Greg Figg - Washington State Department of Transportation (WSDOT)
Feb 18, 2026
Government / Technical
[PDF page 1 of 6]
Good Afternoon All,
Please find attached the WSDOT comments on the DEIS for the comprehensive plan. Thank you again for the opportunity to review this document. Best Regards,
WSDOT has reviewed the PlanSpokane Draft Environmental Impact Statement (DEIS), which was released for public comment on December 18, 2025, along with the additional supplemental material received to date. As an initial matter, WSDOT has not yet received all of the requested supplemental materials it needs to provide a complete comment. Therefore, this comment is incomplete as to information that has been requested but not yet been provided. Nevertheless, after our review of the material received, WSDOT has the following comments:
Traffic Impacts by State Transportation Facilities
1. The modeling along Division Avenue/US-2 does not appear to account for the BRT that is planned, which is included in the Comprehensive Plan,
a. The capacities along Division Avenue/US-2 continue to reflect the 3-lanes per direction and should be reduced to 2-lanes of capacity for the future and approved BRT lane,
b. This may cause traffic to shift to other regional routes and may impact the US-2 corridor, amongst others.
2. The land use growth and trip generation of the 3 alternatives, west of US-195 and south of I-90, are not able to be confirmed based on the limited information provided.
a. Impacts along US-195 were not analyzed and may not account for all trips associated with recently approved land use allocations.
b. Key locations that analysis is being sought include US-195/Thorpe, US-195/I-90, the J-Turn locations on US-195, and Hatch Road/US-195. This analysis is not included in the DEIS.
3. Modeling in the West Plains (south of US-2, north of I-90, east of Fairchild) does not reflect the land uses proposed in the DEIS.
a. Specifically, projected volumes along the 21st Avenue corridor, in many locations, are zero. This corridor is being developed as a parallel arterial to US-2.
[PDF page 3 of 6]
b. Projected volumes associated with TAZs are very low for projected land use densities proposed in all alternatives, especially in Alternative 3.
c. US-2 volumes at I-90 show volumes exceeding capacity. No mitigation was proposed to accommodate planned land uses either on the State or Local network.
d. One (1) intersection (Flint Rd./US-2) was analyzed along US-2, Additional intersections are being requested as several locations have failures (LOS below approved standards) today and limited ability to accommodate additional growth.
4. Modeling along SR-291 does not appear to include all planned growth as shown in the proposed land uses.
a. One (1) intersection (Alberta St/SR-291) along SR-291 was analyzed. Additional intersections are being requested as several locations have poor operations/level of service today.
b. Upon inspection of the travel demand model output, limited growth is shown to come from the vacant land north of Francis Avenue/SR-291 in all three alternatives.
5. Modeling along US-395, near Wellesley Avenue, does not appear to incorporate planned growth as shown in the land use proposals.
a. Analysis was not completed at the Wellesley Avenue intersections with US-395 ramps; therefore it is uncertain what impacts the land use will have on WSDOT facilities.
6. Additional peak hour trip information from the travel demand model at specific TAZ's of concern has been requested and WSDOT is awaiting this information.
7. Upon review of the GIS information provided, several WSDOT facilities are projected to be over capacity with all land use alternatives reviewed. WSDOT is concerned with the City implementing SEPA exemptions with any alternative without additional analysis supporting that adequate facilities are provided with proposed development.
8. In our requests for additional information some of the documents received are dated after the issuance of the DEIS. Was this information considered as part of the DEIS analysis?
9. Pursuant to RCW 36.70A.070, intergovernmental coordination is required. The DEIS does not clearly describe how impacts to the state transportation system were analyzed in coordination with WSDOT and affected neighboring jurisdictions. Please identify the coordination conducted, the assumptions used, and how cross-jurisdictional impacts to state facilities were evaluated and addressed.
10. RCW 36.70A.070 also requires that transportation elements ensure adopted level-of-service standards are maintained and that impacts of planned growth are addressed. Absent this analysis and coordination, the EIS does not demonstrate consistency with the Growth Management Act requirements governing transportation elements and intergovernmental coordination.
[PDF page 4 of 6]
WSDOT requests that the above comments be fully addressed in the revised EIS and that mitigation measures sufficient to maintain WSDOT's adopted level-of-service standards be identified, evaluated, and incorporated where impacts are identified. WSDOT welcomes the opportunity to meet and collaborate with the City of Spokane to ensure these comments are addressed prior to the Final EIS being issued.
SEPA Categorical Exemptions
To adopt the proposed SEPA exemptions, the City must analyze the impacts to the transportation system-including state facilities-in the comprehensive plan environmental impact analysis, with impacts identified. WSDOT is concerned that the transportation analysis in the DEIS largely does not address impacts to the state highway system where growth is expected.
For instance, along the US-195 corridor, where significant residential development is expected, only one screenline was analyzed. The capacity, level of service (LOS), safety, and operational issues will primarily be at intersections that are at grade, such as those along US-195. The screenline is useful to check volumes but is not a tool to identify intersection LOS issues.
If the City did consider this, WSDOT was not provided the necessary documentation that would support the City's conclusion. Additionally, in order to meet the requirement of RCW 43.21c.229(3) the City must consult with WSDOT and document those consultations as well as the impacts and mitigating measures.
If the optional SEPA exemptions are desired by the City, additional transportation analysis is required for the state transportation facilities, and any necessary mitigations must be identified. It should be noted that not all of the needed mitigations are identified in the City's impact fee ordinance, nor can impact fees fund the needed mitigation as they typically only cover 30%-40% of the cost of an improvement.
WSDOT requests a meeting with the City to identify those areas that will be impacted by the growth projected in the DEIS. This will allow a more targeted analysis of those areas.
Request for an Extension of Review Time
WSDOT formally requests an extension of time to provide a complete comment to the DEIS. While the DEIS did have a 60-day public comment period, the data necessary for WSDOT's complete review of the DEIS was not received in a timely manner, essentially preventing WSDOT from the benefit of a full 60 days to comment. Furthermore, the requirement to complete a Public Records Request to obtain information undermines the spirit of coordination that WSDOT seeks with the City of Spokane and is intended by the statute.
[PDF page 5 of 6]
Also, it is unclear if the City of Spokane had all of the information necessary to come to the conclusions made in the DEIS-particularly that there will be no adverse impacts to the state transportation system-as a portion of the transportation and land use data necessary for our review of the impacts was not readily available when requested. WSDOT maintains responsibility for the safety and operations of the state highway system, and the additional information requested from the City of Spokane is necessary to determine if there will be any probable significant adverse impacts resulting from this Comprehensive Plan Update, and to identify possible mitigating measures.
To date, WSDOT has not received all of the data necessary to undertake a complete review of the DEIS. In particular, WSDOT has not received the trip generation and volume data from the TAZ's of concern that impact the highway system. Without this data WSDOT is unable to confirm the planned development's impacts to the state highway system. As such, WSDOT requests a 15-day extension from the time all of the currently requested data is received.
Below is a brief outline of WSDOT's requests for additional information regarding the DEIS:
12/17 - WSDOT requests data from City of Spokane necessary for review of the forthcoming DEIS.
12/18 - DEIS released for 60-day public review.
12/18 - WSDOT instructed by City of Spokane to submit a public records request to receive data necessary for review.
1/7 - WSDOT requests meeting with City of Spokane and Fehr & Peers to discuss the unreceived data requested on 12/17.
1/12 - WSDOT receives a portion of requested data from City of Spokane. Separate memorandums provided on 1/12/2026 are dated January 7, 2026 and January 9, 2026.
1/13 - Meeting with WSDOT, City of Spokane, and Fehr & Peers. Additional necessary data is requested by WSDOT following this meeting.
1/23 - Data requested on 1/13 received by WSDOT from City of Spokane.
2/11 - WSDOT requests additional data from City of Spokane necessary for review.
2/13 - A portion of data requested on 2/11 is received by WSDOT. WSDOT is instructed to obtain an NDA from SRTC to receive the remainder of the data.
2/17 - WSDOT notifies City of Spokane NDA is, and has been, in place with SRTC for data request. No data received from City of Spokane.
2/18 - City of Spokane responds to request for data, indicating it will be a week until the data can be delivered.
2/18 - DEIS Comment Deadline, comments and request of extension of time submitted.
[PDF page 6 of 6]
Please do not hesitate to contact me if you have any questions regarding these comments. As always, we welcome collaboration and are glad to discuss our comments in person.
Sincerely,
Greg Figg
Development Services Manager
WSDOT - Eastern Region
Greg Figg - Washington State Department of Transportation (WSDOT)
Feb 18, 2026
Government / Technical
[PDF page 1 of 6]
Good Afternoon All,
Please find attached the WSDOT comments on the DEIS for the comprehensive plan. Thank you again for the opportunity to review this document. Best Regards,
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ATTACHMENT / ADDITIONAL PAGES
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[PDF page 2 of 6]
Washington State Department of Transportation
February 18, 2026
Tirrell Black
Assistant Director
City of Spokane Planning & Economic Development
808 W. Spokane Falls Blvd, Spokane, WA 99201
RE: PlanSpokane 2046 Draft Environmental Impact Statement - WSDOT Comments
Ms. Black,
WSDOT has reviewed the PlanSpokane Draft Environmental Impact Statement (DEIS), which was released for public comment on December 18, 2025, along with the additional supplemental material received to date. As an initial matter, WSDOT has not yet received all of the requested supplemental materials it needs to provide a complete comment. Therefore, this comment is incomplete as to information that has been requested but not yet been provided. Nevertheless, after our review of the material received, WSDOT has the following comments:
Traffic Impacts by State Transportation Facilities
1. The modeling along Division Avenue/US-2 does not appear to account for the BRT that is planned, which is included in the Comprehensive Plan,
a. The capacities along Division Avenue/US-2 continue to reflect the 3-lanes per direction and should be reduced to 2-lanes of capacity for the future and approved BRT lane,
b. This may cause traffic to shift to other regional routes and may impact the US-2 corridor, amongst others.
2. The land use growth and trip generation of the 3 alternatives, west of US-195 and south of I-90, are not able to be confirmed based on the limited information provided.
a. Impacts along US-195 were not analyzed and may not account for all trips associated with recently approved land use allocations.
b. Key locations that analysis is being sought include US-195/Thorpe, US-195/I-90, the J-Turn locations on US-195, and Hatch Road/US-195. This analysis is not included in the DEIS.
3. Modeling in the West Plains (south of US-2, north of I-90, east of Fairchild) does not reflect the land uses proposed in the DEIS.
a. Specifically, projected volumes along the 21st Avenue corridor, in many locations, are zero. This corridor is being developed as a parallel arterial to US-2.
[PDF page 3 of 6]
b. Projected volumes associated with TAZs are very low for projected land use densities proposed in all alternatives, especially in Alternative 3.
c. US-2 volumes at I-90 show volumes exceeding capacity. No mitigation was proposed to accommodate planned land uses either on the State or Local network.
d. One (1) intersection (Flint Rd./US-2) was analyzed along US-2, Additional intersections are being requested as several locations have failures (LOS below approved standards) today and limited ability to accommodate additional growth.
4. Modeling along SR-291 does not appear to include all planned growth as shown in the proposed land uses.
a. One (1) intersection (Alberta St/SR-291) along SR-291 was analyzed. Additional intersections are being requested as several locations have poor operations/level of service today.
b. Upon inspection of the travel demand model output, limited growth is shown to come from the vacant land north of Francis Avenue/SR-291 in all three alternatives.
5. Modeling along US-395, near Wellesley Avenue, does not appear to incorporate planned growth as shown in the land use proposals.
a. Analysis was not completed at the Wellesley Avenue intersections with US-395 ramps; therefore it is uncertain what impacts the land use will have on WSDOT facilities.
6. Additional peak hour trip information from the travel demand model at specific TAZ's of concern has been requested and WSDOT is awaiting this information.
7. Upon review of the GIS information provided, several WSDOT facilities are projected to be over capacity with all land use alternatives reviewed. WSDOT is concerned with the City implementing SEPA exemptions with any alternative without additional analysis supporting that adequate facilities are provided with proposed development.
8. In our requests for additional information some of the documents received are dated after the issuance of the DEIS. Was this information considered as part of the DEIS analysis?
9. Pursuant to RCW 36.70A.070, intergovernmental coordination is required. The DEIS does not clearly describe how impacts to the state transportation system were analyzed in coordination with WSDOT and affected neighboring jurisdictions. Please identify the coordination conducted, the assumptions used, and how cross-jurisdictional impacts to state facilities were evaluated and addressed.
10. RCW 36.70A.070 also requires that transportation elements ensure adopted level-of-service standards are maintained and that impacts of planned growth are addressed. Absent this analysis and coordination, the EIS does not demonstrate consistency with the Growth Management Act requirements governing transportation elements and intergovernmental coordination.
[PDF page 4 of 6]
WSDOT requests that the above comments be fully addressed in the revised EIS and that mitigation measures sufficient to maintain WSDOT's adopted level-of-service standards be identified, evaluated, and incorporated where impacts are identified. WSDOT welcomes the opportunity to meet and collaborate with the City of Spokane to ensure these comments are addressed prior to the Final EIS being issued.
SEPA Categorical Exemptions
To adopt the proposed SEPA exemptions, the City must analyze the impacts to the transportation system-including state facilities-in the comprehensive plan environmental impact analysis, with impacts identified. WSDOT is concerned that the transportation analysis in the DEIS largely does not address impacts to the state highway system where growth is expected.
For instance, along the US-195 corridor, where significant residential development is expected, only one screenline was analyzed. The capacity, level of service (LOS), safety, and operational issues will primarily be at intersections that are at grade, such as those along US-195. The screenline is useful to check volumes but is not a tool to identify intersection LOS issues.
If the City did consider this, WSDOT was not provided the necessary documentation that would support the City's conclusion. Additionally, in order to meet the requirement of RCW 43.21c.229(3) the City must consult with WSDOT and document those consultations as well as the impacts and mitigating measures.
If the optional SEPA exemptions are desired by the City, additional transportation analysis is required for the state transportation facilities, and any necessary mitigations must be identified. It should be noted that not all of the needed mitigations are identified in the City's impact fee ordinance, nor can impact fees fund the needed mitigation as they typically only cover 30%-40% of the cost of an improvement.
WSDOT requests a meeting with the City to identify those areas that will be impacted by the growth projected in the DEIS. This will allow a more targeted analysis of those areas.
Request for an Extension of Review Time
WSDOT formally requests an extension of time to provide a complete comment to the DEIS. While the DEIS did have a 60-day public comment period, the data necessary for WSDOT's complete review of the DEIS was not received in a timely manner, essentially preventing WSDOT from the benefit of a full 60 days to comment. Furthermore, the requirement to complete a Public Records Request to obtain information undermines the spirit of coordination that WSDOT seeks with the City of Spokane and is intended by the statute.
[PDF page 5 of 6]
Also, it is unclear if the City of Spokane had all of the information necessary to come to the conclusions made in the DEIS-particularly that there will be no adverse impacts to the state transportation system-as a portion of the transportation and land use data necessary for our review of the impacts was not readily available when requested. WSDOT maintains responsibility for the safety and operations of the state highway system, and the additional information requested from the City of Spokane is necessary to determine if there will be any probable significant adverse impacts resulting from this Comprehensive Plan Update, and to identify possible mitigating measures.
To date, WSDOT has not received all of the data necessary to undertake a complete review of the DEIS. In particular, WSDOT has not received the trip generation and volume data from the TAZ's of concern that impact the highway system. Without this data WSDOT is unable to confirm the planned development's impacts to the state highway system. As such, WSDOT requests a 15-day extension from the time all of the currently requested data is received.
Below is a brief outline of WSDOT's requests for additional information regarding the DEIS:
12/17 - WSDOT requests data from City of Spokane necessary for review of the forthcoming DEIS.
12/18 - DEIS released for 60-day public review.
12/18 - WSDOT instructed by City of Spokane to submit a public records request to receive data necessary for review.
1/7 - WSDOT requests meeting with City of Spokane and Fehr & Peers to discuss the unreceived data requested on 12/17.
1/12 - WSDOT receives a portion of requested data from City of Spokane. Separate memorandums provided on 1/12/2026 are dated January 7, 2026 and January 9, 2026.
1/13 - Meeting with WSDOT, City of Spokane, and Fehr & Peers. Additional necessary data is requested by WSDOT following this meeting.
1/23 - Data requested on 1/13 received by WSDOT from City of Spokane.
2/11 - WSDOT requests additional data from City of Spokane necessary for review.
2/13 - A portion of data requested on 2/11 is received by WSDOT. WSDOT is instructed to obtain an NDA from SRTC to receive the remainder of the data.
2/17 - WSDOT notifies City of Spokane NDA is, and has been, in place with SRTC for data request. No data received from City of Spokane.
2/18 - City of Spokane responds to request for data, indicating it will be a week until the data can be delivered.
2/18 - DEIS Comment Deadline, comments and request of extension of time submitted.
[PDF page 6 of 6]
Please do not hesitate to contact me if you have any questions regarding these comments. As always, we welcome collaboration and are glad to discuss our comments in person.
Sincerely,
Greg Figg
Development Services Manager
WSDOT - Eastern Region
cc: Shauna Harshman - WSDOT
Ben Serr - Department of Commerce
Scott Chesney - Spokane County
Ryan Stewart - SRTC