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Through the 1960s, community and regional planning efforts were generally directed to the accommodation of growth as dictated by market forces. Planning focused on the provision of infrastructure needed to facilitate the continued expansion of urban centers as the market dictated. But a series of closely grouped actions in the early 1970s laid the foundation for the now widely accepted concept of "growth management."
Ramapo, New York, a township about thirty miles north of New York City, established a point system, based on its comprehensive plan policies and linked to its capital improvements program, for determining whether proposed developments could be approved. In upholding this then-novel approach to regulating development, New York's highest court noted that: "The Town … has utilized its comprehensive plan to implement its timing controls and has coupled with restrictions provisions for low and moderate income housing on a large scale. Considered as a whole it represents both in its inception and implementation a reasonable attempt to provide for the sequential, orderly development of land." Golden v. Planning Bd. of Ramapo (1972).