land market supply factor employed was reasonable. “[A] market factor represents the estimated percentage of net develop-able acres contained within a UGA that, due to idiosyncratic market forces, is likely to remain undeveloped over the course of the twenty-year planning cycle.” Brent D. Lloyd, Accommodating Growth or Enabling Sprawl? The Role of Population Growth Projections in Comprehensive Planning under the Washington State Growth Management Act, 36 Gonz. L. Rev. 73, 118 (2001). Beginning in 1995, the GMHBs adopted 25 percent as the bright-line test for determining whether a market supply factor is reasonable. City of Bremerton v. Kitsap County, No. 95-3-0039, 1995 GMHB LEXIS 384, at *87, 1995 WL 903165 (Cent. Puget Sound Growth Mgmt. Hr’gs Bd. Final Dec. and Order Oct. 6,1995) (<HOLDING>). However, a GMHB cannot create a bright-line
holding market supply factors of 25 percent or less are presumed reasonable while factors exceeding 25 percent will be subject to increased scrutiny holding that only relevant factors must be considered recognizing same factors holding approximately 21 percent of petitioners common stock holding that where the proper rate of interest was eight percent but the court ordered six percent movant had waived right to higher rate by not raising the issue earlier in its petition for review