# Planning Commission Embraces Co-Living Housing Reform
The City of Bellingham Planning Commission took a significant step toward expanding housing options on October 16th, voting unanimously to recommend approval of new co-living housing regulations that will modernize the city's approach to shared residential spaces and comply with state-mandated housing reforms.
## Meeting Overview
The 77-minute meeting at City Council Chambers featured a thorough review of proposed amendments to Bellingham Municipal Code Titles 16 and 20, designed to implement Washington State House Bill 1998's requirements for co-living housing. Present were Chair Mike Estes and commissioners Daniel Bloemker, Jed Ballew, Lisa Marx, and Russell Whidbee, with Rose Lathrop and Jerry Richmond excused. Staff from Planning and Community Development led by Director Blake Lyon presented the comprehensive package of code changes.
The evening's business centered on bringing Bellingham into compliance with state law while creating opportunities for naturally occurring affordable housing through shared living arrangements. The tone throughout was progressive and forward-looking, with commissioners expressing enthusiasm for housing forms that have existed for centuries but were restricted by outdated zoning codes.
## Passionate Public Comment on Housing Availability
Before diving into co-living regulations, the commission heard pointed criticism of the city's land use policies during general public comment. Brian Gas, a Bellingham resident, delivered an impassioned three-minute testimony challenging what he characterized as artificially created housing scarcity.
"I don't feel like there's an urgency in anybody who lives in Bellingham now to have any guilt on not providing a similar... I guess you're saying you're expecting some of these people to have a lower quality of life or a lower opportunity cost for building a life here in Bellingham," Gas said. "And sadly, I don't believe that it has anything to do with actual supply and demand. I think our demand, I'm kind of finding out now that it's artificially created this scarcity through planning."
Gas specifically criticized the city's land capacity analyses, claiming the city has purchased over 400 acres of residentially zoned property since 2005, removing it from available development land while continuing to count city-owned greenway property in availability calculations. He warned of potential legal challenges under the Growth Management Act, arguing the city was "slow rolling the capacity to disenfranchise any new person who wants to buy a legitimate home in Bellingham that is basically 100% manufactured by policy, not by demand."
Chair Estes acknowledged the comments while noting that Growth Management Act issues were now before City Council rather than the Planning Commission.
## The Co-Living Code Transformation
Long-range planner Sydney Prusak opened the staff presentation by noting it felt good to discuss something other than the Bellingham Plan for once. She and colleague Sara Ullman, a Planner II in development services, outlined the complex web of state legislation driving the proposed changes.
The foundation was laid in 2021 with Senate Bill 5235, which prohibited cities from regulating the number of unrelated persons living together. This struck down Bellingham's "rule of three" that limited single dwelling units to no more than three unrelated individuals. Then came 2024's House Bill 1998, requiring cities to allow co-living housing wherever six or more multifamily units are permitted.
"Co-living is a residential development where sleeping units or bedrooms are independently rented or sold and residents share kitchen facilities," Prusak explained. She emphasized this isn't a new concept: "The term co-living has gotten a lot of buzz over the past few years with housing reform across the state. But please keep in mind that this is something that is regularly occurring and has occurred through time."
The presentation distinguished between naturally occurring co-living—such as college students sharing a house—and purpose-built co-living developments. The latter category, which the code addresses, requires a minimum of 24 sleeping units to ensure meaningful density and shared amenities.
## International Inspiration and Local Examples
Prusak showcased examples from Copenhagen and Seattle to illustrate co-living's potential. The Copenhagen project featured a courtyard design with green space and robust shared facilities, while the Seattle example demonstrated how co-living buildings can blend seamlessly into urban neighborhoods from the outside.
"From the outside, this building really looks like any other higher density multifamily unit. You can't necessarily tell that it's co-living," Prusak noted of the Seattle project. Each unit in that development includes a small bathroom and kitchenette—defined as having a sink, mini fridge, and microwave—while residents share larger kitchen facilities and communal spaces.
The mathematical framework underlying the regulations emerged from state requirements. The legislature established that four co-living sleeping units equal one traditional dwelling unit. Since the state requires co-living wherever six multifamily units are permitted, Bellingham's 24-unit minimum (6 units × 4 sleeping units per unit) maintains density equivalency while ensuring viable shared living arrangements.
## Modernizing Terminology and Removing Barriers
Sara Ullman detailed the specific code amendments, highlighting how the changes eliminate barriers that have prevented co-living development. The outdated "family" definition, which hadn't been enforced since 2021 due to state law changes, will be replaced with "household"—simply defined as "an individual or collection of individuals occupying the entire dwelling unit."
The regulations also replace "boarding and rooming houses," which required conditional use permits and public hearings, with outright permitted co-living housing. This change removes bureaucratic obstacles while maintaining appropriate development standards.
Environmental sensitivity posed no complications. Unlike other recent state housing laws, House Bill 1998 contained no carve-out for environmentally sensitive areas. Co-living will be permitted in residential multi-zones within the Lake Whatcom watershed, though developments must still comply with existing zoning and stormwater regulations.
## Parking and Transportation Integration
Parking requirements reflect the state's recognition that co-living residents often have lower vehicle ownership rates. The code establishes one parking space for every four sleeping units, with no parking required within a half-mile walking distance of major transit stops.
Planning staff confirmed coordination with Whatcom Transportation Authority on transit definitions. Bellingham's four existing Go Lines meet the state's definition of major transit stops with 15-minute headways. A map displayed during the meeting showed that roughly two-thirds of the city falls within the no-parking-required zones, concentrated in multifamily-zoned areas where co-living will primarily occur.
The existing State Street co-living project provided a real-world case study. Staff reported that despite receiving a 100-stall parking reduction through mitigation measures, residents continue bringing vehicles and requiring additional off-site parking arrangements, demonstrating the ongoing transportation challenges.
## Commissioner Enthusiasm and Technical Refinements
Commissioner Jed Ballew expressed particular enthusiasm for the proposals, calling it his "most looked forward to meeting" and noting his personal experience with co-living arrangements. "It was a housing form that was legal for hundreds and hundreds of years until we decided that we knew better and created a housing crisis out of it," he observed.
The commission engaged in detailed technical discussions about design review thresholds and definitions. A contradiction emerged where co-living housing was defined as requiring 24 units minimum, yet design review triggered at 12 units. Commissioners worried this created a regulatory gap for developments between 12 and 24 units.
After extensive debate, Ballew proposed and the commission unanimously approved an amendment simplifying the design review language to apply to "residential development consisting of three or more dwelling units on a site or co-living housing," removing the specific unit count that had created confusion.
Commissioner Russell Whidbee attempted to eliminate parking requirements entirely, arguing for market-based solutions, but failed to receive a second for his motion. Staff recommended maintaining state-mandated parking standards while comprehensive parking reforms proceed separately.
## Western Washington University Connections
Discussion touched on potential applications at Western Washington University, with commissioners exploring how institutional master plans interact with co-living regulations. Staff clarified that Western's campus falls under institutional master plan provisions, though university-owned property outside that framework would be subject to standard zoning.
Director Blake Lyon noted Western is currently conducting a comprehensive campus assessment examining enrollment projections and capital investment strategies. The balance between on-campus and online students remains under evaluation, affecting decisions about additional housing development.
The conversation highlighted the Lincoln Street park-and-ride lot as a potential development site. Staff confirmed Western owns the property, which sits in a planned commercial zone allowing residential with commercial components, though it's not within the institutional master plan.
## Embracing Housing Innovation
Commissioner Lisa Marx praised the proposal as "very progressive and needed to meet the demands of the growth and the comprehensive plan that we're looking at for the future." Her sentiment reflected broader commission support for expanding housing options.
The regulations represent the first phase of co-living implementation, focusing on higher-density zones. Phase two will examine co-living in lower-density residential zones as part of upcoming residential code updates in 2026-2027.
Staff emphasized the affordability benefits of co-living, noting it typically serves residents earning below 50% of area median income—a much lower demographic than traditional apartment dwellers. The shared facilities inherently reduce housing costs while providing social connections and community amenities.
## Looking Ahead
The commission's 5-0 vote sends the co-living regulations to City Council with a strong recommendation for approval. The timing aligns with broader housing reform efforts, including the pending Bellingham Plan adoption and interim parking regulation extensions.
The regulations must be adopted by year-end to comply with state requirements. City Council will likely consider the proposal in late November alongside interim middle housing and design review measures.
As Chair Estes noted before adjourning, the November 6th meeting currently has no agenda items, reflecting the commission's successful completion of major planning initiatives. The co-living vote represents a culmination of years of housing reform efforts, modernizing regulations to support diverse, affordable housing options in a rapidly growing community.
The evening's work demonstrated how state-mandated housing reforms can catalyze local innovation, transforming regulatory obstacles into opportunities for housing diversity. By embracing co-living, Bellingham positions itself to address housing affordability through time-tested arrangements that previous zoning codes had unnecessarily restricted.
### Meeting Overview
The Bellingham Planning Commission held a public hearing on October 16, 2025, to review proposed co-living code updates required by Washington state law. The main focus was implementing state-mandated changes to define and allow co-living housing in zones where six or more multifamily units are permitted.
### Key Terms and Concepts
**Co-living housing:** A residential development with at least 24 sleeping units where residents share kitchen facilities, replacing what was previously called "rooming and boarding houses."
**Sleeping unit:** A lockable, independently rented room up to 300 square feet that may contain a kitchenette but not a full kitchen.
**Household:** A new definition replacing "family" that allows any number of unrelated individuals to live together in a dwelling unit.
**Kitchenette:** Basic food preparation space with a sink and 120-volt electrical outlet, versus a full kitchen with stove and oven capabilities.
**Design review:** Administrative approval process required for larger residential developments, triggered at 12 or more co-living sleeping units.
**Rule of three:** The previous city code restriction limiting dwelling units to no more than three unrelated persons, which has been unenforced since 2021.
**Multifamily zones:** Areas zoned for apartment buildings and condos, along with commercial zones and urban villages, where co-living will now be permitted.
### Key People at This Meeting
| Name | Role / Affiliation |
|---|---|
| Mike Estes | Planning Commission Chair |
| Sydney Prusak | City Planner II, staff presenter |
| Sara Ullman | City Planner II, staff presenter |
| Blake Lyon | Planning & Community Development Director |
| Kurt Nabbefeld | Development Services Manager |
| Bryan Gass | Public commenter on land capacity issues |
| Jed Ballew | Commissioner who proposed design review amendment |
### Background Context
This update stems from two key state laws: Senate Bill 5235 (2021) prohibiting cities from limiting unrelated people living together, and House Bill 1998 (2024) requiring cities to allow co-living housing where six or more multifamily units are permitted. The city must comply by the end of 2025. These changes reflect growing recognition that traditional "single-family" zoning restrictions contributed to housing scarcity and that diverse living arrangements should be legally supported.
### What Happened — The Short Version
Staff presented proposed code changes to define and allow large-scale co-living developments (24+ units) in multifamily, commercial, and urban village zones while replacing the "family" definition with "household" to remove restrictions on unrelated people living together. After minimal public comment, commissioners discussed technical details around design review thresholds and parking requirements. The commission unanimously approved the changes with one amendment simplifying the design review language, recommending city council adoption.
### What to Watch Next
• City Council will hear this recommendation in late November 2025
• A second phase will examine co-living in lower-density residential zones in 2026-2027
• Parking reform discussions continue with potential extensions to interim parking regulations
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**Q:** What is the minimum number of sleeping units required for co-living housing under the proposed code?
**A:** 24 sleeping units minimum, which equals six dwelling unit equivalents under the state's 4-to-1 conversion ratio.
**Q:** What state law requires cities to allow co-living housing?
**A:** House Bill 1998 (2024), codified as RCW 36.70A.535, requiring co-living wherever six or more multifamily units are permitted.
**Q:** What is replacing the "family" definition in city code?
**A:** "Household" - defined as an individual or collection of individuals occupying the entire dwelling unit, with no limit on unrelated persons.
**Q:** What zones will allow co-living housing?
**A:** Multifamily zones, commercial zones, and urban villages - areas where six or more multifamily units are currently permitted.
**Q:** What's the difference between a kitchenette and kitchen in co-living units?
**A:** Kitchenettes have a sink and 120-volt outlet for basic food prep; full kitchens have stove, oven, and full cooking facilities.
**Q:** How many parking spaces are required for co-living housing?
**A:** One parking space for every four sleeping units, or no parking required within half-mile of major transit stops.
**Q:** What amendment did the Planning Commission make to the proposal?
**A:** Simplified design review language to say "or co-living housing" instead of specifying "12 or more co-living sleeping units."
**Q:** What was the "rule of three"?
**A:** Previous city code limiting dwelling units to no more than three unrelated persons, unenforced since 2021 due to state law changes.
**Q:** What triggers design review for co-living projects?
**A:** Three or more dwelling units or co-living housing (which by definition has 24+ units), ensuring all co-living gets design review.
**Q:** What housing type is co-living replacing in city code?
**A:** "Boarding and rooming houses," which previously required conditional use permits and lengthy approval processes.
**Q:** When must the city comply with state co-living requirements?
**A:** By the end of 2025, making this a time-sensitive proposal for legal compliance.
**Q:** What's the maximum square footage for a co-living sleeping unit?
**A:** 300 square feet maximum, ensuring units remain smaller than typical apartments.
**Q:** How many sleeping units can share one kitchen facility?
**A:** Between 4 and 24 sleeping units must share each kitchen to ensure true co-living arrangements.
**Q:** What was the Planning Commission vote on final approval?
**A:** Unanimous 5-0 vote to recommend approval to city council with the design review amendment.
**Q:** When will this come before city council?
**A:** Late November 2025, as part of the second city council meeting that month.
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