7. SEPA and the Growth Management Act (GMA)

Chapter Contents
7.1. Principles for Integrating SEPA and GMA
7.2. GMA Nonproject Review
7.2.1. Early (Preliminary) Environmental Analyses
7.2.2. Timing of the Threshold Determination
7.2.3. Expanded Scoping
7.2.4. Issuing and Distributing an Integrated Document
7.2.5. Adopting the GMA document
7.2.6. Integrated Document Format GMA Action EIS Non-EIS Integrated Documents
7.3. GMA Project Review
7.4. Planned Actions
7.4.1. Tip
7.4.2. Designating Planned Action Projects
7.4.3. Consistency Requirements for Planned Action Projects



SEPA requires all state and local agencies to use an interdisciplinary, integrated approach to include environmental factors in both planning and decision-making. Although the terms "SEPA review" and "environmental review" include formal SEPA determinations and environmental analyses, these terms also refer to the basic concept of taking environmental quality into account in whatever an agency does.

Under GMA, cities and counties adopt policies, plans, and regulations to manage land use, environmental resources, and other aspects of growth within their own jurisdictions, and in a coordinated way with other jurisdictions. It is not possible to meet the goals or requirements of GMA or to make informed planning decisions without giving appropriate consideration to environmental factors. The GMA nonproject actions such as the adoption of policies, plans, and regulations form the basis for subsequent "on the ground" project decisions that directly affect our environment.

Environmental review at the planning stage allows the GMA city or county to analyze impacts and determine mitigation system-wide, rather than project by project. This allows cumulative impacts to be identified and addressed, and provides a more consistent framework for the review, conditioning, or denial of future projects.

Plans that effectively integrate the goals and requirements of SEPA and GMA contribute to public knowledge, environmental protection, and fiscal efficiency for local government services. Benefits include:

  • A more predictable future for the community;

  • A better understanding of the capacity of the built and natural environment and the cumulative impacts of development community-wide, increasing the potential for protection of environmental values

  • Efficient use of public funds for the provision of public facilities, infrastructure, and services; and

  • A decrease in the time and cost associated with obtaining permit approval for appropriate projects in suitable locations resulting from early decisions on land-use, services, and mitigation.

To the extent that plans and implementing regulations are more comprehensive, detailed, and consistently relied upon, environmental review for individual project proposals can be reduced. Environmental review at the project phase entails 1) determining the project’s consistency with the comprehensive plan, development regulations, and other local, state, and federal laws; and 2) using SEPA to address the gaps that may remain, by focusing on any project-specific environmental impacts not addressed under other regulations.

Formal SEPA documents issued by GMA jurisdictions for both project and nonproject proposals serve three purposes:

  1. To document the consideration of environmental values;

  2. To provide public, agency, and tribal review and comment prior to many agency decisions; and

  3. To ensure coordination among the policies, plans, and regulations of various governments.

7.1 Principles for Integrating SEPA and GMA

The integration of SEPA and GMA results in improved planning and project decisions from the environmental prospective. Just as GMA goals cannot be addressed without consideration of environmental factors, the goals of SEPA are benefited by the examination of the "big picture" and identification of mitigation to address cumulative impacts of development that occurs during GMA planning. Jurisdictions planning under GMA should:

  • Think about environmental quality as each community charts its future, by involving diverse sectors of the public and by incorporating early and informal environmental analysis into GMA planning and decision-making.

  • Use SEPA review together with other analyses and public involvement to produce better planning decisions.

  • Combine to the fullest extent possible the processes, analysis, and documents required under GMA and SEPA, so that GMA planning decisions and subsequent implementation will incorporate measures to promote the goals of GMA and SEPA.

  • Recognize that different questions will need to be answered and different levels of detail will be required at each phase of GMA planning, from the initial development of plan concepts or elements to the creation of implementation programs.

  • Focus environmental review and the level of detail needed for different stages of plan and project decisions on the environmental choices most relevant to that stage of the process, while not duplicating the review that has occurred for decisions that have already been made.

  • Use environmental review on projects to help: 1) review and document consistency with GMA plans and regulations; 2) identify any impacts and mitigation needs that had not been considered and addressed at the plan level; and 3) provide the opportunity for review by agencies, tribes, and the public.

  • Continue to maintain or improve the quality of environmental analysis for both plan and project decisions, while integrating these analyses with improved state and local planning and permitting processes.

7.2 GMA Nonproject Review

In 1995, the SEPA Rules were amended to help cities and counties combine SEPA and GMA processes and analyses, including issuing combined SEPA/GMA documents [WAC 197-11-210 through 235]. These amendments affirmed that environmental review should begin at the early stages of plan development in order to ensure that early studies are available and useful throughout the planning and environmental review process [WAC 197-11-030(2)(d)]. Planning and decision-making under GMA is best done concurrently with environmental analysis under SEPA.

Environmental analysis at each stage of the GMA planning process should, at a minimum, address the environmental impacts associated with planning decisions at that stage of the planning process. Impacts associated with later planning stages may also be addressed to the extent that sufficient information is known for the analysis to be meaningful.

7.2.1 Early (Preliminary) Environmental Analyses

Cities and counties are encouraged to integrate informal environmental analysis into preliminary planning considerations. These preliminary analyses can be prepared and used early in the process and may also be incorporated into later analyses. Early environmental analyses:

  • Do not require a threshold determination;

  • May be separate documents or included as part of other planning materials such as issue papers;

  • May use the format of SEPA documents (e.g. environmental checklist, EIS); and

  • May evaluate issues and concerns not required in SEPA documents such as economic or technical factors [WAC 197-11-232].

7.2.2 Timing of the Threshold Determination

A SEPA threshold determination is made:

  • As soon as it can be determined whether a significant adverse environmental impact is likely to result from the implementation of the GMA action; or

  • At any time, as long as it is early enough that the appropriate environmental document can accompany or be combined with a proposed GMA action [WAC 197-11-230].

  • When using existing documents for which a previous threshold determination has been prepared and there are substantial changes or new information indicating significant impacts not previously analyzed [WAC 197-11-230 and 600].

A threshold determination is not required when:

  • There has been a previous threshold determination on the proposal and there are no substantial changes or new information indicating significant impacts not previously analyzed; or

  • A notice of adoption or an addendum is being prepared [WAC 197-11-230 and 600] (except when required by WAC 197-11-600(3)).

7.2.3 Expanded Scoping

Expanded scoping may be used for integrated documents without requiring the preparation of an EIS. Expanded scoping may begin or be combined with early GMA planning activities such as "visioning," development of alternative concepts or elements, or scoping of possible GMA actions.

Expanded scoping may be started before a threshold determination. A scoping notice may be issued separately from or without a threshold determination. If expanded scoping is used before making a threshold determination and a determination of significance (DS) is subsequently issued, additional scoping is optional [WAC 197-11-232(2)].

7.2.4 Issuing and Distributing an Integrated Document

A formal SEPA document must be issued no later than when a proposed GMA action is issued for public review. For comprehensive plans and development regulations, it is issued at least sixty days before final adoption.

The public comment period on a formal SEPA document issued with a GMA document is the longer of:

  • The comment period on the GMA action; or

  • The comment period typically required for a SEPA document.

The document must be distributed to:

  • The Department of Ecology;

  • Any advisory body that makes a formal recommendation to the local legislative body regarding a GMA action;

  • The legislative body that will consider a GMA action;

  • Agencies, affected tribes, and citizens as mandated by WAC 197-11-455 (draft EIS) or 197-11-340 (DNS), as appropriate [WAC 197-11-230(1)(b)(ii)]; and

  • The Department of Community Trade and Economic Development and other state agencies pursuant to RCW 36.70A.106.

7.2.5 Adopting the GMA Document

When a GMA document is integrated with a draft EIS, the agency may adopt the GMA document at the same time that the final EIS is issued. The jurisdiction does not have to wait the seven days usually required. In other instances, the GMA document may be adopted after any required comment period is completed.

7.2.6 Integrated Document Format

Although there are a few requirements, which are defined below, there is no standard format for an integrated GMA document. The overriding consideration is the quality of information and analysis at the appropriate scope and level of detail for the particular GMA document and not the format, length, or bulk of the document [WAC 197-11-235].

An EIS for a GMA action should contain sufficient environmental analysis to provide a basis for future decisions on projects. SEPA documents may be separate and accompany the GMA documents or they may be integrated. An integrated document must include:

  • A fact sheet. The fact sheet, containing the information required in WAC 197-11-440(2), must be the first section of the document.

  • An environmental summary. The environmental summary emphasizes the major conclusions, significant areas of controversy and uncertainty, if any, and the issues to be resolved including the environmental choices to be made and the effectiveness of mitigation measures. It should reflect SEPA’s substantive policies and highlight the primary environmental options that would be preserved or foreclosed by the proposed GMA action, taking into account cumulative impacts. It may discuss non-environmental factors, and should do so if relevant to resolving issues concerning the main environmental choices [WAC 197-11-440(4) and 235(5)].

  • A concise analysis of alternatives. This is a comparative environmental analysis of the principal alternative courses of action that are under consideration [WAC 197-11-440(5)]. Evaluating options helps determine whether the proposal should be revised to avoid or reduce environmental or other impacts. Alternatives discussed may be those presently being considered or considered and discarded earlier.

  • Comments and responses. The final integrated document must include the comments on the draft EIS/plan along with agency responses. Any comments received during the scoping process or on preliminary documents (or a summary of them) must be included in either the final integrated document or the supporting record, together with agency responses to these comments if prepared [WAC 197-11-235(7)].

  • Supporting record, analyses, and materials. Materials in the supporting record allow interested parties to identify and review the planning basis for the conclusions and analyses presented in the integrated GMA document as provided in Chapter 365-195 WAC, "Procedural Criteria for Adopting Comprehensive Plans and Development Regulations. An integrated document must contain a list of the principal analytical documents and other materials (such as meeting minutes, maps, models, tapes or videos) that have been prepared, received, or used to develop the GMA action. These materials are part of the official supporting record for SEPA compliance (see WAC 197-11-090). Annotated lists are encouraged, but not required, to assist current and future reviewers. Non EIS Integrated Documents

If a proposed GMA action is not likely to have a significant adverse environmental impact, an integrated GMA document that combines the formal SEPA document (such as an environmental checklist/DNS, a notice of adoption, or an addendum) with the GMA document is prepared.

If an environmental checklist is prepared for a GMA action, only Parts A (which serves as a fact sheet), C (responsible official's signature), and D (nonproject checklist) must be completed. An environmental summary as specified in WAC 197-11-235(5) is also required and may be combined with Part D of the checklist.

If an addendum is to accompany or be incorporated into an integrated GMA document, it must contain the information specified in WAC 197-11-235(5) for an environmental summary.

7.3 GMA Project Review

The Local Project Review Act, adopted in 1995 added new requirements for cities and counties to consolidate their permit and environmental review processes. Included are many procedural mandates for those cities and counties planning under GMA. Please see section 8. - Local Project Review Act for discussion of these requirements.

7.4 Planned Actions

In 1995, the legislature authorized a new category of project action in SEPA called a "planned action." Designating specific types of projects as planned action projects shifts environmental review of a project from the time a permit application is made to an earlier phase in the planning process. The intent is to provide a more streamlined environmental review process at the project stage by conducting more detailed environmental analysis during planning. Early environmental review provides more certainty to permit applicants with respect to what will be required and to the public with respect to how the environmental impacts will be addressed.

The GMA city or county must first complete an EIS which addresses the likely significant adverse environmental impacts of the planned action. After completing the EIS, the GMA city or county designates by ordinance or resolution those types of projects to be considered planned actions, including mitigation measures that will be applied. The types of project action must be limited to certain types of development or to a specific geographic area that is less extensive than a city or town’s jurisdictional boundaries. (See RCW 43.21C.031, WAC 197-11-164 and 168 for requirements and restrictions on the designation of planned actions.)

Use of the planned action process is restricted to cities and counties planning under GMA. GMA jurisdictions are required to develop both a broader scope and deeper level of planning that provides the foundation for this early type of review.


While normal project review requires a threshold determination, a project qualifying as a planned action project does not require a new threshold determination. If the city or county reviews the project, verifies that it is consistent with the planned action project(s) previously designated, and determines that the impacts are adequately addressed in the EIS on which the planned action relies, project permit review continues without a threshold determination. All of the project’s significant probable environment impacts must have been addressed at the plan level in order for the project to qualify as a planned action. [If a project does not qualify as a planned action because of likely significant adverse environmental impacts that were not adequately addressed in the EIS, a threshold determination is required. Environmental review for the project may rely on the environmental analysis in the EIS, and additional analysis need only address those impacts not addressed in the previous EIS.]

Designating planned action projects reduces permit-processing time. There are no SEPA public notice requirements or procedural administrative appeals at the project level because a threshold determination or new EIS is not required. The only notice requirements are those required for the underlying permit.

The designation of planned action projects will only be appropriate in limited situations. The designation of planned action projects is probably most appropriate for:

  • Smaller geographic areas;

  • Relatively homogenous geographic areas where future development types, site-specific conditions, and impacts can be more easily forecast;

  • Development sites with significant overlapping regulatory requirements; or

  • Routine types of development with few impacts.

Examples of appropriate project actions limited to a specific geographic area might be projects anticipated in a subarea or neighborhood plan with a limited number of development types. Another example could be a large parcel in single ownership, such as a university campus or a large manufacturing complex where project construction will be done in phases.

7.4.1 Tip

When considering whether to designate planned action projects, GMA counties and cities need to be aware that the process can be costly to the jurisdiction. More up-front environmental analysis and review by the county or city in the GMA planning process will be required. As a result, the county or city pays for studies and processes that would normally be paid for by private applicants. [Although there is no formal method under state law to recover the costs of up-front analysis, some jurisdictions have developed cost-sharing agreements with local property owners and associations interested in utilizing the planned action process.]

7.4.2 Designing Planned Action Projects

The basic steps in designating planned action projects are to prepare an EIS, designate the planned action projects by ordinance or resolution, and review permit applications for projects proposed as consistent with the designated planned action.

Step 1:  Prepare the EIS (WAC 197-11-164)

The significant environmental impacts of projects designated as planned actions must be identified and adequately addressed in an EIS [WAC 197-11-164]. The EIS must be prepared for a GMA comprehensive plan or subarea plan, a master planned development or resort, a fully contained community, or a phased project [RCW 43.21C.031].

Planned action projects should only be designated when a county or city can reasonably analyze the site-specific impacts that will occur as a result of the types of projects designated, and can adequately address those impacts in the EIS. A generalized analysis of cumulative environmental impacts will not provide enough information to address a project’s impacts when it is time for the jurisdiction to issue permits for specific projects proposed as planned action projects.

Step 2:  Adopt Planned Action Ordinance or Resolution

Planned action projects must be designated or identified in an ordinance or resolution adopted by a GMA county or city [WAC 197-11-168]. There are a number of procedural requirements for this. A GMA county/city considering the adoption of a planned action ordinance or resolution should review the requirements in RCW 43.21C.031 and WAC 197-11-164, 168, and 315. The following specific points should be considered:

An extensive level of public review for both the EIS and the proposed planned action ordinance is crucial. Since a new threshold determination or EIS is not required when a permit application is received, there may not be an opportunity for public review or administrative appeal at the project review stage. In order to build support for an abbreviated permit process, public awareness is needed at these earlier phases.

Although the statute allows a jurisdiction to designate planned action projects by an ordinance or resolution, adoption by resolution is not recommended. The provisions for adoption of a resolution do not allow sufficient opportunity for public participation.

The planned action ordinance should be as specific as possible, should indicate where in the EIS or associated planning document the projects’ environmental impacts have been addressed, and should include or reference mitigation measures which will be required for a project to qualify as a planned action project. For example, the ordinance should indicate what mitigation has been identified in the EIS or what level of service has been accepted in the subarea plan for traffic impacts.

If desired, the city or county may set a time limit in the ordinance during which the planned action designation is valid. If a GMA county/city does set a time limit on the designation, it should consider how this affects any permits for which there is an expiration date. For example, a project with a permit valid for five years is found to qualify as a planned action project and the permit is issued just prior to the sunset date for the planned action designation. Is the project still considered a planned action project for the life of the permit after the sunset date?

Although a GMA county or city must require the applicant to submit a SEPA environmental checklist with a project proposed as a planned action project, a revised format for the checklist may be developed by the city or county. A draft of the revised form must be sent to Ecology for a thirty-day review [WAC 197-11-315(2)]. While not required at this phase, it would be helpful if the revised checklist were developed in conjunction with the ordinance or resolution designating planned action projects.

Step 3:  Review the Proposed Planned Action Project (WAC-197-11-172)

When a permit application and environmental checklist are submitted for a project that is being proposed as a planned action project, the city or county must verify:

  • The project meets the description of any project(s) designated as a planned action by ordinance or resolution;

  • The probable significant adverse environmental impacts were adequately addressed in the EIS; and

  • The project includes any conditions or mitigation measures outlined in the ordinance or resolution.

If the project meets the above requirements, the project qualifies as a planned action project. Neither a threshold determination nor an EIS will be required. Consequently, there will be no administrative SEPA procedural appeal (an appeal of whether the proper steps in the SEPA process were followed). The planned action project will continue through the permit process pursuant to any notice and other requirements contained in the development regulations.

If the project does not meet the requirements of the planned action ordinance or resolution, or if the EIS did not adequately address all probable significant adverse environmental impacts, the project is not a planned action project. In this instance, the city or county must then make a threshold determination on the project. The project would go through normal environmental review as part of project review. The county or city may still rely on the environmental information contained in the EIS and supporting documents in analyzing the project’s environmental impacts and making the threshold determination. If an EIS or SEIS is found to be necessary for the project, it only needs to address those environmental impacts not adequately addressed in the previous EIS. (See section 2.7. Using Existing Documents.)

7.4.3 Consistency Requirements for Planned Action Projects

A project proposed as a planned action project must still be analyzed for consistency with the local comprehensive plan and development regulations (see section on Analyzing Consistency). Designation of planned action projects does not limit a city or county from using other authority (e.g. transportation mitigation ordinances) to place conditions on a project; it only addresses procedural SEPA requirements. [WAC 197-11-172(2)(a) specifically states that "Nothing in this section limits a GMA county/city from using this chapter or other applicable law to place conditions on the project in order to mitigate nonsignificant impacts through the normal local project review and permitting process."] The GMA county or city may still use its SEPA substantive authority or other applicable laws or regulations to impose conditions on a project qualifying as a planned action project [RCW 43.21C.031(1)].


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