Wash. Rev. Code » Title 36 · Chapter 36.70A
Revised Code of Washington

Wash. Rev. Code § 36.70A.170 (2026)

✓ current as of May 2026
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(1) On or before September 1, 1991, each county, and each city, shall designate where appropriate:
(a) Agricultural lands that are not already characterized by urban growth and that have long-term significance for the commercial production of food or other agricultural products;
(b) Forestlands that are not already characterized by urban growth and that have long-term significance for the commercial production of timber;
(c) Mineral resource lands that are not already characterized by urban growth and that have long-term significance for the extraction of minerals; and
(d) Critical areas.
(2) In making the designations required by this section, counties and cities shall consider the guidelines established pursuant to RCW 36.70A.050.
[ 1990 1st ex.s. c 17 s 17.]
Notes of Decisions
Cited in 65 cases (3 in the last 5 years), 1994–2025 · leading case: Lewis Cnty. v. W. Wa. Growth Mgmt. Hearings Bd., 139 P.3d 1096 (Wash. 2006).
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Lewis Cnty. v. W. Wa. Growth Mgmt. Hearings Bd., 139 P.3d 1096 (Wash. 2006). · cites it 7× “As a threshold matter, then, we must identify the correct definition of "agricultural lands" under the GMA. ¶ 11 Lewis County designated agricultural lands based on its own definition: "those lands necessary to support the current and future needs of the agricultural industry in…”
Preserve Our Islands v. Shorelines Hearings Bd., 137 P.3d 31 (Wash. Ct. App. 2006). · cites it 3× “RCW 36.70A.170 requires counties and cities to designate "[m]ineral resource lands that are not already characterized by urban growth and that have long-term significance for the extraction of minerals.”
Lewis Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 157 Wash. 2d 488 (Wash. 2006). · cites it 6× “VI ¶21 Having discussed whether Lewis County properly designated lands under RCW 36.70A.170, we now turn to the RCW 36.”
Whatcom Cnty. v. Brisbane, 884 P.2d 1326 (Wash. 1994). · cites it 9× “060 and RCW 36.70A.170. As the County explains, these statutes mandate the passage of temporary critical areas ordinances.”
Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011). · cites it 4× “060, and surface water and groundwater resources; and (v) Protecting against conflicts with the use of agricultural, forest, and mineral resource lands designated under RCW 36.70A.170. RCW 36.70A.070(5)(c). [14] Accessory uses are defined in RCW 36.”
City of Redmond v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 959 P.2d 1091 (Wash. 1998). · cites it 3× “060(4) contains the following legislative imperative: “Forest land and agricultural land located within urban growth areas shall not be designated by a county or city as forest land or agricultural land of long- *56 term commercial significance under RCW 36.70A.170 unless the…”
King Cnty. v. Cent. Puget Sound, 14 P.3d 133 (Wash. 2000). · cites it 3× “040, and each city within such county, shall adopt development regulations on or before September 1, 1991, to assure the conservation of agricultural, forest, and mineral resource lands designated under RCW 36.70A.170.... Such regulations shall assure that the use of lands…”
King Cnty. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 142 Wash. 2d 543 (Wash. 2000). · cites it 3× “040, and each city within such county, shall adopt development regulations on or before September 1, 1991, to assure the conservation of agricultural, forest, and mineral resource lands designated under RCW 36.70A.170. . . . Such regulations shall assure that the use of lands…”
City of Arlington v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 193 P.3d 1077 (Wash. 2008). · cites it 4× “" [11] Furthermore, counties must adopt development regulations "to assure the conservation of" those agricultural lands designated under RCW 36.70A.170. [12] While this case was awaiting oral argument the definition of "agricultural land" for GMA purposes was addressed by the…”
City of Arlington v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 164 Wash. 2d 768 (Wash. 2008). · cites it 4× “” 11 Furthermore, counties must adopt development regulations “to assure the conservation of” those agricultural lands designated under RCW 36.70A.170. 12 While this case was awaiting oral argument, the definition of “agricultural land” for GMA purposes was addressed by the…”
Quadrant Corp. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 154 Wash. 2d 224 (Wash. 2005). · cites it 2× “rban growth” as growth that makes intensive use of land for the location of buildings, structures, and impermeable surfaces to such a degree as to be incompatible with the primary use of land for the production of food, other agricultural products, or fiber, or the extraction of…”
Quadrant Corp. v. State, Growth Mgmt. Hearings Bd., 110 P.3d 1132 (Wash. 2005). · cites it 2× “rban growth" as growth that makes intensive use of land for the location of buildings, structures, and impermeable surfaces to such a degree as to be incompatible with the primary use of land for the production of food, other agricultural products, or fiber, or the extraction of…”
Show all 65 citing cases →
— Wash. Rev. Code § 36.70A.170(1) — 7 cases
Lewis Cnty. v. W. Wa. Growth Mgmt. Hearings Bd., 139 P.3d 1096 (Wash. 2006). “As a threshold matter, then, we must identify the correct definition of "agricultural lands" under the GMA. ¶ 11 Lewis County designated agricultural lands based on its own definition: "those lands necessary to support the current and future needs of the agricultural industry in…”
Lewis Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 157 Wash. 2d 488 (Wash. 2006). “VI ¶21 Having discussed whether Lewis County properly designated lands under RCW 36.70A.170, we now turn to the RCW 36.”
Whatcom Cnty. v. Brisbane, 884 P.2d 1326 (Wash. 1994). “060 and RCW 36.70A.170. As the County explains, these statutes mandate the passage of temporary critical areas ordinances.”
Save Our Scenic Area v. Skamania Cnty., 352 P.3d 177 (Wash. 2015).
Clark Cnty. Citizens United, Inc. v. Clark Cnty. Nat. Resources Council, 972 P.2d 941 (Wash. Ct. App. 1999).
— Wash. Rev. Code § 36.70A.170(1)(a) — 11 cases
City of Arlington v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 193 P.3d 1077 (Wash. 2008). “" [11] Furthermore, counties must adopt development regulations "to assure the conservation of" those agricultural lands designated under RCW 36.70A.170. [12] While this case was awaiting oral argument the definition of "agricultural land" for GMA purposes was addressed by the…”
City of Redmond v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 959 P.2d 1091 (Wash. 1998). “060(4) contains the following legislative imperative: “Forest land and agricultural land located within urban growth areas shall not be designated by a county or city as forest land or agricultural land of long- *56 term commercial significance under RCW 36.70A.170 unless the…”
King Cnty. v. Cent. Puget Sound, 14 P.3d 133 (Wash. 2000). “040, and each city within such county, shall adopt development regulations on or before September 1, 1991, to assure the conservation of agricultural, forest, and mineral resource lands designated under RCW 36.70A.170.... Such regulations shall assure that the use of lands…”
Lewis Cnty. v. W. Wa. Growth Mgmt. Hearings Bd., 139 P.3d 1096 (Wash. 2006). “As a threshold matter, then, we must identify the correct definition of "agricultural lands" under the GMA. ¶ 11 Lewis County designated agricultural lands based on its own definition: "those lands necessary to support the current and future needs of the agricultural industry in…”
Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011). “060, and surface water and groundwater resources; and (v) Protecting against conflicts with the use of agricultural, forest, and mineral resource lands designated under RCW 36.70A.170. RCW 36.70A.070(5)(c). [14] Accessory uses are defined in RCW 36.”
— Wash. Rev. Code § 36.70A.170(1)(b) — 2 cases
Manke Lumber Co., Inc. v. Diehl, 959 P.2d 1173 (Wash. Ct. App. 1998).
Save Our Scenic Area, V Skamania Cnty. (Wash. Ct. App. 2014).
— Wash. Rev. Code § 36.70A.170(1)(c) — 2 cases
Preserve Our Islands v. Shorelines Hearings Bd., 137 P.3d 31 (Wash. Ct. App. 2006). “RCW 36.70A.170 requires counties and cities to designate "[m]ineral resource lands that are not already characterized by urban growth and that have long-term significance for the extraction of minerals.”
Preserve Our Islands v. Shorelines Hearings Bd., 133 Wash. App. 503 (Wash. Ct. App. 2006).
— Wash. Rev. Code § 36.70A.170(1)(d) — 8 cases
Whatcom Cnty. v. Brisbane, 884 P.2d 1326 (Wash. 1994). “060 and RCW 36.70A.170. As the County explains, these statutes mandate the passage of temporary critical areas ordinances.”
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).
Tahoma Audubon Soc'y v. PARK JUNCTION, 116 P.3d 1046 (Wash. Ct. App. 2005).
Tahoma Audubon Soc'y v. Park Junction Partners, 128 Wash. App. 671 (Wash. Ct. App. 2005).
— Wash. Rev. Code § 36.70A.170(2) — 3 cases
City of Redmond v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 959 P.2d 1091 (Wash. 1998). “060(4) contains the following legislative imperative: “Forest land and agricultural land located within urban growth areas shall not be designated by a county or city as forest land or agricultural land of long- *56 term commercial significance under RCW 36.70A.170 unless the…”
Thurston Cnty. v. W. WASH. BD., 154 P.3d 959 (Wash. Ct. App. 2007).
Thurston Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 137 Wash. App. 781 (Wash. Ct. App. 2007).
— Wash. Rev. Code § 36.70A.170(d) — 1 case
Stevens Cnty. v. Loon Lake Prop. Owners Ass'n, 187 P.3d 846 (Wash. Ct. App. 2008).
— Wash. Rev. Code § 36.70A.170(l)(a) — 9 cases
City of Arlington v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 164 Wash. 2d 768 (Wash. 2008). “” 11 Furthermore, counties must adopt development regulations “to assure the conservation of” those agricultural lands designated under RCW 36.70A.170. 12 While this case was awaiting oral argument, the definition of “agricultural land” for GMA purposes was addressed by the…”
King Cnty. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 142 Wash. 2d 543 (Wash. 2000). “040, and each city within such county, shall adopt development regulations on or before September 1, 1991, to assure the conservation of agricultural, forest, and mineral resource lands designated under RCW 36.70A.170. . . . Such regulations shall assure that the use of lands…”
Lewis Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 157 Wash. 2d 488 (Wash. 2006). “VI ¶21 Having discussed whether Lewis County properly designated lands under RCW 36.70A.170, we now turn to the RCW 36.”
Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011). “060, and surface water and groundwater resources; and (v) Protecting against conflicts with the use of agricultural, forest, and mineral resource lands designated under RCW 36.70A.170. RCW 36.70A.070(5)(c). [14] Accessory uses are defined in RCW 36.”
Whidbey Env't Action Network v. Island Cnty., 93 P.3d 885 (Wash. Ct. App. 2004).
— Wash. Rev. Code § 36.70A.170(l)(c) — 1 case
Concrete Nor'West v. W. Washington Growth Mgmt. Hearings Bd., 342 P.3d 351 (Wash. Ct. App. 2015).
— Wash. Rev. Code § 36.70A.170(l)(d) — 2 cases
Yakima Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 279 P.3d 434 (Wash. Ct. App. 2012).
Whatcom Cnty. v. Brisbane, 884 P.2d 1326 (Wash. 1994). “060 and RCW 36.70A.170. As the County explains, these statutes mandate the passage of temporary critical areas ordinances.”
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