Whatcom County Planning Commission Challenges Bellingham's $133M Low-Income Housing Plan

Meeting: Whatcom County Planning Commission
Date: January 22, 2026
Meeting Type: Final Public Hearing - Comprehensive Plan Update
Location: Whatcom County

Executive Summary

In their final comprehensive plan review session, the Whatcom County Planning Commission formally recommended that the County Council require the cities of Bellingham and Blaine to adopt "reasonable measures" under the Growth Management Act to meet their housing obligations. The commission raised serious concerns about Bellingham's proposal to fund affordable housing through an annual $133 million allocation - equivalent to the city's entire annual budget - questioning both the legality and economic viability of the plan. The recommendation passed 5-2 with one abstention after extensive debate about how forcefully to challenge Bellingham's assumptions.

Key Decision: Challenging Bellingham's Housing Funding Model

The Core Problem Identified

Commissioner Brown presented a detailed critique of Bellingham's affordable housing funding strategy:

Bellingham's Proposal:

• Allocate an additional $133 million annually over 20 years
• Build 220 additional affordable housing units per year
• Fund the current and anticipated affordable housing needs

Commissioner Brown's Analysis:

• Would require approximately $3,000 per household annually
• No legal mechanism exists under state law to collect such funding
• "The money cannot be collected, therefore the thing fails on its face"
• If collected, would push existing homeowners into poverty
• Would increase the need for subsidized housing, creating a vicious cycle
• Landlords would pass costs on as $250/month rent increases
• Would incentivize residents to move to rural areas to avoid the tax

Critical Context:

• Whatcom County is the second most expensive place to build housing in Washington (after Okanogan County)
• Building costs are 55% higher than the statewide average
• Mercer Island and Kitsap County were forced to revise their plans by courts for proposing affordable housing without viable funding mechanisms

The Bellingham Response

Chris B, Bellingham's Long Range Planning Division Manager, clarified the city's position:

• The $133 million gap is an analytical identification, not a proposed tax
• Bellingham has "never even contemplated" a $3,000 per household tax
• The city has land capacity for housing from a regulatory standpoint
• Current funding includes approximately $15 million annually from:
  • Federal sources (9%)
  • Affordable housing levy money (56%)
  • Other local dollars
• City anticipates this funding continuing at existing levels
• Plan includes multifamily tax exemptions and density incentives
• "We don't pretend that's going to fix the solution...it's everything we feel is reasonable given the resources of our community"

The Funding Reality Check

Commissioner Brown broke down Bellingham's $15 million annual affordable housing funding:

Historical Sources (2024):

• Federal funding: 9%
• Affordable housing levy: ~56%
• ARPA (federal pandemic relief) dollars: remainder

The Problem:

• ARPA dollars are gone - no more federal pandemic relief
• Of the $15 million, approximately $13.5 million must now come from Bellingham taxpayers
• Federal government unlikely to allocate substantial funds to Bellingham when the same money could build twice as many units in Spokane

"Where is the $133 million going to come from?" - Commissioner Brown

The "Reasonable Measures" Recommendation

After extensive debate, the commission revised their language from "reject the plan" to require "reasonable measures":

Final Recommendation to County Council: "The Whatcom County Planning Commission recommends that you require the cities of Bellingham and Blaine adopt reasonable measures as defined by the Growth Management Act to amend their plans to meet their obligations under the GMA."

What "Reasonable Measures" Means:

• A specific legal term in the Growth Management Act RCW
• When a community cannot meet GMA goals through normal process, it must:
  • Review permitting rules
  • Examine zoning codes
  • Reassess how it conducts permitting and construction
  • Find ways to meet growth projections within realistic constraints

Why This Matters:

• Only the County Council can require cities to adopt reasonable measures (not the Planning Commission)
• This gives the Council the legal authority to push back on Bellingham
• Frames the issue as about viability and legal compliance, not just disagreement

The Blaine Component

Commissioner Brown also raised concerns about the City of Blaine's UGA (Urban Growth Area) proposals:

What Blaine Did:

• De-annexed a chunk of land that was ready for development
• 168 units were ready for immediate construction
• 1,000 total units planned, 100 dedicated for affordable housing
• De-annexed land was "largely dry" (not wetlands)

Blaine's New Proposal:

• Proposes growth in an area that is "almost entirely wet or buffers"
• Has not identified:
  • Source of wetlands mitigation
  • Cost of mitigation
  • Who will pay for mitigation
  • Whether costs make land affordable or unaffordable

Commissioner's Concern: "How is this economically viable? How's it going to work?"

The Debate Over Blaine

Respecting Local Democracy: Commissioner Dundes strongly opposed interfering with Blaine voters' decision:

• "The people in Blaine voted to de-annex that area"
• "I think it's pretty arrogant of us to jump in and tell the city of Blaine voters they made a mistake"
• "I still support the voters of City of Blaine and their position"

County Authority: Commissioner Brown countered:

• County Council controls annexation and urban boundaries at the local level
• Council has authority to reject de-annexation requests
• Question is about economic and environmental viability, not second-guessing voters

The Letter's Approach: The final letter avoided explicitly saying "Blaine voters were wrong" and instead questioned the land capacity analysis and wetlands data, suggesting the new UGA may not be viable for development.

The Commission's Deliberation: "Reject" vs. "Re-evaluate"

Initial Proposal

Commissioner Brown's original motion stated: "We recommend that the Council reject the plan unless the city of Bellingham and the city of Blaine incorporate what is called reasonable measures..."

The Pushback

Commissioner Dundes: "Why would we send the packet forward and say, you should reject it because of these things? Why wouldn't we send it forward and say, we think you need to re-evaluate Bellingham and Blaine?"

The Concern:

• Seems contradictory to approve a comprehensive plan while recommending rejection
• Better to frame as "we're good with most of it, we just want you to look at these couple items"
• Avoids appearing to "reject the thing that we've approved"

The Compromise

Final Language: Rather than "reject unless," the commission recommended the Council "require" Bellingham and Blaine to adopt reasonable measures. This approach:

• Forwards the comprehensive plan with caveats
• Flags specific concerns without wholesale rejection
• Gives County Council clear authority to act
• Focuses on legal compliance and viability

The Political Reality

Chair Button's Intervention: After the debate went back and forth between Commissioner Brown and Bellingham staff, Button stepped in:

• "I'm not sure that you and some of the planning commission members will ever come to an agreement"
• "We have the issue raised, and you've admitted you don't have the funding"
• "And I think that's where we're at"

This pragmatic acknowledgment moved the commission past the impasse and toward a formal recommendation.

Vote Results

Letter to County Council (Recommending Reasonable Measures)

• YES (5): Done, VanDalen, Brown, Barton, Chapter
• NO (2): Right, Hanson
• ABSTAIN (1): Eisenberg
• RESULT: Passed

Final Comprehensive Plan Recommendation to Council

• Motion: "The Planning Commission recommend the 2025 comprehensive plan"
• Passed with letter attached

Dissenting Perspectives

Commissioner Eisenberg (Abstained)

Voted against the final comprehensive plan for opposite reasons from Commissioner Brown:

Concerns About Undermining Growth Management:

• "We're sidestepping the real intent of the Growth Management Act, which is to do everything we can to limit rural sprawl"
• County has "adopted a realistic high population projection" but "designated a number of low income housing opportunities to what I've previously referred to as rural ghettos"
• "I don't think that's right"

Environmental Concerns:

• Opposed expanding UGAs into "inappropriate areas of agriculture and wetlands"
• Commission "modified this to provide more lenient interpretations of regulations, whereas I think we should have stuck with the consultant's language to make them more strict"
• Not strong enough on wildlife corridors and urban forest protection

Historical Concern:

• Has participated in three comprehensive plan updates
• Remembers when previous plan was appealed: "We really messed the county up having that on appeal for years and years and cost us a lot of money and opportunities"
• Hopes "the County Council can fix this so it does pass muster"
• Cannot "sign off on approval, because I don't think it really does the job"

Commissioner Hanson and Right (Voted No)

Concerns not fully detailed in transcript, but appeared to center on:

• Questioning whether commission should second-guess Bellingham's planning
• Supporting local jurisdictions' right to make their own planning decisions
• Belief that cities are "doing the best they can" to match regulations with realities

Process Context

Where This Goes Next

Immediate Steps:

• Staff will package recommendations with findings
• Must send to Commerce at least 60 days before anticipated adoption
• Gives County Council "a couple of months to digest and get through the rest of the elements"

County Council Timeline:

• Next meeting (January 27): Committee of the Whole reviewing:
  • Chapter 4: Capital Facilities
  • Chapter 5: Utilities
  • Non-municipal UGAs (Cherry Point, Birch Bay, Columbia Valley, Blaine, NOOKSACK)
• Target: Spring 2026 for final Council adoption
• Two new council members recently elected (were in audience)
• Staff conducting briefings to get new members up to speed

Legal Landscape

Futurewise Threat: Commissioner VanDalen noted: "Futurewise...mentioned future wise suing on the issues like low income housing."

Commissioner Brown's Warning: "If we approve a comp plan, knowing that there is no funding mechanism that's viable, then we are guaranteeing that Futurewise is going to sue us on that."

The Strategy: By recommending reasonable measures, the commission is attempting to preempt legal challenges by forcing cities to demonstrate viable paths to meeting GMA housing obligations.

Recent Precedents:

• Mercer Island: Forced to revise plan for proposing affordable housing without viable funding
• Kitsap County: Forced to revise for updating land without adequate housing planning
• Commerce updated guidance in January 2026 reflecting these hearings

What This Means

If County Council Adopts the Recommendation:

• Bellingham must demonstrate realistic funding mechanisms for affordable housing
• Cannot rely on theoretical $133 million annual allocation without showing how to collect it
• Must revise permitting, zoning, or other regulations to make housing more feasible
• Blaine must provide credible wetlands mitigation and cost analysis

The Bigger Picture: This represents a significant pushback from county-level planning against what commissioners see as unrealistic city-level housing plans that shift costs to county taxpayers or create unviable development proposals.

Commissioner Button's Retirement

The meeting concluded with recognition of Chair Kelvin Button's service:

Service Record:

• 10 years on Whatcom County Planning Commission
• Received certificate of appreciation and plaque
• Special recognition for his spouse for supporting his extensive commission work

Commissioner Brown's Tribute: "I would like to make a motion of appreciation for the chair, Kelvin Button, for your 10 years of honorable service. I'll say goodbye, and you're a great man."

Commissioners Departing:

• Kelvin Button (Chair) - completing term
• Julie Jefferson - did not reapply (position will be open)
• Two open positions for next business meeting in February

Commissioner Reappointed:

• Van Dalen - reappointed (no other applicants for the position)

What Changed

From Previous Discussions: The commission had multiple previous sessions reviewing the comprehensive plan, including discussions of capital facilities, utilities, and various UGAs. This was their final opportunity to make recommendations before sending the plan to County Council.

The Letter Approach: The commission decided to attach a formal letter to their recommendation rather than embedding conditions directly in the plan itself. This gives the County Council maximum flexibility to:

• Adopt the plan as-is
• Require reasonable measures from Bellingham and Blaine
• Modify specific elements
• Send portions back for revision

Evolution of Language: The commission's approach evolved from "reject unless" to "require reasonable measures" - a more constructive framing that focuses on legal compliance paths rather than outright rejection.

What Happens Next

County Council Actions:

1. Review comprehensive plan chapters sequentially
2. Consider Planning Commission's letter and recommendation
3. Decide whether to require reasonable measures from Bellingham and Blaine
4. Potentially modify UGA boundaries or requirements
5. Final adoption expected Spring 2026

City-Level Implications:

• Bellingham may need to revise housing element to show viable funding
• Blaine may need to provide detailed wetlands analysis and mitigation costs
• Both cities could face requirement to modify permitting or zoning
• Failure to comply could trigger legal challenges from groups like Futurewise

Regional Context: This decision could set precedent for how counties handle city-level comprehensive plans that propose housing solutions without demonstrated funding mechanisms - an issue facing jurisdictions across Washington State.

The Core Tension

This meeting highlighted the fundamental tension in Washington's Growth Management Act:

The State Mandate:

• Cities must plan for substantial housing growth
• Must include affordable housing for all income levels
• Must demonstrate how they will meet these obligations

The Local Reality:

• No dedicated funding source for affordable housing
• Federal subsidies are limited and competitive
• Local taxes have political and legal limits
• Building costs vary dramatically by region
• "Reasonable measures" requirement forces cities to confront this gap

The County's Position: By recommending reasonable measures, the Planning Commission is essentially saying: "We support growth and affordable housing, but we cannot endorse plans that appear financially impossible or would shift unrealistic costs to county residents."

Public Impact

For Bellingham Residents:

• No immediate $3,000 annual tax increase is actually proposed
• But affordable housing funding gap is real and unresolved
• City will need to find realistic mechanisms to meet housing goals
• Could mean denser development, modified regulations, or reduced expectations

For Blaine Residents:

• UGA expansion plans may face additional scrutiny
• Wetlands mitigation costs could impact development viability
• Previously de-annexed area unlikely to be reconsidered

For County Residents:

• Comprehensive plan will likely be adopted, but with strings attached
• Reduces risk of future legal challenges that could freeze development
• Maintains pressure on cities to demonstrate realistic planning
• Protects against unfunded mandates that shift costs to county level

Source Documents

Meeting Video: [Whatcom County Planning Commission Meeting - January 22, 2026]
Meeting Date: January 22, 2026
Transcript: Official meeting subtitles

Related Documents Referenced:

• Comprehensive Plan Update 2025 (full packet)
• Commissioner Brown's Letter (as revised) - attached to plan recommendation
• Futurewise Letter (received January 21, 2026 at 4:56 PM)
• Commerce Housing Element Guidance (updated January 2026)
• State Department of Commerce Building Cost Analysis
• Mercer Island and Kitsap County Growth Board Decisions

Next County Council Meeting: January 27, 2026 - Committee of the Whole

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