Tirrell Black Assistant Planning Director, City of Spokane
Re: PlanSpokane 2046 Draft EIS Comments.
Mr Black, The draft EIS is focused on housing and jobs. Consideration is given to how the three alternatives impact, and what mitigations are possible regarding those impacts, on Earth, Water Quality, and Water Resources; Air Quality/Greenhouse Gases; Plants and Animals; Land Use Patterns and Urban Form; Relationship to Plans, Policies, and Regulations; Population, Employment, and Housing; Transportation; Public Services, and Utilities. Section 1.3 defines key issues and options.
My comment is limited to impact and mitigations of impacts on Air Quality/Greenhouse Gases; Plants and Animals; Land Use Patterns and Urban Form. In particular, I write to emphasize protection of the tree canopy in Spokane because it is implicated in the named key issues.
The vision statement names environmental stewardship. Among many other things, Environmental stewardship includes protection of the tree canopy, recognized in the city commitment to SpoCanopy goals.
Each of the other key issues named directly or indirectly affects the canopy.
- Approval of a comprehensive plan that meets state and county requirements to accommodate housing needs at all income bands including best location for units at 0- 80% AMI affordability and addressing racially disparate impacts in access to housing.
There are examples throughout the city where new housing is constructed on land
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cleared of trees. This need not be accepted. Inexpensive housing in an environmentally compromised area serves to institutionalize economic disparity.
- Approval of a comprehensive plan that provides land use and transportation strategies to reduce greenhouse gas emissions.
One of the key mitigation tactics to reduce GHG is planting of trees. Mature trees capture greatly more CO2 than young trees. Yes, after decades young trees will mature and capture more CO2, but we can ill afford to wait for decades. Mature trees must be retained during development.
- Approval of a comprehensive plan that increases resilience to climate-related hazards, reduces exposure to pollution, and addresses environmental impacts.
A tree canopy is high on the list of variables that provide resilience to climate-related hazards, most particularly high heat index in lower income neighborhoods as previously documented by Gonzaga. Consideration must be given to fire risk and damage from insects and storms; but those factors can be included in the review of housing development plans.
- Approval of development regulations that implement the Comprehensive Plan goals, policies, and land use plan.
Goal ECOS 1 of the Climate resiliency and sustainability plan, specifically policy ECOS 1-1, calls to “Establish and support programs, codes, and standards that support the long-term health and maintenance of the urban canopy on public and private lands…” The mechanism to protect mature trees is proper permitting, wherein professional arborists can contribute to proposed development by designating the maximum, reasonable retention of mature trees.
I encourage you to elevate those mitigations that protect and improve the tree canopy in Spokane from just among the possible mitigations to recommended mitigations. For example “Tree canopy loss in areas with overburdened populations could have an elevated risk of adverse impacts, however, creating additional low-cost housing options in areas with more tree canopy could be beneficial: and “The City could consider increased program resources for the SpoCanopy tree canopy cover program, incentive programs for habitat conservation and restoration, land acquisition opportunities in key areas…: p I-21-22. (italics added)
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And on p I-24, “Land use or urban form changes that disproportionately impact historically marginalized or underserved communities with environmental, health, or socioeconomic burdens. This includes increased exposure to noise and light pollution, as well as urban heat island effects, especially in areas with high environmental health disparities, sensitive populations, and limited tree canopy…”
While it may be true that “There are no significant, unavoidable adverse impacts expected for land use, urban form, and environmental justice” in the alternatives, there are significant avoidable adverse impacts. Attention to tree canopy is a readily available metric to minimize adverse impacts, avoidable and unavoidable.
John Wallingford
[Personal contact details omitted from the reading text.]
John Wallingford
Feb 18, 2026
Local Resident
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Tirrell Black Assistant Planning Director, City of Spokane
Re: PlanSpokane 2046 Draft EIS Comments.
Mr Black, The draft EIS is focused on housing and jobs. Consideration is given to how the three alternatives impact, and what mitigations are possible regarding those impacts, on Earth, Water Quality, and Water Resources; Air Quality/Greenhouse Gases; Plants and Animals; Land Use Patterns and Urban Form; Relationship to Plans, Policies, and Regulations; Population, Employment, and Housing; Transportation; Public Services, and Utilities. Section 1.3 defines key issues and options.
My comment is limited to impact and mitigations of impacts on Air Quality/Greenhouse Gases; Plants and Animals; Land Use Patterns and Urban Form. In particular, I write to emphasize protection of the tree canopy in Spokane because it is implicated in the named key issues.
The vision statement names environmental stewardship. Among many other things, Environmental stewardship includes protection of the tree canopy, recognized in the city commitment to SpoCanopy goals.
Each of the other key issues named directly or indirectly affects the canopy.
- Approval of a comprehensive plan that meets state and county requirements to accommodate housing needs at all income bands including best location for units at 0- 80% AMI affordability and addressing racially disparate impacts in access to housing.
There are examples throughout the city where new housing is constructed on land
[PDF page 2 of 3]
cleared of trees. This need not be accepted. Inexpensive housing in an environmentally compromised area serves to institutionalize economic disparity.
- Approval of a comprehensive plan that provides land use and transportation strategies to reduce greenhouse gas emissions.
One of the key mitigation tactics to reduce GHG is planting of trees. Mature trees capture greatly more CO2 than young trees. Yes, after decades young trees will mature and capture more CO2, but we can ill afford to wait for decades. Mature trees must be retained during development.
- Approval of a comprehensive plan that increases resilience to climate-related hazards, reduces exposure to pollution, and addresses environmental impacts.
A tree canopy is high on the list of variables that provide resilience to climate-related hazards, most particularly high heat index in lower income neighborhoods as previously documented by Gonzaga. Consideration must be given to fire risk and damage from insects and storms; but those factors can be included in the review of housing development plans.
- Approval of development regulations that implement the Comprehensive Plan goals, policies, and land use plan.
Goal ECOS 1 of the Climate resiliency and sustainability plan, specifically policy ECOS 1-1, calls to “Establish and support programs, codes, and standards that support the long-term health and maintenance of the urban canopy on public and private lands…” The mechanism to protect mature trees is proper permitting, wherein professional arborists can contribute to proposed development by designating the maximum, reasonable retention of mature trees.
I encourage you to elevate those mitigations that protect and improve the tree canopy in Spokane from just among the possible mitigations to recommended mitigations. For example “Tree canopy loss in areas with overburdened populations could have an elevated risk of adverse impacts, however, creating additional low-cost housing options in areas with more tree canopy could be beneficial: and “The City could consider increased program resources for the SpoCanopy tree canopy cover program, incentive programs for habitat conservation and restoration, land acquisition opportunities in key areas…: p I-21-22. (italics added)
[PDF page 3 of 3]
And on p I-24, “Land use or urban form changes that disproportionately impact historically marginalized or underserved communities with environmental, health, or socioeconomic burdens. This includes increased exposure to noise and light pollution, as well as urban heat island effects, especially in areas with high environmental health disparities, sensitive populations, and limited tree canopy…”
While it may be true that “There are no significant, unavoidable adverse impacts expected for land use, urban form, and environmental justice” in the alternatives, there are significant avoidable adverse impacts. Attention to tree canopy is a readily available metric to minimize adverse impacts, avoidable and unavoidable.
John Wallingford
[Personal contact details omitted from the reading text.]