Choosing a Balanced Path: Why Whatcom County’s “Alternative 2” Is the Best 20‑Year Plan

Whatcom County faces a pivotal choice in planning for the next 20 years of growth. In the 2025 Draft Environmental Impact Statement (EIS), the county and its consultants evaluated four scenarios for updating the Comprehensive Plan: No Action Alternative (status quo growth), Alternative 1 (OFM medium growth), Alternative 2 (the Multi-Jurisdictional Resolution), and Alternative 3 (high growth). Among these, Alternative 2 – Multi-Jurisdictional Resolution emerges as the optimal path forward. This scenario chooses a moderate-high population projection (about 303,438 county residents by 2045) and allocates growth to Whatcom’s cities based on an agreement among jurisdictions. It not only accommodates the estimated growth but does so in a way that best protects the environment, aligns with Washington’s Growth Management Act (GMA) requirements, and directs infrastructure investment to strengthen the county’s social and economic foundations. In short, Alternative 2 offers a balanced growth strategy – one that minimizes environmental impacts while addressing critical housing and infrastructure needs. The choice carries urgency as planning wisely now is crucial to avoid a continued cycle of Bellingham’s housing affordability crisis, sprawl in rural areas of the county, and other long-term challenges.

What Is Alternative 2 and How Does It Differ?

Each alternative in the Draft EIS represents a different approach to growth. The No Action scenario would continue with the 2016 Comprehensive Plan and its low growth assumptions (projecting about 39,650 new residents countywide by 2045). Alternative 1 uses the state’s Office of Financial Management’s (OFM) medium population forecast (56,915 new residents) and would have the greatest allocation of population to the county's rural areas (19%) with continued growth in Whatcom’s urban growth areas (81%) split between Bellingham and the smaller cities. Alternative 2, the Multi-Jurisdictional Resolution, is distinct because it reflects a cooperative strategy – at the end of 2024 the cities and county came together to plan for medium-high growth (about 67,638 new residents countywide by 2045) in a way that all jurisdictions agree upon, this helps relieve pressure on rural areas and allows cities to proactively plan for the housing and employment they’ll need should the county see more than the medium 20-year growth estimate. Finally, Alternative 3 represents a higher growth trajectory than Alternative 2 (85,902 new residents), but still lower than the OFM’s high population projection.

After an in depth review of how the medium-high population estimate could potentially impact the individual elements within the Environmental Impact Statement such as the Earth, air quality, climate, water resources, plants, animals, land and shoreline use, housing, employment, transportation, environmental justice, cultural resources, utilities and public services, Alternative 2 proves to be the best growth strategy that protects rural lands and directs housing and employment growth to the right places. Under this scenario, 87% of new growth would be steered into the cities and their urban growth areas, with only 13% allocated to rural areas. In contrast, the other action alternatives envision a greater portion of growth happening in rural and unincorporated parts of the county. By concentrating development in urban centers like Bellingham, Alternative 2 aligns with the state’s key growth management objectives: “encourage a greater share of growth in urban areas,” “conserve designated resource lands,” and “protect critical areas to promote environmental quality”. These objectives, laid out in the Comprehensive Plan, reflect the community’s desire to channel growth into well-planned urban areas while safeguarding farms, forests, and ecologically sensitive lands. Alternative 2 embraces this philosophy more than any other option and it is literally designed to be a multi-jurisdictional resolution to manage growth responsibly across the county.

Least Environmental Impact Across All Elements

One of the most compelling reasons to favor Alternative 2 is its across-the-board environmental advantage. The Draft EIS examined a wide range of environmental elements – from land use patterns and water resources to air quality, climate resilience, and wildlife habitat. Across these elements, Alternative 2 consistently comes out on top as the most environmentally sound scenario when compared to the others. The focus on urban-centered growth means less sprawl, less impact on sensitive areas, and more sustainable development practices.

• Protecting Rural Lands and Critical Areas: Because Alternative 2 allocates the smallest share of growth to rural areas, it significantly reduces pressure to develop farmland, forests, and natural habitats. The EIS explicitly notes that “Alternative 2 has the lowest percentage of growth allocated to rural areas, so potential land use impacts in rural areas would be lower under Alternative 2 than the other action alternatives.” In practical terms, this means fewer houses scattered across unincorporated areas of the county, fewer trees cleared for housing, and less disturbance to wildlife corridors and critical areas. 

  
  

• Lower Geologic and Climate Hazard Risks: Rural parts of Whatcom County often include geologically unstable zones, areas prone to flooding, wildfires or other climate-related hazards. The EIS points out that because “areas outside of UGAs have a greater distribution of geologic hazard areas,” the lower portion of growth in rural lands under Alternative 2 means a lower potential for problems like erosion, landslide risk, or settlement in hazard-prone zones. Concentrating growth in urban areas not only improves climate adaptation and resilience, but it also helps curb vehicle miles traveled (VMT). Shorter commutes mean lower vehicle emissions – a benefit for air quality and climate. Analysts note that Alternative 2’s emphasis on urban growth would “help reduce vehicle miles traveled and associated emissions” relative to the other scenarios. Alternative 3 (the high-growth scenario) depends on rural lands to support incoming population growth and Alternative 1 doesn’t include an expansion of UGA boundaries to support growth which means growth will continue to occur in rural areas where land is more prevalent and housing is more affordable.

  
  

• Safeguarding Water Resources: A crucial example of Alternative 2’s environmental sensitivity is how it handles the Lake Whatcom watershed – the source of Bellingham’s drinking water. In this scenario, previously planned development areas in the Lake Whatcom watershed would actually be pulled back. Portions of Bellingham’s existing UGA that extend into the watershed (and other sensitive spots, like near the Airport) are removed from the UGA and placed into a “reserve” status. In other words, instead of encouraging growth in this delicate watershed, Alternative 2 does the opposite by discouraging development there. According to the Draft EIS, residential zoning in those areas would be rolled back to allow no more than one home per 10 or even 20 acres – a dramatic reduction intended to protect water quality by preventing urban-density housing from encroaching on the lake’s tributaries and shores. This move proactively shields critical natural resources. Other alternatives do not include this level of protective measure; for instance, continuing with the status quo (No Action) would leave those watershed lands developable, and the high-growth Alternative 3 would only increase pressure to build in such areas. By choosing Alternative 2, Bellingham and Whatcom County double-down on environmental stewardship, ensuring that growth does not come at the cost of clean water.

  
  

Alternative 2 selectively reconfigures UGA boundaries, removing critical areas and including appropriately designated greenfields that can support the next 20 years of housing and employment development to accommodate population growth. It directs new development to places with existing infrastructure and lower ecological value and spares the more sensitive rural and natural areas from heavy growth. This balanced approach means fewer negative impacts across all elements studied in the EIS – whether it’s cleaner air and water, safer development away from hazard-prone land, or the preservation of farmland and habitat. It’s a strategy aligned with the Growth Management Act’s core principles of concentrating growth in urban spaces while protecting the environment. The EIS essentially identifies Alternative 2 as the superior alternative because it smartly mitigates the major impacts that unchecked or poorly managed growth can create.

Smart Growth: Add the North UGA Reserve to Bellingham’s City Limits 

As touched on above, a key feature that sets Alternative 2 apart is how it expands Bellingham’s urban growth area to include the North UGA Reserve. This area north of the current city limits has long been earmarked as a reserve for future growth as the land has no agricultural value and it is not forested. Alternative 2 proposes to formally bring it into Bellingham’s UGA and plan for its development. Why does this matter? Because incorporating the North UGA Reserve fulfills a critical need: more land to support a variety of housing types affordable to all income levels as directed by House Bill 1220, not only the multifamily middle housing from infill development within the city. More so, the initial phases of housing for this area can be supported via the existing infrastructure, without reliance on further public investment in major infrastructure. As future phased development unfolds, city investments in new regional infrastructure will benefit from a more efficient and reliable cost recovery.

Under Alternative 2, the North UGA Reserve would be added to Bellingham’s UGA with a master planned neighborhood capable of accommodating roughly 1,200 new homes and about 540 new jobs. This is a significant addition to the city’s land supply. Those 1,200 housing units would include a mix of housing types – about 175 single-family homes, 830 “middle housing” units (such as townhouses, duplexes, etc.), 175 multi-family apartments or condos, plus some accessory dwelling units. In other words, it wouldn’t just be urban sprawl – it would be a thoughtfully planned community with a variety of housing to meet the diverse needs of Bellingham’s residents. By bringing this reserve area into the city, Alternative 2 ensures that Bellingham has adequate land capacity for future growth, which is a cornerstone of responsible comprehensive planning. The EIS analysis showed that if Bellingham tried to stick within its current city/UGA boundaries without expanding, it would run out of room for thousands of would-be residents and jobs by 2045. Alternative 2 solves this by opening up new land in a planned way, rather than letting growth chaotically occur in unincorporated areas of the county.

Equally important, expanding into the North UGA Reserve aligns with capital facilities planning requirements under the GMA. The Growth Management Act stipulates that cities must not only plan for growth but also ensure that infrastructure (like roads, water, sewer, schools, fire/police services, etc.) will be in place to serve that growth. In other words, land use and capital facilities planning go hand in hand. Alternative 2’s approach exemplifies this principle. Because the area is being added intentionally, the City and County can coordinate extension of urban services there before large-scale development happens. For example, the City’s Capital Facilities plan notes that if the north UGA Reserve becomes part of the city, “additional fire facilities may be necessary to serve this area upon annexation.” This is a proactive stance – planners are flagging that a new fire station or an expansion of service will be needed and can start accounting for it in budgets and plans. Similar planning will occur for roads and utilities in that area, guided by the capital facilities element of the Comprehensive Plan. By comparison, under a scenario where Bellingham does not incorporate new UGA land (say, No Action or Alternative 1), the city will end up with a housing shortfall as it has now where growth is occurring in rural and unincorporated areas of the county without the necessary city services. This kind of haphazard growth is what the GMA was designed to avoid. Alternative 2 allows Bellingham to grow within a well-defined boundary, with infrastructure scaled to support it, rather than letting growth happen unserved. It’s a far more sustainable and organized outcome.

Additionally, Alternative 2 doesn’t just stop at the North UGA Reserve. It also brings in a smaller expansion in the south (the South Yew Street UGA Reserve area) for a few hundred housing units, and, as noted earlier, it removes some environmentally problematic areas from the UGA. The net effect is a UGA boundary that makes sense: it’s shaped by both the need for housing land and the wisdom of avoiding certain locations. This strategy reflects a balanced compliance with GMA goals – providing sufficient land capacity for population and housing growth while ensuring that public facilities can keep up and that critical areas are protected. By choosing Alternative 2, Bellingham positions itself to meet state requirements and community needs simultaneously demonstrating that growth management is about planning intelligently.

Strengthening the Socioeconomic Foundation and Tackling Housing Affordability

Beyond the environmental and technical planning aspects, Alternative 2 offers substantial social and economic benefits for Bellingham. At its core, this alternative is about accommodating growth within the community, rather than pushing it outward. That has direct implications for the local economy, the job market, and the affordability of housing.

First, Alternative 2 supports robust employment growth in the city. By concentrating 87% of new population in urban areas, it similarly concentrates the vast majority of new jobs in cities like Bellingham. In fact, countywide employment under this plan is projected to reach about 144,982 by 2045, with roughly 89% of jobs located in incorporated cities and their UGAs (only 11% in rural areas). This means Bellingham would capture a large share of the 32,000+ new jobs expected, reinforcing its role as the economic hub of the county. A stronger local job base is good for residents as it provides more employment opportunities closer to home. People are more likely to both live and work in Bellingham, which has a multiplier effect: local businesses gain customers, the city’s tax revenues grow (funding services and amenities), and the overall economic vibrancy improves. By contrast, if more growth were shunted to rural areas or smaller towns (as in other alternatives), Bellingham would lose out on that economic energy. Alternative 2’s unified planning approach advocates for centralized housing and employment to support a healthy economy. 

Second, and perhaps most critical, Alternative 2 is a direct response to the housing affordability crisis that Bellingham is grappling with. The city has seen housing costs skyrocket in the past decade. There is a well-recognized shortage of affordable and available homes, which has led to soaring rents and home prices. At the end of 2024, The Muljat Group reported the average home sale price in Bellingham to be $756,000, far above what average local incomes can afford. Such trends have priced out many middle-income families and contributed to a tight rental market with low vacancy rates. Alternative 2 tackles this problem head-on by ensuring there is enough land for both housing and employment to accommodate population growth over the next 20 years. Under this scenario, tens of thousands of new housing units (about 36,000 countywide) will be built including the 1,200 in the North UGA Reserve as well as the expected middle housing infill within Bellingham as a result of House Bill 1110 which allows middle housing types in all residential zones. By diversifying housing options – from single-family homes to duplexes, four-plexes, and condos – Alternative 2 supports the city’s goal to have a variety of housing for a range of income levels and lifestyles, which is essential for affordability.

Economists and planners agree that when housing supply better matches demand, price escalation slows and housing becomes more attainable. If the county chooses a lower-growth alternative, the housing shortage will only worsen. The consequences of a housing shortage are not abstract; community analysis have warned that “failing to plan for sufficient growth could drastically exacerbate Bellingham’s housing crisis and contribute to the rising rate of homelessness in Whatcom County”, as well as push the city’s workforce to seek housing in cheaper outlying areas, fueling rural sprawl. This leads to longer commutes, more traffic congestion, more carbon emissions, and strain on infrastructure – all problems Whatcom County wants to avoid. Alternative 2 helps mitigate these issues effectively underscoring that housing and land use policy is environmental policy. 

For Bellingham, Alternative 2 can strengthen its socioeconomic foundation. More residents mean a larger tax base, bigger customer base for small and large businesses and a deeper talent pool for employers. This plan envisions development in smarter locations like increased development along high-frequency transit routes in the city – which means new housing and job centers would be well-served by public transit, reinforcing a cycle of transit use while reducing traffic congestion. In short, Alternative 2 promotes an urban form that is both sustainable and economically dynamic. It seeks to avoid the pitfalls of runaway growth, finding a middle ground where Bellingham can thrive.

Alternative 2 is the Urgent Choice for a Sustainable Future

As Bellingham charts its course for the next two decades, the stakes are high. The decisions made now – through the Comprehensive Plan update and the chosen growth alternative – will shape the Bellingham’s character, environment, and livability for a generation. Alternative 2: Multi-Jurisdictional Resolution stands out as the most prudent and forward-thinking choice. The Draft EIS analysis and capital facilities planning studies show that it is the scenario that best balances growth with environmental preservation. By focusing growth within Whatcom County’s largest city and established urban areas, Alternative 2 minimizes environmental impacts on rural landscapes and water resources. It upholds the community’s values of clean water, open space, and sustainable living. At the same time, it provides a clear path to accommodate new residents and jobs by expanding in a smart, planned way (notably through the North UGA Reserve) and by investing in the infrastructure needed to support the growth. This ensures compliance with state growth mandates (GMA) and avoids the hidden costs of unplanned sprawl.

Crucially, Alternative 2 directly addresses Bellingham’s housing and affordability crisis in a manner no other alternative does. It lays the groundwork for thousands of new homes across all income levels, aiming to make housing more attainable and to prevent displacement of the local workforce. In doing so, it also shores up the city’s economic future – supporting local businesses, creating jobs, and maintaining quality of life. The alternative scenarios, by comparison, the status quo or Alternative 1 approach might seem “easier” now but will lead to a continued housing shortage and sprawl which will overwhelm existing infrastructure and natural resources. Alternative 2 offers a middle path – a resolution built on regional cooperation, realistic forecasting, and strategic planning – which is exactly in the best interest of Whatcom County and the City of Bellingham.

The next 20 years will bring change whether we plan for it or not – and Alternative 2 is our best shot at guiding that change for the better. By adopting this balanced growth path, Whatcom County and its cities can establish a pattern of smart growth, environmental responsibility, and community vitality that we have the opportunity – and responsibility – to achieve.