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Exhibit B <br />a <br />STATE OF WASHINGTON <br />DEPARTMENT OF COMMERCE <br />1500 Jefferson Street SE I PO Box 42525 1 Olympia, Washington 98501 1 360-725-4000 <br />www.commerce.wa.gov <br />May 22, 2026 <br />Mr. Chad Bala <br />Director of Community Development <br />Kittitas County <br />411 N Ruby Street Suite 2 <br />Ellensburg, WA 98926 <br />Sent Via Electronic Mail <br />Re: 60-day Notice of Intent to Amend Kittitas County Development Regulations (2026-S-11651) <br />Dear Mr. Bala: <br />Thank you for sending Growth Management Services 60-Day Notice of Kittitas County's intent to <br />amend development regulations. We received your amendment proposal and supporting <br />documents as PlanView submittal number 2026-S-11466 on March 26, 2026. <br />We appreciate your coordination as you make this significant step toward completing the 2026 <br />Periodic Update and work to fulfill the community's vision consistent with GMA goals and <br />requirements.' In support of your efforts, please share our comments with your community, elected <br />officials and their representatives for consideration. <br />Based on reviewing current development regulations and proposed amendments, we identify the <br />following to improve alignment with statutory requirements: <br />Transfer of Development Rights (TDR) <br />We recommend amending or rescinding the current TDR program to better protect rural character <br />by directing growth toward cities and urban growth areas (UGAs). <br />TDR programs direct growth toward urban areas while limiting rural development densities, <br />serving to protect natural resource lands under RCW 36.70A.070[5) and rural character as defined <br />by RCW 36.70A.030 38 . Although Kittitas County Code (KCC) includes a TDR program, <br />implementation guidelines are ambiguous and misapplication may have the opposite effect by <br />encouraging growth in rural areas. <br />' RCW 36.70A.106; RCW 36.70A.130 <br />