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Report — Department of Commerce, Growth Management Emphasis Areas and Research Priorities (2023)

Summary

This September 20, 2023 report to the Legislature from the Local Government Division of the Department of Commerce, titled Growth Management Emphasis Areas and Research Priorities Report, was prepared pursuant to Section 128(129) of the 2022 Supplemental Operating Budget, Laws of 2022, Chapter 297. It states that the consultative approach produced four emphasis areas. Ten priorities emerged for the 2023-25 growth management research agenda, including assessing the effect of middle housing implementation on water and related infrastructure and inventorying rural lands. Commerce solicited feedback from legislators, local governments, tribes, state agencies, non-profit organizations, and institutions of higher education.

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“Report — Department of Commerce, Growth Management Emphasis Areas and Research Priorities (2023).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-commercereports-gms-research-priority-0104625d-8910-4ecf-9921-70d-cee4241cb4/, SHA-256 3c11274d7212b8d7f054dfadcc4f292f5c0b6b849773bb8e5aa5a914229ab3d1.

Full text

Pursuant to Section 128(129) of the 2022 Supplemental Operating
Budget, Laws of 2022, Chapter 297 (SB 5693)




                                             September 20, 2023
       LOCAL GOVERNMENT DIVISION
       GROWTH MANAGEMENT
       SERIVCES                              Report to the Legislature

                                             Director Mike Fong
v3.4
 Acknowledgments
 Washington State Department of Commerce
 Dave Andersen, Managing Director,
 Growth Management Services

 Paul Johnson, Operations Support Management,
 Growth Management Services

 Will Simpson, Senior Policy Analyst,
 Growth Management Services

 Jacob Stillwell, Senior Policy Analyst,
 Growth Management Services

 Buck Lucas, Policy and Communications Manager,
 Local Government Division

 1011 Plum St. SE
 P.O. Box 42525
 Olympia, WA 98504-2525

 www.commerce.wa.gov

 For people with disabilities, this report is available on
 request in other formats. To submit a request, please
 call 360-725-4000 (TTY 360-586-0772)




      GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT   2
2.0
Table of Contents
Executive summary...................................................................................................................................... 4

Overview ..................................................................................................................................................... 5

Table 1: Priority research agenda ................................................................................................................. 7

Next steps ................................................................................................................................................... 7

Future Grant Funding ................................................................................................................................... 8

Appendix A: Emphasis areas and research priorities..................................................................................... 9




  GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                                                                           3
Executive summary
The Legislature directed the Department of Commerce (Commerce) to develop a process to consult with
stakeholders and complete a report outlining growth management emphasis areas and research priorities. The
goal is to identify solutions and opportunities related to both ongoing and emerging issues in the state's
growth planning framework.

Specifically, Chapter 297, Laws of 2022 (the 2022 Supplemental State Operating Budget) directs Commerce to:

    (129) $10,000,000 of the general fund – state appropriation for fiscal year 2023 is provided solely for the department
    for grants for updating and implementing comprehensive plans and development regulations in order to implement
    the requirements of the growth management act.

    (c) Up to $500,000 per biennium may be allocated toward growth management policy research and development or
    to assess the ongoing effectiveness of existing growth management policy.

    (d) The department must develop a process for consulting with local governments, affected stakeholders, and the
    legislature to establish emphasis areas for competitive grant distribution and for research priorities. The department
    must complete a report on emphasis areas and research priorities by June 30, 2023.

Commerce solicited feedback from legislators, local governments, tribes, state agencies, non-profit
organizations, local government and planning associations, consultants, and institutions of higher education to
develop the emphasis areas and research priority. Subject to appropriation, Commerce will continue this
collaborative process each biennia as a key component of the comprehensive plan periodic update cycle.

Key findings
The consultative approach to develop a growth management research agenda produced four emphasis areas:

    Impacts on municipal services caused by population and employment growth
    Cross-jurisdictional coordination on long-term local planning objectives
    Statewide inventory of local land use issues and data for uniform analysis, regulatory streamlining, and/or
    development of best practices guidance
    Inventory of best practices of existing programs to use as guidance for other jurisdictions

Ten priorities emerged from these four emphasis areas for the 2023-25 growth management research agenda.
These priorities closely follow emerging issues from the 2023 legislative session and collaborator feedback.

The priorities are:

    Assessing the effect of middle housing implementation on the need for water and related infrastructure
    Forecasting the effect of expanded middle housing on housing production and assessing code provisions
    that are most impactful on the production of middle housing
    Identifying best practices to involve underrepresented communities in the planning process
    Assessing the fiscal consequences of alternative growth strategies in Washington
    Inventorying Washington resource lands and assessment of land use policies to support natural resource
    based industries
    Inventorying rural lands and assessment of best practices in rural lands planning
    Assessing the role of urban tree canopy in mitigating urban heat island effects and best practices in
    increasing tree canopy coverage in underserved urban areas
    Identifying best practices in tribal/local coordination
    Identifying best practices in efficient local permit review

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   Identifying best practice for improving coordination between local governments and special purpose
   districts to ensure provision of adequate public facilities and ensure timely provision of urban services

As Commerce completes an element of the research agenda, we will publish it on a soon-to-be-created
webpage. It is unlikely that Commerce could complete the entire priority research agenda in the 2023-25
biennium. Next steps include assessing what research Commerce can complete within the agency's work
program and identifying a means of completing the research.


Overview
During the 2022 legislative session, the Washington State Legislature provided funding to study ongoing and
emerging issues in the state's growth planning framework. Through a collaborative approach, Commerce
developed areas of emphasis and priorities for research. This report details that approach and outlines the
priorities for research in the 2023-25 biennium.

For the 2023-25 biennium, the Legislature made additional state resources available for communities to
address significant state policy issues regarding middle housing, climate and resilience, and local permit
system modernization. In addition, there are no periodic update resources available for secondary competitive
grant programs in the 2023-25 biennium. For these reasons, there are no current emphasis areas for
competitive grants, and this report will focus on advancing a collaborative research agenda.

Study approach
Beginning in December 2022, the Growth Management Services (GMS) team developed a process for outreach
to local governments and other affected stakeholders to inform them about the research opportunities and to
solicit feedback. The GMS team used the problem statement method, whereby we asked respondents to
identify a problem, describe the need for research, and explain how the research will address the problem.

The study approach involved three steps that GMS will repeat near the close of each biennium:

1) Solicit problem statements from a broad arrangement of stakeholders

2) Organize problem statements and suggested solutions into emphasis areas

3) Seek feedback to prioritize emphasis areas from members of the Legislature that represent local
   government legislative committees in both chambers, and from members of the Collaborative Roadmap
   Task Force

Solicit problem statements
The GMS team distributed a request to submit a problem statement via email in the first week of March 2023,
with a response deadline of April 14. There have been conversations with legislators and local elected officials
about issues of concern. Rather than expecting them to submit a problem statement, Commerce drafted a
number of problem statements to reflect conversations with legislators and local elected officials about issues
of concern to them. Appendix A contains all problem statements. The following recipients received a problem
statement survey request:

   The planning contact for all 323 Washington towns, cities and counties
   State agencies within the Inter-governmental Working Group, which includes:

      Department of Archaeology and Historic Preservation

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      Department of Commerce
      Department of Ecology
      Department of Fish and Wildlife
      Department of Health
      Department of Natural Resources
      Department of Transportation
      Office of the Governor
      Puget Sound Regional Council
      Washington Geological Survey
      Washington State Conservation Commission

   Eastern Washington University, Urban and Regional Planning Department
   The University of Washinghton, Urban Design and Planning Department
   Growth Management Collaborative Roadmap Task Force, which includes:

      American Planning Association
      Association of Washington Cities
      Building Industry Association of Washington
      CAFÉ
      Front and Centered
      Futurewise
      Puyallup Tribe of Indians
      Washington Association of Water and Sewer Districts
      Washington Realtors
      Washington State Association of Counties
      Washington State Department of Commerce
      Washington State Department of Ecology

Organize problem statements into emphasis areas
The GMS team collected and organized problem statement submissions into four emphasis areas.

   1. Impacts on municipal services caused by population and employment growth

   2. Cross-jurisdictional coordination on long-term local planning objectives

   3. Statewide inventory of local land use issues and data for uniform analysis, regulatory streamlining,
      and/or development of best practices guidance

   4. Inventory of best practices of existing programs to use as guidance for other jurisdictions

Seek feedback to prioritize research
The GMS team requested that members of the Legislature and the Collaborative Road Map Task Force
prioritize the problem statements, as organized into one of the four emphasis areas. Table 1 outlines the
respective topics and emphasis areas for the priority research agenda. The priority research agenda pulls from
three of the four emphasis areas, except cross-jurisdictional coordination on long-term planning objectives.




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Table 1: Priority research agenda
Emphasis area                                                    Research topic

Impacts on municipal services caused by population and           Assessing the effect of middle housing implementation on the
employment growth                                                need for water and related infrastructure

                                                                 Forecasting the effect of expanded middle housing on housing
                                                                 production and assessment of code provisions most impactful
                                                                 on the production of middle housing

                                                                 Identifying best practices in the involvement of underrepresented
                                                                 communities in the planning process
Statewide inventory of local land use issues and data for uniform
analysis, regulatory streamlining, and/or development of best     Assessing the fiscal consequences of alternative growth
practices guidance                                                strategies in Washington

                                                                 Inventorying Washington resource lands and assessment of land
                                                                 use policies to support natural resource based industries

                                                                 Inventorying rural lands and assessment of best practices in rural
                                                                 lands planning

                                                                 Identifying best practices in efficient local permit review

                                                                 Assessing the role of urban tree canopy in mitigating urban heat
                                                                 island effects and best practices in increasing tree canopy
                                                                 coverage in underserved urban areas
Inventory of best practices of existing programs to use as
guidance for other jurisdictions                                 Identifying best practices in tribal/local coordination

                                                                 Identifying best practices for improving coordination between
                                                                 local governments and special purpose districts to ensure
                                                                 provision of adequate public facilities and ensure timely provision
                                                                 of urban services



For the upcoming fiscal year (FY 2024), Commerce is prioritizing research that can support the implementation
of recent legislation. Submitted problem statements resonate with this approach and the focus on middle
housing, intergovernmental and tribal collaboration in the planning process, and rural lands planning.
Commerce will seek additional feedback on an ongoing basis as the agency identifies additional problem
statements and commences research.


Next steps
Commerce intends to begin the priority research in the 2023-25 biennium, although it is uncertain how much of
the $500,000 in budget authority would be allocated for this purpose. Commerce will explore the allocation of
funding based on whether we can complete the research internally, or if a contracted pathway is necessary.
Moreover, no funding from the 2021-23 biennium was allocated for research, as the full $10 million
appropriation is required for community updates and implementation of comprehensive plans and
development regulations for the next round of Growth Management Act periodic updates.

In fall 2023, Commerce will create a webpage that hosts growth management research, and that can engage
and inform key partners and the public about this ongoing effort. The webpage will also serve as the
depository for this report, the current biennial priority research agenda, and all updates to the research agenda
for each period funds are available for growth management planning research. The GMS team will repeat this
process near the end of each biennium to maintain connectivity to community planning issues and to research
solutions for them.

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Commerce anticipates using this process to maintain the research priorities on an ongoing basis. As such,
Commerce will solicit problem statements and update the research priorities list on a biennial basis to adjust
priorities and to seek ongoing input on research needs.


Future Grant Funding
In future biennia, Commerce will also seek stakeholder feedback on priorities for future grant programs funded
out of the $10 million periodic update grant fund. All of this funding is committed to the periodic update grants
for this biennia, but as funds become available, Commerce will seek input on funding priorities for any
unprogrammed funding.




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Appendix A: Emphasis areas and research priorities
The GMS Team compiled four themes, or emphasis areas, based on the problem statements and
accompanying solution statements submitted by respondents to the March 2023 survey. These responses are
unedited and presented in their entirety.

Emphasis area one and impacts on municipal services caused by
population and employment growth.
Topic: Why are police not considered for impact fees?
Commenter:
Travis Goddard, City of Woodland, goddardt@ci.woodland.wa.us

Problem statement:
Why does GMA allow for Fire Impact Fees but not Police Impact Fees? Logic tells you that if development and
population growth will both lead to increased demand for Fire Protection, then they should also lead to
increased demand for police protection. New police positions incur costs for vehicles, weapons, recruitment,
qualifications and ongoing training, and other miscellaneous equipment. Those are all one-time costs that
should be subject to impact fees. New fire and medical service demands mean new capital costs like fire
stations and new vehicles/equipment, just like they do for police. However, because communities build
multiple fire stations but don't tend to build multiple police stations, it doesn't make sense that police aren't
treated the same. If the problem is a lack of data for calculating impact fees, then a system needs to be
developed.

Solution statement:
Calculating one-time expenses associated with creating positions and hiring police officers will allow for
development related costs to be passed on to whomever drives that demand.

Topic: What impact has the growth management act had to stop urban sprawl?
Commenter:
Brian Shay, City of Hoquiam, bshay@cityofhoquiam.com

Problem statement:
What impact has the growth management act had to stop urban sprawl? Take a look around Lacey or
Tumwater where they are subject to GMA. There has been vast urban sprawl into the undeveloped rural areas.
My point is that the purpose for GMA has not been effective and might as well be repealed.

The legislature has effectively eliminated single housing zones. How will this impact the quality and character
of neighborhoods? What impact will mandating 4 plexes and duplexes have on parking problems or any
potential public nuisances in neighborhoods? What impact will this have on existing public facilities like parks?
How will these mandatory housing standards impact private developments such as gated communities? Will
there be any options for people who want to live in a single family neighborhood?

Solution statement:
How can the state redirect new housing and provide true incentives to build housing in distressed communities
like Grays Harbor where there are plenty of vacant infill lots as opposed to the continued building along the I-5
corridor. If the state wants to solve the housing crisis they need to incentivize economic development in rural

 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                               9
areas like Grays Harbor where they have water and sewer infrastructure in place to serve double the current
population after all of the economic decline since the 1970s.

Topic: More research on the relationship between housing affordability and density.
Commenter:
David Killingstad, Snohomish County, david.killingstad@snoco.org

Problem statement:
Recent OFM population projections show continued significant increases in the state population over the next
twenty years. In addition, the state is currently facing a severe housing shortage. As required by HB 1220,
Commerce has provided cities with their projected allocation of housing needs by income band. These
allocations show large needs at lower income levels, which are best addressed by significant infill housing.
More research is needed to understand the degree to which density achieves housing affordability.

Solution statement:
Quantitative analysis on the role density plays in achieving housing affordability will assist jurisdictions
implementing HB 1220.

Topic: Implementation of Urban Tree Canopy
Commenter:
David Killingstad, Snohomish County, david.killingstad@snoco.org

Problem statement:
Climate Change, the Evergreen Communities Act, low impact development and public health all point to both
the need for and benefits of urban tree canopy. The GMA, HB 1220 and regional plans such as Vision 2050 all
mandate growth accommodation within UGAs. More research is needed to determine how to achieve both
objectives without resorting UGA expansions or exclusively building multi-story buildings.

Solution statement:
Identify tangible solutions local jurisdictions can implement.

Topic: How are counties obligated and/or supposed to plan for growth and prepare
for the OFM growth projections when our UGAs cannot support development due to
the lack of water and/or water rights?
Commenter:
Christopher Young, Grant County, cyoung@grantcountywa.gov

Problem statement:
Moses Lake UGA is slated for 62% of Grant County's growth and they do not have any water to serve the UGA.
How are counties supposed to plan and prepare for development when there is no water and/or the ability to
obtain water rights? Grant County has approximately 1,000 homes that have proposed development within the
Moses Lake UGA and none are able to be approved due to lack of water. The county cannot plan due to not
having any water right and/or ability for a water bank since Grant County is not served by river watershed. Is
DOC aware of this dilemma in the state and are they prepared to address it?




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Solution statement:
Grant County will be going through a major comprehensive plan amendment, to be completed by June 2026,
and we need direction on how we will be subject to meeting our projected growth numbers within our 15 UGAs.
It is the same situation in all of the UGAs - no water, so how are we supposed to be GMA compliant?

Topic: Have GMA policies and rules resulted in ongoing consideration of cumulative
impacts in county comprehensive and development plans; have SEPA procedures
acted as a safety net in upholding this foundational component of the GMA.
Commenter:
Tracey Morgan, Responsible Growth * NE Washington, tmorgan.rgnew@gmail.com

Problem statement:
Counties design comprehensive plans and development regulations to set procedures for successfully
meeting the directives of the Growth Management Act. One of the underlying principles of the GMA is to
measure and moderate the cumulative impacts of growth so that, while any single action will not have
deleterious effects on a county or area, numerous actions can eventually result in great damage. One such
example is that WRIA 62 watershed I (Little Spokane) This water source is already in peril and caps have been
placed on usage. However county comprehensive plans do not incorporate the water carrying capacity nor
what the maximum developable land is when changing zones/FLU. A study on how the maximum planned
growth would compare to the actual water constraints would show policy does not require consideration of the
cumulative impact of increased housing basin wide. For example if all the available water is in use, how can
the county 'plan' to increase single family homes in rural areas? A broad variety of environmental features are
experiencing cumulative 'erosion' through failure to set the actual constraints or carrying capacity prior to
changes in zoning or future land use. We propose to take Stevens, Pend Oreille, and Ferry County as case study
to show plans and regulations do not use cumulative effects as a basis of those procedures, in violation of the
GMA and SEPA.

Solution statement:
Showing that the current methods for projecting and planning growth may be insufficient to meet GMA
standards, policy could then be developed to require elements such as carrying capacity, maximum stream
bank development for a given water body, maximum acres in housing, or other ceilings so as to not exceed the
capacity of the resource to survive too much growth and development. Water, air, current infrastructure,
services, and presence of known species versus area or quantity could be used to define thresholds for not
impacting those resources. Simple GIS exercises would show the limits in acres or number of homes and
would be very affordable if the methods were well outlined for these counties.

Emphasis area two and cross-jurisdictional coordination on long-
term local planning objectives.
Topic: How does the Growth Management Act inhibit the governance Tribes have
over Federal Indian Reservations and land use decisions.
Commenter:
Andrew Strobel, Puyallup Tribe of Indians, Andrew.Strobel@puyalluptribe-nsn.gov




 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                          11
Problem statement:
Federally Recognized Indian Tribes are enshrined with unique rights and authorities over their lands. The
Federal Government signed Treaties with local Tribes that both established Indian Reservations and
guaranteed benefits and access to resources. While Indian Reservations and Tribal jurisdiction are largely
grounded in federal legislation and judicial precedent, State and local land use policy can frequently interfere
with management of Tribal lands. As such, the Growth Management Act (GMA) has historically omitted any
nexus between Tribal lands and local land use as part of its framework of managing rural and urban growth.
This framework can frequently be incongruous with the unique development patterns of Indian Reservations,
which are neither perfectly urban nor rural in nature. Tribes are incredibly dependent on the development of
local utilities, transportation, transit, and other levels of service to their lands. Many reservations in Washington
State do not have the capacity to provide these services and must partner with local jurisdictions in order to
provide them. However, GMA largely recognizes the relationship of providing these services only between
cities and counties but very limitedly towards Tribes if at all. The ability for Tribes to be named jurisdictions in
annexation proceedings, participate in right-of-way transfers, and expand utilities working with local PUDs and
municipal governments is severely dampened by the absence of Tribes in GMA.

Solution statement:
Research in this area will promote suggestions to modify GMA so that Tribes and local jurisdictions may more
appropriately jointly plan around Indian Reservations without fear of legal actions due to the ambiguity in State
law.

Topic: Impact of partially planning jurisdictions on fully planning jurisdictions.
Transfer of impacts. Lack of concurrency standards.
Commenter:
Travis Goddard, City of Woodland, goddardt@ci.woodland.wa.us, 360-218-9147

Problem statement:
As a fully planning jurisdiction within a partially planning county, county development has a direct impact on
our services without any requirement for concurrency. For example, I-5 Exit 21 is within the city and
approximately 50% of the traffic comes from county-based development. So, while the city is required to
develop public facilities concurrent with development, levels of service may be pushed into failure by forces
outside of our control because they do not have concurrency rules. School Districts also tend to have students
from both incorporated and unincorporated areas. Rural development may be subsidized by urban
development based on political boundaries. There should be mitigation tool that requires development in
partially planning jurisdictions so that fully planning jurisdictions can be made whole subsidizing development.

Solution statement:
Financial impacts from partially planning jurisdictions can be measured and tools for reimbursing for that cost
should be considered.




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Topic: This topic stems from a recommendation of the Collaborative Roadmap, Phase
II project: While the GMA requires cities and counties to coordinate with special
district on the development of utilities and capital facilities plans (RCW
36.70A.070(3) and (4), WAC 365-196-415 and WAC 365-196-420), statutes
governing special districts are not always designed to link with planning requirements
cities and counties perform.
Commenter:
Clay White, LDC Inc., cwhite@ldccorp.com

Problem statement:
While the GMA requires cities and counties to coordinate with special district on the development of utilities
and capital facilities plans (RCW 36.70A.070(3) and (4), WAC 365-196-415 and WAC 365-196-420), statutes
governing special districts are not always designed to link with planning requirements cities and counties
perform. This is currently one of the largest gaps in our growth policy framework and one of the most
important areas where progress must be made. There is often a lack of communication and coordination as
long-range planning occurs and when code changes are considered by a city or county that could impact a
special purpose district. As an example, there is a strong effort to encourage redevelopment in our urban
areas. However, sufficient coordination between cities and existing utility districts may not be occurring to
ensure that services can support the planned-for growth when it is expected to occur. This communication and
planning gap does not emerge from a lack of desire to plan, but rather from a recognition that:

      Many jurisdictions and special purpose districts have limited staffing/resources to coordinate to a
       greater degree; and
      In most cases, statutes guiding special purpose districts are not synced with GMA requirements for
       planning; and
      Statutes are not synced so there are common goals regarding planning for utilities and capital facilities
       as growth occurs; and
      In many cases, there are many special purpose districts who provide utility and capital facilities within a
       particular city or county.

Solution statement:
This is the statement from the Roadmap Task Force: Convene a collaborative process(es) with, at a minimum,
representatives of state agencies, cities, counties, builders, special districts, Tribal governments, and planning
and environmental organizations that have experience with local and/or special district planning processes.
The process shall focus on increasing planning between jurisdictions and special districts to better implement
utility and capital facility planning requirements under the Growth Management Act. The process shall also
focus on methods to help ensure that special districts can more fully incorporate local comprehensive plans
as they plan for the utilities and capital facilities necessary to accommodate growth during the planning
period. In addition, the process shall focus on identifying legislative changes that will increase coordination
during permitting processes that impact special districts while limiting new planning requirements.




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Emphasis area three and statewide inventory of local land use
issues and data for uniform analysis, regulatory streamlining, and/or
development of best practices guidance.
Topic: Creation of a single unified program to address nonpoint source pollution
linking multi-agency programs to address policy, compliance and monitoring efforts
for stormwater management.
Commenter:
Hugo Flores, Washington State Department of Natural Resources, hugo.flores@dnr.wa.gov

Problem statement:
The Puget Sound is an inland sea that is impacted by land uses within the jurisdiction of the SMA and GMA.
Unfortunately, nonpoint source pollution is not being addressed in a unified manner. The state has many
programs addressing some of the issues of nonpoint source pollution, but the lack of coordination among
state agencies creates a significant waterlog in the permitting process and water quality compliance.

Solution statement:
1) Develop an inventory of all the different nonpoint source pollution programs among state agencies to map
   statutory, compliance, and timeline requirements.

2) Analyze and identify gaps and regulatory overlap and oversight of the different programs.

3) Convey a state agency working group to explore potential programs' alignment and develop coordination
   activities, and if necessary, draft policy and compliance guidance.

4) Prepare a report (findings) for legislative representatives interested in this topic.

Topic: Analysis of geologically hazardous area code provisions by local jurisdictions
in Washington State under GMA.
Commenter:
Jessica Czajkowski, Washington Geological Survey, jessica.czajkowski@dnr.wa.gov

Problem statement:
Existing geologic hazard code provisions vary greatly across local jurisdictions in Washington. While this
allows jurisdictions the benefit of developing unique solutions specific to their hazards, it also reveals gaps in
information availability, capacity, and support for effective decision-making. According to the recent
Washington State Department of Commerce Evaluation of Planning Costs report, local jurisdictions have a
strongly identified need for additional technical support from subject matter experts, regardless of their size or
geography. Currently, Washington Geological Survey (WGS) is engaged in a collaborative research project with
the Department of Health (DOH) inventorying critical aquifer recharge areas (CARAs) and geologically
hazardous areas code provisions. WGS proposes to use this collaborative inventory as the basis for
developing criteria that define strong geologic hazard code provisions, evaluating existing code against these
criteria, analyzing and summarizing the broad results, and communicating these results to the Department of
Commerce and the greater planning community.



 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                              14
Solution statement:
A statewide analysis of existing geologic hazard code provisions will provide a baseline of gaps, functions and
values, and identify areas where additional support may be needed. Subsequent efforts can emerge from this
work such as the development of best practices guides for geologic hazard code development, and more
informed feedback during comprehensive plan reviews by WGS to local jurisdictions. Recommendations for
more effective code provisions and mapping information can help jurisdictions address gaps, improve sharing
of information, expand understanding and awareness, and provide tools for decision-making.

Topic: Subject matter expert analysis of Critical Aquifer Recharge Area code
provisions of local jurisdictions in Washington State under GMA.
Commenter:
Nikki Guillot, Washington State Department of Health, nikki.guillot@doh.wa.gov

Problem statement:
Existing Critical Aquifer Recharge Area code provisions vary greatly across local jurisdictions in Washington.
While this allows jurisdictions the benefit of developing unique solutions specific to their geology, it also
reveals gaps in information availability, capacity, and support for effective decision-making. According to the
recent Washington State Department of Commerce Evaluation of Planning Costs report, local jurisdictions
have a strongly identified need for additional technical support from subject matter experts, regardless of their
size or geography. Currently, Washington Geological Survey (WGS) is engaged in a collaborative research
project with the Department of Health (DOH) inventorying critical aquifer recharge areas (CARAs) and
geologically hazardous areas code provisions. DOH proposes to use this collaborative inventory as the basis
for developing criteria that define strong code provisions, evaluating existing code against these criteria,
analyzing and summarizing the broad results, and communicating these results to the Department of
Commerce and the greater planning community.

Solution statement:
A statewide analysis of existing Critical Aquifer Recharge Area code provisions will provide a baseline of gaps,
functions and values, and identify areas where additional support may be needed. Subsequent efforts can
emerge from this work such as the development of best practices guides for code development, and more
informed feedback during comprehensive plan reviews by DOH to local jurisdictions. Recommendations for
more effective code provisions and mapping information can help jurisdictions address gaps, improve sharing
of information, expand understanding and awareness, and provide tools for decision-making.

Topic: What regulations are effective in protecting and restoring ecologically
important lands and where and how are local land use regulations are effective at
preserving ecologically important lands? What are the root barriers in place that keep
local jurisdictions from effectively protecting ecologically important lands?
Commenter:
Rebecca Brown, Washington State Department of Natural Resources, rebecca.brown@dnr.wa.gov

Problem statement:
There are a variety of regulations that exist in Washington State that aim to protect and restore ecologically
important lands. These include Growth Management Act (both comprehensive plans and Voluntary
Stewardship Program), Critical Area Ordinances, Shoreline Master Programs, among others. The problem this
research topics will address is the lack of data on which programs are effective at protecting ecologically

 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                             15
important lands. There is a lack of data that can provide information on which of these programs are most
effective. Which programs are less effective and at what stage are they not effective? Is it the regulation itself?
Is the implementation of the regulation, or is it compliance, or some combination of all three? The barriers to
improving these regulations depend on what stage of the regulation is ineffective.

Solution statement:
Investigating which regulations are most effective at protecting and restoring ecologically important lands can
assist policy-makers, jurisdictions/municipalities, practitioners, and a variety of state and non-state
organizations to better implement land protection and restoration strategies including targeting certain areas
for restoration, protection and/or acquisition through other means (such as incentive programs) where
regulatory programs are failing. It will help to determine why regulatory programs may be lacking whether by
lack of enforcement, funding, geographic specificity or any number of reasons. The research will help
regulators prioritize improvements based on the ineffective stage, such as improving enforcement, adding
staff capacity and training at permitting offices, improving spatial data on lands under threat, changing the
regulation, and more.

Topic: What is the reason for underdevelopment of compact sites in the Urban
Growth Areas? An additional question to consider is where the existing land base of
parcels are available for infill and redevelopment within each Urban Growth Area in
Puget Sound?
Commenter:
Rebecca Brown, Washington State Department of Natural Resources, rebecca.brown@dnr.wa.gov

Problem statement:
With increasing population in Puget Sound comes increased development inside and outside of Urban Growth
Areas. Unfortunately, despite several programs and financial assistance options available, developers are not
developing inside of UGAs at rate that are needed to combat wide-spread development in environmentally
sensitive areas that threaten working lands. By investigating the barriers that are hampering infill and
redevelopment this research topic can reveal some of the reasons why development is not happening within
UGAs at the desired level. These questions aim to address the lack of information around what barriers exist to
redevelopment, infill, and brownfield development within each Urban Growth Area in Puget Sound. Reducing
barriers to infill and redevelopment is an important component of encouraging growth in the UGA and
discouraging growth outside of UGAs – which threatens rural working lands. Several incentive programs, such
as transfer of development rights (TDR) and the Landscape Conservation and Local Infrastructure Program
(LCLIP) are being implemented across Puget Sound. These programs have some success, particularly in urban
centers such as Seattle and Tacoma and in some counties such as King, Pierce and Thurston, but wide-spread
adoption of programs like these, and other programs that encourage density-based development, is minimal.
This research topic should investigate what some of these barriers are that may be hampering infill and
redevelopment. Mapping infill and redevelopment areas would allow regional entities to geographically target
programs that encourage infill and redevelopment. Several maps of these areas do exist, but a cooperative and
combined effort to synthesize them in one place would make efforts to encourage growth inside of UGAs more
effective.

Solution statement:
This research will provide data, either qualitative, quantitative or a visual/spatial representation that can help
policy-makers, jurisdictions, municipalities and practitioners in growth management more effectively
implement targeted programs, campaigns and mechanisms that encourage and direct growth to desired areas

 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                               16
instead of allowing it to continue in ecologically sensitive areas. It will provide the information for practitioners
to remove these barriers to infill and redevelopment, clearing the way for better directing growth towards
preferred growth areas.

Topic: Evaluate the implementation and effectiveness of local government wetland
buffers through the use of the Washington Department of Ecology’s (Ecology) buffer
characterization tool, as detailed in Characterizing Wetland Buffers in Washington
State (Ecology Publication No. 17-06-008).
Commenter:
Rick Mraz, Washington State Department of Ecology rmra461@ecy.wa.gov

Problem statement:
With respect to permit implementation, this research would focus on two main questions. The first addresses
whether permits that are issued are consistent with the requirements of a jurisdiction’s wetland regulations.
Did a permit require the appropriate buffer width and the conditions specified in the regulations, and was the
project built according to the approved site plan illustrating those conditions? The results may indicate
whether wetland regulations are being consistently applied. The second question addresses the ecological
condition of the wetland buffer. Has the buffer been maintained according to the permit conditions, and are
there stressors currently affecting the buffer’s effectiveness? The analysis may reveal that certain key
stressors are common in a jurisdiction or that periodic monitoring is required to maintain buffers in the
intended ecological condition. An additional emphasis and benefit would be further testing and refinement of
Ecology’s Buffer Characterization Tool. An updated tool will further support local government efforts to
monitoring critical area permitting. An improved tool would also support policy development with respect to
monitoring and adaptive management of critical areas and the recent relevant rule updates in WAC 365-195-
920.

Wetland buffers are an effective strategy in protecting wetlands and the functions they provide. Providing
buffers around wetlands is a primary tool used by state and local agencies in Washington State for protecting
wetlands. However, several studies, including three in Washington, suggest that buffers are often not
adequately established and maintained after a permit is issued (Cooke, 1992; Morrison and Julius, 2001;
Snohomish County, 2014). The benefits of buffers in protecting wetland functions and values cannot be
realized without effective establishment and maintenance of those buffers. As noted in Commerce’s CAO
Handbook, “a local government has no way of knowing if they are achieving that goal without looking at the
permit process and the on-the-ground results of critical areas regulation. They need a feedback loop to help
determine whether goals are being met, and if the goals are not being met, how to improve the process.” A
local government should be able to track the effects of decisions made in the implementation of its critical
areas ordinance and produce regular status reports for the public to review. This is an important step to
demonstrate that the goals and requirements of the GMA are being met. To evaluate the effectiveness of local
regulations, one should evaluate the consistency of buffer requirements and whether wetland buffers were
established and maintained. However, our experience indicates that a lack of data may exist on whether
buffers are implemented consistent with local ordinances and whether those buffers maintain attributes that
are protective of wetland functions over time. Applying Ecology’s buffer characterization tool to a random
sample of permits could help the local government assess the consistency of their regulatory requirements
and the effectiveness in establishing the required buffers. Ecology developed a buffer characterization tool, as
detailed in Characterizing Wetland Buffers in Washington State (Ecology Publication No. 17-06-008). The tool
uses four metrics to characterize the condition of a wetland buffer on a project site:


 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                                 17
1) The percentage of the wetland edge that is adjacent to an ecologically significant buffer

2) The width of ecologically significant buffer within the permit buffer

3) The area of ecologically significant buffer within the permit buffer

4) Stressors that are present within the permit buffer

The tool has not been widely used by local governments. Reasons for this may include the general lack of
awareness of it and the absence of training on its use. In addition, elements of the tool, including invasive
species information, data interpretation, and the guidance for using GIS, need to be updated. Updating the tool
will be a natural byproduct of deploying it to study buffer implementation at the local government level. The
additional use and application of the tool through this project will foster opportunities to develop future
outreach and training.

Solution statement:
An analysis of the use of wetland buffers at the local government level would address two recommended
levels of monitoring in the CAO Handbook: permit implementation and effectiveness monitoring. It will also
result in the refinement of a tool that local governments can use to assess these monitoring needs. The
information gathered can be used to strengthen local wetland programs by providing critical feedback on the
effectiveness of a primary wetland protection mechanism (buffers). The tool will be transferable to local
governments interested in conducting their own evaluation of wetland buffer establishment and maintenance.
Local governments make extensive use of Ecology tools when managing and protecting wetlands (e.g., almost
unanimous subscription to the Washington State Wetland Rating System, increasing use the Credit-Debit
method for assessing mitigation adequacy, etc.). Refinement of the buffer characterization tool will promote
its increased use in local government permit monitoring programs. An improved tool will also support policy
development and implementation with respect to monitoring and adaptive management of critical areas and
the recent relevant rule updates.

Topic: What are the best practices for measuring and tracking comprehensive plans’
implementation and effectiveness with regards to equity, including metrics and tools,
and integration of new practices into comprehensive planning such as environmental
justice and improved engagement practices? This topic would provide research into
how local jurisdictions track the their comprehensive plans' effectiveness to equitably
address land use issues within a planning area.
Commenter:
Deric Gruen, Front and Centered, deric@frontandcentered.org

Problem statement:
Recent updates and research associated with the Growth Management Act (GMA) have promised progress of
equity in comprehensive planning. The housing element updates aim for increased affordability and
accessibility for underrepresented communities. At the same time, the Department of Commerce, legislators,
and organizations such as Front and Centered and Futurewise have been working to increase climate justice
and environmental justice as a necessity throughout comprehensive planning. As local governments continue
to add climate justice into their work, tracking the progress will be increasingly important to determine how
local action lessens the harms of environmental and human impacts within our state and better distributes the
benefits.

 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                           18
Solution statement:
Existing tools such as the Environmental Health Disparities Map (EHDM) can be used in early planning stages
to identify overburdened communities and the pertinent health threats within a planning area. However,
research is needed to know how to monitor the impact of comprehensive plan’s actions in a more localized
manner. As comprehensive plans are implemented, it’s important to know whether the measures and actions
are working as intended so that the goals of the plan can be met. If a plan is not on track to meet the plan’s
goals, then that plan is ineffective and does not meet the mandatory or voluntary requirements that planning
areas must meet. As new requirements or measurable needs arise, it is important to evaluate existing and
novel metric tools to know which can be most helpful and which can be improved. The need for equity in
comprehensive planning is continuing to grow, so this research can help support local jurisdictions integrate
such work more smoothly.

Topic: How effectively have state infrastructure funding programs and local financing
options been used to implement local comprehensive plans?
Commenter:
Leonard Bauer, City of Olympia, lbauer@ci.olympia.wa.us

Problem statement:
Local comprehensive plans' capital facilities elements identify projected needs to serve future growth. State
infrastructure programs such as Public Works Trust Fund, Community and Economic Revitalization Board, and
direct appropriations from the Legislature are available to help fund these needs. In addition, the state has
given authority to cities and counties to utilize local tools to fund infrastructure improvements, such as local
improvement districts, transportation benefit districts, and bonding authority. Some state infrastructure
funding programs have adopted criteria or rules related to assessment of funding applications' consistency
with local comprehensive plans. These criteria or rules are generally quite liberal, only requiring a statement
that the project is consistent (or at least not inconsistent) with the comprehensive plan. There is no required
demonstration that the project meets a local priority, or is necessary to serve projected growth. In fact, local
capital facilities elements typically do not provide any prioritization of needs, nor even any analysis of a
project's importance to serving projected growth. As a result, significant portions of many cities and urban
growth areas do not have the necessary basic infrastructure to support private investment in development.
These areas are essentially not available to urban levels of development, despite being included as such in
comprehensive plans and buildable lands analyses. This problem is especially acute in limiting areas available
to address shortages of housing.

Solution statement:
This proposal is for a comprehensive assessment of WA cities' and counties' use of state infrastructure funds
and local infrastructure funding options for facilities to enable future growth within urban growth areas. Such
an analysis could address a number of key questions: How frequently are cities and counties accessing these
programs and tools? How frequently is the resulting funding being targeted to address future growth needs vs.
backlogs in projects to serve existing development? Are cities and counties clearly identifying and prioritizing
infrastructure needs in their comprehensive plans and capital facilities elements to serve future growth? If so,
are they identifying and prioritizing their use of funding tools and applications to those priorities? If not, what
are the impediments to doing so?




 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                               19
Topic: State of the Practice for and Implementation options for the Rural Element.
Commenter:
Dave Andersen, Washington State Department of Commerce, dave.andersen@commerce.wa.gov (Reflects
elected official conversations)

Problem statement:
The GMA contains a clear set of requirements for a robust planning for Rural as well as urban areas. However,
there is little statewide analysis on how the rural element has been implemented.

Solution statement:
This work will produce a map showing designated LAMIRDs in Washington. It will also survey the use of rural
development tools and evaluate the use and effectiveness of different rural development tools. In particular,
the study will evaluate any gaps in state rural policy and assess best practices for implementing the rural
element in both metropolitan and non-metropolitan counties.

Topic: The role of agricultural resource lands in preserving the agricultural economy.
Commenter:
Dave Andersen, Washington State Department of Commerce, dave.andersen@commerce.wa.gov (Reflects
elected official conversations)

Problem statement:
One of the first requirements in the Growth Management Act is to designate and assure the conservation of
agricultural resource lands in order to maintain and enhance the viability of the agricultural sector. Since the
adoption of the Growth Management Act, counties have designated agricultural resource lands, but there is
little statewide understanding of either how many acres are designated or how this has changed over time.
There is a growing trend toward agricultural operations that are smaller in scale, rely on value added activities
or combine agricultural production with experiences, tourism and retail. There is no clear guidance on how
state policies design to enhance the agricultural industry are implemented in a way that facilitates both more
conventional large-scale agriculture and enhances opportunities for new smaller scale agriculture.

Solution statement:
The study will produce a statewide map of designated agricultural, forest and mineral resource lands. The
study will also review policies governing designation and dedesignation criteria and develop best practices for
review of resource lands designation. The study will also review policies governing development and allowed
uses in agricultural resource lands and overall policies governing small-scale value-added agriculture. The
study will provide recommendations on how to adapt agricultural resource lands policy to changes in the
agricultural industry.

Emphasis area four and an inventory of best practices of existing
programs to use as guidance for other jurisdictions.
Topic: Develop a framework for mapping transportation efficient locations across the
state.
Commenter:
Alon Bassok, Washington State Department of Transportation, alon.bassok@wsdot.wa.gov


 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                              20
Problem statement:
Transportation efficient communities offer transportation choices for people and goods to efficiently and
safely reach their destinations. They provide affordable housing near jobs and transportation options, and
transportation choices for all residents and visitors. They are communities where population and jobs should
grow. Several cities in Washington state have explicitly developed transportation efficient communities, and
many more would like to emulate their designs. At the same time, other communities have locations with
some, if not all, of the qualities expected in transportation efficient locations. Some transportation efficient
communities are well known, others are not. There is no baseline data to show where these communities exist.
Lesser known communities may not be on the radar for funding opportunities to improve infrastructure. There
is no inventory from which cities can model transportation efficient design, based on similar geography,
demographics, and community needs.

Solution statement:
Developing a framework for mapping transportation efficient communities already established in the state will
lay the groundwork for data collection and mapping, in order to:

   Establish a data baseline for prioritizing population and job growth in locations where transportation
   efficient communities already exist.
   Establish an inventory of best practices for other cities to model.
   Expand current knowledge of transportation efficient communities, for funding or other technical
   assistance opportunities.

Initial work can build on existing efforts in Washington State including the Growth and Transportation
Efficiency Centers, Regional Growth Centers (Puget Sound Regional Council) and Urban Villages (City of
Seattle). The final product would include a literature review and a list of specifications for what to include in a
mapping effort—e.g., transit stops with frequent, all-day services, density thresholds, appropriate distance
buffers, etc.

Topic: Planning for housing supply and affordability in destination communities.
Commenter:
Dave Andersen, Washington State Department of Commerce, dave.andersen@commerce.wa.gov

Problem statement:
Most rural communities have low rates of growth and relatively low land prices. A few rural communities are
strong tourist destinations. In these communities, much of the housing stock is either vacation homes or
short-term rentals. This presents unusual challenges in applying standard practice for housing planning. For
example, the median income is not as useful an indicator when income is not normally distributed and is highly
unequal.

Solution statement:
Research will evaluate the special housing characteristics and challenges of rural destination communities
and provide practice and policy recommendations on how to adapt the housing element standard practice to
meet the specific challenges of destination communities.

Topic: Evaluating the cost and revenue implications of alternative growth strategies.
Commenter:
Dave Andersen, Washington State Department of Commerce, dave.andersen@commerce.wa.gov


 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                                21
Problem statement:
Local governments are required to plan for and accommodate growth through a 20-year planning horizon. This
includes planning for adequate public facilities such as water, wastewater treatment and capital facilities.
Common practice does not evaluate a resource constrained capital facility plan beyond six years. Local
governments often plan without a clear sense of the fiscal consequences of their long-term growth strategy.

Solution statement:
The solution is to put together a best practice guide that can be utilized and implemented at cities and
counties. A case study with a city and county could be utilized to demonstrate how implementation of revised
permitting practices can reduce timelines, stress on staff, and get permits issued sooner. This is especially
important given the housing crisis. Once complete, options to incentivize implementation of these practices
could also be utilized. More details available upon request.

Topic: Permitting best practices and procedures to reduce the amount of time it takes
to review, and process permit applications.
Commenter:
Clay White, LDC Inc, cwhite@ldccorp.com

Problem statement:
The timeframe to review and issue land use permits has steadily risen over the past 30 years. While statutory
requirements for permit processing have remained the same, such as the requirement for a 14–30-day
comment period for project permit notice of applications, new laws and requirements have made permitting
more complicated. There are also other factors such as multiple departments reviewing applications and how
that is internally coordinated, some jurisdiction's not amending codes to reduce redundant permit processes or
lack of staffing to update codes that could reduce timeframes, optional local government permit processes
that add substantial permitting time, staffing issues related to high retirement rates over the past few years,
and the complexity of redevelopment projects in our most urban areas. There are ways to substantially reduce
permitting timeframes. The way to reduce timeframes is an intentional process which must focus on internal
department review processes, ensuring regulations are up to date and do not create overlapping requirements,
reducing processes that do not add value, and implementing best practices to reduce the amount of review
local governments must do on applications to achieve the same outcomes.

Solution statement:
The solution is to put together a best practice guide that can be utilized and implemented at cities and
counties. A case study with a city and county could be utilized to demonstrate how implementation of revised
permitting practices can reduce timelines, stress on staff, and get permits issued sooner. This is especially
important given the housing crisis. Once complete, options to incentivize implementation of these practices
could also be utilized. More details available upon request.

Topic: How successful has the VSP been in implementing counties to meet the
program purposes?
Commenter:
Dean C. McClary, Pierce County, dean.mcclary@piercecountywa.gov

Problem statement:
The Voluntary Stewardship Program (VSP) was established in 2011. Currently 27 of 39 counties are using this
program as an alternative to traditional GMA CAOs. The program "Promote plans to protect and enhance

 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                          22
critical areas within the area where agricultural activities are conducted, while maintaining and improving the
long-term viability of agriculture in the state of Washington and reducing the conversion of farmland to other
uses (https://app.leg.wa.gov/RCW/default.aspx?cite=36.70A.700).

The current 2023 Washington State legislative will probably pass new legislation to allow the remaining 12
counties to 'Optin-in' the VSP. What Best Available Science (BAS) is there to the program over the last 12 plus
years has effectively protected critical areas in agricultural areas while enhancing agricultural activity?

Solution statement:
The Voluntary Stewardship Program (VSP) was established in 2011. Currently 27 of 39 counties are using this
program as an alternative to traditional GMA CAOs. The program "Promote plans to protect and enhance
critical areas within the area where agricultural activities are conducted, while maintaining and improving the
long-term viability of agriculture in the state of Washington and reducing the conversion of farmland to other
uses (https://app.leg.wa.gov/RCW/default.aspx?cite=36.70A.700).

The current 2023 Washington State legislative will probably pass new legislation to allow the remaining 12
counties to 'Optin-in' the VSP. What Best Available Science (BAS) is there to the program over the last 12 plus
years has effectively protected critical areas in agricultural areas while enhancing agricultural activity?

Topic: What best practices for strategic planning would be effective for local
governments in prioritizing implementation actions in their comprehensive plans?
Commenter:
Leonard Bauer, City of Olympia, lbauer@ci.olympia.wa.us

Problem statement:
City and county comprehensive plans typically do not prioritize or strategically analyze the implementation
actions needed to carry out their comprehensive plans. Many comprehensive plans do not attempt, even at a
very general level, to identify actions needed to implement them. As a result, implementation of comprehensive
plans is extremely uneven and difficult, tending to be very opportunistic depending on political or funding
vagaries. In addition, it is not currently possible for most local governments to track progress of
implementation of their comprehensive plans. This also makes it virtually impossible at a statewide level to
assess effectiveness of plans in addressing statewide GMA effectiveness.

Solution statement:
A result of this research could be specific guidance for local governments that identifies strategic planning
best practices that would be most effective for local governments to identify priorities in implementing their
plans. This guidance could then become part of Commerce GMS's technical assistance to help local
governments utilize those best practices.




 GROWTH MANAGEMENT EMPHASIS AREAS AND RESEARCH PRIORITIES REPORT                                             23


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