Summary
The Washington Supreme Court reviewed whether the City of Olympia's transportation impact fee ordinance complied with the Growth Management Act's impact-fee statutes. The court held that the statutes did not require individualized assessments of a development's direct impact on each planned system improvement, and it reversed the Court of Appeals.
Holdings
- The Growth Management Act impact-fee statutes do not require a local government to calculate an impact fee by making an individualized assessment of the new development's direct impact on each improvement planned within a service area. A local government may calculate the fee by relating the development to area-wide system improvements through a reasonable service area and legislatively adopted fee schedule.
- Olympia's method for calculating the transportation impact fee complied with the plain language of RCW 82.02.050-.090.
Questions Presented
- Whether Washington's Growth Management Act impact-fee statutes, RCW 82.02.050-.090, require a local government to make an individualized assessment of a development's direct impact on each system improvement planned within a service area.
- Whether Olympia's transportation impact-fee methodology, based on a fee schedule and area-wide transportation improvements within a single urban-growth-area service area, complied with RCW 82.02.050(3) and RCW 82.02.060.
Disposition
reversed
Cases Cited (22)
- City of Olympia v. Drebick, 119 Wash. App. 774, 83 P.3d 443 (2004)(reversed)
- Dep't of Ecology v. Campbell & Gwinn, L.L.C., 146 Wash. 2d 1, 43 P.3d 4 (2002)(followed)
- Pinecrest Homeowners Ass'n v. Glen A. Cloninger & Assocs., 151 Wash. 2d 279, 87 P.3d 1176 (2004)(followed)
- State v. J.P., 149 Wash. 2d 444, 69 P.3d 318 (2003)(followed)
- Dennis v. Dep't of Labor & Indus., 109 Wash. 2d 467, 745 P.2d 1295 (1987)(followed)
- C.J.C. v. Corp. of the Catholic Bishop of Yakima, 138 Wash. 2d 699, 985 P.2d 262 (1999)(followed)
- State v. Clausing, 147 Wash. 2d 620, 56 P.3d 550 (2002)(followed)
- Cowiche Growers, Inc. v. Bates, 10 Wash. 2d 585, 117 P.2d 624 (1941)(followed)
- New Castle Investments v. City of LaCenter, 98 Wash. App. 224, 989 P.2d 569 (1999), review denied, 140 Wash. 2d 1019, 5 P.3d 9 (2000)(followed)
- Wellington River Hollow, L.L.C. v. King County, 121 Wash. App. 224, 54 P.3d 213 (2002), review denied, 149 Wash. 2d 1014, 70 P.3d 965 (2003)(followed)
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