Luke Tolley - Community Assembly
Feb 24, 2026
Neighborhood Groups
[PDF page 1 of 9]
Hello,
At our February 5th Community Assembly meeting, the Assembly approved the recommendation from our Land Use Committee to forward these comments and questions in regard to the PlanSpokane 2046 Draft EIS Comments.
I have also attached a more in depth analysis that the committee created.
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 It does mention reliance on Neighborhood Action Plans, but many of those are either outdated and in some cases are non-existent.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.
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.
[PDF page 2 of 9]
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.
In Community,
Thank you.
Luke Tolley
Community Assembly Administration Committee Chair
he/his
Hillyard, Spokane, Washington
[Professional contact details omitted from the reading text.]
[PDF page 3 of 9 begins within the following paragraph.]
Questions and Comments on the Environmental Impact Statement
Linda L. Carroll, Ph.D.
Nominee, Community Assembly Liaison to Plan Commission
The questions and comments in the first section are general ones concerning the Statement and procedures involving it. The second section focuses on specific details.
General Comments and Questions
1. What is the role of Neighborhood Councils and of the Community Assembly, the city's constituted bodies for residents' expression concerning governance issues, in responding to the Environmental Impact Statement and in the choice of the Preferred Alternative by "Community and Decision Makers" (p. 507; Chapter 5 Appendix A, PlanSpokane Community Visioning Engagement Summary, p. 11)? The report utilizes as its basic area units the Neighborhood Council boundaries and relies on Neighborhood Action Plans formulated by the respective Neighborhood Councils.
2. If current mechanisms (e.g. permitting) are inadequate for ensuring that the Preferred Alternative is followed by the private interests that will be building housing, what provisions will the city make for enacting its tenets? For example, what are the City's options if the owner of a parcel of land on/near a bus rapid transit route prefers to leave it as an empty lot (its current state) rather than build affordable multi-family housing on it? (Councilmember Klitzke's idea concerning taxation for vacant properties addresses the issue.)
3. Why is the very important role of the demolition of current housing not mentioned until p. 55 of the Environmental Impact Statement? That statement refers vaguely to "over twice as many housing units" demolished under Alts 2 and 3 as compared to Alt 1--the actual numbers are not given until p. 285 (Alt 1 849, Alt 2 1,697, Alt 3 1,698).
That section (Residential Displacement, pp. 284-86) provides a more detailed discussion of projected demolitions. It notes the potential that lower-income residents' rate of home ownership will be reduced by the demolition of single-family owned homes in favor of multi-family rental property.
And, while note 9 on p. 284 asserts that "development is more likely to occur on vacant lots or those with no existing homes," it is entirely possible instead that owners of vacant properties on corridors will not be interested in constructing affordable multi-family dwellings.
That will then increase pressure to demolish single-family homes in the contiguous quarter-mile included in the corridor designation in favor of multi-family dwellings. The Neighborhood Councils and the Community Assembly should evaluate the very extensive conclusion (p. 303) to this section (3.5): "Over time, additional growth and development will occur through redevelopment as well as on vacant land.
The alternatives vary based on the types and geographic pattern of existing housing and businesses that may be demolished and replaced by new growth.
While this can contribute to the risk of physical displacement, the benefits in terms of reduced economic displacement pressure and increased production of affordable units offered by the action alternatives would address affordability in the marketplace, and the City's new policies and codes would address anti-displacement measures.
Therefore,
[PDF page 4 of 9 begins within the following paragraph.]
no significant unavoidable adverse impacts to population, employment, or housing are expected under any alternative."
4. Although the consideration of future exemptions to the thresholds is located at the very end of the file because it was originally a separate document (Appendix E, pp. 594- 614 and especially pp. 609-14 of pdf), it carries enormous implications for the Environmental Impact Statement. The projected impact of the contemplated exemptions is extensive. 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 a number of neighborhoods; for example, all of Emerson-Garfield would become a corridor. Exh. 7 p. 614 shows that if extended to Phase 2, the "SEPA Proposed Infill / Categorical Exemption Area" would include the entire city.
5. Given that the Environmental Impact Statement envisions that the three alternatives will result in no increased use of transit and only a tiny increase in use of active transportation (Chapter 3, section 7, esp. pp. 386, 390, 393, 399), is the City doing enough to reduce the use of personal vehicles that is the source of a large proportion of many pollutants? See pp. 164-65 for some additional possible measures.
6. Given that this is an Environmental Impact Statement, more of the information concerning "Environment, Impacts, and Mitigation Measures" (Section 3, beginning on p. 114 of the pdf) should be included in the preceding two sections (Section 1 "Summary"; Section 2 "Proposal and Alternatives"), which give almost all of their space to issues of housing, jobs, and transportation. For example, Section 1.4.1 "Earth, Water Quality, and Water Resources" does not contain a single reference to the aquifer that is vital to our region.
7. How will the Plan be affected by the current numerous and profound attempts to reduce and eliminate environmental considerations, incentives, and regulations at the federal level?
8. The narrative, much of which is written in general terms, would benefit from examples of the concrete details given in the exhibits.
9. Citizen comments from outreach sessions included in an Appendix showed a wide preference for combining features of Alternative 2 and Alternative 3 rather than choosing one of the three Alternatives presented. What plans are there for making one or more combined models?
10. What opportunities will there be over the twenty years of the alternative's duration for course correction of any problems that may develop?
Comments on specifics
(page numbers refer to the union pdf; in some cases, numbers referring to the section of the report are also given).
pp. 88-89 (2.16-17) The authors of the Environmental Impact Statement concerning population stipulate a growth range of 25,157-50,650 (4,000-29,000 greater than the state assumption) based on the assumption that the current household size of 2.33 will continue through 2046. On what research do the authors base their assumption? In the next section, they set forth the statistics on household size by dwelling type, which establishes that the dwelling types that the Environmental Impact Statement proposes to increase correlate with smaller households. The assumption that household size will remain the same calls for more single-family dwellings.
[PDF page 5 of 9]
pp. 89-90 (2.17-18) According to the authors, "it is assumed" that allowing more multifamily housing in certain designated areas means that "over 5,400 attached multiunits could be expected." What happens if current owners do not want to construct those kinds of housing and do not want to sell to someone who does?
p. 92 (2.20) What land use and development regulations need to be modernized and in what way?
Specifics are needed.
p. 93 (2.21) In what ways will the anticipated "unified development code and GIS-based zoning map" be "enforceable"?
p. 93 (2.21) need for examples or specifics of strategies to "simplify and expedite development review and permitting processes while ensuring predictable outcomes and consistent application." If they occur later in the report, a cross reference is needed.
p. 93 (2.21) "Engage Stakeholders and the Public" What is the role of Community Assembly and Neighborhood Councils, the city's constituted bodies for residents' expression concerning governance issues, especially in the anticipated "Preferred Alternative Selection" by "Community and Decision Makers" (p. 507; Chapter 5 Appendix A, PlanSpokane Community Visioning Engagement Summary, p. 11)?
pp. 114-464 Chapter 3 This is the Environmental Impact Statement proper.
p. 138 more jobs=greater [negative] impact on environment pp. 145ff 3.2 Air Quality and Greenhouse Gas Emissions p. 150 from 2016 to 2025, increased population and increased consumption of fossil fuels and refrigerants resulted in increased emissions p. 155 expansion of road system, such as North Spokane Corridor, will result in higher levels of pollution p. 157 The report cites three sources for assessing and visualizing pollutant levels in Spokane but does not provide, here or elsewhere, URLs or other means of locating them.
pp. 158-59 in all three scenarios, the large amount of pollutants emitted by energy consumption and vehicles will create air quality issues and burdens throughout the city and especially for those parts which are already suffering because of their proximity to sources of pollution, such as Hillyard, Lincoln Heights, and Chief Garry Park.
p. 160 Given the termination of the federal EV purchase credit, it is unlikely that great reductions of emissions from vehicles will be achieved.
If the current mix of internal combustion-EV vehicles remains unchanged, emissions will increase by about 40% by 2046 for all three Alternatives (535,500 to 714,036 Alt 2 or 737,853 Alt 3).
p. 161 and below, esp. 166 Given the termination of clean-energy projects by the federal government, will the state and city clean-electricity mandates remain in place unchanged?
p. 162 "Alternative 2 results in the lowest energy and transportation emissions across all scenarios."
p. 166 3.2.4 Can the expectation of "[n]o significant unavoidable adverse impacts on air quality and GHG emissions" be maintained in the face of the cancellation of many clean-air projects and incentives by the federal government?
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p. 172 numerous threats to habitat and water quality, including by the numerous local dams, high sediment levels, loss of riparian forest, high water temperatures, runoff from treatments to vegetation for agriculture and yard purposes, stormwater and wastewater, non-native plants pp. 174-75, 177-80 identification-description of a large priority habitat area that extends around southwest Spokane and areas of the extremely rare and disappearing shrub-steppe habitat vital to certain iconic species in Five Mile Prairie, Hillyard, western portion of West Plains. [We must exert all effort needed to preserve these habitats.] p. 183 All alternatives predict population growth and therefore increased damage to habitats.
pp. 184-86 Although the conclusions for the three Alternatives are identical ("As a result, Alternative 1 would result in less than significant impacts to plants and animals"; "As a result, Alternative 2 would result in less than significant impacts to plants and animals."; "The effects of Alternative 3 on plants and animals would therefore be negligibly different from Alternative 2.
As a consequence, while it would have adverse effects, Alternative 3 would result in less than significant impacts to plants and animals."), a comparison of the three discussions makes it clear that Alternatives 1 and 3 would have greater harmful effects on wildlife habitat than Alternative 2.
p. 219 How is 'underutilized' defined with regard to property upon which more housing could be built?
pp. 221, 223 On p. 221, Corbin Park is listed as both a local and a National Historic District; on p. 223 it is referred to only as a local historic district.
Which is correct?
p. 225 The "Existing Transportation-Related Noise" map incorrectly omits Division Street (Division-Ruby couplet) from consideration even though it easily produces as much noise as the Maple-Ash couplet.
p. 226 The list of areas especially affected by noise pollution omits Northwest Spokane, home of the Great Northwest Spokane Street Speedway (Division, Ruby, Post, Monroe, Maple-Ash, Northwest Blvd; Wellesley, Francis, Indiana, Boone, etc.).
Under the current mayoral administration and police chief, the issues it generates are being addressed, but it would be prudent for the City to put lasting measures in place.
pp. 232-35 "Land Use Patterns and Compatibility" "Urban Form" important sections for Neighborhood Councils to review p. 245 "All the alternatives have the potential for significant adverse impacts to cultural resources in the analysis areas."
p. 258 The table evaluates 29 current city policies with regard to their supportiveness of increased housing but gives no list.
Which specific policies are these?
p. 266 Commercial Building Conversion: Is the entire building required to be converted to housing or may a part of it remain commercial?
p. 282-83 Exhibit 3.5-33 Housing Action Plan Strategies Advanced Under Alternatives.
This section is an important one for Neighborhood Councils to review, as the strategies will impact the neighborhood and neighborhood residents, especially features such as attention to the impact of the short-term rental market on affordable housing, preserving the viability of existing home ownership for low-income residents.
p. 284 What is the factual basis for the claim that "new development is more likely to occur on vacant parcels or those with no existing homes (such as an empty parking lot or strip mall)"?
[PDF page 7 of 9 begins within the following paragraph.]
There is a string of parcels with no housing along Division Street between Mission and Bridgeport that has remained unbuilt even after the city's recent change in designations and zoning.
p. 291 Why is North Division with its string of empty lots omitted from the list of streets with redevelopable properties in Alternative 1?
p. 303 The concluding sentence of the following quotation should be evaluated by Neighborhood Councils and the Community Assembly: "Over time, additional growth and development will occur through redevelopment as well as on vacant land.
The alternatives vary based on the types and geographic pattern of existing housing and businesses that may be demolished and replaced by new growth.
While this can contribute to the risk of physical displacement, the benefits in terms of reduced economic displacement pressure and increased production of affordable units offered by the action alternatives would address affordability in the marketplace, and the City's new policies and codes would address anti-displacement measures.
Therefore, no significant unavoidable adverse impacts to population, employment, or housing are expected under any alternative."
pp. 317 ff Neighborhood and Subarea Plans here and following.
pp. 317-18 Emerson-Garfield.
pp. 337-41 3.6-9 through 3.6.12 The estimates made by the authors of the report as to the effect of each of the three Alternatives in carrying out the Action Plan of each neighborhood that has one.
Narrative explanations of those estimates follow.
p. 337 discussion of Emerson-Garfield plan p. 347 the Level of Service grades consider vehicle movement only pp. 359-63 Vehicle Network pp. 487ff Chapter 5 Appendices containing the materials used
Appendix A These are the reports from the various outreach sessions and contain a record of comments made by attendees, some of which are excerpted here.
p. 503, 506, 510, 514, 518-20, 522-23, 525 "Staff Vision Re-Write B," which includes "cherishing its unique and vibrant neighborhoods," received the most votes (this appears to be a total of the votes at all three district sessions; however, the total number of votes for all three rewrites was only 100) (p. 503).
A similar request in the survey resulted in a strong expression of preference for B (p. 506). Survey respondents also added "leveraging existing investment" to desired features of the Plan. Attendees at the District 1 session held at Northeast Community Center supported B (p. 510). Attendees at the District 2 session held at Liberty Park Library supported A, but with C receiving only one less vote (p. 514).
Attendees at the District 3 session held at Shadle Park Library supported B (p. 518). They also added "Reuse of history [sic, recte historic] buildings prior to new development" (p. 519) and "do not let land sit unused/vacant" (p. 520) to the Vision. Attendees at the Community-wide session supported B (p. 522).
They added "Focus on [home] ownership to build personal stability and wealth," "How to test the benefits of proposed changes," and "Ensure changes are beneficial to the city at large, not just those heard from" to the Vision (pp. 522-23, 525).
p. 529 "sittable" neighborhoods (places where elderly and disabled may sit); creating (rather than preserving) neighborhood identities; address land speculation (was this incorporated into Plan documents?); Greater civic engagement, involvement, and transparency.
[PDF page 8 of 9]
p. 531 Under suggestions for "Residential Low" designation: "Create a process of neighborhood input on a project-by-project basis for non-standard uses"; "Prioritize adaptive reuse over new development"
p. 531 Under suggestions for "Commercial" designation: "Leverage vacant commercial areas to add business or apartments"
p. 533 "Alternative 2 received the most votes with 25.
Alternative 3 came in second with 7." However, many attendees instead of voting commented on combining desirable features of 2 and 3, with the result that "[t]he Preferred Alternative can be a combination of elements of the different Growth Alternatives, with these comments providing direction on what aspects were viewed positively from each Alternative." In 2, connectedness appealed; in 3 the emphasis on the Center City appealed.
pp. 534, 536 "No mixed-use in neighborhoods, concerned over exploitative development"; "Create protections against displacement in Chief Garry Park around City Line stops" (p. 534); "Recognition of limits to growth" (p. 536)
pp. 540, 541, 544 suggestions from attendees at District 1 "Future Growth and Guiding Policies Community Workshop" (approximately 22 attendees): "More Civic Engagement"; "Incentives for empty properties on Division following BRT implementation"; "Continue partnerships with housing services and neighborhood councils" (p. 540).
Alternative 2 preferred (p. 541).
"Prioritize policies with city action rather than informational or "encouraging" resident action" (p. 544).
pp. 545, 546, 548, 549, 550 suggestions from attendees at District 2 "Future Growth and Guiding Policies Community Workshop" (approximately 40 attendees): "Don't use broad terms in Comprehensive Plan"; concern about "corporate rental ownership" and request to "Control rents" (p. 545).
"Allow neighborhood input on a project-by-project level for other uses"; "Prioritize historic/adaptive reuse over new development (both commercial and residential)"; though Alternative 2 received the most votes, many did not vote but instead identified desirable and undesirable features of the various alternatives, such as that high density is isolating and large developments should have traffic lights at the exit (p. 546); no mixed use in neighborhoods, protect neighborhood from exploitive development (p. 548); "Enable neighborhoods to create more social capital and be able to take action and help issues"; "Need to have an acknowledgement of growth/our limits" (p. 549); "Recognize limits to growth" (p. 550)
pp. 552, 553, 554 suggestions from attendees at District 2 "Future Growth and Guiding Policies Community Workshop" (approximately 40 attendees): "for elderly and disabled residents, walkable also means sittable"; "sidewalk safety (e.g. electric scooters and conflicts with pedestrians" (p. 552); "Density transition: no high-rise next to single unit homes"; "Vacant lots, parking lots sitting unused" (p. 553).
Although Alternative 2 received the largest number of votes, most attendees instead highlighted desirable features of various alternatives: repeated emphasis on development of downtown; preference for preservation of historic buildings, revitalization and reuse; "Like a multi-block approach to intensities (like Alt 3 downtown) over less depth along transit lines" (p. 554)
pp. 559, 561, 563, 564 suggestions from attendees at City-Wide "Future Growth and Guiding Policies Community Workshop" (approximately 35 attendees): "Address land speculation" (p. 559).
[PDF page 9 of 9 begins within the following paragraph.]
Although Alternative 2 received the largest number of votes, most attendees preferred to comment on desirable features of the various alternatives (p. 561). "On Washington, Howard, and Post, flip bike lane and parking"; "Push Monroe Road Diet down to Kendall Yards" (p. 563). Various suggestions to preserve natural green areas, parks, and animal species (pp. 563-64).
Appendix E Environmental Review Exemptions to Promote Infill Development and Housing, prepared by BERK Consulting (i.e. the consultant whose field of expertise is housing, not the two consultants whose fields of expertise are aspects of the environment).
p. 594 refers to exemptions from new environmental review of development where "probable adverse environmental impacts have been adequately addressed by local regulations and that the City's Comprehensive Plan was previously subject to an Environmental Impact Statement": this exemption is based on probability, not on verified facts; new development could result in new environmental impacts p. 596 how are "adequately" and "non-significance" defined?
p. 598 Exhibit 2 gives an outline of the City's current choice of intermediary amounts of residential units, commercial units, and excavation/landfill but then states "The City could adopt higher thresholds, which could vary by use or different geographic areas, and mixed-use projects." See pp. 610ff Potential Infill Exemption Location for areas where there is the greatest reason for the City to adopt higher thresholds.
pp. 610ff Potential Infill Exemption Location.
It is clear from Exhibits 4, 5, 6, and 7 in this section that the areas of the city that will most likely be considered for the first exemptions are located in neighborhoods developed in the early 20th century and that are currently residential with predominantly single-family housing.
Exh. 7 makes it clear that if the city moves to Phase 2, the entire city will be included in the "SEPA Proposed Infill / Categorical Exemption Area."
Luke Tolley - Community Assembly
Feb 24, 2026
Neighborhood Groups
[PDF page 1 of 9]
Hello,
At our February 5th Community Assembly meeting, the Assembly approved the recommendation from our Land Use Committee to forward these comments and questions in regard to the PlanSpokane 2046 Draft EIS Comments.
I have also attached a more in depth analysis that the committee created.
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.
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.
[PDF page 2 of 9]
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.
In Community,
Thank you.
Luke Tolley
Community Assembly Administration Committee Chair
he/his
Hillyard, Spokane, Washington
[Professional contact details omitted from the reading text.]
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ATTACHMENT / ADDITIONAL PAGES
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[PDF page 3 of 9 begins within the following paragraph.]
Questions and Comments on the Environmental Impact Statement
Linda L. Carroll, Ph.D.
Nominee, Community Assembly Liaison to Plan Commission
The questions and comments in the first section are general ones concerning the Statement and procedures involving it. The second section focuses on specific details.
General Comments and Questions
1. What is the role of Neighborhood Councils and of the Community Assembly, the city's constituted bodies for residents' expression concerning governance issues, in responding to the Environmental Impact Statement and in the choice of the Preferred Alternative by "Community and Decision Makers" (p. 507; Chapter 5 Appendix A, PlanSpokane Community Visioning Engagement Summary, p. 11)? The report utilizes as its basic area units the Neighborhood Council boundaries and relies on Neighborhood Action Plans formulated by the respective Neighborhood Councils.
2. If current mechanisms (e.g. permitting) are inadequate for ensuring that the Preferred Alternative is followed by the private interests that will be building housing, what provisions will the city make for enacting its tenets? For example, what are the City's options if the owner of a parcel of land on/near a bus rapid transit route prefers to leave it as an empty lot (its current state) rather than build affordable multi-family housing on it? (Councilmember Klitzke's idea concerning taxation for vacant properties addresses the issue.)
3. Why is the very important role of the demolition of current housing not mentioned until p. 55 of the Environmental Impact Statement? That statement refers vaguely to "over twice as many housing units" demolished under Alts 2 and 3 as compared to Alt 1--the actual numbers are not given until p. 285 (Alt 1 849, Alt 2 1,697, Alt 3 1,698).
That section (Residential Displacement, pp. 284-86) provides a more detailed discussion of projected demolitions. It notes the potential that lower-income residents' rate of home ownership will be reduced by the demolition of single-family owned homes in favor of multi-family rental property.
And, while note 9 on p. 284 asserts that "development is more likely to occur on vacant lots or those with no existing homes," it is entirely possible instead that owners of vacant properties on corridors will not be interested in constructing affordable multi-family dwellings.
That will then increase pressure to demolish single-family homes in the contiguous quarter-mile included in the corridor designation in favor of multi-family dwellings. The Neighborhood Councils and the Community Assembly should evaluate the very extensive conclusion (p. 303) to this section (3.5): "Over time, additional growth and development will occur through redevelopment as well as on vacant land.
The alternatives vary based on the types and geographic pattern of existing housing and businesses that may be demolished and replaced by new growth.
While this can contribute to the risk of physical displacement, the benefits in terms of reduced economic displacement pressure and increased production of affordable units offered by the action alternatives would address affordability in the marketplace, and the City's new policies and codes would address anti-displacement measures.
Therefore,
[PDF page 4 of 9 begins within the following paragraph.]
no significant unavoidable adverse impacts to population, employment, or housing are expected under any alternative."
4. Although the consideration of future exemptions to the thresholds is located at the very end of the file because it was originally a separate document (Appendix E, pp. 594- 614 and especially pp. 609-14 of pdf), it carries enormous implications for the Environmental Impact Statement. The projected impact of the contemplated exemptions is extensive. 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 a number of neighborhoods; for example, all of Emerson-Garfield would become a corridor. Exh. 7 p. 614 shows that if extended to Phase 2, the "SEPA Proposed Infill / Categorical Exemption Area" would include the entire city.
5. Given that the Environmental Impact Statement envisions that the three alternatives will result in no increased use of transit and only a tiny increase in use of active transportation (Chapter 3, section 7, esp. pp. 386, 390, 393, 399), is the City doing enough to reduce the use of personal vehicles that is the source of a large proportion of many pollutants? See pp. 164-65 for some additional possible measures.
6. Given that this is an Environmental Impact Statement, more of the information concerning "Environment, Impacts, and Mitigation Measures" (Section 3, beginning on p. 114 of the pdf) should be included in the preceding two sections (Section 1 "Summary"; Section 2 "Proposal and Alternatives"), which give almost all of their space to issues of housing, jobs, and transportation. For example, Section 1.4.1 "Earth, Water Quality, and Water Resources" does not contain a single reference to the aquifer that is vital to our region.
7. How will the Plan be affected by the current numerous and profound attempts to reduce and eliminate environmental considerations, incentives, and regulations at the federal level?
8. The narrative, much of which is written in general terms, would benefit from examples of the concrete details given in the exhibits.
9. Citizen comments from outreach sessions included in an Appendix showed a wide preference for combining features of Alternative 2 and Alternative 3 rather than choosing one of the three Alternatives presented. What plans are there for making one or more combined models?
10. What opportunities will there be over the twenty years of the alternative's duration for course correction of any problems that may develop?
Comments on specifics
(page numbers refer to the union pdf; in some cases, numbers referring to the section of the report are also given).
pp. 88-89 (2.16-17) The authors of the Environmental Impact Statement concerning population stipulate a growth range of 25,157-50,650 (4,000-29,000 greater than the state assumption) based on the assumption that the current household size of 2.33 will continue through 2046. On what research do the authors base their assumption? In the next section, they set forth the statistics on household size by dwelling type, which establishes that the dwelling types that the Environmental Impact Statement proposes to increase correlate with smaller households. The assumption that household size will remain the same calls for more single-family dwellings.
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pp. 89-90 (2.17-18) According to the authors, "it is assumed" that allowing more multifamily housing in certain designated areas means that "over 5,400 attached multiunits could be expected." What happens if current owners do not want to construct those kinds of housing and do not want to sell to someone who does?
p. 92 (2.20) What land use and development regulations need to be modernized and in what way?
Specifics are needed.
p. 93 (2.21) In what ways will the anticipated "unified development code and GIS-based zoning map" be "enforceable"?
p. 93 (2.21) need for examples or specifics of strategies to "simplify and expedite development review and permitting processes while ensuring predictable outcomes and consistent application." If they occur later in the report, a cross reference is needed.
p. 93 (2.21) "Engage Stakeholders and the Public" What is the role of Community Assembly and Neighborhood Councils, the city's constituted bodies for residents' expression concerning governance issues, especially in the anticipated "Preferred Alternative Selection" by "Community and Decision Makers" (p. 507; Chapter 5 Appendix A, PlanSpokane Community Visioning Engagement Summary, p. 11)?
pp. 114-464 Chapter 3 This is the Environmental Impact Statement proper.
p. 138 more jobs=greater [negative] impact on environment pp. 145ff 3.2 Air Quality and Greenhouse Gas Emissions p. 150 from 2016 to 2025, increased population and increased consumption of fossil fuels and refrigerants resulted in increased emissions p. 155 expansion of road system, such as North Spokane Corridor, will result in higher levels of pollution p. 157 The report cites three sources for assessing and visualizing pollutant levels in Spokane but does not provide, here or elsewhere, URLs or other means of locating them.
pp. 158-59 in all three scenarios, the large amount of pollutants emitted by energy consumption and vehicles will create air quality issues and burdens throughout the city and especially for those parts which are already suffering because of their proximity to sources of pollution, such as Hillyard, Lincoln Heights, and Chief Garry Park.
p. 160 Given the termination of the federal EV purchase credit, it is unlikely that great reductions of emissions from vehicles will be achieved.
If the current mix of internal combustion-EV vehicles remains unchanged, emissions will increase by about 40% by 2046 for all three Alternatives (535,500 to 714,036 Alt 2 or 737,853 Alt 3).
p. 161 and below, esp. 166 Given the termination of clean-energy projects by the federal government, will the state and city clean-electricity mandates remain in place unchanged?
p. 162 "Alternative 2 results in the lowest energy and transportation emissions across all scenarios."
p. 166 3.2.4 Can the expectation of "[n]o significant unavoidable adverse impacts on air quality and GHG emissions" be maintained in the face of the cancellation of many clean-air projects and incentives by the federal government?
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p. 172 numerous threats to habitat and water quality, including by the numerous local dams, high sediment levels, loss of riparian forest, high water temperatures, runoff from treatments to vegetation for agriculture and yard purposes, stormwater and wastewater, non-native plants pp. 174-75, 177-80 identification-description of a large priority habitat area that extends around southwest Spokane and areas of the extremely rare and disappearing shrub-steppe habitat vital to certain iconic species in Five Mile Prairie, Hillyard, western portion of West Plains. [We must exert all effort needed to preserve these habitats.] p. 183 All alternatives predict population growth and therefore increased damage to habitats.
pp. 184-86 Although the conclusions for the three Alternatives are identical ("As a result, Alternative 1 would result in less than significant impacts to plants and animals"; "As a result, Alternative 2 would result in less than significant impacts to plants and animals."; "The effects of Alternative 3 on plants and animals would therefore be negligibly different from Alternative 2.
As a consequence, while it would have adverse effects, Alternative 3 would result in less than significant impacts to plants and animals."), a comparison of the three discussions makes it clear that Alternatives 1 and 3 would have greater harmful effects on wildlife habitat than Alternative 2.
p. 219 How is 'underutilized' defined with regard to property upon which more housing could be built?
pp. 221, 223 On p. 221, Corbin Park is listed as both a local and a National Historic District; on p. 223 it is referred to only as a local historic district.
Which is correct?
p. 225 The "Existing Transportation-Related Noise" map incorrectly omits Division Street (Division-Ruby couplet) from consideration even though it easily produces as much noise as the Maple-Ash couplet.
p. 226 The list of areas especially affected by noise pollution omits Northwest Spokane, home of the Great Northwest Spokane Street Speedway (Division, Ruby, Post, Monroe, Maple-Ash, Northwest Blvd; Wellesley, Francis, Indiana, Boone, etc.).
Under the current mayoral administration and police chief, the issues it generates are being addressed, but it would be prudent for the City to put lasting measures in place.
pp. 232-35 "Land Use Patterns and Compatibility" "Urban Form" important sections for Neighborhood Councils to review p. 245 "All the alternatives have the potential for significant adverse impacts to cultural resources in the analysis areas."
p. 258 The table evaluates 29 current city policies with regard to their supportiveness of increased housing but gives no list.
Which specific policies are these?
p. 266 Commercial Building Conversion: Is the entire building required to be converted to housing or may a part of it remain commercial?
p. 282-83 Exhibit 3.5-33 Housing Action Plan Strategies Advanced Under Alternatives.
This section is an important one for Neighborhood Councils to review, as the strategies will impact the neighborhood and neighborhood residents, especially features such as attention to the impact of the short-term rental market on affordable housing, preserving the viability of existing home ownership for low-income residents.
p. 284 What is the factual basis for the claim that "new development is more likely to occur on vacant parcels or those with no existing homes (such as an empty parking lot or strip mall)"?
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There is a string of parcels with no housing along Division Street between Mission and Bridgeport that has remained unbuilt even after the city's recent change in designations and zoning.
p. 291 Why is North Division with its string of empty lots omitted from the list of streets with redevelopable properties in Alternative 1?
p. 303 The concluding sentence of the following quotation should be evaluated by Neighborhood Councils and the Community Assembly: "Over time, additional growth and development will occur through redevelopment as well as on vacant land.
The alternatives vary based on the types and geographic pattern of existing housing and businesses that may be demolished and replaced by new growth.
While this can contribute to the risk of physical displacement, the benefits in terms of reduced economic displacement pressure and increased production of affordable units offered by the action alternatives would address affordability in the marketplace, and the City's new policies and codes would address anti-displacement measures.
Therefore, no significant unavoidable adverse impacts to population, employment, or housing are expected under any alternative."
pp. 317 ff Neighborhood and Subarea Plans here and following.
pp. 317-18 Emerson-Garfield.
pp. 337-41 3.6-9 through 3.6.12 The estimates made by the authors of the report as to the effect of each of the three Alternatives in carrying out the Action Plan of each neighborhood that has one.
Narrative explanations of those estimates follow.
p. 337 discussion of Emerson-Garfield plan p. 347 the Level of Service grades consider vehicle movement only pp. 359-63 Vehicle Network pp. 487ff Chapter 5 Appendices containing the materials used
Appendix A These are the reports from the various outreach sessions and contain a record of comments made by attendees, some of which are excerpted here.
p. 503, 506, 510, 514, 518-20, 522-23, 525 "Staff Vision Re-Write B," which includes "cherishing its unique and vibrant neighborhoods," received the most votes (this appears to be a total of the votes at all three district sessions; however, the total number of votes for all three rewrites was only 100) (p. 503).
A similar request in the survey resulted in a strong expression of preference for B (p. 506). Survey respondents also added "leveraging existing investment" to desired features of the Plan. Attendees at the District 1 session held at Northeast Community Center supported B (p. 510). Attendees at the District 2 session held at Liberty Park Library supported A, but with C receiving only one less vote (p. 514).
Attendees at the District 3 session held at Shadle Park Library supported B (p. 518). They also added "Reuse of history [sic, recte historic] buildings prior to new development" (p. 519) and "do not let land sit unused/vacant" (p. 520) to the Vision. Attendees at the Community-wide session supported B (p. 522).
They added "Focus on [home] ownership to build personal stability and wealth," "How to test the benefits of proposed changes," and "Ensure changes are beneficial to the city at large, not just those heard from" to the Vision (pp. 522-23, 525).
p. 529 "sittable" neighborhoods (places where elderly and disabled may sit); creating (rather than preserving) neighborhood identities; address land speculation (was this incorporated into Plan documents?); Greater civic engagement, involvement, and transparency.
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p. 531 Under suggestions for "Residential Low" designation: "Create a process of neighborhood input on a project-by-project basis for non-standard uses"; "Prioritize adaptive reuse over new development"
p. 531 Under suggestions for "Commercial" designation: "Leverage vacant commercial areas to add business or apartments"
p. 533 "Alternative 2 received the most votes with 25.
Alternative 3 came in second with 7." However, many attendees instead of voting commented on combining desirable features of 2 and 3, with the result that "[t]he Preferred Alternative can be a combination of elements of the different Growth Alternatives, with these comments providing direction on what aspects were viewed positively from each Alternative." In 2, connectedness appealed; in 3 the emphasis on the Center City appealed.
pp. 534, 536 "No mixed-use in neighborhoods, concerned over exploitative development"; "Create protections against displacement in Chief Garry Park around City Line stops" (p. 534); "Recognition of limits to growth" (p. 536)
pp. 540, 541, 544 suggestions from attendees at District 1 "Future Growth and Guiding Policies Community Workshop" (approximately 22 attendees): "More Civic Engagement"; "Incentives for empty properties on Division following BRT implementation"; "Continue partnerships with housing services and neighborhood councils" (p. 540).
Alternative 2 preferred (p. 541).
"Prioritize policies with city action rather than informational or "encouraging" resident action" (p. 544).
pp. 545, 546, 548, 549, 550 suggestions from attendees at District 2 "Future Growth and Guiding Policies Community Workshop" (approximately 40 attendees): "Don't use broad terms in Comprehensive Plan"; concern about "corporate rental ownership" and request to "Control rents" (p. 545).
"Allow neighborhood input on a project-by-project level for other uses"; "Prioritize historic/adaptive reuse over new development (both commercial and residential)"; though Alternative 2 received the most votes, many did not vote but instead identified desirable and undesirable features of the various alternatives, such as that high density is isolating and large developments should have traffic lights at the exit (p. 546); no mixed use in neighborhoods, protect neighborhood from exploitive development (p. 548); "Enable neighborhoods to create more social capital and be able to take action and help issues"; "Need to have an acknowledgement of growth/our limits" (p. 549); "Recognize limits to growth" (p. 550)
pp. 552, 553, 554 suggestions from attendees at District 2 "Future Growth and Guiding Policies Community Workshop" (approximately 40 attendees): "for elderly and disabled residents, walkable also means sittable"; "sidewalk safety (e.g. electric scooters and conflicts with pedestrians" (p. 552); "Density transition: no high-rise next to single unit homes"; "Vacant lots, parking lots sitting unused" (p. 553).
Although Alternative 2 received the largest number of votes, most attendees instead highlighted desirable features of various alternatives: repeated emphasis on development of downtown; preference for preservation of historic buildings, revitalization and reuse; "Like a multi-block approach to intensities (like Alt 3 downtown) over less depth along transit lines" (p. 554)
pp. 559, 561, 563, 564 suggestions from attendees at City-Wide "Future Growth and Guiding Policies Community Workshop" (approximately 35 attendees): "Address land speculation" (p. 559).
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Although Alternative 2 received the largest number of votes, most attendees preferred to comment on desirable features of the various alternatives (p. 561). "On Washington, Howard, and Post, flip bike lane and parking"; "Push Monroe Road Diet down to Kendall Yards" (p. 563). Various suggestions to preserve natural green areas, parks, and animal species (pp. 563-64).
Appendix E Environmental Review Exemptions to Promote Infill Development and Housing, prepared by BERK Consulting (i.e. the consultant whose field of expertise is housing, not the two consultants whose fields of expertise are aspects of the environment).
p. 594 refers to exemptions from new environmental review of development where "probable adverse environmental impacts have been adequately addressed by local regulations and that the City's Comprehensive Plan was previously subject to an Environmental Impact Statement": this exemption is based on probability, not on verified facts; new development could result in new environmental impacts p. 596 how are "adequately" and "non-significance" defined?
p. 598 Exhibit 2 gives an outline of the City's current choice of intermediary amounts of residential units, commercial units, and excavation/landfill but then states "The City could adopt higher thresholds, which could vary by use or different geographic areas, and mixed-use projects." See pp. 610ff Potential Infill Exemption Location for areas where there is the greatest reason for the City to adopt higher thresholds.
pp. 610ff Potential Infill Exemption Location.
It is clear from Exhibits 4, 5, 6, and 7 in this section that the areas of the city that will most likely be considered for the first exemptions are located in neighborhoods developed in the early 20th century and that are currently residential with predominantly single-family housing.
Exh. 7 makes it clear that if the city moves to Phase 2, the entire city will be included in the "SEPA Proposed Infill / Categorical Exemption Area."