David Allen - Trestle
Mar 5, 2026
Property / Development
[PDF page 1 of 4]
Mr. Black,
I just realized the public comment deadline for the PlanSpokane environmental review was 5:00 p.m. today, but I'm hoping my comments might still be considered if possible. I've attached them here.
I really appreciate the work your department is doing to improve walkability and zoning in Spokane. My comments primarily focus on further studying VMT outcomes related to corridor intensification, particularly in North Spokane.
Walkable neighborhoods and development are a personal passion of mine, and much of my professional career has been focused on pursuing that goal. I hope the perspective is helpful as the work continues.
Thank you again for the effort your team is putting into this process.
Tirrell Black, Assistant Planning Director
City of Spokane
808 W Spokane Falls Blvd.
Spokane, WA 99201
RE: Spokane Forward Environmental Review
Dear Mr. Black:
I am a Spokane resident and real estate developer who works directly with zoning and housing feasibility. My job requires evaluating whether regulations on paper translate into projects on the ground. I'm writing because I am concerned that none of the proposed plans go far enough to deliver the walkability and reduced VMT.
Spokane has something many cities would love, a strong street grid and historic neighborhood commercial streets that form good bones. What we lack is an effective strategy to turn those bones into a truly walkable city.
After reviewing Section 3.4 (Land Use and Urban Form), Alternative 2 appears to be the most balanced option. If that is the likely path forward, the question becomes whether it is strong enough to achieve its environmental goals.
1. Walkability and VMT:
The report assumes that development intensity leads to lower VMT. There is a correlation between the two, but not necessarily causation.
It is possible to add density without creating walkability. For example, 29th & Grand, and 29th and Regal represent relatively intense development patterns, yet remain largely car centric. Similarly, intensifying corridors like Wellesley, Francis and Division may not lead to the walkability projected in the report. If you're familiar with Seattle, this would be like intensifying Aurora (hwy 99) instead of strengthening neighborhood main streets like Queen Anne or Fremont.
For walkability to increase there must be:
a. Places that can be safely and pleasantly walked to.
b. People living and working withing walking distance of those places.
[PDF page 3 of 4]
To achieve VMT goals we need to allow for human scale street design and development standards in areas where people feel safe walking. Perhaps counterintuitively, this is not along arterials, but calmer neighborhood main streets like Garland, Grand, Market Street ( NW Blvd perhaps being the busiest exception).
2. Adequacy of Identified Nodes:
Option 2 still leave large swaths of neighborhoods inadequately served by walkable neighborhood retail and mixed use. To create walkability for more Spokanites we need to bring new neighborhood commercial nodes to existing development.
For example, while the South Hill is blessed a streetcar-oriented, historic grid pattern, it misses opportunities for intensity along Cedar, Lincoln, W. 29th and 37th.
Another example is Lincoln and 10th which is a highly desirable node, which currently lacks "umph" and walkability to adequately serve the mid-South Hill.
If we want real walkability, we should consider adding neighborhood commercial nodes on adjacent main streets, which are not necessarily corridors - Garland and Grand, not Monroe or 29th.
3. Intensity of the Nodes:
The biggest issue I see with Option 2 is its continued emphasis on corridor density without enough focus on truly walkable neighborhood nodes.
Walkability is about a walkable radius, not contiguous commercial intensity. For a district to be walkable, it has to have a concentration of desirable services, and residential intensity within 1/4 mile to walk to those uses. If a grocery store is on one side of a long commercial corridor and the coffee shop is a mile away on the other side - the district is not walkable and adding residential intensity will not make it so.
If the residential intensity within a 1/4-mile of identified nodes is too low, retail will not pencil, and people will continue to drive. If that happens, projected VMT reductions may not materialize.
4. SEPA Exemptions:
Once proper intensity and walkable nodes are identified, make them categorically exempt from SEPA.
[PDF page 4 of 4 begins within the following paragraph.]
Once impacts are studied at the plan level, development within identified nodes and their walksheds should be streamlined. If a project meets adopted zoning and design standards, it should be able to proceed with minimal additional environmental review.
Extend SEPA exemptions into the 1/4 mile walk shed to ensure the density required for node feasibility has a greater degree of development certainty.
The core point is simple - intensity must be paired with good urban form, sufficient walkshed density, and regulatory certainty if walkability is to become reality.
My family and many others like us have "boomeranged" back to Spokane because we love this place: the access to nature, the relative affordability, and the quality of life. But a consistent theme I hear is that we wish it were just a bit more walkable.
We don't need to become Seattle. We want Spokane at its best. Neighborhoods where kids can bike to get ice cream, run a quick errand to the corner store, or meet friends without always relying on a car. That version of the good life is within reach, and this plan has the opportunity to help make it possible.
David Allen - Trestle
Mar 5, 2026
Property / Development
[PDF page 1 of 4]
Mr. Black,
I just realized the public comment deadline for the PlanSpokane environmental review was 5:00 p.m. today, but I'm hoping my comments might still be considered if possible. I've attached them here.
I really appreciate the work your department is doing to improve walkability and zoning in Spokane. My comments primarily focus on further studying VMT outcomes related to corridor intensification, particularly in North Spokane.
Walkable neighborhoods and development are a personal passion of mine, and much of my professional career has been focused on pursuing that goal. I hope the perspective is helpful as the work continues.
Thank you again for the effort your team is putting into this process.
Sincerely,
David Allen | Principal
Trestle
----------------------------------------
ATTACHMENT / ADDITIONAL PAGES
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[PDF page 2 of 4]
David Allen
Comstock Resident
Spokane, WA 99203
March 5, 2026
Tirrell Black, Assistant Planning Director
City of Spokane
808 W Spokane Falls Blvd.
Spokane, WA 99201
RE: Spokane Forward Environmental Review
Dear Mr. Black:
I am a Spokane resident and real estate developer who works directly with zoning and housing feasibility. My job requires evaluating whether regulations on paper translate into projects on the ground. I'm writing because I am concerned that none of the proposed plans go far enough to deliver the walkability and reduced VMT.
Spokane has something many cities would love, a strong street grid and historic neighborhood commercial streets that form good bones. What we lack is an effective strategy to turn those bones into a truly walkable city.
After reviewing Section 3.4 (Land Use and Urban Form), Alternative 2 appears to be the most balanced option. If that is the likely path forward, the question becomes whether it is strong enough to achieve its environmental goals.
1. Walkability and VMT:
The report assumes that development intensity leads to lower VMT. There is a correlation between the two, but not necessarily causation.
It is possible to add density without creating walkability. For example, 29th & Grand, and 29th and Regal represent relatively intense development patterns, yet remain largely car centric. Similarly, intensifying corridors like Wellesley, Francis and Division may not lead to the walkability projected in the report. If you're familiar with Seattle, this would be like intensifying Aurora (hwy 99) instead of strengthening neighborhood main streets like Queen Anne or Fremont.
For walkability to increase there must be:
a. Places that can be safely and pleasantly walked to.
b. People living and working withing walking distance of those places.
[PDF page 3 of 4]
To achieve VMT goals we need to allow for human scale street design and development standards in areas where people feel safe walking. Perhaps counterintuitively, this is not along arterials, but calmer neighborhood main streets like Garland, Grand, Market Street ( NW Blvd perhaps being the busiest exception).
2. Adequacy of Identified Nodes:
Option 2 still leave large swaths of neighborhoods inadequately served by walkable neighborhood retail and mixed use. To create walkability for more Spokanites we need to bring new neighborhood commercial nodes to existing development.
For example, while the South Hill is blessed a streetcar-oriented, historic grid pattern, it misses opportunities for intensity along Cedar, Lincoln, W. 29th and 37th.
Another example is Lincoln and 10th which is a highly desirable node, which currently lacks "umph" and walkability to adequately serve the mid-South Hill.
If we want real walkability, we should consider adding neighborhood commercial nodes on adjacent main streets, which are not necessarily corridors - Garland and Grand, not Monroe or 29th.
3. Intensity of the Nodes:
The biggest issue I see with Option 2 is its continued emphasis on corridor density without enough focus on truly walkable neighborhood nodes.
Walkability is about a walkable radius, not contiguous commercial intensity. For a district to be walkable, it has to have a concentration of desirable services, and residential intensity within 1/4 mile to walk to those uses. If a grocery store is on one side of a long commercial corridor and the coffee shop is a mile away on the other side - the district is not walkable and adding residential intensity will not make it so.
If the residential intensity within a 1/4-mile of identified nodes is too low, retail will not pencil, and people will continue to drive. If that happens, projected VMT reductions may not materialize.
4. SEPA Exemptions:
Once proper intensity and walkable nodes are identified, make them categorically exempt from SEPA.
[PDF page 4 of 4 begins within the following paragraph.]
Once impacts are studied at the plan level, development within identified nodes and their walksheds should be streamlined. If a project meets adopted zoning and design standards, it should be able to proceed with minimal additional environmental review.
Extend SEPA exemptions into the 1/4 mile walk shed to ensure the density required for node feasibility has a greater degree of development certainty.
The core point is simple - intensity must be paired with good urban form, sufficient walkshed density, and regulatory certainty if walkability is to become reality.
My family and many others like us have "boomeranged" back to Spokane because we love this place: the access to nature, the relative affordability, and the quality of life. But a consistent theme I hear is that we wish it were just a bit more walkable.
We don't need to become Seattle. We want Spokane at its best. Neighborhoods where kids can bike to get ice cream, run a quick errand to the corner store, or meet friends without always relying on a car. That version of the good life is within reach, and this plan has the opportunity to help make it possible.
Thank you for your consideration.
Sincerely,
David Allen