Tirrell Black, Assistant Planning Director
City of Spokane
808 W Spokane Falls Blvd.
Spokane, WA 99201
To Whom it May Concern:
I am very concerned about the environmental exemptions under Section 5 prepared by Berk Consulting Inc, December 2025. The reliance on State regulations is misguided as both Washington Dept of Fish and Wildlife and the Dept of Natural Resources seldom comment and even when they do, the recommendations are ignored by the City Planning Dept.
1. Section 5.2.2 presents exemptions by raising the number of houses or multifamily units. A development with 20 houses or 20 multifamily units should not receive an exemption. There are many properties with critical areas as defined in City Code as well as state regulations. Right now there is little enforcement by the City Planning Dept as illustrated by the Latah Glen development where WA Dept of Fish and Wildlife commented on priority wildlife habitat and priority species of concern as described in Code 17E.020.030. The City allowed the property to be clear cut and grubbed. No protection at all.
2. Section 5.2.2 also states that ""have been adequately addressed for the development exempted". In fact, the state regulations do not address all of the identified critical area types in the City code 17E.020. There is inadequate analysis in the DEIS to define how the environmental exemptions will impact the obvious loss of ecological functions from development.
3. The list of Regulations in Section 5.3 are not effectively enforced currently and without environmental review, compliance will be even less likely. There is no explanation how those regulations will be reviewed and enforced with the environmental exemption.
4. In Section 5.4 the Potential Infill Exemption Phases are unclear whether each phase is a blanket exemption without regard to the natural characteristics or if the referenced Exhibit 4 Existing Hard Surfaces as well as exhibit 3.3-4 showing Natural Resource Designations would affect exemptions. Using 100% hard surfaces as the criteria is appropriate. Not by a blanket exemption for the City in two phases.
5. There is inadequate quantification of impacts of the exemptions in Alternatives 2 and 3 in Section 3.3 Plants and Animals. Exhibit 3.3-2 shows the land cover types but has no scientific data supporting how natural lands such as the critical areas such as forests, wetlands, grasslandss, shrub-steppe would be impacted by the exemptions.
6. Section 5.2.1 states, "To accommodate infill development in urban areas not meeting the density goals"... provided the adverse impacts have been adequately addressed. There is no discussion of how to adequately address environmental impacts.
[PDF page 2 of 2 begins within the following paragraph.]
The approach that benefits the City is to exempt parcels that have 90-100% impervious surfaces. Areas of more than 10,000 sf of undisturbed would be excluded from the exemption. There is a tremendous amount of GIS data that makes exemptions based on site conditions instead of geographic location.
The environmental analyses has not been documented that would allow the exemptions to move forward.
Jeff Lambert
[Personal contact details omitted from the reading text.]
Jeff Lambert
Mar 5, 2026
Local Resident
[PDF page 1 of 2]
Tirrell Black, Assistant Planning Director
City of Spokane
808 W Spokane Falls Blvd.
Spokane, WA 99201
To Whom it May Concern:
I am very concerned about the environmental exemptions under Section 5 prepared by Berk Consulting Inc, December 2025. The reliance on State regulations is misguided as both Washington Dept of Fish and Wildlife and the Dept of Natural Resources seldom comment and even when they do, the recommendations are ignored by the City Planning Dept.
1. Section 5.2.2 presents exemptions by raising the number of houses or multifamily units. A development with 20 houses or 20 multifamily units should not receive an exemption. There are many properties with critical areas as defined in City Code as well as state regulations. Right now there is little enforcement by the City Planning Dept as illustrated by the Latah Glen development where WA Dept of Fish and Wildlife commented on priority wildlife habitat and priority species of concern as described in Code 17E.020.030. The City allowed the property to be clear cut and grubbed. No protection at all.
2. Section 5.2.2 also states that ""have been adequately addressed for the development exempted". In fact, the state regulations do not address all of the identified critical area types in the City code 17E.020. There is inadequate analysis in the DEIS to define how the environmental exemptions will impact the obvious loss of ecological functions from development.
3. The list of Regulations in Section 5.3 are not effectively enforced currently and without environmental review, compliance will be even less likely. There is no explanation how those regulations will be reviewed and enforced with the environmental exemption.
4. In Section 5.4 the Potential Infill Exemption Phases are unclear whether each phase is a blanket exemption without regard to the natural characteristics or if the referenced Exhibit 4 Existing Hard Surfaces as well as exhibit 3.3-4 showing Natural Resource Designations would affect exemptions. Using 100% hard surfaces as the criteria is appropriate. Not by a blanket exemption for the City in two phases.
5. There is inadequate quantification of impacts of the exemptions in Alternatives 2 and 3 in Section 3.3 Plants and Animals. Exhibit 3.3-2 shows the land cover types but has no scientific data supporting how natural lands such as the critical areas such as forests, wetlands, grasslandss, shrub-steppe would be impacted by the exemptions.
6. Section 5.2.1 states, "To accommodate infill development in urban areas not meeting the density goals"... provided the adverse impacts have been adequately addressed. There is no discussion of how to adequately address environmental impacts.
[PDF page 2 of 2 begins within the following paragraph.]
The approach that benefits the City is to exempt parcels that have 90-100% impervious surfaces. Areas of more than 10,000 sf of undisturbed would be excluded from the exemption. There is a tremendous amount of GIS data that makes exemptions based on site conditions instead of geographic location.
The environmental analyses has not been documented that would allow the exemptions to move forward.
Jeff Lambert
[Personal contact details omitted from the reading text.]