The question of whether and how to control growth has come to the fore in the last several years as one of the broadest and most serious environmental issues facing the United States.¹ In the area of land use, this abstract question reduces to the dilemma of managing or controlling the rapid and chaotic development at the perimeters of metropolitan centers that has drastically reshaped the face of our nation since 1945.

Can a small city located within a larger metropolitan region and threatened with strong market pressures for development act to limit numerically its rate of growth? Or must it instead accept all who wish to live there, no matter what the environmental, social and energy costs associated with the resulting "sprawl?" On August 13, 1975, the Ninth Circuit Court of Appeals became the latest court to venture into the constitutional thicket surrounding these questions as it reversed a lower court and upheld a five-year housing and growth limitation plan adopted by the city of Petaluma, Californial.²