Call to Action and CAO update status
By John Brock, EEC Board member
December 29, 2025
CAO Update
On July 18, 2025, the Edmonds Environmental Council (EEC) hosted a workshop at the Port of Edmonds to discuss how the organization should engage with the City of Edmonds. Participants expressed concern that the City was not adequately advancing the Critical Areas Ordinance (CAO) update required by the end of 2025. Based on that discussion, the EEC decided to engage constructively.
Later that month, the EEC board approached City Planning to offer assistance with the CAO update. We were connected with Senior Planner Brad Shipley, who was leading the project and welcomed community input and local expertise. Beginning July 29, a small group of local residents—including EEC members and other volunteers—met seven times with City staff. Our shared goal was to help balance state housing mandates, environmental protection, and compliance with Washington State environmental law. This collaborative, volunteer effort was productive and effective.
The resulting draft ordinance was presented to City Council on November 25, followed by a public hearing. The draft ordinance received significant praise for both its substance and the streamlined, transparent process used to develop it.
Draft Critical Areas Ordinance as presented to Council on November 25th:
However, several days after the public hearing had closed, the City Attorney replaced the Critical Aquifer Recharge Area (CARA) section of the draft CAO with language from the prior ordinance. This late substitution reinstated flawed provisions that would continue to allow PFAS-contaminated stormwater to infiltrate the Deer Creek Springs CARA through shallow UIC wells—without public notice or opportunity for review.
At the December 16 City Council meeting, Council deliberated on this improperly revised ordinance. A thoughtful discussion led Council to postpone action until January 6, 2026, reopen the public hearing, deliberate in open session, and consider possible action. This was the correct decision. It remedies a flawed process in which substantive changes were introduced after the public hearing closed, bypassing meaningful public review.
The City Attorney has asserted that there is insufficient Best Available Science (BAS) to justify prohibiting shallow UIC wells within the CARA. That conclusion is incorrect. While residential stormwater BAS is limited, it does exist, it is adequate for decision-making, and it has been provided to the City:
https://edmondsenvironmentalcouncil.org/critical-areas-best-available-science/
The available BAS consistently concludes that avoiding infiltration is the most protective and currently viable approach for preventing PFAS contamination of groundwater. Claims that such science does not exist reflect a lack of awareness, not a lack of evidence.
City Council has both the authority and the responsibility to correct this. We urge Council to reject the irregularly proposed CAO language change and retain the CARA provisions presented at the November 25 public hearing. That language protects the aquifer and complies with state law. If future BAS demonstrates that infiltration poses no contamination risk, the CAO can be appropriately relaxed. But once an aquifer is contaminated, the damage is effectively permanent.
This CAO update and code reorganization will clarify permitting, protect streams and salmon, preserve natural resources, and hopefully — will safeguard Edmonds’ drinking water for future generations too.
Call to Action:
Please consider attending this important public hearing and delivering your own comments.
The meeting will be held at 6pm on Tuesday, January 6, 2026 at 250 Fifth Ave N, Edmonds.
Please email your comments before the meeting on 1/6/26.
Your comments will be sent to Council members before the public hearing.
City Council – council@edmondswa.gov
Senior Planner – brad.shipley@edmondswa.gov