August 20, 2025

To: Planning Commission, Board Of County Commissioners, Island County Planner Emily Neff

From: Marnie Jackson, WEAN Executive Director

Dear Planners, Commissioners, and Planning Staff,

I urge you to adhere to your original population projections and allocations and ask the City of Oak Harbor to responsibly rezone and plan for infrastructure improvements to accommodate the necessary growth within the city limits. We know that the city favors developer-led annexations as a primary way to add capacity, and we agree with Island County's view of these annexations as inappropriate to meet the needs of city residents. City-led infrastructure improvements within the city limits are necessary, should be expected, and could do a great deal to address the buildable lands capacity shortfall. The September 17th, 2024, Land Capacity Analysis Memorandum from Kimley Horn indicates that among the 1594 parcels removed from analysis, some were “parcels identified by staff as being low probability for development (infrastructure constraints)”. This indicates that addressing infrastructure constraints is at least a partial solution, and one which Oak Harbor should be asked to address.

We know there are already areas in the city that lack sidewalks and basic urban amenities. This is evidence that Oak Harbor should not be allowed to continue planning in the ways it has always done. Instead, it should be held accountable to plan for responsibly improving zoning and infrastructure within the city. The question of whether the UGA needs to expand can only be accurately answered when we can see, some years down the road, whether the city has maximized its capacity within the city by responsibly providing the necessary infrastructure and zoning.

The GMA requires cities and counties to plan for anticipated population increase and the necessary infrastructure to support it. The original population target was the result of a rational process and is more likely to reflect future reality than the reduction now being considered, as was acknowledged by planning commissioners, planners, and county commissioners during your July 16 discussions. The public was even told that the new, reduced targets will likely exacerbate the already present housing shortage. While we understand and share Island County’s concerns about Oak Harbor's apparent unwillingness to act as a good-faith partner in this process, we believe that setting an unrealistic population projection is not the answer. The GMA's purpose is to change growth patterns for the better, and we explicitly reject the argument that Oak Harbor’s past shortcomings should mean they get a pass now.

Oak Harbor’s reliance on developer-provided infrastructure as a de facto policy has been shown to be ineffective in providing the necessary support for affordable housing projects to succeed. This approach is contrary to the purpose of the GMA. We believe that by allowing this reduction, the County would be joining Oak Harbor in avoiding the new housing requirements of the GMA.

Sticking with the original population forecast is not just good planning: it is consistent with the GMA’s new housing requirements, which aim to provide sufficient housing for people of all incomes. It’s fair to Coupeville and Langley, who planned in good faith. It’s fair to the residents and wildlife of the rural areas, who rely on urban density as a counterpoint to the agricultural, recreational, and ecological assets of the surrounding areas. Most of all, it’s fair to the residents of Island County who need and deserve livable cities and affordable homes and apartments. We commend you for your resistance to expanding the UGA, and we urge you to stand firm on the original population projections. Don’t allow the planning process to be undermined by Oak Harbor’s resistance to change.

Thank you, 

Marnie Jackson