01/27/2011: "An Open Letter To The County Council"
(Miki Brostrom addresses County Council)
Honorable Council Members:
It appears to me that the Public Participation Process outlined here is impossibly complicated. [Link to Shoreline Mater Plan Update ]
First of all, this effort is not supposed to create a new plan, which this appears to do. It is supposed to be a review and update of the existing plan, the plan we already have, which was adopted in 1998.
It is not just the State that requires public participation. The 1998 Comprehensive Plan states that, “San Juan County is committed to an inclusive, on-going process of open dialog, effective communication, community education, and broad public participation in the development of (its) Comprehensive Plan.”[San Juan County Comprehensive Plan Introduction.4.] And “public” does not mean just those entities clamoring for changes in the regulations; it means representative participation by as many citizens with as many perspectives and from as many of the islands as possible.
In the early 1970’s, after State adoption of the Shoreline Management Act, the county developed its original Shoreline Master Plan through citizen, local, neighborhood groups. I don’t think anyone on the current council, and certainly no one in the Planning Department, was involved in formulation of that original plan, but there are citizens still here who were. It was a true grassroots effort. For the 1998 update, the County Commissioners appointed three Citizen Advisory Committees, some 46 individuals representing a broad range of interests, to guide the effort [San Juan County Comprehensive Plan Introduction.4], resulting in a plan produced by and for its citizens; again, a grassroots effort. This 2011/2012 update appears to be driven by the Planning Department, with predetermined objectives and “representative parties” identified and invited by them. This is not “grassroots”, and is a distinct departure from previous efforts.
It is the shoreline owners and people who live here, and those of us who have been here for many years, who recognize and can articulate the changes that have occurred, who know intimately current conditions and the areas that are damaged, degraded or impaired.
While anecdotal, this is also a starting point for public participation which, together with the numerous -and many- scientific studies which have been done by local, regional and state agencies, should be the basis of any updated plan. Putting this information together should not be a complicated process.
The current Comprehensive Plan, of which the Shoreline Master Program is one element, has a Vision Statement; it has Goals, Policies and Regulations. The Comprehensive Plan Element 3 contains the goals and policies of shoreline use and is considered Part 1 of the Shoreline Master Program. Shoreline use regulations which implement the goals and policies are contained in the Unified Development Code, which is Part 2. [San Juan County Comprehensive Plan 3.1.B.] There is a clear separation between Part 1 and Part 2.
The proposed public participation plan for this update appears haphazard, throwing everything together, goals, policies and regulations, without an orderly progression. Goals and policies should guide the regulations, not the other way around. The process would be much simpler and understandable, more cohesive, if it were to start with a focused examination of the shoreline plan we currently have, section by section, goals and policies first, and in the light of scientific data. Only when goals and policies are defined as expression of responsibilities should implementing regulations be considered and, if necessary, responsibilities and regulations and property rights reconciled.
The four points I ask the Council to consider are these:
1. Please respect the history of how the existing 1998 plan came to be and the broad range of interests and perspectives included in its development;
2. Please keep in mind that San Juan County is not composed of just three or four major islands, and that the outer, non-ferry-served islands have some of the most vulnerable shorelines;
3. Please use the existing plan as the basis of the update; and
4. Please clearly separate the Goals and Policies, Part 1, from the Regulations, Part 2, so that the cart isn’t ahead of the horse!
And one last thing: The Director is quoted as recently saying that, “Ultimately it is the responsibility of the property owner to know what the codes are…” even when the county doesn’t know itself. Please make sure this time that the county -a well as the citizens- know -and understand- what the code says.