Jim Frank - Greenstone
Feb 17, 2026
Property / Development
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Hi Tirrell....this is a summary of some of my comments. I will send another series of comments by separate cover. This is very complicated and it was difficult to get everything I wanted to say in a single documents. Sorry if this is a bit confused.
Re: Comments on the PlanSpokane 2046 Draft Environmental Impact Statement
I appreciate the significant effort undertaken in preparation of the Draft Environmental Impact Statement (EIS). The attached series of comments address economic feasibility, subsidy efficiency, tenure equity, transportation performance, and alternatives adequacy under SEPA. The Draft EIS evaluates corridor-focused density alternatives but does not adequately analyze cost structure, ownership opportunity, distributed mixed-use growth patterns, or whether a reasonable Neighborhood Mixed-Use alternative should be evaluated.
The Draft EIS appears to assume that increasing zoning capacity for high-density multifamily development will inherently produce improved affordability outcomes. However, the document does not provide sufficient comparative economic analysis to support that conclusion within Spokane's land value context.
I have prepared a series of comments to address selected areas within the EIS. Many of these area are by necessity interrelated so I apologize for any redundancy.
1. Construction Cost Escalation and Affordability Assumptions
Typical Spokane hard construction costs are approximately:
- IRC-scale middle housing (small lot detached, duplex, cottage cluster, townhome): ~$175 per square foot
- Garden-style apartments (2-3 story wood frame): ~$300 per square foot
- 3-5 story podium or structured construction: ~$400 per square foot
Spokane land values generally range from $20-30 per square foot, or approximately $1.09 million per acre at midpoint. While increased density reduces land cost per unit, the reduction is modest relative to the escalation in structural and code-triggered construction costs.
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For a 1,000 square foot unit, estimated hard construction costs are approximately $175,000 for IRC-scale housing, $300,000 for garden apartments (+$125,000), and $400,000 for podium construction (+$225,000). Even accounting for land cost reductions at higher densities, total development cost rises substantially as density increases.
The Draft EIS does not include comparative total development cost analysis by typology, nor does it model subsidy gap per unit across alternatives. Without this analysis, the assumption that corridor-focused density produces superior affordability outcomes remains unsupported.
2. Subsidy Efficiency and Fiscal Impact
Affordable housing below 80% of Area Median Income typically requires public subsidy. As total development cost increases, required loan amounts increase, debt service increases, and the subsidy gap per unit expands. In Spokane's land value context, higher-density podium construction is likely to require significantly greater public subsidy per unit than IRC-scale housing.
The Draft EIS does not evaluate affordability outcomes per public dollar invested. Fiscal efficiency is a relevant environmental and policy consideration and should be analyzed.
3. Tenure Equity and Ownership Opportunity
The Draft EIS evaluates unit counts and density but does not evaluate tenure outcomes (ownership versus rental). Higher-density multifamily development is predominantly rental in structure. IRC-scale middle housing forms can provide fee-simple or condominium ownership opportunities.
Homeownership remains the primary mechanism for household wealth creation and intergenerational mobility. A strategy concentrating affordable production in rental-only formats may limit ownership opportunity for lower-income households and reduce tenure diversity.
4. Omission of a Neighborhood Mixed-Use Alternative
Action Alternatives 1, 2 and 3 focus growth along arterial corridors and designated centers. This reflects a high-density corridor growth premise. However, the Draft EIS does not evaluate a distributed Neighborhood Mixed-Use alternative.
A Neighborhood Mixed-Use zone could:
- Allow middle housing throughout most neighborhood interiors by right - Permit neighborhood-scale retail and services
- Encourage live-work units and small commercial nodes - Promote walkability and internal trip capture
- Distribute growth rather than concentrate it along arterials
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5. Transportation Performance and Research Support
Transportation research consistently demonstrates that walkable neighborhood scale mixed-use environments reduce vehicle trips and vehicle miles traveled (VMT).
Relevant research includes:
- Ewing & Cervero (2010) meta-analysis linking built environment factors to reduced VMT.
- U.S. EPA (2013) documentation of trip reduction through mixed-use internal capture.
- Congress for the New Urbanism studies indicating 20-40% VMT reduction in walkable mixed-use areas.
The Draft EIS does not analyze whether distributed neighborhood mixed-use zoning could achieve comparable or superior VMT reductions relative to corridor-focused density.
6. SEPA Alternatives Adequacy
Under SEPA, an EIS must evaluate reasonable alternatives capable of achieving project objectives. A distributed Neighborhood Mixed-Use alternative represents a feasible growth strategy that is not analyzed. Failure to evaluate this alternative may leave the range of reasonable alternatives incomplete.
Requested Additional Analysis The Final EIS should include:
- Comparative development cost modeling by housing typology - Subsidy gap per unit analysis
- Affordable units per public dollar comparison - Ownership vs rental tenure modeling - VMT modeling for distributed mixed-use scenario
Conclusion Density alone does not guarantee affordability. In Spokane's land cost environment, construction cost escalation associated with high-density multifamily development may increase subsidy requirements while limiting ownership opportunity. A distributed Neighborhood Mixed-Use strategy may better achieve affordability, transportation efficiency, and equity objectives.
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Technical Appendix: Cost and Density Comparison Key Assumptions:
- Land value: $25/sf (-$1.09M per acre)
- IRC construction cost: $175/sf - Garden apartment: $300/sf - Podium construction: $400/sf
- Average unit size: 1,000 sf - Net densities: Middle = 17 du/ac; Garden = 20 du/ac; Podium = 40 du/ac
This simplified comparison demonstrates that in Spokane's land value context, construction cost escalation substantially exceeds land savings achieved through increased density.
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Tirrell....these are the additional comments I am providing. In an additional message I am providing additional documentation to support my comments.
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Housing Allocation Methodologies and Spokane County Method A Prime Analysis
It does not appear that the city is using the housing allocation approved by the Board of County Commissioners and recommended by the SCEO. The city appears to using housing allocation numbers based upon a PTAC recommendation that was never approved. The PTAC recommendation radically altered the housing allocation and is a significant deviation from the information presented to the public, SCEO and the BOCC.
1. Overview of Approved HAPT Methodologies
The Washington State Department of Commerce's Housing for All Planning Tool (HAPT) provides three primary methodologies for allocating projected housing need among jurisdictions within a county.
Method A - Proportional Growth Share Allocates housing need based on each jurisdiction's share of projected population growth. Formula: Countywide Housing Need × Jurisdiction Population Growth Share. This method aligns housing allocations with adopted Countywide Planning Policies and Urban Growth Area (UGA) growth targets.
Method B - Equalized Total Housing Supply by Planning Horizon Allocates housing so that by the end of the planning period each jurisdiction holds the same proportional share of total housing supply at each income level. This method considers existing housing stock plus projected growth and aims to normalize distribution of housing types across jurisdictions.
Method C - Targeted Geographic Allocation Builds on Method A's proportional structure but allows geographic targeting of certain housing types, particularly lower-income units, toward Urban Growth Areas or jurisdictions with infrastructure capacity.
2. Spokane County Adoption of Method A Prime
Spokane County adopted a variation of Method A referred to as "Method A Prime." While maintaining the proportional allocation structure modifications were made to reflect local conditions. In the September 25, 2024, PTAC staff report recommending Method A prime the reports states "Method A Prime uses the same assumptions and calculations as Method A but allows a distinction between rural County lands, unincorporated UGAs and incorporated jurisdictions". One of the "Pros" for the A Prime methodology was that it reserves lower income housing for urban areas. After a public hearing the housing allocation was approved by the SCEO and recommended to the Board of County Commissioners on September 25,
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2024. On January 21, 2025, by resolution number 25-0033. the Board of County commissioners approved a housing allocation to each jurisdiction and it was accompanied by an exhibit that documented the allocation to each jurisdiction. See Appendix A.
3. PTAC Recommendation Regarding Housing Share
Subsequent to the Board action, on January 21, 2025, PTAC recommended a change in the Method A Prime methodology. They recommended that the HAPT input be "housing share" rather than "population share. One would expect "housing share" would not materially deviate from "population share". The input variables used by PTAC materially altered housing allocation outcomes.
Using "housing growth" share instead of population growth share, and whatever other formula modifications made by PTAC, the HAPT Prime A methodology produced significantly different results:
- Increased allocation to rural Spokane County from 3,534 units to 6,195 units (+75%)
- Reduced allocation to urban Spokane County from 22,946 units to 17,142 units (-34%)
- Reduced allocation Airway Heights from 5,007 units to 3,055 units (-27%)
- Reduced allocation to Liberty Lake from 6,601 units to 5,180 units (-27%)
- Increased allocation to City of Spokane from 17,550 units to 22,359 units (+27%)
This divergence decouples housing allocation from adopted population growth targets and may create tension with Growth Management Act principles emphasizing urban concentration, infrastructure efficiency, and reduction of sprawl. For example, rural Spokane County has a population allocation of 4,708 persons but is being allocated 6,195 housing units. This promotes sprawl in conflict with adopted County Wide Planning policies.
This policy recommendation from PTAC was never approved by SCEO or acted upon by the Board of County Commissioners.
4. Draft EIS Impact
It appears that the City of Spokane is not using the using the housing allocation as approved by the Board of County Commissioners resolution no. 25-0033, but rather the PTAC recommended change in data input. The EIS should be modified to reflect the proper housing allocation as approved by the Board of County Commissioners.
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EIS Comments Related to Housing Capacity, Speculative Land Pricing and Displacement Risk
Introduction This supplemental comment focuses on feasibility assumptions, land capacity modeling, speculative pricing effects, displacement risk, infrastructure concentration impacts, and alternatives adequacy under SEPA. While the Draft EIS evaluates zoning capacity and projected unit yield, it does not sufficiently analyze whether that capacity is economically feasible or how corridor-focused upzoning may distort land markets.
1. Feasible Capacity vs. Theoretical Zoning Capacity
The Draft EIS appears to equate zoned capacity with likely production. However, zoning capacity does not automatically translate into economically feasible development. Market absorption, construction cost thresholds, financing constraints, and rent supportability determine whether projects are built.
A significant portion of Spokane's remaining land capacity consists of:
- Underdeveloped land parcels - Underutilized land (single-family or low-intensity uses on land zoned for higher
density)
Redevelopment of underutilized parcels requires land acquisition at prices reflecting redevelopment potential, not existing use value. This increases land basis cost and undermines simple capacity assumptions.
2. Speculative Land Pricing and Corridor Upzoning
Upzoning concentrated along specific arterial corridors can lead to speculative land pricing. There is already observable pricing pressure along corridors such as Division, Hamilton, Monroe and 29th.
When landowners price property based on anticipated future density, land values increase ahead of development. Higher land basis directly increases total project cost and undermines affordability outcomes.
The Draft EIS does not analyze the impact of corridor upzoning on land speculation, nor does it evaluate whether speculative pricing may offset intended affordability gains.
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3. Displacement Risk and Concentration of Redevelopment Pressure
A substantial portion of Spokane's identified underutilized redevelopment capacity is located in historically lower-income neighborhoods, including West Central, East Central, Emerson Garfield and Hillyard. These neighborhoods contain a significant share of older housing stock, small commercial properties, and parcels zoned for higher density than currently built.
Corridor-focused upzoning and redevelopment incentives are therefore likely to concentrate redevelopment pressure in precisely those areas where land values remain comparatively lower and acquisition is more feasible. This creates a material risk that:
- Naturally occurring affordable housing (NOAH) will be demolished;
- Existing low-income renters will be displaced;
- Small neighborhood-serving businesses will be replaced by higher-cost redevelopment;
- Higher-income in-migrants will capture redevelopment benefits while existing residents bear disruption costs.
If higher-density redevelopment replaces older, lower-cost housing with substantially more expensive new construction, the net affordability impact may be neutral or even negative for existing residents.
The Draft EIS does not provide parcel-level demolition likelihood analysis, displacement modeling, or cumulative redevelopment pressure assessment in these neighborhoods. Nor does it evaluate whether concentrating growth in historically lower-income areas disproportionately shifts redevelopment burden onto vulnerable communities.
Housing equity requires that affordable housing opportunities and redevelopment capacity be equitably distributed across all neighborhoods in Spokane - not disproportionately located in neighborhoods that are already lower income.
The Final EIS should include:
- Neighborhood-level displacement risk analysis;
- Identification of naturally occurring affordable housing at risk of demolition;
- Comparative evaluation of redevelopment pressure across income geographies;
- Assessment of whether affordable housing production is equitably distributed citywide.
Conclusion Zoning capacity alone does not ensure feasible or affordable housing production. Speculative pricing, redevelopment land basis, displacement risk, and infrastructure concentration should be fully evaluated before selecting a preferred alternative.
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Draft EIS Comment City of Spokane Comprehensive Plan Update
Comment on Growth Strategy, Land Capacity Assumptions, and Market Feasibility The Draft Environmental Impact Statement (EIS) relies heavily on the assumption that Spokane's Centers & Corridors growth strategy - and its proposed intensification - will generate sufficient housing capacity to accommodate projected growth. However, both empirical growth patterns and the City's Land Capacity Analysis (LCA) raise substantial questions about whether this assumption is realistic.
1. The LCA Relies Primarily on Redevelopment
The 2025 Land Capacity Analysis identifies approximately 30,117 units of theoretical housing capacity. Of that total, approximately 10,344 units (34%) come from vacant land, while approximately 19,774 units (66%) depend on redevelopment of partially used or underutilized parcels, including corridor sites and the South Logan TOD subarea.
This means roughly two-thirds of projected housing capacity assumes redevelopment rather than development of vacant land. Redevelopment capacity is inherently less certain because it depends on willing sellers, financial feasibility, parcel assembly, demolition, environmental remediation, structured parking, infrastructure upgrades, and market rents sufficient to justify higher construction costs.
Over the last decade, the City of Spokane has grown at a slower rate than Spokane County overall and slower than Kootenai County, Idaho. A substantial share of regional housing growth has occurred in areas where development takes place primarily on vacant land rather than through corridor-based redevelopment. This raises a critical question: What evidence supports the assumption that increasing reliance on redevelopment will produce materially different results over the next 20 years?
3. Structural Cost Differential:
Redevelopment vs. Greenfield Development Redevelopment in corridor environments is materially more expensive than development on vacant land due to existing-use land acquisition costs, demolition, structured parking requirements, frontage improvements, utility relocation, tenant displacement mitigation, and greater financing risk. Affordable housing projects subject to prevailing wage and Evergreen standards often exceed $500 per square foot, increasing subsidy requirements.
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By contrast, development on vacant land or small-scale neighborhood infill typically avoids demolition costs, allows surface or no parking, and can be delivered at lower per-unit costs. The has been clearly demonstrated for example in the Highland Village neighborhood where Habitat and Community Frameworks, working with Greenstone have delivered over 100 affordable middle housing units with very modest subsidy.
4. Speculation and Land Pricing Effects
Upzoning limited corridor parcels without demonstrated redevelopment feasibility can increase land speculation, raise acquisition costs, encourage land banking, and reduce turnover. When land is priced based on theoretical mid-rise capacity but rents do not support those construction costs, projects stall. The EIS does not evaluate this risk.
5. Displacement and Equity Impacts
Much of the identified underutilized land capacity is located in historically lower-income neighborhoods such as West Central, East Central, and Hillyard. Because the LCA relies heavily on redevelopment in these areas, the strategy carries inherent displacement risk, including removal of naturally occurring affordable housing and increased land values. The EIS does not adequately analyze these risks.
Additional Comment: Compliance with HB 1220 - Planning for Housing in All Income Bands
HB 1220 requires jurisdictions to plan for and accommodate housing affordable to all economic segments of the community. The Draft EIS does not adequately evaluate whether a redevelopment-dominant growth strategy is consistent with these statutory requirements.
1. Redevelopment Raises Per-Unit Costs Across Income Bands
Because redevelopment sites are more expensive and complex to develop, higher per-unit costs reduce the number of affordable units that can be delivered with available subsidy funding. The EIS does not analyze how these cost factors affect production in the 0-50% AMI and 50-80% AMI income bands.
2. Moderate-Income Housing (80-120% AMI) Risks
Moderate-income housing often relies on lower-cost construction types such as duplexes, fourplexes, townhomes, and small-scale mixed-use infill. A corridor redevelopment strategy dependent on mid-rise construction may struggle to produce housing affordable to this income band without subsidy.
3. Geographic Equity and Distribution
If redevelopment capacity is concentrated in historically lower-income neighborhoods, the strategy risks reinforcing geographic concentration of affordable housing. The EIS should evaluate whether affordable housing opportunity is equitably distributed across neighborhoods.
4. Capacity vs. Deliverability
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The existence of theoretical redevelopment capacity does not guarantee production. Because redevelopment is more expensive and financially complex, a redevelopment-heavy strategy may reduce total deliverable units, increase reliance on limited public funding, and slow production rates.
Requested Additional Analysis To ensure compliance and realistic growth planning, the Final EIS should include:
1. A market feasibility analysis by income band.
2. Evaluation of subsidy capacity relative to redevelopment costs.
3. A geographic equity and displacement risk analysis.
4. Comparison of redevelopment-heavy growth versus broader neighborhood mixed-use growth.
Conclusion The Draft EIS assumes that redevelopment-based capacity will materialize at a scale not demonstrated over the past decade. Given that approximately two-thirds of projected housing capacity depends on redevelopment, additional analysis is necessary to ensure feasibility, equity, and compliance with housing planning requirements.
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Draft EIS Comment Inadequate Range of Alternatives - Failure to Evaluate a Broad Neighborhood Mixed Use Strategy
The Draft Environmental Impact Statement does not appear to evaluate a broadly distributed "Neighborhood Mixed Use" growth strategy as a reasonable alternative to continued reliance on a Centers and Corridors intensification models. All three alternatives analyzed retain the fundamental structural approach of concentrating increased density primarily within designated centers and arterial corridors. While the degree of intensification varies, the underlying development pattern remains corridor-focused.
The EIS does not analyze a materially different land use strategy in which large portions of existing Low Residential and Medium Residential zones are rezoned to a Neighborhood Mixed Use designation calibrated to middle housing scale. Such an approach would distribute growth across neighborhoods rather than concentrating redevelopment pressure along arterial corridors.
1. Requirement to Evaluate Reasonable Alternatives
Under SEPA, an EIS must evaluate a reasonable range of alternatives capable of achieving the proposal's objectives. A broadly distributed Neighborhood Mixed Use strategy could increase overall housing capacity, distribute growth geographically, reduce redevelopment pressure in lower-income corridors, lower per-unit construction costs, reduce land speculation, and improve walkability within neighborhoods.
Because such a strategy represents a fundamentally different land use pattern, it qualifies as a reasonable alternative that should be evaluated. Instead, the Draft EIS analyzes variations of the same corridor-centered framework.
2. Infrastructure and Transportation Implications
A corridor-intensification model assumes high concentrations of traffic along arterial streets, increased need for signalization and intersection upgrades, and greater localized utility capacity upgrades. By contrast, a distributed neighborhood mixed-use model would likely spread trip generation across a broader street network, reduce peak corridor congestion, and allow incremental infrastructure improvements. It has been documents that neighborhood based walkable mixed use can reduce vehicle trip by 30%. The development patterns over time lead to density that supports broader transit reach and service.
The EIS does not compare these infrastructure and transportation impact differences between a corridor-focused model and a broadly distributed mixed-use model.
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3. Housing Form and Market Feasibility Differences
Corridor-focused intensification often assumes mid-rise or podium construction types requiring higher land acquisition thresholds, structured parking, parcel assembly, and higher rents to achieve feasibility. A neighborhood mixed-use zoning framework calibrated to middle housing scale would allow incremental infill, participation by smaller developers, lower per-unit construction costs, and greater feasibility for moderate-income housing.
The Draft EIS does not evaluate whether a distributed middle-housing model could achieve housing targets with lower per-unit costs and greater market deliverability.
4. Equity and Geographic Distribution
Because identified underutilized land is disproportionately located in historically lower-income neighborhoods, a redevelopment-dependent corridor strategy may concentrate redevelopment pressure in those areas. A broadly distributed Neighborhood Mixed Use strategy would expand housing opportunity into higher-income neighborhoods and reduce concentration of affordability.
The EIS does not evaluate these geographic equity implications.
5. Land Speculation Risk
When growth capacity is concentrated in limited corridor areas, remaining vacant or underutilized parcels become speculative assets, and land pricing reflects theoretical buildout potential. A distributed rezoning approach would increase the supply of developable parcels across the city, potentially moderating speculative land pricing pressure. The Draft EIS does not analyze this dynamic.
6. Displacement Risk
When growth is concentrated in redevelopment areas there is a higher risk of displacement as existing affordable housing is demolished to facilitate the new higher intensity development. This is a very real risk in neighborhoods like West Central, East Central, Emerson Garfield and Hillyard where significant large single-family neighborhoods have been zoned for High Density residential development and classified in the LCA as "underutilized" land. The EIS does not analyze this risk.
Requested Revision The Final EIS should evaluate an alternative that rezones substantial portions of Low and Medium Residential areas and existing single family neighborhoods zoned for high density development to a calibrated Neighborhood Mixed Use designation, allows middle housing at scale citywide, reduces reliance on corridor mid-rise redevelopment, and compares infrastructure, displacement, feasibility, and equity outcomes against the corridor-centered alternatives.
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Without analysis of a materially different land use framework, the EIS does not provide decision-makers with a full understanding of reasonable growth strategies available to the City.
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Draft EIS Comment HB 1220 Compliance - Housing in All Income Bands
HB 1220 requires jurisdictions to plan for and accommodate housing affordable to all economic segments of the community. This includes identifying sufficient land capacity and adopting regulatory strategies that realistically enable housing production across all income bands. The Draft Environmental Impact Statement does not adequately evaluate whether a redevelopment-dominant growth strategy is consistent with these statutory requirements. The EIS identifies three plan alternatives:
Alternate 1: The current Comprehensive Plan, adopted in 2017, is based upon concentrating development in "center and corridors". Under Land Use Goals and Policies 3.3 the plan directed: "Much of the future growth should occur within concentrated areas in and around Neighborhood Centers, District Centers, Employment Centers and Regional Centers as designated on the land use map."
Alternate 2: This is called the "distributed and balanced" alternative but is follows the same concentrated development vision of Alternate
1. In the EIS summary is states "Alternate 2 adds greater job and housing intensity along frequent transit routes and applies the recommendations of the Centers and Corridors Study (2024). The study maintains the vision of concentrating development is existing commercial centers and along major arterials along with renaming the CC zones to mixed use nomenclature. This plan alternative does not envision a "neighborhood mixed use" environment where existing low and medium density areas would be rezoned to mix us to encourage middle housing and neighborhood scale commercial use expansion into all neighborhoods enhancing neighborhood walkability.
Alternate 3: The alternate is called City Center and Regional Hubs. This alternative is again a variation of the current centers and corridors plan and focuses development in the downtown core and the larger regional centers.
1. Redevelopment Raises Per-Unit Costs Across Income Bands
As demonstrated in the Land Capacity Analysis, approximately two-thirds of projected housing capacity depends on redevelopment of partially used or underutilized land. Redevelopment sites typically involve acquisition of improved property, demolition, structured parking, greater entitlement risk, and higher infrastructure costs. These factors materially increase per-unit development cost compared to housing constructed on vacant land or small-scale neighborhood infill. All three proposed alternatives focus concentrated growth in existing commercial centers and high traffic corridors. The are primarily redevelopment locations since they contain little "vacant" land.
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The dense concentrated housing in center and corridor locations will have construction costs of $300-$400 per square foot. For affordable housing projects receiving public funding, prevailing wage and Evergreen requirements further increase total development cost, often exceeding $500 per square foot. Higher per-unit costs reduce the number of affordable units that can be delivered with available subsidy funding.
2. Moderate-Income Housing (80-120% AMI) Risks
Moderate-income housing typically relies on construction types and land costs that allow projects to pencil without deep subsidy. Small-scale neighborhood mixed-use, duplexes, fourplexes, and townhomes can often be delivered at lower per-unit cost. By contrast, mid-rise corridor redevelopment with structured parking frequently requires rents above what moderate-income households can afford. A redevelopment-heavy strategy may therefore underperform in the moderate-income bands.
3. Geographic Equity and Distribution Requirements
State housing policy calls for avoiding concentrations of low-income housing and increasing access to affordable housing in areas where it is currently lacking. If redevelopment capacity is concentrated in historically lower-income neighborhoods, the strategy risks reinforcing geographic concentration of affordability rather than distributing housing opportunity equitably across all neighborhoods. All of the current alternative have concentrated development in the low income West Central, Emersons Garfield, East Central, and Hillyard neighborhoods.
4. Capacity vs. Deliverability The existence of theoretical redevelopment capacity does not guarantee production. Because redevelopment is more expensive and financially complex than neighborhood infill or development on vacant land, a redevelopment-heavy strategy may reduce total deliverable units, increase reliance on limited public funding, and slow production rates. The Final EIS should evaluate realistic production feasibility by income band under current and reasonably foreseeable market conditions.
Requested Additional Analysis
To ensure compliance with HB 1220, the Final EIS should include:
1. A market feasibility analysis by income band comparing redevelopment typologies to neighborhood mixed-use typologies.
2. Evaluation of subsidy capacity relative to redevelopment costs.
3. A geographic equity analysis showing likely distribution of affordable housing.
4. Comparison of redevelopment-heavy growth versus broader neighborhood mixed-use growth in meeting income-band targets.
Conclusion A growth strategy that relies primarily on corridor redevelopment rather than broader neighborhood mixed-use may increase per-unit housing costs, reduce deliverability in moderate and low-income bands, and risk geographic concentration of affordability.
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Additional analysis is necessary to ensure that the preferred alternative complies with HB 1220 and produces housing outcomes consistent with state policy.
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Comments to SCEO Related to the County Wide Planning Policies and Modification of the Urban Growth Boundary.docx Comments on Racial and Economic Inequality in Housing.pdf Residential Construction Costs by Unit Type.pdf Comments on City LCA.docx
Tirrell....These are documents submitted in support of the comments letter. Please consider these part of my subhmittal.
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Re: GMA Housing Policy Land Capacity Analysis
I have spent the past few month trying to understand the process we are going through as a community to plan for our growth and establish housing opportunity for the community over the next 20 years. The roadmap set out by State statute and the Department of Commerce is incredibly complicated and virtually impossible for the public to meaningly participate.
It is very easy to get caught in the complexity of land capacity analysis; definitions of "underdeveloped" and "under-utilized" property; infrastructure gap analysis; achievable density; and housing income bands while losing sight of the vision we have for our community.
The GMA process is about both where we will build our homes over the next 20 years and what kind of homes and neighborhoods we want for our families. The focus on the boundary and land capacity has resulted in an emphasis on density and little discussion on the kind of neighborhoods that allow families to thrive.
The Importance of Moderate Density Housing:
The guidance to the process from the Department of Commerce reflects their experience in providing affordable housing. They fund and support the development of large apartment projects. This reflects their experience and expertise. While this may be an efficient funding process it is a housing and community planning failure.
Strong and resilient neighborhoods need diversity housing types at moderate density and finely integrated with close proximity to services. The same is true if we intend to provide opportunity for all families. This means we have a vision to support neighborhoods that are economically diverse; include a wide range of housing products; are mixed use in character; and walkable.
The challenge is this requires a comprehensive change in development regulations. The walkable, housing diverse and mixed use neighborhoods you see in Kendall Yards and River District (Liberty Lake) were possible only because development code waivers and flexibility was provided in those jurisdictions. Here is the housing policy vision from Snohomish County which can serve as a template for Spokane County:
"The county and cities should implement policies that allow for the development of moderate density housing to help meet future housing needs, diversify the housing stock, and provide more affordable home ownership and rental opportunities. This approach should include code updates to ensure that zoning designations and allowed densities, housing capacity, and other restrictions do not preclude development of moderate density housing."
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The important elements of this policy vision are "moderate density"; "diversify the housing stock"; and "affordable home ownership and rental opportunities". From Commerce's perspective housing affordable to families making less that 80% of median income is only possible with MF rental apartments. This is not true. The private sector can built small attached or detached SF homes for a lower cost than Commerce funds large apartment projects. The problem is that development codes have minimum lot sizes and development dimensional standards (frontage, site coverage and setback requirement) that make the construction of small homes on small lot impossible. State law and some new development regulations are allowing 4-plex units and even 6-plex on a lot, but this serves primarily rental housing, not home ownership. Homeownership requires a platted lot to convey ownership (state law has effectively prohibited condominium units and other forms of common interest ownership). Affordable housing solutions go well beyond the "higher density" narrative.
The Lack of Land Inventory:
No single factor has driven up housing cost more that land prices. The lack of land that is "reasonably available for residential development" is critical in Spokane County and has led to rapidly increasing home prices. The median family home in Spokane County has risen dramatically in the past ten years, from under $200,0000 to over $400,000. Land prices in this same period have increased more than four-fold. Even in neighborhoods like West Central and East Central, lot prices alone are exceeding $200,000.
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The Land Capacity Analysis recommended by Commerce is incredibly complex and systemically over estimates land that is "reasonably available for development". Here is a breakdown of the process:
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Because of the complexity, jurisdictions have been short-cutting the process or eliminating steps. For example most jurisdiction are not completing an infrastructure "gap analysis" and are just assuming that all land can be serviced. Jurisdictions are not properly setting aside land for future roadways and public facilities like parks, schools and open space. Expansive definitions of "vacant Land", "underdeveloped Land" and "under-utilized land" are being used that significantly overestimate the inventory of land that can be developed. If the region had a 20 year supply of land capable you would not have seen the rapid and dramatic increase in land and housing prices we are experiencing. There is a significance difference in the "theoretical" land inventory derived from the LCA process being used by local jurisdictions and actual market conditions.
The Consequence of Inadequate Housing and Land Inventory
The primary purpose of the Growth management Act and the imposition of a Urban Growth Boundary Is to limit "urban sprawl" and focus growth where infrastructure is currently available. In Spokane County, which shares a metropolitan area with Kootenai County, limiting growth within the restrictive GMA boundary has resulted in housing and commercial growth "leaking" to north Idaho. The consequence of a restriction on land inventory available for urban development in Spokane County is the shifting of growth to Kootenai County. A shift of 500 residential units a year (the actual leakage is likely much greater) from Spokane County to Kootenai County has very negative fiscal and environmental impacts.
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Comments to SCEO Related to the County Wide Planning Policies and Modification of the Urban Growth Boundary
Over the past 12 months we have provided a series of comments and documentation on important issues related to providing for adequate housing for our population and housing equity. The attached are some of the documents previously submitted.
As this process moves from policy guidance to the updating of comprehensive plans by each jurisdiction, we want to summarize the issue we think most important:
1. While family size is decreasing due to a declining birth rate, household size is increasing. You will find a census summary that documents this. The increasing household size is a result of housing
cost so high that persons from different household are sharing housing.
This reflects the desperate shortage and high cost of housing because of a lack of housing inventory.
2. Home ownership rates are declining, and this is especially true for racial minorities. Kootenai County is not seeing the same decline in homeownership being seem in Spokane.
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3. At the staff level (both local and state) a consensus has developed that the only way to providing housing for middle- and low-income families is to build apartments and rental housing. The solution they offer to meeting housing demand is not providing more land for housing but increasing the density permitted on existing available land. This ignores several realities of new home development. These include the following:
a. The cost of constructing housing escalates rapidly with the mass and scale of the building. SF homes constructed under the IRC
cost about half (cost per SF) of multistory apartment buildings built under the UBC. This is due to a wide range of access, fire safety, energy
code and stormwater standards that are required under the UBC that are not required under the IRC.
b. Significant opportunity to increase density exists in building SF homes if codes would permit the construction of "small homes
on small lots". Most local codes prevent or make the construction of small detached and attached SF homes very difficult and costly. This is
the result of zoning standards like minimum lot sizes, street frontage requirements and restrictive site coverage standards. If SF homes were
permitted on small lots, you can achieve net densities over 18 DU/acres. The reality is that the urban spawl which GMA is trying to reverse is all that is permitted by most codes with large minimum lot
sizes.
c. The emphasis on building more apartments is at the expense of homeownership and housing equity of low-income families and racial minorities. Middle- and low-income families are given no
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housing choice but living in large apartment complexes that are not integrated into neighborhoods when affordable homeownership should and can be an option. This perpetuates the historic inequality in housing opportunity and in the case of our region is simply driving housing to Kootenai County with a significant fiscal impact of Spokane County jurisdictions. (We have documented the construction cost differential, the shift in building permits to Kootenai County and the fiscal impact in the attached documents).
This is an issue that needs to be addressed by the Growth Management Steering Committee and the Board of County Commissioners.
4. PTAC has recommended a procedure for the allocation of housing units that is not based on population but what they call "housing growth". This has not been acted on by either SCEO or the Board of County Commissioners and results in a serious misallocation of housing within the County.
The PTAC recommendation, when compared to a population-based allocation, increases the housing allocated to the City of Spokane and rural Spokane County, and decreases the allocation to Unincorporated Spokane County and most of the smaller cities. The details of the PTAC recommendation and the shift in housing allocation is in our documents. This policy recommendation should be rejected.
As we have documented, the city of Spokane is the local jurisdiction least capable of providing new housing and doubling the housing allocation to rural Spokane County is contrary to the County wide Planning Policies the SCEO has already adopted.
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5. The City of Spokane has grossly overestimated the amount of land reasonably available for residential development in the LCA submitted. The city has ignored many of the requirements outlined in the Burke Consulting (Commerce contractor) on the process to be used in the preparation of an LCA. The deficiencies have been documented in the material we have submitted for the record.
This is important since land cost is the principal driver of higher housing costs and the current lack of land inventory in Spokane is driving housing to outlying areas and Kootenai County. The City of Spokane in 2025 has the lowest number of single-family home construction permits in over 15 years with a mere 120 SF permits issued thru the end of November (Documentation of provided in our submittals).
The lack of housing construction in the City of Spokane has been the primary cause of increasing regional housing costs. We recommend that the County reject the City of Spokane LCA.
6. The misguided emphasis on apartments as the only way to provide affordable housing and the lack of reasonably available land for residential development is limiting housing options for low- and middle-income family. Maybe more importantly it is diving residential development to Kootenai County which subverts the purpose of an Urban Growth Boundary. This impact is well documented in the submittals we have made.
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July 22, 2025
City of Spokane Plan Commission Racially Disparate Impact on Housing
Ezra Klein and Derek Thompson's recent book Abundance documents the national housing crisis that has been decades in the making. After years of inadequate construction and policy inaction, we now face a severe shortage of affordable housing in Spokane. Our city has failed to build enough housing to keep pace with a growing population, leading to skyrocketing prices and rents. For middle- and low-income families, owning or renting a home is increasingly out of reach. The are many regulatory policies, engineering standards, and development code provisions that have in the past and continue to discriminate against lower income and racial minority populations.
The central question we must ask is: How can we foster a political and cultural environment where housing is built at a scale and pace that ensures affordability and abundance for all? Unfortunately, we have restricted the land available for new homes and there's a prevailing political belief that the only way to achieve affordability is by constructing more apartment complexes. However, this approach overlooks a key reality: as the mass and scale of buildings increase, so too do construction costs. Large apartment buildings, especially those aimed at middle- and low-income families, are not only costly to construct but often perpetuate inequality and restrict housing options. The assumption that apartments are the answer to housing affordability is misguided and must be challenged.
The real solution to housing affordability and equality - and the creation of livable, connected neighborhoods - lies in developing "middle housing." These are small homes, either attached or detached, on small lots, such as townhomes or small multifamily buildings (generally fewer than 12 units). Unlike larger apartment complexes, middle housing can be integrated into neighborhoods, preserving the character of communities while increasing housing stock and home ownership. While this approach sounds simple, it faces significant hurdles. Current zoning, and building regulations make it easier to develop large apartment complexes than to build small, affordable homes on smaller lots. This regulatory imbalance must be addressed. Here are a few critical areas:
1. Land Capacity:
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If there is insufficient land to build new homes prices will escalate rapidly. In 2021 the legislature passed HB1021 which required that each jurisdiction prepare a Land Capacity Analysis (LCA) to ensure that they have capacity to accommodate 20 years residential growth based upon population forecasts. The Spokane LCA claims to have land capacity far in excess of there required for 20 years growth, while the actual market conditions and land available for development tell a very different story. The burden of high land prices falls on racial minorities and low income families who's incomes do not keep pace with escalating land prices. Attached is a document that outlines the ways in which the Spokane LCA has overestimated land available for residential development.
2. Zoning: Spokane has zoned numerous low income neighborhoods (parts of West Central, East Central, Emerson Garfield, Logan and Hillyard) with fully developed single family neighborhood for high density MF development. Under GMA single family home neighborhoods with multifamily zoning are designated as "underutilized land" available for redevelopment. This is a policy that encourages the redevelopment of single family home neighborhoods and the displacement of existing residents who are primarily low income. This policy creates economic and racial segregation and inequity in housing.
3. Home Ownership:
A regulatory and policy consensus has developed around the idea that housing affordability can only be developed around building more large apartments. This ignores the reality that housing construction costs increase rapidly with building mass and scale. See the attached documentation. For low income families small home on small lots (including SF attached and townhomes) are the most affordable option. Housing for all income bands should be affordable and located in connected neighborhoods. Restraining low income housing to apartments simply sustains housing inequality in our communities.
4. Development Code Standards:
Dimensional standards (lot size, site coverage, building height, street frontage requirements) and complex long plat, short plat and unit lot subdivision requirements make the development of small home and middle housing very difficult and expensive. The very "middle housing" that we are trying to encourage is the most regulated and difficult to develop. These standards discriminate against small homes and small lots creating economic and racial inequality.
5. Engineering Standards:
There are numerous engineering standards and fee structures that favor large homes on large lots at the expense of small homes. This includes stormwater review requirements, GFC fees, and Traffic impact fees. Fees are generally "one size fits all" rather than reflecting the lower service demand from smaller units. For example a small 1000SF home might pay the same GFC fee and traffic mitigation fee as a 3000SF home. The inequality in engineering standards and fees is systemic. Recent stormwater requirements place a significant burden on lower income home neighborhoods while higher income neighborhoods are allowed to meet significantly lower standards.
Addressing the significant regulatory imbalance that limits housing affordability for lower income families and racial minorities is very complex. It must begin with active listening to the low income families with few housing opportunities and those small market rate and nonprofit housing providers who struggle to meet this need.
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Affordable Housing Options Small Homes on Small Lots and Townhomes: The Preferred Option for Affordable Housing in Low Income Bands
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Housing for all income bands should be be affordable, resilient, and located in connected neighborhoods and communities.
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Misconception: Apartments as the Preferred Housing Option for Low Income Bands Apartments cost more to construct
Apartments have very long approval and construction lead times
Apartments are generally located in commercial high traffic and high land cost corridors
Apartment do not integrate finely into existing neighborhoods
Apartments sustain the housing inequality in our communities
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Variable Housing Construction Costs Development costs increase as mass, scale and complexity of the structure increases - More complex construction systems
- Increased life safety and energy code requirement
- Fewer siting options and higher land costs
- More complex and fewer financing options
- Much longer entitlement and construction time frames
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The Average Cost of Commerce Funded Apartment Projects: $475,000 per unit
Department of Commerce Housing Trust Fund Projects 2024
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Small Homes Home on Small Lots Provide Best Option for Affordable Housing Small homes and townhomes are the lowest cost housing option
On small lots single family homes can achieve MF density
Small homes have short construction lead times and are easier to finance than apartments
Small homes and townhomes easily integrate into existing neighborhoods
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Clustered and Attached Single Family Homes Achieve Net Density Similar to Apartment Projects
- SF Detached on 3000sf lots at 15 units/acre
- SF Attached on 2500sf lots at 18 units/acre
- Townhomes on 1500sf lots at 29 units/acre
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Habitat Cottage Homes $280,000 Highland Village in Airway Heights 2025
- One and Two story Cottage Homes 1200-1400sf
- Lot Size 3000 SF - Construction Costs $175/sf - Total units developments costs about $280,000 per unit
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1. Single Family Detached and Attached (three or fewer units):
- Construction Cost: $175 SF - Net Density Range: 12-18 DU/acre
Construction under International Residential Code (IRC). Simplified building permit review. Plans can be pre-approved. Plans do not require licensed architect. No civil engineering or stormwater review required. Limited or no parking requirements, can take advantage of on street parking. Units can be finely integrated into most neighborhoods with SF or MF zoning providing greater choice and opportunity to families.
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2. Attached Single Family, Townhomes, Small
MF (four or more units):
- Construction Cost: $225/SF - Net Density Range: 12-22 DU/acre
Four or more units are treated as commercial construction and are governed by the Uniform Building Code (UBC). Building plans must be submitted by licensed architect, civil engineering plans required, stormwater management plan required, units must be sprinkled, low frequency fire alarms are required, more stringent energy code and design review requirements. Generally can be integrated into most neighborhoods.
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3. MF Construction Up to 4 Stories with Surface Parking:
- Construction Cost: $300/SF - Net Density: 30-50 DU/acre
Construction is governed by UBC. Projects tend to be larger 40 or more units. Require detailed civil engineering plans for utilities, access and parking. Detailed stormwater engineering plans. Geotechnical soils analysis. SEPA review and traffic impact analysis. Elevators, hallways and secondary stairway systems. Development of detailed fire protection system and fire wall protections. More complicated appraisal and construction financing costs. Significantly longer development timelines and construction phase interest expense. Sites limited to MF zones with arterial access and not integrated well into neighborhoods.
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4. Multi Family Four or more Stories with Structured
Parking:
- Construction Cost: $400/ SF - Net Density Range: 30-50 DU/acre
Construction is governed by UBC. Projects tend to be larger 100 units or more. Require detailed civil engineering plans for utilities, access and parking. Detailed stormwater engineering plans. Geotechnical soils analysis. SEPA review and traffic impact analysis. Elevators, hallways and secondary stairway systems. Development of detailed fire protection systems and fire wall protections. More complicated appraisal and construction financing costs. Significantly longer development timelines and construction phase interest expense. Limited to high density MF zones in high land cost areas.
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Comments on City of Spokane Land Capacity Analysis
The Land Capacity Analysis submitted by the City of Spokane February 2025 is fundamentally flawed and does not reflect an inventory of land reasonably available for housing development during the 20-year study period. Rather the City of Spokane has created an inventory that grossly overestimates land available for housing development. The purpose of the LCA is to identify land likely to be available for residential development during the study period. Rather the city analysis included all land that could theoretically be developed as residential, even when such lands are not likely to be available for development during the study period.
A careful review of the City Land Capacity Analysis reflects the following:
1. Infrastructure Gap Analysis: The city did not identify lands subject to infrastructure gaps that will prevent the assigned densities from being achieved or will delay development during the planning period. RCW 36.70A.215 requires
jurisdictions consider the lack of transportation and utility infrastructure in the land capacity analysis.
2. Vacant Properties: The city failed to consider where adjacent properties are owned by the same party the Assessor commonly assigns the full assessed value to only
one parcel when in fact improvements are located on two or more adjacent parcels owned in common. A significant number of parcels have been identified as "vacant" when they in fact have substantial improvements and improved value.
3. Partially Developed Properties: The city has identified many properties as partially developed where they are not in a current residential use. This includes
churches, cemeteries, schools and businesses where the zoning might permit residential use, but the current use is not residential.
The city provided no mechanism to filter out properties where future residential use was unlikely.
4. Underutilized Land: The category includes parcels improved with single family homes but with zoning that permits higher intensity use. The city provided no
analysis to assure that there was a strong possibility that the property would be redeveloped to a more intensive use in the planning period. The city has many
inner-city SF neighborhood that are zoned for a more intensive use (West Central, Emerson Garfield, Hillyard and East Central) and there is no history of any
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significant redevelopment in these neighborhoods. Our survey of 800 homes in West Central zoned HDR showed only 3 that redeveloped in the past 20 years. This category includes almost 30% of the city estimated housing capacity.
5. Critical Lands: The city has not properly evaluated wetlands, floodplains, and geologic constraints that will limit development in the future. There are many
environmental constraints that do not make development illegal but will significantly reduce the likelihood and density of development.
6. Current Public Use Lands: The city did not exclude lands owned by Federal, State, or local municipality or government that are not likely to be available for development in the planning period.
7. Future Road ROW and Utility Land: The city used a factor of 15% only on larger parcels as a reduction in land available for development. This grossly
underestimates the land required for future development. Our analysis of over 30 projects shows the road and utility requirements to be in the range of 20-35%. ROW
requirements for small projects are significant.
8. Future Public Facilities: The City made no attempt to identify the need for future public facility needs (open space, parks, schools, churches, fire stations, libraries
and so forth) that will be required the planned population increase of 100,000 persons and make a deduction of land inventory for such uses.
Jim Frank - Greenstone
Feb 17, 2026
Property / Development
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Hi Tirrell....this is a summary of some of my comments. I will send another series of comments by separate cover. This is very complicated and it was difficult to get everything I wanted to say in a single documents. Sorry if this is a bit confused.
Thanks, Jim
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ATTACHMENT / ADDITIONAL PAGES
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Jim Frank
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February 14, 2026
Re: Comments on the PlanSpokane 2046 Draft Environmental Impact Statement
I appreciate the significant effort undertaken in preparation of the Draft Environmental Impact Statement (EIS). The attached series of comments address economic feasibility, subsidy efficiency, tenure equity, transportation performance, and alternatives adequacy under SEPA. The Draft EIS evaluates corridor-focused density alternatives but does not adequately analyze cost structure, ownership opportunity, distributed mixed-use growth patterns, or whether a reasonable Neighborhood Mixed-Use alternative should be evaluated.
The Draft EIS appears to assume that increasing zoning capacity for high-density multifamily development will inherently produce improved affordability outcomes. However, the document does not provide sufficient comparative economic analysis to support that conclusion within Spokane's land value context.
I have prepared a series of comments to address selected areas within the EIS. Many of these area are by necessity interrelated so I apologize for any redundancy.
1. Construction Cost Escalation and Affordability Assumptions
Typical Spokane hard construction costs are approximately:
- IRC-scale middle housing (small lot detached, duplex, cottage cluster, townhome): ~$175 per square foot
- Garden-style apartments (2-3 story wood frame): ~$300 per square foot
- 3-5 story podium or structured construction: ~$400 per square foot
Spokane land values generally range from $20-30 per square foot, or approximately $1.09 million per acre at midpoint. While increased density reduces land cost per unit, the reduction is modest relative to the escalation in structural and code-triggered construction costs.
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For a 1,000 square foot unit, estimated hard construction costs are approximately $175,000 for IRC-scale housing, $300,000 for garden apartments (+$125,000), and $400,000 for podium construction (+$225,000). Even accounting for land cost reductions at higher densities, total development cost rises substantially as density increases.
The Draft EIS does not include comparative total development cost analysis by typology, nor does it model subsidy gap per unit across alternatives. Without this analysis, the assumption that corridor-focused density produces superior affordability outcomes remains unsupported.
2. Subsidy Efficiency and Fiscal Impact
Affordable housing below 80% of Area Median Income typically requires public subsidy. As total development cost increases, required loan amounts increase, debt service increases, and the subsidy gap per unit expands. In Spokane's land value context, higher-density podium construction is likely to require significantly greater public subsidy per unit than IRC-scale housing.
The Draft EIS does not evaluate affordability outcomes per public dollar invested. Fiscal efficiency is a relevant environmental and policy consideration and should be analyzed.
3. Tenure Equity and Ownership Opportunity
The Draft EIS evaluates unit counts and density but does not evaluate tenure outcomes (ownership versus rental). Higher-density multifamily development is predominantly rental in structure. IRC-scale middle housing forms can provide fee-simple or condominium ownership opportunities.
Homeownership remains the primary mechanism for household wealth creation and intergenerational mobility. A strategy concentrating affordable production in rental-only formats may limit ownership opportunity for lower-income households and reduce tenure diversity.
4. Omission of a Neighborhood Mixed-Use Alternative
Action Alternatives 1, 2 and 3 focus growth along arterial corridors and designated centers. This reflects a high-density corridor growth premise. However, the Draft EIS does not evaluate a distributed Neighborhood Mixed-Use alternative.
A Neighborhood Mixed-Use zone could:
- Allow middle housing throughout most neighborhood interiors by right - Permit neighborhood-scale retail and services
- Encourage live-work units and small commercial nodes - Promote walkability and internal trip capture
- Distribute growth rather than concentrate it along arterials
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5. Transportation Performance and Research Support
Transportation research consistently demonstrates that walkable neighborhood scale mixed-use environments reduce vehicle trips and vehicle miles traveled (VMT).
Relevant research includes:
- Ewing & Cervero (2010) meta-analysis linking built environment factors to reduced VMT.
- U.S. EPA (2013) documentation of trip reduction through mixed-use internal capture.
- Congress for the New Urbanism studies indicating 20-40% VMT reduction in walkable mixed-use areas.
The Draft EIS does not analyze whether distributed neighborhood mixed-use zoning could achieve comparable or superior VMT reductions relative to corridor-focused density.
6. SEPA Alternatives Adequacy
Under SEPA, an EIS must evaluate reasonable alternatives capable of achieving project objectives. A distributed Neighborhood Mixed-Use alternative represents a feasible growth strategy that is not analyzed. Failure to evaluate this alternative may leave the range of reasonable alternatives incomplete.
Requested Additional Analysis The Final EIS should include:
- Comparative development cost modeling by housing typology - Subsidy gap per unit analysis
- Affordable units per public dollar comparison - Ownership vs rental tenure modeling - VMT modeling for distributed mixed-use scenario
Conclusion Density alone does not guarantee affordability. In Spokane's land cost environment, construction cost escalation associated with high-density multifamily development may increase subsidy requirements while limiting ownership opportunity. A distributed Neighborhood Mixed-Use strategy may better achieve affordability, transportation efficiency, and equity objectives.
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Technical Appendix: Cost and Density Comparison Key Assumptions:
- Land value: $25/sf (-$1.09M per acre)
- IRC construction cost: $175/sf - Garden apartment: $300/sf - Podium construction: $400/sf
- Average unit size: 1,000 sf - Net densities: Middle = 17 du/ac; Garden = 20 du/ac; Podium = 40 du/ac
This simplified comparison demonstrates that in Spokane's land value context, construction cost escalation substantially exceeds land savings achieved through increased density.
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Tirrell....these are the additional comments I am providing. In an additional message I am providing additional documentation to support my comments.
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Housing Allocation Methodologies and Spokane County Method A Prime Analysis
It does not appear that the city is using the housing allocation approved by the Board of County Commissioners and recommended by the SCEO. The city appears to using housing allocation numbers based upon a PTAC recommendation that was never approved. The PTAC recommendation radically altered the housing allocation and is a significant deviation from the information presented to the public, SCEO and the BOCC.
1. Overview of Approved HAPT Methodologies
The Washington State Department of Commerce's Housing for All Planning Tool (HAPT) provides three primary methodologies for allocating projected housing need among jurisdictions within a county.
Method A - Proportional Growth Share Allocates housing need based on each jurisdiction's share of projected population growth. Formula: Countywide Housing Need × Jurisdiction Population Growth Share. This method aligns housing allocations with adopted Countywide Planning Policies and Urban Growth Area (UGA) growth targets.
Method B - Equalized Total Housing Supply by Planning Horizon Allocates housing so that by the end of the planning period each jurisdiction holds the same proportional share of total housing supply at each income level. This method considers existing housing stock plus projected growth and aims to normalize distribution of housing types across jurisdictions.
Method C - Targeted Geographic Allocation Builds on Method A's proportional structure but allows geographic targeting of certain housing types, particularly lower-income units, toward Urban Growth Areas or jurisdictions with infrastructure capacity.
2. Spokane County Adoption of Method A Prime
Spokane County adopted a variation of Method A referred to as "Method A Prime." While maintaining the proportional allocation structure modifications were made to reflect local conditions. In the September 25, 2024, PTAC staff report recommending Method A prime the reports states "Method A Prime uses the same assumptions and calculations as Method A but allows a distinction between rural County lands, unincorporated UGAs and incorporated jurisdictions". One of the "Pros" for the A Prime methodology was that it reserves lower income housing for urban areas. After a public hearing the housing allocation was approved by the SCEO and recommended to the Board of County Commissioners on September 25,
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2024. On January 21, 2025, by resolution number 25-0033. the Board of County commissioners approved a housing allocation to each jurisdiction and it was accompanied by an exhibit that documented the allocation to each jurisdiction. See Appendix A.
3. PTAC Recommendation Regarding Housing Share
Subsequent to the Board action, on January 21, 2025, PTAC recommended a change in the Method A Prime methodology. They recommended that the HAPT input be "housing share" rather than "population share. One would expect "housing share" would not materially deviate from "population share". The input variables used by PTAC materially altered housing allocation outcomes.
Using "housing growth" share instead of population growth share, and whatever other formula modifications made by PTAC, the HAPT Prime A methodology produced significantly different results:
- Increased allocation to rural Spokane County from 3,534 units to 6,195 units (+75%)
- Reduced allocation to urban Spokane County from 22,946 units to 17,142 units (-34%)
- Reduced allocation Airway Heights from 5,007 units to 3,055 units (-27%)
- Reduced allocation to Liberty Lake from 6,601 units to 5,180 units (-27%)
- Increased allocation to City of Spokane from 17,550 units to 22,359 units (+27%)
This divergence decouples housing allocation from adopted population growth targets and may create tension with Growth Management Act principles emphasizing urban concentration, infrastructure efficiency, and reduction of sprawl. For example, rural Spokane County has a population allocation of 4,708 persons but is being allocated 6,195 housing units. This promotes sprawl in conflict with adopted County Wide Planning policies.
This policy recommendation from PTAC was never approved by SCEO or acted upon by the Board of County Commissioners.
4. Draft EIS Impact
It appears that the City of Spokane is not using the using the housing allocation as approved by the Board of County Commissioners resolution no. 25-0033, but rather the PTAC recommended change in data input. The EIS should be modified to reflect the proper housing allocation as approved by the Board of County Commissioners.
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EIS Comments Related to Housing Capacity, Speculative Land Pricing and Displacement Risk
Introduction This supplemental comment focuses on feasibility assumptions, land capacity modeling, speculative pricing effects, displacement risk, infrastructure concentration impacts, and alternatives adequacy under SEPA. While the Draft EIS evaluates zoning capacity and projected unit yield, it does not sufficiently analyze whether that capacity is economically feasible or how corridor-focused upzoning may distort land markets.
1. Feasible Capacity vs. Theoretical Zoning Capacity
The Draft EIS appears to equate zoned capacity with likely production. However, zoning capacity does not automatically translate into economically feasible development. Market absorption, construction cost thresholds, financing constraints, and rent supportability determine whether projects are built.
A significant portion of Spokane's remaining land capacity consists of:
- Underdeveloped land parcels - Underutilized land (single-family or low-intensity uses on land zoned for higher
density)
Redevelopment of underutilized parcels requires land acquisition at prices reflecting redevelopment potential, not existing use value. This increases land basis cost and undermines simple capacity assumptions.
2. Speculative Land Pricing and Corridor Upzoning
Upzoning concentrated along specific arterial corridors can lead to speculative land pricing. There is already observable pricing pressure along corridors such as Division, Hamilton, Monroe and 29th.
When landowners price property based on anticipated future density, land values increase ahead of development. Higher land basis directly increases total project cost and undermines affordability outcomes.
The Draft EIS does not analyze the impact of corridor upzoning on land speculation, nor does it evaluate whether speculative pricing may offset intended affordability gains.
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3. Displacement Risk and Concentration of Redevelopment Pressure
A substantial portion of Spokane's identified underutilized redevelopment capacity is located in historically lower-income neighborhoods, including West Central, East Central, Emerson Garfield and Hillyard. These neighborhoods contain a significant share of older housing stock, small commercial properties, and parcels zoned for higher density than currently built.
Corridor-focused upzoning and redevelopment incentives are therefore likely to concentrate redevelopment pressure in precisely those areas where land values remain comparatively lower and acquisition is more feasible. This creates a material risk that:
- Naturally occurring affordable housing (NOAH) will be demolished;
- Existing low-income renters will be displaced;
- Small neighborhood-serving businesses will be replaced by higher-cost redevelopment;
- Higher-income in-migrants will capture redevelopment benefits while existing residents bear disruption costs.
If higher-density redevelopment replaces older, lower-cost housing with substantially more expensive new construction, the net affordability impact may be neutral or even negative for existing residents.
The Draft EIS does not provide parcel-level demolition likelihood analysis, displacement modeling, or cumulative redevelopment pressure assessment in these neighborhoods. Nor does it evaluate whether concentrating growth in historically lower-income areas disproportionately shifts redevelopment burden onto vulnerable communities.
Housing equity requires that affordable housing opportunities and redevelopment capacity be equitably distributed across all neighborhoods in Spokane - not disproportionately located in neighborhoods that are already lower income.
The Final EIS should include:
- Neighborhood-level displacement risk analysis;
- Identification of naturally occurring affordable housing at risk of demolition;
- Comparative evaluation of redevelopment pressure across income geographies;
- Assessment of whether affordable housing production is equitably distributed citywide.
Conclusion Zoning capacity alone does not ensure feasible or affordable housing production. Speculative pricing, redevelopment land basis, displacement risk, and infrastructure concentration should be fully evaluated before selecting a preferred alternative.
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Draft EIS Comment City of Spokane Comprehensive Plan Update
Comment on Growth Strategy, Land Capacity Assumptions, and Market Feasibility The Draft Environmental Impact Statement (EIS) relies heavily on the assumption that Spokane's Centers & Corridors growth strategy - and its proposed intensification - will generate sufficient housing capacity to accommodate projected growth. However, both empirical growth patterns and the City's Land Capacity Analysis (LCA) raise substantial questions about whether this assumption is realistic.
1. The LCA Relies Primarily on Redevelopment
The 2025 Land Capacity Analysis identifies approximately 30,117 units of theoretical housing capacity. Of that total, approximately 10,344 units (34%) come from vacant land, while approximately 19,774 units (66%) depend on redevelopment of partially used or underutilized parcels, including corridor sites and the South Logan TOD subarea.
This means roughly two-thirds of projected housing capacity assumes redevelopment rather than development of vacant land. Redevelopment capacity is inherently less certain because it depends on willing sellers, financial feasibility, parcel assembly, demolition, environmental remediation, structured parking, infrastructure upgrades, and market rents sufficient to justify higher construction costs.
2. Comparative Regional Growth Raises Performance Questions
Over the last decade, the City of Spokane has grown at a slower rate than Spokane County overall and slower than Kootenai County, Idaho. A substantial share of regional housing growth has occurred in areas where development takes place primarily on vacant land rather than through corridor-based redevelopment. This raises a critical question: What evidence supports the assumption that increasing reliance on redevelopment will produce materially different results over the next 20 years?
3. Structural Cost Differential:
Redevelopment vs. Greenfield Development Redevelopment in corridor environments is materially more expensive than development on vacant land due to existing-use land acquisition costs, demolition, structured parking requirements, frontage improvements, utility relocation, tenant displacement mitigation, and greater financing risk. Affordable housing projects subject to prevailing wage and Evergreen standards often exceed $500 per square foot, increasing subsidy requirements.
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By contrast, development on vacant land or small-scale neighborhood infill typically avoids demolition costs, allows surface or no parking, and can be delivered at lower per-unit costs. The has been clearly demonstrated for example in the Highland Village neighborhood where Habitat and Community Frameworks, working with Greenstone have delivered over 100 affordable middle housing units with very modest subsidy.
4. Speculation and Land Pricing Effects
Upzoning limited corridor parcels without demonstrated redevelopment feasibility can increase land speculation, raise acquisition costs, encourage land banking, and reduce turnover. When land is priced based on theoretical mid-rise capacity but rents do not support those construction costs, projects stall. The EIS does not evaluate this risk.
5. Displacement and Equity Impacts
Much of the identified underutilized land capacity is located in historically lower-income neighborhoods such as West Central, East Central, and Hillyard. Because the LCA relies heavily on redevelopment in these areas, the strategy carries inherent displacement risk, including removal of naturally occurring affordable housing and increased land values. The EIS does not adequately analyze these risks.
Additional Comment: Compliance with HB 1220 - Planning for Housing in All Income Bands
HB 1220 requires jurisdictions to plan for and accommodate housing affordable to all economic segments of the community. The Draft EIS does not adequately evaluate whether a redevelopment-dominant growth strategy is consistent with these statutory requirements.
1. Redevelopment Raises Per-Unit Costs Across Income Bands
Because redevelopment sites are more expensive and complex to develop, higher per-unit costs reduce the number of affordable units that can be delivered with available subsidy funding. The EIS does not analyze how these cost factors affect production in the 0-50% AMI and 50-80% AMI income bands.
2. Moderate-Income Housing (80-120% AMI) Risks
Moderate-income housing often relies on lower-cost construction types such as duplexes, fourplexes, townhomes, and small-scale mixed-use infill. A corridor redevelopment strategy dependent on mid-rise construction may struggle to produce housing affordable to this income band without subsidy.
3. Geographic Equity and Distribution
If redevelopment capacity is concentrated in historically lower-income neighborhoods, the strategy risks reinforcing geographic concentration of affordable housing. The EIS should evaluate whether affordable housing opportunity is equitably distributed across neighborhoods.
4. Capacity vs. Deliverability
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The existence of theoretical redevelopment capacity does not guarantee production. Because redevelopment is more expensive and financially complex, a redevelopment-heavy strategy may reduce total deliverable units, increase reliance on limited public funding, and slow production rates.
Requested Additional Analysis To ensure compliance and realistic growth planning, the Final EIS should include:
1. A market feasibility analysis by income band.
2. Evaluation of subsidy capacity relative to redevelopment costs.
3. A geographic equity and displacement risk analysis.
4. Comparison of redevelopment-heavy growth versus broader neighborhood mixed-use growth.
Conclusion The Draft EIS assumes that redevelopment-based capacity will materialize at a scale not demonstrated over the past decade. Given that approximately two-thirds of projected housing capacity depends on redevelopment, additional analysis is necessary to ensure feasibility, equity, and compliance with housing planning requirements.
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Draft EIS Comment Inadequate Range of Alternatives - Failure to Evaluate a Broad Neighborhood Mixed Use Strategy
The Draft Environmental Impact Statement does not appear to evaluate a broadly distributed "Neighborhood Mixed Use" growth strategy as a reasonable alternative to continued reliance on a Centers and Corridors intensification models. All three alternatives analyzed retain the fundamental structural approach of concentrating increased density primarily within designated centers and arterial corridors. While the degree of intensification varies, the underlying development pattern remains corridor-focused.
The EIS does not analyze a materially different land use strategy in which large portions of existing Low Residential and Medium Residential zones are rezoned to a Neighborhood Mixed Use designation calibrated to middle housing scale. Such an approach would distribute growth across neighborhoods rather than concentrating redevelopment pressure along arterial corridors.
1. Requirement to Evaluate Reasonable Alternatives
Under SEPA, an EIS must evaluate a reasonable range of alternatives capable of achieving the proposal's objectives. A broadly distributed Neighborhood Mixed Use strategy could increase overall housing capacity, distribute growth geographically, reduce redevelopment pressure in lower-income corridors, lower per-unit construction costs, reduce land speculation, and improve walkability within neighborhoods.
Because such a strategy represents a fundamentally different land use pattern, it qualifies as a reasonable alternative that should be evaluated. Instead, the Draft EIS analyzes variations of the same corridor-centered framework.
2. Infrastructure and Transportation Implications
A corridor-intensification model assumes high concentrations of traffic along arterial streets, increased need for signalization and intersection upgrades, and greater localized utility capacity upgrades. By contrast, a distributed neighborhood mixed-use model would likely spread trip generation across a broader street network, reduce peak corridor congestion, and allow incremental infrastructure improvements. It has been documents that neighborhood based walkable mixed use can reduce vehicle trip by 30%. The development patterns over time lead to density that supports broader transit reach and service.
The EIS does not compare these infrastructure and transportation impact differences between a corridor-focused model and a broadly distributed mixed-use model.
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3. Housing Form and Market Feasibility Differences
Corridor-focused intensification often assumes mid-rise or podium construction types requiring higher land acquisition thresholds, structured parking, parcel assembly, and higher rents to achieve feasibility. A neighborhood mixed-use zoning framework calibrated to middle housing scale would allow incremental infill, participation by smaller developers, lower per-unit construction costs, and greater feasibility for moderate-income housing.
The Draft EIS does not evaluate whether a distributed middle-housing model could achieve housing targets with lower per-unit costs and greater market deliverability.
4. Equity and Geographic Distribution
Because identified underutilized land is disproportionately located in historically lower-income neighborhoods, a redevelopment-dependent corridor strategy may concentrate redevelopment pressure in those areas. A broadly distributed Neighborhood Mixed Use strategy would expand housing opportunity into higher-income neighborhoods and reduce concentration of affordability.
The EIS does not evaluate these geographic equity implications.
5. Land Speculation Risk
When growth capacity is concentrated in limited corridor areas, remaining vacant or underutilized parcels become speculative assets, and land pricing reflects theoretical buildout potential. A distributed rezoning approach would increase the supply of developable parcels across the city, potentially moderating speculative land pricing pressure. The Draft EIS does not analyze this dynamic.
6. Displacement Risk
When growth is concentrated in redevelopment areas there is a higher risk of displacement as existing affordable housing is demolished to facilitate the new higher intensity development. This is a very real risk in neighborhoods like West Central, East Central, Emerson Garfield and Hillyard where significant large single-family neighborhoods have been zoned for High Density residential development and classified in the LCA as "underutilized" land. The EIS does not analyze this risk.
Requested Revision The Final EIS should evaluate an alternative that rezones substantial portions of Low and Medium Residential areas and existing single family neighborhoods zoned for high density development to a calibrated Neighborhood Mixed Use designation, allows middle housing at scale citywide, reduces reliance on corridor mid-rise redevelopment, and compares infrastructure, displacement, feasibility, and equity outcomes against the corridor-centered alternatives.
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Without analysis of a materially different land use framework, the EIS does not provide decision-makers with a full understanding of reasonable growth strategies available to the City.
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Draft EIS Comment HB 1220 Compliance - Housing in All Income Bands
HB 1220 requires jurisdictions to plan for and accommodate housing affordable to all economic segments of the community. This includes identifying sufficient land capacity and adopting regulatory strategies that realistically enable housing production across all income bands. The Draft Environmental Impact Statement does not adequately evaluate whether a redevelopment-dominant growth strategy is consistent with these statutory requirements. The EIS identifies three plan alternatives:
Alternate 1: The current Comprehensive Plan, adopted in 2017, is based upon concentrating development in "center and corridors". Under Land Use Goals and Policies 3.3 the plan directed: "Much of the future growth should occur within concentrated areas in and around Neighborhood Centers, District Centers, Employment Centers and Regional Centers as designated on the land use map."
Alternate 2: This is called the "distributed and balanced" alternative but is follows the same concentrated development vision of Alternate
1. In the EIS summary is states "Alternate 2 adds greater job and housing intensity along frequent transit routes and applies the recommendations of the Centers and Corridors Study (2024). The study maintains the vision of concentrating development is existing commercial centers and along major arterials along with renaming the CC zones to mixed use nomenclature. This plan alternative does not envision a "neighborhood mixed use" environment where existing low and medium density areas would be rezoned to mix us to encourage middle housing and neighborhood scale commercial use expansion into all neighborhoods enhancing neighborhood walkability.
Alternate 3: The alternate is called City Center and Regional Hubs. This alternative is again a variation of the current centers and corridors plan and focuses development in the downtown core and the larger regional centers.
1. Redevelopment Raises Per-Unit Costs Across Income Bands
As demonstrated in the Land Capacity Analysis, approximately two-thirds of projected housing capacity depends on redevelopment of partially used or underutilized land. Redevelopment sites typically involve acquisition of improved property, demolition, structured parking, greater entitlement risk, and higher infrastructure costs. These factors materially increase per-unit development cost compared to housing constructed on vacant land or small-scale neighborhood infill. All three proposed alternatives focus concentrated growth in existing commercial centers and high traffic corridors. The are primarily redevelopment locations since they contain little "vacant" land.
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The dense concentrated housing in center and corridor locations will have construction costs of $300-$400 per square foot. For affordable housing projects receiving public funding, prevailing wage and Evergreen requirements further increase total development cost, often exceeding $500 per square foot. Higher per-unit costs reduce the number of affordable units that can be delivered with available subsidy funding.
2. Moderate-Income Housing (80-120% AMI) Risks
Moderate-income housing typically relies on construction types and land costs that allow projects to pencil without deep subsidy. Small-scale neighborhood mixed-use, duplexes, fourplexes, and townhomes can often be delivered at lower per-unit cost. By contrast, mid-rise corridor redevelopment with structured parking frequently requires rents above what moderate-income households can afford. A redevelopment-heavy strategy may therefore underperform in the moderate-income bands.
3. Geographic Equity and Distribution Requirements
State housing policy calls for avoiding concentrations of low-income housing and increasing access to affordable housing in areas where it is currently lacking. If redevelopment capacity is concentrated in historically lower-income neighborhoods, the strategy risks reinforcing geographic concentration of affordability rather than distributing housing opportunity equitably across all neighborhoods. All of the current alternative have concentrated development in the low income West Central, Emersons Garfield, East Central, and Hillyard neighborhoods.
4. Capacity vs. Deliverability The existence of theoretical redevelopment capacity does not guarantee production. Because redevelopment is more expensive and financially complex than neighborhood infill or development on vacant land, a redevelopment-heavy strategy may reduce total deliverable units, increase reliance on limited public funding, and slow production rates. The Final EIS should evaluate realistic production feasibility by income band under current and reasonably foreseeable market conditions.
Requested Additional Analysis
To ensure compliance with HB 1220, the Final EIS should include:
1. A market feasibility analysis by income band comparing redevelopment typologies to neighborhood mixed-use typologies.
2. Evaluation of subsidy capacity relative to redevelopment costs.
3. A geographic equity analysis showing likely distribution of affordable housing.
4. Comparison of redevelopment-heavy growth versus broader neighborhood mixed-use growth in meeting income-band targets.
Conclusion A growth strategy that relies primarily on corridor redevelopment rather than broader neighborhood mixed-use may increase per-unit housing costs, reduce deliverability in moderate and low-income bands, and risk geographic concentration of affordability.
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Additional analysis is necessary to ensure that the preferred alternative complies with HB 1220 and produces housing outcomes consistent with state policy.
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Comments to SCEO Related to the County Wide Planning Policies and Modification of the Urban Growth Boundary.docx Comments on Racial and Economic Inequality in Housing.pdf Residential Construction Costs by Unit Type.pdf Comments on City LCA.docx
Tirrell....These are documents submitted in support of the comments letter. Please consider these part of my subhmittal.
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Re: GMA Housing Policy Land Capacity Analysis
I have spent the past few month trying to understand the process we are going through as a community to plan for our growth and establish housing opportunity for the community over the next 20 years. The roadmap set out by State statute and the Department of Commerce is incredibly complicated and virtually impossible for the public to meaningly participate.
It is very easy to get caught in the complexity of land capacity analysis; definitions of "underdeveloped" and "under-utilized" property; infrastructure gap analysis; achievable density; and housing income bands while losing sight of the vision we have for our community.
The GMA process is about both where we will build our homes over the next 20 years and what kind of homes and neighborhoods we want for our families. The focus on the boundary and land capacity has resulted in an emphasis on density and little discussion on the kind of neighborhoods that allow families to thrive.
The Importance of Moderate Density Housing:
The guidance to the process from the Department of Commerce reflects their experience in providing affordable housing. They fund and support the development of large apartment projects. This reflects their experience and expertise. While this may be an efficient funding process it is a housing and community planning failure.
Strong and resilient neighborhoods need diversity housing types at moderate density and finely integrated with close proximity to services. The same is true if we intend to provide opportunity for all families. This means we have a vision to support neighborhoods that are economically diverse; include a wide range of housing products; are mixed use in character; and walkable.
The challenge is this requires a comprehensive change in development regulations. The walkable, housing diverse and mixed use neighborhoods you see in Kendall Yards and River District (Liberty Lake) were possible only because development code waivers and flexibility was provided in those jurisdictions. Here is the housing policy vision from Snohomish County which can serve as a template for Spokane County:
"The county and cities should implement policies that allow for the development of moderate density housing to help meet future housing needs, diversify the housing stock, and provide more affordable home ownership and rental opportunities. This approach should include code updates to ensure that zoning designations and allowed densities, housing capacity, and other restrictions do not preclude development of moderate density housing."
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The important elements of this policy vision are "moderate density"; "diversify the housing stock"; and "affordable home ownership and rental opportunities". From Commerce's perspective housing affordable to families making less that 80% of median income is only possible with MF rental apartments. This is not true. The private sector can built small attached or detached SF homes for a lower cost than Commerce funds large apartment projects. The problem is that development codes have minimum lot sizes and development dimensional standards (frontage, site coverage and setback requirement) that make the construction of small homes on small lot impossible. State law and some new development regulations are allowing 4-plex units and even 6-plex on a lot, but this serves primarily rental housing, not home ownership. Homeownership requires a platted lot to convey ownership (state law has effectively prohibited condominium units and other forms of common interest ownership). Affordable housing solutions go well beyond the "higher density" narrative.
The Lack of Land Inventory:
No single factor has driven up housing cost more that land prices. The lack of land that is "reasonably available for residential development" is critical in Spokane County and has led to rapidly increasing home prices. The median family home in Spokane County has risen dramatically in the past ten years, from under $200,0000 to over $400,000. Land prices in this same period have increased more than four-fold. Even in neighborhoods like West Central and East Central, lot prices alone are exceeding $200,000.
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The Land Capacity Analysis recommended by Commerce is incredibly complex and systemically over estimates land that is "reasonably available for development". Here is a breakdown of the process:
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Because of the complexity, jurisdictions have been short-cutting the process or eliminating steps. For example most jurisdiction are not completing an infrastructure "gap analysis" and are just assuming that all land can be serviced. Jurisdictions are not properly setting aside land for future roadways and public facilities like parks, schools and open space. Expansive definitions of "vacant Land", "underdeveloped Land" and "under-utilized land" are being used that significantly overestimate the inventory of land that can be developed. If the region had a 20 year supply of land capable you would not have seen the rapid and dramatic increase in land and housing prices we are experiencing. There is a significance difference in the "theoretical" land inventory derived from the LCA process being used by local jurisdictions and actual market conditions.
The Consequence of Inadequate Housing and Land Inventory
The primary purpose of the Growth management Act and the imposition of a Urban Growth Boundary Is to limit "urban sprawl" and focus growth where infrastructure is currently available. In Spokane County, which shares a metropolitan area with Kootenai County, limiting growth within the restrictive GMA boundary has resulted in housing and commercial growth "leaking" to north Idaho. The consequence of a restriction on land inventory available for urban development in Spokane County is the shifting of growth to Kootenai County. A shift of 500 residential units a year (the actual leakage is likely much greater) from Spokane County to Kootenai County has very negative fiscal and environmental impacts.
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Comments to SCEO Related to the County Wide Planning Policies and Modification of the Urban Growth Boundary
Over the past 12 months we have provided a series of comments and documentation on important issues related to providing for adequate housing for our population and housing equity. The attached are some of the documents previously submitted.
As this process moves from policy guidance to the updating of comprehensive plans by each jurisdiction, we want to summarize the issue we think most important:
1. While family size is decreasing due to a declining birth rate, household size is increasing. You will find a census summary that documents this. The increasing household size is a result of housing
cost so high that persons from different household are sharing housing.
This reflects the desperate shortage and high cost of housing because of a lack of housing inventory.
2. Home ownership rates are declining, and this is especially true for racial minorities. Kootenai County is not seeing the same decline in homeownership being seem in Spokane.
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3. At the staff level (both local and state) a consensus has developed that the only way to providing housing for middle- and low-income families is to build apartments and rental housing. The solution they offer to meeting housing demand is not providing more land for housing but increasing the density permitted on existing available land. This ignores several realities of new home development. These include the following:
a. The cost of constructing housing escalates rapidly with the mass and scale of the building. SF homes constructed under the IRC
cost about half (cost per SF) of multistory apartment buildings built under the UBC. This is due to a wide range of access, fire safety, energy
code and stormwater standards that are required under the UBC that are not required under the IRC.
b. Significant opportunity to increase density exists in building SF homes if codes would permit the construction of "small homes
on small lots". Most local codes prevent or make the construction of small detached and attached SF homes very difficult and costly. This is
the result of zoning standards like minimum lot sizes, street frontage requirements and restrictive site coverage standards. If SF homes were
permitted on small lots, you can achieve net densities over 18 DU/acres. The reality is that the urban spawl which GMA is trying to reverse is all that is permitted by most codes with large minimum lot
sizes.
c. The emphasis on building more apartments is at the expense of homeownership and housing equity of low-income families and racial minorities. Middle- and low-income families are given no
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housing choice but living in large apartment complexes that are not integrated into neighborhoods when affordable homeownership should and can be an option. This perpetuates the historic inequality in housing opportunity and in the case of our region is simply driving housing to Kootenai County with a significant fiscal impact of Spokane County jurisdictions. (We have documented the construction cost differential, the shift in building permits to Kootenai County and the fiscal impact in the attached documents).
This is an issue that needs to be addressed by the Growth Management Steering Committee and the Board of County Commissioners.
4. PTAC has recommended a procedure for the allocation of housing units that is not based on population but what they call "housing growth". This has not been acted on by either SCEO or the Board of County Commissioners and results in a serious misallocation of housing within the County.
The PTAC recommendation, when compared to a population-based allocation, increases the housing allocated to the City of Spokane and rural Spokane County, and decreases the allocation to Unincorporated Spokane County and most of the smaller cities. The details of the PTAC recommendation and the shift in housing allocation is in our documents. This policy recommendation should be rejected.
As we have documented, the city of Spokane is the local jurisdiction least capable of providing new housing and doubling the housing allocation to rural Spokane County is contrary to the County wide Planning Policies the SCEO has already adopted.
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5. The City of Spokane has grossly overestimated the amount of land reasonably available for residential development in the LCA submitted. The city has ignored many of the requirements outlined in the Burke Consulting (Commerce contractor) on the process to be used in the preparation of an LCA. The deficiencies have been documented in the material we have submitted for the record.
This is important since land cost is the principal driver of higher housing costs and the current lack of land inventory in Spokane is driving housing to outlying areas and Kootenai County. The City of Spokane in 2025 has the lowest number of single-family home construction permits in over 15 years with a mere 120 SF permits issued thru the end of November (Documentation of provided in our submittals).
The lack of housing construction in the City of Spokane has been the primary cause of increasing regional housing costs. We recommend that the County reject the City of Spokane LCA.
6. The misguided emphasis on apartments as the only way to provide affordable housing and the lack of reasonably available land for residential development is limiting housing options for low- and middle-income family. Maybe more importantly it is diving residential development to Kootenai County which subverts the purpose of an Urban Growth Boundary. This impact is well documented in the submittals we have made.
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July 22, 2025
City of Spokane Plan Commission Racially Disparate Impact on Housing
Ezra Klein and Derek Thompson's recent book Abundance documents the national housing crisis that has been decades in the making. After years of inadequate construction and policy inaction, we now face a severe shortage of affordable housing in Spokane. Our city has failed to build enough housing to keep pace with a growing population, leading to skyrocketing prices and rents. For middle- and low-income families, owning or renting a home is increasingly out of reach. The are many regulatory policies, engineering standards, and development code provisions that have in the past and continue to discriminate against lower income and racial minority populations.
The central question we must ask is: How can we foster a political and cultural environment where housing is built at a scale and pace that ensures affordability and abundance for all? Unfortunately, we have restricted the land available for new homes and there's a prevailing political belief that the only way to achieve affordability is by constructing more apartment complexes. However, this approach overlooks a key reality: as the mass and scale of buildings increase, so too do construction costs. Large apartment buildings, especially those aimed at middle- and low-income families, are not only costly to construct but often perpetuate inequality and restrict housing options. The assumption that apartments are the answer to housing affordability is misguided and must be challenged.
The real solution to housing affordability and equality - and the creation of livable, connected neighborhoods - lies in developing "middle housing." These are small homes, either attached or detached, on small lots, such as townhomes or small multifamily buildings (generally fewer than 12 units). Unlike larger apartment complexes, middle housing can be integrated into neighborhoods, preserving the character of communities while increasing housing stock and home ownership. While this approach sounds simple, it faces significant hurdles. Current zoning, and building regulations make it easier to develop large apartment complexes than to build small, affordable homes on smaller lots. This regulatory imbalance must be addressed. Here are a few critical areas:
1. Land Capacity:
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If there is insufficient land to build new homes prices will escalate rapidly. In 2021 the legislature passed HB1021 which required that each jurisdiction prepare a Land Capacity Analysis (LCA) to ensure that they have capacity to accommodate 20 years residential growth based upon population forecasts. The Spokane LCA claims to have land capacity far in excess of there required for 20 years growth, while the actual market conditions and land available for development tell a very different story. The burden of high land prices falls on racial minorities and low income families who's incomes do not keep pace with escalating land prices. Attached is a document that outlines the ways in which the Spokane LCA has overestimated land available for residential development.
2. Zoning: Spokane has zoned numerous low income neighborhoods (parts of West Central, East Central, Emerson Garfield, Logan and Hillyard) with fully developed single family neighborhood for high density MF development. Under GMA single family home neighborhoods with multifamily zoning are designated as "underutilized land" available for redevelopment. This is a policy that encourages the redevelopment of single family home neighborhoods and the displacement of existing residents who are primarily low income. This policy creates economic and racial segregation and inequity in housing.
3. Home Ownership:
A regulatory and policy consensus has developed around the idea that housing affordability can only be developed around building more large apartments. This ignores the reality that housing construction costs increase rapidly with building mass and scale. See the attached documentation. For low income families small home on small lots (including SF attached and townhomes) are the most affordable option. Housing for all income bands should be affordable and located in connected neighborhoods. Restraining low income housing to apartments simply sustains housing inequality in our communities.
4. Development Code Standards:
Dimensional standards (lot size, site coverage, building height, street frontage requirements) and complex long plat, short plat and unit lot subdivision requirements make the development of small home and middle housing very difficult and expensive. The very "middle housing" that we are trying to encourage is the most regulated and difficult to develop. These standards discriminate against small homes and small lots creating economic and racial inequality.
5. Engineering Standards:
There are numerous engineering standards and fee structures that favor large homes on large lots at the expense of small homes. This includes stormwater review requirements, GFC fees, and Traffic impact fees. Fees are generally "one size fits all" rather than reflecting the lower service demand from smaller units. For example a small 1000SF home might pay the same GFC fee and traffic mitigation fee as a 3000SF home. The inequality in engineering standards and fees is systemic. Recent stormwater requirements place a significant burden on lower income home neighborhoods while higher income neighborhoods are allowed to meet significantly lower standards.
Addressing the significant regulatory imbalance that limits housing affordability for lower income families and racial minorities is very complex. It must begin with active listening to the low income families with few housing opportunities and those small market rate and nonprofit housing providers who struggle to meet this need.
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Affordable Housing Options Small Homes on Small Lots and Townhomes: The Preferred Option for Affordable Housing in Low Income Bands
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Housing for all income bands should be be affordable, resilient, and located in connected neighborhoods and communities.
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Misconception: Apartments as the Preferred Housing Option for Low Income Bands Apartments cost more to construct
Apartments have very long approval and construction lead times
Apartments are generally located in commercial high traffic and high land cost corridors
Apartment do not integrate finely into existing neighborhoods
Apartments sustain the housing inequality in our communities
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Variable Housing Construction Costs Development costs increase as mass, scale and complexity of the structure increases - More complex construction systems
- Increased life safety and energy code requirement
- Fewer siting options and higher land costs
- More complex and fewer financing options
- Much longer entitlement and construction time frames
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The Average Cost of Commerce Funded Apartment Projects: $475,000 per unit
Department of Commerce Housing Trust Fund Projects 2024
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Small Homes Home on Small Lots Provide Best Option for Affordable Housing Small homes and townhomes are the lowest cost housing option
On small lots single family homes can achieve MF density
Small homes have short construction lead times and are easier to finance than apartments
Small homes and townhomes easily integrate into existing neighborhoods
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Clustered and Attached Single Family Homes Achieve Net Density Similar to Apartment Projects
- SF Detached on 3000sf lots at 15 units/acre
- SF Attached on 2500sf lots at 18 units/acre
- Townhomes on 1500sf lots at 29 units/acre
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Habitat Cottage Homes $280,000 Highland Village in Airway Heights 2025
- One and Two story Cottage Homes 1200-1400sf
- Lot Size 3000 SF - Construction Costs $175/sf - Total units developments costs about $280,000 per unit
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1. Single Family Detached and Attached (three or fewer units):
- Construction Cost: $175 SF - Net Density Range: 12-18 DU/acre
Construction under International Residential Code (IRC). Simplified building permit review. Plans can be pre-approved. Plans do not require licensed architect. No civil engineering or stormwater review required. Limited or no parking requirements, can take advantage of on street parking. Units can be finely integrated into most neighborhoods with SF or MF zoning providing greater choice and opportunity to families.
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2. Attached Single Family, Townhomes, Small
MF (four or more units):
- Construction Cost: $225/SF - Net Density Range: 12-22 DU/acre
Four or more units are treated as commercial construction and are governed by the Uniform Building Code (UBC). Building plans must be submitted by licensed architect, civil engineering plans required, stormwater management plan required, units must be sprinkled, low frequency fire alarms are required, more stringent energy code and design review requirements. Generally can be integrated into most neighborhoods.
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3. MF Construction Up to 4 Stories with Surface Parking:
- Construction Cost: $300/SF - Net Density: 30-50 DU/acre
Construction is governed by UBC. Projects tend to be larger 40 or more units. Require detailed civil engineering plans for utilities, access and parking. Detailed stormwater engineering plans. Geotechnical soils analysis. SEPA review and traffic impact analysis. Elevators, hallways and secondary stairway systems. Development of detailed fire protection system and fire wall protections. More complicated appraisal and construction financing costs. Significantly longer development timelines and construction phase interest expense. Sites limited to MF zones with arterial access and not integrated well into neighborhoods.
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4. Multi Family Four or more Stories with Structured
Parking:
- Construction Cost: $400/ SF - Net Density Range: 30-50 DU/acre
Construction is governed by UBC. Projects tend to be larger 100 units or more. Require detailed civil engineering plans for utilities, access and parking. Detailed stormwater engineering plans. Geotechnical soils analysis. SEPA review and traffic impact analysis. Elevators, hallways and secondary stairway systems. Development of detailed fire protection systems and fire wall protections. More complicated appraisal and construction financing costs. Significantly longer development timelines and construction phase interest expense. Limited to high density MF zones in high land cost areas.
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Comments on City of Spokane Land Capacity Analysis
The Land Capacity Analysis submitted by the City of Spokane February 2025 is fundamentally flawed and does not reflect an inventory of land reasonably available for housing development during the 20-year study period. Rather the City of Spokane has created an inventory that grossly overestimates land available for housing development. The purpose of the LCA is to identify land likely to be available for residential development during the study period. Rather the city analysis included all land that could theoretically be developed as residential, even when such lands are not likely to be available for development during the study period.
A careful review of the City Land Capacity Analysis reflects the following:
1. Infrastructure Gap Analysis: The city did not identify lands subject to infrastructure gaps that will prevent the assigned densities from being achieved or will delay development during the planning period. RCW 36.70A.215 requires
jurisdictions consider the lack of transportation and utility infrastructure in the land capacity analysis.
2. Vacant Properties: The city failed to consider where adjacent properties are owned by the same party the Assessor commonly assigns the full assessed value to only
one parcel when in fact improvements are located on two or more adjacent parcels owned in common. A significant number of parcels have been identified as "vacant" when they in fact have substantial improvements and improved value.
3. Partially Developed Properties: The city has identified many properties as partially developed where they are not in a current residential use. This includes
churches, cemeteries, schools and businesses where the zoning might permit residential use, but the current use is not residential.
The city provided no mechanism to filter out properties where future residential use was unlikely.
4. Underutilized Land: The category includes parcels improved with single family homes but with zoning that permits higher intensity use. The city provided no
analysis to assure that there was a strong possibility that the property would be redeveloped to a more intensive use in the planning period. The city has many
inner-city SF neighborhood that are zoned for a more intensive use (West Central, Emerson Garfield, Hillyard and East Central) and there is no history of any
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significant redevelopment in these neighborhoods. Our survey of 800 homes in West Central zoned HDR showed only 3 that redeveloped in the past 20 years. This category includes almost 30% of the city estimated housing capacity.
5. Critical Lands: The city has not properly evaluated wetlands, floodplains, and geologic constraints that will limit development in the future. There are many
environmental constraints that do not make development illegal but will significantly reduce the likelihood and density of development.
6. Current Public Use Lands: The city did not exclude lands owned by Federal, State, or local municipality or government that are not likely to be available for development in the planning period.
7. Future Road ROW and Utility Land: The city used a factor of 15% only on larger parcels as a reduction in land available for development. This grossly
underestimates the land required for future development. Our analysis of over 30 projects shows the road and utility requirements to be in the range of 20-35%. ROW
requirements for small projects are significant.
8. Future Public Facilities: The City made no attempt to identify the need for future public facility needs (open space, parks, schools, churches, fire stations, libraries
and so forth) that will be required the planned population increase of 100,000 persons and make a deduction of land inventory for such uses.