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Housing Affordability Must Guide Bellingham’s Comprehensive Plan Update

Prepared by Carmichael Clark P.s., Attorneys at Law

Keys to a home hang on the wall

Part I: The State of Housing Affordability in Bellingham

Bellingham has, along with Whatcom County and its other Cities, begun the process of updating its 20-year Comprehensive Plan in accordance with Washington’s Growth Management Act (GMA).  These periodic updates take place approximately every ten years and provide the City an opportunity to strategically plan future development, capital facilities investments, and responses to important issues facing the community. Bellingham is calling its Comprehensive Plan update “The Bellingham Plan” and has organized a series of opportunities for community members to provide feedback on important topics. 

This Comprehensive Plan update is taking place against the backdrop of the housing affordability crisis that Bellingham has been grappling with for many years now. In July of 2023, the Bellingham City Council formally declared housing affordability and homelessness a public health crisis. The City’s 2023-2027 Consolidated Plan reports that 24% of homeowners and 56% of renters in Bellingham are cost burdened. Housing affordability impacts the prevalence of homelessness, the local economy, rural sprawl, the City’s budget, and more. Clearly, addressing housing affordability must be at the front and center of this Comprehensive Plan Update.

Housing Affordability Issues Are Felt Across the Economic Spectrum

At the outset, it is important to recognize that housing affordability issues impact people across all economic segments of our Bellingham community. “Affordable Housing” is generally understood as housing for which the occupant(s) pay no more than 30 percent of their gross income. Understandably, when one hears the term “affordable housing” it is often housing options for those in the lowest economic band that come immediately to mind. However, given the realities of today’s housing market, those in higher economic bands also face challenges finding housing that meets the affordability criterion.

As such, a robust and effective response to Bellingham’s housing affordability crisis must address the issue at all economic levels.  Resources for individuals experiencing homelessness, permanent supportive housing, low-income housing, “missing middle” housing, area median housing, and even higher end housing are all important components of such a response, none of which we can afford to overlook.  

The Data on Housing Affordability in Bellingham

It is vital that the response to the current housing affordability crisis developed through The Bellingham Plan be informed by the best available data on the topic. Fortunately, we have the benefit of several studies that analyze housing affordability at different economic levels. Below, we consider three studies: (1) The Whatcom County Coalition’s 2023 Point-in-Time Census of Homeless Residents (zero-to-low income), (2) The University of Washington’s Housing Affordability Indexes (low-to-moderate income), and (3) Construction Coverage’s analysis of Median-Home-Price-to-Income Ratios (median income). These studies highlight just how acute Bellingham’s housing affordability issues are.

Whatcom County Coalition to End Homelessness’s 2023 Point-in-Time Census of Homeless Residents:

While it is not specific to Bellingham, Whatcom County’s annual Point-in-Time count is the best source of data available on homelessness in Whatcom County (much of which is concentrated in Bellingham). In a previous article, we looked at the results of the 2022 Point-in-Time count and highlighted the sharp rise in individuals experiencing homelessness in recent years.

Unfortunately, the 2023 Point-in-Time Count Report shows an even sharper year-over-year rise in the number of individuals and households experiencing homelessness in our community. This year’s report saw a 27% increase in people experiencing homelessness (from 832 to 1,059 individuals) – by far the highest number reported since the counts began in 2008. The number of households experiencing homelessness saw a 33% increase (from 639 to 850 households), which was more than a 200-household increase over the previous high.

whatcom county annual homeless census 2008-2023- persons counted

This growth was driven by a dramatic increase in unsheltered homelessness, which saw a 91% increase year-over-year for individuals (from 182 to 348 individuals) and a 110% increase for households. Comparatively, sheltered homelessness saw only a 9% increase for individuals and an 8% increase for households during the same period.

comparison of sheltered and unsheltered homelessness

As noted in the Point-in-Time Count Report, these increases indicate that the “needs of the community are not being met by current and available resources for shelter, services, and affordable housing.” For more and more of those in our community in the lowest economic band, Bellingham’s housing affordability crisis means there are simply no housing options available to them.

University of Washington’s Housing Affordability Indexes:

Housing affordability issues are also being felt in the low-income and moderate-income economic bands. The University of Washington’s Center for Real Estate Research has developed two “Housing Affordability Indexes:” one that assesses the affordability of a median-priced house for a household with median income (“Median Income Buyer HAI”), and another that assesses the affordability of a house at 85% of median price to a buyer with 70% of the median income (“First-Time Buyer HAI”). These buyer profiles fall within the “Moderate” and “Low” band of Commerce’s housing income categories, respectively.

The UW model calculates an index number each quarter for (1) every Washington city with a population above 10,000, and (2) for every Washington county. A score of 100 means the household has exactly enough income to afford the housing. Scores above 100 mean the household has more than enough income, and scores below 100 indicate the household does not have enough income. These indexes provide a means of assessing housing affordability over time for two key income bands.

Bellingham’s index scores are among the very lowest in the state and have dropped considerably since Q1 of 2021. The City’s Median Buyer HAI score for Q4 2023 was just 43 (down from 72 in Q1 2021).

Washington's city housing affordability index

Bellingham’s First-Time Buyer HAI came in even lower at 34 (down from 58 in Q1 2021).

Bellingham's first-time buyer housing affordability index

These numbers are striking. If a household in Bellingham making the area median doubled their income, they would still fall well short of being able to afford a median cost home – and would-be buyers who make 70% of area median income are even worse off. Bellingham’s indexes have also dropped significantly in recent years, which indicates our community’s housing affordability issues are getting worse rather than improving. Furthermore, both of Bellingham’s indexes are among the lowest in the state.

Construction Coverage’s Analysis of Median-Home-Price-to-Income Ratios:

Construction Coverage has developed what is essentially a housing affordability score that compares local median income data to median home price data from Zillow. The study compared the price-to-income ratio for over 380 U.S. cities, so it provides a window into how Bellingham’s affordability issues compare to other cities across the nation.

Bellingham’s price-to-income ratio was 9.7 –over double the national average of 4.7. Furthermore, Bellingham’s ratio was worse than any other Washington city by a significant margin – Bellevue was the next highest with a ratio of 8.9. In fact, Bellingham’s ratio was the 31st worst in the entire country. And, if one were to remove cities in California, Bellingham’s ratio was the 3rd worst – trailing only New York, NY and Flagstaff, AZ.

construction coverage home price to income ratios

This study shows that, compared to other cities, Bellingham’s housing affordability issues are particularly severe. As we regularly hear news stories about housing affordability across Washington state and across the country, one might assume that Bellingham is merely grappling with issues that are being felt everywhere. However, while housing affordability issues are widespread, they are particularly acute in Bellingham. It’s our job as a community to learn how we can reduce the home price to income gap.

State Law Now Requires Planning for “All Economic Segments”

As housing affordability concerns increase across Washington, in 2021 the Washington Legislature amended the Growth Management Act (“GMA”) to direct local governments to “plan for and accommodate housing affordable to all economic segments of the population.” This goal, which was adopted in House Bill 1220, is now codified at RCW 36.70A.020(4). In addition, RCW 36.70A.070(2)(d) requires jurisdictions fully planning under the GMA (like Bellingham) to make “adequate provisions for existing and projected needs of all economic segments of the community” in the housing element of their comprehensive plans.

The Legislature also directed the Department of Commerce (“Commerce”) to assist jurisdictions with projecting their future housing needs by income bracket. As a result of that directive, Commerce developed methodology and an Excel tool – called the “Housing All Planning Tool” (HAPT) – which calculates the amount of housing needed for each economic segment based on projected population growth during the planning period. Anyone can access the HAPT tool to see how much housing will be needed for each economic band based on possible population levels.

Addressing Housing Affordability Requires Ensuring Adequate Housing Supply

As we have seen, (1) the impacts of housing affordability issues are felt across the economic spectrum, (2) Bellingham’s housing affordability crisis is particularly acute, and (3) Washington State law requires Bellingham to adequately provide the housing needed for each economic segment. Against this backdrop, what would a robust response to the housing affordability issues look like?

A central component of our response must ensure Bellingham adds sufficient housing supply. While there is no one factor that will single handedly reverse our housing affordability issues – utilizing a range of approaches is warranted, and we should not neglect any tool at our disposal – any response that does not adequately address housing supply will inevitably come up short.

Adding sufficient housing supply will make a positive impact on housing affordability across all economic bands. As we discussed in a previous article, Greg Colburn (a housing scholar, Assistant Professor at the University of Washington’s College of Built Environments, and co-author of the recent book Homelessness is a Housing Problem: How Structural Factors Explain US Patterns) has persuasively shown that to meaningfully address homelessness communities must add housing – a lot more housing. Adding sufficient housing supply – particularly “missing middle” housing – will also positively impact affordability across the economic spectrum.

How do we determine how much additional housing supply is needed? The first stage in that process is the adoption of population projections by Whatcom County. Once the county-wide projection is set, the growth will be allocated through a collaborative process amongst Bellingham, the other cities, and unincorporated Whatcom County.

The population ultimately allocated to Bellingham will guide the subsequent steps of the City’s comprehensive planning process, including analysis of the City’s current supply of buildable land, what investments in capital infrastructure are needed, and more. In the next installment in this series, we will look at (1) how Bellingham’s previous planning for population growth came up short, and (2) how we can avoid repeating those same mistakes in this Comprehensive Plan Update.


Housing for Bellingham is a community resource that works to inform the public about the processes and terminology associated with housing to encourage greater public input for housing and land-use planning policies.


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Contact your Bellingham City Council representative and tell them you support a proactive plan for sustainable growth.

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