---
title: Buildable Land vs. Policy Capacity in Bellingham, Washington
description: Case study examining how Bellingham’s housing plan counts zoning ‘capacity’ instead of buildable land and why that gap drives higher prices and fewer homes
---

[Real Housing Reform Blog ](https://www.realhousingreform.org/blog)

# [Buildable Land vs. Policy Capacity in Bellingham, Washington](https://www.realhousingreform.org/blog/buildable-land-vs-policy-capacity-in-bellingham-washington)

 Written by [Brian Gass](https://www.realhousingreform.org/blog/author/brian-gass) | Dec 31, 2025 2:05:12 AM

## 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.

[View full post](https://www.realhousingreform.org/blog/buildable-land-vs-policy-capacity-in-bellingham-washington)

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