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Evaluation of Planning Costs — Washington State Department of Commerce (January 3, 2023)

Issuer
Congressional materials
Document type
Report

Summary

Evaluation of Planning Costs is a report dated January 3, 2023, prepared by Community Attributes Inc. and LDC Inc. for the Washington State Department of Commerce. The 2022 Supplemental Budget directed Commerce to evaluate the costs for cities and counties of revising comprehensive plans to comply with RCW Chapter 36.70A, the Growth Management Act. Based on an online survey and interviews, the executive summary reports that complex comprehensive plan updates have the highest average cost, at more than $340,000 for cities and nearly $680,000 for counties. It finds that staff labor is typically the largest cost component and that circuit rider services received the highest average ranking among technical assistance options, at 2.4. Survey responses came from 48 cities and 14 counties. The report closes with the technical assistance questions of its survey instrument.

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Cite this document

“Evaluation of Planning Costs — Washington State Department of Commerce (January 3, 2023).” Original at app.leg.wa.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-commerce-reports-cai-com-planning-cost-evaluation-report-a0264bae-7213/, SHA-256 4f8de77c2fa48c2280cb68d87f4724fd738dd087d709dfcf6415c22ee3216255.

Full text

Washington State Department of
Commerce
Evaluation of Planning Costs



January 3, 2023




                        Prepared by:




                        Prepared for:
Community Attributes Inc. tells data-rich stories about communities
            that are important to decision makers.




                                                         President and CEO:
                                                               Chris Mefford


                                                            Project Manager:
                                                                 Elliot Weiss


                                                                   Analysts:
                                                               Cassie Byerly
                                                                  Erin Ezell
                                                                Bryan Lobel
                                                           Michaela Jellicoe
                                                                  Jeff Raker
                                                           Nicole Witenstein

                                                                   LDC Inc.
                                            Clay White, Director of Planning
                                                          Samantha Adams
                                                                 Joel Farias
                                                                  Ian Faulds


                                                  Community Attributes Inc.
                                                 500 Union Street, Suite 200
                                                  Seattle, Washington 98101

                                              www.communityattributes.com
EXECUTIVE SUMMARY
        In the 2022 Supplemental Budget, the Washington State Legislature directed
        the Department of Commerce to conduct an evaluation of the costs for cities
        and counties to review and revise their comprehensive plans to ensure
        compliance with Revised Code of Washington (RCW) Chapter 36.70A Growth
        Management – Planning by Selected Counties and Cities, also known as the
        Growth Management Act (GMA).

        The intention of this directive is to establish a more robust understanding of
        resource expenditures on planning activities for jurisdictions of different
        sizes and staff capacity. Both Commerce and the Legislature want to improve
        guidance to local jurisdictions, identify relevant state resources, and ensure
        future planning requirements are informed by any limitations or needs for
        effective city and county planning.

        This study presents an estimation of baseline costs required for cities and
        counties to comply with the requirements of the GMA. This includes
        assessing the level of effort cities and counties voluntarily commit to for
        successful planning within their communities and will help the state gain
        insight into the types of additional technical support cities and counties
        require to help facilitate GMA planning.

     Costs of Planning Activities
        Jurisdictions, through an online survey, were asked to provide cost estimates
        and additional contextual information in connection to seven distinct
        planning activities:

              New comprehensive plan elements
              Complex comprehensive plan updates
              Minor comprehensive plan updates
              Updates to Shoreline Master Programs (SMPs)
              Updates to Critical Area Ordinances (CAOs)
              Revisions to existing development regulations
              New development regulations
        Analysis, supported by interviews and discussions with working group
        members, indicate that the cost to complete any individual planning activity
        might vary considerably based on the actual content of the activity and the
        level of political and community interest in the content, as well as based on
        the general type of activity. Typically, more complex planning activities have
        wider variation and higher average costs, while more routine planning
        activities have a narrower range of cost estimates. Respondents also indicate
        lower levels of confidence in cost estimates for more complex planning
        activities.

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EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
              Complex comprehensive plan updates have the widest variation in
               total costs for both cities and counties. This activity also has the
               highest average cost among respondents at more than $340,000 for
               cities and nearly $680,000 for counties.
              New comprehensive plan elements, updates to shoreline master
               programs and updates to critical areas ordinance are also highly
               variable in cost. These activities have average costs ranging from
               $85,000 for a critical areas ordinances to $383,000 for new
               comprehensive plan elements.
              Minor comprehensive plan updates have the lowest average cost for
               counties at $28,500 ranging to $53,000 for cities. New and existing
               development regulations also have lower and more consistency in
               average cost across both cities and counties, ranging from $34,000 to
               $40,000. (Exhibit 1 and Exhibit 2)
              Across all planning activities, total costs are generally lower for small
               cities and counties and increase based on population size. However,
               the costs per 1,000 population are highest among small cities and
               counties; in most cases, this is double the cost per 1,000 on average.
                               Exhibit 1. Total Cost for Cities by Activity

         $2,500,000
                                 $2,043,000
                                                                                            30
         $2,000,000

                       $1,465,000
         $1,500,000                                                                         20


                                                      $906,300                              10
         $1,000,000

                                                                 $504,700
           $500,000               $340,700 $367,800                                           0
                       $192,700                                             $260,400 $239,900 Maximum
                                              $52,500 $115,600 $85,100 $39,400 $33,900 Average
                  $0                                                                    -10
                        $5,400      $6,700     $1,500 $2,000 $1,000 $1,100 $1,500      Minimum

           -$500,000                                                                        -20
                 n=       38         29         37      31         35         36      31
                         New Complex Minor            Update Update Existing New Dev
                        Comp Comp Comp                 SMP    CAO Dev Reg Reg
                         Plan  Plan  Plan

        Sources: Community Attributes Inc., 2022; LDC, 2022.




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EVALUATION OF PLANNING COSTS                                                    JANUARY 3, 2022
                           Exhibit 2. Total Cost for Counties by Activity
         $6,500,000
                                  $5,579,400
         $5,500,000                                                                       30


         $4,500,000
                                                                                          20

         $3,500,000
                                                                                          10
                       $2,443,700
         $2,500,000
                                                                                          0
         $1,500,000                                              $1,159,000
                                  $679,400
                       $382,800                $112,500 $505,400 $234,400 $112,500 $125,000 Maximum
                                                                                            -10
           $500,000                            $28,500 $156,300           $37,500 $37,400 Average

           -$500,000    $10,000
                              $6,000 $2,800            $45,000 $6,000 $600     $1,200 Minimum
                                                                                      -20
                          9     12     11                14      13    12        11
                 n=
                         New Complex Minor             Update Update Existing New Dev
                        Comp Comp Comp                  SMP     CAO Dev Reg Reg
                         Plan  Plan   Plan

        Sources: Community Attributes Inc, 2022; LDC, 2022.

        Other key findings on the costs of planning are as follows.

              Excluding the costs for a SEPA/NEPA EIS, the maximum and average
               costs per 1,000 population vary widely across planning activities
               among cities. Generally, more complex planning activities have higher
               maximum and average costs per 1,000.
              Labor costs or the costs for city and county staff time are typically the
               largest component of the cost of planning, on average representing
               more than 50% of total costs for all planning activities.
        Overall, survey responses indicate a medium level of confidence in the cost
        estimates jurisdictions provided across all planning activities (ranging from
        45% to 82% of counties and 47% to 65% of cities). When jurisdictions reported
        low levels of confidence it was typically related to more complex planning
        activities, indicating the more complex the planning activity, the less
        confident respondents were in their cost estimates.

     Drivers of Cost
        Key drivers of cost explored through the survey include the length of time to
        complete planning activities, types of technical tasks required, number of
        consultant contracts, number of stakeholder and public meetings, and the
        types of public engagement used.


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EVALUATION OF PLANNING COSTS                                                  JANUARY 3, 2022
              On average, most planning activities require two years or less to
               complete. Planning activities that require more than two years include
               complex comprehensive plan updates, new comprehensive plan
               elements at the county level, and critical areas ordinance updates.
              Public and stakeholder outreach and data analysis are frequently
               utilized across all planning activities, while modeling and other
               technical methods are less frequent.
              Jurisdictions appear to rely on consultants more heavily for complex
               planning activities, including new comprehensive plan elements,
               complex comprehensive plan updates, updates to critical areas
               ordinances and shoreline master programs.
              The number of consultants rarely exceeds one to five contracts, but a
               small share of cities report more than five contracts for new
               comprehensive plan elements, updates to existing development
               regulations, and implementing new development regulations.
              The number of stakeholder meetings held also appears to vary across
               the different planning activities. Most frequently, planning activities
               require one to five meetings.
              Planning activities typically require at least one public meeting. Only
               for implementing a new development regulation do more than 50% of
               cities indicate no public meetings were required.

     Technical Assistance
        Regardless of size and geography, jurisdictions reported that technical
        assistance of varying type and intensity is desperately needed.

              Data collected from the interviews suggest that on a statewide level,
               planners need the most support when it comes to changes to state,
               regional, or county law and policy. Small and medium cities rank this
               topic highest for additional support. This suggests planners in smaller
               jurisdictions across Washington have a harder time keeping up with,
               understanding the impacts of, and implementing changes to comply
               with state regulations.
              Specific comprehensive plan elements rank second highest among
               areas where planners need additional support. Planners across the
               state have expressed that mandatory elements with technical aspects
               such as capital facilities and transportation take significant amounts
               of coordination between multiple departments, and that it would be
               beneficial for Commerce to provide guiding documents or resources.
        Across Washington, two types of technical assistance stand out for
        jurisdiction’s interest: circuit rider services and model codes and ordinances.
        Both cities and counties in Washington give a high-ranking score for circuit
        rider services. The average rank for circuit rider services is 2.4 (on a scale of



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EVALUATION OF PLANNING COSTS                                           JANUARY 3, 2022
        one to ten where one is highest) and this service received the highest average
        score out of all the types of technical assistance. (Exhibit 3)

        Planners express that model codes and ordinances are generally helpful to
        review as they prepare materials, but highlight a caveat that provided
        examples must be changed significantly to flow with existing local code.

             Exhibit 3. Areas of Greatest Challenges and Technical Assistance
                                 Preferences, All Responses

             Alignment with case law and appeals                                       4.7
                        Capital Facilities Planning                               4
                                      Impact Fees                                                6.7
                                    Critical Areas                             3.9
                                Specific Elements                           3.4
                     Changes to Law and Policies                        3

                         Communications and PR                                        4.5
                        Mediation and Facilitation                                     4.7
              Grant Funds for Technical Assistance                          3.4
         State Approval and Defense from Appeal                             3.3
                         Expand Role of Colleges                            3.4
                       Involve Regional Agencies                                      4.5
                   Master Consultant Agreements                                   4
                              Circuit Rider Services              2.4
                            Data or Analytic Tools                             3.8
                          Model Policy Language                          3.2
                      Model Codes or Ordinance                          3
                                                       1      2    3         4        5      6   7     8   9   10

        Sources: LDC, 2022; Community Attributes Inc, 2022.


     Limitations of this Study and Avenues for Future
     Exploration
        At the time of this report’s issuance, survey responses were received from 48
        cities (17% of Washington’s cities) and 14 counties (36% of Washington’s
        counties). Response rates vary when disaggregating by population, geography
        or GMA planning level. Response rates are highest among large cities and
        counties, Central Puget Sound cities and counties, and fully planning
        jurisdictions. Of the 320 jurisdictions in Washington, CAI and LDC
        performed technical assistance interviews with 56 (17%) representatives of
        cities and counties across the state. There is cross-over between jurisdictions
        participating in the survey and interviews.

        There are several limitations to this study. Most critically, while the study
        aimed to gather data from the largest possible number of Washington cities
        and counties, a limited number of jurisdictions responded within the study
        timeframe. The limited sample size for this survey presents challenges for

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EVALUATION OF PLANNING COSTS                                                              JANUARY 3, 2022
        disaggregating responses based on jurisdictional characteristics and
        identifying trends in responses.

        Avenues for further and future investigation to improve this study,
        incorporating feedback from working group members, include:

              Continue to invest in direct outreach. Secure more responses from
               Eastern and Central Washington, small jurisdictions, and those
               planning partially under GMA to improve representation in the
               sample size. Working group feedback indicated that the Washington
               State Association of Counties and Association of Washington Cities
               could provide support for ongoing outreach and leverage their
               relationships with jurisdictions.
               Survey response rates increased as the consultant team was able to
               schedule additional one-on-one discussions to walk-through the
               survey, streamline data collection efforts, and add to jurisdictions’
               capacities in providing a response. An extended timeframe would
               allow for continued in-depth outreach.
              Elected briefing document. Establish a short briefing document to
               highlight the financial impact of planning requirements, explain the
               need and opportunity for financial and technical resources for
               jurisdictions, and connect this with relevant mandates for
               comprehensive plan updates due in 2024 and other planning activities.
               This document could be shared with local elected officials to highlight
               the importance of participating in the study and secure more survey
               responses.
              Ongoing data collection. Create an opportunity for ongoing and
               future data collection by simplifying the survey instrument, aligning
               survey requests within Commerce and among other state agencies
               attempting to secure information from local jurisdictions, and possibly
               add the survey or data requests as part of approval process or close
               out forms for Commerce grants, as well as upon submittal of notice for
               comprehensive plan and development regulation updates. This could
               include providing a link to the survey or data request through
               Planview or sending the request upon receipt of an ordinance
               submittal through automated messages.




DEPT OF COMMERCE                                                          PAGE VIII
EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
CONTENTS
Introduction .................................................................................................................... 1
Methods of Data Collection and Analysis ........................................................................ 5
Cost Estimates by Planning Activity ............................................................................. 10
Key Drivers of Cost ....................................................................................................... 18
Cost Variability and Differentiation by Jurisdiction Characteristics ............................ 31
Critical Technical Assistance ........................................................................................ 33
Appendices .................................................................................................................... 43




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EVALUATION OF PLANNING COSTS                                                                             JANUARY 3, 2022
        Blank.




DEPT OF COMMERCE                      PAGE X
EVALUATION OF PLANNING COSTS   JANUARY 3, 2022
INTRODUCTION

     Background and Purpose
        In the 2022 Supplemental Budget, the Washington State Legislature directed
        the Department of Commerce (Commerce) to conduct an evaluation of the
        costs for cities and counties to review and revise their comprehensive plans
        to ensure compliance with Revised Code of Washington (RCW) Chapter
        36.70A Growth Management – Planning by Selected Counties and Cities,
        also known as the Growth Management Act (GMA).

        The intention of this directive is to establish a more robust understanding of
        resource expenditures on planning activities for jurisdictions of different
        sizes and staff capacity. Both Commerce and the Legislature want to improve
        guidance to local jurisdictions, identify relevant state resources, and ensure
        future planning requirements are informed by any limitations or needs for
        effective city and county planning.

        This study presents an estimation of baseline costs required for cities and
        counties to comply with the requirements of the GMA. This includes
        assessing the level of effort cities and counties voluntarily commit to for
        successful planning within their communities and will help the state gain
        insight into the types of additional technical support cities and counties
        require to help facilitate GMA planning.

     Alignment with the Collaborative Roadmap Project
        The types of technical assistance addressed within this Evaluation of
        Planning Costs have overlap with those included within the Collaborative
        Roadmap Phase III project (Phase III).




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EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
        Phase III is a two-year project, funded by the Washington State Legislature
        during the 2021 legislative session. The project includes a task force, with
        diverse perspectives, to make recommendations to the Legislature regarding
        reforms to the state’s growth policy framework. In addition, working groups
        have been utilized to provide broad outreach and inform the task force on
        important legislative issues it is considering.

        The task force is discussing whether Commerce should provide greater
        technical assistance. Working groups representing tribal nations, Realtors,
        planners, environmental groups, special districts, builders, state agencies,
        and environmental justice organizations have also considered this topic and
        provided broad support and specific recommendations to the task force for
        consideration.

        In addition, Phase III included a project survey, which asked: “Which of these
        options, if any, do you think Washington State should fund to help local
        governments plan under the Growth Management Act?” The survey
        responses, which can be found on the Collaborative Roadmaps project
        website,1 denoted strong support for assistance, such as the state providing
        model policy language for comprehensive plan updates and broad technical
        assistance to cities and counties.

        Subtle differences from Phase III and this project include the need for
        Commerce assistance and resources for tribes, cities, and counties to better
        coordinate with each other on specific planning issues.

        On November 9, 2022, the Phase III Task force recommended that:

        “The state should provide cities and counties, especially those with fewer
        resources, additional technical resources, on an ongoing basis. The findings
        from the Commerce study of planning costs and comments received from
        working groups and surveys during this project should be utilized to assist in
        prioritizing which technical resources are most important to provide. The
        needs of communities vary, and the options listed below may all be useful to
        certain communities.”

        The task force did not prioritize the types of technical assistance for
        Commerce to provide given the varied needs of communities across the state.
        The full recommendation can be found in Exhibit 4.




        1 https://www.commerce.wa.gov/serving-communities/growth-

        management/collaborative-roadmap-phase-iii/
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EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
            Exhibit 4. Collaborative Roadmap – Task Force Recommendation –
                                      November 2022
         The state should provide cities and counties additional technical resources on an ongoing
         basis, especially those with fewer resources. The findings from the Commerce study of
         planning costs and comments received from working groups and surveys during this
         project should be utilized to assist in prioritizing which technical resources are most
         important to provide. The needs of communities vary, and the options listed below might
         be useful to certain communities.

         a. Technical assistance and resources for tribes, cities, and counties to better
            coordinate with each other on specific planning issues.
         b. State development of model code and/or policy language.
         c. Mediation and facilitation services.
         d. State procurement of and assistance with data tools, like GIS.
         e. Technical assistance on specific planning issues to cities and counties.
         f. Assistance with master consultant agreements for planning services.
         g. Expanding the role of regional agencies, such as councils of government, to provide
            planning services to member jurisdictions.
         h. Communications and PR expertise for assistance on complex/controversial issues.
         i. Expanding the role of colleges and universities in assisting local governments with
            planning activities.
         j. Library of case law that local governments can easily locate.


     Limitations of this Study
        There are several limitations to this Evaluation of Costs study. Most
        critically, while the study aimed to gather data from the largest possible
        number of Washington cities and counties, there was a limited response from
        jurisdictions within the study timeframe. At the time of this report’s
        issuance, survey responses were received from 48 cities (17% of Washington’s
        cities) and 14 counties (36% of Washington’s counties). The limited sample
        size for this survey presents challenges for disaggregating responses based
        on jurisdictional characteristics and identifying trends in responses.
        Challenges cited by jurisdictions in responding to the survey include the
        following:

              Timeframe for completing this study was the most frequently cited
               challenge to completion. This includes both the duration of time
               survey responses could be accepted, as well as the timing of the survey
               itself, which coincided with several other survey requests to
               jurisdictions.
              Capacity was a challenge for some jurisdictions, relating to gathering
               information within their context and resources. Small jurisdictions
               and jurisdictions without or limited planning staff mentioned this
               challenge. Additionally, some larger jurisdictions with unfilled staff
               positions or significant staff turnover also noted this issue.


DEPT OF COMMERCE                                                                 PAGE 3
EVALUATION OF PLANNING COSTS                                             JANUARY 3, 2022
              Cost estimation challenged jurisdictions as well, particularly
               jurisdictions without a recent example of a planning activity. For
               comprehensive planning activities, jurisdictions that most recently
               completed these activities as part of a more comprehensive initiative
               also noted challenges with disaggregating cost estimates. Jurisdictions
               with fewer planning requirements under the GMA needed clarification
               about which activities to provide estimates for.
              Measuring costs for local planning work that exceeds planning
               requirements, as well as unaccounted costs, such as costs to
               administer grants challenged jurisdictions.
              Identifying entities with authority to provide data impacted
               data collection for jurisdictions that use planning consultants or their
               Metropolitan Planning Organization for a substantial portion of their
               planning work.
        Avenues for further and future investigation to improve this study include:

              Continue to invest in direct outreach. Secure more responses from
               Eastern and Central Washington, small jurisdictions, and those
               planning partially under GMA to improve representation in the
               sample size. Working group feedback indicated that WSAC and AWC
               may provide support for ongoing outreach and leverage their
               relationships with jurisdictions.
               Survey response rates increased as the consultant team was able to
               schedule addition one-on-one discussions to walk through the survey,
               streamline data collection efforts, and add to jurisdictions’ capacities
               in providing a response. An extended timeframe would allow for
               continued in-depth outreach.
              Elected briefing document. Create a fact sheet to highlight the
               financial impact of planning requirements, explain the need and
               opportunity for financial and technical resources for jurisdictions, and
               connect this with relevant mandates for comprehensive plan updates
               due in 2024 and other planning activities. This document could be
               shared with local elected officials to highlight the importance of
               participating in the study and secure more survey responses.
              Ongoing data collection. Create an opportunity for ongoing and
               future data collection by simplifying the survey instrument, aligning
               survey requests within Commerce and among other state agencies,
               and possibly adding the survey or data requests as part of approval
               process or close out forms for Commerce grants, as well as upon
               submittal of notice for comprehensive plan and development
               regulation updates. This could include providing a link to the survey



DEPT OF COMMERCE                                                              PAGE 4
EVALUATION OF PLANNING COSTS                                          JANUARY 3, 2022
               or data request through Planview or sending the request upon receipt
               of an ordinance submittal through automated messages.

     Organization of this Report
        The remainder of this report is organized as follows:

              Methods of Data Collection and Analysis. Overview of methods
               used to collect data on planning costs and technical assistance needs
               from cities and counties across the state.
              Cost Estimates by Planning Activity. Summarizes findings on the
               costs of planning activities and the variability of costs.
              Key Drivers of Cost. Details the drivers of costs and factors
               influencing cost estimates by planning activity.
              Cost Variability and Differentiation of Jurisdiction
               Characteristics. Synthesizes findings on cost and drivers of cost
               when disaggregated by jurisdiction characteristics including
               population, geography, and planning level.
              Critical Technical Assistance. Summarizes findings from
               interviews including challenges to completing planning requirements
               and technical assistance needs.
              Appendices. Includes detailed findings and analysis from surveys
               and interviews, as well as the survey instrument.

METHODS OF DATA COLLECTION AND ANALYSIS
        Data collection methods included multiple channels of outreach to gather
        meaningful and sufficient data.

              Engagement with a working group throughout the process to inform
               methods, validate findings, test assumptions, and enhance
               interpretation. Feedback from working group members and Commerce
               staff have been integrated into this report.
              Deployment of a survey to gather quantitative and qualitative data
               on the costs of planning. The survey was released in both online and
               Word formats to provide options for cities and counties to share data.
               A supporting template for gathering data was provided in Excel.
              In-depth interviews focusing on technical assistance needs and
               discussion on the costs of planning provided robust qualitative
               information.

     Working Group Engagement
        A nine-person working group served as an advisory body and provided
        essential feedback on methods, data collection, analysis, and interpretation
        to support this report. The working group is comprised of city, county, and
        state representatives, as well as key consultants and organizations that


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EVALUATION OF PLANNING COSTS                                        JANUARY 3, 2022
        support jurisdictions in planning activities statewide. Membership of the
        work group includes representatives from the following organizations:

              Washington State Association of Counties (WSAC)
              Association of Washington Cities (AWC)
              Snohomish County
              Stevens County
              City of Vancouver
              City of Woodland
              Municipal Research and Services Center (MRSC)
              SCJ Alliance
              Washington State Department of Commerce
        At the time of report issuance, the working group met three times. The first
        meeting focused on the data collection process, survey design, and the
        outreach approach. Feedback from the working group informed updates to
        the survey as well as the outreach and analysis approach. Working group
        members shared feedback on approaches to provide additional support and
        increase response rates, as well as framing for findings and deliverables. The
        third meeting covered survey and interview response rates, the limitations of
        the study with a low response rate, and options for continued outreach and
        future data collection and analysis.

     Planning Cost Survey
        Community Attributes (CAI), with support and feedback from Land
        Development Consultants (LDC) and the working group, designed a survey
        questionnaire to collect detailed cost data and supporting details for seven
        planning activities, as specified by the legislative request:

              Developing a new comprehensive plan element.
              Updating a critical areas ordinance.
              Updating a shoreline master program ordinance.
              Completing a minor update to a comprehensive plan element.
              Completing a complex update to a comprehensive plan element.
              Updating an existing development regulation.
              Implementing a new development regulation.
        The complete survey instrument can be found in Appendix P. The survey
        instrument includes the following elements:

              A brief introduction to the survey and project from the Department of
               Commerce and supported by AWC and WSAC, describing the
               importance of the survey, as well as the potential benefits to each
               community from the study.
              Detailed descriptions of the activities required under GMA to complete
               each of the seven planning activities. The descriptions are designed to

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EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
               define the minimum level of effort required to complete each planning
               activity.
              Questions designed to collect quantitative data on each planning
               activity. Cost questions request estimates for high-level breakdowns of
               cost elements, including labor and staff costs and consultant contracts.
              Additional questions designed to collect qualitative information
               probing the drivers of cost estimates, including an environmental
               impact statement in the activity (SEPA/NEPA EIS), level of public
               engagement and outreach, level of technical work required, length of
               time, and the level of confidence in the cost estimate.
        Multiple options for submission were allowed to maximize the response rate.
        The survey was presented in both an online and Microsoft Word format, to
        ensure ease of use while providing respondents the most time and freedom to
        collect data and use the templates as their direct submission or as interim
        working guides. Some jurisdictions had to coordinate with multiple
        departments and staff members to compile a complete understanding of the
        costs required for the specified planning activities.

        To target a more substantial response, the preliminary survey invitation was
        shared by WSAC and AWC, given their direct relationships with each
        jurisdiction. Counties received the invitation on Oct. 6, 2022; cities received
        the invitation on Oct. 12, 2022. The preliminary close date was Oct. 21, 2022.
        However, after an interim evaluation of response rates, the survey was
        extended through Oct. 31, 2022.

        CAI and LDC sent weekly reminders to each jurisdiction, and the consultant
        team updated out-of-date contact information and conducted phone outreach
        directly to jurisdictions. Multiple touch points were employed ensure
        sufficient survey response and collect qualitative findings. CAI and LDC
        provided support to jurisdictions on an ad hoc basis as they completed the
        survey.

        In an effort to provide additional touch points for jurisdictions to connect
        with the consultant team and representatives from other jurisdictions, CAI
        and LDC hosted an introductory webinar on Oct. 11, 2022. Additional
        webinars were held weekly through the close of the survey. The webinars
        provided an overview of the project and emphasized the potential benefits
        that jurisdictions might see if the Legislature has meaningful information on
        the costs of planning. Attendees were encouraged to ask questions and seek
        one-on-one support with the consultant team as needed.

     In-Depth Technical Assistance Interviews
        In addition to evaluating the costs to complete various types of planning, the
        study also focused on other forms of technical assistance beyond direct

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EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
        financial assistance. These resources might provide additional capacity to
        facilitate implementation of new GMA planning requirements. These are
        listed and discussed in the Critical Technical Assistance section.

        Qualitative in-depth interviews help provide an understanding of
        jurisdiction’s interest in different types of technical services and assistance.
        This effort gave jurisdictions an opportunity to share their experience and
        struggles to remain in compliance with GMA from a technical perspective,
        and this data helps inform the Legislature and Commerce on what types of
        assistance would be utilized, if prioritized and funded.

        Over the course of one month, CAI and LDC contacted every jurisdiction to
        invite them to participate in a one-on-one in-depth interview. The consultant
        team spoke directly with 56 city and county planners, administrators, and
        consultants. Interviews were conducted via Microsoft Teams and by
        telephone, ranging in length from 30 minutes to one hour.

        City and county staff were asked a series of five questions, available in full in
        Appendix Q. Questions covered:

              Primary challenges in completing the planning requirements of
               GMA. Interviewees identified, at a high level, the difficulties they face
               when planning for state compliance.
              General planning activities where they could use support. For
               example, interviewees were asked if they would utilize support such
               as updating their Critical Areas based on best available science or
               capital facility planning.
              Specific types of technical assistance needed. The most helpful
               forms of technical assistance were identified.
        Additional open-ended questions encouraged guided discussion on planning
        activities, types of technical assistance and challenges specific to their
        jurisdiction.

        Two of the three interview questions ask jurisdictions to rank preferences on
        a scale of one to ten where one represents the high end of the scale and ten
        represents the low end of the scale. The combination of ranked and open-
        ended questions provides both qualitative and quantitative data. Together
        with the information collected on the cost of planning activities through the
        survey, the state Legislature can use this data to better assess how
        jurisdictions struggle monetarily and technically to remain in compliance
        with GMA. With this information, the state can work to provide accurate and
        specific assistance to help planners continue to do this required work.




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EVALUATION OF PLANNING COSTS                                           JANUARY 3, 2022
     Survey Response Rates
        Detailed analysis of the survey and interview findings are presented in
        subsequent sections. Overall, the survey received 62 responses from 48 cities
        and 14 counties. This represents 17% of Washington’s 281 cities and 36% of
        Washington’s 39 counties. Response rates vary when disaggregating by
        population, geography, or GMA planning level. Response rates are highest
        among large cities and counties, Central Puget Sound cities and counties,
        and fully planning jurisdictions. (Exhibit 5)

        Limited response rates among Central and Eastern Washington cities and
        counties as well as among partially planning (GMA 4.0/5.0) cities and
        counties limits analysis based on these characteristics. Detailed analysis
        contained in appendices A through N do not include summary findings
        aggregated for Eastern Washington city or partially planning city categories
        due to limited response rates. Additionally, county responses are grouped
        into two population categories (large and small/medium) and two geographic
        categories (east and west). Fully planning counties are also grouped,
        including both GMA 1.0 and 2.0/3.0 into a single category.

                          Exhibit 5. Planning Cost Survey Response Rates


                                                  Response                Response
         Characteristic                  Cities                Counties
                                                    Rate                    Rate
         Population Size
         Large (greater than
         100,000)                            5         50%           7      54%
         Medium (10,000 to 100,000)         16         20%           6      27%
         Small (less than 10,000)           27         14%           1      25%
         Geography
         Central Puget Sound (1.0)          20         24%           3      75%
         Northwest                           6         26%           2      33%
         Southwest                           9         21%           5      63%
         Central                             9         14%           2      22%
         Eastern                             4          6%           2      17%
         GMA Planning Level
         2.0/3.0                            23         17%           9      38%
         4.0/5.0                             5          8%           2      18%
         Total                              48         17%          14      36%

        Sources: Community Attributes Inc., 2022; LDC, 2022.


     Segmentation of Cities and Counties
        Analysis of survey and interview responses are segmented based on
        jurisdictional characteristics, including population size, geography, and GMA
        planning level. Low response rates among certain segments limits the level of
        disaggregation possible for both survey and interview findings.

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EVALUATION OF PLANNING COSTS                                                 JANUARY 3, 2022
              Population Size
                 o Large: 100,000 or greater
                 o Medium: 10,000 to 100,000
                 o Small: less than 10,000
              Geography
                 o Central Puget Sound includes all cities and counties within
                    King, Kitsap, Pierce, and Snohomish Counties.
                 o Northwest includes all cities and counties within Clallam,
                    Island, Jefferson, San Juan, Skagit, and Whatcom Counties.
                 o Southwest includes all cities and counties within Clark,
                    Cowlitz, Grays Harbor, Lewis, Mason, Pacific, Thurston, and
                    Wahkiakum Counties.
                 o Central includes all cities and counties within Adams, Chelan,
                    Douglas, Grant, Kittitas, Klickitat, Okanogan, Skamania, and
                    Yakima Counties.
                 o Eastern includes all cities and counties within Asotin, Benton,
                    Columbia, Ferry, Franklin, Garfield, Lincoln, Pend Oreille,
                    Spokane, Stevens, Walla Walla, and Whitman Counties.
              GMA Planning Level
                 o Fully Planning within the Central Puget Sound (1.0)
                 o Fully Planning (2.0/3.0)
                 o Partially Planning (4.0/5.0)

        Interview findings are classified by population size as noted above. Results
        are also separated by those counties and cities that are fully or partially
        planning under the GMA (Exhibit 26). Fully planning jurisdictions are
        categorized as one of five geographies: Central Puget Sound, Northwest,
        Southwest, Central, and Eastern. Results from partially planning
        jurisdictions are analyzed independently. The geographies are based on
        groupings of the workforce development areas from the Employment Security
        Department.

COST ESTIMATES BY PLANNING ACTIVITY
        Cost estimates by planning activity vary widely among respondents. Drivers
        of these costs include the level of engagement, including both public meetings
        and stakeholder meetings, as well as staff costs, the technical tools employed
        across the different planning activities, complexity of the activity, and the
        length of time to completion. Interviews and discussions with working group
        members indicate that the cost to complete an individual planning activity
        may also vary considerably based on the actual content of the activity, and
        the level of political and community interest in the content.

        All costs presented in this section are based on estimates provided by
        individual jurisdictions and aggregated across all cities or counties in the

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EVALUATION OF PLANNING COSTS                                          JANUARY 3, 2022
        state. Appendix A through N contain additional charts and analysis with
        breakouts based on characteristics of each jurisdiction, including population
        size, geography, and level of planning under GMA.

     Total Costs
        Across all planning activities, total costs are generally lower for small cities
        and counties and increase based on population size.

        Complex comprehensive plan updates have the widest variation in costs for
        both cities and counties. This activity has the highest average cost among
        respondents at more than $340,000 for cities and nearly $680,000 for
        counties. New comprehensive plan elements, updates to shoreline master
        programs and updates to critical areas ordinance are also highly variable in
        cost. These activities have averages costs ranging from $85,000 for a critical
        areas ordinances to $383,000 for new comprehensive plan elements.

        Minor comprehensive plan updates have the lowest average cost for counties
        at $28,500, ranging up to $53,000 for cities. New and existing development
        regulations also have lower and more consistency in average cost across both
        cities and counties, ranging from $34,000 to $40,000. (Exhibit 6 and
        Exhibit 7)

                               Exhibit 6. Total Cost for Cities by Activity
         $2,500,000
                                 $2,043,000
                                                                                             30
         $2,000,000

                       $1,465,000
         $1,500,000                                                                          20


                                                      $906,300                               10
         $1,000,000

                                                                 $504,700
           $500,000               $340,700 $367,800                                            0
                       $192,700                                             $260,400 $239,900 Maximum
                                              $52,500 $115,600 $85,100 $39,400 $33,900 Average
                  $0                                                                    -10
                        $5,400      $6,700     $1,500 $2,000 $1,000 $1,100 $1,500 Minimum

           -$500,000                                                                         -20
                 n=       38         29         37      31         35         36      31
                         New Complex Minor            Update Update Existing New Dev
                        Comp Comp Comp                 SMP    CAO Dev Reg Reg
                         Plan  Plan  Plan

        Sources: Community Attributes Inc., 2022; LDC, 2022.




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EVALUATION OF PLANNING COSTS                                                    JANUARY 3, 2022
                           Exhibit 7. Total Cost for Counties by Activity
         $6,500,000
                                  $5,579,400
         $5,500,000                                                                       30


         $4,500,000
                                                                                          20

         $3,500,000
                                                                                          10
                       $2,443,700
         $2,500,000
                                                                                          0
         $1,500,000                                              $1,159,000
                                  $679,400
                       $382,800                $112,500 $505,400 $234,400 $112,500 $125,000 Maximu
                                                                                            -10
           $500,000                            $28,500 $156,300           $37,500 $37,400 m
                                                                                         Average
           -$500,000    $10,000
                              $6,000 $2,800            $45,000 $6,000 $600     $1,200 -20
                          9     12     11                14      13    12        11
                 n=                                                                   Minimum
                         New Complex Minor             Update Update Existing New Dev
                        Comp Comp Comp                  SMP     CAO Dev Reg Reg
                         Plan  Plan   Plan

        Sources: Community Attributes Inc, 2022; LDC, 2022.



     SEPA/NEPA Costs
        Overall, for cities that conducted a SEPA or NEPA EIS as a part of their
        planning activity, average costs range between $1,100 for updates to existing
        development regulations to $30,700 for new comprehensive plan elements.
        Low estimates for SEPA/NEPA ranged from $300 to $1,000 across all
        planning activities. High estimates for SEPA/NEPA costs ranged from $1,500
        for a new development regulation to $300,000 for a new comprehensive plan
        element. Overall, 41% of responding cities provided SEPA/NEPA costs for a
        complex comprehensive plan update, and at the low end just 13% provided
        SEPA/NEPA costs for a new development regulation.

        Average SEPA/NEPA costs among counties ranged from $1,700 for updates to
        existing development regulations or minor comprehensive plan updates to
        $181,200 for complex comprehensive plan updates. Low estimates for
        SEPA/NEPA costs were $1,200 across all planning activities. High estimates
        for SEPA/NEPA costs ranged from $2,500 for updates of existing
        development regulations or minor comprehensive plan updates to $500,000
        for a complex comprehensive plan update. Among county responses, 56%
        included SEPA/NEPA costs as a part of a new comprehensive plan element,
        while just 18% included these costs for a new development regulation.



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EVALUATION OF PLANNING COSTS                                                  JANUARY 3, 2022
     Per Capita Costs
        Excluding the costs for a SEPA/NEPA EIS, the maximum and average costs
        per 1,000 population vary widely across planning activities among cities.
        Generally, more complex planning activities have higher maximum and
        average costs per 1,000 with the exception that minor comprehensive plan
        updates appear to have a high maximum and average cost per 1,000
        population despite being less complex. (Exhibit 8)

              Average per 1,000 costs for a complex comprehensive plan update is
               $57,600. This is close to twice the resource requirement for a minor
               comprehensive plan update or a new element.
              Among less complicated planning activities, including updates to an
               existing development regulation, implementing a new development
               regulation and updates to a critical areas ordinance range from $4,500
               to $10,000, on average.
              While updates to shoreline master programs and critical areas
               ordinances have higher total costs on average, the cost per 1,000 is
               less when compared to other activities.
        Among counties, the maximum costs per 1,000 population vary widely across
        planning activities and both maximum and average costs per 1,000 are
        generally higher for more complex planning activities. Compared to cities,
        the average cost per 1,000 population is lower across all planning activities.

              Average cost per 1,000 population is highest for a new comprehensive
               plan element at an average of $6,200.
              The most complex planning activities, including new comprehensive
               plan elements, updates to a critical areas ordinance, complex updates
               to a comprehensive plan element, and updates to a shoreline master
               program range from $3,600 and $6,200 per 1,000, on average.
              Minor comprehensive plan updates and new or revised development
               regulations all have average costs of $700 or less per 1,000 population.




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EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
               Exhibit 8. Per 1,000 Population Cost for Cities Excluding SEPA/NEPA by
                                               Activity
            $1,200,000
                                       $964,300
            $1,000,000
              $800,000                             $656,600
              $600,000
              $400,000      $200,700
                                                                          $91,600   $123,200
              $200,000     $22,500     $57,600      $26,400     $63,100                        $53,100
                                                                $10,700   $7,600    $10,000    $4,500
                     $0                                                                                  Max
                              38          29          37          31        36         36       31       Avg
                             New       Complex      Minor       Update    Update    Existing New Dev
                    n=      Comp        Comp        Comp         SMP       CAO      Dev Reg    Reg
                             Plan        Plan        Plan


            Sources: Community Attributes Inc, 2022; LDC, 2022.

             Exhibit 9. Per 1,000 Population Cost for Counties Excluding SEPA/NEPA by
                                              Activity
             $40,000      $34,200
                                                                       $32,400
             $35,000
             $30,000
             $25,000                                        $20,300

             $20,000
                                     $11,300
             $15,000
             $10,000      $6,200
                                     $4,200       $2,700      $3,600   $4,500     $3,600   $2,200        Max
               $5,000                              $700                            $700     $600         Avg
                   $0
                    n=       9         10           11        14         12         12       11
                           New      Complex       Minor     Update     Update    Existing New Dev
                          Comp       Comp         Comp       SMP        CAO      Dev Reg    Reg
                           Plan       Plan         Plan

Sources: Community Attributes Inc, 2022; LDC, 2022.


       Components of Costs
            Labor costs or the costs for city and county staff time are typically the largest
            component of the cost of planning. On average, labor costs represent more
            than 50% of total costs for all planning activities. Contract costs represent
            the largest share of total costs, excluding SEPA/NEPA costs, for complex
            comprehensive plan updates among cities (53%) and updates to a shoreline
            master program among counties (54%). Updates to an existing development
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EVALUATION OF PLANNING COSTS                                                        JANUARY 3, 2022
        regulation and implementing a new development regulation require the least
        contract costs at 27% for cities and 5% for counties for an existing regulation,
        and 18% for cities and 4% for counties for a new development regulation.
        (Exhibit 10 and Exhibit 11)

              Exhibit 10. Labor and Contract Costs as a Share of City Total Costs
                               Excluding SEPA/NEPA by Activity
        90%                                                                                       2,000
               Labor Share Contract Share                                             78%
        80%                                                                                       1,800
                                       70%                                70%
        70%                                                                                       1,600
        60%                                                                                       1,400
               53%               53%                          53%
                                                   45% 47%                                        1,200
        50%          44%   44%
                                                                                                  1,000
        40%                                                         35%
                                                                                27%               800
        30%                                  26%
                                                                                            18%   600
        20%                                                                                       400
        10%                                                                                       200
         0%                                                                                       0
              n=    39         29          38          31       36          36          32
                    New    Complex       Minor      Update    Update      Existing    New Dev
                   Comp     Comp         Comp        SMP       CAO        Dev Reg       Reg
                    Plan     Plan         Plan

        Sources: Community Attributes Inc, 2022; LDC, 2022.




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EVALUATION OF PLANNING COSTS                                               JANUARY 3, 2022
           Exhibit 11. Labor and Contract Costs as a Share of County Total Costs
                              Excluding SEPA/NEPA by Activity

        100% Labor Share Contract Share                                                 92%        2,000
                                 87%                                        87%
         90%                                                                                       1,800
         80%                                                                                       1,600
         70%            65%                                                                        1,400
               59%                                              61%
         60%                                              54%                                      1,200
         50%                                        46%                                            1,000
                    39%
         40%                 32%                                      35%                          800
         30%                                                                                       600
         20%                                                                                       400
                                      7%                                          5%
         10%                                                                                  4%   200
          0%                                                                                       0
            n=     9       10       11                 14         12           12          11
                 New    Complex   Minor             Update      Update       Existing   New Dev
                Comp     Comp     Comp               SMP         CAO        Dev Reg       Reg
                 Plan     Plan     Plan

        Sources: Community Attributes Inc, 2022; LDC, 2022.

        Respondents also included other types of costs not captured by labor or
        consultant contract costs. Other frequently mentioned types of costs include:

              Community outreach, including substantial community meetings and
               communication materials, as well as the resources required for public
               meetings and hearings, were among the top other costs mentioned for
               all planning activities.
              Costs attributed to planning review activities, e.g., preparations for
               City Council and Planning Commission hearings, were significant for
               critical area updates and updating or implementing new development
               regulations.
              Among new and complex updates to comprehensive plan elements,
               research and analysis are among the top other costs.
              Legal reviews are another cost included by respondents, particularly
               for new comprehensive plan elements, minor comprehensive plan
               updates, as well as updates to existing development regulations and
               implementing new development regulations.




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EVALUATION OF PLANNING COSTS                                                 JANUARY 3, 2022
     Respondent Level of Confidence
        Overall, survey responses indicate a medium level of confidence in the cost
        estimates jurisdictions provided across all planning activities (ranging from
        45% to 82% of counties, and 47% to 65% of cities). Jurisdiction responses
        indicate that the more complex the planning activity, the less confident
        respondents were in their cost estimates. For cities, the least confidence in
        estimates was for critical areas ordinance updates and new development
        regulations. For counties, there was less confidence in both complex
        comprehensive plan updates and new comprehensive plan elements.

        Cities reported the highest levels of confidence for updates to shoreline
        master programs, with just 10% reporting a low level of confidence and 39%
        with high confidence. Counties were also most confident in their estimate for
        updating a shoreline master program with 0% reporting low level of
        confidence. (Exhibit 12 and




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EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
        Exhibit 13)

                       Exhibit 12. City Level of Confidence by Activity


                  New Comp Plan           22%             51%         27%

              Complex Comp Plan           17%              62%         21%

                 Minor Comp Plan          21%             47%         32%

                       Update SMP 10%               52%              39%

                      Update CAO           26%              51%        23%

                  Existing Dev Reg    11%              65%

                      New Dev Reg          25%             50%         25%

                                     0%                    50%               100%
                                     Low             Medium          High

               Sources: Community Attributes Inc, 2022; LDC, 2022.




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EVALUATION OF PLANNING COSTS                                           JANUARY 3, 2022
                      Exhibit 13. County Level of Confidence by Activity

                    New Comp Plan           22%               56%       22%

               Complex Comp Plan             27%              45%      27%

                   Minor Comp Plan          20%            50%        30%

                        Update SMP                   67%              33%

                        Update CAO      8%                    83%            8%

                    Existing Dev Reg    9%              64%            27%

                       New Dev Reg      10%             60%           30%

                                       0%                     50%             100%
                                       Low             Medium        High

        Sources: Community Attributes Inc, 2022; LDC, 2022.



KEY DRIVERS OF COST
        Many factors influence the level of effort and costs required to complete
        planning activities. Some of these factors include:

              Length of time required to complete the activity
              Reliance on consultant support
              Level and type of public and stakeholder engagement
              Technical tasks involved
        These drivers of cost highlight useful context in connection to the cost
        estimates provided, as well as framing ongoing and future discussions as to
        areas where resource support might be needed for jurisdictions across
        Washington.

     Length of Time to Completion
        On average, most planning activities require two years or less to complete.
        Planning activities that require more than two years include complex
        comprehensive plan updates, new comprehensive plan elements at the county
        level, and critical areas ordinance updates.

        In line with the variable level of effort of different planning activities, most
        cities reported that it takes less than one year to update or establish new
        development regulations (79% for an update, 83% of responding cities for a
        new regulation) or complete a minor comprehensive plan update (69% of
        responding cities). The largest share of respondents indicated that it takes
        one to two years to complete all other planning activities. A complex
        comprehensive plan and update to a shoreline master program are those

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EVALUATION OF PLANNING COSTS                                            JANUARY 3, 2022
            activities that are more likely to require more than two years (33% and 27%
            share, respectively). (Exhibit 14)

            Counties report greater variability in the length of time required to complete
            planning activities. Overall, 63% of counties responding to the survey
            indicated that it requires more than two years to complete a new
            comprehensive plan update and 64% reported the same length was required
            to complete a complex update to a comprehensive plan element. Most
            respondents indicated that it requires a year or less to complete a minor
            update to a comprehensive plan element. The remaining activities, all
            require one to two years to complete. (Exhibit 15)

                 Exhibit 14. Length of Time for Completion Among Cities by Activity

                         New Comp Plan            28%                      53%               19%

                    Complex Comp Plan        7%                 59%                     33%

                        Minor Comp Plan                        69%                      25%     6%

                             Update SMP           23%                  50%               27%

                            Update CAO                  44%                      47%           9%

                         Existing Dev Reg                           79%                  12% 9%

                            New Dev Reg                             83%                      14% 3%

                                            0%                            50%                   100%
                                                         <1 Year 1-2 Years >2 Years


            Sources: Community Attributes Inc, 2022; LDC, 2022.

               Exhibit 15. Length of Time for Completion Among Counties by Activity

                         New Comp Plan       13%         25%                     63%

                    Complex Comp Plan        9%         27%                      64%

                        Minor Comp Plan                       60%                      40%

                             Update SMP 7%                          64%                  29%

                            Update CAO           17%                50%                 33%

                         Existing Dev Reg               42%                      50%           8%

                            New Dev Reg                36%                       64%

                                            0%                            50%                   100%
                                                 <1 Year             1-2 Years         >2 Years
Sources: Community Attributes Inc, 2022; LDC, 2022.

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EVALUATION OF PLANNING COSTS                                                              JANUARY 3, 2022
     Year of Last Example
        Cities drew from examples dating as far back as 1995 for a new
        comprehensive plan element; however, most examples were from after 2015
        across all the different planning activities. Most examples were from 2021 or
        2022.

        City respondents were more consistent in drawing from 2021 or 2022 for new
        development regulations (88% of examples) and updates to existing
        development regulations (84% of examples). Likely related to the cycle of
        planning requirements, examples were drawn from a larger span of years
        after 2015 for critical areas ordinance updates, new comprehensive plan
        elements, and complex comprehensive plan updates.

        The examples counties used mostly ranged across the years after 2017. More
        recent examples were provided for critical areas ordinance updates and new
        development regulations (grouped from 2017 to 2022) with a wider range for
        complex comprehensive plan updates (grouped from 2013 to 2024). Most
        updates to existing development regulations are from up-to-date examples in
        2022 (80% of examples).

     Types of Technical Tasks
        Public and stakeholder outreach and data analysis are frequently utilized
        across all planning activities, while modeling and other technical methods
        are less frequent.

        Cities most frequently employ modeling as part of more complex
        comprehensive plan updates (48% share of cities) or a new comprehensive
        plan element (40%). They are least likely to conduct outreach activities when
        establishing new development regulations (38%), while outreach is most
        frequently used as part of new comprehensive plan elements (75%). Data
        analysis is least frequently used for implementing a new development
        regulation (27%). (




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EVALUATION OF PLANNING COSTS                                        JANUARY 3, 2022
        Exhibit 16)

        Almost all counties report using outreach and data analysis as part of a
        shoreline master program update (93%) while data analysis is least
        commonly employed for implementing new development regulations (36%).
        Outreach activities are frequently used across all activities, with more than
        50% of counties indicating this as a task they utilized. Modeling activities are
        reported most frequently for complex comprehensive plan updates (64%) and
        least frequently for minor comprehensive plan updates and implementing
        new development regulations (7%). (

        Exhibit 17)




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EVALUATION OF PLANNING COSTS                                          JANUARY 3, 2022
                Exhibit 16. Types of Technical Tasks Used by Cities by Activity

                                                                          73%    Data Analysis
            New Comp                               40%
              Plan                                                         75% Modeling
                                                                                 Outreach
                                                            54%
             Complex                                     48%                     Other
            Comp Plan                                        56%
                                 10%
                                                              54%
           Minor Comp                     23%
              Plan                                                   67%
                                    15%
                                                              54%
           Update SMP                     23%
                                                               58%
                                    13%
                                                              54%
          Update CAO                      23%
                                                                    63%
                                     17%
                                                       42%
           Existing Dev             13%
                Reg                                          52%
                                    13%
                                           27%
         New Dev Reg           6%
                                                  38%
                                    13%
                          0%        20%          40%          60%          80%      100%

        Sources: Community Attributes Inc, 2022; LDC, 2022.




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EVALUATION OF PLANNING COSTS                                                     JANUARY 3, 2022
               Exhibit 17. Types of Technical Tasks Used by Counties by Activity

                                                                        57%                   Data Analysis
            New Comp                                        43%
              Plan                                                            64%             Modeling
                                                                                              Outreach
                                                                                          79%
             Complex                                                          64%             Other
            Comp Plan                                                               71%
                                    14%
                                                            43%
           Minor Comp          7%
              Plan                                                      57%
                                    14%
                                                                                                  93%
           Update SMP                                       43%
                                                                                                  93%
                                                29%
                                                                                          79%
          Update CAO                                  36%
                                                                                          79%
                                          21%
                                                                  50%
           Existing Dev             14%
                Reg                                                                 71%
                                          21%
                                                      36%
         New Dev Reg           7%
                                                                        57%
                                          21%
                          0%        20%           40%              60%               80%           100%



        Sources: Community Attributes Inc, 2022; LDC, 2022.

        Other types of technical tasks that jurisdictions completed within planning
        activities include:

               Goal, policy, code, and ordinance writing are common technical tasks
                noted by respondents for all planning activities.
               Research and analysis including land use and mapping analysis are
                technical tasks mentioned for most types of planning activities.
               Other frequently mentioned forms of technical tasks include planning
                review and staff reports, technical meetings, legislative presentations,
                coordination with regional partners and state agencies, as well as
                stakeholder and community coordination and outreach including
                community materials.




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EVALUATION OF PLANNING COSTS                                                                    JANUARY 3, 2022
     Number of Consultant Contracts
        Jurisdictions appear to rely on consultants more heavily for complex
        planning activities, including new comprehensive plan elements, complex
        comprehensive plan updates, updates to critical areas ordinances and
        shoreline master programs. The number of consultants rarely exceeds one to
        five contracts, but a small share (6%) of cities reports more than five
        contracts for new comprehensive plan elements, updates to existing
        development regulations and implementing new development regulations (




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EVALUATION OF PLANNING COSTS                                      JANUARY 3, 2022
        Exhibit 19)

        Consultants are less frequently engaged for new development regulations,
        with 72% of cities in the survey reporting that zero consultant contracts were
        utilized, as well as for revised development regulations, with 67% reporting
        zero consultant contracts. In some cases, cities appear to require a large
        number of contracts for a new comprehensive plan or development
        regulations, while counties do not appear to exceed one to five contracts for
        any of the identified planning activities. (Exhibit 18 and




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EVALUATION OF PLANNING COSTS                                        JANUARY 3, 2022
        Exhibit 19)

         Exhibit 18. Number of Consultant Contracts Reported by Cities by Activity

              New Comp
                                       28%                           67%                 3% 3%
                 Plan
               Complex
                                      21%                            79%
              Comp Plan
             Minor Comp
                                                  61%                            39%
                Plan

             Update SMP                 32%                            68%

            Update CAO                  36%                                64%
              Existing Dev
                                                     67%                         28%     3% 3%
                   Reg

            New Dev Reg                              72%                          22%    3% 3%

                             0%             20%         40%          60%         80%      100%
                                  0         1 to 5         5 to 10     10 to 50         >50

        Sources: Community Attributes Inc, 2022; LDC, 2022.




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EVALUATION OF PLANNING COSTS                                                             JANUARY 3, 2022
           Exhibit 19. Number of Consultant Contracts Reported by Counties by
                                         Activity

                New Comp
                                     33%                        67%
                   Plan
                 Complex
                                   25%                         75%
                Comp Plan
               Minor Comp
                                                      91%                           9%
                  Plan

               Update SMP          29%                         71%

            Update CAO                38%                           62%
               Existing Dev
                                                      92%                           8%
                    Reg

            New Dev Reg                               91%                           9%

                              0%         20%       40%        60%         80%        100%
                                                         0                      1 to 5

        Sources: Community Attributes Inc, 2022; LDC, 2022.

        The types of technical tasks that require consultant support include:

               Research and technical analysis are among the most frequently
                mentioned technical tasks that require consultant support. This
                includes mapping, field work, research on best available science and
                best practices, environmental assessment and review, and
                transportation and growth modeling. This technical analysis supports
                a variety of plan types including transportation, land use, economic
                development, and critical areas.
               Other technical tasks mentioned include drafting code and ordinances,
                policy development, presentations for legislative review and legislative
                process support, plan development and technical writing, legal review,
                and community engagement support and public meeting facilitation.




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EVALUATION OF PLANNING COSTS                                               JANUARY 3, 2022
     Number of Stakeholder Meetings
        The number of stakeholder meetings held also varies across the different
        planning activities. Most frequently, planning activities require one to five
        meetings. The largest share of city respondents indicated that no stakeholder
        meetings were held to implement a new development regulation (69%),
        update an existing development regulation (57%), and update a minor
        comprehensive plan update (56%). More than five stakeholder meetings were
        reported for a new comprehensive plan element (51%). (Exhibit 20)

        Like cities, the number of stakeholder meetings varies across planning
        activities for counties. Counties report no stakeholder meetings most
        frequently for minor comprehensive plan updates. Most activities require
        between one and five meetings, except updates to a shoreline master
        program, for which 50% of responding counties indicate that more than five
        stakeholder meetings are required. (




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EVALUATION OF PLANNING COSTS                                        JANUARY 3, 2022
        Exhibit 21)

        Exhibit 20. Number of Stakeholder Meetings Reported by Cities by Activity

                    New Comp Plan            31%                     51%           8% 10%

               Complex Comp Plan             28%               38%         7%      28%

                   Minor Comp Plan                  56%                      38%         3% 3%

                        Update SMP           26%                     65%                10%

                        Update CAO                 44%                     50%           6%

                    Existing Dev Reg                 57%                    35%         3%    5%

                       New Dev Reg                       69%                      31%

                                       0%                       50%                      100%
                                         0         1 to 5        5 to 10         10 to 50

        Sources: Community Attributes Inc, 2022; LDC, 2022.




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EVALUATION OF PLANNING COSTS                                                        JANUARY 3, 2022
           Exhibit 21. Number of Stakeholder Meetings Reported by Counties by
                                         Activity

                    New Comp Plan                  44%               22%         22%     11%

               Complex Comp Plan                   42%         8%          33%          17%

                   Minor Comp Plan                       64%                     27%     9%

                        Update SMP           29%                 50%               7% 14%

                        Update CAO           23%               46%                23%     8%

                    Existing Dev Reg          33%                      58%                8%

                       New Dev Reg             36%                  36%           18%    9%

                                       0%                       50%                       100%
                                         0          1 to 5       5 to 10          10 to 50

        Sources: Community Attributes Inc, 2022; LDC, 2022.


     Number of Public Meetings
        Planning activities typically require at least one public meeting. Most
        typically, planning activities for cities require between one and five meetings.
        More than a third of cities report requiring more than five public meetings
        for a new comprehensive plan element, updates to a critical areas ordinance,
        updates to a shoreline master program, and a complex comprehensive plan
        update. Only for implementing a new development regulation do more than
        50% of cities indicate no public meetings were required. (




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EVALUATION OF PLANNING COSTS                                                           JANUARY 3, 2022
        Exhibit 22)

        More than 50% of responding counties report more than five public meetings
        as a part of updates to a critical areas ordinance, implementing a new
        development regulation, update to a shoreline master program, and a
        complex update to a comprehensive plan. (Exhibit 23)




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EVALUATION OF PLANNING COSTS                                      JANUARY 3, 2022
            Exhibit 22. Number of Public Meetings Reported by Cities by Activity

                    New Comp Plan       13%              36%                            21% 3%

               Complex Comp Plan            17%           34%            17%           31%

                   Minor Comp Plan      13%                    59%                      28%

                        Update SMP 10%                   45%                 29%          16%

                        Update CAO       14%              42%                    36%          8%

                    Existing Dev Reg        23%                    56%                   21%

                       New Dev Reg                  52%                    30%           15% 3%

                                       0%                          50%                         100%
                                        0     1 to 5         5 to 10       10 to 50          >50

        Sources: Community Attributes Inc, 2022; LDC, 2022.

          Exhibit 23. Number of Public Meetings Reported by Counties by Activity

                    New Comp Plan       11%              44%                   33%           11%

               Complex Comp Plan             25%        8%      25%                42%

                   Minor Comp Plan                36%                36%                27%

                        Update SMP 7%              29%               36%                29%

                        Update CAO          23%           23%            31%             23%

                    Existing Dev Reg    8%                   58%                 17%      17%

                       New Dev Reg          18%          27%               36%            18%

                                       0%                          50%                         100%
                                        0          1 to 5          5 to 10             10 to 50

        Sources: Community Attributes Inc, 2022; LDC, 2022.




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EVALUATION OF PLANNING COSTS                                                             JANUARY 3, 2022
     Other Types of Public Engagement
        More than 48% of cities and counties report using a website for public
        engagement across all planning activities. Almost all counties used a website
        for a shoreline master program update (93%). They less frequently report
        using language translation services or other forms of public engagement as
        part of their planning activities.

        Surveys were employed by cities most for new comprehensive plan elements
        (52%) or complex comprehensive plan updates (48%) and less frequently used
        in implementing new (15%) or updating existing development regulations
        (19%). Counties conducted surveys most frequently as part of shoreline
        master program updates and complex comprehensive plan updates (64%).

        Language translation services are the least frequently reported type of public
        engagement used in planning activities. Cities use language translation
        services most frequently for new comprehensive plan elements and complex
        updates to a comprehensive plan (more than 20%). Counties most frequently
        report using language translation services for complex updates to a
        comprehensive plan and critical areas ordinance updates. (Exhibit 24 and
        Exhibit 25)




DEPT OF COMMERCE                                                           PAGE 34
EVALUATION OF PLANNING COSTS                                        JANUARY 3, 2022
        Exhibit 24. Other Types of Public Engagement Used by Cities by Activity


            New Comp
                                                                                   Website
              Plan                                                   67%           Survey
                                                          52%
                                        21%                                        Language
                                         23%
                                                                                   Translation
             Complex
                                                         48%                       Other
            Comp Plan                                    48%
                                             27%
                                     17%
           Minor Comp
              Plan                                                  63%
                                               33%
                               6%    17%

           Update SMP                                           60%
                                                   35%
                               6%
                               6%

          Update CAO                                           56%
                                             27%
                                 10%
                                  13%
           Existing Dev
                Reg                                       52%
                                       19%
                                8%
                                 10%

         New Dev Reg                                     50%
                                     15%
                               6%
                                    13%
                          0%        20%            40%        60%          80%      100%



        Sources: Community Attributes Inc, 2022; LDC, 2022.




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EVALUATION OF PLANNING COSTS                                                     JANUARY 3, 2022
        Exhibit 25. Other Types of Public Engagement Used by Counties by Activity

                                                                        57%
                                                29%                                               Website
            New Comp                14%
                                                      36%                                         Survey
              Plan                                                            67%
                                                                  52%
                                        21%                                                       Language
                                         23%
                                                                                          79%     Translation
                                                                              64%
             Complex                            29%                                               Other
                                                29%
            Comp Plan                                         48%
                                                              48%
                                            27%
                                     17%
                                                                        57%
                                                            43%
           Minor Comp               14%
                                          21%
              Plan                                                        63%
                                                  33%
                                     17%
                               6%
                                                                                                   93%
                                                                              64%
                               7%
           Update SMP                           29%
                                                                         60%
                                                   35%
                               6%
                               6%
                                                                                          79%
                                                                        57%
                                                29%
          Update CAO                                  36%
                                                                    56%
                                            27%
                                 10%
                                  13%
                                                                                    71%
                                                            43%
           Existing Dev        7%
                                        21%
                Reg                                               52%
                                       19%
                                8%
                                 10%
                                                                                    71%
                                                            43%
                               7%
         New Dev Reg               14%
                                                                  50%
                                   15%
                               6%
                                  13%
                          0%        20%           40%              60%               80%           100%



        Sources: Community Attributes Inc, 2022; LDC, 2022.

        Respondents noted a variety of other types of public engagement, including:

              For comprehensive planning projects, other types of public
               engagement include the public comment process, web-based
               engagement tools, civic and group presentations, and public events, as
               well as workshops and open houses.
              Other public engagement methods mentioned by respondents include
               mailers, newsletters and email, one-on-one meetings, phone calls and
               counter inquiries, as well as technical and business stakeholder
               engagement, map visualizations and permit modifications.




DEPT OF COMMERCE                                                                                       PAGE 36
EVALUATION OF PLANNING COSTS                                                                    JANUARY 3, 2022
COST VARIABILITY AND DIFFERENTIATION BY JURISDICTION
CHARACTERISTICS
        Detailed analysis of costs and drivers of costs by planning activity are
        documented in appendices A through N. Analysis presented in the
        appendices provides summary findings by jurisdictional characteristics,
        including population size, geography, and GMA planning level.

     Population Size
        Across all planning activities, total costs are generally lower for small cities
        and counties and increase based on population size. However, the costs per
        1,000 are highest among small cities and counties and in most cases, this is
        double the cost per 1,000 on average.

     Geography
        Key cost differences for cities between geographic areas include:

              The Central Puget Sound (CPS) region has significantly higher total
               costs on average for new comprehensive plan elements, while the
               region is closer in costs to other regions for complex comprehensive
               plan updates, minor comprehensive plan updates, shoreline master
               program updates, and development regulations.
              The CPS region also has higher total costs per 1,000 for complex
               comprehensive plan updates and minor comprehensive plan updates.
              Southwest cities and counties report higher total costs than all other
               regions for critical areas ordinance updates.
              The Southwest region also has the highest costs per 1,000 population
               for development regulations.
              Like the Central Puget Sound region, the Northwest region has high
               costs for a new comprehensive plan element but is similar to other
               regions for all other planning activities.
              The Northwest region has lower costs per 1,000 population for minor
               updates to a comprehensive plan element and updates to existing
               development regulations.
              Central Washington cities have costs similar to other regions for
               complex updates to a comprehensive plan element and updates to
               existing development regulations, but lower costs on average for all
               other planning activities.
        Among counties, Western Washington has higher total costs than Eastern
        Washington for new comprehensive plan elements, complex comp plan
        updates, minor updates, critical area ordinance updates and development
        regulations. These costs are closer in alignment for shoreline master program
        updates. However, Western Washington has lower per-1,000 costs than

DEPT OF COMMERCE                                                              PAGE 37
EVALUATION OF PLANNING COSTS                                           JANUARY 3, 2022
        Eastern Washington across many planning activities, while it is more
        comparable for complex comprehensive plan updates and critical area
        ordinance updates.

     Variability
        Generally, the range of cost estimates was wider among complex planning
        activities, particularly among larger jurisdictions, the Central Puget Sound
        (CPS) region, and Western Washington.

              Cost estimates for new comprehensive plan elements had a wide range
               for large cities and counties, CPS region, and Western Washington.
              For complex comprehensive plan updates, there is a wide range for
               both large and medium size cities, large counties, CPS and the
               Southwest region, and counties in Western Washington.
              For critical areas ordinance updates, there is a wide range for both
               large and medium size cities and all counties. By region, there is wide
               variability in cost within the CPS and Southwest regions, and Western
               Washington counties.
              Shoreline master program updates had a wider range for large cities,
               and cities within the Southwest region as well as large counties, and
               Western Washington counties.
        Cost estimates for more routine planning activities had a narrower range of
        cost estimates.

              Minor comp plan updates had a wider range for small cities, large
               counties, CPS and Southwest regions among cities, as well as Western
               Washington counties.
              For existing development regulations, there was a narrower range of
               estimates across all cities, but a wider range for large counties, CPS
               and Southwest regions among cities, and Western Washington
               counties.
              New development regulations generally had a narrower range, but
               wider for medium cities and CPS regions, large counties, and Western
               Washington counties.




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EVALUATION OF PLANNING COSTS                                        JANUARY 3, 2022
CRITICAL TECHNICAL ASSISTANCE
        CAI and LDC performed technical assistance interviews with 56
        representatives of cities and counties, representing 17% of the 320
        jurisdictions in Washington, . Findings from these interviews are described
        and compared in three different ways depending on the nature of the data.
        Interview results are analyzed on a statewide scale, based on population size
        and region. Regardless of size and region, jurisdictions reported that
        technical assistance of varying type and intensity is desperately needed.

         Exhibit 26. Distribution of Interviewees by Population Size and Geography

                                                            Total       Response
          Characteristic                  Responses
                                                        Jurisdictions     Rate
          Population Size
          Large (greater than
          100,000)                                  2             23         9%
          Medium (10,000 to 100,000)               24            103        23%
          Small (less than 10,000)                 18            194         9%
          Geography
          Central Puget Sound                      18              86       21%
          Central                                  18              75       24%
          Eastern                                   8              79       10%
          Northwest                                 8              29       28%
          Southwest                                 4              51        8%


        Sources: LDC, 2022; Community Attributes Inc, 2022.

        Technical assistance findings can be used to give equitable support to
        jurisdictions across the state, especially those in regions with specific
        planning difficulties.

     Challenges in Completing GMA Planning Requirements
        Interviewees were asked to identify if any of the below challenges were
        applicable to their jurisdiction.

                  Knowing the requirements of GMA
                  Knowing changes in state law or policy
                  Having financial resources
                  Political challenges with requirements to create new policies or
                   codes
        Of those areas of assistance, having the financial resources and staff
        availability to remain in compliance with GMA are noted as applicable by the
        most jurisdictions. For many cities and counties, their only option is to hire
        consultants to help with long-range, large-scale planning tasks such as
        updating the comprehensive plan. The ability to hire consultants does relieve

DEPT OF COMMERCE                                                                   PAGE 39
EVALUATION OF PLANNING COSTS                                                JANUARY 3, 2022
        local planning staff; however, it takes considerable time to manage a
        consultant contract and it is a costly endeavor.

        Jurisdictions expressed concern that the amount of effort it takes to update a
        comprehensive plan is severely underestimated and therefore the proper
        amount of grant funds has not been provided in the past. Many explained the
        level of detail needed to update elements such as the capital facility plan,
        transportation, and utilities take a significant amount of effort and
        coordination between multiple departments.

        House Bill 1220 is a reoccurring factor described by planners as impacting
        the time and money required for this latest comprehensive plan update. HB
        1220 amended GMA and requires local governments to “plan and
        accommodate” for housing that is affordable to all income levels. Planners
        explain that it is taking significant time to entirely understand this
        amendment and addressing it in plan implementation.

        Jurisdictions across the state, regardless of size and geography, are generally
        comfortable with knowing about state requirements and changes moving
        through the state Legislature. Many jurisdictions find Commerce’s website to
        be a very helpful resource and feel the agency does a good job at keeping it
        updated with relevant information during the comprehensive planning
        period. Jurisdictions in the Central Puget Sound area also mentioned the
        helpful resources of the Puget Sound Regional Council (PSRC) and the
        Municipal Research and Services Center when it comes to comprehensive
        planning information. In small jurisdictions and those interviewed in Central
        and Eastern Washington, planners indicate they use consultants as a guide
        to remain in compliance with GMA.

        Political challenges that come with remaining in compliance with GMA and
        creating new law or policy is a lesser concern for many jurisdictions.
        Washington state planners express that the work performed is political in
        nature and they generally do not experience major hurdles when it comes to
        remaining in compliance with state requirements. Interviewees state that
        political challenges sometimes occur with city councils, the public, or even
        internal to planning departments, but not to the point where this presents a
        significant challenge.




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EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
     Planning Activities Requiring Additional Support
        Changes to State, Regional or County Law and Policy
        Data collected from the interviews suggest that on a statewide level,
        planners need the most support when it comes to changes to state, regional,
        or county law and policy (Exhibit 27). Small and medium cities (




DEPT OF COMMERCE                                                          PAGE 41
EVALUATION OF PLANNING COSTS                                       JANUARY 3, 2022
        Exhibit 28 and Exhibit 29, respectively) rank this topic highest for
        additional support. This suggests planners in smaller jurisdictions across
        Washington have a harder time keeping up with, understanding the impacts
        of, and implementing changes to comply with state regulations. Planners in
        the Central Puget Sound region noted PSRC as a great resource that helps to
        relay information and requirements coming from the state to local planners.
        Councils of government can provide similar assistance to local jurisdictions.

             Exhibit 27. Areas of Greatest Challenges and Technical Assistance
                                  Preferences, All Responses

             Alignment with case law and appeals                                       4.7
                        Capital Facilities Planning                               4
                                      Impact Fees                                                6.7
                                    Critical Areas                             3.9
                                Specific Elements                           3.4
                     Changes to Law and Policies                        3

                         Communications and PR                                        4.5
                        Mediation and Facilitation                                     4.7
              Grant Funds for Technical Assistance                          3.4
         State Approval and Defense from Appeal                             3.3
                         Expand Role of Colleges                            3.4
                       Involve Regional Agencies                                      4.5
                   Master Consultant Agreements                                   4
                              Circuit Rider Services              2.4
                            Data or Analytic Tools                             3.8
                          Model Policy Language                          3.2
                      Model Codes or Ordinance                          3
                                                       1      2    3         4        5      6   7     8   9   10

        Sources: LDC, 2022; Community Attributes Inc, 2022.

        All regions and jurisdiction sizes ranked changes to state, regional or county
        law and policy similarly. On average jurisdictions ranked this between 2 and
        3.3, where one is most important and ten is least important (Exhibit 27).
        Help in understanding changes to state law and policy is considered the most
        important need; planners express less concern about where exactly the
        support is coming from.

        Specific Comprehensive Plan Elements
        Specific comprehensive plan elements rank second highest among areas
        where planners need additional support (Exhibit 27). Planners across the
        state have expressed that mandatory elements with technical aspects such as
        capital facilities and transportation take significant coordination between
        multiple departments, and that it would be beneficial for Commerce to
        provide guiding documents or resources. This is especially difficult for cities
        with a small or no planning team (

DEPT OF COMMERCE                                                                                 PAGE 42
EVALUATION OF PLANNING COSTS                                                              JANUARY 3, 2022
        Exhibit 28). Those who would find this helpful made said that
        comprehensive planning is a local document, unique to the jurisdiction, and
        so they would not be interested in a “plug and play”-type document provided
        by the state. They said there are things the state could do to provide
        foundational support. Interviewees mention that the Passport to 2044 series
        of online workshops to support the comprehensive plan periodic updates,
        hosted by the Puget Sound Regional Council, the Washington State
        Department of Commerce, and the Municipal Research and Services Center,
        has been a helpful resource. They noted that this is exactly the type of
        service to be provided whether or not the state is in a comprehensive
        planning period.

        Critical Areas Based on Best Available Science
        Additional support for critical areas based on best available science ranked
        on average at 3.9 across the state (Exhibit 27). Small cities in the Central
        and Southwest regions (Exhibit 1732 and Exhibit 177, respectively) tend to
        rank this activity as an area needing additional support (3.6 and 3.4,
        respectively), more than other regions and cities. When looking at this area
        of support by size of jurisdiction, small cities and counties across the board
        are more interested in having critical area data provided. Medium and large
        jurisdictions ranked this area of assistance at five, which might be
        interpreted as a neutral position. Many jurisdictions rely heavily on state
        agencies and consultants for critical areas planning, which can be very
        expensive.

        Impact Fees
        Jurisdictions in the Central and Eastern regions (Exhibit 173 and Exhibit
        174 respectively) were much less interested in receiving additional support
        for impact fees than all the Western regions (Exhibit 175 through Exhibit
        177) in Washington. This reflects the fact that many smaller jurisdictions in
        Central and Eastern Washington simply do not collect impact fees because
        the level of development is so low, or because they are not able to charge
        impact fees. For the larger jurisdictions on the western side of the state, the
        consensus was that planners and consultants had a good grasp at creating
        and updating impact fees. Generally, small cities ranked impact fees lower in
        importance than medium and larger cities (




        2 Additional exhibits with breakouts by geography are available in Appendix O.


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EVALUATION OF PLANNING COSTS                                           JANUARY 3, 2022
        Exhibit 28 through Exhibit 30).

        Capital Facility Planning
        Every region except the Central region (Exhibit 173) ranked capital facility
        planning between 4.8 and 5.3. This falls into the neutral category of needing
        additional support, indicating jurisdictions may not necessarily need
        assistance, but would not refuse it if provided. The Central region ranked
        capital facility planning a high 2.8. This indicates the significant effort it
        takes for jurisdictions to update a highly technical element. Overall, smaller
        cities ranked this activity higher than medium and large size cities (




DEPT OF COMMERCE                                                            PAGE 44
EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
        Exhibit 28 through Exhibit 30).

        Alignment with Case Law and Growth Management Hearings
        Board Appeals
        Alignment with case law and GMA Hearings Board appeals ranked between
        a 4.3 and 5.4 in all regions except for the Southwest region (Exhibit 173
        through Exhibit 177). The Southwest region (Exhibit 177) ranked this
        activity a 2.1, very important for receiving additional support. Many
        planners express the importance of understanding what cases are ongoing
        and the details of the review. These planners expressed how helpful it would
        be to have cases publicly available so others can learn from the experience.
        Notably, jurisdictions that have not had problems with appeals felt this did
        not apply to them. There were a few planners who recognize that even
        though they have not been appealed, this would still be useful assistance.

     Interest in Technical Assistance
        The types of technical assistance surveyed include the following:

                 Model codes or ordinance provisions
                 Model policy language for comprehensive plan updates
                 State provision of data or analytical tools
                 Circuit rider services to directly staff local planning activities
                 Master consultant agreements for planning services
                 Involve regional agencies, such as councils of government, to
                  provide planning services to member local jurisdictions
                 Expand the role of colleges and universities in assisting local
                  governments with planning activities
                 Optional process of state approval and defense from appeal
                 Allow some portion of comprehensive plan grant funds to be used
                  for technical assistance
                 Mediation and facilitation services
                 Communications and public relations expertise for assistance in
                  complex/controversial planning issues
                 Any others recommended by jurisdiction
        Across Washington, two types of technical assistance stand out for
        jurisdiction’s interest: circuit rider services and model codes and ordinances.
        Both cities and counties in Washington give a high-ranking score for circuit
        rider services. The average rank for circuit rider services is 2.4, and this
        service received the highest average score out of all the types of technical
        assistance. The next closest is model codes or ordinances, with an average
        rating of 3.0 (Exhibit 27). Planners express that model codes and ordinances
        are generally helpful to review as they prepare materials but comes with the



DEPT OF COMMERCE                                                            PAGE 45
EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
        caveat that provided examples must be changed significantly to flow with
        existing code.

        Circuit rider services are especially highly ranked in small cities (population
        under 10,000) in the Central and Eastern regions (Exhibit 173 and Exhibit
        174 respectively). This may suggest that there is greater need for
        experienced planning staff in these jurisdictions. Almost all jurisdictions said
        that any help with their long-range planning from circuit rider services
        would free up current planning staff to avoid burnout, do more community
        work, and catch up on local permitting backlogs. Others indicated that it
        would help avoid challenges in managing staff loads during different levels of
        intensity between planning cycles. One county planner indicated that the
        planners who do not often need this type of service may still rank it high
        because they know how helpful it could be for smaller jurisdictions.

        All counties interviewed show great interest in the opportunity to secure
        state approval and defense from appeal. Counties ranked state approval and
        defense from appeal as the highest level of interest out of all the types of
        technical assistance surveyed (Exhibit 32). This result suggests that
        counties are receiving many appeals and may spend a lot of time and money
        processing these appeals.

        When asked if there are any other types of technical assistance that would be
        useful in their jurisdiction, a common answer was “any type of assistance to
        increase education of planning commissioners.” There is an even distribution
        geographically where this was mentioned as a needed technical assistance.
        Some of the other types of assistance mentioned include translation services,
        scaling model ordinances and policy, equity, more promotion for university
        planning programs, and more direction with critical areas.




DEPT OF COMMERCE                                                             PAGE 46
EVALUATION OF PLANNING COSTS                                          JANUARY 3, 2022
             Exhibit 28. Areas of Greatest Challenges and Technical Assistance
                    Preferences, Small Population Size, Washington Cities

             Alignment with case law and appeals                                          4.8
                        Capital Facilities Planning                                3.8
                                      Impact Fees                                                               7.4
                                    Critical Areas                                 3.8
                                Specific Elements                                  3.8
                     Changes to Law and Policies                             3.2

                         Communications and PR                                        4.3
                        Mediation and Facilitation                                   4.1
                               Grant Funds for TA                   2.5
         State Approval and Defense from Appeal                               3.2
                         Expand Role of Colleges                            2.9
                       Involve Regional Agencies                                       4.5
                   Master Consultant Agreements                                     3.9
                             Circuit Rider Services               1.9
                            Data or Analytic Tools                            3.5
                          Model Policy Language                              3.2
                      Model Codes or Ordinance                      2.5
                                                       1      2         3       4         5         6       7       8       9   10

        Sources: LDC, 2022; Community Attributes Inc, 2022.

             Exhibit 29. Areas of Greatest Challenges and Technical Assistance
                  Preferences, Medium Population Size, Washington Cities

             Alignment with case law and appeals                                               4.9
                        Capital Facilities Planning                                             5.1
                                      Impact Fees                                                5.2
                                    Critical Areas                                             4.9
                                Specific Elements                                   3.6
                     Changes to Law and Policies                        2.6

                         Communications and PR                                            4.3
                        Mediation and Facilitation                                                      5.8
                               Grant Funds for TA                                             4.6
         State Approval and Defense from Appeal                                     3.6
                         Expand Role of Colleges                                            4.7
                       Involve Regional Agencies                                         4.3
                   Master Consultant Agreements                                         4.0
                             Circuit Rider Services                          2.9
                            Data or Analytic Tools                                     4.1
                          Model Policy Language                                     3.6
                      Model Codes or Ordinance                                           4.5
                                                       1      2         3           4         5         6       7       8       9    10

        Sources: LDC, 2022; Community Attributes Inc, 2022.


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EVALUATION OF PLANNING COSTS                                                                  JANUARY 3, 2022
        The sample for large jurisdictions is limited to one interview.

             Exhibit 30. Areas of Greatest Challenges and Technical Assistance
                    Preferences, Large Population Size, Washington Cities

             Alignment with case law and appeals                                                                       8.5
                        Capital Facilities Planning                                      5.0
                                      Impact Fees                                                  6.0
                                    Critical Areas                                       5.0
                                Specific Elements          1.0
                     Changes to Law and Policies                               3.5

                         Communications and PR                                                               7.0
                        Mediation and Facilitation                                       5.0
                               Grant Funds for TA                                                  6.0
         State Approval and Defense from Appeal                      2.0
                         Expand Role of Colleges                     2.0
                       Involve Regional Agencies                          3.0
                   Master Consultant Agreements                        2.5
                             Circuit Rider Services                                                          7.0
                            Data or Analytic Tools            1.5
                          Model Policy Language                                            5.5
                      Model Codes or Ordinance                       2.0
                                                       1         2         3    4    5         6         7         8   9     10



        Sources: LDC, 2022; Community Attributes Inc, 2022.




DEPT OF COMMERCE                                                                                PAGE 48
EVALUATION OF PLANNING COSTS                                                             JANUARY 3, 2022
             Exhibit 31. Areas of Greatest Challenges and Technical Assistance
                Preferences, Medium Population Size, Washington Counties

             Alignment with case law and appeals                         2.3
                        Capital Facilities Planning                                                  5.9
                                      Impact Fees                                                 5.4
                                    Critical Areas                   2.1
                                Specific Elements                          2.8
                     Changes to Law and Policies                          2.5

                         Communications and PR                                     3.5
                        Mediation and Facilitation                                    4
                               Grant Funds for TA                                    3.9
         State Approval and Defense from Appeal                1.4
                         Expand Role of Colleges                                           4.3
                       Involve Regional Agencies                                                            6.5
                   Master Consultant Agreements                                                            6.3
                             Circuit Rider Services                      2.3
                            Data or Analytic Tools                        2.5
                          Model Policy Language                                        4
                      Model Codes or Ordinance                            2.6
                                                       1        2         3        4        5      6        7       8   9     10

        Sources: LDC, 2022; Community Attributes Inc, 2022.

        The sample for large jurisdictions is limited to one interview.

             Exhibit 32. Areas of Greatest Challenges and Technical Assistance
                  Preferences, Large Population Size, Washington Counties

             Alignment with case law and appeals           1
                        Capital Facilities Planning                  2
                                      Impact Fees                                                                              10
                                    Critical Areas         1
                                Specific Elements                              3
                     Changes to Law and Policies           1

                         Communications and PR                                                                          8.5
                        Mediation and Facilitation                                                              7
                               Grant Funds for TA                    2
         State Approval and Defense from Appeal            1
                         Expand Role of Colleges                                                       6
                       Involve Regional Agencies                                                               7
                   Master Consultant Agreements                                                             6.5
                             Circuit Rider Services                                                            7
                            Data or Analytic Tools                             3
                          Model Policy Language                                3
                      Model Codes or Ordinance                       2
                                                       1        2         3        4        5      6        7       8   9     10

        Sources: LDC, 2022; Community Attributes Inc, 2022.



DEPT OF COMMERCE                                                                                        PAGE 49
EVALUATION OF PLANNING COSTS                                                                     JANUARY 3, 2022
        Jurisdictions also provided suggestions for additional ideas for technical
        assistance in survey responses. Responses focused on additional research
        resources as well as improvements in planning coordination, review
        processes, and existing technical assistance programs. Some jurisdictions
        note the significant cost and difficulty in accessing planning-related data.
        These jurisdictions suggest this could be partly addressed through the
        creation of centralized data resources. Centralized data resources mentioned
        include data sets and standard scope of service templates for jurisdictions to
        use with consultants.

        Several jurisdictions in the survey recommended improved planning mandate
        coordination and funding processes. Several noted the need to better align
        mandate timetables with local planning processes. Improved coordination
        was also recommended for GMA implementation and state agency decisions,
        such as for infrastructure plans and rule changes. Others recommended that
        state planning mandates should allow for more flexible implementation
        based on size of jurisdiction or regional differences in planning processes and
        allow local communities to develop unique visions and plans.

        Several jurisdictions also recommended improved coordination in
        environmental assessment processes. Suggestions include improved
        integration of assessments, particularly those that link assessments in
        comprehensive plans to project-level reviews, and for additional resources to
        cover environmental defense legal fees that result from assessments.

        Jurisdictions also suggested ways to improve existing technical assistance
        programs. Some noted that addressing planning grant reporting
        requirements that are time-consuming and potentially cost-prohibitive.
        Others recommended increasing state resources to more adequately support
        local community engagement activities. Additional recommendations were
        offered for more state technical on-call assistance and best practice
        information on how jurisdictions address specific GMA challenges.




DEPT OF COMMERCE                                                            PAGE 50
EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022
APPENDICES

Appendix A. New Comprehensive Plan Element Detail for
Cities by Characteristic
Survey response data provided by cities and counties for each planning activity are
presented in detail within Appendix A through N. Responses are segmented by city
characteristics including:

      Population size:
          o Large City (more than 100,000 population)
          o Medium City (10,000 to 100,000 population)
          o Small City (less than 10,000 population)
      Geography:
          o Central Puget Sound (CPS) includes all cities within King, Kitsap, Pierce
             and Snohomish counties.
          o Northwest includes all cities within Clallam, Island, Jefferson, San Juan,
             Skagit and Whatcom counties.
          o Southwest includes all cities within Clark, Cowlitz, Grays Harbor, Lewis,
             Mason, Pacific, Thurston and Wahkiakum counties.
          o Central includes all cities within Adams, Chelan, Douglas, Grant, Kittitas,
             Klickitat, Okanogan, Skamania and Yakima counties.
          o Eastern includes all cities within Asotin, Benton, Columbia, Ferry,
             Franklin, Garfield, Lincoln, Pend Oreille, Spokane, Stevens, Walla Walla
             and Whitman counties.
      GMA Planning Level
          o Fully Planning within the Central Puget Sound (1.0)
          o Fully Planning (2.0/3.0)
          o Partially Planning (4.0/5.0)
The breakout for Eastern region and partially planning (4.0/5.0) are excluded from the
presentation of results due to limited response data.




DEPT OF COMMERCE                                                              PAGE 51
EVALUATION OF PLANNING COSTS                                           JANUARY 3, 2022
  Exhibit 33. Total Costs for a New Comprehensive Plan Element by Characteristic
 $1,600,000
              $1,465,000                  $1,465,000
                                                                                               30
 $1,200,000
                                                                                               20
                        $900,000

  $800,000                                                                                     10

                                                   $414,400
              $419,600         $414,400                                             $414,400 0Maximum
                                          $324,800     $350,000
  $400,000
                        $238,300                 $168,500    $230,400
                                                                                               -10
                               $91,600                 $111,800                     $115,100
                                                              $87,100                           Average
        $0                                                                                     -20
               $22,400$6,200 $5,400        $16,500$6,200 $6,700$15,000               $5,400
                                                                                       21       Minimum
       n=        5        15       18        15     5      9      6
                LargeMediumSmall            CPS North- South-Central                2.0/3.0
                 City City City                  west west


       Exhibit 34. Per 1,000 Population Cost (excluding SEPA/NEPA) for a New
                    Comprehensive Plan Element by Characteristic
 $250,000

                               $200,700             $200,700                             $200,700Max
 $200,000


 $150,000
                                           $118,280           $123,240


 $100,000

                     $52,290
                                                      $45,420             $42,900
  $50,000                      $37,060
              $14,390                                           $28,620                  $27,620
                                            $16,130                       $16,740                    Avg
              $3,380 $8,870
       $0
       n=       5        15        19         16         5        9         6                  21
              Large Medium Small             CPS       North- South- Central              2.0/3.0
               City  City   City                        west west




DEPT OF COMMERCE                                                                              PAGE 52
EVALUATION OF PLANNING COSTS                                                           JANUARY 3, 2022
        Exhibit 35. Labor and Contract Costs as a Share of Total Costs for a New
                     Comprehensive Plan Element by Characteristic
 70%                                                                                             2,000
                                                                        Labor Share Contract Share
                      63%
                                                             60%                   59%                           1,800
 60%                                                                 55%                             56%
         52%                       53%                                                                           1,600
                                                    50%
 50%        46%               45%                      46%                                                       1,400
                                                                        42%                               42%
                                                               38%            38%                                1,200
 40%
                        32%                                                                                      1,000
 30%
                                                                                                                 800

 20%                                                                                                             600
                                                                                                                 400
 10%
                                                                                                                 200
  0%                                                                                                             0
    n=      5     15    19                            16       5      9      6                            21
          Large Medium Small                         CPS     North- South- Central                   2.0/3.0
           City  City   City                                  west   west



Exhibit 36. Level of Confidence in Cost                            Exhibit 37. Length of Time to Complete
 Estimates for a New Comprehensive                                  a New Comprehensive Plan Element
    Plan Element by Characteristic                                             by Characteristic

  Large City                                                         Large City     20%         40%              40%
                  25%             50%         25%
                                                                   Medium City      21%               64%            14%
Medium City           27%         53%         20%
                                                                      Small City         35%              47%        18%
  Small City      17%         50%         33%
                                                                           CPS 14%                  57%           29%
                                                                      Northwest         25%                75%
         CPS      19%             69%          13%
                                                                     Southwest                56%              33%     11%
  Northwest            40%              60%                             Central                      67%             17%
  Southwest 13%             38%          50%

    Central       20%               80%                                  2.0/3.0         35%               55%         10%

                                                                                   0%                50%               100%
                                                                               <1 Year 1-2 Years >2 Years
       2.0/3.0        26%     37%         37%

                 0%               50%           100%
                  Low        Medium           High


DEPT OF COMMERCE                                                                                           PAGE 53
EVALUATION OF PLANNING COSTS                                                                        JANUARY 3, 2022
Exhibit 38. Types of Technical Tasks Required for a New Comprehensive Plan Element
                                   by Characteristic

                                                                                          100%
         Large City                                           60%
                                                                                          100%
                                                                                 88%
       Medium City                                    44%
                                                                                 88%
                                                      44%
                                                              59%
          Small City                            33%
                                                                63%               Data Analysis
                              7%
                                                                                  Modeling
                                                                                  Outreach
                                                                     70%          Other
               CPS                                40%
                                                                     70%
                                      20%
                                                                    67%
         Northwest                              33%
                                                                    67%
                                                        50%
                                                                                 89%
         Southwest                                           56%
                                                                                          100%
                                          22%
                                                                    67%
            Central                             33%
                                                                    67%



                                                                               83%
             2.0/3.0                                  43%
                                                                                 87%
                                          22%
                       0%           20%         40%         60%          80%         100%


Exhibit 39. Number of Consultant Contracts for a New Comprehensive Plan Element
                                 by Characteristic
          Large City              40%                       40%                20%      0
         Medium City           27%                           73%
                                                                                        1 to 5
           Small City          26%                          68%                      5% 5 to 10
                                                                                        10 to 50
                CPS           19%                       75%                          6%
           Northwest                 40%                           60%
           Southwest                  44%                         44%           11%
             Central          17%                           83%

               2.0/3.0          29%                          67%
                         0%          20%        40%         60%          80%         100%




DEPT OF COMMERCE                                                                                   PAGE 54
EVALUATION OF PLANNING COSTS                                                                JANUARY 3, 2022
  Exhibit 40. Number of Stakeholder                             Exhibit 41. Number of Public Meetings
 Meetings for a New Comprehensive                                  for a New Comprehensive Plan
   Plan Element by Characteristic                                     Element by Characteristic

  Large City     20%        40%         20% 20%                    Large City       20% 20%           40%        20%

Medium City          33%          47%       13%                 Medium City             27%          47%         20%

   Small City        32%           58%            5%                  Small City    16%       47%          21% 16%



        CPS           44%          38%      13%                              CPS 13% 25%            31%     25%        6%

   Northwest     20%          60%           20%                    Northwest        20% 20%           40%        20%

  Southwest      22%          56%         11%     11%              Southwest 11%          44%              33%   11%

     Central     17%          67%           17%                         Central                83%               17%



      2.0/3.0    24%              62%             10%                    2.0/3.0 14%          43%         24%    19%

                0%            50%               100%                               0%               50%           100%
                 0 1 to 5 5 to 10 10 to 50                                     0 1 to 5 5 to 10 10 to 50 >50


Exhibit 42. Other Types of Public Engagement Used for a New Comprehensive Plan
Element by Characteristic
                                                                       80%
   Large City                                                          80%
                                                          60%
                                 20%
                                                                             88%
 Medium City                                                    69%
                                   25%
                                                   50%
                                                    52%
   Small City                              37%
                        11%
                       7%


                                                                70%
         CPS                                              60%
                                   25%
                                   25%
                                                   50%
   Northwest                                       50%
                             17%
                                         33%
                                                                      78%
   Southwest                                    44%
                           11%                                        Website
                                         33%
                                                        56%           Survey
     Central                                    44%
                                         33%
                           11%                                        Language
                                                                      Translation
                                                                      Other
                                                  48%            74%
      2.0/3.0                     22%
                                  22%
                0%          20%           40%          60%        80%          100%


DEPT OF COMMERCE                                                                                     PAGE 55
EVALUATION OF PLANNING COSTS                                                                  JANUARY 3, 2022
Appendix B. New Comprehensive Plan Element Detail for
Counties by Characteristic
Responses are segmented by county characteristics including:

      Population size:
          o Large county (more than 100,000 population)
          o Small and medium county (less than 100,000 population)
      Geography:
          o West includes the following counties:
                 Central Puget Sound (CPS) counties including King, Kitsap, Pierce
                    and Snohomish.
                 Northwest counties including Clallam, Island, Jefferson, San Juan,
                    Skagit and Whatcom.
                 Southwest counties including Clark, Cowlitz, Grays Harbor, Lewis,
                    Mason, Pacific, Thurston and Wahkiakum.
          o East includes the following counties:
                 Central counties including Adams, Chelan, Douglas, Grant,
                    Kittitas, Klickitat, Okanogan, Skamania and Yakima Counties.
                 Eastern counties including Asotin, Benton, Columbia, Ferry,
                    Franklin, Garfield, Lincoln, Pend Oreille, Spokane, Stevens, Walla
                    Walla and Whitman .
      GMA Planning Level
          o Fully Planning including Central Puget Sound or 1.0 planning counties
             and 2.0/3.0 planning counties
          o Partially Planning (4.0/5.0)
Geographic data are aggregated into two categories due to limited response rates within
more detailed geographies. The breakout for partially planning (4.0/5.0) are excluded
from the presentation of results due to limited response data.




DEPT OF COMMERCE                                                             PAGE 56
EVALUATION OF PLANNING COSTS                                          JANUARY 3, 2022
  Exhibit 43. Total Costs for a New Comprehensive Plan Element by Characteristic
  $2,600,000 $2,443,700              $2,443,700                    $2,443,700           Maximum

  $2,200,000                                                                             30


  $1,800,000
                                                                                         20

  $1,400,000
                                                                                         10
  $1,000,000
               $735,000
                                     $634,700                                            0
   $600,000                                                         $426,300
                          $152,200              $136,300                                Average
                        $101,100                $68,000                                  -10
   $200,000

                $10,000 $35,100       $74,300 $10,000                $10,000
  ($200,000)                                                                             -20
                                                                                        Minimum
        n=        4      5              5            4                    8
                LargeSmall/Med         West       East            Fully Planning
                County County


       Exhibit 44. Per 1,000 Population Cost (excluding SEPA/NEPA) for a New
                    Comprehensive Plan Element by Characteristic
  $40,000
                          $34,210                        $34,210                   $34,210      Max
  $35,000

  $30,000

  $25,000

  $20,000

  $15,000
                          $10,160                        $10,660
  $10,000                                                                          $6,740
               $3,920                                                                           Avg
                                           $4,460
    $5,000                                  $2,600
               $1,200
       $0
        n=       4       5                     5            4                         8
               Large Small/Med                West         East                Fully Planning
               County County




DEPT OF COMMERCE                                                                           PAGE 57
EVALUATION OF PLANNING COSTS                                                        JANUARY 3, 2022
      Exhibit 45. Labor and Contract Costs as a Share of Total Costs for a New
                   Comprehensive Plan Element by Characteristic
   90%    85%                                                                               2,000
                                                                    Labor Share Contract Share
   80%                                                                                                 1,800

   70%                                                                                                 1,600
                              60%                60%                                                   1,400
   60%                                                        57%
                                                                                         54%
                                                                                                       1,200
   50%                                                                                         44%
                                                                    41%                                1,000
                       38%                             38%
   40%
                                                                                                       800
   30%
                                                                                                       600
   20%          14%                                                                                    400
   10%                                                                                                 200

    0%                                                                                                 0
     n=   4       5                                5             4                           8
        Large Small/Med                           West          East                       Fully
        County County                                                                    Planning



Exhibit 46. Level of Confidence in Cost                      Exhibit 47. Length of Time to Complete
 Estimates for a New Comprehensive                            a New Comprehensive Plan Element
    Plan Element by Characteristic                                       by Characteristic

     Large                                                        Large
                            75%           25%                                      25%            75%
     County                                                      County
  Small/Med                                                    Small/Med
                      40%           40%   20%                                        50%               50%
   County                                                       County



                                                                       West                    100%
         West                80%          20%
                                                                       East        33%                67%
         East          50%          25%   25%



                                                             Fully Planning 13% 25%                   63%
Fully Planning 13%           63%          25%
                                                                              0%               50%             100%
                0%             50%          100%
                                                                          <1 Year 1-2 Years >2 Years
                     Low     Medium       High



DEPT OF COMMERCE                                                                                  PAGE 58
EVALUATION OF PLANNING COSTS                                                               JANUARY 3, 2022
Exhibit 48. Types of Technical Tasks Required for a New Comprehensive Plan Element
                                   by Characteristic

                                                         50%
             Large                              33%
             County                                                  67%

                                                                          71%
         Small/Med                                             57%
          County                                                          71%
                                   14%
                                                                                Data Analysis
                                                                                Modeling
                                                                                Outreach
                                                       44%
                                                                                Other
               West                                    44%
                                                              56%
                                         22%
                                                                                         100%
                East                                     50%
                                                                                         100%
                                          25%




                                                                    64%
       Fully Planning                                         55%
                                                                          73%
                                           27%
                        0%         20%          40%           60%         80%      100%


Exhibit 49. Number of Consultant Contracts for a New Comprehensive Plan Element
                                 by Characteristic
                Large
               County
                                  25%                         75%                    0
             Small/Med                                                               1 to 5
                                    40%                             60%
              County


                   West                                100%
                    East                        75%                         25%


          Fully Planning          25%                         75%

                             0%     20%          40%          60%         80%     100%




DEPT OF COMMERCE                                                                                PAGE 59
EVALUATION OF PLANNING COSTS                                                             JANUARY 3, 2022
  Exhibit 50. Number of Stakeholder                            Exhibit 51. Number of Public Meetings
 Meetings for a New Comprehensive                                 for a New Comprehensive Plan
   Plan Element by Characteristic                                    Element by Characteristic

    Large                                                             Large
                25%            50%         25%                                        50%         25%     25%
    County                                                            County
  Small/Med                                                     Small/Med
                      60%              40%                                      20%         40%         40%
   County                                                        County



      West     20%         40%       20% 20%                            West    20%           60%         20%

       East               75%              25%                          East    25%               75%



     Fully                                                             Fully
                    38%        25%    25% 13%                                 13%      38%          38%    13%
   Planning                                                          Planning
              0%               50%           100%                              0%             50%             100%
               0 1 to 5 5 to 10 10 to 50                                        0 1 to 5 5 to 10 10 to 50


 Exhibit 52. Other Types of Public Engagement Used for a New Comprehensive Plan
                              Element by Characteristic

                                                                       67% Website
              Large                               33%
              County                              33%                       Survey
                                                           50%              Language
                                                              57%           Translation
        Small/Med                            29%
         County                                                             Other
                                             29%



                                                               56%
                   West                           33%
                                           22%
                                                         44%
                                                                          75%
                   East                     25%
                                            25%



                                                                         73%
      Fully Planning                               36%
                                      18%
                                                         45%
                          0%         20%          40%          60%        80%         100%



DEPT OF COMMERCE                                                                                    PAGE 60
EVALUATION OF PLANNING COSTS                                                                 JANUARY 3, 2022
Appendix C. Complex Update to a Comprehensive Plan
Element Detail for Cities by Characteristic
   Exhibit 53. Total Costs for a Complex Comprehensive Plan Element Update by
                                    Characteristic
 $2,500,000
              $2,043,000
                                                         $2,043,000           $2,043,000 Maximum
                    $1,934,500          $1,934,500                                      30
 $2,000,000


 $1,500,000                                                                              20


 $1,000,000 $601,400                                                                     10
                                               $481,000     $432,900
                  $482,100
                                        $400,500     $402,100                 $334,300 0Average
  $500,000              $255,000
                        $90,700                $224,000
                                                            $134,600
        $0           $41,300$6,700              $37,100                               -10
                                          $21,600      $6,700 $28,000          $22,100 Minimum
              $21,600
 ($500,000)                                                                              -20
                 5     12        12        12        4        7       5          15
       n=
               LargeMediumSmall            CPS North- South-Central            2.0/3.0
                City City City                  west west


    Exhibit 54. Per 1,000 Population Cost (excluding SEPA/NEPA) for a Complex
               Comprehensive Plan Element Update by Characteristic
 $1,200,000

                             $964,330      $964,330
 $1,000,000

   $800,000

   $600,000

   $400,000
                                                    $122,650
                     $154,720                              $49,260
   $200,000                 $116,720       $110,480               $39,190             $122,650 Max
               $10,340                             $38,790$14,990$15,620
               $3,650 $20,960                                                         $21,640
                                                                                                Avg
         $0
        n=        5     12        12            12        4       7       5              15
               Large Medium Small            CPS     North- South- Central            2.0/3.0
                City  City   City                     west west




DEPT OF COMMERCE                                                                         PAGE 61
EVALUATION OF PLANNING COSTS                                                      JANUARY 3, 2022
    Exhibit 55. Labor and Contract Costs as a Share of Total Costs for a Complex
                Comprehensive Plan Element Update by Characteristic
   70%                           65%                                                       2,000
                                                                   Labor Share Contract Share
         58%                                            60%                59%                          1,800
   60%                                                          55%                         56%
                                                                                                        1,600
                     49%                        50%
   50%                 47%                        46%                                                   1,400
               41%                                                 42%                          42%
                                                          38%            38%                            1,200
   40%
                             32%                                                                        1,000
   30%
                                                                                                        800

   20%                                                                                                  600
                                                                                                        400
   10%
                                                                                                        200
    0%                                                                                                  0
     n= 5      12    12                          12       4      7      5                       15
       Large Medium Small                        CPS    North- South- Central               2.0/3.0
        City  City   City                                west west



Exhibit 56. Level of Confidence in Cost                       Exhibit 57. Length of Time to Complete
        Estimates for a Complex                                  a Complex Comprehensive Plan
Comprehensive Plan Element Update                               Element Update by Characteristic
            by Characteristic
                                                                 Large City          40%                60%
  Large City 0%            80%            20%                  Medium City                58%               42%
Medium City      25%             67%        8%                   Small City     20%               70%               10%
  Small City    17%        50%         33%
                                                                         CPS          55%                45%
         CPS    17%           75%           8%                   Northwest                67%               33%

  Northwest      25%         50%          25%                    Southwest          29%         43%           29%

  Southwest         29%          57%       14%                     Central                  80%               20%

    Central          40%            60%
                                                                      2.0/3.0 7%            71%               21%

     2.0/3.0 13%           53%         33%                                     0%               50%               100%
                                                                           <1 Year 1-2 Years >2 Years
               0%            50%            100%
                Low        Medium         High




DEPT OF COMMERCE                                                                                   PAGE 62
EVALUATION OF PLANNING COSTS                                                                JANUARY 3, 2022
 Exhibit 58. Types of Technical Tasks Required for a Complex Comprehensive Plan
                         Element Update by Characteristic

                                                                                              100%
        Large City                                                               80%
                                                                                              100%
                                                                             75%
      Medium City                                                    63%
                                                                             75%
                                       19%
                                                 33%
         Small City                              33%
                                                   37%
                                7%


                                                               55%                     Data Analysis
              CPS                                        45%
                                                               55%                     Modeling
                            5%
                                                           50%                         Outreach
         Northwest                                         50%                         Other
                                                           50%
                                                                       67%
        Southwest                                                      67%
                                                                              78%
                                           22%
                                                               56%
           Central                                      44%
                                                               56%



                                                                57%
            2.0/3.0                                           52%
                                                                  61%
                                     13%
                      0%             20%         40%           60%         80%          100%


  Exhibit 59. Number of Consultant Contracts for a Complex Comprehensive Plan
                         Element Update by Characteristic
          Large City          20%                           80%                           0
         Medium City        8%                            92%                             1 to 5
           Small City            33%                          67%

                CPS             17%                           83%
           Northwest              25%                           75%
           Southwest               29%                           71%
             Central             20%                           80%

               2.0/3.0      13%                            87%
                           0%         20%         40%          60%         80%         100%




DEPT OF COMMERCE                                                                                     PAGE 63
EVALUATION OF PLANNING COSTS                                                                  JANUARY 3, 2022
 Exhibit 60. Number of Stakeholder                              Exhibit 61. Number of Public Meetings
      Meetings for a Complex                                     for a Complex Comprehensive Plan
Comprehensive Plan Element Update                                 Element Update by Characteristic
          by Characteristic

  Large City    20%       40%          40%                        Large City        20% 20%         40%    20%
Medium City     17% 25% 17%            42%                      Medium City        17% 25% 8%           50%
  Small City        42%              50%           8%             Small City       17%        50%       17% 17%


        CPS         42%         33% 8%17%                                   CPS        33%    17% 17%     33%
  Northwest      25%           50%         25%                    Northwest         25%             75%
  Southwest 14%           43%    14% 29%                          Southwest             43%         43%       14%
    Central     20%       40%          40%                             Central                  100%


     2.0/3.0    20%       33% 7%       40%                             2.0/3.0 7%         47%       13% 33%

               0%              50%           100%                                 0%            50%           100%
               0 1 to 5 5 to 10 10 to 50                                           0 1 to 5 5 to 10 10 to 50



 Exhibit 62. Other Types of Public Engagement Used for a Complex Comprehensive
                       Plan Element Update by Characteristic
                                                                                                100%
          Large City                                                              80%
                                                                      60%
                                                                            69%
        Medium City                                                         69%
                                                          44%
                                                    31%
                                                 26%
           Small City                              30%
                                     11%
                                     11%


                                                            50%
                    CPS                                   45%
                                                  30%
                                       15%
                                                            50%
          Northwest                                         50%
                                                    33%
                                                                 56%
          Southwest                                                     67%
                                            22%
                                                    33%
                                                          44%
               Central                                    44%
                                                    33%
                                            22%
                                                                              Website
                                                                              Survey
                                                                52%           Language Translation
                2.0/3.0                                         52%
                                                   30%
                                           17%                                Other
                          0%          20%           40%         60%           80%            100%



DEPT OF COMMERCE                                                                                       PAGE 64
EVALUATION OF PLANNING COSTS                                                                    JANUARY 3, 2022
Appendix D. Complex Update to a Comprehensive Plan
Element Detail for Counties by Characteristic
   Exhibit 63. Total Costs for a Complex Comprehensive Plan Element Update by
                                    Characteristic
                 $5,579,400            $5,579,400                    $5,579,400          Maximum
  $5,500,000
                                                                                          30
  $4,500,000
                                                                                          20
  $3,500,000
                                                                                          10
  $2,500,000
                 $1,420,100                                                               0
  $1,500,000                           $1,121,400
                          $550,000                                   $803,400
                                                                                         Average
   $500,000               $158,800               $154,200
                                                 $50,800                                  -10

                   $6,000 $19,300       $92,500 $6,000                 $6,000
  ($500,000)                                                                             -20
                                                                                         Minimum
            n=       5          6          7          4                  10

                  LargeSmall/Med         West       East           Fully Planning
                  County County



    Exhibit 64. Per 1,000 Population Cost (excluding SEPA/NEPA) for a Complex
               Comprehensive Plan Element Update by Characteristic
  $12,000                 $11,320                          $11,320                  $11,320      Max

  $10,000
                                               $8,310
   $8,000
                 $5,990
                              $5,600
   $6,000
                                                           $4,490                   $4,540
                                               $3,970                                            Avg
   $4,000
                 $2,040
   $2,000

       $0
        n=       4       6                      6            4                         9
               Large Small/Med                 West         East                Fully Planning
               County County




DEPT OF COMMERCE                                                                           PAGE 65
EVALUATION OF PLANNING COSTS                                                        JANUARY 3, 2022
    Exhibit 65. Labor and Contract Costs as a Share of Total Costs for a Complex
                Comprehensive Plan Element Update by Characteristic
 100%                                                                                       2,000
                                                                   Labor Share Contract Share
          88%
   90%                                                                                                    1,800
   80%                                                         75%                                        1,600
   70%                                                                                                    1,400
                                                  58%                                      61%
   60%                                                                                                    1,200
                        49%
   50%                        46%                                                                         1,000
                                                        41%
   40%                                                                                           36%      800
   30%                                                                                                    600
                                                                     19%
   20%           12%                                                                                      400
   10%                                                                                                    200
    0%                                                                                                    0
    n=       4       6                               6             4                           9
           Large Small/Med                          West          East                       Fully
           County County                                                                   Planning


Exhibit 66. Level of Confidence in Cost                       Exhibit 67. Length of Time to Complete
        Estimates for a Complex                                  a Complex Comprehensive Plan
Comprehensive Plan Element Update                               Element Update by Characteristic
            by Characteristic
                                                                   Large
                                                                                 20% 20%               60%
     Large                                                        County
                        50%           50%                       Small/Med
    County                                                                       20%              80%
                                                                 County
  Small/Med
                        50%           50%
   County

                                                                         West 14%                86%
         West     17%         67%           17%                          East        33%      33%          33%

         East           50%         25%   25%

                                                              Fully Planning 10% 20%                70%

Fully Planning    22%         56%         22%                                   0%            50%                 100%

                 0%           50%            100%                           <1 Year 1-2 Years >2 Years

                  Low     Medium          High




DEPT OF COMMERCE                                                                                  PAGE 66
EVALUATION OF PLANNING COSTS                                                               JANUARY 3, 2022
 Exhibit 68. Types of Technical Tasks Required for a Complex Comprehensive Plan
                         Element Update by Characteristic

                                                                         83%
            Large                                             67%
            County                                            67%

                                                                   71%
        Small/Med                                       57%
         County                                                    71%




                                                                     78%
              West                                                   78%
                                                              67%
                                  11%
                                                                    75% Data Analysis
                                          25%
                                                                    75% Modeling
               East
                                          25%                             Outreach
                                                                          Other


                                                                               91%
      Fully Planning                                               73%
                                                                         82%
                                        18%
                       0%          20%          40%    60%         80%         100%


  Exhibit 69. Number of Consultant Contracts for a Complex Comprehensive Plan
                         Element Update by Characteristic
               Large
                                        40%                  60%                 0
              County
            Small/Med                                                            1 to 5
                                 17%                  83%
             County


                  West           14%                  86%
                   East                  50%                  50%


         Fully Planning           20%                  80%

                            0%          20%     40%    60%         80%     100%




DEPT OF COMMERCE                                                                            PAGE 67
EVALUATION OF PLANNING COSTS                                                         JANUARY 3, 2022
 Exhibit 70. Number of Stakeholder                           Exhibit 71. Number of Public Meetings
      Meetings for a Complex                                  for a Complex Comprehensive Plan
Comprehensive Plan Element Update                              Element Update by Characteristic
          by Characteristic
                                                                    Large
                                                                               20% 20%            60%
      Large                                                         County
                       40%              40%     20%
      County                                                  Small/Med
                                                                                   33%      33%      33%
  Small/Med                                                    County
                      33%         17%    33%    17%
   County


                                                                      West         29% 14%        57%
        West          29% 14%            43%     14%
                                                                       East    25%       25%   25%      25%
         East           50%             25%    25%


                                                                     Fully
                                                                               20% 10% 20%         50%
                                                                   Planning
Fully Planning        30% 10%           40%     20%
                                                                              0%            50%           100%
                 0%                50%               100%                      0 1 to 5 5 to 10 10 to 50
                  0 1 to 5 5 to 10 10 to 50


 Exhibit 72. Other Types of Public Engagement Used for a Complex Comprehensive
                       Plan Element Update by Characteristic

                 Large                                                         83%
                                                            50%
                 County                               33%
                                                      33%
          Small/Med                                                    71%
                                                                       71%
           County                        14%
                                         14%



                                                                          78%       Website
                   West                                       56%
                                                      33%                           Survey
                                               22%
                                                                         75%        Language
                      East                                               75%        Translation
                                                25%                                 Other


                                                                                     91%
        Fully Planning                                                  73%
                                                 27%
                                                 27%
                             0%          20%          40%    60%        80%          100%




DEPT OF COMMERCE                                                                                  PAGE 68
EVALUATION OF PLANNING COSTS                                                               JANUARY 3, 2022
Appendix E. Minor Update to a Comprehensive Plan Detail for
Cities by Characteristic
    Exhibit 73. Total Costs for a Minor Comprehensive Plan Element Update by
                                    Characteristic
  $450,000
                              $367,800   $367,800
                                                                                             30
  $350,000

              $249,400                                      $249,400                      20
                                                                                 $249,400 Maximum
  $250,000
                    $165,000                                                                 10

  $150,000 $104,300
                                               $67,000                                       0
                                         $68,000      $69,600
                    $40,300$47,600             $35,200       $21,900             $46,000
   $50,000                                                                                   Average
                                                                       $10,700               -10

              $15,400 $2,500 $1,500       $1,500 $4,200 $1,500 $2,600             $4,200
  ($50,000)                                                                                  Minimum
                                                                                             -20

      n=        5        14     18         17       4          8         7         17
               LargeMediumSmall            CPS North- South-Central              2.0/3.0
                City City City                  west west


      Exhibit 74. Per 1,000 Population Cost (excluding SEPA/NEPA) for a Minor
               Comprehensive Plan Element Update by Characteristic
 $700,000                     $656,610   $656,610

 $600,000

 $500,000

 $400,000

 $300,000

 $200,000
                                                              $60,900
 $100,000                  $53,090        $48,590                                   $60,900Max
              $1,260 $3,830                         $8,400$12,940 $12,340
               $720 $1,190                          $3,130        $4,800             $7,900Avg
      $0
       n=       5        14     18          17          4          8         7          17
              Large Medium Small            CPS     North- South- Central            2.0/3.0
               City  City   City                     west west




DEPT OF COMMERCE                                                                          PAGE 69
EVALUATION OF PLANNING COSTS                                                       JANUARY 3, 2022
      Exhibit 75. Labor and Contract Costs as a Share of Total Costs for a Minor
               Comprehensive Plan Element Update by Characteristic
 100%                                                                                           2,000
                                                                       Labor Share Contract Share
         89%        89%
  90%                                                                                                     1,800
  80%                                                                                                     1,600
  70%                                                                                                     1,400
                                                            60%                   59%
  60%                                                                55%                        56%       1,200
                                51%                50%
  50%                              46%                46%                                                 1,000
                                                                       42%                          42%
                                                              38%            38%
  40%                                                                                                     800
  30%                                                                                                     600
  20%                                                                                                     400
           10%
  10%                     4%                                                                              200
   0%                                                                                                     0
    n=     5          14          19                  18      4      8      7                       17
         Large Medium Small                         CPS     North- South- Central               2.0/3.0
          City  City   City                                  west   west


Exhibit 76. Level of Confidence in Cost                           Exhibit 77. Length of Time to Complete
 Estimates for a Minor Comprehensive                              a Minor Comprehensive Plan Element
Plan Element Update by Characteristic                                    Update by Characteristic

  Large City              60%            40%                         Large City         40%     20%       40%
Medium City     21%             57%          21%                   Medium City                73%             27%

  Small City        26%        37%       37%                         Small City               75%             25%



         CPS        32%          42%         26%                           CPS            63%             31%       6%

  Northwest                                                          Northwest                75%             25%
                                100%
                                                                     Southwest                75%         13%13%
  Southwest 13%            50%           38%
                                                                       Central                                29%
    Central           17%              67%


                                                                        2.0/3.0               76%             18%   6%
     2.0/3.0 6%            63%               31%
                                                                                  0%            50%               100%
               0%               50%            100%
                Low        Medium            High                             <1 Year 1-2 Years >2 Years




DEPT OF COMMERCE                                                                                     PAGE 70
EVALUATION OF PLANNING COSTS                                                                  JANUARY 3, 2022
   Exhibit 78. Types of Technical Tasks Required for a Minor Comprehensive Plan
                          Element Update by Characteristic

                                                                                         100%
         Large City                                             60%
                                                                                         100%
                                                                   63%
       Medium City                     19%
                                                                           75%
                                                   38%
                                                    41%
         Small City                   19%
                                                             56%
                            4%


                                                          50%                     Data Analysis
               CPS                   15%
                                                                    65%           Modeling
                                           25%
                                                          50%                     Outreach
         Northwest                               33%                              Other
                                                                     67%
                                                                     67%
         Southwest                                     44%
                                                                                  89%
                                 11%
                                                                     67%
           Central                      22%
                                                                     67%



                                                                61%
            2.0/3.0                           30%
                                                                          74%
                                9%
                      0%          20%            40%         60%          80%         100%


Exhibit 79. Number of Consultant Contracts for a Minor Comprehensive Plan Element
                             Update by Characteristic
          Large City                             80%                           20%      0
         Medium City                              86%                           14%     1 to 5
           Small City                37%                           63%

                CPS                          67%                          33%
           Northwest                     50%                          50%
           Southwest                       63%                          38%
             Central                   43%                          57%

               2.0/3.0                     53%                        47%
                           0%        20%         40%         60%         80%      100%




DEPT OF COMMERCE                                                                                 PAGE 71
EVALUATION OF PLANNING COSTS                                                              JANUARY 3, 2022
   Exhibit 80. Number of Stakeholder                              Exhibit 81. Number of Public Meetings
 Meetings for a Minor Comprehensive                                  for a Minor Comprehensive Plan
Plan Element Update by Characteristic                               Element Update by Characteristic

  Large City              60%         20% 20%                         Large City    20%         40%        40%
Medium City          47%              47%           7%            Medium City 7%               53%         40%
  Small City              63%            37%                          Small City    16%              68%     16%


        CPS                 84%               16%                           CPS     21%         42%        37%
  Northwest           50%         25%        25%                      Northwest                75%          25%
  Southwest 13%                  88%                                  Southwest                75%          25%
    Central          43%               57%                              Central                 86%          14%


     2.0/3.0        29%           59%         6% 6%                      2.0/3.0 6%              76%         18%

               0%               50%            100%                                0%                50%         100%
               0 1 to 5 5 to 10 10 to 50                                            0           1 to 5     5 to 10


Exhibit 82. Other Types of Public Engagement Used for a Minor Comprehensive Plan
                          Element Update by Characteristic

                                                                                   80%          100%
          Large City                                                               80%
                                                                                         88%
        Medium City                         19%             44%
                                  6%
                                         19%              41%
           Small City           4%7%


                                                      35%                    75%   Website
                    CPS                 15%                                        Survey
                                                                50%                Language
          Northwest                      17%         33%
                                         17%
                                                                  56%          78% Translation
          Southwest                                                                Other
                                      11% 22%
                                      11%                   44%
               Central
                                      11% 22%


                                                    30%               61%
                2.0/3.0
                                       13% 22%
                           0%           20%          40%          60%        80%           100%




DEPT OF COMMERCE                                                                                       PAGE 72
EVALUATION OF PLANNING COSTS                                                                    JANUARY 3, 2022
Appendix F. Minor Update to a Comprehensive Plan Detail for
Counties by Characteristic
    Exhibit 83. Total Costs for a Minor Comprehensive Plan Element Update by
                                    Characteristic
                $112,500                   $112,500                       $112,500           Maximum
   $115,000
                                                                                                30
    $95,000
                                                                                                20
    $75,000

                                                                                                10
    $55,000
                       $42,900
                         $31,500     $41,700                                                    0
    $35,000                                           $23,600                                Average
                                                                                  $32,100
                                 $18,900                      $14,600                           -10
    $15,000
                           $7,100           $7,100 $2,800
    ($5,000)     $2,800                                                    $2,800            Minimum
                                                                                             -20

        n=         5         5                 6          4                   9
                LargeSmall/Med              West       East             Fully Planning
                County County



      Exhibit 84. Per 1,000 Population Cost (excluding SEPA/NEPA) for a Minor
               Comprehensive Plan Element Update by Characteristic
   $3,000                  $2,710                               $2,710                   $2,710       Max
   $2,500

   $2,000

   $1,500                  $1,360                               $1,360
                                                   $1,270

   $1,000
                                                                                         $700
                                                                                                      Avg
    $500        $220                               $300
                $80
      $0
       n=        5       5                          6             4                         9
               Large Small/Med                     West          East                Fully Planning
               County County




DEPT OF COMMERCE                                                                                PAGE 73
EVALUATION OF PLANNING COSTS                                                             JANUARY 3, 2022
      Exhibit 85. Labor and Contract Costs as a Share of Total Costs for a Minor
               Comprehensive Plan Element Update by Characteristic
 120%                                                                                        2,000
                                                                    Labor Share Contract Share
         100%                                                                                            1,800
 100%
                                                                89%                                      1,600
                                                  83%                                      84%
                                                                                                         1,400
  80%                  71%
                                                                                                         1,200
  60%                                                                                                    1,000
                                                                                                         800
  40%
                                                                                                         600

                              16%                                                                        400
  20%                                                   13%
                                                                                                  9%
                                                                                                         200
   0%                                                                                                    0
    n=      5       5                                6             4                          9
          Large Small/Med                           West          East                       Fully
          County County                                                                    Planning


Exhibit 86. Level of Confidence in Cost                       Exhibit 87. Length of Time to Complete
 Estimates for a Minor Comprehensive                          a Minor Comprehensive Plan Element
Plan Element Update by Characteristic                                Update by Characteristic

     Large                                                         Large
                       50%            50%                                             60%               40%
     County                                                       County
  Small/Med                                                     Small/Med
                     40%             60%                                                75%               25%
   County                                                        County




         West                80%            20%                          West        50%               50%


         East                                                            East                100%
                       50%          25%    25%



                                                              Fully Planning           67%               33%
Fully Planning 13%           63%           25%
                                                                                0%           50%               100%
                0%             50%           100%
                                                                                     <1 Year           1-2 Years
                 Low       Medium          High




DEPT OF COMMERCE                                                                                  PAGE 74
EVALUATION OF PLANNING COSTS                                                               JANUARY 3, 2022
   Exhibit 88. Types of Technical Tasks Required for a Minor Comprehensive Plan
                          Element Update by Characteristic

                                                  33%
            Large
            County                                        50%

                                                        43%
        Small/Med                 14%
         County                                                 57%




                                                                                  Data Analysis
                                                  33%
                                 11%                                              Modeling
               West
                                                        44%                       Outreach
                                 11%                                              Other
                                                          50%
               East
                                                                            75%
                                            25%




                                                         45%
      Fully Planning             9%
                                                                     64%
                                      18%
                       0%         20%             40%          60%         80%           100%


Exhibit 89. Number of Consultant Contracts for a Minor Comprehensive Plan Element
                             Update by Characteristic
              Large
             County
                                                        100%                              0
           Small/Med                                                                      1 to 5
                                                  80%                            20%
            County


                 West                              83%                            17%
                  East                                  100%


         Fully Planning                             89%                            11%

                            0%        20%         40%          60%         80%         100%




DEPT OF COMMERCE                                                                                     PAGE 75
EVALUATION OF PLANNING COSTS                                                                  JANUARY 3, 2022
   Exhibit 90. Number of Stakeholder                                 Exhibit 91. Number of Public Meetings
 Meetings for a Minor Comprehensive                                     for a Minor Comprehensive Plan
Plan Element Update by Characteristic                                  Element Update by Characteristic

      Large                                                                 Large
                             60%                40%                                       20%           60%     20%
      County                                                                County
  Small/Med                                                            Small/Med
                             60%           20% 20%                                             40%      20%   40%
   County                                                               County




        West                  67%               33%                           West            33%       33%   33%

         East            50%           25%       25%                              East        25%       50%    25%




Fully Planning               56%           33%        11%            Fully Planning       22%         44%     33%

                 0%                 50%                100%                              0%             50%         100%
                  0           1 to 5            5 to 10                                   0          1 to 5    5 to 10


Exhibit 92. Other Types of Public Engagement Used for a Minor Comprehensive Plan
                          Element Update by Characteristic

             Large                                                           67%
                                                       33%
             County                       17%
                                                       33%
          Small/Med                                           43%
                                                              43%
           County                         14%
                                          14%



                                                                      56%            Website
                  West                                 33%
                                                22%                                  Survey
                                                22%
                                                                50%                  Language
                      East                                      50%                  Translation
                                                 25%                                 Other


                                                                            64%
       Fully Planning                                          45%
                                           18%
                                                  27%
                             0%        20%             40%           60%           80%          100%




DEPT OF COMMERCE                                                                                             PAGE 76
EVALUATION OF PLANNING COSTS                                                                          JANUARY 3, 2022
Appendix G. Update to a Critical Areas Ordinance Detail for
Cities by Characteristic
   Exhibit 93. Total Costs for a Critical Areas Ordinance Update by Characteristic
                  $504,700
  $550,000 $500,000                      $504,700            $500,000              $500,000 Maximum

                                                                                               30
  $450,000

  $350,000                                                                                     20

                                                 $200,000                                      10
  $250,000                    $200,000
              $170,900                               $139,300
  $150,000          $106,400                   $95,600                                     0
                                         $99,300                                   $80,700 Average
                                                            $54,300
                              $35,300
   $50,000                                                  $18,900                            -10
               $18,000$1,200 $1,000       $1,200$17,900$8,800 $1,000                $1,000 Minimum
  ($50,000)                                                                                -20

      n=        5        15     15         16        4          6        7           17
               LargeMediumSmall            CPS North- South-Central                2.0/3.0
                City City City                  west west


  Exhibit 94. Per 1,000 Population Cost (excluding SEPA/NEPA) for a Critical Areas
                         Ordinance Update by Characteristic
 $100,000                     $91,600               $91,600                           $91,600 Max
  $90,000
  $80,000
  $70,000
  $60,000
                                                               $49,260
  $50,000
  $40,000
  $30,000                                        $24,290
                                          $16,880                        $17,480
  $20,000                     $14,190                                                 $11,640
                                                                $9,960
              $2,530 $8,170                                              $6,710
  $10,000      $790 $2,740                 $3,440                                                    Avg
       $0
       n=       5        15     16          16           4          7        7            17
              Large Medium Small            CPS     North- South- Central              2.0/3.0
               City  City   City                     west west




DEPT OF COMMERCE                                                                            PAGE 77
EVALUATION OF PLANNING COSTS                                                         JANUARY 3, 2022
  Exhibit 95. Labor and Contract Costs as a Share of Total Costs for a Critical Areas
                        Ordinance Update by Characteristic
 70%                                                                                             2,000
                                                                        Labor Share Contract Share
         62%
                                                             60%                     59%                         1,800
 60%                                                                 55%                               56%
                      51%     53%                                                                                1,600
                                                    50%
 50%                                                   46%                                                       1,400
                                                                        42%                               42%
                                  40%                          38%                                               1,200
 40%                                                                          38%
            34%
                        30%                                                                                      1,000
 30%
                                                                                                                 800

 20%                                                                                                             600
                                                                                                                 400
 10%
                                                                                                                 200
  0%                                                                                                             0
    n=      5          15         16                  16       4      7      7                           17
          Large Medium Small                         CPS     North- South- Central                     2.0/3.0
           City  City   City                                  west   west


Exhibit 96. Level of Confidence in Cost                            Exhibit 97. Length of Time to Complete
     Estimates for a Critical Areas                                a Critical Areas Ordinance Update by
 Ordinance Update by Characteristic                                             Characteristic

  Large City      20% 20%               60%                           Large City      20%         40%            40%
Medium City       20%             73%                7%             Medium City       20%                73%               7%

  Small City          33%         40%         27%                     Small City                  79%                21%



         CPS      19%          63%             19%                           CPS          25%            63%           13%

  Northwest                                                           Northwest            33%         33%
                        50%             50%
                                                                      Southwest                 57%              43%
  Southwest 13%             50%           38%
                                                                        Central
    Central                 40%          40%


                                                                           2.0/3.0               63%             31%         6%
       2.0/3.0        29%      41%            29%
                                                                                     0%                50%               100%
                 0%            50%              100%
                  Low       Medium            High                               <1 Year 1-2 Years >2 Years




DEPT OF COMMERCE                                                                                         PAGE 78
EVALUATION OF PLANNING COSTS                                                                      JANUARY 3, 2022
Exhibit 98. Types of Technical Tasks Required for a Critical Areas Ordinance Update
                                  by Characteristic

                                                                              80%
         Large City                     20%
                                                                              80%
                                                                63%
       Medium City                                 38%
                                                                              81%
                                                   38%
                                                      44%
          Small City                  15%
                                                        48%
                                 7%


                                                          55%                       Data Analysis
               CPS                                35%
                                                                      70%           Modeling
                                        20%
                                                  33%                               Outreach
         Northwest                                33%                               Other
                                                        50%
                                       17%
                                                                    67%
         Southwest                11%
                                                                    67%
                                            22%
                                                          56%
            Central               11%
                                                                    67%



                                                              57%
             2.0/3.0                   17%
                                                              57%
                                       17%
                       0%             20%         40%     60%           80%          100%


Exhibit 99. Number of Consultant Contracts for a Critical Areas Ordinance Update by
                                  Characteristic
           Large City                40%                         60%                   0
          Medium City             27%                         73%                      1 to 5
            Small City                44%                         56%

                 CPS                38%                         63%
            Northwest             25%                         75%
            Southwest                 43%                         57%
              Central                 43%                         57%

                2.0/3.0           29%                         71%
                            0%         20%        40%     60%           80%         100%




DEPT OF COMMERCE                                                                                  PAGE 79
EVALUATION OF PLANNING COSTS                                                               JANUARY 3, 2022
 Exhibit 100. Number of Stakeholder                              Exhibit 101. Number of Public Meetings
     Meetings for a Critical Areas                               for a Critical Areas Ordinance Update
 Ordinance Update by Characteristic                                          by Characteristic

   Large City         40%        20%         40%                      Large City           60%          20% 20%
Medium City          33%               67%                        Medium City 13% 27%                   53%          7%
   Small City              56%             44%                        Small City    19%          50%         25%     6%


         CPS               56%             44%                              CPS 13% 25%                50%         13%
   Northwest         25%             75%                              Northwest      25%          50%         25%
   Southwest 14%                 71%             14%                  Southwest            57%               43%
     Central               57%             43%                          Central                    57%         14%


      2.0/3.0         35%            53%         12%                     2.0/3.0 12%        53%              29%     6%

                0%               50%               100%                            0%             50%              100%
                 0          1 to 5           5 to 10                                0 1 to 5 5 to 10 10 to 50


 Exhibit 102. Other Types of Public Engagement Used for a Critical Areas Ordinance
                               Update by Characteristic

                                                                      60%          80%
          Large City                                      40%
                                               31%                                 81%
        Medium City                    13%  25%
                                         19%     37%
           Small City            4%
                                  7%


                                                   30%                        75%
                     CPS             10%
                                     10%
                                                    33%
          Northwest                     17%
                                                    33%
                                                    33% 44%                   Website
          Southwest                  11%
                                     11%                                      Survey
                                                           44%
                Central                  22%                                  Language
                                     11% 22%                                  Translation
                                                                              Other
                                             26%                48%
                2.0/3.0                13%
                                         17%
                           0%          20%          40%           60%        80%           100%




DEPT OF COMMERCE                                                                                        PAGE 80
EVALUATION OF PLANNING COSTS                                                                     JANUARY 3, 2022
Appendix H. Update to a Critical Areas Ordinance Detail for
Counties by Characteristic
  Exhibit 103. Total Costs for a Critical Areas Ordinance Update by Characteristic
  $1,550,000

                                                                                        30
               $1,159,000            $1,159,000                   $1,159,000
                                                                                       Maximum
  $1,150,000
                                                                                        20
                        $766,300
   $750,000                                                                             10


                                                                                        0
                $286,200             $323,800
   $350,000                                                        $262,600
                        $178,200                $115,700                               Average
                                                                                       -10
                                                $48,900

   ($50,000)     $6,000 $23,800       $30,000 $6,000                $6,000              -20
                   6          6          8           4                10               Minimum
        n=
                LargeSmall/Med         West       East           Fully Planning
                County County


  Exhibit 104. Per 1,000 Population Cost (excluding SEPA/NEPA) for a Critical Areas
                         Ordinance Update by Characteristic
  $35,000               $32,400              $32,400                              $32,400      Max

  $30,000

  $25,000

  $20,000

  $15,000
                            $8,650                       $8,490
  $10,000
                                                         $4,160                   $5,100
                                              $4,710
   $5,000       $980                                                                           Avg
                $410
       $0
        n=       6       6                     8           4                         10
               Large Small/Med                West        East                Fully Planning
               County County




DEPT OF COMMERCE                                                                         PAGE 81
EVALUATION OF PLANNING COSTS                                                      JANUARY 3, 2022
 Exhibit 105. Labor and Contract Costs as a Share of Total Costs for a Critical Areas
                        Ordinance Update by Characteristic
 90%     83%                                                                               2,000
                                                                  Labor Share Contract Share
 80%                                                                                             1,800
                                              72%
                                                                                     68%         1,600
 70%
                                                                                                 1,400
 60%                          53%                                 51%                            1,200
 50%
                        39%                                 40%                                  1,000
 40%
                                                                                                 800
 30%                                                 27%                                   27%
                                                                                                 600
 20%           17%
                                                                                                 400
 10%                                                                                             200
  0%                                                                                             0
    n=     6               6                        8          4                          10
         Large         Small/Med                   West       East                     Fully
         County         County                                                       Planning


  Exhibit 106. Level of Confidence in                         Exhibit 107. Length of Time to
  Cost Estimates for a Critical Areas                      Complete a Critical Areas Ordinance
 Ordinance Update by Characteristic                             Update by Characteristic

     Large                                                      Large
                              80%           20%                              17%      50%         33%
    County                                                     County
  Small/Med                                                  Small/Med
                  17%                83%                                      20%         60%         20%
   County                                                     County



         West                  86%          14%                      West           63%          38%

         East         25%            75%                             East           67%           33%




Fully Planning                 89%           11%           Fully Planning     20%      50%           30%

                 0%             50%          100%                           0%            50%            100%

                 Low          Medium       High                             <1 Year 1-2 Years >2 Years




DEPT OF COMMERCE                                                                            PAGE 82
EVALUATION OF PLANNING COSTS                                                         JANUARY 3, 2022
Exhibit 108. Types of Technical Tasks Required for a Critical Areas Ordinance Update
                                  by Characteristic

                                                                                     83%
             Large                                   33%
             County                                                                  83%

                                                                          71%
         Small/Med                                         43%
          County                                                          71%
                                        14%




                                                                                78% Data Analysis
               West                                         44%                        Modeling
                                                                                78%
                                              22%                                      Outreach
                                                                               75%     Other
                East                           25%
                                                                               75%
                                               25%




                                                                                 82%
       Fully Planning                                 36%
                                                                                 82%
                                                27%
                        0%          20%              40%          60%      80%             100%


 Exhibit 109. Number of Consultant Contracts for a Critical Areas Ordinance Update
                                 by Characteristic
               Large
              County
                                                    67%                        33%          0
            Small/Med                                                                       1 to 5
                                  17%                             83%
             County


                  West                        50%                        50%
                   East            25%                             75%


         Fully Planning                       50%                        50%

                             0%          20%          40%         60%     80%          100%




DEPT OF COMMERCE                                                                                     PAGE 83
EVALUATION OF PLANNING COSTS                                                                  JANUARY 3, 2022
 Exhibit 110. Number of Stakeholder                          Exhibit 111. Number of Public Meetings
     Meetings for a Critical Areas                           for a Critical Areas Ordinance Update
 Ordinance Update by Characteristic                                      by Characteristic

      Large                                                         Large
                      33%                67%                                      33%     17%         33%
      County                                                        County
  Small/Med                                                   Small/Med
                  17%        33%         33%    17%                           17% 17%           50%    17%
   County                                                      County



        West          25%           63%         13%                   West 13%13%          50%        25%

         East         25%     25%         50%                         East          50%         25%0%25%




Fully Planning    20%             50%      20% 10%                  Fully
                                                                              20% 20%           40%    20%
                                                                  Planning
                 0%                50%           100%                        0%            50%          100%
                   0 1 to 5 5 to 10 10 to 50                                  0 1 to 5 5 to 10 10 to 50


 Exhibit 112. Other Types of Public Engagement Used for a Critical Areas Ordinance
                               Update by Characteristic

                 Large                                                         83%
                                                            50%
                 County                                     50%
                                                            50%
          Small/Med                                                    71%
                                                               57%
           County
                                         14%



                                                                             78% Website
                   West                                       56%                  Survey
                                                     33%
                                                     33%                           Language
                                                                         75%
                      East                                  50%                    Translation
                                               25%                                 Other


                                                                              82%
        Fully Planning                                       55%
                                                27%
                                                      36%
                             0%          20%         40%     60%        80%             100%




DEPT OF COMMERCE                                                                                  PAGE 84
EVALUATION OF PLANNING COSTS                                                               JANUARY 3, 2022
Appendix I. Shoreline Master Program Update Detail for
Cities by Characteristic
  Exhibit 113. Total Costs for a Shoreline Master Program Update by Characteristic

             $906,300                                        $906,300               $906,300 Maximum
  $950,000
                                                                                               30
  $750,000
                                                                                               20

  $550,000
                                                                                               10
           $343,100                      $357,400
  $350,000        $335,000
                                                                                               0
                              $135,000          $91,000
                                         $146,200     $160,000
                       $127,800                                                     $108,500 Average
  $150,000                                        $56,100               $55,900              -10
                               $39,300                                  $28,100

  ($50,000) $47,000 $2,000 $8,800         $2,000$19,400
                                                       $8,800$10,500                $10,500 -20
                                                                                             Minimum
      n=           4      13               13                                         15
                                 14                  4          7         5
              LargeMediumSmall             CPS North- South-Central                 2.0/3.0
               City City City                   west west


Exhibit 114. Per 1,000 Population Cost (excluding SEPA/NEPA) for a Shoreline Master
                          Program Update by Characteristic
  $70,000
                               $63,060                                    $63,060

  $60,000

  $50,000
                                          $39,330
                                                    $37,150                             $37,150 Max
  $40,000
                                                               $29,560
  $30,000
                       $19,260$17,730
  $20,000                                                                 $16,220

             $4,590 $5,870                 $9,430 $10,640 $9,160                           $8,360
  $10,000                                                                                           Avg
             $1,970
      $0
       n=      4         13      14          13          4          7         5               15
             Large Medium Small             CPS     North- South- Central               2.0/3.0
              City  City   City                      west west




DEPT OF COMMERCE                                                                             PAGE 85
EVALUATION OF PLANNING COSTS                                                          JANUARY 3, 2022
Exhibit 115. Labor and Contract Costs as a Share of Total Costs for a Shoreline Master
                         Program Update by Characteristic
 80%                                                                                             2,000
                                                                        Labor Share Contract Share
 70%                              67%                                                                               1,800
                    61%                                      60%                                                    1,600
           58%                                                                       59%
 60%                                                                 55%                               56%
                                                    50%                                                             1,400
 50%                                                   46%
         42%                                                            42%                               42%       1,200
                                                               38%            38%
 40%                                                                                                                1,000
                            31%
 30%                                                                                                                800
                      23%
                                                                                                                    600
 20%
                                                                                                                    400
 10%                                                                                                                200
  0%                                                                                                                0
    n=     4     13              14                   13       4      7      5                           15
         Large Medium Small                          CPS     North- South- Central                     2.0/3.0
          City  City   City                                   west   west


  Exhibit 116. Level of Confidence in                                 Exhibit 117. Length of Time to
 Cost Estimates for a Shoreline Master                             Complete a Shoreline Master Program
  Program Update by Characteristic                                      Update by Characteristic

  Large City              60%               40%                       Large City      20%              60%              20%
Medium City 15%                 62%           23%                   Medium City 8%               46%              46%

  Small City 8%       38%               54%                           Small City           42%                50%           8%



         CPS 7%                 79%           14%                            CPS            50%                  50%

  Northwest                                                           Northwest            33%         33%           33%
                      50%             25%
                                                                      Southwest             43%                  57%
  Southwest         29%               71%
                                                                        Central                                  50%
    Central      25%                  75%


                                                                           2.0/3.0         36%                57%                7%
       2.0/3.0 13% 31%                 56%
                                                                                     0%                50%                  100%
               0%               50%               100%
                Low        Medium             High                               <1 Year 1-2 Years >2 Years




DEPT OF COMMERCE                                                                                         PAGE 86
EVALUATION OF PLANNING COSTS                                                                      JANUARY 3, 2022
Exhibit 118. Types of Technical Tasks Required for a Shoreline Master Program Update
                                   by Characteristic

                                                                                     80%
          Large City                     20%
                                                                                                  100%
                                                                                75%
       Medium City                                 31%
                                                                                   81%
                                        19%
                                                     37%
          Small City                 19%
                                                     37%
                                  11%


                                                                         65%               Data Analysis
                CPS                      20%
                                                                         65%               Modeling
                                  10%
                                                    33%                                    Outreach
          Northwest                     17%
                                                             50%                           Other
                                                    33%
                                                                         67%
          Southwest                                        44%
                                                                         67%
                                             22%
                                                    33%
            Central               11%
                                                           44%



                                                            48%
             2.0/3.0                               30%
                                                                   57%
                                        17%
                       0%              20%          40%           60%          80%          100%


Exhibit 119. Number of Consultant Contracts for a Shoreline Master Program Update
                                by Characteristic
           Large City                                      100%                               0
          Medium City                   38%                          62%                      1 to 5
            Small City                 36%                          64%

                 CPS             15%                          85%
            Northwest                               75%                          25%
            Southwest                    43%                             57%
              Central                   40%                             60%

                2.0/3.0                33%                          67%
                            0%          20%          40%          60%          80%         100%




DEPT OF COMMERCE                                                                                         PAGE 87
EVALUATION OF PLANNING COSTS                                                                      JANUARY 3, 2022
 Exhibit 120. Number of Stakeholder                              Exhibit 121. Number of Public Meetings
   Meetings for a Shoreline Master                               for a Shoreline Master Program Update
 Program Update by Characteristic                                           by Characteristic

  Large City 0%             75%               25%                     Large City          50%               50%
Medium City      15%            69%            15%               Medium City 8%               46%         23%   23%
   Small City         43%               57%                           Small City 14%           43%         29% 14%


        CPS          31%             54%       15%                          CPS 8% 23%               46%        23%
  Northwest          25%             75%                              Northwest         25%            75%
  Southwest 14%                 71%            14%                    Southwest                71%           14%14%
     Central          40%              60%                              Central     20%             60%           20%


      2.0/3.0       20%           73%                7%                  2.0/3.0 7%            60%          20% 13%

                0%              50%               100%                             0%               50%            100%
                0           1 to 5           5 to 10                               0     1 to 5 5 to 10 10 to 50


Exhibit 122. Other Types of Public Engagement Used for a Shoreline Master Program
                              Update by Characteristic
                                                                                                100%
          Large City                        20%                       60%

                                                                50%                81%
       Medium City                    13%
                                      13%
                                            22%           41%
           Small City
                                4%


                                                         40%                70%     Website
                     CPS        5%10%                                               Survey
                                                                50%
          Northwest                  17%                                            Language
                                     17%                                            Translation
                                                           44%           67%
          Southwest                  11%                                            Other
                                                           44%
                Central              11% 22%


                                                  30%             57%
                2.0/3.0
                                4%9%
                           0%         20%           40%          60%         80%          100%




DEPT OF COMMERCE                                                                                       PAGE 88
EVALUATION OF PLANNING COSTS                                                                    JANUARY 3, 2022
Appendix J. Shoreline Master Program Update Detail for
Counties by Characteristic
  Exhibit 123. Total Costs for a Shoreline Master Program Update by Characteristic
   $600,000
                  $505,400              $505,400                      $505,400            Maximum
                                                                                           30
   $500,000


   $400,000                                                                                20


   $300,000                                                                                10
                             $211,300              $211,300
                  $179,000              $144,700                                           0
   $200,000                                                                               Average
                                                $142,700              $141,900
                          $114,100
   $100,000                                                                                -10
                   $82,800                         $81,300
                             $45,000     $45,000                       $45,000            Minimum
            $0                                                                             -20
        n=           6          7          9            4                11
                   Large…
                        Small/Med…       West       East            Fully Planning



Exhibit 124. Per 1,000 Population Cost (excluding SEPA/NEPA) for a Shoreline Master
                          Program Update by Characteristic
  $25,000

                             $20,270                        $20,270                  $20,270      Max
  $20,000


  $15,000

                                                            $9,500
  $10,000
                             $6,610
                                               $4,180                                $3,980
   $5,000
                 $1,210                                                                           Avg
                  $600                         $1,320
      $0
       n=          6       7                    9             4                         11
                 Large Small/Med               West          East                Fully Planning
                 County County




DEPT OF COMMERCE                                                                            PAGE 89
EVALUATION OF PLANNING COSTS                                                         JANUARY 3, 2022
Exhibit 125. Labor and Contract Costs as a Share of Total Costs for a Shoreline Master
                         Program Update by Characteristic
  100%                                                                 Labor Share Contract Share
                                                                                               2,000
                                                                         88%
   90%                                                                                                      1,800
   80%                                                                                                      1,600
           71%                   69%
   70%                                                66%                                                   1,400
   60%                                                                                                      1,200
                                                                                              49% 50%
   50%                                                                                                      1,000
   40%                                                      34%                                             800
                 29%       30%
   30%                                                                                                      600
   20%                                                             12%                                      400
   10%                                                                                                      200
    0%                                                                                                      0
    n=        6       7                                 9             4                         11
            Large Small/Med                            West          East                       Fully
            County County                                                                     Planning


  Exhibit 126. Level of Confidence in                                Exhibit 127. Length of Time to
 Cost Estimates for a Shoreline Master                            Complete a Shoreline Master Program
  Program Update by Characteristic                                     Update by Characteristic

    Large                                                              Large
                       60%               40%                                        17%        50%              33%
   County                                                             County
 Small/Med                                                          Small/Med
                           67%               33%                                                86%               14%
  County                                                             County



         West              75%               25%                            West              67%               33%

         East        33%               67%                                  East        25%           75%



     Fully                                                        Fully Planning 9%            64%              27%
                       56%               44%
   Planning

                0%               50%           100%                                0%               50%               100%

                     Medium            High                                    <1 Year 1-2 Years >2 Years




DEPT OF COMMERCE                                                                                      PAGE 90
EVALUATION OF PLANNING COSTS                                                                   JANUARY 3, 2022
Exhibit 128. Types of Technical Tasks Required for a Shoreline Master Program Update
                                   by Characteristic

                                                                                     83%
             Large                                   33%
             County                                                                  83%

                                                                                             100%
         Small/Med                                                 57%
          County                                                                             100%
                                        14%

                                                                                           Data
                                                                                           Analysis
                                                                                       89% Modeling
               West                                         44%                            Outreach
                                                                                       89%
                                              22%                                          Other
                                                                                             100%
                East                                          50%
                                                                                             100%
                                               25%




                                                                                       91%
       Fully Planning                                 36%
                                                                                       91%
                                               27%
                        0%          20%              40%          60%          80%         100%


Exhibit 129. Number of Consultant Contracts for a Shoreline Master Program Update
                                by Characteristic
               Large
                                              50%                          50%                    0
              County
            Small/Med                                                                             1 to 5
                                  14%                             86%
             County


                  West                    44%                             56%
                   East                                     100%


         Fully Planning                 36%                              64%

                             0%          20%          40%          60%          80%        100%




DEPT OF COMMERCE                                                                                           PAGE 91
EVALUATION OF PLANNING COSTS                                                                        JANUARY 3, 2022
 Exhibit 130. Number of Stakeholder                            Exhibit 131. Number of Public Meetings
   Meetings for a Shoreline Master                             for a Shoreline Master Program Update
 Program Update by Characteristic                                         by Characteristic

    Large                                                             Large
               17%             67%               17%                               17%         50%           17%
    County                                                            County
  Small/Med                                                      Small/Med
                   29%         43%         14%14%                          14%                 57%         29%
   County                                                         County



      West     22%                   78%                                West 11% 22%            33%        33%

       East    25%        25%             50%                            East            50%           50%



     Fully                                                             Fully
               18%             55%         9% 18%                             9% 18%            45%        27%
   Planning                                                          Planning
              0%               50%                100%                            0%            50%           100%
               0 1 to 5 5 to 10 10 to 50                                           0 1 to 5 5 to 10 10 to 50


Exhibit 132. Other Types of Public Engagement Used for a Shoreline Master Program
                              Update by Characteristic

              Large                                                                            100%
                                                              50%
              County                       17%
                                                       33%
        Small/Med                                                                      86%
                                                                            71%
         County
                                                  29%



                                                                                               100%
                   West                                         56%
                                     11%
                                                       33%                                   Website
                                                                             75%
                   East                                                      75%             Survey
                                                 25%                                         Language
                                                                                             Translation
                                                                                             Other
                                                                                               100%
      Fully Planning                                                  64%
                                     9%
                                                        36%
                          0%           20%             40%     60%          80%          100%




DEPT OF COMMERCE                                                                                      PAGE 92
EVALUATION OF PLANNING COSTS                                                                   JANUARY 3, 2022
Appendix K. Existing Development Regulation Update Detail
for Cities by Characteristic
    Exhibit 133. Total Costs for an Existing Development Regulation Update by
                                    Characteristic

   $290,000 $260,400                      $260,400
                        $220,800                                                               30
   $240,000                   $208,900                   $208,900                   $208,900 Maximum
                                                                                            20
   $190,000

                                                                                               10
   $140,000                                                            $101,100
               $98,800
    $90,000                                     $56,000                                        0
                        $40,000           $48,100     $46,900                                  Average
                                                $23,500                             $35,600
    $40,000                   $25,700                                                          -10
                                                             $23,000

   ($10,000) $17,800 $2,500 $1,100        $2,500 $4,200 $1,100 $4,100                        Minimum
                                                                                     $4,100 -20

                    4     14      18        16       5         7         6            18
        n=
                Large            Small      CPS              South-
                 City             City                        west


    Exhibit 134. Per 1,000 Population Cost (excluding SEPA/NEPA) for an Existing
                  Development Regulation Update by Characteristic
 $140,000                                                      $123,240
                               $123,240                                                 $123,240 Max
 $120,000

 $100,000

  $80,000                                  $67,740

  $60,000
                                                                          $31,630
  $40,000
                           $18,990                            $22,050
  $20,000     $2,560 $3,690                 $9,430 $4,070                 $7,060           $11,020
               $910 $1,140                         $1,900                                            Avg
       $0
       n=       4        14      18          16          5         7         6                18
              Large Medium Small             CPS     North- South- Central                 2.0/3.0
               City  City   City                      west west




DEPT OF COMMERCE                                                                               PAGE 93
EVALUATION OF PLANNING COSTS                                                            JANUARY 3, 2022
   Exhibit 135. Labor and Contract Costs as a Share of Total Costs for an Existing
                 Development Regulation Update by Characteristic
 90%                                                                                         2,000
                                                                    Labor Share Contract Share
         79%          81%
 80%                                                                                                    1,800

 70%                                                                                                    1,600
                              59%                         60%                     59%                   1,400
 60%                                                              55%                         56%
                                                 50%                                                    1,200
 50%                                                46%
                                   40%                              42%                          42%    1,000
                                                            38%            38%
 40%
                                                                                                        800
 30%
            20%                                                                                         600
 20%                                                                                                    400
                        12%
 10%                                                                                                    200
  0%                                                                                                    0
    n=      4          14          18              16       5      7      6                     18
          Large Medium Small                      CPS     North- South- Central               2.0/3.0
           City  City   City                               west   west


  Exhibit 136. Level of Confidence in                              Exhibit 137. Length of Time to
    Cost Estimates for an Existing                              Complete an Existing Development
 Development Regulation Update by                               Regulation Update by Characteristic
             Characteristic
                                                                  Large City            60%             40%
  Large City                60%           40%                   Medium City                   93%                 7%
Medium City       19%         50%         31%                     Small City             71%            14% 14%
  Small City 6%                   81%       13%
                                                                          CPS            71%            21%       7%
         CPS      18%         53%          29%                    Northwest                   100%

  Northwest       20%               80%                           Southwest               88%                 13%

  Southwest                  71%           29%                      Central               80%               20%

    Central                 67%           33%
                                                                        2.0/3.0               88%             6% 6%

       2.0/3.0                79%           16%                                   0%           50%              100%
                                                                              <1 Year 1-2 Years >2 Years
                 0%               50%           100%
                  Low        Medium        High




DEPT OF COMMERCE                                                                                 PAGE 94
EVALUATION OF PLANNING COSTS                                                              JANUARY 3, 2022
    Exhibit 138. Types of Technical Tasks Required for an Existing Development
                        Regulation Update by Characteristic

                                                                         80%
         Large City                                          60%
                       0%
                                                         56%
       Medium City                    19%
                                                                   69%
                                          31%
                                        26%
         Small City             11%
                                                 41%
                           4%


                                                   45%                            Data Analysis
               CPS              10%
                                                 40%                              Modeling
                                  15%
                                             33%                                  Outreach
         Northwest                17%                                             Other
                                                       50%
                                                   44%
         Southwest                     22%
                                                                         78%
                                       22%
                                                   44%
           Central              11%
                                                         56%
                                11%


                                                 39%
            2.0/3.0              13%
                                                                65%
                                 13%
                      0%         20%         40%         60%          80%          100%


Exhibit 139. Number of Consultant Contracts for an Existing Development Regulation
                            Update by Characteristic
                            Large City                         75%                            25%    0
                           Medium City                           86%                            14%  1 to 5
                             Small City                50%                        39%           6%6% 5 to 10
                                                                                                       10 to 50
                                  CPS                     63%                            38%           > 50
                             Northwest                          80%                          20%
                             Southwest                        71%                       14% 14%
                               Central                       67%                          33%

                                  2.0/3.0                    67%                        22%     6%6%
                                            0%     20%          40%         60%         80%       100%




DEPT OF COMMERCE                                                                                PAGE 95
EVALUATION OF PLANNING COSTS                                                             JANUARY 3, 2022
 Exhibit 140. Number of Stakeholder                             Exhibit 141. Number of Public Meetings
Meetings for an Existing Development                            for an Existing Development Regulation
Regulation Update by Characteristic                                     Update by Characteristic

  Large City          60%             20% 20%                        Large City    20%       40%         40%
Medium City          50%              43%          7%            Medium City 13%                69%        19%
  Small City          61%              33%         6%                Small City        33%         50%     17%


        CPS                81%               19%                           CPS         28%      39%      33%
  Northwest         40%          40%        20%                      Northwest     20%             80%
  Southwest         38%               63%                            Southwest 13%                 88%
    Central         33%          50%         17%                        Central    17%          67%        17%



     2.0/3.0        37%          47%        5% 11%                      2.0/3.0    16%           74%           11%

               0%              50%            100%                                0%            50%            100%
               0 1 to 5 5 to 10 10 to 50                                           0         1 to 5       5 to 10


  Exhibit 142. Other Types of Public Engagement Used for an Existing Development
                        Regulation Update by Characteristic

                                                         40%         60%
          Large City                        20%
                                                                            75%
        Medium City                13%             31%
                                      19%
                                 7%                     37%
           Small City          4%7%


                                       15%                       55%         Website
                    CPS          5%
                                 5%                                          Survey
                                                               50%
          Northwest                     17%
                                        17%                                  Language Translation
                                                    33%                      Other
                                                    33%          56%
          Southwest
                                      11%
                                      11%                 44%
               Central
                                      11% 22%


                                           22%                    57%
                2.0/3.0                13%
                                         17%
                          0%           20%          40%         60%         80%          100%




DEPT OF COMMERCE                                                                                    PAGE 96
EVALUATION OF PLANNING COSTS                                                                 JANUARY 3, 2022
Appendix L. Existing Development Regulation Update Detail
for Counties by Characteristic
    Exhibit 143. Total Costs for an Existing Development Regulation Update by
                                    Characteristic
   $135,000
               $112,500             $112,500                       $112,500                Maximum
   $115,000                                                                                30

    $95,000                                                                                20

    $75,000
                                               $49,500                                     10
                $52,700
    $55,000                         $48,400                                                Average
                          $49,500                                   $41,400
                                                                                           0
    $35,000               $25,600
                                               $19,000
                                                                                           -10
    $15,000
                          $6,900     $11,000                                               Minimum
    ($5,000)     $600                          $600                 $600                   -20
         n=       6         5          8            3                  10

                LargeSmall/Med       West       East             Fully Planning
                County County



    Exhibit 144. Per 1,000 Population Cost (excluding SEPA/NEPA) for an Existing
                  Development Regulation Update by Characteristic
   $4,000                  $3,630                       $3,630                    $3,630
                                                                                                 Max
   $3,500

   $3,000

   $2,500

   $2,000                                               $1,700
                          $1,450           $1,550
   $1,500

   $1,000                                                                         $760
               $270
     $500                                  $350                                                  Avg
                $110
       $0
        n=       6       5                  8             3                        10
               Large Small/Med             West          East               Fully Planning
               County County




DEPT OF COMMERCE                                                                          PAGE 97
EVALUATION OF PLANNING COSTS                                                       JANUARY 3, 2022
   Exhibit 145. Labor and Contract Costs as a Share of Total Costs for an Existing
                 Development Regulation Update by Characteristic
 120%                                                                                      2,000
                                                                  Labor Share Contract Share
         100%                                                                                              1,800
 100%
                                                                                                           1,600
                                                 86%          85%                         85%
                                                                                                           1,400
  80%
                       69%
                                                                                                           1,200
  60%                                                                                                      1,000
                                                                                                           800
  40%
                                                                                                           600
                                                                                                           400
  20%                        13%
                                                        8%                                       7%        200
   0%                                                                                                      0
    n=      6       5                                  8          3                             10
          Large Small/Med                             West       East                       Fully
          County County                                                                   Planning


  Exhibit 146. Level of Confidence in                           Exhibit 147. Length of Time to
    Cost Estimates for an Existing                           Complete an Existing Development
 Development Regulation Update by                            Regulation Update by Characteristic
             Characteristic
                                                                  Large
                                                                                     50%                   50%
     Large                                                       County
                       60%               40%                   Small/Med
    County                                                                          40%              40%         20%
  Small/Med                                                     County
                 20%               80%
   County


                                                                        West        38%               63%
         West              86%             14%
                                                                        East              67%                  33%
         East        33%      33%        33%


                                                             Fully Planning          50%               40%        10%
Fully Planning 11%           67%          22%
                                                                               0%               50%                  100%
                0%            50%              100%                        <1 Year 1-2 Years >2 Years
                 Low       Medium         High




DEPT OF COMMERCE                                                                                  PAGE 98
EVALUATION OF PLANNING COSTS                                                               JANUARY 3, 2022
    Exhibit 148. Types of Technical Tasks Required for an Existing Development
                        Regulation Update by Characteristic

                                                  33%
            Large                     17%
            County                                                    67%

                                                                57%
        Small/Med                 14%
         County                                                        71%
                                  14%




                                                        44%                       Data Analysis
               West                     22%                                       Modeling
                                                                      67%         Outreach
                                        22%
                                                                                  Other
                                                          50%
               East
                                                                            75%
                                            25%




                                                        45%
      Fully Planning             9%
                                                                        73%
                                            27%
                       0%         20%             40%          60%      80%             100%


Exhibit 149. Number of Consultant Contracts for an Existing Development Regulation
                            Update by Characteristic
              Large
                                                        100%                             0
             County
           Small/Med                                                                     1 to 5
                                                  80%                         20%
            County


                 West                               88%                           13%
                  East                                  100%


         Fully Planning                             90%                           10%

                            0%        20%         40%          60%      80%         100%




DEPT OF COMMERCE                                                                                  PAGE 99
EVALUATION OF PLANNING COSTS                                                               JANUARY 3, 2022
 Exhibit 150. Number of Stakeholder                               Exhibit 151. Number of Public Meetings
Meetings for an Existing Development                              for an Existing Development Regulation
Regulation Update by Characteristic                                       Update by Characteristic

    Large                                                               Large
                    50%              33%     17%                                  17%     50%        17% 17%
    County                                                              County
 Small/Med                                                         Small/Med
                               100%                                                     60%         20% 20%
  County                                                            County



      West        25%           63%           13%                         West 13%       50%         25% 13%

       East        33%               67%                                  East          67%           33%



     Fully                                                             Fully
                   30%             70%                                        10%        60%          20%10%
   Planning                                                          Planning
              0%               50%              100%                             0%           50%        100%
              0           1 to 5            5 to 10                               0 1 to 5 5 to 10 10 to
                                                                                  50

  Exhibit 152. Other Types of Public Engagement Used for an Existing Development
                        Regulation Update by Characteristic

              Large                                                      67%
                                                      33%
              County                      17%
                                                      33%
         Small/Med                                                         71%
                                                            43%
          County
                                       14%



                                                                         67%            Website
                   West                               33%                               Survey
                                      11%
                                             22%                                        Language
                                                                               75%
                   East                                       50%                       Translation
                                                25%                                     Other



                                                                            73%
      Fully Planning                                   36%
                                     9%
                                                 27%
                          0%           20%            40%         60%       80%         100%




DEPT OF COMMERCE                                                                                    PAGE 100
EVALUATION OF PLANNING COSTS                                                                  JANUARY 3, 2022
Appendix M. New Development Regulation Detail for Cities by
Characteristic
Exhibit 153. Total Costs for a New Development Regulation Update by Characteristic
   $280,000
                     $239,900             $239,900
                                                                                            30
   $230,000

   $180,000                                                                                 20


   $130,000
               $89,000         $107,800                   $107,800                $107,800 10
                                                                                           Maximum

    $80,000                                                                                 0
                     $46,900              $52,600
                                                $24,000$36,800
               $25,500     $24,200                             $24,000            $26,000 Average
    $30,000                                     $14,800                                   -10
                                                               $9,100

                                          $1,500 $5,200 $1,900 $3,000              $3,000 -20
   ($20,000) $3,000 $1,500$1,900                                                            Minimum

        n=       5        13      13        11        4         8       5           18
                Large           Small       CPS               South-
                 City            City                          west


      Exhibit 154. Per 1,000 Population Cost (excluding SEPA/NEPA) for a New
                 Development Regulation Update by Characteristic
  $60,000
                               $53,080                         $53,080                $53,080
                                                                                                   Max
  $50,000

  $40,000

  $30,000

  $20,000
                                                     $12,210$10,770
                               $9,410
  $10,000                                                                $6,420          $6,740
              $580 $5,270                  $5,270
                                           $1,210 $3,460                 $2,360                    Avg
              $180 $1,170
       $0
       n=       5        13      13          11           4         8       5              18
              Large Medium Small             CPS     North- South- Central               2.0/3.0
               City  City   City                      west west




DEPT OF COMMERCE                                                                            PAGE 101
EVALUATION OF PLANNING COSTS                                                          JANUARY 3, 2022
      Exhibit 155. Labor and Contract Costs as a Share of Total Costs for a New
                  Development Regulation Update by Characteristic
 120%                                                                                       2,000
                                                                   Labor Share Contract Share
         99%                                                                                        1,800
 100%
                                                                                                    1,600

                            75%                                                                     1,400
  80%               73%
                                                                                                    1,200
                                                         60%                  59%
  60%                                                            55%                      56%       1,000
                                               50%
                                                  46%
                                                                   42%                       42%    800
                                                           38%           38%
  40%
                                                                                                    600
                                 24%
                      19%                                                                           400
  20%
                                                                                                    200
   0%                                                                                               0
    n=     5     13    14                           12     4      8      5                  18
         Large Medium Small                     CPS      North- South- Central            2.0/3.0
          City  City   City                               west   west


  Exhibit 156. Level of Confidence in                             Exhibit 157. Length of Time to
Cost Estimates for a New Development                             Complete a New Development
 Regulation Update by Characteristic                           Regulation Update by Characteristic

  Large City          60%              40%                       Large City         60%             40%
Medium City         36%         36%     29%                    Medium City            85%               8%     8%

  Small City    23%             62%      15%                     Small City               91%             9%



         CPS    25%         42%        33%                             CPS          64%             27% 9%
                                                                 Northwest                100%
  Northwest               75%           25%
                                                                 Southwest                100%
  Southwest 13%            63%          25%
                                                                   Central                              25%
    Central     17%       50%          33%


                                                                    2.0/3.0               94%                  6%
     2.0/3.0    22%             61%      17%
                                                                              0%          50%               100%
               0%           50%              100%
                Low       Medium        High                              <1 Year 1-2 Years >2 Years




DEPT OF COMMERCE                                                                            PAGE 102
EVALUATION OF PLANNING COSTS                                                          JANUARY 3, 2022
 Exhibit 158. Types of Technical Tasks Required for a New Development Regulation
                              Update by Characteristic

                                       20%
         Large City                    20%
                                              31%
       Medium City                     19%
                                                                56%
                                             31%
                                          26%
         Small City                         30%
                            4%


                                      20%                                          Data Analysis
               CPS               10%                                               Modeling
                                          30%
                                   15%                                             Outreach
                                    17%
         Northwest                          33%                                    Other
                                    17%
                                                                56%
         Southwest               11%
                                                         44%
                                        22%
                                        22%
           Central                                       44%



                                              30%
            2.0/3.0         4%
                                                          48%
                                  13%
                      0%          20%          40%              60%     80%           100%


  Exhibit 159. Number of Consultant Contracts for a New Development Regulation
                            Update by Characteristic
          Large City                                     100%
                                                                                       0
         Medium City                         62%                      31%         8%
                                                                                     1 to 5
           Small City                          71%                      21%       7%
                                                                                     5 to 10
                                                                                     10 to 50
                CPS                          67%                       25%        8%
                                                                                     >50
           Northwest                                     100%
           Southwest                         63%                      25%       13%
             Central                               80%                        20%

               2.0/3.0                         72%                          22%   6%
                           0%       20%            40%          60%    80%        100%




DEPT OF COMMERCE                                                                                 PAGE 103
EVALUATION OF PLANNING COSTS                                                               JANUARY 3, 2022
  Exhibit 160. Number of Stakeholder                              Exhibit 161. Number of Public Meetings
   Meetings for a New Development                                   for a New Development Regulation
 Regulation Update by Characteristic                                      Update by Characteristic

  Large City          60%               40%                         Large City            60%         20% 20%
Medium City           62%               38%                       Medium City            57%          29% 7% 7%
  Small City              79%               21%                      Small City         43%         36%     21%


        CPS           67%               33%                                CPS           54%          31%   15%

  Northwest                    100%                                 Northwest                 75%           25%

  Southwest           63%               38%                         Southwest            50%        25% 13%13%

    Central           60%               40%                             Central         40%           60%



     2.0/3.0              72%               28%                          2.0/3.0         50%        28% 17%       6%

               0%              50%            100%                                 0%           50%           100%
                0                           1 to 5                                  0 1 to 5 5 to 10 10 to 50


    Exhibit 162. Other Types of Public Engagement Used for a New Development
                         Regulation Update by Characteristic
                                                       40%
          Large City                        20%
                                                                              75%
        Medium City                    13% 25%
                                       13%
                                      11%             37%
           Small City
                                        15%
                                                                             Website
                                       15%                  45%              Survey
                    CPS         5%
                                5%                                           Language
                                                              50%
          Northwest                     17%                                  Translation
                                        17%
                                                     33%                 67% Other
          Southwest
                                             22%
                                                           44%
               Central                11%
                                      11%


                                    13%                            57%
                2.0/3.0           9%    22%
                          0%           20%           40%          60%        80%         100%




DEPT OF COMMERCE                                                                                      PAGE 104
EVALUATION OF PLANNING COSTS                                                                    JANUARY 3, 2022
Appendix N. New Development Regulation Detail for Counties
by Characteristic
Exhibit 163. Total Costs for a New Development Regulation Update by Characteristic




      Exhibit 164. Per 1,000 Population Cost (excluding SEPA/NEPA) for a New
                 Development Regulation Update by Characteristic




DEPT OF COMMERCE                                                        PAGE 105
EVALUATION OF PLANNING COSTS                                      JANUARY 3, 2022
     Exhibit 165. Labor and Contract Costs as a Share of Total Costs for a New
                 Development Regulation Update by Characteristic




  Exhibit 166. Level of Confidence in            Exhibit 167. Length of Time to
Cost Estimates for a New Development            Complete a New Development
 Regulation Update by Characteristic          Regulation Update by Characteristic




DEPT OF COMMERCE                                                         PAGE 106
EVALUATION OF PLANNING COSTS                                       JANUARY 3, 2022
 Exhibit 168. Types of Technical Tasks Required for a New Development Regulation
                              Update by Characteristic




  Exhibit 169. Number of Consultant Contracts for a New Development Regulation
                            Update by Characteristic




DEPT OF COMMERCE                                                       PAGE 107
EVALUATION OF PLANNING COSTS                                     JANUARY 3, 2022
  Exhibit 170. Number of Stakeholder      Exhibit 171. Number of Public Meetings
   Meetings for a New Development           for a New Development Regulation
 Regulation Update by Characteristic              Update by Characteristic




   Exhibit 172. Other Types of Public Engagement Used for a New Development
                        Regulation Update by Characteristic




DEPT OF COMMERCE                                                     PAGE 108
EVALUATION OF PLANNING COSTS                                   JANUARY 3, 2022
Appendix O. Technical Assistance Needs Ranked by Region
Areas of challenge and technical assistance preferences are ranked on a scale of one to
ten, with one being most important and ten being least important.

Circuit rider services rank highest among jurisdictions within the Central region.

               Exhibit 173. Areas of Greatest Challenges and Technical Assistance
                           Preferences, Central Washington Geography




Within the Eastern region, jurisdictions have little interest in involving regional
agencies. Similar to statewide results, there is a lot of interest in circuit rider services
as well as data and analytical tools.




DEPT OF COMMERCE                                                                  PAGE 109
EVALUATION OF PLANNING COSTS                                                JANUARY 3, 2022
              Exhibit 174. Areas of Greatest Challenges and Technical Assistance
                          Preferences, Eastern Washington Geography




Standouts for the Central Puget Sound region include a high interest in model policy
language.

              Exhibit 175. Areas of Greatest Challenges and Technical Assistance
                         Preferences, Central Puget Sound Geography




DEPT OF COMMERCE                                                            PAGE 110
EVALUATION OF PLANNING COSTS                                          JANUARY 3, 2022
           Exhibit 176. Areas of Greatest Challenges and Technical Assistance
                            Preferences, Northwest Geography




           Exhibit 177. Areas of Greatest Challenges and Technical Assistance
                            Preferences, Southwest Geography




DEPT OF COMMERCE                                                      PAGE 111
EVALUATION OF PLANNING COSTS                                    JANUARY 3, 2022
Appendix P. Survey Instrument
The Washington State Department of Commerce has been tasked with conducting a
study of the costs to cities and counties of planning requirements. The survey presents a
series of questions to gather cost data for seven specific planning activities. A part
of this task also includes understanding the interest cities and counties have in various
forms of technical assistance. Survey responses will be aggregated to provide the
legislature with a data informed understanding of the costs to complete required
planning activities. Your participation will ensure that the legislature has a
comprehensive understanding of the costs to cities and counties when making
future decisions for required planning activities. Findings will also help the
legislature as they make future decisions on technical assistance the
Department of Commerce can provide.

Below are a series of questions for each of the seven specific planning activities. A
definition for each of these activities is provided for reference. Please provide cost
estimates for each of the major elements outlined below for your City/County’s latest
experience with this activity. Additional details for each activity will help provide the
legislature with the best possible assessment of the costs of planning for Washington
cities and counties.

If you have any questions, please contact Nicole Witenstein at
nicole@communityattributes.com. You may also submit data on your costs via Excel or
another format, if that is simpler for you.

Please provide your contact information:

City/County*: Enter City/County.

Name*: Enter your name.

Position: Enter your position.

Email: Enter your email.

Phone: Enter your phone number.

New Comprehensive Plan Element
A new comprehensive plan element includes the following:
      A new chapter containing new introductions, goals, policies and objectives.
      Minor modifications to policies/policy additions to two existing elements to tie
       into a new planning element (for example – land use and housing element goals
       often have some overlapping language for consistency.)
      Minor modifications to three different chapters of development regulations to
       implement a new goal. This includes minor zoning map changes, minor

DEPT OF COMMERCE                                                              PAGE 112
EVALUATION OF PLANNING COSTS                                            JANUARY 3, 2022
       modifications to subdivision regulations, and minor bulk standard zoning
       changes.
      Engagement activities which include development of website content, publishing
       of public hearing notices, materials, staff reports, and ordinances. It also includes
       two planning commissions and two council meetings or hearings.
      Medium level of public or state or federal agency involvement. Up to 20 comment
       letters.
      SEPA DNS, MDNS, or adoption of existing document. No EIS or SEIS.
      No appeals.
Please provide fully loaded cost estimates for the following cost
components for a new comprehensive plan element.

Note: fully loaded costs include staff labor costs, including wages and benefits, as well as
materials and contracts.

Staff Recovery Rate: $ Enter staff recovery rate per hour here.
Staff recovery rate refers to the fully loaded staff costs on an hourly basis

Staff & Labor Costs or Hours: $ Enter staff and labor costs/hours here.

Are your staff and labor entries above listed as staff hours or total costs?
     ☐Hours              ☐Total Costs

Contracted Services: $ Enter contracted services costs here.

If applicable, how many contracts for services did this activity require?
Enter number here.

Please specify the types of technical tasks that required consultant support:
Enter description here.

Other Costs or Hours: $ Enter other costs/hours here.

Are your other cost or hours entries above listed as staff hours or total costs?
     ☐Hours             ☐Total Costs

Please specify the types of costs included in the other category: Enter
description here.
Note: Other costs or hours excludes contracted services.

Specify year(s) you last engaged in the above activity: Enter year here.

How long did this planning activity require? (Select one)


DEPT OF COMMERCE                                                                 PAGE 113
EVALUATION OF PLANNING COSTS                                               JANUARY 3, 2022
     ☐Less than one year ☐1-2 years   ☐More than 2 years

What types of technical tasks were included in this activity (Select all
that apply)

     ☐Data Analysis

     ☐Modeling

     ☐Public and Stakeholder Outreach

     ☐Other (Please specify):

Did this activity include a SEPA/NEPA EIS?

     ☐Yes           ☐No

SEPA/NEPA EIS Costs: $ Enter other SEPA/NEPA EIS costs here.

How many public meetings did this activity require? Enter number here.

How many focus groups or other types of stakeholder meetings did this
activity include? Enter number here.

What other forms of public engagement did this activity include? (Select
all that apply)

     ☐Language translation services

     ☐Website

     ☐Stakeholder/public survey

     ☐Other (Please specify)

What other unique characteristics influence the cost of the activity?
Enter description here.

What is your level of confidence in the cost estimate provided?

     ☐Low           ☐Medium           ☐High




DEPT OF COMMERCE                                                     PAGE 114
EVALUATION OF PLANNING COSTS                                   JANUARY 3, 2022
Update Critical Areas Ordinance
An update to a critical areas ordinance includes:

      Minor update to critical areas regulations following the guidance in WAC 365-195
       (Shoreline Master program approval/amendment procedures and master
       program guidelines).
      Base level engagement activities as outlined in WAC 173-26-100.
      Engagement activities which include development of website content, publishing
       of public hearing notices, materials, staff reports, and ordinances. Includes two
       planning commissions and two council meetings or hearings.
      Medium level of public or state and federal agency involvement. Up to 20
       comment letters.
      SEPA DNS, MDNS, or adoption of existing document. No EIS or SEIS.
      No appeals.
Please provide fully loaded cost estimates for the following cost
components to update a critical areas ordinance.

Note: fully loaded costs include staff labor costs, including wages and benefits, as well as
materials, and contracts.

Staff Recovery Rate: $ Enter staff recovery rate per hour here.
Staff recovery rate refers to the fully loaded staff costs on an hourly basis

Staff & Labor Costs or Hours: $ Enter staff and labor costs/hours here.

Are your staff and labor entries above listed as staff hours or total costs?
     ☐Hours              ☐Total Costs

Contracted Services: $ Enter contracted services costs here.

If applicable, how many contracts for services did this activity require?
Enter number here.

Please specify the types of technical tasks that required consultant support:
Enter description here.

Other Costs or Hours: $ Enter other costs/hours here.

Are your other cost or hours entries above listed as staff hours or total costs?
     ☐Hours             ☐Total Costs

Please specify the types of costs included in the other category: Enter
description here.

DEPT OF COMMERCE                                                                 PAGE 115
EVALUATION OF PLANNING COSTS                                               JANUARY 3, 2022
Note: Other costs or hours excludes contracted services.

Specify year(s) you last engaged in the above activity: Enter year here.

How long did this planning activity require? (Select one)

      ☐Less than one year ☐1-2 years      ☐More than 2 years

What types of technical tasks were included in this activity (Select all
that apply)

      ☐Data Analysis

      ☐Modeling

      ☐Public and Stakeholder Outreach

      ☐Other (Please specify):

Did this activity include a SEPA/NEPA EIS?

      ☐Yes           ☐No

SEPA/NEPA EIS Costs: $ Enter other SEPA/NEPA EIS costs here.

How many public meetings did this activity require? Enter number here.

How many focus groups or other types of stakeholder meetings did this
activity include? Enter number here.

What other forms of public engagement did this activity include? (Select
all that apply)

      ☐Language translation services

      ☐Website

      ☐Stakeholder/public survey

      ☐Other (Please specify)

What other unique characteristics influence the cost of the activity?
Enter description here.

What is your level of confidence in the cost estimate provided?


DEPT OF COMMERCE                                                     PAGE 116
EVALUATION OF PLANNING COSTS                                   JANUARY 3, 2022
       ☐Low          ☐Medium               ☐High

Update a Shoreline Master Program Ordinance
An update to a shoreline master program ordinance includes:

      Minor updates to the shoreline master program following the guidance in WAC
       173-26 (Shoreline Master program approval/amendment procedures and master
       program guidelines).
      Includes base level engagement activities as outlined in WAC 173-26-100.
      Engagement activities include development of website content, publishing of
       public hearing notices, materials, staff reports, and ordinances. Includes two
       planning commission and two council meetings or hearings.
      Medium level of public or state and federal agency involvement. Up to 20
       comment letters.
      SEPA DNS, MDNS, or adoption of existing document. No EIS or SEIS.
      No appeals.
Please provide fully loaded cost estimates for the following cost
components to update a shoreline master program ordinance.

Note: fully loaded costs include staff labor costs, including wages and benefits, as well as
materials, and contracts.

Staff Recovery Rate: $ Enter staff recovery rate per hour here.
Staff recovery rate refers to the fully loaded staff costs on an hourly basis

Staff & Labor Costs or Hours: $ Enter staff and labor costs/hours here.

Are your staff and labor entries above listed as staff hours or total costs?
     ☐Hours              ☐Total Costs

Contracted Services: $ Enter contracted services costs here.

If applicable, how many contracts for services did this activity require?
Enter number here.

Please specify the types of technical tasks that required consultant support:
Enter description here.

Other Costs or Hours: $ Enter other costs/hours here.

Are your other cost or hours entries above listed as staff hours or total costs?
     ☐Hours             ☐Total Costs


DEPT OF COMMERCE                                                                 PAGE 117
EVALUATION OF PLANNING COSTS                                               JANUARY 3, 2022
Please specify the types of costs included in the other category: Enter
description here.
Note: Other costs or hours excludes contracted services.

Specify year(s) you last engaged in the above activity: Enter year here.

How long did this planning activity require? (Select one)

     ☐Less than one year ☐1-2 years   ☐More than 2 years

What types of technical tasks were included in this activity (Select all
that apply)

     ☐Data Analysis

     ☐Modeling

     ☐Public and Stakeholder Outreach

     ☐Other (Please specify):

Did this activity include a SEPA/NEPA EIS?

     ☐Yes           ☐No

SEPA/NEPA EIS Costs: $ Enter other SEPA/NEPA EIS costs here.

How many public meetings did this activity require? Enter number here.

How many focus groups or other types of stakeholder meetings did this
activity include? Enter number here.

What other forms of public engagement did this activity include? (Select
all that apply)

     ☐Language translation services

     ☐Website

     ☐Stakeholder/public survey

     ☐Other (Please specify)

What other unique characteristics influence the cost of the activity?
Enter description here.


DEPT OF COMMERCE                                                       PAGE 118
EVALUATION OF PLANNING COSTS                                     JANUARY 3, 2022
What is your level of confidence in the cost estimate provided?

       ☐Low          ☐Medium                ☐High

Minor Update to a Comprehensive Plan Element
A minor update to a comprehensive plan element includes:

      Up to 10 new or modified policies.
      Assumes that guidance is provided such as revised Countywide Planning Policies
       (CPPs), state law changes, or prepared guidance that makes clear what needs to
       be amended within the comprehensive plan element.
      Engagement activities include development of website content, publishing of
       public hearing notices, materials, staff reports, and ordinances. Includes two
       planning commission and two council meetings or hearings.
      Medium level of public or state and federal agency involvement. Up to 20
       comment letters.
      SEPA DNS, MDNS, or adoption of existing document.
      No appeals.
Please provide fully loaded cost estimates for the following cost
components for a minor update to a comprehensive plan element.

Note: fully loaded costs include staff labor costs, including wages and benefits, as well as
materials, and contracts.

Staff Recovery Rate: $ Enter staff recovery rate per hour here.
Staff recovery rate refers to the fully loaded staff costs on an hourly basis

Staff & Labor Costs or Hours: $ Enter staff and labor costs/hours here.

Are your staff and labor entries above listed as staff hours or total costs?
     ☐Hours              ☐Total Costs

Contracted Services: $ Enter contracted services costs here.

If applicable, how many contracts for services did this activity require?
Enter number here.

Please specify the types of technical tasks that required consultant support:
Enter description here.

Other Costs or Hours: $ Enter other costs/hours here.

Are your other cost or hours entries above listed as staff hours or total costs?

DEPT OF COMMERCE                                                                 PAGE 119
EVALUATION OF PLANNING COSTS                                               JANUARY 3, 2022
     ☐Hours              ☐Total Costs

Please specify the types of costs included in the other category: Enter
description here.
Note: Other costs or hours excludes contracted services.

Specify year(s) you last engaged in the above activity: Enter year here.

How long did this planning activity require? (Select one)

     ☐Less than one year ☐1-2 years     ☐More than 2 years

What types of technical tasks were included in this activity (Select all
that apply)

     ☐Data Analysis

     ☐Modeling

     ☐Public and Stakeholder Outreach

     ☐Other (Please specify):

Did this activity include a SEPA/NEPA EIS?

     ☐Yes          ☐No

SEPA/NEPA EIS Costs: $ Enter other SEPA/NEPA EIS costs here.

How many public meetings did this activity require? Enter number here.

How many focus groups or other types of stakeholder meetings did this
activity include? Enter number here.

What other forms of public engagement did this activity include? (Select
all that apply)

     ☐Language translation services

     ☐Website

     ☐Stakeholder/public survey

     ☐Other (Please specify)




DEPT OF COMMERCE                                                       PAGE 120
EVALUATION OF PLANNING COSTS                                     JANUARY 3, 2022
What other unique characteristics influence the cost of the activity?
Enter description here.

What is your level of confidence in the cost estimate provided?

       ☐Low          ☐Medium               ☐High

Complex Update to a Comprehensive Plan Element
A major update to a comprehensive plan element, including updates to an element as
part of the 10-year periodic update, includes:

      Preparing a policy gap analysis to review existing policies vs. recent changes to
       state laws, case law, and regional policies.
      Major modifications to policies and policy additions in response to policy gap
       analysis.
      Revision to chapter introduction.
      Documentation of consistency with Commerce checklist (assumes major change is
       conducted as part of the 10-year periodic update).
      Engagement activities include development of website content, publishing of
       public hearing notices, materials, staff reports, and ordinances. Includes two
       planning commission and two council meetings or hearings.
      Medium level of public or state and federal agency involvement. Up to 20
       comment letters.
      SEPA DNS, MDNS, or adoption of existing document.
      No appeals.
Please provide fully loaded cost estimates for the following cost
components for a complex update to a comprehensive plan element.

Note: fully loaded costs include staff labor costs, including wages and benefits, as well as
materials, and contracts.

Staff Recovery Rate: $ Enter staff recovery rate per hour here.
Staff recovery rate refers to the fully loaded staff costs on an hourly basis

Staff & Labor Costs or Hours: $ Enter staff and labor costs/hours here.

Are your staff and labor entries above listed as staff hours or total costs?
     ☐Hours              ☐Total Costs

Contracted Services: $ Enter contracted services costs here.



DEPT OF COMMERCE                                                                 PAGE 121
EVALUATION OF PLANNING COSTS                                               JANUARY 3, 2022
If applicable, how many contracts for services did this activity require?
Enter number here.

Please specify the types of technical tasks that required consultant support:
Enter description here.

Other Costs or Hours: $ Enter other costs/hours here.

Are your other cost or hours entries above listed as staff hours or total costs?
     ☐Hours             ☐Total Costs

Please specify the types of costs included in the other category: Enter
description here.
Note: Other costs or hours excludes contracted services.

Specify year(s) you last engaged in the above activity: Enter year here.

How long did this planning activity require? (Select one)

     ☐Less than one year ☐1-2 years   ☐More than 2 years

What types of technical tasks were included in this activity (Select all
that apply)

     ☐Data Analysis

     ☐Modeling

     ☐Public and Stakeholder Outreach

     ☐Other (Please specify):

Did this activity include a SEPA/NEPA EIS?

     ☐Yes            ☐No

SEPA/NEPA EIS Costs: $ Enter other SEPA/NEPA EIS costs here.

How many public meetings did this activity require? Enter number here.

How many focus groups or other types of stakeholder meetings did this
activity include? Enter number here.

What other forms of public engagement did this activity include? (Select
all that apply)


DEPT OF COMMERCE                                                       PAGE 122
EVALUATION OF PLANNING COSTS                                     JANUARY 3, 2022
       ☐Language translation services

       ☐Website

       ☐Stakeholder/public survey

       ☐Other (Please specify)

What other unique characteristics influence the cost of the activity?
Enter description here.

What is your level of confidence in the cost estimate provided?

       ☐Low          ☐Medium               ☐High

Update an Existing Development Regulation
An update to an existing development regulation includes:

      Research for code update.
      Development of draft and final code language.
      Engagement activities which include development of website content, publishing
       of public hearing notices, materials, staff reports, and ordinances. Includes two
       planning commission and two council meetings or hearings.
      Medium level of public or state and federal agency involvement. Up to 20
       comment letters.
      SEPA DNS, MDNS, or adoption of existing document. No EIS or SEIS.
      No appeals.
Please provide fully loaded cost estimates for the following cost
components for an update to an existing development regulation.

Note: fully loaded costs include staff labor costs, including wages and benefits, as well as
materials, and contracts.

Staff Recovery Rate: $ Enter staff recovery rate per hour here.
Staff recovery rate refers to the fully loaded staff costs on an hourly basis

Staff & Labor Costs or Hours: $ Enter staff and labor costs/hours here.

Are your staff and labor entries above listed as staff hours or total costs?
     ☐Hours              ☐Total Costs

Contracted Services: $ Enter contracted services costs here.


DEPT OF COMMERCE                                                                 PAGE 123
EVALUATION OF PLANNING COSTS                                               JANUARY 3, 2022
If applicable, how many contracts for services did this activity require?
Enter number here.

Please specify the types of technical tasks that required consultant support:
Enter description here.

Other Costs or Hours: $ Enter other costs/hours here.

Are your other cost or hours entries above listed as staff hours or total costs?
     ☐Hours             ☐Total Costs

Please specify the types of costs included in the other category: Enter
description here.
Note: Other costs or hours excludes contracted services.

Specify year(s) you last engaged in the above activity: Enter year here.

How long did this planning activity require? (Select one)

     ☐Less than one year ☐1-2 years   ☐More than 2 years

What types of technical tasks were included in this activity (Select all
that apply)

     ☐Data Analysis

     ☐Modeling

     ☐Public and Stakeholder Outreach

     ☐Other (Please specify):

Did this activity include a SEPA/NEPA EIS?

     ☐Yes            ☐No

SEPA/NEPA EIS Costs: $ Enter other SEPA/NEPA EIS costs here.

How many public meetings did this activity require? Enter number here.

How many focus groups or other types of stakeholder meetings did this
activity include? Enter number here.

What other forms of public engagement did this activity include? (Select
all that apply)


DEPT OF COMMERCE                                                       PAGE 124
EVALUATION OF PLANNING COSTS                                     JANUARY 3, 2022
       ☐Language translation services

       ☐Website

       ☐Stakeholder/public survey

       ☐Other (Please specify)

What other unique characteristics influence the cost of the activity?
Enter description here.

What is your level of confidence in the cost estimate provided?

       ☐Low          ☐Medium               ☐High

Implement a New Development Regulation
A new development regulation includes:

      Work to get new code language online (such as work with code publishing).
      Training for permit reviewers on new code.
      Development of materials for customers such as new development handouts.
      Implement new changes to permit tracking system.
      Modify fee collection (assumes new fee based on code change).
Please provide fully loaded cost estimates for the following cost
components to implement a new development regulation.

Note: fully loaded costs include staff labor costs, including wages and benefits, as well as
materials, and contracts.

Staff Recovery Rate: $ Enter staff recovery rate per hour here.
Staff recovery rate refers to the fully loaded staff costs on an hourly basis

Staff & Labor Costs or Hours: $ Enter staff and labor costs/hours here.

Are your staff and labor entries above listed as staff hours or total costs?
     ☐Hours              ☐Total Costs

Contracted Services: $ Enter contracted services costs here.

If applicable, how many contracts for services did this activity require?
Enter number here.




DEPT OF COMMERCE                                                                 PAGE 125
EVALUATION OF PLANNING COSTS                                               JANUARY 3, 2022
Please specify the types of technical tasks that required consultant support:
Enter description here.

Other Costs or Hours: $ Enter other costs/hours here.

Are your other cost or hours entries above listed as staff hours or total costs?
     ☐Hours             ☐Total Costs

Please specify the types of costs included in the other category: Enter
description here.
Note: Other costs or hours excludes contracted services.

Specify year(s) you last engaged in the above activity: Enter year here.

How long did this planning activity require? (Select one)

     ☐Less than one year ☐1-2 years   ☐More than 2 years

What types of technical tasks were included in this activity (Select all
that apply)

     ☐Data Analysis

     ☐Modeling

     ☐Public and Stakeholder Outreach

     ☐Other (Please specify):

Did this activity include a SEPA/NEPA EIS?

     ☐Yes          ☐No

SEPA/NEPA EIS Costs: $ Enter other SEPA/NEPA EIS costs here.

How many public meetings did this activity require? Enter number here.

How many focus groups or other types of stakeholder meetings did this
activity include? Enter number here.

What other forms of public engagement did this activity include? (Select
all that apply)

     ☐Language translation services

     ☐Website

DEPT OF COMMERCE                                                       PAGE 126
EVALUATION OF PLANNING COSTS                                     JANUARY 3, 2022
     ☐Stakeholder/public survey

     ☐Other (Please specify)

What other unique characteristics influence the cost of the activity?
Enter description here.

What is your level of confidence in the cost estimate provided?

     ☐Low           ☐Medium             ☐High

Technical Assistance
We are looking at ways the state can provide more assistance to local
governments, particularly cities and counties, with fewer resources.

Please rank the following options in order of preference for which
Washington state should fund to help local governments plan under the
Growth Management Act.

     ☐More technical assistance to cities and counties

     ☐Model policy language for comprehensive plan updates

     ☐Optional process of state approval and defense from appeal

     ☐Allow some portion of comprehensive plan grant funds to be used for technical
     assistance

     ☐Mediation and facilitation services

     ☐Communications and PR expertise for assistance in complex, controversial
     planning issues

     ☐Expanding the roles colleges and universities can play in assisting local
     governments

     ☐None of these

     ☐Other (Please specify)

Should more counties be required to regularly update countywide
planning policies?

     ☐Yes           ☐No



DEPT OF COMMERCE                                                            PAGE 127
EVALUATION OF PLANNING COSTS                                          JANUARY 3, 2022
Should slow-growing cities and counties that fully plan under the
Growth Management Act have fewer requirements if their growth rate
falls below a certain rate in the years leading up to their comprehensive
plan update?

     ☐Yes           ☐No

What are specific ideas you may have for how to eliminate gaps,
conflicts, and overlaps in state requirements? Please briefly describe up
to three below.

Enter description here.

Conclusion
Is there anything else you would like to share about the costs of
planning requirements or technical assistance for local governments?

Enter description here.



Thank you for your participation!




DEPT OF COMMERCE                                                 PAGE 128
EVALUATION OF PLANNING COSTS                               JANUARY 3, 2022
Appendix Q. Interview Questions
        Introduction
        The Washington State Department of Commerce has been tasked with
        conducting a study of the costs to cities and counties of planning
        requirements. A part of this task includes understanding the interest in
        cities and counties have in various forms of technical assistance, as well as
        the potential effectiveness of technical assistance. Findings from these
        interviews will help the legislature as they make future decisions on
        technical assistance the Department of Commerce can provide as well as
        future legislative decisions.

        Questions
        1. What are your primary challenges in completing the planning
           requirements in the Growth Management Act?
        2. Please rank on a scale of 1 to 10, with 1 being the most important, the
           importance the areas of planning activities where your jurisdiction may
           need additional support?
                  Changes to state, regional, or county law and policies?
                  Specific comprehensive plan elements?
                  Critical Areas based on best available science?
                  Impact fees?
                  Capital facility planning?
                  Alignment with case law and Growth Management Hearings Board
                   appeals?
                  Other? (Please describe)
        3. Would additional technical assistance provided by the Department of
           Commerce or other state agencies be utilized? Please describe.
        4. Please rank on a scale of 1 to 10, with 1 being the most important, your
           interest in the following types of technical assistance?
                  Model codes or ordinance provisions
                  Model policy language for comprehensive plan updates
                  State provision of data or analytical tools
                  Circuit rider services to directly staff local planning activities
                        o   How many hours of additional planning staff could you
                            make use of?



DEPT OF COMMERCE                                                              PAGE 129
EVALUATION OF PLANNING COSTS                                            JANUARY 3, 2022
                       o   What types of tasks would these additional planning staff
                           support?
                       o   In what way would additional staff increase your capacity
                           for planning?
                 Master consultant agreements for planning services
                 Involve regional agencies, such as councils of government, to
                  provide planning services to member local jurisdictions
                       o   What planning services could your county or regional
                           agencies support?
                       o   How regularly could you use these services?
                 Expand the role of colleges and universities in assisting local
                  governments with planning activities
                 Optional process of state approval and defense from appeal
                 Allow some portion of comprehensive plan grant funds to be used
                  for technical assistance
                 Mediation and facilitation services
                 Communications and PR expertise for assistance in
                  complex/controversial planning issues
                 Other (please describe)
                 None of the above
        5. What other models, pilot programs, options for technical assistance could
           you make use of?




DEPT OF COMMERCE                                                           PAGE 130
EVALUATION OF PLANNING COSTS                                         JANUARY 3, 2022


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