Have Your Voice Heard
Public participation is essential to responsible planning and accountable local government. This page provides a space for residents, stakeholders, and community members to submit comments related to growth, development, and planning decisions in Anacortes.
Whether you are responding to a specific agenda item, sharing concerns, or providing general feedback, your input helps inform public understanding and contributes to a more transparent process.
Please keep your submission respectful and relevant to community planning, development, or public policy topics.
Speak up for R1 Before Sept 15 hearing
On Sept. 15, the Anacortes Planning Commission will hold a public hearing on amendments to streamline development permitting.
The proposed changes will reduce public engagement, affecting every neighborhood in Anacortes and putting added pressure on the about 300-acre R1 Low Density Residential Zone between the city and forestlands.
Residents should comment now and attend the Sept. 15 hearing to speak up for transparency and neighborhood input in Anacortes’ development decisions.
Public Comment On R1 Zoning
Here’s a thought for the R1 Zone that borders the ACFL — what if those folks who used some of their space to plant berries, fruit trees, raise chickens, kitchen gardens which could supply our already existing farmer’s markets, thus securing a little more green border at city limits, got a “waiver” from the planning department protecting them from ADU or subdivision requirements?
Editor Opinion: Is Growth Really Inevitable?
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Locally owned businesses
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Strong civic collaboration
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Investments in schools, parks, housing, broadband, and “third spaces”
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Many rural communities with slow or negative growth still succeed when they plan development strategically.
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Sustainability comes from protecting local assets, walkable main streets, and community-centered planning, not from chasing growth.
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The biggest threat is limited local government capacity, not population growth rate.
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Collaboration, regional partnerships, and diversified economic strategies improve sustainability.
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Rural communities vary widely.
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Some thrive with modest or no population growth.
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Others struggle despite growth because their economic base is narrow.
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Local entrepreneurship
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Civic engagement
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Infrastructure and quality-of-life investments
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Regional collaboration
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Housing affordability crises
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Infrastructure strain
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Loss of rural character
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Traffic congestion
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Loss of farmland and open space
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Stable or slowly changing population
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Strong social capital
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High civic participation
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Locally controlled development
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Local governance weakens
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Civic ties erode
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Economic decisions are outsourced
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Land use becomes reactive instead of planned
Public Comment Submission
Subject: Internal Combustion Engine Motorcycles in the ACFL -Council 03/16/26 Public Hearing on the ACFL Forest Plan
From: Mark B. Nihart
Internal Combustion Engine Motorcycles (Motorcycles) should be banned from the ACFL.
The Forest Advisory Board (FAB) and Parks eliminated the summer Hydroplane Races on Heart Lake. Later they eliminated use of internal combustion engines on Heart Lake (and other ACFL lakes). This greatly protected the wildlife on the lake and surrounding the lake from damaging noise. Now is the time to eliminate motorcycles from the ACFL. In addition, Class 1,2 and 3 e-bikes are available to motorcycle riders who still want to “ride” trails in the ACFL. The ACFL is not a training ground for young unlicensed riders to sharpen their motorcycle motocross skills.
The powerful motorcycles are a physical threat to hikers, horses and mountain bikers.
Motorcycles emitting up to 100 decibels negatively affect both wildlife and people recreating in the ACFL. It is also difficult to enforce noise levels on exhausts and it is relatively easy to modify exhaust systems.
The Forest Plan (FP) did not cite “best available science” for allowing motorcycles in the ACFL although the FP is supposed to be using “best available science.” The Forest Advisory Board and Parks did not produce any studies saying 100 or 90 or 80 decibel motorcycles do not have a negative effect on wildlife and humans during the public comment period. During the public comment period no experts on noise and wildlife were made available to the FAB, Parks and the Public to consult with regarding the negative impact of noise to wildlife.
Motorcycles are the worst offenders of trail damage even in the “dry months” they are allowed. The Forest Plan does not cite “best available science” regarding allowing trail damage from motorcycles.
Per Parks statements, motorcycles continue to be the worst offenders of incorrect trail use and riding during restricted months. The Anacortes Police Department has yet to develop a full Comprehensive Plan on how they will enforce ordinances of the ACFL with limited resources some of which will now be patrolling Fidalgo Bay.
The public was not informed the Forest Plan would be the ACFL section of the Comprehensive Plan. Thus, the whole process used to create the current plan needs to restart to ensure all the processes and procedures required that regulate the Comprehensive Plan such as the Growth Management Act (GMA) for public comments and the declaration any Determination of Non-Significance (DNS) process and procedures are followed BEFORE the plan is made available to Council for a vote. And all the connections to other parts of the Comprehensive Plan need to be clearly identified and correct.
The Forest Plan in its current harmful recreation first versus protection of nature first with limited low-impact human recreation should have an Environmental Impact Statement (EIS) done so all parties have a full understanding of the impact of human recreation in the ACFL. The FP would need to be updated to reflect the findings of the EIS before being sent to Council.
Allowing motorcycles in the ACFL clearly does not reflect the desire of the overwhelming number of public commenters. Commenters want Nature over Recreation.
Respectfully,
Mark B. Nihart
Anacortes Resident
Public Comment Submission
Subject: 2026 FP Security Comment – Council 03/16/26 Public Hearing on the ACFL 2026 Forest Plan.
From: Mark B. Nihart
The ACFL Forest Plan (FP) presented at the Council Meeting Monday Feb 23 is a good improvement over the 2021 plan, mostly in format and edits for readability. The FP, however, should have a cost reduction strategy and an efficiency strategy to maximize expensive and limited staff resources.
The Forest Plan (FP) should have a section that identifies areas of needed, non-human, permanent security infrastructure, a priority of security projects with a Rough Order of Magnitude (ROM) budget each year for the next five years. Ideally, the permanent security systems would be enabled such that cameras can be monitored from the Park’s Office and off/on hours from the Anacortes Police Department offices. The technology is available and relatively inexpensive. (I have a cabin with 4 other cabins off grid 1 ½ miles off the County Road. We use an inexpensive system. It works great.)
Areas for permanent security system consideration –
Cranberry Lake Parking Lot
Whistle Lake Parking Lot
Whistle Lake Trail 20 end at the lake
Heart Lake Parking Lot
Sugar Loaf Parking Lot
Top of Mt Erie
Mt. Erie climbing trailhead
The FP should also identify priority areas and best practices for portable (trail camera) security systems and extend their current use as appropriate.
Rational:
A permanent 24-hour security infrastructure would likely reduce theft, vandalism and capture other misuse of the Forest Lands in those specific areas. It would reduce the need for human enforcement, expensive and limited, to be deployed. A permanent security system would also provide some usage data – hikers, bikers, watercraft, fisherpeople, banned motorcycles and horses.
This data could provide input into a database so Parks could evaluate at each site peak times of use, type of user, number of cars over days, seasons and years. Parks and Police could collaborate then tailor when human enforcement is needed with greater accuracy. The database could be the beginnings of a “data driven” approach to managing the ACFL.
Mitigation:
The FP should identify funding options outside of the normal taxpayer support of ACFL to pay for security systems projects and maintenance. Apparently, the ACFL has funds. The funding could also include an ACFL Trail Pass system like what WA Parks uses. You pay to park at trails heads and parking lots. This would help offset costs for managing the ACFL and have some of the costs picked up by nonresidents as well as us residents that use the ACFL. It would also provide a way to create donation stream like when you buy your car tabs.
The ACFL is not a Federal Park, nor a State Park both of which charge fees nor is it a County Park it is a City Park. The Anacortes residents/taxpayers/voters/ratepayers should not have to bear the whole cost of managing the Park for others to use.
It is too expensive to have the Parks Department staff, and the Anacortes Police Department to provide security and enforcement for all the ACFL problem security areas.
Public Comment Submission
Subject: 2026 ACFL Wildland Fire Management Strategy and Prevention – Council 03/16/26 Public Hearing on the ACFL 2026 Forest Plan.
Subject: ACFL Wildland Fire Management Strategy and Prevention
From: Mark B. Nihart
The Forest Plan (FP) section on Wildland Fire Management is good. However, it should just be a short paragraph then link to Anacortes Fire Department’s (AFD) Wildland Fire Management Plan for the ACFL. The AFD owns the Wildland Fire Management in the ACFL.
The Anacortes Fire Department should specifically accomplish active and passive Wildland Fire Management in the ACFL including firefighting, ACFL Wildland Fire hazard shut down and an evacuation plan.
For consideration:
AFD should develop a tighter, active partnership/relationship with Volunteer Fire Departments, WA State Parks, Swinomish Fire Department, Puget Sound Energy (PSE) and WA Department of Natural Resources (DNR) to create a Fidalgo Island Fire Fighting Consortium (FIFFC). The goal would be to have a strategy to handle multiple wildland fires/structural fires at the same time and large Fidalgo Island wide wildland fire/structural fire. And, specifically fire departments responding to a fire in or near the ACFL.
The city should take the lead in getting the DNR to install a PANO System (https://www.pano.ai/) in place on the top of Mt. Erie including sharing the cost among beneficiaries of the system – all of Fidalgo Island and part of Whidbey Island including WA Deception State Park. The AFD and the Mayor are familiar with this system.
AFD, PSE and the DNR should do a full assessment of potential wildland fire areas within the ACFL and all bordering areas. The assessment should have an action plan and budget to mitigate wildland fires in problem areas.
AFD and Anacortes Police Department should have a strategy and action plan to SHUT DOWN access to the ACFL complete with enforcement and fire watch teams patrolling the ACFL during HIGH fire days.
The city should pursue a fire detection system in collaboration with the DNR, Skagit County Fire Districts, WA State Parks, Samish Nation and Swinomish Tribe to be located on Mt. Eire. The technology is available and affordable and is already deployed in other areas in Skagit County by the DNR. Other detection systems such as drones and boots on the ground to monitor the ACFL during high fire season should also be deployed.
The AFD should have the resources and training to respond to and contain a wildland fire/structural fire before other resources are called in such as Skagit County Volunteer Fire Departments and ultimately the DNR. The AFD might have to wait 2 hours or 6 hours or 12 hours or 24 hours or days before other resources arrive, assuming they can arrive as traffic could snarl hwy 20.
Rational:
Climate Change is likely, has changed the weather on Fidalgo Island. It is supposed be drier. Skagit County is, has been in a drought for the last few years. The drier weather and likely more droughts will continue. Thus, we cannot use past data to plan for future events. The ACFL is likely to have a fire the question is where and how big AND if that fire will quickly spread into homes surrounding the ACFL.
The Anacortes Fire Department doesn’t have the staff (plus staff is in three different geographically locations and all the necessary special equipment if a major fire broke out in the rugged areas even just non roaded areas of the ACFL and spread through the treetops to houses bordering the ACFL. It is not likely the Anacortes Taxpayer will agree to higher taxes to adequately fund the AFD and APD for a “maybe” but likely fire sometime in the future.
It is not just possible a fire will break out in the ACFL a double-digit probability could be assigned. Also same goes a Fidalgo Island wide wildland fire where volunteer departments would be responsible and responding. And same goes for a Skagit County wide. The County is ripe for a large unmanageable fire. Human recreation everywhere (lots of it clueless or irresponsible), logging in the mid to upper Skagit and houses with firepits are everywhere in the forests.
The consequences of a large fire and or many small fires and everything in between is not just the destruction of forests and homes, and potential loss of life (human and wildlife) looms large. Follow-on consequences are home insurance rates likely would increase substantially and some homes near the ACFL might not be able to get insurance. Without access to home insurance or very high insurance rates would affect property values in the City of Anacortes.
The DNR cannot be everywhere at the same time and has limited resources so CALL the DNR is not a solution to a fire in the ACFL or Fidalgo Island.
Note: More and more articles in the media from many different sources are sounding the alarm of wildland fires becoming more common and larger and more dangerous and more destructive. Also, now articles are bringing the forefront the likelihood of many fires happening all at once overwhelming wildfire resources.
Risk Acceptance:
A serious risk assessment then a determination of an “acceptable” risk for a wildland fire needs to be done. In the case of wildland fire, the risk could be currently low to moderate but the impact of even a “small” wildfire that affects infrastructure in Anacortes (or on Fidalgo Island) will be large, a “medium” wildfire/infrastructure fire enormous, a “large” wildfire/infrastructure fire catastrophic. This is no small task.
Mitigation:
It is not likely the Anacortes Taxpayer will agree to higher taxes to adequately fund the AFD and APD for a “maybe” likely fire sometime in the future. So, some serious out-of-the-box, creative thoughts need to be developed then implemented plans are needed to do what is possible with the resources available in the most effective and efficient manner.
The time to do serious scenario planning for the unimaginable fire is now, not after it has occurred.
Warming Raises the Risk That Multiple Wildfires Strike at Once
This article was originally published by Vox and is reproduced here as part of the Climate Desk collaboration.
The extreme heat, high winds, and severe dry conditions that produce towering, fast-moving flames that advance by the acre are not just becoming more common; new research shows that these factors are increasingly arising in multiple regions at the same time, creating the conditions for simultaneous wildfires around the world.
In a study published in the journal Science Advances, researchers reported that the ideal conditions for major wildfires are now aligning across different parts of the world at more than double the rate they did nearly 50 years ago. Climate change is a major driver, accounting for about half of this increase. It’s the latest example of how humans are reshaping the nature of wildfires.
These changes have led to periods of inescapable smoke from blazes and more stress on firefighters, expanding the public health, economic, and social costs of infernos. As the climate continues to warm, these trends are likely to continue to worsen.
Wildfire smoke is already linked to tens of thousands of premature deaths in the U.S., and recent years have shown how this smoke can cross continents and oceans, polluting the air for people far away from the flames. East Coasters might remember how Canadian wildfires a few years ago bathed cities like New York and Philadelphia in an amber haze, triggering air quality warnings. One study found that the smoke from those fires contributed to 82,000 deaths.
Meanwhile, the efforts to contain these devastating blazes are devouring money, time, engines, tankers, and firefighters, often beyond what local fire departments can muster on their own.
But with more wildfires burning in different parts of the world at the same time, countries will have their own blazes to deal with and less outside help will be available.
The result is that we may see more years with multiple major blazes at the same time, and you might find it harder to find clear air to breathe for growing swaths of the year.
Cong Yin, the lead author of the study and a scientist at the University of California Merced, explained that research has been piling up showing that the weather conditions that favor major wildfires are becoming more common in different regions. Yin wanted to take a step back to see if there was a pattern that would emerge when he looked at the world as a whole.
Yin and his colleagues analyzed global climate and fire data between 1979 and 2024 and traced the fire weather index, a measure of fire dangers based on meteorological traits like temperature, wind, and moisture. The higher the index reaches, the greater the chances of a dangerous wildfire. The team drew on fire activity records from the Global Fire Emissions Database, which uses satellite data and ground-based measurements to track burned areas around the world. The team then counted the number of days where the fire weather index was in the 90th percentile in more than one region.
The results showed that over the study period, days with extreme fire weather conditions were increasing in places inside regions like North America but also seeing severe fire weather line up across far-flung areas like North America and Europe. That makes it harder to coordinate firefighting efforts across borders.
We’ve seen in recent years that countries with major fires have received needed help from neighbors, and from farther away. Teams from Canada and Mexico joined the fight against the Los Angeles wildfires last year, even bringing equipment like tanker aircraft. During the wildfires in Spain last summer, the Netherlands, France, and Italy also sent firefighting aircraft. In past fire seasons, South Africa has sent firefighters to Canada. The U.S., Australia, and New Zealand have a standing firefighting cooperation agreement to share personnel and equipment between the countries.
However, worldwide, the number of days where severe fire weather has occurred in multiple places at the same time has more than doubled over the majority of fire-prone landscapes. With more fire weather occurring at the same time, countries may not be able to lend out tools and personnel as much because they’ll need everyone on deck at home.
When Yin and his team looked closer at regions like North America, climate variability drivers like the El Niño–Southern Oscillation, the periodic warming and cooling of the Pacific Ocean, tended to create fire weather conditions across the continent. The planet’s boreal regions — forested areas in northern latitudes — showed the highest levels of synchronized fire weather. They tend to experience extreme heat, little rain, and high winds at the same time more often. At the same time, the research identified areas where fire conditions are becoming less aligned, like Southeast Asia. The researchers think this is likely due to increasing humidity in tropical regions as temperatures rise. That can make it harder to achieve the ideal conditions for a major fire.
To figure out the role of climate change, the researchers constructed a model of a world where the climate hasn’t changed and compared it to the observed results of the world we’re currently in. They also calculated the role of natural climate drivers like the El Niño–Southern Oscillation. When they looked at the difference between the scenarios with and without warming, they found that climate change driven by humans has led to about half of the observed increase in synchronized fire weather since 1979.
Yin cautioned that there are some caveats to consider. Even when weather conditions are favorable to fire, they aren’t a guarantee that one will ignite. Fires also need fuel and a source of ignition. Without these two ingredients, even the most severe hot, dry, and windy conditions won’t lead to a blaze. “They are more difficult to predict or measure,” Yin said. “If we want to do a better job, we need to measure all these three dimensions.”
You may have already experienced how wildfires have become impossible to ignore, even when they’re far away, whether you’re breathing their smoke or paying for their damages. These results show that millions more people will likely be breathing dirty air with you when a major fire season gets underway.
Robert Field, a fire researcher at Columbia University, observed that when so many fires burn at the same time, the smoke can pose an even bigger public danger than the flames. Thousands of homes may burn, but millions of people end up breathing dirty air that takes years off their lives. And when these blazes ignite, the resources for containing wildfires may end up spread thin. That could lead to longer stretches of dirty air as well as more costly damages to property, which end up getting passed onto you through higher taxes and insurance rates.
The increasing threat from wildfires is also taxing for firefighters, who are not just facing more dangers to their lives and limbs, but also to their mental health. Field said the study shows that everyone should start preparing for the threat of simultaneous severe fire. “I really haven’t seen a paper like this on a global scale,” said Field, who was not involved in the study. “I think it’s a prelude to what’s coming.”
It’s clear then that we can’t simply rely on firefighting to cope with this problem.
Many of the ways we measure fire risk today systematically underrate the actual threats that you might face, especially as average temperatures continue to rise and as communities sprawl into fire-prone landscapes.
Getting an accurate assessment of wildfire risk is critical, even if it is inconvenient for your property values. We also need to invest more in managing the landscape through measures like controlled burns, which can worsen air quality but prevent even worse breathing problems down the line.
And of course, we need to reduce our impact on the global climate by curbing our emissions of greenhouse gases. But until then, keep an eye on the forecast and the air-quality index, and keep an N95 mask close.
—Umair Irfan, Vox
Public Comment Submission
Date: July 13th, 2026
Subject: Nihart comment on AMC Title 19, Unified Development Code
Hello Planning Commission:
I have some concerns regarding the AMC Title 19, Unified Development Code proposal. I am hoping the Planning Commission members can help me understand better.
- How does doing a substantial process change at the same time as a huge time-consuming, complex process provide for “better” outcomes than completing the SMP/CAO updates and approval first than doing a process improvement project complete with Public Involvement? (Not to mention not only does this put a huge burden on City Staff, the Planning Commission and Council it is being done during the summer vacation time.)
- What part of the AMC Title 19, Unified Development Code proposal addresses the issues brought up by the FACET Report commissioned by the City? How can a process improvement happen without addressing the issues brought up in that report?
SGA has some suggested edits/additions to the proposal, a proposal that should happen after the SMP/CAO update and FACET Report Analysis:
- It is important to communicate early to neighbors and get their input on major projects. Thus, adding language such as requiring a neighborhood meeting or equivalent early outreach for Type 2, shoreline, critical area, and multifamily projects before SEPA threshold determinations or site plan approval. In addition, require notice plus a comment period before the City issues DNS or MDNS on major projects.
- Environmental issues should be kept open until the project is fully defined. This would require the site plan finality language so that later permits may still revisit environmental mitigation where the engineering package changes materially. Thus, the process should allow reconsideration if revised grading, drainage, access, drainage outfalls, lighting, or utility design could affect shoreline, wetland, steep slope, fish and wildlife habitat, or buffer functions.
- It is important to narrow administrative flexibility in sensitive areas to ensure a repeatable process by all planners and over future years. So, the process should be clarified that no administrative exception or departure may be used to reduce standards in a manner that undermines SMP, CAO, stormwater, floodplain, or comprehensive plan policies. And as important administrative flexibility is not allowed if the result would reduce buffer function, habitat protection, public views, shoreline ecology, or mitigation effectiveness.
- The SEPA/permit sequencing should be much more transparent. The City should publish a single consolidated project summary when SEPA, site plan review, and administrative exceptions are being considered together. To ensure transparency a public-facing decision memo should identify all departures, exceptions, mitigation measures, and unresolved issues before final project approval.
I am all about public involvement as we (including PC members) are the residents – the owners and financiers – of the City of Anacortes: The process should not only preserve public appeal relevance but enhance it. To do this if later engineering plans materially change impacts to critical areas, shorelines, drainage, or access, a supplemental review notice and comment opportunity is required before issuance of site construction or building permits.
The Planning Commission is authorized and mandated to maintain a transparent, accessible public process. They hold regular public hearings to gather citizen testimony and stakeholder input before moving a recommendation forward. I am looking forward to that process.
To close I am very excited that the City is thinking about process improvement. I spent lots of my time at Boeing involved in process improvement projects. I also have a Master of Science in System Management, so it is a passion of mine – systems and improving them.
Thank you for your attention. Much appreciated.
Respectfully,
Mark B. Nihart
Ward 2
SGA comments to Planning Commission 8/8/2026 re: Climate Change, Ecological Resilience, and Implementation Gaps in the Updated Gap Analysis and Consistency Review
To: Anacortes Planning Department and Planning Commission
From: Smart Growth Anacortes (SGA)
Subject: Climate Change, Ecological Resilience, and Implementation Gaps in the Updated Gap Analysis and Consistency Review
Planning Commission Members and Planning Staff:
Smart Growth Anacortes believes, with excellent and independent factual cause, that the Updated Gap Analysis and Consistency Review provides a useful starting point for the Shoreline Master Program update. The document identifies several important changed circumstances and planning updates, including climate change, sea level rise, updated floodplain regulations, the 2025 Comprehensive Plan Climate Element, the Shoreline Master Program Compliance Assessment Report, and the ongoing Best Available Science review.
SGA commends the Planning Department for identifying these issues and for attempting to coordinate the SMP update with the Comprehensive Plan, Critical Areas Ordinance update, and state requirements. This is a positive step.
However, SGA believes the Updated Gap Analysis does not go far enough.
Our concern is not that climate change is completely absent from the document. Climate change and sea level rise are acknowledged. The concern is that they are acknowledged without a sufficiently methodical analysis of how climate change and extreme environmental conditions will affect the ecological systems, shoreline infrastructure, and residents the SMP is intended to protect.
The current analysis is strongest as a review of changes in statutes, regulations, and adopted planning documents. It is less complete as an analysis of changed environmental conditions and foreseeable risks.
SGA believes there is still time to do this right. The City has until December 31, 2027 to update the SMP and there is no State required date for the Permit Streaming proposal. (see Turner and Munce versus City of Anacortes, Case No.: 26-2-0008).
Thus, this allows sufficient time for substantial analysis, major edits and additions to the document and to have the public engaged not only in making comments but in determining decisions.
The City is currently undertaking three related and important processes:
- Updating the Shoreline Master Program
- Reviewing the Shoreline Master Program through the FACET Compliance Assessment Report
- Updating Critical Areas regulations using Best Available Science.
These processes should not operate independently. They should be integrated into one transparent and scientifically supported process.
The FACET Report identifies implementation weaknesses in the existing SMP. The Draft BAS Report identifies the scientific basis for protecting wetlands, fish and wildlife habitat, streams, and other critical areas. The Updated Gap Analysis should use both documents to determine whether the City’s existing and proposed shoreline regulations are adequate for the environmental conditions Anacortes faces today and is likely to face in the future.
SGA therefore submits the following Executive Review, recommendations with annotations, summary, and conclusion.
Executive Review
The Updated Gap Analysis recognizes climate change but does not fully analyze climate change as a changed circumstance
The Updated Gap Analysis identifies climate change and sea level rise as important considerations. It recognizes the City’s Climate Element, changes to floodplain regulations, and future state rulemaking regarding sea level rise and shoreline management.
This is an important start.
However, SGA believes the analysis is too narrowly framed.
Climate change should not be evaluated only as:
- sea level rise
- future coastal flooding
- future state rulemaking
Climate change in Anacortes is a system of interconnected risks and environmental changes. These include:
- sea level rise
- King Tides
- storm surge
- compound flooding
- atmospheric rivers – extreme precipitation
- urban flooding
- drought
- low stream flows
- increased water temperatures
- wildland fires
- post-fire erosion and runoff
- changes to wetland hydrology
- changes to lakes and streams
- degradation of riparian areas
- loss of tree canopy
- habitat fragmentation
- impacts to wildlife, plants, birds, fish, and other species.
These issues should be evaluated together because the impacts can compound one another.
A high King Tide occurring during an atmospheric river is not the same planning event as a normal high tide. A drought followed by an intense rainfall event is not the same as a typical stormwater event. A wildfire followed by heavy rainfall can create sediment, erosion, runoff, and habitat impacts not present under normal conditions.
The Updated Gap Analysis should therefore expand its climate review from a narrow “Climate Change and Sea Level Rise” category to a broader climate and ecological resilience analysis.
Waiting for future Ecology rulemaking should not prevent the City from addressing known local risks now
The Updated Gap Analysis indicates that Ecology’s future rulemaking concerning sea level rise should guide future comprehensive SMP amendments.
SGA agrees that the City should coordinate with Ecology.
However, waiting for future state rulemaking should not prevent Anacortes from addressing environmental conditions and vulnerabilities that are already known.
The City has already recognized and experienced:
- sea level rise
- coastal flooding
- climate change
- flood hazards
- climate-related planning concerns.
The City’s periodic review process should distinguish between:
Actions that can be taken now
These may include:
- improving permit documentation
- mapping environmental conditions
- requiring baseline ecological information
- improving vegetation protection
- improving wetland and stream protection
- improving monitoring
- clarifying no net loss requirements
- identifying site-specific climate vulnerabilities
Actions that may require future state guidance
These may include larger regulatory changes dependent upon new Ecology shoreline guidance or future statewide requirements.
SGA believes both tracks can occur at the same time.
The question should not be: “Do we wait for Ecology?”
The question should be: “What can Anacortes improve now, based upon what we already know, while remaining prepared to make additional changes when Ecology completes its work?”
The FACET Report demonstrates that existing implementation gaps must be addressed before concluding that the SMP is adequate
The FACET Compliance Assessment Report provides an important factual basis for the SMP update.
The report found that the existing permitting and implementation system does not consistently demonstrate compliance with the SMP’s no net loss requirements. Among the concerns identified were:
- incomplete mitigation sequencing documentation;
- infrequent critical area reports;
- inadequate vegetation documentation;
- inconsistent landscape and mitigation plans;
- missing as-built documentation; and
- limited monitoring reports.
SGA previously stated that the FACET Report provides an excellent opportunity for a full process improvement assessment. The City has done something valuable by commissioning an independent review. The next step is to use the findings.
The Updated Gap Analysis should not simply state that FACET recommendations will be considered where applicable.
SGA recommends that each FACET recommendation be tracked through the SMP update process.
A transparent matrix should be created:
| FACET Finding | Identified Problem | Proposed Recommendation | SMP or Code Section | City Action | Implementation Date |
This would provide traceability.
It would allow the Planning Commission and the public to determine:
- which FACET recommendations are being adopted
- which recommendations are being modified
- which recommendations are being rejected
- the reasons for each decision.
This is consistent with SGA’s belief that transparent decision criteria and documented processes improve both public confidence and final outcomes.
The Draft BAS Report should be integrated into the climate analysis
The Draft Best Available Science Report provides a scientific framework for evaluating wetlands, fish and wildlife habitat conservation areas, streams, and other critical areas.
The BAS process recognizes that critical areas perform ecological functions and provide ecological values that depend upon:
- hydrology
- vegetation
- habitat connectivity
- buffer conditions
- sensitivity
- rarity
- location
- site-specific environmental conditions.
Climate change has the potential to alter each of these conditions
A wetland may experience changing hydrology.
A stream may experience lower summer flows and higher winter flows.
Riparian vegetation may experience drought stress.
Wildlife habitat may become fragmented or unsuitable.
Tree canopy may decline.
Plant communities may change.
Bird habitat may be altered by changing food, water, and nesting conditions.
SGA believes that the BAS Report and the SMP Gap Analysis should not be treated as separate documents moving through separate processes.
The City should develop a BAS–CAO–SMP Consistency Matrix:
| BAS Finding or Recommendation | CAO Provision | Existing SMP Provision | Proposed Amendment | Remaining Gap |
This will allow the Planning Commission and public to see whether the science supporting critical area protection is actually being translated into shoreline regulations and permit decisions.
Recommendations With Annotations
Recommendation 1 — Expand the climate change review category
Identified Problem
The current climate discussion is largely focused on sea level rise and future coastal flooding.
SGA Recommendation
Replace the current climate review category with:
Climate Change, Sea Level Rise, Extreme Weather, Hydrologic Change, and Ecological Resilience
Annotation
This broader category should specifically evaluate:
- sea level rise
- King Tides
- storm surge
- compound flooding
- atmospheric rivers
- extreme precipitation
- urban flooding
- drought
- low-flow conditions
- wildfire
- post-fire erosion
- wetland hydrologic change
- stream and lake impacts
- riparian degradation
- tree canopy loss
- habitat fragmentation
- impacts to fish, wildlife, plants, and birds
Why this matters
Climate impacts should not be analyzed as isolated events. The City’s environmental systems are connected.
SGA recommends a simple and transparent analysis matrix:
| Climate Hazard | Resource Affected | Existing Protection | Identified Vulnerability | Recommended Action |
Recommendation 2 — Add King Tides and compound flooding to the changed-circumstances analysis
Identified Problem
The Updated Gap Analysis discusses coastal flooding but does not clearly identify King Tides and compound flooding as separate planning scenarios.
SGA Recommendation
The City should evaluate the combined impacts of:
- elevated tides
- sea level rise
- storm surge
- heavy rainfall
- saturated soils
- high stream flows
- urban drainage limitations
Annotation
The City should evaluate whether existing:
- setbacks
- flood standards
- vegetation requirements
- redevelopment standards
- shoreline stabilization standards
- critical area protections remain adequate under compound flood conditions.
A planning framework that evaluates one hazard at a time may underestimate actual risk.
Recommendation 3 — Add atmospheric rivers and urban flooding as specific review topics
Identified Problem
The Updated Gap Analysis addresses floodplain management but does not appear to fully analyze extreme precipitation and urban flooding as changed circumstances.
SGA Recommendation
Add a specific review category:
Extreme Precipitation, Atmospheric Rivers, Stormwater Capacity, and Urban Flooding
Annotation
Extreme rainfall can:
- overwhelm drainage systems
- increase runoff
- increase erosion
- transport sediment and pollutants
- damage stream banks
- alter wetland hydrology
- affect nearshore water quality
These are shoreline ecological issues as well as infrastructure issues.
The City should evaluate whether current development standards adequately protect:
- permeable surfaces
- native vegetation
- wetlands
- riparian areas
- tree canopy
- natural infiltration
Recommendation 4 — Add drought and low-flow conditions
Identified Problem
Drought and seasonal water stress are not adequately addressed in the climate review.
SGA Recommendation
The Updated Gap Analysis should evaluate the impacts of drought and low-flow conditions on:
- streams
- lakes
- wetlands
- groundwater
- riparian vegetation
- fish
- wildlife
- wildfire risk
Annotation
The City should ask whether the current regulatory framework protects ecological functions during both:
Too Much Water
and
Too Little Water
A climate-resilient shoreline program must be capable of addressing both conditions.
Recommendation 5 — Add wildfire and post-fire environmental impacts
Identified Problem
Wildland fire does not appear to be evaluated as a changed circumstance affecting shoreline and critical-area systems.
SGA Recommendation
Add:
Wildland Fire, Post-Fire Erosion, Watershed Impacts, and Ecological Recovery
as a climate and environmental review category.
Annotation
Wildfire can affect:
- vegetation
- soils
- slope stability
- erosion
- sediment transport
- streams
- wetlands
- habitat
The SMP and CAO should be evaluated to determine whether they provide adequate standards for:
- post-fire erosion control
- sediment protection
- restoration
- native and climate-resilient vegetation
- prevention of unnecessary conversion of environmentally damaged areas into permanent development.
Recommendation 6 — Require a climate-resilience review for wetlands
Identified Problem
Wetlands are generally evaluated based upon current mapping and existing conditions without sufficient consideration of changing hydrology and future climate conditions.
SGA Recommendation
Where climate risk is reasonably foreseeable, shoreline projects should evaluate the potential effects of:
- changing hydrology
- sea level rise
- increased inundation
- drought
- salinity
- sedimentation
- habitat connectivity
Annotation
The BAS Report emphasizes wetland functions and values.
SGA recommends that the City evaluate whether mitigation and restoration plans are designed only to replace present-day conditions or whether they will remain functional under foreseeable future conditions.
The goal should be:
No Net Loss of Ecological Function and Increased Ecological Resilience Where Restoration or Mitigation Occurs.
Recommendation 7 — Strengthen protection for streams, lakes, and riparian areas
Identified Problem
Climate change impacts to streams, lakes, and riparian systems are not clearly integrated into the Gap Analysis.
SGA Recommendation
Require shoreline projects to identify:
- existing streams and waterbodies
- riparian vegetation
- buffers
- canopy conditions
- ecological functions
- foreseeable climate vulnerabilities
Annotation
The City should consider a permit requirement for a baseline ecological conditions analysis for projects involving:
- new development
- substantial redevelopment
- vegetation clearing
- shoreline modification
- work within or near critical areas
This information is necessary for the City to determine whether ecological functions are being protected.
One cannot demonstrate improvement or no net loss without first knowing the baseline condition.
Recommendation 8 — Treat tree canopy and native vegetation as climate infrastructure
Identified Problem
The FACET Report identifies inconsistent implementation of vegetation conservation and revegetation requirements.
SGA Recommendation
The SMP should treat shoreline tree canopy and native vegetation as functional environmental infrastructure.
Require applicable shoreline applications to include:
- existing vegetation mapping
- canopy information where relevant
- proposed vegetation removal
- proposed native vegetation retention
- revegetation areas
- monitoring requirements
Annotation
Vegetation contributes to:
- stormwater infiltration
- erosion control
- shading
- habitat
- water temperature protection
- slope stability
- shoreline resilience
SGA recommends that the City establish a measurable baseline and evaluate projects against that baseline.
Recommendation 9 — Strengthen No Net Loss by adding ecological resilience
Identified Problem
The FACET Report demonstrates that mitigation sequencing and No Net Loss documentation are not consistently demonstrated.
SGA Recommendation
The SMP should clarify that No Net Loss analysis must evaluate:
- Existing ecological functions
- Proposed project impacts
- Avoidance
- Minimization
- Remaining impacts
- Compensatory mitigation
- Long-term ecological resilience
Annotation
SGA recommends a standard City No Net Loss template.
The template should require a documented logic chain:
Existing Condition → Proposed Impact → Avoidance → Minimization → Residual Impact → Mitigation → Monitoring → No Net Loss Determination
This would provide consistency for:
- applicants
- City Staff
- consultants
- the Planning Commission
- the public
Recommendation 10 — Require vegetation and critical-area mapping
Identified Problem
The FACET Report identified deficiencies in the documentation of critical areas and existing vegetation.
SGA Recommendation
Require applicable shoreline permit site plans to identify and map:
- wetlands
- streams
- buffers
- fish and wildlife habitat
- shoreline vegetation
- tree canopy
- significant native vegetation
- proposed clearing
Annotation
This recommendation should be integrated into the permit application and SmartGOV workflow.
The City should use the permit system to automatically identify when additional environmental review is required.
This is an opportunity for process improvement.
Better information at the beginning of the process can reduce:
- uncertainty
- delays
- redesign
- public conflict
- potential litigation later in the process
Recommendation 11 — Integrate the FACET and BAS recommendations before finalizing the SMP update
Identified Problem
The Updated Gap Analysis recognizes the FACET and BAS processes but does not clearly demonstrate how each recommendation will be incorporated into the final SMP.
SGA Recommendation
Before final adoption, publish a consolidated implementation matrix:
| Source | Finding | Recommendation | SMP/CAO Section | City Decision | Reason |
The sources should include:
- Updated Gap Analysis
- FACET Compliance Assessment
- Draft BAS Report
- Comprehensive Plan Climate Element
- public comments
Annotation
This would provide the traceability SGA has previously recommended.
The public should be able to see:
- the problem
- the evidence
- the recommendation
- the City’s response
- the decision maker
- the final action.
Recommendation 12 — Establish a climate and ecological monitoring program
Identified Problem
The FACET Report identified weaknesses in monitoring, as-built documentation, and long-term tracking.
SGA Recommendation
Establish measurable indicators for shoreline ecological condition and climate resilience.
Potential indicators include:
- shoreline vegetation retained
- shoreline vegetation restored
- wetland buffer condition
- riparian canopy condition
- tree canopy changes
- impervious surface changes
- shoreline armoring
- wetland impacts
- stream impacts
- habitat impacts
- mitigation success
- monitoring compliance
- flood and climate-related permit conditions
Annotation
SGA recommends an annual or biennial:
Anacortes Shoreline Ecological Condition and Compliance Report
The report should be public-facing, understandable, and visually organized.
The residents of Anacortes—the owners and financiers of the City—should be able to determine whether the City’s shoreline program is actually protecting the environmental resources it is required to protect.
Summary
SGA believes the Updated Gap Analysis is a useful starting point, but it is not yet a complete analysis of changed environmental conditions.
The document correctly identifies:
- climate change
- sea level rise
- floodplain updates
- the Comprehensive Plan Climate Element
- the FACET Compliance Assessment
- the ongoing BAS review.
However, the analysis should go further.
The primary gap is the difference between recognizing climate change and evaluating the consequences of climate change for the actual environmental systems regulated by the SMP.
Those systems include:
- wetlands
- lakes
- streams
- riparian areas
- shoreline vegetation
- tree canopy
- fish and wildlife habitat
- plants
- birds
- broader ecological connectivity.
The FACET Report provides evidence that the current implementation system has weaknesses.
The Draft BAS Report provides the scientific framework for protecting ecological functions.
The Updated Gap Analysis should bring these findings together.
SGA recommends a single integrated process using:
- A Climate and Ecological Resilience Matrix
- A FACET Recommendation Implementation Matrix
- A BAS–CAO–SMP Consistency Matrix
- A public-facing Shoreline Ecological Condition and Compliance Report.
This would create a transparent logic chain:
Documented Environmental Condition → Identified Risk or Gap → Scientific and Regulatory Basis → Recommendation → Code or Process Change → Monitoring → Public Reporting
This methodology would make the SMP update more transparent, measurable, actionable, and defensible.
Conclusion
SGA respectfully requests that the Planning Department and Planning Commission expand the Updated Gap Analysis before relying upon it as the basis for concluding that only limited amendments to the Shoreline Master Program are necessary.
The City has an opportunity to use this update to address not only changes in state law and adopted plans, but also the environmental conditions that Anacortes is experiencing and will increasingly experience.
SGA is not recommending delay for the sake of delay.
SGA is recommending that the City use the information it has already commissioned and collected to improve the quality of the SMP update.
The FACET Compliance Assessment identifies where implementation is not consistently achieving the intended results.
The Draft BAS Report provides scientific information regarding wetlands and fish and wildlife habitat conservation areas.
The Comprehensive Plan Climate Element identifies climate change as a significant planning issue.
The Updated Gap Analysis should integrate these findings into a single, traceable, transparent, and actionable framework.
There is time to do this right.
SGA requests that the Planning Commission direct Planning Staff to prepare a supplemental Climate and Ecological Resilience Analysis and associated consistency matrices before the Planning Commission makes its final recommendation on the SMP amendment package.
The purpose should be clear:
- identify what has changed
- identify what is at risk
- determine whether existing regulations remain adequate
- identify where implementation has failed
- incorporate Best Available Science
- strengthen shoreline ecological resilience
- improve transparency and public accountability
- provide measurable evidence that the City’s Shoreline Master Program is protecting the environmental resources and community it is intended to serve.
SGA would welcome a respectful, informed, and positive conflicted dialogue with City Staff, the Planning Commission, other organizations, technical experts, and the public.
The objective should not be to create winners and losers.
The objective should be a better process and a better result.
A result in which:
- City Staff have clear decision criteria
- applicants understand requirements
- environmental protections are measurable
- ecological conditions are documented
- mitigation is monitored
- public participation is meaningful
- the residents of Anacortes—the owners and financiers of the City—have confidence that the future of their shoreline, environment, and community is being determined through a transparent, informed, and accountable process.
There is an opportunity here for a win-win for all.
Respectfully,
Mark B. Nihart
President Smart Growth Anacortes
Smart Growth Anacortes – Vision Statement
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, and appointed boards and commissions in a transparent, respectful, collaborative environment for the benefit of all who live, work, and serve in Anacortes.
Strengthening the SMP: A Call for a Complete Climate and Science-Based Update
Smart Growth Anacortes supports the City’s Updated Gap Analysis as a useful starting point for the Shoreline Master Program update, but we believe it falls short of fully addressing the environmental realities Anacortes faces. Climate change, extreme weather, sea level rise, and shifting ecological conditions must be analyzed as interconnected risks—not simply listed as future concerns. The City has already commissioned strong scientific and compliance tools through the FACET Report, the Best Available Science review, and the Comprehensive Plan Climate Element; these should be integrated into one transparent, traceable process that clearly shows how recommendations are being used. With time remaining before the 2027 deadline, the City can strengthen shoreline protections, improve implementation, and build a more resilient, science‑based SMP. We urge the Planning Commission to direct staff to prepare a supplemental climate and ecological resilience analysis so the final SMP update is measurable, defensible, and aligned with the community’s long‑term environmental needs.
Is Growth Necessary?
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Locally owned businesses
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Strong civic collaboration
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Investments in schools, parks, housing, broadband, and “third spaces”
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Many rural communities with slow or negative growth still succeed when they plan development strategically.
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Sustainability comes from protecting local assets, walkable main streets, and community-centered planning, not from chasing growth.
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The biggest threat is limited local government capacity, not population growth rate.
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Collaboration, regional partnerships, and diversified economic strategies improve sustainability.
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Rural communities vary widely.
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Some thrive with modest or no population growth.
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Others struggle despite growth because their economic base is narrow.
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Local entrepreneurship
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Civic engagement
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Infrastructure and quality-of-life investments
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Regional collaboration
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Housing affordability crises
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Infrastructure strain
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Loss of rural character
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Traffic congestion
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Loss of farmland and open space
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Stable or slowly changing population
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Strong social capital
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High civic participation
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Locally controlled development
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Local governance weakens
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Civic ties erode
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Economic decisions are outsourced
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Land use becomes reactive instead of planned
