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13-24 THE LAW OF ZONING AND PLANNING § 13.04 • are phased in relation to more intensive uses according to compre- hensive plan directives.3 Review of subdivisions and/or planned unit develInopmentsthe may also incorporate adequacy considerations for public and/or privately-provided facilities and services.' [2] Downzoning growth management context, downzonings in outlying areas can promote infill development and the more efficient provi- sion of services within urban use classifications.This technique often raises legal concerns regarding the relationship of the proposed change to surrounding land uses and to the locality's comprehensive plan.'An areawide effort is more likely to be upheld than parcel by parcel or small area change.? Downzoning for industrial develop- ment purposes may be permissible.' However, in some states, resi- dential downzoning may be successfully challenged on the basis of 3 See§ 13.04[3],infra. 4 See§§ 13.04[4], [5];§65.02 infra. • S See§§27.02[3),[4],supra.See generally Williamson,"Constitutional and Judicial Limitations on the Community's Power to Downzone," 12 Urb. Law. 157 (1980). ' See §22.02[4], [5].See,e.g.,Carty v. Ojai,77 Cal. App.3d 329, 143 Cal.Rptr. 506(1978)(commercial downzoning consistent with comprehensive plan);Norbeck . Village Joint Venture v. Montgomery County Council, 254 Md. 54, 254 A.2d 700 (1969) (comprehensive downzoning in residential districts consistent with compre- hensive plan); Udell v. Haas, 21 N.Y.2d 463, 235 N.E.2d 897 (1968) (invalidating downzoning not in accordance with local comprehensive plan);Culver v.Dagg,20 Or. App.647,532 P.2d 1127(1975)(plan-based comprehensive downzoning);Williamson, supra N.5,at 159, 164-65;Mandelker,"The Role of the Local Comprehensive Plan in Land Use Regulation,"74 Mich. L. Rev. 899, 920-24,937-38(1976). 7 See,e.g.,Steel Hill Dev.,Inc.v.Town of Sanbornton,469 F.2d 956(1st Cir.1972) (downzoning cluster and conventional homes sustained in light of surrounding un- developed forest lands);Taco Bell v.City of Mission,678 P.2d 133(Kan. 1984)(selec- tive downzoning of fast food restaurants was arbitrary and capricious);McGowan v. Cohalan, 41 N.Y.2d 434, 361 N.E2d 1022 (1977) (downzoning from industrial to residential conformed to surrounding uses);Williamson,supra N. 1,at 160-61. S See, e.g., Poletown Neighborhood Council v. City of Detroit, 410 Mich. 616, 630-33,304 N.W.2d 455,458-59(1981)(downzoning residential area to accommodate plan expansion);Fritts v.City of Ashland,348 S.W.2d 712,713-14(Ky.1961)(rejecting downzoning of four-acre tract in residential district to establish a garment factory); Smith v. Skagit County, 453 P.2d 832 (Wash. 1969) (increase in tax ratables and employment from industrial development held insufficient to justify rezoning a large portion of an island from residential and recreational uses). • j