San Juan County is considering changes to the Comprehensive Plan that would classify utility-scale renewable energy projects, such as large solar arrays, battery storage sites, or experimental tidal energy devices, as Essential Public Facilities (EPFs). Friends of the San Juans supports responsible renewable energy, but we have significant concerns about a blanket approach to EPF designation. The decision would have major impacts on environmental protection, public participation, and land-use planning in the islands.
Background: What Are Essential Public Facilities?
Under Washington’s Growth Management Act (GMA), EPFs are facilities that are difficult to site due to noise, environmental impacts, or public opposition. Examples include jails, solid waste facilities, and major state transportation facilities. Local governments must have a process to identify and site EPFs and cannot completely prohibit them. Renewable energy facilities are not automatically EPFs under state law; including them is a discretionary local decision.
What the County Is Proposing
Several draft Comprehensive Plan policies (LU 4.1, U 6.10, U 7.4, and U 7.7) would identify utility-scale renewable energy generation and energy storage as EPFs, streamline the permitting process, and allow pilot programs for new technologies. Together, these changes create a pathway for major energy projects to receive expedited approval and reduced oversight.
Key Concerns
- A blanket EPF designation shortcuts required review.
Labeling all commercial renewable projects as EPFs bypasses the County’s existing process for determining whether a facility qualifies. This fast-tracks large industrial projects that need careful analysis and public oversight.
- Environmental review may be weakened.
While SEPA still applies, the County may interpret the law to mean it cannot fully deny an EPF. This could allow projects to move forward even where environmental review identifies serious impacts.
- Public participation is reduced.
Adding EPFs through the Comprehensive Plan process mixes the decision into hundreds of pages of updates, making it harder for the community to track, understand, and comment. Focused hearings and clear notices that typically accompany EPF decisions would not occur.
- Projects may be pushed into inappropriate locations.
A blanket EPF designation may lead to siting renewable energy facilities on lands that cannot support them. This includes forested lands that require clear-cutting, agricultural or resource lands protected under the GMA, or areas with sensitive habitat and steep slopes.
- Experimental projects may be placed in fragile ecosystems.
Proposals to give EPF status to pilot or experimental renewable energy projects, including marine or tidal technologies, could expose sensitive waters and habitats to untested systems.
- Resource lands may lose protection.
EPF designation could override long-standing protections for agricultural and forest resource lands, which the GMA requires counties to conserve for long-term use.
- Critical areas may be harmed because the project “must be sited somewhere.”
Wetlands, wildlife habitat, shorelines, and other critical areas may face development pressure if the County believes it cannot deny an EPF even where mitigation is not feasible.
Questions for the Community and Decision-Makers
• Does blanket EPF designation for renewable energy projects undermine proper siting and environmental safeguards?
• How can SEPA function meaningfully if the County believes it must approve an EPF even where impacts cannot be mitigated?
• Should experimental or pilot renewable projects qualify as EPFs given their unknown risks?
• What protects agricultural and forest lands if EPF status allows industrial development where it would otherwise be prohibited?
• Without a way to remove EPF designation later, what happens if a facility becomes harmful or unnecessary?
• Should the County make EPF decisions for renewable energy facilities on a project-by-project basis rather than using one blanket policy?
Friends of the San Juans supports renewable energy and climate resilience. But responsible siting is essential, especially in an island ecosystem as sensitive as the San Juan Islands. A blanket EPF designation limits transparency, reduces public involvement, and puts critical areas and resource lands at risk. Renewable energy development should continue in San Juan County, but through careful, transparent, project-specific review rather than automatic classification.