2026-9-14 CDS_SS_BRIEFINGS - Laserfiche WebLink

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3. Key Findings A. Gap Analysis—Consistency with Commerce Comments and the GMA The gap analysis identified structural concerns focused primarily on the receiving-site component of the program: In particular: • KCC 17.13.015 and 17.13.030(1)(g) authorize all Rural Lands as receiving sites. • KCC 17.13.030(l)(e) and(f)permit certain unincorporated planned unit developments (PUDs) and long plats that increase density to serve as receiving sites. • KCC 17.13.080(5) establishes a 1:1 exchange rate for"Rural Development." • Collectively,these provisions create a pathway for rural-to-rural density transfers. The Department of Commerce stated that these program features may produce the opposite of a TDR program's intended outcome by encouraging additional growth in rural areas rather than directing it toward incorporated cities and urban growth areas (UGAs). Staff s analysis further indicates that the rural receiving-site framework raises consistency questions under GMA goals and requirements addressing: • Concentration of urban growth within UGAs; • Reduction of sprawl; • Protection of rural character; and • Preferential location of urban growth within UGAs where urban services are available or can be provided efficiently. The Sending-site provisions of KCC 17.13, including farm, forest, and critical-area criteria,were found to be generally consistent with conservation objectives and were not the primary focus of Commerce's comments. B.Inventory of Existing Activity Available records indicate that the TDR program has experienced limited utilization for most of its history. The program was adopted in 2009 and subsequently amended. Current records reflect approximately 322 certificates. A substantial portion of those certificates were issued between 2024 and 2026. Several recent applications relied on provisions later identified by the Department of Commerce as problematic. C. Comparative Analysis of Other Washington Counties Review of peer programs indicates that sustained private-market TDR activity has occurred primarily in high-growth Puget Sound markets, most notably King County. Counties with more rural development patterns, limited receiving-area demand, or fewer municipal partners have generally experienced modest transaction volumes.