Draft EIS (Full)

Draft EIS - Full Document
PlanSpokane 2046 Draft Environmental Impact Statement, complete 614-page document
Published December 18, 2025
Source: https://static.spokanecity.org/documents/planspokane/draft-eis/spokane-2046-deis-full.pdf

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City of Spokane
Comprehensive Plan
Update 2026-2046
Draft Environmental Impact Statement
December 2025

Consultant Team
BERK Consulting, Inc.
Cascadia Consulting Group
Fehr & Peers
Kauffman and Associates
Parametrix

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Fact Sheet

Project Title
City of Spokane Comprehensive Plan Periodic Update known as PlanSpokane 2046

Proposed Action and Alternatives
The City of Spokane is preparing a periodic update to the City’s Comprehensive Plan for a horizon of
20 years, from 2026 to 2046. The City’s Comprehensive Plan was last updated in 2017. The
Comprehensive Plan helps the City manage growth, provide housing, and job opportunities, conserve
natural and cultural resources, plan for services and infrastructure (e.g., streets, stormwater, parks),
and more.

Most chapters of the plan will be updated to address new growth targets for population and jobs, and
to meet changes to the Growth Management Act (GMA) since 2017, including considerations around
Climate Planning and Planning for Housing at all income levels.

The Land Use Plan Map will be amended to create more housing and job opportunities and respond to
growth targets, community needs, transportation investments, and environmental conditions. Zoning
and other development regulations will also be amended to implement the Land Use Plan Map.
Critical area regulations will be evaluated and recent state planning rules addressed.

The City is considering tools to facilitate environmental review under the State Environmental Policy
Act (SEPA), including a planned action (RCW 43.21c.440) for subareas such as transit corridors or
employment and mixed-use centers, housing development categorical exemptions (RCW 43.21c.229),
or raising minor new construction thresholds (WAC 197-11-800(1)(c) and (d)).

The City is studying three Alternatives for the Comprehensive Plan:
 Alternative 1, Stay the Course: This SEPA required Alternative (No Action Alternative) is the
continuation of the current Comprehensive Plan and associated zoning and regulations.

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 Under this Alternative, the Comprehensive Plan and development regulations would not be
updated. However, growth would still occur under this alternative under current rules—it
does not assume zero growth over time.
 Alternative 1 has capacity to meet total housing and population targets but would not provide
sufficient capacity for housing at income levels 0-80% of the area median income (AMI, as
determined by the Federal Housing and Urban Development Department for Spokane
County.
 This Alternative assumes jobs would grow consistent with regional Spokane Regional
Transportation Council (SRTC) projections.
 Alternative 2, Distributed and Balanced: Alternative 2 adds greater housing and job intensity
along frequent transit routes.
 Alternative 2 applies recommendations from the adopted Centers and Corridors Study (2024)
to better consider market conditions and zoning best practices, including the use of mixed-
use land use and/or zoning designations.
 Alternative 2 provides sufficient capacity to meet housing and population targets, including
creating greater capacity of housing types that are affordable to all income levels.
 To evaluate the phasing of infrastructure needs, Alternative 2 would have a job growth level
similar to State Employment Security Department trends.
 Alternative 2 prioritizes a balance between the numbers of jobs and housing (also known as a
jobs/housing balance).
 Alternative 2 encourages neighborhood/small scale retail.
 Alternative 2 simplifies the land use plan so that there are fewer land use designations, which
are then implemented by multiple zones.
 Alternative 2 facilitates growth through an infill exemption under SEPA (RCW 43.21c.229),
where the Environmental Impact Statement (EIS) provides upfront evaluation of residential
and mixed-use growth along frequent transit routes, and documents plans or development
regulations that provide mitigation measures. The City may also raise SEPA thresholds
citywide (WAC 197-11-800) or in targeted areas in the city.
 Alternative 2 includes anticipated climate resilience and greenhouse gas reduction goals and
policies per House Bill (HB) 1181. It would also review and update critical areas regulations.
 Alternative 3, Center City and Regional Hubs: Alternative 3 adds greater housing and job
intensity in the City of Spokane’s downtown vicinity called the “Center City” and in employment
centers in Southwest and Northeast Spokane.
 Alternative 3 focuses housing growth in regional hubs, particularly Center City and selected
corridors. Under Alternative 3, city investments prioritize certain centers and major corridors
to maximize impact of designation. Designations in other areas are removed or modified
where appropriate, while still considering livability/streetscape improvements.
 Alternative 3 concentrates industrial jobs in West Plains and Northeast Spokane and
additional education/health jobs in the City Center and University areas.
 Alternative 3 provides sufficient capacity to meet housing and population targets, including
creating greater capacity of housing types that are affordable to all income levels.
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 Alternative 3 establishes the highest jobs allocation that focuses investments in areas with
existing/planned transportation infrastructure (Downtown transit and street network, airport,
rail corridors, North Spokane Corridor or NSC).
 Like Alternative 2, Alternative 3 simplifies the land use plan so that there are fewer land use
designations, which are then implemented by multiple zones.
 Like Alternative 2, Alternative 3 facilitates growth through an infill exemption (RCW
43.21c.229) along frequent transit routes, particularly bus rapid transit. Infill exemption areas
would be focused areas for residential and mixed-use development. The City may also raise
SEPA thresholds citywide (WAC 197-11-800) or in targeted areas in the city.
 Like Alternative 2, Alternative 3 includes anticipated climate resilience and greenhouse gas
reduction goals and policies per HB 1181. It would also review and update critical areas
regulations.

Proponent and Lead Agency
City of Spokane

Location
The Comprehensive Plan primarily addresses the Spokane city limits. Secondarily the plan addresses
unincorporated urban growth areas and utility service areas abutting the city.

Tentative Date of Implementation
December 2026

Responsible SEPA Official
Spencer Gardner, Director, Planning Services
City of Spokane
808 W. Spokane Falls Blvd
Spokane, WA 99201
509.625.6097 | sgardner@spokanecity.org

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City of Spokane Comprehensive Plan Update 2026-2046 Fact Sheet
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Contact Person
Tirrell Black, Assistant Planning Director
City of Spokane
808 W. Spokane Falls Blvd
Spokane, WA 99201
509.625.6185 | PlanSpokane@spokanecity.org

Required Approvals
All Comprehensive Plan amendments and implementing regulations require a 60-day review by the
State of Washington Department of Commerce and other state agencies.

All transportation elements require a 60-day review by the Spokane Regional Transportation Council,
acting as both the Regional Transportation Planning Organization and the Metropolitan
Transportation Planning Organization for the region.

Locally, PlanSpokane 2046 and associated regulatory updates will be considered by the Spokane Plan
Commission and its recommendations will be forwarded to the Spokane City Council who will
deliberate and determine approval.

Following City Council approval, the City of Spokane Mayor must sign the related ordinance(s) for final
adoption to occur.

Principal EIS Authors and Contributors
Under the direction of the Planning & Economic Development Department of the City of Spokane, the
consultant team prepared the EIS as follows:
 BERK Consulting: Prime consultant; alternatives; land use patterns and urban form; relationship to
plans, policies, and regulations; population, employment, and housing; public services.
 Cascadia Consulting Group: Air quality/Greenhouse gas; public engagement.
 Fehr & Peers: Transportation.
 Kauffman and Associates: Cultural and natural resources; Tribal engagement.
 Parametrix: Earth, water quality, water resources; plants and animals; utilities (power, water,
wastewater, and stormwater)

Draft EIS Date of Issuance
December 18, 2025

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City of Spokane Comprehensive Plan Update 2026-2046 Fact Sheet
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Draft EIS Comment Period
Comment Period
The City of Spokane is requesting comments from the public, agencies, Tribes, and all interested
parties on the Draft EIS from December 18, 2025 to February 18, 2026. Comments are due by 5:00
PM, February 18, 2026.

All written comments should be directed to:
Tirrell Black, Assistant Planning Director
City of Spokane
808 W. Spokane Falls Blvd
Spokane, WA 99201
509.625.6185 | PlanSpokane@spokanecity.org

Submittal of comments by email is preferred. Please include in the subject line “PlanSpokane
2046 Draft EIS Comments.”

Public Comment Opportunities
A series of public and agency workshops are planned during the Draft EIS comment period.

A hybrid Agency and Tribes Workshop is scheduled for Tuesday, January 6, 2026 from 9:30-11:30
a.m. at Spokane City Hall, City Council Briefing Center (Lower Floor). Attendees are encouraged to
attend in person if possible; if needed, a virtual Teams link is available. Please contact the Contact
Person above.

Members of the public are encouraged to attend Community informational and listening sessions
scheduled for January and February 2026.
 Virtual Lunch and Learn: When: January 13, 12 to 1 p.m. Where: Teams meeting, link on project
webpage
 PlanSpokane Listening Hours
 Session 1—When: January 20, 11 a.m. to 1 p.m. Where: Spokane City Hall, Tribal Room (Lobby)
 Session 2—When: February 3, 4 to 6 p.m. Where: Hillyard Library, Events Room
 Session 3—When: February 5, 3 to 6 p.m. Where: Liberty Park Library, Study Room A
 Session 4—When: February 10, 4 to 6 p.m. Where: Shadle Park Library, Studio Room
 Session 5—When: February 12, 4 to 6 pm Where: South Hill Library, Study Room A

More information can be found at https://my.spokane.edu/planspokane/draft-eis.

Date of Final Action
Up to December 2026

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Prior Environmental Review
This EIS builds on prior evaluation of the 2017 Shaping Spokane Comprehensive Plan. That
environmental review is contained in a 2017 EIS Addendum to the 2001 Draft Comprehensive Plan
Update EIS, which is available at https://static.spokanecity.org/documents/shapingspokane/draft-
plan/volume2-comp-plan-tech-data.pdf.

Location of Background Data
You may review the City of Spokane website for more information at
my.spokanecity.org/planspokane/. If you desire clarification or have questions, please see the contact
person above.

Purchase/Availability of Draft EIS
The Draft EIS is posted on the City of Spokane website at:
https://my.spokanecity.org/planspokane/draft-eis.

This Draft EIS is also available for review at:
Spokane City Hall
808 W. Spokane Falls Blvd
Spokane, WA 99201

Printed versions are available at cost from the City.

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Distribution List

A notice of availability of the Draft Environmental Impact Statement (EIS) was published and
distributed to agencies, Tribes, and organizations.

Federal and Tribal Agencies
Coeur D'Alene Tribe
Confederated Tribes of the Colville Reservation
Kalispel Tribe of Indians
Spokane Tribe of Indians
U.S. Army corps of Engineers

State and Regional Agencies
Department of Archaeology & Historic Preservation
Department of Commerce
Department of Ecology
Department of Fish & Wildlife
Department of Natural Resources
Department of Transportation
Spokane Regional Clean Air Agency
Spokane Regional Transportation Council

Adjacent Jurisdictions
Spokane County
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City of Spokane Comprehensive Plan Update 2026-2046 Distribution List
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City of Airway Heights
City of Spokane Valley

Services, Utilities, and Transit
Airway Heights Water
American Medical Response
Avista Utilities
Bonneville Power Administration
Cheney School District
District 81 Capital Projects
Fairchild AFB
Fire District 3
Fire District 8
Fire District 9
Fire District 10
Four Lakes Water District
Inland Power
Mead School District Facilities & Planning
Medical Lake Water
North Spokane Irrigation District #8
Spokane Airports
Spokane Aquifer Joint Board
Spokane County Water District 3
Spokane Regional Health District
Spokane Transit Authority
Whitworth Water
Williams Northwest Pipeline

Community, Organizations, Media
American Indian Community Center
Downtown Spokane Partnership
East Sprague Parking and Business Improvement Area
Native Project

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City of Spokane Comprehensive Plan Update 2026-2046 Distribution List
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Neighborhood Councils
Northeast PDA
S3R3
Spokane Riverkeeper
Spokane Tribal Network
Spokane University District
The Spokesman-Review
Upper Columbia United Tribes

City of Spokane
Asset Management
Building Department
City Attorney
City Treasurer & City Taxes & Licenses
Code Enforcement
Construction Management
Engineering Services
Fire Department
GIS
Historic Preservation
Integrated Capital Management
Library Services
Neighborhood Services
Parks Department
PIES
Planning & Development
Police Department
Public Works
Solid Waste
Street Operations
Wastewater Management
Water Department

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Contents

1 Summary 1-1
1.1 Purpose 1-2
1.1 Public Comment Opportunities 1-5
1.2 Objectives, Proposal, and Alternatives 1-5
1.3 Key Issues and Options 1-13
1.4 Summary of Impacts and Mitigation Measures 1-13
1.4.1 Earth, Water Quality, and Water Resources 1-16
1.4.2 Air Quality/Greenhouse Gases 1-18
1.4.3 Plants and Animals 1-21
1.4.4 Land Use Patterns and Urban Form 1-23
1.4.5 Population, Employment, and Housing 1-27
1.4.6 Relationship to Plans, Policies, and Regulations 1-30
1.4.7 Transportation 1-32
1.4.8 Public Services 1-41
1.4.9 Utilities 1-44

2 Proposal and Alternatives 2-1
2.1 Introduction 2-2
2.1.1 Overview of the Proposal 2-2
2.1.2 Alternatives 2-2
2.1.3 Study Area 2-4
2.1.4 Objectives of the Proposal 2-8
2.2 Planning Context 2-9
2.2.1 Growth Management Act 2-9
2.2.2 Comprehensive and Subarea Planning 2-10
2.2.3 Growth Targets and Alternatives 2-13
2.2.4 PlanSpokane Policies and Regulation Proposals 2-20

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2.3 Public Outreach 2-22
2.3.1 Visioning and Scoping Period 2-22
2.3.2 Draft Comprehensive Plan and Draft EIS Engagement 2-24
2.4 Proposed Action and Alternatives 2-25
2.4.1 Alternative Comparison 2-25
2.4.2 Alternative 1: No Action, Stay the Course 2-27
2.4.3 Alternative 2: Distributed and Balanced 2-32
2.4.4 Alternative 3: Center City and Regional Hubs 2-36
2.4.5 Future Alternatives 2-40
2.5 SEPA Process 2-40
2.6 Benefits and Disadvantages of Delaying the Proposed Action 2-41

3 Environment, Impacts, and Mitigation Measures 3-1
3.1 Earth, Water Quality, and Water Resources 3-3
3.1.1 Affected Environment 3-3
3.1.2 Impacts 3-24
3.1.3 Mitigation Measures 3-30
3.1.4 Significant Unavoidable Adverse Impacts 3-32
3.2 Air Quality and Greenhouse Gas Emissions 3-33
3.2.1 Affected Environment 3-34
3.2.2 Impacts 3-44
3.2.3 Mitigation Measures 3-50
3.2.4 Significant Unavoidable Adverse Impacts 3-53
3.3 Plants and Animals 3-54
3.3.1 Affected Environment 3-54
3.3.2 Impacts 3-70
3.3.3 Mitigation Measures 3-73
3.3.4 Significant Unavoidable Adverse Impacts 3-78
3.4 Land Use Patterns and Urban Form 3-79
3.4.1 Affected Environment 3-79
3.4.2 Impacts 3-118
3.4.3 Mitigation Measures 3-127
3.4.4 Significant Unavoidable Adverse Impacts 3-131
3.5 Population, Employment, and Housing 3-133
3.5.1 Affected Environment 3-134
3.5.2 Impacts 3-163
3.5.3 Mitigation Measures 3-184
3.5.4 Significant Unavoidable Adverse Impacts 3-190
3.6 Relationship to Plans, Policies, and Regulations 3-191
3.6.1 Affected Environment 3-191
3.6.2 Impacts 3-215

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3.6.3 Mitigation Measures 3-231
3.6.4 Significant Unavoidable Adverse Impacts 3-232
3.7 Transportation 3-233
3.7.1 Affected Environment 3-235
3.7.2 Impacts 3-264
3.7.3 Mitigation Measures 3-284
3.7.4 Significant Unavoidable Adverse Impacts 3-287
3.8 Public Services 3-288
3.8.1 Affected Environment 3-288
3.8.2 Impacts 3-313
3.8.3 Mitigation Measures 3-322
3.8.4 Significant Unavoidable Adverse Impacts 3-323
3.9 Utilities 3-324
3.9.1 Affected Environment 3-324
3.9.2 Impacts 3-343
3.9.3 Mitigation Measures 3-348
3.9.4 Significant Unavoidable Adverse Impacts 3-351

4 Acronyms and References 4-1
4.1 Acronyms 4-2
4.2 References 4-4
4.2.1 Earth, Water Quality, and Water Resources 4-4
4.2.2 Air Quality 4-4
4.2.3 Plants and Animals 4-7
4.2.4 Land Use Patterns and Urban Form 4-10
4.2.5 Population, Housing, and Employment 4-12
4.2.6 Relationship to Plans, Policies, and Regulations 4-14
4.2.7 Transportation 4-18
4.2.8 Public Services 4-19
4.2.9 Utilities 4-21

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5 Appendices 5-1
A Scoping and Public Outreach 5-3
B Transportation Analysis Zones Maps 5-4
C Transportation Project Implementation Table 5-11
D Utility Maps 5-13
E Environmental Review Exemptions to Promote Infill Development and
Housing 5-2
5.1 Introduction and Purpose 5-3
5.2 Exemption Types 5-4
5.2.1 Infill and Housing Exemptions 5-4
5.2.2 Flexible Categorical Exemption Thresholds in SEPA Rules 5-6
5.2.3 “Exceptions” to Exemptions 5-7
5.3 City of Spokane Environmental Regulations 5-8
5.4 Potential Infill Exemption Location 5-18

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Exhibits
Exhibit 1.1-1. Spokane Study Areas 1-3
Exhibit 1.1-2. City of Spokane Neighborhoods 1-4
Exhibit 1.2-1. Growth Alternatives – Comparison of Features 1-6
Exhibit 1.2-2. Ability to Meet SEPA Objectives 1-7
Exhibit 1.2-3. Alternative Concepts 1-9
Exhibit 1.2-4. Example Land Uses 1-10
Exhibit 1.2-5. Growth Distribution Maps – Housing 1-11
Exhibit 1.2-6. Growth Distribution Maps – Jobs 1-12
Exhibit 1.4-1. Summary of Citywide Impacts and Mitigation – Natural
Environment 1-14
Exhibit 1.4-2. Summary of Impacts and Mitigation – Built Environment 1-15
Exhibit 1.4-3. Potential to Reduce Economic Displacement Pressure 1-29
Exhibit 1.4-4. Transportation Thresholds of Significance 1-33
Exhibit 1.4-5. Summary of Significant Impacts 1-35
Exhibit 1.4-6. Existing (2024) and Alternatives VMT per Capita 1-36
Exhibit 1.4-7. Mode Share – Existing and Alternatives 1-36
Exhibit 1.4-8. Spokane Intersection LOS – All Alternatives 1-37
Exhibit 2.1-1. Employment Growth and Alternatives 2-4
Exhibit 2.1-2. Spokane Study Areas 2-5
Exhibit 2.1-3. City of Spokane Neighborhoods 2-6
Exhibit 2.1-4. Existing Water Retail Service Areas 2-7
Exhibit 2.2-1. Recent and Ongoing Subarea Planning and
Transportation Investments 2-12
Exhibit 2.2-2. Housing Target and Affordable Housing Capacity 2020-
2046 2-13
Exhibit 2.2-3. City of Spokane Housing Unit Capacity by Affordability –
Alternative 1 Stay the Course 2-14
Exhibit 2.2-4. Residential Typologies 2-15
Exhibit 2.2-5. Persons per Household 2-17
Exhibit 2.2-6. Single Unit and Multi-Unit Housing Shares by Alternative 2-18
Exhibit 2.2-7. Employment Projections 2-19
Exhibit 2.2-8. Commercial Typologies 2-20
Exhibit 2.2-9. Industrial and Employment Typologies 2-20
Exhibit 2.3-1. Engagement Themes 2-23
Exhibit 2.4-1. Alternatives Overview 2-26
Exhibit 2.4-2. Alternative 1 Stay the Course 2-28
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Exhibit 2.4-3. Alternative 1 – Growth Intensity 2-29
Exhibit 2.4-4. Alternative 1 Housing Growth 2-30
Exhibit 2.4-5. Alternative 1 Job Growth 2-31
Exhibit 2.4-6. Alternative 2 Distributed and Balanced 2-33
Exhibit 2.4-7. Alternative 2 Housing Growth 2-34
Exhibit 2.4-8. Alternative 2 Job Growth 2-35
Exhibit 2.4-9. Alternative 3: Center City and Regional Hubs 2-37
Exhibit 2.4-10. Alternative 3 Housing Growth 2-38
Exhibit 2.4-11. Alternative 3 Job Growth 2-39
Exhibit 2.5-1. SEPA EIS Steps 2-40
Exhibit 3.1-1. Terrain 3-4
Exhibit 3.1-2. Existing Zoning 3-5
Exhibit 3.1-3. Existing Hard (Impervious) Surfaces 3-7
Exhibit 3.1-4. Hydrologic Soil Groups 3-8
Exhibit 3.1-5. Soil Type Summary 3-9
Exhibit 3.1-6. Hazardous Geology 3-13
Exhibit 3.1-7. Surface Waters 3-15
Exhibit 3.1-8. Surface Waters Summary Table 3-16
Exhibit 3.1-9. Water Quality Impairments 3-17
Exhibit 3.1-10. Shorelines 3-18
Exhibit 3.1-11. FEMA Flood Zones 3-19
Exhibit 3.1-12. Groundwater Resources 3-21
Exhibit 3.1-13. West Plains Private-Well PFAS Levels by Location 3-22
Exhibit 3.1-14. West Plains PFAS Private Well Sampling Data 3-22
Exhibit 3.1-15. Environmental Health Disparities 3-23
Exhibit 3.1-16. Summary of Impact Indicators 3-25
Exhibit 3.1-17. Existing Hard Surfaces and Forecasted Density
Distribution – Alternative 1 3-26
Exhibit 3.1-18. Existing Hard Surfaces and Forecasted Density
Distribution – Alternative 2 3-27
Exhibit 3.1-19. Existing Hard Surfaces and Forecasted Density
Distribution – Alternative 3 3-28
Exhibit 3.1-20. Density Projections as Indicators of Impacts by Spokane
Region 3-30
Exhibit 3.2-1. Spokane County PM2.5 Trends, 2011-2023 3-38
Exhibit 3.2-2. Daily 24-hour Average PM10 for All Spokane County
Monitoring Stations, May 2025. 3-39

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Exhibit 3.2-3. Spokane County Ozone Trends, 2011-2022 3-40
Exhibit 3.2-4. Relative exposure to ozone (left) and PM2.5 (right) in
Spokane. 3-43
Exhibit 3.2-5. Transportation Emissions Summary (MTCO2e). 3-47
Exhibit 3.2-6. Emissions from community transportation under three
scenarios: one with full EV adoption (assuming a 15-year
vehicle lifespan), one in which the current internal-
combustion vehicle mix remains constant, and one with
a moderate EV adoption rate (assuming a 25- year
lifespan). 3-48
Exhibit 3.2-7. Energy Emissions Summary (MTCO2e). 3-48
Exhibit 3.2-8. Emissions associated with each alternative, by sector. 3-49
Exhibit 3.3-1. Noxious Weeds in the Study Area and Surrounding Region 3-55
Exhibit 3.3-2. Land Cover Types in the Study Area 3-57
Exhibit 3.3-3. Land Cover Types in the Study Area 3-58
Exhibit 3.3-4. Natural Resource Designations in the City of Spokane 3-63
Exhibit 3.3-5. Tree Canopy Cover by Neighborhood in the City of
Spokane 3-65
Exhibit 3.3-6. Summary of Federally Listed Species and Washington
Priority Species in the Study Area 3-68
Exhibit 3.4-1. Adopted Land Use Plan Map as of 2025 3-82
Exhibit 3.4-2. Existing Land Use Designation (summarized) by Acreage 3-83
Exhibit 3.4-3. Summary of Existing Land Uses by Area 3-83
Exhibit 3.4-4. Existing Zoning Districts Summary Table 3-85
Exhibit 3.4-5. Existing Zoning Map as of 2025 3-88
Exhibit 3.4-6. Zone by Acreage 3-89
Exhibit 3.4-7. Maximum Height Limit 3-92
Exhibit 3.4-8. Tree Canopy Coverage 3-93
Exhibit 3.4-9. Spokane United Railways system, 1929 3-97
Exhibit 3.4-10. Aerial Image of Downtown Spokane (Circa 1970 and
Present Day) 3-98
Exhibit 3.4-11. Existing Land Use 3-99
Exhibit 3.4-12. Downtown Center City Spokane 3-104
Exhibit 3.4-13. Spokane Housing and Commercial (Pacific Street) 3-105
Exhibit 3.4-14. Spokane Housing (Holyoke Ave) 3-105
Exhibit 3.4-15. Land Capacity Analysis under Current Zoning –2025
(Acres) 3-106

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Exhibit 3.4-16. State Archaeological Risk Assessment Model – City of
Spokane Vicinity 3-107
Exhibit 3.4-17. Historic Districts – National and Local 3-108
Exhibit 3.4-18. Historic Districts and Properties in City of Spokane 3-109
Exhibit 3.4-19. Historic Districts and Properties – Central Spokane
Vicinity 3-110
Exhibit 3.4-20. Existing Transportation-Related Noise 3-112
Exhibit 3.4-21. National Transportation Noise Exposure Map – Share of
Population Exposed to Noise Greater than 50 dB 3-113
Exhibit 3.4-22. Population in Census Tracts within Proximity to Heavy
Traffic Roadways 3-114
Exhibit 3.4-23. Land Surface Temperature and Census Blocks with Very
High Vulnerability 3-116
Exhibit 3.4-24. Future Land Use Intensity Qualitative Comparison 3-119
Exhibit 3.4-25. Land Use Summary Evaluation by Area 3-120
Exhibit 3.4-26. Above Ground Cultural Resources Department of
Archaeology and Historic Preservation (DAHP) Predictive
Model and Summary Survey Recommendations 3-129
Exhibit 3.5-1. Population Growth 1990-2025 and Future Growth to 2046 3-134
Exhibit 3.5-2. Age Structure, City of Spokane + County Comparison (ACS
S0101) 2019-2023 3-135
Exhibit 3.5-3. Race and Ethnicity – City of Spokane (2019-2023) 3-135
Exhibit 3.5-4. Persons per Household 2022 3-136
Exhibit 3.5-5. Citywide Proportion of Households by Income and Tenure
2013 and 2023 3-137
Exhibit 3.5-6. Cost-Burden by Race and Ethnicity and Tenure, City of
Spokane, 2019-2023 3-137
Exhibit 3.5-7. City of Spokane Housing Stock, April 1, 2024 3-138
Exhibit 3.5-8. Net Change in Housing Stock April 1,2013 to April 1,2024
(OFM) 3-139
Exhibit 3.5-9. Housing Unit Completions and Demolitions – April 1, 2010
to April 1, 2024 3-139
Exhibit 3.5-10. Accessory dwelling units completed as of April 1st of each
year 3-140
Exhibit 3.5-11. Housing Action Plan Strategies 3-141
Exhibit 3.5-12. City of Spokane Displacement Risk Map 2025 3-143
Exhibit 3.5-13. Summary of RDI Policy Evaluation 3-145
Exhibit 3.5-14. Center Line BRT and Quarter Mile Buffer with Current
Zoning 2025 3-146
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December 2025 ▪ Draft EIS

Exhibit 3.5-15. City Line HB 1491 Floor Area Ratio Conceptual Evaluation
(2025) 3-148
Exhibit 3.5-16. Total Jobs 2002-2022 (in thousands) 3-149
Exhibit 3.5-17. Employment by Industry, 2002 and 2022 3-150
Exhibit 3.5-18. City of Spokane Employment Change by Industry, 2002 -
2022 3-150
Exhibit 3.5-19. Target Investment Area 3-152
Exhibit 3.5-20. Population Density and Race (2020) 3-155
Exhibit 3.5-21. Income and Poverty 3-156
Exhibit 3.5-22. Redlined Areas in City of Spokane 1938 3-158
Exhibit 3.5-23. Percent of housing units built before 1960 3-159
Exhibit 3.5-24. Affordability of Rental and Owner Housing 3-160
Exhibit 3.5-25. Total Jobs (2022) 3-161
Exhibit 3.5-26. Selected Job Sectors 3-162
Exhibit 3.5-27. Alternative 1 Land Capacity and Total Housing Target 3-163
Exhibit 3.5-28. Population and Household Size 3-164
Exhibit 3.5-29. Housing Capacity and Affordability – Alternative 1 3-165
Exhibit 3.5-30. Housing Types by Alternative 3-166
Exhibit 3.5-31. Housing Mix 2022 and 2046 by Alternative 3-167
Exhibit 3.5-32. City of Spokane – Compassion Spokane Approach to
Homelessness 3-168
Exhibit 3.5-33. Housing Action Plan Strategies Advanced under
Alternatives 3-169
Exhibit 3.5-34. Projected Housing Units Demolished by Housing Type 3-172
Exhibit 3.5-35. Projected Housing Units Demolished by Affordability
Level 3-172
Exhibit 3.5-36. Projected Housing Units Demolished by Study Area 3-173
Exhibit 3.5-37. Projected Units Demolished by Displacement Risk Score 3-173
Exhibit 3.5-38. Potential to Reduce Economic Displacement Pressure 3-174
Exhibit 3.5-39. Amenities by Census Tract: Schools, Libraries, Parks, and
Community Centers 3-175
Exhibit 3.5-40. Commercial and Industrial Properties likely to Redevelop 3-177
Exhibit 3.5-41. Employment Growth and Potential for Redevelopment
and Displacement 3-178
Exhibit 3.5-42. Jobs/Housing Balance 3-180
Exhibit 3.5-43. Jobs in Study Areas by Alternative 3-181
Exhibit 3.5-44. Summary Matrix of Housing and Business Anti-
Displacement Measures 3-184
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December 2025 ▪ Draft EIS

Exhibit 3.6-1 GMA Goals 3-192
Exhibit 3.6-2. Net New Housing Units and Emergency Housing Need,
2020-2046 3-195
Exhibit 3.6-3. SRTC Horizon 2045 Topic Area Principles 3-196
Exhibit 3.6-4. City of Spokane Comprehensive Plan - Land Use Element
Goals 3-199
Exhibit 3.6-5 Growth Management Act Goals - Alternative Evaluations 3-215
Exhibit 3.6-6. Countywide Planning Policies, Major Goals - Alternatives
Evaluation 3-218
Exhibit 3.6-7. SRTC Metropolitan Transportation Plan - Alternatives
Evaluation 3-220
Exhibit 3.6-8 THRIVE Spokane – Alternatives Evaluation 3-222
Exhibit 3.6-9. Alternatives Consistency with Northwest Spokane
Neighborhood Plans 3-224
Exhibit 3.6-10. Alternatives Consistency with Northeast Spokane
Neighborhood Plans 3-225
Exhibit 3.6-11. Alternatives Consistency with Center City Spokane
Neighborhood Plans 3-227
Exhibit 3.6-12. Alternatives Consistency with South Spokane
Neighborhood Plans 3-228
Exhibit 3.7-1. Spokane Existing Pedestrian Facilities 3-236
Exhibit 3.7-2. Spokane Existing Bicycle Network Facilities 3-239
Exhibit 3.7-3. Spokane Bicycle Priority Map 3-241
Exhibit 3.7-4. Summary of Existing Fixed Transit Types and Descriptions 3-243
Exhibit 3.7-5. Existing Transit Routes in Spokane 3-244
Exhibit 3.7-6. Spokane Vehicle Network and Roadway Classification 3-247
Exhibit 3.7-7. Spokane Transportation Network Bridges 3-248
Exhibit 3.7-8. Spokane Intersection LOS 3-249
Exhibit 3.7-9. State Routes and Functional Classifications 3-251
Exhibit 3.7-10. Existing State Facility Performance (v/c Ratio) 3-252
Exhibit 3.7-11. Spokane Freight Routes 3-255
Exhibit 3.7-12. Summary of Fatal and Serious Injury Crashes by Mode
and Severity in Spokane including State Routes (2020 -
2024) 3-257
Exhibit 3.7-13. Mode share (all person trips, %) 3-258
Exhibit 3.7-14. Thresholds of Significance 3-268
Exhibit 3.7-15. Spokane Existing State Facility Volume-to-Capacity Ratio 3-271

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December 2025 ▪ Draft EIS

Exhibit 3.7-16. Existing (2024) and Alternative 1 (No Action) VMT per
Capita 3-273
Exhibit 3.7-17. Mode Share – No Action Alternative 3-273
Exhibit 3.7-18. Spokane Intersection LOS – Alternative 1 (No Action) 3-274
Exhibit 3.7-19. Alternative 1 (No Action) and Alternative 2 VMT per
Capita 3-276
Exhibit 3.7-20. Mode Share – Alternative 2 3-277
Exhibit 3.7-21. Spokane Intersection LOS – Alternative 2 3-278
Exhibit 3.7-22. Alternative 1 (No Action) and Alternative 3 VMT per
Capita 3-280
Exhibit 3.7-23. Mode Share –Alternative 3 3-280
Exhibit 3.7-24. Spokane Intersection LOS – Alternative 3 3-281
Exhibit 3.7-25. Summary of Significant Impacts 3-283
Exhibit 3.8-1. Police Officers per 1,000 Population 3-289
Exhibit 3.8-2. Spokane Police Stations 3-290
Exhibit 3.8-3. Fire Stations and Areas Served 3-292
Exhibit 3.8-4. Spokane Fire Department Stations 3-293
Exhibit 3.8-5. Schools and Districts in Spokane 3-296
Exhibit 3.8-6. Ratio of Students to Housing Units 3-297
Exhibit 3.8-7. Spokane Parks and Amenities 3-299
Exhibit 3.8-8. Parks Acreage 3-300
Exhibit 3.8-9. Trails Acreage 3-300
Exhibit 3.8-10. Park Acres per 1,000 3-301
Exhibit 3.8-11. Gaps in Park Access 3-302
Exhibit 3.8-12. Libraries in Spokane 3-305
Exhibit 3.8-13. Libraries Square Footage 3-306
Exhibit 3.8-14. Waste Facility Capacity 3-308
Exhibit 3.8-15. Poor Physical Health 3-310
Exhibit 3.8-16. Social Vulnerability Index 3-311
Exhibit 3.8-17. Student Growth by School District 3-314
Exhibit 3.8-18. Park Acreage Needs 3-314
Exhibit 3.8-19. Library Levels of Service 3-315
Exhibit 3.8-20. Social Disparities and Housing Growth 3-316
Exhibit 3.9-1. 2026 Generating Capability by Fuel Source 3-325
Exhibit 3.9-2. Change in Energy Use by End Use, 2025-2045 3-326
Exhibit 3.9-3. Customer Load Forecast 3-327
Exhibit 3.9-4. City of Spokane Water System Pressure Zones 3-329

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Exhibit 3.9-5. Map of City of Spokane Water System Pressure Zones 3-330
Exhibit 3.9-6. Equivalent Residential Unit (ERU) Flowrates by Pressure
Zone 3-331
Exhibit 3.9-7. 20-year Projected Number of Equivalent Residential Units
per Pressure Zone 3-332
Exhibit 3.9-8. Growth Rate by Pressure Zone and Customer Class 3-333
Exhibit 3.9-9. Map of Sanitary Sewer Pump Stations In Spokane 3-336
Exhibit 3.9-10. Sanitary Sewer Pump Stations In Northwest Spokane 3-337
Exhibit 3.9-11. Sanitary Sewer Pump Stations In Northeast Spokane 3-338
Exhibit 3.9-12. Sanitary Sewer Pump Stations In Central Spokane 3-338
Exhibit 3.9-13. Sanitary Sewer Pump Stations In South Spokane 3-339
Exhibit 3.9-14. Sanitary Sewer Pump Stations In the West Plains 3-339
Exhibit 3.9-15. Drainage Concern Areas 3-341
Exhibit 3.9-16. Map of CSO/Storm/UIC Areas 3-342
Exhibit 3.9-17. Percent of gross household income spent on energy 3-345

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1 Summary

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

1.1 Purpose
This chapter summarizes the City of Spokane’s proposals to amend its Comprehensive Plan and
development regulations to meet the periodic update requirements of the Growth Management Act
(GMA). It summarizes the objectives to be achieved, and different Alternatives that could achieve those
objectives. It also summarizes environmental review findings in the Draft Environmental Impact
Statement (EIS). Details of the Alternatives are addressed in Chapter 2, and the full environmental
evaluation and mitigation measures are in Chapter 3.

The Draft EIS is organized as follows:
 Chapter 1 Summary
 Chapter 2 Proposal and Alternatives
 Chapter 3 Environment, Impacts, and Mitigation Measures
 Chapter 4 Acronyms and References
 Chapter 5 Appendices

This EIS primarily focuses on the City of Spokane city limits. The city study areas in Exhibit 1.1-1 are
referenced in the EIS:
 Northwest Spokane
 Northeast Spokane
 South Spokane
 West Plains
 Center City, overlapping several study areas, including Downtown Spokane
 Division corridor, straddling Northwest and Northeast Spokane

Within these broad subareas the EIS cites Neighborhood Council boundaries. See Exhibit 1.1-2.

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

Exhibit 1.1-1. Spokane Study Areas

Sources: City of Spokane, BERK, 2025.

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

Exhibit 1.1-2. City of Spokane Neighborhoods

Note: Peaceful Valley, Grandview/Thorpe, Browne’s Addition, and Whitman neighborhoods are shown but too small at this
scale to label.
Sources: City of Spokane, 2024; BERK 2024.

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

1.1 Public Comment Opportunities
The City of Spokane is requesting comments from the public, agencies, Tribes, and all interested parties
on the Draft EIS from December 18, 2025 to February 18, 2026. Comments are due by 5:00 PM,
February 18, 2026. See the Fact Sheet for the method to provide comments. A series of public and
agency workshops are planned during the Draft EIS comment period. For the latest information on the
workshop topics and times, please see the project website at:
https://my.spokanecity.org/planspokane/draft-eis.

1.2 Objectives, Proposal, and Alternatives
Objectives are required by SEPA to identify the purpose and need of the proposals and to compare
alternatives according to WAC 197-11-440 and -442. Objectives are particularly important when
comparing long-range plans like the City of Spokane Comprehensive Plan Periodic Update. This EIS
compares alternatives for their ability to meet these objectives:
 Meet Periodic Update Requirements: Comply with Comprehensive Plan periodic review
requirements to meet state laws including recent changes to the GMA regarding providing capacity
for more housing types and affordability levels, increasing resiliency to climate impacts, evaluating
tree canopy coverage, increasing opportunities for active transportation, reducing vehicle miles
traveled and greenhouse gas emissions, addressing needs of overburdened communities, increasing
green infrastructure, planning for jobs and economic development, and more.
 Accommodate Growth: Demonstrate population, transportation, and housing capacity to
accommodate growth targets through 2046 based on State projections and County allocations in
consultation with the City and ensure City utilities and services are expected to have sufficient
capacity to serve that growth.
 Clarify the Plan: Update policies that are inconsistent, outdated, duplicative, or unclear.
 Simplify the Plan and Codes: Update and simplify future land use map categories and zoning
districts and reflect any new designations such as within centers and corridors.
 Protect Critical Areas: Update critical area regulation updates that respond to best available
science.
 Fast-Track Desired Growth: Facilitate desired growth in priority locations through permit
streamlining, such as through SEPA infill exemptions or raising SEPA thresholds.

A vision statement, goals, or values in a plan can serve as objectives. The City’s proposed draft vision
statement for the Periodic Update is also considered an objective:
Spokane aims to foster a vibrant, resilient, and inclusive city by supporting economic growth,
environmental stewardship, and the diverse needs of the whole community. The City is dedicated to
ensuring access to attainable housing, safe streets, and thriving neighborhoods while inspiring
innovation, cultural vitality, and connection for all Spokane residents.

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

This vision incorporates PlanSpokane 2046 themes of Resilient, Connected, and Livable, as well as public
engagement themes of Nature, Community, Livability, and Innovation.

As part of the City of Spokane’s Comprehensive Plan Periodic Update, the City is preparing an
environmental impact statement (EIS) under the State Environmental Policy Act (SEPA). The City identified
EIS topics and alternatives following a scoping comment period from February 5 to April 7, 2025.

The Draft EIS studies three alternatives, the SEPA-required Alternative 1 Stay the Course (no action), and
Alternatives 2 and 3 that alter patterns of growth (see Exhibit 1.2-1).

Exhibit 1.2-1. Growth Alternatives – Comparison of Features
Alternative 1: Stay Alternative 2: Distributed Alternative 3: Center
the Course and Balanced City and Regional Hubs

Plan & Code Update Current Periodic Update Periodic Update
Areas of Focus for Growth Focuses growth in Mixed-use Transit- Growth in downtown,
Downtown and Oriented Development regional hubs, and
Centers and along frequent transit areas with greatest
Corridors. corridors. investment in transit
Allow more and transportation.
neighborhood-serving Allow more
commercial uses. neighborhood-serving
Simplified Land Use commercial uses.
Plan. Simplified Land Use
Plan.
Housing Growth Target: 2022- 21,738 units in addition to units already developed since 2020
2046 New units would add about 21% new housing stock to existing dwelling
units.
Housing Mix 63% single unit / 59% single-unit / 41% multi-unit (25% of new units
37% multi-unit expected to be single-unit, 75% expected to be
multi-unit)
Housing Affordability Targets: 0-80% Area Median Meets all income levels. Like Alternative 2.
2022-2046 Income (AMI): Denser housing in Provides housing at all
Insufficient proximity to transit. income levels with
80-120% AMI: Inclusion of new mixed- priority for denser
Sufficient use zones. housing along bus
120+% AMI: Meets state rapid transit per state
Sufficient requirements (HB 1491) requirements (HB
for transit-oriented 1491), and other
development near bus focused areas.
rapid transit.
Population Growth Ranges: 25,157
2022-2046 City’s share of OFM medium population forecast

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

Alternative 1: Stay Alternative 2: Distributed Alternative 3: Center
the Course and Balanced City and Regional Hubs
Job Projections 2022-2046 Regional (SRTC) State (ESD) Projection Moderate-High
Projection 34,850 24,939 net jobs Projection
* Each alternative studies a job net jobs. This is about 5,000 jobs 38,848 net jobs
projection from a different data This is about 15,000 above historic trend. This is about 19,000
source to support jobs above historic jobs above historic
infrastructure planning. The trend per Census. trend. Directed to
different numbers are not Center City, West
based on an alternative’s Plains, and Hillyard/
likelihood to produce more or Northeast public
fewer jobs. development
authorities.

Source: City of Spokane, BERK, 2025.

Alternatives 2 and 3 are designed to meet the meet state periodic update requirements (e.g., new
housing, climate, and other requirements), create the opportunity for housing at all income levels,
accommodate jobs, and update policies and codes to streamline them and facilitate growth. Alternatives
2 and 3 would align with the new vision statement. Alternative 1 was developed in prior years with
different growth targets and different state expectations and would partially meet the objectives. See
Exhibit 1.2-2 for a comparison across the alternatives.

Exhibit 1.2-2. Ability to Meet SEPA Objectives
Objectives Alternative 1: Stay Alternative 2: Alternative 3: Center City
the Course Distributed and and Regional Hubs
Balanced

Meet Periodic Update Less Most Most
Requirements
Accommodate Growth: Housing More Most Most
at All Affordability Levels
Accommodate Growth: Jobs More More Most
Clarify the Plan Less Most Most
Simplify the Plan and Codes Less Most Most
Protect Critical Areas More Most Most
Fast-Track Desired Growth Less Most Most
Alignment with Vision Statement Less Most Most
Source: City of Spokane, BERK, 2025.

Maps of each alternative are shown in Exhibit 1.2-3, Exhibit 1.2-4, Exhibit 1.2-5, and Exhibit 1.2-6.
Alternative 1 maintains current designations and housing and job growth intensities. Alternatives 2 and 3
add more moderate and high-density housing, mixed use and commercial, and employment/industrial
areas in areas with frequent transit or in already-established centers.

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Exhibit 1.2-3. Alternative Concepts
Alternative 1: Stay the Course Alternative 2: Distributed and Balanced Alternative 3: Center City and Regional Hubs

Key Features Growth Intensity

Source: City of Spokane, BERK, 2025.

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Exhibit 1.2-4. Example Land Uses

Residential

Single Family with ADU Six Plex (S Grand Blvd.) Lowrise Apt (605 S Grand) Box Car, Univ. District

Low Density Housing Moderate Density High Density Housing
Housing

Commercial/Mixed Use

Corner Cafe (Maple Street) Shopping Center Nonna Mixed Use River Park Square

Neighborhood Commercial Mixed Use Downtown
Commercial

Industrial/Employment

West Plains Area Spokane Med. District Trent Avenue 860 E Spokane Falls

Light Industrial Employment Light Heavy Industrial Employment Heavy

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Exhibit 1.2-5. Growth Distribution Maps – Housing
Alternative 1: Stay the Course Alternative 2: Distributed and Balanced Alternative 3: Center City and Regional Hubs

Source: City of Spokane, BERK, 2025.

Legend – Net New Housing Units

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

Exhibit 1.2-6. Growth Distribution Maps – Jobs
Alternative 1: Stay the Course Alternative 2: Distributed and Balanced Alternative 3: Center City and Regional Hubs

Source: City of Spokane, BERK, 2025.

Legend – Net New Jobs

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1.3 Key Issues and Options
The key issues facing decision makers include:
 Development of a growth concept and goals and policies that implement the plan’s vision and
objectives:
 Vision: “Spokane aims to foster a vibrant, resilient, and inclusive city by supporting economic growth,
environmental stewardship, and the diverse needs of the whole community. The City is dedicated to
ensuring access to attainable housing, safe streets, and thriving neighborhoods while inspiring
innovation, cultural vitality, and connection for all Spokane residents.”
 Objectives:
 Meet Periodic Update Requirements
 Accommodate Growth
 Clarify the Plan
 Simplify the Plan and Codes
 Protect Critical Areas
 Fast-Track Desired Growth
 Approval of a comprehensive plan that meets state and county requirements to accommodate
housing needs at all income bands including best location for units at 0-80% AMI affordability and
addressing racially disparate impacts in access to housing.
 Approval of a comprehensive plan that provides land use and transportation strategies to reduce
greenhouse gas emissions.
 Approval of a comprehensive plan that increases resilience to climate-related hazards, reduces
exposure to pollution, and addresses environmental impacts.
 Approval of development regulations that implement the Comprehensive Plan goals, policies, and
land use plan.

1.4 Summary of Impacts and Mitigation Measures
This section summarizes findings for each environmental topic addressed in the EIS, including:
 Earth, Water Quality, and Water Resources
 Air Quality/Greenhouse Gases
 Plants and Animals
 Land Use Patterns and Urban Form
 Relationship to Plans, Policies, and Regulations
 Population, Employment, and Housing
 Transportation
 Public Services
 Utilities

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

See Chapter3 Environment, Impacts, and Mitigation Measures for the full context of the affected
environment, potential impacts, and mitigation measures. Exhibit 1.4-1 and Exhibit 1.4-2 show a
summary of impacts and mitigation for each alternative.

Exhibit 1.4-1. Summary of Citywide Impacts and Mitigation – Natural Environment

Topic: Potential Impacts and Mitigation Alt. 1 Alt. 2 Alt. 3

Earth, Water Quality, and Water Resources (section 3.1.2)
Potential for soil disturbance, erosion, water pollution, and soil   
contamination from construction activities.
Potential for increased pollution and potential for increased   
rainfall runoff flows based on housing density distribution.
(Higher impact weight than Jobs)
Potential for increased pollution based on job projections against   
already developed hard surfaces. (Lower Impact Weight than
Housing)
Air Quality/Greenhouse Gases (section 3.2.2)

Transportation emissions   
Emissions from non-transportation sources   
Plants and Animals (section 3.3.2)
Consistency with best available science. —  
Potential for impacts to plant and animal species, habitat
conversion, or loss of habitat connectivity
Center City   
Northwest   
Northeast   
South   
West Plains   
Strength of Mitigation – Plan and Code Updates —  
Adverse Impacts: Most impacts (), More impacts (), Less impacts. ().
Potential Beneficial Impacts/Mitigation: Neutral Impacts or Continued Plan/Code (—), Moderately positive (), or
Positive (). For example: New Climate Adaptation and Mitigation Policies, Critical Area Policy Amendments and Code
Updates, and Effects of Increased Housing Affordability/Reduction of Disparate Impacts Policies.

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

Exhibit 1.4-2. Summary of Impacts and Mitigation – Built Environment

Potential Impact and Indicators Alt. 1 Alt. 2 Alt. 3

Land Use Patterns and Urban Form (section 3.4.2)

Land use and urban form compatibility   
Cultural and historic resources, loss, alteration, or damage   
Environmental Justice - Increased exposure of overburdened
populations to light or noise pollution, environmental hazards, or   
urban heat island effects
Population, Employment, and Housing (section 3.5.2)

Capacity for housing and population targets   
Housing variety and affordability   
Implementation of Housing Action Plan   
Growth in housing displacement risk areas / increased housing
/  /  / 
supply that reduces economic displacement pressure
Amount of new housing in connected and accessible
—  
neighborhoods (transit, libraries, parks)
Jobs/housing balance  — 
Job types and quantity and ability to advance City and regional
  
economic development strategies
Commercial business economic displacement   
Relationship to Plans, Policies, and Regulations (section 3.6.2)   
Transportation (section 3.7.2)
Pedestrian Network and Bicycle Network   
Transit   
Vehicle Miles Traveled   
Safety   
Road intersection levels of service   
State Facilities   
Public Services (section 3.8.2)
Citywide demand for police, fire/emergency medical services,
  
schools, parks, libraries, and solid waste
Demand for school capacity – Spokane School District   
Demand for school capacity – Mead School District   
Environmental Justice – Growth in Areas with Health and Social
  
Disparities and Greater Service Demand

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

Potential Impact and Indicators Alt. 1 Alt. 2 Alt. 3

Utilities (section 3.9.2)
Power, Water, Wastewater Demand   
Power, Water, Wastewater Infrastructure Upgrades   
Stormwater Generation   
Strength of Mitigation Potential – Plan and Code Updates —  
Impacts: Most impacts (), More impacts (), Less impacts. (), Moderately positive (), or Positive ().
Potential Beneficial Impacts/Mitigation: Neutral Impacts or Continued Plan/Code (—), Moderately positive (), or
Positive (). For example: New Climate Adaptation and Mitigation Policies, Critical Area Policy Amendments and Code
Updates, and Effects of Increased Housing Affordability/Reduction of Disparate Impacts Policies.

1.4.1 Earth, Water Quality, and Water Resources

Latah Hangman Creek Confluence, M. Murphy, City of Spokane, 2024

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City of Spokane Comprehensive Plan Update 2026-2046 Summary
December 2025 ▪ Draft Environmental Impact Statement

How did we analyze Earth, Water Quality, and Water Resources?
The EIS team reviewed data sources related to steep slopes, land development impacts, hard surfaces
and water runoff, soil types and water infiltration, geologic hazards and contaminated soils, surface water
bodies and watersheds, water quality impairments, shorelines, floodplains, and groundwater resources.
The team also considered data on environmental health disparities across Spokane.

Thresholds of significance used in this analysis include:
 Environmental Earth and Soil Hazards: Disturbances of existing contaminated areas to levels that
could endanger human health or the environment.
 Surface Water Quality: Increases in amount of pollution to receiving waters that would impair their
designated uses (such as human contact and fish habitat).
 Runoff Increases: Impervious surface expansions that would increase runoff flow volumes and
durations to streams by magnitudes resulting in bank scour and erosion.
 Groundwater Recharge: Impervious surface expansions that would decrease groundwater recharge
beyond designated limits.
 Groundwater Quality: Increases in amount of pollution discharged to levels that would contaminate
groundwater supplies.

What impacts did we identify?
All alternatives would have impacts from construction, which would remove some vegetation and hard
surfaces, which could lead to soil disturbance, erosion, water pollution, and soil contamination. All
alternatives would also have potential for increased pollution, due to growth, and increased rainfall
runoff, due to increased hard surfaces. Under all alternatives, stormwater runoff best management
practices (BMPs), and increased density, which would reduce sprawl in the region, would mitigate these
impacts.

What is different between the alternatives?
Increased population, housing, and jobs can increase impacts to earth and water resources in the city
through increased vehicle use, commercial and light industrial activities that produce waste substances,
landscaping with chemicals, and other pollution-generating activities. These impacts would be mitigated
by the presence of stormwater runoff best management practices (BMPs) on roadways and other
pollution-generating surfaces. Overall, Alternative 1 has the highest impacts, Alternative 2 has medium
impacts, and Alternative 3 has the lowest impacts for earth, water quality, and water resources.
 Projections for increased housing are the metrics with the most weight and are used in the earth and
water resources impacts analysis as indicators of increased rainfall runoff. The amount of land with
hard surfaces versus vegetation impacts how much and how quickly rainfall runoff and pollutants
may soak into the earth or are transported to natural receiving waters. Housing density distribution
differs across the alternatives. By creating more density in areas that are currently developed,
Alternative 3 has the lowest expected pollution and stormwater runoff impacts and Alternative 2 has
the second lowest impacts. Alternative 1, in contrast, places more growth in areas with more
undeveloped land.

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 Job projections are the metrics with the least weight in the earth and water resources impact analysis
and are used as indicators of increased pollution. Job projections differ, with Alternative 1 and
Alternative 3 having the greatest job growth and therefore the greatest potential increased pollution
impacts compared to Alternative 2.
 Alternatives 2 and 3 have the strongest mitigation due to including code update, a new Climate
Element, and critical area regulations updates.

What are some solutions or mitigation for impacts?
 Alternatives 2 and 3 include a new Climate Element with climate resilience and greenhouse gas
reduction goals and policies.
 Alternatives 2 and 3 review and update critical areas regulations.
 Federal, state, and regional regulations on water quality, shoreline management, floodplain
management, flood insurance, endangered species, stormwater management, highway runoff,
erosion control, hydraulic control, and environmental standards also mitigate (by preventing or
minimizing) most impacts from development.
 The City could consider additional measures such as installing updated stormwater controls on
roadways, prioritizing opportunities to restore critical area buffers, protecting and expanding tree
canopy, and following recommendations of a recent environmental code audit.

With mitigation, what is the ultimate outcome?
No significant unavoidable adverse impacts to earth and water resources are expected from the plan
alternatives since development associated with every project alternative would be required to implement
best management practices (BMPs) to minimize or avoid potential impacts to earth and water resources.

1.4.2 Air Quality/Greenhouse Gases

How did we analyze Air Quality/Greenhouse Gases?
The EIS team reviewed data sources related to air quality issues and regulations, regional greenhouse gas
emissions, regional air quality monitoring data, air quality permitting requirements, and climate impacts
on air quality and vulnerable populations. Greenhouse gas (GHG) emissions estimates were based on the
City’s 2022 GHG inventory, population and household estimates, employee counts, energy consumption,
and transportation modeling. Other pollutants, including PM₂.₅, ozone, and NOₓ were assessed
qualitatively using City and State sources.

Thresholds of significance used in this analysis include the alternative’s ability to achieve:
 45% reduction in GHG emissions by 2030
 70% reduction in GHG emissions by 2040
 Net Zero by 2050 (per GHG Inventory Results)

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What impacts did we identify?
For all three scenarios, emissions from energy consumption and vehicle transportation will lead to air
quality issues and pollution burden throughout the city. This will especially be the base in areas with
closer proximity to major roads and highways. Several neighborhoods are already disproportionately
exposed to pollutants such as PM₂.₅ and ozone, a pattern that is especially evident in eastern Spokane,
including the Hillyard, Lincoln Heights, and Chief Garry Park neighborhoods.

Despite higher VMT when compared to the 2024 baseline, all alternatives show a net decrease in
transportation emissions by 2046. This reduction is primarily driven by statewide policy assumptions,
including the 2035 ban on internal combustion engine sales and the 2030 clean-electricity mandate.
When modeled with a 15-year vehicle lifespan (full EV Adoption), these policies result in faster paced
vehicle turnover and substantial emissions reductions.

The 2030 clean-electricity mandate significantly reduces community energy emissions across all
alternatives when compared to the 2024 baseline.

Differences in energy emissions between the three growth alternatives are driven largely by projected
changes in residential housing stock and employment capacity

What is different between the alternatives?
Alternative 1 produces the highest emissions for both community energy and transportation. Higher
projected employment capacity and a lower proportion of multifamily housing lead to elevated energy
consumption in 2046. Transportation emissions are also greatest in this alternative due to the highest
projected VMT and the lowest share of walking, biking, and transit trips. This car-dominant pattern
reduces mobility for residents without vehicle access and increases housing scarcity due to limited
multifamily options.

Alternative 2 results in the lowest energy and transportation emissions across all scenarios.
Transportation emissions decline due to the lowest VMT and a reduced share of trucks and heavy-duty
vehicles. Energy emissions also decrease, driven by a larger share of multifamily housing and the lowest
projected commercial and industrial employment capacity. Compared to Alternative 1, this alternative
supports greater transportation choice and expanded multifamily housing options. However, one
potential tradeoff is a more competitive job market due to reduced employment growth.

Alternative 3 results in emissions lower than Alternative 1, but slightly higher emissions than Alternative
2. Energy emissions are influenced by the highest projected employment capacity among all alternatives,
although the emphasis on multifamily housing alleviates overall energy demand relative to Alternative 1.
Transportation emissions are slightly lower than those in Alternative 1 due to marginally reduced VMT,
but higher than those in Alternative 2. Overall, Alternative 3 represents a middle ground between the
higher-emissions No Action alternative and the lower-emissions Alternative 2 Distributed and Balanced
model.

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What are some solutions or mitigation for impacts?
 Alternatives 2 and 3 update the existing comprehensive plan policies, including those that protect the
natural environment and reduce pollution, and also include new climate resilience and greenhouse
gas reduction goals and policies.
 Federal, state, and regional regulations help to mitigate impacts from criteria pollutants, vehicle
emissions, and other air quality hazards.
 Washington State regulations, like the Climate Commitment Act, Clean Energy Transformation Act,
Clean Buildings Performance Standard, Clean Buildings Act, energy codes, and zero-emission vehicle
standards, support the City in reducing greenhouse gas emissions.
 Spokane’s 2021 Sustainability Action Plan also addresses renewable electricity targets and how to
achieve them while mitigating risks from climate change and investing in strengthening Spokane
communities.
 The City could consider additional investment in multi-modal transportation infrastructure, fees that
reduce traffic congestion, greater land use mix and density, electric vehicle adoption, incentives for
building electrification and energy efficiency, designated truck routes, tree canopy protection and
enhancement, street sweeping to reduce dust, zoning standards and other codes that reduce poor air
quality exposure, and increased education on air pollutants.

With mitigation, what is the ultimate outcome?
No significant unavoidable adverse impacts on air quality and GHG emissions are expected. By
implementing mitigation measures, supporting local and state climate initiatives, and through ongoing
regulatory changes, the alternatives could lead to lower GHG emissions on a per capita basis compared
to current conditions. Although each option would produce GHG emissions from growth and
development within the city, focusing development in targeted areas potentially offsets these impacts by
preventing development in peripheral regions of the city.

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1.4.3 Plants and Animals

Ponderosa Pine, City of Spokane, 2024

How did we analyze Plants and Animals?
The EIS team reviewed data related to habitat types, designated habitats, local habitat conditions, and
fish and wildlife species in Spokane. This includes terrestrial, aquatic, and riparian habitats more broadly,
along with mapped shorelines, wetlands, floodplains, and priority habitats with greater importance to
fish or wildlife.

Thresholds of significance used in this analysis include:
 Best Available Science: An alternative would be inconsistent with or counter to best available
science.
 Threatened and Endangered Species: An alternative may have adverse effects to state or federally
listed threatened or endangered species or their habitats that could not be sufficiently addressed
through avoidance, minimization, or mitigation measures, and could potentially result in an up-listing
or jeopardy determination.
 Other Species: An alternative could have population-level adverse effects to other important non-
listed plant or wildlife species (e.g., priority species, migratory birds) that would be perceptible and
measurable within the surrounding region.

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 Habitat Conversion: An alternative would potentially result in permanent habitat conversion, or loss
of habitat connectivity sufficient to compromise overall regional ecosystem function relative to
current conditions.

What impacts did we identify?
All alternatives would see some impacts from new development in currently vegetated areas, impacting
wildlife and fish habitats. Increased impervious surfaces could also affect aquatic habitats by increasing
peak flows, reducing low flows, introducing pollutants, increasing water temperatures, and reducing the
amount of shade. Short-term construction activities could also have impacts through runoff of soils and
sediments in aquatic habitats, as well as potential spills of fuels and fluids from construction equipment.
Noise impacts from construction could also disturb wildlife. Tree canopy loss in areas with overburdened
populations could have an elevated risk of adverse impacts, however, creating additional low-cost
housing options in areas with more tree canopy could be beneficial.

What is different between the alternatives?
Overall, Alternative 1 has the highest impacts while Alternatives 2 and 3 have lesser impacts.
 Alternative 1 would concentrate the least amount of new housing in areas that are currently
developed and the greatest amount of new housing in areas that contain substantial pockets of
priority habitat or other habitat, including North Indian Trail, Balboa/South Indian Trail, and Hillyard. It
would also place growth in Grandview/Thorpe and Latah/Hangman but the other alternatives would
focus a similar amount in these areas.
 Alternatives 2 and 3 would add greater density in already developed areas, such as Center City and
the Division Corridor, putting less development pressure on the less developed areas of Spokane that
contain more plant and animal habitat.
 Alternatives 2 and 3 would update the City’s critical areas code for best available science whereas
Alternative 1 would not include this update.

What are some solutions or mitigation for impacts?
 Alternatives 2 and 3 include new climate resilience and greenhouse gas reduction goals and policies,
which could also support plant and animal habitats.
 Alternatives 2 and 3 also review and update the City’s critical areas regulations best on best available
science.
 Federal, state, and local regulations can minimize impacts to wildlife, including the Endangered
Species Act, Migratory Bird Treaty Act, the Bald and Golden Eagle Protection Act, Section 404 of the
Clean Water Act, the Washington State Growth Management Act, the Washington Shoreline
Management Act, several sections of the Washington Administrative Code, and the City’s
Environmental Standards provisions of in Title 17E of the SMC and the Spokane Shoreline Master
Program.
 The City could consider increased program resources for the SpoCanopy tree canopy cover program,
incentive programs for habitat conservation and restoration, land acquisition opportunities in key

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areas, adaptive management policies for critical area and shoreline codes, and critical areas code
language that limits clearing and soil disturbance.

With mitigation, what is the ultimate outcome?
All of the alternatives would result in unavoidable adverse impacts such as permanent conversion of
forested areas and vegetated open space to developed space, decreased wildlife habitat connectivity,
and additional stormwater runoff to aquatic habitats from increased impervious surfaces. However,
because much of the population and employment growth anticipated under the alternatives would take
place in currently developed areas, and because of existing and anticipated regulations, these effects
would be moderated below the level of significance. No significant unavoidable adverse impacts are
expected to result from any of the alternatives.

1.4.4 Land Use Patterns and Urban Form

Overlook, Cliff Park, M. Murphy, City of Spokane, 2024.

How did we analyze Land Use Patterns and Urban Form?
The EIS team reviewed the local policy framework, existing land use designations and zoning districts,
urban form regulations, land use patterns and current conditions, and cultural resources. The team also
included an analysis of environmental justice considerations, including noise, light and glare, shade and
shadow, and heat islands.

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Thresholds of significance used in this analysis include:
 Land use compatibility: Changes in use type between adjacent areas and any likely incompatibility.
Land use incompatibility could be related to health and safety (such as noise levels), activity levels at
various times of day/night, or conflicting movement patterns.
 Urban form compatibility: Changes in building form, scale, massing, or spatial organization between
adjacent areas and any likely incompatibility. Urban form incompatibility may involve abrupt
transitions in building height or bulk, inconsistent setbacks or street wall continuity, or mismatched
public realm design that result in visual disruption, diminished walkability, or the overshadowing of
public spaces.
 Cultural Resources: Loss, alteration, or damage of archaeological, cultural, and historical resources
and sites due to growth allowed by alternatives.
 Environmental Justice: Land use or urban form changes that disproportionately impact historically
marginalized or underserved communities with environmental, health, or socioeconomic burdens.
This includes increased exposure to noise and light pollution, as well as urban heat island effects,
especially in areas with high environmental health disparities, sensitive populations, and limited tree
canopy, vegetation, or public open space.

What impacts did we identify?
While the alternatives differ in how growth is distributed and intensified across the city, all alternatives
concentrate the highest levels of future growth in centers, corridors, and commercial and
industrial/employment areas that already feature higher intensities, a more diverse mix of uses, and
greater access to frequent transit. Outside these hubs, growth is directed toward low- to moderate-
intensity housing and neighborhood-scale commercial development in designated locations. More
diverse land uses will locate near each other under all alternatives, increasing mixed-use patterns but
also potentially causing adverse compatibility impacts.

Over time, infill and redevelopment will raise development intensity in areas not yet built to full zoning
capacity. Spillover effects such as noise could also occur. Additional height and bulk in commercial,
mixed-use nodes is expected and would likely be consistent with development experienced over the last
20 years. Residential areas would see limited changes in height but more development of middle housing
types and accessory dwelling units (ADUs). Some neighborhoods could see noticeable changes such as
apartments or middle housing being built next to smaller-scale or single-unit homes. Some trees would
be displaced on private property as bulkier development occurs, however street trees may increase
where required with redevelopment. Building shadows from taller and bulkier buildings would occur, and
some scenic views could be impacted. There is also potential for disturbance to archeological resources
during construction and effects to historic properties under all alternatives.

What is different between the alternatives?

Land Use and Urban Form Compatibility
 Alternative 1 continues existing zoning so minimal new conflicts between adjacent land uses are
expected. Existing scale and form patterns would be maintained, and abrupt transitions could occur

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where high density Centers meet lower-density neighborhoods. There would be limited
improvements in street connectivity, sidewalks, and public realm design.
 Alternative 2 maintains existing network of centers and corridors but better connects them by
encouraging greater integration of mixed-use development and commercial activities along transit-
rich corridors. Alternative 2 may reduce large-scale incompatibility between land uses by spreading
growth in existing center and corridors and employment hubs. Small-scale, neighborhood-oriented
retail nodes may create conflicts in some residential areas in terms of noise and traffic. Changes in
building height or scale could contrast with low density neighborhoods as gradual densification
occurs. More street-level design and pedestrian infrastructure could occur and improve walkability.
 Alternative 3 directs most of the new housing, mixed-use development, and job growth toward major
hubs, particularly Center City and the University District as well as West Plains and Hillyard.
Concentration of high-intensity residential, commercial, and industrial uses may create sharp
transitions between dense hubs and lower-density neighborhoods. More intense building scale,
massing, and intensity would be located in major hubs. There may be more intense development in
Center City to the south and west compared to current uses and plans. Transitions from Center City
are expected to be gradual.

Cultural Resources
 Alternative 1 provides for more development in undeveloped areas and may result in less
redevelopment pressure overall on historic sites though since more development is focused in low
density areas there may be a greater risk that undisturbed cultural resources may be found.
 Alternative 2 provides for more housing types and could create impacts where new mixed-use nodes
or corridors overlap with sensitive historic or cultural sites. With less pressure to develop in lower
density areas compared to Alternative 1, there could be less potential risk to undisturbed cultural
resources under Alternative 2.
 Alternative 3: Concentrated development in Center City and Northeast in Hillyard where there are
documented historic and cultural resources could mean a greater potential to alter or demolish
historic buildings or overlap sensitive cultural sites. Incentives to encourage adaptive reuse and
historic preservation regulations would be applied. With less pressure to develop in lower density
areas, there could be less potential risk to undisturbed cultural resources under Alternative 3
compared to Alternative 1.

Environmental Justice
 Alternative 1 continues current plans and provides for growth primarily in undeveloped areas. It does
not address racially disparate impacts or climate-related hazards such as adaptation to extreme heat.
Historically underserved communities may continue to face unequal access to amenities, transit, or
services and existing environmental burdens.
 Under Alternative 2, more population could be located on corridors with transportation noise and
there could be more urban streetscapes with less tree canopy. However, there is an opportunity to
increase landscaping, tree canopy, and shade with new development. A broader distribution of
mixed-use development and services may increase access to historically underserved communities
and reduce environmental burdens by encouraging transit use and shorter trips.

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 Under Alternative 3, most of the new housing, mixed-use development, and job growth is directed
toward major hubs, particularly Center City as well as West Plains and Hillyard. This targeted
approach to development creates opportunities for large-scale infrastructure investments and
energy-efficient design, but it may also concentrate environmental stressors in specific areas unless
carefully mitigated such as through enhanced streetscape as a baseline improvement across more
corridors (addresses tree canopy and extreme heat), criteria for neighborhood commercial areas to
provide commercial and civic uses in areas without larger commercial nodes, noise abatement and
standards, and other similar approaches.

What are some solutions or mitigation for impacts?
 The City’s municipal code can help mitigate compatibility challenges in urban centers, corridors, and
employment/industrial hubs and address height, transitions between zones, building coverage,
landscaping, and aesthetic considerations. Some sections also address noise control, lighting shields
in Planned Unit Developments, and portable cooling devices for renters.
 Federal and state laws that govern the designation and protection of cultural resources can mitigate
impacts, such as the National Historic Preservation Act, the Archeological Resources Protection Act,
and several State laws.
 The City’s Shoreline Master Program includes regulations to stop work and studies if cultural
resources are encountered.
 Spokane’s zoning code includes Chapter 17D.100 Historic Preservation, which addresses the
nomination of historic landmarks or districts.
 The city could consider expanded development regulations and place-specific strategies:
 Apply cultural resources discovery policies to the full city limits instead of only designated
shoreline areas and develop a “decision tree” to determine appropriate level of investigation and
mitigation for below-ground cultural resources.
 Require detailed construction noise rules and best practices, noise reduction standards in areas
with high exterior noise levels, and noise reducing pavement in targeted areas. Coordinate with
WSDOT on sound wall construction.
 Provide additional development standards for light and shading, and make investments to
reduce impacts of extreme heat such as Tribal and cultural infrastructure, resilience hubs, tree
canopy expansion, or building retrofits.

With mitigation, what is the ultimate outcome?
There are no significant, unavoidable adverse impacts expected for land use, urban form, and
environmental justice. Application of the City’s adopted or new development regulations and zoning
requirements, including height, bulk, and scale requirements as well as climate mitigation and adaptation
measures, are anticipated to sufficiently mitigate these impacts.

All the alternatives have the potential for significant adverse impacts to cultural resources. Proactive
consideration of impacts to cultural resources results in more effective identification, planning, and
protection than reactive responses to inadvertent discoveries during project implementation. A well-

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designed and implemented pre-project cultural resource review process is the most effective way to
avoid, minimize, or mitigate adverse impacts.

1.4.5 Population, Employment, and Housing

Duplex, City of Spokane, Undated

How did we analyze Population, Employment, and Housing?
The EIS team reviewed data on population growth, household characteristics, housing stock and
affordability, displacement risk, racially disparate impacts, bus rapid transit and housing, jobs and
sectors, and economic development goals.

Thresholds of significance used in this analysis include:
 Capacity for Housing and Population:
 Ability of the alternative to provide sufficient buildable land capacity for population and housing.
 Housing Variety and Affordability:
 Ability to increase the supply, diversity, and affordability of market-rate housing.
 Ability to increase the supply of income-restricted housing.
 Regulatory barriers to and insufficient capacity for production of affordable units needed (in line
with City’s role / requirements under HB 1220).
 Ability to meet transit-oriented development requirements, or exemption requirements, in
proximity to bus rapid transit stations per state legislation.
 Equity & Disparate Impacts:
 Amount of new housing in areas with high displacement risk.
 Projected loss of homes due to demolition in high displacement risk areas.
 Amount of new housing in connected and accessible neighborhoods (transit, libraries, parks).
 Potential for job or business displacement for employment uses located within medium/high
intensity residential or mixed-use designated areas.

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 Employment:
 Ability to adversely affect citywide Jobs/Housing balance.
 Job types and quantity and ability to advance City and regional economic development
strategies.

What impacts did we identify?
All alternatives provide more capacity than the total citywide housing target and would more than meet
population targets. All alternatives also incorporate some housing policy and code changes made as a
result of the City’s Housing Action Plan, such as allowing more middle housing. Alternatives 2 and 3 would
better support housing affordability than Alternative 1. The majority of housing citywide would continue
to be single-unit under all alternatives. The City would also provide enough density allowances near
transit to meet State requirements. Under all alternatives, the City would continue to address temporary
shelter, re-housing, transitional housing, and permanent supportive housing for people experiencing
homelessness. Under all alternatives, most jobs are in Northeast Spokane and Center City. West Plains
will see a large change compared to present. Job increases in Northwest Spokane will be modest.

What is different between the alternatives?
Overall, Alternative 1 has the highest impacts while Alternatives 2 and 3 have lesser impacts.

Housing Variety and Opportunities
 Alternative 1 would not update the housing element of the comprehensive plan and would not
provide sufficient capacity in zones with potential to support new units at 0-80% AMI affordability
level, with a deficit of 5,477 units in the 2022-2046 period. It would also not make additional changes
to undo racially disparate impacts and address displacement, or update development regulations
around emergency shelters, transitional housing, emergency housing, and permanent supportive
housing.
 Alternatives 2 and 3 propose to increase opportunities for moderate to high intensity residential and
mixed-use development, which would increase land capacity and accommodate the required housing
targets by income band. It would also provide for more mixed-uses/commercial and higher intensity
residential along the City Line transit corridor.
 Under Alternatives 2 and 3, a greater share of the city’s housing capacity would be multi-unit housing
at 41%, instead of the 35% under Alternative 1. Alternative 3 would focus more density in the Center
City and Division Corridor study areas as well as selected other corridors, while Alternative 2 would
add density to more corridors throughout the city.
 Alternatives 2 and 3 update development regulations for emergency shelters, transitional housing,
emergency housing, and permanent supportive housing in line with state requirements.
 Alternatives 2 and 3 would advance more strategies from the City’s Housing Action Plan such as
streamlining permitting, improving infrastructure, targeting higher intensity development near transit,
and other strategies to reduce racially disparate impacts consistent with new Housing Element
requirements.

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Housing Production and Displacement
Potential for Physical Displacement: Based on growth patterns, Alternatives 2 and 3 are expected to
demolish over twice as many housing units when compared to Alternative 1, which directs more
development into undeveloped areas. In all alternatives, most of those units demolished are detached
single unit houses where the previous residents could be homeowners or renters. A smaller number of
demolished units are expected to be multifamily housing, which is much more likely to be occupied by
renters. Demolition would occur gradually over time as individual properties are redeveloped.

Reduced Economic Displacement Pressure: With more growth focused in already developed areas
along corridors and centers such as Division, Center City, and others, there is more development
expected in areas with high displacement risk under Alternatives 2 and 3, compared to Alternative 1. This
results in significantly more homes demolished in these areas. However, the flipside is also true. These
neighborhoods would also receive more new housing production and greater diversity of housing
options. This is expected to reduce economic displacement pressure compared to Alternative 1. See
Exhibit 1.4-3.

Exhibit 1.4-3. Potential to Reduce Economic Displacement Pressure

Ability to Reduce Economic Development Pressure Alt 1 Alt 2 Alt 3
Potential Capacity for New Housing Production ○ ●+ ●+
Potential Capacity to Increase Housing Diversity ○ ● ●+
Anti-displacement Measures included in Plan and Programs ○ ●+ ●+
Legend: ○ = partially supports ●=supports + = optimally supports

Employment
 Based on the applied employment projections, Alternatives 1 and 3 increase the share of jobs relative
to housing whereas Alternative 2 generally holds the current jobs/housing balance.
 The alternatives largely plan for industrial, both light and heavy, in similar locations as zoned under
Alternative 1, but more intense employment is planned, particularly under Alternative 3.
 Alternative 1 would not update the City’s economic development element policies or address
additional commercial displacement strategies, whereas Alternatives 2 and 3 would make these
updates.

What are some solutions or mitigation for impacts?
 Updates to the comprehensive plan under Alternatives 2 and 3 would address housing growth targets
at all income levels, evaluate racially disparate impacts and displacement, and remove barriers to
housing.
 The City of Spokane’s 2021 Housing Action Plan provides short, medium, and long-term strategies to
address the community’s housing needs. A number of strategies have already been implemented.
 StartUp Spokane is a program of Greater Spokane Inc., which in partnership with the Spokane Public
Library and Spokane County Library provides business resources for entrepreneurs.

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 The Small Business Administration Strategic Alliance Memorandum was signed by the U.S. Small
Business Administration, City of Spokane, and the AHANA Multi-Ethnic Business Association in
September 2022. It establishes a heightened level of commitment to work together to bring services
to underserved populations of entrepreneurs.
 Other strategies the City could consider include anti-displacement measures detailed in the Housing
Action Plan and the updated housing element based on the City’s racially disparate impacts
evaluation, including a Rental Assistance Fund, Public Development Authority, land banking, use of
development agreements, setting minimum density requirements, providing incentives for affordable
commercial tenant space, and other efforts.

With mitigation, what is the ultimate outcome?
Over time, additional growth and development will occur through redevelopment as well as on vacant
land. The alternatives vary based on the types and geographic pattern of existing housing and businesses
that may be demolished and replaced by new growth. While this can contribute to the risk of physical
displacement, the benefits in terms of reduced economic displacement pressure and increased
production of affordable units offered by the action alternatives would address affordability in the
marketplace, and the City’s new policies and regulations would address anti-displacement measures.
Therefore, no significant unavoidable adverse impacts to population, employment, or housing are
expected under any alternative.

1.4.6 Relationship to Plans, Policies, and Regulations

How did we analyze Relationship to Plans, Policies, and Regulations?
The EIS team reviewed the state, regional, and local policy and regulatory framework, including the
Growth Management Act, Countywide Planning Policies, Spokane Regional Transportation Council
policies, THRIVE Spokane Comprehensive Economic Development Strategy, Spokane’s existing
comprehensive plan, and Spokane neighborhood and subarea plans.

Thresholds of significance used in this analysis include:
 Conflicts with the Washington State Growth Management Act or Spokane County Countywide
Planning Policies.
 Inconsistency with adopted state, regional, county, or local plans and policies.

What impacts did we identify?
Alternatives 1, 2, and 3 each accommodate the 2046 growth targets and examine different ways the City
could distribute its 2046 forecast growth with varying degrees of concentration. All alternatives have
sufficient zoned vacant and redevelopable land to accommodate the overall 20-year population and
housing targets and job projections. Overall, all alternatives support Growth Management Act goals
related to transportation and urban services, and the key objectives of the City’s neighborhood plans.

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What is different between the alternatives?
Overall, Alternative 1 has the highest impacts while Alternatives 2 and 3 have lesser impacts.
 Alternative 1 would continue current plans and regulations that provide for urban growth served by
transportation and urban services. However, Alternative 1 does not have sufficient land capacity to
accommodate housing at all income levels, particularly 0-80% AMI. Alternative 1 does not meet HB
1181 requirements to include new climate resilience and greenhouse gas reduction goals and
policies.
 All alternatives are fairly consistent with the Countywide Planning Policies, SRTC Metropolitan
Transportation Plan, and THRIVE Spokane, but Alternatives 2 and 3 are better aligned with these
policies. Alternatives 2 and 3 are also better aligned with the Spokane Downtown Plan and the South
University District Subarea Plan.
 Alternatives 2 and 3 would each adopt a new growth strategy, and each element of the
Comprehensive Plan would be updated. The plan would continue to focus growth in an urban area
with a range of public services and multimodal transportation options, provide for public services like
parks and schools, and protect critical areas and environments consistent with the GMA. Alternatives
2 and 3 include climate planning, with goals and policies that are consistent with HB 1181 and support
improved climate resilience for vulnerable populations; these alternatives would also update the
critical areas regulations.
 Alternatives 2 and 3 concentrate housing and job growth in the Logan neighborhood which supports
the goals and objectives in the South Logan TOD Project and Plan, adopted by resolution in 2024.
Alternative 3 has the highest jobs allocation, with focused investment in key employment centers,
which supports locally adopted projects and subarea plans, including the South Logan TOD Plan, the
Spokane Downtown Plan, and the South University District Subarea Plan, as well as the proposed
Hillyard Subarea Plan.

What are some solutions or mitigation for impacts?
 Alternatives 2 and 3 meet housing targets at all income levels to address state housing requirements
in HB 1220.
 Alternatives 2 and 3 include climate planning goals and policies in the Comprehensive Plan to
implement state requirements of HB 1181 to have a Climate Element.
 As required by Growth Management Act, the City must submit proposed Comprehensive Plan
amendments and updated regulations for review and comment by the State prior to final adoption.

With mitigation, what is the ultimate outcome?
No anticipated unavoidable adverse impacts are anticipated with respect to plans and policies.
Inconsistencies with new regional plans and state requirements under Alternative 1 Stay the Course
would be avoided through amendments to the Comprehensive Plan proposed under the action
alternatives.

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1.4.7 Transportation

Spokane Transit Authority CityLine Bus Rapid Transit (Rebecca White, 2023)

How did we analyze Transportation?
The thresholds used to determine the impacts of all three alternatives include both quantitative and
qualitative assessments, which are described in Exhibit 1.4-4.

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Exhibit 1.4-4. Transportation Thresholds of Significance

Performance
Thresholds of Significance
Metric

Alternative 1 (No Action): A significant impact is identified if the City cannot achieve
100% of the 2017 Bicycle Master Plan network by 2037 as established in the previous
Active
Spokane Comprehensive Plan (TR 5) or if pedestrian improvements are not advanced
Transportation
in designated Pedestrian Priority Zones.
Network
Action Alternatives: A significant impact is identified if network completion under the
Completeness
Action alternative lags relative to the No Action alternative or fails to accelerate
progress toward bicycle and sidewalk network completeness.
Alternative 1 (No Action): A significant impact is identified if bicycle ridership fails to
Active increase toward the 2017 Bicycle Master Plan goal of quadrupling by 2036 (relative to
Transportation 2016 levels).
Usage Action Alternatives: A significant impact is identified if ridership increases are less
than the No Action alternative.
Alternative 1 (No Action): A significant impact is identified if there is noncompliance
with the City’s Vision Zero resolution, adopted in late 2022, meaning there is an
increased risk of any single traffic death or injury on City streets by 2042 (Vision Zero
Traffic Safety resolution horizon year).
Action Alternatives: A significant impact is identified if an Action alternative would
increase the likelihood of additional severe or fatal crashes compared to the No Action
alternative.
Alternative 1 (No Action): A significant impact is identified if study intersection or
corridor LOS falls below adopted standards (LOS F within Downtown and within
Transit Access
designated Centers/Corridors; LOS E elsewhere) or if pedestrian/bicycle connections
and
to STA facilities decline.
Performance
Action Alternatives: A significant impact is identified if there is an impact according
to the vehicle network performance thresholds for facilities used by transit.
Alternative 1 (No Action): A significant impact is identified if vehicle operations fail to
meet adopted intersection standards: LOS F (>120 seconds of delay) within the
Downtown and the area bounded by and including the Spokane River, Maple Street,
5th Avenue, and Sherman Street, and within zones that are designated by the City as
Vehicle “Centers and Corridors”; LOS E applies elsewhere. For state routes, an impact occurs if
Network a state facility does not meet the standard set by WSDOT (LOS D, segment volume-to-
Performance capacity (v/c) 1.00).
Action Alternatives: A significant impact is identified if an intersection (city or state
facility) degrades from an acceptable LOS in the No Action scenario; if the intersection
already exceeds LOS thresholds in the No Action scenario, then an impact is identified
if delay increases by 5 or more seconds. For state route segments, a significant impact

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Performance
Thresholds of Significance
Metric
is identified if the segment v/c increases by ≥0.05 at a location already at or above 1.00
under the No Action alternative.
Alternative 1 (No Action): A significant impact is identified if daily VMT per capita
increases by ≥ 1.0 miles/person or if SOV (drive alone) share increases by ≥ 1.0
VMT per
percentage point over 2024 conditions.
Capita and
Action Alternatives: A significant impact is identified if daily VMT per capita increases
Mode Share
by 0.2 miles/person or if SOV share increases by 0.2% relative to the No Action
alternative.

Sources: City of Spokane, WSDOT, SRTC, Fehr & Peers, 2025

What impacts did we identify?
Exhibit 1.4-5 summarizes impact findings across the alternatives. The purpose of this programmatic EIS
is to disclose how potential land use may affect the transportation system relative to what would occur
with currently adopted designations and policies (the No Action alternative). Accordingly, the impacts of
each Action alternative are assessed against the performance of No Action. Impacts expected to occur as
a result of the No Action alternative are also expected under the Action alternatives, even if the Action
alternatives do not result in additional significant impacts.

The Action alternatives perform similarly across categories. Relative to No Action, VMT and VMT per
capita decrease under both Action alternatives, so no significant impacts to VMT per capita or safety are
identified for the Action Alternatives.

For the vehicle network, measured with intersection LOS, the Action alternatives would not result in
additional impacts beyond the performance expected with the No Action alternative. The same
intersections serve transit and freight, so no additional impacts are identified for these categories.

No significant impacts to state facilities, the pedestrian network, the bike network, or mode share are
expected with any of the alternatives.

Across all studied locations and all three alternatives, v/c ratios are expected to remain below 1.0;
therefore, no significant state facility impacts are identified. The pattern shows modest growth and small
differences among alternatives, with the following corridors nearing but not exceeding capacity:
 I-90 west of Sprague Avenue (Spokane Valley) operates at v/c of 0.88–0.90 across alternatives
 US 2 east of the Sunset Frontage Road intersection operates at v/c of 0.83–0.84
 SR 902 south of the Geiger Blvd wye connection operates at v/c of 0.87–0.89

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Exhibit 1.4-5. Summary of Significant Impacts

Impact Type Alternative 1 — Alternative 2 Alternative 3
No Action

Pedestrian Network None None None
Bicycle Network None None None
Transit Significant Impact No additional impacts No additional impacts
beyond No Action beyond No Action
Safety Significant Impact No additional impacts No additional impacts
beyond No Action beyond No Action
VMT per Capita Significant Impact No additional impacts No additional impacts
beyond No Action beyond No Action
Mode Share None None None
Vehicle Network Significant Impact No additional impacts No additional impacts
(Intersection LOS) beyond No Action beyond No Action
State Facilities None None None
Freight Significant Impact No additional impacts No additional impacts
beyond No Action beyond No Action

Source: Fehr & Peers, 2025

What is different between the alternatives?

Vehicle Miles Travelled
All of the alternatives study housing growth to the growth target level with Alternative 1 having a greater
share of single-family housing than Alternatives 2 and 3 which add more attached housing in the
downtown and frequent transit corridors. Alternative 2 studies the lowest job growth, and Alternative 3
the highest with Alternative 1 in the middle.

With Alternative 2, total vehicle miles traveled (VMT) in Spokane are expected to be slightly lower than
with the No Action Alternative. VMT is expected to decrease to 5,732,000 on an average weekday, 3.3%
below the No Action alternative. This translates to a VMT per capita decreases from 19.9 (No Action) to
19.2 (Alternative 2). This reduction reflects the “distributed & balanced” growth pattern placing more new
housing and jobs in established centers and along frequent transit corridors, for example the Center City
and the Division Street areas, which would shorten average trip lengths. It also reflects slightly lower job
growth than Alternative 1 and Alternative 3, more similar to the current jobs/housing balance. See
Exhibit 1.4-6.

With Alternative 3, total vehicle miles traveled in Spokane are expected to be 5,916,000 on an average
weekday, which is slightly below the VMT with No Action and slightly higher than VMT with Alternative 2.

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This translates to a VMT per capita decrease from 19.9 (No Action) to 19.8 (Alternative 3). This slight
decrease reflects growth focused in the Center City and select regional hubs, which brings more trips
closer to destinations and frequent transit routes. However, although Alternative 3 places more housing
and jobs in the Center City than Alternative 2, it also assumes continued employment growth in industrial
hubs, most notably the West Plains/Airport area and Northeast/Hillyard, which increases trips and yields
higher total VMT than Alternative 2. See Exhibit 1.4-6.

Exhibit 1.4-6. Existing (2024) and Alternatives VMT per Capita

Existing 2046 Alt 1 2046 Alt 2 2046 Alt 3
(2024) (No Action)

VMT per Capita 17.9 19.9 19.2 19.8

Sources: SRTC, Fehr & Peers, 2025

Compared to No Action, Alternative 2 is expected to have a slight shift from shared-ride vehicular trips to
active modes with approximately 86,400 walking trips and 16,700 biking trips on an average weekday,
about 900 more walk trips and 100 more bike trips than No Action. See Exhibit 1.4-7.

Compared to No Action, Alternative 3 is expected to have a slight shift from shared-ride vehicle trips to
active modes with approximately 88,600 walking trips and 17,000 biking trips per day, which is about
3,100 more walk trips and 400 more bike trips than No Action. This is greater than the expected added
non-motorized trips than Alternative 2. See Exhibit 1.4-7.

Exhibit 1.4-7. Mode Share – Existing and Alternatives

Mode Existing 2046 Alt 1 2046 Alt 2 2046 Alt 3
(2024) (No Action)

Drive alone (SOV) 50.6% 50.3% 50.3% 50.3%
Shared ride (HOV) 39.5% 39.5% 39.3% 39.3%
Transit 1.2% 1.2% 1.2% 1.2%
Walk 7.3% 7.5% 7.7% 7.7%
Bike 1.4% 1.5% 1.5% 1.5%

Sources: SRTC, Fehr & Peers, 2025

Safety
Under No Action, population and employment growth are expected to increase the number of trips taken
and average trip distances relative to Existing (2024). As a result, total VMT and VMT per capita are higher
than Existing. This increase in VMT and VMT per capita translates into increased exposure on the
transportation network and a corresponding increase in the number of severe and fatal crashes that
could occur relative to Existing, which exceeds the threshold of significance identified for this EIS.

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Under Alternative 2, total VMT and VMT per capita are lower than No Action due to the land use pattern
that assigns more growth in centers and along transit corridors, which reduces trips and average trip
distances. This translates into reduced exposure on the transportation network and a potential reduction
in the number of severe and fatal crashes.

Under Alternative 3, total VMT and VMT per capita are lower than No Action, reflecting the land use
pattern of Alternative 3 that assigns more growth in centers and along transit corridors, which reduces
trips and average trip distances. Compared to No Action, the corresponding reduction in VMT and VMT
per capita translates into reduced exposure on the transportation network and a potential reduction in
the number of severe and fatal crashes.

Vehicle Network, Transit, Freight
Compared to Existing (2024), 10 intersections are expected to remain at the same LOS, and 12 are
expected to decline by one or more LOS grade. Despite the increase in delay, 16 of 22 intersections are
still expected to meet their LOS standard under No Action. See Exhibit 1.4-8.

Compared to No Action, 17 of 22 study intersections are expected to meet their applicable LOS standard
with Alternative 2 or Alternative 3, an improvement over No Action, where 16 of 22 met the standard. The
SR 291/W Francis Avenue and N Alberta Street intersection is expected to operate with lower delay such
that it would meet its LOS D standard (No Action LOS E), and SR 290/E Trent Avenue and N Hamilton
Street would operate at LOS E rather than LOS F (still failing to meet the standard of LOS D).

Four of the remaining locations that would fail to meet the LOS standard under Alternative 2 are S Hatch
Road and E 57th Avenue, US 2/N Division Street and W Wellesley Avenue, US 2/N Division Street and W
Francis Avenue, and US 2/W Sunset Highway and Flint Road. At US 2/W Sunset Highway and Flint Road,
LOS would remain at F and delay would rise from 145 seconds (No Action) to 148 seconds (Alternative 2),
which is a 3 second increase and therefore below the Action alternative threshold of 5 seconds. At S
Hatch Road and E 57th Avenue, US 2/N Division Street and W Wellesley Avenue, and US 2/N Division
Street and W Francis Avenue, delay is incrementally reduced relative to No Action and LOS categories are
unchanged.

The remaining locations failing to meet standard under Alternative 3 are S Hatch Road and E 57th
Avenue, US 2/N Division Street and W Wellesley Avenue, US 2/N Division Street and W Francis Avenue,
and US 2/W Sunset Highway and Flint Road. At these intersections, delay is incrementally improved
compared to the No Action alternative.

Exhibit 1.4-8. Spokane Intersection LOS – All Alternatives
Study Intersection LOS Standard 2046 Alt 1 2046 Alt 2 LOS 2046 Alt 3 LOS
(No Action)
LOS

S Hatch Rd and E 57th Ave (One-way stop E F F F
control)
S SE Blvd and E 29th Ave E D D D

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Study Intersection LOS Standard 2046 Alt 1 2046 Alt 2 LOS 2046 Alt 3 LOS
(No Action)
LOS
S Grand Blvd and E 29th Ave E C C C
N Havana St and E Sprague Ave E E D D
N Napa St and E Sprague Ave E C C C
SR 290/E Trent Ave and N Hamilton St D F E E
US 2/S Division St and E Sprague Ave* F C C C
US 2/N Ruby St and E Indiana Ave* D D D D
US 2/N Division St and W Buckeye Ave/E D C C C
North Foothills Dr
US 2/N Division St and Wellesley Ave D F F F
US 2/N Division St and W Francis Ave* D E E E
US 2/N Newport Hwy and E Holland Ave D D D D
W 3rd Ave and S Monroe St F B B B
N Maple St and W Boone Ave E C C C
E Mission Ave and N Hamilton St E D D E
N Market St and E Euclid Ave E D D D
N T J Meenach Dr and W Northwest Blvd* E E E D
N Ash St and W Wellesley Ave E C C C
E Wellesley Ave and N Haven St* E E E E
N Market St and E Francis Ave E D D D
SR 291/W Francis Ave and N Alberta St D E D D
US 2/W Sunset Hwy and Flint Rd D F F F

Notes: *Analyzed with HCM 2000; BOLD indicates LOS fails to meet standard
Sources: City of Spokane, WSDOT, Fehr & Peers, 2025

For the No Action alternative, the following intersections fail to meet LOS standards and could have an a
significant impact to freight corridors and fixed transit routes: US 2/Sunset Highway and Flint Road (LOS
F), US 2/Division Street and Wellesley Avenue (LOS F), US 2/Division Street and Francis Avenue (LOS E),
and SR 291/W Francis Avenue and N Alberta Street (LOS E).

For Alternative 2, no significant intersection impacts are identified compared to the No Action alternative,
so relative transit and freight performance would be maintained.

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Under Alternative 3, no significant intersection impacts are identified relative to the No Action alternative;
all intersections that exceed LOS thresholds would either maintain or improve LOS and delay relative to
No Action.

What are some solutions or mitigation for impacts?
Several projects and policies are included in the analysis and serve as baseline mitigation because they
improve traffic operations, safety, and multimodal access for all alternatives.
 US 2/Division Street and NSC
 City Line and STA High-Performance Transit (HPT)
 Pedestrian and Bike Master Plans
 Vision Zero and Complete Streets

Spokane’s existing regulatory framework ensures that transportation improvements keep pace with
growth and safety needs.
 Concurrency and impact fees link development to capacity projects. When thresholds are exceeded,
intersection and corridor upgrades are advanced as part of the City’s capital program.
 Frontage improvement requirements ensure that adjoining sidewalks, curb ramps, crossings, and
bike elements are implemented to current standards as sites redevelop.
 The City also maintains partnerships with WSDOT and STA. With WSDOT, the focus is on coordination
between projects, such as the NSC, and traffic operations.
 With STA, coordination centers on transit projects, such as Division Street BRT and future HPT
corridors, to ensure accessibility for future ridership demand.

A range of programmatic strategies could be implemented to reduce the impact of the growth
alternatives evaluated within this EIS:
 Transportation Demand Strategies (TDM)
 TSMO and Signal Timing
 Agency Partnerships
Working closely with WSDOT, Spokane Transit Authority (STA), Spokane County, and the Spokane
Regional Transportation Council (SRTC), some additional programmatic efforts could include:
 Implementing the Commute Trip Reduction (CTR) program, including CTR Four-Year Plan Update
(2025–2029) providing employers, residents, and students with a mix of education, incentives, and
resources to facilitate mode shift.
 Transportation Systems Management & Operations (TSMO) is a programmatic strategy that improves
reliability with intelligent transportation systems (ITS) and operational refinements rather than major
construction. Core tools include periodic signal retiming and coordination, refined phase/split/offset
plans, protected–permissive turn phasing and right-turn overlaps, leading pedestrian intervals and
updated pedestrian clearance, upgraded detection and, where appropriate, transit signal priority and
queue jumps.
 For the intersection of SR 290/E Trent Avenue and N Hamilton Street, the South Logan Transit-
Oriented Development (TOD) Plan identifies signal tools such as signal phase adjustments and

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right-turn overlaps to maintain operations as the area develops. This EIS is consistent with that
approach, and the same signal timing adjustments can be implemented and adjusted as
volumes grow.
 Complementary TSMO strategies including wayfinding and driver information to parallel routes like
the adjacent Martin Luther King Jr Way corridor can help redistribute peak traffic and avoid
oversaturation of the intersection. Together, these programmatic measures paired with ongoing
monitoring and retiming can maintain operations as land-use activation occurs.
 Partnering with the County and other regional agencies on a unified TDM program leverages
resources to provide a robust program with opportunities for targeted programs within the City.

With mitigation, what is the ultimate outcome?
Relative to No Action, the action alternatives maintain or incrementally improve mode share and have
lower VMT per capita, which translates into slight improvements or no change in transit, freight, and
safety performance. The action alternatives would not cause any additional intersections to fall below
standards, and for intersections that already fall below the LOS standard under No Action, the action
alternatives would add less than 5 seconds of average control delay relative to No Action. In addition, the
Action alternatives would maintain all evaluated state facilities below a v/c ratio of 1.0 and would not
degrade pedestrian or bicycle operations at the citywide scale. Therefore, applying the thresholds of
significance, neither action alternative is expected to result in a significant adverse transportation impact.

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1.4.8 Public Services

Cart Tagging, Recycling, City of Spokane, Undated.

How did we analyze Public Services?
The EIS team reviewed current conditions for police, fire and emergency medical services (EMS), schools,
parks, libraries, and solid waste. The team also analyzed environmental justice implications related to
EMS and parks and health.

Thresholds of significance used in this analysis include:
 Police/Fire/EMS – Increased demand for police or fire and emergency that cannot be accommodated
through regular planning and staffing processes.
 Schools – Increased public school enrollment and demand on capital facilities, and broadband that
cannot be addressed through regular school planning processes.
 Parks – Decreased park level of service (LOS), as defined in the Spokane Parks Master Plan (acres of
developed park land per 1,000 people, and percent of households that can reach a public park or
school ground in 10-minute walk)
 Libraries – Recommended square feet per capita LOS not met, as defined in the City of Spokane
Capital Facilities Plan

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 Solid Waste – Collections per household per month that would result in major investments exceeding
what is already planned.
 Environmental Justice
 Growth in areas with existing health disparities would result in increased demand on emergency
medical services and impact response times.
 Growth in areas with high social vulnerability would result in greater pressure on existing parks
and recreation services.

What impacts did we identify?
There is a similar citywide range of population expected under all alternatives, and there will be a greater
demand for police, fire/emergency medical services, schools, parks, libraries, and solid waste under all
alternatives. This includes a need for more police officers, more fire and EMS staff, more school capacity,
more parks, more library square footage, and more solid waste collection positions. All alternatives also
plan for growth in areas with existing health and social disparities. This may have impacts on public
services by creating more demand for emergency services and parks in certain areas of Spokane. All
three alternatives place between 31 and 34% of growth in areas with a high percentage of self-reported
poor physical health, which may increase demand for emergency services where there is already higher
demand – Alternative 1 places 31% of growth in places where people report poorer physical health and
Alternative 3 the most at 34%. All alternatives also place between 23 and 27% of growth in areas with
high social vulnerability, with Alternative 1 at 23% and Alternative 3 at 27%.

What is different between the alternatives?
All alternatives are expected to have impacts to public services but will affect different parts of the city
differently based on where growth is distributed.

General Public Services
 Alternative 1 would increase demand in the Center City and in existing centers and corridors and
particularly in less developed areas of the city (such as Northwest and South).
 Alternatives 2 and 3 would reinforce growth in already developed areas with Alternative 2 mostly
focused on frequent transit corridors and Alternative 3 in the Center City and Regional Hubs and
selected transit corridors though more growth is planned in the South as well. These areas would
therefore see greater demand for public services.

Schools
 Under Alternatives 2 and 3, Spokane School District is expected to add over 500 more new students
than under Alternative 1. In contrast, Alternative 1 would place more growth in the Mead School
District, resulting in about 600 more students than Alternatives 2 and 3.

What are some solutions or mitigation for impacts?
 The adopted Comprehensive Plan and Capital Facilities Plan include policies that support planning for
levels of service, operations, maintenance, funding, and capital projects for public services.

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 The adopted Parks and Natural Lands Master Plan includes levels of service and policies to support
park development to meet current and future City needs.
 An increase to local sales and use tax to support a Public Safety Tax for criminal justice and fire
protection became effective April 1, 2025.
 Local plans for emergency management, fire department strategy, and police department strategy
also support service improvement.
 Alternatives 2 and 3 include a new Climate Element, which includes goals and policies to support
climate resiliency of City functions, including emergency services, like police, fire, and EMS, and parks.
 Alternatives 2 and 3 include a new Spokane Capital Facilities Plan, which updates the adopted plan to
address city services (e.g., police, fire, parks, solid waste) align with other providers’ plans (e.g.,
schools) and current population numbers.
 Impact fees for schools, parks, or fire could support increased staffing and capacity to address
ongoing growth, if other funding streams are unable to match needs.
 The City could investigate opportunities for increased parks access such as a fee-in-lieu program or
park land dedications in key locations.
 Partnerships could support growing education and park needs.

With mitigation, what is the ultimate outcome?
No significant unavoidable adverse impacts are expected. Impacts to police, fire/EMS, schools, parks, and
solid waste, including environmental justice-related impacts, can be managed through regular planning,
staffing processes, and mitigation measures.

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1.4.9 Utilities

Avista Building, Maren Murphy, City of Spokane, 2018.

How did we analyze Utilities?
The EIS team reviewed Spokane’s power, water, wastewater, and stormwater systems, including how
services are provided, the infrastructure involved, utility usage data, and plans to address future growth.

Thresholds of significance used in this analysis include:
 Impacts would require major unplanned capital improvements within Avista’s power service network.
 Impacts would require major unplanned capital improvements within the City’s potable water system.
 Impacts would require major unplanned capital improvements within the City’s sewer system.
 Impacts would require major unplanned capital improvements to prevent flooding at frequencies and
durations beyond design expectations.

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What impacts did we identify?
Each alternative will see growth throughout the study area which will require planning and adjustment of
capital improvement projects to address changes in utility demands. Special consideration should be
given to power substations, power generators, wells, pump stations (water, sewer, and stormwater),
reservoirs, water reclamation facilities, sewer siphons, combined sewer overflows (CSOs), and
stormwater infiltration facilities.

What is different between the alternatives?
All alternatives are expected to have impacts to utilities but will affect different parts of the city differently
based on where growth is distributed.

Energy
 Alternative 1 is consistent with Avista’s energy needs forecasting as the utility has a plan to address
growth along the current trajectory.
 Alternative 2 would concentrate much of the growth around transit routes and increase mixed-use
and multi-unit growth throughout the city. From a power distribution standpoint, if there are more
concentrated users, this should increase the efficiency of the power network and reduce total usage.
This may result in the need to upgrade existing infrastructure to address growth in the areas
surrounding the transit routes.
 Similarly, concentrated growth under Alternative 3 in the downtown area and greater mixed-use and
multi-unit growth throughout the city would increase the efficiency of the power network and reduce
total usage. This higher concentration in these central areas may require additional generation or
transmission capacity.

Water
 Alternative 1 has the largest growth in single-unit housing, which typically creates larger water usage
peaks for irrigation in the irrigable months (April through October). Even so, the City’s water system
would be able to serve that projected growth.
 Concentrating growth along corridors under Alternative 2 would be a net benefit to a water system,
but along some corridors (e.g., Wellesley Ave, Francis Ave) the City may need to upgrade existing
infrastructure or construct new infrastructure. Alternative 2 increases the mixed-use and housing
density along Northwest Blvd, Francis Ave, and Wellesley Ave, which could increase the need for
production and storage in the Low and North Hill pressure zone.
 Alternative 3 concentrates growth in central areas of the city, which is a net benefit to a water system,
but concentrated growth may require expansion of transmission, production, and storage in the Low,
North Hill, Intermediate, High, and Top Pressure zones.

Sewer
 The difference in sewer usage between single unit and multi-unit connection depends on the density
of the development; more dense clusters of single unit and multi-unit developments will see larger

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flows. While there will be an increase in sewer demand, the City has a plan to address needs as the
system expands in Alternative 1 since it aligns with existing planning.
 With growth in Alternative 2 increasing along the Northwest Blvd, Francis Ave, and Wellesley Ave
corridors, as well as in the West Plains, this could result in the need to expand capacity at the Francis,
Cannon, and Clarke Ave pump stations as well as the Latah Creek Siphon.
 With growth in Alternative 3 increasing downtown, as well as in the West Plains, this could require
improvements to the Post Street Bridge Trunk Line and Clarke Ave pump station, as well as the Latah
Creek Siphon.

Stormwater
 There will be an increase in stormwater flows, but the City has a plan to address needs as the system
expands in Alternative 1 since it aligns with existing planning.
 Alternative 2 converts much of the growth into mixed-use and multi-unit developments which could
reduce the stormwater generated overall.
 Alternative 3 concentrates most of the growth in the downtown area where there is already a lot of
development. Since redevelopment is unlikely to increase stormwater runoff, other than maintaining
the existing stormwater mitigation standards, no further action is likely needed.

What are some solutions or mitigation for impacts?
 City programs and policies reduce water use through grants for low water use landscaping,
requirements for onsite stormwater treatment, disposal for new developments, and targeting
infrastructure improvements in historically underserved areas.
 The City plans to update its level of service standards for water service to better align with the
Washington Department of Health’s (DOH) standards.
 The City will update utility plans following the Periodic Update. City codes regulating construction and
future utility investments will continue to ensure new development addresses any service or capacity
constraints.
 The City and Avista regularly plan and adapt to changing growth patterns and are currently engaged
in efforts to improve the water system and address long-term demand and climate change effects on
water supplies and the aquifer, address wastewater and drainage system capacity, meet electrical
demand, and increase the resiliency of their utility systems to growth and impacts of climate change.
 Federal, state, and local codes support the provision of safe, reliable utilities.
 The City could consider additional measures such as expanding local energy resources, investing in
infrastructure to improve energy efficiency, upgrading stormwater infrastructure, minimizing runoff,
protecting critical aquifer recharge areas, and implementing community-based water use efficiency.

With mitigation, what is the ultimate outcome?
None of the alternatives are anticipated to create significant unavoidable adverse impacts to the ability of
the City or Avista to deliver utility services to the population of Spokane

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2 Proposal and Alternatives

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2.1 Introduction

2.1.1 Overview of the Proposal
The City of Spokane (Spokane) is preparing a periodic
What you will find in this chapter
update to its Comprehensive Plan for the period 2026
to 2046. The Periodic Update addresses new growth Chapter 2 Proposal and Alternatives:
targets for population and housing and will meet
 Identifies Comprehensive Plan Periodic
amendments to the Growth Management Act (GMA)
Update proposals
since that last periodic update in 2017. Every chapter
of the current Comprehensive Plan, except for the  Describes City objectives to achieve its
Shorelines Chapter which will be updated in vision and state laws
accordance with State regulations in 2031, will be  Includes alternative ways to meet
amended including the vision, values, goals, and objectives
policies. Major changes include addressing GMA  Shares public outreach results and
requirements for housing affordability and anti- activities planned with the EIS
displacement measures, updating multimodal levels  Describes the SEPA process before,
of service and reducing vehicle trips, and planning for during, and after the Draft EIS
climate resilience and greenhouse gas reductions.
 Summarizes benefits and
The Land Use Plan Map, a component of the Land disadvantages of delaying proposals
Use Chapter that outlines how different areas of the
city are designated for various uses, is proposed for
amendment to simplify its implementation and to respond to growth targets, community needs,
transportation investments, and environmental conditions. Zoning and development regulations are
also proposed to be amended to help ensure the City meets its housing affordability targets, and to
promote transit-oriented development along major transit facilities. The City is also reviewing its
critical areas regulations to address State rules and guidance.

Additionally, the City is considering tools to streamline environmental review under the State
Environmental Policy Act (SEPA), such as housing and infill development categorical exemptions (RCW
43.21c.229) and raising minor new construction thresholds (WAC 197-11-800.

2.1.2 Alternatives
Consistent with the State Environmental Policy Act (SEPA), this Draft Environmental Impact Statement
(EIS) identifies and analyzes a range of alternatives that describe different growth strategies to help
the City prepare the Periodic Update. These alternatives include a “no action alternative” and two
“action alternatives”:
 Alternative 1, Stay the Course: This SEPA required Alternative (No Action Alternative) is the
continuation of the current Comprehensive Plan and associated zoning and regulations.

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 Under this Alternative, the Comprehensive Plan and development regulations would not be
updated. However, growth would still occur under this alternative under current rules—it
does not assume zero growth over time.
 Alternative 1 has capacity to meet total housing and population targets but would not provide
sufficient capacity for housing at income levels 0-80% of the area median income (AMI as
determined by the Federal Housing and Urban Development Department for Spokane
County).
 This Alternative assumes jobs would grow consistent with regional Spokane Regional
Transportation Council (SRTC) projections. See Exhibit 2.1-1 below.
 Alternative 2, Distributed and Balanced: Alternative 2 adds greater housing and job intensity
along frequent transit routes and prioritizes a jobs/housing balance.
 Alternative 2 applies recommendations from the adopted Centers and Corridors Study (2024)
to better consider market conditions and zoning best practices, including the use of mixed-
use land use and/or zoning designations.
 Alternative 2 encourages neighborhood/small scale retail.
 Alternative 2 provides sufficient capacity to meet housing and population targets, including
creating greater capacity of housing types that are affordable to all income levels.
 To evaluate the phasing of infrastructure needs, Alternative 2 would have a job growth level
similar to State Employment Security Department (ESD) trends. See Exhibit 2.1-1 below.
 This Alternative simplifies the land use plan so that there are fewer land use designations,
which are then implemented by multiple zones.
 Alternative 2 facilitates growth through an infill exemption under SEPA (RCW 43.21c.229),
where the EIS provides upfront evaluation of residential and mixed-use growth along frequent
transit routes, and documents plans or development regulations that provide mitigation
measures. The City may also raise SEPA thresholds citywide (WAC 197-11-800) or in targeted
areas in the city.
 Alternative 2 includes anticipated climate resilience and greenhouse gas reduction goals and
policies per HB 1181. It would also review and update critical areas regulations.
 Alternative 3, Center City and Regional Hubs: Alternative 3 adds greater housing and job
intensity in the City of Spokane’s downtown vicinity called the “Center City” and in employment
centers in Southwest and Northeast Spokane.
 Alternative 3 focuses housing growth in regional hubs, particularly Center City and selected
corridors.
 Alternative 3 concentrates industrial jobs in West Plains and Northeast Spokane, and
additional education/health jobs in the City Center and University areas.
 City investments prioritize certain centers and major corridors to maximize impact of
designation. Designations in other areas are removed or modified where appropriate, while
still considering livability/streetscape improvements.
 Alternative 3 meets housing targets at all income levels.

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 Alternative 3 establishes the highest jobs allocation that focuses investments in areas with
existing/planned transportation infrastructure (Downtown transit and street network, airport,
rail corridors, North Spokane Corridor or NSC). See Exhibit 2.1-1 below.
 Like Alternative 2, Alternative 3 simplifies the land use plan so that there are fewer land use
designations, which are then implemented by multiple zones.
 Like Alternative 2, Alternative 3 facilitates growth through an infill exemption (RCW
43.21c.229) along frequent transit routes, particularly bus rapid transit. The City may also
raise SEPA thresholds citywide (WAC 197-11-800) or in targeted areas in the city.
 Alternative 3 includes anticipated climate resilience and greenhouse gas reduction goals and
policies per HB 1181. It also reviews and updates critical areas regulations.

Exhibit 2.1-1. Employment Growth and Alternatives

Spokane County and its cities do not formally allocate job targets. The City of Spokane’s EIS Alternatives can
evaluate a range of potential job growth to help the City consider its role as a regional job center, the
balance of housing and jobs for its community, and ensure it plans appropriately for infrastructure avoiding
over-investment or under-investment. All of the alternatives incorporate job growth projections higher than
the 20-year historic trend (2002-2022). However, Alternative 2 Distributed and Balanced reviews job growth
similar to State Employment Security Department (ESD) projections (2022-2037) and with a jobs/housing
balance similar to the current balance. Alternative 2 employment projections, while greater than trend, are
lower than the Spokane Regional Transportation Council (SRTC) projections incorporated into Alternative 1
Stay the Course. Alternative 3 Center City and Regional Hubs focuses job growth in major centers and hubs
like the Center City and the West Plains and Hillyard areas and tests job growth moderately higher than
Alternative 1. Using different job outlooks can help the City consider the timing of infrastructure needs
based on varying future predictions and does not necessarily indicate that one alternative would remove
potential job opportunities while another would add. While job assumptions vary, both Alternative 2 and 3
focus on ways to increase start-up and business expansions through focused investments in public
infrastructure.

2.1.3 Study Area
This EIS primarily focuses on the Spokane city limits. The city study areas in Exhibit 2.1-2 are
referenced in the EIS:
 Northwest Spokane
 Northeast Spokane
 South Spokane
 West Plains
 Center City, overlapping several study areas, including Downtown Spokane
 Division corridor, straddling Northwest and Northeast Spokane

Within these broad subareas the EIS cites Neighborhood Council boundaries. See Exhibit 2.1-3.

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Exhibit 2.1-2. Spokane Study Areas

Sources: City of Spokane, BERK, 2025.

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Exhibit 2.1-3. City of Spokane Neighborhoods

Note: Peaceful Valley, Grandview/Thorpe, Browne’s Addition, and Whitman neighborhoods are shown but too small at
this scale to label.
Sources: City of Spokane, 2024; BERK 2024.

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Secondarily, the EIS addresses abutting unincorporated urban growth areas (UGAs) and currently
adopted utility service areas, for example, considering land use compatibility and growth trends. See
Exhibit 2.1-4.

Exhibit 2.1-4. Existing Water Retail Service Areas

Source: City of Spokane, 2025.

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2.1.4 Objectives of the Proposal
Objectives are required by SEPA to identify the purpose and need of the proposals and to compare
alternatives according to WAC 197-11-440 and -442. Objectives are particularly important when
comparing long-range plans like the City of Spokane Comprehensive Plan Periodic Update. This EIS
compares alternatives for their ability to meet these objectives:
 Meet Periodic Update Requirements: Comply with Comprehensive Plan periodic review
requirements to meet state laws including recent changes to the GMA regarding providing
capacity for more housing types and affordability levels, increasing resiliency to climate impacts,
evaluating tree canopy coverage, increasing opportunities for active transportation, reducing
vehicle miles traveled and greenhouse gas emissions, addressing needs of overburdened
communities, increasing green infrastructure, planning for jobs and economic development, and
more.
 Accommodate Growth: Demonstrate population, transportation, and housing capacity to
accommodate growth targets through 2046 based on State projections and County allocations in
consultation with the City and ensure City utilities and services are expected to have sufficient
capacity to serve that growth.
 Clarify the Plan: Update policies that are inconsistent, outdated, duplicative, or unclear.
 Simplify the Plan and Codes: Update and simplify future land use map categories and zoning
districts and reflect any new designations such as within centers and corridors.
 Protect Critical Areas: Update critical area regulation updates that respond to best available
science.
 Fast-Track Desired Growth: Facilitate desired growth in priority locations through permit
streamlining, such as through SEPA infill exemptions or raising SEPA thresholds.

A vision statement, goals, or values in a plan can serve as objectives. The City’s proposed draft vision
statement for the Periodic Update is also considered an objective:
Spokane aims to foster a vibrant, resilient, and inclusive city by supporting economic growth,
environmental stewardship, and the diverse needs of the whole community. The City is dedicated
to ensuring access to attainable housing, safe streets, and thriving neighborhoods while inspiring
innovation, cultural vitality, and connection for all Spokane residents.

This vision incorporates PlanSpokane 2046 themes of Resilient, Connected, and Livable, as well as
public engagement themes of Nature, Community, Livability, and Innovation. See Section 2.2.3 for
additional context about public engagement themes.

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2.2 Planning Context

2.2.1 Growth Management Act

State Periodic Update Requirements
The GMA requires that most cities and counties in the state with larger and growing populations – like
Spokane County, City of Spokane, and surrounding cities – prepare a comprehensive plan and
development regulations meeting state goals such as focusing growth in urban areas, providing
opportunities for housing and economic development, protecting critical areas, investing in
infrastructure and transportation, instituting fair and predictable permit processes, and encouraging
community participation.

A comprehensive plan provides guidance for all aspects of the city’s growth and development over a
long period, typically 20 years. The plan is made up of a vision, goals, policies, and implementation
strategies that state how the city should grow physically, socially, and economically. The City of
Spokane’s first GMA compliant Comprehensive Plan was adopted in 2001 and was last updated, aside
from minor annual amendments, in 2017. It is the product of many people, including hundreds of
community members, the Spokane Plan Commission, City Council, and Mayor.

Spokane is preparing a periodic update to the City’s Comprehensive Plan for a new planning period of
2026 to 2046. Called PlanSpokane 2046, this is the most significant update since the plan was originally
written in 2001. Distinct from small annual amendments made along the way, a “periodic update” is a
full review of a comprehensive plan to make sure it complies with any legislative changes to state
law. Each chapter of the plan, excluding the Shorelines Chapter, will be updated to address new
growth targets for population and jobs and to meet changes to the GMA since 2017, including
considerations around Climate Planning and Planning for Housing at all income levels made by HB
1220. In Section 2.2.3 Growth Targets and Alternatives, the action alternatives 2 and 3 further the
City’s compliance with HB 1220 requirements to meet affordable housing targets, remove barriers in
plans and codes, and implement measures to reduce racially disparate impacts.

The GMA and HB 1110 require inclusion of middle housing in single family areas, and the City has
largely implemented those requirements following its Housing Action Plan and the following Building
Opportunity for Housing code project. All of the EIS alternatives studied incorporate middle housing.

Transit-Oriented Development
Placing housing, retail, and services near frequent transit routes together with access to comfortable
sidewalk environments provides more choices for living environments in Spokane and ways to more
easily reach employment, recreation, and other destinations without having to use a car. The City Line
is an existing bus rapid transit line that serves the Center City (Downtown, University, South Logan)
and parts of Northeast Spokane (Chief Garry Park).

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Goals for transit-oriented development (TOD) are woven into the current Comprehensive Plan,
subarea plans, and zoning code, and seek to:
 Improve quality and safety of streetscapes, building frontages, and public spaces next to transit
stations
 Improve connectivity of walking, cycling, and rolling to transit stations
 Ensure that people of all income levels have access to development that offers a mix of
destinations and services
 Ensure affordable housing options are near transit stations for people of all income levels

The City supports TOD along the City Line through the Spokane Downtown Plan, as well as the South
Logan TOD project. A future bus rapid transit line is planned along Division Street. An ongoing
initiative is the Division Street TOD Project, which is a grant-funded pilot program. The City of Spokane,
Spokane County, and the Spokane Transit Authority (STA) are working together on the pilot program. It
builds on the DivisionConnects study by the Spokane Regional Transportation Council (SRTC) and STA,
aligning land use, zoning, and infrastructure with the new transit investments.

Alternative 1 continues current plans and initiatives for TOD. Alternatives 2 and 3 in this EIS consider
the effect of increased transit-oriented development near bus rapid transit infrastructure based on
recent legislation. Under HB 1491(2025), a city may not enact or enforce any development regulation
within a station area that would prohibit the siting of multi-unit residential housing on lots where any
other residential use is permissible. At this time the only BRT line that meets this criteria is the City
Line (STA Route 1). In the future, other areas of the city may fall under this bill. The bill requires a
minimum floor area ratio (FAR) of residential and mixed-use development in a station area except for
areas with shorelines or critical areas or where there is a designated landmark or historic district. The
requirement is 2.5 FAR within one-quarter mile of a bus rapid transit stop, or 3.0 FAR if exempting up
to 25% of bus station areas. Additional FAR must be provided for housing made of mass timber. A
minimum 10% of units must be affordable for at least 50 years and any buildings providing all
affordable units are allowed another 1.5 FAR. An extension to delay implementation is allowed for up
to five years if the areas are at high risk for displacement, as certified by the Washington Department
of Commerce. The requirements must be met during the City’s Periodic Update.

2.2.2 Comprehensive and Subarea Planning
The action alternatives address recent and ongoing subarea planning efforts and transportation
investments. See Exhibit 2.2-1.

Center City, in the University District, South Logan TOD Plan: The South Logan Transit Oriented
Development (TOD) Plan and Final Environmental Impact Statement (EIS) were adopted on January 29,
2023, with land use and zoning amendments and development regulation updates consistent with the
Plan adopted later that year. Since the plan was approved it is part of the current Comprehensive Plan,
and the growth associated with this plan is considered part of the Alternative 1 land capacity.
However, this growth is not included in the SRTC land use and transportation models that have a base
year of 2022. The plan and the growth associated with it are part of the action alternatives.

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Northeast Spokane, Hillyard Subarea Plan: Addressing areas north of East Wellesley Avenue and
along the North Spokane Corridor (NSC), the Hillyard Subarea Plan provides revitalization and funding
strategies to address the prolonged housing needs and infrastructure deficiencies, improve the quality
of life, increase economic opportunity, and place brownfields and other underutilized properties back
into productive use. The Subarea Plan was recognized by resolution in Fall 2025.

South Spokane, East Central, 5th Avenue Community Plan: The 5th Avenue community is the
historic center and cultural hub of the Black community in Spokane and is also home to a growing
diversity of residents, including Latino and recent immigrant communities. The southern extent of the
North Spokane Corridor (NSC) will be built through this neighborhood. The 5th Avenue Community
Plan will establish a community-led framework of goals and policies for future land use, economic
growth, connectivity, and quality of life improvements for the 5th Avenue community in the East
Central neighborhood. The community plan builds on the foundation and vision established in the 5th
Avenue Initiative Community Strategy, adopted in 2021 as the culmination of a multi-year process of
community engagement and work by community leaders, residents, businesses, and organizations.
The initiative fosters neighborhood identity and enhances quality of life for residents and businesses
along the 5th Avenue corridor. The community plan is ongoing as of 2025.

South Spokane, Latah Strategy: The City is funding a study of Latah Valley's traffic and growth to
identify transportation and other infrastructure to invest in. Latah Valley/Grandview Thorpe
neighborhoods are experiencing a high volume of preliminary plats that focus vested residential
growth in this area, resulting in near-term infrastructure investment needs. This study is ongoing and
part of the PlanSpokane 2046 Periodic Update.

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Exhibit 2.2-1. Recent and Ongoing Subarea Planning and Transportation Investments

Sources: City of Spokane, BERK, 2025.

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2.2.3 Growth Targets and Alternatives

Housing Element Requirements
The GMA was amended to strengthen planning for housing that meets the needs of all households,
provides a variety of housing types, and removes barriers to adequate housing, particularly by
undoing racially disparate impacts caused by past plans or codes. Key components of a Housing
Element include:
 Evaluation of Land Capacity to Meet Housing Targets
 Identifying Racially Disparate Impacts and Measures to Undo Impacts
 Evaluating Displacement Risk and Adding Anti-Displacement Measures
 Making Adequate Provisions for Housing Needs and Removal of Barriers

Land Capacity and Housing Targets
The EIS alternatives are evaluated for their ability to achieve housing growth targets that are a
foundation for the Comprehensive Plan Land Use and Housing Elements. Housing targets were set
considering GMA requirements and through a consultation process between Spokane County and
cities. That process established that the City of Spokane should plan for 22,359 dwelling units between
2020 and 2046. The City will need to provide capacity to achieve housing allocations at all income
levels in its Periodic Update. See Exhibit 2.2-2.

Exhibit 2.2-2. Housing Target and Affordable Housing Capacity 2020-2046

Source: City of Spokane, 2024.

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The housing targets by income band are based on a 2020 base year.1 By categorizing the units built
since 2020 by income band, the City can understand how many additional housing units are needed.
For the purposes of the EIS, a base year of 2022 was established to match the SRTC base year of 2022.
The net growth examined in this EIS is 21,738 for the years 2022-2046. See Exhibit 2.2-3.

Exhibit 2.2-3. City of Spokane Housing Unit Capacity by Affordability – Alternative 1 Stay the
Course

Affordability Analysis 0-80% AMI 80-120% AMI 120+% AMI Total

LCA capacity* 9,654 8,036 12,475 30,165
Need (HAPT) 2020-2046** 15,347 2,588 4,424 22,359
2021-2022 Completes*** 216 116 290 621
2021-2024 completes*** 1,328 507 978 2,813
Remaining target during EIS evaluation -5,477 5,564 8,341 21,738
period 2022-2046
Remaining affordable target need -4,365 5,955 9,029 19,546
2025-2046

Notes: * LCA – Land Capacity Analysis **HAPT – Housing for All Planning Tool |
*** Completes are based on the data available in the City of Spokane’s June 2025 Report, Accommodating Affordable
Housing. (City of Spokane, June 2025) As data is improved and evaluated, there may have been more housing
completions than reported which show progress in meeting the City’s housing target.
Sources: SRTC, 2024;, (City of Spokane, June 2025); BERK 2025.

Middle housing types like townhomes, duplexes, and courtyard apartments, as well as accessory
dwelling units, are allowed in all zones that allow residential uses, including in the existing Residential
Low land use designation and R1/R2 implementing zones. These smaller housing types often support
households with incomes at 80-120% AMI incomes, defined as $72,601 to $90,720 annually as of 2025.
Typically, multi-unit housing at low-rise (up to three stories) and mid-rise scales (up to six stories)
provide housing units affordable to households with incomes at 0-80% of AMI (up to $72,600 income
annually as of 2025). Low-rise and mid-rise multi-unit dwellings are at higher densities than middle
housing densities. The action alternatives include areas of Moderate Density Housing and High Density
Housing, as well as Mixed-Uses that can provide low- and mid-rise housing at higher densities, to a
greater extent than Alternative 1. See dwelling types in Exhibit 2.2-4.

1
2020 is the target base year to align with the decennial US Census.

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Exhibit 2.2-4. Residential Typologies

Single Family with ADU Six Plex (S Grand Blvd.) Lowrise Apt (605 S Grand) Box Car, Univ. District

Low Density Housing Moderate Density High Density Housing
Housing

Sources: City of Spokane, BERK, 2025.

Racially Disparate Impacts and Potential for Displacement
The City has conducted an evaluation of whether there are disparities across racial and ethnic groups
in their access to housing per GMA (RCW 36.70A.070(2)).This involves identifying local policies and
regulations that result in racially disparate impacts, displacement, displacement risk, and exclusion in
housing, including: (i) Zoning that may have a discriminatory effect; (ii) Disinvestment; and (iii)
Infrastructure availability. The City published a report in September 2025 that found:
 There is a persistent gap in homeownership rates for Black, Indigenous, and People of Color
(BIPOC) households compared to White households.
 Exclusionary zoning enacted by the City of Spokane reinforced the impacts of redlining and racially
restrictive covenants, wherein redlined areas historically had a lower percentage of single unit
zoning in residential areas which had a segregating effect on BIPOC households and lower income
households.
 Neighborhood access, income disparities, and housing affordability vary by race, putting
homeownership farther out of reach for BIPOC households, who have limited access to
neighborhoods and higher performing schools.
 Environmental health disparities reflect systemic disparities of historic disinvestment, exasperating
disparate outcomes for overburdened communities, including higher levels of exposure to
environmental hazards and lower life expectancy.
 Patterns of historic segregation are reflected in the present-day concentration of BIPOC
households and uneven distribution of racial groups among neighborhoods within Spokane.
 Access to employment areas varies, with areas closer to downtown having better access to jobs,
suggesting there is not an exclusion to jobs proximity.
 While Spokane has grown consistently over the last decade, the growth has not been spread
equally across the city, with both areas of increasing integration and areas experiencing
displacement.

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 In Spokane, households at both ends of the income spectrum have fewer rental units available for
their income level.
 Housing patterns and policies concentrate multi-family subsidized housing primarily into Central
Spokane and Northeast Spokane, which limits access and choice for low-income households,
excluding them from large parts of the city.
 Higher displacement risk exists in Central (Center City) and Northeast Spokane, areas that have
higher proportions of BIPOC and lower income households, with higher eviction and demolition
rates and changing market factors for redevelopment. (City of Spokane, 2025)

The report finds that the City has made recent progress through land use and code changes that begin
to undo the impacts of racially disparate impacts from historic policies and practices that continue to
impact residents’ ability to access housing and opportunities today. The report outlines additional
work to implement changes for a continued and strengthened focus on housing equity and
accessibility over the next 20 years. This includes a menu of potential anti-displacement measures
such as housing preservation, density incentives, small developer technical assistance, tax increment
financing, and others.

Each alternative is evaluated in Section 3.5 Population, Employment, and Housing for how well they
provide policies or changes to the Land Use Plan and zoning in order to provide housing that meets
the needs of all incomes, address equity and disparate impacts, and incorporate anti-displacement
measures.

Adequate Provisions for Needs and Removal of Barriers
With the development of its evaluation of land capacity, affordable housing targets, and racially
disparate impacts, the City is considering changes to its development regulations to remove barriers
to the provision of housing at all income levels particularly housing at 0-80% AMI income levels. This
will be further developed with the Preferred Alternative in the Final EIS when more specific locations
for Land Use Plan Map and zoning changes and when the City develops its companion required
updates to the zoning or development code

Population, Household Sizes, and Housing Types

Population Targets
The adopted population growth target for the City between 2023 and 2046 is 23,357 additional people,
a growth rate of 0.4% per year. (Steering Committee of Elected Officials, 2024) If adjusted to match the
base year of the SRTC model (2022) used for the purposes of this EIS, the net population change for
2022-2046 is 25,157. When considering the most recent Washington State Office of Financial
Management (OFM) 2025 population estimate, which estimates the growth the City has seen since
2022, the remaining population growth for 2025-2046 is 21,357.

The population target assumes a rate of growth substantially slower than the city has experienced in
recent years (0.9% annually between 2015-2025). The population target is also lower than could be

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accommodated by the number of new housing units allocated by the county. Therefore, for a more
conservative analysis of public service needs, this EIS considers a population growth range of
25,157 to 50,650 based on the exact population growth target at the low end (2022-46) and
multiplying the current household size of 2.33 by the 21,738 housing target (2022-46) at the upper
end.

Household Sizes and Types
Approximately two thirds of Spokane’s occupied housing stock is single unit and one third is multi-unit.
The existing multi-unit housing is typically 5+ housing units or greater per building, and less frequently
duplexes, triplexes, and fourplexes. Middle housing types like duplexes, multi-plexes, and townhomes
are part of “multi-unit” based on the total number of units. Household sizes vary by dwelling type, with
higher persons per household in single unit detached dwellings and lower persons per household in
attached single-unit and multi-unit dwellings. See Exhibit 2.2-5.

Exhibit 2.2-5. Persons per Household
Unit Type Housing Units (2022) Persons Per
Household (2022)
Occupied Housing Units, All Types 95,604 2.33
Occupied Frame Housing* 94,053 2.34
Single Family (Single Unit) Detached 62,651 (67%) 2.64
Multifamily (Multi-unit) ** 31,402 (33%) 1.74
Duplex 4,109 (4% of multi-unit) 2.30
Triplex and Fourplex 4,200 (4% of multi-unit) 2.01
Five+ Unit 23,093 (25% of multi-unit) 1.59
* Structures built on-site of wood/brick construction or modular homes.
** Single family-attached structures such as row homes, townhouses and condominiums are categorized as multi-unit
structures based on the total number of units.
Source: OFM 2024 (OFM, Undated)

Under all alternatives, a majority of the housing will remain in single unit homes, but all alternatives
help implement a greater variety of housing options. The City adopted a Housing Action Plan (2021)
and implemented middle housing standards in 2023 and 2024 as part of the Building Opportunity for
Housing program. This effort included provisions for accessory dwelling units, duplexes, triplexes,
fourplexes, and townhomes in Residential Low and Residential Increased Land Use Plan Map
designations allowing 4-10 and 10-20 units per acre respectively.

Taking this past action further, the action alternatives promote strategies to meet HB 1220
requirements to provide more housing types at all affordability levels and to reduce racially disparate
impacts. The alternatives include providing more areas of Moderate Density Housing and High Density
Housing, as well as Mixed-Use/Commercial development in the city to promote low-rise and mid-rise
housing that can meet gaps in capacity for housing types that meet 0-80% AMI. Moderate Density
Housing and High Density Housing would have typical densities of 30-45 units per acre.

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Recognizing the action alternatives would allow for more housing capacity along frequent transit
routes and major employment centers like Downtown and Hillyard, it is assumed that more multi-unit
housing at low- and mid-rise levels or greater would occur. See Exhibit 2.2-6. Action alternatives allow
more intense residential development along frequent transit routes, and mixed-uses in corridors and
in neighborhoods comprising parts of Downtown. Adding the units in these locations, over 5,400
attached multi-units could be expected. This would close the gap in the affordable housing targets
identified in Exhibit 2.2-3.

Exhibit 2.2-6. Single Unit and Multi-Unit Housing Shares by Alternative
Spokane Regional Transportation Council Transportation Analysis Zone Estimates Approximated to City Limits

NET TOTAL
PERCENTAGE

Existing Single Unit (2022) - 65,989* 0.65
Existing Multi Unit (2022) - 35,786* 0.35

Alternative 1 Single Unit 11,942 77,931 0.63
Alternative 1 Multi Unit 9,796 45,581 0.37

Alternative 2 Single Unit 6,456 72,445 0.59
Alternative 2 Multi Unit 15,282 51,068 0.41

Alternative 3 Single Unit 6,450 72,439 0.59
Alternative 3 Multi Unit 15,288 51,074 0.41

*The OFM estimates that are more precise to the city limits total 101,222 units whereas the SRTC model with
transportation analysis zones (TAZs) approximated to the city limits total 101,775 units. OFM estimates 65,876 single
units, 33,713 2+ housing units, and 1,633 mobile homes and special units (e.g., RVs, motel/hotel units permanently
occupied) in the city limits.
Sources: SRTC, 2024 Transportation Analysis Zones matched to city limits; BERK, 2025.

Jobs
The City of Spokane has about 128,000 jobs as of 2022 according to the US Census Bureau, Census on
the Map, growing from 112,000 in 2002. The greatest growth between 2002 and 2022 was in
healthcare with almost 11,500 new jobs. The current mix of jobs shows the highest share in
healthcare, services, retail, and leisure and hospitality.

GMA does not require the allocation of employment targets but cities and counties planning under
GMA must plan for employment uses. Spokane County and the cities within it do not formally allocate
job targets. The City’s EIS Alternatives can evaluate a range of potential job growth to help the City
consider its role as a regional job center, the balance of housing and jobs for its community, and

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ensuring the City plans appropriately for infrastructure (avoiding over-investment or under-
investment).

Based on several employment projections, the City could anticipate nearly 21,000 to 42,000 new jobs
by 2046. To test the phasing of infrastructure needs based on different job numbers, the alternatives
evaluate projections of 25,000 to 39,000 jobs, around a mid-range projection by the Spokane Regional
Transportation Council (SRTC).

All alternatives assume greater jobs than the 20-year trend, which would add nearly 21,000 jobs
between 2022-2046. See Exhibit 2.2-7. Alternative 1 studies the SRTC projections which would add
almost 35,000 jobs, about 14,000 more jobs than the 20-year trend. Alternatives 2 and 3 bookend this
Alternative 1 protection. Alternative 2 studies growth like ESD projections that adds almost 25,000 jobs
in the planning period. Alternative 3 studies a moderately higher projection above Alternative 1 of
nearly 39,000 jobs.

Exhibit 2.2-7. Employment Projections
20-Year Historical Alternative 2 (State Alternative 1 Alternative 3
Rate* ESD)** (SRTC)*** (Moderate-High)
Absolute Change, 20,659 24,939 34,850 38,848
2022-46
Avg Annual 898 1,084 1,515 1,689
Notes: *compound annual growth rate (CAGR) | **Employment Security Department (ESD) | *** Spokane Regional Transportation
Council (SRTC) -using the SRTC model aligning transportation analysis zones (TAZs) with city limits, the jobs assumption is 35,284.
Source: BERK, 2025.

20-Year Historical CAGR. Forecasts employment growth based on historical patterns by applying the observed
20-year compound annual growth rate of 0.65% from 2022 to 2046.
Adjusted Employment Security Department (ESD) County Projection. Forecasts employment growth based
on the forecasted county employment growth as reported by ESD and the share of countywide growth that has
occurred in Spokane in the past ten years (2012-2022).
Spokane Regional Transportation Council (SRTC) Projections. Applies the employment growth rate of 1.05%
generated by SRTC for the City of Spokane.
Moderate-High Projection. Considers a growth rate above the SRTC Projection of 1.15%.

These projections provide total job numbers. It is anticipated the City’s job mix and growth in the
future would be similar to today’s mix with continued growth in health care, services, accommodation,
and others. (Workforce Council, 2025) See Section 3.5 Population, Employment, and Housing.

All alternatives allow a range of commercial uses. Action alternatives provide more opportunities for
neighborhood-serving commercial uses that meet new policies and criteria, and additional areas of
mixed-uses. See Exhibit 2.2-8. All alternatives promote the highest employment in Downtown as well
as Hillyard and around the airport in West Hills. In the southwest and northeast, the employment is

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primarily light or heavy industrial, while Downtown employment includes offices, research and
development, medical, and education. See Exhibit 2.2-9.

Exhibit 2.2-8. Commercial Typologies

Corner Cafe (Maple Street) Shopping Center Nonna Mixed Use River Park Square

Neighborhood Commercial Mixed Use Downtown
Commercial

Exhibit 2.2-9. Industrial and Employment Typologies

West Plains Area Spokane Med. District Trent Avenue 860 E Spokane Falls

Light Industrial Employment Light Heavy Industrial Employment Heavy

2.2.4 PlanSpokane Policies and Regulation Proposals
The Comprehensive Plan includes goals and policies that then are implemented by programs and
regulations. The City has developed draft chapters of the Comprehensive Plan, adjusting the text and
policies to meet new requirements, remove outdated material, and streamline the plan.

The City is also developing regulations to meet state requirements and to simplify, clarify, and
modernize the City’s code:
 Modernize City’s Development Regulations. Conduct a review of existing land use and
development regulations in the Spokane Municipal Code (SMC) to identify outdated provisions,
legal deficiencies, inconsistencies, and gaps relative to state law and adopted plans.
 Remove Barriers to Development. Identify barriers to development including but not limited to
housing production, infill development, and adaptive reuse.

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 Improve Clarity and Usability. Develop a clear, user-friendly, enforceable unified development code
and GIS-based zoning map that support Comprehensive Plan goals related to housing, equity,
sustainability, economic vitality, and community character.
 Streamline Permitting and Service Delivery. Propose strategies to simplify and expedite
development review and permitting processes while ensuring predictable outcomes and consistent
application.
 Engage Stakeholders and the Public. Facilitate inclusive engagement with staff, elected officials,
stakeholders, and the public to build shared understanding and ownership of the code
modernization process and its outcomes.
 Support Implementation and Ongoing Improvement. Provide tools, training, visual aids, and
documentation to support implementation, improve transparency, and ensure long-term
adaptability through integration with planning, permitting, and technology systems.

Fulfilling these purposes will help the City to meet state requirements and the City of Spokane
Comprehensive Plan vision and policies.

Examples of initiatives that support the code update purposes include:
 Land Use Implementation/changes to zoning categories: The City is considering reducing the
number of land use categories in the Comprehensive Plan land use map and allowing
implementing zoning to provide the detail of types of uses and densities.
 Housing code changes to meet state law: This includes reviewing and amending land use and
housing regulations to provide housing types that meet all income levels such as sufficient capacity
in moderate and high-density housing.
 Mixed Use Zone recommendations including adjustments to centers and corridors: Based on the
Spokane Centers and Corridors Study in 2024, changes could include developing mixed-use zones
that support the City’s goals for amenity-rich, walkable, mixed-use center.
 Critical Areas Ordinance: The City is also reviewing critical areas regulations to address state rule
updates and ensure ongoing protection of the functions and values of wetlands, fish and wildlife
habitat, and critical aquifer recharge areas as well as to protect public health and safety in
frequently flooded areas and geologically hazardous areas.

Many of these Comprehensive Plan policy or code update concepts have been the subject of
community engagement, including in fall 2025. See Chapter 5 Appendix A.

Chapter 3 of this Draft EIS identifies how draft policies and code proposals associated with the action
alternatives help serve as mitigation measures (“incorporated plan features”) that reduce potential
environmental impacts.

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2.3 Public Outreach

2.3.1 Visioning and Scoping Period
WAC 197-11-210 et seq. authorizes municipalities planning under GMA to integrate the requirements
of SEPA and GMA so that environmental analysis under SEPA occurs concurrently with, and as an
integral part of, the planning and decision-making process under GMA. Both SEPA and GMA recognize
public participation and governmental agency coordination as critical to the planning process. The City
conducted an integrated visioning and scoping process from February 5, 2025 through April 7, 2025. A
written comment period and several workshops and surveys were conducted and are described
below.

Scoping: Community Engagement
Both before and during the scoping comment period, the City of Spokane Department of Planning and
Economic Development provided opportunities for the community to be engaged in the process of
identifying the future vision for Spokane’s next twenty years. See Chapter 5 Appendix A.
 Vision Board (January 9, 2025 through April 10, 2025, online)
 Community Visioning Workshop Series
 District 1: March 5, 2025, Northeast Community Center
 Community-wide: March 12, 2025, Central Library
 District 2: March 25, 2025, Liberty Park Library
 District 3: March 27, 2025, Shadle Park Library
 Community Visioning Survey (April 1 through April 18, 2025, online)
 Spring Market Visioning (April 9, 2025)

Over 300 people participated and shared ideas about the future of Spokane and how to plan Spokane
through 2046. Key themes included nature, community, innovation, and livability. These themes are
part of Proposal Objectives in Section 2.1.4 Objectives of the Proposal.

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Exhibit 2.3-1. Engagement Themes

Source: City of Spokane, 2025.

Scoping: Agency Workshop and Written Comments
In addition to the community workshops identified in the above section, the City of Spokane hosted an
Agency and Tribal workshop on February 19, 2025.

Agency comments during the 60-day scoping period were received from the Spokane Tribe of Indians,
Washington State Department of Transportation, Spokane Transit, Spokane Riverkeepers, and
University District Development Association. Requests were made to study cultural resources, critical
areas, groundwater, habitat, water conservation, transportation mitigation on state routes, transit-
oriented development, and climate resilience.

Environmental elements proposed for study in the Comprehensive Plan EIS include those listed below.
In addition to standard review, integration of agency comments and study of impacts are emphasized

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with underlines. Each alternative is evaluated with these topics. The City considers environmental
justice and climate resilience as part of studying each topic.
 Earth, water quality, and water resources
 Air quality and greenhouse gas emissions
 Plants and animals, including critical areas and habitat
 Land use patterns and urban form, including historic and cultural resources
 Relationship to plans, policies, and regulations
 Population, employment, and housing
 Transportation, including multiple modes and city and state facilities
 Public services: police, fire and emergency medical services, parks, schools, libraries, and solid
waste
 Utilities: power, water, wastewater, and stormwater

Fall 2025: Future Growth and Guiding Policies Workshops
In November 2025, the City held a community workshop series on future growth and guiding policies
for initial feedback on different ways the City of Spokane can grow, as well as the goals and policies to
guide the growth. See Chapter 5 Appendix A. Over 100 individuals attended one or more of the
workshops, providing valuable feedback to help shape the future of the City of Spokane. These in-
person workshops included discussion, mapping exercises, and feedback opportunities related to
various aspects of the Comprehensive Plan, including the new element of climate and resiliency.

In one station, community members were presented with the three growth alternatives being
evaluated in this EIS as part of the PlanSpokane 2046 Periodic Update process. After reviewing the
proposed maps and a snapshot of environmental impact evaluation comparisons between the three
alternatives, community members were asked to identify their preferred growth strategy. In general,
community members liked the interconnectedness of Alternative 2 but also saw the benefit of the
Center City focus of Alternative 3 on businesses, community safety, and more housing.

Other stations addressed land use and transit-oriented development, future transportation, climate
policies, environmental justice, and displacement and resulted in ideas for strategies and policies to
shape the next twenty years.

2.3.2 Draft Comprehensive Plan and Draft EIS Engagement
See the Fact Sheet for ways to provide written comments during a 60-day written comment period
from December 18, 2025 to February 18, 2026.

A series of public and agency workshops are planned during the Draft EIS comment period. For the
latest information on the workshop topics and times, please see the project website at:
my.spokanecity.org/planspokane/.

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2.4 Proposed Action and Alternatives

2.4.1 Alternative Comparison
The City is studying three Alternatives in the Draft EIS described below and in more detail in following
sections.
 Alternative 1 Stay the Course: This SEPA required Alternative (No Action Alternative) is the
continuation of the current Comprehensive Plan and associated zoning and regulations. This
alternative meets total housing and total population targets but does not meet affordable housing
targets for all income bands. It provides for job growth that is more robust than prior trends.
 Alternative 2 Distributed and Balanced: Alternative 2 adds greater housing and job intensity
along frequent transit routes and prioritizes a jobs/housing balance. Housing targets at all income
levels would be met. To evaluate infrastructure phasing, Alternative 2 is analyzed through a job
growth level similar to State Employment Security Department trends. Alternative 2 includes
climate planning and supporting multimodal levels of service per HB 1181 and would update
critical areas regulations.
 Alternative 3 Center City and Regional Hubs: Alternative 3 focuses both jobs and housing
growth in regional hubs and connections between them, particularly Center City (connecting
regional centers/hubs via I-90 and the North Spokane Corridor (NSC)). Alternative 3 meets housing
targets at all income levels. It uses the highest jobs projection and focuses investments in key
employment centers, also for the purposes of testing infrastructure needs. Alternative 3 includes
climate planning and supporting multimodal levels of service per HB 1181 and would update
critical areas regulations.

Each Alternative is summarized in Exhibit 2.4-1 below and described in more detail in following
sections.

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Exhibit 2.4-1. Alternatives Overview
Feature Alternative 1: Stay the Alternative 2: Alternative 3: Center
Course Distributed and City and Regional
Balanced Hubs

Plan & Code Update Current Periodic Update
Periodic Update
Areas of Focus for Growth Focuses growth in Mixed-use Transit-
Focus growth in
Downtown and Oriented Downtown and
centers and corridors. Development along
Regional Hubs and in
frequent transit
areas with greatest
corridors. investment in transit
Allow more and transportation.
neighborhood- Allow more
serving commercial
neighborhood-serving
uses. Simplified Land
commercial uses.
Use Plan. Simplified Land Use
Plan.
Housing Growth Target: 2022- 21,738 units, in addition to units already developed since 2020
2046 New units would add about 21% new housing stock to existing
dwelling units.
Housing Mix New units would New units are assumed to be 25% single unit
The city’s current proportion slightly move the and 75% multi-unit (middle housing and
of single units is about two proportion towards apartments). Adding new housing to existing
thirds of the housing stock multi-unit (greater housing, the city’s total housing stock would
(65%/35%). than 1 unit) remain majority single unit housing but add
(63%/37%). more variety (59%/41%).
Housing Affordability Targets: 0-80% area median Meets all income levels. This includes low-rise
2022-2046 income (AMI): (2-3 stories) and mid-rise (5-6 stories) housing
Insufficient in proximity to transit and inclusion of new
80-120% AMI: mixed-use zones. Meets HB 1491
Sufficient requirements for transit-oriented
120+% AMI: Sufficient development near bus rapid transit.
Population Ranges: 2022- 25,157 to 50,650
2046
Job Projections 2022-2046* 34,850 net jobs 24,939 net jobs 38,848 net jobs
Regional SRTC State ESD Projection Moderate-High
Projection 5,000 jobs above Projection
15,000 jobs above historic trend 19,000 jobs above
historic trend historic trend
* Each alternative studies a job projection from a different data source to support infrastructure planning. The
different numbers are not based on an alternative’s likelihood to produce more or fewer jobs.
Sources: SRTC, 2022; City of Spokane, 2025; BERK, 2025.

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2.4.2 Alternative 1: No Action, Stay the Course
This SEPA-required Alternative represents continuation of the current Comprehensive Plan and
associated zoning and regulations. Recently amended plans are included, such as the South Logan
Transit-Oriented Development Plan.2

Growth would continue as planned under current rules and is focused on centers and corridors, a
growth strategy originally adopted in the early 2000s. See the adopted Land Use Plan in Exhibit 2.4-2.
Higher intensity housing is found in centers and corridors and Downtown. Middle housing and single
unit dwellings are allowed in all residential areas. Employment is focused on health/services
(Downtown) and industrial jobs in areas along railroads and near Spokane International Airport. A
map showing relative growth intensity levels is shown in Exhibit 2.4-3.

Alternative 1 meets total housing growth targets but does not provide sufficient capacity for housing
at all income levels, particularly those affordable at 0-80% AMI. The distribution of housing is shown in
Exhibit 2.4-4. Job growth is consistent with regional projections by SRTC. Job growth distribution is
shown in Exhibit 2.4-5. For the distribution by Transportation Analysis Zone, please see Chapter 5
Appendix B.

Alternative 1 continues current natural environment policies and critical areas regulations. It would
not add a new Climate Element per HB 1181.

2
The SRTC model base year is 2022 whereas the subarea plan adoption was in January 2024. Thus, the
transportation assumptions for 2022 are lower than the action alternatives that implement the expected growth.

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Exhibit 2.4-2. Alternative 1 Stay the Course

Sources: City of Spokane; BERK Consulting, 2025.

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Exhibit 2.4-3. Alternative 1 – Growth Intensity

Sources: City of Spokane; BERK Consulting, 2025.

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Exhibit 2.4-4. Alternative 1 Housing Growth

Sources: City of Spokane, BERK Consulting, 2025.

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Exhibit 2.4-5. Alternative 1 Job Growth

Sources: City of Spokane, BERK Consulting, 2025.

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2.4.3 Alternative 2: Distributed and Balanced
Alternative 2 modifies centers and corridors concepts following the recommendations of the adopted
Centers and Corridors Study (City of Spokane, 2025) to better consider market conditions and zoning
best practices, primarily through the application of mixed-use designations. It would intensify mixed-
uses along transit in Downtown, Division Street, and other frequent transit routes, and would expand
existing centers in South Spokane into corridors. It adds mixed-use zoning along arterials in Northwest
and Northeast Spokane as well. See Exhibit 2.4-6.

As described above, Alternative 1 continues the current plan and code that advances middle housing
and existing centers and corridors Alternative 2 builds on Alternative 1 and provides a greater range of
housing through low- and mid-rise housing and mixed-use areas along frequent transit routes,
resulting in more corridors identified for residential and mixed uses. Alternative 2 includes planned
transit-oriented development (TOD) improvement areas, which align with recent state legislation (HB
1491). The distribution of housing is shown in Exhibit 2.4-7. Compared with Alternative 3, which
focuses more so on selected corridors and in Downtown, Alternative 2 provides more higher intensity
residential and mixed uses in narrower bands along more corridors.

Alternative 2 continues to support existing job centers, while providing for greater mixed-use
development and commercial uses along corridors with frequent transit. Recognizing community
interest in walkable areas with services, there would be new neighborhood/small scale retail nodes
according to locational criteria. The job distribution under Alternative 2 is Exhibit 2.4-8.

The City’s current jobs-housing ratio is 1.3 jobs for every 1 housing unit. Compared to Alternatives 1
and 3, Alternative 2 provides a more balanced share of housing and jobs with 21,738 housing units
and 24,939 jobs, a ratio of 1.4 for net growth (the total employment and housing shares would result
in a jobs/housing balance 1.2, similar to the current share per Section 3.5). Alternative 2 also meets
housing targets at all income levels, identifies and begins to undo racially disparate impacts in
housing, and establishes anti-displacement policies under HB 1220. Alternative 2 establishes a jobs
allocation somewhat above the 20-year trend linked to jobs/housing balance.

Alternative 2 simplifies the land use plan so that there are fewer land use designations, with each
designation implemented by multiple zones. This provides flexibility to respond to changing
community needs and market conditions and avoids unnecessary Comprehensive Plan amendments.

Alternative 2 includes anticipated climate resilience and greenhouse gas reduction goals and policies
per HB 1181and updates critical areas regulations.

Alternative 2 updates multimodal levels of service (LOS) and improves accessibility for multiple modes
of travel.

Alternative 2 would facilitate growth through infill exemptions under SEPA (RCW 43.21c.229) where the
EIS provides upfront evaluation of growth along frequent transit routes, and documents plans or
development regulations that provide mitigation measures. The City may also raise SEPA thresholds
citywide (WAC 197-11-800).

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Exhibit 2.4-6. Alternative 2 Distributed and Balanced

Note: There will be neighborhood-serving commercial opportunities that could locate in residential areas based on
criteria that are not geographically identified on the map.
Sources: City of Spokane, BERK Consulting, 2025.

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Exhibit 2.4-7. Alternative 2 Housing Growth

Sources: City of Spokane, BERK Consulting, 2025.

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Exhibit 2.4-8. Alternative 2 Job Growth

Sources: City of Spokane, BERK Consulting, 2025.

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2.4.4 Alternative 3: Center City and Regional Hubs
Alternative 3 focuses housing growth in major hubs, particularly in the Center City, and provides
additional education/health jobs in the city center and University Area. It concentrates new industrial
jobs in public development authorities in West Plains and Northeast Spokane. See Exhibit 2.4-9.

Alternative 3 balances regional travel priorities with neighborhood livability by identifying key
transportation connections between regional centers (I-90 and the North Spokane Corridor). It
improves accessibility for multiple modes of travel and new multimodal levels of service.

City investments prioritize certain centers and major corridors to maximize impact of designation.
Designations in other areas are removed or modified where appropriate, while still considering
livability/streetscape improvements. Mixed-use and higher density housing would be designated along
these prioritized corridors. Like Alternative 2, there would be new neighborhood/small scale retail
nodes according to locational criteria.

Alternative 1 continues the current plan and code with a recent emphasis on middle housing unit
types. Alternative 3 meets housing targets at all income levels and provides a greater range of housing
types such as low- and mid-rise housing that is a higher density than middle housing. Housing
distribution is shown in Exhibit 2.4-10. It focuses investments in areas with transportation
investments that improve connections between hubs (Downtown transit and street network, airport,
rail corridors, NSC), as well as along bus rapid transit lines – thus it prioritizes certain corridors for
investments whereas Alternative 2 identifies intensification along more corridors that have frequent
transit. Alternative 3 also identifies and begins to undo racially disparate impacts in housing and
establishes anti-displacement policies under HB 1220. Alternative 3 establishes the highest jobs
allocation. See Exhibit 2.4-11 for the jobs distribution under Alternative 3.

Like Alternative 2, Alternative 3 simplifies the land use plan so that there are fewer land use
designations, which are then implemented by multiple zones.

Alternative 3 includes an infill exemption (RCW 43.21c.229) along frequent transit routes, particularly
bus rapid transit, and potentially includes a planned action with upfront environmental review and
mitigation measures for jobs centers, focused on light industrial and commercial /mixed-use. The City
may also raise SEPA categorical exemption thresholds citywide (WAC 197-11-800).

Like Alternative 2, Alternative 3 includes new climate adaptation and mitigation goals and policies per
HB 1181 and updates critical areas regulations.

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Exhibit 2.4-9. Alternative 3: Center City and Regional Hubs

Note: There will be neighborhood-serving commercial opportunities that could locate in residential areas based on
criteria that are not geographically identified on the map.
Sources: City of Spokane, BERK Consulting, 2025.

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Exhibit 2.4-10. Alternative 3 Housing Growth

Sources: City of Spokane, BERK Consulting, 2025.

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Exhibit 2.4-11. Alternative 3 Job Growth

Sources: City of Spokane, BERK Consulting, 2025.

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2.4.5 Future Alternatives
The Draft EIS presents three alternatives to test different growth patterns and policies. It is expected
that the City will create a preferred alternative based on public input and the Draft EIS evaluation of
the range of the alternatives. The preferred alternative may be one of the action alternatives or be a
combination of one or more features of any of the studied alternatives. The Final EIS will evaluate the
preferred alternative and respond to comments received on the Draft EIS.

2.5 SEPA Process
An EIS is an informational document that provides the City, public, Tribes, and agencies with
environmental information to be considered in the decision-making process. An EIS is required under
the State Environmental Policy Act (SEPA) for larger projects or for major plans, regulations, and
programs. An EIS describes potential environmental impacts, reasonable alternatives, and ways to
avoid or minimize negative impacts that could result from implementation of the Comprehensive Plan.
The EIS evaluation and mitigation measures will inform the City of Spokane Comprehensive Plan
Periodic Update.

The process for an EIS includes a scoping period to share likely topics and alternatives and invite
comments, a comment period on the Draft EIS, and a Final EIS that responds to comments. See
Exhibit 2.5-1. The scoping period lasted from February 5, 2025 to April 7, 2025. The Draft EIS
Comment period extends from December 18, 2025 to February 18, 2026. See the Fact Sheet for
more information about how to comment.

Exhibit 2.5-1. SEPA EIS Steps

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2.6 Benefits and Disadvantages of Delaying the Proposed
Action
SEPA requires an EIS to address “the benefits and disadvantages of reserving for some future time the
implementation of the proposal, as compared with possible approval at this time. The agency
perspective should be that each generation is, in effect, a trustee of the environment for succeeding
generations. Particular attention should be given to the possibility of foreclosing future options by
implementing the proposal.” (WAC 197-11-440(5)(vii) While the City has no intent to delay adoption
that is required by state law under GMA, this section addresses the potential benefits and
disadvantages of delaying the proposed action.

The benefits of delaying the proposed action are to retain a growth strategy that meets total housing
growth targets and contributes jobs at a greater rate than trends. The proposed action also provides
for growth strategies that allow for more walking and biking trips, and housing closer to jobs, and
implementation of climate policies that could help reduce greenhouse gas emissions and modestly
improve vehicle miles travelled per capita.

The disadvantages of delaying the proposal would include reduced housing capacity in housing types
that are more affordable and lack of consistency with affordable housing targets. There would be less
consistency with State requirements to address racial disparities and displacement risk and undo the
harm already done, particularly in creating housing opportunities. The capital facilities plan would not
be updated to direct resources to address demand due to growth. If not implementing a new
Comprehensive Plan, the City would not fully address emerging needs for climate adaptation and
mitigation, or review and update its critical areas regulations.

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3 Environment, Impacts, and
Mitigation Measures

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This chapter describes the affected environment, potential impacts, and mitigation measures for the
following topics:
 Section 3.1 Earth, Water Quality, and Water Resources
 Section 3.2 Air Quality/Greenhouse Gase Emissions
 Section 3.3 Plants and Animals
 Section 3.4 Land Use Patterns and Urban Form
 Section 3.5 Population, Employment, and Housing
 Section 3.6 Relationship to Plans, Policies, and Regulations
 Section 3.7 Transportation
 Section 3.8 Public Services
 Section 3.9 Utilities

Following a description of current conditions (affected environment), the analysis compares and
contrasts the alternatives and provides mitigation measures for identified impacts. It also summarizes
whether there are significant unavoidable adverse impacts.

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3.1 Earth, Water Quality, and Water Resources
This section discusses critical land areas and water resources in the study area, as identified in the
Affected Environment section. Thresholds of significance used to identify potential impacts to earth
and water resources involve comprehensive planning changes that could result in the following:
 Environmental Earth and Soil Hazards: Disturbances of existing contaminated areas to levels
that could endanger human health or the environment.
 Surface Water Quality: Increases in amount of pollution to receiving waters that would impair
their designated uses (such as human contact and fish habitat).
 Runoff Increases: Impervious surface expansions that would increase runoff flow volumes and
durations to streams by magnitudes resulting in bank scour and erosion.
 Groundwater Recharge: Impervious surface expansions that would decrease groundwater
recharge beyond designated limits.
 Groundwater Quality: Increases in amount of pollution discharged to levels that would
contaminate groundwater supplies.

3.1.1 Affected Environment
The affected environment elements for the earth and water resources analysis consist of:
 Earth: terrain, land use, impervious cover, soils and infiltration, geologic hazards, contaminated
soils, and environmental health disparities.
 Water Resources: Surface waters, water quality impairments, shorelines, floodplains, groundwater
resources, and environmental health disparities.

Earth

Terrain
Steep slopes can be vulnerable to erosion and landslides, while flat areas may be at higher risk for
flooding. The city and surrounding study area are relatively flat, with no more than two percent slopes
in most areas. The steepest terrain is in South Spokane around the Latah Creek (also known as
Hangman’s Creek) corridor. A map of study area terrain is presented in Exhibit 3.1-1.

Land Use and Zoning
Spokane is the largest, most developed city in eastern Washington. Land development creates impacts
to earth and water resources through increased vehicle use, commercial and industrial activities that
produce waste substances, landscaping with chemicals, and other pollution-generating activities.
Current zoning in the study area, which is an indicator of land use, is shown in Exhibit 3.1-2. Existing
zones throughout the city consist predominantly of single-unit residential areas, with commercial and

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industrial areas focused in Center City and West Plains, respectively. Northeast Spokane has the
widest variety of zoning classifications in the study area.

Exhibit 3.1-1. Terrain

Source: City of Spokane, 2025; Washington Lidar Portal, 2015 to 2019.

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Exhibit 3.1-2. Existing Zoning

Source: City of Spokane 2025; City of Spokane Aerial Imagery, 2024.

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Hard Surface (Impervious) Cover
The main feature of land development in a city like Spokane is the installation of hard surfaces (e.g.,
roads, parking, buildings, sidewalks; also known as impervious surfaces). The amount of hard surfaces
versus vegetation impacts how much and how quickly rainfall runoff soaks into the earth or is
transported to natural receiving waters. Typically, areas where more hard surfaces have been installed
and vegetation has been removed have produced impacts on earth and water resources over time.
These areas increase runoff volumes, erode streams, increase stream temperatures, decrease
groundwater recharge, and can increase flooding and habitat contamination. In places where runoff
infiltrates into the ground, untreated stormwater that soaks into the earth can potentially contaminate
groundwater.

Existing hard surface cover in the study area is shown in Exhibit 3.1-3. The most densely occurring
hard surface coverage is located in the Center City, followed by Northeast Spokane and Northwest
Spokane. South Spokane has less dense hard surface coverage, and West Plains has the least with
hard surfaces mainly located around the Spokane International Airport.

Soils and Infiltration
Soil type influences the ground’s ability to infiltrate rainwater runoff, which can recharge groundwater
aquifers and prevent high flows from scouring stream banks. In the study area, soil infiltration capacity
in non-developed areas is high to moderate, as shown in Exhibit 3.1-4. Specific soil types are listed in
Exhibit 3.1-5. Infiltration is typically not possible in areas of hard surface development, with the
exception of sites where special porous materials have been used.

In the West Plains region, although the soils are classified as having high to moderate infiltration
capabilities, impermeable shallow bedrock has been found that holds water near the surface.
Additional information is presented in the Stormwater Management Planning of the West Plains
Subarea of Spokane West Plains Geology and Hydrology Report (City of Spokane, 2013).

Hazardous Geology and Contaminated Soils
Erodible soils, landslide-prone geologic forms, and potentially contaminated areas identified on the
Superfund National Priorities List in the study area are shown in Exhibit 3.1-6. The main soil and
geology hazard areas are along Latah Creek and other areas in South Spokane and in the north and
west portions of Northwest Spokane. Potentially contaminated sites are located in and north of
Northeast Spokane. Information on groundwater contamination areas is presented in the
Groundwater Resources section.

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Exhibit 3.1-3. Existing Hard (Impervious) Surfaces

Source: City of Spokane, 2025; National Land Cover Dataset, 2023; Spokane County Aerial Imagery, 2024.

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Exhibit 3.1-4. Hydrologic Soil Groups

Source: United States Department of Agriculture (USDA) SSURGO Soils, 2025; Spokane County Aerial Imagery, 2024.

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Exhibit 3.1-5. Soil Type Summary
Hydrologic Soil Group Soil Type

A – High Infiltration Alecanyon, very stony-Cheney, complex
A – High Infiltration Battleplain ashy sandy loam
A – High Infiltration Battleplain ashy sandy loam, moist
A – High Infiltration Battleplain, moist-Phoebe, complex
A – High Infiltration Battleplain-Phoebe, dry, complex
A – High Infiltration Elmira loamy sand
A – High Infiltration Hagen ashy sandy loam
A – High Infiltration Marble loamy sand
A – High Infiltration Marble-Speigle, complex, mass wasted
A – High Infiltration Marblespring fine gravelly loamy coarse sand
A – High Infiltration Phoebe ashy sandy loam
A – High Infiltration Phoebe ashy sandy loam, dry
A – High Infiltration Phoebe, dry-Battleplain, complex
A – High Infiltration Phoebe-Battleplain, moist, complex
A – High Infiltration Spens very gravelly loamy coarse sand
A – High Infiltration Spens very gravelly loamy coarse sand, cool
A – High Infiltration Springdale gravelly ashy coarse sandy loam
A – High Infiltration Wapal gravelly ashy coarse sandy loam
B – Moderate Infiltration Brevco-Rock outcrop, complex
B – Moderate Infiltration Brincken ashy silt loam
B – Moderate Infiltration Brincken, moist-Fourmound, complex
B – Moderate Infiltration Brincken, moist-Speigle, complex, mass wasted
B – Moderate Infiltration Brincken, moist-Uhlig, complex
B – Moderate Infiltration Cheney ashy silt loam
B – Moderate Infiltration Cheney-Alecanyon, complex
B – Moderate Infiltration Cheney-Seaboldt, dry, complex
B – Moderate Infiltration Clayton-Hagen, complex
B – Moderate Infiltration Garrison very gravelly ashy loam

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Hydrologic Soil Group Soil Type
B – Moderate Infiltration Haploxerolls ashy silt loam, channeled
B – Moderate Infiltration Lenz-Rock outcrop, complex
B – Moderate Infiltration Lenz-Spokane, complex
B – Moderate Infiltration Opportunity very gravelly ashy loam
B – Moderate Infiltration Quinnamose-Micapeak, complex
B – Moderate Infiltration Scoap-Wapal, complex
B – Moderate Infiltration Speigle cobbly ashy loam
B – Moderate Infiltration Speigle-Rock outcrop, complex
B – Moderate Infiltration Stutler-Springdale, complex
B – Moderate Infiltration Uhlig ashy silt loam
B – Moderate Infiltration Uhlig ashy silt loam, dry
C – Slow Infiltration Bobbitt-Lacy, complex
C – Slow Infiltration Bobbitt-Speigle, complex
C – Slow Infiltration Caldwell-Thatuna, complex
C – Slow Infiltration Gibbs ashy silt loam
C – Slow Infiltration Glenrose ashy silt loam
C – Slow Infiltration Klickson gravelly ashy silt loam
C – Slow Infiltration Klickson-Speigle, complex
C – Slow Infiltration Klickson-Speigle, complex, mass wasted
C – Slow Infiltration Klickson-Speigle-Rock outcrop, complex
C – Slow Infiltration Kramerhill ashy loam
C – Slow Infiltration Kramerhill-Spokane, complex
C – Slow Infiltration Kramerhill-Uhlig-Skalan, complex
C – Slow Infiltration Kruse ashy silt loam
C – Slow Infiltration Lenz-Spokane, complex
C – Slow Infiltration Micapeak-Rock outcrop, complex
C – Slow Infiltration Narcisse silt loam
C – Slow Infiltration Northstar-Rock outcrop, complex
C – Slow Infiltration Northstar-Rock outcrop-Rockly, complex

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Hydrologic Soil Group Soil Type
C – Slow Infiltration Northstar-Rockly, complex
C – Slow Infiltration Seaboldt ashy loam
C – Slow Infiltration Seaboldt ashy loam, dry
C – Slow Infiltration Seaboldt, warm-Brincken, moist, complex
C – Slow Infiltration Spokane-Rock outcrop, complex
C – Slow Infiltration Urban land-Seaboldt, disturbed, complex
C – Slow Infiltration Urban land-Seaboldt, warm, disturbed-Brincken, moist, complex
C – Slow Infiltration Xerolls silt loam, cool, mass wasted
C – Slow Infiltration Xerolls silt loam, warm, mass wasted
D – No Infiltration/Wet Rockly-Cocolalla, complex
D – No Infiltration/Wet Rockly-Deno, complex
D – No Infiltration/Wet Rockly-Fourmound, complex
B/D – Mixed Type Aquepts ashy loam, frigid
B/D – Mixed Type Cocolalla ashy silt loam
B/D – Mixed Type Cocolalla-Hardesty, complex
B/D – Mixed Type Endoaquolls and Fluvaquents
B/D – Mixed Type Hardesty ashy silt loam
B/D – Mixed Type Hoodoo-Kronquist, complex
B/D – Mixed Type Peone-Saltese, complex
B/D – Mixed Type Saltese muck
C/D – Mixed Type Dearyton ashy silt loam
C/D – Mixed Type Lakespring ashy loam
C/D – Mixed Type Lakespring-Brincken, moist, complex
C/D – Mixed Type Nez Perce ashy silt loam
(Not classified) Pits-Dumps, complex
(Not classified) Riverwash
(Not classified) Rock outcrop-Klickson-Speigle, complex
(Not classified) Rock outcrop-Northstar, complex
(Not classified) Rock outcrop-Rubble land, complex, cliffs

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Hydrologic Soil Group Soil Type
(Not classified) Speigle-Rubble land-Rock outcrop, complex
(Not classified) Urban land, basalt bedrock substratum
(Not classified) Urban land, gravelly substratum
(Not classified) Urban land, sandy substratum
(Not classified) Urban land-Lakespring, disturbed, complex
(Not classified) Urban land-Lenz, disturbed, complex
(Not classified) Urban land-Marble, disturbed, complex
(Not classified) Urban land-Marblespring, disturbed, complex
(Not classified) Urban land-Northstar, disturbed, complex
(Not classified) Urban land-Opportunity, disturbed, complex
(Not classified) Urban land-Phoebe, disturbed, complex
(Not classified) Urban land-Seaboldt, disturbed, complex
(Not classified) Urban land-Seaboldt, warm, disturbed-Brincken, moist, complex
(Not classified) Urban land-Spens, disturbed, complex
(Not classified) Urban land-Spokane, disturbed, complex
(Not classified) Urban land-Springdale, disturbed, complex
(Not classified) Urban land-Uhlig, disturbed, complex
(Not classified) Water

Source: United States Department of Agriculture (USDA) SSURGO Soils, 2025.

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Exhibit 3.1-6. Hazardous Geology

Source: City of Spokane, 2025; Washington State Department of Natural Resources (WA DNR), 2025; Washington Lidar
Portal, 2015 to 2019.

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Water Resources

Surface Waters
The study area includes five watersheds, shown in Exhibit 3.1-7. The main surface receiving waters are
the Spokane River and Latah Creek (also known as Hangman’s Creek), both of which are fish-bearing.
Discussion of fish habitat is presented in Section 3.3 Plants and Animals. A summary of the surface
water features in the study area is presented in Exhibit 3.1-8.

Water Quality Impairments
As listed in Exhibit 3.1-8 and shown in Exhibit 3.1-9, four water bodies in the study area have been
identified on the Washington State Department of Ecology (Ecology) Clean Water Act Section 303(d)
List as having water quality impairments (Ecology, 2018). For several of the contaminants, formal water
quality improvement plans are in place.

Shorelines
As listed in Exhibit 3.1-8 and shown in Exhibit 3.1-10, three water bodies in the study area have been
designated by Washington Administrative Code (WAC) 173-18 Shoreline Management Act as having
Shorelines of the State as well as Shorelines of Statewide Significance. Shorelines with these
designations have stricter protections from modification through the requirements in WAC 173-26
State Shoreline Master Program.

Floodplains
Flood hazard areas in the study area mapped by the Federal Emergency Management Agency (FEMA)
are shown in Exhibit 3.1-11. Special flood hazard areas, also known as 100-year floodplains, are those
areas subject to flooding by the base flood. The base flood event has a 1 percent chance of occurring
any given year and is commonly known as the 100-year flood. Flood hazard areas known as 500-year
floodplains have an expected inundation chance of 0.2 percent each year. Floodways are the main
watercourse channel and adjacent lands that must be kept free of fill or development to avoid
increasing flood elevations. Floodways are defined through detailed hydraulic analysis; therefore,
many floodplains have not yet had their associated floodways identified. Due to the flat terrain in the
study area, some floodplains are associated with intermittent streams, meaning these areas see
channel flow and overland flooding during flood events but have no channel flow during dry periods.

Climate change may affect floodplains in the future. The FEMA Federal Flood Risk Management
Standard provides guidance on flood risk management to account for climate change by
(1) conducting site-specific hydraulic analysis using climate forecasts, (2) designing facilities based on
the 100-year based flood event with 2 to 3 feet of freeboard added, or (3) designing facilities based on
the 500-year flood elevation (FEMA 2024).

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Exhibit 3.1-7. Surface Waters

Sources: City of Spokane, 2025; National Hydrology Dataset, Washington, 2025; Department of Fish & Wildlife, 2025;
Washington Department of Ecology, 2025; and Spokane County Aerial Imagery, 2024.

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Exhibit 3.1-8. Surface Waters Summary Table

Fish-Bearing Shoreline of
Water Body 303(d) Water Quality Impairment
(Y/N) State (Y/N)

Latah (Hangman) Creek Category 4A: Temperature Y Y*
Category 5: Dissolved oxygen, pH

Little Spokane River Category 4A: Dissolved oxygen, turbidity Y Y*
Category 5: Temperature

Marshall Creek Category 4A: Bacteria - Fecal coliform, N N
Temperature
Category 5: Dissolved oxygen
Spokane River Category 4A: dissolved oxygen, lead, zinc Y Y*
Category 4B: arsenic, cadmium, chromium,
copper, lead, mercury, polybrominated
diphenyl ethers (PBDEs), silver, zinc
Category 5: 2,3,7,8-tcdd (dioxin), bacteria -
fecal coliform, methyl mercury,
polybrominated diphenyl ethers (PBDEs),
polychlorinated biphenyls (PCBs)

Notes: Category 4A – An EPA-approved Total Maximum Daily Load (TMDL) plan is in place and implemented;
Category 4B – A pollution control program, similar to a TMDL plan, is in place that is expected to address the issue;
Category 5 – Data shows water quality standards have been violated, improvement plan has not yet been developed.
*Shorelines of the State that are also designated at Shorelines of Statewide Significance are marked with an asterisk.
Source: Washington Department of Ecology, 2018.

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Exhibit 3.1-9. Water Quality Impairments

Sources: City of Spokane, 2025; National Hydrology Dataset, 2025; Washington Department of Fish & Wildlife, 2025;
Washington Department of Ecology, 2025; and Spokane County Aerial Imagery, 2024.

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Exhibit 3.1-10. Shorelines

Source: City of Spokane, 2025; Spokane County Aerial Imagery,2024.

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Exhibit 3.1-11. FEMA Flood Zones

Source: Federal Emergency Management Agency (FEMA), 2025; and Spokane County Aerial Imagery, 2024.

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Groundwater Resources
Groundwater resources such as critical aquifer recharge and wellhead protection areas in the study
area are shown in Exhibit 3.1-12. These areas are protected through regulation of development and
other activities that could impact groundwater recharge or transport of pollutants. Also, as a result of
an August 5, 2025, ballot measure, the Spokane Valley Rathdrum Prairie Aquifer Protection Area will be
expanded to include all areas within the city boundary (presently it includes none of the city) beginning
on January 1, 2026.

Information on Ecology’s findings of per- and polyfluoroalkyl substances (PFAS) contamination in
private-well groundwater in the West Plains region of the city is presented in Exhibit 3.1-13 and
Exhibit 3.1-14. Additional information on PFAS sampling throughout the city is presented in the City of
Spokane 2024 Water Quality Report available at
https://my.spokanecity.org/publicworks/water/quality/.

The study area contains a portion of the Spokane Valley-Rathdrum Prairie Sole Source Aquifer, located
mainly in Northwest Spokane and Northeast Spokane. Sole source aquifers are identified by the U.S.
Environmental Protection Agency (EPA) as aquifers that supply at least 50 percent of the drinking
water for a service area where there are no reasonably available alternative drinking water sources
should the aquifer become contaminated. In addition, wellhead protection areas are defined by
protection categories that refer to the amount of time it would take contamination to reach the
wellhead from the specified area within each boundary. Projection boundaries include the 5- and 10-
year time-of-travel boundaries. Required levels of protection and restrictions on certain activities
increase for boundaries closer to the wellhead.

Environmental Health Disparities
Environmental health disparities in the study area based on the Washington State Department of
Health (DOH) data is shown in Exhibit 3.1-15. This data compares environmental and socioeconomic
risk factors across all of Washington U.S. census tracts and consists of indicators like proximity to
hazardous waste facilities, proximity to wastewater discharges, income, and race. Highly impacted
communities, which are defined as vulnerable populations in close proximity to environmental
hazards, are considered those in areas ranked with risk factors of 9 or 10. In the City of Spokane,
highly impacted communities are found primarily along I-90 and throughout Center City and
Northeast Spokane.

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Exhibit 3.1-12. Groundwater Resources

Sources: City of Spokane, 2025; Washington State Department of Health, 2025.

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Exhibit 3.1-13. West Plains Private-Well PFAS Levels by Location

Source: Washington Department of Ecology, 2025.

Exhibit 3.1-14. West Plains PFAS Private Well Sampling Data

Sample results Number of Percent of
locations* locations*

Private wells that do not have PFAS 111 27%
Private wells with PFAS below drinking water standards 64 16%
Private wells with PFAS above drinking water standards 236 57%

Total 411 100%
* Includes locations outside of Comprehensive Plan study area.
Source: Washington Department of Ecology, 2025.

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Exhibit 3.1-15. Environmental Health Disparities

Source: City of Spokane, 2025; Washington State Department of Health, 2025.

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3.1.2 Impacts

Impacts Common to All Alternatives
This section discusses impacts to earth and water resources that are common to all alternatives. It
should be noted that most impacts of future development projects on earth and water resources
would be avoided or minimized through compliance with the Spokane Regional Stormwater Manual
(Spokane et. al. 2008), Spokane Municipal Code (SMC) 17D.060 – Stormwater Facilities, SMC 17D.090 –
Erosion and Sediment Control, SMC Title 17E – Environmental Standards (which covers aquifer
protection, fish and wildlife conservation areas, floodplain management, geologically hazardous areas,
shoreline regulations, and wetlands protection), and other applicable federal, state, and local
regulations. Details of impact mitigation are discussed in Exhibit 3.1-11.

The impacts to earth and water resources common to all plan alternatives are:
 Construction impacts—Construction of development projects that may result from the plan
alternatives would remove vegetation and/or hard surfaces, which can result in soil disturbance,
erosion, water pollution, and soil contamination. In addition, vehicles, machinery, and materials
brought to a construction site can introduce oil, grease, chemicals, and other pollutants that pose a
risk to earth and water resources if not managed properly. Best management practices (BMPs)
required by development permits to control construction activities and rainfall runoff are expected
to prevent or minimize adverse impacts.
 Potential for increased pollution—Projected increases in population, jobs, and housing densities
are used as indicators of increased pollution in the earth and water impacts analysis. The plan
accommodation of higher populations in the urban growth center through increased jobs and
housing will provide benefits to the community and protect natural resources in the region by
preventing developmental sprawl in rural areas. However, increased jobs and housing can also
increase impacts to earth and water resources in the city through increased vehicle use,
commercial and light industrial activities that produce waste substances, landscaping with
chemicals, and other pollution-generating activities. These impacts would be mitigated by the
presence of stormwater runoff BMPs on roadways and other pollution-generating surfaces. A
comparison of the potential for increased pollution risk to earth and water resources across the
plan alternatives is presented in Exhibit 3.1-15.
 Potential for increased rainfall runoff flows—Projections for increased housing are used in the
earth and water resources impacts analysis as indicators of increased rainfall runoff. As discussed
in Section 3.1.1, the amount of hard surfaces versus vegetation impacts how much and how
quickly rainfall runoff and pollutants may soak into the earth or are transported to natural
receiving waters. A comparison of the potential for increased runoff impacts to earth and water
resources across the plan alternatives is presented in Exhibit 3.1-15. Maps showing the density
projections of each alternative against already developed hard surfaces are shown in Exhibit
3.1-16 through Exhibit 3.1-19. Additional considerations of changes in land cover, including
changes in vegetation, are discussed in Section 3.3 Plants and Animals.

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Comparison of Impacts

Environmental Impacts

A comparison of the plan alternatives is presented in Exhibit 3.1-16. Maps showing the density
projections of each alternative against already developed hard surfaces are shown in Exhibit 3.1-17
through Exhibit 3.1-19.

Exhibit 3.1-16. Summary of Impact Indicators

Impact Metric Alternative 1: Stay the Alternative 2: Distributed Alternative 3: Center City
(Weight) Course and Balanced and Regional Hubs

Pollution Population target for 2022 Same as Alternative 1. Same as Alternative 1.
Indicator – to 2046: 25,157 to 50,650.
Population
() No difference No difference No difference
Pollution Regional (SRTC) Projection State (ESD) Projection Moderate-High Projection
Indicator - Job 34,850, about 15,000 jobs 24,939, about 5,000 jobs 38,848, about 19,000 jobs
Projections above historic trend. above historic trend. above historic trend
() High impact Medium impact Highest impact
Pollution High intensity housing in Greater range of housing Prioritizes low- and mid-
Indicator and Centers & Corridors and including low-rise, mid- rise housing along bus
Flow Increase Downtown, with middle rise, and mixed-use along rapid transit per HB 1491
Indicator - housing and single unit frequent transit routes. and in targeted centers.
Density allowed in residential Meets HB 1491 transit- Distributes neighborhood
Distribution areas. oriented development. commercial.
Highest increased density Some increased density Least increased density
focused on currently focused on currently focused on currently
undeveloped areas. undeveloped areas. undeveloped areas.
() Highest impacts Medium impacts Lowest impacts
Strength of No comprehensive plan or Periodic code update, Similar to Alternative 2.
Mitigation municipal code updates. including new Climate
Potential – No new Climate Element Element per HB 1181 and
Code Updates per HB 1181. critical area regulation
update based on best
available science.
() Weakest mitigation Strongest mitigation Strongest mitigation

Overall Highest Impacts Medium/Lower Impacts Lowest Impacts

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Exhibit 3.1-17. Existing Hard Surfaces and Forecasted Density Distribution – Alternative 1

Sources: City of Spokane, 2025; National Hydrology Dataset, 2025; Washington Department of Fish & Wildlife, 2025; and
Washington Department of Ecology, 2025.

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Exhibit 3.1-18. Existing Hard Surfaces and Forecasted Density Distribution – Alternative 2

Source: City of Spokane, 2025; National Hydrology Dataset, 2025; Washington Department of Fish & Wildlife, 2025; and
Washington Department of Ecology, 2025.

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Exhibit 3.1-19. Existing Hard Surfaces and Forecasted Density Distribution – Alternative 3

Source: City of Spokane, 2025; National Hydrology Dataset, 2025; Washington Department of Fish & Wildlife, 2025; and
Washington Department of Ecology, 2025.

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Environmental Justice Implications

As discussed in Section 3.1.1 and shown in Exhibit 3.1-15, highly impacted communities are located in
the study area along I-90 and throughout Center City and Northeast Spokane. Redevelopment in these
areas associated with the plan alternatives could have both beneficial and detrimental impacts to the
population in these areas, as follows:
 Water Quality: In many cases, development permitted in eastern Washington before the 2000’s
often does not have rainwater runoff management protective of water resources, and
development permitted earlier than the 2020’s typically does not have stormwater management
that captures pollution or controls flow volumes to the maximum extent practicable.
Redevelopment of these areas often triggers requirements to upgrade stormwater management to
meet current standards. These upgrades can result in a benefit to earth and water resources, and
in turn to those living in the surrounding community. Newer stormwater infrastructure can be
designed to be more resilient to changes in rainfall frequencies and volumes, thereby lowering the
flood risks for the community. In cities like Spokane with some areas that were developed decades
ago, redevelopment areas with underserved populations can sometimes help address
environmental inequities related to water quality. Among the plan alternatives, each includes
changes in development patterns in the highly impacted communities discussed in Section 3.1.1,
which could result in beneficial retrofits to stormwater management.
 Exposure to Contaminated Sites: Populations living near historically contaminated sites may be at
risk from environmental hazard exposure, and disturbance of the ground surface in these areas
can sometimes increase the risk. However, larger redevelopment in these areas can trigger site
remediation to either more safely contain the contaminants up to current standards or remove the
contaminants to a designated hazardous waste disposal site. Therefore, redevelopment can
sometimes pose a risk of exposure from contaminated sites or motivate additional clean-up and
protection, depending on the scale of the project.
 Exposure to Flooding and Landslides: Where redevelopment would trigger installation of newer
stormwater infrastructure as described above, that infrastructure can be designed to be more
resilient to changes in rainfall frequencies and volumes, thereby lowering the flood risks for the
community. While Alternative 1 retains current plans and regulations, Alternatives 2 and 3 would
include a new climate element with resilience and mitigation policies and update critical area
regulations.

Area Specific Evaluation
As previously discussed, density projections can serve as an indicator of potential impacts to earth and
water resources. A comparison of the density projections of each alternative for each city region is
presented in Exhibit 3.1-20.

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Exhibit 3.1-20. Density Projections as Indicators of Impacts by Spokane Region

Alternative 1: Stay the Alternative 2: Distributed Alternative 3: Center City
Course and Balanced and Regional Hubs

Northwest Most density focused in Some density focused in Least density focused in
Spokane currently undeveloped currently undeveloped currently undeveloped
(less developed) areas. areas. areas.
Northeast Spokane Most density focused in Some density focused in Least density focused in
(moderately currently undeveloped currently undeveloped currently undeveloped
developed) areas. areas. areas.
Division Corridor Lowest amount of new Moderate amount of new Highest amount of new
(highly developed) density focused in this density focused in this density focused in this
already developed area. already developed area. already developed area.
Center City Lowest amount of new Moderate amount of new Highest amount of new
(highly developed) density focused in this density focused in this density focused in this
already developed area. already developed area. already developed area.
South Spokane Highest amount of new Moderate amount of new Lower amount of new
(less developed) density in this currently density in this currently density in this currently
less developed area. less developed area. less developed area.
West Plains Some new density Lowest amount of new Same as Alternative 2.
(less developed) focused north of the density.
airport.

3.1.3 Mitigation Measures

Incorporated Plan Features
The following plan features that would be included in Alternatives 2 and 3 would potentially help to
minimize impacts to earth and water resources:
 Develop and implement climate resilience and greenhouse gas reduction goals and policies per
HB 1181.
 Review and update of critical areas regulations based on best available science.

Regulations and Commitments
Most impacts on earth and water resources from future development projects associated with the
plan alternatives would be avoided or minimized through compliance with the applicable regulations
such as those listed below.

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Federal
 Clean Water Act, 33 United States Code (USC) 1251 et seq., including Sections 401—Water Quality
Certification, 402—National Pollutant Discharge Elimination System, and 404—Permits for Dredge
or Fill
 Coastal Zone Management Act, 16 USC 1451 et seq.
 Section 14 of the Rivers and Harbors Act of 1899, 33 USC 408 (Section 408)
 National Flood Insurance Act of 1968 and Flood Disaster Protection Act of 1973, 42 USC 4001 et
seq.
 Floodplain Management Presidential Executive Order 11988
 Endangered Species Act (ESA) Biological Opinion for the Implementation of the National Flood
Insurance Program in the State of Washington (National Marine Fisheries Service 2008)
 Safe Drinking Water Act, 42 USC 300 et seq., Chapter 6A

State & Regional
 Water Quality Standards for Surface Waters, Washington Administrative Code (WAC) 173201A
 Water Quality Standards for Groundwater, WAC 173-200
 Flood Control Management Act, Revised Code of Washington (RCW) 86
 Water Pollution Control Act, RCW 90.48
 Shoreline Management Act, RCW 90.58, WAC 173-26
 National Pollutant Discharge Elimination System (NPDES) Construction Stormwater General Permit
(Washington State Department of Ecology [Ecology], 2020)
 National Pollutant Discharge Elimination System (NPDES) Eastern Washington Phase II Municipal
Stormwater General Permit (Ecology, 2024a)
 Stormwater Management Manual for Eastern Washington (Ecology Manual) (Ecology, 2024b)
 Washington State Department of Transportation (WSDOT) Highway Runoff Manual (WSDOT, 2019a)
 WSDOT Hydraulics Manual (WSDOT, 2024)
 WSDOT Temporary Erosion and Sediment Control Manual (WSDOT, 2019b)
 Washington State Hydraulic Code, WAC 220-660

City of Spokane
 SMC 17D.060 – Stormwater Facilities
 SMC 17D.090 – Erosion and Sediment Control
 SMC Title 17E – Environmental Standards (which covers aquifer protection, fish and wildlife
conservation areas, floodplain management, geologically hazardous areas, shoreline regulations,
and wetlands protection)
 Spokane Regional Stormwater Manual (Spokane et. al., 2008)

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Other Potential Mitigation Measures
The following mitigation measures are not part of the plan alternatives but are recommended for
consideration by the City. These measures would help to further address existing impacts on earth
and water resources associated with overall urban development in Spokane.
 Install updated stormwater controls on roadways, which are not likely to be upgraded as part of
the parcel redevelopments included in the alternatives.
 Prioritize opportunities to restore critical area buffers.
 Identify, protect, and restore tree canopy – especially in stream and river buffers.
 Avoid adding or expanding roadways through transit and other approaches.
 Continue to follow-up on recommendations of recent environmental code audit (Spokane, 2025) to
review Spokane Municipal Code Section 17E.010 Critical Aquifer Recharge Area for additional
protections, such as addressing demands on aquifer for uses as temperatures increase.

3.1.4 Significant Unavoidable Adverse Impacts
As discussed in Section 3.1.3, development associated with every project alternative would be
required to implement BMPs to minimize or avoid potential impacts to earth and water resources.
Therefore, no significant unavoidable adverse impacts to earth and water resources are expected
from the plan alternatives.

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3.2 Air Quality and Greenhouse Gas Emissions
This section addresses existing air quality and greenhouse gas (GHG) emissions within Spokane,
explores how the alternatives may influence air quality, and considers implications for public health,
particularly focusing on vulnerable populations and overburdened communities. It also provides an
overview of regional, state, and federal air quality regulations, including monitoring and permitting
programs, and a summary of regional GHG emissions.

Increasing GHG emissions exacerbate air quality issues and contribute directly to climate change.
Spokane faces increasing climate hazards, including rising temperatures and extreme heat, wildfires
and smoke, heavy precipitation and flooding, drought, and reduced snowpack. Wildfires and smoke
have the greatest impact on regional air quality and are increasing in likelihood due to rising
temperatures and changing precipitation patterns. The City of Spokane is projected to experience an
additional 16 “very high” fire danger days and 11 “extreme” fire danger days by midcentury. By the end
of the century, there is an expected 87% chance of climate and fuel conditions within Spokane County
being favorable for wildfire in any given year (Hegewisch & Abatzoglou, n.d.). Additionally, Spokane
County has received some of the highest wildfire smoke scores in the state, reflecting elevated
concentrations of fine particulate matter on days impacted by smoke from regional wildfires as well as
those across the western U.S. and Canada (City of Spokane, 2025).

Air quality in Spokane is also impacted by year-round pollution sources. Vehicle emissions—
particularly from heavy traffic along the I-90 corridor—residential wood burning, and industrial
operations contribute to elevated levels of particulate matter and ground-level ozone, which are the
region’s primary criteria pollutants of concern. Criteria pollutants refers to six of the most common air
pollutants—carbon monoxide, lead, ground-level ozone, particulate matter, and sulfur dioxide (U.S.
Environmental Protection Agency, 2025). These pollutants are linked to a myriad of respiratory and
cardiovascular problems that pose a serious risk to ecosystem function and human health, especially
for vulnerable populations. Neighborhoods along the I-90 corridor, Northeast Spokane, and parts
of South Spokane are identified as having high environmental health disparities (City of Spokane,
2025).

Diminished air quality from emissions poses significant risks to Spokane’s economic vitality. Wildfire
smoke and elevated particulate matter (PM2.5 and PM10) will negatively impact and reduce the
workforce, increase healthcare costs, and disrupt outdoor recreation and tourism. These effects are
particularly burdensome for vulnerable populations, as they exacerbate financial hardships and health
conditions.

The following sections assess how the alternatives may influence air quality and GHG emissions in
Spokane, discuss consistency with applicable air quality standards and climate policies, and evaluate
mitigation measures that reduce potential impacts and prioritize equity and resilience.

Consistent with the above descriptions and based on GHG emissions reduction goals set within
Spokane’s Municipal Code Section 15.05.020, thresholds of significance utilized in this impact analysis
include:

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 Achieve 45% reduction in GHG emissions by 2030
 70% reduction in GHG emissions by 2040
 Net Zero by 2050 (per GHG Inventory Results)

3.2.1 Affected Environment
Spokane is located in eastern Washington and serves as the economic and cultural center of the inland
Pacific Northwest. The city is situated in a valley by the Spokane River and is surrounded by rolling
hills, dense forestland, and the foothills of the Rocky Mountains to the west. The region’s semi-arid
climate brings cold, snowy winters and hot, dry summers. Spokane’s geography and climate contribute
to its air quality challenges, particularly during wildfire season and stagnant weather conditions typical
to valleys.

Regulatory Overview for Pollutants of Concern
Air quality is regulated through local, state, and federal policies, standards, and enforcement
mechanisms. At the federal level, the Environmental Protection Agency (EPA) enforces the Clean Air
Act (CAA), which establishes National Ambient Air Quality Standards (NAAQS) for six criteria pollutants
and sets emissions standards for vehicles and fuels, stationary industrial facilities such as refineries
and power plants, and hazardous air pollutants.

In Washington State, the Department of Ecology (Ecology) develops and implements plans to ensure
compliance with NAAQS, and locally, the Spokane Regional Clean Air Agency (SRCAA) is tasked with air
quality monitoring, enforcement, inspections, permitting, and outreach within Spokane County.
SRCAA’s core air quality regulatory code—Regulation I—incorporates federal and state standards,
while including specific requirements for air quality measures within the county. The following
sections describe sources, regulatory mechanisms, monitoring and compliance efforts, and public
health and environmental impacts for the six criteria pollutants within Spokane. Regional monitoring
programs and data for particulate matter and ozone emissions—Spokane’s primary pollutants of
concern—will be discussed in Data and Methods.

Particulate Matter
Particulate matter is mostly comprised of tiny airborne smoke and dust particles that can lead to
respiratory and cardiovascular issues when inhaled. In Spokane County and the city, sources of
particulate matter typically include construction sites, paved and unpaved roads, mobile vehicles,
residential and non-residential burning, and wildfires (Spokane Regional Clean Air Agency, 2025).
SRCAA continuously monitors particulate matter (PM10 and PM2.5) levels at seven monitoring sites
throughout the county and enforces burn bans and dust control measures to prevent exceeding the
NAAQS established by the EPA.

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Ozone
Ground-level ozone (O3) is formed when sunlight or heat interacts with chemical reactions between
oxides of nitrogen and volatile organic compounds from vehicle emissions, solvents, and industrial
processes (EPA, 2025). Ground-level ozone is particularly harmful to children and those with existing
respiratory issues. SRCAA and Ecology monitor summer levels of ground-level ozone closely and
implement strategies to maintain federal standards through vehicle emissions reduction programs
and permitting. Additionally, the EPA regulates ozone-depleting chemicals, including
chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), helping to restore and protect the
stratospheric ozone layer (EPA, 2025).

Carbon Monoxide
Carbon monoxide (CO) is a colorless, odorless gas that is released when fossil fuels are burned, with
major sources including motor vehicles, heating appliances, and wood burning (EPA, 2025). CO
emissions can become particularly elevated during periods of heavy traffic congestion and thermal
inversions. Breathing air with a high concentration of CO is very harmful to heart and brain function,
as it reduces oxygen levels in the bloodstream. NAAQS for CO sets limits of 35 ppm for 1-hour
averages and 9 ppm for 8-hour averages, with no more than one exceedance allowed per year to
protect public health. As late as the 1990s, many dense urban areas in Washington state violated these
standards. After Washington’s urban areas reached attainment status for CO in 2004, Ecology phased
out most monitoring programs, including in Spokane. (Washington State Department of Ecology,
2025). SRCAA’s permitting and wood stove restrictions, as well as public education campaigns around
wood burning and vehicle idling, are strategies used to regulate CO levels in Spokane County,
including the city, and ensure ongoing attainment status with EPA’s NAAQS.

Nitrogen Dioxide
Nitrogen Dioxide (NO2) is formed from motor vehicle emissions, industrial combustion, and wood
smoke, and can cause harm to respiratory systems and the natural environment. NO2 levels in
Washington have never exceeded the standards set forth by the EPA and are thus not continuously
monitored throughout the state. In Spokane County, SRCAA maintains attainment status with NAAQS
through regulatory measures like construction permitting, monitoring and inspection, and
enforcement.

Sulfur Oxides
Sulfur Oxide (SO2) is a colorless gas produced by burning fossil fuels containing sulfur, like coal and
crude oil. Exposure to SO2 can impair ecosystem function and cause harm to respiratory systems—
particularly for children, older adults, and those with preexisting health conditions. In Washington
state, industrial facilities such as fossil fuel power plants, aluminum smelters, oil refineries, pulp mills,
and ships and locomotives are major contributors to SO2 emissions (EPA, 2025).

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In 2010, EPA adopted more stringent SO2 measures, setting the standard at a 1-hour standard of 75
ppb. In response to the update, Ecology evaluated SO2 ambient levels in all 39 counties in Washington,
concluding that all except a small area in Whatcom County met the standard. Since then, continuous
SO2 monitoring has been phased out across most of the state, including in Spokane. SRCAA ensures
levels meet NAAQS through regulatory measures like construction permitting, monitoring and
inspection, and enforcement.

Lead
The EPA began phasing out lead from motor vehicle gasoline in the 1970s, resulting in a 98% decrease
of airborne lead between 1980 and 2014. Lead is a toxic metal that poses serious risks to human
health—particularly children—and impairs ecosystem function (EPA, 2025). Due to EPA’s regulatory
efforts, most ambient lead levels in the U.S. remain well below NAAQS and regular monitoring is no
longer required in areas without major lead sources like Spokane County. Major sources of airborne
lead emissions typically include metal and ore processing, lead aviation fuel, waste incinerators,
utilities, and lead-acid battery manufacturers (EPA, 2025). SRCAA’s regulatory efforts include
overseeing permitting and inspections of stationary sources that may emit lead on an as-needed basis.

Regional Greenhouse Gas Emissions
In 2025, the City of Spokane developed 2022 GHG emissions inventories for the city’s community and
government operations. The inventories included Scope 1 emissions, which are direct emissions from
sources within the community’s geographic boundary, and Scope 2 emissions, which are indirect
emissions from purchased electricity, steam, or heating/cooling used by the community or local
government. The City also included some Scope 3 emissions—indirect upstream and downstream
emissions associated with the production and disposal of goods and services. The details of the
emissions inventory boundary include:
 Communitywide emissions that occurred within the City of Spokane’s geopolitical boundaries
across the residential, commercial, municipal, and industrial sectors. Spokane’s city boundary
covers approximately 69.5 square miles.
 Local government operations emissions that resulted from the City’s governmental operations,
including sources under the City’s operational control (City has full authority to introduce and
implement operating policies at facilities), regardless of geographic location.

Communitywide emissions totaled 2,283,457 metric tons of carbon dioxide equivalent (MTCO2e) in
2022, while government operations produced 148,058 metric tons of carbon dioxide equivalent
(MTCO2e) in 2022 – approximately 6.5% of communitywide emissions (City of Spokane, 2025). Energy
use (48%) and transportation (41%) contribute to the majority of GHG emissions across the community
and also contribute to criteria air pollutants of primary concern, including particulate matter and
ozone (Spokane Regional Clean Air Agency, 2025). Within government operations emissions, solid
waste operations were the largest source of emissions (73%) since they include the emissions from the
disposal of City and County municipal solid waste. This includes the City’s Waste to Energy (WTE)

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facility, the North and South Side landfills, and grid electricity and natural gas consumption within
facilities used for solid waste operations (City of Spokane, 2025).

Communitywide emissions increased slightly (5%) from 2016 to 2022, while emissions produced by the
City of Spokane’s government operations decreased by 2% in the same timeframe. The
communitywide increase is largely attributable to an increase in population and higher consumption
of aviation fuel, natural gas, and refrigerants. Since 2016, natural gas consumption has risen by 30% in
the city. The decrease in government operations emissions primarily comes from a reduction in
emissions from solid waste operations, electricity consumption, wastewater processes, and employee
commuting (City of Spokane, 2025).

Regional Air Quality Monitoring Data
SRCAA operates seven air quality monitoring stations throughout Spokane County measuring PM2.5,
PM10, and ozone. The Agency releases monthly air quality reports which show daily Air Quality Index
(AQI) values for PM2.5, PM10, and ozone, the number of days in each AQI category, and detailed
pollutant information per site (Air Quality Index Basics, 2025). SRCAA also releases annual air quality
report cards, highlighting AQI trends and year-to-year comparisons and pollution spikes.

In 2024, 63% of the year had “Good” AQI and another 24% had “Moderate” AQI, while just two days
were categorized as “Unhealthy for Sensitive Groups.” The highest daily AQI of 2024 was 106 on
November 9 (Spokane Regional Clean Air Agency, 2025)

In Spokane County, SRCAA continuously monitors three ambient air pollutants of primary concern,
including fine and coarse particulate matter (PM2.5 and PM10) and ground-level ozone (O3). Fine
particles (PM2.5) are 2.5 microns in diameter or less and are formed during the burning process, while
PM10 are larger, coarse particles measuring 10 microns in diameter or less, such as dust (Spokane
Regional Clean Air Agency, 2025). The health-based standard for both PM2.5 and PM10 is a 24-hour
average, measured from midnight to midnight. PM2.5 standard is 35 micrograms per cubic meter of air,
and PM10 is 150 micrograms per cubic meter of air. If the daily average concentration of either
pollutant goes above these limits, it may pose a risk to public health—especially for sensitive groups
like children, the elderly, and people with heart or lung conditions. Exhibit 3.2-1 shows Spokane’s
PM2.5 concentrations exceeded the health-based standard from 2016 to 2019 but have since been
reduced. The exceedances are linked to a rise in wildfire activity and smoke events, which began
increasing around 2015 and peaked in severity during the 2020 and 2021 wildfire seasons.

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Exhibit 3.2-1. Spokane County PM2.5 Trends, 2011-2023

Source: SRCAA Air Pollutants and Trends, 2025.

In Spokane County, PM10 concentrations typically fall below EPA standards, as shown in Exhibit 3.2-2,
which shows the most current data on countywide PM10 concentrations in May of 2025.

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Exhibit 3.2-2. Daily 24-hour Average PM10 for All Spokane County Monitoring Stations, May 2025.

.

Source: (Spokane Regional Clean Air Agency, 2025).

Ozone in the upper atmosphere, known as the stratosphere, protects people, wildlife, and ecosystems
from harmful ultraviolet rays, while ozone in the lower atmosphere—even in small concentrations—
can have serious health implications. This ground-level ozone becomes a health concern during the
hot summer months, when photo-chemicals react with volatile organic compounds, nitrogen oxides,
and sunlight and heat. The EPA established the 8-hour health-based standard for ozone at 0.070 ppm
in 2015. Exhibit 3.2-3 shows Spokane County’s ozone concentration trends from 2011 to 2022, which
consistently remained below 0.070 ppm.

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Exhibit 3.2-3. Spokane County Ozone Trends, 2011-2022

Source: S (Spokane Regional Clean Air Agency, 2025).

Air Quality Permitting Requirements
Ecology and SRCAA issue the following permits and programs related to air quality:
 Annual Registration Programs
 Notice of Construction (NOC) Permits
 Air Operating Permits (AOP)
 Burn Permits
 General Order of Approval

Annual Registration Programs
As mandated by Regulation I, SRCAA’s annual registration program requires most stationary sources of
air pollution to register annually. These sources include auto shops, dry cleaners, gas stations, and
small manufacturers. The program ensures ongoing compliance with air quality regulations through
annual fees, inspections, emissions reporting, and recordkeeping requirements. It applies to both
permitted and non-permitted sources and helps SRCAA track emissions, enforce rules, and maintain
regional air quality standards (Spokane Regional Clean Air Agency, 2025).

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Notice of Construction (NOC) Permits
SRCAA implements the state Notice of Construction (NOC) rules (Washington State Legislature, 2025),
which requires the owner or operator of an air contaminant source to file an application for an NOC
approval prior to constructing, installing, establishing, replacing, or modifying air contaminant sources,
emissions units, or air pollution control equipment in Spokane County (Spokane Regional Clean Air
Agency, 2025).

Air Operating Permits (AOP)
As mandated by the EPA, SRCAA administers the federal Air Operating Permit (AOP) program in
Spokane County. Major sources are defined as businesses or facilities with a potential to emit any of
the following:
 100 tons of any criteria pollutant
 10 tons of any single hazardous air pollutant (HAP) as listed pursuant to subsection 112(b) of the
federal Clean Air Act
 25 tons of all HAPS combined

Burn Permits
Outdoor burning is heavily restricted in Spokane County and burn permits are issued and approved by
SRCAA for limited activities and on a case-by-case basis. These permits are available for certain types
of natural vegetation disposal, such as agricultural clearing, flood debris clearing, noxious weed
abatement, training exercises, or small social events. However, all permit applications must comply
with local smoke management and public health standards to receive approval (Spokane Regional
Clean Air Agency, 2025)

Prevention of Significant Deterioration (PSD)
The Prevention of Significant Deterioration (PSD) program is a federal permitting process that applies
to major new sources or major modifications in areas that meet federal air quality standards, including
Spokane County. PSD permits, issued by Ecology, require a detailed air quality analysis and the use of
Best Available Control Technology (BACT) to prevent deterioration of existing clean air conditions
(Washington State Department of Ecology, 2025).

General Order of Approval
Ecology issues General Order Permits for commercial sources of air pollution including asphalt plants,
autobody shops, concrete batch plants, dairy digesters, dry cleaners, rock crushers, water heaters, and
small boilers (Washington State Department of Ecology, n.d.). In Spokane County, these state-issued
permits are rarely used because SRCAA has jurisdiction and typically requires operators of these
commercial sources to obtain NOC permits.

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Climate and Air Quality
A combination of natural sources and human activity influences air quality. Cars, trucks, and other
fuel-burning equipment are the largest sources of transportation-related emissions, which can cause
localized and regional levels of CO, PM2.5, PM10, NO2, and O3. Spokane County currently meets all
federal standards for air quality; however, it remains in attainment for CO and PM10 due to past
exceedances (Washington State Department of Ecology, 2025). The expansion of roads and highways,
such as the new North Spokane Corridor, which is located in one of the most overburdened areas in
the city, can lead to increased localized levels of these pollutants, as more traffic and congestion in an
area releases pollutants from various vehicle-related processes (EPA, 2014).

Spokane is situated on the Columbia Plateau in northeastern Washington, near the foothills of the
Rocky Mountains to the north and east, and with the Cascade Mountains to the west. The area’s
climate is semi-arid, characterized by dry, hot summers and cold winters with occasional snowfall.
During summer, ground-level ozone, commonly referred to as smog, is more likely to become elevated
with high temperatures and sunlight.

Wind patterns in the region vary seasonally, with summer winds typically coming from the north or
northwest and winter winds often coming from the south or southwest. Average wind speeds are
usually below 10 miles per hour, and stagnant air conditions can cause pollutants to remain in the
region longer. Wildfire smoke is also a recurring concern in late summer and early fall, as large fires in
the northwestern U.S. and Canada can affect air quality (Spokane Regional Clean Air Agency, 2021),
(Spokane Regional Clean Air Agency, 2025).

Aside from wildfire events, poor air quality most often occurs during temperature inversions in the
cooler months when a layer of warm air traps colder air and pollutants close to the ground. These
inversions can linger for several days, and when stagnant conditions persist, SRCAA may temporarily
restrict outdoor burning (Spokane Regional Clean Air Agency, 2023)

Exhibit 3.2-4 shows relative exposures to PM2.5 and ozone across Spokane. Average levels of PM2.5
exceed the U.S. EPA’s recommended level of 9.0 micrograms per cubic meter across nearly all of
Spokane, though ozone levels are significantly below the EPA’s recommended threshold. As the
Spokane region experiences continued growth in population and economic activity, GHG emissions
and levels of criteria air pollutants are expected to rise. The increased emissions will amplify climate
hazards, such as extreme heat, wildfires, and wildfire smoke, posing serious and widespread risk to
public health and safety. While climate and air quality hazards will impact all of Spokane’s community
members, vulnerable populations and overburdened communities concentrated in neighborhoods
along the I-90 corridor, Northeast Spokane, South Hill, and the area where the North Spokane Corridor
is currently under development, will continue to be disproportionately impacted.

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Exhibit 3.2-4. Relative exposure to ozone (left) and PM2.5 (right) in Spokane.

Source: Spokane Climate Vulnerability Index, 2025.

Vulnerable populations in Spokane include children and caregivers, houseless residents, outdoor
workers, low-income households, pregnant people, older adults, residents with disabilities, Native
American and Tribal communities, communities in the Wildland Urban Interface (WUI), communities of
color, and people with chronic health conditions (City of Spokane, 2025). Addressing these disparities
is key to achieving climate justice and building a clean, resilient, and equitable Spokane.

Data and Methods

Greenhouse Gas Emissions
Emissions for greenhouse gases (GHGs) were quantified for each alternative, with the methodology
detailed below.

The project team collected data from the following sources:
1. U.S. Energy Information Administration
2. Spokane 2022 GHG Inventory
3. Spokane Regional Transportation Council
4. Census American Community Survey

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5. EPA GHG Emission Factors Hub

Using data from Spokane’s 2022 community GHG inventory, population and household estimates, and
employee counts, GHG emissions from energy consumption were estimated for the three land use
alternatives.

For commercial and industrial energy use, estimates for alternatives 1, 2, and 3 were developed by
calculating electricity and natural gas consumption in Spokane’s commercial and industrial sectors in
2022. These totals were divided by the number of employees in 2022 to generate an average energy
use per employee. This per-employee energy metric was then applied to the projected employment
capacity of each alternative to estimate total energy use. Emission factors for CO₂, CH₄, and N₂O, along
with their respective global warming potentials (GWPs), were used to calculate the resulting GHG
emissions.

A similar method was used to estimate residential energy-related emissions for each scenario.
Housing unit counts from 2022, broken down by housing type (single-unit, multi-unit, and
manufactured homes), were combined with regional average household energy consumption data
from the U.S. Energy Information Administration to establish differences in energy use by housing
type. This differential was used to estimate per-unit energy consumption in Spokane by housing type
for both natural gas and electricity. These estimates were applied to the projected number of single-
unit and multi-unit housing units under each alternative, and total consumption was multiplied by
fuel-specific emission factors and GWPs to estimate GHG emissions for each alternative.

To estimate emissions from transportation, a daily vehicle miles traveled (VMT) model from 2024 and
an annualization factor of 320 days were used to estimate annual VMT under each alternative. Vehicle
type breakdowns, including motorcycles, passenger vehicles, and light and heavy-duty trucks by fuel
type (gasoline and diesel), were derived from the 2022 inventory and applied proportionally to each
alternative’s estimated VMT. These projected VMTs were then multiplied by vehicle type-specific
emission factors and GWPs to calculate total transportation-related emissions for each alternative.

Other Pollutants
While the alternatives are expected to have varying air quality impacts, criteria pollutants such as
PM₂.₅, ozone, and NOₓ were not quantified and instead were assessed qualitatively. Sources to assess
and visualize pollutants in Spokane include:
 Spokane Climate Risk and Vulnerability Assessment
 Spokane Climate Vulnerability Index Map
 Washington Environmental Health Disparities Map

3.2.2 Impacts
Land use changes, including urban development and deforestation, can also impact air quality and
climate by altering natural carbon sinks, increasing VMT, and reducing vegetation that helps filter air

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pollutants. The following section provides an overview of how air quality might change across the
three alternatives based on the results of the air quality analysis.

Impacts Common to All Alternatives
All three proposed alternatives under the EIS must be evaluated through the lens of climate justice, as
climate-related air quality issues in Spokane disproportionately affect its most vulnerable and
overburdened populations, including Native American, Black, and Latino residents; low-income and
houseless individuals; youth and older adults; residents with disabilities or chronic health conditions;
outdoor workers; and those living in communities that bear a disproportionate share of
environmental hazards and have limited access to resources and decision-making power regarding
their environment.

These overburdened populations are more likely to live in areas with high concentrations of airborne
pollutants, heat island effect, and have limited access to healthcare facilities, health insurance, clean
indoor air, and cooling infrastructure. Systemic barriers, such as financial hardship, housing insecurity,
limited English proficiency, physical disabilities, and mental health struggles, can also limit these
groups from building resilience to withstand these conditions.

Air Quality Impacts
For all three scenarios, emissions from energy consumption and vehicle transportation will lead to air
quality issues and pollution burden throughout the city. This will especially be the base in areas with
closer proximity to major roads and highways. Several neighborhoods are already disproportionately
exposed to pollutants such as PM₂.₅ and ozone, a pattern that is especially evident in eastern Spokane,
including the Hillyard, Lincoln Heights, and Chief Garry Park neighborhoods.

Wildfire and Particulate Matter Exposure
One of Spokane’s most pressing climate justice and air quality concerns is the increase in wildfire
smoke, which has become a frequent and recurring hazard in the region. Driven by hotter, drier
summers and changing forest conditions, wildfire seasons have grown longer and more intense,
subjecting local communities to hazardous levels of fine particulate matter (PM2.5). Spokane has
experienced multiple years with days or even weeks of unhealthy or hazardous air quality, particularly
in late summer and early fall. According to the Spokane Climate Impacts and Climate Justice
Assessment (BERK Consulting, Inc.; Cascadia Consulting Group, 2025), Spokane County has had some
of the highest elevated particulate matter concentrations from wildfires in the state, and this trend is
projected to worsen as climate change continues.

Spokane’s vulnerable populations are less able to avoid, prepare for, or recover from wildfire and
wildfire smoke events. Low-income households, Tribal members, houseless individuals, and those with
chronic health conditions are more likely to live in areas with higher PM2.5 concentrations and have
less access to clean indoor air, healthcare to address impacts from poor air quality, and transportation

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to leave the region during smoke events. As wildfires increase in frequency and intensity, disparities in
exposure and resilience will continue to grow and compound existing health and climate justice issues.

Geographic Concentrations of Risk
Residents living in Northeast Spokane, South Spokane, and along the I-90 corridor in the West Plains
and Center City neighborhoods face elevated health risks associated with impaired air quality and
other environmental concerns (City of Spokane, 2025). Many of these residents belong to
overburdened groups, including Native American, Black, Latino, low-income, and disabled individuals,
as well as seniors and outdoor workers. Residents or workers in these areas face higher health risks
due to the proximity of air pollution sources, including major roadways and industry centers,
compounding the effects of wildfire smoke in the summer months.

Limited green space and tree canopy in these areas exacerbate heat island effects, while exposure to
traffic emissions increases impaired and often hazardous air quality. These conditions are
compounded by systemic barriers to healthcare and housing, which leave residents and workers along
the I-90 corridor particularly vulnerable to respiratory illness, heat-related health concerns, and other
chronic health impacts made worse by climate change.

Spokane’s Climate Risk and Vulnerability Assessment (CRVA) compiled geographic information on
exposure, sensitivity (health/environmental), and adaptive capacity to create a Climate Vulnerability
Index Map for community members and decision-makers to understand which parts of the city are
most vulnerable to the impacts of climate change when compared to the city average. This map can
also be used to inform which areas of the city are more at-risk of impacts from changes in air quality.
The following provides an area-specific evaluation of this data across Spokane:
 Northwest Spokane: Overall, Northwest Spokane’s Climate Vulnerability Index (CVI) ranges from very
low to very high, with very high areas concentrated in the central and northeastern part of the
area. Northwest Spokane also has higher exposure rates to PM2.5 in its eastern half and CO in its
western half. CO in Northwest Spokane is particularly high compared to other areas of the city.
 Northeast Spokane: In Northeast Spokane, the CVI also ranges from very low to very high, but most
of this area is high or very high, with very high concentrated in the northeastern part. This area
also has higher land surface temperatures in the summer compared to Northwest Spokane and
South Spokane. PM2.5 exposure levels are generally high across Northeast Spokane when
compared to the other study areas, and are highest in the eastern part of the area. CO exposure
levels are low in the western portion of Northeast Spokane, but higher in the eastern half.
 Division Corridor: In the Division Corridor, the CVI ranges from very high to very low, with most
areas ranging from moderate to very low. However, the corridor has higher land surface
temperatures in the summer when compared to Northeast Spokane and South Spokane. PM2.5
exposure is higher along the corridor than in many other parts of the city, while CO is generally low
compared to the rest of the city.
 Center City: Overall, Center City’s CVI is mostly very low, with a small area being low in the southern
part and very high in the northeastern part. PM2.5 exposure is higher across Center City, while the
exposure level for CO is low.

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 South Spokane: In South Spokane, the CVI is mostly very low, with very high being located around
Highway 195 and just south of I-90 in the northeastern part of the area. PM2.5 exposure levels
range from low to high compared to the rest of Spokane, with the highest levels being in the
northeastern part of the city. CO, on the other hand, is highest in the southern and western parts
of the area.
 West Plains: The CVI in West Plains is very low; however, this area has some of the city’s highest land
surface temperatures during summer and has high exposure levels of CO.

Although direct environmental and climate impacts of each alternative may vary, these underlying
vulnerabilities will persist, and disparities may widen if appropriate considerations are not evaluated
and integrated. Climate justice considerations related to air quality and equitable access to healthcare,
housing, and resilience-building resources must be at the center of EIS alternatives planning and
implementation. Climate justice, equity, and resilience considerations specific to each alternative will
be discussed in the following sections.

Greenhouse Gas Emissions Impacts

Despite higher VMT when compared to the 2024 baseline, all alternatives show a net decrease in
transportation emissions by 2046. This reduction is primarily driven by statewide policy assumptions,
including the 2035 ban on internal combustion engine sales and the 2030 clean-electricity mandate.
When modeled with a 15-year vehicle lifespan (full EV Adoption), these policies result in faster paced
vehicle turnover and substantial emissions reductions (Exhibit 3.2-5).

Exhibit 3.2-5. Transportation Emissions Summary (MTCO2e).
ASSUMPTION 2024 2046 ALT 1 2046 ALT 2046 ALT
2 3
Full EV Adoption 535,500 63,971 61,949 64,791
Moderate EV Adoption 535,500 210,139 203,279 210,647
Current Mix 535,500 738,370 714,036 737,853

Source: Cascadia Consulting Group, 2025.

To account for potential differences in EV adoption, two additional scenarios were evaluated: a
moderate EV adoption case using a 25-year vehicle lifespan, which may model Spokane’s typical
vehicle replacement patterns more accurately, and a scenario in which today’s internal-combustion
vehicle mix remains unchanged Exhibit 3.2-6

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Exhibit 3.2-6. Emissions from community transportation under three scenarios: one with full EV
adoption (assuming a 15-year vehicle lifespan), one in which the current internal-combustion
vehicle mix remains constant, and one with a moderate EV adoption rate (assuming a 25- year
lifespan).

Source: Cascadia Consulting Group, 2025.

The 2030 clean-electricity mandate significantly reduces community energy emissions across all
alternatives when compared to the 2024 baseline. Exhibit 3.2-7 summarizes projected 2046 energy
emissions for each alternative.

Exhibit 3.2-7. Energy Emissions Summary (MTCO2e).
2046 ALT 1 2046 ALT 2 2046 ALT 3
609,942 582,691 611,011

Source: Cascadia Consulting Group, 2025.

Differences in energy emissions between the three growth alternatives are driven largely by projected
changes in residential housing stock and employment capacity (Exhibit 3.2-8).

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Exhibit 3.2-8. Emissions associated with each alternative, by sector.

Source: Cascadia Consulting Group, 2025.

Alternative 1: No Action, Stay the Course
Alternative 1 produces the highest emissions for both community energy and transportation. Higher
projected employment capacity and a lower proportion of multifamily housing lead to elevated energy
consumption in 2046.

Transportation emissions are also greatest in this alternative due to the highest projected VMT and the
lowest share of walking, biking, and transit trips. This car-dominant pattern reduces mobility for
residents without vehicle access and increases housing scarcity due to limited multifamily options.

Alternative 2: Distributed and Balanced
Alternative 2 results in the lowest energy and transportation emissions across all scenarios.
Transportation emissions decline due to the lowest VMT and a reduced share of trucks and heavy-duty
vehicles.

Energy emissions also decrease, driven by a larger share of multifamily housing and the lowest
projected commercial and industrial employment capacity. Compared to Alternative 1, this alternative
supports greater transportation choice and expanded multifamily housing options. However, one
potential tradeoff is a more competitive job market due to reduced employment growth.

Alternative 3: Center City and Regional Hubs
Alternative 3 results in emissions lower than Alternative 1, but slightly higher emissions than
Alternative 2. Energy emissions are influenced by the highest projected employment capacity among

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all alternatives, although the emphasis on multifamily housing alleviates overall energy demand
relative to Alternative 1.

Transportation emissions are slightly lower than those in Alternative 1 due to marginally reduced VMT,
but higher than those in Alternative 2. Overall, Alternative 3 represents a middle ground between the
higher-emissions No Action alternative and the lower-emissions Alternative 2 Distributed and
Balanced model.

3.2.3 Mitigation Measures

Incorporated Plan Features
The 2017 Comprehensive Plan for the City of Spokane outlines goals and policies to protect the natural
environment, including clean air and reducing pollution from transportation (City of Spokane, 2017).
Under the action alternatives, the City will update its Comprehensive Plan policies related to land use,
transportation, and others that could protect the city from major air emission sources. This update will
also include the addition of climate planning, now mandated by the Washington State Growth
Management Act, to integrate climate considerations into every aspect of the city’s future (City of
Spokane, 2025).

Regulations and Commitments

Air Quality
 NAAQS: The EPA enforces the CAA, which establishes the NAAQS for six criteria pollutants and sets
emissions standards for vehicles and fuels, stationary industrial facilities, and hazardous air
pollutants.
 Washington State: Ecology develops and implements plans to ensure compliance with NAAQS and
has established state ambient air quality standards. Washington State has also enacted the
Washington Clean Air Act.
 State Implementation Plan: The EPA reviews and approves Washington’s State Implementation
Plan, which provides tools to restore air quality and meet NAAQS when one or more pollutants are
not in compliance.
 SRCAA Regulations: SRCAA’s core air quality regulatory code—Regulation I—incorporates federal
and state standards, while including specific requirements for air quality measures within the
county.
 SRCAA is tasked with air quality monitoring, enforcement inspections, permitting, and outreach
with Spokane County.
 Washington State Department of Health also shares air quality data with the public and provides
public education on hazards.

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Greenhouse Gases & Climate Change
 Washington State: The State has enacted the Climate Commitment Act to cap and reduce statewide
GHG emissions with a goal of achieving a 95% reduction by 2050. The State has also established
the Clean Energy Transformation Act, which commits the state to emissions-free electricity by
2045. The State’s Clean Buildings Performance Standard, Clean Buildings Act, energy codes, and
zero-emission vehicle standards will also help the State and Spokane reduce greenhouse gas
emissions.
 Spokane’s 2021 Sustainability Action Plan: In 2021, the City updated its 2009 Sustainability Action
Plan to address environmental and climate-related requirements at the local and State levels. Since
the 2009 plan was adopted, the City adopted a goal of achieving 100% renewable electricity by
2030, and the State enacted legislation requiring the City to have 100% renewable electricity by
2045 and to have 30-year GHG reduction targets with an interim stepped approach. The updated
plan provides guidance on achieving these requirements while mitigating risks from climate
change and investing in strengthening Spokane communities.

Other Potential Mitigation Measures
No significant unavoidable adverse impacts on air quality and GHG emissions are expected; however,
the following mitigation strategies can be implemented to address the potential exposure of residents
and other sensitive areas of the city to criteria air pollutants.

Transportation-Related Emissions and Pollutants
In 2022, transportation emissions accounted for 41% of the city's communitywide GHG emissions,
making it the second largest source. These emissions also significantly contribute to PM2.5 and CO
levels, and the new North Spokane Corridor could cause higher levels of criteria air pollutants in
nearby areas. Actions to reduce emissions and pollutants from transportation include:
 Expanding multi-modal pathways, facilities, and public transit services to encourage residents to
walk, bike, roll, or use public transportation and reduce VMT from single-occupancy vehicles.
 Implementing roadway fees, tolls, or congestion pricing to reduce traffic congestion, especially
during peak travel times on key road segments.
 Increasing land use mix and density of the city to reduce the need for vehicle ownership and
shorten trip distances.
 Supporting electric vehicle or zero emissions vehicle adoption through expanding charging options
and providing incentives.

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Building-Related Emissions
Energy use was the largest source of emissions in 2022, making up 48% of Spokane’s communitywide
emissions. Most of these emissions came from using electricity, natural gas, and other fossil fuels in
residential, commercial, and industrial buildings. Actions to help reduce building and energy emissions
include supporting and incentivizing building owners to switch from fossil fuels to electric options,
adopting rooftop solar and battery storage, and improving building efficiency through retrofits.
The City can assist building owners in implementing each of these measures by:
 Strengthening building codes and standards, including requiring high efficiency in new
construction, energy performance standards for existing buildings, and phasing out fossil fuels in
new construction.
 Offering rebates, low-interest loans, or grants for equipment and retrofits or working with Avista to
provide these to building owners.
 Conducting education and outreach to the public to inform them of the benefits of improving
building efficiency and going electric or working with Avista on these efforts.
 Offering expanded weatherization assistance programs for low-income households with partner
organizations. This could include expanding programs to offer electrification options, solar panels,
battery storage, or other opportunities that reduce building emissions and increase energy
efficiency.

Additional Potential Mitigation Measures
The City can also implement the following measures to improve air quality for residents:
 Designate truck routes that serve industrial, manufacturing, and commercial areas away from
residential areas.
 Protect and enhance tree canopies and natural landscapes and plant more trees near heavy traffic
corridors and industrial areas.
 Increase street sweeping across the city and incorporate or improve standards to reduce dust
associated with high traffic corridors and construction sites.
 Amend development standards for buildings and air filtering near air pollution sources like
freeways.
 Adopt new development and building codes and require or incentivize air filtering and circulation
in residences, schools, hospitals, and other sensitive and vulnerable building types or areas.
 Increase education and outreach on the risks associated with air pollutants and how residents can
protect themselves.

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3.2.4 Significant Unavoidable Adverse Impacts
No significant unavoidable adverse impacts on air quality and GHG emissions are expected. By
implementing mitigation measures, supporting local and state climate initiatives, and through ongoing
regulatory changes, the alternatives could lead to lower GHG emissions on a per capita basis
compared to current conditions. The alternatives would not hinder statewide, regional, or local efforts
to reduce GHG emissions. Although each option would produce GHG emissions from growth and
development within the city, focusing development in targeted areas potentially offsets these impacts
by preventing development in peripheral regions of the city.

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3.3 Plants and Animals
Habitat loss, fragmentation, and degradation create substantial challenges for fish and wildlife
populations throughout Washington. In large part, these habitat impacts are associated with the urban
and suburban development that will continue to support the state’s increasing human population. As
urban communities continue to grow, habitat can become more fragmented and less available. This
section discusses important fish and wildlife species, vegetated habitats in the City of Spokane and
surrounding study area, and the potential impacts of the three Alternatives on these resources.

Thresholds of significance utilized in the impact analysis in this section include:
 An alternative would be inconsistent with or counter to best available science.
 An alternative may have adverse effects to state or federally listed threatened or endangered
species or their habitats that could not be sufficiently addressed through avoidance, minimization,
or mitigation measures, and could potentially result in an up-listing or jeopardy determination.
 An alternative could have population-level adverse effects to other important non-listed plant or
wildlife species (e.g., priority species, migratory birds) that would be perceptible and measurable
within the surrounding region.
 An alternative would potentially result in permanent habitat conversion, or loss of habitat
connectivity sufficient to compromise overall regional ecosystem function relative to current
conditions.

The identified thresholds of significance were used to determine whether the alternatives would have
a significant impact on fish, wildlife, and vegetation.

3.3.1 Affected Environment

General Habitat Setting

Terrestrial Habitats
Spokane is located at a transition zone between the Columbia Plateau and Columbia
Mountains/Northern Rockies ecoregions (NatureServe Explorer 2025), and thus the vegetated habitats
are representative of a transition zone between montane forest and shrubsteppe ecosystems.
Ponderosa pine (Pinus ponderosa) dominates lowland forests in the study area and surrounding
region, with juniper/sage understory in drier zones. Spokane’s hills and bluffs are dominated by a mix
of Ponderosa pine and Douglas‑fir (Pseudotsuga menziesii), with bunchgrasses and shrubs dominating
the ground layer and understory (Fryer 2016). Patches of shrubsteppe habitat are dispersed
throughout the city, with large patches most prevalent in the West Plains area. Shrubsteppe
communities are arid ecosystems dominated by drought tolerant shrubs such as rabbitbrush
(Chrysothamnus viscidiflorus) and sagebrush (Artemisia spp.) with interspersed grasses. Shrubsteppe
ecosystems are highly biodiverse and provide habitat for species found nowhere else in Washington,
such as the Greater sage-grouse (Centrocercus urophasianus), sagebrush sparrow (Artemisiospiza

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nevadensis), and burrowing owl (Athene cunicularia). An estimated 80% of historic shrubsteppe has
been lost or degraded by development and agriculture since the arrival of non-native settlers (WDFW
2025a). The Washington Department of Fish and Wildlife has developed a mapping tool and strategy
identifying xeric (dry) and mesic (wet) shrubsteppe habitats and priorities. There are patches of xeric
habitats and some corridors of mesic habitat along streams and rivers identified as “other” than the
core habitat which are more degraded but have opportunities for conservation and enhancement.
(Washington Shrubsteppe Restoration and Resiliency Initiative, 2024)

Vegetation in the developed urban areas of the city is typical of urban environments, consisting largely
of grass lawns, landscape plantings, and streetscape vegetation, including street trees. Parks provide
blocks of vegetated open space distributed throughout the city. Tree canopy coverage varies widely
among the neighborhoods in Spokane. A 2021 report by Gonzaga University found that tree canopy
coverage ranged from 7.8% in the Riverside neighborhood, which spans portions of Center City and
Northwest Spokane, to 38.5% in the Manito neighborhood in South Spokane. Average canopy
coverage was estimated at 20% citywide (Manthey et. al. 2021). The City of Spokane’s Urban Forestry
division sponsors a tree planting program called SpoCanopy, which has a goal of achieving 30% forest
canopy coverage in every neighborhood in Spokane by 2030 (Spokane Urban Forestry, 2025).

Common noxious weed species in the study area and surrounding region are shown in Exhibit 3.3-1.
Noxious weeds are invasive plants that have been accidentally or intentionally introduced outside of
their native range and are highly destructive to native plant and animal habitat, difficult to control by
cultural or chemical practices, and can reduce crop yields, damage recreational sites, lower land
values, and poison humans and/or livestock.

Class A noxious weeds are those whose distribution is still limited. Preventing new infestations and
eradicating existing infestations is required by state law. Class B noxious weeds are limited to portions
of Washington State but may be widespread elsewhere. They are designated for mandatory control in
regions where they are not yet widespread. In areas where Class B weeds are already abundant,
containment is the primary goal, and control is decided at the local level. Class C noxious weeds are
non-native species that are already widespread in Washington and long-term programs of
suppression and control are a local option (Washington State Noxious Weed Control Board 2025;
Spokane County Noxious Weed Control Board 2025).

Exhibit 3.3-1. Noxious Weeds in the Study Area and Surrounding Region
Common Name Scientific Name Class

Flowering Rush Butomus umbellatus A
Garlic Mustard Alliaria petiolata A
Goatsrue Galega officinalis A
Marsh thistle Cirsium palustre A
Palmer Amaranth Amaranthus palmeri A
Wild Four O’Clock Mirabilis nyctaginea A

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Common Name Scientific Name Class

Brown Knapweed Centaurea jacea B1
Garden Loosestrife Lysimachia vulgaris B1
Herb-Robert Geranium robertianum B1
Hoary Alyssum Berteroa incana B1
Musk Thistle Carduus nutans B1
Myrtle Spurge Euphorbia myrsinites B1
Perennial Pepperweed Lepidium latifolium B1
Policeman’s Helmet Impatiens glandulifera B1
Puncturevine Tribulus terrestris B1
Russian Knapweed Rhaponticum repens B1
Saltcedar Tamarix ramosissima B1
Scotch Broom Cytisus scoparius B1
Velvetleaf Abutilon theophrasti B1
Wall Subgenus Hawkweed Hieracium (yellow-flowered) B1
White Bryony Bryonia alba B1
Wild Chervil Anthriscus sylvestris B1
Yellow Starthistle Centaurea solstitialis B1
Blueweed Echium vulgare B
Common Bugloss Anchusa officinalis B
Dalmatian Toadflax Linaria dalmatica B
Orange Hawkweed Hieracium aurantiacum B
Diffuse Knapweed Centaurea diffusa B
Spotted Knapweed Centaurea stoebe B
Kochia Bassia scoparia B
Leafy Spurge Euphorbia virgata B
Purple Loosestrife Lythrum salicaria B
Rush Skeletonweed Chondrilla juncea B
Scotch Thistle Onopordum acanthium B
Buffalobur Solanum rostratum C
Canada Thistle Cirsium arvense C
Common Barberry Berberis vulgaris C
Hoary Cress Lepidium draba C
Oxeye Daisy Leucanthemum vulgare C

Note: 1 Denotes Class B Designate weeds, which are not yet widespread and therefore mandated for control.
Source: Spokane County Noxious Weed Control Board 2025; Washington State Noxious Weed Control Board 2025.

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Overall, the land cover types in present-day Spokane are reflective of the human development
activities and land conversion that have taken place on the city’s landscape over time. Forest clearing
and conversion of native grassland for small farms and residences began in what is now Spokane in
the late 1800s. Population and related land conversion increased in conjunction with railroad
development beginning in 1881. Development of industrial uses along the banks of the Spokane River
began in the late 1880s with construction of grist mills, lumber mills and, subsequently, dams for
electricity generation. From the mid- to late 20th century, rural areas underwent conversion to
suburban land uses as automobile mobility shifted development patterns away from the dense urban
core, facilitating more dispersed land use patterns (Spokane Historic Preservation Office 2025). Most
of the productive agricultural lands, forested hillsides, and shrubsteppe habitats remaining within the
study area are in areas nearer to the outer periphery of Spokane or outside the City’s boundary in its
UGA (USGS 2023). Land cover types in the study area, and their prevalence on the landscape, are listed
in Exhibit 3.3-2 and shown in Exhibit 3.3-3.

Exhibit 3.3-2. Land Cover Types in the Study Area

NLCD Land Cover Type Acres Percentage of
Total Study
Area

Barren Land (Rock/Sand/Clay) 0.22 0.00%
Cultivated Crops 570.89 0.89%
Deciduous Forest 1.11 0.00%
Developed, High Intensity 4796.47 7.49%
Developed, Medium Intensity 18415.43 28.75%
Developed, Low Intensity 21909.67 34.21%
Developed, Open Space 5875.48 9.17%
Emergent Herbaceous Wetlands 99.25 0.15%
Evergreen Forest 3197.03 4.99%
Grassland/Herbaceous 3176.38 4.96%
Open Water 384.88 0.60%
Pasture/Hay 322.02 0.50%
Shrub/Scrub 5174.66 8.08%
Woody Wetlands 122.96 0.19%

TOTAL 64,046.45 100.00%

Source: USGS 2023.

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Exhibit 3.3-3. Land Cover Types in the Study Area

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Aquatic and Riparian Habitats
Aquatic habitats in the study area are predominantly associated with the Spokane River and Latah
Creek, a major Spokane River tributary and the largest within Spokane city limits. The Little Spokane
River, the largest tributary of the Spokane River, forms approximately 1.4 miles of the study area’s
northern boundary, within the city’s Urban Growth Area (UGA) but outside the city limits. A short
segment (approximately 950 feet) of Marshall Creek flows through the far southwestern portion of the
South Spokane region of the study area, in the Latah Valley neighborhood. Riparian habitats –
vegetated communities that represent a transition between aquatic and terrestrial ecosystems - are
primarily adjacent to the major water corridors of the Spokane River and Latah Creek. Wetlands in the
study area are likewise mostly associated with the Spokane River and Latah Creek systems. Additional
isolated wetlands, ponds, and small tributary streams are interspersed throughout the study area,
most prevalently in South Spokane (USFWS 2025a).

Riverine and stream habitats within the study area, particularly those associated with the Spokane
River and Latah Creek, are affected by the close proximity of urban development, which often directly
abuts or encroaches on vegetated riparian buffers and has filled former wetland and floodplain
habitat areas. The Spokane River watershed is facing many issues that damage habitat and reduce
water quality such as stormwater runoff, loss of wetland habitat, streambank erosion, and historic use
of toxic chemicals. The Spokane River has also been substantially affected by the construction of
dams, both within and outside the city limits. A total of seven dams have been constructed on the
Spokane River, from Post Falls Dam at the outlet of Lake Coeur d’Alene to Little Falls Dam at river mile
(RM) 29 (Ecology 2025a). Latah Creek experiences elevated water temperatures, high levels of
sediment, and flashy high flow events, all of which harm native fish, largely due to removal of
shoreline forests. Other issues in Latah Creek include nonpoint pollution from farming and ranching
upstream from Spokane, which contribute contaminants that adversely affect native fish and aquatic
organisms. Key contributing sources of contamination also include stormwater runoff and wastewater
discharges (Ecology 2020, Ecology 2025b, Spokane Riverkeeper 2025b).

Riparian habitats in the study area are frequently dominated by invasive reed canarygrass (Phalaris
arundinacea), with scattered scrub-shrub communities of black hawthorn (Crataegous douglasii), red-
osier dogwood (Cornus stolonifera), willows (Salix spp.), and occasional black cottonwoods (Populus
trichocarpa). The current status of these habitats provides little diversity and value for the wildlife and
fisheries. Natural riparian plant associations in the study area, such as those found in the basalt
canyon area of Latah Creek, include well-established stands of black cottonwoods, hardstem bulrush
(Scirpus acutus), quaking aspen (Populus tremuloides), mountain alder (Alnus incana), and various scrub-
shrub communities. (Spokane Conservation District 2012).

Latah Creek is known for its overall poor aquatic and riparian habitat quality. In early 2018,
Washington Department of Ecology (Ecology) and Spokane Riverkeeper reached a settlement
agreement that requires Ecology to take specific actions, including:
 Complete a full analysis of the creek’s health including streamside vegetation and instream
conditions within Washington State boundaries.

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 Identify, prioritize, and fix water quality problems through focused Best Management Practice
(BMP) implementation.
 Monitor the creek’s health and track progress of improvements; and
 Develop and implement an education and outreach plan. (Ecology 2025c).

Ongoing efforts are also under way to restore riparian habitat along the Spokane River, led by
numerous proponents including Spokane Conservation District, Gonzaga University, the Lands
Council, and various other non-governmental organizations. These restoration efforts are often
undertaken in partnership with private landowners. Projects have included installation of native
riparian plantings, wetland and floodplain restoration, and placement of woody debris to stabilize the
riverbank (Inland Northwest Land Conservancy 2016, Spokane Conservation District 2025, Lands
Council 2025).

Designated Habitats: Shorelines, Floodplains, Wetlands, and Priority Habitats

Shorelines
Shorelines contain valuable natural resources, provide natural scenic qualities, support important
ecological functions and processes, and/or can also present potential hazards to human life and
property. Shorelines in Spokane are regulated under Spokane Municipal Code Chapter 17E.060,
Shoreline Regulations, with the purpose of avoiding impacts to these areas from alteration wherever
feasible and reasonable. Designated shorelines of the state are limited to the Spokane River and Latah
Creek. Development within 200 feet of the ordinary high water mark along these streams is heavily
restricted and allowed only as authorized according to the Spokane Shoreline Master Program.
Shorelines in the study area are shown in Exhibit 3.3-4 below.

Wetlands
Mapped wetlands in the study area are shown in Exhibit 3.3-4 The majority of wetlands in the study
area are associated with the Spokane River and Latah Creek. Additionally, isolated wetland areas exist
in scattered locations throughout the study area, mostly in the South Spokane and West Plains study
areas. All development and uses are generally prohibited from wetlands and wetland buffers, except
as authorized by federal, state, and local regulations. In general, limitations on allowable impacts and
the required widths of wetland buffers are directly related to the habitat quality and the critical
importance of the wetland resource – for example, if it is directly associated with a Shoreline of the
State and/or fish-bearing streams - and the integrity of ecological function provided. Wetlands in the
City of Spokane are regulated under SMC 17E.070.

Floodplains
Floodplains provide benefits to functioning natural systems, including fish and wildlife habitat
protection, enhanced biological productivity, natural flood storage and erosion control, surface water
quality maintenance, and groundwater recharge (FEMA 2024). Most floodplain resources in the study

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area are concentrated along the Spokane River and Latah Creek, often co-occurring with riparian and
wetland ecosystems in these areas. Relatively small and interspersed areas of regulated floodplains
are distributed in small areas in South Spokane (WDFW 2025c; WDNR 2025; FEMA 2025). Floodplains in
Spokane are regulated under SMC Chapter 17E.030. Mapped floodplains in the City of Spokane are
shown in Exhibit 3.3-4. See Section 3.1 Earth, Water Quality, and Water Resources, for additional
discussion of floodplains.

Priority Habitats
Priority habitats are identified by the Washington Department of Fish and Wildlife (WDFW) as habitat
types or elements with unique or significant value to one or more species, for which special
conservation measures should be taken (WDFW 2025b). A priority habitat may consist of a unique
vegetation type like shrubsteppe, a dominant plant species, or a specific habitat feature (e.g., cliffs). In
general, priority habitats with greater importance to fish or wildlife have one or more of these
characteristics (WDFW 2023):
 Habitat areas that are larger generally support greater biodiversity and ecosystem function than
areas that are smaller, because they can support sensitive species, species that require large areas,
and more resilient wildlife populations.
 Habitat areas with more structural complexity (e.g., multiple canopy layers, snags, geologically
diverse) provide a greater diversity of habitat types and support higher species diversity than areas
with less complexity.
 Areas that contain different native habitat types contiguous with one another provide for greater
ecosystem function and biodiversity than isolated habitats, because they support species that use
multiple habitat types for different activities or life cycle stages (especially aquatic habitats
associated with terrestrial habitats),
 Habitat areas that are connected, as opposed to areas that are isolated, provide better pathways
for wildlife to move between biodiversity areas. This movement supports critical ecosystem
functions including plant and animal movement to access food, water, shelter, and breeding
habitat; adaptation to climate change; and gene flow.
 Habitat areas that have maintained continuity in historical ecosystem processes (e.g., disturbance
regimes, successional patterns) generally exhibit greater ecosystem function and habitat
complexity, and better support the long-term health of wildlife populations, than areas lacking
such processes.

The study area has one large block of identified priority habitats extending along the west side of the
City of Spokane from the southern boundary of the Latah/Hangman neighborhood in South Spokane,
through the eastern portion of the West Plains, and along the Spokane River corridor on the western
boundary of Northwest Spokane. Priority habitats throughout this area are largely identified as
northwest white-tailed Deer and mule deer winter range. Intermittent patches of shrub-steppe habitat
are also interspersed throughout this larger contiguous block of priority habitat. The Latah Creek and
Spokane River corridors are identified as biodiversity areas and corridors. Biodiversity areas and
corridors consist of relatively undisturbed and unbroken tracts of vegetated habitat connecting fish

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and wildlife populations. Other concentrations of priority habitat include Biodiversity Areas and
Corridors associated with the Five Mile Prairie area on the northern fringe of Northwest Spokane, a
block of priority habitat in the Hilyard neighborhood of Northeast Spokane identified as shrubsteppe
habitat and biodiversity areas and corridors, and a relatively large contiguous area of shrubsteppe
habitat in the western portion of the West Plains region (WDFW 2025c; WDNR 2025). Mapped priority
habitats in the study area are shown in Exhibit 3.3-4.

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Exhibit 3.3-4. Natural Resource Designations in the City of Spokane

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Locally Specific Habitat Conditions

Northwest Spokane
The Spokane River forms the western boundary of most of the Northwest Spokane area. As a result,
priority habitat areas, floodplains, and wetlands associated with the river extend along the west side of
this region from the West Central neighborhood in the south to the northern boundary of the
Northwest study area in the north. Small remnant patches of shrubsteppe of one acre or less in size
are scattered throughout this region of the study area. Larger areas of shrubsteppe exist near the
northern boundary of the city in the North Indian Trail and Balboa/South Indian Trail neighborhoods.
Identified biodiversity areas and corridors exist in the Balboa/South Indian Trail and Five Mile Prairie
neighborhoods (WDFW 2025c). Land cover types in Northwest Spokane are classified primarily as
“developed, high intensity” and “developed, medium intensity” in the eastern and southern portions of
the region closer to the Division Corridor and Center City. Land cover classifications transition to a
higher proportion of “developed, low intensity” and “developed, open space” in the western and
northern portions of this region, with patches of evergreen forest and scrub-shrub classifications
along the western and northwestern perimeter (USGS 2023). Spokane City Council District 3, which is
largely coterminous with Northwest Spokane, was found to have overall tree canopy coverage of
20.8%, roughly matching the City average. (Manthey et. al. 2021). See Exhibit 3.3-5.

Northeast Spokane
The Spokane River passes through the southern portion of the Northeast Spokane region, forming the
northern boundary of the Chief Garry Park neighborhood. There are few areas of priority habitat in
Northeast Spokane, with the exception of the Hillyard neighborhood and areas adjacent to the
Spokane River. No mapped waters, wetlands, or floodplains exist in Northeast Spokane, aside from
those associated with the river. Land cover in this region of the study area is predominantly classified
as “developed, medium intensity” interspersed with “developed, low intensity.” Concentrations of
“developed, high intensity” land cover types are located along the SR 290 corridor and along E Francis
Avenue as it approaches the Division Corridor. Open space areas, along with small areas classified as
“scrub/shrub,” “pasture/hay,” and “evergreen forest” are confined to the northern and eastern
periphery of Northeast Spokane (USGS 2023). Spokane City Council District 1, which is largely
coterminous with Northeast Spokane and has a high population with social vulnerability, was found to
have the lowest overall tree canopy coverage of the city’s three council districts, at 13.9% (Manthey et.
al. 2021). See Exhibit 3.3-5.

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Exhibit 3.3-5. Tree Canopy Cover by Neighborhood in the City of Spokane

Source: (The Lands Council, 2023)

Division Corridor
The Division Corridor extends northward from Center City, straddling the boundary between
Northeast and Northwest Spokane along a major arterial corridor. The landscape is characterized
primarily by low-rise urban commercial development and large paved areas. Land cover along the
Division Corridor is classified predominantly as “developed, high-intensity” in the south. North of
Center City and extending to its northern boundary, land cover in the Division Corridor consists of
“developed, high intensity” along N Division Street, with a blend of “developed, medium intensity” and
“developed, low intensity” land cover types at distances further than 500 feet from N Division Street
(USGS 2023). Shoreline areas and floodplains associated with the Spokane River are present at the
southern end of the Division Corridor where it overlaps with Center City; no waters or wetlands are
present elsewhere in the corridor. Four small areas of remnant shrubsteppe habitat, each less than a
half-acre, are identified west of N Division Street in the northern half of the corridor (WDFW 2025c).
Tree canopy coverage along the Division Corridor approximates that of Northeast Spokane, with lower
percentages of canopy cover at the southern end of the corridor (Manthey et. al. 2021). See Exhibit
3.3-5.

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Center City
Center City is heavily developed, with low vegetative cover and low percentages of tree canopy cover
compared to other study areas (USGS 2023; Manthey et. al. 2021). See Exhibit 3.3-5. Designated
shoreline areas and FEMA regulated floodplains are present adjacent to the Spokane River. Land cover
types in the Center City are predominantly classified as “developed, high Intensity” and secondarily as
“developed, medium intensity.” Areas classified as “developed, low intensity” and “developed, open
space” exist along the Spokane River and near the Center City’s southern periphery (USGS 2023).

South Spokane
The South Spokane region contains the largest area of priority habitats among the six identified study
areas of the city. Priority habitats are most heavily concentrated in the western portions of South
Spokane, in the Latah/Hangman and Grandview/Thorpe neighborhoods. All of the shoreline areas,
floodplains, and wetlands associated with Latah Creek are located within the boundaries of the
Latah/Hangman neighborhood (WDFW 2025c; USFWS 2025a). Land cover in most of South Spokane
outside of the Latah/Hangman and Grandview/Thorpe neighborhoods is classified as “developed, low
intensity” and “developed, open space.” Areas of relatively denser development along major roadway
corridors in the Southgate, Lincoln Heights, and Comstock neighborhoods are classified as “developed,
medium intensity” and “developed, high density” (USGS 2023). Large portions of the land cover in the
Latah/Hangman and Grandview/Thorpe neighborhoods are classified as scrub/shrub or evergreen
forest. Areas classified as “developed, medium intensity” and “developed, low intensity” are present
along the US 195 corridor. Together with the West Plains region, the South Spokane region makes up
Spokane City Council District 2, which was found to have the highest overall tree canopy coverage of
the city’s three council districts, at 24.9% (Manthey et. al. 2021). See Exhibit 3.3-5.

West Plains
The West Plains region contains substantial areas of mapped shrubsteppe habitat and mule deer and
white-tailed deer winter range. Numerous palustrine emergent wetlands are scattered throughout the
eastern and southern portions of this region. Land cover in the areas surrounding Spokane
International Airport and along US 2 is classified as a mixture of “developed, high intensity” and
“developed, medium intensity.” The remainder of this region is largely classified as scrub/shrub or
grassland/herbaceous, with interspersed areas of cultivated crops, pasture, developed open space,
and evergreen forest (USGS 2023). Together with the South Spokane region, the West Plains region
makes up Spokane City Council District 2, which was found to have the highest overall tree canopy
coverage of the city’s three council districts, at 24.9% (Manthey et. al. 2021). See Exhibit 3.3-5.

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Fish and Wildlife

General Wildlife
Wooded areas and other urban vegetated habitats in the City of Spokane support a wide variety of
mammals, birds, reptiles, and amphibians. Common mammals within the study area include small
rodents such as chipmunks and squirrels; larger rodents including porcupines and marmots; moles,
shrews, rabbits, raccoons, skunks, and various species of bat. Wetlands and riparian areas support
semi-aquatic mammals such as muskrat (Ondatra zibethicus), beaver (Castor canadensis), and river otter
(Lontra canadensis). Larger mammals including mule deer (Odocoileus hemionus hemionus), northwest
white-tailed deer (Odocoileus virginianus ochrourus), and coyote (Canis latrans) can also be found within
the study area. (WDFW 2025d; Burke Museum 2025a). These species tolerate varying levels of urban
development as long as some habitat and connecting migration corridors remain undisturbed. The
number and diversity of species declines in direct relation to the size of habitat patches and their level
of isolation from other natural areas (Hennings and Soll 2010; Krausman et. al. 2008).

Numerous species of migratory songbirds rely on the habitat provided by larger wooded areas in
Spokane. Smaller wooded tracts, parks, and open spaces may provide temporary foraging or
migratory habitat within the urban areas of Spokane. Portions of the Spokane River and Latah Creek
drainages provide suitable habitat for aquatic bird species including mallards (Anas platyrhynchos),
American wigeons (Mareca americana), green-winged teal (Anas carolinensis), blue-winged teal (Spatula
discors) common merganser (Mergus merganser) and other ducks; as well as other birds associated
with aquatic environments such as great blue heron (Ardea herodias), and Canada goose (Branta
canadensis). Species such as savannah sparrow (Passerculus sandwichensis), ruffed grouse (Bonasa
umbellus), Ring-necked Pheasant (Phasianus colchicus), and wild turkey (Meleagris gallopavo) can be
found in shrubsteppe areas of the West Plains (eBird.org 2025).

Common reptiles and amphibians found in the study area include various native lizard species such as
common sagebrush lizard (Sceloporus graciosus), western fence lizard (Sceloporus occidentalis),
northern alligator lizard (Elgaria coerulea), western toad (Anaxyrus boreas), and several species of
salamanders (Ambystoma spp.) (Burke Museum 2025b). Invasive American bullfrog (Lithobates
catesbeianus) has become established throughout wet lowland environments of eastern Washington,
including in the various ponds and wetlands throughout South Spokane (Mulvany 2019)

Fish and Aquatic Species
Streams in the study area that are recorded as fish-bearing include the Spokane River, Latah Creek,
Little Spokane River, and Marshall Creek (SWIFD 2025; Visit Spokane 2025). While Latah Creek and
Marshall Creek are not currently recorded to have any fish species present, the Spokane River and
Little Spokane River provide habitat for a number of native and non-native fish species. Native fish
documented in the Spokane River system within the study area include Westslope cutthroat trout
(Oncorhynchus lewisi), Redband trout (Oncorhynchus mykiss gairdneri), Rainbow trout (Oncorhynchus
mykiss), mountain whitefish (Prosopium williamsoni), and kokanee salmon (Oncorhynchus nerka). Bull
trout (Salvelinus confluentus), anadromous salmon, and steelhead were once native to the Spokane

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River system, but since the construction of Grand Coulee Dam on the Columbia River downstream
from its confluence with the Spokane River, there is no passage for these species (WSDOT 2019). Non-
native fish in the study area include game fish species such as smallmouth bass (Micropterus dolomieu),
largemouth bass (Micropterus salmoides), brown trout (Salmo trutta), and eastern brook trout (Salvelinus
fontinalis) (WDFW 2025e; SWIFD 2025; Spokane Water Trail 2025). The non-native northern pike (Esox
Lucius) is classified as a prohibited aquatic invasive species in Washington. It has spread to several
water bodies within the state, including the Spokane River. Northern pike represents a potential for
substantial ecological and economic damage. It can live for over 20 years, grows to more than 45
pounds, produces a large number of young, and can both prey upon native salmonid species as well
as outcompete them for food and habitat (WDFW 2025f).

Federal and State Threatened, Endangered, and Special Status Species

An inventory of federally-listed fish and wildlife species protected under the ESA (16 USC 1531 et seq.,
as amended in 1998), was compiled using the U.S. Fish and Wildlife Service (USFWS) IPaC Information
for Planning and Consultation database (USFWS 2025a). See Exhibit 3.3-6. State-listed protected
species were identified using the Washington Natural Heritage Program data explorer and WDFW
Priority Habitats and Species webmap tools (WDFW 2025c; WDNR 2025). The study area falls outside
the jurisdictional limits of all ESA-listed species administered by NOAA Fisheries (NMFS); therefore,
these species are not considered.

Federally listed species and Washington priority species that are potentially present in the study area
and surrounding vicinity are shown in Exhibit 3.3-6 (USFWS 2025b; WDFW 2025c; WDNR 2025). No
critical habitat has been designated or proposed for any federally listed or proposed species within the
study area at this time.

Exhibit 3.3-6. Summary of Federally Listed Species and Washington Priority Species in the
Study Area

Priority Species Scientific Name Federal Status State Status

Monarch butterfly Danaus plexippus Proposed Threatened Candidate
Suckley’s cuckoo bumble bee Bombus suckleyi Proposed N/A
Endangered
Spalding’s catchfly (herbaceous Silene spaldingii Threatened N/A
perennial)
Westslope Cutthroat Trout Oncorhynchus clarki N/A N/A
lewisi
Rainbow Trout Oncorhynchus mykiss N/A N/A
Redband trout Oncorhynchus mykiss N/A N/A
gairdneri

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Priority Species Scientific Name Federal Status State Status

Big Brown Bat Eptesicus fuscus N/A Endangered
Townsend’s Big-eared Bat Corynorhinus N/A Candidate
townsendii
Western toad Anaxyrus boreas N/A Candidate
Black-backed woodpecker Picoides arcticus N/A Candidate
Burrowing owl Athene cunicularia N/A Candidate
California floater mussel Anodonta N/A Candidate
(mollusc) californiensis
Shortface lanx (mollusc) Fisherola nuttalli N/A Candidate

Sources: USFWS 2025b; WDFW 2025c; WDNR 2025.
N/A = not applicable

Migratory Bird Treaty Act and Bald and Golden Eagle Protection Act

Migratory birds are federally protected under the Migratory Bird Treaty Act (MBTA), which makes it
illegal to take, possess, import, export, transport, sell, purchase, barter, or offer for sale any migratory
bird or eagle, or the parts, nests, or eggs of such a bird except under the terms of a valid federal
permit from USFWS (16 USC 703 et seq). Bald and golden eagles, though no longer on Washington’s
state endangered species list, continue to be protected under the Bald and Golden Eagle Protection
Act which prohibits take (defined to include pursuing, shooting, poisoning, wounding, killing, capturing,
trapping, collecting, molesting, or disturbing bald or golden eagles), possession, and commerce of
these species (16 USC 668-668ds). Like most of Washington, Spokane is within the Pacific Flyway, a
migratory bird route that extends from Alaska to South America. Migratory birds are known to travel
through Spokane and its vicinity and use various habitats including agricultural habitats, interspersed
undeveloped uplands, open space, forests and wetland areas, and aquatic habitats associated with
streams and ponds. The primary nesting season for most migratory birds in Washington is from April
1 to July 1 (USDA-FSA 2018). Bald and golden eagles are both known to be present in the region
surrounding Spokane, although golden eagles are encountered much more rarely. These species are
likely nesting and breeding between the months of January through August (USFWS 2025b).
Development activities within up to 660 feet of bald eagle nests, roost sites, or foraging areas—or up
to 0.5 miles for activities producing loud intermittent noises—is required to comply with federal
guidelines for bald eagle management (USFWS 2007).

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3.3.2 Impacts

Impacts Common to All Alternatives
Population and employment growth, and therefore new development, would continue into the future
under all alternatives. All of the alternatives would provide opportunities for development within
currently vegetated areas; thereby, all have the potential to impact wildlife and fish habitats, including
tree canopy, open space, riparian areas, wetlands, and streams. Site development and redevelopment
would have long-term effects on vegetation by physically removing trees, shrubs, and non-woody
plants. Land development would also result in short-term construction activities. Ground clearing
would expose soils and sediments that could be mobilized in stormwater runoff and impact nearby
aquatic habitats. Spills of fuels and fluids from construction vehicles and equipment could also
potentially result in mobilization of contaminants to surface water bodies and impacts to fish and
aquatic wildlife. Construction activities would create noise impacts that could cause short-term
behavioral disturbance to terrestrial wildlife.

Development activities can result in fragmentation of wildlife habitat and reduction of wildlife habitat
connectivity, quality, and function, resulting in adverse long-term impacts. Conversion of forest, open
space, and agricultural lands to urban-scale development would permanently remove vegetated
habitat, increase impervious surfaces, and facilitate increased generation of pollutants that could
reach aquatic habitats. Tree removal and reduction in tree canopy cover, in particular, would result in
the loss of benefits such as terrestrial wildlife and migratory bird habitat, soil and slope stabilization,
and the maintenance of lower ground surface and stream temperatures. Additionally, vegetation
removal and ground disturbance would provide opportunities for establishment of non-native and
invasive plants, which tend to establish quickly and colonize areas where soils have been disturbed.

Development of vacant or larger low density properties under all alternatives would lead to habitat
loss and reduced connectivity that would further reduce biodiversity. Increases in impervious surface
could also adversely impact aquatic habitat quality by increasing peak flows, reducing low flows,
introducing pollutants, increasing water temperatures, and reducing the amount of shade.
Development may also result in conversion of wetlands or degradation of floodplain or riparian
habitat, adversely affecting habitats that support fish and aquatic wildlife. The potential to affect
habitat varies among the alternatives, because the footprint of the concentrated development areas
varies by alternative, but general nature of the impacts would be similar among all alternatives.

Environmental Justice Considerations
As discussed in the City’s Climate Risk and Vulnerability Assessment, areas with disadvantaged
populations tend to have less tree canopy cover than other areas. For these reasons, alternatives with
a higher likelihood of contributing to canopy cover loss in areas with a combination of disadvantaged
populations and low canopy cover would have an elevated risk of adverse effects on disadvantaged
populations. Conversely, changes that allow lower-cost housing options in areas that are currently
designated for low density development could allow more overburdened populations to live in areas

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with higher canopy cover and access to large parks. The planting of trees in rights of way and on public
lands, where appropriate and managed for fire risk, along with policies that prioritize the protection,
maintenance, and expansion of tree canopy in residential and mixed-use areas where tree canopy is
currently low, could provide benefit to overburdened populations.

Alternative 1: No Action, Stay the Course
The overall character of potential impacts to plants and animals under Alternative 1 would be
consistent with the impacts common to all alternatives discussed above. Spokane’s future growth
under Alternative 1 is focused in the existing concentrated growth areas in downtown Spokane and
regional centers and corridors, which are generally highly developed. Development of residential-
zoned areas outside of the Center City would continue along current patterns at current densities.
Development would continue to be largely focused in developed areas that are already characterized
by large areas of impervious surfaces and relatively low vegetation cover. This would moderate the
potential for new development in more heavily vegetated or less intensively developed areas, and thus
minimize the potential for substantial impacts to fish, wildlife, and vegetated habitats. Continued
residential development at existing densities outside of Center City could result in additional loss of
vegetative cover in these areas compared to Alternatives 2 and 3, however. Without the additional
density benefits associated with greater amounts of infill and transit-oriented development, some
currently undeveloped areas surrounding residential areas that function as greenspace may be
eliminated as more single-unit homes are needed to accommodate growth. Continued clearing of
vegetation, particularly tree canopy, associated with residential development in these areas would
contribute to loss and fragmentation of wildlife habitat.

Among the three alternatives, Alternative 1 would concentrate the least amount of new housing in
Center City and the Division Corridor, foregoing opportunities to create increased density in these
currently developed areas. Alternative 1 would result in the greatest projected increase of housing
units in the far northwest Spokane neighborhoods of North Indian Trail and Balboa/South Indian Trail.
These neighborhoods contain substantial pockets of priority habitat, including shrubsteppe and
biodiversity areas and corridors, along with wetlands, floodplains, and shoreline areas associated with
the Spokane River. Alternative 1 could also potentially create greater development or human-use
pressure on habitats in the Hillyard neighborhood of Northeast Spokane compared to the other
alternatives. Alternative 1 would result in a slightly greater increase in the number of housing units in
the eastern portion of the Hillyard neighborhood than Alternatives 2 and 3 would; however, the
housing in Alternative 1 is predominately single-unit dwellings, whereas under Alternatives 2 and 3 it
would consist mostly of multi-unit development.

Alternative 1 would also concentrate additional housing and population in the Grandview/Thorpe and
Latah/Hangman neighborhoods of South Spokane. These neighborhoods are currently characterized
by relatively larger areas of undeveloped or less-densely developed land and large pockets of priority
habitat. While increased residential development would potentially increase development pressures
on these areas under Alternative 1, Alternatives 2 and 3 would focus a similar amount of additional
housing development in Grandview/Thorpe and Latah/Hangman. As a result, there would be no

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meaningful difference among the three alternatives in the potential amount of development pressure
on habitats in this area of the city.

Overall, Alternative 1 would have adverse effects on plants and animals resulting from increased
development. However, existing federal, state, and local regulations would be expected to moderate
potential adverse effects. Additionally, existing riparian habitat and tree planting programs would
continue to improve watershed and tree canopy coverage conditions throughout urban Spokane.
Alternative 1 would not be inconsistent with best available science, would not have irreversible
adverse effects on federally or state-listed threatened or endangered species, and would not have
adverse population-level effects on important non-listed species. Alternative 1 would result in
permanent habitat conversion, but due to existing federal, state, and local regulations it would not be
sufficient to compromise overall regional ecosystem function. As a result, Alternative 1 would result
in less than significant impacts to plants and animals.

Alternative 2: Distributed and Balanced
The overall character of potential impacts to plants and animals under Alternative 2 would be
consistent with the impacts common to all alternatives discussed above. Spokane’s future growth
under Alternative 2 is focused on creating greater housing and job intensity along frequent transit
routes and prioritizing a greater geographic balance of jobs and housing. Alternative 2 would result in
the most widespread distribution of new housing units and jobs within Spokane; however, it would
accomplish this in part by intensifying mixed-uses along high-use transit corridors, including in
Downtown and along Division and other frequent transit routes. Existing centers of development in
South Spokane would become linked by intensified development along the arterial corridors between
them. The addition of mixed-use zoning to arterials in Northwest and Northeast Spokane would
provide opportunities to increase density in these currently developed areas.

Similar to Alternative 1, Alternative 2 would concentrate additional housing and population in
Grandview/Thorpe and Hillyard, which could create additional development and/or human use
pressures on priority habitats in these areas. However, Alternative 2 would concentrate a substantially
greater amount of housing and job growth in Center City and the Division Corridor, which Alternative 1
would not. Concentrating housing, jobs, and transit within denser, more centrally situated, and
accessible areas could potentially defuse some of the development pressures in less developed areas
at the city’s periphery.

Similar to Alternative 1, Alternative 2 would have adverse effects on plants and animals resulting from
increased development. While Alternative 2 would be focused on creating increased density in
already-developed areas, it would have the most diffuse and widespread footprint among the
alternatives. As with Alternative 1, existing regulations and ongoing restoration and tree-planting
efforts would be expected to moderate potential adverse effects. Alternative 2 would not be
inconsistent with best available science, would not have irreversible adverse effects on federally or
state-listed threatened or endangered species, and would not have adverse population-level effects on
important non-listed species. Alternative 2 would likely result in permanent habitat conversion.
However, due to its focus on increasing existing urban density, the existing framework of federal,

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state, and local regulations (including the current update to the City’s Comprehensive Plan) and
ongoing local habitat restoration initiatives, Alternative 2 would not have effects that would be
sufficient to compromise overall regional ecosystem function. As a result, Alternative 2 would result
in less than significant impacts to plants and animals.

Alternative 3: Center City and Regional Hubs
The overall character of potential impacts to plants and animals under Alternative 3 would be
consistent with the impacts common to all alternatives discussed above. Alternative 3 plans for more
concentrated development in Center City, the Division Corridor, and a limited number of regional
centers such as Hillyard, Southgate, and West Plains than do Alternative 1 or Alternative 2. Growth
would also be focused along a limited number of corridors where substantial transit investments are
planned or under way. Alternative 3 would thus have a less geographically diffuse overall approach to
housing and job growth than Alternative 2 but would focus more intensively on a smaller subset of the
same areas. The effects of Alternative 3 on plants and animals would therefore be negligibly different
from Alternative 2. As a consequence, while it would have adverse effects, Alternative 3 would result
in less than significant impacts to plants and animals.

3.3.3 Mitigation Measures
Impacts to terrestrial habitats and associated impacts to wildlife can be minimized via implementation
of existing federal and state laws and local regulations such as the Environmental Standards
provisions in Title 17E of the SMC and the Spokane SMP.

Impacts to aquatic habitats and fish can be minimized by complying with regulations for all
development projects. This includes, but is not limited to, adhering to shoreline area, wetland, and
stream buffer requirements, complying with allowable in-water work windows, meeting stormwater
requirements, and complying with state and federal requirements regarding fish, wildlife, and waters
of the state and U.S.

Because none of the alternatives would result in significant adverse impacts, adherence to existing fish
and wildlife habitat protection regulations would be expected to sufficiently minimize adverse
development impacts under all of the alternatives. No additional mitigation would be necessary for
adverse impacts, and as a result, none is proposed. Measures that would contribute to ongoing
protection of fish, wildlife, and habitat resources, as well as additional measures that could help to
improve on current conditions, are discussed below.

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Incorporated Plan Features
The following plan features that would be included in Alternatives 2 and 3 would potentially help to
minimize impacts to plants and animals:
 Develop and implement climate resilience and greenhouse gas reduction goals and policies per
HB 1181. Strategies of the City’s June 2025 Climate Risk and Vulnerability Assessment that could be
incorporated into the element include:
 Restore shoreline habitats.
 Expand and manage the City of Spokane’s tree canopy.
 Consider a “One Health” approach to habitat management (optimize the health of people,
animals, and the environment).
 Establish development regulations that incorporate best practices for:
 Reducing the risk of wildfires, which are a prevalent hazard in the region.
 Mitigating the impacts of extreme heat and flooding.
 Review and update critical areas regulations based on best available science. A preliminary review
as part of the City’s June 2025 Climate Policy Audit provided the following strengths and
opportunities in the City’s Critical Areas Regulations:

 Section 17E.020 Fish and Wildlife Conservation Areas (FWCA): Spokane has fairly large riparian
buffers that align well with the State Department of Fish and Wildlife’s site potential tree
height recommendations, which is supportive of climate planning.
 Section 17E.020.120 Incentives and Stewardship Options for FWCA: The City could consider
similar incentives (tax incentives, stewardship options) in other sections of the critical areas
ordinance.
 Section 17E.030 Floodplain Management: Consider adding development restrictions for areas
within the mapped 500-year floodplain.

Regulations and Commitments
A substantial body of regulation exists to direct the management and protection of fish, wildlife, and
habitat within the State of Washington. Key federal, state, and local laws affecting fish, wildlife, and
vegetation are summarized below.

Federal

Endangered Species Act

The Endangered Species Act (ESA) provides a framework to conserve and protect endangered and
threatened species and their habitats from a project’s effects. Section 7 of the ESA requires federal
agencies to ensure that their actions do not jeopardize the existence of listed species or destroy or
adversely modify designated critical habitat. The ESA is administered by the U.S. Fish and Wildlife

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Service (USFWS) and National Oceanic and Atmospheric Administration National Marine Fisheries
Service (NOAA Fisheries, or NMFS).

Migratory Bird Treaty Act of 1918

The act protects migratory birds, making it illegal to take, possess, import, export, transport, sell,
purchase, barter, or offer for sale, purchase, or barter, any migratory bird, or the parts, nests, or eggs
of such a bird except under a valid federal permit from USFWS.

Bald and Golden Eagle Protection Act of 1940

This act prohibits “take,” including parts (including feathers), nests, or eggs of bald eagles (Haliaeetus
leucocephalus) and golden eagles (Aquila chrysaetos).

Section 404 of the Clean Water Act

Section 404 of the Clean Water Act requires authorization from the Secretary of the Army, acting
through the Corps of Engineers (USACE), for the discharge of dredged or fill material into all waters of
the United States, including wetlands. A permit is required whether the work is permanent or
temporary.

State of Washington

Growth Management Act of 1990 (RCW 36.70A)

Washington’s Growth Management Act (GMA) states that in drafting comprehensive plans,
jurisdictions should “protect the environment and enhance the state’s high quality of life, including air
and water quality, and the availability of water” and “conserve fish and wildlife habitat” (RCW
36.70A.020). The GMA requires that critical areas be designated, and development regulations be
adopted, to protect such areas.

Shoreline Management Act (RCW 90.58, WAC 173-18-100, and Chapter 173-22 WAC) of 1972

The Shoreline Management Act (SMA) requires protection for shoreline natural resources, including “…
the land and its vegetation and wildlife, and the waters of the state and their aquatic life … to ensure
no net loss of ecological function.” Its goal is “to prevent the inherent harm in an uncoordinated and
piecemeal development of the state’s shorelines.” The SMA requires jurisdictions with river, lake, or
marine shorelines to develop and implement Shoreline Master Programs (SMPs).

Chapter 220-610 WAC, State and Protected Species

Chapter 220-610 WAC identifies the federal ESA-listed species that are present in Washington and
establishes closed seasons and penalties for take of federally listed fish species. It also identifies and
classifies native wildlife species needing protection in Washington; defines the listing, management,
recovery, and delisting processes; and establishes rules for bald eagle management in Washington.

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Chapter 77.12.020 RCW, Wildlife to be classified

This chapter empowers the director of the Washington Fish and Wildlife Commission to determine
whether a species should be managed by WDFW, and to classify it as protected, endangered, or as
deleterious exotic wildlife that is dangerous to the environment or wildlife of the state.

Chapter 77.55 RCW, Construction Projects in State Waters

This law requires a Hydraulic Project Approval (HPA) from the Washington Department of Fish and
Wildlife WDFW for any work that uses, diverts, obstructs, or changes the natural flow or bed of any
fresh water or saltwater of the state of Washington, including wetlands.

Chapter 220-640 WAC, Invasive/Non-native Species; Chapter 17.10 RCW, Noxious Weeds—Control Boards;
and Chapter 16-750 WAC State Noxious Weed List and Schedule of Monetary Penalties:

These chapters establish the framework for regulating and controlling noxious weeds in the state of
Washington and designate the list of noxious weeds that pose threats statewide and regionally.

Washington State Wildlife Action Plan

The Washington State Wildlife Action Plan (SWAP) is a roadmap for conserving the state’s fish and
wildlife and the natural habitats on which they depend. The SWAP is currently undergoing a
comprehensive revision.

City of Spokane

Environmental Standards (Spokane Municipal Code Title 17E)

Spokane Municipal Code (SMC) Title 17E, Environmental Standards, provides for the protection of
identified Critical Areas within the City of Spokane. Key chapters of SMC Title 17E include provisions
regulating Critical Aquifer Recharge Areas (17E.010), Fish and Wildlife Conservation Areas (areas with
which priority species are associated, including important terrestrial and aquatic habitats as well as
riparian areas and buffers) (17E.020), Floodplains (17E.030), Geologically Hazardous Areas (17E.040),
and Wetlands (17E.070). Title 17E also includes provisions governing the administration of the city’s
SEPA regulations and the implementation of its Shoreline regulations.

Shoreline Master Program

The Washington Shoreline Management Act requires local governments to prepare locally relevant
policies and regulations for managing shorelines though their Stormwater Master Program (SMP). The
City of Spokane’s SMP governs the preservation, restoration, use, modifications, and development of
shoreline areas, which include the areas inside city limits that are located within 200 feet of the
Spokane River and Latah Creek. Both the Spokane River and Latah Creek are designated as Shorelines
of Statewide Significance, a special category of shorelines where statewide interests take priority and
specific uses are preferred. The City of Spokane SMP defines how these streams’ shoreline areas will

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be managed and includes goals, policies, development standards, and use regulations. The objectives
of the City of Spokane SMP are to improve environmental quality, enhance public access and
recreational opportunities, plan and coordinate development, raise development standards, and
ensure that Spokane’s greatest natural assets are carefully managed for the enjoyment of future
generations. Spokane Municipal Code Chapter 17E.060, Shoreline Regulations, establishes the city’s
authority for administration and implementation of the SMP.

Other Potential Mitigation Measures
Although none of the alternatives would result in significant adverse impacts to plants and animals,
and existing protections would preclude the need for additional mitigation, opportunities exist to build
on existing plans and regulations. Potential strategies to enhance vegetated habitat areas and benefit
fish and wildlife populations, beyond the protections afforded by existing plans and regulations and
the plan features of the City’s Comprehensive Plan Update, could include such measures as those
discussed below.

The City could increase program resources or incentives for the SpoCanopy program, which has a goal
for every neighborhood in Spokane to have 30% canopy cover by 2030.

The City could consider opportunities to develop additional incentive programs, and allocate increased
program resources, for habitat conservation and restoration,

To address patches and corridors of shrubsteppe habitat, the City could consider conservation
strategies that address the State’s Washington Shrubsteppe Restoration and Resiliency Initiative Long-
Term Strategy for xeric and mesic habitat, including incentive programs (Washington Shrubsteppe
Restoration and Resiliency Initiative, 2024).

The City could consider opportunities to identify and acquire undeveloped land in key areas to
designate for parks and natural lands. Section 3.8 in this document discusses current park levels of
service, and the levels identified by the 2022 Parks and Natural Lands Master Plan as needed to meet
current and future City needs. Exhibit 3.8-18 in this document shows future parks and natural lands
needs throughout the City. The City could prioritize acquiring undeveloped lands adjacent to existing
parks and natural areas, as well as undeveloped lands with limited development potential. The City
could also work with developers to identify strategies and incentives to incorporate vegetated open
space and wildlife corridors into new developments where feasible.

The City could address the following in future code amendments to strengthen resilience:
 Incorporate adaptive management into critical area and shoreline code, particularly as it relates to
mitigation (17E.020.090, 17E.060, 17E.070.130). Monitoring and adaptive management is
encouraged in WAC 365-195-905(6). Adaptive management is the process of monitoring and
improving permits, regulations, and programs to ensure the protection of critical areas.
 Consider adding code language to the critical areas regulations that is similar to provisions
contained in the shoreline regulations for limiting clearing and minimizing soil disturbance.

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3.3.4 Significant Unavoidable Adverse Impacts
All of the alternatives would result in unavoidable adverse impacts such as permanent conversion of
forested areas and vegetated open space to developed space, decreased wildlife habitat connectivity,
and additional stormwater runoff to aquatic habitats from increased impervious surfaces. However,
because much of the population and employment growth anticipated under the alternatives would
take place in currently developed areas, and because of existing and anticipated regulations, these
effects would be moderated below the level of significance. While impacts would overall be adverse
under all of the alternatives, no significant unavoidable adverse impacts are expected to result from
any of the alternatives.

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3.4 Land Use Patterns and Urban Form
This section discusses the City of Spokane’s land use and urban form, addressing land use patterns,
planned land use and zoning, and changes to the scale and type of land use and building forms with
the alternatives. Thresholds of significance utilized in this impact analysis include:
 Land use compatibility: Changes in use type between adjacent areas and any likely
incompatibility. Land use incompatibility could be related to health and safety (such as noise
levels), activity levels at various times of day/night, or conflicting movement patterns.
 Urban form compatibility: Changes in building form, scale, massing, or spatial organization
between adjacent areas and any likely incompatibility. Urban form incompatibility may involve
abrupt transitions in building height or bulk, inconsistent setbacks or street wall continuity, or
mismatched public realm design that result in visual disruption, diminished walkability, or the
overshadowing of public spaces.
 Cultural Resources: Loss, alteration, or damage of archaeological, cultural, and historical
resources and sites due to growth allowed by alternatives.
 Environmental Justice: Land use or urban form changes that disproportionately impact
historically marginalized or underserved communities with environmental, health, or
socioeconomic burdens. This includes increased exposure to noise and light pollution, as well as
urban heat island effects, especially in areas with high environmental health disparities, sensitive
populations, and limited tree canopy, vegetation, or public open space.

3.4.1 Affected Environment

Local Policy Framework
This section outlines the city’s current land use and zoning framework, along with policies and
regulations related to urban form such as height, bulk and scale, transitions, and views, and describes
current land use conditions. Most state, regional, and local land use policies are reviewed in Section
3.6 Relationship to Plans, Policies, and Regulations, while the discussion below focuses on policies
and regulations specific to land use and urban form.

Centers and Corridors Growth Strategy
The Comprehensive Plan, last amended in 2023, designates several centers and corridors throughout
the city. It focuses most new development in specific areas identified on the Land Use Plan Map
(Exhibit 3.4-1, page 3-82), including Neighborhood Centers, District Centers, Employment Centers,
Corridors, and Downtown, which serves as the city’s Regional Center.

Center and corridor land use policies promote the efficient use of land by promoting density and
mixed-use development in proximity to retail businesses, public services, places of work, and
transportation systems. Currently, there are 7 designated Neighborhood Centers, 7 District Centers, 6
Employment Centers, and 3 Corridors. These designated areas are intended to support a mix of uses

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such as higher-density housing, retail and commercial businesses, offices, and community facilities like
parks, schools, and government buildings in order to create vibrant, walkable places where people can
live, work, and access services.

Employment Centers share many of these characteristics but place a stronger emphasis on job-
generating development, such as office campuses or light industrial uses.

Outside of these key growth areas, existing residential neighborhoods are expected to evolve more
gradually, with new development carefully designed to be compatible with the surrounding homes.
Higher-density housing within and around centers and corridors can strengthen local businesses and
enable more efficient transit service across Spokane. As planning efforts move forward, center and
corridor designations on the Land Use Plan Map may be updated to reflect local priorities and
community input, ensuring the land use strategy remains flexible and responsive over time.

Relevant Existing Land Use Policies

LU 3.2 Centers and Corridors - Designate centers and corridors (neighborhood scale, community or district
scale, and regional scale) on the Land Use Plan Map that encourage a mix of uses and activities around
which growth is focused.
LU 3.3 Designating Centers and Corridors – Designate new centers and corridors in appropriate locations
on the Land Use Plan Map through a city-approved planning process.
LU 3.4 Planning for Centers and Corridors - Conduct a city-approved subarea planning process to
determine the location, size, mix of land uses, and underlying zoning within designated centers and
corridors. Prohibit any change to land use or zoning within suggested centers or corridors until a subarea
planning process is completed.
LU 3.5 Mix of Uses in Centers - Achieve a proportion of uses in centers that will stimulate pedestrian activity
and create mutually reinforcing land uses.
LU 3.6 Compact Residential Patterns - Allow more compact and affordable housing in all neighborhoods, in
accordance with design guidelines.

Subarea Plans and Neighborhood Plans
In addition to the Comprehensive Plan and the Centers and Corridors Growth Strategy, the City of
Spokane has several subarea and neighborhood planning efforts that guide development and
revitalization efforts in specific areas. These plans address various aspects like land use,
transportation, economic development, and infrastructure. See Section 3.6 Relationship to Plans,
Policies, and Regulations for discussion of subarea plans and other studies.

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Existing Land Use Designations and Zoning Districts

Existing Land Use Plan
The City of Spokane covers approximately 70 square miles, with residential land use making up the
largest portion (55%). Residential areas are currently categorized into three main designations:
Residential 10-20 (low), Residential 15-30 (moderate), and Residential 15+ (high).

Approximately 10% of land is designated for commercial and office use including Neighborhood Retail,
Mini Center, Center and Corridor (CC) Transition, and CC Core designations, 19% for industrial uses,
3% for institutional uses, and 12% for parks, open space, water, or vacant land.

Exhibit 3.4-1 shows the distribution of existing land uses across the city and Exhibit 3.4-2 shows the
acreage associated with each land use designation. The highest concentrations of commercial, mixed-
use, and multi-family development are located in the Downtown area, as well as in the Center and
Corridor and High Residential areas along major corridors such as North Division Street and East
Sprague Avenue, and within designated Centers. Low density residential neighborhoods
predominately made up of single-unit dwellings fill most land area while parks, open space, and major
institutional areas fill intervening spaces. Industrial development is concentrated in industrial areas,
along the Spokane River, and railroad corridors.

Exhibit 3.4-3 provides a summary of future land uses by area, outlining how Residential,
Commercial/Mixed-Use, Industrial, and Open Space/Agricultural uses are emphasized across different
parts of the city of Spokane. The existing land uses in some cases match the intended densities and
uses in the Comprehensive Plan, or are less developed and do not yet reflect the future land use. See
Exhibit 3.4-2.

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Exhibit 3.4-1. Adopted Land Use Plan Map as of 2025

Sources: City of Spokane; BERK, 2025.

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Exhibit 3.4-2. Existing Land Use Designation (summarized) by Acreage

Land Use Category Included Categories Area
(summarized) (acres)

Low Residential Residential Plus, Residential Low 22,381
Industrial Mining, Heavy Industrial, Light Industrial 8,337
Open Space Agriculture, Conservation Open Space, Open 5,387
Space, Potential Open Space
Commercial Office, Commercial, Neighborhood Retail, Mini 3,444
Center
Moderate to High Residential Residential Moderate, Residential High 2,268
Institutional Institutional 1,249
Center and Corridor CC Core Area, CC Transition Areas 761
Downtown Downtown 636

Sources: City of Spokane; BERK, 2025.

Exhibit 3.4-3. Summary of Existing Land Uses by Area

Area Residential Commercial/ Industrial Open Space / Notes
Density Mixed-Use Agriculture

Northwest Primarily low Commercial Industrial near Open space Major corridors
Spokane density; and mixed-use western edge and agriculture define
scattered nodes along by transport on outskirts commercial
moderate- Francis Ave and corridors nodes
density pockets Wellesley Ave
Northeast Mix of low- and Commercial Concentrated Open space Industrial
Spokane moderate- clusters along heavy and light and agriculture concentrated
density Market Street industrial on fringe areas in far northeast
and arterials; zones,
some mixed- especially near
use corridors rail lines

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Area Residential Commercial/ Industrial Open Space / Notes
Density Mixed-Use Agriculture

Division Higher-density Dense mix of Not Not Major north-
Corridor residential retail, services, emphasized emphasized south
nodes along mixed-use; commercial
corridor commercial spine
intense near
Center City and
key
intersections
Center City Medium- to High-density Some limited Not Includes
high density commercial, industrial uses emphasized Downtown,
residential institutional, in the eastern University,
(high-rise, mid- mixed-use edge. Medical District
rise) dominant
South Hill / Primarily low Mixed-use and Not Substantial Institutional
South density with higher-density emphasized parks and open uses: schools,
Spokane pockets of along Grand spaces medical
higher-density Blvd and Perry facilities
St
West Plains Pockets of low Limited Large-scale Open space in Industrial
density commercial industrial (light undeveloped dominant area
residential near highway near airport sections;
interchanges and I-90; some agriculture
heavy) present

Sources: BERK, 2025.

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Land Use Code

Zoning Districts

The City of Spokane utilizes a zoning code that divides the city into various districts, each with its own
set of regulations for land use and development. These districts are categorized into Residential,
Commercial, Industrial, and Mixed Use (i.e., Downtown and Centers and Corridors) categories, with
further subdivisions—each tailored to accommodate different uses and development intensities. See
Exhibit 3.4-4.

Key aspects of Spokane's land use code (SMC Title 17) establish districts and the different uses and
standards that apply to different districts including:
 Zoning Districts: These define the types of land uses allowed in different areas, such as residential,
commercial, industrial, and mixed-use.
 Permitted Uses: The code specifies what types of buildings, structures, and activities are allowed
within each zoning district.
 Building Regulations: This includes height restrictions, setbacks (distance from property lines), lot
coverage, and other development standards.
 Subdivision Regulations: Regulations governing the division of land into lots for development.
 Sign Regulations: Rules for the size, location, and type of signs allowed.
 Parking Regulations: Requirements for parking spaces based on land use.

Exhibit 3.4-4. Existing Zoning Districts Summary Table

Zone Category Zone Type

Residential RA, R1, R2, RMF, RHD
Commercial O, OR, NR, NMU, CB, GC
Downtown DTC, DTG, DTU, DTS
Industrial LI, HI, PI
Centers and Corridors CC1, CC2, CC3, CC4

Sources: City of Spokane; BERK, 2025.

 Characteristics of Residential Zones:
 Residential Agriculture (RA) – Low-intensity; for agriculture-related uses like farming,
greenhouses, single-unit homes, and on-site product sales.
 Residential 1 (R1) – Low-intensity; detached, attached, and middle housing at the scale/height
of single-unit homes.
 Residential 2 (R2) – Low-intensity; similar to R1 but allows slightly higher housing density.

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 Residential Multifamily (RMF) – Medium-intensity; mix of detached, middle housing, and larger
multi-unit buildings; denser than R2.
 Residential High Density (RHD) – High-intensity; tallest and most dense housing, including
RMF-type housing and large apartment complexes.

 Characteristics of Commercial Zones:
 Office (O) – Low-intensity; small-scale offices in or near residential areas; designed to
compliment residential areas and serve nearby neighborhoods.
 Office Retail (OR) – Higher-intensity; larger offices plus supporting retail/services; often in
downtown-adjacent areas; retail limited to avoid dominating.
 Neighborhood Retail (NR) – Neighborhood-serving, pedestrian-oriented businesses; limits on
auto-oriented uses like gas stations or drive-throughs.
 Neighborhood Mixed Use (NMU) – Similar to NR but encourages residential units alongside
commercial; allows more commercial space if housing is included.
 Community Business (CB) – Auto-accommodating commercial; wide range of local/regional
retail and services; some size limits near neighborhoods.
 General Commercial (GC) – Broadest range of retail, services, and limited industrial; industrial
uses restricted in size to maintain commercial focus.

 Characteristics of Downtown Zones
 Downtown Core (DTC) – Central downtown; tallest and most intensive building heights and
massing in the city.
 Downtown General (DTG) – High-density, mixed-use; encourages retail at street level with
residential/office above; wide range of uses but discourages auto-oriented and heavy
industrial.
 Downtown University (DTU) – Supports an urban university environment; promotes
pedestrian-friendly spaces with a mix of residential, office, retail, and related commercial
uses.
 Downtown South (DTS) – South of the railroad viaduct; accommodates a wide mix of uses,
including auto-oriented businesses.

 Characteristics of Industrial Zones
 Light Industrial (LI) – Wide range of industrial, commercial, and office uses; commercial size
limited to maintain industrial focus; residential allowed near the Spokane River; minimal but
safe and environmentally sound standards.
 Heavy Industrial (HI) – Primarily high-impact industrial; allows compatible office and limited
commercial; similar residential allowance near the river as LI; standards ensure safe, efficient,
and functional development.

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 Planned Industrial (PI) – For light or heavy industrial areas; prioritizes employment-focused
uses; nonindustrial uses limited unless part of an approved site plan or development.
 Characteristics of Centers and Corridors
 These regulations carry out the Comprehensive Plan’s goals for centers and corridors –areas
designed to concentrate jobs, shopping, and housing in shared locations. They promote
economic activity through new development and redevelopment with cohesive, mixed-use
patterns, higher-density housing, street-oriented buildings, screened rear parking, pedestrian
safety, alternative transportation, quality design, smaller blocks, and narrow, on-street-
parking streets.
 Zones include:
 Type 1, 2, and 3 (CC1–CC3): Located in center and corridor core areas and core
commercial areas shown on the land use plan map.
 Type 4 (CC4): Mixed-use transition zones in designated transition areas.
 These zones apply to properties within the plan’s mapped centers and corridors. The
zoning map also shows the center type: Neighborhood Center (NC), District Center or
Corridor (DC), and Employment Center (EC).
 Identified as a Center and Corridor Core Area in the Land Use Plan, the Hamilton Form
Based Code in the South Logan area implements a Context Area (CA) zone and Shopfront
requirements.

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Exhibit 3.4-5. Existing Zoning Map as of 2025

Source: City of Spokane, 2025.

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Exhibit 3.4-6 presents the acreage associated with each zoning category. It shows that Residential 1 is
by far the largest zone in the city, followed by Light Industrial, General Commercial, and Residential
Multifamily.

Exhibit 3.4-6. Zone by Acreage

Zone Category Zone Type Zone Description Area (acres) Percent

Residential RA Residential Agricultural 147 0.3
R1 Residential 1 26,763 60.1
R2 Residential 2 905 2.0
RMF Residential Multifamily 1,853 4.2
RHD Residential High 1,171 2.6
Density
Commercial O Office 301 0.7
OR Office Retail 418 0.9
NR Neighborhood Retail 177 0.4
NMU Neighborhood Mixed No acres, not Not applicable
Use applied
CB Community Business 606 1.4
GC General Commercial 1,932 4.3
Downtown DTC Downtown Core 95 0.2
DTG Downtown General 480 1.1
DTU Downtown University 202 0.5
DTS Downtown South 91 0.2
Industrial LI Light Industrial 7,309 16.4
HI Heavy Industrial 1,168 2.6
PI Planned Industrial No acres, not
applied
Centers and CC1 Center and Corridor 316 0.7
Corridors Type 1
CC2 Center and Corridor 490 1.1
Type 2
CC3 Center and Corridor Applied as an Not applicable
Type 3 Overlay
CC4 Mixed-Use Transition 56 0.1
CA Context Area 1 (CA1) 53 0.1

Source: City of Spokane, BERK, 2025.

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Centers and Corridors: 2024 Assessment Study

In 2024, the Centers and Corridors Update Study was conducted to evaluate the effectiveness of the
current growth strategy and provide recommendations for the 2026 Comprehensive Plan Periodic
Update. The proposed changes will impact how centers and corridors are designated, the types of
designations used, public investment policies, and development regulations. Key recommendations
include eliminating the Employment Center designation and integrating it into other typologies, clearly
defining implementing zones for each typology, and updating the mapping of land use designations
for Centers and Corridors. Furthermore, the study proposed that mixed use zoning (see below) might
be allowed in limited areas outside designated Centers & Corridors.

A key regulatory change recommendation is the introduction of a new family of mixed-use zones to
replace the existing Center and Corridor zones:
 MU-TOD: emphasizes uses that support walking activity and high-intensity development, to be
applied near high-capacity transit stops.
 MU-1: the “base” mixed-use zone that allows a broad mix of uses and high-intensity development,
intended primarily for District Centers and Corridors.
 MU-2: oriented towards a narrower range of walking-friendly uses and moderate-scale
development, intended primarily for Neighborhood Centers and Mini-Centers
 MU-3: oriented towards smaller-scale development, intended for peripheral areas at the end of
centers. This is intended to replace both the CC4 and NMU zones.

Other notable regulatory proposals include increased height limits, relaxation of zone edge transition
standards, maximum block length/through-block connection standards, and updates to block frontage
standards (provisions for Pedestrian-designated streets and other block frontages).

Overlay Districts

Spokane has three major overlay zones that influence land use in specific areas of the city. The North
River overlay zone limits the maximum floor area ratio and site coverage to protect the public’s view of
the Spokane River, Riverfront Park, and the Downtown core. The Adult overlay zone coincides with the
area of the city where adult business may be located. Finally, the Center and Corridor (CC3) overlay
zone is applied in areas near existing centers and corridors, allowing development in those areas to
use either the standards of the Type 1 or 2 Center and Corridor zone or the existing underlying zone.
Additionally, there are further height limitations related to the flight paths of Spokane International
Airport, Fairchild Air Force Base, and Felts Field.

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Urban Form Regulations
Development regulations govern what uses are permitted, as well as the physical form (such as
heights and setbacks) of development, which influences the form and function of urban environments.
Policies guiding height, bulk, and scale in the Land Use Element of the current Comprehensive Plan
include:
 LU 5.5, Compatible Development: Ensure that infill and redevelopment projects are designed to be
compatible with and complement surrounding uses and building types.
 LU 1.4: Direct new higher intensity residential uses to areas in and around Centers and Corridors
designated on the Land Use Plan Map and to areas where existing development intensity is already
consistent with development of this type.
 LU 2.1, Public Realm Features: Encourage features that improve the appearance of development,
paying attention to how projects function to encourage social interaction and related to and enhance the
surrounding urban and natural environment.
 LU 2.1, Performance Standards: Employ performance and design standards with sufficient flexibility
and appropriate incentives to ensure that development is compatible with surrounding land uses.

Height, Bulk, and Scale
Height, bulk, and scale regulations vary greatly by location in Spokane. See Exhibit 3.4-7. Low
intensity residential zones (R1, R2) feature height limits of 40 feet, with setbacks of 10 to 15 feet and a
maximum lot coverage of 50% to 65%, while higher intensity and mixed-use zones allow for smaller
setbacks, greater lot coverage, and taller buildings. Tall buildings are required to have maximum floor
area for floors above seventy feet to contribute to a visually interesting skyline and to blend cohesively
into the existing urban form.

Transitions

To ensure compatibility between zones of varying intensity, the Spokane zoning code requires
elements such as lower height limits for lots located near lower intensity residential zones.
Additionally, specific zones such as Mixed-Use Transition are used to transition between higher and
lower intensity areas.

Tree Canopy

Spokane has a variety of policies intended to enhance their urban forest, reduce stormwater runoff,
and provide shade and shelter. Trees are required to be planted and maintained by adjacent property
owners, and enhancing the urban tree canopy is a central goal of the Spokane Comprehensive Plan.
Exhibit 3.4-8 illustrates the percentage of each block group’s area covered by tree canopy. It reveals
higher canopy coverage in parts of South Spokane, while Center City, West Plains, and Northeast
Spokane show notably lower coverage. It also highlights that several block groups identified as facing
high climate vulnerability (due to a range of climate hazards, environmental and health conditions, or
socioeconomic factors) are situated in areas with low tree canopy coverage.

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Exhibit 3.4-7. Maximum Height Limit

Source: City of Spokane, 2025; BERK, 2025

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Exhibit 3.4-8. Tree Canopy Coverage

Source: National Land Cover Database, 2021; BERK, 2025.

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Views

Maintaining views and vistas is one consideration in planning for new development in Spokane,
helping to support a unique sense of place for Spokanites. Ensuring ample open space and reducing
the bulk of large buildings are major parts of this. In addition, key view corridors, such as around the
St. John’s Cathedral at the south end of Center City, get special consideration and impact how tall
nearby buildings can be. In addition, views are considered in the city’s land use standards in the North
River Overlay district:
Section 17C.160.020 Views, Vistas and Site Coverage Design: To maintain views, vistas from the
ground level to the Spokane River Gorge and Downtown Spokane from the north side of the
river. Views, vistas and pedestrian access should be maintained at periodic intervals in a north to
south direction. Ideally the views from the public street system will allow the viewing of the
Spokane River’s path and the recognition of the natural environment along the river.

Major Land Use/Development Policies and Efforts Currently Under Consideration
Interim elimination of height limits: In early 2025, City leadership introduced an interim ordinance
eliminating building height limits across over 200 downtown blocks, aiming to boost housing and
economic development.
Reform proposals for Centers & Corridors zones: In mixed-use Centers & Corridors areas, the city is
proposing to:
 Raise height limits from 40/55/150 ft to 55/75/150 ft, depending on zone classification.
 Ease transition height requirements adjacent to single-family zones
 Remove maximum FAR and introduce a modest minimum FAR, simplifying density control.
 Offer height bonuses for providing affordable housing, off-street (concealed) parking, or public art.
 Revise the existing Center and Corridor zoning designations to reflect Mixed-Use terminology.
Height controls near Riverfront Park: Although only interim changes have been made (see above),
height limits along Spokane Falls Boulevard, south of Riverfront Park, were reviewed due to concerns
over shadowing; proposals include flexibility in height with limits on tower floor sizes and spacing to
protect park light and views.
Transit-Oriented Development: Division Street BRT & North Spokane Corridor: Division Bus Rapid
Transit (BRT) is being planned along Division Street, expected to launch in 2027–2029. The project
includes land-use planning to support increased density along the corridor. The North Spokane
Corridor (US 395 freeway) is also under development and is slated for completion by 2030; it includes
recognizing the corridor as a multi-modal freeway with shared transit, bike, and pedestrian facilities.
Downtown Plan Update & Complete Street Designation: Emergency amendment to the Spokane
Municipal Code that adjusts Complete Street characteristics in downtown. November 2019

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Land Use Patterns and Current Conditions

Overview of Historical Planning and Land Use Patterns
The Spokane River has drawn people to the area for thousands of years and was the reason for both
the Spokane Tribe of Indians’ ancestors, and later, white settlement, according to the Spokane Tribe of
Indians tribal history. The Spokane ancestors were a river people, living a semi-nomadic way of life
hunting, fishing, gathering. They lived along the banks of the Spokane and Columbia Rivers and the
tributaries in much of northeastern Washington, which consisted of approximately three million acres.
During salmon runs, other tribes joined the Spokanes at the falls for fishing, trade, games, celebration,
and socializing (City of Spokane, 2025) (Spokane Tribe of Indians, 2020).

In the 1800s, U.S. soldiers arrived and displaced the Spokanes from their ancestral land as white
settlement increased. Settlement increased within the area in the 1870s as the first sawmill was built,
followed by stores, churches, schools, banks, hotels, saloons, and a newspaper. The area was formally
settled in 1873 by James Nettle Glover as Spokan Falls (later named Spokane Falls, and then just
Spokane). In 1881, President Rutherford B. Hayes formally established the Spokane Indian Reservation
of approximately 154,602 land acres known as Chief Lot’s reservation, which was located northwest of
the present city. In that same year, Spokane was incorporated with a population of about 350 (City of
Spokane, 2025; City of Spokane, N.D.). The arrival of the Northern Pacific Railroad around the same
time and its transcontinental linkage in 1883 marked a transformative period in Spokane’s
development, positioning the city as a key transportation and commercial hub. The discovery of gold
in the nearby Coeur d'Alene mining district further spurred economic growth, making Spokane the
principal gateway to the Pacific Northwest, leading to a surge in population and infrastructure. Despite
the Great Fire of 1889, which destroyed 32 downtown blocks, the city was quickly rebuilt with durable
materials, sparking a period of intense growth and construction (City-County of Spokane Historic
Preservation Office, 2005).

The expansion west brought mining, railroad, and timber industries, which brought new immigrants
from all over the world in the 1800s, including people from China and Japan who helped build local
industries and established Spokane's Chinatown on Front Street. Spokane’s Chinatown began in the
1880s and was at first mostly populated by Chinese laborers who had immigrated in the 1850s and
1860s to work in the local railroad and mining industries, with Japanese immigrants arriving in the
1890s. Many Chinese and Japanese businesses were destroyed in the Spokane Fire of 1889 and the
population of Chinese residents declined, partly due to the Chinese Exclusion Act of 1882 that
prevented Chinese laborers from immigrating and denied recently-arrived Chinese residents
citizenship. In 1921, Washington State passed the Alien Land Law which barred non-white immigrants
from owning land, though specifically targeted towards Japanese and other Asian immigrants, and the
number of Japanese families declined in Spokane. WWII reversed this trend, however, when Spokane
became a haven for Japanese families fleeing the threat of Internment camps within the exclusion
zone on the West Coast, many of whom settled into what became known as Trent Alley. In 1974, the
remaining buildings and courtyards of Trent Alley were destroyed to facilitate construction for Expo ’74
(City of Spokane, 2025).

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African Americans began migrating to Spokane in the late 1800s, when the Great Northern Railroad
brought Black workers to the area. Early families established businesses and organizations that served
the growing Black population. Initially, Spokane's Black community was not confined to a specific area,
however segregation later developed through local policies enacted on racial covenants and redlining,
eventually concentrating the Black community in the East Central neighborhood. East Central had
already been facing a post-war economic decline for decades. Spokane’s Black population doubled
from 1940 to 1950, and gained an additional 50% from 1950 to 1960. This rapid growth intensified
segregation, particularly in housing. By the 1960s, nearly a quarter of the Black population in Spokane
lived in East Central, and the area around the 5th Avenue Business District became a residential center
of Spokane’s Black community (City of Spokane, 2025).

Urban expansion and civic planning played pivotal roles in shaping Spokane’s modern identity. By
1907, the city had nearly doubled in size to 37 square miles. In 1909, the Olmsted Brothers were
brought in to guide park and landscape development, laying the foundation for Spokane’s identity as
the “City Beautiful.” From 1888 to 1936, streetcars played a vibrant and iconic role in Spokane’s history
(Kershner, 2007). Exhibit 3.4-9 shows a map of the city’s streetcar network as it existed in 1929. As
ridership declined, Spokane United Railways began converting its routes to bus service. Remnants of
the streetcar era remain, however, as old rails can still be seen through the cobblestones of some
streets. Today, over half of Downtown Spokane is designated as historic, highlighting Spokane’s
architectural legacy and preservation efforts.

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Exhibit 3.4-9. Spokane United Railways system, 1929

Source: (Transit Maps, 2017)

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Between the City Beautiful movement of the early 20th century and discrete local events, such as the
1974 World’s Fair and its recent 50th anniversary, Spokane’s urban development has been significantly
altered since it was established (City of Spokane, 2017). See Exhibit 3.4-10. Adaptive reuse of historic
buildings and Riverfront Park’s transformation from railroad hub to a park and cultural events center
invite residents and visitors to the heart of Spokane. A convergence of state routes, transit, rail lines,
and an airport also draw employers and investment throughout Spokane.

Exhibit 3.4-10. Aerial Image of Downtown Spokane (Circa 1970 and Present Day)

Source: (Washington State Digital Archives); Google Maps, 2025.

Current Conditions

Current Uses

Spokane’s major land use categories are currently residential, commercial, downtown, and industrial.
Residential neighborhoods are concentrated outside of Center City and dominate the landscape in the
middle to outer sections of South, Northeast, and Northwest Spokane. Commercial areas are
concentrated around major nodes at the intersections of arterial roads, with limited mixed-use areas
typically located within the core areas of the city. Commercial uses include things such as
neighborhood convenience stores, major retailers, and restaurants. Industrial uses are concentrated
near the major highways in the city (I-90, US 395, and US 2), as well as around the major railyard in
Northeast Spokane. These industrial uses range from major construction operations to small-scale
fabrication. The Downtown region consists of major office buildings, entertainment, hospitals, and
major civic institutions.

Spokane’s urban development is largely consistent with its land use and zoning plans, with the bulk of
existing uses being residential (Exhibit 3.4-11). Key industrial areas, such as the region surrounding
the major railyard in Northeast Spokane, have a diverse mix of local manufacturing, utility and
transportation uses, and commercial-oriented services. In addition, significant amounts of currently
vacant land around the edges of the city are likely to be, or in the process of, developing into new
housing and services for suburban residents.

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Exhibit 3.4-11. Existing Land Use

Source: Spokane County Assessor’s Office, 2025; BERK, 2025.

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Land Use in Northeast Spokane

Source: Google Earth

Northeast Spokane is home to a significant concentration of industrial uses, centered around the US
395 and a major railyard. Beyond this, it is home to Spokane Community College and features a
diverse array of housing types, ranging from dense mixed-use developments around Hamilton and
Nevada streets to more traditional low density suburban housing further north. The ongoing project to
build out the North Spokane Corridor (US 395) has displaced a significant number of residents,
businesses, and industries, and will significantly affect travel and freight distribution patterns in and
around Northeast Spokane upon completion in 2030.

Land Use in Northwest Spokane

Source: Google Earth

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Northwest Spokane is primarily residential, with commercial and mixed-uses centered just outside of
downtown in the Emerson-Garfield and West Central neighborhoods. The northwesterly flowing
Spokane River provides significant nearby open space for residents, while continuing suburban
development along North Indian Trial Road characterizes the far north reaches of Northwest Spokane.

Land Use in Center City

Source: Google Earth

Centered around Spokane Falls on the Spokane River, Center City features a wide array of building
types, uses, and ages. The intense business and commercial use in Center City is well contrasted by
the shady campus of Gonzaga University and ample open space along the river. Center City functions
as the heart of the region’s economic and civic life.

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Land Use in South Spokane

Source: Google Earth

Separated from Center City by a series of ridges and without major freight or highway routes, South
Spokane is primarily residential, with a few commercial and mixed-use corridors centered around
Grand Boulevard and 29th Avenue. It is generally less intensely developed than Central, Northeast, and
Northwest Spokane, and features many parks and mature trees.

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Land Use in West Plains

Source: Google Earth

The West Plains is centered around Spokane International Airport, the busiest airport in the Inland
Northwest and a key anchor for a variety of industrial and commercial enterprises. Additionally,
Fairchild Air Force Base just outside the city limits is a major driver of both employment and industry
in the region, significantly affecting the mix of uses in the West Plains area. Lands around the airport
have been earmarked for industrial uses and other uses more consistent with close proximity to the
airport.

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Building Types and Styles
Spokane has a wide variety of building types, ages, and styles, varying significantly by region of the city.
In Center City, historic masonry buildings contrast with mid-century and modern architecture, and tall
buildings are the norm (Exhibit 3.4-12). Remnants of Expo ’74 and the associated downtown
renaissance are evident in much of the core area near the Spokane River. Center City has the widest
array of building age and type of any place in the city.

Exhibit 3.4-12. Downtown Center City Spokane

Source: City of Spokane, 2025.

Downtown is typified by a mix of historic early-19th century buildings intermixed with more modern
development—much of which arose after the World’s Fair in 1974 reinvigorated the downtown and
updated the focus from manufacturing and industrial materials manufacturing to more office and
retail uses. The tallest buildings in the city are found here as well as some of the most architecturally
unique designs.

In inner neighborhoods within a 3 mile radius of downtown, that developed in the early 20th century,
low-rise commercial buildings (one to two-story) along historic streetcar corridors mix with small-scale
apartment buildings and craftsmen style single unit homes (Exhibit 3.4-13). These neighborhoods
include historic alongside newly built homes, all relatively modest in height and scale and lie on a
typical gridiron street pattern.

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Exhibit 3.4-13. Spokane Housing and Commercial (Pacific Street)

Source: City of Spokane, 2025.

Further than three miles from Central Spokane, in places which have been urbanized since the middle
of the twentieth century, there are many ranch-style homes on curvilinear streets, and residential and
commercial uses are more strictly separated. Since these areas have developed more recently, it is
common to find similar looking homes along blocks, rather than the more eclectic mix of ages and
styles found in more central locations.

Exhibit 3.4-14. Spokane Housing (Holyoke Ave)

Source: Google Maps

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Land Capacity
While Spokane, like most cities in the United States, is experiencing a housing crisis, the City has
identified ample space to accommodate all of its projected future growth within its existing
boundaries. The 2025 Land Capacity Analysis identified 3,000+ parcels making up some 1,800 acres
(Exhibit 3.4-15), capable of housing nearly 70,000 additional Spokanites in 33,000 new dwelling units.

Exhibit 3.4-15. Land Capacity Analysis under Current Zoning –2025 (Acres)
Category Parcel Count Buildable Area
Vacant 1,151 1,118.4
Partially Used 205 355.0
Underutilized 1,672 364.8
Total 3,028 1,838.2
Source: (City of Spokane, 2025)

Cultural Resources

Cultural and Archaeological Resources
As further described in Overview of Historical Planning and Land Use Patterns on page 3-95, the
Spokane Tribe’s ancestral homelands encompass the Spokane River and surrounding region. The
Spokanes are composed of three ethnographic bands: Lower Spokane at Little Falls and the Spokane
River mouth, the Middle Spokane at Tum Tum and the Little Spokane River, and the Upper Spokane on
Latah Creek and Spokane Falls. The Spokanes relied on migrating salmon in particular, which was
limited greatly by the damming of the Spokane and Columbia rivers. (Historical Research Associates,
Inc., 2015) (Spokane Tribe of Indians, 2020) (Arksey, 2005) The area was also a major trading center for
the Spokanes as they welcomed other area Tribes through their relations, history, trade, and
ceremony.

The lower band of the Spokane Tribe was resettled to the Spokane Reservation in 1881. In 1887, the
Upper and Middle Spokane people signed an agreement to move to the Coeur d’Alene, Jocko
(Flathead), or Colville reservations. Some Upper and Middle Spokane Tribal members did move to the
Spokane reservation. (Spokane Tribe of Indians, 2020)

The potential for archaeological resources is very high or high risk throughout most of the city limits.
See Exhibit 3.4-16.

The City of Spokane regulates development to protect cultural resources in its Shoreline Master
Program and Subdivision Code (SMC Section 17E.060.160, Chapter 17G.080). The City may require a
cultural survey through the SEPA process that is applicable except where development is categorically
exempt; otherwise, the City reviews development for cultural resources impacts if a proposal needs
state or federal funding or permits. The City notifies Tribes of the proposals that require a notice of
application or through the SEPA process.

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Exhibit 3.4-16. State Archaeological Risk Assessment Model – City of Spokane Vicinity

Source: (Washington Department of Archaeology and Historic Preservation, 2025)

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Historic Resources
The City of Spokane was incorporated in 1881, and shortly later in 1883 the Northern Pacific railroad
was completed. (City of Spokane, N.D.) The 1880s were prosperous. Major institutions like Gonzaga
University and Sacred Heart Hospital were founded and a street railway system was established.
Platting of the north shore of the river began. Browne’s Addition was one of Spokane’s earliest
neighborhoods. (Washington State Office of Archaeology and Historic Preservation, 1976) See
Overview of Historical Planning and Land Use Patterns section above for more on historic
development patterns.

The City of Spokane adopted a historic preservation ordinance (04.35) in November 1981 that
established the Spokane Historic Landmarks Commission, a City/County body made up of
professionals and community members which reviews applications and designate historic properties
to the Spokane Register of Historic Places. For designated sites, the commission conducts design
review of exterior changes.

There are eighteen historic districts on the local or national registers of historic places within Spokane.
There are also over 400 individual local sites designated in the Spokane Register of Historic Places. See
Exhibit 3.4-17 for a citywide view of districts and places and Exhibit 3.4-18 for a closeup of the
districts.

Exhibit 3.4-17. Historic Districts – National and Local
Name Local National Acres Study Area
Booge's Addition Yes No 1.3 South
Brownes Addition Yes Yes 113.8-133.5 South
Cannon Streetcar Suburb Yes No 145.4 South
Comstock-Shadle Yes No 1.6 South
Corbin Park Yes Yes 35.2-45.3 Northwest
Desmet Avenue Warehouse No Yes 3.7 Northeast
East Downtown No Yes 68.7 Center City
Felts Field No Yes 27.4 Northeast
Ft. George Wright No Yes 183.9 Northwest
Hillyard Business District Yes Yes 8.4 Northeast
Marycliff-Cliff Park No Yes 82.6 South
Mission Avenue No Yes 23.5 Northeast
Nettletons No Yes 192.9 Northwest
Ninth Avenue No Yes 73.6 South
Peaceful Valley No Yes 40.4 Center City
Riverside Avenue No Yes 17.4 Center City
Rockwood No Yes 181.7 South
West Downtown No Yes 35.8 Center City
Source: Spokane City/County Historic Preservation Office, 2025.

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Exhibit 3.4-18. Historic Districts and Properties in City of Spokane

Source: (Spokane City/County Historic Preservation Office, 2025)

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Exhibit 3.4-19. Historic Districts and Properties – Central Spokane Vicinity

Source: (Spokane City/County Historic Preservation Office, 2025)

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Environmental Justice
GMA requires that Comprehensive Plan land use, transportation, and climate elements address
environmental justice. According to the Healthy Environment for All Act (also known as the HEAL Act)
and the Growth Management Act, Environmental Justice is defined as (RCW 70A.02.010, RCW
36.70A.030(16)):
The fair treatment and meaningful involvement of all people regardless of race, color, national
origin, or income with respect to the development, implementation, and enforcement of
environmental laws, rules, and policies. Environmental justice includes addressing disproportionate
environmental and health impacts in all laws, rules, and policies with environmental impacts by
prioritizing vulnerable populations and overburdened communities, the equitable distribution of
resources and benefits, and eliminating harm.

This section addresses the potential for disproportionate impacts to vulnerable populations and
overburdened communities due to development or the location of population in areas that are
affected by noise, light and glare, shade and shadow, and heat islands.

Noise
With the Spokane International Airport in the West Plains area, Felts Field—a general aviation relief
airport—in Northeast Spokane, a cross-country Interstate Highway running east to west through the
city, and a strategic position on the freight rail network, Spokane experiences high levels of noise
pollution in many areas, adversely impacting neighborhood health and quality of life.

Exhibit 3.4-20 shows noise pollution levels across the city. The map highlights the impacts of
Interstate 90 and the railroad corridor on Center City and the East Central neighborhood in particular,
as well as the location of the North Spokane Corridor, a 10.5-mile multimodal transportation route
planned for completion by 2030, which may contribute to increased noise impacts in the East Central
neighborhood and Northeast Spokane study area.

While higher environmental noise levels are experienced in and around Spokane’s two airports, the
impacts of these operations are mitigated somewhat by long-standing regulations limiting sensitive
land uses within areas of higher (65+ decibels (dB)) noise levels. The effectiveness of these regulations
is somewhat improved by largely identical regulations in the City of Airway Heights and Spokane
County.

The high noise levels are mostly clustered around those identified sources, but most major roads and
interstates in Spokane are also significant contributors to noise pollution. Both current and future city
policy clusters higher intensity development along these corridors, and rising traffic levels as the city
population increases are likely to exacerbate these issues, particularly in overburdened communities
closer to sources of noise pollution.

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Exhibit 3.4-20. Existing Transportation-Related Noise

Source: National Transportation Noise Map, 2020; BERK, 2025.

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The population affected by high noise levels is relatively high in the Center City, East Central, and
Northeast Spokane areas. See Exhibit 3.4-21 and Exhibit 3.4-22 which shows population affected by
transportation noise and population affected by state roads. The Washington State Department of
Health has identified that “traffic volume and density greatly impact health conditions and are
associated with infant mortality, poor birth outcomes, cardiovascular disease, and cancers [and] the
effect of pollution is more pronounced among the elderly and those who have preexisting health
conditions.” (Washington State Department of Health, 2022)

Exhibit 3.4-21. National Transportation Noise Exposure Map – Share of Population Exposed to
Noise Greater than 50 dB

Source: (Seto and Huang, 2023)

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Exhibit 3.4-22. Population in Census Tracts within Proximity to Heavy Traffic Roadways

Source: (Washington State Department of Health, 2022)

Light & Glare and Shade and Shadow
Light pollution includes misdirected or stray light, unnecessary reflected light, illumination during
hours when it is not needed, and lighting levels that exceed what is required for a given task (MRSC,
2025). The widespread use of artificial light has substantially altered the natural pattern of darkness
and obscured views of the natural night sky, and light and glare from new development have the
potential to impact a significant number of residents and affect scenic resources, such as designated
parks and scenic routes.

Common contributors to light pollution include building lighting, advertisements, streetlights, and
illuminated sporting venues. A single light source often overlaps multiple categories. While light
pollution is particularly pronounced in densely populated and highly industrialized areas, even
relatively small amounts of artificial light, such as those from low density residential or commercial
sources, can disrupt ecosystems, disturb human circadian rhythms, and obscure the night sky (Wu,
2024).

Hilly topography plays a major role in the prevalence of shadows. Generally, the north side of a hill or
areas within a valley experience extended periods of shadow throughout the day. Trees, especially
large, dense evergreens, contribute to these shadows year-round. Additionally, building heights play a

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major role in shadow formation, as structures over two stories tall often cast long shadows that reach
the sidewalk.

Viewpoints and scenic routes often concentrate along waterfronts and topographically high points.
Factors that may influence a lack of viewpoints include a combination of topography with fewer
natural viewpoints, large trees blocking views, and limited public space at high points. The 2008 Fast
Forward Spokane Plan articulated a vision to foster and improve upon Downtown’s ‘sense of place.’
Central to this vision was the objective to protect solar access in key areas, as well as preserve views of
important amenities. One strategy outlined in the plan emphasized the community’s strong desire to
maintain optimal sunlight exposure in critical public spaces, such as Riverfront Park, through
thoughtful urban design, including the promotion of buildings that minimize shadows (City of
Spokane, 2008; City of Spokane, 2017). Protecting important views, such as those of the Spokane River
and landmarks like St. John’s Cathedral, is supported by specific overlay zones and design standards.

Heat Island
Spokane, like most urbanized areas, struggles with the Urban Heat Island effect. The most affected
areas have low tree canopy and high impervious surfaces, exacerbating high land surface
temperatures. People can be affected by heat islands outdoors walking or recreating, or in buildings
lacking cooling when extreme heat events occur. Well-shaded neighborhoods can be more than 10
degrees cooler than poorly shaded ones (Institute for Climate, Water, and the Environment, 2022). As
is the case in many cities around the country, this burden of higher temperatures tends to fall on the
more vulnerable populations within Spokane (Exhibit 3.4-23).

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Exhibit 3.4-23. Land Surface Temperature and Census Blocks with Very High Vulnerability

Source: LANDSAT-8; BERK, 2025.

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Summary of Affected Environment
This section provided an overview of the city’s current land use and zoning framework, detailing key
policies and regulations that shape the urban form. It also offered a description of existing land use
conditions, illustrating how these regulations influence the city’s development patterns.

Spokane’s current land use framework focuses new development in designated Centers and Corridors
to encourage mixed-use, higher-density, walkable communities near jobs, services, and transit.
Outside these areas, residential neighborhoods will develop more gradually. The City uses subarea
and neighborhood plans to guide localized growth and revitalization.

Spokane’s land use is primarily residential (55%), divided into low, moderate, and high intensity zones,
with commercial (10%), industrial (19%), institutional (3%), and open space (12%) making up the rest.
Commercial and higher-density development is concentrated downtown and along major corridors,
while industrial uses cluster near rivers, rail lines, and other key transportation hubs. The City’s zoning
code divides land into Residential, Commercial, Downtown, Industrial, and Centers and Corridors
districts, each with specific regulations on use, density, and development standards. Overlay districts
address special protections like river views and adult business locations.

Spokane’s urban form regulations guide building heights, setbacks, and design to ensure new
development complements surrounding areas. Taller buildings are allowed mainly in higher-intensity
zones, with design features to create an appealing skyline. Transition zones help blend different
intensity areas. The City prioritizes enhancing the tree canopy for environmental and climate benefits,
especially in vulnerable areas.

Spokane, founded in 1873 and incorporated in 1881 was historically shaped by the railroad and
mining booms. It has grown into a key commercial and transportation hub in the Inland Empire. Its
urban development reflects a mix of historic downtown architecture, early 20th-century
neighborhoods with streetcar-era buildings, and newer suburban-style housing on the outskirts.
Despite the current housing crunch, Spokane has substantial vacant and underutilized land, capable of
supporting future growth within city limits.

Culturally, the Spokane Tribe’s ancestral lands encompass the region, and the city regulates
development to protect significant archaeological and historic resources. Spokane has eighteen
historic districts and over 400 designated local historic sites, reflecting its rich heritage and ongoing
preservation efforts.

Environmental justice in Spokane focuses on fair treatment and meaningful involvement of all people,
especially vulnerable communities, in environmental decisions, aiming to address disproportionate
impacts and ensure equitable resource distribution.

The city faces noise pollution mainly near the airport, highways, and rail lines. Light pollution and
shadows from buildings and trees affect residents and scenic views, prompting policies to protect
solar access and important vistas. Spokane also contends with the urban heat island effect, which
disproportionately affects vulnerable neighborhoods.

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3.4.2 Impacts
Local land development patterns and zoning policies fundamentally affect many of the critical factors
that shape the form and features of Spokane and the neighborhoods within, directly affecting people’s
access to housing, jobs, schools, open space, public services, transportation, and experience of place.
Overly restrictive land use regulations can also narrow economic opportunities for workers or
encourage expansion outward, increasing travel by car and greenhouse gas emissions (GHGs). This
section focuses on the potential impacts—including equity and climate vulnerability considerations—
of changes in land use patterns, permitted uses, or development intensities. Impacts are discussed
based on the following categories:
 Land use compatibility: Changes in use type between adjacent areas and any likely
incompatibility. Land use incompatibility could be related to health and safety (such as noise
levels), activity levels at various times of day/night, or conflicting movement patterns
 Urban form compatibility: Changes in building form, scale, massing, or spatial organization
between adjacent areas and any likely incompatibility. Urban form incompatibility may involve
abrupt transitions in building height or bulk, inconsistent setbacks, or street wall continuity, or
mismatched public realm design that result in visual disruption, diminished walkability,
overshadowing of public spaces, or a lack of coherent neighborhood identity.
 Cultural Resources: Loss, alteration, or damage of archaeological, cultural, and historical
resources and sites due to growth allowed by alternatives.
 Environmental Justice: Land use or urban form changes that disproportionately impact
historically marginalized or underserved communities with environmental, health, or
socioeconomic burdens. This includes increased exposure to light or noise pollution,
environmental hazards, or urban heat island effects, especially in areas with high environmental
health disparities, sensitive populations, and limited tree canopy, vegetation, or public open space.

Impacts Common to All Alternatives
The alternatives primarily differ in how growth is distributed and intensified across the city, as well as
in their projected land use patterns. The pace and location of future development would be shaped by
factors such as the implementation of Comprehensive Plan policies, related regulations and actions,
and decisions made by individual property owners and developers.

In general, all alternatives concentrate the highest levels of future growth in centers, corridors, and
commercial and industrial/employment areas that already feature higher intensities, a more diverse
mix of uses, and greater access to frequent transit. Outside these hubs, growth is directed toward low-
to moderate-intensity housing and neighborhood-scale commercial development in designated
locations. Each alternative assumes mixed-use growth in Center City, with additional varying levels of
mixed-use development along Division Street (northern spine) and South Regal Street between the
Lincoln Heights and Southgate centers. All alternatives also anticipate some industrial growth in
Northeast Spokane (Hillyard area) and the West Plains near the airport.

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Land Use Patterns and Compatibility
Growth across all alternatives—housing, commercial, industrial, and mixed-use— will spur new
development and redevelopment citywide. Across all alternatives, more diverse land uses will locate
near each other, increasing mixed-use patterns within activity hubs, centers, corridors, and, to varying
degrees, other parts of the city. Exhibit 3.4-24 shows a comparison of future land use intensity, based
on the designated amount of land, for each alternative. While the Comprehensive Plan encourages
mixing uses in centers and corridors, some adjacencies could potentially cause adverse compatibility
impacts on less intense uses. Over time, infill and redevelopment will raise development intensity in
areas not yet built to full zoning capacity. The extent of these conflicts varies by alternative and would
continue to be mitigated through the application of existing development regulations.

Exhibit 3.4-24. Future Land Use Intensity Qualitative Comparison

Alternative 1: No Action Alternative 2: Distributed Alternative 3: Center City
and Balanced and Regional Hubs

Low Higher Moderate Moderate
Intensity
Residential

High Lower Moderate Moderate - Corridors
Intensity
Higher – Center City
Residential

Mixed-use/ Lower Moderate Moderate - Corridors
Commercial
Higher – Center City

Industrial Lower Moderate Higher

Open Space Moderate Moderate Moderate
Source: BERK, 2025.

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Under Alternatives 2 and 3, new mixed-use development could replace areas originally zoned for a
single use. This would occur in Northwest, Northeast, and South Spokane study areas. See Exhibit
3.4-25. Greater mixing of uses can increase localized spillover effects, such as noise, particularly in
Downtown and other urban centers and corridors. While not unusual in these areas, such impacts
remain a potential adverse effect of future growth. They can be mitigated through land use policies
that provide transitions in intensity, apply use restrictions, and separate incompatible zones, as well as
through continued enforcement of noise, nuisance, and public safety codes.

In Alternatives 2 and 3, the Northeast study area is assumed to transition from primarily industrial
uses to a blend of industrial, mixed-use development, and high- to moderate-intensity residential
neighborhoods. This shift could bring a range of potential impacts, such as increased traffic and freight
movement, changes in neighborhood identity, greater demand for infrastructure and public services,
and possible land use conflicts where residential areas meet active industrial sites. At the same time,
the mix of uses could create opportunities for new jobs, improved amenities, and more housing
choices within walking distance of employment centers. See additional study area comparisons in
Exhibit 3.4-25.

Exhibit 3.4-25. Land Use Summary Evaluation by Area

Area Alternative 1: No Action Alternative 2 Alternative 3

Northwest Continue as planned Residential moderate to Residential moderate to
Spokane More growth on vacant high, mixed-use zones high concentrated in
land in North Indian Trails. extending northwest and southeast area nearer to
east-west along Central City/Downtown
Medium and high
corridors/frequent transit core; some residential
residential intensities and
routes. moderate and mixed-use
commercial uses along
distributed along N Indian
some corridors. Middle
Trail Rd.
housing in Residential Low
areas.
Northeast Continue as planned Residential moderate to Residential high and
Spokane Redevelopment potential high, mixed-use zones mixed-use concentrated on
in some corridors and extending north and east- Division St. Residential
centers. Middle housing in west along corridors/ moderate to high and
Residential Low areas. frequent transit routes. mixed-use around edges of
Residential moderate to Hillyard area. Industrial
high and mixed-use focused on upper
around edges of Hillyard northeast.
area. Industrial focused on
upper northeast.

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Area Alternative 1: No Action Alternative 2 Alternative 3

Center City Continue as planned. Residential high and Intense clustering of high
Downtown would have mixed-use distributed and moderate-high growth
unlimited heights per beyond just the downtown with strong focus on
interim regulations. core. mixed-use and housing on
surrounding
South Logan Subarea Plan
neighborhoods and along
not included in growth
Division Street.
estimates.
South Continue as planned. Moderate-to-high More limited spread south;
Spokane More growth in residential spread further growth stays nearer the
Latah/Hangman south along South Regal St; city center, with fewer
neighborhood on vacant mixed-use focus on outer high-intensity zones.
land. designated centers: Grand More growth in
District, Lincoln Heights, Latah/Hangman
Redevelopment potential
South Gate, 57th & Regal. neighborhood on vacant
in some corridors and
centers. Middle housing in More growth in land.
Residential Low areas. Latah/Hangman
neighborhood on vacant
land.
West Plains Continue as planned. Industrial heavy Expanded industrial
concentration north of the concentration to southwest
airport; residential uses are of airport; residential uses
minimal, prioritizing are minimal, prioritizing
employment/industrial employment/industrial
functions. functions.

Sources: BERK, 2025.

Urban Form

Height, Bulk, & Scale

Future growth and development directed into existing centers, corridors, and employment/industrial
hubs under all alternatives would result in a moderate amount of additional height and bulk in these
commercial, mixed-use nodes. The overall height, bulk, and scale implications from such development
would likely be consistent with that experienced over the last 20 years. Residential areas will see
limited changes to height, but more development of middle housing types and accessory dwelling
units (ADUs) will add more buildings to these areas.

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Transitions

Across all alternatives, redevelopment will likely bring larger buildings to replace smaller ones –
especially in urban centers, along major streets, near frequent transit, and in mixed-use or industrial
areas. In some neighborhoods, this could mean noticeable changes, such as apartments or middle
housing being built next to smaller-scale or single-unit homes.

These changes can also create sharper boundaries between different types of areas. Centers and
corridors often have a mix of zones (CC1, 2, 3 and 4) and building types, and in Alternatives 2 and 3,
growth is expected along their edges. While these areas may eventually blend together more
smoothly, in the short term the contrast between low density neighborhoods and busier, more
developed centers may become more pronounced.

In Alternatives 2 and 3, Northeast Spokane is envisioned to transition from primarily industrial uses to
a mix of industrial, mixed-use, and high- to moderate-intensity residential development. Here,
transitions would involve not only changes in building height and intensity but also shifts in land use.
Careful planning through setbacks, buffers, streetscape design, and pedestrian connections would be
needed to ensure these transitions are gradual and functional, minimizing conflicts while supporting a
cohesive, mixed-use neighborhood.

Tree Canopy

Bulkier development under all alternatives would likely displace some trees on private property,
especially in residential zones. At the same time, the number of street trees may increase where they
are required with redevelopment.

Shadows

Under any alternative, redevelopment will generally be taller and bulkier than the existing buildings.
Taller buildings cast longer shadows, and bulkier buildings cast wider shadows. A combination of tall
and wide can mean large areas become shaded during much or all of the day. Building shadows in
dense urban areas offer public health benefits that have often been overlooked in livability
discussions. Shading can reduce UV exposure, a leading cause of skin cancer, and mitigate the urban
heat island effect by cooling public spaces, promoting comfort, and encouraging outdoor activity.
However, excessive overshadowing can reduce natural light in adjacent buildings, increasing energy
use to maintain comfortable indoor temperatures. Furthermore, more shadows can result in icy roads
and sidewalks remaining slippery for longer after snow events and in the spring/fall when mixed
weather can cause traction issues. Balancing urban density with access to sunlight is essential to
support healthy, vibrant public and private spaces.

Views

Taller, larger buildings are expected in all alternatives, which could change some scenic views. This is
likely in both Alternatives 2 and 3, where new development in the northwestern part of the Center City
study area may impact ground-level views of the Spokane River Gorge and Downtown Spokane from

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the north side of the river. Current rules in the North River Overlay District aim to preserve these
vistas.

Cultural Resources
Under all alternatives there is a potential to disturb archaeological resources during construction given
the extensive very high- and high-risk areas throughout most of the city, especially in the Northwest,
Northeast, Center City, and Division study areas, as well as the Latah/Hangman portion of the South
study area. Regardless of alternative, growth may occur throughout the city and affect cultural
resources (except in critical areas such as wetlands, stream corridors, and priority habitats). Such
impacts can include physical alteration, damage, or destruction of all or part of a resource; alteration
of the characteristics of the surrounding environment that contribute to the property’s significance;
and the introduction of visual or audible elements that are incompatible with the property.
Under all alternatives, development of different scales or design may affect designated historic
properties and those that are greater than 45 years old or those sites that are eligible for listing as a
historic resource but not yet listed. All alternatives propose similar residential development to meet
growth targets but alternatives 2 and 3 focus growth at greater intensities in corridors and centers
where there is a potential to alter historic sites and structures, although it could decrease pressure for
development in “greenfield” areas where undisturbed cultural resources may be found.

Environmental Justice
The alternatives vary in their proposed concentration of growth in areas vulnerable to climate risks or
in their level of opportunity to incorporate additional climate resilience strategies. Alternative 2
maintains the existing network of centers and corridors and encourages greater integration of mixed-
use development and commercial activities along transit-rich corridors. Its emphasis on service-rich
neighborhoods and neighborhood-oriented nodes helps distribute growth more evenly across the city,
which may reduce concentrated noise, light pollution, and localized heat island effects, while also
allowing for smaller-scale, community-driven climate adaptation strategies. In turn, Alternative 3
directs most of the new housing, mixed-use development, and job growth toward major hubs,
particularly Center City and the University District as well as West Plains and Hillyard. This targeted
approach to development creates opportunities for large-scale infrastructure investments and energy-
efficient design, but it may also concentrate environmental stressors in specific areas unless carefully
mitigated.

North Spokane Corridor (US 395)

Northeast Spokane contains a significant concentration of industrial uses. It is also home to Spokane
Community College and features a range of housing types, from mixed-use development to low
intensity suburban housing. The ongoing construction of the North Spokane Corridor (US 395) has
already displaced a number of residents, businesses, and industrial operations. Once completed in
2030, the corridor is expected to significantly reshape travel and freight distribution patterns
throughout the region. Designed as a multimodal freeway, the corridor will include transit, bicycle, and
pedestrian facilities alongside vehicle lanes.

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The project is likely to introduce several environmental impacts to surrounding neighborhoods.
Increased vehicle traffic, especially freight, may elevate noise levels, affecting nearby residential areas.
New roadway lighting could contribute to light pollution, impacting visibility of the night sky and
altering nighttime conditions for nearby homes. Additionally, the expansion of paved surfaces may
lead to localized heat island effects.

This project presents an opportunity to proactively plan for land use compatibility and long-term
community development. Both Alternative 2 and Alternative 3 envision continued industrial uses in
the upper northeast area, surrounded by moderate- to high intensity residential and mixed-use zones.
Thoughtful planning will be essential to ensure that these uses can coexist in a way that supports both
economic growth and neighborhood livability.

Division Bus Rapid Transit (BRT)

Division Bus Rapid Transit (BRT) is planned for launch between 2027 and 2029. It will expand existing
bus service between downtown Spokane and north Spokane and Spokane County. While the project
will enhance mobility and reduce car dependency, potentially lowering regional noise and emissions, it
may also bring localized increases in noise, light, and heat in areas of intensified development along
the corridor.

Alternative 1: No Action, Stay the Course
The City of Spokane’s growth patterns and development intensity would continue as currently
planned, following existing land use regulations and policies, which already direct higher-intensity
housing toward designated Centers and Corridors, as well as the Downtown core/Center City area.
Employment growth would continue in the Downtown area and in industrial zones located along
major rail lines and near Spokane International Airport.

Based on the comparison of alternatives under Impacts Common to All Alternatives, the potential for
impacts under Alternative 1 is summarized below:
 Land use compatibility: Development continues under existing zoning; minimal new conflicts
between adjacent land uses.
 Urban form compatibility: Existing scale and form patterns would be maintained; abrupt
transitions may continue where high-density Centers meet lower-density neighborhoods. There
would be more limited improvements in street connectivity, sidewalks, or public realm design.
 Cultural Resources: Growth could occur throughout the city, and there is potential to disturb
cultural resources during construction. Alternative 1 proposes similar total growth as other
alternatives, but focuses more growth in areas in outer neighborhoods such as North Indian Trail
as well as in centers and corridors. It would not increase the capacity for development and may
have less pressure on historic sites since it has less intensity planned along corridors with existing
development built more than 45 years ago. However, since more development is focused in low
density areas there may be a greater risk that undisturbed cultural resources may be found.

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 Environmental Justice: Historically underserved communities may continue facing unequal
access to amenities, transit, or services (see also Section 3.5). Existing environmental burdens,
such as noise or light near development intense or industrial zones. This could be lessened with
current transitional standards but may occur to a greater degree than other alternatives.

Alternative 2: Distributed and Balanced
Alternative 2 maintains the existing network of centers and corridors but better connects them by
encouraging greater integration of mixed-use development and commercial activities along transit-
rich corridors. This approach responds to community interest in creating more walkable, service-rich
neighborhoods by introducing small-scale, neighborhood-oriented retail nodes in strategic locations,
guided by specific locational criteria. Some centers connected by transit could evolve into corridor
development. These retail and mixed-use hubs would strengthen connections between residential
areas, transit stops, and commercial destinations, enhancing both accessibility and quality of life.
Additional discussion of impacts under Alternative 2 includes:
 Land use compatibility: Generally balanced development reduces large-scale incompatibility by
spreading growth in existing centers and corridors, and employment hubs. Introduction of small-
scale, neighborhood-oriented retail nodes may create localized activity conflicts in some residential
areas (noise, traffic).
 Urban form compatibility: Gradual densification along transit-rich corridors may introduce
changes in building height or scale that contrast with existing low-density neighborhoods.
Improved street-level design and pedestrian infrastructure can enhance visual coherence and
walkability.
 Cultural Resources: Alternative 2 has similar residential growth and less job growth compared to
Alternative 1. Alternative 2 increases the capacity for more housing types, and there is potential for
localized impacts if new mixed-use nodes or corridors overlap with sensitive historic or cultural
sites. With less pressure to develop in lower density areas compared to Alternative 1, there could
be less potential risk to undisturbed cultural resources under Alternative 2. Impacts can be
mitigated by advanced review and application of historic and cultural resources policies and
regulations.
 Environmental Justice: More population could be located along corridors that may have
transportation noise and there could be more urban streetscapes with less tree canopy. However,
there is an opportunity to increase landscaping, tree canopy, and shade structures with new
development and along street frontages. The broader distribution of mixed-use development and
services may improve access for historically underserved communities (see also Section 3.5).
Alternative 2 could reduce environmental burdens by encouraging transit use and shorter trips,
mitigating air pollution and heat island effects. The implementation of Climate Element mitigation
and adaptation policies could reduce environmental justice impacts.

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Alternative 3: Center City and Regional Hubs
Alternative 3 directs most of the new housing, mixed-use development, and job growth toward major
hubs – particularly within Center City and the University District. These areas would see expanded
opportunities for mixed-use projects and employment centers, creating vibrant, high-activity districts.
Industrial development would be concentrated in targeted zones, especially within West Plains and
Northeast Spokane. This alternative also involves a more selective investment strategy, where City
resources are prioritized for certain high-impact Centers and major Corridors. In some cases,
designations in other areas may be removed or modified to focus growth where it will be most
effective. Along prioritized corridors, new designations would encourage mixed-use development and
higher-density housing. Enhanced livability such as improved streetscapes, pedestrian infrastructure,
and public amenities would accompany this targeted growth. Neighborhood commercial uses would
be established throughout the city, provided they meet established criteria, ensuring localized access
to goods and services.

Potential impacts under Alternative 3 include:
 Land use compatibility: Concentration of high-intensity residential, commercial, and industrial
uses may create sharp transitions between dense hubs and adjacent lower-density
neighborhoods. Targeted corridors may see mixed-use intensification that could conflict with
surrounding residential areas. Industrial intensification in some areas may conflict with
surrounding areas, particularly the Northeast.
 Urban form compatibility: Building scale, massing, and intensity would be located in major hubs;
abrupt transitions are possible at edges of priority growth areas. High-quality public realm
investments can mitigate some incompatibilities within hubs, but peripheral areas may experience
visual or transition disruption. There may be more intense development in Center City to the south
and west compared to current uses and plans. Transitions from Center City are expected to be
gradual.
 Cultural Resources: Growth in housing is similar to other alternatives and focused in already
developed areas in Center City and selected corridors. There would be higher job growth than the
other alternatives. Concentrated development pressure in Center City and Northeast in Hillyard
could mean a greater potential to disturb cultural resources or pressure to alter or demolish
historic buildings or districts. Incentives to encourage adaptive reuse and historic preservation
regulations would be applied. With less pressure to develop in lower density areas compared to
Alternative 1, there could be less potential risk to undisturbed cultural resources under Alternative
3. Impacts can be mitigated by advanced review and application of historic and cultural resources
policies and regulations.
 Environmental Justice: Center City and Regional Hubs benefit from enhanced infrastructure,
amenities, and transit access. Areas outside prioritized hubs may see limited improvements,
potentially exacerbating disparities for marginalized communities. High-intensity growth could
increase localized heat island effects, traffic congestion, or noise if not paired with environmental
mitigation. However, Alternative 3 would apply livability and streetscape improvements. This could
involve enhanced streetscape as a baseline improvement across more corridors (addresses tree
canopy and extreme heat), criteria for neighborhood commercial areas to provide commercial and

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civic uses in areas lacking services, noise abatement and standards, and other similar approaches
to address environmental justice.

3.4.3 Mitigation Measures

Incorporated Plan Features
All alternatives would focus most future growth into the existing urban centers, corridors, and
employment/industrial hubs. Compatibility challenges would not be an uncommon or new
phenomenon in these areas and can be avoided or mitigated by continuing to implement the Unified
Development Code.

Regulations and Commitments

Zoning and Urban Design
Spokane’s municipal code contains regulations for land use and urban form. Standards address
height, including transitions between more intense and less intense zones, building coverage, blank
walls, roof forms, landscaping, and screening, and more. These regulations as well as existing
supporting policies and programs would serve to mitigate impacts associated with the alternatives.

Noise, Light, Heating and Cooling
Chapter 10.70 Noise Control provides environmental designations for noise abatement and noise
limits between different land use categories (residential, commercial, industrial).

Chapter 17G.070 Planned Unit Developments are required to have lighting with cut-off shields.

Section 10.57.170 Portable Cooling Devices indicates rental tenants are allowed to install portable
cooling devices.
Cultural and Historic Resources
Federal and state laws govern the designation and protection of cultural resources, including but not
limited to:
 National Historic Preservation Act (NHPA) of 1966, as amended, known as Section 106, has
implementing regulations (36 CFR Part 800), that require federal agencies, or those receiving
federal grants or funds, or a federal permit or license, to identify historic properties, assess
adverse effects, and resolve those adverse effects.
 Archaeological Resources Protection Act (ARPA) of 1979 protects archaeological resources.
 National American Graves Protection and Repatriation Act (NAGPRA) creates protections for Native
American burial sites, remains, and cultural objects.
 Washington Executive Order 21-02 (formerly 05-05) requires that impacts to cultural resources
must be considered as part of any state-funded project or investment and must include

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consultation with Washington State Department of Archaeology and Historic Preservation (DAHP)
and with Tribal governments.
 Washington State law (RCW 27.53 and 27.44) protects archaeological resources (RCW 27.53) and
Indian burial grounds and historic graves (RCW 27.44) located on both the public and private lands
of the State.
 An archaeological excavation permit issued by the DAHP is required in order to disturb an
archaeological site.
 Knowing disturbance of burials/graves and failure to report the location of human remains are
prohibited at all times (RCW 27.44 and 68.60).

The City’s Shoreline Master Program (Section 5.2.4 Historic or Archeological Impacts) includes
regulations regarding stop work and studies if cultural resources are encountered:
 For any use, activity or development, the project proponent, agent, or applicant shall notify the
Spokane Historic Preservation Office and the Director whenever any archaeological or historical
artifacts or cultural resources are encountered during any grading or excavation. All work on the
project site shall cease immediately.
 Work may resume only after the applicant, project proponent, or agent and the Spokane Historic
Preservation Office, the Washington State Department of Archaeology and Historic Preservation,
and appropriate Tribal entities agree in writing on measures to protect potentially affected
archaeological or historic artifacts or cultural resources.

Spokane’s zoning code includes Chapter 17D.100 Historic Preservation, which addresses the
nomination of historic landmarks or districts. If there is a request for the demolition of an historic
landmark or a contributing building located within a local historic district, the City’s Historic
Preservation Officer and the Spokane City/County Historic Landmarks Commission reviews the
proposal against criteria. The code also contains incentives such as façade, utility, and sidewalk grants
to support preservation. Section 17D.100.230 of the Spokane Municipal Code specifically addresses
demolition permits for historic structures located within the downtown boundary area, National
Register historic districts, and centers and corridors, which were recently incorporated into the
ordinance (Spokane City/County Historic Preservation Office, 2024).

Other Potential Mitigation Measures

Land Use and Urban Design
The City could consider other actions if it wishes to proactively guide future land use and urban form
conditions. In addition to the policy and regulatory changes already discussed, the City could further
expand or refine these concepts through expanded development regulations and place-specific
strategies such as targeted approaches for specific neighborhoods, corridors, or centers which could
address unique conditions, such as industrial-to-residential transitions, mixed-use redevelopment, or
preservation of scenic views and open spaces.

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Cultural Resources
Advanced planning to eliminate, minimize, or avoid impacts to cultural resources would improve
outcomes under all the alternatives. If elimination, minimization, or avoidance is impracticable,
mitigation should be implemented by coordinating with the area’s Tribes, the City as the lead agency,
and all other stakeholders and consulting parties in accordance with DAHP Mitigation Options and
Documentation Standards and the City of Spokane’s Historic Preservation code.
The City could apply similar cultural resources policies and regulations found in the Shoreline Master
Program to the full city limits.

The City could develop a “decision tree” for below-ground cultural resources to determine the
appropriate level of investigation and, if necessary, mitigation; see the example in Exhibit 3.4-26. Even
when available information suggests a low probability of encountering cultural resources, it is never
possible to guarantee they will not be encountered during project activities; therefore, the standard
inadvertent discovery language (SIDL) should be followed per RCW 27.44 and 27.53.

Exhibit 3.4-26. Above Ground Cultural Resources Department of Archaeology and Historic
Preservation (DAHP) Predictive Model and Summary Survey Recommendations

Risk Category Minimum Evaluation
Low Standard inadvertent discovery language (SIDL)
Moderately Low and Desktop Review and SIDL
Moderate
High and Very High Survey and SIDL

Environmental Justice

Noise

To limit the impacts of temporary construction noise, in addition to restrictions on the hours of
construction, other mitigation that could be applied includes:
 Installing barriers to shield noise sensitive receptors and enclosing stationary work.
 Selecting haul routes to avoid noise sensitive areas.
 Using alternative methods to pile-driving.
 Using fully baffled compressors or electric compressors.
 Using fully mufflered construction equipment.

Where there are new residential uses near noise sources such as highways, the City could require
noise reduction standards in residential buildings where exterior noise levels greater than 65 dBA are
likely to occur or where other uses occupying the same structure would likely contribute to excessive
noise levels (above 45 dBA) within residences. These standards could include:

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 Municipal code provisions to ensure interior noise levels for all buildings/land use types are within
acceptable standards.
 Noise studies/mitigation for all development where the projected exterior noise levels exceed the
City’s allowable noise standards, to the extent feasible.
 Building standards or retrofits such as installation of acoustically rated windows and doors,
installation of additional wall and attic/roof insulation, and installation of dampers and baffles on
exterior vents, flues, and chimneys.
 Adopt goals or policies with site planning/design techniques to help guide land use planning
decisions and encourage proper design for future developments. Such techniques may include,
but are not limited to, the following:
 Increase the distance from the road to the extent feasible, depending on road classification,
while supporting walkability and encouraging neighborhood connectivity.
 Place noise compatible land uses such as landscaping areas, maintenance facilities, and utility
areas between the road and the residences or noise-sensitive uses.
 Use buildings or berms as noise shields by locating them parallel to the road(Note, this is an
effective strategy for roads but is ineffective from aircraft noise). Soundproof the building if it
contains residences.
 Locate residences in topographically low points that are naturally low noise pockets if they
exist.
 Orient the residences—and spaces within the building that benefit from quieter volumes
(bedrooms and living rooms)—away from the noise.
 Use cluster and planned unit development techniques to accomplish combinations of the
above. However, these techniques have limited to no effect on noise originating from aircraft
overhead.

The City should advocate for and coordinate with WSDOT on noise abatement and mitigation where
major highways bisect and disrupt residential areas to advance environmental justice outcomes.

Noise from tire-pavement interactions is a dominant contributor to roadway noise. A long-term
mitigation program to reduce noise in noise-sensitive areas within the study areas would be to install
noise reducing pavement on major arterials and roadways that experience relatively high traffic
volumes and speeds.

Light and Glare, Shade and Shadow

The following approaches could be taken with development regulation updates:
 Consider implementation of additional development standards to address maximum height of
exterior illumination.
 Address placement, light output, direction, and shielding of any exterior illumination above a given
height to reduce light and glare emissions to sensitive areas.
 Condition development near parks and open spaces or key pedestrian corridors with a
combination of the following measures to reduce shading effects:

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 Height limits within a specified distance of the public space or shade and shadow analysis that
demonstrate the preservation of sunlight in public spaces during peak periods of use.
 Separation of high-rise building massing.
 Maximum floorplate size.
 Modification of high-rise tower location and orientation upper-level stepbacks.
 Floorplate reductions.

Heat Island

The Climate Risk and Vulnerability Assessment identified adaptation and mitigation measures to
improve resilience to extreme heat. Some measures recognize the balance of adding trees for shade
while also managing for wildfire risk.
 Invest in green infrastructure to reduce the impacts of extreme heat.
 Invest in Tribal and cultural infrastructure to improve climate resilience.
 Enhance community gathering places as resilience hubs.
 Protect and adapt Spokane’s parks, open spaces, and shorelines.
 Expand and manage the City of Spokane’s tree canopy for cooling and air quality.
 Retrofit existing buildings for cooling, air filtration, and energy conservation.
 Incentivize or require green and cool roofs to reduce building temperatures and cool pavement in
place of conventional dark pavements.
 Prioritize tree canopy, cool corridors, and built shade installation on streets, public lands, and
public and private parking lots.
 Improve site and building design and install treed buffers along highways and roadways to
improve local air quality.
 Improve wildfire protection plans with more accurate risk maps, enhanced codes, and right tree,
right place concepts.

3.4.4 Significant Unavoidable Adverse Impacts

Land Use, Urban Form, Environmental Justice
Over time, Spokane is expected to experience continued growth, with development gradually
becoming more intense in terms of height, bulk, and scale under all alternatives. This shift from lower-
intensity to higher-intensity development is a natural and expected outcome of urban population and
employment growth. No significant, unavoidable adverse impacts on land use patterns, compatibility,
or overall urban form are anticipated under any alternative.

Future growth is likely to result in temporary or localized land use impacts as development occurs.
More growth could occur in proximity to noise sources or light and glare sources and in areas where
there are heat island effects. The potential impacts related to these changes may differ in intensity and
location in each of the alternatives and many are expected to resolve over time. Application of the

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City’s adopted or new development regulations and zoning requirements, including climate mitigation
and adaptation measures, are anticipated to sufficiently mitigate these impacts.

Cultural Resources
All the alternatives have the potential for significant adverse impacts to cultural resources in the
analysis areas. Proactive consideration of impacts to cultural resources results in more effective
identification, planning, and protection than reactive responses to inadvertent discoveries during
project implementation. A well-designed and implemented pre-project cultural resource review
process is the most effective way to avoid, minimize, or mitigate adverse impacts.

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3.5 Population, Employment, and Housing
This section addresses the City of Spokane’s population and demographic characteristics, housing
types and numbers, and employment types and numbers. The thresholds of significance in this
section include:
 Capacity for Housing and Population:
 Ability of the alternative to provide sufficient buildable land capacity for population and
housing.
 Housing Variety and Affordability:
 Ability to increase the supply, diversity, and affordability of market-rate housing.
 Ability to increase the supply of income-restricted housing.
 Regulatory barriers to and insufficient capacity for production of affordable units needed (in
line with City’s role / requirements under HB 1220).
 Ability to meet transit-oriented development requirements, or exemption requirements, in
proximity to bus rapid transit stations per state legislation.
 Equity & Disparate Impacts:
 Amount of new housing in areas with high displacement risk.
 Projected loss of homes due to demolition in high displacement risk areas.
 Amount of new housing in connected and accessible neighborhoods (transit, libraries, parks).
 Potential for job or business displacement for employment uses located within medium/high
intensity residential or mixed-use designated areas.
 Employment:
 Ability to adversely affect citywide Jobs/Housing balance.
 Job types and quantity and ability to advance City and regional economic development
strategies.

Other EIS sections address the compatibility of existing and future households near air pollution and
noise sources, respectively Sections 3.2 Air Quality and Greenhouse Gas Emissions and 3.4 Land
Use Patterns and Urban Form. In addition, the increase in growth in areas with social disparities and
demand for public services is addressed in Section 3.8 Public Services.

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3.5.1 Affected Environment

Citywide

Population and Households

Population Growth Trends

Prior to white settlement, the Spokane area was home to the Spokane Tribe of Indians’ ancestors. The
Spokane and Columbia River corridors and the tributaries in much of northeastern Washington were
places for Tribal hunting, fishing, and gathering. During salmon runs, other tribes joined the Spokanes
at the falls for fishing, trade, games, celebration, and socializing. See also Section 3.4.1 Affected
Environment, Cultural Resources.

The City of Spokane incorporated in 1881 with a population of around 350 but by the 1890 U.S. Census
it had a population of 19,922. In 2025, it is the second largest city in the state. Recent population
growth shows that from 1990-2025 the city grew at a rate of 0.8%. The city is expected to grow 9.1%
between 2025 and 2046. The population target growth between 2023 and 2046 is 23,357 people, an
annual growth rate of 0.4%. (Steering Committee of Elected Officials, 2024) See Exhibit 3.5-1.

More description of the population target is found in Chapter 2, Section 2.2.3.

Exhibit 3.5-1. Population Growth 1990-2025 and Future Growth to 2046

Sources: OFM 2025; BERK 2025.

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Likely due to the number of universities, the city has a relatively larger number of young adults
compared to the county; otherwise, the city has similar shares of ages. See Exhibit 3.5-2.

Exhibit 3.5-2. Age Structure, City of Spokane + County Comparison (ACS S0101) 2019-2023

10%
9% 9% Spokane Spokane County
9%
8% 7% 7% 7%
7% 6% 6%
6% 6% 6% 6%
6% 5% 5% 5%
5% 5%
4%
3% 2% 2%
2%
2%
1%
0%
Under 5

9-5

10-14

15-19

20-24

25-29

30-34

35-39

40-44

45-49

50-54

55-59

60-64

65-69

70-74

75-79

80-84

85+
Age Cohort

Source: U.S. Census Bureau, 2019-2023 American Community Survey 5-Year Estimates.

The population is majority white population but has a slightly higher share of non-white
residents than the county as a whole. See Exhibit 3.4-23.

Exhibit 3.5-3. Race and Ethnicity – City of Spokane (2019-2023)

81%
White alone
185,586
3%
Black or African American alone
6,162
1%
American Indian and Alaska Native alone
3,006
3%
Asian alone
6,595
1%
Native Hawaiian and Other Pacific Islander alone
1,853
2%
Some other race alone
4,729
9%
Two or More Races
21,297
8%
Hispanic or Latino (any race)
17,904
0 40,000 80,000 120,000 160,000 200,000
Population

Source: U.S. Census Bureau, 2019-2023 American Community Survey 5-Year Estimates.

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Household Characteristics

Citywide

Approximately two thirds of Spokane’s occupied housing stock is single-unit and one third is multi-
unit. Multi-unit housing is typically 5+ housing units or greater per building, and less frequently
duplexes, triplexes, and fourplexes. Household sizes typically vary by dwelling type, with higher
persons per household in single-unit dwellings and lower persons per household in attached
dwellings. See Exhibit 3.5-4.

Exhibit 3.5-4. Persons per Household 2022
Unit Type Housing Units (2022) Persons Per
Household
(2022)
Occupied Housing Units, All Types 95,604 2.33
Occupied Frame Housing* 94,053 2.34
Single-Unit Detached 62,651 (67%) 2.64
Multi-Unit** 31,402 (33%) 1.74
Duplex 4,109 (4% of multi-unit) 2.30
Triplex and Fourplex 4,200 (4% of multi-unit) 2.01
Five+ Unit 23,093 (25% of multi-unit) 1.59
* Structures built on-site of wood/brick construction or modular homes.
** Single family-attached structures such as row homes, townhouses and condominiums are categorized as multi-unit
structures based on the total number of units.
Source: OFM, 2024.

Homeownership rates remained consistent at 57% owner-occupied and 43% renter-occupied for all
households in the City of Spokane between 2013 and 2023. Homeownership rates increased for all
racial groups since 2013 except for Black households and Hispanic and Latino households, which
decreased by 3% and 2%, respectively. See Exhibit 3.5-5.

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Exhibit 3.5-5. Citywide Proportion of Households by Income and Tenure 2013 and 2023

Notes: American Indian and Alaska Native AIAN; Native Hawaiian and Other Pacific Islander households were omitted
due to the margin of error in 2013 exceeding the population estimates.
Sources: U.S. Census Bureau; U.S. Department of Commerce; American Community Survey 2023: 5-Year Estimates and
2013: 5-Year Estimates, Table S2502. Published by: (City of Spokane, 2025)

Cost burden refers to households that spend more than 30% of their income on rent and utilities and
who earn less than 80% of the area median income (AMI). Large shares of all renter households, at
least 40%, are cost burdened, with Black and Native Hawaiian and Other Pacific Islander (NHOPI)
renter households substantially more cost burdened than other racial groups. For owner-occupied
and households, Hispanic and Latino and Asian households have slightly higher cost-burdened rates
than other races. See Exhibit 3.5-6.

Exhibit 3.5-6. Cost-Burden by Race and Ethnicity and Tenure, City of Spokane, 2019-2023

Notes: American Indian and Alaska Native – AIAN, Native Hawaiian, and Other Pacific Islander - NHOPI
Sources: U.S. Census Bureau; U.S. Department of Commerce; American Community Survey, 2023: 5-Year Estimates,
Table B25140. Published by: (City of Spokane, 2025)

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Housing

Housing Stock

Nearly two thirds of the housing stock in the city is composed of single units and about one third in
multi-unit formats, typically more than five units per building. See Exhibit 3.5-7. Between 2013 and
2024, the city saw more multi-unit construction than single unit construction, and small amounts of
duplexes and multiplexes. See Exhibit 3.5-8.

As the city has grown over time, older housing units have been replaced by newer units. However, far
more units were constructed than demolished each year. Between 2010 and 2024, for every 1 housing
unit demolished the city gained about 7.4 units. See Exhibit 3.5-9.

Exhibit 3.5-7. City of Spokane Housing Stock, April 1, 2024

2%

25%

HOUSING
INVENTORY
4% (2024)
4% 65%

Single Unit
Duplexes
Multi-unit (3 or 4 Units)
Multi-unit (5+ Units)
Mobile Homes

Note: OFM unit type names adjusted from single family to single unit and multi-family to multi-unit.
Sources: OFM 2024; BERK 2025.

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Exhibit 3.5-8. Net Change in Housing Stock April 1,2013 to April 1,2024 (OFM)

+4,000 +3,757
Net change in housing, 2013–2024

+3,500

+3,000 +2,749
+2,500

+2,000

+1,500

+1,000

+500 +170 +68 +105
0
Single Unit Duplexes Multi-unit (3 or 4 Multi-unit (5+ Mobile Homes
Units) Units)
Housing Type

Note: OFM unit type names adjusted from single family to single unit and multi-family to multi-unit.
Sources: OFM 2024; BERK 2025

Exhibit 3.5-9. Housing Unit Completions and Demolitions – April 1, 2010 to April 1, 2024

Source: OFM 2024; BERK 2025

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The city has seen limited accessory dwelling units (ADUs) being built, but a noticeable rise in accessory
dwelling units were completed in the last 10 years. See Exhibit 3.5-10.

Exhibit 3.5-10. Accessory dwelling units completed as of April 1st of each year

18
New/Lost ADUs

Completed 16
16
Demolished
14
12
10
10
8
8 7
6
6 5
4
4 3 3 3
2
2
0
-2 1 1
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Sources: OFM 2024; BERK 2025.

Housing Needs and Affordability

Housing targets for Spokane were determined based on state projections and a regional process in
collaboration with other cities and Spokane County. Spokane’s target includes a total of 22,359 new
housing units from 2020 to 2046, as well as specific targets for each income band (see Exhibit 3.6-2).

Housing needs in the city were also identified in the Spokane Housing Action Plan (HAP) (City of
Spokane, 2021), resulting in the following findings:
 The City of Spokane and greater region is seeing steady population and job growth. As of 2021, the
HAP identified that at least 6,800 housing units are needed by 2037.
 There is an increased demand for housing for households in the moderate and middle-income
ranges (80-120% AMI), that can mostly be met through single-unit attached housing. In addition,
demand has increased for 2-bedroom apartments, rentals, and housing for seniors.
 Housing prices have outpaced household incomes. Based on a review of 2010-2020 data, a low
vacancy rate and demand for rental and ownership housing from persons from areas with more
housing wealth resulted in increases in housing prices.
 Changing household characteristics result in changing housing needs with greater elderly
population (65 years +) and Millennial populations (29-44 years) likely demanding smaller sized
housing as well as housing with living assistance support.

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As a result of these findings, the City’s strategies to meet needs included a range of activities to
increase and protect affordable housing and accessibility to it. These efforts included zoning
amendments to increase variety of housing types and increase densities and supply, incentive
programs, partnerships, and others. In addition, the City of Spokane Community, Housing, and Human
Services (CHHS) department has various programs implementing strategies. See Exhibit 3.5-11.

Exhibit 3.5-11. Housing Action Plan Strategies

Housing Action Plan Strategies

A. Increase housing supply, options, and affordability for all incomes.
A1. Explore and expand allowed housing types to encourage missing middle housing throughout
Spokane’s neighborhoods.
A2. Target efforts to increase the development of affordable housing throughout the city to support
mixed-income neighborhoods.
A3. Continue to streamline and simplify changes to the City’s permit process, as necessary.
A4. Leverage infrastructure and investment, including near high-performance transit stops, in
Centers and Corridors, the downtown core, and other targeted areas to increase housing supply.
A5. Revise Accessory Dwelling Unit standards to allow for additional flexibility.
A6. Leverage public and partner-owned3 land for housing, including a land bank. *
B. Preserve existing housing affordability and quality to help people thrive where they live.
B1. Expand preventative and proactive code enforcement to help maintain safe and quality
housing. *
B2. Align and leverage programs, funding, and resources to preserve the quality and livability of
existing affordable housing.
B3. Enhance protections and assistance for renters, particularly the most vulnerable.
B4. Maintain and improve existing affordable rental housing.
B5. Study the local short-term rental market to reduce impact on housing affordability,
neighborhood identity, and displacement.
C. Enhance equitable access to housing and homeownership.
C1. Reduce barriers and expand access to housing and homeownership for lower income
households, first-time homebuyers, people of color, and people with disabilities.

3
The HAP described examples of partners as Spokane Public Schools and the Washington Department of
Transportation.

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Housing Action Plan Strategies

C2. Address racial inequities and disparities in housing. **
C3. Preserve and stabilize the viability of existing homeownership for low-income homeowners.
D. Leverage and grow partnerships to support housing initiatives across the region.
D1. Support growth management planning which best meet the Comprehensive Plan’s goals and
policies.
D2. Leverage partnerships within the health, education, parks, and transportation fields to support
housing affordability, access to opportunity and quality of life.
D3. Grow and expand use of both local and regional housing data and analysis.

*Not yet implemented as of 2025.
**Action alternatives address racially disparate impacts requirements of HB 1220.
Source: (City of Spokane, 2021)

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Displacement Risk

As part of the Periodic Update the City is examining displacement risk, which refers to when a
household or business is “forced or pressured to move from their community by factors outside of
their control.” (Washington State Department of Commerce, 2023) Census tracts with greater
potential for residential displacement are shown in Exhibit 3.5-12. The indicators of risk include:
 Rental affordability and availability
 Homeowner affordability
 Housing age
 Unpaid property taxes
 Access to services
 New development and future development pressure

Exhibit 3.5-12. City of Spokane Displacement Risk Map 2025

Source: (City of Spokane, 2025)

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There are several causes of displacement:
 Economic displacement: Displacement due to inability to afford rising rents or costs of
homeownership like property taxes.
 Physical displacement: Displacement resulting from eviction, acquisition, rehabilitation, or
demolition of property, or the expiration of covenants on rent- or income-restricted housing.
Climate-related displacement, such as increasing flood risk, dangerous heat, or forest fire, falls into
this category. The potential risks due to changing climate could result in an inability to insure a
property which could impede securing a mortgage.
 Cultural displacement: Residents are compelled to move because the people and institutions that
make up their cultural community have left the area.

The Housing Action Plan (City of Spokane, 2021) found increasing housing costs and low availability
(low vacancy) in the city could lead to economic displacement. Physical displacement due to
development could occur with rehabilitation or demolition of housing units. Per Exhibit 3.5-9,
comparing units built to units demolished there has been an 11% rate of demolitions over the 2010-
2024 period (7,579 units completed divided by 808 demolished=11%), with 62% of demolitions being
single-unit and 38% of demolitions related to multi-unit development.

Evaluation of Current Policies under State Laws

Racially Disparate Impacts (RDI) Policy Evaluation

Based on the data analysis provided in the City of Spokane Racially Disparate Impacts Report (City of
Spokane, 2025), there is determination that the City has perpetuated racially disparate impacts,
stemming from historic policies and practices that continue to impact residents’ abilities to access
housing and opportunities. The City has made recent progress through land use and code changes
that begin to undo the impacts of racially disparate impacts. Policy analysis is important to change
policy direction. The first lens for policy evaluation focuses on actions the policies support or prohibit,
using the questions below for consideration. The second lens focuses on the narrative effect of the
policy and whether it furthers harmful biases about groups of people and communities. Racial bias is a
predisposition for or against based on unconscious associations about people based on race, whether
intentional or unintentional.

Questions for Consideration:
 Is the policy effective in accommodating needed housing?
 Does the policy contribute to racially disparate impacts? Displacement? Exclusion in housing?
 Who benefits and who is burdened by the policy?
 Does the policy increase displacement risk? If so, can this be mitigated through policies or actions?
 Does the policy provide vulnerable communities protection from displacement?
 Does existing terminology encode bias, racially informed presumptions or phrases that promote
exclusion?

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In total, 29 policies were evaluated in the Housing Element, as of August 2025, with the following
assessment: 10 of the policies were found to be supportive, 16 were found to be approaching, and 3
were found to either be challenging or not applicable. See Exhibit 3.5-13.

Exhibit 3.5-13. Summary of RDI Policy Evaluation

RDI Criteria Evaluation Policies
Identified

The policy is valid and supports meeting the identified housing Supportive 10
needs. The policy is needed and addresses identified racially
disparate impacts, displacement, and exclusion in housing.
The policy can support meeting the identified housing needs Approaching 16
but may be insufficient or does not address racially disparate
impacts, displacement, and exclusion in housing.
The policy may challenge the jurisdiction’s ability to meet the Challenging 2
identified housing needs. The policy’s benefits and burdens
should be reviewed to optimize the ability to meet the policy’s
objectives while improving the equitable distribution of
benefits and burdens imposed by the policy.
The policy does not impact the jurisdiction’s ability to meet the Not Applicable 1
identified housing needs and has no influence or impact on
racially disparate impacts, displacement, or exclusion.

Source: (City of Spokane, 2025)

Once policies are revised in the Comprehensive Plan, additional analysis and implementation will be
done through development regulations with clear and achievable incentives, strategies, actions, and
regulations that help move toward goals. There are likely supportive and conflicting regulations within
the Spokane Municipal Code as well. Review and updating of development regulations will come as
part of the adoption of PlanSpokane 2046 in 2026.

Bus Rapid Transit and Housing Densities and Displacement

Under HB 1491(2025), a city may not prohibit the siting of multifamily residential housing on lots
where any other residential use is permissible within one-quarter mile of a bus station area (bus rapid
transit) like along the existing City Line, or in the future, along the planned Division Bus Rapid Transit
Line. HB 1491 requires a minimum floor area ratio4 (FAR) of 2.5 applicable to residential and mixed-

4
Building square footage divided by the developable property square footage.

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use development in a bus station area.5 A city may exempt areas with shorelines or critical areas or
where there is a locally designated landmark or historic district established under a local preservation
ordinance; the FAR minimum is 3.0 on average if a city exempts up to 25% of bus station areas.
Additional FAR must be provided for housing made of mass timber. A minimum 10% of units must be
affordable for at least 50 years and such buildings are allowed another 1.5 FAR. An extension to delay
implementation is allowed for up to 5 years if the areas are at high risk for displacement, as certified
by the Department of Commerce.6 The City Line and buffer of a quarter mile with underlying zoning is
provided in Exhibit 3.5-14.

Exhibit 3.5-14. Center Line BRT and Quarter Mile Buffer with Current Zoning 2025

Source: City of Spokane, 2025.

5
Fully or partially within one-quarter mile walking distance of a stop on a fixed route bus system that is
designated as a bus rapid transit stop.
6
The City of Spokane shows moderate to high displacement risk in the census tracts along the route.
Commerce’s displacement risk map differs to some degree but also shows moderate and high risk.

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Areas that could be exempted include:
 Land within the Spokane River shoreline management area (200 feet of ordinary high-water mark).
 Land within Browne’s Addition local historic district (it is also a national historic district). There are
other national register districts (West Downtown, East Downtown, Peaceful Valley, Riverside
Avenue). Section 17D.100.230 of the Spokane Municipal Code addresses demolition permits for
historic structures located within the downtown boundary area, National Register historic districts,
and centers and corridors.
 Industrial lands if the zoning limits housing to one dwelling per lot or for caretakers. Within one
quarter mile of the river, the City’s LI and HI zones allow group living (LI) and residential household
living (LI and HI) subject to standards like access to the river, though it is unlikely in the Chief Gary
Park area given presence of Avista and Spokane Community College campuses. Areas where
housing is not allowed beyond caretaker housing can be excluded.

With no areas excluded, the current average FAR is 8.9. Excluding shorelines, local historic district, and
industrial zones the current average FAR would be 6.3, with a conservative analysis of heights, still
double the minimum 3.0 FAR. However, this is an average across all station areas, which includes
areas of high intensity on the western portions of the City Line and lower intensity areas. Some station
areas may not meet the minimum FAR. See Exhibit 3.5-15 below for a conceptual depiction of results
across the stations that shows the variable results. The Washington Department of Commerce is
preparing implementation guidelines, and the evaluation is likely to change.

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Exhibit 3.5-15. City Line HB 1491 Floor Area Ratio Conceptual Evaluation (2025)
Western End of City Line

Eastern End of City Line

Sources: City of Spokane, BERK, 2025.

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Employment

Total jobs and sectors

The city is a central job hub for the county and inland Northwest region and has approximately
128,000 jobs as of 2022. See Exhibit 3.5-16. In the past two decades, city employment experienced
two periods of decline – in 2012 to 2014, a few years after the Great Recession and most recently from
2020 to 2021, during the COVID-19 pandemic. In 2022, employment had recovered to pre-pandemic
levels.

From 2002 to 2022, city employment followed the same pattern of ebbs and flows as county
employment but has consistently grown at a slower pace than the county, with 0.7% per year on
average compared to 1.2% per year on average for the county.

Exhibit 3.5-16. Total Jobs 2002-2022 (in thousands)

135
Thousands

130 128

125

120

115 112

110

105

100

Sources: U.S. Census LEHD OntheMap, 2002-2022; BERK, 2025.

As shown in Exhibit 3.5-17 and Exhibit 3.5-18 the city’s employment mix is service oriented with
health care:
 Health Care and Other Services accounted for over 40% of the city’s total employment in 2022.
Health Care was by far the fastest growing industry in the City of Spokane. It added almost 11,500
jobs between 2002 and 2022, and its share increased from 18% to 25% of total citywide
employment during this period.
 The Retail and Wholesale, Warehousing & Transportation industries experienced a decline of 12% and
19% respectively since 2002.
 The Utilities sector had a negative change in employment from 2002 to 2022, mostly because of the
reclassification of the majority of Avista's office-type employment from Utilities to Other Services in
the job data. Thus, it is not a true decline.

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Exhibit 3.5-17. Employment by Industry, 2002 and 2022
0.8% Utilities
100.0% 3.8%
4.1% Manufacturing
3.8% Construction & Resources 5.2%
90.0%
8.0% Wholesale, Warehousing & 5.7%
Transp
80.0% 6.4% 6.3%
Government
7.4%
8.6% FIRE
70.0%
7.5%
7.8% Education
60.0% 10.4%
10.3% Leisure & Hospitality
50.0%
10.7%
13.8% Retail
40.0%
17.8%
30.0%
18.0% Other Services
20.0%
Health Care 25.1%
10.0% 18.4%

0.0%
2002 2022

Notes: FIRE stands for finance, insurance and real estate, rental, and leasing. Other Services includes information,
professional, scientific, and technical services, management of companies and enterprises, administrative and waste
management, and others.
Sources: U.S. Census LEHD OntheMap, 2002-2022; BERK, 2025.

Exhibit 3.5-18. City of Spokane Employment Change by Industry, 2002 - 2022

Health Care 11,482
Other Services 2,640
Construction & Resources 2,306
Leisure & Hospitality 1,719
Education 870
Government 837
Manufacturing 330
Retail (1,885)
Wholesale, Warehousing & Transp (1,668)
Utilities (888)
FIRE (220)
(4,000) (2,000) - 2,000 4,000 6,000 8,000 10,000 12,000 14,000
Change in Employment, 2002-2022

Notes: FIRE stands for finance, insurance and real estate, rental, and leasing. Other Services includes information,
professional, scientific, and technical services, management of companies and enterprises, administrative and waste
management, and others.
Source: U.S. Census LEHD OntheMap, 2002-2022; BERK, 2025.

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The Workforce Council has provided job sector projections for the year 2034 that anticipates nearly
16,000 new jobs between 2024-2034. Over 35% of the new jobs are anticipated to be in healthcare and
another 20% in other services (information, professional, other). (Spokane Workforce Council, 2025)

City and Regional Economic Development Goals

Economic Development Plans

The City’s Economic Development goals are found in the current Comprehensive Plan and promote a
strong and diverse economy with opportunities including available land, education, and workforce
development, with the following themes of goals and policies:
 ED 1 Cooperative Partnerships
 ED 2 Land Availability for Economic Activities
 ED 3 Strong, Diverse, and Sustainable Economy
 ED 4 Income and Employment Opportunity
 ED 5 Education and Workforce Development
 ED 6 Infrastructure
 ED 7 Regulatory Environment and Tax Structure
 ED 8 Quality of Life and The Environment

The City of Spokane has planned for economic development in specific subareas that are key job
centers including Downtown, Hillyard, and others. See Section 3.6.1 Affected Environment.

Public Development Authorities

There are three public development authorities (PDAs) in the city that are meant to promote economic
development by attracting and coordinating investments, including the University District PDA in
Center City, the Northeast PDA addressing the Hillyard area, and S3R3 addressing West Plains,
particularly the airport. Each PDA’s purpose is shared below:
 University District Public Development Authority: Spokane’s University District is where,
“business and education grow together and the place to live, learn, work, and play in the
Intermountain Northwest. …With five major universities, two medical school programs, top-notch
community colleges, a nationally recognized smart city testbed, and a burgeoning life sciences
ecosystem, this is an idea-generating and innovation-focused community...”
 Northeast Public Development Authority (NEPDA): The mission of the NEPDA is to “facilitate the
redevelopment, development, and construction of public benefit projects, resulting in increased
economic activity and job growth within the PDA boundary (The YARD).”
 S3R3 Solutions (formerly known as West Plains/Airport Area Public Development Authority):
This PDA focus is “to undertake, assist with and otherwise facilitate the acquisition, construction,
development equipping, leasing, operation and maintenance of public benefit projects within the

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PDA boundaries…in order to assist both the City, County and the Spokane International Airport in
their ability to improve the economic conditions in and around the City and County of Spokane.”

Strategies & Programs

In 2022 the City of Spokane updated its economic development strategy to direct resources and
incentives to the most economically distressed Census tracts, called the Spokane Target Investment
Area. The Census tracts within the STIA were chosen by the criteria from the federal Community
Development Financial Institutions (CDFI) Fund requirements for defining a distressed community for
the New Market Tax Credit (NMTC) program. The STIA covers the geographies of all three PDAs, the
City’s two business improvement districts, Opportunity Zones, and Community Empowerment Zones,
as well as Census tracts that are NMTC eligible. See Exhibit 3.5-19.

Exhibit 3.5-19. Target Investment Area

Source: (City of Spokane, 2025)

The City of Spokane has access to numerous incentive programs addressing housing and
employment, including:
 Multi-Family Tax Exemption: A State enabled property tax exemption, the MFTE incentive allows
a time-specific exemption on the property taxes for the residential improvements that create new

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housing. In exchange for an exemption, at least 25-30% of the created units need to be workforce
rental housing or affordable owner-occupied housing. The incentive allows for differing exemption
lengths – 8 years (market rate rents), 12 years (workforce rentals and affordable ownership units),
and 20 years (permanent owner-occupied units).
 Single-Unit & Detached ADU Tax Exemption: A State enabled property tax exemption for single
unit housing administered through Spokane County, the incentive allows a property owner to have
the new construction value of a physical improvement to their dwelling exempt for three years
following the completion of the physical improvement, including the construction of an accessory
dwelling unit. The amount of exemption is the difference between the dwelling’s market value
before and after the improvements, not to exceed 30% of the original market value.
 Parking 2 People: This incentive is for the redevelopment of underutilized parking via a State
enabled sales and use tax deferral, which is meant to support construction of affordable housing.
Upon approval from the Department of Revenue, who issues a tax deferral certificate, an applicant
is able to defer the City of Spokane’s approximately 9% sales and use tax on applicable purchases
related to the housing being constructed. Fifty percent of the housing constructed through this
incentive is then maintained as affordable for 10 years for residents with an area median income
between 80-115% AMI.
 Commercial Building Conversion: This incentive is for the redevelopment of underutilized and
existing commercial buildings via a State sales and use tax deferral. Upon approval from the
Department of Revenue, who issues a tax deferral certificate, an applicant can defer the City of
Spokane’s approximately 9% sales and use tax on applicable purchases related to the housing
being constructed. Ten percent of the housing constructed through this incentive is then
maintained as affordable for 10 years for residents with an area median income at or below 80%
AMI.
 New Markets Tax Credit Benefits: This US Treasury program, authorized by Congress in 2000,
was created to increase the flow of private sector capital to projects that create jobs and provide
goods and services in distressed communities. NMTCs attract private investment by providing
banks with a 39% federal tax credit over seven years. The proceeds of these investments are used
as flexible, forgivable financing for a wide variety of projects, such as manufacturing/industrial,
health/medical centers, education facilities, and others. The benefit to a qualified NMTC project
results in a net subsidy of 20%+ of the tax credits a project attracts.
 Historic Tax Credits: There are incentives available to owners of designated historic properties
(commercial and residential) in the City of Spokane. This includes federal tax credits, property tax
waivers, and façade grants. For designated historic properties in Spokane, the Special Valuation Tax
incentive supports rehabilitation of historic properties by providing a 10-year property tax
reduction. This incentive can be combined with MFTE or Federal Historic Tax Credits.
 Opportunity Zones: Opportunity Zones (OZs) are a community development program
established by Congress to encourage long-term investments in low-income and urban
communities. Under the 2017 Opportunity Zones program, the City of Spokane was able to have
11 census tracts designated by the federal government for qualified OZ investment. The City is
working with the Governor’s Office to renominate census tracts under the renewed Opportunity
Zone legislation passed by the One Big Beautiful Bill. The existing and future census tracts are

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aligned with the Spokane Target Investment Area, and the City’s economic development strategy to
support investment in areas that have suffered disinvestment.
 Brownfields Program: Through partnership with the Environmental Protection Agency (EPA), the
City of Spokane applies for EPA-funded Brownfields grants that fund work to evaluate if
development, expansion, or redevelopment of property within the City might be complicated by
the presence or potential presence of a hazardous substance, pollutant, or contaminant. Property
owners can get financial assistance completing environmental site analysis, as well as technical
assistance from city staff and EPA staff. Examples of brownfield projects in Spokane include the
Riverpoint Campus east of Downtown, Kendall Yards, and Riverfront Park.
 Commercial Property Assessed Clean Energy + Resiliency (C-PACER): Administered by Spokane
County, this financing tool is an innovative financing mechanism to help commercial, industrial,
and multi-family buildings become more efficient and resilient. Property owners have access to low
interest loans, with longer payback terms, so that they can upgrade buildings to be more energy
efficient.

Focus Areas

Population and Household Characteristics
Except in industrial areas or places with vacant land, there are dense populations in most parts of the
city. The non-white population is more concentrated in the Northeast, Division, and Center City areas,
whereas there is a greater density of the white population in the Northwest and South study area.
Given the airport and employment uses, there is limited population in the West Plains. See Exhibit
3.5-20.

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Exhibit 3.5-20. Population Density and Race (2020)

Note: Some census blocks extend into unincorporated areas.
Source: 2020 Decennial Census.

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Households with higher median incomes tend to live in South Spokane. Households with greater levels
of poverty tend to be concentrated in the Center City and Northeast study areas. See Exhibit 3.5-21.

Exhibit 3.5-21. Income and Poverty

Median Household Income 2022 Percent of People Living in Poverty 2022

Sources: ACS 2022 5-Year estimates for block group, Table B19013 and ACS 2022 5-Year estimates for block group,
Table B17021.

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Neighborhood and Housing Condition and Affordability
Redlining is a “ranking system that categorizes neighborhoods as more or less impoverished largely
based on the race of the residents. Government maps were created so that banks could determine
where it was a “safe” bet to lend money to residents.” (Nelson, R. K., Winling, L, et al., 2023) As shown in
Exhibit 3.5-22, areas of Spokane were categorized into “grades” – the first grade in green signified the
lowest risk for lending, and the fourth grade, indicated in red, signified a “hazardous” risk area for
lending. The City’s Racially Disparate Impacts Analysis, found that “exclusionary zoning enacted by the
City of Spokane reinforced the impacts of redlining and racially restrictive covenants, wherein redlined
areas historically had a lower percentage of single unit zoning in residential areas which had a
segregating effect on BIPOC households and lower income households.” (City of Spokane, 2025)

Areas that were redlined have reduced tree canopy and green spaces, lower-quality housing, and
increased impervious surfaces, all of which exacerbate climate hazard risks. Redlined areas were also
subjected to practices like highway construction, railroads, toxic waste siting, and other uses that have
created health disparities. Redlined areas were located primarily in the Northeast and Center City as
well as portions of West Plains and South study areas near US 195.

As a long-standing city, Spokane has housing stock built in all eras since the 1880s. Most housing
throughout the city was built prior to 1960 and may lack more modern heating and cooling systems.
See Exhibit 3.5-23.

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Exhibit 3.5-22. Redlined Areas in City of Spokane 1938

Source: (Nelson, R. K., Winling, L, et al., 2023)

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Exhibit 3.5-23. Percent of housing units built before 1960

Source: ACS 2022 5-Year estimates for block group, Table B25034

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Affordable rental housing is found throughout the city, though less so in the North Indian Trail
neighborhood of the Northwest study area or Logan neighborhood of the Northeast study area.
More affordable areas for ownership housing include most of the Northeast study area excluding
Logan and Minnehaha neighborhoods, neighborhoods lining Division in the Northwest study area,
and most of the South area, excluding the East Central neighborhood. See Exhibit 3.5-24.

Exhibit 3.5-24. Affordability of Rental and Owner Housing

Source: (City of Spokane, June 2025)

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Jobs in Study Areas
Most jobs in the city are located in Center City and along the Division corridor, as well as in the
Northwest at the VA property and at the West Plains airport area. See Exhibit 3.5-25.

Exhibit 3.5-25. Total Jobs (2022)

Source: Census on the Map, 2022.

When breaking down total jobs into particular sectors, clear patterns emerge about the economic
ecosystem. Healthcare services are largely in the Center City and Division study areas. Retail jobs are
along multiple corridors and nodes, particularly in the Center City, Division, and Northwest areas.

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Some nodes are also found in the South study area. See Exhibit 3.5-26. Manufacturing jobs are in the
Center City and Northeast study areas. Transportation and Warehousing jobs are similarly in Center
City and Northeast, as well as West Plains.

Exhibit 3.5-26. Selected Job Sectors
Health Jobs Retail Jobs

Manufacturing Jobs Transportation/Warehouse Jobs

Source: Census on the Map, 2022.

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3.5.2 Impacts

Impacts Common to All Alternatives

Citywide

Capacity for Housing and Population Targets

This sub-section addresses the following thresholds:
 Ability of the alternative to provide sufficient buildable land capacity for population and housing.

All alternatives provide capacity for more than the total housing target of 21,738 between 2022 and
2046 based on the City of Spokane’s 2025 Land Capacity Analysis of Alternative 1 Stay the Course.
Alternative 1 provides total capacity for 30,165 dwelling units. See Exhibit 3.5-27. As described in
Chapter 2, Alternatives 2 and 3 propose to increase opportunities for low- and mid-rise housing,
increasing land capacity, as well as continue Alternative 1’s approach to middle housing. Once a
preferred alternative is developed, new zoning would be identified and the increased land capacity
determined.

Exhibit 3.5-27. Alternative 1 Land Capacity and Total Housing Target
AFFORDABILITY ANALYSIS TOTAL
Need (HAPT*) 2020-2046 22,359
2021-2022 Completes** 621
Remaining Total Target: 2022-2046 21,738
Alternative 1: LCA capacity *** 30,165
Notes: *HAPT – Housing for All Planning Tool
** Completes are based on the data available in the City of Spokane’s June 2025 Report, Accommodating Affordable
Housing. (City of Spokane, June 2025) As data is improved and evaluated, there may have been more housing
completions than reported which show progress in meeting the City’s housing target.
*** LCA – Land Capacity Analysis
Sources: City of Spokane, 2025, BERK 2025.

Since the population target is similar to the housing target, and all alternatives have housing capacity
exceeding the housing target, each alternative would more than meet population targets. See Exhibit
3.5-28.
 Population Target 2022-2046: 25,157 or 1.2 persons per household per target housing unit
 Population with Current Household Size: 50,650 or 2.33 persons per household per target housing
unit

Adding the new population to the existing population (2022) moderates the household size. See
Exhibit 3.5-28.

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Exhibit 3.5-28. Population and Household Size

BASED ON BASED ON
TARGETS TRENDS
Existing Population 2022 230,900 230,900
Net Change 2022-2046 25,157 50,650
Resulting Population 256,057 281,550
Existing Occupied Housing 95,604 95,604
Housing Target 21,738 21,738
Future Housing Units 117,342 117,342
Future PPHH 2.182 2.399
Source: OFM 2022, BERK 2025,

Housing Variety and Affordability

This section evaluates the following thresholds:
 Ability of the alternative to increase the supply, diversity, and affordability of market-rate housing.
 Ability of the alternative to increase the supply of income-restricted housing.
 Regulatory barriers to, and insufficient capacity for, the production of affordable units needed in
line with City’s role / requirements under HB 1220).

Housing Variety and Affordability

Housing types accommodated by all alternatives include single unit, middle housing, and higher
intensity multi units. Alternative 1 would not provide sufficient capacity in zones with potential to
support new units at 0-80% AMI affordability level, with a negative balance of -5,477. See Exhibit
3.5-29.

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Exhibit 3.5-29. Housing Capacity and Affordability – Alternative 1

Affordability Analysis 0-80% AMI 80-120% AMI 120+% AMI Total

Need (HAPT*) 2020-2046 15,347 2,588 4,424 22,359
2021-2022 Completes** 216 116 290 621
Remaining Total Target: 15,131 2,472 4,134 21,738
2022-2046
LCA capacity*** 9,654 8,036 12,475 30,165
Remaining target during -5,477 5,564 8,341 8,428
EIS evaluation period
2022-2046

Housing Types that Low Rise and Mid Moderate Low Intensity
typically serve needs Rise (walk-ups up Intensity (single-unit)
to 3 stories, (townhomes,
apartments, and duplex, triplex, 4-
condos) plex) + ADUs

Notes: *HAPT – Housing for All Planning Tool
** Completes are based on the data available in the City of Spokane’s June 2025 Report, Accommodating Affordable
Housing. (City of Spokane, June 2025) As data is improved and evaluated, there may have been more housing
completions than reported which show progress in meeting the City’s housing target.
*** LCA – Land Capacity Analysis
Sources: SRTC, 2024, City of Spokane, 2025, BERK 2025.

Alternatives 2 and 3 would allow for increased moderate to high intensity residential and mixed-use
designations in corridors or centers that increase opportunities for low- and mid-rise housing, typically
serving households with incomes at 0-80% AMI. Alternatives 2 and 3 would increase the multi-unit
housing shares from 35% under Alternative 1 to 41% per Chapter 2, Exhibit 2.2-6. Alternative 3 would
focus more density in the Center City and Division Corridor study areas as well as selected other
corridors, while Alternative 2 would add density to more corridors throughout the city. See Exhibit
3.5-30.

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Exhibit 3.5-30. Housing Types by Alternative

Density Group Alternative 1: Maximum Assumed Action Alternatives
Housing Types Density Density 2 And 3
Allowed Allowed

Low Intensity Single-Unit and 10 5-9 du/ac Alternatives 2 and 3
Residential Middle Housing (approximate) implement Middle Housing
Middle Housing 20 similar to Alternative 1
(approximate)

Moderate Middle Housing 30 29 du/ac Under Alternatives 2 and 3
Intensity and Multi-Unit (approximate) along frequent transit
Residential corridors: Increased
High Intensity No Limit moderate and high
Residential intensity residential areas,
supportive of Low- and
Mid-Rise Housing

Non-Residential, Middle Housing No Limit 30.2 du/ac in Under Alternatives 2 and 3
Excluding and Multi-Unit 33% of the along frequent transit
Industrial development corridors and Alternative 3
in the Center City:
Increased Mixed-use areas,
Supportive of Low and Mid
Rise

Downtown Middle Housing No Limit 44.4 du/ac in Under Alternative 3 in the
and Multi-Unit 33% Center City and selected
of the corridors: Increased share
development
of residential at higher
densities

Sources: (City of Spokane, June 2025); BERK 2025.

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Reflecting the housing targets and added low- and mid-rise housing, Alternatives 2 and 3 alter the
share of growth that is multi-unit housing; however, in 2046 the majority of housing citywide would
still be single-unit. See Exhibit 3.5-31.

Exhibit 3.5-31. Housing Mix 2022 and 2046 by Alternative

Single Unit Multi-Unit

EXISTING (2022) 65,989 35,786

ALTERNATIVE 1 77,931 45,581

ALTERNATIVE 2 72,445 51,068

ALTERNATIVE 3 72,439 51,074

Source: SRTC, 2022; BERK 2025.

Floor Area Ratios Along Bus Rapid Transit Lines

Under current zoning (Alternative 1) the City of Spokane already provides sufficient FARs along the City
Line except along the eastern portion of the line where lower intensity is planned. See Exhibit 3.5-15.

Alternatives 2 and 3 provide for added Mixed Uses/Commercial and High Density Residential along the
City Line, and Alternative 3 provides more extensive Mixed Uses/Commercial areas beyond the City
Line corridor. Thus, the City would meet the FAR requirements with these alternatives. Additional code
amendments would be needed under any studied alternative to address inclusionary affordable
housing, multifamily tax exemption amendments, and mass timber incentives. The City may also
request a portion of the area be exempt for five years in areas of high risk of displacement (e.g., East
Mission Avenue east of river) subject to the Department of Commerce approval.

Permanent Supportive and Emergency Housing

The City’s housing targets include a share of housing that is permanent supportive housing (“PSH”)
that would mean the addition of 1,851 PSH housing units between 2020 and 2046. The allocation of
emergency housing is 983 beds. Under all alternatives, the City would continue programs and
regulations to address homelessness. It addresses temporary shelter, re-housing, transitional housing,
and permanent supportive housing. See Exhibit 3.5-32.

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Exhibit 3.5-32. City of Spokane – Compassion Spokane Approach to Homelessness

Source: (City of Spokane, Undated)

HB 1220 (2021) requires jurisdictions to update their development regulations with respect to
emergency shelters, transitional housing, emergency housing, and permanent supportive
housing (STEP). The current Spokane Municipal Code requirements for some STEP uses are
sufficient to meet the requirements of HB 1220; thus, all alternatives would likely comply with
this requirement. However, development of new housing in the most affordable bracket
(either PSH or non-PSH) would not meet the requirements of HB 1220 due to the availability
of land in more affordable locations. Conversely, the action alternatives provide capacity for
housing at all income levels, update the Housing Element policies on emergency and
permanent housing, and implement code amendments to address STEP housing.

Implementation of Housing Action Plan

The City has implemented many recommendations of the Housing Action Plan (HAP) under Alternative
1 Stay the Course, such as allowing for middle housing, creating a Target Investment Area (see Exhibit
3.5-19) and incentives, addressing short-term rentals, numerous updates to Accessory Dwelling Unit
standards, and more. Action alternatives would advance more HAP strategies to streamline permitting
under the SEPA infill exemption and SEPA exemption thresholds, improve infrastructure in centers
and corridors, target higher intensity development to where there is ready access to transit, and

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address other strategies to reduce racially disparate impacts consistent with new Housing Element
requirements. See Exhibit 3.5-33.

Exhibit 3.5-33. Housing Action Plan Strategies Advanced under Alternatives
 Strategy Implemented  Strategy Under consideration with EIS Alternatives

Alt. 1 Alt. 2 Alt. 3

A. Increase housing supply, options, and affordability for all incomes.
A1. Explore and expand allowed housing types to encourage   
missing middle housing throughout Spokane’s neighborhoods.
A2. Target efforts to increase the development of affordable   
housing throughout the city to support mixed-income
neighborhoods.
A3. Continue to streamline and simplify changes to the City’s  
permit process, as necessary.
A4. Leverage infrastructure and investment, including near high-  
performance transit stops, in Centers and Corridors, the
downtown core, and other targeted areas to increase housing
supply.
A5. Revise Accessory Dwelling Unit standards to allow for   
additional flexibility.
A6. Leverage public and partner-owned7 land for housing,
including a land bank. (not yet implemented)
B. Preserve existing housing affordability and quality to help people
thrive where they live.
B1. Expand preventative and proactive code enforcement to help
maintain safe and quality housing. (not yet implemented)
B2. Align and leverage programs, funding, and resources to   
preserve the quality and livability of existing affordable housing.
B3. Enhance protections and assistance for renters, particularly  
the most vulnerable.

7
The HAP described examples of partners as Spokane Public Schools and the Washington Department of
Transportation.

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Alt. 1 Alt. 2 Alt. 3
B4. Maintain and improve existing affordable rental housing.   
B5. Study the local short-term rental market to reduce impact on   
housing affordability, neighborhood identity, and displacement.
C. Enhance equitable access to housing and homeownership.
C1. Reduce barriers and expand access to housing and  
homeownership for lower income households, first-time
homebuyers, people of color, and people with disabilities.
C2. Address racial inequities and disparities in housing.  
C3. Preserve and stabilize the viability of existing homeownership  
for low-income homeowners.
D. Leverage and grow partnerships to support housing initiatives
across the region.
D1. Support growth management planning which best meet the   
Comprehensive Plan’s goals and policies.
D2. Leverage partnerships within the health, education, parks, and  
transportation fields to support housing affordability, access to
opportunity and quality of life.
D3. Grow and expand use of both local and regional housing data  
and analysis.

 Strategy Implemented
 Strategy Under consideration with EIS Alternatives and updated Housing Element per HB 1220 and other laws.

Equity and Disparate Impacts

This section addresses the distribution of housing, employment opportunities, and neighborhood
amenities, and the potential that alternatives could adversely or positively affect overburdened
communities and vulnerable populations. The thresholds include:
 Amount of new housing in areas with high displacement risk.
 Projected loss of homes due to demolition in high displacement risk areas.
 Amount of new housing in connected and accessible neighborhoods (transit, libraries, parks).
 Potential for job or business displacement for employment uses located within medium/high
intensity residential or mixed-use designated areas.

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Residential Displacement

A 2025 Pew study found that new housing production slows rent growth throughout a metropolitan
region, but it takes the most pressure off of older, less-expensive housing (Seva Rodnyansky, 2025).
While all alternatives assume the same amount of total new housing production, Alternatives 2 and 3
would provide a greater diversity of new housing compared to Alternative 1. These alternatives are
expected to increase the supply of apartments and other rental housing options, with potential to
have the greatest impact on moderating housing cost escalation among the city’s existing rental
housing stock. As a result, Alternatives 2 and 3 are expected to reduce economic displacement
pressure for current and future low-income renter households, including vulnerable households in
areas of highest displacement risk, when compared to Alternative 1.

While rising housing costs are currently the most significant contributor to displacement pressure in
Spokane, there is also potential for physical displacement when older housing units are demolished to
make way for new development. Between 2010 and 2024, an average of 76 housing units were lost to
demolition each year in Spokane, and the loss of older homes is expected to continue under all
alternatives.8 In some cases, the demolished homes are relatively affordable compared to new market
rate housing. And in some cases, the demolition of older homes can result in the physical
displacement of lower-income renter households who resided in those older units.

While it is impossible to predict whether a demolition will result in the displacement of a household, it
is possible to estimate the types of homes that will be demolished and their approximate affordability
level.9 Exhibit 3.5-34 compares the alternatives with regards to projected demolitions by housing type.
Alternative 1 focuses more of its total housing growth in areas of the city with vacant land where fewer

8
Source: Washington State Office of Financial Management, 2025; BERK, 2025.
9
To estimate the number of existing housing units that could be demolished as a result of redevelopment, BERK
utilized land capacity analysis data. Specifically, for each transportation analysis zone (TAZ) we calculated the
total number of existing housing units on redevelopable parcels and divided this by the total capacity for new
housing development. BERK then multiplied this "demolition ratio" by the projected housing growth in the TAZ to
estimate the number of existing housing units that may be demolished during the planning period. This method
is likely to produce a conservatively high estimate of demolitions given that new development is more likely to
occur on vacant parcels or those with no existing homes (such as an empty parking lot or strip mall). Additionally,
zoning changes associated with each action alternative would increase capacity in many TAZs, which would
reduce the demolition ratio.
To estimate demolished units by housing type, BERK first calculated for each TAZ the percentage of existing units
on redevelopable parcels that are single unit and the percentage that are in multi-unit buildings. We then applied
these percentages to the total estimated demolished units in each TAZ to calculate demolished units by housing
type.
To estimate the affordability level of each demolished unit, BERK leveraged prior City work that identified the
typical affordability level of existing ownership and rental units by area of the city in Accommodating
Affordability Housing in the City of Spokane, Washington, June 2025. For each TAZ, we applied the ownership
affordability level to demolished single-unit homes and the rental affordability level to demolished multi-unit
homes.

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existing housing units are expected to be demolished to make way for new development. Alternatives
2 and 3, on the other hand, focus more growth in established areas of the city where more new
construction will occur through redevelopment. As a result, Alternatives 2 and 3 are expected to
demolish over twice as many housing units when compared to Alternative 1. In all alternatives, most of
those units demolished are detached single unit houses where the previous residents could be
homeowners or renters. A smaller number of demolished units are expected to be multifamily
housing, which is much more likely to be occupied by renters.

Exhibit 3.5-34. Projected Housing Units Demolished by Housing Type

0 500 1,000 1,500 2,000 2,500

Alternative 1 235 849

Alternative 2 493 1,697

Alternative 3 487 1,698

Multi-Units Single Unit Houses

Sources: City of Spokane, 2025; BERK 2025.

Exhibit 3.5-35 shows projected demolished units by affordability level. It is expected that most of
these units would be affordable at the moderate (80-120% AMI) or high (120%+ AMI) income level. This
is because demolished units are predominantly older single unit homes. Compared to Alternative 2,
Alternative 3 is anticipated to have slightly fewer units demolished at 50-80% AMI and 80-120% AMI
levels and slightly more at the 120%+ AMI level.

Exhibit 3.5-35. Projected Housing Units Demolished by Affordability Level

0 500 1,000 1,500 2,000 2,500

Alternative 1 185 304 595

Alternative 2 399 1,264 526

Alternative 3 394 1,176 615

50-80% AMI 80-120% AMI 120% AMI +

Sources: City of Spokane, 2025; BERK 2025.

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Exhibit 3.5-36 shows projected demolished units by study area. There would be a similar number of
demolished units in Northeast, Northwest, and South Spokane under Alternatives 2 and 3. There are
slightly more units demolished in Center City under Alternative 3 than Alternative 2.

Exhibit 3.5-36. Projected Housing Units Demolished by Study Area

0 500 1000 1500 2000 2500

Alternative 1 156 247 363 305 13

Alternative 2 197 710 731 548 4

Alternative 3 227 727 697 534 0

Center City Northeast Spokane Northwest Spokane South Spokane West Plains

Sources: City of Spokane, 2025; BERK 2025.

Exhibit 3.5-37 shows the expected units demolished by the area’s displacement risk score. With more
growth focused in already developed areas along corridors and centers such as Division, Center City,
and others, there is more development expected in areas with high displacement risk under
Alternatives 2 and 3, compared to Alternative 1. This results in significantly more homes demolished in
these areas. However, the flipside is also true. These neighborhoods would also receive more new
housing production and greater diversity of housing options. Alternatives 2 and 3 will incorporate anti-
displacement measures that mitigate displacement risk. This is expected to reduce economic
displacement pressure compared to Alternative 1. See Exhibit 3.5-38.

Exhibit 3.5-37. Projected Units Demolished by Displacement Risk Score

Displacement Risk Displacement Alternative 1 Alternative 2 Alternative 3
Score Risk Level
1 Low 127 87 44
2 163 171 170
3 Medium 332 182 220
4 121 345 379
5 High 341 1,404 1,372
Total 1,084 2,190 2,185
Sources: City of Spokane, BERK 2025.

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Exhibit 3.5-38. Potential to Reduce Economic Displacement Pressure

Ability to Reduce Economic Development Pressure Alt 1 Alt 2 Alt 3

Potential Capacity for New Housing Production ○ ●+ ●+
Potential Capacity to Increase Housing Diversity ○ ● ●+
Anti-displacement Measures included in Plan and Programs ○ ●+ ●+
Legend: ○ = partially supports ●=supports ●+ = optimally supports

Housing in Connected and Accessible Neighborhoods (transit, libraries, parks)
Community Amenities

Community amenities such as schools, libraries, parks, and community centers provide important
educational, social, and recreation resources that enhance livability. However, studies have shown that
housing costs can rise faster in the vicinity of these amenities, such as next to new parks and parks in
downtowns (Trust for Public Land, 2024). Housing and property values support school funding
through property taxes and more funding for schools can support home appreciation (Savageau,
2023). Multiple amenities are near each other in the downtown, Liberty Park, the Northeast
Community Center, and Shadle Park, including in several tracts considered to have higher
displacement risk. See Exhibit 3.5-39.

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Exhibit 3.5-39. Amenities by Census Tract: Schools, Libraries, Parks, and Community Centers

Source: (City of Spokane, 2025)

Transit and Home Values

A 2017 study of bus rapid transit (BRT) and home prices found that BRT routes positively impact
surrounding single-unit home sale prices, with closer homes having higher sales prices than those
located further from the route (Perk, 2017). A study of development along BRT and household
socioeconomics in Vancouver, B.C. found “proximity to rapid transit infrastructure increases the
attractiveness of nearby areas and results in a larger share of higher-income renters who can
potentially price out lower-income households if the supply of affordable housing remains the same”
(Kapatsila, 2024). The study notes examples of pairing transit-oriented development and affordable
housing policies to increase affordable housing supply as part of transit system planning in the Puget
Sound and Portland, Oregon.

A July 2025 study by the Urban Institute for Washington State regarding transit-oriented development
(TOD) and transit found that, of the cities studied in Washington state, Spokane had limited transit and
low housing costs, and average rents near Spokane’s BRT stations are lower than those in the rest of

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the city. Spokane was considered to be a community with “limited transit, low housing costs” along
with Everett and Tacoma, as well as others. As a group, the study found:
 Attracting development, especially retail, is hard because of limited market demand.
 Rents are increasing more quickly than incomes, putting families at risk.
 Many people living near transit do not take advantage of the system.

In higher cost cities with more ample transit like Seattle, Bellevue, and Redmond, the study found
some gentrification may be occurring near transit where households with higher incomes are
choosing to move. Overall, the study indicates that “displacement of residents with low or moderate
incomes may … be occurring near transit in some cities. But we caution that we have inadequate
evidence to definitively prove whether displacement is occurring. It is possible that some families with
low incomes may choose to pay more for housing in exchange for the reduced transportation costs
made available thanks to transit investments.” The report recommends developing higher housing
densities and encouraging small businesses near transit routes, funding infrastructure grants to lower
tax base municipalities along transit routes, reducing pollution exposure of highway-adjacent transit
areas, and investing in affordable housing. It also recommends expanding the capacity of public
entities, including transit agencies, to facilitate housing development (Urban Institute, 2025). It
identifies the benefits of increasing densities near transit under HB 1491 and offers recommendations
to further improve the law with infrastructure investment funds and minimum floor area ratios.

Commercial and Industrial Business Displacement

This evaluation considers the potential that commercial or industrial buildings and businesses could
see investment or change where there are:
 Commercial and industrial buildings on “underutilized” parcels where parcel value is higher than
building value.
 Commercial and industrial buildings built pre-1985.

The parcels with these characteristics are shown in Exhibit 3.5-40.

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Exhibit 3.5-40. Commercial and Industrial Properties likely to Redevelop

Sources: Spokane County Assessor, BERK, 2025.

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If the alternatives apply land use designations and implement zoning with limitations on employment,
there could be displacement of existing buildings. If the alternatives increase allowances for mixed-
uses or housing existing businesses may be displaced or unable to afford new space in mixed use
developments due to rising costs; however, it is also possible that added residents in or near
commercial areas can provide additional customers allowing businesses to successfully occupy new
space.

In areas where the land use designations and implementing zones remain similar (such as industrial
areas), these sites may be good candidates for further investments in commercial or industrial uses.
Zoning in the Division Corridor is largely multi-unit and commercial under Alternative 1. The number
of parcels that could be redeveloped is high and more intense residential density could lead to
displacement under Alternatives 2 and 3. Recent studies suggest that gentrification is not happening
near transit; however, rents are increasing faster than incomes in the cities that, like Spokane, have
less transit use and are lower cost cities (Urban Institute, 2025). See Exhibit 3.5-41.

The alternatives largely plan for industrial, both light and heavy, in similar locations as zoned under
Alternative 1, but more intense employment is planned, particularly under Alternative 3. There are
parcels with older industrial buildings that could see change such as the addition of new businesses
but still remain industrial.

Exhibit 3.5-41. Employment Growth and Potential for Redevelopment and Displacement

Region Alternative 1 Alternative 2 Alternative 3

Northwest In areas with redevelopable Distributed mixed-uses and Greater growth along
properties, there could be commercial uses on selected corridors
moderate growth on W corridors at a slightly lower particularly north-south
Northwest Blvd, N Monroe level than Alternative 1. corridors like N Monroe
Street and N Maple Streets. Lowest potential for and to W Northwest Blvd.
Moderate potential for displacement. Greater potential for
displacement. displacement.

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Region Alternative 1 Alternative 2 Alternative 3
Northeast Moderate growth on Higher growth on more Higher growth on selected
corridors such as E Francis corridors with existing corridors such as the E
Avenue, E Fairview Avenue, businesses such as E Mission Avenue corridor
E North Foothills Dr, and N Francis Avenue and and portions of N Hamilton
Market Street. portions of N Hamilton Street.
Moderate growth in Hillyard Street. Moderate-high job growth
on redevelopable Moderate growth in Hillyard in Hillyard on
properties. Continued, on redevelopable redevelopable properties.
expanded, or new industrial properties. Continued, Continued, expanded, or
uses. expanded, or new industrial new industrial uses. Higher
uses. displacement due to North
Spokane Corridor. Higher
residential displacement
risk could affect cultural
institutions and local
businesses.
Division Moderate growth with Focused mixed-use growth Greater growth and wider
potential to change at north and south ends of extent along the corridor
redevelopable properties Division Street with modest with greater potential for
along Division Street. job growth in between. redevelopment or
Moderate potential for Lesser potential for displacement.
displacement. redevelopment or
displacement.
Center City Moderate growth in North Moderate growth in Greater job growth in
Bank, Downtown Core, and Medical district. Moderate Downtown Core, North
Medical District, and lower potential for displacement. Bank, and Medical District.
growth in South Logan. Planned growth in South Greater potential for
Moderate potential for Logan per new subarea displacement.
displacement. plan. Planned growth in South
Logan per new subarea
plan.
South Higher growth in smaller Moderate growth along Less area identified for
nodes along corridors with corridors with S Grand, E change than Alternative 2.
S Grand, E 29th Avenue, and 29th Avenue, S Regal, and S Moderate-higher job,
S Regal and S Freya Streets. Freya Street. Moderate particularly along southern
Higher potential for potential for displacement. end of transit corridors.
displacement. Moderate potential for
displacement.

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Region Alternative 1 Alternative 2 Alternative 3
West Plains Moderate industrial growth Moderate industrial growth, Moderate-higher industrial
in airport vicinity; much with more north of airport. growth in airport vicinity
land in the area is vacant. Displacement is not throughout airport vicinity.
Displacement is not anticipated as described Displacement is not
anticipated though under Alternative 1. anticipated as described
expansion and further under Alternative 1.
investment is possible.

Sources: SRTC, 2022, BERK 2025.

Employment
Balance of Jobs and Housing
Employment types, employment levels, and proximity of
housing and jobs are key topics for the Land Use, Some communities may wish to seek a greater
Housing, and Economic Development elements under balance of jobs and housing for more complete
the Periodic Update (see text box). The employment neighborhoods where people can live and work
thresholds of significance examined include: in the same area. This proximity improves work-
life balance, reduces greenhouse gas emissions,
 Ability to adversely affect citywide Jobs/Housing
and improves overall quality of life. This may
balance.
require stronger policies to support new
 Job types and quantity and ability to advance City businesses and appropriately zoned land. If the
and regional economic development strategies. economic development strategy will attract more
The City of Spokane is a job hub in the Inland Empire, employers and new jobs, it should also consider
and there are slightly more jobs in relation to housing housing for those new workers and their
units. A higher ratio of jobs to housing could increase prospective incomes. (Washington State
commuting into the city unless there is an increase in Department of Commerce, 2023)
housing at all affordability levels to accommodate
commuters.

Alternatives 1 and 3 increase the share of jobs relative to housing whereas Alternative 2 generally
holds the current jobs/housing balance. See Exhibit 3.5-42.

Exhibit 3.5-42. Jobs/Housing Balance

2022 ALTERNATIVE 1 ALTERNATIVE 2 ALTERNATIVE 3

Jobs Housing Jobs Housing Jobs Housing Jobs Housing
Totals 121,781 101,774 157,065 123,512 146,720 123,512 160,629 123,512

Jobs/ Housing Ratio 1.20 1.27 1.19 1.30

Source: SRTC 2022, BERK 2025.

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Under all alternatives, most jobs are in Northeast Spokane and Center City. West Plains will see a large
change compared to present. Job increases in Northwest Spokane will be modest. See Exhibit 3.5-43.

Exhibit 3.5-43. Jobs in Study Areas by Alternative

180,000

160,000
12,994 13,535
140,000 12,914
25,970 26,720
120,000 5,966 23,652
18,539 26,432 26,636
100,000 24,080
20,281
80,000
49,895 50,786
60,000 47,187
41,048
40,000

20,000 35,947 41,773 38,888 42,952

-
2022 Alternative 1 Jobs Alternative 2 Jobs Alternative 3 Jobs
2046 2046 2046

Center City Northeast Spokane Northwest Spokane South Hill/South Spokane West Plains

Sources: SRTC 2022; BERK 2025.

Detailed job sector projections are not available for 2046 but based on historic trends and mid-period
projections for 2034 by the Spokane Workforce Council shows continued growth in healthcare and
other services. (Spokane Workforce Council, 2025)

Alternative 1: No Action, Stay the Course
Alternative 1 No Action, Stay the Course provides capacity for total housing targets and partially meets
the housing targets by affordability for those with incomes at 80-120% and above AMI. Alternative 1
incorporates housing policy and code changes made as a result of the HAP such as middle housing
and targeted investment areas, but it does not update the housing element and would not make
additional changes to undo racially disparate impacts and address displacement from past decades of
planning that prioritized single unit zoning and less investment in formerly redlined areas, and it
would not add code amendments to streamline permitting as recommended in the Housing Action
Plan (City of Spokane, 2021). Alternative 1, however, would meet population targets.

Alternative 1 would have a lower share of multi-unit housing forms than alternatives 2 and 3. It does
not include the new housing and jobs anticipated in the South Logan Subarea Plan.

Alternative 1 provides mid-range jobs and focuses the jobs in center and corridors. It does not update
economic development element policies and would not address additional commercial displacement

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strategies. It would increase the jobs-housing ratio which assumes a higher rate of jobs than
historically achieved. (See Section 3.7 Transportation.)

Alternative 1 provides more housing on vacant land and would have less physical displacement
impacts than Alternatives 2 and 3 but it would not increase capacity for housing most likely to be
affordable to lower income households and it would have a greater potential for adverse impacts in
terms of economic displacement pressure.

Alternative 1 does not propose changes to land use designations or development standards around
the City Line BRT stations. It would not meet the provisions of HB 1491 for a 3.0 FAR in each BRT
station area in the Chief Garry Park vicinity. It would not provide additional anti-displacement
measures in the Comprehensive Plan.

Alternative 2: Distributed and Balanced
Alternative 2 Distributed and Balanced provides capacity for total housing targets and fully meets the
housing targets by affordability for all incomes by providing more mixed-use and residential medium
and high intensities designed to support low- and mid-rise development that is more affordable. There
would be a higher share of multi-unit housing compared to Alternative 1. Alternative 2 would include
the new housing and jobs anticipated in the South Logan Subarea Plan.

Alternative 2 has the potential to displace existing housing particularly single-unit detached homes
and some multi-unit homes (see Impacts Common to All Alternatives) but there is a greater capacity
for housing supply that should reduce the pressure of economic displacement. Compared to
Alternative 3, Alternative 2 is anticipated to have slightly more units demolished at 50-80% AMI and 80-
120% AMI levels and slightly less at the 120%+ AMI level. Alternative 2 would also establish anti-
displacement housing policies. See Mitigation Measures particularly Exhibit 3.5-44. With most units
demolished likely being single-unit, either owner or rental, anti-displacement programs addressing
ownership housing or housing choice may be appropriate. Anti-displacement measures that promote
low-rise and mid-rise housing along frequent transit routes would assist in providing housing that is
more affordable, such as increasing allowable building heights along transit corridors.

Alternative 2 fully updates the housing element. Racially disparate impacts are addressed by allowing
for more forms of ownership housing (e.g., co-housing) and multi-unit developments in single unit
dominated areas, as well as where there is more investment in transit. In support of the Housing
Action Plan, Alternative 2 adds code amendments to streamline permitting through an infill exemption
and raising SEPA thresholds (City of Spokane, 2021). Alternative 2 would meet population targets.

Alternative 2 increases jobs along corridors and adds mixed-use zoning in more locations, and has the
potential to displace existing businesses along more corridors than Alternative 3, but measures to
reduce business displacement could be implemented per Exhibit 3.5-44. Its balance of jobs and
housing is similar to the ratio found today. It has fewer total jobs than Alternatives 1 and 3. (See
Section 3.7 Transportation)

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Alternative 2 updates economic development element policies and addresses additional commercial
displacement strategies.

Alternative 2 proposes Mixed Use Commercial and High-Density Housing along the Center Line in the
Chief Garry Park Vicinity. This could result in implementing zoning addressing the FAR requirements of
HB 1491. Alternative 2 also proposes anti-displacement policies which would be important in the
context of housing intensification along the TOD route.

Alternative 3: Center City and Regional Hubs
Alternative 3 meets all housing targets at all affordability levels like Alternative 2. It increases the share
of multi-unit housing in low- and mid-rise formats to help close the gap in housing affordable to those
with incomes of 0-80% AMI. As with Alternative 2, there would be a higher share of multi-unit housing
compared to Alternative 1. Alternative 3 would include the new housing and jobs anticipated in the
South Logan Subarea Plan.

The housing intensities would be highest in Center City and selected corridors like Division and where
there is frequent transit, such as along Routes 4 and 23 that extend from the Northwest to the South.
Compared to Alternative 2, Alternative 3 is anticipated to have slightly fewer units demolished at 50-
80% AMI and 80-120% AMI levels and slightly more at the 120%+ AMI level. There is a potential for
displacement of existing housing (see Impacts Common to All Alternatives) but there is a greater
capacity for housing supply that should reduce the pressure of economic displacement. Like
Alternative 2, most units that could potentially be demolished are single-unit, owner or rental, and
programs that address both needs are important as shown in Exhibit 3.5-44. See Mitigation Measures
below.

Similar to Alternative 2, Alternative 3 would also update the housing element and institute some
actions to streamline permits as recommended in the HAP.

Alternative 3 provides the highest number of new jobs and would increase the jobs/housing ratio. It
would boost jobs in the larger job hubs in Center City such as in the Medical District and University
District as well as the Downtown Core. (See Section 3.7 Transportation.) It has the potential to
displace some existing commercial jobs on corridors, but fewer corridors would be affected, and
existing job hubs would be a focus of new jobs, compared to Alternative 2.

Like Alternative 2, this alternative addressing Center City and Regional Hubs updates economic
development element policies, together with additional commercial displacement strategies.

Similar to Alternative 2, Alternative 3 proposes Mixed Use Commercial and High-Density Housing along
the Center Line in the Chief Garry Park Vicinity, which should support consistency with requirements
of HB 1491. Likewise, anti-displacement policies which would be important in the context of housing
intensification along the TOD route.

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3.5.3 Mitigation Measures

Incorporated Plan Features
PlanSpokane 2046 includes an updated housing element that addresses housing growth targets at all
income levels. It also includes an evaluation of racially disparate impacts and displacement and makes
adequate provisions to remove barriers to housing.

The City is updating its Economic Development Element to address the 2026-2046 period.

Regulations and Commitments
The City of Spokane’s 2021 Housing Action Plan provides short, medium, and long-term strategies to
address the community’s housing needs. A number of strategies have been implemented as described
in Exhibit 3.5-33.

StartUp Spokane is a program of Greater Spokane Inc., which in partnership with the Spokane Public
Library and Spokane County Library provides business resources for entrepreneurs.

The Small Business Administration Strategic Alliance Memorandum was signed by the U.S. Small
Business Administration, City of Spokane, and the AHANA Multi-Ethnic Business Association in
September 2022. It establishes a heightened level of commitment to work together to bring services to
underserved populations of entrepreneurs.

Other Potential Mitigation Measures

Residential Anti-Displacement Strategies
The City’s Housing Action Plan (City of Spokane, 2021) identifies potential displacement risk and
evaluates potential strategies. It recommends additional research and ongoing monitoring of
displacement factors. The City is developing its suite of policies in the updated housing element based
on the City’s RDI evaluation. See Exhibit 3.5-44.

Exhibit 3.5-44. Summary Matrix of Housing and Business Anti-Displacement Measures

Measure Details Target

Community Engage early and often with neighborhood stakeholders Community
Engagement to ensure all voices are heard.

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Rental Assistance A Rental Assistance Fund is a relatively low-cost way to Community
Fund minimize the impacts of displacement on the most
economically vulnerable populations. The Fund could be
capitalized through development-related fees or through
government or grant subsidy. The Fund would be
available to those residents needing relocation cost
assistance or to cover security deposit requirements or
moving expenses.
Tenant Protections Support residential anti-displacement strategies for Community,
tenants, including relocation assistance, rent Residential
stabilization, and ‘right to return’ policies that give
highest preference for housing support due to
displacement from new development
Community Consider a “community preference” policy which Community,
Preference Program establishes preference for existing residents of the Residential
community in applications for affordable housing units to
allow for disadvantaged residents of high displacement
areas to access priority to new affordable housing units
which could directly address displacement.
Right-to Purchase Provides tenants and cities with the right to purchase Community,
Programs government-assisted multifamily rental properties and Residential
mobile home parks when the owner decides to sell a
property or exit an affordable housing program. This right
is typically provided to qualified nonprofit organizations
with the intent to keep current tenants housed and to
prevent disruption of residence.
Community Land Land acquired by public agencies, nonprofits, or Community,
Trusts community-based organizations that maintain permanent Residential
ownership of land. Prospective homeowners are able to
enter long-term (i.e., 99-year), renewable leases at an
affordable rate. Upon selling, homeowners only earn a
portion of the increased property value, while the trust
keeps the remainder, thereby preserving affordability for
future low- to moderate-income families.

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Housing Promote City programs that support affordable Residential
Rehabilitation homeownership, including single-unit rehabilitation
programs and essential home repair programs to help
low- and moderate-income homeowners with home
maintenance for health and safety.
Land Bank Land banks can used in service of other forms of public Residential
benefit, which might include in the creation of affordable
housing and the development of properties which offer
below-market commercial space, both of which
contribute directly to anti-displacement goals.
Use of Development A development agreement is a contract between a city Residential
Agreements and a property owner which summarizes responsibilities
associated with redevelopment of land. Development
agreements are highly customized and specific to a
particular site to maximize public and private benefits.
Development agreements can be a useful tool to
document an agreement between the City and the
property owner to guide development towards certain
policy goals, including the creation of housing.
Minimum Density Setting a right-sized minimum density to be structured as Residential
Requirements an incentive rather than as a requirement. If the density
requirement is set at too high a level, development could
be discouraged in the near- and medium-term, a
counterproductive and unintended consequence. If the
requirement is too low, opportunities to add density in
strategic locations could be less than capacity.
Credit support for Lack of sufficient financial capacity is typically the primary Residential
small-scale barrier to financing of small projects and stands in the
developers way of a citizen-developer corps who can do the hard but
valuable work of locally-led, tactical, small-scale
development.
Subsidy for less Land trusts, limited-equity cooperatives, and co-housing Residential
common ownership are relatively rare in the United States, but can be
models powerful models for long-term affordability and anti-
displacement protection.
Middle Housing Continue to remove barriers to the development of Residential
middle housing, which can provide for greater housing
choice and affordability.

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Affordable Housing In Spokane, projects with 25% or more units designated Residential
Density Bonus as “affordable” are granted expanded ground floors
(building coverage) and additional floor area. Affordable
housing bonuses can expand beyond these provisions to
include bonus height, density, and waivers to typical costs
such as off-site infrastructure impact fees.
Public Investments Building housing along older commercial corridors can Residential
In Infrastructure To involve hidden risks and challenges. Chief among those
Support risks is uncertainty and cost associated with older
Development infrastructure like sewer, water, and electricity. Cities,
regional governments, and states can play a role in
accelerating housing production by making investments
in aging sewer, water, and electric infrastructure at a
neighborhood-wide scale to reduce financial barriers to
housing development.
Low-Cost Rental Preventing displacement and preserving "naturally Residential
Housing occurring" affordable housing through acquisition, low-
Preservation interest loans/revolving loan fund for preservation,
and/or code enforcement. Example: The Oregon
Legislature committed $15 million in lottery bonds to
Oregon Housing and Community Services (OHCS) in 2019
to create a naturally occurring affordable housing loan
fund modeled after the Greater Minnesota Housing Fund.
Encourage the use of historic preservation credits and
grants for multi-unit housing where the building would
retain that housing after preservation.

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Public Development PDAs play a critical role in addressing displacement Commercial,
Authority (“PDA”) pressures arising from rising housing costs and Residential
gentrification in urban environments. These authorities
can implement a range of strategies to promote equitable
development and prevent the displacement of vulnerable
residents and businesses. Consider structuring PDAs to
respond to community needs, like the example of Cultural
Space Agency (CSA) in Seattle, which is a Public
Development Authority that secures long-term affordable
cultural space with community partners. Cultural spaces
forestall cultural displacement by giving community
members a place to assemble, organize, celebrate, and
create a sense of connection. CSA partners with
communities of color to create opportunities for
ownership of commercial cultural space.
Reduce or Eliminate Reduce or eliminate parking requirements, in exchange Residential,
Minimum Parking for a contribution in lieu which furthers the public Commercial
Requirements benefit.
Building Heights Support increasing allowable building heights along Residential,
transit corridors. Consider pairing with neighborhood Commercial
Design Standards, especially in critical, high visibility
areas.
Commercial Anti- Create and implement commercial anti-displacement Commercial
Displacement strategies to keep and give preference to local, historic,
and unique businesses in redevelopment
Flexibility for Ground Flexible ground floor standards that permit but do not Commercial
Floor Retail require retail, or require a smaller portion of the ground
Requirement floor (e.g., corner space of buildings at intersections),
would allow opportunities for retail to flourish in the right
locations without also creating an impediment to new
housing construction. Certain ground floor design or
construction standards such as minimum floor heights
can be employed to ensure flexibility to convert
residential or “flex” space to convert to retail over time
should demand for retail space increase in a particular
location.

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Tax Increment Tax Increment Financing (TIF) can be used for the Commercial
Financing (“TIF”) “purchasing, rehabilitating, retrofitting for energy
efficiency, and constructing housing for the purpose of
creating or preserving long-term affordable housing,”
RCW.39.114. The City currently only has one such TIF
operating, with other opportunities possible.
Facilitate Public- Partner with institutional partners, like universities, to Commercial
Private support business and economic development in strategic
Partnerships areas.

Business BID could have as a guiding philosophy the support of Commercial
Improvement new and preservation of existing local businesses, along
District (“BID”) with provision of funding programs, advisory services,
and political advocacy.
Affordable Provides public subsidy of commercial rents for qualified Commercial
Commercial tenants in new construction. In Portland, OR, the City’s
Tenanting Affordable Commercial Tenanting Program addresses the
displacement of small businesses from Portland’s urban
neighborhoods. The program provides incentives to
property owners in exchange for below-market rents for
commercial tenants. Tenants must satisfy certain
conditions including revenue thresholds, cultural
contributions to the neighborhood.
Small Developer Small loans ($20,000-$50,000) coupled with technical Commercial
Technical Assistance assistance to help local land owners and entrepreneurs
build new development or renovate existing structures.
Program features low-barrier underwriting, and very low
or no interest.
Storefront Grants (typically <$50,000) for small-scale revitalization Commercial
Improvement projects such as rehabilitation of street-facing building
Program facades including storefronts, cornices, gutters and
downspouts, signs and graphics, exterior lighting,
canopies and awnings, painting and masonry cleaning,
and limited security and accessibility improvements.
Small Business Develop a business association focused on small or Commercial
Alliance home- based businesses. Ensure this group is narrowly
focused on issues impacting the neighborhood. Should be
facilitated by City staff who can also provide technical
assistance.

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Local Vendor Resources to support home-based and other businesses Commercial
Collective without brick-and-mortar space. In Vancouver, BC, the
vendor's collective offers vending opportunities to low-
income artists, craftspeople, and entrepreneurs with
experience in the informal economy. Resources could
include booths and/or table space, publicity and event
organization, dedicated space for vending activities.

Source: (City of Spokane, 2025)

3.5.4 Significant Unavoidable Adverse Impacts
Over time, additional growth and development will occur through redevelopment as well as on vacant
land. The alternatives vary based on the types and geographic pattern of existing housing and
businesses that may be demolished and replaced by new growth. While this can contribute to the risk
of physical displacement, the benefits in terms of reduced economic displacement pressure and
increased production of affordable units offered by the action alternatives would address affordability
in the marketplace, and the City’s new policies and codes would address anti-displacement measures.
Therefore, no significant unavoidable adverse impacts to population, employment, or housing are
expected under any alternative.

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3.6 Relationship to Plans, Policies, and Regulations
The City of Spokane’s last periodic update of the Comprehensive Plan was approved in 2017, with
amendments last approved in 2023. This Comprehensive Plan Update is the next major periodic
review to evaluate the Comprehensive Plan for consistency with the latest provisions of the State of
Washington Growth Management Act (GMA), Countywide Planning Policies (CPPs), regional plans, and
the community’s vision. This section reviews adopted state, regional, and city plans and policies that
guide growth in Spokane and evaluates the proposed alternatives for consistency. An impact is
identified if the proposal would result in an inconsistency with adopted plans and policies. Mitigation
measures to address identified adverse impacts and a summary of any significant unavoidable
adverse impacts follow the description of existing conditions (affected environment) and impacts
analysis.

Thresholds of significance utilized in this impact analysis include:
 Conflicts with the Washington State Growth Management Act or Spokane County Countywide
Planning Policies.
 Inconsistency with adopted state, regional, county, or local plans and policies.

Per WAC 365-196-210, consistency means: no feature of a plan or regulation is incompatible with any
other feature of a plan or regulation. Consistency is indicative of a capacity for orderly integration or
operation with other elements in a system.

3.6.1 Affected Environment
The current policy and regulatory framework regulating land use in Spokane flows from the GMA,
Spokane County CPPs, the City’s current Comprehensive Plan, as well as implementation actions
including development standards in the Spokane Municipal Code (SMC) and the Shoreline Master
Program (SMP), which is not due for an update until 2030. Several other regulatory measures affect
land use including regional strategic reports, localized subareas, overlay districts, adopted
neighborhood plans, and design guidelines.

State and Regional Framework

Growth Management Act
Comprehensive Plans and development regulations within the City of Spokane must be consistent
with the provisions of the Growth Management Act (GMA). Adopted in 1990, the GMA addresses
concerns about the impacts of uncoordinated growth on Washington communities and the
environment, and it provides a framework for land use planning and development regulations in the
state. The GMA directs coordinated regional and countywide planning, which then informs the locally
adopted comprehensive plans and development regulations of individual cities and counties. Key
provisions of the GMA include:

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 Planning Goals
 Land Designations
 Buildable Lands Program
 Countywide Planning Policies (CPPs)
 Local Comprehensive Planning
The GMA is primarily codified under Chapter 36.70A RCW. The Washington State Department of
Commerce (Commerce) has published a series of amendments to the GMA from 1995 through 2025.
In 2021, GMA goals and element requirements regarding housing were amended to require
jurisdictions to plan for and accommodate housing that is affordable to all economic segments of the
population and to identify and address racially disparate impacts in the housing element. (See Section
3.5 Population, Employment, and Housing).
The GMA includes 15 planning goals, in no particular order, to help guide the development and
adoption of local comprehensive plans and development regulations. GMA Goal 15 references goals
and policies of the Shoreline Management Act. These goals direct most population and employment
growth to be focused in urban areas to avoid sprawl, provide efficient and effective services and
infrastructure within adopted levels of service, and protect environmentally critical areas. See Exhibit
3.6-1.

Exhibit 3.6-1 GMA Goals

GMA Goal Text

(1) Urban Growth Encourage development in urban areas where adequate public facilities and
services exist or can be provided in an efficient manner.

(2) Reduce Sprawl Reduce the inappropriate conversion of undeveloped land into sprawling, low
density development.

(3) Transportation Encourage efficient multimodal transportation systems that will reduce
greenhouse gas emissions and per capita vehicle miles traveled and are based
on regional priorities and coordinated with county and city comprehensive
plans.

(4) Housing Plan for and accommodate housing affordable to all economic segments of the
population of this state, promote a variety of residential densities and housing
types, and encourage preservation of existing housing stock.

(5) Economic Encourage economic development throughout the state that is consistent with
Development adopted comprehensive plans, promote economic opportunity for all citizens
of this state, especially for unemployed and for disadvantaged persons,
promote the retention and expansion of existing businesses and recruitment of
new businesses, recognize regional differences impacting economic
development opportunities, and encourage growth in areas experiencing

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GMA Goal Text

insufficient economic growth, all within the capacities of the state's natural
resources, public services, and public facilities.

(6) Property Rights Private property shall not be taken for public use without just compensation
having been made. The property rights of landowners shall be protected from
arbitrary and discriminatory actions.

(7) Permits Applications for both state and local government permits should be processed
in a timely and fair manner to ensure predictability.

(8) Natural resource Maintain and enhance natural resource-based industries, including productive
industries timber, agricultural, and fisheries industries. Encourage the conservation of
productive forestlands and productive agricultural lands and discourage
incompatible uses.

(9) Open space and Retain open space and green space, enhance recreational opportunities,
recreation enhance fish and wildlife habitat, increase access to natural resource lands and
water, and develop parks and recreation facilities.

(10) Environment Protect and enhance the environment and enhance the state's high quality of
life, including air and water quality, and the availability of water.

(11) Citizen Encourage the involvement of citizens in the planning process, including the
participation and participation of vulnerable populations and overburdened communities, and
coordination ensure coordination between communities and jurisdictions to reconcile
conflicts.

(12) Public facilities Ensure that those public facilities and services necessary to support
and services development shall be adequate to serve the development at the time the
development is available for occupancy and use without decreasing current
service levels below locally established minimum standards.

(13) Historic Identify and encourage the preservation of lands, sites, and structures that
preservation have historical or archaeological significance.

(14) Climate change Ensure that comprehensive plans, development regulations, and regional
and resiliency policies, plans, and strategies under RCW 36.70A.210 and chapter 47.80 RCW
adapt to and mitigate the effects of a changing climate; support reductions in
greenhouse gas emissions and per capita vehicle miles traveled; prepare for
climate impact scenarios; foster resiliency to climate impacts and natural
hazards; protect and enhance environmental, economic, and human health
and safety; and advance environmental justice.

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GMA Goal Text

(15) Shorelines For shorelines of the state, the goals and policies of the shoreline management
act as set forth in RCW 90.58.020 shall be considered an element of the
county's or city's comprehensive plan.

Sources: RCW 36.70A.020 and RCW 36.70A.480(1), 2023.

Jurisdictions planning under the GMA are required to balance these goals in the development and
adoption of their comprehensive plans and development regulations. Counties and cities in most parts
of the state—including the City of Spokane—must prepare comprehensive plans that include
objectives, principles, standards, and a future land use map. Required elements of the comprehensive
plan include land use, housing, capital facilities plan, utilities, rural (for counties), transportation,
economic development, parks and recreation, and climate change and resiliency. Local governments
may include other elements if they wish. Development regulations, such as zoning, must be consistent
with the local government’s Comprehensive Plan. Counties and cities must be up to date with the
requirements of the GMA, including the Periodic Update requirements, to be eligible for grants and
loans from certain state infrastructure programs.

Countywide Planning Policies
The GMA requires counties and cities to collaboratively develop countywide planning policies (CPPs) to
set the general framework for coordinated land use and population planning between a county and its
cities to ensure comprehensive plans are consistent with each other (RCW36.70A.210). The role of the
CPPs is to coordinate comprehensive plans of jurisdictions in the same county regarding regional
issues and issues affecting common borders (RCW 36.70A.100).

The Spokane County CPPs were adopted December 22, 1994, and were last amended December 13,
2022. The CPPs aim to promote resident participation, neighborhood character, aquifer protection,
environmental justice, environmental sustainability, urban growth areas, economic vitality, the
Fairchild Air Force Base, and the Spokane International Airport.

Key topics covered by the CPPs include joint planning in the urban growth areas (UGAs) and the
promotion of contiguous and orderly development and provision of urban services; retention of open
space and development of parks and recreation; coordinated and efficient multimodal transportation
systems based on regional priorities and corridors that can provide high-capacity transportation; the
siting of capital facilities with active resident involvement; economic growth that protects Fairchild Air
Force Base as a key economic resource; recognizes the environment as a regional economic asset;
establishes regional planning relationships with adjacent counties and the State of Idaho; and
enhancement of downtowns and commercial and industrial opportunities in cities.

The CPPs also aim to support affordable housing through the analysis of existing and projected
housing needs, identification of sufficient land for housing, and adequate provisions of this need for all
economic segments of the community, encouraging the development of diverse housing stock

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accessible to a range of household type and promoting accessibility. It also promotes coordination of
housing, transportation, and economic strategies. As part of the Periodic Update, Spokane County has
updated its CPPs to better support affordable housing by meeting state requirements under HB 1110
and HB 1220. The amendments expand Policy Topic 7 to guide housing allocations, promote diverse
housing for all household types, address racial disparities and displacement, preserve existing
affordable housing, and coordinate housing with transportation and economic strategies. The update
also adds a new policy topic on climate change and resiliency.

Housing targets were set considering GMA requirements and through a consultation process between
Spokane County and each city. Through that process, the City of Spokane should plan for 22,359
dwelling units between 2020 and 2046. The City must also plan for housing targets by income band.
See Exhibit 3.6-2. Section 3.5 Population, Employment, and Housing provides a discussion of
affordable housing and the remaining need for 2023-2046.

Exhibit 3.6-2. Net New Housing Units and Emergency Housing Need, 2020-2046

Emergency
Total 0-30% AMI Housing
Housing 30-50% 50-80% 80-100% 100-120% >120%
Need Non -PSH PSH AMI AMI AMI AMI AMI (Beds)
22,359 6,452 1,851 4,413 2,631 1,418 1,170 4,424 983

Notes: AMI = Area Median Income; PSH = Permanent Supportive Housing;
This is based on the Department of Commerce Housing Allocation Planning tool.
Source: City of Spokane, 2024.

Spokane Regional Transportation Council
The Spokane Regional Transportation Council (SRTC) develops policies and coordinates decisions
about regional transportation over the next 20 years through its Metropolitan Transportation Plan
(MTP) (Spokane Regional Transportation Council, 2025). Updated every four to five years, the MTP
includes coordination with other local and regional planning efforts and includes: significant project,
plans, and programs; key transportation challenges; future opportunities; regional growth projections;
and strategies to meet future needs. SRTC is currently updating its long-range transportation plan,
Horizon 2050. Horizon 2045 is the region’s current long-range plan, adopted by the SRTC Board of
Directors on December 9, 2021. It serves as both the regional transportation plan (RTP) and MTP for
Spokane County. The SRTC has a role to certify transportation elements of comprehensive plans.

Horizon 2045 (Spokane Regional Transportation Council, 2021) is a plan for an integrated, accessible,
and multimodal transportation system through 2045. It establishes guiding principles and policies to
achieve the regional vision and align with statewide transportation goals. Its regional vision focuses on
economic vitality, cooperation and leadership, stewardship, system operations, maintenance,
preservation, safety and security, and quality of life. See Exhibit 3.6-3.

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Exhibit 3.6-3. SRTC Horizon 2045 Topic Area Principles

Topic Area Guiding Principles

(1) Economic Vitality Promote economic vitality and prioritize transportation
3 Policies investment.
(2) Cooperation and Leadership Provide a regional forum for transportation planning and
5 Policies funding.
(3) Stewardship Protect the environment and minimize impacts from
5 Policies transportation.
(4) System Operations, Maintenance, Maximize the operations and physical condition of the
and Preservation transportation network.
2 Policies
(5) Safety and Security Maximize operations and physical condition of the
4 Policies transportation network.
(6) Quality of Life Improve choice and mobility.
5 Policies

Source: SRTC Horizon 2045.

Horizon 2045 estimates future conditions based on employment, housing, and employment density
travel forecasting models. For the City of Spokane, Horizon 2045 anticipates concentrated growth and
density through 2045, supporting density and development through the City’s Centers and Corridors
strategy. Housing density is anticipated in the Central Core of Spokane, specifically Downtown
Spokane and West Central Neighborhood; in Northeast Spokane specifically along the Division
Corridor and the neighborhoods of Shiloh Hills and Hillyard; and in South Spokane, specifically the
Lincoln Heights neighborhood. Horizon 2045 anticipates employment growth in relation to activity
centers in the Central Core of Spokane, along the Division Corridor, in Northeast Spokane near the
Hillyard neighborhood, in West Plains, and in South Spokane near the Southgate and Lincoln Heights
neighborhoods. Other areas include Northwest Spokane, specifically the Audubon/Downriver
neighborhood.

Horizon 2045 anticipates growth outside of the City of Spokane throughout the region, particularly in
the cities of Spokane Valley, Liberty Lake, and Airway Heights. The City of Spokane provides water
service to parts of Airway Heights and Spokane Valley. Additional studies and plans conducted by SRTC
include the Regional Safety Action Plan and DivisionConnects. These plans identify strategies for
increasing the safety of multi-modal travel by changing street cross-sections to manage speeds and
accommodate multiple travel options through infrastructure investments.

THRIVE Spokane – Comprehensive Economic Development Strategy
The Greater Spokane Inc. “THRIVE Spokane” is the region’s five-year comprehensive economic
development strategy (CEDS) developed in accordance with the US Economic Development

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Administrations CEDS requirements. While it is not a regulatory requirement, it is a strategic
framework that aligns economic development efforts, guides public and private investment, workforce
development, and infrastructure priorities throughout the Greater Spokane region. It represents
countywide economic development in collaboration with jurisdictions, community partners, education
institutions, downtown associations, chambers, transportation councils, and community members.
Alignment can support the Spokane region in pursuing federal and state funding. Updated in 2022,
THRIVE Spokane and its action plan include the four following goals:
 Goal 1: Recovery and Resiliency – Target efforts that prepare the region to avoid, withstand, and
recover from economic shocks and natural disasters.
 Strategies and actions include investments to reduce employment barriers (e.g., efficient
routes to connect workers to employment centers and development of a diverse set of
attainable housing options), and investment in the development of downtowns and
commercial centers, including pursual of redevelopment for mixed-income, mixed-use
developments.
 Goal 2: Competitiveness – Position the Greater Spokane region as a strong competitor to attract
talent, capital, and resources for strategic economic development.
 Strategies and actions include equitable real estate development; investment in mixed-use
projects; the expansion and preservation of a full range of housing options that target new
housing developments in areas that connect low-income workers with growth employment
centers; and exploration of zoning policy changes to reduce barriers to housing development,
 Goal 3: Equitable Growth – Seek to understand, address, and dismantle outcome disparity
through intentional initiatives that include all Spokane residents in the benefits of economic
growth and prosperity.
 Strategies and actions include sustainable funding for coalitions accountable to the
communities they serve, resources to build capacity and support BIPOC business owners,
equitable economic and workforce development, reduction in barriers to public-private
development projects and real estate development by community-based entities, recruitment
and funding of housing industry innovators, and plan for the protection and incremental
expansion of transportation-oriented business districts by increasing allowable housing and
commercial districts.
 Goal 4: Connectivity – Promote the interconnectedness of Greater Spokane and drive cross—
sector partnerships to align efforts that advance economic opportunity for all.
 Strategies and actions focus on prioritized infrastructure investments, including prioritizing
transit-oriented development, investment in public space activation, proactive engagement
with community-based organizations, and investment prioritization in multimodal and
intermodal transportation to maximize connectivity.

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Local Framework

Spokane’s Existing Comprehensive Plan
The City of Spokane’s existing Comprehensive Plan, Shaping Spokane, is a 20-year vision and roadmap
for Spokane’s future (City of Spokane, 2023). The plan guides City decisions on where to build new jobs
and housing, how to improve the transportation system, and where to make capital investments, such
as utilities, sidewalks, schools, and parks. Shaping Spokane is the framework for the City’s broad
decisions on how to grow while recognizing and improving existing city neighborhoods.

The Comprehensive Plan was first adopted in 2001 consistent with the GMA. It was developed through
Spokane Horizons, a community member participation process that involved all segments of the
population to help shape the city’s future. Since then, the City incorporated minor revisions and
updates to the Comprehensive Plan on an annual basis, with significant periodic review updates
completed in 2006 and 2017. The current plan was last amended in 2023. This Comprehensive Plan
Update is the next significant periodic review.

The Shaping Spokane Comprehensive Plan Update consists of 14 elements – all of which will be
reviewed and updated as part of the proposal:

1. Introduction

2. Implementation

3. Land Use Element

4. Transportation Element

5. Capital Facilities and Utilities Element

6. Housing Element

7. Economic Development Element

8. Urban Design and Historic Preservation Element

9. Natural Environment Element

10. Social Health Element

11. Neighborhoods Element

12. Parks and Recreation Element

13. Local Governance and Citizenship Element

14. Shorelines Element

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The vision of the City of Spokane’s Comprehensive Plan is:
“Spokane will be a city of people living and working together where diverse interests, including
neighborhoods, business, education, and government, build upon the community’s past
accomplishments and heritage to ensure an exceptional sense of community, a healthy
environment, and a high quality of life.”

The appendices include a summary of the GMA and CPPs, the full text of the CPPs as of 2011, the
Horizons Process and the Ahwahnee Principle, the Capital Facilities Plan Technical Appendix, the
Transportation Technical Appendix, Population Projections, Neighborhood Profiles, a Work Plan
Matrix, Neighborhood Planning Resolutions, and Public Outreach conducted for the current
Comprehensive Plan.

Land Use Element

The Land Use Element includes goals and policies that guide the physical form and activities allowed in
the city, with policies under each goal that provide direction on implementation of these goals. See
Exhibit 3.6-4.

Exhibit 3.6-4. City of Spokane Comprehensive Plan - Land Use Element Goals

Goal Text

LU 1 Citywide Land Use: Offer a harmonious blend of opportunities for living, working,
recreation, education, shopping, and cultural activities by protecting natural amenities,
providing coordinated, efficient, and cost effective public facilities and utility services,
carefully managing both residential and non-residential development and design, and
proactively reinforcing downtown Spokane’s role as a vibrant urban center.
LU 2 Public Realm Enhancement: Encourage the enhancement of the public realm.
LU 3 Efficient Land Use: Promote the efficient use of land by the use of incentives, density,
and mixed-use development in proximity to retail businesses, public services, places
of work, and transportation systems.
LU 4 Transportation: Promote a network of safe and cost effective transportation
alternatives, including transit, carpooling, bicycling, pedestrian-oriented environments,
and more efficient use of the automobile, to recognize the relationship between land
use and transportation.
LU 5 Development Character: Promote development in a manner that is attractive,
complementary, and compatible with other land uses.
LU 6 Adequate Public Lands and Facilities: Ensure the provision and distribution of
adequate, public lands and facilities throughout the city.
LU 7 Implementation: Ensure that the goals and policies of the Comprehensive Plan are
implemented.

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Goal Text

LU 8 Urban Growth Area: Maintain an Urban Growth Area that includes areas and
densities sufficient to accommodate the city’s allocated population, housing and
employment growth for the succeeding twenty-year period, including the
accommodation of the medical, governmental, educational, institutional, commercial,
and industrial facilities related to such growth, but that does not exceed the area
necessary to accommodate such growth.
LU 9 Annexation: Support annexations that enhance effective and efficient government.
LU 10 Joint Planning: Support joint growth management planning and annexation requests
which best meet the Comprehensive Plan’s development goals and policies.

The Land Use Element also includes a Future Land Use Map with several designations.
 Neighborhood Center
 District Center
 Employment Center
 Corridor
 Regional Center (Downtown)
 Center & Corridor Core
 Center & Corridor Transition
 Heavy Industrial
 Light Industrial
 General Commercial
 Neighborhood Retail
 Neighborhood Mini-Center
 Office
 Institutional
 Residential 15+
 Residential 15-30
 Residential 10-20
 Residential 4-10
 Agriculture
 Conservation Open Space
 Potential Open Space
 Open Space
 Mining

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Centers and Corridors Growth Strategy

The City of Spokane adopted a planning strategy to focus growth toward centers and corridors (City of
Spokane, 2025). Adopted in 2001 following a public outreach process called Spokane Horizons,
associated land use policies implemented in December 2005 helped define key characteristics of these
centers and corridors. These locations are characterized by the ability to accommodate new housing
within a short walking or rolling distance of shopping, services, public transit, and other amenities. The
planning strategy identified twenty-three centers and corridors throughout Spokane, ranging from
neighborhood centers such as Garland Avenue and Perry Street to shopping destinations such as
Shadle Park and Lincoln Heights. Associated policies and regulations aimed to support these
locations and foster further investment in a mix of shopping, retail, services, and housing.

Center and corridor land use policies promote the efficient use of land by promoting density and
mixed-use development in proximity to retail businesses, public services, places of work, and
transportation systems. It is a strategy that directs growth to areas where adequate services and
facilities are available. There are five different Center designations throughout the city (City of
Spokane, 2023):
 Neighborhood Centers: Neighborhood Centers have a greater intensity of development than the
surrounding residential areas. Businesses primarily cater to neighborhood residents in the form of
convenience and service businesses. Density of housing supports frequent transit and
neighborhood businesses. Buildings orient to the street to allow for a more inviting pedestrian
environment, and the layout of buildings should promote active modes of transportation.
 District Centers: District Centers resemble Neighborhood Centers but allow for a greater intensity
of all uses. District Centers serve a large portion of the surrounding neighborhoods and include
gathering spaces, civic centers, large retail, and housing areas as part of a major activity hub.
Buildings orient to the street and pedestrian access is vital to the surrounding residential areas.
District Centers have frequent transit service, walkways, and bicycle paths
 Employment Centers: Employment Centers allow similar intensities of all use types as
Neighborhood and District Centers, but include a strong, non-service oriented, employment
component.
 Corridors: Corridors, the connection between Centers and the Downtown, allow higher intensities
of all use types. They resemble District and Neighborhood Centers, but with a greater focus on
improving the street network to allow people to move from one Center to the next via multiple
modes of transportation.
 Regional Centers: Downtown Spokane is the only Regional Center and is the hub for shopping,
dining, arts and culture, entertainment, and academics across the region.

Relevant Land Use Policies
 LU 3.2 Centers and Corridors - Designate Centers and Corridors (neighborhood scale, community
or district scale, and regional scale) on the Land Use Plan Map that encourage a mix of uses and
activities around which growth is focused.

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 LU 3.3 Designating Centers and Corridors – Designate new Centers and Corridors in appropriate
locations on the Land Use Plan Map through a City-approved planning process.
 LU 3.4 Planning for Centers and Corridors - Conduct a City-approved subarea planning process to
determine the location, size, mix of land uses, and underlying zoning within designated Centers
and Corridors. Prohibit any change to land use or zoning within suggested Centers or Corridors
until a sub area planning process is completed.
 LU 3.5 Mix of Uses in Centers - Achieve a proportion of uses in Centers that will stimulate
pedestrian activity and create mutually reinforcing land uses.
 LU 3.6 Compact Residential Patterns - Allow more compact and affordable housing in all
neighborhoods, in accordance with design guidelines.

In 2024, the City completed a study (Makers et al., 2024) to evaluate updates or changes to this growth
strategy. While still designating centers and corridors in the land use map, the study recommends
evolving the existing Center and Corridor zones into an updated family of mixed-use zones.

The study identified four key recommendations, including:
 Recommendation 1 – Establish a new set of mixed-use zones
 Recommendation 2 – Address allowed building height
 Recommendation 3 – Update block frontage standards
 Recommendation 4 – Increase connectivity
The recommended revisions to the zones seek to better align with current development practices and
building styles, while maintaining support for the development of walkable street frontages and
accessibility.

Capital Facilities Element and Capital Improvement Program

The Capital Facilities Element contains goals and policies that are carried forward with specific projects
and matching revenues in a Capital Improvement Program.
 CFU 1 Adequate Public Facilities and Services - Provide and maintain adequate public facilities and
utility services and reliable funding in order to protect investment in existing facilities and ensure
appropriate levels of service.
 CFU 2 Concurrency - Ensure that those public facilities and services necessary to support
development are adequate to serve the development and available when the service demands of
development occur without decreasing current service levels below locally established minimum
standards.
 CFU 3 Coordination - Promote contiguous, orderly development and provision of urban services
through the regional coordination of land use and public services related to capital facilities and
utilities.
 CFU 4 Service Provision - Provide public services in a manner that facilitates efficient and effective
delivery of services and meets current and future demand.

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 CFU 5 Environmental Concerns - Minimize impacts to the environment, public health, and safety
through the timely and careful siting and use of capital facilities and utilities.
 CFU 6 Multiple Objectives - Use capital facilities and utilities to support multiple interests and
purposes.
Annually, the City adopts a capital improvement program addressing a six-year period that includes
major projects that work to address repair, replacement, and capacity related to growth. The current
program is 2025-2030, and the City is currently processing the 2026-2031 update. The program
addresses improvements towards the Spokane Police Department; the Spokane Fire Department;
Spokane Parks & Recreation, including trail connections; transportation; water; wastewater; solid
waste; information technology; the city-owned fleet services; and facilities management.

Other Elements

Other relevant elements to highlight in the existing Comprehensive Plan include Transportation,
Housing, Economic Development, and Neighborhoods.

Transportation

The Transportation Element focuses goals and policies on promoting transportation choices and
accessibility for all users, aligning transportation projects with economic vitality and land use
objectives, prioritizing active transportation network projects and connectivity access in
neighborhoods, improving multimodal transportation options particularly in Centers (e.g., District
Centers, Neighborhood Centers, Employment Centers, Corridors, Downtown, and Regional Centers),
and promoting safety and demand management to ensure efficient network capacity.

Housing Element

The Housing Element focuses goals and policies on promoting housing choice and diversity of housing
types that are safe and affordable for all income levels; improving housing quality and encouraging
home preservation and rehabilitation of older neighborhoods; encouraging home ownership; and
encouraging housing for lower-income community members throughout the city.

Economic Development Element

Relevant goals and policies in the Economic Development Element focus on ensuring adequate supply
of useable industrial and commercial property is available, including the support of mixed-use
development to stimulate economic activity and vitality, promoting a range of employment and
businesses.

Neighborhoods Element

The Neighborhood Element focuses on recognizing downtown Spokane as the primary regional
economic and cultural center and as mixed-use neighborhood with a diversity of housing; developing
neighborhoods that feel like small towns and provide a variety of compatible services; promoting

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alternative modes of transportation and circulation in neighborhoods, including multimodal
transportation; increasing open space, trails, and pedestrian connections within and between
neighborhoods; protecting and enhancing the natural environment; and promoting social amenities
and a sense of community.

Neighborhood and Subarea Plans
The 2001 Comprehensive Plan Update included policies that called for neighborhood planning (City of
Spokane, 2025). In 2007, the City set aside $550,000 to be used for neighborhood planning, distributed
funds, and created the Community Assembly to guide neighborhoods through the neighborhood
planning process that identifies issues, solutions, and results tracking. The neighborhood plans can
then be used to develop a project plan for a specific project (Track 1), develop a visioning plan that
may include specific requests for future land use revisions or amendments to the Comprehensive Plan
(Track 2), or can be adopted by ordinance and incorporated into the Comprehensive Plan (Track 3)
(City of Spokane, 2021). Of the neighborhood-focused planning efforts, the following have been
adopted by ordinance and incorporated into the Comprehensive Plan:
 Spokane Downtown Plan, adopted in 2021.
 South University District Subarea Plan, adopted in 2020.
The neighborhood plans, with the exception of the above Downtown Plan, have not been adopted by
ordinance.10

Northwest Spokane

Neighborhood Planning Efforts

These plans are the result of neighborhood planning efforts and, though not formally adopted into the
Comprehensive Plan, are acknowledged by the City and play a role in guiding development and
informing policy.

Emerson Garfield

Emerson-Garfield is a centrally located Spokane neighborhood just north of downtown, bounded
roughly by Division Street on the east, Cora Avenue to the north, and portions of Indiana Avenue and
Monroe Street to the south and west. The neighborhood action plan envisions Emerson-Garfield as “a
diverse and vibrant neighborhood actively supporting a thriving business district, strong residential
areas, beautiful parks, walkable amenities, and a unique historic character.” (Emerson-Garfield
Neighborhood Council, 2014). Key priorities identified through a collaborative planning process
include pedestrian safety (addressing dangerous crossings, lack of sidewalks, and high-traffic arterials

10
The City adopted the South Logan TOD Plan by resolution in 2024. It then implemented the TOD Plan’s
proposed land use and zoning through a comprehensive plan amendment.

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like Monroe, Indiana, and Northwest Boulevard); neighborhood beautification; business diversity and
occupancy; community resources; alternative and public transportation; and neighborhood
connectivity and events.

The plan places particular emphasis on improving land use along the Monroe Street corridor and
enhancing the pedestrian environment with complete streets strategies—such as crosswalks, ADA
ramps, lighting, and traffic-calming measures. This top priority supported the development of the
North Monroe Corridor Project 2018 (City of Spokane, 2016), a project to improve the Monroe Street
Corridor by improving safety, enhancing the streetscape, and reconfiguring traffic on North Monroe
Street. Construction began in 2018 (City of Spokane, 2018).

City Council recognized it by resolution in July 2014 (City of Spokane, 2014).

Five Mile Prairie

The Five Mile Prairie Neighborhood, located in the northwest corner of Spokane and bordered on
three sides by unincorporated Spokane County, is primarily residential with two major parks, Sky
Prairie Park and Austin Ravine Conservation Area. Its neighborhood plan focuses exclusively on
improving pedestrian and bicycle safety and connectivity (Five Mile Prairie Neighborhood, 2012),
outlining 21 capital improvement projects aimed at enhancing walking and biking facilities. Key
priorities include creating safer routes for pedestrians and cyclists; improving connections between
homes, schools, parks, and neighboring areas; and integrating local improvements with broader city
policies and capital plans. The plan emphasizes linking residential areas with community destinations
to encourage active transportation and reduce reliance on cars. It also identifies a potential future
study area for additional planning and infrastructure needs. By targeting strategic connections and
safety upgrades, the plan seeks to create a more accessible and connected neighborhood for all
residents. City Council passed a resolution in 2012 to recognize the plan as a priority planning
document for the neighborhood; the recommendations have not yet been incorporated in the
Comprehensive Plan (City of Spokane, 2012).

North Hill

The 2015 North Hill Neighborhood Action Plan emphasizes connectivity, safety, livability, and a vibrant
community (North Hill Neighborhood Council, 2015). Priorities include boosting commercial vitality in
the Garland District; increasing safety; enhancing public spaces; implementing pedestrian connectivity
and traffic calming measures; and preserving the South Bluffs as open space. The plan supports local
businesses, mixed-use development along Division Street and the Garland District, and improved
pedestrian and bike connections—especially between residential areas and the Garland District—
within broader city transportation plans. Predominantly low intensity residential, North Hill also
includes commercial and higher intensity areas along its eastern edge and in the Garland
Neighborhood Center. Bounded by Francis Avenue, Division Street, Courtland and Cora Avenues, and
Ash Street, it serves as a transition between downtown and northern residential neighborhoods. The
City Council adopted the neighborhood plan by resolution in July 2015 (City of Spokane, 2015).

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Shadle District (Northwest & Audubon / Downriver neighborhoods)

The Shadle Area Neighborhood Plan, adopted by resolution by City Council in 2019 (City of Spokane,
2019), provides a long-range vision to guide development in this designated District Center (SCJ
Alliance, 2019). The plan emphasizes pedestrian-oriented, mixed-use growth supported by CC1 and
CC2 zoning, encouraging diverse housing options such as townhomes, multi-units, and senior housing.
It prioritizes public realm improvements—particularly along Wellesley, Belt, Alberta, and Ash—to slow
traffic, improve walkability, and support mixed-use intensification. Key focus areas include enhancing
transportation connectivity with safer crossings, bike access, and transit improvements; creating more
housing diversity to support affordability and aging in place; and improving public spaces like Shadle
Center and Shadle Park to foster community identity and accessibility. Investments aim to create
strong pedestrian and bicycle links to surrounding neighborhoods, reduce surface parking, and
encourage storefront-oriented development. The plan anticipates gradual transformation, with
incremental public and private investment shaping the district’s evolution into a vibrant center
connected to other parts of Spokane through frequent and accessible transit.

West Central

Completed in May 2012, the West Central Neighborhood Action Plan outlines priorities across land
use, transportation, community facilities, housing, design and historic preservation, parks and open
space, social needs, and economic development (West Central Neighborhood, 2012). Key land use
goals include attracting commercial and light industrial investment while protecting single unit
residential areas through land use regulation enforcement. Transportation priorities focus on adding
bike lanes and multimodal options to connect the neighborhood to downtown and expand options for
low-income households. The plan calls for maintaining and improving community centers;
encouraging homeownership and infill housing development; investing in historic streets and housing
stock; protecting and enhancing open space; fostering a safe and inclusive community with
opportunities for all ages; and supporting local businesses while attracting new economic investment.
Located north and west of the Spokane River, the neighborhood is bounded to the south by West
Indiana Avenue and to the east by North Monroe Street. Through these strategies, the plan seeks to
preserve West Central’s historic character while promoting growth, connectivity, and community well-
being. The City Council passed a resolution in February 2013 to recognize the planning efforts of the
West Central Stakeholder Group and the West Central Neighborhood Action Plan (City of Spokane,
2013).

Related planning in West Central includes programming of traffic calming and transportation
improvements through the West Central Infrastructure Project. This neighborhood-led study,
completed in 2024, reassessed and prioritized projects originally listed in founding legislation for the
West Quadrant Tax Increment Finance District.

West Hills

West Hills Neighborhood developed the Fort George Wright Drive Station and Corridor Plan, with
planning efforts focused on the Fort George Write Boulevard (now Whistalks Way) and Spokane Falls
Community College area (City of Spokane, 2016). Plan development included collaborative efforts from

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Spokane Falls Community College, Mukogawa Institute, Spokane Transit Authority, the West Hills
Neighborhood Council, River Run PUD, and other entities. The plan focused on addressing immediate
public safety needs, improving provision of transit, encouraging new land uses, boosting bike and
pedestrian connectivity, and identifying supporting actions to develop a cohesive neighborhood
center. The City Council recognized the Fort George Wright Drive Station and Corridor Plan by
resolution in late 2016 (City of Spokane, 2016).

Future neighborhood planning projects

Future neighborhood planning projects in Northwest Spokane include Balboa / South Indian Trail.

Northeast Spokane

Hillyard Subarea Plan

The Hillyard Subarea Plan is a combined effort of the City of Spokane and the Northeast Public
Development Authority (NEPDA) to define a vision for the Hillyard neighborhood in the northeast
corner of the city (Northeast PDA, 2025). The City Council formally recognized and adopted the plan by
resolution in November 2025.

Goals, strategies, and actions included in the plan are guided by the following vision to “rediscover
Hillyard’s history, assets, community, and potential through an actionable plan centered on physical
enhancements, supportive infrastructure and land use planning.” It is focused on six key vision themes
that include: create distinctive places; enhance livability; achieve economic vitality; improve services;
and identify implementation strategies.

The subarea plan addresses land use and infrastructure throughout the Hillyard neighborhood. The
plan also identifies catalyst sites to help focus targeted redevelopment efforts, with the underlying
zone driving the resulting development

South Logan TOD Plan

The South Logan Transit-Oriented Development (TOD) Project supports increased connectivity and
livability in the South Logan area, located in the Logan neighborhood of Spokane. (City of Spokane,
2025). Its study area is focused on areas up to a half mile around three City Line bus rapid transit
stations in the South Logan area of the Logan Neighborhood. This area includes the Hamilton Street
Corridor, Gonzaga University, the new UW and Gonzaga health sciences center, Mission Avenue
Historic District, local businesses and organizations, Mission Park, Upriver Park, Centennial Trail, and
the Spokane River. The City Council approved the South Logan TOD Plan by resolution in early 2024,
with land use and zoning changes as well as citywide and area-specific amendments to the Spokane
Municipal Code approved later in 2024.

The South Logan TOD Plan (City of Spokane, 2024) values include enhancing connectivity, accessibility
and mobility; supporting universities and health sciences; supporting job access, diverse industries,
and employment; expanding housing options and affordability for residents of all incomes and ages;

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minimizing residential and local business displacement; and building on the neighborhood’s diverse
urban context and history with integrity.

Plan recommendations include pairing transit infrastructure investments with targeted investments in
public spaces; increasing active transportation connections and improvements; making strategic
updates to zoning, design standards, and regulations to encourage private investment; and drawing in
more businesses and residents to the area while also applying anti-displacement efforts to keep
existing community members and anchors. Its efforts build on the Logan Neighborhood Identity Plan,
adopted by resolution in May 2014, and the Hamilton Street Corridor form-based code, adopted by
ordinance in 2015. Added as a new chapter to the Title17C Land Use Standards of the Spokane
Municipal Code, the Hamilton Street Corridor form-based model code aimed to foster an economically
vibrant, walkable, mixed-use environment along the Hamilton Corridor.

Neighborhood Planning Efforts

These plans are the result of neighborhood planning efforts and, though not formally adopted into the
Comprehensive Plan, are acknowledged by the City and play a role in guiding development and
informing policy.

Bemiss, Hillyard, and Whitman neighborhoods

The Greater Hillyard Northeast Planning Alliance (GHNPA) neighborhood strategic plan covers Bemiss,
Hillyard, and Whitman neighborhoods in northeast Spokane (Greater Hillyard Northeast Planning
Alliance, 2010). It identifies ten strategic areas, including parks and trails; housing and commercial
buildings; public safety; economic development; transportation and infrastructure; and community
organization. Land use priorities focus on maintaining and upgrading housing and enhancing
commercial buildings. Community facility and infrastructure goals include improving parks and trails,
as well as developing East Hillyard’s industrial corridor and a Manufacturing Development Center.
Organizational priorities call for stronger neighborhood-level structures to coordinate efforts and
resources.

The plan’s vision is for a safer, greener, and better-connected East Spokane, where housing and
economic development thrive alongside community pride, civic engagement, and a positive
neighborhood image. It promotes a collaborative approach among residents, nonprofits,
neighborhood councils, businesses, and the City to implement a unified revitalization strategy.
Through sustained partnerships, the three neighborhoods aim to foster economic opportunity,
enhance livability, and strengthen the community’s identity. GHNPA finalized its report and final
proposals in 2010.

Chief Garry Park

The Chief Garry Park neighborhood is in the central section of northeast Spokane. It is predominantly
comprised of single unit residential, with retail at Mission and Napa Street and near Spokane
Community College. Prominent landmarks include Spokane Community College in the center of the
neighborhood, Felts Field to the east, and Spokane River forming the northern border. The vision of its

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neighborhood action plan identifies Chief Garry Park as a “strong residential neighborhood with
thriving businesses, attractive and connected parks, and accessible transit and pedestrian amenities”
(Chief Garry Park Neighborhood Council, 2017). The action plan focuses on pedestrian safety,
beautification, economic development, connectivity, and preserving neighborhood character. Its
priorities include encouraging higher density residential and mixed-use development near transit,
particularly at Mission Avenue and Napa Street and Mission and Greene Street near City Line stations.
Other priorities include placemaking strategies; pedestrian and trail enhancements, specifically toward
the Iron Bridge; and identifying TOD that aligns with the City Line bus rapid transit. In 2017, the City
Council passed a resolution recognizing the neighborhood action plan as a guide for the
neighborhood’s desired direction for local activities and priority projects (City of Spokane, 2017).

East Central

East Central is located in the southern part of Northeast Spokane, just east of Center City. It is between
Division Street and Havana Street, with Interstate-90 running east-west through the neighborhood. It
includes an employment center along Sprague Avenue, a neighborhood center along Perry Street,
various neighborhood retail locations, and Liberty Park. To form the East Central Neighborhood Plan,
the East Central Planning Stakeholder Group built on previous planning efforts in the neighborhood
and prioritized making improvements to the Ben Burr Trailhead to help link the neighborhood more
effectively to the Centennial Trail (East Central Neighborhood Partnership Center, 2006). The plan
reflects a focused, project-based approach that upgrades recreational infrastructure and fosters
connectivity within East Central. It was adopted as a neighborhood planning document by City Council
resolution on March 27, 2006.
 ReFIVE 5th Avenue Community Plan: The City is currently in the planning process for the 5th
Avenue community in the East Central neighborhood (City of Spokane, 2025). Located south of I-90
around the 5th Avenue corridor in the southeast section of the East Central neighborhood, the area
includes the historical Black business district and diverse community organizations.

Nevada Lidgerwood Neighborhood

The Nevada Lidgerwood neighborhood is located in Northeast Spokane, approximately bound by
Division Street to the west, Perry and Crestline Streets to the east, Lincoln Avenue to the north, and
East Euclid Avenue to the south. Key streets include Nevada Street and Addison Street running north-
south. In 2009-2010, neighborhood residents and businesses identified important issues and solutions
to improve the neighborhood (EWU URP Program, 2011) (Eastern Washington University's Planning
Team, 2011), which focused on non-motorized travel safety, traffic patterns, volume, and speed. City
Council recognized the neighborhood’s planning efforts by resolution in January 2012 (City of Spokane,
2012).

Future neighborhood planning projects

Other Future Neighborhood Planning Efforts
 Shiloh Hills – Annexed to the City in the 1960s, Shiloh Hills is a newer neighborhood that split from
the Nevada / Ledgerwood Neighborhood; it is north of East Francis Street and west of North

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Division Street. Recent planning efforts have focused on traffic calming efforts, including street art
and traffic islands (Shiloh Hills Neighborhood Council, 2025).

Division Corridor

DivisionConnects and the Division Street TOD Project

In 2021 and 2022, SRTC and Spokane Transit Authority (STA) led a two-year transportation and land
use study that identified opportunities and challenges on Division Street. The Phase 1 Corridor
Development Plan was adopted by SRTC Board of Directors on June 10, 2021, and the Phase 2 Vision
and Implementation Strategy was adopted by the SRTC Board on September 8, 2022.

Phase 1 evaluated bus rapid transit (BRT) along Division Street and other corridor transportation
elements (SRTC; STA, 2021). Its findings focus on implementation steps that transition the corridor
from local to BRT service, securing funding, finalizing station locations, and development of transit-
supportive strategies including supportive land uses along the corridor and multimodal transportation
modes.

Phase 2 focused on opportunities and challenges on Division Street with the completion of the North
Spokane Corridor, including the evaluation of active transportation capital investments and areas
where land use changes may occur to create TOD (SRTC, 2022). Phase 2 discusses revisiting zoning
policies to achieve a mixed-use Division Street BRT corridor that optimizes TOD opportunities.

In 2024, the City, STA and the County initiated a joint planning effort, currently underway, to develop
the Division Street Transit-Oriented Development Plan using funding from the Federal Transit
Administration’s Pilot Program for Transit Oriented Development. The plan focuses on aligning land
use, zoning, and infrastructure to make the most of upcoming transit investments on the Division
Street corridor. The final plan is anticipated in Winter 2025.

Related Neighborhood Plans

Other adopted subareas and neighborhood plans overlap with the Division Corridor. See the North
Hill neighborhood plan in the Northwest Spokane section, and the South Logan TOD Plan and
Nevada Lidgerwood neighborhood planning efforts in the Northeast Spokane section.

Center City

Spokane Downtown Plan

Approved by City Council and adopted as a subarea plan by ordinance in 2021, the Spokane
Downtown Plan outlines the community’s vision for the Downtown subarea through 2031 (Downtown
Spokane Partnership, 2021). Through a collaborative process between the City and the Downtown
Spokane Partnership, which oversees the Downtown Business Improvement District, the plan
identifies five goals including:

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 A connected and walkable Downtown.
 Thriving arts, culture and historic places.
 A great place to live, work, and play.
 Welcoming and engaging public spaces for all.
 A well-organized Downtown.
To align its goals and vision in the plan, it also identifies 15 priority actions including a focus on
multimodal transportation and walkable pedestrian-focused street design; infill development focused
on small businesses, start-ups, arts, and culture; and integrated parks and public space.

South University District Subarea Plan

The South University District lies south of the main University District campus (east of Downtown
Spokane), south of the BNSF tracks up to I-90, and north of the South Hill medical district. Adopted by
ordinance in 2020, the South University District Subarea Plan reaffirms and adopts the vision, goals,
and policies for the district (City of Spokane, 2020). It outlines the City and East Central Neighborhood
Council’s priorities for new growth and investment, with the vision for it to emerge as a “true gateway.”

Key themes addressed include land use transitions that align with pedestrian activity; transportation
improvements prioritizing walking, biking, and transit; maintaining and adapting existing businesses
and historic character; and fostering design through public realm enhancements and neighborhood
revitalization. The vision places centers on Sprague and Sherman, the heart of a pedestrian-oriented
innovation district. It envisions a lively, mixed-use "urban village" – retail, institutional, residential,
artisan/light-industrial uses, housing diversity, public amenities, and walkable streets tying together
universities, Downtown, and healthcare areas.

Other Plans

North Bank Subarea Plan

The key findings and issues identified in the Draft North Bank Subarea neighborhood plan (City of
Spokane, n.d.) were incorporated into the Downtown Plan Update, adopted by City Council in 2021.

Transit-Oriented Development Framework Study

The Transit Oriented Development (TOD) Framework Study, conducted from 2021 to 2022, built on
previous planning efforts including an economic impact study for the City Line in 2014 and a 2017
strategic overlay study for the City Line. The TOD Framework Study developed recommended updates
to Center and Corridor zones and rezoning selected station areas, supporting future planning
including the completed South Logan TOD Study and the ongoing Division Street TOD Plan. City
Council adopted it by resolution in May 2022.

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South Spokane

Neighborhood Planning Efforts

These plans are the result of neighborhood planning efforts and, though not formally adopted into the
Comprehensive Plan, are acknowledged by the City and play a role in guiding development and
informing policy.

Browne’s Addition

Browne’s Addition is located in South Spokane, north of I-90 and West Sunset Boulevard, east of Latah
Creek, and south of Spokane River and Peaceful Valley Neighborhood. It is one of the city’s earliest
neighborhoods and is designated as a historic district nationally and locally. The Browne’s Addition
Neighborhood Association developed a master park plan for Coeur d’Alene Park, a nearly 10-acre park
in the heart of the neighborhood (Friends of Coeur d'Alene & Browne's Addition Neighborhood
Association, 2015). The Spokane Park Board adopted the master park plan in September 2015 (City of
Spokane Parks and Recreation, 2015).

Grandview / Thorpe

Located in Southwest Spokane west of Highway 195 and south of I-90, Grandview / Thorpe is a low
intensity residential community with strong connections to natural areas and recreational amenities. It
is also the location of a former interurban rail line. Adopted by its neighborhood council in 2015, the
Grandview / Thorpe Neighborhood Action Plan envisions creating a more connected, walkable, and
community-focused Grandview/Thorpe area in Southwest Spokane, blending natural character with
neighborhood identity (Grandview/Thorpe Neighborhood Council, 2015). It prioritizes establishing a
neighborhood activity center or small-scale retail node, improving trail connectivity through
partnerships and easements, and creating gateway features at key intersections like Grandview & 17th
and Thorpe Road. The plan also highlights road improvements to enhance walkability and access
throughout the neighborhood.

Land use priorities include exploring modifications to the comprehensive plan and zoning to enable
neighborhood-serving retail—an option currently not permitted under existing regulations. On the
transportation front, emphasis is placed on improving trail access and walking infrastructure, while
strategically positioned neighborhood gateways serve both functional and identity-strengthening
roles.

The City Council adopted the plan by resolution in November 2015 (City of Spokane, 2015).

Peaceful Valley

The Peaceful Valley Neighborhood is on the south bank of the Spokane River, immediately west of
Downtown Spokane and north of Browne’s Addition neighborhood. Adopted by resolution by the City
Council in 2015 (City of Spokane, 2015), the Peaceful Valley Neighborhood Plan focuses on vibrancy,
walkability, and a connected community (Peaceful Valley Neighborhood Council, 2015). Key priorities
include improve traffic and pedestrian safety along Clarke and Main avenues, improve crime

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awareness, and build trust among neighbors. There are also environmental protections, a desire to
improve access to parks and recreation, and a desire to preserve the housing quality and historic
character of the neighborhood.

South Hill Coalition

Connectivity and Livability Strategic Plan

The South Hill Coalition (SHC), comprising five neighborhoods—Cliff Cannon, Comstock, Lincoln
Heights, Manito/Cannon Hill, and Rockwood—collaborated to develop a unified vision for the South
Hill area. Adopted as a resolution in 2014 by City Council, the 20-year Connectivity and Livability
Strategic Plan is a visionary document to guide improvement in the neighborhood that emphasizes
enhancing connectivity, livability, and neighborhood identity (South Hill Coalition, 2014). The plan
identifies priority projects aimed at improving infrastructure, promoting sustainable development, and
fostering community engagement. These initiatives are designed to create a more cohesive and
vibrant South Hill, aligning with the broader goals of the City of Spokane.

The plan's vision focuses on creating a well-connected, livable, and sustainable community that
respects the unique character of each neighborhood. Key priorities include enhancing transportation
options, improving public spaces, and promoting responsible land use. The plan also emphasizes the
importance of community involvement and collaboration in achieving these goals. By addressing these
priorities, the SHC aims to ensure that South Hill remains a desirable place to live and work for years
to come.

Grand Boulevard Transportation and Land Use Study

To support planning efforts in South Hill, the City conducted the Grand Boulevard Transportation and
Land Use Study (City of Spokane, 2020), adopted by resolution in August 2020 (City of Spokane, 2020).
It studied the Grand Boulevard segment and set a long-range vision and implementation plan for
safety, access, and mobility improvements. Study elements included reviewing traffic patterns and
safety on Grand Boulevard; developing an understanding of bicycle and pedestrian needs; evaluating
concepts of land reduction, bike lanes, wider sidewalks, and green infrastructure; conducting market
analysis for redevelopment potential; studying land use designations and patterns of use; and
collecting multimodal traffic data.

Future Neighborhood Planning Projects
Future neighborhood planning projects include Latah/Hangman Neighborhood Action Plan.

The City is also addressing a Strategy for Growth in Latah Valley and exploring needed local
transportation improvements and other capital facility improvements. Another effort led by SRTC,
together with WSDOT, the City, County, and Spokane Transit Authority, includes the US 195 North/I-90
Transportation Study that produced a study in 2021. The purpose was to develop a long-range
transportation strategy for the Latah Valley, Grandview, and Thorpe areas of Spokane and Spokane
County.

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West Plains

In 2014, the City of Spokane studied subarea planning efforts in the West Plains and issued a Draft
West Plains Transportation Subarea Plan. West Plains also has a WSDOT-led “living study” for the West
Plains subarea. However, these documents have not been formally adopted.

West Plains Draft Transportation Subarea Plan (2014)

In 2014, the City of Spokane coordinated study efforts with partnering jurisdiction and agencies to
study adequate transportation facilities and facilitate anticipated and desired development in the West
Plains area (City of Spokane, 2014). Outcomes and recommendations from the Draft Subarea Plan
include:
 Increase the overall transportation network density in the West Plains.
 Reserve right-of-way for arterials identified in the updated arterial plan.
 Accommodate and balance multiple modes of transportation.
 Design and improve US 2 to be an attractive entry; encourage new development to promote a
distinct character.
 Develop safe and comfortable bike and pedestrian connections between Downtown Spokane and
Fairchild Air Force Base and Downtown Spokane and the Spokane International Airport.
 Coordinate, prioritize, and invest in transportation system improvements.
 Anticipate the eventual extension of rights-of-way into urban reserve areas.

These findings were incorporated into the WSDOT West Plains Subarea Transportation Management
Plan “living study.”

West Plains Transportation Subarea Plan (Ongoing)

Led by WSDOT, the West Plains Subarea Transportation Management Plan is a “living study” that
focuses on land use and multimodal transportation solutions in the West Plains Area of the Spokane
region (WSDOT - Eastern Region Planning, 2022). As a living study, WSDOT is continuing to update the
project webpage (www.connectwestplains.com) with new data as it becomes available. The study area
is in and around the US 2 corridor west of I-90 between the Fairchild Air Force Base entrance at
Mitchell Street to the west to just east of Russell Road, and it encompasses part of the City of Spokane,
as well as the City of Airway Heights and areas of Spokane County, the Fairchild Air Force Base, the
Spokane International Airport, and lands of the Kalispell and Spokane Tribes. With land use
development in the West Plains vicinity outpacing the available multimodal transportation system in
the area, which has been found to be one of the fastest growing areas in Washington State, the study
works to identify potential practice solutions.

Goals, strategies, and early actions in the plan focus on safety, mobility, quality of life, and economic
vitality. Regarding land use, strategies are focused on promoting “a more balanced mix of land uses to
facilitate shorter trips, use of transit and active transportation, and efficient use of the transportation

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system” (WSDOT, 2025). Relevant land use strategies prioritize balancing employment growth with
housing development.

3.6.2 Impacts
This section reviews the proposed alternatives for consistency with the adopted plans and policies
discussed above. Impacts would arise if the alternatives impeded state or regional policies. More
specifically, an impact is identified if the alternatives:
 Conflicts with the Washington State Growth Management Act or Spokane County Countywide
Planning Policies.
 Are inconsistent with adopted state, regional, county, or local plans and policies.

Impacts Common to All Alternatives

Growth Management Act
Spokane adopted its Comprehensive Plan to comply with the GMA in 2001, with periodic amendments
since then. The plan contains the elements required by the GMA, and the City has adopted land use
and environment regulations (Title 23 and Title 25 in the SMC) that implement the plan.

The action alternatives would each adopt a new growth strategy, and each element of the
Comprehensive Plan would be updated. The plan would continue to focus growth in an urban area
with a range of public services and multimodal transportation options, provide for public services like
parks and schools, and protect critical areas and environments consistent with the GMA.

The Draft EIS alternatives each accommodate the 2046 growth targets and examine different ways the
City could distribute its 2046 forecast growth with varying degrees of concentration. Focusing growth
within urban areas in this manner is consistent with GMA policies that seek to prevent sprawl and
preserve rural areas and resource lands. All alternatives have sufficient zoned vacant and
redevelopable land to accommodate the 20-year population, housing, and job allocations. However,
Alternative 1 does not have sufficient land capacity to accommodate housing at all income levels,
particularly 0-80% AMI. See Exhibit 3.6-5.

Exhibit 3.6-5 Growth Management Act Goals - Alternative Evaluations

GMA Goal Discussion

(1) Urban Growth Each studied alternative would serve growth with city or municipal services.

(2) Reduce Sprawl Each studied alternative would focus on redevelopment in an urban
environment.

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GMA Goal Discussion

(3) Transportation Each studied alternative would place most growth in Downtown and along
transit corridors. Alternatives 2 and 3 provide new multimodal level of
service and improve accessibility for multiple modes of travel. Alternative 2
would intensify mixed-uses along transit in Downtown, Division Street, other
frequent transit routes, and along corridors. Alternative 3 identifies key
transportation connections between Center City, West Hills, and the North
Spokane Corridor in the Hillyard area, and it includes the planned growth in
the 5th Avenue Corridor on the southern end of the corridor.

(4) Housing All alternatives accommodate housing growth targets. However, Alternative
1 does not provide sufficient capacity for housing at all income levels,
particularly 0-80% AMI. Alternatives 2 and 3 provide for a greater range of
housing in addition to middle housing. See also Section 3.5 Population,
Employment, and Housing for a discussion of how the alternatives impact
housing and address new GMA housing requirements in HB 1220.

(5) Economic All alternatives accommodate job targets. Alternative 1 focuses job growth in
Development health/services (Downtown) and industrial (along railroads and near the
Spokane International Airport). Alternative 2 supports existing job centers
and establishes a job allocation above the 20-year trend linked to
jobs/housing balance. Alternative 3 establishes the highest jobs allocation
with focused investment in areas with planned transportation investment.

(6) Property Rights All alternatives support a reasonable use of property.

(7) Permits All alternatives would implement City policies that promote fair permitting.

(8) Natural resource There are mining resources in the city in the northeast corner, outside the
industries Shiloh Hills neighborhood. Alternatives 2 and 3 are not anticipated to put
housing in proximity, as much of the housing and job growth is concentrated
in different locations of the city.

(9) Open space and All alternatives create demand for parks and recreation under adopted
recreation levels of service. The updated Comprehensive Plan could include an updated
level of service standard. See Section 3.8 Public Services.

(10) Environment All alternatives focus growth in the urban growth area, with impacts on the
environment mitigated through compliance with federal, state, and local
regulations. Alternatives 2 and 3 include development and implementation
of climate resilience and greenhouse gas reduction goals and policies per HB
1181, as well as a review and update of critical areas regulations based on
best available science.

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GMA Goal Discussion

See Sections 3.1 Earth, Water Quality, and Water Resources, 3.2 Air
Quality and Greenhouse Gas, and Section 3.3 Plants and Animals for
discussion of how the alternatives impact the natural environment.

(11) Citizen Alternative 1 was based on a public engagement process in the last periodic
participation and review update. Relevant to the action alternatives, the public participation
coordination plan outlines how the City intends to engage community members in the
plan update. See the summary Chapter 2 Proposal and Alternatives.

(12) Public facilities All alternatives allow for growth that will increase demand for public
and services services. The City and municipal providers regularly plan for capital facilities
to meet current and projected needs. See Sections 3.8 Public Services and
3.9 Utilities for detailed analysis.

(13) Historic Each alternative could result in redevelopment that has the potential to alter
preservation eligible historic resources or result in ground disturbing activities that could
affect cultural resources. See the evaluation and mitigation measures on
Cultural Resources in Section 3.4 Land Use Patterns and Urban Form.

(14) Climate change The action alternatives add climate planning, which include new climate
and resiliency resilience and greenhouse gas reduction goals and policies per HB 1181.
Alternative 1 continues current natural environment policies and critical
areas regulation, but these were not designed to meet the new HB 1181
requirements in full.

(15) Shorelines The City maintains a shoreline master program under the Shoreline
Management Act. It is updated periodically under a different timeline. The
City must be consistent with the shoreline goals of environmental
conservation, public access, and shoreline-oriented uses. All alternatives
would continue to maintain the shoreline master program.

Multicounty Planning Policies and SRTC Regional Transportation Plan
Regional policies and alternatives’ consistency are evaluated in Exhibit 3.6-6. Highlights are described
below.

Countywide Planning Policies

Each alternative would provide capacity to meet minimum growth targets for housing and jobs. See
Exhibit 3.6-6. The ability to produce housing at affordability levels is described in Section 3.5
Population, Employment, and Housing.

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Exhibit 3.6-6. Countywide Planning Policies, Major Goals - Alternatives Evaluation

Topic Area Relevant Overarching Policy Evaluation

Land Use Policy Topic 1 Urban Growth Areas All alternatives would focus the
Overarching summary: Growth in majority of future growth in Downtown
Spokane County will be encouraged in Spokane and in centers and corridors.
the UGAs, with lands in the UGAs Alternative 1 focuses growth in
developed with urban character and Downtown and in centers and
supported by urban services and corridors. Job growth is focused
facilities. Downtown and in West Plains.
Land outside UGA will remain rural or Alternative 2 focuses growth along
maintain its existing character, with mixed-use TOD development along
jurisdictions working to protect natural frequent transit corridors, with more
resources lands, critical areas, and neighborhood commercial zoning.
open spaces. Alternative 3 focuses growth
Downtown and in Regional Hubs. Job
growth is in Major Hubs, such as City
Center, University District, and West
Plains.
See Section 3.5 Population,
Employment, and Housing for further
analysis on growth distribution in the
city.

Public Services / Policy Topic 3. Provision of Urban All alternatives would allow for growth
Utilities Services that increases demand for public
Overarching summary: Urban services. The City and municipal
development will be distributed to providers regularly plan for capital
promote land efficiency and in facilities to meet current and projected
coordination with public facilities and need. See Section 3.8 Public Services
utilities. and Section 3.9 Utilities.

Public Services Policy Topic 4 Parks and Open Space All alternatives would focus
Overarching summary: Jurisdictions in redevelopment in the UGA and in
Spokane County will identify and concentrated locations, increasing the
protect open space lands, natural opportunity to identify and protect
areas, and environmental corridors; open space and natural lands outside
develop and retain parks and open of these development areas. The City
space; and recognize open space and also regularly plans for parks and
recreation opportunities. recreation to meet current and
projected need. See 3.8 Public
Services.

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Topic Area Relevant Overarching Policy Evaluation

Transportation Policy Topic 5 Transportation Each alternative would place most
Overarching summary: Jurisdictions in growth around transit investments.
Spokane County will coordinate with The action alternatives provide for new
regional transportation planning (SRTC multimodal LOS and improved
and STA) to ensure transportation and accessibility for multiple travel modes.
land use compatibility, including the Alternative 2 intensifies mixed-uses
adoption of LOS standards, the and housing growth along corridors
designation of specific transportation and frequent transit routes. Alternative
corridors to support high-capacity 3 focuses growth in Center City, along
transportation, and coordination and corridors, and with connections to
support of existing or new multimodal regional centers. See Section 3.7
transportation systems. Transportation for a discussion on
how the alternatives relate to
transportation investment.

Housing Policy Topic 7. Affordable Housing All alternatives meet total housing
Overarching summary: Communities in growth targets; however, only
Spokane County will accommodate a Alternative 2 and 3 have sufficient
wide variety of development and capacity to provide housing at all
housing types, with consistency in income levels, particularly 0-80% AMI.
development regulations and See Section 3.5 Population,
standards within UGAs. It includes Employment, and Housing for a
coordination of housing, discussion on how the alternatives
transportation, and economic impact housing.
development strategies to ensure land
and densities for affordable housing
are in locations accessible to
employment centers.

Economy / Policy Topic 8 Economic All alternatives would accommodate
Climate Development greater jobs and would promote
Overarching summary: Regional economic opportunity in the city and
economic development will include region. There are no regionally
cooperation between the private designated jobs targets. Alternative 3
sector and government, the need to has the highest job growth projections
maintain downtowns as retail and and Alternative 2 has the lowest job
cultural hubs, and the need to adopt a growth projections.
regional approach to environmental Alternative 2 supports existing job
issues (water and air quality). centers but supports neighborhood
commercial retail nodes.

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Topic Area Relevant Overarching Policy Evaluation

Alternative 3 focuses jobs in Center
City, University District, and West
Plains.
See Section 3.5 Population,
Employment, and Housing for further
discussion on job growth and analysis.

Regarding climate, Alternatives 2 and 3
include new climate policies focused
on reducing emissions from buildings
and transportation and making the city
more capable of withstanding the
impacts of climate change. These
policies are not included in Alternative
1.

SRTC Metropolitan Transportation Plan

The SRTC Metropolitan Transportation Plan policies and consistency with the alternatives are
evaluated in Exhibit 3.6-7. Highlights are described below.

Exhibit 3.6-7. SRTC Metropolitan Transportation Plan - Alternatives Evaluation

Topic Area Relevant Overarching Policy Evaluation

Economic Vitality Promotes economic vitality and Alternative 1 concentrates housing
prioritizes transportation investment. growth throughout the city but with
intense concentrations on the fringes
of the city. It supports some existing
transit routes investments in
Northwest Spokane and in Center City.
Alternative 2 intensifies growth in
mixed-use areas along frequent transit
routes and corridors, and includes
planned TOD improvement areas,
which helps concentrate
transportation investment.
Alternative 3 focuses investment in
areas with transportation investments
that help improve connections to hubs.
However, it requires the greatest

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Topic Area Relevant Overarching Policy Evaluation

investment in transit and
transportation. It also promotes
mixed-use development and
neighborhood commercial, which
contributes to economic vitality,
particularly in Center City and regional
hubs.

Stewardship Protects the environment and Alternative 1 has intense levels of
minimizes impacts from transportation growth in West Plains, Center City, and
Northeast Spokane specifically the
Hillyard and Chief Garry
neighborhoods.
Alternative 2 intensifies growth in
mixed-use areas, which helps increase
land use efficiency and reduce sprawl,
which helps minimize impacts on the
environment from transportation.
Alternative 3 intensifies growth along
key transportation connections
between regional centers and
promotes multimodal levels of service,
minimizing the transportation impacts
to the environment.

Quality of Life Improves choice and mobility Alternatives 2 and 3 provide for a new
multimodal LOS and improve
accessibility for multiple modes of
transportation. See Section 3.7
Transportation for further discussion
on transportation accessibility.

THRIVE Spokane – Comprehensive Economic Development Strategy Plan

The THRIVE Spokane Comprehensive Economic Development Strategy Plan goals and consistency with
the alternatives are evaluated in Exhibit 3.6-8. Highlights are described below.

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Exhibit 3.6-8 THRIVE Spokane – Alternatives Evaluation

Topic Area Relevant Overarching Strategies and Evaluation
Actions

Recovery and Targets efforts that prepare the region All alternatives would focus the
Resilience to avoid, withstand, and recover from majority of future growth in Downtown
economic shocks and natural disasters. Spokane and in centers and corridors

Alternative 1 concentrates housing
growth in Downtown and in centers
and corridors. It supports some
existing transit routes investments in
Northwest Spokane and in Center City.
Alternative 2 focuses growth along
mixed-use TOD development along
frequent transit corridors, with
planned TOD improvement areas.
Alternative 3 focuses growth in Center
City and in regional hubs. It also
promotes mixed-use development and
neighborhood commercial, which
contributes to economic vitality and
resiliency, particularly in Center City.
See Section 3.5 Population,
Employment, and Housing for further
analysis on growth distribution in the
city.

Competitiveness Positions the region as a strong All alternatives would accommodate
competitor to attract talent, capital, and greater jobs and promote economic
resources for strategic economic opportunity in the city and region.
development.
Alternative 1 has intense levels of
growth in West Plains, Center City, and
Northeast Spokane specifically the
Hillyard and Chief Garry
neighborhoods.
Alternative 2 intensifies growth in
mixed-use areas, which helps support
investment in mixed-use projects and

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Topic Area Relevant Overarching Strategies and Evaluation
Actions

connects workers with growth
employment centers.
Alternative 3 intensifies job growth in
Center City, University District, and
West Plains, supporting economic
agglomeration to attract capital and
resources. It also places capacity for
housing growth for all income levels on
key transportation corridors to support
the connection of workers with
employment centers.

Equitable Seeks to understand, address, and All alternatives would support growth.
Growth dismantle outcome disparity Alternatives 2 and 3 support TOD
development and increase mixed-use
development.

Connectivity Promotes the interconnectedness of All alternatives have growth in well-
Greater Spokane and drives cross-sector connected opportunity areas of
partnerships to align efforts that Spokane. Alternative 2 prioritizes TOD
advance economic opportunity for all. development and growth along
corridors and frequent transit routes.
Alternative 3 establishes the highest
jobs allocation with focused
investment in areas with planned
transportation investments.

Area Specific Evaluation

Northwest Spokane

All alternatives have concentrated growth in Northwest Spokane, in the neighborhoods of North
Indian Trail, Emerson / Garfield, Northwest, and North Hill. Overall, the alternatives support the key
objectives of the neighborhood plans. See Exhibit 3.6-9 for an evaluation of consistency of the
alternatives with neighborhood planning efforts.

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Exhibit 3.6-9. Alternatives Consistency with Northwest Spokane Neighborhood Plans

Neighborhood / Action Plan Alternative 1 Alternative 2 Alternative 3

Emerson-Garfield ● ● ●+
Five Mile Prairie ● ● ●
North Hill ● ●+ ●+
Northwest & Audubon / Shadle Area ●+ ● ●+
West Central ●+ ● ●

Legend: ○ = does not support or partially supports ●=supports ●+ = optimally supports

Neighborhood Planning Efforts
 Emerson-Garfield: Alternatives 2 and 3 promote higher housing growth in the Emerson-Garfield
neighborhood, which supports its neighborhood action plan goals to have strong residential areas.
However, Alternative 1 does have some growth, particularly closer to Center City. Alternatives 1
and 3 have more job growth in this neighborhood than Alternative 2, which supports the
neighborhood action plan to build a vibrant business district.
 Five Mile Prairie: The neighborhood action plan focuses on transportation connectivity and
improvements, and it identifies as a low-density residential neighborhood. Alternative 1
concentrates housing growth in the neighborhood, which may result in changes to the
neighborhood action plan. Alternatives 2 and 3 focus less housing and job growth in this
neighborhood.
 North Hill: Alternatives 2 and 3 anticipate more housing and job growth in the North Hill
neighborhood than Alternative 1. This anticipated growth will help support the neighborhood’s
vision to create a vibrant, higher intensity area.
 Northwest & Audubon / Downriver: Alternatives 1 and 3 have concentrations of housing and job
growth in the Shadle Area of this neighborhood, which support the Shadle Area Neighborhood
Plan to encourage mixed-use growth and diverse housing options. Alternative 2 focuses job growth
in the Shadle Area; however, much of its housing growth is anticipated along the northern border
of the neighborhood.
 West Central: The neighborhood action plan promotes attracting commercial and light industrial
investment while maintaining single unit residential. Alternative 1 forecasts lower housing growth
concentrations in the neighborhood than Alternatives 2 and 3, so it may be more supportive of the
neighborhood plan’s overall goals. Regarding job growth, Alternatives 1 and 3 anticipate higher
concentrations of job growth in the neighborhood than Alternative 2; however, all alternatives are
anticipated to attract economic investment.

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Northeast Spokane

All alternatives have concentrated growth in Northeast Spokane that varies by alternative. Overall, the
alternatives support the key objectives of the neighborhood plans. See Exhibit 3.6-10 for an
evaluation of consistency of the alternatives with adopted plans and neighborhood planning efforts.

Exhibit 3.6-10. Alternatives Consistency with Northeast Spokane Neighborhood Plans

Neighborhood Plan Alternative 1 Alternative 2 Alternative 3

Subarea and TOD Plans
Hillyard Subarea Plan ● ● ●+
South Logan TOD Plan ○ ●+ ●+
Neighborhood Planning Efforts
Bemiss, Hillyard, and Whitman ● ● ●
Chief Garry Park ● ●+ ●+
East Central ● ● ●
Nevada-Lidgerwood ● ● ●
Legend: ○ = does not support or partially supports ●=supports ●+ = optimally supports

Hillyard Subarea Plan

All alternatives have concentrations of housing and job growth in the Hillyard neighborhood.
Alternatives 2 and 3 have high concentrations of housing growth in the Hillyard Business District,
which aligns with the Hillyard Subarea Plan’s vision to build upon assets and promote mixed-use
development in this district. Alternatives 1 and 3 also have concentrations of job growth throughout
The Yard in the Hillyard Subarea, which aligns with the Subarea Plan’s goal to evolve The Yard into a
diverse employment center. All three alternatives have concentrated residential growth in the Beacon
Hill area in the southeast corner of the Hillyard Subarea, which aligns with future redevelopment in
this area.

South Logan TOD Plan and Logan Neighborhood Plan

Alternatives 2 and 3 have high concentrations of housing and job growth in the South Logan
neighborhood. The concentration of growth supports the South Logan TOD Plan, adopted by
resolution in 2023, which focuses on expanding housing options and affordability and drawing in
business investment and residents. In comparison, Alternative 1 has some housing and job growth in
the Logan neighborhood, but it is limited and does not reflect the South Logan TOD Plan since No
Action was based on the Comprehensive Plan in place as of the 2022 base year. The action alternatives

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also support TOD concepts developed in the Transit Oriented Development Framework Study,
adopted by resolution, which emphasized transit-supportive, mixed-use growth at Bus Rapid Transit
station areas in the Chief Garry Park neighborhood along Mission Avenue and near Spokane
Community College.

Other Neighborhood Planning Efforts
 Bemiss, Hillyard, and Whitman: All three alternatives focus job growth in the Hillyard
neighborhood and part of the Bemiss neighborhood. Alternatives 2 and 3 both focus housing
growth along corridors in the Hillyard neighborhood; Alternative 1 focuses housing growth
throughout these three neighborhoods, with housing concentrations on the east border of
Hillyard. Alternatives 2 and 3 align housing and job growth with existing transportation
connections to help enhance livability, a core goal of the neighborhood plan.
 Chief Garry Park Neighborhood: All three alternatives focus housing growth in the northwest
corner of the neighborhood, which aligns with the neighborhood plan’s focus areas for growth.
Both Alternatives 2 and 3 encourage moderate increases in housing density throughout the area,
which aligns with the neighborhood plan to help maintain affordability. Job growth in all three
alternatives is focused on the southern half of the neighborhood.
 East Central Neighborhood: While the existing neighborhood plan focuses primarily on
improvements to the Ben Burr Trailhead, overall neighborhood goals include connectivity. All
alternatives add housing and job growth to East Central. Alternatives 2 and 3 add more housing
growth than Alternative 1, which helps promote connectivity to Center City. All alternatives add
concentrated job growth in the neighborhood.
 Nevada Lidgerwood: Neighborhood planning efforts focus on non-motorized travel safety and
helping to reduce traffic volumes and speed. All alternatives focus job growth in the northwest
corner of the neighborhood. Alternatives 2 and 3 focus housing growth along Division Street, while
Alternative 1 has housing growth in less concentrated amounts throughout the neighborhood.

Division Corridor

Alternatives 2 and 3 focus mixed-use and commercial growth along the Division Corridor, as well as
moderate and high residential density. This aligns with strategies and priorities recommended in the
DivisionConnects Phase 1 and Phase 2 study, which includes development of transit-supportive
strategies including supportive land uses along the corridor, such as mixed-use, commercial, and
higher intensity residential. This also aligns with ongoing planning efforts in the Division Street TOD
Plan, which models transit-supportive growth and mixed-use development at Rowan and Francis Bus
Rapid Transit station areas and in the southern portion of the Division-Ruby couplet.

Alternative 1 primarily concentrates growth in the Division Corridor where it overlaps with the Center
City study area (e.g., near University District, Medical District, and the Downtown Center).

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Center City

All alternatives have concentrated job and housing growth in Center City, with Alternatives 2 and 3
promoting denser concentration of housing growth than Alternative 1. Overall, the alternatives
support the adopted plans’ key objectives. See Exhibit 3.6-11 for an evaluation of consistency of the
alternatives with adopted plans and neighborhood planning efforts.

Exhibit 3.6-11. Alternatives Consistency with Center City Spokane Neighborhood Plans

Neighborhood Plan Alternative 1 Alternative 2 Alternative 3

Adopted Plans
Spokane Downtown Plan ● ●+ ●+
South University District Subarea Plan ● ●+ ●+

Legend: ○ = does not support or partially supports ●=supports ●+ = optimally supports

Spokane Downtown Plan

All alternatives place housing and job growth in Downtown Spokane, which supports the overall vision
of the Downtown Plan. Alternative 2, and particularly Alternative 3, focus higher concentrations of
housing in the Center City and Downtown area than Alternative 1. Higher densities of housing in this
area support the Plan’s vision to promote higher density residential with a range of housing options
and mixed-use development. Regarding job development, Alternative 3 places higher job growth in
Center City, which supports the Downtown Plan vision to build upon its emerging activity centers and
promote mixed-use development.

South University District Subarea Plan

Compared to Alternative 1, Alternatives 2 and 3 place higher concentrations of housing and job
density in this area which supports the subarea plan’s vision of a lively mixed-use urban village design
of residential, retail, institutional, and artisan/light industrial uses. Alternative 3 in particular would
provide more housing and jobs than other alternatives.

South Spokane

All alternatives have concentrated job and housing growth along corridors and nodes in South
Spokane, and on vacant land in the Grandview and Latah neighborhoods. See Exhibit 3.6-12 for an
evaluation of consistency of the alternatives with neighborhood planning efforts.

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Exhibit 3.6-12. Alternatives Consistency with South Spokane Neighborhood Plans

Neighborhood Plan Alternative 1 Alternative 2 Alternative 3

Neighborhood Planning Efforts
Grandview / Thorpe ● ● ●
Peaceful Valley ● ● ●
South Hills Coalition ● ● ●
Does not include Browne’s Addition; that neighborhood plan is focused on a master park plan.
Legend: ○ = does not support or partially supports●=supports ●+ = optimally supports

Neighborhood Planning Efforts
 Grandview / Thorpe: The neighborhood action plan prioritized establishing a neighborhood
activity center or small-scale retail node. All alternatives anticipate a similar level of housing and
job growth.
 Peaceful Valley: The neighborhood action plan focuses on community connectivity, walkability,
and traffic safety. All alternatives place similar levels of growth and support these objectives.
 South Hill Coalition: The neighborhood coalition plan focuses on connectivity, enhancing livability,
and fostering a cohesive and vibrant South Hill. The alternatives support these neighborhood
objectives, with all alternatives placing housing growth in focused concentrations in Southgate,
Lincoln Heights, and Rockwood neighborhoods. Alternative 3 also places higher concentrations of
housing growth in Cliff Cannon than Alternatives 1 and 2. Job growth follows similar geographic
concentrations across all alternatives, with job growth in Lincoln Heights, Southgate, and Cliff
Cannon. Alternative 3 shows higher concentrations of job growth in South Hill neighborhoods
closer to the Center City core in the medical district. All alternatives show similar levels of support
for these plan objectives and are anticipated to contribute to livability and cohesiveness in the
South Hill area.

West Plains

The West Plains Subarea Transportation Management Plan focuses on promoting a balanced mix of
land uses to support efficient use of the transportation system. All alternatives promote similar
concentrations of job growth in the West Plains neighborhood. Regarding housing growth, Alternative
1 has concentrations of housing growth in the West Plains neighborhood, near the Grandview /
Thorpe and Latah neighborhoods. Alternatives 2 and 3 anticipate lower levels of concentrated growth
in this area. The anticipated housing and job growth concentrations in West Plains support the overall
goal to balance land uses in this neighborhood.

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Comparison of Impacts

Environmental Justice Implications

Climate Resilience and Greenhouse Gas Reduction Policies

Alternatives 2 and 3 will add climate planning, which include new climate resilience and greenhouse
gas reduction goals and policies per HB 1181. In comparison, Alternative 1 No Action continues
current natural environment policies and critical areas regulation, but these were not designed to
meet the new HB 1181 requirements in full.

Without these climate resilience goals and policies, Alternative 1 may increase vulnerability for
overburdened communities in the city. These community members often have fewer resources and
may face greater harm should they be impacted by extreme weather (e.g., extreme heat, wildfire
smoke). Alternative 1 may also place disproportional health impacts on vulnerable populations (e.g.,
children, seniors, and people with preexisting health conditions) affected by increased exposure to air
pollution, heat, and other climate-related hazards. Furthermore, it may deepen disparities among
community members with adaptive capacity and more vulnerable community members without these
resources.

Alternatives 2 and 3 add climate planning, which increases goals and policies in climate resilience and
greenhouse gas emission reduction. Possible effects include prioritizing improvements to vulnerable
communities to increase resilience (e.g., tree planting, cooling centers), equity integrated in climate
planning to increase recovery capacity should an extreme weather event occur, and targeted
greenhouse gas emission strategies to help improve local air quality in communities located near
traffic or industrial use.

Alternative 1: No Action, Stay the Course
Alternative 1 No Action would meet GMA goals regarding urban growth served by transportation and
urban services. It would not meet new GMA requirements to amend the Housing Element to address
new requirements in HB1220 regarding housing opportunities by income band. While it has enough
land capacity to accommodate housing and job growth targets, it does not have enough capacity to
accommodate housing targets at all income levels, specifically housing for those with incomes at 0-
80% of AMI. Alternative 1 No Action also does not meet HB 1181 requirements to include new climate
resilience and greenhouse gas reduction goals and policies.

Regarding regional planning policies, Alternative 1 meets CPPs related to focusing growth in the urban
area that is coordinated with urban services. It also generally supports regional coordination efforts
related to transportation and economic development. While the City has existing multimodal
transportation level of service standards, Alternative 1 does not update its multimodal transportation
level of service to adopt VMT and GHG reduction goals for transportation. Alternative 1 also does not
meet capacity for affordability housing targets and does not include climate policies that could help

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address environmental issues related to air quality. Alternative 1 is also generally supportive of
policies in the SRTC Horizon 2045 Metropolitan Transportation Plan and THRIVE Spokane.

Regarding local planning efforts, Alternative 1 is generally supportive of local neighborhood plans’
objectives but assumes a growth strategy before the completion of the South Logan TOD Plan and the
DivisionConnects corridor strategy. See Impacts Common to All Alternatives for more details.

Alternative 2: Distributed and Balanced
Alternative 2 would be consistent with state and regional goals. Similar to Alternative 1, it would meet
GMA goals regarding urban growth served by transportation and urban services. Unlike Alternative 1,
it would meet new GMA requirements to update the Housing Element in the Comprehensive Plan to
address new requirements in HB1220 regarding housing opportunities by income band. It has enough
capacity to accommodate housing targets at all income levels. Alternative 2 includes climate planning,
with goals and policies that are consistent with HB 1181. It would also update the critical areas
regulations.

Regarding regional planning policies, Alternative 2 meets CPPs, including focused growth in the urban
area and the provision of urban services. It concentrates growth along frequent transit routes and
corridors to support regional transportation planning investments. It also provides for an updated
multimodal LOS that adopts VMT and GHG reduction goals. In addition, it supports improved mobility
and accessibility efforts for multiple travel modes due to its concentration of housing and job growth.
Similarly, Alternative 2 is supportive of regional transportation planning policies and THRIVE Spokane,
due to its concentration of growth along frequent transit routes and corridors. The jobs/housing
balance in concentrated areas of the city that aligns with transportation investment helps support
mixed-use and TOD improvements, and aligns with regional economic goals around recovery,
resiliency, equitable growth, and connectivity.

Regarding local planning efforts, Alternative 2 supports or optimally supports local neighborhood
plans. See Impacts Common to All Alternatives for more details. Below is an evaluation of how
Alternative 2 supports adopted projects and subarea plans incorporated in the City’s Comprehensive
Plan and/or municipal code.

Northeast Spokane

Alternative 2 concentrates housing and job growth in the Logan neighborhood, which supports the
goals and objectives in the South Logan TOD Project and Plan. It aligns with land use and zoning
changes to support a mixed-use corridor along Hamilton Street and aligns with TOD investments in
this neighborhood. It also has concentrations of housing growth and promotes mixed-use
development in the Hillyard neighborhood, aligning with the Hillyard Subarea Plan’s vision.

Division Corridor

Alternative 2 adds greater housing and job intensity along frequent transit routes, with mixed-use,
commercial, and higher density residential along Division Street. This aligns with the DivisionConnects

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Phase 2 study and Division Street TOD Plan, which models transit-supportive growth and mixed-use
development at Rowan and Francis Bus Rapid Transit station areas and in the southern portion of the
Division-Ruby couplet.

Center City

Alternative 2 focuses high concentrations of housing and job growth in the Center City, including
Downtown and the South University District. These higher concentrations of growth align with the
Spokane Downtown Plan to promote higher density residential growth and mixed-use development
and with the South University District Subarea Plan to have higher concentrations of housing and job
growth to support a lively mixed-use urban village.

Alternative 3: Center City and Regional Hubs
Impacts under Alternative 3 are similar to those described under Alternative 2. The alternative
concentrates jobs and housing growth in regional hubs with connections to the Center City and North
Spokane corridor in the Hillyard area and includes the planned growth in the 5th Avenue Corridor on
the southern end of the corridor. Alternative 3 has the highest jobs allocation, with focused
investment in key employment centers, which supports locally adopted projects and subarea plans,
including the Spokane Downtown Plan, the South University District Subarea Plan, the South Logan
TOD Plan, and the Hillyard Subarea Plan These Plans support increased business and commercial
investment, the promotion of mixed-use development, and lively centers, which will be supported
through the concentrated residential and job growth in Alternative 3.

3.6.3 Mitigation Measures

Incorporated Plan Features
Features of the alternatives that help increase policy and plan consistency include:
 Alternatives 2 and 3 meet housing targets at all income levels to address state housing
requirements in HB 1220.
 Alternatives 2 and 3 include climate planning goals and policies in the Comprehensive Plan to
implement state requirements of HB 1181 to have a Climate Element.

Regulations and Commitments
As required by GMA, the City must submit proposed Comprehensive Plan amendments and updated
regulations for review and comment by the State prior to final adoption.

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Other Potential Mitigation Measures
When a Preferred Alternative is developed, it should be evaluated for conformity to state and regional
plans and policies. This may include reallocating growth assumptions in certain areas while still being
in the range of the studied alternatives.

3.6.4 Significant Unavoidable Adverse Impacts
No anticipated unavoidable adverse impacts are anticipated with respect to plans and policies.
Inconsistencies with new regional plans and state requirements under the No Action Alternative would
be avoided through amendments to the Comprehensive Plan proposed under the action alternatives.

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3.7 Transportation
This section describes citywide existing transportation conditions in the City of Spokane, establishing a
baseline for evaluating potential future performance of the growth alternatives presented in Chapter 2
of the Draft Environmental Impact Statement (DEIS). This section provides an inventory of existing
pedestrian, bicycle, transit, vehicle, and freight networks, documents overall safety conditions, and
assesses mobility, access, and equity across the city.

The transportation existing conditions baseline reflects available data and adopted plans, including
Spokane’s Pedestrian and Bicycle Master Plans, and supports analysis of how each alternative could
affect travel behavior, infrastructure performance, and user experience. This chapter also identifies
key metrics and evaluation criteria used to assess impacts and potential mitigation measures,
consistent with the overarching goals of PlanSpokane 2046.

Study Area
The City of Spokane is Washington State’s second largest city and covers an area of approximately 69
square miles. The primary transportation study area is within the City’s limits; connections to
neighboring jurisdictions are also considered to reflect regional travel patterns. For a citywide
description of the EIS alternatives and study area, see Chapter 2 (Proposal and Alternatives). A map of
the City’s limits, urban growth areas, and neighborhoods is available in Section 2.1.3 Study Area.

Data and Methods
This analysis evaluates the potential transportation impacts of the Spokane Comprehensive Plan
growth alternatives using a combination of citywide datasets, regional planning tools, and multimodal
performance measures.

The transportation analysis provides a citywide, programmatic assessment of how growth alternatives
would affect travel behavior, congestion, and multimodal network performance. Rather than
evaluating individual projects, the methods are designed to compare how overall land use affect
system-level travel and access to mobility options.

A set of qualitative and quantitative metrics is utilized to compare how each alternative affects
conditions for people walking, bicycling, taking transit, and driving. Results are summarized at both the
citywide and subarea levels to capture variations in land use and travel patterns.

For the Vehicle Network and State Facilities, quantitative metrics are used to measure performance.
These metrics are defined below.

Intersection Level of Service (LOS)
Intersection LOS is a qualitative measure used to evaluate traffic operations and delay at signalized
and unsignalized intersections. It is defined in the Highway Capacity Manual (HCM) and widely used by
transportation agencies across the U.S., including WSDOT and the Spokane Regional Transportation

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Council (SRTC). LOS is expressed as a letter grade from A to F, representing the average delay
experienced by vehicles during peak conditions.

LOS Letter Grades:
 LOS A: Free flow: Little to no delay (≤10 seconds); high comfort and freedom of movement.
 LOS B: Stable flow: Slight delay (10–20 seconds); minor restriction to maneuverability.
 LOS C: Stable flow with more delay: Moderate delay (20–35 seconds); acceptable performance in
urban areas.
 LOS D: Approaching unstable flow: Noticeable delays (35–55 seconds); common threshold for
acceptable performance in cities like Spokane.
 LOS E: Unstable flow with significant delays: High delay (55–80 seconds); nearing capacity with poor
progression.
 LOS F: Forced or breakdown flow: Very high delay (>80 seconds); over-saturated conditions, often
resulting in queuing and driver frustration.

Volume-to-Capacity Ratio (v/c) Summary
The volume-to-capacity ratio (v/c) is a performance metric used to assess how efficiently a roadway or
intersection is operating. It compares the actual traffic volume using a facility to its maximum carrying
capacity:

v/c = traffic volume ÷ roadway capacity

A v/c ratio < 1.0 indicates that demand is within the available capacity.

A v/c ratio = 1.0 suggests the facility is operating at capacity.

A v/c ratio > 1.0 means demand exceeds capacity, often resulting in congestion, delays, and
queuing.

Transportation agencies like WSDOT and SRTC use v/c ratios to evaluate system performance, identify
deficiencies, and prioritize improvements in corridor planning and environmental review.

VMT per Capita and Mode Share
Vehicle-Miles-Traveled (VMT) per capita and mode share are travel‑behavior indicators used to
compare growth alternatives at a citywide, programmatic scale. VMT Per-capita measures driving by
population, and mode share shows how trips are distributed across drive alone (SOV), shared ride
(HOV), transit, walk, and bike. These metrics are planning-scale indicators intended for relative
comparison among land use patterns.

Results are derived from the SRTC regional travel demand model for the study years (2024 existing
and 2046), with model post-processing consistent across all alternatives. Future funded projects and
service assumptions, such as the North Spokane Corridor and Division Street BRT, are constant across
alternatives for comparability.

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3.7.1 Affected Environment
This section describes the existing transportation network within the City of Spokane. The
transportation network consists of pedestrian, bicycle, transit, and City and state-owned roadway
facilities, serving general purpose and freight traffic.

Pedestrian Network
The City’s pedestrian network consists of sidewalks, crosswalks, shared-use paths, neighborhood
streets, and trails. The existing sidewalk network is mapped in Exhibit 3.7-1. Most major arterials have
sidewalks on one or both sides of the road. However, there are considerable gaps in the sidewalk
network in the West Plains and Northwest Spokane area and generally in the outer area of the City.
Overall, north-south connectivity is also limited by the barriers of I-90 and SR 290 which have limited
crossings and fewer adjacent sidewalks.

With the introduction of the 2015 Pedestrian Master Plan, the City of Spokane has worked to address
gaps in the pedestrian network as a core element of its multi-modal transportation system alongside
the implementation of its Complete Streets ordinance. These plans, in addition to the City’s
maintenance programs, ensure that the pedestrian network can be continually upgraded and
maintained.

In addition, the 2015 Pedestrian Master Plan11 established City Pedestrian Priority Zones, which are
designated areas where the City will aim to invest in pedestrian infrastructure. These zones were
chosen through an analysis of pedestrian demand and deficiencies and aim to enhance safety and
walkability, particularly around schools, parks, and transit stops. These zones are spread throughout
the city, and are periodically evaluated based on growth and pedestrian activity.

11
City of Spokane, https://my.spokanecity.org/projects/pedestrian-master-plan/, 2015

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Exhibit 3.7-1. Spokane Existing Pedestrian Facilities

Sources: City of Spokane, Fehr & Peers, 2025

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Northwest Spokane
Sidewalk completeness generally improves closer to the City’s core and activity nodes, while peripheral
areas like Indian Trail and Five Mile Prairie have more gaps. Sidewalk infill continues on along the key
diagonal connection of Driscoll Boulevard. Within Pedestrian Priority Zones, the City’s plan highlights
locations such as the Monroe Street Corridor, Cannon & Maxwell Center, and Shadel Center (Ash
Street/Wellesley Avenue) for pedestrian access and safety improvements tied to centers and corridors.

Northeast Spokane
Northeast Spokane includes a mix of neighborhoods with uneven sidewalk coverage and more
frequent gaps on the outskirts and along some local streets. Priority locations emphasize access along
in centers and corridors such as the Five Mile Center (Division Street/Francis Avenue), the Hamilton
Corridor, and the Market Street Corridor adjacent to the North Spokane Corridor. In the Hillyard
neighborhood, sidewalks are less frequent on corridors, such as Wellesley Avenue and Freya Street, in
the industrial and commercial areas east of the North Spokane Corridor (NSC).

Center City
Center City has the highest concentration of existing sidewalks in Spokane, with few missing segments.
However, north-south pedestrian connectivity is occasionally constrained by geographic barriers such
as the Spokane River and the BNSF railway. Key connectors that help bridge these obstacles include
the Post Street Bridge in Downtown Spokane and the University District Gateway Bridge over the BNSF
tracks. Most of the City’s pedestrian priority zones are located within this subarea, reflecting its high
pedestrian demand and infrastructure focus.

South Hill / South Spokane
In this subarea, sidewalk gaps are prevalent on the periphery of the city, which is largely related to the
age of the neighborhood. The Pedestrian Master Plan identified several pedestrian priority zones
adjacent to US 2, I-90, and in the Lincoln Heights neighborhood. These areas are prioritized for
improvements to enhance walkability and safety.

West Plains
The West Plains subarea is predominantly industrial and lacks a comprehensive sidewalk network.
Pedestrian access is constrained by proximity to major infrastructure such as the airport, US 2, I-90,
and large industrial buildings. Notably, this is the only subarea in Spokane without any designated
pedestrian priority zones under the Pedestrian Master Plan.

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Bicycle Network
The bicycle network includes several facility types as designated in the City’s 2017 Bicycle Master Plan.
These bikeway types include Bike Lanes, Bike Friendly Routes, Neighborhood Greenways, Shared Use
Paths, and Soft Surface Paths. In addition, the Bicycle Master Plan establishes a desired 2037 bicycle
network, which would extend Spokane’s bicycle network to roughly 400 miles.

Exhibit 3.7-2 shows the existing bicycle network in Spokane. The City’s network primarily consists of
bike friendly routes, bike lanes, and shared-use paths. Neighborhood greenways have been
implemented along Cincinnati Street and are in progress in several other locations. There are also
several soft-surface paths, mainly along the Spokane River and on the outskirts of the city.

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Exhibit 3.7-2. Spokane Existing Bicycle Network Facilities

Sources: City of Spokane, Fehr & Peers, 2025

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The City’s Bicycle Priority Network (Exhibit 3.7-3) identifies a fully connected, all-ages-and-abilities set
of priority bikeways that link neighborhoods to schools, parks, transit, jobs, and activity centers. The
Bicycle Priority Network was assembled with the input of community stakeholders to compose a
network composed of a primary spine plus an Expanded Priority Network of important connections.
The Bicycle Priority Network targets low-stress riding and aims for practical spacing of about 1/2 mile
between parallel routes in most of the city and no more than 1 mile in less-dense areas. The Bicycle
Priority Network is a planning network used to inform future bikeway implementation; not all priority
routes have facilities today.

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Exhibit 3.7-3. Spokane Bicycle Priority Map

Sources: City of Spokane, Fehr & Peers, 2025

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Northwest Spokane
Northwest Spokane’s bicycle network features the Spokane River Centennial Trail, which is a
recreational and commuter spine linking neighborhoods to the Center City and Spokane Falls
Community College. Recent projects are closing gaps, for example, the Maxwell Avenue (Pettet–
Walnut) Bike/Pedestrian Safety Upgrades, completed in October 2025, added buffered bike lanes that
connect the Centennial Trail to Maxwell at Walnut. The City’s Bicycle Priority Network highlights lower-
stress corridors parallel to the high-traffic Ash/Maple Street north–south couplet, with intersecting
bike-friendly routes completing east–west connections between the river and the Division Street
corridor.

Northeast Spokane
Northeast Spokane’s bicycle network features the Children of the Sun Trail, which is a shared-use path
along the North Spokane Corridor that links the county area of Wandermere south toward Spokane
Community College and the Centennial Trail. The City’s Bicycle Priority Network focuses on linking
neighborhoods to this north-south connector and to major activity corridors. Emphasis is on creating
lower-stress east–west alternatives to Wellesley Avenue to link the Market and Haven Street corridor
with the Division Street Corridor and improve access to schools, parks, and transit.

Center City
The Center City’s bicycle network is primarily composed of shared use paths, with additional bike-
friendly routes located throughout the area. Despite this multimodal presence, some of Spokane’s
highest-stress bicycle facilities are located in Center City, contrasting with its well-developed
pedestrian network. One notable low-stress facility is the bike-friendly route along Pacific Avenue,
which is classified as LTS 1, and the Centennial Trail which provides a continuous shared-use facility
extending east-west through downtown. Both routes provide more comfortable connection for cyclists
in the downtown core.

South Hill / South Spokane
This subarea features a range of bicycle facilities, including bike-friendly routes, shared use paths, and
bike lanes. In some locations, neighborhood greenways and soft surface paths supplement the
network. The Ben Burr Trail provides a connection linking East Central and Lincoln Heights to the
Centennial Trail and University District. The Fish Lake Trail serves Latah Valley and Grandview-Thorpe,
and the City’s Fish Lake–to–Centennial Trail Connection project will extend the trail north to the
Centennial Trail and improve access from these neighborhoods toward Center City. However,
compared to other subareas, South Hill and South Spokane generally have fewer low-stress bicycle
routes, limiting accessibility for less confident riders.

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West Plains
The West Plains subarea has minimal bicycle infrastructure, with the limited network primarily
composed of shared use paths, soft surface paths, and a bike-friendly route. Historically, many
segments are high-stress for everyday cycling. Sunset Boulevard provides a key connection between
the West Plains, Spokane International Airport, and the broader Spokane network, and the City’s
Sunset Highway Trail – Spotted Road to Royal Street project. This project will provide a 10 to 12-foot
dedicated multi-use path on the north side of Sunset, improving safety and connectivity for people
biking and walking along the corridor.

Transit Network
Transit in Spokane is governed primarily by Spokane Transit Authority (STA). STA has established
several transit plans to guide the development of the transportation network, such as STA Connect
2035, the Zero-emission Transition Plan, STA Moving Forward, as well as major ongoing projects such
as Division Street Bus Rapid Transit and the I-90/Valley High Performance Transit (HPT) Project.

STA’s fixed route transit network consists of frequent routes, regional routes, Bus Rapid Transit (BRT),
and regular transit routes. Exhibit 3.7-4 provides a summary of the existing STA routes. In addition,
the City’s existing transit network is shown in Exhibit 3.7-5. There are several transit routes
throughout the Center City and options for east-west connectivity, especially due to transit offerings
along I-90.

Exhibit 3.7-4. Summary of Existing Fixed Transit Types and Descriptions

Route Type Route Type Description

Bus Rapid Transit Frequent rapid transit service along the six-mile route between Browne’s
(City Line - STA Addition and Spokane Community College, connecting through
Route 1) downtown and the University District, including Gonzaga University.
Frequent Routes Local service at frequent intervals: every 15 minutes on weekdays and
every 15-60 minutes on weekends.
Regional Routes STA operates several regional and commuter routes between major
destinations. These routes are designed to provide regional links and
typically serve Park & Ride lots, transit centers, and key destinations
during peak commute times.
Regular Routes Local service at varying intervals: every 30-60 minutes on weekdays and
varying service by route on weekends and nights. Multiple routes may
serve certain segments/stops, which combine to provide more frequent
service.
Source: Spokane Transit Authority

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Exhibit 3.7-5. Existing Transit Routes in Spokane

Sources: City of Spokane, Fehr & Peers, 2025

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While the City does not operate local transit, it supports transit by partnering with STA on street,
sidewalk, and bikeway improvements that enhance transit reliability and access. The City also
coordinates with STA on bus-priority treatments such as Business Access and Transit (BAT) lanes and
transit signal priority.

Several projects are currently in development by STA to enhance the City’s transit network. Division
Street Bus Rapid Transit (BRT) is part of a regional vision to bring frequent, reliable service along the
US 2 corridor within the City of Spokane. STA, the project’s lead agency, is implementing several
enhancements including improved passenger facilities, transit priority elements, and Business Access
and Transit (BAT) lanes. Construction is expected to begin in 2028. In addition, the I-90/Valley High
Performance Transit (HPT) Project is expected to establish new transit service and transit amenities,
such as Park-and-Rides and transit centers throughout the region, focusing on the I-90 corridor.

Northwest Spokane
This subarea is served by STA’s frequent and regular routes providing connections to Center City and
east–west across the city. Frequent routes that link Northwest Spokane with Center City and Northeast
Spokane include Route 4 (Monroe Street) and Route 33 (Wellesley Avenue), respectively. Other key
regular routes within this area include Route 22 (Northwest Boulevard), 23 (Maple/Ash Street), Route
35 (Francis Avenue), and Route 36 (Maxwell Avenue).

Northeast Spokane
This subarea is similarly served by STA frequent and regular routes. Route 28 (Hamilton/Nevada
Street) offers frequent north–south connections to the Center City, and Route 33 (Wellesley Avenue)
provides frequent service between Northeast and Northwest Spokane. Consistent with STA’s plans,
Route 33 (Wellesley) is identified for future investment as a High-Performance Transit corridor and is
slated to be the next major route improvement following Division Street BRT. Service includes
continuations of Route 35 (Francis Avenue) and Route 36 (Maxwell Avenue), plus regular service of
Route 27 that connects Center City and Shiloh Hills and Route 31 that connects Shiloh Hills to Spokane
Community College. The City Line provides high-frequency service linking the University District and
Spokane Community College, crossing the Spokane River, and connecting Northeast Spokane to
Center City.

Center City
Center City functions as both a major destination and a transfer hub within the STA network, with
most transit routes offering connections throughout the subarea. Several regional routes pass
through Center City, linking it to other parts of Spokane County. The City Line also runs predominantly
through this subarea, reinforcing its role as the core of the regional transit system.

South Hill / South Spokane
This subarea is served by Route 4, a single frequent route, that connects its southeastern
neighborhoods with Center City. Regular transit routes in South Hill and South Spokane operate at
lower frequencies and provide broader geographic coverage across the area. The Latah Valley
currently does not have fixed route service.

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West Plains
Transit in the West Plains is organized around the West Plains Transit Center (WPTC), which functions
as the area’s transfer hub. The area within the city limits is served by three STA routes: Route 61
(Highway 2/Fairchild), a regular route along US 2/Sunset Highway serving Airway Heights and Fairchild
AFB; Route 7 (Valley/Airport), a high-speed regional link that provides service between
Downtown/Spokane Valley and Spokane International Airport; and Route 6 (Cheney) providing
frequent, limited-stop service between Downtown/University-District, the West Plains, and Cheney.

Vehicle Network
The City of Spokane is a major regional hub, with a vehicle and freight network that connects
Washington, Idaho, Montana, Oregon, British Columbia, and Alberta. The City’s vehicle network
consists of major arterials, minor arterials, collector, and local access streets, as shown in Exhibit
3.7-6. Currently, the vehicle network includes five highways: I-90, US 2, SR 290, SR 291, SR 395, and SR
195. However, the regional network will soon be expanded by the completion of the North Spokane
Corridor (NSC) project, a 10.5-mile multi-modal connection between I-90, US 2, and SR 395.

As part of the previous Spokane Comprehensive Plan update in 2017, the City also substantially
updated their Street Design Standards12. The City’s Street Design Standards shape the development,
redevelopment, and reconstruction of facilities built in the City’s right-of-way and ensure their
consistency. As part of their Street Design Standards, the City provides definitions and applications for
its principal street classifications. These street classifications are expected to be evaluated alongside
zoning contexts when initiating the design process for modifications to the City’s roadway
infrastructure.

The City’s vehicle network and its functional classifications are summarized in Exhibit 3.7-6 below. The
arterials tend to follow a grid pattern, especially within the Center City. The Spokane River shapes the
layout of some roads, while also dividing South Spokane from the rest of the city. In addition, several
bridges provide major crossing points to connect the vehicles, freight, and active transportation users.
These bridges are mapped in Exhibit 3.7-7 below.

12
City of Spokane. “Design Standards.” Engineering Services. https://my.spokanecity.org/business/bid-and-
design/design-standards/

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Exhibit 3.7-6. Spokane Vehicle Network and Roadway Classification

Sources: City of Spokane, WSDOT, Fehr & Peers, 2025

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Exhibit 3.7-7. Spokane Transportation Network Bridges

Sources: City of Spokane, Fehr & Peers, 2025

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Existing Intersection LOS
The following table (Exhibit 3.7-8) presents 22 representative intersections selected for evaluation of
existing (2024) intersection LOS as part of the EIS. These intersections were chosen to ensure a diverse
sample that reflects a range of neighborhood contexts and land use contexts across the city. The
selection includes locations with a range of multimodal activity, existing development, and planned
growth or infrastructure investment.

Exhibit 3.7-8. Spokane Intersection LOS

Location LOS Standard Existing (2024)
LOS

S Hatch Rd and E 57th Ave (One-way stop control) E E
S SE Blvd and E 29th Ave E C
S Grand Blvd and E 29th Ave E C
N Havana St and E Sprague Ave E D
N Napa St and E Sprague Ave E C
SR 290/E Trent Ave and N Hamilton St D E
US2/S Division St and E Sprague Ave* F B
US 2/N Ruby St and E Indiana Ave* D C
US 2/N Division St and W Buckeye Ave/E North D C
Foothills Dr
US 2/N Division St and Wellesley Ave D E
US 2/N Division St and W Francis Ave* D D
US 2/N Newport Hwy and E Holland Ave D D
W 3rd Ave and S Monroe St F B
N Maple St and W Boone Ave E C
E Mission Ave and N Hamilton St E D
N Market St and E Euclid Ave E D
N T J Meenach Dr and W Northwest Blvd* E D
N Ash St and W Wellesley Ave E C
E Wellesley Ave and N Haven St* E C
N Market St and E Francis Ave E D
SR 291/W Francis Ave and N Alberta St D D
US2/W Sunset Hwy and Flint Rd D C
Notes: *Analyzed with HCM 2000; BOLD indicates LOS fails to meet standard
Sources: City of Spokane, WSDOT, Fehr & Peers, 2025

Northwest Spokane / Northeast Spokane
The roadway network in this subarea follows a mostly gridded layout, with some diagonal and
curvilinear streets that respond to natural features such as the Spokane River. Major highways serving

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the area include US 2/Division Steet, SR 290, and SR 291, which provide regional connections and
support both local and through traffic.

Division Corridor
Division Street serves as a major north-south arterial and carries the US 2 highway designation north
of I-90. East-west connectivity across Division Street is supported by several intersecting arterials. One
vehicular bridge carries Division Street over the Spokane River, serving as a critical crossing point
within the city’s transportation network. The planned STA Division Street Bus Rapid Transit (BRT) will,
in phases, convert one lane in each direction to Business-Access-and-Transit (BAT) lanes. Completion
of the BRT project will coincide with the final phase of the NSC, which will shift some traffic off Division
Steet.

At the intersection of US 2/Division Street at Wellesley Avenue, a state-route intersection, the
applicable LOS standard is D (WSDOT). The intersection is a key crossroad serving Northwest and
Northeast areas. The intersection is a focal point of the Division corridor, with heavy turning
movements and frequent transit activity supporting adjacent retail and services. As the Division Street
BRT project is implemented in phases, this location will sit within the BRT corridor and transit service
improvements.

Center City
Center City serves as a focal point of Spokane’s roadway system, with many arterial streets throughout
the city designed to converge on or connect with this subarea. US 2 and I-90 are the primary highways
traversing Center City, and due to the presence of geographic and infrastructure barriers, including
the BNSF railway and the Spokane River, this area also contains numerous bridge crossings that
facilitate multimodal and vehicular access. In addition, Center City includes several parallel one-way
street couplets that concentrate north–south movements and access, notably the Monroe/Lincoln
couplet and the Division/Ruby one-way couplet.

At the intersection of SR 290/E Trent Avenue and N Hamilton Street, a state-route intersection, the
applicable LOS standard is D (WSDOT). Existing operations are LOS E, indicating the location fails to
meet standard under current conditions. The intersection is within the South Logan TOD Planned
Action Area established to implement the South Logan Transit-Oriented Development Plan.

South Hill / South Spokane
South of I-90, the street network begins as a grid but becomes more irregular where challenging
topography limits road construction. I-90 and SR 195 serve as the primary highway connections in this
subarea. Several vehicular bridges span SR 195, I-90, and other geographic constraints, supporting
access between residential areas, employment centers, and regional corridors.

West Plains
The West Plains subarea is primarily served by I-90 and US 2, which provide east-west and regional
connectivity. There are two key vehicular bridges in this area, one crossing I-90 and another crossing
Sunset Highway, that facilitate access across these major corridors.

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State Facilities
The City of Spokane is served by a network of state-owned highways (Exhibit 3.7-9) that are essential
for regional mobility, freight movement, and economic development. These facilities are owned and
maintained by the Washington State Department of Transportation (WSDOT) and include both
Highways of Statewide Significance (HSS) and other regionally significant routes.

Exhibit 3.7-9. State Routes and Functional Classifications
Route Functional Description and Connectivity
Classification

I-90 Urban– A major east-west corridor connecting Spokane to Seattle and the
Interstate Midwest. It is the primary interstate route through Spokane and a critical
freight and passenger corridor.

US 2 Urban Other Connects Spokane to northern Idaho and western Washington. US 2
Principal Arterial spans east-west across the West Plains and north-south between
Northwest and Northeast Spokane. It provides access to Spokane
International Airport and supports regional freight and commuter traffic.

US Urban Other A north-south corridor connecting Spokane to Colville and Canada. Along
395 Freeways and Northeast Spokane, the North Spokane Corridor (NSC) is a major
Expressways realignment project for this route to improve freight mobility.

US Urban Other Connects Spokane to Pullman and Lewiston, Idaho. Within South
195 Freeways and Hill/South Spokane, it is a key highway for travel and freight south of I-90.
Expressways

SR 290 Urban Other Connects downtown Spokane to Spokane Valley and Idaho. It supports
Principal Arterial commuter and freight traffic and is a designated freight corridor.

SR 291 Urban Other Serves Northwest Spokane and connects to Nine Mile Falls. It supports
Principal Arterial local and recreational travel.
Sources: WSDOT, Fehr & Peers, 2025

These classifications are consistent with WSDOT’s functional classification system and are used for
planning, funding, and performance monitoring purposes.

SEPA and State-Owned Facilities
The City of Spokane is evaluating adoption of the housing infill State Environmental Policy Act (SEPA)
categorical exemption under RCW 43.21C.229, and potential updates to local categorical exemption
thresholds as outlined in WAC 197-11-800, as part of this Comprehensive Plan EIS. This EIS evaluates
those exemptions under each growth alternative, including the required multimodal transportation

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analysis of impacts to the local network, neighboring jurisdictions, transit facilities, and the state
transportation system. If specific adverse impacts are identified with the Action alternatives, mitigation
will be proposed and implemented through locally adopted plans and development regulations
consistent with RCW 43.21C.229.

In accordance with RCW 43.21C.229 and WAC 197-11-800, the City of Spokane will consult with the
WSDOT when proposed SEPA exemptions or threshold increases may affect state highway facilities.

Existing State Facility Segment v/c ratios
The following table (Exhibit 3.7-10) summarizes selected state highway segments within the City of
Spokane used to evaluate directional weekday PM peak-hour volume-to-capacity (v/c) ratios. Segments
were chosen to represent a mix of facility types and land-use contexts and to align with locations
where WSDOT collected directional hourly traffic counts in 2024. Planning capacities are the
directional link capacities from the Spokane Regional Transportation Council (SRTC) regional travel
demand model; volumes are the 2024 WSDOT counts at the listed locations. The v/c ratio equals the
directional weekday PM peak-hour volume divided by the corresponding planning capacity.

Exhibit 3.7-10. Existing State Facility Performance (v/c Ratio)
Location Roadway Existing Existing
Type Volume/Capacity v/c Ratio

I-90 east of the US 2 interchange (Spokane) Freeway 8,340 / 13,300 0.63

I-90 west of the Sprague Ave interchange Freeway 11,130 / 11,400 0.98
(Spokane Valley)

US 2 north of North River Dr - northbound only Arterial 2,530 / 4,900 0.52
(Spokane)

US 2 (Division St couplet) south of Euclid Ave - Arterial 1,720 / 4,900 0.35
southbound only (Spokane)

US 2 north of Walton Ave (Spokane) Arterial 3,610 / 9,800 0.37

US 2 east of the Sunset Frontage Rd Arterial 3,080 / 6,200 0.50
intersection

SR 291 northwest of the Wind River Dr Arterial 1,290 / 6,200 0.21
intersection

SR 291 northwest of the Nine Mile Rd wye Arterial 2,000 / 6,200 0.32
connection

US 195 south of the I-90 off-ramp Freeway 2,150 / 6,900 0.31

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Location Roadway Existing Existing
Type Volume/Capacity v/c Ratio

SR 195 northwest of the Cheney–Spokane Rd Freeway 2,020 / 7,600 0.27
on-ramp

US 195 north of Hatch Rd (median crossover Freeway 1,430 / 6,200 0.23
location)

SR 902 south of the Geiger Blvd wye connection Arterial 1,510 / 2,600 0.58
Sources: WSDOT, SRTC, Fehr & Peers, 2025

Northwest Spokane
Within the city, SR 291 serves the Northwest area and connects Spokane to Nine Mile Falls and SR 231.
Existing v/c ratios of 0.21–0.32 indicate available corridor capacity.

Northeast Spokane
WSDOT is constructing the NSC as a new limited-access freeway that will connect I-90 to US 2 at the
north end of the city. Remaining phases include the I-90 connection, with WSDOT indicating
completion in 2030. Once open, the NSC adds north–south capacity for regional and local trips and
facilitates a shift of traffic from local arterials to the new regional connector. SR 290/Trent Ave is an
east–west state route linking the University District to the Idaho state line, functioning as an alternate
to I-90 for commuter and freight movements.

South Hill / South Spokane
US 195 is the main southern corridor, linking South Hill and the Latah Valley to I-90 and downtown.
Existing v/c ratios of 0.23–0.32 indicate available capacity. However, due to continued growth in the
Latah Valley, a SRTC-led US 195/I-90 study was conducted which identifies a package of near- and
longer-term investments, so more short trips can use local routes, and the highway can focus on
regional travel.

West Plains
US 2 connects the West Plains, including industrial areas, Fairchild Airforce Base, and Spokane
International Airport, to central Spokane. US 2 also connects to the neighboring City of Airway Heights.
An existing v/c ratio around 0.50 indicates moderate utilization with remaining capacity.

Division Corridor
US 2/Division Street is currently the main north-south corridor for north of I-90. Existing v/c ratios of
0.35–0.52 indicate available capacity in the corridor. The planned STA Division Street BRT will, in
phases, convert one lane in each direction to Business-Access-and-Transit (BAT) lanes. Completion of
the BRT project will coincide with the final phase of the NSC, which will shift some traffic off Division
Street.

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I-90
I-90 is the primary east–west corridor, carrying most regional through-traffic with limited alternatives.
Existing v/c is approaching 1.0, indicating the facility is at capacity. Current regional plans focus on
interchange/bridge projects and transit along the corridor; no additional mainline capacity is planned.

Freight
Spokane acts as a major distribution and logistics hub for the region, especially due to its proximity to
I-90 which carries more than 10 million tons of freight per year. Exhibit 3.7-11 below shows the City’s
freight network and each roadway’s classification under Washington State’s Freight and Goods
Transportation System (FGTS). The freight network in Spokane consists of I-90, state routes, and major
arterials that link the city and its key freight destinations with the local, regional, and international
freight network. The new North Spokane Corridor (NSC) project is anticipated to become a new key
element of the City’s freight network by improving mobility and freight access. By connecting US 395 to
I-90, the NSC will offer an alternative north-south route through the city, relieving pressure on local
arterials.

The City’s zoned industrial areas include the “Yard” in the Hillyard neighborhood of Northeast
Spokane, areas surrounding Trent Avenue within Northeast Spokane, and most of the West Plains
area. These zoned industrial areas are shown in an overlay in Exhibit 3.7-11. Nearby, Spokane Valley is
home to several additional industrial zones and the Spokane Valley switching yard, which is vital to the
area’s railway network.

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Exhibit 3.7-11. Spokane Freight Routes

Sources: City of Spokane, WSDOT, Fehr & Peers, 2025

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Northwest Spokane
Compared with the northeast, Northwest Spokane has limited industrial zoning with light-industrial
pockets near the Center City edge, and freight activity is driven more by through truck routes than by
large industrial activity. Key designated truck routes include the Maple/Ash Street couplet, which
facilitate north–south freight movements into and through downtown.

Northeast Spokane
Northeast Spokane has designated industrial land-use, including the Hillyard industrial area. These
areas are served by freight corridors such as the Market/Haven Street couplet with direct connections
to SR 290 (Trent Avenue) and I-90. Completion of US 395/NSC by WSDOT in 2030 will strengthen
regional freight movement and facilitate a shift of north-south freight traffic from local arterials to the
higher-capacity corridor.

Center City
The I-90 corridor through Center City is the second of Spokane’s two T1 FGTS freight routes, serving as
a critical link in the regional and international freight network. Multiple highways converge in this
subarea, making it a major freight hub. As a result, much of Spokane’s core freight infrastructure is
concentrated in the Center City.

South Hill / South Spokane
This subarea contains no designated Heavy-Light Industrial zones and has relatively limited freight
infrastructure. The few freight routes that do serve this area are classified within the lower FGTS tiers,
reflecting their smaller role in regional goods movement.

West Plains
The West Plains subarea is largely industrial and plays a significant role in Spokane’s freight economy.
It is served by FGTS freight routes, including I-90, which provide essential connectivity to regional and
national freight corridors. These facilities support the movement of goods to and from large industrial
developments and the Spokane International Airport.

Safety
The Spokane Regional Transportation Council (SRTC) completed in 2024 the SRTC Regional Safety
Action Plan13, which provided a high-level overview of fatal and serious injury (FSI) crashes within
Spokane County from 2018 to 2022.

Within Spokane, a large share of vulnerable-user FSI (people walking and biking) occurs on arterials
and in a core area. The City’s Vision Zero Action Plan identifies a 12-square-mile Priority Study Area
that contains 68 of 162 vulnerable-user FSI crashes. About 85% of those vulnerable-user FSI crashes
occur on the arterial system. Key contributing factors include lack of traffic control, speeding, turning

13
SRTC Regional Safety Action Plan - Crash Analysis Technical Memorandum

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movements at signals, and dark lighting conditions. Recommended countermeasures emphasize
leading pedestrian intervals, protected bike facilities, shorter crossings, lighting upgrades, and ADA
improvements.

Spokane’s ongoing Vision Zero policies, Vision Zero Action Plan, and programs – such as speed
management, signal timing upgrades and LPIs, crossing protection, ADA upgrades, and access
management – aid in systematically reducing risk for all growth alternatives.

A tabulated summary of updated crash data from WSDOT (2020-2024) is shown in Exhibit 3.7-12. The
five-year data including 2024 mirrors a similar story as SRTC’s Regional Safety Action Plan that people
walking and biking are over-represented in KSI relative to their share of trips.

Exhibit 3.7-12. Summary of Fatal and Serious Injury Crashes by Mode and Severity in Spokane
including State Routes (2020 - 2024)

Mode Type Fatal Suspected Suspected Possible No Apparent Unknown
Serious Injury Minor Injury Injury Injury

Bicycle 2 30 183 62 24 0
Pedestrian 42 135 332 164 12 1
Pedestrian and 1 1 0 0 0
Bicycle
Vehicle-Only 54 325 1956 3585 11818 550

Grand Total 98 491 2472 3811 11854 551
Sources: WSDOT, Fehr & Peers, 2025

VMT and Mode Share
Spokane’s transportation environment is summarized with two systemwide metrics: vehicle miles
traveled (VMT) per capita and citywide mode share. VMT per capita is a measure of total driving by the
number of people generating trips in the city. Mode share (Exhibit 3.7-13) shows how people choose
to travel on a typical weekday across all trip purposes (drive alone, shared ride, transit, walk, and bike).
Both metrics come from the SRTC regional travel model for the 2024 base year and include intrazonal
travel and a standard allocation of external trips to Spokane. These values provide the reference point
for the Impacts section, which evaluates whether alternatives change VMT per capita relative to No
Action and whether Spokane’s travel behavior shifts toward or away from non-auto modes.

VMT per capita (service population): 17.9 miles/person (weekday)

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Exhibit 3.7-13. Mode share (all person trips, %)

Drive Shared Transit Walk Bike
alone ride

50.6 39.5 1.2 7.3 1.4
Sources: SRTC, Fehr & Peers, 2025

Regulatory Context

Pedestrian Master Plan
The Spokane Pedestrian Master Plan14 was adopted by City Council in 2015 and provides a framework
for improving citywide walkability. The plan established Pedestrian Priority Zones to guide investments
to areas based on walking access to key destinations, demand, and infrastructure deficiencies. These
zones help the City target pedestrian infrastructure investments. The plan includes a pedestrian needs
analysis, crash data review, and programmatic recommendations. It emphasizes closing sidewalk gaps,
enhancing crossings, and integrating pedestrian planning with land use. Funding strategies include
local, state, and federal sources, and the plan supports implementation through detailed project
identification and prioritization.

Americans with Disabilities Act (ADA) Transition Plan
The City of Spokane’s draft ADA Transition Plan15, covering the years 2014-2019, outlines the City’s
commitment to provide equal access to public programs, services, and facilities for individuals with
disabilities. It provided a comprehensive self-evaluation of the City’s facilities and programs to
understand existing barriers for individuals with disabilities and establish potential improvements and
implementation steps. This document followed federal requirements outlined in Section 504 of the
Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990 and recent amendments.
Locally, street projects are guided by the Public Right of Way Accessibility Guideline (PROWAG). This
plan was set to be updated every five years, but there have been no further publicized updates to this
plan. Key themes from this plan relevant to transportation include:
 Addressing the backlog of accessibility needs on the public street system and ensuring compliance
with current ADA standards across new capital projects, design standards, and plans

14
Spokane Pedestrian Master Plan (2015). City of Spokane, project page.
Overview: my.spokanecity.org/projects/pedestrian-master-plan
15
ADA Transition Plan (2014–2019). City of Spokane.
PDF (Draft/Plan document): ada-transition-plans-draft.pdf

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 Emphasizing interdepartmental coordination, public outreach, and funding strategies to
implement accessibility improvements.

Spokane Bicycle Master Plan
The Spokane Bicycle Master Plan16, adopted in May 2017, aims to create a safe, connected, and
accessible bicycling environment for all ages and abilities. It has been amended four times within the
City’s Comprehensive Plan update process and is complemented by the addition of a Bicycle Priority
Network described below. The Bicycle Master Plan establishes a vision for enhancing bicycling
opportunities, increasing bicycle mode share, and enhancing the City’s bicycle network. It establishes a
goal of 5% of all trips in Spokane being taken on a bicycle. The first part of this plan provided policies
and action items meant to encourage construction of bicycle projects, support facilities, maintenance,
education, funding, evaluation, and more. This plan also establishes a proposed 400-mile bicycle
facility network as part of the 2017 Comprehensive Plan update. Facilities were expected to be
prioritized as the opportunity arises.

Spokane Bicycle Priority Network
The City’s Bicycle Priority Network17 is a citywide, all-ages-and-abilities network used to prioritize
bikeway upgrades when streets are improved or redesigned and strengthen grant applications. It
complements, but does not replace, the adopted Bicycle Master Plan. The Bicycle Priority Network was
developed with data and community-informed measures and refined with input from the Bicycle
Advisory Board. The Bicycle Priority Network includes key routes with an Expanded Priority Network of
important connections.

Complete Streets Ordinance
The City’s Complete Streets Ordinance18 (17H.020) was passed in December 2011 with the purpose of
ensuring all users are considered in the construction of all City transportation improvement projects. It
also establishes that all street projects shall include Complete Streets elements as mentioned in the
Bicycle Master Plan and Pedestrian Master Plan with an additional set of performance measures which
will be reviewed through an annual progress report. A 2024 update to this ordinance also established
a Transportation Commission which is meant to study significant transportation issues and programs
and make recommendations that align with the overall Complete Streets Ordinance.

16
Spokane Bicycle Master Plan. City of Spokane.
Overview: my.spokanecity.org/projects/bicycle-master-plan
17
Bicycle Priority Network (BPN). City of Spokane.
Project page (North/South maps & interactive viewer links): my.spokanecity.org/projects/bicycle-priority-network
18
Complete Streets Ordinance (SMC 17H.020). City of Spokane Municipal Code.
Chapter: SMC 17H.020 – Complete Streets Program

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Spokane Comprehensive Plan 2017
The City of Spokane’s Comprehensive Plan19 was last updated in 2017 and provided a guiding
document for growth within the City. Chapter 4 of the Spokane Comprehensive Plan outlined the city’s
transportation vision and strategies through 2040. It emphasized a balanced, multimodal system that
supports economic vitality, public health, and environmental sustainability. Key goals included
promoting transportation choices, enhancing safety, supporting economic development, and
maintaining infrastructure.

Spokane Vision Zero
The Spokane Vision Zero Action Plan20, published in June 2023, establishes the City’s commitment to
eliminate fatal and serious injuries among all road users. Based on analyses from 2017-2021, the plan
introduces the City’s Vision Zero resolutions (2022-0107), identifies high risk corridors and
intersections for all users, with a focus on particularly vulnerable road users such as pedestrians and
cyclists. Key strategies include:
 Infrastructure improvements (e.g., curb extensions, protected bike lanes), speed management, and
public education.
 Prioritizing equity by focusing on underserved areas
 Providing performance metrics for tracking progress.

Connect Spokane
Connect Spokane21 is STA’s comprehensive public transportation plan, originally adopted in 2010 and
revised in 2024. It provides a 30-year vision for transit services, focusing on High Performance Transit,
fixed-route, paratransit, and flexible services. The plan is structured around guiding principles, policies,
and performance standards to ensure equitable, efficient, and sustainable transit.

Key goals include expanding multimodal access, integrating land use and transit planning, and
promoting equity and sustainability. The plan outlines detailed service design principles, infrastructure
investment strategies, and fare policies. It also includes performance metrics and remediation
strategies to ensure continuous improvement and alignment with regional development.

19
Spokane Comprehensive Plan (2017 update). City of Spokane.
Comprehensive Plan hub (Shaping Spokane / current plan):
my.spokanecity.org/shapingspokane/comprehensive-plan
20
Vision Zero. City of Spokane.
Project page: my.spokanecity.org/projects/vision-zero
21
Connect Spokane (Comprehensive Plan for Public Transportation). Spokane Transit Authority (STA).
Plan page: spokanetransit.com/projects/comprehensive-plan

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Spokane Transit Authority (STA) Planning and Projects
STA operates the City’s public transportation options and currently has several plans and projects22 to
expand the transit network. These plans include STA Connect 2035, the Zero-emission Transition Plan,
STA Moving Forward, as well as major ongoing projects such as Division Street Bus Rapid Transit and
the I-90/Valley High Performance Transit (HPT) Project.

Horizon 2045: Spokane Metropolitan Transportation Plan
Horizon 204523 is Spokane Regional Transportation Council’s (SRTC) long-range transportation plan
and was adopted in December 2021. It addresses the Spokane Metropolitan Planning Area’s
transportation needs through 2045, focusing on multimodal transportation, sustainability, and
performance-based planning. It provides information on regionwide demographic and land use
forecasts, safety and infrastructure performance targets, and public transit, freight, and active
transportation strategies.

Spokane Regional Transit Council Regional Safety Action Plan
The Spokane Regional Transportation Council’s Regional Safety Action Plan24, adopted in June 2024,
establishes a regional commitment to the goal of zero roadway facilities and serious injuries with
target goals in 2030 and 2042, with periodic assessments every four to five years. The plan identifies
high injury networks and proposes potential targeted safety improvements across Spokane County.
Other elements of this plan include detailed crash analysis, community feedback, and recommended
safety strategies.

Summary and Key Findings
The regulatory context for evaluating Spokane’s transportation network is shaped by several key plans
and upcoming projects. The Spokane Pedestrian Master Plan (2015) and Spokane Bicycle Master Plan
(2017) focus on improving the pedestrian and bicycling networks, respectively, while identifying key
investment areas for each mode. Meanwhile, the City of Spokane’s Complete Streets Ordinance (2011)
supports the City’s Pedestrian and Bicycle Master Plans and provides additional sets of performance
metrics to evaluate the City’s transportation network. The draft ADA Transition Plan aims to ensure
new street projects are guided by the Public Right of Way Accessibility Guideline (PROWAG) and meet
ADA standards. The City’s Vision Zero Action Plan (2023) and SRTC’s Spokane Regional Safety Action

22
STA Planning & Projects.
Projects & Plans hub (Connect 2035, STA Moving Forward, etc.): spokanetransit.com/about-sta/projects-plans
23
Horizon 2045 — Metropolitan Transportation Plan (MTP). Spokane Regional Transportation Council (SRTC).
MTP hub: srtc.org/our-work/core-plans-and-programs/metropolitan-transportation-plan
24
Regional Safety Action Plan (RSAP). SRTC.
RSAP page: srtc.org/our-work/safety-planning/regional-safety-action-plan

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Plan (2024) aim to eliminate traffic fatalities and injuries by targeting improvements and periodic
safety assessments across the City and the region.

STA’s Connect Spokane plan, along with related initiatives like the Zero-emission Transition Plan and
Moving Forward, provide long-term guidance for public transit, supported by major projects such as
Division Street Bus Rapid Transit and the I-90/Valley HPT Project. SRTC’s Horizon 2045 regional plan
addresses regional transportation needs through 2045 with a focus on sustainability and
performance-based planning.

Existing conditions, gaps, and opportunities across the city are summarized below based on modal
type.

Pedestrian Network
 Northwest Spokane / Northeast Spokane has several gaps in the sidewalk network, especially
towards the edges of the city and along some unpaved street segments within these areas.
Pedestrian priority zones are concentrated near the Spokane River, along Division Street, and near
the North Spokane Corridor.
 The Center City has the highest concentration of existing sidewalks with few missing segments. Key
connectors include the Post Street Bridge and the University District Gateway Bridge. Most
pedestrian priority zones are located within the Center City subarea.
 South Spokane also has sidewalk gaps toward the periphery of the city, including some unpaved
street segments. There are some pedestrian priority zones in this subarea, adjacent to US 2, I-90,
and in the Lincoln Heights neighborhood.
 The West Plains subarea lacks a comprehensive sidewalk network and has no designated
pedestrian priority zones.

Bicycle Network
 In Northwest Spokane / Northeast Spokane, east-west routes are mostly bike-friendly lacking
bicycle facilities, with some shared use paths and bike lanes. North-south routes in this area vary,
with higher BLTS along Maple Street and Euclid Avenue.
 The Center City subarea’s bicycle network is primarily composed of shared use paths and bike-
friendly routes. Despite this, some of the highest BLTS bicycle facilities are located here due to
absent or substandard bicycle facilities on bicycle routes with high traffic volumes.
 The South Hill/South Spokane area features a range of bicycle facilities but generally has fewer low-
stress routes compared to other subareas.
 In the West Plains subarea, the bicycle infrastructure is minimal and mostly high-stress, with
limited connectivity.

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Transit Network
 The subareas of Northwest Spokane / Northeast Spokane are served by many frequent routes that
provide north-south connections into the Center City. East-west connectivity in this subarea is
supplemented predominantly by regular routes, offering lower frequencies but greater coverage.
 The Center City subarea offers a major destination and transfer hub with most transit routes
offering connections throughout the subarea, including the City Line.
 South Hill / South Spokane is served by a single frequent route connecting southeastern
neighborhoods with Central City. Other routes operate at lower frequencies.
 In the West Plains subarea, transit service is served by high-speed regional routes and other
regular routes.

Vehicle Network
 In Northwest Spokane / Northeast Spokane, the roadway network follows a mostly gridded layout
with major highways including US 2, SR 290, and SR 291.
 In Center City, US 2 and I-90 are the primary highways, and many arterial streets converge into the
Center City.
 For South Hill / South Spokane, the street network has topographical challenges south of I-90. I-90
and SR 195 are the primary highways.
 The West Plains area is primarily served by I-90 and US 2, which provide essential connectivity.
 Division Street serves as a major north-south arterial and carries the US 2 highway designation
north of I-90. East-west connectivity across Division Street is supported by several intersecting
arterials. One vehicular bridge carries Division Street over the Spokane River, serving as a critical
crossing point within the city’s transportation network.

Metrics evaluated for the vehicle network include intersection LOS and segment LOS:
 Intersection LOS was evaluated at 22 intersections within the city and WSDOT using LOS standards.
Of these intersections, two locations currently fail to meet their LOS standard: S Hatch Rd/57th
Avenue, located in South Spokane; and Division Street (US 2)/Wellesley Avenue on the Division
Street Corridor.
 Of the state facilities that were evaluated for segment LOS, none currently have a v/c ratio higher
than 1.00.

Freight Network
 Northwest Spokane / Northeast Spokane contains many designated industrial zones and a high-
volume freight corridor providing connections to SR 290 and I-90.
 In the Center City, the I-90 corridor serves as a critical link in the regional and international freight
network.
 In South Hill / South Spokane, there are no designated Heavy-Light Industrial zones, which
translates to limited freight infrastructure. Existing freight infrastructure tends to be classified as
lower-tier freight routes.

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 The West Plains subarea is largely industrial with several higher-tier freight routes, including I-90,
and key facilities like the Spokane International Airport.

Safety
Severe crashes in Spokane concentrate on higher-volume arterials and major intersections with
people walking and biking over-represented in KSI crashes. A higher share of serious and fatal injuries,
especially for vulnerable users, is clustered in Center City. The City’s Vision Zero policy and related
programs provide the citywide framework for prioritizing investments regardless of alternative.

VMT and Mode Share
Spokane’s travel is predominantly auto oriented. VMT per capita is 17.9. Mode share: 50.6% drive
alone, 39.5% shared ride, 1.2% transit, 7.3% walk, 1.4% bike. Values come from the SRTC regional
model. These metrics provide the reference point for evaluating alternatives.

3.7.2 Impacts
This section provides an overview of the impacts related to each of the three future year alternatives
established by the City of Spokane: Alternative 1: Stay the Course (the No Action alternative),
Alternative 2: Distributed and Balanced, and Alternative 3: Center City and Regional Hubs. This section
also provides an overview of the thresholds of significance used to determine each alternative’s
impact, a description of these proposed alternatives, methodology used to evaluate the future year
analyses, and an overall summary of impacts.

Description of Evaluated Alternatives

Evaluated Alternatives
The City is evaluating three growth alternatives as part of the Comprehensive Plan update. Each
alternative accommodates projected population and employment growth but differs in how
development is distributed, the intensity of land uses, and the relationship to transportation
infrastructure. More detailed descriptions of the land use assumptions and policy basis for these
alternatives are provided in Chapter 2.

Alternative 1 – Stay the Course (No Action)
This alternative represents continuation of the current Comprehensive Plan, zoning, and development
regulations. Growth would follow existing patterns under current rules, with jobs and housing
allocated consistent with Spokane Regional Transportation Council (SRTC) projections. While this
scenario provides sufficient overall capacity to meet growth targets, it does not substantially change
land use or transportation relationships compared to today.

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Alternative 2 – Distributed and Balanced
This alternative focuses additional housing and employment growth along frequent transit corridors
and emphasizes a stronger jobs–housing balance. It applies recommendations from the Centers and
Corridors Study to simplify land use designations, encourage mixed use, and support neighborhood-
scale retail. Growth is more evenly distributed across the city, with capacity for housing at all income
levels. Employment assumptions reflect State Employment Security Department trends. This
alternative is intended to leverage the transit network to support transportation and climate goals.

Alternative 3 – Center City and Regional Hubs
This alternative directs the greatest concentration of growth to Center City, selected corridors, and
regional hubs. Housing growth is focused in urban centers with high-capacity transit, while major job
growth is allocated to the West Plains, Northeast Spokane, Downtown, and University District.
Industrial and institutional job concentrations align with regional transportation facilities such as the
airport, rail corridors, and the North Spokane Corridor (NSC). This alternative places a greater
emphasis on investment in a limited number of hubs and corridors to maximize transportation
infrastructure efficiency.

Analysis Methodology
The transportation analysis evaluates how each growth alternative would affect the city’s multimodal
network, including roadway operations (for autos and freight), transit demand, walking, bicycling, and
safety conditions. Key elements of the methodology include:

Transportation Network Assumptions
This EIS uses Spokane Regional Transportation Council’s (SRTC) regional travel demand model (TDM),
which has a 2022 base year and a 2050 forecast horizon. Results for this study are reported for 2024
existing conditions and a 2046 horizon year. The 2024 base year is used because screenline volumes
and turning-movement counts were collected in 2024 and used to validate the model for this analysis.
To quantify land use for 2024 and 2046, households and employment were linearly interpolated at the
Transportation Analysis Zone (TAZ) level between SRTC’s 2022 base and 2050 forecasts, then input to
the TDM to produce network outputs for 2024 Existing and the 2046 alternative scenarios. Resulting
daily 2024 volumes from the TDM are within 2 to 4% of 2022, providing a current, representative
baseline while remaining consistent with the 2022–2050 SRTC model framework.

The analysis also incorporates planned transportation investments by the City and partner agencies,
and these projects provide the baseline network assumptions. Major projects particularly relevant to
this analysis include:
 North Spokane Corridor (NSC): Completion of the NSC, along with associated transit investments.
 Division Street Bus Rapid Transit (BRT): Implementation of high-capacity transit service and
Business Access and Transit (BAT) lanes along Division Street.

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In addition to these projects, the model includes a range of roadway extensions, intersection
improvements, safety enhancements, and transit upgrades delivered by the City of Spokane (Six-Year
Comprehensive Street Program), Spokane County (Six-Year Transportation Improvement Program),
WSDOT, and Spokane Transit Authority (Connect Spokane and the Transit Development Plan). See
Chapter 5 Appendix C Transportation Project Implementation Table for each modeled project’s
lead agency, status, and funding pathway.

Regional plans are updated periodically, and additional projects may be adopted before the City’s 2046
horizon year. For this EIS, these projects serve as an assumption for reasonably foreseeable
transportation network improvements applied across all growth alternatives.

Travel Demand Forecasting
The Spokane Regional Transportation Council (SRTC) maintains a regional travel demand model that is
used to predict how travel behavior will change based on land use and transportation network inputs.
The model is a tool best used to compare the relative differences among alternatives rather than to
provide a precise prediction of future travel behavior. In other words, the model identifies which
growth alternatives are likely to result in greater or lesser transportation impacts, though the exact
locations and magnitude of future impacts cannot be forecasted with certainty in this programmatic
EIS where specific development projects are unknown.

The SRTC model is a conventional four-step model, meaning it estimates travel patterns by
sequentially estimating trip generation, trip distribution, mode choice, and trip assignment. It relies on
survey data, demographic information, land use assumptions, and transportation system
characteristics to represent the ways people travel in the Spokane region. The model is regularly
calibrated and validated to reflect observed conditions and regional travel surveys.

Key features of the SRTC travel demand model include:
 Analysis Years: The most recent model update established a base year of 2022 and a forecast
horizon year of 2050. As noted within the Transportation Network Assumptions subsection, the
results for this analysis are reported for 2024 existing conditions and a 2046 horizon year.
 Land Use: Land use forecasts were developed for each alternative using Transportation Analysis
Zones (TAZs) that cover Spokane and the broader region. TAZ-level assumptions for households,
employment, and demographic characteristics are maintained by SRTC for consistency across
agencies.
 Network Representation: The model includes the regional roadway system, major transit
services, and other multimodal infrastructure. This allows forecasts of traffic volumes, transit
ridership, and other metrics on key corridors and intersections across the Spokane region.
 Transit and Active Modes: In addition to auto and truck travel, the model estimates demand for
transit, bicycle, and walking trips, supporting analysis of multimodal system performance.
 Travel Demand: Travel demand is forecast across four daily time periods (AM peak, midday, PM
peak, and night). For this EIS analysis focuses on the PM peak period, when the largest number of
trips occur.

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Vehicle Network Performance
Intersection LOS and roadway segment v/c was analyzed at the same 22 study intersections and 12
state highway segments as were analyzed in the Affected Environment Section 3.7.1. For intersections,
2024 PM peak turning movement counts provide the existing baseline, and 2046 forecasts were
developed from the SRTC regional travel demand model using standard post-processing methods. For
state segments, 2024 WSDOT counts provide the existing baseline, and future-year growth from the
SRTC model is added to those counts with planning capacities coming from the SRTC model network.
All segment results are total, weekday PM peak hour unless noted otherwise. Results are compared to
adopted City LOS standards and WSDOT standards. For state facility segments, the volume to capacity
(v/c) ratio is used for evaluation.

Transit and Active Modes
For each growth alternative, a comparison is drawn based on the proposed concentration of
development relative to funded investments such as Division Street BRT and City Line and to
pedestrian and bicycle networks. Results from the Vehicle Network Performance analysis are used to
identify corridors where congestion or access constraints may affect transit reliability. Key
considerations are walk access to transit service, continuity of bikeways, and major barriers. Findings
are interpreted alongside VMT per capita and mode share and used to inform the determination of
significant impacts and potential mitigation.

VMT and Mode Share
Vehicle Miles Traveled (VMT) is the sum of all miles traveled by vehicles in the city over the course of a
particular period. For the purposes of this EIS, VMT is aggregated at the daily level using the SRTC
regional travel demand model for 2024 Existing and 2046 for all alternatives and then divided by the
total number of Spokane residents and workers for each scenario. Therefore, VMT per capita is an
estimate of the average number of vehicle miles traveled by each Spokane resident and/or worker.
This metric speaks to how travel behavior may shift with different land use concentrations and mixes
as it captures changes in mode choice as well as vehicle trip length.

Mode share is the proportion of person trips taken by each travel mode. This EIS reports daily mode
share for trips that begin or end within the City of Spokane using the SRTC regional travel demand
model for 2024 Existing and 2046 for all alternatives. Modes are reported as drive alone (SOV), shared
ride (HOV), transit, walk, and bike. Mode share indicates how travel behavior is expected to change
with different land use patterns and transportation investments.

Thresholds of Significance
The thresholds used to determine the impacts of all three alternatives include both quantitative and
qualitative assessments, which are described in Exhibit 3.7-14.

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Exhibit 3.7-14. Thresholds of Significance

Performance
Thresholds of Significance
Metric

Alternative 1 (No Action): A significant impact is identified if the City cannot
achieve 100% of the 2017 Bicycle Master Plan network by 2037 as established in
Active the previous Spokane Comprehensive Plan (TR 5) or if pedestrian improvements
Transportation are not advanced in designated Pedestrian Priority Zones.
Network
Completeness Action Alternatives: A significant impact is identified if network completion
under the Action alternative lags relative to the No Action alternative or fails to
accelerate progress toward bicycle and sidewalk network completeness.

Alternative 1 (No Action): A significant impact is identified if bicycle ridership
Active fails to increase toward the 2017 Bicycle Master Plan goal of quadrupling by
Transportation 2036 (relative to 2016 levels).
Usage Action Alternatives: A significant impact is identified if ridership increases are
less than the No Action alternative.

Alternative 1 (No Action): A significant impact is identified if there is
noncompliance with the City’s Vision Zero resolution, adopted in late 2022,
meaning there is an increased risk of any single traffic death or injury on City
Traffic Safety streets by 2042 (Vision Zero resolution horizon year).

Action Alternatives: A significant impact is identified if an Action alternative
would increase the likelihood of additional severe or fatal crashes compared to
the No Action alternative.

Alternative 1 (No Action): A significant impact is identified if study intersection
or corridor LOS falls below adopted standards (LOS F within Downtown and
within designated Centers/Corridors; LOS E elsewhere) or if pedestrian/bicycle
Transit Access connections to STA facilities decline.
and Performance
Action Alternatives: A significant impact is identified if there is an impact
according to the vehicle network performance thresholds for facilities used by
transit.

Alternative 1 (No Action): A significant impact is identified if vehicle operations
fail to meet adopted intersection standards: LOS F (>120 seconds of delay)
within the Downtown and the area bounded by and including the Spokane
Vehicle Network
River, Maple Street, 5th Avenue, and Sherman Street, and within zones that are
Performance
designated by the City as “Centers and Corridors”; LOS E applies elsewhere. For
state routes, an impact occurs if a state facility does not meet the standard set
by WSDOT (LOS D, segment volume-to-capacity (v/c) 1.00).

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Performance
Thresholds of Significance
Metric

Action Alternatives: A significant impact is identified if an intersection (city or
state facility) degrades from an acceptable LOS in the No Action scenario; if the
intersection already exceeds LOS thresholds in the No Action scenario, then an
impact is identified if delay increases by 5 or more seconds. For state route
segments, a significant impact is identified if the segment v/c increases by ≥0.05
at a location already at or above 1.00 under the No Action alternative.

Alternative 1 (No Action): A significant impact is identified if daily VMT per
capita increases by ≥ 1.0 miles/person or if SOV (drive alone) share increases by
VMT per Capita ≥ 1.0 percentage point over 2024 conditions.
and
Mode Share Action Alternatives: A significant impact is identified if daily VMT per capita
increases by 0.2 miles/person or if SOV share increases by 0.2% relative to the
No Action alternative.
Sources: City of Spokane, WSDOT, SRTC, Fehr & Peers, 2025

Impacts Common to All Alternatives
This section describes the assessed impacts common to all alternatives.

Pedestrian Network
The City’s Pedestrian Master Plan, which recommended policies and actions to support a more
walkable Spokane, supports the City of Spokane pedestrian system upgrades. The Pedestrian Master
Plan also established City Pedestrian Priority Zones, which are discussed in further detail within the
Affected Environment section. This Pedestrian Master Plan acts as an implementation plan under the
conditions expected as part of the No Action alternative because the No Action alternative follows the
policies and actions in place during the creation of the Pedestrian Master Plan. Under the No Action
alternative, these Pedestrian Master Plan improvements would be implemented to support continued
growth and pedestrian activity.

With Alternative 2, housing growth would be concentrated along transit corridors, encourage mixed-
use, and support neighborhood-scale retail. As redevelopment occurs in these areas, City code
requires frontage improvements and reconstruction of adjoining sidewalk to meet City standards. It is
expected that this alternative would not inhibit the implementation of the Pedestrian Master Plan
compared to the No Action alternative.

Alternative 3 directs growth to the Center City and regional hubs, depending on high-capacity transit
access and major industrial job growth. This emphasis on focused growth in targeted areas aims to
maximize transportation infrastructure efficiency, which would help accelerate pedestrian
improvements in these selected areas through frontage improvements. It is expected that this

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alternative would not inhibit the implementation of the Pedestrian Master Plan compared to the No
Action alternative.

Overall, none of the alternatives are expected to inhibit the City’s ability to improve its pedestrian
network and achieve future pedestrian goals. The City will continue to move forward with other
neighborhood improvements, prioritization, and future planning of pedestrian improvements. In
parallel, the planned refresh to the Pedestrian Master Plan will update the City’s baseline and
prioritization to reflect growth, needs, and project delivery since 2017.

Finding Common to All Alternatives

Growth would increase walking activity, and adopted programs will continue regardless of the selected
alternative. Impacts to the pedestrian network are expected to be similar across alternatives and not
result in a significant impact.

Bicycle Network
Through the City’s Bicycle Master Plan, the City of Spokane provided categorizations for its various
bicycle facility types and established a desired 2037 bicycle network. The Bicycle Master Plan also
established a bicycle ridership goal, which aims to quadruple bicycle ridership between 2016 and
2036. The Bicycle Master Plan establishes the City’s implementation plan under the conditions
expected as part of the No Action alternative.

The No Action alternative retains the same policies, actions, and land use expectations as anticipated
during the creation of the Bicycle Master Plan. Therefore, the improvements highlighted under the
Bicycle Master Plan are expected to be implemented to support continued growth in cyclist activity.

Alternative 2 places additional housing growth along transit corridors, encourages mixed-use, and
supports neighborhood-scale retail. Alternative 3 directs growth to the Center City and regional hubs
based on high-capacity transit access and major industrial job growth. Neither of these growth
alternatives would necessitate reducing scope or extending the timeline of implementation of the
Bicycle Master Plan compared to the No Action alternative.

Finding Common to All Alternatives

None of the alternatives are expected to inhibit the City’s ability to improve its bicycle network and
achieve their Bicycle Master Plan goals such as increasing bicycle ridership, although implementation
pace may depend on funding, land use patterns, and other construction activity.

State Facilities
The state facilities reviewed are located across the city, with a select number just outside the city limits,
and include I-90, US 2, US 195, SR 902, SR 291, and SR 195. For each alternative, growth from the SRTC
regional travel demand model was added to existing WSDOT 2024 counts at the study locations to

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estimate future volumes. The directional link capacities from the SRTC model are used as planning
capacities for this analysis.

Results in Exhibit 3.7-15 reflect weekday PM peak hour, directional conditions at selected state
segments.

Across all studied locations and all three alternatives, v/c ratios are expected to remain below 1.0;
therefore, no significant state facility impacts are identified. The pattern shows modest growth and
small differences among alternatives, with the following corridors nearing but not exceeding capacity:
 I-90 west of Sprague Avenue (Spokane Valley) operates at v/c of 0.88–0.90 across alternatives
 US 2 east of the Sunset Frontage Road intersection operates at v/c of 0.83–0.84
 SR 902 south of the Geiger Blvd wye connection operates at v/c of 0.87–0.89

Exhibit 3.7-15. Spokane Existing State Facility Volume-to-Capacity Ratio

Roadway
Type / Alt 1 Alt 1 v/c Alt 2 Alt 2 v/c Alt 3 Alt 3 v/c
Location Capacity Volume Ratio Volume Ratio Volume Ratio

I-90 east of the US 2 Freeway
10,960 0.82 11,030 0.83 11,030 0.83
interchange (Spokane) 13,300

I-90 west of the Sprague
Freeway
Ave interchange (Spokane 13,590 0.89 13,320 0.88 13,640 0.90
15,200
Valley)

US 2 north of North River
Arterial
Dr - northbound only 2,620 0.54 2,730 0.56 2,790 0.57
4,900
(Spokane)

US 2 (Division St couplet)
south of Euclid Ave - Arterial
1,670 0.34 1,640 0.33 1,680 0.34
southbound only 4,900
(Spokane)

US 2 north of Walton Ave Arterial
3,410 0.35 3,300 0.34 3,350 0.34
(Spokane) 9,800

US 195 south of the I-90 Freeway
2,670 0.39 2,730 0.40 2,730 0.40
off-ramp 6,900

SR 902 south of the Geiger Arterial
2,260 0.87 2,300 0.89 2,280 0.88
Blvd wye connection 2,600

US 2 east of the Sunset Arterial
5,140 0.83 5,230 0.84 5,150 0.83
Frontage Rd intersection 6,200

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Roadway
Type / Alt 1 Alt 1 v/c Alt 2 Alt 2 v/c Alt 3 Alt 3 v/c
Location Capacity Volume Ratio Volume Ratio Volume Ratio

US 195 north of Hatch Rd Freeway
1,670 0.27 1,640 0.27 1,680 0.27
6,200

SR 291 northwest of the Arterial
1,840 0.30 1,830 0.29 1,840 0.30
Wind River Dr intersection 6,200

SR 291 northwest of the
Arterial
Nine Mile Rd wye 2,510 0.40 2,580 0.42 2,500 0.40
6,200
connection

SR 195 northwest of the
Freeway
Cheney–Spokane Rd on- 2,250 0.30 2,200 0.29 2,220 0.29
7,600
ramp
Sources: WSDOT, SRTC, Fehr & Peers, 2025

Finding Common to All Alternatives

No significant impacts to state facilities are identified for any future year alternatives because all
segments evaluated are expected to maintain v/c ratios below the threshold of 1.0 during the PM
peak.

Environmental Justice Implications
None of the alternatives are expected to introduce adverse transportation effects on environmental
justice populations. Programmed safety and access investments such as Vision Zero-related projects
and sidewalk/crossing improvements would proceed with any alternative selected.

Alternative 1: No Action, Stay the Course
The No Action alternative represents the transportation conditions that can be expected if no changes
are made to currently adopted policies. Therefore, this alternative acts as the baseline against which
potential impacts of the Action alternatives are evaluated. This section summarizes analysis results
and identifies potential transportation impacts that are expected under the No Action alternative, as
growth will continue even under currently adopted policies.

VMT per Capita and Mode Share
In Spokane, a total of 4,369,000 miles is traveled on an average weekday in the Existing (2024)
scenario, and that is expected to rise to 5,928,000 miles traveled in the 2046 No Action alternative. As
shown in Exhibit 3.7-16, this translates to VMT per capita rising from 17.9 in Existing to 19.9 by 2046

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with the No Action alternative. This increase reflects existing plans in which population and job growth
would generate more trips, and a greater share of growth would occur in areas that lengthen average
trip distances, for example the West Plains and Hillyard employment areas. Trips between the city and
neighboring jurisdictions would also rise with regional growth in the future.

Exhibit 3.7-16. Existing (2024) and Alternative 1 (No Action) VMT per Capita

Existing (2024) 2046 Alt 1
(No Action)

VMT per Capita 17.9 19.9
Sources: SRTC, Fehr & Peers, 2025

Mode shares (Exhibit 3.7-17) are expected to remain similar to today, with small increases in
walking/biking and stable transit share. Just over half of trips would continue to be made by SOV and
nearly 40 percent of trips would be made by HOV.

Exhibit 3.7-17. Mode Share – No Action Alternative

Mode Existing (2024) 2046 Alt 1
(No Action)

Drive alone (SOV) 50.6% 50.3%

Shared ride (HOV) 39.5% 39.5%

Transit 1.2% 1.2%

Walk 7.3% 7.5%

Bike 1.4% 1.5%
Sources: SRTC, Fehr & Peers, 2025

Compared to 2024, the drive-alone share decreases from 50.6% to 50.3%. The shift translates to an
increase in more active modes. Average weekday walking trips are expected to rise from
approximately 68,000 to 85,500 and biking trips are expected to rise from approximately 13,500 to
16,600.

Finding

Compared to Existing (2024), a significant impact to VMT per capita is anticipated with the No Action
alternative. No significant impact to mode share is expected with the No Action alternative.

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Safety
At the planning scale, safety and exposure to conflicts can be evaluated using total VMT and VMT per
capita for context. These metrics come from the regional model and are used to quantify the miles
traveled. VMT is used as a measure for exposure because an increase in miles driven could result in
more total crashes, even if the rate of crashes per miles driven remains the same.

Under No Action, population and employment growth are expected to increase the number of trips
taken and average trip distances relative to Existing (2024). As a result, total VMT and VMT per capita
are higher than Existing. This increase in VMT and VMT per capita translates into increased exposure
on the transportation network and a corresponding increase in the number of severe and fatal
crashes that could occur relative to Existing, which exceeds the threshold of significance identified for
this EIS.

Finding

Because total VMT and VMT per capita increases relative to Existing (2024), the No Action alternative
would have a significant safety impact at the planning scale due to the increased exposure and
corresponding increase in serious and fatal crashes.

Vehicle Network (Intersections)
Exhibit 3.7-18 tabulates PM peak hour LOS results for the 22 study intersections under the No Action
alternative. LOS values in bold are not expected to meet their applicable LOS standards. The vehicle
network serves all vehicle types including transit and freight, which will be discussed within this
subsection.

Exhibit 3.7-18. Spokane Intersection LOS – Alternative 1 (No Action)
Study Intersection LOS Standard Existing 2046 Alt 1 (No
(2024) LOS Action) LOS
S Hatch Rd and E 57th Ave (One-way stop E E F
control)
S SE Blvd and E 29th Ave E C D
S Grand Blvd and E 29th Ave E C C
N Havana St and E Sprague Ave E D E
N Napa St and E Sprague Ave E C C
SR 290/E Trent Ave and N Hamilton St D E F
US 2/S Division St and E Sprague Ave* F B C
US 2/N Ruby St and E Indiana Ave* D C D
US 2/N Division St and W Buckeye Ave/E North D C C
Foothills Dr
US 2/N Division St and Wellesley Ave D E F
US 2/N Division St and W Francis Ave* D D E
US 2/N Newport Hwy and E Holland Ave D D D
W 3rd Ave and S Monroe St F B B

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Study Intersection LOS Standard Existing 2046 Alt 1 (No
(2024) LOS Action) LOS
N Maple St and W Boone Ave E C C
E Mission Ave and N Hamilton St E D D
N Market St and E Euclid Ave E D D
N T J Meenach Dr and W Northwest Blvd* E D E
N Ash St and W Wellesley Ave E C C
E Wellesley Ave and N Haven St* E C E
N Market St and E Francis Ave E D D
SR 291/W Francis Ave and N Alberta St D D E
US 2/W Sunset Hwy and Flint Rd D C F
Notes: *Analyzed with HCM 2000; BOLD indicates LOS fails to meet standard
Sources: City of Spokane, WSDOT, Fehr & Peers, 2025

Under Alternative 1, 6 of 22 study intersections would fall below their applicable LOS standards. Five of
the six are on WSDOT routes, with two along the US 2/Division corridor (the Wellesley Avenue and
Francis Avenue intersections), one at SR 290/E Trent Avenue and N Hamilton Street in the Center City,
one at SR 291/W Francis Avenue and N Alberta Street in Northwest Spokane, and one at US 2/Sunset
Highway and Flint Road in the West Plains. The remaining below-standard location is S Hatch Road and
E 57th Avenue in South Spokane.

Compared to Existing (2024), 10 intersections are expected to remain at the same LOS, and 12 are
expected to decline by one or more LOS grade. Despite the increase in delay, 16 of 22 intersections are
still expected to meet their LOS standard under No Action.

Finding

Applying the thresholds of significance to the 2046 No Action results, 6 of 22 study intersections
constitute significant impacts because they are expected to operate below their applicable standards.

Transit and Freight
STA transit routes, freight, and trucks use network intersections as part of their regular service, so any
intersection impact identified with the No Action alternative may affect performance of these modes.

The intersection of US 2/Sunset Highway and Flint Road in the West Plains is part of Route 61 (Fairchild
AFB) and Route 7 (Spokane International Airport). US 2/Sunset Highway is a designated T-2 freight
corridor, and Flint Road is designated T-3. The intersection delays associated with LOS F could impact
performance for transit and freight.

On the US 2/Division corridor (the Wellesley Avenue and Francis Avenue intersections), the
intersection LOS of F and E, respectively, could impact STA Route 25 that provides north-south service
along the corridor (STA’s Division Street BRT project will be discussed in Section 3.7.3 Mitigation
Measures). Freight performance could be impacted since US 2/Division is categorized as a T-2 freight
corridor.

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SR 290/E Trent Avenue and N Hamilton Street do not have a fixed transit route that uses the
intersection. However, SR 290 is identified as a T-3 freight corridor, so degraded LOS and delay could
impact freight performance on this route.

S Hatch Road and E 57th Avenue is crossed east–west by Route 144 (commuter route), which currently
travels on the uncontrolled approaches and therefore experiences limited control delay today. The
south and west legs of the intersection are part of a T-3 freight corridor; delay at the stop-controlled
south leg could impact freight performance.

SR 291/W Francis Avenue and N Alberta Street is used by Route 35 (east–west on Francis) and Route 23
(turns; west/south legs). Intersection LOS E fails to meet the standard for the intersection (LOS D) and
the increased delay could affect transit performance. Both SR 291/W Francis Avenue and N Alberta
Street are T-3 freight corridors. The increased delay could affect freight performance.

Finding

For the No Action alternative, the following intersections fail to meet LOS standards and could have an
a significant impact to freight corridors and fixed transit routes: US 2/Sunset Highway and Flint Road
(LOS F), US 2/Division Street and Wellesley Avenue (LOS F), US 2/Division Street and Francis Avenue
(LOS E), and SR 291/W Francis Avenue and N Alberta Street (LOS E).

Alternative 2: Distributed and Balanced
This section summarizes the model results for Alternative 2 and the impacts expected based on the
thresholds of significance stated in Section 3.7.2 Thresholds of Significance.

VMT per Capita and Mode Share
With Alternative 2, total vehicle miles traveled in Spokane are expected to be slightly lower than with
the No Action Alternative. VMT is expected to decrease to 5,732,000 on an average weekday, 3.3%
below the No Action alternative. This translates to a VMT per capita (Exhibit 3.7-19) decreases from
19.9 (No Action) to 19.2 (Alternative 2). This reduction reflects the “distributed & balanced” growth
pattern placing more new housing and jobs in established centers and along frequent transit
corridors, for example the Center City and the Division Street areas, which would shorten average trip
lengths. It also reflects slightly lower job growth than Alternative 1 and Alternative 3, more similar to
the current jobs/housing balance.

Exhibit 3.7-19. Alternative 1 (No Action) and Alternative 2 VMT per Capita

2046 Alt 1 2046 Alt 2
(No Action)

VMT per Capita 19.9 19.2
Sources: SRTC, Fehr & Peers, 2025

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Relative to No Action, Alternative 2 is expected to produce minimal shifts in mode share (Exhibit
3.7-20) with slightly higher walk share and the same transit and bike shares. SOV trips would stay the
same compared to No Action, and HOV trips would decrease slightly.

Exhibit 3.7-20. Mode Share – Alternative 2

Mode 2046 Alt 1 2046 Alt 2
(No Action)

Drive alone (SOV) 50.3% 50.3%

Shared ride (HOV) 39.5% 39.3%

Transit 1.2% 1.2%

Walk 7.5% 7.7%

Bike 1.5% 1.5%
Sources: SRTC, Fehr & Peers, 2025

Compared to No Action, Alternative 2 is expected to have a slight shift from shared-ride vehicular trips
to active modes with approximately 86,400 walking trips and 16,700 biking trips on an average
weekday, about 900 more walk trips and 100 more bike trips than No Action.

Finding

Based on the thresholds of significance used for this EIS, no significant impact to mode share or VMT is
expected under Alternative 2.

Safety
At the planning scale, safety and exposure to conflicts can be evaluated using total VMT and VMT per
capita for context. These metrics come from the regional model and are used to quantify the miles
traveled. VMT is used as a measure for exposure because an increase in miles driven could result in
more total crashes, even if the rate of crashes per miles driven remains the same.

Under Alternative 2, total VMT and VMT per capita are lower than No Action. This reflects the land use
pattern of Alternative 2 that assigns more growth in centers and along transit corridors, which reduces
trips and average trip distances. Compared to No Action, the corresponding reduction in VMT and VMT
per capita translates into reduced exposure on the transportation network and a potential reduction
in the number of severe and fatal crashes.

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Finding

Total VMT and VMT per capita with Alternative 2 is expected to decrease relative to No Action;
therefore, Alternative 2 does not result in a significant safety impact at the planning scale due to the
reduced exposure and corresponding potential reduction in the number of severe and fatal crashes.

Vehicle Network (Intersections)
As shown in Exhibit 3.7-21, 17 of 22 study intersections are expected to meet their applicable LOS
standard with Alternative 2, an improvement over No Action, where 16 of 22 met the standard. The
five intersections that are not expected to meet their LOS standard under Alternative 2 are shown in
bold. The vehicle network serves all vehicle types including transit and freight, which will be discussed
within this subsection.

Exhibit 3.7-21. Spokane Intersection LOS – Alternative 2
Study Intersection LOS Standard 2046 Alt 1 2046 Alt 2 LOS
(No Action)
LOS
S Hatch Rd and E 57th Ave (One-way stop E F F
control)
S SE Blvd and E 29th Ave E D D
S Grand Blvd and E 29th Ave E C C
N Havana St and E Sprague Ave E E D
N Napa St and E Sprague Ave E C C
SR 290/E Trent Ave and N Hamilton St D F E
US 2/S Division St and E Sprague Ave* F C C
US 2/N Ruby St and E Indiana Ave* D D D
US 2/N Division St and W Buckeye Ave/E North D C C
Foothills Dr
US 2/N Division St and Wellesley Ave D F F
US 2/N Division St and W Francis Ave* D E E
US 2/N Newport Hwy and E Holland Ave D D D
W 3rd Ave and S Monroe St F B B
N Maple St and W Boone Ave E C C
E Mission Ave and N Hamilton St E D D
N Market St and E Euclid Ave E D D
N T J Meenach Dr and W Northwest Blvd* E E E
N Ash St and W Wellesley Ave E C C
E Wellesley Ave and N Haven St* E E E
N Market St and E Francis Ave E D D
SR 291/W Francis Ave and N Alberta St D E D
US 2/W Sunset Hwy and Flint Rd D F F

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Notes: *Analyzed with HCM 2000; BOLD indicates LOS fails to meet standard
Sources: City of Spokane, WSDOT, Fehr & Peers, 2025

Compared to No Action, the SR 291/W Francis Avenue and N Alberta Street intersection is expected to
operate with lower delay such that it would meet its LOS D standard (No Action LOS E), and SR 290/E
Trent Avenue and N Hamilton Street would operate at LOS E rather than LOS F (still failing to meet the
standard of LOS D).

Four of the remaining locations that would fail to meet the LOS standard under Alternative 2 are S
Hatch Road and E 57th Avenue, US 2/N Division Street and W Wellesley Avenue, US 2/N Division Street
and W Francis Avenue, and US 2/W Sunset Highway and Flint Road. At US 2/W Sunset Highway and
Flint Road, LOS would remain at F and delay would rise from 145 seconds (No Action) to 148 seconds
(Alternative 2), which is a 3 second increase and therefore below the Action alternative threshold of 5
seconds. At S Hatch Road and E 57th Avenue, US 2/N Division Street and W Wellesley Avenue, and US
2/N Division Street and W Francis Avenue, delay is incrementally reduced relative to No Action and LOS
categories are unchanged.

Finding

Alternative 2 does not introduce new significant intersection impacts relative to No Action with no
additional locations failing to meet LOS standards and with delays increasing by less than 5 seconds.
Therefore, no significant intersection impacts are identified under Alternative 2.

Transit and Freight
Under Alternative 2, no significant intersection impacts are identified relative to the No Action
alternative. The intersection of US 2/Sunset Highway and Flint Road in the West Plains remains at LOS
F and delay increases incrementally by 3 seconds versus the No Action alternative. This increase is
below the Action alternative threshold of 5 seconds. The remaining intersections either maintain or
improve LOS/delay relative to No Action.

Finding

For Alternative 2, no significant intersection impacts are identified compared to the No Action
alternative, so relative transit and freight performance would be maintained.

Alternative 3: Center City and Regional Hubs
This section summarizes the model results for Alternative 3 and the impacts expected based on the
thresholds of significance stated in Section 3.7.2 Thresholds of Significance.

VMT per Capita and Mode Share
With Alternative 3, total vehicle miles traveled in Spokane are expected to be 5,916,000 on an average
weekday, which is slightly below the VMT with No Action and slightly higher than VMT with Alternative

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2. This translates to a VMT per capita (Exhibit 3.7-22) decrease from 19.9 (No Action) to 19.8
(Alternative 3). This slight decrease reflects growth focused in the Center City and select regional hubs,
which brings more trips closer to destinations and frequent transit routes. However, although
Alternative 3 places more housing and jobs in the Center City than Alternative 2, it also assumes
continued employment growth in industrial hubs, most notably the West Plains/Airport area and
Northeast/Hillyard, which increases trips and yields higher total VMT than Alternative 2.

Exhibit 3.7-22. Alternative 1 (No Action) and Alternative 3 VMT per Capita

2046 Alt 1 2046 Alt 3
(No Action)

VMT per Capita 19.9 19.8
Sources: SRTC, Fehr & Peers, 2025

Relative to No Action, Alternative 3 is expected to produce the same modest shifts in mode share
(Exhibit 3.7-23) as Alternative 2: slightly higher walk share and slightly lower HOV share with the other
mode shares remaining the same as No Action.

Exhibit 3.7-23. Mode Share –Alternative 3

Mode 2046 Alt 1 2046 Alt 3
No Action

Drive alone (SOV) 50.3% 50.3%

Shared ride (HOV) 39.5% 39.3%

Transit 1.2% 1.2%

Walk 7.5% 7.7%

Bike 1.5% 1.5%
Sources: SRTC, Fehr & Peers, 2025

Compared to No Action, Alternative 3 is expected to have a slight shift to from shared-ride vehicle trips
to active modes with approximately 88,600 walking trips and 17,000 biking trips per day, which is
about 3,100 more walk trips and 400 more bike trips than No Action.

Finding

Based on the thresholds of significance used for this EIS, no significant impact to mode share or VMT is
expected under Alternative 3.

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Safety
At the planning scale, safety and exposure can be evaluated using total VMT and VMT per capita for
context. These metrics come from the regional model and are used to quantify the miles traveled. VMT
is used as a measure for exposure because an increase in miles driven could result in more total
crashes even if the rate of crashes per miles driven remains the same.

Under Alternative 3, total VMT and VMT per capita are lower than No Action. This reflects the land use
pattern of Alternative 3 that assigns more growth in centers and along transit corridors, which reduces
trips and average trip distances. Compared to No Action, the corresponding reduction in VMT and VMT
per capita translates into reduced exposure on the transportation network and a potential reduction
in the number of severe and fatal crashes.

Finding

Total VMT and VMT per capita with Alternative 3 is expected to decrease relative to No Action;
therefore, Alternative 3 does not result in a significant safety impact at the planning scale due to the
reduced exposure and corresponding potential reduction in the number of severe and fatal crashes.

Vehicle Network (Intersections)
As shown in Exhibit 3.7-24, 17 of 22 study intersections are expected to meet their applicable LOS
standard with Alternative 3, an improvement over No Action. The five intersections that are not
expected to meet their LOS standard under Alternative 3 are shown in bold.

Exhibit 3.7-24. Spokane Intersection LOS – Alternative 3
Study Intersection LOS Standard 2046 Alt 1 2046 Alt 3 LOS
(No Action)
LOS
S Hatch Rd and E 57th Ave (One-way stop E F F
control)
S SE Blvd and E 29th Ave E D D
S Grand Blvd and E 29th Ave E C C
N Havana St and E Sprague Ave E E D
N Napa St and E Sprague Ave E C C
SR 290/E Trent Ave and N Hamilton St D F E
US2/S Division St and E Sprague Ave* F C C
US 2/N Ruby St and E Indiana Ave* D D D
US 2/N Division St and W Buckeye Ave/E North D C C
Foothills Dr
US 2/N Division St and Wellesley Ave D F F
US 2/N Division St and W Francis Ave* D E E
US 2/N Newport Hwy and E Holland Ave D D D

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Study Intersection LOS Standard 2046 Alt 1 2046 Alt 3 LOS
(No Action)
LOS
W 3rd Ave and S Monroe St F B B
N Maple St and W Boone Ave E C C
E Mission Ave and N Hamilton St E D E
N Market St and E Euclid Ave E D D
N T J Meenach Dr and W Northwest Blvd* E E D
N Ash St and W Wellesley Ave E C C
E Wellesley Ave and N Haven St* E E E
N Market St and E Francis Ave E D D
SR 291/W Francis Ave and N Alberta St D E D
US2/W Sunset Hwy and Flint Rd D F F
Notes: *Analyzed with HCM 2000; BOLD indicates LOS fails to meet standard
Sources: City of Spokane, WSDOT, Fehr & Peers, 2025

Compared to No Action, SR 291/W Francis Avenue and N Alberta Street improves to meet LOS
standard, and SR 290/E Trent Avenue and N Hamilton Street improves from LOS F to LOS E (failing to
meet the standard of D).

The remaining locations failing to meet standard under Alternative 3 are S Hatch Road and E 57th
Avenue, US 2/N Division Street and W Wellesley Avenue, US 2/N Division Street and W Francis Avenue,
and US 2/W Sunset Highway and Flint Road. At these intersections, delay is incrementally improved
compared to the No Action alternative.

Finding

Alternative 3 does not introduce significant intersection impacts relative to No Action with no new
locations exceeding LOS thresholds and with delay improving incrementally. Therefore, no significant
intersection impacts are identified under Alternative 3.

Transit and Freight
Under Alternative 3, no significant intersection impacts are identified relative to the No Action
alternative; all intersections that exceed LOS thresholds would either maintain or improve LOS and
delay relative to No Action.

Finding

For Alternative 3, no intersection impacts are identified compared to the No Action alternative, so
relative transit and freight performance would be maintained.

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Summary of Impacts
Exhibit 3.7-25 summarizes impact findings across the alternatives. The purpose of this programmatic
EIS is to disclose how potential land use may affect the transportation system relative to what would
occur with currently adopted designations and policies (the No Action alternative). Accordingly, the
impacts of each Action alternative are assessed against the performance of No Action. Impacts
expected to occur as a result of the No Action alternative are also expected under the Action
alternatives, even if the Action alternatives do not result in additional significant impacts.

Exhibit 3.7-25. Summary of Significant Impacts

Impact Type Alternative 1 — Alternative 2 Alternative 3
No Action

Pedestrian Network None None None

Bicycle Network None None None

Transit Significant Impact No additional impacts No additional impacts
beyond No Action beyond No Action

Safety Significant Impact No additional impacts No additional impacts
beyond No Action beyond No Action

VMT per Capita Significant Impact No additional impacts No additional impacts
beyond No Action beyond No Action

Mode Share None None None

Vehicle Network Significant Impact No additional impacts No additional impacts
(Intersection LOS) beyond No Action beyond No Action

State Facilities None None None

Freight Significant Impact No additional impacts No additional impacts
beyond No Action beyond No Action
Source: Fehr & Peers, 2025

The Action alternatives perform similarly across categories. Relative to No Action, VMT and VMT per
capita decrease under both Action alternatives, so no significant impacts to VMT per capita or safety
are identified for the Action alternatives.

For the vehicle network, measured with intersection LOS, the Action alternatives would not result in
additional impacts beyond the performance expected with the No Action alternative. The same
intersections serve transit and freight, so no additional impacts are identified for these categories.

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No significant impacts to state facilities, the pedestrian network, the bike network, or mode share are
expected with any of the alternatives.

3.7.3 Mitigation Measures
The focus of an EIS is to disclose the potential impacts of the Action alternatives rather than mitigate
conditions under the currently adopted land-use planning (the No Action alternative). For the
alternatives evaluated, the Action alternatives have no impact or no additional impact beyond the No
Action Alternative.

This section identifies programmatic mitigation measures that the City of Spokane can apply to avoid
or minimize transportation impacts across all alternatives. Measures are presented in three sections:
projects and policies already incorporated in the plans; regulatory/committed tools that apply citywide
regardless of alternative; and other potential mitigation measures.

Incorporated Plan Features
Several projects and policies are included in the analysis and serve as baseline mitigation because they
improve traffic operations, safety, and multimodal access for all alternatives.

US 2/Division Street and NSC
US 2/Division Street is a north-south corridor that carries all modes of traffic. STA’s Division Street BRT
project will repurpose one lane in each direction for Business Access and Transit (BAT) lanes; however,
the final project phase is planned to coincide with opening of the North Spokane Corridor (NSC), which
will add new north-south freeway capacity for regional and local connectivity. Construction of the BRT
project in phases is expected to maintain vehicle capacity, with completion of the NSC aiding in the
transition of the Division Corridor towards a transit and local access context. From a freight
perspective, the NSC will aid access between I-90 and the Hillyard industrial area and provide a faster
regional alternative to north-south arterials for freight traveling between Spokane and destinations to
the north. The NSC will help serve growing demand among all alternatives; however it will not resolve
congestion or localized constraints on the local network.

City Line and STA High-Performance Transit (HPT)
The City Line continues to provide frequent east–west service across central Spokane, which is coupled
with improvements that make transit more accessible. STA aims to deliver six HPT corridors as part of
STA Moving Forward, a voter approved initiative to expand regional service. HPT will provide additional
passenger capacity and connectivity both within the City of Spokane and across Spokane County.

Pedestrian and Bike Master Plans
The City’s Pedestrian Master Plan (2015) sets policies and actions to make Spokane more walkable,
including a toolbox to guide sidewalk and crossing upgrades across the city. The Bicycle Master Plan

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(2017) and Bicycle Priority Network (2024) provide a strategy to expand safe bicycling for all residents,
with policies and projects that build a connected, lower-stress system.

Vision Zero and Complete Streets
The City has adopted Vision Zero and formalized it via Council resolution, followed by a 2023 Action
that sets strategies and monitoring for the reduction in serious and fatal crashes. Spokane’s Complete
Streets program requires streets to be safely accessible for all users, and a 2025 ordinance updated
the code and added links to the Pedestrian Master Plan and Bicycle Priority Network.

Areas Not Subject to Infill Exemption (City Core Focus)
The City of Spokane is evaluating adoption of SEPA categorical exemptions for infill housing under
RCW 43.21C.229. The potential exemption area will be identified by walk access to major transit stops
served by frequent and regular STA routes. Core locations where transit can support infill include
Center City, the Division Street Corridor, and the core of Northwest and Northeast Spokane, which
have a higher density of major stops and service frequency.

Outside the core, neighborhoods that are generally farther from frequent and regular service and
therefore not proposed for a potential infill exemption include Grandview/Thorpe, West Hills,
Latah/Hangman, Five Mile Prairie, and North Indian Trail.

Regulations and Commitments
Spokane’s existing regulatory framework ensures that transportation improvements keep pace with
growth and safety needs. Concurrency and impact fees link development to capacity projects. When
thresholds are exceeded, intersection and corridor upgrades are advanced as part of the City’s capital
program. Frontage improvement requirements ensure that adjoining sidewalks, curb ramps,
crossings, and bike elements are implemented to current standards as sites redevelop. The City also
maintains partnerships with WSDOT and STA. With WSDOT, the focus is on coordination between
projects, such as the NSC, and traffic operations. With STA, coordination centers on transit projects,
such as Division Street BRT and future HPT corridors, to ensure accessibility for future ridership
demand.

Spokane’s transportation impact fee program links new development to delivery of transportation
network improvements identified in the City’s capital/impact‑fee project lists. This program remains in
place even if SEPA categorical exemptions for infill housing are adopted. Fees collected at permitting
are restricted to eligible capacity and safety projects, so investments are made where growth occurs.
Because the program is district-based, revenues generated in growth areas including designated infill
areas can be directed to corridor and intersection improvements that support concurrency and
mitigate impacts discussed within this EIS.

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In summary, the SEPA categorical exemptions for infill housing do not remove transportation impact
fees, frontage improvement requirements, design standards, or the City’s coordination with WSDOT
and STA.

Other Potential Mitigation Measures
This section introduces a range of programmatic strategies that could be implemented to reduce the
impact of the growth alternatives evaluated within this EIS.

Transportation Demand Strategies (TDM)
Transportation Demand Strategies (TDM) is one potential measure that is utilized to encourage
carpooling, vanpooling, transit, walking, biking, and telework to reduce single-occupancy vehicle (SOV)
trips and peak demand. Deployed citywide and regionally, these measures help mitigate congestion
and aid state-facility performance, freight mobility, and transit reliability.

Spokane implements TDM through the regional Commute Trip Reduction (CTR) program, branded
Commute Smart Northwest and administered by Spokane County. Consistent with Washington State
law, employers with over 100 employees must implement a CTR program and work toward mode
share goals. The City participates in and helps fund this regional program alongside local agency
partners, while Spokane County’s Commute Smart Northwest provides employer services and tools
across the region. The City has adopted CTR goals through Spokane Municipal Code 15.01 to align with
the regional TDM strategy and advance these goals at the local level.

The City’s CTR Four-Year Plan Update (2025–2029) links mode shift to safety, access, and climate goals.
Spokane targets employers, residents, and students with a mix of education, incentives, and resources
to facilitate mode shift. Available tools include ride matching via CommuteFinderNW.com, employer
and individual incentive programs, and a guaranteed/emergency ride home. These resources are
available not only to large CTR programs but also to smaller employers.

A core feature of TDM is to make other travel options more attractive and less stressful. Through
continued coordination with Spokane Transit Authority, the City is facilitating the implementation of
High-Performance Transit corridors in order to make transit a reliable alternative to driving alone. In
addition, the Pedestrian and Bike Master Plans aid in facilitating connectivity for people who choose to
walk or bike.

Spokane has the framework and service platform to scale TDM strategies. Expanding employer and
development-linked measures, incentives, and access can reduce drive-alone trips and help moderate
impacts identified within this EIS.

TSMO and Signal Timing
Transportation Systems Management & Operations (TSMO) is a programmatic strategy that improves
reliability with intelligent transportation systems (ITS) and operational refinements rather than major
construction. Core tools include periodic signal retiming and coordination, refined phase/split/offset

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plans, protected–permissive turn phasing and right-turn overlaps, leading pedestrian intervals and
updated pedestrian clearance, upgraded detection and, where appropriate, transit signal priority and
queue jumps. Because these measures are relatively low-cost with lower overhead, they can be
iterated as conditions change and paired with capital projects.

For the intersection of SR 290/E Trent Avenue and N Hamilton Street, the South Logan Transit-
Oriented Development (TOD) Plan identifies signal tools such as signal phase adjustments and right-
turn overlaps to maintain operations as the area develops. This EIS is consistent with that approach,
and the same signal timing adjustments can be implemented and adjusted as volumes grow.
Complementary TSMO strategies including wayfinding and driver information to parallel routes like
the adjacent Martin Luther King Jr Way corridor can help redistribute peak traffic and avoid
oversaturation of the intersection. Together, these programmatic measures paired with ongoing
monitoring and retiming can maintain operations as land-use activation occurs.

Agency Partnerships
WSDOT, Spokane Transit Authority (STA), Spokane County, and the Spokane Regional Transportation
Council (SRTC) provide critical transportation facilities, services, data, and funding pathways for the
City of Spokane. The City has a long history of working with these partners to expand multimodal
access to and within Spokane, and continued coordination is essential to evolve the regional network.

For transit service, mitigating delay and improving speed and reliability will require close coordination
with STA. For Division Street BRT, the City and STA will continue to work towards phasing and
implementation for the transit corridor. The City will also coordinate with STA to enhance first and last-
mile access improvements along transit routes.

Partnering with the County and other regional agencies on a unified TDM program leverages
resources to provide a robust program with opportunities for targeted programs within the City.

On state facilities, Spokane will continue to partner with WSDOT to coordinate on critical regional
corridors including I-90, US 2, US 195, SR 290, SR 291, and related ramp terminals and bridges.

3.7.4 Significant Unavoidable Adverse Impacts
Relative to No Action, the Action alternatives maintain or incrementally improve mode share and have
lower VMT per capita, which translates into slight improvements or no change in transit, freight, and
safety performance. The Action alternatives would not cause any additional intersections to fall below
standards, and for intersections that already fall below the LOS standard under No Action, the Action
alternatives would add less than 5 seconds of average control delay relative to No Action. In addition,
the Action alternatives would maintain all evaluated state facilities below a v/c ratio of 1.0 and would
not degrade pedestrian or bicycle operations at the citywide scale.

Therefore, applying the thresholds in Section 3.7.2, neither Action alternative is expected to result in a
significant adverse transportation impact.

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3.8 Public Services
This section describes current conditions for public services and analyzes changes in demand based
on each alternative’s level and location of growth. Public services analyzed in this section include
police, fire and emergency medical services (EMS), schools, parks, libraries, and solid waste. An
impacts analysis for environmental justice, as it relates to parks and emergency services access, is also
included.

Thresholds of significance utilized in this impact analysis include:
 Police/Fire/EMS – Increased demand for police or fire and emergency that cannot be
accommodated through regular planning and staffing processes.
 Schools – Increased public school enrollment and demand on capital facilities, and broadband that
cannot be addressed through regular school planning processes.
 Parks – Decreased park level of service (LOS), as defined in the Spokane Parks Master Plan (acres
of developed park land per 1,000 people, and percent of households that can reach a public park
or school ground in 10-minute walk)
 Libraries – Recommended square feet per capita LOS not met, as defined in the City of Spokane
Capital Facilities Plan
 Solid Waste – Collections per household per month that would result in major investments
exceeding what is already planned.
 Environmental Justice
 Growth in areas with existing health disparities would result in increased demand on
emergency medical services and impact response times.
 Growth in areas with high social vulnerability would result in greater pressure on existing
parks and recreation services.

3.8.1 Affected Environment

Police
The Spokane Police Department (SPD) has 333 commissioned police officers and 91 full-time civilian
staff members (City of Spokane, 2025). The City is authorized for 354 commissioned positions.
Volunteers also provide support and completed more than 27,000 volunteer hours in 2023 (City of
Spokane, 2025). SPD has several specialized teams, including a Violent Crimes Task Force, Special
Investigative Unit, Stolen Property Enforcement and Recovery Unit, and SWAT (Spokane Police
Department, 2024). There are four precincts and a police headquarters, as well as other administrative
and support buildings (Exhibit 3.8-2).

Spokane currently employs 1.4 officers per 1,000 population (Exhibit 3.8-1). Staffing has been cited as
a “critical issue” for the Spokane Police Department (City of Spokane, 2025). As of early 2024, the
department had only two vacancies to fill after hiring 34 officers in 2023 (Spokane Police Department,

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2024). However, SPD has emphasized that the department is still approximately 200 officers short of
the national average officers per thousand and demand for police services exceeds capacity. Calls for
service increased 14% from 2022 to 2023, with an average of 295 calls with police response each day.
SPD also emphasizes proactive policing and aims to increase it by 10% between 2025 and 2027.

Exhibit 3.8-1. Police Officers per 1,000 Population

Police Officers (2025) Population (2025) Officers per 1,000
population

333 234,700 1.4

Source: (City of Spokane, 2025), (BERK, 2025), (Washington Office of Financial Management, 2025)

SPD has a goal of answering 95% of calls within 15 seconds after being transferred from Spokane
Regional Emergency Communications (SREC). This exceeds the national standard of answering 90% of
calls within 15 seconds (City of Spokane, 2025). In 2023, SPD answered 97% of calls within 10 seconds
and 99.8% of calls within 20 seconds (Spokane Police Department, 2024).

The City is moving to establish a new Emergency Communications Center in 2026 that will handle both
fire and police calls.

The violent crime rate in Spokane is 7.0 per 1,000 residents and the property crime rate is 55.9 per
1,000 residents (Spokane Trends, 2023). Both rates have decreased over the past five years.

Key priorities for SPD through 2026 include:
 Implementing a comprehensive strategy to reduce violent gun crime.
 Deploying holistic, all-city strategies to address quality of life issues, including homelessness and
drug use.
 Exploring community-centered policing strategies to build public trust.
 Increasing employee wellness strategies and programmatic opportunities.
 Increasing employee recruitment and retention.
 Deploying evidence-based practices to achieve organizational excellence. (City of Spokane, 2025)

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Exhibit 3.8-2. Spokane Police Stations

Source: (City of Spokane, 2025; BERK, 2025)

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Northwest Spokane
The Detective’s Building and the Northwest Police Precinct are located in Northwest Spokane.

Northeast Spokane
The Northeast Police Precinct is located in Northeast Spokane.

Division Corridor
None of the Police Department buildings are located in the Division Corridor. Other buildings are
nearby in Center City, Northwest Spokane, and Northeast Spokane.

Center City
Police Headquarters and the Downtown Police Precinct are located in Center City.

South Spokane
The South Police Precinct is located in South Spokane.

West Plains
None of SPD’s facilities are located in West Plains.

Fire/EMS
Spokane is served by the Spokane Fire Department (SFD), which provides fire response services and
EMS. The Department has 376 budgeted full-time fire and EMS staff, including 350 uniform staff and
25.63 civilian staff. This equals approximately 1.5 uniform staff per 1,000 Spokane residents. SFD hired
approximately 39 new firefighters in 2023 and four in 2024 (Spokane Fire Department, 2024; Spokane
Fire Department, 2023). There is one Fire Chief, one Assistant Fire Chief, three Deputy Chiefs, and
three Staff Battalion Chiefs. SFD operates 16 fire stations throughout the city (Exhibit 3.8-3 and
Exhibit 3.8-4) organized into a North and a South Battalion.

In addition to fire and EMS, the Department has several specialty teams. This includes hazardous
materials response, water rescue, and a rescue task force for high-threat scenarios. SFD also provides
prevention education and training (Spokane Fire Department, 2025). A Logistics Division and an
Information Technology team support the Department’s functions, and a Wildland Resource Planner
works on Wildland Fuels Reduction and prevention.

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Exhibit 3.8-3. Fire Stations and Areas Served

Station Areas Served Percent of 2024 Responses

Station 1 Downtown, East Central, Rockwood 18%
Station 2 Logan, Gonzaga University 7%
Station 3 Emerson/Garfield, West Central 10%
Station 4 Browne’s Addition, Downtown 9%
Spokane, Sunset Hill, lower South
Hill, Peaceful Valley, Grandview
Station 5 Latah Valley, Hangman 1%
Station 6 West Plains, Spokane International 1%
Airport
Station 7 East Central 5%
Station 8 East Central 4%
Station 9 Manito, Comstock 2%
Station 11 Lincoln Heights 6%
Station 13 Shadle, Five Mile Prairie, Northtown, 7%
Garland
Station 14 Lincoln Heights, East Central, 4%
Southgate
Station 15 Hillyard, Bemiss 8%
Station 16 Audubon/Downriver, Northwest 4%
Station 17 Indian Trail 2%
Station 18 Shiloh Hills 12%

Source: (Spokane Fire Department, 2025; Spokane Fire Department, 2024)

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Exhibit 3.8-4. Spokane Fire Department Stations

Source: (Spokane Fire Department, 2025)

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In 2024, SFD had a total of 54,279 responses, of which 88% were EMS and rescue incidents, 2% were
fire incidents, and 10% were other service calls for assistance. The Department’s Insurance Rating is
currently a Class 3, after being downgraded in 2000 due to reductions in fire stations, staffed
apparatus, and on-duty personnel (Spokane Fire Department, 2024). SFD currently has a goal to
achieve a Class 2 rating.

As described above in Police, fire and police calls will move from SREC to a new City Emergency
Communications Center in 2026.

The Department has the following objectives for response times (Spokane Fire Department, 2024):
 Turnout Time: 90 seconds, 90% of the time. In 2024, average turnout time was two minutes and
25 seconds.
 Response Time (First Arriving Apparatus): 8 minutes and 30 seconds, 90% of the time. In
2024, average response time was five minutes and 29 seconds.
 Structure Fire Response Time: 11 minutes, 90% of the time. The Department met this standard
for 97% of structure fires in 2024.
 Structure Fire Travel Time: First unit to arrive within 7 minutes, 90% of the time. In 2024,
average travel time was two minutes and 25 seconds.

Northwest Spokane
Northwest Spokane is served by the North Battalion and includes Stations 3, 13, 16, and 17.

Northeast Spokane
Northeast Spokane is served primarily by the North Battalion, with some overlap with the South
Battalion, and includes Stations 2, 7, 8, 15, and 18.

Division Corridor
The Division Corridor is served primarily by the North Battalion, with some overlap with the South
Battalion, and overlaps with Stations 1 and 18.

Center City
Center City is served by both the North and South Battalions and includes Station 1.

South Spokane
South Spokane is served by the South Battalion and includes Stations 4, 5, 7, 9, 11, and 14.

West Plains
West Plains is served by the South Battalion and includes Station 6.

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Schools
School districts serving Spokane include Spokane Public Schools, Mead School District, and Cheney
Public Schools (Exhibit 3.8-5).

Spokane Public Schools (SPS) is the main public school provider in Spokane. There are 34 elementary
schools, nine middle schools, five high schools, and multiple option schools in the district (Spokane
Public Schools, 2025).

The school district serves almost 30,000 students, including 12,000 elementary school students, 6,000
middle school students, 8,000 high school students, 3,000 students in special schools, and 800
students attending virtual classes. 60% of SPS students are in households with low incomes
(Washington OSPI, 2024). Only 68% of students attended 90% or more of the school days in the 2023-
2024 school year. For comparison, this is lower than Seattle Public Schools, where 77% of students
attended 90% or more days. The average class size is 19.1 students. RCW 28A.150.100 requires 46
instructional staff per 1,000 students, or a ratio of approximately one teacher per 21.7 students
(Revised Code of Washington, 2022). The City’s Capital Facilities Plan specifies a level of service
standard of one teacher per 19 students (City of Spokane, 2017). SPS buildings total approximately
5,300,000 square feet.

Prior capacity issues observed in 2015 capital planning have been addressed in part by additional
middle school space added through a 2018 bond measure. Based on births within the school district,
SPS projects that in 5 years it will serve approximately 600 fewer students overall than in the 2024-
2025 school year, with decreases in the number of elementary and middle school students and a slight
increase in high school students.

Major future projects, pending voter approval of a 2025 bond, include rebuilding of Adams and
Madison elementary schools, modernizing parts of North Central High School and Garry Middle
School, and establishing a new Trades High School (Spokane Public Schools, 2025). Other
improvements are also planned for various schools throughout the district. SPS also partners with City
of Spokane Parks and Recreation through the Together Spokane Initiative, which relies on both the
SPS bond and the 2025 Parks levy passing. The 2018 bond program included a total of $553 million for
school projects, including the replacement of three middle schools.

Mead School District and Cheney Public Schools serve small portions of the city, with Mead School
District covering some northern areas and Cheney Public Schools covering a small area around Eagle
Ridge. Mead School District has a total of 17 schools serving 10,800 students and an average student
to teacher ratio of 17.89. Cheney Public Schools has a total of 12 schools serving 5,700 students and
an average student to teacher ratio of 16.7.

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Exhibit 3.8-5. Schools and Districts in Spokane

Source: (City of Spokane, 2025; BERK, 2025)

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To understand student growth in relation to population growth, the current ratio of students to
housing units is shown in Exhibit 3.8-6. SPS and Cheney Public Schools have a similar average number
of students per housing units, while Mead School District has a higher ratio.

Exhibit 3.8-6. Ratio of Students to Housing Units

School District Students (2024-2025) Housing Units (2024) Students per Housing
Unit

Spokane School District 29,690 108,297 0.27
Mead School District 10,761 23,742 0.45
Cheney Public Schools 5,702 18,738 0.30

Source: (Washington OFM, 2024; Washington OSPI, 2024)

Northwest Spokane
SPS facilities in Northwest Spokane include three high schools, two middle schools, and 11 elementary
schools. Mead School District serves a small portion of Northwest Spokane though no schools are
located within the boundaries.

Northeast Spokane
SPS facilities in Northeast Spokane include three high schools, three middle schools, and 12
elementary schools. Mead School District also serves a small area on the north end and has one
elementary school within the boundaries.

Division Corridor
SPS schools in the Division Corridor include two elementary schools.

Center City
SPS schools in Center City include one high school (Lewis and Clark High School).

South Spokane
South Spokane includes one SPS high school, three middle schools, and 10 elementary schools. A
small portion at the south end is served by Cheney School District though no schools are located
within the boundaries.

West Plains
Cheney School District serves West Plains, though no schools are located within the boundaries.

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Parks
The City of Spokane has approximately 130 miles of trails and 3,800 acres of parks, including 1,600
acres of natural lands (City of Spokane, 2022). Within the City’s more than 87 parks, the City provides a
range of facilities, including playgrounds, sports fields, sports courts, community gardens, formal
gardens, dog parks, splash pads, and pools, and unprogrammed field areas. The City of Spokane also
owns and manages three sports complexes, four public golf courses, six aquatic centers, and an
arboretum. Natural lands provide opportunities for passive recreation and plant and animal habitat.
Trails serve as corridors for pedestrian and bicycle use for both commuting and recreation. Exhibit
3.8-7 shows the locations of City parks and amenities.

Other recreation providers in Spokane include Washington State Parks, the school district, and the
YMCA, as well as private recreation providers.

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Exhibit 3.8-7. Spokane Parks and Amenities

Source: (City of Spokane, 2022)

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Exhibit 3.8-8. Parks Acreage

Classification Acreage

Special Use Park 248
Community Park 297
Natural Lands 1,643
Golf Course 690
Regional Park 474
Neighborhood Park 274
Pocket Park 14
Parkway 196

Total 3,863

Source: (City of Spokane, 2022)

Exhibit 3.8-9. Trails Acreage

Classification Mileage

Natural Trail (Single Track) 108
Paved Trail (Wider Track) 14
Sidewalk 8

Total 130

Source: (City of Spokane, 2022)

The Parks Department also provides recreational programming, including adult, youth, aquatic,
community, arts, and outdoor programs. There are also Therapeutic Recreation Services programs to
ensure residents with disabilities can participate.

Spokane currently provides 16.2 acres of park land per 1,000 people, including 5.8 acres of developed
park land per 1,000 people (Exhibit 3.8-10). The neighborhoods of Shiloh Hills, Lincoln Heights,
Southgate, Latah/Hangman, North Indian Trail, Five Mile Prairie, and Northwest were identified as
areas with low access to parks within a 10-minute walkshed in the 2022 Spokane Parks and Natural
Lands Master Plan.

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Exhibit 3.8-10. Park Acres per 1,000
Park Classification Number of Publicly Acres/1,000
Properties Accessible population in
Property Acres 2020 (223,600)
Regional Park 3 474 2.1
Special Use Park 6 248 1.11
Golf Course 4 690 3.09
Community Park 12 297 1.33
Neighborhood Park 32 274 1.23
Pocket Park 13 14 0.06
Parkway 18 196 0.88
Natural Lands 17 1,643 7.25
Total 105 3,836 17.2
Total Excluding Golf Courses, 82 1,307 5.8
Parkways, and Natural Lands
Source: (City of Spokane, 2022)

The 2022 Spokane Parks and Natural Lands Master Plan also found a need for more investment in a
higher number of smaller projects and increased maintenance throughout the City rather than a large,
singular project. Opportunities for improvement identified in the plan include:
 Land
 Serving under-resourced areas of the city.
 Reflecting the assets of the Inland Northwest.
 Preserving natural areas.
 Water
 Expanding aquatic facilities.
 Activating the Spokane River.
 Improving water use efficiency.
 People
 Improving existing parks.
 Building awareness of programs and facilities.
 Improving the diversity of offerings.
 Addressing conflicts between park users.
 Legacy
 Maintaining and caring for the system.
 Acquiring new funding sources and leveraging current assets.
 Strategic acquisitions, partnerships, and real estate management.

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Exhibit 3.8-11. Gaps in Park Access

Source: (City of Spokane, 2022)

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Northwest Spokane

Northwest Spokane includes a variety of parks, including several properties along the Spokane River
and the Downriver Golf Course. Riverside State Park also overlaps with Northwest Spokane. The 2022
Spokane Parks and Natural Lands Master Plan identified several gap areas for parks within a 10-
minute walk on the northern end of Northwest Spokane, including North Indian Trail, Northwest, Five
Mile Prairie, and Balboa/South Indian Trail.

Northeast Spokane
Parks in Northeast Spokane include various smaller properties, including Mission Park and Upriver
Drive Parkway along the Spokane River, as well as the Esmeralda Golf Course and the Hillyard Senior
Center. Park gap areas include parts of the Shiloh Hills, Hillyard, Bemiss, and East Central
neighborhoods.

Division Corridor
Parks in the Division Corridor include Franklin Park and B A Clark Park. There are two park gap areas in
the Division Corridor, including in Shiloh Hills and in East Central.

Center City
The major park in Center City is Riverfront Park, which includes properties on both sides of the
Spokane River in Downtown. Park gap areas in Center City include several pockets in East Central.

South Spokane
A variety of parks are located in South Spokane, with the largest being the conservation properties on
Latah Creek, High Bridge Park, and the Creek at Qualchan Golf Course. There are many park gap areas
in South Spokane, including parts of the East Central, Lincoln Heights, Rockwood, Comstock,
Southgate, Latah, Grandview/Thorpe, and Browne’s Addition neighborhoods.

West Plains
Parks in West Plains are concentrated on the east side, as the Spokane International Airport covers
much of the area to the west. Parks include Whittier Park, Finch Arboretum, and Indian Canyon Golf
Course. There is a park gap area in West Plains on the eastern side as the golf course is not considered
a park for this analysis.

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Libraries
Spokane Public Library is the library service provider in Spokane. There are seven library locations with
millions of items in total, including books, movies, and music (Exhibit 3.8-12). There are also four
library kiosks throughout the city where residents can check out and return items and pick up holds
(Spokane Public Library, 2025). The library also provides events, printing, computer use, and meeting
rooms (Spokane Public Library, 2025). In 2024, Spokane libraries had more than 1.2 million visitors
(Spokane Public Library, 2024).

Substantial improvements to the library system have been completed recently, supported by a $77
million bond approved in 2018. Four new libraries opened in 2021, one opened in 2022, and two more
opened by the end of 2023. According to the City’s Capital Facilities Plan, the average life span of a
library facilities is 20 to 30 years (City of Spokane, 2017). Voters also approved a levy in 2024, which is
expected to raise $2.5 million in 2025, $2.52 million in 2026, and $2.55 million in 2027 ((The
Spokesman Review, 2024).

Other libraries in the vicinity of Spokane include those managed by Spokane County Library District.

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Exhibit 3.8-12. Libraries in Spokane

Source: (City of Spokane, 2025; BERK, 2025)

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The library system, after the 2018 bond projects, now includes a total of 211,750 square feet. See
Exhibit 3.8-13. With the estimated 2025 population of 234,700, this equals 0.9 square feet per
resident. The recommended level of service is 0.813 square feet of library facilities per capita (City of
Spokane, 2017). Other recommended levels of service include $50 of operating budget per capita,
$7.50 of materials budget per capita, 15% of the operating budget for materials, 10.5 circulation per
capita, and 60 unduplicated hours of operation per week.

The Capital Facilities Plan also specifies that, “if future development and population growth were to
continue away from the city center and major corridors, the library would feel it necessary to build
new facilities to serve these areas” (City of Spokane, 2017).

The 2025-2030 Capital Improvement Program has several projects planned related to library planning,
all focused on improvements to information technology, such as fiber network upgrades and
computing hardware (City of Spokane, 2025).

Exhibit 3.8-13. Libraries Square Footage

Library Square Footage

Shadle Library 30,000
Central Library 117,000
Hillyard Library 12,725
Liberty Park Library 12,725
The Hive 13,700
Indian Trail Library 10,600
South Hill Library 15,000

Total 211,750

Sources: (Spokane Public Library, 2022) (Urban Land Institute, 2025) (MW Engineers, 2025) (MW Engineers, 2025)

Spokane Public Library’s mission is to “inspire a thriving city through cultural and educational
opportunities” (Spokane Public Library, 2025).

Strategic directions for the library include:
 Educate Our Citizens
 Become a Platform
 Be the Community’s Partner

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Northwest Spokane
Library locations in Northwest Spokane include Indian Trail Library and Shadle Park Library, as well as
two kiosk locations in West Central and Five Mile.

Northeast Spokane
Northeast Spokane is served by Hillyard Library, The Hive, and Liberty Park Library. Spokane
Community College Library, operated by the college, is also located in Northeast Spokane. Thrive
International, a non-profit organization, is currently developing a new Spokane Public Library event
and learning space and library kiosk as part of a mixed-income housing project.

Division Corridor
There are no libraries located specifically in the Division Corridor.

Center City
The Central Library serves Center City and is also a regional draw for its regular programming and
events.

South Spokane
South Spokane is served by the South Hill Library and a library kiosk in Latah/Hangman. There is also a
County library immediately to the south of the Southgate neighborhood.

West Plains
There are no library locations in West Plains.

Solid Waste
The City provides solid waste services, including residential and commercial services. This includes
garbage, recycling, and an optional food and yard-waste collection (City of Spokane, 2025). Garbage
and food and yard-waste is collected weekly, while recycling is collected every other week.

City activities include:
 Collecting solid waste.
 Operating the Valley Transfer Station, Colbert Transfer Station, and Northside Landfill.
 Collecting recyclables and yard waste.
 Administering contracts for processing of recyclables.
 Operating a moderate risk waste collection station at the Waste to Energy (WTE) Plant.
 Operating transfer activities between facilities.

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 Administering permits for medical waste haulers.
 Completing illegal dumpling inspections and cleanup.
 Coordinating with the Spokane Regional Health District and City departments on facility
inspections and enforcement.

Waste Management and Barr-Tech currently provide contracted recycling and compost processing.

The Waste to Energy Facility burns municipal solid waste to recover electricity. It handles 800 tons of
solid waste per day, including waste from other parts of the county, and generates approximately 22
megawatts of electricity, which is enough to power 13,000 homes and earn up to $5 million in power
sales each year (City of Spokane, 2025). The facility opened in 1991 to reduce amount of material sent
to landfill and better protect the region’s sole source aquifer. The operational life of the facility is
expected to continue for the long-term, with maintenance costs of about $4 million per year (Spokane
County, 2022).

The City participates in the County’s solid waste planning process, which is formalized in the
Comprehensive Solid Waste and Moderate Risk Waste Management Plan (Spokane County, 2022). The
plan identifies a potential need for a future transfer station by 2039 in the main center part of
Spokane or on the west side of the County. The 20-year capital improvements plan, however, does not
include a new facility and emphasizes repairs and improvements to existing facilities. Solid waste
capacity is shown in Exhibit 3.8-14. Recycling and composting facilities have adequate capacity for
projected growth trends according to the County plan.

The City’s level of service standard for solid waste and recycling is 4.33 collections per household per
month (City of Spokane, 2017). The County’s level of service is 800 pounds of solid waste per capita per
year. The City is projected to collect 168,386 tons of solid waste from 70,164 customers in the year
2027. Spokane currently employs approximately 120 staff in its Solid Waste Department (City of
Spokane, 2023)

Exhibit 3.8-14. Waste Facility Capacity

Facility Capacity

Waste to Energy Facility 292,000 tons per year
Northside Landfill 1.5 million cubic yards total

Source: (Spokane County, 2022)

Northwest Spokane
The Northside landfill is located in Northwest Spokane. Waste from this area, and the rest of the city, is
sent to the Waste to Energy Facility and recycling and compost processing facilities.

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Northeast Spokane
There are no solid waste facilities located in Northeast Spokane. Waste from this area, and the rest of
the city, is sent to the Waste to Energy Facility and recycling and compost processing facilities.

Division Corridor
There are no solid waste facilities located in the Division Corridor. Waste from this area, and the rest of
the city, is sent to the Waste to Energy Facility and recycling and compost processing facilities.

Center City
There are no solid waste facilities located in Center City. Waste from this area, and the rest of the city,
is sent to the Waste to Energy Facility and recycling and compost processing facilities.

South Spokane
The Southside Landfill is located south of South Spokane, in unincorporated Spokane County. Waste
from this area, and the rest of the city, is sent to the Waste to Energy Facility and recycling and
compost processing facilities.

West Plains
The Waste to Energy Plan is located in West Plains, near the Spokane International Airport. Waste from
this area, and the rest of the city, is sent to the Waste to Energy Facility and recycling and compost
processing facilities.

Environmental Justice Implications
Some areas of Spokane have higher rates of self-reported “poor” physical health in general (when
provided the options of excellent, very good, good, fair, or poor) and higher rates of social
vulnerability than other areas. Data from the Centers for Disease Control and Prevention (CDC)
analyze rates of health conditions, including self-reported poor physical health, and social vulnerability
of a community (Centers for Disease Control, 2025; Centers for Disease Control, 2022). Areas with
more health concerns may have higher demand for EMS and areas of higher social vulnerability may
have greater need for services that support wellbeing and resilience, like parks.

Exhibit 3.8-15 shows areas of the city with the highest rates of poor physical health and Exhibit 3.8-16
shows areas of the city with the highest social vulnerability scores.

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Exhibit 3.8-15. Poor Physical Health

Source: (Centers for Disease Control, 2025) (BERK, 2025)

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Exhibit 3.8-16. Social Vulnerability Index

Source: (Centers for Disease Control, 2022)

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Northwest Spokane
Northwest Spokane has some Census block groups with a high population with self-reported poor
physical health. This includes areas around North Monroe Street and West Wellesley Avenue. Most of
Northwest Spokane is not considered highly socially vulnerable, except for the Census tracts on the
edge of Center City.

Northeast Spokane
Much of Northeast Spokane has a high percentage of residents with self-reported poor physical
health, with the highest percentages around North Market Street and south of the Spokane River.
Northeast Spokane also has several Census tracts that are considered high social vulnerability areas,
including along North Market Street, North Nevada Street, East Lincoln Road, and south of the
Spokane River.

Division Corridor
Much of the Division Corridor has a high percentage of residents with self-reported poor physical
health, with the highest percentages around Center City. Areas of high social vulnerability are primarily
to the north and south ends of the corridor.

Center City
Much of Center City has high percentages of residents with self-reported poor physical health. Social
vulnerability is also generally high in this area.

South Spokane
While most of South Spokane does not have high rates of self-reported poor physical health, one area
on the west side, following SR 195, does have high rates. There is one Census tract with high social
vulnerability, along South Thor Street and South Roy Street towards I 90.

West Plains
West Plains does not have high rates of self-reported poor physical health or high social vulnerability.

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3.8.2 Impacts

Impacts Common to All Alternatives

Environmental Impacts

Police

While the three alternatives vary in the location of future growth, all alternatives plan for between
25,157 and 50,650 new residents. The total number of jobs varies by alternative, with Alternative 3
planning for the highest number (38,848), Alternative 1 planning for the second highest (34,850), and
Alternative 2 planning for the lowest (24,939).

To maintain the current ratio of 1.4 officers per 1,000 residents, SPD would need to hire between 36
and 72 new officers by 2046. This would equal between 3 and 6 new police officer positions per year
over the 20-year period. Alternatives 1 and 3 may have additional impacts due to the higher number of
jobs. Impacts from growth can be addressed through regular planning, staffing, and budgeting
processes. For comparison, SPD hired 34 officers in 2023 alone, though this number also accounts for
regular staff attrition. Additional evaluation may be needed to consider whether the current ratio of
officers per 1,000 residents is adequate, based on SPD’s reported capacity issues that persist even
when all positions are filled.

Fire/EMS

All alternatives are expected to have similar impacts to fire and EMS services at the citywide scale
because they all plan for the same amount of housing growth. To maintain the current ratio of 1.5
uniform staff per 1,000 residents, SFD would need to hire between 38 and 76 staff per year.
Alternatives 1 and 3 may have additional impacts due to the higher number of jobs. Impacts from
growth can be addressed through regular planning, staffing, and budgeting processes. For reference,
43 new firefighters were hired in 2023 and 2024, though this number also accounts for regular staff
attrition.

Schools

Each alternative is expected to have varying impacts to each school district due to differences in
growth distribution (Exhibit 3.8-17). Under Alternatives 2 and 3, Spokane School District is expected to
add 488-505 more new students than under Alternative 1. In contrast, Alternative 1 would place more
growth in the Mead School District, resulting in 549-600 more students than Alternatives 2 and 3.

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Exhibit 3.8-17. Student Growth by School District

Alternative 1 Alternative 2 Alternative 3

District Housing Student Housing Student Housing Student
Growth Growth Growth Growth Growth Growth

Spokane School
District 19,074 5,229 20,914 5,734 20,852 5,717
Mead School
District 1,406 637 79 36 193 88
Cheney School
District 1,176 358 637 194 621 189

Source: (BERK, 2025).

Parks

All alternatives include the same overall population growth and are expected to have similar impacts
to the park system on a citywide scale. The City will need to add new park acreage under all
alternatives to maintain the levels of service described in the 2022 Parks and Natural Lands Master
Plan. This includes 53-106 acres of regional parks, 33-67 acres of community parks, 31-62 acres of
neighborhood parks, and 182-367 acres of natural lands (Exhibit 3.8-18).

Exhibit 3.8-18. Park Acreage Needs

Park Publicly Acres/1,000 New Acres New Acres
Classification Accessible Population in Needed (Low Needed (High
Property Acres 2020 (223,600) Growth) – All Growth) – All
Alternatives Alternatives

Regional Park 474 2.1 53 106
Community Park 297 1.33 33 67
Neighborhood 274 1.23 31 62
Park
Natural Lands 1,643 7.25 182 367

Source: (BERK, 2025)

Impacts on park gap areas vary by alternative and are addressed in the Area Specific Evaluation
below.

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Libraries

All alternatives plan for the same amount of growth and therefore are expected to have similar
impacts on the citywide library system. See Exhibit 3.8-19. The current ratio of library square footage
to population is 0.9, which exceeds the adopted level of service of 0.813 square feet for capita. Without
additional square footage added to the system, the level of service in 2046 is expected to be 0.83
under a lower growth projection and 0.74 under a higher growth projection. Therefore, under lower
growth, Spokane Public Library would exceed the adopted level of service without adding new square
footage. However, under a high growth projection, the level of service would decline below the target.
To maintain the target level of service, 20,240 square feet of library space would be needed by 2046.
The event and learning space currently under development by Thrive International, as part of a mixed-
income housing project, will add approximately 1,500 square feet.

Exhibit 3.8-19. Library Levels of Service

Low Growth Level of Service – High Growth Level of Service
All Alternatives – All Alternatives

Level of service 0.83 0.74
Total square footage needed 208,174 231,989
(0.813 s.f. per capita)
Additional square footage 0 20,240*
needed (in addition to existing
211,750 s.f.*)

* Does not include Thrive International partnership space that is currently in development.
Source: (BERK, 2025)

Solid Waste

All alternatives plan for the same amount of housing unit and population growth. However,
Alternatives 1 and 3 plan for greater job growth, which would result in a greater amount of
commercial waste. Under the planned housing unit growth, to maintain the current ratio of staff to
waste collections per month, the City would need to add 25 additional staff positions to meet
residential waste increases. This equals an average of 1-2 positions per year. A total of 102,000-
114,000 tons of solid waste from Spokane residents and businesses would be expected per year
starting in 2046, using the County’s estimate of 800 pounds per capita per year.

Environmental Justice Implications

All alternatives plan for growth in areas with existing social disparities. This may have impacts to public
services by creating more demand for emergency services and parks in certain areas of Spokane. All
three alternatives place between 31 and 34% of growth in areas with a high percentage of self-
reported poor physical health, which may increase demand for emergency services where there is

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already higher demand. See Exhibit 3.8-20. All alternatives also place between 23 and 27% of growth
in areas with high social vulnerability. Greater growth in these areas may put more pressure on
services like parks. Specific areas of growth are discussed below in Area Specific Evaluation.

Exhibit 3.8-20. Social Disparities and Housing Growth

Alternative 1 Alternative 2 Alternative 3

Existing Housing Percent of Housing Percent of Housing Percent of
Conditions Growth Growth Growth Growth Growth Growth

High
percentage of
6,700 31% 7,100 33% 7,500 34%
poor physical
health
High social
5,000 23% 5,500 25% 6,000 27%
vulnerability

Source: (BERK, 2025) (Centers for Disease Control, 2022) (Centers for Disease Control, 2025)

Area Specific Evaluation

Northwest Spokane

All alternatives plan for some housing growth in Northwest Spokane, particularly near Center City and
the Division Corridor as well as in the North Indian Trail neighborhood. Job growth is also generally
near Center City as well as pockets of growth in the Northwest and North Indian Trail neighborhoods.
These neighborhoods are therefore likely to see some increased demand for police, fire/EMS, solid
waste, schools, parks, and libraries in all alternatives. Housing growth is also expected in park gap
areas in all alternatives, including North Indian Trail, Balboa/South Indian Trail, and Northwest. In
Alternative 1, this also includes Five Mile Prairie. Need and demand for new parks in these gap areas
will therefore increase.

Across the alternatives, Northwest Spokane has minimal growth overlapping with areas of high rates
of self-reported poor physical health and high rates of social vulnerability. Minimal environmental
justice impacts are expected in relation to public services.

Northeast Spokane

Housing growth in Northeast Spokane across the alternatives is generally clustered around Center City
and in parts of the Hillyard neighborhood, as well as along the Division Corridor especially in
Alternatives 2 and 3. Job growth is generally near downtown, along the Division Corridor, and along
East Francis Avenue, as well as in the Hillyard neighborhood. These neighborhoods are therefore likely
to see some increased demand for police, fire/EMS, solid waste, schools, parks, and libraries in all

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alternatives. Housing growth is also expected in park gap areas in all alternatives, including Shiloh
Hills, Hillyard, parts of Bemiss, and parts of East Central. Need and demand for new parks in these gap
areas will therefore increase.

Across the alternatives, Northeast Spokane has growth in areas with high rates of self-reported poor
physical health, particularly on the northern side and especially for Alternatives 1 and 2. Northeast
Spokane is also expected to see growth in areas with high rates of social vulnerability. Growth may
result in higher demand for EMS and parks in these areas, which may already experience greater need
than other areas of the city.

Division Corridor

All alternatives plan for some job and housing growth in the Division Corridor, especially in
Alternatives 2 and 3. This area is therefore likely to see some increased demand for police, fire/EMS,
solid waste, schools, parks, and libraries in all alternatives. This includes housing growth in the park
gap areas in north Shiloh Hills and East Central. These areas are therefore expected to have an
increased need and demand for new parks.

Under all alternatives, some growth is expected to occur in parts of the Division Corridor that have
high rates of self-reported poor physical health and social vulnerability, particularly in Alternatives 2
and 3. Growth may result in higher demand for EMS and parks in these areas, which may already
experience greater need than other areas of the city.

Center City

All alternatives plan for a substantial amount of job and housing growth in Center City, with the
greatest growth planned under Alternative 3. Center City is therefore likely to see more demand for
police, fire/EMS, solid waste, schools, parks, and libraries than other parts of the city in all alternatives.
This includes housing growth in the park gap area in East Central, which is therefore expected to have
an increased need and demand for new parks.

Under all alternatives, growth is expected in Center City, which has generally high rates of self-
reported poor physical health and social vulnerability. Growth may result in higher demand for EMS
and parks in these areas, which may already experience greater need than other areas of the city.

South Spokane

Some housing growth is planned for South Spokane in all alternatives, especially in the neighborhoods
around Center City, along with parts of Lincoln Heights, Southgate, Grandview/Thorpe, and
Latah/Hangman. These areas will likely experience greater demand on police, fire/EMS, solid waste,
schools, parks, and libraries than other areas within South Spokane. This includes housing growth in
the park gap areas in the East Central, Lincoln Heights, Rockwood, Comstock, Southgate, Latah,
Grandview/Thorpe, and Browne’s Addition neighborhoods. These areas are therefore expected to
have an increased need and demand for new parks. Acquisition of land may also be more feasible in

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these areas than others based on land availability, particularly natural lands in the Thorpe and Latah
areas.

Across the alternatives, South Spokane has minimal growth overlapping with areas of high rates of
self-reported poor physical health and high rates of social vulnerability. Minimal environmental justice
impacts are expected in relation to public services.

West Plains

All alternatives plan for some job and housing growth in West Plains, with housing primarily planned
towards the eastern edge and jobs planned throughout, with an emphasis on the area north of the
airport. These areas will likely experience greater demand on police, fire/EMS, solid waste, schools,
parks, and libraries than other areas within West Plains. The location of housing growth also overlaps
with park gap areas. This area will therefore have increased need and demand for new parks.

West Plains does not have areas of particularly high rates of self-reported poor physical health and
social vulnerability. Minimal environmental justice impacts are expected in relation to public services.

Alternative 1: No Action, Stay the Course

Police
Greater demand for police services may occur in Downtown and in centers and corridors, as this is
where growth would be focused in Alternative 1. Alternative 1 plans for more job growth than
Alternative 2, but less than Alternative 3, which could result in greater demand for police services.

Fire/EMS
Greater demand for fire and EMS services may occur in Downtown and in centers and corridors, as
this is where growth would be focused in Alternative 1. This may result in more demand on fire
stations throughout the City, especially those serving Downtown (1), West Plains (6), Hillyard (15),
Shiloh Hills (18), and East Central (7, 8, and 14). Stations 1 and 18 already respond to a substantial
percentage of citywide calls.

Alternative 1 plans for more job growth than Alternative 2, but less than Alternative 3, which could
result in greater demand for fire/EMS services.

Schools
Alternative 1 would have the greatest impact on the Mead and Cheney School Districts and the least
on Spokane School District among the alternatives, based on the location of growth. Based on housing
growth, new school demand in Alternative 1 is likely to be Downtown and in centers and corridors.

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Parks
Parks demand in Alternative 1 is expected to be highest in Center City and surrounding
neighborhoods, North Indian Trail, Five Mile Prairie, Shiloh Hills, Hillyard, Grandview/Thorpe,
Latah/Hangman, Lincoln Heights, Southgate, East Central, and the eastern part of West Hills. Almost all
of these areas also have existing gaps in park access.

Libraries
Growth in Alternative 1 is focused in Downtown, and in centers and corridors, so greater library
demand in these areas is expected though citywide demand is expected to be the same. This may
especially affect the Central Library.

Solid Waste
Growth in Alternative 1 is focused in Downtown and in centers and corridors, so greater residential
waste demand is expected in those areas though citywide demand is expected to be the same.
Alternative 1 plans for more job growth than Alternative 2, but less than Alternative 3, which could
result in greater demand for commercial solid waste.

Environmental Justice Implications
Alternative 1 includes some areas of growth that overlap with areas of self-reported poor physical
health, including Center City and the north side of Northeast. These areas may have greater demand
for EMS services. Center City and parts of Northeast also have growth areas overlapping with areas of
high social vulnerability, which may indicate an increased need for parks.

Alternative 2: Distributed and Balanced

Police
Greater demand for police services may occur along frequent transit corridors, as this is where growth
would be focused in Alternative 2 though citywide demand is expected to be the same. Alternative 2
plans for the least amount of jobs so would likely have lower overall demand than Alternatives 1 and
3.

Fire/EMS
Greater demand for fire and EMS may occur along frequent transit corridors, as this is where growth
would be focused in Alternative 2 though citywide demand is expected to be the same. This may result
in more distributed demand across the City, particularly at Stations 1, 2, 7, 8, 11, 13, 15 and 18.
Stations 1 and 18 already take a high percentage of citywide calls. Alternative 2 plans for the least
amount of jobs so would likely have lower overall demand than Alternatives 1 and 3.

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Schools
Total demand for new schools is likely to be similar across alternatives, however Alternative 2, like
Alternative 3, would have greater demand on the Spokane School District and less on the Mead and
Cheney School Districts than Alternative 1. Based on housing growth, new school demand in
Alternative 2 is likely to be along frequent transit corridors. New students would likely be distributed
more across the city, in contrast to Alternative 3 where much of the student growth would happen in
Downtown, West Plains, and Hillyard.

Parks
Parks demand in Alternative 2 is expected to be highest in Center City and surrounding
neighborhoods, North Indian Trail, Hillyard, North Hill, Nevada Heights, Grandview/Thorpe,
Latah/Hangman, Lincoln Heights, Southgate, and East Central. Many of these areas also have existing
gaps in park access.

Libraries
Greater demand for libraries may occur along frequent transit corridors, as this is where growth would
be focused in Alternative 2. This may distribute library demand more around the city, in contrast to
Alternative 3 where much of the demand would likely affect the Central Library branch.

Solid Waste
Growth in Alternative 2 is focused along frequent transit corridors so greater residential waste
demand is expected in those areas. Alternative 2 plans for the least amount of jobs so would likely
have lower commercial demand than Alternatives 1 and 3. Under Alternatives 2 and 3, new LOS are
also under consideration with the Capital Facilities Plan update and may change the number of
collections to four per household per month for garbage, two for recycling, and four for organics.

Environmental Justice Implications
Alternative 2 includes some areas of growth that overlap with areas of poor physical health, including
Center City, the north side of Northeast, and parts of the Division Corridor. These areas may have
greater demand for EMS services. Center City and parts of Northeast also have growth areas
overlapping with areas of high social vulnerability, which may indicate an increased need for parks.

Alternative 3: Center City and Regional Hubs

Police
Greater demand for police services may occur in Downtown and Regional Hubs like in West Plains and
Hillyard, as this is where growth would be focused in Alternative 3. Alternative 3 plans for the greatest
number of jobs so would likely have greater overall demand than Alternatives 1 and 2.

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Fire/EMS
Greater demand for fire and EMS may occur in Downtown and Regional Hubs including in West Plains
and Hillyard, as this is where growth would be focused in Alternative 3. This may result in more
demand at Stations 1, 6, and 15. Station 1 already responds to 18% of citywide calls. Alternative 3
plans for the greatest number of jobs so would likely have greater overall demand than Alternatives 1
and 2. The additional intensities of jobs are expected in Center City to be focused on medical,
educational, and R&D, whereas in West Plains and Hillyard more light and heavy industrial jobs are
expected, which would require greater attention to fire and EMS activities including application of fire
codes and regular inspections.

Schools
Total demand for new schools is likely to be similar across alternatives; however Alternative 3, like
Alternative 2, would have greater demand on the Spokane School District and less on the Mead and
Cheney School Districts than Alternative 1. Based on housing growth, new school demand in
Alternative 3 is likely to be highest Downtown and in Regional Hubs like West Plains and Hillyard.

Parks
Parks demand in Alternative 3 is expected to be highest in Center City and surrounding
neighborhoods, North Indian Trail, Hillyard, Shiloh Hills, North Hill, Nevada Heights,
Grandview/Thorpe, Latah/Hangman, Lincoln Heights, Southgate, and East Central. Many of these areas
also have existing gaps in park access.

Libraries
Greater demand for libraries may occur in Downtown and Regional Hubs such as West Plains and
Hillyard, which would have both industrial jobs and mixed-use commercial as well as residential uses.
With this growth pattern, there may be increased demand at the Central Library in particular, as well
as Liberty Park Library

Solid Waste
Greater demand for solid waste services may occur in Downtown and Regional Hubs including West
Plains and Hillyard, as this is where growth would be focused in Alternative 3. Alternative 3 plans for
the greatest number of jobs so would likely have greater commercial waste demand than Alternatives
1 and 2. Under Alternatives 2 and 3, new LOS are also under consideration with the Capital Facilities
Plan update and may change the number of collections to four per household per month for garbage,
two for recycling, and four for organics.

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Environmental Justice Implications
Alternative 3 includes some areas of growth that overlap with areas of self-reported poor physical
health, including Center City and parts of the Division Corridor, to a greater extent than Alternative 2.
These areas may have greater demand for EMS services. Center City and the north end of the Division
Corridor also have growth areas overlapping with areas of high social vulnerability, which may indicate
an increased need for parks.

3.8.3 Mitigation Measures

Incorporated Plan Features
 The adopted Comprehensive Plan includes a Capital Facilities and Utilities Element and a Parks and
Recreation Element, which include policies that support planning for levels of service, operations,
maintenance, funding, and capital projects for public services.
 The adopted Capital Facilities Plan includes level of service standards for police, fire/EMS, schools,
and libraries.
 The adopted Parks and Natural Lands Master Plan includes levels of service and policies to support
park development to meet current and future City needs.
 Alternatives 2 and 3 include a new Spokane Capital Facilities Plan, which updates the adopted plan
to align with other providers’ plans and current population numbers. An updated Capital Facilities
Plan would ensure the most recent plans for future growth are considered in capital planning. New
LOS for some types of capital facilities are also under consideration as part of this plan and would
better take current conditions and observed deficiencies into account.
 Alternatives 2 and 3 include a new Climate Element, which includes goals and policies to support
climate resiliency of City functions, including emergency services, like police, fire, and EMS, and
parks. Policies will also support environmental health which may put less pressure on emergency
services.

Regulations and Commitments
 An increase to local sales and use tax to support a Public Safety Tax for criminal justice and fire
protection became effective April 1, 2025.
 Spokane County’s 2021 Comprehensive Emergency Management Plan includes actions for
preparedness, prevention, protection, mitigation, response, and recovery for a range of hazards
that require emergency response.
 The Spokane Fire Department created a Strategic Positioning Plan in 2019, which included seven
goals to continuously improve its services.
 The Spokane Municipal Code includes fire code (Chapter 17F.080) and wildland-urban interface
code (Chapter 17F.110) for fire prevention and response, both of which are based on international
standards.

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 The 2025-2026 Spokane Police Department Strategic Plan identified six strategic priorities for the
department.

Other Potential Mitigation Measures
 Impact fees for schools, parks, or fire could support increased staffing and capacity to address
ongoing growth, if other funding streams are unable to match needs.
 The City could investigate opportunities for increased parks access such as a fee-in-lieu program or
park land dedications in key locations.
 The City could explore partnership opportunities to support the development of educational and
childcare spaces, or public-private partnerships to develop parks or acquire natural lands.

3.8.4 Significant Unavoidable Adverse Impacts
No significant unavoidable adverse impacts are expected as impacts to police, fire/EMS, schools, parks,
and solid waste, including environmental justice-related impacts, can be managed through regular
planning, staffing processes, and mitigation measures.

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3.9 Utilities
This section identifies the policy and regulatory framework governing utility development, provision,
and operations; existing utilities providers in Spokane; and the potential effects of the three
alternatives being considered on the need for capital improvements.

Thresholds of significance utilized in this impact analysis include:
 Impacts would require major unplanned capital improvements within Avista’s power service
network.
 Impacts would require major unplanned capital improvements within the City’s potable water
system.
 Impacts would require major unplanned capital improvements within the City’s sewer system.
 Impacts would require major unplanned capital improvements to prevent flooding at frequencies
and durations beyond design expectations.

3.9.1 Affected Environment
The following existing utility providers in the City of Spokane were considered in this analysis:
 Power (Avista)
 Water system (City of Spokane)
 Sewer system (City of Spokane)
 Storm drainage system (City of Spokane)

This section describes the elements of the existing utility systems as well as related natural, social, and
economic environments that might be affected by the alternatives. This section provides a baseline by
which changes that might be caused by the proposals can be measured against.

Power
Information about power relies primarily from Avista Corporation’s 2025 Electric Integrated Resource
Plan (2025 IRP).

Avista is an electrical and natural gas utility with a service area that spans much of the northwestern
United States. Service to the City of Spokane area started in 1889 as Washington Water Power which
changed to Avista in 1999 through an update to their corporate name. Avista provides electricity
through natural gas generators as well as water, solar, and wind sources. The breakdown of the power
generation sources is provided in Exhibit 3.9-1.

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Exhibit 3.9-1. 2026 Generating Capability by Fuel Source

Source: Figure 2 - 2025 Avista IRP, 2025.

Avista prepared its 2025 IRP to address growth in their services over the next 20 years based on their
own projections of a 0.91% increase of electricity consumption for the first 10 years and then a1.4%
increase in consumption in the last 10 years, largely due to electrification of buildings and
transportation. Exhibit 3.9-2 shows the growth in energy use separated by end use from 2025 to
2045.

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Exhibit 3.9-2. Change in Energy Use by End Use, 2025-2045

Source: Figure 3.11 – 2025 Avista Electric IRP, 2025.

Avista also records and forecasts their summer and winter peak loads as they tend to be
representative of the largest loads on their system. These peaks are forecasted to grow at 1.14% and
1.12% for the summer and winter peaks respectively for the first 10 years with a significantly higher
growth rate of 1.7% for the last 10 years. Exhibit 3.9-3 is a graph of the annual average energy growth
rate with the summer and winter peaks shown.

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Exhibit 3.9-3. Customer Load Forecast

Source: Figure 1 - 2025 Avista Electric IRP, 2025.

Avista’s power system has interplay between public and private infrastructure over the entire study
area as it serves as the primary power source. Growth in any subarea and type of connection would
result in a larger power demand on Avista’s grid. Avista’s Spokane-based power system interacts with
the following study areas outlined below.

Northwest Spokane
Northwest Spokane has a varied landscape including high density residential as well as commercial,
educational, and rural areas. Most of the area is dominated by single unit residential developments
with smaller pockets of high intensity residential and commercial developments near the Division
corridor. The western and northern sections of this area are more rural with lower intensity residential
and forested areas. Avista operates 5 substations in the Northwest Spokane Subarea.

Northeast Spokane
Northeast Spokane is varied in its landscape with a larger area of industrial sites to the east and south
and commercial developments along the Division corridor. The area also includes a large amount of
single unit and high intensity residential areas. There are little to no rural areas as much of the area is
developed. Avista operates 4 substations and a natural gas generator in the Northeast Spokane
Subarea. Avista’s IRP notes a plan to upgrade the Beacon Substation located near the intersection of
Havana St. And Buckeye Ave.

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Center City
The Center City area is the highest intensity area within Spokane including commercial, office, and high
intensity residential areas. Many of the governmental entities reside within this area. Center City has
little to no rural or forested areas. Avista has one substation and 4 hydroelectric facilities in this study
area.

South Spokane
The South Spokane area is another varied area with areas of commercial as well as single unit and
multi-unit residential areas. This area is more spread out and has large variations in elevation. The
center of this area is where most of the commercial development is located (along 29th and Regal). The
area is bounded on the west and south by more rural and forested areas. Avista operates 5
substations in this study area.

West Plains
The West Plains area is the most spread out area and also the area with the least development.
Spokane International Airport is located in the center of this area. Much of the West Plains is covered
by open space and industrial areas. Avista notes that the West Plains is a target of new improvements
with the Blue-Bird – Garden Springs 230 kV project. Avista operates 4 substations in this study area.
Avista’s IRP identified the West Plains area as one where additional capacity would be required due to
residential and industrial growth.

Water
Information in this section relies primarily on the 2023 City of Spokane Water System Plan (WSP).

The City of Spokane has owned and operated its public water system since the late 1800s. The water
system includes 8 water producing well stations, 37 water storage reservoirs, 26 booster pump
stations serving 25 pressure zones, and more than 1,100 miles of water pipelines. It serves more than
80,000 connections throughout the city.

The source water for the City’s water system is the Spokane Valley-Rathdrum Prairie Aquifer
(designated a sole source aquifer in 1978 by the EPA). The Aquifer is primarily recharged through
surface runoff and surface waters in the region.

This analysis references the pressure zones for the water system as there is significant overlap
between pressure zones in multiple study areas, and the Water System Plan is arranged to address
each pressure zone. The City’s Pressure Zones are provided in Exhibit 3.9-4 and Exhibit 3.9-5. They
are grouped by general area for the discussion later in this chapter.

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Exhibit 3.9-4. City of Spokane Water System Pressure Zones

Pressure Zone Location

Cedar Hills South Spokane: off Hwy 195 in the Latah Valley north of Eagle Ridge
Eagle Ridge South Spokane: off Hwy 195 in the Latah Valley south of Eagle Ridge
Eagle Ridge 2 South Spokane: off Hwy 195 in the Latah Valley just west of Hatch Rd
Five Mile Northwest Spokane: on top of Five Mile Prairie
Glennaire South Hill Spokane: east of Glenrose on 57th
Hatch Road South Hill Spokane: on Hatch Road Between Hwy 195 and 57th
High South Hill Spokane: Manito and Lincoln Heights Neighborhoods
Highland West Plains Area: around Highland Park
Indian Hills Northwest Spokane: east of the Intersection of Indian Trail Rd and Barnes Rd
Intermediate South Hill Spokane: south of Downtown between I90 and 14th.
Kempe Northwest Spokane: on the 5 Mile Prairie north of Strong Rd
Low Center Spokane: large low-lying area north of I90 and south of Garland Ave
Midbank Northwest Spokane: southern hillside of the Five Mile Prairie
North Hill North Spokane: large area spanning north of Garland to the City limits
Northwest Terrace Northwest Spokane: development west of Hwy 291 north of Francis Ave
Shawnee Northwest Spokane: east of Indian Trail Rd near Shawnee Ave
SIA West Plains area: in and around the Spokane International Airport
Southview Southeastern Spokane: east of Glennaire at the top of the hill
Top South Hill Spokane: south of the High Zone extending outside of the city limits
to the south.
West Plains West Plains area: southwest of Spokane International Airport
Woodland Heights West Plains area: area west of Hwy 195 and south of I90
Woodridge Northwestern Spokane: at the northwestern end of Five Mile Prairie

Source: City of Spokane, September, 2023.

Exhibit 3.9-5 below shows the pressure zones over the study area.

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Exhibit 3.9-5. Map of City of Spokane Water System Pressure Zones

Source: City of Spokane, July, 2025.

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The WSP determined the initial water system demands shown in Exhibit 3.9-6. Water system demands
are expressed in terms of Equivalent Residential Units (ERUs) which represent the average use of a
single-unit residential dwelling within the pressure zone. Also shown in Exhibit 3.9-6 is the
Distribution System Leakage (DSL), which is the representation of the estimated water loss due to
system leakage, also expressed as ERUs.

Exhibit 3.9-6. Equivalent Residential Unit (ERU) Flowrates by Pressure Zone

DSL ERU Total ERU ERUMDD ERU Winter
Pressure Zone ERU (Count) ERUADD (gpd/unit)
(Count) (Count) (gpd/unit) (gpd/unit)

Hatch Road 198 n/a 198 951 4,460 161

Southview 43 1 44 657 3,001 166

Woodridge 64 4 68 733 2,895 135

Glennaire 522 8 530 571 2,709 139

Shawnee 156 10 166 603 2,277 148

Eagle Ridge 459 3 462 501 2,157 132

Indian Hills 56 n/a 56 524 2,150 147

Five Mile 2,047 54 2,101 594 2,138 141

Woodland
243 82 325 463 1,976 124
Heights

Kempe 885 28 913 529 1,970 123

Midbank 573 12 585 514 1,911 128

Cedar Hills 221 6 227 443 1,906 116

Highland 862 67 929 442 1,883 126

Eagle Ridge 2 915 25 940 455 1,821 120

Northwest
1,497 n/a 1,497 487 1,739 120
Terrace

Top 11,811 1,181 12,992 509 1,718 127

SIA 5,840 31 5,871 419 1,661 132

West Plains 4,665 167 4,832 415 1,547 130

High 9,563 604 10,167 368 1,203 130

North Hill 39,531 2,104 41,635 347 1,032 120

Intermediate 8,757 1,073 9,830 303 838 107

Low 47,166 8,990 56,156 303 734 106

Total 136,074 14,450 150,524

Source: Table 2.2 - City of Spokane 2023 Water System Plan, September, 2023.

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Growth in each pressure zone was determined in the WSP through the Spokane Regional
Transportation Council (SRTC) 2019 Land Use Update Summary Traffic Analysis Zones (TAZs) and
associated demands were applied to forecast water demand to 2042. These growth rates were applied
to each pressure zone based on the TAZ forecast which resulted in the growth shown in Exhibit 3.9-7.
The annual growth in percent (%) between the plan year and 20-year projection is summarized in
Exhibit 3.9-8 as well.

Exhibit 3.9-7. 20-year Projected Number of Equivalent Residential Units per Pressure Zone
Pressure Zone Number of ERU ERU Growth Per Year (%)
Cedar Hills 475 5.46
Eagle Ridge 1,001 5.83
Eagle Ridge 2 1,665 3.86
Five Mile 3,095 2.37
Glennaire 530 0
Hatch Road 230 0.81
High 10,955 0.39
Highland 1,653 3.9
Indian Hills 56 0
Intermediate 11,874 1.04
Kempe 1,178 1.45
Low 62,948 0.60
Midbank 604 0.16
North Hill 46,540 0.59
Northwest Terrace 2,257 2.54
Shawnee 182 0.48
SIA 11,127 4.48
Southview 44 0
Top 14,955 0.76
West Plains 7,602 2.87
Woodland Heights 347 0.34
Woodridge 82 1.03
Uncategorized 828 N/A
Total 180,228 1.62

Source: Table 2.11 - City of Spokane Water System Plan, 2023.

The Water System Plan also classified the growth of different customer classes. Exhibit shows the
growth of each customer class by pressure zone.

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Exhibit 3.9-8. Growth Rate by Pressure Zone and Customer Class

Source: City of Spokane Water System Plan, 2023.

The following sections outline the characteristics of each group of water pressure zones. The groups of
pressure zones were selected based on their geographic area with some consideration of the study
areas, but as noted previously they have significant overlap between different study areas in many
cases.

Cedar Hills, Eagle Ridge 1 & 2, and Hatch Pressure Zones
The Cedar Hills, Eagle Ridge 1&2, and Hatch pressure zones are in the South Spokane study subarea
and are generally characterized by large suburban developments. The Water System Plan (WSP) shows
almost all the growth for this zone is to support single unit household customers with limited
commercial growth. The WSP includes projects that address growth in the zone with the planned
addition of a new booster pump station and reservoir within the Eagle Ridge pressure zone as well as
associated transmission mains.

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High, Top, Glennaire, and Southview Pressure Zones
The High, Top, Glennaire, and Southview pressure zones are located in the South Spokane study
subarea, extending beyond the city limits and span a wide range of elevations. The WSP shows growth
in this zone to support single unit, multi-unit, and commercial uses. The WSP includes projects that
upgrade booster stations to address additional flowrate needs to keep up with growth, replacements,
and maintenance for reservoirs that are nearing the end of their service life.

Low and Intermediate Pressure Zones
The Low and Intermediate pressure zones cover areas in the Center City, Northeast, and Northwest
study subareas and extend north to near Garland Ave and Northwest Blvd. Most of the City’s
production wells are in the Low and Intermediate pressure zones. The WSP shows growth in all
categories but includes higher growth levels to support medical and educational uses. The WSP
includes projects that increase well production and pump station capacity, replace pump stations
nearing the end of their service life, increase transmission main capacity, and install new reservoirs to
increase storage capacity.

North Hill, Northwest Terrace, Midbank, Indian Hills, Five Mile, Kempe, Shawnee, and
Woodridge Pressure Zones
The North Hill, Northwest Terrace, Midbank, Indian Hills, Five Mile, Kempe, Shawnee and Woodridge
pressure zones are in the Center City, Northeast, and Northwest study subareas in the northern third
of the city and extend over a wide range of elevations and around isolated hillsides. The WSP shows
growth for all customer classes but has higher growth for single and multi-unit housing, commercial,
and medical uses. The WSP includes projects that increase well production and pump station capacity,
replace pump stations nearing the end of their service life, increase transmission main capacity, and
install new reservoirs to increase storage capacity.

West Plains, SIA, Highland, and Woodland Heights Pressure Zones
The West Plains, SIA, Highland, and Woodland pressure zones are within the West Plains and South
Spokane study subareas and cover the area west of downtown including the Spokane International
Airport and the West Plains. The WSP shows growth for all customer classes except medical and
educational. The WSP includes projects that increase pump station capacity, replace pump stations
nearing the end of their service life, increase transmission main capacity, and install new reservoirs to
increase storage capacity.

Wastewater
Information from this section is based on the City of Spokane’s Integrated Clean Water Plan (ICWP)
from 2014.

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The City owns and maintains a wastewater system that comprises nearly 900 miles of sewer lines.
There are several areas within the City’s sanitary sewer system which are combined with stormwater,
but those areas have interceptors and combined sewer overflow tanks which provide temporary
storage during large rain events. The City also owns and operates the Riverside Park Wastewater
Reclamation Facility (RPWRF), which collects and treats all the wastewater in the City’s sanitary sewer
system.

Sewer basins are usually split between those that drain via gravity and those that drain via a pumped
system. Pumped systems are inherently more restrictive than gravity systems and thus will be more
susceptible to issues brought about due to increases in unplanned flowrates. For this reason, this
analysis focuses on basins that drain via pumped systems over the capacity of gravity sewer mains.
The other consideration is the connection between the City’s stormwater and sanitary sewer systems
via the Combined Sewer Overflow (CSO) network. The discussion on the CSO network is provided in
the Stormwater section later in this chapter. Exhibit 3.9-9 below shows the locations of the City’s
wastewater pump stations from the 2023 Wastewater Lift Stations Conditions Assessment completed
by Parametrix, Inc.

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Exhibit 3.9-9. Map of Sanitary Sewer Pump Stations In Spokane

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Northwest Spokane
The sanitary sewer system in Northwest Spokane flows to the RPWRF generally southeasterly via
gravity except for several isolated areas which flow to a regional pump station first. The pump stations
located in this region are shown below in Exhibit 3.9-10. There are a few other limiting pipelines
within this study area, including the siphon crossing of the Spokane River near TJ Meenach Way and
the siphon that crosses the Northside Landfill just south of the Indian Trail area. The RPWRF is also
located in this area, and per the ICWP, it was planned for treatment of 50 million gallons per day (mgd)
through a membrane facility, which was completed between the preparation of the plan in 2014 and
this document. The ICWP envisioned possible future expansion to handle 85 mgd. The City has
recently begun the facility planning process for the RPWRF to look at the 20-year horizon and beyond.
This process will evaluate the need for further expansion.

Exhibit 3.9-10. Sanitary Sewer Pump Stations In Northwest Spokane

Station Name

Northwest Terrace
River Run
Sans Souci
Sundance 3rd Addition
Sundance IX Addition
Meadow Glen
Evergreen
Rossmoor Ridge
Copper River
Francis & Assembly
Francis & Cannon
Lower Crossing
Aubrey L. White
(Decommissioned)
Wind River

Source: City of Spokane, 2023.

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Northeast Spokane
The sanitary sewer system in Northeast Spokane flows southwesterly towards the RPWRF, but due to
several isolated areas, there are several regional pump stations that are used to link to larger gravity
mains. The Upriver pump station captures several services from Spokane County and pumps them
westerly. The Northpointe and Lincoln pump stations capture the large area north of Francis Ave and
East of Division St and pump south to a trunk line that links up with the rest of the northeastern
system before heading to the RPWRF. Other limiting pipes within the Northeast area are siphons that
cross the Spokane River near Regal St and Boone Ave. This area also receives flows from a portion of
the Spokane County sewer system that cannot easily be routed to the Spokane County Wastewater
Treatment Plant. This flow comes from the Marion Hay pump station which outlets into the Francis
and Cannon Station.

Exhibit 3.9-11. Sanitary Sewer Pump Stations In Northeast Spokane

Station Name

Upriver
Lincoln Rd
Shiloh Hills
Crestline
Northpointe

Source: City of Spokane, 2023.

Center City
The sanitary sewer system in Center City flows northwesterly towards the RPWRF. This area has the
fewest pump stations but is the most densely populated. There are a few critical pipelines that cross
bridges in this area which convey flow from much of the South Hill, most notably the 60-inch trunk line
that crosses the Post Street Bridge.

Exhibit 3.9-12. Sanitary Sewer Pump Stations In Central Spokane

Station Name

Springfield

Source: City of Spokane, 2023.

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South Spokane
The sanitary sewer system in the southern portion of Spokane flows northerly towards the RPWRF.
Flows from this region cross the Spokane River in one of only two locations, either through the Clarke
Ave pump station or across the 60-inch trunk line under the Post Street Bridge. Clarke Ave is the City’s
largest pump station and it conveys most of the west half of the South Hill as well as all of the West
Plains area. The remaining pump stations serve several smaller isolated areas.

Exhibit 3.9-13. Sanitary Sewer Pump Stations In South Spokane

Station Name

Eagle Ridge
Clarke Ave
Qualchan
35th and Helena
Highland Park
Elm Street

Source: City of Spokane, 2023.

West Plains
The West Plains sanitary sewer system flows northeasterly towards the Clarke Ave pump station,
where it crosses the Spokane River towards the RPWRF. This area also crosses Latah Creek near High
Bridge Park. Also included in this sewage basin is the Fairchild Airforce Base as well as the Spokane
International Airport. The Hayford pump station in this area receives mainly industrial flows from the
surrounding area.

Exhibit 3.9-14. Sanitary Sewer Pump Stations In the West Plains

Station Name

Hayford
SIA

Sources: City of Spokane, 2023

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Stormwater
Information in this section refers primarily to the City of Spokane’s Integrated Clean Water Plan from
2014, and the Stormwater Management Program Plan from 2025. For information regarding surface
waters, refer to Section 3.1 Earth, Water Quality, and Water Resources.

The City manages a stormwater system mainly focused on collecting, treating, and infiltrating
stormwater within the right of way of city streets. There are several areas where the stormwater and
sanitary sewer systems are combined. These areas are typically older neighborhoods closer to the city
center or in the South Spokane or Center City subareas. In areas where there are combined sewers,
interceptors and combined sewer overflow tanks provide temporary storage of peak rainfall events to
help prevent overloads at the treatment plant. There are also outfalls to the Spokane River in the
event of extreme events to prevent flooding.

The City identified Drainage Concern Areas (DCAs), shown in Exhibit 3.9-15 to address specific
localized issues with infiltration, high groundwater, and shallow bedrock, which limit available options
to manage and disperse stormwater.

This section discusses the plans for capital improvement projects related to the CSO system within
each DCA and identifies inconsistencies between the plans for the CSO and stormwater system that
could result in flooding, sewer outfall events, or damage to infrastructure. A map of the CSO basins is
provided in Exhibit 3.9-16 and Chapter 5 Appendix D. Further explanation of each study area and the
relevant DCA and CSO basins is provided later in this section.

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Exhibit 3.9-15. Drainage Concern Areas

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Exhibit 3.9-16. Map of CSO/Storm/UIC Areas

Source: CSO Annual Report, City of Spokane, 2024.

Northwest Spokane
Within Northwest Spokane, the Five Mile Prairie, and North River MS4 are the two DCAs of note. In the
Five Mile Prairie, there are large areas of poorly draining soils, shallow bedrock, and high groundwater.
It is also at a significantly higher elevation than the surrounding area. North River MS4 has areas of
shallow bedrock and groundwater. The CSO basins in northwestern Spokane are 02, 06, 07, 10, 12, 14,
15, and 23, which are mostly located adjacent to the Spokane River except for CSO 06 (Chapter 5
Appendix D). CSO 06 serves an area where the stormwater system has not been separated from the
sewer system. The ICWP (Table 4-1) identified a need for additional storage and infiltration capacity
within all CSO basins within this area except for CSO 02.

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Northeast Spokane
Within Northeast Spokane the Northeast Drainage and North River MS4 are the two DCAs of note. The
Northeast Drainage DCI has areas of poorly draining soils. North River MS4 has areas of shallow
bedrock and groundwater. The CSO basins in Northwestern Spokane are 38, 39, 40, 41 and 42 which
are all adjacent to the Spokane River. The ICWP identified a need to adjust the regulator setting at CSO
41.

Center City
Within Center City the Downtown DCA was established due to shallow bedrock and limited areas for
treatment and disposal due to the amount of development. The CSO basins in Center City are 23, 25,
26, 24B, and 33 C and D. The ICWP did not identify any specific projects for this area.

South Spokane
The South Hill and South Spokane area includes the Lower South Hill and Moran Prairie DCIs. The
Lower South Hill DCA has limited combined sewer pipe capacity. The Moran Prairie DCA has shallow
groundwater and bedrock. The CSO basins in South Spokane are 19, 20, 24 A and B, 26, 33 A and B,
and 34. The ICWP Identified needs to increase storage at CSO 24, 26, 33 and 34. The South Hill area
also includes the only stormwater specific pump station that the City operates, at 35th Ave and Helena
St.

West Plains
Within the West Plains area the West Plains DCA was established due to shallow bedrock and
groundwater and poorly draining soils. The only CSO basin in the West Plains area is 16. The ICWP did
not identify any specific projects for this area.

3.9.2 Impacts

Impacts Common to All Alternatives
Each alternative will see growth throughout the study area which will require planning and adjustment
of capital improvement projects to address changes in utility demands. The City departments and
Avista should plan to align the scheduling of projects to those areas where growth is anticipated to
avoid any mismatches between their planned improvement projects and the chosen alternative
impacts which could result in the need for additional improvements. Special consideration should be
given to key infrastructure for the following utilities:

Power
 Substations
 Generators (gas, solar, hydroelectric, wind)

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Water
 Wells
 Pump Stations
 Reservoirs

Sewer
 Pump Stations
 Water Reclamation Facilities
 Siphons

Stormwater
 CSOs
 Pump Stations
 Infiltration Facilities

Environmental Justice Considerations
Lower-income households may spend more of their income on energy expenses, and may live in
poorly insulated housing which can result in higher energy demand. Costs to install more resilient
forms of energy may be a barrier.

A household with 6% or greater energy burden is considered to be a high energy burden household.
Energy cost burdens vary in Spokane with greater energy costs in Northeast Spokane and the East
Central portion of South Spokane, and parts of Northwest Spokane typically along Division Corridor,
though the areas overall do not reach 6%. See Exhibit 3.9-17.

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Exhibit 3.9-17. Percent of gross household income spent on energy

Calculated by dividing the average housing energy cost by the average annual household income.
Source: (US Department of Energy, 2025)

Growth in areas with high risk and vulnerability to a changing climate such as in areas subject to
flooding or urban flooding may require a greater degree of investment in improved drainage to
overcome these vulnerabilities as described in the City of Spokane Climate Risk and Vulnerability
Assessment, June 2025. Within the Center City area there is significant crossover between the high-
susceptibility climate vulnerability index and the Downtown DCA. The Center City area should be
considered for additional funding for storage and disposal to help mitigate flooding risk.

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Alternative 1: No Action, Stay the Course

Power
Alternative 1 is consistent with Avista’s forecasting as the utility has a plan to address growth along the
current trajectory. Avista’s planned growth rates in power demand are within the range shown in
Exhibit, with Avista’s growth at a combined 1.15% (0.91% for the first 10 years and 1.4% for the next
10 years) landing within the Moderate-High projection.

Water
Alternative 1 differs from the projections in the City’s WSP (2042 horizon) based on the new
projections in the updated SRTC TAZ data (SRTC up to 2050, adjusted in this EIS for 2046). While there
will be an increase in water demand, the City has a plan to address needs as the system expands,
which will need to be compared to the growth targets between the two projections. This alternative
does have the largest growth in the single unit housing, which typically creates larger water usage
peaks for irrigation in the irrigable months (April through October). Even so, the City’s water system
would be able to serve that projected growth.

Wastewater
There are plans in the ICWP to expand treatment capacity at the RPWRF. The difference in sewer usage
between single unit and multi-unit connection depends on the density of the development; more
dense clusters of single unit and multi-unit developments will see larger flows. While there will be an
increase in sewer demand, the City has a plan to address needs as the system expands in Alternative 1
since it lines up with their existing plan.

Stormwater
There are plans in the ICWP to upgrade the CSO system. The City may need to develop a strategy to
address or mitigate the drainage issues in each of the DCIs. There will be an increase in stormwater
flows, but the City has a plan to address needs as the system expands in Alternative 1 since it lines up
with their existing plan.

Alternative 2: Distributed and Balanced

Power
Alternative 2 would concentrate much of the growth around transit routes and increase mixed-use
and multi-unit growth throughout the city. From a power distribution standpoint, if there are more
concentrated users, this should increase the efficiency of the power network and reduce total usage.
This may result in the need to upgrade existing infrastructure to address growth in the areas
surrounding the transit routes.

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Water
Similar to the impacts noted in the Power section, concentrating growth along corridors under
Alternative 2 would be a net benefit to a water system. However, as WSP assumptions do not show the
same level of growth around the Wellesley and Francis Corridors, the City may need to upgrade
existing infrastructure or construct new infrastructure to support growth in those areas.

Alternative 2 increases the mixed-use and housing density along Northwest Blvd, Francis Ave, and
Wellesley Ave, which could increase the need for production in the Low and North Hill pressure zones
which only showed an increase of 0.60% and 0.59%, respectively. Since the production wells are
predominantly in this zone, the production capacity may need to be expanded in these zones.

As with water production there is also a potential mismatch between the storage capacity in the Low
and North Hill pressure zones between Alternatives 1 and 2. As noted above, there may be additional
storage needs in the areas surrounding Northwest Blvd, Francis Ave, and Wellesley Ave.

Wastewater
Concentrating growth along corridors may be a net benefit to a utility, but the plan for growth should
be compared to where limiting infrastructure is located, such as siphons, pump stations, and the water
reclamation facility. With growth in Alternative 2 increasing along the Northwest Blvd, Francis Ave, and
Wellesley Ave corridors, as well as in the West Plains, this could result in the need to expand capacity
at the Francis and Cannon and Clarke Ave pump stations as well as the Latah Creek Siphon.

Stormwater
Alternative 2 converts much of the growth into mixed-use and multi-unit developments which could
reduce the stormwater generated overall. There are a few DCIs which the growth either happens
adjacent to or near, but all of them are already developed, and the planned development is not likely
to increase the stormwater generated so long as the City maintains their existing stormwater
mitigation standards for both private and public developments.

Alternative 3: Center City and Regional Hubs

Power
Alternative 3 would concentrate much of the growth in the downtown area and increase the mixed-
use and multi-unit growth throughout the city. From a power distribution standpoint, if there are more
concentrated users, this should increase the efficiency of the power network and reduce total usage.
This higher concentration in these central areas may require additional generation or transmission
capacity.

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Water
Similar to the impacts noted above in the Power section, concentrating growth in a central area is a
net benefit to a water system. However, this concentrated growth may require expansion of
transmission, production, and storage in the Low, North Hill, Intermediate, High, and Top Pressure
zones.

Wastewater
Concentrating growth along corridors may be a net benefit to a utility, but the plan for growth should
be compared to where limiting infrastructure is located such as siphons, pump stations, and the water
reclamation facility. With growth in Alternative 3 increasing downtown, as well as in the West Plains,
this could require improvements to the Post Street Bridge Trunk Line and Clarke Ave pump station, as
well as the Latah Creek Siphon.

Stormwater
Alternative 3 concentrates most of the growth in the downtown core where there is already a lot of
development. Since redevelopment is unlikely to increase stormwater runoff, other than maintaining
the existing stormwater mitigation standards, no further action is likely needed.

3.9.3 Mitigation Measures

Incorporated Plan Features
While the alternatives do not specifically discuss utilities, the City’s Comprehensive Plan does include a
section on utilities that lists the policies, goals, and regulations that are set to provide safe, reliable,
and equitable service that addresses growth throughout the city; protect water quality; advocate for
water conservation; encourage energy efficiency; and revitalize the community. These policies include
City programs to reduce water use through grants for low water use landscaping, requirements for
onsite stormwater treatment, disposal for new developments, and targeting infrastructure
improvements in historically underserved areas. The City plans to update its level of service standards
for water service to better align with the Washington Department of Health’s (DOH) standards. Their
current standard targets meeting 45 pounds per square inch (PSI) of pressure at a minimum. The DOH
standard better targets pressures with system flows like a minimum service pressure of 30 PSI during
the maximum day flow as well as meeting required minimum fire flows at 20 PSI. Updating this
standard will allow the City to better align its goals with state regulatory standards.

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Regulations and Commitments

Electrical

Federal
 National Electrical Code, as adopted by the National Fire Protection Association

State
 2019 Washington State Clean Energy Transformation Act, amending portions of RCW Titles 19
(Business Regulations – Miscellaneous), 43 (State Government – Executive), 80 (Public Utilities), and
82 (Excise Taxes) to commit Washington to an electricity supply free of greenhouse gas emissions
by 2045.
 Washington State Energy Code, WAC Title 51, Chapters 11C and 11R

Local
 Electric Service Requirements administered by Avista

Drinking Water

Federal
 Safe Drinking Water Act, 42 USC 300 et seq., Chapter 6A, administered but the U.S. Environmental
Protection Agency

State
 Water Systems, WAC Title 246, Chapters 290-296, administered by the Washington State
Department of Health

Local
 Public Utilities and Services, Spokane Municipal Code Title 13 Chapter 13.04 – Water
 City of Spokane Design Standards

Wastewater

Federal
 National Environmental Policy Act United States Code (USC) 4321 et seq.
 Clean Water Act, 33 United States Code (USC) 1251 et seq., including Section 402 – National
Pollutant Discharge Elimination System (NPDES)

State
 State Environmental Policy Act (SEPA) RCW Title 43.21C; WAC 197-11

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 Washington State Department of Ecology, WAC Title 173, Chapters 200-270, which includes
administration of the NPDES program, discharge and effluent standards, the waste discharge
general permit program, construction of wastewater treatment plants, and construction and
operation of combined sewer overflow reduction facilities
 NPDES Wastewater Discharge Permit program, administered by the Washington State Department
of Ecology
 Wastewater Collection System Consent Decree, administered by the Washington State Department
of Ecology and U.S. Environmental Protection Agency

Local
 Public Utilities and Services, Spokane Municipal Code Title 13 Chapter 13.03 – Sewers
 City of Spokane Design Standards

Stormwater

Federal
 Clean Water Act, 33 USC 1251 et seq., including Section 402 – National Pollutant Discharge
Elimination System
 Endangered Species Act, 16 USC 1531 et seq.

State
 National Pollutant Discharge Elimination System (NPDES) Western Washington Phase I Municipal
Stormwater General Permit, administered by the Washington State Department of Ecology
 NPDES Industrial Stormwater General Permit, administered by the Washington State Department
of Ecology
 Stormwater Management Manual for Eastern Washington, administered by the Washington State
Department of Ecology
 Washington State Hydraulic Code, WAC Title 220, Chapter 660, administered by the Washington
Department of Fish and Wildlife

Local
 Public Utilities and Services, Spokane Municipal Code Title 13 Chapter 13.03 – Sewers
 City of Spokane Design Standards
 Spokane Regional Stormwater Manual

Other Potential Mitigation Measures
While each alternative has the potential to impact utilities through increased demand, none of these
impacts are identified as significant adverse impacts. City codes regulating construction and future

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utility investments will continue to ensure new development addresses any service or capacity
constraints.

The City and Avista regularly plan and adapt to changing growth patterns and are currently engaged in
efforts to improve the water system and address long-term demand and climate change effects on
water supplies and the aquifer, address wastewater and drainage system capacity, meet electrical
demand, and increase the resiliency of their utility systems to growth and impacts of climate change.

Some recommendations in the June 2025 Climate Risk and Vulnerability Assessment include:
 Consider expanding local energy resources. An example includes: Maximize renewable energy
sources for the supply of electricity and heat to new and existing buildings.
 Invest in public infrastructure to improve energy efficiency.
 Invest in upgrading gray and green infrastructure.
 Minimize runoff. This could include requiring the use of green infrastructure and low-impact
development to address increased storm intensities and stormwater runoff.
 Protect critical aquifer recharge areas.
 Implement community-based water use efficiency.

3.9.4 Significant Unavoidable Adverse Impacts
None of the alternatives are anticipated to create significant unavoidable adverse impacts to the ability
of the City or Avista to deliver utility services to the population of Spokane. While there are some
inconsistencies between areas targeted for future growth and planned infrastructure improvements
or expansion areas, the City and Avista regularly review changes in growth patterns and are actively
engaged in efforts to improve wastewater and drainage system capacity and reduce water
consumption and electrical demand. City codes regulating construction and future utility investments
will continue to ensure new development addresses any service or capacity constraints.

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4 Acronyms and References

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4.1 Acronyms
ACS American Community Survey
ADA Americans with Disabilities Act
ADU Accessory Dwelling Unit
AIAN American Indian and Alaska Native
ALT Alternative
AMI Area Median Income
AOP Air Operating Permits
BIPOC Black, Indigenous, and People of Color
BMPs Best Management Practices
BRT Bus Rapid Transit
CAA Clean Air Act
CAGR Compound Annual Growth Rate
CARA Critical Aquifer Recharge Area
CFCs chlorofluorocarbons
CIP Capital Improvement Program
CO Carbon Monoxide
CPPs Spokane County Countywide Planning Policies
CSO Combined Sewer Overflow
DAHP Department of Archaeology and Historic Preservation, Washington State
DCAs Drainage Concern Areas
EIS Environmental Impact Statement
EMS Emergency Medical Services
EPA Environmental Protection Agency
ERU Equivalent Residential Unit
ESD Employment Security Department, Washington State
FEMA Emergency Management Agency
GHG Greenhouse Gas
GMA Growth Management Act
HAP Housing Action Plan
HAPT Housing for All Planning Tool
HB House Bill
HCM Highway Capacity Manual
HOV High Occupancy Vehicle
HPT High-Performance Transit
ICWP Integrated Clean Water Plan
IRP Integrated Resource Plan
LCA Land Capacity Analysis
LOS Level of Service
MFTE Multifamily Tax Exemption
mgd million gallons per day

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MPH Miles per Hour
N.D. Not Dated
NAAQS National Ambient Air Quality Standards
NO2 Nitrogen Dioxide
NOC Notice of Construction
NPDES National Pollutant Discharge Elimination System
NSC North Spokane Corridor
NWI National Wetlands Inventory
O3 Ozone
OFM Office of Financial Management, Washington State
PPPH Persons per Household
PSD Prevention of Significant Deterioration
PSI pounds per square inch
RCW Revised Code of Washington
RDI Racially Disparate Impacts
RPWRF Riverside Park Wastewater Reclamation Facility
s.f. square feet
SMA Shoreline Management Act
SMC Spokane Municipal Code
SMP Shoreline Master Program
SO2 Sulfur Oxide
SOV Single Occupancy Vehicle
SR State Route
SRCAA Spokane Regional Clean Air Agency
SRTC Spokane Regional Transportation Council
ST Street
STA Spokane Transit Agency
SVI Social Vulnerability Index
SWAP Washington State Wildlife Action Plan
TAZ Transportation Analysis Zones
TDM Transportation Demand Management
TOD Transit Oriented Development
U.S., US United States
USFWS U.S. Fish and Wildlife Service
V/C Volume to Capacity
VMT Vehicle Miles Traveled
WAC Washington Administrative Code
WDFW Washington Department of Fish and Wildlife
WRIA Water Resource Inventory Area
WSDOT Washington State Department of Transportation

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December 2025 ▪ Draft EIS

4.2 References

4.2.1 Earth, Water Quality, and Water Resources
Ecology (Washington State Department of Ecology). 2018. Washington State Water Quality Assessment
303(d)/305(b) List. https://ecology.wa.gov/Water-Shorelines/Water-quality/Water-
improvement/Assessment-of-state-waters-303d. Accessed August 11, 2025.
Ecology. 2019a. Stormwater Management Manual for Western Washington. Department of Ecology
Water Quality Program. Publication Number 19 10 021. July 2019.
Ecology. 2019b. Phase I NPDES Municipal Stormwater General Permit. Effective August 1, 2019;
modified October 20, 2021; expires on July 31, 2024.
Ecology. 2021. National Pollutant Discharge Elimination System Construction Stormwater General
Permit. Effective January 1, 2021; expires December 31, 2025.
Ecology. 2025. PFAS in West Plains private wells. https://ecology.wa.gov/spills-cleanup/contamination-
cleanup/cleanup-sites/sites-with-pfas-in-drinking-water/west-plains-pfas. Accessed on
August 15, 2025.
FEMA (Federal Emergency Management Agency). 2024. Federal Flood Risk Management Standard.
Policy 206-24-005. https://www.fema.gov/sites/default/files/documents/fema_floodplain-
management_ffrms-policy_092024.pdf. September 2024.
Spokane, City of. Spokane Regional Stormwater Manual (Spokane et. al., 2008)
Spokane, City of. 2013. Stormwater Management Planning of the West Plains Subarea of Spokane,
West Plains Geology and Hydrology Report. April 2013.
Spokane, City of. 2025. Spokane Climate Policy Audit. Prepared by: BERK, Cascadia Consulting Group,
Fehr & Peers, and Parametrix. Available:
https://static.spokanecity.org/documents/planspokane/climate-planning/spokane-climate-
policy-audit-memo.pdf. Accessed: August 19, 2025.
United States Department of Agriculture (USDA) SSURGO Soils. 2025. Soil Survey Geographic Database
(https://www.nrcs.usda.gov/resources/data-and-reports/soil-survey-geographic-database-
ssurgo. Accessed August 5, 2025.
WSDOT (Washington State Department of Transportation). 2019a. Highway Runoff Manual. M 31-16.
https://www.wsdot.wa.gov/Publications/Manuals/M31-16.htm. April 2019.
WSDOT. 2019b. Hydraulics Manual. M 23 03. https://www.wsdot.wa.gov/Publications/Manuals/M23-
03.htm. April 2019.

4.2.2 Air Quality
Air Quality Index Basics. (2025). Retrieved from AirNow.org: https://www.airnow.gov/aqi/aqi-basics/

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December 2025 ▪ Draft EIS

BERK Consulting, Inc. (2025). Spokane Climate Vulnerability Index. Retrieved from
https://experience.arcgis.com/experience/cf4009af3d13499d8daba03ca580365c/page/Vulnera
bility-Index

BERK Consulting, Inc.; Cascadia Consulting Group. (2025, January 14). Spokane Climate Impacts and
Climate Justice. Retrieved from City of Spokane:
https://static.spokanecity.org/documents/planspokane/climate-planning/spokane-climate-
impacts-and-climate-justice-memo-2025-03-07.pdf

City of Spokane. (2017, June). Shaping Spokane: Comprehensive Plan for the City of Spokane. Retrieved
from City of Spokane:
https://static.spokanecity.org/documents/shapingspokane/comprehensive-plan/approved-
comprehensive-plan-2017-v12-2023-09-07.pdf

City of Spokane. (2025). 2022 Community and Local Government Operations Greenhouse Gas Emissions
Inventory Report. Retrieved from
https://static.spokanecity.org/documents/publicworks/environmental/2019-city-of-spokane-
greenhouse-gas-inventory.pdf

City of Spokane. (2025, June). Climate Planning. Retrieved from City of Spokane:
https://static.spokanecity.org/documents/planspokane/climate-planning/spokane-city-crva-
final-no-appendix-6-19-25-sh.pdf

EPA. (2014). Near Roadway Air Pollution and Health: Frequently Asked Questions. Office of Transportation
and Air Quality. Retrieved from https://www.epa.gov/sites/default/files/2015-
11/documents/420f14044_0.pdf

EPA. (2025). Ground-level Ozone Basics. Retrieved from EPA: https://www.epa.gov/ground-level-ozone-
pollution/ground-level-ozone-basics#wwh

Hegewisch, K., & Abatzoglou, J. (n.d.). Future Boxplots. Retrieved August 1, 2024, from Climate Toolbox:
https://climatetoolbox.org/tool/future-boxplots

Institute for Climate, Water, and the Environment. (2022). Spokane Urban Heat Maps. Retrieved from
Institute for Climate, Water, and the Environment: https://www.gonzaga.edu/climate-
institute/projects/climate-resilience-project/understanding/heat-mapping

Spokane Regional Clean Air Agency. (2021). Weather affects our air quality. Retrieved from Spokane
Regional Clean Air Agency: https://spokanecleanair.org/weather-affects-our-air/

Spokane Regional Clean Air Agency. (2023). High temperatures contribute to ground-level ozone
formation. Retrieved from Spokane Regional Clean Air Agency:
https://spokanecleanair.org/high-temperatures-contribute-to-ground-level-ozone-formation/

Spokane Regional Clean Air Agency. (2025). Air Pollutants & Trends. Retrieved from Spokane Clean Air
Agency: https://spokanecleanair.org/air-quality/air-pollutants-trends-reports/

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December 2025 ▪ Draft EIS

Spokane Regional Clean Air Agency. (2025). Spokane Regional Clean Air Agency. Retrieved from Spokane
Clean Air: https://spokanecleanair.org/air-quality/air-pollutants-trends-reports/

Spokane Regional Clean Air Agency. (2025). Spokane Regional Clean Air Agency. Retrieved from Clean Air
Report Card for 2024: https://spokanecleanair.org/the-2024-air-quality-data-for-spokane-
county-is-official-and-the-news-is-largely-positive-overall-the-air-quality-was-good-though-not-
perfect/

Spokane Regional Clean Air Agency. (2025). Spokane Regional Clean Air Agency. Retrieved from Outdoor
Burning: https://spokanecleanair.org/burning/outdoor-burning/

Spokane Regional Clean Air Agency. (2025). Spokane Regional Clean Air Agency - Air Quality Report - May
2025. Spokane Regional Clean Air Agency. Retrieved from https://spokanecleanair.org/wp-
content/uploads/AQ-May-2025.pdf

Spokane Regional Clean Air Agency. (2025, July 1). Notice of Construction Information Sheet. Retrieved
from Spokane Regional Clean Air Agency: https://spokanecleanair.org/wp-
content/uploads/NOC-Info-Sheet.pdf

Spokane Regional Transportation Council. (2021, December 9). Horizon 2045 - Spokane Metropolitan
Transportation Plan. Retrieved from SRTC: https://srtc.org/wp-
content/uploads/2025/02/Horizon2045_compressed.pdf

Spokane Regional Transportation Council. (2025). Metropolitan Transportation Plan - Horizon 2045.
Retrieved from https://srtc.org/our-work/core-plans-and-programs/metropolitan-
transportation-plan/#2045

U.S. Environmental Protection Agency. (2025, June 17). Outdoor Air Quality. Retrieved from United
States Environmental Protection Agency: https://www.epa.gov/report-environment/outdoor-air-
quality

US Department of Energy. (2025). Low-income Energy Affordability Data Tool. Retrieved from
https://www.energy.gov/scep/slsc/lead-tool

Washington State Department of Ecology. (2025). Carbon monoxide in Washington's air. Retrieved from
Washington State Department of Ecology: https://ecology.wa.gov/air-climate/air-quality/air-
quality-targets/air-quality-standards/carbon-monoxide

Washington State Department of Ecology. (2025). Lead in Washington's air. Retrieved from Washington
State Department of Ecology: https://ecology.wa.gov/air-climate/air-quality/air-quality-
targets/air-quality-standards/lead

Washington State Department of Ecology. (2025). Nitrogen dioxide in Washington's air. Retrieved from
Washington State Department of Ecology: https://ecology.wa.gov/air-climate/air-quality/air-
quality-targets/air-quality-standards/nitrogen-dioxide

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December 2025 ▪ Draft EIS

Washington State Department of Ecology. (2025). Prevention of Significant Deterioration (PSD) Permit.
Retrieved from Washington State Department of Ecology: https://ecology.wa.gov/regulations-
permits/permits-certifications/air-quality-permits/prevention-of-significant-deterioration-psd

Washington State Department of Ecology. (2025). Verification of Continued Attainment in Select
Maintenance Areas (2025). Washington State Department of Ecology. Retrieved from
https://apps.ecology.wa.gov/publications/SummaryPages/2502018.html

Washington State Department of Ecology. (n.d.). General orders for air quality permits. Retrieved from
Washington State Department of Ecology: https://ecology.wa.gov/regulations-permits/permits-
certifications/air-quality-permits/air-quality-general-orders

Washington State Legislature. (2025). General Regulations For Air Pollution Source. Retrieved from
https://app.leg.wa.gov/wac/default.aspx?cite=173-400

4.2.3 Plants and Animals
Burke Museum. 2025a. “Mammals of Washington.” Accessed July 31, 2025 at
https://www.burkemuseum.org/collections-and-
research/biology/mammalogy/mamwash/?_ga=2.185509036.462253364.1754549419-
853978113.1754549419
Burke Museum. 2025b. “Amphibians & Reptiles of Washington.” Accessed August 1, 2025 at
https://www.burkemuseum.org/collections-and-research/biology/herpetology/amphibians-
reptiles-washington
eBird.org. 2025. Spokane, WA bird list. Accessed July 31, 2025 at https://ebird.org/region/US-WA-
063/bird-list?yr=curM
Federal Emergency Management Agency (FEMA). 2024. "Benefits of Natural Floodplains." Last updated
July 26, 2024. Accessed August 4, 2025 at https://www.fema.gov/floodplain-
management/wildlife-conservation/benefits-natural
FEMA. 2025. FEMA National Flood Hazard Layer Viewer. Accessed July 31, 2025 at
https://www.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5529a
a9cd
Fryer, Janet L. 2016. Fire regimes of Northern Rocky Mountain ponderosa pine communities. In: Fire
Effects Information System, [Online]. U.S. Department of Agriculture, Forest Service, Rocky
Mountain Research Station, Missoula Fire Sciences Laboratory (Producer). Available:
www.fs.usda.gov/database/feis/fire_regimes/Northern_RM_ponderosa_pine/all.html Accessed
August 5, 2025.
Hennings, L. and Soll, J. 2010. Wildlife Corridors and Permeability: A Literature Review. Portland, OR:
Metro Sustainability Center, April 2010.
Inland Northwest Land Conservancy. 2016. “Restoring the Spokane River: Community Collaboration.”
September 1, 2016. Accessed August 1, 2025 at https://inlandnwland.org/restoring-the-
spokane-river-community-collaboration/

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December 2025 ▪ Draft EIS

Krausman, P. R., S. Smith, J. Derbridge and J. A. Merkle. 2008. Suburban and exurban influences on
wildlife and fish. FWP Project 2801. Wildlife Division, Montana Fish, Wildlife & Parks, Helena,
USA.
Manthey, G., Marinkovic, M., Lalonde, S., and Chehab, S. 2021. Urban Tree Analysis Report 2020. A
Collaboration between the City of Spokane, the Spokane Lands Council, and Gonzaga
University.
Mulvany, Colin. 2019. “Bullfrogs in Cannon Hill Pond.” The Spokesman-Review, June 14, 2019. Accessed
online July 28, 2025 https://www.spokesman.com/galleries/2019/jun/14/bullfrogs-in-cannon-
hill-pond/
NatureServe Explorer. 2025. Information on the Columbia Plateau and Columbia Mountains/Northern
Rockies Level III ecoregions. Accessed July 28, 2025 at
https://explorer.natureserve.org/pro/Welcome
Spokane City/County Historic Preservation Office. 2025. Accessed online at
https://www.historicspokane.org/. August 4, 2025
Spokane Conservation District. 2012. Hangman (Latah) Creek Watershed Riparian Action Plan.
November 21, 2012
Spokane Conservation District 2025. “Restored Access Points” Accessed August 1, 2025 at
https://spokanecd.org/blogs/news/spokane-river-restored-access-points
Spokane County Noxious Weed Control Board 2025. “Weeds of Concern.” Accessed July 20,2025 at
https://www.spokanecounty.gov/1095/Noxious-Weed-Control
Spokane Parks and Recreation, Urban Forestry Division. 2025. “SpoCanopy.” Accessed August 4, 2025
at
https://my.spokanecity.org/urbanforestry/programs/spocanopy/#:~:text=We%20want%20to%2
0ensure%20every,Learn%20more!
Spokane Riverkeeper. 2025. Redband trout, Spokane’s fish. Accessed July 28, 2025 at
https://www.spokaneriverkeeper.org/spokanes-redband-trout
Spokane Water Trail 2025. “Fishing.” https://www.spokaneriver.net/watertrail/fishing/ accessed July 30,
2025
SWIFD (Statewide Washington Integrated Fish Distribution). 2025. Datamap. Accessed July 20, 2025.
https://geo.nwifc.org/swifd/
USDA-FSA (U.S. Department of Agriculture Farm Service Agency). 2018. Primary Nesting Season Dates
and Duration. Accessed March 14, 2023 at https://www.fsa.usda.gov/Assets/USDA-FSA-
Public/usdafiles/Conservation/PDF/primary-nesting-season.pdf.
USFWS (U.S. Fish and Wildlife Service). 2007. National Bald Eagle Management Guidelines. May 2007.
Accessed March 12, 2024 at https://www.fws.gov/sites/default/files/documents/national-bald-
eagle-management-guidelines_0.pdf
https://www.fws.gov/sites/default/files/documents/national-bald-eagle-management-
guidelines_0.pdf.
USFWS. 2025a. National Wetlands Inventory (NWI) Wetlands Mapper. Accessed August 3, 2025 at
https://www.fws.gov/program/national-wetlands-inventory/wetlands-mapper

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December 2025 ▪ Draft EIS

USFWS 2025b. IPaC Information for Planning and Consultation database: Washington Fish and Wildlife
Office official species list. July 3, 2025. https://ipac.ecosphere.fws.gov/
U.S. Geological Survey (USGS). 2023. National Land Cover Dataset.
Visit Spokane 2025. "Fly Fishing on the Spokane River.” Accessed July 30, 2025 at
https://www.visitspokane.com/blog/fly-fishing-the-spokane-
river/#:~:text=Types%20of%20Fish%20in%20the,about%20a%2050/50%20split
Washington Department of Ecology (Ecology). 2020. Hangman (Latah) Creek Hydrogeologic
Assessment Focusing on the Latah Creek Wastewater Treatment Plant. November 2020,
Publication 20-03-013
_______ Ecology 2025a. “Making Improvements in the Spokane River Watershed.” Accessed July 25, 2025
at https://ecology.wa.gov/ecologys-work-near-you/river-basins-groundwater/spokane-river-
watershed
_______ Ecology. 2025b. Hangman Creek multi-parameter TMDL. Accessed October 17, 2025 at
https://.ecology.wa.gov/water-shorelines/water-quality/water-improvement/total-maximum-
daily-load-process/directory-of-improvement-projects/hangman-creek _______ Ecology. 2025c.
Hangman Settlement Agreement 2024 Annual Report. July 2025.
Washington Department of Fish and Wildlife (WDFW). 2023. Priority Habitats and Species Local
Government User Guide. May 12, 2023. Accessed July 20, 2025 at
https://wdfw.wa.gov/sites/default/files/publications/02426/wdfw02426.pdf.
WDFW. 2025a. “Ecosystems in Washington: Shrubsteppe.” Accessed August 4, 2025 at
https://wdfw.wa.gov/species-habitats/ecosystems/shrubsteppe
WDFW. 2025b. “Priority Habitats and Species List.” Accessed August 4, 2025 at
https://wdfw.wa.gov/species-habitats/at-risk/phs/list
WDFW. 2025c. PHS on the Web. Accessed August 4, 2025 at
https://geodataservices.wdfw.wa.gov/hp/phs/.
WDFW. 2025d. “Living with Wildlife - Species fact sheets” Accessed August 4, 2025 at
https://wdfw.wa.gov/species-habitats/living/species-facts#mammals
WDFW. 2025e. “Species in Washington.” Accessed July 30, 2025 at https://wdfw.wa.gov/species-
habitats/species
WDFW. 2025f. “Northern pike (Esox lucius).” Accessed October 17, 2025 at https://wdfw.wa.gov/species-
habitats/invasive/esox-
lucius#:~:text=The%20northern%20pike%20(Esox%20Lucius,water%20bodies%20within%20the
%20state
Washington Shrubsteppe Restoration and Resiliency Initiative. (2024). Retrieved from Washington
State Department of Fish and Wildlife: https://wdfw.wa.gov/species-habitats/habitat-
recovery/shrubsteppe#strategy.
Washington State Department of Natural Resources (WDNR). 2025. Washington Natural Heritage
Program Data Explorer. Accessed July 30, 2025 at https://www.dnr.wa.gov/NHPdataexplorer
Washington State Department of Transportation (WSDOT). 2019. US 395 North Spokane Corridor -
Spokane River Bridge Project Biological Assessment.

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December 2025 ▪ Draft EIS

Washington State Noxious Weed Control Board 2025. Spokane County Noxious Weed List. Accessed
July 20, 2025. https://www.nwcb.wa.gov/pdfs/Spokane-County.pdf

4.2.4 Land Use Patterns and Urban Form
Arksey, L. (2005, September 4). Spokane — Thumbnail History. Retrieved from HistoryLink.org Essay
7462: https://historylink.org/File/7462

BERK. (2025). Spokane Climate Vulnerability Index. Retrieved from
https://experience.arcgis.com/experience/cf4009af3d13499d8daba03ca580365c/page/Vulnera
bility-Index

City of Spokane. (2008). Fast Forward Spokane: Downtown Plan Update. Retrieved from
https://static.spokanecity.org/documents/business/resources/compplan/subarea/fast-forward-
downtown-plan-update.pdf

City of Spokane. (2015, Jan 26). Ordinance No. C35212 Hamilton Form Based Code Subarea Plan.
Retrieved from https://static.spokanecity.org/documents/projects/logan/formbased/ord-
c35212-hamilton-form-based-code.pdf

City of Spokane. (2017). Building Heights on Spokane Falls Boulevard: A Study Into the Challenges and
Opportunities of the Spokane Municipal Code, the Downtown Plan, and the Development
Requirements of the City of Spokane as they Apply to Shading on Riverfront Park. Retrieved from
https://static.spokanecity.org/documents/projects/building-heights-on-spokane-falls-
boulevard/building-heights-on-spokane-falls-boulevard-final-draft-report-oct-2017.pdf

City of Spokane. (2017). Shaping Spokane. Retrieved from A Comprehensive Plan for the future of
Spokane: https://my.spokanecity.org/shapingspokane/comprehensive-plan/

City of Spokane. (2017, June 23). RES 2017-0056 - Resolutions (Agenda Item 0650: Chief Garry Park
Neighborhood Action Plan 2017). Retrieved from
https://static.spokanecity.org/documents/projects/chief-garry-park-neighborhood/res-2017-
0056-final-signed.pdf

City of Spokane. (2022, May). Transit-Oriented Development Framework Study. Retrieved from
https://static.spokanecity.org/documents/projects/transit-oriented-development-study/tod-
framework-study-final-2022-05-06.pdf

City of Spokane. (2023, October 12). Centers and Corridors (GIS Map). Retrieved from
https://www.arcgis.com/home/webmap/viewer.html?webmap=9f72209fc23a46f69e8cd07f83ffd
2ad&extent=-117.7083,47.4965,-117.0979,47.8161

City of Spokane. (2024, January 29). South Logan TOD Final Plan (Adopted). Retrieved from South Logan
TOD Project: https://static.spokanecity.org/documents/projects/south-logan-tod/south-logan-
tod-final-plan-adopted-2024-01-29.pdf

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December 2025 ▪ Draft EIS

City of Spokane. (2025). Centers and Corridors Study. Retrieved from Projects:
https://my.spokanecity.org/projects/centers-and-corridors-study/

City of Spokane. (2025, February). 2025 Land Capacity Analysis. Retrieved from
https://static.spokanecity.org/documents/planspokane/2025-land-capacity-analysis.pdf

City of Spokane. (n.d.). Spokane Area History. Retrieved from https://my.spokanecity.org/about/history/

City-County of Spokane Historic Preservation Office. (2005). Downtown Spokane Heritage Walk.
Retrieved from Spokane History:
https://www.historicspokane.org/HeritageTours/downtown/history.html

Historical Research Associates, Inc. (2015). Chrisanne Beckner, MS, and Natalie K. Perrin, MS. Retrieved
from City of Spokane Parks and Boulevards (1891-1974), National Register of Historic Places
Multiple Property Documentation Form: https://www.historicspokane.org/wp-
content/uploads/2015/10/City-of-Spokane-Parks-and-Boulevards-MPD-2015.pdf

Institute for Climate, Water, and the Environment. (2022). Spokane Urban Heat Maps. Retrieved from
Institute for Climate, Water, and the Environment: https://www.gonzaga.edu/climate-
institute/projects/climate-resilience-project/understanding/heat-mapping

Kershner, J. (2007, January 25). Spokane's Streetcars. Retrieved from HistoryLink:
https://www.historylink.org/File/8080

MRSC. (2025, February 10). Light Nuisances - Ambient Light, Light Pollution, Glare. Retrieved from MRSC:
https://mrsc.org/explore-topics/code-enforcement/nuisances/light-nuisances

Nelson, R. K., Winling, L, et al. (2023). Mapping Inequality Redlining in New Deal America. Retrieved from
Digital Scholarship Lab:
https://dsl.richmond.edu/panorama/redlining/map/WA/Spokane#loc=12/47.668/-117.3898

Perk, V. C. (2017). Impacts of Bus Rapid Transit (BRT) on Surrounding Residential Property Values. Retrieved
from National Institute for Transportation and Communities. NITC-RR-894. Portland, OR:
Transportation Research and Education Center (TREC).: https://doi.org/10.15760/trec.178

Spokane City/County Historic Preservation Office. (2024). Updating the Historic Preservation Code SMC
17D.100.230. Retrieved from HistoricSpokane: https://www.historicspokane.org/centers-and-
corridors

Spokane City/County Historic Preservation Office. (2025, July). Spokane City and County Historic Districts
and Properties. Retrieved from https://www.historicspokane.org/

Spokane Tribe of Indians. (2020). The History of the Spokane Tribe of Indians. Retrieved from
https://www.spokanetribe.com/history/

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Transit Maps. (2017). Spokane United Railways system map from 1929 - Spokane once had one of the most
extensive electric trolley systems in the country. Retrieved from Reddit:
https://www.reddit.com/r/Spokane/comments/7153yu/spokane_united_railways_system_map_f
rom_1929/

Washington Department of Archaeology and Historic Preservation. (2025, August 6). Archaeological Risk
Assessment Model. Retrieved from WISAARD: https://wisaard.dahp.wa.gov/map

Washington State Digital Archives. (n.d.). Retrieved from
https://digitalarchives.wa.gov/do/CFDB6E8CABCB839591606C6B0DCDD4CF.jpg

Washington State Office of Archaeology and Historic Preservation. (1976, January). Browne's Addition
Historic District. Retrieved from NATIONAL REGISTER OF HISTORIC PLACES INVENTORY--
NOMINATION FORM: https://properties.historicspokane.org/_pdf/districts/national/district-
national-18.pdf

Wu, J. (2024, February 15). Light Pollution Explained: Impacts and Solutions. Retrieved from Leotek:
https://leotek.com/light-pollution/

4.2.5 Population, Housing, and Employment
BERK Consulting, Inc.; Cascadia Consulting Group. (2025, January 14). Spokane Climate Impacts and
Climate Justice. Retrieved from City of Spokane:
https://static.spokanecity.org/documents/planspokane/climate-planning/spokane-climate-
impacts-and-climate-justice-memo-2025-03-07.pdf

Chapple, K. (.-S. (2021, February 28). White Paper on Anti-Displacement Strategy Effectiveness. Retrieved
from Prepared for the California Air Resources Board: https://www.urbandisplacement.org/wp-
content/uploads/2021/08/19RD018-Anti-Displacement-Strategy-Effectiveness.pdf

City of Spokane. (2021, July 16). Spokane Housing Action Plan. Retrieved from
https://my.spokanecity.org/housing/spokane-housing-action-plan/

City of Spokane. (2025, February). 2025 Land Capacity Analysis. Retrieved from
https://static.spokanecity.org/documents/planspokane/2025-land-capacity-analysis.pdf

City of Spokane. (2025). Division Street Transit-Oriented Development. Retrieved from Spokane City >
Projects: https://my.spokanecity.org/projects/division-street-transit-oriented-development/

City of Spokane. (2025). Map Spokane. Retrieved from
https://spokane.maps.arcgis.com/apps/webappviewer/index.html?id=3bd21df38df54be58870e
0d66c80d6ae

City of Spokane. (Undated). Spokane Homeless System Map. Retrieved from
https://static.spokanecity.org/documents/ending-homelessness/about/spokane-homeless-
system-map.pdf

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December 2025 ▪ Draft EIS

City of Spokane. (2025, September). Racially Disparate Impacts Analysis. Retrieved from HB 1220:
Racially Disparate Impacts, Displacement, and Exclusion in Housing:
https://my.spokanecity.org/planspokane/housing-needs/racially-disparate-impacts/

City of Spokane. (June 2025). Accommodating Affordable Housing in the City of Spokane, Washington.
Spokane.

Kapatsila, B. R. (2024). If you build it, who will come? Exploring the effects of rapid transit on residential
movements in Metro Vancouver. Retrieved from Journal of Transport and Land Use, 17(1), 163–
185.: https://doi.org/10.5198/jtlu.2024.2364

OFM. (Undated). April 1 Definitions. Retrieved from https://ofm.wa.gov/wp-
content/uploads/sites/default/files/public/dataresearch/pop/april1/ofm_april1_definitions.pdf

Northeast PDA. (2025, July 24). Hillyard Subarea Plan. Retrieved from City of Spokane > Projects >
Hillyard Subarea Plan: https://static.spokanecity.org/documents/projects/hillyard-subarea-
plan/hillyard-subarea-plan-draft-2025-07-24.pdf

Savageau, A. (2023, March 15). How Housing and Education Drive Inequality. Retrieved from University of
Michigan, Michgan Journal of Economics: https://sites.lsa.umich.edu/mje/2023/03/15/how-
housing-and-education-drive-inequality/

Seva Rodnyansky, D. S. (2025, July 31). Pew. Retrieved from New Housing Slows Rent Growth Most for
Older, More Affordable Units: https://www.pew.org/en/research-and-
analysis/articles/2025/07/31/new-housing-slows-rent-growth-most-for-older-more-affordable-
units

Small Business Anti-Displacement Network. (2024). Small Business Anti-Displacement Toolkit. Retrieved
from https://antidisplacement.org/toolkit/

Spokane Trends. (2023). Public Safety. Retrieved from spokanetrends.org

Steering Committee of Elected Officials. (2024, May 15). First-Round Population Forecast and Allocation.
Retrieved from Report and Recommendation to the Steering Committee of Elected Officials:
https://www.spokanecounty.gov/DocumentCenter/View/54949/2026-2046-Initial-Jurisdictional-
Population-Allocation-SCEO-Recommendation-051524---signed?bidId=

Trust for Public Land. (2024, August). Great parks should not uproot communities. Retrieved from
Alessandro Rigolon, The University of Utah: https://www.tpl.org/wp-
content/uploads/2024/08/081224_Green-Papers_Great-Parks_G_final.pdf

Urban Institute. (2025, July). Generating Affordable and Abundant Transit-Oriented Development in
Washington State. Retrieved from https://www.urban.org/sites/default/files/2025-
07/Generating_Affordable_and_Abundant_Transit_Oriented_Development_in_Washington_State
.pdf

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December 2025 ▪ Draft EIS

Washington Office of Financial Management. (2025). April 1, 2025 Population of Cities, Towns, and
Counties. Retrieved from
https://ofm.wa.gov/sites/default/files/public/dataresearch/pop/april1/ofm_april1_population_fi
nal.pdf

Washington State Department of Commerce. (2023, August). Guidance for Updating your Housing
Element. Retrieved from Book 2:
https://deptofcommerce.app.box.com/s/1d9d5l7g509r389f0mjpowh8isjpirlh

Washington State Department of Commerce. (2023, April). Guidance to Address Racially Disparate
Impacts. Retrieved from Book 3 of GMA housing element guidance:
https://deptofcommerce.app.box.com/s/1l217l98jattb87qobtw63pkplzhxege

4.2.6 Relationship to Plans, Policies, and Regulations
Chief Garry Park Neighborhood Council. (2017). Chief Garry Park Neighborhood Action Plan 2017.
Retrieved from https://static.spokanecity.org/documents/projects/chief-garry-park-
neighborhood/chief-garry-park-neighborhood-plan-final.pdf

City of Spokane. (2012, Jan 30). RES 2012-0007: 0650 Five Mile Prairie Neighborhood Planning. Retrieved
from City Council Meeting Agenda Sheet:
https://static.spokanecity.org/documents/projects/fivemileprairie/five-mile-city-council-
resolution.pdf

City of Spokane. (2014, July 28). Council Agenda (July 28, 2014) - Resolution 2014-0086. Retrieved from
City Council Legislative Meeting:
https://my.spokanecity.org/citycouncil/meetings/2014/07/28/legislative-
meeting/?utm_source=chatgpt.com

City of Spokane. (2014, June 22). West Plains Draft Transportation Subarea Plan. Retrieved from Projects
> West Plains Subarea:
https://static.spokanecity.org/documents/projects/westplainssubarea/west-plains-
transportation-subarea-plan-07-22-2014.pdf

City of Spokane. (2016, Dec 12). City Council Agenda - RES 2016-0099. Retrieved from City Council
Meeting: https://static.spokanecity.org/documents/citycouncil/current-agendas/2016/12/city-
council-current-agenda-2016-12-12.pdf

City of Spokane. (2016, October). Fort George Wright Drive Staton & Corridor Plan: Final West Hills
Neighborhood Plan. Retrieved from City of Spokane Planning & Development Services
Department: https://static.spokanecity.org/documents/business/planning/neighborhood/final-
west-hills-plan-ft-george-wright-drive-sc-plan.pdf?

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December 2025 ▪ Draft EIS

City of Spokane. (2017, June 23). RES 2017-0056 - Resolutions (Agenda Item 0650: Chief Garry Park
Neighborhood Action Plan 2017). Retrieved from
https://static.spokanecity.org/documents/projects/chief-garry-park-neighborhood/res-2017-
0056-final-signed.pdf

City of Spokane. (2020, August 24). South University District Subarea Plan. Retrieved from Projects >
South University District Subarea Planning:
https://static.spokanecity.org/documents/projects/south-university-district-sub-area-
planning/south-u-district-subarea-plan-adopted-2020-08-24.pdf

City of Spokane. (2021). Volume V, Appendix H Neighborhood Planning - City of Spokane Resolutions.
Retrieved from City of Spokane Comprehensive Plan:
https://static.spokanecity.org/documents/shapingspokane/comprehensive-plan/appendix-h.pdf

City of Spokane. (2023, October 12). Centers and Corridors (GIS Map). Retrieved from
https://www.arcgis.com/home/webmap/viewer.html?webmap=9f72209fc23a46f69e8cd07f83ffd
2ad&extent=-117.7083,47.4965,-117.0979,47.8161

City of Spokane. (2023, September 7). Shaping Spokane - Comprehensive Plan for the City of Spokane.
Retrieved from https://static.spokanecity.org/documents/shapingspokane/comprehensive-
plan/approved-comprehensive-plan-2017-v12-2023-09-07.pdf

City of Spokane. (2024, January 29). South Logan TOD Final Plan (Adopted). Retrieved from South Logan
TOD Project: https://static.spokanecity.org/documents/projects/south-logan-tod/south-logan-
tod-final-plan-adopted-2024-01-29.pdf

City of Spokane. (2025). 5th Avenue Community Plan. Retrieved from Projects:
https://my.spokanecity.org/projects/fifth-avenue-plan/

City of Spokane. (2025). Centers and Corridors Study. Retrieved from Projects:
https://my.spokanecity.org/projects/centers-and-corridors-study/

City of Spokane. (2025). Neighborhood Planning. Retrieved from
https://my.spokanecity.org/business/planning/neighborhood/?utm_source=chatgpt.com

City of Spokane. (2025). South Logan TOD Project. Retrieved from Projects:
https://my.spokanecity.org/projects/south-logan-transit-oriented-development-project/

City of Spokane. (n.d.). Downtown Plan Update. Retrieved from Projects:
https://my.spokanecity.org/projects/downtown-plan-update/

City of Spokane. (n.d.). North Bank Plan. Retrieved from Projects:
https://my.spokanecity.org/projects/north-bank-plan/

Downtown Spokane Partnership. (2021, July 26). Spokane Downtown Plan. Retrieved from Projects >
Downtown Plan Update: https://static.spokanecity.org/documents/projects/downtown-plan-
update-2020/2021-07-26-spokane-downtown-plan-web.pdf

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December 2025 ▪ Draft EIS

East Central Neighborhood Partnership Center. (2006). East Central Neighborhood Plan. Retrieved from
https://static.spokanecity.org/documents/projects/tip/east-central-neighborhood-plan-
update.pdf

Eastern Washington University's Planning Team. (2011, December). Nevada Lidgerwood Neighborhood
Planning- Identity Report. Retrieved from City of Spokane > Projects > Nevada Lidgerwood:
https://static.spokanecity.org/documents/projects/nevadalidgerwood/nevada-lidgerwood-
neighborhood-identity.pdf

Emerson-Garfield Neighborhood Council. (2014, June). Emerson-Garfield Neighborhood Action Plan.
Retrieved from City of Spokane > Neighborhood Planning:
https://static.spokanecity.org/documents/projects/emersongarfield/emerson-garfield-final-
plan-07-10-14.pdf

EWU URP Program. (2011, 12). Nevada Lidgerwood Neighborhood - Planning Stakeholder Team Meeting.
Retrieved from Projects > Nevada Lidgerwood:
https://static.spokanecity.org/documents/projects/nevadalidgerwood/nevada-lidgerwood-non-
motorized-travel-safety.pdf

Five Mile Prairie Neighborhood. (2012). Neighborhood Plan for Bicycle and Pedestrian Improvements.
Retrieved from https://static.spokanecity.org/documents/projects/fivemileprairie/five-mile-bike-
pedestrian-improvements.pdf

Friends of Coeur d'Alene & Browne's Addition Neighborhood Association. (2015). Coeur d'Alene Park
Master Plan. Retrieved from
https://static.spokanecity.org/documents/parksrec/aboutus/planning/cda-park-master-plan-
final.pdf

Grandview/Thorpe Neighborhood Council. (2015, June 23). Grandview/Thorpe Neighborhood Action Plan.
Retrieved from https://static.spokanecity.org/documents/bcc/commissions/plan-
commission/meeting-documents/2015/07/08/gt-final-draft-2015-06-23.pdf

Greater Hillyard Northeast Planning Alliance. (2010, July 18). Bemiss, Hillyard, and Whitman
Neighborhoods - Report and Final Proposals from the 2009-2010 Neighborhood Planning Activities.
Retrieved from https://static.spokanecity.org/documents/projects/hillyard-subarea-
plan/ghnepa-neighborhood-plan-2010.pdf

Greater Spokane Inc. (2022, June). THRIVE Spokane Comprehensive Economic Development trategy.
Retrieved from GSI > Greater Growth: https://greaterspokane.org/what-we-do/greater-
growth/thrivespokane/

Makers, SCJ Studio, & Leland Consulting Group. (2024, June). City of Spokane Centers and Corridors
Study. Retrieved from Projects > Centers and Corridors Study:
https://static.spokanecity.org/documents/projects/centers-and-corridors-study/centers-and-
corridors-final-report.pdf

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December 2025 ▪ Draft EIS

North Hill Neighborhood Council. (2015, June 16). North Hill Neighborhood Action Plan. Retrieved from
City of Spokane > Business and Development > Neighborhood Planning:
https://static.spokanecity.org/documents/projects/north-hill/north-hill-final-draft-plan-2015-06-
16.pdf

Northeast PDA. (2025, July 24). Hillyard Subarea Plan. Retrieved from City of Spokane > Projects >
Hillyard Subarea Plan: https://static.spokanecity.org/documents/projects/hillyard-subarea-
plan/hillyard-subarea-plan-draft-2025-07-24.pdf

Peaceful Valley Neighborhood Council. (2015, November 11). Peaceful Valley Neighborhood Action Plan.
Retrieved from https://static.spokanecity.org/documents/bcc/commissions/plan-
commission/meeting-documents/2015/07/08/gt-final-draft-2015-06-23.pdf

SCJ Alliance. (2019, October). Shadle Area Neighborhood Plan (Plan Commission Draft) - Audubon-
Downriver/Northwest Neighborhoods. Retrieved from City of Spokane > Business Development >
Neighborhood Planning: https://static.spokanecity.org/documents/projects/northwest-and-
audubon-downriver-neighborhood-planning/shadle-area-draft-plan-2019-october.pdf

Shiloh Hills Neighborhood Council. (2025). Shiloh Hill Neighborhood Council. Retrieved from
https://shilohhills.spokaneneighborhoods.org/

South Hill Coalition. (2014, June). Spokane South Hill Coalition Connectivity and Livability Strategic Plan.
Retrieved from City of Spokane > Projects:
https://static.spokanecity.org/documents/projects/southhill/south-hill-coalition-adopted-
plan.pdf

Spokane Regional Transportation Council (SRTC). (2021, December 9). Horizon 2045 - Spokane
Metropolitan Transportation Plan. Retrieved from SRTC: https://srtc.org/wp-
content/uploads/2025/02/Horizon2045_compressed.pdf

SRTC. (2025). Metropolitan Transportation Plan - Horizon 2045. Retrieved from https://srtc.org/our-
work/core-plans-and-programs/metropolitan-transportation-plan/#2045

SRTC. (2022, July). DivisionConnets Phase 2 Report: Vision and Implementation Strategy. Retrieved from
SRTC: https://srtc.org/wp-content/uploads/2025/02/DivisionConnects-Vision-and-
Implementation-Strategy-Phase-2-Report_final2_compressed.pdf

SRTC; STA. (2021, May). DivisionConnects Study Phase 1: Division Street Corridor Development Plan.
Retrieved from Spokane Regional Transportation Council: https://srtc.org/wp-
content/uploads/2025/02/Corridor-Development-Plan_06102021_compressed.pdf

West Central Neighborhood. (2012, May). West Central Neighborhood Action Plan. Retrieved from
Business Development > Neighborhood Planning:
https://static.spokanecity.org/documents/projects/westcentral/west-central-action-plan-05-
2012.pdf

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December 2025 ▪ Draft EIS

WSDOT - Eastern Region Planning. (2022, Febuary 02). West Plains Subarea Transportation Management
Plan Phase 1 - US 2 Vicinity. Retrieved from
https://www.wsdot.wa.gov/publications/fulltext/GIS/US2/WPSA%20Phase%201%20Study%20Ex
ec%20Summary%20Documentation%202022-02-02%20-%20FINAL%20DRAFT.pdf

WSDOT. (2025). Final Outcomes / Practical Solutions. Retrieved from Online Open Houses > West Plains
Subarea Transportation Management Plan: https://engage.wsdot.wa.gov/west-plains-subarea-
transportation-management-plan/final-outcomes-practical-solutions/

4.2.7 Transportation
City of Spokane. (2014). Draft ADA Transition Plan, 2014–2019. Retrieved from
https://static.spokanecity.org/documents/about/spokanecity/accessibility/ada-transition-plans-
draft.pdf (Spokane City)
City of Spokane. (2015, November 2). Spokane Pedestrian Master Plan. Retrieved from
https://static.spokanecity.org/documents/projects/pedestrianplan/spokane-final-pedestrian-
plan-adopted-2015-11-02.pdf (Spokane City)
City of Spokane. (2017). Bicycle Master Plan. Retrieved from
https://my.spokanecity.org/projects/bicycle-master-plan/ (Spokane City)
City of Spokane. (2017). Shaping Spokane: City of Spokane Comprehensive Plan, Chapter 4 –
Transportation. Retrieved from
https://static.spokanecity.org/documents/shapingspokane/comprehensive-plan/chapter-4-
transportation-v7.pdf (Spokane City)
City of Spokane. (2023, June). 2023 Vision Zero Action Plan. Retrieved from
https://static.spokanecity.org/documents/projects/vision-zero/vision-zero-action-plan-june-
2023.pdf (Spokane City)
City of Spokane. (2024). Bicycle Priority Network. Engage Spokane. Retrieved from
https://engage.spokane.gov/bicycle-priority-network (Engage Spokane)
City of Spokane. (2025). Complete Streets Program (Spokane Municipal Code Chapter 17H.020). Retrieved
from https://my.spokanecity.org/smc/?Section=17H.020.040 (Spokane City)
Spokane Regional Transportation Council. (2021). Horizon 2045: Metropolitan Transportation Plan for the
Spokane Region. Retrieved from https://srtc.org/our-work/core-plans-and-
programs/metropolitan-transportation-plan/ (SRTC)
Spokane Regional Transportation Council. (2024). Spokane Regional Safety Action Plan. Retrieved from
https://www.srtc.org/wp-
content/uploads/2025/02/29478_SRTC_RSAP_v15_SMALL_081324_compressed.pdf (SRTC)
Spokane Regional Transportation Council. (2024). Regional Priority Networks – Horizon 2045 [GIS
dataset]. Retrieved from https://data-srtc.hub.arcgis.com/datasets/regional-priority-networks-
horizon-2045 (SRTC Regional Data Hub)
Spokane Regional Transportation Council. (2025). Spokane Regional Travel Demand Model, Provided to
the City of Spokane and Fehr & Peers for the Spokane 2046 Comprehensive Plan EIS.

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December 2025 ▪ Draft EIS

Spokane Transit Authority. (2024). Connect Spokane: A Comprehensive Plan for Public Transportation (as
amended 2024). Retrieved from https://www.spokanetransit.com/projects/comprehensive-
plan/ (Spokane Transit Authority)
Spokane Transit Authority. (2025). 2026–2031 Transit Development Plan. Retrieved from
https://www.spokanetransit.com/projects/transit-development-plan/ (Spokane Transit
Authority)
Spokane Transit Authority. (2025). Division Street Bus Rapid Transit (BRT). Retrieved from
https://www.spokanetransit.com/division-street-brt/ (Spokane Transit Authority)
Washington State Department of Transportation. (2024). Crash Data Portal. Retrieved from
https://remoteapps.wsdot.wa.gov/HighwaySafety/Collision/Data/Portal/Public/ (WSDOT Remote
Apps)
Washington State Department of Transportation. (2023). Freight and Goods Transportation System (FGTS)
– Truck Corridors [dataset and report]. Retrieved from https://gisdata-
wsdot.opendata.arcgis.com/datasets/wsdot-freight-data-freight-and-goods-transportation-
system-truck-corridors/about and https://wsdot.wa.gov/sites/default/files/2023-12/Freight-
Report-FGTS2023.pdf (WSDOT Geospatial Open Data Portal)
Washington State Department of Transportation. (2025). North Spokane Corridor (NSC) Major Project.
Retrieved from https://wsdot.wa.gov/construction-planning/major-projects/north-spokane-
corridor (WSDOT)
Washington Traffic Safety Commission. (2024). Data Dashboards. Retrieved from
https://wtsc.wa.gov/dashboards/ (Washington Traffic Safety Commission)

4.2.8 Public Services
Centers for Disease Control. (2022). SVI Interactive Map. Retrieved from
https://www.atsdr.cdc.gov/place-health/php/svi/svi-interactive-map.html

Centers for Disease Control. (2025). PLACES: Local Data for Better Health. Retrieved from
https://www.cdc.gov/places/index.html

City of Spokane. (2023). City Curbside Solid Waste Collection Moves to 6 a.m. Retrieved from
https://my.spokanecity.org/news/releases/2023/12/29/city-curbside-solid-waste-collection-
moves-to-6-am/

City of Spokane. (2025). 2025-2030 Citywide Capital Improvement Program. Retrieved from
https://static.spokanecity.org/documents/budget/2025/draft-2025-2030-citywide-capital-
improvement-program.pdf

City of Spokane. (2017). Capital Facilities Plan. Retrieved from
https://static.spokanecity.org/documents/shapingspokane/comprehensive-plan/appendix-c-
v2.pdf

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December 2025 ▪ Draft EIS

City of Spokane. (2022). Spokane Parks and Natural Lands Master Plan. Retrieved from
https://static.spokanecity.org/documents/parksrec/master-plan/spokane-parks-and-natural-
lands-master-plan.pdf

City of Spokane. (2025, August 27). Citywide Capital Improvement Program 2026-2031, DRAFT. Retrieved
from https://static.spokanecity.org/documents/budget/2026/draft-2026-2031-citywide-capital-
improvement-program.pdf

City of Spokane. (2025). Officer. Retrieved from Police Department:
https://my.spokanecity.org/police/officer/

City of Spokane. (2025). Spokane Police Department Strategic Plan 2025-2026. Retrieved from
https://static.spokanecity.org/documents/police/information/2025-2026-spd-strategic-plan.pdf

City of Spokane. (2025). Waste to Energy. Retrieved from https://my.spokanecity.org/solidwaste/waste-
to-energy/

City of Spokane. (2025). Solid Waste Services. Retrieved from https://my.spokanecity.org/solidwaste/

MW Engineers. (2025). Spokane Public Library Hillyard Library at Shaw MS. Retrieved from
https://www.mwengineers.com/portfolio/library-hillyard/

MW Engineers. (2025). Spokane Public Library Liberty Park. Retrieved from
https://www.mwengineers.com/portfolio/spokane-library-liberty-park/

Revised Code of Washington. (2022). RCW 28A.150.100. Retrieved from
https://app.leg.wa.gov/rcw/default.aspx?cite=28A.150.100

Spokane C.O.P.S. (2025). About Us. Retrieved from https://www.spokanecops.org/about-us

Spokane County. (2022). Comprehensive Solid Waste and Moderate Risk Waste Management Plan (2022-
2027). Retrieved from https://www.spokanecounty.gov/DocumentCenter/View/44215/Spokane-
County-SWMP?bidId=

Spokane Fire Department. (2023). 2023 Spokane Fire Department Annual Report. Retrieved from
https://static.spokanecity.org/documents/fire/resource-library/annual-reports/2023-annual-
report.pdf

Spokane Fire Department. (2024). 2024 Annual Report. Retrieved from
https://static.spokanecity.org/documents/fire/resource-library/annual-reports/2024-annual-
report.pdf

Spokane Fire Department. (2025). Fire Department. Retrieved from https://my.spokanecity.org/fire/

Spokane Fire Department. (2025). Fire Stations. Retrieved from
https://my.spokanecity.org/fire/operations/stations/

Spokane Police Department. (2024). SPD 2023 Highlights. Retrieved from
https://my.spokanecity.org/police/news/2024/01/04/spd-2023-highlights/

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December 2025 ▪ Draft EIS

Spokane Police Department. (2024). SPD 2023 Highlights. Retrieved from
https://my.spokanecity.org/police/news/2024/01/04/spd-2023-highlights/

Spokane Police Department. (2025). CompState NIBRS Report 07/14/2025. Retrieved from
https://static.spokanecity.org/documents/police/prevention/compstat/2025/07/compstat-
report-2025-07-14.pdf

Spokane Public Library. (2022). Imagine the Library of the Future. Retrieved from
http://future.spokanelibrary.org/

Spokane Public Library. (2024). 2024 Annual Report. Retrieved from
https://www.spokanelibrary.org/wp-content/uploads/25-001_Annual-Report-2024_Single.pdf

Spokane Public Library. (2025). About Us. Retrieved from https://www.spokanelibrary.org/aboutus/

Spokane Public Library. (2025). All Locations and Hours. Retrieved from
https://www.spokanelibrary.org/locations-
all?gad_source=1&gad_campaignid=20481966692&gbraid=0AAAAAqH-
fguh8iOKPeSDwbMzMm_c7GZbw&gclid=EAIaIQobChMIgOiymZz3jgMVASatBh0ohSiREAAYASAA
EgKRQvD_BwE

Spokane Public Schools. (2025). 2025 Bond. Retrieved from
https://www.spokaneschools.org/page/2025-bond

Spokane Public Schools. (2025). Our District. Retrieved from
https://www.spokaneschools.org/page/our-district

The Lands Council. (2023). URBAN FORESTRY- Spocanopy & coolcanopy. Retrieved from The Lands
Council: https://landscouncil.org/urban-canopy

The Spokesman Review. (2024). Voters agree to tax for Spokane Public Library to maintain services.
Retrieved from https://www.spokesman.com/stories/2024/feb/13/voters-poised-to-give-
spokane-libraries-funds-to-m/

Washington OFM. (2024). Small Area Estimates. Retrieved from https://ofm.wa.gov/washington-data-
research/population-demographics/population-estimates/small-area-estimates-program

Washington OSPI. (2024). OSPI Report Card - Spokane School District. Retrieved from
https://reportcard.ospi.k12.wa.us/ReportCard/ViewSchoolOrDistrict/100247

Urban Land Institute. (2025). The Hive – ULI Americas Awards for Excellence Special Mention. Retrieved
from https://americas.uli.org/the-hive-uli-americas-awards-for-excellence-special-mention/

4.2.9 Utilities
Avista Corp. (2025). 2025 Electric Integrated Resource Plan. Retrieved from:
https://www.myavista.com/about-us/integrated-resource-planning

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December 2025 ▪ Draft EIS

City of Spokane. (2023, February). City of Spokane Water System Plan. Retrieved from:
https://static.spokanecity.org/documents/publicworks/water/draft-water-system-plan-feb-
2023.pdf
City of Spokane. (2025). 2024 Combined Sewer Overflow (CSO) Annual Report. Retrieved from:
https://static.spokanecity.org/documents/publicworks/wastewater/cso/2024-annual-cso-
report.pdf

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5 Appendices

5-1

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City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix A ▪ Scoping and Public Outreach

A Scoping and Public Outreach 5-3
B Transportation Analysis Zones Maps 5-4
C Transportation Project Implementation Table 5-11
D Utility Maps 5-13
E Environmental Review Exemptions to Promote Infill Development and
Housing 5-2

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City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix A ▪ Scoping and Public Outreach

A Scoping and Public Outreach

 Notice: Determination of Significance and Request for Comments on Scope of EIS
 Fact Sheet: Environmental Impact Statement Scoping Fact Sheet
 Visioning Engagement Summary: PlanSpokane Community Visioning Engagement Summary
 Future Growth and Guiding Policies Workshops: Future Growth and Guiding Policies Engagement
Summary - PlanSpokane

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[Page 491]

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EIS Scoping Fact Sheet
Date: February 5, 2025

1 What is an EIS?
An Environmental Impact Statement (EIS) is an informational document that provides
the City, public, Tribes, and agencies with environmental information to be considered
in the decision-making process. An EIS is required under the State Environmental
Policy Act (SEPA) for larger projects or for major plans, regulations, and programs.
An EIS describes potential environmental impacts, reasonable Alternatives, and ways
to avoid or minimize negative impacts that could result from implementation of the
Comprehensive Plan. The EIS evaluation and mitigation measures would inform the
Spokane Comprehensive Plan periodic update.

The public, Tribes, and agencies will be invited to provide comments on the Draft EIS.
The Final EIS will include all comments received on the Draft EIS and responses from the
City of Spokane. The Final EIS may include revisions to the Draft EIS based on comments
received and new information learned. The Final EIS may also evaluate a Preferred
Alternative developed in the range of the Alternatives examined in the Draft EIS.

2 What is the Spokane Comprehensive Plan?
A “comprehensive plan” is the name given to identify the community’s long-range plan
for growth and is required by the Growth Management Act (GMA). It provides guidance
for all aspects of the city’s growth and development over a long period, typically 20
years. The plan is made up of a vision, goals, policies, and implementation strategies
that state how the city should grow physically, socially, and economically.

Spokane’s Comprehensive Plan is the product of many, many people including
hundreds of community members, the city Plan Commission, City Council and Mayor.
The City’s Comprehensive Plan was originally adopted in 2001 and last updated in 2017.

1

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3 What is a periodic update?
Spokane is preparing a periodic update to the City’s Comprehensive Plan for a new
planning period of 2026 to 2046, called PlanSpokane 2046. A “periodic update” is the
state’s term for a full review of a Comprehensive Plan to make sure it is in conformance
with any legislative changes to state law. Each chapter of the plan will be updated
to address new growth targets for population and jobs, and to meet changes to the
Growth Management Act (GMA) since 2017, including considerations around Climate
Planning and Planning for Housing at all income levels.

The Land Use Plan Map may be amended to create more housing and job opportunities
and respond to growth targets, community needs, transportation investments, and
environmental conditions. Zoning and other development regulations may also be
amended to implement the Land Use Plan Map. Critical area regulations would be
evaluated and recent state planning rules would be addressed.

4 What topics will be evaluated in the EIS?
Natural and built environment topics proposed for study in the Comprehensive Plan
Environmental Impact Statement (EIS) include those listed below. Each Alternative would
be evaluated with these topics.

Air quality and
Earth and water
greenhouse gas Plants and animals
quality
emissions

Population,
Land use patterns and Relationship to plans
employment, and
urban form & policies
housing

Transportation Public services Utilities

* police, fire and emergency medical services, parks, schools, and libraries
** power, water, wastewater, and stormwater

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5 What Alternatives will be studied in the EIS?
An Environmental Impact Statement (EIS) is required to identify and analyze Alternative
approaches to meeting the goals of a proposal. In the case of Comprehensive Plans,
these “EIS Alternatives” represent different growth strategies. Alternatives should
represent a diverse range of options that can highlight the impacts of different potential
choices. The Alternatives should be broad enough that the final Preferred Alternative,
which is included in the final plan, will fall within the range of the Alternatives studied.

The City anticipates studying three Alternatives in the Draft EIS described below.

• No Action Alternative: This State Environmental Policy Act (SEPA) required
Alternative is the continuation of the current Comprehensive Plan and associated
zoning and regulations. Growth would continue as planned under current rules.
Under this Alternative, the Plan would not be updated.

• Action Alternatives: Two Action Alternatives will be evaluated in the Draft EIS.
The Alternatives are under development and will explore different ways the City
can both meet Growth Management Act (GMA) requirements and accomplish
PlanSpokane 2046 themes to create a resilient, connected, and livable city. Public,
Tribal, and agency input during the scoping process will help Spokane form the
Alternatives for study in the EIS. Alternative features are anticipated to include:

• Meet Spokane’s population and housing growth targets for the period
2026-2046.
• Consider new or expanded locations for neighborhood commercial
services.
• Explore employment opportunities in existing or expanded centers.
• Consider changes to land uses where there are new investments in
transportation.

A Final EIS would study a Preferred Alternative in the range of the studied Alternatives,
potentially including components of all of the different Alternatives.

6 What is the schedule?
The City will match Growth Management Act (GMA) requirements for the periodic
update schedule. Currently the City is planning to issue the Draft Environmental Impact
Statement (EIS) in fall 2025 and the Final EIS in spring 2026. The City intends to integrate
the State Environmental Policy Act (SEPA) and GMA process by issuing the Draft Plan
and Draft EIS concurrently.

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EIS Schedule – Tentative

7 When can I provide comments on the EIS?
The City is providing a 60-day comment window during the scoping period in the first
quarter of 2025. See the Determination of Significance and Scoping Notice for
how to provide your comments in writing or attend several workshop opportunities. The
notice is available at: https://my.spokanecity.org/planspokane/about/.

The City will provide an additional comment period following release of the Draft
Environmental Impact Statement (EIS). Additional information on dates and how to
provide comment will be provided in the Draft EIS. Comments are accepted throughout
the Periodic Update process – please see below on how to participate.

8 How can I participate in PlanSpokane?
The City of Spokane invites your participation.

• Visit the project website to learn about the PlanSpokane 2046 planning process,
• Subscribe to the PlanSpokane newsletter on the project website
(https://my.spokanecity.org/planspokane/about/),
• Attend workshops, meetings, and hearings hosted by the City,
• Respond to surveys,
• Provide written comments, and
• Contact the Planning team at PlanSpokane@spokanecity.org or (509) 625-6500.

For more information, please see the project website:
https://my.spokanecity.org/planspokane/about/.

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PlanSpokane
Community Visioning
Engagement Summary
April, 2025

[Page 498]

Table of Contents

Executive Summary 3

Background 4

Vision Board 5

Community Visioning Workshop Series 6

Community Visioning Survey 9

Spring Market Visioning 11

Next Steps 11

Appendices 13

District 1 Memo

District 2 Memo

District 3 Memo

Community-Wide Memo

Community Visioning Engagement Summary 2

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Community Visioning Engagement Summary 3

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Background
The City of Spokane is commencing a periodic
update to the City’s Comprehensive Plan. A What is a Comprehensive
“periodic update” is the state’s term for a full Plan?
review of a Comprehensive Plan to make sure it’s
A Comprehensive Plan is the community’s
in conformance with any legislative changes to
vision for how the city grows and invests.
state law. The update also provides an opportunity
It is mandated by state law requiring a
to learn about any changes supported by the “road map” for fast-growing cities, known
community. as the Growth Management Act. Spokane
must have a Comprehensive Plan to
The City’s first Growth Management Act compliant
manage population growth, with goals
Comprehensive Plan was adopted in 2001 after a
that include reducing sprawl, supporting
robust community engagement process. It is made efficient multimodal transportation,
up of 14 Chapters which include Housing, Land protecting the environment, and many
Use, Transportation, Neighborhoods, Capital more. The Comprehensive Plan
Facilities, Natural Environments, and more. Minor establishes a vision for the city – looking at
annual amendments are processed most years, a horizon of twenty years. It guides
which primarily look at individual properties to implementation through Capital projects,
adjust land use designations to meet project City programs, and regulations.
needs. Then, every ten years the City goes through
a periodic update as required by the Growth Management Act, which takes a deeper look at the
entire document. Spokane’s last periodic update was in 2017, producing a plan called “Shaping
Spokane”.

The next periodic update is due in 2026, and is dubbed PlanSpokane 2046, as it is looking at the
next twenty-year planning horizon. While regular updates have occurred, this will be the first
substantial update since the Comprehensive Plan was first adopted in 2001. With the
significant population growth and changing local factors Spokane has experienced since then, this
update provides the community with an opportunity to reevaluate the vision. The goals of this
update are to meet all state legislative requirements updated since 2017, incorporate community
input around changing needs and wants, and to streamline the Plan to make it more user friendly.

Being the first substantial update since 2001, the City of Spokane has determined that this proposal
is likely to have a significant and potentially negative impact on the environment. As such, an
Environmental Impact Statement (EIS) is required under RCW 43.21C.030 (2)(c) and will be
prepared as part of the PlanSpokane 2046 effort. The Determination of Significance is the first step
towards updating the Comprehensive Plan to reflect visions, goals, and legislation to support
Spokane’s growth into 2046, and will provide insight into how to mitigate any potential impacts of
future growth.

The first step of the EIS process is known as “scoping”. Ultimately, the “scope” of the EIS identifies
different ways the City can meet its goals for growth or put differently, how to meet Spokane’s

Community Visioning Engagement Summary 4

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envisioned future. A request for comment on the scope of the EIS was issued on February 5, 2025
and ran through April 7, 2025. Both before and during the scoping comment period, the City of
Spokane Department of Planning and Economic Development provided opportunities for the
community to be engaged in the process of identifying that future vision for Spokane’s next twenty
years.

Feedback received during the Vision Board, Community Visioning Workshop Series, Community
Visioning Survey, and Spring Market Visioning are documented below and will help inform the
Environmental Impact Statement and PlanSpokane 2046 update to the Comprehensive Plan.

Vision Board
Launched on January 9, 2025 and
open for three months through April
10, 2025, the City of Spokane Vision
Board provided an early opportunity
for community members to share
their future vision for Spokane. A
vision board is a collection of images
and words that inspire and motivate
you to reach your goals. Looking
towards the Periodic Update of
Spokane’s Comprehensive Plan, this
vision board sought to identify the
community’s goals for Spokane for
the next twenty years. Figure 1. City of Spokane Vision Board was open from January 9, 2025 through April 10, 2025.

Of the 36 individual responses to the vision board activity, the common themes revolved around
nature and environmental stewardship, community connection, opportunities for housing
and jobs, improved access to public spaces. The list of responses can be found below.

A roof over every head Human-centered urban planning
Dedicated dog parks Make Spokane more walkable
Promote a mindset and local economy of Increased public green spaces in all
recycling and upcycling neighborhoods
Improved lighting on streets Preservation of historic architecture
Conversion of residential arterials to Build homeownership opportunities in infill
boulevards housing
Ensure public access to school playfields Rewild Spokane
A green, wet, and cool Spokane A Spokane River regatta
Neighborhood signs and identify Natural spaces preserved for wildlife
Pride in a cleaner city Neighborhood historic character preserved
Wilderness in every neighborhood Teach Peace
A welcoming Spokane to all people End of the housing shortage

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Children own the streets No one feels alone
Good jobs with higher wages People-oriented streets
Third places in every neighborhood (corner Property crime enforced and a greater feeling
stores, coffee shops, etc.) of safety
Promote home ownership over workforce Spaces where bicyclists and pedestrians are
housing protected from vehicles
An ability to age in place Attainable and accessible housing for all
Inclusive and welcoming community that Robust community gardens and sharing of
caters to the needs of everyone local crops
Public art and cultural arts economic growth Walkable and lively neighborhoods

Community Visioning Workshop Series
To further identify the community’s desires for Spokane’s future, the City of Spokane hosted a
Community Visioning Workshop Series in March 2025. One workshop was held in each Council
District, with one community-wide workshop located
in downtown. Over 150 individuals attended one or
more of the workshops, providing valuable feedback
to help shape the vision and future policies of the
Comprehensive Plan.

These in-person workshops included discussion,
mapping exercises, and feedback opportunities
related to various aspects of the Comprehensive
Plan and future growth options for the City. Each
station sought reactions and comments on how
community members envisioned the next twenty
years of Spokane. Figure 2. Community members participate in the District 2 Community
Visioning Workshop.

Station 1: Vision

The current City of Spokane Comprehensive Plan – Shaping Spokane – has unique vision statements
for the majority of the chapters. This station aimed to receive feedback on the general future they
envisioned for Spokane while also working towards the creation of a singular vision statement for
the updated Comprehensive Plan that will allow all chapters to work towards the same future.

When asked to write down one word that describes their ideal future, community members
provided the following themes:

Vibrant Affordable
Walkable Industries/Jobs
Safe Resilient/Sustainable
Bike-Friendly Attractive
Diverse Dense

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Art/Culture Family-Friendly
Access to Nature/Green Thriving
Community/Connected Accessible
Inclusive/Diverse/Welcoming Livable
Healthy Cutting-Edge/Innovation

Having thought of their ideal future
for Spokane, community members
were asked to rank rough drafts of
vision statements derived from the
existing statements found in the
Comprehensive Plan. Though similar,
the different statements were
intended to identify the phrasing and
general direction for the new vision
statement. The vision statements
voted on were as follows: Figure 3. A word cloud created from the existing vision statements in the Shaping Spokane
Comprehensive Plan.

Staff Vision Rewrite A: More
Collaborative

“Spokane will support its vibrant and inclusive neighborhoods by balancing livability, environmental
stewardship, and economic vitality, while cherishing its unique cultural and natural assets. The city
will ensure safe and efficient mobility, attainable housing, access to green spaces, neighborhood
services, and a high quality of life for all residents through responsible planning and community
partnership.”

Staff Vision Rewrite B: More Active

“Spokane will foster livability, connectivity, and resiliency throughout the city by balancing economic
vitality, environmental stewardship, and the diverse needs of residents, while cherishing its unique
and vibrant neighborhoods. The city will ensure access to safe and efficient mobility, attainable
housing, natural environments, and walkable neighborhood services to support a high-quality of
life for all residents.”

Staff Vision Rewrite C: Preserve Existing Traits

“Spokane is a livable, connected, and resilient city that balances the needs of its diverse residents,
economic vitality, and environmental stewardship to support vibrant and inclusive neighborhoods
that have access to safe and efficient mobility, attainable housing, green spaces, and services that
result in a high-quality of life for all residents.”

Statement B received the most votes with 33. Statement A came in a close second with 31 votes.
Statement C received 20 votes.

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When asked what may be missing from the rough draft statements, common themes were:

Arts and Culture Safety/Safe Streets
Housing and Food Security Acknowledgement of Tribal Sovereignty
Economic Mobility Connected Community
Access to Nature Pedestrian Focus

Station 2: Commercial Use Preference

Community members were asked to identify which commercial types they wanted to see more of
throughout Spokane and within their neighborhood. Participants were asked to vote between
convenience/groceries/big-box, restaurants, boutique stores,
shopping/retail complex, pharmacies/clinics, mixed-use/ground-
floor retail, neighborhood corner stores/cafes, and hotel/lodging.
The top three selected uses were neighborhood corner
stores/cafes (83 votes), mixed-use/ground-floor retail (79
votes), and restaurants (42 votes).

Additional uses or considerations provided included childcare,
senior housing, adaptive reuse of existing building, neighborhood
Figure 4. Community members participate in the groceries, community spaces, breweries, and bike repair/rentals.
District 3 Community Visioning Workshop.

Station 3: Your Spokane Mapping Exercise

Workshop participants were asked to indicate where they
currently live, work, and play in Spokane to provide an
understanding of who was providing comments and what areas
in Spokane are currently appealing to its residents. The four
workshops had a wide range of geographic input, with
participants living and working throughout the city. District
specific locations can be found in the attached appendices.

Comments were also received on initial thoughts about Spokane’s
current needs. Common themes included increased walkability
and bikeability, more frequent and expanded public
transportation, fire and traffic management, and public
meeting places. Figure 5. Community members participate in the
District 2 Community Visioning Workshop.

Station 4: Your Future Spokane Mapping Exercise

Next, community members were asked to think about the future of Spokane. Local businesses and
job opportunities were desired throughout Spokane, with specific locations identified during the

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individual workshops found in the attached appendices. However, large retailers were only
indicated to be desired in downtown and the North Hill Neighborhood.

Additional uses and considerations for Spokane’s future included:

Community gardens Increased fire infrastructure
Small grocery stores More housing types (including senior housing)
Improved pedestrian infrastructure Use of vacant properties
More natural areas and habitats Improved transit services
Public community spaces Balanced development (density + open space)

Station 5: Climate Ready Spokane

While the integration of climate and resiliency policies into the Comprehensive Plan is going through
a separate engagement process to gather even more feedback about the community’s experiences
with climate hazards and their impacts, the visioning workshops provided an additional opportunity
to reflect on ways to increase resiliency in Spokane. Specific mapped concerns or considerations
can be found in the attached appendices for each workshop. Common themes to support resiliency
were:

Provide more covered bus shelters Provide electric car charging stations
Plant more trees Increase public transit access
Reduce community water usage Increase recycling
Further incentivize low-water landscaping Improve walkability and bikeability
Fire management Provide public education on resiliency

Station 6: What Did We Miss?

At the end of the workshops, community members were asked to document any other topic or
theme that was missed, or any additional comments they wished to provide. Those comments can
be found in the attached appendices. Larger concepts that the community wants to also be
considered as part of the PlanSpokane 2046 update included services for Spokane’s unhoused
residents, food policy, urban design, connectivity, and all-age and all-ability usability of the
city.

Community Visioning Survey
In order to provide a feedback opportunity for members of the community who were unable to
attend one of the in-person workshops, an online Community Visioning Survey was launched.
Though only open two weeks during the beginning of April to ensure feedback was timely and able
to be included in the scoping process of the PlanSpokane 2046 effort, 64 responses were received
that will help direct the scope of the Periodic Update.

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Survey respondents were first asked what one word describes their ideal future for Spokane. Shared
themes include:

Inclusive/Diverse Prosperous
Sustainable/Nature/Conservation Safe/Clean
Affordable/Housed Accessible
Community Walkable/Bikeable
Healthy Family-Friendly
Vibrant Resilient

When asked to rank the available draft vision statement (reference
Station 1: Visioning section above), vision statement B was ranked
the most preferred. 25 votes ranked the statement the most
preferred and 22 votes ranked it second most preferred. Vision
station A came in second.

Vibrant, walkable neighborhoods, environmental stewardship,
balanced, and affordable housing were all concepts in the draft
statements that stood out to respondents. Missing terms from the
vision statements were also called out, including accessibility,
clean, an emphasis on safety, leveraging existing investment,
and all-age amenities. This feedback largely mirrors the
preferences of the Community Visioning Workshop Series and will
help shape the final vision statement of the PlanSpokane 2046 Figure 6. Scout the Marmot encourages you to
get involved in PlanSpokane 2046.
Comprehensive Plan.

To better understand desired uses throughout Spokane’s neighborhoods, the Community Visioning
Survey also asked about opinions on commercial uses. The majority of respondents agreed in some
capacity that they would like more local businesses and job opportunities within their
neighborhoods. Conversely, the majority of respondents disagreed in some capacity that they would
like more larger retailers. When asked to rank commercial uses, neighborhood corner
stores/cafes ranked first, followed by restaurants and groceries.

When asked what other uses they would like to see in their neighborhood, survey respondents
responded with:

Child Care Affordable Housing/Accessory Dwelling Units
Safe Sidewalks/Walking Trails Amenities in Parks
Professional Services Community Spaces/Maker Spaces
Farmer’s Markets/Community Gardens Bike Shops
Access to Transit Electric Charging Stations
Neighborhood Events/Art Walk Fire Services
Mental Health Support Memory-Friendly Public Spaces

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Spring Market Visioning
To wrap up the community engagement for the PlanSpokane 2046
visioning process, Planning staff attended the Spring Riverfront
Market in early April to advertise the Community Visioning Survey
and learn additional themes for Spokane’s future. Approximately 50
community members attended the tabling booth to learn about the
PlanSpokane 2046 project, Climate Planning efforts, and ongoing
transportation projects.

Shared themes for Spokane’s ideal future include:

Walkable/Bikeable Equitable
Healthy Safe/Clean
Well Known Exciting/Vibrant
Figure 7. Comments received during the
2025 Spring Riverfront Market.

Next Steps
Feedback received during the visioning, or scoping, process will inform the next steps of the
PlanSpokane 2046 effort. Based on the identified vision, potential “hows” of meeting that vision will
be identified. These different ways that the City may grow, called Growth Alternatives, will be
reviewed through the Draft Environmental Impact Statement. These Growth Alternatives look at
different scenarios, like different job growth or different zoning and code allowances, and what
impact those different scenarios may have on the environment and Spokane as a whole. Those
impacts are compared and a Preferred Alternative, the selected “how” for getting to the future
vision, will be selected. The Preferred Alternative, along with legislative requirements and document
streamlining, will inform changes to the actual Comprehensive Plan document. Final adoption of
the PlanSpokane 2046 Comprehensive Plan is expected in the later part of 2026.

Figure 8. PlanSpokane 2046 process timeline

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Community feedback will be accepted throughout the entire PlanSpokane 2046 process, from
helping select the Preferred Alternative to weighing in on proposed goals and policies of the
Comprehensive Plan.

We invite your participation:

• Visit the project webpage at PlanSpokane.org to learn more about the planning process
• Learn more about the Climate Planning efforts at my.spokanecity.org/climateplanning
• Subscribe to the PlanSpokane monthly newsletter to receive timely updates
• Attend future workshops, meetings, and hearings hosted by the City of Spokane
• Provide written comments or ask questions of the Planning team by emailing
PlanSpokane@spokanecity.org

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Appendices –
District 1 Memo

District 2 Memo

District 3 Memo

Community-Wide Memo

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Memo
Date: April 2, 2025

Re: District 1 Visioning Workshop Engagement Summary

The District 1 Visioning Workshop occurred on March 5 at the Northeast Community Center.
Approximately 30 community members attended. Feedback received at each station activity is
summarized below. A full visioning engagement summary will be developed at a later date.

Station 1: Vision Statement – One Word
Community members were asked to write down one word that describes their ideal future. The
themes were:
• Community • Walkable
• Resilient / Sustainable / Nature • Innovation
• Affordable

Station 1: Vision Statement – Statement Ranking
Community members were asked to rank three similar vision statements based off themes
found in the existing vision statement in the Comprehensive Plan. With 6 votes, vision
statement B received the most votes: “Spokane will foster livability, connectivity, and
resiliency throughout the city by balancing economic vitality, environmental stewardship,
and the diverse needs of residents, while cherishing its unique and vibrant neighborhoods.
The city will ensure access to safe and efficient mobility, attainable housing, natural
environments, and walkable neighborhood services to support a high-quality of life for all
residents.”

When asked what was missing from the sample vision statements, the themes were:

• Investment • Emphasis on non-personal vehicle
• All-age access transportation
• Engage / Active voice • Historic connections
• Open spaces access

Station 2: Commercial Preference
Community members were asked to identify which commercial types they wanted to see
throughout Spokane.

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Neighborhood corner stores/cafes received the most votes, with 14.

Mixed-use/ground-floor retail came in second, with 10 votes.

Restaurants came in third, with 9 votes.

Additional uses/considerations provided included:

• Gathering places / Community • Evening / weekend childcare
meeting spaces • Reuse of small-scale commercial
• Corner stores in walkable areas that’s currently vacant

Station 3: Your Spokane Mapping Exercise
Community members were asked to indicate where they currently live, work, and play in
Spokane. Participants indicated a wide array of areas in the city, showing geographic diversity
in living, working, and leisure activities. Despite the range, there were more people who live
in District 1. Downtown also contained a significant number of pins indicating work and
favorite places.

Comments received focused on initial thoughts about Spokane’s current needs:

• Hillyard needs transit • Need indoor aquatics facilities
• River access is priority • Lack of connectivity & services
• No good N-S bike route to E • West of Latah/Hangman has
Sprague equestrian activities

Station 4: Your Future Spokane Mapping Exercise
Community members were asked to think about the future of Spokane. Pins indicated a
desire for more local businesses in Chief Garry (Napa and Sprague), Bemiss, Northwest,
Balboa/South Indian Trail, Shiloh Hills, and North Indian Trail. More job opportunities were
desired in North Indian Trail/Balboa and South Indian Trail.

Additional uses/considerations provided included:

• Focus on vacant / underutilized • Community meet-ups / gathering
commercial, particularly in East spaces
Central and Chief Garry • Bakery in Hillyard
• More accessible commercial on • Jobs near schools for high
South Hill / Cliff Cannon schoolers
• Allow hotels in more areas, makes • More grocery stores, food deserts
short term rentals less desirable (North Hill)
• More historic activities in every • More dense middle housing
neighborhood balanced with open space, trees,
food gardens
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[Page 512]

• Safety concern for Mission bridge • Mixed-use on arterials
crossing • Recapture the spirit of Expo ’74
• Create a pedestrian friendly and create a community-side
downtown festival focusing on the river
• More trees, more food forests, • Healthy food / neighborhood
daylighting creeks grocery
• Expand commercial along freeway • Faster bus times
• More local businesses in all • North Indian Trail traffic calming
neighborhoods • Scattered site shelters

Station 5: Climate-Ready Spokane
Community members were asked to reflect on ways to increase resiliency within Spokane.
Suggestions included:

• Empower the community to adopt • Every bike lane should be a
lawn-less, water-less landscaping protected bike lane
• Incentivize low water lawns • Provide subsidies for people
• Bring back increased rates for high purchasing an e-bike / other
water users related purchases
• Advocate for shift away from • Ensure housing development
natural gas for homes incorporates non-vehicle
• Need more neighborhoods with transportation to reduce burden
lots of services and housing on roads
choices
Community members also mapped specific concerns or considerations on a map of the
City of Spokane:

• Fire danger and low fire response • What is planned for potential
in N Indian Trail / 5-mile prairie Yellowstone pipeline issues?
• Audubon / Downriver needs more • Need more trees in Bemiss, Logan,
bike/ped routes to services Mission, and the City in general
• Need community / neighborhood • Dead street trees need replaced
resiliency hubs • Need bike crossings at major
• Help people replace wood / vinyl intersections (e.g. Division / Ruby)
siding with more fire-resistant
materials

Station 6: What Did We Miss?
Community members were asked to document anything topic or theme that was missed,
or any additional comments they wished to provide. Those comments included:

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• All-age and all-ability usability of • Address existing car parking lots
the city and car dealerships in downtown /
• Solution for homelessness / urban underutilized land
camping • Not enough bus shelters and safe
• Security / safety bus stops
• Lighting for more public spaces to • Buffering between railroads /
increase safety freeways / industrial development
• Access to safe / attractive route to and residential
bike to the library, school, high- • Arterials as boundaries for
frequency transit route for all neighborhoods makes it harder to
housing advocate for better bike / ped
• Make downtown more pedestrian crossings on them (funding
friendly limiting within neighborhood
• City line is great, replicate and boundaries)
incorporate transit-oriented
development

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[Page 514]

Memo
Date: April 2, 2025

Re: District 2 Visioning Workshop Engagement Summary

The District 2 Visioning Workshop occurred on March 25 at the Liberty Park Library. Approximately 45
community members attended. Feedback received at each station activity is summarized below. A full
visioning engagement summary will be developed at a later date.

Station 1: Vision Statement – One Word
Community members were asked to write down one word that describes their ideal future. The
themes were:
• Accessible • Family-friendly
• Thriving • Cutting-edge
• Inclusive / Diverse • Safe / Clean
• Density • Creative
• Verdant / Sustainable

Station 1: Vision Statement – Statement Ranking
Community members were asked to rank three similar vision statements based off themes
found in the existing vision statement in the Comprehensive Plan. With 13 votes, vision
statement A received the most votes: “Spokane will support its vibrant and inclusive
neighborhoods by balancing livability, environmental stewardship, and economic vitality,
while cherishing its unique cultural and natural assets. The city will ensure safe and efficient
mobility, attainable housing, access to green spaces, neighborhood services, and a high
quality of life for all residents through planning and community partnership.” Vision
statement C had 12 votes.

When asked what was missing from the sample vision statements, the themes were:

• Commitment to expanding public • Retain the elements that
transportation / bike lanes distinguish neighborhoods from
• Safe street for pedestrians / each other
bicyclists • Commitment to not only trees, but
entire ecosystem

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[Page 515]

• Connection of Spokane to nature- • Access to nature
based building solution • Connected community / places to
• Improving health of residents gather
• Economic mobility

Station 2: Commercial Preference
Community members were asked to identify which commercial types they wanted to see
throughout Spokane.

Mixed-use/ground-floor retail received the most votes, with 32 votes.

Neighborhood corner stores/cafes came in second, with 28.

Restaurants came in third, with 18 votes.

Additional uses/considerations provided included:

• Public open space • Preservation of green space
• Small neighborhood grocery stores • Mixed-use neighborhood
• Parking with rooftop gardens • Ensure appropriate parking for all
• Family-friendly businesses uses
• Alleys – require for new
development, build new ones,
improve existing alleys

Station 3: Your Spokane Mapping Exercise
Community members were asked to indicate where they currently live, work, and play in
Spokane. Most participants indicated living in West Central / Chief Garry Park and south.
Downtown also contained a significant number of pins indicating work, as well as East
Central and Comstock. People’s favorite places were in nearby State park lands, downtown,
in local parks, and along the Centennial Trail / Spokane River.

Comments received focused on initial thoughts about Spokane’s current needs:

• Plan for traffic in Cliff-Cannon, • Pavement improvements along
Vinegar Flats, along 29th, and heavy traffic routes
generally within South Hill • Create partnerships to reduce
• Support natural environment of homelessness
Lincoln Park • Define what density means for
• Unpaved roads within Hillyard Spokane / avoid comparisons to
other cities

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[Page 516]

Station 4: Your Future Spokane Mapping Exercise
Community members were asked to think about the future of Spokane. Pins indicated a
desire for more local businesses in Northwest, North Hill, West Central, East Central, Lincoln
Heights, Cliff-Cannon, and Manito/Cannon Hill. More job opportunities were desired in
Northeast Spokane, downtown in Riverside, East Central, and West Central. Large retailers
were desired in downtown.

Additional uses/considerations provided included:

• Need more natural areas and • Mixed use in Lincoln Heights along
habitats in East Central 29th
• Neighborhood park needed in east • Create more indoor community
of Lincoln Heights activities during winter
• Mixed-use and arts development • What is the future plan for
in Comstock near 37th and Grand cemeteries?
• Support native habitat / bird • Reduce front-facing parking lots
habitat in Lincoln Heights along N Division St
• More transit routes / stops needed • Possibility of “tunneling” section s
in Vinegar Flats, Magnolia and 5th, of I90 to reduce separation of
and near MLK Center neighborhoods (e.g. between
• Neighborhood Center in lower Maple and Freya)
South Hill near 6th and 7th off
Maple
Station 5: Climate-Ready Spokane
Community members were asked to reflect on ways to increase resiliency within Spokane.
Suggestions included:

• Build more shade structures at • Provide electric car charging
parks and over play areas stations
• More covered bus stops • Ensure public transportation is
• Plant more trees accessible to all new development
• Incentivize meadow lawns / / treat public transportation like a
emphasize Water Wise efforts required utility

Community members also mapped specific concerns or considerations on a map of the
City of Spokane:

• Expand greenways for pedestrian • Cliff Cannon lacks bus service and
connectivity downtown considerations for commercial
• Use less water / partner with traffic
schools and community gardens to • Enforce watering restrictions
reduce water usage • Create more resiliency hubs
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[Page 517]

• Protect tree health • Increase recycling / reduce amount
• Improve access and mobility at of garbage burned
Lewis and Clark High School • Fire concern over Spokanescape
• Promote new infrastructure for encouraging wood mulch
clean electricity groundcover

Station 6: What Did We Miss?
Community members were asked to document anything topic or theme that was missed,
or any additional comments they wished to provide. Those comments included:

• Need more frequent and later bus • Support greater system of bike
times lanes and transit stops
• Keep park bathrooms open • Aesthetics of the built
• Create a plan to save assets e.g. environments – landscaping, art,
open space / habitat / water design, open space
resources • Narrow streets for slower and
• Install automated recycling at safer streets
WTEF to increase recycling to 66% • Photo enforced speed cameras
• Support more winter activities near District 2 public schools
within city limits • Support multi-family and mixed-
• Plan for water health / use development
conservation • Reduce parking
• Food policy • Increase sidewalk network

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[Page 518]

Memo
Date: April 3, 2025

Re: District 3 Visioning Workshop Engagement Summary

The District 3 Visioning Workshop occurred on March 27 at the Shadle Park Library. Approximately 37
community members attended. Feedback received at each station activity is summarized below. A full
visioning engagement summary will be developed at a later date.

Station 1: Vision Statement – One Word
Community members were asked to write down one word that describes their ideal future. The
themes were:
• Inclusive / Diverse / Welcoming • Dense
• Equity • Bike-friendly
• Sustainable / Green • Healthy
• Fun • Connected
• Welcoming • Affordable
• Thriving • Safe
• Livable • Attractive

Station 1: Vision Statement – Statement Ranking
Community members were asked to rank three similar vision statements based off themes
found in the existing vision statement in the Comprehensive Plan. With 12 votes, vision
statement B received the most votes: “Spokane will foster livability, connectivity, and
resiliency throughout the city by balancing economic vitality, environmental stewardship,
and the diverse needs of residents, while cherishing its unique and vibrant neighborhoods.
The city will ensure access to safe and efficient mobility, attainable housing, natural
environments, and walkable neighborhood services to support a high-quality of life for all
residents.” Statement A came in second with 9 votes.

When asked what was missing from the sample vision statements, the themes were:

• Support for arts and culture • Acknowledgement of Tribal
• Housing security sovereignty
• Food security • Conservation / preservation of
• Safety natural spaces

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[Page 519]

Station 2: Commercial Preference
Community members were asked to identify which commercial types they wanted to see
throughout Spokane.

Neighborhood corner stores/cafes received the most votes, with 27.

Mixed-use/ground-floor retail came in second, with 26 votes.

Restaurants came in third, with 10 votes.

Additional uses/considerations provided included:

• Senior housing (Audubon- • Greenway or walking path
Downriver, Northwest, Balboa, connection Division to Garland
South Indian Trail) District
• Reuse of history buildings prior to • Neighborhood grocery (e.g.
new development Downriver)
• Community spaces • Protected bike lanes

Station 3: Your Spokane Mapping Exercise
Community members were asked to indicate where they currently live, work, and play in
Spokane. Participants primarily indicated living, working, and playing within District 3
boundaries. However, participants also worked in downtown, in Chief Garry Park, and
Lincoln Heights in additional to concentration of employment in West Central. Favorite
places included downtown as well, in addition to areas along Northwest Boulevard, in North
Hill, and within natural areas like State park lands.

Comments received focused on initial thoughts about Spokane’s current needs:

• More walkability, bike-ability, and • Fire management needed
access to transit • Need transit access to natural
• Protected bike lanes areas
• Connect sidewalks and improve • Connect northern portions of
crossings on Northwest Boulevard Spokane to a bike network
• Ash and Grace bus stop is dangers throughout the city
for school students • Traffic considerations from new
• Need bus access to medical district housing in North Indian Trail
• Address high speed cars / traffic
calming
Station 4: Your Future Spokane Mapping Exercise
Community members were asked to think about the future of Spokane. Pins indicated a
desire for more local businesses throughout North Indian Trail, Balboa/South Indian Trail,

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[Page 520]

Northwest, Audubon/Downriver, West Central, Emerson Garfield, North Hill, and Nevada
Heights. More job opportunities were desired in Balboa/South Indian Trail along Indian Trail
Road and in North Hill. Large retailers were desired in North Hill.

Additional uses/considerations provided included:

• More industrial in the West Hills • Park in northeast corner of North
with a job focus Indian Trail
• Increased fire infrastructure in • Conversion of existing homes into
Latah Valley cafes / small businesses
• Small, locally owned grocery stores • Community gardens
throughout, in West Central • Yoga studio (North Hill)
• Various housing types within each • Main Street pedestrian mall with
neighborhood, including senior no cars downtown
housing • Incentivize use of land / do not let
• A walkable urban center for Shadle land sit unused / vacant
area with connections to the • Tall mixed-use development along
neighborhood Northwest Boulevard
• Pedestrian infrastructure along • Increase bus service (Routes 22
Northwest Boulevard and 23, Northwest Boulevard,
• Protective bike lanes connection Maple to Driscoll, throughout)
Garland / Monroe / Downtown • Make Northwest Boulevard more
walkable

Station 5: Climate-Ready Spokane
Community members were asked to reflect on ways to increase resiliency within Spokane.
Suggestions included:

• Increase frequency and number of • Support low water and other
transit routes Water Wise workshops
• Water usage – use non-potable • Invest in natural areas
water for irrigation, make it easier • Make neighborhoods more
to use rainwater, reduce lawn pedestrian friendly
watering, increase fees
Community members also mapped specific concerns or considerations on a map of the
City of Spokane:

• Transit access needed to • More frequent transit / support
recreational areas Bus Rapid Transit / consider light
• Create bike friendly routes on rail
Cedar Street from Francis to • Provide increased incentives for
downtown Spokanescape

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[Page 521]

• Prioritize pedestrian and • Fire mitigation along Sunset and
alternative transportation for all Peaceful Valley
development • Make Main Street pedestrian only /
• Northwest road resident with bike create pedestrian mall downtown
lanes • Safer bike routes in South Hill / to
• Create safe crossing points on SR Garland
291, current separates walking and • Protected bike lanes needed
biking pathways • More fire infrastructure in Latah
• Provide more “essential stores” Valley
such as groceries and pharmacies • Preserve natural areas around
in North Hill / Garland Thorpe area
• Crosswalks on Ash and Maple • Increase watering restrictions
• Connect Children of the Sun to • Consider land value tax
Centennial Trail • Drop city speed limit
• Increase tree plantings for canopy • Bike route to Northwest and
cover Driscoll

Station 6: What Did We Miss?
Community members were asked to document anything topic or theme that was missed,
or any additional comments they wished to provide. Those comments included:

• Planning for a large community • Improve greenways by
aquatics center incorporating traffic calming
measures

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[Page 522]

Memo
Date: April 2, 2025

Re: Community-Wide Visioning Workshop Engagement Summary

The Community-Wide Visioning Workshop occurred on March 12 at the Central Library. Approximately
50 community members attended. Feedback received at each station activity is summarized below. A
full visioning engagement summary will be developed at a later date.

Station 1: Vision Statement – One Word
Community members were asked to write down one word that describes their ideal future. The
themes were:
• Industries / Jobs • Vibrant
• Affordable • Multi Mobile / Good Public
• Walkable Transportation
• Safe • Robust
• Arts / Culture • Thriving
• Diverse • Access to Nature
• Resilient • Family-friendly
• Dense

Station 1: Vision Statement – Statement Ranking
Community members were asked to rank three similar vision statements based off themes
found in the existing vision statement in the Comprehensive Plan. With 9 votes, vision
statement B received the most votes: “Spokane will foster livability, connectivity, and
resiliency throughout the city by balancing economic vitality, environmental stewardship,
and the diverse needs of residents, while cherishing its unique and vibrant neighborhoods.
The city will ensure access to safe and efficient mobility, attainable housing, natural
environments, and walkable neighborhood services to support a high-quality of life for all
residents.” Statement A came in second with 5 votes.

When asked what was missing from the sample vision statements, the themes were:

• Pedestrian focus • Focus on ownership to build
• Community support (e.g. financial personal stability and wealth
literacy and housing classes) • Understood and defined solution
• Enforcement of laws to homelessness
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[Page 523]

• How to test the benefits of
proposed changes

Station 2: Commercial Preference
Community members were asked to identify which commercial types they wanted to see
throughout Spokane.

Neighborhood corner stores/cafes received the most votes, with 14. Comments indicated
a desire for this use in South Hill, Cliff Cannon, Minnehaha, West Hills, and around Maxwell.
Some community members noted a need for design standards with the use.

Mixed-use/ground-floor retail came in second, with 11 votes, with an emphasis of the use
in Neighborhood Centers, Downtown, and around Maple and Francis.

Restaurants came in third, with 5 votes. There was a desire for this use on East 5th Avenue
and along Mission Avenue.

Boutiques, convenience stores, groceries, and big-box stores all received 4 votes.
Mission and Napa, as well as Downtown, were noted as desired areas for those uses.
Downtown has an emphasis for groceries.

Additional uses/considerations provided included:

• Small scale hotels / lodging • Bike repair & rental
• Corner stores near housing, • “more of everything in Latah
grouped with other businesses, on Valley”
every corner “where it makes • Breweries
sense” • Retain existing businesses

Station 3: Your Spokane Mapping Exercise
Community members were asked to indicate where they currently live, work, and play in
Spokane. Participants indicated a wide array of areas in the city, showing geographic diversity
in living and leisure activities. Downtown contained a significant number of pins indicating
work. Favorite places included areas in State parks and other recreational areas, in
downtown, Manito Park, libraries, and community centers.

Comments received focused on initial thoughts about Spokane’s current needs:

• Create a hub on Northwest • Bus route needed near Riverview
Boulevard near Drive near Audubon/Downriver
Audubon/Downriver and and West Hills border
Emerson/Garfield border • Need more small grocery store
option in West Central

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[Page 524]

• Arts and culture events and places • Add retail / restaurants / mixed-
in West Central use in University District
• Infill development around 3rd

Station 4: Your Future Spokane Mapping Exercise
Community members were asked to think about the future of Spokane. Pins indicated a
desire for more local businesses in Chief Garry, Nevada Heights, Minnehaha,
Audubon/Downriver, Manito/Cannon Hill, East Central, and Latah/Hangman. More job
opportunities were desired downtown in Riverside. Large retailers were desired
downtown and Southgate.

Additional uses/considerations provided included:

• More retail in Whitworth • Attract more employees to
• More walkable bus routes downtown to support downtown
throughout city / Route 28 local businesses
• Small scale retail near and on Five • More businesses in western
Mile Prairie portion of Northwest
• Support and improve existing • Community gardens in East
development and infrastructure Central
• Encourage more use of transit / • More South Hill retail due to low
cycling / vanpools commercial vacancy
• Small retail “like Garland” • Opportunity for mixed-use and
throughout, in West Central pedestrian-oriented development
• Avoid convenience stores in Lincoln Heights
• Small / affordable grocery stores • Latah / Hangman needs centers /
throughout corridors to provide services

Station 5: Climate-Ready Spokane
Community members were asked to reflect on ways to increase resiliency within Spokane.
Suggestions included:

• Properties that use more water • Preserve green space in new
should pay more developments
• Do not require traditional • Support walkability with accessible
landscaping for new construction curb cuts, snow clearing
• Help get Spokane buildings off gas • Provide public education and
heat awareness around low-water
• Considerations for how much plants, landscaping, sustainable
water goes to Airway Heights choices

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[Page 525]

Community members also mapped specific concerns or considerations on a map of the
City of Spokane:

• Wildfire risk: Northwest and South • More trees in Hillyard / Northeast
• Make it easier to make Spokane
environment-friendly choices in • Conflict between street trees and
north and center city sidewalks
• Provide more green spaces and • Concern over wood mulch
permeable surfaces throughout promoted through Spokanescape
Division Street due to fire risk
• More density / housing in Five Mile • Citywide leaf pickup
Prairie • Bike friendly routes on Highway 2
• Francis / Maple / Ash difficult to
navigate via bike

Station 6: What Did We Miss?
Community members were asked to document anything topic or theme that was missed,
or any additional comments they wished to provide. Those comments included:

• No gentrification with growth • Preserve positives in Spokane,
• Need small neighborhood grocery don’t change
stores in downtown and in food • Increase transit access,
desert areas connectivity, and frequency
• Ensure continued development of between neighborhoods
East Central with green space and • Pedestrians and cyclist first
community gardens policies
• Grow Spokanescape program / • East / west transit connectivity
increased use of Spokanescape on • Rethink parking minimums
city-owned properties • More permeable surfaces
• Maintain good job of listening to • All-age use of the city, including
residents and departments bike lanes (design focused on all-
working together age use)
• Ensure changes are beneficial to • New sidewalks need planting strip
city at large, not just those heard to create pedestrian separation
from

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[Page 526]

PlanSpokane
Future Growth and Guiding Policies
Engagement Summary

December 2025

[Page 527]

Table of Contents

Background 3

Community Workshop Series 4

Station 1: Guiding Policies 4
Station 2: Displacement 5
Station 3: Land Use Schema 6
Station 4: Growth Alternatives 7
Station 5: Map Your Future Spokane – Mixed-Uses 8
Station 6: Map Your Future Spokane – Transportation 9
Station 7: Planning for Climate 10
Station 8: Developing Climate Policies 10
Station 9: Environmental Justice 11
Station 10: Prioritizing Climate Policies 12
Next Steps 12

Appendices 14

District 1 Memo
District 2 Memo
District 3 Memo
Community-Wide Memo
Workshop Posters

Future Growth and Guiding Policies Engagement Summary December 2025 2

[Page 528]

Background
As part of the PlanSpokane 2046 Periodic
Update to its Comprehensive Plan, the City of What is a Comprehensive
Spokane has been seeking public feedback on Plan?
the City’s next twenty years throughout 2025.
A Comprehensive Plan is the community’s
While regular updates to the Comprehensive
vision for how the city grows and invests. It
Plan have occurred, this will be the first
is mandated by state law requiring a “road
substantial update since the Comprehensive map” for fast-growing cities, known as the
Plan was first adopted in 2001. With the Growth Management Act. Spokane must
significant population growth and changing local have a Comprehensive Plan to manage
factors Spokane has experienced since then, population growth, with goals that include
this update provides the community with an reducing sprawl, supporting efficient
opportunity to reevaluate how they want the multimodal transportation, protecting the
City to grow. The goals of this update are to meet environment, and many more.
all state legislative requirements adopted since The Comprehensive Plan establishes a vision
2017, incorporate community input around for the city – looking at a horizon of twenty
changing needs and wants, and to streamline years. It guides implementation through
the Plan to make it more user friendly. Capital projects, City programs, and
regulations.
Being the first substantial update since 2001, the
City of Spokane has determined that this
proposal is likely to have a significant and potentially negative impact on the environment. As such,
an Environmental Impact Statement (EIS) is required under RCW 43.21C.030 (2)(c) and will be
prepared as part of the PlanSpokane 2046 effort. The first step of the EIS process is known as
“scoping”. Both before and during the scoping comment period, the City of Spokane Department of
Planning and Economic Development provided opportunities for the community to be engaged in
the process of identifying the future vision for Spokane’s next twenty years. The Community
Visioning Engagement Summary provides a recap of the feedback heard.

Once the overall vision for the future is determined, the next step of the EIS process is to evaluate
different ways the City can meet that vision while also accommodating future growth. To that end,
the City of Spokane held a community workshop series on future growth and guiding policies in
November 2025 for initial feedback on different ways the City of Spokane can grow, as well as the
goals and policies to get us there.

More information about the PlanSpokane 2046
Periodic Update can be found at PlanSpokane.org

Future Growth and Guiding Policies Engagement Summary December 2025 3

[Page 529]

Community Workshop Series
At the beginning of 2025, community members provided invaluable feedback to create a 20-year
vision for the City of Spokane. Since then, there has been ongoing work to identify different ways to
reach that vision. To present the community with those options on how the City can grow, and
receive feedback on goals and policies, a community workshop series on future growth and guiding
policies was held in November 2025. One workshop was held in each City Council District, with one
community-wide workshop held downtown. Over
100 individuals attended one or more of the
workshops, providing valuable feedback to help
shape the future of the City of Spokane.

These in-person workshops included discussion,
mapping exercises, and feedback opportunities
related to various aspects of the Comprehensive
Plan, including the new element of climate and
resiliency. Each station sought reactions and
comments on how community members wanted
to shape the next twenty years. Kids activities and
Figure 1. Community members participate in the District 1 catered food was also available.
Community Workshop.

Station 1: Guiding Policies

After learning more about the PlanSpokane 2046 Periodic Update and Environmental Impact
Statement process through informational posters, the first activity station revolved around the
policies of the Comprehensive Plan and the current Chapter Review process. Community members
were asked to identify what topics they want to make sure are addressed in the updated
Comprehensive Plan to help identify potential gaps in the currently proposed amendments.

Themes from the four community workshops include:

Accessibility (housing, public spaces, “sittable” Address employment and job creation
neighborhoods)
Incentives to revitalize vacant properties More “third places” for community
connection
Bikeable streets, including protected bike lanes Levels of service for fire safety
Art districts Daycare centers and support
Address land speculation Creating neighborhood identities
Indoor swimming pools More greenways and trails
Incentives for affordable and mixed-use Greater civic engagement, involvement, and
housing transparency

Future Growth and Guiding Policies Engagement Summary December 2025 4

[Page 530]

Conservation/migration corridors and natural Create/support quality and beautiful places
playgrounds to live
Reduced dependency on single occupancy Support for unhoused residents, including
vehicles work programs
Context sensitive design standards Sidewalk and pedestrian safety
Allow for more mixed uses in neighborhoods Coordination of road construction to
to support walkability, create local “hubs” prevent multiple roadway maintenance in
the same direction

Station 2: Displacement

As part of the PlanSpokane 2046 Periodic Update to the Comprehensive Plan, the City of Spokane
has completed analysis on racially disparate impacts and displacement risk to meet state legislative
requirements (HB 1220). After being presented with the
three different types of displacement – physical,
economic, and cultural – community members were
asked to help brainstorm causes of housing and small
business displacement, as well as how the City of
Spokane could address those causes.

Causes identified included high housing costs and lack
of housing inventory to keep up with population
increases, mobile home parks being replaced,
businesses leaving and/or not having patrons due to
perception of safety or vandalism, lack of inclusive
and accessible transit and public spaces, impact of
taxes, buildings being demolished for parking lots or
shopping centers, vacant or underutilized lots, increase
in housing costs due to surrounding development,
lack of pedestrian infrastructure, high insurance
costs/losing property insurance due to wildfire risk,
Figure 2. City of Spokane Displacement Risk Map from the
corporate rental ownership, and climate risks (heat, Racially Disparate Impacts Analysis Report (2025).
lack of trees).

Potential actions to address the causes included streamlining permit processing, the City being
involved in public housing development, replacing existing housing with affordable multi-
family housing, create supportive zoning before development is expected to occur, wildfire risk
mitigation (to address insurance issues), rental costs management, increase transportation
options (pedestrian friendly streets/bus routes/road access), and support community resiliency
to climate hazards.

Future Growth and Guiding Policies Engagement Summary December 2025 5

[Page 531]

Station 3: Land Use Schema

One aspect of the PlanSpokane 2046 Periodic Update includes updating the land use schema for
the City of Spokane, with the goal of reducing the number of land use categories. Land use is
essentially what kinds of uses can be built where, and community members were asked to provide
feedback on the proposed land use categories: Urban Agriculture, Residential Low, Residential High,
Commercial, Centers & Corridors, Institutional, Downtown, Industrial, and Open Space. Community
members were asked what uses they would like to see in each proposed land use and where they
should be located.

Urban Agriculture
• Allow flower growers, small vegetable and fruit farmers market-style food production
• Locate to avoid impacts of potential pesticides
• Preserve agriculture in the city by only allowing agricultural uses

Residential Low
• Ensure there is human-scale and human serving design, walkable third places, a transition
between low- and high-density areas, and that the scale of residential and commercial
uses match
• Allow parking, community gardens, small mixed uses (cafes, ice cream parlors, bookstores,
medical uses like a dentist), indoor community pools, community gathering spaces, and
professional offices
• Do not allow gas stations
• Create a process of neighborhood input on project-by-project basis for non-standard uses
• Develop incentives for neighborhood businesses
• Prioritize adaptive reuse over new development
• Locate near centers and corridors and other high intensity uses

Residential High
• Ensure accessible housing (no stairs)
• Expand into existing lower scale residential, such as near transit or in close proximity to
amenities
• Have a minimum density

Commercial
• Expand mixed uses
• Leverage vacant commercial areas to add business or apartments
• Establish zoning requirements for gas stations/convenience stores related to sober living
and other affordable housing services

Centers & Corridors
• Allow multi-unit housing and trade/live-work makerspaces
• Do not allow drive throughs, gas stations, convenience stores, hostile architecture, or
single-unit homes

Future Growth and Guiding Policies Engagement Summary December 2025 6

[Page 532]

• Locate throughout Division once NS Corridor is complete and traffic reduces

Downtown
• Allow taller buildings and larger business spaces

Institutional
• Incentivize apartments
• Allow community pools

Industrial
• Encourage adaptive reuse of existing spaces

Open Space
• Allow undeveloped/natural parks with trails, mountain biking, indoor community pools
• Ensure enough parks/trails for those living in dense areas/apartments to have outdoor
access, as well as accessible open spaces
• The full length of the Spokane River should be a public park
• Prioritize passive natural spaces

Station 4: Growth Alternatives

A significant result of the PlanSpokane 2046 Periodic Update and Environmental Impact Statement
will be the selection of a Preferred Alternative – the desired direction for growth and prioritization
for the City of Spokane’s next twenty years. To identify that
Preferred Alternative, the City must study different Growth
Alternatives, which are different ways to address population
growth, economic goals, and the community vision. More detailed
analysis and comparisons will be available during the Draft
Environmental Impact Statement public comment period
expected to kick off in December 2025. This poster station allowed
for an initial reaction to the potential options.

Community members were presented with the three Growth
Alternatives being evaluated as part of the PlanSpokane 2046
Periodic Update process. Alternative 1 (Stay the Course)
Figure 3. Community members participate in the represents the current growth strategy. To address recent state
District 2 Community Workshops.
legislation, Alternative 2 (Distributed and Balanced) and
Alternative 3 (Center City and Regional Hubs) were developed out of earlier visioning and scoping
engagement. After reviewing the proposed maps and a snapshot of environmental impact
evaluation comparisons between the three alternatives, community members were asked to vote
on their preferred growth strategy.

Future Growth and Guiding Policies Engagement Summary December 2025 7

[Page 533]

Alternative 2 received the most votes with 25. Alternative 3 came in second with 7 votes. One
vote selected a middle ground between Alternative 1 and Alternative 2. Alternative 1 did not
receive any votes (presumably due to community understanding that it does not meet all state
legislative requirements).

Rather than voting for a specific Alternative, most community members provided comments on the
City of Spokane’s future growth. The Preferred Alternative can be a combination of elements of the
different Growth Alternatives, with these comments providing direction on what aspects were
viewed positively from each alternative.

In general, community members liked the interconnectedness of Alternative 2, but also saw the
benefit of the Center City focus of Alternative 3 on businesses, community safety, and more
housing. Full comments can be found in the workshop-specific memos in the appendix of this summary.

Station 5: Map Your Future Spokane – Mixed-Uses

Through a mapping exercise where different color pins represented different types of mixed-use
designations, community members were asked to identify where they thought different sizes and
scales of mixed-use development should be located throughout the City.

Figure 4. Mixed-use descriptions provided for the Map Your Future Spokane exercise. A higher resolution image can be found in the Workshop Posters
appendix.

In general, MU-TOD was located along Division/Ruby, Market Street, Mission Avenue, North
Monroe, near Shadle Library on Wellesley, in parts of downtown and Cliff-Cannon, Hamilton and
the northernmost portion of Nevada Street, and in areas along 29th.

MU-1 was located in Hillyard, Nevada Heights just east of Division, the middle of Cliff-Cannon, north
Five Mile Prairie, in parts of Audubon/Downriver and West Central, between Northwest and
Balboa/South Indian Trail, North Monroe, near Shadle Library on Wellesley, and downtown.

MU-2 was located in Nevada Heights, the middle of Bemiss, adjacent to Chief Garry Park within the
Chief Garry Park neighborhood, the northwest corner of Manito/Cannon Hill, north of Comstock,
Shiloh Hills, Northwest, North Hill, along Indian Trail Road, and in areas along 29th.

MU-3 was located in the middle of Hillyard and Bemiss, multiple locations in Cliff-Cannon, on West
Sunset Boulevard, Audubon/Downriver, Northwest, and along the edges of Manito/Cannon Hill.

Future Growth and Guiding Policies Engagement Summary December 2025 8

[Page 534]

Additional comments about mixed-uses included:

Provide more uses in proximity to housing to Trade and makerspaces in West Central
reduce distance/need for transportation
There’s currently a lack of affordable and larger Mobility connectivity for all modes in East
retail near neighborhoods, not just small Hillyard is a local priority
No more drive throughs MU-2 should be everywhere
More intensity along arterials, transition to No mixed-use in neighborhoods, concerned
higher commercial, and then allow residential over exploitative development
Need a Latah-Cannon Corridor Plan to address Need parks and trails in Hillyard
traffic, 195 and I-90 ramp
More health and transportation access in West Designated business district/center/corridor
Central down east Broadway of West Central
Encourage trades academy Support the creation of 24-hour daycare
Increase pedestrian/bike infrastructure along Create protections against displacement in
Northwest Boulevard Chief Garry Park around City Line stops,
including increasing resources for community

Station 6: Map Your Future Spokane – Transportation

Through a mapping exercise to indicate preferred development types and street upgrades,
community members were asked to identify what type of street improvements they want to see
along major transit stops, with street trees and greater connectivity being consistent themes. Full
summaries can be found in the workshop-specific memos in the appendix of this summary.

District 1 District 2

Future Growth and Guiding Policies Engagement Summary December 2025 9

[Page 535]

District 3 Citywide

Station 7: Planning for Climate

Another significant component of the PlanSpokane 2046 Periodic Update is the integration of
climate and resiliency policies into the Comprehensive Plan to align with recent state legislation.
Climate Planning efforts have been ongoing, with this workshop series providing an opportunity to
bring all elements of the update together for community input. Workshop attendees were first
asked to identify what actions they want the City of Spokane to take to support local climate
resiliency.

Key themes from the feedback include tree canopy expansion and protection; resilient and
equitable development; climate resilience education and community engagement; water
conservation and quality; energy efficiency and weatherization; reducing car reliance; air
quality and pollution reduction; fire safety and mitigation; access and preservation to natural
spaces; and housing and infrastructure.

Station 8: Developing Climate Policies

In order to help develop climate and resiliency policies, community members were presented with
top themes heard throughout the earlier phase of climate planning engagement, including wildfire
smoke and extreme heat, water conservation, human health, food systems, tree canopy and green
spaces, transportation and infrastructure, education, collaboration, and financial barriers. With
those in mind, participants were then asked to identify any other topics of importance.

Future Growth and Guiding Policies Engagement Summary December 2025 10

[Page 536]

Topics identified include:

Address financial barriers Food security
Do not exclude businesses from Local community solutions to address climate
SpokaneScape program hazards and resiliency
Greater bike infrastructure and connectivity Impact of Artificial Intelligence
Increased shade Water conservation
Convert unused city property to green spaces Walkable neighborhoods
Indoor spaces to escape to during weather More resources directed to conservation
extremes programs
Trees and native landscaping, including Support creation of more efficient building
potential for fruit trees as street trees construction
Balance between infill development and trees Active role of City in tree planting programs
Green infrastructure/swales Education programs to support local resiliency
Mental and physical health Intersection of natural and built environment
Protect mature trees and iconic basalt rocks Increase accountability, including for
businesses
Require parking Maintenance of street trees
Incentives for tree planting in the north of the Weatherization/support new windows for
city historic homes
Recognition of limits to growth “Dead internet” greenhouse gas emissions
Restrict wood burning fireplaces to improve air Adjust development requirements to allow
quality more room for trees
Growth numbers should consider possibility of Faster and cheaper transit (including through
climate refugees bus-only lanes and in Latah Valley)

Station 9: Environmental Justice

Environmental justice, as defined by state law,
means the fair treatment and meaningful
involvement of all people regardless of race, color,
national origin, or income with respect to
development, implementation, and enforcement
of environmental laws, regulations, and policies. It
includes addressing disproportionate health and
environmental impacts. Community members
were presented with the definition and ways to
assess environmental justice, in order to support Figure 5. Community members participate in the District 3 Community
state required policies within the Comprehensive Workshops.

Plan.

Workshop attendees were then asked to provide ideas on how the City of Spokane can support
environmental justice. Key themes included supporting a safe and connected transportation

Future Growth and Guiding Policies Engagement Summary December 2025 11

[Page 537]

system that does not rely on single-occupancy vehicles, targeting heat mitigation and resiliency
to vulnerable populations, expanding green infrastructure and tree canopy, neighborhood
investment without displacement, and City-funded resiliency investments that support
impacted neighborhoods and communities.

Station 10: Prioritizing Climate Policies

In addition to identifying potential climate and resiliency policies, the climate planning effort will
include a prioritization process, which will help ensure that selected policies can be implemented
and align with state requirements. Presented
with the options of Resilience, Equity, Climate
Pollution Reduction, Logistics, and Risk,
community members were asked to identify
the criteria they believed should be weighted
more heavily than others.

Resilience came in first, with 21 votes,
followed by Equity (16 votes) and Climate
Pollution Reduction (15 votes). Logistics
received 8 votes, while Risk had a total of 4
Figure 6. Community members participate in the Citywide Community
Workshops. votes.

In addition to what was listed, community members were then asked to identify any other criteria
that should be considered:

Build equity into each criterion Legislative control to create solutions
How to reduce homelessness/outdoor Prioritize policies with City action rather than
sleeping to make people less vulnerable informational or “encouraging” resident action
Emphasize natural environment as a Without resilience, we will have a hard time
component of resilience criteria delivering on the other policies
Improvement to tree canopy Clear out underbrush in fire risk areas
Inequitable impact of policy Banning of wood burning fireplaces
Balancing costs and benefits to ensure Spreading out of affordable housing, “stop
prospective business ventures aren’t impacted consolidating poverty”
Tighten controls on vehicle emissions Allowing for shelters near services

Next Steps
Feedback received during the community workshops on future growth and guiding policies will
inform amendments to goals and policies in the Comprehensive Plan, as well as discussion around
the chosen growth strategy (or Preferred Alternative) for Spokane’s next twenty years. Community
members will have the opportunity to take a deeper dive into the details of and comparisons

Future Growth and Guiding Policies Engagement Summary December 2025 12

[Page 538]

between the Growth Alternatives after the release of the Draft Environmental Impact Statement
(EIS) in December 2025, which will include a formal public comment period. More information about
the Draft EIS will be available at PlanSpokane.org upon release. Final adoption of the PlanSpokane
2046 Comprehensive Plan is expected in the later part of 2026.

Figure 7. PlanSpokane 2046 process timeline

Community feedback will be accepted throughout the entire PlanSpokane 2046 process, from
helping select the Preferred Alternative to weighing in on proposed goals and policies of the
Comprehensive Plan.

We invite your participation:

• Visit the project webpage at PlanSpokane.org to learn more about the planning process
• Learn more about the Climate Planning efforts at my.spokanecity.org/climateplanning
• Subscribe to the PlanSpokane monthly newsletter to receive timely updates
• Attend future meetings and hearings hosted by the City of Spokane
• Provide written comments or ask questions to the Planning team by emailing
PlanSpokane@spokanecity.org

Future Growth and Guiding Policies Engagement Summary December 2025 13

[Page 539]

Appendices –
District 1 Memo

District 2 Memo

District 3 Memo

Community-Wide Memo

Workshop Posters

Future Growth and Guiding Policies Engagement Summary December 2025 14

[Page 540]

Memo
Re: District 1 Future Growth and Guiding Policies Community Workshop

The District 1 Future Growth and Guiding Policies Community Workshop occurred on
November 12, 2025 at Yasuhara Middle School. Approximately 22 community members
attended. Feedback received at each station activity is summarized below. A full
engagement summary of the workshop series will be developed at a later date.

Station 1: Guiding Policies
Community members were asked to write down what topics they want to make sure are
addressed in the Comprehensive Plan to help identify potential gaps in the proposed
amendments:

• Move civic engagement
• More districts for city council members
• More government transparency
• Incentives for empty properties on Division following BRT implementation
• More third places
• Continue partnerships with housing services and neighborhood councils
• Bikeable streets.

Station 2: Displacement
After being told about three different types of displacement (physical, economic, and
cultural), community members were asked what causes to housing and small business
displacement are they most concerned about. Additionally, how could the City address
them?

The comments included:

• Consider the impacts of housing costs because of Division BRT.
• Get ahead of zoning along the corridor for middle/multi-unit housing.

Station 3: Land Use Schema
Community members were asked to provide feedback on proposed land use designations
to implement the future growth of the Spokane. Specifically, they were asked what uses
Page | 1

[Page 541]

should be allowed in the different land uses and were should the land use be located.
Participants reflected on the following land uses:

• Residential Low:
o Allow professional office
o Allow MU-3 uses (like The Scoop)
• Residential High:
o Have minimum density
• Centers and Corridors:
o Do not allow single-unit homes
• Open Space:
o Include intentional passive recreation

Station 4: Growth Alternatives
Community members were presented with the three Growth Alternatives being evaluated
as part of the PlanSpokane 2046 Periodic Update process. Alternative 1 (Stay the Course)
represents the current growth strategy. To address recent state legislation, Alternative 2
(Distributed and Balanced) and Alternative 3 (Center City and Regional Hubs) were developed
out of earlier visioning and scoping engagement. After reviewing the proposed maps and a
snapshot of environmental impact evaluation comparisons between the three alternatives,
community members were asked to vote on their preferred growth strategy. Alternative 1
received 0 votes, Alternative 2 received 5 votes, and Alternative 3 received 1 vote.

Participants who did not fully prefer one alternative over another, as well as those who did
make a selected, were asked to identify their likes and dislikes of potential growth options,
as well as other considerations for future growth. Those comments included:

• Evacuation routes need for Latah around gathering places (e.g.
Valley area/Vinegar Flats arena).
• Distribute growth to remove silos • Build up, two story buildings waste
between neighborhood and land potential
connected the community. • Have services in all areas of the
• Capitalize on larger roads to city.
connect centers and places people • Lack of ability to make left turns on
visit Division can cause vacant lots/lack
• Address Division BRT fully in Alt. 2 of businesses/patrons.
and 3. • Alternative 2 seems to be a natural
• Require parking for large housing approach to what will likely occur
developments to be located within naturally.
garages/parking structure. • Vinegar Flats has a potential for
• Turn parking lots into garages for a job growth (mini Hillyard).
better use of land, especially

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[Page 542]

• Vinegar Flats is separate from • Build up, not out; focus on
Latah Valley area and should be downtown and where growth
treated as having different already exists.
potential • Base Latah Strategy on
infrastructure findings for
connectivity.

Station 5: Map Your Future Spokane – Mixed-Uses
Through a mapping exercise where different color pins represented different types of mixed-
use designations, community members were asked to identify where they thought different
sizes and scales of mixed-use development should be located throughout the City. In
general, respondents wanted respondents wanted MU-TOD along Division; MU-1 in Hillyard,
Nevada Heights just east of Division, and in the middle of Cliff-Cannon; MU-2 in Nevada
Heights, the middle of Bemiss, adjacent to Chief Garry Park within the Chief Garry Park
neighborhood, the northwest corner of Manito/Cannon Hill, and the north of Comstock; MU-
3 in the middle of Hillyard and Bemiss, the southeast corner of Bemiss, multiple locations in
Cliff-Cannon, and along the edges of Manito/Cannon Hill.

In addition to pin placement, addition comments included:

• Make transportation less required (most uses in close proximity to households)
• Lack of affordable and larger retail near neighborhoods, highlighting Bemiss
• Mobility connectivity for all modes in East Hillyard is a local priority

Station 6: Map Your Future Spokane - Transportation
Through a mapping exercise that included stickers that indicated preferred development
types and street upgrades, community members were asked to identify what type of street
improvements and destinations they want to see along major transit stops throughout
Spokane. In general, community members indicated wanting improved crosswalks and
wider sidewalks along Northwest Boulevard; street trees, lighting and faster bus times
around Vinegar Flats; improved crosswalks Downtown; more street trees on Market Street;
separated bike lanes, improved crosswalks, lighting, and bus shelters along Division between
the Ruby interchange and Wellesley; lighting and wider sidewalks in the Logan
neighborhood, south of Wellesley; and improved bike connections and faster bus times in
Hillyard.

In addition to sticker placement, addition comments included:

• Better crosswalks on Wellesley at Driscoll Boulevard
• Better lighting along bus routes including Route 28
• Hays Park needs sidewalks
• Bus shelter at Bridgeport and Glass

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[Page 543]

• Improve crosswalks at Glass
• Need a bus route on Freya in Wellesley area
• Fix Hairball intersection at Main/Monroe/Spokane Falls
• Pedestrian bridge is needed on Rowan to cross NSC
• Bridgeport near Division, people park half on sidewalk and half on street
• Fire access at Euclid into Minnehaha needs to be improved

Station 7: Planning for Climate
Community members were asked to identify what actions they want the City of Spokane to
take to support local climate resiliency. Those comments included:

• Facilities and accommodations for • More sidewalk connectivity.
dogs/pets. • More spending on education on
• More shade on sidewalks. water usage information.
• Reduction of VMTs through denser • Removed trees need to be
housing and more walkability. replanted in that area (not
• Locally fund ore SpoCanopy. elsewhere in the City).
• Increase LOS for active • Areas with lower tree canopy need
transportation, reduced LOS for higher tree requirements.
cars. • More lawn alternative promotion,
• More shade on trails and bus not just SpokaneScape.
stops. • New Hillyard there are big oil tanks
• Non-shaded areas and sidewalks that burp oil smells into homes,
are a burn risk for kids (toys, cause air quality issues.
slides, etc.). • Make the things that have and
• Water conservation should not be have not worked known; tell
focused just on residents. residents about known issues.
• More fuel reduction in WUI areas. • More mail fliers of education, not
• Continue tree canopy program. just online.
• More QR codes around town (like • More education on fire wise and
parks) so people can get fuel reduction programs the City is
connected to information. already doing.
• Less black asphalt that raises heat, • Install solar panels over parking
more white concrete. lots.

Station 8: Developing Climate Policies
In order to help develop climate and resiliency policies, community members were
presented with top themes heard throughout the earlier phase of climate planning
engagement. With those in mind, participants were then asked to identify any other topics
of importance:

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[Page 544]

• Trees:
o Require in new development
o Leave existing trees in new development
o Active City involvement in tree planting (don’t require residents to request
trees, ask them if they want trees)
• Oversight of street trees to support maintenance and growth to ensure trees live
• Swales

Station 9: Environmental Justice
Community members were presented with the definition and ways to assess environmental
justice, in order to support state required policies within the Comprehensive Plan.
Participants were then asked to provide ideas on how the City of Spokane can support
environmental justice:

• Connect bicycle network and make e-bike traffic less dangerous.
• Expand the transportation network for bike and pedestrian connectivity.

Station 10: Prioritizing Climate Policies
In addition to identifying potential climate and resiliency policies, the climate planning effort
will include a prioritization process. Community members were asked to identify the top
criteria they believed should be weighted more heavily than others. Resilience received
1vote, Equity received 1 vote, Climate Pollution Reduction received 1 vote, Logistics received
1 vote, and Risk received 1 vote.

Community members there then asked to identify any other criteria that should be
considered:

• Prioritize policies with city action rather than informational or “encouraging” resident
action.
• Improvement to tree canopy (increase oversight and assistance, reduction of water
costs to water trees, tree health support)

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[Page 545]

Memo
Re: District 2 Future Growth and Guiding Policies Community Workshop

The District 2 Future Growth and Guiding Policies Community Workshop occurred on November 5,
2025 at Ferris High School. Approximately 40 community members attended. Feedback received
at each station activity is summarized below. A full engagement summary of the workshop series will
be developed at a later date.

Station 1: Guiding Policies
Community members were asked to write down what topics they want to make sure are
addressed in the Comprehensive Plan to help identify potential gaps in the proposed
amendments:

• Don’t use broad terms in Comprehensive Plan
• Levels of service, especially for fire

Station 2: Displacement
After being told about three different types of displacement (physical, economic, and
cultural), community members were asked what causes to housing and small business
displacement are they most concerned about. Additionally, how could the City address
them?

The comments included:

• Affordable Housing • Tree desert/heat island in certain
• Address vandalism to support neighborhoods
businesses • Increase tree canopy
• Concerned about gangs for both • Codes that require solar cooling
housing and small businesses • Control rents
• Lack of pedestrian infrastructure • Increase bus routes
and transit • Create more pedestrian friendly
• High insurance for homes in the streets
WUI, mitigate wilfire risk • Build roads before new
• Corporate rental ownership development
• High housing costs

[Page 546]

• Losing property insurance • City should work with the State on
housing costs and insurance loss

Station 3: Land Use Schema
Community members were asked to provide feedback on proposed land use designations
to implement the future growth of the Spokane. Specifically, they were asked what uses
should be allowed in the different land uses and were should the land use be located.
Participants reflected on the following land uses:

• Urban Agriculture:
o Preserve, no other use allowed.
• Residential Low:
o Allow businesses catered toward people walking
o Allow neighborhood input on a project-by-project level for other uses
o Allow coffee shops, gathering spaces, and bookstores
o Develop incentives for neighborhood businesses
o Prioritize historic/adaptive reuse over new development (both commercial
and residential)
o Commercial and residential can coexist as long as the scale and auto vs
pedestrian uses match each other in intensity.
o Locate near centers and corridors and other high intensity uses.
• Commercial:
o Zoning requirements for gas stations and convenience stores related to
sober living and other affordable housing services.
• Centers and Corridors:
o Do not allow drive-thrus, gas stations or any other auto-oriented uses.
• Open Space:
o Should include parks and natural open space.
o Preserve open space.
o Protect trees during development, including on private property.

Station 4: Growth Alternatives
Community members were presented with the three Growth Alternatives being evaluated
as part of the PlanSpokane 2046 Periodic Update process. Alternative 1 (Stay the Course)
represents the current growth strategy. To address recent state legislation, Alternative 2
(Distributed and Balanced) and Alternative 3 (Center City and Regional Hubs) were developed
out of earlier visioning and scoping engagement. After reviewing the proposed maps and a
snapshot of environmental impact evaluation comparisons between the three alternatives,
community members were asked to vote on their preferred growth strategy. Alternative 1
received 0 votes, one vote was cast for a middle option between Alternative 1 and Alternative
2, Alternative 2 received 6 votes, and Alternative 3 received 2 votes.

[Page 547]

Participants who did not fully prefer one alternative over another, as well as those who did
make a selected, were asked to identify their likes and dislikes of potential growth options,
as well as other considerations for future growth. Those comments included:

• Direct growth to • High intensity housing can be
Garland/Perry/Downtown/areas isolating, community hubs are
already with growth and not within needed.
neighborhoods with limited • Increase housing downtown; get
parking and emergency access. more people visiting downtown.
• Direct growth away from mature • Locate mix-use along NS Corridor
trees and rock formations. interchanges.
• Distributed housing and • Address Airway Heights growth
transportation needed. impact on access to water.
• Alternative 2 & 3 should both focus • Concerns over Division traffic and
on TOD and increased affordable conflict of businesses, curb cuts.
housing. • Infrastructure needs to be in place
• Large subdivisions should have before continuing to allow new
traffic lights to exit to development (Freya Lower South
accommodate surrounding Hill highlighted).
growth. • More mixed-uses everywhere; less
• Duplexes built and sold as areas with single uses.
duplexes are not selling/not • Locate employment and industrial
affordable; concerns over uses on edges of the city.
affordable housing in alternatives. • Provide/expect commercial uses to
• Parking requirements should be 1 pop up around employment.
space per unit. • Provide more attractions; things
• Need safe crossings to bus for groups/teens to do together.
stops/park and rides.

Station 5: Map Your Future Spokane – Mixed-Uses
Through a mapping exercise where different color pins represented different types of mixed-
use designations, community members were asked to identify where they thought different
sizes and scales of mixed-use development should be located throughout the City. In
general, participants had few locations they wanted mixed-uses to be located. However, MU-
TOD was identified for Market Street, North Monroe, and portions of Ruby. MU-3 was
identified on West Sunset Boulevard.

In addition to pin placement, addition comments included:

• MU-2 should be everywhere.
• No neighborhood businesses, there is no parking.

[Page 548]

• No Latah-Cannon Corridor plan; all the traffic, no plan.
• No mixed use in neighborhoods, protect neighborhood from exploitive
development.
• Want to see more intensity at arterials, then higher commercial, and finally
residential.
• Want a transportation plan for Cliff-Cannon; there’s no future plan considering 195
and I-90 ramp.

Station 6: Map Your Future Spokane - Transportation
Through a mapping exercise that included stickers that indicated preferred development
types and street upgrades, community members were asked to identify what type of street
improvements and destinations they want to see along major transit stops throughout
Spokane. In general, community members indicated wanting street trees along Ruby and
Division, as well as downtown; improved bike connections north of Francis Avenue in the
northwest, in South Logan at Mission and Hamilton, near Spokane Community College, and
near Ray Street, Regal, and other areas in South Spokane; separate bike lanes at Wellesley
and Driscoll Boulevard, within Latah Valley, and in various locations near downtown and just
south of I-90 in the southwest; bus route improvements near Vinegar Flats and within Latah
Valley; bus shelters throughout Latah Valley and on Ray Street; speed management along
Grand Boulevard; and new and improved crosswalks throughout the southwest. Additional
improvements, largely in in the southwest, include emergency services, improving bridges,
new sidewalks, fixing of roads, lighting, and new intersection.

Station 7: Planning for Climate
Community members were asked to identify what actions they want the City of Spokane to
take to support local climate resiliency. Those comments included:

• Create trails that are more like dog • Create urban public garden inside
parks parks
• Support engaged and active • Encourage TOD
citizenry for resiliency • Encourage safe streets for bikes
• Expand safe bike and walking to and pedestrians; protected bike
grocery stores lanes, more crosswalks
• Responsible and equitable • Expand bike in infrastructure
development • More walkable neighborhoods (i.e.
• Increase density and make it 29th and Grand area
easier for residents to do that • Canon area lost lots of trees, not
themselves replanted by new development
• More trees and shade along trails • People drink PFAS and then it
• Ban wood burning fireplaces moves through sewer pipes and
treatment

[Page 549]

• Sewer infrastructure in Canon is • Maintain our strong tree canopies
old and breaks often • Need more protected bike lanes
• Lack of parking becomes a safety • Extend existing bike lanes, don’t
and resiliency issue just stop the bike lanes suddenly
• Incentivize more tree canopy in • Development should not remove
lower areas but maintain aging trees, plants, and Spokane’s
tree canopy (especially in aging distinct environment
demographics) • Rain retention facilities
• Water quality of PFAS in mystic requirements should be stronger
falls/garden spring due to • Bike lanes with multiple lines helps
development enforce walking
• More dense development so there • Ensure social capital is created
is less cross through traffic to during development
sprawling suburbs • Green roofs
• Enable neighborhoods to create • More walking paths
more social capital and be able to • Stronger codes to maintain tree
take action and help issues canopy
• Incentivize responsible • Need to have an
development acknowledgement of growth/our
• Solar on rooftops before green limits
spaces
• Money, investment, and code is
very car focuses and needs to be
more holistic
• Toolkit for tactical urbanism
(empower communities to
improve areas themselves)
• Life flight should use major
corridors to reduce residential and
wildlife noise pollution
• Expand historic preservation,
create culture like Canon
• Fix challenging areas for biking
(hills make it impossible and
dangerous to bike, even with e-
bikes)
• NSC will bring more car
infrastructure and needs to be
more resilient and multimodal
• Development should not be in
neighborhoods

[Page 550]

Station 8: Developing Climate Policies
In order to help develop climate and resiliency policies, community members were
presented with top themes heard throughout the earlier phase of climate planning
engagement. With those in mind, participants were then asked to identify any other topics
of importance:

• Recognize limits to growth.
• Prioritize protection of mature trees and iconic basalt rocks.
• The new infill law is destroying mature trees and neighborhoods.
• No mixed-use growth in the middle of neighborhoods.
• Bike infrastructure
• Walkable neighborhoods
• Public Transportation in Latah Valley
• Protect trees
• Require parking spaces for all units, change setbacks to 5-feet, change lots from 20
to 50 foot minimum.
• Sponsor new windows for historic homes.
• Convert unused city property to public pea patches.
• Growth numbers should consider possibility of climate refugees.

Station 9: Environmental Justice
Community members were presented with the definition and ways to assess environmental
justice, in order to support state required policies within the Comprehensive Plan.
Participants were then asked to provide ideas on how the City of Spokane can support
environmental justice:

• Plant more trees
• More bike lanes in all communities
• Community infrastructure built now to we have it when growth occurs
• Sound walls along freeways to protect housing
• Reducing pollution in low-income areas
• Walkable neighborhoods for everyone

Station 10: Prioritizing Climate Policies
In addition to identifying potential climate and resiliency policies, the climate planning effort
will include a prioritization process. Community members were asked to identify the top
criteria they believed should be weighted more heavily than others. Resilience received 6
votes, Equity received 3 votes, Climate Pollution Reduction received 4 votes, Logistics
received 1 vote, and Risk received 2 votes.

Page | 6

[Page 551]

Community members there then asked to identify any other criteria that should be
considered:

• Without resilience, we will have a hard time delivering on the other policies
• Clear out underbrush in fire risk areas.
• Inequitable impact e.g. when you add a historic district, you reduce the value of the
homes surrounding the historic district.
• Ban wood burning fireplaces.
• Tighten controls on vehicle emissions.
• Stop consolidating poverty; spread out affordable housing outside of poverty-stricken
neighborhoods.
• Balancing costs and benefits to ensure prospective business ventures aren’t too
impacts.
• Stop allowing shelters in areas with no services.

Page | 7

[Page 552]

Memo
Re: District 3 Future Growth and Guiding Policies Community Workshop

The District 3 Future Growth and Guiding Policies Community Workshop occurred on November 18,
2025 at Salk Middle School. Approximately 20 community members attended. Feedback received
at each station activity is summarized below. A full engagement summary of the workshop series will
be developed at a later date.

Station 1: Guiding Policies
Community members were asked to write down what topics they want to make sure are
addressed in the Comprehensive Plan to help identify potential gaps in the proposed
amendments:
• For elderly and disabled residents,
• Accessibility (housing and public walkable also means sittable
space) • Context sensitive design
• Mixed-use housing in standards, especially in historic
neighborhoods to make more centers
“hubs” instead of strip malls • Sidewalk safety (e.g. electric scoots
• More greenways and trails like and conflicts with pedestrians)
Centennial; need north/south • Require more design variety within
connections new developments
• Protected bike lanes, not just • Create quality and beautiful places
painted ones to live
• Allow for more mixed use in • Less dependence on vehicles
established neighborhoods • Allow for or encourage local
• Allow for more walkable services, restaurants, or grocery
neighborhoods stores in neighborhoods
• Sidewalks in existing development, • Organize road construction
not just new development planning so that if a main
• Programs for homeless residents north/south roadway is under
like jobs, including helping clean construction, you wait on further
up neighborhoods north/south projects
• Third spaces

[Page 553]

• Increase pedestrian safety at
uncontrolled intersections on large
roads, especially one way roads

Station 2: Displacement
After being told about three different types of displacement (physical, economic, and
cultural), community members were asked what causes to housing and small business
displacement are they most concerned about. Additionally, how could the City address
them?

The comments included:

• Lack of low friction transit
• Lack of public spaces free from oppression
• Please always consider small business impact when considering taxes
• Greater options in affordable housing (location, size, etc.)
• Density transition, no high-rise next to single unit homes
• Building getting torn down for parking lots or mall centers
• Mixed use housing can balance both
• Vacant lots/parking lots sitting unused

Station 3: Land Use Schema
Community members were asked to provide feedback on proposed land use designations
to implement the future growth of the Spokane. Specifically, they were asked what uses
should be allowed in the different land uses and were should the land use be located.
Participants reflected on the following land uses:

• Residential Low:
o Consider impacts of less on-site parking
o Allow small mixed uses (cafes, etc.) and embrace being an urban area
o Allow mixed-use spaces, community spaces, community gardens, parks, and
walkable third spaces.
o No gas stations
o Allow for small scale medical uses (e.g. dentist) near hospital district
o Need transition between low- and high-density areas
• Residential High:
o Needs to be expanded into existing lower scale residential, such as near
transit or in close proximity to amenities
• Commercial:
o Mixed use needs to be expanded
o Take advantage of vacant commercial areas to add businesses or apartments
• Centers and Corridors:

[Page 554]

o No hostile architecture
o Locate throughout Division once NSC is complete and traffic reduces
• Downtown:
o Allow taller buildings and bigger business spaces
• Industrial:
o Encourage adaptive reuse of existing spaces
• Open Space:
o Undeveloped parks with trails, not every park needs big grass fields
o Accessible open space
o Mountain biking
o 100% of the river should be public park

Station 4: Growth Alternatives
Community members were presented with the three Growth Alternatives being evaluated
as part of the PlanSpokane 2046 Periodic Update process. Alternative 1 (Stay the Course)
represents the current growth strategy. To address recent state legislation, Alternative 2
(Distributed and Balanced) and Alternative 3 (Center City and Regional Hubs) were developed
out of earlier visioning and scoping engagement. After reviewing the proposed maps and a
snapshot of environmental impact evaluation comparisons between the three alternatives,
community members were asked to vote on their preferred growth strategy. Alternative 1
received 0 votes, Alternative 2 received 5 votes, and Alternative 3 received 1 vote.

Participants who did not fully prefer one alternative over another, as well as those who did
make a selected, were asked to identify their likes and dislikes of potential growth options,
as well as other considerations for future growth. Those comments included:

• Development is currently • Alternative 2 has housing more
happening below bluff, create accessible to all parts of the city
transitional uses to reinvent the and spread impacts.
area. • Plan around future light rail.
• Alternative 2 plus downtown • Balanced alternative allows for
revitalization preferred. areas to grow and revitalize more.
• Allow Browne’s Additional uses • Do not focus on downtown, people
through the city/neighborhoods. do not visit as often as other parts
• Alternative 2 improves already of the city.
existing sprawl in city limits, • To change behavior, give a better
Alternative 3 avoids sprawl. alternative; carrot needed first.
• Neighborhood hubs needed • Pedestrian only streets or golf
throughout, create economic areas cart/scooter only streets needed.
in neighborhoods. • Need easier access to bus routes
like Division.

[Page 555]

• Downtown focus creates • Downtown expansion plus the
opportunity for more housing and connectedness along the streets
revitalization/reuse of existing and transit lines.
buildings. • Reuse abandoned commercial
• Alternative 2 preferred, but with buildings for housing.
preservation of historic buildings, • Increase middle housing
revitalize or reuse buildings. everywhere.
• The investment downtown of • Job growth is important; make
Alternative 3 is a good priority to sure we are encouraging
avoid businesses leaving. industries and not just mixed-uses.
• Like the mixed uses in north • Like a multi-block approach to
Spokane but want downtown intensities (like Alt 3 downtown)
focus as well. over less depth along transit lines.
• Housing does not fix homeless • Downtown as a primary working
problems, need other solutions hub allows for investments to
like centralized facilities. make it a safe and appealing
• Take advantage of areas already destination.
changing – vacant areas, industries
that moved.
Station 5: Map Your Future Spokane – Mixed-Uses
Through a mapping exercise where different color pins represented different types of mixed-
use designations, community members were asked to identify where they thought different
sizes and scales of mixed-use development should be located throughout the City. In
general, respondents wanted respondents wanted MU-TOD along Hamilton, North Monroe,
and along the northernmost portion of Nevada Street; MU-1 between Northwest and
Balboa/South Indian Trail neighborhoods, on North Monroe, and near the Shadle Library on
Wellesley; MU-2 along Indian Trail Road; and MU-3 in the southwest corner of
Manito/Cannon Hill, within Audubon/Downriver, and in Northwest.

Station 6: Map Your Future Spokane - Transportation
Through a mapping exercise that included stickers that indicated preferred development
types and street upgrades, community members were asked to identify what type of street
improvements and destinations they want to see along major transit stops throughout
Spokane. In general, community members indicated wanting more street trees along Ruby
and Division, Browne’s Addition, and near Illinois Avenue; wider sidewalks on Division in
downtown; lighting on Grand and south of Wellesley; bus shelters along Division; increase
bus times near Government Way; better connected areas in Northwest and
Audubon/Downriver as well as just south of downtown; improved intersection at near Freya
and 5th Avenue; wayfinding near Maple/Walnut; and reduced speeds new Wellesley and
Driscoll Boulevard.

[Page 556]

In addition to sticker placement, addition comments included:

• There is no access from housing to river between TJ Meenach and Seven Mile.
• Close some intersections along Driscoll at A and C streets, they are dangerous and
confusing.
• Increased (bus?) access and frequency to airport.
• Better “barriers” needed for separated bike lanes.
• Browne’s Addition/Downtown need pedestrian and bike connection improvements
at Maple and 1st/Pacific/Riverside.

Station 7: Planning for Climate
Community members were asked to identify what actions they want the City of Spokane to
take to support local climate resiliency. Those comments included:

• Provide good resilient tree typers • Use more fire safe housing
that don’t cause damage to pipes. material in new developments
• Help connect homeowners with • Targeted partnerships to get
getting weatherization like better air filters for the community
insulation (both knowledge and • More signage about issues like
resources). heat islands, where/when they are
• Discourage the purchasing of big happening
gas guzzling trucks, SUVs, etc. • Take a position as a city to go
• Support the replacement of trees solar, provide information to
when they need replanted connect to contractors or best
• Make our neighborhoods more products
beautiful and bring community • More coverage of trees throughout
pride Spokane
• Tree maintenance subsidies • Need formal river access for non-
• Fire hazard mitigation for car residents between TJ Meenach
homeowners and 7-Mile
• Ensure trees are watered, when • More trail and native preservation
people quit watering their yards in little parks
the summer, they also don’t water • Look at housing ages to determine
the trees places to target aging tree
• Developers need to plant higher replacement
age and mature trees • Quit encourage people to remove
• Equal investment opportunities yards, instead of drought tolerant,
into neighborhoods most people are landscaping with
• Work with local areas, including rock and amplifying the problem.
Idaho, to maintain/preserve • Do more that just Avista providing
climate energy efficiency

[Page 557]

• Urban re-forestation tree planting • Window upgrade help to reduce
subsidies energy cost
• Raise subsidy help by a sliding
scale

Station 8: Developing Climate Policies
In order to help develop climate and resiliency policies, community members were
presented with top themes heard throughout the earlier phase of climate planning
engagement. With those in mind, participants were then asked to identify any other topics
of importance:

• No additional power to AI facilities, • Address financial barriers
it will create more pollution • Low/zero friction public transit
• More bus only lanes to make • Shade
public transit faster, cheaper, and • Intersection of natural and built
quicker environment
• SpokaneScape: incentive model is • Mental and physical health
helpful, but businesses are exempt • Low-cost improvements to support
• More improvements to bike biking
infrastructure and consistent • Education around benefits of tree
connectivity throughout canopy
neighborhoods • Incentivize tree planting on the
• Tree and native landscaping north side of the city
• Better park and transit accessibility • Hold businesses more accountable
for walkable neighborhoods • Trees as physical barriers for bike
• Tree canopy lanes to improve safety
• Promotion of local community • Greenhouse gas emissions related
solution for addressing climate to “dead internet”

Station 9: Environmental Justice
Community members were presented with the definition and ways to assess environmental
justice, in order to support state required policies within the Comprehensive Plan.
Participants were then asked to provide ideas on how the City of Spokane can support
environmental justice:

• Support bicycle use and protected • Supporting walkable
bike lanes neighborhoods for community
• Fruit and nut trees in public development
spaces, not ornamental fruit trees • Fund solar panel
• Protected bike lanes and bus only • Heat mitigation in neighborhoods,
lanes especially East Central

[Page 558]

• City should provide funding • Safer roads
opportunities for climate change • Support equity in neighborhoods
mitigation activities impacted by freeways through
• Supporting pedestrian noise barriers, reinvestment
transportation without gentrifying
• Leaf removal should happen in • More bus rapid transit throughout
West Central, equal access to the city
resource • Stop watering public spaces that
• More advertising for Spokanopy aren’t parks
and SpokaneScape

Station 10: Prioritizing Climate Policies
In addition to identifying potential climate and resiliency policies, the climate planning effort
will include a prioritization process. Community members were asked to identify the top
criteria they believed should be weighted more heavily than others. Resilience received 8
votes, Equity received 5 votes, Climate Pollution Reduction received 7 votes, Logistics
received 5 votes, and Risk received 1 vote.

Community members there then asked to identify any other criteria that should be
considered:

• Legislative control to create solutions
• How to reduce homelessness/outdoor sleeping to make people less vulnerable
• Build equity into each criterion

[Page 559]

Memo
Re: Citywide Future Growth and Guiding Policies Community Workshop

The Citywide Future Growth and Guiding Policies Community Workshop occurred on November 19,
2025 at the Central Library. Approximately 35 community members attended. Feedback received
at each station activity is summarized below. A full engagement summary of the workshop series will
be developed at a later date.

Station 1: Guiding Policies
Community members were asked to write down what topics they want to make sure are
addressed in the Comprehensive Plan to help identify potential gaps in the proposed
amendments:

• Art districts • Promoting outdoor activities in the
• Neighborhoods being distinct winter e.g. park use in the winter,
• Overnight daycares SCC pool
• Spark House • Addressing employment and job
• Address land speculation creation
• Shopping District (Monroe, • Ensuring adequate levels of
Garland) transportation/transit
• Indoor swimming pools for the opportunities to reduce single
winter occupancy vehicles
• Trails • Aim to make all playgrounds and
• Action plan for incentivizing parks accessible
affordable, dense housing • Natural playgrounds
• Daycare centers • Shoreline master planning
• Conservation/migration corridors
to connect to County corridors

Station 2: Displacement
After being told about three different types of displacement (physical, economic, and
cultural), community members were asked what causes to housing and small business

[Page 560]

displacement are they most concerned about. Additionally, how could the City address
them?

The comments included:

• Faster permit processing
• City should be involved in public housing development
• High housing costs are a concern
• Mobile home park developments being replaced by affordable multi-family housing
• Business displacement due to neighborhood perception of safety
• Lack of housing inventory to keep up with population increases

Station 3: Land Use Schema
Community members were asked to provide feedback on proposed land use designations
to implement the future growth of the Spokane. Specifically, they were asked what uses
should be allowed in the different land uses and were should the land use be located.
Participants reflected on the following land uses:

• Urban Agriculture:
o Allow flower growers, small vegetable and fruit farmers market-type food
production
o Locate to avoid impacts of potential pesticides
• Residential Low:
o Human-scale and human serving design
o Allow parking
o Allow community gardens and indoor community pools
• Residential High:
o Accessible housing (no stairs)
• Centers and Corridors:
o Allow multi-family as well as trade/live work makerspaces
o Do not allow drive throughs
• Institutional:
o Incentives apartments
o Community pools
• Open Space:
o Allow indoor community pools
o Provide enough parks/trails so those in dense areas/apartments have a
place to go outside

[Page 561]

Station 4: Growth Alternatives
Community members were presented with the three Growth Alternatives being evaluated
as part of the PlanSpokane 2046 Periodic Update process. Alternative 1 (Stay the Course)
represents the current growth strategy. To address recent state legislation, Alternative 2
(Distributed and Balanced) and Alternative 3 (Center City and Regional Hubs) were developed
out of earlier visioning and scoping engagement. After reviewing the proposed maps and a
snapshot of environmental impact evaluation comparisons between the three alternatives,
community members were asked to vote on their preferred growth strategy. Alternative 1
received 0 votes, Alternative 2 received 9 votes, and Alternative 3 received 3 votes.

Participants who did not fully prefer one alternative over another, as well as those who did
make a selected, were asked to identify their likes and dislikes of potential growth options,
as well as other considerations for future growth. Those comments included:

• North/South and East/West • Alternative 2 needs the medical
connection in Alternative 2 is a focus and should include better
positive transit for shift work for medical
• Diversity of locations is positive for staff
clients/investors; “diversity of • Watch out for community
options” displacement in West
• Use land along Government Center/Broadway
Way/West Hills • Push heavy industrial outside of
• Alt 2 creates bridge between city limits
neighborhoods • Health impact to neighborhoods
• Protect agricultural lands; should be analyzed
encourage regenerative • Add home occupation for mix of
agricultural practices jobs/uses
• Like NW mixed use proposal • Need traffic calming at Broadway
• East/West supported in Alt 2 along in West Central
Wellesley and Francis • Ensure professional buildings are
• Alt 3 plus Wellesley, E/W also part of mixed-use areas, not
connection just retail/food
• Like mixed use along NW • For industrial areas where
Boulevard in Alt 2 residential areas can be allowed,
• Alter 2 favors more positive expand the tree canopy
distribution but also add corner • Need to address transportation
stores • More mixed-use and corner stores
• Neither alternative focus on with pedestrian emphasis
connecting smaller areas • Need code enforcement for
• Encourage arts through home parking in Cannon
occupation • Maintain Center and Corridors

[Page 562]

Station 5: Map Your Future Spokane – Mixed-Uses
Through a mapping exercise where different color pins represented different types of mixed-
use designations, community members were asked to identify where they thought different
sizes and scales of mixed-use development should be located throughout the City. In
general, respondents wanted respondents wanted MU-TOD near the Shadle Library on
Wellesley, along Market Street in Hillyard, on North Monroe, along Mission, in parts of
downtown and Cliff-Cannon, and in areas on 29th; MU-1in north Five Mile Prairie, in parts of
Audubon/Downriver and West Central, and downtown; MU-2 in Shiloh Hills, Northwest, and
North Hill and in areas along 29th; and MU-3 in multiple areas spread out through Comstock,
Latah/Hangman, Lincoln Height, East Central, Cliff-Cannon, Manito/Cannon Hill, Chief Garry,
Audubon/Downriver, Bemiss, and Whitman.

In addition to pin placement, addition comments included:

• No more drive throughs
• Need parks and trails in Hillyard
• Design for less disruption in displacement
• Cannon’s Addition concern over privacy with height differences
• Cannon’s Addition needs transportation management
• More health and transportation access in West Central
• Trades academy
• 24-hour day care
• Designated business district/center/corridor down east Broadway of West Central
• Trade and maker spaces in West Central
• “Sparkhouse” at McKinley School, various locations throughout City
• Create protections against displacement in Chief Garry around City Line stopes,
including increasing resources for community
• Increase Pedestrian/Bike Infrastructure along Northwest Boulevard

Station 6: Map Your Future Spokane - Transportation
Through a mapping exercise that included stickers that indicated preferred development
types and street upgrades, community members were asked to identify what type of street
improvements and destinations they want to see along major transit stops throughout
Spokane. In general, community members indicated wanting increase bus access in
downtown, along Grand Boulevard, out towards the airport, and near Northwest Boulevard;
bus shelters on Wellesley in West Central; downtown wayfinding, seating along Wellesley,
Northwest Boulevard, Division, Market, Grand Boulevard, and Regal; improved or new
crosswalks on Northwest Boulevard and near Monroe Street, as well as near Trent Avenue
and on Francis; intersections throughout northwest Spokane; street trees in East Center and
downtown; and greater and safer bike connectivity along Division, between Division and
Monroe, and on Grand.

[Page 563]

In addition to sticker placement, addition comments included:

• On Grand Boulevard from 9th to • Recommended bus routes,
29th, add center turn lane, remove including to natural areas like Mt.
parking, and add bike lanes. Spokane, Little Spokane River, and
• Increase separated protected bike Bowl and Pitcher
connectivity north/south away • Slow default neighborhood speeds
from Centennial Trail to 20 MPH
• Double decker bus cut frequency • Climate town videos like park(ing)
of the 6, not frequent enough day
• Slow down one-way couplets or • Grand should have a different type
remove them of arterial status
• No in-town highways • Micromobility designated
• Potential for strong transit spaces/use for daylighting off
connectivity with Valley-BRT or sidewalk parking
light rail on Sprague Avenue • Blue Moon Nursery will sell and
• Add pedestrian mall/mid lane develop
island to Main Street • Develop planned pedestrian
• Create school streets and shared natural surface trail along Latah
streets Creek
• Finish the envisioned boulevard • Make a one hour bus loop down to
plan for Regal Steet through Latah through Cliff-Cannon
Southgate District Center • Pedestrian path buried in park
• On Washington, Howard, and Post development
flip bike lane and parking • Trail easement at 11th Ave and
• Push Monroe Road Diet down to bridge
Kendall Yards

Station 7: Planning for Climate
Community members were asked to identify what actions they want the City of Spokane to
take to support local climate resiliency. Those comments included:

• Climate resilience education
• End wood burning fireplaces
• Real penalties for water use abuse
• Park and ride/multimodal transportation system
• Incentivize public transit use
• Encourage water conservation and restrict water use in dry months
• Extreme weather even shelters
• Adon’t rely on air conditioners as they just displace heat, use good design

[Page 564]

• Increase accessibility of recycling and composting
• Stop logging forests to make room for development, planting street trees does not
replace natural forests
• Address growth at the edge of the UGA
• Stop over building lots and not leaving space for trees
• Park and ride as entry way into public transit use

Station 8: Developing Climate Policies
In order to help develop climate and resiliency policies, community members were
presented with top themes heard throughout the earlier phase of climate planning
engagement. With those in mind, participants were then asked to identify any other topics
of importance:

• Indoor spaces to escape to during weather extremes
• Water conservation
• More resources directed to conservation programs
• Street trees, including maintenance
• Food security
• Allow fruit trees near street/sidewalks
• City should partner with property owners to maintain trees to offset costs
• Support creation of more efficient building construction
• Restrict wood burning fireplaces to improve air quality

Station 9: Environmental Justice
Community members were presented with the definition and ways to assess environmental
justice, in order to support state required policies within the Comprehensive Plan.
Participants were then asked to provide ideas on how the City of Spokane can support
environmental justice:
• Low-income renters and homeowners can’t easily afford maintenance of
sidewalks/trees/bioswales, but these improve their environment; city needs to
support neighborhoods by maintaining these elements
• Reduce light pollution
• Protecting elders from heat impacts through tree canopy and programs to reduce
costs for AC units
• Land bridge for wildlife crossing (Thorpe and 195); don’t just plan for humans
• Increase public indoor pools for year-round use for social and health benefits for
kids and elderly
• Amenities like parks and other public places need to be designed to allow
vulnerable populations to access during high temperatures

[Page 565]

Station 10: Prioritizing Climate Policies
In addition to identifying potential climate and resiliency policies, the climate planning effort
will include a prioritization process. Community members were asked to identify the top
criteria they believed should be weighted more heavily than others. Resilience received 6
votes, Equity received 7 votes, Climate Pollution Reduction received 3 votes, Logistics
received 1 vote, and Risk received 0 votes.

Community members there then asked to identify any other criteria that should be
considered:

• Emphasize natural environment as a component of resilience criteria

Page | 7

[Page 566]

Welcome!

The City of Spokane is working on a periodic update to the
City’s Comprehensive Plan as required by the State’s Growth
Management Act (GMA). This “periodic update” ensures the plan
aligns with any changes to state law. The last periodic update
was completed in 2017. Since then, the State has added new
requirements, especially around climate and housing. Due in
June 2026, the periodic update will identify policies and future
regulations to guide the next 20 years of our city.

What We’re Planning For
Population
Based on growth forecasts for Spokane County, the City of Spokane is
expected to gain at least 23,357 new residents between 2023 and
2046, bringing the City’s total population to just over 256,000. 23,357
projected new residents by 2046

Housing Needs
As part of the periodic update, the City of Spokane is seeking to better
understand how to support existing housing while addressing future
housing needs.

Per state requirements and County allocations, the City of Spokane
is expected to need 22,359 additional permanent housing units
between 2020 and 2046. 13,415 of those units are to accommodate new
residents, while the remaining units are intended to meet past housing
22,359
additional permanent housing units
underproduction needs. In addition to a total number of housing units, needed between 2020 and 2046
the City of Spokane is also required to plan for housing by affordability
bracket.

Learn more at PlanSpokane.org

[Page 567]

Environmental Impact Statement
Background
As part of the PlanSpokane 2046 process, the City
of Spokane is developing an Environmental Impact
Statement (EIS), an informational document that
provides the City, public, Tribes, and agencies with
environmental information to be considered in the
decision-making process.

An EIS is required under the State Environmental
Policy Act (SEPA) for larger projects, such as significant
updates to Comprehensive Plans. An EIS describes
potential environmental impacts, reasonable
alternatives, and ways to avoid or minimize negative
impacts that could result from implementation of
policies, informing the Comprehensive Plan Periodic
Update.

Draft EIS
The Draft EIS presents three alternatives to test Final EIS
different growth patterns and policies. The City of After public feedback and the selection of a
Spokane will then create a “preferred alternative” preferred alternative, a Final Environmental Impact
based on public input and the Draft EIS evaluation of Statement will be written that analyzes the chosen
the range of the alternatives. path forward.
The preferred alternative may include any features The Final EIS will also respond to comments received
of the studied alternatives, including a combination on the Draft EIS.
of various elements from all of the alternatives. The
preferred alternative will be evaluated in the Final EIS.

EIS Topics
Earth, water quality, and water Relationship to plans, policies,
resources and regulations

Air quality and greenhouse gas Transportation, including
emissions multiple modes and city and
state facilities

Plants and animals, including Public services: police, fire and
critical areas and habitat emergency medical services,
parks, schools, libraries, solid
Land use patterns and urban waste
form, including historic and
cultural resources
Utilities: power, water,
wastewater, and stormwater
Population, employment, and
housing

[Page 568]

Growth Alternatives The City is studying three alternatives in the Draft EIS.
Each alternative describes different growth strategies.

Legend
Growth Intensity Alternative 1 Alternative 2 Alternative 3
(Alternative 1)
Stay the Course Distributed and Balanced Center City and Regional Hubs
Low

Moderate

Moderate-High

High

Growth Intensity
(Alternatives 2 and 3)
High Density
Housing
Moderate
Density Housing
Mixed Use /
Commercial
Employment/
Industrial Light
Employment/
Industrial Heavy

Employment/ Employment/
High Density Housing Moderate Density Housing Mixed Use / Commercial
Industrial Light Industrial Heavy

[Page 569]

Alternatives Comparison (Preliminary)
This board shares preliminary environmental impact evaluation results on the natural There will be a public comment opportunity to weigh in on the alternatives and the
and built environment. Each table has a table or “report card” with comparison symbols. Draft EIS evaluation. That will help the City of Spokane create a Preferred Alternative
Impacts may be greater or lesser, or there can be potential beneficial impacts/mitigation that mixes and matches alternative features and adds mitigation measures that can
measures. The results may change with the completion of the Draft EIS. reduce impacts on the natural and built environment.

Objectives Report Card - Built Environment
OBJECTIVES ALT. 1 ALT. 2 ALT. 3 BUILT ENVIRONMENT ALT. 1 ALT. 2 ALT. 3

Land Use Patterns and Urban Form
Meet Periodic Update Requirements x ı+ ı+
Land use and Urban Form compatibility: Changes
in use type between adjacent areas and potential
Accommodate Growth: Housing at All
ı ı+ ı+ incompatibility.
Affordability Levels
Environmental Justice: Increased exposure of
Accommodate Growth: Jobs ı ı ı+ overburdened populations to light or noise pollution,
environmental hazards, or urban heat island effects
Clarify the Plan x ı+ ı+
Population, Employment, and Housing

Simplify the Plan and Codes x ı+ ı+ Capacity for Housing and Population Targets

Housing Variety and Affordability
Protect Critical Areas ı ı+ ı+
Implementation of Housing Action Plan

Fast-Track Desired Growth x ı+ ı+ Growth in Housing Displacement Risk Areas /
Increased Housing Supply that Reduces Economic / / /

Alignment with Vision Statement x ı+ ı+ Displacement Pressure

Job types and quantity and ability to advance City and
Ability to Meet Objectives regional economic development strategies
x Less More ı+ Most
Commercial business economic displacement

Relationship to Plans, Policies, and Regulations
Report Card - Natural Environment Public Services

NATURAL ENVIRONMENT ALT. 1 ALT. 2 ALT. 3 Citywide demand for police, fire/emergency medical
services, schools, parks, libraries, and solid waste
Earth, water quality, and water resources: Potential for
increased pollution and potential for increased rainfall Schools – Spokane School District
runoff flows based on housing density distribution.
Schools – Mead School District
Plants and animals: Potential for habitat conversion, or loss
Environmental Justice – Growth in Areas with Health
of habitat connectivity
and Social Disparities and Greater Service Demand
Center City
Utilities
Northwest
Power, Water, Wastewater Demand
Northeast
Power, Water, Wastewater Infrastructure Upgrades
South
Stormwater Generation
West Plains
Strength of Mitigation Potential – Plan and Code
-
Strength of Mitigation – Plan and Code Updates. - Updates

Adverse Impacts Potential Beneficial Impacts/Mitigation
Less Impacts More Impacts Most Impacts - Neutral Impacts Moderately Positive Positive

Your Ideas
What features of the different growth options do you like best? What could be improved?

[Page 570]

Map Your Future Spokane -
What type of street improvements and
Transportation! destinations do you want to see near transit
throughout Spokane?
Help us by using these stickers to indicate
your preferences for development types and
street upgrades near major transit stops.

What is Transit-Oriented
Development (TOD)?
Transit-Oriented Development, or TOD, concentrates a diversity of land
uses within easy walking, bicycling, and rolling distance of high-performance
transit lines. Key characteristics of TOD include active street frontages
with housing, shopping, employment opportunities near transit stations.
These characteristics enhance neighborhood access to resources and
transportation options, supporting local economic growth and resiliency.

[Page 571]

Map Your Future Earlier community feedback indicated a desire for more
Spokane! mixed-uses throughout Spokane.
Where should different sizes and scales of mixed-use
development be located throughout the City?
MU-TOD MU-1 MU-2 MU-3

0 2 4 miles

MU-TOD MU-1 MU-2 MU-3
Transit-Oriented Maximum Flexibility Small Neighborhood Scale Residential Mixed-Use
• Targeted towards vicinity of major transit • “Base” type for Centers and Corridors. • Smaller scale and lower intensity than • Smallest scale and intensity, targeted towards
stops (within 1/4 mile). MU-1 zone. neighborhood serving uses.
• Maximum amount of land use flexibility.
• Tallest heights (150’). • High amount of land use flexibility, but no • Can be placed both inside Centers and in
• Taller heights (90’).
self storage residential neighborhoods (limits on driveway
• Avoids vehicle-serving uses (no drive-
• Allow industrial zones where uses are spacing, street access)
thrus, commercial parking lots, etc.). • Moderate heights (75’).
currently industrial.
• Heights similar to neighborhoods (40’).
• No mini-storage • Moderate support for people driving, but
• Greatest amount of accommodation for
no drive-thrus on storefront streets • Large-scale retail/services allowed but only in
• Greatest provisions for people walking, people driving (drive-thrus permitted).
structures that also provide residential units.
bicycling, or rolling with assistive devices • Replaces some areas currently zoned
• Entirely residential buildings allowed.
to access transit. Neighborhood Retail. • Focused on accommodating people walking,
bicycling, rolling with assistive devices, and
accessing transit.

[Page 572]

Displacement Your Ideas
As part of the PlanSpokane 2046 Periodic Update, the
City of Spokane has completed analysis to understand
displacement risk as we grow. As directed by recent What causes to housing and
state legislation (HB 1220), the City is working to
establish anti-displacement policies. small business displacement are
Common anti-displacement policies include
inclusionary zoning, tenant protections, public/private you most concerned about? How
partnerships, tax incentives, community land banks,
and development agreements. could the City address them?

There are three
primary types of
displacement:
• Physical displacement, which occurs when
a project — such as building demolition,
renovation, or infrastructure — creates such
adverse conditions that a resident can no
longer physically stay in their unit.

• Economic displacement, which occurs when
increasing housing costs create pressure,
forcing a household or business to move to a
less expensive location.

• Cultural displacement, which occurs
when changes render a neighborhood quite
different, as many cultural institutions leave,
creating a sense of isolation for long-term
residents.

(Source: MRSC)

More information about the displacement
analysis, as well as racially disparate impacts,
Scan here can be found at the Housing Needs webpage

[Page 573]

What Can Be Built Where?
What is Land Use?
Land use is essentially what kinds of uses can be built where. It
Provide feedback on proposed land guides which uses are compatible in different parts of the City while
ensuring the whole City has the right mix of residential, commercial,
use designations that will implement and industrial uses needed to support a thriving city and economy.

the future growth of our city. For example, an area designated for “mixed use” can have an office, a
restaurant, or living units on the same street, while an industrial land

What uses should be allowed and use will allow mostly manufacturing or warehouses. Each land use
allows different zoning categories within it. Zoning determines the

where? rules and regulations that apply for uses and development for each
property.

What uses should Where should the
Land use type or should not be land use be or not be
allowed? located?

Urban Agriculture
• Low intensity residential with agricultural uses
• Intended for small portions of the City already with agricultural
operations

Residential Low
• Single-unit homes and middle housing
• Small scale businesses and other public-serving uses allowed

Residential High
• Middle housing and taller/wider buildings with more units
• Larger commercial uses than Residential Low

Commercial
• Non-residential uses for living, working, and shopping
• Mixed-uses and multi-unit residential in some areas

Centers & Corridors
• Core or “heart” of each Center or Corridor
• Other designations will likely be mixed in and around the core area

Institutional
• More intense residential and commercial uses to support colleges,
medical centers, and other institutions

Downtown
• Taller buildings and higher density
• Range of uses

Industrial
• Range of industrial uses including light industrial like maker spaces
and rapid prototyping

Open Space
• Active parks and open space protection in some areas

[Page 574]

Chapter Review
Non-Technical Chapters Available for Public Comment
While there are many studies and projects in progress that will inform Comprehensive Plan
updates through PlanSpokane 2046, a big part of any periodic update is a review and assessment
of the many existing goals and policies. To this end, the City is undertaking a review of the
current Comprehensive Plan, known as the Chapter Review process. Edits to the Community,
Environment, and How We Grow Chapters have been made based on legislative requirements,
direction from the Spokane Plan Commission, and community engagement.

All comments and recommendations on the non-technical chapters
can be sent to PlanSpokane@spokanecity.org.
We encourage the public to include the Chapter name and Goal/Policy number(s) as applicable.

Community
Chapters
+ Climate
NON-TECHNICAL CHAPTERS

Environment
Chapters
+ Climate
*

“How We Grow”
Chapters
+ Climate

Technical
Chapters
+ Climate

Climate will be addressed throughout the update.
*Per state regulations, Shorelines is not due to be updated until 2031.

Learn more at the Chapter Review webpage

[Page 575]

Guiding Policies Report cards summarizing the current
edits to the non-technical chapters
As part of the Chapter Review process, seven non- indicate how many new, removed, or
technical chapters have been reviewed and updated changed policies are in each chapter.
to meet state legislative requirements, recent Learn more at PlanSpokane.org.
plans and studies, direction from the Spokane Plan
Commission, and ongoing community engagement.
These chapters are now out for public comment,
with additional changes to each chapter are likely
to occur as public feedback is collected, additional
analysis is conducted, and a preferred alternative is
selected for the final Plan and Environmental Impact
Statement (EIS).

Your Ideas
As the chapters of the draft
Comprehensive Plan continue
to evolve based on community
feedback, what topics do you want to
make sure are addressed?

[Page 576]

City of Spokane climate planning is supported with funding from Washington’s Climate
Commitment Act. The CCA supports Washington’s climate action efforts by putting
cap-and-invest dollars to work reducing climate pollution, creating jobs, and improving
public health. Information about the CCA is available at www.climate.wa.gov.

[Page 577]

City of Spokane climate planning is supported with funding from Washington’s Climate
Commitment Act. The CCA supports Washington’s climate action efforts by putting
cap-and-invest dollars to work reducing climate pollution, creating jobs, and improving
public health. Information about the CCA is available at www.climate.wa.gov.

[Page 578]

City of Spokane climate planning is supported with funding from Washington’s Climate
Commitment Act. The CCA supports Washington’s climate action efforts by putting
cap-and-invest dollars to work reducing climate pollution, creating jobs, and improving
public health. Information about the CCA is available at www.climate.wa.gov.

[Page 579]

City of Spokane climate planning is supported with funding from Washington’s Climate
Commitment Act. The CCA supports Washington’s climate action efforts by putting
cap-and-invest dollars to work reducing climate pollution, creating jobs, and improving
public health. Information about the CCA is available at www.climate.wa.gov.

[Page 580]

City of Spokane climate planning is supported with funding from Washington’s Climate
Commitment Act. The CCA supports Washington’s climate action efforts by putting
cap-and-invest dollars to work reducing climate pollution, creating jobs, and improving
public health. Information about the CCA is available at www.climate.wa.gov.

[Page 581]

City of Spokane climate planning is supported with funding from Washington’s Climate
Commitment Act. The CCA supports Washington’s climate action efforts by putting
cap-and-invest dollars to work reducing climate pollution, creating jobs, and improving
public health. Information about the CCA is available at www.climate.wa.gov.

[Page 582]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix B ▪ Transportation Analysis Zones Maps

B Transportation Analysis Zones Maps

5-4

[Page 583]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix B ▪ Transportation Analysis Zones Maps

Alternative 1 – No Action Stay the Course: Housing

5-5

[Page 584]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix B ▪ Transportation Analysis Zones Maps

Alternative 1 – No Action Stay the Course: Jobs

5-6

[Page 585]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix B ▪ Transportation Analysis Zones Maps

Alternative 2 – Distributed and Balanced: Housing

5-7

[Page 586]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix B ▪ Transportation Analysis Zones Maps

Alternative 2 – Distributed and Balanced: Jobs

5-8

[Page 587]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix B ▪ Transportation Analysis Zones Maps

Alternative 3 – Center City and Regional Hubs: Housing

5-9

[Page 588]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix B ▪ Transportation Analysis Zones Maps

Alternative 3 – Center City and Regional Hubs: Jobs

5-10

[Page 589]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix C ▪ Transportation Project Implementation Table

C Transportation Project Implementation Table

ID Project Scope / Description (one Lead / Status Funding Pathway
line) Implemented
By

1 NSC North North Spokane Corridor: WSDOT In progress / State & federal
Francis Ave → Spokane WSDOT
River program

2 NSC South North Spokane Corridor: WSDOT In progress / State & federal
Spokane River → I-90 (I-90 WSDOT
connection) program

11 Bigelow Rd Straighten/extend Bigelow Spokane Planned / County match,
Extension at Thierman; widen to 4 County County grants
lanes program

19 Meadow Lane J-turn configuration at City of Committed Impact fees, grants,
Rd J-Turns Meadow Lane Rd Spokane (2026) City match

21 Cedar Rd Realign Cedar to Cheney- City of Developer- Developer mitigation
Realignment Spokane Rd; roundabout Spokane project
(Spokane) at new Marshall Creek
intersection

22 Inland Empire Reconnect Inland Empire City of Planned Impact fees, grants,
Reconnection Way to US 195 with NB Spokane City match
on-ramp at Spring Creek

23 Marshall Rd Pave Marshall Rd and City of Planned Impact fees, grants,
Activated build 44th Spokane City match
(Spokane)

24 12th: Deer Construct new 12th Ave City of Planned Impact fees, grants,
Heights → Flint link Spokane City match
Rd (Spokane)

29 Central Access New N–S connection Spokane Developer- Developer mitigation
Rd w/ Hawthorne → Farwell County delivered
Roundabouts (east of Costco)

5-11

[Page 590]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix C ▪ Transportation Project Implementation Table

ID Project Scope / Description (one Lead / Status Funding Pathway
line) Implemented
By

30 Craig & Thorpe Reconfigure offset Spokane Planned / Federal grant, local
Reconfiguration intersection at Craig & County Federal match
Thorpe grant-
seeking

32 Thorpe & New Lindeke Frontage City of Planned Impact fees, grants,
Lindeke (16th→Thorpe) + Spokane City match
Frontage roundabout
Roundabout

38 NSC Transit — Transit service on/along STA Planned / STA Moving Forward,
Line 125 NSC corridor STA plan grants

39 Division St BRT BRT on Division/Ruby with STA (with City) Planned/Ad STA capital, grants;
— Line 5 BAT segments & stations vancing / City ROW
STA plan coordination

44 W 21st Ave: Connector at W 21st from City of Partially Impact fees, City
Flint → Deer Flint to Deer Heights Spokane complete / match, developer
Heights Developer- mitigation, grants
led

45 Remove 16th ↔ Deactivate link; route to City of Planned Local revenue
US 195 Thorpe/US 195 Spokane
Connection

49 Spotted Rd Realign Spotted; Spokane Planned Federal funding
Realignment overpass/interchange to Airports
Airport Dr; connect
18th/21st

50 US 2 / Campus Roundabout at US 2 & City of Planned Impact fees, City
Roundabout Campus; open south leg Spokane match, grants

51 6th/12th Connect 6th/12th (east City of Airway Planned Grants & local match
Connection → end) to Sunset Hwy Heights
Sunset Hwy

58 US 2 / Spotted Roundabout at US 2 & City of Planned Impact fees, City
Roundabout Spotted Spokane match, developer,
grants

5-12

[Page 591]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix D ▪ Utility Maps

D Utility Maps

5-13

[Page 592]

Lift Station Inventory

5-1

[Page 593]

CSO Basin Sites

5-1

[Page 594]

City of Spokane Comprehensive Plan Update 2026-2046 Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix E ▪ Environmental Review Exemptions to Promote Infill Development and Housing

E Environmental Review Exemptions to Promote Infill
Development and Housing

5-2

[Page 595]

Environmental Review Exemptions to Promote Infill Development and Housing Ch. 5 ▪ Appendices
December 2025 ▪ Draft EIS Appendix E ▪ Environmental Review Exemptions to Promote Infill Development and Housing

Environmental Review
Exemptions to Promote
Infill Development and
Housing
Prepared by: BERK Consulting, Inc. | December 2025

5.1 Introduction and Purpose
The City of Spokane is considering updating its thresholds for environment review consistent with the
housing and infill exemption provisions of the State Environmental Policy Act (SEPA) at RCW 43.21c.229
which encourages development of housing and mixed-use development consistent with
environmental evaluation of planned densities such as through an Environmental Impact Statement
(EIS), allowing for less duplication of evaluation effort and time at the project level since regulations
such as transportation concurrency, stormwater permits, critical areas regulations, shoreline
regulations, and others are meant to protect the environment.

Another avenue for streamlined review under SEPA includes raising categorical exemptions in using
flexible thresholds in state rules at WAC 197-11-800(1)(c) and (d). Spokane has raised exemptions
higher than the minimum categorical exemption thresholds but not made full use of thresholds to
limit review of minor new construction.

Under either of the SEPA exemption provisions, the City would help fulfill a strategy in its Housing
Action Plan (2021) to streamline permitting for housing.25

The City of Spokane is preparing a new EIS for its Comprehensive Plan periodic update due in 2026
which evaluates new residential, mixed use, and employment uses in the city over the 2022-2046

25
See: Spokane Housing Action Plan - City of Spokane, Washington.

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December 2025 ▪ Draft EIS Appendix E ▪ Environmental Review Exemptions to Promote Infill Development and Housing

period. The EIS also summarizes the federal, state, and local regulations that apply and serve as
mitigation. The EIS process provides notices to agencies and Tribes of the intent to provide for these
expanded exemptions and opportunities to comment.

This document outlines requirements, describes policies and regulations that mitigate impacts, and
identifies potential infill exemption locations and phasing.

5.2 Exemption Types

5.2.1 Infill and Housing Exemptions
To accommodate infill development in urban areas not meeting the density goals of a Comprehensive
Plan,26 the City can establish an infill exemption where development that is consistent with City
regulations is not required to undergo new environmental review, provided that the probable adverse
environmental impacts have been adequately addressed by local regulations and that the City’s
Comprehensive Plan was previously subject to an Environmental Impact Statement (EIS). The City of
Spokane is preparing a new EIS for its Comprehensive Plan periodic update due in 2026.

The provisions in RCW 43.21C.229 allow cities or counties (in urban growth areas) planning under the
Growth Management Act (GMA) to exempt residential development and raise SEPA thresholds for:
 Residential development;
 Mixed-use development; or
 Commercial development up to 65,000 square feet, excluding retail development;

Senate Bill 5412 (2023) added a new section at RCW 43.21C.229(3) allowing cities or counties (in urban
growth areas) to adopt a new SEPA exemption for all project actions proposing to develop housing
units provided:
 the development is consistent with all development regulations implementing a GMA
comprehensive plan;
 the development is consistent with the proposed use or density and intensity of use in the
designated infill area;
 the EIS prepared for the exemption analyzes multimodal transportation impacts, including impacts
to neighboring jurisdictions, transit facilities, and the state transportation system;
 the city or county has documented consultation with the Washington State Department of
Transportation including consideration of whether mitigation is necessary for impacts to
transportation facilities;

26
Places where the current density and intensity of use in the area is roughly equal to or lower than called for in
the goals and policies of the applicable comprehensive plan.

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December 2025 ▪ Draft EIS Appendix E ▪ Environmental Review Exemptions to Promote Infill Development and Housing

 the environmental analysis documents that the comprehensive plan, subarea plans, adopted
regulations, and state and federal regulations adequately mitigate impacts in an environmental
determination (e.g., EIS or determination of non-significance); and
 there is a 60-day notice to affected tribes, state agencies, and other jurisdictions and public before
the environmental analysis is completed.

The Infill Exemption process is summarized in Exhibit 1.

Exhibit 1. Infill and Housing Exemption Process
Prepare Environmental Provide 60-day
Impact Statement (EIS) Develop ordinances.
notice to affected
evaluating infill, mixed Consider Adoption
tribes, relevant state Review Future
use, and housing of Infill and Housing
agencies, other Permits for
development. Exemptions in City's
jurisdictions that Consistency with
SEPA Rules. The
•Identify how federal, state, may be impacted. Ordinances.
effective date is 30
and local regulations mitigate Consult with
impacts. days after adoption.
WSDOT.

Categorical exemptions adopted under RCW 43.21C.229 (3) become effective 30 days after the
adoption of the enacting ordinance.

In the SEPA Handbook (2025)27, the Washington State Department of Ecology recommends that the
exemption clearly indicate:
 The level of residential or mixed-use development that will be exempt,
 The area where the exemption will apply, and
 How the exemption will be applied to a proposed project.

The Handbook also indicates that when an application for residential or mixed-use development is
received by local government, the city must:
 Compare the proposal to the adopted categorical exemption.
 Ensure the proposed density or intensity of the development does not exceed the density/intensity
levels established in the comprehensive plan.

This is consistent with WAC 197-11-800(6) that limits exemptions for rezones that require a
Comprehensive Plan Amendment.

New Exemption in Station Areas
Based on a 2025 amendment under HB 1491, a new section (5) was added stating that all project
actions that propose to develop residential or mixed-use development within a station area (along bus

27
See: https://apps.ecology.wa.gov/publications/documents/2506009.pdf.

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December 2025 ▪ Draft EIS Appendix E ▪ Environmental Review Exemptions to Promote Infill Development and Housing

rapid transit such as the City Line in central Spokane) are categorically exempt from the requirements
of this chapter, subject to the rules of the department adopted according to RCW 43.21C.110(1)(a) that
provide exceptions to the use of categorical exemptions adopted by the department. See “Exceptions
to Exemptions” below. The Washington Department of Commerce is providing guidance on intensity of
development in station areas, and exceptions, by 2027.

5.2.2 Flexible Categorical Exemption Thresholds in SEPA Rules
SEPA provides for minimum exemption levels for minor new construction, as well as flexible
thresholds, where agencies may adopt the maximum level or a level between the minimum and
maximum level in Exhibit 2 in its SEPA rules, the City of Spokane has implemented 20% of single-
family residential exemption thresholds and 10% of multifamily exemption thresholds.

Exhibit 2: Categorical Exemptions – State Rules and City Regulations

Project Type SEPA Default SEPA Max. for Cities City of Spokane
Exemption Threshold (Incorporated Municipal Code
UGAs) WAC 197-11-
WAC 197-11-800(1)(a) Section 17E.050.070
800(1)(d)

Single family residential 4 units 30 units 20
Single family residential 4 units 100 units 20
with the total square
footage less than 1,500
square feet
Multifamily residential 4 units 200 units 20
Office, school, commercial 4,000 sf 30,000 sf 12,000 square feet
(square feet) w/parking or and 40 parking
20 spaces 90 spaces
stand-alone parking lot spaces
Landfill or excavation 100 1,000 Up to 500 Cubic
(cubic yds) Yards

The City could adopt higher thresholds, which could vary by use or different geographic areas, and
mixed-use projects.

To raise thresholds, the City would follow a process similar to that identified for the infill and housing
exemption described earlier. The steps involve:
 Documentation of Existing Federal, State, and Local Regulations: Documentation that the
requirements for environmental analysis, protection and mitigation for impacts to elements of the
environment (listed in WAC 197-11-444) have been adequately addressed for the development
exempted. The requirements may be addressed in specific adopted development regulations, and
applicable state and federal regulations.

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December 2025 ▪ Draft EIS Appendix E ▪ Environmental Review Exemptions to Promote Infill Development and Housing

 Documentation of Cultural and Historic Resources Regulations: Document how specific development
regulations and applicable state and federal laws provide adequate protections for cultural and
historic resources. The local ordinance or resolution shall include, but not be limited to, the
following:
 Use of available data and other project review tools regarding known and likely cultural and
historic resources, such as inventories and predictive models provided by the Washington
department of archaeology and historic preservation, other agencies, and tribal governments.
 Planning and permitting processes that ensure compliance with applicable laws including
chapters 27.44, 27.53, 68.50, and 68.60 RCW.
 Local development regulations that include at minimum pre-project cultural resource review
where warranted, and standard inadvertent discovery language (SIDL)28 for all projects.
 Transportation Outreach: Document the result of its outreach with the Department of
Transportation on impacts to state-owned transportation facilities, including consideration of
whether mitigation is necessary for impacts to state-owned transportation facilities.
 60-day Notice: Before adopting the ordinance or resolution containing the proposed new
exemption levels, provide a minimum of 60 days’ notice to affected tribes, agencies with expertise,
affected jurisdictions, the department of ecology, and the public and provide an opportunity for
comment. The requirements for notice and opportunity to comment must be specifically
documented.
 Findings: Description in the findings or other appropriate section of the adopting ordinance or
resolution of the locally established notice and comment opportunities for the public, affected
tribes, and agencies regarding permitting of development projects included in these increased
exemption levels.

5.2.3 “Exceptions” to Exemptions
Regardless of which SEPA provision is implemented for changing exemptions, the categorical
exemptions do not apply in the following cases when the project:
 Is undertaken wholly or partly on lands covered by water (WAC 197-11-756);
 Requires a license governing discharges to water that is not exempt under RCW 43.21C.0383 such
as construction projects that are greater than 5 acres in size that require a NPDES construction
stormwater permit;
 Requires a license governing emissions to air that is not exempt under RCW 43.21C.0381 regarding
air operating permits, or WAC 197-11-800 (7) regarding open burning or (8) variance from clean air
act requirements; or

28
The State Department of Archaeology and Historic Preservation has recommended SIDL language, available at:
https://dahp.wa.gov/archaeology/human-remains/recommended-inadvertent-human-remains-discovery-
language.

5-7

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December 2025 ▪ Draft EIS Appendix E ▪ Environmental Review Exemptions to Promote Infill Development and Housing

 Requires a land use decision that is not exempt under WAC 197-11-800(6) such as rezones
requiring a corresponding Comprehensive Plan Amendment.

5.3 City of Spokane Environmental Regulations
The State Environmental Policy Act (SEPA) was passed by the Washington State Legislature in 1971.
The statute creates a review and evaluation framework centering on the identification and mitigation
of impacts to the natural and built environment.

Numerous state and federal laws also require that cities like Spokane to adopt regulations protecting
water quality, wetlands, streams, fish and wildlife, floodplains, archaeological and cultural resources,
air quality, noise, transportation, building, fire protection, energy, and more. The City of Spokane has
adopted numerous development regulations and can condition development through its permit
review process. See Exhibit 3.

Exhibit 3: Element of the Environment and Plans and Codes that Protect Environmental Quality

Environmental Topic Plans and Codes Addressing Environmental Topic

Earth See Water regarding erosion control. In addition:
 Chapter 17E.040 Spokane Geologically Hazardous Areas
 Building and Construction Codes that regulate development in
seismic hazard areas, Title 17F Construction Standards, Section
17F.040.105 Design Criteria
Air Quality
Federal and State
 NAAQS: The EPA enforces the CAA, which establishes the NAAQS for
six criteria pollutants and sets emissions standards for vehicles and
fuels, stationary industrial facilities, and hazardous air pollutants.
 Washington State: Ecology develops and implements plans to ensure
compliance with NAAQS and has established state ambient air quality
standards. Washington State has also enacted the Washington Clean
Air Act.
 State Implementation Plan: The EPA reviews and approves
Washington’s State Implementation Plan, which provides tools to
restore air quality and meet NAAQS when one or more pollutants are
not in compliance.
 The State has enacted the Climate Commitment Act to cap and
reduce statewide GHG emissions with a goal of achieving a 95%
reduction by 2050. The State has also established the Clean Energy
Transformation Act, which commits the state to emissions-free

5-8

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December 2025 ▪ Draft EIS Appendix E ▪ Environmental Review Exemptions to Promote Infill Development and Housing

Environmental Topic Plans and Codes Addressing Environmental Topic
electricity by 2045. The State’s Clean Buildings Performance Standard,
Clean Buildings Act, energy codes, and zero-emission vehicle
standards will also help the State and Spokane reduce greenhouse
gas emissions.

Regional/Local
 Spokane Regional Clean Air Agency (SRCAA), Air Quality Regulations,
and Federal Air Operating Permit (AOP) program, Notice of
Construction (NOC) Permit, Portable Source Permit (PSP), Outdoor
Burning requirements, Asbestos Requirements
 SRCAA Regulations: SRCAA’s core air quality regulatory code—
Regulation I—incorporates federal and state standards, while
including specific requirements for air quality measures within the
county.
 SRCAA is tasked with air quality monitoring, enforcement inspections,
permitting, and outreach with Spokane County.
Water, ground and
Federal
surface
 Clean Water Act, 33 United States Code (USC) 1251 et seq., including
Sections 401—Water Quality Certification, 402—National Pollutant
Discharge Elimination System, and 404—Permits for Dredge or Fill
 Coastal Zone Management Act, 16 USC 1451 et seq.
 Section 14 of the Rivers and Harbors Act of 1899, 33 USC 408 (Section
408)
 National Flood Insurance Act of 1968 and Flood Disaster Protection
Act of 1973, 42 USC 4001 et seq.
 Floodplain Management Presidential Executive Order 11988
 Endangered Species Act (ESA) Biological Opinion for the
Implementation of the National Flood Insurance Program in the State
of Washington (National Marine Fisheries Service 2008)
 Safe Drinking Water Act, 42 USC 300 et seq., Chapter 6A

State & Regional
 Water Quality Standards for Surface Waters, Washington
Administrative Code (WAC) 173201A
 Water Quality Standards for Groundwater, WAC 173-200
 Flood Control Management Act, Revised Code of Washington (RCW)
86

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Environmental Topic Plans and Codes Addressing Environmental Topic
 Water Pollution Control Act, RCW 90.48
 Shoreline Management Act, RCW 90.58, WAC 173-26
 National Pollutant Discharge Elimination System (NPDES)
Construction Stormwater General Permit (Washington State
Department of Ecology [Ecology], 2020)
 National Pollutant Discharge Elimination System (NPDES) Eastern
Washington Phase II Municipal Stormwater General Permit (Ecology,
2024a)
 Stormwater Management Manual for Eastern Washington (Ecology
Manual) (Ecology, 2024b)
 Washington State Department of Transportation (WSDOT) Highway
Runoff Manual (WSDOT, 2019a)
 WSDOT Hydraulics Manual (WSDOT, 2024)
 WSDOT Temporary Erosion and Sediment Control Manual (WSDOT,
2019b)
 Washington State Hydraulic Code, WAC 220-660

Local
Chapter 17E.010 Critical Aquifer Recharge Areas – Aquifer Protection

Chapter 17E.030 Floodplain Management
Chapter 17E.060 Shoreline Regulations

Chapter 17E.070 Wetlands Protection
Chapter 17D.060 Stormwater Facilities
Chapter 17D.090 Erosion and Sediment Control
Spokane Regional Stormwater Manual (Spokane et. al., 2008)
Standards include:
1. Standard Specifications of the Washington State Department of
Transportation, latest edition.
2. General Special Provisions of the City of Spokane, latest edition.
3. City of Spokane Design Standards and Standard Plans, latest edition.
4. The Spokane Regional Stormwater Manual (SRSM), latest edition.
5. Spokane Aquifer Water Quality Management Plan. Spokane County,
Washington “208” Program. County engineers’ office.
6. Stormwater Management Manual for Eastern Washington
(SWMMEW), Washington State Department of Ecology, latest edition.
Spokane Aquifer Joint Board Wellhead Protection Program

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December 2025 ▪ Draft EIS Appendix E ▪ Environmental Review Exemptions to Promote Infill Development and Housing

Environmental Topic Plans and Codes Addressing Environmental Topic

Plants and Animals
Federal
 Endangered Species Act (ESA): Provides a framework to conserve and
protect endangered and threatened species and their habitats from a
project’s effects. Section 7 of the ESA requires federal agencies to
ensure that their actions do not jeopardize the existence of listed
species or destroy or adversely modify designated critical habitat.
The ESA is administered by the U.S. Fish and Wildlife Service (USFWS)
and National Oceanic and Atmospheric Administration National
Marine Fisheries Service (NOAA Fisheries, or NMFS).
 Migratory Bird Treaty Act of 1918: Protects migratory birds, making it
illegal to take, possess, import, export, transport, sell, purchase,
barter, or offer for sale, purchase, or barter, any migratory bird, or
the parts, nests, or eggs of such a bird except under a valid federal
permit from USFWS.
 Bald and Golden Eagle Protection Act of 1940: Prohibits “take,”
including parts (including feathers), nests, or eggs of bald eagles
(Haliaeetus leucocephalus) and golden eagles (Aquila chrysaetos).
 Section 404 of the Clean Water Act: Requires authorization from the
Secretary of the Army, acting through the Corps of Engineers
(USACE), for the discharge of dredged or fill material into all waters of
the United States, including wetlands. A permit is required whether
the work is permanent or temporary.

State
 Chapter 220-610 WAC, State and Protected Species: Identifies the
federal ESA-listed species that are present in Washington and
establishes closed seasons and penalties for take of federally listed
fish species. It also identifies and classifies native wildlife species
needing protection in Washington; defines the listing, management,
recovery, and delisting processes; and establishes rules for bald eagle
management in Washington.
 Chapter 77.12.020 RCW, Wildlife to be classified: Empowers the
director of the Washington Fish and Wildlife Commission to
determine whether a species should be managed by WDFW, and to
classify it as protected, endangered, or as deleterious exotic wildlife
that is dangerous to the environment or wildlife of the state.
 Chapter 77.55 RCW, Construction Projects in State Waters: Requires a
Hydraulic Project Approval (HPA) from the Washington Department

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Environmental Topic Plans and Codes Addressing Environmental Topic
of Fish and Wildlife WDFW for any work that uses, diverts, obstructs,
or changes the natural flow or bed of any fresh water or saltwater of
the state of Washington, including wetlands.
 Chapter 220-640 WAC, Invasive/Non-native Species; Chapter 17.10
RCW, Noxious Weeds—Control Boards; and Chapter 16-750 WAC
State Noxious Weed List and Schedule of Monetary Penalties:
Establish the framework for regulating and controlling noxious weeds
in the state of Washington and designate the list of noxious weeds
that pose threats statewide and regionally.

Local
 Chapter 17E.020 Fish and Wildlife Conservation Areas
 Chapter 17E.060 Shoreline Regulations
 Chapter 17E.070 Wetlands Protection
Energy and Natural
Federal
Resources
 National Electrical Code, as adopted by the National Fire Protection
Association

State
 2019 Washington State Clean Energy Transformation Act, amending
portions of RCW Titles 19 (Business Regulations – Miscellaneous), 43
(State Government – Executive), 80 (Public Utilities), and 82 (Excise
Taxes) to commit Washington to an electricity supply free of
greenhouse gas emissions by 2045.
 Washington State Energy Code, WAC Title 51, Chapters 11C and 11R

Local
 Electric Service Requirements administered by Avista
 Section 17F.040.010 Adoption of Building Codes and Related
Washington State Codes, International Energy Conservation Code,
current adopted Edition, chapter 51-11C and 51-11R WAC.
 Section 12.05.030 Sustainable Public Buildings Requirements
Environmental Health
State
 Model Toxics Control Act (MTCA) - Chapter 70A.305 RCW (MTCA law)
 MTCA Cleanup Regulations - Chapter 173-340 WAC (MTCA rule, also
known as the MTCA Cleanup Rule)

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Environmental Topic Plans and Codes Addressing Environmental Topic
 Sediment Management Standards - Chapter 173-204-WAC (SMS rule,
also known as the Sediment Cleanup Rule)
 Washington's hazardous waste management law and dangerous
waste regulations.

Local
 Chapter 17F.080 Fire Code
 Chapter 10.70 Noise Control, including Section 10.70.070 Maximum
Permissible Environmental Sound Levels
 Chapter 12.03 Airport Regulations
 Chapter 17C.182 Fairchild Overlay Zones
 See also air quality.
Land and Shoreline Use  Title 17B Comprehensive Plan and Sub-area Plans
 Title 17C Land Use Standards
 Title 17D City-wide Standards
 Title 17E Environmental Standards including Chapter
17E.060 Shoreline Regulations
Aesthetics  Chapter 17C.160 North River Overlay District, Section
17C.160.020 Views, Vistas and Site Coverage Design
 Section 17C.124.585 Jefferson Street & Spokane County Courthouse
View Corridor
 Chapter 17C.250 Tall Building Standards
Light and Glare  Chapter 17C.111 Residential Zones, Section 17C.111.520 Lighting,
Section 17C.111.420 Open Spaces
 Chapter 17C.123 Form Based Code Zones, Section
17C.123.050 Parking and Pedestrian Connectivity
 Chapter 17G.070 Planned Unit Developments, Section
17G.070.150 Lighting
 Chapter 17C.180 Airfield Overlay Zones, and
Chapter 17C.182 Fairchild Overlay Zones
 Chapter 17E.060 Shoreline Regulations (multiple districts address
Dark Sky)
Parks and Recreation  Open space per unit: Chapter 17C.111 Residential Zones
 Plazas and Open Spaces: Chapter 17C.120 Commercial Zones
 Spokane Parks Master Plan:
https://my.spokanecity.org/parksrec/master-plan/

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Environmental Topic Plans and Codes Addressing Environmental Topic

Historic and Cultural
Federal and State
Preservation
Federal and state laws govern the designation and protection of cultural
resources, including but not limited to:
 National Historic Preservation Act (NHPA) of 1966, as amended,
known as Section 106, has implementing regulations (36 CFR Part
800), that require federal agencies, or those receiving federal grants
or funds, or a federal permit or license, to identify historic properties,
assess adverse effects, and resolve those adverse effects.
 Archaeological Resources Protection Act (ARPA) of 1979 protects
archaeological resources.
 National American Graves Protection and Repatriation Act (NAGPRA)
creates protections for Native American burial sites, remains, and
cultural objects.
 Washington Executive Order 21-02 (formerly 05-05) requires that
impacts to cultural resources must be considered as part of any
state-funded project or investment and must include consultation
with DAHP and with Tribal governments.
 Washington State law (RCW 27.53 and 27.44) protects archaeological
resources (RCW 27.53) and Indian burial grounds and historic graves
(RCW 27.44) located on both the public and private lands of the State.
 An archaeological excavation permit issued by the Washington State
Department of Archaeology and Historic Preservation (DAHP) is
required in order to disturb an archaeological site.
 Knowing disturbance of burials/graves and failure to report the
location of human remains are prohibited at all times (RCW 27.44
and 68.60).

Local
Shorelines: Section 17E.060.160 Archaeological and Historic Resources
The City’s Shoreline Master Program (Section 5.2.4 Historic or
Archeological Impacts) includes regulations regarding stop work and
studies if cultural resources are encountered:
 For any use, activity or development, the project proponent, agent, or
applicant shall notify the Spokane Historic Preservation Office and
the Director whenever any archaeological or historical artifacts or
cultural resources are encountered during any grading or excavation.
All work on the project site shall cease immediately.

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Environmental Topic Plans and Codes Addressing Environmental Topic
 Work may resume only after the applicant, project proponent, or
agent and the Spokane Historic Preservation Office, the Washington
State Department of Archaeology and Historic Preservation, and
appropriate Tribal entities agree in writing on measures to protect
potentially affected archaeological or historic artifacts or cultural
resources.
 Spokane’s zoning code includes Chapter 17D.100 Historic
Preservation, which addresses the nomination of historic landmarks
or districts. If there is a request for the demolition of an historic
landmark or a contributing building located within a local historic
district, the City’s Historic Preservation Officer and the Spokane
City/County Historic Landmarks Commission reviews the proposal
against criteria. The code also contains incentives such as façade,
utility, and sidewalk grants to support preservation. Section
17D.100.230 of the Spokane Municipal Code specifically addresses
demolition permits for historic structures located within the
downtown boundary area, National Register historic districts, and
centers and corridors, which were recently incorporated into the
ordinance (Spokane City/County Historic Preservation Office, 2024).
 Chapter 17C.335 Historic Structures – Change of Use
The Draft EIS identifies potential mitigation measures such as applying
shoreline master program requirements citywide and developing a
decision tree guiding the amount of documentation and consultation
depending on the potential risk of uncovering cultural resources.
Transportation Spokane’s existing regulatory framework ensures that transportation
improvements keep pace with growth and safety needs. Concurrency
and impact fees link development to capacity projects. When thresholds
are exceeded, intersection and corridor upgrades are advanced as part
of the City’s capital program. Frontage improvement requirements
ensure that adjoining sidewalks, curb ramps, crossings, and bike
elements are implemented to current standards as sites redevelop.
 Chapter 17G.010 Building and Construction Permits
 Chapter 17H.010 Street Development Standards
 Chapter 17H.020 Complete Streets Program
 Chapter 17D.075 Transportation Impact Fees: Spokane’s
transportation impact fee program links new development to
delivery of transportation network improvements identified in the
City’s capital/impact‑fee project lists. Fees collected at permitting are
restricted to eligible capacity and safety projects, so investments are

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Environmental Topic Plans and Codes Addressing Environmental Topic
made where growth occurs. Because the program is district-based,
revenues generated in growth areas can be directed to corridor and
intersection improvements that support concurrency and mitigate
impacts discussed within this EIS. In the West Plains, impact fees are
programmed to construct parallel roadways to US 2/Sunset Highway,
which will enhance east-west mobility as employment expands in the
area. In South Spokane, impact fees are programmed to convert S
Hatch Road and E 57th Avenue from side-street stop control to a
signal or roundabout, reducing delay and improving safety for all
users.
 Chapter 17C.420 South Logan TOD Planned Action
Public Services  Fire: Chapter 17F.080 Fire Code
 Fire  Fire: Chapter 17F.110 International Wildland-Urban Interface Code
 Police  Fire/Police: An increase to local sales and use tax to support a Public
 Schools Safety Tax for criminal justice and fire protection became effective
April 1, 2025.
 Schools: The City addresses school demand and facilities in its Capital
Facilities Plan. The City implements safe routes to schools as part of
land use permit review.
Utilities
Federal
 Water  Safe Drinking Water Act, 42 USC 300 et seq., Chapter 6A,
 Stormwater administered but the U.S. Environmental Protection Agency
 Sewer  Clean Water Act, 33 United States Code (USC) 1251 et seq., including
 Solid Waste Section 402 – National Pollutant Discharge Elimination System
(NPDES)

State
 Washington State Department of Ecology, WAC Title 173, Chapters
200-270, which includes administration of the NPDES program,
discharge and effluent standards, the waste discharge general permit
program, construction of wastewater treatment plants, and
construction and operation of combined sewer overflow reduction
facilities
 NPDES Wastewater Discharge Permit program, administered by the
Washington State Department of Ecology
 Wastewater Collection System Consent Decree, administered by the
Washington State Department of Ecology and U.S. Environmental
Protection Agency

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Environmental Topic Plans and Codes Addressing Environmental Topic
 Water Systems, WAC Title 246, Chapters 290-296, administered by
the Washington State Department of Health
 NPDES Industrial Stormwater General Permit, administered by the
Washington State Department of Ecology
 Stormwater Management Manual for Eastern Washington,
administered by the Washington State Department of Ecology
 Washington State Hydraulic Code, WAC Title 220, Chapter 660,
administered by the Washington Department of Fish and Wildlife

Local
Chapter 17G.010 Building and Construction Permits, including
concurrency with utilities
Title 13 Public Utilities and Services
 Chapter 13.02 Solid Waste
 Chapter 13.03 Sewers
 Chapter 13.035 Water-Wastewater Rates
 Chapter 13.03A Pretreatment
 Chapter 13.04 Water
 Chapter 13.08 Utility Cost Recovery Methods

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5.4 Potential Infill Exemption Location
To streamline development under SEPA exemptions, the City could consider a phased approach:
 Phase 1 infill exemption area: These are areas in the city that are already urbanized with less
environmental constraints and with greater access to multimodal transportation including transit.
These have opportunities for residential, mixed use, and small-scale commercial infill and
redevelopment to meet the City’s housing and job needs.
 Phase 2 infill exemption area: These are areas in the balance of the city limits that are developing
where there is less infrastructure. The City would have a greater understanding of the conditions of
approval needed in its standard permit process once the transportation impact fee and associated
updated Transportation Improvement Program are amended to implement the Comprehensive
Plan periodic update including the City’s multimodal levels of service.

Maps informing the phases are included on the following pages:
 Exhibit 4: Existing Hard (Impervious) Surfaces (2023)
 Exhibit 5: EIS Study Areas with Frequent Transit Routes (2025)
 Exhibit 6: Access to Frequent Transit within a Half and Quarter Mile Distance (2025)

Preliminary Phase 1 boundaries are included for consideration during the Draft EIS comment period:
 Exhibit 7: Phased SEPA Proposed Infill /Categorical Exemption Area

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Exhibit 4: Existing Hard (Impervious) Surfaces (2023)

Sources: City of Spokane, 2025; National Land Cover Dataset, 2023; Spokane County Aerial Imagery, 2024.

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Exhibit 5: EIS Study Areas with Frequent Transit Routes (2025)

Source: City of Spokane, BERK, 2025.

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Exhibit 6: Access to Frequent Transit within a Half and Quarter Mile Distance (2025)

Source: City of Spokane, BERK, 2025.

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Exhibit 7: Phased SEPA Proposed Infill /Categorical Exemption Area

Source: City of Spokane, BERK, 2025.

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