Comprehensive Plan Update: Draft Environmental Impact Statement (DEIS) Alternative Hearing Breakdown
What is the Draft Environmental Impact Statement (DEIS) for the Comprehensive Plan Update and what was this hearing about?
Clark County and its cities are updating their comprehensive plans. The land use alternatives proposed for the cities and the county will be evaluated as part of the Environmental Impact Statement for Clark County’s Comp Plan Update, in accordance with the State Environmental Policy Act (SEPA), which requires governments to consider the environmental impacts of their actions before carrying them out.
The December 6th hearing was for the Clark County Council to select different options (called alternatives) for environmental review, which establish the parameters of what actions would ultimately be considered as part of the 2025 Comprehensive Plan Update: from urban growth boundary expansion, to de-designating agricultural land, to adding surface mining overlays over forest land
What’s at stake in the Comp Plan Update:
8,600 acres, or 15% of Clark County’s precious and dwindling agricultural land lost to urban sprawl (as well as the pollution, health problems, loss of food security, and high cost-of-living that comes with that), and over 3,000 acres of prime, carbon-sequestering forest land lost to environmentally devastating surface mining near existing residences.
What FOCC called for:
What we are calling for in the Comp Plan Update is:
1) zero loss of agricultural land to development in the Comp Plan update, as well as essential rural buffer lands that protect those lands;
2) no expansion of the urban growth boundaries (UGBs) to protect land and prevent sprawl; and
3) no loss of forest land to mining.
For this alternative selection hearing, we requested and hoped that certain egregious options offered by the building and mining industries would be taken off the table at this juncture by not including them in any alternative for environmental review. We submitted 7 sets of comments that included maps, articles, and legal analysis addressing the UGA expansion proposals and site specific requests, discussed Clark County’s historic erosion of support for our agricultural community, and laid out our bold new vision for agricultural policy in Clark County. You can read that piece of our commentary, including our fascinating and disturbing breakdown about how County policy has fueled land speculation and its impact on farmers, on our website here.
Summarized, our expressed position to the Council was:
- The Cities and the County have failed to conduct a countywide study of natural resource lands as required by statute and rule;
- Given the time remaining for the County to complete its work on the Comprehensive Plan update, there is insufficient time and County resources to conduct a thorough and comprehensive analysis of agricultural lands of long term commercial significance;
- Therefore, all site specific requests for conversion of designated agricultural or forest lands should be excluded from any review, and
- The County should embrace our rich agricultural resources and adopt a vision for agriculture in Clark County that preserves, protects and enhances our agricultural lands, provides the support for farmers to thrive and maximize productivity of those lands, addresses the urgent need to build climate resilience, protects fish and wildlife, and creates the conditions for the collective well-being of the residents of Clark County.
What happened and what it means:
The Council decisions from this hearing were:
- No re-opening of the Vacant Buildable Lands Model (VBLM) as recommended by the Planning Commission, which would have delayed the County’s submittal of the Comp Plan Update and put more land on the chopping block for residential and commercial development. You can learn more about the VBLM here;
- Council directed staff to do a resource lands study at the behest of the Building Industry Association (BIA), because without this study no agricultural lands or forest lands can be de-designated as a matter of law. We do not believe this can be done without significantly delaying the Comp Plan Update and we question where the funding will come from for this study, given that the residents of this county do not support reckless land use policy. Important note: it is possible that this decision backfires and more land is designated agricultural than is currently (as demonstrated by a study in Pierce County);
- The 3 presented options for alternatives were approved, which are:
- No change to UGAs (known as the “No Action Alternative” required by law)
- Cities’ Alternative 1 plus the County alternative (as some cities offered multiple alternatives);
- Cities Alternative 2 plus the County alternative. For more information on these alternatives, check out the County’s project page here.
4. “Evaluate every site specific request’ was added to the County alternative, which includes 22 surface mining overlay (SMO) requests over forest land that will require time and money for environmental review, even as the Council has chosen not to conduct a county-wide aggregate availability study. Additionally, this is the same Council that recently passed a budget with a $10 million deficit, which could have been prevented through fiscally responsible decision making. So, this appears to be another costly special favor to the mining industry with no consideration for the County’s obligations under the GMA to protect the environment or to act on the climate crisis.
What’s next for the Comp Plan:
The Alliance for Community Engagement (ACE) and the Southwest Washington Equity Coalition (SWEC) asked the Council to defer this hearing’s decisions to the new Council, with ACE asking for more time to come up with a “people’s” alternative. They argued that the Council should honor the Washington Department of Commerce’s intent by allowing the multitude of community-based organizations representing underserved communities who received Commerce grants for public participation in the Comprehensive Plan Update to be able to get up to speed and actually participate. Additionally, ACE cited the County’s own Public Participation Plan. Unfortunately, there was no acknowledgement of this ask during Council discussion. We are hopeful that this disregard for public opinion, especially our underserved communities, will end with the installment of the new Council.
Decisions coming out of this hearing were targeted to what growth scenarios the County will study regarding environmental impacts, and that while we wanted the County to rule out certain proposals, no final decisions have been made regarding the Comprehensive Plan Update.
The 2025 Comprehensive Plan update is due in December 2025, and the decisions the County made at this hearing in favor of the building and mining industries’ proposals will further delay the process. If the update is not submitted by this deadline, the County will be out of compliance with the Growth Management Act and risk, once again, grants and low-cost loans from the State of Washington to the detriment of the people of Clark County.
By about late spring or early summer, we’ll begin to see the formation of the final drafts of the plan. Although your participation has been valuable throughout the process, it’s most crucial for folks to step up their attention over the next 12 months. For those of you who live in Clark County’s cities, we also urge you to check with your local city’s Comp Plan update and get involved.
FOCC will continue to participate and keep the public informed on Clark County’s Comp Plan update. We have a long way to go to develop a plan that meets the needs of residents of Clark County.