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The city is in the process of adopting a comprehensive plan. There was a scheduled public comment period that closed. Is any additional public comment required?
Reviewed: 12/17

A second opportunity for public comment is not required in any of the statutes governing notice/comment/public participation associated with the adoption of comprehensive plan or development regulations. Below are the statutes that relate to the process by which a city adopts or amends a comprehensive plan and development regulation:

RCW 36.70A.035 sets forth the specific notice provisions for public participation for proposed amendments to comprehensive plans and development regulations, including area-wide rezones. However, it does not prescribe a specific type of notice but lists examples of reasonable notice provisions. Note that RCW 36.70A.035(2) provides:

(a) Except as otherwise provided in (b) of this subsection, if the legislative body for a county or city chooses to consider a change to an amendment to a comprehensive plan or development regulation, and the change is proposed after the opportunity for review and comment has passed under the county's or city's procedures, an opportunity for review and comment on the proposed change shall be provided before the local legislative body votes on the proposed change.
(b) An additional opportunity for public review and comment is not required under (a) of this subsection if:
(i) An environmental impact statement has been prepared under chapter 43.21C RCW for the pending resolution or ordinance and the proposed change is within the range of alternatives considered in the environmental impact statement;
(ii) The proposed change is within the scope of the alternatives available for public comment;
(iii) The proposed change only corrects typographical errors, corrects cross-references, makes address or name changes, or clarifies language of a proposed ordinance or resolution without changing its effect;
(iv) The proposed change is to a resolution or ordinance making a capital budget decision as provided in RCW 36.70A.120; or
(v) The proposed change is to a resolution or ordinance enacting a moratorium or interim control adopted under RCW 36.70A.390.

RCW 36.70A.130 describes requirements for amendment to the comprehensive plan, and limits action to once per year, with some exceptions.

RCW 36.70A.140 does not outline specific procedures that must be followed but states (in part) that:

The [public participation] procedures shall provide for broad dissemination of proposals and alternatives, opportunity for written comments, public meetings after effective notice, provision for open discussion, communication programs, information services, and consideration of and response to public comments. . . .

RCW 35A.63.070, RCW 35A.63.073 and RCW 35A.63.100 set forth the notice provisions for adopting comprehensive plans, proposed amendments to comprehensive plans, and development regulations, including area-wide rezones in code cities. RCW 35A.63.100 and RCW 35A.63.070 considered together state that any amendment to the zoning code requires at least one public hearing; if the amendment is a site-specific rezone, it is a "project permit" for which only one hearing may be held per RCW 36.70B.050. Prior to holding the public hearing, notice of the time and place of the hearing must be published in a "newspaper of general circulation in the municipality and in the official gazette, if any, of the municipality at least ten days prior to the date of the hearing."

The GMA did not repeal the notice requirements in RCW 35A.63.070 and RCW 35A.63.100 for code cities. Therefore, code cities must follow those requirements in addition to those imposed by the GMA.

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What process must a city use to enter into a solid waste collection contract?
Reviewed: 12/17

In general, solid waste collection is considered to be a service, and it is therefore exempt from public works bidding requirements. Many jurisdictions use an RFP process when seeking solid waste collection services. Here is a link to MRSC’s Solid Waste Collection page.

RCW 35.21.156 does set forth an RFP process for solid waste collection. However, it is important to remember that this procedure is not mandatory and that cities may use different procedures to contract for solid waste collection. This is an area where cities have considerable flexibility—there are no mandatory procedural requirements with respect to contracting for solid waste collection.

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Why can’t impact fees be used for maintenance?
Reviewed: 11/17

Impact fees may only be imposed for public capital facilities (also called “system improvements”) identified in a local government’s capital facilities plan that are designed to provide service to the community at large, are reasonably related to a new development, and will benefit that new development (see WAC 365-196-850). RCW 82.02.050(4) states in relevant part (emphasis added):

The impact fees:

(a) Shall only be imposed for system improvements that are reasonably related to the new development . . . .

In addition, RCW 82.02.050(5)(a) states in part (emphasis added):

Impact fees may be collected and spent only for the public facilities defined in RCW 82.02.090 which are addressed by a capital facilities plan element of a comprehensive land use plan adopted pursuant to the provisions of RCW 36.70A.070 or the provisions for comprehensive plan adoption contained in chapter 36.70, 35.63, or 35A.63 RCW.

RCW 82.02.090(9) defines “system improvements” to mean (emphasis added):

public facilities that are included in the capital facilities plan and are designed to provide service to service areas within the community at large, in contrast to project improvements.

RCW 82.02.090(7) then defines “public facilities” to mean:

the following capital facilities owned or operated by government entities: (a) Public streets and roads; (b) publicly owned parks, open space, and recreation facilities; (c) school facilities; and (d) fire protection facilities.

Nowhere in the above-quoted provisions is there any reference to operations or maintenance of public facilities. Rather, there is reference only to the public facilities themselves. If the Legislature intended impact fees to be usable for operations or maintenance of public facilities, it would have said so.

For more information, see MRSC’s Impact Fees topic page.

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How can we fix a scrivener’s error in the zoning code?
Reviewed: 11/17

The general principle is that in order to make a correction to the original ordinance itself, it takes a formal amendment to the ordinance by the council. There is no specific statute that allows for clerical or administrative correction of an obvious mistake in an ordinance in most circumstances.

There is an exception to this rule. RCW 35.21.500RCW 35.21.500(3) relates to the process of codification and it provides that the term “codification” includes editing ordinances, which specifically includes correcting manifest errors. So if you are preparing ordinances for codification purposes, then there is authorization to correct manifest errors in references to other ordinances, also spelling, clerical, or typographical errors. These types of errors can be corrected for purposes of codification without specific council action, but this authority is limited to that specific context. If the ordinance has already been codified, the advisable course of action is for the council to amend the ordinance through another ordinance.

Note that RCW 35A.21.010 indicates that deficiencies in the form of ordinance do not affect the validity of the ordinance. This includes inadvertent use of an incorrect or inaccurate proper term or name, such as a citation. But while this helps interpret the ordinance, it does not really provide authority for the agency to correct to the error administratively.

So, assuming you have to amend the ordinance, the normal process for adopting an ordinance should be followed. The following reasoning in Responsible Urban Growth v. Kent, 123 Wn.2d 376, 386-87 (1994), in which the state supreme court addressed the "correction" of zoning ordinances, would appear to be applicable here:

The relevant statutes, however, appear to require notice whether the Council's action is in the form of a correction, an amendment, or a rezone. Although neither RCW 35A.63- .070 nor KCC 15.09.050 specifically mentions "corrections" they do require notice for "amendments" to zoning ordinances. Neither do the statutes define "amendment". Where terms are not defined in a statute, the court will look to the plain, ordinary meaning of the words. American Legion Post 32 v. Walla Walla, 116 Wn.2d 1, 8, 802 P.2d 784 (1991). Webster's dictionary defines "amendment" as "a correction of errors, faults, etc." Webster's New World Dictionary of the American Language 47 (College ed. 1968). Black's Law Dictionary defines "amendment" in pleading and practice as "[t]he correction of an error committed in any process, pleading, or proceeding at law, or in equity. . . ." Black's Law Dictionary 74 (6th ed. 1990). Courts have defined the word "amendment" to mean "correction of fault or faults" or "to change by freeing from faults, to correct, to reform." United States v. Munday, 211 F. 536, 538 (W.D.Wash. 1914); Pacific Gamble Robinson Co. v. Pay'n Save Drugs, Inc., 2 Wn. App. 728, 730, 469 P.2d 571, review denied, 78 Wn.2d 995 (1970). It appears, therefore, that a correction is included within the meaning of amendment and therefore, requires the same notice as that required for a rezone or an amendment.

Under the reasoning in Responsible Urban Growth v. Kent, a correction to an ordinance, even for an obvious scrivener's error, requires amendment of the ordinance, which can be accomplished only by an amending ordinance enacted by the governing body.

One approach to avoid this problem in the future is to include a "scrivener’s error" section in the adopting ordinance, which authorizes staff to correct any typographical or scrivener’s error. See Section Three of this Mount Vernon ordinance as an example.

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Are salary increases or decreases approved by the city’s salary commission subject to referendum when the city has not adopted the powers of initiative or referendum?
Reviewed: 11/17

Yes, salary action by a salary commission is subject to referendum even if the city has not adopted the powers of initiative and referendum. RCW 35.21.015(6) provides, in part, as follows (emphasis added):

Salary increases and decreases shall be subject to referendum petition by the people of the town or city in the same manner as a city ordinance upon filing of such petition with the city clerk within thirty days after filing of the salary schedule. . . .

This mandatory requirement cannot be evaded where a code city has not adopted the powers of initiative and referendum. Although RCW 35.21.015 does not provide a specific referendum procedure, it does provide at subsection (7) that (emphasis added):

Referendum measures under this section shall be submitted to the voters of the city or town at the next following general or municipal election occurring thirty days or more after the petition is filed, and shall be otherwise governed by the provisions of the state Constitution, or city charter, or laws generally applicable to referendum measures.

The laws “generally applicable to referendum measures” for a code city could only be those that would apply (via RCW 35A.11.100) if the city had adopted the powers of initiative and referendum.

There are other provisions of state law that require referendums even for cities that have not retained referendum procedures. See, e.g., RCW 35.21.706 (referendum authorized on B&O tax ordinance); RCW 82.14.036 (referendum authorized on additional sales tax); and RCW 82.14.340 (referendum authorized on additional sales tax for criminal justice purposes).

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Must the oath of office of city, town, and county elective officials be filed with the county auditor?
Reviewed: 11/17

Yes, the oath of office of elective officials serving in code cities, second class cities, towns, and counties must be filed with the county auditor. See RCW 35A.12.080 (code cities), RCW 35.23.081 (second class cities), RCW 35.27.120 (towns), and RCW 36.16.060 (counties).

Please note that RCW 42.12.010 provides that failure to properly take an oath and file the oath is a cause for vacancy in office!

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What policies have jurisdictions adopted governing: data, public records (retention, disposition, and production), email, mobile devices, and social media?
Reviewed: 10/17

For sample policies governing: data, public records (retention, disposition, and production), email, mobile devices, and social media, please see the following MRSC topic pages:

  • Public Records Act (Includes information regarding public records retention/management and sample policies and procedures)
  • Internet, Email and Computer Usage Policies (Contains examples of local government policies that regulate the use of computing devices including desktop, mobile computing devices and smart phones, internet usage, and electronic communications by employees and elected officials)
  • Text Messaging Policies (Provides an overview of various approaches to text messaging policies for local government staff and elected officials including sample policies)
  • Social Media (Includes sample social media policies)

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Request for sample ordinances that prohibit smoking of any kind—including tobacco and e-cigarettes—in city parks.
Reviewed: 10/17

Here are several examples of total or partial bans on smoking in city parks. Some also specifically include e-cigarettes.

Bans

Partial Bans

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Does the OPMA apply to elected officials before they are sworn in?
Reviewed: 10/17

In Wood v. Battle Ground Sch. Dist., 107 Wn. App. 550 (2001), the Washington Court of Appeals reasoned that the OPMA does not apply to elected officials before they are sworn in:

Washington's OPMA is, at most, ambiguous as to its application to members-elect. Although the OPMA defines “action” broadly, nothing suggests that members-elect have the power to transact a governing body's official business before they are sworn in. Thus, they are not “members” of a governing body with authority to take “action.”

Therefore, under the Wood case, members-elect do not become members of a governing body for the purpose of the OPMA until they are sworn in.

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Does MRSC have any sample code provisions related to urban farms?
Reviewed: 10/17

Here are some sample code provisions from jurisdictions in Washington State:

In addition, the following information may be of interest:

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Can a group of area mayors host a “legislative forum” at a city-owned facility with several candidates for state offices to discuss their views on city issues?
Reviewed: 10/17

In general, use of city facilities in support of a political candidate is prohibited under RCW 42.17A.555. However, under RCW 42.17A.555(3), activities that are part of the normal and regular conduct of the office or agency are permissible.

Accordingly, it is permissible for the city to host in a city facility a “neutral forum” for candidates for elective office to speak and answer questions from the public. The Public Disclosure Commission (PDC) has taken the position that a public agency may, under RCW 42.17A.555, allow its meeting facilities to be used for a neutral forum with respect to a ballot measure or a campaign for elected office, with equal opportunity for both sides of the measure to present their views or for candidates to present themselves to the public. See the PDC’s Guidelines for Local Government Agencies in Election Campaigns (revised May 22, 2013). See also PDC Declaratory Order No. 13, “Use of City Facilities to Broadcast Candidate Forum”; and AGO 1979 No. 3 (“The facilities of a state college or university may be used for a candidates' forum to which candidates for elective office would be invited on a nondiscriminatory basis to appear on campus to present their views and respond to questions from the audience . . . .”).

According to the PDC’s Guidelines for Local Government Agencies in Election Campaigns, the following are permitted uses of public agency facilities:

  • Agency meeting facilities, including audio visual equipment, may be used by campaign committees for activities on the same terms and conditions available to other community groups, subject to the provisions of the agency’s policy.

  • Use of agency meeting facilities is permitted when the facility is merely a “neutral forum” where the activity is taking place, and the public agency in charge of the facility is not actively endorsing or supporting the activity that is occurring.

According to the PDC, here are the factors it considers when determining if the use of agency meeting facilities are the “normal and regular conduct” of the agency and therefore permissible:

  • Can community groups typically use agency facilities?
  • Are facilities made available to all groups on the same terms?
  • Has the agency adopted a policy regarding the distribution of campaign materials on agency property?
  • Is the meeting facility customarily made available on an equal access, nondiscriminatory basis for a variety of uses?

With these considerations in mind, to comply with RCW 42.17A.555, it will be important to invite all declared candidates for the particular state offices to the event. It will also be important to make sure all candidates who attend have an equal opportunity to participate.

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Can real estate excise tax (REET) funds be used for maintenance?
Reviewed: 09/17

Yes, RCW 82.46.015 expands upon the use of REET 1 tax funds to allow for maintenance of capital projects as defined by the REET 1 statute (RCW 82.46.010(6)(b)) subject to both limitation and reporting requirements defined within the statute.

The statute defines maintenance and does not include labor or material cost for routine operations.

The maximum allowed use of REET 1 for maintenance is the greater of $100,000 or 25% of available funds, but not to exceed $1 million per year and a written report that will demonstrate that you have or will have adequate funding from all sources to pay for all capital projects as identified in your capital facilities plan for the succeeding 2 years. Refer to RCW 82.46.015 (3) for complete reporting details.

RCW 82.46.037 expands upon the use of REET 2 tax funds to allow for maintenance of capital projects as defined by the REET 2 statute (RCW 82.46.035(5)) subject to both limitation and reporting requirements like those described above. The definition of maintenance has been defined within the statute and does not include labor or materials costs for routine operations.

The maximum allowed use of REET 2 for maintenance is the greater of $100,000 or 25% of available funds, but not to exceed $1 million per year and a written report prepared that demonstrates that you have or will have adequate funding from all sources to pay for all capital projects as identified in your capital facilities plan for the succeeding 2 years. Refer to RCW 82.46.037 (3) for complete reporting details.

Additionally, REET 2 funds may also be used for those capital projects that are defined in REET 1 (RCW 82.46.010(6)(b)) that are not also included in the REET 2 definition, and for a brief period of time (July 1, 2017 to June 30, 2019) REET 2 funds may be used for the acquisition, construction, improvement or rehabilitation of facilities to provide housing for the homeless. Both of these additional options are subject to the same limitation and reporting requirements as required when funds are used for “maintenance.”

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Does a city or county need a vote of the people in order to levy the second quarter percent of the real estate excise tax (REET 2)?
Reviewed: 09/17

It depends. If the city or county is required to plan under the Growth Management Act, then only an affirmative vote of the legislative body is needed to levy this tax. (Don’t forget to notify the county treasurer so that you will begin to receive the second quarter).

However, if the city is located in a county that has voluntarily chosen to fully plan under GMA, this tax may be levied only "if first authorized by a proposition approved by a majority of the voters." RCW 82.46.035(2).

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If an employee is called to active duty and will be gone for several months, must the local government employer continue to pay them and provide benefits while they are away?
Reviewed: 09/17

Under RCW 38.40.060, local government employees are entitled to paid military leave for up to 21 work days. Such military leave is in addition to any vacation or sick leave to which the employee would otherwise be entitled. During the period of military leave, the employee receives his or her normal pay.

Regarding benefits, 38 U.S.C. § 4317 provides that employees who leave their job to perform military service are entitled to continue their employer-based health insurance coverage for up to 24 months while on military leave.

In addition, the federal Uniformed Services Employment and Reemployment Rights Act (USERRA) states that a person who leaves a civilian job to enter active duty is entitled to return to his or her civilian job after discharge or release from active duty. However, there are five basic eligibility requirements under federal law:

  • The person must have been released from service under honorable conditions and must furnish proof of that release;
  • The person must have held a civilian job "other than temporary" at the time he or she entered active duty;
  • The employee must have left the civilian job for the purpose of going into active duty, and must have given notice to his or her employer to that effect;
  • The employee must apply in writing within 90 days of separation or release from training or service (lesser periods apply when the period of service is 180 days or less); and
  • The period of service must not exceed five years.

The reemployment rights are available whether the person is in combat, active duty for training, or inactive duty. For a full list of USERRA regulations issued from the U.S. Department of Labor, see 20 C.F.R. § 1002. For additional information, see MRSC’s Military Leave topic page.

Finally, local governments are free to provide additional leave or benefits for employees who have been called for active service in the military than would otherwise be required by state or federal law. So, be sure to consult your local policies as well.

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What cities and counties can levy the second quarter percent of the real estate excise tax (REET 2)?
Reviewed: 09/17

Any county or city that is required to fully  plan under the Growth Management Act (RCW 36.70A.040(1)) may impose the second quarter percent of the real estate excise tax.

Any county choosing to plan under the Growth Management Act (RCW 36.70A.040(2)) and the cities located in them have the ability to impose the second quarter percent if first approved by the majority of the voters of the taxing district. (RCW 82.46.035(2))

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What is the industry standard for determining gross site area vs. net site area for determining density?
Reviewed: 09/17

Most (but not all) regulations with which we are familiar use a net density calculation that subtracts such factors as on-site natural resources/critical areas and public rights-of-way. Here are some sample code provisions:

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May a city or county use real estate excise tax (REET) revenues to pay debt service on a councilmanic bond?
Reviewed: 09/17

Yes, as long as the project is one for which these revenues may be used. For example, revenues from the second quarter percent (REET 2) can only be spent on projects listed in RCW 82.46.035(5) -- street, water, sewer, and parks (excluding land acquisition) projects . Therefore, these revenues could not be used to pay debt service on a new city hall or county courthouse. Note that if the real estate excise tax receipts fall short of the amount needed to pay debt service, the general fund must make up the difference.

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Can the county use real estate excise tax (REET) money for a pathway?
Reviewed: 09/17

The REET 1 statute, RCW 82.46.010(6), includes the term "trail" in its definition of "capital project" for which REET 1 funds may be used, and so that should include a "pathway." The REET 2 statute, RCW 82.46.035(5), on the other hand, does not include the term "trail" - or "path" or "pathway" - in its definition of "capital project," though it does include "sidewalks." So, it's our opinion that REET 1 funds could be used to construct improvements along the pathway, but not REET 2 funds, unless the pathway here could be considered a sidewalk.

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Does a city council in a noncharter code city have the legal authority to impose term limits on city councilmembers and the mayor?
Reviewed: 09/17

The answer appears to be “yes.” AGO 1991 No. 22 addressed the imposition of term limits on local government elected officials and concluded, in part, that noncharter code cities may impose term limits for their elected officials.

In reaching its conclusion, the AG’s Office differentiated between two types of local governments: those with broad home rule authority, consisting of charter cities and counties and noncharter code cities; and those with no home rule authority, consisting of second-class cities, towns, and noncharter counties. The AG’s Office concluded that only those jurisdictions with broad home rule authority could impose term limits and that noncharter code cities could impose term limits by ordinance.

Here are some examples of noncharter code cities that have adopted term limits:

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Can the real estate excise tax (REET) be levied even though the city or county is not yet allowed to spend it?
Reviewed: 09/17

Yes. The tax can be levied and placed in a municipal or county improvements fund until the city or county completes the capital facilities element of its comprehensive plan.

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Can cities and counties use real estate excise tax (REET) funds for planning?
Reviewed: 09/17

Cities and counties cannot use these funds for planning in the sense of developing a capital facilities element or a capital improvements plan. However, MRSC has advised that cities and counties can use these funds for design costs, engineering costs, surveys, etc. for specific projects in their capital facilities element or capital improvements plan. REET 1 funds may only be used for REET 1 allowed projects and REET 2 funds can only be used for REET 2 allowed projects.

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Is a capital facility plan required before expending Growth Management Act real estate excise tax (REET) funds?
Reviewed: 09/17

Yes. A capital facilities plan is required before expending either the first quarter percent REET funds, authorized by RCW 82.46.010(2) or the second quarter percent REET funds authorized by RCW 82.46.035.  Note that the rate at which it can be levied and the uses to which it may be put differs by city or county size and whether the city or county is planning under the Growth Management Act (GMA). More detailed information is available on our Real Estate Excise Tax webpage. 

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Does MRSC have a summary of the new PRA legislation?
Reviewed: 09/17

HB 1594 and HB 1595 contained the high-profile PRA legislation this session. MRSC has published three blog posts outlining the key provisions in these two bills:

In addition to MRSC’s resources, AWC has prepared a number of great materials related to these changes to the PRA that you may find useful.

Finally, here are the final house bill reports for both HB 1594 and HB 1595, which contain a concise summary of the changes made to the PRA:

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Is a city or county exempt from the real estate excise tax (REET) when purchasing real property?
Reviewed: 09/17

No. The sale of city or county real property is exempt from the real estate excise tax because such a sale is not included within the definition of "sale "for real estate excise tax purposes. However, in 1993 the legislature eliminated the same exemption for purchases of real property by a city, county, or other governmental entity. Thus, purchases of real property by a city or county (other than those by condemnation) are subject to the tax.

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How and when can a city or county that is planning under the Growth Management Act and that has a population of 5,000 or less spend its real estate excise tax (REET) revenues?
Reviewed: 09/17

The receipts from the first quarter percent (REET 1) can be spent on "any capital purpose identified in a capital improvements plan and local capital improvements, including those listed in RCW 35.43.040" (RCW 82.46.010(2)). RCW 35.43.040 lists projects for which local improvement districts (LIDs) may be formed and includes everything from street projects to parks to sewers to swimming pools. For a complete list, consult the statute.

Additionally, RCW 82.46.015 expands upon the use of REET 1 tax funds to allow for maintenance of capital projects as defined by the REET 1 statute (RCW 82.46.010(6)(b)) subject to both limitation and reporting requirements defined within the statute. The definition of maintenance has been defined within the statute and does not include labor or materials costs for routine operations. The maximum allowed use of REET 1 for maintenance is the greater of $100,000 or 25% of available funds, but not to exceed $1 million per year and a written report prepared that will demonstrating that you have or will have adequate funding from all sources to pay for all capital projects as identified in your capital facilities plan for the succeeding 2 years. Refer to RCW 82.46.015(3) for complete reporting details.

The second quarter percent (REET 2) cannot be spent until the city or county has completed the capital facilities element of its comprehensive plan. This part of the tax has more limited uses. It can only be spent on street projects, water and sewer projects, and parks projects (excluding the acquisition of land). RCW 82.46.035(5).

Like REET 1, REET 2 use has been expanded under RCW 82.46.037 to allow for maintenance of capital projects as defined by the REET 2 statute (RCW 82.46.035(5)) subject to both limitation and reporting requirements like those described above. The definition of maintenance has been defined within the statute and does not include labor or materials costs for routine operations. The maximum allowed use of REET 2 for maintenance is the greater of $100,000 or 25% of available funds, but not to exceed $1 million per year and a written report prepared that demonstrates that you have or will have adequate funding from all sources to pay for all capital projects as identified in your capital facilities plan for the succeeding 2 years. Refer to RCW 82.46.037 (3) for complete reporting details.

Additionally, REET 2 funds may also be used for those capital projects that are defined in REET 1 (RCW 82.46.010(6)(b)) that are not also included in the REET 2 definition, and for a brief period of time (July 1, 2017 to June 30, 2019) for the acquisition, construction, improvement or rehabilitation of facilities to provide housing for the homeless. Both of these additional options are subject to the same limitation and reporting requirements as required when funds are used for “maintenance.”

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