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Easton Subarea Plan — Public Comment <br />• Development that converts open space, forest, or natural landscape into predominantly <br />built environment <br />• Uses that create strip commercial patterns along highway corridors, especially near <br />other LAMIRD commercial uses <br />• Uses incompatible with adjacent working forest land, airport operations, or outdoor <br />recreation values <br />• Any development within a Critical Aquifer Recharge Area that has not undergone a <br />verified CARA review, mitigation sequencing, and Best Available Science analysis <br />• 24/7 commercial operations that generate noise, light pollution, and heavy vehicle traffic <br />incompatible with rural character <br />7. USE THE RIGHT PROCESS FOR THE RIGHT PROPOSAL <br />The subarea plan should make clear that a variance is not the appropriate mechanism for <br />approving development that exceeds Type 3 LAMIRD dimensional standards. A variance <br />addresses minor deviations in cases of practical difficulty or unnecessary hardship. It is not a <br />tool for authorizing development at a fundamentally different scale or intensity than what the <br />zoning allows. <br />Recommended subarea plan language: "Any proposed development that exceeds the <br />dimensional standards established in KCC 17.15.070 for rural General Commercial zoning shall <br />not be processed as a variance. Proposals that would fundamentally alter the character, scale, <br />or intensity of land use shall be evaluated as a Comprehensive Plan amendment and rezone, <br />subject to full public participation, environmental review, and policy analysis as required by the <br />Growth Management Act" <br />8. SUMMARY OF REQUESTED SUBAREA PLAN ADDITIONS <br />I respectfully request that the Easton Subarea Plan be updated to include the following <br />provisions: <br />4. Restate the binding dimensional limits from KCC 17.15.070 (30,000 sq ft total area, <br />4,000 sq ft retail, 33% impervious surface) as hard caps that cannot be exceeded <br />through variance. <br />5. Require documented proof of prior commercial occupancy through historical aerial <br />photography and county records before any Type 3 LAMIRD development is approved. <br />6. Mandate verified critical areas review cross-referenced against County CARA maps <br />and Group A Wellhead Protection Area maps for every development application. <br />7. Require mitigation sequencing and Best Available Science for all proposals within or <br />within 200 feet of a Critical Aquifer Recharge Area. <br />8. Require compatibility review for proposals adjacent to DNR resource lands and the <br />Easton State Airport, consistent with Comprehensive Plan Policies T-P44 and RR-P2. <br />9. Prohibit strip commercial development patterns along highway corridors, consistent <br />with GMA and Comprehensive Plan policy. <br />10. Direct over -scale proposals to the Comprehensive Plan amendment and rezone <br />process, not variance, to ensure adequate public participation and environmental <br />review. <br />Page 4 <br />