Ryan Stewart - Spokane Regional Transportation Council (SRTC)
Feb 12, 2026
Government / Technical
[PDF page 1 of 4]
Hello,
Thank you for the opportunity to review the transportation-related elements of the City of Spokane's PlanSpokane 2046 DEIS. Below are just a few SRTC staff comments:
Overall SRTC Comment: The DEIS is very thorough and the analysis appears complete. SRTC staff finds no issues with the transportation-related items and only requires a little more clarification about some assumptions.
Land Use Growth Scenarios
Employment growth Alt 1 = SRTC regional projection adjusted to year 2046 (34,850) Alt 2 = WA ESD projection (24,939) Alt 3 = Unclear of source (38,848)
SRTC Comment: SRTC requires the source behind the Alternative 3 projection and the details about the assumptions used in order to understand the larger growth in jobs. For example, if housing units are held constant across the alternatives, where will the larger number of employees reside?
[PDF page 2 of 4]
Transportation DEIS states "No significant impacts to state facilities, the pedestrian network, the bike network, or mode share are expected with any of the alternatives."
SRTC Comment: This statement is somewhat confusing as significant impacts ("Thresholds of Significance") to Performance Metrics are described but will not inhibit the city's ability to implement mitigations and strategies. The LOS and Summary of Impacts sections reference significant impacts as well (Exhibits 1.4-4 and 1.4-5 and later in 3.7-25). Request clarification.
VMT (p.60, 1-34)
The DEIS states "The Action alternatives perform similarly across categories. Relative to No Action, VMT and VMT per capita decrease under both Action alternatives, so no significant impacts to VMT per capita or safety are identified for the Action Alternatives." The correlation between VMT and safety is explained in more detail beginning on page 1-36. The SRTC RSAP is referenced on p. 3-256.
SRTC Comment: Exhibit 1.4-6 shows the forecasted increase in per capita VMT. Alt 2 has the least growth but all three are very close. This is in line with what we saw in the VMT Reduction Framework in the City of Spokane with greater increases in outlying areas.
LOS (p.60, 1-34) The DEIS mentions the state facilities and other regionally significant facilities. Alts. 2 and 3 have slightly better LOS than the no action at the 22 city intersections studied, though 5 intersections have failing LOS in all alternatives. Solutions/mitigations include completion of the NSC, Division BRT and other STA HPT, pedestrian and bike improvements reflected in the master plans, ADA transition plan, TDM, TSMO, complete streets, and other safety improvements.
SRTC Comment: SRTC is supportive of the City of Spokane's solutions and mitigations for impacts to LOS as they are consistent with the Horizon 2050 Guiding Principles and Policies.
Intersection LOS (p.346, 3-233) "Intersection LOS is a qualitative measure used to evaluate traffic operations and delay at signalized and unsignalized intersections. It is defined in the Highway Capacity Manual (HCM) and widely used by transportation agencies across the U.S., including WSDOT and the Spokane Regional Transportation Council (SRTC). LOS is expressed as a letter grade from A to F, representing the average delay experienced by vehicles during peak conditions."
SRTC Comment: SRTC does not use intersection LOS as a measure for analysis. SRTC is a regional planning agency and uses Regional Mobility Corridor LOS as well as countywide metrics for level of service evaluation. Please see the SRTC Comprehensive Plan Certification Checklist (Attachment A, beginning on page 2) for a description of SRTC's multimodal level of service methodology.
[PDF page 3 of 4]
Volume-to-Capacity Ratio (v/c) Summary (p.347, 3-234) "Transportation agencies like WSDOT and SRTC use v/c ratios to evaluate system performance, identify deficiencies, and prioritize improvements in corridor planning and environmental review."
SRTC Comment: SRTC does not use V/C ratios as a performance metric unless it is part of a subarea or corridor-level study.
Regulatory Context (p.374, 3-261) References Horizon 2045 and RSAP.
SRTC Comment: Request updated reference to Horizon 2050.
SRTC Comment: The section about the City's ADA Transition Plan does not reference analysis of impacts to adjacent jurisdictions that is required in RCW 36.70A (6)(a)(G)(v). This could be included in the Transportation Chapter when it is released but will be an ongoing discussion with the City and other jurisdictions.
Summary of Impacts (p.396, 3-283) SRTC Comment: Exhibit 3.7-25 is confusing. For some of the "Impact Types" under Alts 2 and 3, it states "No additional impacts beyond No Action" but the Alt 1 has a "Significant Impact" - doesn't this mean they still have a significant impact? It is understood that the mitigation measures for Alts 2 and 3 lessen the impacts but the wording is still confusing. Request clarification.
SEPA exemption under RCW 43.21C.229 (p.398, 3-285) "The City of Spokane is evaluating adoption of SEPA categorical exemptions for infill housing under RCW 43.21C.229. The potential exemption area will be identified by walk access to major transit stops served by frequent and regular STA routes. Core locations where transit can support infill include Center City, the Division Street Corridor, and the core of Northwest and Northeast Spokane, which have a higher density of major stops and service frequency. Outside the core, neighborhoods that are generally farther from frequent and regular service and therefore not proposed for a potential infill exemption include Grandview/Thorpe, West Hills, Latah/Hangman, Five Mile Prairie, and North Indian Trail."
SRTC Comment: This appears to be a reasonable approach. Please include SRTC in the regional coordination of the transportation impact analysis.
Appendix C Transportation Project implementation Table (p.589, 5-11) SRTC Comment: All projects are consistent with Horizon 2050 and recent regional study efforts (e.g., US 195/I-90 Study, DivisionConnects, US 2 West Plains studies).
Please let me know if you have any questions or require additional information.
Ryan Stewart, AICP
Principal Transportation Planner
Spokane Regional Transportation Council
[Professional contact details and the standard public-records footer omitted from the reading text.]
[PDF page 4 of 4]
Please let me know if you have any questions or require additional information.
Ryan Stewart, AICP
Principal Transportation Planner
Spokane Regional Transportation Council
[Professional contact details and the standard public-records footer omitted from the reading text.]
Ryan Stewart - Spokane Regional Transportation Council (SRTC)
Feb 12, 2026
Government / Technical
[PDF page 1 of 4]
Hello,
Thank you for the opportunity to review the transportation-related elements of the City of Spokane's PlanSpokane 2046 DEIS. Below are just a few SRTC staff comments:
Overall SRTC Comment: The DEIS is very thorough and the analysis appears complete. SRTC staff finds no issues with the transportation-related items and only requires a little more clarification about some assumptions.
Land Use Growth Scenarios
Employment growth Alt 1 = SRTC regional projection adjusted to year 2046 (34,850) Alt 2 = WA ESD projection (24,939) Alt 3 = Unclear of source (38,848)
SRTC Comment: SRTC requires the source behind the Alternative 3 projection and the details about the assumptions used in order to understand the larger growth in jobs. For example, if housing units are held constant across the alternatives, where will the larger number of employees reside?
[PDF page 2 of 4]
Transportation DEIS states "No significant impacts to state facilities, the pedestrian network, the bike network, or mode share are expected with any of the alternatives."
SRTC Comment: This statement is somewhat confusing as significant impacts ("Thresholds of Significance") to Performance Metrics are described but will not inhibit the city's ability to implement mitigations and strategies. The LOS and Summary of Impacts sections reference significant impacts as well (Exhibits 1.4-4 and 1.4-5 and later in 3.7-25). Request clarification.
VMT (p.60, 1-34)
The DEIS states "The Action alternatives perform similarly across categories. Relative to No Action, VMT and VMT per capita decrease under both Action alternatives, so no significant impacts to VMT per capita or safety are identified for the Action Alternatives." The correlation between VMT and safety is explained in more detail beginning on page 1-36. The SRTC RSAP is referenced on p. 3-256.
SRTC Comment: Exhibit 1.4-6 shows the forecasted increase in per capita VMT. Alt 2 has the least growth but all three are very close. This is in line with what we saw in the VMT Reduction Framework in the City of Spokane with greater increases in outlying areas.
LOS (p.60, 1-34) The DEIS mentions the state facilities and other regionally significant facilities. Alts. 2 and 3 have slightly better LOS than the no action at the 22 city intersections studied, though 5 intersections have failing LOS in all alternatives. Solutions/mitigations include completion of the NSC, Division BRT and other STA HPT, pedestrian and bike improvements reflected in the master plans, ADA transition plan, TDM, TSMO, complete streets, and other safety improvements.
SRTC Comment: SRTC is supportive of the City of Spokane's solutions and mitigations for impacts to LOS as they are consistent with the Horizon 2050 Guiding Principles and Policies.
Intersection LOS (p.346, 3-233) "Intersection LOS is a qualitative measure used to evaluate traffic operations and delay at signalized and unsignalized intersections. It is defined in the Highway Capacity Manual (HCM) and widely used by transportation agencies across the U.S., including WSDOT and the Spokane Regional Transportation Council (SRTC). LOS is expressed as a letter grade from A to F, representing the average delay experienced by vehicles during peak conditions."
SRTC Comment: SRTC does not use intersection LOS as a measure for analysis. SRTC is a regional planning agency and uses Regional Mobility Corridor LOS as well as countywide metrics for level of service evaluation. Please see the SRTC Comprehensive Plan Certification Checklist (Attachment A, beginning on page 2) for a description of SRTC's multimodal level of service methodology.
[PDF page 3 of 4]
Volume-to-Capacity Ratio (v/c) Summary (p.347, 3-234) "Transportation agencies like WSDOT and SRTC use v/c ratios to evaluate system performance, identify deficiencies, and prioritize improvements in corridor planning and environmental review."
SRTC Comment: SRTC does not use V/C ratios as a performance metric unless it is part of a subarea or corridor-level study.
Regulatory Context (p.374, 3-261) References Horizon 2045 and RSAP.
SRTC Comment: Request updated reference to Horizon 2050.
SRTC Comment: The section about the City's ADA Transition Plan does not reference analysis of impacts to adjacent jurisdictions that is required in RCW 36.70A (6)(a)(G)(v). This could be included in the Transportation Chapter when it is released but will be an ongoing discussion with the City and other jurisdictions.
Summary of Impacts (p.396, 3-283) SRTC Comment: Exhibit 3.7-25 is confusing. For some of the "Impact Types" under Alts 2 and 3, it states "No additional impacts beyond No Action" but the Alt 1 has a "Significant Impact" - doesn't this mean they still have a significant impact? It is understood that the mitigation measures for Alts 2 and 3 lessen the impacts but the wording is still confusing. Request clarification.
SEPA exemption under RCW 43.21C.229 (p.398, 3-285) "The City of Spokane is evaluating adoption of SEPA categorical exemptions for infill housing under RCW 43.21C.229. The potential exemption area will be identified by walk access to major transit stops served by frequent and regular STA routes. Core locations where transit can support infill include Center City, the Division Street Corridor, and the core of Northwest and Northeast Spokane, which have a higher density of major stops and service frequency. Outside the core, neighborhoods that are generally farther from frequent and regular service and therefore not proposed for a potential infill exemption include Grandview/Thorpe, West Hills, Latah/Hangman, Five Mile Prairie, and North Indian Trail."
SRTC Comment: This appears to be a reasonable approach. Please include SRTC in the regional coordination of the transportation impact analysis.
Appendix C Transportation Project implementation Table (p.589, 5-11) SRTC Comment: All projects are consistent with Horizon 2050 and recent regional study efforts (e.g., US 195/I-90 Study, DivisionConnects, US 2 West Plains studies).
Please let me know if you have any questions or require additional information.
Ryan Stewart, AICP
Principal Transportation Planner
Spokane Regional Transportation Council
[Professional contact details and the standard public-records footer omitted from the reading text.]
[PDF page 4 of 4]
Please let me know if you have any questions or require additional information.
Ryan Stewart, AICP
Principal Transportation Planner
Spokane Regional Transportation Council
[Professional contact details and the standard public-records footer omitted from the reading text.]