Build Up, Not Out

UGA Swaps Explained

Do you like trees? Then you should be a big fan of infill housing. That means building up, not out, and putting houses where we’ve already cut down all the trees.

“UGA” stands for Urban Growth Area. An Urban Growth Area is like a belt around a city. The purpose of a UGA is to keep urban sprawl from paving over rural lands and creating endless strip malls. The UGA belt does not aim to halt all development; rather, it seeks to ensure that progress occurs in harmony with farmlands and our natural environment.

Best practices exist for developers to minimize harm to watersheds and agricultural lands while pursuing growth and new housing. Keeping growth inside existing UGAs encourages sustainable approaches that can lead to more resilient and livable communities. By supporting current UGA boundaries, we’re investing in the long-term health and prosperity of our county.

A county and city are generally not allowed to expand the city's UGA, or belt, until the UGA has run out of land to accommodate population growth projections for the next 20 years.

A UGA swap is an exception to this rule. It's supposed to be used to allow minor "adjustments" in one situation only: where the belt is bursting at the seams in one area (because there is not anymore available land in that part of the UGA), while another part of the belt is loose (because there is plenty of undeveloped land in that part of the UGA).

In those cases, if all the other swap law criteria are met, the county can loosen the belt where it's tight so that it surrounds new, undeveloped land and can tighten the belt where it's loose and take out undeveloped land. The county swaps out undeveloped land and swaps in developed land. At the end of the swap, there can't be more land inside the UGA than before and there can't be more development capacity as a result of the swap. ​

That's how it's supposed to work. However, because the law is new, some county commissioners are not understanding all the requirements and are heading toward approving swaps that do not meet legal criteria. ​

The first of these is BAR Holdings. If the commissioners approve the BAR Holdings swap, they will approve others that also violate the law. This puts most rural and natural resource lands in the county at risk of conversion to sprawl.

The BAR Holdings UGA swap would be detrimental to groundwater (including well water), river water, and salmon runs. The forestland on which the developers want to build a mini-city has one of the highest water tables in the county and extremely permeable soil. The aquifer most likely flows into the Deschutes River nearby. Additionally, according to the hydrology report prepared by the county, several important documented springs emerge nearby to feed baseflow in the Deschutes River. Depending on the springs’ capture areas, the flow to these springs has the potential to short-circuit (accelerate) the movement into the river of any contaminants in stormwater, leaks, and spills. Along with contamination risk, there are instream flow impacts. The Deschutes River near these parcels frequently fails to meet Minimum Instream Flows. As with all rivers, adequate streamflows must be maintained for water quality and aquatic habitat. The Deschutes Watershed is classified as “high risk” by Ecology. Yet, stormwater management requirements at the Bar Holdings parcel would possibly further reduce Deschutes River discharges. This would exacerbate the river's already lower-than-required Minimum Instream Flows.         

The project would also put development pressure on surrounding rural and natural resource lands, further impacting the river. This is because extending sewer service to the parcel is a de facto encouragement of land development around the parcel. Many developable parcels south of the proposed site are also very close to the river and would be subject to similar water supply limits, stormwater design limitations/costs, leaks/spills and streamflow reductions. The multiple hydrologic liabilities of the proposal suggest that other locations further from the Deschutes River and closer to existing water/wastewater utility service might be superior development alternatives.

Additionally, the swap would result in a net loss in groundwater protections because the parcels that would be swapped out of the urban growth area near Black Lake have far less permeable soil and/or have a deeper water table compared to the Bar Holdings parcels. Specifically, the BAR Holdings parcel is zoned "Critical Aquifer Resource Area-Extreme" while the parcels that would be swapped out are zoned merely "Critical Aquifer Resource Area-Moderate." 

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The proposal would add unnecessary transportation costs for people who would end up living there. The developers' main selling point is the claim that BAR Holdings would help address the "housing crisis." But transportation is a large part of many household budgets. (Typical American household spends 12% of their budget on transportation.) This development would create housing that is far from services and schools.

Developers claim it would be walkable. But it is walkable to nowhere. And there is no bus-line that goes anywhere close to the location. This would mean that households would need two cars.

Owning a car is expensive and it is not just gas. It is the initial cost, insurance, licensing, maintenance, tires, etc. When people live near services, schools and transit, they can choose to have no car, or only one car. That is a pretty big deal for a household budget.

Locating housing outside of the urban area is also expensive for all of us. We end up paying for the roads, emergency services and school bus transportation. Sprawl eats up land that could be farms. It threatens water resources and bulldozes forests and prairies. Let's be real - sprawl is wasteful and costly.