City of Bellingham Water Resources Advisory Board

The Bellingham Water Resources Advisory Board received a comprehensive briefing on the future of wastewater solids management at the Post Point Treatment Plant, addressing one of the city's most complex infrastructure challenges. The presentation, delivered by Superintendent Steve Bradshaw and Engineer Steve Day, outlined the city's path forward after abandoning a $200+ million biosolids project in 2022 due to escalating costs and emerging PFAS contamination concerns. The board learned that the city will proceed with emissions control upgrades to existing incinerators while developing a comprehensive sewer plan over the next two years to identify long-term solutions. The emissions upgrade project, costing significantly less upfront than landfilling alternatives, keeps treatment local under city control while buying time for next-generation technologies to mature. Staff emphasized that landfilling would cost $189 million over 20 years compared to $70 million for the emissions upgrade, while adding 3-4 truck trips daily through Fairhaven and creating dependency on outside vendors. The presentation revealed the challenging regulatory landscape surrounding PFAS (per- and polyfluoroalkyl substances) in biosolids, with states like Maine banning land application while the federal government has provided little guidance on safe levels. Washington will require PFAS sampling by 2027, adding another layer of uncertainty to future planning. The discussion highlighted that Bellingham's PFAS concentrations are very low compared to communities with industrial sources, reflecting general community background levels rather than concentrated contamination. Board members engaged in detailed questioning about the decision-making framework, carbon emissions comparisons, and permitting challenges for new incinerators. The meeting concluded with recognition that this issue will require hundreds of millions in ratepayer investment over the coming decades, with no external funding sources available to the city.

No formal votes were taken during this informational meeting. The presentation served to brief board members on the current status of wastewater solids management and upcoming comprehensive planning process. Key informational updates provided: - Emissions control upgrade project will proceed (previously authorized via AB 24670) - Comprehensive Sewer Plan development will begin in 2026 with public engagement - Timeline established: technology updates in early 2026, public engagement mid-2026, recommendations in early 2027, rate study mid-2027, final plan late 2027 - Goal to identify and design next treatment system by mid-2030s

**Steve Bradshaw, on PFAS regulatory challenges:** "None of the solutions at hand are ideal in any way, and what we thought we were getting into in 2016 to 2022 was the best and greenest, even if it had a slightly higher cost approach, and it really did check all of the boxes at that time." **Joel Pfundt, on community investment decisions:** "We want to make sure that we're getting that right, and that kind of thing, so that's what we will be working on... it will all, in the end, fall to the ratepayers of Bellingham to fund that." **Steve Day, on PFAS concentrations:** "Our concentrations in our product represents, really, the concentrations that are in your carpet, or your home, or your bloodstream already. It's reflective of the community." **John Peppel, on decision-making frameworks:** "In the IT world for, like, let's say, security. They'll break down what level of perfection you want... And the first process was to decide what level of perfection are we shooting at." **Steve Bradshaw, on regulatory uncertainty:** "I'm looking for clarity in the world of PFAS and biosolids land application, because none of the solutions at hand are ideal in any way." **Carl Benson, on PFAS source control:** "Has the city, or are there any organizations of cities or municipalities that can deal with the situation in Washington where there doesn't seem to be much urgency in getting PFAS out of consumer products."

# Water Resources Advisory Board Faces Bellingham's Biggest Wastewater Challenge ## Meeting Overview The Bellingham Water Resources Advisory Board convened at Pacific Street Operations on November 25, 2025, for what would prove to be one of the most substantive technical briefings in recent memory. Present were board members John Peppel, Fiona McNair, Carl Benson, and Martin Kjelstad, along with City staff including Director Joel Pfundt, Superintendent Steve Bradshaw, Engineer Steve Day, and project manager Rush Duncan. The evening's focal point was a comprehensive presentation on Post Point solids management — a decades-long challenge that has become increasingly complex as federal regulations around PFAS (per- and polyfluoroalkyl substances) have upended traditional approaches to biosolids management across the country. With the city facing critical infrastructure decisions that will cost hundreds of millions of dollars and affect Bellingham ratepayers for decades, the presentation aimed to provide the advisory board with the technical foundation they'll need as the city moves toward its comprehensive sewer planning process in 2026-2027. Also attending were two members of the public: an inventor hoping to share a water-saving device with the board, and James Perkins, a student observing for a school assignment. The meeting reflected the complex intersection of municipal engineering, environmental regulation, and community engagement that defines modern wastewater management. ## The Post Point Wastewater Challenge: A 50-Year Legacy Meets Modern Complexities Superintendent Steve Bradshaw and Engineer Steve Day opened with a detailed history that traces back to 1974, when Bellingham built its first incinerator at Post Point — "a major environmental step forward at that time." Before then, the city's wastewater received only basic primary treatment at C Street before being discharged directly into Bellingham Bay. "Prior to 1974, our wastewater received basic primary treatment at C Street prior to being directly discharged into Bellingham Bay," Bradshaw explained. A second incinerator was added in 1994 "for redundancy and reliability," creating a system that has provided "50 years of continuous and local treatment under state and regional oversight." The presentation revealed how what seemed like a straightforward infrastructure challenge has become infinitely more complex. In 2012, the city upgraded the liquid side of the treatment plant, but the solids stream "was value engineered out as cost competing project priorities." Three years later, city planners launched an ambitious resource recovery project using anaerobic digestion. "The project was selected because it reflected sustainability goals — beneficial reuse, energy generation, and a low carbon footprint," Day said. "With years of technical and community work," the biosolids project seemed to check all the boxes for modern environmental stewardship. But then came PFAS. "By 2022, the project cost for the biosolids conversion project had grown to more than $200 million," Bradshaw continued. "At that time, new concerns of PFAS and other contaminants made biosolid reuse uncertain. There were no available technologies that could meet all three of the priorities, which was affordability, reliable service, and environmental certainty." The reality was stark: what city planners thought would be the greenest, most sustainable approach to wastewater management had become a regulatory and financial quagmire. "With those risks in mind, the City Council made the decision to pause that project and refocus on maintaining reliability, compliant operations using proven systems already in place at Post Point." ## The Numbers Behind the Decision The staff's re-evaluation of options focused on three approaches: continuing incineration with emissions upgrades, transitioning to landfilling, or pursuing new technologies. The cost analysis they presented tells a compelling story about long-term municipal planning. "This table summarizes what we found when we looked at the cost and operational impacts," Day said, walking through projections that show landfilling appearing similar in short-term costs but becoming "significantly higher" over 20 years, "largely due to the hauling and the vendor fees." Board member John Peppel pressed for clarification on numbers that seemed counterintuitive: "It's not commonsensical to me for, like, $70 million to go to 189 on hauling and vendor fees. Does that... what makes those skyrocket like that?" Day's response revealed the assumptions driving the analysis: "The trucking price would increase with inflation at a minimum, up to 5% per year, and then we'd also... with growth in the city, annual volumes increase of at least 1%." The trucking costs, he explained, are "all-in numbers" that include both transportation and disposal fees at distant landfills. More significantly, landfilling would require "3 to 4 truck trips through Fairhaven" and would "add odor, methane, and traffic impacts" while creating dependency on outside vendors with "no clear timetable for a new technology." "When we step back and look at the overall picture, the difference becomes clear," Bradshaw said. "The emissions project costs more up front, but keeps treatment on site and has the lowest long-term costs. Landfilling costs more over time and adds truck traffic and dependency on outside vendors." ## Why Not Just Switch to Landfilling Temporarily? Board members explored whether the city could simply shut down its incinerators and use landfilling as a temporary bridge while new technologies mature. The staff response revealed regulatory complexities that make such transitions far more permanent than they might appear. "What we found is that landfilling isn't a short-term option," Bradshaw explained. "Once the incinerators are shut down, they can't be restarted as they currently are permitted, and selecting, permitting, and building a new system would take 10 to 15 years." This regulatory reality means "committing to landfill for the entire period and at much higher long-term cost. It also means losing our emergency backup. We can't store solids on site, so any interruption in hauling creates an immediate operational risk." The presentation compared Bellingham's situation to other Puget Sound communities facing similar challenges. In Lynnwood, "their incinerator was shut down after years of compliance issues. Emergency hauling was the only available option for them. The long-term plan is to build a digestion system and apply biosolids. This is the same project we stopped in 2022." Edmonds has "transitioned to a gasifier system. But that new equipment isn't yet operational, so they are still landfilling solids in the meantime. The project has been under delays for many years and still hasn't shown signs of being completed or operational yet." The contrast was clear: "In both cases, landfill is temporary, driven by loss of treatment capacity, not by choice. Both cities still face several years of transition. In contrast, Bellingham's system is operational and compliant today." ## The PFAS Uncertainty and Industry-Wide Impact Much of the evening's discussion centered on PFAS — the "forever chemicals" that have upended biosolids management nationwide. Staff painted a picture of an industry grappling with regulations that vary widely because "there's been little federal guidance on what is a safe level related to PFAS in biosolids." "It is an endemic issue within the industry," Day said. "Every conference you attend regarding wastewater, especially with relation to the solids handling, a huge focus is really in reaction to state-applied bans on land application, most notably Maine." The federal government "hasn't taken a stance," creating a patchwork of state regulations. "We would like to see some strategy at both the state and federal levels," Day said. Board member Carl Benson asked whether there were municipal organizations working on PFAS policy at the source — trying to get the chemicals out of consumer products rather than dealing with them at treatment plants. Day acknowledged this was "definitely an important element, but they are, as you said, so ubiquitous. There's maybe limited political leverage for a city of our size to even enact a ban." Importantly, staff emphasized that Bellingham's PFAS levels are relatively low. "Ecology ran a recent PFAS assessment through wastewater treatment plants in Washington State, and their findings, including here in Bellingham, is that across the board, generally, wastewater treatment plants in Washington state have very low concentrations of PFAS. We're very close to background." "Our concentrations in our product represents, really, the concentrations that are in your carpet, or your home, or your bloodstream already. It's reflective of the community," Day explained. "We do not have on-site industrial generators in Bellingham, very few in Washington State. We don't have the DuPonts or the 3Ms." ## Technical Details and Future Planning Board members pressed for technical details about the proposed emissions upgrades. The current system operates under regulations for incinerators built before 2010, but the upgrades will bring the facility up to standards "as if we were a brand new incinerator." "There's, I think, 9 categories of pollutants regulated under, effectively, the sewage sludge incinerator rules," Day said, listing carbon monoxide, nitrogen oxides, sulfur oxides, particulates, sulfur dioxide, and mercury. The new standards are "generally much lower, in some cases multiple factors lower." The upgrades will also address other infrastructure needs: "Roof replacements, generator replacements, sludge tank renewal, environmental work cleanup, and upgrades to our control systems." When Peppel asked about the timeline for ultimate replacement of the incineration system, the response revealed the complexity of major infrastructure planning. "If you start design by the mid-2030s, you're talking about mid-2040s to be operational," Peppel observed. "On a capital project of that magnitude, it's roughly in that zone," Bradshaw confirmed. "I think we intend to start it a bit earlier." Day offered a sobering assessment of what keeps him awake at night: "I'm looking for clarity in the world of PFAS and biosolids land application, because none of the solutions at hand are ideal in any way, and what we thought we were getting into in 2016 to 2022 was the best and greenest, even if it had a slightly higher cost approach, and it really did check all of the boxes at that time." "This PFAS industry headwind has been a major challenge of upending dozens of states and millions of residents in costs for disposal of what our state says is a product, not a waste," he continued. "But if we can't put it... can't get it into the area that needs to get into due to health concerns over PFAS... it's a tricky, tricky subject to solve." ## Community Engagement and Decision-Making Frameworks The discussion turned to how the city will engage the community in making decisions about hundreds of millions of dollars in infrastructure investments. Director Pfundt emphasized the challenges ahead: "In Bellingham, we don't have... like, you know, some big industry or something like that, that we can rely on to help fund that, so it will all, in the end, fall to the ratepayers of Bellingham to fund that." Board member Peppel offered insights from his experience in other industries, suggesting a decision-making framework that establishes acceptable levels of performance upfront. "Like, in the IT world for, like, let's say, security. They'll break down what level of perfection you want. So, for example, if you're a bank, you need a lot different level of security than you do if you're a hot dog stand, right?" "The first process was to decide what level of perfection are we shooting at," Peppel explained. "To get the clarity around, you know, people are always going to talk number 5, but now we agreed to number 3. This is the reason why we're not a bank or a this. But that added a lot of clarity around what otherwise becomes disjointed discussions." Day acknowledged the value of such frameworks but noted the additional complexity of emerging technologies: "There's always a desire to do better, right? And there's... we could meet minimum regulatory standards. We could try to clean it a bit more, or we could try to be, you know, super environmentally progressive, if you will. The challenge with that is, especially if you focus on that decision early in the project... of course, everybody wants to be progressive on the environmental side, because they don't really know what it's going to cost." ## The Path Forward Staff outlined a two-year timeline for comprehensive planning that will shape Bellingham's wastewater future. "Early 2026, we'll bring forward the state of technology update. The public engagement for the sewer comp plan will begin in mid-2026. Early recommendations will come out earlier in 2027 for feedback, followed by the comprehensive rate study in mid-2027." "By late 2027, we will expect to have final draft of the sewer comp plan and rate recommendations. Throughout this process, we'll be focused on keeping the work transparent and involving the community in each step." The comprehensive sewer plan will "evaluate long-term options and include public engagement through the Water Resource Advisory Board and the Council." Staff committed to continuing to monitor new technologies like "gasifiers and pyrolysis and supercritical water oxidation" as they mature. ## Public Comment and Board Transition The meeting began with public comment from an inventor who had developed what he described as a water-saving device for bathtubs. "I'm an inventor, and I have invented a... it takes no water at all. And it attaches to the bathtub. And it goes down the drain. So there is actually no water at all... It saves gallons and gallons of water every day." Board Chair Rush Duncan arranged to follow up with the inventor after the meeting rather than have him retrieve the device during the presentation. The evening also marked a transition for the board, as member Martin Kjelstad noted this was his final meeting. "I'd like to thank everybody for making me a part of it," Kjelstad said, particularly thanking Chair Duncan. When asked for parting wisdom, Kjelstad observed simply: "There's a lot of work to do." ## Closing: The Weight of Infrastructure Decisions As the meeting adjourned at 6:50 p.m., the magnitude of the decisions facing Bellingham became clear. The city must navigate complex regulations, emerging environmental concerns, evolving technologies, and significant financial commitments — all while maintaining reliable service for a growing community. The emissions upgrade project provides a bridge to maintain compliance while longer-term solutions are developed. But the fundamental challenge remains: how to manage the waste stream from a medium-sized city in an era when traditional approaches have been upended by environmental and health concerns that weren't even on the radar when Bellingham built its treatment systems. As staff emphasized throughout the presentation, this is not just a technical challenge but a community one. The decisions made in the coming years will affect ratepayers for decades and reflect Bellingham's values around environmental stewardship, fiscal responsibility, and public health. The comprehensive sewer planning process beginning in 2026 will be the community's opportunity to grapple with these trade-offs and chart a course forward. The Water Resources Advisory Board now has the technical foundation to engage meaningfully in those discussions. The real work, as Kjelstad observed, is just beginning.