Eileen Kazura - Emerson-Garfield Neighborhood Council
Feb 18, 2026
Neighborhood Groups
[PDF page 1 of 2]
Hello,
On behalf of the Emerson-Garfield Neighborhood Council, I am submitting the below questions and concerns regarding the PlanSpokane 2046 Draft EIS. At the February 11, 2206 EGNC meeting, the Council voted to submit these questions as a formal comment, raising concerns about the proposed growth alternatives and the potential impacts on low income neighbors and infill development in our neighborhood.
Comments/Questions
1. The draft EIS uses the neighborhood council boundaries but gives no role or voice to the councils or the Community Assembly, although these are the city's constituted bodies for residents' expression regarding governance issues. It does mention reliance on Neighborhood Action Plans, but many of those are either outdated and in some cases are non-existent.
2. Both the Plan Commission and various community members have concerns regarding both Alternatives 2 and 3. What is the mechanism for modifying these alternatives and coming to consensus on a single, final map?
3. When looking at Alternatives 2 and 3, it is important to consider the number and types of additional housing units that are required in the next 20 years. Several 2025 studies, including the Land Capacity Analysis and Accommodating Affordable Housing, point to the fact that the city already has sufficient or surplus housing for all income types except 0-80% AMI.
In that category, Spokane has a 4,400-unit shortage. In 80-120% AMI, there is a 6,000-unit excess. In 120% AMI there is a 9,000-unit excess. The only housing needed until 2046 is in the lower income categories. How might this fact affect land use, permitting, demolition, incentives, etc.?
The EIS seems to be written with the idea that building by private individuals will continue unabated whether need has been established. It seems that the idea is that city residents must accept all additional construction with the idea that some of the housing will accrue to residents in the 0-80% AMI category. However, no mechanisms to accomplish this are proposed in the draft EIS or elsewhere.
[PDF page 2 of 2 begins within the following paragraph.]
4. The role of demolition of housing stock is a key issue in both alternatives but is not mentioned early in the draft statement. Demolition of current stock comes with many issues, including the potential displacement of those with lower incomes, the reduction of home ownership in favor of renting, and the disruption of neighborhoods, especially those near corridors with empty lots on which owners do not wish to build housing. However, as currently written the document suggests that none of these issues is a problem. The city seems to be relying on action alternatives that would address affordability in the marketplace, and the City's new policies and codes addressing anti-displacement measures. There is no proof that such will take place or be effective.
5. The projected impact of the contemplated exemptions is extensive. For instance, Exh. 6 p. 612 shows how an infill exemption extending the 'corridor' definition to one-half mile on each side of the corridor would affect some neighborhoods negatively. The 'Exemption' document (originally separate but now the final appendix of the EIS) even calls for the entire city to be designated a 'corridor'.
6. Given that the draft envisions that no alternative will result in the increased use of transit and only a tiny increase in use of active transportation, is the City doing enough to reduce the use of personal vehicles that is the source of a large proportion of pollutants? Where will the increased number of vehicles correlated to the increased population be parked?
7. The section labelled "Earth, Water Quality, and Water Resources" does not contain a single reference to the aquifer that is vital to our region. Why? How will the Plan, in this section and elsewhere, address the current numerous and profound attempts to reduce and eliminate environmental considerations, incentives, and regulations at the federal level?
8. Since there is provision for course correction during the 20-year period, it is essential that we use today as a starting point, when considering population, current housing stock, family size, the state of the environment, home ownership, displacement, etc. The statement should seek to lessen environmental impacts, while improving home ownership and minimizing displacement.
Summary
In sum, the effect of infill exemptions and Plans 2 and 3 will open neighborhoods to exploitive and somewhat unregulated development where retail, restaurants and apartment buildings are placed in the midst of single-family home communities, often with no parking requirements and no room for trees. Many resident commentators on the draft comprehensive plan indicate that there is no need for an either/or approach to these options. Rather the city might adopt the best from each of them to achieve the goals of protecting neighborhoods, increasing environmental integrity and reaching environmental goals (such as air quality through the protection of trees) and provision of affordable housing. But clearly, as offered, none of these options are optimal. As written, neither Options 2 or 3 protect neighbors or neighborhoods for the reasons mentioned.
Please do not hesitate to reach out with any questions.
Eileen Kazura - Emerson-Garfield Neighborhood Council
Feb 18, 2026
Neighborhood Groups
[PDF page 1 of 2]
Hello,
On behalf of the Emerson-Garfield Neighborhood Council, I am submitting the below questions and concerns regarding the PlanSpokane 2046 Draft EIS. At the February 11, 2206 EGNC meeting, the Council voted to submit these questions as a formal comment, raising concerns about the proposed growth alternatives and the potential impacts on low income neighbors and infill development in our neighborhood.
Comments/Questions
1. The draft EIS uses the neighborhood council boundaries but gives no role or voice to the councils or the Community Assembly, although these are the city's constituted bodies for residents' expression regarding governance issues. It does mention reliance on Neighborhood Action Plans, but many of those are either outdated and in some cases are non-existent.
2. Both the Plan Commission and various community members have concerns regarding both Alternatives 2 and 3. What is the mechanism for modifying these alternatives and coming to consensus on a single, final map?
3. When looking at Alternatives 2 and 3, it is important to consider the number and types of additional housing units that are required in the next 20 years. Several 2025 studies, including the Land Capacity Analysis and Accommodating Affordable Housing, point to the fact that the city already has sufficient or surplus housing for all income types except 0-80% AMI.
In that category, Spokane has a 4,400-unit shortage. In 80-120% AMI, there is a 6,000-unit excess. In 120% AMI there is a 9,000-unit excess. The only housing needed until 2046 is in the lower income categories. How might this fact affect land use, permitting, demolition, incentives, etc.?
The EIS seems to be written with the idea that building by private individuals will continue unabated whether need has been established. It seems that the idea is that city residents must accept all additional construction with the idea that some of the housing will accrue to residents in the 0-80% AMI category. However, no mechanisms to accomplish this are proposed in the draft EIS or elsewhere.
[PDF page 2 of 2 begins within the following paragraph.]
4. The role of demolition of housing stock is a key issue in both alternatives but is not mentioned early in the draft statement. Demolition of current stock comes with many issues, including the potential displacement of those with lower incomes, the reduction of home ownership in favor of renting, and the disruption of neighborhoods, especially those near corridors with empty lots on which owners do not wish to build housing. However, as currently written the document suggests that none of these issues is a problem. The city seems to be relying on action alternatives that would address affordability in the marketplace, and the City's new policies and codes addressing anti-displacement measures. There is no proof that such will take place or be effective.
5. The projected impact of the contemplated exemptions is extensive. For instance, Exh. 6 p. 612 shows how an infill exemption extending the 'corridor' definition to one-half mile on each side of the corridor would affect some neighborhoods negatively. The 'Exemption' document (originally separate but now the final appendix of the EIS) even calls for the entire city to be designated a 'corridor'.
6. Given that the draft envisions that no alternative will result in the increased use of transit and only a tiny increase in use of active transportation, is the City doing enough to reduce the use of personal vehicles that is the source of a large proportion of pollutants? Where will the increased number of vehicles correlated to the increased population be parked?
7. The section labelled "Earth, Water Quality, and Water Resources" does not contain a single reference to the aquifer that is vital to our region. Why? How will the Plan, in this section and elsewhere, address the current numerous and profound attempts to reduce and eliminate environmental considerations, incentives, and regulations at the federal level?
8. Since there is provision for course correction during the 20-year period, it is essential that we use today as a starting point, when considering population, current housing stock, family size, the state of the environment, home ownership, displacement, etc. The statement should seek to lessen environmental impacts, while improving home ownership and minimizing displacement.
Summary
In sum, the effect of infill exemptions and Plans 2 and 3 will open neighborhoods to exploitive and somewhat unregulated development where retail, restaurants and apartment buildings are placed in the midst of single-family home communities, often with no parking requirements and no room for trees. Many resident commentators on the draft comprehensive plan indicate that there is no need for an either/or approach to these options. Rather the city might adopt the best from each of them to achieve the goals of protecting neighborhoods, increasing environmental integrity and reaching environmental goals (such as air quality through the protection of trees) and provision of affordable housing. But clearly, as offered, none of these options are optimal. As written, neither Options 2 or 3 protect neighbors or neighborhoods for the reasons mentioned.
Please do not hesitate to reach out with any questions.