StffRrpt_Resolution_Exhibit A_Exhibit B_Exhibit C 07282026

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Department of Commerce: Submittal ID 2026-5-11466 Rural Recreation includes Master Planned Resort (MPR) as a zoning type. MPRs are defined as urban in statute and should be a land use designation under the urban type. We recommend that the County consider adopting a mineral resources overlay. This will reduce room for potential error when implementing development regulations where mineral resources overlap multiple zones. An overlay would enable the County to more readily identify and apply the additional protections required for designated natural resource lands. Specifying Limited Areas of More Intensive Rural Development (LAMIRD) by type: Statute defines separate requirements for three types of LAMIRDs. The plan mentions all three types, but without consistent clarification to convey their fundamental differences: (1) Type -I LAMIRDs were established only once in the 1990s to recognize existing rural communities and allow limited infill but not expansion. (2) Type -II LAMIRDs may be newly created for small-scale recreational uses not intended to serve rural populations. (3) Type -III LAMIRDs may be newly created for small-scale businesses and cottage industries and are similarly not intended to serve rural populations. We recommend reviewing RCW 36.70A.070(5)(d) and WAC 365-196-425(6) and revising the plan's references to LAMIRDs. Specifically, provide glossary definitions based on statute and codified guidelines then revise land use maps, zoning maps and written sections accordingly. Include tables within these revisions, such as Table 2-1 (Land Use Element) and Table 3-1 (Rural and Resource Lands Element) where one generic label for LAMIRDs incorrectly implies that all zoning classifications listed in the adjacent columns would be permissible in any type of LAMIRD. There should be separate land use categories for the three types of LAMIRDs. This can be misleading to readers and, if not revised, may lead to statutory violations if inappropriately carried into implementing regulations and project permitting. Further, we recommend having distinct zoning types that are not shared with other LAMIRDs or land use categories. Planned Unit Development (PUD) Zones: Kittitas County provides one PUD zoning classification for development across multiple land use designations which span urban and rural lands. Allowing the same zone across clearly different land uses is problematic. Projects permitted within PUDs will encounter different standards depending on the area's underlying land use. We recommend a more predictable development framework by adopting distinct PUD zoning classifications that differ based on the land use designations. If the County intends to maintain the PUD zoning, we recommend prioritizing amendments to the PUD zoning classification within both the comprehensive plan and development regulations during this periodic update. One approach may be to adopt an Urban-PUD zoning classification which applies to unincorporated UGAs with the purpose of accommodating growth at increased densities and a separate Rural-PUD zoning classification with the express purpose of limiting rural densities to help the County protect rural character, per RCW 36.70A.070(5). Consider this or other alternative strategies that similarly reinforce the policy -setting role of land uses which guide and must be implemented by zoning and other development regulations. This will offer project applicants a more immediate understanding of what zoning will allow for their project site rather than requiring applicants or permit reviewers to interpret how underlying land use designations alter how zoning code behaves. Specify a Transfer of Development Rights (TDR) section to guide effective implementation. Kittitas County has adopted a TDR program, which various sections within the comprehensive plan describe. However, we recommend consolidating TDR-specific goals and policies under a TDR section within the Rural Element. TDR programs are an important tool for protecting rural character and natural resource lands by ensuring rural areas develop at rural densities while directing growth toward urban 9 RCW 36.70A.360(1) Page: 4 of 6