Public Hearing

AGENDA Public Hearing Meeting 10:00 AM - Tuesday, April 21, 2026 200 East Scott Avenue - Woodland, Washington Page I. CALL TO ORDER II. PUBLIC HEARING A. Belmont RV Conditional Use Permit renewal (WLD-26-002) 2 - 30 Item-26-0067 Supporting Packet - Pdf III. END MEETING Join Zoom Meeting https://zoom.us/j/95399631481?pwd=QpCe7SIyDRNadyZ7toCBDtblDgzVyZ.1 Meeting ID: 953 9963 1481 Passcode: 083487 One tap mobile +12532158782,,95399631481#,,,,*083487# US (Tacoma) +12532050468,,95399631481#,,,,*083487# US Join by SIP • 95399631481@zoomcrc.com Join instructionshttps://zoom.us/meetings/95399631481/invitations?signature=yE_BoUNfiUVuwcoE DC5yJ37nRWOF3iqyguhEZLT9SqE Page 1 of 30 Agenda Item Report Meeting Date: Public Hearing - 21 Apr 2026 Department: Building/Planning Heading: PUBLIC HEARING Staff Contact: Travis Goddard, Community Development Director Subject: Belmont RV Conditional Use Permit renewal (WLD-26-002) Summary Statement: The applicant is requesting a new Conditional Use Permit (CUP) for the Belmont RV Park located at 1880 Belmont Loop in Woodland Washington. The site was first opened in 2023 with an approved site plan and CUP but the CUP was revoked in 2026 due to non-compliance with the conditions of approval. The applicant is seeking to renew the CUP to resume operation. Financial Impact: Cost of Item: $0 Amount Budgeted: $0 Bars Code description: Unexpended Balance: $0 Attachments: Staff Report Belmont RV CUP WLD-26-002 Page 2 of 30  .u'r Community Development Department City 0/ Building | Planning [ Code Enforcement WASHINGTON OODLAND P.O. Box 9, 230 Davidson Avenue (360) 225-7299, www.ci.woodland.wa.us STAFF REPORT 8: RECOMMENDATION Belmont RV Conditional Use Permit Renewal — Land Use Application Nos.: (Site Plan Review & Conditional Use Permit) WLD—26—002 Applicant/Owner: Belmont Loop RV Resort LLC Michael & Denise Werner 7607 NE 26‘hAvenue Vancouver, WA 98665 Site Location: 1880 &1876 Belmont Loop Woodland, WA 98674 Parcel Nos. & Size: 54211600, 504211602, 3.69 acres Zoning Designation: C—2,Highway Commercial Date Application Received: March 10, 2026 Notice of Application & Public March 18, 2026 Hearing: Publication Date: March 25, 2026 Public Comment for CUP April 10, 2026 ends: Public Hearing: April 21, 2026. 10:00 am. Staff Report Date: April 14, 2026 Staff Recommendation: Approval with Conditions I. DESCRIPTIONOF REQUEST The Belmont Loop RV Park received site plan and Conditional Use Permit (CUP) approval to develop 3.69 acres in to 67 full-utility hookup RV sites, an office building, restrooms, shower and laundry facility, and garbage and recycling enclosures. The proposal was approved and appealed in 2021, where the City Council upheld the Hearing Examiner decision to approve the CUP. The CUP included conditions of approval including a limit for occupancy of RVs to 90 days per Woodland Municipal Code (WMC). The City rescinded the CUP in a Notice & Order dated February 2026 for failure to meet the conditions of approval. Staff Report and Recommendation Belmont RV (WLD-265002 for SPR 20-011, SEP 207016, CUP 20-001) Page 1 Page 3 of 30 The applicant has requested a new CUP to operate the facility in accordance with WMC and the conditions of approval for the CUP. ll. LOCATIONOF PROPOSED DEVELOPMENT The development is proposed for parcels 54211600, 504211602 at 1880 Belmont Loop. The lots are zone highway commercial (C-1) and are located between Belmont Loop and Old Pacific Highway toward the south end ofthe loop. I". REVIEWAUTHORITY Per WMC 19.08.030, Site Plan Reviews shall be reviewed by the Development Review Committee. Per WMC 19.08.030 and 17.81.020, Conditional Use Permits are reviewed by Hearing Examiner. The original Site Plan Review (SPR), Conditional Use Permit (CUP), and SEPA checklist were consolidated for review and per WMC 19.08.020, the final decision for the consolidated application was rendered by the highest authority designated for any part ofthe application which was the Hearing Examiner. IV. FINDINGSOF FACT Permit History Finding 1: This city received a Conditional Use Permit and Site Plan application in December of 2020 and issued a Determination of Non-Significance on January 28, 2021. The Hearing Examiner issued a Final Order on the proposal in May of 2021 and the decision was appealed to the City Council. The council held a hearing on the appeal in July of 2021 and upheld the Examiner’s decision in August of 2021. Finding 2: The original staff report, Examiner’s Final Order, Examiner’s response to new information (as submitted during the open record process), and the Council’s appeal decision are all available on the project page and are part of the record because they show that the project as designed and constructed can meet city code. Based on this, staff will not repeat all of the analysis of those documents. Staff will however, analyze the project for how it has failed to meet code and the conditions of approval that were attached to CUP-20-001, SEP—20—016, and SPR—20—011. Finding 3: During operation, the site received several complaints for violations of city code and the conditions of approval. These complaints were not resolved and resulted in a Code Enforcement Notice & Order being issued on February 27, 2026 wherein staff cited multiple violations, assessed penalties at $50 a day for each violation, and listing required corrective actions. Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20001) Page 2 Page 4 of 30  Finding 4: One ofthose corrective actions was to resubmit for a new CUP if the business wanted to resume operating within the code and an approved permit. This application is an effort to resolve one of the violations listed on the Notice & Order. Specifically, to reestablish 3 CUP with conditions, so that the business can operate legally (because there are still RV units on the site). Finding 5: This staff report analyzes not only the impact of the RV park as proposed, but also the implications of how the year—round occupancy ofthe site in violation of the original CUP conditions of approval, has affected the city. This analysis is not meant either as opposition or support of the new CUP. It is instead meant to illustrate the impact of how the project affected the city when it was previously in operation without compliance. Finding 6: Staff wants to make sure the applicant understands the site will be responsible for operating with the conditions of approval for this CUP, not those of the original CUP. Development Impact Fees | WMC 3.41 and 3.42 Finding 7: Impact fees are collected at the time of building permit issuance. A condition of approval was added to the original application which required the fees to be calculated and paid at the time of building permit issuance. This condition was met with the original project when they paid Fire Impact Fees (FIF)and Transportation Impact Fees (TIF) for the project as proposed. Finding 8: Transportation impact Fees (TIF)are required on new development to support future transportation improvements within the city. The TIF was calculated for the proposal using ITE category 416 (Campground/Recreational Vehicle Park) which generates 0.27 new peak hour trips per RV site or 19.44 PM peak hour trips for the proposal. Finding 9: This calculation was on the assumption that the proposed RV Park would function as a commercial RV Park as permitted, and not as a permanent year—round occupancy similar to residential uses like a mobile home park or apartment complex. Such uses generate more impacts and higher trip rates than the CUP contemplated when it was approved. Finding 10: Residential uses like single»family homes generate approximately .98 trips per unit, and multi-family units like apartments generate from .51 to .7 peak hour trips per dwelling unit. As a result, more permanent housing situations like mobile homes or apartments would generate significantly higher trips than originally contemplated for the use. Staff Report and Recommendation Belmont RV (SPR 207011, SEP 20-016, CUP 20-001) Page 3 Page 5 of 30 For example, 67 single family units would generate 65.66 trips. At the 2020 TIF rate of $828 the project would have paid $54,366.48 for units occupied year—round, instead of the approximate $16,290 that was paid for a RV park with Highway Commercial (C-2) style turn-around rates. That amount is not due now, but it illustrates a measure of the impacts to the community that have resulted from the project not complying with its conditions of approval. Finding 11: Fire Impact Fees (FIF) are required on new development and the fee is calculated for commercial uses at a rate of$.51 per square foot for the commercial structure to be served. The fees paid at the time was for 885 sq. ft. (764 sq. ft. office + 121 sq. ft. restroom) for a FIF amount of about $451. For year-round occupancy, the use would have functioned similar to a mobile home park with living units, and the FIF rate would have been assessed at $1,426 per multi— family unit or $1,536 for a single-family unit. At that time, if Clark—CountyFire Rescue had known the site would be occupied year—round, additional SEPA mitigation or a FlF amount of between $95,542 and $102,510 would have been warranted. Again, this amount is not due at this time, but it should be noted that full time occupancy ofthe site in violation ofthe permit conditions of approval, have had a significant impact on the community. An impact that was not considered or mitigated for. Finding 12: School Impact Fees (SIF) are not collected for commercial projects and the RV park was not charged when it opened. Again, operating with year-round tenants, the use has been functioning similar to a mobile home park. SEPA mitigation or SIF would have been collected to mitigate for the impacts of 67 potential units and would have amounted to $385,300. Again, this amount is not due at this time, but it should be noted that full time occupancy of the site in violation of the permit conditions of approval, have had a significant impact on the community. An impact that was not considered or mitigated for. Finding 13: Park Impact Fees (PIF) are not collected for commercial projects and the RV park was not charged when it opened. Again, operating with year—round tenants, the use has been functioning similar to a mobile home park. SEPA mitigation or PIF would have been collected to mitigate for the impacts of 67 potential units and would have amounted to $306,860. However, staff must recognize that recreation impacts could have been mitigated for on site. The project included the minimum open space Staff Report and Recommendation Belmont RV (SPR 207011, SEP 20-016, CUP20-001) Page 4 Page 6 of 30  necessary to meet the 02 code for a site plan, but there were no additional efforts employed as a means to offset demand. Again, this amount is not due at this time, but it should be noted that full time occupancy ofthe site in violation ofthe permit conditions of approval, have had a significant impact on the community. An impact that was not considered or mitigated for. Conclusion: As conditioned, the project did mitigate for the impacts that would have been incurred had the site operated in compliance with the conditions of approval. Provided the applicant operates within the limits and conditions attached to this permit, the impact fee sections of code should be considered consistent with the code. Ifthe project does not comply with all the conditions of approval and city codes, the CUP would be subject to being rescinded again and the project closed. Streets and Sidewalks [ WMC Title 12 Finding 14: Belmont Loop street improvements are complete and no additional work is required. Conclusion: As it exists, the project complies with these development standards. Even with the additional demand placed on Belmont Loop from the operation in violation of permits, the project has not impacted the street or sidewalk standards that are applied to this site. Water and Sewage | WMC Title 13 Finding 15: Existing water mains with existing connections serve the site. Provided backflow devices are installed on the domestic supply line to the site, the project can meet standards. Finding 16: On-site fire hydrants are installed and as of late 2025, the fire mains are now with the required 15 ft wide easement to the City. This meets the condition of approval for the original CUP and city code. Finding 17: An existing sewer main is available and the site is connected within Belmont Loop. As built drawings for the 8—inchon site sewer main extension onto the site have been received by the city and the site meets the original condition of approval and city code at this time. Staff Report and Recommendation Belmont RV (SPR 207011, SEP 20-016, CUP 204101) Page 5 Page 7 of 30  Finding 18: Water and Sewer Assessment Fees were paid when the connections were made to the city utilities. If service connection sizes change as a result in the amount of water use and discharge, additional charges and assessments might be required. Finding 19: The demand for water and sewer will be dependent on the occupancy rate of the park. Given that the park has operated with full occupancy for some time, and there have been no problems with water pressure or sewer discharge, staff does not expect that additional work will be needed to keep service to the park under normal operating conditions under the requested CUP. Conclusion: As conditioned, the project can comply with this standard. Erosion Control | WMC 15.10 Finding 20: No development work is involved in this stage ofthe project. Conclusion: The project complied with this standard during construction. Stormwater Management ] WMC 15.12 Finding 21: Stormwater detention and treatment for the Pacific Park binding site plan is addressed by the off-site system and no changes are proposed. As part of the Belmont Loop development, they will be responsible for their share ofthe maintenance costs to keep the facility in working order. Conclusion: As conditioned, the proposal complied with this development standard. Permitted & Conditional Uses | WMC 17.36.020-.030 & 17,72,090 Finding 22: Per WMC 17.36.030, recreational vehicle camper parks located East of Interstate 5 are permitted as a conditional use with approval of the hearing examiner in the C—2(highway commercial) zoning district. Lodging such as hotels and motels are the most similar permitted uses in the C—2zone per WMC 17.36.020. Finding 23: The applicant has applied for a conditional use permit to replace CUP 20—001 which was rescinded by a Notice & Order for noncompliance with city code and the conditions of the CUP. Finding 24: Per WMC 17.72.090, a conditional use permit should be reviewed annually by a designated city official to ensure proper compliance with all permit provisions Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 6 Page 8 of 30  and conditions. At any time, if a permit is found to be in violation of permit conditions, the director and/or hearing examiner is empowered to review the permit and findings of the appropriate city official and, if deemed necessary, issue an order requiring compliance with the permit or revoke the permit. A condition of approval was added requiring the operator to submit materials demonstrating compliance with permit requirements for conditional use review to the Community Development Director by March 15‘,every year, to continue operating under the conditional use permit. (Original Condition #13.) This condition was not met nor was the condition for monthly reporting of occupancy. Staff is emphasizing the need for compliance with the reporting condition required in 17.72.090(C) and recommends adding a condition of approval for weekly occupancy reporting. See Conditions #2, #3 and #4 below. Conclusion: As conditioned, the project can comply with the criteria and standards for Recreational Vehicle Camper Parks. Setbacks l WMC 17.36.070 Finding 25: The setbacks are not intended to be changed. Conclusion: As existing, the project can comply with this standard. Building Height [ WMC 17.36.080 Finding 26: The minimum height allowed for buildings in the C—2zone is 15 ft and the maximum height is 45 ft. The existing office and restroom building meets this standard. Conclusion: As existing, the project can comply with this standard. Off-Street Parking I WMC 17.36.100, WMC 17.36.130, WMC 17.56 Off—streetparking must meet the landscape design standards in WMC 17.36.130.L, WMC 17.36.130.N.4 & .5 and WMC 17.36.1300. Number of parking spaces required are set by WMC 17.56. Required Spaces Finding 27: The project can generally be found to comply with the codes for parking. No additional work is required at this time for a new CUP. Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 7 Page 9 of 30 Screening Finding 28: As it exists the project generally complies with the screening standards if the vegetation is maintained and trees and shrubs are replaced as needed. A condition of approval reflecting the continued maintenance of the landscaping is included. See Condition #5. Conclusion: As conditioned, the project can comply with off—streetparking and landscaping standards. Architectural and Site Design Standards [ WMC 17.36.130 The purpose of the architectural and site design standards is to produce development that: Creates a physical environment that emphasizes buildings and landscaping, rather than parking lots, driveways, or large signs. Maintains the scale, texture, and architectural context of development. Encourage creative and innovative designs for sites and building designs. Allow for infill development that is sensitive to the existing urban design context. Protect and enhance the business environment and property values within the city in manners that support and stimulate business and industry. Standards in WMC 17.36.130 regard orientation to the street; plazas, courtyards, and seating areas; entrances, weather protection, articulation/massing, materials and colors, ground level details, transparency, blank wall treatments, roofline, screening rooftop equipment, sidewalks and street trees, curbs cuts and driveways, location of parking lot, pedestrian and bicyclist connections, site screening and buffers, parking lot landscaping, screening of trash and service areas, lighting, and sign design. Finding 29: The landscaping was installed as required but has not been maintained as discussed below. There is significant die off of the vegetation on the site. A condition of approval has been added requiring the applicant to reinstall landscaping to bring the site up to the approved plan and to maintain the landscaping as required. See Condition #5. Finding 30: Garbage and Recycling areas must be screened from the public view per WMC 17.36.1330 (P). The site has been cited for this because the garbage dumpster is stored outside the enclosure that was built for it. Staff Report and Recommendation Belmont RV (SPR 20»011, SEP 20-016, CUP 20-001) Page 8 Page 10 of 30  msmrs BELMONTLOOP IV nu Staff can only assume that the original dumpster enclosure was sized for a normal RV Park that would operate as a commercial operation. The full-time occupancy of the site likely resulted in a significantly increased amount of waste and recycling which necessitated a larger dumpster (which did not fit in the enclosure). 50, the location of the dumpster as shown was likely a result ofthe size ofthe dumpster. Finding 31: An The original Condition #16 required that a building permit be obtained for the garbage and recycling enclosure and that the structure must meet site design standards. It was recommended that the applicant discuss the enclosure size and location with Waste Control to determine that the enclosure design and location be serviceable and the garbage and recycling receptacles be sized as needed to serve the RV sites and be able to fit inside. This condition was either not complied with or their failure to operate within the CUP conditions caused the failure to comply with the CUP. Since this is an existing condition, it should be implemented without delay because the receptacles are plainly visible from public streets. Staff has added a condition of approval that requires the timely construction of a larger enclosure to ensure that WMC 17.36.130 (P) can be met. See Condition #6. Finding 32: A separate permit was required for all signs per WMC 1736.130 (R) and that they meet the requirements of WMC 17.52. A condition of approval was added but the project ultimately failed to meet these standards and the site was cited for this violation. See Condition #17. Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 9 Page 11 of 30  Finding 33: The site otherwise appears to meet the requirements of WMC 17.36.130. Conclusion: As conditioned, the project can comply with these architectural and site design standards. Performance StandardslWMC 17.48 The requirements of this section cover hazards and nuisances including sound level, vibration, air emissions, smoke, dust, odors, industrial wastes, fire hazards, heat, glare, radioactivity and radio transmitters. The project will be required to meet these requirements on an ongoing basis. Finding 34: The site has a proliferation of propane tanks that are larger than those that would normally be expected in an RV park which would normally serve transient tenants. The city updated the code allowing occupancy to go from 30-days to 90—daysin 2019 when it adopted Ordinance No. 1437. Finding 35: In that ordinance, the city amended Chapter 17.72 as discussed below, but it did contemplate the use of large propane tanks, nor did the CUP issued for the project. Finding 36: The site plan and conditional use permit did not include the provision for commercial propane sales. There appears to be a large tank for sales on the site. —-‘_ This tank is located at thenorth end of the site in the open space area next to the dog run as shown by the red circle on the aerial photograph below. Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP20-001) Page 10 Page 12 of 30 Finding 37: This type and size of tank require a building permit, a review and approval from Clark Cowlitz Fire Rescue, as well as bollards or some other form of barrier to protect the tank in accordance with the fire code. Staff has attached a condition requiring this tank be removed unless a site plan is pursued for the sale or resail of propane and any required review and permits are obtained. See Condition #9. Finding 38: In addition to that commercial tank, there are a number of large tanks that may not require building permits (due to size), but that nonetheless pose a safety concern. (Seethe ures below.) ' Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20—016,CUP 20-001) Page 11 Page 13 of 30  Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP20-001) Page 12 Page 14 of 30  Ground tanks ofthis size imply more than a transient occupancy because these tanks are typically delivered and filled by a commercial delivery service. As a result there is a lack of ownership by the occupant and the safety, security, and liability is unclear. Given the number of unprotected and unsecured tanks on the site, staff has signigicant concerns that may not be addressed by normal city code. Given the temporary nature of occupants, staff has attached a condition of approval requiring that propane or similar tank sizes be limited to 100 pound tanks if they site on the ground. These tanks would typically hold up to 23.6 gallons of propane and approximately up to 48—inchesin height and 18-inches in diameter. Tanks that are normally mounted inside or on the tenant vehicle are exempt from this limitation. See Condition #10. Staff finds these limitations warranted as part of the CUP since the concerns are unique to the type of use. (Per WMC 17.72.010.) Conclusion: As condition, the proposal can comply with the development standards. Criteria and Standards for Specific Conditional Uses | WMC 17.72.100 (D) Per WMC 17.72.100 (D), Recreational Vehicle Camper Parks, as a conditional use, must meet the criteria and standards regarding signs, camper space, sewer and water, open space, residences, occupancy, and State regulations listed below. Finding 39: One single-faced or double—faced wall or freestanding park identification sign is permitted. Such sign shall be a maximum of thirty-six square feet in gross area perface and may be illuminated by indirect lighting only. Additional entrance and exit signs, one per entrance/exitand two square feet in area each are permitted. Finding 40: Signs require a building permit and the existing signs did not get a permit when placed. To meet this condition, the applicant must submit for needed sign permits within 30-days ofthe approval ofthis CUP. No signs are proposed or permitted as part of this application. See Condition #17. Finding 41: There was an additional sign in the shape of a sasquatch was placed on the fence. Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, cup 20-001) Page 13 Page 15 of 30  a! .'I llIllll II I !llllllill ”Ill! "HE illllllllllll_ lllll' 4km This sign was raised by a neighbor as a safety concern because it eventually fell off, or was blown by wind, off ofthe fence and into the street. This type of logo represents a sign and requires a building permit to review how it is attached. (Ifthe operator intends to replace the sign.) Finding 42: The project meets the minimum of seven hundred fifty sq. ft. of site per camper vehicle space. Finding 43: in all cases, camper parks shall be required to be served by public sewer and water systems. Restrooms, bath, and shower facilities shall be provided and shall meet all State Department of Social and Health Services standards. This should continue to be true for the new CUP. lll'm' Finding 44: Public water and sewer are provided by the city. However, the intention was not for the 67 sites to be occupied year-round. This level of water and sewer use may warrant system or downstream improvements that were not considered with the original site plan. Long—term occupancy may warrant additional review and mitigation and the applicant would be responsible for a proportionate share of those improvements. Finding 45: Camper parks shall allocate at least twenty percent ofthe total site as usable open space or recreation area for use by the park’s patrons. The site functionally meets this requirement. Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 14 r Page 16 of 30  Finding 46: (Original Finding #60) Per WMC 17.72.100 (D)(6), no one camper unit shall occupy a camper site for more than ninety consecutive days per year. This standard shall not permit a camper to be moved off—sitefor one day or so and moved back in thereafter. The intent ofthe code is not to have the occupants move from space to space on a rotating basis to ensure that tenants can have year—round occupancy. (On the technicality that they are not on the same spot, or that they have been temporarily moved off site.) Staff is adding a condition of approval to clarify that occupancy is intended to be limited to ninety consecutive days per year, for the entire park. See Condition #11. Finding 47: The original CUP had a condition requiring reporting for compliance with WMC 17.72.100 (D)(6). This condition was not followed and there was no effort to prove compliance. In fact, staff has visually seen, and received verbal testimony that vehicles have had substantially longer occupancy on site than allowed by the code. The original condition is being revised to require weekly reporting of space occupancy. The report must contain adequate information for the daily occupants of each space, including at least the vehicle license plate number, size, and make and/or model ofthe vehicle so that staff can do spot checks and/or monitor occupancy. See Condition #12. Finding 48: Camper parks must meet all applicable state regulations and standards related to the operation and maintenance of recreational vehicle facilities. Finding 49: To demonstrate compliance with WMC 17.72.100 (D)(7), a condition of approval is added to submit proof of compliance with State regulations and standards as part ofthe annual conditional use review requirement. See Condition #3. Conclusion: As conditioned, the proposal can comply with these criteria and standards. Fire Review Finding 50: All applications must be reviewed and approved for Fire Life Safety by Clark- Cowlitz Fire Rescue (CCFR).A summary of comments: I Propane tank location shall be reviewed and approved by CCFR. o All work subject to field inspection and correction as identified at the time ofthe on-site inspection. 0 Inspection of work and acceptance testing to be scheduled directly with Clark County Fire & Rescue. 0 Where required access is restricted with a gate, provide an approved KNOX padlock. Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20»016, CUP 20-001) Page 15 Page 17 of 30  0 Where hydrants are on a fire apparatus access road, the minimum width ofthe road shall be 26 ft. for a distance of 20 ft., 10 ft. in either direction. 0 Required roadways must have signage for parking restrictions: No Parking Fire Lane. 0 Required access roadways and hydrants shall be serviceable and unobstructed prior to combustible construction. Contact CCFR for more details. A condition is added to meet all requirements of CCFR. See Condition #8. Conclusion: As conditioned, the project can comply with this standard. SEPA Review Finding 51: Staff adopted the original SEPA decision by reference. Conclusion: As conditioned, the project can comply with SEPA. Comprehensive Plan (As adopted in 2019) Land Use The land use chapter of the comprehensive plan considers the general distribution and location of land uses and the appropriate intensity and density of land uses. Table 3-1, Woodland Planning Assumptions and Targets: A target of 20 jobs/acre was set for the 2,480 acres undeveloped of undeveloped commercial land in 2016. ORIGINAL Staff Response: An average RV park offers an estimated 34 jobs per park. This job/acre ratio of .9 falls far short of 20 jobs/acre target. And while the average of 20 jobs/acre is meant to apply to the entire commercial zoning district rather than parcel by parcel, providing an estimated 4 jobs for a 3.69-acre site will bring down the jobs per acre average city»wide. This a huge under— utilization of the employment potential for the site, particularly in a thriving and growing commercial district like Belmont Loop. REVISEDSTAFF RESPONSE: The current owner was not the applicant but the sign on the window (see below) shows that in fact the office is only open 165 hours a week which is less than even one half-time employee in practical terms. Staff Repelt and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 16 Page 18 of 30  ON SITE HOURS OF OPERATlON: MONDAY 1:00 PM - 5:30 PM TUESDAY—THURSDAY 3:00 PM - 5:30 PM FRlDAY 1:00 PM . 5:30 PM Fo UTSIDE or THE OFFICE The fact that the comp plan goal is for approximately 73 jobs, the current project, in practice, should clearly be seen as not meeting the city’s comp plan. As a result, staff is advocatirga condition that should the site receive a CUP, and not follow through with complete compliance with the permit and city codes, that the city will no longer consider that this use meets the city’s zoning, CUP standards, goals, policies, or economic needs, and wants the applicant to know that no new CUP will be issued. Further non-compliance will not be tolerated and endangers the ability of this development to continue to operate in the city where it is currently located. Resuming gperation of the park by taking in new occupants after the CUP is reissued, will be seen as an acknowledgement of this fact. LU 1. The primary land use goal (LU 1) listed in the comprehensive plan is: Protect and enhance the character and long—term stability ofthe city through current standards for land development and subdivision. LU 1.10 Ensure that the character and location of land uses provides the best opportunity for economic benefit and the enjoyment and the protection of natural and cultural resources while minimizing the threat to health, safety, and welfare posed by hazards, nuisances, incompatible land uses, and environmental degradation. ORIGINAL Staff Response, LU 1 and LU 1.10: As conditioned, the proposal can meet the site design and landscaping standards required of the C—2zoning district. The open space standard was not met in the proposal, but the applicant Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 17 Page 19 of 30  may revise the site plan and meet this standard by adding usable open space and recreational area as a condition ofapproval. Neighbor comments raise a question about the low job-producing effect of this use, as well as the long—term stability, vitality and economic benefit goals noted above. Another development standard encouraged in city code is to provide commerce along the sidewalk to add to a vibrant commercial district as described in WMC 17.36.070. As discussed in Finding 15 above, only 30 ft. of the 515 ft. street frontage is dedicated to a commercial use or commercial building. The rest of the frontage is parking lot or campsites. The campsites can be considered a commercial use and a recreational use, but they do not contribute to active, vibrant, and lively commercial use along the street or sidewalk. Staff recommends revising the site plan to include more commercial use along the frontage. Converting the campsites along the frontage to food truck stalls or other mobile vending stands and providing communal dining area, open space, or public plaza near the sidewalk would help the proposal meet the land use and economic goals in the comprehensive plan. Additionally, providing for more commerce along the street frontage will increase the amount ofjob opportunities provided by the project and offer new entrepreneurial opportunity to the community. Staff recommends that the applicant propose such a revision prior to the approval of the conditional use permit so that such uses can be included in the CUP. See Section V—Staff Recommendation and Decision. The anticipated peak hour trips are low for a site of this size (19.44 PM peak hour trips for the 3.69—acre development or .27 trips per RV site) compared to surrounding businesses. The trips generated by each business on Belmont Loop help contribute to commercial activity for surrounding businesses because customers may stop at more than one business in a general area per trip. The low job—producing effect, minimal use of street frontage for commerce, and the low traffic counts for the use, does raise a question for staff as to whether the proposal can meet the land use goals and policies described in the comprehensive plan without significant additional mitigation to allay those concerns. See Condition #14. REVISEDSTAFF RESPONSE: As discussed above, the project is clearly not producing anywhere near the jobs quoted by the developer, let alone the comprehensive plan goals for employment. This fact would tend to show that the neighbors concerns were right and that the park would not be a boon for the commercial zone it is located in. Staff also has discussed how the trip generation for the project was misrepresented because the full—timeoccupancy under which the site has been operating (in violation of Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 18 Page 20 of 30  the code) is vastly different than originally proposed. However, staff recognizes that this violation is a pro and a con because the illegal occupancy of the site means that those additional trips may contribute to economic activity in the area. But at the same time, the presence of substantial and prolonged residents ofthe site when the neighboring businesses were closed, presents a whole separate concern that was raised by the neighboring land owners. As a result, the current operating conditions of the park should be seen as an overall negative for the neighbors. Compliance with the conditions of approval and city code should mitigate for this situation. Given the last few years of operationin violation ofthe CUP and city code, staff again recognizes that the site could be considered marginally compliant with code and the comprehensive plan if it meets all the conditions of approval. But staff also recognizes that operation outside ofthe CUP and city code, the park should be considered significantly non—compliant and inconsistent with the comprehensive plan. LU 1.11. Eliminate incompatible land uses through active code enforcement or available regulatory measures. ORIGINAL Staff Response: An RV Camper Park is dissimilar from the surrounding commercial uses on Belmont Loop, but it is not considered an incompatible land use in city code. Other types of lodging, such as hotels and motels are approved C-2 uses. As long as the criteria and standards for RV Camper Parks are met, this conditional use is considered compatible in the C—2zone as well. Should the RV Camper Park fail to meet the required standards while in operation, they will be subject to code enforcement action, monetary penalties, and risk losing their conditional use permit. REVISED STAFF RESPONSE: The staff again wants to emphasize that additional violations on the site can result in permit revocation under WMC 17.72.090 and may result in closure of the business. The operator received the February 2026 Notice & Order and recognized the enforcement action as warranting a new CUP to operate legally. The original analysis was a clear warning about compliance and the possibility of loosing the right to operate in the city. The fact that it took almost four years for the city to revoke the first CUP should not be interpreted in a way that the city will not pursue further enforcement actions without delay. Economic Development Chapter 5 of the Comprehensive Plan addresses goals and policies for economic development. Following are goals and policies applicable to the Belmont RV proposal and staff response. EC 1. Support a diverse and balanced local economy to ensure sustained growth, locally available commercial services, and varied employment opportunities. Staff Report and Recommendation Belmont RV (SPR 20»011, SEP 20-016, CUP 20-001) Page 19 Page 21 of 30  ORIGINAL Staff Response: An RV Park on Belmont loop would add to the diversity of commercial services and draw travelers and customers to Belmont Loop. However, the proposal will fall far short of the 20 jobs/acre goal set in the land use chapter of the comprehensive plan. The low trip generation ofthe use could also raise questions about whether it can contribute vitality to the commercial character ofthe neighborhood and to the commercial services used by Woodland residents. REVISED STAFF RESPONSE: Again, the fact that this site has not operated in accordance with its approvals, there are pros and cons from the use. The site has full occupancy which could be a positive but those conditions were not contemplated properly under the code and permits. Especially since the council has made strong statements about the fact that the city does not want residential units in any zone within the city except for in the downtown 01 district. At the same time, there would be similar or better economic impacts from travelers who were the intended customers ofthe Highway Commercial zone. Staff current opinion is reflected in its current warnings to the applicant that the use was marginal to begin with and that only operation as originally intended, would justify the staff’s initial trust in the proposal. Failure to comply with code and permit conditions will be seen as justification for not finding the use an appropriate use for the site (as argued by the neighbors in the original planning process). EC 1.2. Develop Woodland’s position as the commercial center serving southern Cowlitz County and the recreation trade ofthe upper Lewis River and Mount St. Helens area. ORIGINAL Staff Response: The proposal for an RV campground would contribute to the recreation trade in the surrounding area. REVISEDSTAFF RESPONSE: This policy would further support the idea that long—term occupancy of the use is not consistent with the comp plan. EC 1.5. Use the advantage of freeway visibility to establish the city as a traveler/tourist service center. ORIGINAL Staff Response: The proposal is near an [—5exit and would be visible with a freestanding pole sign. The RV camper park adds to traveler/tourist services in Woodland. Occupancy of the campsites is limited to 90 days; the proposal is for a recreational campground. However, concerns have been raised about long-term occupants in this RV park. The idea that the use is taking advantage of its location along l—5would seem to be inconsistent with long—term Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 20 Page 22 of 30  tenancy. Placing clear and definitive limits on park occupancy (conditions #13 and #21) could mitigate this concern. REVISEDSTAFF RESPONSE: This policy would only be supported with short term, quick turn—over, and ready vacancy, to meet the needs of the target customers on I—5to take advantage of. Even 90—dayoccupancies by repeat customers would not seem consistent with this policy. EC 3.6. Maintain active and cooperative partnership between the city, business and property owners, civic groups, and citizens to promote successful business district redevelopment, including downtown. ORIGINAL Staff Response: The proposal for an RV campground received ten letters expressing concern and objection (as of 3/22/21) from surrounding property owners. This response suggests that the community could benefit from creating a partnership between the city and a new civic group, a Belmont Loop business district for example. The proposed RV Park could also enter into a CC&R relationship with surrounding businesses to allow for cooperative support for all commercial activities in the Belmont Loop area. Through collaborating on a long- range plan for Belmont Loop, new goals, a new zone and permitted use list, and new development standards could be developed based on a collective vision for Belmont Loop. For this current proposal, staff recommends that applicants hold a neighborhood meeting with the surrounding business owners to gather feedback to incorporate as possible into the project design. See Condition #26. See Section V — StaffRecommendation and Decision. REVISED STAFF RESPONSE: In retrospect, staff’s overly optimistic view ofthe proposal might have been naive and the subsequent several years of operating in violation ofthe permit and codes was proofthat the neighbors were right. The fact that the park did not enter into a cooperative relationship with neighbors and operates in violation to this day, shows that the project is not appropriate for this location if it cannot operate in compliance with its permits and city code. As conditioned, the forfeiture if the legal use ofthe site for this use if it can’t meet those conditions, is in staff opinion, warranted. EC 3.6. Cluster commercial uses near intersections of major and/or secondary arterials or adjacent to existing commercial land uses. ORIGINAL Staff Response: The proposal is located near a major arterial and the RVs will have easy access from Exit 22. Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, cup 20-001) Page 21 Page 23 of 30  REVISED STAFF RESPONSE: This policy is still consistent because the site is fixed. The proposed use is consistent with this policy provided it operates as intended (to pull economic activity off of I—S). EC 3.7. Develop areas classified for commercial use on the Land Use Plan Map before other areas are reclassified for commercial use. ORIGINAL Staff Response: The land is classified as highway commercial. REVISED STAFF RESPONSE: This project has no impact on this policy. EC 3.8. Encourage downtown revitalization by supporting the expansion of commercial and multifamily residential use. ORIGINAL Staff Response: While the RV camper parks is not a residential development (stays are limited to 90 days by the conditional use permit), it can contribute to a mix of uses and increase of customer traffic to Belmont Loop by introducing short—term camping stays. Travelers staying at the RV park can walk to shop and services along Belmont Loop. REVISED STAFF RESPONSE: No change in opinion but that is based on how the park is operated. Finding 52: Ifthe project operates consistent with the conditions of approval and city code, the staff generally finds that one more chance to operate the use as permitted would be consistent with comp plan, but non—compliance with the conditions and code would demonstrate that the use is not consistent with the comp plan. Any need to significantly modify the CUP or proposed conditions should also be seen as a way to make it compliant, which in itself might be a recognition that the use is not appropriate for the site. Conditional Uses — Conditions of Approval l WMC 17.72.060 Finding 53: Per WMC 17.72.050, the Hearing Examiner shall be guided by the following criteria in granting a conditional use permit: A. The proposed use will not be materially detrimental to the public welfare or injurious to the property or improvements in the vicinity of the proposed use or in the district in which the subject property is situated. Staff Response: An RV camper park is not necessarily detrimental to public welfare or injurious to property in the vicinity; however, the City has made the decision to prohibit these uses in commercial districts west of l—5.This shows Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 22 Page 24 of 30 that the community as a whole does have some concern. (Per WMC 17.36.030 (3), recreational vehicle camper parks are only allowed as a conditional use in the C-2 zone when located East of Interstate 5). The operator had an opportunity to demonstrate that the use could be operated and maintained in a manner that will prevent the worst potential elements to dominate the character ofthe use. However, history has shown that if not operated consistent with code, the use could be detrimental. The safety concerns around propane tanks, the lack of screening for the garbage containers, accumulates amounts of outside storage, and the long— term occupancy that dominates the use will change the character of the park and neighborhood, if responsible measures are not taken to prevent those actions. Several nearby property and business owners are concerned about crime stemming from the RV Park. Crime is not a given characteristic of an RV camper park; however, the conditional use permit must be renewed annually. Frequent crime reports involving the RV camper park could lead to denial of permit renewal. The proposed use shall meet or exceed the performance standards that are required in the district in which the subject property is situated. Staff Response: As conditioned, the proposal must meet the condition of approval and performance standards and site design standards from the code. Otherwise, the operation can be subject to permit revocation per code. Staff finds the applicant should be given one more chance to show the use can be operated in a manner that meets code. The proposed development shall be compatible generally with the surrounding land uses in terms of traffic and pedestrian circulation, building and site design. Staff Response: The development is generally compatible with the surrounding land uses because it is a commercial use. However, the use would have to be operated as permitted and not in a way that functions as a residential use. The presence of long-term occupants would make it residential in nature and was a use/activity the city has specifically prohibited in the C—2zone. Given the community’s concerns demonstrated in public comment, the applicant will need to be able to convincingly argue that the site will retain its commercial character and not evolve into a residential—style use pattern. The applicant must demonstrate WEEKLYthat occupancy of each site is being limited to 90 days. See Conditions #12. Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 23 Page 25 of 30  D. The proposed use shall be in keeping with the goals and policies of the Woodland comprehensive plan. Staff Response: For more detail, see the staff responses in the Comprehensive Plan section above that the proposal under—utilizes the site and is very marginal in its ability to meet the comp plan goals and policies. Accordingly, staff has clearly stated that this project would not meet those goals and policies if it is operated with occupancies longer than allowed by code or if it violates conditions of approval and the CUP. Given public response to the original CUP from several neighboring property owners and business owners, the proposal may not match the community’s vision for Belmont Loop. That seems to be borne out by the way the violation has been operated since it opened. The only counter argument to these concerns would be the operation of the use in accordance with the code and permit conditions. E. All measures have been taken to minimize the possible adverse impacts, which the proposed use may have on the area in which it is located. Staff Response: For the original CUP, crime was the most often cited potential adverse impact that neighbors had. The Police Chief indicated that he has noted no disproportionate increase in crime at the park, to his knowledge. This does not mean that the use is crime free, but that at this time there is no need for additional mitigation measures be added to address the neighbors’ concerns. (This criterion says ”all measures have been taken to minimize possible adverse impacts”) However, occupancy of the site for more than 90-days does have other potential adverse impacts on other services like schools, roads, water, sewer, parks, and fire/medicalresponses. Because these impacts are not mitigated for, they can only be minimized by complying with the 90—dayoccupancy limit. The applicant may need to revise their project and propose mitigation to be able to truly meet that criteria if another option is viable or occupancy is otherwise extended. Finding 54: Per WMC 17.72.060, the Hearing Examiner may impose conditions of approval which are found necessary to ensure the use is compatible with other uses in the vicinity. These conditions may include, but are not limited to the following: A. Limiting the hours, days, place, and manner of operation; B. Requiring design features, which minimize environmental impacts such as, noise, vibration, air pollution, glare, odor, and dust; C. Requiring additional setback areas, lot area, or lot depth or width; D. Limiting the building height, size or lot coverage, or location on the site; Staff Report and Recommendation Belmont RV (SPR 207011, SEP 20-016, CUP 20001) Page 24 Page 26 of 30  E. Designating the size, number, location, and design of vehicle access points; F. Requiring street right—of—way to be dedicated and the street to be improved; 6. Requiring landscaping, screening, drainage and surfacing of parking and loading areas; H. Limiting the number, site location, height, and lighting of signs; I. Limiting or setting standards for the location and intensity of outdoor lighting; J. Requiring berming, screening or landscaping and the establishment of standards for their installation and maintenance; K. Requiring and designating the size, height, location, and materials for fences; L. Requiring the protection and preservation of existing trees, soils, vegetation, watercourses, habitat areas, and drainage areas. Staff Response: Conditions of approval have been revised as discussed above and documented below. Staff recommends that the examiner adopt the conditions below as a way to ensure that the community is protected from unmitigated impacts and the intent and letter ofthe City’s code is followed. Staff further supports the Examiner using his best professional judgment from his years of experience, to formulate any additional conditions, or in modifying/clarifying the attached conditions, that they feel will increase clarity and effectiveness ofthe CUP permitting process. Conclusion: As conditioned, the project can comply with the criteria, standards, and requirements for Recreational Vehicle Camper Parks. V. STAFF RECOMMENDATION & DECISION Based on the criteria and standards outlined in Woodland Municipal Code (WMC), the City of Woodland's Development Review Committee (DRC) recommends APPROVED WITH CONDITIONS. See Section VIfor recommended conditions of approval. The city hereby adopts by reference the ODNS adopted as part ofthe original review (SEP —20— 001) as the lead agency for the proposal. An environmental impact statement (EIS)is not required under RCW 43.21C.030(2)(c). This decision was made after review of a completed environmental checklist and other information on file with the lead agency. This information is available to the public on request. This DNS was issued after using the optional DNS process in WAC 197-11-355. There is no further comment period on the DNS. VI. RECOMMENDEDCONDITIONSOF APPROVAL 1) Comply with all conditions of approval for CUP—ZO—OOI,SEP—20—016, and SPR—ZO—Oll) as expressed in the Examiner's Final Order issued May 4‘hand upheld by the City Council upon appeal (APL-2021-001). Staff Report and Recommendation Belmont RV (SPR 20011, SE? 20~016, CUP 20-001) Page 25 Page 27 of 30 2) Applicant must submit materials demonstrating compliance with permit requirements for conditional use review to the Community Development Director by March 15‘, every year, to continue operating under the conditional use permit. This condition will be effective starting in 2027 and the date is intended to give the operator 3) Submit evidence of meeting State Department of Social and Health Services Standards as necessary, with each annual CUP review. 4) To demonstrate compliance with WMC 17.72.100 (D)(6), submit records of vehicle license numbers and occupancy dates for each vehicle as part of the annual conditional use review requirement. 5) The applicant is required to replant the site in accordance with the approved landscaping plan and ensure survival of the plants on an ongoing basis in accordance with WMC 17.36.120 requiring neat and orderly maintenance of the property and landscaping. 6) Within 60—daysof issuance ofthe Examiner’s final order for this application, the applicant shall submit for a building permit for the garbage and recycling enclosure that meet site design standards for screening. It is recommended to discuss the enclosure size and location with Waste Control to determine if the enclosure design and location is serviceable and if the garbage and recycling receptacles needed to serve all the RV sites will fit inside. This structure must be constructed within 6—monthsof the issuance ofthe final order. 7) Within 30-days of issuance of the Examiner’s final order for this application, the applicant shall submit building plans and elevations for all signs and comply with the standards of WMC 17.52. 8) Address all requirements of Clark County Fire and Rescues and submit revised plans as requested. 9) The commercial propane tank as discussed should be permitted through a site plan review and building permit, or it shall be removed permanently. The removal should occur within 14—daysof the hearing, or, as an alternative, placement of barriers can be placed for the protection of the tank ask it goes through the site plan review process. Building permits for permanent placement of the tank should be submitted for concurrent review of the Type 1 site plan. 10) For propane tanks on the site which are associated with RV spaces, tank sizes shall be limited to IOU-pound tanks or smaller if they are not permanently affixed to the vehicle. Clark—Cowlitz Fire Rescue staff will be tasked with determining whether a tank is affixed to a vehicle in a safe manner. Tanks that sit on the ground will also be required to be clearly marked, secured to prevent falling over, and protected from being hit by vehicles. Examples of protective measures can be reflective tape on the tank, straps, bands, secured ropes or chains, and traffic cones or pylons, or a similar durable means of marking. City staff and Clark—Cowlitz Fire Rescue staff will also be tasked with using their best professional judgement in making a determination whether the spirit of this condition is met. 11) Per WMC 17.72.100(D)(6) limits occupancy to 90-days in a calendar year. The historical non—compliance of the project warrants clarification of the CUP condition, to say that occupancy ofthe park by vehicles is limited 90-days in any 365-day period. This includes Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20001) Page 26 Page 28 of 30  any and all spaces in the park and a vehicle cannot return to the park within the 365 days of the first date of occupancy, if it has spent more than 90 days at the park. 12) The applicant must provide occupancy data for the park on a weekly basis. This report should be provided in either an Excel or .pdf format, and must include enough information for the staffto be able to verify vehicle occupancy days and dates. The reporting information should at a minimum include space numbers, license plates, size, and make and/or model. The information for the towing or towed vehicle can be included but will not substitute for the recreation vehicle identification itself. This is to ensure that if such a RV is accompanied by multiple secondary, towing, or towed vehicle identifications can be used to extend occupancy periods. 'vu. APPEALPROCEDURE As per WMC 19.08.020 and 19.08.030, the decision of the Hearing Examiner may be appealed to City Council within 14 days ofthe date the decision is issued. Per WMC 17.81.150 the appeal shall state grounds for appeal and be submitted in writing along with payment ofthe appeal fee to the Community Development Department. Decisions are due by 5:00 PM by email or at the location indicated below. Staff Contact: Travis Goddard, Community Development Director City of Woodland PO. Box 9 230 Davidson Ave Woodland, WA 98661 goddardt@ci.woodland.wa.us VIII. NEXTSTEPS Ifthere is no appeal to the decision, the applicant may move forward to develop the site. 0 If additional engineering is required, the final civil plans addressing the conditions above shall be submitted. Include Woodland standard details for water, sewer, erosion control, etc. as required to support the civil design when you submit drawings for final civil approval. The details can be found at www.ci.woodland.wa.us/departments/public— works/standards.php. 0 Pay any outstanding professional consulting services per Woodland Municipal Code and the adopted fee schedule. 0 Submit for building, grading, and sign permits as necessary. 0 Schedule a pre—construction meeting, if needed, before beginning any construction activities. Contact public works at 360—225—7999to schedule. 0 install all required landscaping and irrigation prior to applying for final occupancy or within 30-days ofthe CUP issuance. Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 27 Page 29 of 30  o If necessary, submit three copies of full—sizedand one copy of reduced size (11” x 17”) as-built drawings. In addition, submit a CD/thumb drive containing the as—builtdrawings in AutoCAD and pdf formats prior to applying for final occupancy. Date: 4/17/2026 Signature: Travis Godard, Director cc: Applicant Planning Commission Property Owner City Council City Engineer Mayor Parties of Record File Department Heads Counter Copy Building Official Website Fire Marshal Attachments: (Found on the project page at: https://www.ci.woodland.wa.us/commdev/proiect/1880-belmont-loop-belmont-loop-rv) City Council Appeal Decision Hearing Examiner Response to New Evidence for CUP-20-001 Hearing Examiner Final Decision for CUP-20-001 Notice & Order dated February 27, 2026 Penalty Assessment Letter dated February 27, 2026 Staff Report and Recommendation Belmont RV (SPR 20-011, SEP 20-016, CUP 20-001) Page 28 WPOPP Page 30 of 30