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Re: Comments on the Kittitas County 2026 Comprehensive Plan update <br />March 2, 2026 <br />Page g <br />rural areas increases transportation costs for families and transportation and <br />public service costs for the County. We recommend that these housing targets <br />should be reallocated to urban growth areas. Planning on affordable housing units <br />outside urban growth areas means that the county will not achieve its affordable <br />housing targets and there will not be opportunities for all income groups. <br />Similarly, the Washington Farmworker Housing Needs Assessment recommended <br />that to provide more affordable farm worker housing cities should be encouraged <br />"to increase zoning and infrastructure investments for multi -family housing <br />within urban growth areas.1130 <br />Low-rise multifamily and mid -rise multifamily housing are urban densities and <br />are only allowed in urban growth areas. Planning on providing housing affordable <br />families earning 8o percent or less AMI in the rural area will fail. Instead these <br />housing targets should be reallocated to urban growth areas near jobs where the <br />affordable housing can be provided. <br />Address the other requirements for housing elements in RCW 36.70A.020(2). <br />RCW 36.7oA.020(2)(d)(ii) requires the comprehensive plan to "[d]ocument[] <br />programs and actions needed to achieve housing availability including gaps in <br />local funding, barriers such as development regulations, and other limitations ..." <br />We were unable to identify the programs, actions, and gaps in local funding in the <br />Housing Element or the Kittitas County - Housing Needs Assessment. <br />RCW 36.7oA.020(2)(e) requires the housing element to identify "local policies and <br />regulations that result in racially disparate impacts, displacement, and exclusion <br />in housing ...." We were unable to identify the programs, actions, and gaps in local <br />funding in the Housing Element or the Kittitas County - Housing Needs <br />Assessment. <br />RCW 36.7oA.020(2)(f) requires the housing element to "[i]dentif[] and <br />implements policies and regulations to address and begin to undo racially <br />disparate impacts, displacement, and exclusion in housing caused by local policies, <br />plans, and actions ...." RCW 36.7oA.020(2)(g) requires the housing element to <br />[i]dentif[y] areas that may be at higher risk of displacement from market forces <br />30 BERK Consulting, Washington Farmworker Housing Needs Assessment p. 184 (The Washington <br />State Department of Commerce: Jan. 2022) last accessed on Feb. 27, 2026, at: <br />https://www.commerce.wa.gov/wp- <br />content/ uploads / 20 2 2 / o4 / CommerceReports CSHD FarmworkerHousing Final 4.26.22.pdf and at <br />the link on the last page of this letter with the filename: <br />"CommerceReports_CSHD_FarmworkerHousing_Final_4.26.22.pdf." <br />L <br />