Attachments. Attached find the response we received in our request to obtain the Kitsap County Realtors email and the email letter that basically recommends the Commissioners reject the Illahee Community Plan.
The Battle Has Begun. We heard this group spoke in opposition to the Plan at the County Commissioners’ meeting on Monday evening, and again at the Planning Commission meeting on Tuesday evening.
A Second Letter. We also heard there was a second letter received from them that we will try to obtain and pass on.
More Information Coming. We are trying to get more information and will pass it on as it comes in.
One Last Comment. We have been told by some who are aware of this group of people, that once they target something or someone, that the targeted person or group is in for a big fight.
Illahee Has Been Targeted!!! They went on to say that based on what they heard at Monday and Tuesday’s meetings that Illahee is apparently their target and the community better get ready for a fight if they want to have a community plan for Illahee.
———- Forwarded message ———-
From: Katrina Knutson
You made a public disclosure request for the email. As a government employee, I am required to give you information I have, as it is a public document.
October 3, 2008
Board of County Commissioners
County Administration Building
619 Division Street
Port Orchard, Washington 98366
RE: Illahee Community Plan
Several issues have surfaced in our review of the Illahee Community Plan that would appear to require more work before the plan is adopted. Before we address our concerns, we wish to complement the people of the Illahee community area for their hard work and commitment spanning two years to formulate the plan. We also praise the Department of Community Development staff planners for their efforts as well because it is indeed a time consuming task to prepare a comprehensive plan for public review and final approval.
Although a lot of time, commitment, and work have been expended in the development of the plan, there are some oversights that need to be addressed before the proposal is ready for adoption. Our concerns are as follows:
Need for this Sub-Area Plan. The Growth Management Act (GMA) provides for the option of Sub-Area Comprehensive Plans, but we question whether the County has given any pre-thought to how many Sub-Area Comprehensive Plans may be generated? Already there is the Kingston Plan, the Port Blakely Plan, the Keyport Plan, and the McCormick Woods / ULID No. 6 Plan. Besides these sub-area plans, there are the LAMRIDs for Manchester, George’s Corner, Suquamish, and Indianola. With each plan comes an individual set of zoning rules to govern land use in these individual areas of the County.
In a period of sixteen years, we have gone from a county with one set of rules governing land use in a Zoning Ordinance with about 78 pages to our present code which has quadrupled in size. Our new present zoning ordinance is difficult to comprehend and has complicated our permit approval process. Those complications and added regulations have increased the need for staff to administer it. So the real question is whether the County afford to keep setting up sub-area plans for each small community within the County? We conclude there is no need for another sub-area plan with its own set of rules.
Public Participation. One of the problems with sub-area plans is the limited opportunity for public participation. There are typically months and months of work on the part of a small group of people and a substantial commitment of DCD staff time, yet people across the County have a vested interest in what happens in each sub-area. The county-wide citizenry does not get a chance to review any of the work in progress until it is packaged for public hearing consideration. Then it is almost too late for substantive questions and challenges to the plan.
Planning Area Boundary. Other than discussion about two adjustments to the planning area boundary, no rationale was presented to justify the planning area boundary shown in Figure 2.1. The descriptions of the history of the Illahee area and the “Visions for the Illahee Community” paint the picture that Illahee is focused around the State Park, Illahee Creek, the Illahee Preserve, and three miles of “pristine waterfront.” There is nothing in either of these two discussions to indicate why the western boundary goes all the way west to State Highway 303 (Wheaton Way). Also, the boundary splits two neighborhood areas in the vicinity of Aegean / Sunset Avenues and University point.
Where is the rationale for the inclusion of these areas? Particularly of concern is the commercial area along Wheaton Way. How does this area relate more to Illahee than to Bremerton – especially since the commercial area is not even in the Illahee Creek watershed?
Compliance with County-wide Planning Policies. Section 2.7 and 2.8 of the Illahee Sub Area Plan address the 13 Goals of GMA and the plan’s compliance with those goals. Chapter 3 of the plan deals with the history of plan development. However, there is not one mention in the plan of the County-wide Planning Policies adopted by Kitsap County Ordinance 403-2007 on November 19, 2007. This is no small oversight. Element B.4 is particularly relevant as it addresses “Coordinated Growth Management in Urban Growth Areas.” Why is there no discussion in the Illahee Sub-Area Plan regarding annexation to the City of Bremerton (see sub paragraph a.). Also important is sub paragraph b. “To maximize the efficient use of urban lands, subdivisions in Urban Growth Areas shall be consistent with the associated jurisdiction’s Comprehensive Plan and underlying zoning densities.” This requirement has not been addressed in the plan. While it is evident the Illahee area is not adjacent to the City of Bremerton it does abut the City along Riddell Road and it is adjacent to the City’s UGA north of Riddell Road.
Subsection B.4.d states “The County and Cities shall establish procedures to facilitate the smooth transfer of governance for associated Urban Growth Area(s) through the adoption of Urban Growth Area Management Agreements (UGAMAs), as per Appendix C: Urban growth area Management Agreements.” What is the status of this agreement with Bremerton as it pertains to the Illahee area? Why is this information not disclosed in the plan?
Element F – Contiguous and Orderly Development – There is no discussion in the plan regarding these set of policies.
Element I – Affordable Housing – the Illahee Sub-Area Comprehensive Plan has only two statements in it to address this subject matter. Thus for all intents and purposes the subject matter has been ignored. One would think that Housing Affordability would be addressed in Section 3.10 of the plan pertaining to Goals and Policies and yet there is no mention of this goal or how it might be implemented. The County-wide Planning Policies clearly call for more substantive analysis.
Property Rights. Section 2.8 of the plan addresses the compliance of the plan with the 13 Goals of GMA. Regarding property rights there is only this statement in the plan found on page 21. “The Plan balances new regulations with private property rights through the provisions of the Kitsap County Code.” What new regulations?” How does the reader of the plan know whether the Plan is in balance with the Kitsap County Code with or without “new regulations? A one sentence response might be acceptable in an executive summary, but not in a plan where significant changes are being made to land uses and zoning patterns. Also, aspects of the plan definitely affect the constitutional rights given to property owners to use their land. The so-called “Community Tree Protection Standards” found on page 60 represents one such abridgement of a property owner’s right to use his or her property. There is no discussion in the plan regarding this issue. There are other provisions that similarly take away or diminish rights of property owners to use their land.
Natural Systems. Where is the discussion to indicate why the 2006 adopted update to the County’s 1998 Plan was not adequate to address either the land use or natural system conditions in the Illahee planning area? This question is especially significant in light of the fact that the 2006 plan update changed the zoning from Urban Low to Urban Restricted in much of the planning area due to environmental constraints. Why 25 pages of text devoted to Natural Systems when the County-wide Plan already makes provisions for Natural Systems and in light of the fact there is a Critical Areas Ordinance to implement the County-wide Plan?
The text of this plan is disturbing because there is no clear distinction between what is new in the Sub-Area Plan and what already exists in the County-wide Plan. This concern is particularly evident when the Goals and Policies found in Section 4.10 are considered. How many of these Goals and Policies are redundant? How many are not even necessary in light of other existing plans and regulations? Policies 4.4-1, 4.5-1, 4.5-3 (these already exist in the CAO), 4.6-1and 4.9 should be eliminated. They are unnecessary as they are addressed in the County-wide Plan or in the County’s Critical Areas Ordinance.
There are policy statements that really are not policy and provide no real guidance in the land use decision-making process. Included in this category are Policies 4.2-2, 4.3-3, 4.4-3, 4.5-2, 4.6-1, 4.6-2, 4.6-3, 4.6-4 and 4.8. The subject matter addressed in these so-called policies is better handled in discussion text. Kitsap County’s 1998 Comprehensive Plan had many such policies and now 10 years later none of those “non-policies” were ever implemented because they were meaningless as directives for action.
The questions and comments recorded about this section of the plan really do need to be answered and the policies section amended to delete the aforementioned policies.
Transportation. The Goals and Policies of this section of the plan have the same kind of problems found in the Natural Systems section. They need to be re-examined, taking out ones that are duplicative in the County-wide Plan and those that provide no real guidance in decision making.
Public Infrastructure. In September 2007, Kitsap County’s 2006 Comprehensive Plan update was overturned in part by the Central Puget Sound Growth Management Hearings Board. A central issue in their order of “invalidation” related to the capital facilities element of the Plan and the lack of a showing how utilities – particularly sewer – would be extended into the expanded UGAs to serve development. In light of the County’s experience in the aftermath of the 2006 Update, is it not more than just a little ironic that the Illahee Sub-Area Plan contains no discussion about capital improvement financing? While there is a reference to the adoption of the Central Kitsap Wastewater GMA Compliance Plan. However, it is a disservice to the plan reviewer that there is no summary of the provisions of that “compliance plan” as it is pertinent to the Illahee Sub-Area. For example, how much money is going to be allocated to future utility upgrades or new service extensions in the Illahee Sub-Area? Also important is how much will be spent by Kitsap County versus the City of Bremerton or North Perry Water District.
We do not believe the County has justified the need for this Sub-Area Comprehensive Plan. Also, we are concerned that there is no process for citizens of this County to voice their opinion as to whether or not plans should be drafted for particular neighborhoods of the County. Therefore, the Kitsap County Association of REALTORS® hereby request that the Illahee Sub-Area Comprehensive Plan not be adopted until at least the problems identified in this letter are rectified.
Richard A. Brown
Government Affairs Chairperson
Kitsap County Association of REALTORS®