Your Future, Your Voice: Call to Action for the Final Clark County Council Comp Plan Update Hearing on Thursday, October 1st at 4pm
Help us advocate for a sustainable future balancing growth, the preservation of prime agricultural land, and meaningful climate action in Clark County.
What’s at stake?
The loss of hundreds of acres of prime agricultural lands and meaningful climate action in Clark County’s Comprehensive Plan Update.
Background
Clark County is revising its Comprehensive Growth Management Plan, a 20-year guide for managing growth and development with respect to the natural environment and available resources. In addition, the cities of Vancouver, Battle Ground, Camas, La Center, Ridgefield, Washougal, Woodland and Yacolt are also updating their comprehensive plans.
Three land use alternatives were studied for those cities and the county in a draft environmental impact statement (EIS). In addition, the Clark County Council majority ordered and the county carried out an Agricultural Lands Study. The county then selected a Preferred Alternative that was studied for the Final Environmental Impact Statement (FEIS), and the Washington Department of Commerce issued a letter to Clark County flagging compliance issues with its draft Comp Plan.
What’s happening?
If the Clark County Council selects any alternative that allows for urban growth area (UGA) expansions, especially those that include the de-designation of agricultural land, they will be permitting the permanent destruction of hundreds of acres of our prime farmlands in violation of the Growth Management Act (GMA). According to the county’s own modeling, and the Department of Commerce, all of our current urban areas have the capacity to accommodate all expected growth over the next 20 year horizon—meaning expansion of our current boundaries and paving over farmland for expensive, sprawling and emissions-inducing development is unnecessary and would prove harmful to our community and our climate goals. Therefore, an alternative with no urban growth area expansions is the only responsible choice.
The purpose of the hearing on October 1, 2026 will be to take public testimony on the Comp Plan Update. The Clark County Council will then adopt final revisions to the Comp Plan, most notably changes to the comprehensive and zoning plan map, as well as updates to policies and text in the comprehensive plan document and changes to the County’s development code.
Call to action
We need you to help us call for no UGA expansions, no de-designation of agricultural land, and meaningful climate action in Clark County’s Comp Plan update!
Testify virtually, in person, or over the phone for up to 3 minutes at the hearing on Thursday, October 1st, starting at 4pm, or send in written public comment.
Attendees can join in person in the sixth-floor hearing room of the Public Service Center, 1300 Franklin St., or virtually via Webex. Meeting information
Comment guide
Main Statements
1) The Comp Plan Update should reflect the fact that all forecasted population and employment growth can be accommodated within current UGAs, meaning there is no legal justification to expand UGAs. This fact has recently been reiterated in the county’s own Final Environmental Impact Statement (FEIS) document, which states that, “Given the planning assumptions for growth rate and jobs/acre, the Preferred Alternative exceeds the land capacity needed to accommodate the housing and job growth projected for the next 20 years.”
2) The WA Department of Commerce recently made it clear that expanding UGA’s and de-designating agricultural land is not justified. The DOC noted that:
- “In our review, we did not find sufficient analysis supporting the proposed expansion of various urban growth areas outside of Vancouver to meet future population and growth targets…The combined urban growth area may not exceed the areas necessary to accommodate the growth management planning projections…From our understanding of the county’s Vacant Buildable Lands Model (2023), it appears the current urban growth area boundaries are sufficient for the projected population increases expected within Clark County (HAPT compared to Alternative 1).”
- In our review we did not find documentation indicating how the County expects urban levels of service will be provided to the expanded areas over the 20-year planning horizon.
- “In our review of the draft comprehensive plan and agricultural lands study, we did not find any discussion clearly demonstrating that the lands proposed for de-designation no longer meet the designation criteria.”
- “…De-designations of agricultural lands based solely or primarily on proximity to urban growth that otherwise meet the definition of agricultural lands, historically have not been found to be defensible by the Growth Management Hearings Board.”
- “TDR programs are not intended to be used as a mechanism to expand UGA Boundaries. When designated resource lands are already within a UGA, TDR programs provide a valuable mechanism to ensure those lands do not face development pressure.”
3) The hundreds of acres that Ridgefield, La Center, and Camas are requesting to pave over forever are designated prime agricultural lands and farmlands of statewide importance. Additionally, Battle Ground’s proposed expansion would pave over hundreds of acres of ag-quality rural lands identified in the Agricultural Lands Study. These lands represent an invaluable community resource as we consider the need to feed our growing population, local food security and climate change resiliency, and the future of the farming industry and jobs in the agricultural sector as a whole.
4) Clark County must match the City of Vancouver’s greenhouse gas Emissions Goals, as the recommendations made by the Clark County Climate Community Advisory Group (CAG) will be rendered toothless without an explicit greenhouse gas (GHG) reduction goal. Clark County, as well as the world, are far behind in acting meaningfully to address the climate emergency at the level of urgency and scale articulated by global scientific consensus.
5) Urbanization begets urbanization. To use encroaching development as a justification to de-designate land, will continue to chip away at agricultural land, which goes against the conservation purpose of the agricultural land designations. This de-designation risk has been articulated in Washington state law, and was noted by Clark County’s own lawyer as “the absolute definition of urban sprawl”.
Additional points:
- Agricultural land in Clark County has been eroded by the county’s actions over the decades since the passage of the original Comprehensive Plan. The de-designation of any agricultural land, especially for unnecessary UGA expansions, would continue to undermine the capability of our agricultural sector to rise to its highest levels of productivity, which would also undermine our communities’ access to food and our successful adaptation to the climate emergency. Just as our residents need housing and jobs, they also need food and clean water.
- The County is required by law to have a sufficient supply of agricultural lands to sustain a local agricultural economy.
- The County should honor the recommendations of the Agricultural Advisory Commission, which voted to maintain all existing agricultural designations and requested a moratorium on upzoning of lands that meet the legal criteria for agricultural designation.
- The County should consider the needs of the entire county and our collective future, not reward cities for failing to propose alternatives for their cities that do not include paving over prime farmland.
Tips for an effective public comment
- Keep your commentary relevant, respectful, and succinct.
- Be sure to indicate where in the county you live.
- If you have time, try and paraphrase the points we’ve provided rather than copy/pasting.
- Make it personal: Share your feelings, concerns, and how you and your community will be impacted by this Comp Plan decision.