TO:
BELLINGHAM PLANNING COMMISSION
FROM:
DONNA AUER
DATE:
SUBJECT:
2005 REVISIONS TO THE
INTRODUCTION/ CHAPTER 1 FRAMEWORK GOALS
AND POLICIES/CHAPTER 2 LAND USE - REVIEW AND COMMENTS
The following
comments were written with emphasis on my particular area of interest: public participation in planning documents
that affect the citizens where they live; and the protection and preservation
of the character, quality, and livability of
COMMENTS REGARDING CITIZEN PARTICIPATION
OF THE REWRITING OF THE 2005 REVISED COMPREHENSIVE PLAN (2005 REVISED CP):
1. ABSENCE OF PUBLIC PARTNERSHIP
In many
instances, our City does not yet understand how to more fully utilize the intelligence,
expertise, energy, vision and dedication of its citizens when developing a
planning document such as the 2005 Revised Comprehensive Plan (2005 Revised
CP). To do so would increase efficiency
in City departments, at the Planning Commission and at City Council. Perhaps we all fail to acknowledge the model
by which we operate as a City, and the values that take precedent in that
operation. Do we have a traditional top-down,
command-and-control structure that sets the agenda, sets the direction, and
occasionally allows a few questions or a few minutes at a microphone? How much more profitable it would be to
engage citizens in a positive process, rather than a reactive one, by
encouraging DISCUSSION, DIALOGUE AND TEAMWORK – especially at the onset and
during the creation of an important document such as the Bellingham
Comprehensive Plan. We would all benefit
from an egalitarian model, where we experience each other in an enthusiastic
PARTNERSHIP.
2. PLEASE NOTE:
3. The new 2005 Revised Comprehensive Plan has
not been seen by the public in general, nor were we brought to the table in the
actual writing of it. The ABN began an
effort to do so last year but met only a few times before being halted to
participate in the 2004 Growth Forum.
The Growth Forum was interesting, but basically asked the public to
respond to the established premise that “we must have infill” and then
proceeded to engage in exercises to select methods of infill. The Mayor’s Neighborhood Advisory Commission
rarely dialogues amongst each other, and does not grapple with current events
that pertain to the Comprehensive Plan.
The document itself has had little to no public input through the usual
formal channels.
4. There has not been adequate public discussion
regarding this first element of the Comprehensive Plan, a core document for
planning in our city, with absolute relevance to the citizens and
neighborhoods. The revised version was
introduced to the Planning Commission on
5. Though I appreciate the efforts that have
gone into the 2005 Revised Comprehensive Plan by the Planning Department, the
structure of the reorganization and revision is difficult to navigate, and
particularly to find phrases and paragraphs located in former documents. It is a Herculean effort to review such a
document after the fact, rather than
during its creation. Therefore, my
comments are a rough overview and I apologize for any possible oversights that
I have made.
IMPORTANT SECTIONS OF THE 1995
COMPREHENSIVE PLAN (1995 CP) – WHERE ARE THEY IN THE 2005 REVISIONS?
EXECUTIVE
SUMMARY
1. The Executive Summary allowed an overview of
the whole plan, for easy access to anyone reading about the Comprehensive
Plan. Unfortunately, the Executive
Summary has been eliminated from the current revisions.
2. (1995 CP, Section Format of the Plan, page
es.2): included in this section is
mention of the neighborhood plans and how they are part of the Comprehensive Plan,
emphasizing separate plans for each neighborhood. This has been left out of the 2005 Revised CP
Introduction.
3. (1995 CP, Section Land Use Classification
System, page es.3): not only describes
how land is classified and used, but provides for “special conditions” that
flag a sub area eg view protection, and “prerequisite considerations” that
encourage discretion in permitting certain areas. These are imperative practices and their
importance is made clear further in this section that states: “the neighborhood plans are structured this
way to encourage development that is compatible with neighborhood character
while at the same time requiring that essential public facilities and services
are in place to serve new development.” (page es.5) This is a very important and necessary
statement of intent that should be present in the 2005 Comp Plan, and
particularly in its introductory pages.
4. (1995 CP, Visions for Bellingham, Citizen
Participation, page es 19-20): A-2 “The
county and the cities shall provide opportunities for citizens to become
involved in the growth management planning process through various mechanisms,
such as….advisory committees.. and
A-3 “Citizens shall be notified in a timely
manner of opportunities to have input and key decision points in the planning
process. and A-4 “Citizen
comments and viewpoints shall be incorporated into the decision-making process
in development of final plans and regulations.
Consideration of citizen comments shall be evident in the
decision-making process.” These are
not included in the 2005 Revision. This portion was carried out in 1995 to
satisfy the GMA Goal 11: Citizen Participation and Coordination –
Encourage the involvement of citizens in the planning process and ensure
coordination between communities and jurisdictions to reconcile conflicts. On
paper, this part of the Visions for
LAND USE
1. (1995 CP, Part I Introduction
page lu.1): sets forward that
both the 1980 and the 1995 Comprehensive Plan “had at its core two basic commitments:
first, to maintain and enhance
the Central Business District; second, to uphold the neighborhood
structure of
2. (1995 CP, page lu.3) Again, there is further assurance in the
Introduction that land use can be protected through the means of “special
conditions” that flag a subarea eg view protection, and “prerequisite
considerations” that encourage discretion in permitting certain areas (p.
lu.3). And states “the purpose of this structure of the neighborhood plans is to allow
develop,en that fits the neighbohorhood.
Individual characteristics of the neighborhoods are matched by
corresponding conditions in the plans.
Overlaying the pattern of neighborhood plans are the goals and policies
for the city as a whole.”
3. (1995 CP, LUG 1, page lu.16) “Bellingham
relies on distinctive neighborhoods, a vital downtown, and a community’s
respect for its natural setting to retain its unique identity in the 21st
century” This is part of the Visions statements but is
not included as a viable statement in the Land Use Section of the 2005 Revised
Plan.
PROBLEMS:WITH THE 2005 REVISED
COMPREHENSIVE PLAN (2005 Revised CP)
Though clearly
the revised plan contains an enormous amount of work, the ability to review it
adequately is hampered not only by too little time to do so, but also because
the “cross out” format is not consistent throughout the document. It is not possible in some sections to see
what has eliminated from the 1995 Plan.
Instead we find occasional crossed-out sections, though they appear
sporadically (beginning suddenly in Framework Policies, County-wide Policies
(2005 Revised CP, page 2-16, for example) or not at all in other sections (such
as the Visions section)
INTRODUCTION
1. (2005 Revised CP, page 1-6): Though the 23 Neighborhood Plans are briefly
mentioned, their importance is omitted, particularly as they serve as documents
that preserve character and moderate development in their areas.
2. (2005 Revised CP, Section 1.4 Citizen Involvement, page 1-7): citizens may have been involved in certain
topics such as population growth and methods of infill, this actual written
document of the 2005 Revised Comprehensive Plan has not been included as part
of any formal or informal citizen participatory group. The document itself surfaced at a Planning
Commission work session without ANY public exposure, nor through any of the
formal channels. Though of course,
announcements had gone out to some, regarding the schedule for revising the
Comprehensive Plan at the Planning Commission, the document itself was not
previewed. One week after the work
session, the Planning Commission held a “public hearing” that only a handful of
citizens had heard about, and about which the general populace had no idea
regarding the writing and presentation of this document. On the morning of the first public hearing of
the Planning Commission, the 2005 Revised Comprehensive Plan had not yet been placed
on the City web site, so that even then it was not accessible to the
public. I would venture to say that
there was not adequate or acceptable notification nor awareness on the public’s
part to review the document, to understand it, and to respond in a unified way
to it. This begs the question whether
Goal 11 of the GMA Citizen Participation has been respected. Perhaps the letter of the law was followed,
but certainly the intent is questionable.
(And even in 1995, the Planning staff utilized a work group for some
portions of the Plan.)
CHAPTER 1 FRAMEWORK GOALS AND POLICIES
1. (2005 Revised CP, Introduction, page
2-1): This chapter states that the
Comprehensive Plan “reflects the long-term values and preferences held by the
community”. Yet most of the framework
goals (with the exception of those informed by Waterfront Futures) were
developed over 10 years ago
(1992/1995) as the Visions for
2. (2005 Revised CP, Visions for Bellingham Goal
Statements, Section 1 Development Patterns and Community Character, page
2-2): The Visions have been reorganized
in this section, but seem to retain the statements that were given in 1995. However, because eliminated sections have not
been shown via cross-out, it is difficult to decipher if all the Visions
statements (pertaining to these first few revised sections) have been
retained.
3. Public participation in this document is required by the GMA and is advised by
the 2004 Growth Forum’s recommendations, yet there has not been a citizen work
group that has worked on this document (except for 3 ABN meetings in spring
2004 that were discontinued). The
Visions statements merit a rewriting or creating additions by a citizen body. Though “visions” have been expressed in
numerous venues, such as at population growth meetings, the 2004 Growth Forum,
neighborhood association meetings etc, and have included such topics as
“natural spaces, the importance of “view corridors”, avoiding buildings that
make “a wall on the water”, and the complex issues around “view protection”,
none of these present-day visions have
been utilized here.
4. The 1995 Visions for
5. (2005 Revised CP, Section Framework Policies
– 2004 Community Growth Forum, page 2-32&33): The Growth Forum Recommendations have been
included as part of the Revised Plan.
However, City Council voted only to “accept” the recommendations, not
adopt them - and said that they required
further discussion. The Planning
Department is now including the recommendations in this Revised Plan “for
discussion”, but recommending that they be adopted as part of the 2005 Revised
Comprehensive Plan. There are many fine
points of the Growth Forum Recommendations that give impetus to greater citizen
participation and involvement, so the recommendations are favorable in that
direction. However, there are many
factors in the recommendations that require greater study and discussion
amongst all members of City officials, developers and neighborhoods. REQUEST:
that further study of the Growth Forum Recommendations take place in an
open, creative format, with involved, interested citizens.
6. The Growth Forum was hosted by the City to
present a series of a priori
determinations about how (not whether) infill was to proceed. The Forum was not viewed or experienced as an
activity that engaged citizens in the actual and specific rewriting of all
elements of the 2005 Comprehensive Plan, as has been claimed.
CHAPTER 2 LAND USE
1. (2005 Revised CP, Section 2.2 Introduction,
page. 3-3): This chapter. “is intended
to guide land use, zoning and the physical development of the city”,
establishing a framework for future growth and development of
2. (2005 Revised CP, page 3-7): The Introduction has omitted the above
explanation regarding protections set forth in special conditions and
prerequisite considerations, such as view protection and design review. Also omitted is the statement that the
inherent purpose of these protections is to allow development that fits the
neighborhood. (all crossed out on page
3-7). REQUEST: would it be
unreasonable to ask that the 2005 Revised Comprehensive Plan leave in the
importance of special conditions and prerequisite considerations as
acknowledged and important aspects of neighborhood and city uniqueness, to be
utilized when needed? The special
conditions and prerequisite considerations speak to the protective factor of
the Comprehensive Plan, which should be part of its “comprehensiveness”. This Land Use Chapter is part of a
Comprehensive Plan, not a “Development Plan”.
3. (2005 Revised CP, page 3-10): In fact, this section states that
neighborhood plans are critically important in achieving the vision and goals
of the Comprehensive Plan.….and will continue to be used to guide the
development of regulations. There is
little information about how this will be done, yet a great deal of this
section focuses on describing the new land use and development code regulatory
system.
REQUEST: more explanation that
addresses how neighborhoods will be
preserved and protected by their neighborhood plans, under the protective and
driving force of the Comprehensive Plan.
4. (2005 Revised CP, page 3-10): Neighborhood plans “ will continue to be used
to:…review and evaluate rezone and neighborhood plan amendment requests.”. Through what means will this be
accomplished? The revision does not set
down a series of commitments about how
this will be accomplished.
5. (2005 Revised CP, Section Population Growth
Forecasts, page 3-15): what methods are
used to “forecast” population growth.
At the Growth Forum, population increase was being determined by number
of new building permits issued.
Certainly, this cannot be a proper method for counting new people?! Who is ECONorthwest? How are the City and various organizations
funding and promoting an influx of new people to
6. (2005 Revised CP, Section 2.6 Land Use,
Bellingham Land Use, page 3-22): This
all new section includes the stated “land use within the city is governed by the
land use designations contained in the 23 neighborhood plans”. Is this true, especially after zoning and
development codes have been taken out of the neighborhood plans? Isn’t it more likely that our land use will
be governed by the more generic, standardized land use and development codes
located in the Bellingham Municipal Codes?
7. (2005 Revised CP, Section 2.7 Land Supply and Projected Demand,
8. (2005 Revised CP, page 3-33): I question this statement “Therefore the
current residential land supply in the city and UGA does not contain sufficient capacity to
accommodate the forecasted demand of 14,800 swelling units over the 20-year
planning period.” REQUEST: Include the community
to come up with creative solutions to this problem. Involve citizens in advisory groups, or a
committees - to research similar problems in other cities and the VARIOUS ways
that they have been solved, other than the usual and myopic “build more and
they will come” perspective. What forces
are guiding the City to come up with a solution to this problem?
9. (2005 Revised CP, Section 2.9 Land Use Policies, A Framework Land Use
Policies, page 3-42) This section
includes a “mix of policies from 1995 comp plan and new policies” – but it does
not show what it has been crossed out.
Review of this section is difficult if the omitted policies are not
seen.
10. (2005 Revised CP, page 3-42&43): Suddenly and surprisingly, excellent land use
policies that preserve and protect are inserted in this section, though there
was little indication from the overview in Introductions that these would
emerge here. FLU-4 states “The character
of single family neighborhoods should be protected as higher intensity land
uses are located in designated urban villages and corridors” and FLU-5 states
“Protect and enhance the quality of the natural environment by protecting and
restoring….” FLU-6 states “The quality of the natural environment should be protected
by taking into account the land’s suitability for development and directing
development away from important natural resources and environmentally sensitive
areas.” and: FLU-7 “Emphasize Bellingham’s role as an environmental steward by
conduction City business in a manner that:…promotes sustainable land use
patterns and low-impact development practices, and…leads by example in the
conservation of natural resources…”FLU-8, 9, 10, 11 and the grand finale, FLU-12:
Establish and support a culture of dialogue and partnership among city
officials, residents, property owners, the business community and other
governmental agencies.”
11. (2005
Revised CP, Section D, Residential Development Policies, page 3-47): REQUEST: LU-19 should include “neighborhood character”.
12. (2005
Revised CP, LU-21, page 3-48) This
reads, “residential zoning applied in a manner that is consistent with the
neighborhood’s building densities and development pattern” AND
COULD WE ADD “that is consistent
with the neighborhood tradition of
building densities, development pattern, and
neighborhood character”?”
13.
(2005 Revised CP, LU-24, page 3-48):
If the city is to establish minimum densities, shouldn’t the
neighborhoods be involved in establishing MAXIMUM
densities also?
14. (2005 Revised CP, LU-27, page 3-48): This reads, “which provide a balance between
accommodating development and prtecting the public health, safety and welfare” REQUEST:
and include here neighborhood character,
views and the natural environment”. Surely,
these must be part of the balance.
15. (2005 Revised CP, LU-28, page 3-48): This
reads, “Flexibility in development regulations pertaining to single family
areas should…REQUEST: and continue on
with this change, “should be examined
when application has been made for cluster, cluster detached and cluster
attached housing…”. This has always deserved further
discussion and examination. Otherwise,
this will be in direct conflict with neighborhood character and previous
patterns of development.
16. (2005 Revised CP, LU-30, page 3-48): If (as this reads), “setback, parking and lot
coverage requirements should be flexible in older neighborhoods with
established lots, so that in-fill single family housing can conform to the
existing neighborhood structures”, this will introduce a drastic change in
neighborhood character. These kinds of
changes are too grave and have such enormous consequences that they must be
researched and discussed in a serious
and thoughtful manner with urban planning professionals, knowledgeable and
progressive planners, citizens and neighborhoods. We all are aware of formerly beautiful, older
neighborhoods that have lost their appeal and value as their lot lines decrease
(the infamous “zero lot lines”) and concrete had overcome vegetation. This may produce short-term gain for some
property owners but it relinquishes long-term value and desirability of city
neighborhoods.
17. (2005 Revised CP, LU-40, page 3-49): This phrase has been crossed out -
“incentives to encourage neighborhood scale commercial buildings should be
provided in the urban centers”.
Why? Aren’t neighborhood scale
buildings in keeping with the neighborhood character?
18. (2005 Revised CP, LU-41, page 3-50) This has been entirely crossed out. REQUEST: Maintain limited
mixed use development in neighborhood centers through a public review
process.
19. (2005 Revised CP, Section F, View
Preservation and Protection Policies, page 3-50): Just as suddenly as the
protection and preservation system of the FLUs above were introduced, so this
section gives us a direct contradiction
to them. The essential and highly
honored present-day values of view protection (and as backed up by the
city-wide Citizen View survey in 2001), have been demolished here.
20. (2005 Revised CP, LU-46, page 3-50): This policy has been thoroughly crossed
out. REQUEST: Maintain this very
important section. The open space, the
natural features such as the hills surrounding us are part of what make the
experience of being in the city so
unique and enjoyable (and ultimately that which will attract a continual influx
of visitors and homeowners).
21. (2005 Revised CP, LU-47, page 3-50: This entire policy has been crossed out. It did read,, “every effort should be made
to preserve and enhance the views of
22. (2005 Revised CP, LU-50, page 3-51) This crossed-out policy is too
important. REQUEST: Absolutely maintain
building height limits in specific view areas.
23. (2005 Revised CP, LU-51, page 3-51): This policy crossed out. REQUEST: High rises structures should be examined, in
terms of overall city design and planning.
The greater desirability will be in areas without them. Keep this definition for control of high
rises in specific areas.
24. (2005 Revised CP, LU-57, Essential Public
Facility Siting Process, Part 5. a.and b, page 3-53&54): This states that “public notice shall be
mailed” REQUEST TO INCLUDE… “in a timely
fashion” and INCLUDE “to neighborhood association representatives.”
25. (2005 Revised CP, Section J, General Land Use
Policies, LU-91, page 3-58): This reads,
“Development regulations should provide for an appropriate level of flexibility
while balancing community goals, AND
ADD, neighborhood character, and the need….Include neighborhood
character.
26. (2005
Revised CP, Section L, Comprehensive Plan Land Use Designation Policies, page
3-59): This definition of Single Family
Residential requires examination of the “range of densities” and the “number of
forms” that housing can take. This
directly contradicts FLU-4 above
that protects the character of neighborhoods.
Additionally, it omits the 1995 Comp Plan definition that includes
“single lot in areas currently developed in this fashion” What is desirable for and by the
neighborhood? This is not just a
development decision, but a neighborhood-wide decision.
COMMENDATIONS, WHAT IS GOOD ABOUT THE
2005 REVISED COMPREHENSIVE PLAN:
1. This Plan reflects an enormous amount of
work by the Planning Department and a great deal of time and effort
synthesizing citizen input over the last year.
2. Emphasis on flexibility of the Plan, and a
bow to the ability to re-evaluate as needed.
3. Keeping in the Visions for
4. Emphasizing the 2004 Community Growth Forum
as Framework Policies.
5. Continuing beyond the GMA by retaining the
Community Design Element. (suggestion:
include citizen participation in the writing of this section – via ABN, for instance)
6. Land Use Policies/Framework Land Use Policies
– excellent preservation and protection of neighborhoods and environment, as
well as respecting citizen partnership with the City.
7. For urban centers, requirements include
master plans, design guidelines and development standards to “ensure that the
centers complement the character of the area”, and that citizen participation
is included in the planning process.
(2005 Revised CP, page 3-44)
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