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Whatcom County’s 2022 First Buildable Lands Report Falls Short



The Importance of a Buildable Lands Report


As a designated fast-growing area, Washington’s Growth Management Act (GMA) requires Whatcom County to fully plan for growth to accommodate the increasing population. Land use and development are critical components of planning. As such, Whatcom County is expected to produce a Buildable Lands Report (BLR), a report card if you will, that assesses how “recent development in Whatcom’s cities and urban growth areas (UGAs) are meeting the planning assumptions, targets and objectives” for housing as set forth in the 2016 Comprehensive Plan to accommodate the projected population and employment increases through 2036.


Some may not realize that the data from the Buildable Lands Report will be used to set the framework for Whatcom County’s 2025 Comprehensive Plan. According to the MSRC, “A comprehensive plan articulates a series of goals, objectives, policies, actions, and standards that are intended to guide the day-to-day decisions of elected officials and local government staff.” Thus, it’s critical for this report to provide an accurate picture to give policymakers an opportunity to address and correct the current issues of housing availability, affordability, and variety, specifically within the City of Bellingham where we’re faced with a housing crisis.


Unpacking Whatcom County’s Buildable Lands Report


Released for public review on July 7th, 2022, the 144-page Buildable Lands Report assesses the development activity that occurred from 2016 to 2021 and also determines whether there is sufficient land to house the growing population for the next 14 years.


The report concludes, “on a county-wide basis surplus capacity exists to accommodate the projected population and employment growth through 2036.”


Specifically, the City of Bellingham’s profile resolves it has sufficient surplus capacity to accommodate the projected population and employment growth through 2036.


This has many people in the community scratching their heads as to how there can be a surplus of buildable land in the Bellingham area when we’re now four years into a housing crisis. Further, because the report indicates the County is on track to meet our goals for 2036, it does not include reasonable measures to help course correct the current state of housing availability and affordability in the City of Bellingham. In fact, according to the report:


“The City of Bellingham has not identified any inconsistencies between growth and the [2016] Comp plan. Therefore, the City has not identified any ‘reasonable measures’, but does acknowledge that housing affordability is a critical issue that is driving Bellingham’s work program.”


Reasonable measures are steps that must be taken by a city or county when there are inconsistencies between growth and development. When a Buildable Lands Report identifies reasonable measures, it assigns accountability for mitigating and addressing these inconsistencies in the next planning cycle. According to the Buildable Lands Guidelines, a few considerations for reasonable measures include:


● Planned urban densities are not being achieved

● Insufficient capacity

● Growth targets or projections are not being met


Bellingham’s housing crisis is complex, but the root of the issue is fairly straightforward: There is not enough supply to meet the demand.


Back in April of 2019, the Whatcom County Business and Commerce Advisory Committee sent a letter to both City and the County officials sounding the alarm about the lack of affordable housing for working wage residents, who are the backbone of Whatcom’s local economy. The letter called for government officials to treat the lack of affordable housing as a crisis, recommending the following solutions to help mitigate the housing problem:

  1. Replace current zoning rules, codes, and procedures with a Temporary Housing Crisis Plan

  2. Provide infrastructure and resources to increase housing availability

  3. Reduce government fees for housing

  4. Provide incentives for hitting affordable housing and workforce targets

  5. Annex additional outlying areas

While County and City officials have worked to reduce zoning barriers and provide density bonus incentives, Bellingham’s housing crisis is worse than ever, with home prices running far above the means of most local families. According to the City’s website, there are an estimated 742 people without housing on any given night.


This begs the question, if there’s a surplus of buildable land across Whatcom County and in the City of Bellingham, why is there a housing crisis? Simply put, there is not sufficient land capacity to accommodate the population growth needs in Bellingham, therefore, reasonable measures should be included in the 2022 BLR to address the capacity shortfall.



The Shortcomings of Whatcom County’s First Buildable Lands Report


Following the release of the Buildable Lands Report, Darcy Jones of Jones Engineers (also an associate of Housing for Bellingham) and his team have carefully reviewed the report and its findings to better understand how the report’s conclusions align with the lived reality of housing availability and affordability.


If housing supply is low in 2022, what measures need to be in place to ensure we can meet the housing demand over the next 14 years?


After finding a number of inconsistencies and gaps in the report, Jones submitted the following letter on October 10th addressing how the Buildable Lands Report falls short, requesting revisions prior to its finalization. A few of the items listed in his letter:

  1. Areas inside of Bellingham have been assigned unrealistic densities to support housing

  2. The report does not address housing affordability or many of the other housing goals and policies of the Comprehensive Plan and countywide planning policies

  3. No reasonable measures are included in the report to address current housing issues


Unrealistic Densities


Jones points out that much of the land classified as buildable, within the City and its Urban Growth Areas (UGAs), is located in extremely challenging areas to build. Some of the land is in critical areas such as the Padden Creek watershed and steep slope areas, and much of it lacks the necessary capital facilities infrastructure, such as sewer and public utilities. Other areas also require expensive off-site road construction that may never be built as prerequisite conditions for any development.


In short, Jones finds the report assigns unrealistic housing densities to areas that are not readily buildable and notes that many of the assigned areas will require such significant financial and time-consuming commitments to develop housing that those lands will not fulfill the population needs by 2036.


In a Whatcom County Planning Commission hearing on October 13, 2022, Robert Carmichael says (1:00.42) planners adopted overly optimistic assumptions of buildable land which cannot be developed. At the hearing, Carmichael proposed conducting a feasibility study to assess the cost of infrastructure and the likelihood that the assessed land will actually be developed. Without reliable measurements such as ground-truthing, we’re at risk of producing inaccurate data that ultimately results in an insufficient supply of buildable land.


In a Whatcom County Council Planning and Development committee meeting on November 9, 2022, Council person, Kathy Kershner, asked (20:34),


“Why are developers not building housing on the buildable lands in the City? … This is a shocker to me because we’ve got people who can’t find homes, literally can’t find a home even if they can afford it.”


In response to Kershner’s question, some point to external factors such as the Great Recession of 2009 (21:47), supply chain issues, and interest rate increases. However, it’s important to remember that the Buildable Lands Report assessed the time period between 2016 and 2021, three and a half years pre-COVID when supply chain issues weren’t a factor, and interest rates were at all-time lows. Many in the building industry will confirm that the period from 2016 to 2021 was one of the most active building periods in Whatcom County’s recent history.


In response to this reasoning for the underproduction of housing in the City of Bellingham, Jones states in his public memo:


“The underproduction of housing since 2016 is due to the fact that there is not enough truly buildable land available within Bellingham. The problem is compounded by a lack of infrastructure planning to accommodate new housing, which has driven housing production farther away from the city.”


The shortage of homes to buy and rent has sent home prices soaring and has contributed to a significant increase in an unhoused population. Affordability benchmarks establish that no more than 30% of income should be spent on housing, but Bellingham’s median household income[1]was reported to be $59,163 per survey data collected by the US Census Bureau in 2021. In October 2022, Realtor.com reported the median home listing price in Bellingham, “was $625K, trending up 4.3% year-over-year.”


Home prices are too high for middle-class families, which is driving buyers and renters alike out of Bellingham and into more affordable areas like unincorporated places in Whatcom County and into the smaller cities like Ferndale, Lynden, and Everson that have seen unprecedented growth.


Exhibit 9 from the Buildable Lands report shows that Bellingham needs to be building 708 units a year to meet the population projections by 2036, while Lynden needs 114 units per year, Ferndale 96 units, and Everson only 17 housing units per year.


The City of Bellingham has worked to reduce barriers for new homes by utilizing the Infill Housing Toolkit, encouraging the building of accessory dwelling units (ADUs), implementing density bonuses, and amending certain zone classifications to increase plat density. These efforts rely heavily on current homeowners to re-build, remodel, or divide their lots to produce more housing. However, it’s unrealistic to depend on current homeowners to produce more housing to fill the need. Furthermore, these solutions will not provide enough new homes for buyers. These efforts may ultimately result in the availability of new rentals, but there’s no guarantee that these rentals will be affordable. In fact, City planner Chris Behee notes in the end of a presentation on Missing Middle Housing[2] that, “Infill Toolkit housing has generally not equated to affordable housing.”

“The assignment of density on land that is not buildable takes away the opportunity for real housing,” said Jones. This issue directly impacts Whatcom County’s residents, employers, and its overall economy.


Housing Affordability


Going back to the 2019 letter from the Business and Commerce Advisory Committee, one of the bigger and more pressing items with the 2022 Buildable Lands Report is that it does not include information about housing availability, affordability, or the variety of residential densities and housing types to meet the needs of all segments of the population.


It’s important to note that housing affordability was addressed by the consulting firm, Community Attributes, which helped prepare the BLR for Whatcom County. In the May 23, 2019 Stakeholder Interview Summary, Whatcom County Review and Evaluation (Buildable Lands) Program, the consulting firm notes in the Key Findings on Housing (page 5):


“Housing affordability is a principal concern in communities throughout Whatcom County. There are concerns that this challenge will grow as more higher income residents are drawn to Whatcom County from Seattle and Vancouver. Housing shortfalls are limiting jurisdictions’ ability to attract new employers.”


When questioned why housing availability and affordability were absent from the report, staff emphasized that affordability was not one of the measurements of the report and that it would be addressed in the 2025 Comprehensive Plan. Rather, the Buildable Lands Report focused only on the most basic and necessary fundamentals:


  1. Review Achieved Densities

  2. Assemble Net Developable Land Inventory

  3. Estimate Population and Employment Capacity

  4. Evaluate Land Capacity


One can surmise that the affordability was left out because it wasn’t officially mandated by the Growth Management Act until January 2021, when the first draft of Whatcom’s BLR was already in the works. However, Washington State law has encouraged counties to evaluate affordability and availability since 2017. Section 3 (e) in the E2SSB 5254 Senate Bill passed in October of that year calls for fully planning counties to identify measures to “increase housing availability and affordability for all segments of the community.”


As Whatcom County’s cultural and economic center, there is a consensus that the City of Bellingham has a responsibility to provide data on housing availability and affordability. During the Planning Commission hearing on October 13th, 2022, a number of residents, builders, and realtors called for the report to be revised. At the end of the two-hour hearing Commissioner Atul Deshmane moved that the first Findings of Fact should include:


“Staff and the Planning Commission recognize that the Buildable Lands Report does not address issues of housing affordability. Additional work that revisits the estimates of supply and demand that are feasible, realistic, and consistent with current regulatory requirements and infrastructure are needed and will be reviewed in the 2025 comprehensive plan updates.”


The Discussion to Introduce Whatcom’s First Buildable Lands Report


In a County Council committee meeting on December 6th, Jones and other stakeholders shared their concerns about the report’s shortcomings, which resonated with Council members who acknowledged the importance of having the report include an analysis of and recommendations for housing availability and affordability.


The Council also pushed for more clarity on the definition of single-family homes, and how the number of single-family homes was measured in the report. This is an important observation as some of the homes qualifying as “single-family” in the Buildable Land Report are actually accessory dwelling units or multi-unit townhome structures, which conflates the data. After thoroughly mapping the City of Bellingham and its urban growth areas, Jones reports that land for true single-family detached housing is severely constrained.


Per RCW 36.70A.020 the City has a duty to supply a variety of residential densities and housing types. Many of those who work and recreate in Bellingham and want to own a traditional single-family home have been forced to move to areas outside of the city, creating sprawl.


Yet, as it stands today, the Buildable Lands Report paints a rosy picture illustrating Bellingham’s progress of fulfilling the 2016 housing goals while carrying a surplus of land capacity. It claims that Bellingham can accommodate 16,063 dwellings to house 31,392 people through 2036, which is 10,672 more people than required. In reality, the report does not reflect the lived experience where there are not enough homes to buy or rent, and home prices are too expensive for middle-class families.


“If we accept the Buildable Lands [Report] as it is… we will continually plan for stagnation,” said Council Member Ben Elenbaas. “If you plan for stagnant growth, you’re going to get that.”


Running out of time to hear all of the concerns about the report, the County Council Planning and Development Committee moved to conduct additional committee meetings[3] for further discussion before introducing the report to the full County Council. Watch the committee discussion about the Buildable Lands Report beginning at 19:01.


Why Reasonable Measures for Bellingham Should Be Included in the 2022 Buildable Lands Report


As mentioned, many of the conclusions found in the report will be baselines for the 2025 Comprehensive Plan. If we rely on the current conclusions, we’re saying that Bellingham has a healthy housing market with plenty of land for new home construction.


The addition of reasonable measures will hold officials accountable to the actual lived experience in Bellingham. Steadfast in their call for affordable housing, the Housing Subcommittee of the Whatcom Business Advisory Council submitted a letter in September 2022 to the City of Bellingham’s Mayor Fleetwood and County Executive Satpal Sidhu, outlining almost two pages of potential solutions to create more affordable housing for our community.


Largely, the issue of housing transcends politics as we’ve seen at the County level. The Housing Subcommittee is composed of people representing a spectrum of viewpoints. From government officials to non-profit organizations, the letters were signed by the Whatcom Housing Alliance, Kulshan CLT, the Bellingham Regional Chamber of Commerce, the Port of Bellingham, Birch Equipment, CAZ Construction, and others.


Important to the evaluation of Bellingham in the Buildable Lands Report, it is proposed to consider including the following reasonable measures in accordance with the Department of Commerce Buildable Lands Guidelines:

  1. Review Bellingham’s Urban Growth Areas and reassess their capacity for growth

  2. Create an Annexation Plan to include the current UGA reserves in the City of Bellingham

  3. Invest in capital facilities to extend water and sewer services to areas that have viable, buildable lands

Jones emphasizes that City staff have done a tremendous amount of good work to produce the first Buildable Lands Report, and recognizes its complexity. Although, because it is Whatcom’s first BLR, it is crucial for the County to set a precedent by forming and releasing a report that outlines reliable density data and includes data on housing affordability, availability, and variety. All of those factors will create the foundation for the future growth strategies of Whatcom County.


Notes [1] We use median household income as it is the affordability benchmark used in Bellingham’s 2018 Consolidated Plan.

[2] FTP user name is anonymous and no user password is required.

[3] The next meeting to discuss the Buildable Lands Report is set to take place on January 10th 2023.

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