2026-03-30-cds-study-session-supporting-documents

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SUBMITTED VIA ONLINE COMMENT FORM 3/2/2026 Comment #003 AVAILABLE ON THE PROJECT WEBSITE (KittitasCou nty2026.com) "Dear Kittitas County Planning Department, As concerned residents of Washington State with an interest in sustainable rural development, we are submitting this public comment on the Easton Subarea Plan, particularly regarding the integration and application of Type 3 Limited Areas of More Intensive Rural Development (LAMIRDs) under the Growth Management Act (GMA). Our comments are informed by a detailed review of expert analysis on similar proposals in the area, such as the Sparks Park-Easton Travel Center variance (File VA-23-00003), which highlights critical inconsistencies with state and county planning standards. These issues underscore the need for stricter adherence to rural character protection in any subarea planning updates. 1.Scale and Intensity of Development: The subarea plan should explicitly limit new commercial developments to isolated small-scale businesses to preserve rural character. For instance, proposals exceeding Kittitas County Code (KCC) 17.15.070 limits, such as those over 30,000 square feet in area, 33% impervious surfaces, or 4,000 square feet of retail, risk creating urban-like sprawl along highway corridors. In the case of large-scale facilities like travel centers with extensive impervious surfaces (e.g., 69% coverage over 15+ acres), this violates Comprehensive Plan standards and discourages low-density rural sprawl as prohibited by the GMA. We urge the plan to incorporate binding size caps and intensity thresholds to ensure new uses remain compatible with surrounding rural lands. 2.Utilization of Pre-Existing Sites: LAMIRDs are intended as a one-time recognition of areas in existence prior to 1991, not for ongoing expansion onto vacant lands. The subarea plan must prohibit designations on sites without evidence of prior commercial occupancy, such as tree-covered parcels shown in historical aerial photos (e.g., 2009 Easton Study Area imagery). Allowing development on undeveloped sites contradicts RCW 36.70A.070(5)(d) and could lead to inappropriate conversion of rural lands. Recommendations include mandatory historical site reviews using GIS and aerial data to verify pre-1991 uses. 3.Conformance to Rural Character: The plan's definition of rural character, emphasizing open spaces, natural landscapes, vegetation predominance, traditional rural lifestyles, wildlife compatibility, and protection of groundwater, must be rigorously enforced. Developments that introduce 11-12 acres of impervious surfaces within Critical Aquifer Recharge Areas (CARAs) or near Group A Wellhead Protection Areas pose significant risks to groundwater resources, as seen in proposals covering 74% of sites with impervious materials. This conflicts with KCC 17A.03.020 and Best Available Science requirements. Additionally, incompatibility with adjacent resource lands (e.g., state-owned forests) and facilities like Easton State Airport could undermine outdoor recreation and aviation safety, per Comprehensive Plan policies T-P44 and RR-P2. The subarea plan should mandate critical areas reviews, mitigation sequencing (KCC 17A.01.100), and buffers (up to 200 feet from CARAs) for all proposals, while discouraging strip commercial developments. In conclusion, updating the Easton Subarea Plan provides an opportunity to align with the GMA by evaluating intense proposals such as Comprehensive Plan amendments or rezones, rather than variances. Prioritizing small-scale, site-specific developments will protect Eastern Washington's rural economies, water resources, and visual landscapes. We recommend incorporating these safeguards to prevent future inconsistencies and support job opportunities for rural residents without compromising environmental values. Thank you for considering this comment. Warm Regards, Friends of Easton, on behalf of its members: (including but not limited to) Gina Peckman, gina@peckmansearch.com Marge Brandsrud John Jensen Cc. Terry Danysh, PRK Livengood James Carmody, MFT Law