Methow Valley Citizens’ Council

Our rural heritage

Comp Plan Woes

Contents:


RESOURCE LANDS DESIGNATIONS AND MAP
ENVIRONMENTAL PROTECTION
RURAL DENSITIES AND MAP
GROUND WATER

RESOURCE LANDS DESIGNATIONS AND MAP

(Agriculture, Timber, and Mining lands of Long-Term Commercial Significance)

1. Include your own passionate feelings regarding protection of agriculture, future availability of food in our county, and water available for agriculture.

2. Map - Resource lands: It is not possible to tell from the available "Comp Plan Map" which lands are designated as Agricultural, Forest, or Mining Resource Lands of Long-Term Commercial significance.

3. Local Food Supply: A deleted section of the comp plan deleted the statement that:

it is important that local policies recognize a need to preserve the capacity to provide a local independent food supply."

It is imperative that a local, dependable food supply is possible.

4. Needs of the Industry On page 16 the draft states that it may occur that lands that meet the criteria for resource designation but are in excess of the needs of the industry will not be designated resource lands. This is wrong. The county has to designate all lands that qualify as forest or agricultural lands of long term commercial significance. In addition, the county has not accounted in its date for the need of land to produce hay for cattle during the winter. Acres of grazing land is not the only need of the industry.

5. Currently Productive Ag Lands: The county is required to designate currently productive agricultural lands as Agricultural Lands of Long-Term Commercial Significance. It has not done so. Instead, it has designated almost no private lands under this category, designating public lands instead - in spite of the fact that almost all these agricultural lands are on private lands.

6. Water availability for Agriculture: The county has not included availability of water as a criterion for designation of Agricultural Resource Lands.

7. Map/Text Consistency: Designations of public lands as Ag Resource lands on the accompanying map are not consistent with the criteria listed in the text. These include topography and altitude, availability of public facilities, and availability of markets. The public lands designated on the map do not, for the most part, meet these criteria.

8. Coordination with federal and state agencies: If public lands alone are relied upon to supply the needs of the industry, federal and state agencies must be involved in the Draft Comp Plan or EIS. The county will need to coordinate with, rather than dictate to, the public agencies involved.

9. Needs of cattle industry: Public Lands provide only one-third of the annual forage necessary to sustain current levels of grazing. The proposed Comp Plan also fails to provide or account for acres of irrigated and non-irrigated acres now occurring on private land, required for hay production, to support current livestock economy. Cattle are feeding on hay closer to 4 months than 3 months, as the draft has calculated.

10. Forest Lands: Since only public lands seem to be designated as Forest Lands of Long-Term Commercial Significance, it will put more pressure on public lands for logging and providing of forest resources. Coordination with federal and state agencies is necessary because of this.

11. The draft also recognizes that as Okanogan County has grown "recreation, hunting and fishing has also become an economic generator to our local businesses". These are the reasons Resource Land designations must assure agricultural lands for future generations as well as protection of environmental values that have become more important as "economic generators". This draft proposes that all future food crop and forest land needs be met on public lands (Federal and State) and conservation easements and deletes the need for protections included in the existing plan. That proposal is not in the best interest of Okanogan County's economy.

12. Chapter 1 concludes with:

This statement should not be construed in any manner that implies any interference with an owner's right to sell their water right to any buyer.

This does not take into consideration the concern of neighborhood groups that water rights not be removed from current agricultural uses nor transferred out of the county. The county must retain water rights for agricultural needs within the county.

RURAL DENSITIES AND MAP

1. Make known your own passionate feelings about rural areas, availability of water in rural areas of our county, open space, sufficient lot size for agriculture, and overdevelopment .

2. High and Low Density designations: The "medium" density designation has been deleted from the Comp Plan map, so there are now only 1-acre minimums (Rural High Density) and 5-acre minimums (Rural Low Density.) Medium density should not have been removed from the equation. There are areas of the county which should have minimum lot sizes of 10, 20, or 40 acres. Why not designate them? Why was medium density deleted?

2. 1-acre minimum lot sizes are closer to Urban density than Rural. In the Quadrant Corp. decision, the Supreme Court held that a county could consider an area with vested one acre lots as "already characterized by urban growth." What public input can the county refer to that drove them to zone remote areas, in Agricultural land use, with no public services and inadequate water resources, as urban densities of 1 acre minimums?

3. Lot sizes of 5 acres minimum are not low density. Areas with a "demonstrated inability to provide adequate water resources", as well as steep, hard to access areas and those used currently for agricultural and forest resources demand a much lower density. Even the previous 20 acre minimum is insufficient on much of the difficult and arid terrain. Much of this land is currently in forest and agriculture.

4. Historical comparison: After much public input in favor of environmental protections, which are needed now because of pressures on the land that were not present 50 years ago, when the Planning Enabling Act was written, we are now being presented with a plan that would incorporate county-wide urban desities very similar to the one acre densities allowed nearly fifty years ago. This does not make sense and is not a Comprehensive Plan with sufficient guidance for the 21st Century.

5. Map inconsistent with text: The text of the Comp Plan does not follow the criteria set forth in the text for Rural High density. For example, areas such as the Middle Fork of Gold Creek, upper McFarland Creek, and others are very remote and not in proximity to paved roads, major roadways, supply centers, or subdivisions. Why are they considered Rural High Density, with 1-acre minimum lot sizes? The Plan states that high density rural will be located adjacent to urban areas and areas that demonstrate an enhanced ability to provide services. But the map shows high density rural development will be permitted in many areas that are remote and far from services.

6. City Expansion Areas: Water and sewage facilities must be in place or have secured funding prior to authorization of development agreements, commercial development, high density residential development, or other substantial development proposals. (Note: large city expansion areas have great potential to create strip development and urban sprawl.)

7. Eliminate "Proximity to Subdivisions" as criterion for Rural High Density. Poor planning in the past has created dense subdivisions in areas where they should not have been allowed (critical areas, sharptail grouse leks and habitat, areas very distant from services, etc.) Let's not continue that trend by increasing the densely subdivided properties in areas where they didn't belong in the first place.

8. Commercial Development: Previous versions of the comp plan (2009) say commercial development should stay close to established urban centers. This is what planning is supposed to do in order to prevent sprawl and save farms and open space. The current draft promotes residential sprawl with its zoning. It then asserts that commercial development should follow. This creates sprawl.

10. Rural lands will be a catch-all for the greatest variety of permitted and conditional uses. For example, low density rural (5 acre minimums) allows as a compatible conditional use "non-resource based heavy industrial". Such a use demands an industrial zone designation, not low-density rural that is mainly on land now used for agricultural purposes.

11. Examine your own property designation on the maps: Each citizen or landowner needs to look at the Comprehensive Plan map and give specific input publicly and in writing if you do not agree with the density category of your property or lands that are of concern to you.

ENVIRONMENTAL PROTECTION

1. Lower Methow: The Methow Valley Review District documents, which are incorporated in the current draft, do set a good direction for environmental issues. However, the Lower Methow is not included.

2. Keep the Comprehensive Planning documents for the Upper and Middle Methow Valley. The general goals and vision for Okanogan County do not support the zoning in the Methow Valley, due to lack of acknowledgement of environmental concerns. Should the Methow zoning face a legal challenge without support in the Comprehensive Plan, it is difficult to predict what a judge might decide.

3. Need more than SMP and CAO reference: there is no statement of the high value Okanogan County residents place upon clean air, clean water, wildlife habitat, viewsheds, or open space. Environmental concerns encompass more than just those addressed in the Critical Areas and Shorelines, and the Plan offers no guidance as to how this is compatible with one acre parcel densities. Frequent mention of environmental concerns raised by Neighborhood Groups are not mentioned.

4. Changes in Comp Plan: The draft Comp Plan has changed so much since the Environmental Impact Statement was written that it requires a new EIS, not just a supplement.

5. Global Warming: Failure to address Global Warming in this Comp Plan will restrict the ability of the county to receive grant monies from the State. This lack of funding will have an impact upon the county's ability to write good environmental protections and to enforce them.

6. Environmental Concerns: The county lists 4 planning objectives for Resource Lands. Private property rights is included but environmental concerns - neither adverse effects of environmental agents upon agricultural lands nor the effects of agriculture upon the environment - are not.

GROUND WATER

1. Indicate your own passionate feelings about ground water purity and quantity, the current predictions of dwindling supplies of ground water, the effects of dense developments and exempt wells in our arid/semi-arid area of the county.

2. State requirement on ground water quality and quantity: The county is required in this Comprehensive Plan by state law to provide for protection of the quality and quantity of groundwater used for public water supplies. This draft makes little or no reference to the need for protection of ground water quality or ground water quantity with the dense development they are planning.

4. Ground water quantity/availability: An increasing number of areas in the Columbia Basin have experienced a significant drop in the water table in their locations recently. Could this happen in the Methow with 1-acre lots in arid areas such as the Lower Methow?

5. Keeping Ag water in county: Chapter 1 concludes with "This statement should not be construed in any manner that implies any interference with an owner's right to sell their water right to any buyer." This statement does not take into consideration the concern of neighborhood groups and other citizens that water rights not be transferred out of the county. The county must retain water rights for agricultural needs within the county.