## Meeting Overview The Bellingham City Council Public Works and Natural Resources Committee convened on September 29, 2025, for a focused 30-minute session that centered on a critical infrastructure decision at the city's Post Point Wastewater Treatment Plant. Chair Hannah Stone presided over the committee, joined by members Lisa Anderson and Jace Cotton, along with Mayor Kim Lund and key staff members. The sole agenda item before the committee was authorization to apply for state approval to use an alternative project delivery method for a major emissions control upgrade project — a $40 million investment to modernize the plant's air pollution control systems to meet stricter federal standards. The meeting revealed both the technical complexity of municipal infrastructure decisions and the underlying community tensions around wastewater treatment that have simmered since the city's controversial PFAS discovery in biosolids several years ago. While the meeting proceeded with careful technical explanations and ultimately unanimous approval, it also highlighted ongoing community concerns about transparency and alternative approaches to sewage treatment — concerns that staff and elected officials acknowledged would require continued engagement in the months ahead. ## The Post Point Emissions Control Challenge Steve Day, the city's plants engineer, laid out the scope and urgency of the emissions control upgrade project with methodical precision. The Post Point plant, serving over 95,000 residents with a peak capacity of 72 million gallons per day, operates two multiple hearth incinerators that burn dewatered sewage sludge. These incinerators, constructed years ago, currently meet older emission standards but need upgrading to comply with the more stringent "Quad L" standards under federal Clean Air Act regulations. "Obviously the number one project driver here is to maintain our city's commitment to environmental stewardship," Day explained. "The sole purpose of the post-point plant is to reduce both emissions to our water bodies and our air bodies as well." The project involves completely replacing the existing air pollution control equipment with new technology including venturi scrubbers, wet electrostatic precipitators, regenerative thermal oxidizers, and granular activated carbon systems. Day outlined an aggressive timeline: completion of basis of design by early 2026, full design by late 2027, construction beginning in 2028, and both new emission control trains operational by early 2031. The complexity extends beyond just installing new equipment. As Day emphasized, "the flow does not stop at post-point" — the plant must maintain continuous operations throughout the multi-year construction process while meeting all regulatory requirements. This operational constraint, combined with the technical complexity and tight schedule, drove staff's recommendation for a collaborative delivery method. ## The Case for General Contractor/Construction Manager Rather than the traditional design-bid-build approach where the city would hire an engineer to design the project and then separately bid it to contractors, staff recommended the General Contractor/Construction Manager (GC/CM) model. This approach brings the contractor onto the project team during the design phase, creating what Day described as "an embedded relationship for them to work together." Day methodically walked through the advantages: early contractor input on constructability, the ability to pre-procure long-lead equipment, cost transparency throughout design rather than just at bid time, and crucially, contractor expertise in maintaining plant operations during construction. "Many wastewater and water industries have turned to this type of method because the plants are so critical, they're so complex, and they require that input to be considered early," he explained. The city has successfully used this approach twice before at Post Point — once for a project that went to construction in 2012, and again for a biosolids project authorized by council in 2021 (though that project was later cancelled due to PFAS concerns). Mike Olinger, Deputy Public Works Director, reinforced that "we have full intention of coming back to award that contract" when a contractor is selected, preserving council oversight while gaining the benefits of early collaboration. State law requires approval from the Project Review Committee to use alternative delivery methods, with an application deadline of October 15th. Once approved, the city would issue a Request for Proposals in early 2026, selecting a contractor based on qualifications and pricing factors rather than just low bid. As Day noted, "we still get that element of value pricing there, but have the additional support from the contractor early on." ## Community Concerns and Alternative Voices The technical discussion was interrupted by deeper questions from Council Member Lisa Anderson about community opposition to the project direction. Anderson revealed that the city had received "a bunch of communication over the weekend" from community members proposing an alternative approach to sewage treatment entirely. "There is a community member who we have received a lot of communication who has also been communicating out in the public of an alternative method that would, in their opinion, be substantially less," Anderson explained. The alternative involves drying sewage sludge to cake and shipping it to eastern Washington for disposal rather than incinerating it locally. Anderson expressed skepticism about this approach, noting the extensive permitting requirements from EPA and state ecology, the decades-long timeline, and the state's push to reduce organic waste in landfills. "Even though we do send ash, it is very different than dried out cake which is highly organic," she pointed out. The discussion revealed the lasting impact of the PFAS discovery that derailed the city's previous biosolids project. "We stopped a process after probably over a decade of work and research of choosing which direction to go for our sewer treatment," Anderson noted. "So now we're at a point of ensuring that our sewer treatment is stable and one of an important element... is that this is a vital piece to it." Anderson wanted assurance that community members would have opportunities to present their concerns before the city commits to the full $40 million construction project. While supporting the application to move forward, she emphasized the need for meaningful engagement: "I want to make sure that they have an opportunity to have a seat at the table to have that conversation." ## Mayor's Regulatory Reality Check Mayor Kim Lund stepped in with a firm reminder of the regulatory framework constraining the city's options. She confirmed that meetings with community members would happen — in fact, one had been scheduled just five minutes before the committee meeting — but emphasized that "we are working within a regulatory framework right now to come into compliance and this council has voted to support coming into compliance right now." The mayor then read directly from a recent Washington State Department of Ecology bulletin addressing the alternative disposal approach: "Landfilling biosolids contradicts state laws implemented to limit organics in the landfill and leads to increased production of greenhouse gases. Furthermore... Washington state does not have adequate SSI or landfill capacity to dispose of the biosolids we generate each year." "I want to just put that out there so that this is ecology's own guidance to how we're moving forward right now," Lund stated. "And in their perspective, landfilling is not a statewide viable alternative for solids waste handling." Legal counsel Matt Stamps added the enforcement context: "We are in a... notice of violation pending from the Northwest Clean Air Agency with respect to Post Point and operations down there." The city's commitment to this emissions control project is "a critical component of moving forward with NWAKA here," he noted, referring to the regional air quality agency. ## Technical Comparisons and Council Questions Council Member Michael Lilliquist raised an important technical question about why the city chose GC/CM over progressive design-build, which Whatcom County selected for their justice center project. Day's response highlighted the city's desire to maintain design control: with progressive design-build, "you essentially give them set a criteria and say, you need to build me something that does this... you lose quite a bit of your direct input to the design." Under GC/CM, the city retains the ability to review designs at 30%, 60%, and 90% completion and "steer that project in the right direction." As Day noted, "the city still is regulatory responsible for the actions that take place at the plant. And if we go with one of these other types, we give up some of that control, but yet we're still responsible for it." Council Member Jace Cotton asked about the approval process, confirming that contractor selection would return to council. The initial design-phase contract would be relatively small — perhaps $500,000 to $750,000 — but gives the contractor opportunity to propose construction pricing through "essentially a large modification to that initial contract." Olinger emphasized that there are multiple "off-ramps" where council can stop the process, continuing "until we award a construction contract." This preserves council oversight while gaining the collaborative benefits during design. ## Timeline Pressures and Good Faith Compliance The discussion revealed the delicate balance the city must strike between community engagement and regulatory compliance. The October 15th application deadline creates immediate pressure, but Anderson confirmed that between application submission and RFP issuance in January 2026, "we have at least a few months before we're further committed into this process that should compelling information come forward, we would have time to take that into consideration." Chair Stone emphasized the regulatory context: "Our good faith in our words and actions and how we're moving forward is critical in maintaining that path forward" with regulators. The city cannot afford to appear to be delaying or avoiding compliance with emission standards. Anderson ultimately moved to approve, emphasizing both support for the methodology and recognition of community concerns: "I do support this methodology... having the ability to have the engineer and construction work together. I've worked in a shipyard. I know what change orders cost and so I think that will minimize that and we'll get a better design." She also acknowledged the community engagement commitment: "We were asked in emails to not forward this and I wanted individuals in the community to know they were heard and that there's still time to have those conversations. But we do have a pending deadline and ultimately I think the most important element is that we do improve our emission control regardless." ## Retaining Specialized Legal Counsel The agenda item also included authorization to retain Michael Loulakis, a nationally recognized expert in alternative project delivery methods, to provide legal counsel throughout the GC/CM process. Loulakis had previously assisted the city on the 2021 biosolids project and brings specialized expertise in complex infrastructure procurement. The legal support reflects the complexity of alternative delivery methods and the city's commitment to following proper procedures. As the staff memo noted, Loulakis is "well known and an expert in this field" with extensive experience in design-build and construction management approaches. ## Unanimous Approval and Path Forward Despite the community concerns and extensive discussion, the committee voted 3-0 to recommend approval. The recommendation advances to the full council meeting that evening, with Chair Stone noting she would "bring forward that recommendation this evening." The approval authorizes staff to submit the Project Review Committee application by the October 15th deadline and retain Loulakis for legal services. If the state committee approves the GC/CM approach in December, the city will begin contractor market sounding and RFP development for early 2026 issuance. ## What's Ahead The emissions control upgrade represents one of the most significant infrastructure investments in Bellingham's recent history, with implications for environmental compliance, public health, and fiscal responsibility. The GC/CM delivery method offers promise for better cost control and risk management, but also requires navigating complex procurement procedures and ongoing community concerns. The next several months will test the city's ability to balance regulatory compliance with community engagement. While the technical path forward has council support, the broader questions about wastewater treatment alternatives and public participation in major infrastructure decisions remain unresolved. As the meeting concluded, the immediate focus shifts to preparing the state application and continuing conversations with concerned community members. The $40 million price tag and multi-year construction timeline ensure this project will remain a significant focus of civic attention as Bellingham works to modernize its critical infrastructure while maintaining the environmental stewardship commitments that define the community's values.

### Meeting Overview The Public Works and Natural Resources Committee met on September 29, 2025, to consider using a collaborative construction delivery method for the Post Point Wastewater Treatment Plant emission control upgrades. The committee unanimously approved staff's request to apply to the State Project Review Committee to use a General Contractor/Construction Manager (GC/CM) approach for this $40 million project. ### Key Terms and Concepts **General Contractor/Construction Manager (GC/CM):** A collaborative project delivery method where a contractor is brought on board during the design phase to provide construction input, rather than only after design is complete. **Design-Bid-Build:** The traditional construction delivery method where design is completed first, then the project is competitively bid for construction. **Project Review Committee (PRC):** A state committee that must approve the use of alternative delivery methods like GC/CM for public projects in Washington State. **Post Point Wastewater Treatment Plant:** Bellingham's sewage treatment facility that serves over 95,000 residents and processes up to 72 million gallons per day. **Quad L Emission Limits:** Federal air quality standards (40 CFR Part 60 Subpart LLLL) that require more stringent emission controls than current standards. **Notice of Violation (NOV):** A pending enforcement action from the Northwest Clean Air Agency regarding Post Point's current operations. **Biosolids Project:** A previous Post Point project that was stopped in 2021 due to PFAS contamination concerns in the end product. **PFAS:** Per- and polyfluoroalkyl substances, often called "forever chemicals," that are persistent environmental contaminants. ### Key People at This Meeting | Name | Role / Affiliation | |---|---| | Hannah Stone | Committee Chair, First Ward Council Member | | Lisa Anderson | Committee Member, Fifth Ward Council Member | | Jace Cotton | Committee Member, At-Large Council Member | | Kim Lund | Mayor | | Mike Olinger | Deputy Director, Public Works | | Steve Day | Plants Engineer, Public Works | | Matt Stamps | Assistant City Attorney | | Michael Loulakis | Legal consultant for GC/CM process | ### Background Context This decision comes after the city stopped its previous biosolids processing project due to PFAS contamination concerns. Now the city must upgrade its emission control equipment to meet stricter federal air quality standards while continuing to operate the plant that treats all of Bellingham's wastewater. The Northwest Clean Air Agency has issued a notice of violation for current emissions, creating regulatory pressure to move forward quickly. The city has successfully used the GC/CM approach on two previous Post Point projects—one completed in 2012 and another authorized in 2021 (though later cancelled). This collaborative approach allows the contractor to provide input during design, potentially reducing change orders and improving constructability while maintaining the plant's critical operations. Community members have raised concerns about this project, advocating for alternative approaches like drying and transporting waste to eastern Washington landfills. However, state ecology officials have stated that landfilling biosolids contradicts state laws and Washington lacks adequate landfill capacity for this approach. ### What Happened — The Short Version Staff presented their recommendation to use GC/CM delivery for the emission control upgrades project and to retain legal expert Michael Loulakis. Steve Day explained that GC/CM provides early contractor input during design, allows pre-procurement of specialized equipment, and enables better coordination to maintain plant operations during construction. Council Member Anderson acknowledged community concerns about the project approach but supported moving forward with the application deadline of October 15th. She emphasized there would still be opportunities for community input between now and when construction contracts are awarded. Mayor Lund confirmed meetings with concerned community members would happen and read state ecology guidance opposing landfilling as an alternative. Council Member Cotton asked about the selection process, confirming that contractor selection would return to council for approval. Council Member Lulakis questioned why progressive design-build wasn't considered instead, with staff explaining that GC/CM maintains more city control over the design process. The committee unanimously approved authorizing the PRC application and retaining Michael Loulakis for legal services. ### What to Watch Next - PRC application due October 15, 2025 - PRC review and decision in December 2025 - If approved, RFP issuance in January 2026 - Community meetings between now and contractor selection - Contractor selection returning to council for approval (estimated 2026) - Construction timeline: 2028-2031 ---

**Q:** What is the estimated cost of the emission control upgrades project? **A:** $40 million, funded through the Sewer Fund. **Q:** What is the deadline for submitting the PRC application? **A:** October 15, 2025, for consideration at the December PRC meeting. **Q:** How many Post Point projects has the city previously used GC/CM delivery for? **A:** Two—one completed construction in 2012, and one was authorized in 2021 but later cancelled. **Q:** Who is Michael Loulakis and why does the city want to retain him? **A:** A nationally recognized legal expert in alternative project delivery methods who previously advised the city on the 2021 biosolids project. **Q:** When is construction expected to be completed? **A:** Between late 2030 and early 2031, bringing both new air emission control trains online. **Q:** What federal emission standards must the project meet? **A:** Quad L emission limits (40 CFR Part 60 Subpart LLLL). **Q:** Which regulatory agency issued a notice of violation to the city? **A:** The Northwest Clean Air Agency for current Post Point operations. **Q:** What is the main benefit of GC/CM over traditional design-bid-build? **A:** Early contractor involvement during design provides construction input, cost transparency, and better coordination to maintain operations. **Q:** When would an RFP be issued if the PRC approves the application? **A:** Early 2026, probably January, to coincide with completion of the basis of design report. **Q:** How many residents does Post Point serve? **A:** Over 95,000 residents in the Bellingham area. **Q:** What is the peak hydraulic capacity of Post Point? **A:** 72 million gallons per day. **Q:** Why did the city stop the previous biosolids project? **A:** Due to PFAS contamination concerns in the end product. **Q:** According to state ecology, why is landfilling biosolids not viable? **A:** It contradicts state laws, increases greenhouse gases, and Washington lacks adequate landfill capacity. **Q:** Who will the contractor selection come back to for approval? **A:** City Council, though state law doesn't require it, the city intends to follow past practice. **Q:** What happens if the city and contractor can't agree on pricing? **A:** There are "off-ramps" allowing the city to convert to traditional bidding until a construction contract is awarded. **Q:** When must contractor negotiations be completed? **A:** By September 30, 2026, to meet regulatory milestone requirements. **Q:** What committee members voted on this item? **A:** Chair Hannah Stone, Lisa Anderson, and Jace Cotton—all voted yes. **Q:** Why didn't the city consider progressive design-build? **A:** It would give the city less control over design decisions while still leaving the city responsible for plant operations. **Q:** What specialized equipment will the upgrades likely include? **A:** Venturi, wet scrubber, wet electrostatic precipitator, regenerative thermal oxidizer, and granular activated carbon. **Q:** Will there be opportunities for community input before construction begins? **A:** Yes, meetings are scheduled and there are several months before further commitments are made. ---