Kathy Hagy Sue Arnesen
Apr 13, 2026
Local Residents
[PDF page 1 of 4]
To: Tirrell Black, Assistant Planning Director
This comment is about the same as the one you received from Nolan Steiner. He did such a great job of writing and stating our thoughts, we pretty much copied his. Thank you for reading this.
Kathy Hagy
Sue Arnesen
[Personal contact details omitted from the reading text.]
Strengthening & Codifying Equitable Scattered-Site Model for STEP Housing April 13, 2026
Thank you for the opportunity to comment on the PlanSpokane 2046 update. Our comments focus on one significant structural deficiency in the current Comprehensive Plan: Spokane lacks a codified, enforceable mechanism to ensure equitable geographic distribution of all facilities serving unsheltered and vulnerable residents. The absence of such a mechanism has allowed significant concentration of emergency shelters, transitional housing, and supportive housing in only a few neighborhoods, while others have remained functionally exempt from participating in the citywide responsibility to provide restorative housing and services. As will be discussed below, our recommendation is for the City of Spokane to establish an ‘Equitable Distribution Scattered-Site Program’ that ensures societal equity across all Spokane neighborhoods.
Recent Events & Relevance: WA State House Bill 2266 (Governor signed March 27, 2026)
Washington State’s HB 2266 expands where STEP housing must be allowed and restricts local governments from imposing unique barriers to these facilities. While the law increases siting flexibility, it also creates a local responsibility to ensure that the resulting development pattern is equitable and not disproportionately borne by a small number of neighborhoods.
The law requires cities and counties planning under the Growth Management Act to bring their codes into compliance within two years of the bill’s effective date or at their next comprehensive plan update—whichever comes first.
Because of this, this Comprehensive Plan update is the appropriate venue to articulate how Spokane will implement HB 2266 in a manner that complies with state requirements while preventing unbalanced clustering of STEP facilities.
Of importance, HB 2266 removes mandatory public hearings and shifts approvals for STEP housing to administrative, staff-level review. This eliminates the formal, quasi-judicial settings where residents previously provided testimony, raised concerns, and ensured that project-level decisions were transparent and accountable. While residents may still submit written comments or speak in general public-forum settings, these avenues are no longer tied to the actual approval process. As a result, the Comprehensive Plan has become one of the few remaining tools that can protect meaningful public involvement and ensure that fairness, transparency, and accountability are embedded in citywide policy, and not left exclusively to city administrative oversight or discretion.
Because WA State HB 2266 was not in effect during the eight months of prior EIS and Plan 2046 development sessions, the existing draft plan has not yet reflected these new municipal
[PDF page 3 of 4]
public constraints mandated by the legislation. This makes it essential that PlanSpokane 2046 explicitly address the newly reduced public-participation and for the City of Spokane to strengthen the policy framework accordingly for the protection of city residents and neighborhoods.
Establishing an Equitable Distribution Scattered Site Program
The existing Comprehensive Plan references the value of integrated, non-concentrated housing, but it does not define a scattered-site model, require its use, or establish any monitoring or enforcement structure. As a result, the scattered-site concept has remained policy rhetoric rather than operational practice. This needs to change.
The updated Comprehensive Plan should establish a citywide Equitable Distribution Scattered Site Program with the following core elements:
• A formal definition of the scattered-site model as a land-use and service-distribution doctrine that prevents over-concentration of STEP-related facilities in any single neighborhood.
• Application of the program to all facilities whose primary business function is restorative housing, treatment, emergency sheltering, transitional housing, permanent supportive housing, or low-barrier sheltering—regardless of whether they are city-funded, state-funded, federally funded, or privately funded.
• A requirement that siting decisions, permitting, and funding recommendations be evaluated against citywide geographical distribution metrics to ensure equitable placement across neighborhoods.
• Siting decisions must not default to areas with lower property values or greater land availability, as doing so would systematically concentrate STEP facilities and further marginalize the economic development prospects of those neighborhoods.
Required Updates to Planning, Permitting, and Land-Use Processes
To operationalize the Equitable Distribution Scattered Site Program, the Comprehensive Plan should direct an update of, at minimum:
• Permitting processes, requiring geographic and neighborhood distribution analysis as part of a project review.
• Land-use and zoning codes, ensuring that expanded siting allowances under HB 2266 are paired with geographical and neighborhood distribution safeguards.
• Funding and partnership criteria, so that city support prioritizes projects that advance equitable geographic distribution. As stated earlier, the program needs to include all projects regardless of funding source (i.e., city, county, state, federal, private, non-profit, or a combination of funding sources).
• Neighborhood planning, integrating STEP facility distribution into subarea plans and growth strategies.
• Public transparency tools, including a mandatory, publicly accessible GIS layer and heat-map that displays the location of all STEP-related facilities and visualizes geographic distribution metrics across neighborhoods.
[PDF page 4 of 4]
Public GIS Layer and Heat-Map Requirements
The Comprehensive Plan should require the City to maintain a public GIS dashboard that includes:
• Facility locations mapped citywide.
• Bed capacity by site and by neighborhood.
• Facility type by neighborhood (i.e., tiny homes, transitional housing, emergency shelter, permanent supportive housing, etc.).
• Persons served vs service capacity (reported daily as well as average by month, average by year, etc.)
• Proportion of citywide STEP capacity located in each neighborhood
• Any additional effectiveness or impact metrics adopted by the City
The recommended GIS layer must be updated regularly and made available to the public, neighborhood councils, service providers, and policymakers. A transparent, data-driven visualization tool is essential for demonstrating that fairness is being addressed across all measures and to ensure accountability in siting decisions. Data supporting the GIS layers should also be publicly available and subject to audit by the public.
Citywide Fairness as a Foundational Planning Principle
The goal of these comments is not to shift facilities away from any particular neighborhood, but to ensure that every neighborhood participates fairly in meeting Spokane’s housing and service obligations. A citywide scattered-site doctrine—defined, measured, enforced, and publicly visible—will improve outcomes for unsheltered residents, strengthen neighborhood stability, and align Spokane’s planning framework with state law and best practices in distributed supportive housing.
Closing
We respectfully request that the PlanSpokane 2046 update include a fully articulated Equitable Distribution Scattered Site Program as a core component of the Housing and Land Use elements. Without codified definitions, metrics, public transparency tools, and enforcement mechanisms, Spokane will continue to experience uneven and inequitable siting outcomes. This update is the city’s opportunity to correct that structural gap and establish a fair, citywide approach to STEP housing distribution.
Thank you,
Kathy Hagy
Sue Arnesen
[Personal contact details omitted from the reading text.]
Kathy Hagy Sue Arnesen
Apr 13, 2026
Local Residents
[PDF page 1 of 4]
To: Tirrell Black, Assistant Planning Director
This comment is about the same as the one you received from Nolan Steiner. He did such a great job of writing and stating our thoughts, we pretty much copied his. Thank you for reading this.
Kathy Hagy
Sue Arnesen
[Personal contact details omitted from the reading text.]
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ATTACHMENT / ADDITIONAL PAGES
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[PDF page 2 of 4]
Public Comment – PlanSpokane 2046 Draft EIS
Strengthening & Codifying Equitable Scattered-Site Model for STEP Housing April 13, 2026
Thank you for the opportunity to comment on the PlanSpokane 2046 update. Our comments focus on one significant structural deficiency in the current Comprehensive Plan: Spokane lacks a codified, enforceable mechanism to ensure equitable geographic distribution of all facilities serving unsheltered and vulnerable residents. The absence of such a mechanism has allowed significant concentration of emergency shelters, transitional housing, and supportive housing in only a few neighborhoods, while others have remained functionally exempt from participating in the citywide responsibility to provide restorative housing and services. As will be discussed below, our recommendation is for the City of Spokane to establish an ‘Equitable Distribution Scattered-Site Program’ that ensures societal equity across all Spokane neighborhoods.
Recent Events & Relevance: WA State House Bill 2266 (Governor signed March 27, 2026)
Washington State’s HB 2266 expands where STEP housing must be allowed and restricts local governments from imposing unique barriers to these facilities. While the law increases siting flexibility, it also creates a local responsibility to ensure that the resulting development pattern is equitable and not disproportionately borne by a small number of neighborhoods.
The law requires cities and counties planning under the Growth Management Act to bring their codes into compliance within two years of the bill’s effective date or at their next comprehensive plan update—whichever comes first.
Because of this, this Comprehensive Plan update is the appropriate venue to articulate how Spokane will implement HB 2266 in a manner that complies with state requirements while preventing unbalanced clustering of STEP facilities.
Of importance, HB 2266 removes mandatory public hearings and shifts approvals for STEP housing to administrative, staff-level review. This eliminates the formal, quasi-judicial settings where residents previously provided testimony, raised concerns, and ensured that project-level decisions were transparent and accountable. While residents may still submit written comments or speak in general public-forum settings, these avenues are no longer tied to the actual approval process. As a result, the Comprehensive Plan has become one of the few remaining tools that can protect meaningful public involvement and ensure that fairness, transparency, and accountability are embedded in citywide policy, and not left exclusively to city administrative oversight or discretion.
Because WA State HB 2266 was not in effect during the eight months of prior EIS and Plan 2046 development sessions, the existing draft plan has not yet reflected these new municipal
[PDF page 3 of 4]
public constraints mandated by the legislation. This makes it essential that PlanSpokane 2046 explicitly address the newly reduced public-participation and for the City of Spokane to strengthen the policy framework accordingly for the protection of city residents and neighborhoods.
Establishing an Equitable Distribution Scattered Site Program
The existing Comprehensive Plan references the value of integrated, non-concentrated housing, but it does not define a scattered-site model, require its use, or establish any monitoring or enforcement structure. As a result, the scattered-site concept has remained policy rhetoric rather than operational practice. This needs to change.
The updated Comprehensive Plan should establish a citywide Equitable Distribution Scattered Site Program with the following core elements:
• A formal definition of the scattered-site model as a land-use and service-distribution doctrine that prevents over-concentration of STEP-related facilities in any single neighborhood.
• Application of the program to all facilities whose primary business function is restorative housing, treatment, emergency sheltering, transitional housing, permanent supportive housing, or low-barrier sheltering—regardless of whether they are city-funded, state-funded, federally funded, or privately funded.
• A requirement that siting decisions, permitting, and funding recommendations be evaluated against citywide geographical distribution metrics to ensure equitable placement across neighborhoods.
• Siting decisions must not default to areas with lower property values or greater land availability, as doing so would systematically concentrate STEP facilities and further marginalize the economic development prospects of those neighborhoods.
Required Updates to Planning, Permitting, and Land-Use Processes
To operationalize the Equitable Distribution Scattered Site Program, the Comprehensive Plan should direct an update of, at minimum:
• Permitting processes, requiring geographic and neighborhood distribution analysis as part of a project review.
• Land-use and zoning codes, ensuring that expanded siting allowances under HB 2266 are paired with geographical and neighborhood distribution safeguards.
• Funding and partnership criteria, so that city support prioritizes projects that advance equitable geographic distribution. As stated earlier, the program needs to include all projects regardless of funding source (i.e., city, county, state, federal, private, non-profit, or a combination of funding sources).
• Neighborhood planning, integrating STEP facility distribution into subarea plans and growth strategies.
• Public transparency tools, including a mandatory, publicly accessible GIS layer and heat-map that displays the location of all STEP-related facilities and visualizes geographic distribution metrics across neighborhoods.
[PDF page 4 of 4]
Public GIS Layer and Heat-Map Requirements
The Comprehensive Plan should require the City to maintain a public GIS dashboard that includes:
• Facility locations mapped citywide.
• Bed capacity by site and by neighborhood.
• Facility type by neighborhood (i.e., tiny homes, transitional housing, emergency shelter, permanent supportive housing, etc.).
• Persons served vs service capacity (reported daily as well as average by month, average by year, etc.)
• Proportion of citywide STEP capacity located in each neighborhood
• Any additional effectiveness or impact metrics adopted by the City
The recommended GIS layer must be updated regularly and made available to the public, neighborhood councils, service providers, and policymakers. A transparent, data-driven visualization tool is essential for demonstrating that fairness is being addressed across all measures and to ensure accountability in siting decisions. Data supporting the GIS layers should also be publicly available and subject to audit by the public.
Citywide Fairness as a Foundational Planning Principle
The goal of these comments is not to shift facilities away from any particular neighborhood, but to ensure that every neighborhood participates fairly in meeting Spokane’s housing and service obligations. A citywide scattered-site doctrine—defined, measured, enforced, and publicly visible—will improve outcomes for unsheltered residents, strengthen neighborhood stability, and align Spokane’s planning framework with state law and best practices in distributed supportive housing.
Closing
We respectfully request that the PlanSpokane 2046 update include a fully articulated Equitable Distribution Scattered Site Program as a core component of the Housing and Land Use elements. Without codified definitions, metrics, public transparency tools, and enforcement mechanisms, Spokane will continue to experience uneven and inequitable siting outcomes. This update is the city’s opportunity to correct that structural gap and establish a fair, citywide approach to STEP housing distribution.
Thank you,
Kathy Hagy
Sue Arnesen
[Personal contact details omitted from the reading text.]