Sunday, November 2, 2008

A Local Citizen says Whatcom County GMA Update is ill advised

The enclosed correspondence was sent to the County Council on 11/3/2008.
This submittal is in response to the 2031 Comp Plan Update Questionnaire that was sent to some county residents, which is due on Friday.


The decision to launch a major revamp of the Comp Plan at this time is unjustified and ill advised. I urge that the effort be scaled back to the minimum required to comply with state law.

I base this recommendation upon the following incontrovertible facts and inescapable conclusions:


Approximately half of the water users in Whatcom County, including farmers, residents, and businesses, do not have legal access to the water they are currently using.

Instream flow and tribal treaty rights to water remain totally unresolved as of this date.

The Department of Ecology has announced that they intend to begin enforcing water rights at the beginning of 2009, absent some agreement in principle regarding instream flow.

Whatcom County, as a legal entity, has no water rights and it does not control any source of water supply.

No plan exists for Whatcom County to provide water to those who are currently using it, let alone additional water for growth, to the current 2022 projection, or anything over that.

So-called "exempt wells" can provide service only to new residential construction, and only under limited circumstances and at great per capita cost to each homeowner. Exempt wells can have water quality impacts and directly impact the water supplies of existing water users within the same aquifer.

WRIA 1 Management Plan

The WRIA 1 Watershed Management Plan passed in 2005 was designed to address these issues, among others; Whatcom County has chosen to suspend many of its obligations under said Plan due, it claims, to budgetary constraints. As a result, crucial Plan elements remain undone, including assessment of water supply availability, water supply planning, and provision of funding for major Plan elements.

RCW 36.70A, the GMA, requires adoption of a population projection within the range provided by OFM, unless a jurisdiction can show good reason to the contrary. Lack of resources and infrastructure are valid bases for limiting growth.

The current Comp Plan places a high priority on the preservation of farmland.
There is a trend toward local economic prosperity becoming highly dependent upon population growth.


Whatcom County cannot reasonably and realistically plan for ANY growth, let alone update its current target to a 2031 time frame, while the water supply of many existing residents and farms remains in doubt.

Depending upon the amount of water allocated to instream flow, either by agreement or by Ecology fiat, there could well be insufficient local water supply available for all existing residents and farms, let alone any population growth.

If half the farmers are put out of business due to enforcement of water rights, the goal of preserving farmland will be placed in far greater jeopardy than it already is.

Resolution of the water supply crisis must take precedence over any future population growth planning. Nothing in the GMA can or should be used to justify continuing to plan for growth that cannot be served with adequate water.

If Whatcom County should come under fire from CTED for failing some GMA requirement in that regard, it need only refer them to Ecology for its justification.
If lack of resources and infrastructure are valid bases for limiting growth, shouldn’t lack of resolution of critical water supply issues be a valid basis for postponing critical growth planning decisions?

For the County to spend money on a Comp Plan update when it claims it has no money to complete its vital obligations under the Watershed Management Plan is bad judgment. If water resource planning were not related to land use planning, it would be one thing, but given the close linkage between the two, and the crisis pending in the former, it is unconscionable for the County to forge ahead with a land use plan update while giving short shrift to water supply planning.

All those who wish to see a supportable growth projection to the year 2031 should join me in urging the County to put first things first, and the first thing is water, water, water.


I look forward to receiving your thoughts and comments regarding the proposed GMA update.

Just for the fun of it - consider the rising cost of logistics - (the cost of shipping goods in and out of Whatcom County) and the impact Ecology's decision will have on our ability to purchase affordable, locally grown produce should Ecology decide that un-permited farms can no longer draw water to grow crops in Whatcom County.

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