Revised Code of Washington

Wash. Rev. Code § 36.70B.180 (2026)

✓ current as of May 2026
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Unless amended or terminated, a development agreement is enforceable during its term by a party to the agreement. A development agreement and the development standards in the agreement govern during the term of the agreement, or for all or that part of the build-out period specified in the agreement, and may not be subject to an amendment to a zoning ordinance or development standard or regulation or a new zoning ordinance or development standard or regulation adopted after the effective date of the agreement. A permit or approval issued by the county or city after the execution of the development agreement must be consistent with the development agreement.
[ 1995 c 347 s 503.]

Notes:

FindingsIntent1995 c 347 ss 502-506: See note following RCW 36.70B.170.
Notes of Decisions
Cited in 14 cases (5 in the last 5 years), 2014–2025 · leading case: Snohomish Cnty. v. Pollution Control Hearings Bd., 368 P.3d 194 (Wash. Ct. App. 2016).
Snohomish Cnty. v. Pollution Control Hearings Bd., 368 P.3d 194 (Wash. Ct. App. 2016). · cites it 14× “033(1)), and development agreements (RCW 36.70B.180).7 Town of Woodway, 180 Wn.”
Snohomish Cnty. v. Pollution Control Hearings Bd., 386 P.3d 1064 (Wash. 2016). · cites it 4× “033 (subdivision applications); RCW 36.70B.180 (development agreements). RCW 19.”
Town of Woodway v. Snohomish Cnty., 322 P.3d 1219 (Wash. 2014). “The GMA aims to curtail “uncoordinated and unplanned growth” that “pose[s] a threat to the environment, sustainable economic development, and the health, safety, and high quality of life enjoyed by residents of this state.”
Potala Vill. Kirkland, LLC v. City of Kirkland, 334 P.3d 1143 (Wash. Ct. App. 2014). “033(1) (subdivision applications); RCW 36.70B.180 (development agreements)).”
City Of Issaquah, V. Westridge-issaquah Ii Lp, 500 P.3d 157 (Wash. Ct. App. 2021). “RCW 36.70B.180 (emphasis added). The development agreement herein, which was entered into in June 1996, established a build-out period of 20 years: A “Buildout Period” of twenty (20) years following first final plat approval is established for the development and construction of…”
Snohomish Cnty. v. Pollution Control Hr'gs Bd. (Wash. 2016). “3 RCW 36.70B.180 provides in relevant part: A development agreement and the development standards in the agreement govern during the term of the agreement, or for all or that part of the build- out period specified in the agreement, and may not be subject to an amendment to a…”
Rmg Worldwide Llc., Et Ano v. Pierce Cnty. (Wash. Ct. App. 2017). “Thus, even if the original PDD/Rezone application had not been abandoned, the application would still be subject to the current Rural Reserve zoning and not the pre-GMA General zone.”
Snohomish Cnty. v. Pollution Control Hr'gs Bd. (Wash. 2016). “3 RCW 36.70B.180 provides in relevant part: A development agreement and the development standards in the agreement govern during the term of the agreement, or for all or that part of the build- out period specified in the agreement, and may not be subject to an amendment to a…”
Midtown Props., Llc, V. The City Of Bonney Lake (Wash. Ct. App. 2023). “RCW 36.70B.180. Development agreements are contracts and are subject to the rules of contract interpretation.”
Shadow Creek Investments, V. City Of Anacortes (Wash. Ct. App. 2024). “033(1); and development agreements (RCW 36.70B.180).” Id. at 279-80. Given this statutory directive, we concluded “the vested rights doctrine does not apply” to the new owner’s application because “applications for a PDD or rezone are not vested by statute.”
Shadow Creek Investments, V. City Of Anacortes (Wash. Ct. App. 2025). “033(1); and development agreements (RCW 36.70B.180).” Id. at 279-80. Given this statutory directive, we concluded “the vested rights doctrine does not apply” to the new owner’s application because “applications for a PDD or rezone are not vested by statute.”
H.c. Burkholder, App V. Pollution Control Hearings Bd. & Wa State Dept Of Ecology, Resps (Wash. Ct. App. 2025). “095(1); RCW 36.70B.180. But no authority supports the proposition that groundwater permitting requirements are land use ordinances for the purposes of the vesting statutes.”
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