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

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Appendix B Additional Public Comments Submitted in Writing Public Comment—Kittitas County Comprehensive Plan Update March 2026 LU-P39: Rural Mixed-Use Without Standards LU-P39, as currently drafted, opens rural commercial zones to residential and tourism uses without defined size limits, density caps, or infrastructure requirements. We believe this policy, while perhaps well-intentioned, lacks the guardrails necessary to prevent outcomes the GMA was specifically designed to avoid. The core problem is the absence of standards. The Type 1 LAMIRD statute (RCW 36.70A.070(5)(d)(i)) caps retail and food service space at 5,000 square feet or the footprint of previously occupied space, whichever is greater. LU-P39 appears to contain no equivalent limitation. Without size limits, there is nothing preventing a large-scale tourism or residential development from establishing in a rural commercial zone and fundamentally changing the character of the surrounding community. At that point, the rural commercial zone is no longer rural— it is a de facto urban center without any of the services, infrastructure, or oversight that Urban Growth Areas provide. We ask the Commission to consider adding the following standards before adopting LU-1339: specific square footage or density caps on mixed-use development in rural commercial zones; infrastructure triggers requiring confirmation of water, sewer, road, and emergency services capacity before approval; a conditional use permit requirement with public notice so that adjacent property owners and the community have a meaningful opportunity to weigh in; and design guidelines or performance standards that ensure new development is consistent with rural character. We also ask the Commission to consider the compounding effect of LU-P39 and RR-P73 together. Individually, each policy may appear modest. Combined, they create a scenario where LAMIRD boundaries are expanded AND the uses within those boundaries are broadened —a multiplicative effect that could authorize urban-scale development throughout rural Kittitas County. The Commission should analyze these policies as a package, not in isolation. Has the County Attorney reviewed LU-P39 for GMA compliance? If so, we request that analysis be made part of the public record. If not, we ask that a compliance review be completed before the policy is adopted. Our Requests We are not asking the Commission to reject the comprehensive plan update. We support many of its provisions and recognize the work that has gone into it. We are asking for six specific actions on RR-P73 and LU-P39: First, delay action on RR-P73 until the County provides a written legal opinion from the Prosecuting Attorney's Office confirming the expansion is defensible under GMA and GMHB precedent. The legal risk is too high to proceed without this. Second, disclose all parcels and ownership affected by the proposed Ronald LAMIRD expansion, and make all related correspondence part of the public record. Transparency is essential. Third, conduct community outreach with Ronald and Easton area residents before finalizing any LAMIRD boundary changes. The communities most directly affected have not been adequately consulted. Fourth, add development standards to LU-1339 before adoption —including size limits, infrastructure triggers, and a conditional use permit requirement with public notice. Submitted fnr ti7c Put;:ic Rocord Page 4