Schools Sited Outside of Urban Growth Areas
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- 2023 Commercereports Lgd School Siting Report Final 1De8Ebc1 Ae40 4C64 9A28
Summary
Schools Sited Outside of Urban Growth Areas, a report to the Legislature dated December 1, 2023 from the Growth Management Services unit of the Washington State Department of Commerce, submitted pursuant to Chapter 32, Laws of 2017. The report identifies schools built, planned or under construction since 2017 outside urban growth areas that serve both rural and urban students and are served by an extension of public facilities or utilities. It finds that 183 new schools were sited inside the UGA and that, of 26 schools sited outside UGAs, only two met all report criteria: Highland Middle School and Skyline Elementary School in the Mead School District. It lists 12 key cost considerations for rural school siting and describes a methodology of surveys, interviews and GIS analysis. Appendix A maps schools built from 2017 -2023 by region.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
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“Schools Sited Outside of Urban Growth Areas.”
Original at app.leg.wa.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-commercereports-lgd-school-siting-report-final-1de8ebc1-ae40-4c64-9a28/
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Schools Sited Outside of
Urban Growth Areas
Report submitted pursuant to Chapter 32, Laws of 2017 3rd Sp. Sess
December 1, 2023
GROWTH
MANAGEMENT
SERVICES Report to the Legis lature
Director Mike Fong
v3.4
Municipal Research & Services Center
Acknowledgments Northshore School District
Washington State Department of Commerce
Office of the Superintendent of Public Instruction
Local Government Division
Pacific County Department of Community Development
Growth Management Services Unit
Pend Oreille County Community Development
Anne Fritzel, Housing Programs Manager Department
Benjamin Serr, Eastern Washington Regional Manager Pierce County Planning and Public Works Department
Deanah Watson, Senior Planner Skagit County Planning and Development Services
Department
Research and Development Services Unit
Snohomish County Planning and Development Services
Allan Johnson, Municipal Finance Section Manager Department
Alice Zillah, Research and Development Services Unit Spokane County Building and Planning Department
Managing Director
Stevens County Planning Division
James Vogl, Research Analyst
Walla Walla County Community Development
Jordan Laramie, State Surplus Property Program Department
Manager
Washington Association of Education Service Districts
Additional thanks to:
Washington State Department of Transportation
Benton County Planning Division
Washington State School Directors Association
Bethel School District
Whatcom County Planning and Development Services
Chelan County Community Development Department
Yakima County Planning Division
Clark County Community Planning
Columbia County Planning and Building Department
LOCAL GOVERNMENT DIVISON
Construction Services Group, Education Service District
Mark Barkley, Assistant Director
112
Mark.Barkley@commerce.wa.gov
Franklin County Planning and Building Department
1011 Plum St. SE
Grant County Planning Division
P.O. Box 42525
Island County Planning and Community Development Olympia, WA 98504-2525
Department
www.commerce.wa.gov
Jefferson County Department of Community
Development For people with disabilities, this report is available on
Kitsap County Department of Community Development request in other formats. To submit a request, please
call 360-725-4000 (TTY 360-586-0772)
King County Planning
Lewis County Community Development Department
Mason County Department of Community Development
Mead School District
Moses Lake School District
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 2
2.0
Contents
Acknowledgments ................................ ................................ ................................ ................................ ....... 2
Executive summary................................ ................................ ................................ ................................ ...... 4
Introduction ................................ ................................ ................................ ................................ ................. 6
Case studies ................................ ................................ ................................ ................................ ................ 9
Highland Middle School and Skyline Elementary School ............................................................................................ 10
Mos es Lake Elementary School #12 ............................................................................................................................... 12
Ruby Bridges Elementary School ..................................................................................................................................... 13
Key cost factors ................................ ................................ ................................ ................................ ......... 15
Conclusions on rural school siting ................................ ................................ ................................ .............. 23
Background studies on rural school siting ................................ ................................ ................................ .. 24
Appendix A: Mapping urban growth areas and new school construction since 2017 ................................ .... 30
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 3
Executive summary
The Legislature passed Chapter 32, Laws of 2017, which clarifies that nothing in Chapter 36.70A RCW
prohibits "a county planning under RCW 36.70A.040 from authorizing the extension of public facilities and
utilities to serve a school sited in a rural area that serves students from a rural area and an urban area," subject
to certain conditions. Commerce prepared this legislative report in alignment with tho se requirements.
Specifically:
"By December 1, 2023, [Commerce] shall report to the governor and the appropriate committees of the
legislature about schools outside of urban growth areas that have been built, are under construction, or are
planned as a result of the requirements of [Chapter 32, Laws of 2017 3rd sp. sess]. The report shall include
the number, location, and characteristics of the schools; the number of urban and rural students served; and
a cost analysis of schools built outside of urban growth boundaries."
Project goals
This report identifies the number of schools built, planned, or under construction since 2017 and the passage
of Chapter 32, Laws of 2017, and which:
Are s ited outs ide of urban growth areas (UGA);
S erve s tudents from both rural and urban areas ; and
Are s erved by an extens ion of public facilities or utilities .
It includes findings related to:
Where the s chools are located
T he s chools ' characteris tics
T he number of s tudents from rural and urban areas that thes e s chools s erve
Cos t analys es for s chools built outs ide of UGAs , and factors that affect s iting decis ions
T o accomplis h thes e goals , Commerce conducted s urveys of and interviews with planning and community
development officials , s chool as s ociation repres entatives , and s chool dis trict officials . Commerce als o
conducted geos patial analys is to aid in identifying s chools that may have met the report criteria.
Key findings
S ince 2017, 183 new s chools were s ited ins ide the UGA either on newly acquired s ites or on exis ting land. Of
the 26 s chools s ited outs ide of UGAs in this period, Commerce found only two s chools that met all report
criteria. Both s chools are located in the Mead S chool Dis trict, on the s ame 64-acre parcel outs ide of the City of
S pokane's UGA. Thes e s chools , Highland Middle S chool and Skyline Elementary S chool, s erve s tudents from
both rural and urban areas , and are connected to s ervices by an extens ion of public utilities .
Highland Middle S chool characteris tics :
Opened: 2020
Total cost : $41 million
Size: 120,000 square feet
Students enrolled in the 2021 -2022 school year: 757
Proportion of students served that live in rural areas : 75%
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 4
S kyline Elementary S chool characteris tics :
Opened: 2021
Total cost : $24 million
Size: 62,000 square feet
Students enrolled in the 2021 -2022 school year: 358
Proportion of students served that live in rural areas : 50%
In addition to these schools, Commerce found two schools sited near the boundaries of or outside of UGAs
that did not meet all report criteria, but which exemplify some of the key factors that affect school siting
decisions. The Case Studies section of the report provides details about each of these four schools.
Cost considerations:
Through interviews with subject matter experts and reviews of past research on school siting in Washington
and school construction costs, Commerce identified 12 key cost considerations that may influence rural
school siting d ecisions:
Parcel availability
Parcel size
Parcel cost
Site hazards
Water utilities
Sewer utilities
Pedestrian and bike facilities
Motorized transportation including school buses and private vehicle transportation
Stormwater facilities
Proximity to housing
Shared use agreements
Impact fees
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 5
Introduction
Urban growth areas
Urban Growth Areas (UGAs ) are a community tool under the Growth Management Act (GMA) 1 to limit urban
s prawl, protect agricultural and fores t lands from development, and maintain rural character. Communities can
primarily do this by limiting s ewer and s tormwater infras tructure and s mall lot s izes to within a UGA. An added
benefit of concentrating development is that the capital and ongoing maintenance cos ts of infras tructure are
s us tainable. As development dens ity decreas es , the feas ibility of maintaining public infras tructure at cos ts
affordable to mos t people diminis hes .
T here are 29 counties in Was hington that are "fully planning"2 under the GMA, each of which mus t des ignate
and periodically review UGAs as part of a public proces s that res ults in a comprehens ive plan. Each UGA is the
product of an analytical public proces s . Communities can cus tomize the UGA to provide s ervices and facilities
without exceeding their financial limits . T he infras tructure needed to s erve s chools are s ubject to the s ame
capital and maintenance cos ts as the res t of the community.
Urban s ervices and s chool s iting
Communities plan for urban s ervices —s uch as s anitation, s ewers , drinking water, and s tormwater s ys tems , as
well as s chools and other facilities —bas ed on a twenty-year planning period. 3 Property values outs ide of UGA
boundaries appear lower-cos t at the time of purchas e compared to urban properties . However, low-dens ity
s prawl is les s affordable over time bas ed on the overall cos t of building, repairing, and replacing urban s ervices
extended to remote locations .
For s chool dis tricts that s erve s tudents from both rural and urban areas , rural s ites near an urban growth
boundary may be es pecially appealing and mos t s uitable for accommodating s tudents from both areas . When
a dis trict s eeks a place for a new s chool, rural properties jus t beyond the UGA may be readily available and
inexpens ive real es tate. Yet s chool dis tricts contend with much more than property cos ts alone. A fully
informed choice involves meas uring potential s avings agains t the expens e of extending and maintaining urban
s ervices and other budgetary factors .
Under mos t circums tances , cities cannot extend public utilities outs ide of UGAs unles s doing s o protects the
environment as well as bas ic public health and s afety. 4 However, the GMA allows extens ion of urban s ervices ,
s uch as s ewer, to s erve s chools s ited outs ide UGAs . Prior to the pas s age of Chapter 32, Laws of 2017, s ome
s chool dis tricts built on-s ite was tewater treatment facilities for s chools s ited outs ide of UGAs , while others
abandoned propos ed s ites outs ide of UGAs in favor of urban locations due to a variety of factors , including
proximity to s tudents . 5 6
T he up-front cos ts to buy or expand upon urban properties may be higher than an available rural s ite, but
s chool dis tricts als o budget for trans portation cos ts , which increas e when bus ing s tudents to outlying areas .
1 RCW 36.70A
2 RCW 36.70A.040
3 RCW 36.70A.110
4 RCW 36.70A.110
5 RCW 36.70A.110
6 King County, "King County S chool S iting Tas k Force: Final Report and Recommendations ," (2012),
https ://kingcounty.gov/~/media/depts /executive/performance-s trategy-budget/regional-
planning/GrowthManagement/2012_S choolS itingFinalReportAndRecommendations .as hx?la=en
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 6
T his dynamic produces important trade-offs for communities to cons ider each time there are choices between
s ites equipped with urban s ervices (at property prices reflecting the public inves tment) compared with s ites
that will require expanded s ervices to s upport s tudents at a rural s chool.
Methodology
Commerce pursued two research tracks to prepare this report to identify key cost factors and case studies.
The results of this method provide background on cost considerations influencing school siting in rural areas .
It also provides insight for schools that meet the report criteria defined by the report's authorizing mandate in
Chapter 32, Laws of 2017. 7 Both tracks involved res earch ques tions bas ed on content in the report mandate,
s uch as :
How many s chools are planned, under cons truction, and/or have been built outs ide of UGA boundaries as a
res ult of the 2017 legis lative changes ?
Where are thes e s chools located?
Are thes e s chools s erved by an extens ion of public facilities from ins ide a UGA?
What are the s chools ' characteris tics , including how many (urban and rural) s tudents do they s erve?
What can be identified as decis ion-making factors and cos t cons iderations to s ite a s chool outs ide vers us
within UGA boundaries ?
T hes e bas eline ques tions provided guidelines for topic s cope and s erved a s tarting-point from which the
res earch team could expand where neces s ary to provide context or highlight relevant information.
Methodology: Key cos t factors
Commerce determined key cos t factors affecting rural s chool s iting bas ed on relevant s tudies , pas t planning
efforts acros s the s tate and other s ources regarding rural s chool s iting, and cons truction cos ts . T his included
s ources from the United S tates Environmental Protection Agency 8 as well as s ources from other s tates
including California 9 , Maine 10 and Oregon. 11
Commerce then interviewed s takeholders to inves tigate the decis ion-making factors that influence whether a
s chool dis trict will locate a s chool outs ide UGA boundaries . An examination of individual cas e s tudies followed
along with additional res earch to build upon s taff knowledge and refine our findings .
Methodology: Cas e s tudies
Commerce s urveyed s ubject-matter experts , including local planning officials and s tatewide s chool
as s ociations , and conducted GIS analys is to identify s chools that might meet the report criteria. Commerce
began by identifying s chools s ited outs ide of UGAs s ince 2017 and then identified s chools from that lis t that
s erve s tudents from both rural and urban areas and are s erved by an extens ion of public utilities .
7 RCW 36.70A.213 (2017), https ://leg.wa.gov/CodeRevis er/documents /s es s ionlaw/2017pam3.pdf
8 Environmental Protection Agency, "S chool S iting Guidelines ," (2011), https ://www.epa.gov/s ites /default/files /2015-
06/documents /s chool_s iting_guidelines -2.pdf
9 California Department of Education, "S chool S ite S election and Approval Guide," (2023),
https ://www.cde.ca.gov/ls /fa/s f/s chools iteguide.as p
10 Maine Department of Education, "Major Capital S chool Cons truction Programs ," (2023),
https ://www.maine.gov/doe/s chools /facilities /mcs cp
11 Oregon T rans portation and Growth Management Program, "Planning for S chools & Liveable Communities , the Oregon S chool S iting
Handbook," (2005), https ://www.oregon.gov/lcd/Publications /s chools itinghandbook_2005.pdf
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 7
Commerce contacted planning or community development departments in the 29 fully planning counties and
received res pons es from 22 of thos e counties . Of thes e 22 counties , only three identified s chools s ited on or
outs ide of urban growth area boundaries s ince 2017. Only one of thes e s chools als o met the additional report
criteria, however.
Moreover, Commerce reached out to the Was hington S tate S chool Directors As s ociation (WS S DA) and the
Was hington As s ociation of Education S ervice Dis tricts (WAES D). WSS DA agreed to inquire with its members if
they were aware of any s chools in their dis tricts that may meet the report criteria. Commerce received three
res pons es from this s urvey, one of which identified a s chool s ited outs ide a UGA s ince 2017.
WAES D referred Commerce to s everal contacts with deep knowledge of s chool s iting acros s the s tate,
including its cons truction s ervices group (CS G). CSG, hous ed in Education Service Dis trict 112, provides a
variety of capital project s upport s ervices to s chool dis tricts s tatewide. WAES D's contacts helped Commerce
identify s everal s chools s ited outs ide urban growth areas s ince 2017.
In addition to thes e s urvey efforts , Commerce overlaid OS PI cons truction data from its Inventory and Condition
of S chools (ICOS ) s ys tem with a s tate GIS layer containing UGAs to identify new cons truction in rural areas
s ince 2017. T he ICOS s ys tem only contains data on s chool capital projects that received s tate funding, or
voluntarily reported data. Commerce conducted further res earch on s chools it identified outs ide of urban areas
to filter out replacement or renovation projects on exis ting rural s ites , or s chools that only s erve rural s tudents .
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 8
Case studies
Figure 1: Four case studies from Grant, Snohomish, and Spokane
Overview
The following case studies feature two schools from Spokane County, which Commerce found to meet all the
criteria established for this report. Both schools are located in the Mead School District and were built outside
of UGA boundaries since 2017. They also serve students from rural as well as urban areas and are connected
to services by extension of public utilities.
Commerce identified two other schools fulfilling only part of the research criteria for constructed facilities and
included them within the following case studies. The examples feature elementary schools from Grant
County's Moses Lake School District and Snohomish County's Northshore School District. Theyprovide insight
into factors that dis tricts consider in the decision to site schools serving urban and rural student populations
either inside or outside UGA boundaries.
Construction data
In addition to the newly built or proposed schools featured in case studies of this section, OSPI provided data
for this analysis that combines construction of new schools with other construction projects. Since 2017,
school districts have undertaken a total of 235 school building construction projects, 26 of which were
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 9
projects beyond UGAs and 209 were for projects located within UGAs . T hes e totals aggregate new-builds with
other cons truction activities , including facility expans ions or repairs .
Bas ed on OS PI data, four s chools have been built jus t beyond UGA boundaries s ince 2017. However, it is not
clear whether thes e s chools were built as a direct result of the legislative changes that clarified conditions for
extending urban services for rural schools.
In addition to data analysis pertaining to school construction, Commerce directly contacted sch ool district
officials to verify findings and collect more detailed information to contextualize each case study.
Four case studies
S pokane County, Mead School Dis trict: Highland Middle S chool
S pokane County, Mead School Dis trict: S kyline Elementary S chool
Grant County, Mos es Lake S chool Dis trict: Mos es Lake Elementary S chool # 12
S nohomis h County, Norths hore S chool Dis trict: Ruby Bridges Elementary S chool
S pokane County cas e s tudies : Mead S chool Dis trict
Highland Middle School and Skyline Elementary School
In 2018, S pokane County voters approved a $114.5 million bond propos ition to finance the cons truction of a
new middle s chool and elementary s chool, among other capital improvements . T hes e propos ed s chools
became Highland Middle S chool and Creeks ide Elementary S chool. Creeks ide is located ins ide the urban
growth area, northeas t of the Highland s ite, acros s US Highways 2 and 395. In the proces s of building
Creeks ide Elementary S chool, the dis trict acquired 16 lots in order to have enough land to accommodate the
s chool. Creeks ide s its on 11.4 acres and is 66,000 s quare feet in s ize.
During cons truction planning, the dis trict decided to extend public utilities to the Highland s ite knowing that it
might als o become the s ite of a s econd new s chool, which could utilize this new infras tructure. While the bond
propos ition did not include a propos al for two new elementary s chools , the Mead S chool Dis trict received more
s tate S chool Cons truction As s is tance Program funds than it anticipated for the Highland project, allowing it to
finance the cons truction of S kyline Elementary S chool.
Highland and S kyline are located outs ide of the City of S pokane UGA. Both s chools are connected to public
utilities and s erve s tudents in urban and rural areas . T he dis trict’s decis ion to s ite Highland Middle School and
S kyline Elementary S chool in the Five Mile Prairie area, near S pokane, was influenced by increas ed res idential
development and growing enrollment in the area, and the greater eas e of purchas ing s ufficient land outs ide the
urban growth area.
Prior to the cons truction of thes e s chools , the dis trict was bus ing 60 to 70 s tudents from the Five Mile Prairie
neighborhood to neighboring Farwell Elementary S chool, about five miles away from the current location of
S kyline Elementary S chool. 12 By building the two new s chools in Five Mile Prairie, one of the objectives of the
dis trict was to reduce thes e bus ing miles .
12 Mead S chool Dis trict, email corres pondence, (2023)
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 10
Figure 2. Highland Middle School and Skyline Elementary School in Spokane County
Figure 3. Mead School District sites located outside of the City of Spokane's Urban
Growth Area
Highland Middle School, 120,000 square feet in size, opened in 2020,and Skyline Elementary School, 62,000
square feet in size, opened in 2021. The total costs for these schools were $41 million and $24 million,
respectively. According to the National Center for Education Statistics, 757 students enrolled at Highland
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 11
Middle S chool during the 2021-2022 s chool year, and 358 s tudents enrolled at S kyline Elementary School
during the s ame period, with capacity to s erve up to 600 s tudents in the future. 13 14 T he dis trict es timates that
75% of s tudents enrolled at Highland and 50% of s tudents enrolled at Skyline live outs ide of the S pokane UGA.
T he dis trict cons idered s everal s ites for Highland and S kyline, but s truggled to find a large enough parcel
ins ide the UGA. Highland and Skyline s it on the s ame 64-acre parcel, jus t outs ide of the UGA.
Grant County cas e s tudy: Mos es Lake S chool Dis trict
Moses Lake Elementary School #12
The Moses Lake School District is currently in the process of acquiring a 14-acre lot for a proposed elementary
school in the Mae Valley, just west of the Moses Lake UGA.Part of the district's interest in proposing a new
school in the Mae Valley is to reduce busing miles for an area where residential development has increased.
The district currently buses more than 300 students out of the area to other schools, and these trips include
highway miles. New development in the Mae Valley area includes a new 57-lot subdivision contributing to
busing miles in a trend that the district expects will continue.15
The school district, in consultation with the City of Moses Lake, identified the Mae Valley location as a possible
site for a new elementary school - Moses Lake Elementary School #12 - while it was in the process of siting
and building Vicki Groff Elementary School. Moses Lake Elementary School #12 would serve 450 students and
could serve up to 750 students, if needed, to accommodate future growth.
Figure 4. Moses Lake Elementary #12 and Vicki Groff Elementary in Grant County
13 National Center for Education Statistics, "Highland Middle School," (2023),
https://nces.ed.gov/ccd/schoolsearch/school_detail.asp?Search=1&DistrictID=5304920&ID=530492003767
14 National Center for Education Statistics, "Skyline Elementary School," (2023),
https://nces.ed.gov/ccd/schoolsearch/school_detail.asp?Search=1&Zip=99021&Miles=10&SchoolPageNum=2&ID=53049200377 9
15 Columbia Basin Herald, "Refuge at Mae Valley," (2023), https://columbiabasinherald.com/news/2023/feb/10/refuge -mae-valley/
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 12
Figure 5. Proposed Moses Lake Elementary School #12 in the City of Moses Lake
The proposed site for Moses
Lake Elementary School #12 is
situated partly inside and partly
outside the UGA. According to
the district, the property owner
plans to subdivide the parcel
and seek an amendment to the
UGA in a process to bring the
entire site into the UGA.
The district intends to acquire
the portion of the parcel outside
of the UGA to serve as ballfields
for the proposed school . This
would bring the portion of the lot
that is currently beyond the UGA
inside of it. The district hopes to
close on the property by the end
of 2023 and begin construction
in 2024.
Snohomish County case study: Northshore School District
Ruby Bridges Elementary School
Completed in the fall of 2020, Ruby Bridges Elementary School is located in Woodinville, just outside of the
Bothell unincorporated UGA. Funded by a $275 million bond proposition approved by voters in 2018,the school
was built to ease overcrowding in other schools in the Northshore School District, at a total cost of
approximately $65 million.
Ruby Bridges Elementary School is approximately 76,000 square feet, and was designed to serve around 500
students. According to the National Center for Education Statistics, 474 students enrolled at the school during
the 2021-2022 school year.16 However, the dis trict provides that it is unknown how many of thes e s tudents live
outs ide the UGA and how many s tudents live ins ide it.
T he s chool does not have a s ewer connection, operating a large s eptic s ys tem on-s ite becaus e the s ite is
outs ide the UGA, and s ufficiently dis tant from any planned s ewer extens ions by the Alderwood Water and
Was tewater Dis trict. If the UGA were extended in the future, and include the s ite of Ruby Bridges , then the
s eptic s ys tem may eventually be changed to a s ewer extens ion.
16 National Center for Education S tatis tics , "Ruby Bridges Elementary S chool," (2023),
https ://nces .ed.gov/ccd/s chools earch/s chool_detail.as p?S earch=1&Zip=98072&Miles =10&ID=530591003746
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 13
Figure 6. Ruby Bridges
Elementary in Snohomish
County | Figure 7. School Site
and UGA Boundaries
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 14
Key cost factors
Cost analysis of Key Factors
Based upon review of the case studies and through interviews of key stakeholders, there appear to be12 key
factors that play into the cost of construction and ongoing operation , and affect the decision whether to site all
or part of a school facility in a rural location:
S ite Availability
S ite S ize
S ite Cos t
S ite Hazards
Water Utilities
S ewer Utilities
Pedes trian and Bike Facilities
Motorized T rans portation
S tormwater Facilities
Proximity to Hous ing
S hared Us e Agreements
Impact Fees
S ome of thes e factors , like parcel cos ts , provide s trong incentives to s chool dis tricts to s ite new facilities in
rural locations ; however other factors , s uch as the extens ion of urban s ervices and facilities , create cos ts and
impacts that can offs et thos e incentives and make development within the urban growth area often the
preferred alternative, bas ed on overall lower cos ts .
T his analys is provides a broad overview of the factors that s tood out among many and this dis cus s ion
attempts to put into contras t the magnitude of thes e factors . It is does not provide an in-depth analys is , which
mus t be as certained on a cas e-by-cas e bas is .
Interviews and data analys is
T o unders tand the range of cos t factors that affect the decis ion whether to s ite a s chool in a rural s etting
better, we held eight interviews with s takeholders in J uly and Augus t of 2023. Thes e interviews included
dis cus s ion with the following:
King County
Municipal Res earch and S ervices Center
Office of the S uperintendent of Public Ins truction
Was hington S tate Department of Commerce
Was hington S tate Department of T rans portation
Was hington S tate S chool Dis trict As s ociation
T opics that we dis cus s ed at length included water rights , climate change planning, us e of impact fees , and
s afe routes to s chools . T hes e interviews helped inform the analys is of key cos t factors affecting s chool s iting
decis ions .
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 15
S ite s ize
Perhaps no other factor is more important to the s uitability of a potential new s chool location as the s ize of the
facility and the land that mus t be s ecured for it. WAC 392-342-020 s ets forth advis ory guidelines for the
minimum s ize of s chool facilities . T hes e guidelines s ugges t a minimum of five us able acres for an elementary
s chool and 10 us able acres for a middle or s enior high s chool. An additional five us eable acres is
recommended for every 100 s tudents at maximum enrollment levels , though not required.
With an average enrollment of about 400 s tudents , that s ets the minimum recommended s ize for an
elementary s chool at 25 acres . 17 A directory of Was hington high s chools provides that High s chools average
approximately 800 s tudents and therefore have a minimum recommended average s ize of 55 acres bas ed
upon the guidelines in the WAC. 18 Importantly, enrollment in a particular s chool may vary s ignificantly higher or
lower than thes e s tatewide averages .
T hes e average s ize requirements res ult in the need for a parcel that could otherwis e accommodate 150-330
homes (at s ix gros s units /acre) or 450-990 apartment units (at 18 gros s units /acre). S ites of this s ignificant
s ize are becoming harder to find within a number of urban areas throughout the s tate. 19 20
Rural s ites often provide an advantage over urban locations when s earching for s ites of s ufficient s ize becaus e
larger parcels and undeveloped s ites tend to be more readily available outs ide of urban growth areas . S chool
dis tricts may face cons traints in s ecuring s ites of s ufficient s ize for a new facility in urban locations .
One method that s chool dis tricts can cons ider is opting for a s maller s ite within urban growth boundaries .
WAC 392-342-020 allows for s iting new facilities on s ites s maller than the minimum guidelines if:
(a) T he health and s afety of the s tudents will not be in jeopardy;
(b) T he internal s paces within the propos ed facility will be adequate for the propos ed educational program;
(c) T he neighborhood in which the s chool facility is or will be s ituated will not be detrimentally impacted by
lack of parking for s tudents , employees , and the public; and
(d) T he phys ical education and recreational program requirements will be met.
T here are a number of ways to reduce s chool s ize including:
Cons tructing multi-s tory facilities ;
Creating s hared us e agreements with adjacent community facilities s uch as parks or community centers ;
Developing s hared facilities or integrating new s chools within larger developments ;
Utilizing s ubterranean or s tructured parking; and
Redeveloping exis ting facilities or locations .
S ome of thes e approaches , s uch as s hared us e agreements , can help reduce the overall cos t of development
while others , like multi-s tory cons truction or s tructured parking will likely res ult in increas ed facility cos ts . In
17 National Center for Education S tatis tics , "Diges t of Education S tatis tics , Table 103 Public Elementary S chools by grade s pan…, 2008-
09," (2023), https ://nces .ed.gov/programs /diges t/d10/tables /dt10_103.as p
18 High S chools .com, "Was hington High S chools ," (2023), https ://high-s chools .com/directory/wa/
19 Reas on Foundation, "A Line in the Land: Urban-growth Boundaries , S mart Growth, and Hous ing Affordability," (1999),
https ://reas on.org/wp-content/uploads /files /c5ba9be86e1bda65352dcf0e87a46c5a.pdf
20 Pacific Res earch Ins titute, "U.S . Land S hortage is a Res ult of Artificial Growth Limits ," (2022), https ://www.pacificres earch.org/u-s -
land-s hortage-is -res ult-of-artificial-growth-limits /
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 16
s ome cas es , thes e cos ts may double for multi-s tory facilities with s ubterranean or s tructured parking bas ed
upon recent es timates of cons truction cos ts . 21
S ite availability
In the abs ence of an exis ting location that can be renovated or rebuilt, one of the firs t tas ks upon s iting a new
s chool facility pertains to an inventory of s ites that are currently owned or available for purchas e (or in rare
cas es through condemnation) by the s chool dis trict. Even when new s chool facilities can be reduced in s ize, it
is pos s ible that the dis trict could encounter difficulty identifying adequate vacant or underdeveloped s ites . T he
relative abundance of larger parcels and potential development s ites in rural locations may res ult in the dis trict
cons idering multiple s ites in rural areas compared to fewer s ites within the urban area.
While the ratio of s ites within urban areas vers us rural areas may not directly affect the cos t of the
development of each s ite, it can affect the final cons truction decis ion if no s uitable s ites are located within the
urban area. 22
A s ignificant number of s chool dis tricts own lands in rural areas and many of thes e as s ets were purchas ed
prior to the change in the law regarding rural s chool s iting. In thes e locations , the exis ting owners hip of
property provides a s trong incentive for the dis trict to utilize that location, even if it is outs ide of the UGA.
S ite cos t
S ites outs ide of UGA boundaries appear more affordable when excluding the cos ts inherent in extending urban
s ervices . The bas e property cos t of a rural s ite is generally lower when compared to s ites within a UGA where
urban s ervices are already available nearby. T his forms an initial preference for communities to s eek
pros pective s chool s ites outs ide of UGA boundaries .
While the actual cos t ratio varies by location, res earch indicates that rural s ites may be s ecured for 10% to 50%
of the cos t of a comparable parcel located within urban growth boundaries . 23 24 25 T his price differential can
create a s trong motivation for dis tricts to look to rural s ites as the pos s ible location of a new s chool.
T his initial preference for rural s ites can be more pronounced when a s chool dis trict already owns property
outs ide of a UGA. Dis tricts in this pos ition need to weigh s ite-s pecific alternatives to determine which s ites
offer the mos t feas ible financial option. They mus t determine whether it is more beneficial to either pay for
extending public facilities and s ervices to their rural s ite or to leverage as s ets and acquire new property at a
s ite where the community already concentrates s uch public inves tments .
21 T om S calis i, Levels et "2022 Guide to US Building Commercial Cons truction Cos t per S quare Foot," (2022),
https ://www.levels et.com/blog/commercial-cons truction-cos t-per-s quare-foot/
22 Office of S uperintendent of Public Ins truction, "S ummary Report: Firs t S ummit on S chool Planning and S iting in Was hington," (2007),
https ://web.archive.org/web/20120906001855/https ://www.k12.wa.us /s chfacilities /publications /pubdocs /s ummits chools itingreport
may2007.pdf
23 Shishir Mathur, Housing Studies, “Impact of Urban Growth Boundary on Housing and Land Prices: Evidence from King County, WA, "
(2014),
https://www.researchgate.net/publication/261857272_Impact_of_Urban_Growth_Boundary_on_Housing_and_Land_Prices_Evidence_fr
om_King_County_Washington
24 Wendell Cox, Newgeography, "The Costs of Smart Growth Revisited: A 40 YearPerspective," (2011),
https://www.newgeography.com/content/002324 -the-costs -smart-growth-revisited-a-40-year-perspective
25 Scott Latta, Modern Farmer, "Portland’s Urban Growth Boundary Plots City Versus Country," (2016),
https://modernfarmer.com/2016/09/portland -urban-growth-boundary/
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 17
S ite hazards
When evaluating potential s ites , dis tricts cons ider factors that could affect the s afety of s tudents and faculty
as well as the s tructures thems elves . T hes e potential hazards include ts unami zones , s eis mic hazards ,
potential lands lide locations , and areas at ris k for wild fire.
Other natural features that can limit the us ability of a s ite include the pres ence of water features , wetlands or
s teep s lopes . T he pres ence of any of thes e encumbrances will affect the planning and placement of buildings ,
parking, play areas , and ballfields , and may render large portions of the s ite undevelopable.
While thes e encumbrances may occur on urban s ites that are undeveloped or underdeveloped, they tend to be
more prevalent in rural s ettings . This happens in part becaus e communities excluded locations prone to
s ignificant hazards from the urban area during creation of their urban growth areas . In addition, s ome
communities des ignate urban areas cons trained by natural hazards for low-dens ity development.
As a res ult, s ignificant portions of large rural s ites , or urban areas with low-dens ity zoning, may not be us able
for development of new s chool facilities . If half of a s ite has natural hazards , then the net price of the us able
land is effectively increas ed and perhaps doubled. 26
Water utilities
T he provis ion of water to a rural location can res ult in s ignificant added expens e to the development of a new
s chool facility. With recent water rights decis ions , it is more likely that a s chool would need to connect to an
exis ting water s ys tem rather than es tablis hing a new well. 27 28 Individual water rights are rare and expens ive to
get in mos t locations throughout the s tate.
Water s ys tem extens ions can become quite expens ive as current es timates place cos ts at $75 to $225 per
linear foot. T hus , a half-mile water main extens ion could add up to $594,000 to the cos t of a new s chool. 29 T he
alternative cos t of a private well could not be as certained for this s tudy.
S ewer utilities
S omewhat s imilar to water mains , s ewer mains can cos t $50 to $200 per linear foot. This can res ult in
s ignificant development cos ts . At thes e rates , a half-mile extens ion would cos t up to $528,000. 30 31 T his
additional cos t as s umes that the s chool would not, or could not, utilize a s eptic s ys tem where s ewage flows
into a detention chamber and outflows to a drainage field. While utilizing a s eptic s ys tem would involve s ome
cos ts reducing the net financial impact, we anticipate that approach to be s ignificantly les s than extens ion of
26 T eri S hore, Greenbelt Alliance, "What are Urban Growth Boundaries and Why Do We Need Them?," (2020),
https ://www.greenbelt.org/blog/what-are-urban-growth-boundaries -need/
27 Was hington S tate Department of Ecology, "Hirs t Decis ion," (2023), https ://ecology.wa.gov/Water-S horelines /Water-s upply/Water-
rights /Cas e-law/Hirs t-decis ion
28 Municipal Res earch and S ervices Center, "Water Rights ," (2023), https ://mrs c.org/explore-topics /environment/water-topics /water-
rights
29 Fixr, "Main Water Line Ins tallation Cos t Guide," (2022), https ://www.fixr.com/cos ts /main-water-line-ins tallation
30 Alliw Ogletree, Angi "How Much Does S ewer Line Ins tallation Cos t? [2023 Data]," (2023), How Much Does It Cos t to Connect to Public
S ewer? [2023 Data] | Angi
31 Alexis Carthan, T his Old Hous e, "What is a S ewer Line Replacement?," (2023),
https ://www.this oldhous e.com/plumbing/reviews /s ewer-line-replacement-
cos t# :~:text=T ypically%2C%20you'll%20pay%20between,extra%20expens es %20to%20your%20project
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 18
s ewer. 32 Us e of an on-s ite treatment s ys tem, which provides localized s anitary s ewage treatment, is more
expens ive and would tend to even out cos t differentials . 33
S eptic s ys tems will have ongoing cos ts as s ociated with periodic emptying of the detention tanks . However,
dead-end tightline s ewers would als o res ult in s ome ongoing cos ts , es pecially during s ummer breaks , as they
need to have water running frequently to avoid s tagnation, plus monthly fees to the s ewer provider.
S ewer cos ts appear to be one of the deciding factors that led the Central Valley S chool Dis trict (CVS D) in
Liberty Lake, Was hington to pick a s ite located within the urban growth area over s everal rural locations . T he
CVS D conducted an analys is of four s ites with three of thos e locations being in rural areas . They es timated
s ewer cos ts to the rural locations at $600,000 to $750,000 in 2020. While the overall cos ts of the all three rural
locations exceeded the urban location, s ewer was one of the mos t s ignificant cos ts found in the analys is .
Pedes trian and bike facilities
On average, an es timated 10% to 20% of s tudents either bike or walk to s chool. T he ratio of s tudents walking
decreas es at dis tances more than a quarter-mile from the s chool while biking ratios decreas e at dis tances
between one to three miles . 34 35
In urban locations , s tudents us e the exis ting network of roads and s idewalks to acces s s chools by foot or bike.
T hes e networks are typically limited in rural s ettings . In cas es where s chools are located in rural areas , the
ability to create a new network is cons trained and facilities typically become res tricted to one, or a few, linear
routes . T ypically, new s idewalks and bike paths are required to provide acces s for s tudents to travel to and
from the s chool by non-motorized trans portation. T hes e generally mus t be newly ins talled facilities as they are
cons idered urban facilities and would not otherwis e be allowed in the rural area. The Was hington S tate
Department of T rans portation generally es timates cos ts for thes e improvements at $1 million per mile.
T he linear configuration of bike and pedes trian routes to rural s chool locations can increas e traffic levels and
hazards along the pedes trian and bike routes , requiring greater hazard mitigation meas ures s uch as
roundabouts and added traffic s igns and s ignals . T his may res ult in s ignificant added traffic mitigation cos ts .
In addition, becaus e the ratio of s tudents living within a quarter-mile of the s chool in a rural area is s ignificantly
lower than in an urban location, it is likely that there will be an increas e in s tudents that utilize bus es or
pers onal vehicles for trans portation to and from s chool.
T he Was hington S tate Department of T rans portation provides grants through the S afe Routes to School
Program (S RT S ) to improve s afety and mobility for children, encouraging more walking and biking to s chool. 36
S iting s chools clos er to urban areas is cons is tent with many of the program's primary objectives , s uch as
ens uring children have buffered bike lanes and other bicycle facilities along with pedes trian facilities that
32 Premier T ech Water and T reatment, "S eptic or public s ewer, which is better?," (2023), https ://www.premiertechaqua.com/en-
us /was tewater/s eptic-s ys tem-vs -public-s ewer
33 Univers ity of T ennes s ee, Knoxville, "Rural S chool Was tewater T reatment S ys tem," (2016),
https ://trace.tennes s ee.edu/cgi/viewcontent.cgi?referer=&https redir=1&article=3034&context=utk_chanhonoproj
34 Office of the S uperintendent of Public Ins truction "S chool Walk and Bike Routes : A Guide for Planning and Improving Walk and Bike to
S chool Options for S tudents ," (2015), http://wts c.wa.gov/wp-
content/uploads /dlm_uploads /2014/09/S choolWalkBikeGuide_T echnicalUpdate.pdf
35 Everett J ones S . and S liwa S., Centers for Dis eas e Control, “School Factors As s ociated with the Percentage of S tudents Who Walk or
Bike to S chool, S chool Health Policies and Practices S tudy," (2016), https ://www.cdc.gov/pcd/is s ues /2016/15_0573.htm
36 Was hington S tate Department of T rans portation, "S afe Routes to S chool Program," (2023), https ://ws dot.wa.gov/bus ines s -
ws dot/s upport-local-programs /funding-programs /s afe-routes -s chool-program
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 19
include s idewalks and cros s walks along s chool routes . In turn, thes e bicycle and pedes trian facilities help
"improve pers onal health, wellbeing, and community connection; reduce traffic conges tion; and protect the
environment."37
While s chools in rural s ettings may apply for SRTS grants , urban areas are generally more cons is tent with the
program's objectives and award criteria. 38 It is not clear whether this factor plays a part in decis ion-making
when choos ing between an urban and a rural location.
Motorized trans portation
As the dis tance between s tudent and s chool increas e, the us e of motorized trans portation goes up and
continues to climb with additional dis tance. Having s tudents located clos e to s chools reduces the average
vehicle miles traveled per hous ehold over the lifetime of the facility. Bus ing and motor vehicle traffic create
lifetime cos ts for the project and thus are higher for s chools located at a greater average dis tance from the
s tudent.
S chools located in rural areas are us ually located at a greater average dis tance from s tudent homes compared
to thos e located within urban areas . As a res ult, bus ing expens es can be greater for the dis trict at rural
locations than at urban s ites . It als o can res ult in added parking and drop-off/pick-up facilities . For example, if
the number of non-motorized trips to a s chool were cut in half from 20% to 10%, then a corres ponding 10%
increas e would be needed to accommodate higher motorized trips . This trade-off would likely add s ome
expens es to the rural s ite option vers us a comparable urban option.
T his as s umption may not always be the cas e, as cas e s tudies in Mos es Lake and the Mead S chool Dis trict
indicate that a new s chool located in a rural area may actually reduce reliance on bus ing and pers onal vehicle
trips for a s ignificant number of s tudents . Nevertheles s , s chools s ited in rural areas will res ult in the need for
capital improvement and ongoing road maintenance over the life of the facility. T he King County S chool T as k
Force data s ugges ts a lifetime facility cos t of approximately $1.7 to 2 million per s chool s ited in rural
locations . 39
Factors that affect traffic-mitigation-meas ure cos ts include the need to purchas e right-of-way, the number of
cros s ings , whether traffic s ignals are needed, whether roundabouts are needed, whether electricity needs to be
extended, whether there is a need for curbing. T raffic s peeds tend to be higher along rural roads and thus more
traffic calming mitigation meas ures may be needed in rural s ettings .
S tormwater management
While s ome juris dictions maintain s tormwater utility s ys tems and could require the extens ion of s tormwater
mains at a cos t s imilar to s ewer mains , it is more likely that rural s chools would be required to develop
37 Was hington S tate Department of T rans portation, "T he Pedes trian/Bicyclis t and S afe Routes to S chools Programs : 2023-2025
Prioritized P roject Lis t and Program Update," (2022), https ://ws dot.wa.gov/s ites /default/files /2022-11/2023-2025-Bike-Ped-S RT S-
Priortized-Project-Lis t-Program-Update_0.pdf
38 Was hington S tate Department of T rans portation, "S afe Routes to S chool Program," (2023), https ://ws dot.wa.gov/bus ines s -
ws dot/s upport-local-programs /funding-programs /s afe-routes -s chool-program
39 King County, "King County S chool S iting Tas k Force: Final Report and Recommendations ," (2012),
https ://kingcounty.gov/~/media/depts /executive/performance-s trategy-budget/regional-
planning/GrowthManagement/2012_S choolS itingFinalReportAndRecommendations .as hx?la=en
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 20
s tormwater retention facilities . As s ociated cos ts for thes e type of facilities are es timated at s everal hundred
thous and dollars . 40 41
Proximity to hous ing
It has long been a central planning concept that s chools , es pecially elementary s chools , s erve as one of the
focal points for a neighborhood. 42 43 44
T his nexus between the community and its s chools helps cement the bond between s tudents and their
educational environment, and between the families in the s chool catchment area. It als o helps increas e the
ability of s tudents to participate in extracurricular activities s uch as s ports teams , gifted and talented
programs , dances , plays , and other events . It helps minimize the amount of travel both for thos e biking,
walking, or bus ing to the s chool, and for parents or s tudents driving to the s chool on a regular bas is .
S iting s chools in rural areas can take a toll on community and s tudent connections to the s chool, and can
pres ent a financial burden, es pecially to lower-income hous eholds . For hous eholds s tretched for financial
res ources , this can limit the ability of s ome s tudents and families to participate in activities and fundrais ers or
to afford s upplies and other expens es incurred through the cours e of a s chool year. T rans portation for regular
s chool hours is provided by the bus s ys tem, but after-s chool activities require private trans portation, which can
provide inequitable acces s to thos e opportunities . It may be harder for low-income hous eholds to participate.
S hared us e agreements
It is not uncommon for cities and counties to have s hared us e agreements with s chool dis tricts . T hes e
agreements allow the us e of s chool facilities s uch as ball fields , pools , gymnas iums , auditoriums , and other
facilities for the benefit of the broader community. In s ome locations , s chool s ites are us ed for community
gardens , farmers markets , continuing education, job training, and cultural events .
S hared us e agreements can allow for the s haring of cos ts and ris ks among partners to the agreement, and this
can help reduce the cos t of new facility development for the dis trict. T he exact amount of this cos t impact will
vary greatly and cannot be identified in a precis e way.
While s hared us e agreements with counties may be pos s ible for s chools located in rural areas , the ability for
cities to partner with s chools for s hared us e of facilities is limited in thes e circums tances . T his is becaus e city
boundaries are not allowed to extend pas t the urban growth area and thus rural s chools by definition are not
neces s arily located clos e to nor within cities . In thes e circums tances , the city would likely need to partner with
the county for a s hared us e agreement at a s chool located in the rural area.
40 Environmental Protection Agency, "Cos ts & Benefits of S torm Water BMPs ," (2023), https ://www3.epa.gov/npdes /pubs /us w_d.pdf
41 WGA, "Creative S tormwater Detention Option is Gaining Ground," (2023), https ://wga-llp.com/creative-s tormwater-detention-option-
is -gaining-ground/
42 American Planning As s ociation, American S ociety of Planning Officials , "Neighborhood Boundaries , PAS Report 141," (1960),
https ://www.planning.org/pas /reports /report141.htm
43 Highline Community College, "S ummary Report: Firs t S ummit on S chool Planning and S iting in Was hington," (2007),
https ://web.archive.org/web/20120906001855/https :/www.k12.wa.us /s chfacilities /publications /pubdocs /s ummits chools itingreportm
ay2007.pdf
44 Puget Sound Regional Council, "Vis ion 2050 S chool S iting: implementation Briefing Paper," (2021), VIS ION 2050 S chool S iting
Implementation Briefing Paper (J uly 2021) (ps rc.org)
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 21
T his reduced ability to utilize s chool facilities can take a particular toll on lower-income communities that often
utilize s chool facilities after hours for recreation and educational purpos es . 45 46 47 48
Impact fees
Impact fees are a one-time charge collected from new development to pay for new facilities needed to s erve
that growth. In Was hington, impact fees may be collected for roads , parks , fire, and s chool facilities .
RCW 36.70A.211 (3) s tates that a s chool s ited under this s ection may not collect or impos e the impact fees
des cribed in RCW 82.02.050. T his can s ignificantly affect the ability of the dis trict to pay for the new facility.
Even though a dis trict cannot s olely rely upon impact fees for new facility development, thes e fees can
potentially repres ent a s ignificant portion of the overall cos ts , es pecially if the new s chool is s erving
predominantly new res idential development.
While the total number of dis tricts that currently impos e impact fees is not known, Commerce’s Impact Fee
Deferral Report publis hed in December 2019, indicated s chool impact fees were collected by 54 juris dictions
on behalf of s chool dis tricts . 49 50
T he inability to collect impact fees could be the deciding factor in whether a facility is even feas ible outs ide of
an urban growth area. This could es pecially be the cas e if impact fees are anticipated to cover 25 to 50% of the
cos t of the new s chool.
45 Amelie Ramirez, S alud America!, "Active S paces & Latino Kids Res earch, S hared Us e Agreements ," (2016), https ://s alud-
america.org/active-s paces -latino-kids -res earch-s hared-us e-agreements /
46 Nathan Blackwell, MLT News , "Mountlake T errace council eyes changes to s hared-us e agreements with s chool dis trict," (2021),
Mountlake T errace council eyes changes to s hared-us e agreements with s chool dis trict | MLT news .com
47 ChangeLab S olutions , US DA SNAP funded, "S hared Us e in the S ummer, Opening s chool s paces to the public when clas s es are out,"
(2023), S hared Us e in the S ummer | ChangeLab S olutions
48 HiP Cuyahoga, "S hared Us e Agreement Res ource Guide," (2015), S UARes ourceGuide_Oct2018.pdf (prchn.org)
49 Was hington S tate Department of Commerce, "Impact Fee Deferral Report," (2019), https ://www.commerce.wa.gov/wp-
content/uploads /2020/05/Impact-Fee-Deferral_Final-Report.pdf
50 S teve Butler, Municipal Res earch S ervices Center, "T he Ins and Outs of S chool Impact Fees ," (2018), https ://mrs c.org/s tay-
informed/mrs c-ins ight/january-2018/the-ins -and-outs -of-s chool-impact-fees
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 22
Conclusions on rural school siting
Since 2017, Commerce found only two schools that are sited outside a UGA, served by a new extension of
public facilities or utilities from an urban area, and serve students from both rural and urban areas. During this
period, 183 new schools were sited inside the urban growth area either on newly acquired sites or on existing
land. In addition to these schools, Commerce found two schools sited near the boundaries of or outside of
urban growth areas that exemplify some of the key factors that affect school siting decisions.
To conduct a cost analysis of scho ols sited in rural areas, Commerce conducted additional interviews with
subject matter experts and reviewed the extensive research on school siting in Washington that has been done
to date in order to identify additional factors that may impact the cost of siting schools in rural areas.
This analysis indicated that:
T he total cos t differential needed to favor a s iting decis ion to a rural s ite mus t generally exceed $4.5
million within a half-mile of an urban growth boundary, and over $6 million if over one mile from the UGA.
T his is primarily due to the cos t of water, s ewer, s tormwater, non-motorized trans portation and motorized
trans portation cos ts and impacts . T hes e cos ts are es timated at $1 million or more per mile for water and
s ewer utilities , as well as pedes trian and bike facilities . T hus , each half-mile res ults in at leas t $1.5 million
in s ys tem extens ion cos ts .
Motorized trans portation may increas e the amount of parking/drop-off/pick-up areas by up to 10% adding
a s mall amount to parcel s ize requirements . Ongoing maintenance and upkeep cos ts for the rural s ite will
res ult in impacts over the project timeline of up to $2 million.
it is es timated that s tormwater facilities will cos t up to $1 million more for rural s ettings whether they are
connected to a s torm s ewer s ys tem or utilize on-s ite detention.
Land cos ts in rural areas may be 10% to 50% of a s imilar s ized urban s ite. T his as s umes that the rural s ite
will not have any s ite hazards or encumbrances that reduce its us able portion.
T he need for a s imilar-s ize parcel can be reduced in the urban area if a s chool incorporates approaches like
multi-s tory cons truction with s ubterranean, multi-s tory or s hared parking and acces s . For s ites where an
exis ting s ite is already owned or an exis ting s chool dis trict facility can be renovated or rebuilt, the land cos t
differential takes a hard preference for that location whether urban or rural.
While it is likely that the opportunities for s hared us e agreements may be higher in urban locations , the
impact of this factor on the overall cos t and benefit analys is is indeterminate.
One factor, which very well may be the deciding one, is the ability to collect impact fees for s chools located
within urban growth boundaries . School funding can be difficult and thus the availability of an additional
s ignificant funding option is a powerful tool to favor urban locations .
In places where s chool enrollment continues to grow, s chool dis tricts will continue to find ways to
accommodate their growing s tudent populations , and in particular, due to cons iderations of s ite availability,
cos t and s ize, s chool dis tricts will likely continue to cons ider s ites outs ide of UGAs for new s chools that s erve
s tudents from both rural and urban areas . S ome s trategies that might s upport benefits of an urban s chool
while addres s ing a dis trict's needs may include:
Placing s chool buildings within the UGA and expanding the UGA to allow for s chool fields .
Multi-s tory s chools with attention to careful s ite planning on s maller s ites .
Integrating s chool s ites into new developments .
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 23
Background studies on rural school siting
Discussions about rural school siting have been ongoing throughout the state for many years and past efforts
significantly inform this analysis. The following background highlights past work that can provide the
foundation for the provisions that currently allow communities to extend sewers and urban services to schools
on rural sites that serve students from rural and urban areas.
School summit
In response to the introduction of several bills regarding school siting during the legislative sessions in 2005
and 2006, the Office of the Superintendent of Public Instruction (OSPI) and the Department of Community
Trade and Economic Development (CTED), now the Department of Commerce, held a public forum in 2006
which resulted in a summary report published in February 2007. 51
One of the key is s ues that forum participants rais ed is the difficulty of finding and s ecuring adequate s ites for
new s chool facilities , es pecially within UGAs . However, they als o identified the lack of incentives to cons ider
s maller parcel s izes for s chool s ites . T hey further noted an abs ence of other s trategies that could open more
options within urban areas , s uch as s chools benefiting from s hared us e or joint facilities .
T he forum recommended 11 cons iderations for s iting new s chools :
Fos ter clos e coordination between s chool dis tricts and local government planning bodies to help achieve
the mos t favorable outcomes ;
Cons ider a s tatewide review of impact fees 52 and whether their us e s hould be expanded to cover the full
cos ts of s chool cons truction;
Create an expedited permit review proces s for s chools ;
Create flexibility in zoning and development s tandards (two-s tory buildings , reduced s etbacks , reduced
parking requirements );
Develop model ordinances for co-location and s hared us e of s chool facilities , applicability of flexible
des ign and development s tandards , and model impact fees ;
Develop policies to favor remodeling s chools and encourage s election of infill s ites for new s chools ;
Develop technical as s is tance tools to s upport collaborative s chool s iting;
Es tablis h grant program for rehabilitation of his toric s chools modeled after the s tate’s His toric County
Courthous e Rehabilitation Grant program;
Provide financial incentives for pres ervation, rehabilitation, and/or reus e of his toric s chools ;
Provide financial incentives for s chools s ited ins ide urban growth areas ; and
Provide incentives for infill development.
It is important to note that the recommendations did not repres ent cons ens us among all the participants . 53
51 Highline Community College, "S ummary Report: Firs t S ummit on S chool Planning and S iting in Was hington," (2007),
https ://web.archive.org/web/20120906001855/https :/www.k12.wa.us /s chfacilities /publications /pubdocs /s ummits chools itingreportm
ay2007.pdf
52 Impact fees refer to a one-time fee collected from new development to pay for cos ts as s ociated with that development's increas ed
demand for roads , parks , fire, or s chool facilities . For greater detail, s ee s tatutory definitions outlined by RCW 82.02.090.
53 Highline Community College, "S ummary Report: Firs t S ummit on S chool Planning and S iting in Was hington," (2007),
https ://web.archive.org/web/20120906001855/https :/www.k12.wa.us /s chfacilities /publications /pubdocs /s ummits chools itingreportm
ay2007.pdf
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 24
King County S chool T as k Force
T he King County Growth Management Planning Council convened the King County S chool T as k Force in 2011
to finalize recommendations on s chool s iting to inform updates for the Countywide Planning Policies . T he tas k
force deliberated on is s ues of rural s chool s iting and completed its final report and recommendations in March
2012. The main goal of the tas k force was to evaluate the inventory of rural properties that s chool dis tricts
own and make recommendations for their us e or dis pos ition, according to eight Guiding Principles , which the
tas k force defined as : 54
Academic Excellence: Educational facilities s hould promote and s upport Students ' academic achievement.
Equitable: All children s hould have acces s to quality educational facilities .
Financially S us tainable: S chool s iting s hould be financially s us tainable for each impacted juris diction [and]
make the mos t efficient us e of total tax dollars .
S upport S us tainable Growth: Planning for s chool facilities s hall comply with s tate law and be integrated
with other regional and local planning, including land us e, trans portation, environment, and public health.
Community As s ets : Schools s hould unite the communities in which they are located and be compatible
with community character.
Bas ed on exis ting data and evidence: T he T as k Force proces s s hall utilize recent demographic, buildable
lands inventory, and other relevant data and information.
Public Engagement: T he T as k Force proces s s hould include robus t community engagement with impacted
communities . Meetings will be trans parent and open to the public for obs ervation. T he T as k Force s hall
provide opportunities for public comment.
Bes t Practice and Innovation: Las ting recommendations s hould s erve the region well for years to come and
s upport education, health, environmental, programmatic, fis cal, and s ocial objectives
T he tas k force evaluated 18 s ites as a part of this proces s and found that s everal rural s ites s hould be allowed
to be developed for new s chool facilities with the extens ion of tightline s ewers (s ized s pecifically for the
s chool). 55 T hes e allowances were limited to s ites owned by s chool dis tricts and were located clos e to the
urban growth area. In s ome cas es , the tas k force recommended adjus tment to the urban growth boundary to
incorporate the s chool s tructures within the urban area.
T he tas k force concluded with a recommendation that new s chools predominantly s erving s tudents located
within the urban growth area s hould be located within that boundary. 56
Legis lative T as k Force on S chool S iting 2015
In the 2015 capital budget, 57 Was hington formed a Legis lative T as k Force on S chool S iting to review the is s ue
of s iting s chools ins ide and outs ide of urban growth areas in accordance with the GMA's planning goals and
requirements . T heir s cope included cons ideration of capacity is s ues and infras tructure needs facing s chool
dis tricts and local governments . T he tas k force was als o required to cons ider:
54 King County, "King County S chool S iting Tas k Force: Final Report and Recommendations ," (2012),
https ://kingcounty.gov/~/media/depts /executive/performance-s trategy-budget/regional-
planning/GrowthManagement/2012_S choolS itingFinalReportAndRecommendations .as hx?la=en
55 Law Ins ider, "T ightline S ewer Definition," (2023),
https ://www.lawins ider.com/dictionary/tightline# :~:text=T ightline%20means %20a%20s ewer%20line,a%20particular%20facility%20or%
20place
56 King County, "King County S chool S iting Tas k Force: Final Report and Recommendations ," (2012),
https ://kingcounty.gov/~/media/depts /executive/performance-s trategy-budget/regional-
planning/GrowthManagement/2012_S choolS itingFinalReportAndRecommendations .as hx?la=en
57 2EHB 1115 (2015)
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 25
T rans portation impacts of s chools in urban and rural areas ;
Growth impacts of s chools when they are cons tructed in urban and rural areas ;
T he availability and cos t of public s ervices s uch as water, s ewer, trans portation, law enforcement,
emergency res pons e facilities and s ervices , and other facilities and s ervices in urban and rural areas ; and
Identify s chool locations that provide the mos t financially s us tainable facilities and make the mos t efficient
us e of total tax dollars for all impacted juris dictions .
Upon deliberation, the tas k force came to cons ens us to:
Allow extens ion of urban s ervices s uch as s ewer and water into rural areas , exclus ively to s erve s chools ;
Amend urban growth areas to include new s chool s ites under certain circums tances ;
Clas s ify s chools as "es s ential public facilities " under the Growth Management Act; and
Provide a s afe harbor from litigation for counties , cities , and s chool dis tricts that s ite s chools outs ide of an
urban growth area, and/or require courts and the Growth Management Hearings Board to defer to local
s chool s iting decis ions that meet certain criteria. 58
Clark County Comprehens ive Plan S chool Element 2016
In 2005, CT ED 59 financed a pilot project for s chool dis trict and local government coordination. At that time, the
Clark County Quality S chools T as k Force convened to work on is s ues that included s chool s iting policy. Part of
the res ults of that effort was the development of a unique element in the county’s Comprehens ive Plan
regarding s chools . 60
T he Comprehens ive Plan's S chool Element contains s everal policies regarding the s iting of s chools in rural
areas . Policy 10.2.1 s tates , “S chool facilities s erving predominantly urban populations s hould be preferably
located in urban growth areas then in rural areas adjacent to the urban growth boundary….”
S upplemental policies addres s ed s chools s erving urban s tudents s ited in a rural area:
S chool facilities s hall be located as clos e to the UGA as pos s ible, preferably within a quarter-mile.
Before s iting a s chool facility outs ide the urban growth area, the s chool dis trict s hall demons trate that the
propos ed s ite is more s uitable than alternative s ites within the exis ting urban growth area.
T he s chool dis trict s hall demons trate that the trans portation facilities s erving the s ite are adequate to
s upport s ite-generated traffic, including bus es .
the s chool dis trict s hall agree to connect to public water and s ewer when they become available within 300
feet or les s of the s ite, provided s uch a connection does not neces s itate s pecial facilities (e.g., pump
s tations ) or capital improvements (e.g., larger pipes ) to increas e the capacity of the s ys tem. 61
58 Was hington S tate Legis lature, "Report of the Legis lative T as k Force on S chool S iting," (2015),
https ://leg.wa.gov/J ointCommittees /archive/T FS S /Documents /T FSS _FinalRpt.pdf
59 T he Was hington State Department of Commerce, formerly the Department of Community T rade and Economic Development (CT ED).
60 Clark County "Clark County Comprehens ive Plan S chool Element 2016, Clark County Comprehens ive Plan 2015-35," (2016),
https ://clark.wa.gov/s ites /default/files /dept/files /community-planning/2016-
update/Plan%20Adoption/Comp%20Plan%20T ext/14_S chool%20Element-tc%20vers ion.pdf
61 Clark County "Clark County Comprehens ive Plan S chool Element 2016, Clark County Comprehens ive Plan 2015-35," (2016),
https ://clark.wa.gov/s ites /default/files /dept/files /community-planning/2016-
update/Plan%20Adoption/Comp%20Plan%20T ext/14_S chool%20Element-tc%20vers ion.pdf
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 26
Commerce guidance on rural s chool s iting policy
T he Department of Commerce is s ued guidance on rural s chool s iting in 2017 in res pons e to the adoption of
RCWs 36.70A.211, 36.70A.212, and 36.70A.213. 62 Guidance in the form of frequently as ked ques tions
addres s es points that thes e amendments may rais e for officials from cities , counties , and s chool dis tricts . 63
T he guidance s ets s chool s iting in context within the GMA's encouragement of compact urban growth to limit
s prawl. It affirms that the GMA does not prohibit building s chools on rural s ites , but has largely prohibited
extending certain public s ervices into rural areas . It then des cribes how amendments in 2017 outline s pecific
conditions by which communities may extend s ervices and utilities for s chools in rural areas . 64
Under the current approach, RCW 36.70A.213 requires that each of the following conditions be met prior to
extending public facilities and utilities to a rural s chool s ite that s erves s tudents from rural and urban areas :
S chool dis trict policy in-place: T he s chool dis trict board of directors mus t have adopted a policy
addres s ing educational program requirements , s chool s ervice area and facility needs .
S chool dis trict action to s elect the s ite: T he dis trict mus t find the propos ed s ite to be s uitable for a s chool
and that the s chool (including as s ociated recreational facilities ) cannot reas onably be collocated at an
exis ting s chool s ite.
Concurrence by county and affected cities : T he County and any affected cities mus t agree to the extens ion
of public facilities and utilities for the rural s chool s ite.
Limited extens ion of urban s ervices : If public facilities or utilities are extended beyond the urban growth
area to s erve a s chool, with s ome exceptions , they mus t only s erve the s chool and the s chool dis trict is to
bear the cos t of extens ion bas ed on a reas onable nexus to the s chool's impacts to the area.
Mitigation of impacts : Any impacts as s ociated with the s iting of the s chool mus t be mitigated as required
by the S tate Environmental Policy Act. 65
Pierce County Comprehens ive Plan
Following adoption of RCWs 36.70A.211 and 36.70A.212, which s pecifically apply to Pierce County, the County
amended its Comprehens ive Plan to conform to the new s tatutes . The amendments retained a provis ion
preferring expans ion of exis ting s ites to the creation of new facilities . 66
King County Growth Management Planning Council
Following the adoption of RCWs 36.70A.211, 36.70A.212 and 36.70A.213, King County conducted additional
work to finalize rural s chool s iting recommendations . T his effort has res ulted in the convening of coordination
s es s ions between s chool dis tricts and the county regarding growth plans and the s iting of new s chool
facilities . 67 In addition, the county has identified actions juris dictions can take to facilitate the development
and renovation of s chools within the UGA. T here were 10 actions identified as a res ult of this effort:
62 Was hington S tate Department of Commerce, "T he S iting of School Facilities and the Growth Management Act: 2017 S chool S iting
Law: Frequently As ked Ques tions ," (2018), https ://deptofcommerce.app.box.com/s /prt1n00019b2c2johnnc41kruu6c2312
63 Was hington S tate Department of Commerce, "T he S iting of School Facilities and the Growth Management Act: 2017 S chool S iting
Law: Frequently As ked Ques tions ," (2018), https ://deptofcommerce.app.box.com/s /prt1n00019b2c2johnnc41kruu6c2312
64 Was hington S tate Department of Commerce, "Planning for S chool S iting", (2018), www.commerce.wa.gov/s erving-
communities /growth-management/growth-management-topics /planning-for-s chool-s iting
65 RCW 43.21
66 Pierce County, "Comprehens ive Plan T ext Amendment- Rural S chool Policies : No.891627," (2018),
https ://www.piercecountywa.gov/DocumentCenter/View/75567/S taff-Report---Rural-S chools -891627
67 King county Office of the Executive, "King County GMPC S chool S iting Activities ," (2020),
https ://kingcounty.gov/depts /executive/performance-s trategy-budget/regional-planning/GMPC/S choolS iting.as px
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 27
Identify s urplus public properties that could work as new s chool s ites .
As s is t with identifying private properties that could be available for new s chool s ites .
Look for opportunities for s hared us e of buildings , fields , parking, and other facilities between the city or
county and the s chool dis trict.
Cons ider options and zoning for mixed us e development that could accommodate a s chool.
Inves tigate how regulations and proces s es can be modified to make challenging s ites work for new,
expanded, and renovated s chool facilities (s uch as providing flexible application of development
regulations for height res trictions , maximum lot coverage, and parking s tandards ).
Cons ider the feas ibility of allowing playfields in the Rural Area adjacent to s chools located in the UGA and
with direct acces s from the UGA.
Broaden the number of zone clas s ifications within which s chools are permitted to locate.
Coordinate the permit review proces s to improve certainty for s chool dis tricts and to s horten the permitting
proces s time (us ing priority permitting as appropriate).
Implement a phas ed review of s chool development s o the s chool s ite may be modified as needed over
time and s o portable facilities may be s ited and/or replaced in an efficient manner.
Work with s chool dis tricts , to es tablis h s ite-s pecific trans portation demand management protocols to
encourage more walking, biking, and trans it riders hip to reduce the need for parking.
Partner with s chool dis tricts in the planning and financing needed to improve, if appropriate bas ed on
topography and s urrounding neighborhood characteris tics , walking and biking routes to the s chool.
Puget S ound Regional Council Vis ion 2050
Als o in res pons e to the adoption of s tatewide legis lation regarding rural s chool s iting, the Puget S ound
Regional Council (PS RC) embarked on revis ions to Vis ion 2050, the regional planning framework, to bring it
into conformance with s tate provis ions . Any countywide planning policies mus t be cons is tent with the GMA
goals and the multicounty planning policies embodied in Vis ion 2050. PRSC adopted the following policies :
Work cooperatively with s chool dis tricts to plan for s chool facilities to meet the exis ting and future
community needs cons is tent with adopted comprehens ive plans and growth forecas ts , including s iting and
des igning s chools to s upport s afe, walkable acces s and bes t s erve their communities .
S ite s chools , ins titutions , and other community facilities that primarily s erve urban populations within
urban growth areas in locations where they will promote the local des ired growth plans , except as provided
for by RCW 36.70A.211.
Locate s chools , ins titutions , and other community facilities s erving rural res idents in neighboring cities and
towns and des ign thes e facilities in keeping with the s ize and s cale of the local community, except as
provided for by RCW 36.70A.211.
T he PRS C als o adopted two action s tatements . Specifically, the PRS C committed to:
Initiate and s upport dis cus s ions with the Office of the Superintendent of Public Ins truction to facilitate
updates that modernize s chool s iting s tandards , es pecially thos e related to s ite area requirements .
Updates s hould work to align s chool s iting s tandards with the goals of the Growth Management Act and
facilitate s chool dis tricts ’ ability to better meet urban capacity needs .
Res earch and develop guidance on innovative methods to update regulations and local plans to develop a
regional approach to s chool s iting and to as s is t local juris dictions and s chool dis tricts in s iting new
s chools in urbanized areas .
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 28
T he PSRC publis hed a briefing paper in J uly 2021 announcing the policy changes and giving an update on
actions that had been taken in member counties regarding the is s ue of s chool s iting. 68 T he actions included:
King County’s Comprehens ive Plan calls for locating s chools that primarily s erve s tudents from urban
areas ins ide the Urban Growth Area and commitment to cooperative planning between juris dictions and
s chool dis tricts .
T he Kits ap County Comprehens ive Plan requires des igning s chools to be compatible with the s urrounding
community character and needs . In addition, it calls for locating s chools in Des ignated Centers or near
major trans portation corridors and public trans portation routes . Finally, it talks about S afe Routes to
S chool as a potential s trategy for reducing vehicle trips .
Pierce County’s countywide planning policies call for the county, municipalities , and education s ervice
providers to coordinate planning activities and determining s pecific s ite requirements for all public and
private s chools , with an emphas is on locating in urban areas and compatibility with neighborhood
characteris tics .
T he S nohomis h County Comprehens ive Plan outlines how s chools s hould be primarily located ins ide urban
growth areas and, if not, to allow for urban growth area expans ions if a s ite is adjacent to the exis ting urban
area. T wo policies reference working with s chools to improve public trans portation, walking, and biking.
WAC update 365-196-350
An update to WAC 365-196-350 in early 2023 repres ents the mos t recent changes to how s chools may be s ited
in rural areas . T he rules provide for the extens ion of public facilities and utilities to new s chools s ited in rural
areas that s erve a mix of urban and rural s tudents if certain requirements are met. The rules emphas ize
coordination and concurrence amongs t the various government entities that participate in comprehens ive
planning and provis ion of utilities and s chool s iting. T his includes cities , counties , s chool dis tricts , and other
s pecial dis tricts s uch as s ewer dis tricts . T he updated rules addres s other provis ions to define circums tances
where communities may extend and pay for urban s ervices (s uch as s ewers ) into rural areas for s chools as
well as res idents or other rural properties .
68 Puget Sound Regional Council,"Vision 2050 School Siting: implementation Briefing Paper," (2021), VISION 2050 School Siting
Implementation Briefing Paper (July 2021) (psrc.org)
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 29
Appendix A: Mapping urban growth areas and new
school construction since 2017
Part of Commerce's methodology for identifying schools built outside of UGAs since 2017 that met the other
report criteria was conducting geospatial analysis of Office of the Superintendent of Public Instruction (OSPI)
Inventory and Condition of Schools (ICOS)system data, and a state GISlayer of urban growth areas.
One of the products of that work was a Tableau map visualizing the location of new school construction since
2017, with UGAs overlaid.It is important to note that only schools that voluntarily report to OSPI or receive
School Construction Assistance Program funding are reflected in the ICOS system.
Commerce conducted outreach to schools identified through this analysis that also potentially met t he report
criteria of serving students from both rural and urban areas, and being served by an extension of public
facilities or utilities from an urban area. Additionally, not all of the schools in the ICOS system are new
construction on new sites. Some schools are additions to or replacements of existing schools.
Maps of urban growth areas and schools in Washington
The maps below present UGAs and schools constructed after 2017 by region. The two schools sited outside
the UGA and which meet all report criteria are not annotated in the figures that follow.
Figure A-1. Map of schools built inside and outside of UGAs from 2017 -2023
Schools built from 2017 -2023
Note: Sites include schools in rural areas
whether they receive urban services or not.
Sites include rural schools that do serve
urban students and those that do not.
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 30
Figure A-2. Regional map: Northwest Washington
Schools built from 2017 -2023
Note: Sites include schools in rural areas
whether they receive urban services or not.
Sites include rural schools that do serve urban
students and those that do not.
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 31
Figure A-3. Regional map: Southwest Washington
Schools built from 2017 -2023
Note: Sites include schools in rural areas whether they
receive urban services or not. Sites include rural schools
that do serve urban students and those that do not.
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 32
Figure A-4. Regional map: Northeast Washington
Schools built from 2017 -2023
Note: Sites include schools in rural areas whether they
receive urban services or not. Sites include rural schools
that do serve urban students and those that do not.
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 33
Figure A-5. Regional map: Southeast Washington
Schools built from 2017 -2023
Note: Sites include schools in rural areas whether they
receive urban services or not. Sites include rural schools
that do serve urban students and those that do not.
SCHOOLS OUT SIDE OF URBAN GROWT H AREAS 34
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