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Planning for Growth in Bellingham

The Link Between Population Projections and the Ability to Add New Housing in Bellingham

Prepared by Jones Engineers, Inc.

Planning for growth in Bellingham


The City of Bellingham is experiencing a housing crisis – the median price of a single-family home is almost three times what is affordable on the City’s median household income, the number of people experiencing homelessness is at an all- time high, 56% of rental households in the City are cost burdened (spending more than 30% of their income on housing), and 22% of rental households are severely cost burdened (spending more than 50% of their income on housing). There are many different factors contributing to the housing crisis. While some of these factors are readily apparent, others are easy to overlook.

One of the oft-overlooked factors is how decisions over the past two decades to limit the City’s population projections have prevented the addition of new housing units in recent years – at a time when those new units have been desperately needed. The City’s population projections inform not only how much land must be made available for new housing, but also when the City must invest in key infrastructure. Available infrastructure capacity determines how much new housing can be timely built within the City.

Back in 2002, Bellingham adopted a 2022 population projection of 113,055 (which accounted for 54% of all growth projected to occur in Whatcom County from 2002-2022). However, on three occasions over the intervening years, the City chose to significantly reduce its population projection rather than make the required investment in infrastructure. Proponents of these reductions claimed that, instead of making a firm commitment to invest in infrastructure, the City could instead monitor the housing market and adjust its level of infrastructure commitment as needed. However, history has shown that the City is not able to adjust quickly to infrastructure needs. While the proponents’ line of thinking might seem appealing at first blush, in practice the decision to reduce the commitment to invest in infrastructure has severely limited the community’s ability to add new housing units during times – like the present – when they are needed most.

As a result, while the 2002 population projections were spot on for Whatcom County, Bellingham accommodated 9,000 people less than projected during that timeframe. This data means that while people came to Whatcom County as expected, many settled in rural areas and smaller cities that were not prepared to accommodate that growth. This history provides a key lesson to be taken into the City’s next comprehensive plan cycle: the City must take a realistic approach to population projections, plan for new infrastructure, and then not shy away from making the necessary investments. Doing so will put the City in the best position to alleviate the current housing crises and ensure adequate housing opportunities exist throughout the next planning period.

“Shortages in the supply of land available for urban development--the defining feature of an under-sized UGA -- quickly jack-up rents and land prices to levels that prohibit or discourage commercial and residential development within the UGA.”

Brent D. Lloyd (2011), Accommodating Growth or Enabling Sprawl? The Role of Comprehensive Planning Under the Washington State Growth Management Act


Amidst a backdrop of escalating housing challenges, the City of Bellingham finds itself in a reactive position for many of its current planning decisions. As a result of decisions made over the past two decades, the housing shortage in Bellingham is exacerbated by the lack of adequate infrastructure capacity for new homes. Planning needs to be proactive and strategic – most notably when it comes to infrastructure planning. A significant influence on infrastructure planning are the population projections adopted by the City.

By evaluating the historical context and the outcomes of the population projection adjustments, this research underscores the necessity for a sensible and pragmatic approach in population forecasting, comprehensive infrastructure planning, and the imperative of bold investments to effectively address Bellingham's ongoing housing crisis within the upcoming 20-year planning horizon.

Aerial photo of Bellingham's neighborhoods

Looking in the rearview mirror we can see how the population projections have affected our housing supply today. Stated reasons for choosing a lower population projection have been directly correlated with the City’s infrastructure investment (1). However, the decision for savings over the past 20 years is outweighed by the deficit in housing today. The following timeline is but one observation, one perspective of these implications. With these historical lessons in mind, we know the better option is to be prepared for population growth because it has been shown time after time it is impossible for a City to pivot fast enough when more housing is needed. If the housing supply in an area does not keep up with population growth, it can lead to a housing crisis, just as we are seeing today.

Reasonable measures to increase Bellingham’s housing supply have included adopting affordable housing incentives, reducing parking requirements, adopting accessory dwelling unit ordinances, amending Infill Toolkit standards, adopting streamlined urban village design review regulations, elimination of single-family zoning and more (2). Recently, some experts have argued that traditional land use zoning have caused the housing crisis, however, there is no substantiated evidence suggesting that the removal of single-family zoning will increase the availability of affordable housing or improve its economic feasibility (3). The Municipal Research and Services Center (MRSC) has demonstrated that in the areas studied missing middle housing has not equated to affordable housing (4).

Moreover, according to Lorelei Juntunen, the CEO of Eco Northwest, the implementation of the measures listed above will not yield immediate results; it could take several years, or even decades before significant outcomes are seen (5). Juntunen emphasized, “We are in such a large deficit right now that all of the planning and regulatory moves in the world are not going to get us out of the hole” and allocating capital funds becomes crucial to make a substantial impact in housing solutions.

If the housing supply does not adequately accommodate this increased demand, it will result in rising housing prices, decreased affordability, and a shortage of available housing options. From an economic perspective, this also discourages new industries and businesses from settling in the area, reducing local employment opportunities.

Conversely, in areas experiencing population decline or stagnant growth, the housing market may face different challenges. A decrease in population can result in an over-investment in infrastructure and a surplus of housing, leading to declining property values, high vacancy rates, and economic challenges for the local housing market and community taxpayers. However, this has not been the case in Whatcom County and Bellingham over the past 20 years.

To address these issues, it is important for local governments, policymakers, and urban planners to ensure that population projections accurately align with the expected changes in growth or decline and to develop strategies to meet the housing demand effectively. If there is expected population growth, the first step in increasing the housing supply is to plan for the infrastructure necessary to accommodate housing.

Population growth forecasts are not to be used to either encourage or discourage growth. Rather the law requires that the forecast used for planning purposes represent the “most likely to occur” scenario.

– 2006 Bellingham Comprehensive Plan, Land Use Chapter (LU-10)

Growth Expectations in 2002

In this report, the story of Bellingham’s current housing crisis will be traced back to the year 2002 during City Council deliberations on a plan to accommodate the incoming population growth, commonly called a Comprehensive Plan.

2022 Bellingham and Whatcom County population

The Washington State Growth Management Act requires cities and counties to adopt comprehensive plans and set urban growth boundaries to accommodate the projected population, housing, and job growth.

The population growth projections must be within the range the State Office of Financial Management (OFM) provides. Growth forecasts help communities to plan for land use, transportation, utility infrastructure, environmental protection, neighborhood character, school capacity, parks, open space, and affordable housing to meet the needs of the projected population. The Growth Management Act (GMA) also requires that each jurisdiction has enough developable land to accommodate the 20-year projected population growth. Following the direction of the GMA, Bellingham City Council conferred over population projections through the year 2022 which was adopted in Bellingham City Resolution 2003-39: A Resolution Adopting a 20-Year Population Growth Forecast for the Greater Bellingham Area.

“Population and employment growth are fundamental considerations in making long-range planning decisions. All key planning decisions – including those involving public facilities and services, allowable residential densities, land for commercial and industrial development, park and roadway designs – are based on the number of people that must be accommodated during the planning period.”

– Resolution # 2003-39

Within this resolution, Bellingham City Council members adopted a 20-year Population cycle through 2022 projecting the population growth to be a total of 231,928 in Whatcom County and 113,055 in Bellingham.

2002's 2022 population projections for Bellingham and Whatcom County

At this time, Bellingham was expected to accommodate 54% of Whatcom County's population growth through 2022 (31,600 of 58,457 total county growth). Two years later, in 2004 Whatcom County’s Ordinance # 2004-013: Amending Chapter 1 of the Whatcom County Comprehensive Plan Including Population Projections bumped up the 20-year projection for Whatcom County. To “avoid tightening urban land supply” and for land use and facility planning purposes (6), the 2022 County projection was set at 234,917. Interestingly, Bellingham’s 2022 projection stayed the same (31,600 of 61,450 total growth). The public became concerned with decisions surrounding land use planning during this time and from this was the birth of the Community Growth Forums.

2004's 2022 Population projections for Bellingham and Whatcom County

This was established as a public gathering where growth management issues could be addressed. These were some of the most well-attended public land use forums in Bellingham’s history with a turnout of up to 100 individuals in any given meeting. This body made policy recommendations focused on building community and encouraging civic wellness.

“The quality of life in Whatcom County is expected to fuel growth in the future, and ensuring an adequate land supply to accommodate this growth, the need to plan for growth and the need to protect the quality of life and natural resources in Whatcom County. This population projection is selected for planning purposes only and does not obligate the County to encourage growth. Given past population trends and the requirements of GMA, planning for population growth, whether it occurs or not, is critical for the quality of life, protection of natural resources, and economic health of Whatcom County.”

– Ordinance # 2004-013 (1-9)

One growth management recommendation embraced at the Community Growth Forums and with the City of Bellingham was an urban village strategy.

This proposed new development, redevelopment and densification within specific nodes throughout the city (figure 1).

Bellingham's Urban Villages
Figure 1. Bellingham urban village strategy.

These urban villages support the combination of mixed residential and commercial neighborhoods to promote walkability. Also included in the City’s plan to accommodate growth was to bring in additional lands to the urban growth area (UGA) boundaries. This would provide new opportunities for neighborhood master planning and densification (figure 2). Some areas within the UGA were proposed for removal, such as Dewey Valley, because the majority of residents shared a strong disinterest in annexation into the city. Other reasons for removal have to do with land suitability and the available housing capacity in the area (see Appendix A). Some of the land within Bellingham’s UGA has many protected critical areas and cannot provide the additional housing needed. Once removed, these areas were to be replaced with land from the UGA Reserves, (previously referred to as Five- and Ten-year review areas). The fiscal impacts of updating these plans for growth management were carefully evaluated and documented. It was well-known and agreed among stakeholders in the Community Growth Forums that the City of Bellingham Capital Improvement Plans would be updated to reflect the necessary system upgrades.

“The city staff and Planning Commission have maintained a firm grasp on reality in this process and the need to aggressively find truly achievable and balanced solutions in a timely and responsible manner.”

– Bill Quern, Executive Officer of Building Industry Association, 2006

Map of Bellingham's growth management strategy
Figure 2. Bellingham Urban Village areas, UGA & UGA Reserve Areas.

Buildable Land Shortage

In 2005, the Bellingham Business Journal reported on the shortage of buildable land and the concerns associated with incoming population to Whatcom County and the fear of sprawling development. To prevent urban sprawl, one solution lies in vertical growth, but it was known nearly 20 years ago that infill methods alone would not be enough to solve the projected population boom. There is a limit to how high structures can be built.

2006's 2022 population projections for Bellingham and Whatcom County

The Bellingham Planning Director at the time, Jorge Vega, stated “Given that restriction, and concerns that our neighborhoods want to maintain character – which is a very critical component of our Comprehensive Plan – it’s very important we look at what are our real land-supply capabilities, what we can do realistically from an infill capacity.” The Bellingham Business Journal highlighted that due to the limited amount of available land within the city's boundaries and in the Urban Growth Area, it is probable that the city will require annexing additional land.

"We’re in the situation where we really don’t have enough land, that’s why we’re looking at areas that would be appropriate to add, so we can add to the land supply.”

– Greg Aucutt, City Planner, 2005

It was inherently clear to Bellingham's City Council that there was not enough buildable land to accommodate the expected growth and the Council documented this in the Comprehensive Plan. To address the shortage of land and necessity to increase our housing supply, Bellingham City Council approved Resolution 2006-15: A Resolution Recommending Amendments to the Whatcom County Urban Fringe Subarea Plan (UFS Plan) and Bellingham’s Urban Growth Area (UGA), Consolidating the City’s Urban Growth Areas into One County Planning Subarea, Adding Land to the City’s Urban Growth Area in the North, and Revising Zoning in Some Areas of the UGA Consistent with the Growth Management Act, Whatcom County Comprehensive Plan, County-wide Planning Policies, and Bellingham’s 2006 Comprehensive Plan.

Within this UGA resolution, the 2022 population projection again remained the same as adopted in 2004. It was clearly identified in the 2006 Bellingham Comprehensive Plan if the urban growth area did not expand to meet growth projections, it would lead to higher housing costs and encourage sprawl into rural areas. The housing crisis we are in today was anticipated by Bellingham City staff 20 years ago.

“The disadvantages of a too-small urban growth area can be a disproportionate increase in the value of land within the area, thereby contributing to higher housing costs and encouraging development in rural and other less appropriate areas of Whatcom County.”

2006 Bellingham Comprehensive Plan, Land Use Chapter (LU-24)

Within Resolution 2006-15 it reads, “the adopted forecast means the Bellingham urban area is required to plan to accommodate over 50% of the total county growth over the next 20-years (31,600 of 61,500); and … the city and county are required to provide enough developable land to accommodate the projected growth for the area; and… adjustments to the City’s UGA boundaries are being considered because projected growth cannot be accommodated inside Bellingham and the Urban Growth Area” (p. 1-2). Furthermore, there were specific areas listed in this resolution that were analyzed for annexation suitability.

With annexation comes the need for new infrastructure. The Urban Growth Area Guidebook states, “there are urban services required to be available when urban growth and urban densities are permitted to occur in UGAs. These services typically include public sewer, public water, transportation, and stormwater. As UGAs develop and as population numbers reach levels that can pay for additional urban services (e.g. police and fire, libraries, schools, parks) then a full set of urban services can be achieved for UGAs. These are the types of urban services that need to be documented in the Capital Facilities Plan” (7).

Simply put, a [Capital Facilities Plan] is an inventory of what you currently have for urban services, what you will need to support your 20-year land use plan and UGA, what it costs to provide these services, and where the money will come from. The CFP analysis is in reality, a budget exercise, and one that local governments should perform with their rolling 6-year CIP – together with their annual budget cycle.”

– Infrastructure Assistance Coordinating Council (IACC), 2011

The City of Bellingham updated the 6-year Capital Facilities Plan in the 2006 Comprehensive Plan to reflect the urban services needed, such as water reservoirs, and dedicated funds (8). to develop the necessary infrastructure to accommodate the expected population. Plans to add land to Bellingham were well underway to ensure the City would have enough land to build the appropriate amount of housing for the next 20 years.

Employment Lands

While development projects were set to begin in Blaine, Birch Bay, Ferndale, and other smaller cities in the coming years, planners forecasted that most incoming residents and job opportunities within Whatcom County would be concentrated in Bellingham.

Bellingham City Planner, Greg Aucutt expressed concerns in 2006 stating, “If we’re not successful in increasing the supply of residential land (in the city), we’re afraid a lot of the people who are going to move here anyway will move out into the rural areas of the county. That would be a problem because Bellingham has 65 to 70 percent of the county’s total jobs so even if people live all over the place they’re still going to be driving into town in the morning and driving out at night. There are lots of examples of cities that have let that happen, and their transportation systems are a nightmare.” Aucutt stressed, “it can take years to get from raw land to the point where someone can build a house on a lot…” (9).

In 2008, The City of Bellingham produced the 2008 Employment Lands report as an overview of Bellingham’s industry sectors, employment zones, and future employment capacity. The analysis of this report shows after the deduction of critical areas (nearly 50% of employment lands) there was a total of 1,000 net developable acres. Of this land, the Alderwood and Northwest Drive areas contain about 520 developable acres and the West Bakerview/Meridian/Cordata area contains about 207 developable acres. Whatcom County contracted with a private consultant, Berk & Associates (BERK) to develop low, medium, and high forecasts for employment growth as part of the 10-year UGA update process. Whatcom County adopted the consultant’s estimate for the City of Bellingham and the Bellingham UGA of 18,829 new jobs by 2029 (10). The City of Bellingham maintained a medium-high employment allocation while later decreasing the population allocation.

2036 high, mid and low employment allocations for Bellingham and Whatcom County

This is the exact concern raised by Greg Aucutt. Lower population allocations result in less housing in Bellingham which forces people out into the rural areas, thereby creating the perfect recipe for sprawl.

Population Allocations

In 2009, after three years of deliberation and significant pressure from interest groups following the Bellingham City Council’s actions, Whatcom County Council adopted Ordinance 2009-071: Ordinance Amending Whatcom County Zoning Code Title 20, The Official Whatcom County Zoning Map, and the Whatcom County Comprehensive Plan and Maps, to Implement Changes Relating to Completion of the 10 Year Review of the Urban Growth Areas Required Under the Growth Management Act. This ordinance accepted certain urban growth area recommendations from the City and rejected others.

“In the 2002 Comprehensive Plan, Bellingham was allocated the greatest share of population. Rural areas were slated to take the least share of growth, but have seen substantially more growth than was intended…”

– Ordinance 2009-071 (p. 10)

Whatcom County Projection from 2009 to 2029

In 2009, the County Council tasked the Growth Management Coordinating Council (GMCC) to make recommendations to Council for population projection and allocations for the year 2031. Additionally, BERK, was hired to assist in this population projection update process. One of the strategies promoted by the Growth Management Coordinating Council was to reallocate population densities from unincorporated rural areas and to allocate them to the smaller cities, such as Blaine, to help them become more independent. Additionally, Futurewise Whatcom offered their input into the process as well, arguing for lowering population projections.

The County Executive proposal was based on having small cities become more self-sufficient. This should allow more efficient delivery of public services and facilities and reduce commuter traffic into Bellingham. Growth allocated to areas outside UGAs should not exceed 15% of total population growth.

Ordinance 2009-071, Findings of Fact (p. 13)

The GMCC originally recommended a countywide population projection of 253,951 for the year 2031. Berk & Associates recommended a 2029 countywide projection of 251,490. Futurewise recommended a projection of 220,000 (see Appendix B). Whatcom County Council ultimately adopted a 2029 population projection of 246,602, much lower than the recommendations from the Growth Management Coordinating Council and the professional consultant, Berk & Associates.

This lowered projection was largely influenced by testimony from special interest groups and associated experts provided to City and Planning Commissions and Councils in 2009. This testimony included letters written with the primary goal to “protect working farms, forests, and other rural areas from sprawling development”. An additional concern was that the City may over invest in infrastructure if population projections were too high. Futurewise Whatcom wrote urging the Bellingham Planning Commission to recommend the Bellingham Mayor and City Council ask the Whatcom County Council to adopt the lowest population projection for year 2031 of around 220,000 people and a year 2031 allocation for Bellingham of about 110,000 people or less. As you may recall, in the year 2022, Bellingham and its UGAs have a combined population of 104,016.

Population projections recommendations

Low-growth advocates stated within these letters:

Planning for a high population growth commits the county and its municipalities to provide an unaffordable level of government services and infrastructure."

By committing itself to a larger population number, Whatcom County will also be committing itself to build and pay for significantly more infrastructure and government services. This includes roads, bridges, stormwater, and flood control measures, as well as fire, police, emergency, and public health services” (p. 59).

Low-growth advocates argued that a lower population projection would facilitate infill into the urban areas, limit sprawl, provide agricultural preservation and conserve open space in rural areas. Others argued that a lower population projection would result in less infrastructure investment in the city and encourage sprawl because there would not be enough buildable land within Bellingham. People are searching for land to build homes and are forced into rural areas because options are limited within city limits.

Lowering population projections can reduce the perceived need for infrastructure investments but can also reduce the potential to receive government grant funding for capital infrastructure. The projects listed in the Capital Improvement Plan (CIP) should be identified as proactive planning. Without a plan for future infrastructure investment, our elected officials are missing the opportunity for the City and County to qualify for grant funding (12).

2009's 2029 population projections for Bellingham and Whatcom County

Over the past 20 years, deliberations on Comprehensive Plan updates have included testimony that the City can use lower projections, then track and monitor the housing market and make adjustments to the plans, if necessary. However, the market moves much faster than the City and County Councils can react. A healthy economy needs clarity, consistency, and certainty. A plan to “change plans” does not create a healthy economy.

Bellingham Projection from 2009 to 2029

In 2009, a portion of the existing City of Bellingham Urban Growth Area was removed. This seemingly minor adjustment reduced Bellingham’s responsibility to create housing for 4,441 people.

In response to the UGA adjustment, Whatcom County requested Bellingham develop a proposal on how they would accommodate the people who were removed urban growth area. This proposal was to include infill, changes to land use densities, or reconfiguration of the urban growth area.

The City of Bellingham accepted the request to plan for a population allocation of 116,200 for 2029. However, rather than include the 4,441 people within the City of Bellingham, calculations in the 2009 Whatcom County Comprehensive Plan show these people were instead subtracted from the total Bellingham population allocation of 116,200 (p. 19). The new 2029 assigned population allocation for Bellingham was 111,761 (p. 53).

Coincidently, in 2014 the City of Blaine adopted a population projection based on the Blaine’s multi-jurisdictional Resolution 1639-14. This resolution allocated a growth of 4,414 people to Blaine by 2036 – an 85.3% increase (13). To put this increase into perspective, Blaine’s population trends over previous decades from 1950 to 2010 had averaged a 19.5% growth (Resolution 1639-14, Table 1.1). The unusual excessive surplus of population allocation to Blaine and similarly Birch Bay came directly from Bellingham rather than the unincorporated, rural areas of Whatcom County as it was intended. It can also be argued the City of Blaine has been used as a bedroom community for Canadian commuters (14).

Population and housing that is shifted from Bellingham to Blaine does not positively influence the economic health nor the housing crisis we are experiencing in Bellingham. This shift has put severe pressure on the City of Blaine.

Blaine and Birch Bay did not have the appropriate infrastructure planned to accommodate the new population that was allocated to them. To this day, these homes have yet to be created. Blaine still has incomplete infrastructure and Birch Bay has many critical wetlands that must be avoided. This population density was misallocated and has left many families without the opportunity to find homes. If the population allocation was left in Bellingham, the City would have been able to appropriately plan for infrastructure as necessary.

In 2009, the total Bellingham population growth forecast was reduced from 31,600 (51.4%) to 22,500 (40%). The 2009 forecast recommended by Bellingham staff and adopted by the County was much lower than historic trends. This was due in part to the small cities’ desire to increase their share of total population, however, the smaller cities were not prepared with capital infrastructure and facility plans or funding to take on this increase in population allocation. Consequently, this has resulted in housing displacement and increased sprawl in rural Whatcom County.

Figure 3. Bellingham population allocation shifted to Blaine and Birch Bay.
Figure 3. Bellingham population allocation shifted to Blaine and Birch Bay.

In 2009 and 2010 several parties filed petitions to the Growth Management Hearings Board to review the findings of Whatcom County Ordinance 2009-071. Subsequently, in 2010 the Whatcom County Council hosted a series of public meetings, including public testimony to discuss the various petitions. As a result of these meeting the County Council adopted Resolution 2010-014: Resolution Requesting the Executive to Have Proposed Legislation Prepared Amending the Comprehensive Plan, Zoning Code and Maps to Alter the Designations of Various Urban Growth Areas. This resolution established there was adequate interest on the part of the Whatcom County Council to consider the following changes to the County’s UGAs which directly affected the City of Bellingham.

However, after further deliberations and testimony the Whatcom County Council ultimately did not approve these proposed changes to the UGA.

Preparing for the 2016 Bellingham Comprehensive Plan

In 2013, Whatcom County and the cities engaged Berk & Associates to prepare 2036 population and employment projections and UGA allocations in anticipation of the 2016 Comprehensive Plan update. BERK prepared Phase I of their technical report for the Whatcom County Department of Planning and Development Services titled Whatcom County Population and Employment Projections and Urban Growth Area Allocations. In accordance with the Growth Management Act, it is necessary for Whatcom County to establish a 20-year projection of population and employment and then distribute this growth to the UGAs and areas outside the UGAs. For this Comprehensive Plan update cycle, we are now looking to the year 2036 for population projections. BERK lists low, medium, and high population allocations for 2013-2036 (see Table 2).

In Bellingham Resolution 2014-11: Non-binding Multi-jurisdictional Resolution Regarding Population and Employment Allocations, (Also referred to as Whatcom County Resolution 2014-013) the County and the City agree to use the 2036 high population growth allocation for the Bellingham Comprehensive Plan (a growth of 35,918 people). This growth is added to the 2013 Bellingham population of 93,107 to give Bellingham’s total population allocation for 2036.

Planning Commissions Call for More Land

In June 2015, the Bellingham Planning Commission made a recommendation that the South Caitac and South Yew Street properties are needed to accommodate the recommended population growth allocation and should be added to the City’s UGA.

2015's 2036 population projections for Bellingham and Whatcom County

“The existing city and the UGA do not contain sufficient capacity to accommodate the recommended population growth forecast of 35,918. Both the Caitac area and the South Yew Street area abutting the current city limits and would add enough capacity to accommodate the recommended population growth forecast” (p. 6).

“Placing the S. Caitac and S. Yew Street Properties in the UGA now will allow the City and the property owners time to develop a plan to serve the area, including a method to address the capital and operational costs associated with providing the full range of urban services.”

– Bellingham Planning Commission Findings of Fact, 2036 Population Growth Forecasts and UGA Boundary Review (2015)

Additionally, the Whatcom County Planning Commission recommended using the BERK high 2036 projection for Bellingham to allow more people to live near work, thereby decreasing impacts to the transportation system and the environment.

“In order to accommodate the Bellingham UGA population allocation of 35,918 more people, and provide additional land capacity for single family housing closer to a major employment center, the Whatcom County Planning Commission recommends adding the South Yew Street area… and the South Caitac area… to the Bellingham UGA.”

– County Planning Commission Findings, 2016 Comp Plan Update/UGA Review (2016)

Commitments Unfulfilled

Following the Population Projections and Land Capacity Analysis the City evaluated the potential capital infrastructure and service needs associated with the UGAs. As a result, the City of Bellingham passed a resolution which reduced their previous population commitment. In Resolution 2015-14: A Resolution Regarding the Update to Bellingham’s Comprehensive Plan, Providing Recommendations to Whatcom County Regarding Population and Employment Growth Allocations and Potential Changes to the City’s Urban Growth Boundary.

The results of the Land Capacity Analysis showed that the current land supply in the City and UGA could accommodate about 32,900 of the projected 35,900 additional residents. In order to address the 3,000-person shortfall in capacity, areas that could potentially be added to the City's urban growth boundary were evaluated.

Following this review, Bellingham City Staff made a new recommendation to City Council. Rather than plan for the necessary capital facilities to accommodate the adopted population projection for 2036 as the Planning Commission recommended, Bellingham City staff recommended reducing the population projection in order to avoid planning for the cost of capital improvements.

“[T]he City’s resources are limited, and the ability to afford facilities and services that the forecasted population and employment growth will require is critical…

The mid-range forecast … should be the final population growth allocation used to update the Bellingham Comprehensive Plan.

Use of the mid-range population growth forecast and the high-range employment growth forecast means that no changes to the City’s urban growth boundary are needed or recommended at this time.”

– City of Bellingham, Resolution 2015-14

2013's 2036 population projections for Bellingham and Whatcom County
Table 2: BERK 2013-2036 population forecasts for Whatcom County and Bellingham.

During the summer of 2015, City of Bellingham Planning Commission voted unanimously in support of the “Multi-Jurisdictional Resolution”. However, on August 31, 2015, the City Council did not adopt the City Planning Commission recommendation, with a close vote (3-4). During the hearing, three City Council members voiced passionate, strong opinions in support of the Planning Commission’s recommendation. Again, the Council was assured that the City would monitor the housing market and make adjustments to the UGA as necessary. It was argued in the hearings that the pending “Annexation Phasing Plan” would identify the necessary UGA revisions and evaluate the associated capital facilities and service requirements associated with UGA revisions. Staff reassured the Council that adjustments to the plan would be made as necessary, based on the market conditions.

In August 2015, Bellingham City Council approved the new population growth allocation used to update the Comprehensive Plan to be 28,398, or a total 2036 projection of 121,505. This is the medium allocation from the 2013 Berk & Associates report - Whatcom County Population and Employment Projections and Urban Growth Area Allocations – Phase I Technical Report. This reduced Bellingham’s allocation by 2,652 people. This seemingly small alteration removed the need to include either the South Yew Street UGA or North Cordata/ Caitac Area to be included in Bellingham’s Urban Growth Area. This relinquished the City of Bellingham from the responsibility of funding the capital improvement costs as discussed in Resolution 2015-14.

To reiterate, a population projection is a prediction of what is expected to occur in the future. It is not a target that should be adjusted based on the costs associated with the prediction.

August 2015's 2036 population projections for Bellingham and Whatcom County

The implications of selecting a number that turns out to be too low may result in a significant lag between when capital facilities and public services are needed and when the City can provide them. Public capital projects such as road improvements, fire stations, and new parks take years to fund and complete. Hiring and training additional City staff such as police officers and firefighters takes time and resources. Playing catch-up with capital facilities and services is not an advantageous position to be in.

“The Whatcom County Planning Commission finds that Bellingham’s recommendations for the medium population allocation coupled with the high employment allocation will cause more people, who cannot find single family housing in their price range in Bellingham, to live in the small cities, unincorporated UGAs , and rural areas while commuting to Bellingham for work.”

– County Planning Commission Findings, 2016 Comp Plan Update/UGA Review (2016)

Infrastructure is Limited

Over the past 20 years, the City of Bellingham failed to accommodate over 9,000 people as was anticipated by the City Council. These growth projections were adopted in 2003 and again in 2006. In Ordinance 2006-06-058, Bellingham City Council adopted the 2006 Bellingham Comprehensive Plan (15) which encompassed all the major recommendations from the Community Growth Forums. The 2022 population projection used in this plan for Bellingham remained at 31,600 from Ordinance 2004-013.

By 2022, we have now seen the population projection for Whatcom County from 20 years ago was spot on. The City of Bellingham population total, however, has been constrained and does not meet its share of the projected population from 2002. Bellingham’s population in 2022 was 104,016 which equates to an increase of 22,562 people.

Actual 2022 population of Bellingham and Whatcom County

Based on this data, Bellingham only accommodated about 38.7% of the countywide growth between 2002 and 2022 (22,562 of 58,179 total growth). As we recall from Resolution 2003-39, it was expected that Bellingham would accommodate 54% of the total countywide growth. Additionally, in accordance with the Growth Management Act, it is required that each jurisdiction(city) have enough developable land to accommodate the 20-year projected population growth. The City of Bellingham limited the development of new infrastructure by reducing Bellingham’s growth projections, and population growth was reallocated to the smaller cities and into the rural counties.

“The current residential supply in the City and the UGA does not contain sufficient capacity to accommodate the forecasted demand for housing

over the 20-year planning period.”

- 2006 Bellingham Comprehensive Plan, Land Use Chapter (LU-18)

The Next Steps: 2025 Comprehensive Plan

The situation we are in now is the demand for affordable homes far outnumbers the supply. Frequently cited as a factor of our housing shortage is the Great Recession of 2008. During this time housing permits in Bellingham fell significantly16 and since then, it has been an uphill journey to recover from this dip in production. Although, if this housing recession had not happened, would Bellingham have the necessary capital infrastructure to accommodate the homes that would have otherwise been built during this time? The Great Recession only slowed the inevitable. Bellingham would have been faced with the effects of our housing crisis years sooner if production stayed on course with previous years (see figure 4). This experience shows the critical means of adopting a population projection that is too low for a region’s potential.

Director of Planning and Community Development, Blake Lyon, poses the questions: “Does that historic trend mean that we’re continuing to sprawl too much? Are we putting too much pressure on the smaller communities in this county or the rural lands of this county? Should [Bellingham] be absorbing more of that in an urban infill fashion?”17. We have seen arguments for a lower population projection to avoid investment in capital infrastructure. We now have a unique opportunity to look at the outcome of Whatcom County and Bellingham’s population statistics over the past 20 years. It comes as no surprise Bellingham has a significant housing deficit to make up.

In 2002 the Countywide population was 173,471. The projection for 2022 was 231,928. In 2022 the Countywide population is 231,650. The total County Growth from 2002-2022 is 58,179 people.

In 2002 the Bellingham City + UGA population was 81,454. The projection for 2022 was 113,055. In 2022 the Bellingham City + UGA population is 104,016 (OFM Estimate April 1, 2022 and OFM SAEP Estimate). The total Bellingham City Growth from 2002-2022 is 22,562 people. Based on this data Bellingham has accommodated about 38.7% of the countywide growth between 2002 and 2022, whereas in Resolution 2003-39, Bellingham was expected to plan for 54% of the total countywide growth.

Figure 4. Bellingham housing permits from 2000 through 2022 provided by the City of Bellingham.
Figure 4. Bellingham housing permits from 2000 through 2022 provided by the City of Bellingham.

To make up for this 15% deficit in population growth allocation, it is urgent Bellingham make some significant decisions. Following the 2022 Whatcom County Buildable Lands Report it is clear Bellingham has a shortage of buildable land for new homes. Of course, there is not one singular solution, it is going to take a comprehensive plan that integrates appropriate reasonable measures including infill strategies in our urban core and greenfield strategies as presented in the Whatcom County Buildable Lands Report.

Reasonable measures in Bellingham are warranted. These measures could include but are not limited to:

· “Updating annexation plans and coordinating with Whatcom County to evaluate and adjust future City zoning in the unincorporated UGA and UGA Reserves to support expanding housing opportunities.

· Investment in capital facilities, giving priority to capital facility investments that support production of housing;” (18)

City Councilman Michael Lilliquist has stated City Council adopts a predictive expectation of population growth, what they think may happen. “Our job is to make sure we have public infrastructure available when [population] grows as we expect it to grow. Now, we have an additional obligation [to ensure] there is enough housing at all income levels – that is a target. But again, our goal is not actually to see population growth. Our goal is to see infrastructure growth and housing growth.” (19).

“Smart Growth involves prudent annexation, and also appropriate infill and upzones in areas suitable for urbanization and higher density.”

-Councilman Michael Lilliquist, 2021

In reflection, the housing crisis gripping the City of Bellingham is a multifaceted challenge with far-reaching implications for our residents. The exorbitant median home prices, soaring homelessness rates, and the strain placed on rental households underscore the urgency of addressing this crisis comprehensively. While various factors contribute to the housing dilemma, one often underestimated aspect is the impact of population projections on housing development. Over the past two decades, decisions to curtail population projections have hindered the creation of much-needed housing units, exacerbating the city's predicament. The history of recalibrating projections in lieu of immediate infrastructure investments has unveiled the limitations of this approach. By adopting a pragmatic perspective on population projections, strategically planning for new infrastructure, and committing to necessary investment strategies, the city can aptly address the present housing crisis and foster a variety of housing opportunities through the next planning phase. Learning from this history, the upcoming comprehensive plan cycle presents an opportunity for the city to take proactive measures, ensuring that adequate housing opportunities materialize to meet the community's needs in the years ahead.


1 City of Bellingham, Agenda Bill No 18354, p. 59.

2 Whatcom County Buildable Lands Report, Bellingham UGA, p. 31

3 Lane Kendig (2020) Eliminating Existing Single-Family Zoning Is a Mistake, Journal of the American Planning Association, 86:1, 124-125, DOI: 10.1080/01944363.2019.1689016

4 Butler, Steve (2022) Infill Housing Approaches: Targeting the Missing Middle and Accessory Dwellings, MRSC.

5 Ehrlich, April. “Oregon has an extreme housing shortage. Here’s what could be done.” Oregon Public Broadcasting, Accessed 16 August 2023.

6 Ordinance 2004-013, p. 1.10

7 Washington State Department of Commerce Urban Growth Area Guidebook, 2012, p. 16.

8 The 2006 Bellingham Comprehensive Plan dedicated 4 million dollars to the King Mountain Reservoir to serve the North Bellingham area. (CF-86)


10 City of Bellingham 2008 Employment Lands Report forecasts to the year 2029 while the BERK report forecasts to the year 2036

11 The City of Bellingham was planning to accommodate 116,200 by 2029. However, 4,441 people were removed from Bellingham’s population allocation when the Yew Street UGA was removed. Subsequently, Bellingham’s 2029 population allocation is listed as 111,761 in the Whatcom County Comprehensive Plan

12 Growth Management Grants.

13 Population Projections found in Blaine Resolution 1639-14 (p. 2). Blaine 2013 population: 5,177. 2036 Growth Allocation: 4,414. 2036 Population: 9,591. % Change (2013-2036): 85.3%

14 First phase of this 992-unit housing community moves forward in Whatcom. “The project is designed to attract local retirees, young families and Canadian commuters, according to the project website.”

15 These comprehensive plans are intended to be used as a guide for the physical, economic, and social development of a city or county for a 20-year period



18 Whatcom County Buildable Lands Report, Bellingham UGA Jurisdiction Profile, p. 34

19 Bellingham Committee of the Whole session, June 5, 2023.

Appendix A

Appendix B: Futurewise Whatcom Letter to Bellingham Planning Commission



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

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