16-0915 v3.0/Common Ground/Development Within a Growth Management Area


The Common Ground site is located within a designated Growth Management Area planned in accordance with a Washington State-sanctioned and managed growth management planning process. The site is located within the Lopez Village Urban Growth Area, adopted by the San Juan County Council on July 26, 2005 through Ordinance 9-2005.  The Village Urban Growth boundary was later reduced in size in 2008 through Ordinance 17-2008.

Exception I01-E3 Greenfields Surrounded by Development allows greenfield sites to be developed if they are surrounded on at least 75% of the project perimeter by areas designated for increased density under a jurisdiction-sanctioned Growth Management Plan ratified before December 31, 2007. This Exception does not address situations where the site itself is designated for increased density. Extending the logic of this Exception, it appears appropriate that if a greenfield site is designated for increased density through a growth management planning process, it should be considered compliant with this aspect of the Limits to Growth Imperative. 

Similarly, the Common Ground site is located on USDA NRCS designated prime farmland. In many areas, prime farmlands are a widespread resource; indeed, in parts of the United States, entire cities are built on land that would otherwise be excellent farmland. While unrestricted development of farmland is inappropriate, where growth management systems exist which regulate orderly urban development and protect resource and agricultural areas, it appears appropriate to allow development of sites located on prime farmlands if they are designated for increased density by inclusion within an urban growth boundary.


A site designated for increased density, even when it is a greenfield or prime farmland, meets the intent of Exception I01-E3, when the relevant growth management system meets certain standards. Therefore, the Institute is establishing the following new Exception:  

I01-E16 Greenfields Within Urban Growth Boundaries
Sites in Transects L3-L6 which are located within areas designated for increased density through a regionally-sanctioned and managed urban growth boundary, including those sites containing USDA NRCS designated Prime Farmlands, may be developed under Imperative I-01. A “regionally-sanctioned and managed urban growth boundary” must meet the following characteristics: 

  • Geographically defined to proscribe a contained urban development area;
  • Established, modified or approved by a regional (i.e. county or multijurisdictional metropolitan area authority) level authority and higher;
  • Established based on both human and environmental needs; limiting sprawl and growth based on appropriate infilling and densification strategies;
  • Based on growth management planning that addresses protection and continuity of agriculture and farmland within the overall planning area in all cases where the site in question includes prime farmland.

I01-b Technical Documentation - Evidence that the regionally-sanctioned growth management plan meets the Exception criteria. Examples include a statement from the jurisdiction, highlighted excerpts from the growth management plan, or similar.
I01-c Context Documentation - A map showing the project is within the urban growth boundary.

Post ID 6106

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