KCAA Comments on“Year of the Rural” (YOTR) Draft 2.0 Update

Kitsap County's Department of Community Development (DCD) has released their 2.0 DRAFT updates of the Comp Plan's Rural and Resource Lands Chapter, as well as the updated draft Agricultural Code. Below are our comments.

Written and Prepared by Scott Hall and Bob Geballe

1. Comments on Description of the Function of the Agriculture Advisory Council – Rural and Resource Lands Strategy 5.c.

Recommendation:

The wording in the draft 2.0 YOTR document be changed to the following:

The Council would advise Commissioners and staff on key agricultural matters, including policy, land use, and economic opportunities, while serving as a collaborative forum for stakeholders to shape the long-term sustainability and resilience of the County’s agricultural community. The initial term would be 2026–2027, with potential for extension based on demonstrated need and value. The following sections outline the Council’s structure, goals, objectives, hot topics, membership, and operational details.

Explanation:

The current wording in Rural and Resource Lands Strategy 5.c. reads as follows:

“Form an Agriculture Advisory Council to inform the agricultural community about development of future policies and regulations and act as a resource to farmers regarding incentives and other assistance programs.”

This is precisely backwards of what the relationship should be. The agricultural community should be informing the BoCC about issues relating to agriculture and suggesting future policies and regulations for improving the status of agriculture in the County.

2. Comments on Proposed Changes to the Agriculture Code

Recommendation:

If Kitsap County again picks up the topic of equestrian land uses for potential changes to the Agriculture Code, KCAA should be directly included in any effort to draft equestrian-related land use regulations.

Explanation:

KCAA agrees with all the changes proposed in the Version 2.0 draft Agriculture Code now that the proposed changes related to certain equestrian land uses have been dropped. However, KCAA would like to point out that it is not possible to separate equestrian-related land uses from agricultural land uses without updating the main land use table in Title 17, Zoning. As long as equestrian-related land uses are tied to agriculture land uses, KCAA is a primary stakeholder for any land use discussions that would affect county codes addressing agriculture.

3. Comments on Proposed Comprehensive Plan Rural and Resource Lands Chapter

Recommendation:

KCAA recommends Kitsap County adopt Land Use Goal 5, Strategy 5e with the condition that this particular strategy has a time clock attached to it. Specifically, KCAA recommends this strategy be formally docketed through resolution to ensure it occurs in a timely manner following the adoption of this update.

Explanation:

KCAA believes that Kitsap County has not adequately addressed the topic of agriculture as an integral part of rural life, rural character, and rural resource-based businesses in Kitsap County’s 2025 Year of the Rural (YOTR) update of the Rural and Resource Lands (RRL) chapter of its Comprehensive Plan.

4. Comments on Establishing “Working Lands” as a Recognized Land Use Designation

Recommendation:

Because any in-depth review of ARL criteria and designations has the potential to significantly alter how the County identifies and protects agricultural lands, KCAA suggests all references to “Working Lands” be removed from the current RRL chapter update. If it is found that the concept of “Working Lands” still has value in the future, “Working Lands” can be introduced as a more fully developed concept than it is at the present time.

Explanation:

KCAA believes that Kitsap County is moving farther and farther away from the concepts established in RCW 36.70A regarding agricultural viability and is making it increasingly difficult to establish non-competing land use rules for designated zones where agriculture might occur.

Apparently, establishing an overlay for agricultural “Working Lands” is an attempt by Kitsap County to afford some form of protection for lands historically used for agriculture, but does not affect the underlying zoning. There is so little information about how the Working Lands overlay is supposed to function that it is essentially just a placeholder for something that may or may not ever come to be.

5. General Comments on Lack of Agricultural Resource Lands (ARL) Designation

In the 2025 YOTR RRL chapter update, there continues to be a near total lack of regulatory protection afforded to the lands most suited to long-term agricultural uses in Kitsap County. In every other county in Washington State, each has identified and designated agricultural lands and enacted some form of regulatory protection for at least part of the land base to protect agriculture as a viable natural resource-based industry.

Washington State’s Growth Management Act recognizes three different land use classifications: Urban Lands, Rural Lands, and Resource Lands. Kitsap County’s approach to protecting resource lands and rural lands has been problematic from the start, as the County has been extremely reluctant to designate any land as resource lands, including Agricultural Resource Lands (ARL).

Kitsap County’s Comprehensive Plans have consistently maintained that the County does not contain agricultural lands of long-term commercial significance. As such, there currently is no land designated as ARL and therefore no land protected from competing non-agricultural land uses anywhere in Kitsap County.

Although Kitsap County states it has no ARL, three factors suggest that land which could and/or should have been designated as ARL was, or still is, present in the County:

• Kitsap County government cannot point to any documentation of any process since the inception of the GMA whereby a Finding of Fact established that Kitsap County had no land matching Washington State’s ARL designation criteria. Only a portion of the ARL designation process was completed by 1992. Kitsap County ARL designation criteria were adopted, but were highly exclusive. There is no evidence showing that this criteria was used to determine if, or how much, land matched the local ARL designation criteria.

• Since at least the 2012 update of Kitsap County’s Comprehensive Plan, sufficient doubt has been expressed about the propriety of having no land designated as ARL. Each successive Comprehensive Plan update has included a policy or strategy to revisit ARL designation for potential zoning amendment.



• This Comprehensive Plan RRL chapter update continues the trend of calling for comparing actual conditions against ARL designation criteria. Rural and Resource Lands Use Goal 5, Strategy 5e once again addresses this issue. However, adopting a goal, policy, or strategy to carry out an action cannot substitute for the statutory requirement to actually perform the mandated process—i.e., to complete the full ARL designation process and document the outcome.