When looking at Alternatives 2 and 3 in the PlanSpokane 2046 Draft EIS, it is important to consider the number and types of additional housing units that are anticipated during Spokane's growth in the next 20 years. Several 2025 studies 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.
I strongly support infill as an important tool for providing much needed low-income/attainable housing while also avoiding the expansion of our Urban Growth Boundary (UGB). I support fast-tracking (waiving SEPA review) on urban lands that are already mostly impervious. However, what the City of Spokane is proposing, in my reading of the PlanSpokane Draft EIS and the Environmental Review Exemptions notice, is that environmental review will be waived for the bulk of the projected infill development destined for all of the affected neighborhoods.
Of the three choices, alternative 3 provides the greatest long-term climate, land-use, water, transportation, and infrastructure-efficiency benefits. However, I cannot in good conscience support any of these alternatives without the City's assurance that they will establish clear guardrails before broadly applying exemptions. My recommendation is that you break this effort into two phases.
The first phase would identify those properties that are already denuded and whose soils and surfaces are 100% impervious and fast-track these properties, even incentivize their development for low-income/attainable housing. The second phase would begin once the remaining areas (those offering ecologically and culturally valuable services) have been reviewed and mapped.
The City urgently needs to identify and map Spokane's remaining green infrastructure and develop well-defined objectives, using a scientifically grounded rubric for the assessment of these areas based on criteria established to protect the ecological and climate resilience services they are already providing our community.
It is commonly understood that green infrastructure provides critical services such as mitigating urban heat island effects, improving air quality, managing stormwater to reduce flash flooding as well as reducing energy demand and providing social, economic, and ecological co-benefits for public health.
Language for identifying and protecting interconnected natural areas, open space and habitat corridors can be found in Spokane's guiding documents: specifically in the existing Natural Environment chapter of our Comprehensive Plan (NE 6.3 and 11.1). Additional language for protecting these places can be found in the Sustainability Action Plan. There is also language suggested in the Climate Resilience and Sustainability Board's climate resilience policy recommendations, which I wholeheartedly appreciate and support adoption of (LUZ 2-4). Waiving environmental review on new development won't align well with Section 12.02.905 of the Spokane Municipal Code. This goal is supported by the PLANT (Protecting Leaves and Adding New Trees) Ordinance, which focuses on increasing canopy coverage from the estimated 23% in 2019 to 30% by 2030. We are currently losing a large number of pine trees to drought and bark beetle infestation, so we will not be moving towards this target if the city doesn't provide due diligence to protect our remaining urban forest.
I recommend that this language be added to our Comprehensive Plan, as suggested by the CRSB: "Create and maintain an inventory of existing and potential natural lands and fish and wildlife habitat, evaluated for their ecological and climate resilience values, using Best Available Science. A Natural Area and Habitat Connectivity Network database in the city's Geographic Information System would disseminate the information for decision makers and the public in a usable, interactive format."
The city has access to valuable data if collaborating with the state and taking advantage of information in the Washington Habitat Connectivity Action Plan (WAHCAP) which provides a data-driven, statewide framework to integrate wildlife movement and habitat connectivity into local, regional, and transportation planning. This plan helps planners move beyond just identifying critical areas to actively designing landscapes that accommodate ecological, climate, and development needs.
I wholeheartedly recommend that the City Council place a moratorium on the removal of any significantly large patches of green infrastructure, until such time as our city has the capacity to map our local canopy and natural areas of value, including their potential connectivity to one another. Once an area has been identified for protection, the city can use tools such as ordinances, zoning restrictions, "open space" designation, incentives or acquisition to secure the land for the benefit of our present and future generations. Meanwhile, lands that are close to services, transportation corridors or have experienced disturbances and that are 100% impervious, should be fast-tracked for low-income/attainable housing.
[PDF page 2 of 2 begins within the following paragraph.]
Additionally, I encourage our city's decision makers to avoid development on formerly active agricultural lands within and close to our Urban Growth Boundary. There should be a concentrated effort by our city leaders to protect these lands to increase the overall resilience of our community. Vinegar Flats and Five Mile prairie should NOT be considered for development and should receive a special zoning designation (Urban Agricultural Asset) and possibly other added protections and incentives, to encourage regenerative agricultural practices and support our growing local food economy.
Kirsten Angell
Feb 18, 2026
Local Resident
[PDF page 1 of 2]
When looking at Alternatives 2 and 3 in the PlanSpokane 2046 Draft EIS, it is important to consider the number and types of additional housing units that are anticipated during Spokane's growth in the next 20 years. Several 2025 studies 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.
I strongly support infill as an important tool for providing much needed low-income/attainable housing while also avoiding the expansion of our Urban Growth Boundary (UGB). I support fast-tracking (waiving SEPA review) on urban lands that are already mostly impervious. However, what the City of Spokane is proposing, in my reading of the PlanSpokane Draft EIS and the Environmental Review Exemptions notice, is that environmental review will be waived for the bulk of the projected infill development destined for all of the affected neighborhoods.
Of the three choices, alternative 3 provides the greatest long-term climate, land-use, water, transportation, and infrastructure-efficiency benefits. However, I cannot in good conscience support any of these alternatives without the City's assurance that they will establish clear guardrails before broadly applying exemptions. My recommendation is that you break this effort into two phases.
The first phase would identify those properties that are already denuded and whose soils and surfaces are 100% impervious and fast-track these properties, even incentivize their development for low-income/attainable housing. The second phase would begin once the remaining areas (those offering ecologically and culturally valuable services) have been reviewed and mapped.
The City urgently needs to identify and map Spokane's remaining green infrastructure and develop well-defined objectives, using a scientifically grounded rubric for the assessment of these areas based on criteria established to protect the ecological and climate resilience services they are already providing our community.
It is commonly understood that green infrastructure provides critical services such as mitigating urban heat island effects, improving air quality, managing stormwater to reduce flash flooding as well as reducing energy demand and providing social, economic, and ecological co-benefits for public health.
Language for identifying and protecting interconnected natural areas, open space and habitat corridors can be found in Spokane's guiding documents: specifically in the existing Natural Environment chapter of our Comprehensive Plan (NE 6.3 and 11.1). Additional language for protecting these places can be found in the Sustainability Action Plan. There is also language suggested in the Climate Resilience and Sustainability Board's climate resilience policy recommendations, which I wholeheartedly appreciate and support adoption of (LUZ 2-4). Waiving environmental review on new development won't align well with Section 12.02.905 of the Spokane Municipal Code. This goal is supported by the PLANT (Protecting Leaves and Adding New Trees) Ordinance, which focuses on increasing canopy coverage from the estimated 23% in 2019 to 30% by 2030. We are currently losing a large number of pine trees to drought and bark beetle infestation, so we will not be moving towards this target if the city doesn't provide due diligence to protect our remaining urban forest.
I recommend that this language be added to our Comprehensive Plan, as suggested by the CRSB: "Create and maintain an inventory of existing and potential natural lands and fish and wildlife habitat, evaluated for their ecological and climate resilience values, using Best Available Science. A Natural Area and Habitat Connectivity Network database in the city's Geographic Information System would disseminate the information for decision makers and the public in a usable, interactive format."
The city has access to valuable data if collaborating with the state and taking advantage of information in the Washington Habitat Connectivity Action Plan (WAHCAP) which provides a data-driven, statewide framework to integrate wildlife movement and habitat connectivity into local, regional, and transportation planning. This plan helps planners move beyond just identifying critical areas to actively designing landscapes that accommodate ecological, climate, and development needs.
I wholeheartedly recommend that the City Council place a moratorium on the removal of any significantly large patches of green infrastructure, until such time as our city has the capacity to map our local canopy and natural areas of value, including their potential connectivity to one another. Once an area has been identified for protection, the city can use tools such as ordinances, zoning restrictions, "open space" designation, incentives or acquisition to secure the land for the benefit of our present and future generations. Meanwhile, lands that are close to services, transportation corridors or have experienced disturbances and that are 100% impervious, should be fast-tracked for low-income/attainable housing.
[PDF page 2 of 2 begins within the following paragraph.]
Additionally, I encourage our city's decision makers to avoid development on formerly active agricultural lands within and close to our Urban Growth Boundary. There should be a concentrated effort by our city leaders to protect these lands to increase the overall resilience of our community. Vinegar Flats and Five Mile prairie should NOT be considered for development and should receive a special zoning designation (Urban Agricultural Asset) and possibly other added protections and incentives, to encourage regenerative agricultural practices and support our growing local food economy.
Thank you for your consideration,
Kirsten Angell