Introduction: Why This Distinction Matters
Bellingham’s housing debate often centers on density — more units, more zoning flexibility, more capacity.
But there is a critical question that rarely gets asked:
Is the land we’re counting actually buildable?
Under Washington’s Growth Management Act (GMA), cities are not allowed to rely on theoretical zoning capacity. They are required to demonstrate that enough realistically buildable land exists to meet 20-year housing needs.
That distinction — buildable land versus paper capacity — is where Bellingham’s current planning framework begins to break down.
What the State Actually Requires
Washington’s Buildable Lands Guidelines were created to prevent cities from overstating housing supply.
They require jurisdictions to:
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Inventory land at the parcel level
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Remove public and quasi-public land
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Deduct critical areas (wetlands, buffers, slopes)
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Account for infrastructure constraints
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Apply market feasibility factors
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Adjust assumptions when projections fail
In short:
Zoning allowances are not housing supply.
Bellingham Used to Follow the Rules
This is not a theoretical argument.
In 2003–2004, Bellingham conducted a land supply analysis that closely followed the State’s methodology. The City:
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Removed public and quasi-public land from the inventory
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Classified parcels as developed, partially developed, vacant, or redevelopable
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Used improvement-to-land value ratios to estimate redevelopment likelihood
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Deducted infrastructure and market constraints
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Calculated net buildable acres, not just allowed density
The result was a conservative, reality-based estimate of how many homes could actually be built.
That process worked — even if the conclusions were politically inconvenient.
What Changed: From Buildable Land to Policy Capacity
Fast forward to the 2025 Comprehensive Plan.
Bellingham’s housing capacity is now increasingly expressed as:
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Allowed density
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Hypothetical redevelopment
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Zoning envelopes
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Aspirational unit counts
What’s missing?
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Clear exclusion of public land
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Parcel-level feasibility analysis
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Market discounting
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A feedback loop when housing production falls short
This shift replaces evidence-based planning with policy narrative.
The Public Land Problem
State guidance is explicit:
Public land is not buildable unless declared surplus.
Yet today, land owned by:
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The City
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Greenways
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Utilities
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Public agencies
is often left inside housing capacity discussions — despite no intent to sell, no timeline, and in many cases legal restrictions on development.
Counting land that will never be built on does not create housing. It only creates the appearance of capacity.
Ignoring the Market Doesn’t Make It Go Away
The State requires cities to account for market realities:
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High development fees
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Construction costs
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Financing constraints
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Owner reluctance to redevelop
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Price and rent limits
Bellingham’s current framework largely assumes redevelopment occurs at maximum density — regardless of whether projects pencil.
The result is predictable:
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Fewer homes built than projected
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A collapse in ownership housing
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Density increases without affordability
This is not a housing shortage caused by lack of zoning.
It’s a shortage caused by ignoring feasibility.
No Course Correction
Perhaps the most serious issue is the absence of recalibration.
When housing projections fail:
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Assumptions should change
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Capacity should be reevaluated
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Policy should adjust
Instead, Bellingham’s response has been to:
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Increase density again
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Remove parking requirements
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Raise fees
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Shrink buildable land further
That is not planning.
It’s a one-way ratchet.
Why This Matters
When cities rely on paper capacity instead of buildable land, the consequences are real:
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Housing targets are “met” on paper
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Prices rise
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Choices disappear
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Infrastructure planning breaks down
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Displacement accelerates
Density alone does not create affordability — especially when the land itself is not realistically buildable.
The Fix Is Not Radical
Bellingham does not need a new theory.
It needs to return to the methodology it already used — and the State still requires.
That means:
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Parcel-level analysis
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Honest exclusions
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Market realism
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Public accountability
Real housing policy starts with real numbers.
Closing
The housing crisis is complex — but this part is not. If the land isn’t buildable, it shouldn’t be counted, and until Bellingham confronts that reality, no amount of density rhetoric will fix the problem.
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