KAPO’s Submission to the Planning Commission on the Critical Ares Ordinance Update

KAPO Testimony to the Kitsap County Planning Commission on the Critical Ares Ordinance dated 2 May 2017   Ltr-KAPO to PlanComsn 5-2-17

Our testimony should be influential in what is included in an updated CAO, if any changes in the 2005 adopted Ordinance are to be made, but so far there is no indication it has or will. Thus, KAPO concludes the ordinance as presently drafted is vulnerable in an appeal. If our assessment is correct, Kitsap County will be spending the public’s money to rectify issues after the fact that could have been addressed in the drafting process or at the very least in the public hearing consideration process. Based on appearances, the Draft CAO Update is nothing more than proposed legislation for the sake of adopting more restrictive rules. So far, no justification has been presented by DCD staff for:

a.) what the values and functions are of so-called Critical Areas,
b.) what measures, if any, are necessary to protect those values and functions,
c.) what consequences redound to the County’s citizens if those undefined values and functions are somehow compromised,
d.) what data has been collected to demonstrate a problem exists that justifies regulatory measures and finally
e.) what is the minimum necessary to address the issues presented in the analysis that documents or documented a problem. Clearly the “problem” has not been defined and yet draconian rules (even more so than found in the 2005 Cao) are being proposed to supposedly solve a problem that may not in fact exist.

KAPO remains unalterably opposed to this proposed Draft CAO Update or any and all other regulations proposed for regulation sake.



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