StffRrpt_Resolution_Exhibit A_Exhibit B_Exhibit C 07282026

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Department of Commerce: Submittal ID 2026-S-11466 We urge Kittitas County to revise the TDR program to ensure policies effectively concentrate growth where urban levels of development already exist and clarify implementation procedures to protect natural resource lands and rural character. To accomplish this, the County may proceed with options that include the following: • Consider taking legislative action to rescind and/or amend the existing TDR program. • Consider adopting a moratorium as allowed under RCW 36.70A.390 to provide interim zoning controls which will offer Kittitas County time to update TDR provisions. We also offer the following observations and recommendations based on our analysis of the current TDR program's approach to receiving sites, transfer procedures, and exchange rates: TDR Definitions We noted a need for clarification for TDR-related definitions within KCC 17.13.015. • We recommend revising regulations for receiving sites to distinguish between areas with capacity for growth. The current TDR program designates all rural lands without differentiating between areas where growth can be accommodated based on existing public infrastructure and services and presence of urban development (for example unincorporated UGAs). This is inconsistent with the GMA's UGA framework2 as well as the central purpose and intent of TDR programs to concentrate development in areas best suited for growth. TDR Receiving sites We noted concerns with eligible receiving sites identified by KCC 17.13.0303 (e), (f), and (g). We recommend clarifying conditions of receiving sites. • Without further distinction, including proximity to infrastructure and services as well as existing urban or planned urban development, conditions for receiving sites provide broad ability to transfer development rights from one rural area to another, but without meeting the purpose and intent of TDR and growth goals set out in the Kittitas County comprehensive plan. Receiving sites should be better suited for guiding growth by their location within existing urban areas and have the infrastructure capacity and services to meet the needs of increased growth. TDR Transfer process under and Exchange rate table The use table under 17.13.080, it is unclear how the exchange rate is applied. • We recommend providing further explanation on how the TDR credits are applied and how many additional units would be applied to the underlying zoning in each of the different receiving sites. • We also recommend revising this section to clarify whether the additional units allowed are on top of what is allowed in the underlying zoning designation or if these depict the total allowed density. Beyond clarification, provisions must prioritize rural densities which meet Kittitas County's statutory requirement to protect rural character, as defined by attributes under RCW 36.70A.030 38 .3 2 RCW 36.70A.110(1) 3 RCW 36.70A.070(5); RCW 36.70A.030(38)