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Comprehensive Plans and Climate Justice:
HB 1181 in Action

Have you ever wondered how cities and counties decide what can be built where, which type of projects should be prioritized, and how the jurisdiction will be livable for its residents? The Growth Management Act (GMA) is a state law that requires this work, and it’s really important!

Thirty-three years after it was codified, the GMA finally requires cities and counties to integrate climate change into comprehensive plans! The Front and Centered coalition and supporters have advocated for years to include climate and environmental justice in the GMA. Finally, in the 2023 legislative session, we saw progress on policy. Now, we look forward to 2024 where we anticipate funding frontline communities to advance their planning priorities.

What is the Growth Management Act, and why is it important?

The GMA is a state law that determines how cities and counties plan to manage population growth by dictating what can be built where, which type of projects should be prioritized, and how the jurisdiction will be livable for its residents. When it became law in 1990, the GMA aimed to protect critical areas and ecosystems in our state. But that was over thirty years ago, and the need to reassess this bill’s scope and reach has grown in importance.

At its inception, the GMA failed to contemplate important societal factors that impact where people live or how they get to work, such as displacement rates, the impacts of gentrification, equity, or environmental justice. As a result, comprehensive plans in Washington have lacked adequate consideration and planning to address the current, historical, and ongoing environmental racism that many communities around our state experience, and many comprehensive plans may have done more harm than good.

Front and Centered was engaged in this bill over multiple sessions, and over the course of the last year, coalition members spoke with their communities about comprehensive planning and its impacts on their daily lives to inform how the law would be carried out. Many people reported that they don’t know much about their city’s or county’s planning or how to get involved. What they did share fervently is that they don’t believe their jurisdictions are doing enough to plan for a future that prepares communities for the rapidly growing impacts of the climate crisis.

Comprehensive plans are often a critical, deciding factor in how communities will endure rising heat, floods, fires, and other climate related impacts. However, the existing comprehensive planning process is not accessible or equitable for many people in frontline communities and does not address the disproportionate impacts from climate change and pollution.

Required Elements in Comprehensive Plans
(RCW 36.70A.070)

  • Land Use Element
  • Housing Element
  • Capital Facilities Plan
  • Utilities Element
  • Rural Element
  • Transportation Element
  • Economic Development Element
  • Park and Recreation Element
  • NEW! Climate Change Element (effective date: July 23, 2023)

What is the good news about the Growth Management Act?

Equity in the Housing Element

In 2021, the GMA was updated to require that cities and counties plan for housing that is affordable at all income levels. These updates require identification of the gaps in housing within a planning area, and a plan to remedy these gaps with special attention to consistent and emergency housing for moderate, low, very low, and extremely low-income households.

These changes also require cities and counties to identify and undo local policies and regulations that result in racially disparate impacts, displacement, or exclusionary housing. They also require jurisdictions to create new anti-displacement policies, especially ones that preserve historical and cultural communities and invest in low-income housing.

Currently, the Washington State Department of Commerce is granting out $55.5 million for cities, counties, and utility districts to partner with housing developers supporting affordable housing by paying for water, sewer and stormwater utility improvements and/or waived system development charges for new affordable housing units.

A New Climate Element

Since 2020, Futurewise, Front and Centered, and many others have been working to include climate in the GMA, in a way that addresses environmental justice, including identifying overburdened communities and reducing environmental health disparities. Our work shaped this policy and led to the passage of House Bill 1181 during this last legislative session; the bill was signed by Governor Inslee in May and took effect on July 23.

HB 1181 adds a new Climate Change and Resiliency Element that cities and counties must include in their comprehensive plans. This element is designed not only to reduce overall greenhouse gas emissions, but also to enhance resiliency to and even avoid the adverse impacts of climate change. There are also two sub-elements that are required as part of HB 1181:

  • The greenhouse gas (GHG) emissions reduction sub-element requires jurisdictions to prioritize reductions that maximize the co-benefits of reduced air pollution and environmental justice for overburdened communities in addition to reducing overall GHGs from transportation and land use.
  • The second sub-element requires jurisdictions to identify, protect, and enhance community resiliency and adaptation to climate change impacts consistent with environmental justice.

Olympia, WA (Jan. 2023) — Front and Centered Legislative Advocate Guillermo Rogel Jr. testifies in support of Senate Bill 5203, the Senate version of HB 1181.

Other additions to the GMA include requiring environmental justice considerations in both the land use and transportation elements.

To support these additions, Commerce is required to publish guidelines that specify a set of measures jurisdictions may implement. They must have a demonstrated ability to increase housing capacity in urban areas or reduce greenhouse gas emissions. Crucially, these guidelines must be consistent with the Healthy Environment for All (HEAL) Act and prioritize overburdened communities, but HB 1181’s definition of environmental justice (EJ) does not include the clause in the HEAL Act’s definition of EJ that talks about eliminating harm in all laws, rules, and policies.

Overall, HB 1181 is a necessary addition to the GMA but is not a replacement for addressing environmental justice across comprehensive planning elements.

Our Guidance on the Climate Element and the Climate Uplift Projects

Last year, in anticipation of this change, the legislature directed Commerce to provide cities and counties with guidance and a menu of measures to support the anticipated climate work. As part of the project team, Front and Centered was contracted to ensure overburdened communities were not disproportionately impacted, and ideally benefit.

Front and Centered brought together a community leadership committee to inform Commerce’s measures, and wrote a report included in the Commerce guidance. That report includes an evaluation matrix and topic-specific guidance for jurisdictions to use as they create dynamic and intersectional comprehensive plans that prioritize historically and continuously overburdened communities. The matrix is based on the pillars of a Just Transition, the priority work of our coalition. It is a tool for jurisdictions to use in collaboration with communities to determine if a particular measure maximizes benefits to climate and community. Our recommendation is that the equitability of a measure cannot and should not be determined without insight from the most impacted communities in a planning jurisdiction.

Additionally, our report rejects a “one-size-fits-all” approach to the selection and application of measures. Instead, it recommends that jurisdictions center community voices and priorities and adjust engagement practices based on the needs, perspectives, and realities of frontline community members and the organizations that represent them within the planning jurisdiction.

When the legislature funded Commerce’s work on climate considerations in the GMA, HB 1181 had not passed into law. Now, with the requirements from that bill, Commerce will create additional guidance that cities and counties can use in their next comprehensive plan updates. The legislature allocated $41 million to Commerce to fund the new climate planning requirements; a portion of that money is required to be spent on grants to community-based organizations for advancing participation of vulnerable populations and overburdened communities in the planning process. The agency recently opened a grant process to give cities and counties in Washington State $30 million, and it anticipates granting $5 million for communities to get involved in comprehensive planning in the spring of 2024.

What do our communities still need?

These recent updates are moving the GMA in the right direction, towards equitable comprehensive plans that benefit our state’s environment and most vulnerable populations. However, the GMA can still be improved if it were to require environmental justice in local planning across the state. This year, we advocated for a bill that would have done just that, but we fell one vote short of getting our bill to the floor of the legislature for a vote.

Our bill would have added an environmental justice (EJ) goal to the GMA that would direct jurisdictions to develop and apply fair land use and environmental policies based on respect and justice for all people. Currently, no other GMA goals explicitly address equity or EJ. Likewise, an EJ element would require a cumulative look at the impacts of comprehensive plans to fully understand how these plans—which help shape our communities for decades—impact the health of overburdened communities and vulnerable populations. (The difference between goals and elements in the GMA is that goals are aspirational guidance points, whereas elements are legally binding requirements.)

This EJ element would have gone beyond HB 1181 because it recognizes that certain communities in Washington State have been disproportionately impacted by the placement of polluting facilities, changes in transportation systems, and other land use practices. To undo and prevent further disparity, jurisdictions must identify the overburdened communities and vulnerable populations within their purview and make intentional efforts to understand the cumulative threats these communities are facing, how those issues may be alleviated through land use planning, and how such local communities want to be supported. These efforts should be shaped heavily through collaboration with the overburdened communities through building community capacity and meaningful public participation processes.

What comes next?

The Growth Management Act will continue to be an influential and leading piece of land use legislation in Washington. Our coalition will continue to push that law to better serve the needs of all communities, but especially those who are most and disproportionately impacted by impacts of the climate crisis. Ultimately, it will come down to communities to hold their state and local governments accountable for meeting the goals and elements in their plans an d in their actions.

If you are interested in learning more about your local comprehensive planning, check out this map! It shows when your jurisdiction will next update its plan, and this document tells you whom you can contact get be involved.

If you want to stay up to date on what Front and Centered is doing to advocate for better land use planning in Washington State, sign up to our listserv. Also, you can download translations of the executive summary of Commerce’s guidance—it is available in eight additional languages as per the request of Front and Centered’s members:

Understanding “Overburdened Communities” and “Vulnerable Populations”

Front and Centered generally uses the term “frontline communities” as a descriptor for communities of color, Indigenous peoples, and people with lower incomes who are hit first and worst by environmental damage and climate change. However, terms like Overburdened Communities and Vulnerable Populations are used in law, and their definitions affect which communities are targeted for resource allocation.

Therefore, while we generally avoid words like “vulnerable” and “overburdened” due to the disempowering and othering nature of such labels, they are used throughout this analysis to conform to the language of the law and will remain capitalized to signify that they are both terms of art:

Overburdened Community as defined in HEAL means a geographic area where vulnerable populations face combined, multiple environmental harms and health impacts, and includes, but is not limited to, highly impacted communities.

Additionally, the CCA defines Overburdened Community to include health impacts or risks due to exposure to environmental pollutants or contaminants through multiple pathways, which may result in significant disparate adverse health outcomes or effects. These include Highly Impacted Communities (as used in the Clean Energy Transformation Act), “Indian Country,” and populations who may face disproportionately greater health risks due to exposure to environmental contaminants and pollutants outside of the geographic area in which they reside based on their use of traditional or cultural foods and practices (such as Native Americans and immigrant populations).

Vulnerable Populations are population groups that are more likely to be at higher risk for poor health outcomes in response to environmental harms. Vulnerable populations include, but are not limited to: racial or ethnic minorities; low-income populations; populations disproportionately impacted by environmental harms; and populations of workers experiencing environmental harms.