For almost 30 years, Futurewise has worked to encourage sustainable natural and built environments by using the policy, advocacy and legal tools available through Washington State’s Growth Management Act (GMA).  We have great appreciation for the GMA framework, however, we also recognize that Washington is a different place than it was in 1990 when the GMA was adopted.  The work of managing growth needs to evolve and adapt over time, particularly as the impacts of climate change and the disparities between different segments of the population rapidly increase.

The Road Map to Washington’s Future is potentially valuable as a vehicle for generating conversations on the relationship between the GMA and climate, health and housing equity – all top Futurewise priorities. However, the lack of a scientifically researched, community-based or quantitative evaluation of how the GMA has impacted residents and the environment over the last three decades leaves a significant gap that stands as a barrier to bold policy action in those priority areas.

 

Background  

On June 30, 2019, after almost three years of work, the Ruckelshaus Center’s Road Map to Washington’s Future delivered to the legislature a “comprehensive and collaborative look at the Growth Management Act.”  Futurewise participated in the development of the Road Map report through the limited avenues that were made available to stakeholders: we submitted written comments; we participated in discussions with the Road Map team; we completed available surveys; and, we invited almost 100 individuals (including members of our staff and board) to participate in stakeholder meetings throughout Washington State.  The purpose of this memo is to outline Futurewise’s perspective on some of the top priority issues discussed in the Road Map.  This is not an exhaustive review of every important issue highlighted in the report.

 

General Observations  

The Road Map is based almost entirely on subjective information from surveyed or interviewed participants.  The lack of a scientifically researched, community-based or quantitative evaluation of how the Growth Management Act has performed in the last 30 years is a significant oversight.  

Futurewise supported the Road Map (the only NGO to sponsor the project) because we were interested in having an objective, fact and science-based evaluation of where the Growth Management Act has succeeded or failed over the last 30 years. Unfortunately, while there are some transformative concepts proposed in the report, the lack of quantitative analysis makes it very difficult to discern how to evaluate those concepts – particularly given that there are at least some attributed statements made in the report that are verifiably false.
Many of the most critical reforms are left to be determined by a series of future convenings, which will take significant funding and time to pull together – in some cases with no discernable path forward given the conflicting perspectives of the assumed stakeholders.

For example, the Report’s highlighting of the use of adaptive management and regionally-based approaches makes a lot of sense, particularly in light of the ways that regions – rather than individual cities or counties – will need to react and plan together for the impacts of climate change.  However, rather than researching and providing recommendations on which regions and which issues are most likely to be impacted in common ways across the state and highlighting the partners and issues that are the highest priorities, the report only speaks broadly of bringing together urban and rural interests for regional summits.  This approach places a heavy burden on state and other agencies to develop the research and data that will support these summits, and pushes the timeline for meetings, deliberations, and action out for years – if not decades – beyond what will be needed to adapt to a rapidly changing climate.  This approach of loosely recommending the convening of interests and stakeholders to determine the next course of action is common across the critical issues discussed in the report.

 

The “Guiding Principles” are a helpful set of guidelines that can be used to guide planning and policy making, but they fail to address the equity.

The center suggests nine “guiding principles” to guide future decisions (page 12). These are good principles that should be considered in planning and policy making. However, equity must be added to these principles to create a future that benefits all current and future Washingtonians.

 

Highest Priorities Moving Forward

Climate Resilience (Section 3.1)

Planning and funding for climate adaptation and resilience is one of the single most important policy areas that GMA should address, and we agree with all of the proposed Transformative Actions in Section 3.1.  We principally support the creation of a “…mechanism to link local and regional planning to the State’s adopted schedule and targets to reduce greenhouse gas emissions” from which many of the other recommended actions would flow. We also support the “key reform” of adding a planning goal to the GMA calling for plans and regulations to be resilient to climate change and natural disasters and to mitigate and adapt to these events.

Missing from the recommended actions on climate is focused attention on the need to develop state-level climate adaptation and resilience strategies that will trickle down to implementation policy areas like GMA.  For example, local land-use decisions that respond to sea-level rise would benefit from a clear and decisive policy directive from the state on retreat and defense strategies in coastal areas.

 

Equity (Section 5.1)

Ensuring that GMA policies and processes lead to equitable outcomes for Washington residents is a top priority for Futurewise, and we welcome the Transformative Actions in Section 5.1 that address developing equity metrics, evaluation tools and performance measures.  Missing from this section of the report are two important aspects of equity-focused work.  The first is a stated commitment to asking communities of color and vulnerable communities what they need from growth management in order to succeed and thrive.  We know first-hand that the data and evaluation tools that are readily available to measure inequities and develop methods for delivering equitable outcomes frequently do not represent the lived experience of vulnerable communities.  Before we seek to collect and analyze data, we need to engage with community and learn what’s important, what’s missing, and what would potentially cause more harm than good.  Secondly, equity is an outcome, but it is also a process.  The future convenings, initiatives and data collecting efforts outlined in the Road Map – and there are many – need an agreed-upon framework for using an equity lens in the process, and one that is developed with community and embedded in each effort.

 

Housing (Page 95)

The report falls short of addressing the GMA Housing Element reforms that would create an equitable and measurable approach to ensuring housing for all current and future residents, and a housing accountability framework for local jurisdictions that is rooted in community.  An equitable approach would include incorporating “affirmatively furthering fair housing” policies, accompanied by housing analyses and policies that require jurisdictions to allow and promote the housing that meets local and regional needs.  Even more importantly, the report does not address the impacts of displacement on vulnerable communities, nor the impacts on the areas that are serving displaced populations.   Understanding and addressing displacement on a local and regional scale is a critical body of work that must be part of the state’s growth management strategies for the foreseeable future.  The impacts of not addressing displacement will be felt through increases in sprawl, in vehicle-miles-traveled, homelessness and public health crises.

 

Government to Government Consultations with Indian Tribes and Nations (Action 2.2)

Futurewise supports government to government consultations with Indian Tribes and Nations on both the Roadmap questions and guidance and on local government plans and plan implementation. We recommend that these consultations lead to a strategic framework that local governments will use when they plan and then implement those plans.

 

Monitoring and Evaluation of Comprehensive and Regional Plans (Page 93)

Futurewise strongly supports monitoring and evaluating comprehensive plans and regional plans to ensure they are delivering on state goals as well as community priorities and needs. Existing data can be used to evaluate the plans along with other information such as the Washington Center for Real Estate Research at the University of Washington reports on housing supply and affordability of cities of 10,000 or more  that plan under the GMA. Plans and development regulations would then be updated based on these evaluations.

 

Top Issues of Concern  

Reformation of the Appeals Process (Action 2.1)

The report is unclear on the underlying goals of reforming the appeals process.  While we believe some reformations of the appeals process may be necessary – particularly those that make the process more transparent and accessible for a broader segment of the population, or those that suggest condensing the process to allow appeals of Growth Management Hearings Board (GMHB) decisions to go directly to the Court of Appeals – overall, the GMHB and subsequent appeals processes have been a dependable and critical element of strengthening GMA and holding jurisdictions accountable for their planning decisions.

 

Changing the Timeline for Comprehensive Plan Updates (Page 100)

An effective plan is a current plan – ten years is just too long to go between updates for most counties and cities.  Washington is a fast-growing state and most counties – 22 of 39 – are growing more quickly than the United States on a percentage basis.  This high rate of growth requires frequent updates to comprehensive plans and development regulations to address the needs of the growing populations. This rapid growth argues for more frequent updates, not less frequent updates for comprehensive plans and development regulations.

Additionally, many counties and cities only do six-year capital facility plans. If the update requirement is changed to once every ten years, there will be an unplanned and unfunded four-year gap in capital facility plans creating problems for providing growth with necessary public facilities and services. For the “lower growing” counties, there could be a five-to seven-year unplanned capital facility gap between the last update and the next update.  Lastly, climate change is happening now, which requires accelerating the requirements for planners to address greenhouse gas emissions, sea level rise, increased wildfires, reduced availability of drinking water, more flooding, and more extreme weather events.  These events call for more frequent updates rather than less frequent updates.

 

Other Comments  

Disaster Preparedness (Action 3.2)

We agree that GMA is a critical place to address disaster preparedness, however, while the report mentions incorporating hazard analyses into planning decisions, it falls short of stating that planning guidelines should be developed for steering population growth away from areas where disasters – including slow moving disasters like climate impacts – are likely to occur.

 

Fix broken tax structures and Increase Planning Funding (Action 1.1)

Washington State has the most regressive tax system in the nation, and we will be unable to fully address any of the issues outlined in the Road Map report without identifying equitable and stable revenue sources.  Full stop.

 

Development of a Statewide Water Plan (Action 4.1)

We support a statewide water plan.  Unfortunately, the Road Map skirts the issue of highest importance as it relates to GMA: building a plan that develops priorities for statewide water use and creating accountability for local land use decisions to act consistent with those policies.

 

Education (Page 93)

We support civic and land-use education for elected officials, K-12 and community-based programs.  Missing from the report is education specifically targeted at Planning Commissioners who are often unelected and yet have a significant impact on land-use decisions at the local level.

 

Economic Development (Action 6.1)

We support investment in economic development opportunities for natural resource economies, including agriculture.  Missing from the economic development section of the report is a focus on quantifying and educating elected officials and other decision makers on the unsustainable costs of sprawling development.  A successful economic development program needs to address equity in all forms.

 

Human Health and Well-Being (Page 95)

We support the adding a Planning Goal to the GMA on Heath and Well-Being, particularly if the objective is to link development patterns to health outcomes – both historic and future – and to create accountability mechanisms for planning decisions.

 

Transportation (Page 98)

We support all of the transportation reforms, however, we remain concerned that integrating state highways into the GMA transportation concurrency system could lead to a “tail wagging the dog” situation whereby local jurisdictions will be able to force the hand of the state to invest in highway improvements that serve ill-planned developments.  A better approach is for local plans to focus growth where it can be supported by a well-planned and adequately funded local, regional, and state multimodal transportation system and to consider the impacts of planning decisions on local, regional, and state transportation systems.

 

Integrating School District Planning (page 101)

We strongly support increasing coordination between counties, cities and school districts.  For too long, school districts have gained the upper hand on forcing land-use decisions that serve the district (particularly siting schools outside of the urban growth boundary) but lead to unplanned and unsustainable development in the surrounding areas.