I am writing as a resident of the Grandview/Thorpe Neighborhood to express serious concerns regarding the Draft Environmental Impact Statement (EIS), the proposed land use Alternatives 2 and 3, and the associated environmental review exemptions.
Housing Need Must Drive Policy
Recent 2025 housing studies clearly demonstrate that Spokane's housing shortage is concentrated in the 0-80% AMI category, with a deficit of approximately 4,400 units. At the same time, the City shows a surplus in the 80-120% and 120%+ AMI categories.
Yet the Draft EIS appears to assume that increased private development across all income levels will resolve affordability challenges. There are no enforceable mechanisms identified to ensure that new development will meaningfully address the documented shortage in lower-income housing.
If affordability is the goal, land use decisions, permitting practices, demolition approvals, and incentives must be aligned with demonstrated need - not with generalized growth assumptions.
Demolition and Displacement Concerns
Both Alternatives 2 and 3 rely heavily on redevelopment and infill, but the Draft EIS does not adequately analyze the impact of demolition. Demolition can lead to:
Displacement of lower-income residents
Reduction in homeownership
Increased rental concentration
Loss of neighborhood stability
There is an assumption that future anti-displacement policies will mitigate harm, yet no evidence is provided that such protections are enforceable or sufficient. Spokane should not move forward with sweeping zoning changes without first strengthening displacement safeguards.
Neighborhood-Scale Environmental Protection
Spokane has a stated tree canopy goal of 30%, yet we do not currently have adequate codes to ensure its achievement.
I strongly support the development of a comprehensive Tree and Natural Land Inventory.
[PDF page 2 of 4]
Spokane must inventory trees, natural areas, wildlife habitat, riparian corridors, and remaining undeveloped lands to properly inform the Critical Areas Code. The Growth Management Act requires protection of critical areas, forests, habitat, and natural lands. Without a current inventory, we cannot meaningfully comply.
Enforceable Critical Areas Ordinance
An enforceable Critical Areas Ordinance is required to protect:
Wetlands
Forests and mature tree stands
Wildlife habitat
Riparian areas
Water quality
The Draft EIS itself (Exhibit 3.3-3) shows unprotected natural lands throughout the City. We cannot responsibly expand development capacity while leaving critical natural systems inadequately protected.
Environmental Review Exemptions
I oppose the blanket environmental review exemption proposed in the Draft EIS. Exhibit 7 demonstrates that, in two phases, all neighborhoods would become exempt from environmental review.
This would remove essential safeguards for wetlands, forests, habitat, and riparian areas embedded within residential neighborhoods.
Environmental review exemptions should apply only to properties that are 100% disturbed and impervious, as identified in Draft EIS Exhibit 3.1-3. If a site is fully hardened and contains no ecological value, exemption may be appropriate. Otherwise, environmental review remains a critical tool for protecting public health and environmental integrity.
Aquifer Protection and Water Resources
It is deeply concerning that the "Earth, Water Quality, and Water Resources" section does not reference the Spokane Valley-Rathdrum Prairie Aquifer, which is essential to our regional drinking water supply.
Growth policy must explicitly address aquifer protection, stormwater management, and riparian health - especially given ongoing reductions in federal environmental oversight.
Transportation and Vehicle Impacts
[PDF page 3 of 4 begins within the following paragraph.]
The Draft EIS acknowledges that neither alternative will meaningfully increase transit usage. If population grows without a corresponding shift to transit or active transportation, personal vehicle use will increase.
Where will additional vehicles be parked? How will emissions be reduced? How will heat island effects be mitigated if tree canopy declines?
These questions remain insufficiently addressed.
Support for Climate Resilience and Sustainability Board Policy
I strongly support the Climate Resilience and Sustainability Board's recommended Policy Land Use & Zoning 2-4:
"Protect, restore, acquire, and maintain urban agricultural lands, urban forests, critical areas, shorelines, habitats, and open spaces as interconnected natural systems that provide flood protection, heat reduction, and carbon sequestration benefits, including through codes, capital investments, and regional partnerships."
This policy recognizes that natural systems are not obstacles to growth - they are infrastructure. Trees reduce heat, wetlands manage floods, and open space improves air quality and public health.
Land use planning must integrate climate resilience as a foundational principle, not an afterthought.
Conclusion
As currently written, Alternatives 2 and 3 - combined with sweeping environmental exemptions - risk opening established neighborhoods to redevelopment without sufficient safeguards for affordability, displacement prevention, environmental protection, or infrastructure capacity.
Spokane does not need an either/or approach. The City can adopt the strongest elements of each alternative while:
Targeting housing production where it is actually needed
Protecting critical areas and natural lands
Preserving tree canopy
Strengthening homeownership
Preventing displacement
Aligning growth with climate resilience goals
I urge you to revise the Draft EIS to incorporate enforceable protections and meaningful environmental review before adopting long-term zoning changes that will shape our city for decades.
Molly Marshall
Feb 16, 2026
Local Resident
[PDF page 1 of 4]
I am writing as a resident of the Grandview/Thorpe Neighborhood to express serious concerns regarding the Draft Environmental Impact Statement (EIS), the proposed land use Alternatives 2 and 3, and the associated environmental review exemptions.
Housing Need Must Drive Policy
Recent 2025 housing studies clearly demonstrate that Spokane's housing shortage is concentrated in the 0-80% AMI category, with a deficit of approximately 4,400 units. At the same time, the City shows a surplus in the 80-120% and 120%+ AMI categories.
Yet the Draft EIS appears to assume that increased private development across all income levels will resolve affordability challenges. There are no enforceable mechanisms identified to ensure that new development will meaningfully address the documented shortage in lower-income housing.
If affordability is the goal, land use decisions, permitting practices, demolition approvals, and incentives must be aligned with demonstrated need - not with generalized growth assumptions.
Demolition and Displacement Concerns
Both Alternatives 2 and 3 rely heavily on redevelopment and infill, but the Draft EIS does not adequately analyze the impact of demolition. Demolition can lead to:
Displacement of lower-income residents
Reduction in homeownership
Increased rental concentration
Loss of neighborhood stability
There is an assumption that future anti-displacement policies will mitigate harm, yet no evidence is provided that such protections are enforceable or sufficient. Spokane should not move forward with sweeping zoning changes without first strengthening displacement safeguards.
Neighborhood-Scale Environmental Protection
Spokane has a stated tree canopy goal of 30%, yet we do not currently have adequate codes to ensure its achievement.
I strongly support the development of a comprehensive Tree and Natural Land Inventory.
[PDF page 2 of 4]
Spokane must inventory trees, natural areas, wildlife habitat, riparian corridors, and remaining undeveloped lands to properly inform the Critical Areas Code. The Growth Management Act requires protection of critical areas, forests, habitat, and natural lands. Without a current inventory, we cannot meaningfully comply.
Enforceable Critical Areas Ordinance
An enforceable Critical Areas Ordinance is required to protect:
Wetlands
Forests and mature tree stands
Wildlife habitat
Riparian areas
Water quality
The Draft EIS itself (Exhibit 3.3-3) shows unprotected natural lands throughout the City. We cannot responsibly expand development capacity while leaving critical natural systems inadequately protected.
Environmental Review Exemptions
I oppose the blanket environmental review exemption proposed in the Draft EIS. Exhibit 7 demonstrates that, in two phases, all neighborhoods would become exempt from environmental review.
This would remove essential safeguards for wetlands, forests, habitat, and riparian areas embedded within residential neighborhoods.
Environmental review exemptions should apply only to properties that are 100% disturbed and impervious, as identified in Draft EIS Exhibit 3.1-3. If a site is fully hardened and contains no ecological value, exemption may be appropriate. Otherwise, environmental review remains a critical tool for protecting public health and environmental integrity.
Aquifer Protection and Water Resources
It is deeply concerning that the "Earth, Water Quality, and Water Resources" section does not reference the Spokane Valley-Rathdrum Prairie Aquifer, which is essential to our regional drinking water supply.
Growth policy must explicitly address aquifer protection, stormwater management, and riparian health - especially given ongoing reductions in federal environmental oversight.
Transportation and Vehicle Impacts
[PDF page 3 of 4 begins within the following paragraph.]
The Draft EIS acknowledges that neither alternative will meaningfully increase transit usage. If population grows without a corresponding shift to transit or active transportation, personal vehicle use will increase.
Where will additional vehicles be parked? How will emissions be reduced? How will heat island effects be mitigated if tree canopy declines?
These questions remain insufficiently addressed.
Support for Climate Resilience and Sustainability Board Policy
I strongly support the Climate Resilience and Sustainability Board's recommended Policy Land Use & Zoning 2-4:
"Protect, restore, acquire, and maintain urban agricultural lands, urban forests, critical areas, shorelines, habitats, and open spaces as interconnected natural systems that provide flood protection, heat reduction, and carbon sequestration benefits, including through codes, capital investments, and regional partnerships."
This policy recognizes that natural systems are not obstacles to growth - they are infrastructure. Trees reduce heat, wetlands manage floods, and open space improves air quality and public health.
Land use planning must integrate climate resilience as a foundational principle, not an afterthought.
Conclusion
As currently written, Alternatives 2 and 3 - combined with sweeping environmental exemptions - risk opening established neighborhoods to redevelopment without sufficient safeguards for affordability, displacement prevention, environmental protection, or infrastructure capacity.
Spokane does not need an either/or approach. The City can adopt the strongest elements of each alternative while:
Targeting housing production where it is actually needed
Protecting critical areas and natural lands
Preserving tree canopy
Strengthening homeownership
Preventing displacement
Aligning growth with climate resilience goals
I urge you to revise the Draft EIS to incorporate enforceable protections and meaningful environmental review before adopting long-term zoning changes that will shape our city for decades.
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ATTACHMENT / ADDITIONAL PAGES
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[PDF page 4 of 4]
Thank you,
Molly Marshall
Grandview/Thorpe Neighborhood