Trail connection coming soon.

A vision that has been held for decades is finally going to pay off.

I had heard that the "Fairgounds trail" was moving forward but saw in the paper this morning that even better than that, with enough volunteer help, it could be ready for use in a month.

In an article on the front page of the Life section of the Columbian, written by Scott Hewitt, says that this short trail will be an important connection to a trail that will eventually connect our regional parks. Lisa Goorjian, a landscape architect with the Vancouver-Clark parks says this trail will eventually run from the Columbia River on the west to the Mount Vista area, near the campus of Washington State University Vancouver, on the east.

Dennis and I were part of a committee that continued long standing work to get a trail from the fairgounds to Whipple Creek park. When that committee died because of a change in county employees, we felt like that option would be gone forever.

Let me encourage you to not give up on a good idea for the good of our horse community. Where we left off, others came in and now we will have our trail!

Thank you to all who worked to get this accomplished.

Now we just need 'wet gloves on the handle of a shovel' to get this trail ready to ride.

Park Plan Passes

For those of you that don't get The Columbian in print or online, here is the article from yesterday's paper.

County commissioners voted 3-0 on Tuesday to approve the Lower Daybreak Regional Park master plan, acknowledging that there’s no funding in sight but recognizing that formally adopting the plan opens up the possibility of receiving grants for the project.

This is a victory for the horse community in that extensive equine facilities are planned for the area. Clark County Executive Horse Council and interested individuals have worked for may years to get the county to ok something like this. There is no money to accomplish the plan right now but just having it ok'd is a start.

Many thanks to Butch Reynolds, president of the Clark County Executive Horse Council for getting this passed. It is a good thing............

Land use Meetings

There are two meetings this week that would be of interest to the local horse community.

Tonight, Nov 9th, the Equestrian Advisory group for the first time.

Tomorrow night, Nov 10th, there will be an open house to let you know about what is being discussed by the Rural Lands task force.


But before I go on more about those meetings, let me tell you that I am getting confused! I love the fact that our city and county officials are finally looking at making the area more horse friendly. The tough part is that there are so many groups and meetings that sound alike, I’m having a hard time keeping them straight - and I make it my business to keep up on these things. I have spent several hours figuring out the names of these task groups and what they are about. I hope this helps.


Like I have been saying for a bit now, I think the tide is turning and local governments are realizing the need for the citizens of our county to enjoy a ‘back to the land’ life style and are aligning the codes and zoning to facilitate that.

Here goes:

Urban Livestock Task Force (Urban Livestock review) has completed its job.

In response to a complaint about horses on small acreage in the Vancouver UGA and resulting concern from some that the County was going to restrict the keeping of horses on smaller parcels, the Board of Clark County Commissioners (BOCC) appointed a task force on urban livestock
The Board of Clark County Commissioners adopted an urban livestock ordinance at its hearing on October 6, 2009. The ordinance takes affect on November 1, 2009. The new ordinance is Section 40.260.235 of the Clark County Code.




The Rural Lands Task force is an ongoing group working on the Rural lands review

Current rural land zoning in the county was established in 1994 with the adoption of the County's first comprehensive plan under the Growth Management Act (GMA). The County has completed two comprehensive plan updates since then (2004 and 2007), but their focus has been on urban areas and how to accommodate projected growth.
After completion of the 2007 update of the Growth Management Act, the BOCC directed a review of rural lands.
The first phase is completed with task force recommendations listed here.

They are working at making our county more Ag friendly, perhaps even encouraging Ag use on appropriate land. If you have not taken the online survey that I talked about in a previous blog, click here to get your opinion counted. They are listening.

This is the new kid on the block and is also from the Community Planning people.

Equestrian advisory group was formed because of the interest shown by horse people in the Rural lands Review. (see they are listening)
Their first meeting will be tonight, Nov. 9th, and is open to the public.

The advisory group will help develop an equestrian plan focusing on the following elements:

• Equestrian trails
• Equestrian overlay district to supplement existing zoning
• Best management practices
• Economic development opportunities at the county fairgrounds

For more information, please contact Laurie Lebowsky in Community Planning at (360) 397-2280 ext. 4544 or e-mail Laurie.Lebowsky@clark.wa.gov.
The seven-member Equestrian Advisory Group will look at topics ranging from trails and events to zoning that could support equestrian-related housing developments.


Just to add one more element, the city of Vancouver has created the City of Vancouver - Urban Livestock Advisory Group. I am a member of this group and we have been meeting since the middle of August. We are working on possible code changes that would allow the raising of farm animals within the City limits. These would affect the residents of the City of Vancouver with an eye out for the folks in the Urban Growth Boundary that will become part of the city in the future.


OK, so I hope this makes the issues a bit clearer. Or if not, at least you know about the discussions going on in the area concerning our horse keeping.

Daybreak Park

When: Wednesday, October 14th – 7:00 PM
Were: Daybreak Primary and Middle School commons
1900 NW 20th Ave, Battle Ground

What: Another meeting……………..

Seems like there have been a lot lately but these are all important for the future of our horse community. And they seem to be making a difference.

The latest one is a chance for us to let the county know what we think should happen at Daybreak Park.

There was a good article in The Columbian this morning about this meeting. The county is looking to private groups – including us – for good ideas about the use of the 112-acre undeveloped site on the south bank of the East Fork Lewis River. They are looking for partnerships in the planning and developing of the park. The meeting on Wednesday will be for public comment. Jean Akers, county parks planner, stated: “I think there are a number of different groups out there who are interested. I’ll wait and see who comes on Wednesday.” The county will use residents’ input from the Wednesday meeting and from comments on the expansion project’s web site. The plan that is developed from this input will be presented in a public meeting in December. Online, e-mail and phone comments will be accepted from Oct. 15-29. Check out Lower Daybreak Regional Park Master Plan web site for more information.

Or contact:
Pat Lee, Legacy Lands Program Manager
(360) 397-2375 ext. 4070
Patrick.Lee@clark.wa.gov

Jean Akers, Park Planner
Vancouver-Clark Parks and Recreation
(360) 619-1120
Jean.Akers@ci.vancouver.wa.us

There have been conversations about making this park a major equine area and it sounds to me like the county is asking us, the horse community, to put our time and money where ‘our’ mouth is. We can start by showing up at the meeting to let them know that we want into the party.

This meeting will be in Battle Ground but it will affect all of the horse community. Even if you are from East County, come and stand up for more horse event and trail areas. Send me an email from ‘post a comment’ if you need directions.

See you there,
Jody Benson

Urban Livestock Hearing Oct 6th

Just to remind you. Come all who can.

The county is listening to us and we need to make sure they know we are interested in what happens to the horses in this county.
This is the continuation of the meeting we attended in July where the planners were directed to go back and look at the issues again. At that time we asked that they offer an evening meeting so more people could attend.

PUBLIC HEARING: URBAN LIVESTOCK
6:00 PM
Public Service Center, 1300 Franklin Street, 6th Floor

To consider proposed addition of a special uses section of the Clark County Code dealing with Urban Livestock (Clark County Code 40.260.235). Continued from July 21, 2009. Staff Report
Staff: Gordy Euler, 360.397.2280, ext. 4968

The tide may be turning......

I need to lead off this post by saying that I choose to be an optimist.

People in this horse community have been working for years to open the eyes of the local officials to see the value in making this a more horse-friendly area. For the most part, it has felt like they have been banging their heads against the closed barn door.

I have reasons to believe that someone has been listening to the noise and they are thinking about seeing what may be inside the barn. Corny I know but I think that may be just what is happening.

I am a member of the City of Vancouver Urban Livestock Advisory Group, lead by John T Manley, Senior Planner from Vancouver Community Planning. I am very excited about our conversations. The general direction is that the city is leaning towards looking more favorably at having livestock (both large and small) be part of the community with reasonable guidelines so that we can all remain neighborly. Allowing smaller animals on smaller lots and larger animals on reasonably sized properties with due consideration towards the surrounding neighbors.

In the county area, I have asked to be a part of the the Equestrian Advisory Group. Just reading the previously posted News Release gives me hope that someone has been listening and is starting to see that the horse community does have a real economic impact on the area. With a bit of proactive planning, it would be possible to build this county into a horse mecca and I think that would be so cool. We have a lot going for us already. We just need the 'officials' on board.

I know that all these thoughts are optimistic but as I already said, that is how I choose to look at it. Come join me. Give me your ideas. Dream big. Let's make this "The Premier Horse Community" in the state.

News Release

Clark County Community Planning
September 14, 2009

Contact: Laurie Lebowsky, Community Planning
(360) 397-2280 ext. 4544, e-mail laurie.lebowsky@clark.wa.gov

Equestrian Advisory Group forming to explore horse opportunities

Vancouver, WA - More opportunities for Clark County horse owners and riders could be identified in coming months thanks to a newly forming committee headed by Laurie Lebowsky of the Community Planning Department.

The seven-member Equestrian Advisory Group will look at topics ranging from trails and events to zoning that could support equestrian-related housing developments.

With an estimated 29,000 horses in local barns and fields, the Board of Clark County Commissioners directed planners to broaden recreational options for equine owners and economic development opportunities for the county. Equestrian activities include trail riding, 4-H open and breed shows, fair court, cow sorting, gaming, dressage, rodeo, drill teams, endurance riding, eventing, hunter/jumper, driving and pack trips.

The group will guide development of the plan to be presented at open houses scheduled in coming months to encourage additional public review and comment.

Three seats are vacant on the Equestrian Advisory Group. People interested in serving on the panel are asked to e-mail laurie.lebowsky@clark.wa.gov or call her at (360) 397-2280 ext. 4544.

Urban Livestock Code

The Board of County Commissioners will be holding a public hearing this coming Tuesday on the proposed Urban Livestock Code.

I believe some good people worked on this proposal but I believe there are still some questions that need to be asked and explained.

From the Draft of the Urban Livestock Task Force Concepts for Urban Livestock Code dated 3/25/09:
40.260.235 Urban Livestock
Page 2 line 8 -
D. 3. All buildings used for urban livestock shall be legally permitted.

This sentence concerns me because it appears to be a change from the current agriculture building requirements.

As I understand it now, in Clark County, an agricultural building does not need to be permitted through the county building department permit system as long if it is set back 50 feet from the property line.

There are a few other questions that others have asked and I’m hoping that this hearing will get them answered.

As usual, a good showing of horse people lets the Commissioners know that we are interested in what is happening in our county. Unfortunately the hearing is during the day so we need to really work to get people there. If you can’t attend, pass this information on to someone that you think might be able to come.

July 21st, 2009 @ 10am
Public Services Building, Commissioners Hearing Room
6th Floor
1300 Franklin Street
Vancouver, WA

You can read the proposed code and more information about how the task force developed this proposed code on the county webpage.

I'll see you there,

Jody

Results of Planning Commission meeting

I received this email from the President of WTRA -

Tonight I could not be prouder of the 40 men and woman who attended the City of Vancouver Planning Commission meeting to speak against the proposed development code amendments related to urban livestock.

Over 24 people spoke up giving well thought out, meaningful testimony to the value horses bring to the lives of their family and community. What was said tonight had an impact.

The planning commission sent back the proposed changes to the City of Vancouver planning department with recommendations of striking out the one acre per animal requirement and advising them to reach out to some of the groups represented to establish whether the current requirement of one acre for smaller animals was viable.

Sometimes what we say and how we say it makes a difference. Tonight it did.

Proud of all of you
Barbara Thomas


Way to go people. We did good.

This is just round one. I'll keep you updated on the progress and future meetings. This is of greatest concern to those of us in the Urban Growth Boundary but it does effect everyone within the horse community in one way or another.

Jody Benson

Urban Horses

Very Important Meeting:
Tuesday June 9th
7:00 PM
Vancouver City Council Chambers

The City Council is scheduled to APPROVE a proposed amendment to the development codes relating to the keeping and raising of livestock such as horses, bovine, pigs, sheep, goats, llamas etc. that will effect folks within the city limits now and those within the Urban Growth Boundary as the city annexes those areas.

The 1st change is the definition of domestic animal (VMC 20.150) which currently limits this definition to dogs, cats and other pets.

Under the new proposal, farm animals will be classified as a domestic animal.

Some of the concerns are not directly related to the proposed changes but would come into play because of current codes for ‘dogs and cats’.

1) Domestic animals which would now include cows and horses under VMC 8.24.180 2 c requires the owner to provide a barn or other enclosed structure sufficient to protect the animal from wind, rain, snow or sun and which has adequate bedding to protect against cold and dampness.

Lean-to’s would not be sufficient anymore. Additionally, enclosed structures require building permits and must follow the adopted international building codes. The proposed, but not adopted, county animal control changes directed toward farm animals only require access to basic shelter for two hours per day, not enclosed and there were no acreage requirements.

2) VMC section 20.912.060 prohibits electric or barbed wire fences. There is no indication that there will be any exemptions on this requirement for cows and horses.

3) Peope that work with animal control on horse rescues believe that this change has the potential to flood animal control with ‘created’ work when they need to be out rescuing the horses that are really in need of help.

The 2nd change comes under the general requirements for land for each bovine, horse, goat, sheep, llama or similar large farm animal.

Previously the ordinance read that a minimum of one acre is required for each farm animal and an additional 10,000 square feet must be provided for the second. This now will read that a minimum of one acre is required for each and every farm animal.
Section 20.930.020 allows for nonconforming use status (grand fathered uses). This lays the burden upon the property owner that they legally had the allowable number of horses on their property when under Clark County jurisdiction. The examples of proof include copies of building or land use permits or maps or some type of demonstration that the use was established before annexation.

This code does not clearly establish how livestock owners will be able to prove (for example) that they had 2 horses on 1.75 acres of land.

There is also an existing code that states “where a nonconforming use is discontinued or abandoned for one year, the nonconforming use status of the land shall be eliminated". This could mean that if your second horse on 1.75 acres dies or is lame you have one year to replace that horse or you will never be allowed to have two horses on your property again.

With these proposed changes in mind, these are some things that need to be addressed:

• Stables are not allowed within the city limits. Would this mean that any established stable would not be allowed to add on to what they have and if they have a fire they would not be allowed to re-build?
  
• How do we establish that we have X amount of horses on our land while in the county so that we can be grandfathered in?
  
• How do we keep our cows/horses inside our property without electric fencing or barb wire?? Is the city going to specify what a "barn" or proper shelter is for each horse or cow?

From the city’s point of view, the most important question we can ask them is how does the restrictions on the present rural community equate to a diverse experience that the City of Vancouver finds important? They need to recognize that there are urban areas and rural areas within the urban growth boundary and they need to have planning regulations that recognize both types of land use.

If you can’t attend or even if you do, a letter sent to Long Range Planning,
attn: John Manley, Senior Planner, 487-7948, would give them some idea of where we are on this issue and that we do find it very important and not as the staff report states: John Manley’s staff has determined (these changes)... Non-Significance (DNS).

This may not directly affect you and your property but I believe that it does affect the livablitly of our county and the horse community as a whole and is a meeting that everyone needs to attend.

It is especially important for those folks in the urban growth area to attend because it would be a very significant change. Check here to see if you in the UGB.

And be sure to wear something horsey so they know real well who we are. Dennis and I will be wearing our cowboy hats.

Remember:
Tuesday June 9th at 7:00 PM
Vancouver City Council Chambers

Meeting agenda

Equine Survey

Hopefully most of you have already filled out the Clark County Executive Horse Council Equine Survey but if not, this is your reminder.

It takes all of about 5 minutes and is very important. The last one is several years old and has been a valuable tool but it needs to be updated to reflect the current population.

The results of this survey will enable the horse community to go to the various county offices and agencies and show them what an enormous economic impact we have in the county - politicians and politics go with the most pressure or biggest number. The results will also show that all the horses are not out in Amboy or other outlying areas, they are all over the county.

This information is also used by the news media when deciding what to cover in their reporting, and what twist to put on the story. It has been used when dealing with horse shows, clinicians and vendors. And finally, the numbers can be used by retailers looking to locate stores or to get financing.

The survey asks about the number of horses you own, if you board or keep them at home and the average monthly upkeep. It also asks for the yearly related expenses and if you have purchased a truck and/or trailer from a county dealer in the past three years. The only identifying question is your zip code.

Now, the only way that this will be truly valuable is if ALL of us fill out the survey. I know that when the last survey was put out, there were folks that were reluctant to fill it out because they were afraid that in some form or another, the county would “know where I live and would tax me”. The people who are doing this survey are in the business of doing market research and they know how to make sure all the information is anonymous. All they want is an accurate as possible count of the horses in the county - this always blows the politians away - and the ENOURMOUS amounts of money that we spend on our horses - another real eye opener for the rest of the folks.

Just click on this link to take the survey.

Now Get ‘R Done and let's put some muscle behind our requests.

(those are our boys this morning while it was still sunny and we do live in the urban area - it just doesn't look like it)

New Signature Event

I'm on my soap box again.
I just read this in a small 'box' in The Columbian this morning:

What is Vancouver's New Signature Event?
Without Vancouver's annual fireworks extravaganza, what will be our signature event?
Tell what event you think is the highlight of Clark County's social calendar.
E-mail your response to signature-event@columbian.com.
Be sure to include your city of residence, age and phone number.

Ok, so I think the Vancouver Rodeo could fill that hole.

• It is already on the July 4th weekend and used to be part of the Vancouver 4th of July events (a few years ago).
• There is wide appeal and it is unique for this area. There are two other rodeos but they are not close and they are not as 'home town' as OUR rodeo.

Yes, I am on the Rodeo Committee and we have been talking about how we adjust our event to provide something more for the community in light of the absence of the fireworks display this year.

The other part that I saw when I read that piece was this designation would be a chance for the 'other' folks to see more of the horse community. I know this isn't about all the horse people in the area but it is horse related and would be a great chance for the rest of the folks to recognize that we (horse people) exist and are an economic force here. A lot of local people participate in the rodeo both as contestants and as volunteers. And if anyone wanted to see the economic impact of horses, all they would have to do is look at the infield at the Saddle Club during the rodeo and see all the trucks and trailers not to mention the horses and tack. Even if they do a write up about the ones that are mentioned, if a bunch of people sent in this idea, we could get some really good press for the rodeo and the horse community as a whole.

Storm Damage

I found this by way of the 5:00 news this evening that sent me to the blog at http://www.cresa911.blogspot.com/


Clark County Residents Need to Report Storm Damage
Homeowners, renters, and business owners in Clark County who sustained damage from the recent winter storms, flooding, and landslides should report their damage as soon as possible to Clark Regional Emergency Services Agency at (360) 992-9229.
Please call if you had damage to your primary residence or business - vacation homes and outbuildings are not eligible for disaster assistance - that occurred between December 11, 2008 and January 9, 2009 - that was caused by the winter weather, flooding, and landslides - that occurred in this period - that is not covered by insurance.
To report damage, please call (360) 992-9229 between 7 AM and 6 PM, Monday through Friday through Wednesday, January 21st or send an e-mail to cresaemergencymanagement@clark.wa.gov.
Check back on the blog at http://www.cresa911.blogspot.com/ for further updates on damage assessment efforts.

Currently, no disaster assistance is available to disaster victims in Washington State. Emergency management officials are in the process of collecting damage information from families, individuals, renters, business owners, non-profit agencies, and government agencies to determine if there is enough damage within Clark County for it to be eligible for disaster assistance. In order for local communities to become eligible for disaster assistance they have to demonstrate that they suffered damage that is beyond what the community can handle. This is why it is essential for people to report their damage. Reporting damage doesn’t guarantee that assistance will be provided but it does help make the case for receiving federal disaster assistance.

Here is another location with information - http://emd.wa.gov/documents/Dec_2008_ReportYourDamage.pdf

and this is the link to the story carried on KOIN news.

Public Imput Needed

I received this from the "Small Acreage Outreach Program" today. This is one of those issues that is important for all of us to weigh in on if we want to keep our horses in this county.

Clark County is one of eight counties in Western Washington currently working to develop a farmland preservation program in cooperation with the Washington State Conservation Commission.


After meeting through the spring and summer, a local advisory committee has drafted 24 strategies intended to protect opportunities to pursue commercial and non-commercial agriculture. These strategies are now available for public review and comment through November 17.


The public is encouraged to fill out The Farmland Preservation survey online.

More information will be available at a series of open houses, all from 6 to 8 p.m., as follows:


Wednesday, November 5 - 6 to 8 p.m, Camas Public Library, 625 NE Fourth Ave., Camas


Monday, November 10 - - 6 to 8 p.m, C.A.S.E.E., 11104 NE 149th St., Brush Prairie


Wednesday, November 12 - 6 to 8 p.m, Clark County Public Safety Complex, 505 NW 179th St., Ridgefield.


The county web site also contains more information.

You can see the draft farm preservation strategies here.

The committee will consider public comments before finalizing recommendations to the Board of Clark County Commissioners later this year. The project is modeled after similar efforts in King County, to address economic, social and political pressures that discourage farming in areas where population has been increasing and lifestyles are becoming more urban.


Comments may be sent to Clark County Agricultural Preservation Advisory Committee, Attn: Patrick Lee, Room 185, Public Service Center, P.O. Box 5000, Vancouver 98666-5000 or by e-mail to Patrick.Lee@clark.wa.gov.

Possible Tax Issue

I received this by way of the Back County Horseman of Washington and I thought that more people should have this information. It isn't exactly our issue yet but ........

Dear Horsey Friends,

Thank you for all of your support these last couple of months. As most of you know, King County has come down hard on all the farms in King County the last few months. After 30+ years, King County and the Washington State Department of Revenue changed their interpretation of the Open Space Taxation Act which is jeopardizing the existence of farms, especially horse farms, in King County (and all of Washington for that matter because it is the Washington State Department of Revenue that is requiring this different interpretation.) Therefore, I have to ask for another favor….please attend the public hearing on November 13th from 10-noon at: 1025 Union Avenue SE, Olympia, WA 98504, 4th Floor Executive Conference Room.

This is the meeting that really counts!!!!!

Please contact Marilou at the DOR to confirm your attendance. Her email is: MarilouR@DOR.WA.GOV. Please contact your horsey friends and especially other horse boarders and ask them to rsvp for this meeting. This is the meeting that will determine the viability of horse farms in King County and the State of Washington. This is the farm owner's and equestrian's opportunity to finally be heardJ

Also, if you are unable to attend this meeting, please email your written comments Marilou at MarilouR@DOR.WA.GOV.

Thank you,

Dana Kapela
dkapela@msn.com
206/930-2163

Please see letter below from the Department of Revenue…..:

STATE OF WASHINGTON
DEPARTMENT OF REVENUE
October 15, 2008
TO: Interested Parties
FROM: Brad Flaherty, Assistant Director
Property Tax Division
SUBJECT: STAKEHOLDER MEETING TO REVIEW OPEN SPACE TAXATION
ACT DEFINITION (WAC 458-30-200)
The Department of Revenue wants to acknowledge recent concerns and confusion about the
definition of "commercial agricultural purposes" as defined in WAC 458-30-200 and is
beginning a stakeholder process to consider changes to the rule.
Definition to be reviewed
The Legislature enacted chapter 84.34 RCW, the Open Space Taxation Act, in 1970, and the
Department adopted rules (chapter 458-30 WAC) to implement and administer this program in
1971. In 1988, the original rules were repealed and new rules adopted, including WAC 458-30-
200, which defines "commercial agricultural purposes," in pertinent part, as the:
(i) Raising, harvesting, and selling lawful crops;
(ii) Feeding, breeding, managing, and selling of livestock, poultry, fur-bearing
animals, or honey bees, or any products thereof;
(iii) Dairying or selling of dairy products;
(iv) Animal husbandry;
(v) Aquaculture;
(vi) Horticulture; or
(vii) Participating in a government-funded crop reduction or acreage set-aside
program.
Except for the inclusion of the cultivation of Christmas trees and certain short-rotation
hardwoods, the definition of "commercial agricultural purposes" has remained virtually
unchanged since at least 1988. It is time to give the definition a thorough review to make sure it
makes sense in light of current agricultural practices and other current use provisions.
Specific issues to be addressed
We are aware of two specific issues that need to be covered. Persons who purchase calves or
piglets in the Spring, raise them over the Summer, and sell them in the late Fall want this activity
to be included in the definition of "commercial agricultural purposes." The eligibility of horse
boarding also needs to be addressed. You may know of other issues we need to consider.
First stakeholder meeting scheduled
Our initial stakeholder meeting to consider possible rule changes will be held at 1025 Union
Avenue SE, Olympia, WA 98504, 4th Floor Executive Conference Room, on Thursday,
November 13, from 10:00 a.m. to noon. We invite you and others you may know who have an
All Interested Parties
October 15, 2008
Page 2
interest in clarifying this rule to join us in a discussion. Space is limited so please confirm your
attendance by responding to the e-mail address below. Based on the issues raised and interest
shown at this meeting, additional meetings may be planned, including meetings throughout the
state as appropriate.
Additional questions
If you have any additional questions or would like more information about the meeting, please
contact Marilou Rickert in the Department's Interpretations and Technical Advice Division at
(360) 570-6115 or by e-mail at MarilouR@DOR.WA.GOV.
BF:slc