>Illahee Community Plan Comment Deadline – 12/3/08

>Plan Comments Deadline 12/5/08. The deadline for public comments on the Illahee Community Plan is 4:30 pm on Friday, 12/5/08.

Example Comment Forms Requested. We have been requested to provide examples of email comments, primarily to show the email addresses of the County Commissioners, as some are more comfortable reading emails than sending them. We have taken the heading from an email sent to the Commissioners which is provided below. Some have sent one-liners, others have expounded with paragraphs. Our suggestion is to do whatever you feel comfortable with.

To: Steve Bauer: <sbauer@co.kitsap.wa.us>,

Josh Brown: <jwbrown@co.kitsap.wa.us>,

Jan Angel: <jangel@co.kitsap.wa.us>,

Subject: Illahee Community Plan

Cc: Katrina Knutson <Kknutson@co.kitsap.wa.us>

Dear Commissioners,

KAPO Letter With 13 Concerns. Yesterday we received a copy of the letter written by William Palmer that described 13 areas of concern that the Kitsap Alliance of Property Owners (KAPO) had with the Illahee Community Plan. It was the letter that was turned in at the public hearing for the Illahee Plan and that was referenced in the linked Kitsap Sun article. We responded to the letter with answers to all 13 concerns, and have attached the letter below for those who have been following the opposition letters to the Illahee Plan.

Let Us Know Your Thoughts. We have been preoccupied during the Thanksgiving holiday and are just getting back to Illahee issues. Let us know your thoughts on this subject and other issues you would like to have more information on.

Jim Aho

Board of County Commissioners

County Administration Building

614 Division Street

Port Orchard, WA 98366

Subject: Illahee Community Response to Palmer/KAPO Letter of November 24, 2008

Dear Commissioners:

The following is a response to the William Palmer / Kitsap Alliance of Property Owners (KAPO) letter dated November 24, 2008, from the co-chairs of the Illahee Community Plan efforts in 2006 and 2007. We have followed the letter’s numerical items with a brief restatement of their concern, followed by our response, and then a concluding comment.

KAPO Concern #1. “Criteria For SubArea Comprehensive Planning.” KAPO’s concern is that the “Board of County Commissioners have established no qualification criteria for how to determine what portion of the County might be considered for SubArea planning consideration,” and specifically the absence of the City of Bremerton’s involvement. They go on to allege the 2006 adopted Comprehensive Plan does not mention a need to specifically plan for the Illahee SubArea or suggest what constitutes its boundary.

Response. While we cannot respond to the Board’s SubArea planning criteria, we can respond that in 2007 Geoffrey Wentlandt, City of Bremerton planner, participated with Kitsap County Planner Linda Bentley in the 2007 County Planning effort that took place prior to Ms. Bentley’s departure. Additionally, the City has been kept informed of all planning efforts since 2006.

With regards to the allegation that the Comprehensive Plan did not mention Illahee or its boundaries, the Illahee Community Plan and the Illahee boundary map are presented in Chapter 17 of Volume I of the adopted 2006 Comprehensive Plan Update.

Conclusion. KAPO’s concerns regarding the involvement of the City of Bremerton and the alleged failure to include reference to the Plan in the 2006 Comprehensive Plan Update are not substantiated.

KAPO Concern #2. “No Justification of Changed Conditions.” KAPO’s concern is that SubArea plans must be justified by changed conditions, which allegedly were not discussed in the Plan nor in the 2006 Comprehensive Plan Update.

Response. The Illahee Community Plan did discuss changed conditions in Section 1.3 “Visions for the Illahee Community” and more specifically they were also noted in Section 17.2 “Vision” in the 2006 Comprehensive Plan Update, Volume I.

Conclusion. Justification of “changed conditions” is provided in Section 17.2 of the 2006 Comprehensive Plan Update, and in Section 1.3 of the Illahee Community Plan.

KAPO Concern #3. “SubArea Plans Cannot Modify Policies and Land Use Designations.” KAPO’s concern is that the Illahee Plan modifies comprehensive plan policies and land use designations.

Response. The fact that the Growth Management Act permits yearly amendments to the 10 Year Comprehensive Plan Updates, and such amendments modify policies and land use designations, counters the allegation that SubArea plans cannot modify the contents of a Comprehensive Plan. The reason the Illahee Community Plan is being enacted on as an amendment to the Comprehensive Plan, rather than enacted earlier in the year similar to the Keyport Plan in 2007, is because it was already in the 2006 Comprehensive Plan. The Illahee Community Plan is simply the further amplification and completion of the process documented in the 2006 Comprehensive Plan.

Conclusion. SubArea plans can and do update policies and land use designations as permitted and authorized by the Comprehensive Plan Amendment Process.

KAPO Concern #4. “Arbitrary Boundaries Set For the SubArea.” KAPO alleges the Illahee boundaries are arbitrary and not justified to extend westward to Wheaton Way.

Response. The boundary discussion occurred early in 2006 and then again in 2008. As stated in the Plan, the Citizens Advisory Group (CAG) followed GMA and other guidelines, which were straightforward and noted. The major guideline was to utilize any governmental or public jurisdiction boundaries, which explains the extension of the boundary to State Highway 303. The boundaries are essentially the boundaries of the Port of Illahee, with two “logical extensions” that again fit the guidelines that are to be followed. Also, the Illahee Preserve boundary extends westward to State Highway 303, and much of the northerly and southerly boundaries for the Preserve define the boundaries of the Illahee Community’s Westerly extension. It makes no sense to limit the boundary to the top of the ridge, essentially cutting through the center of the Illahee Preserve.

The primary justification of the use of the Port of Illahee boundaries is that they provide a jurisdictional boundary that provides for taxation and representation, through the election of the Port of Illahee Commissioners. What better criteria can there be for a community boundary than one that has already been defined by earlier public officials and has been in existence for decades, that encompasses the major natural features of the area, and that provides for representation and taxation of the community?

Conclusion. The Illahee boundaries are not arbitrary, but were well thought out considering all parameters and inputs. The boundary rationale was presented and approved by the CAG in both 2006 and again in 2008, and represents the most logical and appropriate boundary delineation possible. The boundary map was published in early 2006 and has been in every Plan since, not to mention that it is included as Figure 17-1 in the 2006 Comprehensive Plan Update (Volume I) that was adopted December 11, 2006 by the Board of County Commissioners.

KAPO Concern #5. “No Commercial or Industrial Area in Illahee Proper.” KAPO on one hand is concerned that the boundary extends to State Highway 303 (see previous item) and then states that without a commercial area that it would no longer qualify for SubArea status.

Response. The Illahee Plan does include the 120 acre commercial corridor along SR 303, which according to the rationale stated by KAPO, justifies the SubArea plan.

Conclusion. A commercial corridor does exist in Illahee along the east side of SR 303.

KAPO Item #6. “Lack of Compliance with County-Wide Planning Policies.” KAPO’s letter alleges the Plan does not comply or discuss the County’s adopted County Wide Planning Policies.

Response. The first draft of the Illahee Community Plan was completed in July 2006, nearly a year and a half before Kitsap County Ordinance 403-2007 “Kitsap Countywide Planning Policies” was adopted on November 19,2007. Members of the CAG did not feel the need to reference the Ordinance or restate policies, but rather to ensure that the Illahee Plan was in compliance. That compliance was confirmed during the county review process.

Conclusion. The Illahee Community Plan, while not referring directly to the Ordinance, does comply with the policies stated therein.

Note: The Realtor Board’s letter of concerns, which are referred to in the KAPO letter, described in greater detail some of the issues with the Ordinance. Those issues were previously answered in the response letter regarding the Realtor Board’s concerns.

KAPO Concern #7. “Unnecessary Introduction of New Zones to Zoning Ordinance.” KAPO states that the Plan unnecessarily introduces new Zones to the planning area noting that the zones are unjustified and complicate the zoning process.

Response. The Illahee Plan includes two new zones: a View Protection Overlay Zone and a Greenbelt Overlay Zone, both of which satisfy community goals. The View Protection Zone was desired by residents to protect their own and future residents’ east facing views. The Greenbelt Zone was desired to protect many of the natural features of the critical areas surrounding Illahee Creek and the natural features and wildlife corridors between the Cheney Estates, Illahee State Park, and the Illahee Preserve.

Conclusion. There are no unnecessary Zones introduced in the Illahee Community Plan.

KAPO Concern #8. “Lack of Substantive Discussion of Property Rights.” KAPO’s concern is that the Illahee Plan only gives “lip service” to the property rights issue and that the issue “desires a whole lot more discussion than one paragraph.”

Response. The property rights statement used in the Plan was adopted early on from the 2002 Manchester Community Plan in order to use a statement that has gone through previous public and county scrutiny. In retrospect, with the addition of view protection overlay in 2008, an additional sentence from the 2007 Updated Manchester Plan could have been added to address the new overlay regulations, which read as follows: “New regulations included in the Plan allow the sensible development of land without inappropriate financial impacts.”

Conclusion. There is no need to use more than one paragraph to state that Illahee residents believe in individual property rights.

KAPO Concern #9. “Housing Affordability Issue Ignored.” The concern appears to be that “Affordable Housing” was not addressed and the Plan should have a “substantive discussion” of this issue

Response. Affordable housing, or below market rate housing, was discussed at great length during 2006 as the CAG looked at trying to balance zoning designations with the numbers of people being allocated to specific areas. The solution was to increase zoning densities in areas where the infrastructure and services were available. Higher density zoning was proposed along Trenton Avenue and Almira, with senior and low income high rise buildings proposed along Almira. Those decisions were affirmed again in 2008.

Conclusion. Below market rate housing was properly and adequately considered.

KAPO Concern #10. “No Need for Natural Systems Section of Plan.” KAPO simply asks the following question for this concern: “Where is the documentation of need for the expanded Natural System’s section of the Illahee SubArea Plan?”

Response. Community plans are to highlight the unique features of the community and the area. Illahee has many natural systems, resource lands, and critical areas that limit development and these areas need to be described in a community plan

Conclusion. The abundance of natural features of Illahee are what make this area unique and worthy of special attention, which includes coverage in the Illahee Community Plan.

KAPO Concern #11. “The Transportation Section of the Plan is Duplicative.” The concern is with duplication of policy items that are in the Comprehensive Plan and that there are policies that are “not capable of being implemented.”

Response. Not everyone in the Illahee community is familiar with the Transportation policies in the Comprehensive Plan. As such there are duplications for the community. That is what the CAG wanted included in the Plan. This Chapter of the Plan was extensively reviewed and updated by county officials. We are not aware of what specific policies KAPO is referring to that are not capable of being implemented.

Conclusion. Duplication of Transportation Policies is appropriate in a community plan.

KAPO Concern #12. “Lack of Capital Improvement Financing Discussion.” KAPO simply asks another question regarding this concern which is: “Why is there not discussion of capital improvement financing in the Illahee Sub Area Plan?”

Response. The future infrastructure plans for Illahee, specifically for sewers, are referenced. This issue has been a concern of some for years and has been discussed at various meetings. The community was told that there is generally insufficient density in the Illahee area for the county, or the City of Bremerton, which would be responsible for the areas to the south, for there to be a push for sewers in the near future unless new housing developments came on line. Community members met with both city and county engineers in 2006. County personnel worked with the CAG in 2008 to rework the chapter to suit current thinking and plans.

Conclusion. The discussion of capital improvement financing was not considered appropriate by the CAG or the County for inclusion into the Illahee Community Plan.

KAPO Concern #13. “Public Participation Too Limited.” KAPO states that “public participation has been very limited at best,” and that the County had “a greater responsibility to solicit participation from a broader area of the County…”

Response. Over the nearly three years the Illahee Community Plan has been in the preparation and review processes, there have been many involved and contributing residents and some non-residents involved in the completion of the Plan. Signs were placed along the roadways of Illahee, Illahee Community Newsletters go out via Postal Service mail to over 260 families, Illahee Community Updates go out via email to over 300 recipients, and the Illahee Community website was created primarily because of the Illahee Community Plan in order to keep the community and any interested others informed about the Plan and other Illahee issues. The first version of the Plan was completed by the community on July 5, 2006, and subsequent versions were issued in September 2007 and February 2008 before the County took over the process in February of 2008. The number of community members who have been kept informed of the Plan during this timespan is considerable, with the final list of public participants (which numbers nearly 100 for the process period between 2006 and 2008) available on the County’s website.

We are not sure what more the County could have done to solicit participation from a broader area of the County as public notices were published in the legal sections of County papers. Additionally, the Kitsap Sun, the most widely distributed paper in the County, covered the Illahee Community Plan from 2006 to 2008.

Conclusion. Public notice and participation was more than adequate to properly represent the Illahee community. Additionally, press coverage and legal notices provided adequate notice to interested county residents.

Final Comment. The Kitsap Alliance of Property Owners (KAPO) had every opportunity to be involved with the Illahee Community Plan from the beginning in 2006 until fall of 2008, a nearly three year time frame. They had a chance to bring their concerns before a very interested and involved Planning Commission, but did not do so. The KAPO objections to the Illahee Community Plan are without merit as noted in the above reasoned explanations and answers.

We, therefore, respectfully request the Board of County Commissioners approve the Illahee Community Plan.

Dennis Sheeran & Jim Aho

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