Residents Coalition of Chelan County (RC3) submitted three detailed comment letters addressing proposed zoning code text amendments under Chelan County File No. ZTA 25‑248. In three separate comment letters—January 27, February 10, and March 24—RC3 has consistently advocated for clearer, enforceable code, public transparency, and protection of rural character and community interests. Our comments have focused on three major themes:
1. Strengthening Land Use Protections & Preventing Abuse of Code “Tools”
Across the February 4 and March 20 letters, RC3 repeatedly warned that both the existing and proposed versions of Chelan County’s Boundary Line Adjustment (BLA) and exempt subdivision code allow a loophole known as “tiling.”
What is tiling?
A process where landowners use BLAs and exempt 20‑acre subdivisions to create many new lots without going through the subdivision process, thereby avoiding:
- Access and road review
- Water/sewer analysis
- Critical areas review
- Fire protection requirements
- Stormwater management
- SEPA
- Public input
- Consistency checks with the Comprehensive Plan
RC3 cited examples—including a real case in Chelan and a hypothetical scenario—showing how tiling can dramatically increase density with zero public oversight.
RC3’s core concerns
- The Planning Commission’s recommended BLA definition reverts to a 1987 RCW definition that does not prevent wholesale relocation of lots.
- The proposed 20‑acre exemption rule stops iterative tiling but still allows one full round of tiling that can create a de facto subdivision.
- Surveyors have pushed for maximum flexibility, overshadowing public interest.
RC3’s recommended fixes
RC3 urges the County to adopt a BLA definition that:
- Prevents entire relocation of lots, as Chelan did in 2023, or
- Restores the originally proposed definition requiring “minor adjustment” and retention of at least two original boundaries.
RC3 also recommends:
- Limiting exempt subdivisions to no more than five new lots per contiguous ownership, or
- Increasing minimum exempt subdivision lot size to 40 acres (Chelan uses 640 acres).
The March 20 letter emphasizes that many Washington municipalities already define BLAs as “minor” adjustments, reinforcing RC3’s position.
2. Ensuring Responsible Rural Development & Protecting Community Character
In the January 20 letter, RC3 addresses several code sections affecting rural aesthetics, agricultural land use, and neighborhood compatibility.
Storage Containers (CCC 11.88.170)
RC3 supports allowing permanent storage containers only with aesthetic standards to prevent visual blight. We propose:
- Requiring containers to be “painted and kept free of rust to reflect the residential character…”
- Applying aesthetic standards countywide, not just in rural residential zones.
- Limiting the number of containers per parcel based on acreage (1–3 maximum).
Farmstay RV Uses
RC3 supports agricultural tourism but warns of potential abuse by non‑farmers. We recommend:
- No RV sites on farms <5 acres
- Graduated RV site limits based on acreage (5–20 sites)
- Requiring at least 51% of land in active agriculture, mirroring the City of Chelan
Our goal is to ensure Farmstay RV uses genuinely support agriculture rather than becoming disguised RV parks.
3. Improving Noise Code Enforcement Through Objective Standards
RC3 strongly supports augmenting the subjective “reasonable person standard” with decibel‑based noise limits, as used in Douglas County and Leavenworth.
We argue:
- Decibel limits remove ambiguity and improve enforceability.
- Sound meters are inexpensive and easy to use.
- Adoption by Chelan County, along with the current decibel-based standard in Leavenworth would encourage the Sheriff’s Office to acquire equipment.
- Numeric standards are common statewide and should be part of Chelan County’s code.
RC3 supports the originally proposed decibel table and urges the County to reinstate it.
4. Overarching Themes Across All Three Comment Letters
We advocate for:
✔ Transparency and public input
Avoiding loopholes that allow major land use changes without community review.
✔ Protection of rural character
Through aesthetic standards, limits on RV uses, and responsible subdivision practices.
✔ Objective, enforceable standards
Especially in noise regulation and land use definitions.
✔ Alignment with best practices
Citing examples from Chelan, Douglas County, Leavenworth, and multiple Washington municipalities.
✔ Closing loopholes before they cause harm
RC3 believes that code should not rely on the discretion of individual administrators.
Read all three letters: January 27, February 10, and March 24.