Revised Code of Washington

Wash. Rev. Code § 36.70A.103 (2026)

State agencies required to comply with comprehensive plans

✓ current as of May 2026
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State agencies shall comply with the local comprehensive plans and development regulations and amendments thereto adopted pursuant to this chapter except as otherwise provided in RCW 71.09.250 (1) through (3), 71.09.342, and 72.09.333.
The provisions of chapter 12, Laws of 2001 2nd sp. sess. do not affect the state's authority to site any other essential public facility under RCW 36.70A.200 in conformance with local comprehensive plans and development regulations adopted pursuant to chapter 36.70A RCW.
[ 2002 c 68 s 15; 2001 2nd sp.s. c 12 s 203; 1991 sp.s. c 32 s 4.]

Notes:

PurposeSeverabilityEffective date2002 c 68: See notes following RCW 36.70A.200.
IntentSeverabilityEffective dates2001 2nd sp.s. c 12: See notes following RCW 71.09.250.
Notes of Decisions
Cited in 9 cases, 2008–2019 · leading case: Residents Opposed Turbines v. State Efsec, 197 P.3d 1153 (Wash. 2008).
Residents Opposed Turbines v. State Efsec, 197 P.3d 1153 (Wash. 2008). · cites it 2× “The legislature amended the GMA in 2002 to recognize the importance of protecting rural lands and economies. RCW 36.70A.011. The GMA requires that "[s]tate agencies shall comply with the local comprehensive plans and development regulations and amendments thereto adopted…”
Residents Opposed to Kittitas Turbines v. State Energy Facility Site Evaluation Council, 165 Wash. 2d 275 (Wash. 2008). · cites it 2× “The legislature amended the GMA in 2002 to recognize the importance of protecting rural lands and economies. RCW 36.70A.011.”
Whatcom Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 381 P.3d 1 (Wash. 2016). “010(1)(b) (emphasis added); RCW 36.70A.103 (state agencies shall comply with local comprehensive plans), .”
In the Matter of the Petition of: Kittitas Cnty. for a Declaratory Order, 438 P.3d 1199 (Wash. Ct. App. 2019). · cites it 8× “State agencies shall comply with the local comprehensive plans and development regulations and amendments thereto adopted pursuant to this chapter except as otherwise provided in RCW 71.”
Univ. of Wash. v. City of Seattle (Wash. 2017). · cites it 5× “If so, is UW a "[s]tate agenc[y]" that must comply with local development regulations adopted pursuant to the Growth Management Act (GMA) in accordance with RCW 36.70A.103? C. If so, is the LPO a local "development regulation[]" that was "adopted pursuant to" the GMA in…”
Univ. of Wash. v. City of Seattle (Wash. 2017). · cites it 4× “If so, is UW a "[s]tate agenc[y]" that must comply with local development regulations adopted pursuant to the Growth Management Act (GMA) in accordance with RCW 36.70A.103? C. If so, is the LPO a local "development regulation[]" that was "adopted pursuant to" the GMA in…”
Whatcom Cnty. v. W. Wash. Growth Mgmt. Hr'gs Bd. (Wash. 2016). “010(1)(b) (emphasis added); RCW 36.70A.103 (state agencies shall comply with local comprehensive plans), .”
Columbia Riverkeeper v. Port of Vancouver USA (Wash. 2017). “92335-3 preemption clauses: the GMA instructs state agencies to comply with "local comprehensive plans and development regulations," RCW 36.70A.103, while EFSLA grants EFSEC the power to supersede local zoning and licensing requirements, RCW 80.”
Whatcom Cnty. v. W. Wash. Growth Mgmt. Hr'gs Bd. (Wash. 2016). “010(1)(b) (emphasis added); RCW 36.70A.103 (state agencies shall comply with local comprehensive plans), .”
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