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Comment by Nov. 4 on the Thurston County Comprehensive Plan

Loretta Seppanen | Published on 10/27/2025

It’s time to submit comments regarding the draft Thurston County Comprehensive Plan. The hearing before the Board of County Commissioners (BoCC) is on Nov. 4. I’ve provided links to several chapters and sample comments below. Email Thurston2045@co.thurston.wa.us not later than noon on Nov. 4 or comment at the 3:30 p.m. hearing that day.

Chapter 2, Climate. Express appreciation for the new Goal 4: . . . seek to protect and preserve water quality and quantity from drought, sea level rise, and other hazards. This goal and its related policies are consistent with the positions created by the recent LWVTC Water Study. The entirely new climate chapter incorporates many of the Thurston Climate Mitigation Plan statements.

Chapter 7, Housing. You may want to acknowledge positively the addition of Goal 5: Establish a sustainable development pattern by limiting growth and new development in the rural areas to 5% and focusing growth in the urban areas. This is a call for significant new housing to be in large and small cities and the Urban Growth Areas (UGAs) surrounding the cities (plus the small rural Grand Mound UGA). Also ask the supervisors to weigh whether several new development codes related to rural housing are consistent with Goal 5. Specifically question whether the proposed rural detached Accessory Dwelling Unit code and several rural conservation subdivision codes would bring more rapid development than desired in the rural area.


Farmland Preservation
in Chapter 5, Natural Resources. Again, new policies deserving of support – here, creating a new ag zone that reduces development pressure on farms, expanding the lands that can be both farmed and support species under the Habitat Conservation Plan, enhancing Transfer of Development Rights and Purchase of Development Rights farmland preservation programs, and exploring water banking for agriculture.


Four new farmland preservation policies merit comments:

Policy NR-1.A.6 Consider a new agricultural zone . . . outside of the long-term agriculture designation that protects underlying agriculture soils . . . from . . . development pressures and maintains and enhances agricultural viability.In addition to supporting this policy ask the BoCC to turn the policy into action by placing this consideration on the 2026-28 docket.

Policy NR-1.A.11 Continue to support access to lands protected under the Habitat Conservation Plan for conservation grazing, and explore new opportunities to use the lands for native seed and plant cultivation. The original Habitat Conservation Plan included purchasing development rights on ranch land to benefit endangered species and continuing use for grazing cattle. This policy expands the farmlands that can be conserved using the plan’s funding to purchase development rights.

Policy NR-2.B.1 Explore updates to the Transfer of Development Rights and Purchase of Development Rights programs that improve the overall market demand for these programs.A grant funded study, Working Lands Conservation Strategies, is currently underway that aims to identify potential updates to these two programs with a goal of paying landowners for the rights in exchange for not developing the land.

Policy NR-2.B.5 Explore approaches to administering water in cooperation with farmers, including water banking, that would allow farmers to realize value of inchoate or excess water.


Comment on a
Development Code proposal of concern: 20.30A.060 (page 94) (Density Bonus for Rural Residential Resource 1/5 conservation subdivision). This proposal could have benefits for farmland in the zone by permanently precluding future development on most of parcels 20 to 100 acres in size. As written, however, the proposal allows creation of subdivisions with urban density levels – for example, 12 houses squeezed into two acres. Recommendation: Send the proposal back to the Planning Commission to set limits on the density of rural subdivisions; for example, density at no less than one acre per house.

The proposed development code allows a bonus of more housing units when the landowner conserves more than 65% of the parcel for farmland. Instead of dividing the farmland into five-acre parcels, a landowner can create a conservation subdivision on up to 35% of the land. Here are some examples of what is allowed under the current code on a 40-acre farmed parcel:

A landowner can cluster the allowed eight units (40 acres divided by 5) on 35% of the land - a 14-acre subdivision – with each house on 1.75 acres. The remaining 65% or 26 acres of the original farm remains undivided for use as farmland.

If the landowner reduces the subdivision size from 14 to 9 acres and increases the farmland to 31 acres, the landowner gets the bonus of an additional house, creating a subdivision of nine units. At one house per acre the resulting density is still less than typical urban areas.

As the subdivision size decreases as a proportion of the total farm acreage, the bonus housing units increase. At the maximum bonus, the entire subdivision could be reduced to two acres (5% of the 40-acre parcel) with a bonus of 4 additional units – 12 altogether. That results in an urban density level of six houses per acre.

Unfortunately, the development code does not provide clear information about the resulting housing density. This proposal needs recalibration to avoid creating urban density levels in rural areas and still conserve farmland.

Comments are needed related to a different late addition to the development code: 20.30A.031 (page 93). The problem here is the lack of public review, a process concern. As of this writing on Oct. 20, this late addition has not been called to public attention. It is hidden in 125 pages of code with no “red line text to alert the reader to recent changes. Tell the BoCC to send the proposal back to the Planning Commission to allow a full review during 2026. Sending the proposal back would affirm the board’s commitment to public engagement.

info@LWVThurston.org

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Olympia WA 98507