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HomeMy WebLinkAboutAssessment Memo CASCADIA Community Planning Services 1233 Blaine Street Port Townsend, WA 98368 Phone: (360) 421-4972 Email: eric@cascadiaplanningservices.com MEMORANDUM To: Richard Sepler, AICP, Community Services Director; Judy Surber, Senior Planner/Planning Manager From: Eric Toews, Principal Date: September 29, 2014 Re: 2016 Comprehensive Plan Update –Preliminary Assessment & Work Plan Recommendations INTRODUCTION The Port Townsend Comprehensive Plan is the community’s official statement concerning its vision for the future. Statutorily mandated under the Washington State Growth Management Act (GMA), Chapter 36.70A RCW, the City’s Plan was adopted during a time of rapid growth, development and economic expansion in Washington State. More recent data show that Washington’s rate of population growth is slowing somewhat, although it remains one of thefastest growing states in the nation at 1.27% annually. While the growth trends that necessitated the GMA may be changing, the City is nevertheless statutorily required to review, and (if needed) amend its Plan and implementing regulations by June 30, 2016 (RCW 36.70A.130). This mandatory review and revision process is needed to: a.Ensure that both the Plan and implementing regulations (codified principally in Title 17 PTMC) are consistent with the requirements of the GMA, as amended; and to b.Examine,in light of current information, whether the assumptions underpinning the Plan remain valid. The process also presents an opportunity for the City to assess whether changes in community attitudes and values necessitate revisions to the adopted vision, goals and policies. KEY PLANNING ASSUMPTIONS It is suggested that the assumptions guiding the scope and character of the Plan update process be explicitly documented for both the public, elected and appointed officials, and staff. The following assumptions underpin the recommendations outlined in this memorandum: PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE1SEPTEMBER 2014 1.There is an acute need at the outset of the process to avoid over-committing limited staff and financial resources in the effort. Specifically, resources must be carefully deployed to undertake only those amendments that: a) ensure the legal defensibility of the Plan and continued eligibility for grant funding; and b) only those optional amendments whichare deemed essential. 2.The City’s Plan has been recurrently amended over the past 18 years. In addition to regular discretionary amendments, the City has also conducted a statutorily mandated review and update to its Plan and implementing regulations (2004/2005) to ensure ongoing compliance with the GMA. Accordingly, much of the foundation of the existing Plan remains generally relevant and appropriate. 3.The original Plan contained very explicit direction regarding its implementation through development regulations. Although most of the goal and policy direction remains relevant, the document could be streamlined and simplified by removing redundant and now obsolete policies (e.g., those that have been accomplished). 4.No additional staff or other resources will likely be available for the project. In consequence, the substantive work effort will largely be undertaken and completed by Development Services Department and Public Works Department staffs and a project team including representatives from other City departments, the Planning Commission, and key committees (e.g., Climate Action Committee). It is anticipated that Public Works Department staff will complete required updates to the Transportation and Capital Facilities & Utilities Elementsof the Plan. However, peer review and (if necessary) amendment to the Critical Areas Ordinance (Chapter 19.05 PTMC) may require consultant support and additional funding. 5.Though the Comprehensive Plan has been in effect since 1996, it is likely that some participants in the process will be unfamiliar with the key concepts of the existing Plan. Accordingly, it may be necessary to prepare and provide informational and background materials to ensure a common understanding of the core requirements of theGMA, the existing Community Direction Statement, and key goal and policy guidance provided by the Plan. 6.The Environmental Impact Statement (EIS) for the current Plan was prepared in 1996. Both the Draft and Final EIS provided extensive analysis of the environmental impacts anticipated as a result of Plan adoption and implementation. Given that the projected population is substantially less than was previously expected, substantial changes to the land use plan that would require preparation of an entirely new EIS are not anticipated. Hence, SEPA compliance will likely be achieved either through an Addendum, or a narrowly scoped Supplemental EIS. 7.While the principal priority of the project is to ensure continued statutory compliance, the update process affords the City with a unique opportunity to initiate a vitally necessary conversation about the coming “downshift.” Unsustainable global trends in the economy, energy and the environment have caught up with us, and are likely to converge within theplanning period. The Plan update provides a platform to begin a community conversation about the challenging and uncertain times that lie ahead, and an opening for the City to PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE2SEPTEMBER 2014 map a future process that will seek to: a) identify core systems and servicesthat are critical to the protection of public health and safety; b) determine critical vulnerabilities; and c) outline mitigating actions to reduce risks to the City’s basic infrastructure and services. COMPREHENSIVE PLAN ASSESSMENT Introduction Section 20.04.050(A)(1) of the Port Townsend Municipal Code (PTMC) sets forth the process for the Planning Commission’s assessment of the Comprehensive Plan, including the seven review criteria to guide the inquiry. The criteria address the following subjects: Population growth and development trends; City’s ability to provide necessary infrastructure; Sufficiency of land use designations and zones; Validity of assumptions underpinning the Plan; Changes in community values and attitudes; Changes in circumstances that may suggest the need for amendments; and Consistency with the GMA, the Countywide Planning Policies, and Jefferson County’s Comprehensive Plan. Application of this review framework to the Comprehensive Plan helps the City to identify policy and regulatory changes that may be necessary to better align the Plan with changing circumstances, emerging issues, and changes in community attitudes. The following section restates the evaluation criteria of §20.04.050(A)(1) PTMC as questions, and provides brief responses to each. Evaluation Criteria 1. Is the growth and development envisioned in the City’s Plan occurring faster or slower than anticipated? Or, is it failing to materialize? (§20.04.050(A)(1)(a) PTMC) Brief Discussion:The growth rates of both Jefferson County and the City of Port Townsend have slowed markedly over the last decade. In fact, the City's population is actually expected to be less in 2036 under the County’s population projection and allocation than was anticipated for the year 2024 under the previous forecast (see Table 1, below). Thus, the demands placed upon the City’s infrastructure, natural resources and land supply are likely to be somewhat less, or occur somewhat later, than predicted at the time of the last periodic update in 2005. Port Townsend is obligated to plan to accommodate slightly less than one-third (31.76%) of countywide growth over the coming years (2,692). This population target assumes a growth rate of approximately 1.00% annually from a 2010 “base year” population of 9,113 residents to 11,805 by the end of the planning period. Table 1 compares the population planning forecasts that have shaped City and County Comprehensive Plans over the past decades. Each of the two prior forecasts, 1996 and 2004 respectively, anticipated faster population growth than has actually been observed. PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE3SEPTEMBER 2014 Of potential concern is the decline in Port Townsend’s population as a percentage of Jefferson County’stotal population. The City’s 1996 Comprehensive Plan anticipated that Port Townsend would capture a higher percentage of the County’s total population, as more people would choose to live in UGAs rather than in rural areas. Observed population trends have not supported this expectation. Preliminary Conclusion: Population growth within both the City and County has been slower than anticipated under the population forecasts and allocations. Consistent with this trend, Port Townsend’s allocated share of countywide population growth has also decreased, from 36% in the 1996 forecast, to slightly less than 32% in the allocation for 2036. However, as noted in Table 3, below, the County continues to maintain a 70% urban, 30% rural population distribution, withTri-Area UGA and Port Ludlow and Brinnon Master Planned Resorts (MPRs) receiving the balance of projected urban growth (see Table 3, below). Table 1: Comparison of Population Planning Forecasts –1996 to Present Geographic Area1996 Projection for2004 Projection forAnticipated 2014 20162024Projection for 2036 City of Port Townsend 8,366 (1996) + 5,510 = 8,334 (2000) + 4,985) = 9,113 (2010) + 2,692) = 13,876 (2016)13,329 (2024)11,805 (2036) Jefferson County 25,756 (1996) + 13,640 26,299 (2000) + 13,840 29,872 (2010) + 8,477 = = 39,396 (2016)= 40,139 (2024)38,349 (2036) Table 2, below, shows the anticipated population growth for both the City and County for the planning period ending in 2036. Table 2: Anticipated2036 Population Projection & Allocation* Anticipated Projected 2036 Percentage of Compound Geographic Area2010 PopulationGrowthPopulationCountywide Annual Growth (2010-2036)GrowthRate (2010-2036) Port Townsend UGA 9,1132,69211,80531.76%1.00% (Incorporated) Unincorporated Areas (UGAs, 20,7595,78526,54468.24%0.95% Rural & Resource) Countywide Total 29,8728,47738,349100%0.97% * These preliminary projections are based upon the OFM Intermediate or “Midrange”Series. Although no projection and allocation has yet been formalized by Jefferson County, it is expected that the updated GMA planning population projection and allocation will employ a methodology similar to that used for the last periodic plan updates. See Jefferson County Resolution No. 55-03, September 22, 2003 for further information. PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE4SEPTEMBER 2014 Table 3: Urban/Rural Population Allocation Summary Geographic AreaAnticipated Population AllocationPercentage of Projected Countywide Growth (2010-2036) Port Townsend UGA2,69231.76% (Incorporated) Unincorporated UGAs/MPRs3,24238.24% (i.e., Tri-Area; Port Ludlow; Brinnon) Unincorporated Rural & 2,54330% Resource Areas 2. Has the City’s capacity to provide adequate services diminished, or (§20.04.050(A)(1)(b) PTMC) increased? Brief Discussion: Because the City’s growth is occurring more slowly than was expected in prior iterations of the Comprehensive Plan, the anticipated demands on public services and infrastructure have eased somewhat, or are occurring later in time. Although growth pressures have diminished, the City’s financial capacity to provide expanded services and infrastructure has –like most jurisdictions –been negatively impacted by the 2008 “Great Recession” and its lingering effects. Nevertheless, the City has successfully undertaken many capital projects since 1996 both to maintain existing infrastructure as well as expand capacity to meet future demand: Wastewater Collection and Treatment: Several projects (e.g., Gaines Street Pump Station, Island Vista Pump Station, Tremont Street Sewer Trunk Line Rebuild, and Treatment Plant Outfall Line Replacement) have increased the capacity and the reliability of the central conveyance system. The collection system has generally grown concurrent with development, although certain areas of town remain un-served (e.g., commercial and industrial zoned land located near the entrance to the City). Although sized to excess capacity, incremental population growth and development continues to slowly reduce available plant capacity. It should be noted that slower growth has thus far allowed the City to defer the initiation of planning studies to expand treatment plant capacity. Water Treatment and Distribution: Water system improvements since initial Plan adoption have increased the service pressures to specific areas of town that previously failed to meet State standards. Generally, the system has grown concurrent with development. However, as federal and state drinking water standards continue to evolve, improvements may be necessary to maintain statutory compliance. Streets: Bicycle and pedestrian access has been expanded with the completion of work along Upper Sims Way/Highway 20, which also helped to calm traffic flows and aesthetically improve the entrance to the City. Additionally, some gravel streets have been surfaced in recent years. However, street maintenance funding has not kept pace with roadway deterioration throughout significant PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE5SEPTEMBER 2014 portions of the City. This shortfall continues to increase the City’s financial liability to bring the streets to adopted standards. In general, new development has resulted in improvements to the street network commensurate with its impacts. The City continues to plan for substantial improvements to the Howard Street Corridor to address current and projected traffic levels. Stormwater: The City’s adoption of the 2005 DOE Stormwater Management Manual for Western Washington has increased the level of stormwater improvements required for new development. Over time, application of these standards should increase the City’s ability manage runoff from additional development. City Buildings: Significant improvements to certain City buildings (e.g., seismic retrofit and expansion of City Hall; new Fire Station) have enhanced the City’s ability to serve the existing and future population. Additionally the Police Station has been relocated from the historic downtown area to the former Mountain View School on Walker Street, where it is more centrally located to enhance response times and to situate this essential emergency service outside a tsunami and seismically-vulnerable zone. Parks: The City has acquired a number of properties in recent years for park nd purposes. Some of these properties (e.g. 22Street Park) have been opened to th the public, while others remain as yet undeveloped (e.g., 35Street Park). Park development has not always kept up with new development, inparticular in the western and northwestern parts of the City. The City acquired title to the Kah Tai Nature Park from the Port of Port Townsend in 2013, while at the same time deeding both its City Dock and Union Wharf facilities to the Port. While this reciprocal transaction did not expand park and recreational offerings to City residents, transfer of the docks did marginally reduce the City’s long-term capital maintenance obligations. Preliminary Conclusion: Since initial Plan adoption, the services and facilities provided to City residents have generally expanded and improved. However, looking to the years ahead, continued economic volatility, the lingering effects of the 2008 recession, and peak net energy and its negative implications for economic and tax revenue growth, all raise serious concerns as to how the City will continue to fund basic infrastructure and services. 3. Has the City designated and zoned sufficient land to meet projected (§20.04.050(A)(1)(c) PTMC) demand and needs? Brief Discussion: During the last “Mid-Cycle Assessment” in 2008, City staff conducted an analysis to determine vacant lands within the City. It found that no category of land use designation had seen more than 15% of its area developed since 1996. Further, it concluded that sufficient land was designated in appropriate use categories to meet projected demand and needs. Since 2008, growth and development have slowed notably as a result of the economic downturn. Thus, it would be expected that an updated vacant lands analysis would reach the same conclusion. Moreover, the 1996 Plan designated sufficient vacant PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE6SEPTEMBER 2014 residential lands to accommodate a theoretical population in excess of 30,000. Because the anticipated population at the end of the planning period in 2036 (11,805) is less than that expected under the prior forecast and allocation for 2024 (13,329), it can be safely concluded that the City’s UGA remains adequately sized to accommodate anticipated urban population growth. In fact, the City continues to maintain a population carrying capacity theoretically capable of accommodating allprojected population growth in Jefferson County through 2036. Preliminary Conclusion: Since initial Plan adoption, the amount of vacant land available in the City’s land use designations has not substantially declined. Because the City’s anticipated population at the end of the 20-year planning period (11,805) is now significantly less than was previously forecast under either the 1996 Plan (13,876 for 2016) or thelast major Plan Update in 2004 (13,329 for 2024), it can reasonably be concluded that more than sufficient land –in all land use categories –has been designated to meet projected demand and needs. 4. Do the assumptions upon which the Plan is based remain valid? (§20.04.050(A)(1)(d) PTMC) Brief Discussion: The assumptions upon which the Plan is based are set forth on pages II-9 and II-10. These hypotheses, all of which date to the original 1996 Plan, were remarkably prescient in describing the ensuing18 years of Port Townsend’s history. Will these assumptions remain relevant in the years ahead? Multiple lines of evidence strongly hint that the answer may be “no”. Most notably, the economic crisis that began in 2008 with the bursting of the sub-prime mortgage bubble was (is) no ordinary downturn. This event, which is likely to be seen in hindsight as a turning point in human history, suggests that something fundamental has changed with our world, something that lies at the very foundation of our way of living, producing, and consuming. The 1996 Plan was predicated on the unstated assumption of the continuation of the millenarian arc of growth and progress that has characterized western civilization since the Industrial Revolution and Enlightenment. However, global economic trends (unsustainable levels of public and private debt), the approaching peak of net energy necessary to fuel continued economic growth, and global scale environmental degradation (largely a byproduct of fossil fueled growth)all point to a societal “reset” in the coming decades. It would appear that the current Plan does not in any meaningful way address these convergent crises of economy, energy and environment. Preliminary Conclusion: From a conventional perspective that does not account for national and global trends, the basic assumptions documented in the Comprehensive Plan would appear to remain largely valid. However, a review of broader data trends suggests a need to revisit and update the Plan’s assumptions to factor energy-descent, economic contraction, and mounting infrastructure and environmental costs in an era of shrinking public budgets. 5. Have changes occurred in the community’s attitudes and basic values that (§20.04.050(A)(1)(e) PTMC) would necessitate amendments to the Plan? Brief Discussion: The Comprehensive Plan is intended to reflect, to the greatest extent possible, community-wide attitudes about the future growth and management of the City. PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE7SEPTEMBER 2014 The public outreach and involvement process that leadup to adoption of the 1996 Plan was exhaustive and unprecedented in the City’s history (more than 1,400 hours of informal citizen “Coffee Hour” meetings, six Comprehensive Plan working committees, more than 50 public meetings, and a series of public hearings and deliberations workshops before the Planning Commission and City Council). During the last “Mid-Cycle” update to the Plan, the City held a series of three Town Meetings that was broadly consistent with the key themes of community attitudes identified in 1996. Nevertheless, it may be advisable to clarify and confirm community- wide attitudes through additional community meetings and informal surveys conducted during the Plan Update process. Preliminary Conclusion: No obvious changes in community attitudes or values have been identified that would suggest a need for Plan amendments. However, additional public process is needed to confirm this finding. 6. Does a change (or lack of change) in circumstances reveal that Plan (§20.04.050(A)(1)(f) PTMC) amendments are necessary? Brief Discussion: As outlined under assessment criterion 4, above, circumstances have changed materially since the Plan was adopted in 1996 and updated in 2008. Peak net energy available to society (“peak oil”), coupled with the impairments of capital formation due to unsustainable levels of public and private debt, and the tangible effects of climate disruption and widespread environmental degradation, have all emerged as the preeminent trends likely to shape the coming decades –an era of “limits to growth”. These changed circumstances demand that Port Townsend residents and decision- makers begin to craft a coherent narrative about what is happening to our community and world, and to forge an intelligent consensus concerningwhat to do about it. The work plan set forth in this memorandum suggests establishing a procedural framework to begin preparing Port Townsend for Transition and Resilience. Preliminary Conclusion: Yes –circumstances have changed since the Plan was last updated. The converging crises of economy, energy and environment require the City to begin planning for an economically and energy constrained future in a time of rising infrastructure and environmentalcosts. 7. Do inconsistencies exist between the Plan and the GMA or Countywide Planning Policy for Jefferson County that must be remedied? (§20.04.050(A)(1)(f) PTMC) Brief Discussion:A preliminary evaluation of the City’s Comprehensive Plan and Development Regulations has been completed. A number of inconsistencies with the GMA have been identified through use of the “Periodic Update Checklist for Cities” prepared by the Department of Commerce (June 2013). Specific amendments have been outlined in the recommended work plan to address and eliminate these inconsistencies. No inconsistencies with the Countywide Planning Policy for Jefferson County have been identified at the time of this writing. Preliminary Conclusion: Yes –inconsistencies have beenidentified between the Plan and Development Regulations and the GMA that require resolution through amendment during the 2016 update process. PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE8SEPTEMBER 2014 SPECIFIC WORK PLAN RECOMMENDATIONS Background The GMA does not exempt any portion of a comprehensive plan or development regulation from being subject to review and evaluation as part of the required periodic update. Annual amendments made to a Comprehensive Plan typically focus on specific sections or changes, but the periodic update is required to assess the Plan as a whole. The plan assessment criteria (§20.04.050(A) PTMC) discussed above should be the framework for evaluating the continuing efficacy of the Comprehensive Plan overall, and the appropriateness of potential “optional” amendments in particular. Asoutlined below, the scope of recommended amendments falls into two broad categories: Those required to maintain consistency with the GMA; and Potential optional or discretionary amendments. GMA Required Amendments Chapter V –The Land Use Element 1.A consistent population projection must be used throughout the Plan, which should be consistent with the Office of Financial Management (OFM) forecast for the Jefferson County, and County’s sub-county allocation of that forecast. The City has proposed use of the OFM mid-range projection, and use of a sub-county allocation methodology similar to that used under the prior forecast. (For background, please refer to County Resolution No. 55-03, September 22, 2003). If agreed to by the County, this would necessitate use of a revised population target of 11,805 for Port Townsend throughout the Plan. This represents anticipated population growth of 2,692 persons from a 2010 “base year” population of 9,113. Although this directs 31.76% of projected countywide growth for the period to Port Townsend, overall, Jefferson County would continue to maintain a 70% urban, 30% rural allocation by planning to accommodate 3,242 persons within the unincorporated Tri-Area UGA and the Port Ludlow and Brinnon MPRs. See RCW 43.62.035 and WAC 365-196-405(f). 2.The comprehensive plan public participation process, detailed in Land Use Element Goal 15 and Policies 15.1-15.5 requires critical review and revision to ensure its conformance with RCW 36.70A.130(2), as amended, as well §§20.04.020 and 20.04.035 PTMC. Presently, the municipal code appears to more faithfully reflect the statutory requirements than the Plan. Consideration should be given to modifying the Plan policies to better align with the statutory requirements, differentiating between annual amendments, periodic updates, and emergency amendments. See also, RCW 36.70A.020(11) and WAC 365-196- 600(3). 3.Land Use Element Policies 2.8 and 16.7 require critical review and assessment to ensure that they provide sufficient guidance to ensure that both regulatory and administrative actions taken by the City do not result in unconstitutional takings of private property. It is recommended that specific policy guidance be included that outlines the analysis the City will conduct to avoid both “facial” (prospective) PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE9SEPTEMBER 2014 and “as applied” (retrospective) takings. See RCWs 36.70A.020(6) and 36.70A.370, as well as Attorney General’s Advisory Memorandum: Avoiding Unconstitutional Takings of Private Property(2006). Chapter VI –The Housing Element 4.An updated inventory and analysis of existing and projected housing needs over the planning period. The anticipated population for the year 2036 (11,805) is lower than was forecast in the current Plan for 2024 (13,329). Accordingly, an updated inventory and analysis would be expected to reflect lower aggregate housing demand than the current Plan. Because of this lower overall housing demand, a simplified inventory format would appear justified. See RCW 36.70A.070(2)(a) and WAC 365-196-410(2)(b) and (c). Chapter VII –The Transportation Element 5.An updated inventory of air, water, and ground transportation facilities and services, including transit routes, state-owned transportation facilities, and general aviation airports is required. See RCW 36.70A.070(6)(a)(iii)(B) and WAC 365-196-430. 6.New or revised policy language should be contemplated that specifies actions that will be employed by the City to bring locally owned transportation facilities and services to establishedlevels of service (LOS). This requirement is a consequence of amendments to RCW 36.70A.070(6)(a)(iii)(D) in 2005. The guidance provided in Transportation Element policies 8.1 through 8.8 arguably may suffice; however, critical review and evaluation against the revised statutory language is necessary. See RCW 36.70A.070(6)(a)(iii)(D) and WAC 365-196- 430. 7.An updated forecast of traffic (through at least 2026) must be prepared, including the land use assumptions used in estimating travel. See RCWs 36.70A.070(6)(a)(i) and 36.70A.070(6)(a)(iii)(E), and WAC 365-196-430(2)(f). 8.An updated projection of state and local system needs to meet current and future demand is required. See RCW 36.70A.070(6)(a)(iii)(F), and WAC 365-196- 430(2)(f). 9.An updated analysis of future funding capabilities, to judge needs against probable funding resources is necessary. See RCW 36.70A.070(6)(a)(iv)(A), and WAC 365-196-430(2)(k)(iv). 10.An updated multi-year financing plan must be prepared, based on the needs identified in the Plan, the relevant parts of which serve as the basis for the 6-year street, road or transit program. See RCWs 36.70A.070(6)(a)(iv)(B) and 35.77.010, and WAC 365-196-430(2)(k)(ii). 11.An updated description of intergovernmental coordination efforts should be incorporated, including an assessment of the impacts of the transportation and land use assumptions on the transportation systems of adjacent jurisdictions and how they are consistent with the regional transportation plan. See RCW PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE10SEPTEMBER 2014 36.70A.070(6)(a)(v), RCW 35.77.010, and WAC 365-196-430(2)(a)(iv). Capital Facilities & Utilities Element 12.An updated inventory of existing capital facilities owned by public must be completed. For example, the inventory should be updated to reflect changes in the ownership of facilities since 2005 (Kah Tai Lagoon Nature Park, City Dock, Union Wharf, etc.). See RCW 36.70A.070(3)(a) and WAC 365-196-415(b). 13.A forecast of needed capital facilities is required, based upon the projected population at the end of the planning period and adopted levels of service (LOS). As was the case with the housing inventory, the anticipated population projection would be expected to decrease the demand and need for expanded capital facilities. See RCW 36.70A.070(3)(b) and WAC 365-196-415(b). 14.A six-year funding plan identifying sources of public money to finance planned capital facilities is necessary. Because the City does this on an annual basis as part of its budget process, this requirement should not add to staff’s baseline workload. See RCW 36.70A.070(3)(d), 36.70A.120 and WAC 365-196-415. Required Amendments to Implementing Regulations The purpose of reviewing and amending the City’s implementing regulations concurrent with plan amendments is to ensure that the code is consistent with, and successfully implements, the GMA Comprehensive Plan. Although the GMA precludes plan amendments from occurring more frequently than once annually (RCW 36.70A.130(2)(a)), there is no such restriction for regulatory amendments, provided that such amendments do not create inconsistencies with the Plan. City staff has maintained an extensive “running list” of potential amendmentsto the Port Townsend Municipal Code. Nearly all of these potential amendments deal with procedural issues, definitions, and clarifying confusing or internally inconsistent code language. None of these potential code amendments would appear to be required to maintain consistency with either the GMA, as amended, or the Comprehensive Plan. Accordingly, it is recommended that the City’s focus during the Update process be centered upon the GMA consistency issues outlined below, and that other code amendmentsbe addressed outside the 2016 Update. 15.An ongoing requirement of the GMA is for local jurisdictions to periodically review and evaluate their adopted critical areas policies and regulations. The City last completed a comprehensive update of its Critical Areas regulations (codified in Chapter 19.05 PTMC) in 2007 at the time of adoption of its new Shoreline Management Master Program. As part of the periodic update, the City is again required to review, and if necessary, update its critical areas policies and regulations. This includes the requirement to include the best available science (BAS). See RCW 36.70A.172. Any deviations from science-based recommendations should be identified, assessed and explained (Washington Administrative Code (WAC) 365-195-915). Accordingly, it is recommended that the City seek professional peer review of Chapter 19.05 PTMC to ascertain whether or not it continues to reflect the best available science for the designation and protection of critical areas. PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE11SEPTEMBER 2014 16.The definition of fish and wildlife habitat conservation areas (§ 19.05.020 PTMC) should be amended to specifically exclude artificial features and constructs (e.g., irrigation delivery systems, irrigation infrastructure, irrigation canals or drainage ditches) that lie within the boundaries of, and are maintained by, a port district or irrigation district. See RCW 36.70A.030(5). Though arguably not directly germane to the City’s circumstances, the municipal code definition should conform to recent statutory changes. 17.Except for residential zoning districts, the tables of permitted, conditional and prohibited uses set forth in Title 17 PTMC (§§ 17.18.020, 17.20.020, 17.22.020 and 17.24.020) must be amended to specifically permit electric vehicle battery charging stations in all areas outside designated critical areas. See RCW 36.70A.695. 18.The timelines for approval and disapproval of preliminary plats in RCW 36.70A.140 have been amended in the wake of the 2008 recession, providing more time to obtain final plat approvals. Sections 18.12.140 and 18.16.150 PTMC must be reviewed and amended to ensure conformance with the statute, as revised. Preliminary plat approvals are now valid for seven (7) years if the date of preliminary approval is on or before December 31, 2014, five (5) years if preliminary approval is issued on or after January 1, 2015, and nine (9) years if outside the shoreline jurisdiction and preliminary approval was obtained on or before December 31, 2007. Amendments Needed to Address Changed Circumstances Planning for Transition and Community Resilience The City should seize the Plan update process to begin preparing a policy framework to deal with energy descent, economic contraction, and mounting environmental consequences and costs. The next twenty years are very unlikely to resemble the last twenty years. The world is at a critical economic and environmental turning point, and there are no longer any easy fixes to the problems we face. In the past decade, the inflation adjusted price of a barrel of oil as spiked from $40 to over $100, at one point exceeding $140 beforethe onset of the 2008 recession. It is increasingly clear that the cheap energy chapter of industrial civilization’s story is behind us, and that we have entered the era of expensive and harder to get energy. Over time, this will change everything aboutthe way we live. The community would benefit greatly if we began to ask difficult questions, learn unpleasant facts, and prepare for a different version of everyday life in the future. The central challenges Port Townsend is likely to face in the decades ahead are as follows: 1) maintaining basic services and public order in a time of energy descent and economic contraction, when demand for services is rising and revenues are shrinking; and 2) determining how to use the City’s position of leadership to enable, foster, and support a transition to new living arrangements (Plan “B”). Because of the substantial level of education and outreach required, and the controversial nature of the topics, it will be impossible to complete this effort within the scopeof the Plan update. Nevertheless, the update process can serve as a launch pad PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE12SEPTEMBER 2014 for an ongoing discussion as to what steps City government can take to make the community more resilient and secure. The great challenge will be to “get real” without lapsinginto denial or despair, while at the same time providing a genuinely positive alternative vision for the future. In formulating a policy framework to address the challenges ahead, it is recommended that five (5) basic questions be confronted by policy advisors and elected officials: How will the combined effects of peak net energy and climate disruption affect the community? What can City government do to cushion the community against the long-term negative consequences of those impacts? What shouldCity government be prepared to do in case of emergencies (e.g., prolonged fuel shortages, price spikes, drought, storm damage, etc.), most of which are inevitable? What basic infrastructure and services are vitalto the protection of the public health and safety, what are their vulnerabilities, and how can the City marshal its resources to mitigate those vulnerabilities? How will the City continue to fund basic infrastructure and services as economic volatility, recession and economic decline cause taxrevenues to fall? Decision-makers must avoid simply attempting to preserve the status quo or relying upon markets and technology to solve these issues. Over the long-term, such an approach is highly unlikely to succeed. Initial review under the criteriaoutlined in §20.04.050 confirms that this policy initiative is warranted: Energy depletion, economic decline and increasing environmental costs and public demand for services are likely to directly affect the City’s financial and practical capacity to provide adequate services during the planning period. See §20.04.050(b) PTMC. The assumptions upon which the proposed initiative is founded are supported by voluminous empirical data (both from official and independent sources), which clearly portray a future with less available net energy to fuel the economy. However, the current plan is predicated to a large extent upon the notion that economic growth and concomitant population increase will consistently demand increased land use and associated infrastructure improvements (funded by an expanding tax base). Instead, energy depletion portends a shrinking economy and tax base, and over the longer-term, population decline. See §20.04.050(d). The fact that Port Townsend is already one of America’s “Transition Towns,” and is home to a vibrant “Local 2020” effort, along with other related community initiatives, suggests that the attitudes of many Port Townsend residents may be somewhat ahead of current Plan policy and City leadership on these issues. See §20.04.050(e). The convergent issues of peak net energy, economic constraints to growth, and the likelihood of mounting legacy infrastructure costs, as well as costs associated with responding to environmental damage –all strongly indicate a sufficient change in circumstances warranting a Plan amendment. See §20.04.050(f). PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE13SEPTEMBER 2014 Potential Optional Amendments Revisiting the Mixed Use Center Designations A central policy initiative of the 1996 Comprehensive Plan was the designation of five (5) mixed use centers, which were intended to serve as focal points for new and emerging neighborhoods, and to promote access to goods and services within walking distance of where people live. The original Plan established a C-I/MU or “Neighborhood Serving” center, anticipating a mix of medium density multi-family residential development with smaller-scale commercial uses, as well as a C-II/MU or “Community Serving” center accommodating a wider range, scale and intensity of commercial uses coupled with high density multi-family residential use. Subsequent Plan amendments also added a Mixed Use Planned Unit Development designation, permitting deviation from the prescriptive requirements applicable to the C-I/MU and C-II/MU designations. None of these zones has been developed as envisioned in 18 years ago: a significant policy disappointment. A number of factors would appear to pose obstacles to the development of trulyurban mixed-use projects in Port Townsend, as follows: Higher costs: Mixed-use projects often have higher costs per square foot than other projects because of costs associated with parking structures, firewalls between ground floor commercial and upper-floor residential units, elevators, and advanced fire suppression systems. Large financing gaps: Mixed-use projects, particularly those that incorporate some element of affordable housing, often face both “cost gaps”(the difference between the cost of development and what the market is willing to finance) and “affordability gaps” (the difference between market rates and what the project’s target market can afford to pay) associated with both the housing and the commercial uses. The challenge of filling these gaps is compounded by the fact that there are relatively few subsidy sources for commercial real estate development, and that many common housing subsidy tools are not well suited for projects that consist of multiple uses. A lack of market demand: Although mixed-use development is commonplace in many larger cities, it has been far less common in smaller communities. With the exception of four adaptive re-use projects within established commercial districts, nonew mixed-use projects have been developed in Port Townsend since the adoption of the Comprehensive Plan and zoning which enabled them. Slowing population growth and the “Great Recession” of 2008 and its lingering effects have also negatively influenced demand. Moreover, because there are relatively few mixed-use projects in Port Townsend, and most housing in the city is located in distinctly residential areas, lenders have not been persuaded that potential home buyers will be interested in high density housing located on busy commercial streets and transit routes. Implementation difficulties: Projects with multiple uses are inherently less efficient to design, finance and manage. Because housing and commercial uses are fundamentally different, they require different design features, different financing tools (with different underwriting standards) and different management skills. In some cases, the demands of housing and commercial uses conflict in ways that make it difficult to market the product. Bringing all of the divergent components together so that they complement each other is the key to having a successful mixed-use project. PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE14SEPTEMBER 2014 Accordingly, it is recommended that these designations be critically reevaluated to assess whether or not they should be retained in their present form, substantially modified, or eliminated. In conducting such a review, it will be important to: Assess not only the policy framework in the Plan, but also the specific (and restrictive) implementation provisions within Chapter 17.18 PTMC, which potentially have contributed to the lack of mixed use development; and Carefully consider the need and advisability of retaining some form of walk-able activity nodes throughout the City in light of the Transition and Community Resilience initiative outline above. Revolutionary changes in degree of human mobility are likely over the coming decades, and incorporating peak energy and climate change considerations into all aspects of land-use and transportation policy and capital investment decisions will be crucially important. As was the case for the Transition and Resilience initiative, potential Plan amendments regarding mixed-use centers appear justified in light of the review criteria of §20.04.050: The growth and developmentof these zones imagined in 1996 has not materialized. See §20.04.050(a) PTMC. This suggests that more mixed-use land is designated and zoned than may be necessary to meet projected demand and need. It also indicates that the assumptions regarding market conditions and demand that underpin the current mixed-use policy framework may be inaccurate. See §20.04.050(c) and (d) PTMC. Finally, the lack of mixed-use development (i.e., the lack of a “change in circumstances”) suggests a need for amendment. Policies and Capital Improvements that Support Young Families and Youth The City’s 1996 Plan sought to resist the trend towards becoming a retirement residential town, and to maintain an authentic small town atmosphere with distinctive and vibrant neighborhoods and a working waterfront. The Plan (e.g., Community Direction Statement, Economic Development Element) stressed the need to support the provision of “family-wage” jobs to allow young families to both live and work in the community. The Plan also sought to cultivate opportunities for the youth in our community to “play, socialize, find entertainment, work, and be involved in extra- curricular experiences.” Despite the Plan’s focus on maintaining small town character and achieving a better balancebetween jobs and housing, the undeniable demographic trend has been towards a retirement residential community. Moreover, while certain areas of town have experienced an influx of retirees with comparatively significant financial resources, US Census data also show that the number of citizens living below the federal poverty line has increased -particularly young families with children and certain segments of the elderly population. Without question, these trends mirror broader national currents, and have been magnified by the economic turmoil of the past six years. While the City is powerless to influence global and national economic tendencies, it can nevertheless direct policy focus upon, and commit scarce public resources towards, supporting youngfamilies and vulnerable populations. PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE15SEPTEMBER 2014 How can this be accomplished? An important first step in addressing these difficult issues lies in strengthening Plan policy language within the Land Use, Capital Facilities and Economic Development Elements, to emphasize the following: Fostering educational excellence: Good schools come from good communities. The City should consider adopting policy language that seeks to support the Port Townsend School District in providing the highest quality educational programs that foster student achievement. With community support, Port Townsend’s schools provide a gateway to vocational and life-long learning programs and choices that enrich lives and sustain our local economy. Providing a fairer distribution of recreational facilities and programs: Certain portions of the City (e.g., the Castle Hill Subarea) appear to lack adequate park and recreational facilities and programs to serve the needs of youth. Consideration should be given to including language within the Capital Facilities Element that seeks to fairly distribute City investments in park and recreational facilities to serve all population segments and geographic areas of the community. Support for daycare facilities and youth programs: The OlyCAP Community Needs Assessment Report (2013) suggests that the number of childcare centers in Jefferson County and Port Townsend has decreased over the past decade, while the number of children needing daycare has essentially remained constant. Consideration should be given to inclusion of Plan policy language that acknowledges this problem, and clearly pledges the City’s support to local not- for-profit social service agencies and organizations that fill this vital need (e.g., YMCA, Lutheran Community Services Northwest, United Good Neighbors, etc.). The review criteria of §20.04.050 PTMC would appear to be largely inapplicable to this proposal. CONCLUSION Preliminary review of the Port Townsend Comprehensive Plan reveals the need for substantial “housekeeping” amendments to ensure continued compliance with the Growth Management Act, as amended. Though largely of a technical and non-policy nature, these necessary changes will likely require a significant investment of staff time and resources. Additionally, andin some ways perhaps more relevant to the City’s likely (rather than wished for) future, a review and assessment of adopted policy indicates an urgent need to focus on developing a policy framework and corollary investments that will make core public infrastructure more resilient and secure in an age of “limits to growth.” I welcome the discussion and constructive criticism to follow, and stand prepared to assist you in any way I can. PORT TOWNSEND ASSESSMENT & WORK PLAN COMPREHENSIVE PLAN UPDATE16SEPTEMBER 2014