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.
Washington’s Buildable Lands Guidelines were created to prevent cities from overstating housing supply.
They require jurisdictions to:
Inventory land at the parcel level
Remove public and quasi-public land
Deduct critical areas (wetlands, buffers, slopes)
Account for infrastructure constraints
Apply market feasibility factors
Adjust assumptions when projections fail
In short:
Zoning allowances are not housing supply.
This is not a theoretical argument.
In 2003–2004, Bellingham conducted a land supply analysis that closely followed the State’s methodology. The City:
Removed public and quasi-public land from the inventory
Classified parcels as developed, partially developed, vacant, or redevelopable
Used improvement-to-land value ratios to estimate redevelopment likelihood
Deducted infrastructure and market constraints
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.
Fast forward to the 2025 Comprehensive Plan.
Bellingham’s housing capacity is now increasingly expressed as:
Allowed density
Hypothetical redevelopment
Zoning envelopes
Aspirational unit counts
What’s missing?
Clear exclusion of public land
Parcel-level feasibility analysis
Market discounting
A feedback loop when housing production falls short
This shift replaces evidence-based planning with policy narrative.
State guidance is explicit:
Public land is not buildable unless declared surplus.
Yet today, land owned by:
The City
Greenways
Utilities
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.
The State requires cities to account for market realities:
High development fees
Construction costs
Financing constraints
Owner reluctance to redevelop
Price and rent limits
Bellingham’s current framework largely assumes redevelopment occurs at maximum density — regardless of whether projects pencil.
The result is predictable:
Fewer homes built than projected
A collapse in ownership housing
Density increases without affordability
This is not a housing shortage caused by lack of zoning.
It’s a shortage caused by ignoring feasibility.
Perhaps the most serious issue is the absence of recalibration.
When housing projections fail:
Assumptions should change
Capacity should be reevaluated
Policy should adjust
Instead, Bellingham’s response has been to:
Increase density again
Remove parking requirements
Raise fees
Shrink buildable land further
That is not planning.
It’s a one-way ratchet.
When cities rely on paper capacity instead of buildable land, the consequences are real:
Housing targets are “met” on paper
Prices rise
Choices disappear
Infrastructure planning breaks down
Displacement accelerates
Density alone does not create affordability — especially when the land itself is not realistically buildable.
Bellingham does not need a new theory.
It needs to return to the methodology it already used — and the State still requires.
That means:
Parcel-level analysis
Honest exclusions
Market realism
Public accountability
Real housing policy starts with real numbers.
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.