland Buffers: The State of the Science, Final Report. Washington Department of Ecology. Publication #13-06-011. Olympia, WA. 33 pp. Johnson, Patricia, Dana L. Mock, Andy McMillan, Lauren Driscoll, Tom Hruby. February 2002. Washington State Wetland Mitigation Evaluation Study – Phase 2: Evaluating Success. Washington State Department of Ecology. Publication #02-06-009. Olympia, WA. Sheldon, Dyanne, Tom Hruby, Patricia Johnson, Kim harper, Andy McMillam, Teri Granger, Stephen Stanley, Erik Stockdale. March 2005. Wetlands in Washington State - Volume 1. A Synthesis of the Science. Washington State Department of Ecology. Publication #05-06-006. Olympia, WA. US Army Corps of Engineers (Army Corps 2010). 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (Version 2.0). US Army Engineer Research and Development Center Environmental Laboratory. Vicksburg, MS. Publication # ERDC/EL TR-10-3 [May 2010]. Washington State Department of Ecology. 2022. Wetland Guidance for Critical Area Ordinance (COA) Updates: Western and Eastern Washington, Publication No. 22-06-014. October 2022. Shorelands and Environmental Assistance Program, Olympia, WA. 36 pp + App. Washington State Department of Ecology, US Army Corps of Engineers Seattle District, and US Environmental Protection Agency Region 10. 2021. Wetland Mitigation in Washington State – Part 1: Agency Policies and 24 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 21 Guidance (Version 2). April 2021. Washington State Department of Ecology Publication #21-06-003. Olympia, WA. Washington State Department of Ecology, US Army Corps of Engineers Seattle District, and US Environmental Protection Agency Region 10. March 2006. Wetland Mitigation in Washington State – Part 2: Developing Mitigation Plans (Version 1). Washington State Department of Ecology Publication #06-06-011b. Olympia, WA. 8.5 Geologically Hazardous Areas WADNR, Washington Geologic Survey. Washington Geologic Information Portal, online webmap. First accessed February 2025 at: https://geologyportal.dnr.wa.gov/2d-view#wigm?-14404025,- 12535292,5509193,6538952?Surface_Geology,500k_Surface_Geology,Map_Units, (Washington Geologic Information Portal). 8.6 Critical Aquifer Recharge Areas (CARA) City of Yakima, WA. 2017. City of Yakima 2017 Water System Plan, System Number 991509. Yakima County, Washington. Washington State Department of Ecology. 2021. Critical Aquifer Recharge Area Guidance. Revised March 2021. Washington State Department of Ecology Publication #05-10-028. Olympia, WA. Washington State Department of Ecology. 2005. Implementation Guidance for Ground Water Quality Standards. October 2005. Washington State Department of Ecology Publication #96-02. Olympia, WA. Washington State Department of Health, Office of Drinking Water. 2017. Wellhead Protection Program Guidance Document. January 2017. Washington State Department of Health Publication #DOH 331-018. Olympia, WA. 25 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 22 APPENDIX A WA Dept. of Commerce Critical Areas Checklist 26 of 83 Page 1 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 Critical Areas Checklist A Technical Assistance Tool from Growth Management Services – updated May 2024 Name of city or county: City of Yakima, WA Staff contact, phone, and e-mail address: Trevor Martin, 509-575-6183, Ask.Planning@YakimaWA.gov INSTRUCTIONS This checklist is intended to help local governments update their development regulations, pursuant to the schedule in RCW 36.70A.130(5). We strongly encourage but do not require jurisdictions to complete the checklist and return it to Growth Management Services (GMS), along with their updates. However, If the jurisdiction is using a portion of their Periodic Update Grant (PUG) to update the Critical Areas Ordinance, this checklist is required. This checklist may be used by all jurisdictions, including those local governments planning for resource lands and critical areas only. For general information on update requirements, refer to A Guide to the Periodic Update Process Under the Growth Management Act – Fully Planning Counties & Cities, 2022 and WAC 365-196-610 . For additional information, resources, and general checklists pertaining to comprehensive plan and development regulation periodic updates please visit Commerce’s Growth Management Act Periodic Update webpage. Bold items are a GMA requirement or may be related requirements of other state or federal laws. Underlined items are links to Internet sites and may include best practices or other ideas to consider. Commerce WAC provisions are advisory under Commerce’s statutory mandate to provide technical assistance, RCW 43.330.120 which states that the Department of Commerce “…shall help local officials interpret and implement the different requirements of the act through workshops, model ordinances, and information materials.” If you have questions, call GMS at (360) 725-3066. How to fill out the checklist Using the current version of your critical areas regulations, fill out each item in the checklist. Select the check box or type in text fields, answering the following question: Is this item addressed in your current Critical Areas Ordinance (CAO)? If YES, fill in the form with citation(s) to where in the plan or code the item is addressed. We recommend using citations rather than page numbers because they stay the same regardless of how the document is printed. If you have questions about the requirement, follow the hyperlinks to the relevant statutory provision or rules. If you still have questions, visit the Commerce Growth Management Services Web page or contact one of the Commerce planners assigned to your region. CONTENTS Instructions………..………….….1 Overall Requirements………..2 Wetlands…………………………….3 Critical Aquifer Recharge Areas…………………………….……5 Frequently Flooded Areas….6 Geologically Hazardous Areas…………………………………. 7 Fish and Wildlife Habitat Conservation Areas….………..8 Designating and Protecting Waters of the State……..….....9 Anadromous Fisheries………………………….....10 Reasonable Use Exceptions…………………….…….10 Agricultural Activities…….…..11 Forest Practices Regulations……………………....11 Good Ideas…….……..……….….12 LOCAL GOVERNMENT DIVISION 27 of 83 Page 2 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 CRITICAL AREAS Regulations protecting critical areas are required by RCW 36.70A.060(2) and RCW 36.70A.172(1). WAC 365-195-900 through 925 provide guidelines. Guidance can also be found in Commerce’s Critical Areas Handbook (2022); the Minimum Guidelines WAC 365-190-080 through 130; Best Available Science WAC 365-195; and Procedural Criteria, WAC 365-196-485 and WAC 365-196-830, and on Growth Management’s Critical Areas webpage. Regulations required to protect critical areas Addressed in current plan or regulations? If yes, note where OVERALL REQUIREMENTS The CAO includes best available science to clearly designate and protect all critical areas that might be found within the jurisdiction. 1. Designation of Critical Areas RCW 36.70A.170(1)(d) requires all counties and cities to designate critical areas. RCW 36.70A.170(2) requires that counties and cities consider the Commerce Minimum Guidelines pursuant to RCW 36.70A.050. RCW 36.70A.050 directs Commerce to adopt the Minimum Guidelines to classify critical areas. WAC 365-190-080 through 130 provide guidance on defining or “designating” each of the five critical areas. WAC 365-190-040 outlines the process to classify and designate natural resource lands and critical areas. 2. Definition of Critical Areas RCW 36.70A.030(11) provides definitions for critical areas. Sections (20) regarding geologically hazardous areas; and (48) regarding wetlands were updated in 2010. WAC 365-190-030 provides definitions in the Minimum Guidelines. 3. Protection of Critical Areas RCW 36.70A.060(2) requires counties and cities to adopt development regulations that protect the critical areas required to be designated under RCW 36.70A.170. RCW 36.70A.172(1) requires the inclusion of best available science in developing policies and development regulations to protect the functions and values of critical areas. In addition, counties and cities must give special consideration to conservation or protection measures necessary to preserve or enhance anadromous fisheries. WAC 365-196-830 provides guidance on protection of critical areas. Was BAS documented in the record for the review and updates to the critical areas regulations? ☒ Yes ☐ No Location in Text: 1. Designation YMC Chapter 15.27 Part One & YMC Chapter 17.09 (SMP) 2. Definitions YMC 15.27.200, YMC 15.27.700, & YMC 17.01.090 (SMP) 3. Protection YMC Chapter 15.27 Article IV-Permit Review Critieria, YMC 15.27.321, YMC 15.27.407-15.27.408, YMC 15.27.501, YMC 15.27.602, YMC 15.27.702, YMC 15.27.820, & YMC Chapter 17.09 4. Best Available Science YMC 15.27.150, YMC 15.27.314(B), YMC 15.27.500(A), YMC 15.27.501(2), YMC 15.27.604(A), YMC 15.27.605(I)(7), YMC 17.01.090 (SMP), 28 of 83 Page 3 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 4. Inclusion of Best Available Science RCW 36.70A.172(1) requires inclusion of the best available science (BAS). WAC 365-195-900 through 925 outlines recommended criteria for determining which information is the BAS, for obtaining the BAS, for including BAS in policies and regulations, for addressing inadequate scientific information, and for demonstrating “special consideration” to conservation or protection measures necessary to preserve or enhance anadromous fisheries. WAC 365-195-915 provides criteria for including BAS in the record. 5. No net loss of critical area functions and values is a requirement for development regulations in WAC 365-196-830(4). If development regulations allow harm to critical areas, they must require compensatory mitigation of the harm. YMC 17.03.090 (SMP), YMC 17.05.020 (SMP), YMC 17.07.120 (SMP), YMC 17.09.010(P), (I)(4) (SMP), & YMC 17.09.030-17.09.040 Note: The code sections of the SMP (Title 17) referenced above utilized the terms “scientific evidence” or “scientific and technical information” instead of “best available science”. Do your regulations address no net loss and require compensatory mitigation? ☒ Yes ☐ No Location in Text: YMC 15.27.130, YMC 15.27.314-15.27.321, YMC 15.27.605, YMC 17.01.030(H) (SMP), YMC 17.01.040(K) (SMP), YMC 17.03.030- 17.03.060 (SMP), YMC 17.05.020-17.05.060 (SMP), YMC 17.07.050 (SMP), YMC 17.07.070 (SMP), YMC 17.07.090 (SMP), YMC 17.07.130 (SMP), YMC 17.07.160- 17.07.170 (SMP), YMC 29 of 83 Page 4 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 17.09.010(B)(1) and (Q) (SMP), YMC 17.09.050(C) (SMP), YMC 17.13.160 (SMP) WETLANDS DEFINITION The definition of wetlands is consistent with RCW 36.70A.030(48). Is the wetland definition consistent with RCW 36.70A.030(48)? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.200 Definitions, & YMC 17.01.090 Definitions (SMP) WETLANDS DELINEATION Wetlands are delineated using the approved federal wetland delineation manual and applicable regional supplements in accordance with WAC 173-22-035. See Ecology’s Wetland Delineation page and WAC 365-190-090 for additional assistance. Are wetlands delineated using the approved Federal Wetland Delineation Manual and Regional Supplements? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.601, & YMC 17.09.040(B)(1) (SMP) 30 of 83 Page 5 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 WETLANDS PROTECTION Policies and regulations protect the functions and values of wetlands. RCW 36.70A.172(1). Counties and cities are encouraged to make their actions consistent with the intent and goals of “protection of wetlands”, Executive Order 89-10 as it existed on September 1, 1990. WAC 365-190-090(3) recommends using a wetlands rating system that evaluates the existing wetland functions and values to determine what functions must be protected. Ecology updated its recommended wetlands rating systems effective January 2015. For information on the rating system, including the July 2018 adjustments to ranges for habitat scores, see: • 2014 Updates to the Washington State Wetland Rating Systems • Washington State Wetland Rating System for Western Washington • Washington State Wetland Rating System for Eastern Washington For other resources and guidance on protecting wetlands, go to Ecology’s Local Wetland Regulations: Growth Management Act technical assistance and see: • Wetland Guidance for Critical Areas Ordinance (CAO) Updates: Western and Eastern Washington (2022) Do the regulations use a rating system to determine wetlands protection? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.603, & YMC 17.09.040(D)(2) (SMP) CRITICAL AQUIFER RECHARGE AREAS Policies and regulations protect the functions and values of critical aquifer recharge areas. RCW 36.70A.172(1). Policies and regulations protect the quality and quantity of groundwater used for public water supplies. RCW 36.70A.070(1) and WAC 365-196-485(1)(d). The following references also relate to protection of groundwater resources: • RCW 90.44 – Regulation of Public Groundwaters • RCW 90.48 – Water Pollution Control • RCW 90.54 – Water Resources Act of 1971 • RCW 36.36.020 - Creation of aquifer protection area (1985) • WAC 365-190-100 Critical Aquifer Recharge Areas 2023 • WAC 173-100 Groundwater Management Areas and Programs (1988) • WAC 173-200 Water Quality Standards for Groundwaters of the State of Washington (1990) • WAC 365-196-735 Consideration of state and regional planning provisions (list) (2010) The Critical Aquifer Recharge Areas Guidance Document (2021) provides information on protecting functions and values of critical aquifer recharge areas, best available science, how to work with state and local regulations and adaptive management. Also, consider the following: If groundwater is used for potable water, do regulations protect the quality and quantity of ground water? ☒ Yes ☐ No ☐ N/A Location in text: YMC 15.27.800 & YMC 17.09.060 (SMP) 31 of 83 Page 6 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 CRITICAL AQUIFER RECHARGE AREAS • Prohibiting or strictly regulating hazardous uses in critical aquifer recharge areas (CARAs) and designating and protecting wellhead areas. See Ecology’s guidance on Critical Aquifer Recharge Areas. • Limiting impervious surfaces to reduce stormwater runoff, as required under Phase I and II municipal stormwater permits. Ecology’s Stormwater Manual for Western Washington (2012) includes low impact development (LID) related definitions, requirements, and an LID performance standard. See Stormwater Management and Design Manuals on Ecology’s web page. • For additional guidance on LID resources, see Commerce’s Incentivizing low- impact development guidebook. Are the critical aquifer recharge regulations consistent with current mapping of these critical areas? ☒ Yes ☐ No ☐ N/A Location in text: YMC 15.27.800- 15.27.820 & YMC 17.09.060(B) (SMP) FREQUENTLY FLOODED AREAS Regulations protect the functions and values of frequently flooded areas and safeguard the public from hazards to health and safety. RCW 36.70A.172(1). WAC 365-196-830 provides: "’Protection‘ in this context means preservation of the functions and values of the natural environment, or to safeguard the public from hazards to health and safety.” WAC 365-190-110 directs counties and cities to consider the following when designating and classifying frequently flooded areas: (a) Effects of flooding on human health and safety, and to public facilities and services; (b) Available documentation including federal, state, and local laws, regulations, and programs, local studies and maps, and federal flood insurance programs, including the provisions for urban growth areas in RCW 36.70A.110; (c) The future flow flood plain, defined as the channel of the stream and that portion of the adjoining flood plain that is necessary to contain and discharge the base flood flow at build out; (d) The potential effects of tsunami, high tides with strong winds, sea level rise, and extreme weather events, including those potentially resulting from global climate change; (e) Greater surface runoff caused by increasing impervious surfaces. Classification of and regulations for frequently flooded areas should not conflict with the FEMA requirements for the National Flood Insurance Program (NFIP). See Ecology’s Frequently Flooded areas: Critical Areas Ordinance webpage and 44 CFR 60. Communities that are located on Puget Sound or the Strait of Juan de Fuca, or have lakes, rivers or streams that directly or indirectly drain to those water bodies, are subject to the NFIP Biological Opinion (BiOp) for Puget Sound. The biological opinion required changes to the implementation of the NFIP in order to meet the Are frequently flooded areas designated and regulated using FEMA and Ecology guidance? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27 Part Four – Flood Hazard Areas; The City updated YMC 15.27 Part Four in 2021 (Ord. 2021-021), amending and adding sections related to the identification and establishment of flood hazard areas (YMC 15.27.400), Methods of Reducing Flood Losses (YMC 15.27.403), and amending sections related to Penalties, Liabilities, Variances, New Construction, General Standards for Construction 32 of 83 Page 7 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 FREQUENTLY FLOODED AREAS requirements of the Endangered Species Act (ESA) in the Puget Sound watershed. FEMA Region X has developed an implementation plan that allows communities to apply the performance standards contained in the Biological Opinion by implementing: 1) a model ordinance; 2) a programmatic Checklist; or 3) on a permit by permit basis as long as it can be demonstrated that there is no adverse effect to listed species. Communities have the option of utilizing their CAOs as part of a programmatic response to address the requirements of the biological opinion. FEMA must approve a community’s biological opinion compliance strategy. Additional resources: RCW 86.12 Flood Control by Counties RCW 86.16 Floodplain Management RCW 86.26 State Participation in Flood Control Maintenance RCW 86.16.041 Floodplain Management Ordinance and Amendments WAC 173-158-070 Requirements for construction in Special Flood Hazard Areas Techniques, Floodproofing Certificates, Storage of Materials, Critical Facilities, Livestock Sanctuary Areas, and Specific Standards for Residential and Nonresidential Construction, Manufactured Homes, Enclosed Areas, areas with or without established base flood elevations / floodways, Shallow Flooding Areas, Structure Drainage, Recreational Vehicles, and Permit Application / Review Process. YMC 17.03.010 & 17.05.060 through the establishment of the Floodway/Channel Migration Zone (CMZ) within shoreline environmentally designated areas, also supports the protection of overflow channels and preservation of natural hydraulic, geologic, and biological functions. 33 of 83 Page 8 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 FREQUENTLY FLOODED AREAS Are you utilizing your CAO as part of a programmatic response to the BiOp? ☐ Yes ☐ No ☒ N/A Location in Text: Not Applicable; Only applies to communities with watersheds directly or indirectly draining into the Puget Sound or the Strait of Juann Fuca. DEFINITION OF GEOLOGICALLY HAZARDOUS AREAS The definition of geologically hazardous areas is consistent with RCW 36.70A.030(20) and WAC 365-190-120(1). “Geologically hazardous areas" means areas that because of their susceptibility to erosion, sliding, earthquake, or other geological events, are not suited to the siting of commercial, residential, or industrial development consistent with public health or safety concerns. Is the geologically hazardous areas definition consistent with RCW 36.70A.030(20)? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.700(A); The definition is uniquely listed within YMC 15.27 Part Seven and not within the preliminary Definitions section (YMC 15.27.200). The critical area is also defined in YMC 17.09.050(A)(1) (SMP). 34 of 83 Page 9 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 PROTECTION OF GEOLOGICALLY HAZARDOUS AREAS Regulations protect the functions and values of geologically hazardous areas and safeguard the public from hazards to health and safety. RCW 36.70A.172(1). WAC 365-196-830 provides: “’Protection’" in this context means preservation of the functions and values of the natural environment, or to safeguard the public from hazards to health and safety.” Geologically hazardous areas are designated, and their use is regulated or limited consistent with public health and safety concerns. RCW 36.70A.030(20) WAC 365-190-120 describes the different types of hazardous areas: • Geologically hazardous areas include: • Erosion hazards • Landslide hazards • seismic hazards • tsunami hazards • volcanic hazards • channel migration zones • areas subject to other geological events such as coal mine hazards including: mass wasting, debris flows, rock falls, and differential settlement. The Department of Natural Resource’s Washington Geological Survey Geologic Hazards and the Environment website includes information on earthquakes and faults, landslides, volcanoes and lahars, tsunamis, hazardous minerals, emergency preparedness, historic mines and includes geologic hazard maps that can be accessed from the Geologic Information Portal. Are uses in geologically hazardous areas designated and regulated or limited consistent with public health and safety? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27 Part Seven & YMC 17.09.050 (SMP) DEFINITION OF FISH AND WILDLIFE HABITAT AND CONSERVATION AREAS The definition of fish and wildlife habitat conservation areas is consistent with WAC 365-190-030(6). The definition of fish and wildlife habitat conservation areas was amended to state that they do not include: “such artificial features or constructs as irrigation delivery systems, irrigation infrastructure, irrigation canals, or drainage ditches that lie within the boundaries of and are maintained by a port district or an irrigation district or company”. Is the FWHCA definition consistent with WAC 365-190- 030(6)? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.200 & YMC 17.01.090 (SMP) 35 of 83 Page 10 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 PROTECTION OF FISH AND WILDLIFE HABITAT AND CONSERVATION AREAS Policies and regulations protect the functions and values of fish and wildlife habitat conservation areas. RCW 36.70A.172(1) and WAC 365-190-030(6). WAC 365-190-130(4) says local jurisdictions must consult current information on priority habitats and species identified by WDFW. Additional information that must be consulted is available from DNR’s natural heritage program and aquatic resources program. BAS regarding biodiversity areas and corridors has advanced significantly. Recent updates and resources include: • Aquatic Habitat Guidelines • Priority Habitat and Species maps • Priority Habitats and Species List (updated June 2023) • Priority Habitats and Species: Management recommendations: • Landscape Planning for Washington’s Wildlife (2009) • Land Use Planning for Salmon, Steelhead and Trout (2009) • Riparian Ecosystems, Volume 1: Science Synthesis and Management Implications (2020) • Riparian Ecosystems, Volume 2: Management Recommendations (2020) • Riparian Management Zone Checklist for CAOs (2023) • Shrub-Steppe Management Recommendations (2020) • Oregon White Oak Woodlands Ecosystems Management Recommendations (1998) • Management recommendations for Washington's Priority Species (by taxa) • Puget Sound Kelp Conservation and Recovery Plan (2020) • Stream Habitat Restoration Guidelines (2012) • Water Crossing Design Guidelines (2013) “Areas where endangered, threatened, and sensitive species have a primary association” must be considered per WAC 365-190-130(2)(a). Consult WDFW’s Threatened and Endangered Species list and U.S. Fish and Wildlife Service’s Information for Planning and Consultation resources for up to date information on all state and federal listed species. Also see the Puget Sound Partnership’s Salmon Recovery website for Water Resource Inventory Area (WRIA) Plans in Puget Sound. Have you reviewed your regulations regarding any applicable changes in management recommendations for priority habitats and species? ☒ Yes ☐ No ☐ N/A Location in Text YMC 15.27 Part Five, YMC 17.09.010(D)(3) and (Q) (SMP); Have you reviewed your regulations regarding any changes in species listings? ☒ Yes ☐ No ☐ N/A Location in Text YMC 15.27.502-507 & YMC 17.09.030(C) and (D) (SMP) 36 of 83 Page 11 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 DESIGNATING AND PROTECTING WATERS OF THE STATE RCW 90.48.020 defines waters of the state, which include all surface waters, salt waters, groundwater and all other water courses in Washington. WAC 365-190- 130(2)(f) recommends designating all waters of the state as fish and wildlife habitat conservation areas (FWHCAs). Stream types are classified in WAC 222-16-030 with field verification, or an alternate system that considers factors listed in WAC 365-190-130(4)(f)(iii). See http://www.dnr.wa.gov/forest-practices-water-typing to use Washington State Department of Natural Resources (DNR)’s stream typing system. Establish riparian management zones to maintain no net loss of riparian ecosystem functions and values. Designate areas that risk contaminating or harming shoreline resources including tidelands and bedland suitable for shellfish harvest, kelp and eelgrass beds and forage fish spawning areas. Do you designate waters of the state as FWHCAs? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.502(A)(4) & YMC 17.09.030(C)(4) (SMP) Do your regulations protect waters of the state? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27 Part Five & YMC 17.09.030(H) through (P) 37 of 83 Page 12 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 ANADROMOUS FISHERIES Policies and regulations for protecting critical areas give special consideration to conservation or protection measures necessary to preserve or enhance anadromous fisheries. RCW 36.70A.172(1) is the requirement and WAC 365-195- 925 lists criteria involved. This requirement applies to all five types of critical areas. WAC 365-190-130(4)(i) recommends sources and methods for protecting fish and wildlife habitat conservation areas, including salmonid habitat. Counties and cities may use information prepared by the United States Department of the Interior Fish and Wildlife Service, National Marine Fisheries Service, the Washington State Department of Fish and Wildlife, the State Recreation and Conservation Office, and the Puget Sound Partnership to designate, protect and restore salmonid habitat. Counties and cities should consider recommendations found in the regional and watershed specific salmon recovery plans (see the Governor's Salmon Recovery Office webpage and the Puget Sound Partnership’s Salmon Recovery webpage). Land Use Planning for Salmon, Steelhead and Trout: A land use planner’s guide to salmonid habitat protection and recovery (October 2009) is an excellent resource. Do your regulations give special consideration to anadromous fisheries? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.150 & YMC 17.09.030 REASONABLE USE EXCEPTIONS The Critical Areas Ordinance (CAO) allows for “reasonable use” if the CAO would otherwise deny all reasonable use of property. Reasonable use provisions should limit intrusions into critical areas to the greatest extent possible and apply the mitigation sequence as needed for no net loss of ecosystem functions and values RCW 36.70A.370. Common exemptions include emergencies, remodels that do not further extend into critical areas, surveying, walking, and development that has already been completed with critical areas review under a previous permit. See Critical Areas Handbook, Chapter 3: Structuring Critical Areas Regulations, p.10 (Updated 2022). Do you have reasonable use provisions? ☒ Yes ☐ No Location in Text: YMC 15.27.318; SMP “Variance Provisions” are provided in YMC 17.13.080 38 of 83 Page 13 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 AGRICULTURAL ACTIVITIES (COUNTIES ONLY) Non-VSP Counties Critical areas regulations as they specifically apply to agricultural activities in counties or watersheds not participating in the Voluntary Stewardship Program (VSP) have been reviewed, and if needed, revised pursuant to RCW 36.70A.130. RCW 36.70A.710(6) "Agricultural activities" means all agricultural uses and practices as defined in RCW 90.58.065. VSP Counties After watershed work plan approval, VSP counties are encouraged to reference and describe their participation in the program within their critical areas development regulations (WAC 365-196-832). See Critical Areas Handbook, Chapter 5: Protecting Critical Areas in Natural Resource Lands (2022). Did you review your regulations as they apply to agricultural activities? ☐ Yes ☐ No ☒ N/A Location in Text: Not Applicable to the City of Yakima (Counties Only) FOREST PRACTICES APPLICATION REGULATIONS If applicable, regulations for forest practices have been adopted: RCW 36.70A.570. RCW 76.09.240, requires many counties over 100,000 in population, and the cities and towns within those counties to adopt regulations for forest practices. These are often included in clearing and grading ordinances. Have you adopted forest practices regulations? ☐ Yes ☒ No ☐ N/A Location in Text: Related provisions related to Forest Practices are included in: YMC 7.82.010 Definitions. (Stormwater) – New Development, YMC 7.82.090.4 Exemptions. (Construction Stormwater Runoff), YMC 7.83.020 Definitions. (Stormwater) – New Development, YMC 7.83.040.1.a Exemptions. (Post-Construction Stormwater Runoff), YMC 39 of 83 Page 14 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 17.01.090 Definitions. (SMP) – Forest land, & YMC 17.01.090 Definitions. (SMP) – Forest practices GOOD IDEAS Non-regulatory measures to protect or enhance functions and values of critical areas may be used to complement regulatory methods. These may include: • public education • stewardship programs • pursuing grant opportunities • water conservation • joint planning with other jurisdictions and non-profit organizations • stream and wetland restoration activities • transfer of development rights Monitoring and adaptive management is encouraged in WAC 365-195-905(6) to improve implementation of your regulations. See Commerce’s Monitoring and Adaptive Management chapter in the Critical Areas Handbook, Chapter 7: Monitoring and Adaptive Management of Critical Areas (2022). Are you using non- regulatory measures to protect critical areas? ☒ Yes ☐ No Location in Text: Joint Planning with Yakima County, WA Dept. of Ecology, WA Dept. of Fish & Wildlife, & Yakama Nation. Do you have a monitoring and adaptive management program for your CAO? ☐ Yes ☒ No Location in Text: Monitoring provisions are located throughout YMC 15.27, but adaptive management mechanism is not present. 40 of 83 OCTOBER 2025 | COA GAP ANALYSIS & BAS MEMO 23 APPENDIX B WA Dept. of Fish & Wildlife Riparian Management Zone Checklist 41 of 83 Washington Department of Fish and Wildlife 1 Riparian Management Zone Checklist for Critical Areas Ordinances A Technical Assistance Tool – April 2023 Purpose The Washington Department of Fish and Wildlife (WDFW) has developed guidance to support local jurisdictions as they designate and protect riparian ecosystems as critical areas (i.e., Fish and Wildlife Habitat Conservation Areas, FWHCAs1) consistent with the goals of the Growth Management Act and Shoreline Management Act. Volume 1: Science Synthesis and Management Implications (Quinn et al. 2020) is a source of Best Available Science (BAS) that describes how riparian areas and surrounding watersheds affect ecological functions and aquatic habitats. Volume 1 is intended to inform policies related to management of riparian areas. Volume 2: Management Recommendations (Rentz et al. 2020) provides guidance to assist cities and counties with the protection and restoration of healthy, intact, and fully functioning riparian ecosystems, which are fundamental for clean water, healthy salmon populations, and climate-resilient watersheds. This guidance supports compliance with state statute 2, which calls for BAS to be included in developing policies and development regulations to protect the functions and values of critical areas. This checklist is designed to help local planners translate BAS-based recommendations into Critical Areas Ordinance (CAO) amendments (reference Addendum for examples). If you need help updating your CAO and/or completing this checklist, use WDFW's appropriate Land Use Planning Contact Email for technical assistance. Instructions This checklist is a voluntary tool that supplements Commerce’s Critical Areas Checklist, specifically the section on Protection of Fish and Wildlife Habitat and Conservation Areas. 1. Column 1 provides a list of WDFW’s key Riparian Management Recommendations (RMR) in the form of CAO-related questions. 2. Column 2 indicates the location in Volume 2 where further detail about each RMR can be found. Definitions of terms can be found in the glossary of Volume 2. 3. In column 3, check the appropriate box and where appropriate, cite the section in your CAO where the RMR is addressed. Your response to this question may change as your CAO is amended. 4. In column 4, describe how your CAO addresses or does not address the RMR or why the RMR may not apply (“N/A”). 5. If sections of your CAO do not yet address the RMR, please refer to the location cited in Volume 2 and any additional BAS-based guidance to update your CAO language (and revise columns 3 and 4 accordingly). This is meant to be an iterative process through which your CAO can better designate and protect riparian areas the more boxes are checked “Y.” Rows that remain checked “N” after all CAO amendments have been proposed may represent departures from BAS that must be documented and explained 3. PREPARED FOR (Jurisdiction Name): PREPARED BY (Name, Title, email): DATE: 1 WAC 365-190-130 2 RCW 36.70A.172(1) 3 WAC 365-195-915 WashingtonDepartment ofFISH & WILDLIFE 42 of 83 Washington Department of Fish and Wildlife 2 Riparian Management Recommendation (RMR) Location in RMR Vol. 2 Citation in CAO How Addressed in CAO (or why not addressed in CAO) A. Does your CAO intend to protect all key riparian ecosystem functions (i.e., shade, root strength, nutrient input, wood input, and pollution control)? Section 2.2.2 ☐ Yes ☐ No ☐ N/A Citation: B. Depending on your ecoregion(s), do your FWHCAs utilize the appropriate methodology (whichever width is greater) for delineating riparian management zones (RMZs) for all stream types? • the Site-Potential Tree Height (at age 200 years, SPTH200), • the extent of native riparian vegetation, or • the minimum pollution removal distance of 100 feet Section 2.3 and Fig. 2.4 ☐ Yes ☐ No ☐ N/A Citation: C. If your jurisdiction does not delineate RMZs consistent with the methodologies listed in question B, do your FWHCAs meet the intent of the RMR in Vol. 2 (or are they otherwise consistent with the BAS in Vol. 1) with regards to riparian functions? If protection varies by stream type, please address how and why protections vary by each type in your response. Section 2.3 and Fig. 2.4 ☐ Yes ☐ No ☐ N/A Citation: D. Where a channel migration zone (CMZ) is present, does the RMZ begin on the outer edge of the CMZ to the extent practicable (meaning, include areas having the potential to provide riparian functions and exclude functionally disconnected areas)? Section 2.3.3(B) ☐ Yes ☐ No ☐ N/A Citation: E. Is the RMZ width extended beyond a 100-foot minimum where needed to provide adequate pollution removal functions from upland adjacent land uses (i.e., especially at sites with steep slopes or poorly drained soils or where upland uses contribute nitrogen based on expert assessment)? Section 2.3.5, step 3 ☐ Yes ☐ No ☐ N/A Citation: 43 of 83 Washington Department of Fish and Wildlife 3 Riparian Management Recommendation (RMR) Location in RMR Vol. 2 Citation in CAO How Addressed in CAO (or why not addressed in CAO) F. In locations where riverine wetlands are present, do the RMZs incorporate them using the appropriate wetland delineation, assessment methodology, and protection (per Ecology)? Section 2.3.5, step 2 Section 3.2.2, #2 ☐ Yes ☐ No ☐ N/A Citation: G. Does FWHCA designation also support terrestrial species, habitat connectivity, and Priority Habitats within and adjacent to RMZs? Section 3.2.2, #2 ☐ Yes ☐ No ☐ N/A Citation: H. Does your CAO apply the mitigation sequence to ensure no net loss of riparian ecological functions and values due to permitted activities within RMZs delineated consistent with question B (or equivalent methods)? Section 3.2.1 ☐ Yes ☐ No ☐ N/A Citation: I. Does your CAO require that applicants provide a Critical Areas Report prepared by a qualified professional for projects in or near known or suspected FWHCAs, and require that a Habitat Management Plan be provided if FWHCAs are found to be present and/or impacted by the project? Section 3.2.2 ☐ Yes ☐ No ☐ N/A Citation: J. Does your CAO require that On-Site Sewage Systems are located outside of RMZs? Section 3.2.1, #1 ☐ Yes ☐ No ☐ N/A Citation: K. Does your CAO prohibit new development that requires bank protection/hardening now or in the future (taking into consideration channel migration, wind and wave action, and climate change)? Section 3.2.1, #2 ☐ Yes ☐ No ☐ N/A Citation: 44 of 83 Washington Department of Fish and Wildlife 4 Riparian Management Recommendation (RMR) Location in RMR Vol. 2 Citation in CAO How Addressed in CAO (or why not addressed in CAO) L. Could other regulations conflict with your CAO and inadvertently impact riparian functions (e.g., clearing, grading, and filling ordinances)? If so, does your code include a provision that the regulation which provides greater protection to critical areas shall apply? Section 3.2.1, #3 CA Handbook, Ch. 4 ☐ Yes ☐ No ☐ N/A Citation: M. Does the issuance of an exemption letter or permit for invasive and/or noxious plant removal require that impacts to fish, wildlife, and habitat are minimized (e.g., hand weeding with light equipment, use only Ecology-approved aquatic herbicides and adjuvants, avoid use of hazardous substances, and avoid soil compaction)? Section 3.2.1, #4 ☐ Yes ☐ No ☐ N/A Citation: N. Does your CAO include all of the following provisions? • define a “hazard tree” as a threat to life, property, or public safety, • require that the method of hazard tree removal not adversely affect riparian ecosystem functions to the extent practicable, • encourage the creation of snags (Priority Habitat features) rather than complete tree removal, • involve an avoidance and minimization of damage to remaining trees and vegetation within the RMZ, and • require a qualified arborist to evaluate requests for hazard tree removal Section 3.2.1, #7 ☐ Yes ☐ No ☐ N/A Citation: O. Does your CAO incorporate a pathway to mitigate or compensate for impacts to RMZs arising from emergency activities (e.g., bank stabilization to address imminent threats to homes)? Section 3.2.1, #9 ☐ Yes ☐ No ☐ N/A Citation: P. Does your CAO require that impacts and disturbances from recreational trails and interpretive facilities are minimized to the extent practicable, informed by Priority Habitats and Species data and management recommendations? Section 3.2.1, #10 ☐ Yes ☐ No ☐ N/A Citation: 45 of 83 Washington Department of Fish and Wildlife 5 Riparian Management Recommendation (RMR) Location in RMR Vol. 2 Citation in CAO How Addressed in CAO (or why not addressed in CAO) Q. Does your CAO include watershed–scale management considerations such as protecting and restoring watershed processes (e.g., channel movement, sediment transport); stormwater management; land management for stream temperatures; and protecting and restoring longitudinal, lateral, and vertical connectivity? Section 3.4 ☐ Yes ☐ No ☐ N/A Citation: R. Does the CAO include measures for bolstering climate resilience within critical areas (i.e., increase habitat connectivity, plan for a wider range of stream flows, and increase stream shading)? Section 1.4, #6 Section 3.4.1, GMA Climate Guidance ☐ Yes ☐ No ☐ N/A Citation: S. Is there a stated goal or intent in your CAO to retain and restore CMZs and RMZs to the extent practicable to maximize riparian function over time? Section 4.2 ☐ Yes ☐ No ☐ N/A Citation: T. Does your CAO promote incentives and include a streamlined review process for riparian restoration or enhancement projects to help facilitate projects that go “above and beyond” minimum regulatory requirements? Section 4.3 ☐ Yes ☐ No ☐ N/A Citation: U. Does your CAO establish a monitoring and adaptive management program designed to: • collect information on CAO effectiveness, • evaluate the potential for exemptions and variances to cumulatively affect riparian functions across your jurisdiction, and • improve permit implementation? Section 3.2, Chapter 5; CA Handbook, Ch. 7 ☐ Yes ☐ No ☐ N/A Citation: 46 of 83 Washington Department of Fish and Wildlife 1 Riparian Management Zone Checklist for Critical Areas Ordinances A Technical Assistance Tool – April 2023 Purpose The Washington Department of Fish and Wildlife (WDFW) has developed guidance to support local jurisdictions as they designate and protect riparian ecosystems as critical areas (i.e., Fish and Wildlife Habitat Conservation Areas, FWHCAs1) consistent with the goals of the Growth Management Act and Shoreline Management Act. Volume 1: Science Synthesis and Management Implications (Quinn et al. 2020) is a source of Best Available Science (BAS) that describes how riparian areas and surrounding watersheds affect ecological functions and aquatic habitats. Volume 1 is intended to inform policies related to management of riparian areas. Volume 2: Management Recommendations (Rentz et al. 2020) provides guidance to assist cities and counties with the protection and restoration of healthy, intact, and fully functioning riparian ecosystems, which are fundamental for clean water, healthy salmon populations, and climate-resilient watersheds. This guidance supports compliance with state statute 2, which calls for BAS to be included in developing policies and development regulations to protect the functions and values of critical areas. This checklist is designed to help local planners translate BAS-based recommendations into Critical Areas Ordinance (CAO) amendments (reference Addendum for examples). If you need help updating your CAO and/or completing this checklist, use WDFW's appropriate Land Use Planning Contact Email for technical assistance. Instructions This checklist is a voluntary tool that supplements Commerce’s Critical Areas Checklist, specifically the section on Protection of Fish and Wildlife Habitat and Conservation Areas. 1. Column 1 provides a list of WDFW’s key Riparian Management Recommendations (RMR) in the form of CAO-related questions. 2. Column 2 indicates the location in Volume 2 where further detail about each RMR can be found. Definitions of terms can be found in the glossary of Volume 2. 3. In column 3, check the appropriate box and where appropriate, cite the section in your CAO where the RMR is addressed. Your response to this question may change as your CAO is amended. 4. In column 4, describe how your CAO addresses or does not address the RMR or why the RMR may not apply (“N/A”). 5. If sections of your CAO do not yet address the RMR, please refer to the location cited in Volume 2 and any additional BAS-based guidance to update your CAO language (and revise columns 3 and 4 accordingly). This is meant to be an iterative process through which your CAO can better designate and protect riparian areas the more boxes are checked “Y.” Rows that remain checked “N” after all CAO amendments have been proposed may represent departures from BAS that must be documented and explained 3. PREPARED FOR (Jurisdiction Name): PREPARED BY (Name, Title, email): DATE: 1 WAC 365-190-130 2 RCW 36.70A.172(1) 3 WAC 365-195-915 WashingtonDepartment ofFISH & WILDLIFE 47 of 83 Washington Department of Fish and Wildlife 2 Riparian Management Recommendation (RMR) Location in RMR Vol. 2 Citation in CAO How Addressed in CAO (or why not addressed in CAO) A. Does your CAO intend to protect all key riparian ecosystem functions (i.e., shade, root strength, nutrient input, wood input, and pollution control)? Section 2.2.2 ☐ Yes ☐ No ☐ N/A Citation: B. Depending on your ecoregion(s), do your FWHCAs utilize the appropriate methodology (whichever width is greater) for delineating riparian management zones (RMZs) for all stream types? • the Site-Potential Tree Height (at age 200 years, SPTH200), • the extent of native riparian vegetation, or • the minimum pollution removal distance of 100 feet Section 2.3 and Fig. 2.4 ☐ Yes ☐ No ☐ N/A Citation: C. If your jurisdiction does not delineate RMZs consistent with the methodologies listed in question B, do your FWHCAs meet the intent of the RMR in Vol. 2 (or are they otherwise consistent with the BAS in Vol. 1) with regards to riparian functions? If protection varies by stream type, please address how and why protections vary by each type in your response. Section 2.3 and Fig. 2.4 ☐ Yes ☐ No ☐ N/A Citation: D. Where a channel migration zone (CMZ) is present, does the RMZ begin on the outer edge of the CMZ to the extent practicable (meaning, include areas having the potential to provide riparian functions and exclude functionally disconnected areas)? Section 2.3.3(B) ☐ Yes ☐ No ☐ N/A Citation: E. Is the RMZ width extended beyond a 100-foot minimum where needed to provide adequate pollution removal functions from upland adjacent land uses (i.e., especially at sites with steep slopes or poorly drained soils or where upland uses contribute nitrogen based on expert assessment)? Section 2.3.5, step 3 ☐ Yes ☐ No ☐ N/A Citation: 48 of 83 Washington Department of Fish and Wildlife 3 Riparian Management Recommendation (RMR) Location in RMR Vol. 2 Citation in CAO How Addressed in CAO (or why not addressed in CAO) F. In locations where riverine wetlands are present, do the RMZs incorporate them using the appropriate wetland delineation, assessment methodology, and protection (per Ecology)? Section 2.3.5, step 2 Section 3.2.2, #2 ☐ Yes ☐ No ☐ N/A Citation: G. Does FWHCA designation also support terrestrial species, habitat connectivity, and Priority Habitats within and adjacent to RMZs? Section 3.2.2, #2 ☐ Yes ☐ No ☐ N/A Citation: H. Does your CAO apply the mitigation sequence to ensure no net loss of riparian ecological functions and values due to permitted activities within RMZs delineated consistent with question B (or equivalent methods)? Section 3.2.1 ☐ Yes ☐ No ☐ N/A Citation: I. Does your CAO require that applicants provide a Critical Areas Report prepared by a qualified professional for projects in or near known or suspected FWHCAs, and require that a Habitat Management Plan be provided if FWHCAs are found to be present and/or impacted by the project? Section 3.2.2 ☐ Yes ☐ No ☐ N/A Citation: J. Does your CAO require that On-Site Sewage Systems are located outside of RMZs? Section 3.2.1, #1 ☐ Yes ☐ No ☐ N/A Citation: K. Does your CAO prohibit new development that requires bank protection/hardening now or in the future (taking into consideration channel migration, wind and wave action, and climate change)? Section 3.2.1, #2 ☐ Yes ☐ No ☐ N/A Citation: 49 of 83 Washington Department of Fish and Wildlife 4 Riparian Management Recommendation (RMR) Location in RMR Vol. 2 Citation in CAO How Addressed in CAO (or why not addressed in CAO) L. Could other regulations conflict with your CAO and inadvertently impact riparian functions (e.g., clearing, grading, and filling ordinances)? If so, does your code include a provision that the regulation which provides greater protection to critical areas shall apply? Section 3.2.1, #3 CA Handbook, Ch. 4 ☐ Yes ☐ No ☐ N/A Citation: M. Does the issuance of an exemption letter or permit for invasive and/or noxious plant removal require that impacts to fish, wildlife, and habitat are minimized (e.g., hand weeding with light equipment, use only Ecology-approved aquatic herbicides and adjuvants, avoid use of hazardous substances, and avoid soil compaction)? Section 3.2.1, #4 ☐ Yes ☐ No ☐ N/A Citation: N. Does your CAO include all of the following provisions? • define a “hazard tree” as a threat to life, property, or public safety, • require that the method of hazard tree removal not adversely affect riparian ecosystem functions to the extent practicable, • encourage the creation of snags (Priority Habitat features) rather than complete tree removal, • involve an avoidance and minimization of damage to remaining trees and vegetation within the RMZ, and • require a qualified arborist to evaluate requests for hazard tree removal Section 3.2.1, #7 ☐ Yes ☐ No ☐ N/A Citation: O. Does your CAO incorporate a pathway to mitigate or compensate for impacts to RMZs arising from emergency activities (e.g., bank stabilization to address imminent threats to homes)? Section 3.2.1, #9 ☐ Yes ☐ No ☐ N/A Citation: P. Does your CAO require that impacts and disturbances from recreational trails and interpretive facilities are minimized to the extent practicable, informed by Priority Habitats and Species data and management recommendations? Section 3.2.1, #10 ☐ Yes ☐ No ☐ N/A Citation: 50 of 83 Washington Department of Fish and Wildlife 5 Riparian Management Recommendation (RMR) Location in RMR Vol. 2 Citation in CAO How Addressed in CAO (or why not addressed in CAO) Q. Does your CAO include watershed–scale management considerations such as protecting and restoring watershed processes (e.g., channel movement, sediment transport); stormwater management; land management for stream temperatures; and protecting and restoring longitudinal, lateral, and vertical connectivity? Section 3.4 ☐ Yes ☐ No ☐ N/A Citation: R. Does the CAO include measures for bolstering climate resilience within critical areas (i.e., increase habitat connectivity, plan for a wider range of stream flows, and increase stream shading)? Section 1.4, #6 Section 3.4.1, GMA Climate Guidance ☐ Yes ☐ No ☐ N/A Citation: S. Is there a stated goal or intent in your CAO to retain and restore CMZs and RMZs to the extent practicable to maximize riparian function over time? Section 4.2 ☐ Yes ☐ No ☐ N/A Citation: T. Does your CAO promote incentives and include a streamlined review process for riparian restoration or enhancement projects to help facilitate projects that go “above and beyond” minimum regulatory requirements? Section 4.3 ☐ Yes ☐ No ☐ N/A Citation: U. Does your CAO establish a monitoring and adaptive management program designed to: • collect information on CAO effectiveness, • evaluate the potential for exemptions and variances to cumulatively affect riparian functions across your jurisdiction, and • improve permit implementation? Section 3.2, Chapter 5; CA Handbook, Ch. 7 ☐ Yes ☐ No ☐ N/A Citation: 51 of 83 Page 1 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 Critical Areas Checklist A Technical Assistance Tool from Growth Management Services – updated May 2024 Name of city or county: City of Yakima, WA Staff contact, phone, and e-mail address: Trevor Martin, 509-575-6183, Ask.Planning@YakimaWA.gov INSTRUCTIONS This checklist is intended to help local governments update their development regulations, pursuant to the schedule in RCW 36.70A.130(5). We strongly encourage but do not require jurisdictions to complete the checklist and return it to Growth Management Services (GMS), along with their updates. However, If the jurisdiction is using a portion of their Periodic Update Grant (PUG) to update the Critical Areas Ordinance, this checklist is required. This checklist may be used by all jurisdictions, including those local governments planning for resource lands and critical areas only. For general information on update requirements, refer to A Guide to the Periodic Update Process Under the Growth Management Act – Fully Planning Counties & Cities, 2022 and WAC 365-196-610 . For additional information, resources, and general checklists pertaining to comprehensive plan and development regulation periodic updates please visit Commerce’s Growth Management Act Periodic Update webpage. Bold items are a GMA requirement or may be related requirements of other state or federal laws. Underlined items are links to Internet sites and may include best practices or other ideas to consider. Commerce WAC provisions are advisory under Commerce’s statutory mandate to provide technical assistance, RCW 43.330.120 which states that the Department of Commerce “…shall help local officials interpret and implement the different requirements of the act through workshops, model ordinances, and information materials.” If you have questions, call GMS at (360) 725-3066. How to fill out the checklist Using the current version of your critical areas regulations, fill out each item in the checklist. Select the check box or type in text fields, answering the following question: Is this item addressed in your current Critical Areas Ordinance (CAO)? If YES, fill in the form with citation(s) to where in the plan or code the item is addressed. We recommend using citations rather than page numbers because they stay the same regardless of how the document is printed. If you have questions about the requirement, follow the hyperlinks to the relevant statutory provision or rules. If you still have questions, visit the Commerce Growth Management Services Web page or contact one of the Commerce planners assigned to your region. CONTENTS Instructions………..………….….1 Overall Requirements………..2 Wetlands…………………………….3 Critical Aquifer Recharge Areas…………………………….……5 Frequently Flooded Areas….6 Geologically Hazardous Areas…………………………………. 7 Fish and Wildlife Habitat Conservation Areas….………..8 Designating and Protecting Waters of the State……..….....9 Anadromous Fisheries………………………….....10 Reasonable Use Exceptions…………………….…….10 Agricultural Activities…….…..11 Forest Practices Regulations……………………....11 Good Ideas…….……..……….….12 LOCAL GOVERNMENT DIVISION 52 of 83 Page 2 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 CRITICAL AREAS Regulations protecting critical areas are required by RCW 36.70A.060(2) and RCW 36.70A.172(1). WAC 365-195-900 through 925 provide guidelines. Guidance can also be found in Commerce’s Critical Areas Handbook (2022); the Minimum Guidelines WAC 365-190-080 through 130; Best Available Science WAC 365-195; and Procedural Criteria, WAC 365-196-485 and WAC 365-196-830, and on Growth Management’s Critical Areas webpage. Regulations required to protect critical areas Addressed in current plan or regulations? If yes, note where OVERALL REQUIREMENTS The CAO includes best available science to clearly designate and protect all critical areas that might be found within the jurisdiction. 1. Designation of Critical Areas RCW 36.70A.170(1)(d) requires all counties and cities to designate critical areas. RCW 36.70A.170(2) requires that counties and cities consider the Commerce Minimum Guidelines pursuant to RCW 36.70A.050. RCW 36.70A.050 directs Commerce to adopt the Minimum Guidelines to classify critical areas. WAC 365-190-080 through 130 provide guidance on defining or “designating” each of the five critical areas. WAC 365-190-040 outlines the process to classify and designate natural resource lands and critical areas. 2. Definition of Critical Areas RCW 36.70A.030(11) provides definitions for critical areas. Sections (20) regarding geologically hazardous areas; and (48) regarding wetlands were updated in 2010. WAC 365-190-030 provides definitions in the Minimum Guidelines. 3. Protection of Critical Areas RCW 36.70A.060(2) requires counties and cities to adopt development regulations that protect the critical areas required to be designated under RCW 36.70A.170. RCW 36.70A.172(1) requires the inclusion of best available science in developing policies and development regulations to protect the functions and values of critical areas. In addition, counties and cities must give special consideration to conservation or protection measures necessary to preserve or enhance anadromous fisheries. WAC 365-196-830 provides guidance on protection of critical areas. Was BAS documented in the record for the review and updates to the critical areas regulations? ☒ Yes ☐ No Location in Text: 1. Designation YMC Chapter 15.27 Part One & YMC Chapter 17.09 (SMP) 2. Definitions YMC 15.27.200, YMC 15.27.700, & YMC 17.01.090 (SMP) 3. Protection YMC Chapter 15.27 Article IV-Permit Review Critieria, YMC 15.27.321, YMC 15.27.407-15.27.408, YMC 15.27.501, YMC 15.27.602, YMC 15.27.702, YMC 15.27.820, & YMC Chapter 17.09 4. Best Available Science YMC 15.27.150, YMC 15.27.314(B), YMC 15.27.500(A), YMC 15.27.501(2), YMC 15.27.604(A), YMC 15.27.605(I)(7), YMC 17.01.090 (SMP), 53 of 83 Page 3 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 4. Inclusion of Best Available Science RCW 36.70A.172(1) requires inclusion of the best available science (BAS). WAC 365-195-900 through 925 outlines recommended criteria for determining which information is the BAS, for obtaining the BAS, for including BAS in policies and regulations, for addressing inadequate scientific information, and for demonstrating “special consideration” to conservation or protection measures necessary to preserve or enhance anadromous fisheries. WAC 365-195-915 provides criteria for including BAS in the record. 5. No net loss of critical area functions and values is a requirement for development regulations in WAC 365-196-830(4). If development regulations allow harm to critical areas, they must require compensatory mitigation of the harm. YMC 17.03.090 (SMP), YMC 17.05.020 (SMP), YMC 17.07.120 (SMP), YMC 17.09.010(P), (I)(4) (SMP), & YMC 17.09.030-17.09.040 Note: The code sections of the SMP (Title 17) referenced above utilized the terms “scientific evidence” or “scientific and technical information” instead of “best available science”. Do your regulations address no net loss and require compensatory mitigation? ☒ Yes ☐ No Location in Text: YMC 15.27.130, YMC 15.27.314-15.27.321, YMC 15.27.605, YMC 17.01.030(H) (SMP), YMC 17.01.040(K) (SMP), YMC 17.03.030- 17.03.060 (SMP), YMC 17.05.020-17.05.060 (SMP), YMC 17.07.050 (SMP), YMC 17.07.070 (SMP), YMC 17.07.090 (SMP), YMC 17.07.130 (SMP), YMC 17.07.160- 17.07.170 (SMP), YMC 54 of 83 Page 4 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 17.09.010(B)(1) and (Q) (SMP), YMC 17.09.050(C) (SMP), YMC 17.13.160 (SMP) WETLANDS DEFINITION The definition of wetlands is consistent with RCW 36.70A.030(48). Is the wetland definition consistent with RCW 36.70A.030(48)? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.200 Definitions, & YMC 17.01.090 Definitions (SMP) WETLANDS DELINEATION Wetlands are delineated using the approved federal wetland delineation manual and applicable regional supplements in accordance with WAC 173-22-035. See Ecology’s Wetland Delineation page and WAC 365-190-090 for additional assistance. Are wetlands delineated using the approved Federal Wetland Delineation Manual and Regional Supplements? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.601, & YMC 17.09.040(B)(1) (SMP) 55 of 83 Page 5 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 WETLANDS PROTECTION Policies and regulations protect the functions and values of wetlands. RCW 36.70A.172(1). Counties and cities are encouraged to make their actions consistent with the intent and goals of “protection of wetlands”, Executive Order 89-10 as it existed on September 1, 1990. WAC 365-190-090(3) recommends using a wetlands rating system that evaluates the existing wetland functions and values to determine what functions must be protected. Ecology updated its recommended wetlands rating systems effective January 2015. For information on the rating system, including the July 2018 adjustments to ranges for habitat scores, see: • 2014 Updates to the Washington State Wetland Rating Systems • Washington State Wetland Rating System for Western Washington • Washington State Wetland Rating System for Eastern Washington For other resources and guidance on protecting wetlands, go to Ecology’s Local Wetland Regulations: Growth Management Act technical assistance and see: • Wetland Guidance for Critical Areas Ordinance (CAO) Updates: Western and Eastern Washington (2022) Do the regulations use a rating system to determine wetlands protection? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.603, & YMC 17.09.040(D)(2) (SMP) CRITICAL AQUIFER RECHARGE AREAS Policies and regulations protect the functions and values of critical aquifer recharge areas. RCW 36.70A.172(1). Policies and regulations protect the quality and quantity of groundwater used for public water supplies. RCW 36.70A.070(1) and WAC 365-196-485(1)(d). The following references also relate to protection of groundwater resources: • RCW 90.44 – Regulation of Public Groundwaters • RCW 90.48 – Water Pollution Control • RCW 90.54 – Water Resources Act of 1971 • RCW 36.36.020 - Creation of aquifer protection area (1985) • WAC 365-190-100 Critical Aquifer Recharge Areas 2023 • WAC 173-100 Groundwater Management Areas and Programs (1988) • WAC 173-200 Water Quality Standards for Groundwaters of the State of Washington (1990) • WAC 365-196-735 Consideration of state and regional planning provisions (list) (2010) The Critical Aquifer Recharge Areas Guidance Document (2021) provides information on protecting functions and values of critical aquifer recharge areas, best available science, how to work with state and local regulations and adaptive management. Also, consider the following: If groundwater is used for potable water, do regulations protect the quality and quantity of ground water? ☒ Yes ☐ No ☐ N/A Location in text: YMC 15.27.800 & YMC 17.09.060 (SMP) 56 of 83 Page 6 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 CRITICAL AQUIFER RECHARGE AREAS • Prohibiting or strictly regulating hazardous uses in critical aquifer recharge areas (CARAs) and designating and protecting wellhead areas. See Ecology’s guidance on Critical Aquifer Recharge Areas. • Limiting impervious surfaces to reduce stormwater runoff, as required under Phase I and II municipal stormwater permits. Ecology’s Stormwater Manual for Western Washington (2012) includes low impact development (LID) related definitions, requirements, and an LID performance standard. See Stormwater Management and Design Manuals on Ecology’s web page. • For additional guidance on LID resources, see Commerce’s Incentivizing low- impact development guidebook. Are the critical aquifer recharge regulations consistent with current mapping of these critical areas? ☒ Yes ☐ No ☐ N/A Location in text: YMC 15.27.800- 15.27.820 & YMC 17.09.060(B) (SMP) FREQUENTLY FLOODED AREAS Regulations protect the functions and values of frequently flooded areas and safeguard the public from hazards to health and safety. RCW 36.70A.172(1). WAC 365-196-830 provides: "’Protection‘ in this context means preservation of the functions and values of the natural environment, or to safeguard the public from hazards to health and safety.” WAC 365-190-110 directs counties and cities to consider the following when designating and classifying frequently flooded areas: (a) Effects of flooding on human health and safety, and to public facilities and services; (b) Available documentation including federal, state, and local laws, regulations, and programs, local studies and maps, and federal flood insurance programs, including the provisions for urban growth areas in RCW 36.70A.110; (c) The future flow flood plain, defined as the channel of the stream and that portion of the adjoining flood plain that is necessary to contain and discharge the base flood flow at build out; (d) The potential effects of tsunami, high tides with strong winds, sea level rise, and extreme weather events, including those potentially resulting from global climate change; (e) Greater surface runoff caused by increasing impervious surfaces. Classification of and regulations for frequently flooded areas should not conflict with the FEMA requirements for the National Flood Insurance Program (NFIP). See Ecology’s Frequently Flooded areas: Critical Areas Ordinance webpage and 44 CFR 60. Communities that are located on Puget Sound or the Strait of Juan de Fuca, or have lakes, rivers or streams that directly or indirectly drain to those water bodies, are subject to the NFIP Biological Opinion (BiOp) for Puget Sound. The biological opinion required changes to the implementation of the NFIP in order to meet the Are frequently flooded areas designated and regulated using FEMA and Ecology guidance? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27 Part Four – Flood Hazard Areas; The City updated YMC 15.27 Part Four in 2021 (Ord. 2021-021), amending and adding sections related to the identification and establishment of flood hazard areas (YMC 15.27.400), Methods of Reducing Flood Losses (YMC 15.27.403), and amending sections related to Penalties, Liabilities, Variances, New Construction, General Standards for Construction 57 of 83 Page 7 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 FREQUENTLY FLOODED AREAS requirements of the Endangered Species Act (ESA) in the Puget Sound watershed. FEMA Region X has developed an implementation plan that allows communities to apply the performance standards contained in the Biological Opinion by implementing: 1) a model ordinance; 2) a programmatic Checklist; or 3) on a permit by permit basis as long as it can be demonstrated that there is no adverse effect to listed species. Communities have the option of utilizing their CAOs as part of a programmatic response to address the requirements of the biological opinion. FEMA must approve a community’s biological opinion compliance strategy. Additional resources: RCW 86.12 Flood Control by Counties RCW 86.16 Floodplain Management RCW 86.26 State Participation in Flood Control Maintenance RCW 86.16.041 Floodplain Management Ordinance and Amendments WAC 173-158-070 Requirements for construction in Special Flood Hazard Areas Techniques, Floodproofing Certificates, Storage of Materials, Critical Facilities, Livestock Sanctuary Areas, and Specific Standards for Residential and Nonresidential Construction, Manufactured Homes, Enclosed Areas, areas with or without established base flood elevations / floodways, Shallow Flooding Areas, Structure Drainage, Recreational Vehicles, and Permit Application / Review Process. YMC 17.03.010 & 17.05.060 through the establishment of the Floodway/Channel Migration Zone (CMZ) within shoreline environmentally designated areas, also supports the protection of overflow channels and preservation of natural hydraulic, geologic, and biological functions. 58 of 83 Page 8 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 FREQUENTLY FLOODED AREAS Are you utilizing your CAO as part of a programmatic response to the BiOp? ☐ Yes ☐ No ☒ N/A Location in Text: Not Applicable; Only applies to communities with watersheds directly or indirectly draining into the Puget Sound or the Strait of Juann Fuca. DEFINITION OF GEOLOGICALLY HAZARDOUS AREAS The definition of geologically hazardous areas is consistent with RCW 36.70A.030(20) and WAC 365-190-120(1). “Geologically hazardous areas" means areas that because of their susceptibility to erosion, sliding, earthquake, or other geological events, are not suited to the siting of commercial, residential, or industrial development consistent with public health or safety concerns. Is the geologically hazardous areas definition consistent with RCW 36.70A.030(20)? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.700(A); The definition is uniquely listed within YMC 15.27 Part Seven and not within the preliminary Definitions section (YMC 15.27.200). The critical area is also defined in YMC 17.09.050(A)(1) (SMP). 59 of 83 Page 9 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 PROTECTION OF GEOLOGICALLY HAZARDOUS AREAS Regulations protect the functions and values of geologically hazardous areas and safeguard the public from hazards to health and safety. RCW 36.70A.172(1). WAC 365-196-830 provides: “’Protection’" in this context means preservation of the functions and values of the natural environment, or to safeguard the public from hazards to health and safety.” Geologically hazardous areas are designated, and their use is regulated or limited consistent with public health and safety concerns. RCW 36.70A.030(20) WAC 365-190-120 describes the different types of hazardous areas: • Geologically hazardous areas include: • Erosion hazards • Landslide hazards • seismic hazards • tsunami hazards • volcanic hazards • channel migration zones • areas subject to other geological events such as coal mine hazards including: mass wasting, debris flows, rock falls, and differential settlement. The Department of Natural Resource’s Washington Geological Survey Geologic Hazards and the Environment website includes information on earthquakes and faults, landslides, volcanoes and lahars, tsunamis, hazardous minerals, emergency preparedness, historic mines and includes geologic hazard maps that can be accessed from the Geologic Information Portal. Are uses in geologically hazardous areas designated and regulated or limited consistent with public health and safety? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27 Part Seven & YMC 17.09.050 (SMP) DEFINITION OF FISH AND WILDLIFE HABITAT AND CONSERVATION AREAS The definition of fish and wildlife habitat conservation areas is consistent with WAC 365-190-030(6). The definition of fish and wildlife habitat conservation areas was amended to state that they do not include: “such artificial features or constructs as irrigation delivery systems, irrigation infrastructure, irrigation canals, or drainage ditches that lie within the boundaries of and are maintained by a port district or an irrigation district or company”. Is the FWHCA definition consistent with WAC 365-190- 030(6)? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.200 & YMC 17.01.090 (SMP) 60 of 83 Page 10 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 PROTECTION OF FISH AND WILDLIFE HABITAT AND CONSERVATION AREAS Policies and regulations protect the functions and values of fish and wildlife habitat conservation areas. RCW 36.70A.172(1) and WAC 365-190-030(6). WAC 365-190-130(4) says local jurisdictions must consult current information on priority habitats and species identified by WDFW. Additional information that must be consulted is available from DNR’s natural heritage program and aquatic resources program. BAS regarding biodiversity areas and corridors has advanced significantly. Recent updates and resources include: • Aquatic Habitat Guidelines • Priority Habitat and Species maps • Priority Habitats and Species List (updated June 2023) • Priority Habitats and Species: Management recommendations: • Landscape Planning for Washington’s Wildlife (2009) • Land Use Planning for Salmon, Steelhead and Trout (2009) • Riparian Ecosystems, Volume 1: Science Synthesis and Management Implications (2020) • Riparian Ecosystems, Volume 2: Management Recommendations (2020) • Riparian Management Zone Checklist for CAOs (2023) • Shrub-Steppe Management Recommendations (2020) • Oregon White Oak Woodlands Ecosystems Management Recommendations (1998) • Management recommendations for Washington's Priority Species (by taxa) • Puget Sound Kelp Conservation and Recovery Plan (2020) • Stream Habitat Restoration Guidelines (2012) • Water Crossing Design Guidelines (2013) “Areas where endangered, threatened, and sensitive species have a primary association” must be considered per WAC 365-190-130(2)(a). Consult WDFW’s Threatened and Endangered Species list and U.S. Fish and Wildlife Service’s Information for Planning and Consultation resources for up to date information on all state and federal listed species. Also see the Puget Sound Partnership’s Salmon Recovery website for Water Resource Inventory Area (WRIA) Plans in Puget Sound. Have you reviewed your regulations regarding any applicable changes in management recommendations for priority habitats and species? ☒ Yes ☐ No ☐ N/A Location in Text YMC 15.27 Part Five, YMC 17.09.010(D)(3) and (Q) (SMP); Have you reviewed your regulations regarding any changes in species listings? ☒ Yes ☐ No ☐ N/A Location in Text YMC 15.27.502-507 & YMC 17.09.030(C) and (D) (SMP) 61 of 83 Page 11 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 DESIGNATING AND PROTECTING WATERS OF THE STATE RCW 90.48.020 defines waters of the state, which include all surface waters, salt waters, groundwater and all other water courses in Washington. WAC 365-190- 130(2)(f) recommends designating all waters of the state as fish and wildlife habitat conservation areas (FWHCAs). Stream types are classified in WAC 222-16-030 with field verification, or an alternate system that considers factors listed in WAC 365-190-130(4)(f)(iii). See http://www.dnr.wa.gov/forest-practices-water-typing to use Washington State Department of Natural Resources (DNR)’s stream typing system. Establish riparian management zones to maintain no net loss of riparian ecosystem functions and values. Designate areas that risk contaminating or harming shoreline resources including tidelands and bedland suitable for shellfish harvest, kelp and eelgrass beds and forage fish spawning areas. Do you designate waters of the state as FWHCAs? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.502(A)(4) & YMC 17.09.030(C)(4) (SMP) Do your regulations protect waters of the state? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27 Part Five & YMC 17.09.030(H) through (P) 62 of 83 Page 12 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 ANADROMOUS FISHERIES Policies and regulations for protecting critical areas give special consideration to conservation or protection measures necessary to preserve or enhance anadromous fisheries. RCW 36.70A.172(1) is the requirement and WAC 365-195- 925 lists criteria involved. This requirement applies to all five types of critical areas. WAC 365-190-130(4)(i) recommends sources and methods for protecting fish and wildlife habitat conservation areas, including salmonid habitat. Counties and cities may use information prepared by the United States Department of the Interior Fish and Wildlife Service, National Marine Fisheries Service, the Washington State Department of Fish and Wildlife, the State Recreation and Conservation Office, and the Puget Sound Partnership to designate, protect and restore salmonid habitat. Counties and cities should consider recommendations found in the regional and watershed specific salmon recovery plans (see the Governor's Salmon Recovery Office webpage and the Puget Sound Partnership’s Salmon Recovery webpage). Land Use Planning for Salmon, Steelhead and Trout: A land use planner’s guide to salmonid habitat protection and recovery (October 2009) is an excellent resource. Do your regulations give special consideration to anadromous fisheries? ☒ Yes ☐ No ☐ N/A Location in Text: YMC 15.27.150 & YMC 17.09.030 REASONABLE USE EXCEPTIONS The Critical Areas Ordinance (CAO) allows for “reasonable use” if the CAO would otherwise deny all reasonable use of property. Reasonable use provisions should limit intrusions into critical areas to the greatest extent possible and apply the mitigation sequence as needed for no net loss of ecosystem functions and values RCW 36.70A.370. Common exemptions include emergencies, remodels that do not further extend into critical areas, surveying, walking, and development that has already been completed with critical areas review under a previous permit. See Critical Areas Handbook, Chapter 3: Structuring Critical Areas Regulations, p.10 (Updated 2022). Do you have reasonable use provisions? ☒ Yes ☐ No Location in Text: YMC 15.27.318; SMP “Variance Provisions” are provided in YMC 17.13.080 63 of 83 Page 13 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 AGRICULTURAL ACTIVITIES (COUNTIES ONLY) Non-VSP Counties Critical areas regulations as they specifically apply to agricultural activities in counties or watersheds not participating in the Voluntary Stewardship Program (VSP) have been reviewed, and if needed, revised pursuant to RCW 36.70A.130. RCW 36.70A.710(6) "Agricultural activities" means all agricultural uses and practices as defined in RCW 90.58.065. VSP Counties After watershed work plan approval, VSP counties are encouraged to reference and describe their participation in the program within their critical areas development regulations (WAC 365-196-832). See Critical Areas Handbook, Chapter 5: Protecting Critical Areas in Natural Resource Lands (2022). Did you review your regulations as they apply to agricultural activities? ☐ Yes ☐ No ☒ N/A Location in Text: Not Applicable to the City of Yakima (Counties Only) FOREST PRACTICES APPLICATION REGULATIONS If applicable, regulations for forest practices have been adopted: RCW 36.70A.570. RCW 76.09.240, requires many counties over 100,000 in population, and the cities and towns within those counties to adopt regulations for forest practices. These are often included in clearing and grading ordinances. Have you adopted forest practices regulations? ☐ Yes ☒ No ☐ N/A Location in Text: Related provisions related to Forest Practices are included in: YMC 7.82.010 Definitions. (Stormwater) – New Development, YMC 7.82.090.4 Exemptions. (Construction Stormwater Runoff), YMC 7.83.020 Definitions. (Stormwater) – New Development, YMC 7.83.040.1.a Exemptions. (Post-Construction Stormwater Runoff), YMC 64 of 83 Page 14 – Updated through laws of 2023 Note: Bold items and checkboxes are a requirement of the GMA. Other items are other state or federal laws or examples of best practices. Underlined items are links to Internet sites. V3.0 17.01.090 Definitions. (SMP) – Forest land, & YMC 17.01.090 Definitions. (SMP) – Forest practices GOOD IDEAS Non-regulatory measures to protect or enhance functions and values of critical areas may be used to complement regulatory methods. These may include: • public education • stewardship programs • pursuing grant opportunities • water conservation • joint planning with other jurisdictions and non-profit organizations • stream and wetland restoration activities • transfer of development rights Monitoring and adaptive management is encouraged in WAC 365-195-905(6) to improve implementation of your regulations. See Commerce’s Monitoring and Adaptive Management chapter in the Critical Areas Handbook, Chapter 7: Monitoring and Adaptive Management of Critical Areas (2022). Are you using non- regulatory measures to protect critical areas? ☒ Yes ☐ No Location in Text: Joint Planning with Yakima County, WA Dept. of Ecology, WA Dept. of Fish & Wildlife, & Yakama Nation. Do you have a monitoring and adaptive management program for your CAO? ☐ Yes ☒ No Location in Text: Monitoring provisions are located throughout YMC 15.27, but adaptive management mechanism is not present. 65 of 83 MEMORANDUM 2707 Colby Avenue, Suite 900, Everett, WA 98201  P 425.252.7700 To: Trevor Martin, Planning Manager, City of Yakima, WA From: Jennifer Groos, Environmental Planner III, Perteet, Inc. Andrea Bachman, Senior Environmental Scientist, Perteet, Inc. Oneza Ferdouse, Associate Principal, BERK Consulting Date: December 22, 2025 Re: Yakima Critical Areas Ordinance (CAO) Periodic Update Recommended Datasets are Underlined. Figure 1 - Yakima 2040 Comp Plan Exhibit 10-6 • City of Yakima o The existing city dataset contains three classifications (Figure 2):  High Risk – Landslide, Intermediate Risk – Oversteepened Slopes, and High Risk – Oversteepened Slopes o Supplemental Data Review: In addition to the City of Yakima–sourced Geologically Hazardous Areas and Underlying Geology datasets, publicly available Washington State Department of Natural Resources (WA DNR) landslide inventory and landslide susceptibility mapping were reviewed for context (WA DNR Geology Portal). The WA DNR mapping generally aligns with the City’s mapped high-risk landslide and oversteepened slope areas and does not indicate materially different hazard extents within the City limits. Consistent with Comp Plan mapping practices, the City-adopted datasets remain the primary reference for regulatory and policy purposes. 66 of 83 o Questions:  When might an update to the GeoHaz dataset be performed related to Surfacewater Department’s remote sensing efforts? Before June 2026? If not, we can use the existing (Figure 2).  Would the City’s GIS Department be willing to deduce a new dataset formatted according to the recommended Known/Suspect-No Known-Unknown classifications? A dataset and matching graphic reflecting these classifications are not required, but may be a future consideration for Comm. Dev. and GIS Departments if/when code amendments are adopted.  Has there been an Administrative presendence established internally in which specific soil types require Critical Area Report based on that soil types geologically functions and values? Alternatively, is the Underlying Geology dataset used in manner to evaluate area with potential hazards based on soil type? Figure 2 - Yakima Existing Dataset - Geologically Hazardous Areas Figure 3 - Yakima Existing Dataset – Underlying Geology Due to recommendations made in the CAO Gap Analysis for the reclassification of Geologically Hazardous Areas utilizing Known/Suspect, No Known, and Unknown classifications, consideration should be given to the 67 of 83 following datasets. The following are suggestions for managing public-facing map graphics and stored city- datasets: a. A publicly shared dataset utilizing the Known/Suspect-No Known-Unknown classification format is a great thematic map for residents to evaluate whether or not their property could require critical areas review process related to development activity. b. To support the creation of the above Known/Suspect-No Known-Unknown formatted map the following datasets could be used to derive area classifications. 1. Remote-sensing (created by PW-Surfacewater Dept.?) – identifies areas with steep slopes. 2. USDA National Resource Conservation Service (NRCS) Soil Types – underlying geology with soil type identified as known/suspect to contribute to landslides. 3. WA Dept. of Natural Resources (DNR) Liquefication Susceptibility (Figure 4, below) 4. WA DNR Seismic Site Class (Figure 5, below) c. If (a) and (b) are not likely to be assessed or considered at this time, it would be beneficial to show (1), (3), and (4) datasets listed in (b) above as well as the existing City-sourced Underlying Geology. • WA DNR o Figure 4 - Liquefaction Susceptibility o Figure 5 - NEHRP Seismic Site Classification 68 of 83 • USDA NRCS o Figure 6 – Soil Typing Figure 7 - Yakima 2040 Comp Plan Exhibit 10-2 • City of Yakima o The existing city dataset contains three classifications (Figure 2). The same classifications will be referenced in the Comp Plan.  Zone AE, Zone A, and Floodway Areas o Question:  When comparing recent FEMA datasets with the map graphic currently in the Comp Plan, an small area near Fruitvale Blvd is no longer identified as Zone AE Floodplain. Does this correctly align with any recent floodplain management projects in that area? 69 of 83 • Figure 7a – Highlighted Fruitvale Blvd Area with existing City-dataset: • Figure 7b – Highlighted Fruitvale Blvd Area with current FEMA dataset: Figure 8 – FEMA Floodplains & Floodways 70 of 83 Critical Aquifer Recharge Areas : Figure 9 - Yakima 2040 Comp Plan Exhibit 10-7 • City of Yakima o The existing city dataset contains three classifications (Figure 2). The same classifications will be represented in the Comp Plan.  Wellhead 10-Year Protection Area, Moderate, High, and Extreme o Data Source Clarification: City-sourced Critical Aquifer Recharge Areas (CARA) and Aquifer High Vulnerability Areas were used for Comp Plan mapping. County-level CARA mapping was also reviewed for comparison purposes and is generally consistent with the City’s compiled datasets. For clarity, the City-sourced CARA and Aquifer High Vulnerability datasets are retained as the primary mapping layers, with the Washington Department of Health Wellhead Protection Area (10-year travel time) dataset updated to reflect the most current available information. o Questions:  None Figure 10 – Critical Aquifer Recharge Areas In Figure 10, above, the same existing city-sourced datasets for Aquifer High Vulnerability Areas, and Critical Aquifer Recharge Areas are utilized, and the latest Washington Department of Health dataset for Wellhead Protections Areas with a 10yr Travel Time has been updated (shown in green dot-dash lines). 71 of 83 Wetlands & Streams: Figure 11 - Yakima 2040 Comp Plan Exhibit 10-7 • City of Yakima o The existing city dataset contains three classifications (Figure 2),  Freshwater Emergent Wetland, Freshwater Forested/Shrub Wetland, Freshwater Pond, Lake, Riverine, and Streams o Question:  WADNR dataset notes Lateral L to be a ‘canal/ditch’. It is suggested that this segment be removed from the existing city dataset for ‘Creeks & Streams’. Would you concur and find this revision acceptable for reference in the Comp Plan? • Figure 11a – Highlighted Lateral L Area per City • Figure 11b – Highlighted Lateral L Area per WADNR 72 of 83 Figure 12 – NWI Wetlands Figure 13 – Streams 73 of 83 Fish & Wildlife Habitat Conservation Areas : Figure 14 - Yakima 2040 Comp Plan Exhibit 10-4 • City of Yakima o The existing city dataset contains three classifications (Figure 2). Updated classifications according to WDFW will be included in the Comp Plan.  Bald Eagle, Riparian Zones, Shrub-Steppe, Waterfowl Concentrations, and Wood Duck o Questions:  None Figure 15 – WDFW Priority Habitat Species 74 of 83 Building Permits Issued - Previous Month Permit Number Date Issued Primary Parcel Number Site Address Permit Type Project Description Applicant Total Valuations B251061 01/02/2026 18132543418 906 W VIOLA AVE BLD-RES-ADD covered attached patio on existing concrete slab ALFREDO & PETRA VEGA $7,704.00 B251251 01/02/2026 18132924427 912 S 75TH AVE BLD-RES-SOLAR 10.660kw PV roof mount- solar Freedom Forever WA LLC - Leann Malloy $22,000.00 B251261 01/02/2026 19133013442 1216 S 6TH ST #B BLD-RES-DEMO Demolish the little house behind the main house on the same property to make room for a new restaurant in the future AR 509 CONSTRUCTION LLC $3,000.00 B251269 01/02/2026 18132224429 4302 AVALANCHE AVE BLD-RES-SOLAR 11.070 kw pv solar roof mount, solar and service Freedom Forever WA LLC - Leann Malloy $25,000.00 B251283 01/02/2026 19131843537 202 N 8TH ST BLD-RES-SOLAR 6.560kw PV roof mount -solar and service Freedom Forever WA LLC - Leann Malloy $17,000.00 B251147 01/05/2026 18131432003 3005 CASTLEVALE RD, # 9B BLD-MFH-IN A COURT placement of a new manufactured home, 2026 MARLETE/CLAYTON HOMES, MODEL TEMPO, 24X56 CASTLEVALE COURT LLC $100,000.00 B251148 01/05/2026 18131432003 3005 CASTLEVALE RD, #10 BLD-MFH-IN A COURT placement of a new manufactured home, 2026 MARLETE/CLAYTON HOMES, MODEL TEMPO, 24X56 CASTLEVALE COURT LLC $100,000.00 B241076 01/07/2026 19131942480 414 S 6TH ST BLD-RES-ADU Convert garage into ADU M & B CONSTRUCTION - MARCELINO BADILLO $99,402.00 B251289 01/07/2026 18132421539 1204 CHERRY AVE BLD-RES-MISC-ALT interior remodel, relocate kitchen, create two bedrooms, remove storage area to create a hallway, bathroom cosmetic remodel and install exhaust fans. MUIRA MORALES, SAUL FERNANDO $8,000.00 B260002 01/07/2026 18132013402 206 N 70TH AVE BLD-RES-SOLAR 12.04 PV SOLAR ROOF MOUNT Freedom Forever WA LLC - Leann Malloy $24,500.00 B260012 01/07/2026 18131332448 918 N 15TH AVE BLD-RES-ROOF Complete tear off and re-roof SUPERIOR ROOFING LLC $9,000.00 B251170 01/08/2026 18132012435 415 SNOW MASS LN BLD-RES-GARAGE Building a residential detached shop 40x30 10' ft tall, no plumbing Dobens & Scott Const LLC $77,820.00 B260016 01/09/2026 19131832491 605 N 3RD ST BLD-RES-ROOF-P Repair and upgrade roofing as needed.MARK ROVETTO $3,298.00 B250351 01/12/2026 18133531001 2300 W WASHINGTON AVE BLD-COM-REN REMODEL OF NORTHEASTERLY PORTION OF AIR TERMINAL: RECONFIGURE BAGGAGE HANDLING AREA, MINOR EXTERIOR WALL ALTERATIONS TO ACCOMMODATE NEW BAGGAGE HANDLING EQUIPMENT. DEMOLISH (3) THREE INTERIOR OFFICES AND JANITOR AREA. REMODEL EXISTING MEN'S AND WOMEN'S RESTROOMS. CREATING A SINGLE-USER, FAMILY RESTROOM. CREATING A FAMILY LOBBY. ADDING A DOUBLE DOOR EXIT TO THE EAST WALL AS AN ALTERNATE METHOD TO MITIGATE THE OCCUPANT LOAD FOR THIS AREA. MWA ARCHITECTS-VON BARGEN ROOT, JEAN $2,289,518.00 B260021 01/12/2026 18132314520 1612 MONROE AVE BLD-RES-ROOF-P roof replacement A W ROOFING OF YAKIMA LLC $8,900.00 B251246 01/13/2026 18132631488 2412 W NOB HILL BLVD #102 BLD-COM-TI Change of use tenant build out of a 1,650 sq ft ground floor suite in an existing tenant build. Formerly an AT&T store intended use is for an outpatient physical therapy. See attached document Blanco Construction LLC $170,000.00 75 of 83 Building Permits Issued - Previous Month Permit Number Date Issued Primary Parcel Number Site Address Permit Type Project Description Applicant Total Valuations B260017 01/13/2026 18132431519 11 N 11TH AVE # 101 BLD-COM-TI tennant improvement, from a dental lab to a professional office, removing dental sinks, creating office space, and adding one interior door, making existing exterior 24"door larger to 36", and sheet rock repairs where the plumbing and electrical work was previously done and ceiling was re- done CRITCHLOW, TYLER $1,500.00 B260025 01/13/2026 18132912005 620 S 70TH AVE BLD-RES-MISC-ALT Replace 7 2x6 rafters like for like. New sheeting and roofing replace bottom cords and sheetrock on the ceiling. Add interconnected smoke detectors and co2 all same for same due to tree fall/wind damage AJR LIONS CONSTRUCTION LLC- Juan Manuel Nava Gallo $22,000.00 B251156 01/13/2026 18131924470 9102 HAWTHORNE DR BLD-MSTR-SFR New single-family residence COLUMBIA RIDGE HOMES LLC - HELLEM, JUSTIN $389,103.96 B251009 01/13/2026 18131434494 707 N 28TH AVE #1-2 BLD-RES-DUP New 2176 duplex VICTOR J & PATRICIA PADILLA $364,710.72 B251264 01/15/2026 18133421905 4000 CREEKSIDE LOOP BLD-COM-REN existing half walls to be framed to full height on the second floor of the building JACOB LIDDICOAT $100,000.00 B251279 01/15/2026 18132043445 203 S 68TH AVE BLD-RES-MISC-ALT INTERIOR REMODEL, CURRENT LAUNDRY ROOM WILL BE A LARGER BATHROOM, AND THE LAUNDRY ROOM IS BEING RELOCATED TO THE BASEMENT, NEW FULL BATHROOM IN BASEMENT AS WELL. GALBREATH, JACOB $600.00 B260008 01/15/2026 18132324024 2701 SUMMITVIEW AVE BLD-RES-MISC-ALT Install trusses on a garage (existing structure) that was damaged by a tree falling on the roof. Baxter Construction - Crause, Ryan $15,000.00 B260019 01/15/2026 18131643453 5413 ENGLEWOOD AVE BLD-RES-SOLAR 7.2 KW ROOF MOUNTED SOLAR ARRAY ELLENSBURG SOLAR LLC - REGAN MORRIS $12,425.00 B260028 01/15/2026 18132631470 1215 S 26TH AVE BLD-RES-ROOF-P REMOVE AND REPLACE ROOFING COLUMBIA PLATEAU ROOFING $38,954.00 B260030 01/15/2026 18132321034 2604 POWERHOUSE RD BLD-RES-ROOF-P Replacing whole house roof with 11SQ of CertainTeed Landmark; excluding detached garage/shed.Adamson, Missy $16,740.00 B260035 01/16/2026 18132641457 1208 S 18TH AVE BLD-RES-ROOF replacement of sheathing and shingles on residential home AJR LIONS CONSTRUCTION LLC- Juan Manuel Nava Gallo $11,000.00 B260038 01/16/2026 19132943413 1903 SIMPSON LN BLD-RES-ROOF-P Re roof and fix plywood madrigal, gustavo $4,000.00 B260039 01/19/2026 19131832401 804 N 3RD ST BLD-RES-ROOF-P leticia roof Kendra Zazueta $16,516.67 B251267 01/20/2026 18132431416 111 S 11TH AVE STE 205 & 210 BLD-COM-TI This project will be a demolition of a suite in an existing building in anticipation of a future tenant improvement project (office to office) STEPHENS BEN $100,000.00 B260033 01/20/2026 19133023421 811 S 3RD AVE BLD-RES-DEMO Demo of shop only at this location GABBARD, RAY $2,000.00 B251006 01/20/2026 19131834400 509 N 4TH ST BLD-COM-TI Hope Market and Salvation Army food bank new location. Hope Market will provide food and daily necessities to all people. BORA ARCHITECTURE PLLC - SHEEBA JOHN $150,000.00 B260027 01/21/2026 18132641047 1902 W NOB HILL BLVD BLD-COM-REN Doing a residing on the front of the building (Sport store) JJ Rojas Carpentry $5,800.00 B260006 01/22/2026 18132521409 605 QUEEN AVE BLD-RES-MISC-ALT Fire damage repair. Replace drywall, insulation, interior finishes, doors. Repair damaged wall framing.ALFA CONSTRUCTION CORP $78,400.00 B251079 01/22/2026 18133413002 3202 W WASHINGTON AVE BLD-COM-NEW Proposal to build one aircraft hangar building in the AS zoning district. MCCORMICK AIRCRAFT HANGARS LLC $1,071,924.00 B251270 01/22/2026 18131924480 307 N 91ST AVE BLD-MSTR-SFR COLUMBIA RIDGE HOMES LLC $492,124.25 B250242 01/23/2026 19132032479 508 S 12TH ST #2 BLD-RES-ADU Converting the detached garage into an ADU RODOLFO RODRIGUEZ PEREZ $15,346.12 76 of 83 Building Permits Issued - Previous Month Permit Number Date Issued Primary Parcel Number Site Address Permit Type Project Description Applicant Total Valuations B251262 01/23/2026 18120423470 5704 W LARCH AVE BLD-RES-SFR NEW 1692 SQ FT HAYDEN HOMES LLC - GALINDO, JAVIER $314,893.89 B260050 01/23/2026 18132223402 4405 SUMMITVIEW AVE BLD-RES-ROOF Complete tear off and re-roof for the garage RICHARD E JR FOREST $4,000.00 B260054 01/25/2026 18132641468 1802 W PRASCH AVE BLD-RES-ROOF-P Complete re-roof (like for like)Hohmann, Tobias $10,000.00 B251107 01/26/2026 19131923461 114 E STAFF SGT PENDLETON WAY MOH BLD-COM-TI cosmetic interior renovation, tenant improvement, going from bakery to restaurant.FOSTER, RON E $56,000.00 B251285 01/27/2026 18132442504 510 W CHESTNUT AVE BLD-COM-REN REMODEL EXISTING RESTROOM INTO ADA UNISEX COMPLIANT. ADD AN ADJACENT ADDITIONAL UNISEX NON-ADA RESTROOM, APPLY AN ADDITIONAL LAYER OF 5/8'" DRYWALL TO APPROX 1200 SQ FT OF CEILING, apply r22 inslutaion and 5/8" drywall to west wall (550swq ft) LARRY DAY CONSTRUCTION $17,500.00 B260010 01/27/2026 18132511500 716 S 4TH AVE BLD-RES-SOLAR 8.20 kw PV roof Mount- Solar Freedom Forever WA LLC - Leann Malloy $16,500.00 B260011 01/27/2026 18132741479 3202 CAROL AVE BLD-RES-SOLAR 10.660kw PV Roof mount - Solar Revision: slight change on modules and layout of roof mount panels. 2/6/2026 Freedom Forever WA LLC - Leann Malloy $21,000.00 B260013 01/27/2026 18131934444 209 S 89TH AVE BLD-RES-SOLAR 6.15 km PV Roof Mount- Solar Freedom Forever WA LLC - Leann Malloy $12,500.00 B260023 01/27/2026 18132434404 309 S 10TH AVE BLD-RES-SOLAR 8.20 kw pv SOLAR ROOF MOUNT Freedom Forever WA LLC - Leann Malloy $16,500.00 B260024 01/27/2026 18132732465 4701 W PRASCH AVE BLD-RES-ADD re-build existing deck and add to it for a total of 480 sq ft Dobens & Scott Const LLC $15,408.00 B260046 01/27/2026 18133511438 1515 S 18TH AVE BLD-RES-SOLAR Install roof mount 8.36kw DC solar system ARIZONA SOLAR SOLUTIONS DBA SUNTRIA - ANTENETTE SPENCER $30,461.56 B260051 01/27/2026 18132121406 416 N 56TH AVE BLD-RES-SOLAR 9.840 kw pv solar roof mount Freedom Forever WA LLC - Leann Malloy $20,000.00 B260053 01/27/2026 18132533495 1317 S 14TH AVE BLD-RES-SOLAR install roof mount 11kw dc solar system, line side tap, temp powerkill required Revisions made 2/11/2026, Plans match install array layout, Equipment elevation has been updated. ARIZONA SOLAR SOLUTIONS DBA SUNTRIA - ANTENETTE SPENCER $50,259.46 B250584 01/28/2026 18132441443 108 S 3RD AVE BLD-COM-TI change of use, from a garage to a second daycare facility with a restroom LP ARCHITECTURE - KYLE LEPPER $5,000.00 B251224 01/28/2026 18131734459 7407 PLATEAU PLACE BLD-RES-GARAGE 1024 sq ft non-heated, unfinished RV storage garage, no plumbing HIMSL DOUGLAS $66,406.40 B260060 01/28/2026 18132323024 3001 SUMMITVIEW AVE BLD-RES-ROOF-P Reroof of the home Nava, Juan $8,900.00 B260058 01/28/2026 18131931425 8806 W BARGE ST BLD-RES-ROOF-P Reroof whole house with 2500 Squares of CertainTeed Patriot XL Adamson, Missy $32,000.00 B251168 01/29/2026 18132444427 515 S 5th Ave BLD-COM-REN INSTALLATION OF ROLL FORM STEEL PALLET RACKING UNDER PARTIALLY COVERED AREA. Multiple pallets of: Stakes, Tie wire, Expansion, Plastic rolls, J bolts, Plywood, MDO plywood, SST bolts, and miscellaneous NORTHWEST HANDLING SYSTEMS - MARTIN CARSTEN $22,000.00 77 of 83 Building Permits Issued - Previous Month Permit Number Date Issued Primary Parcel Number Site Address Permit Type Project Description Applicant Total Valuations B260015 01/29/2026 18132443517 402 S 9th Ave BLD-RES-ADU NEW 1000 SQ FT TWO-LEVEL ACCESSORY DWELLING UNIT ATTACHED TO AN 801 SQ FT SHOP GARAGE, WITH A 364 SQ FT STORAGE AREA ABOVE THE GARAGE, (319 SQ FT ADU ON THE FIRST FLOOR AND 681 SQ FT ADU ON THE SECOND FLOOR); STORAGE AREA IS PART OF THE GARAGE, NOT THE LIVING SPACE. RAKEL RIVERA & EFREN ZAMORA $242,920.25 B260037 01/29/2026 18132134014 5601 TIETON DR BLD-COM-DEMO remove brick building in preparation for building a new commercial building. new building design has not been determined yet. sewer services will be re used TIETON PLAZA LLC- DJ HENN $20,000.00 B260059 01/29/2026 18132734437 1402 S 42ND AVE BLD-RES-SOLAR INSTALL ROOF MOUNT 14.96KW DC SOLAR SYSTEM, LINE SIDE TAP, TEMPORARY POWERKILL REQUIRED ARIZONA SOLAR SOLUTIONS DBA SUNTRIA - ANTENETTE SPENCER $52,270.45 B251263 01/30/2026 18120423450 5701 WOOLSEY RD BLD-RES-SFR New construction build 1408 sqft SFR HAYDEN HOMES LLC - GALINDO, JAVIER $280,999.31 B251291 01/30/2026 18120413441 4809 W LARCH AVE BLD-RES-SFR New Construction build 2046 sq ft HAYDEN HOMES LLC - STOKES, KRIS $397,002.42 B251293 01/30/2026 18120413439 4805 W LARCH AVE BLD-RES-SFR New construction buils SFR 1574 sq ft HAYDEN HOMES LLC $301,185.53 B251294 01/30/2026 18120413440 4807 W LARCH AVE BLD-RES-SFR New construction build SFR 1574 sq ft HAYDEN HOMES LLC - STOKES, KRIS $314,072.63 B260055 01/30/2026 18132234487 4002 W CHESTNUT AVE BLD-RES-SOLAR installing 14 solar panels roof mounted and one solar battery Campbell Cool Electric Plumbing Corporation - Reynaga, Bella $41,637.40 63 Total Permits 78 of 83 Building Permits Issued - Previous Month Permit Number Date Issued Primary Parcel Number Site Address Permit Type Project Description Applicant Total Valuations B251215 02/02/2026 18120413492 4602 W LARCH AVE BLD-MSTR-SFR new sfr 1735 sq ft LUIS VILLALOBOS $339,979.65 B260014 02/02/2026 18132434582 1111 W SPRUCE ST #30 BLD-COM-REN Removing interior walls, non-bearing and bearing, also constructing (3) new walls. Installing a beam where the bearing walls will be removed. Blair, Lance $10,000.00 B260029 02/02/2026 18132033503 207 S 78TH AVE BLD-RES-ADD ADD A SECOND LEVEL TO HOME, ONE BEDROOM WITH FAMILY ROOM HUNTER, TRAVIS $60,253.20 B251175 02/03/2026 18133133425 2105 S 96TH AVE BLD-RES-SFR New SFR APPLE TREE CONSTRUCTION CO - HILL, STAN $614,665.74 B260074 02/03/2026 18132221414 4106 RICHEY RD BLD-RES-SOLAR INSTALL ROOF MOUNT 6.36KW DC SOLAR SYSTEM, LINE SIDE TAP, TEMPORARY POWERKILL REQUIRED ARIZONA SOLAR SOLUTIONS DBA SUNTRIA - ANTENETTE SPENCER $21,836.04 B260075 02/03/2026 18132541477 1212 S 6TH AVE BLD-RES-SOLAR INSTALL ROOF MOUNT 11KW DC SOLAR SYSTEM WITH MAIN PANEL UPGRADE ARIZONA SOLAR SOLUTIONS DBA SUNTRIA - ANTENETTE SPENCER $45,203.89 B260080 02/03/2026 18131944460 231 JOYCE PL BLD-RES-ROOF shingle roof replacement DAMPIER, ROGER E $8,000.00 B260079 02/03/2026 18133013518 8503 WESTBROOK AVE BLD-RES-ROOF-P roof replacement A W ROOFING OF YAKIMA LLC $12,300.00 B260064 02/04/2026 18132811425 812 S 50TH AVE BLD-RES-SOLAR INSTALL ROOF MOUNT 9.24 KW DC SOLAR SYSTEM, LINE SIDE TAP AND TEMPORARY POWERKILL REQUIRED. ARIZONA SOLAR SOLUTIONS DBA SUNTRIA - ANTENETTE SPENCER $32,403.79 B260076 02/04/2026 19133012441 1006 S 6TH ST BLD-RES-SOLAR INSTALL ROOF MOUNT 7.48KW DC SOLAR SYSTEM W ARIZONA SOLAR SOLUTIONS DBA SUNTRIA - ANTENETTE SPENCER $28,509.40 B251136 02/05/2026 18131333093 1407 CHERRY AVE BLD-RES-DEMO 18'x20' garage demolition. Garage is falling apart need it gone for safety purposes PEREZ, JESUS $5,000.00 B260077 02/05/2026 18132543443 904 W LOGAN AVE BLD-RES-SOLAR install roof mount 7.92kw dc solar system with main panel/ meter upgrade ARIZONA SOLAR SOLUTIONS DBA SUNTRIA - ANTENETTE SPENCER $36,546.20 B260087 02/05/2026 18132731454 1111 S 42ND AVE BLD-RES-SOLAR install roof mount 8.8kw dc solar system, main panel/meter upgrade ARIZONA SOLAR SOLUTIONS DBA SUNTRIA - ANTENETTE SPENCER $31,672.54 B260088 02/05/2026 18132621493 709 S 25TH AVE BLD-RES-SOLAR install roof mount 8.36kw DC solar system; sistering a 2 x 6 to all rafters in the area supporting the solar panels ARIZONA SOLAR SOLUTIONS DBA SUNTRIA - ANTENETTE SPENCER $33,479.89 B260092 02/06/2026 18132414506 202 W YAKIMA AVE BLD-COM-ROOF Remove and disposal of existing roof system. Removal and re-installation of excising coping metal. Replace damage plywood roof sheeting. 6 mil visqueen vapor barrier over plywood sheathing. 1/4 coverboard mech attached & 60 mil PTO membrane roof system fully adhered. LESLIE & CAMPBELL INC - CHRISTINA GONZALES $370,470.00 B260093 02/06/2026 19133032423 1204 S 1ST AVE BLD-RES-ROOF REPLACE ROOF WITH SHEATING PEDRO F ALONZO $7,200.00 B260094 02/06/2026 18132422442 507 N 16TH AVE BLD-RES-ROOF replacement from 3 tab shingles to metal roofing THOMAS P CARLSON $4,000.00 B260090 02/06/2026 18132844416 4809 W VIOLA AVE BLD-RES-ROOF-P Tear off existing roof and plywood. Install new 7/16" OSB, insulation board and TPO roof membrane.Brandon Woodcock $36,000.00 B260009 02/09/2026 19132933476 1125 Simpson Ln, #1- 2 BLD-RES-DUP NEW DUPLEX SILVANO ROMAN MONTES DE OCHOA $322,891.20 B260031 02/09/2026 18132033470 349 S 76TH AVE BLD-RES-ADD 11'X18' PATIO COVER HILLS, JEFF $6,355.80 79 of 83 Building Permits Issued - Previous Month Permit Number Date Issued Primary Parcel Number Site Address Permit Type Project Description Applicant Total Valuations B260101 02/09/2026 18132321034 2604 POWERHOUSE RD BLD-RES-SIDING-P Tear off and install with Ascend 14Squares Adamson, Missy $33,738.18 B260096 02/09/2026 18132811404 4806 BRISTOL WY BLD-RES-ROOF-P Reroof for 4806 Bristol WY, Yakima, WA.salas, sergy $8,000.00 B251132 02/09/2026 18133333494 5912 CRESTFIELDS RD BLD-RES-SFR New single-family residence Value Added LLC - Bader, Bruce $267,155.14 B251133 02/09/2026 18133333495 5914 CRESTFIELDS RD BLD-RES-SFR New single-family residence Value Added LLC - Bader, Bruce $267,155.14 B251125 02/09/2026 18133214664 6501 W WASHINGTON AVE BLD-CELL-TWR ATC TO INSTALL A 20'-0" EXTENSION AND MODIFICATIONS TO THE MONOPOLE FOR T MOBILE PROPOSED LOCATION VINH DINH - TEP FOR T- MOBILE $40,000.00 B260007 02/10/2026 18132741414 3510 W NOB HILL BLVD BLD-COM-DEMO Removal of 95' ft awning on the front of the building RALPH & SONS $1,500.00 B260104 02/10/2026 19133032003 1208 ROCK AVE BLD-RES-ROOF Doing a tear off and re-roof on unit# 1 only on a duplex VELAZQUEZ-ORTIZ AMBROSIO $10,000.00 B260102 02/10/2026 18132042476 6802 W YAKIMA AVE BLD-RES-ROOF-P Residential Tear-Off and Re-Roof Kearby, Don $23,630.00 B251254 02/10/2026 18133014498 8200 ANNALISA LN BLD-RES-SFR New single-family residence.GIBBS, TIM $431,255.08 B250729 02/11/2026 19131913466 210 S 7TH ST BLD-RES-ADD Constructing exterior stairs, second floor deck, and attached cover. Correcting the expiration of the original permit for the stairs and deck. Removing some of the concrete on the property to bring the property into compliance with lot coverage requirements. FLORES FRANCO HERMENGILDO $2,953.20 B260095 02/11/2026 18132623460 921 S 28TH AVE BLD-RES-SOLAR install solar roof mount system, 4.4kw pv ARIZONA SOLAR SOLUTIONS - Emily Stipp $15,756.08 B260106 02/11/2026 18133212524 1534 S 67TH AVE BLD-RES-ROOF Complete tear off and re-roof SUPERIOR ROOFING LLC $16,000.00 B251166 02/12/2026 18131434025 2404 JEROME AVE BLD-RES-SFR-FND PUTTING NEW FOUNDATION, NON-PREVIOUS VALENCIA, HERIBERTO $5,000.00 B251167 02/12/2026 18131434025 2404 JEROME AVE BLD-RES-MISC-ALT REMODEL INTERIOR OF HOME: remodeling kitchen, new applicances, new kitchen island. Enlarging and enclosing laundry room area. remodeling and expanding bathroom, changing the door going into the bathroom, from bedroom to living room. enlarging the closets inside both bedrooms. VALENCIA, HERIBERTO $5,000.00 B260072 02/12/2026 18132642049 1105 S 24TH AVE BLD-COM-DEMO Remove and dispose of the fire damaged materials as required. Area will be cleared and made ready for restoration work. Willy's Construction LLC $7,000.00 B260107 02/12/2026 18132633459 1403 S 32ND AVE BLD-RES-ROOF replace roof shingles STOUT CHRIS $7,200.00 B251131 02/12/2026 18133214664 6501 W WASHINGTON AVE BLD-CELL-TWR t-mobile proposes a collocation at an existing wireless facility and tower per plans. new antenna array consisting of antennas, radios, and associated cables. At ground level, new 10'x20' equipment leased area in existing storage area with two equipment cabinets and electrical connections. VINH DINH - TEP FOR T- MOBILE $40,000.00 B260061 02/13/2026 19131923471 6 S 2ND ST BLD-COM-REN REPAIRS SAME FOR SAME, DUE TO WATER DAMAGE, 40 0' INSULLATION, AND 200 O' DRYWALL INSTALL #1002, 10TH FLOOR CLEAN IMAGE SERVICES - ANTHONY LENBERG $5,000.00 B260063 02/13/2026 18133523401 3003 W WASHINGTON AVE BLD-COM-DEMO remove billboard and structure LAMAR ADVERTISING CO OF SPOKANE $1,000.00 80 of 83 Building Permits Issued - Previous Month Permit Number Date Issued Primary Parcel Number Site Address Permit Type Project Description Applicant Total Valuations B260108 02/13/2026 19133014492 1311 S 8TH ST BLD-RES-ROOF Tearing off old roof and doing a re-roof on a SFR SAGRADO ROOFING LLC - FRANCISCO SANTIAGO GUZMAN $12,443.00 B260109 02/13/2026 19133033494 1303 LANDON AVE BLD-RES-ROOF Residential re-roof SAGRADO ROOFING LLC - FRANCISCO SANTIAGO GUZMAN $9,446.00 B260111 02/13/2026 19131913507 107 S 7TH ST BLD-RES-MISC-ALT Re-siding the single-family residence.VICTOR CRUZ CUENCA $5,000.00 B260071 02/17/2026 18132942428 1103 S 72ND AVE STE 200 BLD-COM-TI tenant improvement for new restaurant. To go only. wall framing, and new commercial kitchen. HOME UNITED CONSTRUCTION LLC $87,000.00 B260099 02/17/2026 18132312468 2104 ENGLEWOOD AVE BLD-RES-MISC-ALT Repairs due to Fire damage on single family, replace trusses, siding, insulation (R13 for walls, blown in for attic), Sheetrock (5/8" for ceiling and 1/2" for walls), replacing windows, same for same mechanical and plumbing will be applied for by subcontractors within a week. Baxter Construction LLC - Lambert, Rodney $59,755.00 B260069 02/17/2026 18131924472 402 N 91ST AVE BLD-MSTR-SFR New single-family residence.COLUMBIA RIDGE HOMES LLC - HELLEM, JUSTIN $492,124.25 B260070 02/17/2026 18131924470 9102 HAWTHORNE DR BLD-RES-ADD Constructing a 206 sq. ft. covered patio in the rear.COLUMBIA RIDGE HOMES LLC - HELLEM, JUSTIN $6,612.60 B260068 02/17/2026 18131924473 404 N 91ST AVE BLD-MSTR-SFR New single-family residence.COLUMBIA RIDGE HOMES LLC - HELLEM, JUSTIN $470,473.00 B260065 02/18/2026 18132543495 1306 S 7TH AVE BLD-RES-SOLAR 6.150 KW PV ROOF MOUNT- SOLAR Freedom Forever WA LLC - Leann Malloy $12,000.00 B260086 02/18/2026 18133132404 2011 GALA AVE BLD-RES-SFR New SFR 1859 SQ FT, 1 STORY, 3 BEDROOM, 2 BATHROOM APPLE TREE CONSTRUCTION CO - HILL, STAN $356,851.48 B260089 02/18/2026 18132542480 1215 S 8TH AVE BLD-RES-SOLAR 9.840kw pv roof mount solar Freedom Forever WA LLC - Leann Malloy $20,000.00 B260020 02/18/2026 18132642053 2204 W NOB HILL BLVD BLD-COM-NEW Install new theft deterrent rails with automated entrance/exit gates (Electrical work to be permitted separately by another contractor) Williams, Kathy $45,000.00 B260034 02/18/2026 18131434496 705 N 28TH AVE #1-2 BLD-MSTR-DUP New 2176 duplex VICTOR J & PATRICIA PADILLA $364,710.72 B260078 02/19/2026 18133524402 2500 RACQUET LANE BLD-COM-REN remodel for an existing clean supply room, for the Ridgeview Ambulatory Surgery Center to bring it into compliance with DOH standards, and to bring the room under the hospital license. KDA Architecture - Dodge, Erik $108,096.37 B260091 02/19/2026 18132713475 1015 S 40TH AVE BLD-COM-REN Remove (1) non-bearing wall and constructing new interior walls to create patient rooms Hammered LLC $16,000.00 B251217 02/19/2026 18132143412 5301 TIETON DR BLD-COM-NEW Installation of new playground 58'x93' with a 40X35 fabric shade over playground the playground is going where the old playground was NORTHWEST PLAYGROUND EQUIP - CHRIS BRUMMETT $210,000.00 B260120 02/19/2026 18132223441 4705 AVALANCHE AVE BLD-RES-ROOF-P roof replacement A W ROOFING OF YAKIMA LLC $12,400.00 B260001 02/20/2026 18120423423 5604 WOOLSEY RD BLD-RES-SFR New single-family residence.HAYDEN HOMES LLC - GALINDO, JAVIER $401,014.92 B260057 02/20/2026 18132712010 3808 TIETON DR BLD-COM-REN installing interior 2x4 sheetrock wall 15ft wide 7.5 high in addition to installing door on same wall MAXWELL JOHN $400.00 81 of 83 Building Permits Issued - Previous Month Permit Number Date Issued Primary Parcel Number Site Address Permit Type Project Description Applicant Total Valuations B260066 02/20/2026 18120423422 5605 WOOLSEY RD BLD-RES-SFR NEW SFR 2046 SQ FT HAYDEN HOMES LLC - GALINDO, JAVIER $388,701.62 B260121 02/20/2026 19131911468 904 PITCHER ST BLD-RES-ROOF-P repairing leak that morphed into a reroof Juan Pinon $6,275.00 B260113 02/23/2026 18132031009 100 N 72ND AVE BLD-COM-ROOF replacement roof, over existing layer, shingles, no tear off, 30-year TIM LACY $30,000.00 B260124 02/23/2026 18132543463 1318 S CORNELL AVE BLD-RES-ROOF Doing complete tear off and re-roof on a SFR SAGRADO ROOFING LLC $10,500.00 B260081 02/24/2026 18132531425 1212 QUEEN AVE BLD-RES-MISC-ALT add interior walls and egress windows to create 2 additional bedrooms in basement, no plumbing, no mechanical DOCKINS, BRADLEY W $16,000.00 B260130 02/24/2026 18132124412 310 N 57TH AVE BLD-RES-ROOF-P we are doing a reroof including tear-off of old shingles and installing with new asphalt shingles D-1 Roofing LLC $11,000.00 B260114 02/25/2026 181332-32428 7700 W WHATCOM AVE BLD-RES-SOLAR 8.8 kW roof mounted solar array ELLENSBURG SOLAR LLC - REGAN MORRIS $10,692.00 B260129 02/25/2026 19132242456 613 FERNCREST DR BLD-RES-ROOF-P tear off and reroof asphalt shingles CASTILLON ROOFING $22,000.00 B231422 02/26/2026 19132032473 520 S 12TH ST BLD-RES-ADD Remove front enclosed porch and the carport that was converted to a garage without permits; remove and replace second floor; replace roof with new trusses; repair/correct first floor framing that was modified without permits; correcting framing and finish on alterations made to residence without permit, including sunroom added to rear. ANTONIA & EVAN OCHOA $35,873.28 B260022 02/26/2026 19132913448 1205 S 18TH ST BLD-CELL-TWR TOWER WORK: REMOVE 12 RRU'S. AND 6 (1-5/8") COAXX CABLES. INSTALL 3 ANTENNAS, 3 RRUS, 2 OVPS, AND 3 6X12 (1.25"/31.8MM) HYBRIFLEX CABLES. EXISTING 12 ANTENANAS TO REMAIN. GROUNDWORK TO INSTALL 2 - 12 OVPS CRAFTON COMMUNICATIONS - COURTNEY DAVIS $25,000.00 B260122 02/26/2026 18132714068 1015 S 33RD AVE BLD-RES-MISC-ALT Remove (1) interior non-bearing wall between (2) bedrooms to combine them. Constructing (3) new interior walls to create a new bathroom and closet out of the old bedroom space. Mercy, Christopher $435.65 B260128 02/26/2026 19133014483 1206 S FAIR AVE BLD-RES-MISC-ALT UPDATING INTERIOR OF WHOLE HOME, FINISHES AND FIXTURES. SAME LOCATIONS FOR ALL WALLS AND FIXTURES. THE 2 X 4 WALLS WILL BE INSULATED WITH R-15 AND 1/2" SHEETROCK, THE CEILING WILL HAVE 5/8" SHEETROCK, BLOWN IN INSULATION FOR ATTIC, R-60. PLUMBING AND MECHANICAL. ALL FIXTURES BEING REPLACED SAME FOR SAME. APPROVED WITHOUT PLANS PROVIDED NOTHING IS RELOCATED AND NO STRUCTURE IS ALTERED. Mejia Property Investments LLC - Mejia, Pablo $7,800.00 B260137 02/26/2026 18132323401 2802 W LINCOLN AVE BLD-RES-ROOF Doing a complete tear off and re-roof on SFR BALCON ROOFING LLC - JESUS MENDEZ $10,000.00 B251152 02/27/2026 19132931475 1419 S 14TH ST BLD-RES-GARAGE NEW GARAGE SHOP 1200 SQ FT PLUS AN ATTACHED COVERED CARPORT 400 SQ FT (No plumbing or heating)M A T CONST & RMDLNG LLC $90,660.00 B260052 02/27/2026 18132034489 120 S 72ND AVE #104 BLD-COM-TI Constructing interior walls for the new nail salon Tony's Home Improvement $77,000.00 B260125 02/27/2026 18132312418 523 N 24TH AVE BLD-RES-MISC-ALT Replace and install new trusses, sheeting roofing along with drywall replacement (1/2 house and ceiling). Replace 6 windows (same for same) due to fire damage CLEAN IMAGE SERVICES - ANTHONY LENBERG $60,000.00 82 of 83 Building Permits Issued - Previous Month Permit Number Date Issued Primary Parcel Number Site Address Permit Type Project Description Applicant Total Valuations B260126 02/27/2026 18133333466 2206 S 61ST AVE BLD-RES-SOLAR ROOFTOP SOLAR INSTALLATION WITH BATTERY BACKUP REVOLUSUN MOUNTAIN STATES - Ziegler, Jeremy $48,708.29 75 Total Permits 83 of 83