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Re: Comments on the Kittitas County 2026 Comprehensive Plan update March 2, 2026 Page 8 including, but not limited to, government-assisted housing, housing for moderate, low, very low, and extremely low-income households, manufactured housing, multifamily housing, group homes, foster care facilities, emergency housing, emergency shelters, permanent supportive housing, and within an urban growth area boundary, consideration of duplexes, triplexes, and townhomes[J" The State of Washington Department of Commerce has documented that in moderate-cost communities to provide housing affordable to families and individuals earning 8o percent or less of the area median income requires low-rise multifamily and mid- rise multifamily housing and accessory dwelling units.22 In moderate cost jurisdictions townhomes, duplexes, triplexes, and quadplexes can be affordable to families earning 8o to 120 percent Area Median Income (AMI).23 Middle housing is not affordable to families earning 8o percent or less AMI.�4 Detached single family homes are only affordable to families earning more than 120 percent AMI.�5 Table 4-2 relies in part on duplexes and triplexes to provide housing affordable to families earning 8o percent or less AMI. This is not possible. Duplexes, triplexes, and manufactured, mobile, and modular homes cannot be produced at rents affordable to families earning zero to less than 30 percent AMI or 30 to less than 50 percent AMI. We recommend focusing on low-rise multifamily and mid-rise multifamily housing and accessory dwelling units within urban growth areas.z6 Affordable housing should be focused in cities and urban growth areas. Table 4-2 on page 81 allocates the unincorporated rural county 156 units of housing affordable to families earning between 50 to 8o percent AMI to be produced with duplexes and accessory dwelling units. The State of Washington Department of Commerce has documented that to provide housing affordable to families and individuals earning 8o percent or less of the area median income requires low-rise multifamily and mid-rise multifamily housing and accessory dwelling units.27 In moderate cost jurisdictions townhomes, duplexes, triplexes, and quadplexes can be affordable to families earning 8o to 120 percent AMI.2$ Middle housing is not affordable to families earning 8o percent or less AMI.�9 In addition, there are significant water constraints and placing affordable housing in 22 Washington States Department of Commerce, Local Government Division Growth Management Services, Guidance for Updating Your Housing Element: Updating your housing element to address new requirements P. 36 (Aug. 2023, updated Jan. 2026). �3 Id. �4 Id. �5 Id. 26 Id. 29 Id. 2s Id. �9 Id. L