Comprehensive Plan Update: March 2025
Overview
Since our last update, the County has selected the alternatives to be included in the Draft Environmental Impact Statement (DEIS) for the Comprehensive Plan Update in accordance with the State Environmental Policy Act (SEPA).
Staff had proposed three alternatives:
- No changes to urban growth boundaries (UGBs) (this is known as the “No Action Alternative” that is required by state law)
- City alternatives 1 with county changes
- City alternatives 2 with county changes.
Sadly, at the behest of the Planning Commission and the building industry, the Clark County Council added a review of all site specific requests (SSRs) and a study of resource lands to this environmental review, meaning they are leaving all options on the table for heavy sprawl, destruction of farmland, and the sacrificing of our forests to mining at this juncture. All of this is in spite of the fact that the last study of this sort took years, and the Comp Plan Update has to be complete and implemented (all code changes made, reviewed by Commerce, etc.) by December 31st of this year. It was already a tight calendar.
Resource Lands Study
The only reason for doing a study of resource lands now is that a study is required in order to de-designate Agricultural, Forest, Mineral Lands, including critical habitat, under state law. This would allow Ridgefield and La Center and Camas to expand their boundaries, swallowing up farmland and forest. FOCC has consistently been supportive of a comprehensive study that would serve a useful purpose in smart planning, but has serious concerns about the quality of the study that can be done in a two-month window of time.
The most critical current issue is the Request for Proposal (RFP) that was issued for the resource lands study. FOCC has urged the Clark County Council to carefully evaluate the responses to the RFP and reject any that would not return useful, quality information. A resource lands study is a great idea, but should be separated from the Comp Plan process so it can be given the time and resources to do a good job.
Site Specific Requests
Community Planning has been reviewing SSR’s for the past three years. Those that adjoin existing urban growth boundaries were already considered options by the county; there are some that were included by the cities, and are within one or more alternatives that have been submitted as part of the Comp Plan Update. The majority of the rest are far from any city so not appropriate to include when considering an expanded UGB. Other SSRs are for Surface Mining Overlays (SMOs) totaling nearly 3,000 acres over existing forest land and critical areas (just think of the devastating impacts to fish, watershed, forest, climate, etc.), which need evaluation of their environmental impacts than can be done within this cycle. So this review, in our view, is unnecessary, creates additional costly staff work for no good reason, and leaves the door open for seriously irresponsible Comp Plan decisions.
Furthermore, many of the site specific requests should have been submitted as part of the regular annual review process. Three years ago the then County Council resolved to suspend the process so that staff could be directed towards Comp Plan Update efforts. This has meant a significant loss of revenue for the county (requests coming in through the annual review process are costly to the applicant) and pushed the requests into the comp plan update cycle.
On top of this, many community members as well as folks from Friends of the Columbia River Gorge have investigated the mining industry’s claim that there is an aggregate depletion crisis in Clark County, and have concluded that there is no rock-based construction materials access shortage in Southwest Washington, as competitively-priced aggregate has been barged into the Portland Metro area for years. However, the Council continues to appear misled by the claim and their obligations under the Growth Management Act (GMA), so much so that County staff had to remind Councilors that the GMA does not require them to establish a 20 year supply of aggregate within Clark County.
Of course, the County should not just take the industry word nor count on investigations from resourceful community members; but rather perform its own study of aggregate availability prior to the consideration of approving any more SMO’s or permitting any new mines given the known harmful impacts of mining.
Furthermore, staff has said that there are existing SMOs which are not currently being used, and most of the mineral rights are owned by an out-of-state mining corporation that does not own the land. Some landowners did not even know that an SSR was submitted for their property by the mining companies!
What’s Next?
The Comp Plan schedule was reviewed with the Planning Commission and the Clark County Council, and can be found here. Again, this is a tight schedule that will require staff and Council to work and meet well into December. If they miss that date, the county will be out of compliance with the GMA, which has cost the county millions in lost grants and loans in the past.
Meanwhile, staff is beginning to review draft chapters of the updated Comp Plan with the Planning Commission – mostly where there are few changes. You can find them here.
The next Clark County Council work session on the DEIS is targeted for April 16th. The Public Comment period is targeted for the full month of June. In the meantime, there will hopefully be a chance to weigh in on the RFP for the resource lands study and the cities are holding meetings on their alternatives.
As always, FOCC will be keeping an eye out and keep our members informed.