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• (g) `All parcels designated as Rural Land shall be eligible to be a receiving site." <br /> Commerce specifically flags subsections (e), (f), and (g) in the May 22, 2026 letter as creating "broad <br /> ability to transfer development rights from one rural area to another." <br /> Receiving Site Development Limitations—KCC 17.13.055 <br /> KCC 17.13.055(2)—(4): <br /> "(2) The density within the established boundary may be increased over the underlying zone by the <br /> number of TDR Density Credits. This means that the parcel sizes within the boundary may be <br /> decreased. <br /> "(3)No parcel with the project boundary shall be reduced in size below one-half acre except in a <br /> Planned Unit Development as provided for in KCC Chapter 17.36 or within a City, UGA or LAMIRD. <br /> "(4) TDR Density Credits may be used to increase density in the following county actions;Boundary <br /> Line Adjustments, Long Plats, Planned Unit Developments, Short Plats and Cluster Plats." <br /> Exchange Rates—KCC 17.13.080(5) <br /> Receiving Sites Exchange Rate <br /> Urban Growth Areas 1 TDR Credit=3 Additional Units <br /> Planned Unit Developments 1 TDR Credit=2 Additional Units <br /> Rural Development 1 TDR Credit= 1 Additional Unit <br /> In their May 22, 2026, letter the Department of Commerce described ambiguity associated with how the <br /> table is applied. The concern centered on a lack of transparency regarding the application of additional <br /> density credits, specifically whether the additional units described in the table are in addition to or <br /> including the underlying density allowance. The intention of the table is to reflect the additional credits <br /> allowed beyond the base density. The table will need to be amended to clarify this intention. <br /> GMA Consistency Analysis <br /> TDR's are authorized as an innovative technique under RCW 36.70A.090. The rural element(RCW <br /> 36.70A.070(5)(b))permits density transfer only to the extent resulting densities and uses"are not <br /> characterized by urban growth and that are consistent with rural character."This section examines the <br /> Kittitas County TDR program in relationship to general GMA standards and guidance. <br /> Conflict with Urban Growth and Sprawl Goals—RCW 36.70A.020(1)—(2) <br /> Goal 1 requires encouragement of development in urban areas where adequate public facilities exist or <br /> can be efficiently provided. Goal 2 requires reduction of the inappropriate conversion of undeveloped land <br /> into sprawling, low-density development. KCC 17.13.030(1)(g) and the rural development exchange rate <br /> in KCC 17.13.080(5) allow additional residential units on rural lands, working against both goals. <br /> Conflict with Rural Character—RCW 36.70A.030(38) and .070(5)(c) <br /> Rural character requires that open space and natural landscape predominate,that urban governmental <br /> services generally not be required, and that inappropriate conversion to sprawling low-density <br />