Buildable Land vs. Policy Capacity in Bellingham, Washington

Prepared by:

Real Housing Reform Initiative
A Housing Policy Media Initiative

Executive Summary

Washington State requires cities planning under the Growth Management Act (GMA) to demonstrate that sufficient buildable land exists to meet 20-year housing needs. This analysis compares the State’s Buildable Lands Guidelines with the City of Bellingham’s current Comprehensive Plan approach and finds a significant methodological departure.

Bellingham has shifted from parcel-level buildability analysis toward theoretical zoning capacity, creating a gap between planned and actual housing production.

1. State Requirement: Buildable Land Is Not Zoning Capacity

The State’s Buildable Lands framework requires jurisdictions to determine whether land is realistically capable of development, not merely allowed by zoning.

Key requirements include:

• Parcel-level land inventory

• Removal of public and quasi-public land

• Deduction of critical areas and infrastructure needs

• Application of market feasibility factors

• Periodic recalibration when assumptions fail

This framework exists to prevent cities from overstating housing capacity.

2. Bellingham’s Prior Compliance (2003–2005)

Bellingham previously applied the State methodology correctly.

Its 2003–2004 Land Supply Analysis:

• Removed public and quasi-public land

• Classified parcels by development status

• Applied improvement-to-land value tests

• Discounted for market and infrastructure constraints

• Produced a net buildable acreage figure

This resulted in a realistic estimate of housing capacity tied to actual development likelihood.

3. Current Practice: Shift to Policy Capacity

The 2025 Comprehensive Plan increasingly relies on:

• Allowed density

• Hypothetical redevelopment

• Aggregate zoning envelopes

Key analytical elements are now missing:

• Clear exclusion of public land

• Market feasibility adjustments

• Ownership vs. rental production realism

• Correction of failed assumptions

As a result, housing “capacity” exists largely on paper.

4. Consequences of the Shift

This methodological change has produced predictable outcomes:

• Housing targets are met on paper but not in practice

• Ownership housing production collapses

• Density increases without affordability

• Infrastructure planning becomes misaligned with real growth

These outcomes are not accidental — they are consistent with overstated land capacity.

5. GMA Compliance Implications

Under the GMA, comprehensive plans must be:

• Internally consistent

• Based on demonstrable capacity

• Grounded in realistic assumptions

Counting land that cannot or will not be developed undermines that standard.

6. Recommendations

1. Re-establish a parcel-level buildable lands inventory

2. Explicitly remove all non-surplus public land

3. Restore market feasibility discounting

4. Separate ownership and rental capacity analysis

5. Publicly recalibrate assumptions against real outcomes

Conclusion

Bellingham’s housing challenge is not a lack of density allowances — it is a failure to distinguish what is allowed from what is buildable.

Returning to the State’s Buildable Lands framework is essential to producing real housing, not just planning documents.