619 Division Street
Port Orchard, Washington 98366
SUBJECT: Opposition To The 2016 Kitsap County Comprehensive Plan Update
KITSAP ALLIANCE OF PROPERTY OWNERS (KAPO) objects to the 2016 Kitsap County Comprehensive Plan for the following reasons:
- Lack of an interactive plan development process with citizens of the county.
- Issuance of drafts of the plan documents that are undated, hard to find on the County’s website and improperly advertised.
- Inclusion of County-wide Planning Policies that have not had public scrutiny as in no prior discussion or debate about the merits of the policies.
- Inclusion of the Puget Sound Regional Council’s Vision 2040 Plan policies and provisions and Transportation 2040 Plan policies and provisions.
- Creation of an “Urban Center’ classification of Silverdale without prior discussion with the County residents at large of the implications for such classification on the rest of Kitsap County.
- Creation of Title 17 (Zoning Ordinance) amendments that have had no vetting with the public other than introductory categories.
- Refinement I update to the “Reasonable Measures” Appendix E of the Buildable Lands Report without proper notice to the citizens of Kitsap County or allowance for timely review and discussion prior to Public hearing consideration by the Kitsap County Planning Commission.
- Formula based planning that is in fact “growth control” planning and a “top down” process designed by the arrogance of government to minimize the individual citizen.
- Lack of an interactive Plan Development process:
Back in October of 2014, the County via the Department of Community Development began the process of updating the 2006/2012 Comprehensive Plan. It started with a series of three ”open houses” to introduce the plan update process. Those open houses were followed by a series of questions posed about the comprehensive plan sent to individual e-mail boxes of those who had signed up to receive them or visited the County’s website and found a question to which they might like to respond.
Apparently there were a lot of responses to those questions even though quite a few of them had to be placed into the category of “DUMB.” Meaning a response would also be without any merit. Even so there were quite a few people who tried to answer those questions ……………… but to what end? Is there any evidence that any of those citizen submittals had any impact on how the plan might be constructed? Unless the County can show otherwise, that form of citizen participation is nothing more or less documentation that citizens of the county tried to interact with staff to express their views.
Somewhere along the line Kitsap County forgot what meaningful citizen participation looks like. They even forgot what was done in 2006 when the 1998 Comprehensive Plan was updated. Then there were citizen groups formed wherein involved citizens could discuss the merits of plan proposals. Even though a few dissidents did not like what the citizens wanted and appealed the plan, there was the kind of interaction with citizens that could lead to a plan the majority of the County residents could support. There has been no such offer of public involvement that even compares to the 2006 planning process. The net result is ……….. citizens of the County have been excluded from the plan development process.
- Issuance of Plan Documents – undated, improperly advertised and posted on the County’s website in a manner that makes them hard to find.
Two examples of the above statement involve the “Reasonable Measures” document that was posted on the County’s website on April 25th in the Planning Commission’s portion of the website and in the appendix to the Buildable Lands Report. Even if one knew in advance that the document was going to be made available to the public, the posting on the website was obscure at best. As problematic as that fact, what is worse, there was virtually no prior review of these measures other than at the Kitsap County Home Builder’s Development Council.
What is true of the ”Reasonable Measures” document is even more problematic for the Comprehensive Plan document itself. Prior to April 29th the public had notice only for the April 6th draft of the plan that they could review. On April 29th, that draft of the plan was updated and published only on the Planning Commission’s section of the Department of Community Development’s website and not on the section of DCD’s website where one finds all other documents pertinent to the Comprehensive plan. To make matters worse, the “revised” document published on April 29th bears no date and did not until May 3rd bear any notations regarding what was changed.
If the public is confused, uninformed and ill prepared to mabe comment at the nth hour, how can this be characterized as in any way an honest public involvement process? And can any person allotted only three minutes to testify do any more than object to the Comprehensive Plan?
Essentially there was no prior public exposure of either documents before the County Planning Commission began its review last Tuesday May 3rd and Thursday May 5th.
The public is allowed to witness discussion items, but not ask questions or even make suggestions. And when testimony is taken on May 10th comments are limited to what can be presented in three (3) minutes. The lack of process involving the citizens of the County is nothing but a SHAM! Never mind the fact that these measures have a significant impact on the investment people have in their property and their right to use their property as provided in both the State and Federal Constitutions.
- Inclusion of County-Wide Planning Policies without prior public review.
The last time anyone in Kitsap County had the opportunity to examine the County Wide Planning Policies was 2011. Kitsap County adopted the amendments proposed in 2010. Members of the public had a chance to review the then proposed amendments and make comment, but no opportunity to engage the County or its staff in any sort of dialog. According to the Growth Management Hearings Board, members of the public were to get their “bite at the apple” in the context of a Comprehensive Plan update process.
Problem is Kitsap County continues to ignore public input on these policies but has included them by reference in the Comprehensive Plan. The long and the short of these policies is that they are poorly crafted, full of unattainable platitudes and are inappropriate to be used or even referenced in Kitsap County’s Comprehensive Plan.
- Inclusion of Puget Sound Regional Council’s Vision 2040 and Transportation 2040 plan provisions in Kitsap County’s 2016 Plan Update.
Other than as they are referenced in the Comprehensive Plan document and as that plan is under consideration by the County, there has been no public exposure to the provisions of Vision 2040 or Transportation 2040s. Virtually no one in Kitsap County other than staff or elected officials knows what is in those documents or how they are now impacting or will impact the citizens of this County.
Their inclusion in Kitsap County’s 2016 Comprehensive Plan update is nothing less than an example of “top down planning” leading to “growth control.” Also, the inclusion of these plan provisions in Kitsap County’s Comprehensive Plan is a demonstration of the arrogance of Kitsap County officials to think that citizens should have no say about what is included in the Comprehensive Plan.
- Creation of the Silverdale “Urban Center” without public input to satisfy a funding criteria not found in the Growth Management Act (GMA).
While it may be evident that Silverdale is in many ways the hub of Kitsap County, what is not evident is that in order for it to be classified as an “Urban Center,” certain criteria must be satisfied to allow the Puget Sound Regional Council (PSRC) to funnel Federal Department of Transportation dollars to Kitsap County. One such criteria is that Kitsap County must increase the density of development in Silverdale so that it can better be served by mass transit.
The decision of the County to comply with PSRC’s criteria comes at a price not well understood by the citizens of the County and likely even the public officials. One price is the consequential reduction in size of the Silverdale UGA as urban density is going to be sucked up in high rise development. A second consequence is no assessment has been made of the cost to Kitsap County or even to the private sector developers who must fund the infrastructure and added costs of building up instead of out. And a fundamental flaw in this decision is that people living in Silverdale, will not find work in Silverdale, but have to travel elsewhere in Kitsap County or the Puget Sound Region to find employment. These are locations not centralized and therefore not conducive to being served by mass transit.
BUT SINCE THE AVERAGE CITIZEN IN KITSAP COUNTY DOES NOT KNOW what is going on the County seems to think their rationale is best.
- Creation of Title 17 Amendments without prior vetting.
For the last two – three years the Department of Community Development staff has tried to start a process whereby needed amendments to the Zoning Ordinance could be drafted and considered by the public. Now two and a half years later in the process there is finally a draft of the proposed amendments. Prior to Planning Commission study session consideration, the first week of May, the public has had no change to engage staff in any dialog about the provisions of such amendments.
In mid-April the only thing available for public review was an outline of the amendments DCD staff believed had to be made in order to implement provisions of the 2016 Comprehensive Plan update. Noting that time was short, even members of the professional community were promised that once the Plan was adopted in June, there would be time to undertake a more thorough review of what the County would adopt in June. Faulty reasoning at best, but clearly a “dis” to people who have to work with the ordinance day in and day out.
- Refinement I Update of the “Reasonable Measures” Appendix E of the Buildable Lands Analysis document.
The lack of notice issue has already been addressed. The point of emphasis here is to note that contrary to the apparent assumption of DCD staff, a prior and proper vetting of these measures, might yield ones that may actually work as an incentive for people to locate in urban verses rural areas. As a construct that the County can level a “club” to enforce growth controls, those officials that may believe that, will find to their dismay that their measures do not work and that enough people dissatisfied with such measures will “throw the bums out” or initiate costly appeals.
- Formula based planning that is in fad “growth control” planning and a “top down, process designed by the arrogance of government to minimize the individual citizen.
In late January and early February of this year, the DCD staff issued what they termed the “preferred staff plan alternative.” When the Board of County Commissioners held public hearings on this proposal also in February, an explanation was proffered by DCD staff that the UGA areas were being sized according to a formula worked out in the Buildable Lands Report. Therefore, the consequences as to how that formula was worked some UGAs could be increased in size and others had to shrink.
No part of that formula process could involve the public unless there was an overt objection such as in the case of the proposal for the South Bethel Corridor. Even Cities were not consulted as to their wishes, rather they were informed as to what was going to happen and in fact has.
A formula based planning process and resulting comprehensive plan is the anti-thesis to a citizen involvement program and the resulting plan placates only the decision makers and not the public.
For the foregoing reasons KITAP ALLIANCE OF PROPERTY OWNERS has no choice but to consider plan appeal strategies once the plan is adopted. We took on that assignment when the Critical Areas Ordinance was adopted in 2005 and in the years following, both KAPO and the County spent a lot of money working though that appeals process and it appears that we will have to go that same route.
Alternatively, KItsap County could delay the adoption of the Comprehensive Plan in June to a later date as Bainbridge Island has done. Perhaps even there might be some dialog about the plans provisions. But alas the “train is about to arrive at the station” and what the people of Kitsap County might want appears to be unimportant.
Respectfully submitted on behalf of the KITSAP ALLIANCE OF PROPERTY OWNERS.
William M. Palmer, President
KITSAP ALLIANCE OF PROPERTY OWNERS