Well, the county PC [Whatcom County Planning Commission] does not care, but if anyone else does, here is a copy of the comment that I submitted to the PC regarding the environment chapter of the comp. plan.
My general review of the Environment Chapter [of the Comprehensive Plan] is as follows:
The Environment chapter of the Comp. Plan still requires significant revision. There have been important changes in the law and the science since the last review and yet, this draft reflects relatively small changes. This indicates that changes in law and science have not been considered.
Additionally, in the last decade we have continued to experience degradation of the environment, biodiversity has been lost, we are now dealing with a water quantity problem and an increase in invasive species. All of this indicates that our existing environment polices are not adequately resulting in sufficiently protective development regulations. We need to revise the policies so that this problem is addressed and corrected.
The county is not compliant with GMA requirements to identify open space corridors within and between urban growth areas that are useful for wildlife habitat and critical area connectivity. ( RCW 36.70A.160). This reflects the county’s refusal to look beyond a site specific review of ecological issues, despite Best Available Science and state and federal polices strongly encouraging a landscape based ecosystem approach to environmental protection. The environment policies should be written to ensure compliance with the GMA (i.e., adoption of a landscape based approach that considers ecosystems and watersheds as a interrelated whole).
Finally, as drafted, this chapter reflects an antiquated view of the environment that might have been appropriate 25 or 30 years ago, but is certainly no longer relevant. The most important concepts and terms of today are not highlighted, or in many cases, even mentioned; landscape planning, ecosystem function (interconnected and synergistic), ecosystem services and benefits; biodiversity, resiliency; nutrient loading; intensity of use impacts; incompatible land use activities, baseline standards, metrics for monitoring no net loss, citizen science, limited nature of natural resources.
Underpinning all of this is the recognition of global scientists that humans have so altered the world that the survival of our species is no longer assured. The environment chapter needs to reflect the dire state of the county, the nation and the world based on human alteration. The only honest and brave thing to do is to acknowledge this situation so that we can begin a public discussion of how best to accommodate competing needs in our policies and development regulations that protect the long term health and vitality of Whatcom County.
A primary problem is one of process. The county is piecemealing the GMA Comp. Plan update. It is treating only the population projections, UGA boundaries and Comp. Plan chapters as the Comp. Plan review, while revising the Critical Area Ordinance and zoning as part of a separate process. (An important question to ask is what purpose does this piecemealing serve? It is something both the county and Bellingham are pursuing.)
The GMA was enacted to ensure comprehensive and coordinated planning. The GMA update process includes both the comp. plan chapters and development regulations (the critical area ordinance, zoning and subdivsions). RCW 70a.130(1)(c) provides that the comp. plan shall include consideration of the critical area ordinance, and analysis of population allocations.
Why is the county requiring the Planning Commission to review and recommend changes to the comp. plan chapters prior to the time it will be reviewing the CAO and zoning? While the development regulations must comply with comp. plan policies, those policies must be developed based on a sound understanding of the current law and Best Available Science, which is being incorporated into the CAO. Thus, the only logical and legal approach is to include both all of these things as part of the same review process.
This planning commission has been put in a position that deprives it of the information necessary to do a fully adequate job. I think it is important that the planning commission understand this so that it can insist on the right to be properly educated and fully informed on the important matters under review.
My recommendations: 1) I suggest that this Chapter be forwarded to the County’s Critical Area Ordinance citizen and technical committees for review and comment prior to moving forward. These committees are still meeting and have a stronger background in the CAO and its changes. 2) The PC should advise the county (administration and staff) that the comp. plan chapters need to be revised as a part of a coordinated and comprehensive review that considers these interconnected items as cohesive whole. 3) The environment chapter needs to be revised to reflect our current understanding of ecological function and health.
Although the latest planning commission meeting was last night, it is never to late to add important data, comments, or concerns you wish to be registered with the Whatcom County Planning Commission as part of the permanent record.
You can contact the Planning Commission here: