Preservation v. church construction

From the Washington Post (a few weeks ago):

"The Montgomery County Council sided with environmentalists instead of church leaders yesterday, voting unanimously to place development limits on federally tax-exempt institutions in the county's 93,000-acre agricultural reserve.

Council members closed a loophole in a 25-year-old policy that had exempted institutions including churches, private schools and day-care centers from a ban on public water and sewer service within the nationally known reserve in northwestern Montgomery."

Put aside (for now) the merits of so-called "smart growth" development restrictions, and also the question whether, under any relevant religious-freedom laws, churches are entitled to exemptions from bans like this.  Here's my question / concern:  Religious freedom requires (doesn't it?) the realistic (i.e., financially realistic) ability to construct and maintain churches and other places of worship.  So, should we worry that, at some point (I do not think we are there yet), a combination of smart-growth restrictions, zoning regulations, historic-preservation rules, sprawl, and NIMBYism will undermine religious freedom by making it increasingly difficult to construct and maintain such places?