Whidbey Environmental Action Network

Whidbey Environmental Action Network

Restoration Education Preservation

Box 53, Langley, WA USA 98260

(360) 579-4202

Dedicated to the preservation and restoration of the native biological diversity

of Whidbey Island and the Pacific Northwest

Oct.7, 2010

TO:Board of Island County Commissioners

FROM:Steve Erickson

RE:CPA 155/04 Oak Harbor UGA Expansion

Whidbey Environmental Action Network urges the Board of County Commissioners not to adopt CPA 155/04 as recommended by the Planning Commission. Instead, the Board should change the proposal so it excludes the UGA additions proposed for residential development on the west side of Whidbey Island. Our reasons for opposing the expansion as proposed are:

1) Expansion for residential development is not needed.

2) The expansion to the west of Oak Harbor will have significant adverse environmental impacts.

3) The expansion will destroy the viability of the Fakkema farm as a functional unit, cause the large immediate loss of viable agricultural land in active farm use, and inevitably lead to the further loss of the remainder of the Fakkema farm to urban and sprawl development.

4) The expansion to the west threatens to make implementation of GMA’s requirement for greenbelts and the interlocal agreement between Oak Harbor and Island County, part of the county-wide planning policies, moot.

We address these reasons in more detail below.

1) Expansion for residential development is not needed.

As pointed out in the staff report, at the time when Oak Harbor requested the expansion the city had at least 106% of the residential capacity it would need in 2025. Considering the economic recession and great reduction that has occurred in new residential development since then, there appears to be no real need for any expansion at this time. Upcoming UGA reviews will be using more current population data and forecasts.

Additionally, as GayLynn Beighton will show in her testimony and submission, the analysis performed by Oak Harbor to justify the UGA residential expansion was woefully inaccurate and grossly underestimated the existing and potential residential capacity within the existing UGA. The City of Oak Harbor has no need to sprawl outward into the rural and agricultural county. Its time for Oak Harbor to grow up, not out.

2) The expansion to the west of Oak Harbor will have significant adverse environmental impacts.

Because environmental issues related to the proposed UGA expansion will be dealt with at length in a different forum, we will just summarize them here.

First, this will immediately and ultimately cause the loss of a large area of viable farmland in active agricultural use. This is discussed in more detail below. It is important to realize that over the long term this farmland is important in major part because of its close proximity to an urban area. As the economic and environmental costs of food transportation become more pronounced due to climate change and the decline of cheap fossil fuels, this proximity will be a major environmental and economic advantage for this farm.

Second, the Fakkema farm drains directly into Swan Lake, a coastal pocket lagoon used by about 1/6 of all bird species reported from the contiguous United States. The lagoon has also been judged to have high value for salmonid use given appropriate restoration, which is currently being studied. Likewise, the proposed Cohick and Hillcrest additions drain into the very high quality wetland in Joseph Whidbey State Park. Simply because of the proposed location, urban development will degrade both water and aquatic habitat quality.

Third, urban expansion by Oak Harbor threatens to create a complete barrier across the entire island to north-south movement of terrestrial wildlife. This habitat fragmentation would have very severe long term impacts to wildlife viability on central and south Whidbey. This is because it would fragment these populations from more northerly ones on north Whidbey and Fidalgo. Over the long term, this genetic isolation is likely to result in in-breeding and loss of fitness for non-migratory birds and amphibians on central and south Whidbey. Once isolated, as these populations’ sizes fluctuate over time, their “rescue” and recolonization from local extinction events (extirpations) will be impossible.

3) The expansion will destroy the viability of the Fakkema farm as a functional unit, cause the large immediate loss of viable agricultural land actively being farmed, and inevitably lead to the further loss of the remainder of the Fakkema farm to urban and sprawl development.

The Planning Commission’s recommendations contain several findings which are factually inaccurate regarding the existing use of this land. The land is still being actively farmed. Attached is a montage of photos taken in late August, 2007, nine months after the Planning Commission found that “The Fakkema Farm is no longer an operating commercial farm.” The entire farm was in active agriculture during that summer. If you blow up the photo montage, tractors in operation are visible. The hillside with the corn crop, above the farm buildings, is part of the area proposed for urban development. In fact, the Fakkema farm is in active commercial agricultural use. Moreover, the UGA expansion would include the farm buildings. Hence, even though the City is not proposing urbanization of the remaining 272 acres at this time (even though the Fakkemas have proposed this), the immediately proposed UGA expansion would fracture the farm as a functioning unit, removing the building infrastructure from most of the land. And that land includes extensive areas of both Rural and Commercial Ag zoned land. Conservation of farmland is an explicit and primary goal of GMA.[1] The proposed UGA expansion runs counter to this goal.

GMA requires designation of open space corridors within and between urban growth areas.[2] This requirement is echoed in the interlocal agreement between Oak Harbor and the County, which is part of the County-wide Planning Policies. To date, no open space corridors or greenbelts around Oak Harbor have been identified. Options for identification will be severely reduced if the proposed UGA expansion is approved. As discussed above in #1, loss of the remaining corridor for terrestrial wildlife movement on the west side of Whidbey will have very serious long term consequences for nonmigratory terrestrial wildlife on central and south Whidbey. Identification of this corridor in the Oak Harbor area is a very high priority and should be performed during the upcoming belated update of the Fish and Wildlife Habitat Conservation critical area regulations.

For the above reasons, we urge the Board of Island County Commissioners to reject CPA 155/04 and instead limit Oak Harbor’s UGA expansion to the single nonresidential area on the north end of Oak Harbor.

[1] RCW 36.70A.020 (8) Natural resource industries. Maintain and enhance natural resource-based industries, including productive timber, agricultural, and fisheries industries. Encourage the conservation of productive forest lands and productive agricultural lands, and discourage incompatible uses.

[2] RCW 36.70A.160

Identification of open space corridors -- Purchase authorized.

Each county and city that is required or chooses to prepare a comprehensive land use plan under RCW 36.70A.040 shall identify open space corridors within and between urban growth areas. They shall include lands useful for recreation, wildlife habitat, trails, and connection of critical areas as defined in RCW 36.70A.030. Identification of a corridor under this section by a county or city shall not restrict the use or management of lands within the corridor for agricultural or forest purposes. Restrictions on the use or management of such lands for agricultural or forest purposes imposed after identification solely to maintain or enhance the value of such lands as a corridor may occur only if the county or city acquires sufficient interest to prevent development of the lands or to control the resource development of the lands. The requirement for acquisition of sufficient interest does not include those corridors regulated by the interstate commerce commission, under provisions of 16 U.S.C. Sec. 1247(d), 16 U.S.C. Sec. 1248, or 43 U.S.C. Sec. 912. Nothing in this section shall be interpreted to alter the authority of the state, or a county or city, to regulate land use activities. The city or county may acquire by donation or purchase the fee simple or lesser interests in these open space corridors using funds authorized by RCW 84.34.230 or other sources.