Planning Commission - Regular Meeting

Welcome. I would like to call this planning commission work session to order, Thursday, 05/07/2026. My name is Jack Haroun, and I'm the vice chair of the Clark County Planning Commission. Before we can begin tonight, I would like to announce that our planning commission work sessions are hybrid, both in person and via Webex. For the virtual and in person members of the planning commission and staff, please ensure that your microphones are turned off or muted unless you are speaking.

There will not be any public comment during this work session, but members of the public can watch or listen. Written testimony related to this evening's agenda items or other topics considered by the planning planning commission is encouraged and and is accepted at any time. This evening agenda is as planned. Stonewater quote code and manual updates. We'll have convert comments from the members of the planning commit mission and adjournment.

Alright. Well, welcome, everyone. We'd like to go over the stormwater and final, stormwater code and manual updates. And Devin?

Hi. Good evening, planning commissioners. For the record, my name is Devin Rostofer. I'm the clean water division manager in public works. And today, we're here to introduce the 2026 update to Clark County stormwater code and manual.

This is a required update tied to our phase one municipal stormwater permit, and today's session is focused on giving you an overview of the key changes that are being proposed for the update and receiving your questions and input before the hearing later this month. Today, what you have before you is a public review draft that went out with general public comment in March 2026, which was available for public review through April. Next slide, please. We have about sixty minutes total today together, and we'll focus our sorry. Next slide.

It's okay. No worries. In our hour together today, we'll cover four main topics. We'll provide a project overview and how we've approached the update to the code and manual and some background. We'll also go through the engagement process that we use to interact with DEEV, the Clean Water Commission, and county council, and, again, the general public. We'll also provide a summary of proposed changes, a timeline, and next steps to get to adoption. And we ask that you please hold your questions until the end. We have a quite a bit to get through. And if we don't get to everything today, we'll follow-up in writing or during the public hearing. Next step, please.

So once again, our desired outcomes from today are to introduce the manual update, hear your questions and initial feedback, and we'll also discuss all the public input we've received so far and how we've responded to that. And with that, I'd like to now hand it over to Trista Kobluski from OTEC, who has been the the lead professional services contractor on this project. We're very lucky to have her, and she'll walk through the background and purpose of the stormwater code manual.

Good evening. I'm Trista Koblesky, senior stormwater planner at OTAC. Thank you for having us here today. Am I audible? Loud enough? Okay. Thank you. Next next slide, please. All right. What we're introducing today, the stormwater code and manual update is pertinent to the county's phase one municipal stormwater permit, as Devin already mentioned.

This is a permit issued under the Clean Water Act to the county, and it is administered by the State Department of Ecology. We're currently in the twenty twenty four to 2029 permit cycle. The permits are usually five years. They re renew every five years, and, the county is allowed to discharge stormwater runoff to surface waters because of this permit. Next slide, please.

So the permit mandates that the county maintain a compliant stormwater code and manual to regulate runoff from development sites, essentially. And in this case, the update has to be done by 06/30/2026 and be effective on July 1. The county's regulations must be equivalent to the stormwater management manual for Western Washington, which was last updated in 2024. The state updates it about every five years, and the county follows by updating their manual a couple years after that, generally speaking, again, cyclically. Next slide, please.

The stormwater codes and manual are contained in a few different places. Clark County code title 40, which is the Uniform Development Code, has chapter, three eighty six, which is stormwater and erosion control. I should also mention that chapters 4,100, general provisions, and 4,500, overview of procedures have small amounts of language related to stormwater as well, which will be updated. There's also title 13 public works and utilities, chapter 26a, water quality, which is an environmental regulation limiting the discharge of pollutants. And both of those code chapters adopt the stormwater manual, which is the engineering standards, the selection criteria, and operation and maintenance standards for stormwater control on the in the county.

So together, these set the rules for designing, constructing, and maintaining stormwater facilities, across the county. Next slide, please.

Just to give you a sense of who uses the manual, it's a relatively broad audience.

Public Works Clean Water, division maintains and updates it, and they are the county's representative in complying with the permit. The community development department uses it for permitting, construction and development. Private engineers and developers use it to know their design standards, so they design to it. Public Works itself builds and maintains infrastructure using the standards in the manual as well. And builders and homeowners also apply it on smaller projects, home construction sites, for example.

So it's a pretty broad range of users. Next slide, please. So the importance of the manual goes beyond permit compliance. The county strives through the stormwater code and manual to protect water quality that includes, surface waters and groundwaters, like to limit the damage to streams from high runoff volumes, which occur when we add impervious surfaces, and reduce flooding. You know, this is localized flooding in your neighborhood street or on an intersection, like to reduce that flooding.

And in general, strive for better resilient infrastructure that provides a safe living environment in the county. Next slide, please. So with the update, we have several goals. First, but not only, is to maintain compliance with the permit. As we've mentioned, many of these updates are mandatory.

The county would like to apply best available science under the Growth Management Act as well, address past issues that have come up as the county has been able to see the results of previous design standards, how can we improve stormwater analysis and design, and then make the manual easier to use and enforce. So that's consistency, clarity, and communications about it. Next slide, please. So that's all the background. Devin, do you have anything to add to that?

Okay. Thank you. Wonderful. So I will now walk through a high level summary of, that. Okay.

Commissioner O'Brien here. Does when you talked about, other municipalities, do the other municipalities like City Of Vancouver and Ridgefield all adopt the same code, or do they have their own independent codes? Are we just hearing Clark unincorporated Clark County?

Good question. They would have the option of adopting the Clark County manual because it is determined to be equivalent to the stormwater management manual for Western Washington, which is Department of Ecology's publication. At the current time, none of the cities do. So they, generally adopt the Western Washington manual. And then in their own engineering standards, there's usually some provisions that are unique, to the to the city.

And and I would just also offer that, jurisdictions that are phase one and phase two are able to use any approved equivalent manual. So, anyone in Washington state could choose to use Clark County's code and manual in Western Washington.

Correct? West Western.

Western Washington and be compliant because Ecology, again, has deemed it equivalent to their 2024 stormwater management manual.

Yep.

Okay. Next slide, please. So we've, have a set of updates that maintain the county's compliance with the permit. These were very specifically listed out in appendix 10 of the permit as, required updates. And if we went to the next slide, they are these, seven topics.

So there are some changes to redevelopment thresholds, some clarifications to exemptions from the manual, some updates to definitions, a bit of a change to standards for wetland protection from stormwater runoff, some some changes to runoff treatment, language, essentially, requiring metals and phosphorus treatment in a few additional locations, changes to source control requirements having to do with PCBs, and then the addition of a high performance bioretention soil mix, which is a new option that allows bioretention to be used to manage phosphorus. Whereas previously, you couldn't use bioretention near a phosphorus sensitive water body, which we do have in Clark County. All right. Next slide, please. We're also proposing some more updates to engineering standards.

These, are designed to improve infrastructure performance, protect drinking water quality, protect Mill Creek, reduce erosion risks, and improve long term maintenance access and maintainability of stormwater facilities. And these are based on recent project experience and observed outcomes. And many of these were, a result of, requests from manual users over the last five years since the 2021 manual was adopted. So the community staff, have been involved in these improvements. Next slide, please.

We also have a set of clarifications and corrections. These don't change anything. They simply clarify language that was already present or standards that were already present. One of these is to emphasize infiltration and low impact development as the primary or first choice of stormwater management, clarify the uses of certain facility types on sites or for different performance purposes, refine some of the submittal requirements, and just correct some errors that were in the manuals. Manual, just one of them.

Next slide, please.

So we wanted to highlight four changes that we think have the important environmental benefits from the proposed update. The first one is better protection of drinking water, which, as you may know, Clark County has a sole source aquifer. So I think more like, 90% of the drinking water in the county is provided by one aquifer. We're proposing to limit the use of, deep underground injection control wells to manage stormwater for flow control. I do wanna distinguish.

This is not a typical dry well, which are used commonly in Clark County. Although they are not called this, you might call them the shallow version. So they go to about 25 feet maximum underground. The deep underground injection control wells, by contrast, could reach a 100 feet below ground depending on, groundwater resources in the location. And they are recognized by the state, but Clark County is proposing to not recognize them as an allowable or an approvable BNP for flow control purposes.

The second one is to require more consistent testing and design for infiltration facilities. Again, based on recent past performance and recent experience, we wanna make sure infiltration facilities not only provide the flow control and the water quality performance that they are meant to, but that they continue to function into the future. And they are susceptible to clogging, and they are susceptible to poor construction practices, leading to failure potentially. And they are sensitive to the type of soils analysis and infiltration analysis that you do. So we are strengthening the requirements for analysis and design where infiltration is proposed.

Thirdly, we're improving stream channel protection for Mill Creek. In the current manual, there is an alternative flow control standard for Mill Creek, and we are proposing to remove that and bring the flow control standard in the Mill Creek Watershed into alignment with the entire rest of the county so it will be consistent. And then finally, we are changing the requirements and options for phosphorus removal. That's a runoff treatment type for phosphorus. To protect, Vancouver Lake and Lake River, we're requiring phosphorus in more locations.

And then as I mentioned before, there are now more options for phosphorus treatment facilities. One of those is now bioretention using the new high performance bioretention soil mix. Next slide, please. Oh, this is the map, incidentally, of where phosphorus control would be required under the 2026 proposed updates in kind of the brown areas.

And I will just offer that that requirement has already been in place for Lackamas Creek Yes. To protect Lackamas Lake. So the proposed update is just for the drainages to Lake River and Vancouver Lake.

Correct. So about half of this or a third of this area was already had a phosphorus requirement. Okay. Next slide, please. All right. I will take us through the engagement process. We have consistently reached out to the community during this process as well as staff. And next slide, please. We worked closely with the internal staff and county action team on stormwater. Representatives from public works and community development, several different divisions participated on this.

These were also the folks that, since the 2021 manual was published, had been, you know, logging or noting their request for improvements to the manual in terms of usability, standards, maintainability, all that sort of thing. So they were engaged numerous times starting in 2024. Next slide, please. And we consistently engaged the development and engineering advisory board beginning in October 2024. We met with them seven times, I believe.

We gave DEEB and the Clean Water Commission, which is the, advisory commission on to the Clean Water Division, the opportunity to review early drafts of the full documents in December 2025. So we called that an invited public review. We didn't release it to the entire public, but we asked DEEB and the Clean Water Commission to, or we gave them access to the full drafts of all the documents. And because we consistently engage staff in the community, the input or the the results that you'd see in front of you, their input helps shape and refine what you what you'll see. And next slide, please.

Thank you. And then we began a general public review period in March, and we had that going through into April where the drafts, which had been updated since December when we invited DEEB and the Clean Water Commission to comment. So these drafts incorporated the comment we received then. They were released on the website, and then we notified DEEB and the Clean Water Commission as well that there were new drafts that they could review. SEPA comment period is ongoing right now.

The Washington State Department of Commerce review is also ongoing right now. And there are, public notices thanks to this work session and then the hearing that we will have. So we've engaged the public quite a bit. Next slide, please.

Sorry. Could I interrupt again? I'm sorry. But back to the engagement. So far, we've only seen one comment from the public. And is that is that all there is so far as far as public comment goes?

There is

Besides DEEP and and, of course, Stormwater Commission.

Yes. We've oh, sorry. No. No. We've received, just in preparation for this work session, the one public comment that I believe has been provided to you. It there will be another public comment period for the hearing, so that's another opportunity for the public to weigh in as well as the council adoption public hearing. We did receive quite a we do have Deebs comments that I believe are have those been made available or will be made available for the hearing? And, yes, I I apologize, except with the exception of the last one that is the email that we received.

I was just curious. Is the do you think the lack of comments is because these the process is a very difficult one for people to get their mind around? Or It is technical. There much else going on?

It is technical. Yeah. It's very technical. But I want one point of clarification. The comments that you see here are mostly deep, but there are is one other comment that, that came in during the March and April public review period that was not associated with DEEB to the best of our knowledge. And then the there's also that email that Devin mentioned.

Great. Thanks. I I just wanna make sure that we were seeing the whole picture there.

And and

it sounds like a lot of work getting out to get the public to understand what's going on and not getting a lot of feedback, except for Deep. I Deep is amazing in what they dig into, and I'm thankful for their hard work, especially.

That's part of the reason that we did seven touch points with Deep, knowing that they are key stakeholders and experts in the manual, you know, complying with it, implementing, using it in multiple ways. And I think it was a worthwhile investment because you can see that you only have one piece of paper that's two sided. Hope I got that right with, comments, and I really think that was from the time that we invested in talking through and and the targeted early review as well. So, lesson learned, more engagement early, leads to good outcomes. And I hope I hope that represents to the support that we're hearing from other commissions as well.

Did you guys directly reach out to, like, the building communities or some of the associations?

My understanding is that they were included on the email distribution list that went out for the general public comment period.

Yeah. Yes. The I did not develop that list, but, yeah, I believe there it went to the SEPA notification list Yeah. Our gen the general public comment period in March and April. And building industry, there were Facebook posts and potentially some other social media outreach.

And we maintain a Stormwater Partners for Southwest Washington list, which includes all of the municipalities in the area who could choose to use the manual. And I my understanding too is that that partners list, they maintain a list of, potential contractors, specifically that work in the area of maintenance that would have received it as well.

I I would also wonder if the it shouldn't go to all the CSOL certificate Those are the guys with the boots on the ground that are dealing with this daily too.

That's a great recommendation. And, actually, one of the most important next steps is providing all the training, just for those who are implementing and complying with, but for county staff who are using it to review and permit. So that is something we are, have in the works.

Alright. And, actually, this was timely because this is the slide this is the slide we're on. I the drafts that were with your packet today are the same as the drafts that we showed the public in March and April. And so this list of comments that's in your packet as well that you, held up earlier, commissioner Halbert, are currently being incorporated. And we have, in fact, finished doing that, and the drafts that are being presented to you for the hearing in two weeks incorporate these changes that you see here, our responses.

So we modified or reversed a handful of our original proposals, due to the the comments that we received in March and April. And so those are listed here, and you can see the responses. And they'll be incorporated in the drafts that you see, for the hearing. All right. Next slide.

We'll talk about the formal adoption process, and we can go on to the next slide. We mentioned early on that permit compliance was important. So Ecology does does have a review role for these manuals, and they issued an equivalency determination on 03/11/2026, which I think might be in it's I think it's in your hearing packet. I don't think you have it today. But, that really is an important milestone. It is in

your packet today.

Oh, it's in your packet today. Alright. Yes. Thank you. Washington letterhead. There you go. Washington state letterhead. Yes. That's a really important milestone. And any changes we make or comments we receive, we have to think about in light of the equivalency determination.

Next slide, please. We are meeting with you here today in a work session and plan to have a hearing, planning commission hearing, on 05/21/2026. So we'll see you in two weeks when, again, you will see the draft final versions of the documents that incorporate the public comment we received through basically yesterday. Next slide, please. And we have reached out, and we'll continue to engage county council, of course.

We had a work session in January 2026 where we received many questions from council and are engaging them on those answers. We have our second work session with them on May 20 and the public hearing to adopt the, amendments to title 40, the amendments to title 13, and they updated 2026 Clark County stormwater manual on June 16. And, again, per the permit deadline, those have to be adopted by June 30 and in effect on July 1. Next slide, please. And we are going to talk about next steps.

And I can talk about it, or Devin can talk about it. As I said before, we have a SEPA review going on and are expecting a determination of non significance. The Department of Commerce State Department of Commerce review is ongoing. That always has to occur when you update your development regulations. The Planning Commission hearing, county council, and adoption in June.

And then importantly, as Devin mentioned, training and guidance for the manual users. So you saw that broad list of users. County staff reviewers could use training on the changes. The development community, contractors, and, county staff who inspect and maintain stormwater facilities all will be the audience for the training. Trainings or guidance as well.

And next up or next slide, I guess. This is just a summary of things we've talked about already. The schedule that we took, we began actually doing this in 2024 and are planning to adopt by the county's permit deadline. Next slide.

Okay. And I guess that concludes us. I just wanted to quickly thank Trista. We've been so lucky to have her, expertise and really appreciate working with OTEC. I also want to acknowledge and thank our prosecuting attorney who has reviewed the full thousand plus pages of everything, and, that has been an incredible amount of time. And we've worked through a lot of details, so thank you, as well as staff. I believe Jen is online right now who prepared all of the materials for the work session and the public hearing. So we couldn't do it without and those who participated, on the county internal team and, again, to Deep and our Clean Water Commission and to all

of you.

So thank you so much for having us here, and we'll take any questions.

We have Yeah. So when we have our hearing in two weeks,

I'm anticipating that you're gonna show us the before

and the after of any changes that are included.

The documents are in strikeout and underline.

Okay. And

Those are online currently.

They are they're the March drafts. Oh, actually, I think the hearing materials Sorry. Yeah. Is that online? Uploaded. Yeah. They've been uploaded. So so the hearing materials are the latest drafts, and they are in strikeout and underline.

Okay. That's what I was wondering. Alright. Thank you.

Mhmm.

Oh, I do have another question. Mill Creek. Yes. Typically, Creek goes through the jurisdiction of Battleground?

The area that is actually, Mill Creek, it it comes and drains into the confluence with Salmon Creek near WSU Vancouver. And so, there are portions outside of the urban growth area, and then there are portions within the urban growth area. I don't wanna misspeak and say how far it goes up to Battleground, but it is, within our UGA near WSU Vancouver.

For other jurisdictions that have Mill Creek in it, these changes that are being proposed, are we expecting them to adopt the same?

Is it all unincorporated?

I I don't have the answer as to whether it actually crosses into Battleground. But theoretically speaking, the other jurisdictions adopt the Western Washington manual. The Western Washington manual never had an alternative flow control standard for Mill Creek. That was Clark County specific only and applied only in unincorporated Clark County. So again, I'm sorry. I don't I actually don't know if Mill Creek crosses any of the incorporated boundaries of the county, but none none of the other, cities adopt the Clark County manual. So they would not have had that alternative standard in the first place. They would not have had it to begin with. Mhmm.

Who is the who makes the or signs the, SIPA nondetermination?

Great question. So the responsible official is our public works director Ken later.

Mark, did you have any questions? Yeah. I have a I have a couple question. What is what is unique about the counties versus the state? Like, if if it were just going for compliance, call it efficiency, what would be would be the downfall of just adopting the states and then not doing anything? It's like, yep. States gave us this, we adopted.

There are unique elements of the Clark County stormwater manual. The state's manual does not contain a variety of standards that you need to design a stormwater system. They don't have conveyance standards, for example. They don't have standards for outfalls. It does not include setbacks and other elements that you really need to design a stormwater system effectively.

So no matter what, Clark County would have to have somewhere where those standards lived. It could be in code, but we try to avoid technical engineering standards in code. Or it could be in a standalone engineering manual. So many cities have, you know, the right of way manual or or the engineering manual, and many of them put those types of standards for conveyance, outfalls, setbacks in their right of way manual or their engineering manual. Clark County doesn't have that.

So we have we have to find a place for those standards to be anyway. It doesn't have to be in a standalone manual, but it there are other benefits. For example, for a while, Clark County had an alternative flow control standard for Mill Creek. That's not less straightforward if you're adopting the state's manual. Clark County adopts a specific version of the Western Washington hydrology model that is tailored to the county's soil types and the way engineers, think of soils in Clark County.

We have an infiltration, facility sorry, infiltration testing method adopted in Clark County that is unique to Southwest Washington. It's commonly used by engineers here, and it is not available in the Western Washington manual. So there that's probably not an exhaustive list of the reasons why. But there there are reasons that it's tailored to conditions in the county. It's tailored to the way that business is done here. It's tailored to the way that permits are land use permits and engineering permits are ish approvals are issued here.

I would also wanna offer one other example. Our decision to place limitations on the use of those deep underground injection control wells, which, again, are much deeper than the shallow wells, that was the manual is an opportunity for us to have that locally specific restriction because of the Troutdale aquifer. And so if we adopted the Western Washington manual that enables use, we would have to put any limitations in separate code. And so it it allows you to be more be more local. And I also will offer, though, that the neighboring this was a question that came from council if our neighboring jurisdictions also choosing that ones to have limitations to that one specific BMP, and they are in alignment with us on that and choosing to do that.

With within the code, I believe it's 5,000 square feet of hard surface requires you to hire a civil engineer, to do the infiltration. It's like it's kind of like four or 5,000 square feet. Is that a state requirement, or is that a county requirement?

That essentially comes from the state. If you if you are designing a flow control facility, minimum requirement seven and using infiltration. The qualified professional needs to be an engineer, a a licensed professional. Smaller sites can use an on-site sewage designer in addition as another option.

Is that okay. And that I part of it is because I recently came up against this of where I do a lot of development in downtown. So we have very small sites. And under 4,000 square feet, it's, you know, no big deal. There's you have your infiltration test from your geotech. It's a chart, you know, of this is what you need for volume flow. It's pretty simple. But then doing a larger house, all of a sudden, had to do the exact same thing because it was just a little bit bigger. I had to write a check for $6,500 and, to a civil outside of the geotech with the infiltration and then, you know, for the design standard. And so then I'm paying a civil to look at the same chart and say, but this is how big your trench needs to be.

I'm like, I know. So so there's some real world cost in in some of this stuff. And then so I wanted to understand if that was something locally we had options for because we're always trying to keep housing affordable or more affordable. And and that's a real you know, that's that's real money. And I know if you have a double wide trailer with a long driveway, you easily go over the 5,000 square feet of hard surface.

And so so I I really wanna know is, like, is is that something that could be modified or we're bound by state? If we're bound by state, we're bound by state, and there's nothing that's gonna be beyond that. But if it's just like, oh, that's just kind of how we've done it, then I would really like to to revisit that. So but but I wanted to know, like, am I just wishing and hoping, or is it or is it law? So

We can respond to that one, before the hearing.

Along that line, and I just read, there was quite a few changes to the exemptions or clarifications to the exemptions in book one. Mhmm. And and some of that had to do with driveways and if I'm not mistaken and just wondered if what Jack's talking about would fall under an exemption at some point, or is it hardline 5,000 square feet and greater?

The the state manual does describe the professionals that are qualified to do your soil testing and infiltration testing. The exemptions that you're talking about in book one are essentially verbatim from the permit itself, actually. They're not even in the Western Washington manual. They are in the county's permit. And those they don't overlap with the the professionals that can do the soils analysis.

The exemptions are about sites or situations or projects that were that don't trigger the requirements of the manual. So it it's a my apologies. I talk with my hands. It's a it's a bad idea when there's a microphone there. But if to answer your question, the exemptions are coming straight from the permit, and, they have been clarified.

So Ecology is interested in making sure that projects that should not be exempted from the manual, that they they do not want to be exempted from stormwater requirements, are not actually being exempted due to misunderstanding of what the exemptions are. So that's why there's a lot of changes in the exemptions. Those came directly from ecology. It doesn't include the qualified professionals. So I will look a little more into the question you've asked.

And and also the clarification on a qualified professional. In the city's the city of Vancouver specifically's permit, it says you have to have a a licensed civil engineer. Where if it's just a qualified professional, if I'm already paying a geotech, then I could just have him give me the chart in the the infiltration. So so there's a couple of things that are, like, versus hiring one professional versus two professionals for the same poll. It would be nice to have some clarification there on that.

Can I ask for a clarification from you? Sorry. So are you interpreting the Clark County stormwater manual as not allowing you to use a geotechnical engineer to do your site assessment?

So I'm not sure. I can just tell you my experience over the last two weeks. It's right. Where I'm hiring, you know, SWT to come out and do an infiltration test for me, And then I'm hiring SGA to come out and tell me how big of a ditch I need for the amount of hard surface that we're infiltrating. So roof you know, where's the where's the roof water going? Like, well, it's 7,000 square feet of roof, and this is the size that we need. And then, and then we have our our driveway and stuff. So so I'm winding up with two different professional.

Alright. So it's the the professional who sizes your stormwater facility has to be a licensed engineer if you're over 5,000 square feet. And that's a different person than the person than who the person who did the site assessment was a geotechnical engineer. Right. Okay. I understand.

Right.

So it's not really it's not the soils and site assessment. It's the facility design. The professional that has to do the facility design Correct. And submit the submittals to the county.

Right. And but if it's under that, I do it myself.

Prepare the submittals to them.

Right. I mean, I still have the infiltration test, but it's it's literally there's the chart, average rainfall, square footage. Here's here's your size. So that's just kind of one of those, you know, always looking in the the gators in the code that are are continuing adding any cost to single panel weather. Understood. And then, you know, my other question is phosphorus control. Like, what how does that what does that look like? Like, where are we getting the phosphorus? Is it is it off of driveways and we're treating, like Yeah. That stuff differently, or what is it from yards? Yeah.

I can talk to that. So there are a lot of different sources of phosphorus. It's a nonpoint pollutant. It can come from anything from fertilizer and and lawn care practices. Or if you have crops or livestock, manure is a source of phosphorus, human waste that may enter the environment through septic systems, and probably dog waste, potentially.

There's there's quite a it's a there's a variety. Am I missing any? I'm I think that's primarily it. But then when the rain hits the ground, it it's all carried downstream. And this is, the most important thing that the county can do to help prevent harmful algal blooms and beach closers in our lakes, as you're probably all aware, it's a the lakes are not just a recreational gem. They're there's an economic value to the lake. There's a lot of tourism and out of town visitors that come for rowing events, and we are often

facing challenges with keeping the lake open due to the harmful algal blooms. So this

is just really an intent like, the most important thing that we can do from a stormwater perspective is to treat for phosphorus. And there's lots of different ways to do that, and we're we would be doing that as a we've chosen to do that countywide as a public works, best practice for public infrastructure, but this would make it a requirement specific to the areas training to Lake River. Because phosphorus, they've determined, is the limiting nutrient, which is the main pollutant that is causing the algae blooms.

So on the main changes of the phosphorus control, is it primarily on the public work side where we're seeing the roads and bridges, or are we looking at changing the design standards for infiltration in single family houses or apartments or what what's what's the big?

The requirement that we're proposing changes where runoff treatment is required to include phosphorus control for any site that triggers minimum requirement number six within that boundary that you saw. And so those are usually sites that are over 5,000 square feet of new or replaced hard surfaces. And so it could be a large home site, could be a subdivision, could be a short plat, could be a commercial or industrial, could be a road, could be a park that has a parking lot. So, really, any type of development within those boundaries that triggers minimum requirement six and has enough hard surface in the ultimate build out of the project would need to require, would need to use a phosphorus type treatment best management practice.

Yeah. I just just mentally am sorry because it's really technical. But

That's okay.

Our roof structure I mean, because the the law right now is it has to act pre European. Right? So I can't the water hits my site. It can't leave my site. It has to infiltrate on my or techno I mean, act as in a manner right here. But they generally speaking, water can't leave my site. So how does that how does that translate? So, like, if all all of my hard surface water is being directly infiltrated. So, like, roofing's directly infiltrated. Driveways are captured, usually run through some kind of bioswales. Is that kind of we're talking and then infiltrated?

If you infiltrate, you will not need a phosphorus treatment BMP as long as the soils below your infiltration facility provide treatment, which in general they do, or you could add a treatment layer. But so it really is only runoff that is leaving your site and needs to pass through a runoff treatment facility. And now in that boundary, it would have to be a phosphorus treatment facility. But it would be from any type of site. If it triggers that requirement and there is an outflow from the site and it has to go through a treatment facility, it would need to be a phosphorus one.

Thank you.

Along that line, you mentioned that agricultural uses of phosphorus that really aren't controlling any type of runoff. It's just natural flows wherever they go. And and how do you propose that would capture the phosphorus for a ag use that's that's going going into into the the local ditch and then downstream from there? Is that even something that could be captured, or is it a limited use of phosphorus eventually or in process?

The manual only comes into effect when you do when you develop or construct on a site in a using a project type or an activity that is not exempt from the manual. So that list of exemptions includes some agricultural uses, forestry, things like that are in the exemptions. But just an existing farm going about their business, they don't trigger the stormwater manual because they're not developing their land or, performing construction. So there's no requirement to for everyone in the Salmon Creek Watershed that's draining to Lake River or Vancouver Lake to provide phosphorus treatment. There we don't have the manual just gets triggered when you develop land.

And so I guess

a follow-up question. If a farm added, you know, a new structure, could would that be a situation where it may? I'd have

to I'd have to review the exact language of the exemptions. It not everything on an agricultural parcel is exempt. It has to do with the precise activity. So I don't wanna speak out of turn. I don't wanna say something wrong. But I will often It's not a universal exemption on agricultural properties, but it has to do with the activity.

And I will offer there are a lot of local resources available for agricultural properties who may want help with manure management BMPs. It's just not a part of the stormwater code manual.

Yeah. I know, family farmers, and, I know there's been some grants in the past where they're able to get, like, a chicken manure storage facility that helps with that. But there's see, there's ample opportunity to reduce farm or to reduce phosphorus in farm waste. And just being on farms, you go, like, there's there's a lot of opportunity that would be greater, I think, than what we're able to capture on these small lot things from a dollars thing. So I'm not saying don't do this.

I think it's great. I think when you protect your water, all for it. But I think there's some tremendous opportunities. So and I'm not sure what part you guys would all play in that, but, it would be nice to see grants or education work works on some of these things to to help with that for sure. So

And I I will just offer that our team is a partner on a program. It has a the name Poop Smart Clark, and it's administered by Clark Conservation District. And, our team actually goes out and collects water quality samples and bacteria, and we'll do DNA testing to help figure out, is it human, is it livestock, or is it dog, to help target outreach for technical and financial assistance. And there is funding or has been funding available through the Natural Resource Conservation Service, NRCS, as well as the local conservation district. So we do help by helping clarify what is that source, and then working with our partners.

And public health has a role as well, and there's funding available for septic system pumping and minor major replacement as well if it's steamed human. And then we do outreach on, canines for clean water where, we'll go out and outreach at dog parks and put up signage and give out poop bags to help reduce all of the sources of phosphorus. So we do have those programs. It's just not a part of the code and manual.

Are the tribes affected by this manual or bound by it?

It's a good question.

If they are on sovereign land, then no. They are not. For the record, Katie Joel, a DPA.

Commissioners, any other questions? Alright. Ladies, do you have anything else to add? Or

See you in two weeks.

I see you in two weeks.

Thank thank you for listening, and, thank you for the great questions.

Yeah. Thanks. I I thought it was an excellent presentation for the amount of pages that are in the stormwater manual. I I went through a substantial chunk of them today, and wow. It's there's a lot going on there.

And I'm impressed that, you know, you're like, it's so it's thousand pages. I was like, well, you did your homework, so thank you for taking the time to dig through it. It's quite the effort.

We're the policy wonk crew. You know? Right. Alright. Alright. Well, if there's no other comments, I think we're adjourned. Mhmm. Thanks, everyone.