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