By Eve Goldman | 2.5-minute read
1000 Friends of Oregon recently earned another legal victory—one that helps to ensure that the future growth of Oregon's communities will be based on up-to-date information and a fair public process.
“It goes without saying that decisions about how to grow our cities need to be based in fact,” says Nellie McAdams, executive director of Oregon Agricultural Trust. “The City of North Plains was defending a housing plan that used drastically out-of-date population figures.”
On August 25, 2026, the Land Use Board of Appeals (LUBA), remanded LUBA case no. 2024-044, which was 1000 Friends of Oregon’s appeal of Ordinance No. 489 approving and adopting the City’s proposed updated housing needs analysis (HNA). LUBA’s decision was guided by the City of North Plains’ stipulated motion for voluntary remand, filed at LUBA on August 13. The City’s HNA was initially updated to supplement its sequential urban growth boundary (UGB) expansion proposal, which was ultimately rejected by Washington County on July 16, 2024. The City, however, continued its attempt to update the HNA. 1000 Friends brought this appeal in July 2024.
In its LUBA appeal, 1000 Friends argued in part that the proposed HNA relies on out-of-date population forecasts. Pursuant to Statewide Planning Goal 14 (Urbanization), a UGB expansion must be based on the appropriate 20-year population forecast for the urban area. Population forecasts form the baseline in anticipating the amount of needed housing and employment. Using an up-to-date population forecast is crucial to ensure that the city does not overestimate the amount of land needed to accommodate these figures or commit public funds to unneeded infrastructure.
A local government outside of the Metro boundary must apply the most recent final forecast issued by the Portland State University Population Research Center (PRC), according to OAR 660-032-0020(1). In 2024, the PRC updated the North Plains UGB population forecast as part of its update to Washington County’s population projections. Accordingly, if the City sought to remedy the deficiencies in its adoption of the challenged HNA, it would need to apply the 2024 North Plains population projections to meet Goal 14 requirements. Instead, the City relied on an old population forecast, which projected a larger population increase than the 2024 one, in its continued attempts to update the HNA. 1000 Friends also argued that the City failed to follow applicable procedures, prejudicing 1000 Friends’ substantial rights. The City conferred with 1000 Friends, and on the day the City’s brief was due the City filed a stipulated motion for voluntary remand, withdrawing from the LUBA appeal.
“The residents would have been on the hook for infrastructure costs for this overbuild, and a few landowners would walk away with massive windfalls for selling farmland to developers,” McAdams says. “Developers would get greenfield land cheaper than inside of cities, where there is still space for homes and where workforce housing belongs. And developers don't pass that cost savings on to the buyer; it just pads their profits.”