To: Tirrell Black, City of Spokane Planning Services
Subject: Comments on City of Spokane Comprehensive Plan Update 2026-2046 Draft EIS
From: Kerry R. Brooks, Ph.D., Spokane, WA, West Central
My comments focus on several sections of the DEIS Chapter Three. Thank you.
3.1. Earth, Water Quality, Water Resources
P 3-3. Terrain discusses slopes.
Exhibit 3.1 merely depicts elevation with no representation of slopes. This should be corrected.
P 3-6. Soils and infiltration.
Text mentions mismatch between representation of soils as having high/moderate infiltration but shallow bedrock. How is this problem mitigated in the plan alternatives that focus growth on the West Plains?
P 3-14. Floodplains.
Have the plan alternatives incorporated the limitations and FEMA recommendations described in the text into their land allocations?
P 3-15. Exhibit 3.1-7, Surface Waters.
Exhibit 3.1-7 does not depict all the intermittent waters shown in the current National Hydrography Dataset Plus High Resolution dataset (see ArcGIS Online, e.g.). Please correct this omission—if they are not identified in this EIS they cannot be protected, especially in reference to the effort to have this EIS serve as sufficient to support categorical environmental review exemptions.
Perhaps add language to the mitigation discussion requiring identifying and preserving intermittent water bodies.
PP 3-25–3-28. Existing and Forecast Hard Surfaces / Development Density.
Please add explanation of the methods applied to develop the Housing Unit Growth Forecasts.
Is the large increase in housing units forecast in areas such as Hangman supported with respect to preservation of critical areas (especially habitat and “Natural Open Space” (SMC 17E.020.030.B.12)) serving as wildlife corridors, as well as water quality and quantity and available infrastructure?
3.3. Plants and Animals
PP 3-57–3-35.
Provide full definitions of the Land Cover categories depicted to Table 3-3-2 and Exhibit 3.3.3. Particularly, the Developed Land Cover categories are defined by percentage of open space vs. developed space, which is important in articulating impacts to natural vs. impervious surfaces under the various alternatives.
This is also important in developing a full representation of “Natural Open Space.”
An example: Class 22: Developed, Low Intensity—areas with a mixture of constructed materials and vegetation. Impervious surfaces account for 20% to 49% percent of total cover. These areas most commonly include single-family housing units (https://www.mrlc.gov/data/legends/national-land-cover-database-class-legend-and-description).
Additionally, the National Landcover database includes a “Percent Canopy” dataset which is also useful in articulating and representing built vs. natural form and understanding landscape (corridor) connectivity.
These datasets can help identify the “small patches” of habitat described in the text (c.f. 3-64), which together constitute more fine-grained habitat connectivity that is common in urban environments.
[PDF page 3 of 3]
ATTACHMENT PAGE 2 OF 2
In 2025 the Washington Department of Fish and Wildlife completed and finalized the Washington Habitat Connectivity Action Plan (WAHCAP, https://wdfw.wa.gov/species-habitats/habitat-recovery/connectivity/action-plan). This product represents current Best Available Science. While primarily focused on statewide habitat connectivity priorities, it developed datasets useful on a regional scale. The WAHCAP did not cover large urban areas, including Spokane. However, the WAHCAP plan recommends that urban areas conduct fine-grained habitat and connectivity work. The plan provides recommendations for including connectivity and land use policy and planning (see WAHCAP pp 72-26).
WAHCAP also provides constructive examples of how urban areas developed habitat and connectivity data, maps and recommendations. Considering that corridors are Critical Areas this work must be done in Spokane prior to finalization of the revised land use map and any land use designations. Completing this work with supporting implementation regulations can result in a dataset that guides appropriate development and intensification while fostering connectivity and limiting fragmentation. Perhaps even restoring lost connectivity and habitats. Such restoration of habitats (trees and understory) should focus on areas of the City that lack them. That work would coincide with environmental justice and consideration of climate impacts on overburdened communities.
Discussion of Plant and Animal Impacts (3.3.2 and Mitigation 3.3.3)
Impacts
The discussion as written does not demonstrate how any of the alternatives prevent “no net loss of habitat values and functions” (WAC 365-196-830 Protection of critical areas). Please correct this omission.
Additionally, WAC 365-196-335, Identification of open space corridors requires cities and counties to identify open space corridors. Specifically:
(a) Each county or city planning under the act must identify open space corridors within and between urban growth areas. They must include lands useful for recreation, wildlife habitat, trails, and connection of critical areas as defined in RCW 36.70A.030 (WAC 365-196-335(1)b).
Finally, the Washington Department of Commerce Guidelines for developing HB 1181 Comprehensive Plan Climate contain three main requirements. Relevant to this discussion is requirement #2:
Requirement 2: Identify, protect, and enhance natural areas to foster climate resilience, as well as areas of vital habitat for safe species migration; (DOC Guidance, page 16, https://www.commerce.wa.gov/growth-management/climate-planning/climate-planning-guidance/)
The land use plan alternatives and the preferred alternative must address these requirements.
Mitigation
The DEIS states that no “additional” mitigation measures are necessary. However, it is not clear that the DEIS (and alternatives) address the requirements outlined immediately above.
Kerry Brooks
Feb 18, 2026
Local Resident
[PDF page 1 of 3]
Please find attached comments on the Draft EIS for the Spokane Comprehensive Plan update.
Thank you.
Kerry Brooks
[Personal contact details omitted from the reading text.]
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ATTACHMENT / ADDITIONAL PAGES
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[PDF page 2 of 3]
ATTACHMENT PAGE 1 OF 2
To: Tirrell Black, City of Spokane Planning Services
Subject: Comments on City of Spokane Comprehensive Plan Update 2026-2046 Draft EIS
From: Kerry R. Brooks, Ph.D., Spokane, WA, West Central
My comments focus on several sections of the DEIS Chapter Three. Thank you.
3.1. Earth, Water Quality, Water Resources
P 3-3. Terrain discusses slopes.
Exhibit 3.1 merely depicts elevation with no representation of slopes. This should be corrected.
P 3-6. Soils and infiltration.
Text mentions mismatch between representation of soils as having high/moderate infiltration but shallow bedrock. How is this problem mitigated in the plan alternatives that focus growth on the West Plains?
P 3-14. Floodplains.
Have the plan alternatives incorporated the limitations and FEMA recommendations described in the text into their land allocations?
P 3-15. Exhibit 3.1-7, Surface Waters.
Exhibit 3.1-7 does not depict all the intermittent waters shown in the current National Hydrography Dataset Plus High Resolution dataset (see ArcGIS Online, e.g.). Please correct this omission—if they are not identified in this EIS they cannot be protected, especially in reference to the effort to have this EIS serve as sufficient to support categorical environmental review exemptions.
Perhaps add language to the mitigation discussion requiring identifying and preserving intermittent water bodies.
PP 3-25–3-28. Existing and Forecast Hard Surfaces / Development Density.
Please add explanation of the methods applied to develop the Housing Unit Growth Forecasts.
Is the large increase in housing units forecast in areas such as Hangman supported with respect to preservation of critical areas (especially habitat and “Natural Open Space” (SMC 17E.020.030.B.12)) serving as wildlife corridors, as well as water quality and quantity and available infrastructure?
3.3. Plants and Animals
PP 3-57–3-35.
Provide full definitions of the Land Cover categories depicted to Table 3-3-2 and Exhibit 3.3.3. Particularly, the Developed Land Cover categories are defined by percentage of open space vs. developed space, which is important in articulating impacts to natural vs. impervious surfaces under the various alternatives.
This is also important in developing a full representation of “Natural Open Space.”
An example: Class 22: Developed, Low Intensity—areas with a mixture of constructed materials and vegetation. Impervious surfaces account for 20% to 49% percent of total cover. These areas most commonly include single-family housing units (https://www.mrlc.gov/data/legends/national-land-cover-database-class-legend-and-description).
Additionally, the National Landcover database includes a “Percent Canopy” dataset which is also useful in articulating and representing built vs. natural form and understanding landscape (corridor) connectivity.
These datasets can help identify the “small patches” of habitat described in the text (c.f. 3-64), which together constitute more fine-grained habitat connectivity that is common in urban environments.
[PDF page 3 of 3]
ATTACHMENT PAGE 2 OF 2
In 2025 the Washington Department of Fish and Wildlife completed and finalized the Washington Habitat Connectivity Action Plan (WAHCAP, https://wdfw.wa.gov/species-habitats/habitat-recovery/connectivity/action-plan). This product represents current Best Available Science. While primarily focused on statewide habitat connectivity priorities, it developed datasets useful on a regional scale. The WAHCAP did not cover large urban areas, including Spokane. However, the WAHCAP plan recommends that urban areas conduct fine-grained habitat and connectivity work. The plan provides recommendations for including connectivity and land use policy and planning (see WAHCAP pp 72-26).
WAHCAP also provides constructive examples of how urban areas developed habitat and connectivity data, maps and recommendations. Considering that corridors are Critical Areas this work must be done in Spokane prior to finalization of the revised land use map and any land use designations. Completing this work with supporting implementation regulations can result in a dataset that guides appropriate development and intensification while fostering connectivity and limiting fragmentation. Perhaps even restoring lost connectivity and habitats. Such restoration of habitats (trees and understory) should focus on areas of the City that lack them. That work would coincide with environmental justice and consideration of climate impacts on overburdened communities.
Discussion of Plant and Animal Impacts (3.3.2 and Mitigation 3.3.3)
Impacts
The discussion as written does not demonstrate how any of the alternatives prevent “no net loss of habitat values and functions” (WAC 365-196-830 Protection of critical areas). Please correct this omission.
Additionally, WAC 365-196-335, Identification of open space corridors requires cities and counties to identify open space corridors. Specifically:
(a) Each county or city planning under the act must identify open space corridors within and between urban growth areas. They must include lands useful for recreation, wildlife habitat, trails, and connection of critical areas as defined in RCW 36.70A.030 (WAC 365-196-335(1)b).
Finally, the Washington Department of Commerce Guidelines for developing HB 1181 Comprehensive Plan Climate contain three main requirements. Relevant to this discussion is requirement #2:
Requirement 2: Identify, protect, and enhance natural areas to foster climate resilience, as well as areas of vital habitat for safe species migration; (DOC Guidance, page 16, https://www.commerce.wa.gov/growth-management/climate-planning/climate-planning-guidance/)
The land use plan alternatives and the preferred alternative must address these requirements.
Mitigation
The DEIS states that no “additional” mitigation measures are necessary. However, it is not clear that the DEIS (and alternatives) address the requirements outlined immediately above.
The final EIS must fully address them.