Land Use Chapter

Land Use
• Actively limit tree canopy removal activities; encourage development that is congruent with natural systems.
• When planning for urban growth, focus on growth in quality and only permit growth in quantity (population, housing units, etc.) where growth in quality can also be managed.

We are eager to see Bellingham's plan for doing what House Bill 1220 calls for - making sure that new homes over the next 20 years are affordable for all economic segments of the community. I'd like to make a friendly wager that the City's Community Development Advisory Board had a good, workable idea for doing that back in August 1990 when CDAB's volunteers proposed a City Council Resolution for an idea they called, "Growth Management Housing Affordability Program." The program's purpose was, "To provide an adequate number of affordable homes for every income group in Bellingham and at the rate of population growth that public spending, services and facilities can accommodate gracefully without burdensome taxation." I would like to provide the City with a copy of the program's methodology. It might be workable if there's enough political will to meet the vision of HB 1220. Thanks for considering this.

Urban and Community Forests
The Growth Management Act has a new requirement to designate urban and community forests within urban growth areas. These designations are required to be included in your Land Use Element, not the Climate Change and Resiliency Element. (RCW 36.70A.070(1)) Your November 2024 Land Use Chapter Update provides no reference to urban and community forests.

We would urge you to identify these urban and community forests early in the process. Much of the City’s parks and greenways are heavily forested and could be designated. We would want to see that these designations include protections to ensure that they remain urban and community forests and not converted to other uses that would result in loss of the forest.

We also note that your strategy includes consideration of expanding into the Samish Crest/Yew Street/Lake Padden area, which is heavily forested, a critical wildlife corridor, and helps protect Lake Padden water quality. This area needs to include open space corridors, as already shown in your Parks, Recreation and Open Space Plan and the forest requires protection and conservation.

Regional Growth Strategy
We don’t see anything in your draft growth strategy that addresses Bellingham’s role in the regional (county) growth strategy. The following are topics that should be discussed.

Water
Water is essential for growth. Water is essential for agriculture. Water is also essential for fish and wildlife. We are at the beginning of a long process to address the adjudication of water right claims in the Nooksack watershed. What role does Bellingham, its water rights, and its diversion of water from the Middle Fork of the Nooksack play in that process? If Bellingham places a priority on water for fish and wildlife, then how might that affect your proposed growth strategy?

Share of Growth
It appears that Bellingham is proposing to assume a greater share of population and employment growth than in the past. Our input on this issue requires additional information that should be found in the SEPA environmental review. We need to see which growth allocation alternative would result in a reduction of greenhouse gas emissions and per capita vehicle miles traveled. If that alternative demonstrates that Bellingham would best accomplish this requirement, then we could support that, and your growth strategies should make explicit the reasons for accommodating additional growth.

Rural Growth
Pursuant to a 2022 Interlocal Agreement, Bellingham is required to consider a density credit program where developers obtain density credits purchased from agricultural lands, rural areas or sensitive watersheds. Density credits should be mandatory for any proposed UGA expansion and considered as a development incentive in other areas.

I strongly suggest and am a proponent of incorp[orating the existing UGA Reserve into full UGA status and simultaneous annexation into the City of Bellingham. These areas have been set aside for this precise purpose nearly 20 years ago, and now is the time to legitimize them into the comprehensive plan update to provide the needed land and urban planning and development flexibility for the city during the next 20 years.

Thank you!

Although these plans are helpful and need to be considered, I think it’s disingenuous to talk about adding more county land into the city limits, converting small properties to multi-dwelling lots, and building more Urban Villages without also addressing rezoning of city neighborhoods where land is already plenty, such as Edgemoor, parts of Birchwood, etc. For instance, making an Urban Village of James Street will raze housing already in existence, whereas short-platting Edgemoor lots for the same would be a 100% net gain of housing. Since UGAs have to be platted and developed from scratch, it seems the same can be done in Edgemoor and other sparsely-populated neighborhoods. Sure, not many people want to live in neighborhoods more dense, especially when they already live in and love their own neighborhood as is, whether Sunnyland or Edgemoor, but some neighborhoods are being transformed to support growth while others are left untouched. It may not be that simple, but it doesn’t seem fair.

An October 2024 power point at a joint Planning Commission and City Council meeting showed that while Bellingham will need 18,443 housing units in order to accommodate the population figure it requested, it only has the current capacity to add 14,370 more units. The presentation listed potential strategies for developing additional housing capacity to make up for the 4,000 unit shortfall. Those strategies are: (1) Residential zoning changes related to House Bill 1110; (2) Code amendments allowing more small-scale commercial services in residential zones; (3) Zoning changes for transit-oriented development corridors; (4) Road, water, sewer, and fire infrastructure investments in Samish Hill/Yew Street area and King Mtn/North Bellingham; (5) Expanding UGA to include North Bellingham UGA Reserve; (6) Expanding UGA to include South Bellingham UGA Reserve; and (7) Additional housing capacity from single room occupancy living situations.
Faced with such an extreme shortfall, the city must develop a diverse and varied plan to make up the difference. All seven of these strategies must be implemented. Any one strategy might not produce as much housing as anticipated, but together, all seven together will provide the resilience needed to adapt to changing situations.
Of all the points, expansion of the UGAs, especially expanding the UGA to include the North Bellingham UGA Reserve, is extremely important. Bringing the North Bellingham UGA Reserve into the UGA will easily add over a thousand new housing units, plus commercial development for a potential town center/urban village. Other strategies, like utilizing the infill toolkit or upzoning, will likely eventually add some new units, but may take time as property owners must choose to add units and fund their projects. By contrast, a proven and experienced developer (Caitac) is waiting for the North Bellingham UGA Reserve to be added to the UGA. In north Bellingham, Caitac has pioneered a large development of all solar powered homes, while responsibly caring for area wetlands.
Though it may be counterintuitive, achieving the city's land use goal of limiting sprawl will require some expansion of its UGA to make certain there is a sufficient supply of a variety of housing for all income levels. If a variety of housing is not available in Bellingham, some home buyers will purchase in the rural areas and small cities. Whatcom County's consultant, Leland Consulting Group pointed out that 18.9% of the recent population growth was in rural areas. This type of development does not allow for efficient provision of services, burdens scarce water resources in rural areas, and locks in longer drive times and higher carbon footprints. More growth should be directed to Bellingham so that this type of sprawl is discouraged. Staff's suggestion of selecting the medium high of Leland's population projection is the minimum number Bellingham should accept for its share of population growth.

We should not grow out, especially into forested areas around our already compromised watersheds (Padden and Lake Whatcom). We need high rises downtown, and to convert all the under utilized and vacant properties there. Land speculation in our community whether it be in downtown, our urban villages or in the the huge parking lots that dominate the north end should not be so profitable. Peace Health has 3 full city blocks that have been vacant for over 20yrs, and the answer is to add acres of sprawl?

Do not increase the size of the city by pushing out into UGAs, especially the Padden north area and Lake Whatcom. New urban centers should be placed in the north areas where much growth is going without amenities. The number of people living downtown is not adequate, and focus should be on downtown high rise development. Under utilized lands like the huge parking lots in Meridian, the Peace Health 3 block blight, Macs motel...the list goes on. How many parcels in downtown are under utilized or vacant? Pushing out into forested areas, and allowing density that does not include open space and trees will increase our heat island, making the entire city (except the most expensive enclaves) less livable. If we have too much single family housing, then the cul-de-sac single family development should not be allowed yet so much of the new areas being developed are exactly this type.

Most concerning is increased traffic in an area already overflowing with traffic congestion. Each new development has added more street parking and more traffic flow. This is right up to freeway entrance N 1-5. Byron St. to turn Left on Lincoln is Very Difficult and at times Dangerous. The focus often is on watching for traffic, yet there is a pedestrian crosswalk to consider that is overlooked. I would recommend a light for the pedestrians crossing at a minimum.

I also forgot to comment on the affordability of the proposed housing development on the Samish Crest and above Wildwood. This would not be affordable for most people due to the views from up there. If density is the goal, the value of the land doesn’t seem to match with stated purpose of development.

We live on Samish Hill and are very concerned about the proposed annexation of the Samish Crest and Samish Woods above Wildwood and proposed housing developments that have been discussed over the last few years. Access to these areas is currently extremely limited-currently Wildwood is the only access up there. The current access and egress off of 40th St to Samish way and to the areas west of I-5 can’t handle to volume of cars that will be anticipated to be driving. There are only 3 roads, each of which are only 2 lanes to handle the volume. Also Mill Ave has serious blind spots at both top and bottom of the newly “redone” street. We also have great concerns about water run off if the properties are developed above us as there are numerous natural springs. We lived through the logging of the area above us 5 years ago and had to contend with large truck dropping their trailers in front of our house daily for months and the additional traffic just from those truck back and forth and up Wildwood had a big impact on traffic.

Yes to Caitec, no to Yew Street Road bring added to UGA. Caitec is nearer most services and stores and the land is flatter. Yew Street Road has many wetlands, hills and gullies and its access is limited by a winding road. There are already mobile home parks dotting the landscape along with smaller homes and a mix of small lots/acreage. It is fine as it is.

As a lifelong resident of Bellingham, then Whatcom County, I am wondering why the push for growth. As Edward Abbey said, “Growth for the sake of growth is the ideology of the cancer cell.” We stopped a large development some years back that would have added an 80 fold increase in density and added commercial use to a wooded rural area that had wetlands. A city planner at the time encouraged this upzone. Please grow up, not out. No annexations of farmland or large wooded parcels will keep Bellingham’s growth checked.

Whenever new buildings are going up there must be a plan in place for people with disabilities to access. There needs to be space for transit (including paratransit) to park to safely load and off load passengers.

If Bellingham's aspirational goal is to be a walkable city and to reduce car trips or avoid them all together then Urban Village neighborhoods connected via walking/bike trails and WTA are essential. We live in Larabee Springs South Development and our walkability score is an abysmal low 2/100. Which means driving everywhere. The proposed annexation of the Land between the north end of Bellingham and Smith Road with the proposed development by Caitac containing a varied selection of housing, Commercial/Residential buildings a Grocery Store, parks and other amenities would be a welcome expansion of Bellingham to the North.

I am not in favor of expanding the city of Bellingham boundaries. I am not in favor of increasing the urban growth boundary. I grew up here and do not want to support anymore growth into the county. This is a beautiful place for a reason and I would like to see Bellingham manage growth within its current boundaries. Accommodating growth is not a priority for me or my family.

As the Urban Village concept is expanded, please consider architecture and design. Adding cookie-cutter, box-like buildings of questionable build quality (usually put forth as a cost-effective option, but expensive in the long run) leads to the homogenization of communities. Can we give at least some thought to the design? Include features that represent the culture, environment, and heritage of this region (including — and especially so — that of the Coast Salish)? Walkability should also take into account our region’s climate and include features to help mitigate deterrents to walking in the rain, snow, etc.

Based on reviewing the plan, I don't see the connection between limiting spread and clustering near facilities and amenities and the reserve expansion areas. The reserve expansion area in the North is only residential and there's not much mixed use development in that area.

This Land Use Section really includes many aspects of tools necessary to continue making Bellingam a great small town.