Garrett LaCivita - Washington Department of Fish and Wildlife (WDFW)
Mar 6, 2026
Government / Technical
[PDF page 1 of 5]
Good afternoon City of Spokane Planning Team,
Here are WDFW's first round of comments on the chapters you provided. If you would like to set a meeting time to go over and discuss our comments, we would be more than happy to do so. Other jurisdictions have found this helpful - it gives us time to rework some language or remove comments that where we have potentially misinterpreted things before final submission and final edits.
Looking forward to hearing from you and hope you have a lovely weekend - cheers!
Garrett LaCivita (she/her)
Land Use Planner, WDFW Region 1
State of Washington
DEPARTMENT OF FISH AND WILDLIFE
Eastern Region - Region 1
2315 North Discovery Place, Spokane Valley, WA 99216-1566
March 6th, 2026
City of Spokane
Department of Planning Services
808 W. Spokane Falls Blvd.
Spokane, WA 99201
PlanSpokane@spokanecity.org
RE: WDFW Comments on City of Spokane Draft Comprehensive Plan Chapters (Natural Environment, and Parks and Recreation)
Dear City of Spokane Planning Department,
On behalf of the Washington Department of Fish and Wildlife (WDFW), thank you for the opportunity to formally comment on the draft Comprehensive Plan Chapters (Natural Environment and Parks and Recreation) for the City of Spokane.
Within the State of Washington's land use decision-making framework, WDFW's role is that of technical advisor with respect to the habitat needs of fish and wildlife and the likely implications of various land use decisions on those resources over time.
WDFW supports the City's ongoing efforts to integrate environmental protection with thoughtful planning and offers the following comments to help ensure continued alignment with the Growth Management Act (GMA), especially regarding fish and wildlife habitat conservation.
We provide these comments and recommendations in keeping with our legislative mandate to preserve, protect, and perpetuate fish and wildlife and their habitats for the benefit of future generations - a mission we can only accomplish in partnership with local jurisdictions. We may decide to submit additional comments on this topic in the future.
Overall, we found a high level of consistency between your draft 2026 Comprehensive Plan Chapters, our resources, and our future conservation goals, and we are excited to be working alongside Airway Heights through these new updates. This Plan is a wonderful foundational guideline for the city.
The following comments are provided for each Draft Chapter. All edits in red are WDFW language suggestions, while broader thematic insertions will be indicated below the sample text.
Natural Environment Chapter:
The narrative is a little brief, but WDFW is pleased to see this level of insight and analysis for the Natural Environment Chapter along with the ambitious addition of 5 new goals and policies along with climate resiliency integration.
- Comment: We would recommend the addition of maps that illustrate natural areas in Spokane City, critical areas, and drainage concerns to provide better supporting evidence of some of these policies.
[PDF page 3 of 5 begins within the following paragraph.]
- Comment: Action items or an implementation section would strength these policies and provide strategic clarity.
- Comment: Critical areas on private lands should be listed on property papers and landowners should be aware of building restrictions or mitigation measures.
Natural Environment Goals and Policies:
Goal NE-1: Water Quality
- Policy: NE-1.2, Stormwater Techniques and Best Practices - Encourage the use of evolving best practices for stormwater, including solutions like rain gardens, Wastewater Combined Sewer Overflow (CSO) tanks, and other low-impact mitigation tools that protect ground and surface water from contamination and pollution.
o Comment: Are salmon and fish impacts or mitigation part of this strategy?
Goal NE-2: Sustainable Water Supply and Resources
- Policy: NE-2.2, Landscaping Requirements and Incentives - Expand the use of incentives like SpokaneScape and other programs that encourage use of drought-tolerant plants and the placement of native trees and vegetation, including incentives like water bill credits and discounts.
o Comment: This policy would work well with Commerce's Policy Z.04 - "Promote the sale and use of agricultural supplies, pesticides, fertilizers, and fuels that are not derived from fossil fuels" as a high priority for the state.
Goal NE-5: Native Species Protection
- Policy: NE-5.2, Public Native Species Application and Education - Utilize and expand programs and incentives like Spokane Scape that educate and recognize members of the public who install and maintain drought tolerant native planting in yards and landscaping.
o Comment: WDFW has several certifications, resources, and programs for private landowners, schools, or parks that could help enhance this policy.
Please refer to our
"Habitat at Home" webpage for resources.
- Policy: NE-5.3, Habitat Network - Identify, purchase, preserve, and maintain existing and potential links between wildlife habitats, seeking to form a network of wildlife habitats while
partnering with regional and state agencies and programs.
o Comment: This is a great policy and WDFW is thrilled to see habitat connectivity in the City's Comp Plan priorities.
- Policy: NE-5.4, Fish and Wildlife Protection - Continue to identify, and protect, and ensure
no net loss of ecological function or values to those fish, and wildlife, and their habitats
which are identified as a priority for ecological health by citizens and scientific experts while
utilizing current best available science practices and standards.
[PDF page 4 of 5 begins within the following paragraph.]
- Policy: NE-5.5, Protection of Adjacent Wildlife Habitats - Coordinate with adjacent jurisdictions and agencies to designate, protect, and acquire wildlife habitats that abut or straddle the city limits or the urban growth area boundary to enhance connectivity and ease of movement for wildlife.
Goal NE-9: Sustainable Economics and Employment
- Goal: NE-9, Sustainable Economies and Employment - Support a sustainable economy and incentivize employment that enhances the natural environment
o Policy Suggestion: language regarding green infrastructure and low impact development would work well here.
Goal NE-11: Natural Areas
- Policy: NE-10.2 Natural Corridor Links and Connections - Agency consultation to help identify and enhance interconnections between undisturbed natural areas, understanding
that protected and local species need movement corridors to navigate the city.
- Policy Suggestion: Noise and light pollution reduction efforts would be beneficial here.
Goal NE-11: Urban Forestry
- Policy: NE-11.5, Tree Replacement Program - Develop and implement a program whereby the City maintains "no net loss" of street trees through programs and incentives for tree maintenance and replacement, while considering exemptions for emergencies and public safety
o This is great, we would love to use this as an example for other jurisdictions
Parks and Recreation Chapter:
- Comment: We would recommend the addition of maps that illustrate current parks or recreation areas and future planned parks and recreation areas in Spokane City to provide better supporting evidence of some of these policies.
Goal 1 - Preservation and Conservation
- Policy: PR-1.2, River Corridors - Recognize, enhance, and preserve access to the Spokane
River and various waterways for the recreational enjoyment and use of the public, recognizing the health, social, and cultural benefits access to the waters of Spokane
provides, while maintaining consistency with preservation and protection standards
o Comment: The wording here needs to be a little stronger in regards to salmon protections.
- Policy: PR-1.4, Explore Opportunities for Acquisition of Natural Areas - Acquire and preserve natural lands that provide connectivity and support opportunities for passive
[PDF page 5 of 5]
recreation while preserving the land in its natural state and helping to preserve and provide priority wildlife and habitat protection.
- Comment: For Policy: PR-1.5, Developers and Open Space Dedication and 1.6 Open Space Buffers, would the City consider minimum size standards for these buffers or open spaces?
Proper corridor widths will depend on the species or suite of species being targeted.
Widths of >1,000 ft provide the most benefits for the most species, while narrower widths are important but for fewer numbers of species, but in urban areas species needs are generally more flexible.
o Our Landscape Planning for Washington's Wildlife: Managing For Biodiversity In Developing Areas is an excellent resource on wildlife and green spaces in urban environments.
WDFW would also be happy to discuss this more and provide recommendations.
We value the relationship we have with your jurisdiction and the opportunity to work collaboratively with you. We have assembled a list of land-use planning priorities and resources to help support your periodic update process. If you have any questions, need technical assistance, or resources at any time, please don't hesitate to contact me your Regional Habitat Biologist.
Garrett LaCivita - Washington Department of Fish and Wildlife (WDFW)
Mar 6, 2026
Government / Technical
[PDF page 1 of 5]
Good afternoon City of Spokane Planning Team,
Here are WDFW's first round of comments on the chapters you provided. If you would like to set a meeting time to go over and discuss our comments, we would be more than happy to do so. Other jurisdictions have found this helpful - it gives us time to rework some language or remove comments that where we have potentially misinterpreted things before final submission and final edits.
Looking forward to hearing from you and hope you have a lovely weekend - cheers!
Garrett LaCivita (she/her)
Land Use Planner, WDFW Region 1
----------------------------------------
ATTACHMENT / ADDITIONAL PAGES
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[PDF page 2 of 5]
State of Washington
DEPARTMENT OF FISH AND WILDLIFE
Eastern Region - Region 1
2315 North Discovery Place, Spokane Valley, WA 99216-1566
March 6th, 2026
City of Spokane
Department of Planning Services
808 W. Spokane Falls Blvd.
Spokane, WA 99201
PlanSpokane@spokanecity.org
RE: WDFW Comments on City of Spokane Draft Comprehensive Plan Chapters (Natural Environment, and Parks and Recreation)
Dear City of Spokane Planning Department,
On behalf of the Washington Department of Fish and Wildlife (WDFW), thank you for the opportunity to formally comment on the draft Comprehensive Plan Chapters (Natural Environment and Parks and Recreation) for the City of Spokane.
Within the State of Washington's land use decision-making framework, WDFW's role is that of technical advisor with respect to the habitat needs of fish and wildlife and the likely implications of various land use decisions on those resources over time.
WDFW supports the City's ongoing efforts to integrate environmental protection with thoughtful planning and offers the following comments to help ensure continued alignment with the Growth Management Act (GMA), especially regarding fish and wildlife habitat conservation.
We provide these comments and recommendations in keeping with our legislative mandate to preserve, protect, and perpetuate fish and wildlife and their habitats for the benefit of future generations - a mission we can only accomplish in partnership with local jurisdictions. We may decide to submit additional comments on this topic in the future.
Overall, we found a high level of consistency between your draft 2026 Comprehensive Plan Chapters, our resources, and our future conservation goals, and we are excited to be working alongside Airway Heights through these new updates. This Plan is a wonderful foundational guideline for the city.
The following comments are provided for each Draft Chapter. All edits in red are WDFW language suggestions, while broader thematic insertions will be indicated below the sample text.
Natural Environment Chapter:
The narrative is a little brief, but WDFW is pleased to see this level of insight and analysis for the Natural Environment Chapter along with the ambitious addition of 5 new goals and policies along with climate resiliency integration.
- Comment: We would recommend the addition of maps that illustrate natural areas in Spokane City, critical areas, and drainage concerns to provide better supporting evidence of some of these policies.
[PDF page 3 of 5 begins within the following paragraph.]
- Comment: Action items or an implementation section would strength these policies and provide strategic clarity.
- Comment: Critical areas on private lands should be listed on property papers and landowners should be aware of building restrictions or mitigation measures.
Natural Environment Goals and Policies:
Goal NE-1: Water Quality
- Policy: NE-1.2, Stormwater Techniques and Best Practices - Encourage the use of evolving best practices for stormwater, including solutions like rain gardens, Wastewater Combined Sewer Overflow (CSO) tanks, and other low-impact mitigation tools that protect ground and surface water from contamination and pollution.
o Comment: Are salmon and fish impacts or mitigation part of this strategy?
Goal NE-2: Sustainable Water Supply and Resources
- Policy: NE-2.2, Landscaping Requirements and Incentives - Expand the use of incentives like SpokaneScape and other programs that encourage use of drought-tolerant plants and the placement of native trees and vegetation, including incentives like water bill credits and discounts.
o Comment: This policy would work well with Commerce's Policy Z.04 - "Promote the sale and use of agricultural supplies, pesticides, fertilizers, and fuels that are not derived from fossil fuels" as a high priority for the state.
Goal NE-5: Native Species Protection
- Policy: NE-5.2, Public Native Species Application and Education - Utilize and expand programs and incentives like Spokane Scape that educate and recognize members of the public who install and maintain drought tolerant native planting in yards and landscaping.
o Comment: WDFW has several certifications, resources, and programs for private landowners, schools, or parks that could help enhance this policy.
Please refer to our
"Habitat at Home" webpage for resources.
- Policy: NE-5.3, Habitat Network - Identify, purchase, preserve, and maintain existing and potential links between wildlife habitats, seeking to form a network of wildlife habitats while
partnering with regional and state agencies and programs.
o Comment: This is a great policy and WDFW is thrilled to see habitat connectivity in the City's Comp Plan priorities.
- Policy: NE-5.4, Fish and Wildlife Protection - Continue to identify, and protect, and ensure
no net loss of ecological function or values to those fish, and wildlife, and their habitats
which are identified as a priority for ecological health by citizens and scientific experts while
utilizing current best available science practices and standards.
[PDF page 4 of 5 begins within the following paragraph.]
- Policy: NE-5.5, Protection of Adjacent Wildlife Habitats - Coordinate with adjacent jurisdictions and agencies to designate, protect, and acquire wildlife habitats that abut or straddle the city limits or the urban growth area boundary to enhance connectivity and ease of movement for wildlife.
Goal NE-9: Sustainable Economics and Employment
- Goal: NE-9, Sustainable Economies and Employment - Support a sustainable economy and incentivize employment that enhances the natural environment
o Policy Suggestion: language regarding green infrastructure and low impact development would work well here.
Goal NE-11: Natural Areas
- Policy: NE-10.2 Natural Corridor Links and Connections - Agency consultation to help identify and enhance interconnections between undisturbed natural areas, understanding
that protected and local species need movement corridors to navigate the city.
- Policy Suggestion: Noise and light pollution reduction efforts would be beneficial here.
Goal NE-11: Urban Forestry
- Policy: NE-11.5, Tree Replacement Program - Develop and implement a program whereby the City maintains "no net loss" of street trees through programs and incentives for tree maintenance and replacement, while considering exemptions for emergencies and public safety
o This is great, we would love to use this as an example for other jurisdictions
Parks and Recreation Chapter:
- Comment: We would recommend the addition of maps that illustrate current parks or recreation areas and future planned parks and recreation areas in Spokane City to provide better supporting evidence of some of these policies.
Goal 1 - Preservation and Conservation
- Policy: PR-1.2, River Corridors - Recognize, enhance, and preserve access to the Spokane
River and various waterways for the recreational enjoyment and use of the public, recognizing the health, social, and cultural benefits access to the waters of Spokane
provides, while maintaining consistency with preservation and protection standards
o Comment: The wording here needs to be a little stronger in regards to salmon protections.
- Policy: PR-1.4, Explore Opportunities for Acquisition of Natural Areas - Acquire and preserve natural lands that provide connectivity and support opportunities for passive
[PDF page 5 of 5]
recreation while preserving the land in its natural state and helping to preserve and provide priority wildlife and habitat protection.
- Comment: For Policy: PR-1.5, Developers and Open Space Dedication and 1.6 Open Space Buffers, would the City consider minimum size standards for these buffers or open spaces?
Proper corridor widths will depend on the species or suite of species being targeted.
Widths of >1,000 ft provide the most benefits for the most species, while narrower widths are important but for fewer numbers of species, but in urban areas species needs are generally more flexible.
o Our Landscape Planning for Washington's Wildlife: Managing For Biodiversity In Developing Areas is an excellent resource on wildlife and green spaces in urban environments.
WDFW would also be happy to discuss this more and provide recommendations.
We value the relationship we have with your jurisdiction and the opportunity to work collaboratively with you. We have assembled a list of land-use planning priorities and resources to help support your periodic update process. If you have any questions, need technical assistance, or resources at any time, please don't hesitate to contact me your Regional Habitat Biologist.