How to Comment

Testify at the Public Hearing at 6pm on November 29.  Join the Hearing here. (3 minute limit on comments)

Submit written comments to mallen@co.okanogan.wa.us before the 29th at 12pm.

You can read the full Comp Plan on Okanogan County’s website here. At the bottom of this comment guide see other important dates in the Comp Plan timeline.

Same Plan, New Look

In March 2021, Methow Valley community members turned out in force again, sharing over 100 thoughtful comments in support of a Plan to protect what’s important – fish and wildlife, open spaces, dark skies, agriculture, property owners and first responders – and provide for affordable housing, sustainable recreation and climate resilience. The Planning Commission (PC) met with the intent of considering public comments but dismissed all comments from the Valley and recommended adoption of Alternative 3. The PC recommendation was supposed to be considered by the County Commissioners in June at a new public hearing, but instead the Plan disappeared for months behind closed doors without any explanation.

The Comp Plan re-emerged in early November as a revised draft presented to the Planning Commission (PC). Planning Director Pete Palmer reported that the Plan had been worked over by the county’s hired legal team. A new, expedited timeline was presented to fast-track the Plan for approval by the end of this year, with no changes allowed to be proposed by the PC.

The Methow Valley More Completely Planned Area (sub area) provisions will not be adopted with the Comp Plan, according to the new timeline. Instead, the Methow sub area plans will be considered by Commissioner-appointed local committees and appended to the Comp Plan sometime in the future. In the interim, it is unclear which Plan will guide land use decisions in the Methow.

Director Palmer further explained the orders she was given: the PC’s only action could be to recommend adoption to the Commissioners, whose only option will be to accept the recommendation or remand the Plan back to the PC. This makes us wonder if public comment will be considered at all. Legally, the Planning Commission is required to consider public comments and to suggest changes accordingly. We know that if more comments are submitted it will be harder to ignore these collective comments.

Given the amount of time that has passed, and the county’s investment in editing by a legal team, we expected a much-improved Plan that would at a minimum be responsive to the legal concerns that started this process over 5 years ago. We were disappointed to find that not much has changed.

The new draft of the Comp Plan has been reorganized and has a more traditional structure that is easier to navigate – at least on the surface. The use of numbered goals and objectives also makes it easier to connect concepts. Beneath the surface however, the Plan doesn’t function at a basic level. For example, the pages don’t match up with the Table of Contents. Poor grammar and weak word choice make the county’s commitment to enforcing goals and objectives seem optional. And the lack of current maps make it difficult to connect concepts to realities on the ground.

The latest draft of the Plan also fails to completely address the top four legal issues that led to this lengthy revision process in the first place. At the end of the day, provisions in the plan still do not provide adequate protection to: water quantity and quality from development, fish and wildlife habitat from development, life and property from wildfire, and agricultural lands from conversion or de-designation.

Divide and Conquer

Most concerning to us is that the timeline presented with the Plan suggests a strategy to isolate the Methow Valley from the rest of the county: it seems to propose that we should accept a sub-standard Comprehensive Plan for the whole county that fails to protect water quantity and quality, throws fish and wildlife under the bus to accommodate resource extraction, and endorses the conversion of agricultural land to other uses. The new Plan remains silent on the critical issue of affordable housing, as well as Dark Sky and Ridgetop Building overlays that could be adopted over time by communities desiring additional protection of their natural assets.

In exchange, the Methow Valley gets to start all over: the Commissioners will appoint citizen committees, composed solely of “landowners,” to write a separate plan for the Methow Valley sub area. We are not assured that this process will result in adoption of any of the provisions that community members have consistently advocated for.

Additionally, while the Methow Valley is indeed a unique place and we would embrace a sub-area plan, the changes we are proposing to the Comp Plan are changes that can benefit most of Okanogan County. What occurs across the county impacts the Methow Valley and vice versa—we are all in this together. For this reason, we encourage you to press the Commissioners to strengthen the entire Comp Plan rather than only relying on subarea planning to address concerns.

Some Suggested Talking Points

This year we are joining Futurewise to submit detailed comments with specific recommendations to make the Plan legally acceptable. It may be beneficial to point out in your comments that the county should follow the specific recommendations provided by our organizations to improve the Plan before final adoption, so we can move forward with Critical Areas and Zoning instead of going back to court. Other recommendations below are not legally mandated but support the desires consistently expressed by citizens through many rounds of public comment. 

MVCC supports changes to the Comp Plan for Okanogan County that will: 

• Concentrate most growth closer to towns. 
• Clearly identify future growth boundaries for cities and towns 
• Take a conservative approach to addressing current and future water supplies. 
• Conserve natural resources and promote land uses that support local agriculture. 
• Encourage resilience to wildfires and other impacts of climate change. 
• Identify and protect wildlife and migration corridors and consider our important mule deer population. 
• Minimize conflict between residential and other uses of Rural lands 
• Plan for a diversity of affordable housing strategies 
• Improve and enhance sustainable recreational opportunities; and  
• Allow for communities to opt into protection of night skies from excessive light pollution, and skylines from ridgetop development. 

MVCC recommends the following improvements to the Plan:

 Make Clearer Goals for Protecting Water Quantity and Quality that Anticipate Climate Impacts. 
The Plan needs to require new development to comply with the instream flow rules for individual watersheds. Most, if not all, of the water in the county is already allocated and many rivers and streams do not meet their instream flow or water quality goals. Hydrograph modeling shows declining flows in the future due to climate change. These realities need to be considered in planning for growth. The comprehensive plan needs to recognize the reality that there are not significant amounts of legally and physically available water to serve development everywhere in the county. Instead, the plan should encourage policies that support water conservation, mitigation and storage, and direct growth and development toward cities and towns.  

Improve Wildfire Safety Provisions.
The Comprehensive Plan needs stronger language committing county leaders to identify and direct growth away from areas of high wildfire danger, areas with single lane roads, and areas that do not have two ways out. The Plan should require the county to maintain safety improvements on roads for emergency equipment, rather than leaving it up to future property owners. These changes are needed to protect people and property, and to save the lives of firefighters and other first responders. 

Define and Protect Fish and Wildlife Habitat Conservation Areas. 
The current draft proposes to “balance” the regulation of these critical habitats with the needs of resource extraction:  this balancing act is not legally acceptable in critical habitats. The county must commit to language that unambiguously provides protection, especially for threatened and endangered species. Fish and wildlife habitat conservation areas must be defined to include WDFW priority habitats and species and Washington State Department of Natural Resources rare plants. Additionally, Okanogan County must comply with the Growth Management Act by including objectives that designate and protect fish and wildlife habitat conservation areas.  

 Support Local Agriculture: 
The Comp Plan recognizes the importance of agriculture to the economy but does not provide adequate provisions to identify and conserve its agricultural assets. The Plan needs to do more to strengthen measures that protect and conserve farms and ranches – start by deleting the objective that sells out our farms by presuming they will be lost to other uses (p.16) and replace it with an objective that supports protecting and encouraging agriculture for future generations.  Better maps should be made to show how criteria for designating and de-designating agricultural lands of long-term commercial significance will be applied.  

Provide Accurate Maps of City Expansion Areas to Guide Future Decisions.
“Established City Expansion Areas” (CEAs) are defined as lands into which a city or town intends to grow through a twenty-year planning window. The Comprehensive Plan explains that established CEAs are necessary for the County to make designation and de-designation decisions about agricultural resource lands. But the Plan doesn’t include any baseline maps for established city expansion areas or even name Cities or Towns that are eligible or have submitted requests for specific City Expansion Areas. Without a baseline, it seems like the County plans to evaluate resource land designation and de-designation on an individual parcel basis, which is not allowed (See p. 22). The lack of any maps or reference materials implies that no CEAs currently exist. If they do exist, they need to be included in land use maps. Decisions about land use designations that relate to CEAs need to be explicit. 

Allow Communities to Opt into Viewshed Protection 
There are no goals or objectives in the current Plan that facilitate the development of regulations to prevent ridgetop development or protect night skies from light pollution. Protecting viewsheds, especially in areas dependent on these qualities for economic benefit (i.e. tourism, recreation) is important and needs to be included in the Plan as an option that communities throughout Okanogan County can choose. 

Provide for an Affordable Housing Strategy
During the course of this Plan revision, affordable housing has become a crisis across all of Okanogan County, including but not limited to the Methow Valley. The Plan should add goals and objectives to ensure that an inclusive strategy to address the affordable housing crisis is created and implemented countywide.  

We recommend that the comprehensive plan include an objective directing the designation of land with densities and housing types sufficient to allow affordable housing in cities, towns, and City Expansion Areas (C.E.A.). The objective could also call for incentives to encourage affordable housing in these areas, such as density bonuses.

We would also like to see an objective encouraging internal and attached accessory dwelling units (ADUs) for use as long-term rentals in locations that are relatively safe from wildfires, have adequate water supplies, and have lots and soils sufficient to manage wastewater. Internal and attached ADUs are located inside or attached to a single-family home or in an accessory building, such as a garage or even a barn, located close to the house. ADUs can allow the use of underused space, provide the opportunity for a person or family that can watch and care for a house that is used only part of the year, and provide a more affordable long-term rental option.

Other upcoming Comp Plan dates:

This is the timeline the Planning Commission has laid out:
November 29, 2021 Planning commission to take verbal comment at public hearing on Comp Plan. Written comments on Comp Plan due by this date.  This is the only public hearing scheduled
December 10, 2021 Written comment deadline for DEIS.
December 27, 2021 Special meeting of Planning Com­mission to consider public comments on DEIS and vote on a recommendation to the county commissioners.
December 29, 2021 County Commissioners Meeting on final Comp Plan & DEIS. Open public meeting, but not a public hearing. Commissioners will deliberate upon the recommendations passed on to them from the Planning Commission. It is anticipated they will vote upon a Final Comp Plan and Final EIS in order to meet a legal deadline.