In April 1997, the Public Good Project presented a research report, The Castle Upon the Hill, to the Commission. In that report, we made six requests to the Commission. In this report, we revisit those requests, review the City's responses, and make some recommendations.
Of the six requests, we find that two have been satisfied and four were disregarded. Two observations emerge from the City's failure to address previous requests:
We urge the Commission to prepare recommendations for process guidelines and forward these to the City Council for action as an amendment to the Bellingham Comprehensive Plan. The suggested process for the Happy Valley neighborhood plan update is a good beginning, but it should be made clear that the process applies to all neighborhoods uniformly.
We urge the Commission to redraft the WWU neighborhood plan update to remove any suggestion that it relies on the WWU DCMP. By adopting the WWU DCMP as the basis of a neighborhood update, the City will assume the liability of demonstrating that the process which generated the University's draft meets GMA goals. This is a manifest impossibility.
Convene an open discussion between the University, the neighbors, and the City on the process to clarify the procedure for neighborhood sub-area plans. Invite the Washington Department of Community, Trade and Economic Development (DCTED) to participate as a moderator/facilitator of this open discussion.
No such discussions have taken place. Instead, there has been a half-year of hearings, unofficial meetings convened by the University (at the suggestion of City staff) which were misrepresented as part of the formal planning process and extensive confusion on the part of the Commission and staff as to what the process is and where it is going. This confusion continues today and the City is still as far from compliance with GMA public participation requirements as they were at the beginning of the year.
In addition, DCTED informed the neighbors that it could only participate in such a process upon the request of the City. Absent any cooperation in this matter by the City, the citizens are unable to avail themselves of the resources of a state agency which ostensibly exists to assist them.
Prepare a written policy and procedure for the neighborhood sub-area plans as part of the comprehensive planning process. The City does not currently have these documents and is out of compliance with GMA process goals in this regard.
In the record of these hearings, there have been at least two clear instances of staff putting forward what they claim to be process documents:
The City is making up the rules as it goes along. Zig-zagging with a series of ad hoc and irregular process guidelines fails to meet GMA public participation goals and clearly calls into question any result arrived at by the Commission.
Begin the institutional master planning process for WWU immediately. If it is not found possible to begin this process, the reasons for this decision should be clearly stated and made part of the record.
We are pleased that the City has begun the consideration of an IMP for Western. Given the current state of affairs, it is reasonable to complete the WWU neighborhood plan update as a precondition to the IMP. We note that the confusion over the public participation process in the neighborhood plan update has now expanded into confusion over public participation in the IMP process.
Examine the SEPA scoping process of the Master Plan to determine if it was adequate. The record suggests that scoping did not address annexation south of Bill McDonald Parkway, the potential area-wide impact of the proposed cross-city arterial from Holly and Garden to the Old Fairhaven Parkway and several other issues of vital concern to the comprehensive planning process. If the Commission determines that scoping was inadequate, the commission should assume the role of the lead agency and conduct a new scoping hearing under SEPA with the University as the proponent.
The City has disregarded this request entirely, while the Planning staff have produced two draft WWU neighborhood plans which are mangled copies of the WWU DCMP.
The use of the WWU DCMP as a foundation for a neighborhood plan is absurd, since the University has repeatedly stated the WWU DCMP: is only a draft; is subject to continuing revision of the WWU Strategic Plan; and lacks the approval of the WWU trustees and certainly will not be implemented in its present form.
Furthermore, we note that the WWU DCMP contains many elements that conflict with the University's new articulation of strategic goals, city-wide planning goals, local comprehensive land use ordinances, state statues and the University's current funding authorizations from the legislature. In light of these issues, the validity of the SEPA scoping process pales in significance, but it still represents a critical issue that the Commission should not ignore.
Disentangle the WWU Master Plan development, some of which has been underway for a considerable time and currently is continuing, from the City of Bellingham Comprehensive Plan neighborhood sub-area plan.
The City has chosen to adopt the WWU DCMP as the basis for the WWU neighborhood sub-area plan. This is startling in light of the statements by acting Commission Chair Judith Wiseman that the commission will not review the WWU DCMP. Incorporation without review is about as far from disentangling as it is possible to get. If they chose to incorporate the WWU DCMP as the basis for WWU neighborhood plan update, the City should understand that they also inherit all of the failures of the WWU DCMP process under the GMA.
Consider minimal modifications to the existing neighborhood boundaries. Instead of altering the boundaries of the neighborhoods adjacent to WWU, incorporate the University as a member and participant in other neighborhoods. This would solve part of the conflicts with the Happy Valley and WWU neighborhood by making WWU one of many neighbors in Happy Valley.
Happily, the September 11 memo from Patricia Decker addresses this request.
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