SGA Comments on Protecting Public Involvement in Proposed Title 19 Permit Streamlining Amendments

Smart Growth Anacortes

 

Date: July 15th, 2026

Subject: SGA AMC Title 19, Unified Development Code – Comments Corrected.

To: Planning Commission

 

Hello Again Planning Commission Members:

 

SGA has taken more input on the AMC Title 19, Unified Development Code and has done more analysis. This has led to a more defined and directed set of comments. It is SGA’s hope that these comments are not seen as divisive but rather as a start of a “positive conflicted dialogue” in which at the end of the dialogue a solution is discovered that is acceptable to all.

 

SGA asks Planning Commission members and Planning Staff to incorporate these comments into the proposed AMC Title 19 Permit Streamlining Amendments. As written, they reduce public involvement and potentially compromise the quality of project results. SGA would like a respectful forum with the Planning Commission members and Planning Staff to provide ideas to address our concerns, streamline the permitting process, and improve project results.

There is time to do this right.

 

  1. Concerns: The draft still says it is intended to “promote timely and informed public participation” but it reduces early public involvement while preserving a few participation points for certain projects through (one-way, limited) SEPA review. There is a shift towards more Type 1 and Type 2 administrative actions, where many permits are handled without Council process for small projects, shoreline exemptions, and certain permit revisions. The public input aspects of the 19.20.030 Types of Review are unimproved (see table on page 2). The Type 2 and Type 3 Pre-Application Neighborhood Meetings remain discretionary and there is no Type 2 Pre-Decision Open Record Public Hearing. The R1 Zone is not addressed.

 

SGA Position: We have experience that even Type 2 short plat projects can set precedents with unintended, negative consequences. In particular, the R1 Zone deserves early notification and discussion. We believe there are ways to make this part of the process more efficient and effective for staff but cutting out early engagement generally leads to more time/cost/burden/litigation. With this in mind we recommend the following.

  • Provide clear criteria for allowing administrative decisions for Type 1 reviews.
  • Amend Table 19.20.030 (page 2) to REQUIRE pre-application meetings with neighbors and the public for all R1 Zone reviews, and for Type 2 reviews and Type 3 reviews.
  • Amend Table 19.20.030 (page 2) to REQUIRE a pre-Decision Open Record Public Hearing for all R1 Zone and Type 2 reviews.

 

  1. Concerns: The draft proposes that Site Plan review becomes the main place where land-use, environmental, infrastructure, and design issues are evaluated before later permit stages. Once the Site Plan is approved, the draft expressly limits later Site Construction and Building permit review to consistency with already-approved Site Plans.

 

SGA Position: This is a red flag. Never revisiting the Site Plan as it moves to Construction and Building review removes the learning element to improve the project as more information becomes available. It creates a “lock-in” effect before the public has had a full opportunity to respond to the final project shape, conditions, and mitigation package. This flawed approach favors administrative closure over innovation and best practice outcomes. It will not streamline the process – it will sub-optimize outcomes and/or lead to legal battles.

 

  1. Concerns: The amendments fail to address offsite impacts for construction and build-out.

 

SGA Position: Short-term and long-term offsite impacts for construction and build-out should be assessed for stormwater, traffic, lighting, noise, etc. This should be done early in the Site Review and throughout the permitting process to ensure offsite impacts are identified and mitigated to avoid unintended consequences.

 

 

Thank you for your time, patience, and openness to new ideas. Much appreciated.

 

Respectfully,

Mark Nihart

President of Smart Growth Anacortes

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To have Anacortes as a premier example of a city in which assertive, knowledgeable and actively engaged residents – the owners and financiers of Anacortes – are working with City Staff, the Mayor, the City Council in a transparent, respectful, collaborative environment for the benefit of all who live, work and serve in Anacortes.

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