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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 <br />ohnsDarrell <br />�7 jj — ���1 �� <br />�Y Sl agaKo o -skov L <br />S. Mifisunag �z <br />Dua.na T. Kolouskova <br />Vicki E. Orrico <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 />