Brooke Frickleton - Futurewise
Feb 18, 2026
Community Advocate
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Please find attached Futurewise's comments on the Draft Environmental Impact Statement for the City of Spokane Comprehensive Plan Update 2026-2046 (PlanSpokane),
Please do not hesitate to contact me if you have any questions.
Cheers,
Brooke Frickleton (she/they)
Deputy Legal Director
Futurewise
Spencer Gardner, Director, Planning Services
City of Spokane
808 W. Spokane Falls Blvd.
Spokane, WA 99201
Submitted via email: PlanSpokane@spokanecity.org
Dear Staff and Consulting Team:
Thank you for the opportunity to comment on the Draft Environmental Impact Statement for the City of Spokane Comprehensive Plan Update 2026-2046 (PlanSpokane). Futurewise agrees with the City's decision to prepare an environmental impact statement (EIS). The comprehensive plan and the development it will authorize is likely to have a significant probable adverse impact on the environment.
Futurewise is a Washington State nonprofit organization that works to advance healthy, equitable, and opportunity-rich communities through smart land use policy and advocacy. We appreciate the City of Spokane's substantial investment in developing a thoughtful and ambitious Comprehensive Plan update, and we write to offer constructive comments on the Draft Environmental Impact Statement (DEIS).
In addressing the adequacy of a nonproject EIS, the Court of Appeals wrote that:
In Leschi v. Highway Comm'n, 84 Wn.2d 271, 525 P.2d 774 (1974), a majority of the Supreme Court held that the adequacy question is one of law, subject to de novo review by the courts. The test to be applied is "whether the environmental effects of the proposed action and reasonable alternatives are sufficiently disclosed, discussed and that they are substantiated by supportive opinion and data." Leschi v. Highway Comm'n, supra at 286, 525 P.2d at 785. 1
Ullock v. City of Bremerton, 17 Wn. App. 573, 580, 565 P.2d 1179, 1184 (1977).
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WAC 197-11-440(6)(a) requires that for the elements of the environment significantly affected by the proposed action, "the EIS shall describe the existing environment that will be affected by the proposal, analyze significant impacts of alternatives including the proposed action, and discuss reasonable mitigation measures that would significantly mitigate these impacts." WAC 197-11-442 (1) provides that the lead agency shall have more flexibility in preparing EISs on nonproject proposals. WAC 197-11-442(2) also provides that for nonproject EISs
[t]he lead agency shall discuss impacts and alternatives in the level of detail appropriate to the scope of the nonproject proposal and to the level of planning for the proposal. Alternatives should be emphasized. In particular, agencies are encouraged to describe the proposal in terms of alternative means of accomplishing a stated objective (see WAC 197-11-060(3)). Alternatives including the proposed action should be analyzed at a roughly comparable level of detail, sufficient to evaluate their comparative merits (this does not require devoting the same number of pages in an EIS to each alternative).
As is documented below, the DEIS may not comply with these requirements for several elements of the environment.
Transportation Analysis: Per Capita VMT Baseline Comparison and the Environmental Case for Alternative 2
We commend the City for using the SRTC regional travel demand model and for presenting VMT per capita as a key comparative metric. This is the right framework for evaluating the land use-transportation nexus at a programmatic scale. However, we identify two significant gaps in the transportation analysis that should be addressed in the Final EIS
The Final EIS should compare per capita VMT under each alternative against existing conditions to demonstrate compliance with RCW 36.70A.070(9)(d)(i)(B).
RCW 36.70A.070(9)(d)(i)(B) requires that the greenhouse gas emissions reduction sub element of the comprehensive plan identify actions that will result in "reductions in per capita vehicle miles traveled within the jurisdiction." This is a mandate to demonstrate actual reductions from current conditions - not merely reductions relative to a No Action baseline.
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The DEIS presents per capita VMT for 2046 across alternatives, with Alternative 2 at 19.2 and Alternative 3 at 19.8 (DEIS pp. 3-277, 3-280), both compared only against the No Action alternative at 19.9. However, the DEIS does not present existing per capita VMT - whether using the 2022 GHG inventory baseline or another current year - alongside those 2046 projections.
Without that comparison, it is impossible to determine whether either action alternative would actually achieve the per capita VMT reductions that RCW 36.70A.070(9)(d)(i)(B) requires. The statute mandates reductions from current conditions, not merely performance better than No Action. A plan that reduces VMT relative to the No Action scenario but leaves per capita VMT at or above today's levels would not satisfy that statutory requirement.
This gap is particularly consequential because the DEIS's GHG reductions are driven primarily by statewide policies - the 2035 internal combustion engine ban and the 2045 clean electricity mandate - rather than by Spokane's land use decisions. If per capita VMT under either action alternative is projected to remain at or above today's levels, that is a material finding that must appear in the Final EIS and must be addressed in the Climate Element.
The Preferred Alternative should more fully account for the environmental significance of the VMT difference between Alternative 2 and Alternative 3.
Beyond the baseline comparison issue, the DEIS concludes that "no significant impact to mode share or VMT is expected" under either action alternative, using identical findings for both. This conclusion obscures a meaningful environmental difference between the alternatives that decision-makers should have before them.
The DEIS's own data shows:
- Alternative 2 (Distributed & Balanced): Daily VMT (2046), 5,732,000; VMT per capita, 19.2
- Alternative 3 (Center City & Regional Hubs): Daily VMT (2046), 5,916,000; VMT per capita, 19.8
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Alternative 2 produces approximately 184,000 fewer vehicle miles traveled every weekday than Alternative 3. Annualized over 320 weekdays, this is roughly 59 million fewer VMT per year. Given that transportation accounted for 41% of Spokane's 2022 community GHG emissions, this difference carries material climate significance. The DEIS acknowledges that Alternative 2 produces the lowest transportation emissions of any alternative (DEIS p. 3-49), yet the transportation impact findings treat both action alternatives as equivalent. The driver of this gap is Alternative 3's continued concentration of employment in industrial hubs at West Plains/Airport and Northeast/Hillyard - areas with limited transit access - which generates longer trip lengths and higher total VMT. This is precisely the land use-transportation tradeoff that a programmatic EIS should illuminate for decision-makers, and the Preferred Alternative and Final EIS should quantify the cumulative annual GHG emissions difference attributable to this VMT gap.
Water Resources and Aquifer Protection
The Spokane Valley-Rathdrum Prairie Aquifer is a federally designated sole-source aquifer and deserves commensurate analysis in the Final EIS.
The DEIS acknowledges that the City of Spokane's water supply depends on the Spokane Valley-Rathdrum Prairie Aquifer, which is designated by the U.S. Environmental Protection Agency as a "sole source aquifer" - meaning it is the sole or principal drinking water source for the area and has no reasonably available alternative should it become contaminated (DEIS p. 3-20).
The DEIS also notes that, as a result of an August 2025 ballot measure, the Spokane Valley-Rathdrum Prairie Aquifer Protection Area will be expanded beginning January 1, 2026 to include all areas within the City boundary - an area that previously had no protection area coverage at all. This is a significant change to the regulatory landscape that the Final EIS should fully integrate.
Despite these facts, the DEIS does not include a cumulative impact analysis of how the growth projected under each alternative would affect aquifer recharge rates, impervious surface additions over Critical Aquifer Recharge Areas, or the long-term sustainability of the water supply. The DEIS references a 2025 environmental code audit recommending review of Spokane Municipal Code Section 17E.010 (Critical Aquifer Recharge Area regulations) and lists aquifer protection as a potential mitigation measure, but does not commit to implementing those recommendations or explain how they would be triggered (DEIS pp. 3-30-3-32).
Given that this aquifer supplies more than 50% of the drinking water for the Spokane-Coeur d'Alene metropolitan area and has no reasonable alternative source, the applicable legal standard for protection is correspondingly high. The GMA requires comprehensive plans to "provide for protection of the quality and quantity of groundwater used for public water supplies." RCW 36.70A.070(1). The GMA also requires counties and cities to designate and protect aquifer recharge areas and adopt measures to prevent groundwater contamination and overuse. RCW 36.70A.170; RCW 36.70A.060(2).
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The Final EIS should assess whether existing water rights are sufficient to serve projected growth under each alternative.
The DEIS presents water demand projections by pressure zone through 2042 (DEIS pp. 3-331-3-333) but does not assess whether the City's existing water rights portfolio is sufficient to meet that projected demand. This is an important gap. As Washington State Department of Ecology water resources staff have documented, all of Washington's water is already allocated to a water user - meaning that new demand can only be met through existing water rights, water conservation, or market transactions. In Eastern Washington specifically, groundwater levels are declining in most aquifer layers, and the Lower and Middle Spokane watersheds are projected to experience increasing summer demand against decreasing summer supply, as was scene last summer.
A programmatic EIS that projects significant population and employment growth through 2046 without analyzing whether legally and physically available water exists to serve that growth is analytically incomplete. The Final EIS should confirm whether the City's existing water rights are sufficient to serve the projected growth under each alternative, and if not, what water supply strategy the City proposes to address that gap.
The Final EIS should specifically analyze the interaction between projected West Plains growth and the identified PFAS contamination in that area.
The DEIS identifies per- and polyfluoroalkyl substances (PFAS) contamination in private-well groundwater in the West Plains region of the city (DEIS pp. 3-13 to 3-14). Both Alternatives 2 and 3 contemplate growth and employment concentration in the West Plains/Airport area. The Final EIS should specifically analyze how projected growth in that subarea interacts with the identified PFAS contamination, and what regulatory tools the City will use to protect groundwater quality in the expanded Aquifer Protection Area.
Higher-density, compact growth supports aquifer sustainability - an additional environmental advantage of Alternative 2.
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Research demonstrates that higher-density, multifamily housing types use significantly less water per capita than large-lot, low-density development - both indoors and outdoors. The U.S. EPA has documented that compact growth, by reducing service line lengths and outdoor irrigation demands, can reduce total residential water demand by 5-25% over lower-density alternatives. Alternative 2's greater emphasis on multifamily housing and its distributed centers-and-corridors approach means it would likely generate less per capita water demand than Alternative 3's higher employment growth scenario. The Final EIS should quantify this difference as part of the utilities analysis.
Housing Element: HB 1220 Compliance and Displacement Risk
We commend the City for conducting and publishing a racially disparate impacts analysis in September 2025. The findings - documenting persistent BIPOC homeownership gaps, the legacy of exclusionary zoning and redlining, environmental health disparities, and uneven distribution of housing growth - are honest and substantive. This positions Spokane well for a GMA-compliant housing element.
First, the Final Plan should demonstrate housing capacity disaggregated by income band.
HB 1220 requires that jurisdictions plan for and accommodate housing affordable to all income levels, and that the housing element document adequate provisions for extremely low, very low, low, and moderate-income households specifically. The DEIS references capacity for "all income levels" and HB 1220 compliance in general terms. The Final Plan's housing element should include a table confirming that sufficient zoned and buildable capacity exists for each income tier, consistent with Commerce's Housing Element guidance.
Second, the Final Plan's policy response should match the strength of the disparate impacts diagnosis.
RCW 36.70A.070(2)(e)-(h) requires jurisdictions to "implement policies and regulations that begin to undo" identified racially disparate impacts. We encourage the Final Plan to include specific, mandatory anti-displacement tools such as: targeted rezoning in historically excluded neighborhoods rather than only high-opportunity areas; affordable housing preservation requirements in high-displacement-risk areas; and explicit linkage between the Target Investment Area strategy and affordability outcomes for BIPOC households.
Climate Element: Strengthening Local Policy Commitments
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The DEIS GHG analysis uses a 2022 baseline and presents projections against the City's adopted reduction targets (45% by 2030, 70% by 2040, net-zero by 2050). We support this framework. However, as noted in Section I above, the heavy reliance on statewide EV and electricity mandates to drive projected reductions raises a fundamental question about local accountability: what does Spokane's own plan contribute?
RCW 36.70A.070(9)(d)(i)(A) requires that the Climate Element identify actions that will result in "reductions in overall greenhouse gas emissions generated by transportation and land use within the jurisdiction." The Final EIS should include a "policy wedge" analysis isolating the GHG reductions attributable to Spokane's specific land use decisions - infill siting, TOD density, parking reform, TDM requirements - from the reductions that would occur regardless under state law. This analysis is recommended by Commerce's climate planning guidance and is necessary for the Climate Element to demonstrate independent compliance with RCW 36.70A.070(9)(d)(i)(A).
We also encourage the Final Plan's Climate Element to include specific implementation commitments rather than exploratory language. Rather than "the City will consider TDM strategies," the plan should commit to adopting specific TDM standards, parking reform, and building decarbonization regulations by a date certain. Alternative 2's lower VMT profile and higher multifamily share position it well to support these commitments.
Conclusion
Our core recommendations are: (1) the Final EIS should present existing per capita VMT alongside the 2046 alternative projections, so decision-makers can evaluate compliance with RCW 36.70A.070(9)(d)(i)(B)'s requirement for actual reductions from current conditions; (2) the Final EIS should include cumulative aquifer impact analysis and confirm water rights sufficiency for projected growth, consistent with the January 2026 expansion of the Aquifer Protection Area; (3) the Final Plan's housing element should disaggregate capacity by income band and include binding anti-displacement tools; and (4) the Climate Element should isolate Spokane's own policy contributions to GHG reduction and include a binding implementation schedule.
On alternative selection, we encourage the City to give full weight to the environmental advantages that Alternative 2 demonstrates across transportation, GHG emissions, water demand, and housing affordability, and to make those advantages explicit in the preferred alternative selection rationale. We look forward to continued engagement as the City moves toward Final EIS and Final Plan adoption.
Thank you for considering our comments.
Thank you for considering our comments.
[Professional contact details omitted from the reading text.]
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- RCW 36.70A.070(1): Comprehensive plan land use element must provide for protection of the quality and quantity of groundwater used for public water supplies.
- RCW 36.70A.170 and RCW 36.70A.060(2): Critical areas designation and protection requirements, including aquifer recharge areas.
- Washington State Department of Commerce, Guidance for Updating Your Housing Element:
Updated Housing Element Requirements with HB 1220 (Book 2, August 2023, updated September 2024). Available at: https://www.commerce.wa.gov/serving-communities/growth-management/growth-management-topics/housing/.
- Washington State Department of Commerce, Guidance to Address Racially Disparate Impacts: Updating Your Housing Element to Address New Requirements (Book 3, April 2023). Available at: https://www.commerce.wa.gov/serving-communities/growth-management/growth-management-topics/housing/.
Water Resources - U.S. Environmental Protection Agency, Sole Source Aquifer Program: Spokane Valley-Rathdrum Prairie Sole Source Aquifer. Available at: https://www.epa.gov/dwssa.
Referenced in DEIS Section 3.1.1 (p. 3-20).
- Hall, S.A., Adam, J.C., Yourek, M.A., et al., 2021 Washington State Legislative Report:
Columbia River Basin Long-Term Water Supply and Demand Forecast (Publication No. 21-12-006, Washington Department of Ecology, 2022). Available at:
https://apps.ecology.wa.gov/publications/SummaryPages/2112006.html.
Documents declining groundwater levels in most aquifer layers and subareas across eastern
Washington, and projected summer supply decreases in the Lower and Middle Spokane watersheds.
- State of Washington Department of Ecology, Water Resources Program, WRIA Watershed Water Availability publications. Available at: https://ecology.wa.gov/water-shorelines/water-supply/water-availability/in-your-watershed.
Documents water availability limitations throughout the Lower Spokane, Little Spokane, Hangman, and Middle Spokane watersheds.
- Washington State Department of Health, PFAS Testing Results Dashboard (last accessed February 2026). Available at: https://doh.wa.gov/data-and-statistical-reports/washington-tracking-network-wtn/pfas/dashboard.
See also DEIS Exhibits 3.1-13 and 3.1-14 (PFAS contamination in West Plains private wells).
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- Swanson, Conrad, "Trump keeps talking about taking PNW water - is that possible?" The Seattle Times (Updated February 23, 2025). Available at:
https://www.seattletimes.com/seattle-news/climate-lab/trump-keeps-talking-about-taking-pnw-water-is-that-possible/. Citing Ria Berns, Washington State Department of Ecology Water Resources Program Manager, on full allocation of Washington's water resources.
- U.S. Environmental Protection Agency, Growing Toward More Efficient Water Use: Linking Development, Infrastructure, and Drinking Water Policies (EPA 230-R-06-001, January 2006). Available at: https://www.epa.gov/smartgrowth/growing-toward-more-efficient-water-use.
Cited for research showing higher-density, compact development reduces per capita water demand by 5-25% compared to low-density alternatives.
- Sampson, D.A., Quay, Ray, and Horrie, Mitch, "Building type, housing density, and water use: Denver Water data and agent-based simulations," 58 Journal of the American Water Resources Association 355 (2022).
Available at:
https://asu.elsevierpure.com/en/publications/building-type-housing-density-and-water-use-denver-water-data-and. Peer-reviewed study documenting per capita water demand differences by housing type and density.
Transportation and Climate Science
- Cascadia Consulting Group, Greenhouse Gas Emissions Analysis for City of Spokane Comprehensive Plan Update EIS (2025).
Referenced in DEIS Section 3.2, Exhibit 3.2-8.
Source for finding that Alternative 2 produces the lowest energy and transportation emissions across all alternatives.
- Zhang, Lei, Hong, Jinhyun, Nasri, Arefeh, and Shen, Qing, "How built environment affects
travel behavior: A comparative analysis of the connections between land use and vehicle miles traveled in US cities," 5 Journal of Transport and Land Use 40 (2012).
Available at:
https://www.jtlu.org/index.php/jtlu/article/view/266.
Peer-reviewed study documenting that increases in density reduce per capita vehicle miles traveled, with more pronounced effects in higher-density areas.
- Goldstein, Benjamin, Gounaridis, Dimitrios, and Newell, Joshua P., "The carbon footprint of household energy use in the United States," 117 Proceedings of the National Academy of
Sciences 19122 (August 11, 2020).
Available at:
https://www.pnas.org/content/117/32/19122.
Peer-reviewed study documenting that meeting necessary GHG reductions requires higher residential densities, achievable through a mix of small apartment buildings and modest single-family homes.
- Kuss, Paula and Nicholas, Kimberly A., "A dozen effective interventions to reduce car use in European cities: Lessons learned from a meta-analysis and transition management," 10 Case Studies on Transport Policy 1494 (Issue 3, September 2022).
Available at:
https://www.sciencedirect.com/science/article/pii/S2213624X22000281. Peer-reviewed meta-analysis identifying effective strategies to reduce vehicle use, including TDM measures, parking reform, and land use density.
Brooke Frickleton - Futurewise
Feb 18, 2026
Community Advocate
[PDF page 1 of 10]
Please find attached Futurewise's comments on the Draft Environmental Impact Statement for the City of Spokane Comprehensive Plan Update 2026-2046 (PlanSpokane),
Please do not hesitate to contact me if you have any questions.
Cheers,
Brooke Frickleton (she/they)
Deputy Legal Director
Futurewise
Book time to meet with me
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ATTACHMENT / ADDITIONAL PAGES
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February 18, 2026
Spencer Gardner, Director, Planning Services
City of Spokane
808 W. Spokane Falls Blvd.
Spokane, WA 99201
Submitted via email: PlanSpokane@spokanecity.org
Dear Staff and Consulting Team:
Thank you for the opportunity to comment on the Draft Environmental Impact Statement for the City of Spokane Comprehensive Plan Update 2026-2046 (PlanSpokane). Futurewise agrees with the City's decision to prepare an environmental impact statement (EIS). The comprehensive plan and the development it will authorize is likely to have a significant probable adverse impact on the environment.
Futurewise is a Washington State nonprofit organization that works to advance healthy, equitable, and opportunity-rich communities through smart land use policy and advocacy. We appreciate the City of Spokane's substantial investment in developing a thoughtful and ambitious Comprehensive Plan update, and we write to offer constructive comments on the Draft Environmental Impact Statement (DEIS).
In addressing the adequacy of a nonproject EIS, the Court of Appeals wrote that:
In Leschi v. Highway Comm'n, 84 Wn.2d 271, 525 P.2d 774 (1974), a majority of the Supreme Court held that the adequacy question is one of law, subject to de novo review by the courts. The test to be applied is "whether the environmental effects of the proposed action and reasonable alternatives are sufficiently disclosed, discussed and that they are substantiated by supportive opinion and data." Leschi v. Highway Comm'n, supra at 286, 525 P.2d at 785. 1
Ullock v. City of Bremerton, 17 Wn. App. 573, 580, 565 P.2d 1179, 1184 (1977).
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WAC 197-11-440(6)(a) requires that for the elements of the environment significantly affected by the proposed action, "the EIS shall describe the existing environment that will be affected by the proposal, analyze significant impacts of alternatives including the proposed action, and discuss reasonable mitigation measures that would significantly mitigate these impacts." WAC 197-11-442 (1) provides that the lead agency shall have more flexibility in preparing EISs on nonproject proposals. WAC 197-11-442(2) also provides that for nonproject EISs
[t]he lead agency shall discuss impacts and alternatives in the level of detail appropriate to the scope of the nonproject proposal and to the level of planning for the proposal. Alternatives should be emphasized. In particular, agencies are encouraged to describe the proposal in terms of alternative means of accomplishing a stated objective (see WAC 197-11-060(3)). Alternatives including the proposed action should be analyzed at a roughly comparable level of detail, sufficient to evaluate their comparative merits (this does not require devoting the same number of pages in an EIS to each alternative).
As is documented below, the DEIS may not comply with these requirements for several elements of the environment.
Transportation Analysis: Per Capita VMT Baseline Comparison and the Environmental Case for Alternative 2
We commend the City for using the SRTC regional travel demand model and for presenting VMT per capita as a key comparative metric. This is the right framework for evaluating the land use-transportation nexus at a programmatic scale. However, we identify two significant gaps in the transportation analysis that should be addressed in the Final EIS
The Final EIS should compare per capita VMT under each alternative against existing conditions to demonstrate compliance with RCW 36.70A.070(9)(d)(i)(B).
RCW 36.70A.070(9)(d)(i)(B) requires that the greenhouse gas emissions reduction sub element of the comprehensive plan identify actions that will result in "reductions in per capita vehicle miles traveled within the jurisdiction." This is a mandate to demonstrate actual reductions from current conditions - not merely reductions relative to a No Action baseline.
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The DEIS presents per capita VMT for 2046 across alternatives, with Alternative 2 at 19.2 and Alternative 3 at 19.8 (DEIS pp. 3-277, 3-280), both compared only against the No Action alternative at 19.9. However, the DEIS does not present existing per capita VMT - whether using the 2022 GHG inventory baseline or another current year - alongside those 2046 projections.
Without that comparison, it is impossible to determine whether either action alternative would actually achieve the per capita VMT reductions that RCW 36.70A.070(9)(d)(i)(B) requires. The statute mandates reductions from current conditions, not merely performance better than No Action. A plan that reduces VMT relative to the No Action scenario but leaves per capita VMT at or above today's levels would not satisfy that statutory requirement.
This gap is particularly consequential because the DEIS's GHG reductions are driven primarily by statewide policies - the 2035 internal combustion engine ban and the 2045 clean electricity mandate - rather than by Spokane's land use decisions. If per capita VMT under either action alternative is projected to remain at or above today's levels, that is a material finding that must appear in the Final EIS and must be addressed in the Climate Element.
The Preferred Alternative should more fully account for the environmental significance of the VMT difference between Alternative 2 and Alternative 3.
Beyond the baseline comparison issue, the DEIS concludes that "no significant impact to mode share or VMT is expected" under either action alternative, using identical findings for both. This conclusion obscures a meaningful environmental difference between the alternatives that decision-makers should have before them.
The DEIS's own data shows:
- Alternative 2 (Distributed & Balanced): Daily VMT (2046), 5,732,000; VMT per capita, 19.2
- Alternative 3 (Center City & Regional Hubs): Daily VMT (2046), 5,916,000; VMT per capita, 19.8
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Alternative 2 produces approximately 184,000 fewer vehicle miles traveled every weekday than Alternative 3. Annualized over 320 weekdays, this is roughly 59 million fewer VMT per year. Given that transportation accounted for 41% of Spokane's 2022 community GHG emissions, this difference carries material climate significance. The DEIS acknowledges that Alternative 2 produces the lowest transportation emissions of any alternative (DEIS p. 3-49), yet the transportation impact findings treat both action alternatives as equivalent. The driver of this gap is Alternative 3's continued concentration of employment in industrial hubs at West Plains/Airport and Northeast/Hillyard - areas with limited transit access - which generates longer trip lengths and higher total VMT. This is precisely the land use-transportation tradeoff that a programmatic EIS should illuminate for decision-makers, and the Preferred Alternative and Final EIS should quantify the cumulative annual GHG emissions difference attributable to this VMT gap.
Water Resources and Aquifer Protection
The Spokane Valley-Rathdrum Prairie Aquifer is a federally designated sole-source aquifer and deserves commensurate analysis in the Final EIS.
The DEIS acknowledges that the City of Spokane's water supply depends on the Spokane Valley-Rathdrum Prairie Aquifer, which is designated by the U.S. Environmental Protection Agency as a "sole source aquifer" - meaning it is the sole or principal drinking water source for the area and has no reasonably available alternative should it become contaminated (DEIS p. 3-20).
The DEIS also notes that, as a result of an August 2025 ballot measure, the Spokane Valley-Rathdrum Prairie Aquifer Protection Area will be expanded beginning January 1, 2026 to include all areas within the City boundary - an area that previously had no protection area coverage at all. This is a significant change to the regulatory landscape that the Final EIS should fully integrate.
Despite these facts, the DEIS does not include a cumulative impact analysis of how the growth projected under each alternative would affect aquifer recharge rates, impervious surface additions over Critical Aquifer Recharge Areas, or the long-term sustainability of the water supply. The DEIS references a 2025 environmental code audit recommending review of Spokane Municipal Code Section 17E.010 (Critical Aquifer Recharge Area regulations) and lists aquifer protection as a potential mitigation measure, but does not commit to implementing those recommendations or explain how they would be triggered (DEIS pp. 3-30-3-32).
Given that this aquifer supplies more than 50% of the drinking water for the Spokane-Coeur d'Alene metropolitan area and has no reasonable alternative source, the applicable legal standard for protection is correspondingly high. The GMA requires comprehensive plans to "provide for protection of the quality and quantity of groundwater used for public water supplies." RCW 36.70A.070(1). The GMA also requires counties and cities to designate and protect aquifer recharge areas and adopt measures to prevent groundwater contamination and overuse. RCW 36.70A.170; RCW 36.70A.060(2).
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The Final EIS should assess whether existing water rights are sufficient to serve projected growth under each alternative.
The DEIS presents water demand projections by pressure zone through 2042 (DEIS pp. 3-331-3-333) but does not assess whether the City's existing water rights portfolio is sufficient to meet that projected demand. This is an important gap. As Washington State Department of Ecology water resources staff have documented, all of Washington's water is already allocated to a water user - meaning that new demand can only be met through existing water rights, water conservation, or market transactions. In Eastern Washington specifically, groundwater levels are declining in most aquifer layers, and the Lower and Middle Spokane watersheds are projected to experience increasing summer demand against decreasing summer supply, as was scene last summer.
A programmatic EIS that projects significant population and employment growth through 2046 without analyzing whether legally and physically available water exists to serve that growth is analytically incomplete. The Final EIS should confirm whether the City's existing water rights are sufficient to serve the projected growth under each alternative, and if not, what water supply strategy the City proposes to address that gap.
The Final EIS should specifically analyze the interaction between projected West Plains growth and the identified PFAS contamination in that area.
The DEIS identifies per- and polyfluoroalkyl substances (PFAS) contamination in private-well groundwater in the West Plains region of the city (DEIS pp. 3-13 to 3-14). Both Alternatives 2 and 3 contemplate growth and employment concentration in the West Plains/Airport area. The Final EIS should specifically analyze how projected growth in that subarea interacts with the identified PFAS contamination, and what regulatory tools the City will use to protect groundwater quality in the expanded Aquifer Protection Area.
Higher-density, compact growth supports aquifer sustainability - an additional environmental advantage of Alternative 2.
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Research demonstrates that higher-density, multifamily housing types use significantly less water per capita than large-lot, low-density development - both indoors and outdoors. The U.S. EPA has documented that compact growth, by reducing service line lengths and outdoor irrigation demands, can reduce total residential water demand by 5-25% over lower-density alternatives. Alternative 2's greater emphasis on multifamily housing and its distributed centers-and-corridors approach means it would likely generate less per capita water demand than Alternative 3's higher employment growth scenario. The Final EIS should quantify this difference as part of the utilities analysis.
Housing Element: HB 1220 Compliance and Displacement Risk
We commend the City for conducting and publishing a racially disparate impacts analysis in September 2025. The findings - documenting persistent BIPOC homeownership gaps, the legacy of exclusionary zoning and redlining, environmental health disparities, and uneven distribution of housing growth - are honest and substantive. This positions Spokane well for a GMA-compliant housing element.
First, the Final Plan should demonstrate housing capacity disaggregated by income band.
HB 1220 requires that jurisdictions plan for and accommodate housing affordable to all income levels, and that the housing element document adequate provisions for extremely low, very low, low, and moderate-income households specifically. The DEIS references capacity for "all income levels" and HB 1220 compliance in general terms. The Final Plan's housing element should include a table confirming that sufficient zoned and buildable capacity exists for each income tier, consistent with Commerce's Housing Element guidance.
Second, the Final Plan's policy response should match the strength of the disparate impacts diagnosis.
RCW 36.70A.070(2)(e)-(h) requires jurisdictions to "implement policies and regulations that begin to undo" identified racially disparate impacts. We encourage the Final Plan to include specific, mandatory anti-displacement tools such as: targeted rezoning in historically excluded neighborhoods rather than only high-opportunity areas; affordable housing preservation requirements in high-displacement-risk areas; and explicit linkage between the Target Investment Area strategy and affordability outcomes for BIPOC households.
Climate Element: Strengthening Local Policy Commitments
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The DEIS GHG analysis uses a 2022 baseline and presents projections against the City's adopted reduction targets (45% by 2030, 70% by 2040, net-zero by 2050). We support this framework. However, as noted in Section I above, the heavy reliance on statewide EV and electricity mandates to drive projected reductions raises a fundamental question about local accountability: what does Spokane's own plan contribute?
RCW 36.70A.070(9)(d)(i)(A) requires that the Climate Element identify actions that will result in "reductions in overall greenhouse gas emissions generated by transportation and land use within the jurisdiction." The Final EIS should include a "policy wedge" analysis isolating the GHG reductions attributable to Spokane's specific land use decisions - infill siting, TOD density, parking reform, TDM requirements - from the reductions that would occur regardless under state law. This analysis is recommended by Commerce's climate planning guidance and is necessary for the Climate Element to demonstrate independent compliance with RCW 36.70A.070(9)(d)(i)(A).
We also encourage the Final Plan's Climate Element to include specific implementation commitments rather than exploratory language. Rather than "the City will consider TDM strategies," the plan should commit to adopting specific TDM standards, parking reform, and building decarbonization regulations by a date certain. Alternative 2's lower VMT profile and higher multifamily share position it well to support these commitments.
Conclusion
Our core recommendations are: (1) the Final EIS should present existing per capita VMT alongside the 2046 alternative projections, so decision-makers can evaluate compliance with RCW 36.70A.070(9)(d)(i)(B)'s requirement for actual reductions from current conditions; (2) the Final EIS should include cumulative aquifer impact analysis and confirm water rights sufficiency for projected growth, consistent with the January 2026 expansion of the Aquifer Protection Area; (3) the Final Plan's housing element should disaggregate capacity by income band and include binding anti-displacement tools; and (4) the Climate Element should isolate Spokane's own policy contributions to GHG reduction and include a binding implementation schedule.
On alternative selection, we encourage the City to give full weight to the environmental advantages that Alternative 2 demonstrates across transportation, GHG emissions, water demand, and housing affordability, and to make those advantages explicit in the preferred alternative selection rationale. We look forward to continued engagement as the City moves toward Final EIS and Final Plan adoption.
Thank you for considering our comments.
Thank you for considering our comments.
[Professional contact details omitted from the reading text.]
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- RCW 36.70A.070(1): Comprehensive plan land use element must provide for protection of the quality and quantity of groundwater used for public water supplies.
- RCW 36.70A.170 and RCW 36.70A.060(2): Critical areas designation and protection requirements, including aquifer recharge areas.
- Washington State Department of Commerce, Guidance for Updating Your Housing Element:
Updated Housing Element Requirements with HB 1220 (Book 2, August 2023, updated September 2024). Available at: https://www.commerce.wa.gov/serving-communities/growth-management/growth-management-topics/housing/.
- Washington State Department of Commerce, Guidance to Address Racially Disparate Impacts: Updating Your Housing Element to Address New Requirements (Book 3, April 2023). Available at: https://www.commerce.wa.gov/serving-communities/growth-management/growth-management-topics/housing/.
Water Resources - U.S. Environmental Protection Agency, Sole Source Aquifer Program: Spokane Valley-Rathdrum Prairie Sole Source Aquifer. Available at: https://www.epa.gov/dwssa.
Referenced in DEIS Section 3.1.1 (p. 3-20).
- Hall, S.A., Adam, J.C., Yourek, M.A., et al., 2021 Washington State Legislative Report:
Columbia River Basin Long-Term Water Supply and Demand Forecast (Publication No. 21-12-006, Washington Department of Ecology, 2022). Available at:
https://apps.ecology.wa.gov/publications/SummaryPages/2112006.html.
Documents declining groundwater levels in most aquifer layers and subareas across eastern
Washington, and projected summer supply decreases in the Lower and Middle Spokane watersheds.
- State of Washington Department of Ecology, Water Resources Program, WRIA Watershed Water Availability publications. Available at: https://ecology.wa.gov/water-shorelines/water-supply/water-availability/in-your-watershed.
Documents water availability limitations throughout the Lower Spokane, Little Spokane, Hangman, and Middle Spokane watersheds.
- Washington State Department of Health, PFAS Testing Results Dashboard (last accessed February 2026). Available at: https://doh.wa.gov/data-and-statistical-reports/washington-tracking-network-wtn/pfas/dashboard.
See also DEIS Exhibits 3.1-13 and 3.1-14 (PFAS contamination in West Plains private wells).
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- Swanson, Conrad, "Trump keeps talking about taking PNW water - is that possible?" The Seattle Times (Updated February 23, 2025). Available at:
https://www.seattletimes.com/seattle-news/climate-lab/trump-keeps-talking-about-taking-pnw-water-is-that-possible/. Citing Ria Berns, Washington State Department of Ecology Water Resources Program Manager, on full allocation of Washington's water resources.
- U.S. Environmental Protection Agency, Growing Toward More Efficient Water Use: Linking Development, Infrastructure, and Drinking Water Policies (EPA 230-R-06-001, January 2006). Available at: https://www.epa.gov/smartgrowth/growing-toward-more-efficient-water-use.
Cited for research showing higher-density, compact development reduces per capita water demand by 5-25% compared to low-density alternatives.
- Sampson, D.A., Quay, Ray, and Horrie, Mitch, "Building type, housing density, and water use: Denver Water data and agent-based simulations," 58 Journal of the American Water Resources Association 355 (2022).
Available at:
https://asu.elsevierpure.com/en/publications/building-type-housing-density-and-water-use-denver-water-data-and. Peer-reviewed study documenting per capita water demand differences by housing type and density.
Transportation and Climate Science
- Cascadia Consulting Group, Greenhouse Gas Emissions Analysis for City of Spokane Comprehensive Plan Update EIS (2025).
Referenced in DEIS Section 3.2, Exhibit 3.2-8.
Source for finding that Alternative 2 produces the lowest energy and transportation emissions across all alternatives.
- Zhang, Lei, Hong, Jinhyun, Nasri, Arefeh, and Shen, Qing, "How built environment affects
travel behavior: A comparative analysis of the connections between land use and vehicle miles traveled in US cities," 5 Journal of Transport and Land Use 40 (2012).
Available at:
https://www.jtlu.org/index.php/jtlu/article/view/266.
Peer-reviewed study documenting that increases in density reduce per capita vehicle miles traveled, with more pronounced effects in higher-density areas.
- Goldstein, Benjamin, Gounaridis, Dimitrios, and Newell, Joshua P., "The carbon footprint of household energy use in the United States," 117 Proceedings of the National Academy of
Sciences 19122 (August 11, 2020).
Available at:
https://www.pnas.org/content/117/32/19122.
Peer-reviewed study documenting that meeting necessary GHG reductions requires higher residential densities, achievable through a mix of small apartment buildings and modest single-family homes.
- Kuss, Paula and Nicholas, Kimberly A., "A dozen effective interventions to reduce car use in European cities: Lessons learned from a meta-analysis and transition management," 10 Case Studies on Transport Policy 1494 (Issue 3, September 2022).
Available at:
https://www.sciencedirect.com/science/article/pii/S2213624X22000281. Peer-reviewed meta-analysis identifying effective strategies to reduce vehicle use, including TDM measures, parking reform, and land use density.