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Friends of North Plains and CPO-8
Comments on Periodic Review Work Products 3, 4, and 5

September 5, 2001

To: The North Plains Planning Commission

From: James Just, Friends of North Plains

Brian Beinlich, CPO 8

Re: Comments on Periodic Review Work Products 3, 4, and 5

Enclosed please find comments regarding Periodic Review Work Products 3, 4, and 5. We are submitting these comments in our role as our groups' citizen representatives to Periodic Review. Due to the extremely limited time available for review, these comments do not represent our complete analysis of the above Work Products, and we expect to submit further comments in the future. These comments have also not been reviewed or approved by either the Steering Committees or the members of Friends of North Plains or CPO 8.

The limited time available for document review concerns us greatly. We appreciate that the City is under a tight time line, as established by DLCD's April 10, 2001 Work Program. However, the sheer quantity of documentation, coupled with the short availability prior to the due date for comments, makes it nearly impossible for any person or group to conduct any meaningful review of the Work Products.

As an example of the amount of effort required, we note that the Work Product 3, 4, and 5 documents together stand about 7-8" tall. Work Products 3 and 4 (about 1 1/2" and 4" thick, respectively) were previously issued, but the new versions give no indication of the nature or extent of changes from the previous version. A prudent review of the documents would involve either (a) tediously comparing the document with the previous version to discover the differences, or (b) conducting a full review from scratch. Neither option is particularly appealing, especially given the time available.

Of the nine calendar days between the notice of document availability (8/27) and the review deadline (9/5), three were weekends or holidays. The City Manager was out of the office for at least three of the remaining days, further limiting our ability to obtain information about revisions to Work Products 3 and 4. In addition, the City did not provide copies of documents to Periodic Review participants as they have done in the past; instead, the entire document set could only be "checked out" for four days.

We would also like to remind you of the time that is now required to obtain CPO 8 approval of its representative's testimony. During the October 2000 CPO 8 meeting, Don Otterman, North Plains' City Manager, expressed concern that testimony and objections submitted by the CPO 8 representative might not reflect the viewpoint of the entire organization. The CPO 8 Steering Committee subsequently ratified the testimony in question, and now requires that submitted testimony be first approved by the CPO 8 Steering Committee, and if time permits, be voted upon at a CPO 8 meeting. (Note that CPO 8 meets monthly and usually does not meet during the summer.) Since this policy was created in response to the City's concerns, the City needs to provide sufficient additional time for the CPO approval process to operate. This includes time for Steering Committee members to review and revise the proposed testimony. Five to seven calendar days would be a practical minimum; longer time should be allowed if holidays are involved (as they are in this case), or if the City wishes to allow CPO members to review and approve the proposed testimony.

Taking all of the above into consideration, we believe the City has failed to provide for reasonable citizen review of its Work Products 3, 4, and 5. We therefore request that (a) the City provide copies of all documents to Review participants as it has done in the past, and (b) the Planning Commission continue the hearing on these Work Products to its October 10, 2001 meeting. These actions will help facilitate meaningful citizen review of the City's Work Products.

CPO 8 and Friends of North Plains appreciate the opportunity to participate in the City's Periodic Review. Our motivation is to enhance the City's efforts, not to hinder progress. However, in order for our input to be accurate and of maximum value to the City, we must have sufficient and timely access to the Work Products to allow for their evaluation. We look forward to continued collaboration on Periodic Review.

Respectfully submitted,

cc: Meg Fernekees, DLCD Regional Representative

Last modified 2001-09-06.

Friends of North Plains
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