Board of County Commissioners

1820 Jefferson Street

PO Box 1220
Port Townsend, WA 98368
Kate Dean, District I David Sullivan, District 2 Kathleen Kler, District 3

Washington State Department of Commerce

Local Government Division - Growth Management Services
Attn: Deanna Watson, Program manager
1011 Plum Street
Olympia, WA 98504-2525
July 31, 2017

RE: Washington State Military and Community Compatibility Strategy

Dear Ms. Watson:

The Jefferson County Board of Commissioners appreciates this opportunity to provide comments on
the above referenced document.

General Comments
We have substantial concerns with respect to the equity and parity that local governments are
afforded in this proposed strategy. Jefferson County is the location of Naval Magazine Indian Island
and is situated very closely between NAB Whidbey Island and NBK Bangor, two areas of major on-
going military base training, testing and other operations. Jefferson County supports our military
partners and their efforts and understand the large and often complex training and testing work that
our military bases require.

While the Strategy does a very good job describing how local communities and the military bases can
work together better to cooperatively problem-solve and provide better planning outcomes relative to
avoiding incompatibilities and base encroachment, we believe the current cost-benefit ratio puts the
County at a disadvantage. We request that the Commerce Strategy more deliberately integrate the
social, economic and long-range planning data from local jurisdictions.

Background
Jefferson County, on the Olympic Peninsula, is a resource-rich, rural region with historical roots in
forestry, agriculture, fishing and mineral extraction. The County is characterized by hundreds of miles
of marine and fresh water shorelines from the Hood Canal to the Pacific Ocean, dense forests and the
Olympic Mountains. This uniquely remote region provides the ideal landscape for outdoor recreation,
conservation and ecosystem services, and enviable "quality of life." While the 30,000 residents of
Jefferson County highly value these attributes, they also suffer from a lack of economic opportunity,
familiar to many rural communities that have seen industry and jobs migrate to the 1-5 corridor which

Phone (360) 385-9100 Fax (360) 385-9382 jeffbocc@co.jefferson.wa. us

sits only 30 miles to the east. Eighteen per cent of families with children live under the federal
poverty level.

Jefferson County has become a backyard and playground for our more urban neighbors, including the
military. Navy operations continue to increase in intensity and frequency, generating significant
impacts without the economic benefits that Kitsap and Island Counties experience as the home to
bases and installations. Impacts to Jefferson County include :
Increasing Growler flights which result in noise impacts that affect residents in Eastern Jefferson
County, including loss of sleep, inability to hold a conversation uninterrupted, complaints from
customers at hospitality businesses, fear of decreased property values and degrading of quality of
life. In their comment letter on the US Navy Draft EIS on a proposal to substantially increase
growler flights, the WA Department of Health documents that noise negatively impacts human
health;
Growler noise and pollution associated with the Navy's Pacific Northwest Electronic Warfare Range
impacts in Western Jefferson County's Olympic National Park and in the nearby National Forests;
state and federal environmental agencies cite the need for more data as to the negative effects of
this warfare training and testing on wildlife;
The closing of Jefferson County's major transportation corridor (WA Highway 104) for submarine
traffic;
Limitations on boating and recreational use and enjoyment activities in the Hood Canal;
The Navy's purchase of development rights to remove, restrict and otherwise limit residential and
other development considered by the Navy as incompatible and/or an encroachment to naval
operations, testing, training and transportation.

Jefferson County participated in the Kitsap-Jefferson-City of Bremerton Joint Land Use Study (JLUS)
that analyzed local planning goals and policies, permitting programs and development trends with
respect to potential encroachment and/or incompatibility with military operations, training and
testing. This study identified specific individual results for each involved jurisdiction. For Jefferson
County, development throughout the unincorporated rural-residentially zoned lands was a published
area of concern to existing and potential future expansions of unencumbered military base
operations. Suggested strategies for potential local adoption include restricting, removing or limiting
land development; property owner notifications, permit conditions and land title recordings on
adjacent water-based military uses and other similar suggestions. What continues to be lacking in
studies as such, and not abundantly clear in the Commerce Strategy, is an acknowledgement that
Jefferson County depends upon orderly and thoughtful growth and development in order for its local
economy to thrive. Rural counties within the greater Puget Sound region need to be available for
growing populations while maintaining a high quality of life and access to services.

The Sentinel Landscape Designation

The Commerce Strategy lists the Sentinel Landscape Designation as an implementation action that, if
funded, Commerce would assist in executing. The Hood Canal Sentinel Landscape Designation,
pending approval in 2017, will use Navy REPI funds to purchase the development rights on
approximately 40,000 acres in Jefferson County. Commercial forest land owners will receive
substantial funds for selling development rights, the Navy will benefit from the reduction of

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development pressures and potential incompatible uses, and conservation groups further their
mission through securing both easement acres and stewardship funds as a result of this designation .
In contrast, Jefferson County loses development potential, tax base and options for future growth.
With two-thirds of the County already publicly owned, the Sentinel Landscape designation creates yet
another impact that limits economic opportunity for residents and local governments alike.
The impacts associated with the loss of development rights on this scale is exacerbated by the
limitations already realized via the Growth Management Act. While we aspire to the best planning
practices to reduce sprawl and protect working lands and open space, Jefferson County's lack of
funding for a sewer in its only unincorporated Urban Growth Area, and limited potential to carefully
develop in designated Limited Areas of More Intense Rural Development are already resulting in high
development costs, a lack of affordable housing and little commercial activity to generate tax
revenues.

Recommendations
We ask that our military partners better assess impacts to local jurisdictions, particularly in regions
where a base or installment is not located. Further, without the economic benefits that accompany
installations, we feel that mitigation efforts should be assessed to offset impacts.

We raise these issues to remind the Department of Commerce that our support for on-going and
future military base operation, training and testing is strong and our desire to serve as a partner is
inarguable. Jefferson County wishes that the subject Strategy provided more detail, more focus and
better inclusivity on local governments and community needs, goals and desires.

In conclusion, we believe mutual benefits are possible from the Washington State Military and
Community Compatibility Strategy. We believe rural counties like Jefferson County can further benefit
by receiving technical assistance and mitigation with consideration to the issues outlined on this
letter. We appreciate this opportunity to provide comments. We look forward to participating further
with the Department of Commerce on this critically important topic.

Sincerely,

Kathleen Kier, Chair

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Kate Dean, Commissioner

Districtl