# A Planning Commission Grapples with Growth: The Path Forward for Bellingham's Development On a July evening when the planning calendar showed just how quickly 2025 was racing toward its end, the Bellingham Planning Commission convened for what could only be described as a marathon session on the city's future. The stakes were unmistakable: with a December 31st state deadline looming, every meeting from here forward would help determine how Bellingham accommodates thousands of new residents over the next two decades. ## Setting the Stage Chair Mike Estes called the meeting to order at 6 p.m. in City Council chambers, with five commissioners present and Rose Lathrop absent. The room felt charged with the weight of consequential decisions ahead. Long Range Division Manager Chris Behee would guide them through the complexities of environmental impact analysis and growth projections — the technical underpinning of what will become the Bellingham Plan. This wasn't a public hearing, Estes reminded everyone, but rather a work session to digest the countywide environmental impact statement draft and understand how it relates to land capacity analysis and growth strategies. Still, the evening would begin with public voices that would set the tone for everything that followed. ## Voices from the Community Peter Frazier approached the podium with the measured confidence of someone who had clearly studied the issues deeply. His message was direct and urgent: the exclusion of the South U Street Urban Growth Area from the city's preferred alternative was "a consequential policy decision that if left unchallenged will limit Bellingham's ability to meet its own housing and economic goals." Frazier's three minutes painted a picture of missed opportunity. "Were landowners in the South U and Samish Ridge area ever consulted?" he asked, answering himself: "From everything I've seen, the answer is no. A significant omission." He described eager property owners ready to work with the city, infrastructure planning decades in the making, and "the largest blocks of undeveloped land in the city" positioned for thousands of homes in walkable, well-connected neighborhoods. The Lake Padden watershed concerns that helped push this area to reserve status? "It didn't hold up then and it doesn't now," Frazier argued. Extending sewer service and modern stormwater systems would actually improve water quality by replacing aging septic systems, he contended. His closing struck at the heart of Bellingham's affordability crisis: "Right now, we're at risk of becoming a city that's unaffordable to the very people who power our economy. Family wage employers in advanced manufacturing, medical, and public sector already struggling to recruit and retain staff." Without housing near job centers, he warned, that only gets worse. Brian Armstrong followed with a different but complementary concern about incorporating native habitat into infrastructure. Walking recently along Telegraph, he'd seen "sidewalks that are six to eight feet wide but with no trees" — brand new infrastructure that somehow failed to include the urban forestry the city claims to prioritize. "What they're going to have to come do is come back with a jackhammer, carve out spaces for trees, then plant the trees," he observed. "So I'm just wondering how much money that's going to cost." But Armstrong's bigger point was about underutilized land within the city itself. He pointed to successful mall redevelopment in other cities — Alderwood Mall building hundreds of apartment units after losing a major tenant, Northgate Mall adding apartments around a Kraken practice facility. "I look at our mall and I remember growing up with that when it used to be busy and now I just see this giant landscape of pavement and unused space," he said. "We're constantly saying, 'Well, how can we develop? How can we we don't have enough land?' And I see all these underutilized properties within our town and think, 'What do you mean we don't have any land?'" The final public comment came via Zoom from Perry, representing the building industry's government affairs committee. His remarks were dense with technical concerns about the land capacity analysis: assumptions that 33% of new lots would have one ADU and 30% would have two ADUs seemed "likely high" to industry professionals. Construction costs for detached ADUs at $325 per square foot made them effectively unaffordable, he noted, while integrated ADUs could come down to $150-170 per square foot. Perry raised financing realities often overlooked in planning: "You get above three units, you're suddenly in a commercial loan. That's a whole different set of appraisers. That's a whole different set of appraisal rules." His committee also questioned whether landmark tree deductions properly accounted for groves, and suggested that relying on University of Washington racial covenant research wasn't sufficient when "since about 1970, every development that has occurred has the one house per lot restriction on it." ## The Environmental Impact Statement Deep Dive Behee's presentation began with an acknowledgment of complexity. The memo provided to commissioners was lengthy, he apologized, but the subject matter demanded it. The county-wide environmental impact statement, released at the end of April, had generated substantial public comment during its May review period. Now consultants were preparing the final version, hopefully ready by the end of July. The timing was critical. If the final EIS arrived on schedule, the city could complete its SEPA determination and advertise for the required 30-day public hearing notice, bringing a fully formed draft of the Bellingham Plan to the commission by early September. Everything hinged on that final EIS release. The State Environmental Policy Act requires jurisdictions updating land use documents to examine potential impacts across 14 major topic areas — from earth, air, and water to transportation, public services, and environmental justice. The key insight Behee stressed: the EIS evaluates alternatives, not necessarily the final policy direction. These alternatives represent a range from low to high growth, allowing analysis of the full spectrum of potential impacts. "The idea is that those alternatives are not necessarily the fully formed policy direction that will come out of this plan," Behee explained, "but they are typically alternatives that represent a low end, a high end, and maybe some alternatives in the middle." ## Three Paths to the Future The growth alternatives painted starkly different pictures of Whatcom County's next 20 years: **Alternative 1 — Medium Growth** used the state's Office of Financial Management medium projection of 292,714 people countywide by 2045. This represented about 2,587 people per year, roughly 87% of the actual growth rate over the past decade. For Bellingham, this meant no Urban Growth Area boundary changes but significant zoning restructuring to allow middle housing — duplexes, triplexes, and townhomes — with up to four units per lot or six if two were affordable. **Alternative 2 — Multi-Jurisdictional Resolution** anticipated 303,438 people countywide, translating to 3,074 people annually — about 103% of recent growth trends. This alternative, which aligned most closely with Bellingham's thinking, included removing industrial areas west and north of the airport from the UGA, removing Lake Whatcom watershed areas, and adding both North and South Bellingham UGA reserve areas. The middle housing allowances remained, along with increased development capacity in transit-oriented corridors. **Alternative 3 — High Growth** projected 321,702 people, requiring 3,905 new residents annually — 31% above recent experience. Like Alternative 2, this brought in both reserve areas but kept everything else in the current UGA. The higher growth would demand more aggressive infrastructure investment to close gaps. Behee walked commissioners through detailed charts showing how growth would be distributed across jurisdictions. Bellingham's numbers consistently split the difference between OFM medium and adjusted high projections. Some cities chose the lower end (Lynden), others the higher end (Ferndale), creating a patchwork of local choices that would collectively shape the county's future. ## The Geography of Growth Maps revealed the physical implications of these choices. Seven analysis areas within and around Bellingham's UGA would see different treatment depending on the alternative selected. Areas 1, 2, and 3 — the industrial zones between Bellingham International Airport and Ferndale — would stay in Alternative 1, leave in Alternative 2, and stay in Alternative 3. Area 4, the North UGA Reserve, would join the UGA in Alternatives 2 and 3. Areas 5 and 6 — the Lake Whatcom watershed areas in Hillsdale and Geneva — would remain in Alternative 1 and 3 but get permanently removed in Alternative 2. And Area 7, the South U Street Reserve that Frazier had advocated for, would be added in Alternative 2 for analysis but ultimately left in reserve status in the city's preferred alternative. The EIS analysis revealed the environmental tradeoffs embedded in each choice. Areas proposed for removal from the UGA were "highly impacted by wetlands" north and west of the airport. The South UGA reserve sat "largely within the Lake Padden watershed area" with "steep slopes, sandstone formations and things, the steep geology that you find up on that Samish crest and Samish Hill area." Yet the EIS also noted potential benefits. Removing watershed areas from the UGA "makes sense from some perspectives related to protection of those areas related to wildlife habitat." Alternative 2 did "the best job of the three action alternatives at minimizing climate impacts," though the differences were subtle. ## The Capacity Question The land capacity analysis represented perhaps the most technical but crucial part of the evening's discussion. This was the mechanism for "right-sizing" the urban growth area — estimating how future policies would play out across buildable land to determine how many housing units and jobs could be accommodated over 20 years. The methodology started with all land, then systematically removed constraints: mapped critical areas and buffers, future public facilities, infrastructure gaps, landmark trees larger than 36 inches in diameter. "In general we are reducing more than 50% of our theoretical capacity through a wide variety of deductions," Behee explained, "to get at a number that we feel is realistic." The preliminary results showed Bellingham's capacity at roughly 18,900 new housing units across all zones. About a third would come in the residential low zone — much of that from the new middle housing allowances on existing properties. Urban villages would contribute about 6,000 units, continuing their role as a cornerstone of the growth strategy. The housing mix reflected both regulatory changes and market realities. Single-family detached capacity was just under 1,000 units. Middle housing — duplexes, triplexes, townhomes — accounted for 5,800 units. But multifamily development still dominated at over 10,000 units, representing more than half the total capacity. Behee cautioned that employment capacity was inherently more speculative. He offered his standard example: a former furniture warehouse on Bakerview that employed maybe 40 people as retail space but now housed 300-400 people as a call center. "Same square footage, order of magnitude difference in how many people can work there. You won't find those kinds of differences in housing occupancy over time." ## The Preferred Alternative Takes Shape Between the draft and final EIS, Bellingham had the opportunity to submit a "preferred alternative" that refined the analysis based on what they'd learned. The city's preferred alternative looked much like Alternative 2 but with one significant change: the South U Street UGA Reserve would remain in reserve status rather than being added to the UGA. The reasons were multiple. The draft EIS had identified impacts to wildlife habitat, water quality, and steep slopes. The city's own evaluation revealed missing infrastructure — roads, water reservoirs, fire service. But perhaps most importantly, in late 2024 the city had purchased about 66 acres of buildable land in the South U Street area for the Greenways program. "It was about half of the development capacity of that area is now in city ownership for preservation of land for greenways purposes," Behee explained. This decision would undoubtedly disappoint advocates like Frazier, but it reflected the complex balancing act inherent in growth management. The preferred alternative still brought in the North UGA Reserve, removed the airport industrial areas and Lake Whatcom watershed lands, and embraced the middle housing revolution. The result: about 3% surplus housing capacity and 9% surplus employment capacity — tight margins for a 20-year planning period. ## Commissioner Concerns and Calculations As Behee concluded his presentation, commissioners grappled with the implications. Mike Estes immediately zeroed in on the South U Street question, expressing sympathy for Frazier's arguments. He understood the North UGA was financially "low-hanging fruit" for the city, but worried about repeating past patterns: "When we saw growth there before, we saw national builders come in, bring in labor from out of town, build it fast, build it cheap." South U Street offered different possibilities, Estes argued. "We do have a local developer. We have landowners that are ready to go. We have locals who are ready to take that action." The environmental concerns were "valid," he acknowledged, "but those can all be engineered and mitigated." More fundamentally, Estes worried about what kind of place Bellingham was trying to become. "When we talk about attracting people here and companies that offer good paying jobs and people that want to come here, a lot of them want to come here and they don't want to live out by Cordata. That's not really Bellingham to them. A lot of people want to come here and ride their bikes, take advantage of the parks and walk." Behee explained the county's reserve designation — essentially a planning tool identifying the "next tier of land we would look to for analysis" in future updates. South U Street had been in the UGA until 2009, then moved to reserve status, and would stay there until 2035 under the preferred alternative. Jed Ballew raised technical questions about minimum density regulations and how they would interact with the new middle housing requirements. The residential low zone assumed minimum lot sizes around 5,000 square feet, but that lot would still be subject to middle housing rules allowing four units per lot, or six with affordability requirements. The conversation revealed the complexity of implementing the state's middle housing mandate. Most property owners in established neighborhoods would likely add only one or two units if any, Behee predicted. But the regulations also allowed more ambitious property owners to add up to six units. "It will depend on the resources those folks have and their desire to take action," he noted. Russ Whidbee pressed on the landmark tree ordinance's impact, wondering how forested growth areas would affect development capacity. The question highlighted another layer of uncertainty: while the city had LIDAR data showing tree heights, actual landmark tree surveys would be required for development projects. "You have to go in and survey those areas individually and figure out how many are trees that do match the landmark tree criteria," Behee acknowledged. The most pointed challenge came from Commissioner Ballew, who expressed concern about the 3% housing capacity surplus. Given the high uncertainty in population projections and the unknown pace of middle housing implementation, was this margin adequate? Ballew cited sobering statistics: the no-action alternative would cover only 61% of trailing ten-year growth projections, and the 2016 planning process had underestimated actual growth by 7%. "I think 3% is giving us too narrow of margin for error," he said, suggesting 7% might be more appropriate given past performance. "We can have a lot of control of the zoned capacity and the housing capacity and from there kind of the housing supply. We don't have a lot of control of population," Ballew observed. "People choose to move here because they like the area, not because they checked the permit desk counter numbers from the last year." His concern was particularly acute given the reliance on the untested middle housing rules. "I look at areas of multifamily within the city that look like single family neighborhoods and you don't see a ton of redevelopment even when zoning capacity allows for it. And I'm worried that the new zoning capacity is going to be very slow to be realized." Behee acknowledged the validity of these concerns while defending the chosen approach. The OFM medium projection was lower than Bellingham's preferred numbers, providing some cushion. Birth rates would decline as baby boomers aged, but climate change and political instability might drive increased in-migration. "We just don't want to get caught kind of behind the curve on some of those things," he said. ## Comment Patterns and Community Concerns As the technical discussion wound down, Behee summarized the patterns emerging from the EIS comment period. Five major themes had emerged, often with multiple commenters saying similar things. The U Street corridor generated the strongest response in both directions. Environmental advocates wanted the entire area left out of growth strategies, concerned about wildlife habitat, tree cover, Lake Padden water quality, and preserving a natural corridor. Development advocates like Frazier wanted it brought in to capitalize on housing opportunities. Industrial zoning in the Alderwood Urban Growth Area sparked significant concern, particularly the three heavy impact industrial areas around Bennett and Marine Drive. Residents worried about noise, vapors, and traffic impacts, with many requesting rezoning to light industrial. The Port of Bellingham's successful light industrial business park was cited as a model that could work at larger scale. The North UGA Reserve drew mostly supportive comments from both property owners and others who saw it as an opportunity for significant housing development and mixed-use services during the planning period. More generally, commenters expressed frustration with the EIS's level of detail and the long gap between scoping and publication. Bellingham had requested more rigorous traffic analysis and better arterial street network evaluation, beyond just the focus on Lakeway Drive. ## A Framework for Balanced Growth Despite the technical complexity and competing pressures, a coherent growth strategy emerged from the evening's discussion. The preferred alternative sought what Behee called "a balanced approach" recognizing both urgent housing needs and infrastructure limitations. The strategy operated on multiple scales simultaneously. For smaller landowners wanting to add a single ADU, the new rules provided clear pathways. For those wanting to develop larger projects, urban villages and edge areas offered opportunities. "All of those three different scenarios are groups that have access to different financial resources and can respond on different timelines," Behee explained. Urban villages would continue as a cornerstone, with transit access, infrastructure investments, and proximity to jobs and services. Middle housing would slowly transform neighborhoods as property owners chose to add units. And selective expansion at the edges would provide relief valves for land supply while protecting critical environmental areas. The numbers behind this strategy reflected both ambition and caution. The 18,900-unit capacity represented unprecedented change driven by state mandates Behee called "once in a generation." Yet the methodology's conservative assumptions — removing more than half the theoretical capacity through various deductions — suggested appropriate humility about predicting the future. ## Looking Forward As commissioners wrapped up their questions, the path ahead came into focus. No meeting was scheduled for July 17th as originally planned. Instead, they would wait for the final EIS, hopefully arriving by month's end. If the timeline held, September would bring the fully formed Bellingham Plan to a public hearing where this body would vote and accept formal testimony. The weight of that moment was not lost on anyone in the room. After two years of work sessions, policy discussions, and technical analysis, the commission would soon make its recommendation to the City Council. The decisions would shape how Bellingham grows for the next two decades — determining where thousands of new residents will live, how they'll get around, and what kind of community they'll help create. Behee thanked commissioners for their attention to what could be "kind of a dry topic, but it's a very important kind of key piece from the land use perspective." Estes adjourned the meeting just before 8 p.m., nearly two hours after it began. Outside the chambers, the summer evening stretched long toward twilight, but inside the work of planning Bellingham's future continued. The September hearing would bring everything together — growth projections and environmental analysis, infrastructure needs and housing goals, community values and state mandates. What emerged from that process would define not just where Bellingham grows, but what kind of place it becomes.