The City of Bellingham's Land Use Policy Trick: Making Buildable Land Disappear.

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“Now you see it — now you don’t.”In most magic shows, the illusionist hides a rabbit. In Bellingham’s Planning Department, they hide developable land.

The Setup

City planners love to talk about “limited buildable land.”They point to charts and maps that show a shrinking supply, then use that “evidence” to justify higher density, smaller lots, and new fees. But behind the curtain lies a trick that would make Houdini proud: they don’t just measure land — they make it vanish on paper.

In the City’s 2025 Land Capacity Analysis, North Yew Street (UGA 15) — once the largest reserve for future housing — shows only 125 acres of “buildable” land left. Yet when we measured it parcel-by-parcel, the same area contained over 1,000 acres, with more than 870 privately owned and physically developable. This isn’t real demand-caused scarcity in the economic sense we all know; it’s a planning illusion born from subtraction.”

How the Trick Works

The sleight of hand happens through a stack of “deductions.”

Deduction Type	How It Shrinks Land
Critical Areas	Buffers double or triple in size, wiping out parcels that could easily host homes.
Stormwater Reserve	A blanket 25–33 % removal for pipes and ditches — even when infrastructure already exists.
Market Factor	Up to 40 % of all vacant lots are erased because staff assume owners “might not want to sell.”
Redevelopment Discount	A 25 % penalty on every parcel that isn’t totally empty.
Emergency Housing Carve-Out	Entire sites are deducted to satisfy a legislative checkbox.

Layer these “buffers” together, and two-thirds of the land disappears — without a single bulldozer moving an inch.

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Each of these may sound technical, but when combined, they erase real, buildable land — not because it’s undevelopable, but because it’s politically inconvenient.”

City of Bellingham says "Hold My Beer" when it comes to land use.

 Step 1 – What the City Code really says

Critical-Area Type	Buffer or setback in BMC Title 16	Where it applies	Notes / Citation
Wetlands	Category I = 150 ft Category II = 100 ft Category III = 75 ft Category IV = 25 ft	Measured horizontally from wetland edge	BMC 16.55.480(A)
Streams / Fish-bearing waters	Type F = 100 ft • Type Np = 75 ft • Type Ns = 50 ft	Both sides of stream centerline	BMC 16.55.480(B)
Steep slopes (>40%)	25 ft setback from top + 10 ft from toe	Any mapped slope area	BMC 16.55.440
Landslide / Erosion hazard	50 ft typical	Where mapped	BMC 16.55.460
Floodplain	Within FEMA 100-yr floodway = no build	Squalicum, Whatcom, Padden Creeks	BMC 16.55.420
Aquifer recharge	No specific setback; infiltration BMPs	City-wide	BMC 16.55.400

All of these are linear distances, not percentages. But you will see how COB Planning Department and the City will "up percentage" each requirement.

Step 2 – How planners turned those feet into percentages

Because they can’t model buffers parcel-by-parcel, staff run GIS overlays and then apply average deduction factors to whole sub-areas.Here’s how those distances roughly translate when generalized over mixed parcel sizes:

Code buffer (ft)	Approx. share of a 1-acre parcel lost	Rounded deduction planners use
25 ft (minor slope / Cat IV)	≈ 5–7 %	10 %
50 ft	≈ 10–15 %	15 %
75–100 ft	≈ 20–25 %	25 %
150 ft	≈ 30–35 %	30–35 %

Then they layer on top:

• Stormwater / ROW = +15–25 %

• Market factor = +25–40 %

Result: a “composite deduction” of 50–70 % of total area once all factors stack together — even though the code-based buffers alone might only eliminate 10–20 %.

Step 3 – Example: North Yew Street UGA

Component	Raw land (acres)	Deduction % (2025 LCA)	Acres removed	Notes
Critical-areas buffers	≈ 560	30 %	168	From wetland & slope overlays
Stormwater / ROW		25 %	140	Blanket deduction
Market factor		25 %	140	“Owner preference / infeasibility”
Total removed		≈ 65 %	≈ 448 acres	Leaves ≈ 125 acres buildable
Net housing capacity	—	—	≈ 540 units	Down from 938 (2018)

So roughly two-thirds of the area was erased on paper through generalized buffers and policy add-ons — not through new environmental mapping. AGAIN: No mention of how much property the city owns or its effect on buildable lot affordability and no new development occurred between 2018 and 2025 — the only thing that changed was the math.

Step 4 – Who defines those numbers

• The CAO buffer distances → set in BMC Title 16 (legally adopted ordinance).

• The conversion to % deductions → set internally by Planning & Community Development staff during LCA modeling.

• The decision to apply or inflate them → approved by the Mayor and City Council when they adopt the Comprehensive Plan or LCA update.

Here’s where the illusion flips.

The “Reverse” Part

In a normal magic trick, something physical disappears. In this one, it’s the definition of developable land that vanishes. Instead of starting with what exists and removing real constraints, the City starts with what it wants the outcome to be — a “shortage” — and works backward by inflating every deduction until the math fits the narrative.

Just to make sure the illusion holds, the City buys the easiest and most affordable parcels for itself — often with Greenways or Watershed funds. Those public purchases are immediately declared “protected,” permanently off-limits for housing. The result? Private builders and first-time buyers are left with the hardest, steepest, and costliest ground in town.

"When we look at the Yew corridor, especially west of Yew, the terrain is favorable and infrastructure already exists. That area would be the easiest to bring online for housing if it were available. However, most of that land is City-owned and designated for open space, so it’s not considered in the capacity model.”— City of Bellingham Planning & Community Development, Joint Growth-Management Workshop

Listen to when the planners "DON'T EVER SAY" when it comes to land use. They will never say up front just how many acres the city owns. They will say "land is City-owned and designated for open space", but they will never say what "percentage of open space" is required, or the actual percentage that the city owns. I'd say that 99% of residents in Bellingham have no idea the city owns 55% of the easiest property to develop.

The Cost of the Illusion

When land supply shrinks on paper, prices rise in reality. Impact fees climb. Permit timelines stretch. Developers pass the cost along to buyers and renters. And every time the City claims “we’re out of land,” it wins political cover to demand more density, more fees, and more control.

Capacity Implications (using the City’s own density factor ≈ 4.3 du/ac)

Scenario	Acres Counted as Buildable	Estimated Unit Capacity	Difference from City Claim (540 units)
City’s 2025 Land Capacity Analysis	125 ac	~540 units	—
Measured Reality (1,000 ac gross − 133 City-owned)	≈ 870 ac	≈ 3,740 units	+ 3,200 units of actual capacity

➡️ Even after deducting environmentally constrained parcels, the physical land area still supports several times the City’s stated “buildable” capacity. North Yew Street alone lost roughly 3,000 potential homes through spreadsheet manipulation. Multiply that by every UGA in Whatcom County, and the illusion costs thousands of families their shot at ownership.

Why It Matters

Washington’s Growth Management Act never required these inflated deductions. State law says to protect critical areas and ensure sufficient land for housing — not to erase acres because of policy preference. The “shortage” is a local choice dressed up as state compliance.

Here is the change the city made with the same UGA between 2018 and 2025. Note NOT A SINGLE PROPERTY WAS DEVELOPED BETWEEN THESE DATES.

Example: North Yew Street UGA

	2018 Annexation Strategy	2025 Land Capacity Analysis
Gross Land Area	≈ 560 ac	≈ 560 ac
Deducted Buffers & Factors	≈ 30 % (standard)	≈ 65 % (layered policy)
Net Buildable Acres	≈ 390 ac	≈ 125 ac
Estimated Housing Units	≈ 938	≈ 540

💬 Same land. Different math.

What looks like data is really direction. The mayor and city council set the priorities, the planning staff build the model to match them, and the public sees only the final slide deck:

“Limited capacity — time to densify.”

What the City’s Model Says vs. What the Land Shows

Subarea	Measured Total Acres	City-Owned Acres	Privately-Owned / Potentially Developable	Notes
North Yew Annex (West of Yew St)	~250 ac	133 ac	~117 ac	City holds over half of this annexation area.
N Yew Street UGA (East Side)	~300 ac	—	~300 ac	Entirely unbuilt in the 2018/2025 models.
Combined North Yew Corridor	≈ 1,000 ac total (300 + 250 + remainder areas)	133 ac	≈ 870 ac privately owned / developable	Confirms much larger area than the City’s reported ~560 ac.

Pulling Back the Curtain

Once you see the trick, you can’t unsee it. Land didn’t disappear. It was deducted. And while officials insist it’s “just methodology,” the outcome is the same: fewer lots, higher prices, and a city increasingly owned by itself.

Pattern Over Time

Report Year	Document	Behavior Repeated
2003–2005	Final EIS Appendix D – Land Supply Methodology	Inflated “critical-area” + “market factor” deductions; no ownership accounting.
2018	Annexation Strategy	UGAs labeled “mostly constrained”; large City parcels treated as off-limits.
2025 (Draft)	Land Capacity Analysis	Even larger deductions; City-owned land again omitted.

So next time a planner says “there’s no more room for housing,” ask them to show their math. Ask how 1,000 acres became 125 acres. Ask why the City keeps buying starter-home land while preaching affordability.

Because this isn’t magic. It’s manipulation — and the cost of the trick is paid by every future homeowner who can no longer afford to live here.

Sources & Data

• City of Bellingham 2018 Annexation Strategy

• 2025 Whatcom County Land Capacity Analysis (Draft)

• Field measurements — North Yew Street UGA (2025)

• Real Housing Reform Initiative Analysis

Call to Action

If you want a transparent, data-based housing policy in Bellingham, share this post, tag @RealIssuesPodcast, and subscribe at www.RealHousingReform.org. The only way to stop the illusion is to shine a light on the stage.