Comprehensive Plan Update

What this Plan does to the corridor

Clark County is finishing its Comprehensive Plan — the 20-year blueprint, required by state law, that decides how much growth goes where and whether the roads, schools, and services keep up. Adoption is scheduled for October 13. It is a dry, complicated process, and that is part of the problem: almost no one reads it. Here is what it does to this corridor.

A lot of new housing is being pointed this way. Of roughly 103,700 new homes the County must plan for countywide, about 44,000 — 43% — are directed to the unincorporated Vancouver urban growth area and rural county, which includes the 179th Street corridor. The code being written to carry out the Plan goes further than the density limits the Council adopted: on commercial and mixed-use land it removes any cap on density for affordable and supportive housing, so more homes can be built here than the adopted zoning called for.

This is not about who the new neighbors will be. The concern is that the infrastructure was already inadequate, and the Plan adds far more demand without funding it. The County’s own 20-year transportation plan is short about $584.5 million — 36% of what it says it needs. On 179th, only the stretch from the I-5 interchange to NE 29th Avenue is funded; the segment east to NE 50th and the NE 50th roundabout are not, with construction start dates already pushed to 2029, 2031, and 2035 or later. And the developer-commissioned traffic studies show the corridor failing even after the planned roads are assumed built. Schools and utilities are in the same position — identified as inadequate, and not funded to catch up.

There is also a catch most people miss. Allowing commercial and mixed-use land to be built 100% residential means the shops, restaurants, and services many people have been hoping for don’t have to be built at all — and the jobs that would come with them disappear from the very place the Plan is adding people.

That gets to the heart of it. State law does not just require the County to plan for housing. The Growth Management Act requires it to balance housing with jobs, transportation, and the money to pay for it — and to plan in a way that reduces how far people have to drive. This Plan delivers the housing and leaves the rest undone.

Many people would also welcome real walking, biking, and transit options. But the County has confirmed there is no fixed-route transit planned for 179th, the sidewalks are missing or disconnected, and there is no funding to build them — so those choices are not coming any time soon.

The details

The specific findings behind the summary above, drawn from the County’s own draft chapters, appendices, and work session materials. These points were submitted to the County Council for the record in three documents on July 18, July 19, and July 21, 2026.

• 44,000 units, 43% of the county’s total. Of roughly 103,700 new housing units countywide, about 44,000 are directed to the unincorporated Vancouver urban growth area and rural county — the share the County itself must site, since the cities plan their own. The majority falls in income bands at or below 80% of area median income.
• The allocation is driven by vacant land, not by the Plan’s own policies. Growth is placed by a land-capacity model, which identifies where vacant land exists. Every element of the Plan that addresses the question — Land Use, Housing, Community Design, Economic Development, Climate — directs higher density to transit corridors, employment centers, and areas already served by urban infrastructure, and calls for less intensity where urban services do not yet exist. The GMA requires a comprehensive plan to be internally consistent.
• The code removes the ceiling. Commercial and mixed-use land can be built 100% residential under a full exception for qualifying affordable projects; there is no maximum density for affordable, transitional, or permanent supportive housing in Mixed Use; and off-street parking minimums drop to 0.5 spaces per unit or disappear entirely for affordable and senior housing and any dwelling under 1,200 square feet.
• Removing parking assumes alternatives that do not exist here. Rural roads, many without shoulders. Sidewalks missing or disconnected. No fixed-route transit planned. Households will still own the cars; there will simply be nowhere to put them.
• The roads are funded only as far as NE 29th. Funded work on 179th runs from the I-5 interchange about a mile east to NE 29th Avenue. The segment on to NE 50th, and the NE 50th roundabout, are not funded. Construction start dates have slipped to 2029, 2031, and 2035 or later — and those are start dates, so completion runs well into the 2030s.
• The failures survive the improvements. The developer-commissioned traffic studies for corridor projects model the network as built out — after the planned improvements are assumed complete — and still show volume-to-capacity failures.
• The $584.5 million gap is a floor, not a ceiling. Costs are stated in constant 2026 dollars with no inflation applied over 20 years, while revenue is escalated across the same period. Comparing frozen costs against grown revenue understates the shortfall.
• The gap is growing, not shrinking. From about $158 million (23%) in 2016 to about $584.5 million (36%) in this draft — against a prior commitment to close it.
• The funding options do not close it. A one-percent road levy increase yields roughly $450,000 to $460,000 a year; a transportation benefit district roughly $3.4 to $3.9 million; a local-option gas tax requires a public vote. About $7 million a year, against a shortfall concentrated in 2032–2045.
• The Road Fund runs out of capital around 2038. The County’s own long-term trends exhibit shows funds available for capital falling from roughly $15 million toward zero by about 2038 — the same years the corridor projects are scheduled. Appendix A nonetheless books about $42.7 million of Road Fund capital revenue for 2032–2045.
• The largest revenue line needs a match that will not exist. Grants account for about $426.3 million, roughly 42% of projected revenue, with $339.8 million assumed for 2032–2045. Competitive grants require local match, and the Road Fund is the match source. Remove grants from the projection and the shortfall becomes about $1.01 billion.
• No project carries a cost. Every project in the Appendix A tables has a blank Project Cost Estimate column and a blank Priority column, so the $1.6 billion expenditure total has no disclosed derivation from the project list.
• The financing plan disagrees with itself by $535 million. Appendix G’s executive summary table states six-year expenditures of $1,116,361,138; its own financial plan summary states $580,858,481. Same six-year plan, two totals. Appendix A and Appendix G also state the six-year transportation program about $3.8 million apart.
• The only performance table is physically impossible. Table 5.10 reports 768,505 vehicle-miles traveled against 1,172,620 vehicle-hours traveled — an average network speed of about 0.66 miles per hour. It is also not stated as the annual per-capita figure the statute requires, so the Plan contains no valid measurement of whether it raises or lowers driving.
• No transit is planned, and the one line that exists ends south of here. The Regional Transportation Council has confirmed no fixed-route service is planned for NE 179th Street. C-TRAN’s Vine Purple Line, scheduled to open in 2027, terminates at WSU Vancouver; this housing sits well north of that terminus, and the connecting roads and pedestrian network are not built out. Park-and-ride capacity at Salmon Creek is being reduced from 462 stalls to 365.
• The errand trips concentrate on Salmon Creek. Daily-needs shopping is clustered along NE 10th and NE 20th Avenues and NE 134th and NE 139th Streets. New housing on the 179th corridor carries no co-located commercial of its own, so every routine trip funnels onto those same roads. The County’s own chronology documents emergency development moratoria in that area between 2001 and 2006 because capacity could not keep pace — and today Salmon Creek Interchange Phase 2 (about $35 million) is excluded from the funding analysis, while the NE Salmon Creek Avenue realignment is reported rescinded in RTC’s July 2026 project obligation status report.
• Jobs are moving the wrong way. HB 1181 requires the Plan to reduce per-capita driving. The City of Vancouver told the County on the record in November 2024 that meeting that target is likely impossible without co-located employment. Converting commercial and mixed-use land to housing removes the jobs the corridor would need to comply.
• Parks are not keeping up. The Parks element sets a standard of six acres per 1,000 residents and already documents a deficit against it. Required on-site amenity for multifamily has been cut to 5% of developable area, up to half of which can be satisfied by balconies and patios as small as 48 square feet, and the Plan’s definition of open space counts stormwater ponds and unimproved buffers.
• Schools are running on 2022 plans. Five districts are carried forward on capital facilities plans drawn before this density was authorized. By the districts’ own figures, 92% to 96% of new school capacity is paid for with public money rather than impact fees.
• $739 million of ADA sidewalk and curb-ramp deficiency, with no identified funding. About 5,784 curb ramps at $7,340 each, and 2,239,604 linear feet of missing sidewalk at $311 per foot. The only traceable sidewalk line in Appendix A is a superseded $500,000 per year stated in 2014 dollars.
• Adoption on a record no one has seen. Cost estimates were still being refined, preferred-alternative model results were not yet available, and several capital facilities plans had not been received — yet the package goes to the Department of Commerce to start the 60-day clock. Whatever gets finished at the end goes forward without the Council reviewing it in an open session or the public seeing it.

Why the Comp Plan matters for transportation

The Comprehensive Plan is where the County decides how much development to allow and how much infrastructure to build. The concurrency code — the rule that’s supposed to keep those two things in balance — only works if the plan behind it is realistic.

Right now, the plan isn’t realistic. The County selected Preferred Alternative 2 in April, increasing density in corridors where developer-commissioned traffic studies already show the roads failing. The developer’s own traffic engineer identified 22 corridors exceeding the V/C 0.90 standard — almost all in Salmon Creek/Fairgrounds and SR-503/Brush Prairie. Infrastructure promised in 2019 is years behind schedule. The six-year GMA deadline passed in November 2025 with no major corridor projects complete.

And by the County’s own numbers, the money to build the roads isn’t there. The transportation plan presented for this week’s Council work sessions shows a 20-year funding gap of at least $585 million — and likely more, because the cost estimates aren’t final. Even that figure already assumes hundreds of millions of dollars in state and federal grants that are far from guaranteed, plus impact fees that only materialize if this kind of development keeps getting approved.

The transportation and capital facilities chapters were taken up at the July work sessions, and the comments above are in the record on them. The Plan itself is not adopted until October. Written comments go on the permanent record and must be considered before adoption.

Key dates

Work sessions are open to the public but do not include verbal public comment. Written testimony is accepted at any time and goes on the permanent record. Transportation sessions are highlighted below.

County Council work sessions

Wednesdays, typically 9:00 AM, 6th floor Public Service Center (1300 Franklin St.) or via Webex

Date	Topics
June 10	Community Framework, Environment, Parks, Historic, Economic Development, Schools, Community Design, Annexation, Shoreline, Climate
July 1	Transportation chapter, project list, and evaluation criteria (moved from June 24); Land Use, Housing, Rural, Mobile Home code
July 15	Transportation appendix, Capital Facilities Plan chapter and appendix, Capital Facilities Financial Plan
July 22	Housing and transportation development code changes, Introduction, Procedural chapters
July 29	School and fire district capital facility plans, impact fees

Planning Commission work sessions

Thursdays, 5:30 PM, 6th floor training room or via Webex

Date	Topics
June 18	Introduction, Land Use, Rural, Procedural
July 2	Schools, Housing, Transportation, project list, evaluation criteria
July 16 (5:30 PM)	Transportation appendix, Capital Facilities
July 16 (6:30 PM)	Planning Commission hearing — School and Fire Impact Fees
July 30	Additional appendices

Adoption timeline

Date	Milestone
July 24	Final EIS issued; documents submitted to Commerce for 60-day review
Aug 6	Planning Commission work session
Aug 20	Planning Commission hearing (Comp Plan text, Title 40, Capital Facilities)
Sep 3	Planning Commission deliberation
Sep 16	Council work session
Oct 6	Council hearing and deliberation
Oct 13	Council adoption (Final Ordinance)
Oct 23	Notice of adoption — triggers 60-day GMA appeal period

Full schedule: County project timeline (PDF) →

What to say about transportation

You don’t need to be an engineer. You live here, you drive these roads, and you can read a traffic study. Here are specific points you can raise in written comments. Use your own words — personal comments carry more weight than form letters.