SAVE THE DATE

Save the Date Thursday, December 6th for the Holiday Party from 6:30 to 9:00 at the World Trade Center. As is our tradition, attendance is free for APA members and just $25 for non-member guests. Please RSVP for guests.

If your firm would like to help sponsor the Holiday Party, we are offering $200 standard sponsorships, which include 4 newsletter ads beginning in April (a $75 value). Please contact Patricia Love (425) 355-4141 Ext. 226 or plove@ci.mukilteo.wa.us for more information and be sure to look for the banner and brochure recognizing and thanking our sponsors at the party. The deadline to sponsor is Wednesday November 14.

The Puget Sound Section APA cordially invites you to take a break from work or studies and have a night of FUN!

WHAT: Pub Night at the RAM!
WHO: New and Returning UW M.U.P. students & WA-APA Professionals
WHEN: Thursday, OCTOBER 11th, 6:30p.m. - 8:30p.m.

APA Professionals - Take a break after work, a chance to chat with new and returning M.U.P. students soon to be entering the planning field
M.U.P. students - This is your chance to meet & greet with local professionals in the planning field in an informal and fun atmosphere

The Ram is known for great pub-style food and their own beers!

WHERE: 2650 University Plaza NE at the U-Village, Seattle

Please RSVP to Todd Hall, PSS King County Representative at todd.hall@duvallwa.gov or 425-788-2779.

TEST YOUR PLANNING LAW KNOWLEDGE

The Buildable Lands program directs certain cities and counties planning under GMA to complete an inventory of potential growth, or buildout, of the urban areas (among other requirements).

QUESTIONS:

1) How many counties are required to report under buildable lands?

2) All cities within those counties required to report must also produce buildable lands reports. In 2006, how many cities were within those counties. In other words, how many cities were required to report under the buildable lands provision?

A. 72
B. 82
C. 92
D. 102

3) According to the 2002 Buildable Lands Evaluation Report, what was the average density (housing units per acre) for King County in the "urban areas"?

4) Buildable lands allows for the exclusion of critical areas. Which of the following is NOT defined as a "Critical Area" by GMA (unless designated by the city or county)?

A. Frequently Flooded Areas
B. Fish and Wildlife Habitat Conservation Areas
C. Shorelines of the State
D. Areas with a Critical Recharging Effect on Aquifers Used for Potable Water

5) The Central Puget Sound Growth Management Hearings Board (CPSGMHB) did not make which of the following decision(s):

A. The Buildable Lands Report was not intended to be an assessment of infrastructure capacity.
B. Affordable housing is not an issue the Builable Lands Report was designed to address.
C. In determining future buildout of the city, the Buildable Lands Report must consider future market feasibility factors.
D. All of the above
E. None of the above

6) AICP Study question: In 1915 Patrick Geddes wrote which of the following books that created the foundation of regional planning theory in America?

A. The Culture of Cities
B. Cities in Evolution
C. Regional Survey of New York and its Environs
D. Tomorrow: A Peaceful Path to Real Reform

ANSWERS:

Answers to the following questions are at the end of this newsletter.

FAST-GROWING MONROE ENCOUNTERS POPULATION CAPACITY CHALLENGE

In response to the review and evaluation requirements of the Washington State Growth Management Act (GMA) in RCW 36.70A215, commonly referred to as the "buildable lands statute", Snohomish County has prepared a draft Buildable Lands Report for review and approval by the Snohomish County Tomorrow Steering Committee and the Snohomish County Council. The report analyzes population and employment capacity county-wide and for the individual cities within the County, using year 2025 population and employment projections. County staff, headed by Steve Toy, Principal Demographer & Planner with the County, prepared the report. Progress on the report was monitored by the Planning Advisory Committee of Snohomish County, a group of city and county planning directors and senior staff that meet monthly. The 2007 draft report is available on Snohomish County's website by going to www.snoco.org.

The report evaluates whether urban densities are being achieved and whether there is sufficient land within the Urban Growth Areas (UGA 's) to accommodate the forecasted residential, commercial and industrial growth anticipated through the end of the 20-year GMA planning period, currently 2025. The GMA requires that the buildable lands review and evaluation occur at least every five years. The report identified sufficient capacity is available within the overall UGA in the County for population and employment. However, some individual cities were lacking capacity for either population or employment. In Monroe's case, a population capacity shortfall of 2,519 was calculated, based on existing and projected densities within the City's UGA. The City has sufficient employment capacity using the analysis in the report.

The finding of insufficient capacity was not surprising given the city's rapid projected growth and other factors which limit the city's ability to accommodate it. One factor which is widely known is the presence of the Washington Department of Corrections (DOC) facility in Monroe; other factors include the presence of two salmon-bearing rivers on the City's south and east, and extensive critical areas within the north portion of the UGA. Under the City's Critical Areas Ordinance (adopted in 2003, following adoption of the previous Buildable Lands Report in 2002), those water bodies and other critical areas require extensive buffers, effectively removing large swaths of the city from urban development.

The City and County have negotiated an Interlocal Agreement, which provides for a joint planning process for the unincorporated portions of the city's UGA, including analysis of a possible expansion of the city's urban growth boundary along the southwest corner of the UGA. It is anticipated that this joint planning process will help address the necessary densities and development patterns within the unincorporated UGA, and provide recommendations regarding development regulations and land use designations that would be implemented both before and after annexation of these areas, resulting in accommodation of more population and densities. The City and County are jointly applying for competitive GMA grant funding to CTED for the 2007-2009 period, to reimburse costs associated with the joint planning project.

The adoption of the Interlocal Agreement and joint planning project can serve as a model for other cities and their counties that are experiencing similar conflicts regarding densities within the unincorporated UGA. The Interlocal Agreement also adopts a system of reciprocal traffic mitigation fees to help finance necessary transportation facilities resulting from growth in the Monroe area.
Questions or comments regarding this article can be directed to Hiller West at: hwest@ci.monroe.wa.us or 360-863-4531.

BUILDABLE LANDS REPORT: SNOHOMISH COUNTY

Snohomish County and its 20 cities have recently completed a second buildable lands review and evaluation report using the collaborative process of Snohomish County Tomorrow (SCT). The report is based on the methods and approaches first developed and used by the county and cities for the Snohomish County Tomorrow 2002 Buildable Lands Report, which evaluated UGA capacity for accommodating growth to the year 2012. The current report evaluates whether urban densities are being achieved and whether there is sufficient suitable land within the Urban Growth Areas (UGAs) to accommodate the forecasted residential, commercial and industrial growth anticipated through the end of the 20-year GMA planning period, currently 2025.

Overall, at the countywide UGA level, the report concluded that urban densities are being achieved consistent with GMA comprehensive plans, and that there is adequate land capacity to accommodate the adopted 2025 UGA population and employment growth targets. Estimated additional population capacity at the countywide UGA level of 236,474 is sufficient for accommodating the anticipated 2006-2025 total UGA population growth of 206,774. Sixty-five percent of the additional population capacity at the total UGA level is estimated to be available through single family residential development. Estimated additional employment capacity at the countywide UGA level of 138,289 is adequate for accommodating the anticipated 2006-2025 total UGA employment growth of 106,107.

At the individual UGA level, there is a shortfall of population capacity compared with the adopted 2025 population target for the Monroe UGA. There is also a shortfall of employment capacity compared with the adopted 2025 employment target for the Lake Stevens UGA. For all other UGAs, and in nearly all cities, there is adequate population and employment capacity for accommodating the remaining portion of the adopted growth targets. Based on these findings, subsequent "reasonable measures" evaluation and implementation may be required on the part of the county and affected cities to remedy the inconsistencies revealed by the buildable lands report.

Methodological assumptions identified in the report that should be monitored over time to identify issues and potential revisions include:

• The effect of new critical area regulations and stormwater regulations on achieved densities
• The cumulative effect of temporary local restrictions on development due to transportation concurrency, sewer capacity, and other infrastructure and services constraints
• The amount of land needed for public/institutional purposes and its effect on buildable land supply.

BUILDABLE LANDS REPORT: KING COUNTY

How Are We Doing? Some Answers in the 2007 King County Buildable Lands Report

After 5 years of hard work and collaboration between King County and its 39 cities, our second Buildable Lands Report (BLR) is finally complete. The 2007 BLR responds to a GMA requirement (RCW 36.70A.215) with data on development activity for the years 2001-2005 and an updated analysis of land supply and capacity as of early 2006. The report represents a mid-course check that compares real-world data with the goals and targets for growth contained in local plans and Countywide Planning Policies.

What did we find?

• With housing growth of about 49,000 net new units, the Urban Growth Area (UGA) is ahead of pace to reach household targets for the 2001-2022 planning period.
• Single-family development achieved 6.2 units per net acre; multifamily 38 units per acre. Both figures reflect a trend toward higher densities since 2000.
• While the county lost jobs in the recent recession, building permits show continued growth in new industrial and especially commercial space.
• The UGA contains 22,000 net acres of land suitable for residential development, with capacity to accommodate about 277,000 households, more than twice the 106,000 household target through 2022.
• The UGA contains more than 6,000 net acres of land suitable for commercial and industrial development, with capacity for about 525,000 additional jobs, double the growth target of approximately 267,000 jobs through 2022.
• Each planning subarea and nearly all individual jurisdictions have sufficient capacity to accommodate both residential and employment targets.

BUILDABLE LANDS REPORT: PIERCE COUNTY

Ahhhhh... I had to take a few moments to catch my breath. After the first Buildable Lands Report in 2002 I swore I wouldn't coordinate a second. I'm sure I'm not alone. The insurmountable details, the unique nuances among 24 jurisdictions, and the coordination efforts over the past 5 years...but yes... I'm thankful I'm not filling the shoes of Chandler Felt or Mike Hubner in King County...I can't imagine completing this significant endeavor for 40 jurisdictions. You may ask, besides meeting some regulatory requirement, is it worth the mammoth effort? My answer is yes!

Pierce County, and I'm sure many other jurisdictions, had good intentions in the mid-90s of monitoring the effectiveness of their adopted GMA policies. However, monitoring efforts always fell to the bottom of the priority as budgets were developed. The Buildable Lands legislation passed in 1997 required jurisdictions within six counties to follow through and participate in a countywide monitoring and evaluation program. The compiled development data not only fulfills a state GMA requirement, it also contributes to data needs for other planning efforts such as capital facilities and transportation.

So...how did Pierce County and its cities and towns fare through the latest report? Is there sufficient land to accommodate the 2022 population allocation? Countywide the answer is yes...with a 68 percent excess of needed housing units. Individually, six jurisdictions lack the residential capacity to fulfill their future allocation, and only one would be labeled as a significant deficit.

This conclusion was reached through the application of assumptions that may not be evident today but with the inevitable change in housing markets, feasibility of projects and individual financial situations, there is ample time in the next 15 years to realize the assumed growth and development. This isn't to say that jurisdictions don't have a responsibility to create a regulatory environment to entice consistency between the assumptions and built development. A follow-up consistency evaluation report will be drafted in the coming months to identify jurisdictions that may need to adopt "reasonable measures" to address these differences.

A central point raised through this year's stakeholder review which wasn't voiced in 2002, is that despite having the residential capacity, some local jurisdictions are not experiencing the housing production levels needed to meet the 2022 allocations. This has brought into question the accuracy of the future population allocations. The current allocations reflect a significant change in population distribution...a redirection of growth from unincorporated urban areas to within existing municipal boundaries. Some question if this is realistic considering housing prices and the preference of home buyers. Fortunately, this issue can be delayed for a few months until the Office of Financial Management releases its next GMA population projection series and the process to update the County's allocation to 2027 begins.

What's next? The effort to fulfill the buildable lands requirements are on-going and does not stop with the final printing of a 2007 Report. A consultant needs to be selected to complete the consistency evaluation report. Workshops need to be planned to engage elected officials, planning commissions, and planning staff in a discussion about the ramifications associated with the report. Not to mention collecting development data and research projects for the 2012 Pierce County Buildable Lands Report.

Oh yes, the 2012 Report, its only 5 years away; how can I convince a co-worker it's a fulfilling project to lead? Your suggestions are welcome!

For additional information about the 2002 Pierce County Buildable Lands Report contact Dan Cardwell, Senior Planner, Pierce County PALS at 253-798-7039 or dcardwe@pierce.co.wa.us. You may review the 2007 report on-line at www.co.pierce.wa.us/pc/services/home/property/pals/landuse/buildablelands.htm.

HOW TO CALCULATE RESIDENTIAL DENSITY

How to Calculate Residential Density (from the PowerPoint presentation at the May 16, 2006 APA Brown Bag)
By Stephen Ladd, AICP

Density equals the number of dwelling units divided by (per) # of acres. So think in terms of fractions. It's always "units / acres."

Remember your grade school arithmetic? The top number in a fraction is the numerator. The bigger the numerator, the bigger the value. The bottom number is the denominator. Now watch out: the bigger the denominator the smaller the value. I call it the "counter-intuitive denominator." It often confuses people when trying to understand density.

Here's an example. There are 20 units on 5 acres. What's the density? 20/5 = 4 units per acre.

"Gross density" means the number of dwelling units divided by the entire acreage. In gross density the denominator is larger. So, the value is smaller. Gross density always "sounds" less than net density. A suburban jurisdiction arguing that it complies with the GMA will never quote you their gross acreage because it doesn't sound good! Gross density dictates transit feasibility, because it's a better measure for how many people will actually got on a bus or train at a given stop.

"Net density" means the number of dwelling units divided by the net acreage. That's the acreage with the streets, stormwater ponds, critical areas, etc. netted out. Exactly what should be netted out varies from jurisdiction to jurisdiction. In net density the denominator is smaller, so the value is bigger.

OK, let's try examples. These examples are based on a hypothetical parcel that is being subdivided. In subdivision terminology it is called the "parent parcel." The parent parcel is 1.5 acres gross in size, but 33% of it is netted out for streets, unbuildable slopes, and wetland. So it is exactly 1 net acre.

For this "parent parcel" there are four development scenarios. In each scenario, calculate the gross density, net density, and average lot size. Remember: units / acres! Cover up the answers if you want to test your skill.

Scenario #1
In this scenario the parcel is not really being subdivided. It just has one house. But the street and critical areas exist, so calculate the gross density, net density, and lot size.

Answers:
Gross density: 1 / 1.5 = .666
Net density: 1 / 1 = 1
Lot size: 1 acre











Scenario #2
In this scenario the parcel is being divided into 4 lots.

Answers:
Gross density: 4 / 1.5 = 2.666
Net density: 4 / 1 = 4
Ave. lot size: (43,560 / 4 =) 10,890 sq. ft.














Scenario #3
In this scenario the parcel is being divided into 5 lots.

Answers:
Gross density: 5 / 1.5 = 3.333
Net density: 5 / 1 = 5
Ave. lot size: (43,560 / 5 =) 8,712 sq. ft.













Scenario #4
In this scenario the parcel is being divided into 5 smaller lots and an open space tract is being set aside.

Answers:
Gross density: 5 / 1.5 = 3.333
Net density: 5 / 1 = 5
Ave. lot size: (43,560 X .75) / 5 = 6,534 sq. ft.











Note that the net density is the same for Scenarios 4 and 5. Does this come as a surprise! Think about it. Both achieve the same number of lots. The developer could have built on that land but he chose to set it aside. So what you divide by is still the same net acreage. If the open space were unbuildable it would have been netted out.

Example of a multiplication scenario
Here's another common situation. Someone owns X acres in a zone in which X units per (gross or net) acre are allowed.

Example: A zone allows 5 units per net acre, in which "net" means to net out streets, stormwater facilities, critical areas, AND critical area buffers. (Warning: not all formulae net out the buffers!) The parcel in question contains 10 acres (gross). Half that is critical areas and buffers (single net). 20% of the single net will be streets and stormwater (double net). How many lots can they have? Just multiply the net acres by the density allowance and round down.

Answer
10 acres / 2 = 5 acres (single net)
20% of 5 acres is 1 acre
5 - 1 = 4 acres (double net)
4 acres X 5 units per net acre = 20 lots

That does it. Happy density calculating!

PLANNING STUDENTS ENJOY DIVERSE SUMMER EXPERIENCES

MUP students had a variety of rich experiences this summer either studying abroad or interning at local agencies, companies, and organizations. Here is a partial list:

Katie Somers worked at the King County Solid Waste Division, Recycling and Environmental Services Section. Katie and Tzu-Yu Lin also traveled to Tokyo and Taipei with the Landscape Architecture program to study micro-urbanism in Asian cities. Tzu-Yu also worked for the Office of Emergency Management, Seattle Police Department, and helping them update the Seattle Hazard Identification Vulnerability Analysis.

Vivian Chang and Angie Salicetti attended an urban design/ historic preservation studio in China, and studied the influence on family lineage on planning practices. Vivian
worked for Seattle DPD's Design Commission, while Angie interned at a private architecture firm.

Michelle Zeidman spent most the summer working for the Government Accountability Office in Seattle. She also spent three weeks studying urban renewal in Bogota, Colombia where she learned about (and used) their renowned bus rapid transit and library systems.

Andrea Clinkscales worked for Seattle DPD's Planning Commission, doing research and analysis.

Stephanie Parkins worked on finalizing the City of Bellevue's Commute Trip Reduction (CTR) Plan this summer. The goal of the CTR Plan is to lower the drive alone rate traveling to worksites with 100 employees commuting between 6 am and 9 am by 10% and reducing the vehicle miles traveled to these worksites by 13% no later than 2011.

Tessa Gregor spent half the summer working on a GIS project at UW and the rest traveling around The Netherlands and Ireland studying Urban Design and Planning with Liz Stenning, who also helped plan this summer's Great Places Symposium.

Meghan Pinch worked as an intern this summer for local green building consultant O'Brien and Company. She also successfully completed a bicycle tour from Seattle to San Francisco, which gave her plenty of time to think about the built environment.

SUMMER '07 BROWN BAG RECAPS

Governor Gregoire's Puget Sound Initiative, 07/25/07

Although the Northwest has a very active environmentally aware population, within the area, over 75% of the population is unaware of the issues. There is a history of neglect. In the past, both public support and funding has not existed. However, with this new Initiative, there is a new focus and new approach.

The Puget Sound Initiative's goal is to create a strategic approach to protect the Sound. The approach to protection is two fold. First, the initiative is based on long term results based and built on existing plans. Secondly, the initiative is to raise public awareness. The difference between this new initiative and other initiatives is the emphasis on measurable goals and published results. This effort will bring together a diverse group of individuals - from biologists to Native American Indian tribe leaders - with the objective of providing a comprehensive approach to resource management. The program will seek to protect and restore habitats, reducing toxins, improving water quality, protecting ecosystem diversity all while building and sustaining the capacity for action. For more information, visit the Puget Sound's Partnership on the web at http://www.psp.wa.gov/.

A special thanks to our speakers: Linda Lyshall, Puget Sound Action Team, Tim Walls, Snohomish County Surface Water, and Terry Williams, Tulalip Tribe

McMansions, Mega houses, and Tear-Downs, 08/1/07

Regulating floor area ratios in wealthy and booming communities is a hot topic for many planners. Homes with large footprints can be unsightly and out of place and, in many cases, local jurisdictions have their 'regulatory' hands tied.

The City of Mercer Island has encountered the spectrum of issues associated with McMansions and teardowns. Travis Saunders, Mercer Island, has faced these challenges at the City has created a development framework to manage this growing issue. He provided helpful tools every city planner has to direct development and minimize the impact of large mansions - from articulation mandates to setback requirements. We also heard from the private side. Bill Kreager, from Mithun Partnership, provided a developers perspective. In many cases, reducing the floor area ratios work in the favor of the client - providing a better overall product.

A special thanks to our speakers.

How Light Rail Will Change Our Urban Fabric, 08/ 8/07

The first phase of Sound Transit's light rail is under construction and will be ready to ride in the near future. Along with this exciting new mode of transportation, is a new paradigm for development. Fred Glick, CDM, and Brian Jackson, IBI Group, provided an overview of Transit Oriented Development.
Transit Oriented Development (TOD) is compact and people-centered (as opposed to auto-oriented) development. The general development area is within the station's pedestrian shed, roughly 1/2 to 1/4 mile radius, from the station location. The Development itself, can be at many scales with the common focus on the pedestrian flow and multimodal transit options. Many successful TOD projects have been seen in Portland and along some Southern California light rail lines. These existing projects can serve as an educational experience - for are local planners and transit officials to glean from.
Local Planners and Transit Officials can expect plenty of excitement along this line from the development community. It is important to pair that excitement with standards and regulations which support compact and smart growth.

Special thanks to our speakers: Brian Jackson, IBI Group, and Fred Glick, CDM

What local planners need to know about State & Federal permits, 8/15/07

Moderator Peter Hapke of Hapke Law Office introduced the panel. Heather of the City of Bonney Lake listed what agencies require what permits for various types of work. Communication between agencies is lacking, especially when the work involves wetlands. The Joint Aquatic Review Permit Application (JARPA) helps in that this one application form is accepted by several agencies. But which agency is the lead? Who goes first? It seems to vary from jurisdiction to jurisdiction. Local planners can provide better service by telling applicants what they know about state and federal permit requirements.

Sheila Hosner said the Governor's Office of Regulatory Assistance has no regulatory role but assists in many ways. Sheila shows a schematic of how a wetland permit winds its way through the various agencies. If it's an isolated wetland the Corps of Engineers wouldn't have jurisdiction but the Department of Ecology (DOE) still would. She also discussed how the DOE may invoke the 2005 Stormwater manual in certain instances though the local government does not. Applicants that don't know that may have to redesign their stormwater facilities before they can get approval. Try the ORA at www.ora.wa.gov or 1-800-917-0043.

Jonathan Smith of the U.S. Army Corps of Engineers said his agency is somewhat isolated from the others. The Corps often has a closer rapport with state agencies than with local governments. Major permit programs are Section 10 of the Navigable Waters Act, which regulates such things as docks and bank protection, and Section 404 of the Clear Waters Act, which regulates such things as fill and pilings in wetlands and ponds. The Corps uses Individual Permits for complex and controversial projects and General Permits for routine projects. The latter consist largely of Nationwide Permits, of which there are 50 different kinds. For example, there is one for maintenance activities. Corps permit review is concurrent with or after local government review. If there's a violation the Corps can help with enforcement. Corps wetland regulations protect the wetland itself, not the buffer. Interagency coordination on Section 404 regulation is poor - the state may eventually take over - but coordination on shoreline permits is good.

Washington Realtors' Housing Policies Benchmarks Study, 8/22/07

Jeanette M. McKague's organization, the Washington Association of Realtors, asked for GMA amendments to help with the housing shortage. The legislators said they needed data first. So the Realtors have completed a Housing Policy Benchmarking Report that will be updated in the future to determine trends. The Report lists new units, job/housing ratio, and similar statistics for local governments in King, Kitsap, Pierce, and Snohomish Counties. It also shows which jurisdictions have enacted housing-friendly policies such as higher SEPA exemptions, lot-size averaging, and permission for accessory dwelling units and cottage housing.

According to Forbes Magazine Seattle's housing is the second least affordable of any in the nation because jobs have increased much faster than housing. Michael Luis of Michael Luis Associates shared figures demonstrating the high cost of bringing a building lot to the market in various Puget Sound locales. In contrast, residential construction costs have remained flat over the last decade. So properly zoned vacant lots is the key to lowering housing costs. He said the housing/jobs mix is important by subregion but not down to the jurisdiction level because people tend to commute to outside their home municipality regardless.

Tim Gugerty of the Association of Washington Cities discussed the findings of the Affordable Housing Advisory Board, which determined that infrastructure needs are paramount in providing more housing.

FALL '07 BROWN BAG SCHEDULE

Fall 2007 Brown Bag Series Schedule

Come to the FREE session you need to do your job better! APA-subsidized lunches, only $2! RSVP by the preceding Monday at 9 AM to Katie Pelton, kpelton@ibigroup.com.

ANSWERS TO TEST YOUR PLANNING LAW KNOWLEDGE

Answers

1) Six counties (Clark, King, Kitsap, Pierce, Snohomish, and Thurston) per RCW 36.70A.215(7). Any county with a population over 150,000 in 1995 and that are located west of the crest of the Cascade mountain range must report under buildable lands.

2) D. 102 cities are within the boundaries. (Clark has 8 cities, King has 39, Kitsap has 4, Pierce has 24, Snohomish has 20, and Thurston has 7.) Therefore a total of 108 jurisdictions (the six counties and the 102 jurisdictions within them) are required to report.

3) According to the 2002 Buildable Lands Evaluation Report, the average density for 2002 in King County was 7.3 units/acre within urban areas.

4) C. RCW 36.70A.030(5) "Critical areas include the following areas and ecosystems: (a) Wetlands; (b) areas with a critical recharging effect on aquifers used for potable water; (c) fish and wildlife habitat conservation areas; (d) frequently flooded areas; and (e) geologically hazardous areas." RCW36.70A.480(5) states "Shorelines of the state shall not be considered critical areas under this chapter except to the extent that specific areas located within shorelines of the state qualify for critical area designation based on the definition of critical areas provided by RCW 36.70A.030(5) and have been designated as such by a local government pursuant to RCW 36.70A.060(2)."

5) C. The CPSGMHB Final Decision and Order states the Buildable Lands Report "is not intended to be a comprehensive market feasibility study, a predictor of the economic climate in the future, or source for identifying parcels ripe for development." (Case No. 04-3-0028.) "A" and "B" was also decided in CPSGMHB Case No. 04-3-0028.

6) B. Patrick Geddes wrote Cities in Evolution