“Instead of following the common-sense approach of only redesignating land that is no longer publicly owned, the County is proposing to redesignate all of the land currently designated “Public Lands,” whether it is publicly owned or not. While we have not seen the new Future Land Use Map and zoning map, it appears all of areas current designated as “Public Lands” will be given a rural comprehensive plan designation. This approach violates the Growth Management Act (GMA) because some of these lands, such as the State of Washington Department of Natural Resources (DNR) timber trust lands, qualify as forest lands of long-term commercial significance and so should be given a “Natural Resource Lands 40” comprehensive plan designation and zone.40 Some DNR timber trust lands are already designated “Natural Resource Lands 40,” but other suitable forest lands are not. A broad-brush rezone, as is proposed by Application CPU-18-POC, is likely to make this and other errors. Case-by-case amendments can be more carefully done.