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Chair and members of the Commission, thank you for the opportunity to speak this <br /> evening. My name is Gina Peckman and I am a community member of Kittitas County along <br /> with a member of the Easton community working on the sub-area plan. <br /> The Growth Management Act is built on a simple principle. Goal 12, codified in RCW <br /> 36.70A.020(12), states it plainly: public facilities and services necessary to support <br /> development shall be adequate to serve the development at the time it is available for <br /> occupancy and use, without decreasing current service levels below locally established <br /> minimum standards. <br /> That is the concurrency requirement. It is not optional. It is the law. <br /> RCW 36.70A.070(6)(b) goes further—it requires the County to adopt and enforce <br /> ordinances that prohibit development approval if the development causes level of service <br /> to decline below adopted standards, unless improvements or strategies are in place at the <br /> time of development, or a financial commitment exists to complete them within six years. <br /> (And in Kittitas County Conservation v. Kittitas County,the Growth Management Hearings <br /> Board found this County noncompliant on transportation concurrency—specifically <br /> because the County could not cite any provisions that would prohibit development <br /> approval when level of service standards were not met.That finding is still instructive <br /> today. <br /> ,APR-P73 expands LAMIRD boundaries—pushing more intensive development into rural <br /> areas that have no sewer, limited water,volunteer fire service, and roads the County <br /> already cannot afford to maintain.The County's own transportation analysis identifies a <br /> $91 million funding deficit over 20 years. And the proposed solution? Privatize the roads <br /> and shift the costs to rural residents. <br /> LU-P39 opens rural commercial zones to residential, and tourism uses with no size limits, <br /> no density caps, and no infrastructure triggers.There is no concurrency analysis.There is <br /> no requirement that water, sewer, fire, or road capacity be confirmed before development <br /> is approved. <br /> The Workforce Housing Rural Innovation Overlay can be applied anywhere residential is <br /> permitted,which is essentially the entire county, again with no concurrency requirements <br /> tied to it. <br /> And PUD guardrails under RR-P21 are being weakened, removing the constraint that PUDs <br /> in rural areas cannot create high-density environments requiring urban services. <br />