HomeMy WebLinkAbout2026-04-02 PC APPROVED SIGNED MINUTESSpecial Meeting Minutes
Spokane Valley Planning Commission
Spokane Valley City Hall
April 2, 2026
I. Chairman Robertson called the special meeting to order at 6:04 p.m. The
meeting was held in person and via ZOOM meetings.
II. The Commissioners and staff stood for the Pledge of Allegiance.
III. Administrative Assistant Jennifer Musselwhite took attendance, and the
following members and staff were present:
John Robertson
Bob McKinley - Absent
Thomas Dingus - Zoom
Kristopher Pockell
Justin Weathermen
Ann Winkler
Steve Roberge, Planning Manager
Tony Beattie, Senior Deputy City Attorney
Jonny Solberg, IT Specialist
Jennifer Musselwhite, Admin Assistant
There was a consensus from the Planning Commissioners to excuse Vice
Chairman McKinley from the meeting.
IV. AGENDA: Commissioner Pockell moved, and it was seconded, to approve the
agenda for April 2, 2026. There was no discussion. The vote on the motion was
four in favor, zero opposed, and the motion passed.
V. MINUTES: Commissioner Pockell moved, and it was seconded, to approve the
minutes as presented. There was no discussion. The vote on the motion was
four in favor, zero opposed, and the motion passed.
VI. COMMISSIONER REPORT: There were no Planning Commissioner reports.
VII. ADMINISTRATIVE REPORT: Planning Manager Steve Roberge reported the
upcoming schedule. He will be canceling a few meetings and adding in a special
meeting on April 301h. The schedule will resume to regular days beginning in
May.
Date: Planning Commission Minutes
Page 2 of 3
Commissioner Winkler reported that she would not be available at the next
meeting and asked to be excused.
VIII. PUBLIC COMMENT:
• Jim Frank has been reviewing housing affordability as agencies move
through their Growth Management Act. He presented a pdf PowerPoint to
accompany his statement regarding affordable housing options.
• Elizabeth Tellessen submitted a written statement to the Planning
Commission before the meeting regarding a housing allocation
discrepancy.
Steve Roberge, Planning Manager, made a statement about the housing
allocation and where those numbers are derived from.
IX. COMMISSION BUSINESS:
a. Study Session: Comprehensive Plan Draft Element Review
c Chapter 8: Utilities Element - The commissioners took a few minutes to
review some last-minute changes to the utilities element that were not
available before the meeting. Mr. Roberge presented the utilities
element, and the commissioners discussed the element and praised the
changes as they were presented.
Chapter 5: Housing Element and Racially Disparate Impacts Analysis -
Mr. Roberge presented the changes to the housing element. This
included changes to the income distribution to account for inflation.
Commissioner Dingus requested additional documentation to validate
the income numbers. The commissioners discussed the income
distribution and housing numbers. Chairman Robertson requested that
there be some information that shows age as it compares to income
level to determine who is driving the housing needs.
Chapter 11: Climate & Resiliency Element - Mr. Roberge presented the
requested changes to this element. This included the changes to the
vulnerability assessment and a request for any emissions data prior to
2022. The emissions data could be compiled, but it might not be
accurate or comparable to current data. The commissioners asked for
any data on where the city might compare to other jurisdictions. Mr.
Roberge briefly discussed the draft review schedule. There was a
Date: Planning Commission Minutes
Page 3 of 3
discussion regarding the comments submitted and when those would be
thoroughly reviewed. The commissioners also discussed possible map
overlays that they would like to see for housing distributions.
X. GOOD OF THE ORDER: Commissioner Weathermon voiced his excitement for
the process and moving forward with the comprehensive plan update.
Commissioner Winkler is encouraged to see options for affordable single-family
homes. Chairman Robertson gave a statement regarding the 250th anniversary
of the United States.
XI. ADJOURNMENT: Commissioner Winkler moved, and it was seconded, to
adjourn the meeting at 7:49 p.m. The vote on the motion was four in favor,
zero opposed, and the motion passed.
L,Jehn Robertson, Chairman
rio
Denise Mclain, Secretary
04, u`t 2,M,
Date Signed
Planning Commission
Spokane Sign -in sheet
,,;OoWVa11ey- April 2, 2026
NAME (PLEASE PRINT)
ADDRESS
ZipE-MAIL
I PA A .KL
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I
Affordable Housing Options
Small Homes on Small Lots and Townhomes: The
Most Effective Option for Affordable Home
Ownership and Housing families in Low Income
Bands
Misconception: Apartments as the Most
Effective Housing Option for Low Income Bands
Apanm.im.on noromconalma
Ap.nn .onnmff yvuW Wry lode epp�al
.naeuon rasa mnn
A,xxy M.an e.mr911 ltl In
co.Mm linene+M..n. NO land
at oomdom
Apmlmanl do no[ MepMe finely Imo
.nixela^ebh.lb. n
Annlmem4 suer lh. fousing
InedutlM In our COnnunlees
Housing for all income
bands should be be
affordable, resilient,
and located in
connected
neighborhoods and
communities.
1111ftwh.l.1
Variable Housing Construction Costs
Development costs increase as mass, scale and complexity
of the structure increases
• More Complex construction
systems
• I ncreasel life safety and energy
code requirement
• Fewer siting options and higher
land costs
• More complex and fewer financing
options
• Much longer entitlement and
construction time frame6
.l' I
4e$°:� l'
Small Homes on Small Lots Provide Best And
Most Effective Option for Affordable Housing
Small homes and townhomes are fine
lawgt sort housing option
On small Iota single family homes, can
achieve aF density
Small homes laveshotconsnvcdon
lead times and as easier io finance
than aparMwres
Small
homes and mwnhomes easiy
imega. into existing neighborhooM
The Average Cost of Commerce Funded Apartment
Projects: $475,000 per unit and over S500/sf 1/
Average Cost of Habitat Homes in Highland Village:
$255,00 per unit and less than $175/SF 2/
1l Depaanem of Oanmerce Housing Tmst wnd Pmjeo s4 2,1
2 Habiat for Humariy Spokane
The regulatory rules favor apartment
Smaller Homes on
development over home ownership.
Small Lots 1
,
I
I
This is an essmple of now smalls
Mmes and be clusters on ypcal
The construction of small home on small lots
city blocks.
is constricted by a signifant shortage of land
or
The onas fanbe softao ort
ttUnits o groups a two or lnma
inventory, lot size and frontage standards and
Raohcnaaapeaald ,,oAdas
very complicated lot creation rules and
°`"° edwnersnp
l
process that can take years to complete.
and thus story homes using Two
hared dr.
-� -.
Attached Small Single Family Homes
of :<.
,1 ,g
Habitat Cottage Homes 5225,O0O Construction Cost
Highland Village in Airway Heights 2025
One and T,vu story Cottage
Homes 1200-140Csf
Lot Size 3000 SF
Construction Costs $175/sf
Units ere finery integrated into
and existing neighborhood
Clustered and Attached Single Family Homes
Achieve Net Density Similar to Apartment Projects
Single Family Detached and Attached
construction Cost: $175 SF
Net Density Range: 12-18 DU/acre
Construction under International Residential Code
(IRC). Simplified building permit review. Plans can be
pre -approved. Plans do not require licensed architect
or civil engineering. Limited or no parking
requirements, can take advantage of on street
parking. Units can be finely integrated into most
neighborhoods with SF or MF zoning providing
greater choice and opportunity to families.
Muilti Family Consturction:
• Construction CO=$ago-Sa00 per square foot
- Net Density Range: M-30 DWacm
Construction is governed by UBC. Projects tend to be larger 100 units
or more. Require detailed civil engineering plans for utilities, access
and parking. Detailed stormwater engineering plans. Geotechnical
soils analysis. SEPA review and traffic impact analysis. Elevators,
hallways and secondary stairway systems. Development of detailed
fire protection systems and fire wall protections. More complicated
appraisal and construction financing costs. Significantly longer
development timelines and construction phase interest expense.
Limited to high density MF zones in high land cost areas.
Exhibit 13. Estimated Housing Unit Capacity by Income
Percent AMI
Allocated
TOTAL
and Special
Housing
Surplus or
Units
Housing
Housing
Need
Capacity
Deficit
Requiring
Income Level
Needs
(Units)
(Units)
(Units)
Subsidies
Extremely Low
0-30%PSH
1353
1.380
141
(1,239)
(1,239)
Extremely Low
0 - 30% Other
4966
4,713
141
(4,572)
(4,572)
Very Low
> 30- 50%
7697
2,811
1,201
(1,610)
(1,610)
Low
> 50 - 80%
1646
378
6,467
6.088
0
Moderate
> 80. 100%
eel
583
1,709
1,125
0
High
> 100- 120%
823
694
945
251
0
Vuv WnA
, IIAW
$440
s, inn
9 d71
1e7
n
Source: CAI, 2025
Note: Final housing unit allocations by income band have been reduced by a total of 3, 795 units from the
HAPT figures in Spokane Valley's original allocations to reflect permitted units in projects built since 2020, per
Department of Commerce guidance.
Note 2: The projections assume that the entirety of housing units for 0-3096 income will require subsidies,
Incentives or other measures. Similarly, the above projections assume a portion of units in the 30-50%
income bend will be produced bythe market and additional subsldyls required to produce the necessary
units.
Supportive Housing
The 2023 update to the comprehensive plan process stipulates that housing unit inventory
include projections for housing units by income level as well as emergency housing,
emergency shelters, and permanent supportive housing. It also must identify sufficient
capacity of land forgovernment-assisted housing, group homes and foster care facilities.
Permanent supportive housing (PSH) is defined by the State legislature as subsidized,
leased housing for people experiencing or at risk of homelessness and living with a
disabling condition.' PSH is a long-term housing solution and is included in housing need
projections as a subset of 0-30%AMI income band. Emergency housing meanwhile is
defined as temporary accommodations for households experiencing homelessness or at
imminent risk of becoming homeless.' The capacity for emergency housing Is evaluated
Independently from that for permanent housing. Group homes, while not defined by
legislation, are commonly defined as residential environments for people with mental or
physical disabilities, such as adult family homes."Foster care facilities, or foster family
' RC W.3e.070.030
bld
' MSRC, Gicup Homes
Spoknur 0ff4rr
Bank otAnrzdca I4nrnaat Cerra
601 W. RlvenW. Sake 1900
Spalane, WaAiagwn 99101-0695
Phan. 1509) 838 6131
Fxo(509)838-14%
oebtita...%b..oaeohru.eam
Elizabeth Tellessen
eatGDwinstoneashall.com
April 2, 2026
City of Spokane Valley
10210 E. Sprague Ave.
Spokane Valley, WA 99206
Via Email to Council Members
vim" 14 g�"W
L A W Y E R S
A Ponfnrionrtl Servirr Cerparnlian
Irgmron f Ckd oI., ff,,r is Speknnr, Irarki„gmu
old eNur d'Akrn, /A W
Re: City of Spokane Valley — Housing Allocation Discrepancy in 2026-2046
Comprehensive Plan Update
Dear City of Spokane Valley City Council:
We represent Greenstone Corporation, which has requested our assistance in pointing out a
procedural and legal concern regarding the housing allocation used by the City of Spokane Valley ("the
City") in its 2026-2046 comprehensive plan. Growth planning under the Growth Management Act
("GMA' is an inherently complex and collaborative undertaking, requiring coordination among the
county, municipalities, regional committees, and the public. The integrity of the planning process depends
on transparency, consistency, and adherence to formally adopted frameworks.
The GMA places particular importance on public participation and on the orderly coordination of
planning assumptions across jurisdictions. See RCW 36.70A.020(11); RCW 36.70A.070. This aids the
community in evaluating whether plans are consistent with the adopted cuunlywide framework and with
the statutory requirements governing comprehensive planning. The GMA also specifically requires a
quantitative analysis of how the county and municipalities will serve the population and housing allocations
made for the 20-year planning period. RCW 36.70A. 110(2), .115(1), .215(3).
In this regard, we find the housing -share allocation currently being used by the City differs from
the population -share allocation adopted by the Spokane County Board of County Commissioners
(`BOCC"). (Res, 25-0033) Based on the records available it appears the City's housing -share allocation
has not been adopted consistently with the GMA or guidance from the Department of Commerce.' This
raises questions about the legal basis for the allocation, land capacity and housing analyses, and ultimately
the City's comprehensive plan. We request reconciliation of the housing allocation so that the County and
members of the public can meaningfully understand and evaluate the assumptions underlying the planning
process, and ensure the comprehensive plan complies with the GMA and adequately plans for future
growth. Absent a reconciliation through the proper process the comprehensive plan could he subject of
appeal to the Growth Management Hearings Board ("GMHB"). See RCW 36.70A.330.
t Fndhemsore, bernnse the allocation may be in dirert contravention of slate legislation and the countywide planning policies, the
possibility also exists that the Governor could exercise the sanction powers it is granted under the GMA to resolve this issue. See
RCW 36.70A.340.
Beverly L Anderson
Hannah M. Jonas
Dalton J. Reynelds
Cuurbrey B. Whitten '°
Carl E. Hatter
Patrick J. Cronin "
Collette C. Leland'"
Gabrielle C. Roth
NaneyL, berths
Damn M. Daie.irt.-
Christine M. Meegan
Ehaaberh A. Tellessen '^
Ofce,
Richard W. Relyea
sent, A. Ging.--
Anm K. O'Qtinn
Christina Vogel n
C. MMthew Andersen '°
JettyR. Re,
hlichnelT Howard''
Baganua H. RawofP'°
Zad.ary M. Walls '°
KevinI Cuais
Lueivias. Whaley
Arl /myersndnuneAks WA. LmyersndneineAln ID, MT, nnANYaainAinre2
April 2, 2026
Page 2
To aid clarity and understanding of the issue below is a timeline of events resulting in the City's
allocative baseline being different from the BOCC's adopted allocation and why this ought to be resolved
prior to adoption of the comprehensive plan.
1. Adopted Methodology vs. Applied Allocations'l'Imeline
The BOCC adopted the preliminary countywide population project of 654,665 on March 26, 2024.
(Res. 24-0180). A "first round" allocation population growth (100,065 rota] for Spokane County) was then
adopted, allotting 20,913 to the City. (Res. 24-0348) On January 21, 2025, the BOCC adopted Resolution
25-0033, formally approving the "Method A Prime" HAPT methodology for converting the population
allocations to housing allocations for the 2026-2046 planning period ("housing allocation'). See Exhibit
A. The resolution expressly attaches the Planning Technical Advisory Committee ("PTAC") September 16,
2024, memorandum, which notices housing allocations derived from population growth share inputs
("population -share allocation"). The City was allocated 15,713 housing units under Method A Prime. See
id.
At the January 29, 2025, Growth Management Steering Committee of Elected Officials (SCEO)
meeting, PTAC presented a recommendation suggesting that the housing allocations could be based on
"housing growth share" rather than the "population growth share" adopted by the BOCC. This is the specific
recommendation from PTAC to SCEO:
Following a review of the data and the HAPT itself, the PTAC recommends that the region use
housing growth share as the input for the HAPT, specifically a housing growth share created by
applying the same assumptions built into the HAPT tool itself to convert the adopted population
share to housing share. See Exhibit R, al 1.
PTAC then produced a revised set of allocations based oil housing shares (`housing -share allocation") and
presented a side -by -side comparison showing substantial and, in many cases, dramatic changes between
the population -share allocation and housing -share allocation. See Exhibit B, at 3, 4. In this iteration the
City was allocated 16,661 units, a modest increase in the units that need to be provided over the next 20
years. See id. Critically, the housing -share allocations identified in the January 2025 PTAC
recommendation were never subject to public review or comment and were not formally adopted by
either the SCEO or the BOCC.
How the City has utilized the adopted population -share allocation or the PTAC housing -share
allocation is not apparent from its Land Capacity Analysis (2025), which concludes an ability to
accommodate only 6,121 dwelling units and 14,405 residents. See Spokane Valley Land CatoacitvAnalvsis.
Spokane County Steering Committee of Elected Officials Review Draft, at 12 (hereinafter "LCA"); see also
Director of Die Stale Department of Community, Trade and Economic Development v. Snohomish County,
CPSGMHB Case No. 03-3-0017, Final Decision and Order, (Mar. 8, 2004), at 20-22 (holding that the land
capacity analysis is a vital componcnl of the work (hat must be shown during comprehensive planning). To
confuse the matter further the Housing Element Update Summary, March 16, 2026, indicates that the
residential capacity was revaluated "under recent middle housing legislation" and concludes the City is now
planning to deliver 12,866 housing units (March 2026 housing -share allocation) .2
It is troubling Thai the Cily's and PTAC recommendations have not engendered more concern from
the planning staff as the City seems to be planning to underserve its housing allocation, which will
undoubtedly impact the City's ability to provide adequate housing for its growing population as required
by HB I110 and 1220.
c Initial search nfreadily available hdormalion did ant reveal the "Spokane Valley Land Capacity Anatyles, 2026; CAI, 2026"
apparently relied upon for this change, kading In the presumption that this analysis has ant been shared will, Spokane County m
the SCEO for consideration in the roun ywide planning.
April 2, 2026
Page 3
2, Conflict with the GMA's Public Participation Mandate
The GMA requires a comprehensive Plan that is a "coordinated land use policy statement of the
governing body." RCW 36.70A.030(4). The statute requires public participation as part of Ihis coordination.
RCW 36.70A.020(11), .070, and .140. RCW 36.70A.020(I1) identifies 'citizen participation and
coordination" as one of the Act's guiding principles, directingjurisdiclions to "encourage the involvement
of eilizens in the planning process, including the participation of vulnerable populations and overburdened
communities." See also Citizens for Good Governmrce v. Walla Walla County, BWGMHR Case No. 05-
010013 (June 15, 2006) ("public participation is the heart and soul of the UMA."); If'ilrna v. City ofColvifle,
C WUMHB Case No. 02-1-0007 (Dec. 5, 2002) ("A failure in [he public participation process undermines
the very core of the GMA and the legitimacy of adopted or amended comprehensive plan provisions and
development regulations."). Moreover, RCW 36.70A.035 directs that when a change is considered, "after
the opportunity far review and comment has passed... an opporhmity for review and content on the
proposed change shalt be provided before the local legislative body votes on the proposed change."
Further, each plan must include "p)pulation densities, building intensities, and estimates of future
population growth." RCW 36.70A.070(1). 'Thus, "population growth predictions are the foundation of
effective long-term comprehensive planning...Y Spokane Cny. v. F. WashingtrnI Growth Algmt. Hearings
Bd., 198 We. App. 467, 485, 353 P.3d 680, 688 (2015). "Population growth is a fundamental consideration
in making long-range land use planning decisions.... Indeed, all key planning decisionsincluding those
involving public facilities and services, residential and commercial zoning, road and highway design, and
landfill placement, to name only a few —arc contingent on the number of people that must be
accommodated during the planning cycle." Id. at 486.
Thus, the City's reliance on the March 2026 housing -share allocation seems misplaced since it was
not the subject of meaningful public review or comment or approved by the BOCC, which is inconsistent
with the UMA. Cf. Spokane Crry., 188 Wn. App. at 487. This is a substantial modification to the
assumptions underlying the comprehensive plan and therefore requires an opportunity for public review
and comment. See to.; RCW 36.70A.035(2)(a). Absent such review, the City's housing -share allocation
undermines the GMA's fundamental attributes ofpnblic participation and adequate planning for a growing
population. RCW 36.70A,035(2)(a); RCW 36.70A.070. See e.g., Brenton Grp. v. JeffersonC ijo, 159 Wit.
App. 446, 466, 245 P.3d 789 (2011).
3. Conflict with the CMA's Joint Planning Requirement
In enacting the GMA, there was n `legislative awareness that land is scarce, land use decisions are
largely permanent, and, in particularly in urban areas, land use decision affect ... entire communities."
Frickean & Associates, Inc. v. AlcLerrat, 123 Wn.2d 864, 876, 872 P.2d 1090 (1994). Thus, embedded
within the planning goal of public participation is the additional requirement that planning jurisdictions
"ensure coordination between communities and jurisdictions to reconcile conflicts." RCW 36.70A.020(1 I );
RCW 36.70A. 100; see also Diehl v. Mason Cray., 94 Wit. App. 645, 654, 972 P.2d 543, 547 (1999) (holding
that because the population projections used by Mason County and by the City of Shelton are different, the
Board's order of reentering negotiations was proper under the GMA); Thurston Cngt. v. IN. Washington
Growth Alcmt. Hearings Bd, 158 Wn. App. 263, n. 5, 240 P.3d 1203 (2010) (noting that county and city
comprehensive plans need to he eonsislen[ tvnh each other In order to ensure harmonious land use planning,
and thus the fact that the population projections in the Join[ Plan and the Thurston County Comprehensive
Plan are inconsistent is a separate issue under the GMA) (citations omitted).
The City's reliance on its March 2026 housing-shm'e allocation, rather than the 15,713-uni[
population -share allocation formally adopted by the BOCC, creates a material inconsistency with the
countywide planning framework. Tire currently available Countywide Planning Policies for Spokane
County indicate thatjoint planning is needed for any planning issue that is inlerjinisdictional in nature. See
April 2, 2026
Page 4
C t ntinvlde Planning Policies for Stisokarre C Iv ProposedAmendesenis donuari, 29 2025, at 7; see also
King Cnty. v. Cent. Puget Sound Growth Mgmt. Hearings Bd., 138 Wrl 161, 979 P.2d 374 (1999)
(holding CPPs as binding on cities, and that these policies create enforceable coordination obligations).
Where a city applies an allocation that differs from the county's adopted baseline, the resulting plan is not
coordinated within the meaning of the GMA. Cf. Dield, 94 Wn. App. at 654. Absent formal joint
reconsideration, the City's approach risks producing a comprehensive plan inconsistent with countywide
policies unit therefore legally vulnerable based on a lack of joint planning.'
4. Conflict with Commerce Guidance
The Washington State Department of Commerce has issued guidance describing how counties and
cities should idenlify and allocate projected housing needs when updating comprehensive plans under
GMA. See Commerce, Establishing Housing Rwitets for your Commusatr Book I, at 59-75 (2023). That
guidance sets forth recommended practices and minimum standards intended to ensure that housing need
projections are coordinated acrossjurisdictions and applied consistently during the planning process.
Commerce explains that once jurisdictions determine anticipated population growth over the next
twenty years, based on OFM projections and applied through the RAPT, the next step is to divide the
countywide housing needs between the cities, towns and unincorporated county. See to. Commerce
mcommends that this allocation occur through a coordinated regional process involving the county and
par icipalingjm isdictions. Specifically, "Commerce recommends that counties allocate projected housing
needs using a similar process as the locally established process to allocate population targets, working in
consultation with cities and towns." Id. This coordinated process ensures that jurisdictions rely upon
consistent assumptions when conducting land capacity analyses and developing housing elements for their
comprehensive plans.
Commerce also establishes minimum standards governing how projected housing needs must be
documented. Among them, "allocations must be consistent with any relevant countywide planning policies
or multicounly planning policies that address housing." Id. In addition, `the allocation of housing needs to
each local jurisdiction and the sum of housing needs to all jurisdictions should be documented in a public -
facing summary document at the countywide level prior to the periodic update," such as an addendum in
countywide planning policies or a resolution adopted by participatingjurisdielions. Id.
Here, the BOCC adopted Resolution 25-0033 approving the "Method A Prime" methodology and
allocating 15,713 housing units (o (he City for 2026-2046. In reliance on the March 2026 housing -share
allocation the City reduced its allocation to 12,866 units without meaningful public paitieitimion in this
change and in contravention ofCo nmerce's guidance.
5. Conclusion and Requested Action
The public record reflects two materially different housing allocations: (1) the population -share
allocation formally adopted by the BOCC through Resolution 25-0033, and (2) a March 2026 housing -
share allocation without meaningful public notice or comment, or adoption by either the SCEO or the
BOCC. The City's reliance on the March 2026 housing -share allocation we think is in error. We request
the City use the approved allocation of 15,713 units or coordinate with Spokane County to ensure public
'The lack of meaningful joint planning between Spokane County and other municipalities (including the City), is evident in the
fact that there is not a consistent housing allocation being used by the municipalities: Cheney relied on the population -share
allocation (2,535) rather than the housing -share allocation (2,076); Mfloe.d relied on the housing -share allocation (106) rather
than the population -sham allocation (36); City of Sp.k.. mmlyzcd land capacity only against population allocations; explicitly
staling the Final housing allocation remained unresolved, and relying on HAPT Method C; and City of Airway Heights has mlicd
on the housing -share allocation of3,955 units instead of the population -share allocation of 5,007 uuils.
April 2, 2026
Page 5
pail icipalion in the housing allocation as well as consistency in the application of the same prior to adoption
of the City's comprehensive plan.
Very
truly yours, � t
P.nclasures
cc:
Jim Frank, Oreenstone Corporation
City of Spokane Valley Planning Commission
Scott Chesney, Spokane County Planning Director
Steering Committee of Elected Officials
Michael Cathcart, City of Spokane Councilman
At French, Spokane County Commissioner
Albert Tripp, City of Spokane Valley
Joel White, Spokane Home Builders
Michelle Garden, Habitat for Humanity Spokane
NO. 25-0033 --
BEFORE THE BOARD OF COUNTY COMMISSIONERS
OF SPOKANE COUNTY, WASHINGTON
IN THE MATTER OF CONSIDERING THE
SPOKANE COUNTY STEERING COMMITTEE
OF ELECTED OFFICIALS (SCEO)
RECOMMENDATION RELATED TO THE
HOUSING FOR ALL PLANNING TOOL (RAPT)
METHODOLOGY FOR HOUSING
ALLOCATIONS
RESOLUTION
WHEREAS, pursuant to the provisions of RCW 36.32.120(6), the Board of County Commissioners of
Spokane County, Washington, hereinafler referred to as the "Board," has the care of county property and
the management of county funds and business; and
WHEREAS, pursuant to the provisions of Chapter 36.70.040 RCW, the Board has created a Planning
Department, hereinafter referred to as the "Department," and a Planning Commission, hereinafter referred
to as the "Commission" (Resolution No. 76-698 as amended by Resolution 23-0057); and
WHEREAS, pursumrt to RCW 36, 70A.210, the Steering Committee of Elected Officials ("Steering
Committee") was established by interlocal agreement (Resolution 1994A686, and as amended thereafter
from time to time) to assist in the development of the Countywide Planning Policies and perform other
duties, including but not limited to providing recommendations to the Board of County Commissioners on
the same; and
WHEREAS, the Planning Technical Advisory Committee (PTAC), consisting of technical staff from the
various jurisdictions, is tasked with providing a report and recommendation to the Steering Committee on
proposed amendments to the Countywide Planning Policies; and
WHEREAS, pursuant to the provisions of chapters 36.70 and 36.70A RCW, the Board adopted a
Comprehensive Plan for Spokane County on November 5, 2001 (Board Resolutions I-1059 and 1-1060),
which has been thereafter amended from lime to time; and
WHEREAS, pursuant to the provisions of chapters 36.70 and 36.70A RCW, the Board, on May 25, 2004,
under Spokane County Resolution No. 04-0461, adopted a new Zoning Code to implement the goals and
policies of the Comprehensive Plan, said regulation becoming effective June 1, 2004, which has been
thereafter amended from time to time; and
WHEREAS, in accordance with RCW 36.70A.130, the county must review and update its comprehensive
plan and development regulations every ten years, with the next update due by 2026; and
WHEREAS, SCEO held a public hearing on the proposed "A Prime" H"I' methodology on 9/25/24 and
considered comments from the Planning Technical Advisory Committee (PTAC). No public comment or
testimony in favor of or against the proposed methodology was received; and
WHEREAS, after deliberation, the Steering Committee unanimously recommended approval of the
proposed Spokane County "A Prime" HAFT methodology foruse in each constituent's 2026 comprehensive
plans; and
WHEREAS, pursuant to RCW 36.70 A, the county and the cities within it must update (heir comprehensive
Exhibit A
plans based on a countywide population for the 20-year planning period as projected by the Office of
Financial Management; and
WHEREAS, as the regional government, the county is tasked with the adoption of the Countywide
Planning Policies, a part of which includes the adoption of the Countywide Population Projection as well
as sub -allocations of population to the cities within the county; and
WHEREAS, the Spokane County planning commission held workshops examining HAFT on 6/ 13/24 and
7111/24; and
WHEREAS, SCEO held workshops examining HAPT on 5115124, 7/17/12 and 8120/24; and
WHEREAS, the Board of County Commissioners received the SCEO recommendation on January 14",
2025, and set January 21", 2025, to consider the same; and
WHEREAS, at the January 21", 2025, open public meeting the Board considered the recommendation of
the SCF.O, and the Department filed and voted on whether to adopt the same.
NOW THEREFORE BE IT RESOLVED, the Board herby adopts the "A Prime" RAPT methodology
for the purpose of allocating housing units for the planning period of 2026- 2046.
PASSED AND ADOPTED this Z/ sr day of sTQ2025.
�F 60MM/�i
b°NecoU o BOARD OF COUNTY COMMISSIONERS
f, ti•. yM
m,h OF SPOKANE COUNTY, WASHINGTON
•i
ATTEST:
rb4;gHE CpO Mary u ,Chair
Vona Vasquez, Clerk of the Board MiLz�-
Al
French, Commissioner
Amber Waldref, Commissioner
cl
Chris Jordan, Commisner
MEMORANDUM
To: Steering Committee of Elected Ofticials(SCEO)
From: Planning Technical Advisory Committee(PTAC1
Via: Spokane County Building and Planning
Date: September 16, 2024
Re: PTAC Recommendation, Housingfor All Planning Toot methodology
Background Summary
Earlier this year, SCEO tasked PTAC with analyzing possible HAFT methodologies.
During this exploration, PTAC analyzed:
• Methods A and
• Commerce's update of method A(A Prime), wherein the county's share is split between the
unincorporated UGAs and rural areas.
• Custom methods created by other counties (Lewis, King, Skagit, and Snohomish)
o Lewis, Skagit, and Snohomish's custom methodologies were found to be not
applicable to Spokane County.
o King County's custom methodology served as the basis for a Spokane County
proposal that was brought before PTAC and SCEO.
• Two possible custom methods, including
o Weighted transit
• This methodology would have allocated low-income housing partially based
on transit availability,
• Was not carried forward, owing to a lack of support from PTAC,
o lobs to housing ratio
• This methodology, based on King County's custom method, adjusts 0.50%
allocations based on the ratio of low-income jabs (under $40,0001 to low-
income residents.
• Was not carried toward, owing to a lack of support from PTAC.
Options Going Forward
SCEO has two options:
1. Adopt one of the base Commerce methodologies (A, A prime, or B).
a. Adoption ofA prime is recommended by PTAC.
2. Continue pursuing a custom methodology(method C).
a. Any potential custom method will require clear guidance from SCEO on what
changes are desired. There is no readily available data to accommodate such an
exploration, so it wouid likely require a significant commitment of staff time.
Recommendation
PTAC recommends using HAPT Method A Prime. Method A Prime uses the same assumptions and
calculations as Method Abut allows for a distinction between rural County lands, unincorporated
UGAa, and the incorporated jurisdictions. Additional details on this recommendation, along with
the housing allocation numbers based on the current population allocation, can be found below.
Methodology Pros/Cons
Methotl
Pros
Cons
A
Equally distributes housing
Allocates law -income and
levels amongjurisdictions,
emergency housing to rural areas
based an growth projections;
Simplicityand clarity
A Prime
Reserves lower -income housing
None Identified by PTAC
for urban areas;
Avoids placing emergency
housing In rural areas
8
Accounts for existing housing by
Allocates low-income and
allocating fewer units per
emergency housing to rural areas;
Income band to jurisdictions
creates negative housing
that have a larger share of
allocations, the Implications of
housing in said income band
which are not well understood.
than otherjurisdictions
C: Low-incomejobs to
Accounts for an additional
What welghtto give the analysis is
tow -Income residents'
piece of local analysis that
unknown;
ratio
factors in housing and
Lack of support from jurisdictions;
employment locations,
Concerns about the amount of
Identifying locations where
time needed to perfect this
iowerwagejobs exist but not
methodology
enough lower cost housing
Housing Allocation Numbers (Corrected)
Total Countywld. Allocation
Method A Prime
HousinS Allocation income Banda
0-306AMI
TWO Nob -PS" PSM 30-SM 50-M 80-100% 1W1203f >120%
Temporary
Emer,amc, Hounkst
75,1841 19,WS 5,714 13,620 9,944 4,772 3,937 18,392
3,037
Uninco maled UGA
22,9d6
6,375
1,830
4.362
2,699 1,456
1,202
5,022
95
Rural Outside UGA
3,534
0
0
0
416 225
195
2,708
0
Alma He Is
5,007
1,391
399
952
569 318
262
1,096
212
Cherry
2,535
7M
202
482
298 161
133
555
107
Over Park
1.023
284
82
194
120 65
54
224
43
F.H.1,11
0
0
0
0
0 0
0
0
0
Utah
0
0
0
0
0 0
0
0
0
Liberty take
6,601
1,8m
526
1,255
776 419
345
1,445
280
Medical lake
179
50
14
34
21 it
9
40
8
Millwood
36
10
3
7
4 2
2
8
2
Rockford
53
15
4
10
6 3
3
12
2
Spa .
0
0
0
0
0 0
0
0
0
Spokane ICItyl
17,550
4,875
1,4W
3,336
2,066 1,115
919
3,840
7"
Slacken. Valley
15,713
4,365
1,253
2,987
1,848 997
823
3,440
666
W.v.
7
2
1
1
1 0
0
2
0
Note: Jurisdictions are NOT required to ensure that these units are built. They must simply
have zoning, regulations and development codes that allow these units to be built.
Housing Allocation Numbers (Original)
TotalOmntywke Allocation
Method A Prime
Housing Allo allon Income Bands
LL304AMI
Total Non-MH PSM 30-50% 50�80% 86100% 1001W!4 >120%
Temporary
Emer ency
Hcud
75,184 19,905 5,714 13,620 8.844 4.772 3,937 18,464
3,037
Unlncorpoaled UGA
22,946
61375
1,830
4,362
2,09
1.456
1,202
5,022
973
Rural DUUIde UGA
3,534
0
0
0
416
225
185
2.7"
0
Airway Moshe
5,007
1,391
399
952
589
316
262
1,05
212
CMn
2,535
7M
202
482
298
161
133
555
107
We Park
1,023
284
82
194
120
65
54
224
43
F.IHIeIE
0
0
0
0
0
0
0
0
0
1ansh
0
0
0
0
0
0
0
a
0
Ube"take
6,601
1,834
526
1,255
776
419
346
11445
280
Medlollake
179
50
14
34
21
11
9
40
8
Millwood
36
10
3
7
4
2
2
8
2
Rockord
53
15
4
30
5
3
3
12
2
SP NI.
0
0
0
0
0
0
0
0
0
Spokamrianyl
17,550
4,875
1,400
3,336
2,066
1,115
918
3,840
744
5 lone Vall
15,713
4365
1253
2,997
IMH
997
$23
3.440
666
W..Iv
7
2
1
1
1
0
0
2
0
Note: These numbers, which were Included in the original staff report, contain small errors
that Incorrectly represent the current HAPT allocation. These errors have been corrected in
the table on the top of this page.
SPOKANE COUNTY STEERING COATMITTEE OF ELECTED OFFICIALS
1026 w Hwadrcay • Spokaac WA 992W.0170. 509.477. i 500 - bphclpCi.spukanucounty.urg
December 17, 2024
Mary Kuney, Chair
Spokane County Board of County Commissioners
1026 W. Broadway Ave.
Spokane, WA 99260
RE: Steering Committee of Elected Officials Recommendation for the 2026-2046 Spokane County
Housing for All Planning Tool (RAPT) methodology
Chair Kuney and Commissioners,
As required by the Spokane County Tnterlocal Agreement titled Growth Management Act (GMA
Joint Planning) Section 3 D, I am forwarding the recommendation of the Steering Committee of
Elected Officials (SCEO) regarding the adoption of the Spokane County Housing for All
Planning Tool (RAPT) methodology for the planning period of 2026-2046 for use by the County
and constituent communities in planning for future growth and housing allocations under the
GMA.
The SCEO held a public hearing an the proposed amendment on September 25, 2024, and
considered comments from the Planning Technical Advisory Committee (PTAC). There was no
public comment or testimony in favor of or against the proposed amendment.
After deliberation, the Steering Committee unanimously recommended approval of the proposed
Spokane County 2026-2046 HAPT methodology.
Sincerely,
Al French, Commissioner of Spokane County,
Chair, Spokane County Steering Committee of Elected Officials
Submit to Clerk of the Board with availahle supporting materials (Resolutions, Agreements, Presentations, etc.)
AGENDA SHEET
SUBMITTING DEPARTMENT: Building & Planning
CONTACT PERSON. Scott Chesney, Laurie Carver
PHONE, NUMBER: 477-7212, 509-477-7127
CHECK TYPE OF MEETING BELOW.'
® Regular Legislative Session Agenda
BELOW FOR CLERK'SLrr5 USE ONLY:
Clerk's ResaInfirm No. -0 033
Approved: Majority/tinanimous
Denied: Majurity/Unanimnus
Renews/Amends No.
Public Works No.
Purchasing Dept. No.
AGENDA TITLE (please Provide a reasonably descrioilve agenda tide for this item: Consider the SCEO
Recommendation for the Housing for all Planning Tool Methodology (RAPT)
DESCRIPTIVE SUMMARY (please Provide anliciaaled fiscal and budgetary information & reason for request): On
September 25, 2024, the Steering Committee of Elected Officials voted to adopt HAPT method A -Prime based on the
Planning Technical Advisory Committee recommendation. Method A -Prime allocates housing units based primarily on
the share of growth eachjurisdiction is projected to receive.
FISCAL IMPACT (please provide am0puted fiscal and hudeetary impact with amount and source q(unds
applicable): NA
REQUESTED BOARD ACTION (if any),
Other County Departments Impacted -List any other departments that were notified in advance of this agenda item: Legal
This Item will need to he codified in the Spokane County Code: No
Recommendation for RAPT: Housing Share
PLANNING TECHNICAL ADVISORY COMMITTEE
Report and Recommendation to the Steering Committee of Elected Officials
Periodic Update under the Growth Management Act, 2026 to 2046
Written and Recommended by PTAC, January 2025
Exhibit B
Executive Summary
The Planning Technical Advisory Committee (PTAC) has identified a possible issue with previous runs of
the "ousingfor All Planning Tool (HAPT), which all communities planning underthe Growth Management
Act have been advised to use when allocating housing by affordability for the region. The intended input
for the tool —the data that Is provided to the tool and then used to calculate each jurisdictions' housing
allocation —is the share of housing growth each jurisdiction is expected to accommodate. Unfortunately,
due to unclear instructions, the previous "APT outputs shared with the Steering Committee of Elected
Officials (SCEO) used the share of population growth instead.
Following a review of the data and the HAPT itself, the PTAC recommends that the region use housing
growth share as the Input for the RAPT, specifically a housing growth share created by applying the same
assumptions built into the HAPT tool itself to convert the adopted population share to housing share.
Of note, this recommendation does not affect which method within HAFT is utilized. The existing SCEO
recommendation for the method known as "A Prime' is not affected by PTACs recommendation in this
memo.
The full output of the HAPT, assuming that housing share generated in the way recommended by PTAC is
used, is attached to the end of this memo.
Introduction
Following the SCEO vote to recommend Method "A Prime" when using the HAPT, the members of PTAC
identified that there had been some confusion as to which inputs should be provided to the HAPT when
calculating housing share. As a result, PTAC's Housing Subcommittee met several times in the third and
fourth quarters of 2024 to consider how this might affect the housing allocation output from HAPT. In
essence, it appears to PTAC that the HAPT was intended to be provided with the share of housing growth
each jurisdiction is expected to accommodate, while previous use of the HAPT utilized the share of
population growth instead.
After discussing this at length, PTAC has developed a method for converting the currently adopted
Population Share' to housing growth share, which can then be input into HAPT. This memo outlines the
recommendation by PTAC for doing this, and provides the summary growth numbers for each jurisdiction
that results.
HAPT Method A Prime
At their meeting on September 25, 2024, the SCEOvoted to recommend the use of the "A Prime" method
in the HAPT. Throughout this discussion and recommendation by PTAC, no change to this method is
anticipated or recommended. PTAC feels that SCEO's original recommendatim adopted on September
24, 2024, does not require revision to accommodate PTAC's recommendations herein.
' Adopted by OOCC Resolution 24-0348 on June 18, 2024.
Page I 1
Housing Share versus Population Share
When PTAC and SCEO previously saw the "A Prime" results, it was always using the share of population
growth assigned to each jurisdiction per the adopted allocation'. However, after multiple conversations
within PTAC and with Commerce staff, it was apparent that the Instructions in HAPT were unclear and
that the tool was instead asking for the share of housing growth.
The share of population growth and the share of housing growth are directly related to each other, but
due to certain factors they are rarely the same number for a given jurisdiction. For instance, household
size (people per household) in each jurisdiction is not the same nor does it stay static over time.
Household size is continually changing from year to year. Furthermore, somejurisdictions contain a larger
amount of group quarters housing (i.e. college dorms, prisons, treatment centers) and that rate changes
over time. Those living in group quarters do not require additional housing units, thus they must be
subtracted from the overall population growth share for each jurisdiction.
Because of these factors, it is important to develop a share of housing each jurisdiction for the entirety of
the planning horizon (through 2046), not just today. Jurisdictions differ from each other and some
attempt to differentiate their allocations accordingly should be made as well.
A Note on the Underproduction of Housing
An additional factor has been raised by public commenters and PTAC members that is worth discussing
here. That factor is the known historic underproduction of housing statewide. Commerce's research has
made it clear that development in Jurisdictions across the state have been lower than what is required to
house existing populations. As a result, many Jurisdictions' current housing stock is already too small to
accommodate the need of the existing population, not to mention the growth that is coming.
It is Important to note that HAPT factors this underproduction into its results. Accordingly, the number
of housing units a jurisdiction may be allocated when using HAFT will appear high when compared to
population growth. This is specifically because HAPT attempts to also allocate sufficient housing to
accommodate the recent underproduction of housing as well as future growth. This condition is true
regardless of which input is used for HAFT.
Determining Housing Share
The Department of Commerce has not provided Jurisdictions with a method for calculating housing
growth share. Likewise, GMA does not mandate that Cities and Counties use a particular method to
develop housing share. However, the PTAC subcommittee found that the HAPT itself provides one
possible method.
While PTAC spent considerable time exploring other ways to convert population growth to housing
growth, ultimately PTAC felt that because the resulting housing share would be input Into HAFT, it was
most defensible to use the assumptions already built Into HAFT to calculate housing share. That way, the
same set of assumptions would be applied to all parts of the tool and any unintentional bias or
modification of results would be minimized.
' Adopted by BOOC Resolution 24-0348 on June 13, 2024.
Page 12
EssentlaIly, the housing share for each jurisdiction would be calculated directly from the population share
already adopted by the BOCC. While It is more sophisticated than can be expressed simply here, the
method for calculating housing share from population share is generally' as follows:
[(Population Share -Group Quarters Population) / Household Size] 4 694 to Account for Vacant Homes
For the purposes of the HAPT, the tool assumes that household size is shrinking overtime and that each
jurisdiction will see the same share of group housing in the County as they are in 2020. The resulting
housing share for each jurisdiction and area Is as shown in the following table. Again, when considering
the resulting housing share, the following should be kept in mind:
• Population share and housing share are not the same thing, though they are related to one
another.
• Housing share in the tool is somewhat elevated to account for historic underproduction of
housing.
Table 1: Population and Housing Share Compared
Share:
Share:
Share:
Share:
-
Population
Housing
Population
Housing
Jurisdiction
Growth
Growth
Jurisdiction
' Growth
Growth
y
Spokane County (Whole)
100.00%
100.00%
Airway Heights
6.66%
5.26%
All Unincorporated Areas
35.21 %
31.14%
Cheney
3.37%
2.76%
Unincorporated Rural
4.70%
8.24%
Deer Park
1.36%
1.44%
Unincorporated UGA
30.51%
22.81 %
Fairfield
0.00%
0.00%
Incorporated County
64.79%
68.95%
Latah
0.00%
0.00%
Liberty Lake
8.78%
6.89%
Medical Lake
0.24%
0.44%
Millwood
0.05%
0.14%
Rockford
0.07%
0.09%
Spangle
0.00%
0.02%
Spokane
23.34%
29.74%
Spokane Valley
20.90%
22.16%
Waverly
0.01%
0.02%
As shown in the table, when comparing population share to housing share, some jurisdictions are
expected to accommodate a lower share of housing growth than population growth (e.g. Liberty Lake)
while others are shown to expect a higher share of housing than population (e.g. the City of Spokane).
Why this happens is complex and due to the fact that HAPT uses multiple factors from multiple sources
to determine these amounts.
Because the HAPT only has one input for each jurisdiction -share of housing growth -those jurisdictions
where the housing share is larger than population share can expect their housing number output from
HAPT to Increase when compared to the sample outputs discussed by SCEO previously. Conversely,
'The assumptions in HAM are more sophisticated than this, accounting for changes over time and each jurisdiction's
share of certain values. Replication of the numbers herein by using this simplified equation should not be considered
when evaluating this recommendation.
Page 13
jurisdictions with smaller housing share than population share can expect their HAPT output to decrease
over earlier results.
Comparing HAPT Results from Prior Versions and Now
As a handy comparison of how overall housing
allocations would change when housing share
Table 2: Comparison of HAPT Total
Housing by Jurisdiction
is input into HAPT rather than population
Total New Units
share, the table at right lists the total housing
_
Change if
Using
using
Using
allocation using both Inputs. Also shown Is
Pop
Housing
Housing
whetherthetotal housing units would increase
Jurisdiction
Share
Share
Share
or decrease for each jurisdiction when using
Unincorporated Rural
3,534
6,195
Higher
housing share, as the tool intended.
Unincorporated UGA
22,946
17,142
Lower
While housing share is the intended input for
Airway Heights
5,007
3,955
Lower
HAPT, using housing share would Increase the
Cheney
2,535
2,076
Lower
housing allocation to the rural areas (outside
Deer Park
1,023
1,083
Higher
the UGA). To a greater degree, the larger
Fairfield
0
0
Higher
jurisdictions would also be subject to a larger
Latch
0
0
Higher
allocation.
Liberty Lake
6,601
5,180
Lower
Medical Lake
179
329
Higher
It's important to notethatwhile this represents
Millwood
36
106
Higher
a large change for some jurisdictions, increased
Rockford
53
68
Higher
allocations to those communities in the center
Spangle
0
15
Higher
of the UGA (CityofSpokane, Spokane Valley) is
Spokane
17,550
22,359
Higher
consistent with the requirements of GMA,
Spokane Valley
15,713
16,661
Higher
wherein growth should be concentrated in the
Waverly
7
15
Higher
UGA and limited on the edges.
While the allocation for unincorporated rural areas would be more than 314 larger, that increase would
be spread throughout a very large area (all parts of the County outside the
UGA), tempering
the
effects
of that growth somewhat. Furthermore, urban
scale services to those additional homes
would
not he
required due to their location.
PTAC Recommendations: Housing Share and HAPT
Following multiple discussions on the differences between population share and housing share, PTAC
generally feels that housing share, created using the same assumptions already built into the HAPT, is the
most defensible and effective input for the HAPT. The following benefits of using housingshare discussed
were as follows:
• The assumptions used to generate housing share from population share are Identical to those in
the HAPT now.
• The HAPT model is sophisticated —an adjustment in one variable can have unintended
consequences.
• The data used togenerate housingshare have already been considered and adopted by the BOCC.
Page 14
Final Results
If the share of housing growth indicated in Table 1 In Input Into the HAPT, and the method previously
described as Method A Prime in the SCEO recommendation is utilized, then the final housing allocation
shown in the attached spreadsheet is provided.
Page 15
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