| Comprehensive Plan Update Comments | |
The proposed Policy 8A-5.2 establishes the sequence of remedies for increased capacity demands on the Guemes Island Ferry from “(a) encouraging car-pooling and walk-on passengers; (b) increasing the frequency of ferry runs based on demand; (c) considering additional ferry capacity if the aforementioned procedures fail to accommodate demand…” As proposed, it includes an additional provision “(d) adding additional runs outside the current schedule” whether or not other the other measures are in place. Goal A4 of this chapter establishes an “…ongoing program of community planning to address the specific issues and concerns of Skagit County communities.” The communities included in this program are Big Lake, Birdsview, Day Creek, and Upper Samish Valley. Guemes Island has been specifically eliminated from this list despite the fact that the County has adopted a resolution supporting the development of a sub area plan for the island. |
April 18, 2006 Skagit County Planning
and Development Services Subject: Skagit County Comprehensive Plan Update Thank you for the opportunity to comment on the proposed Comprehensive Plan and code amendments. I have reviewed these documents and find that generally they achieve the goal of updating, clarifying, and streamlining the documents. However, there are several proposals that concern me, including the application of the LAMIRD provision and some policies that are discussed below. In addition, I am very disappointed that no attempt was made to show where specific changes were made in the comprehensive plan policies. Without highlighting the changes, the public must go through the tedious process of comparing the old and the new through a line by line review. Clearly, this is inconsistent with the County’s expressed desire to promote public involvement. LAMIRDS As I discussed in my comments at the March 21 hearing, I am concerned about the application of the LAMIRD policy to the zoning of a 280 acre area on Guemes Island north of Holiday Hideaway that flanks either side of Square Harbor Road (case CPA05-21). This site fails to meet any of the criteria set forth in Policy 3B-1.4 a-d. It is beyond “the logical outer boundary of the existing area or use”. In this case, the “existing area” is the Holiday Hideaway development, an established neighborhood primarily composed of _ acre lots. If developed at the Rural Intermediate (RI) density, the Square Harbor area would allow a new pattern of low-density sprawl. Further, this area was undeveloped in 1990 and is still a substantially undeveloped forest. In addition to the lack of development there, it is a poor choice for intensive construction since it has little water (because it is largely underlain by rock). (It was intended to receive water via the Square Harbor Water Company that serviced Holiday Hideaway, but the water company has since gone out of business and conveyed the system to the Holiday Hideaway Association. The emerging Association policy is to improve service to its current customers, rather than expand water service to new areas.) To underscore the fact that this is not the logical outer boundary of the Holiday Hideaway neighborhood, the Square Harbor area is substantially in a different watershed containing a number of critical areas, including several eagle nest sites, wetlands, a stream, and steep and unstable slopes. The private roads on these slopes are not to standard and have poor accessibility for emergency services. All of these characteristics, as well as the fact that the predominant platting pattern is 5 and 10 acre lots, similar to adjacent Rural Reserve (RRv) zoned areas, makes the area a logical candidate for the RRv zone. Maintaining the RI zone there would be an unfortunate precedent for the island and elsewhere in the county. If the RI zone could be justified there, it could also be justified across much of the interior of the island that is adjacent to RI but is now zoned RRv, and platted in 5 and 10 acre parcels. If that were to occur, devastating impacts to the sole source aquifer and rural character of the island would be likely. Application of the Rural Commercial (RC) zone to the parcel involved in SC05-02 based on the LAMIRD policy is inappropriate as well. This site is currently residential and all adjacent is property is either zoned RI or a road. Under the circumstances, I view the rezone of this site to RC as a spot zone. Transportation Policy The proposed Policy 8A-5.2 establishes the sequence of remedies for increased capacity demands on the Guemes Island Ferry from “(a) encouraging car-pooling and walk-on passengers; (b) increasing the frequency of ferry runs based on demand; (c) considering additional ferry capacity if the aforementioned procedures fail to accommodate demand…” As proposed, it includes an additional provision “(d) adding additional runs outside the current schedule” whether or not other the other measures are in place. I also note that the current Plan Policy 9A-8.7, which recommends that the Regional Transportation Planning Organization establish level of service standards for ferry service, has been deleted. When this omission is coupled with the new subsection (d) of policy 8A-5.2, it appears to be a clear attempt to support the extension of ferry service hours in a manner that is contrary to what the Growth Management Act views as otherwise logical approaches to excess capacity cited in (a)-(c) of this policy. Increasing vehicle access to the island by extending mid-week ferry service hours to commuter traffic would induce growth here in the same way as substantially increasing the capacity of a road. Adding subsection (d) to policy 8A-5.2 also conflicts with several other policies that are rooted in the GMA, including the following:
Policy 8A-2.1 establishes level of service standards for County roads. LOS standards are the predecessor of the design standards for roads and according to policy 8A-2.3 they distinguish between “… urban and rural design standards for structures, roads, and utility systems constructed either by the county or other public or private sponsors. These standards shall reflect the character of the communities as defined in the Land Use, Rural, and Community Planning Elements.” Why then is the Guemes Ferry excluded from receiving level of service standards and where is the policy that would ensure that design standards for ferry service “…reflect the character of the communities as defined in the Land Use, Rural, and Community Planning Elements”? Without level of service and design standards commensurate with rural development on the island and an environmental analysis, any policy supporting extended ferry hours is premature. The internal conflicts in the transportation policies that are raised by the addition of subsection (d) to policy 8A-5.2 castes a troubling shadow over the plan policies in general and raise questions about the ability of the County to implement them as intended. I strongly urge the following steps:
Economic Development An additional policy is needed under Goal A7. This Goal supports economic development by providing adequate transportation for moving products. The new policy should state that the scheduling of ferry maintenance or repairs should be avoided during the fall harvest season. Island agricultural producers were unable to move their product when the ferry was out of service during the 2005 harvest season. Environment Element Policy 5A-1.3.e. addresses the criteria for classifying Fish and Wildlife Habitat Conservation Areas. The criteria should include areas where species of concern or threatened or endangered species on state or federal lists are documented. Also bodies of water that are planted with game fish should not be HCAs since planted fish are either hatchery origin fish that dilute the genetic integrity of wild stocks or nonnative species. The introduction to the Air Quality section (page 19) includes several sentences committing the County to cooperating with the Northwest Air Pollution Authority to maintain air quality. The commitments in this paragraph should be stated as a goal and policies like any other plan issue. Plan Implementation Goal A4 of this chapter establishes an “…ongoing program of community planning to address the specific issues and concerns of Skagit County communities.” The communities included in this program are Big Lake, Birdsview, Day Creek, and Upper Samish Valley. Guemes Island has been specifically eliminated from this list despite the fact that the County has adopted a resolution supporting the development of a sub area plan for the island. GIPAC and the Guemes Island property owners are now in the middle of preparing sub area plan, having only recently received grant support to complete it. Guemes Island should continue to be included as a sub area of the County at least until a plan for the island has been adopted. Thank you again for the opportunity to comment. I look forward to improvements in the next version. Sincerely, Roz Glasser CC: Ellen Grey, Futurewise |
Roz Glasser is a member of the Guemes Island Planning Advisory Committee For further information contact Roz at (360) 588-0160 or rozglasser@juno.com.
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