Futurewise v. Growth Management Hearings Board, 43643-4

Futurewise appeals a superior court decision affirming the Western Washington Growth Management Hearings Board (Board) finding that Pacific County's 2010 updated comprehensive plan complied with the GMA.
Pacific County adopted a 2010 updated plan amending its agricultural lands section and adding new maps, after previously declaring long-term agricultural significance for aquaculture, cranberries, and bog-related crops in 1997 and codifying that in the 1998 plan.
The GMA requires counties to designate agricultural lands of long-term significance and periodically update their plans; Pacific County updated its plan in 2010 despite being under population thresholds and opting in.
Futurewise challenged only the 2010 amendments (not pre-1997 designations), arguing (i) new criteria for agricultural lands were adopted but not applied, (ii) deviation from the statutory definition of agricultural land, and (iii) improper map labeling of lands as Rural Agricultural.
The court applies APA standards, reviews legal conclusions de novo, and reviews challenged factual findings for substantial evidence; the Board’s determination that the 2010 plan complied with the GMA is reviewed for clear error.
The Washington Supreme Court (as the reviewing court) affirms the Board, holding no adoption of new criteria occurred, no deviation from the statutory definition was shown, and the Rural Agricultural labeling did not improperly merge agricultural lands into the rural element.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the 2010 update adopt new criteria for designating agricultural land without applying them?	Futurewise contends the plan added new criteria but did not use them to reclassify land.	Pacific County did not adopt new criteria; the references were to existing statutory/regulatory provisions.	No new criteria adopted; plan consistent.
Did the updated plan deviate from the statutory definition of agricultural land?	Futurewise asserts misalignment with RCW 36.70A.030(2) and Lewis County.	Board correctly quoted and adhered to the statutory definition.	No deviation; plan complied with the statutory definition.
Did labeling agricultural lands as 'Rural Agricultural' improperly place them in the rural element?	Futurewise argues the map labeling collapses agricultural lands into the rural element.	Rural element remains separate; maps label Rural Agricultural but do not place designated lands in the rural element.	Labels did not improperly include agricultural lands in the rural element.

Lewis County v. W. Wash. Growth Mgmt. Hearings Bd., 157 Wn.2d 488 (2006) (three-part test for agricultural land; long-term significance)
Thurston County v. Western Washington Growth Mgmt. Hearings Bd., 164 Wn.2d 329 (2008) (board deference; substantial evidence review; amendments scope)
Quadrant Corp. v. Central Puget Sound Growth Mgmt. Hearings Bd., 154 Wn.2d 224 (2005) (APA standards; scope of review for administrative orders)
City of Redmond v. Central Puget Sound Growth Mgmt. Hearings Bd., 136 Wn.2d 38 (1998) (substantial evidence standard; review of findings)
King County v. Central Puget Sound Growth Mgmt. Hearings Bd., 142 Wn.2d 543 (2000) (board interpretations; deference but independent legal review)
City of Arlington v. Central Puget Sound Growth Mgmt. Hearings Bd., 164 Wn.2d 768 (2008) (legal standards in GMA challenges; de novo review of law)