StffRrpt_Resolution_Exhibit A_Exhibit B_Exhibit C 07282026

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Department of Commerce: Submittal ID 2026-S-11466 We recognize that Kittitas County is not currently proposing amendments to designated resource lands or Urban Growth Area (UGA) boundaries. We encourage the County to note this in any ordinances or resolutions documenting the steps taken to complete this update. We offer the following recommendations to help strengthen the comprehensive plan's clarity, consistency and effective implementation. Please share these comments with appointed and elected officials before adopting final amendments: Population and Housing Growth Allocations: Improve transparency by providing separate figures for incorporated areas, unincorporated UGAs, and unincorporated rural lands outside UGAs in tables and sections addressing densities, growth, and population allocations. For example, Table 2-4 displays housing unit allocations for each city and the unincorporated rural area, but it is not immediately clear whether UGAs are reflected in figures associated with cities or within the total allocation for unincorporated rural areas. We recommend providing this distinction within the table and explanatory captions or text immediately before or after the table. We recommend revising the comprehensive plan and subarea plans to clearly indicate what values or figures are for the full county, including cities, and what values are for the unincorporated county. Integrating the Housing Needs Analysis (HNA) and additional housing policies: Kittitas County has most likely completed a racially disparate impact (RDI) analysis as part of the Housing Needs Analysis (HNA) and identified gaps that amendments to affordable housing policies should address. If the County has completed this work, please adopt policies to address community needs and include the analysis or a summary of the revisions in the Housing Element (or an appendix). To meet requirements under RCW 36.70A.070 2 e and , we recommend including policies or actions that address and begin to undo racially disparate impacts (RDI), displacement, and exclusion in housing caused by local policies, plans, and actions. In our review, we did not find policies and regulations explicitly addressing this, nor did we find specific policies and regulations which the County has identified as resulting in or contributing toward these issues.' Ideally, these will be clearly informed by findings revealed by the County's policy evaluation.' We did not find where the Housing Element identifies areas at risk of residential displacement, as required by RCW 36.70A.07OL2X91. Kittitas County can meet this requirement by including a displacement risk map, such as Commerce Draft Displacement Risk Mg , or a discussion of areas that may be at risk of displacement. General policies on housing affordability have strengths and are close to meeting some of these requirements, but the plan does not provide policies addressing displacement. The policy section on housing equity addresses special -needs housing, but we recommend ensuring this appears alongside additional policies that explicitly address Racially Disparate Impacts (RDI). 3 Guidance to Address Racially Disparate Impacts (Step 3; pages 33-36) ' Guidance to Address Raciall Dis crate Im acts (Steps 4 and 5; pages 36-48). Page: 2 of 6