A Guide to Initiative 933
Property Fairness Initiative
October 2006
A growing trend of “property fairness” initiatives has reached Washington state in the form of Initiative 933. The philosophy behind these initiatives draws on a long-established principle of environmental economics which says that those who benefit from an activity impacting the environment should also pay the costs. For instance a manufacturing plant must also absorb the costs of its activity, like paying to reduce the pollution they emit. Under Initiative 933, when the public benefits from an activity, for instance receiving the benefit of land kept in a natural state, the public must share the cost of that activity.
Initiative 933 has three key elements.
Our research indicates that Initiative 933 is likely to have a limited impact. The vast majority of claims are likely to come from small landowners, not developers. This has been the experience of Oregon, which is operating under a similar voter-approved property rights law, Measure 37. Additionally, Initiative 933 limits claims to regulations after January 1, 1996, narrowing the field of potential claims.
Opponents have made a variety of claims, focusing primarily on the potential cost of the initiative. They argue that the initiative could cost the state up to $8 billion and tens of millions more to administer. Our study demonstrates, however, that these estimates are based on faulty assumptions and are off by more than 10,000 percent in some cases. Opponents admitted that estimates are based on the false assumption that local jurisdictions could not waive rules in some cases.
We believe the best way for voters to decide is to focus on the philosophical choice. Voters who trust government planners are likely to vote against the initiative. Voters who believe a few small landowners should not bear a disproportionate burden of regulation and that the public should pay for public benefits are likely to vote yes.
Across the United States, there are a growing number of “property fairness” initiatives designed to increase protection for individual landowners from the rise in land use regulation. The most significant of these efforts to have success was Measure 37 which passed in Oregon in 2004 earning 61% of the vote statewide.
The philosophy behind these initiatives draws on a long-established principle of environmental economics which says that those who benefit from an activity impacting the environment should also pay the costs. The most common example is that of the factory smokestack that impacts air quality. The factory receives the benefit from the manufacturing that creates the smoke, but the community at large absorbs all the costs of that pollution. A standard response is to find a way to have the factory accept the costs of that “externality,” and either pay the community or reduce the emissions.
That same philosophy motivates “property fairness” initiatives. Public benefits derived from land use regulations should be paid for by the public rather than transferring the entire cost to individual landowners who happen to be in the wrong place. Those who benefit, in this instance the public at large, should also pay for the benefit they receive and offset the negative costs to others.
In order to uphold this principle, Washington’s Initiative 933 uses a system known as “pay or waive.” “Pay or waive” provides that jurisdictions must pay for the impact of new restrictions or waive those restrictions. Government would have to pay for the reduction in value due to the restrictions.
The ballot title outlines this philosophy:
This paper will take a section-by-section look at the wording of I-933 and examine some of the most common critiques of the initiative.
The first section of Initiative 933 outlines four basic findings that motivate the language of the initiative.
First, the initiative seeks to ensure “that government agencies do not damage the use or value of private property, except if necessary to prevent threats to human health and safety.”[2] It also outlines the need for government to prioritize voluntary actions over mandatory restrictions. The initiative encourages governments to look for voluntary programs that would achieve the same goal.
Second, it finds that “over the last decade governmental restrictions on the use of property have increased substantially, creating hardships for many, and destroying reasonable expectations of being able to make reasonable beneficial use of property.”[3] The initiative asks whether these restrictions are necessary to meet the public interest.
Third, it cites government’s power of eminent domain, noting that it should be limited and used only when necessary.
Finally, the intent section notes that I-933 is to “assist governmental agencies in undertaking such reviews and in proposing, planning, and implementing actions with due regard for the constitutional protections of property and to reduce the risk of inadvertent burdens on the public in creating liability for the government or undue burdens on private parties.”[4]
The intention section recognizes private property and the need for the government to examine the costs and benefits of government regulation before adding new restrictions on private property. To achieve these goals, Section 2 outlines a number of definitions and restrictions.
A key element of the initiative is the notion that without apparent cost, government has been too quick to add regulations to the detriment of private property owners. Section 2 is written, in part, to require jurisdictions to consider the cost of restrictions before they are passed. The section requires regulators to consider nine different areas of potential impacts and alternatives to regulation. The process would not bind the government to any particular decision based on the result of the analysis. Similar to the State Environmental Policy Act (SEPA), this simply requires that the government examine the potential impacts of a policy on private property and provide that information to the public.
To meet the standards of the initiative, jurisdictions must look at regulations to ensure that there is a “legitimate governmental purpose for the action”[5] and whether the action will actually achieve that goal. Governments must see whether the restrictions are proportionate in relation to the goal they are trying to achieve or, put more simply, whether the restrictions operate like a scalpel or like a sledgehammer.
The next two subsections require the government to assess the actual and philosophical, i.e. the benefit of private property rights, impacts of new restrictions on private property rights and the utility of private property. Subsections (e) and (f) require the government to examine how restrictions would harm private property owners economically and how a restriction “derogates or takes away a fundamental attribute of property ownership…”[6]
Subsection (h) further asks the government to determine the “estimated compensation that may need to be paid under this act.”[7] This anticipates Section 3 which actually would require the government to pay the cost of any diminished use of private property.
Finally, subsection (i) requires the government to examine and lay out “alternative means which are less restrictive,”[8] and asks that the government look at voluntary means to achieve the same goal.
As noted, there are already laws that require government to examine the potential impact of any action. In many instances government is required to undergo an environmental impact statement (EIS) or small business impact statement (SBIS) to provide information to regulators and the public about proposed actions. This initial portion of Section 2 lays out much the same type of analysis, this time emphasizing the range of potential impacts on private property. As noted above, these impacts are not limited to fiscal impacts, but also must consider the “enjoyment” and other more intangible values of private property.
The initiative does not require any course of action based on these assessments, but simply asks that information to be made public so that decision makers and members of the public can use the information to assess the proposal.
As with many laws, how terms are defined is often the most important part of how the law will ultimately affect society. Many of the key elements of Initiative 933 can be found in the definitions listed in subsection 2 of Section 2. The definitions of “private property,” “damaging the use or value” and “compensation” are all included in this subsection.
One of the areas of I-933 that has drawn particular attention is its definition of “private property.” The definition includes the “interest in the land”[9] as well as “mineral and water rights.”[10] These are not unusual, as they address the land and the rights to use that land associated with zoning and other permitted activities. However, the definition also includes, but is not limited to, “buildings, crops, livestock.”[11] Other equipment has also been mentioned in public, although they are not specifically called out in the initiative. The impact of this is twofold.
First, it is to address not only the value of the property itself, but also of the products of that land. For instance, if regulation determined that timber could not be harvested on a particular piece of land, the compensation would have to cover not only the diminished value of the land but also the lost value of the standing timber which the owner is not allowed to harvest.
Second, it is intended to close an anticipated avenue of alternative regulation that could be used to offset government’s ability to avoid paying the cost of restrictions. A jurisdiction could decide to allow a parcel to be used for grazing but prohibit cows from being on the property. Without the addition of “real and personal property,”[12] regulators could argue that they had not actually changed the rights associated with the land but simply altered the way those rights could be used, thereby avoiding compensation.
The definition of “damaging the use or value” is divided into two parts, one outlining what it includes, and the other describing what is excluded. The first portion is broken into essentially three parts: the timeframe, specified allowed maintenance activities and the range of other damaging activities.
The first subsection of the definition, subsection (i), sets the timeframe for the initiative, making it retroactive to “any use legally existing or permitted as of January 1, 1996.”[13] This timing is significant for at least two reasons.
First, the timing approximates the beginning of growth management activities in counties across Washington under the Growth Management Act (GMA) in Washington. As a result, some of the local plans undertaken to comply with GMA would be covered by I-933. Of note are the Critical Areas Ordinances (CAO) which have received so much attention across the state and especially in King and Thurston counties. The rule included in those ordinances would be subject to being waived or would require compensation to the property owners to keep these in place.
Despite those restrictions being impacted, this date does not change the many land use restrictions that were put in place before 1996 which includes the GMA itself, but not many of the local rules to implement that act. For instance, one issue that is raised is the ability to add billboards or other signs due to a waiver of the restrictions. In the case of Seattle, for example, these guidelines were passed in 1987 and updated in 1995 and would not be waivable under I-933.[14]
Second, this makes Initiative 933 different from its counterpart in Oregon, Measure 37, in one significant way. Measure 37 ties the ability to contest regulations back to the date the current owner bought the parcel. A landowner can ask to be reimbursed for or waive restrictions as far back as the owner or his family has maintained continuous ownership. I-933, however, ties the ability to ask for reimbursement or waiver to the property much in the way that rights or obligations are tied to a parcel, not ownership.[15] This means that an owner who purchased land tomorrow could make a claim under I-933 on all restrictions created since 1996.
By granting all property owners the right to contest regulations since 1996, I-933 is potentially more expansive in its reach than Measure 37 for the past decade. However, because I-933 caps claims going back a decade, it avoids circumstances which are common in Oregon where families who have owned a parcel for several decades can remove a significant amount of the limits on the use of their land. The likely impact of this limitation is that the cost and impact in Washington would be less per capita than in Oregon.
The definition also outlines several maintenance activities that will continue to be allowed under Initiative 933, including the “operation, maintenance, replacement, or repair of existing tidegates, bulkheads, revestments, or other infrastructure reasonably necessary for the protection or use or value of private property.”[16] This is extended to maintenance of “irrigation facilities”[17] and activities that are “necessary to prevent or mitigate harm from fire, flooding, erosion, or other natural disasters…”[18]
Finally, the definition includes regulations that would require property to be “left in its natural state or without beneficial use to its owner, unless necessary to prevent immediate harm to human health or safety.” (italics added)[19] The critical word in that second clause is “immediate.” This would seem to indicate that activities that may cause eventual harm to human health or safety will be allowed. There are a number of such examples that are excluded from this definition in the next part of the definition, but not all potential threats are excluded. The inclusion of the word “immediate” can be read two ways.
The apparent intention of the inclusion of this word was to prevent regulators from using an overly broad definition of “harm to human health or safety.” There is a wide range of activities that could be extrapolated to posing such a threat and, therefore, could be used to prevent activities while avoiding the compensation requirements of I-933. Again, the drafters of I-933 have tried to anticipate, and close, future loopholes that could be used to circumvent the intent of the initiative.
On the other side, such a narrow exemption could allow property owners to undertake activities despite longer term threats to health and human safety. Of course, if the threats were significant enough, the jurisdiction would have the option of paying compensation to keep the restrictions in place. Further, a number of potentially significant long term threats are specifically exempted in the next portion of the definition.
Subsection (c) specifically outlines those things which are exempted from the definition of “damaging the use or value.” Generally, rules that “apply equally to all property subject to the agency's jurisdiction” are exempted from the definition. The section also identifies a number of specific exemptions.
The first two listed relate to health, safety and natural disasters, specifically exempting “structural standards for buildings in building or fire codes to prevent harm from earthquakes, flooding, fire or other natural disasters.”[20] These threats need not be “immediate,” but can be long-term. A similar exemption has been used in Oregon by local governments to reject claims for compensation, in one instance even preventing the construction of low-income housing by Habitat for Humanity.[21]
Also exempted are claims relating to “the location or operation of sex offender housing or adult entertainment.”[22] Opponents have claimed that I-933 might actually remove laws restricting the location of sex offender housing. Given the clear nature of this clause, it would take an extremely creative reading of the initiative to make that argument. Furthermore, the location of sex offender housing is determined by governments not private citizens. It is unclear why I-933 would be used by governments against themselves or others to locate sex offender facilities.
The next restriction exempts “chemical use restrictions that have been adopted by the United States environmental protection agency.”[23] Other federal laws, however, are not specifically exempted. It does not appear that this clause would cover local rules put in place to implement updates to the Clean Air Act or other environmental regulations. Those regulations, however, are likely to fall under the requirement that claims apply only to rules that are applied differently across a jurisdiction.
The next section exempts “worker health and safety laws…”[24] This clause was added primarily as an outgrowth of an analysis that appeared when a similar initiative was first offered in the mid-1990s. An academic critic argued that that referendum might undermine such laws, despite the argument of supporters that this was a tortured reading of the initiative. In order to avoid this controversy this time, the drafters simply included this clause to make clear the intent.
There is also an exemption for rules governing the management of dairy farms, exempting claims related to “dairy nutrient management restrictions”[25] which provide restrictions aimed at protecting ground water, streams and the environment from effluent and other pollution related to cows. Ironically, opponents like the American Planning Association (APA), have still claimed in a report that I-933 could allow a farmer to “graze his cattle right down to the bank of the stream (or into the stream for that matter)”[26] even though this clause specifically prohibits that. The actual language cites the full legal code (RCW) title 90, titled “Water Rights – Environment,”[27] and reads in part that “The department of ecology shall develop and maintain a standard protocol for water quality monitoring of the waters of the state within the vicinity of dairies…”[28] The section is entirely dedicated to maintaining water quality around dairy farms. It appears that the APA’s author never actually read RCW 90.64 before making this claim.
Finally, the definition exempts rules that require “compliance with local ordinances establishing setbacks to property lines” that were put in place prior to January 1, 1996.[29]
Between the two portions of the definition of “damaging the use or value,” what is included and excluded, should serve to limit most, if not all, horror stories raised by opponents. As noted, the definition excludes many long and short-term threats to health and human safety, rules that are applied evenly across a jurisdiction, sex offender housing and many other potential exemptions. The breadth of these exemptions is one reason that the number of claims from Oregon’s similar measure has been smaller than expected and the nature of the claims is more limited than critics claimed.
The final definition outlines what kinds of “compensation” can be offered. The compensation required is the “fair market value” of the reduction in property value caused by the regulation or restriction. The definition makes clear that this applies both to lost market value of the property as a whole or the lost value from any portion that is required to remain “in its natural state without beneficial use by its owner.”[30] The clause also includes “any costs and attorneys’ fees reasonably incurred by the property owner in seeking to enforce this act.”[31] This clause is included in a number of environmental laws that allow the public to bring lawsuits to enforce laws.
Most of the attention related to Initiative 933 is focused on the provisions of Section 3 which contains the “pay or waive” clause. If a parcel of private property is damaged by a government restriction, Section 3 requires that the jurisdiction “shall first pay the property owner compensation…”[32] As noted above, compensation means the “fair market value” of the value lost due to the restriction. I-933 does not outline how “fair market value” would be established and this would have to be determined by the jurisdictions. No clear system of compensation has been developed in Oregon primarily because no jurisdiction has ever paid a claim.
It is likely that, as in Oregon, claimants in Washington would be required to provide an estimate of lost value. In Oregon the basis for these claims has varied from an estimate based on a neighbor’s recent sale to an actual market appraisal. Each county already has an estimated value of a parcel for tax purposes, so there is an existing basis to establish valuation. For instance, in King County officials describe the valuation process this way:
Real property valuations are made by our staff of accredited real estate appraisers. The total valuation represents 100% of fair market value. Market value is the amount of money a buyer, willing but not obligated to buy, would pay to a seller willing but not obligated to sell. For residential parcels, fair market value is determined by analyzing recent sales of comparable properties in the same area. Commercial properties also may be appraised using this method or by using the income or cost approach. The appraisal method used will be the one that offers the best evidence of market value.[33]
Such procedures would likely form the basis for determining the actual value of claims.
If the jurisdiction cannot afford to pay to maintain the restriction, it has the option of waiving the regulation in question. The section notes that a jurisdiction has the right to waive the restrictions and therefore would not be “liable for paying remuneration under this section.”[34] This is the most likely route for claims if I-933 is approved.
The opportunity to provide waivers offers flexibility to jurisdictions. In Oregon some counties have already looked at waiving some rules within a claim and paying to maintain others. This would further reduce potential costs while allowing local jurisdictions to prioritize the true cost and benefit of each restriction. This strategy has not yet been applied, but it is one example of the types of flexibility and creativity that jurisdictions can use to determine which rules are truly useful and which were implemented simply because there was no cost associated.
When multiple jurisdictions are involved, waivers would have to come from each of the jurisdictions who have created the restrictions. Thus, if a landowner was making a claim both for local zoning and state growth management rules, they would need to file multiple claims.
Two final sections deserve attention.
Initiative 933 prohibits jurisdictions from charging fees to file claims if that fee is designed to “avoid responsibility for paying compensation.”[35] This anticipates a circumstance where jurisdictions require payment of a fee from the landowner prior to paying a claim. Some have interpreted this to mean that jurisdictions cannot require fees at all. The plain language of the initiative, however, contradicts that view.
Finally, Section 5 is a grandfather clause, which allows legally existing actions to continue. One creative reading of this clause claims it will permit any previously allowed activity going back decades or hundreds of years. This is, however, another convoluted reading of the initiative. The section does not say “ever existing,” but allows currently “existing” activities to continue.
A number of criticisms have already been leveled at I-933. The primary concern is that the large number of claims would cost state and local governments billions. The Association of Washington Cities estimated that Washington cities would face a bill “between $3.5 and $4.5 billion, and an Administrative Costs estimate of between $60 and $76 million per year.”[36] The Office of Financial Management estimated the cost to the state to be $7 to $9 billion.[37] These estimates, however, are highly speculative and exaggerated. These decisions mirror some of the false claims made about Measure 37 in Oregon. They are wrong for a number of reasons.
First, these estimates assume that a large percentage of potential claims would actually be made. This is unlikely. In Oregon a very small portion of the potential claims were actually made, and virtually all of the claims were made by families.
Second, estimates that can be verified have turned out to be wide of the mark. In Oregon, opponents estimated that the cost to administer Measure 37 would be $344 million each year, a prediction that is repeated by I-933 opponents in Washington. The Association of Washington Cities’ estimate of $60-76 million each year echoes that effort. More than a year after Measure 37 took effect, the Portland Oregonian looked at this estimate and found that the actual cost to the state government was approximately $3 million.[38] When projections by opponents are off by a factor of more than 110, they are not useful when trying to make an informed decision.
One argument used to create the exorbitant projections is the argument that I-933 does not provide authority to local governments to waive state land use rules. As a result, local governments, they argue, would be unable to waive rules and would be forced to pay for claims made against it. This is simply incorrect. Local jurisdictions would not be liable for state rules and would only face claims about laws under their jurisdiction. Waivers might have to be approved by the Legislature, as opposed to an agency, but every jurisdiction would have the opportunity to waive rules.
At a press conference announcing the results of a study by the Northwest Center for Livable Communities, a research and public service center at the University of Washington, opponents admitted that the state does, in fact, have the ability to waive the rules. They claimed, however, that the Legislature would not have the political will to make the changes. This is contradicted by legislators themselves. Seattle Times reporter Eric Pryne reported that “Considering the alternative — potentially budget-busting compensation bills — legislators probably would accommodate them if Initiative 933 passes. Sen. Jim Kastama, D-Puyallup, and Rep. Geoff Simpson, D-Covington, who chair committees with jurisdiction over the Growth Management Act, agreed.”[39]
Second, as noted above, opponents argue that the exemptions are too narrowly defined, putting a number of environmental protections in jeopardy. They cite the Forests and Fish rules, the Clean Air Act and other rules. While they are not specifically exempted, implementation of these rules is likely to be exempted from I-933 claims because they apply equally to property subject to the agency’s jurisdiction.
For instance, the Forests and Fish laws are applied uniformly to all private land by the State Department of Natural Resources. Thus, it would appear that such laws are exempted from claims. This also makes sense when you consider the philosophy of I-933. The goal is that the public should share the cost of restrictions equally. If all landowners have to meet the same restrictions, the unfairness of uneven regulation disappears.
The decision about voting for or against I-933 really reduces down to a philosophical viewpoint rather than an effort to calculate the projected positive and negative impacts on the land or on local budgets.
If voters attempt to make a decision based on the projections and speculations offered by either side, they are likely to be misled. The projected impacts of Measure 37 in Oregon, which have been repeated in the current campaign in Washington, have proven to be very wide of the mark. Relying on these projections, which have proven to be off by more than a factor of 100, is little better than guessing. The speculation has even reached the point where some opponents predicted “total ecosystem collapse”[40] in the Puget Sound region when a bill similar to I-933 was before the legislature. Such hyperbole makes a rational understanding of impacts virtually impossible.
The analysis above, and experience in Oregon, shows that the impacts are likely to be much more moderate than some claim. In Oregon, the groups who argued against Measure 37, saying it would cause a sweeping change there are now arguing that the law is narrow and doesn’t apply to a wide range of claims.
As a result, the best way for voters to decide about I-933 is to judge the philosophies behind the initiative and those who support and oppose it. For those who believe that local government planners should have a relatively unencumbered hand in guiding the direction of development, even if that means a few landowners will bear the burden of restrictions, they are likely to vote against I-933.
Those who believe that restrictions that benefit the public should be paid for by the public at large, and that individual landowners should not bear the uneven burden of regulation are likely to vote yes.
[1] Washington Secretary of State, “Elections: Initiatives to the People,” http://www.secstate.wa.gov/elections/initiatives/people.aspx (Accessed 9/10/2006)
[2] Initiative 933, http://www.secstate.wa.gov/elections/initiatives/text/i933.pdf (Accessed 9/10/2006), p 1
[3] Initiative 933, http://www.secstate.wa.gov/elections/initiatives/text/i933.pdf (Accessed 9/10/2006), p 1-2
[4] Initiative 933, http://www.secstate.wa.gov/elections/initiatives/text/i933.pdf (Accessed 9/10/2006), p 2
[5] Ibid.
[6] Ibid.
[7] Ibid.
[8] Ibid.
[9] Initiative 933, http://www.secstate.wa.gov/elections/initiatives/text/i933.pdf (Accessed 9/10/2006), p 3
[10] Ibid.
[11] Ibid.
[12] Ibid.
[13] Ibid.
[14] City of Seattle, Seattle Municipal Code 23.60.180 “Sign standards,” http://clerk.ci.seattle.wa.us/~scripts/nph-brs.exe?s1=&s2=height+restriction&S3=&Sect4=AND&l=20&Sect1=IMAGE&Sect3=PLURON&Sect5=CODE1&d=CODE&p=1&u=%2F%7Epublic%2Fcode1.htm&r=11&Sect6=HITOFF&f=G (Accessed 9/10/2006)
[15] For instance, if a property carried a lien, the lien does not go away simply because the property is sold. It remains in effect.
[16] Ibid.
[17] Initiative 933, http://www.secstate.wa.gov/elections/initiatives/text/i933.pdf (Accessed 9/10/2006), p 4
[18] Ibid.
[19] Ibid.
[20] Ibid.
[21] “Resolution 2005-136 (M37 Denial) (M37-006-04),” Board of County Commissioners for Linn County, May 4, 2005.
[22] Initiative 933, http://www.secstate.wa.gov/elections/initiatives/text/i933.pdf (Accessed 9/10/2006), p 4
[23] Ibid.
[24] Ibid.
[25] Ibid.
[26] Washington Chapter of the American Planning Association, “Analysis of Proposed Initiative 933 & its Consequences for Washington,” http://www.washington-apa.org/pdf/Final_Draft_of_APA_I_933_Analysis.pdf (Accessed 9/12/2006) p. 6
[27] Registered Code of Washington, “Title 90 RCW: Water Rights,” http://apps.leg.wa.gov/rcw/default.aspx?Cite=90 (Accessed 9/12/2006)
[28] Registered Code of Washington, “RCW 90.64.180: Protocol for monitoring waters near dairies and CAFOs,” http://apps.leg.wa.gov/RCW/default.aspx?cite=90.64.180 (Accessed 9/12/2006)
[29] Initiative 933, http://www.secstate.wa.gov/elections/initiatives/text/i933.pdf (Accessed 9/10/2006), p 4
[30] Ibid.
[31] Ibid., p. 5
[32] Ibid.
[33] King County Department of Assessments, “Real Property Assessments Summary,” http://www.metrokc.gov/assessor/RealProperty.htm (Accessed 9/13/2006)
[34] Initiative 933, http://www.secstate.wa.gov/elections/initiatives/text/i933.pdf (Accessed 9/10/2006), p 5
[35] Ibid.
[36] Association of Washington Cities, “AWC I-933 Fiscal Impact Estimates,” 8/18/2006 http://www.awcnet.org/portal/studionew.asp?Mode=b1&WebID=1&UID=&MenuActionTypeID=80&MenuActionParm=127&OriginPage=/portal/studionew.asp&EDate=&ChannelLinkID=6576 (Accessed 9/13/2006)
[37] Washington State Office of Financial Management, “Potential Financial Impacts of I–933,” http://www.ofm.wa.gov/initiatives/933.asp (Accessed 9/28/2006)
[38] Laura Oppenheimer, “Land law gobbles planning staff,” Portland Oregonian, July 3, 2006
[39] Eric Pryne, “Initiative 933 could cost state billions, study says,” The Seattle Times, September 21, 2006, http://archives.seattletimes.nwsource.com/cgi-bin/texis.cgi/web/vortex/display?slug=proprights21m&date=20060921&query=I-933+OFM (Accessed 9/28/2006)
[40] Washington State Puget Sound Action Team Bill Review HB 3311, February 24, 2006, p. 2