All things land use in Washington State are tied to the Growth Management Act (GMA) and its many provisions. One such provision is RCW 36.70A.130, which among other things, establishes an every ten-year cycle in which jurisdictions must “review and revise” their comprehensive plans and development regulations. You’ll often here this referred to as the “periodic update” by many involved.
Periodic Update Schedules
Under the current, codified schedule in RCW 36.70A.130, these periodic updates happen on a rolling basis so that not every county is on the same schedule. The most current round of periodic updates is occurring between 2024 and 2027, starting with King, Kitsap, Pierce and Snohomish counties this year (we’ll have some analysis out on these plan updates soon). You can check out a map of the statewide schedule by county here.
You may or may not have heard about these updates, but several of them have been underway for some time now as jurisdictions (counties and cities) have advanced preparatory work that needs to be completed, including buildable lands reports, revisions to multi-county1 and countywide planning policies,2 etc. So, for example, Snohomish County has really been in the process of updating their comprehensive plan since 2020. While Lewis County, which plans under GMA but is not required to have a buildable lands report, has been working on parts of their comprehensive plan update since early 2023 even though it’s not due until December 2025.
Although jurisdictions are required by GMA to have robust public participation plans3 that include ‘early and continuous’ public participation, the vast majority of folks aren’t typical aware of or hear about the updates, or choose to ignore them.
However, periodic updates can have big impacts on properties. For example, Pierce County’s Land Use Alternative 3 (under review right now) proposes to eliminate density bonuses in rural areas that incentivize clustering rural development into smaller footprints while permanently protecting open spaces.
The periodic updates also affect when jurisdictions will consider citizen-initiated proposals to proposed changes to their properties.
How Scheduling Impacts Annual Amendments
The timing of the periodic update schedule impacts what’s often called the “annual amendment cycle” or “annual docket” - a one-time4 per year opportunity to propose comprehensive plan and zoning map amendments. Annual dockets are the most common and accessible processes used by developers and property owners to propose changes to their properties (i.e., proposing to switch zoning from commercial to multifamily).
But most jurisdictions pause or suspend the “docket” starting in the year prior to their periodic update in order to focus exclusively on the update. The primary reason for this is that the periodic updates come with a large work plan that must follows checklists prepared by the State and also account for recent legislative changes which this go around include middle housing, the additional of a climate change and resiliency element, etc.
That means if you want to propose a change before annual amendment cycles are suspended for a periodic update, you’ll typically need to apply about two years prior to the year in which your county or city periodic update is due. But you should also be aware that some jurisdictions may still defer your proposal to the periodic update.5
Don’t Take a Wait & See Approach
If you’re hoping to make a change to your property during your jurisdiction’s periodic update, it’s not advised to wait until your jurisdiction presents its draft plan before suggesting your proposed change. Ultimately you could, but here’s why you shouldn’t:
The Point of No Return. There comes a point of no return in the periodic update process after which point your proposal’s environmental impacts may not be able to be studied (as required) because the jurisdiction has already started or completed that review process. During the periodic update, a jurisdiction has to identify a range of land use alternatives and study them in accordance with SEPA.6
The scoping for the SEPA environmental review is identified near the beginning of the update process because the amount of change contemplated during a periodic update will typically require completion of what’s known as an Environmental Impact Statement (EIS), a study of probable significant environmental impacts, which study takes a lot of time and typically drives the schedule for a periodic update.
This means that those of you in King, Kitsap, Pierce & Snohomish counties are past the point of no return (in most cases7). And for those of you in counties that will be completing updates by the end of 2025, you may be close to or just past the point of no return.Post Periodic Update Limitations. Timing is also important relative to when a periodic update is finished. For example, if your proposal is not proposed or considered during the periodic update, local regulations often directly or indirectly limit future consideration of such proposals for a year or more after the comprehensive plan is adopted.
For example, Snohomish County limits the types of proposals that may be brought forward in the first year after the periodic update to “minor” amendments only.8 While Issaquah applies a criterion to proposals that the Applicant must establish there have been “significantly changed conditions9 from when the plan was adopted.
Even if your proposal is considered during a periodic update but not adopted, limitations may still restrict when it can be proposed again. For example, Fife requires proposals considered but rejected within the last two years to identify reasons why the proposal merits consideration again.10
What Should You Do If You Want A Change?
If you own a property and want to make a change:
Don’t wait, be proactive.
Contact your jurisdiction and get information on the process and timing for submitting annual amendments and/or proposing changes as part of the periodic update.
Consider submitting a formal application. Generally, when given the choice between submitting a formal application for the docket (or periodic update) versus merely submitting a public comment seeking to have your change considered, you’ll have a much better chance of getting your proposal considered if the jurisdiction is reviewing a specific application.11
Get information on how to apply and what to submit directly from the jurisdiction. Typically, this includes one or more application forms, and a checklist detailing exhibits you need to also provide. What you are required to submit will vary depending on how complex your proposal is, whether it’s part of the annual docket or a periodic update, and whether you’re seeking a text or map amendment.
Consider getting assistance from a land use professional who can walk you through the challenges, the processes, the requirements, the likely costs, and your likelihood for success.
One More Tip
The success rate for zoning changes is considerably higher when the changes proposed have been analyzed in detail before being submitted and the application includes supporting exhibits, studies, narratives, etc. that articulate how the change is consistent with the jurisdiction’s planning goals and policies, as well as that jurisdiction’s current and future needs.
Want Some Help
You can book a free consultation with Toyer Strategic, a land use consulting firm, here.12
Multicounty planning policies or MPPs are regionally coordinated planning policies that apply in a limited number of areas based on RCW 36.70A.210(7). The most notable of which are contained in VISION 2050 - a regional growth strategy adopted by King, Kistap, Pierce and Snohomish counties in October 2020.
Countywide Planning Policies or CPPs are policies negotiated between the cities and their county, which policies establish agreement on how growth will be coordinated among those jurisdictions. These policies establish the population, housing and employment targets to be distributed to each jurisdiction.
For example, here’s Snohomish County’s and Island County’s (Draft) Public Participation Plans for their periodic updates.
Most jurisdictions have an annual docket; however there have been jurisdictions who’ve had biennial dockets or major/minor docket cycles. Check with your jurisdiction or a land use professional to identify exactly when you can submit changes.
For example, Fife Municipal Code’s review criteria at 19.90.050(B)(2) asks whether the proposal “. . . is best addressed as an individually docketed item, instead of evaluating as part of a periodic update to Fife’s comprehensive plan, or other planning processes such as those led by neighboring jurisdictions, regional, or state agencies.”
abbv. for the State Environmental Policy Act, regulations are at RCW 43.21C and WAC 197-11
In some cases your proposed change may fit within the range of alternatives a jurisdiction has considered and could still be proposed. But it will face an uphill battle.
See SCC 30.74.015(2)
See IMC 18.104.060(a)(2)(c)
See FMC 19.90.050(B)(9)
Note that submiting your own application often comes with expenses like application and review fees, payment of a proportionate share of environmental review, etc. You’re encouraged to discuss this with the jurisdiction and/or a land use professional in advance of making your final decision on how to proceed.
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