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191_-_2021-8-31_Leslie_OlmsteadAugust 31, 2021 Lori Barlow, AICP, Senior Planner City of Spokane Valley 10210 East Sprague Avenue Spokane Valley, WA 99206 (509) 720-5335 or LBarlow@spokanevalley.org RE: Comments to the Painted Hills Planned Residential Development – Draft EIS Dear Ms. Barlow: I have reviewed the Painted Hills Draft EIS and have comments and a few questions that will likely serve as comments. Please accept the questions and comments to the Draft EIS. Stormwater and Flooding 1. In Figure 3.6, the floodways run to the northwest. This development will have an increased covered area (concrete and asphalt) of 25% of the total project. Also, in the northwest corner of the PRD, the covered areas will be greater, due to multifamily housing parking and commercial development parking. The problem is stormwater will have a higher likelihood of continuing to run to the northwest, not be captured for stormwater treatment and potentially flood the residents in the trailer park located on the west side of Dishman-Mica. 2. This development will likely have impacts further to the northwest that currently do not seem to be captured within this DEIS yet given the potential economic impacts due to flooding of a trailer park, they should be considered. 3. Have additional box culverts been considered for the northwest side of the project? 4. There has been a great deal of discussion of the flooding on Thorpe. However, changing the flood patterns within this area will likely have impacts to Madison as well. Have those impacts been looked at? What will the mitigation measures be in relation to Madison? 5. It is not clear how the compensatory storage areas will be compensated or mitigated in detail. I would like to see more information in relation to this aspect of stormwater management. 6. In the statement below, taken from the DEIS – “The implementation of Alternative 2a will require the flood hazard management system to remain in optimal condition in perpetuity.” Who will be managing this system in optimal condition in perpetuity? The builder? Or will the cost be passed on to the taxpayers beyond just the residents? Will the new residents be made aware of these obligations? Transportation 1. Per the Transportation section, “Bicycle and pedestrian facilities per the City of Spokane Valley Bicycle and Pedestrian Master Plan will be completed along the site frontages.” Does this mean sidewalks will be added to Madison, Thorpe and Dishman-Mica? 2. Any variation in the Truck Haul Plans that allow use of Madison should be prohibited. 3. It is disappointing the traffic study did not look at any of the roads south of Thorpe. I believe we will see increased traffic flow on Mohawk to access Dishman-Mica. Many children live in the houses to the south of Thorpe, up in the Painted Hills. They walk and bike down roadways that have no sidewalks, are fairly narrow, poorly maintained and have no shoulder. This area needs to be studied for both the safety component as well as the traffic component. 4. I also believe we will see continued use of roadways to the south. It is not clear the traffic study pulled into account the new development just south of the Thorpe Dishman-Mica intersection. I believe the traffic study needs to be updated to reflect new changes. 5. The traffic study is 5-years old and does not reflect changes population to the south of the traffic study area. There have been at least three new developments completed in the Painted Hills and another one is proposed, since the study date. All of them are south of the current study area, but all of the residents use the roads in the 2016 study area. 6. Although several of the following topics were not “studied in detail” they should have been. Air Quality 1. The project is scheduled to take approximately 10 years to complete with 4 years of fill and grading. Since 2020, the air quality has been poor for months at a time during the summer months, due to forest fires. This will only get worse. What are the fugitive dust management and mitigation plan for the area? 2. The health-based standard for PM2.5 has been exceeded during the winter months due to wood stove smoke in 9 of the past 19 years, including 2013, 2014, 2015, and 2017. The health-based standard for PM2.5 has been exceeded in July, August, and/or September due to forest fire smoke in 2014, 2015, 2017 (16 days), and 2018 (13 days) (SRCAA, 2016, 2019). The last two years, 2020 and 2021 have seen horrible air quality days. Extending the poor air quality into the winter months will further contribute to air quality related health issues. I believe this warrants more study, given the number of houses being considered in this project. Although the DEIS looked at stormwater and traffic, more attention needs to be given to air quality and the impacts this project will have on air quality. Aesthetics 1. The location of high-density housing in this PRD does not consider the low- density housing that surrounds it. The Spokane County Comprehensive Plan provides guidance indicating neighborhood character should be preserved and protected. 2. Although I am not anti-development, I am against developments that have no blend factor to the surrounding neighborhoods. It leaves the developments as small islands that do not incorporate into the surrounding neighborhoods well. Environmental Consequences 1. The PRD plan presented has limited actual open space. Since most of the trails are internal to the neighborhood and do not connect to any bikeways, pathways, sidewalks external to the development, it only enhances the island nature of the project. Too often when these residential developments are considered, the developer does not provide enough open space for neighbors to develop a sense of community. There are no parks, dog areas, picnic areas or open spaces in the plan that would contribute to an overall creation of community. This continues to develop islands within islands and is not beneficial to neighborhoods or communities. I believe, at this scale at least two legitimate park areas should be constructed by the developer to enhance the open space features Spokane and Spokane Valley residents’ desire. 2. The proponent indicates no aesthetic cumulative impact. However, the vinyl fences, lack of connectivity to the outside neighborhoods and the generic landscaping at each house provides no aesthetic appeal and makes the project appear as if were a potted plant someone just set out. There is no flow, no connection. The proponent needs to enrich the area and the development by providing more inclusion and connection with the outside areas. Biological Resources - Species of Concern 1. Although the DEIS indicates there are no Bald Eagles in the area. On numerous occasions I have seen Bald Eagles in the area. I think the biological study may need to be updated a last time to ensure raptors in the area are not impacted by the development. Hopefully, the study will take place during the raptor nesting season. 2. The trail network noted on the plan map does not provide enough room for large mammals to move through the area. Deer need cover and grazing areas. Maintaining some of those elements within this development would be beneficial to the overall ecosystem in the area. 3. Moose and elk have also been seen regularly in the area. Minimizing some of the lots to continue to provide habitat will help this development better blend into the neighborhood. Schools 1. What is the date of the public comment period for the Painted Hills PRD project? I believe it was 2016. It is possible the public comments are old enough that an update from the school district is warranted. The boundary area that includes the site is all Central Valley School District and the three schools are on Pines are the closest school to the development. Students from the area will attend Chester, Horizon and University High. The school data needs to be updated. 2. With regards to the schools, much has changed since the original public comment period. A new look needs to be given that includes a global pandemic and its affect on classroom sizes and other school impacts. A new development in conjunction with the other developments that will feed into these three schools needs further review of the impacts. There are enough developments in the area that it may warrant at least one new school being built to accommodate overcrowding. If we are willing to study traffic, we should be willing to study schools. Miscellaneous 1. There need to be more open spaces. Spokane County and Spokane Valley should insist developers build open space into their plans, otherwise they are simply shifting the burden onto the taxpayers and government agencies. The developer needs to have a higher level of ownership and accountability. 2. What water district will this development be in? We use the Spokane Valley – Rathdrum Prairie aquifer like it will last forever. Will the homes have water meters? Will any type of water use accountability be incorporated into the planning? 3. The level of traffic on Madison will increase over time. This is the primary walkway to the schools. Many of us who live in these neighborhoods want our children to be safe and healthy, part of which is being outside. Walking on a street with higher traffic volumes, narrow travel paths and no sidewalks will not benefit the neighborhoods or communities in the area. Please insist Madison have sidewalk / bike path added to ensure safe access to the schools. 4. Given the current housing market and sales price, I do wonder how much Spokane Valley truly believe this will help with inventory. The housing prices in this area will be astronomical. The development will also have an HOA. I don’t believe it will help alleviate any of the low-income housing needs. I believe there should be some obligation for the developer to provide dollars towards low-income options as well as homelessness funds. Otherwise, the developer takes all the profit (and there will be a lot) and leaves Spokane Valley and taxpayers with all the costs. Thank you for providing an opportunity to submit comments to the DEIS. Regards, Leslie L Olmstead 5806 S Lochsa Drive Spokane, WA 99206 509-496-4224