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9 <br /> 02/26/12 <br /> City of Everett Planning&Community Development Department <br /> Attn.: Dave Koenig,Long Range Planning <br /> Re: DNS,SEPA11-027,Parks Element Update to Everett Comprehensive Plan <br /> It is true that the Parks Element Update to Everett Comprehensive Plan does not impose a <br /> probable significant adverse impact upon Everett's environment,and therefore is eligible <br /> for DNS status. <br /> However,it's unclear why this Element was needlessly re-organized in a manner that <br /> complicates citizen assessment of changes from the previous Comprehensive Plan.It was <br /> hoped that this Update would identify new or revised goals and/or policies,and relative <br /> priorities for addressing them,especially in underserved areas of Everett.This update's <br /> main shift in goals and policies is clear in Section III,Parts C,D, and E:positioning of the <br /> Parks and Recreation Department for increased engagement in revenue-producing forms of <br /> recreation,to sustain and supplement the Department's budget. Fine:but why rewrite even <br /> the unchanged objectives,policies,and supporting activities into lengthy, shuffled lists re- <br /> labeled"Strategies"?. <br /> Section III A,.Policy#3 clearly expresses the Parks Department's heightened priority on <br /> the business of recreation: <br /> According to the introductory paragraphs of Section III: <br /> "The statements of"policies,goals, and strategies are intended to guide the public and <br /> • <br /> those who make decisions about our future." <br /> "Policies are plans or courses of actions designed to determine decisions. Goals are <br /> broad statements of the community's desires and are supported by Parks and Recreation <br /> policies.The strategies are specific actions that are designed to help achieve goals." <br /> Yet many of the"strategies"cited for policy implementation apply to multiple City <br /> department operations in general,and represent objectives and sub-tasks internal to these <br /> Departments' normal administrative functions,without need for specification at the level of <br /> Everett's Comprehensive Plan.For example,the tasks specified in Strategies 9.6.1 through <br /> 9.6.3 would also apply to the work of the departments that support Transportation, <br /> Housing, or Public Works,as standard administrative practices. If included,they should at <br /> most be boiled down to concise statements like those used in Section V,the Action Plan. <br /> Two other unfortunate Strategy statements (below) seem to suggest that the Department <br /> seeks to steer the Parks Commission's role in decision-making toward to endorsement of <br /> Dept.priorities: <br /> Strategy 9.6.4 Utilize a management strategy for the Board of Park Commissioners <br /> that allows it to achieve measurable outcomes and that hold the Department <br /> accountable. (Interpretation,please?) <br /> Strategy 9.6.7 Train (??Provide guidelines to?) all advisory boards and <br /> committees on communication and management practices(?) of boards to achieve the <br /> highest level of productivity. (City departments serve the public: citizen advisory <br /> boards and committees deserve respectful communication, not "training".) <br /> 81 -1.. <br />