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PUBLIC HEARING UDC Amendment to Ch 25-24 re: Shrubsteppe Mitigation
Banking
DATE February 3, 2026
TIME 12: 00 PM
Please Print Your Name Clearly
NAME
'S UY-\ C L� cSC
REPRESENTING
V':>.�,k
CONTACT INFO: PHONE/E-MAIL
https:Hgrantcountywa.sharepoint.coin/teamsIBOCC/Shared DocumentsIGeneraFTemplates/Public Hearings/0 Sign In Sheet, Open Record.docx
DEVELOPMENT SERVICES DEPARTMENT
264 West Division Ave. • PO Box 37
Ephrata, WA 98823
(GRANT COUNTY
WASHINGTON
Y
l
GRANT COUNTY, WASHINGTON
UNIFIED DEVELOPMENT CODE (UDC)
2024 ANNUAL AMENDMENT
STAFF REPORT
Date: December 31, 2025
To: Grant County Planning Commission
From: Jim Anderson -Cook, Director
Applicant: Grant County
P.O. Box 37
Ephrata, WA 98823
Project Number: P 25-0196
PLANNING DIVISION
(509) 754-2011 Ext. 2501
PlanningDivision@grantcountywa.gov
Description of Proposal: Amending Chapter 25.24 of the Grant County Unified Development Code
to adopt rules establishing a countywide process for certifying and regulating shrubsteppe mitigation
banks and to aid in the County's goal of achieving no net loss of ecological functions and values.
Approved banks will generate shrubsteppe mitigation credits that provide compensatory mitigation in
advance of unavoidable impacts to shrubsteppe, a priority habitat per the Washington State Department
of Fish and Wildlife (WDFW). Approved banks will consolidate compensatory mitigation into larger
contiguous areas consistent with WDFW guidance for regionally significant ecological benefits.
Location of Proposal: Grant County, WA.
Zoning: Countywide.
Environmental Review: SEPA review was completed by Grant County, and a Determination of Non -
Significance was issued on September 29, 2025.
Public and Agency
Comments: A Public Notice containing information on this project was published in the Columbia Basin
Herald on August 8, 2025. Information on this project was also mailed to applicable agencies of
jurisdiction and special interest groups for their review and comment. The public, agency, and special
interest group comment period ended on October 10, 2025.
Reviewing Agencies & Special Interest Groups:
Agencies Notified
g
Response
Agencies Notified
g
Response
Received
Received
Grant County Fire Marshal/Building
None
Grant County Treasurer's
None
Official
Office
Grant County Emergency
None
Grant County Assessor's
None
Management
Office
Grant County Health
None
Grant County Auditor
None
District
Grant County Sheriff's Office
None
Grant County Prosecuting
None
Attorne Y's Office
"To foster a thriving, resilient, and safe community through innovative planning, efficient building processes, and robust fire prevention measures. "
DEVELOPMENT SERVICES DEPARTMENT
264 West Division Ave. • PO Box 37
Ephrata, WA 98823
DATE: January 26, 2026
'GRANT COUNTY PLANNING DIVISION
WASHINGTON (509) 75A--2011 Ext. 2501
%y- PlanningDivision@grantcountywa.gov
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STAFF REPORT
TO: Grant County Board of County Commissioners
FROM: Jim Anderson -Cook, Director
SUBJECT: Comprehensive Plan Amendment Application
File #P 25-0196
APPLICANT: Grant County
P.O. Box 37
Ephrata, WA 98823
AGENT: Grant County Development Services
P.O. Box 37
Ephrata, WA 98823
PROPOSAL: UNIFIED DEVELOPMENT CODE AMENDMENT APPLICATION
The applicant proposes an amendment to Grant County Unified Development Code Chapter 25.24 of the
Grant County Unified Development Code to adopt rules establishing a countywide process for certifying
and regulating shrubsteppe mitigation banks and to aid in the County's goal of achieving no net loss of
ecological functions and values. Approved banks will generate shrubsteppe mitigation credits that provide
compensatory mitigation in advance of unavoidable impacts to shrubsteppe, a priority habitat per the
Washington State Department of Fish and Wildlife (WDFW). Approved banks will consolidate
compensatory mitigation into larger contiguous areas consistent with WDFW guidance for regionally
significant ecological benefits.
LOCATION:
Countywide.
STAFF ANALYSIS AND RECOMMENDATION:
After Staff's review of this application along with balancing the Goals and Policies of the Comprehensive
Plan, Staff recommended APPROVAL of the Unified Development Code amendment application File #P
25-0196.
PLANNING COMMISSION HEARING SUMMARY AND RECOMMENDATION:
At their open record hearing held on January 7, 2026, the Planning Commission considered the Staff
Report and application materials for the Unified Development Code change request. There were no
public comments received about this proposal. Following the public hearing and discussion, the
Commission voted 4-2 to recommend APPROVAL of this Unified Development Code amendment
request based upon the eight (8) findings of fact as well as plan consistency, process compliance, and
clear public benefit.
"To foster a thriving, resilient, and safe community through innovative planning, efficient building processes, and robust fire prevention measures. "
At this public hearing, the Board of County Commissioners may:
1. Uphold the recommendation of the Planning Commission, or;
2. Uphold the recommendation of the Planning Commission with additional conditions, or:
3. Modify the recommendation of approval with or without the applicant's concurrence so long as
the modification does not increase the area or scope of the project, increase the density of the
project or increase the adverse environmental impacts of the proposal, or"
4. Deny the requested amendment, or;
5. Deny with prejudice, or;
6. Remand the application to the Planning Commission for further proceedings.
If the Board of County Commissioners chooses to UPHOLD the recommendation of the Planning
Commission, they may wish to use the suggested motion below.
"I make a motion to uphold the recommendation of the Planning Commission and APPROVE the subject
Unified Development Code amendment application (File # P 25-0196) amending Chapter 25.24 of the
Grant County Unified Development Code to adopt rules establishing a countywide process for certifying
andregulating shrubsteppe mitigation banks." , with the eight (8) findings of fact in the affirmafive.;;
This motion must then be seconded.
A I ilk "I yk
1. Adequate information has been provided to determine the intent and purpose of the proposed
amendment;
2. Adequate information has been provided to determine the impacts caused by the change,
including geographic area affected if any, and issues presented by the proposed amendment;
3. Adequate information has been provided to determine why the existing Comprehensive Plan
policies should not continue to be in effect or no longer apply;
4. Adequate information has been provided to determine if the proposed amendment complies with
community vision statements, goals, objectives and policies found in the comprehensive plan;
5. Adequate information has been provided to determine if the proposed amendment supports the
Capital Facilities and Transportation elements of the adopted Comprehensive Plan;
6. Adequate information has been provided to determine how the proposed amendment affects the
implementation of the Unified Development Code (Titles 22, 23, 24, 25 of Grant County Code)
and what changes to the Unified Development Code were necessary to bring them into
compliance with the Comprehensive Plan;
7. Adequate information has been provided to determine if the proposed amendment has been
subject to any public review;
8. New specific language has been provided for the proposed amendment and in which section of
the Comprehensive Plan or Unified Development Code the new language is located.
Grant County — Unified Development Code Amendment — Staff Report
File #P 25-0196 - 2 -
Attachment A
December 31, 2025
Planning Commission Staff Report
Grant County — Unified Development Code Amendment — Staff Report
File #P 25-0196 ' 3 '
DEVELOPMENT SERVICES DEPARTMENT
264 West Division Ave. o PO Box 37
Ephrata, WA 98823
(GRANT COUNTY PLANNING DIVISION
WASH€' (509) 754-2011 Ext. 2501
s
PLanningDivision@grantcountywa.gov
GRANT COUNTY, WASHINGTON
UNIFIED DEVELOPMENT CODE (UDC)
2024 ANNUAL AMENDMENT
STAFF REPORT
Date: December 31, 2025
To: Grant County Planning Commission
From: Jim Anderson -Cook, Director
Applicant: Grant County
P.O. Box 37
Ephrata, WA 98823
Project Number: P 25-0196
Description of Proposal: Amending Chapter 25.24 of the Grant County Unified Development Code
to adopt rules establishing a countywide process for certifying and regulating shrubsteppe mitigation
banks and to aid in the County's goal of achieving no net loss of ecological functions and values.
Approved banks will generate shrubsteppe mitigation credits that provide compensatory mitigation in
advance of unavoidable impacts to shrubsteppe, a priority habitat per the Washington State Department
of Fish and Wildlife (WDFW). Approved banks will consolidate compensatory mitigation into larger
contiguous areas consistent with WDFW guidance for regionally significant ecological benefits.
Location of Proposal: Grant County, WA.
Zoning: Countywide.
Environmental Review: SEPA review was completed by Grant County, and a Determination of Non -
Significance was issued on September 29, 2025.
Public and Agency
Comments: A Public Notice containing information on this project was published in the Columbia Basin
Herald on August 8, 2025. Information on this project was also mailed to applicable agencies of
jurisdiction and special interest groups for their review and comment. The public, agency, and special
interest group comment period ended on October 10, 2025.
Reviewing Agencies & Special Interest Groups:
Agencies Notified
g
Response
Received
Agencies Notified
g
Response
Received
Grant County Fire Marshal/Building
None
Grant County Treasurer's
None
Official
Office
Grant County Emergency
Non e
Grant County Assessor's
None
Management
Office
Grant County Health
None
Grant County Auditor
None
District
Grant County Sheriff's Office
Grant County Prosecuting
None
I
INone
Attorne Y's Office
"To foster a thriving, resilient, and safe community through innovative planning, efficient building processes, and robust fire prevention measures."'
Grant County Public
None
Wanapum Band of Indians
None
Works Department
p
US Bureau of Reclamation
None
Wanapum Tribe
None
US Bureau of Land Management
Colville Confederated
None
None
Tribes
Confederated Tribes & Bands of the
WA Department of
Yakama Indian Nation
None
Commerce GMA Review
None
Team
WA Department of Ecology SEPA Unit
WA Department of Health
None
& Drinking Water
None
WA Department of Fish & Wildlife
WA Department of Natural
10/10/25
Resources
None
WA Parks and Recreation
WA Department of
Commission
None
Transportation
None
WA Department of Archeology &
WA Department of
Historic Preservation
None
Agriculture
None
City of Moses Lake
None
City of Ephrata
None
City of Quincy
None
City of Mattawa
None
City of Warden
None
City of Royal City
None
City of George
None
City of Soap Lake
None
City of Grand Coulee
None
City of Electric City
None
Town of Coulee City
None
Town of Wilson Creek
None
Town of Hartline
Grant County PUD
None
None
Port of Moses Lake
Quincy Columbia Basin
None
Irrigation District
None
East Columbia Basin Irrigation District
South Columbia Basin
None
Irrigation District
None
Natural Resource Conservation
None
Future Wise
None
NAS Whidbey Island
None
Comments:
The following is a summary of any public, agency, and special interest group comments received.
1. All public, agency, and special interest group comments can be found in "Attachment B."
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees - 2 -
Staff Comments and Analysis:
1. This proposal was processed as a Legislative Action in accordance with Grant County Code §
25.12, Legislative Actions.
2. Application was determined to be Technically Complete on July 1, 2024.
3. On August 11, 2025, Grant County received a letter from the Department of Commerce
acknowledging receipt of Grant County's 60-day notice of intent to adopt (2025-S-9741). Grant
County has met the procedural requirement outlined in RCW 36.70A.106. On September 12,
2024, Grant County received a letter from the State of Washington Department of Fish and Wildlife
Region Two providing comments in response to this proposal on October 10, 2025.
4. A copy of the proposed chapter of the Unified Development Code can be in Attachment A of this
Staff Report.
5. The proposed amendment is considerate of the requirements found in RCW 36.70B "Local Project
Review."
6. No substantive public, agency, or special interest group comments were received regarding the
proposed UDC amendment.
Analysis and Recommendation:
These Findings of Fact have been developed by Grant County Planning Staff, and it has been determined
that this proposal complies with these findings as outlined below and recommends APPROVAL of the
proposed amendments:
1. What is proposed to be changed and why?
Staff Response:
Amendin_g Chapter 25.24 of the Grant County Unified Development Code to adopt rules establishing a
county wide process for certifying and regulating shrubstenge mitigation banks.
2. What are the anticipated impacts caused by the change, including geographic area affected if
any, and issues presented?
Staff Response:
There are no anticipated additional impacts should this change take place.
3. Why should the existing Comprehensive Plan policies no longer continue to be in effect or no
longer apply?
Staff Response:
This change, if _granted, will build upon the existing Goals and Policies found in the Grant County
Comprehensive Plan. All existing Comprehensive Plan Policies shall continue to be in effect and shall
continue to apply.
4. Does the proposed amendment comply with community vision statements, goals, objectives, and
policies found in the Comprehensive Plan?
Staff Response:
This change, if _granted, reaffirms Grant County's responsibility in local government planning and
implementation found in 1.6 of the Grant County Comprehensive Plan, specifically developing, adopting
and implementing comprehensive plans and development regulations and the processing of land use
permits within the unincorporated portions of the County.
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees -3-
5. Do the Capital Facilities and Transportation elements support the proposed amendment?
Staff Response:
Capital facilities plan LCFP) are one of six elements required by the GMA and are required to incorporate
plans for capital facilities of state and/or regional significance, adjacent local govemments, and special
districts This does not apply to this proposed amendment.
6. How does the proposed amendment affect the implementation of the Unified Development Code
(Titles 22, 23, 247 25 of Grant County Code) and what changes to the Unified Development Code
are necessary to bring them into compliance with the Comprehensive Plan?
Staff response:
A change in Grant County's Unified Development Code is directly relevant to its Comprehensive Plan
because the Development Code serves as the regulatory framework that implements the Goals and
Policies laid out in the Comprehensive Plan This proposed application amends Chapter 25.24 —
Mitigation Requirements & Impact Fees Changes to these sections are the minimum necessary to meet
the County's goal of achieving no net loss of ecological functions and values to habitat conservation
areas.
7. Has this proposal been subject to any public review prior to submittal? if so, describe the review
that was provided.
Staff response:
A five -member Technical Advisory Group (TAG) was convened by Grant County Development Services
in March 2024 to consider the establishment of a Shrubsteppe Mitigation Bank and proposed
amendments to GCC 25.24. The Grant County Planning Commission held workshops on the proposed
amendments on August 8, 2024, and again on November 5, 2025. Information describing the purpose of
the TAG, along with a summary of minutes from six L6) meetings of the Grant County Shrubsteppe
Mitigation TAG and the full meetinq minutes, is provided in Attachment C.
8. Has specific suggested new language been provided? Which section of the Comprehensive Plan
or Unified Development Code is the new language located?
Staff response:
See draft 25.24 in Attachment A
FINDINGS OF FACT
The Planning Commission may want to consider the following criteria in making a recommendation to
the Board of County Commissioners. If the Grant County Planning Commission makes a
recommendation to either approve, approve with conditions, or deny this proposal, a written record of the
case and the findings of fact upon which the action is based shall be included (RCW 36.70.900). The
following criteria of approval should be considered and may be used as findings of fact for this proposal:
1. Adequate information has been provided to determine the intent and purpose of the proposed
amendment;
2. Adequate information has been provided to determine the impacts caused by the change,
including geographic area affected if any, and issues presented by the proposed amendment;
3. Adequate information has been provided to determine why the existing Comprehensive Plan
policies should not continue to be in effect or no longer apply;
4. Adequate information has been provided to determine if the proposed amendment complies with
community vision statements, goals, objectives and policies found in the comprehensive plan;
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees - 4 -
5. Adequate information has been provided to determine that the proposed amendment does not
apply to the Capital Facilities and Transportation elements of the adopted Comprehensive Plan;
6. Adequate information has been provided to determine how the proposed amendment affects the
implementation of the Unified Development Code (Titles 22, 23, 247 25 of Grant County Code)
and what changes to the Unified Development Code were necessary to bring them into
compliance with the Comprehensive Plan;
7. Adequate information has been provided to determine if the proposed amendment has been
subject to any public review;
8. New specific language has been provided for the proposed amendment and in which section of
the Comprehensive Plan or Unified Development Code the new language is located.
Action:
The Planning Commission should make a recommendation to the Grant County Board of Commissioners,
which may include either to approve, approve with modifications, or deny this request for a Unified
Development Code amendment.
1. An amendment to Chapter 25.24 of the Grant County Unified Development Code to adopt rules
establishing a countywide process for certifying and regulating shrubsteppe mitigation banks.
Motion:
If the Planning Commission chooses to uphold the recommendation of Staff, they may wish to use the
suggested motion below.
"I make a motion to recommend to the Board of County Commissioners to approve the subject
amendment (File # P24-0196) amending Chapter 25.24 of the Grant County Unified Development Code
to adopt rules establishing a countywide process for certifying and regulating shrubsteppe mitigation
banks."
This motion must then be seconded.
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees - 5 -
ATTACHMENT A
Proposed amendments to Unified Development Code 25.24
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees - 6 -
Chapter 25.24
MITIGATION BANK REQUIREMENTS
Sections pie
Article I. General Provisions — Shrubsteppe Mitigation Banking....................................................1
25.24.010 Background and Purpose.....................................................................................................1
25.24.020 Interagency Review Team................................................................................................... I
ArticleII. Certification Process.............................................................................................................1
25.24.030 Decision -Making Procedure................................................................................................1
25.24.040 Purpose of the Prospectus....................................................................................................1
25.24.050 Content of the Prospectus.................................................................................................... 2
25.24.060 Mitigation Banking Instrument............................................................................................ 2
25.24.070 Public Notice....................................................................................................................... 3
25.24.080 Review and Approval of Bank Instrument.......................................................................... 3
ArticleIII.
Bank Establishment...........................................................................................................4
25.24.090
Design Incentives................................................................................................................ 4
25.24.100
Site Selection....................................................................................................................... 4
25.24.110
Permanent Protection...........................................................................................................4
25.24.120
Credit Description................................................................................................................ 5
25.24.130
Credit Generation................................................................................................................ 5
25.24.140
Release of Credits................................................................................................................ 5
25.24.150
Performance Standards........................................................................................................ 5
25.24.160
Service Area........................................................................................................................ 6
25.24.170
Financial Assurance for Long Term Management.............................................................. 6
ArticleIV.
Bank Operation..................................................................................................................6
25.24.180
Monitoring and Reporting................................................................................................... 6
25.24.190
Maintenance Plan................................................................................................................ 7
25.24.200
Adaptive Management......................................................................................................... 7
25.24.210
Master Credit Ledger...........................................................................................................7
ArticleV. Use of Bank Credits........................................................................................................... 7
25.24.220 Use of Bank Credits............................................................................................................. 7
ArticleVI. Compliance with Certification.........................................................................................8
25.24.230 Remedial Actions C'el ,rIxilan .�vzit :Fe f Y,C of Gei4i- eatieii 8
...............................................
25.24.240 Compliance with Re ucl fired Remedial Actions.................................................................... 8
Article VII. General Provisions - Water Mitigation Banking (RESERVED)...................................9
Chapter 25.24 i December 2025 Amendments
Article I. General Provisions — Shrubsteppe Mitigation Banking
25.24.010 Background and Purpose
(a) Grant County (County) requires compensatory mitigation for unavoidable, unintentional, or
intentional impacts to wildlife species and habitat conservation areas. Compensatory mitigation
consists of replacing or providing substitute resources or environments. The County may accept the
purchase of mitigation credits through its shrubsteppe mitigation bank program as fulfillment of the
requirements for compensatory mitigation, once all available and prudent measures have been taken
to avoid, minimize, rectify, and reduce or eliminate over time any impacts to critical areas. The
County supports the use of mitigation banking as a regulatory tool to enhance mitigation outcomes for
impacts to regulated upland and aquatic habitats, consistent with local, state, and federal regulations.
Mitigation banks shall be utilized in accordance with their approved Mitigation Banking Instrument
(MBI) and applicable county regulations to support county -approved development projects.
(b) The purpose of this chapter is to adopt rules establishing a county wide process for certifying and
regulating shrubsteppe mitigation banks and to aid in the Countv's goal of achieving no net loss of
ecological unctions and values Approved banks will generate shrubsteppe mitigation credits that
provide compensatory mitigation in advance of unavoidable impacts to shrubsteppe, a priority habitat
,per the Washington State Department of Fish and Wildlife (WDFW). Approved banks will
consolidate compensatory mitigation into larger contiguous areas consistent with WDFW guidance
for regionally significant ecological benefits.
25.24.020 Interagency Review Team
(a) The interagency review team (IRT) consists of the County as the IRT chair, County designated staff
or hired consultant(s), and may include other relevant parties as
deemed appropriate by the County Director_e. , WDFW and Columbia Basin Conservation District)
that have technical expertise or regulatory authority in the specific regulated habitat and that choose
to participate in the bank program. The IRT assists in the development of the terms and conditions of
the MBI by participatin in 'n negotiations with the Mitigation Bank Sponsor (Sponsor) and providing
feedback on bank proposals The IRT members assist the Sponsor in identifying any permits or
approvals that may be required by their respective agency. The IRT may offer guidance or feedback
on the proposed shrubsteppe mitigation bank related to technical feasibility, operational sustainability,
durability, and ecologically appropriateness.
Article II. Certification Process
25.24.030 Decision Making Procedure
(a) All decisions made by the County will take into consideration IRT and public comments submitted to
the County as part of the certification process The County will strive to incorporate IRT and public
comments on the terms and conditions of the MBI where practical. Ultimately, the County shall be
responsible for making the final decisions on the bank proposal and final approval of the MBI.
25.24.040 Purpose of the Prospectus
(a) The purpose of the prospectus is to provide a conceptual plan for a bank proiect. The County uses the
prospectus to notify interested state agencies, tribes and the local government of the proposed bank
Chapter 25.24 1 December 2025 Amendments
project. The prospectus initiates dialogue between the County, Sponsor, and IRT members on a
proposed bank project. The County uses the prospectus to make an initial determination on whether
there are critical issues that may affect the ability of the bank to be certified and promptly notify the
Sponsor of specific concerns and if the County is willing to move forward with consideration of a
Banking Instrument.
25.24.050 Content of the Prospectus
a) At a minimum, the prospectus must contain information on the following elements:
1. The goals and objectives of the ,project.
2. Location of the project, proximity to existing roads and other landmarks, and a vicinity map
showing location of the proposed site(s).
3. Detailed site map that includes parcel numbers, total area of the site, mapped habitat areas and
fish and wildlife habitat conservation areas associated with the project, presence of rights of way,
easements, or other encumbrances.
4. A description of existing conditions of the proposed site(s) including but not limited to: (a) Land
ownership; (b) Local land use or zoning designation; (c) Current use, (d) Presence of liens,
easements, or other encumbrances.
5. Identification of all buildings, structures, and other built features that would remain on the site
after approval of the bank.
6. Discussion and description of any alterations or enhancements proposed for the site based on
agency prescribed habitat restoration goals and objectives.
7. Proposed credit generation ratios for the site and total credits anticipated to be generated.
8. Identification and details of proposed permanent protection mechanism, such as a conservation
easement.
9. The proposed ownership arrangements and long-term management strategy for the bank.
1.0. The qualifications of the Sponsor to successfully complete the proposed bank project(s),
including information describing any such past activities by the Sponsor.
11. Credit descriptions should also demonstrate additionality or otherwise explain hove the impact
achieved by the bank would not otherwise occur.
25.24.060 Mitigation Banking Instrument
(b) Following acceptance of the Prospectus by the County, a Mitigation Banking Instrument (MBI) will
be required from the Sponsor that will function as the contract between the Sponsor and the County
on the details of the permitting, establishment, construction, operation, and long-term management of
the mitigation bank site. A Sponsor can be a private or public entity. The MBI will include detail on
all the physical characteristics, legal obligations, operational procedures, credit generation and credit
transaction tracking and reporting, monitoring, and maintenance requirements for a bank. Once the
MBI is approved, the Sponsor will be responsible for the site during the Bank Establishment Period
which starts when the Conservation Easement is placed on the property. The Bank Establishment
period may involve site restoration, maintenance, and monitoring of vegetation. After the Bank
Establishment period is completed, the Long -Term Steward will take over responsibility for the site.
Requirements for instruments may vary based on the specific conditions of the bank site but at a
Chapter 25.24 2 December 2025 Amendments
minimum include the following:
1. The goals and objectives of the project.
2. Site location and legal description of the bank project and included parcel boundaries, proximity to
existing roads and other landmarks, and a vicinity map showing location of the proposed site(s);
3. A detailed description of existing conditions of the proposed site(s) including but not limited to:
La) Habitat assessment including a vegetation survey, existing vegetation conditions, soils mapping
and specific WDFW mapped priorityspecies present on the site; (b) Current uses; (c) Presence of
liens, rights of way, easements, or other encumbrances.
4. Identification of all buildings, structures, and other built features that would remain on the site
after construction.
5. A summary of how the bank meets County and resource agency habitat restoration and
preservation goals and how its design and location are ecologically appropriate.
6. A detailed description of the proposed bank site including but not limited to: The bank size and a
detailed analysis of existing habitat conditions across the site and actions that will be taken to
improve specific wildlife and habitat values.
7. Bank establishment timing and schedules.
8. Documentation of the ownership of bank lands and a legal description of the bank site.
9. A detailed description of Sponsor responsibilities for bank establishment including information on
permanent conservation easement placement, site monitoring, protection and reporting, and
identification of long-term maintenance and site stewardship responsibilities, in perpetuity.
10. The potential number of credits to be generated by the bank and a credit description.
11. Credit tracking and accounting procedures, including County reporting requirements.
12. Performance standards for determining bank success and credit release process.
13. Monitoring and adaptive management plan and reporting_ protocols, including a clear statement of
responsibility for conducting the monitoring and reporting.
14. The ownership arrangements and long-term management plan for the bank with an entity that is
qualified to undertake lony,-term stewardship in perpetuity for the site.
15. Provisions for permanent protection of the bank site.
16. Force majeure clause (identification of Sponsor responsibilities in the event of catastrophic events
such as wildfire that are beyond the Sponsor's control).
17. A provision stating that legal responsibility for providing the compensatory mitigation lies with
the Sponsor once a permittee secures credits from the Sponsor.
18. Default, enforcement and closure provisions.
Chapter 25.24 3 December 2025 Amendments
25.24.70 Public Notice
(a) It is the County's goal to ensure that accurate information on the proposed bank MBI is made
available to the public, and to avoid duplicative processes for public comment. The County shall
provide public notice, using an existing public notice process, or in conjunction with the SEPA
process as appropriate, to solicit comment on the MBI.
25.24.080 Review and Approval of Bank Instrument
(a) Upon final review and approval by the County of the MBI, the Sponsor will sign the agreement,
followed by the County. At a minimum, the County shall notify the following entities: The local
jurisdiction(s) where the bank site is located, WDFW, local Tribes, and the public. A signed copy of
the MBI will be made available on the County's website.
Article III. Bank Establishment
25.24.090 Desisn Incentives
(a) The goal of this guidance document is to encourage the development of banks which utilize best
available science as documented by resource agencies working to protect regulated habitat and
species in Washington State to provide significant and sustainable compensatory mitigation. To
achieve this, incentives have been built into the certification, bank establishment, and credit
generation process to encourage the siting and design of banks that provide significant ecological
benefits to regulated habitat and species in areas identified as high priority by WDFW. The County
shall make decisions regardingthe application of specific incentives on a case -by -case basis.
The County may utilize their In Lieu Fee Program and funds collected therein to support the
development of a Mitigation Bank from the onset. Specifically, In Lieu of Fee funds can be applied to
the procurement of land approved as a Bank Site or restoration efforts at the approved Bank Site
consistent with an adopted MBI.
When In Lieu Fee funds are used for acquisition or restoration at a mitigation bank site, the credit —
debit accounting system shall explicitly account for those. Credits generated by actionseLunded wholly
or partially with In Lieu Fee payments must be debited in applicable credit ledger(s) (., the ILF
prograin's and, as applicable, the mitigation bank sponsor's) and reconciled in the applicable
registry to prevent double -counting and to ensure compensatory mitigation obligations are met.
25.24.100 Site Selection
(a) Banks must be sited, planned, and designed to be self-sustaining over time. The County shall
carefully consider ecological suitability, ecological sustainability, and land use compatibility_ when
determining if a site is an appropriate location for a bank.
The County shall consider whether the bank location conflicts with local or statewide goals for land
preservation. Strong preference will be given to sites that meet the goals of the Washington
Department of Fish and Wildlife's long-term strategy for priority habitat restoration.
Chapter 25.24 4 December 2025 Amendments
Site selection preference of a Bank Site will be given to Grant County parcels containing shrubsteppe
habitat designated as "Core Habitat" on the WDFW Washington Shrubsteppe Restoration &
Resiliency Initiative (WSRRI) Mapping Platform.
25.24.110 Permanent Protection
(a) A permanent protection mechanism, such as a conservation easement, placed on the title to the bank
property, held by a Land Trust accredited by the Land Trust Accreditation Commission or suitable
public agency, must be in place before any credits can be released by the County to the Sponsor for
sale.
Terms of the conservation easement must be approved by the County to ensure that the conservation
values of the bank site are monitored, protected and enforced in perpetuity by a responsible,
financially viable third party.
(b) In addition to the Conservation Easement, the MBI must include a long-term stewardship plan that
will be implemented by the long-term steward in perpetuity after the establishment period is ended.
The long-term Stewardship plan will be implemented by the Long Term Steward, supported by a
team of stakeholders that are experienced in managing habitat. The plan must include a description of
long-term management needs, annual cost estimates for these needs, and identify the funding
mechanism that will be used to meet those needs in perpetuity.
The MBI may contain provisions allowing the Sponsor to transfer the long-term stewardship
responsibilities for the bank site to a land stewardship entity, such as a public agency,
nongovernmental organization, land trust or private land manager, after review and approval by the
County. This land stewardship entity need not be identified in the MBI, as long as the future transfer
of long-term stewardship responsibility is approved by the County and implemented before the final
25% of credits from the bank are awarded to the Sponsor.
The owner of a bank property may not complete any conveyance of title, easement, lease, or other
interest directly related to the bank without adequate and complete provision for the continued
management of the bank property as specified in the MBI.
25.24.120 Credit Description
The Sponsor must provide a description of what the credit values represent in the MBI. Credit
generation may be based on area ratios of different restoration actions undertaken at the bank, to area
of impact at the impact site Credit values may also be based on functional assessment methods
determining_ the functions and values at the bank site and the functions and values at the impact site.
Credit values are expected to vary based on land use category (i.e., residential, commercial or
industrial) at the impact site and the duality of the habitat/mapped habitat present at the impact site.
Credit values may be modified or converted to another currency based on the shrubsteppe habitat
functions restored at the bank site and the functions impacted at the impact site, if future guidance or
policies support other forms of functional assessment methods.
Chapter 25.24 5 December 2025 Amendments
25.24.130 Credit Generation
a) The County will be responsible for determining the appropriate credit values associated with the
restoration actions and long-term stewardship of a bank. These factors will determine the credit use
ratios. In all cases the County will determine and approve specific credit ratios based on the overall
ecological function and condition of the mitigation area, potential of enhancement, restoration and
connectivity to other core shrubsteppe habitat, effectiveness of protection and preservation and other
relevant factors that would contribute to the overall improvement and long-term success of the bank
25.24.140 Release of Credits
a) The MBI shall include the process and schedule for the release of credits to the Sponsor by the
County, which shall be tied to peg forinance standards appropriate for the mitigation activities
undertaken..
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25.24.150 Performance Standards
a) The development of Performance Standards shall be incorporated into the MBI. Performance
Standards are goals, objectives, and commitments of the formed Mitigation Bank. The success of
the Mitigation Bank will be derived from the conformance of the established Performance
Standards. Examples of Performance Standards include but are not limited to the following
percent recruitment of native vegetative assemblages; survival percentage of installed native
plantings; reduction percentage of invasive or weedy species; percent increase of overall aerial
vegetative species cover; and documented presence of specific wildlife species. Performance
Standards are tracked over the established monitoring_ period / bank establishment period
stipulated in the MBI, and will
continue until a minimum o ten years or the desired ecological uplift is achieved.
25.24.160 Service Area
a) The County will determine the appropriate service area for Proposed banks. Out of service area credit
transfers are allowed as long as the regulatory entities involved are aware of and approve the transfer.
The Sponsor must provide a detailed text description and a map of the bank's proposed service area in
the MBI. Generally, the service area for a mitigation bank would be the political boundary of Grant
County and include the local jurisdictions contained within.
25.24.170 Financial Assurance for Lone Term Management
a) The County will require financial assurances for the long-term stewardship of a bank site. The
Sponsor must provide the department with a written stewardship plan with an estimate of the costs,
including an allowance for inflation going forward in time. The Sponsor must document how
sufficient funds for the anticipated long-term stewardship costs will be provided.
Chapter 25.24 6 December 2025 Amendments
Appropriate long-term financing mechanisms include, but are not limited to, nonwasting
endowments, trusts, contractual arrangements with future responsible parties, and other appropriate
financial instruments.
In cases where the long-term stewardship entity is a public authority or government agency, that
entity must provide a plan for the long-term financing of the bank site. If the ownership of the site is
transferred in the future, the financial mechanism for long-term stewardship must remain with the
entity responsible for the long-term stewardship of the bank site.
Article IV. Bank Operation
25.24.180 Monitoring and Reportiny,
(a) The goal of monitoring a bank site is to:
1. Document changes to the baseline conditions at the site.
2. Document the condition of the site as it develops over time.
3. Provide early identification of problems in the site's development that would trigger potential
adaptive management activities.
(b) The Sponsor must develop a monitoring plan and include it in the MBI. The monitoring plan must
include, but is not limited to:
1. A description of the variables that will be monitored, a description of the methods or protocols
used to monitor those variables, and how they will be evaluated.
2. A schedule of monitoring including the time of year, frequency, and duration.
3. A description and map of photo points or other methods such as drone photography, documenting
the site conditions.
25.24.190 Maintenance Plan
(a) Ongoing, maintenance activities that may be required during the life of the bank should be
documented in the MBI These activities may include, but are not limited to, control of invasive
species, seeding of native species, fence and signage repair, trail or road maintenance.
25.24.200 Adaptive Management
(a) Each MBI must include an adaptive management plan. The adaptive management plan for a bank site
must include the following elements, but is not limited to:
1. Identification of potential causes for site failure or changes that would trigger adaptive
management.
2. A management strategy to address unforeseen changes in site conditions.
3. The Sponsor's responsibilities and process for reporting and implementing adaptive management
activities.
Chapter 25.24 7 December 2025 Amendments
The Sponsor shall notify the County within thirty days if adaptive management activities are
implemented to address unforeseen problems with site conditions.
25.24.210 Master Credit Ledter
a) The County shall maintain a master ledger for each bank and must cross-check the Sponsor's annual
ledger against the master ledger. The Sponsor is required to submit a copy of the ledger to the County
with each credit transaction and then annuallyiftransactions have occurred. The County will
apply administrative fees to the Sponsor for bank use fees and recording keeping. The County's
administrative fees will not exceed 10% of the mitigation credit fee.
The County must notify the Sponsor within sixty days of receipt of the Sponsor's annual ledger if the
ledger conflicts with the master ledger. At a minimum the ledger must document the number and date
when credits are received and then for each transaction, the date, the name, address and phone
number of the purchaser, the permit numbers and regulatory agencies that the credits are being
transferred to, a description of the impact and the number of credits transferred. The Sponsor is
responsible for reconciling any discrepancies between the Sponsor's ledger and the County's master
ledger. If the Sponsor fails to resolve any discrepancies, the County may suspend the further use of
available credits.
Article V. Use of Bank Credits
25.24.220 Use of Bank Credits
(a) Banks are a preferable option for compensating for authorized impacts to regulated habitat areas Use
of a bank can help reduce risk and uncertainty as well as temporal loss of resource functions and
services when used to compensate for authorized impacts. Banks can also site mitigation in areas that
have more value to ecosystem functions. Projects located within the bank's service area are eligible to
apply to use credits from a bank to compensate for authorized unavoidable impacts. The permitting
agencies determine whether the use of credits from a bank provides appropriate compensation for a
debit proiect's unavoidable impacts in the project permitting process. Purchase of bank credits may
be a condition of permit approval and be required as a condition before construction may be in.
Additionally, the County has the option to utilize previously collected funds associated with its In
Lieu Fee program to purchase available bank credit in cases where such funds are unable to be
expended on other mitigation related projects within a reasonable period of time.
Article VI. Compliance with Certification
25.24.230 Remedial Actions
It is the County's goal during the bank establishment period to ensure that the creation and operation
of a bank is consistent with the terms and conditions of the certification as specified in the MBI. If a
bank does not attain the required conditions or document attainment of performance standards or
meet other requirements specified in the MBI, the Sponsor shall implement additional adaptive
management activities. If such activities do not achieve compliance within a reasonable time, the
County may require remedial actions, which may include additional adaptive management activities
or other activities necessary to achieve compliance.
Chapter 25.24 8 December 2025 Amendments
If the Sponsor determines that the bank will not attain performance standards, the Sponsor shall notify
the County. The notification must include:-- (a) A clear statement of the issue; (b) Supporting
documentation of the problem, such as photographic evidence, documentation from field reviews, the
submitted monitoring report, or the credit release petition; and (c) Recommendations for remedial
actions or other alternatives to address the problem. If the County determines that remedial actions
are necessary(a) The County shall consult with the signatories and long term steward to determine
appropriate remedial actions; (b) During consultation, the signatories and long term steward may
recommend remedial actions to the County and may comment on remedial actions proposed by the
County; and (c) The County shall consider the recommendations and comments of the signatories,
and long term steward if any, and shall make the final decision regarding appropriate remedial
actions The County shall issue, in writing, its determination for required remedial actions to the
Sponsor, the signatories, and long-term steward.
25.24.240 Compliance with Required Remedial Actions
(a) If the Sponsor does not complete the required remedial actions within the schedule specified by the
County, the County must send a notice of noncompliance to the Sponsor, signatories, and long-term
steward The Sponsor must respond in writing to the County within thirty days of receipt of the
notice The response shall include an explanation of why the Sponsor has not implemented the
required remedial actions and a proposed schedule for completion. The County, in consultation with
the long-term steward, shall determine whether the reasons provided by the Sponsor constitute
extenuating circumstances and shall determine whether to extend the schedule for implementing
remedial actions If the County determines that the schedule should be extended, the County must
notify the Sponsor in writing If the County determines that the schedule should not be extended, the
County must notify the Sponsor by certified mail with a return receipt requested that it intends to
proceed with one of the following actions: Adjust the total number of potential credits at the bank; or
suspend the use and sale of available credits at the bank.
Article VII. General Provisions — Water Mitigation Banking (RESERVED)
Chapter 25.24 9 December 2025 Amendments
ATTACHMENT B
Public, Agency, and Special Interest Group Comments
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees - 7 -
5TA 7,p
"1 4
State of Washington
DEPARTMENT OF FISH AND WILDLIFE REGION TWO
Mailing Address: 1550 Alder Street NW, Ephrata, WA 98823-9699 - 509 754-4624 TDD 360 902-2207
Region Two Office Location: 1550 Alder Street NW, Ephrata, WA
October 10, 2025
Grant County Planning Division
Attention: Jim Anderson -Cook, Development Services Director
264 W. Division Avenue
Ephrata, WA 98823
SUBJECT: PLANVIEW SUBMITTAL 2024-S-9741; PROPOSED AMENDMENT TO
CHAPTER 25.24 — MITIGATION BANK
Dear Mr. Anderson -Cook,
On August 11, 2025, the Washington Department of Fish and Wildlife (WDFW) received from the
Washington State Department of Commerce a Notice of Intent to Adopt the proposed amendment
referenced above, and that the comment period had commenced. WDFW's interest in this proposal is
based on our agency's mandate to perpetuate fish, wildlife, and their habitat'. )ArDFW Habitat
Program staff review proposed changes to local jurisdictions' land use plans to advise of potential
fish and wildlife issues and impacts. In keeping with our role as a technical advisor, we offer the
following comments and recommendations.
Upon review of the submittal, it appears that the proposal amends Chapter 25.24 of the Unified
Development Code (UDC) through the addition of language governing Mitigation Banks. As the
county has consistently and substantially engaged us as a partner for more than a year on the
development of its shrubsteppe mitigation bank policy, we want to note our gratitude for our ability
to contribute to the development and eventual implementation of this policy. We highly value the
relationship we have with the county and wish to maintain this collaborative partnership into the
future.
Our comments are meant to provide assistance in the county's efforts to implement its development
in a way that preserves habitat quality and connectivity and ensures the county meets its
requirements to maintain No Net Loss (NNL) to ecological functions and valueS2 . For questions on
technical guidance, we recommend referring to our Technical Memorandum on Shrubsteppe
Mitigation Guidance, dated May 2025. Please feel free to contact us with any questions, concerns, or
responses to the below comments.
RCW 77.04.012
WAC 365-196-830
WDFW Comments: Proposed Amendments to the Grant County Unified Development Code
October 10, 2025
Page 2 of 6
25.24.010 Background and Purpose
We are grateful for the county's progressive thinking and sustained efforts to create more effective
policies to maintain critical shrubsteppe habitat within its boundaries. We believe that banking
instruments, when effectively implemented, can go a long way to help the county meet its
requirement for No Net Loss of ecological functions and values3.
Throughout our collaboration, the county has committed to maintaining No Net Loss to functions
and values of its shrubsteppe landscapes as being the standard by which it will measure the success
of the banking policy. We are aligned with the county in this and support the development of this
innovative policy in order to meet that goal. To enshrine that commitment, we recommend including
language establishing the NNL standard in this section. This section does not change any existing
policy within the UDC but succinctly commits to and describes the overarching goal of this program.
The purpose of this chapter is to adopt rules establishing acounty-wide process for certifying
and regulating shrubsteppe mitigation banks and to aid in the County 's goal of achieving no
net loss of ecological functions and values. Approved banks will generate shrubsteppe
mitigation credits that provide compensatory mitigation in advance of unavoidable impacts to
shrubsteppe, a priority habitat per the Washington State Department of Fish and Wildlife
(WDFW). Approved banks will consolidate compensatory mitigation into larger contiguous
areas consistent with WDFW guidance for regionally significant ecological benefits.
25.24.050 Content of the Prospectus
We are grateful for the county's establishment of guidelines for bank prospectuses. We are largely
satisfied with the listed requirements and only want to recommend a minor addition to the list
explaining how the bank would prove additionality, meaning that bank's mitigation would create
ecological uplift which would not otherwise happen.
11. Credit descriptions should also demonstrate additionality or otherwise explain how the
impact achieved by the bank would not otherwise occur.
25.24.090 Design Incentives
As written, the code allows the County to use In -Lieu Fee (ILF) funds to support the development of
a mitigation bank, including procurement of land or restoration at a bank site. However, the section
does not address how those ILF payments will be reconciled within the credit —debit accounting
system to prevent "double-dipping" (i.e., credits being generated and sold after they have already
been funded in part by ILF payments). This creates a risk of over -crediting and undermining the
integrity of the program.
3 WAC 365-196-830(4)
WDFW Comments: Proposed Amendments to the Grant County Unified Development Code
October 10, 2025
Page 3 of 6
Based upon our conversations with the county and its consultants, it is our understanding that the
county recognizes the potential for double-dipping, and that any use of the county's ILF funds
toward the establishment of a Mitigation Bank will be accounted for within the bank registry and
will properly retire the appropriate number of credits. Accordingly, we support this policy and offer
the following language amendment only as a formal clarification and requirement.
The county may utilize their In Lieu Fee Program and funds collected therein to support the
development of a Mitigation Bank from the onset. Specifically, In Lieu of Fee funds can be
applied to the procurement of land as a Bank Site or restoration efforts at the approved Bank
Site consistent with an adopted MBI.
When In Lieu Fee fiends are used for acquisition or restoration at a mitigation bank site, the
credit —debit accounting system shall explicitly accountfor those. Credits generated by
actions ficnded wholly or partially with In Lieu Fee payments must be debited in applicable
credit ledger(s) (e.g., the ILFprogram's and, as applicable, the mitigation banksponsor's)
and reconciled in the applicable registry to prevent double -counting and to ensure
compensatory mitigation obligations are met. "
25.24.120 Credit Description
Based upon the language within this section, we have some concerns over the credit generation
process that the county has outlined. Our concerns pertain mainly to conflating terminology and the
use of land use categories within credit valuation. The amendments we recommend are aimed at
improving the generation process through increased clarity and firmer grounding in the scientific
basis. We believe that these changes will protect the integrity of bank credits, increasing developer
confidence in their value and through that the success of the banking program.
The section suggests that credit values are expected to vary based impact site characteristics not
just based on habitat quality and quantity but also land use category. This appears to conflate the
terminology for two different concepts credit value, which is derived from bank -side
characteristics, with debit ratios, which are derived from impact -side characteristics compared to
how they are commonly used in Washington regulatory contexts. Per the Department of Ecology's
Credit Guide 4, Credit values should reflect the ecological gain at the bank site, while debit ratios
reflect specific characteristics of the impact site. While the county may be broadly referring to
overall mitigation ratios as a combination of the two, it could result in some uncertainty for operators
seeking to develop a Mitigation Banking Instrument (MBI). If our understanding is accurate, we
would recommend clarifying the use of these terms with those used by the Department of Ecology.
4 Credit Guide for Wetland Mitiiation Banks
WDFW Comments: Proposed Amendments to the Grant County Unified Development Code
October 10, 2025
Page 4 of 6
Regarding variables impacting debit ratios, we are concerned by the inclusion of land use category.
Current VWDFW management recommendations do not treat land use category (or zoning
designation) as a variable that equates to ecological value. Whether habitat falls within a residential,
commercial, or industrial zone does not inherently diminish its ecological functions or values.
We have recently discussed this topic in meetings with the county, and it is our understanding that
the exact policy is yet to be determined. While we understand the county's efforts to align this
mitigation banking policy with its housing goals, there is some danger in using non -scientific
variables to determine debit ratios, and it is vital that any methodology that uses these variables still
demonstrate overall No Net Loss to functions and values. As written in our Technical Memorandum,
we recommend the use of an Ecological Integrity Assessment (EIA) in the determination of credit
value. An EIA provides a science -based framework that can more accurately capture habitat quality
and ecological nuance. We look forward to collaborating on this more in the future.
25.24.130 Credit Generation
Based upon our most recent conversations with the county, it is our understanding that the county
will ultimately maintain the registry of all mitigation banks operating within its borders. In this
regulatory role, it will determine the ultimate mitigation ratios (which are based upon the credit
generation and credit debiting policies) and will judge proposals in line with Best Available Science
and hold them to a standard of No Net Loss to ecological functions and values, as described in
section 25.24.090. Accordingly, we support this policy.
25.24.140 Release of Credits
We are grateful for the county's efforts to set guidelines on the staging of credits when released (or
debited) from a bank. We acknowledge that the code language is fungible and leaves the county with
discretion to establish more elaborate release schedules, but as written, we have concern over the
nature of the policy as described in this proposal.
As written, this section allows up to 75% of bank credits to be released upon completion of
administrative steps (MBI approval, easement, stewardship account), without any demonstrated
ecological performance. This policy, if implemented at the most literal level, particularly for
enhancement and restoration activities, would allow the bank sponsor to recoup nearly all their
expenses before a single acre of land is mitigated. This creates a significant risk of spatiotemporal
ecological loss and over -crediting if the bank does not achieve its performance standards.
Standard practice in mitigation banking ties credit releases to the achievement of ecological
milestones (or performance standards) and not just to administrative requirements. For example,
Washington's wetland banking rules releases credits in stages: up to 14% at preconstruction when
5 WAC 173-700-330 through -335)
WDFW Comments: Proposed Amendments to the Grant County Unified Development Code
October 10, 2025
Page 5 of 6
site protections and financial assurances are in place; up to 3 0% after construction and as-builts; and
up to 50% as key ecological performance standards (e.g., hydrology) are met, with the remainder
released only after all standards are achieved and long-term management is secured. Ecology may
allow earlier timing (not larger amounts) if approved function -boosting actions are completed, but
total releases cannot exceed these caps. In practice, full release typically spans several years to
ensure durable outcomes. An example of such a system is outlined in our Technical Memorandum.
While wetland banking and shrubsteppe mitigation are operationally different, the same principle
applies to credit release stages. There are significant risks associated with releasing credits during
the bank establishment phase, as it allows the bank operator to recoup costs before completing the
work. It allows for the sale of credits signifying ecological uplift before that uplift occurs. When
credits are released in bulk prior to bank establishment, they must be backed by performance
security separate from the long-term stewardship endowment in order to guarantee the financial
resources necessary to achieve mitigation. Grant County already requires a Mitigation Security for
development undertaken prior to the completion of mitigation per GCC 24.08.180, which we
understand to apply here.
Based upon our conversations with the county, it is our understanding that the proposed 75%/25%
split was written largely due to the structure of the site selected for the proposed pilot Mitigation
Bank and will be removed from the final version submitted for review to the Planning Commission.
The pilot bank would manage parcels which are largely existing shrubsteppe and thus most work
activities would be preservation.
It is our understanding that under this policy, credit release schedules will be proposed and adopted
specific to each MBI. We support this policy as we believe it allows for more flexibility in
determining appropriate release schedules. As it relates to release policy, our recommendation is to
structure the credit release schedule to incentivize achieving performance standards, and to require a
Mitigation Security if this is not the case. Accordingly, we recommend striking the language within
section 25.24.140 and replacing it with the following:
25.24.140 Release of Credits
(a) The MBI shall include the process and schedule for the release of credits to the Sponsor
by the County, which shall be tied to performance standards appropriate for the
mitigation activities undertaken. oif �504 Ar laQQ Aftha nraid;+ aanar-Ataj vnpu
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WDFW Comments: Proposed Amendments to the Grant County Unified Development Code
October 10, 2025
Page 6 of 6
Per GCC 24.08.180, mitigation banks are required to secure performance bonds or other
mitigation securities when performing restoration or other similar activities prior to
completion of mitigation.
25.24.150 Performance Standards
We are grateful for the county's establishment of performance standards and a monitoring period,
though we have some concerns on over implementation. Ten years is a short time for monitoring
efforts in the shrubsteppe ecosystem. Sagebrush and Bitterbrush plants take many more years to
establish and grow to a size that confers effective habitat to the many priority species that utilize the
ecosystem. It is not uncommon for restoration efforts to struggle, stall, or fail, and setting an
arbitrary period of ten years confers a significant degree of risk toward the success of the effort.
It is our recommendation that monitoring not be limited to an arbitrary time period. Monitoring
should continue until all performance standards are achieved and demonstrated to be sustainable.
Best practice is to require that performance metrics be met for at least three consecutive years before
the bank is considered successful. Otherwise, there is a risk that short-term gains will be counted as
success, even if the site is not ecologically stable. We recommend:
(a) Performance Standards are tracked over the established monitoring period/bank
establishment period stipulated in the MBI, «T,.;%VX %�T-ni -allyol*es to At least PN 4
and will continue until a minimum of ten years or the desired ecological
uplift is achieved.
We would like to thank you for the opportunity to review and provide comments on these proposed
Unified Development Code amendments. If you have any questions or would like to schedule time
with WDFW staff to discuss our comments, I can be reached by email at brian. aston(cdfw.wa.gov
or at (509) 431-03 3 9.
Sincerely,
Brian Gaston
WDFW Region 2 Habitat Program Manager
cc: Kara Whittaker, WDFW Land Use Conservation & Policy Section Manager
Cole Webster, WDFW Land Use Conservation & Policy Planner
Mallory Hirschler, WDFW Assistant Region 2 Habitat Program Manager
Paul Christianson, WDFW Region 2 Land Use Lead
Eric Pentico, WDFW Habitat Biologist
ATTACHMENT C
Grant County BhrubateopeMitigation Technical Advisory Group
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees -8-
THE PURPOSE OF A TECHNICAL ADVISORY GROUP
A Technical Advisory Group (TAG) is a group of subject matter experts convened to provide.
specialized, evidence -based advice that guides the technical direction, standards, or policies of a
program or organization. It does not usually make binding decisions itself, but its recommendations
strongly influence how leaders design, implement, and improve complex technical work.
Core Purpose
1. Provide expert technical guidance so that programs, policies, or standards are scientifically and
technically sound.
2. Inform strategic and operational decisions (for example, what methods, tools, or priorities to adopt
in a policy).
3. Help interpret complex or evolving evidence so non -experts (managers, policymakers) can act on
it appropriately.
Typical Functions
1. Review and advise on technical documents, guidance, and standards before they are finalized.
2. Identify emerging challenges, gaps, and needed updates in a technical area and recommend
responses.
3. Recommend or assess methodologies and performance measures to ensure high -quality,
effective practice.
Role in Governance
1. Serve as an advisory (not policymaking) body that informs, but does not replace, formal
decision -making structures.
2. Increase transparency and credibility by documenting expert reasoning and providing
independent, evidence -based viewpoints.
3. Support alignment with external standards when relevant.
Membership Characteristics
1. Composed of recognized experts In relevant disciplines.
2. Members are typically expected to be independent, declare conflicts of interest, and provide
unbiased advice in a personal capacity.
3. Group size and composition are chosen to cover the range of expertise needed for the TAG's
remit while remaining workable for discussion and consensus.
Benefit to Grant County
1. Improves technical quality and relevance of policies, programs, and guidance.
2. Helps the County stay current with evolving science, technology, and best practices.
3. Build trust among stakeholders by showing that complex decisions are informed by independent,
high-level expertise.
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees - 9 -
SUMMARY OF THE GRANT COUNTY SHRUBSTEPPE
MITIGATION BANK TECHNICAL ADVISORY GROUP
The Grant County Shrubsteppe Mitigation Bank Technical Advisory Group (TAG) meetings document
the step-by-step development of a pilot shrubsteppe mitigation bank, including goals, policy framework,
credit ratios, monitoring, and governance arrangements. Across six meetings (March 2024—January
2025), the TAG refines county code updates, a mitigation guidance document, and the practical design
of banking instruments, with recurring focus on habitat quality, landowner feasibility, and the role of
WDFW and the Conservation District. [1][2][3][4][5][6]
Overall Objectives and Context
1. Establish a Mot shrubsteppe mitigation bank that is sustainable, economically viable, and
supports preservation and restoration of shrubsteppe while providing predictable mitigation
options under Grant County code.[1]
2. Align the bank with WDFWs Shrubsteppe
prioritizing defense of core habitat, expansion
corridors and connectivity.[1]
Key Policy and Program Design Themes
Restoration and Resiliency Initiative (WSRRI),
of adjacent areas, and maintenance of habitat
1. County Critical Areas Ordinance (CAO) updates (chapters 24 and 25) are drafted and iteratively
revised to codify mitigation hierarchy, ban king/perm ittee-responsible mitigation (PRM), and in -lieu
fee (ILF) options, with deadlines to meet 2024 code update cycles. [3][6]
2. A separate shrubsteppe mitigation guidance document is developed as a "living" resource to
guide future bank sponsors on site selection, habitat types, service areas, credit generation, and
acceptable land uses, distinct from but referenced by County code. [2][3]
Credit Ratios, Economics,!2nd Landowner Feasibility
1. TAG repeatedly discusses credit generation ratios (e.g., 1:1 7 2:1 7 3: 1) and impact ratios, balancing
WDFW's preference for higher ratios (such as 2:1 minimum) with the need to keep banking
economically attractive and competitive with scattered PRM.[5][6][2]
2. - Ratios are stratified by habitat quality and level of protection (e.g., removal of grazing vs continued
use) and are intended to "bake in" ecological uplift while allowing ranchers and landowners
enough economic incentive to participate. [2][1]
Governance, Roles, and Long -Term Stewardship
1. Grant County is positioned as bank sponsor and decision -maker, with WDFW, the Conservation
District, and others participating as technical advisors, not regulators, and potentially transitioning
into an Interagency Review Team —type structure. [3][2][1]
2. Conservation easements or deed restrictions held by a third party land trust or similar entity,
paired with an endowment, are envisioned to secure long-term site protection, monitoring,
maintenance, and response to disturbances such as fire or invasive species outbreaks. [5][2][1]
Monitoring, ILF, and Implementation Details
1. Monitoring concepts include a roughly 10-year intensive monitoring period (varying by restoration
vs preservation) followed by ongoing easement monitoring, with ideas such as drone surveys and
use of WDFW best available science guidance. [3][5]
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees _10-
2. ILF is framed mainly for large-scale projects (e.g., major solar) that could otherwise exhaust bank
capacity at once, with discussion of fee basis (market value of suitable mitigation land), timelines
for expenditure (around six years), and IRT involvement in project selection.[s][s]
1. Grant County TAG 1 Meeting Notes from 3.28.2024
2. Grant County TAG 6 Meeting Notes from 1.14.2025
3. Grant County TAG 3 Meeting Notes from 5.21.2024
4. Grant County TAG 5 Meeting Notes from 12.2.2024
5. Grant County TAG 2 Meeting Notes from 4.22.2024
6. Grant County TAG 4 Meeting Notes from 6.25.2024
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees
f G'Ka""'ANT COUNTY
s
3
Meeting Notes
Grant County Shrubsteppe Mitigation TAG Meeting # 1
March 28, 20241 9:00 - 10:30 (PST)
Agenda /Meeting Notes:
1. Introductions f Attendees -
a. Grant County — Chris Young
b. Consultant Team (Ardurra/Habitat Bank) — Shane Slate, Victor Woodward, Vince
Barthels, Zach Woodward
c. WDFW — Eric Pentico, Ben Turnock, Julia Michalak, Amanda Barg
d. Conservation District — Kristina Ribellia, Kaley Wisher, Harold Crose
e. Local Biologist (Ecosystems Northwest) — Dennis Beich
2. Project Team Goals —
Chris Young provided an overview of Grant County's objectives with this contract to establish
a shrubsteppe (SS) mitigation bank. Ultimately, the goal or purpose of the mitigation banking
program is to support efforts to locate appropriate SS mitigation that is sustainable, is
economically viable, is beneficial to the preservation and restoration of SS Habitat and
provides mitigation options to applicants under Grant County code requirements. Our team
will assess potential mitigation needs in the next 5-10 years, identify most valuable areas for
protection and restoration of SS habitat in Grant 1..0 y, locate and negotiate with landowners
on suitable mitigation bank sites, and develop the banking program framework and
agreements in Grant County. The goal will be to have a "Pilot," mitigation bank approved by
the County based upon the updated Grant County Critical Areas Code related to SS impacts
and mitigation.
3. History and findings of existing TAG -
What consensus has been reached, what are the outstanding issues and questions to date,
what are the biggest challenges?
a. Agency opinions about status of SS in Grant County.
Eric (WDFW) provided some background related to the segmentation of the shrubsteppe
habitats being impacted by development and how establishing mitigation banking could
provide the opportunity to establish/protect more valuable and utilized habitat corridors.
Right now mitigation that is being proposed is in 5 acre parcels that are separated from
other habitats. There are also no monitoring or reporting on most of these mitigation
projects.
b. What are considered the major SS threats in Grant County that would impact
development of a banking program?
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The group mentioned: Agriculture (grazing, chaining to remove shrubs, producers leaving the
NRCS based CRP program), fire, new land development, solar power/support power
infrastructure projects.
Chris inquired on who is the agency with approval authority for a bank of this type? The
consensus was that WDFW would be the main agency driver, but it would do so in a
technical advisory role supporting the County as lead/final decision maker. According to
Habitat Bank, WDFW has been an advisor, and an interagency team member on past
mitigation bank projects in WA state, however they only advise in a technical role or sign
bank agreements in a non- binding way as a sign of support and agreement.
4. Determining Mitigation Hierarchy (preservation vs. restoration actions] -
a. Current strategy for prioritizing mitigation actions (preservation of core habitat,
creating/extending corridors, expanding core habitat etc.)
The group discussed the merits of preservation since restoration/creation of shrubsteppe
habitat is very difficult and has a low rate of success. Vegetation establishment is a challenge
in and lands. A brief discussion was also had regarding consideration of property taxes
implications and other potential consequences to landowners associated with taking land out
of conservation or ag uses and converting it to a mitigation bank.
Amanda provided the following to represent WDFW's priorities, which were taken from
Washington Shrubsteppe Restoration and Resiliency Initiative's (WSRRI's) prioritizing actions:
WSRRI's approach to prioritizing actions within remaining habitat is built around:
Defending high -quality core habitat from encroachment of threats, like development,
conversion, loss due to wildland fire, and invasive annual grasses, must be the highest
priority for WSRRI;
Taking action in lesser -quality habitat surrounding and adjacent to core areas, to
expand the footprint of high -quality habitat; and
Connecting the core, by maintaining open and viable linkages between core areas, will
allow wildlife to move across the landscape and access high -quality habitat, allow for
demographic and genetic exchange between populations, and increase habitat
resilience and viability.
b. Agency input on targeting specific locations for mitigation actions in Grant Co.
Amanda (WDFW) mentioned utilizing the newly added biodiversity corridors in PHS data
and provided the information to obtain this GIS data from WDFW.
Based on the Map that Chris Young shared, the northern portion of the County contains a
large geographical area of SS.
Ultimately Habitat Bank/Ardurra would locate a pilot bank project based on WSSRI criteria
listed above and on the ground knowledge and direction from WDFW staff working in Grant
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County. This could be a bank focused on preservation of very high quality habitat within core
areas or to preserve connected corridors that are critical and under private ownership or
threat.
c. Establishing predictable mitigation ratios based on restoration/preservation actions
for a mitigation bank program.
This topic was tabled for discussion in a future TAG meeting.
5. Site protection, monitoring, and maintenance -
a. What level of protection is needed and what are the options for these protections,
what are allowable or compatible uses, who are potential easement holders?
A discussion of the challenges associated with long term stewardship of protective covenants
(both conservation easements and deed restrictions) was had. This an issue that could be
improved upon within the County though the steps taken to establish a banking program.
Zach from Habitat Bank knows that there are examples of both conservation easements and
deed restrictions being used in other County mitigation programs and this program could
borrow from the lessons learned about long term protection and site stewardship from
alternative mitigation � pr o,VI U s a; id the state banking p ogra�m.
b. Short term monitoring requirements, long term monitoring requirements
Eric (WDFW) mentioned that the current issue with monitoring is that for the most part it simply
isn't happening. However, this is regarding permittee responsible mitigation and a mitigation
banking program would establish a clear standard for monitoring.
c. Maintenance requirements
Discussion of long-term stewardship of protective covenants potential being a challenge we
will need to overcome. Can be accomplished through appropriate endowment.
d. Reporting requirements
This is a topic that will need to be addressed in future TAG meetings as the pilot program
begins development.
6. Next steps and future discussions -
a. Schedule next meeting
April 22nd 1-3 PM PST
Stakeholder groups need to decipher who their representative on the TAG will be to ensure
proper structure. All are invited to participate but a lead for each agency/group should be
assigned.
At the next TAG, the Consultant Team will present a conceptual pilot SS Mitigation Bank
Program for discussion.
3
TAG Meeting Notes 4.22.24
The Biden Administration announced 7 billion in solar funding to be released.
We need to establish ratio structure prior to talking to Landowners since this
would dictate how credits are structured and what the costs are.
MBI Agreement (Bank Sponsor) will be the county. WDFW can sign on as an
interested party if they choose. Amanda mentioned that they are advisory
only and not technical so they would not be able to sign as an administrator of
the banking program.
The conservation easements that are established on the banking ground can
be done in phases but the easement must be managed by 3 rd party. Still no
determination whether this will be the Conservation District or not.
The fee structure should also contain an endowment amount to create and
grow the endowment for future sustainabiLity.
Action Items:
Credit Generation Ratios, i.e. 1:1 1 2:11 3:1, etc.
Costs of mitigation per acre ($$/acre) based on quality and species? The
higher the quality of SS and species - the higher the cost per acre.
This initiative will start out as a Pilot Bank so we don't necessarily need all
information up front and we can change as we develop the program. WDFW
was concerned about not having "their" ratios established until end of 2024.
Think about a Restoration option and how those ratios would work.
Land Trust —do we need one to manage this?
Monitoring Plan:
• Drone Semi-annual observation?
• WDFW (BAS) monitoring/Lands guidelines
• Depends on how the Landis used; protection vs. restoration, grazing,
etc.
Example is a portion was to be used for controlled grazing. The area used for
controlled grazing could have the conservation easement reflect the specific
requirements for this area to be grazed along with the monitoring plan, etc.
We can establish one bank and then use the "umbrella" bank option for future
areas (banks).
GRANT COU
Grant County Shrubsteppe Mitigation TAG Meeting #3
May 21., 2024., 1:00pm (PST)
Meeting Notes:
1. Introductions/Attendees
a. Grant County - Chris Young
b. Consultant Team - Shane Slate, Victor Woodward, Vince Barthels,
Zach Woodward
c. WDFW - Eric Pentico, Ben Turnock, Amanda Barg
d. Conservation District - Kristina Ribellia, Kaley Wisher
e. Local Biologist (Ecosystems Northwest) - Dennis Beich
2. Quick Recap of TAG Meeting #2 and other shrubsteppe related meetings
a. Chris participated in the April 26th wind and solar workshop meeting
and mentioned that the there is uncertainty in how the Least
Conflict Solar Siting tool fits into the picture as it seems to present
solar project practicability issues (proximity to distribution, etc) that
are eliminating its use in Grant County. Additionally, there seems to
be a gap in appropriate guidance and resources for solar projects
on how to properly address cultural resources and correctly move
through the process.
b. Eric discussed a recent WDFW meeting related to the solar/wind
guidance document and mentioned that preparing guidance to
properly quantify and consider cumulative impacts is proving to be
a challenge.
c. Ben mentioned that WDFW had a mitigation related meeting
(internal) regarding the solar/wind guidance and trying to quantify
and identify potential mitigation structures.
3. Draft adjustments to Grant County CAO for Group Discussion
a. Language utilized was discussed and it was mentioned that this is
just our starting point, and it is based off of wetland mitigation
guidance to get the ball rolling.
b. In -lieu fee (ILF) was discussed and how it would fit into this process
and the CAO. WDFW voiced concerns based on past history and
difficulties in implementing the funds and how there is a temporal
loss issue to be considered. It was mentioned that the Oregon White
Oak guidance materials attempt to address some of these
temporal loss considerations and could be an example.
c. Chris mentioned that the County is considering multiple mitigation
avenues to ensure they are able to provide the appropriate
mitigation options to developers of all scales.
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d. Vince requested that the TAG provide input on how an ILF and
other mitigation options should be worded/codified in the CAO.
How do we spell out the steps in a valuable way?
e. Zach brought up that the CAO will reference the instrument(s) that
define how the mitigation bank or ILF program operates. So, the
program itself will be defined outside of the CAO language but be
very thoroughly describe in the banking instrument as the
certification document.
f. Mitigation hierarchy and site protection methods were discussed by
the group and how they fit into the proposed program. It was
mentioned that site protection has recently raised a large amount
of confusion due to lack of codification.
g. Ratios were discussed and how to apply the concept to banking
and RRM mitigation to help emphasize an appropriate mitigation
type hierarchy. Especially as it pertains to the differences between
small scale segmented habitat vs large scale projects with
interconnected habitats.
h. Chris emphasized that the CAO edits need to consider the County's
customers, be consistent, and understandable.
i. CAO edits need to be finalized and in by June 28th to be
incorporated this year.
4. Potential Mitigation Guidance Document Outline for Group Discussion
a. A draft outline of a potential guidance document for Shrubsteppe
mitigation was discussed by the group. This is outline was based off
examples provided in USAGE and Ecology guidance.
b. The big difference in this instance compared to wetland mitigation
banks is that the County is fully the lead without outside oversight
like wetlands have with USAGE/Ecology. In this scenario, WDFW is a
technical advisor rather than a regulatory presence, so the burden
falls on the County to develop a proper shrubsteppe mitigation
framework.
c. This makes development of an Interagency Review Team (IRT) of
sorts all that much more important to ensure the County receives
the technical input it needs to support the banking endeavor. The
role of the IRT was discussed.
5. Potential Monitoring Requirements for Group Discussion
a. Zach presented a high level overview of potential monitoring
requirements. The type of mitigation implemented (enhancement,
creation, vs preservation) needs to be considered with establishing
monitoring requirements. The initial monitoring period may be vastly
different in duration based on the level of change/effort.
It is anticipated that monitoring may not be as rigorous as required
for wetland mitigation banks based on the difference in needs. A
general idea would be a 10 year monitoring period with level of
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monitoring requirements being adjusted by mitigation type. Long
term (past initial 10 year monitoring) monitoring would still happen
through the conservation easement monitoring.
b. Ben brought up how to consider impacts to preservation
components. For example, if you had a fire impact, newly
introduced invasive species taking over, etc. How do we address
these types of impacts? Consideration of funding endowment
insurances for these risks, or other funding opportunities for large
scale fire impacts. The maintenance plan for the bank should
incorporate invasive species control (cheatgrass for example).
c. Amanda mentioned the Shrub -Steppe and Grassland Restoration
Manual for the Columbia Basin (wa.govI which has monitoring
requirements/guidance.
6. Draft Press Release for Group Discussion
a. The press release was presented and briefly discussed. Timing of the
press release was brought up. Chris mentioned that there is currently
a placeholder on the County's website for the program, so he is
working to ensure that Grant County residents remain informed on
our process and that there is a public involvement and
transparency component.
b. Amanda mentioned that WDFW has a communication specialist
and that we could have her review the release and also brought up
the potential of a joint public notice/press release.
7. Next steps and future discussions
a. Schedule next meeting -Tuesday June 25t" @ 2pm PST
b. Action Items - If any TAG members have any comments on the
materials provided and discussed please provide them to the
consultant team for utilization and incorporation in the draft
documents. Please help focus on the proposed CAO edits and any
suggestions.
ARDURRA
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4, GRANT COUNTY
W A S H I N G T 0 N
Grant County Shrubseppte Mitigation TAG Meeting #�4
June 25, 2024, 2:OOpm (PST)
Meeting Notes:
1. Attendees
a. Grant County - Chris Young, Jim Anderson -Cook
b. Consultant Team - Shane Slate, Victor Woodward, Vince Barthels,
Zach Woodward, Chad Kauppi
c. WDFW - Ben Turnock, Amanda Barg, Paul Christianson, Christine
Davis
d. Conservation District - Kaley Wisher, Harold Crose
e. Local Biologist (Ecosystems Northwest) - Dennis Beich
2. Review of Chapter 25.02 definition updates
a. Ben raised a question on the operational life of a mitigation bank as
it pertains to the differences between a shrubsteppe bank vs a
wetland mitigation bank (the wetland banks have more established
standards and monitoring requirements). Zach clarified the
difference I a bank and what
irTerence between the operational i i o'
happens after that point. Basically, the operational phase of the
bank ends when all credits are sold (timeline governed by the
banking instrument), at which point operation of the bank moves
over to long-term management of the protected land.
b. Discussion was had regarding how the mitigation habitat would be
defined (cover, plants, etc) and how it will be maintained. This
included a brief discussion on what will happen if fire occurs in the
mitigation bank site (s) as it regards to fire protections, response, etc.
c. Victor mentioned who is responsible for the operation phase
(sponsor, landowner) but in the following stages (during the
maintenance stage), activities would be transferred to a 3rd party
(land trust for example). Such as any response that may occur after
a fire or other disturbance activities that may occur.
d. Kaley asked if the wording is such that you have to maintain a
certain level of shrubsteppe on the ground or is worded so that
there is an area set aside for Shrubsteppe? Is their allowance for
natural functions and cycles to occur as opposed to us trying to
control the shrubsteppe. Victor mentioned guidance from WDFW
will be utilized in defining that for the mitigation bank within the
bank's instrument.
e. Amanda asked the question on where base definitions come from.
For example, many use Websters. Chris mentioned that they utilize
the Planners definitions and Zach contributed that many were
pulled for WA guidance.
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3. Review of Chapter 24.08 updates
a. 24.08.160(e) (SJ (a) Dennis brought up for discussion regarding the
minimum fee calculation for in lieu fee and the mention of 2-acres
per 1-acre. Victor clarified that the intent of the statement fora 2:1
ratio. Dennis further brought up that as written the ILF seems to
penalize small landowners (whose impact is less than an acre) that
minimize impacts. Chris began a discussion to clarify utilizing a
current solar project nearing review as an example of the large
scale impacts that would require in -lieu fee. ILF is intended only for
those large scale projects which would empty out a mitigation bank
in one shot. Dennis further asked if the fee is based on value of
impacted land or value of potential mitigation land? Victor
responded that the fee would be based on the market value of
potential mitigation land (acceptable shrubsteppe habitat or
mitigation bank site). Looking at only the value of the land that
needs to be acquired for appropriate habitat and the fair market
value of the core shrubsteppe area.
b. Jim asked if the intent within the document for ILF collected fees to
expend those amounts within 5 or 6-years. Vince clarified that it was
intended to be 6-years to mirror similar timelines associated with
traffic impacts fees, etc.
c. Ben asked if the IRT is involved in ILF project/site selection. Chris
replied that the County sees the IRT being involved in evaluations
for large scale project that would utilize the ILF program and where
the mitigation funds may be utilized on the landscape, etc.
d. On the subject of PRM ratios, Dennis raised the question regarding
the 1: 1 ratio for core mapped habitat. How do we ensure that
functions of the impacted habitat are considered vs the core
preservation areas to ensure an equal or uplift in habitat function?
e. Amanda mentioned that Ben is working on an alternative table
regarding ratios and how to approach them. Ben shared his table
and considerations behind it with the group. The approach starts
with the WDFW recommended 2:1 for in -kind and then raised the
ratio for out -of -kind mitigation. Discussion was had regarding ratios
for mitigation banking as it eliminates the temporal loss, etc. Net loss
needs to be considered when thinking about preservation, etc.
which brings in the WDFW consideration of 2:1 even for banking.
f. Zach mentioned that in order for successful banking we want to
incentive use of the banking program, we must be able to show
favorable credit ratios. If all the ratios are 2:1, it does not incentivize
the bank. This will warrant further discussion during development of
the banking instrument for the mitigation bank.
g. Amanda brought up in section 24.08.360(d) it could be helpful to
include reference to utilizing a functional assessment. Such as, the
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assessment provided within the WDFW shrubsteppe management
recommendations.
h. Under 24.08.350(2)(D) Amanda request we don't directly mention
WDFW and utilize a broader statement regarding the applicable
entities.
i. 24.08.160(E) (5) Dennis mentioned adding a section for considering
sensitive/listed species presence to allow the official to increase
ratios at their discretion.
j. Additions to exceptions under 240.08.350 where introduced.
Amanda mentioned instances where defensible space for fire
resulted in extra impacts associated with new developments and
that it should be included in mitigation. For existing structures that
need defensible space it is a different subject and that habitat is
probably highly disturbed already. On the maintenance subject
there are types of "maintenance" that typically involve trenching
which can have large impacts to PHS listed species/habitats.
Therefore, maintenance exemptions can actually have large
impacts so without prior review there can be issues and large
impacts. Burrowing species are the major concern in these types of
activities.
k. Jim brought up ideas regarding 23.08.357 for Solar Energy Facilities
on how to connect it to ILF use. Amanda and Jim will connect
offline to work this subject.
4. Review of Chapter 25.24 updates
a. Presented this chapter which is an outline or placeholder for the
Mitigation Bank Requirements & Impact fees which will be defined
later.
b. Chris mentioned that all of these edits still have to go through the
public process and there will be additional edits/opportunities
through December.
5. Upcoming Planning Commission Meeting
a. The planning commission meeting will be hosted online in August
and it would be helpful to have TAG members to support. The
Planning Commission Workshop is scheduled for August 7, 2024,
from 6:30 to 10:00 PM. The meeting will be available virtually or in
person and if interested in attending virtually you can access the
meeting link from the Planning Commission Agenda on the website:
https:llwww.qrantcountZwo.gov/`Ag ndaCenter/Planning-
Commission-3
/�,r'" ARDURRA HABITAT BANK PLC
TAG #5 M EETI N G N ®TES — 12/2/2024
Habitat Bank reports that they looked at approximately 12 sites in North
County and the BeazLey Hill area and focused on core and species. The
BeazLey Hill area seems the most promising and in speaking with Landowners,
many have already been approached with using their land for alternative
energy options.
* Tough to compete against this
The owners are interested with preserving open space but having the option
for grazing their Land. It is evident that current grazing through Leased options
is uncontrolled.
i
Habitat Bank recommends the Pilot Bank be established in the BeazLey Hill,
area if possible.
• Need to nail down appropriate ratios
• Stewardship
• And whether we want one Large site or several small sites — umbrella
bank format.
It makes sense to do multiple smaller sites as this is what seem ' s to be really
available and also provides f LexibiLity, such as if one bank site experiences a
fire, etc.
We need to focus on the fact that our goal is to have the bank option priority
over the in -Lieu -fee option and permittee mitigation. In order to do this we
need to incentivize the bank and not make the ratios too arduous. Mitigation
Banks are considered the "Gold Standard" in mitigation so we need to keep
this in mind.
Temporary versus permanent impact discussion. Temporary impact is really
permanent impact even though the use and/or impact has a finite duration.
We should not address temporary impacts from this perspective as it will
complicate things. Impacts are impacts.
There are temporary impacts associated with any development and these can
be mitigated through the process, such as Lay down areas and site access.
These areas can be restored once the development is complete and are really
associated with large-scale solar or other complicated sites.
Debit ratios are not recommended to be included as well.
There was a Lot of discussion on the IRT and a Lot of good questions.
• This is hard to nail down a definitive IRT since each project maybe
substantially different where the IRT members need to change
It was agreed that both WDFW and CBCD representation will always be
needed.
Will there be management plan updates, such as with grazing (Haley
concern). There was a Lot of discussion regarding who would write, review and
approve grazing plans. Also, the species element needs to be included since
uncontrolled grazing could upset this. ALL projects would need to have an
"adaptive" management plan that captures these concerns and these are
typical in the banking business.
There was some discussion regarding phase 2 codification and Victor
reminded everyone that we would like to get the PoLit Bank up and running
prior to actual codification.
Question: Should the County's Noxious Weed Board have a seat at the IRT
table?
Next meeting was determined to be January 14 th from 1 to 2
GRANT COUNTY
W A 5 H 1 N G 7 O N
Grant County Shrubsteppe Mitigation TAG Meeting #6
January 14, 2025., 1:00pm (PST)
Meeting Notes:
1. Attendees/Introductions
a. Grant County - Jim Anderson -Cook
b. Consultant Team - Shane Slate, Victor Woodward, Vince Barthels,
Zach Woodward
c. WDFW - Eric Pentico, Ben Turnock, Carmen Andonaegui, Paul
Christianson, Michael Ritter
d. Conservation District - Kaley Wisher, Deanna Elliot, Wade Haughton,
Harold Crose
2. Questions/Comments on Mitigation Bank Guidance Document
a. Ben asked how the document will be incorporated into County
code. It will be encompassed in chapter 25.24. The guidance will be
updated as need or wanted by the County.
b. Ben asked about the credit ratios and how they relate to the
mention of ratios within current code. Vince and Zach explained
that the ratios in the code relate to permittee responsible mitigation
while guidance document refers to the bank only and in particular
credit generation. When the pilot bank is established the banking
instrument will detail the impact ratios required for purchase of
credits to offset impacts. Zach explained how the ratios in the
guidance bake in a ratio.
c. There was discussion of impact ratios/generation ratios and how
they compare to the 2:1 ratio suggested by WDFW. Zach and Jim
provided input on how the ratios need to be set in a manner that
makes it practicable to have applicants actually utilize the bank
over the patch work of permittee responsible mitigation options.
d. Kaley asked if there was a reference source to the generation ratios
selected. Vince explained that we attempted to stratify the
generation ratios based on the habitat quality and imposed
limitations of use. Zach added that WSSRI goals and objectives were
utilized to select sites and to guide the hierarchy of ratios. That
paired with the economics and considerations of the level of
protections was utilized to establish the ratios. Victor added that the
guidance is aimed for future bank sponsors who may establish a
bank within the County. To attract potential sponsors, establishment
of a bank needs to palatable and profitable from a business
perspective. The guidance directs potential sponsors to the correct
land areas, habitat types, etc.
e. Ben asked if the required credits/impact ratios will be included in
County code? Jim explained how these items will be included in the
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guidance. The use of Article V 25.24 will allow the County to put in
how they will require the purchase of credits for impacts to
shrubsteppe habitat, etc. Jim added that the establishment of the
Credit Generation table really affects the ability to talk to
landowners about shrubsteppe banking and the ability to convey
to the landowners what they can still do with their land if they
participate in the bank and at what level the bank would be able
to generate credits in those agreements with landowners.
f. Kaley asked a question regarding the ratio hierarchy when
considering utilizing grazing as a management too/ to increase
habitat and if we should consider flipping our view. Vince explained
that the team considered removing disturbance as more beneficial
in this case. The current generation ratio table is based on the
thought process that removal of grazing will provide higher
shrubsteppe habitat function. Kaley added that landowners who
think of removing grazing will want to know how to reduce
increased risk of fire danger. Zach added discussion related to the
proposed endowment fund that will further protect the land (paired
with the conservation easement in perpetuity) allowing funds to be
available to restore the bank site (s) if/when there are large scale
natural impacts (such as fire, invasive species, etc).
g. Harold and Deanna brought up that the ratios may not be
weighted enough to favor ranchers well enough to be
economically feasible to the landowner to work with a bank. The
subject of grazing was further discussed at length and realized that
there are a lot of intricacies to the subject where grazing in some
cases may be a benefit and others can be a negative.
h. It was mentioned throughout conversations that the guidance
document is intended to be a living document that will be updated
as the pilot bank and available science progresses in the future.
i. Kaley asked about the Service Area section and what the defined
service area is? Currently it is limited to Grant County. Kaley inquired
about future use of nearby Counties such as Douglas and Adam
counties. Vince provided clarity that cross County credit purchases
may be allow but there is more work between the local jurisdictions
that would be involved. Jim mentioned that cities under 25,000
people will soon be able to directly adopt the County's CAO.
j. Kaley also asked about how the protective covenants will stop or
allow modifications to property structures (fences, gates, access
points, watering, etc). Victor mentioned that those flexibilities will
need to be considered and incorporated into the banking
instrument, accepted grazing management plan, and conservation
easement.
k. Ben brought up the following questions:
/��,,.
HABITAT BANK PLC
GRANT COUNTY
fi
W A S H I N G T 0 N
i. Role of the IRT in this guidance -document?
1. Vince mentioned we would like to move the current
TAG to the established IRT comprised of the County,
WDFW, and the Conservation District.
ii. Will the County hold funds for the bank or will it go directly to
the bank?
1. Jim mentioned that in the case of the banking the
County would at most be a temporary hold transferred
to the banking sponsor.
iii. Ben asked if how to hold the bank successful by the County?
1. This will be part of the future process, but one key
component will the 3rd party conservation easement
holder and their oversight. The County could then hold
that 3rd accountable.
iv. WDFW will send us some comments/language
suggestions/questions and we can continue discussing them
at next meeting
3. Next steps:
a. Follow up meeting to continue discussion Thursday 23rd @ I pm-
2:30pm
b. Please send further comments to Vince to help us be able to
respond and discuss at the follow up.
/�� ARDURRA HABITAT BANK LLC
ATTACHMENT D
Grant County Planning Commission Minutes
Grant County Unified Development Code Amendment — Staff Report
File #P 25-0196 — Chapter 25.24 Mitigation Requirements & Impact Fees - 12 -
GRANT COUNTY
PLANNING COMMISSION
Chairman: Bill Bailey
Vice Chairman: Elliott Goodrich
Board Members: Carol Dawson, Patricia Jackson, Richard Leitz and Sandra Marcusen
Secretary: Doris Long
COMMISSIONERS' HEARING Room - GRANT COUNTY COURTHOUSE, EPHRATA, WASHINGTON
AuGUST 7, 2024 @ 7:00 P.M.
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P=Present A=Absent C=Canceled NM=No Meeting Held
At 7:04 p.m. Chairman, Bill Bailey, opens the workshop.
I
Board Action:
Approval of the October 4, 2023, Planning Commission Meeting minutes,
Mr. Goodrich moves to approve the meeting minutes as presented.
Ms. Marcusen seconds the motion.
ACTION: - Elliott Goodrich moves to approve the meeting minutes as presented. Sandra Marcusen seconds the
motion.
Voted on and passes unanimously.
Election of 2024 Planning Commission Officers
Mr. Goodrich moves to nominate Mr. Bailey to retain his position as Planning Commission Chairman.
Ms. Marcusen seconds, the motion.
ACTION: Elliott Goodrich moves for Bill Bailey to act, as Planning Commission Chairman for the year 2024.
Sandra Marcussen seconds the motion.
Voted on and passes unanimously.
Ms. Marcusen moves to nominate Ms. Freeman to act as Planning Commission Vice -Chairman.
Mr. Goodrich seconds the motion.
ACTION: Sandra Marcusen moves for Susan Freeman to act as Planning Commission Vice -Chairman for the year
20240
Elliott Goodrich seconds the nomination.
Voted on and passes unanimously.
Planning Commission Workshop Minutes August 7, 2024
Mr. Bailey informs the audience how the workshop will proceed.
Deputy Director, Jim Anderson -Cook, introduces Vince Barthels.
Director, Chris Young, provides some background information for the shrubsteppe mitigation banking
initiative.:fie explains that a stakeholder working group was established with the intention of providing some
viable otions for customers besides the "' A
"preserve and protecti, options that the Critical Areas Ordinance
p
allows. After a year, the Board of County Commissioners allowed a Request For Quotes in order to retain a
consultant group to perform a feasibility study of the shrubsteppe mitigation bank-. Ardurra, Vince Barthels, and
Habitat Bank LLC, Victor Woodward, are the consultant groups to be hired from that RIF-4Q.
The mitigation bank, is comprised of two components. the framework- and structure, which will be handled by
Ardurra, and the establishment of the actual bank, which Will be handled by Habitat Bank LLC.
Vince Barthel reports that he is the Environmental Services Manager for Ardurra and introduces Victor
Woodworth of Habitat Bank-.
Mr. Barthel presents the following PowerPoint.
HABITAT BANK LLC
W
71 A RDURRA
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Planning Commission Workshop Minutes 2 August 7.2024
• Atypical 5-acre parcel owner, constrUCtS
a homestead across 2.5 acres of
shrubsteppe habitat.
• With a 1:1 conservation ratio we end
with a net loss of 2.5 acres and the
fragmentation of the remaining 2.5 acres.
• This process gets repeated...
A` The fragmentation and net loss compoun
slowly degrading the habitat.
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This is a depiction of a -basically common dte-velopment scenario -where a -)-acre piece of land is being
developed. The developer we. ould like to preserve or coif see
cove, about half the property. As that keeps on
_j V Ott re loshrubsteppe and the properties become fragmented from the rest of the habitat. As
reoccur g. incI Z�
history has basically presented, it becomes more and more ineffective.
Washington State
��►� pIriaCOmerce
WAC 365-196-830 — Protection of critical areas.
• Desicfnation of critical areas and the adoption of regulations for the
protection of such areas.
RCW 36.70A.172 — Cr RdGai. areas designation and protection
include the best available, science in devetoping policies and
fa
deveatopmeInt regulations to protect the functions and values of critical,
areas,
A 0 1- Cu, nty and the
aricuLtural Uses are not exempt, however, Grant o
Columbb Basin C'onservation District participate in the Votuntairy
St-ewalrdship Program (VSPI-Work Plan and Monit[orin_ Plat'l,
American Badger
These WACs essentially lay the foundation for what's being discussed . critical areas and protection.
I '.
Planning Commission Workshop Minutes Auoust 7. ?0')4
a Chapt-er 24.088 - Critical Ar�Cas Ordinance
I -r
Chapter 25.24 — Guidance Frat tework
0 'nitions
Chapter 25.02- Defi i
These a -.re the Code sections to be discussed toni(,�ht-
4_
TAG (Techni aL Advisory Group)
• County Building and Planning
Division
• WDFW (Washington Department of
Fish and Wildlife)
Conservation District
• Development Community
• Grant County PIED (Public Utility
District)
igebrwSh S0j-rrbwIN
.0
Ao
49
_k
Sage Thrasher
Through a series of four meetings, this group helped to develop and vet some of the ordinance modifications
that are to be presented.
Planning Commission Workshop Minutes 4 August 7, 2024
W ashington Shrubsteppe Restoration &
Re s i Li e n cy I n iti ative
30-year Strategy
The "Core" Principle
• Defend the Core
• Grow the Core
• Connect the Core
N
-J
Sagebrush Lizard
In 2021 WDFW came out with the Washington Shrubsteppe Restoration and Resiliency Initiative 30-year
Strategy. With the WSRR1 they also developed maps to map the Core Areas; the Growth Opportunity Areas for
the Core and the Core.
jL.1
Five Key Elements
* Community Engagement
* Habitat Protection
Habitat Restoration
Species Management
Fire Management
• Conversion to Cropland
• Wind and Solar Power
Residential Development
Soil Disturbance
Invasive Plants
• Increased Fire Frequency and
Intensity
Excessive Grazing
Roads and Transmission Lines
These are some of the threats to shrubsteppe. The focus tonight will be, for the most part, on development,
Whether that's residential, commercial., industrial or even other infrastructure, solar, wind. etcetera.
Planning Commission Workshop Minutes 5 August 7, 2024
Zn
Current: On -site 11
• Avoid
• Minimize impacts
* Restore
• Reduce by
preservation
• Compensate
to Monitor
Permittee Responsible Mitigation
• Onsite
• Prevention with enhancement
• Prevention only
• Offsite
• Prevention with enhancement
• Prevention onLy.
Proposed: In -Lieu of
Fee or Banking
• Pay a fee in Lieu of the
impact
• Purchase bank credits
Many of these amendments apply directly to Chapter 24.08 and Chapter 25.24. The first column is what is
currentiv contained in Chapter 24.08, 1:1 on site preservation. The slide below represents mitigation
Z=1
sequencina, which means avoidance. minimize and rn'tiorate. WDFW has a blanket statement on unavoidable
tr I
impacts to shrubsteppe, and they prefer a 2:1 ratio.
The middle column is Permittee Responsible Mitigation and is broken into two different subsets, Onsite and
offsite. These are in turn broken down into two subsets, preservation, which means the ground is locked up in
perpetuity with. no other development in the area., or with enhancements. Enhancements could be weed control,
plantings, fencing, possibly signage.
One thing not mentioned on the slide is rehabilitation or restoration, which could possibly be replanting a farm
Meld. into shrubsteppe vegetation.
The right-hand column covers proposed In -LieLt of Fee or Banking. Currently there is only one option; I : I on
site or offsite. A few more options are being presented to bring forth consistency and streamline the process,
through pen-nittee responsible on site or offsite, and the In -Lieu of Fees program that would ultimately feed into
a banking program
Planning Commission Workshop Minutes 6 Auaust 7, 2024
Mitigation is accounted for at a 2:1 ratio in another approved location
This represents the most accepted mitigation ratio that is endorsed by WDFW- a 2:1 ratio. If a 10,000 square
feet area is being developed, a 20,000 square feet mitigation area will be necessary.
Permittee pays a fee to a designated third party.
This will evolve into and sustain the mitigation banking program
These are generally -facilitated through a Developer" s Agreement, which has regulatory oversight by the County
With input from WDFW. A fee per acre is established depending on the habitat that is goinp, to be impacted. The
fees that are collected can be used for conservation, and specifically a banking program.
Planning Commission Work -shop Minutes August 7, 2024
THERE IS A COMFIED PROCESS FOR, WATER AND WETLANDS BUT NOTHING FOR HABITAT CRITICAL AREAS (HCAS)
CY0
Bank Site SeR Credits
Restored Habitats
Pay for Credits
mitigation Banker
Permittee
-o-1
-;ncy to i-niflate a pilot I wnic'rl that establishes a shrubsti. er)pe batik. '11 _e Col-tntv �N' fld Na
.eii,pf
G Ir a Ini t C r% 1 1 R. An fl_A' s 9- It. A e_ I 1 t. S.
th-.,--, re( tilato-ry7 oversight with inpUt ti'0111 WDFW, the Conservation District and other stakeholders.
lutbat-,& is
Me service area is oenerall-y a aeographie area that is being de Pvelo ed, and woud title he bank. Thle
typdeal 1v a large site that could be 1,000 acres or better. UaAA-
tilizing a bank gets 'ay ro fm the off`.-sitepermutee
respo-tisib le, mitigation, that is checked boar ded and fragmented. It is consolidatino resources into a much larcTer
ee
or a developer to use the bank is that once the f
ner Y'"
site. IC Ua�,�,� is ge I ally held b third party. The bene! t E
is paid, arn-a approved by the regulatotir official, the liability for mitigation is removed f rom the developer and
transfers to the bank. The bank can be composed of land owned by the bankerand land o-%'--V'-ned in a
conservation easement.
Planning Commission Workshop Minutes 9 August 7, 2024
Shrubsteppe acres
lViiiigation Ratios .are Dependent on Location and Shrubsteppe
impacted
Claseificstion (Required mitigation area : impact area)
Mitigations Actions = Preservation with Enhancement or Re-establishment
Shrubsteppe or other
Shrubsteppe Classification
Core
GOO
Corridor
haVAnt(outside of core,
GOA and corridors
Core
2:7
2:1
3:1
4:1
Grawth Opportunity Area (GCA)
21
2:1
2:1
3:1
Corridor
2:1
2:1
2:1
2:1
Shrubsteppe or other habitat
(outside of core, GOA, and
2:1
2:1
2:1
2:1
corridors
Mitigations Actions ;.:Preservation 0nly
Shrubsteppeior other
Shrubsteppe classification
Core
GOA
Corridor
habitat (cutside of core,
----GOk and corridors)
Core
2:1
3.1
4:1
6:1
IGOA
2:1
2:1
3:1
4:1
Corridor
2:1
2-A
2:1
&1
Shrubsteppe orother habitat
{outside of core, GOB and
2:1
2:1,
2:1
2:1
corridors
This table was vetted through the TAG working groups. w ►Fw had some input on the development of the
table. This goes back to the 3 mapped areas mentioned earlier. In the first column the mapped areas are the
Core, Growth opportunity Area and Corridor. The table tries to focus on where the impacts are occurring.
The mapped area must be validated though a habitat assessment. The map is only a visual tool.
This only pertains to permittee responsible mitigation.
For enhancement mitigation, if the properly is located in the Growth opportunity Area and the offsite location
is in the Corridor, the swap would be 2:1. That is assuming there is some enhancement being done.
If mitigation property was being purchased for preservation only, then the ratio would be 3:1.
For permittee responsible mitigation measures, the ratio varies from 2:1 to 6:1. The ratios are dependent on the
quality of the shrubsteppe; Core being the highest, Growth opportunity Areas are second and Corridor is third.
Planning Commission Work -shop Minutes 9 August 7, 2024
• Shrubsteppe is an important 0 More options to protect and mitigate
ecosystem that needs protection. are needed for sustainable growth.
Current mitigation options are not enough. 0 Establishing a Mitigation Bank will allow continued
• Bring consistency growth without compromising critical habitat.
ALI Incorporate best available science
Streamline Permitting Process
t
Sage, grouse
Shrubsteppe is important habitat. The intention is to bring forth additional mitigation options that provide
development options that are viable to help preserve shrubsteppe. The proposed options incorporate best
available science, and involves regulatory agencies,, to ultimately establish a process that brings consistency and
streamlines the process.
Discussion follows the presentation.
Mr. Bailey asks where is the mitigation ground going to come from? If it is farm ground, that would be
counterproductive to -what Grant County is all about.
Mr. Woodward explains WDFW is a big player in this entire process. They are d1rectinv, a lot of the actions,
both at the County for regulating, but also on how to properly mitigate for the impacts. The strategy that they're
wanting adopted is to focus on the high. -quality Core shrubsteppe areas, and preserve those through the
mitigation process. It isn't to convert agricultural land through this process. WDFW really wants to find the
corridors, and the areas of high quality shrubsteppe, that might be at risk for conversion and protect those areas
through this mitigation process.
Mr. Bailey asks if this ground has been identified.
Mr. Woodward replies that the TAG groups are working to gather the information and provide direction on
t:� L-*�
where to look for the property. Conversations are starting to happen with landowners in the areas that they
believe WDFW would be most interested in having protected. Part of the challenge of creating a bank is
satisfying the needs of the County and doing it in a way that is agreeable to WDFW.
doing,
is a great deal of discussion related to the mapped shrubsteppe areas of Core, Growth Opportunity Area
and Corridor, mitigation ratios and how they are applied during the development of property, the Critical Areas
Ordinance and the land banking process.
Planning Commission Workshop Minutes 10 August 7, 2024
Harold Crose, Senior Technical Advisor with the Columbia Basin Conservation District, explains how the
Voluntary Stewardship Program interacts with some of the discussions taking place.
Agricultural lands and activities were not subject to any of the critical area requirements until July of 2011
when the Supreme Court of Washington determined .that agricultural lands are subject to critical areas. The
Growth Management Act states that those land have to be maintained at the same level as July of 2011.
There are ways of determining the quality of rangeland. He worked with the Natural Resource Conservtion
Service for 41 years. Through the soil survey and range management efforts, a scale called the Ecological Site
Description for Rangelands was developed. This scale could tell a person what would have been on a site pre -
entry of development in pristine condition. This is important because if the County were ever to use a gradation
system, or determine what land is worthy of investing public or private dollars into enhancement, this scale
would determine what the condition would be.
Currently 75% of Grant County rangelands are deteriorated well beyond what an Ecological Site Description
would determine should be there due to invasive species. He believes a 6-8 inch precept zone is better off left
alone, than to disturb it anymore. The likelihood of rehabilitating the ground back to what it had been in past
history is minimal at best.
Additional discussion related to protecting shrubsteppe habitat and how it would be enforced.
Mr. Goodrich asks Staff what the goal date is to have the changes implemented.
Mr. Anderson -Cook answers the formal hearing for all of the proposed UDC amendments will be held October
2nd with the Planning Commission. There are 9 UDC amendments, and tonight they are discussing 3. Another
workshop will be held in September to discuss the other 6 amendments, which should go fairly quick, but they
better do this one again. The Planning Commission needs to provide him with some guidance, so he knows
what they want to act on during the October 2nd hearing.
Mr. Bailey continents that this is going to restrict development, whether it be homes, dryland wheat, or even
solar. who is really going to make the rules? Are the rules already established and the Planning Commission
doesn't have a choice, or do they get to have input as to what is going to be part of the Code? He has watched
Washington Department of Fish and wildlife for 35 years and every time development comes up, they have a
negative comment. The Planning Commission did not receive information to tell them how many acres of
shrubsteppe habitat are in the County, and how many of those acres are State, federally or privately owned?
What is Core or Corridor? The Planning Commission needs to have this type of information, if for no other
reason but to help -therm understand what is being talked about. when he first looked at the information ernailed,
he didn't know how the Planning Commission was going to do something like this, and it didn't seem to fit. He
still doesn't understand it well enough to say that it does fit. His inclination is that the Planning Commission
needs to change it. They need to snake sure the changes are something they can live with as a Planning
Commission making a recommendation to the County Commissioners, and be able to face folks, friends,
neighbors, business associates, whoever and say -we did this for your own good. He is having a hard time with
that and wants a lot more information. More workshops are needed. Asa Planning Commissioner, he wants to
snake sure that when they are done, they get the best deal they can make for the people of the County.
Mr. Goodrich states that he agrees with Mr. Bailey. He sees their opportunity as being in the ratios, because
they aren't taking away options, but adding an option. As the first people doing this process, it is important to
push as hard as they can to get the ratios as low as possible and provide as many options as possible for
mitigation.
Mr. Bailey states he is concerned that the citizens of the County are not going to be aware of what is happening
to their property.
Planning Commission Workshop Minutes .11 August 7. 2024
Mr. Young replies that it is important to understand that this initiative is brought forward by Staff. It isn't
mandated by State statute. Staff will provide the information that has been requested.
Deputy Director, Jim Anderson -Cook is presenting the proposed amendments for Solar Energy Facilities. He
explains he feels it is important to highlight a strike out in Chapter 23.08.3 )57 Section 1-1. He reads the following
proposed strikeou-t: "Additionally, solar energy./acilities that will hnpactfish and wildlife habitat areas, including but not limited to priority habitat areas, must comply -with the protection and mitigation requirements
fiound in the [Vashington.De partment of Fish and TVildlifg TVind Power Guidedines published in April 2009, or
as amended hereafter.
These (Yuidelines are changing and will be published in December of this year. The tables that were presented to
the Planning Commission are lesser than the tables that will be in the new wind and solar guidelines.
Mr. Anderson -Cook continues to read "In the event a solar energy fiacilily proponent chooses to utilize thefte
in lieu prograin of must be identified as the
,t�red by) TVDFW TVind Power Guidelines, a qual�fying entity m
recipient of thefitnd-s% The quali�ing recipient mitst be a bonafide and verifiable conservation oraanization
within with specialization or focus on lands and habitat conservation. " This does not exii,st so this is what they
are trying to stand up.
The people who would like to develop solar do not have the option to do a pay in lieu and enter into a binding
agreement with Fish and Wildlife. This is a tool to use to mitigate if a project is impacting critical areas.
Mr. Anderson -Cook presents the following PowerPoint.
Planning Commission Workshop Minutes 12 August 7, 2024
SOLAR ENERGY FACILITY- 23.08357
Defined limitations on parcel area conversions for non-agricultural
uses.
Amended setback distance from residences.
Amended to reflect changes to Grant County Critical Area
Ordinance and updates to WDFW Wind and Solar Guidance.
Amended to include baseline site assessments and soil monitoring
for decommissioning agreements. —_
Parcel Area conversion Limits
Current code only considers permanently placed structures, ie.
Slabs, footings, posts, columns, etc. towards the 20% conversion
limits for AG Rangeland and Dryland. This is industry standard and
widely used by Energy Citing Councils nationwide.
Proposed changes to the code would require the Solar Panel that
cantilever's it's supporting structure to be taken into consideration as
part of the 20% conversion limitation.
In both cases, the conversion limits are on aparcel-by-parcel basis
and would include parcels that contain Battery Storage facilities,
Substations and Operations & Maintenance Facilities. _Ao.
To ca.] culate the so Liare feet of a parcel of AG land being converted under the current (-'ode,, the ..t z sq. ii.
col u-.tniis supporting the solar rack, which are at'25' on. center, would. be counted over the parcel area.
1) j area.
As proposed, the 26.,.)-' sq. ft. of the solar panels would be counted and calculated as the conversior
This is an example of a proposed solar prqjject demonstratincy the conversion of around uncter tne currem tocte,
compared. to the proposed Code.
cyust -1.
Planning Commission Work -shop MAu
Minutes 14 t:: 7, 20'24
Parcel Area Conversion Limits
Example Project — 2,061 Acres across 8 Parcels
Current Code — 1,110,727 sq. ft. of converted lands, all parcels
compliant.
Proposed Code — 34,572,000 sq. ft. of converted lands, ONE parcel
compliant, not to industry or Energy Citing Council standards.
It's important to keep in mind that the intent of the code was to reduce
the impact to be able to return the lands to their original condition
upon decommission, or as near to as possible.
Setback Distances to Residences
Nonparticipating Residence: a residence located on nonparticipating
property that is existing and occupied on the date an application for
a permit to develop a specific project is filed with the County.
Proposed: In no case shall any component of a solar energy facility
be constructed within 1,000 feet of any nonparticipating residence.
Current: In no case shall any component of a solar energy facility be
constructed within 100 feet of any off -site residence.
z-ct dc-monstnafincy the' potential impact to a project wnen ine
T his is an exam.ple ofa proposed solar pjoj,,,,, %,111 LL xl.-Lc� I.X-L Y%.
proposed- setback. distances to residences are applied.
The participatlino and nonparticipating latiauage is important, because there. are landoN-v-ners that choose to live.
in the middle of the solar development.
Create a baseline assessment so the site can be returned to the condition it was betore tne sour cieveiopment.
Planning Commission Workshop Minutes 16 August 7, 2024
ENERGY STORAGE SYSTEMS - 2108,A65
New allowed use in certain zoning designations via DUP or CUP.
Either stand alone or co -located with a Solar Energy Facility.
Typical stand alone is interconnected to an existing utility substation.
By storing energy during times of excess and dispatching during
times of need, energy storage increases reliability and controls costs
for Grant County consumers.
When co -located with a Solar Energy Facility, energy storage
systems dispatch energy to the grid when demand is higher or solar
generation is unavailable, such as night or days of cloud cover.
ENERGY STORAGE SYSTEMS - 23.08.165
Energy Storage System facilities of any size shad be an allowed
use, subject to discretionary review, in certain zoning districts as
specified in Tables 3, 4 and 5 of GCC § 23.04. As specified in Tables
37 4 and 5 of GCC § 23.04, Energy Storage System facilities with a
nameplate rating that exceeds 10 Megawatts (MW) shall require
conditional use permits in the same zoning district. In addition to the
energy storage devices, an ESS may include other accessory
structures and equipment including substations, switchyards,
electrical infrastructure, generators, distribution lines,
communication infrastructure, transmission lines and other
appurtenant structures or facilities. _
T tir
i
. Tlico e mmuniClation anct e
his s a..." example of a battery storage system. It is very sophisticated technol-ou.
in is
C, of the art. The Washington. State Fire Code,
protection systems that are buill inside of the cabarc tat se
adopted this vear, contains elements specifically targeting energy, stora(ye systems.
Discussion takes place.
Mr. Goodrich comments that he -finds it odd that more restrictions are placed on. a solar prolect than a dairy or
feedlot, which would have a larger impact than solar would.
Ms. Marcuseji states that she attended a PUD nneeting where it was said that by 2030 they were going to be
z::�
carbon neutral by using solar. She is pro -solar and feels it would be advantageolus to add to the power.
(Mr. Anderson -Cook explained earlier that EFSEC (Energy Facility Site Evaluation Council) is a State agency
that developers have the option to go to for permitting and site enerav facilities, thereby circumventing Countv
processes and Codes.)
Mr. Anderson -Cook points out that WDFWs recommendation for proposals that are being processed through
EFSEC, are the same proposals as permitting through the County. Staff prefers that the proposals be processed
through the County offices to keep the permit revenues in Grant County and allowing their input on the
projects.
The proposed mitigation amendments presented earlier are important to solar development. A solar
development is going in front of the Rearings.Exam.iner next week, with. 995 acres of shrubsteppe being
impacted, and because of this initiative there is the opportunity to do pay in. lieu.
Discussion takes place among Staff, the Plarming Commission and audience members, which. includes how the
I
mitigation fees would be calculated, what ability the Planning Cornmissi*on would have in modifying the
-1
proposed amendments, and why make the solar regulations more restrictive.
Planning Commission Workshop Minutes 48 August 7, 2024
PatrIck Boss cornments that lie represents scl-verall Po-11 Dis-IrIcts in the County,. Couln-tv need.-s more ower
P
solar is he only anwe.A coupe off D icts arelookI 'ng at dni g %owewcorn*nd c-% cle gas
4
Wirbines. and sollar, and bw,-,L-erieF-.. Larae pr(-:�;ects, su(.,,'-,. as ste-el' n.-i.anuffictui,ers. and processors. are currently
looking atro-ijuld the Cour-olLy, and if the Coturav doesn't'n-ave molre power they` are (yoing 'to mIss ot-tt on. -it
ef
v for opportunitgro�mth.
"I z::),
DisIC-lussion takes place rePi'ardin-o the nee�,-J to be able to store energy and nnaximize the energv productiol-I
capatv
f
T d like to see other t�--rpes of energN--y storacye inctude.d, along wi-th battery
ivIr, Baile-3v comments that he woialcl
storaa e.
General discussion take place.
Mr. Bailev, closes the work-shop al 9: 22 pm,
v
Respectfully submitted:
Long, Secreta, yl
Appro-ved b-ly
Y
Hill Bail-ev, Chairmap,
Pla,nning Commission Workshop Minutes .19 Au54ust 7. 20-2.4
GRANT COUNTY
PLANNING COMMISSION
Chairman: Elliott Goodrich
Vice Chairman: Bill Bailey
Board Members: Carol Dawson, Susan Freeman, Patricia Jackson, Richard Leitz and Sandra Marcusen
Secretary: Doris Long
COMMISSIONERS' HEARING Room - GRANT COUNTY COURTHOUSE, EPHIIZATA9 WASHINGTON
NOVEMBER 59 2025 * 7:00 P.M.
'?n?'; A1l-tPnr1;;nrtn
NAME
JAN
FEB
MAR
APRIL
MAY
JUNE
JULY
AUG
SEPT
OCT
NOV
DEC
BAILEY
NM
NM
NM
NM
NM
NM
NM
NM
P
P
P
NM
DAWSON
NM
NM
NM
NM
NM
NM
NM
NM
A
A
A
NM
FREEMAN
NM
NM
NM
NM
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NM
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P
P
P
NM_
GOODRICH
NM
NM
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NM
NM
NM
NM
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Zoom
P
P
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JACKSON
NM
NM
NM
NM
NM
NM
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P
P
P
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LEI17
NM
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A
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MMCUSEN
L
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P=Present A=Absent C=Canceled NM=No Meeting Held
At 7:00 p.m. Chairman, Elliott Goodrich, opens the workshop.
Board Action:
Approval of the Planning Commission Meeting minutes.
Ms. Freeman moves to accept the October 8, 2025 minutes as presented.
Ms. Jackson seconds the motion.
ACTION: Susan Freeman moves to approve the October 8,2025 meeting minutes as presented.
Patty Jackson seconds the motion.
Voted on and passes unanimously.
Planning Director, Jim Anderson -Cook, explains that the workshop will begin with Shrubsteppe Mitigation
Banking, which was previously presented as file P 25-0196 for the purpose of standing up Grant County
Unified Development Code Chapter 25.24 — Mitigation Banking and Impact Fees.
Chairman Goodrich clarifies the purpose of the proposed Code revision. This is to simply establish the
structure. It's not the Code that will establish the ratios that people have to use to mitigate for their projects.
This is how credits are created, not how credits are used.
Mr. Anderson -Cook reinforces that Chapter 25.24 would create the framework for bank establishment and
governance, while project -level mitigation ratios and usage live in Chapter 24.08 (Critical Areas Ordinance) and
other guidance, which includes in -lieu fee mitigation and "Table 5" for on -site and off -site mitigation.
Consultant Vince Barthels, Northwest Environmental Services Director at Ardurra, presents a PowerPoint and
explains mitigation banking as being a sponsor who restores or preserves a site and generates credits; permittees
buy credits to offset regulated ecological impacts; and a regulatory body oversees establishment, operations, and
long-term stewardship. The central instrument is the Master Banking Instrument (MBI). It is the enforceable
proposal a sponsor submits to the county. An MBI is where the ratios by which credits are generated are
established via site -specific, restoration -type tailored credit generation (shrubsteppe restoration vs.
preservation). He states that those ratios do not appear in Chapter 25.24 itself.
Planning Commission Workshop Minutes 1 November 5, 2025
Mr. Goodrich clarifies that the ordinance dictates how someone applies to create a bank. The negotiation during
MBI review determines how many credits your acres would generate. Then you're at liberty to sell those credits
to projects that need them under the Critical Areas Ordinance. The market value is not set by the County;
technical review governs credit quantities, while the Critical Areas Ordinance governs project -level usage
ratios.
Mr. Bailey asks whether banks own their sites and how large they should be.
Mr. Barthels answers generally larger, 1,000 acres or better, but notes that smaller scales may be feasible.
Mr. Anderson -Cook reports that a banking sponsor is "champing at the bit" to pilot a bank on approximately
1,000 acres consisting of approximately 750 acres held in CRP and 250 acres of core shrubsteppe. The sponsor
is planning on active restoration, the placement of a conservation easement, and operating as a for -profit bank.
Mr. Leitz asks about wildfire risk, what happens to the credits when the property bums.
Mr. Barthels describes standard instruments that are used to protect the bank such as conservation easements,
long-term stewardship, and dedicated endowments designed for restoration and contingencies.
Mr. Anderson -Cook confirms that this ordinance will establish that when a person applies, they must have a set -
aside endowment.
Mr. Leitz asks what percentage of Grant County has to be shrubsteppe to satisfy Fish and Wildlife.
Mr. Anderson -Cook explains the purpose is not to hit a number, but to provide tools to help customers mitigate
shrubsteppe disturbance. There are 3 possible tools, which are to mitigate on or off site, do an in lieu of fee
under a Development Agreement or a mitigation bank.
Mr. Barthels provides a list of key terms.
• Regulatory Agency — is Grant County.
• Interagency Review Team (IRT) — is composed of the Planning Department staff, possibly consultants
or may be an agency such as WDFW, or the Conservation District.
There is discussion regarding the Interagency Review Team (IRT); who participates, how it functions, and how
conflicts are managed. Draft language identified the County (Planning Director as Chair), County staff or hired
consultants, and "may include" agencies such as WDFW or the Columbia Basin Conservation District.
Mr. Goodrich would like to add optional representation from commercial interests, like 9
developers, agriculture,
_L 1
or related groups, as long as it is in general terms and at the Planning Director's discretion.
Mr. Anderson -Cook cautions the more that are involved, the harder it is to get consensus, favoring the "may
include" structure that preserves flexibility and discretion.
The Planning Commission suggests removing named agencies to avoid locking the process. They would like to
see "Other relevant parties as deemed appropriate by the Planning Director," which would enable inclusion of
geologists, biologists, cultural resource experts, or Tribal consultation.
The Planning Commission and Mr. Anderson -Cook agrees on the following language: "The Interagency
Review Team consists of the County as the IRT Chair, County - designated staff or hired consultants, and may
include other relevant parties as deemed appropriate by the County Director."
There is discussion as to whether mitigation banking would "decrease land balance" for agriculture or erode
values. It is noted that the mitigation bank would be Rural Resource non -irrigated land, lower productivity
ground.
Planning Manager, Michelle Mercer, explains that in Benton County there is another taxing designation, Open
Open Space, that could be a better economic value than Current Use for farmers not using particular parcels. If
the County chooses to establish that program, landowners could get mitigation revenue plus better tax
incentives.
Mr. Barthels continues covering the key terms.
Planning Commission Workshop Minutes 2 November 5, 2025
• Mitigation Bank Sponsor — the individual or party who is accountable for the bank site.
• Site Selection — 10% of Grant County is in poor habitat, so the banks will likely be in poor habitat.
• Prospectus — is the proposal, the first step, the preliminary plan.
• Mitigation Banking Instrument (MBI) also called the Master Banking Instrument — is the master
document. It contains everything from baseline conditions, surveys, what the plan is, how it is going to
be monitored, and performance standards. It is the blueprint for the bank.
• Service Area — is Grant County.
• Performance Standards — generally have to do with planting. Performance standards are attributed to
vegetation and habitat structure.
• Permanent Protections — perpetual endowment funds and bonding.
• Long-term Stewardship - endowments are typically stewarded by nonprofits, accruing interest,, designed
to finance restoration.
• Credit Ledger — is like a checkbook ledger managed by the County. For example, if the MBI is targeting
100 credits, an initial release might be 25% of the ledger, with staged releases contingent upon
performance standards being met as negotiated under the MBI with County oversight.
• In Lieu of Fees Program (ILF) — collected in lieu of fees money can be applied to a banking program.
There is discussion related to the In Lieu of Fees Program. ILF funds paid by developers are held in escrow by
the County and may be applied to items such as plantings, studies, or IRT costs. ILF-funded improvements must
be deducted from the bank's ledger to avoid double counting. The amount of cash used is equaled to credits and
wiped off the credit ledger.
Mr. Barthels briefly summarizes the 6 articles of Chapter 25.24.
1. General Provisions: provides the purpose, establishes Grant County as the authority and the IRT
composition.
2. Certification Process: what is in the prospectus, what is in the MBI, what are the public notice
requirements for a bank site.
3. Bank Establishment: how the site is selected, what are the performance standards, and how the credits
are generated.
4. Bank Operation: what is the maintenance, what is the monitoring, and how is the ledger reviewed.
5. Use of Credits: how and where credits are applied to the service area.
6. Compliance: enforcement mechanisms to make sure the mitigation bank sponsor is held accountable to
their MBI.
Chapter 25.24 governs bank establishment and operations, including the application process via the MBI; how
credits are generated, tracked, and transferred; oversight and compliance; and long-ten-n stewardship via
conservation easements and endowment requirements. It does not set project -level mitigation ratios, determine
credit market value, or compel usage, those functions remain with Chapter 24.08 and the marketplace.
Mr. Goodrich would like to discuss tokenized credits. He explains that he is concerned about solar farms as they
are not indefinite, while bank credits exist in perpetuity. Each credit should be assigned a unique token in the
ledger signifying ownership of the credit. When the life cycle of the solar farm ends, and the site is reverted
back to its original state, those credits should be able to be sold to whoever needs them. There is an infinite need
for shrubsteppe ground to be preserved in perpetuity, so there needs to be an instrument in place to prevent the
credits from disappearing after the project that required the mitigation is finished.
The Planning Commission, Mr. Barthels and Mr. Anderson -Cook discuss the concept.
Planning Commission Workshop Minutes 3 November 5, 2025
Climate Resiliency Element Update: House Bill 1181
Mr. Anderson -Cook introduces Annie Murai and Kara Odegard, of Measure Meant, who are consultants that he
has been working with for a climate resiliency update to the Comprehensive Plan as required by House Bill
1181. Ms. Murai and Ms. Odegard are attending and presenting via the Zoom platform.
Ms. Odegard explains that this is part of the Growth Management Act (GMA), as amended in 2023 by House
Bill 1181, which requires that all Planning jurisdictions include climate considerations in their Comprehensive
Plans. Grant County must adopt a Resilience Sub -Element. The work is funded by the Climate Commitment
Act and is administered through the Department of Commerce. The plan that is being developed for Grant
County is a community -driven plan.
The three requirements for the Resilience Sub -Element:
• Addressing climate -related hazards.
• Protecting natural areas critical for habitat.
• Ensuring community resilience - protecting people, infrastructure, and economic systems.
The eleven sectors the state highly encourages evaluation of:
• Agriculture
• Buildings and Energy
• Cultural Resources & Practices
• Economic Development
• Ecosystems
• Emergency Management
• Human Health
• Transportation
• Waste Management
• Water Resources
• Zoning & Development
The contract period to produce the County's draft Climate Element is from January — December 2025.
Ms. Murai explains the Climate Advisory Team (CAT) is made up of interdisciplinary experts across the eleven
sectors, including city representatives and planners, Public Works, experts in natural resources, energy health
and wellbeing from throughout the County. The CAT met monthly and chose to co -create the process and help
do the work. Four focus group sessions were hosted across the sectors covering infrastructure, economic
development, community and health, and natural resources to validate vulnerability assessment results and to
brainstorm policy solutions. One on one informational interviews were conducted with those who couldn't
make the commitment to the CAT, or if additional expertise was needed, including four Tribal representatives.
They participated in the Umani Festival (a Hispanic heritage festival) in Moses Lake where over 100
participants took a survey and responded with open ended ideas around what policy solutions would support
them in addressing temperature and precipitation changes. They also have a few "meetings in a box" scheduled
so that community -based organizations can facilitate conversations with their constituents and then provide
feedback.
The Climate Impact Report is the backbone of the project and all of the data in the Report is available on the
Planning Department's website. The primary climate drivers for Grant County include the projected increase in
the frequency and duration of drought; diminishing snowpack affecting streamflow; potential increases in storm
magnitude causing flooding in certain areas; and rising year-round temperatures with higher nighttime lows.
They find that often the temperature and precipitation indicators are very important for the agricultural
community. It is noted that the Comprehensive Plan is a 10-20 year Planning document, but the guidance from
the Department of Commerce was to look at future climate projections throughout the century.
Ms. Murai explains the vulnerability assessment process follows the State guidance. High -vulnerability assets
cluster in infrastructure power, housing, water delivery, and roadways followed by health and emergency
Planning Commission Workshop Minutes 4 November 5. 2025
management, with disproportionate impacts on farm workers, low-income residents, those with pre-existing
conditions, children, and seniors. Also categorized are nine natural resource items and four economic/cultural
resources. Surface water resources such as ephemeral springs and creeks scored very high, as many are drying
up. Non -irrigated crops scored highly, reflecting less capacity to manage drought without irrigation
infrastructure. Traditional plant food & medicines scored highly vulnerable as well. The intent is to create Goals
and Policies for the Climate Element that will address the highest scoring vulnerabilities.
Twelve policy priorities from the CAT ranked in order of which received the most support in their meetings.
• water conservation
• reduced reliance on groundwater
• ecosystem preservation
• viable solutions for the unhoused community
• enhanced public transit
• accessibility to fresh food
• education and outreach
• energy & transmission permitting improvements
• ecosystem preservation
• economic diversification
• passive building systems
• economic growth
• resilience centers
Ms. Odegard explains the Climate Element is part of the broader Comprehensive Plan update, due by June
2027. Climate work began earlier due to grant timing.
Mr. Goodrich explains that the County uses the Comprehensive Plan as the guide to establish its Code. This
Climate Element is going to be added to the Comprehensive Plan.
Discussion takes place including how the Climate Element could be used to the County's benefit, to make
developing easier and not harder, preferring broader goals.
Mr. Goodrich asks what the Planning Commission's meeting schedule will be for the next few months.
Mr. Anderson -Cook replies they will start meeting monthly as they work through the periodic Comprehensive
Plan update. He will meet with Ms. Mercer to evaluate the "token system" and whether re-publication/re-
notification is required. If not, the plan is -to present a revised Chapter 25.24 for the Planning Commission to
make a recommendation to the Board of County Commissioners. In January there will be a workshop to review
wind energy. The County is currently under a moratorium for Wind. We don't have a wind ordinance, and we
have developers that have signed leases with property owners. .
Mr. Goodrich reports that Carol Dawson stepped down from the Planning Commission acknowledging her
service.
Chairman Goodrich closes the workshop at 8:45 pm.
Approved by:
Elliott Goodrich, Chairman
Doris Long, Secretary
Planning Commission Workshop Minutes 5 November 5, 2025
GRANT COUNTY
PLANNING COMMISSION
Chairman: Elliott Goodrich
Vice Chairman: Bill Bailey
Board Members: Susan Freeman, Patricia Jackson, Richard Leitz, Sandra Marcusen and Stephen Phipps
Secretary: Doris Long
COMMISSIONERS' HEARING Room - GRANT COUNTY COURTHOUSE, EPHRATAq WASHINGTON
JANUARY 7, 2026 g 7:00 P.M.
2026 Attendance
At 7:00 p.m. Chairman, Elliott Goodrich, opens the e
--ting.
l_�
Mr. Elliott announces the Commissioners who are,��ptesent and Stephen Phipps as the newest member
of the Planning Commission.
Planning Commission Meeting Minutes 1 January 7, 2026
Development Services Director, Jim Anderson -Cook, provides a summary of activities conducted for the 2027
Comprehensive Plan update. He explains that the mandated update is required to be completed and ready to
adopt by June of 2027. The bulk of the work will be done through 2026 into 2027.
There has been 30 stakeholder interviews held with various representative organizations from throughout the
County. The main concerns that were brought up during the interviews are:
1. Power Availability: Impacts on the limitation of available electricity to support demands of growing
(high load dependent) economic industries.
2. Water Concerns: Includes 1) depletion of the aquifer 2) availability of potable water for domestic use 3)
water quality of Moses Lake 3) expanding irrigation supporting expansion of agricultural growth.
3. Transportation Safety and Connectivity: Includes 1) Infrastructure and growth patterns requiring
vehicle -dependence 2) Emergency service access to unincorporated residential communities.
4. Environmental and Resource Preservation: Concerns of expanded industry and renewable energy
development. f
5. Economic Development and Work Force: Need to diversify employment opportunities.
6. Housing Diversification and Affordability: Housing development ne-, eded for various incomes and
family types. Concern over rising housing costs, and daily cost �oohiving.
7. Expanded Tourism: Opportunity to develop and promote the County's tourism and recreation offerings.
8. Collaboration Opportunities Between Public Agencies: Emphasis on communication and integrated
strategy serving shared outcomes.
9. Industrial Demand: Opportunity to assess Industrial land. demand region -wide and develop a
countywide industrial lands policy.
A great deal of feedback concerning industrial land availability was received from the Mattawa, Quincy and
Warden areas, as well as the rural lands around Priest Rapids Dam. A website has been created, and community
open houses are scheduled to be held in Moses Lake, M attawa and Grand Coulee.
Mr. Leitz asks who has the say about Zoning, whether it is Giant `County or the Department of Commerce.
Mr. Anderson -Cook explains, it is the County. Every 10 years the mandated update is the one opportunity for a
countywide lands analysis to be perforr : -bd allowing for incorrect Comprehensive Plan Land Use and Zoning
Designations to be corrected. During the years in-bdwe"downels apply for site -specific land use
designation changes, and it is the applicant's responsibility to prove that the wrong designation was established
during the periodic update.
Discussion takes place regarding the Goals and Policies of the Comprehensive Plan including possibly
structuring the Plan to allow for: a little snore flexibility, maintaining the ability to be able to adjust to the needs
of the people of Grant County, the affordability of property and housing, future power generation and economic
growth and opportunity for the smaller communities in the County.
Chairman Goodrich reports that the Board of County Commissioners are going to be more diligent about
enforcing term limits for their co" nmmissions and boards. The Planning Commission also needs to update their
Rules of Procedure that are Located in the Grant County Code. These items will be discussed at the next
meeting.
P 25-0196 Amendment of Chapter 25.24 - To establish a Mitigation Bank to offset development impacts to
shrubsteppe habitat.
Mr. Anderson -Cook explains that this application is to amend Chapter 25.24 of the Grant County Unified.
Development Code to adopt rules establishing a countywide process for certifying and regulating shrubsteppe
mitigation banks.
The Planning Commission has previously reviewed the suggested language in the original application materials.
Planning Commission Meeting Minutes 2 January 7, 2026
Language has been incorporated into 25.24.020 -Interagency Review Team, at the Planning Commission's
request. It is specific to who the Interagency Review Team is going to consist of; Parties as deemed
appropriate by the County Director has been added. The Section now reads:
The interagency review team (IRT) consists of the County as the IRT chair, County designated staff
or hired consultant(s), and may include other relevantparties as deemed appropriate by the County Director
(e.g., WDFW and Columbia Basin Conservation District) that have technical expertise or regulatory authority
in the specific regulated habitat and that choose to participate in the bank program.
The accepted comments and suggestions for text edits received from WDFW have been incorporated into the
revisions.
Mr. Goodrich asks Mr. Anderson -Cook to display the final ratio requirement.
Mr. Anderson -Cook reads from the WDFW letter:
25.24.130 Credit Generation
Based upon our most recent conversations with the county, it is our understanding that the county
will ultimately maintain the registry of all mitigation banks operating within -its borders. In this
regulatory role, it will determine the ultimate mitigation ratios (which...are based upon the credit
generation and credit debiting policies) and willjudge proposals in line with Best Available Science
and hold them to a standard of No Net Loss to ecological functions, and values, as described�n
section 25.24.090. ,4ccordingly, we support this policy.
He states that the credit generation and ratios will be decided by the IRT and the County. This was a significant
win.
Ms. Marcusen asks what law requires Grant County to preserve shrubsteppe habitat.
Mr. Anderson -Cook replies that the Director of Fish and Wildlife has determined that shrubsteppe habitat is a
protected habitat (a critical area) in the State of Washington P' ' the Growth Management Act the County is
required to protect critical areas.
Ms. Marcusen explains that she is not going to be able to vote for this. She cannot support something that is a
directive and not a law. When the Planning Commission signs this, it will become enforceable, and it is a land
grab.
Discussion takes place during which Planning Manager, Michelle Mercer, points out that the amendment being
heard is not about protecting shrubsteppe. It. is` a voluntary program that would provide landowners an avenue to
generate revenue for property that is notbeing utilized, and that they would like to protect and preserve.
There is no public in attendance.
Ms. Marcusen recuses herself from doting.
Mr. Bailey moves to recommend approval to the Board of County Commissioners of Unified Development
Code Amendment P 25-0196 as presented.
Ms. Jackson seconds the motion. -
The motion is voted on and passes.
Mr. Goodrich, Mr. Bailey, Mr. Phipps and Ms. Jackson vote in favor of the motion.
Mr. Leitz votes in opposition.
Ms. Marcusen abstains from voting.
Board Action:
ACTION: BILL BAILEY MOVES TO RECOMMEND TO THE BOARD OF COUNTY COMMISSIONERS THAT THE UNIFIED
DEVELOPMENT CODE AMENDMENT TO CHAPTER 25.249 MITIGATION REQUIREMENTS AND IMPACT FEES, TO
ESTABLISH A MITIGATION BANK TO OFFSET DEVELOPMENT IMPACTS TO SHRUBSTEPPE HABITAT, BE APPROVED
WITH 8 FINDINGS OF FACT.
PATTY JACKSON SECONDS THE MOTION.
Planning Commission Meeting Minutes 3 January 7, 2026
VOTED ON AND PASSES WITH 4 IN FAVOR, I OPPOSED AND I ABSTAINING.
General discussion takes place.
Chairman Goodrich closes the public hearing at 8:07 pm.
Approved by:
Elliott Goodrich, Chairman
Planning Commission Meeting Minutes 4 January 7, 2026
AFFIDAVIT OF P UBL ICA TION
STATE OF WASHINGTON COUNTY OF GRANT
I, Blaze Griffith -Steele, do solemnly swear that I am the Principle Agent of the Columbia '
p g mbla Basin
Herald, a newspaper established and regularly published five days a week in the English
y g language,
in and of general circulation continuously for more than sixprior the 3
(6) months p 1st day of
March, 1944; that said newspaper is printed in an office maintained at its lace of publication '
p p lication in
the City of Moses Lake, Washington; that said newspaper was approved and designated � "a,
PP g a� a 1eg�.j
newspaper by the order of the Superior Court of the State of Washington for Grant County ty on the
31 st day of March, 1944; and that said order has not been revoked and is in full force and
effect.
That the annexed is a true copy of Legal Notice # 01044/44978 Unified Development Code
Amendment - Grant County Planning File P 25-0196 as it was published in regular is p g sues (and
not in supplement form) of said newspaper once each DAY fora period of 1 consecutive lve DAY
commencing on the 16TH of JANUARY 2026 and ending on the 16TH of JANUARY 20
26 both
dates inclusive and that such newspaper was regularly distributed to its subscribers du
ring all of
said period, that the full amount of fee charge for the foregoingpublication is the sum o p f $44.58 .
laze ri -Steele
A
Subscribed and sworn to before me this 16TH DAY OF JANUARY2026,
LMBob
tc ar son
Notary Public :.
State of Washington
y Appointment Expires 1114029
Commission Number 21034179
rotB
Rey
ary Public in and for the State of Washington
Residing in Moses Lake, Washington
GRANT COUNTY
BOARD OF COUNTY COMMISSIONERS
EMAIL
To: Legals
Columbia Basin Herald
Fax: (509) 765-8659
Phone: (509) 765-4561
Re: Public Hearing Notice
❑ Urgent
❑ For Review ❑ Please Comment
From: Jim Anderson -Cook
Development Services Director
Pages: 1 (including coversheet)
Phone: (509) 754-2011, ext. 2522
Date: January 81 2426
p Please Reply ❑Confidential
Grant Count Development Services
n January 16, 2026, and bill y al six -
Please publish the following o �' the ad in 9 pt font and your norm
Affidavit of Publication. Please place above.
We also require an Aff tact me at the number listed
at columnar, as shown. Feel free to con
column format,
vOTICE IS HEREBY GIVEN
['HAT AN OPEN RECORD
'UBLIC MEETING WILL BE
IELD February 3, 2026, at 12:00
'.m. in the Grant County
'ommissioners Hearing Room,
ourthouse, Ephrata, WA to consider
to following Unified Development
ode Amendment applications:
File #P 25-0196 Unified
Development Code (UDC)
Amendment from Grant
County. The applicant
proposes an amendment to
Chapter 25.24 of the Grant
County Unified Development
Code to adopt rules
establishing a Countywide
NOTICE IS HEREBY
EN THAT AN OPEN RE.
process for certifying and
CORD PUBLICEN
MEETING
regulating shrubsteppe
WILL BE HELD February
mitigation banks. At their
3, 2026, at 12:00p.m, in
regularly scheduled public
the Grant County Com-
hearing on January 7, 20269
missioners Hearing
the Grant County Planning
,Room, "Courthouse, Ephra
Commission conducted an
open
ta, WA to consider the
following Unified Devel-
record public hearing to
consider file P 26-0196. The
opment Code Amendment
Planning Commission
applications: • File P 25-
0196 Unified Development
recommended approval of
the proposed UDC
Code (UDC) Amendment o
,from
..::from Grant County. The
y
amendment.
Proposes an
JAny interested persons may appear
amendment to Chapter ticipate in the hearing
25.24 of the Grant County please call in to the hear-
egarding these matters.
Unified Development Code ing at 1 (253) 205-0468 and
to adopt rules establishing enter
Grant County is Providing access to this
the meeting I.D (940
a Countywide process for 4827 7440), meeting ass -
g p
chedreled heating via Zoom. To
articipate in the hear ngplease
certifying and regulating word (26229323). You will
shrubste e
pp mitigation be joined to the meeting in
call in to
the hearing at 1(253) 205-0468 and enter
the meetingID (940 4827
banks.. At their regularly a muted
scheduled public hearin a as tim status until such
the hearing allows
7440), meetin
password (26229323). You will bejoined
on January 7, 2026, the for
Grant County plan_ O public testimony. If
you have
�o the meeting in a fnzcted'statccs until
znl
Duch time as the hearing allows
any questions
Wing Commission conduct- about this procedure,
ed an open record public
forpublic
estimon � I o
.� fy u have any questions
please call the Commis.
hearing to consider file sioner's Office in advance
P 26-0196.
rbout thisprocedure, please call the
ommissioner's Office in advance of the
The •
Planning of the hearing. Barbara
Commission recommend- J. Vasquez, CMC Admin.
�earin g
ed approval of the pro- istrative Assistant &
posedUDC amendment. Clerk of the Boar d Grant
,arbara J. Vasquez, CMC
,dministrative Assistant
Any interested persons CountyCO
may appear regarding Commissioners
these
& Clerk of
te Board Grant County
matters. Gra#0104
Count is 4/44978
y providing ac- Pub: January 16, 2026
ommissioners.
cess to this scheduled
hearing via Zoom. To par.