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

Wash. Rev. Code § 36.70A.320 (2026)

✓ current as of May 2026
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(1) Except as provided in subsections (5) through (7) of this section, comprehensive plans and development regulations, and amendments thereto, adopted under this chapter are presumed valid upon adoption.
(2) Except as otherwise provided in subsection (4) of this section, the burden is on the petitioner to demonstrate that any action taken by a state agency, county, or city under this chapter is not in compliance with the requirements of this chapter.
(3) In any petition under this chapter, the board, after full consideration of the petition, shall determine whether there is compliance with the requirements of this chapter. In making its determination, the board shall consider the criteria adopted by the department under RCW 36.70A.190(4). The board shall find compliance unless it determines that the action by the state agency, county, or city is clearly erroneous in view of the entire record before the board and in light of the goals and requirements of this chapter.
(4) A county or city subject to a determination of invalidity made under RCW 36.70A.300 or 36.70A.302 has the burden of demonstrating that the ordinance or resolution it has enacted in response to the determination of invalidity will no longer substantially interfere with the fulfillment of the goals of this chapter under the standard in RCW 36.70A.302(1).
(5) The shoreline element of a comprehensive plan and the applicable development regulations adopted by a county or city shall take effect as provided in chapter 90.58 RCW.
(6) The greenhouse gas emissions reduction subelement required by RCW 36.70A.070 shall take effect as provided in RCW 36.70A.096.
(7) Any housing element and any housing development regulations subject to review under RCW 36.70A.835 take effect as provided in RCW 36.70A.835.
[ 2025 c 269 s 4; 2023 c 228 s 8; 1997 c 429 s 20; 1995 c 347 s 111; 1991 sp.s. c 32 s 13.]

Notes:

State representation—Short title—2025 c 269: See notes following RCW 36.70A.835.
Prospective application—1997 c 429 ss 1-21: See note following RCW 36.70A.3201.
Severability—1997 c 429: See note following RCW 36.70A.3201.
Finding—Severability—Part headings and table of contents not law—1995 c 347: See notes following RCW 36.70A.470.
Notes of Decisions
Cited in 117 cases (7 in the last 5 years), 1998–2025 · leading case: Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011).
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Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011). · cites it 25× “RCW 36.70A.320(1). Petitioners contend that the Board did not give proper deference to the County and implicitly present a question about the evidentiary rule in City of Arlington v.”
Quadrant Corp. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 154 Wash. 2d 224 (Wash. 2005). · cites it 10× “FOTL asserts that “substantial weight” should be given to the Board’s interpretation of the statute it is charged with “administering,” while King County and Quadrant respond that this is the very type of situation the legislature had in mind when it amended RCW 36.70A.320 to…”
Quadrant Corp. v. State, Growth Mgmt. Hearings Bd., 110 P.3d 1132 (Wash. 2005). · cites it 10× “FOTL asserts that "substantial weight" should be given to the Board's interpretation of the statute it is charged with "administering," while King County and Quadrant respond that this is the very type of situation the legislature had in mind when it amended RCW 36.70A.320 to…”
Thurston Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 164 Wash. 2d 329 (Wash. 2008). · cites it 5× “A comprehensive plan is presumed valid upon adoption, RCW 36.70A.320(1), and is conclusively deemed legally compliant if it is not challenged within 60 days.”
Thurston Cnty. v. W. Wash. Growth Mgmt., 190 P.3d 38 (Wash. 2008). · cites it 5× “A comprehensive plan is presumed valid upon adoption, RCW 36.70A.320(1), and is conclusively deemed legally compliant if it is not challenged within 60 days.”
Clark Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 161 Wash. App. 204 (Wash. Ct. App. 2011). · cites it 14× “RCW 36.70A.320(1) states that “comprehensive plans and development regulations, and amendments thereto, adopted under this chapter are presumed valid upon adoption.”
Clark Cnty. v. W. Wash. Growth Mgt., 254 P.3d 862 (Wash. Ct. App. 2011). · cites it 14× “RCW 36.70A.320(1) states that "comprehensive plans and development regulations, and amendments thereto, adopted under this chapter are presumed valid upon adoption.”
City of Arlington v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 193 P.3d 1077 (Wash. 2008). · cites it 4× “Under RCW 36.70A.320(2), "the burden is on the petitioner to demonstrate that any action taken by a state agency, county, or city under [the GMA] is not in compliance with the requirements of [the GMA].”
1000 Friends of Washington v. McFarland, 149 P.3d 616 (Wash. 2006). · cites it 4× “RCW 36.70A.320(1), (2) (GMA comprehensive plans and development regulations "are presumed valid upon adoption" and places burden on the challenger to show any action taken under the GMA is not in compliance with the requirements of the GMA).”
Brinnon Grp. v. Jefferson Cnty., 159 Wash. App. 446 (Wash. Ct. App. 2011). · cites it 4× “RCW 36.70A.320(1). Consequently, the Board must find that a county complied with the GMA unless the party challenging the plan demonstrates that the county’s action was “ ‘clearly erroneous in view of the entire record before the board and in light of the [GMA’s] goals and…”
1000 Friends v. McFarland, 159 Wash. 2d 165 (Wash. 2006). · cites it 3× “RCW 36.70A.320(1), (2) (GMA comprehensive plans and development regulations “are presumed valid upon adoption” and places burden on the challenger to show any action taken *187 under the GMA is not in compliance with the requirements of the GMA).”
City of Arlington v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 164 Wash. 2d 768 (Wash. 2008). · cites it 3× “The superior court’s ruling that the County be required to show evidence of changed circumstances in order to overcome collateral estoppel and res judicata thus directly conflicts with the statutorily mandated burden of proof set forth in RCW 36.70A.320(2) and affirmed in City…”
Show all 117 citing cases →
— Wash. Rev. Code § 36.70A.320(1) — 69 cases
Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011). “RCW 36.70A.320(1). Petitioners contend that the Board did not give proper deference to the County and implicitly present a question about the evidentiary rule in City of Arlington v.”
Thurston Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 164 Wash. 2d 329 (Wash. 2008). “A comprehensive plan is presumed valid upon adoption, RCW 36.70A.320(1), and is conclusively deemed legally compliant if it is not challenged within 60 days.”
Thurston Cnty. v. W. Wash. Growth Mgmt., 190 P.3d 38 (Wash. 2008). “A comprehensive plan is presumed valid upon adoption, RCW 36.70A.320(1), and is conclusively deemed legally compliant if it is not challenged within 60 days.”
Clark Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 161 Wash. App. 204 (Wash. Ct. App. 2011). “RCW 36.70A.320(1) states that “comprehensive plans and development regulations, and amendments thereto, adopted under this chapter are presumed valid upon adoption.”
Clark Cnty. v. W. Wash. Growth Mgt., 254 P.3d 862 (Wash. Ct. App. 2011). “RCW 36.70A.320(1) states that "comprehensive plans and development regulations, and amendments thereto, adopted under this chapter are presumed valid upon adoption.”
— Wash. Rev. Code § 36.70A.320(2) — 44 cases
Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011). “RCW 36.70A.320(1). Petitioners contend that the Board did not give proper deference to the County and implicitly present a question about the evidentiary rule in City of Arlington v.”
Thurston Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 164 Wash. 2d 329 (Wash. 2008). “A comprehensive plan is presumed valid upon adoption, RCW 36.70A.320(1), and is conclusively deemed legally compliant if it is not challenged within 60 days.”
Thurston Cnty. v. W. Wash. Growth Mgmt., 190 P.3d 38 (Wash. 2008). “A comprehensive plan is presumed valid upon adoption, RCW 36.70A.320(1), and is conclusively deemed legally compliant if it is not challenged within 60 days.”
City of Arlington v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 193 P.3d 1077 (Wash. 2008). “Under RCW 36.70A.320(2), "the burden is on the petitioner to demonstrate that any action taken by a state agency, county, or city under [the GMA] is not in compliance with the requirements of [the GMA].”
Quadrant Corp. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 154 Wash. 2d 224 (Wash. 2005). “FOTL asserts that “substantial weight” should be given to the Board’s interpretation of the statute it is charged with “administering,” while King County and Quadrant respond that this is the very type of situation the legislature had in mind when it amended RCW 36.70A.320 to…”
— Wash. Rev. Code § 36.70A.320(3) — 81 cases
Kittitas Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 256 P.3d 1193 (Wash. 2011). “RCW 36.70A.320(1). Petitioners contend that the Board did not give proper deference to the County and implicitly present a question about the evidentiary rule in City of Arlington v.”
Quadrant Corp. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 154 Wash. 2d 224 (Wash. 2005). “FOTL asserts that “substantial weight” should be given to the Board’s interpretation of the statute it is charged with “administering,” while King County and Quadrant respond that this is the very type of situation the legislature had in mind when it amended RCW 36.70A.320 to…”
Quadrant Corp. v. State, Growth Mgmt. Hearings Bd., 110 P.3d 1132 (Wash. 2005). “FOTL asserts that "substantial weight" should be given to the Board's interpretation of the statute it is charged with "administering," while King County and Quadrant respond that this is the very type of situation the legislature had in mind when it amended RCW 36.70A.320 to…”
Clark Cnty. v. W. Washington Growth Mgmt. Hearings Bd., 161 Wash. App. 204 (Wash. Ct. App. 2011). “RCW 36.70A.320(1) states that “comprehensive plans and development regulations, and amendments thereto, adopted under this chapter are presumed valid upon adoption.”
Lewis Cnty. v. W. Wa. Growth Mgmt. Hearings Bd., 139 P.3d 1096 (Wash. 2006).
— Wash. Rev. Code § 36.70A.320(4) — 4 cases
Wells v. W. Washington Growth Mgmt., 997 P.2d 405 (Wash. Ct. App. 2000).
Miotke v. Spokane Cnty., 325 P.3d 434 (Wash. Ct. App. 2014).
Wells v. W. Washington Growth Mgmt. Hearings Bd., 100 Wash. App. 657 (Wash. Ct. App. 2000).
Heritage Baptist Church v. Cent. Puget Sound Growth Mgmt., 413 P.3d 590 (Wash. Ct. App. 2018).
— Wash. Rev. Code § 36.70A.320(l) — 1 case
Spokane Cnty. v. E. Washington Growth Mgmt. Hearings Bd., 173 Wash. App. 310 (Wash. Ct. App. 2013).
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