Please let me know if you have questions or concerns about either of these items.

Transcription

1 From: To: Subject: Date: Attachments: Forrest Longman Council FW: Comp Plan Chapter 2 (Land Use) and Chapter 11 Deadline Thursday, March 24, :30:11 PM memo-multi-stakeholder-workgroup pdf blaine_ pdf ferndale_ pdf From: Forrest Longman Sent: Thursday, March 24, :16 PM To: Rud Browne; Barry Buchanan; Todd Donovan; Ken Mann; Satpal Sidhu; Carl Weimer; Barbara Brenner Cc: Dana Brown-Davis; Jill Nixon; Jennifer Schneider; Kristi Felbinger; Marina Engels Subject: FW: Comp Plan Chapter 2 (Land Use) and Chapter 11 Deadline Good Afternoon, The attached document is PDS staff s suggested revisions to the proposed TDR language in Chapter 2 (Policy 2A-14, etc.). Blaine and Ferndale have voiced concerns about having UGA decisions tied to a TDR program. I ve included their letters on the subject for reference. Additionally, please send me your proposed changes to Chapter 11 by the end of the day Monday for inclusion in the 4/5 agenda packet. Please let me know if you have questions or concerns about either of these items. Forrest Longman Legislative Analyst Whatcom County Council flongman@whatcomcounty.us From: Matt Aamot Sent: Thursday, March 24, :36 PM To: Dana Brown-Davis Cc: Jack Louws; Forrest Longman; City of Ferndale; Michael Jones, Blaine Planning; Amy Harksell, City of Lynden Planning; rollinh@sehome.com; Greg Aucutt, Bellingham Planning; Dannon Traxler; Mark Personius Subject: Comp Plan Chapter 2 (Land Use) - Multi-Stakeholder Workgroup Policy Hi Dana: Please distribute the attached letter to the County Council members. Thanks, Matt

2 WHATCOM COUNTY Planning & Development Services 5280 Northwest Drive Bellingham, WA , TTY Fax J.E. "Sam" Ryan Director Memorandum TO : FROM: The Honorable Jack Louws, Whatcom County Executive The Honorable Whatcom County Council Mark Person ius, Assistant Director /U? DATE: March 24, 2016 SUBJECT: Camp Plan Update - Chapter 2 (Land Use) As you know, the cities of Ferndale and Blaine submitted letters on March 22, 2016 raising concerns relating to some of the Chapter 2 changes proposed by Council members. One of the issues raised by the cities is proposed new Policy 2A-14 relating to commensurately reducing densities in Agricultural and Rural areas when expanding urban growth areas. Staff would like to propose modifications to this proposed policy that seek close coordination with the cities on developing new UGA expansion criteria, as shown below: Policy 2A- 14: Establish a clear, predictable, and fair processformula for allowing expansion of urban growth areas that considers reasonable measures to mitigate the impacts of growth. Ensure that UGA expansions O hand in har-t 1--v4ith density reductions in rural sending areas throu h required participation in either a Transfer or Purchase of De>Jelopment Rights program. This process should includebe accomplished--by: Convening a multi-stakeholder work group, including the Cities, tasked with: Reviewing the current TDR and PDR programs. Identifying political, financial, and regulatory barriers...t.q effective TDR and PDR programs.

3 Identifylo_g opportunities and solutions for creating a workablewefflifl9 TDR program. Identifyl.n.g mechanisms to create a PDR fund that could be used to protect important agricultural and rural lands. Recommendlo_g policy a~d regulatory amendments necessary to implement the above policy. Identifylo_g proposed sending areas in critical areas, the Agricultural Zone, and the Agricultural Rural Study Areas. Identifying receiving areas within existing UGAs, including areas within cities and urban areas. Identifying other factors and/or growth management tools relevant to UGA expansions. Based upon the fi ndings of the mult i-stakeholder work group, consider strategies that cou ld require purchase, transfer or otherwise incentivize removal of potential development rjghts from rural or resource lands in exchange for UGA expansions. The above changes would ensure that the findings and recommendations of the multi-stakeholder work group are issued before the County concludes what action should be taken when future UGA expansions are proposed. Likewise, we would recommend deferring any changes to policies relating to interlocal agreements with the cities until after the multi-stakeholder work group recommendations are issued (proposed new Policy 2R-3 and proposed Council amendments to existing Policies 2U-5, 2V-5, 2W-4, 2X-5, 2Y-3, 2Z-4, 2AA-5). In a similar light, we would recommend deferring proposed changes to Goals 2P and 2R and new proposed Policy 2BB-16 until after the work group recommendations are issued. Thank you for your consideration of this matter. We look forward to discussing it with you.

4 PHONE: (a60) 332-8al1 FiLX: (360) W.lillSITf.:..ll11'1Y.cil,.,.c..._ J """',,._.Jc 0 COUNCIL MEETING l.8l -v t.o\v'j :j'> m.,....,_, coo!.!.n!..!o. l COMMITTEE W hatcom County Council EXfllgiJlaarrecOAh-t.2~21, ~20i*1H6r Grand Avenue Suite 105 Bellingham, WA Honorable Councilmembers, The City of Blaine writes to you to express our concern over several amendments proposed by you to Chapter 2 {land Use) of the Whatcom County Comprehensive Plan. The Whatcom County Council is tasked with reviewing a broad range of subjects as part ofthe Comprehensive Plan update, and the majority of your proposed edits in Chapter 2 and other chapters reflect this fact, and our respective Cities take no issue with those edits. The Cities take issue with proposed new policy 2A-14, new policy 2R-3, amendments to Policies 2V-5,2X- 5, 2Y-3, 2Z-4, 2AA-5, and (all generally associated with linking future UGA expansions with density reductions in rural areas through a Transfer or Purchase of Development Rights program). Goal 2R is also included in these amendments. The Cities also take issue with amendments to Goal 2P, generally encouraging the various cities to establish minimum residential density requirements at levels identified by Whatcom County. Issues were brought by the respective jurisdictions as early in the process as possible and the parties have generally been able to find adequate solutions to those Issues. The wounds from the review process had been largely healed, and the Cities collectively believed that they could trust the County to adopt a Growth Management Act-compliant comprehensive plan in a cooperative manner. The amendments listed above, proposed less than three months before the Cities are scheduled to adopt their comprehensive plans, and without any advance discussion with the Cities, have the potential to change everything. Transfer of Development Rights (TOR) The small Cities have made clear their general support for engaging on a discussion of multijurisdictional steps that could be taken to reduce development in unincorporated rural areas. We have also made clear our opinion that members of the Whatcom County Council concluded long ago that a TOR program should be adopted, regardless of its effectiveness or its relationship to other growth issues. Members of the Whatcom County Council have sought to apply this solution to one or more issues for years. Page- 1 -

5 The small Cities have expressed their collective desire to have this discussion. However, the Cities are opposed to a goal or policy (non-binding or not) that seeks to tie such a program to the expansion of Urban Growth Areas. This link has been discredited over and over again since 2009, when spurious claims that the Cities sought sprawling UGA's were first made. There is little incentive for the Cities to expand their Urban Growth Areas, particularly for residential purposes, which would likely be the main target of a TDH or PDR program. Wilen the Cit ies propose an expansiou of thetrl7ga's, it is-typiea-hv because there is a demonstrable need for the expansion, and/or it is simply good planning for future growth. GMA Purpose The proposed amendments should be rejected for many reasons. Among them is the fact that the proposed amendments would seek to penalize the City and property owners for seeking such an expansion. By requiring that a City or property owner (or owners) purchase development rights from the rural county, the County would essentially be taxing the applicant in an effort to prevent UGA expansions that would otherwise be considered not only appropriate but necessary. Department of Commerce describes development right transfers as "voluntary market-based transactions" and they provide numerous examples of communities identifying sending and receiving areas within their own communities. 1 The proposed use of a TDR program to expand UGA's is framed in a way that is likely to be neither "voluntary" nor "within the community." Instead it is most likely to become a mandatory tax or purchase of UGA area moving density from one community (the rural County) to another community (a receiving city). The proposed amendments also seek to establish a link between future urban development within a UGA and development in unincorporated areas. As we understand the theory, a mitigation measure for development in expanded Urban Growth Areas is to prevent development in unincorporated rural sending areas. While there may be a nexus between the expansion of UGAs into productive agricultural lands and the need to protect other productive agricultural lands through a TDR or PDR program, there does not appear to be such a nexus for the expansion into non-productive agricultural lands, nonessential resource lands, or other non-urban zoned lands. In fact the reverse is true: where possible, UGA's should be expanded to non-agricultural lands. Provided that this expansion is appropriate (that a future demand for the land can be established), such an expansion would in theory channel growth that could otherwise bleed into the County back into the Cities- where it belongs. The small Cities also question the County Council's unwavering confidence in a TDR program. Such programs have been shown to work in only a few situations nationally. The struggles of the existing TDR program in Bellingham may demonstrate the fact that the market does not yet demand- and could not yet support~ a traditional TDR program in which applicants voluntarily acquire development rights from sending areas in exchange for the ability to develop to higher densities in receiving areas. Apparently realizing this, members of the Whatcom County Council have sought to identify a development issue that they feel has some leverage, any leverage- and have arrived at the expansion of UGA's. While we agree that TOR's depend on restricting the supply of a product to increase demand, 1 Urban Growth Area Guidebook, Department of Commerce,

6 we question whether using UGA expansions as a lever is most appropriate to solve the issue. This program will undoubtedly make development within a future UGA more expensive. How a higher cost to create responsible urban development can be seen as a way to discourage rural growth is lost on us. Simply put, making cities buy urban growth is not the solution to the excessive rural growth. At this time, we believe,the only issue that this proposal solves is to establish a TDR program. The Cities have been prepared to have a discussion of TOR's, protecting rural lands and encouraging growth in the Cities for several years- but no effort has been made by the County to initiate these discussions. Implementing policies that suggest that TOR's are a solution, before they have shown to be one, is inappropriate and irresponsible. Density Modifications In 2014, Whatcom County and the seven Cities adopted a non-binding resolution that identified potential growth allocations. This resolution was considered three years prior to the adoption of the comprehensive plan in order to provide the Cities (and the County) with sufficient time to complete transportation and capital facilities planning. A complicated Land Capacity Analysis (LCA) was crafted; the Cities undertook substantial public outreach and examined their development and zoning codes. Consultants were hired and studies were completed. This extensive process was intended to provide the Cities, their citizens, and decision-makers with the knowledge that development regulations, comprehensive plans, financing and other factors could come together to allow future growth to occur, in the manner that it has been planned for. The process for determining future densities, and the roads and utilities to serve them, is underway and nearing completion. Now come several amendments that would "encourage" the jurisdictions to modify their density requirements. While we understand that the word "encourage" is intended to be non-binding, we also understand that such language is subject to interpretation. Comprehensive Plan policies are specifically intended to become the basis of development regulations and administrative policy, and such have substantial weight in future decision making. The word encourage (and others like it) also imply that the County would "discourage" jurisdictions from doing the opposite- implying again that there equid be penalties or sanctions against jurisdictions that cannot or do not wish to comply. This is a huge issue for the Cities. While the vast majority of the small Cities do have zones and codes in place (or that are proposed) that could meet or exceed the average densities anticipated by the County, the language of the proposed amendment appears to require that g!l residential lands meet these minimum density requirements. This is inconsistent with the Growth Management Act, and the Growth Management Hearings Board has struck down the "bright line" standards for densities that were recommended by previous Whatcom County planning administrations. Further, the Cities reject attempts by the Whatcom County Council to determine the minimum densities that are appropriate for the respective Cities; only the Growth - 3-

7 2 Recorded under Auditor's file number ~ - 4- Management Hearings Board has that authority, and at this time, the Cities are all in compliance with regard to density. As written, the Whatcom County Council is considering modifications that, if enforced, would change the character of some or all parts of each of the small Cities. The one-line phrases are a blunt-force -----emffff ortto-define-eaeh-of-the Cities anel--#ley-ighet=e-tl1e-fa.gt-that-the-tl:u::e.e=y.ear...p.w.cess described above was intended to carefully define and preserve what made each City unique. Further, these policies ignore that each City has a unique identity and 100-plus years of historical development patterns that mal<e arbitrary density thresholds chosen by others to be inappropriate. Planning is not a blunt-force directive from on high, and it is insulting that the Whatcom County Council would atte.mpt to ignore this work of local cities- especially when the end results (higher densities) of this work may result in exactly what the proposed language inelegantly seeks to "encourage." Violation of the Whatcom County-Small Cities lnterlocal Agreemene The Whatcom County-Small Cities lnterlocal agreement (lnterlocal Agreement) required Whatcom County to utilize the City's GMA compliant comprehensive plan and zoning classifications for land capacity analysis for property with the Cities. See Section 2.D.iii of the lnterlocal Agreement. Further, for property in the City's UGA but outside the City limits, assumed densities for land capacity analysis were to be determined through a collaborative process. See Section 2.D.iv of the lnterlocal Agreement. At the core, the County was required to accommodate and plan for population growth allocated to the UGA through a collaborative process. See Section 2.G and 2.N of the lnterlocal Agreement. The Cities did commit to adopt appropriate densities consistent with the State GMA, the City's Comprehensive Plan, and the density goals of the County Comprehensive Plan. See Section 3.E of the /nterlocal Agreement. This does not empower the County to impose a minimum density obligation, nor commit the Cities to a TOR program. The small Cities engaged in good faith with the County in relation to this Comprehensive Plan update. As of a month or so ago, the small cities believed that there was agreement on the Comprehensive Plan update recommendations, only to learn of the new proposals being presented to the County Council that were not presented to or reviewed by the small Cities. These new proposals we believe are in violation of the commitment to the collaborative process and requirements of the lnterlocal Agreement. Nothing in these new proposals identified above is an outcome of a collaborative process that the County obligated itself to undertake. Moving Forward In conclusion, we believe that the proposed amendments are both unnecessary and unworkable. We realize that the Whatcom County Council last entered the comprehensive plan discussion in an era of conflict and misinformation. The Cities and their staff (and we believe your staff as well) have transitioned from that mindset. We sincerely believe that there are opportunities for the Cities and County to work together to reduce development within the rural areas ofwhatcom County. We also believe that there are opportunities

8 to slow or even stop unnecessary UGA expansions. There are a number of related issues (and solutions) that are not contemplated in the Comprehensive Plan- and we hope to have that discussion with you. We a I so wish to support increased densities. Few if any of the small Cities are sustainable for the longterm with only low-density single family development. But none of the Cities will be attractive (or -----R=m~T~aFketa-b l e-}-- i HI ea5ftie-s-afe-r~~ =ed-tq-sugi~ n..gxte.t~ubaube...essent i alc.baracter of the com m un11.,_ y... is. forever lost. Until the draft changes were made available for public review, we believed that Whatcom County was on the same page as the Cities- and this gave us hope for productive progress in the future. Significant modifications to the Comprehensive Plan at this point will require re-review by the Whatcom County Planning Commission and the respective Cities. Please reject the proposed modifications described in this chapter entirely, or consider modifications as follows: Rural/Urban Development Opportunities: Establish an ad hoc committee consisting of one or more representatives of each City and the County, as well as other stakeholders to discuss opportunities and barriers to creating more efficient development within cities while restricting or decreasing development in unincorporated rural areas, with a specific emphasis on the protection or enhancement of unincorporated agricultural and sensitive areas. Densities: Encourage and support the efforts of the seven Cities of Whatcom County to establish regulations requiring that new residential development achieve local density requirements appropriate to achieve the efficient delivery of capital facilities, to encourage commerce within the jurisdiction, to generally exceed historic levels of development throughout the city or in specific areas, to protect important natural functions and wildlife corridors, and to decrease the need for expansion of Urban Growth Areas In the future. Respectfully submitted as your partners In Whatcom County's future, City Manager /ka-0~ Michael Jones, Aiel Community Development Director - 5-

9 CITY OF FERNDALE 2095 Main Street PO Box 936 Ferndale, Washington, flle UNDER AB 20 lie 0 l.\ 1 6 DATE RECEIVED: 3 f :2-'2-l J-.D It, SUBMITTED BY:. Dc,fY)DO Tro,y..,\-v- Whatcom County Council 311 Grand Avenue Suite 105 D COUNCil MEETING S s c T'f'-.1 =r-m. COMMITTEE EXHIBIT: Bellingham, WA Honorable Councilmembers, We, the undersigned small cities of Whatcom County, write to you to express our concern over several amendments proposed by you to Chapter 2 {Land Use) of the Whatcom County Comprehensive Plan. The Whatcom County Council is tasked with reviewing a broad range of subjects as part ofthe Comprehensive Plan update, and the majority of your proposed edits in Chapter 2 and other chapters reflect this fact, and our respective Cities take no issue with those edits. The Cities take issue with proposed new policy 2A-14, new policy 2R-3, amendments to Policies 2V-5,2X- 5, 2Y-3, 2Z-4, 2AA-5, and 2BB-164 (all generally associated with linking future UGA expansions with density reductions in rural areas through a Transfer or Purchase of Development Rights program). Goal 2R is also included in these amendments. The Cities also take issue with amendments to Goal 2P, generally encouraging the various cities to establish minimum residential density requirements at levels identified by Whatcom County. Issues were brought by the respective jurisdictions as early in the process as possible and the parties have generally been able to find adequate solutions to those issues. The wounds from the review process had been largely healed, and the Cities collectively believed that they could trust the County to adopt a Growth Management Act-compliant comprehensive plan in a cooperative manner. The amendments listed above, proposed less than three months before the Cities are scheduled to adopt their comprehensive plans, and without any advance discussion with the Cities, have the potential to change everything. Transfer of Development Rights (TOR) The small Cities have made clear their general support for engaging on a discussion of multijurisdictional steps that could be taken to reduce development in unincorporated rural areas. We have also made clear our opinion that members of the Whatcom County Council concluded long ago that a TDR program should be adopted, regardless of its effectiveness or its relationship to other growth Administration & City Clerk Phone: Fax: Finance Phone: Fax: Visit us at Community Development Phone: Fax: Public Works Phone: Fax:

10 issues. Members of the Whatcom County Council have sought to apply this solution to one or more issues for years. The small Cities have expressed their collective desire to have this discussion. However, the Cities are opposed to a goal or policy (non-binding or not) that seeks to tie such a program to the expansion of t-+rtjarrg-rowttr-are-a"s:-'fhin-k-hasbeerrdiscretl+ted"'ve t attd over-agaln-stnce-2tl69;-when--sptrriou-<:- s claims that the Cities sought sprawling UGA's were first made. There is little incentive for the Cities to expand their Urban Growth Areas, particularly for residential purposes, which would likely be the main target of a TDR or PDR program. When the Cities propose an expansion of their UGA's, it is typically because there is a demonstrable need for the expansion, and/or it is simply good planning for future growth. GMA Purpose The proposed amendments should be rejected for many reasons. Among them is the fact that the proposed amendments would seek to penalize the City and property owners for seeking such an expansion. By requiring that a City or property owner (or owners) purchase development rights from the rural county, the County would essentially be taxing the applicant in an effort to prevent UGA expansions that would otherwise be considered not only appropriate but necessary. Department of Commerce describes development right transfers as "voluntary market-based transactions" and they provide numerous examples of communities identifying sending and receiving areas within their own com munities. 1 The proposed use of a TOR program to expand UGA's is framed in a way that is likely to be neither "voluntary" nor "within the community." Instead it is most likely to become a mandatory tax or purchase of UGA area moving density from one community (the rural County) to another community (a receiving city). The proposed amendments also seek to establish a link between future urban development within a UGA and development in unincorporated areas. As we understand the theory, a mitigation measure for development in expanded Urban Growth Areas is to prevent development in unincorporated rural sending areas. While there may be a nexus between the expansion of UGAs into productive agricultural lands and the need to protect other productive agricultural lands through a TOR or PDR program, there does not appear to be such a nexus for the expansion into non-productive agricultural lands, nonessential resource lands, or other non-urban zoned lands. In fact the reverse is true: where possible, UGA's should be expanded to non-agricultural lands. Provided that this expansion is appropriate (that a future demand for the land can be established), such an expansion would in theory channel growth that could otherwise bleed into the County back into the Cities- where it belongs. The small Cities also question the County Council's unwavering confidence in a TOR program. Such programs have been shown to work in only a few situations nationally. The struggles of the existing TDR program in Bellingham may demonstrate the fact that the market does not yet demand- and could not yet support- a traditional TOR program in which applicants voluntarily acquire development rights from sending areas in exchange for the ability to develop to higher densities in receiving areas. 1 Urban Growt h Area Guidebook, Department of Commerce, 2012

11 Apparently realizing this, members of the Whatcom County Council have sought to identify a development issue that they feel has some leverage, any leverage- and have arrived at the expansion of UGA's. While we agree that TOR's depend on restricting the supply of a product to increase demand, we question whether using UGA expansions as a lever is most appropriate to solve the issue. This program will undoubtedly make development within a future UGA more expensive. How a higher cost to create responsible urban development can be seen as a way to discourage rural growth is lost on us. Simply put, making cities buy urban growth is not the solution to the excessive rural growth. At this time, we believe the only issue that this proposal solves is to establish a TOR program. The Cities have been prepared to have a discussion of TOR's, protecting rural lands and encouraging growth in the Cities for several years- but no effort has been made by the County to initiate these discussions. Implementing policies that suggest that TOR's are a solution, before they have shown to be one, is inappropriate and irresponsible. Density Modifications In 2014, Whatcom County and the seven Cities adopted a non-binding resolution that identified potential growth allocations. This resolution was considered three years prior to the adoption of the comprehensive plan in order to provide the Cities (and the County) with sufficient time to complete transportation and capital facilities planning. A complicated Land Capacity Analysis (LCA) was crafted; the Cities undertook substantial public outreach and examined their development and zoning codes. Consultants were hired and studies were completed. This extensive process was intended to provide the Cities, their citizens, and decision-makers with the knowledge that development regulations, comprehensive plans, financing and other factors could come together to allow future growth to occur, in the manner that it has been planned for. The process for determining future densities, and the roads and utilities to serve them, is underway and nearing completion. Now come several amendments that would "encourage" the jurisdictions to modify their density requirements. While we understand that the word "encourage" is intended to be non-binding, we also understand that such language is subject to interpretation. Comprehensive Plan policies are specifically intended to become the basis of development regulations and administrative policy, and such have substantial weight in future decision making. The word encourage (and others like it) also imply that the County would "discourage" jurisdictions from doing the opposite- implying again that there could be penalties or sanctions against jurisdictions that cannot or do not wish to comply. This is a huge issue for the Cities. While the vast majority of the small Cities do have zones and codes in place (or that are proposed) that could meet or exceed the average densities anticipated by the County, the language of the proposed amendment appears to require that.ill.[ residential lands meet these minimum density requirements.

12 2 Recorded under Auditor's file number ~ This is inconsistent with the Growth Management Act, and the Growth Management Hearings Board has struck down the "bright line" standards for densities that were recommended by previous Whatcom County planning administrations. Further, the Cities reject attempts by the Whatcom County Council to determine the minimum densities that are appropriate for the respective Cities; only the Growth Management Hearings Board has that authority, and at this time, the Cities are all in compliance with regard to density. As written, the Whatcom County Council is considering modifications that, if enforced, would change the character of some or all parts of each of the small Cities. The one-line phrases are a blunt-force effort to define each of the Cities and they ignore the fact that the three-year process described above was intended to carefully define and preserve what made each City unique. Further, these policies ignore that each City has a unique identity and 100-plus years of historical development patterns that make arbitrary density thresholds chosen by others to be inappropriate. Planning is not a blunt-force directive from on high, and it is insulting that the Whatcom County Council would attempt to ignore this work of local cities- especially when the end results (higher densities) of this work may result in exactly what the proposed language inelegantly seeks to "encourage." Violation of the Whatcom County-Small Cities lnterlocal Agreement 2 The Whatcom County-Small Cities lnterlocal agreement (lnterlocal Agreement) required Whatcom County to utilize the City's GMA compliant comprehensive plan and zoning classifications for land capacity analysis for property with the Cities. See Section 2.D.iii of the /nterloca/ Agreement. Further, for property in the Citys UGA but outside the City limits, assumed densities for land capacity analysis were to be determined through a collaborative process. See Section 2.D.iv of the lnterlocal Agreement. At the core, the County was required to accommodate and plan for population growth allocated to the UGA through a collaborative process. See Section 2.G and 2.N of the lnterlocal Agreement. The Cities did commit to adopt appropriate densities consistent with the State GMA, the City's Comprehensive Plan, and the density goals of the County Comprehensive Plan. See Section 3. of the lnterlocal Agreement. This does not empower the County to impose a minimum density obligation, nor commit the Cities to a TDR program. The small Cities engaged in good faith with the County in relation to this Comprehensive Plan update. As of a month or so ago, the small cities believed that there was agreement on the Comprehensive Plan update recommendations, only to learn of the new proposals being presented to the County Council that were not presented to or reviewed by the small Cities. These new proposals we believe are in violation of the commitment to the collaborative process and requirements of the lnterlocal Agreement. Nothing in these new proposals identified above is an outcome of a collaborative process that the County obligated itself to undertake. Moving Forward In conclusion, we believe that the proposed amendments are both unnecessary and unworkable. We realize that the Whatcom County Council last entered the comprehensive plan discussion in an era of

13 conflict and misinformation. The Cities and their staff (and we believe your staff as well) have transitioned from that mindset. We sincerely believe that there are opportunities for the Cities and County to work together to reduce development within the rural areas of Whatcom County. We also believe that there are opportunities t-.crsfuw-oreven stop or 11 recessary-i:j'5a-expansions. Tlrer e-are-a-no mbero f-retated- i ssuestand -soiutr0"1"' 1 S~) that are not contemplated in the Comprehensive Plan- and we hope to have that discussion with you. We also wish to support increased densities. Few if any of the small Cities are sustainable for the longterm with only low-density single family development. But none of the Cities will be attractive (or marketable) if densities are required to such an extent that the essential character of the community is forever lost. Until the draft changes were made available for public review, we believed that Whatcom County was on the same page as the Cities- and this gave us hope for productive progress in the future. Significant modifications to the Comprehensive Plan at this point will require re-review by the Whatcom County Planning Commission and the respective Cities. Please reject the proposed modifications described in this chapter entirely, or consider modifications as follows: Rural/Urban Development Opportunities: Establish an ad hoc committee consisting of one or more representatives of each City and the County, as well as other stakeholders to discuss opportunities and barriers to creating more efficient development within cities while restricting or decreasing development in unincorporated rural areas, with a specific emphasis on the protection or enhancement of unincorporated agricultural and sensitive areas. Densities: Encourage and support the efforts of the seven Cities of Whatcom County to establish regulations requiring that new residential development achieve local density requirements appropriate to achieve the efficient delivery of capital facilities, to encourage commerce within the jurisdiction, to generally exceed historic levels of development throughout the city or in specific areas, to protect important natural functions and wildlife corridors, and to decrease the need for expansion of Urban Growth Areas in the future. Respectfully submitted as your partners in Whatcom County's future, "~-P- nmu~ Ie r Mayor, City'of Ferndale