Revised Code of Washington

Wash. Rev. Code § 36.70A.020 (2026)

Planning goals

✓ current as of May 2026

Find cases: SyfertCases citing this section WA-LEGapp.leg.wa.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

The following goals are adopted to guide the development and adoption of comprehensive plans and development regulations of those counties and cities that are required or choose to plan under RCW 36.70A.040 and, where specified, also guide the development of regional policies, plans, and strategies adopted under RCW 36.70A.210 and chapter 47.80 RCW. The following goals are not listed in order of priority and shall be used exclusively for the purpose of guiding the development of comprehensive plans, development regulations, and, where specified, regional plans, policies, and strategies:

(1) Urban growth. Encourage development in urban areas where adequate public facilities and services exist or can be provided in an efficient manner.

(2) Reduce sprawl. Reduce the inappropriate conversion of undeveloped land into sprawling, low-density development.

(3) Transportation. Encourage efficient multimodal transportation systems that will reduce greenhouse gas emissions and per capita vehicle miles traveled, and are based on regional priorities and coordinated with county and city comprehensive plans.

(4) Housing. Plan for and accommodate housing affordable to all economic segments of the population of this state, promote a variety of residential densities and housing types, and encourage preservation of existing housing stock.

(5) Economic development. Encourage economic development throughout the state that is consistent with adopted comprehensive plans, promote economic opportunity for all citizens of this state, especially for unemployed and for disadvantaged persons, promote the retention and expansion of existing businesses and recruitment of new businesses, recognize regional differences impacting economic development opportunities, and encourage growth in areas experiencing insufficient economic growth, all within the capacities of the state's natural resources, public services, and public facilities.

(6) Property rights. Private property shall not be taken for public use without just compensation having been made. The property rights of landowners shall be protected from arbitrary and discriminatory actions.

(7) Permits. Applications for both state and local government permits should be processed in a timely and fair manner to ensure predictability.

(8) Natural resource industries. Maintain and enhance natural resource-based industries, including productive timber, agricultural, and fisheries industries. Encourage the conservation of productive forestlands and productive agricultural lands, and discourage incompatible uses.

(9) Open space and recreation. Retain open space and green space, enhance recreational opportunities, enhance fish and wildlife habitat, increase access to natural resource lands and water, and develop parks and recreation facilities.

(10) Environment. Protect and enhance the environment and enhance the state's high quality of life, including air and water quality, and the availability of water.

(11) Citizen participation and coordination. Encourage the involvement of citizens in the planning process, including the participation of vulnerable populations and overburdened communities, and ensure coordination between communities and jurisdictions to reconcile conflicts.

(12) Public facilities and services. Ensure that those public facilities and services necessary to support development shall be adequate to serve the development at the time the development is available for occupancy and use without decreasing current service levels below locally established minimum standards.

(13) Historic preservation. Identify and encourage the preservation of lands, sites, and structures, that have historical or archaeological significance.

(14) Climate change and resiliency. Ensure that comprehensive plans, development regulations, and regional policies, plans, and strategies under RCW 36.70A.210 and chapter 47.80 RCW adapt to and mitigate the effects of a changing climate; support reductions in greenhouse gas emissions and per capita vehicle miles traveled; prepare for climate impact scenarios; foster resiliency to climate impacts and natural hazards; protect and enhance environmental, economic, and human health and safety; and advance environmental justice.

(15) Shorelines of the state. For shorelines of the state, the goals and policies of the shoreline management act as set forth in RCW 90.58.020 shall be considered an element of the county's or city's comprehensive plan.

[ 2023 c 228 s 1; 2021 c 254 s 1; 2002 c 154 s 1; 1990 1st ex.s. c 17 s 2.]

Notes:

For a 14th goal: See RCW 36.70A.480.

Notes of Decisions

Cited in 154 cases (6 in the last 5 years), 1993–2026 · leading case: Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011).

Sort: Relevance Newest Treatment

Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011). · cites it 24× “The GMA specifically allows counties to consider local circumstances when planning this element, providing that [b]ecause circumstances vary from county to county, in establishing patterns of rural densities and uses, a county may consider local circumstances, but shall develop…”

King Cnty. v. Cent. Puget Sound, 14 P.3d 133 (Wash. 2000). · cites it 11× “Despite the fact the statute specifically states its goals "are not listed in order of priority," RCW 36.70A.020, the majority concludes a county's duty to conserve agricultural land is a higher priority than creating recreational facilities, in essence making meaningless other…”

King Cnty. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 142 Wash. 2d 543 (Wash. 2000). · cites it 10× “Despite the fact the statute specifically states its goals “are not listed in order of priority,” RCW 36.70A.020, the majority concludes a county’s duty to conserve agricultural land is a higher priority than creating recreational facilities, in essence making meaningless other…”

City of Redmond v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 959 P.2d 1091 (Wash. 1998). · cites it 8× “See RCW 36.70A.020(1) (Urban growth) and (2) (Reduce sprawl).”

Whatcom Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 381 P.3d 1 (Wash. 2016). · cites it 8× “” RCW 36.70A.020. Read collectively, these goals convey some conceptual guidance for growth management.”

Lewis Cnty. v. W. Wa. Growth Mgmt. Hearings Bd., 139 P.3d 1096 (Wash. 2006). · cites it 6× “RCW 36.70A.020; WAC 365-195-070(1). ¶ 32 The GMA was to be a "bottom-up" approach, allowing local cities and counties the authority to make decisions based on their local needs in order to harmonize and balance the 13 statewide planning goals.”

Clallam Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 130 Wash. App. 127 (Wash. Ct. App. 2005). · cites it 11× “RCW 36.70A.020. One of these goals is to “[m]aintain and enhance natural resource-based industries, including productive .”

Quadrant Corp. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 154 Wash. 2d 224 (Wash. 2005). · cites it 4× “” RCW 36.70A.020 (emphasis added). Additionally, while the GMA goals “collectively convey some conceptual guidance for growth management,” the GMA “explicitly denies any order of priority among the thirteen goals” and it is evident that “some of them are mutually competitive.”

Quadrant Corp. v. State, Growth Mgmt. Hearings Bd., 110 P.3d 1132 (Wash. 2005). · cites it 4× “" *1144 RCW 36.70A.020 (emphasis added). Additionally, while the GMA goals "collectively convey some conceptual guidance for growth management" the GMA "explicitly denies any order of priority among the thirteen goals" and it is evident that "some of them are mutually…”

Viking Props., Inc. v. Holm, 118 P.3d 322 (Wash. 2005). · cites it 5× “RCW 36.70A.020. These goals include, inter alia, encouraging development within urban areas, reducing the conversion of undeveloped land into low-density development, retaining open space, protecting the environment, and protecting private property rights.”

Thurston Cnty. v. Cooper Point Ass'n, 57 P.3d 1156 (Wash. 2002). · cites it 4× “RCW 36.70A.020; WAC 365-195-070(1). *1165 A number of goals would be furthered by installing the four-inch sewer line to replace the existing obsolete treatment facilities before they fail and spill pollution into Puget Sound.”

Swinomish Indian Tribal Cmty. v. W. Washington Growth Mgmt. Hearings Bd., 161 Wash. 2d 415 (Wash. 2007). · cites it 6× “” RCW 36.70A.020. ¶11 The lack of priority in the planning goals becomes especially problematic when local governments are faced with land that qualifies as both agricultural land and as a critical area (for example, a parcel of agricultural land that abuts a water source).”

Show all 154 citing cases →

— Wash. Rev. Code § 36.70A.020(1) — 30 cases

City of Redmond v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 959 P.2d 1091 (Wash. 1998). “See RCW 36.70A.020(1) (Urban growth) and (2) (Reduce sprawl).”

City of Arlington v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 193 P.3d 1077 (Wash. 2008).

City of Arlington v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 164 Wash. 2d 768 (Wash. 2008).

Thurston Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 164 Wash. 2d 329 (Wash. 2008).

Thurston Cnty. v. W. Wash. Growth Mgmt., 190 P.3d 38 (Wash. 2008).

— Wash. Rev. Code § 36.70A.020(10) — 18 cases

Whatcom Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 381 P.3d 1 (Wash. 2016). “” RCW 36.70A.020. Read collectively, these goals convey some conceptual guidance for growth management.”

Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011). “The GMA specifically allows counties to consider local circumstances when planning this element, providing that [b]ecause circumstances vary from county to county, in establishing patterns of rural densities and uses, a county may consider local circumstances, but shall develop…”

Swinomish Indian Tribal Cmty. v. W. Washington Growth Mgmt. Hearings Bd., 161 Wash. 2d 415 (Wash. 2007). “” RCW 36.70A.020. ¶11 The lack of priority in the planning goals becomes especially problematic when local governments are faced with land that qualifies as both agricultural land and as a critical area (for example, a parcel of agricultural land that abuts a water source).”

Whatcom Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 344 P.3d 1256 (Wash. Ct. App. 2015).

Swinomish Indian Tribal Cmty. v. Dep't of Ecology, 311 P.3d 6 (Wash. 2013).

— Wash. Rev. Code § 36.70A.020(11) — 13 cases

City of Redmond v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 959 P.2d 1091 (Wash. 1998). “See RCW 36.70A.020(1) (Urban growth) and (2) (Reduce sprawl).”

1000 Friends of Washington v. McFarland, 149 P.3d 616 (Wash. 2006).

1000 Friends v. McFarland, 159 Wash. 2d 165 (Wash. 2006).

Advocates for Responsible Dev. v. W. Washington Growth Mgmt. Hearings Bd., 230 P.3d 608 (Wash. Ct. App. 2010).

Chevron U.S.A., Inc. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 156 Wash. 2d 131 (Wash. 2005).

— Wash. Rev. Code § 36.70A.020(12) — 11 cases

James v. Cnty. of Kitsap, 115 P.3d 286 (Wash. 2005).

James v. Kitsap Cnty., 154 Wash. 2d 574 (Wash. 2005).

Whatcom Fire Dist. No. 21 v. Whatcom Cnty., 256 P.3d 295 (Wash. 2011).

Whatcom Cnty. Fire Dist. No. 21 v. Whatcom Cnty., 171 Wash. 2d 421 (Wash. 2011).

City of Redmond v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 65 P.3d 337 (Wash. Ct. App. 2003).

— Wash. Rev. Code § 36.70A.020(15) — 1 case

One Energy Dev., LLC v. Kittitas Cnty. (Wash. Ct. App. 2019).

— Wash. Rev. Code § 36.70A.020(2) — 20 cases

Quadrant Corp. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 154 Wash. 2d 224 (Wash. 2005). “” RCW 36.70A.020 (emphasis added). Additionally, while the GMA goals “collectively convey some conceptual guidance for growth management,” the GMA “explicitly denies any order of priority among the thirteen goals” and it is evident that “some of them are mutually competitive.”

Quadrant Corp. v. State, Growth Mgmt. Hearings Bd., 110 P.3d 1132 (Wash. 2005). “" *1144 RCW 36.70A.020 (emphasis added). Additionally, while the GMA goals "collectively convey some conceptual guidance for growth management" the GMA "explicitly denies any order of priority among the thirteen goals" and it is evident that "some of them are mutually…”

Thurston Cnty. v. Cooper Point Ass'n, 57 P.3d 1156 (Wash. 2002). “RCW 36.70A.020; WAC 365-195-070(1). *1165 A number of goals would be furthered by installing the four-inch sewer line to replace the existing obsolete treatment facilities before they fail and spill pollution into Puget Sound.”

Thurston Cnty. v. Cooper Point Ass'n, 148 Wash. 2d 1 (Wash. 2002).

Thurston Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 164 Wash. 2d 329 (Wash. 2008).

— Wash. Rev. Code § 36.70A.020(3) — 3 cases

City of Des Moines v. Puget Sound Reg'l Council, 988 P.2d 27 (Wash. Ct. App. 1999).

Miotke v. Spokane Cnty., 325 P.3d 434 (Wash. Ct. App. 2014).

City of Des Moines v. Puget Sound Reg'l Council, 108 Wash. App. 836 (Wash. Ct. App. 1999).

— Wash. Rev. Code § 36.70A.020(4) — 6 cases

Manufactured Hous. Communities v. State, 13 P.3d 183 (Wash. 2000).

Low Income Hous. Inst. v. City of Lakewood, 77 P.3d 653 (Wash. Ct. App. 2003).

Paul Stickney & Stefan Birgh, Apps. v. Cent. Puget Snd Growth Mgmt. Hearings Bd., Res. (Wash. Ct. App. 2019).

Summit Waller Cmty. Ass'n v. Pierce Cnty. (Wash. Ct. App. 2019).

Low Income Hous. Inst. v. City of Lakewood, 77 P.3d 653 (Wash. Ct. App. 2003).

— Wash. Rev. Code § 36.70A.020(5) — 5 cases

Clark Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 161 Wash. App. 204 (Wash. Ct. App. 2011).

Clark Cnty. v. W. Wash. Growth Mgt., 254 P.3d 862 (Wash. Ct. App. 2011).

Summit Waller Cmty. Ass'n v. Pierce Cnty. (Wash. Ct. App. 2019).

Neighbors Against Annexation v. Snohomish Cnty. Boundary Review Bd. (Wash. Ct. App. 2018).

— Wash. Rev. Code § 36.70A.020(6) — 15 cases

Clallam Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 130 Wash. App. 127 (Wash. Ct. App. 2005). “RCW 36.70A.020. One of these goals is to “[m]aintain and enhance natural resource-based industries, including productive .”

City of Redmond v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 959 P.2d 1091 (Wash. 1998). “See RCW 36.70A.020(1) (Urban growth) and (2) (Reduce sprawl).”

Viking Props., Inc. v. Holm, 118 P.3d 322 (Wash. 2005). “RCW 36.70A.020. These goals include, inter alia, encouraging development within urban areas, reducing the conversion of undeveloped land into low-density development, retaining open space, protecting the environment, and protecting private property rights.”

Olympic Stewardship Found. v. W. Washington Growth Mgmt. Hearings Bd., 166 Wash. App. 172 (Wash. Ct. App. 2012).

Olympic Stewardship v. Wash. Growth Mgmt., 274 P.3d 1040 (Wash. Ct. App. 2012).

— Wash. Rev. Code § 36.70A.020(7) — 1 case

City Of Tukwila v. Sleeping Tiger (Wash. Ct. App. 2013).

— Wash. Rev. Code § 36.70A.020(8) — 34 cases

King Cnty. v. Cent. Puget Sound, 14 P.3d 133 (Wash. 2000). “Despite the fact the statute specifically states its goals "are not listed in order of priority," RCW 36.70A.020, the majority concludes a county's duty to conserve agricultural land is a higher priority than creating recreational facilities, in essence making meaningless other…”

King Cnty. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 142 Wash. 2d 543 (Wash. 2000). “Despite the fact the statute specifically states its goals “are not listed in order of priority,” RCW 36.70A.020, the majority concludes a county’s duty to conserve agricultural land is a higher priority than creating recreational facilities, in essence making meaningless other…”

City of Redmond v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 959 P.2d 1091 (Wash. 1998). “See RCW 36.70A.020(1) (Urban growth) and (2) (Reduce sprawl).”

Lewis Cnty. v. W. Wa. Growth Mgmt. Hearings Bd., 139 P.3d 1096 (Wash. 2006). “RCW 36.70A.020; WAC 365-195-070(1). ¶ 32 The GMA was to be a "bottom-up" approach, allowing local cities and counties the authority to make decisions based on their local needs in order to harmonize and balance the 13 statewide planning goals.”

Whidbey Env't Action Network v. Island Cnty., 93 P.3d 885 (Wash. Ct. App. 2004).

— Wash. Rev. Code § 36.70A.020(9) — 12 cases

Stevens Cnty. v. Futurewise, 192 P.3d 1 (Wash. Ct. App. 2008).

Isla Verde Int'l Holdings, Inc. v. City of Camas, 49 P.3d 867 (Wash. 2002).

— Wash. Rev. Code § 36.70A.020(l) — 3 cases

Brinnon Grp. v. Jefferson Cnty., 159 Wash. App. 446 (Wash. Ct. App. 2011).

Quadrant Corp. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 81 P.3d 918 (Wash. Ct. App. 2003).

Jerry Harless v. Cent. Puget Sd. Growth Mgmt. Hrgs Bd. (Wash. Ct. App. 2019).

— Wash. Rev. Code § 36.70A.020(l1) — 1 case

Spokane Cnty. v. E. Washington Growth Mgmt (Wash. Ct. App. 2015).

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.