Comment on the Preferred Alternative, PlanSpokane: The Latah Valley should not show intense development because the infrastructure of all types but especially transportation is deficient and difficult to be corrected. My understanding of the concurrency review process is the Planning Department conducts the review, while specific service providers evaluate their respective capacities. The results have shown that the Latah Valley is severely lacking in capacity in all criteria including transportation, utilities and public services.
The proposed alternatives shown density in the Latah Valley that is inappropriate given the lack of concurrency and the extremely high cost of upgrading the infrastructure. It is clear that the City of Spokane does not have the capacity or a plan to fund the necessary infrastructure improvements. Consequently, there is a large risk to the City from adopting a plan and development strategy that can ’t be funded.
I recommend the intensity of development be reduced in the selected Alternative and that the area north of 44th Avenue, West of Latah Creek, south of 16th Ave, and east of Assembly be designated as a Critical Area due to the Dept. of Fish and Wildlife critical habitat, steep terrain, wetlands, unstable slopes and other geologic factors.
Environmental review should not be exempted in this area.
Perhaps a Transfer of Development Rights from the Latah Valley Critical Area to other parts of the City that can accommodate the higher density would be beneficial to all parties. I include a background on concurrency for the Commission’s review.
Jeff Lambert [home address redacted]
[Editor’s note: The following background material was included with the submission and contains an AI-response disclaimer.]
Background on Concurrency
- Application Submittal: When a development permit is filed, the planning department identifies if a concurrency review is required.
- Agency Notification: The department notifies all relevant service providers (e.g., water, sewer, transportation) of the application.
- Concurrency Test: Service providers perform a "test" by comparing the applicant's projected impact against available capacity.
- Transportation: Evaluates both "available and planned" capacity.
- Utilities (Water/Sewer): Evaluates only "available" capacity.
- Result Notification: The department notifies the applicant of the final results (approval or denial).
- Mitigation: If capacity is lacking, particularly for transportation, the applicant may be required to provide improvements or financial commitments (like impact fees) to meet Level of Service (LOS) standards within six years. City of Spokane, Washington +5
Key Performance Standards
Facility Category | Evaluation Criteria | Potential Outcome of Failure
Transportation | Available and planned capacity | Denial unless improvements or financial
[PDF page 2 of 3]
(Level of Service) commitments are made. Utilities (Water, Sewer, Solid Waste) Available capacity only Approval requires sufficient existing capacity. Public Services (Police, Fire, Schools, Parks, Libraries) Available and planned capacity Impact is weighed against long-term planning.
Options if Capacity is Lacking
If a project fails the concurrency test, the applicant has several options under Spokane Municipal Code Section 17D.010.020:
- Reservation: Accept a 90-day reservation of existing capacity while addressing the gap.
- Modification: Reduce the project's scale to lower its capacity needs.
- Direct Provision: Arrange to provide the necessary additional capacity themselves.
- Appeal: Submit an appeal to the Hearing Examiner within the allotted timeframe.
City of Spokane, Washington +2
Would you like to see the specific Level of Service (LOS) standards currently adopted in Spokane's Comprehensive Plan for transportation?
REFERENCES
- Spokane Municipal Code - Section 17D.010.020: Concurrency Review
Spokane Municipal Code * The concurrency review will be performed in the processing of the development permit and conducted by the...
City of Spokane, Washington
- Spokane Municipal Code - Section 17D.010.020
The concurrency review will be performed in the processing of the development permit and conducted by the appropriate facility and...
City of Spokane, Washington
- Spokane Municipal Code - Section 17D.010.050: Appeals
The planning and economic development services department and appropriate service provider(s) shall transmit to the hearing examin...
City of Spokane, Washington
Is the City of Spokane complying with the process of concurrency rules?
The City of Spokane maintains compliance with concurrency rules by embedding these reviews into its development code and Comprehensive Plan, though it is currently in a critical transition period to align with new state mandates. City of Spokane, Washington +2
Evidence of Ongoing Compliance
The City actively enforces concurrency through the following mechanisms:
- Mandatory Review: All non-exempt development permits must pass a concurrency test for transportation and utilities before approval.
- Code Modernization (BUILDSpokane): As of early 2026, the City is conducting a comprehensive update to Title 17 of the Spokane Municipal Code to ensure development regulations align with current Level of Service (LOS) standards and state legislative changes.
[PDF page 3 of 3]
- Financial Commitments: For projects that impact transportation, the City satisfies the "concurrent" requirement by ensuring improvements are finished within six years or that a "financial commitment" (including impact fees) is secured. City of Spokane, Washington +5
Current Areas of Focus & Challenges
While the City is generally compliant, it is currently addressing several areas to avoid future non compliance:
- 2026 Periodic Update: Spokane is under a state-mandated deadline of December 31, 2026, to update its Comprehensive Plan. This update is necessary to incorporate new requirements for climate planning and housing diversity.
- Transportation Evolution: Traditional concurrency often focuses strictly on vehicle congestion. The City is exploring more multimodal metrics to account for transit, biking, and walking as density increases, which helps prevent development denials in urban centers.
- Level of Service (LOS) Maintenance: If a proposed development would drop the LOS below minimum standards, the Planning Department is legally required to deny it unless mitigation is provided. City of Spokane, Washington +5 There are currently no major published audit findings or court rulings indicating that Spokane is in systemic violation of Growth Management Act (GMA) concurrency requirements for the 2025 –2026 period. Office of Financial Management (.gov) +1
Would you like to review the specific projects listed in the City's current 6-Year Capital Improvement Program that are being used to satisfy transportation concurrency? AI responses may include mistakes. For legal advice, consult a professional. Learn more
13 sites
- Spokane Municipal Code - Section 17D.010.020
Development applications that would result in a reduction of a level of service below the minimum level of service standard cannot...
City of Spokane, Washington
- Spokane Municipal Code - Section 17D.075.030: Concurrency
The concurrency requirement is satisfied if the required system improvements are in place at the time of development activity, or ...
City of Spokane, Washington
- Spokane Municipal Code - Section 17D.010.020: Concurrency Review
All development permit applications are subject to a concurrency review except those exempted in SMC 17D. 010.030.
Jeff Lambert
Apr 14, 2026
Local Resident
[PDF page 1 of 3]
To: Planning Commission From: Jeff Lambert
Comment on the Preferred Alternative, PlanSpokane: The Latah Valley should not show intense development because the infrastructure of all types but especially transportation is deficient and difficult to be corrected. My understanding of the concurrency review process is the Planning Department conducts the review, while specific service providers evaluate their respective capacities. The results have shown that the Latah Valley is severely lacking in capacity in all criteria including transportation, utilities and public services.
The proposed alternatives shown density in the Latah Valley that is inappropriate given the lack of concurrency and the extremely high cost of upgrading the infrastructure. It is clear that the City of Spokane does not have the capacity or a plan to fund the necessary infrastructure improvements. Consequently, there is a large risk to the City from adopting a plan and development strategy that can ’t be funded.
I recommend the intensity of development be reduced in the selected Alternative and that the area north of 44th Avenue, West of Latah Creek, south of 16th Ave, and east of Assembly be designated as a Critical Area due to the Dept. of Fish and Wildlife critical habitat, steep terrain, wetlands, unstable slopes and other geologic factors.
Environmental review should not be exempted in this area.
Perhaps a Transfer of Development Rights from the Latah Valley Critical Area to other parts of the City that can accommodate the higher density would be beneficial to all parties. I include a background on concurrency for the Commission’s review.
Jeff Lambert [home address redacted]
[Editor’s note: The following background material was included with the submission and contains an AI-response disclaimer.]
Background on Concurrency
- Application Submittal: When a development permit is filed, the planning department identifies if a concurrency review is required.
- Agency Notification: The department notifies all relevant service providers (e.g., water, sewer, transportation) of the application.
- Concurrency Test: Service providers perform a "test" by comparing the applicant's projected impact against available capacity.
- Transportation: Evaluates both "available and planned" capacity.
- Utilities (Water/Sewer): Evaluates only "available" capacity.
- Result Notification: The department notifies the applicant of the final results (approval or denial).
- Mitigation: If capacity is lacking, particularly for transportation, the applicant may be required to provide improvements or financial commitments (like impact fees) to meet Level of Service (LOS) standards within six years. City of Spokane, Washington +5
Key Performance Standards
Facility Category | Evaluation Criteria | Potential Outcome of Failure
Transportation | Available and planned capacity | Denial unless improvements or financial
[PDF page 2 of 3]
(Level of Service) commitments are made. Utilities (Water, Sewer, Solid Waste) Available capacity only Approval requires sufficient existing capacity. Public Services (Police, Fire, Schools, Parks, Libraries) Available and planned capacity Impact is weighed against long-term planning.
Options if Capacity is Lacking
If a project fails the concurrency test, the applicant has several options under Spokane Municipal Code Section 17D.010.020:
- Reservation: Accept a 90-day reservation of existing capacity while addressing the gap.
- Modification: Reduce the project's scale to lower its capacity needs.
- Direct Provision: Arrange to provide the necessary additional capacity themselves.
- Appeal: Submit an appeal to the Hearing Examiner within the allotted timeframe.
City of Spokane, Washington +2
Would you like to see the specific Level of Service (LOS) standards currently adopted in Spokane's Comprehensive Plan for transportation?
REFERENCES
- Spokane Municipal Code - Section 17D.010.020: Concurrency Review
Spokane Municipal Code * The concurrency review will be performed in the processing of the development permit and conducted by the...
City of Spokane, Washington
- Spokane Municipal Code - Section 17D.010.020
The concurrency review will be performed in the processing of the development permit and conducted by the appropriate facility and...
City of Spokane, Washington
- Spokane Municipal Code - Section 17D.010.050: Appeals
The planning and economic development services department and appropriate service provider(s) shall transmit to the hearing examin...
City of Spokane, Washington
Is the City of Spokane complying with the process of concurrency rules?
The City of Spokane maintains compliance with concurrency rules by embedding these reviews into its development code and Comprehensive Plan, though it is currently in a critical transition period to align with new state mandates. City of Spokane, Washington +2
Evidence of Ongoing Compliance
The City actively enforces concurrency through the following mechanisms:
- Mandatory Review: All non-exempt development permits must pass a concurrency test for transportation and utilities before approval.
- Code Modernization (BUILDSpokane): As of early 2026, the City is conducting a comprehensive update to Title 17 of the Spokane Municipal Code to ensure development regulations align with current Level of Service (LOS) standards and state legislative changes.
[PDF page 3 of 3]
- Financial Commitments: For projects that impact transportation, the City satisfies the "concurrent" requirement by ensuring improvements are finished within six years or that a "financial commitment" (including impact fees) is secured. City of Spokane, Washington +5
Current Areas of Focus & Challenges
While the City is generally compliant, it is currently addressing several areas to avoid future non compliance:
- 2026 Periodic Update: Spokane is under a state-mandated deadline of December 31, 2026, to update its Comprehensive Plan. This update is necessary to incorporate new requirements for climate planning and housing diversity.
- Transportation Evolution: Traditional concurrency often focuses strictly on vehicle congestion. The City is exploring more multimodal metrics to account for transit, biking, and walking as density increases, which helps prevent development denials in urban centers.
- Level of Service (LOS) Maintenance: If a proposed development would drop the LOS below minimum standards, the Planning Department is legally required to deny it unless mitigation is provided. City of Spokane, Washington +5 There are currently no major published audit findings or court rulings indicating that Spokane is in systemic violation of Growth Management Act (GMA) concurrency requirements for the 2025 –2026 period. Office of Financial Management (.gov) +1
Would you like to review the specific projects listed in the City's current 6-Year Capital Improvement Program that are being used to satisfy transportation concurrency? AI responses may include mistakes. For legal advice, consult a professional. Learn more
13 sites
- Spokane Municipal Code - Section 17D.010.020
Development applications that would result in a reduction of a level of service below the minimum level of service standard cannot...
City of Spokane, Washington
- Spokane Municipal Code - Section 17D.075.030: Concurrency
The concurrency requirement is satisfied if the required system improvements are in place at the time of development activity, or ...
City of Spokane, Washington
- Spokane Municipal Code - Section 17D.010.020: Concurrency Review
All development permit applications are subject to a concurrency review except those exempted in SMC 17D. 010.030.