On March 18, I attended a public hearing for the EIS scoping process on the county comprehensive plan update and was disappointed to see only a handful of people in attendance. The information analyzed in the EIS will guide policy development and UGA (urban growth area) boundaries, and previous hearings drew a large crowd. Perhaps attendance was low because a “non-binding resolution” between the county and cities had “fixed” the population projections and ensured they would remain in the higher range of what was authorized. Perhaps attendance was low because everyone vested their rights and obtained what they wanted during the last round of updates.
However, there are many issues that remain of concern, not the least of which involves our water resources and our wildlife. Public comment, in the week that remains, can help ensure that these issues are analyzed sufficiently to allow adequate protection in the future. I know this is a technical and confusing issue, so I have attempted below to explain the basics to encourage more folks to weigh in.
The Scoping Process
Whatcom County is reviewing its Comprehensive Plan and development regulations for a 2016-update process required under the Growth Management Act. The county and the cities will be determining how much new growth to plan for, and it is required they analyze the impacts this will have on the environment through an Environmental Impact Statement (EIS).
Because an EIS reviews significant environmental impacts, “scoping” is intended to identify and focus the EIS on these significant issues. The public “scoping period” for the EIS is an opportunity to comment on the range of proposed actions, alternatives and the impacts that will be addressed. The scoping process is open for public comment until April 7th , and can be sent to email@example.com. More information is available on the county website under the link for the EIS Scoping Document. http://www.co.whatcom.wa.us/pds/plan/lr/compplan/updates.jsp.
The EIS describes proposed actions under four alternatives, including a “no action” alternative, which in this case is the current Comprehensive Plan without revision. A second alternative will be adoption of growth figures based on the higher range of projected growth that is permissible. There will be two other alternatives for growth figures and patterns that have not yet been identified, and presumably, will be determined through the public scoping process. I would encourage the public to include in their comments the request that at least one of these alternatives review impacts under the lowest population projections authorized.
The EIS determines if there will be “significant, unavoidable and adverse” impacts under each alternative. Mitigation measures to reduce or eliminate the harmful impacts are analyzed and discussed. Because this is a “non-project” or programmatic EIS, the county emphasizes that this will not address specific development impacts, and will focus only on an “order of magnitude” analysis. In short, they will not be providing site specific and detailed analysis of impacts. However, the degree to which they should provide qualitative and quantitative data is an appropriate subject of public comment.
Elements of the Environment Proposed For Review
Impacts and mitigation focus on specific topics and concerns. The range of issues currently proposed include: earth; air quality; water resources; plants and animals; land and shoreline use; plans and policies; population, housing and employment; cultural resources; transportation; and public services and utilities. However, the public can suggest additional issues, or request the scope of the issues be extended. (The proposed scope of each issue is explained in the website link above.)
For example, under the issue of air quality, the county is trying to address some of the problems attributable to climate change. It proposes review of greenhouse gas emissions under each alternative based on an order of magnitude comparison of vehicle miles traveled. Additionally, “a summary of climate change programs available to the county or the region would be summarized.”
Perhaps climate change is an impact worthy of its own issue for EIS review. The scope of climate change extends far beyond air quality impacts. It involves shoreline use, water supply, food supply, public utilities (stormwater management, energy use, etc.) and wildlife and habitat impacts. Some argue it impacts future population growth. If the county does not create a new EIS issue specific for climate change, it should ensure that the full range of impacts is being addressed in analysis of the other applicable issues.
Another issue that would be appropriate for public comment involves water resources. The proposed scope of the county’s review involves only drainage, flooding and storm water run-off. I believe the scope of this review is too limited and should be expanded to include: water supply; water treatment; groundwater movement, quality and quantity, and impacts upon surface water levels; surface water movement, quality and quantity; aquatic invasive species; wetlands and floodplains. I would like the EIS to address water resources under a watershed analysis approach, and list the status of water quantity and quality for each water body. It would be helpful to have an EIS analysis of the effectiveness and needed improvements for the overlay zones for impaired water bodies.
But most importantly, I would like to see a map reflecting the growth patterns under each alternative superimposed over a map of critical areas, shellfish protection districts, and areas with known surface or ground water supply or water quality problems. Because the EIS is being created as a tool to guide future planning, the best way to do that is to show us, in simple and visual terms, how much impact each alternative is expected to have the county’s water resources. This is a very simple and inexpensive thing to do, and it is an analysis method that conforms to the review standards appropriate for a non-project review.
The plants and animals issue calls out for expanded scoping and I will be submitting my own comments for this issue, focused on the need for an on-site review and quantification of local species, habitats and connectivity corridors in order to establish a baseline standard to measure any loss in ecological function. But the point here is that you must review the EIS Scoping Document yourself and find the particular issues that speak to you. You have one week to review this short document and comment on the scope of the proposed review.