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Responsible Planning for Growth: The 2025 Comprehensive Plan – February 2024 update

What is the Comp Plan? 

The Growth Management Act (GMA) was adopted in 1990 to address growth in Washington State. Cities in counties over a certain size must do periodic Comp Plan updates in accordance with the GMA, while smaller counties may choose to do so. Cities within a county that plans under the GMA are also required to do so . 

This means that Clark County and its cities are required to plan under the GMA. Woodland has chosen to plan under the GMA although it straddles 2 counties while Cowlitz County has declined to create a Comp Plan. The current planning cycle is in progress and due in June of 2025, although there is a bill under consideration in the state legislature to change this for some counties, including Clark, to December of 2025. The Comp Plan is only updated once every ten years and has broad, sweeping implications for our county and cities, so the process that is underway is a very big deal!   

Image from the Clark County Comprehensive Plan 

Clark County’s Comp Plan Update Status

• Shoreline Management Plan complete, which is made up of the following 3 elements:

1. 1. Shoreline goals and policies are included in the Clark County Comprehensive Plan as Chapter 13.
   2. Shoreline use regulations are included in Clark County Code, Chapter 40.460.
   3. The Official Shoreline Map is an appendix in the Comprehensive Plan.
      

• Parks, Recreation, and Open Space (PROS) plan complete, which can be found here;
• Population projections adopted in May 2023. The county chose to use higher numbers than the Department of Commerce (and others) believed were most likely, which will cause unnecessary expansion of Urban Growth Areas (areas the cities can annex, while the county can develop to urban densities). 
  • Projections provided by WA Dept of Commerce:
    High – 798,809
    Med – 698,416 (most likely)
    Low – 576,151 
  • Clark County adopted: 718,154
• Employment projections adopted August 2023. Learn more here.
• Vacant Buildable Lands: first round complete and being updated due to legislative changes. This will assess the capacity of the current cities and urban growth areas to accommodate residential and commercial/industrial growth which will be used to determine what additional (if any) urban growth area needs to be defined. Learn more here.
• Public Participation Plan(s) adopted. 
• Site Specific Requests for inclusion in the Comp Plan being accepted through March 15th. You can see what has been requested, as well as public comments, here. 

What’s Next in the Comp Plan Process

• Housing Options Study:  Focused on urban growth areas of unincorporated Vancouver, but implements many of the new middle housing/density requirements from recent GMA legislation. 
• Climate Change Plan: Recent legislation requires that considerations for climate change be incorporated into the Comp Plan, including resilience (planning for impacts such as flooding, fires, heat, etc.) as well as reduction of greenhouse gas emissions (transportation planning, reducing trips, etc.). Three advisory groups are being created now. The Environmental Justice Group has been selected (see our Farmer’s Corner article with Trish from Delish Farms on being selected for this group!), and the Community Advisory Group has been selected with an initial meeting of both groups on February 21.
• Types of housing to plan for: new legislation from last session includes the need to plan for housing at various income levels. The county cannot just plan for all single family homes; there has to be housing for people at very low, low, and middle incomes. The Department of Commerce has provided a spreadsheet that shows how much is required in each category given the county’s chosen population growth numbers. 

Issues and Concerns

• Freight Rail Dependent Uses (FRDU): In 2017, at the urging of Portland Vancouver Junction Railroad (PVJR) and Clark County’s Railroad Advisory Board (RRAB), who operates Clark County’s publicly owned short line railroad, legislation was adopted to allow Freight Rail Dependent Uses. This allows heavy industrial development along a short line railroad regardless of the underlying zoning (i.e. agricultural, residential, forest, etc.). This loophole around the GMA threatens significant swaths of important agricultural and natural resource lands, as well as serious impacts to our water. It would also impact communities along the rail line, as there are tons of houses situated as close as 20’ to the line. All things considered, there would be vast and devastating impacts for everyone in Clark County’s health, safety, and well being if the FRDU were to be implemented to the extent that the rail operator and the county want. Visit the FRDU Update portion of the newsletter for the latest on the subject and links to further information.
• Expansion of Urban Growth Areas (UGAs): The City of Vancouver has commented that the Vacant Buildable Lands Model (VBLM) that the county adopted does not incorporate the current density and plans the city has, and therefore is undercounting the current capacity of the city. This would cause the UGA to be unnecessarily expanded. As previously mentioned, against the advice of the Department of Commerce, the county adopted a population projection at the high end of the range, which could also extend the UGAs. 
• Climate Change: As noted above, legislation passed last year requires climate change considerations be included in the plan. As this is new and guidance is just being released, we do not know what this will look like. Close attention to the county and cities efforts on this will be needed.

Further Resources

• 2025 Update | Clark County
• MRSC – Comprehensive Planning
• Washington State Department of Commerce Growth Management

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