(dissenting) — I dissent. King County did comply with the requisite statutory and regulatory requirements and, it did not err in relying on the provisions of the King County Comprehensive Plan in denying Cougar Mountain's subdivision application.
I would affirm the trial court.
Facts
This case is about the approval of a subdivision of a 128-acre undeveloped parcel of land into 90 building lots for new residences. The proposed site for this subdivision is adjacent to Ames Lake Wetland 57 which is rated as a unique and outstanding wetland. The water flowing into this wetland flows into a nearby wetland, Ames Lake Wetland 58. A wetland is a swamp, marsh or bog that supports vegetation typically adapted for life in saturated soil condition. The site itself contains several small knolls, ravines and depressions throughout. These ravines and depressions form the headwater extensions of tributaries that flow primarily into the wetlands. The majority of the eastern half of the site is an erosion hazard area. Terrain on the site varies from relatively level to steep slopes.
Cougar Mountain Associates filed an application for approval of this subdivision. An environmental impact statement was required because the proposal would have *759significant adverse environmental impacts. After the environmental information was reviewed, the King County Council, in ordinance 7945 (February 2, 1987), denied the proposal pursuant to its authority under SEPA.
Statutory Requirements
In order to deny a proposal under SEPA, "an agency must find that: (1) The proposal would result in significant adverse impacts identified in a final or supplemental environmental impact statement prepared under this chapter; and (2) reasonable mitigation measures are insufficient to mitigate the identified impact." (Italics mine.) RCW 43.21C.060. King County followed this mandate when it adopted and incorporated findings, conclusions and decision in ordinance 7945 denying Cougar Mountain's proposal. While the conclusions may not be "sufficiently specific", as the majority holds, the incorporated findings of ordinance 7945 are sufficiently specific to comply with the statutory requirements. These findings are discussed below.
The EIS and finding 5 detailed the unavoidable adverse impacts of the project and identified surface water runoff, erosion, public services, water quality, wildlife and impacts on existing land use as major issues.
Finding 7 discussed the impacts on the wetlands and Ames Creek as follows:
A . . . Development in the density proposed [by the subdivision] can be expected to significantly disturb Wetland 57 with an adverse impact on this unique and outstanding wetland. The impact on this wetland can be expected to he particularly adverse during March through June which is the breeding season for both migratory fowl and resident wildlife species.
B. Flowing out of Ames Lake Wetland No. 57 is Ames Creek which is rated by the Department of Natural Resources as a Type 3 water. [This classification] is applied to natural waters which among other things are used by significant numbers of fish for spawning, rearing and migration, are used by significant numbers of resident, game fish, or are highly significant for the protection of downstream water quality.
*760The recommended mitigation measures for both the wetlands and the creek were detention/retention ponds and native growth protection easements. The King County Council found this mitigating measure to be insufficient in finding 7:
A . . . Although the proposal contemplates mitigation of any impacts on the wetlands by the provision of a native growth easement between the wetland and any development, such native growth protection easements are difficult to enforce and therefore risk losing their integrity. . . .
B ... As with the mitigation for Ames Lake Westland [sic] No. 57, a native growth protection easement is proposed to mitigate the adverse impacts of the development on Ames Creek.
The EIS and finding 6 identified the significant impacts on public services: The proposal would create a need to upgrade the fire station in Carnation. It would also require the addition of one more police officer to the area precinct. The solid waste disposal transfer station is currently operating at capacity and the new site for a use facility has not been determined. The junior and senior high schools would be placed above their planned capacity and could have adverse effects on the ability of the school district to staff and provide educational services, particularly due to current state funding levels and the lag time of the new homes being placed on the tax rolls.
The Council in its findings was concerned with the funding for these needed public services. The Council's concern was well grounded, given the recent political climate in rural areas against the passage of new bond issues. The Council found that the proposal adversely impacted public services in the area. The measures to deal with the cost of these services were insufficient to mitigate the impacts discussed.
In finding 8, the Council also considered the pressure to alter surrounding land use. A proposed project's potential for creating pressure to alter surrounding land use may properly be evaluated in a decision of this nature. Polygon *761Corp. v. Seattle, 90 Wn.2d 59, 70, 578 P.2d 1309 (1978). Specifically, the Council found an
unavoidable adverse impact of the proposal through the creation of pressure for similar density developments in the area through the introduction of ... an estimated 307 people . . . and the concomitant expansion and extension of services into previously undeveloped areas for purposes of providing service to the proposal.
The Council considered this and found the resulting pressures unavoidable.
The King County Council's incorporated findings of ordinance 7945 identified the significant adverse impacts, the insufficient mitigation measures suggested, and the Council's conclusion was that based on SEPA this subdivision as currently presented should be denied. King County Ordinance 7945 was "sufficiently specific" to comply with the statutory requirements.
Use of Comprehensive Plan
In the subject case, the majority holds that the zoning code repeals and/or supersedes SEPA if the comprehensive plan is not in accordance with the zoning code. The majority, without reasoning or authority, unilaterally gives legislative bodies of municipal corporations veto powers over SEPA. By doing this the majority overrules all those cases which hold that SEPA "overlays local ordinances and must be enforced even where a particular use is allowed by local law or policy." These cases are Cook v. Clallam Cy., 27 Wn. App. 410, 415, 618 P.2d 1030 (1980), review denied, 96 Wn.2d 1008 (1981); West Main Assocs. v. Bellevue, 106 Wn.2d 47, 53, 720 P.2d 782 (1986); Polygon Corp. v. Seattle, 90 Wn.2d 59, 65, 578 P.2d 1309 (1978).
The majority relies on Nagatani Bros., Inc. v. Skagit Cy. Bd. of Comm'rs, 108 Wn.2d 477, 480, 739 P.2d 696 (1987), (citing Norco Constr., Inc. v. King Cy., 97 Wn.2d 680, 649 P.2d 103 (1982)) for its proposition that an "'inconsistency between the zoning ordinance and the comprehensive plan must be resolved by application of the zoning ordinance.'" These cases relied on by the majority did not involve the *762use of standards in a comprehensive plan where the plan standards have been specifically adopted as a basis for making local SEPA decisions. In view of this, the majority's reliance on Nagatani is misplaced.
The majority's position that a plan should be approved since it is in compliance with the zoning code misconstrues the nature of the SEPA mandate for environmental considerations. Department of Natural Resources v. Thurston Cy., 92 Wn.2d 656, 665, 601 P.2d 494 (1979), cert. denied, 449 U.S. 830 (1980).
An environmental review process reveals impacts that general zoning regulations do not and could not take into account. An example of such impacts would be the discovery of wetlands, steep slopes, or unstable soils on a particular piece of property. Thus, a proposal that is in compliance with a zoning regulation may nonetheless have environmental impacts, and under SEPA this proposal may be denied. Polygon, at 66; West Main Assocs. v. Bellevue, 49 Wn. App. 513, 525, 742 P.2d 1266 (1987); Cook v. Clallam Cy., at 415; see Department of Natural Resources, at 667.
It is important to note that SEPA policies have regulatory effect only when a proposed project has been determined to significantly affect the environment. West Main Assocs., at 525. When SEPA is not involved the question of whether a specific zoning ordinance prevails over a general comprehensive plan becomes a different situation from the present case.
Here, SEPA is involved in Cougar Mountain's proposed subdivision since it is a "major action significantly affecting the quality of the environment. ” The King County Council has enacted a SEPA ordinance which expressly adopts the comprehensive plan as a local SEPA policy. The King County Council, in addition to adverse environmental impacts, specifically based its denial of the Cougar Mountain proposal on policies and plans identified in this ordinance. In finding 10, the substantive basis for the County to deny the proposal of Ames Lake Hills was set forth:
*76310. In 1984, . . . King County identified in King County Code 20.44.080 both the policies of the state environmental policy act and the King County Comprehensive Plan as policies . . . which, among others, form the basis for the exercise of the county's substantive authority under Chapter 43.21C RCW.
The decision itself in ordinance 7945 states the basis for denial:
The proposal as presently envisioned would likely result in significant adverse environmental impacts which cannot be mitigated by reasonable mitigation measures. The proposal also conflicts with numerous policies of the King County Comprehensive Plan-1985. Therefore, pursuant to the authority provided by Chapter 43.21C RCW and King County Code Chapter 20.44, the proposal is denied with leave to submit a revised application.
Since the Council adopted the comprehensive plan as a local SEPA policy, it was entitled to rely on the comprehensive plan in denying the proposal under SEPA. West Main Assocs., at 522.
Conclusion
In sum, the Council complied with applicable statutory requirements in setting forth the basis for its decision, and this decision is supported by information set forth in the EIS and the adopted SEPA policies. Furthermore, the County did not err in relying on the comprehensive plan in denying the application. The record does not substantiate the majority's position that the court is "left with the definite and firm conviction that a mistake has been committed" by the Council. The Council's decision to deny Cougar Mountain's application passes the clearly erroneous test. I would affirm.
Pearson, C.J., concurs with Dore, J.