CITY OF SPOKANE Draft EIS and Infill Exemption Comments
Date: 3/4/2026
To: Tirrell Black, Assistant Planning Director
From: Integrated Capital Management
CC: ICM file
Subject: PlanSpokane 2046 Draft EIS and Infill Exemption Comments
Attachments: Exhibit 7, DEIS
SUMMARY: This document provides utility and transportation comments on the proposed Exemptions to Promote Infill Development and Housing. In the Programmatic Draft Environmental Impact Statement (DEIS) issued December 18, 2025, conducted in conjunction with the City’s mandated periodic update to the Comprehensive Plan to be completed by December 31, 2026, the City has examined both raising the Categorical Exemptions to SEPA Citywide, as well as a more targeted Infill Exemption.
ICM is supportive of changes to the Categorical Exemption levels subject to code revision recommendations and future considerations, studies or analysis detailed below.
ICM is supportive of the Phase 1 Infill Exemptions Area moving forward but has concerns with the proposal for Phase 2 area at this time. Many of these concerns can be addressed in the city’s planned development code update beginning in Q2 2026. ICM looks forward to participating in that process.
Categorical Exemptions - Initial Recommendations: If there is desire to streamline development within the Phase 2 area ICM staff would be supportive of increasing the following thresholds allowed by WAC 197 -11-800.
• Up to 30 SF units, including those under 1500 square feet. There is no difference in trip generation with smaller SF homes in areas with no alternatives to driving.
• Up to 50 MF units. This would be consistent with the 30 SF units as they generate a similar number of PM peak trips. Also, significant water amenities such as pools or water parks should not be included within the exemption. The selected maximum flow rate exemption should be decided by the City’s Wastewater and Water Engineers.
• Up to 30k for office, commercial, service and storage. This size of commercial building water and sewer demands can range greatly but are typically within the range of 50 MF Units wastewater and water utility demands. Exception should be made for commercial buildings with high water and sewer demand facilities. Examples include breweries, carwashes, marijuana growing or processing facilities, pharmaceutical facilities or data centers. The selected maximum flow rate exemption should be decided by the City’s Wastewater and Water Engineers.
• Up to 90 for parking stalls
• Up to 1000 cubic yards for grading
[PDF page 3 of 5]
CITY OF SPOKANE Draft EIS and Infill Exemption Comments
Infill Exemption, Phase 2 area recommendations, focusing on future Unified Development Code changes:
Note: Infrastructure capacity needs and challenges vary by location; ICM Staff would be supportive of evaluating individual TAZs or a group of TAZ’s (within the Phase 2 boundary) as potential add-ons to the Phase 1 areas subject to considerations noted in sections below.
In order to consider the additional SEPA exemption Phase 2 area, additional consultation with ICM, Water, Wastewater and Street Departments is required and additional capacity analysis may be warranted. Necessary code modifications, City Actions and Additional Considerations and Limitations that should be addressed prior to expansion of the SEPA exemptions for Phase 2 areas are summarized below.
Modifications to the Spokane Municipal Code requiring developers to do the following:
• Offsite sidewalk and roadway improvements under certain conditions to access transit, schools, bus stops, parks and commercial sites.
• Offsite crosswalk enhancements (signing, striping, illumination, refuge islands, RRFBs, etc.) when the development will cause an increase in pedestrian need to cross arterials.
• Code requirement for traffic signals for locations not covered by concurrency, such as an entrance to a large shopping center or apartment complex.
• Other traffic safety improvements when the need is identified through a traffic impact analysis, including but not limited to traffic calming devices, sight distance mitigations, installation of curbing to restrict access, relocation or consolidation of driveways, dedication of right-of-way, modifications to signal phasing, and construction of turn pockets.
Infill Exemption, Phase 2 Area, City Actions which are needed prior to adopting Infill Exemption in the Phase 2 area:
• Analysis of the proposed use and density for the Phase 2 area using the SRTC Model, along with identification of transportation and wet utility mitigation(s) to address the environmental impact, per the requirements of RCW 43.21C.229(2) or (3).
• Adoption of additional transportation long-term funding source(s) such as a Tax Increment Financing District, Local Improvement District or similar program to provide match for the Transportation Impact Fee Program. For utilities, a funding source could be a ULID (Utility Local Improvement District) or other mechanism.
• An update to the City’s Design Standards and modifications to the Spokane Municipal Code for all wet utilities.
• Development of a funding plan including a commitment from state sources to support projects parallel to US 2 and US 195.
• Development of a funding plan or approach for upsizing requirements for major wet utility facilities including interceptor mains, transmission mains, storages, siphons, lift stations or booster stations, etc.
[PDF page 4 of 5]
CITY OF SPOKANE Draft EIS and Infill Exemption Comments
Additional Conditions and Limitations
Examples of additional conditions and potential limitations that should be considered in evaluating expansion of Phase 2 SEPA exemptions include but are not limited to:
Transportation:
• Availability of transit service within ½ mile.
• Construction of alternative and parallel routes to State highways to provide connectivity.
Stormwater:
• Identify locations within special stormwater or drainage districts such as Moran Prairie or Five Mile Prairie or areas of challenging treatment and drainage options such as the West Plains.
Wastewater:
• Identify locations that will be contributing to regional lift station(s).
• Consideration goals, status and progress of objectives of the Septic Elimination Program.
Water:
• Consideration of additional infrastructure demands created by water contamination.
• Capacity challenges related to future intertie agreements .
[PDF page 5 of 5]
CITY OF SPOKANE Draft EIS and Infill Exemption Comments
Kevin Picanco - City of Spokane Integrated Capital Management
Mar 5, 2026
Government / Technical
[PDF page 1 of 5]
Please see attached comments from ICM.
Thanks,
Kevin Picanco, P.E. | Director – Integrated Capital Management
City of Spokane
[Professional contact details omitted from the reading text.]
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ATTACHMENT / ADDITIONAL PAGES
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[PDF page 2 of 5]
CITY OF SPOKANE Draft EIS and Infill Exemption Comments
Date: 3/4/2026
To: Tirrell Black, Assistant Planning Director
From: Integrated Capital Management
CC: ICM file
Subject: PlanSpokane 2046 Draft EIS and Infill Exemption Comments
Attachments: Exhibit 7, DEIS
SUMMARY: This document provides utility and transportation comments on the proposed Exemptions to Promote Infill Development and Housing. In the Programmatic Draft Environmental Impact Statement (DEIS) issued December 18, 2025, conducted in conjunction with the City’s mandated periodic update to the Comprehensive Plan to be completed by December 31, 2026, the City has examined both raising the Categorical Exemptions to SEPA Citywide, as well as a more targeted Infill Exemption.
ICM is supportive of changes to the Categorical Exemption levels subject to code revision recommendations and future considerations, studies or analysis detailed below.
ICM is supportive of the Phase 1 Infill Exemptions Area moving forward but has concerns with the proposal for Phase 2 area at this time. Many of these concerns can be addressed in the city’s planned development code update beginning in Q2 2026. ICM looks forward to participating in that process.
Categorical Exemptions - Initial Recommendations: If there is desire to streamline development within the Phase 2 area ICM staff would be supportive of increasing the following thresholds allowed by WAC 197 -11-800.
• Up to 30 SF units, including those under 1500 square feet. There is no difference in trip generation with smaller SF homes in areas with no alternatives to driving.
• Up to 50 MF units. This would be consistent with the 30 SF units as they generate a similar number of PM peak trips. Also, significant water amenities such as pools or water parks should not be included within the exemption. The selected maximum flow rate exemption should be decided by the City’s Wastewater and Water Engineers.
• Up to 30k for office, commercial, service and storage. This size of commercial building water and sewer demands can range greatly but are typically within the range of 50 MF Units wastewater and water utility demands. Exception should be made for commercial buildings with high water and sewer demand facilities. Examples include breweries, carwashes, marijuana growing or processing facilities, pharmaceutical facilities or data centers. The selected maximum flow rate exemption should be decided by the City’s Wastewater and Water Engineers.
• Up to 90 for parking stalls
• Up to 1000 cubic yards for grading
[PDF page 3 of 5]
CITY OF SPOKANE Draft EIS and Infill Exemption Comments
Infill Exemption, Phase 2 area recommendations, focusing on future Unified Development Code changes:
Note: Infrastructure capacity needs and challenges vary by location; ICM Staff would be supportive of evaluating individual TAZs or a group of TAZ’s (within the Phase 2 boundary) as potential add-ons to the Phase 1 areas subject to considerations noted in sections below.
In order to consider the additional SEPA exemption Phase 2 area, additional consultation with ICM, Water, Wastewater and Street Departments is required and additional capacity analysis may be warranted. Necessary code modifications, City Actions and Additional Considerations and Limitations that should be addressed prior to expansion of the SEPA exemptions for Phase 2 areas are summarized below.
Modifications to the Spokane Municipal Code requiring developers to do the following:
• Offsite sidewalk and roadway improvements under certain conditions to access transit, schools, bus stops, parks and commercial sites.
• Offsite crosswalk enhancements (signing, striping, illumination, refuge islands, RRFBs, etc.) when the development will cause an increase in pedestrian need to cross arterials.
• Code requirement for traffic signals for locations not covered by concurrency, such as an entrance to a large shopping center or apartment complex.
• Other traffic safety improvements when the need is identified through a traffic impact analysis, including but not limited to traffic calming devices, sight distance mitigations, installation of curbing to restrict access, relocation or consolidation of driveways, dedication of right-of-way, modifications to signal phasing, and construction of turn pockets.
Infill Exemption, Phase 2 Area, City Actions which are needed prior to adopting Infill Exemption in the Phase 2 area:
• Analysis of the proposed use and density for the Phase 2 area using the SRTC Model, along with identification of transportation and wet utility mitigation(s) to address the environmental impact, per the requirements of RCW 43.21C.229(2) or (3).
• Adoption of additional transportation long-term funding source(s) such as a Tax Increment Financing District, Local Improvement District or similar program to provide match for the Transportation Impact Fee Program. For utilities, a funding source could be a ULID (Utility Local Improvement District) or other mechanism.
• An update to the City’s Design Standards and modifications to the Spokane Municipal Code for all wet utilities.
• Development of a funding plan including a commitment from state sources to support projects parallel to US 2 and US 195.
• Development of a funding plan or approach for upsizing requirements for major wet utility facilities including interceptor mains, transmission mains, storages, siphons, lift stations or booster stations, etc.
[PDF page 4 of 5]
CITY OF SPOKANE Draft EIS and Infill Exemption Comments
Additional Conditions and Limitations
Examples of additional conditions and potential limitations that should be considered in evaluating expansion of Phase 2 SEPA exemptions include but are not limited to:
Transportation:
• Availability of transit service within ½ mile.
• Construction of alternative and parallel routes to State highways to provide connectivity.
Stormwater:
• Identify locations within special stormwater or drainage districts such as Moran Prairie or Five Mile Prairie or areas of challenging treatment and drainage options such as the West Plains.
Wastewater:
• Identify locations that will be contributing to regional lift station(s).
• Consideration goals, status and progress of objectives of the Septic Elimination Program.
Water:
• Consideration of additional infrastructure demands created by water contamination.
• Capacity challenges related to future intertie agreements .
[PDF page 5 of 5]
CITY OF SPOKANE Draft EIS and Infill Exemption Comments
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