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Robert D. Johns (Retired)
<br />Lindsey Ozbolt, Planning Official October 30, 2019
<br />Community Development Services
<br />Kittitas Countv
<br />411 N. Ruby Street, Suite 2
<br />Ellensburg, WA 98926
<br />Re: Project File No. DV -19-00001, Marian Meadows
<br />Dear Ms. Ozbolt:
<br />On behalf of Easton Ridge Land Company (ERLC), Martens Enterprises, LLC and the
<br />Marian Meadows development proposal, we provide the following written comments on
<br />the above referenced Application and the proposed mitigation for impacts to the Easton
<br />School District (the "District"). As you are aware, ERLC has volunteered to pay mitigation
<br />for impacts to the District in the amount of $500 per household for the Marion Meadows
<br />residential development. To the best of our information, this is the first time a project
<br />developer in Kittitas County has volunteered to pay mitigation, of any amount, to the
<br />District for residential housing units and the first time the District has ever asked for such
<br />mitigation from any new residential development.
<br />The District has responded that it believes this mitigation is insufficient, but has not
<br />provided any concrete information on which it relies. ERLC has three concerns with the
<br />District's response. First, the District's argument that the number of students from Marian
<br />Meadows would abolish the District's small school funding status is misleading, if not
<br />entirely incorrect. Second, the District has historically never required mitigation from new
<br />developments. Thus, the District's own choices have led to this supposedly dire situation,
<br />not Marian Meadows. Third, in light of the above, equating any loss in public funding to
<br />the proportional impacts ofthe Marian Meadows development would, not only be wrong,
<br />but also unlawful under chapter 43.21C RCW, the State Environmental Policy Act
<br />("SEPA") and chapter 82.02 RCW, the State impact fee and voluntary mitigation statute.
<br />Easton School District's Funding
<br />The District relies heavily on its status as a Small School District, as defined in state law,
<br />and the expectation that the students added by Marian Meadows will be greater than reports
<br />conclude, creating a tipping point for the District's facilities. Whether this latter point holds
<br />any truth to it is essential to the District's argument. As demonstrated below, the District
<br />already lacks small district status for much of its program. There is also a significant
<br />difference between even the highest estimates and the actual number of students Marian
<br />Meadows would have to contribute to deprive the District of its small district status for the
<br />T. (425) 451-2812 • F: (425) 451-2818
<br />11 201 SE 8th St. • Suite 120 • Bellevue, WA 58004
<br />www.jmmklanduselaw.com
<br />Michael P. Monroe
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<br />Dean Williams
<br />Lindsey Ozbolt, Planning Official October 30, 2019
<br />Community Development Services
<br />Kittitas Countv
<br />411 N. Ruby Street, Suite 2
<br />Ellensburg, WA 98926
<br />Re: Project File No. DV -19-00001, Marian Meadows
<br />Dear Ms. Ozbolt:
<br />On behalf of Easton Ridge Land Company (ERLC), Martens Enterprises, LLC and the
<br />Marian Meadows development proposal, we provide the following written comments on
<br />the above referenced Application and the proposed mitigation for impacts to the Easton
<br />School District (the "District"). As you are aware, ERLC has volunteered to pay mitigation
<br />for impacts to the District in the amount of $500 per household for the Marion Meadows
<br />residential development. To the best of our information, this is the first time a project
<br />developer in Kittitas County has volunteered to pay mitigation, of any amount, to the
<br />District for residential housing units and the first time the District has ever asked for such
<br />mitigation from any new residential development.
<br />The District has responded that it believes this mitigation is insufficient, but has not
<br />provided any concrete information on which it relies. ERLC has three concerns with the
<br />District's response. First, the District's argument that the number of students from Marian
<br />Meadows would abolish the District's small school funding status is misleading, if not
<br />entirely incorrect. Second, the District has historically never required mitigation from new
<br />developments. Thus, the District's own choices have led to this supposedly dire situation,
<br />not Marian Meadows. Third, in light of the above, equating any loss in public funding to
<br />the proportional impacts ofthe Marian Meadows development would, not only be wrong,
<br />but also unlawful under chapter 43.21C RCW, the State Environmental Policy Act
<br />("SEPA") and chapter 82.02 RCW, the State impact fee and voluntary mitigation statute.
<br />Easton School District's Funding
<br />The District relies heavily on its status as a Small School District, as defined in state law,
<br />and the expectation that the students added by Marian Meadows will be greater than reports
<br />conclude, creating a tipping point for the District's facilities. Whether this latter point holds
<br />any truth to it is essential to the District's argument. As demonstrated below, the District
<br />already lacks small district status for much of its program. There is also a significant
<br />difference between even the highest estimates and the actual number of students Marian
<br />Meadows would have to contribute to deprive the District of its small district status for the
<br />T. (425) 451-2812 • F: (425) 451-2818
<br />11 201 SE 8th St. • Suite 120 • Bellevue, WA 58004
<br />www.jmmklanduselaw.com
<br />
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