Please submit to the GMA Record for the 2005 Oak Harbor UGA and 2005 Comp Plan Amendments.

Discrepancies and areas of concern regarding Finding 35 of the Island County Planning & Community Development Report, Island County Planning Commission: CPA 155/04 Population and Urban Growth Areas.

Finding 35: “During the end of 2004 and all of 2005 the Comprehensive Plan Task Force held numerous public meetings regarding options for urban growth area policies. The Task Force evaluated a land capacity analysis prepared by city staff. The analysis was conducted for lands within the municipal boundary of Oak Harbor and for lands within the unincorporated portion of the urban growth area. The land capacity analysis determined that the existing urban growth area (within both the city and the unincorporated areas) was capable of accommodating 106% of the 2025 population projection.” The 106% capacity deserves closer scrutiny. Said 106% capacity is misrepresented and is artificially low. In fact, the existing capacity is significantly higher.

The City of Oak Harbor did a detailed Land Capacity Analysis titled Technical Paper No.1 Urban Growth Area Housing Capacity Analysis, attached Exhibit ”A”, pages 1,2,3,4. It is based on an analysis of individual land parcels within the city limits and the Urban Growth Boundaries at that time, April 1, 2004. The methodology and criteria used to perform this analysis contains a number of assumptions built in to the calculations that served to depress the existing land capacity:

i.)RE: Fine Tuning the Assumptions, Item 2: Oak Harbor ignored parcels arbitrarily on the basis that there was “no clear economic benefit for redevelopment”. Redevelopment, also known as infill, of these types of parcels directly support GMA goals and thus improve quality of life and protect rural land, forests, family farms and natural areas. For example, all smaller, underdeveloped lots in the city were ignored. These lots can be used very effectively to provide affordable housing with the construction of accessory dwelling units (a mother-in-law suite above or beside a garage, addition to existing house or a cottage in a large yard). Oak Harbor zoning codes allows such accessory dwelling units. There are hundreds of such properties. As a second example, extra capacity was counted within only two mobile home parks. Investors recognize mobile home parks as ideal land holding opportunities with interim cash flow until the market is ripe for a higher and better use for the land. The “no clear economic benefit” (as of April 4, 2004) assumption alone provides an uncalculated cushion masking hundreds of potential affordable housing units within existing city limits.

ii.)RE: Fine Tuning the Assumptions, Item 5: Oak Harbor did not consider any of the parcels located on arterials in the Residential Office (RO) zone as having any capacity for residential zoning. Nor were various vacant parcels located within commercial zones counted in the capacity analysis. These are wonderful locations for mixed-use projects because of easy accessibility to public transit, shopping and public facilities.

There is now the opportunity to compare the 2004 government estimate of capacity to the actual capacity realized on those land parcels that have gone through the permitting process and/or are currently going through the permitting process in the three years subsequent to April 1, 2004.


Source: Information published in the Whidbey News Times, Island County records, or information verified by owner.

Using the same methodology that was originally used in the parcel by parcel analysis of vacant and underdeveloped land that resulted in a 106% land capacity, there is conservatively an additional 8.21% unrecognized additional capacity that has been or is in the process of being realized via the permitting process in the time elapsed since the Oak Harbor Land Capacity Analysis was presented to the Task Force.

Using the same methodology as Oak Harbor used in Technical Paper No. 1, attached as Exhibit “A”, page 4 the revised, more accurate table on the last page of said document:


The comparison of the government estimated capacity and the results of those parcels that have been permitted for development and/or are in the process of being permitted since April 1, 2004, in conjunction with Fine Tuning the Assumptions Items 2 & 5 illustrate a significant inherent cushion in the existing Oak Harbor land capacity that was presented to the Task Force in 2004 and 2005.

It is recommended that no additional land is included in the Oak Harbor UGA at this time.

Discrepancies and areas of concern regarding Finding 38 of the Island County Planning & Community Development Report, Island County Planning Commission: CPA 155/04 Population and Urban Growth Areas.

Finding 38: “In a letter dated November 14, 2006 the City of Oak Harbor provides six reasons that support their decision to choose a 126.5% capacity over other options.” The decision to choose this excess capacity deserves closer scrutiny. Excess capacity is not warranted.

Re: Finding 38a. “Providing a larger cushion will help maintain affordable housing.”

This Finding is not factual with regards to Areas 3 & 4 specifically and is questionable with regards to all potential Inclusion Areas.

According to conventional wisdom, the maximum amount of income that can be allocated to mortgage payments for “affordable housing” is 28% of the median household income. Sometimes this is rounded up to 30% of the median household income as the acceptable maximum percentage of income devoted to basic housing costs (mortgage payments, property taxes, insurance).

There are no 2006 sales of new construction in the western outskirts of Oak Harbor, on Whidbey Island within one mile of the Area 3&4 assemblage that are affordable to the median wage household in Island County or the median wage household in the State of Washington, see Table 1.


The lowest price 2006 home that was “new construction” within a mile of Areas 3&4 yields a hypothetical housing cost of 40.59% to an Island County median income household and a hypothetical housing cost of 40.68% to a WA State median income household. The median price new construction within a mile of Areas 3&4 yields a hypothetical housing cost of 48.94% to an Island County median income household and a hypothetical housing cost of 49.06% to a WA State median income household, see Table 2.

These homes that have been built in 2006 are not ocean view acreage either. Ocean view lots are significantly more valuable for upper-end housing than non-ocean view lots. The Fakkema Farm assemblage (Area 3&4) is false with regards to encouraging availability of “affordable housing to all economic segments of the population of this state” because it is a prime ocean view property of the Strait of Juan de Fuca. The Fakkemas have in fact named their farm: Beach View Farms.


The overwhelming majority, if not all of 2006 residential construction within a mile of Oak Harbor UGA expansion Area 3&4 consist of upper-middle class single family residences - most in gated communities, in “Adult only” and/or ”Over 55” communities. The neighborhood surrounding Area 3&4 consists of: Whidbey Golf & Country Club, which is a private golf club one street removed to the east; middle to high-end housing, older farms and some very large homes on farmettes to the north and south; beach front homes and custom upper-middle class homes to the west. It is inconceivable that Area 3&4 will be developed into “affordable housing to all economic segments of the population of this state”.

Good planning for affordable housing includes walkable, mixed-use communities and multi-modal community transit-oriented development strategies. None of the acreage that is pending for the expanded UGA is within walking distance to the Oak Harbor urban core area and its various amenities: a community college, library, marina, parks, various shopping venues, commercial businesses that provide jobs, post office, excellent fare-free transit system, and utility infrastructure systems: water, sewer, utility and roads. Automobile ownership will be essential for residents in all Oak Harbor UGA annexation Areas. The 2006 homes in Table 1 within a mile of Areas 3&4 in fact are providing multi-car garages for families in adult communities, see photo below. The requirement to own a personal automobile is inextricably linked to owning such housing and therefore additional homes that are even further out from the Oak Harbor urban core will not be “affordable housing to all economic segments of the population of this state”.

Transportation costs are increasingly recognized as an integral factor in housing costs to reflect true housing affordability.1

Locations of all UGA inclusion Areas are too far from town to be within walking distance to the Oak Harbor urban core.

The proposed excess housing capacity for the next 20 years growth within the pending expanded Oak Harbor UGA will not …“encourage the availability of affordable housing to all economic segments of the population of this state”. It provides for predominantly single family suburban housing and exacerbate the continued, inappropriate conversion of undeveloped farmland into sprawl.

Re: Finding 38b. “It is prudent to have a supply of residential land that can respond to unforeseen conditions (e.g. changes as NASWI)”.

Item 4 under Fine Tuning the Assumptions, page 2 of the City of Oak Harbor 2005 Comprehensive Plan Amendments Technical Paper No. 1 Urban Growth Area Housing Capacity Analysis: “NAS Housing – Based on input from NAS personnel, the housing capacity analysis assumed no net increase in the amount of military housing inside the Urban Growth Area. Likewise, the housing need does not anticipate any increase in military personnel.”

NAS Whidbey Island has entered into an agreement with American Eagle to demolish 160 homes at Crescent Harbor plus an additional 100 homes at the Seaplane Base in preparation for construction of 360 new homes for military families in Oak Harbor2. This reflects and unrecognized additional 100 military units that are unaccounted for in any of the capacity calculations.

The City of Oak Harbor has not demonstrated any need for additional housing needs such as changes in NASWI.

Re: Finding #38c:“The larger cushion will promote more housing choices (a diversity of housing)” and #38f. “The public is best served by more choices rather than fewer choices”.

These two reasons are redundant. The GMA goal that most closely relates to finding 38c & 38f is that portion of Goal #4…“promote a variety of residential densities and housing types”. The excess capacity will not promote a variety of residential densities and housing types. The excess capacity will encourage continued, low-density sprawl.

History since the implementation of GMA in 1990 has shown that when abundant choices are available in Oak Harbor, sprawl will result.


1US Census including Seaplane base population for the respective year. (Next US Census: 2010).

2US Census - including Seaplane base: +/-2897.7 acres per City of Oak Harbor

Table 3 analyzes the decrease in Oak Harbor population density on the assumption that the NASWI Sea Plane Base is within the City Limits of Oak Harbor geographically and assumes that Oak Harbor has control over the land use and zoning of NASWI Sea Plane Base. In reality NASWI Sea Plane Base is not within the city limits for the purpose of civilian population planning and zoning. It is for the exclusive use of NASWI. Thus Table 3 does not give the most accurate analysis of density trends of the civilian population under the jurisdiction of the City of Oak Harbor. Table 3 was presented to the Island County Planning Commission on October 24, 2006.

Subsequent to said presentation, a more refined analysis has been performed. Table 4 analyzes the density trends of the civilian population under the jurisdiction of the City of Oak Harbor (net of the land area and population of NASWI Seaplane Base).


1US Census excluding Seaplane base population for the respective year. (Next US Census: 2010).

2US Census - excluding Seaplane base: +/-2897.7 acres per City of Oak Harbor

In the ten years between the 1990 Census and 2000 Census the population growth of the citizens within the control of Oak Harbor land use and planning was 23.96%. In that time period, Oak Harbor City Limits expanded geographically by 53.59%. There has been a decrease in the population density of –19.34% within Oak Harbor city limits between the US Census Years 1990 and 2000. Including additional land that is even further out from the Oak Harbor urban core will exacerbate decreased density trends unless population and job growth keeps up. Non-military job growth has been elusive for Island County. The Oak Harbor urban core has been deteriorating. When there is market demand for additional housing, the urban core will be developed when that is the most attractive option to the developers and builders.

A negative change in density indicates urban sprawl. People are moving out away from the city core, which is left to deteriorate. People are moving into former rural areas, which then becomes suburbs of the city. For example, Ft. Nugent Road and Swantown Road areas.

Using their own calculations, Oak Harbor is already is weighted toward Single Family Residential (R1) zoned capacity without additional UGA Inclusions. The Results of Technical Paper No. 1 Urban Growth Area Housing Capacity Analysis conclude that Oak Harbor total housing capacity as of April 1, 2004 is 3,392 units:

  • 44.1% = 1,497 units are Low Density Residential (R1)
  • 22.8% = 773 units Medium Density Residential (R2)
  • 9.4% = 318 units Medium Density Residential (R3)
  • 17.4% = 590 units High Density Residential (R4)
  • 2.5% = 84 units Residential Office (RO) aka Mixed-use
  • 3.5% = Commercial Districts (CBD and C3)
  • <.1% = Residential Estate (RE)

The existing housing capacity consists of more “Low Density Residential” capacity (R1) than any other type of capacity. Additional UGA Inclusions will skew the balance even further towards single family, automobile dependant homes. This is not more housing choices (a diversity of housing) – this is sprawl.

Re: Finding #38d: “It will encourage development of certain properties to occur under urban standards rather than rural ones.”

This reason is in direct conflict with a number of GMA goals:

i.)GMA goal: encourage development in urban areas where adequate public facilities and services exist or can be provided in an efficient manner because the UGA inclusion Areas will occur where adequate public facilities do not currently exist and requires multi-million dollar public investment in the infrastructure of roads, sewer, water required for development. Said investment is unaffordable to the City of Oak Harbor without raising taxes.

ii.)GMA goal: to encourage efficient multimodal transportation systems that are based on regional priorities and coordinated with county and city comprehensive plans. The Areas to be annexed are not close enough to be within walking distance to the urban core or large enough to encourage efficient multimodal transportation systems. They will always be dependant on the automobile. There will be a foreseeable increase in traffic accidents as a result of traffic congestion and dumping of traffic onto SR20, which is simultaneously a Highway of Statewide significance and the main street in Oak Harbor.

iii.)GMA goal: to maintain and enhance natural resource-based industries, including productive timber, agricultural, and fisheries industries. Encourage the conservation of productive forestlands and productive agricultural lands and discourage incompatible uses. The urban development standards referenced in this reason will cause urban density. In Areas 3,4,5,6 and possibly 2 & 8 this density causes increased non-point pollution leading from suburban housing: pesticides, cleaners, gasoline, oil, brake fluid, etc. into Swan Lake downstream, and thus contaminate and degrade this pocket estuary downstream from said development. This will in turn, hinder any possibility of salmon habitat restoration that will help maintain the fishing industry.

iv.)GMA goal: Protect the environment and enhance the state’s high quality of life, including air and water quality, and the availability of water. The Areas annexed will be converted from farmland to urban density and covered with many impervious surfaces: rooftops, driveways and road systems. Areas 3,4,5,6 and possibly 2 & 8 will exacerbate flooding of Swan Lake and its surrounding wetland. Island County references this concern in the document known as: Salmon Habitat Limiting Factors Water Resource Inventory Area 6 Island County by Washington State Conservation Commission, April 2000, page 105.

The Goals of the Growth Management Act are to be used exclusively for the purpose of guiding the development of comprehensive plans and development regulations. This one statement arguably violates four of the 13 GMA Goals all by itself. It is not compliant with the Growth Management Act.

In summary, Finding 38, which rationalizes excess housing capacity, does not support the fundamental reason for the GMA, which is to keep the city growing within its boundaries and preserve rural character, thereby protecting the quality of life for Island County.

In lieu of adding rural land into the Oak Harbor UGA, we need to think outside the box.

Reasonable measures to achieve GMA Goal oriented development include, but are not limited to:

  • Increasing the density and height allowed within existing Multi-Family Residential zones and R-O zones.
  • Encouraging R-O zoned properties located on arterial streets to be developed in a mixed-use style and discouraging R-O zoned properties located on arterial streets to be developed into exclusively office use, as assumed in Assumption #5 of Technical Paper No. 1 Urban Growth Area Housing Capacity Analysis.
  • Expanding the geographic area of Multi-Family Residential zones into adjacent Single Family Residential zones (“R-1”) zones that are within walking distance to the Oak Harbor urban core.
  • Encouraging accessory dwelling units on underutilized parcels within walking distance to the Oak Harbor urban core.
  • Reinstating a transfer of density credit program for Island County that takes advantage of the Oak Harbor urban core.

Due to the above discrepancies and areas of concern regarding Findings 35 & 38 of the Island County Planning & Community Development Report, Island County Planning Commission: CPA 155/04 Population and Urban Growth Areas it is recommended that no additional residential land be added to the Oak Harbor UGA at this time.