Tirrell Black, Assistant Planning Director City of Spokane 808 W Spokane Falls Blvd. Spokane, WA 99201
Re: Draft Environmental Impact Statement – 2024 Comprehensive Plan Update
Dear City of Spokane Planning Team,
Spokane Riverkeeper appreciates the opportunity to provide comments on the Draft Environmental Impact Statement (DEIS) for the City of Spokane’s 2024 Comprehensive Plan Update. Our organization works to protect and restore the Spokane River and its watershed, including its fish, wildlife, and groundwater resources. We offer the following observations and recommendations regarding water resources, river and aquifer protection, and the iconic native Redband trout.
Spokane Riverkeeper is a non-profit, advocacy organization that works to protect the Spokane River Watershed. The mission of the organization is to protect and restore the health of the Spokane River watershed, defend access to clean water, and the opportunity for all communities to enjoy the benefits of a clean and healthy Spokane River.
The Spokane River is more than a scenic amenity; it is a lifeline for the community and a critical ecological system. The Spokane River provides essential habitat for a remnant population of Redband trout, a species of concern and a barometer of aquatic health. These trout are descendants of historically anadromous steelhead, landlocked by downstream Columbia Basin hydropower development. Redbands thrive in clean, cool, low-gradient rivers like the Spokane. Studies by the Washington Department of Fish and Wildlife indicate that populations in the upper Spokane River have declined nearly 75% since the 1990s. This decline is driven by habitat degradation, including removal of native riparian vegetation, construction of docks and overwater structures, sedimentation, nutrient pollution, warming water temperatures, and the proliferation of invasive species such as bass.
Redband trout require gravel riverbeds free of silt and excess nutrients such as phosphorus, which promote algae growth and deplete dissolved oxygen to successfully spawn and survive in www.spokaneriverkeeper.org | 35 W. Main Ave Suite 308, Spokane, WA 99201
[Professional contact details omitted from the reading text.]
[PDF page 3 of 5]
the watershed. Flooding events, like those on Hangman Creek in February of 2025, transport sediment into the Spokane River, damaging spawning grounds and aquatic insect populations that trout rely on for food. Ongoing shoreline and river-adjacent projects have the potential to further harm these sensitive habitats if conducted without careful planning and protections. Protecting riparian vegetation and shoreline forests is therefore essential to maintain water quality, moderate temperatures, and reduce sediment impacts.
Looking forward, any planning and development in the Spokane River watershed must also consider the potential for future salmon reintroduction. Restoring salmon to the Spokane River would require cool, clean flows, intact riparian buffers, and healthy in-stream and floodplain habitat, all of which are directly influenced by land use, stormwater management, and groundwater withdrawals. The Comprehensive Plan should ensure that growth, redevelopment, and infrastructure investments support these ecological conditions rather than degrade them, providing a river system resilient enough to sustain salmon populations alongside Redband trout and other native species. Proactive measures now, such as protecting undeveloped lands, reducing impervious surfaces, restoring shoreline vegetation, and maintaining sustainable aquifer and river flows, will determine whether salmon reintroduction efforts can succeed in the coming decades.
The Spokane River and the SVRP Aquifer are inseparably linked. The aquifer underlies roughly 370 square miles across Washington and Idaho, with some areas flowing as much as 60 feet per day, and contains an estimated 10 trillion gallons of water, making it one of the most productive aquifers in the country. It is the sole source of drinking water for over 600,000 residents of Spokane and Kootenai counties and contributes approximately 60% of the Spokane River’s annual outflow. Water from lakes, mountain streams, precipitation, and the river recharge the aquifer, and small changes in aquifer levels can dramatically alter river flows. Last year’s dry river event served as a stark warning: if we mismanage our water resources, the river will disappear and threaten the underlying aquifer, causing cascading ecological, social, and economic impacts. The DEIS must fully account for this interconnection by prioritizing conservation, sustainable water use, and recharge protection in land-use planning. This also means continuing to conduct environmental assessments to ensure water resources remain intact.
Population and housing growth must be balanced with river and aquifer health. While concentrating growth along existing centers and transit corridors can reduce sprawl, the DEIS should explicitly ensure that environmental review protects river-adjacent lands, floodplains, and undeveloped recharge areas. Redevelopment, infill, and higher-density housing must incorporate river-friendly stormwater management, low-impact development, riparian buffers, and green infrastructure to prevent sediment and nutrient loading and maintain cool, clean water for aquatic species. Industrial expansion similarly must avoid runoff, pollution, and habitat loss.
[PDF page 4 of 5]
Public services and utilities intersect with river health in critical ways. Trash and litter from unsheltered camps along the river have become a significant source of pollution, with over half of riverine trash originating from these camps. Spokane Riverkeeper has removed over 285,000 pounds of trash over the past decade, including 57,000 pounds in 2025 alone, yet cleanup alone does not solve the problem. Effective programs that integrate trash removal, outreach, and support services, like our floating clean-up and medical outreach model, have proven that people want to keep the river clean when given the tools to do so. Expanding such programs, including employing individuals with lived experience, providing consistent clean-up, and rapidly addressing abandoned camps, will reduce river pollution without criminalizing unsheltered individuals. Effective planning under the Comprehensive Plan must recognize that managing growth and housing affordability is not only a social imperative but also an environmental one: by ensuring safe, accessible housing options throughout the city, we reduce the pressure on river corridors, decrease the volume of trash entering the Spokane River, and support broader river stewardship efforts already underway by organizations like Spokane Riverkeeper
Climate change, flooding, and stormwater management further underscore the need for careful planning. Floods like those in 2016–17 and 2025 transport sediment, cover spawning substrates, and stress aquatic ecosystems. Green infrastructure, riparian restoration, limits on impervious surface expansion, and rigorous stormwater standards are essential to prevent damage to fish and invertebrate populations. Water conservation, including low-water-use landscaping, rainwater capture, and efficient irrigation, must be aggressively implemented to maintain aquifer levels and river flows under a warming climate.
In conclusion, the DEIS and Comprehensive Plan Update must treat the Spokane River and SVRP Aquifer as central to the city’s environmental, social, and economic health. We strongly recommend:
1. Protecting and restoring riparian forests, shoreline vegetation, and floodplains.
2. Ensuring environmental review and development regulations safeguard undeveloped lands, river corridors, and aquifer recharge zones.
3. Expanding water conservation measures across all sectors to maintain river flows and aquifer health.
4. Strengthening stormwater management and low-impact development standards to reduce sediment and nutrient loading.
5. Implementing structured trash management and outreach programs for unsheltered populations along the river.
6. Monitoring and managing aquifer-surface water interactions to maintain sustainable flows for fish, human use, and climate resilience.
7. Avoiding development patterns or projects that further degrade Redband trout habitat, including shading, sediment, and invasive species pressures.
[PDF page 5 of 5]
The health of the Spokane River is inseparable from the health of the city and its people. Protecting this resource now ensures clean water, resilient ecosystems, and a thriving community for generations to come.
Katelyn Scott - Spokane Riverkeeper
Feb 18, 2026
Community Advocate
[PDF page 1 of 5]
Please see attached our comments on the Draft EIS. We appreciate the opportunity to comment and look forward to seeing the responses.
Thank you,
Katelyn Scott
Water Protector (she/her/hers)
Spokane Riverkeeper
[Professional contact details omitted from the reading text.]
spokaneriverkeeper.org
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ATTACHMENT / ADDITIONAL PAGES
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Tirrell Black, Assistant Planning Director City of Spokane 808 W Spokane Falls Blvd. Spokane, WA 99201
Re: Draft Environmental Impact Statement – 2024 Comprehensive Plan Update
Dear City of Spokane Planning Team,
Spokane Riverkeeper appreciates the opportunity to provide comments on the Draft Environmental Impact Statement (DEIS) for the City of Spokane’s 2024 Comprehensive Plan Update. Our organization works to protect and restore the Spokane River and its watershed, including its fish, wildlife, and groundwater resources. We offer the following observations and recommendations regarding water resources, river and aquifer protection, and the iconic native Redband trout.
Spokane Riverkeeper is a non-profit, advocacy organization that works to protect the Spokane River Watershed. The mission of the organization is to protect and restore the health of the Spokane River watershed, defend access to clean water, and the opportunity for all communities to enjoy the benefits of a clean and healthy Spokane River.
The Spokane River is more than a scenic amenity; it is a lifeline for the community and a critical ecological system. The Spokane River provides essential habitat for a remnant population of Redband trout, a species of concern and a barometer of aquatic health. These trout are descendants of historically anadromous steelhead, landlocked by downstream Columbia Basin hydropower development. Redbands thrive in clean, cool, low-gradient rivers like the Spokane. Studies by the Washington Department of Fish and Wildlife indicate that populations in the upper Spokane River have declined nearly 75% since the 1990s. This decline is driven by habitat degradation, including removal of native riparian vegetation, construction of docks and overwater structures, sedimentation, nutrient pollution, warming water temperatures, and the proliferation of invasive species such as bass.
Redband trout require gravel riverbeds free of silt and excess nutrients such as phosphorus, which promote algae growth and deplete dissolved oxygen to successfully spawn and survive in www.spokaneriverkeeper.org | 35 W. Main Ave Suite 308, Spokane, WA 99201
[Professional contact details omitted from the reading text.]
[PDF page 3 of 5]
the watershed. Flooding events, like those on Hangman Creek in February of 2025, transport sediment into the Spokane River, damaging spawning grounds and aquatic insect populations that trout rely on for food. Ongoing shoreline and river-adjacent projects have the potential to further harm these sensitive habitats if conducted without careful planning and protections. Protecting riparian vegetation and shoreline forests is therefore essential to maintain water quality, moderate temperatures, and reduce sediment impacts.
Looking forward, any planning and development in the Spokane River watershed must also consider the potential for future salmon reintroduction. Restoring salmon to the Spokane River would require cool, clean flows, intact riparian buffers, and healthy in-stream and floodplain habitat, all of which are directly influenced by land use, stormwater management, and groundwater withdrawals. The Comprehensive Plan should ensure that growth, redevelopment, and infrastructure investments support these ecological conditions rather than degrade them, providing a river system resilient enough to sustain salmon populations alongside Redband trout and other native species. Proactive measures now, such as protecting undeveloped lands, reducing impervious surfaces, restoring shoreline vegetation, and maintaining sustainable aquifer and river flows, will determine whether salmon reintroduction efforts can succeed in the coming decades.
The Spokane River and the SVRP Aquifer are inseparably linked. The aquifer underlies roughly 370 square miles across Washington and Idaho, with some areas flowing as much as 60 feet per day, and contains an estimated 10 trillion gallons of water, making it one of the most productive aquifers in the country. It is the sole source of drinking water for over 600,000 residents of Spokane and Kootenai counties and contributes approximately 60% of the Spokane River’s annual outflow. Water from lakes, mountain streams, precipitation, and the river recharge the aquifer, and small changes in aquifer levels can dramatically alter river flows. Last year’s dry river event served as a stark warning: if we mismanage our water resources, the river will disappear and threaten the underlying aquifer, causing cascading ecological, social, and economic impacts. The DEIS must fully account for this interconnection by prioritizing conservation, sustainable water use, and recharge protection in land-use planning. This also means continuing to conduct environmental assessments to ensure water resources remain intact.
Population and housing growth must be balanced with river and aquifer health. While concentrating growth along existing centers and transit corridors can reduce sprawl, the DEIS should explicitly ensure that environmental review protects river-adjacent lands, floodplains, and undeveloped recharge areas. Redevelopment, infill, and higher-density housing must incorporate river-friendly stormwater management, low-impact development, riparian buffers, and green infrastructure to prevent sediment and nutrient loading and maintain cool, clean water for aquatic species. Industrial expansion similarly must avoid runoff, pollution, and habitat loss.
[PDF page 4 of 5]
Public services and utilities intersect with river health in critical ways. Trash and litter from unsheltered camps along the river have become a significant source of pollution, with over half of riverine trash originating from these camps. Spokane Riverkeeper has removed over 285,000 pounds of trash over the past decade, including 57,000 pounds in 2025 alone, yet cleanup alone does not solve the problem. Effective programs that integrate trash removal, outreach, and support services, like our floating clean-up and medical outreach model, have proven that people want to keep the river clean when given the tools to do so. Expanding such programs, including employing individuals with lived experience, providing consistent clean-up, and rapidly addressing abandoned camps, will reduce river pollution without criminalizing unsheltered individuals. Effective planning under the Comprehensive Plan must recognize that managing growth and housing affordability is not only a social imperative but also an environmental one: by ensuring safe, accessible housing options throughout the city, we reduce the pressure on river corridors, decrease the volume of trash entering the Spokane River, and support broader river stewardship efforts already underway by organizations like Spokane Riverkeeper
Climate change, flooding, and stormwater management further underscore the need for careful planning. Floods like those in 2016–17 and 2025 transport sediment, cover spawning substrates, and stress aquatic ecosystems. Green infrastructure, riparian restoration, limits on impervious surface expansion, and rigorous stormwater standards are essential to prevent damage to fish and invertebrate populations. Water conservation, including low-water-use landscaping, rainwater capture, and efficient irrigation, must be aggressively implemented to maintain aquifer levels and river flows under a warming climate.
In conclusion, the DEIS and Comprehensive Plan Update must treat the Spokane River and SVRP Aquifer as central to the city’s environmental, social, and economic health. We strongly recommend:
1. Protecting and restoring riparian forests, shoreline vegetation, and floodplains.
2. Ensuring environmental review and development regulations safeguard undeveloped lands, river corridors, and aquifer recharge zones.
3. Expanding water conservation measures across all sectors to maintain river flows and aquifer health.
4. Strengthening stormwater management and low-impact development standards to reduce sediment and nutrient loading.
5. Implementing structured trash management and outreach programs for unsheltered populations along the river.
6. Monitoring and managing aquifer-surface water interactions to maintain sustainable flows for fish, human use, and climate resilience.
7. Avoiding development patterns or projects that further degrade Redband trout habitat, including shading, sediment, and invasive species pressures.
[PDF page 5 of 5]
The health of the Spokane River is inseparable from the health of the city and its people. Protecting this resource now ensures clean water, resilient ecosystems, and a thriving community for generations to come.
Sincerely,
Katelyn Scott, Esq.
Water Protector
Spokane Riverkeeper