In a decision which promises to add momentum to a significant recent trend in zoning law, the Washington Supreme Court has invalidated a city's rezoning of farmland because the zoning body failed to consider or attempt to mitigate the adverse environmental and fiscal impacts of the action on the surrounding region. The court's ruling in Save a Valuable Environment v. City of Bothell¹ represents the first explicit application of the "regional welfare" test recently articulated by several state courts² to zoning measures that threaten generalized adverse environmental effects and are not directly related to questions of housing supply.

Considering the importance of the ruling, the court's analysis was relatively brief. Moreover, the decision was at least partially based on a state statutory provision explicitly recognizing every citizen's right to a healthful environment. The opinion's precedential impact can therefore not be assessed with certainty. If followed by courts in other states, however, this broad requirement that localities fully consider and mitigate the adverse regional impacts of all zoning decisions could greatly improve the caliber of local land use decision making across the nation and may also serve as a strong impetus for increased regional land use planning.