Accommodating Affordable Housing Report
City of Spokane
PlanSpokane 2046
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Accommodating Affordable Housing
in the City of Spokane, Washington
a requirement of the Growth Management Act (RCW 36.70A.70)
June, 2025
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Table of Contents
Executive Summary.............................................................................................................................i
I. Introduction.......................................................................................................................................1
II. Report Preparation...........................................................................................................................1
III. Defined Terms...................................................................................................................................2
IV. Housing Affordability Brackets........................................................................................................2
V. The Housing Allocation Planning Tool............................................................................................4
• A Note On Housing Versus Population Growth...........................................................5
• A Note On Housing Affordability Brackets and Grouping..........................................7
VI. Determining Affordability Bracket by Geographic Location.......................................................7
• Using Zoning to Inform Housing Affordability.............................................................7
• Sources for Housing Affordability for Rentals and Purchases..................................8
• Rent/Purchase Price by Affordability Bracket..............................................................9
• Determining Housing Tenure.......................................................................................14
VII. Unit Capacity by Affordability Bracket.........................................................................................14
• Special Cases in the Land Capacity Analysis..............................................................16
VIII. Housing Unit Development Since 20200.....................................................................................16
IX. RESULTS: Housing Unit Capacity by Affordability Bracket........................................................17
Figure 6: City of Spokane Housing Growth Allocation (2020 to 2046)....................................................5
Figure 7: City of Spokane New Housing Need by Household Income (2020 to 2046).........................6
Figure 8: Zoning Classified by Housing Type and Maximum Density.....................................................8
Figure 9: Process for Calculating Income from Median Home Price....................................................10
Figure 10: Rent Affordability by Approximate Location (Apartments.com)...........................................11
Figure 11: Rent Affordability by Approximate Location (Rentcafe.com)................................................11
Figure 12: Home Value Affordability by Approximate Location (Zillow.com)........................................12
Figure 13: Home Value Affordability by Approximate Location (Redfin.com).......................................12
Figure 14 Assumed Affordability by Location–Rentals and Purchases..................................................13
Figure 15 Percent of Rented Homes by Census Tract (All Housing Types)...........................................15
Figure 16 Percent of Owned Homes by Census Tract (All Housing Types)...........................................15
Figure 17 Example Affordability Calculation–LCA to Affordability Bracket...........................................16
Figure 18 Final Results–City of Spokane Housing Unit Capacity by Affordability.................................17
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Executive Summary To determine where in the City units might
The State of Washington has adopted new be affordable for these incomes, the analysis
legislation that requires communities like used publicly available commercial price data
Spokane to ensure they can accommodate from Zillow.com, Redfin.com, Rentcafe.com, and
needed housing in various affordability brackets Apartments.com. Tenure information from the
when updating their Comprehensive Plans. As American Communities Survey (ACS) was then
the City of Spokane is undertaking the next man- used to determine what proportion of units in a
dated Periodic Update to its Comprehensive given part of the city might be rented or owned.
Plan, the City must consider growth for the next By comparing the unit capacity in the LCA against
twenty years. Sufficient capacity must exist in the the affordability information from the web-
City to accommodate housing development in based sources and the tenure (rent vs. own) data
these brackets. from the ACS, the City has determined which
The City has analyzed its housing unit capac- units of capacity in the LCA are expected to fall
ity already as part of the adopted Land Capacity within one of the three affordability brackets.
Analysis (LCA) for the City of Spokane. This report By applying the analysis outlined in this re-
expands upon the findings of the LCA in order to port, the City determined that even though there
differentiate the available land capacity by currently exists sufficient land capacity for
affordability bracket. 33,000+ units, the City cannot likely accommo-
Affordability in Spokane is established by a date the needed units in the most affordable cat-
percentage of the Area Median Income (AMI), set egory, 0-80% AMI. The specific number of units in
by the U.S. Department of Housing and Urban each category the City can accommodate is
Development. Currently, the City of Spokane ex- shown in Figure 1 below.
hibits a median three-person family income of Per the Washington Department of Com-
$90,720 per year, through which the City can de- merce guidance on the subject, the City must
termine the various affordability brackets as fol- now contemplate certain amendments to devel-
lows: opment strategies, code requirements, and pol-
icy towards raising the number of 0-80%AMI
• 0-80% AMI = $0 and $72,600 units the City can accommodate in the next
• 80-120% AMI = $72,601 and $108,864 twenty years. What those amendments might be
will be a topic of the upcoming Environmental
• 120+% AMI = more than $108,864 Impact Statement and Comprehensive Plan Peri-
odic Update.
Figure 1: Final Results–City of Spokane Housing Unit Capacity by Affordability
0-80%AMI Units 80-120%AMI Units 120+%AMI Units
Need (Commerce HAPT, 2020-2046) 15,347 2,588 4,424
Units Completed (2020-2024) 1,328 507 978
Capacity for Additional Growth (2025-2046) 9,654 8,036 12,475
Comparison RESULT -4,365 5,955 9,029
Source: New Units Needed = Department of Commerce Housing Allocation Planning Tool (HAPT). Units Already Built: City of Spokane, Acella Data 2021 to 2024. Capacity for Additional
Growth = Land Capacity Analysis for the City of Spokane, 2025.
Notes: RESULTS row represents the following calculation: (Units Already Built + Remaining Capacity) - New Units Needed. A negative number denotes a lack of sufficient capacity in that
affordability bracket to accommodate the need identified by the State.
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I. Introduction
In 2021 the Washington State Legislature passed new legislation seeking to
remedy the State’s ongoing housing crisis. Described as a bill “supporting emergency
shelters and housing through local planning and development regulations,” House Bill
1220 (HB1220) was passed on April 14, 2021. Among other changes, HB1220
expanded the requirement for Cities and Counties planning under the Growth
Management Act (GMA) to plan for and accommodate housing within their borders
when conducting major updates to their comprehensive plan.
Prior to HB1220, Cities and Counties were only required to quantify and
accommodate their total 20-year housing unit need. HB1220 expanded that
requirement, calling on jurisdictions to consider and plan for housing units broken
down by various affordability brackets, based on Area Median Income (AMI).
Accordingly, the Washington Department of Commerce (Commerce) provided the
Housing Allocation Planning Tool (HAPT) and various guidance documents to help
jurisdictions meet the new requirements.
The following analysis conforms largely to the guidance provided by Commerce,
primarily Commerce publications Establishing Housing Targets for your Community
(Book 1) and Guidance for Updating your Housing Element (Book 2). While HB1220
also included the requirement that the City consider racially disparate impacts and
displacement, those topics will be addressed in a separate study underway by the City
of Spokane and are not explored in detail here. Additionally, HB1220 requires that City
quantify their ability to accommodate emergency housing—a topic which will be
addressed in a separate report from this one.
II. Report Preparation
The following report was prepared by the Planning & Economic Development
department at the City of Spokane, utilizing the following staff:
Project Manager & Chief Analyst: Kevin Freibott, Senior Planner
Planning Director: Spencer Gardner, AICP
Deputy Planning Director: Tirrell Black, AICP
Economic Development: Amanda Beck, Planner II
This report is a follow-up to the City’s Land Capacity Analysis (LCA), adopted earlier
in 2025. Readers are referred to that document for greater detail as to the available
lands within the City and the development potential therein.
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III. Defined Terms
Prior to discussing the housing allocation and the City’s capacity to accommodate
those units, it’s important to understand several key terms used by Commerce, the
HAPT, and mentioned in GMA and HB1220. Those terms are as follows:
Area Median Income (AMI): The HAPT describes housing affordability by AMI,
specifically as a percentage of the Spokane County AMI. AMI is established by
the United States Department of Housing and Urban Development (HUD) and
is updated annually for the use of housing providers and local government.
HUD sets the AMI for the entire Spokane metropolitan area, not for cities
specifically. For financial year 2025, HUD states the AMI for the Spokane area
is $100,800. Commensurately, a household making $100,800 annually in
Spokane would be a 100%AMI household. Conversely, a household with an
annual income of $50,400 would be in the 50%AMI bracket.
Permanent Housing: Permanent housing units provide permanent
residence, whether or not those units are provided along with supporting
services. A housing unit can be any type of unit, be it a standalone house,
apartment, condo, middle housing, or some other type of housing. For the
purposes of this analysis, group housing is not considered as part of the
permanent housing number, commensurate with HB1220 requirements.
Permanently Supportive Housing (PSH): PSH units are subsidized housing
units with no limit on the length of stay, prioritizing housing for people who
require comprehensive support services to retain tenancy. Generally, PSH is
paired with on-site or off-site voluntary services designed to support a person
living with a complex and disabling behavioral health or physical health
condition who either was experiencing homelessness or was at imminent risk
of homelessness prior to moving into housing. Simplified, PSH provides both
housing and support to help prevent those in PSH from entering or returning
to homelessness. PSH is quantified in the HAPT by unit.
IV. Housing Affordability Brackets
The analysis required by HB1220 and GMA calls for the City to quantify and
account for new housing in several affordability ranges, or brackets, based on AMI.
The brackets are based on AMI, set by HUD, and represent a range of household
incomes in the extremely-low-, very-low-, low-, and moderate-income ranges. Also
included are higher incomes greater than the AMI, such as 120% AMI, but legislation
has fewer requirements for planning for these housing types.
By calculating income as a percentage of AMI, the range of household incomes in
each bracket can be determined. This is complicated somewhat by the fact that AMI
changes by household size, rising as the number of people in the household rises.
While most agencies and jurisdictions rely on the 4-person number, Commerce allows
for jurisdictions to make adjustments according to local average household size.
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The following table (Figure 2) provides the current AMI brackets, based on the
region’s median family income of $100,800. The table includes both the 3-person
income limits and the 4-person income limits. While 4-person family limits are most
often cited when discussing AMI, the current average household size in the City of
Spokane is closer to 3-persons1. Per Commerce Guidance, when this is true the
jurisdiction can consider home affordability by using the 3-person limit instead2.
Accordingly, the analysis in this report will do so.
Figure 2: Income Brackets in Spokane County (2025)
3-Person Family 4-Person Family
Affordability Bracket %AMI Income Range (Annual) Income Range (Annual)
Extremely Low Income 0-30% AMI $0 - $27,250 $0 - $30,240
Very Low-Income 30-50% AMI $27,251 - $45,400 $30,241 - $50,400
Low Income 50-80% AMI $45,401 - $72,600 $50,401 - $80,640
Moderate Income 80-100% AMI $72,601 - $90,720 $80,641 - $100,800
High Income 100-120% AMI $90,721 - $108,864 $100,801 - $120,960
Highest Income 120% + AMI $108,865 and up $120,961 and up
Source: 2025 Income Limits Documentation System, United State Housing and Urban Development Department (HUD). Retrieved online at www.huduser.gov.
Notes: Calculations of income range, maximum annual housing cost, and maximum monthly housing cost made by City staff from HUD income limits.
The Commerce guidance directs Jurisdictions towards assuming that a household
should expect 30 percent of its income to go towards housing costs. Incidentally, this
is the threshold for “cost burdened” households used by the State and most local
jurisdictions. Those households that pay more than 30 percent of their monthly
income towards housing costs are considered “cost burdened.”
In order to analyze the relationship between rents in the City of Spokane and the
income brackets offered by AMI, first the appropriate maximum monthly housing cost
for each bracket must be calculated. Converting annual income to determine what
comprises 30 percent of the monthly income requires a simple calculation:
Maximum Monthly Housing Cost = Annual Income / 12 * 0.30
However, an additional calculation must be made because housing cost, when
considered by Commerce and the state, includes monthly utility costs in addition to
rent or mortgage payments. The amount to subtract from housing cost for utilities is
informed on a county by county basis by local housing authorities. In the case of
Spokane County, the Spokane Housing Authority publishes worksheets for the
allowances for certain household utilities. Spokane Housing Authority’s most current
utility allowances are provided by housing type and the utilities involved (e.g. whether
they be gas or electric, forced air or furnace). By using the most common utility types
in Spokane, the following utility allowances can be assumed (see Figure 3).
Accordingly, the amounts in Figure 3 should be incorporated into the maximum
monthly housing cost calculation by subtracting them from the total. For the purposes
1 2.35 according to the US Census American Communities Survey, 2023 5-year Average.
2 See p. 35 of Guidance for Updating Your Housing Element by the Department of Commerce, August,
2023.
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Figure 3: Utility Allowances by Unit Type and Number of Bedrooms, Spokane County
Unit Type 0 Bedroom 1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom 5 Bedroom
High-Rise/Apartment $206 $213 $227 $243 $259 $282
Middle Housing & Low Rise $216 $224 $243 $263 $282 $300
Single-Unit, Duplex, Mobile Home $232 $244 $263 $283 $304 $323
AVERAGE VALUE $218 $227 $244 $263 $282 $302
Source: Spokane Housing Authority, February 2025.
Notes: Assumes electric heating, electric cooking, and electric water heating, indicated by the source as the most common condition. The average value is a calculated value of the average of
the values in the three unit types. It is not provided by Spokane Housing Authority.
of this analysis, and consistent with the overall assumption of 3 persons per unit, this
analysis will apply 2 bedroom average value of $244. This results in the following
calculation for maximum monthly rent or mortgage payment:
Maximum Monthly Housing Cost = Annual Income / 12 * 0.30 - $244
By applying this formula, the maximum monthly housing cost for each
affordability bracket result can be determined, as shown in Figure 4 below. Note that
the analysis in this report will utilize the three-person household data as discussed
previously.
Figure 4: Rent/Mortgage Payment Limits in Spokane County
Persons Per Household
AMI Bracket One Two Three Four Five Six
30% AMI $312 $378 $437 $559 $678 $797
50% AMI $665 $782 $891 $1,016 $1,098 $1,181
80% AMI $1,195 $1,387 $1,571 $1,772 $1,916 $2,058
100% AMI $1,546 $1,789 $2,024 $2,276 $2,459 $2,642
120% AMI $2,192 $2,477 $2,780 $3,003 $3,226 $3,448
Source: Calculated values based on method in text.
Notes: Assumes 30 percent of monthly income calculated from annual Area Median Income, minus utility allowances.
V. The Housing Allocation Planning Tool (HAPT)
Commerce has provided a complex set of tools for Counties and Jurisdictions to
utilize when determining their housing unit growth allocation through the planning
horizon. This tool, known as HAPT, provides the countywide housing allocation based
on the planning horizon and the County’s overall population growth, as well as
individualized jurisdiction housing growth based upon the share of the County’s
growth each jurisdiction expected to accommodate.
In the case of the Spokane County numbers, the County has adopted the middle
housing forecast from OFM. This forecast is the most statistically supported option
and provides for growth of 100,065 persons in the County by 2046. By using the
regionally adopted projections, the entire county’s allocation is provided (see Figure 5
below).
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Figure 5: Countywide Housing Growth Allocation–Cities Included
Permanent Housing Needs by Income Level in Housing Units (as % of Area Median Income)
TOTAL 0-30%AMI
Non-PSH PSH 30-50%AMI 50-80%AMI 80-100%AMI 100-120%AMI >120%AMI
Current Estimated Housing 221,840 6,613 937 34,798 91,803 32,035 20,981 34,673
New Housing by 2046 297,024 26,518 6,651 48,418 100,647 36,807 24,918 53,065
Additional Units Needed 75,184 19,905 5,714 13,620 8,844 7,772 3,937 18,392
Source: Spokane County HAPT, January 2025.
Notes: AMI = Area Median Income, as set by the United State Housing and Urban Development Department (HUD). Current AMI is for FY2025.
Once countywide need is determined, HAPT divides up countywide growth by a
number of possible methods. Spokane County and the Cities within it have chosen to use
“Method C” in HAPT, as it provides for both a statistical division of the overall growth
shown in Figure 5, but also accounts for housing need outside cities but within the Urban
Growth Area (UGA). See Appendix A for more information on this method.
HAPT requires that Counties apportion housing need among the Cities as a
percentage of regional housing growth each jurisdiction expects to accommodate.
Ultimately, the region agreed on a method to convert projected population share into
housing share, which was then input into HAPT (see Appendix A). Regarding the City of
Spokane, while the city is expected to experience 23.34% of population growth, the City’s
housing need represents 29.74% of the countywide housing growth. This is
commensurate with recent development in Spokane that has exceeded 1,300 units
annually since the recovery from COVID. By inputting 29.74 percent of countywide
housing growth for the city into HAPT, the tool provides the following housing need in the
city shown in Figure 6 below.
Figure 6: City of Spokane Housing Growth Allocation (2020 to 2046)
Permanent Housing Needs by Income Level (as % of Area Median Income)
TOTAL 0-30%AMI
Non-PSH PSH 30-50%AMI 50-80%AMI 80-100%AMI 100-120%AMI >120%AMI
Estimated Current Housing 99,938 3,534 937 19,479 47,090 11,873 7,118 9,907
Additional Units Needed 22,359 6,452 1,851 4,413 2,631 1,418 1,170 4,424
Source: Spokane County HAPT, January 2025.
Notes: AMI = Area Median Income, as set by the United State Housing and Urban Development Department (HUD). Current AMI is for FY2025.
As shown above, the City is expected to require 22,359 additional permanent housing
units between 2020 and 2046. While those units are spread among all the affordability
brackets, that spread is not equal bracket to bracket. Figure 7 on the following page
provides a graphical depiction of that need by bracket.
A Note On Housing Units Versus Population Growth
The city is expected to grow by 23,357 people between 2020 and 20463. Compared to
a housing need of 22,359 homes (Figure 6) the two projections would seem incongruous,
3 Land Capacity Analysis for the City of Spokane, 2025.
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Figure 7: City of Spokane New Housing Need by Household Income (2020-2046)
Source: Spokane County HAPT, January 2025.
Notes: Income limits provided by United State Housing and Urban Development Department, FY2025 Income Limits Documentation System, retrieved online at
www.huduser.gov.
as if the HAPT was assuming that most new residents will live alone in their home. This is
not the case, however, as HAPT provides for more than the housing units needed to
accommodate new population growth.
Per the Commerce guidance on the HAPT, the allocation accounts for three areas of
housing need, as follows:
• New Growth. The housing units to accommodate new population growth in the
city between 2020 and 2046. The proportion of new housing in the HAPT
corresponding to this need is approximately 60 percent of the total.
• Underproduction. In its study of housing needs and production in Washington,
Commerce identified that, overall, the state had under-produced housing by a
significant degree. This was largely due to COVID and other economic factors
outside the control of Cities and Counties, but the need is there regardless. To
remedy this situation, 30 percent of the HAPT housing allocation is included to
address issues with overpriced housing and historic underproduction. As a result,
approximately 30 percent of the HAPT allocation addresses the housing needs of
people who are already residing in Spokane.
• Homelessness. A small percentage of the overall HAPT allocation, approximately
10 percent, is intended to address the need of those experiencing homelessness
or in danger of imminent homelessness. As with underproduction, much of this
need is for people already in Spokane, not new growth.
While the City of Spokane has been allocated 22,359 units between 2020 and 2046,
only about 13,415 of those units are to accommodate new residents. Regardless, HB1220
states that the City must have enough capacity to accommodate the entire allocation, thus
this analysis in this report concerns the full number of units allocated (see Figure 6).
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A Note on Housing Affordability Brackets and Grouping
While HAPT provides for housing need in seven brackets (see Figure 6), difficulties
arise in providing such a high level of differentiation in housing data. It is near impossible
to divide housing costs into so many brackets due to the limited number of zoning types
and the high number of variables involved. As such, most jurisdictions have decided to
group the affordability brackets into the following three groups:
• 0-80% AMI – The highest need bracket, requiring the most program/funding
support.
• 80%-120% AMI - The middle bracket, where some support is necessary, but some
market-rate development may occur as well. Some organizations label this group
as “workforce housing.”
• 120%+AMI – The highest cost group, often called “market rate” housing.
Commerce’s guidance assumes little to no support for these householders.
Not only are jurisdictions using these three groupings, but the example tables and
calculations in Commerce’s own guidance group affordability thus. Accordingly, the City of
Spokane analysis will use the same groups.
VI. Determining Affordability Bracket by Geographic Location
As demonstrated above, the HAPT indicates the City must accommodate 22,359
additional housing units between 2020 and 2046. To determine what capacity exists in the
city to accommodate those units, Commerce provides specific guidelines in their
“Guidance for Updating Your Housing Element,” published August 2023. This guidance
directs jurisdictions to consider their zoning and which housing types might be assumed
in those zones. Additionally, the guidance from Commerce directs jurisdictions to use
multiple data sources to determine what affordability can be expected from various
housing types. The following analysis conforms substantially to the Commerce guidance.
Using Zoning to Inform Housing Affordability
The Commerce guidance indicates that jurisdictions should compare the housing
types allowed in individual zones to inform what level of affordability might be expected
in given areas. To this end, the City analyzed all zones in which housing is allowed and
compared the housing types and densities assumed for each, as shown in Figure 8 on the
following page.
The City of Spokane is somewhat unusual, in that the municipal code allows for the
development of residential uses in all zones except industrial zones. Additionally, most
housing types (single-unit and middle housing) are allowed everywhere. Save for the lower
density residential zones (RA, R1, and R2), multi-unit housing is allowed in every zone. This
makes it difficult to impossible to differentiate housing development in the city only by
considering zoning.
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Figure 8: Zoning Classified by Housing Type and Maximum Density
Zone Housing Types Allowed Maximum Density Assumed Density Density Group
Allowed
RA Single-Unit and Middle Housing 10 (approximate)
R1 10 (approximate) 5-9 du/ac Residential Low
R2 Middle Housing 20 (approximate)
RMF Middle Housing & Multi-Unit 30 (approximate) 29 du/ac Residential High
RHD No Limit
NR
CB
GC 30.2 du/ac in 33%
O Middle Housing & Multi-Unit No Limit of the Area Non-Residential
OR
CC#
CA1
DTC
DTG Middle Housing & Multi-Unit No Limit 44.4 du/ac in 33% Downtown
DTU of the area
DTS
Source: Spokane Municipal Code, SMC Title 17; Shaping Spokane, the Spokane Comprehensive Plan (Chapter 3); Land Capacity Analysis for the City of Spokane
(2025).
Notes: Maximum density is approximate in residential zones due to the fact that lots under 2 acres are not restricted by density–rather the SMC uses height and
setbacks to control for density in these zones. Assumed Density and Density Group conform to the City’s Land Capacity Analysis, adopted March 10, 2025, via
resolution RES 2025-0015.
Further complicating matters, the City does not have sufficient data to correlate
housing type with housing affordability as suggested by the Department of Commerce.
This is not a failure by the City, rather the requirement to track such data did not exist
historically, so these values weren’t collected. To remedy this, the Commerce guidance
provides for the option for Cities to augment and adjust affordability assumptions using
publicly available market data.4
Sources for Housing Affordability for Rentals and Purchases
Cities, Spokane included, often do not track the affordability of a given housing unit
when permitting its construction. Accordingly, the City has limited internal sources that
might indicate at what level of affordability housing development is occurring. As a result,
the City must look outside it’s own data for this information.
Per the suggestion in the Commerce guidance, the City has utilized data from multiple
sources to determine housing affordability by type, including the following:
• Home Value (purchases) by neighborhood provided by Zillow.com. Zillow
provides a combination of self-reported and industry information on home
purchases, assembling that data into ‘neighborhoods’ that generally conform to
certain parts of the city.
4 See p. 32 of Guidance for Updating Your Housing Element by the Department of Commerce, August,
2023.
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• Home Value (purchases) by neighborhood provided by Redfin.com. Redfin is
similar to Zillow, but follows a more industry-based approach for home value,
lessening the impact of individual self-reported home values skewing the results.
As with Zillow, Redfin data can be divided up roughly by neighborhood.
• Median Rents by neighborhood provided by Apartments.com. Like with Zillow
but in this case concerning rentals, Apartments.com is somewhat weighted by
self-reporting while also accounting for historic data related to past listings that
may not currently be open for rent.
• Median rents by neighborhood provided by Rentcafe.com. Similar to Redfin,
RentCafe’s data is backed up by industry information in addition to current active
listings. RentCafe also directly contacts management companies and real estate
professionals to augment their data with additional confirmation.
Rent/Purchase Price by Affordability Bracket
Before a comparison can be made between median house price and monthly housing
costs, the home price must be converted to an assumed mortgage payment. Following the
Commerce guidance, the City utilized the Fannie Mae mortgage calculator to determine
what the approximate monthly mortgage payment might be for home purchases in the
City. The Fannie Mae mortgage calculator5 requires the user to input various assumed
factors that affect the payment amount. The factors used for this analysis were the most
common factors reported by Realtor.com for home purchases in Spokane County,
namely:
• 5 percent down payment;
• 30-year fixed rate loan; and
• 6.8% interest.
Plugging those factors into the Fannie Mae mortgage calculator returned a monthly
payment for each neighborhood’s median home price. That monthly value was then
converted into the annual income necessary to maintain such a payment amount. For this,
the Commerce assumption that 30 percent of annual income as the maximum that should
go to home payments/rents was assumed. The calculation shown in Figure 9 on the
following page provided the income required for a given median home price.
The same base calculation was used to determine the income required for rentals,
using the median rents provided by Apartments.com or RentCafe. Since those sources
provide rents in a monthly form to begin with, the first step (using a mortgage calculator)
was not necessary. Income required for a given median rent was calculated by dividing by
0.3 and multiplying by 12 only.
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Figure 9: Process for Calculating Income from Median Home Price
Source: City of Spokane, based on WA Department of Commerce, “Guidance for Updating your Housing Element” (August 2023).
Notes: Fannie Mae mortgage calculator assumed a 5 percent down payment, 30-year fixed rate mortgage, and 6.8% interest, as averages provided by Realtor.com
for Spokane County.
Utilizing the calculations above, an affordability bracket can be assumed for each part
of the City for both median home price (purchases) and median rent (rentals). As an
example calculation for rental units, the following sample calculation utilizes the RentCafe
reported average rent for the Cliff-Cannon neighborhood:
1. Average Rent = $1,521
2. Assuming 30% of Income for Rent (Rent / 0.3) = $5,070
3. Multiplied by 12 to convert from monthly to annual: $60,840
Because $60,840 falls within the 0-80%AMI bracket (see Figure 2), we can assume that
rental units in the Cliff-Cannon neighborhood generally fall within that bracket. By using
this same calculation for both sources of rental data (Apartments.com and RentCafe) the
affordability bracket for each area in the city can be determined, as shown in Figure 10
and Figure 11 on following pages.
As an example calculation for units for purchase, the following sample uses the Zillow.
com reported median home value in the Northwest Neighborhood:
1. Median Home Value = $346,592
2. Mortgage Payment (Fannie Mae) = $2,966
3. Assuming 30% of Income for Mortgage (Payment / 0.3) = $9,887 a month
4. Multiplied by 12 to convert from monthly to annual = $118,640
Because $118,640 falls within the 120+%AMI bracket (Figure 2), we can assume that
homes for purchase in the Northwest Neighborhood generally fall within that bracket. By
using this method for both sources for sales data (Zillow and Redfin) the affordability
bracket for each area can be determined, as shown in Figure 12 and Figure 13.
Summary tables showing the calculations above for all four sources and all areas of
the city are included at the end of this report. See Appendix B for more details.
2025 Accommodating Affordable Housing Page 10 of 20
[Page 16]
Figure 10: Rent Affordability by Approximate Location (Apartments.com)
Source: Apartments.com, data
from May 2025.
Notes: Areas used by the source do not
necessarily match neighborhood
boundaries, as shown. The source had no
data for blank areas.
Figure 11: Rent Affordability by Approximate Location (Rentcafe.com)
Source: Rentcafe.com, data
from May 2025.
Notes: Areas used by the source do not
necessarily match neighborhood
boundaries, as shown. The blank area
contains zero housing units, thus it is not
shown here.
Page 11 of 20 2025 Accommodating Affordable Housing
[Page 17]
Figure 12: Home Value Affordability by Approximate Location (Zillow.com)
Source: Zillow.com, data from
May 2025.
Notes: The source had no data
for blank areas. Areas used by
the source do not necessarily
match neighborhood
boundaries, as shown.
Figure 13: Home Value Affordability by Approximate Location (Redfin.com)
Source: Redfin.com, data from
May 2025.
Notes: The source had no data
for blank areas. Areas used by
the source do not necessarily
match neighborhood
boundaries, as shown.
2025 Accommodating Affordable Housing Page 12 of 20
[Page 18]
By comparing and combining the four maps above, general affordability assumptions
can be made for both rental and purchase homes by location in the City, as shown in
Figure 14. These assumptions were used by this analysis to assign assumed affordability
to either rental units or homes for purchase in each part of the City.
Figure 14: Assumed Affordability by Location–Rentals and Purchases
Source: City of Spokane, Synthesized from multiple sources.
As shown above, rented units in the City generally fall within the 0-80%AMI bracket,
though two smaller areas tend to be more expensive, falling within the 80-120%AMI
bracket. The picture for housing units for purchase is more complex, with a somewhat
even split between areas exhibiting 80-120%AMI units and areas in the 120+%AMI
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[Page 19]
bracket. By determining affordability by geography in this way, the analysis can be more
nuanced as to the expected affordability of new units in the City over the next twenty
years. Many jurisdictions can consider their affordability for the entire City, but the great
size of Spokane (nearly 70 square miles) points to the need for a more refines analysis
than simply one value for the entire city. The approach outlined above grants that higher
level of detail.
Determining Housing Tenure
Now that the areas of the City in which certain affordability brackets can be assumed
has been established, the only remaining step is to determine which new units might be
for rent and which might be for purchase. Of note, it is inaccurate to assume that all
detached homes are for purchase, as the rental house market in Spokane is rather robust.
To determine the split of rented and purchase units expected in the city, this analysis
utilized data from the American Communities Survey (ACS) 5-year average reports from
2023. ACS provides sample-based data to fill in between the decennial censuses, providing
a relatively reliable data source for tenure (owned versus rented).
By polling ACS data, the City determined the mix of owned and rented homes in each
Census Tract, resulting in the maps on the following pages (Figure 15 and Figure 16). By
utilizing the ratio of rented to owned homes in each tract, any capacity for new housing
development in those tracts can be split accordingly into assumed rental units and units
for purchase. For instance, assume a given Census Tract exhibits 60% owned and 40%
rented units. That same Tract, say, shows an expected affordability of 80-120%AMI for
rental units and 120%+AMI for purchased units (per Figure 14). If that tract has capacity
for 100 units, 40 of those units could be assumed to be rented in the 80-120%AMI bracket
and 60 units could be assumed to be sold in the 120+%AMI bracket. This is precisely the
calculation used to determine final capacity in this report.
V. Unit Capacity by Affordability Bracket
The Commerce guidance states that once a jurisdiction has determined the
affordability of various housing types, zones, and locations, then the unit capacity in those
areas should be incorporated into the analysis. As the City has completed its LCA6, that
analysis provides a theoretical unit capacity in various locations throughout the city. Per
Commerce’s guidance, the unit capacity from the LCA was used in this analysis.
Because the LCA provides for potential units of capacity by geographic location within
the city, each unit of capacity in the LCA can be compared to the tenure assumptions
shown in Figures 15 and 16, producing an assumed number of rented units and owned
units of capacity in each Census tract. For example, if the LCA found that 100 units of
capacity exist in a tract of 60 percent owned and 40 percent rented homes, this analysis
assumes that 60 units of capacity would be owned and 40 units of capacity would be
rented.
6 Land Capacity Analysis for the City of Spokane, adopted March 10, 2025, via resolution RES 2025-0015.
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Figure 15: Percent of Rented Homes by Census Tract (All Housing Types)
Figure 16: Percent of Owned Homes by Census Tract (All Housing Types)
Source (Both): US Census Bureau, American Communities Survey, 2023 5-Year Average
Note (Both): Areas around the Spokane International Airport are blank due to a lack of any housing in this area.
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Once the assumptions for tenure (owned versus rented) are applied to units of
capacity in the LCA, the affordability of those units can be inferred by comparing the
location to the affordability in Figure 14. A schematic example of this calculation is shown
below (Figure 17).
Figure 17: Example Affordability Calculation–LCA to Affordability Bracket
Special Cases in the Land Capacity Analysis
The LCA considers two special areas in its analysis, those of adopted Planned Unit
Developments (PUDs) that have not yet completed platting all lots, and the South Logan
Transit Oriented Development (South Logan TOD) subarea analysis. Readers are referred
to the LCA itself for details on how these areas were handled in the LCA.
Following the process in the LCA, the analysis of affordability herein considers the
PUDs and South Logan TOD area separately as well. This is for the same reason—a greater
level of specificity is known about the development potential in these areas. Regarding the
PUDs, these typically involve either single-unit homes or multi-unit buildings as part of a
larger planned development with (generally) higher costs for residents, both rented or
purchased. Accordingly, for any units of capacity within PUDs the analysis in this report
assumes those units to occur at the more costly affordability bracket—namely 80-120%
AMI for rental units and 120+% AMI for purchased homes. Additionally, most PUDs include
covenants that restrict the renting of homes within PUDs. As a result, this analysis
assumes that 100 percent of single unit homes in PUDs will be for purchase. Likewise, all
multi-unit potential in PUDs is assumed to be for rent.
When considering the South Logan TOD area, the project area located in a part of the
City with the least affordable brackets in both rentals and purchase homes. Accordingly,
all units in the South Logan TOD area are assumed by this analysis to be in the 120+% AMI
bracket for purchase and the 80-120%AMI bracket for rentals.
VI. Housing Unit Development Since 2020
The housing allocation provided by Commerce via the HAPT establishes need between
the years 2020 and 2046. Because development has continued since 2020 and the unity
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[Page 22]
capacity presented by the LCA is for 2025, housing units built between 2020 and 2025
should be accounted for. In essence, any unit constructed between 2021 and now would
reduce the overall need identified by the HAPT.
To do this, all residential permits issued between January 1, 2021 and December 31,
2024 were pulled from the City’s permit database. All completed units–-those issued a
Certificate of Occupancy or indicating a successful final inspection–were geo-located and
compared to the affordability assumptions in Figure 14, resulting in a tabulated number
of completed units in each of the affordability brackets. These units were then subtracted
from the “new” units called for in HAPT. This number of completed units is included in the
final table of this report (see below).
VII. RESULTS: Housing Unit Capacity by Affordability Bracket
Overall, the LCA found that the City has sufficient theoretical capacity to
accommodate slightly more than 30,000 dwelling units. By applying those units of capacity
to the assumptions and calculations described in the sections above, those units are
divided among the three affordability brackets as follows (see Figure 18):
According to this analysis, informed by and in compliance with the guidance of the
Figure 18: Final Results–City of Spokane Housing Unit Capacity by Affordability
0-80%AMI Units 80-120%AMI Units 120+%AMI Units
Need (Commerce HAPT, 2020-2046) 15,347 2,588 4,424
Units Completed (2020-2024) 1,328 507 978
Capacity for Additional Growth (2025-2046) 9,654 8,036 12,475
Comparison RESULT -4,365 5,955 9,029
Source: Need = Department of Commerce Housing Allocation Planning Tool (HAPT). Completed Units: City of Spokane,
Acella Data 2021 to 2024. Capacity for Additional Growth = Land Capacity Analysis for the City of Spokane, 2025,
classified per the analysis outlined in this report.
Notes: Completed units represent those building permits issued by the City between January 1, 2021 and December 31,
2024, showing that either a certificate of occupancy was issued or a final inspection has been completed.
Resulting unit capacity represents the result of the analysis and calculations described in this report.
Comparison represents the following calculation: (Completed Units + Unit Capacity) - Need = Comparison RESULT. A
negative number denotes a lack of sufficient capacity in that affordability bracket to accommodate the need identified
by HAPT.
Department of Commerce, the City of Spokane does not currently contain sufficient
capacity to accommodate needed growth in the 0-80%AMI bracket. Concurrently, the
City has excess capacity in both the 80-120% AMI bracket and the 120+% AMI bracket.
To comply with the requirements of House Bill 1220, the City must consider, as part of the
overall Comprehensive Plan Periodic Update, actions sufficient to raise the capacity in the
0-80%AMI bracket by nearly 4,400 units. Those changes will likely be identified during the
preparation of the Environmental Impact Statement for the Comprehensive Plan Update,
as well as during preparation of the Update itself. For more information on these changes
as they are developed, readers are encouraged to visit www.planspokane.org.
Page 17 of 20 2025 Accommodating Affordable Housing
Appendix to Accommodating Affordable Housing in the City of Spokane, 2025
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Recommendation for HAPT: Housing Share
PLANNING TECHNICAL ADVISORY COMMITTEE
Report and Recommendation to the Steering Committee of Elected Officials
Periodic Update under the Growth Management Act, 2026 to 2046
Written and Recommended by PTAC, January 2025
[Page 32]
Executive Summary
The Planning Technical Advisory Committee (PTAC) has identified a possible issue with previous runs of
the Housing for All Planning Tool (HAPT), which all communities planning under the Growth Management
Act have been advised to use when allocating housing by affordability for the region. The intended input
for the tool—the data that is provided to the tool and then used to calculate each jurisdictions’ housing
allocation—is the share of housing growth each jurisdiction is expected to accommodate. Unfortunately,
due to unclear instructions, the previous HAPT outputs shared with the Steering Committee of Elected
Officials (SCEO) used the share of population growth instead.
Following a review of the data and the HAPT itself, the PTAC recommends that the region use housing
growth share as the input for the HAPT, specifically a housing growth share created by applying the same
assumptions built into the HAPT tool itself to convert the adopted population share to housing share.
Of note, this recommendation does not affect which method within HAPT is utilized. The existing SCEO
recommendation for the method known as “A Prime” is not affected by PTACs recommendation in this
memo.
The full output of the HAPT, assuming that housing share generated in the way recommended by PTAC is
used, is attached to the end of this memo.
Introduction
Following the SCEO vote to recommend Method “A Prime” when using the HAPT, the members of PTAC
identified that there had been some confusion as to which inputs should be provided to the HAPT when
calculating housing share. As a result, PTAC’s Housing Subcommittee met several times in the third and
fourth quarters of 2024 to consider how this might affect the housing allocation output from HAPT. In
essence, it appears to PTAC that the HAPT was intended to be provided with the share of housing growth
each jurisdiction is expected to accommodate, while previous use of the HAPT utilized the share of
population growth instead.
After discussing this at length, PTAC has developed a method for converting the currently adopted
Population Share 1 to housing growth share, which can then be input into HAPT. This memo outlines the
recommendation by PTAC for doing this, and provides the summary growth numbers for each jurisdiction
that results.
HAPT Method A Prime
At their meeting on September 25, 2024, the SCEO voted to recommend the use of the “A Prime” method
in the HAPT. Throughout this discussion and recommendation by PTAC, no change to this method is
anticipated or recommended. PTAC feels that SCEO’s original recommendation, adopted on September
24, 2024, does not require revision to accommodate PTAC’s recommendations herein.
1 Adopted by BOCC Resolution 24 -0348 on June 18, 2024.
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Housing Share versus Population Share
When PTAC and SCEO previously saw the “A Prime” results, it was always using the share of population
growth assigned to each jurisdiction per the adopted allocation 2. However, after multiple conversations
within PTAC and with Commerce staff, it was apparent that the instructions in HAPT were unclear and
that the tool was instead asking for the share of housing growth.
The share of population growth and the share of housing growth are directly related to each other, but
due to certain factors they are rarely the same number for a given jurisdiction. For instance, household
size (people per household) in each jurisdiction is not the same nor does it stay static over time.
Household size is continually changing from year to year. Furthermore, some jurisdictions contain a larger
amount of group quarters housing (i.e. college dorms, prisons, treatment centers) and that rate changes
over time. Those living in group quarters do not require additional housing units, thus they must be
subtracted from the overall population growth share for each jurisdiction.
Because of these factors, it is important to develop a share of housing each jurisdiction for the entirety of
the planning horizon (through 2046), not just today. Jurisdictions differ from each other and some
attempt to differentiate their allocations accordingly should be made as well.
A Note on the Underproduction of Housing
An additional factor has been raised by public commenters and PTAC members that is worth discussing
here. That factor is the known historic un derproduction of housing statewide. Commerce’s research has
made it clear that development in jurisdictions across the state have been lower than what is required to
house existing populations. As a result, many jurisdictions’ current housing stock is already too small to
accommodate the need of the existing population, not to mention the growth that is coming.
It is important to note that HAPT factors this underproduction into its results. Accordingly, the number
of housing units a jurisdiction may be allocated when using HAPT will appear high when compared to
population growth. This is specifically because HAPT attempts to also allocate sufficient housing to
accommodate the recent underproduction of housing as well as future growth. This condition is true
regardless of which input is used for HAPT.
Determining Housing Share
The Department of Commerce has not provided jurisdictions with a method for calculating housing
growth share. Likewise, GMA does not mandate that Cities and Counties use a particular method to
develop housing share. However, the PTAC subcommittee found that the HAPT itself provides one
possible method.
While PTAC spent considerable time exploring other ways to convert population growth to housing
growth, ultimately PTAC felt that because the resulting housing share would be input into HAPT, it was
most defensible to use the assumptions already built into HAPT to calculate housing share. That way, the
same set of assumptions would be applied to all parts of the tool and any unintentional bias or
modification of results would be minimized.
2 Adopted by BOCC Resolution 24 -0348 on June 18, 2024.
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Essentially, the housing share for each jurisdiction would be calculated directly from the population share
already adopted by the BOCC. While it is more sophisticated than can be expressed simply here, the
method for calculating housing share from population share is generally3 as follows:
[(Population Share – Group Quarters Population) / Household Size] + 6% to Account for Vacant Homes
For the purposes of the HAPT, the tool assumes that household size is shrinking over time and that each
jurisdiction will see the same share of group housing in the County as they are in 2020. The resulting
housing share for each jurisdiction and area is as shown in the following table. Again, when considering
the resulting housing share, the following should be kept in mind:
• Population share and housing share are not the same thing, though they are related to one
another.
• Housing share in the tool is somewhat elevated to account for historic underproduction of
housing.
Table 1: Population and Housing Share Compared
Share: Share: Share: Share:
Population Housing Population Housing
Jurisdiction Growth Growth Jurisdiction Growth Growth
Spokane County (Whole) 100.00% 100.00% Airway Heights 6.66% 5.26%
All Unincorporated Areas 35.21% 31.14% Cheney 3.37% 2.76%
Unincorporated Rural 4.70% 8.24% Deer Park 1.36% 1.44%
Unincorporated UGA 30.51% 22.81% Fairfield 0.00% 0.00%
Incorporated County 64.79% 68.95% Latah 0.00% 0.00%
Liberty Lake 8.78% 6.89%
Medical Lake 0.24% 0.44%
Millwood 0.05% 0.14%
Rockford 0.07% 0.09%
Spangle 0.00% 0.02%
Spokane 23.34% 29.74%
Spokane Valley 20.90% 22.16%
Waverly 0.01% 0.02%
As shown in the table, when comparing population share to housing share, some jurisdictions are
expected to accommodate a lower share of housing growth than population growth (e.g. Liberty Lake)
while others are shown to expect a higher share of housing than population (e.g. the City of Spokane).
Why this happens is complex and due to the fact that HAPT uses multiple factors from multiple sources
to determine these amounts.
Because the HAPT only has one input for each jurisdiction—share of housing growth—those jurisdictions
where the housing share is larger than population share can expect their housing number output from
HAPT to increase when compared to the sample outputs discussed by SCEO previously. Conversely,
3 The assumptions in HAPT are more sophisticated than this, accounting for changes over time and each jurisdiction’s
share of certain values. Replication of the numbers herein by using this simplified equation should not be considered
when evaluating this recommendation.
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jurisdictions with smaller housing share than population share can expect their HAPT output to decrease
over earlier results.
Comparing HAPT Results from Prior Versions and Now
As a handy comparison of how overall housing Table 2: Comparison of HAPT Total Housing by Jurisdiction
allocations would change when housing share
is input into HAPT rather than population Total New Units Change if
share, the table at right lists the total housing Using Using Using
allocation using both inputs. Also shown is Pop Housing Housing
whether the total housing units would increase Jurisdiction Share Share Share
or decrease for each jurisdiction when using Unincorporated Rural 3,534 6,195 Higher
housing share, as the tool intended. Unincorporated UGA 22,946 17,142 Lower
While housing share is the intended input for Airway Heights 5,007 3,955 Lower
HAPT, using housing share would increase the Cheney 2,535 2,076 Lower
housing allocation to the rural areas (outside Deer Park 1,023 1,083 Higher
the UGA). To a greater degree, the larger Fairfield 0 0 Higher
jurisdictions would also be subject to a larger Latah 0 0 Higher
allocation. Liberty Lake 6,601 5,180 Lower
Medical Lake 179 329 Higher
It’s important to note that while this represents Millwood 36 106 Higher
a large change for some jurisdictions, increased Rockford 53 68 Higher
allocations to those communities in the center Spangle 0 15 Higher
of the UGA (City of Spokane, Spokane Valley) is Spokane 17,550 22,359 Higher
consistent with the requirements of GMA, Spokane Valley 15,713 16,661 Higher
wherein growth should be concentrated in the Waverly 7 15 Higher
UGA and limited on the edges.
While the allocation for unincorporated rural areas would be more than 3/4 larger, that increase would
be spread throughout a very large area (all parts of the County outside the UGA), tempering the effects
of that growth somewhat. Furthermore, urban scale services to those additional homes would not be
required due to their location.
PTAC Recommendations: Housing Share and HAPT
Following multiple discussions on the differences between population share and housing share, PTAC
generally feels that housing share, created using the same assumptions already built into the HAPT, is the
most defensible and effective input for the HAPT. The following benefits of using housing share discussed
were as follows:
• The assumptions used to generate housing share from population share are identical to those in
the HAPT now.
• The HAPT model is sophisticated—an adjustment in one variable can have unintended
consequences.
• The data used to generate housing share have already been considered and adopted by the BOCC.
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Final Results
If the share of housing growth indicated in Table 1 in input into the HAPT, and the method previously
described as Method A Prime in the SCEO recommendation is utilized, then the final housing allocation
shown in the attached spreadsheet is provided.
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Appendix B:
Assembled Affordability by SubArea from
Public Market Data Sources
Appendix to Accommodating Affordable Housing in the City of Spokane, 2025
[Page 39]
Affordability Data by Subarea - Purchase Costs
Home Prices from fanniemae mortgage calculator
Mortgage Income
Source: Zillow SubareaMedian ValuePayment Required Bracket
Balboa-South Indian Trail $424,754 $3,635 $145,400 120+%AMI
Bemiss $280,200 $2,398$95,920 80-100%AMI
Browne's Addition $354,056 $3,031 $121,240 120+%AMI
Chief Garry Park $268,467 $2,298 $91,920 80-100%AMI
Cliff-Cannon $405,652 $3,473$138,920 120+%AMI
Comstock $448,209 $3,836 $153,440 120+%AMI
East Central $307,951 $2,636 $105,440 80-100%AMI
Emerson-Garfield $292,084 $2,500 $100,000 80-100%AMI
Five Mile-Prairie $565,299 $4,839 $193,560 120+%AMI
Hillyard $280,517 $2,401 $96,040 80-100%AMI
Latah Valley $566,119 $4,846$193,840 120+%AMI
Lincoln Heights $391,469 $3,351 $134,040 120+%AMI
Logan $303,672 $2,599 $103,960 80-100%AMI
Manito-Cannon Hill $535,315 $4,582 $183,280 120+%AMI
Minnehaha $314,370 $2,690$107,600 80-100%AMI
Moran Prairie $494,428 $4,232 $169,280 120+%AMI
Nevada-Lidgerwood $299,131 $2,560 $102,400 80-100%AMI
North Hill $310,829 $2,661$106,440 80-100%AMI
North Indian Trail $496,470 $4,249 $169,960 120+%AMI
Northwest $346,592 $2,966 $118,640 120+%AMI
Peaceful Valley $329,062 $2,817$112,680 120+%AMI
Riverside $400,099 $3,424 $136,960 120+%AMI
Rockwood $619,562 $5,303 $212,120 120+%AMI
Thorpe-Westwood $442,224 $3,785 $151,400 120+%AMI
West Central $299,526 $2,563 $102,520 80-100%AMI
West Hills $405,951 $3,475 $139,000 120+%AMI
Whitman $280,856 $2,404$96,160 80-100%AMI
Home Prices from fanniemae mortgage calculator
Mortgage Income
Source: Redfin SubareaMedian ValuePayment Required Bracket
Balboa-South Indian Trail $382,450 $3,274 $130,960 120+%AMI
Bemiss $295,750 $2,532 $101,280 80-100%AMI
Browne's Addition $310,000 $2,654 $106,160 80-100%AMI
Chief Garry Park $296,956 $2,542 $101,680 80-100%AMI
Cliff-Cannon $430,000 $3,681 $147,240 120+%AMI
Comstock $435,475 $3,728$149,120 120+%AMI
East Central $300,000 $2,568 $102,720 80-100%AMI
Emerson-Garfield $302,500 $2,589 $103,560 80-100%AMI
Five Mile-Prairie $565,530 $4,841 $193,640 120+%AMI
Grandview Thorpe $463,000 $3,962 $158,480 120+%AMI
Hillyard $285,000 $2,439 $97,560 80-100%AMI
Latah Valley $574,950 $4,921 $196,840 120+%AMI
Lincoln Heights $403,000 $3,449 $137,960 120+%AMI
Logan $318,000 $2,722 $108,880 120+%AMI
Manito-Cannon Hill $540,000 $4,622 $184,880 120+%AMI
Minnehaha $330,000 $2,825 $113,000 120+%AMI
Moran Prairie $634,656 $5,432 $217,280 120+%AMI
Nevada-Lidgerwood $302,000 $2,585 $103,400 80-100%AMI
North Hill $305,000 $2,611 $104,440 80-100%AMI
North Side $335,000 $2,868 $114,720 120+%AMI
Northwest Spokane $340,000 $2,910 $116,400 120+%AMI
Peaceful Valley $310,000 $2,654 $106,160 80-100%AMI
Riverside $460,000 $3,937 $157,480 120+%AMI
Rockwood $635,000 $5,435$217,400 120+%AMI
West Central $280,500 $2,400 $96,000 80-100%AMI
West Hills $415,000 $3,552 $142,080 120+%AMI
Whitman $291,000 $2,491 $99,640 80-100%AMI
NOTE: The subareas above do not necessarily correspond to Spokane Neighborhood Council boundaries.
[Page 40]
Affordability Data by Subarea - Rental Costs
Rental Costs
Average Rent Income
Source: RentCafe Subarea(May 2025)Required Bracket
Balboa - South Indian Trail $1,330 $53,200 0-80%AMI
Bemiss $1,442 $57,680 0-80%AMI
Browne's Addition $1,546 $61,840 0-80%AMI
Chief Garry Park $1,426 $57,040 0-80%AMI
Cliff - Cannon $1,441 $57,640 0-80%AMI
Comstock $1,373 $54,920 0-80%AMI
East Central Spokane $1,345 $53,800 0-80%AMI
Emerson - Garfield $1,521 $60,840 0-80%AMI
Five Mile Prairie $1,328 $53,120 0-80%AMI
Grandview - Thorpe $1,540 $61,600 0-80%AMI
Hillyard $1,366 $54,640 0-80%AMI
Latah Valley $1,467 $58,680 0-80%AMI
Lincoln Heights $1,149 $45,960 0-80%AMI
Logan $2,009 $80,360 80-120%AMI
Manito - Cannon Hill $1,139 $45,560 0-80%AMI
Minnehaha $1,366 $54,640 0-80%AMI
Moran Prairie $1,329 $53,160 0-80%AMI
Nevada - Lidgerwood $1,237 $49,480 0-80%AMI
North Hill $1,072 $42,880 0-80%AMI
North Indian Trail $1,759 $70,360 80-120%AMI
Northwest Spokane $1,382 $55,280 0-80%AMI
Peaceful Valley $1,546 $61,840 0-80%AMI
Riverside $1,466 $58,640 0-80%AMI
Rockwood $1,139 $45,560 0-80%AMI
Southgate $1,529 $61,160 0-80%AMI
West Central Spokane $1,546 $61,840 0-80%AMI
West Hills $1,425 $57,000 0-80%AMI
West Meadows $1,277 $51,080 0-80%AMI
Whitman $1,335 $53,400 0-80%AMI
Rental Costs
Average Rent Income
Source: Apartments.com Subarea (May 2025) Required Bracket
Bemiss $1,202 $48,080 0-80%AMI
Chief Garry Park $1,555 $62,200 0-80%AMI
City Center $1,460 $58,400 0-80%AMI
Cliff Cannon $1,359 $54,360 0-80%AMI
Comstock $1,330 $53,200 0-80%AMI
Dartford $1,394 $55,760 0-80%AMI
Downtown $1,410 $56,400 0-80%AMI
Emerson Garfield $1,374 $54,960 0-80%AMI
Lincoln Heights $1,127 $45,080 0-80%AMI
Logan $1,360 $54,400 0-80%AMI
Moran Prairie $1,380 $55,200 0-80%AMI
Nevada Lidgerwood $1,202 $48,080 0-80%AMI
North Spokane $1,311 $52,440 0-80%AMI
Palisades Park $1,282 $51,280 0-80%AMI
Rockwood $1,157 $46,280 0-80%AMI
South Spokane $1,265 $50,600 0-80%AMI
Town and Country $1,369 $54,760 0-80%AMI
U-District $1,659 $66,360 80-120%AMI
West Central $1,326 $53,040 0-80%AMI
West Spokane $1,274 $50,960 0-80%AMI
NOTE: The subareas above do not necessarily correspond to Spokane Neighborhood Council boundaries.
[Page 41]
City of Spokane
Department of Planning & Economic Development
808 W. Spokane Falls Blvd
Spokane, WA 99201
(509) 625-6500
compplan@spokanecity.org
Accommodating Affordable Housing Report
City of Spokane
PlanSpokane 2046
[Page 1]
Accommodating Affordable Housing
in the City of Spokane, Washington
a requirement of the Growth Management Act (RCW 36.70A.70)
June, 2025
[Page 2]
[Image-based page. View this page in the slide viewer.]
[Page 3]
Table of Contents
Executive Summary.............................................................................................................................i
I. Introduction.......................................................................................................................................1
II. Report Preparation...........................................................................................................................1
III. Defined Terms...................................................................................................................................2
IV. Housing Affordability Brackets........................................................................................................2
V. The Housing Allocation Planning Tool............................................................................................4
• A Note On Housing Versus Population Growth...........................................................5
• A Note On Housing Affordability Brackets and Grouping..........................................7
VI. Determining Affordability Bracket by Geographic Location.......................................................7
• Using Zoning to Inform Housing Affordability.............................................................7
• Sources for Housing Affordability for Rentals and Purchases..................................8
• Rent/Purchase Price by Affordability Bracket..............................................................9
• Determining Housing Tenure.......................................................................................14
VII. Unit Capacity by Affordability Bracket.........................................................................................14
• Special Cases in the Land Capacity Analysis..............................................................16
VIII. Housing Unit Development Since 20200.....................................................................................16
IX. RESULTS: Housing Unit Capacity by Affordability Bracket........................................................17
APPENDIX A: Housing Allocation Planning Tool Documentation......................................................A-1
APPENDIX B: Assembled Affordability by SubArea from Public Market Data Sources..................B-1
[Page 4]
Figures
Figure 1: Final Results—City of Spokane Housing Unit Capacity by Affordability..................................i
Figure 2: Income Brackets in Spokane County...........................................................................................3
Figure 3: Utility Allowances by Unit Type and Number of Bedrooms, Spokane County.....................4
Figure 4: Rent/Mortgage Payment Limits in Spokane County.................................................................4
Figure 5: Countywide Housing Growth Allocation–Cities Included.........................................................5
Figure 6: City of Spokane Housing Growth Allocation (2020 to 2046)....................................................5
Figure 7: City of Spokane New Housing Need by Household Income (2020 to 2046).........................6
Figure 8: Zoning Classified by Housing Type and Maximum Density.....................................................8
Figure 9: Process for Calculating Income from Median Home Price....................................................10
Figure 10: Rent Affordability by Approximate Location (Apartments.com)...........................................11
Figure 11: Rent Affordability by Approximate Location (Rentcafe.com)................................................11
Figure 12: Home Value Affordability by Approximate Location (Zillow.com)........................................12
Figure 13: Home Value Affordability by Approximate Location (Redfin.com).......................................12
Figure 14 Assumed Affordability by Location–Rentals and Purchases..................................................13
Figure 15 Percent of Rented Homes by Census Tract (All Housing Types)...........................................15
Figure 16 Percent of Owned Homes by Census Tract (All Housing Types)...........................................15
Figure 17 Example Affordability Calculation–LCA to Affordability Bracket...........................................16
Figure 18 Final Results–City of Spokane Housing Unit Capacity by Affordability.................................17
[Page 5]
Executive Summary To determine where in the City units might
The State of Washington has adopted new be affordable for these incomes, the analysis
legislation that requires communities like used publicly available commercial price data
Spokane to ensure they can accommodate from Zillow.com, Redfin.com, Rentcafe.com, and
needed housing in various affordability brackets Apartments.com. Tenure information from the
when updating their Comprehensive Plans. As American Communities Survey (ACS) was then
the City of Spokane is undertaking the next man- used to determine what proportion of units in a
dated Periodic Update to its Comprehensive given part of the city might be rented or owned.
Plan, the City must consider growth for the next By comparing the unit capacity in the LCA against
twenty years. Sufficient capacity must exist in the the affordability information from the web-
City to accommodate housing development in based sources and the tenure (rent vs. own) data
these brackets. from the ACS, the City has determined which
The City has analyzed its housing unit capac- units of capacity in the LCA are expected to fall
ity already as part of the adopted Land Capacity within one of the three affordability brackets.
Analysis (LCA) for the City of Spokane. This report By applying the analysis outlined in this re-
expands upon the findings of the LCA in order to port, the City determined that even though there
differentiate the available land capacity by currently exists sufficient land capacity for
affordability bracket. 33,000+ units, the City cannot likely accommo-
Affordability in Spokane is established by a date the needed units in the most affordable cat-
percentage of the Area Median Income (AMI), set egory, 0-80% AMI. The specific number of units in
by the U.S. Department of Housing and Urban each category the City can accommodate is
Development. Currently, the City of Spokane ex- shown in Figure 1 below.
hibits a median three-person family income of Per the Washington Department of Com-
$90,720 per year, through which the City can de- merce guidance on the subject, the City must
termine the various affordability brackets as fol- now contemplate certain amendments to devel-
lows: opment strategies, code requirements, and pol-
icy towards raising the number of 0-80%AMI
• 0-80% AMI = $0 and $72,600 units the City can accommodate in the next
• 80-120% AMI = $72,601 and $108,864 twenty years. What those amendments might be
will be a topic of the upcoming Environmental
• 120+% AMI = more than $108,864 Impact Statement and Comprehensive Plan Peri-
odic Update.
Figure 1: Final Results–City of Spokane Housing Unit Capacity by Affordability
0-80%AMI Units 80-120%AMI Units 120+%AMI Units
Need (Commerce HAPT, 2020-2046) 15,347 2,588 4,424
Units Completed (2020-2024) 1,328 507 978
Capacity for Additional Growth (2025-2046) 9,654 8,036 12,475
Comparison RESULT -4,365 5,955 9,029
Source: New Units Needed = Department of Commerce Housing Allocation Planning Tool (HAPT). Units Already Built: City of Spokane, Acella Data 2021 to 2024. Capacity for Additional
Growth = Land Capacity Analysis for the City of Spokane, 2025.
Notes: RESULTS row represents the following calculation: (Units Already Built + Remaining Capacity) - New Units Needed. A negative number denotes a lack of sufficient capacity in that
affordability bracket to accommodate the need identified by the State.
2025 Accommodating Affordable Housing Page i
[Page 6]
I. Introduction
In 2021 the Washington State Legislature passed new legislation seeking to
remedy the State’s ongoing housing crisis. Described as a bill “supporting emergency
shelters and housing through local planning and development regulations,” House Bill
1220 (HB1220) was passed on April 14, 2021. Among other changes, HB1220
expanded the requirement for Cities and Counties planning under the Growth
Management Act (GMA) to plan for and accommodate housing within their borders
when conducting major updates to their comprehensive plan.
Prior to HB1220, Cities and Counties were only required to quantify and
accommodate their total 20-year housing unit need. HB1220 expanded that
requirement, calling on jurisdictions to consider and plan for housing units broken
down by various affordability brackets, based on Area Median Income (AMI).
Accordingly, the Washington Department of Commerce (Commerce) provided the
Housing Allocation Planning Tool (HAPT) and various guidance documents to help
jurisdictions meet the new requirements.
The following analysis conforms largely to the guidance provided by Commerce,
primarily Commerce publications Establishing Housing Targets for your Community
(Book 1) and Guidance for Updating your Housing Element (Book 2). While HB1220
also included the requirement that the City consider racially disparate impacts and
displacement, those topics will be addressed in a separate study underway by the City
of Spokane and are not explored in detail here. Additionally, HB1220 requires that City
quantify their ability to accommodate emergency housing—a topic which will be
addressed in a separate report from this one.
II. Report Preparation
The following report was prepared by the Planning & Economic Development
department at the City of Spokane, utilizing the following staff:
Project Manager & Chief Analyst: Kevin Freibott, Senior Planner
Planning Director: Spencer Gardner, AICP
Deputy Planning Director: Tirrell Black, AICP
Economic Development: Amanda Beck, Planner II
This report is a follow-up to the City’s Land Capacity Analysis (LCA), adopted earlier
in 2025. Readers are referred to that document for greater detail as to the available
lands within the City and the development potential therein.
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III. Defined Terms
Prior to discussing the housing allocation and the City’s capacity to accommodate
those units, it’s important to understand several key terms used by Commerce, the
HAPT, and mentioned in GMA and HB1220. Those terms are as follows:
Area Median Income (AMI): The HAPT describes housing affordability by AMI,
specifically as a percentage of the Spokane County AMI. AMI is established by
the United States Department of Housing and Urban Development (HUD) and
is updated annually for the use of housing providers and local government.
HUD sets the AMI for the entire Spokane metropolitan area, not for cities
specifically. For financial year 2025, HUD states the AMI for the Spokane area
is $100,800. Commensurately, a household making $100,800 annually in
Spokane would be a 100%AMI household. Conversely, a household with an
annual income of $50,400 would be in the 50%AMI bracket.
Permanent Housing: Permanent housing units provide permanent
residence, whether or not those units are provided along with supporting
services. A housing unit can be any type of unit, be it a standalone house,
apartment, condo, middle housing, or some other type of housing. For the
purposes of this analysis, group housing is not considered as part of the
permanent housing number, commensurate with HB1220 requirements.
Permanently Supportive Housing (PSH): PSH units are subsidized housing
units with no limit on the length of stay, prioritizing housing for people who
require comprehensive support services to retain tenancy. Generally, PSH is
paired with on-site or off-site voluntary services designed to support a person
living with a complex and disabling behavioral health or physical health
condition who either was experiencing homelessness or was at imminent risk
of homelessness prior to moving into housing. Simplified, PSH provides both
housing and support to help prevent those in PSH from entering or returning
to homelessness. PSH is quantified in the HAPT by unit.
IV. Housing Affordability Brackets
The analysis required by HB1220 and GMA calls for the City to quantify and
account for new housing in several affordability ranges, or brackets, based on AMI.
The brackets are based on AMI, set by HUD, and represent a range of household
incomes in the extremely-low-, very-low-, low-, and moderate-income ranges. Also
included are higher incomes greater than the AMI, such as 120% AMI, but legislation
has fewer requirements for planning for these housing types.
By calculating income as a percentage of AMI, the range of household incomes in
each bracket can be determined. This is complicated somewhat by the fact that AMI
changes by household size, rising as the number of people in the household rises.
While most agencies and jurisdictions rely on the 4-person number, Commerce allows
for jurisdictions to make adjustments according to local average household size.
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[Page 8]
The following table (Figure 2) provides the current AMI brackets, based on the
region’s median family income of $100,800. The table includes both the 3-person
income limits and the 4-person income limits. While 4-person family limits are most
often cited when discussing AMI, the current average household size in the City of
Spokane is closer to 3-persons1. Per Commerce Guidance, when this is true the
jurisdiction can consider home affordability by using the 3-person limit instead2.
Accordingly, the analysis in this report will do so.
Figure 2: Income Brackets in Spokane County (2025)
3-Person Family 4-Person Family
Affordability Bracket %AMI Income Range (Annual) Income Range (Annual)
Extremely Low Income 0-30% AMI $0 - $27,250 $0 - $30,240
Very Low-Income 30-50% AMI $27,251 - $45,400 $30,241 - $50,400
Low Income 50-80% AMI $45,401 - $72,600 $50,401 - $80,640
Moderate Income 80-100% AMI $72,601 - $90,720 $80,641 - $100,800
High Income 100-120% AMI $90,721 - $108,864 $100,801 - $120,960
Highest Income 120% + AMI $108,865 and up $120,961 and up
Source: 2025 Income Limits Documentation System, United State Housing and Urban Development Department (HUD). Retrieved online at www.huduser.gov.
Notes: Calculations of income range, maximum annual housing cost, and maximum monthly housing cost made by City staff from HUD income limits.
The Commerce guidance directs Jurisdictions towards assuming that a household
should expect 30 percent of its income to go towards housing costs. Incidentally, this
is the threshold for “cost burdened” households used by the State and most local
jurisdictions. Those households that pay more than 30 percent of their monthly
income towards housing costs are considered “cost burdened.”
In order to analyze the relationship between rents in the City of Spokane and the
income brackets offered by AMI, first the appropriate maximum monthly housing cost
for each bracket must be calculated. Converting annual income to determine what
comprises 30 percent of the monthly income requires a simple calculation:
Maximum Monthly Housing Cost = Annual Income / 12 * 0.30
However, an additional calculation must be made because housing cost, when
considered by Commerce and the state, includes monthly utility costs in addition to
rent or mortgage payments. The amount to subtract from housing cost for utilities is
informed on a county by county basis by local housing authorities. In the case of
Spokane County, the Spokane Housing Authority publishes worksheets for the
allowances for certain household utilities. Spokane Housing Authority’s most current
utility allowances are provided by housing type and the utilities involved (e.g. whether
they be gas or electric, forced air or furnace). By using the most common utility types
in Spokane, the following utility allowances can be assumed (see Figure 3).
Accordingly, the amounts in Figure 3 should be incorporated into the maximum
monthly housing cost calculation by subtracting them from the total. For the purposes
1 2.35 according to the US Census American Communities Survey, 2023 5-year Average.
2 See p. 35 of Guidance for Updating Your Housing Element by the Department of Commerce, August,
2023.
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Figure 3: Utility Allowances by Unit Type and Number of Bedrooms, Spokane County
Unit Type 0 Bedroom 1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom 5 Bedroom
High-Rise/Apartment $206 $213 $227 $243 $259 $282
Middle Housing & Low Rise $216 $224 $243 $263 $282 $300
Single-Unit, Duplex, Mobile Home $232 $244 $263 $283 $304 $323
AVERAGE VALUE $218 $227 $244 $263 $282 $302
Source: Spokane Housing Authority, February 2025.
Notes: Assumes electric heating, electric cooking, and electric water heating, indicated by the source as the most common condition. The average value is a calculated value of the average of
the values in the three unit types. It is not provided by Spokane Housing Authority.
of this analysis, and consistent with the overall assumption of 3 persons per unit, this
analysis will apply 2 bedroom average value of $244. This results in the following
calculation for maximum monthly rent or mortgage payment:
Maximum Monthly Housing Cost = Annual Income / 12 * 0.30 - $244
By applying this formula, the maximum monthly housing cost for each
affordability bracket result can be determined, as shown in Figure 4 below. Note that
the analysis in this report will utilize the three-person household data as discussed
previously.
Figure 4: Rent/Mortgage Payment Limits in Spokane County
Persons Per Household
AMI Bracket One Two Three Four Five Six
30% AMI $312 $378 $437 $559 $678 $797
50% AMI $665 $782 $891 $1,016 $1,098 $1,181
80% AMI $1,195 $1,387 $1,571 $1,772 $1,916 $2,058
100% AMI $1,546 $1,789 $2,024 $2,276 $2,459 $2,642
120% AMI $2,192 $2,477 $2,780 $3,003 $3,226 $3,448
Source: Calculated values based on method in text.
Notes: Assumes 30 percent of monthly income calculated from annual Area Median Income, minus utility allowances.
V. The Housing Allocation Planning Tool (HAPT)
Commerce has provided a complex set of tools for Counties and Jurisdictions to
utilize when determining their housing unit growth allocation through the planning
horizon. This tool, known as HAPT, provides the countywide housing allocation based
on the planning horizon and the County’s overall population growth, as well as
individualized jurisdiction housing growth based upon the share of the County’s
growth each jurisdiction expected to accommodate.
In the case of the Spokane County numbers, the County has adopted the middle
housing forecast from OFM. This forecast is the most statistically supported option
and provides for growth of 100,065 persons in the County by 2046. By using the
regionally adopted projections, the entire county’s allocation is provided (see Figure 5
below).
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Figure 5: Countywide Housing Growth Allocation–Cities Included
Permanent Housing Needs by Income Level in Housing Units (as % of Area Median Income)
TOTAL 0-30%AMI
Non-PSH PSH 30-50%AMI 50-80%AMI 80-100%AMI 100-120%AMI >120%AMI
Current Estimated Housing 221,840 6,613 937 34,798 91,803 32,035 20,981 34,673
New Housing by 2046 297,024 26,518 6,651 48,418 100,647 36,807 24,918 53,065
Additional Units Needed 75,184 19,905 5,714 13,620 8,844 7,772 3,937 18,392
Source: Spokane County HAPT, January 2025.
Notes: AMI = Area Median Income, as set by the United State Housing and Urban Development Department (HUD). Current AMI is for FY2025.
Once countywide need is determined, HAPT divides up countywide growth by a
number of possible methods. Spokane County and the Cities within it have chosen to use
“Method C” in HAPT, as it provides for both a statistical division of the overall growth
shown in Figure 5, but also accounts for housing need outside cities but within the Urban
Growth Area (UGA). See Appendix A for more information on this method.
HAPT requires that Counties apportion housing need among the Cities as a
percentage of regional housing growth each jurisdiction expects to accommodate.
Ultimately, the region agreed on a method to convert projected population share into
housing share, which was then input into HAPT (see Appendix A). Regarding the City of
Spokane, while the city is expected to experience 23.34% of population growth, the City’s
housing need represents 29.74% of the countywide housing growth. This is
commensurate with recent development in Spokane that has exceeded 1,300 units
annually since the recovery from COVID. By inputting 29.74 percent of countywide
housing growth for the city into HAPT, the tool provides the following housing need in the
city shown in Figure 6 below.
Figure 6: City of Spokane Housing Growth Allocation (2020 to 2046)
Permanent Housing Needs by Income Level (as % of Area Median Income)
TOTAL 0-30%AMI
Non-PSH PSH 30-50%AMI 50-80%AMI 80-100%AMI 100-120%AMI >120%AMI
Estimated Current Housing 99,938 3,534 937 19,479 47,090 11,873 7,118 9,907
Additional Units Needed 22,359 6,452 1,851 4,413 2,631 1,418 1,170 4,424
Source: Spokane County HAPT, January 2025.
Notes: AMI = Area Median Income, as set by the United State Housing and Urban Development Department (HUD). Current AMI is for FY2025.
As shown above, the City is expected to require 22,359 additional permanent housing
units between 2020 and 2046. While those units are spread among all the affordability
brackets, that spread is not equal bracket to bracket. Figure 7 on the following page
provides a graphical depiction of that need by bracket.
A Note On Housing Units Versus Population Growth
The city is expected to grow by 23,357 people between 2020 and 20463. Compared to
a housing need of 22,359 homes (Figure 6) the two projections would seem incongruous,
3 Land Capacity Analysis for the City of Spokane, 2025.
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Figure 7: City of Spokane New Housing Need by Household Income (2020-2046)
Source: Spokane County HAPT, January 2025.
Notes: Income limits provided by United State Housing and Urban Development Department, FY2025 Income Limits Documentation System, retrieved online at
www.huduser.gov.
as if the HAPT was assuming that most new residents will live alone in their home. This is
not the case, however, as HAPT provides for more than the housing units needed to
accommodate new population growth.
Per the Commerce guidance on the HAPT, the allocation accounts for three areas of
housing need, as follows:
• New Growth. The housing units to accommodate new population growth in the
city between 2020 and 2046. The proportion of new housing in the HAPT
corresponding to this need is approximately 60 percent of the total.
• Underproduction. In its study of housing needs and production in Washington,
Commerce identified that, overall, the state had under-produced housing by a
significant degree. This was largely due to COVID and other economic factors
outside the control of Cities and Counties, but the need is there regardless. To
remedy this situation, 30 percent of the HAPT housing allocation is included to
address issues with overpriced housing and historic underproduction. As a result,
approximately 30 percent of the HAPT allocation addresses the housing needs of
people who are already residing in Spokane.
• Homelessness. A small percentage of the overall HAPT allocation, approximately
10 percent, is intended to address the need of those experiencing homelessness
or in danger of imminent homelessness. As with underproduction, much of this
need is for people already in Spokane, not new growth.
While the City of Spokane has been allocated 22,359 units between 2020 and 2046,
only about 13,415 of those units are to accommodate new residents. Regardless, HB1220
states that the City must have enough capacity to accommodate the entire allocation, thus
this analysis in this report concerns the full number of units allocated (see Figure 6).
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A Note on Housing Affordability Brackets and Grouping
While HAPT provides for housing need in seven brackets (see Figure 6), difficulties
arise in providing such a high level of differentiation in housing data. It is near impossible
to divide housing costs into so many brackets due to the limited number of zoning types
and the high number of variables involved. As such, most jurisdictions have decided to
group the affordability brackets into the following three groups:
• 0-80% AMI – The highest need bracket, requiring the most program/funding
support.
• 80%-120% AMI - The middle bracket, where some support is necessary, but some
market-rate development may occur as well. Some organizations label this group
as “workforce housing.”
• 120%+AMI – The highest cost group, often called “market rate” housing.
Commerce’s guidance assumes little to no support for these householders.
Not only are jurisdictions using these three groupings, but the example tables and
calculations in Commerce’s own guidance group affordability thus. Accordingly, the City of
Spokane analysis will use the same groups.
VI. Determining Affordability Bracket by Geographic Location
As demonstrated above, the HAPT indicates the City must accommodate 22,359
additional housing units between 2020 and 2046. To determine what capacity exists in the
city to accommodate those units, Commerce provides specific guidelines in their
“Guidance for Updating Your Housing Element,” published August 2023. This guidance
directs jurisdictions to consider their zoning and which housing types might be assumed
in those zones. Additionally, the guidance from Commerce directs jurisdictions to use
multiple data sources to determine what affordability can be expected from various
housing types. The following analysis conforms substantially to the Commerce guidance.
Using Zoning to Inform Housing Affordability
The Commerce guidance indicates that jurisdictions should compare the housing
types allowed in individual zones to inform what level of affordability might be expected
in given areas. To this end, the City analyzed all zones in which housing is allowed and
compared the housing types and densities assumed for each, as shown in Figure 8 on the
following page.
The City of Spokane is somewhat unusual, in that the municipal code allows for the
development of residential uses in all zones except industrial zones. Additionally, most
housing types (single-unit and middle housing) are allowed everywhere. Save for the lower
density residential zones (RA, R1, and R2), multi-unit housing is allowed in every zone. This
makes it difficult to impossible to differentiate housing development in the city only by
considering zoning.
Page 7 of 20 2025 Accommodating Affordable Housing
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Figure 8: Zoning Classified by Housing Type and Maximum Density
Zone Housing Types Allowed Maximum Density Assumed Density Density Group
Allowed
RA Single-Unit and Middle Housing 10 (approximate)
R1 10 (approximate) 5-9 du/ac Residential Low
R2 Middle Housing 20 (approximate)
RMF Middle Housing & Multi-Unit 30 (approximate) 29 du/ac Residential High
RHD No Limit
NR
CB
GC 30.2 du/ac in 33%
O Middle Housing & Multi-Unit No Limit of the Area Non-Residential
OR
CC#
CA1
DTC
DTG Middle Housing & Multi-Unit No Limit 44.4 du/ac in 33% Downtown
DTU of the area
DTS
Source: Spokane Municipal Code, SMC Title 17; Shaping Spokane, the Spokane Comprehensive Plan (Chapter 3); Land Capacity Analysis for the City of Spokane
(2025).
Notes: Maximum density is approximate in residential zones due to the fact that lots under 2 acres are not restricted by density–rather the SMC uses height and
setbacks to control for density in these zones. Assumed Density and Density Group conform to the City’s Land Capacity Analysis, adopted March 10, 2025, via
resolution RES 2025-0015.
Further complicating matters, the City does not have sufficient data to correlate
housing type with housing affordability as suggested by the Department of Commerce.
This is not a failure by the City, rather the requirement to track such data did not exist
historically, so these values weren’t collected. To remedy this, the Commerce guidance
provides for the option for Cities to augment and adjust affordability assumptions using
publicly available market data.4
Sources for Housing Affordability for Rentals and Purchases
Cities, Spokane included, often do not track the affordability of a given housing unit
when permitting its construction. Accordingly, the City has limited internal sources that
might indicate at what level of affordability housing development is occurring. As a result,
the City must look outside it’s own data for this information.
Per the suggestion in the Commerce guidance, the City has utilized data from multiple
sources to determine housing affordability by type, including the following:
• Home Value (purchases) by neighborhood provided by Zillow.com. Zillow
provides a combination of self-reported and industry information on home
purchases, assembling that data into ‘neighborhoods’ that generally conform to
certain parts of the city.
4 See p. 32 of Guidance for Updating Your Housing Element by the Department of Commerce, August,
2023.
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[Page 14]
• Home Value (purchases) by neighborhood provided by Redfin.com. Redfin is
similar to Zillow, but follows a more industry-based approach for home value,
lessening the impact of individual self-reported home values skewing the results.
As with Zillow, Redfin data can be divided up roughly by neighborhood.
• Median Rents by neighborhood provided by Apartments.com. Like with Zillow
but in this case concerning rentals, Apartments.com is somewhat weighted by
self-reporting while also accounting for historic data related to past listings that
may not currently be open for rent.
• Median rents by neighborhood provided by Rentcafe.com. Similar to Redfin,
RentCafe’s data is backed up by industry information in addition to current active
listings. RentCafe also directly contacts management companies and real estate
professionals to augment their data with additional confirmation.
Rent/Purchase Price by Affordability Bracket
Before a comparison can be made between median house price and monthly housing
costs, the home price must be converted to an assumed mortgage payment. Following the
Commerce guidance, the City utilized the Fannie Mae mortgage calculator to determine
what the approximate monthly mortgage payment might be for home purchases in the
City. The Fannie Mae mortgage calculator5 requires the user to input various assumed
factors that affect the payment amount. The factors used for this analysis were the most
common factors reported by Realtor.com for home purchases in Spokane County,
namely:
• 5 percent down payment;
• 30-year fixed rate loan; and
• 6.8% interest.
Plugging those factors into the Fannie Mae mortgage calculator returned a monthly
payment for each neighborhood’s median home price. That monthly value was then
converted into the annual income necessary to maintain such a payment amount. For this,
the Commerce assumption that 30 percent of annual income as the maximum that should
go to home payments/rents was assumed. The calculation shown in Figure 9 on the
following page provided the income required for a given median home price.
The same base calculation was used to determine the income required for rentals,
using the median rents provided by Apartments.com or RentCafe. Since those sources
provide rents in a monthly form to begin with, the first step (using a mortgage calculator)
was not necessary. Income required for a given median rent was calculated by dividing by
0.3 and multiplying by 12 only.
5 https://yourhome.fanniemae.com/calculators-tools/mortgage-calculator
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Figure 9: Process for Calculating Income from Median Home Price
Source: City of Spokane, based on WA Department of Commerce, “Guidance for Updating your Housing Element” (August 2023).
Notes: Fannie Mae mortgage calculator assumed a 5 percent down payment, 30-year fixed rate mortgage, and 6.8% interest, as averages provided by Realtor.com
for Spokane County.
Utilizing the calculations above, an affordability bracket can be assumed for each part
of the City for both median home price (purchases) and median rent (rentals). As an
example calculation for rental units, the following sample calculation utilizes the RentCafe
reported average rent for the Cliff-Cannon neighborhood:
1. Average Rent = $1,521
2. Assuming 30% of Income for Rent (Rent / 0.3) = $5,070
3. Multiplied by 12 to convert from monthly to annual: $60,840
Because $60,840 falls within the 0-80%AMI bracket (see Figure 2), we can assume that
rental units in the Cliff-Cannon neighborhood generally fall within that bracket. By using
this same calculation for both sources of rental data (Apartments.com and RentCafe) the
affordability bracket for each area in the city can be determined, as shown in Figure 10
and Figure 11 on following pages.
As an example calculation for units for purchase, the following sample uses the Zillow.
com reported median home value in the Northwest Neighborhood:
1. Median Home Value = $346,592
2. Mortgage Payment (Fannie Mae) = $2,966
3. Assuming 30% of Income for Mortgage (Payment / 0.3) = $9,887 a month
4. Multiplied by 12 to convert from monthly to annual = $118,640
Because $118,640 falls within the 120+%AMI bracket (Figure 2), we can assume that
homes for purchase in the Northwest Neighborhood generally fall within that bracket. By
using this method for both sources for sales data (Zillow and Redfin) the affordability
bracket for each area can be determined, as shown in Figure 12 and Figure 13.
Summary tables showing the calculations above for all four sources and all areas of
the city are included at the end of this report. See Appendix B for more details.
2025 Accommodating Affordable Housing Page 10 of 20
[Page 16]
Figure 10: Rent Affordability by Approximate Location (Apartments.com)
Source: Apartments.com, data
from May 2025.
Notes: Areas used by the source do not
necessarily match neighborhood
boundaries, as shown. The source had no
data for blank areas.
Figure 11: Rent Affordability by Approximate Location (Rentcafe.com)
Source: Rentcafe.com, data
from May 2025.
Notes: Areas used by the source do not
necessarily match neighborhood
boundaries, as shown. The blank area
contains zero housing units, thus it is not
shown here.
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Figure 12: Home Value Affordability by Approximate Location (Zillow.com)
Source: Zillow.com, data from
May 2025.
Notes: The source had no data
for blank areas. Areas used by
the source do not necessarily
match neighborhood
boundaries, as shown.
Figure 13: Home Value Affordability by Approximate Location (Redfin.com)
Source: Redfin.com, data from
May 2025.
Notes: The source had no data
for blank areas. Areas used by
the source do not necessarily
match neighborhood
boundaries, as shown.
2025 Accommodating Affordable Housing Page 12 of 20
[Page 18]
By comparing and combining the four maps above, general affordability assumptions
can be made for both rental and purchase homes by location in the City, as shown in
Figure 14. These assumptions were used by this analysis to assign assumed affordability
to either rental units or homes for purchase in each part of the City.
Figure 14: Assumed Affordability by Location–Rentals and Purchases
Source: City of Spokane, Synthesized from multiple sources.
As shown above, rented units in the City generally fall within the 0-80%AMI bracket,
though two smaller areas tend to be more expensive, falling within the 80-120%AMI
bracket. The picture for housing units for purchase is more complex, with a somewhat
even split between areas exhibiting 80-120%AMI units and areas in the 120+%AMI
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bracket. By determining affordability by geography in this way, the analysis can be more
nuanced as to the expected affordability of new units in the City over the next twenty
years. Many jurisdictions can consider their affordability for the entire City, but the great
size of Spokane (nearly 70 square miles) points to the need for a more refines analysis
than simply one value for the entire city. The approach outlined above grants that higher
level of detail.
Determining Housing Tenure
Now that the areas of the City in which certain affordability brackets can be assumed
has been established, the only remaining step is to determine which new units might be
for rent and which might be for purchase. Of note, it is inaccurate to assume that all
detached homes are for purchase, as the rental house market in Spokane is rather robust.
To determine the split of rented and purchase units expected in the city, this analysis
utilized data from the American Communities Survey (ACS) 5-year average reports from
2023. ACS provides sample-based data to fill in between the decennial censuses, providing
a relatively reliable data source for tenure (owned versus rented).
By polling ACS data, the City determined the mix of owned and rented homes in each
Census Tract, resulting in the maps on the following pages (Figure 15 and Figure 16). By
utilizing the ratio of rented to owned homes in each tract, any capacity for new housing
development in those tracts can be split accordingly into assumed rental units and units
for purchase. For instance, assume a given Census Tract exhibits 60% owned and 40%
rented units. That same Tract, say, shows an expected affordability of 80-120%AMI for
rental units and 120%+AMI for purchased units (per Figure 14). If that tract has capacity
for 100 units, 40 of those units could be assumed to be rented in the 80-120%AMI bracket
and 60 units could be assumed to be sold in the 120+%AMI bracket. This is precisely the
calculation used to determine final capacity in this report.
V. Unit Capacity by Affordability Bracket
The Commerce guidance states that once a jurisdiction has determined the
affordability of various housing types, zones, and locations, then the unit capacity in those
areas should be incorporated into the analysis. As the City has completed its LCA6, that
analysis provides a theoretical unit capacity in various locations throughout the city. Per
Commerce’s guidance, the unit capacity from the LCA was used in this analysis.
Because the LCA provides for potential units of capacity by geographic location within
the city, each unit of capacity in the LCA can be compared to the tenure assumptions
shown in Figures 15 and 16, producing an assumed number of rented units and owned
units of capacity in each Census tract. For example, if the LCA found that 100 units of
capacity exist in a tract of 60 percent owned and 40 percent rented homes, this analysis
assumes that 60 units of capacity would be owned and 40 units of capacity would be
rented.
6 Land Capacity Analysis for the City of Spokane, adopted March 10, 2025, via resolution RES 2025-0015.
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Figure 15: Percent of Rented Homes by Census Tract (All Housing Types)
Figure 16: Percent of Owned Homes by Census Tract (All Housing Types)
Source (Both): US Census Bureau, American Communities Survey, 2023 5-Year Average
Note (Both): Areas around the Spokane International Airport are blank due to a lack of any housing in this area.
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Once the assumptions for tenure (owned versus rented) are applied to units of
capacity in the LCA, the affordability of those units can be inferred by comparing the
location to the affordability in Figure 14. A schematic example of this calculation is shown
below (Figure 17).
Figure 17: Example Affordability Calculation–LCA to Affordability Bracket
Special Cases in the Land Capacity Analysis
The LCA considers two special areas in its analysis, those of adopted Planned Unit
Developments (PUDs) that have not yet completed platting all lots, and the South Logan
Transit Oriented Development (South Logan TOD) subarea analysis. Readers are referred
to the LCA itself for details on how these areas were handled in the LCA.
Following the process in the LCA, the analysis of affordability herein considers the
PUDs and South Logan TOD area separately as well. This is for the same reason—a greater
level of specificity is known about the development potential in these areas. Regarding the
PUDs, these typically involve either single-unit homes or multi-unit buildings as part of a
larger planned development with (generally) higher costs for residents, both rented or
purchased. Accordingly, for any units of capacity within PUDs the analysis in this report
assumes those units to occur at the more costly affordability bracket—namely 80-120%
AMI for rental units and 120+% AMI for purchased homes. Additionally, most PUDs include
covenants that restrict the renting of homes within PUDs. As a result, this analysis
assumes that 100 percent of single unit homes in PUDs will be for purchase. Likewise, all
multi-unit potential in PUDs is assumed to be for rent.
When considering the South Logan TOD area, the project area located in a part of the
City with the least affordable brackets in both rentals and purchase homes. Accordingly,
all units in the South Logan TOD area are assumed by this analysis to be in the 120+% AMI
bracket for purchase and the 80-120%AMI bracket for rentals.
VI. Housing Unit Development Since 2020
The housing allocation provided by Commerce via the HAPT establishes need between
the years 2020 and 2046. Because development has continued since 2020 and the unity
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[Page 22]
capacity presented by the LCA is for 2025, housing units built between 2020 and 2025
should be accounted for. In essence, any unit constructed between 2021 and now would
reduce the overall need identified by the HAPT.
To do this, all residential permits issued between January 1, 2021 and December 31,
2024 were pulled from the City’s permit database. All completed units–-those issued a
Certificate of Occupancy or indicating a successful final inspection–were geo-located and
compared to the affordability assumptions in Figure 14, resulting in a tabulated number
of completed units in each of the affordability brackets. These units were then subtracted
from the “new” units called for in HAPT. This number of completed units is included in the
final table of this report (see below).
VII. RESULTS: Housing Unit Capacity by Affordability Bracket
Overall, the LCA found that the City has sufficient theoretical capacity to
accommodate slightly more than 30,000 dwelling units. By applying those units of capacity
to the assumptions and calculations described in the sections above, those units are
divided among the three affordability brackets as follows (see Figure 18):
According to this analysis, informed by and in compliance with the guidance of the
Figure 18: Final Results–City of Spokane Housing Unit Capacity by Affordability
0-80%AMI Units 80-120%AMI Units 120+%AMI Units
Need (Commerce HAPT, 2020-2046) 15,347 2,588 4,424
Units Completed (2020-2024) 1,328 507 978
Capacity for Additional Growth (2025-2046) 9,654 8,036 12,475
Comparison RESULT -4,365 5,955 9,029
Source: Need = Department of Commerce Housing Allocation Planning Tool (HAPT). Completed Units: City of Spokane,
Acella Data 2021 to 2024. Capacity for Additional Growth = Land Capacity Analysis for the City of Spokane, 2025,
classified per the analysis outlined in this report.
Notes: Completed units represent those building permits issued by the City between January 1, 2021 and December 31,
2024, showing that either a certificate of occupancy was issued or a final inspection has been completed.
Resulting unit capacity represents the result of the analysis and calculations described in this report.
Comparison represents the following calculation: (Completed Units + Unit Capacity) - Need = Comparison RESULT. A
negative number denotes a lack of sufficient capacity in that affordability bracket to accommodate the need identified
by HAPT.
Department of Commerce, the City of Spokane does not currently contain sufficient
capacity to accommodate needed growth in the 0-80%AMI bracket. Concurrently, the
City has excess capacity in both the 80-120% AMI bracket and the 120+% AMI bracket.
To comply with the requirements of House Bill 1220, the City must consider, as part of the
overall Comprehensive Plan Periodic Update, actions sufficient to raise the capacity in the
0-80%AMI bracket by nearly 4,400 units. Those changes will likely be identified during the
preparation of the Environmental Impact Statement for the Comprehensive Plan Update,
as well as during preparation of the Update itself. For more information on these changes
as they are developed, readers are encouraged to visit www.planspokane.org.
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Appendix A:
Housing Allocation Planning Tool
Documentation
Appendix to Accommodating Affordable Housing in the City of Spokane, 2025
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Recommendation for HAPT: Housing Share
PLANNING TECHNICAL ADVISORY COMMITTEE
Report and Recommendation to the Steering Committee of Elected Officials
Periodic Update under the Growth Management Act, 2026 to 2046
Written and Recommended by PTAC, January 2025
[Page 32]
Executive Summary
The Planning Technical Advisory Committee (PTAC) has identified a possible issue with previous runs of
the Housing for All Planning Tool (HAPT), which all communities planning under the Growth Management
Act have been advised to use when allocating housing by affordability for the region. The intended input
for the tool—the data that is provided to the tool and then used to calculate each jurisdictions’ housing
allocation—is the share of housing growth each jurisdiction is expected to accommodate. Unfortunately,
due to unclear instructions, the previous HAPT outputs shared with the Steering Committee of Elected
Officials (SCEO) used the share of population growth instead.
Following a review of the data and the HAPT itself, the PTAC recommends that the region use housing
growth share as the input for the HAPT, specifically a housing growth share created by applying the same
assumptions built into the HAPT tool itself to convert the adopted population share to housing share.
Of note, this recommendation does not affect which method within HAPT is utilized. The existing SCEO
recommendation for the method known as “A Prime” is not affected by PTACs recommendation in this
memo.
The full output of the HAPT, assuming that housing share generated in the way recommended by PTAC is
used, is attached to the end of this memo.
Introduction
Following the SCEO vote to recommend Method “A Prime” when using the HAPT, the members of PTAC
identified that there had been some confusion as to which inputs should be provided to the HAPT when
calculating housing share. As a result, PTAC’s Housing Subcommittee met several times in the third and
fourth quarters of 2024 to consider how this might affect the housing allocation output from HAPT. In
essence, it appears to PTAC that the HAPT was intended to be provided with the share of housing growth
each jurisdiction is expected to accommodate, while previous use of the HAPT utilized the share of
population growth instead.
After discussing this at length, PTAC has developed a method for converting the currently adopted
Population Share 1 to housing growth share, which can then be input into HAPT. This memo outlines the
recommendation by PTAC for doing this, and provides the summary growth numbers for each jurisdiction
that results.
HAPT Method A Prime
At their meeting on September 25, 2024, the SCEO voted to recommend the use of the “A Prime” method
in the HAPT. Throughout this discussion and recommendation by PTAC, no change to this method is
anticipated or recommended. PTAC feels that SCEO’s original recommendation, adopted on September
24, 2024, does not require revision to accommodate PTAC’s recommendations herein.
1 Adopted by BOCC Resolution 24 -0348 on June 18, 2024.
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Housing Share versus Population Share
When PTAC and SCEO previously saw the “A Prime” results, it was always using the share of population
growth assigned to each jurisdiction per the adopted allocation 2. However, after multiple conversations
within PTAC and with Commerce staff, it was apparent that the instructions in HAPT were unclear and
that the tool was instead asking for the share of housing growth.
The share of population growth and the share of housing growth are directly related to each other, but
due to certain factors they are rarely the same number for a given jurisdiction. For instance, household
size (people per household) in each jurisdiction is not the same nor does it stay static over time.
Household size is continually changing from year to year. Furthermore, some jurisdictions contain a larger
amount of group quarters housing (i.e. college dorms, prisons, treatment centers) and that rate changes
over time. Those living in group quarters do not require additional housing units, thus they must be
subtracted from the overall population growth share for each jurisdiction.
Because of these factors, it is important to develop a share of housing each jurisdiction for the entirety of
the planning horizon (through 2046), not just today. Jurisdictions differ from each other and some
attempt to differentiate their allocations accordingly should be made as well.
A Note on the Underproduction of Housing
An additional factor has been raised by public commenters and PTAC members that is worth discussing
here. That factor is the known historic un derproduction of housing statewide. Commerce’s research has
made it clear that development in jurisdictions across the state have been lower than what is required to
house existing populations. As a result, many jurisdictions’ current housing stock is already too small to
accommodate the need of the existing population, not to mention the growth that is coming.
It is important to note that HAPT factors this underproduction into its results. Accordingly, the number
of housing units a jurisdiction may be allocated when using HAPT will appear high when compared to
population growth. This is specifically because HAPT attempts to also allocate sufficient housing to
accommodate the recent underproduction of housing as well as future growth. This condition is true
regardless of which input is used for HAPT.
Determining Housing Share
The Department of Commerce has not provided jurisdictions with a method for calculating housing
growth share. Likewise, GMA does not mandate that Cities and Counties use a particular method to
develop housing share. However, the PTAC subcommittee found that the HAPT itself provides one
possible method.
While PTAC spent considerable time exploring other ways to convert population growth to housing
growth, ultimately PTAC felt that because the resulting housing share would be input into HAPT, it was
most defensible to use the assumptions already built into HAPT to calculate housing share. That way, the
same set of assumptions would be applied to all parts of the tool and any unintentional bias or
modification of results would be minimized.
2 Adopted by BOCC Resolution 24 -0348 on June 18, 2024.
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Essentially, the housing share for each jurisdiction would be calculated directly from the population share
already adopted by the BOCC. While it is more sophisticated than can be expressed simply here, the
method for calculating housing share from population share is generally3 as follows:
[(Population Share – Group Quarters Population) / Household Size] + 6% to Account for Vacant Homes
For the purposes of the HAPT, the tool assumes that household size is shrinking over time and that each
jurisdiction will see the same share of group housing in the County as they are in 2020. The resulting
housing share for each jurisdiction and area is as shown in the following table. Again, when considering
the resulting housing share, the following should be kept in mind:
• Population share and housing share are not the same thing, though they are related to one
another.
• Housing share in the tool is somewhat elevated to account for historic underproduction of
housing.
Table 1: Population and Housing Share Compared
Share: Share: Share: Share:
Population Housing Population Housing
Jurisdiction Growth Growth Jurisdiction Growth Growth
Spokane County (Whole) 100.00% 100.00% Airway Heights 6.66% 5.26%
All Unincorporated Areas 35.21% 31.14% Cheney 3.37% 2.76%
Unincorporated Rural 4.70% 8.24% Deer Park 1.36% 1.44%
Unincorporated UGA 30.51% 22.81% Fairfield 0.00% 0.00%
Incorporated County 64.79% 68.95% Latah 0.00% 0.00%
Liberty Lake 8.78% 6.89%
Medical Lake 0.24% 0.44%
Millwood 0.05% 0.14%
Rockford 0.07% 0.09%
Spangle 0.00% 0.02%
Spokane 23.34% 29.74%
Spokane Valley 20.90% 22.16%
Waverly 0.01% 0.02%
As shown in the table, when comparing population share to housing share, some jurisdictions are
expected to accommodate a lower share of housing growth than population growth (e.g. Liberty Lake)
while others are shown to expect a higher share of housing than population (e.g. the City of Spokane).
Why this happens is complex and due to the fact that HAPT uses multiple factors from multiple sources
to determine these amounts.
Because the HAPT only has one input for each jurisdiction—share of housing growth—those jurisdictions
where the housing share is larger than population share can expect their housing number output from
HAPT to increase when compared to the sample outputs discussed by SCEO previously. Conversely,
3 The assumptions in HAPT are more sophisticated than this, accounting for changes over time and each jurisdiction’s
share of certain values. Replication of the numbers herein by using this simplified equation should not be considered
when evaluating this recommendation.
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jurisdictions with smaller housing share than population share can expect their HAPT output to decrease
over earlier results.
Comparing HAPT Results from Prior Versions and Now
As a handy comparison of how overall housing Table 2: Comparison of HAPT Total Housing by Jurisdiction
allocations would change when housing share
is input into HAPT rather than population Total New Units Change if
share, the table at right lists the total housing Using Using Using
allocation using both inputs. Also shown is Pop Housing Housing
whether the total housing units would increase Jurisdiction Share Share Share
or decrease for each jurisdiction when using Unincorporated Rural 3,534 6,195 Higher
housing share, as the tool intended. Unincorporated UGA 22,946 17,142 Lower
While housing share is the intended input for Airway Heights 5,007 3,955 Lower
HAPT, using housing share would increase the Cheney 2,535 2,076 Lower
housing allocation to the rural areas (outside Deer Park 1,023 1,083 Higher
the UGA). To a greater degree, the larger Fairfield 0 0 Higher
jurisdictions would also be subject to a larger Latah 0 0 Higher
allocation. Liberty Lake 6,601 5,180 Lower
Medical Lake 179 329 Higher
It’s important to note that while this represents Millwood 36 106 Higher
a large change for some jurisdictions, increased Rockford 53 68 Higher
allocations to those communities in the center Spangle 0 15 Higher
of the UGA (City of Spokane, Spokane Valley) is Spokane 17,550 22,359 Higher
consistent with the requirements of GMA, Spokane Valley 15,713 16,661 Higher
wherein growth should be concentrated in the Waverly 7 15 Higher
UGA and limited on the edges.
While the allocation for unincorporated rural areas would be more than 3/4 larger, that increase would
be spread throughout a very large area (all parts of the County outside the UGA), tempering the effects
of that growth somewhat. Furthermore, urban scale services to those additional homes would not be
required due to their location.
PTAC Recommendations: Housing Share and HAPT
Following multiple discussions on the differences between population share and housing share, PTAC
generally feels that housing share, created using the same assumptions already built into the HAPT, is the
most defensible and effective input for the HAPT. The following benefits of using housing share discussed
were as follows:
• The assumptions used to generate housing share from population share are identical to those in
the HAPT now.
• The HAPT model is sophisticated—an adjustment in one variable can have unintended
consequences.
• The data used to generate housing share have already been considered and adopted by the BOCC.
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Final Results
If the share of housing growth indicated in Table 1 in input into the HAPT, and the method previously
described as Method A Prime in the SCEO recommendation is utilized, then the final housing allocation
shown in the attached spreadsheet is provided.
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Appendix B:
Assembled Affordability by SubArea from
Public Market Data Sources
Appendix to Accommodating Affordable Housing in the City of Spokane, 2025
[Page 39]
Affordability Data by Subarea - Purchase Costs
Home Prices from fanniemae mortgage calculator
Mortgage Income
Source: Zillow SubareaMedian ValuePayment Required Bracket
Balboa-South Indian Trail $424,754 $3,635 $145,400 120+%AMI
Bemiss $280,200 $2,398$95,920 80-100%AMI
Browne's Addition $354,056 $3,031 $121,240 120+%AMI
Chief Garry Park $268,467 $2,298 $91,920 80-100%AMI
Cliff-Cannon $405,652 $3,473$138,920 120+%AMI
Comstock $448,209 $3,836 $153,440 120+%AMI
East Central $307,951 $2,636 $105,440 80-100%AMI
Emerson-Garfield $292,084 $2,500 $100,000 80-100%AMI
Five Mile-Prairie $565,299 $4,839 $193,560 120+%AMI
Hillyard $280,517 $2,401 $96,040 80-100%AMI
Latah Valley $566,119 $4,846$193,840 120+%AMI
Lincoln Heights $391,469 $3,351 $134,040 120+%AMI
Logan $303,672 $2,599 $103,960 80-100%AMI
Manito-Cannon Hill $535,315 $4,582 $183,280 120+%AMI
Minnehaha $314,370 $2,690$107,600 80-100%AMI
Moran Prairie $494,428 $4,232 $169,280 120+%AMI
Nevada-Lidgerwood $299,131 $2,560 $102,400 80-100%AMI
North Hill $310,829 $2,661$106,440 80-100%AMI
North Indian Trail $496,470 $4,249 $169,960 120+%AMI
Northwest $346,592 $2,966 $118,640 120+%AMI
Peaceful Valley $329,062 $2,817$112,680 120+%AMI
Riverside $400,099 $3,424 $136,960 120+%AMI
Rockwood $619,562 $5,303 $212,120 120+%AMI
Thorpe-Westwood $442,224 $3,785 $151,400 120+%AMI
West Central $299,526 $2,563 $102,520 80-100%AMI
West Hills $405,951 $3,475 $139,000 120+%AMI
Whitman $280,856 $2,404$96,160 80-100%AMI
Home Prices from fanniemae mortgage calculator
Mortgage Income
Source: Redfin SubareaMedian ValuePayment Required Bracket
Balboa-South Indian Trail $382,450 $3,274 $130,960 120+%AMI
Bemiss $295,750 $2,532 $101,280 80-100%AMI
Browne's Addition $310,000 $2,654 $106,160 80-100%AMI
Chief Garry Park $296,956 $2,542 $101,680 80-100%AMI
Cliff-Cannon $430,000 $3,681 $147,240 120+%AMI
Comstock $435,475 $3,728$149,120 120+%AMI
East Central $300,000 $2,568 $102,720 80-100%AMI
Emerson-Garfield $302,500 $2,589 $103,560 80-100%AMI
Five Mile-Prairie $565,530 $4,841 $193,640 120+%AMI
Grandview Thorpe $463,000 $3,962 $158,480 120+%AMI
Hillyard $285,000 $2,439 $97,560 80-100%AMI
Latah Valley $574,950 $4,921 $196,840 120+%AMI
Lincoln Heights $403,000 $3,449 $137,960 120+%AMI
Logan $318,000 $2,722 $108,880 120+%AMI
Manito-Cannon Hill $540,000 $4,622 $184,880 120+%AMI
Minnehaha $330,000 $2,825 $113,000 120+%AMI
Moran Prairie $634,656 $5,432 $217,280 120+%AMI
Nevada-Lidgerwood $302,000 $2,585 $103,400 80-100%AMI
North Hill $305,000 $2,611 $104,440 80-100%AMI
North Side $335,000 $2,868 $114,720 120+%AMI
Northwest Spokane $340,000 $2,910 $116,400 120+%AMI
Peaceful Valley $310,000 $2,654 $106,160 80-100%AMI
Riverside $460,000 $3,937 $157,480 120+%AMI
Rockwood $635,000 $5,435$217,400 120+%AMI
West Central $280,500 $2,400 $96,000 80-100%AMI
West Hills $415,000 $3,552 $142,080 120+%AMI
Whitman $291,000 $2,491 $99,640 80-100%AMI
NOTE: The subareas above do not necessarily correspond to Spokane Neighborhood Council boundaries.
[Page 40]
Affordability Data by Subarea - Rental Costs
Rental Costs
Average Rent Income
Source: RentCafe Subarea(May 2025)Required Bracket
Balboa - South Indian Trail $1,330 $53,200 0-80%AMI
Bemiss $1,442 $57,680 0-80%AMI
Browne's Addition $1,546 $61,840 0-80%AMI
Chief Garry Park $1,426 $57,040 0-80%AMI
Cliff - Cannon $1,441 $57,640 0-80%AMI
Comstock $1,373 $54,920 0-80%AMI
East Central Spokane $1,345 $53,800 0-80%AMI
Emerson - Garfield $1,521 $60,840 0-80%AMI
Five Mile Prairie $1,328 $53,120 0-80%AMI
Grandview - Thorpe $1,540 $61,600 0-80%AMI
Hillyard $1,366 $54,640 0-80%AMI
Latah Valley $1,467 $58,680 0-80%AMI
Lincoln Heights $1,149 $45,960 0-80%AMI
Logan $2,009 $80,360 80-120%AMI
Manito - Cannon Hill $1,139 $45,560 0-80%AMI
Minnehaha $1,366 $54,640 0-80%AMI
Moran Prairie $1,329 $53,160 0-80%AMI
Nevada - Lidgerwood $1,237 $49,480 0-80%AMI
North Hill $1,072 $42,880 0-80%AMI
North Indian Trail $1,759 $70,360 80-120%AMI
Northwest Spokane $1,382 $55,280 0-80%AMI
Peaceful Valley $1,546 $61,840 0-80%AMI
Riverside $1,466 $58,640 0-80%AMI
Rockwood $1,139 $45,560 0-80%AMI
Southgate $1,529 $61,160 0-80%AMI
West Central Spokane $1,546 $61,840 0-80%AMI
West Hills $1,425 $57,000 0-80%AMI
West Meadows $1,277 $51,080 0-80%AMI
Whitman $1,335 $53,400 0-80%AMI
Rental Costs
Average Rent Income
Source: Apartments.com Subarea (May 2025) Required Bracket
Bemiss $1,202 $48,080 0-80%AMI
Chief Garry Park $1,555 $62,200 0-80%AMI
City Center $1,460 $58,400 0-80%AMI
Cliff Cannon $1,359 $54,360 0-80%AMI
Comstock $1,330 $53,200 0-80%AMI
Dartford $1,394 $55,760 0-80%AMI
Downtown $1,410 $56,400 0-80%AMI
Emerson Garfield $1,374 $54,960 0-80%AMI
Lincoln Heights $1,127 $45,080 0-80%AMI
Logan $1,360 $54,400 0-80%AMI
Moran Prairie $1,380 $55,200 0-80%AMI
Nevada Lidgerwood $1,202 $48,080 0-80%AMI
North Spokane $1,311 $52,440 0-80%AMI
Palisades Park $1,282 $51,280 0-80%AMI
Rockwood $1,157 $46,280 0-80%AMI
South Spokane $1,265 $50,600 0-80%AMI
Town and Country $1,369 $54,760 0-80%AMI
U-District $1,659 $66,360 80-120%AMI
West Central $1,326 $53,040 0-80%AMI
West Spokane $1,274 $50,960 0-80%AMI
NOTE: The subareas above do not necessarily correspond to Spokane Neighborhood Council boundaries.
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City of Spokane
Department of Planning & Economic Development
808 W. Spokane Falls Blvd
Spokane, WA 99201
(509) 625-6500
compplan@spokanecity.org