What neighbors are telling the City.

To

City of Walla Walla City Council

Re

2026 Critical Areas Ordinance Update, File PLN5-26-0001 - Technical, Legal, and Policy Concerns

1. A policy choice, not a state width

   Argues state law requires using best available science, not any particular width, and that labeling 100 ft 'State Mandated' blurs that distinction.

   Pages 3–4

2. No alternative widths tested

   Says the City's only technical study (Facet, July 1) maps the footprint of 100 ft but never tests 60 ft, 75 ft, or reach-by-reach alternatives.

   Pages 4–5, 10–11

3. Pause, and show the work

   Asks Council to pause adoption, get written Commerce guidance on the Dec. 31 deadline, commission a reach-by-reach analysis, and 'Show the work'.

   Pages 11–12

Read with its date in mind. The review is dated “October 2026” and was filed on the City portal on October 8, one day before the October 9 draft table. It opens by saying there is no dispute that Walla Walla must protect critical areas (p. 2); its account of a records request (p. 10) is WWVAR’s own characterization, which the City has not answered in writing. The quote is from the record; the points are our summaries.

To

Walla Walla Planning Commission

Re

Proposed Updates to Critical Areas Ordinances

1. A transition period

   Asks for a transition period, delaying implementation until the end of 2026 so projects already in planning can adjust.

   Pages 1–2

2. 75 feet versus 100 feet changes lot counts

   Says the difference between 75 ft and 100 ft can change lot counts and project feasibility at a time the state is pushing for more housing.

   Page 1

3. Kennewick’s draft as a comparison

   Points to Kennewick's draft, which it says keeps 75 ft for fish-bearing and 50 ft for non-fish-bearing streams — CreekChecker has not verified Kennewick's adopted text.

   Pages 1–2

Read with its date in mind. Written September 11 to the Planning Commission, before the October 9 draft. The letter opens by recognizing the state’s update requirement and says the association supports responsible growth and environmental stewardship (p. 2). CreekChecker has not verified the Kennewick figures it cites. The quote is from the record; the points are our summaries.

To

City of Walla Walla Planning Commission and Walla Walla City Council

Re

File PLN5-26-0001, 2026 Critical Areas Ordinance Amendments - Proposed 100-foot riparian buffers, WWMC 21.04.650 and Table 6

1. Council has discretion

   Reads RCW 36.70A.172 and WAC 365-195-915 as giving Council discretion to weigh the science against housing, property-rights and growth goals.

   Pages 1–2

2. Measure what the line removes

   Says the SEPA addendum and staff report contain no estimate of developable land, housing units or assessed value removed, and asks the City to measure it.

   Page 2

3. Five code fixes

   Proposes five code fixes: a vesting/transition section, a lots-of-record rule, stronger flexibility tools, nonconforming-structure language, and a reasonable-use path for small infill lots.

   Page 4

Read with its date in mind. Written September 11, before the October 9 draft; Davis also testified at the September 14 hearing. The letter is a scan with no text layer, so the quote was read from the page itself. His acreage arithmetic on page 2 is his own; the City consultant’s July memo puts the buffer area at 268.8 acres today and 757.4 acres as proposed. The quote is from the record; the points are our summaries.

To

Walla Walla City Council

Re

Opposition to Proposed Critical Areas Ordinance

1. Sixteen affordable units on Garrison Creek

   A behavioral-health provider split its Garrison Creek parcel in 2022-26 to build 16 affordable housing units with Department of Commerce help.

   Page 1

2. A vesting deadline after the plat was final

   Says the short plat was finalized Aug. 24, 2026 and the City told it the next week that staying vested required an amended plat, new SEPA and a critical areas report by Sept. 15.

   Page 1

3. Asks the Council to oppose the change

   Calls the buffer an infringement on property rights and asks Council to oppose the change.

   Pages 1–2

Read with its date in mind. Written September 21, before the October 9 draft. The dollar figure and dates are the letter’s own, read from the scanned page. The City’s side of the vesting exchange is not in the record, so this is one party’s account. The quote is from the record; the points are our summaries.

To

Council Members and Commissioners

Re

Proposed Critical Areas Ordinance Amendments

1. Protection yes, a blanket width no

   Opens by supporting protection of critical areas; his objection is to a blanket 100 ft without site-specific evaluation.

   Page 1

2. Learned of it from another person, not the City

   Says he learned of the proposal a month earlier from another person, not the City, and asks for direct notice to substantially affected owners.

   Pages 1–2

3. Fifteen lots, and a list of alternatives

   Estimates the change could cost his planned subdivision 15 lots, and lists alternatives: site-specific widths, averaging, mitigation, rules for existing homes, vesting.

   Page 2

Read with its date in mind. Written September 14, before the October 9 draft; he also testified that evening. The letter is a scan, so the quote was read from the page. His name is shortened here until CreekChecker has contacted him; the full letter is in the City’s packet. The quote is from the record; the points are our summaries.

To

Permits inbox / Pamela Ransier, Development Services

Re

Critical Areas Comments

1. Nearly the whole city is in some critical area

   Reads the City's critical-area maps as putting nearly the whole city inside one or more critical areas, so the rewrite reaches far beyond streams.

   Page 1

2. Terms the draft leaves undefined

   Asks for definitions the draft lacks or leaves vague: 'reasonable use', 'reasonable economic use', 'trail corridor', the RMZ, and the scope of a 'neighborhood analysis'.

   Pages 1–2

3. “Hasty”: study first

   Calls the rewrite 'hasty' and asks for further study before adoption.

   Page 3

Read with its date in mind. Written September 14, before the October 9 draft, which later added a definition of “reasonable use” that partly answers his second point. He states his license and local experience himself. His name is shortened here until CreekChecker has contacted him. The quote is from the record; the points are our summaries.

To

Permits inbox, Development Services

Re

comments regarding proposed Critical Areas Ordinance changes

1. Most creekside land predates any setback

   Notes most stream-adjacent land was developed before any setback existed, so most existing improvements would not be allowed under the new rules.

   Page 1

2. A 15-foot setback on top of the buffer

   Objects to raising the building setback from the buffer edge from 5 ft to 15 ft on top of the wider buffer; suggests 0 ft, or keeping 5 ft.

   Page 1

3. The earliest warning in the record

   Cited by WWVAR, on page 8 of its October review, as the earliest public warning about infill loss.

   WWVAR review, p. 8

Read with its date in mind. Written August 26, the only public comment received before the staff report’s September 4 cutoff and well before the October 9 draft. His name is shortened here until CreekChecker has contacted him. The quote is from the record; the points are our summaries.

To

City Planning Commission public hearing

Re

Critical Areas Ordinance update, PLN5-26-0001 (oral testimony as recorded in draft minutes)

1. A 2022 short plat and the studies he paid for

   Described a small 2022 subdivision on Yellowhawk Creek and the environmental and cultural-resource studies he paid for under the rules then in force.

   Draft minutes, p. 3

2. Would “expect compensation”

   Said that if his lots were not grandfathered he 'would expect compensation' for those costs (minutes' wording).

   Draft minutes, p. 3

3. “Best available science” as a label

   Called 'best available science' an overused term used to justify a predetermined outcome, and asked that all variables be weighed.

   Draft minutes, p. 3

Read with its date in mind. These are the draft minutes’ words, a staff summary rather than a transcript, and they are unapproved: the Planning Commission’s October 5 meeting was cancelled. He gave his title on the record and is named as the minutes name him. Spoken September 14, before the October 9 draft. The quote is from the record; the points are our summaries.

To

City Planning Commission public hearing

Re

Critical Areas Ordinance update, PLN5-26-0001 (oral testimony as recorded in draft minutes)

1. Vesting questions first

   Asked staff procedural and vesting questions before stating his concern.

   Draft minutes, p. 2

2. A growth-area question deferred

   Also questioned development in the Urban Growth Area; staff said that belonged to the Comprehensive Plan hearing, not this one.

   Draft minutes, p. 2

3. A second voice from the same household

   A second speaker from the same household (Pleasant Street) asked for more detail on how best available science sets the widths and said the online map was blurry when enlarged.

   Draft minutes, p. 2

Read with its date in mind. These are the draft minutes’ words, a staff summary rather than a transcript, and they are unapproved: the Planning Commission’s October 5 meeting was cancelled. Spoken September 14, before the October 9 draft. His name is shortened here until CreekChecker has contacted him. The quote is from the record; the points are our summaries.

To

City Planning Commission public hearing

Re

Critical Areas Ordinance update, PLN5-26-0001 (oral testimony as recorded in draft minutes)

1. A direct effect on his business

   Said the changes will affect his business directly.

   Draft minutes, p. 4

2. Parcels he cannot subdivide

   Described being unable to subdivide a parcel that Yellowhawk Creek bisects (outside city limits) and other land along Russell Creek.

   Draft minutes, p. 4

3. One of thirteen speakers

   One of 13 speakers; the hearing ran from 6:39 to 7:39 p.m., and only one resident testified largely in favor.

   Draft minutes, p. 4

Read with its date in mind. These are the draft minutes’ words, a staff summary rather than a transcript, and they are unapproved: the Planning Commission’s October 5 meeting was cancelled. Spoken September 14, before the October 9 draft. The quote is from the record; the points are our summaries.

To

City of Walla Walla Planning Office

Re

WDFW Comments on City of Walla Walla Critical Areas Ordinance (Plan View Case #2026-S-15148)

1. A “technical advisor” that finds “a high level of consistency”

   Calls its own role 'technical advisor' and finds 'a high level of consistency' between the draft and its conservation goals for anadromous fish and protected hawks.

   Page 1

2. 100 feet “may be compliant”; a site evaluation “would be best”

   On Table 6: 100 ft 'may be compliant' with its site-potential-tree-height science, 'however a site evaluation would be best to determine the correct buffer width'.

   Page 7

3. Asks for stricter terms than the draft

   Asks for stricter terms than the draft: no buffer averaging, never below 100 ft at the narrowest point, intrusions limited to the outer 25 percent, deed-recorded protection.

   Pages 7–8

Read with its date in mind. Written August 28, before the October 9 draft. Staff adopted some of WDFW’s requests and kept buffer averaging. This is the only written support for 100 feet in the record. The hosted file is the full Planning Commission packet; the letter begins on page 89. The quote is from the record; the points are our summaries.

To

Members of the City of Walla Walla Planning Commission and City Council

Re

(no subject line; the letter concerns the SPTH200 stream-buffer standard proposed by WDFW)

1. “Not to argue against protecting our waterways”

   Writes 'not to argue against protecting our waterways' but to have SPTH200 described as a policy choice with a specific origin, not 'an unambiguous scientific fact'.

   Pages 1–2

2. WDFW’s own “departure from widespread practice”

   Notes WDFW's own user guide says it extends protection to non-fish-bearing streams as 'a departure from widespread practice' and attaches that guide.

   Pages 1, 3–4

3. Property rights, compensation and tax relief

   Asks that the discussion also cover property rights, compensation for land designated as buffer, and property-tax relief on it.

   Page 2

Read with its date in mind. Written September 14, before the October 9 draft. Pages 3–4 of the letter are a printout of WDFW’s user guide. CreekChecker reads this as conditional support: protective buffers in principle, with objections to how the standard is described. His name is shortened here until CreekChecker has contacted him. The quote is from the record; the points are our summaries.

To

City Planning Commission public hearing

Re

Critical Areas Ordinance update, PLN5-26-0001 (oral testimony as recorded in draft minutes)

1. First speaker, and the only one largely in favor

   First speaker at the hearing and the only one the minutes record as largely supportive.

   Draft minutes, p. 2

2. A practical reservation

   Her reservation was practical: how riparian areas on private land would be implemented and maintained.

   Draft minutes, p. 2

3. One sentence in the minutes

   The minutes give one sentence; no written comment from her is in the packet.

   Draft minutes, p. 2

Read with its date in mind. These are the draft minutes’ words, a staff summary rather than a transcript, and they are unapproved: the Planning Commission’s October 5 meeting was cancelled. Spoken September 14, before the October 9 draft. She named no organization and none is shown. Her name is shortened here until CreekChecker has contacted her; she may prefer to supply her own words. The quote is from the record; the points are our summaries.