StffRrpt_Resolution_Exhibit A_Exhibit B_Exhibit C 07282026

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Department of Commerce: Submittal ID 2026-S-11466 Barriers and solutions to provide adequate housing for all residents: The housing element does not include documentation of programs and actions needed to achieve housing availability, as required by RCW 36.70A.070 2 d ii . We recommend amending the Housing Element to include a list of barriers to affordable housing needs and actions needed to remove those barriers to align with statute.5 Based on recent GMHB cases, we also recommend identifying the number of units that require additional funding to be developed and gaps in local funding needed to achieve these affordable housing needs, documenting which available local funding tools or incentives are already being used, and which tools can be implemented to help close the funding gap.6 Land capacity for housing needs of all economic segments: Additionally, we recommend that Kittitas County review land capacity for extremely low-income housing to ensure sufficient capacity for all housing needs as required by RCW 36.70A.070(2)(c). The County's Land Capacity Analysis (LCA) indicates sufficient capacity of housing for all income levels; however, the analysis is unclear whether it includes housing typologies likely to serve the community's extremely low-income households between 0-30% Area Median Income (AMI). Please review and integrate recommendations from our housing element guidance 7 The County must also allow permanent supportive housing (PSH) in enough places to accommodate their share of permanent supportive housing needs (0-30% PSH) for consistency with RCW 36.70A.070(2)(c). Within our review, we were unable to identify where zones will allow PSH. To be consistent with this requirement, the County will need to allow permanent supportive housing with its development regulations update to ensure there is capacity for the 0-30% PSH needs. Future land use map within the main body of the comprehensive plan: We recommend adding the future land use map to the main body of the Land Use Element instead of separately providing these as appendices. Please consider these changes to the Land Use Element and subarea plans prior to adopting the final updated comprehensive plan. RCW 36.70A.070 outlines central features of land use elements, including maps upon which other elements of the comprehensive plan rest. To ensure consistency across the adopted plan, also consider adding clearly labeled future land use maps within each subarea plan. Land Use Maps should show land use designations, city limits, and UGA boundaries. Land Use Designations and Zoning Classifications: Commerce has significant concerns with the land use and zoning table in the Land Use Element, Table 2- 1. LAMIRDs and the Planned Unit Development (PUD) are covered separately below. We like that the County identifies the three general land use types of Resource Lands, Rural, and Urban and this framework should be retained. The remaining concerns with Table 2-1 are as follows: • We recommend providing more distinction in the Urban land use category. Typical minimum urban distinctions are residential, commercial, industrial, institutional/governmental, open space, and MPR. Simply identifying it as Urban is far too broad and does not make it clear to the public how the urban land is going to be treated. • Urban land use designations are required to allow urban densities.' The zoning associated with the urban land use designation includes the following rural zoning classifications: Agriculture 3, Rural 3, Rural 5, and Forest and Range. These zones combined account for approximately 640 acres, which is more than 11% of the unincorporated UGA within the county. Commerce recommends the county only apply urban zones to the urban land use designation. If the county wishes to maintain rural zoning in these areas, the county could consider removing the areas from the UGA if the areas removed from the urban growth area are not characterized by urban growth or urban densities, and revised urban growth area is contiguous, does not include holes or gaps, and will not increase pressures to urbanize rural or natural resource lands. 5 Guidance for Updating Your HousingElern (Chapter 4; pages 54-76). 6 Guidance for Updating Your Housing Element (Chapter 4; pages 63-65 and Appendix B: Adequate Provisions Checklist) 7 Guidance for Updating Your Housing Eleme, (Book 2; pages 33-39) 8 RCW 36.70A.110(2) Page: 3 of 6