## Facts

- Snohomish County adopted the Snohomish/Lake Stevens Area Comprehensive Plan designating the Soper Hill site near Lake Stevens as suburban residential.
- Hewlett-Packard proposed an electronics manufacturing facility on the site and urged an amendment to permit a business-park designation.
- The County Planning Department prepared draft environmental impact statements addressing the plan amendment and the business-park proposal.
- After public hearings, a majority of the planning commission recommended against amending the plan.
- The County Council held hearings, rejected the commission’s recommendation, and enacted a comprehensive plan amendment creating a business-park designation for the site.
- The Council conditioned any business-park rezone on measures addressing drainage control, buffering of agricultural lands, and road/traffic impacts.
- HP and associated landowners submitted a development plan and rezone application; a hearing officer recommended approval, and the Council unanimously approved the rezone.
- Save Our Rural Environment (SORE) petitioned for review, alleging illegal spot zoning, inadequate justification and consistency, failure to consider alternative sites, and insufficient mitigation of regional impacts.
- The superior court upheld the County’s actions; the Washington Supreme Court accepted direct review.

## Issues

1. Whether the site-specific rezone to business-park zoning constituted illegal spot zoning.
2. Whether the comprehensive plan amendment and rezone were sufficiently tied to legitimate public purposes and reasonably consistent with comprehensive planning objectives.
3. Whether the County’s environmental review and consideration of impacts and alternatives satisfied SEPA and related procedural requirements.

## Decision

- The Washington Supreme Court affirmed the superior court and upheld both the comprehensive plan amendment and the rezone.
- The court held the action was not illegal spot zoning because it was implemented through a formal plan amendment process and was supported by public-welfare justifications.
- The court concluded the County’s decision was not arbitrary, capricious, or clearly erroneous given the record, hearings, and imposed impact-mitigation conditions.
- The court rejected SEPA-based objections, finding the County adequately reviewed environmental consequences and considered relevant impacts and alternatives.

## Legal Principles

- Spot zoning is invalid when a small area is singled out for a classification inconsistent with the surrounding area and comprehensive planning, primarily for private benefit, and without a substantial relationship to the public welfare.
- Legislative land-use decisions by local governments (including plan amendments and rezones) are presumed valid; challengers bear the burden to show arbitrariness, capriciousness, or clear error under the applicable standard of review.
- A comprehensive plan may be amended in a site-specific manner; legality turns on whether the amendment and implementing rezone reasonably further planning objectives and legitimate public purposes.
- Under SEPA, courts generally defer to local decisionmaking where the agency takes a hard look at environmental consequences through required review documents and procedures and considers relevant impacts and mitigation.

## Conclusion

The court sustained Snohomish County’s site-specific comprehensive plan amendment and business-park rezone for Soper Hill, holding that the County acted within its legislative discretion, avoided illegal spot zoning by grounding the change in public-welfare and planning considerations, and satisfied environmental review obligations.


Save Our Rural Env’t v. Snohomish County, 99 Wash. 2d 363, 662 P.2d 816 (1983)