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Both options remain available to the Board. The analysis indicates that Option B, implemented with <br /> appropriate transition and legacy provisions,would more directly resolve the specific deficiencies <br /> identified by Commerce, reduce future administrative complexity, ensure GMA compliance, and reduce <br /> staff resources toward a consistently underutilized program,while still safeguarding the rights of <br /> existing certificate holders. <br /> 6. Recommended Next Steps <br /> Staff recommends that the Board provide direction on the preferred path: <br /> 1. Option A: Comprehensive revision of KCC Chapter 17.13; or <br /> 2. Option B: Prospective repeal of KCC Chapter 17.13 with transition and legacy certificate <br /> provisions. <br /> Upon Board direction, staff will proceed with Task 2 work, including detailed option development, <br /> drafting of necessary code and Comprehensive Plan amendments, stakeholder engagement, and <br /> coordination with the Planning Commission. <br /> Attachments: <br /> 1. Gap Analysis of KCC Chapter 17.13 <br /> 2. TDR Application/Certificate Inventory Summary <br /> 3. Comparative Analysis of Washington County TDR Programs <br /> 4_ Legal Review Memorandum(Vested Rights, Takings Exposure, and Transition Issues) <br />