Climate Chapter

City of Bellingham Comp Plan Update Review

Thank you for your work on this important Comp Plan update. The materials offered as review of Comp Plan chapter updates via PowerPoint are ineffective as the content is strictly a conceptual outline. There is no detail to review. These chapters are more closely scoping documents submitted for comment before the actual work is conducted. Although providing the public with opportunity to comment is always welcomed, we question the effectiveness of issuing PowerPoint presentations that only provide a very rough conceptual-level of detail that sumarrizes what the City plans to do. Given that fact, we offer the following comments on both the Climate and Environment chapters.

Climate Chapter:

Slide 1:
The “Climate Chapter” is only a PowerPoint presentation with broad concepts presented but no detailed text. This is not a plan because it is an outline of topics to be fleshed out. A person may agree with the concepts in the PowerPoint presentation, but disagree on how the actual plan text, which has not been developed, is developed. This is a disservice to the public that the City serves. The Comp Plan update and review process should be paused to allow time for the actual chapters to be written so as the public can actually review a plan, not just an rough outline of concepts.

Slide 2:
It is unlikely that the legislature intended that an outline of topics would comprise a Comp Plan.

In order for the Bellingham community to understand the concepts in this chapter and be able to provide effective informed comment, COB needs to provide actual detailed text, not just a power point presentation.

We agree that the topic “Climate” is important to the health, safety, and well-being of the community. However, providing a PowerPoint outline as a surrogate for the detail that should be in this chapter is ineffective.

Slide 3:
If this chapter was fully scoped, it is likely that many additional common opinions would also be listed. “Common opinions” is a very subjective term. This is an example on why a PowerPoint outline will not replace the need for an actual text chapter.

Slide 4:
It is difficult to comment on a topic or process that is only outlined at the highest level of generality. The referenced “Summary of Proposed Updates” has even less detail in it than the powerpoint presentation.

Slide 5:
Planning for climate impacts on water supply will be a part of this chapter, but no detail is provided. There are several landmark research projects and reports that evaluate the impacts of climate change on water supply and should be utilized in addressing this topic. One of the most significant impacts of climate change will be water availability and water supply. Climate change will significntly decrease streamflow in the rivers and streams of the county, which impacts COB water availability and should be taken into consideration in growth-related planning processes.

It is good to see the new chapter content will utilize an existing program and source of relevant information on low-impact development. Measures identified as low-impact development will assist in climate change mitigation and adaptation/resilience planning.

Slide 7:
Slide 7 is missing.

Slide 8:
Although climate impact mitigation is an important approach to addressing climate change impacts overall, this chapter should also address climate change adaptation and resilience planning as mitigation alone will not be enough to offset such impacts.

Another topic area should include heat island effects and heat loading caused by development and the loss of forest cover/native vegetation cover and increased atmospheric temperatures that may not be “extreme weather”, but the new normal.

Slide 9:
It is surprising to notice that water supply is not mentioned as a specific topic area as such will likely be one of the most significant climate change impacts affecting our community.

“Extreme weather” is only part of the issue over weather—the issue is the new normal with continued climate change that should be directly considered.

Again, given the gravity of reduced water availability and supply with continued climate change, these should be a specifically identified topic area to be addressed in the updated Comp Plan. The list of topics seems unrealistically limited given the importance of water supply and other natural resource elements in the context of climate change impacts, mitigation, and adaptation/resilience planning.

Slide 10:
No comment.

Slide 11:
No comment.

Slide 12:
No comment.

Slide 13:
The impacts of continued climate change and extreme weather on water availability and supply should be listed as a topic.

Slide 14:
The issue with wildfires isn’t just smoke and resiliency, but should explicitly include the change in wildfire frequency, intensity, duration, and areal coverage with continued climate change.

Slide 15:
Given the gravity of the impact of sea level rise due to climate change on all existing shoreline buildings and infrastructure, mitigation needs to be comprehensively spelled out.

Slide 16:
Congratulations, finally water supply is explicitly listed in this new chapter per this slide. The impacts of cliamte change on water supply may be one of the most significant topics that this chapter should address.

Slide 17:
“Ecosystem resiliency” must involve evaluating existing regulations for effectiveness in promoting resiliency. There is a concern that development regulations, legacy tree ordinance, and the urban forest plan may be at odds. For instance, the City has goals to increase forest cover, yet develoment involving the removal of forest cover may atoccur at a faster rate than increased forest cover or effective ecosystem recovery. This inconsistency should be addressed in this chapter.

Slide 18:
“Mitigate building emissions” should also address the use of concrete and the high rates of greenhouse gas emissions in the process of producing raw cement and concrete materials.

Slide 19:
“Mitigate transportation emissions” should also include traffic signal sequencing to conserve momentum energies by providing more continuance of travel through intersections as opposed to traffic backups waiting for green lights with engines running. The City does this with Holly Street signal sequencing. Also, hybrid vehicles should be expliicitly itemized in addition to EVs as hybrid vehicles use less fossil fuels and turn off while at a standstill at a stop sign or red traffic signal.

Slide 20:
No comment.

Slide 21:
This slide show is a rough and generalized outline and is not a substitute for a comprehensive text chapter. There is simply not enough detail presented to comment on.

Slide 3: The commenters stating that the cost to housing choices will be impacted by climate action and that transportation, housing, and land use are "intertwined" are absolutely correct. Recently, many of these subjects seem to have been considered in a vacuum, separate and apart from the plan as a whole, and the deficiencies in that approach, which have plagued plans before, is becoming more and more apparent. At present, the most glaring issue is the reliance on the Urban Forestry Management Plan, a draft plan, which is supposed to inform many aspects of the plan including housing and climate. That plan, at present, seems to have stalled yet the implications from that plan when adopted have the potential to derail so much of the comprehensive plan.

Slide 5: Transportation emissions are a very large consideration for climate planning. Yet, with the extreme costs of housing in Bellingham, it seems the city fails to realize that poor housing policy has created increased travel from Whatcom's smaller cities and rural areas. If Bellingham continues to adopt additional ordinances placing new restrictions or requirements on housing construction, the people moving to Bellingham for employment will only add to increased car traffic on the freeway and state highways connecting Bellingham to outlying areas. This "drive to qualify" housing plan that Bellingham seems to have adopted is only adding to transportation emissions.

Likewise, planning for water impacts seems to be lacking. The Bellingham Water Advisory Board just met to consider the city's 20-year water plan and there was not a single mention of the WRIA 1 (Nooksack) water adjudication. How is the public to take a water plan seriously when that plan fails to even acknowledge what is likely to be the single most impactful action on water resources in Whatcom County for the foreseeable future. Will Bellingham be called upon to serve a larger area than just the city? Will Bellingham's senior water right be necessary to serve rural areas and supplement jurisdictions that have exceeded those jurisdiction's rights? If the smaller cities are no longer able to accept additional population due to water limits, how will Bellingham plan for absorbing the additional population? These are very important questions for which there seems to be no plan.

Also related to water, it would appear that the recent park purchase on Samish Crest will have a direct impact on the city's plan to build three reservoirs and a pump station in that vicinity. Parks have an important climate role, but when the parks directly interfere with plans for water resiliency, it would appear the plan is incomplete. Interfering with the water construction also has a direct impact on the housing that might be constructed in that area.

It appears the plan also relies on trees for carbon sequestration as well as calling out collaboration with county hazards. The immediate question, again related to the Urban Forestry Plan, would be to what extent the city's tree/carbon plan impacts and informs the county's wildfire resiliency plans.

Slide 8: One of the biggest questions from this slide concerns the city's ongoing investment in the Post Point Water Treatment facility vis-a-vis sea level rise. Even the city's water plan only considers continuing investment for increased capacity at that facility and makes no mention of future siting or detailed plans for resiliency at that plant.

Slide 12: The plan calls for limiting impacts on "vulnerable communities." I would posit that one of the most vulnerable communities are those experiencing housing insecurity. Without shelter, community members become exposed completely to climate events. One of the single largest contributions to equitably distribute climate resiliency would be to construct sufficient housing so as to make shelter available to our citizens. Affordable housing located in proximity to services and amenities, constructed with technology readily available at this moment to both heat and cool spaces with little energy, should be easily accomplished, yet over 50% of Bellingham citizens experience some level of housing insecurity. The single largest contributor to human flourishing in history has been the ability to control our environment through shelter, yet the city continues to adopt regulations and restrictions making the construction of that shelter increasingly difficult.

Slide 14: The plan appears to include a portion related to wild fire resiliency. What will be interesting is how this policy will "square" with increased protection of "landmark trees," trees that nearly by definition are on the last one-half of their life span, the time when disease and declining health are most prevalent. Moreover, the UFMP's call to increase the city's canopy cover only means that fires originating in the rural fringe of the city pose an increasing threat to flames moving into the city due to the increased tree canopy. This is why the terms of the UFMP are so important to know before committing to the growth policies in the comprehensive plan.

Slide 15: See comments above on the waste water treatment plant.

Slide 16: Again, it would not appear that the city has adequately considered the impact that the WRIA 1 Adjudication may have not just on increased demand on the city's senior water right as Whatcom's smaller jurisdictions approach the limits of those rights, but also the increased population that will result as those other jurisdictions are unable to accommodate population growth.

Slide 18: Building preservation is an important goal, but it must come with the recognition that retrofitting existing building to adopt new heating and cooling technology can be very expensive. Building preservation should consider the need for additional affordable housing and ensure that preservation as a goal does not thwart our desperate need for housing.

Bellingham should pursue electrification and energy efficiency opportunities in municipally-owned buildings and electrification of municipal fleet vehicles as a Policy in the comp plan.

Climate New Policy C-31 fails to account for the significant conflicts between historic preservation and climate action. While preservation is often framed as a sustainability strategy, in practice, it frequently serves as a barrier to necessary climate measures and housing production.

Older buildings were not designed with modern energy efficient systems and approaches. Upgrading insulation, windows, HVAC, and roofing can reduce energy in existing buildings, but may alter the historic nature of the structure. Additionally, it may be more cost-effectively retrofit old buildings to meet building efficiency standards, let alone other considerations related to floodproofing and seismic retrofitting. Historic preservation ordinances frequently limit energy-efficiency upgrades such as double paned windows, solar PV, or other desirable climate measures that could be considered incompatible with historic character. In many cases, historic preservation serves as a tool to block new development rather than a genuine effort to protect historically significant sites.

Preservation policies that lock in existing land uses can also hinder urban densification, which is critical for reducing car dependency, expanding public transit, preserving green space, and preventing sprawl. These land use constraints also have significant implications for housing production and affordability, as discussed in other chapters of the Comprehensive Plan.

While arguments about embodied carbon are often used to justify preservation, these benefits must be weighed against the long-term energy inefficiency of aging buildings and the opportunity costs of restricting denser, lower-carbon development. Policy C-31 should better reflect these trade-offs to ensure that preservation and reuse of old buildings and climate action work in tandem rather than at cross-purposes.

Thank you for the work done on the new chapter.
I would like Bellingham to stop providing for migrants (regardless of the whether it's due to global warming), to stop encouraging growth. This place has become so overcrowded now already (like everwhere else), and promoting further growth BEFORE updating infrastructure (e.g. transportation engineering) to accommodate further growth is dumb. If folks want to (understandably) escape some armpit of the world (e.g. Texas), let 'em relocate somewhere else rather than come here to turn Bellingham into the next overcrowded, smelly armpit. So, in the interest of climat resliency (as in more people equals more pollution of all sorts), Bellingham needs to prevent further mass-residency development, for it is well past the stage of being sustainable.
Thank you for your time and attention to my input.

I'm glad Bellingham is developing a plan to address the impacts of climate change. I think a lot of comments misunderstand the reason for housing unaffordability. It's not climate policy. Reducing the need for cars to get around town goes hand in hand with meeting climate goals and making our city more friendly to people without access to cars, or who would like to leave theirs at home more often. It's smart to get ahead of any global/national changes that are inevitable. Some commenters think the policy laid out here is a waste of time and money because we can't have "any measurable impact" on the climate as a city. Thankfully the city (and state) see the writing on the wall and know if we don't make change now it will only be more expensive in the future. Electrification is the future, regardless of politics. If we don't develop more efficient ways to build communities we won't have green spaces left. The list goes on.

I forgot to add one major drawback of public transport: girls' vulnerability to touch from boys and men.
I grew up in a big city and used buses a lot. Although it is not customary to talk about it out loud, but in crowded buses men touch girls on various parts of their bodies and press themselves against them as if by accident. Protect yourself, your wives and daughters (and boys too). Cars are not only convenience and pleasure, they are also much-needed privacy.

I read the previous comments - it feels like the mayor's office has ordered its employees to leave their opinion on what they are planning to do, lol.
I don't know what kind of feelings you have to have to advocate for changing transport to bicycles/electric bicycles in our city, where it rains 8-9 months a year, where most of the city is located on hills and has flooded lowlands. Guys, if you personally want it and you have enough strength and health, it is your right. But as a mother of a disabled child, your option is absolutely not suitable for me; for my neighbors, two elderly people who already walk slowly, your option is not suitable; for the majority of people with dogs who want to take them out of their apartments to places for walking, your option is not suitable. You want to increase public transport. Ok. But you forget that a huge number of people go to the mountains, to parks, beyond the bays; people travel around the country. People will not give up cars in favor of buses because there is no alternative here. Having a car for occasional trips is expensive in terms of insurance. Do you want to lock everyone in apartments and leave the means of transportation as a luxury? Let people have a decent life, isn't that what all the progress is for?

I am also against the wholesale introduction of electric cars. Let's be honest - they are not yet safe enough and do not have a sufficient resource to be able to drive them safely. Equip enough electric charging stations in the all state (at least), then we can talk about the mass introduction of electric cars. Although I personally do not consider them more environmentally friendly: there are no exhaust emissions directly in the city, but they are in places of production - the climate as a whole does not benefit much from such a rearrangement. It would be better to stop cutting down green areas of our city: because trees absorb carbon emissions. Obligating developers to properly green the territory is a good idea.

#1 Prevent suburban sprawl

#2 Increase access for public transportation and make it more convenient and affordable than driving.

#3 Build fully divided bike lanes across the city and safe covered locations at public transport hubs.

#4 Build urban village concepts in each area of town thus reducing the need for daily commutes and errands across the city.

Thank you for making a plan for climate change. The impacts are going to be devastating and we'll be better off if we prepare now. I am strongly in favor of protecting and planting trees to increase biodiversity and keep this amazing place an oasis of nature. To address the affordability and supply of housing, I recommend a "mansion tax" like the one that they passed in L.A. It's a tax on all real estate transactions above $5 million, and the funds are used to pay for 1) affordable housing and 2) programs to prevent people from entering homelessness. I read an article about it today and the funds are already making an impact on people's lives. As a Bellingham transplant, I think I should have had to pay a tax when buying my house, to offset the impact that my moving here has had on housing prices. We could set the threshold lower since L.A. is a much wealthier place with higher home values. Hope you all will consider this!

Part of mitigation is forest protection, adding canopy and green infrastructure. The emphasis is on energy use, but this is reduced by sustainable practices in our landscape. I’d like to see more emphasis on sustainable practices.

Buildings should not just be bigger, but taller rather than bulky. Providing for open space around buildings and sufficient areas for infiltration, trees and habitat should be incorporated on every parcel.

Heat island effect should be addressed throughout, making shade a priority and open expanses of pavement limited. Parking lots could be converted to housing, but where they remain they could be part of efforts to reduce heat. Current standards for streets and parking are going to result in increase in heat and pollution.

Urban forests and green infrastructure should not be add on attributes, but bottom lines for building. Our inequities in building have been exacerbated by lack of serious enforcement and planning for open space and canopy. Low income areas have less access to nature and less canopy, this has to be reversed.

Under climate equity, reach out to disability community to incorporate those lived experiences in the conversation.

Climate change is the single largest issue of our time - and is connected to other issues of affordability, quality of life, healthy ecosystems, and community care that should all be guiding priorities. I fully support GHG emissions reduction work and climate resilience measures. In particular the City has a role to play in gathering resources and helping residents access them. Please keep in mind that housing affordability and job availability are big concerns for many residents amid the growing wealth gap in town. Tenants should not bear the brunt of any buildings/energy measures.

I agree with the Whatcom Environmental Council. It's beyond time to start getting more specific about the areas the city can make the biggest impact.

As a scientist, it's clear we need to end car-dependence. This includes *safe* bicycle infrastructure (*separated* bike lanes or paths), covered bike parking, more support to WTA, and more investment in accessible sidewalks.

The other key is zoning and reducing heating/cooling emissions per capita - we need to have pre-approved designs for developments that use sustainable, local materials as much as possible. Pre-approved designs remove a lot of the permitting cost of new building. We also need to be up-zoning single-family housing into duplex+. The city should consider eminent domain for abandoned or neglected properties, then building / renovating these properties and selling at cost. Lakewood, Colorado is doing something similar.

I see tons of local solar power projects but no wind-power projects, why?

We also need to think about local long-term energy storage solutions that will make Bellingham's grid more independent and self-sufficient. We cannot rely on PGA to get us to the level of sustainability and resilience that we need to be at.

The topics important and relevant for Bellingham's current phase of widespread development. So far the proposed concepts of ecofriendly development, efficiency and sustainability are general ideas somewhat related to the specific type of proposed projects that seem already committed. ***The plan needs to include clear and direct language regarding the city's accountability to uphold the proposed claims and commitments to "CO2 sequestering, low impact development techniques, transportation-related emissions reductions, etc." Moving forward without clear language and descriptions of the "techniques" and methods that will be employed to meet those standards creates loopholes and backdoors to agendas bent on rapid, irresponsible development, and a basic goal only focused on profits. Accountability and consequences MUST be included in the plan.

Your focus on anything having to do about the climate and the impact we will have on it is a joke. Any money, time, or effort you spend on it is a waste of our taxpayer dollars!!! If you truly care about our community and the people that live here you will stop spending any time or money on climate issues and start focusing on the the people that live here and the quality of life that has been lost.Bellingham and Whatcom county used to be a place where I wanted to live, our government has slowly destroyed our community. Stop virtue signaling and start helping the people that live in this once great community!

The City should encourage structures and lifestyles that improve quality-of-life while simultaneously reducing climate and other environmental impacts (climate and nature are, of course, intertwined!). Supporting alternatives to driving in the roads and buildings we build, supporting local regenerative agriculture and rewilding efforts within and outside the annexation lines, and incentivizing the construction of highly sustainable (and ideally regenerative) building designs are all examples of this in action.

Urban design is a key component of our intent to reduce emissions. Encouraging naturally more efficient building types such as apartment buildings and townhomes while also designing transportation infrastructure to reduce vehicle miles traveled (VMT) can significantly reduce CO2 emissions. Unlike cars, electric bikes are much more useful than their traditional version with the common consensus that E-bikes are more likely to replace car trips than traditional bike trips. These can be key tools in the fight to reduce emissions but only if we design for all users of them. If you wouldn't feel safe letting your child use the bike infrastructure, it's not good enough infrastructure.

Sprawled development and auto-dependence are key contributors to climate-altering emissions. We should remove limits on density such as minimum lot sizes, maximum floor-area ratios, minimum setbacks, etc. That would lower the cost of housing, and indirectly reduce rents as well. Sprawl is our #1 enemy, requiring reliance on the automobile and greatly increasing the cost of providing public services such as sewer and water, police, fire, street maintenance, etc., which are unsustainable for city finances. Density got a bad name in past decades, but it is the opposite of sprawl. Dense cities have carbon footprints per capita equal to remote rural areas, whereas sprawl areas have extremely high carbon footprints per capita.

Parking tends to be a problem for those of us (such as elderly) who cannot walk or bike to places/events, particularly with the city's policy of allowing housing with fewer than standard parking available and reducing the downtown parking that is available for either bike lanes or outdoor restaurant seating. The result is one must often drive around to find a space. Two ideas would help: move the portable micropark to a low impact location and changing loading zones that are not needed at times, say on weekends, to loading zone on Monday through Friday, opening it up for parking on weekends.