350 Court Street No. 1 District 2, Rick Hughes Friday Harbor, WA 93250 District 3, Jamie Stephens (360) 378 - 2898 MEMORANDUM Date: June 25, 2015 From: Jamie Stephens and Rick Hughes, San Juan County Council Members To: County Council, Randall Gaylord, Prosecuting Attorney Subject: Investigation, Analysis and Conclusions regarding January 21, 2015 Improper Government Action Report Dear Council Members and Prosecuting Attorney Gaylord: On January 21?, Prosecutor Gaylord was presented with an Improper Government Action Report (IGA) pursuant to Resolution No. 113-1992 (actually 113-1993), the County?s Whistleblower Policy. Although the San Juan County Whistleblower Policy outlines a different process for such complaints, PA Gaylord chose to be the recipient and the investigator on the validity of the IGA. The Council has retained the authority as the Administrative branch of the County to evaluate PA Gaylord?s assessment and to make ?irther assessment if warranted. On February 12, 2015, PA Gaylord submitted a draft memorandum of his findings, followed by a ?nal memorandum on March 11, 2015 . Mr. Gaylord has characterized, in his report, the issue of the IGA as of an informal and low-level nature. The County Council believes that the review of the IGA was cursory and warranted ?irther investigation. The Council has therefore reviewed the IGA report, and the materials related to the report independently, and have incorporated its ?ndings into this final determination regarding the January 21St IGA, as per the authority of the San Juan County Charter and Resolution 113-1993. The January 21, 2015 IGA concerns the assessment of Parcel TPN353450009, known as 310 Treeline Drive, under the County?s new Critical Areas Ordinance. The parcel bordering 310 Treeline Drive, TPN3534500053000 has a man-made pond on it, constructed in the 1960?s as a farm pond. The actions of concern in the IGA relate to the assessment of whether the pond was constructed in what was once a wetland, making it a wetland by default, what classi?cation Page 1 01?29 would such a wetland have, and what habitat and water quality buffer zones might then apply to adjacent parcels, based on this classification. 3 Although the building permit was issued in September, 2014, an anonymous Environmental Tracking Report System (ERTS) noti?cation was received by the County and by the Department of Ecology on January 20, 2015, complaining that wetlands were being damaged by construction at 310 Treeline Drive. The following day, January 21, 2015, a County employee ?led an IGA report, claiming that a County official had exceeded his authority in assessing the wetland and recommending speci?c action to the staff of the Department of Community Development (DCD). The writer of the IGA claimed that the County of?cial improperly ?overruled? the prior determinations of the DCD staff. The writer also erroneously claimed that the County of?cial based his reconnaissance on his wife?s professional assessment of the property, therefore implying there was a con?ict of interest. The County of?cial lived in the Treeline neighborhood, and, on an evening walk with his spouse and their dogs, walked the parcel boundaries. The of?cial?s wife being in the vicinity does not mean her professional opinion was sought, expressed or implied. Attached to this summary are the following items: 1. A chronology of events related to the application for a permit to construct a single family residence at 310 Treeline Drive, describing the several and varied investigations that occurred. 2. The specific sections of the San Juan County Code related to Critical Areas, speci?cally to wetlands and to wetland delineations. In the recently published code updates, this information will be found in the following Code Sections: 18.35.095: Wetlands Minimum size thresholds for regulated wetlands 18.35 . 1 DOA-1: Wetlands Protection standards Table 1 8.3 5.100-1 Water Quality Buffers Table 18.35.100?3: Habitat Buffer 18.35.105: Wetlands Determination of wetland boundary and requirements for wetland reports. $999.3?? 3. Statement from Planner 11, Annie Matsumoto-Grah 4. E?mail from Director Sam Gibboney to Annie Matsumoto-Grah, 9/9/14 5. Resolution No. 113?1992 (1993), San Juan County Whistleblower Policy Legai Delegation of the Authority of the County Council in the County Manager In the course of their work, Council members are frequently approached by citizens with speci?c concerns or issues connected to their interactions with County staff. In many instances, the Council members delegate the resolution of the concern to the County Manager. He has often intervened within the processes of the departments under his supervision to resolve a citizen issue, at times in con?ict with the personal or professional opinions of his staff; with the goal of streamlining a process, resolving a long term iSSue, re?ecting the wishes of the Council, or with the larger goal of improving the perception of County government within the community. it is Page 2 of 29 not unusual, nor is it illegal for him to do so. It is an expectation of the citizens that their elected of?cials, and those agents of the elected of?cials, will take their concerns seriously and address them. The County Charter allows for this delegation: 1. Article 2, section 2.3 1( 1) of the San Juan County Home Rule Charter reads: Executive Powers and Duties . (1) The executive powers of the County as granted by the State Constitution and law, and not otherwise reserved or granted by the Constitution, state law or this Charter to other independently elected county o?icials, are vested in the County council. The enumeration of particular executive powers herein shall not be construed as limiting the executive powers of the County Council. (2) The County Council shall exercise its executive power by adoption an enactment of ordinances or resolutions. It shall have the power to: a) To delegate its executive duties to subordinate o?icers appointed for that Assign duties to administrative ojj?ices, which are not speci?cally assigned by this Charter or by ordinance. - 2. Resolution 10-2013: A Resolution De?ning the County Manager?s Authority and Responsibility as Determined by the County Council and San Juan County Charter. Section 1 the Council wishes that the County Manager shall serve as the Council?s chief appointed management o?icial. Section 6: Administrative Procedures and Process. Pursuant to County policy direction by Ordinance or Resolution, the County Manager will be responsible for establishing internal operating procedures to carry out Council policy, while continuously seeking ways to streamline processes and improve customer service. As the ?Administrator? under the following County code,: Section 18.10.4130: Code interpretations and administrative determinations, Director Gibboney has the authority to ?review and resolve any questions involving the proper interpretation or application of the provisions of this code?. Ms. Gibboney, who had already reviewed Ms. Grah?s initial decision, concurred with the County Manager?s assessment, and gave her approval for a permit to be issued. San Juan County Code reiated to Critieai Areas In reviewing whether there was an inaccurate assessment by the County Manager, as the IGA claimed, we researched the following four questions: (1) When would a site reconnaissance be suf?cient to determine the width of required buffers? Section 18.35.1415: Wetlands Determination of wetland boundary and requirements for wetland reports (D): states that ?The necessary scope of wetland delineations and reports ranges ?om a wetland reconnaissance that simply confirms the presence or absence of a wetland, determines the wetland type, rating, and approximate size, and identifies the edge of the wetland in a limited area, to a delineation of the entire wetland with a detailed Page 3 of 29 report describing its functions and values. Section 18.35.100 Wetlands Protection standards, states that ?Required bu?ers apply regardless of whether the wetland is on the same parcel or another parcel that may be under di??erent ownership.? Using the Wetlands Rating Category, the pond was a Category IV. Step 1. Location Relative to a Wetlands states: ?In many cases, this can be based on a wetland reconnaissance rather than a fall delineation. (2) Was there a wetland on the Hughes Parcel? Prior to the IGA being ?led, no less than ?ve professionals had reviewed the site and made the determination that the Hughes property did not contain a regulated wetland: The septic system designer a The County planner, Chris Laws, who reviewed the septic permit application in 2011 and approved it The consulting engineer who wrote the stormwater plans a The County planner, Annie Matsumoto-Grah, who did initial reconnaissance using maps and the regulations a The County Manager Mike Thomas (3) Was the Hughes parcel outside the buffer zones required by the Category IV wetland on the neighboring parcel? The neighboring property did contain a Category TV wetland, but the Hughes building site was clearly outside the designated zones for both Water Quality Buffers and Habitat Buffers. Per Table 18.35.1004 Water Quality Buffers, a 40 foot water quality buffer would apply to the pond neighboring the Hughes parcel. Per Table 18.35.100-3 Habitat Buffer, a 40 foot habitat buffer would apply. - (4) Does the code specify what kind of written record of site reconnaissance is suf?cient? Director Gibboney, acting in her authority as the Director, sent an email to the Planner, saying that no further reconnaissance was needed. Although we would prefer a more descriptive email be the department?s standard, Ms. Gibboney did provide a record for the ?le of her determination, based on the County Manager?s reconnaissance. Process Concerns On January 21, 2015, an employee of the County (whom we will reference as RE for Reporting Employee, in order to protect his identity per Resolution No. 113-93), submitted a report on alleged improper government action (IGA) to Randy Gaylord, the County's Prosecuting Attorney. The Prosecuting Attorney informed the County Council on the general nature of the report and let them know he would be handling the investigation. The Council reviewed the County's Whistleblower policy (Resolution No. 113?1993), and noted that the proper process outlined in the policy is for the employee to ?rst raise the issue with their supervisor. Our investigation notes that RE did not do so; he Spoke with his supervisor about his intention to ?le the report, did not give her a copy of the report, and told her not to interfere with his investigation. He then refused to give her a copy of the report. The Council also noted that the next reporting agency, should the employee not feel they can raise the issue with the supervisor, is to present the employee's concerns to the County Risk Manager, and that this was not done. Page 4 of 29 The Prosecuting Attorney contended that he was also able to be a recipient of the IGA report and determined that his of?ce would be the investigatory agency. In another recent IGA case, the alleged action was properly reported to the Risk Manager, who met with the County Council to advise them of the allegations, and to inform the Council of the two actions that would be taken to address these allegations: l) forwarding the IGA report to the appropriate State Agency for an independent assessment of potential violations; and 2) engaging the services of an independent investigator to review the claim. The Council will revise the Whistleblower policy to clarify the reporting channels, and to ensure that an adequate and impartial investigation is undertaken for such claims in the ?lture. In addition, the Council supports having County Planners able to make reconnaissance reviews and simplifying the wetlands determination process when warranted. Although citizen concerns will be taken seriously, in this instance, the complaint caused the Planner to second-guess her initial determination and the determination of her supervisor. Although in this instance, the County was providing the wetlands review at no cost to citizens and paying for it ?om funds set aside in the CAO implementation plan, Mr. Thomas saved the County an unnecessary expense by his review, and Ms. Gibboney by her determination. The Councils supports additional training to ensure the staff planners have the skills and con?dence to make these determinations and to prevent citizens from unnecessary wetlands reviews and determinations. Summa? The County did its reconnaissance for possible wetlands issues properly. The preperty was ?rst reviewed for its septic system application, and the application was approved by the County. It was then reviewed on site by a stormwater engineer at a well-reputed engineering consulting ?rm, was reviewed on?site by two seasoned County planners, and reviewed by the County Manager, whose long career had included years as the head of municipal planning departments, where such concerns were regularly dealt with. In addition, the Department of Ecology expert, Doug Gresham, in his delineation of the neighboring pond/wetland following the ?ling of the IGA, found the construction of the Hughes residence was outside of the both the habitat and water quality buffer required by the neighboring pond/wetlands. Five separate reviews came to the same conclusion. our of these reviews took place prior to the ?ling of the Improper Government Action Report. Regarding code enforcementactivities, it is important to take citizen concerns and complaints seriously, and to investigate carefully, as Ms. Grah has done. There is no evidence, on the other hand, that RE did a proper and full investigation of the ERTS prior to ?ling the IGA. After a cursory review of the Hughes ?le, in which no notice of the Stormwater report was made and no review of the septic application was made, after a review of notes in the permit tracking system, and a conversation with co-worker Annie Matsumoto-Grah, RE decided to write the Improper Government Action report prior to doing further research. He did not visit the Hughes property, and did not interview the Hughes, any representatives of the Portland Fair Estates Owners Association, his supervisor Sam Gibboney, or County Manager Thomas before making his claim of improper government action. He made the assumption that the pond was a critical wetlands Page 5 of 29 area, without investigating whether it was, in fact, manmade in origin and a Class IV wetland with a smaller buffer requirement; this investigation in the company of the wetland representative from the Department of Ecology, Doug Gresham, occurred after the IGA was ?led with the Prosecuting Attorney. RE did not talk to his supervisor or the Risk Manager, as outlined in the County's Whistleblower policy, before making his claims. The County has now spent signi?cant time and resources to con?rm/arrive at the same conclusion Ms. Grah made in her initial analysis, and to determine that there was no improper government action on the part of County Manager Thomas. Approved by the County Council on June 25, 2015'; COUNTY COUNCIL SAN JUAN COUNTY, WASHINGTON Recused Jamie Stephey?ce Chair Rick Hughes, Member Bob arman, Chair District No. 3 District NO. 2 District No_ 1 Page 6 of 29 ATTACHMENT 1: Chronology of Events: June 13 2011 Septic Permit for TPN3 53450009 (319 Treeline) approved by Chris Laws in the Community Development Planning Department, and by Gary Covington in the Health and Community Services Department. Februgy 25, 2014 On behalf of the property owners Chris and Jenise Hughes, Sam Buck Jr., Realtor with Coldwell Banker, forwarded the initial house plans for'310 Treeline Drive to the Board Members of the Portland Fair Estates Owners Association. In March, 2014, Bob Jarman, as President of the Association, con?rmed that the Hughes site and house plans had been reviewed and approved, as is required by the Association's bylaws. June 13 2014 The Hughes submitted a permit application package for a residential permit to DCD. June 16 201.4 Construction plans for Hughes house, including drawings, engineering calculations, building site plan, Stormwater Plan and Construction were received by DCD. The Stormwater Site Plan Report, prepared by Land Technologies, Inc, notes the following: 2.1.3 Vegetative Cover. The property consists almost entirely of pasture and forest. 2.1.4. Topography. The pre-developed existing topography both onsite and o?fsite was evaluated using generated surfaces. The average slope as indicated by the models 1 7.24% throughout the site. The site topography is generally steep per drainage standards and there are some moderate slopes encountered within the parcel area. 2.1.5 Critical Areas. There are no known critical areas or bu?ers near the site. A manmade pond is located directly south of the site and is hydrological distinct upstream and of the site. Another manmade pond resides to the west of the site but a ridge separates the site and pond ?om sources. 2.1.6 Soils. The NRCS Soils mappings for the site consist mainly of Roche?Killebrew complex-Rock Outcrop Complex, 5 to 35 percent slopes and Coveland loam 0 to 5 slopes. 7 July 19, 2014 Hughes building permit application is routed to Annie Matsumoto-Grah for landuse/critical area review. In a written statement (January 26, 2015) later prepared at Mr. Law's request, Ms. Grah notes that: "critical areas maps depicted a pond/wetland area located on the property directly Page '7 of 29 west of the Hughes property. In addition (sic) to the wetland critical maps showed an "un-typed stream "/drainage are running ?om the pond/wetland to the south east". Ms. Grah notes that she consulted with senior staff as to whether a wetland report should be required. She concluded that the 'pond/wetland would most likely be rated as a Category or IV and wetland and that the house site would be beyond the required water quality/habitat bu??ers", and that "no letter was sent to the applicant requesting additional wetland information Following this determination, Ms. Grah received a phone call ?om Sheryl Albritton, who owned property adjacent to the Hughes parcel. According to Ms. Grah's statement, Ms. Albritton "expressed concern that any development on the Hughes parcel would greatly impact the wetlands to the west?, that Ms. Albritton "walked extensively around the pond/wetland area and the Hughes property and that the pond/wetland area was much larger than what it appeared to be on the county wetland maps. Ms. Grah told Ms. Albritton that she would further investigate. Around August 25 - 27. 2014 Ms. Grah and co-worker Nadine Cook made a site visit to the Hughes property and the neighboring pond. Ms. Grah observed wetland vegetation around the pond. She wrote in her statement that there was too much vegetation to identify the wetland boundary, and therefore wanted an expert to do so. She had previously determined that the site, being upland and east of the pond, would have no effect on the wetland, but, in light of Ms. Albritton's comments, wanted to be careful. August 27, 2015 Ms Grah writes in her statement that she sent a letter to the Hughes' contractor, Travis Stanton, requesting that a wetland assessment be done prior to approval of the building permit. She explained in the letter that the County wetland assistance program would provide the ?ee assessment from a wetland consultant. September 4. 2014 Hughes contractor, Travis Stanton, sent Annie Matsumoto-Grah an email, stating that he had faxed a "Wetland Review Request", signed by the Hughes. In the e-mail, Mr. Stanton asked if he needed to meet her on site, and if she could call him for a "run down on this process." Ms. Grah wrote that the Request was not documented or may have been discarded by other staff. It is not in the ?le. Around September 4-7, 2014. Mike Thomas recalls ?rst hearing about the Hughes property during one of his weekly meetings with Director Sam Gibboney, in the context of Ms. Grah's work. Their discussion, as both Sam and Mike recall, centered around the need to somehow give the planning staff more training, or more review and participation in reviews by wetlands experts so they would develop more confidence in their own judgment to make these calls: when is something a critical area, or a wetland; what should the buffer be, etc. Because of extreme levels of questioning by citizens of County land use decisions, the staff was now uncomfortable making such calls. Page 8 of 29 Mike Thomas stated, when interviewed for this report, that Bob arman had asked him to assess whether Mr. Hughes property was encumbered by a wetland. Mike said that he and his wife took their dogs for a walk the evening following Mr. Jarman?s request. The Thomas's were renting a home in the Portland Fair neighborhood, and the Hughes property was five lots east of the rental. He walked the PF EOA community pond area and the perimeter of the Hughes property. He determined that the property was primarily forested slope, with no evidence of the criteria required for the Hughes property to be designated as wetlands. He determined that the building site did not drain to the wetlands, but instead to the east. He determined that the property would be outside of any buffer required by the County's ordinances. He confirmed his assessment by reviewing the County's Polaris map of the site. County Manager Thomas's career has included signi?cant experience as a planner and as the head of planning departments in several municipalities, including Aberdeen, Federal Way, Burien and Eumenclaw. His experience included work on land issues such as those that arise in San Juan County. Mr. Thomas states that he spoke with Sam Gibboney about his visit to the Hughes site, and gave his opinion that he saw no need for a wetlands review. September 7. 2014 Following her conversation with Mr. Thomas, Ms. Gibboney then emailed Ms. Grah that no review would be necessary. She referenced a "local wetlands expert" in her email. Mrs. Thomas is a state?certi?ed wetlands expert, but she did not make a professional determination about the Hughes site, nor did her husband ask her to do so. This was an incorrect statement on the part of Ms. Gibboney's. September 10. 2014 Ms. Albritton sent an email to Ms. Grah: "It is my understanding we will not be required to provide a wetland rating/critical areas assessment for Portland fair for our future permit. I would like to review the data which was provided to show our wetlands are non-wetlands, since this is part of what] do I am curious. The water really runs through here most of the year except the driest months and there are connections with other wetlands, streams, etc. This is not an isolated pond simply because someone chose to damn it. the seeps are not currently ?owing but they will be as soon as the rain hits. September 11, 2014 Ms. Grah sent an email to Ms. Gibboney, asking if a written determination had been made, following the 9/10/15 email request from Ms. Albritton. Ms. Grah did not receive any further written documentation ?om Ms. Gibboney. September 12, 2014 Ms. Grah noted ?le with to issue permit September 17, 2014 Page 9 of 29 DCD issued building permit for Hughes construction at 310 Treeline Drive. January 20. 2015/ January 21. 2015 RE received an Environmental Tracking Report System (ERTS) noti?cation ?'om Linsay Albin at the Department of Ecology, incident number 654194. Email shows the ERTS was sent on January 21, 2015. It may be that this was a revision of original ERTS incent sent the prior day. The incident referenced in the ERTS allegedly took place on 11/1/2014 Activity listed as "other construction". ERTS statement: he PRP was undergoing a permit process. The county asked homeowner to get a WS to review. Property owner and their builder approached neighbors (county managers) which resulted in going over staff?s head and waiving critical areas review/evaluation of any kind. There is nothing in the ?le to support the stream no longer being considered a stream or wetland It is believed the previous owner was allowed to ?ll channel to get the property to perk. New owner took it a step further getting county to waive requirements. Driveway has been expanded in channel and there has been clearing in the buffer zone. Homeowner could do more damage given they think it is not mapped. County?s maps do not adequately show critical areas which are headwater wetlands and streams heavily altered during farming, plat construction. Aerial photos show the lot was ?lled and additional driveway placed in 2005 Stream shows on old Soil Manual maps, DNR FPARS. County maps are erroneous and do not show connectivity between old streams and wetlands. Contractor and owner are responsible, Travis Stanton Contour Construction. investigation, per his written notes, consisted of the following: 1. RE read the permit ?le for 2. RE looked at Eden permit routing history and read notation ?orn Lisa Brown about status of Hughes permit on 9/11/2014, who spoke with Ms. Grah after a call ?om Michael Grif?n on permit status. Ms. Brown's comments note a neighbor complaint. Eden ?le has notation ?om Ms. Grah regarding email from her supervisor (Sam Gibboney) that ?property "not a wetland per Mike Thomas and wetland specialist Land use approved. 3. RE interviewed Ms. Grah, and con?rmed that Ms. Grah had approved permit based on instructions ?om her supervisor. According to Ms. Grah, RE directed her to not speak to anyone else about their conversation or the case, and speci?cally cited Ms. Gibboney. 4. RE read the County's whistleblower policy. 5. Instead of approaching his supervisor or Risk Manager, as directed by the policy, RE went to Amy Vira in the Prosecuting Attorney's of?ce to discuss the ERTS, his review of the Eden ?le, and interview with Ms. Grah. 6. Ms Vira advised him to contact his supervisor per the whistleblower policy to initiate the investigation. 7. RE Forwarded the ERTS by email to Director Gibboney, with a note that that discussion was needed. Page 10 of 29 Janu? 21, 2015 RE met with Director Gibboney on January 21, 2015. In his written notes, RE notes that he told her that he had determined that Mr. Thomas's actions were "unprecedented, that it was outside his job duties to conduct field investigations to validate land-use planner decisions, that his actions were unethical, and validated the concerns that many citizens in the county have that the County has a double-standard and engages in improper if not corrupt activities - these charges are levelled often at (now DCD). RE also identi?ed what personnel rules he felt Mr. Thomas had violated. He continued: made it clear to Ms. Gibboney that I would fully investigate the ERT and that (sic) and would not tolerate an interference in doing so and that any such interference would be a violation of RCW 9a. 76. 020 Later that morning I placed a hard copy of Resolution No. 113?1992 (Whistleblower Policy) on Ms. Gibboney's desk. Also on January 21, 2015, RE hand?delivered a copy of the IGA Report with his complaint against Mr. Thomas to Randall Gaylord, after deciding that the county Risk Manager had been made aware of Mr. Thomas's action at the time and "apparently did not act. so RE could bypass that instruction in the Policy (In fact, the County's Risk Manager had no notice of the ERTS or the Hughes property wetland issue.) Around January 21- 22. 2015 After ?ling the IGA report, RE visited the Hughes property, and made his own determination that there were signs of wetland habitat on both the Hughes property and the adjacent property (with the pond). He determined that the "claim that no signs of wetland habitat was erroneous". Janqu 23, 2015 On January 23, 2015, RE contacted Department of Ecology's Wetland Specialist Doug Gresham and asked for help with the Hughes property wetlands assessment. Janna}: 26, 2015 RE traveled to the Hughes property with Mr. Gresham. Mr. Gresham con?rmed that there were wetlands on the adjoining property, con?rmed it was a manmade pond, and that the Hughes's planned single Family residence was properly placed outside the buffers required. RE asked Mr. Gresham to assist him in rating and delineating the wetland edges, which they then did. They were witnessed measuring the PFEOA property and at no time did they notify the Portland Fair Estates Owners Association as to their intention to be on the Association's property. January 26, 2015 Without noti?cation to or consultation with Ms. Grah's direct supervisor, Linda Kuller, RE requested that Annie Matsumoto?Grah prepare a written statement regarding her work with the Hughes project and give that statement directly and only to him. Ms. Grah did so. Ms. Grah noti?ed her supervisor and Director Gibboney that she had been asked to prepare the statement. Page 11 of 29 Janu?y 27, 2015 In notes, he states that Ms. Gibboney met with him and inquired as to why he had not followed the procedure in the Whistleblower policy. He stated that he did so based on the advice of the Prosecuting Attorney, and that he had handed the investigation over to the Prosecuting Attorney's of?ce. Ms. Gibboney asked RE for a written report, citing the "procedures for reporting" in the Whistleblower Policy, and he refused, stating that he had already given a detailed report to the PA. RE then notes that he called PA Gaylord, who said RE should not give her a copy of the report. RE wrote that he asked the County?s GIS Program Coordinator to accompany him this same day to the Hughes property. At the property, the Coordinator used the remote GPS to map the delineation ?ags placed by Wetland Specialist Doug Gresham. Janum 28, 2015 PAvGaylord sent RE a letter acknowledging his receipt of report pursuant to Resolution Gaylord writes that he has "disclosed the existence of the report to senior management, but that the existence of the report and the name of the reporting party remain con?dential. He further notes the following: "Given the fact that this matter involves an isolated incident for which there is good documentation, I am hopeful that I will be able to take prompt action without the need for a full investigation. According to the policy, at least 2 Council Members (if the PA felt there was a con?ict with Mr. arman being the president of the homeowners association) should have been informed of the full details of the report and should have been given full access to the investigation. RE noted his concern that this letter states his identity was revealed to senior management. This is not what Mr. Gaylord wrote in his report. Janm 30, 2015 For the first time since his "investigation" began, RE contacted the property owner, Mr. Chris Hughes, about the August request from Ms. Grah to have a wetland review. Mr. Hughes told RE that he had not met Mr. arman before the summer of 2014, and that he did recall discussing the wetland review requirement with Mr. arman but wasn't specific about whether he complained to him. February 5, 2015 Doug Gresham, Wetland Specialist with DOE, provided RE with his report: "Ecology Wetland Findings for Hughes Property In his report, he notes: "starting at the western edge of the adjacent property, there is a seasonal steam that ?ows southeast into a farm pond impounded by a manmade berm. his farm pond over?ows into a drainage ditch that eventually ?ows southeast onto the Hughes property. Surface water ?om this seep ?ows in a de?ned channel across the southwest corner of the Hughes property and is culverted under both driveway Mr. Gresham made the following conclusions about the Hughes property: Page 12 of 29 J. "Soil pit was located with the channel between the two driveway crossings, and contained dark brown (I OYR 3/1) sandy silt with redoximorphic features that meet the redox dark surface criteria for hydric soil. There was ?owing water and the vegetation consisted of creeping bentgrass and so?? rash. 2. Soil pit was located on a terrace above that channel so there were no signs of hydrology. The soils were dark brown 7.5 Yr 3/2) silty sand but did not meet the hydric soil criteria. Dominant vegetation included Douglas fir, madrone (Arbutus menziesiz), snowberry, orchardgrass, braken fern, and creeping bentgrass. 3. According to the Cowardin classi?cation system, Wetland (pond) includes both palustrine emergent and open water classes, while Wetland (Hughes property) contains palustrine scrub/shrub and emergent classes. 4. Based on the hydrogeomorphic classification system, Wetland is a depressional wetland, and Wetland is a slope wetland. 5. According to the Washington department of Ecology wetland rating system, both Wetlands (the PFEOA pond) and (ditch at bottom of the Hughes property) are Category IV wetlands. February 12, 2015 PA Gaylord presented the County Council a draft report, and sent a copy of this report to RE. The content of the report is covered in a separate section of the report. February 18,2015 RE sent PA Gaylord a response memo to PA Gaylord's preliminary report. The following summarizes the points in the response memo: He objects that the names of those involved would remain con?dential until the report is ?nal, and claims that the Resolution 113?19928) only requires that the identity of the reporting employees should be kept con?dential, "to the extent possible and any personnel actions that may be applied. The subtext appears to be that he wants the names of the alleged wrongdoers to be made public. March ll 2015 Prosecuting Attorney Randall Gaylord issued a Memorandum, ?Report on IGA report dated January 21, 2015? and sent to Mike Thomas, RE, Bob Jarman, Jamie Stephens, Rick Hughes, and Sam Gibboney. March 11 2015 RE sent a report to Sam Gibboney related to his investigation of the ERTS #6541194. ,The report states that Ms. Grah asked the Hughes for a Wetlands Review; based on Ms. Gibboney?s email, Ms. Grah approved the Hughes permit without a written wetlands review; in response to the ERTS #654194, RE visited the Hughes parcel, he asked the DOE wetlands specialist to visit the parcel as well to determine if wetlands were present. The wetlands specialist Gresham evaluated the soil and delineated the wetlands; Gresham determined that the Hughes project was properly Page 13 of 29 placed outside of what would be the Water Quality buffer of 60 feet and the Habitat buffer of 110 feet. RE noted that there was a minor violation of approved Storm Water management Plan?s Best Management Practices (straw on ditch and driveway) that he would work with the property owners to correct, but that there was no need for formal enforcement action. He considered the enforcement inquiry closed. In the closing section of his report, he references the IGA report concerning Mr. Thomas and PA Gaylord?s official memorandum concerning the IGA issues, although that has no bearing on the ERTS wetland determination. March 12 2015 RE sent an email to six employees of the Department of Ecology (including Doug Gresham), one employee of the Department of Fish and Wildlife, and one employee of the Army Corp of Engineers, noting that ?On January 20m, 2015 San Juan County Code Enforcement received ERTS #654194 concerning a possible wetland violation and more importantly an allegation of improper interference with San Juan County permit review by County In the interest of transparency and to assure the public and other agencies that such allegations are thoroughly investigated by San Juan County I am sending out this emails which has attached San Juan County?s investigatory actions and my ?nal report on enforcement ?le In addition to his code enforcement ?le, RE attached his IGA report and PA Gaylord?s Memorandum concerning Report on IGA Report dated January 21, 2015. Mr. Law?s supervisor, Sam Gibboney, was given the report at the end of the prior day, March 1 1, 2015, and had not had an opportunity to comment on it, nor was she copied on the email correspondence. March 13 2015 RE email of 3/ 12/ 5 was forwarded to Ms. Gibboney by Erik Stockdale, Mr. Gresham?s supervisor. April 6, 2015 Sheryl Albritton sent Sam Gibboney a letter questioning the County?s decision to close the Hughes enforcement case. Ms. Albritton notes that the complaint was closed because the location of the house is outside wetlands buffers, but says that the driveways were the focus of her complaint. Specifically, she contends that there is a second driveway she terms ?illegal? that was expanded by the new owners, wetlands were ?lled, a water issue caused additional ditching in the area, and there was a ?great amount of fill? as a new disturbance. She notes that ?the final determination by ER states the case was closed since the wetland ?ll was prior to 2008. if this is the case then this determination shall serve as a standard for all other pre-existing non- conforming (in general). Please con?rm that 2008 is a new base line standard for unpermitted activities or require the Hughes obtains proper review and permits for the wetland ?ll. Mid?April, 20 5 Sam Gibboney met with RE to review his enforcement report, identifying misinformation. She requested he rewrite the report to focus on the content of the ERTS. May 7, 2015 Page 14 of 29 Ms. Gibboney received a revised code enforcement report from RE and identi?ed additional errors. She instructed RE to submit the corrected report to DOE. Ms. Gibboney has not been noti?ed that he has done so. Page 15 of 29 ATTACHMENT 11: San Juan Countyr Code related to Critical Areas Section 18.10.030: Code interpretations and administrative determinations. (A) Code Interpretations. 1. Upon request or upon the administrator?s own initiative the administrator shall review and resolve any questions involving the proper interpretation or application of the provisions of this code. The administrator?s decision shall conform to the letter of this code and with the spirit and intent of the Comprehensive Plan. (B) Administrative Determinations and Decisions. Upon request or upon the administrator?s own initiative the administrator may issue a determination regarding the administration of this code, including but not limited to, a determination of incomplete application (see SJ CC and a determination terminating review of a proposal. The administrator also issues decisions approving or denying develOpment or project permit applications, or imposing conditions on such permit applications. These administrative decisions include, but are not limited to, decisions on applications for those project permits where the administrator is the decisionmalcer simple land divisions). Section 18.020.010: de?nitions ?Administrator,? ?planning director,? and ?director? each mean the San Juan County community development and planning department director or a designated representative. Section 18.35.095: Wetlands Minimum size thresholds for regulated wetlands. Section states the following: Wetlands exceeding the following size thresholds are regulated under this section: A. Category I wetlands." no exemption all wetlands are regulated B. Category and Wetlands: 1, 000 square feet C. Category IV wetlands wetland mosaics: 2, 5 00 square feet. The pond on the Portland Fair Estates Owners Association property has been designated a Category IV wetland. The ditch area on the Hughes property would also be Category IV and falls under the threshold for being regulated. Section 18.35.100 Wetlands Protection standards This subsection establishes protection standards for wetlands, including a site-specz?c procedure for sizing wetland bu?ers A. Site-Speci?c Bu?er Sizing Procedure. The following is a site?speci?c procedure for determining the size of vegetative bu??ers necessary to protect the water quality, water Page 16 of 29 quantity, and habitat functions of wetlands. Two separate bu?er components, a water quality component and habitat component, are considered in the procedure. Required bu?ers apply regardless of whether the wetland is on the same parcel or another parcel that may be under di?erent ownership. If the wetland is under dijj?erent ownership and is not accessible, then the wetland rating and boundaries are established using available maps and information, including a visual assessment if possible. The water quality bu?er is determined first based on the wetland rating category and land use intensity ?om Tables 18. 35. 1001 and 18. 35. 100?2 provided in Step 4 below. The habitat buffer is then determined ?om Table 18.35.] 00-3. In all cases, conditions on the ground shall control. 1. Determine the Water Quality Bu?ier. Step 1. Location Relative to Wetlands. Is the proposed development, vegetation removal or other site modi?cation located within 3 00 feet of a wetland? 17 so, proceed to the next step. In some cases, to answer this question, it may be necessary to have the wetland edge ?zcing the area that will be developed or modi?ed delineated in accordance with SJCC 18. 35.105. In many cases, this can be based on a wetland reconnaissance rather than a full delineation. Although maps and other imagery can be sued to help with this determination, conditions on the ground shall control Step 2. Drainage Direction. Does the area proposed to be developed or modified drain to the wetland? 1f the area proposed to be developed or modi?ed drains to the wetland, delineate the wetland in accordance with SJCC 1835.105 and proceed to determine the required water quality bu?er. 1f the area proposed to be developed or modified does not drain to the wetland, a water quality bu?er is not required and only a habitat buffer applies. Proceed to the habitat bu?er sizing procedure in subsection (140(2) of this section. Table 18.35.100-1 Water Quality Buffers Category IV wetlands have water quality buffers based on land use intensity as follows: a Low intensity (forestry, low intensity agriculture) 25 feet a Medium intensity (residential) 40 feet a High intensity (commercial, industrial, high intensity agriculture) I 50 feet The 40 foot water quality buffer would apply to the pond neighboring the Hughes parcel Table 18.35.1006 Habitat Buffer Category IV wetlands have habitat buffers based on land use impact as follows: a Low impact 25 feet 8 Moderate impact 40 feet a High impact 50 feet The 40 foot habitat buffer would apply to the pond neighboring the Hughes parcel. Page 17 of 29 Section 18.35.105: Wetlands Determination of wetland boundary and requirements for wetland reports. of the San Juan County Code apply to this parcel investigation. (A) The purpose of wetland boundary delineations and wetland reports is to provide the information necessary to determine compliance with the wetland protection requirements of the County Code, and to help maintain protected areas overtime. (B) The delineation of wetland boundaries, and, except as noted, the preparation of wetland reports, must be performed by a qualified wetlands professional. (C) If a wetland is under dijferent ownership and is not accessible by the applicant, the wetland boundaries and information for the report will be obtained from available maps and information, including a visual assessment if possible. he necessary scope of wetland delineations and reports ranges from a wetland reconnaissance that simplv con?rms the presence or absence of a wetland, determines the wetland type, rating, and approximate size, and identifies the edge of the wetland in a limited area, to a delineation of the entire wetland with a detailed report describing its functions and values. (E) A wetland report and boundary delineation, with an appropriate scope and scale to determine compliance with the County Code, must be provided with applications for project and development permits located within 3 00 feet of wetlands. Page 18 of 29 ATTACHMENT ill: Statement by Annie Matsumoto-Grah SAN JUAN COUNTY DEPARTMENT OF COMMUNITY DEVELOPMET 135 Rhone Street, PO Box 947, Friday Harbor, WA 98250 (360] 378-2354 I (360) 373-21 16 dcd@soniuonco.com I To: \0 rom: Annie Matsumoto?Grah RE Re: statement Date: January 26, 2015 This statement will give a chronological account of my involvement in the land use/critical areas review of building permit application Buildg-14-O229 (Hughes). This statement will also include information on all correspondence between SJC employees/publiclowners regarding this permit. review of the iand use designation maps, plat maps, critical area maps, and aerial and topography maps. Critical area maps depicted a pond/wetland area located on the property directly west of the Hughes property. in addition to the wetland critical maps showed an "un- typed stream?/drainage area running from the pond/wetland to the south east. Within a few days of this determination i received a phone call from Sheryl Albritton. property owner of the parcel directly north of the Hughes parce. She inguired about any building permits submitted on the Hughes parcel and expressed concern that any development on the Hughes parcel would greatly impact the wetlands to the west. Sheryl said she had walked extensively around the pond/wetland area and the Hughes property and that the pond/wetland area was much larger then what it appeared to be on the county wetland maps. As with any inquiry or concern expressed by a member of the public i told her would further investigate the issue. Between August 25?h and August 27?" (I cannot remember the exact day) visited the Hughes parcel with my co-worker Nadine Cook. On my site visit i observed a substantial amount of wetland vegetation around the pond and surrounding areas. Due to the heavy amount of vegetation, both wetland and non?wetland species I could not clearly identify the wetland w. .. 7 arms? - 4 was" Buiidg?14-0229 Hughes Page 19 of 29 -. boundary. As i could not clearly identify the wetland boundary 1 believed a wetland assessment prior to land use! critical area approval of the building permit. The letter included information about a county wetland assistance program in place in 2014 which provided a free wetland assessment from a wetland consultant contracted with the county. On September 4, 2014 i received an email from Mr. Stanton he had faxed the application for the free wetland assistance program. i do not beli lication made it our department as it was not documented or entered into our permit tracking system or the application was discarded following later correspondence with other staff. Some point after receiving my letter i believe the property owner called a council member or Mike Thomas in protest of the requirement of a wetland assessment. On September 7, 2014 i received an email from SJC DCD Director, Sam Gibbcney which said Mike Thomas, County Manager and a "local wetland expert" someone with the initials visited the site and determined that there were no wetlands present so need for a wetland assessment. No information was included in the email in regards to how Mike and the "local wetland expert" came to the conclusion that no wetlands were present, I thought this odd because i saw something very different on site. i sent Sam an email on September 11, 2014 asking if we received any written determination from the ?local wetland expert", following an email request from Sheryl Albritton. I did not receive any response from Sam. approved this permit on September 12, 2014 following several frustrated inquiries from the applicant's agent asking why this permit wasn't issued yet. later verbally reminded Sam for a written response for the file and she said she would look into it and get back to me. I never received any additional written documentation other than the email from Sam dated September 7, 201-4. Since did not receive any response from Sam spoke to Linda Kuller, Planning Manager regarding this issue. emailed her on December 12, 2014 with Sam?s email attached. To this date, no written documentation was ever provided from the ?local wetland expert?. Page 20 of 29 ATTACHMENT EV: E-mail from Director Gibbonev to Ms. Grah From: Sam Gibboney Sent: Tuesda': Segaie'mbeare?, 2914 1134534 To: Annie lviafsumatG?Gm Subject a Portland fair praperby Annie - there is a permit applicatier in for a pmperiy in Ehe P?l?tfa?d Fairneighborhmd. Sapposediy ?ne ofihe neighbors reports-u? iha?tthere might be a wetiand. Mike walke? {he site 135% night with a local wetland expert a?d then! are no signs a? me. 50 n9 need far a rattan. Let me know you me which app?ica??n Fm faking abeut. Sen: from my iPhame Page 21 of 29 ATTACHMENT V: San Juan County Whistle Blower Policv RESOLUTION NO. 113 1993 RESOLUTION ESTABLISHING PROCEDURE FOR REPORTING IMPROPER GOVERNMENT ACTION AND PROTECTING EMPLOYEES AGAINST RETALIATION WHEREAS, San Juan County adopted. Resolution No. 151?1991 establishing new personnel rules which did not include guidelines for reporting improper government action and rules for protecting the employees from retaliation, and it is the policy of San Juan County to foster open and efficient operations free of any taint of impropriety, and WHEREAS, it is in the interests of all employees and citizens of San Juan County to have a swift and specific procedure available at the local level for any complaints about governmental improprieties, and WHEREAS, no employee should suffer retaliation due to any attempts by such an employee to identify a governmental impropriety, NOW THEREFORE BE IT RESOLVED, that San Juan County adopt the following "Whistleblower Policy" as a new section to Chapter 15 of the Personnel Rules. WHT STLEBLOWER POLICY REPORTING IMPROPER GOVERNMENT ACTION AND PROTECTING EMPLOYEES AGAINST RETALIATION Policy Statement It is the policy of San Juan County (1) to provide a procedure for employees to report improper governmental action_by San Juan County officers or employees, and (2) to protect San Juan County employees who have reported improper governmental actions in accordance with San Juan County?s policies and procedures. Dave%- 5mm? Th?s .3: ~5 USDMQ Couvi'hmf?a: Page 22 of 29 Definitions As used in this policy, the following terms shall have the meanings indicated: 1. "Improper governmental action? means any action by a San Juan County officer or employee: a. That is undertaken in the performance of the officer?s or employee?s official duties as a county employee, whether or not the action is within the scope of the employee?s employment; and b. That is in violation of any federal, state, or local law or written departmental policy, (ii) is-an abuse of authority, is of substantial and specific danger to the public health or safety or (iv) is a gross waste of public funds. "Improper governmental actionf does not include personnel actions, including employee grievanoes, complaints, appointments, promotions, transfers, assignments, reassignments, reinstatements, restorations, reemployments, performance evaluations, reductions in pay, dismissals, suspensions, demotions, violations of collective bargaining? or civil service laws, alleged violations of labor agreements or reprimands. 1?0 "Retaliatory action" means any adverse change in the terms and conditions of a San Juan County employee?s employment. 3, "Emergency" means a circumstance that if not immediately changed may cause damage to persons or property. Procedures for Reporting San Juan County employees who become aware of improper governmental action should raise the issue first with their supervisor. If requested by the supervisor, the employee shall submit a written report ix) the supervisor stating in detail the basis for the employee?s belief that an improper governmental action has occurred. Where the employee reasonably believes the improper governmental action involves his or her supervisor, the employee should raise the issue directly with the highest official in the department or the official holding the position of Risk Manager. In the case of EUI emergency, where the employee believes that damage to persons or property may result if action is not taken immediately, the employee may report the improper governmental -9- Page 23 of 29 action directly to the Board of County Commissioners and to the appropriate government agency outside of the County when such agency has responsibility for investigating the improper action. msupervisors or the Risk Manager shall take prompt action to assist San Juan County in properly investigating the report of improper governmental action. San Juan. County? officers and employees I '1 - .. Clio: .L In. op out: iuen L. .L L. J. I epo rt. ing employees confidential to the extent possible under law, unless the employee authorizes the disclosure of ?his or .her identity in writing. After an investigation has been completed, the employee reporting the improper governmental action shall be advised of a summary of the results of the investigation, except that personnel actions taken.as a result of the inVestigation shall be kept confidential. Thereafter, San Juan County employees may report information about the improper governmental action directly to the appropriate government agency which has responsibility for inVestigating the improper action if the San Juan County employee has a reasonable belief that one of the following two conditions exists: 1) An adequate investigation was not undertaken by San Juan County% to determine whether an improper governmental action occurred, or insufficient action has been taken by San Juan County to address the improper governmental action. San Juan County employees who fail to make a good?faith attempt to follow San Juan County procedures in reporting improper governmental action shall not receive the protection provided by San Juan County in these procedures. Protection Against Retaliatory Actions San Juan County officials and employees are prohibited from taking retaliatory action against a San Juan.County employee because he or she has, in good faith, reported an improper governmental action in accordance with these policies and procedures. Employees who believe that they have been retaliated against for reporting an improper governmental action should advise the San Juan County Personnel Director. San Juan County officials shall take appropriate action to investigate and address complaints of retaliation. If the San Juan County Personnel Director does not satisfactorily resolve a San Juan County employee?s complaint that he or she has been retaliated against in violation of this policy, the San Juan w3. Page .54 OT ?3 County employee may obtain protection 'under this policy and pursuant to state law by providing a written notice to the San Juan County Board of County Commissioners that: a. Specifies the alleged retaliatory action and b. Specifies the relief requested. A San Juan County employee shall provide a copy of the written charge to the Sen Juan County Personnel Director no later than thirty (30) days after the occurrence of the alleged retaliatory action. San Juan County shall respond within thirty (30) days to the charge of retaliatory action. .After receiving either the response of San Juan County or thirty days after the delivery of the charge to San Juan County the San Juan County employee may request a hearing before a state administrative law judge to establish that a retaliatory action occurred and to obtain appropriate relief provided by law. An employee seeking a hearing should deliver the request for hearing to the San Juan County Personnel Director within the earlier of: 1) either fifteen (15) days of delivery of San Juan County?s response to the charge of retaliatory action, or 2) forty?five (45) days of delivery of the charge of retaliation to San Juan County for response. Upon receipt of request for hearing, San Juan County Personnel Director shall apply Within five (5) working days to the State Office of Administrative Hearings for an adjudicative proceeding before an administrative law judge: Office of Administrative Hearings P.O. Box 42488, 4224 Sixth S.E. Row Six, Building 1 Lacey, WA 98504-2488 (206) 459?6353 San Juan County will consider any recommendation provided by the. Administrative Law Judge that the retaliator be suspended with or without pay or be dismissed. Responsibilities The Personnel Director is responsible for disseminating San Juan County?s policies and procedures 1) for reporting improper governmental action and 2) for protecting employees against retaliatory actions. This includes ensuring that this policy and these procedures are: permanently posted where all employees will 'have reasonable access in) them, (2) made axailable upon request and (3) provided to all newly~hired employees. Officers, managers and supervisors are responsible for ensuring the procedures are fully' implemented. within their areas of Page 25 of 29 mean I responsibility. 'Violations of this policy and these procedures may result in appropriate disciplinary action, up to and including dismissal. List oi Agenc1es Attached is a list of some of the agencies responsible for enforcing federal, state and local laws and investigating other issues involving improper governmental action. Employees having questions about these agencies or the procedures for reporting improper government action are encouraged to contact the Personnel Director who shall review and update the list periodically for completeness and accuracy. DONE this Hm day of gain 199;?. BOARD OF COUNTY COMMISSIONERS SAN JUAN COUNTY, WASHINGTON Jar-M aware Member Member ATTEST: Si A. Stephens, Auditor and Ex?Officio Clerk of the Board BY: 'Hq'?s Jeerie J. MaQJsden Deputy APPROVED AS TO FORM ONLY: 05.x, {km San Juan County Prosecuting Attorney. BY: Attachment to Resolution No. H3 1993 LIST OF AGENCIES Following is a list of agencies responsible for enforcing federal, state and lecal laws and investigating other issues involving improper governmental action? Employees having questions about these agencies or the procedures for reporting improper governmental action are encouraged to contact the Personnel Director. Office of San Juan County Prosecuting Attorney P.O. Box 760, 350 Court Street Friday Harbor, WA 98250 (206) 378~4101 Office of San Juan County Sheriff P.O. Box 669, Annex 135 Rhone Street Friday Harbor, WA 98250 (206) 378-4151 STATE OF .WASEZEJGTON Attorney Genersfs O?ce Fair Practices Division Human Rights Commission #02 Evergreen. Plaza Bldg, FJ?dcl 711 South Capitol Way Olympia, WA 98504-2490 2000 Bank of California Center take Deparment of Health mo Avenug- Health Consumer Assistance sear-43? WA RC). Box 4789 (295) 4m~ Olympus, WA 98504?7891 800-525-0127 Stats Audi'be Of?ce Department of Labor 3: Industries l'eg?la?ve B?djng 300 West Harm's-on, Room. 201 PO. Box 4-0021 Seat?tie, WA 9 (-05) 753?3280 State Liquor Control Board State Department ofEbulogy Enforcth CECE 3190 150th 533- 2101 Sixth Avenue Bellevue, (206) 6494000 (206) 4?54-6094 Page 27 of 29 Department of Natural Resources P. O. Box 68 a ,Enumciz'aw. WA 98022 5' . . . :rzr? tarry-m: mun-.2: .-.-: Puget Sound Water Quality Authority P. O. Box 40900 Olympia, WA 98504 (206) 493?9300 Department of Social and Health Services Special Investigation O?ce 5200 Southcenter Blvd, Suite 23 ?I?ukwila, WA . 764?4048 Fraud Complaints 800?562-6025 UNITED STATES Depar?ent ongI-iculture Of?ce of Inspector General 915 Second Avenue Seattle, WA Supervisor Auditor (206) 553-6290 Supervisor Special Agent Investigation (206) 55313235 ioohol Tobacco all: Firearms ziminal Enforcement 915 Second Avenue Seattle, WA (206) 553?4485 U. S.Attoruey 800 Fifth Avenue Seattle, WA (206 553?7970 Department of Commerce O?ce of Inspector General Of?ce of Audits 915 Second Avenue Seattle, WA (205) 553?0801 Government Accounting O?ice Fraud Hot Line 800424-5454 Consumer Product Safety Commission Hot line 800?638?2772 US. Customs Service Of?ce of Enforcement 909 First Avenue attle, WA 553-7531 nan-z 72-: . Res. Joe. ?5?1713 US. Department of Education Of?ce of Inspector General 915 Second Avenue?, Audits Investigations (206) 553?0657 (206) 553-1482 Environmental Protection Agency Criminal Investigations 1200 Sixth Avenue Seattle, WA (205) 553-8305 Equal Employment Opportunity Commission 2815 Second, Suite 500 Seattle, WA (206) 553-0963 Federal Emergency Management Agency 130 228th Street SW. Bothell, WA (2.06) 487-4600 Federal Trade Commission 915 Second Avenue Seattle, WA (206) 553-4556 General Services Administration 915 Second Avenue Seattle, WA O?ce of Inspector General Audits Investigations (206) 931-7550 931-7654 Law Enforcement (205 553-0290 Department of Health 8: Human Services Food Drug Administration 22201 23rd Drive SE. Bothell, WA Tiade Complaints (205) 483?4949 Of?ce of the Regional Secretary . General Comel?s-O?ioe, Inspector General Audits Investigations (206) 553-0452 (206) 553m0229 Department of Housing and Urban Development O?ce of Counsel 1321 Second Avenue Seattle, WA 553-4976 Of?ce of Inspector Audits Investigatiooe (-206) 553-0270 (206) Page 28 of 29 Interstate Commerce Commissien 915 Second Avenue, Room 1894 Seattle, WA 98174 (206) 553-5421 Department of Interior US. Fish 8: Wildlife Services, Division ofLaw Enforcement 121- 107th NE. Bellevue, WA (206) 553-5543 Department of Justice Drug Enforcement Administra tiou 220 West Mercer, Suite 300 Seattle, WA {205) 553-5443 Department of Labor Occupational Safety 8: Health (OSHA) 1111 Third Avenue, Suite 715 Seattle, WA. 98101-3212 (206) 553-5330 Office ofluspector General Audits 1111 Third Avenue, Suite 780 Seattle, WA 98101-3212 (206) 553-4880 Investigations 1111 Third Avenue, Suite 785 Seattle, WA 98101-3212 Of?ce of Women's Bureau 1111 Third Avenue, Suite 885 Seattle, WA 98101-3212 Mine Safety 9: Health Administration 117 107th NE. Bellevue, WA (206) 553-7037 National Transportation Safety Board 19518 Paci?c Highway? South. Seattle, WA (206) 764?3782 Nuclear Regulatory Commissien 510?975-0200 Securities and Exchange Commission 915 Second Avenue Seattle, WA 98174 (206) 553-7990 Depaxtment Of?ce of Inspector General 915 Second Avenue Seattle, WA 98178 (206) 553-5720 Department ofTreasmjr Bureau of Alcohol, Tobacco Firearms Law Enforcement Division 915 Second Avenue, Room 806 Seattle, WA 98174 Department of Veterans Affairs Of?ce of Inspector General 915 Second Avenue Seattle, WA 98174 Fraud/Waste/Abuse Hot Line 800?488?8244 Page 29 01?29