The Islands Trust is circulating a survey on their draft Trust Policy Statement (TPS), a document that regulates bylaws and Official Community plans passed by Local Trust Committees. We encourage anyone who cares about protecting the Islands Trust area to fill out the survey (link at the bottom) with consideration for significant shortcomings, explained below.
The survey groups many policies together, giving little opportunity to comment on which you approve and which you disapprove of. But there is a place for comments at the end of each section, as well as at the very end of the survey. Be aware that Directive Policies are supposed to be mandatory so are used by staff to evaluate compliance. Advisory policies are advisory. Please consider our concerns:
Goal 3 List Ecosystem Integrity suggested comments:
- Include protection of wetlands, riparian areas and all types of marine ecosystems and forests.
- State that natural ecosystems of all types should be protected against further degradation and adverse impacts of development.
- Consideration of the precautionary principle and cumulative effects must be in Directives.
Goal 4 Managing Growth and Development suggested comments:
- “Managing” growth allows ALL types of growth. Protecting the islands from over-development requires limiting growth and development.
- Addressing climate change was one of three goals of this project. One vague Directive (3.4.5) is not adequate.
Goal 4 (continued) Housing suggested comments:
- Omit zoning by floor area covered/FAR (3.4.14) that allows for many small residences on single-family lots. More people use more water, produce more sewage and have more vehicles. It is a way to sneak in unsuitable density.
- A Directive is needed to assure that rezoning for more density will only be for affordable and workforce housing with binding agreements to assure affordability
Goal 5 Freshwater suggested comments:
- Add Directive: protect water by protecting groundwater recharge areas, unfragmented forests, and native ecosystems via zoning/development permits.
- Recognize that many islands are already not self-sufficient in water and hence zoning increases must be limited to affordable housing
Overall Effectiveness of Draft TPS suggested comments:
- Directives should be mandatory: The introduction, not on the survey, states that policies called Directives are required whereas Advisory Policies are not. However later on, the TPS states that Directives may not be enforced if “adequate justification” is given.
- “Environment” should be defined as referring to the natural environment – This word is used throughout the document, yet is not defined in the glossary. A previous definition (that received objections) included man-made structures.