HomeMy WebLinkAboutord2023-010File ID:
File Created:
AB2022-641
11/02/2022
Whatcom County
Agenda Bill Master Report
File Number: AB2022-641
Version:
Entered by: maamot@co.whatcom.wa.us
COUNTY COURTHOUSE
311 Grand Avenue, Ste #105
Bellingham, WA 98225-4038
(360) 778-5010
Status: Adopted
Department: Planning and
Development Services
Department
File Type: Ordinance Requiring a Public Hearing
Assigned to:
Agenda Date:
Council
03/21/2023
Primary Contact Email: maamot@co.whatcom.wa.us
TITLE FOR AGENDA ITEM:
Ordinance adopting the Buildable Lands Report
SUMMARY STATEMENT OR LEGAL NOTICE LANGUAGE:
Final Action: 03/21/2023
Enactment#: ORD 2023-010
Ordinance adopting the Buildable Lands Report 2022 Whatcom County Review and Evaluation
Program (issued July 7, 2022, revised February 27, 2023), concluding that the review and evaluation
required by the Growth Management Act (RCW 36.70A.215) has occurred, concluding that
"reasonable measures" are required for the Birch Bay, Cherry Point, and Columbia Valley urban
growth areas, and concluding that "reasonable measures" are not required for any other lands in
unincorporated Whatcom County. The Buildable Lands Report indicates that reasonable measures are
also needed in the City of Bellingham and the City of Blaine.
HISTORY OF LEGISLATIVE FILE
Date: Acting Body: Action: Sent To:
11/22/2022 Council REFERRED TO Council Planning and
COMMITTEE Development Committee
Aye: 7 Buchanan, Byrd, Donovan, Elenbaas, Frazey, Galloway, and Kershner
Nay: 0
Absent: 0
12/06/2022 Council WITHDRAWN
Aye: 6 Buchanan, Byrd, Donovan, Elenbaas, Frazey, and Galloway
Whatcom County Page 1 Printed on 3/22/2023
Agenda Bill Master Report Continued (AB2022-641)
Nay: 0
Absent: Kershner
03/07/2023 Council SUBSTITUTE INTRODUCED Council
FOR PUBLIC HEARING
Aye: 7 Buchanan, Byrd, Donovan, Elenbaas, Frazey, Galloway, and Kershner
Nay: 0
Absent: O
03/21/2023 Council ADOPTED
Attachments:
Whatcom County
Aye: 7 Buchanan, Byrd, Donovan, Elenbaas, Frazey, Galloway, and Kershner
Nay: 0
Absent: O
Staff Memo (Feb 28, 2023), Substitute Ordinance for 3.7.2023 Introduction with staff change in
Finding 1, Proposed Ordinance for 3.7.2023 Introduction, Planning Commission Findings
Page2 Printed on 3/2212023
ORDINANCE NO. 2023-010 -------
ADOPTING THE BUILDABLE LANDS REPORT 2022
WHEREAS, The Whatcom County Planning Commission held a public hearing and issued
recommendations on the Buildable Lands Report; and
WHEREAS, The County Council considered Planning Commission recommendations;
WHEREAS, The County Council held a public hearing; and
WHEREAS, The County Council hereby adopts the following findings of fact:
FINDINGS OF FACT
1. The Buildable Lands Report 2022 -Whatcom County Review and Evaluation Program (July
7, 2022, revised February 27, 2023) recognizes that housing availability and housing
affordability are highly significant issues impacting our community.
2. Whatcom County recognizes that the Buildable Lands Report does not address the issue
of housing affordability and that there remain significant concerns regarding housing
availability. 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. Specifically,
land supply will need to be carefully reviewed to account for land constrained by legal
impediments, lack of infrastructure, and critical area restrictions. Additionally,
infrastructure improvements including transportation, public water, and sewer
improvements will need to be included in capital facility plans to accommodate forecasted
growth. And, as required by Engrossed Second Substitute House Bill 1220, jurisdictions
will need to plan for and accommodate housing affordable to all income segments of the
community.
3. The proposal is to adopt the Buildable Lands Report 2022 -Whatcom County Review and
Evaluation Program (July 7, 2022, revised February 27, 2023).
4. The SEPA Official determined on July 19, 2022 that adoption of the Buildable Lands Report
2022 -Whatcom County Review and Evaluation Program is categorically exempt from
SEPA review under WAC 197-11-800(17) as information collection and research.
5. Notice of the Planning Commission hearing was posted on the County website on
September 30, 2022.
6. Notice of the Planning Commission hearing was published in the Bellingham Herald on
September 30, 2022.
7. Notice ofthe Planning Commission hearing was sent to the County's email list on
September 30, 2022.
Page 1 of 12
8. The Planning Commission held a public hearing and recommended that the County
Council adopt the Buildable Lands Report 2022 -Whatcom County Review and Evaluation
Program on October 13, 2022.
9. The Growth Management Act "Review and Evaluation Program" (buildable land)
requirements became applicable to Whatcom County and the cities when the State
Legislature adopted Engrossed Second Substitute Bill 5254 in 2017.
10. The Growth Management Act's Review and Evaluation Program requirements (RCW
36.70A.215) include updating county-wide planning policies, developing a buildable lands
program methodology, data collection, reviewing achieved densities, evaluating land
suitable for development and issuing a Buildable Lands Report. The information contained
in the Buildable Lands Report will help to inform the next update of the Whatcom County
Comprehensive Plan, which is due by June 30, 2025.
11. In evaluating land suitable for development, RCW 36. 70A.215{3)(b)(ii) requires
jurisdictions to develop a "reasonable land market supply factor" consistent with the
Review & Evaluation Program Buildable Lands Guidelines {2018) published by the
Department of Commerce ("Guidance").
12. The land market supply factor is incorporated to account for the reality that not all
developable land will actually be developed within the planning timeframe.
13. WAC 365-196-310(2)(e) authorizes jurisdictions to consider unique local conditions when
establishing a market supply factor. Including relevant local factors is vital to ensuring that
the Buildable Lands Report presents a realistic picture of development within the
remaining planning period.
14. The Department of Commerce's Guidance also expressly encourages cities to adopt a
market supply factor that reflects "uniquely local conditions" to "avoid overestimation of
effective buildable lands capacity" (p. 47).
15. On March 24, 2022, the City of Bellingham released a Technical Memo describing the
analysis used to develop the land market factor utilized for developable lands within
Bellingham.
16. The County's consultant held interviews with representatives of each jurisdiction and
several key community stakeholders. This information was compiled in a Stakeholder
Interview Summary Whatcom County Review and Evaluation (Buildable Lands) Program
(CAI, May 2019).
17. The County's consultant conducted research on topics with important implications for the
buildable lands report, including local regulations, infrastructure, housing affordability,
and growth trends. This included reviewing relevant portions of the Revised Code of
Page 2 of 12
Washington and Washington Administrative Code. This information was compiled in a
Background Information and Key Issues Report (CAI, June 2019).
18. Whatcom County and the cities, with the assistance of a consultant, developed the
Whatcom County Review and Evaluation Program Public Participation Plan (April 2020)
and have followed that Plan.
19. Whatcom County and the cities developed draft Countywide Planning Policies establishing
the Review and Evaluation Program. The Whatcom County Planning Commission held a
public hearing on these Countywide Planning Policies on September 10, 2020. The
Whatcom County Council held a public hearing and adopted the Countywide Planning
Policies on February 9, 2021 (Ordinance 2021-003).
20. Whatcom County and the cities, with the assistance of a consultant, drafted the Whatcom
County Review and Evaluation Program Methodology to implement the 2017 state
amendments to the Growth Management Act. Stakeholders reviewed and provided
comments on preliminary draft versions of this Methodology in 2021. Modifications to
the draft Methodology were made based upon stakeholder comments in 2021. The
Whatcom County Planning Commission held a public hearing on the draft Methodology
on October 28, 2021. The County Council and city councils were briefed on the draft
Methodology in 2021-2022. The Whatcom County Planning Director approved the
Methodology on February 10, 2022.
21. Whatcom County and the cities, with the assistance of a consultant, developed Data
Reporting Tool templates for collection of data on development and local government
ordinances over the review period. The templates are intended to facilitate uniform
collection of data by the County and cities.
22. The County and cities entered information in the Data Reporting Tools, including
information on building permits and plats issued between April 1, 2016 and March 31,
2021. The Data Reporting Tools calculate achieved densities over the five-year review
period.
23. Whatcom County and the cities, with the assistance of a consultant, developed Suitable
Land Tool templates for estimating the amount of land available for development over the
remaining portion of the planning period. The templates are intended to facilitate
uniform evaluation of land supply by the County and cities.
24. The County and cities entered information in the Suitable Land Tools to estimate the
capacity of land suitable for development to accommodate population and employment
growth over the remaining portion of the existing planning period (2021-2036). The
Suitable Land Tools compare the land capacity to the projected population and
employment growth to estimate whether there will be a surplus or deficit of land to
accommodate projected growth (2021-2036).
Page 3 of 12
25. The City of Bellingham and the County shared draft Data Reporting Tool and Suitable Land
Tool spreadsheets at a Buildable Lands -Virtual Stakeholder Workshop on February 9,
2022.
26. Whatcom County and the cities issued the Bui/dable Lands Report 2022-Whatcom County
Review and Evaluation Program on July 7, 2022 and revised this Report on February 27,
2023 (the revisions primarily relate to the Jurisdiction Profile for the Bellingham UGA).
This Report summarizes and analyzes information from the Data Reporting Tools, Suitable
Land Tools, and other sources to meet the requirements of the Growth Management Act.
27. The Buildable Lands Report 2022-Whatcom County Review and Evaluation Program
states that there is sufficient suitable land to accommodate the countywide population
projection contained in the current Whatcom County Comprehensive Plan (Chapter 1),
which allocated growth through the year 2036.
28. The Buildable Lands Report 2022 -Whatcom County Review and Evaluation Program
states that each Urban Growth Area (UGA), with the exception of the Birch Bay UGA, has
sufficient suitable land to accommodate the UGA population projections contained in the
current Whatcom County Comprehensive Plan (Chapter 1), which allocated growth
through the year 2036.
29. The Buildable Lands Report 2022 -Whatcom County Review and Evaluation Program
states that there is sufficient suitable land to accommodate the countywide employment
projection contained in the current Whatcom County Comprehensive Plan (Chapter 1),
which allocated growth through the year 2036.
30. The Buildable Lands Report 2022 -Whatcom County Review and Evaluation Program
states that each UGA has sufficient suitable land to accommodate the UGA employment
projections contained in the current Whatcom County Comprehensive Plan (Chapter 1),
which allocated growth through the year 2036.
31. The Buildable Lands Report 2022 -Whatcom County Review and Evaluation Program
shows that reasonable measures are needed for the Birch Bay, Cherry Point, and
Columbia Valley UGAs pursuant to RCW 36.70A.215.44.
32. For the Birch Bay UGA, reasonable measures are needed to address:
a. Achieved residential densities between 2016 and 2021 were below the planned
densities in Whatcom County Comprehensive Plan Chapter 2 (Goal 2P);
b. Land capacity to accommodate the population projection adopted in Whatcom County
Comprehensive Plan Chapter 1; and
c. Land capacity to accommodate single family housing needs as set forth in Whatcom
County Comprehensive Plan Chapter 3.
Page 4 of 12
33. For the Cherry Point UGA, reasonable measures are needed to address employment
growth because growth that occurred between 2016 and 2021 was significantly below the
planned growth projected in the Whatcom County Comprehensive Plan (Chapter 1).
Employment growth would have exceeded the planned growth, except that a major
employer shut down in 2020.
34. For the Columbia Valley UGA, reasonable measures are needed to address employment
growth because growth that occurred between 2016 and 2021 was significantly below the
planned growth projected in the Whatcom County Comprehensive Plan (Chapter 1).
35. Reasonable measures are not required for any other lands in unincorporated Whatcom
County.
36. The suitable lands analysis is a planning level tool using model assumption and values
informed by development data from the 2016-2021 evaluation period. It is not derived
from an in-depth, parcel-by-parcel assessment of developability within the remainder of
the 20-year planning period.
37. There are large blocks of property in Bellingham that would benefit from an in-depth,
individual, parcel-by-parcel assessment of developability within the current planning
period. This level of review and analysis has not been completed in Bellingham and is
beyond the scope of this Build able Lands Analysis. In the land capacity analysis for the
2025 Comprehensive Plan update, Bellingham should coordinate further with owners of
large undeveloped land holdings to document and evaluate challenges and barriers
associated with development. Findings from these efforts should consider legal
impediments and be compared against deductions for critical areas, buffers, future
infrastructure, and market factors already incorporated into development capacity
estimates to determine if further deductions are appropriate.
38. As stated in the Bellingham jurisdictional profile, the capacity for single-family housing to
be built during the remaining planning period is minimally adequate to meet the target
established in the current Whatcom County Comprehensive Plan (Chapter 3-Housing,
Chart 3). As such, any overestimation of supply in Bellingham's land capacity analysis
could lead to a shortfall in that category. Further, the Bellingham analysis shows that
capacity for housing offering ownership opportunities is very limited. As seen in Exhibit
16, while 64% of the City's developable residential land is zoned for single-family
development, it accounts for only 26% of estimated future housing production. Whereas
the 36% of residential land zoned for multi-family development accounts for 74% of
estimated future production.
39. Following adoption of the 2016 Comprehensive Plan, Bellingham has undertaken
numerous initiatives to address housing availability and affordability. These initiatives
include measures identified by the Department of Commerce's Guidance as reasonable
measures, including without limitation encouraging infill and redevelopment, allowing
Page 5 of 12
density bonuses, rezoning, and encouraging developers to reduce off-street surface
parking.
40. Despite the many reasonable measures Bellingham has already undertaken, housing
affordability and housing supply remain critical concerns that warrant adopting additional
reasonable measures. The Bellingham jurisdictional profile in the Buildable Lands Report
includes a variety of reasonable measures aimed at addressing housing supply,
affordability, and ownership opportunities.
41. The Growth Management Act requires Whatcom County and the cities to update their
respective Comprehensive Plans by 2025 (RCW 36.70A.130), in part to accommodate
projected population and employment growth for the new planning period through the
year 2045.
42. Growth Management Act Planning Goal 4, which guides the development and adoption of
comprehensive plans and associated regulations, is to:
Plan for and accommodate housing affordable to all economic segments of the
population of this state, promote a variety of residential densities and housing
types, and encourage preservation of existing housing stock (RCW
36. 70A.020{4)).
43. The Growth Management Act includes mandatory elements that must be included in a
local comprehensive plan, including a housing element (RCW 36.70A.070{2)).
44. The Washington State Legislature passed Engrossed Second Substitute House Bill 1220,
which became effective on July 25, 2021. This legislation enacted significant amendments
to RCW 36.70A.070(2), requiring additional analysis and planning to address housing
affordability in the 2025 comprehensive plan updates.
45. In 2017, the Washington State Legislature amended the requirements of the evaluation
. program (Buildable Land Report) to include a "review and evaluation of ... infrastructure
gaps (including but not limited to transportation, water, sewer, and stormwater)" (RCW
36. 70A.215{{3)(b )(i)).
46. The Growth Management Act requires the 2025 comprehensive plan periodic updates to
address a number of things, including an inventory and analysis of existing and projected
housing needs that identifies the number of housing units necessary to manage projected
growth (provided by the department of commerce), preservation, improvement, and
development of housing, sufficient land capacity, and adequate provisions for existing and
projected needs of all economic segments of the community (RCW 36.70A.070(2)).
Page 6 of 12
47. The Washington State Department of Commerce anticipates that the State Legislature will
provide grants to local governments, including Whatcom County and the cities, to
implement the expanded housing element requirements in RCW 36. 70A.070(2). The State
anticipates these grants will be available July 1, 2023.
48. Whatcom County recognizes that housing availability and housing affordability are major
issues in our community.
49. Detached single family median home prices for the cities and Whatcom County as a whole
have risen as shown below.
2016 2022 Percentage Increase
Bellingham $340,500 $680,000 99.71%
Blaine $274,000 $536,000 95.62%
Everson $308,500 $565,000 83.14%
Ferndale $313,200 $630,000 101.15%
Lynden $314,000 $595,000 89.49%
Nooksack $262,000 $500,000 90.84%
Sumas $219,000 $340,000 55.25%
Whatcom County $315,000 $602,000 91.1%
Source: Whatcom County Association of REALTORS/ Multiple Listing Service data.
50. A report entitled "Puget Sound Regional Council & Washington State Department of
Commerce Housing Survey" (December 2022) indicates that respondents statewide and in
Western Washington identified housing costs/rents and homelessness as the two most
important problems facing Washington State today (p. 9). Statewide, 39% of respondents
identified housing costs/rents and 39% identified homelessness as the most important
issues. These percentages were slightly higher in Western Washington, where 40% of
respondents identified housing costs/rents and 41% identified homelessness as the most
important issues.
51. A report entitled "The Conspicuous Crisis: Addressing Housing Affordability in
Washington" (Challenge Seattle, January 2023) states" ... Nearly ~1 million Washington
households are cost-burdened, spending more than 30% of household income on
housing-related costs ... While burden rate varies, affordability is a state-wide challenge .
. . " (p. 5). Whatcom County has a high cost burden rate of 35.9% (p. 5).
Page 7 of 12
52. Whatcom County recognizes that solutions to housing availability and housing
affordability problems will require County government, city governments, the private
sector, and other entities working to plan and provide for sufficient and affordable
housing for the community.
53. Whatcom County recognizes that land capacity for housing is an important factor relating
to housing availability and affordability. Additional land capacity can be provided by
increasing densities (e.g. rezoning or amending the code to require minimum densities)
and/or reconfiguring or expanding urban growth areas.
54. Whatcom County and the cities should evaluate increasing densities (e.g. rezoning or
amending the code to require minimum densities) in urban growth areas, including land
within city limits, to accommodate additional housing units.
55. The Whatcom County Comprehensive Plan anticipates that approximately 84% of
population growth will occur in UGAs and about 16% outside UGAs in rural and resource
lands.
56. There are 10 UGAs in Whatcom County. Seven of these UGAs are associated with cities
and three are non-city UGAs (one of the non-city UGAs is Cherry Point, which does not
accommodate residential development).
57. The Whatcom County Comprehensive Plan anticipates countywide population growth will
occur in the following geographic areas:
a. 74.4% in the seven city UGAs;
b. 9.5% in the two non-city UGAs (Birch Bay and Columbia Valley); and
c. 16.1% outside of UGAs (in rural and resource lands).
58. The seven city UGAs consist of the land in the city limits and surrounding land designated
by the County for urban growth and annexation into the cities. The seven cities do not, as
a general matter, allow extension of public water and sewer outside city limits anymore.
County urban residential zoning in UGAs allows one dwelling unit/ten acres until public
water and sewer are available. The reason for this restriction is to preserve land for urban
density development once public water and sewer become available. As a practical
matter, this means that new urban density residential developments will not occur in city
UGAs until annexation takes place.
59. The Growth Management Act indicates that a purpose of the Buildable Lands Program is,
when necessary, to "Identify reasonable measures, other than adjusting urban growth
areas, that will be taken to comply with the requirements of this chapter" (RCW
36. 70A.215{1)(b)).
Page 8 of 12
60. However, population growth and housing allocations for the new planning period through
the year 2045 will be adopted in the 2025 comprehensive plan update process.
Accommodating the projected growth through the year 2045 will require a new land
capacity analysis to evaluate each UGA's ability to accommodate this additional growth
based on new population projections. The cities will make recommendations to the
County as part of the 2025 comprehensive plan updates whether to expand their
respective UGAs or not to accommodate this additional growth. The County Council
makes the final decision on UGA expansions.
61. The Growth Management Act requires capital facility planning for transportation, public
water, sewer, stormwater, schools, parks, and fire protection facilities in association with
the 2025 comprehensive plan updates (RCW 36.70A.070(3) and (6)).
62. The Housing Memorandum: Issues Affecting Housing Availability and Affordability (State
Department of Commerce, June 2019} indicates:
... Appropriate infrastructure of all types is perhaps the single most-important
determinant of whether or not otherwise buildable land will be developed or
redeveloped. Without appropriate connection and capacity for transportation,
water, wastewater, and stormwater in particular, new development or
redevelopment of land is extremely unlikely. Thus, lack of infrastructure renders
land unavailable for development or redevelopment, limiting the supply of land
and potentially driving up prices and costs (p. 59).
63. The Growth Management Act states "In general, cities are the units of local government
most appropriate to provide urban governmental services ... " (RCW 36.70A.110(4)). It is
essential that cities plan capital facilities to support housing growth.
64. Whatcom County is not a provider of public water and sewer, which are essential services
for urban residential growth. Therefore, Whatcom County will work with water and
sewer districts serving the Birch Bay and Columbia Valley UGAs to facilitate appropriate
urban growth in these areas.
65. Factors under local government control affect housing production and affordability, such
as land capacity, infrastructure, permit timelines, zoning, and complexity of regulations.
Cities control these factors in their incorporated boundaries and, therefore, have a large
influence on housing in Whatcom County. Whatcom County controls land use regulations
and permitting in unincorporated areas, but is not a provider of public water and sewer.
Additionally, the County has a responsibility under the Growth Management Act to
protect rural character and conserve resource lands.
Page 9 of 12
66. Factors beyond local government control also influence housing production and
affordability. The Housing Memorandum: Issues Affecting Housing Availability and
Affordability (State Department of Commerce, June 2019) identifies macroeconomic
trends including employment, prices/inflation (material and labor costs), and interest
rates, along with other factors, that affect housing production and affordability (p. 12).
67. Housing availability and affordability are issues of critical importance in Whatcom County.
They are also issues in many other areas around the country. The Joint Center for Housing
Studies of Harvard University's The State of the Nation's Housing 2022 indicates that
home prices in the U.S. have more than doubled from the 2012 low (following the Great
Recession) to early 2022 (p. 9). Additionally, Harvard's report states" ... The national
housing shortage is not just in affordable homes. According to Freddie Mac estimates, the
short fall in market-rate housing both for sale and for rent amounts to some 3.8 million
units ... " (p. 41). Harvard's report identifies factors under local control, such as land use
regulations, along with other factors that have contributed to housing production and
affordability issues.
68. Housing needs and affordability will be addressed in the 2025 Comprehensive Plan
Update as required by the Growth Management Act. The 2025 Comprehensive Plan
update will also "[p]lan for and accommodate housing affordable to all economic
segments of the population ... promote a variety of residential densities and housing
types, and encourage preservation of existing housing stock" as required by RCW
36. 70A.020(4).
69. The Buildable Lands Report 2022 -Whatcom County Review and Evaluation Program
provides an important analysis of development trends and characteristics in Whatcom
County and its cities from 2016-2021. Based on the foregoing findings, the Whatcom
County Review and Evaluation Program provides important input moving forward with
the 2025 comprehensive plan update process for the County and the cities, but should not
be considered the sole source of information that the County and cities rely upon to plan
for accommodating projected future growth.
70. All of the foregoing Recitals and Findings of Fact are legislative findings of the Whatcom
County Council and are fully incorporated into the following ordinance as a material part
thereof.
Page 10 of 12
NOW, THEREFORE, BE IT ORDAINED by the Whatcom County Council that:
Section 1. The review and evaluation required by the Growth Management Act has occurred
and the Buildable Lands Report 2022 -Whatcom County Review and Evaluation Program has
been issued in accordance with RCW 36. 70A.215.
Section 2. The Whatcom County Council hereby adopts the Buildable Lands Report 2022 -
Whatcom County Review and Evaluation Program (Exhibit A).
Section 3. The Whatcom County Council has determined that reasonable measures are needed
for the Birch Bay, Cherry Point, and Columbia Valley Urban Growth Areas (UGAs) pursuant to
RCW 36.70A.215.
Section 4. For the Birch Bay UGA reasonable measures are needed to address:
• Achieved densities that occurred between 2016 and 2021 that were below the planned
densities in Whatcom County Comprehensive Plan Chapter 2 (Goal 2P);
• Land capacity to accommodate the population projection adopted in Whatcom County
Comprehensive Plan Chapter 1; and
• Land capacity to accommodate the single family housing need as set forth in Whatcom
County Comprehensive Plan Chapter 3.
Section 5. For the Cherry Point UGA reasonable measures are needed to address employment
growth that occurred between 2016 and 2021 that was significantly below the planned growth
projected in Whatcom County Comprehensive Plan Chapter 1. Employment growth would have
exceeded the planned growth, except that a major employer shut down in 2020.
Section 6. For the Columbia Valley UGA reasonable measures are needed to address
employment growth that occurred between 2016 and 2021 that was significantly below the
planned growth projected in Whatcom County Comprehensive Plan Chapter 1.
Section 7. Reasonable measures are not needed for any other lands in unincorporated
Whatcom County.
Page 11 of 12
Section 8. The Clerk of the Council is hereby instructed to publish notice of the ordinance
adopting the Buildable Lands Report 2022 -Whatcom County Review and Evaluation Program
pursuant to RCW 36.70A.290.
Section 9. Adjudication of invalidity of any of the sections, clauses, or provisions of this
ordinance shall not affect or impair the validity of the ordinance as a whole or any part thereof
other than the part so declared to be invalid.
ADOPTED this 21st day of March
WHATCOM COUNTY COUNCIL
Dana Brn0n,i~,a\:,ts}t~;µri~il Clerk
(. ,:, 0 N
APPROVED as to form:
/s/ Karen Frakes
Civil Deputy Prosecutor
Date: 3/07/2023
2023.
)(f Approved ( ) Denied
¥StJL
Satpal Sidhu, County Executive
Page 12 of 12
~1µ1~3
~~
Exhibit A
Buildable Lands Report
Buildable Lands Report 2022
July 7, 2022 (Revised February 27, 2023)
ACKNOWLEDGEMENTS
Project Manager
• Matt Aamot, Whatcom County
Technical Committee
• Greg Aucutt, City of Bellingham
• Chris Behee, City of Bellingham
• Jori Burnett, City of Ferndale (former member)
• Michael, Cerbone, City of Ferndale
• Heidi Gudde, City of Lynden
• Eric Guida, Washington State Department of Commerce (former
member)
• Rollin Harper, Cities of Everson, Nooksack, and Sumas
• Haylie Miller, City of Ferndale (former member)
• Mark Personius, Whatcom County
• Stacie Pratschner, City of Blaine
• Valerie Smith, Washington State Department of Commerce
• Dave Timmer, City of Lynden
• Jennifer Noveck, Port of Bellingham
Consultant Team
Community Attributes, Inc.
• Cassie Byerly
• Kristina Gallant, AICP
• Tyler Coyle
• Michaela Jellicoe
• Bryan Lobel
• Chris Mefford
• Ethan Schmidt
• Elliot Weiss, AICP
CONTENTS
Introduction .................................................................................................................... 5
Background and Purpose ............................................................................................. 5
Methods ....................................................................................................................... 6
Organization of Report ................................................................................................. 6
Policy Framework ............................................................................................................ 7
Countywide Planning Policies ...................................................................................... 7
Population and Employment Growth Allocations ......................................................... 7
Methods ........................................................................................................................... 9
Data Sources ................................................................................................................ 9
Data Collection and Evaluation (2016-2021) ................................................................ 9
Review and Evaluation of Land Suitable for Development (2021-2036) ..................... 10
Countywide Findings ..................................................................................................... 16
Population & Employment Growth ............................................................................ 18
Development Activity ................................................................................................. 21
Planned and Achieved Densities ................................................................................ 24
Land Suitable for Development .................................................................................. 25
Inconsistencies and Reasonable Measures ................................................................. 27
Jurisdiction Profiles ...................................................................................................... 28
1. Bellingham UGA ................................................................................................. 29
2. Birch Bay UGA .................................................................................................... 48
3. Blaine UGA ......................................................................................................... 61
4. Cherry Point UGA ················································:·············································· 72
5. Columbia Valley UGA ......................................................................................... 78
6. Everson UGA ....................................................................................................... 89
7. Ferndale UGA ..................................................................................................... 99
8. Lynden UGA ...................................................................................................... 109
9. Nooksack UGA ....... : .......................................................................................... 120
10. Sumas UGA .................................................................................................... 130
Appendix A: Annexations ............................................................................................ 139
Appendix B: Urban Growth Area Changes .................................................................. 140
Appendix C: Zoning Map Changes ............................................................................... 141
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 1
JULY 2022, REVISED FEB 2023
EXECUTIVE SUMMARY
The Whatcom County Buildable Lands Report 2022 is the first report
completed by the County and cities consistent with the requirements of the
Review and Evaluation Program within Washington State's Growth
Management Act (RCW 36. 70A.215). The purpose of this report is to assess
how recent development in the cities and urban growth areas (UGAs) has
compared with planning assumptions, targets, and objectives in adopted
Countywide Planning Policies and comprehensive plans, and whether there
are inconsistencies for the County and cities to address. The report assesses
how much land is available to serve future growth, and whether it is
sufficient to accommodate expected growth. Finally, the report provides basic
information relating to development on rural and resource lands (areas
outside UGAs).
Population & Employment Growth
From 2016-2021, new residential construction in Whatcom County and the
cities accommodated an estimated 24% of the projected 20-year population
growth for the planning period (2016 through 2036). The County and cities
will need to accommodate another 46,240 persons for the remaining period
2021 through 2036. From 2016 to 2021, new commercial and industrial
construction in Whatcom County and the cities accommodated an estimated
17% of the projected employment growth for the 20-year planning period, and
will need to accommodate another 26,829 jobs by 2036.
• Whatcom County contains 10 urban growth areas (UGAs). Seven
UGAs represent future annexation areas for corresponding
incorporated cities. Three are standalone UGAs, not associated with a
city.
• Whatcom County is projected to have 275,450 residents and 120,284
employees by 2036 with projected growth allocations of 60,565 for
population and 32,219 for employment between 2016 and 2036.
• New construction in Whatcom County and the cities accommodated an
estimated 14,326 people (83% within UGAs) and 5,351 employees (93%
within UGAs) from 2016-2021.
• Whatcom County has an estimated 46,240 population growth and
26,829 employment growth remaining to accommodate between 2021
and 2036.
Development Activity
From 2016-2021, Whatcom County and the cities permitted 6,659 new
housing units, averaging 1,332 per year. This average will need to increase to
accommodate remaining projected population growth. Achieved densities in
incorporated city UGA areas are exceeding planned densities, while achieved
WHATCOM COUNTY
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JULY 2022, REVISED FEB 2023
commercial and industrial densities are lagging in some areas. The
Jurisdiction Profiles section of this report contains UGA-level details on
achieved densities for the period 2016-2021.
• Whatcom County and the cities permitted a total of 6,659 housing
units countywide between 2016 and 2021 (84% within the UGAs, 16%
outside the UGAs).
• On average countywide, the number of net new housing units
permitted and built was 1,332 per year from 2016-2021. The
jurisdictions will need to increase the average annual housing
production to 1,478 units per year from 2021-2036 to accommodate
remaining projected population growth.
• Densities ranging from 4.4 to 11.5 dwelling units per acre were
achieved for residential uses in incorporated areas and one dwelling
unit per 3. 7 acres for Non-UGA areas.
• Achieved residential densities in cities exceeded planned densities,
while three unincorporated city UGAs had achieved densities that
were lower than ultimate planned densities (as city water and sewer
are typically not extended to new development outside city limits).
Achieved commercial and industrial densities are lagging planned
densities in several small cities.
• For non-city UGAs, residential development in the Columbia Valley
UGA exceeded the planned density while residential development in
the Birch Bay UGA did not.
Land Suitable for Development
For the inaugural Review and Evaluation Period, it is estimated that
Whatcom County UGAs have over 6,102 acres of net developable (vacant,
partially-used, and underutilized) land to accommodate remaining projected
population and employment growth from 2021-2036. The Jurisdiction Profiles
section of this report contains UGA-level details on developable land and
deductions. Appendices A through C document annexations, UGA changes,
and zoning map changes for the period 2016-2021.
• Whatcom County UGAs, which include cities, have estimated net land
capacity for remaining population growth of 73,075 for the remainder
of the 20-year planning period from 2021 to 2036, indicating an
estimated population capacity surplus of 34,215.
• Whatcom County UGAs, which include cities, have estimated net land
capacity for remaining employment growth of 41,057 for the
remainder of the 20-year planning period from 2021 to 2036,
indicating an estimated employment capacity surplus of 16,652.
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JULY 2022, REVISED FEB 2023
Inconsistencies and Reasonable Measures
On a county-wide basis, surplus capacity exists to accommodate both
remaining projected population and employment growth for the rest of the
20-year planning period through 2036. In addition, planned residential
densities in the cities are being achieved.
When planned densities are not being achieved, there is not sufficient
capacity to accommodate remaining projected population or employment
growth, or development patterns are not occurring as planned, Whatcom
County and the cities will work together to determine if reasonable measures
are necessary to address the issue, with the jurisdiction making the final
decision on reasonable measures.
A list of potential reasonable measures that jurisdictions may consider, if
needed, are documented in the Whatcom County Review and Evaluation
Program Methodology (February 10, 2022), Appendix A. The Jurisdiction
Profiles address whether reasonable measures may be needed for individual
UGAs.
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,JULY 2022, REVISED FEB 2023
INTRODUCTION
Background and Purpose
The Review and Evaluation Program, which is also known as the Buildable
Lands program, is part of Washington State's Growth Management Act
(GMA). The program requires that certain counties and cities review the
growth and development that has occurred within their jurisdictions since
the last updates to their State mandated comprehensive plans. Past growth
is compared with the growth and development assumptions, targets, and
objectives that are contained in the current plans. Where actual growth
diverges from growth and development assumptions, the State calls on the
jurisdictions to implement "reasonable measures" in the next comprehensive
plan updates to maintain consistency with GMA requirements (RCW
36. 70A.215(1)). Under the GMA, the deadline for the next comprehensive
plan updates is June 30, 2025.
The GMA's Review and Evaluation Program was established in 1997 and
originally applied to all jurisdictions within six counties. The first major
revision to the program was completed in 2017, when the State Legislature
passed Engrossed Second Substitute Bill (E2SSB) 5254. As part of this
revision, Whatcom County was added as the seventh Buildable Lands county.
The Buildable Lands Report 2022 is the County and cities first report
responding to the review and evaluation requirements of GMA. The report
reviews development data from 2016-2021, and evaluates capacity to serve
remaining growth through 2036, the planning horizon from the most recently
adopted comprehensive plan.
The report summarizes development data at the city, UGA and County level
to answer the following questions:
• What is the actual density and type of housing (single family and
multifamily) that has been built in Whatcom County's UGAs?
Approximately how much population does it support? Are urban
densities being achieved?
• How much land has been developed for commercial and industrial
uses? Approximately how much employment does it support?
• How does this development activity compare with growth and
development assumptions, targets, and objectives in the
comprehensive plans?
• How much population and employment growth remains to be
accommodated by 2036? Is there sufficient land and densities in UGAs
to accommodate planned growth?
WHATCOM COUNTY
BUILDABLE LANDS REPORT
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JULY 2022, REVISED FEB 2023
Whatcom County and the cities have updated the inventory of vacant,
partially-used, and underutilized land in accordance with the Whatcom
County Review and Evaluation Program Methodology. This is the supply of
land available to serve future growth. Using recent achieved densities and
other data as a guide, the report estimates how much population and
employment this land can support. This analysis is used to answer the
following question: is there enough suitable land to accommodate population
and employment growth through 2036?
Where inconsistencies are identified, the report will discuss whether
"reasonable measures" may be needed to address inconsistencies in the
upcoming comprehensive plan update cycle. Ultimately, the County and each
city will individually determine whether reasonable measures are required
for their jurisdiction.
Methods
The methods for this analysis were developed based on the Department of
Commerce's 2018 Buildable Lands Guidelines and the Whatcom County
Review and Evaluation Program Methodology. A technical committee with
representatives of the County and each city (City/County Planner Group) met
regularly to discuss and establish key elements of the program. Program
methods are summarized in the "Methods" section, with full detail provided
in the Whatcom County Review and Evaluation Program Methodology. The
suitable lands analysis is a planning level tool using model assumption and
values informed by development data from the 2016-2021 evaluation period.
It is not derived from an in-depth, parcel-by-parcel assessment of
developability within the remainder of the 20-year planning period.
Organization of Report
This report is organized into the following sections:
• Policy Framework. Explains key Whatcom County policies relevant
to the program, including Countywide Planning Policies and growth
allocations.
• Methods. Explains how data was gathered and analyzed for this
report, key assumptions, and how these methods were developed.
• Countywide Findings. Summarizes the ability of UGAs and other
areas to accommodate adopted population and employment allocations
through 2036. Seven of the ten UGAs correspond to cities.
• Jurisdiction Profiles. Provides detailed findings for recent
development activity and land suitable for development at the UGA
and zoning designation level.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
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JULY 2022, REVISED FEB 2023
POLICY FRAMEWORK
Countywide Planning Policies
The County and cities worked together to develop Countywide Planning
Policies to establish and guide the Review and Evaluation Program, as
required by RCW 36.70A.215. In summary, Countywide Planning Policies Q.1
-Q.8:
• Indicate that the County and cities will cooperate to implement and
maintain the Review and Evaluation Program;
• Set forth the purposes of the program;
• Address the Review and Evaluation Program Methodology; and
• Indicate that the County and cities will prepare a Buildable Lands
Report, collect and analyze development data, and discuss potential
reasonable measures if there are inconsistencies between actual
development patterns and assumptions contained in the County or
city comprehensive plans.
The County and cities also developed Countywide Planning Policies R.1 -R.4
relating to Dispute Resolution Procedures.
Population and Employment Growth Allocations
A key outcome of the Review and Evaluation Program is estimating
population and employment growth and determining if population and
employment capacity are consistent with adopted growth targets. Whatcom
County has adopted population projections by UGA and for areas outside of
UGAs (Non-UGAs) through 2036 in the Whatcom County Comprehensive
Plan, Chapter 1 (page 1-7). Total Whatcom County population is projected at
275,450 by 2036. The Comprehensive Plan also adopts employment
projections for 2036 (page 1-8), totaling 120,284 by 2036.
For the purposes of the Review and Evaluation Program analysis, population
and employment growth projections have been pro-rated to the 2016-2036
timeframe to fit the Review and Evaluation period (Exhibit 1 and Exhibit
2).
Population and employment growth estimates for 2016-2021 are subtracted
from total projected growth by UGA for 2016-2036 to estimate the remaining
population and employment growth to be accommodated during the review
period (2021-2036). This remaining growth to be accommodated is then
compared to estimated population and employment capacity to understand if
there are sufficient land and densities to accommodate planned growth.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
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JULY 2022, REVISED FEB 2023
Exhibit 1. Whatcom County Comprehensive Plan Population (2013-2036)
and Pro-Rated Population Growth (2016-2036)
2013 2036 Population 2016-2036
UGA Population Allocation Population
Growth
Bellingham 92,660 123,710 27,000
Birch Bay 7,540 12,822 4,593
Blaine 5,171 9,585 3,838
Columbia Valley 3,103 4,448 1,170
Everson 2,665 3,907 1,080
Ferndale 12,758 19,591 5,942
Lynden 12,872 19,275 5,568
Nooksack 1,435 2,425 861
Sumas 1,449 2,323 760
UGA Total 139,696 198,129 50,811
Non-UGA 66,104 77,321 9,754
County Total 205,800 275,450 60,565
Sources: Whatcom County Comprehensive Plan (Chapter 1, page 1-7); Whatcom County, 2021.
Notes: The Cherry Point UGA is excluded from this table as no population growth is projected
for the UGA.
Exhibit 2. Whatcom County Comprehensive Plan Employment (2013-2036)
and Pro-Rated Employment Growth (2016-2036)
2013 2036 Employment E 201
1
6•2036 t UGA . mp oymen Employment Allocation Growth
Bellingham 52,359 75,000 19,688
Birch Bay 595 1,140 474
Blaine 3,062 5,159 1,823
Cherry Point 1,993 2,883 774
Columbia Valley 85 444 312
Everson 710 1,312 523
Ferndale 5,372 9,372 3,478
Lynden 4,946 7,103 1,876
Nooksack 254 369 100
Sumas 700 1,145 387
UGA Total 70,076 103,927 29,436
Non-UGA 13,156 16,357 2,783
County Total 83,232 120,284 32,219
Sources: Whatcom County Comprehensive Plan (Chapter 1, page 1-8); Whatcom County, 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 8
JULY 2022, REVISED FEB 2023
METHODS
This section summarizes the principal methods, data sources, and key
assumptions developed for Whatcom County's Buildable Lands Report 2022.
The complete methodology is documented in the Whatcom County Review and
Evaluation Program Methodology.
Data Sources
Whatcom County and the cities collected key data on development in their
jurisdiction between 2016 and 2021. Each jurisdiction submitted data and
analysis to Whatcom County, who facilitated the overall Buildable Lands
process. Whatcom County gathered data for unincorporated UGAs and Non-
UGAs (rural areas and resource lands). Jurisdictions collected the following
data for this Review and Evaluation Program:
1. Development activity, sourced primarily from city and County
building permitting and platting data.
2. Land use and zoning changes, from local ordinances relating to
annexations, changes to UGAs and zoning map changes.
3. Changes to development and environmental
regulations, from city and County ordinances relating to
zoning, development codes and critical areas regulation.
4. Parcel data, from County Assessor's real property and
parcel files and related extracts, to tabulate and classify
types of land available for future development.
5. Other documentation, such as changes to planned capital
facilities and any adopted reasonable measures that could
impact land capacity.
Data Collection and Evaluation (2016-2021)
Data collection is only required to the extent necessary to determine
compliance with RCW 36. 70A.215 (including achieved densities and the
remaining quantity and types of land available for development during the
current planning period). The County and cities entered data into
spreadsheet-based Data Reporting Tools for each jurisdiction to capture all
required data between April 1, 2016 and March 31, 2021. City data is
maintained separately from unincorporated UGA data as building permit
records for unincorporated UGAs are maintained and administered by the
County and urban development is not generally anticipated to occur in
unincorporated city UGAs until they are annexed.
The Data Reporting Tools facilitate the collection, organization, and analysis
of permitting, platting, and other data from each city and the County. The
data are used to calculate and compare actual achieved densities for the
reporting period (2016-2021) with planned densities. The Data Reporting
WHATCOM COUNTY
BUILDABLE LANDS REPORT
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JULY 2022, REVISED FEB 2023
Tools estimate population and employment growth between 2016-2021 and
estimate population and employment growth for the remainder of the 20-year
planning period of the current County Comprehensive Plan (2021-2036).
In looking forward to subsequent updates, additional information on planned
future capital facilities, regulatory updates, and any previously adopted
reasonable measures will be collected to facilitate tracking by the County and
cities. Countywide annexations, UGA changes, and zoning map changes are
also inventoried for the reporting period (Appendix A through C). Data
should be collected annually for subsequent Review and Evaluation Periods.
Review and Evaluation of Land Suitable for Development
(2021-2036)
The GMA requires Whatcom County and cities to identify land suitable for
development or redevelopment and determine whether there is sufficient
suitable land to accommodate future growth. This section outlines the steps
and methods used to complete this Buildable Lands analysis. The basic steps
for cities and UGAs are as follows:
1. Review Assumptions and Achieved Densities
2. Assemble Net Developable Land Inventory
3. Estimate Population and Employment Capacity
4. Evaluate Land Capacity Sufficiency
The County and cities entered data and assumptions into spreadsheet-based
Suitable Land Tools for each UGA to estimate population and employment
capacity, compare that capacity to growth allocations, and evaluate whether
land capacity is sufficient to accommodate growth over the remaining portion
of the planning period (2021-2036).
If the analysis identifies shortfalls in land capacity, or if recent development
has diverged from planning assumptions, targets, and objectives there is an
additional requirement to determine if reasonable measures are required
to improve consistency.
Review Assumptions and Achieved Densities
Several key components of the Buildable Lands analysis rely on
developing assumptions and calculating the achieved net density of new
residential, commercial, and industrial development in cities and UGAs
during the reporting period (2016-2021). Two primary steps in the process
are:
• Developing assumptions for occupancy rates and average household
sizes (for residential development) and occupancy and square feet per
employee rates (for commercial / industrial development).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
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JULY 2022, REVISED FEB 2023
• Determining achieved densities for residential, commercial, and
industrial development completed during the reporting period.
Three technical memos developed for Whatcom County's Review and
Evaluation Program document methods used to determine the assumptions
used in the analysis. Technical Memo Comparing Whatcom County
Occupancy and Persons Per Household Rates by Housing Type and
Owner I Renter Tenure (City of Bellingham, February 2022) examines the
differences between occupancy and persons per household rates for single
family and multifamily housing types and for renter-occupied and owner-
occupied households. Whatcom County Review and Evaluation Program Birch
Bay Occupancy & Persons per Household Rates (CAI, June 29, 2021) provides
alternative assumptions for the Birch Bay UGA. The City of Bellingham
developed a Technical Memo Estimating Square Feet Per Job for
Commercial and Industrial Lands in Whatcom County (October 20, 2020)
that evaluates local space utilization patterns for all UGAs throughout the
County. Resulting figures are used to translate built commercial and
industrial building area into an estimate of the number of employees that
can be accommodated in that area. Based on this analysis, each city and
Whatcom County selected the appropriate assumed square feet per employee
for commercial and industrial development types. Exhibit 3 summarizes the
assumptions by development type and jurisdiction.
Exhibit 3. Commercial and Industrial Employment Density Estimates in
Square Feet per Employee
UGA Commercial Industrial
Bellingham 440 660
Birch Bay 532 812
Blaine 531 739
Cherry Point 205 1,779
Columbia Valley 532 812
Everson 800 1,501
Ferndale 580 1,129
Lynden 721 1,037
Nooksack 605 795
Sumas 669 890
Source: Technical Memo Estimating Square Feet Per Job for Commercial and Industrial
Lands in Whatcom County, City of Bellingham, October 20, 2020. Whatcom County and cities'
Suitable Land Tools.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
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JULY 2022, REVISED FEB 2023
Once population and employment assumptions have been selected, the next
step is to determine the actual density of residential and employment
development that occurred during the reporting period (2016-2021) in terms of
dwelling units per net acre for residential development and floor area ratios
(FAR) for commercial and industrial development. Later, achieved net
density data and other planning assumptions are used to convert developable
land into future population and employment capacity for UGAs in the
Suitable Land Tools.
Assemble Net Developable Land Inventory
The Net Developable Land Inventory for UGAs consists of all land which, as
of April 1, 2021, was considered vacant, partially-used, or underutilized
and which is expected to be available for development and served by
infrastructure during the current planning period. Exhibit 4 details the
criteria underlying each of these categories.
Exhibit 4. Criteria for Classifying Developable Land
Category
Vacant
Parcel Zoning Criteria for Classification
A--'V•~-~w,-•~o•••-Yo,--,---"~'-•mmw""~~--------------•
All Residential, Improvement value less than $10,000
Partially
Used
Commercial, Industrial
Single Family Parcel size greater than three (3) times
minimum allowed under zoning.1 This may be
lowered to between two (2) and three (3)
times the minimum allowed under zoning at
the discretion of the jurisdiction.
Jurisdictions may propose to exclude parcels
with current assessed improvement value >
93 rd percentile 2 of jurisdiction improvement
values if the parcel size is less than five
acres.
Multifamily, Ratio between improvement value and land
Commercial, Industrial value less than 1.0.3
1 This threshold accounts for parcels less than three times the minimum size that due to parcel
configuration, location of existing development on the site, or other factors are not likely to be
divided to their maximum potential.
2 The option to exclude parcels with high improvement values is meant to account for large single
family parcels with high-end homes that are unlikely to be subdivided. The 93 rd percentile threshold
was determined by analyzing the distribution of housing values in the County and selecting a
reasonable value that could be applied across all jurisdictions.
3 The Department of Commerce's Buildable Lands Guidelines (2018) state" ... When the value of
the land is near or higher than the value of the improvement on the land, the property is generally
going to be more favorable for redevelopment ... " (page 34).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
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JULY 2022, REVISED FEB 2023
Category Parcel Zoning Criteria for Classification
Under-
Utilized
Single Family
Multifamily
Commercial and
Industrial
Jurisdictions can identify existing
development, such as gas stations or uses
that preclude significant development on the
site, as fully developed when the ratio of
improvement value to land value is less than
1.0. If identified as fully developed, the parcel
will be subtracted from the inventory.
NIA
Parcels occupied by nonconforming single
family residential uses.
Parcels occupied by nonconforming
residential uses or other nonconforming uses.
The net developable land inventory process for the Review and Evaluation
Period included the following steps, described in greater detail in the
Whatcom County Review and Evaluation Program Methodology:
• Compile Gross Developable Land Inventory: Identify parcels
zoned for residential and employment development which are
considered vacant, partially-used, or underutilized.
• Deduct Critical Areas and Other Areas with Reduced
Development Potential: Remove the parcels and portions of parcels
which are impacted by critical areas or other issues that, it is assumed,
will not be developable during the planning period.
• Deduct Land for Future Public Uses: Remove any land already
planned for future capital facilities and quasi-public uses.
• Infrastructure Gaps: Determine if there are infrastructure gaps that
would reduce or prevent urban density development on vacant,
partially-used, and underutilized lands over the remainder of the
planning period. Remove land not likely to be served with the capital
facilities needed to support urban density development.
• Deduct Land for Future Infrastructure and Quasi-Public Uses:
Apply percentage reductions to deduct assumed portions of developable
land that will be dedicated to future infrastructure and quasi-public
WHATCOM COUNTY
BUILDABLE LANDS REPORT
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JULY 2022, REVISED FEB 2023
UGA
Bellingham
Birch Bay
Blaine
Cherry Point
uses. Future infrastructure deductions are informed by the analysis of
2016-2021 permit data for each jurisdiction.
• Deduct Market Factor: Apply a reasonable market factor to account
for lands that are not likely to be available for development because of
landowner preferences or other reasons not accounted in the previous
deduction steps. For the Review and Evaluation Period, Whatcom
County and the cities have developed a framework, documented in the
Whatcom County Review and Evaluation Program Methodology to
guide development of suitable market factors specific to the UGAs and
land uses by development status. Market factors applied by
development type and parcel status, as well as the overall average
market factor for each UGA are presented in Exhibit 5.
Exhibit 5. Market Factors by UGA, Land Use Category, and Development
Status
Single Family Multifamily Commercial Industrial Combined
Vacant PU uu Vacant PU uu Vacant PU uu Vacant PU uu
22% 26% 30% 20% 25% 30% 20% 25% 30% 20% 25% 30% 24%
17% 27% 27% 15% 27% 27% 17% 27% 27% N/A N/A N/A 20%
15% 25% 25% 15% 25% 25% 15% 25% 25% 15% 25% 25% 19%
N/A N/A N/A N/A N/A N/A N/A N/A N/A 23% 33% 33% 23%
Columbia Valley 24% 30% N/A 24% N/A 30% 24% N/A 30% 24% N/A N/A 24%
Everson
Ferndale
Lynden
Nooksack
Sumas
15% 25% N/A 15% 25% N/A 15% 25% 25% 15% 25% 25% 19%
15% 25% 25% 15% 25% 25% 15% 25% 25% 15% 25% 25% 20%
15% 25% N/A 15% 25% 25% 15% 25% 25% 15% 25% 25% 20%
15% 25% N/A N/A N/A N/A 15% 25% 25% 15% N/A 25% 21%
15% 25% N/A 15% 25% N/A 15% N/A 25% 15% 25% 25% 19%
Sources: Whatcom County and Cities' Suitable Land Tools, 2022.
Note: PU refers to partially-used land. UU refers to underutilized land. NI A's indicate a
category that has no assumed future development or no developable land capacity within the
jurisdiction.
After applying the market factor, the final acreage totals by zoning
designation and UGA represent the updated net developable land inventory -
the land expected to be available to accommodate future population and
employment over the remaining planning period.
Estimate Population and Employment Capacity
In this step, net developable land inventory is converted into population and
employment capacity. The final product is an estimate of the number of
people and employees that can be accommodated in each UGA on developable
land. This process includes the following steps, described in detail in the
Whatcom County Review and Evaluation Program Methodology:
• Determine Assumed Future Densities: Use achieved densities,
when available, as the baseline assumed densities for future
WHATCOM COUNTY
BUILDABLE LANDS REPORT
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JULY 2022, REVISED FEB 2023
development in the UGA over the remaining portion of the current
20-year planning period.
• Determine Population Capacity: Apply residential development
assumptions, including assumed density, occupancy rate and
persons per household to the residential Net Developable Land
Inventory to estimate current capacity for new residential
development in UGAs.
• Determine Employment Capacity: Apply employment
development assumptions, including assumed density (FAR),
occupancy rate, and employees per square foot to the commercial
and industrial net developable land inventory to estimate current
capacity for new commercial and industrial development.
Evaluate Land Capacity Sufficiency
The final step is to evaluate whether there is currently enough land capacity
in UGAs to accommodate projected growth through the remainder of the
current 20-year planning period (2021-2036). This includes the following
steps:
• Compare Population Capacity to Remaining Projected
Growth: Compare the estimated population growth capacity to the
remaining projected population growth. Identify any
inconsis te ncie s.
• Compare Employment Capacity to Remaining Projected
Growth: Compare the estimated employment growth capacity to
remaining projected employment growth. Identify any
inconsistencies.
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JULY 2022, REVISED FEB 2023
COUNTYWIDE FINDINGS
Whatcom County contains ten urban growth areas (UGAs). Seven UGAs
represent future annexation areas for corresponding cities and three are
standalone, non-city UGAs (Cherry Point, Columbia Valley, and Birch Bay).
Whatcom County as a whole is projected to have 275,450 residents and
120,284 employees by 2036. Whatcom County UGAs have projected growth
allocations of 50,811 for population and 29,436 for employment between 2016
and 2036 (Exhibit 1 and Exhibit 2).
Based on data collected by the cities and the County in the Data Reporting
Tools for building permits that received final approval between April 1, 2016
and April 1, 2021 and occupancy, persons per household and square feet per
employee assumptions, new construction in Whatcom County and the cities
accommodated an estimated 14,326 people (83% within UGAs) and 5,351
employees (93% within UGAs) in this five year period (Exhibit 6 and
Exhibit 7).
The Washington State Office of Financial Management (OFM) estimates that
Whatcom County population grew by 13,631 between April 1, 2016 and April
1, 2021. This total would have been higher if not for the COVID 19
pandemic, which resulted in out-of-county higher education students
returning home to engage in on-line classes. OFM estimates that changes in
housing occupancy rates and household size in existing 2016 housing stock
account for 14% of total growth in countywide household population between
2016 and 2021.
The Buildable Lands Report 2022 uses the 2036 population projections that
were adopted in the 2016 city and County comprehensive plans. The
estimated growth from building permits, as compiled in the Data Reporting
Tools by the cities and the County, is similar to the growth estimated by
OFM (2016-2021) as shown below.
Based on
information
from the Data
Reporting Tools
WHATCOM COUNTY
BUILDABLE LANDS REPORT
County-wide
Population Growth
(2016-2021)
14,326
County-wide Growth to
Pro-rated Accommodate
Population (2021-2036)
Growth (2016-
2036)
60,565 46,239
PAGE 16
JULY 2022, REVISED FEB 2023
Based upon 13,631 60,565 46,934
OFM estimates
This Buildable Lands Report uses the population growth estimate (2016-
2021) from the Data Reporting Tools, which means that Whatcom County
and the cities have an estimated 46,239 more people and 26,829 more
employees to accommodate between 2021 and 2036 (Exhibit 6 and Exhibit
7).
For the Review and Evaluation Period of 2016-2021, Whatcom County and
the cities permitted a total of 6,659 net new housing units (Exhibit 8). Of
these, 84% were permitted within the UGAs, and 16% were outside the
UGAs. On average, the number of net new housing units permitted and built
was 1,332 per year for the County as a whole. With 22,176 additional housing
units needed to accommodate projected population growth from 2021 through
2036, and based on VGA-specific occupancy and density assumptions, the
cities and County will need to increase the average annual housing
production to 1,478 units per year from 2021-2036 (Exhibit 9). This
represents an increase of around 11 % over the 2016-2021 production rate.
From 2016-2021 Whatcom County and the cities also developed a total of 3.9
million square feet of built area on 1,285 commercial and industrial acres
supporting an estimated 5,351 jobs (Exhibit 7 and Exhibit 10). UGAs
accommodated 94% of the built square footage and 93% of the estimated jobs
on 38% of the developed acres. Non-UGA areas accommodated 6% of the
built square footage and 7% of the estimated jobs on 62% of the developed
acres. Commercial development comprised 84% of this developed acreage for
the period 2016-2021, with industrial development comprising 16%. When
considering these numbers, it should be noted that some commercial building
in the Non-UGAs occurs on rather large parcels where large areas of the lot
remain undeveloped. On a countywide basis, commercial development
averaged 0.05 floor-area ratio (FAR -a ratio of built square footage to net
parcel land area), while industrial development averaged 0.18 FAR.
Between 2016 and 2021, the cities and the Columbia Valley UGA have
achieved densities greater than planned for residential uses, while the Birch
Bay UGA has not (Exhibit 11). These achieved densities ranged from 4.4 to
11.5 dwelling units per net acre for residential uses in incorporated areas
and averaged one dwelling unit per 3.7 acres for Non-UGA areas. The
unincorporated portions of city UGAs generally lag planned urban densities
for their corresponding cities or did not experience residential development
during the five-year review period. This is likely due to these as-yet
unannexed areas lacking urban zoning and/or infrastructure. These
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 17
JULY 2022, REVISED FEB 2023
unincorporated areas serve as urban growth potential for future growth after
annexation, when city zoning is adopted and public water and sewer
provided.
Four cities have planned densities for commercial development within their
incorporated UGAs -Blaine, Everson, Nooksack, and Sumas (Exhibit 11).
Blaine and Nooksack have achieved densities that are lagging the planned
densities for the 2016-2021 period. Everson exceeded its planned commercial
density, while Sumas did not have any commercial development in the five-
year review period. Whatcom County has not adopted planned densities for
commercial uses in its city UGAs, non-city UGAs, nor its Non-UGA areas.
The same four cities also have planned densities for industrial development
within their incorporated UGAs (Exhibit 11). Blaine is lagging the planned
densities for the 2016-2021 period. Sumas has exceeded its planned
industrial density, while Everson and Nooksack did not have any industrial
development in the five-year review period. Whatcom County has not adopted
planned densities for industrial uses in its city-UGAs, non-city UGAs, nor its
Non-UGA areas.
The UGAs in Whatcom County have estimated net land capacity for
population growth of 73,075 for the remainder of the 20-year planning period
from 2021 to 2036, indicating an estimated population capacity surplus of
34,215 (Exhibit 12).
The UGAs in Whatcom County have estimated net land capacity for
employment growth of 41,057 for the remainder of the 20-year planning
period from 2021 to 2036, indicating an estimated employment capacity
surplus of 16,652 (Exhibit 13).
On a countywide basis, surplus capacity exists to accommodate both
remaining projected population and employment growth for the rest of the
20-year planning period through 2036. In addition, planned residential
densities in the cities are being achieved.
Population & Employment Growth
Data collected for the Review and Evaluation Period from 2016-2021 indicate
that new construction in Whatcom County and the cities accommodated
14,326 people, or about 24% of its 2016-2036 growth projection of 60,565 for
the 20-year planning period (Exhibit 6). About 44% of this growth occurred
in the City of Bellingham and 83% occurred within the urban growth areas
(UGAs) of the County.
The remaining projected population growth for the County from 2021-2036 is
46,240. Of this, the Bellingham UGA is allocated 45%, the Ferndale UGA,
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 18
JULY 2022, REVISED FEB 2023
8%, the Lynden UGA, 8%; and the Blaine UGA, 7%. Approximately 16% of
remaining projected population growth is to be accommodated in non UGA-
areas of the County for the remainder of the 20-year planning period.
Exhibit 6. Population Growth Estimates and Projected Growth, 2016-2036
2016-2036 2021-2036
2016-2021 Population
Population Remaining
UGA Growth Estimate
Growth Population
Projection Growth to
City County Total Accommodate
Bellingham 6,202 78 6,280 27,000 20,720
Birch Bay N/A 389 389 4,593 4,204
Blaine 501 50 551 3,838 3,287
Cherry Point N/A 0 0 0 0
Columbia Valley N/A 271 271 1,170 899
Everson 317 0 317 1,080 763
Ferndale 2,081 8 2,089 5,942 3,853
Lynden 1,685 3 1,688 5,568 3,880
Nooksack 177 0 177 861 684
Sumas 190 0 190 760 570
UGA Total 11,152 799 11,951 50,812 38,861
Non-UGA N/A 2,375 2,375 9,754 7,379
Total 11,152 3,174 14,326 60,566 46,240
Sources: Whatcom County and Cities' Data Reporting Tools, 2022; Community Attributes, Inc.,
2021.
Data collected for the 2016-2021 Review and Evaluation Period indicate that
new construction in Whatcom County and the cities accommodated 5,351
jobs, or about 17% of its 2016-2036 growth projection of 32,179 for the 20-
year planning period (Exhibit 7). Approximately 58% of this growth occurred
within the Bellingham UGA, while most of the remaining employment
growth occurred in the Ferndale, Lynden, and Blaine UGAs. Almost 93%
occurred within the UGAs.
The remaining projected employment growth for the County from 2021-2036
is 26,829. Of this, the Bellingham UGA is allocated 62%; the Ferndale UGA,
9%, the Blaine UGA, 6%, and the Lynden UGA, 5%. Approximately 9% of
remaining projected employment growth is to be accommodated in Non-UGA
areas of the County for the remainder of the 20-year planning period.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
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JULY 2022, REVISED FEB 2023
Exhibit 7. Employment Growth Estimates and Projected Growth, 2016-2036
2016-2036 2021-2036
2016-2021 Employment Employment Remaining
UGA Growth Estimate
Growth Employment
Projection Growth to
City County Total Accommodate
Bellingham 2,613 495 3,108 19,688 16,580
Birch Bay N/ /\ 55 55 474 419
Blaine 245 0 245 1,823 1,578
Cherry Point* N/l\ (141) (141) 735 876
Columbia Valley NIA 11 11 312 301
Everson 13 3 16 523 507
Ferndale 942 59 1,001 3,478 2,477
Lynden 624 0 624 1,876 1,252
Nooksack 8 0 8 100 92
Sumas 65 0 65 387 322
UGA Total 4,510 482 4,992 29,396 24,405
Non-UGA I\J/ A 359 359 2,783 2,424
Total 4,510 841 5,351 32,179 26,829
Sources: Whatcom County and Cities' Data Reporting Tools, 2022; Community Attributes, Inc.,
2021.
* Employment for Cherry Point is estimated through supplemental analysis provided to
Whatcom County by Western Washington University (Employment at Cherry Point, June
2021), as permit data for this UGA do not accurately reflect employment growth trends. Cherry
Point UGA employment declined between 2016 and 2021 because of job losses associated with
the Alcoa (lntalco) shutdown.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 20
JULY 2022, REVISED FEB 2023
Development Activity
The Review and Evaluation Program tracks both residential and
nonresidential development, as well as the distribution of development
between urban and rural areas. This analysis tracks housing production to
compare against planned growth and the necessary growth rates in terms of
housing units to achieve those targets. It also tracks commercial and
industrial land developed, building square footage, and development
expressed as a floor-to-area ratio (FAR -a ratio of built square footage to net
parcel land area).
Residential Development
For the Review and Evaluation Period of April 1, 2016 through March 31,
2021, the cities and the County permitted a total of 6,659 housing units
inside and outside its UGAs (Exhibit 8). Of these units, 84% were permitted
within the UGAs, and 16% were permitted outside the UGAs.
Exhibit 8. Net Housing Units Permitted, Rural and Urban Areas Countywide,
2016-2021
2016* 2017 2018 2019 2020 2021** Year
Unknown
UGAs 851 1,074 946 1,041 1,140 531 33
Area Outside U GAs 135 198 215 238 215 42 0
Total 986 1,272 1,161 1,279 1,355 573 33
UGA Share 86% 84% 81% 81% 84% 93%
Outside U GAs Share 14% 16% 19% 19% 16% 7%
Sources: Whatcom County and Cities, 2022; Community Attributes, Inc., 2021.
* 2016 captures net housing units permitted between April 1, 2016 and December 31, 2016.
** 2021 captures net housing units permitted between January 1, 2021 and March 31, 2021.
Of these new units, 48% were permitted and built in the Bellingham UGA
(3,219 from 2016-2021), while almost 36% were permitted and built in all
other UGAs combined (2,397 units from 2016-2021). The remaining 1,043
units were constructed outside UGAs (Exhibit 9).
On average, the number of net new housing units permitted and built was
1,332 per year for the County as a whole (UGA plus Non-UGA areas) for the
2016-2021 Review and Evaluation Period. With 22,176 additional housing
units needed to accommodate projected population growth through 2036, and
based on the current distribution of single family and multifamily
development and UGA specific occupancy and density assumptions, the cities
and the County will need to increase average annual housing production to
1,478 units per year from 2021-2036. This represents an increase of around
11 % over the 2016-2021 production rate.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 21
JULY 2022, REVISED FEB 2023
Total
5,616
1,043
6,659
84%
16%
Relatively small increases in production rates will be needed for the
Bellingham, Nooksack, and Columbia Valley UGAs. The Birch Bay and
Blaine UGAs will have to substantially increase their housing production
rates to meet their population allocation targets. Specifically, housing
production in the Birch Bay UGA will need to increase from an average of 46
new units per year in 2016-2021 to 164 units per year for the remainder of
the planning period 2021-2036. Housing production in the Blaine UGA will
need to increase from 53 to 105 for the remainder of the planning period
2021-2036.
Exhibit 9. Annual Housing Production Necessary to Accommodate Growth
Allocations by UGA and Non-UGA Areas, 2021-2036
NetNew Average Net Additional Average Net
UGA Units New Units Per Housing Units New Units per
(2016-2021) Year Needed by Year Needed
(2016-2021} 2036 ( 2021-2036}
Bellingham 3,219 644 10,620 708
Birch Bay 228 46 2,462 164
Blaine 263 53 1,569 105
Cherry Point 0 0 0 0
Columbia Valley 106 21 352 23
Everson 108 22 260 17
Ferndale 810 162 1,494 100
Lynden 742 148 1,706 114
Nooksack 59 12 229 15
Sumas 81 16 242 16
UGA Total 5,616 1,123 18,935 1,262
Non-UGA 1,043 209 3,241 216
County Total 6,659 1,332 22,176 1,478
Sources: Whatcom County and Cities, 2022; Community Attributes, Inc., 2022.
Commercial & Industrial Development
For the Review and Evaluation Period (April 1, 2016 through March 31,
2021), a total of 3.9 million square feet was constructed on 1,285 commercial
and industrial acres supporting an estimated 5,351 jobs inside and outside
its urban growth areas (Exhibit 7 and Exhibit 10). UGAs accommodated
94% of the built square footage and 93% of the estimated jobs on
approximately 38% of the developed acres. Non-UGA areas accommodated
approximately 6% of the built square footage and 7% of the jobs on 62% of the
acres. When considering these numbers, it should be noted that some
commercial building in the Non-UGAs occurred on rather large parcels where
large areas of the lot remain undeveloped.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 22
JULY 2022, REVISED FEB 2023
On a countywide basis, commercial development comprised 84% of this
developed acreage for the period 2016-2021, with industrial development
comprising 16%. Overall, commercial development averaged 0.05 FAR, while
industrial development averaged 0.18 FAR. Within UGAs, commercial
development averaged 0.16 FAR, while industrial development averaged 0.20
FAR.
Exhibit 10. Countywide Nonresidential Development by UGA, 2016-2021
Commercial Industrial Total
UGA Net Building FAR Net Building FAR Net Building FAR Acres Sg Ft Acres Sg Ft Acres Sg Ft
Bellingham
City 110.8 l, 174,506 0.24 43.8 466,871 0.24 154.6 1,641,377 0.24
County 16.6 184,246 0.26 5.3 67,200 0.29 21.8 251,446 0.26
UGA Total 127.4 1,358,752 0.24 49.0 534,071 0.25 176.4 1,892,823 0.25
Birch Bay l l.9 30,628 0.06 0.0 0 0.00 l l.9 30,628 0.06
Blaine
City 6.6 116,580 0.41 0.0 0 0.00 6.6 116,580 0.41
County 0.0 0 0.00 0.0 0 0.00 0.0 0 0.00
UGA Total 6.6 116,580 0.41 0.0 0 0.00 6.6 116,580 0.41
Cherry Point 0.0 0 0.00 16.8 80,551 0.11 16.8 80,551 0.11
Columbia Valley 2.7 6,364 0.05 0.0 0 0.00 2.7 6,364 0.05
Everson
City 0.9 10,825 0.26 0.0 0 0.00 0.9 10,825 0.26
County 0.0 0 0.00 16. l 5,400 0.01 16.l 5,400 0.01
UGA Total 0.9 10,825 0.26 16. l 5,400 0.01 17.0 16,225 0.02
Ferndale
City 113.7 425,773 0.09 46.4 393,457 0.19 160.l 819,230 0.12
County 0.0 0 0.00 7.6 70,214 0.21 7.6 70,214 0.21
UGA Total 113.7 425,773 0.09 54.0 463,671 0.20 167.6 889,444 0.12
Lynden
City 37.8 191,276 0.12 35.4 405,818 0.26 73.2 597,094 0.19
County 0.0 0 0.00 0.0 0 0.00 0.0 0 0.00
UGA Total 37.8 191,276 0.12 35.4 405,818 0.26 73.2 597,094 0.19
Nooksack
City 0.8 4,925 0.14 0.0 0 0.00 0.8 4,925 0.14
County 0.0 0 0.00 0.0 0 0.00 0.0 0 0.00
UGA Total 0.8 4,925 0.14 0.0 0 0.00 0.8 4,925 0.14
Sumas
City 0.0 0 0.00 l l.2 60,549 0.12 l l.2 60,549 0.12
County 0.0 0 0.00 0.0 0 0.00 0.0 0 0.00
UGA Total 0.0 0 0.00 l l.2 60,549 0.12 l l.2 60,549 0.12
UGA Total 301.8 2,145,123 0.16 182.4 1,550,060 0.20 484.2 3,695,183 0.18
Non-UGA* 777.9 201,601 0.01 23.l 16,920 0.02 801.0 218,521 0.01
County Total 1,079.7 2,346,724 0.05 205.5 1,566,980 0.18 1,285.2 3,913,704 0.07
Sources: Whatcom County and Cities' Data Reporting Tools, 2022; Community Attributes, Inc., 2021.
* Non-UGA acreage is gross acres, rather than net acres.
WHATCOM COUNTY PAGE 23
BUILDABLE LANDS REPORT JULY 2022, REVISED FEB 2023
Planned and Achieved Densities
The jurisdictions entered permit information into their respective Data
Reporting Tools, which calculated the achieved densities (2016-2021). The
cities all achieved greater-than-planned residential densities as articulated
in their planning and zoning policies and regulations. The cities of
Bellingham, Ferndale, Lynden, and Sumas significantly outperformed their
planned residential densities for the period.
In the corresponding unincorporated portions of UGAs of Bellingham,
Ferndale and Lynden achieved residential densities generally lag planned
densities. The unincorporated portions of the Everson, Nooksack, and Sumas
UGAs did not experience any residential development between 2016 and
2021. This is largely because these as-yet unannexed areas lack urban zoning
and/or infrastructure. The unincorporated areas serve as urban growth
potential for future growth after annexation, when city zoning is adopted and
public water and sewer provided. For non-city UGAs, residential
development in the Columbia Valley UGA exceeded the planned density
while residential development in the Birch Bay UGA did not.
Many cities in Whatcom County do not yet have planned commercial or
industrial densities. However, several cities have such planned densities.
Blaine and Nooksack achieved densities lagged planned densities.
Development in Everson and Sumas exceeded planned densities between
2016 and 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 24
JULY 2022, REVISED FEB 2023
Exhibit 11. Planned and Achieved Densities by Jurisdiction
Residential Commercial Industrial
Planned Achieved Pl d Achieved Planned Achieved
UGA Density ann~ Density . Density Density 2016-2021 Difference Density 2016-2021 Difference Density 2016-2021 Difference
(units/cc) (units/cc) (FAR) (FAR) (FAR) (FAR)
Bellingham
City 7.2 l l.5 4.3 1'I/A 0.22 N/J\ N/A 0.24 N/A
County 6.0 l.3 (4.7) r-1/A 0.26 N/ /\ N/ ;\ 0.29 N/A
Birch Bay 5.0 4.5 (0.5) 1N/ J\ 0.06 N/A N/ J\ 0.00 I'~/ A
Blaine
City 4.3 4.4 0.2 0.80 0.31 (0.49) 0.89 0.30 (0.59)
County 4.0 4.7 0.7 l'1/ J\ 0.00 N/A 1'1/ /\ 0.00 r-1/A
Cherry Point N/ ;\ 0.0 N/A N/A 0.00 N/A GI//\ 0.11 N/A
Columbia Valley 4.0 4.9 0.9 N/A 0.05 N/ ;\ N/A 0.00 GI/ A
Everson
City 4.0 4.8 0.8 0.20 0.26 0.06 0.30 0.00 GI/A
County 4.0 0.0 i'-1/A N/A 0.00 N/A N/ ;\ 0.01 N/A
Ferndale
City 4.0 6.1 2.1 N/A 0.09 N/A N/./\ 0.19 i~/ A
County 6.0 0.3 (5.7) GI/ A 0.00 i'-J/ A N/A 0.21 i~/ /\
Lynden
City 5.0 7.2 2.2 NA 0.12 N/A NA 0.26 N/A
County 6.0 l.7 (4.3) N/ ;\ 0.00 1'1/A N/A 0.00 N/ /\
Nooksack
City 4.4 5.2 0.8 0.25 0.14 (0.11) 0.10 0.00 N/A
County 4.0 0.0 N/A 1'1/A 0.00 GI/A N/A 0.00 i'-1/ A
Sumas
City 4.9 7.5 2.7 0.22 0.00 N//\ 0.11 0.12 0.01
County 4.0 0.0 N;A N/ /\ 0.00 N/A f,JjA 0.00 N//\
Non-UGA Areas N/A 3.7 N//\ N/A 0.01 N/ /\ N/A 0.02 N/A
Sources: Whatcom County and Cities' Data Reporting Tools, 2022; Community Attributes, Inc.,
2022.
Note: An NI A in the Planned Density columns indicates that the jurisdiction does not have an
adopted planned density for the specific development type. An NI A in the Difference columns
indicates that the difference between planned and achieved densities cannot be calculated
because no planned density is available. The achieved density for the Non-UGA Areas is acres
per dwelling unit.
Land Suitable for Development
An analysis of the developable lands inventory by UGA, deducting critical
areas, future public uses, quasi-public uses, infrastructure gaps, and an
assumed market factor, provides an estimate of land capacity for population
and employment growth. Applying densities, occupancy rates, and other
population and employment assumptions, the developable lands inventory
results in an estimate of population and employment capacity to compare to
the remaining population to accommodate.
Development data show that UGAs accommodated population growth of
approximately 11,951 persons for the Review and Evaluation Period of 2016-
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 25
JULY 2022, REVISED FEB 2023
UGA
Bellingham
Birch Bay
Blaine
Cherry Point
2021. The remaining forecast population growth to be accommodated for the
rest of the 20-year planning period ending in 2036 is 38,861 for all UGAs
(Exhibit 6). Based on an analysis of developable residential land capacity for
the UGAs, additional population (housing) growth capacity exists to
accommodate 73,075 for the period -a surplus of 34,215, or 17% beyond what
is necessary (Exhibit 12).
While individual UGA population growth capacity surpluses range from 9%
in Bellingham to 84% in Blaine, Birch Bay has a 10% deficit in capacity.
Exhibit 12. Whatcom County Population Growth Capacity and Allocations
by UGA, 2021-2036
2016-2036 2036 Total 2036 2016-2021 2021-2036 2021-2036 Population Population Population Population Remaining Population Surplus Surplus
Growth Allocation Allocation Growth Population Capacity (Deficit) Percent
Allocation Share Estimate Growth
27,000 123,710 45% 6,280 20,720 31,392 10,672 9%
4,593 12,822 5% 389 4,204 2,950 (1,254) (10%)
3,838 9,585 3% 551 3,287 11,324 8,037 84%
0 43 0% 0 0 0 0 0%
Columbia Valley 1,170 4,448 2% 271 899 2,167 l,268 29%
Everson
Ferndale
Lynden
Nooksack
Sumas
UGA Total
1,080 3,907 1% 317 763 3,634 2,871 73%
5,942 19,591 7% 2,089 3,853 10,786 6,932 35%
5,568 19,275 7% 1,688 3,880 8,467 4,587 24%
861 2,425 1% 177 684 1,283 599 25%
760 2,323 1% 190 570 1,073 503 22%
50,812 198,129 72% 11,951 38,861 73,075 34,215 17%
Sources: Whatcom County and Cities, 2022; Community Attributes, Inc., 2021.
For Non-UGAs (areas outside UGAs), the Whatcom County Comprehensive
Plan's pro-rated population growth allocation for 2016-2036 equates to 9,754
more people (Exhibit 1). Based upon building permits and assumptions in
the Data Reporting Tool, it is estimated that new development in the Non-
UGAs accommodated about 2,375 people between 2016 and 2021. Therefore,
these areas would need to accommodate about 7,379 more people over the
remainder of the planning period from 2021-2036 (Exhibit 6). The County
estimates that land outside UGAs can accommodate in excess of 14,000
additional dwelling units. This is more than enough capacity to
accommodate population growth in these areas.
Both UGAs, which include cities, and Non-UGAs have sufficient capacity to
accommodate projected population growth over the remaining portion of the
planning period through the year 2036. Therefore, there is sufficient suitable
land capacity to accommodate the countywide population projection set forth
in the Whatcom County Comprehensive Plan.
UGAs accommodated estimated employment growth of approximately 4,992
jobs from 2016-2021. The remaining forecast employment growth to be
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 26
JULY 2022, REVISED FEB 2023
UGA
Bellingham
Birch Bay
Blaine
Cherry Point*
accommodated for the rest of the 20-year planning period ending in 2036 is
24,405 for all UGAs (Exhibit 7). Based on an analysis of developable
commercial and industrial land capacity for UGAs, additional employment
growth capacity exists to accommodate 41,057 more jobs for the period -a
surplus of 16,652, or 16% beyond what is necessary (Exhibit 13).
Individual UGA employment growth surpluses ranged from 3% in
Bellingham to 136% in Blaine. No UGA has a deficit in capacity to
accommodate employment growth for the remainder of the planning period
(2021-2036).
Exhibit 13. Whatcom County Employment Growth Capacity and
Allocations by UGA, 2021-2036
2016-2036 2036 2016-2021 2021-2036 2036 Total 2021-2036 Employment Employment Employment Employment Remaining Employment Surplus Surplus
Growth Allocation Allocation Growth Employment Capacity (Deficit) Percent
Allocation Share Estimate Growth
19,688 75,000 62% 3,108 16,580 18,671 2,090 3%
474 1,140 1% 55 419 573 154 13%
1,823 5,159 4% 245 1,578 8,570 6,992 136%
735 2,883 2% (141) 876 2,613 1,737 60%
Columbia Valley 312 444 0% 11 301 420 119 27%
Everson 523 1,312 1% 16 507 1,575 1,068 81%
Ferndale 3,478 9,372 8% 1,001 2,477 3,484 1,007 11%
Lynden 1,876 7,103 6% 624 1,252 4,038 2,786 39%
Nooksack 100 369 0% 8 92 355 263 71%
Sumas 387 l, 145 1% 65 322 758 436 38%
UGA Total 29,396 103,927 86% 4,992 24,405 41,057 16,652 16%
Sources: Whatcom County and Cities, 2022; Community Attributes, Inc., 2021.
*Cherry Point UGA employment estimates were developed by Western Washington University
(Employment at Cherry Point, June 2021). The timeframe for the estimated employment
growth, and employment growth allocation for Cherry Point is 2017-2021 and 2017-2036 to
coordinate with the timeframe for the employment growth estimate. Complete data was not
available for 2016 for the Cherry Point UGA.
Inconsistencies and Reasonable Measures
On a countywide basis, surplus capacity exists to accommodate both
remaining projected population and employment growth for the rest
of the 20-year planning period through 2036. In addition, planned
residential densities in the cities are being achieved.
When planned densities are not being achieved, there is not sufficient
capacity to accommodate remaining projected population or employment
growth, or development patterns are not occurring as planned, Whatcom
County and the cities will need to determine if reasonable measures are
necessary to address the issue.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 27
JULY 2022, REVISED FEB 2023
Reasonable measures should, if necessary, be selected by the jurisdiction
based on the nature of the inconsistency that has occurred. The measures
should be reasonably likely to increase consistency during the succeeding
review and evaluation period. Once selected, reasonable measures must be
adopted, as applicable, into individual County and city comprehensive plans
and/or implementing regulations.
A list of potential reasonable measures that jurisdictions may consider, if
needed, are documented in the Whatcom County Review and Evaluation
Program Methodology, Appendix A. Many of the potential reasonable
measures identified have already been implemented by jurisdictions to
varying degrees to address housing affordability, land supply, and other
concerns. The Jurisdiction Profiles address whether additional reasonable
measures may be needed for individual UGAs.
JURISDICTION PROFILES
This section provides detailed data and analysis on achieved and assumed
future densities, as well as summaries of developable land capacity and
growth capacity, by jurisdiction. Whatcom County contains ten UGAs -seven
city UGAs, and three non-City UGAs (Birch Bay, Cherry Point, and Columbia
Valley) -that are described in this section.
In accordance with RCW 36. 70A.215(3)(e) and the Whatcom County Review
and Evaluation Program Methodology, the Buildable Lands Report will
typically use achieved densities (as measured for the Review and Evaluation
period, 2016-2021) as a basis for the assumed densities for future
development in the UGA over the remaining portion of the current 20-year
planning period (2021-2036). If there is little or no data on achieved
densities, or the achieved densities are clearly not reflective of future
development that is anticipated in the UGA then, based on a review of
achieved densities in comparable (lreas and other analysis, the local
jurisdiction has developed assumptions for future development densities in
the UGA.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 28
JULY 2022, REVISED FEB 2023
1. Bellingham UGA
The Bellingham Urban Growth Area is the
largest in Whatcom County, projected to
encompass 123,710 residents and 75,000
employees by 2036. The UGA has growth
allocations of 27,000 new residents and 19,688
new jobs between 2016 and 2036 (Exhibit 1
and Exhibit 2).
Achieved Growth 2016-2021
Based on permit data collected between 2016
and 2021 and occupancy, persons per
household, and square feet per employee
assumptions, new construction in the
Bellingham UGA accommodated an estimated
6,278 new residents (99% within the City of
Bellingham) and 3,108 new jobs (84% within
the City of Bellingham) (Exhibit 6 and
Exhibit 7).
Bellingham's residential growth over the past
five years has occurred at higher-than-
expected densities achieving an overall density
of 11.5 units per acre. The Whatcom County
Land Capacity Analysis Report referenced in
the 2016 City of Bellingham Comprehensive
plan (Land Use Chapter page 31) assumed
future residential growth would average 7.2
units per acre. The achieved density within
the incorporated portions of the UGA falls
within the planned densities of 6.0 to 24.0
WHATCOM COUNTY
BUILDABLE LANDS REPORT
units per acre adopted in the Whatcom County
Comprehensive Plan for the City of
Bellingham (Exhibit 11).
Development in the unincorporated portions of
the Bellingham UGA achieved a residential
density of 1.3 units per acre (Exhibit 11).
This density lags planned urban densities for
the City of Bellingham and is likely due to
these as-yet unannexed areas lacking city
zoning and complete infrastructure; instead,
the unincorporated areas serve as urban
growth potential for future growth after
annexation, when city zoning is adopted and
public water and sewer provided.
Neither the City of Bellingham or Whatcom
County have adopted planned densities for
commercial or industrial uses. Between 2016
and 2021, incorporated areas of the UGA
achieved a commercial Floor-Area-Ratio (FAR)
of 0.22, and an industrial FAR of 0.24. The
unincorporated areas within the Bellingham
UGA achieved slightly higher FARs of 0.26
and 0.29 for commercial and industrial uses
respectively (Exhibit 11).
PAGE 29
JULY 2022, REVISED FEB 2023
Population Capacity 2021-2036
Based on achieved densities and regulatory
changes adopted since 2016, the forward-
looking evaluation of land suitable for
development that estimates the growth
capacity on remaining buildable lands is
assuming an overall residential density of 11.2
units per acre on vacant, partially used, and
underutilized lands. This aligns well with the
11. 5 units per acre overall achieved density for
residential development from 2016 to 2021.
City of Bellingham planners are assuming
future densities ranging between 0.2 units per
acre and 14.5 units per acre for single-family
zones, depending on the specific zone (Zones in
Bellingham's unincorporated UGA with a
density of 0.2 units per acre or one dwelling
per five acres are located within the Lake
Whatcom Watershed and were adopted by
Whatcom County for the purpose of water
quality protection). Future density
assumptions range between 4.0 and 69. 7 units
per acre for zones allowing multifamily uses
(Exhibit 14).
The results of the analysis show the
Bellingham UGA has estimated net land
capacity for residential development
(population growth) of 752.98 acres (Exhibit
15). When combined with pending projects in
the development pipeline and in approved
WHATCOM COUNTY
BUILDABLE LANDS REPORT
master plans these buildable lands have a
total estimated occupied unit capacity of
15,531 dwelling units. Based on persons per
household assumptions, these dwelling units
can accommodate an estimated 31,392 new
residents indicating an estimated population
capacity surplus of 10,672 people (Exhibit
16).
Housing Needs by Type
The Whatcom County Comprehensive Plan
(Chapter 3-Housing, Chart 3 -Estimated
Dwelling Units Needed, page 3-8) indicates
Bellingham has a need for 5,171 single-family,
9,507 multi-family, and 1,410 other (group
housing) new dwelling units during the 2013-
2036 planning period.
• During the period April 1, 2013 to March
31, 2016 Bellingham completed final
inspections on permits for 372 single-family
and 797 multi-family housing units.
• During the period April 1· 2016 to March
31, 2021 Bellingham completed final
inspections on permits for 794 new single-
family and 2,393 new multi-family housing
units (including 537 student housing and
memory-care group housing units that
would fall under the "other" category in the
County housing needs chart).
PAGE 30
JULY 2022, REVISED FEB 2023
• The forward-looking evaluation of land
suitable for development component of
Bellingham's Buildable Lands Analysis
shows that the City and unincorporated
UGA have an estimated 2021-2036 capacity
for an additional 4,200 single-family and
11,863 multi-family housing units (Exhibit
16).
Combining the 2013-2016 and 2016-2021 built
totals with the estimated 2021-2036 capacity
results in an overall capacity of 5,366 single-
family and 15,053 multi-family housing units
plus 537 completed units in the "other"
category. The combined single-family capacity
is slightly higher than the estimated need
(5,366 -5,171 = 195 housing units or 4%). The
combined multi-family totals exceed the
estimated need by 58% or 5,546 housing units
(15,053 -9,507). And the combined overall total
(single-family, multi-family, and other) exceeds
the estimated need by 30% or 4,868 housing
units (20,956 -16,088). While the estimated
single-family housing capacity is minimally
adequate, the overall land capacity is sufficient
to accommodate the dwelling units needed in
the planning period as established in the
Whatcom County Comprehensive Plan (Chapter
3-Housing, Chart 3).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
Employment Capacity 2021-2036
Based on achieved densities and regulatory
changes adopted since 2016, City of
Bellingham planners are assuming future
commercial F ARs ranging between 0.25 and
3.50, depending on the specific zone. Assumed
future industrial F ARs range between 0.25
and 0.40 (Exhibit 17).
The results of the evaluation of land suitable
for development show the Bellingham UGA
has estimated net land capacity for
employment growth of 377.6 acres (Exhibit
18). When combined with pending projects in
the development pipeline and in approved
master plans these buildable lands have a
total estimated occupied commercial and
industrial capacity of 9.8 million square feet.
Based on square feet per employee
assumptions, this employment space can
accommodate an estimated 18,671 jobs
indicating an estimated employment capacity
surplus of 2,091 jobs (Exhibit 19).
Analysis of Comprehensive Plan
Objectives and Reasonable Measures
Over the past five years Bellingham has
worked hard to implement the goals adopted
in the 2016 Comprehensive Plan. Through
that process, the City has already taken many
steps that would be considered reasonable
PAGE 31
JULY 2022, REVISED FEB 2023
measures (many of which are expressly
identified in Appendix B of the Buildable
Lands Guidelines) including, but not limited
to:
• Adopting affordable housing incentives
including transportation, park, and school
impact fees and system development charge
waivers up to 80%, reducing parking
requirements, expanding the Multi-Family
Tax Exemption zone, and designating a
Federal Opportunity Zone;
• Adopting a rental registration and safety
inspection program;
• Adopting a short-term rental registration
and monitoring program;
• Working with Whatcom County to update
the Urban Fringe Subarea plan in 2017-
2018;
• Amending the City subdivision ordinance
in 2018 to improve the land division
process, allow for more flexible design, and .
up to a 50% density bonus when including
smaller infill housing forms;
• Adopting a new Accessory Dwelling Unit
(ADU) ordinance in 2018 allowing ADUs in
all residential zones;
WHATCOM COUNTY
BUILDABLE LANDS REPORT
• Extending in 2018 the tax levy for the
Bellingham Home Fund for an additional
ten years. This levy provides about $4
million per year and is combined with
about $3 million per year from the
Affordable Housing Sales Tax, and about
$2.5 million per year in Federal CDBG and
HOME funds. The combined annual total
of over $9 million is used to provide rental
assistance, homebuyer down payment
assistance, home preservation, human
services, and rental housing production for
low-income households in Bellingham.
About $5 million per year of these funds
are directed to production of affordable
rental housing. The City partnering with
non-profit developers has leveraged local
funds at a 1:8 ratio ($ 1 of City funds for
every $8 of partner funds) to build and
maintain over 1,400 housing units and
hundreds more are in the development
pipeline;
• Amending the Infill Toolkit standards in
2021, eliminating redundant fees, reducing
parking requirements, and simplifying and
improving the process for permitting and
building "missing middle" housing forms;
• Encouraging reductions in off-street
surface parking;
PAGE 32
JULY 2022, REVISED FEB 2023
• Adopting revisions to the multi-family
zoning code in 2021 to include a simpler
ranged zoning system and minim um
density standards to ensure infill goals are
met;
• Updating the interlocal agreement with
Whatcom County concerning planning,
annexation, and development within UGAs;
• Adopting a manufactured home park
protective overlay zone and enhanced
resident notification requirements in 2022;
• Adopting streamlined urban village design
review regulations in 2022;
• Working with partners in the development
community to identify and overcome
regulatory barriers to bringing more
affordable renter and owner-oriented
housing online sooner;
• Utilizing development agreements and
other tools to assist land-owners with
successful redevelopment of challenging
sites in urban villages and other priority
areas;
• Taking an active role with our local
representatives in the current state
legislative session as they consider a wide
WHATCOM COUNTY
BUILDABLE LANDS REPORT
array of bills addressing housing
affordability and supply;
• Addressing the recent, dramatic increase in
families with children experiencing
homelessness by designating space in new
affordable housing projects, investing in
pro-active prevention programs, and
working with community partners to plan,
fund, and build new family housing
solutions; and
• Creation of Urban Holding Zones (UGA
Reserves).
Despite these reasonable measures the City
has already taken, and the analysis showing
that Bellingham is meeting or exceeding the
development density assumptions in the
county-wide planning policies and the 2016
comprehensive plan, housing affordability and
supply remain critical concerns.
According to the 2018 Bellingham
Consolidated Plan, 43% of Bellingham citizens
pay more than 30% of their income towards
housing expenses (they are "cost burdened"),
and nearly one-half of those households pay
more than 40% of their income towards
housing expenses (they are "severely cost
burdened"). Furthermore, housing in
Bellingham is of particular importance given
PAGE 33
JULY 2022, REVISED FEB 2023
the City's status as the employment center of
Whatcom County.
Of particular note, the capacity for housing
offering ownership opportunities is very
limited. As seen in Exhibit 16, while 64% of
Bellingham's developable residential land is
zoned for single-family development, it
accounts for only 26% of estimated future
housing production. Whereas the 36% of land
zoned for multi-family development accounts
for 7 4% of estimated future production. Also,
of concern related to homeownership
opportunities, while about 70% of
Bellingham's recent housing production has
been multi-family, the number of units sold as
condominiums has been negligible.
Based on these persistent concerns adopting
additional reasonable measures in Bellingham
is warranted. These measures could include,
but are not limited to:
• Evaluating Bellingham's existing single-
family zoning code and (similar to the 2021
multi-family code update) considering
adoption of the following:
o A standardized and simplified range
of densities consistent with those in
the 2016 Comprehensive Plan;
o Minimum densities;
WHATCOM COUNTY
BUILDABLE LANDS REPORT
o Increasing densities where
appropriate; and
o Allowing Infill Toolkit development
and "middle" housing forms in all
single-family zones;
• Evaluating regulatory barriers to
condominium-style development;
• 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;
• Considering enacting incentive-based
inclusionary zoning ordinances for new
housing developments;
• Exploring incentives for limited equity
cooperatives and other models that provide
an affordable path to homeownership (e.g.
land trusts);
• Revisiting existing regulations and
neighborhood plans to evaluate and, if
appropriate, remove regulatory
PAGE 34
JULY 2022, REVISED FEB 2023
impediments to otherwise-developable
land;
• Considering code amendments allowing a
wider variety of Form Based Housing;
• Considering restoring and updating the
Master Plan Ordinance;As mandated by
HB1220, conducting a comprehensive
Housing Needs Assessment to identify and
quantify the housing needs for all economic
segments of the community;
• Using the Housing Needs Assessment to
develop policies to plan for and
accommodate a variety of housing types
affordable to all economic segments; and
• Ensuring timely updates to capital facility
plans identify future infrastructure needs,
funding mechanisms, and implementation
plans to provide urban services to prioritize
housing development necessary to
accommodate forecast growth.
Analysis by Zoning Category
The following section provides details for each
of Bellingham's general zoning categories of
the residential densities assumed in 2016,
those achieved 2016 to 2021, and those used in
the forward-looking evaluation of land suitable
for development that estimates the growth
WHATCOM COUNTY
BUILDABLE LANDS REPORT
capacity on remaining buildable lands from
2021 to 2036.
Single family residential zones in Bellingham
accommodated 566 single family and 321 multi
family units for a total of 886 units and an
overall achieved density of 5.3 units per acre
compared to an assumed density of 4. 7 units
per acre. There are 19 unique single family
zones, of which 15 had growth over the past
five years. Nine experienced higher than
expected levels of development accommodating
160% of the growth assumed for them. Six
zones fell short accommodating about 90% of
assumed growth. Overall single family zones
accommodated 114% of assumed growth.
Multi family residential zones accommodated
748 multi family and 149 single family units
for a total of 897 units and an overall achieved
density of 22.9 units per acre compared to an
assumed density of 17.7 units per acre. There
are 34 unique multi family zones, of which 17
had growth over the past five years. Nine
experienced higher than expected levels of
development accommodating 263% of the
growth assumed for them. Eight zones fell
short accommodating about 91% of assumed
growth. Overall multi family zones
accommodated 130% of assumed growth.
Commercial zones allowing and encouraging
residential uses accommodated 671 multi
PAGE 35
JULY 2022, REVISED FEB 2023
family units for an achieved density of 20. 7
units per acre compared to an assumed
density of 17.8 units per acre. There are seven
unique commercial zones, of which two had
residential growth over the past five years.
Both zones experienced higher than expected
levels of development accommodating 116% of
the growth assumed for them. For commercial
zones allowing and encouraging residential
uses the analysis continues the use of 2,500
square feet per multi family unit (Municipal
Code does not specify a density) as a realistic
value given the densities achieved in recent
projects in these zones.
Commercial/Industrial/Residential Multi zones
accommodated 154 single family and 93 multi
family units for an overall achieved density of
13.1 units per acre compared to an assumed
density of 7.5 units per acre. There are two
unique Com/Ind/RM zones, one of which
experienced residential growth over the past
five years. This zone experienced higher than
expected levels of development accommodating
176% of the growth assumed for it.
Urban Village zones accommodated 5 single
family and 524 multi family units for an
overall achieved density of 58. 9 units per acre
compared to an assumed density of 41.4 units
per acre. There are 13 unique urban village
zones, 11 of which experienced residential
growth over the past five years. Ten
WHATCOM COUNTY
BUILDABLE LANDS REPORT
experienced higher than expected levels of
development accommodating 175% of the
growth assumed for them. One zone fell short
accommodating 89% of assumed growth.
Overall urban village zones accommodated
142% of assumed growth. For urban village
zones the analysis uses density values keyed
to the floor area ratios (F ARs) specified in the
Municipal Code for each urban village land
use area. A table included in the evaluation of
land suitable for development worksheet
documents the assumptions that model
allocation of building square footage to non-
residential uses, parking, hallway/mechanical
spaces, and residential units to translate each
FAR value into a specific units per acre
density. These model assumptions are based
on densities achieved by recent projects in
each of the urban villages.
Background Details
The following section highlights details
specific to Bellingham's application of the
Whatcom County Review and Evaluation
Program Methodology in the analysis of
buildable lands. It includes the rates used to
estimate population and employment,
discussions of regulatory changes since 2016
that affect development capacity,
infrastructure and future public uses,
environmental constraints, market factors,
PAGE 36
JULY 2022, REVISED FEB 2023
and lands in Washington State ownership
excluded from the capacity analysis.
Population and Employment Assumptions
The housing occupancy rate and persons per
household assumptions for the Bellingham
UGA are based on current values from the
Washington State Office of Financial
Management (OFM) and are specific to
Bellingham. The employment occupancy rate
and jobs per square foot assumptions are
based on Washington State Employment
Security and Whatcom County Assessor's data
as explained in Section 4.1 of the Whatcom
County Review and Evaluation Program
Methodology. The values are as follows:
• 97.5% Single Family occupancy rate
• 96.4% Multifamily occupancy rate
• 95.0% Commercial and Industrial
occupancy rate
• 2.499 persons per Single Family
household
• 1.850 persons per Multifamily
household
• 440 and 660 respectively Commercial
and Industrial square feet per employee
WHATCOM COUNTY
BUILDABLE LANDS REPORT
The Bellingham UGA has an estimated 20,720
population and 16,580 employment growth
remaining to accommodate between 2021 and
2036 (Exhibit 6 and Exhibit 7).
Regulatory Changes
Since adoption of the 2016 Comprehensive
Plan Bellingham has approved many
regulatory changes that impact either the
amount of land available for development, or
the densities and mix of uses allowed on
buildable lands. These changes are
documented in detail in the Data Reporting
Tool worksheet. The most significant changes
include a rezone for Cordata Park removing 20
acres of mixed-use land from the buildable
land supply (estimated capacity of 150 jobs
and 100 housing units); approval of two
annexations activating development of
infrastructure and allowing development on
249 acres; approval of Title 23 (subdivision
ordinance) streamlining the plat process and
allowing a 50% density bonus for single-family
cluster zones when at least 50% of units are
Infill Toolkit forms; approval of an Accessory
Dwelling Unit (ADU) ordinance allowing and
encouraging ADUs in Bellingham's
neighborhoods; approval of an updated
residential multi-family (RM) development
code establishing a simplified tiered density
system and minimum densities (increasing
Bellingham's overall development capacity by
PAGE 37
JULY 2022, REVISED FEB 2023
an estimated 20%); and Phase I of an update
to the Infill Toolkit regulations streamlining
and clarifying the development of missing-
middle housing forms.
Infrastructure and Future Public Uses
Bellingham has identified areas within the
City and unincorporated UGA that are within
the service area for urban sewer utilities but
may not achieve full buildout until after 2036
due to reliance upon developer-provided
portions of these future utility systems. The
areas identified based on mapping from the
2016 Bellingham Wastewater Conveyance
Plan were also determined to be areas where
development of other related infrastructure
like roads and municipal water would likely
depend on some level of developer
participation. These areas were assigned
estimated near-term, mid-term, long-term, or
longer-term time frames and received
associated percentage deductions of their
developable area. The deductions total
approximately 112 acres and do not preclude
all development but acknowledge that full
buildout may not occur until after 2036. This
jurisdiction profile includes a map of the
Bellingham UGA illustrating the land areas
associated with these deductions.
Deductions of buildable land related to roads,
and water, sewer, and storm utilities are
WHATCOM COUNTY
BUILDABLE LANDS REPORT
accounted for in the methodology through an
infrastructure deduction on vacant, partially-
used, and underutilized land of between 5%
and 24%. The recent 17-acre land acquisition
by the Bellingham School District for a future
elementary school is also removed from the
buildable land supply. Future development on
the three college campuses in Bellingham is
accounted for in the "master planned" category
of buildable land based on the adopted
Institutional Master Plan (IMP) for each
institution. Deductions for future public uses
were made from the developable land supply
based primarily on land acquisition needs
identified in the Bellingham 2020 Park,
Recreation, and Open Space (PRO) Plan. A
total of 104 acres was deducted from
developable vacant land for these purposes
(see 2020 PRO Plan, Table 4.6.1 "Proposed
Park System Additions -City & UGA").
PAGE 38
JULY 2022, REVISED FEB 2023
WHATCOM COUNTY
BUILDABLE LANDS REPORT
FERNDALE
·",}9
infrastructure Gap deductions applied to areas in the City and unincorporated UGA
that wt11 rely on owners/developers of private property to help fund and/or build road
and utdity.infrastructure to enabie development Ar<'-as WPff evaluatE'd by City staff
intorm€d by adopted infrastructure pians a11d grouped into (ategories based on
estimated development horizons. The'>e d(0 duction~ are not intendf'd to reflect !and
eliminated from the bui!dable supply, rather they are intended to r€'flect pot~ntia!
delays in avaii,}bi!ity of dev0lopm1?nt capacity due to thP timP r(1 quirf!d to rnmp!Ptl:'
road and utility infrastructure syst<?rr.s.
Key
Estimated Potential
Delays &
Deductions
Short-Term 10%
Mid-Term 20%
Long-Term 30%
-Longer-Term 50%
City Limits
Urban Growth
Area 11
LOY.l'
\\Jhot(t;.,"l
t
fl..fLr7 Miles
0 0.5 1
PAGE 39
JULY 2022, REVISED FEB 2023
Environmental Constraints
Deductions for environmental constraints
(critical areas) were made to all developable
land including ALL residential, commercial,
and industrial zones. Deductions were based
on the best-available data in the City's GIS
system following criteria set out in Bellingham
Municipal Code (BMC) Chapter 16.55.
Wetlands were buffered with 150-foot buffers
based on a composite of all mapped wetland
delineations, and wetland reconnaissance
inventories from 2015, 2003, and 1992 (NWI
data from the 1980's was not used due to the
relatively complete coverage by more
recent/accurate studies). In addition, a staff-
generated potential wetlands layer was
created from color-infrared imagery and
LiDAR data to fill gaps across properties
where access limitations prevent on-the-
ground mapping of wetland systems. Other
critical areas layers used include steep slopes,
FEMA floodways and floodplains (2019 data),
and regulated shorelines and stream/riparian
corridors. Shorelines were buffered using
adopted Shoreline Master Program (SMP)
development setbacks designated for each
reach. Stream/riparian buffers were based on
distances specified for each reach in BMC
Table 16.55.500(A).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
Market Factors
The Review and Evaluation Program
Methodology includes a market factor
deduction to account for land not likely to
develop during the remainder of the 2021 to
2036 planning period. The criteria considered
while developing the market factor(s) for
Bellingham's buildable lands analysis include
examination of improvement to total value
ratios, transaction and conversion history, a
property owner survey, targeted outreach to
specific owners and developers, and
comparative studies of market factors from
other buildable lands jurisdictions. The
market factors developed for Bellingham's
analysis are arranged in a tiered system
corresponding to the complexities involved in
development and the relative return or benefit
to property owners and developers. Vacant
land usually presents the fewest challenges to
development, partially-utilized land is
typically more complex to develop due to
existing ongoing uses on the property during
development, and underutilized land is often
the most-complex due to the requisite re-
location or change of non-conforming uses
accompanying redevelopment. The relative
return or benefit to property owners and
developers is closely related to the zoned
density or intensity of developable land. Land
zoned for higher density or intensity uses will
PAGE 40
JULY 2022, REVISED FEB 2023
'
usually provide a bigger return or benefit to
owners and developers making it more likely
they will develop sooner. And land zoned for
lower density or intensity uses will usually
provide a lower return or benefit to owners
making it less likely to develop sooner. The
market factors assigned to each tier are as
follows: vacant higher density/intensity =
20%, vacant lower density/intensity = 25%,
partially-utilized higher density/intensity=
25%, partially-utilized lower density/intensity
= 30%, underutilized higher density/intensity
= 30%, underutilized lower density/intensity =
35%. A technical memo explaining the details
of Bellingham's market factor analysis can be
found here
https://maps.cob.org/resources/images/pcd/Bell
inghamMarketFactor TechnicalMemo Septl0t
h2021.pdf
State-Owned Lands
The 2016 Bellingham Comprehensive Plan
Land Capacity Analysis included some
development capacity on approximately 266
acres of land owned by Washington State.
This land located in one block west of
Bellingham International Airport, and in three
blocks lying north of and parallel to the Mt
Baker Highway has been excluded from the
developable land supply in this analysis.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 41
JULY 2022, REVISED FEB 2023
Residential Development
Exhibit 14. Residential Development, Achieved and Assumed Densities, City of Bellingham, 2016-2021
Development Acres Dwelling Achieved Density Assumed
Zoning Category Type Developed Units Density (Units/Acre)
(Units/Acre)
Min Max
Single Family Single Family 138.2 586 4.24 0.20 14.52
Multifamily 29.9 321 10.74 7.26 7.26
Multifamily Single Family 20.1 149 7.40 N/A N/A
Multifamily 32.2 748 23.25 4.04 43.56
Mixed-Use Single Family 28.5 169 5.93 6.00 6.00
Multifamily 3.3 93 28.24 6.00 17.42
Urban Village Single Family 0.5 5 9.96 8.71 8.71
Multifamily 8.7 524 59.93 8.71 69.70
Commercial Multifamily 20.6 671 32.55 12.10 48.40
Institutional Multifamily 1.5 76 50.97 N/A N/A
Industrial Multifamily 0.2 6.19 N/A N/A
Sources: City of Bellingham, 2022; Community Attributes Inc., 2021.
Note: "Density Assumed" is the assumed density for evaluation of land suitable for development by zone. City of Bellingham zoning
districts are grouped into seven collapsed, generalized categories.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 42
JULY 2022, REVISED FEB 2023
Exhibit 15. Residential Land Supply, Bellingham UGA, 2021-2036
UGA Total Single Multifamily Mixed-Urban Commercial Institutional Industrial Public Airport
Family Use Village Operations
Vacant Land
Gross Acres 1,291.19 802.97 322.52 119.16 2.94 41.41 2.19 0.00 0.00 0.00
Critical Areas 688.47 426.50 183.11 48.51 0.52 27.81 2.02 0.00 0.00 0.00
Future Public Uses 63.66 39.59 15.90 5.87 0.14 2.04 0.11 0.00 0.00 0.00
Infrastructure Gaps 55.48 41.84 8.74 4.89 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 24.18 14.75 5.74 2.99 0.11 0.58 0.00 0.00 0.00 0.00
Infrastructure Deduction 97.79 70.81 11.48 14.22 0.11 1.16 0.01 0.00 0.00 0.00
Market Factor 75.72 45.29 19.51 8.53 0.41 1.96 0.01 0.00 0.00 0.00
Net Acres 285.91 164.20 78.04 34.14 1.64 7.86 0.05 0.00 0.00 0.00
Partially-Used Land
Gross Acres 1,378.76 845.05 141.46 321.62 53.25 17.39 0.00 0.00 0.00 0.00
Critical Areas 567.27 421.40 49.59 84.38 4.89 7.00 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 23.84 8.42 0.40 15.01 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 39.38 20.76 4.57 11.11 2.42 0.52 0.00 0.00 0.00 0.00
Infrastructure Deduction 165.59 99.65 9.15 53.34 2.42 1.04 0.00 0.00 0.00 0.00
Market Factor 149.18 77.22 19.44 39.45 10.88 2.21 0.00 0.00 0.00 0.00
Net Acres 433.50 217.59 58.31 118.34 32.64 6.62 0.00 0.00 0.00 0.00
Underutilized Land
Gross Acres 69.84 0.00 25.64 1.15 29.40 9.92 3.72 0.00 0.00 0.00
Critical Areas 14.96 0.00 8.29 0.02 0.81 2.65 3.18 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 2.72 0.00 0.87 0.06 1.43 0.36 0.00 0.00 0.00 0.00
Infrastructure Deduction 4.22 0.00 1.73 0.27 1.43 0.73 0.05 0.00 0.00 0.00
Market Factor 14.38 0.00 4.42 0.24 7.72 1.85 0.15 0.00 0.00 0.00
Net Acres 33.56 0.00 10.32 0.56 18.01 4.32 0.34 0.00 0.00 0.00
Sources: City of Bellingham, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
Note: City of Bellingham zoning districts are grouped into nine collapsed, generalized categories.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 43
JULY 2022, REVISED FEB 2023
Exhibit 16. Developable Residential Land Capacity, Bellingham UGA, 2021-2036
UGA Single-Multi-Mixed-Urban Commercial Institutional Industrial Public Airport
family family Use Village Operations
Net Developable Residential Acres
(Vacant, PU, UU) 752.98 381.79 146.67 153.03 52.29 18.80 0.39 0.00 0.00 0.00
Single Family Developable Acres 485.56 374.47 110.00 1.09
Assumed Single Family Density (units/acre)
Subtotal Single Family Unit Capacity 2,994 2,325 660 9
Existing Single Family Units 1,646 419 370 314 366 28 146 2
Pending Single Family Units 1,872 1,164 505 123 14 65
Master Planned Single Family Units 75 58 17
Subtotal: Net Single Family Unit Capacity 4,200 3,070 505 527 15 65 17
Potential Occupied Single Family Units 4,095 2,993 492 514 15 63 16
Single Family Population Capacity 10,233 7.480 1,230 1,285 37 158 41 2
Multifamily Developable Acres 267:42 7.32 146.67 43.03 51.20 18.80 0.39
Assumed Multifamily Density (units/acre)
Subtotal Multifamily Unit Capacity 5,544 65 2,791 420 1,842 411 15
Existing Multifamily Units 122 27 25 20 20 10 20
Pending Multifamily Units 4,903 124 927 758 1,477 1,617
Master Planned Multifamily Units 1,492 413 760 200 119
Subtotal: Net Multifamily Unit Capacity 11,863 189 3,693 1,571 4,059 2,018 215 119
Potential Occupied Multifamily Units 11,436 182 3,560 1,514 3,913 1,945 207 115
Multifamily Population Capacity 21,159 338 6,586 2,801 7,239 3,599 384 212
Net Dwelling Unit Capacity 16,063 3,259 4,198 2,098 4,074 2,083 215 135
Potential Occupied Dwelling Units 15,531 3,175 4,052 2,028 3,928 2,009 207 131
Population Capacity 31,392 7,818 7,816 4,086 7,276 3,757 384 253 2
Remaining Population Growth to
Accommodate (2021-2036) 20,720
Population Capacity Surplus (Deficit) 10,672
WHATCOM COUNTY PAGE 44
BUILDABLE LANDS REPORT JULY 2022, REVISED FEB 2023
Sources: City of Bellingham, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
Note: Bellingham UGA zoning districts are grouped into nine collapsed, generalized categories.
Commercial and Industrial Development
Exhibit 17. Nonresidential Development, Achieved and Assumed Densities, City of Bellingham, 2016-2021
Zoning Designation Development Acres Built Square Achieved Assumed Density (FAR)
Type Developed Feet Density (FAR) Min Max
Single Family Commercial 7.6 22,776 0.07 N/A N/A
Multifamily Commercial 1.4 17,966 0.28 N/A N/A
Mixed-Use Commercial 21.7 230,519 0.24 0.40 0.40
Industrial 0.0 0 0.00 0.40 0.40
Urban Village Commercial 3.1 81,619 0.61 0.40 3.50
Industrial 2.4 58,710 0.57 0.40 0.40
Commercial Commercial 10.8 189,313 0.40 0.40 2.50
Institutional Commercial 12.3 188,774 0.35 0.40 0.40
Industrial Commercial 12.0 155,697 0.30 N/,A N/A
Industrial 45.2 466,052 0.24 0.25 0.25
Public Commercial 50.2 323,042 0.15 0.40 0.40
Industrial 1.4 9,309 0.15 N/A N/A
Airport Operations Commercial 8.2 149,046 0.42 0.25 0.25
Industrial 0.0 0 0.00 0.25 0.25
Sources: City of Bellingham, 2022; Community Attributes Inc., 2021.
Note: Assumed Density is the assumed density for evaluation of land suitable for development by zone. Bellingham UGA zoning districts
are grouped into nine collapsed, generalized categories.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 45
JULY 2022, REVISED FEB 2023
Exhibit 18. Developable Nonresidential Land Supply, Bellingham UGA, 2021-2036
UGA Total Single Multifamil Mixed-Urban Commercial Institutional Industrial Public Airport
Family Use Village oeerations y
Vacant Land
Gross Acres 819.40 0.00 O.Ql 24.40 3.38 4 l.61
Critical Areas 562.80 0.00 0.05 10.32 0.23 27.81
Future Public Uses 40.40 0.00 0.00 l.20 0.17 2.05
Infrastructure Gaps 22.55 0.00 0.00 0.54 0.00 0.00
Quasi-Public Use Deduction l.35 0.00 0.00 0.62 0.15 0.59
Infrastructure Deduction 20.13 0.00 0.00 2.15 0.15 l.18
Market Factor 34.43 0.00 0.00 l.91 0.54 2.00
Net Acres 137.73 0.00 0.01 7.66 2.15 7.99
Partially-Used Land
Gross Acres 359.15 0.00 0.24 35.74 25.13 17.52
Critical Areas 146.67 0.00 0.09 9.38 2.92 7.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 10.20 0.00 0.00 l.67 0.00 0.00
Quasi-Public Use Deduction 2.88 0.00 0.01 l.23 l.11 0.53
Infrastructure Deduction 22.57 0.00 0.02 5.93 l. l l l.05
Market Factor 44.21 0.00 0.03 4.38 5.00 2.23
Net Acres 132.62 0.00 0.10 13.15 14.99 6.70
Underutilized Land
Gross Acres 444.57 0.00 0.03 0.13 3.74 10.70
Critical Areas 273.85 0.00 0.00 0.00 0.13 2.65
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 0.59 0.00 0.00 0.01 0.18 0.40
Infrastructure Deduction 16.91 0.00 0.00 O.Q3 0.18 0.81
Market Factor 45.97 0.00 0.01 O.Q3 0.97 2.05
Net Acres 107.25 0.00 0.02 0.06 2.27 4.79
Sources: City of Bellingham, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
Note: Bellingham UGA zoning districts are grouped into nine collapsed, generalized categories.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
6.58 743.27 0.08 0.00
6.07 518.24 0.08 0.00
0.32 36.64 0.00 0.00
0.00 22.01 0.00 0.00
0.00 0.00 0.00 0.00
0.02 16.64 0.00 0.00
0.03 29.95 0.00 0.00
0.14 119.79 0.00 0.00
0.00 279.05 0.00 l.48
0.00 126.77 0.00 0.52
0.00 0.00 0.00 0.00
0.00 8.53 0.00 0.00
0.00 0.00 0.00 0.00
0.00 14.38 0.00 0.10
0.00 32.34 0.00 0.22
0.00 97.03 0.00 0.65
3.72 426.24 0.00 0.00
3.18 267.88 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
0.05 15.84 0.00 0.00
0.15 42.76 0.00 0.00
0.34 99.77 0.00 0.00
PAGE 46
JULY 2022, REVISED FEB 2023
Exhibit 19. Developable Nonresidential Land Capacity, Bellingham UGA, 2021-2036
UGA Multi-Single-Mixed-Urban Commercial Institutional Industrial Public Airport
fami!)' familt Use Village O~erations
Net Developable Employment Acres
(Vacant, PU, UU) 377.60 0.00 0.13 20.87 19.41 19.48
Commercial Developable Acres 54.06 0.13 18.89 14.75 19.48
Subtotal: Commercial Capacity (SF) 2,330,253 2,203 329,224 1,400,226 586,709
Existing Commercial Space (SF) 716,719 4,287 5,423 422,903 224,113
Pending Commercial Space (SF) 1,095,040 78,100 6,933 26,239 140,669 268,607
Master Planned Commercial Space (SF) 2,528,209 210,603 617,200 -
Subtotal: Net Commercial Capacity (SF) 5,346,344 78,100 9,136 566,066 1,775,050 631,203
Potential Occupied Commercial Space (SF) 5,079,027 74,195 8,679 537,763 1,686,297 599,643
Commercial Employment Capacity 11,542 168 20 1,222 3,832 1,362
Industrial Developable Acres 323.54 1.97 4.66
Subtotal: Industrial Capacity (SF) 3,566,662 34,347 81,132
Existing Industrial Space (SF) 871,274 79,196 26,762 5,496 135,082 81,437
Pending Industrial Space (SF) 1,016,738 28,382 45,000
Master Planned Industrial Space (SF) 981,055 77,213 376,000
Subtotal: Net Industrial Capacity (SF) 4,952,113 111,560 416,473 45,000
Potential Occupied Industrial Space (SF) 4,704,507 l 05,982 395,649 42,750
Industrial Employment Capacity 7,129 161 599 65
Net Commercial & Industrial Capacity (SF) 10,298,457 78,100 9,136 677,626 2,191,523 676,203
Potential Occupied Commercial & Industrial
Capacity (SF) 9,783,534 74,195 8,679 643,745 2,081,947 642,393
Empls,yment Capacity 18,671 168 20 1,383 4,431 1,427
Remaining Employment Growth to
Accommodate (2021-2036) 16,580
Emplo~ment Capacity Surplus (Deficit} 2,091
Sources: City of Bellingham, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
Note: Bellingham UGA zoning districts are grouped into nine collapsed, generalized categories.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
0.48 316.59 0.00 0.65
0.48 0.32
8,373 3,518
59,993
11,813 463,912 98,767
1,294,730 39,397 266,279 l 00,000
1,314,916 503,309 365,046 103,518
1,249,170 478,144 346,793 98,342
2,839 1,087 788 224
316.59 0.32
-3,447,665 3,518
543,301
912,841 30,515
172,841 355,000
-3,990,046 30,515 358,518
-3,790,544 28,989 340,592
5,743 44 516
1,314,916 4,493,355 395,561 462,036
1,249,170 4,268,688 375,783 438,934
2,839 6,830 832 740
PAGE 47
JULY 2022, REVISED FEB 2023
2. Birch Bay UGA
The Birch Bay Urban Growth Area is one of
three Non-City UGAs in Whatcom County.
The UGA has a projected total allocation of
12,822 residents and 1,140 jobs by 2036. The
UGA has a projected growth allocation of
4,593 new residents and 4 7 4 new jobs between
2016 and 2036 (Exhibit 1 and Exhibit 2).
Achieved Growth 2016-2021
Based on permit data collected between 2016
and 2021, occupancy, persons per household
and square feet per employee assumptions,
new construction in the Birch Bay UGA
accommodated an estimated 389 new residents
and 55 new jobs over this five-year period
(Exhibit 6 and Exhibit 7).
The Birch Bay UGA achieved an overall
residential density of 4.5 units per net acre
between 2016 and 2021. This is below the 5.0
to 10.0 units per net acre planned in the
Whatcom County Comprehensive Plan
(Exhibit 11).
The Whatcom County Comprehensive Plan
does not have adopted planned densities for
commercial or industrial uses. Between 2016
and 2021, the UGA has achieved a commercial
FAR of 0.06. The Commercial FAR is based
upon a limited number of commercial building
WHATCOM COUNTY
BUILDABLE LANDS REPORT
permits (eight) issued between April 1, 2016
and March 31, 2021. Six of the eight building
permits were in commercial zones (the other
two were in residential zones). Five of the six
permits in commercial zones were for
commercial storage buildings (the other was
for a covered patio). The UGA did not have
industrial development between 2016 and
2021 (Exhibit 11).
Population and Employment Assumptions
Occupancy rate and population and
employment assumptions for estimating future
growth capacity in the Birch Bay UGA are:
• 75.0% Single Family occupancy rate
• 51.0% Multifamily occupancy rate
• 95.0% Commercial and Industrial
occupancy rate
• 2.38 Single Family persons per
household
• 2.22 Multifamily persons per household
• 532 Commercial square feet per
employee
The Birch Bay UGA is characterized by a mix
of single family and multifamily residences, as
well as historically high seasonal housing.
There are also a number of businesses in the
UGA.
PAGE 48
JULY 2022, REVISED FEB 2023
Population Capacity 2021-2036
The Birch Bay UGA will need to accommodate
4,204 more residents and 419 more jobs
between 2021 and 2036 under current
planning assumptions (Exhibit 6 and Exhibit
7).
Based on achieved densities between 2016 and
2021 and other planning assumptions,
Whatcom County is assuming future densities
ranging between 4.4 unit~ per acre and 10.0
units per acre for single family development,
depending on the specific zone. Future density
assumptions range between 5.9 and 17.0 units
per acre for multifamily development (Exhibit
20). Density assumptions for the Suitable
Land Tool, which estimates future
development capacity, are further described
below (achieved density is based on building
permits issued between 2016 and 2021):
Urban Residential (UR4) -The achieved net
density from the Data Reporting Tool for the
UR4 zone is 4.4 units/acre for single family
development. This net density is used in the
Suitable Land Tool to estimate capacity to
accommodate development in the future.
Urban Residential Medium Density (URM6) -
For single family, the achieved net density
from the Data Reporting Tool for the URM6
zone is 3.3 units/acre. However, this is likely
WHATCOM COUNTY
BUILDABLE LANDS REPORT
not reflective of future development. While
there is currently not a minimum density in
the URM6, the County Comp Plan encourages
development at 5-10 units per acre in the
Birch Bay UGA. For multi-family, the
achieved net density from the Data Reporting
Tool for the URM6 zone is 5.9 units/acre. This
density is used in the Suitable Land Tool for
both single family and multi-family land.
Urban Residential Medium Density (URM24)
-The URM24 zone did not experience any
residential development from 2016-2021 (see
Data Reporting Tool). The URM24 zone has a
minimum net density of 10 dwelling units/acre
and a maximum gross density of 24
dwellings/acre (WCC 20.22.252). A density of
10 units per net acre is used for single family
land and 17 units per net acre for multi-family
land in the Suitable Land Tool.
Resort Commercial (RC) -For single family,
the achieved net density from the Data
Reporting Tool for the RC zone is 8. 3
units/acre. This density is used in the Suitable
Land Tool for future single family
development. The RC zone did not experience
any multi-family residential development from
2016-2021 (see Data Reporting Tool). The RC
zone allows multi-family zoning at a maximum
gross density of 22 units per acre (WCC
20.64.262). A density of 17 units per net acre
PAGE 49
JULY 2022, REVISED FEB 2023
for multi-family development is used in the
Suitable Land Tool (same as the URM24 zone).
General Commercial (GC) -The GC zone did
not experience any residential development
from 2016-2021 (see Data Reporting Tool).
Therefore, the achieved density for the RC
zone (8.3 units/net acre) is used in the
Suitable Land Tool for single family land in
the GC zone. The GC zone allows multi-family
zoning at a maximum density of 18 units per
acre (WCC 20.62.066). A density of 17 units
per net acre is used for multi-family
development in the Suitable Land Tool (same
as URM24 and RC zones).
The Birch Bay UGA has estimated net land
capacity for population growth of about 297
acres (Exhibit 21), with a total estimated
potential occupied unit capacity of 1,257
dwelling units. Based on persons per
household assumptions, the Birch Bay UGA
has an estimated population capacity of 2,950,
indicating an estimated population capacity
deficit of 1,254 for the 2021-2036 time period
(Exhibit 22).
Housing Needs by Type
The Whatcom County Comprehensive Plan
(Chapter 3-Housing, Chart 3 -Estimated
Dwelling Units Needed, page 3-8) indicates
that the Birch Bay UGA has a need for 3,106
WHATCOM COUNTY
BUILDABLE LANDS REPORT
new single-family dwelling units during the
2013-2036 planning period (the
Comprehensive Plan does not estimate
multifamily housing needs for Birch Bay). The
calculation for Chart 3 in the Whatcom County
Comprehensive Plan included building activity
from 2013. Therefore, the analysis below
includes permit data from April 1, 2013, even
though the planning period for this Buildable
Lands Report is from 2016.
• Between April 1, 2013 and March 31, 2021,
Whatcom County performed final
inspections on 304 single-family and 39
multi-family units in the Birch Bay UGA.
Comparing units built and the needs
indicated on Chart 3, the Birch Bay UGA
needs an additional 2,802 single-family
units between 2021 and 2036.
• The Birch Bay UGA has an estimated 2021-
2036 capacity for 1,333 single-family and
504 multi-family housing units (Exhibit
22).
The capacity to accommodate single family
residential housing in the Birch Bay UGA is
not sufficient to accommodate the single
family dwelling units needed in the planning
period as established in the Whatcom County
Comprehensive Plan (Chapter 3-Housing,
Chart 3).
PAGE 50
JULY 2022, REVISED FEB 2023
Employment Capacity 2021-2036
Whatcom County is using an average of the
small city F ARs for future commercial
development, since there are limited data on
achieved densities in the Birch Bay UGA
(Exhibit 23).
The Birch Bay UGA has estimated net land
capacity for employment growth of 44.3 acres
(Exhibit 24), with a total estimated potential
occupied commercial capacity of 305,008
square feet. Based on square feet per employee
assumptions, the Birch Bay UGA has an
estimated employment capacity of 573,
indicating an estimated employment capacity
surplus of 154 for the 2021-2036 time period
(Exhibit 25).
Regulatory Changes
The County has evaluated development
regulations adopted in the review period (April
1, 2016 -March 31, 2021). Only Ordinance
2019-005 could prevent assigned densities
from being achieved or impact the quantity of
land suitable for development in the
remainder of the 20-year planning period
(2021-2036). In an e-mail of October 6, 2021, a
representative of the Whatcom County Public
Works River & Flood Division stated:
WHATCOM COUNTY
BUILDABLE LANDS REPORT
... the 2019 revisions were done mainly to
reflect updated flood study and the most
recent just adopted in 2021 was for
compliance with building freeboard
required for CRS [Community Rating
System] credit, nothing to do with 'supply of
land'. That being said, the flood study did
change the Base Flood Elevations and
floodplain boundaries in those areas and
the FEMA Biological Opinion does restrict
density in the floodplain ... "
A September 30, 2021 River & Flood Division
memo attached to the e-mail states that the
Special Flood Hazard Area is:
... designated Critical Area and/or Habitat
Conservation Area (HCA) per WCC Title-
16. As such, creating additional 'buildable'
lots within a Critical Area or HCA may be
prohibited. For further information
reference WCC 16.16.420 -Frequently
Flooded Areas ...
Pursuant to the Whatcom County Review and
Evaluation Program Methodology, Whatcom
County deducted floodplains from the
buildable land supply.
PAGE 51
JULY 2022, REVISED FEB 2023
Infrastructure Gaps
Whatcom County has reviewed capital facility
plans and/or consulted with service providers.
Based upon these actions, the County has not
identified any infrastructure gaps that would
prevent service providers from supplying
planned capital facilities to developable land
in the Birch Bay UGA within the planning
period (2021-2036).
Analysis of Comprehensive Plan
Objectives and Reasonable Measures
Residential development in the Birch Bay
UGA between 2016 and 2021 has occurred at
an overall net density less than anticipated in
the Whatcom County Comprehensive Plan.
Additionally, there is not enough capacity in
the Birch Bay UGA, with current density
assumptions, to accommodate the projected
residential growth in the remaining portion of
the planning period (between 2021 and 2036).
The single family unit capacity in the Birch
Bay UGA is insufficient to accommodate the
estimated dwelling units needed between 2021
and 2036. Therefore, reasonable measures are
appropriate.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
Whatcom County Comprehensive Plan Goal 2P
states:
. .. The County should approve new
residential developments at overall average
net densities as shown below, while
respecting unique characteristics of each
community:
Birch Bay -five to ten units per net
acre ...
The overall achieved residential density in the
Birch Bay UGA was 4.5 units per net acre
during the review period (2016-2021). Lots in
the Birch Bay UGA have historically been
created at densities that the land owner or
developer chose. The UR4 zone has a
minimum net density of 4 dwelling units/acre,
but this is below the Comprehensive Plan goal
of five to ten units per net acre. Several other
zones in the UGA do not have minimum
density requirements. Increasing residential
density, including density in zones that allow
single family dwellings, would provide
additional capacity for growth within the
UGA. Therefore, adjustments to the zoning
code are appropriate to better implement the
Comprehensive Plan.
The Growth Management Act indicates that
one of the purposes of the review and
evaluation program is to:
PAGE 52
JULY 2022, REVISED FEB 2023
Identify reasonable measures, other than
adjusting urban growth areas, that will be
taken to comply with the requirements of
this chapter. Reasonable measures are
those actions necessary to reduce the
differences between growth and
development assumptions and targets
contained in the countywide planning
policies and the county and city
comprehensive plans with actual
development patterns ... (RCW
36. 70A.215(1)(b)).
The Whatcom County Review and Evaluation
Program Methodology (February 10, 2022)
identifies minimum density requirements and
maximum lot sizes as potential reasonable
measures (Appendix A). Specifically, the
Methodology states:
Zoning ordinances can establish minimum
and maximum densities in each zone to
ensure that development occurs as
envisioned for the community (page 46).
The State Department of Commerce Housing
Memorandum: Issues Affecting Housing
Availability and Affordability (June 2019)
identifies "Reasonable Measures as Tools for
Increasing Housing Availability and
Affordability" including:
WHATCOM COUNTY
BUILDABLE LANDS REPORT
Allow or require small lots (5,000 square
feet or less) for single-family neighborhoods
within UGAs. Small lots limit sprawl,
contribute to the more efficient use of land,
and promote densities that can support
transit. Small lots also provide expanded
housing ownership opportunities to broader
income ranges and provide additional
variety to available housing types (page
116).
In October 2021, Whatcom County adopted a
reasonable measure increasing the allowed
density in the UR4 zone in the Birch Bay
UGA, if public water and sewer are available
and density credits are purchased, from 4
dwellings/acre to 5 dwellings per acre
(Ordinance 2021-059). This ordinance also
reduced the conventional minimum lot size for
residential development in the UR4 zone in
the Birch Bay UGA from 8,000 square feet to
4,500 square feet when public water and
sewer are available. In November 2017,
Whatcom County adopted an ordinance
allowing increased density for single family
development in the RC zone through the
planned unit development process, if density
credits are purchased (Ordinance 2017-062).
Other potential reasonable measures the
County may consider for the Birch Bay UGA
include:
PAGE 53
JULY 2022, REVISED FEB 2023
• Increasing the minimum net residential
density and/or adopting maximum lot
size in the UR4 zone (WCC 20.20);
• Adopting minimum net residential
density requirements and/or maximum
lot size in the URM6 zone (WCC 20.22);
• Adopting minimum net residential
density requirements and/or maximum
lot size in the GC zone (WCC 20.62);
and/or
• Adopting minimum net residential
density requirements and/or maximum
lot size in the RC zone (WCC 20.64).
The UR4, URM6, GC, and RC zones all allow
single family dwelling units.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 54
JULY 2022, REVISED FEB 2023
Residential Development
Exhibit 20. Residential Development, Achieved and Assumed Densities, Birch Bay UGA, 2016-2021
Zoning Development Acres Dwelling Achieved Density
Designation Type Developed Units Density Assumed
{Units/Acre) {Units/Acre)
UR4 Single Family 38.3 168 4.39 4.39
URM6 Single Family 7.6 25 3.31 5.89
M ult if amily 4.6 27 5.89 5.89
URM24 Single Family N/A N/A N/A 10.00
Multifamily N/A N/A N/A 17.00
RC Single Family 1.4 12 8.32 8.32
M ult if amily N/A N/A N/A 17.00
GC Single Family N/A N/A N/A 8.32
Multifamily N/A N/A N/A 17.00
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
Note: "Density Assumed" is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 55
JULY 2022, REVISED FEB 2023
Exhibit 21. Residential Land Supply, Birch Bay UGA, 2021-2036
UGA Total UR4
Vacant Land
Gross Acres 816.99 471.94
Critical Areas 450.86 277.61
Future Public Uses 15.80 14.00
Infrastructure Gaps 0.00 0.00
Quasi-Public Use Deduction 17.52 9.02
Infrastructure Deduction 74.76 41.48
Market Factor 43.87 22.07
Net Acres 214.18 107.77
Partially-Used Land
Gross Acres 232.69 109.12
Critical Areas 84.62 48.97
Future Public Uses 0.00 0.00
Infrastructure Gaps 0.00 0.00
Quasi-Public Use Deduction 7.40 3.01
Infrastructure Deduction 30.86 13.84
Market Factor 29.65 11.69
Net Acres 80.16 31.62
Underutilized Land
Gross Acres 4.16 0.00
Critical Areas 0.28 0.00
Future Public Uses 0.00 0.00
Infrastructure Gaps 0.00 0.00
Quasi-Public Use Deduction 0.19 0.00
Infrastructure Deduction 0.48 0.00
Market Factor 0.87 0.00
Net Acres 2.34 0.00
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
URM6 URM24
146.62 98.96
43.69 69.51
0.00 0.00
0.00 0.00
5.15 1.47
22.13 5.30
12.86 3.85
62.79 18.82
64.66 0.00
14.24 0.00
0.00 0.00
0.00 0.00
2.52 0.00
10.84 0.00
10.01 0.00
27.06 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
RC GC NC
62.65 36.82 0.00
37.86 22.19 0.00
0.00 l.80 0.00
0.00 0.00 0.00
1.24 0.64 0.00
4.26 1.59 0.00
3.28 l.80 0.00
16.01 8.80 0.00
52.63 6.28 0.00
20.73 0.69 0.00
0.00 0.00 0.00
0.00 0.00 0.00
1.59 0.28 0.00
5.49 0.69 0.00
6.70 1.25 0.00
18.11 3.37 0.00
0.00 4.16 0.00
0.00 0.28 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.19 0.00
0.00 0.48 0.00
0.00 0.87 0.00
0.00 2.34 0.00
PAGE 56
JULY 2022, REVISED FEB 2023
Exhibit 22. Developable Residential Land Capacity, Birch Bay UGA, 2021-2036
UGA UR4
Net Developable Residential Acres
(Vacant, PU, UU) 296.68 139.39
Single Family Developable Acres 249.48 139.39
Assumed Single Family Density (units/acre) 4
Subtotal Single Family Unit Capacity 1,358 612
Existing Single Family Units 188 67
Pending Single Family Units 145
Master Planned Single Family Units
Subtotal: Net Single Family Unit Capacity 1,333 545
Potential Occupied Single Family Units 1,000 409
Single Family Population Capacity 2,380 973
Multifamily Developable Acres 47.20
Assumed Multifamily Density (units/acre)
Subtotal Multifamily Unit Capacity 652
Existing Multifamily Units 148
Pending Multifamily Units
Master Planned Multifamily Units
Subtotal: Net Multifamily Unit Capacity 504
Potential Occupied Multifamily Units 257
Multifamily Population Capacity 570
Net Dwelling Unit Capacity 1,837 545
Potential Occupied Dwelling Units 1,257 409
Population Capacity 2,950 973
Remaining Population Growth to
Accommodate (2021-2036) 4,204
Population Capacity Surplus (Deficit) (1,254)
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
URM6 URM24
89.85 18.82
76.37 9.41
6 lO
450 94
95
145
500 94
375 71
893 168
13.48 9.41
6 17
79 160
35
44 160
22 82
50 181
544 254
397 152
943 349
RC GC NC
34.12 14.51 0.00
17.06 7.25
8 8
142 60
4 4 18
138 56
104 42
246 100
17.06 7.25
17 17
290 123
113
177 123
90 63
200 139
315 179
194 105
446 239
PAGE 57
JULY 2022, REVISED FEB 2023
Commercial and Industrial Development
Exhibit 23. Nonresidential Development, Achieved and Assumed Densities, Birch Bay UGA, 2016-2021
Zoning Development Acres Built Square Achieved Assumed
Designation Tyee Develoeed Feet Density (FAR) Density (FAR)
UR4 Commercial 7.1 3,780 0.01 N/A
RC Commercial 0.6 368 0.01 0.18
GC Commercial 4.1 26,480 0.15 0.18
NC Commercial N/A N/A N/A 0.18
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
Note: Assumed Density is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 58
JULY 2022, REVISED FEB 2023
Exhibit 24. Developable Nonresidential Land Supply, Birch Bay UGA, 2021-2036
UGA Total UR4
Vacant Land
Gross Acres 103.67 0.00
Critical Areas 64.19 0.00
Future Public Uses 4.20 0.00
Infrastructure Gaps 0.00 0.00
Quasi-Public Use Deduction 1.76 0.00
Infrastructure Deduction 4.44 0.00
Market Factor 4.94 0.00
Net Acres 24.13 0.00
Partially-Used Land
Gross Acres 20.50 0.00
Critical Areas 3.91 0.00
Future Public Uses 0.00 0.00
Infrastructure Gaps 0.00 0.00
Quasi-Public Use Deduction 0.83 0.00
Infrastructure Deduction 2.23 0.00
Market Factor 3.65 0.00
Net Acres 9.88 0.00
Underutilized Land
Gross Acres 17.52 0.00
Critical Areas 0.64 0.00
Future Public Uses 0.00 0.00
Infrastructure Gaps 0.00 0.00
Quasi-Public Use Deduction 0.84 0.00
Infrastructure Deduction 1.91 0.00
Market Factor 3.81 0.00
Net Acres 10.31 0.00
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
URM6
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
URM24
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
RC GC NC
6.96 85.91 10.80
4.21 51.77 8.21
0.00 4.20 0.00
0.00 0.00 0.00
0.14 1.50 0.13
0.47 3.71 0.26
0.36 4.20 0.37
1.78 20.52 1.82
5.85 14.65 0.00
2.30 1.60 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.18 0.65 0.00
0.61 1.62 0.00
0.74 2.91 0.00
2.01 7.87 0.00
0.00 9.70 7.82
0.00 0.64 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.45 0.39
0.00 1.12 0.78
0.00 2.02 1.79
0.00 5.46 4.85
PAGE 59
JULY 2022, REVISED FEB 2023
Exhibit 25. Developable Nonresidential Land Capacity, Birch Bay UGA, 2021-2036
UGA UR4
Net Developable Employment Acres
(Vacant, PU, UU) 44.32 0.00
Commercial Developable Acres 44.32
Assumed Commercial Density (FAR)
Subtotal: Commercial Capacity (SF) 355,214
Existing Commercial Space (SF) 70,779 3,848
Pending Commercial Space (SF) 19,776
Master Planned Commercial Space (SF)
Subtotal: Net Commercial Capacity (SF) 321,061
Potential Occupied Commercial Space (SF) 305,008
Commercial Employment Capacity 573
Industrial Developable Acres
Assumed Industrial Density (FAR)
Subtotal: Industrial Capacity (SF)
Existing Industrial Space (SF) 43,012 2,402
Pending Industrial Space (SF)
Master Planned Industrial Space (SF)
Subtotal: Net Industrial Capacity (SF)
Potential Occupied Industrial Space (SF)
Industrial Employment Capacity
Net Commercial & Industrial Capacity (SF) 321,061
Potential Occupied Commercial & Industrial 305,008
Employment Capacity 573
Remaining Employment Growth to
Accommodate (2021-2036) 419
Employment Capacity Surplus (Deficit) 154
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
URM6 URM24
0.00 0.00
7,663
6,768
RC GC NC
3.79 33.85 6.68
3.79 33.85 6.68
0.2 0.2 0.2
30,387 271,322 53,505
35,726 21,742 1,800
19,776
269,356 51,705
255,888 49,120
481 92
756 33,086
269,356 51,705
255,888 49,120
481 92
PAGE 60
JULY 2022, REVISED FEB 2023
3. Blaine UGA
The Blaine Urban Growth Area is projected to
encompass 9,585 residents and 5,159
employees by 2036. The UGA has a projected
growth allocation of 3,838 population and
1,823 employment between 2016 and 2036
(Exhibit 1 and Exhibit 2).
Achieved Growth 2016-2021
Based on permit data collected between 2016
and 2021 and occupancy and persons per
household and square feet per employee
assumptions, the Blaine UGA grew by an
estimated 551 population (91 % within the City
of Blaine) and 245 employment (100% within
the City of Blaine) (Exhibit 6 and Exhibit 7).
Between 2016 and 2021, the City of Blaine
achieved densities greater than planned for
residential uses, 4.4 units per acre achieved
compared to 4.25 average across single family
residential zones adopted by the City of
Blaine. The achieved density within the
incorporated portions of the UGA also fall
within the planned densities of 4.0 to 6.0 units
per acre adopted in the Whatcom County
Comprehensive Plan for the City of Blaine
(Exhibit 11).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
The unincorporated portions of the Blaine
UGA have an achieved residential density of
4. 7 units per acre, matching the densities
achieved within incorporated portions of the
UGA (Exhibit 11).
The City of Blaine has not adopted F ARs.
However, for purposes of the Data Reporting
Tool, Blaine developed F ARs based on the
bulk, dimensional, and performance standards
defined in municipal code for non-residential
zones. The City of Blaine developed planned
F ARs for commercial zones averaging 0.80.
Across all commercial development between
2016-2021, the achieved FAR is 0.31. No
commercial development occurred during the
period in unincorporated areas of the UGA.
The average planned FAR for industrial zones
is 0.89 for the City of Blaine. Between 2016
and 2021, the achieved FAR is 0.30. No
industrial development occurred in the
unincorporated portions of the UGA. Whatcom
County has not adopted planned densities for
commercial or industrial development
(Exhibit 11).
PAGE 61
JULY 2022, REVISED FEB 2023
Population and Employment Assumptions
Specific occupancy rate and population and
employment density assumptions for the
Blaine UGA are:
• 87.8% Single Family occupancy rate
• 86.9% Multifamily occupancy rate
• 95.0% Commercial and Industrial
occupancy rate
• 2.4 79 Single Family persons per
household
• 2.009 Multifamily persons per
household
• 531 and 739 respectively Commercial
and Industrial square feet per employee
The Blaine UGA has an estimated 3,287
population and 1,578 employment growth
remaining to accommodate between 2021 and
2036 (Exhibit 6 and Exhibit 7).
Population Capacity 2021-2036
Based on achieved densities between 2016 and
2021 and planning assumptions, City of Blaine
planners are assuming future densities
ranging between 3.0 units per acre and 20.0
units per acre for single family residential,
WHATCOM COUNTY
BUILDABLE LANDS REPORT
depending on the specific zone. Future density
assumptions range between 4.0 and 24.0 units
per acre for multifamily zones (Exhibit 26).
The Blaine UGA has estimated net land
capacity for population growth of 684.97 acres
(Exhibit 27), with a total estimated potential
occupied unit capacity of 4,857 dwelling units.
Based on persons per household assumptions,
the Blaine UGA has an estimated population
capacity of 11,324, indicating an estimated
population capacity surplus of 8,037 (Exhibit
28).
Housing Needs by Type
The Whatcom County Comprehensive Plan
(Chapter 3-Housing, Chart 3 -Estimated
Dwelling Units Needed, page 3-8) indicates
that Blaine has a need for 1,548 single-family
and 678 multi-family new dwelling units
during the 2013-2036 planning period. The
calculation for Chart 3 in the Whatcom County
Comprehensive Plan included building activity
from 2013. Therefore, the analysis below
includes permit data from April 1, 2013, even
though the planning period for this Buildable
Lands Report is from 2016.
• Between April 1, 2013 and March 31, 2021,
Blaine issued building permits for 343
single-family/mobile home units, 5
accessory dwelling units, and multi-family
PAGE 62
JULY 2022, REVISED FEB 2023
units 179 (this includes duplexes).
Comparing units built and the needs
indicated on Chart 3, Blaine needs an
additional 1,205 single-family/mobile home
units and 499 multi-family units between
2021 and 2036.
• The City and unincorporated UGA have an
estimated 2021-2036 net capacity for 3,794
single-family and 1,756 multi-family
housing units.
These capacities are sufficient to accommodate
the dwelling unit types needed in the planning
period as established in the Whatcom County
Comprehensive Plan (Chapter 3-Housing,
Chart 3).
Employment Capacity 2021-2036
Based on achieved densities between 2016 and
2021 and planning assumptions, City of Blaine
planners are assuming future commercial
FARs ranging between 0.60 and 1.00,
depending on the specific zone. Assumed
future industrial FARs range between 0. 75
and 1.00 (Exhibit 29).
The Blaine UGA has estimated net land
capacity for employment growth of 165. 76
acres (Exhibit 30), with a total estimated
potential occupied commercial and industrial
capacity of 5.38 million square feet. Based on
WHATCOM COUNTY
BUILDABLE LANDS REPORT
square feet per employee assumptions, the
Blaine UGA has an estimated employment
capacity of 8,570, indicating an estimated
employment capacity surplus of 6,992
(Exhibit 31).
Regulatory Changes
Subsequent to the adoption of the 2016
Comprehensive Plan and through April of
2021, the City of Blaine adopted regulatory
changes that either impacted the amount of
land available for development or modified the
densities and mix of uses allowed on buildable
lands. These changes are listed in the Data
Reporting Tool worksheet. In summary, those
updates include the following:
• Updates to the City's Central Business
District zoning designation that allow it
to function as an urban village.
Examples include zero-lot line setbacks,
multi-use and multi-family
development, and higher allowable
impervious surfaces.
• Adoption of a multi-family tax
exemption (MFTE) to encourage the
construction of affordable, multi-family
housing.
• Updates to the Wharf District Master
Plan to permit additional space for
PAGE 63
JULY 2022, REVISED FEB 2023
marine commercial and industrial
development.
As of the issuance of this report, the City has
additionally adopted updates to allow
work/live units in the Manufacturing zone,
and modified the Highway Commercial "C"
zone to permit a greater range of land uses.
The City in early 2022 also adopted legislation
to identify the Hearing Examiner as the
hearing body for quasi-judicial decisions,
ensuring a more predictable and legally sound
process for land use decisions. The City will
be updating the Critical Areas Ordinance in
2023.
Infrastructure Gaps
Blaine has identified a lack of capacity for
sewer service in East Blaine, however the City
of Blaine Capital Improvement Plan for
Wastewater Utility: 2022-2027 anticipates
needed capacity being restored pursuant to the
funded "G Street Sewer Improvement -East
Blaine Pipe Capacity" project. Subsequent to
the improvements being completed in 2022,
the City will be able to supply this planned
wastewater capital facilities to developable
land in the eastern Blaine UGA within the
planning period (2021-2036). Additional sewer
upgrades under I-5 are identified in the 2022-
2027 CIP. The City of Blaine has identified
WHATCOM COUNTY
BUILDABLE LANDS REPORT
potential constraints to water availability and
capacity. The City has contracted with a
consultant to both identify existing capacity
and propose recommendations to increase that
capacity. As of the writing of this report, the
City has determined that if needed, it will
consider updates to the 2021 Comprehensive
Water System Plan and Capital Facilities Plan
to plan and budget for the increased capacity,
and therefore the planned densities in the
City's Comprehensive Plan will be realized.
Analysis of Comprehensive Plan
Objectives and Reasonable Measures
The City of Blaine has determined that growth
targets and assumptions for residential
development are being met. Therefore, an
analysis of comprehensive plan residential
development targets, assumptions, and
objectives is not deemed necessary during the
reporting cycle.
No inconsistencies between planned and
actual residential growth have been identified
in the Blaine UGA. Therefore, reasonable
measures are not required under RCW
36. 70A.215.
The City of Blaine has identified that there
are inconsistencies between planned and
actual commercial, industrial, and
manufacturing growth in the Blaine UGA.
PAGE 64
JULY 2022, REVISED FEB 2023
Potential reasonable measures may include
the following:
• Updates to the Binding Site Plans
requirements. Blaine should consider
adopting updates that require the
installation of public and private
infrastructure as a condition of final
binding site plan approval. Binding
site plan expiration dates should be
modified to align with the timelines for
plats.
• Updates the allowed uses in the
Manufacturing zoning districts. Blaine
should consider adopting updates that
would expand allowed uses in the
manufacturing zone, subject to
appropriate performance standards.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 65
JULY 2022, REVISED FEB 2023
Residential Development
Exhibit 26. Residential Development, Achieved and Assumed Densities, City of Blaine, 2016-2021
Development Acres Dwelling Achieved Density
Zoning Designation Type Developed Units Density Assumed
(Units/Acre} (Units/Acre}
PR Single Family 3.3 17 5.09 4.00
Multifamily N/ ,\/A 4.00
RL Single Family 9.6 54 5.62 6.00
SF-l Single Family l.O 4 4.09 6.00
SF-2 Single Family 2.3 14 6.19 6.00
PC Single Family 0.2 5.42 N/A
RH Single Family \/A N/.A_ 20.00
Multifamily 0.5 2 3.72 24.00
RM Single Family 2.4 14 5.82 6.00
Multifamily 2.6 28 10.61 12.00
R/O Single Family i'~/ A, ;v,i 6.00
Multifamily N/A. \i : 24.00
RPR Single Family 21.0 72 3.42 3.00
CB G-36 Multifamily N/ /\ N //, ! .; r\ 20.00
CB G-48 Multifamily I' ,'\ 20.00
CB-M Multifamily r0./A 20.00
CB M-48 Multifamily NIA N//:.... 20.00
CB M-60 Multifamily N/A ,'-1/A 20.00
CB-T Multifamily ~✓/ A N/i\ 20.00
CB TP-60 Multifamily A. N/A 20.00
CB WV-36 Multifamily N/A ['\j//\ 20.00
HCA Multifamily !~/A N/A 20.00
HCb Multifamily t\/ 1-\ N/A N/A
HCc Multifamily N/ A. N/A 20.00
HCd Multifamily r✓/ A N/A 20.00
Mpr Single Family 6.4 36 5.60 5.00
Multifamily 3.3 18 5.40 12.00
Sources: City of Blaine, 2022; Community Attributes Inc., 2021.
Note: "Density Assumed" is the assumed density for evaluation of land suitable for development by zone. NOTE Assumed densities differ
from achieved density
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 66
JULY 2022, REVISED FEB 2023
Exhibit 27. Residential Land Supply, Blaine UGA, 2021-2036
UGA Total CB-M CB-T HCA Ma Mb Mpr PC PR RL RM R/O RPR SF-1
Vocont Lond
Gross Acres 818.01 0.00 0.00 0.00 0.00 0.00 0.00 7.74 368.53 109.17 38.43 54.74 216.18 5.18
Critical Areas 229.19 0.00 0.00 0.00 0.00 0.00 0.00 5.65 48.30 47.05 20.83 49.74 49.74 0.52
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 29.44 0.00 0.00 0.00 0.00 0.00 0.00 0.10 16.01 3.11 0.88 0.25 8.32 0.23
Infrastructure Deduction 29.44 0.00 0.00 0.00 0.00 0.00 0.00 0.10 16.01 3.11 0.88 0.25 8.32 0.23
Market Factor 79.49 0.00 0.00 0.00 0.00 0.00 0.00 0.28 43.23 8.39 2.38 0.68 22.47 0.63
Net Acres 450.45 0.00 0.00 0.00 0.00 0.00 0.00 1.60 244.98 47.52 13.47 3.83 127.33 3.56
Partially-Used Land
Gross Acres 428.70 0.00 0.00 0.00 0.00 0.00 0.00 3.80 181.35 213.60 9.27 1.40 9.68 0.48
Critical Areas 86.61 0.00 0.00 0.00 0.00 0.00 0.00 0.58 14.41 68.67 2.33 0.00 0.03 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 17.10 0.00 0.00 0.00 0.00 0.00 0.00 0.16 8.35 7.25 0.35 0.07 0.48 0.02
Infrastructure Deduction 17.10 0.00 0.00 0.00 0.00 0.00 0.00 0.16 8.35 7.25 0.35 0.07 0.48 0.02
Market Factor 76.97 0.00 0.00 0.00 0.00 0.00 0.00 0.72 37.56 32.61 1.56 0.32 2.17 0.11
Net Acres 230.91 0.00 0.00 0.00 0.00 0.00 0.00 2.17 112.68 97.83 4.69 0.95 6.51 0.33
Underutilized Land
Gross Acres 5.57 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.40 2.55 0.00 0.00
Critical Areas 0.21 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 0.27 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.13 0.00 0.00
Infrastructure Deduction 0.27 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.13 0.00 0.00
Market Factor 1.20 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.09 0.57 0.00 0.00
Net Acres 3.61 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.27 1.72 0.00 0.00
Sources: City of Blaine, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
SF-2
3.77
0.30
0.00
0.00
0.17
0.17
0.47
2.65
5.18
0.00
0.00
0.00
0.26
0.26
1.16
3.49
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
CB TP-CB M-CB M-CB G-CB WV-HCc HCd RH 60
2.21
0.68
0.00
0.00
0.08
0.08
0.21
1.17
0.45
0.31
0.00
0.00
0.01
0.01
0.03
0.09
0.21
0.00
0.00
0.00
0.01
0.01
0.05
0.14
60 48 36 36
0.31 0.97 2.13 6.00 1.43 0.63 0.52
0.27 0.23 0.10 5.26 0.00 0.00 0.52
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.04 0.10 0.04 0.07 0.03 0.00
0.00 0.04 0.10 0.04 0.07 0.03 0.00
0.01 0.10 0.27 0.10 0.19 0.08 0.00
0.03 0.57 1.55 0.56 1.09 0.48 0.00
0.00 0.71 0.48 0.36 1.01 0.09 0.34
0.00 0.03 0.00 0.01 0.00 0.00 0.24
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.03 0.02 0.02 0.05 0.00 0.01
0.00 0.03 0.02 0.02 0.05 0.00 0.01
0.00 0.15 0.11 0.08 0.23 0.02 0.02
0.00 0.46 0.32 0.23 0.68 0.06 0.07
0.16 0.42 0.00 0.00 0.68 0.56 0.00
0.16 0.00 0.00 0.00 0.06 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.02 0.00 0.00 0.03 0.03 0.00
0.00 0.02 0.00 0.00 0.03 0.03 0.00
0.00 0.09 0.00 0.00 0.14 0.13 0.00
0.00 0.28 0.00 0.00 0.42 0.38 0.00
PAGE 67
JULY 2022, REVISED FEB 2023
CBG-
48
0.07
0.00
0.00
0.00
0.00
0.00
0.01
0.05
0.49
0.00
0.00
0.00
0.02
0.02
0.11
0.33
0.59
0.00
0.00
0.00
0.03
0.03
0.13
0.40
Exhibit 28. Developable Residential Land Capacity, Blaine UGA, 2021-2036
UGA CB-M CB-T HCA Ma Mb Mpr PC PR RL RM R/O RPR
Net Developable Residential Acres
(Vacant, PU, UU) 684.97 0.00 0.00 0.00 0.00 0.00 0.00 3.77 357.66 145.36 18.42 6.49 133.84
Single Family Developable Acres 546.67 282.37 145.36 -3.25 105.66
Assumed Single Family Density (units/acre) 5 4 6 6 6 3
Subtotal Single Family Unit Capacity 2,397 1,129 872 19 317
Existing Single Family Units 232 28 2 11 58 74 11 5
Pending Single Family Units
Master Planned Single Family Units 1,552 1,177 375
Subtotal: Net Single Family Unit Capacity 3,794 2,248 798 14 692
Potential Occupied Single Family Units 3,331 1,974 701 12 608
Single Family Population Capacity 8,258 4,893 1,737 30 1,506
Multifamily Developable Acres 138.30 3.77 75.30 18.42 3.25 28.18
Assumed Multifamily Density (units/acre) 20 20 20 12 18 4 12 24 12
Subtotal Multifamily Unit Capacity 1,194 68 301 221 78 338
Existing Multifamily Units 27 3 2 8
Pending Multifamily Units
Master Planned Multifamily Units 583 220 212 151
Subtotal: Net Multifamily Unit Capacity 1,756 220 68 510 221 70 489
Potential Occupied Multifamily Units 1,526 191 59 443 192 61 425
Multifamily Population Capacity 3,066 384 119 890 386 122 854
Net Dwelling Unit Capacity 5,550 220 68 2,758 798 221 84 1,181
Potential Occupied Dwelling Units 4,857 191 59 2,417 701 192 73 1,033
Population Capacity 11,324 384 119 5,783 1,737 386 152 2,360
Remaining Population Growth to
Accommodate (2021-2036) 3,287
Population Capacity Surplus (Deficit) 8,037
Sources: City of Blaine, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
SF-1
3.89
3.89
6
23
5
18
16
39
18
16
39
SF-2 CB TP-CB M-CB M-CB G-CB WV-HCc HCd 60 60 48 36 36
6.15 1.41 0.04 1.31 1.87 0.80 2.19 0.92
6.15
6
37
13 3 8 3
24
21
52
1.41 0.04 1.31 1.87 0.80 2.19 0.92
20 20 20 20 20 20 20
28 26 37 16 44 18
4 2 8
28 24 29 16 44 18
24 21 25 14 38 16
49 2 42 51 28 77 31
24 28 24 29 16 44 18
21 24 1 21 25 14 38 16
52 49 2 42 51 28 77 31
PAGE 68
JULY 2022, REVISED FEB 2023
RH CBG-
48
0.07 0.79
0.00
20
2 4
O.Q7 0.79
24 20
2 16
2 16
2 14
3 28
2 16
2 14
3 28
Commercial and Industrial Development
Exhibit 29. Nonresidential Development, Achieved and Assumed Densities, City of Blaine, 2016-2021
Zoning Development Acres Built Square Achieved Assumed
Designation Ty~e Develo~ed Feet Densi!Y (FAR} Densi!Y (FAR}
PR Commercial N/ /\ N!/A 0.60
PC Commercial ;; /\ 0.80
R/O Commercial N/A 0.70
RPR Commercial 0.5 6,955 0.31 0.70
CB G-36 Commercial N/A N/A 0.85
CB G-48 Commercial N//\ 0.85
CB-M Commercial 0.9 19,644 0.51 1.00
CB M-48 Commercial N,/A 1'\i/ p\ 1.00
CB M-60 Commercial ~/ p\ 1.00
CB-T Commercial N/A 1.00
CB TP-60 Commercial /\ N(/\ 1.00
CB WV-36 Commercial 1.00
CB-W Commercial 3.7 62,296 0.39 1.00
Industrial /\ N/ /\ 1.00
GW Commercial N/l\ f</ ?, 0.90
Industrial 2.3 22,873 0.23 0.90
HCA. Commercial 1.5 27,685 0.41 0.85
HCb Commercial i\/A N/A 0.85
HCc Commercial Nii\ ~✓/A 0.85
HCd Commercial i~/;\ L ·' 0.85
M Industrial N/P 0.75
Ma Commercial N/A /\ 0.75
Industrial N/ 0.75
Mb Commercial N/A 0.75
Industrial N/A ;, 0.75 ;,
Mc Commercial N/ f\ 0.75
Industrial 2.9 43,600 0.35 0.75
Mpr Commercial N/i\ N//-\ 0.70
Sources: City of Blaine, 2022; Community Attributes Inc., 2021.
Note: Assumed Density is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 69
JULY 2022, REVISED FEB 2023
Exhibit 30. Developable Nonresidential Land Supply, Blaine UGA, 2021-2036
UGATotal GW HCA Ma Mb Mc Mpr PC PR RL R/O
Vacant Land
Gross Acres 262.01 9.05 41.03 15.07 122.02 9.23 0.00 2.58 19.40 0.00 13.69
Critical Areas 105.40 0.00 24.34 l.83 55.65 0.73 0.00 l.88 2.54 0.00 12.44
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 7.83 0.45 0.83 0.66 3.32 0.43 0.00 0.03 0.84 0.00 0.06
Infrastructure Deduction 7.83 0.45 0.83 0.66 3.32 0.43 0.00 0.03 0.84 0.00 0.06
Market Factor 21.14 l.22 2.25 1.79 8.96 l.15 0.00 0.09 2.28 0.00 0.17
Net Acres 119.80 6.93 12.76 10.13 50.77 6.50 0.00 0.53 12.89 0.00 0.96
Partially-Used Land
Gross Acres 43.68 15.80 2.93 0.00 4.87 2.76 0.00 1.27 9.54 0.00 0.35
Critical Areas 10.97 4.58 1.59 0.00 0.71 0.15 0.00 0.19 0.76 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
I nfrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction l.64 0.56 0.07 0.00 0.21 0.13 0.00 0.05 0.44 0.00 0.02
Infrastructure Deduction l.64 0.56 0,07 0.00 0.21 0.13 0.00 0.05 0.44 0.00 0,02
Market Factor 7.36 2.52 0.30 0.00 0.94 0.59 0.00 0.24 l.98 0.00 0.08
Net Acres 22.08 7.57 0.90 0.00 2.81 1.76 0.00 0.72 5.93 0.00 0.24
Underutilized Land
Gross Acres 64.54 0.30 6.19 13.03 42.07 0.00 0.00 0.00 0.00 0.00 0.64
Critical Areas 29.17 0.00 2.10 4.45 22.52 0.00 0.00 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
I nfrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 1.77 0.01 0.20 0.43 0.98 0.00 0.00 0.00 0.00 0.00 0.03
Infrastructure Deduction 1.77 0.01 0.20 0.43 0.98 0.00 0.00 0.00 0.00 0.00 0.03
Market Factor 7.96 0.07 0.92 l.93 4.40 0.00 0.00 0.00 0.00 0.00 0.14
Net Acres 23.87 0.20 2.76 5.79 13.20 0.00 0.00 0.00 0.00 0.00 0.43
Sources: City of Blaine, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
RPR
11.38
2.62
0.00
0.00
0.44
0.44
l.18
6.70
0.51
0.00
0.00
0.00
0.03
0.03
0.11
0.34
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
CB TP-CB M-CB M-CB G-CB WV-HCb HCc HCd 60
0.25
0.08
0.00
0.00
0.01
0.01
0,02
0.13
0.05
0,03
0.00
0.00
0.00
0.00
0.00
0.01
0,02
0.00
0.00
0.00
0.00
0.00
0.01
0.02
60 48 36 36
0.08 0.32 0.53 3.01 2.59 1.43 0.63
0.07 0.08 0.03 2.64 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.01 0.03 0.02 0.13 0,07 0.03
0.00 0.01 0.03 0.02 0.13 0,07 0.03
0.00 0.03 0.07 0.05 0.35 0.19 0.08
0.01 0.19 0.39 0.28 1.98 1.09 0.48
0.00 0.24 0.12 0.18 1.63 l.01 0.09
0.00 0.01 0.00 0.01 0.71 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.01 0.01 0.01 0.05 0.05 0.00
0.00 0.01 0.01 0.01 0.05 0.05 0.00
0.00 0.05 0,03 0.04 0.21 0.23 0.02
0.00 0.15 0.08 0.12 0.62 0.68 0.06
0.04 0.14 0.00 0.00 0.72 0.68 0.56
0.04 0.00 0.00 0.00 0.00 0.06 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.01 0.00 0.00 0.04 0.03 0,03
0.00 0.01 0.00 0.00 0.04 0.03 0.03
0.00 0.03 0.00 0.00 0.16 0.14 0.13
0.00 0.09 0.00 0.00 0.49 0.42 0.38
PAGE 70
JULY 2022, REVISED FEB 2023
CBG-
48
0.02
0.00
0.00
0.00
0.00
0.00
0.00
0.01
0.12
0.00
0.00
0.00
0.01
0.01
0,03
0.08
0.15
0.00
0.00
0.00
0.01
0.01
0.03
0.10
Exhibit 31. Developable Nonresidential Land Capacity, Blaine UGA, 2021-2036
UGA GW HCA Ma Mb Mc Mpr PC PR RL R/O RPR
Net Developable Employment Acres
(Vacant, PU, UU) 165.76 14.70 16.42 15.92 66.78 8.27 0.00 1.26 18.82 0.00 1.62 7.04
Commercial Developable Acres 71.97 14.70 16.42 1.26 18.82 1.62 7.04
Assumed Commerciol Density (FAR) 0.9 0.9 0.8 0.8 0.8 0.7 0.8 0.6 0.7 0.7
Subtotal: Commercial Capacity (SF) 2.466.577 57 6.235 608.115 -43,790 491,993 49,505 214,792
Existing Commercial Space (SF) 143,180 45,286 13,682 -17,773 160 11,177
Pending Commercial Space (SF)
Master Planned Commercial Space (SF) 225,000 37,000 -71,000 -72,000 -45,000
Subtotal: Net Commercial Capacity (SF) 2,558,953 567,949 594,433 -71,000 26,017 563,993 38,328 259,792
Potential Occupied Commercial Space (SF) 2.431,006 539,552 564,711 -67,450 24,716 535,793 36,412 246,802
Commercial Employment Capacity 4,578 1,016 1,063 127 47 1,009 69 465
Industrial Developable Acres 93.79 -15.92 66.78 8.27
Assumed Industrial Density (FAR) 0.9 0.8 0.8 0.8
Subtotal: Industrial Capacity (SF) 3,094,830 -520,064 2,181.559 270,122
Existing Industrial Space (SF) 19,761 1,044 200 4,864
Pending Industrial Space (SF)
Master Planned Industrial Space (SF) 10,208 10,208
Subtotal: Net Industrial Capacity (SF) 3,104,838 10,208 -520,064 2,181,559 269,922
Potential Occupied Industrial Space (SF) 2,949,596 9,698 -494,061 2,072,481 256,426
Industrial Employment Capacity 3,992 13 669 2,804 347
Net Commercial & Industrial Capacity (SF) 5,663,791 578,157 594,433 520,064 2,181.559 269,922 71,000 26,017 563,993 38,328 259,792
Potential Occupied Commercial & Industrial 5,380,602 549,249 564,711 494,061 2,072,481 256,426 67,450 24,716 535,793 36,412 246,802
Employment Capacity 8,570 1,029 1,063 669 2,804 347 127 47 1,009 69 465
Remaining Employment Growth to
Accommodate (2021-2036) 1,578
Employment Capacity Surplus (Deficit) 6,992
Sources: City of Blaine, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
CB TP-CB M-CB M-CB G-CB WV-HCb HCc HCd 60 60 48 36 36
0.16 0.01 0.44 0.47 0.40 3.08 2.19 0.92
0.16 0.01 0.44 0.47 0.40 3.08 2.19 0.92
1.0 1.0 1.0 0.9 1.0 0.9 0.9 0.9
6,825 413 19,010 17,314 17,396 114,111 81,215 33,946
1,223 2.472 18,393 1,494 2,182 5,640 3,848 2,352
5,602 617 15,820 15,214 108,471 77,367 31,594
5,322 586 15,029 14,453 103,047 73,499 30,014
10 28 27 194 138 57
2.000 6,253
5,602 617 15,820 15,214 108,471 77,367 31,594
5,322 586 15,029 14,453 103,047 73,499 30,014
10 28 27 194 138 57
PAGE 71
JULY 2022, REVISED FEB 2023
CBG-
48
0.20
0.20
0.9
7,290
5,945
1.345
1,278
2
1,345
1,278
2
4. Cherry Point UGA
The Cherry Point Urban Growth Area is
characterized by and planned for industrial
uses. This UGA does not have residential
zoning or allocated population growth. The
UGA has an employment growth allocation of
774 between 2016 and 2036 (Exhibit 2).
Achieved Growth 2016-2021
Permit data for the Cherry Point UGA is not a
sufficient data source to estimate past
employment growth. This is because a major
employer in the UGA shutdown in 2020.
Additionally, the Cherry Point Urban Growth
Area is unique in that many of the building
permits are not for the more traditional
enclosed industrial buildings that have been
permitted in other cities and UGAs (building
permits at Cherry Point include equipment,
pipe supports, platforms, etc.). Therefore,
Whatcom County contracted with Western
Washington University to provide an
employment growth estimate for the review
period (Employment at Cherry Point, June
2021). Employment data for 2016 was limited.
Therefore, the employment estimate
represents growth between 2017 and 2021.
Based on these estimates, the Cherry Point
UGA declined in employment by 141 (Exhibit
7). Cherry Point UGA employment declined
between 2016 and 2021 because of job losses
WHATCOM COUNTY
BUILDABLE LANDS REPORT
associated with the Alcoa Intalco shutdown in
2020.
Employment Assumptions
Occupancy rate and employment density
assumptions for estimating future growth
capacity in the Cherry Point UGA are:
• 95.0% Industrial occupancy rate
• 1,779 Industrial square feet per
employee
The Cherry Point UGA will need to
accommodate 876 more jobs between 2021 and
2036 under current planning assumptions
(Exhibit 7).
Employment Capacity 2021-2036
The Whatcom County Comprehensive Plan
does not have adopted industrial planned
densities. Between 2016 and 2021 the Cherry
Point UGA has seen an overall achieved
industrial FAR of 0.11 (Exhibit 11).
Based on achieved densities between 2016 and
2021, Whatcom County is assuming future
F ARs of 0.10 for the HII zone and 0.12 for the
LII zone (Exhibit 32).
PAGE 72
JULY 2022, REVISED FEB 2023
The Cherry Point UGA has estimated net land
capacity for employment growth of 1,152 acres
(Exhibit 33), with a total estimated potential
occupied industrial capacity of over 4.6 million
square feet. Based on square feet per employee
assumptions, the Cherry Point UGA has an
estimated future employment capacity of
2,613, indicating an estimated employment
capacity surplus of 1,737 (Exhibit 34).
Regulatory Changes
The County has evaluated development
regulations adopted in the review period (April
1, 2016 -March 31, 2021). Only Ordinance
2019-005 could prevent assigned densities
from being achieved or impact the quantity of
land suitable for development in the
remainder of the 20-year planning period
(2021-2036). In an e-mail of October 6, 2021, a
representative of the Whatcom County Public
Works River & Flood Division stated:
... the 2019 revisions were done mainly to
reflect updated flood study and the most
recent just adopted in 2021 was for
compliance with building freeboard
required for CRS [Community Rating
System] credit, nothing to do with 'supply of
land'. That being said, the flood study did
change the Base Flood Elevations and
floodplain boundaries in those areas and
WHATCOM COUNTY
BUILDABLE LANDS REPORT
the FEMA Biological Opinion does restrict
density in the floodplain ...
A September 30, 2021 River & Flood Division
memo attached to the e-mail states that the
Special Flood Hazard Area is:
... designated Critical Area and/or Habitat
Conservation Area (HCA) per WCC Title-
16. As such, creating additional 'buildable'
lots within a Critical Area or HCA may be
prohibited. For further information
reference WCC 16.16.420 -Frequently
Flooded Areas ...
Pursuant to the Whatcom County Review and
Evaluation Program Methodology, Whatcom
County deducted floodplains from the
buildable land supply.
After the end of the review period, the County
Council adopted Ordinance 2021-046
prohibiting certain uses and requiring a
conditional use permit for certain uses in the
Cherry Point UGA. This ordinance also
included greenhouse gas provisions in SEP A.
Infrastructure Gaps
Whatcom County has reviewed capital facility
plans and/or consulted with service providers.
Based upon these actions, the County has not
identified any infrastructure gaps that would
PAGE 73
JULY 2022, REVISED FEB 2023
prevent service providers from supplying
planned capital facilities to developable land
in the Cherry Point UGA within the remaining
portion of the planning period (2021-2036).
Analysis of Comprehensive Plan
Objectives and Reasonable Measures
The Cherry Point UGA experienced negative
job growth in the review period because of the
Alcoa Intalco shutdown, which resulted in the
loss of approximately 662 jobs at this plant
(Employment at Cherry Point, June 2021, page
8). The shutdown was a business decision by a
large corporation based upon a number of
factors, including the global business
environment. If not for this shutdown,
employment growth in the UGA would have
outpaced the growth allocated in the Whatcom
County Comprehensive Plan.
Whatcom County Comprehensive Plan Policy
7B-l states:
The Port of Bellingham, serving as the ADO
[Associate Development Organization], will
work with the cities, the County, Chambers
of Commerce, educational institutions, and
other groups to assist retention and
expansion of existing local businesses and
to attract appropriate businesses to
Whatcom County ...
WHATCOM COUNTY
BUILDABLE LANDS REPORT
The Port of Bellingham is actively working to
recruit a business for the Alcoa Intalco
property. A reasonable measure is for the Port
of Bellingham to continue the recruitment
process until a new tenant is found, in order to
facilitate job growth as envisioned in the
Whatcom County Comprehensive Plan and
implement Comprehensive Plan Policy 7B-1.
PAGE 74
JULY 2022, REVISED FEB 2023
Commercial and Industrial Development
Exhibit 32. Nonresidential Development, Achieved and Assumed Densities, Cherry Point UGA, 2016-2021
Zoning Development Acres Built Square Achieved Assumed
Designation Type Developed Feet Density (FAR) Density (FAR)
HI I Industrial 8.8 39,560 0.10 0.10
LI I Industrial 8.0 40,991 0.12 0.12
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
Note: Assumed Density is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 75
JULY 2022, REVISED FEB 2023
Exhibit 33. Developable Nonresidential Land Supply, Cherry Point UGA, 2021-2036
Vacant Land
Gross Acres
Critical Areas
Future Public Uses
Infrastructure Gaps
Quasi-Public Use Deduction
Infrastructure Deduction
Mark et Factor
Net Acres
Partially-Used Land
Gross Acres
Critical Areas
Future Public Uses
Infrastructure Gaps
Quasi-Public Use Deduction
Infrastructure Deduction
Mark et Factor
Net Acres
Underutilized Land
Gross Acres
Critical Areas
Future Public Uses
Infrastructure Gaps
Quasi-Public Use Deduction
Infrastructure Deduction
Market Factor
Net Acres
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
UGA Total
3,834.69
2,188.05
10.00
0.00
81.83
163.66
313.0l
1,078.14
148.42
109.30
0.00
0.00
l.96
3.91
10.81
22.45
223.24
133.21
0.00
0.00
4.50
9.00
24.87
51.65
HII
3,765.09
2,132.12
10.00
0.00
81.15
162.30
310.39
1,069.13
148.42
109.30
0.00
0.00
l.96
3.91
10.81
22.45
218.47
130.42
0.00
0.00
4.40
8.80
24.32
50.52
LIi
69.60
55.93
0.00
0.00
0.68
l.37
2.62
9.01
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
4.77
2.79
0.00
0.00
0.10
0.20
0.55
1.14
PAGE 76
JULY 2022, REVISED FEB 2023
Exhibit 34. Developable Nonresidential Land Capacity, Cherry Point UGA, 2021-2036
Net Developable Employment Acres
(Vacant, PU, UU)
Commercial Developable Acres
Assumed Commercial Density (FAR)
Subtotal: Commercial Capacity (SF)
Existing Commercial Space (SF)
Pending Commercial Space (SF)
Master Planned Commercial Space (SF)
Subtotal: Net Commercial Capacity (SF)
Potential Occupied Commercial Space (SF)
Commercial Employment Capacity
Industrial Developable Acres
Assumed Industrial Density (FAR)
Subtotal: Industrial Capacity (SF)
Existing Industrial Space (SF)
Pending Industrial Space (SF)
Master Planned Industrial Space (SF)
Subtotal: Net Industrial Capacity (SF)
Potential Occupied Industrial Space (SF)
Industrial Employment Capacity
Net Commercial & Industrial Capacity (SF)
Potential Occupied Commercial & Industrial
Employment Capacity
Remaining Employment Growth to
Accommodate (2021-2036)
Employment Capacity Surplus (Deficit)
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
UGA
1,152.24
11,328
1152.24
5,027,995
134,000
4,893,995
4,649,295
2,613
4,893,995
4,649,295
2,613
876
1,737
HII
1,142.09
11,328
1142.09
0.1
4,974,958
134,000
4,840,958
4,598,910
2,585
4,840,958
4,598,910
2,585
LIi
10.15
10.15
0.1
53,037
53,037
50,385
28
53,037
50,385
28
PAGE 77
JULY 2022, REVISED FEB 2023
5. Columbia Valley UGA
The Columbia Valley Urban Growth Area, one
of three Non-City UGAs, is projected to reach
4,448 total population and 444 employees by
2036. The UGA has projected growth
allocations of 1,170 new residents and 312 new
jobs between 2016 and 2036 (Exhibit 1 and
Exhibit 2).
Achieved Growth 2016-2021
Based on permit data collected between 2016
and 2021, occupancy, persons per household
and square feet per employee assumptions,
new construction in the Columbia Valley UGA
accommodated an estimated 271 new residents
and 11 new jobs over this five-year period
(Exhibit 6 and Exhibit 7).
The Columbia Valley UGA achieved an overall
residential density of 4.9 units per net acre
between 2016 and 2021. This is within the
range of 4.0 to 6.0 units per net acre planned
in the Whatcom County Comprehensive Plan
(Exhibit 11).
Whatcom County has not adopted planned
densities for commercial or industrial uses.
Between 2016 and 2021, the UGA achieved a
commercial FAR of 0.05, and did not have
industrial development during the period
(Exhibit 11). The commercial FAR is based
WHATCOM COUNTY
BUILDABLE LANDS REPORT
upon a limited number of commercial building
permits (2) issued between April 1, 2016 and
March 31, 2021. One of the 2 building permits
was in a commercial zone (the other was in a
residential zone). The permit in commercial
zone was for a new food bank.
Population and Employment Assumptions
Occupancy rate and population and
employment assumptions for estimating future
growth capacity in the Columbia Valley UGA
are:
• 88.0% residential occupancy rate
• 95.0% Commercial and Industrial
occupancy rate
• 2.90 persons per household
• 532 and 812 respectively Commercial
and Industrial square feet per employee
Population Capacity 2021-2036
The Columbia Valley UGA will need to
accommodate 899 more residents and 301
more jobs between 2021 and 2036 under
current planning assumptions (Exhibit 6 and
Exhibit 7).
Based on achieved densities between 2016 and
2021, Whatcom County is assuming future
residential densities of 4.9 units per acre for
PAGE 78
JULY 2022, REVISED FEB 2023
both single family and multifamily
development (Exhibit 35).
The Columbia Valley UGA has estimated net
land capacity for population growth of 178.4
acres (Exhibit 36), with a total estimated
potential occupied unit capacity of 7 4 7
dwelling units. Based on persons per
household assumptions, the Columbia Valley
UGA has an estimated population capacity of
2,167, indicating an estimated population
capacity surplus of 1,268 (Exhibit 37).
Housing Needs by Type
The Whatcom County Comprehensive Plan
(Chapter 3-Housing, Chart 3 -Estimated
Dwelling Units Needed, page 3-8) indicates
that the Columbia Valley UGA has a need for
613 new single-family dwelling units during
the 2013-2036 planning period (the
Comprehensive Plan does not estimate
multifamily housing needs for Columbia
Valley). The calculation for Chart 3 in the
Whatcom County Comprehensive Plan included
building activity from 2013. Therefore, the
analysis below includes permit data from April
1, 2013, even though the planning period for
this Buildable Lands Report is from 2016.
• Between April 1, 2013 and March 31, 2021,
Whatcom County performed final
inspections on 120 single-family and 0
WHATCOM COUNTY
BUILDABLE LANDS REPORT
multi-family units in the Columbia UGA.
Comparing units built and the needs
indicated on Chart 3, the Columbia Valley
UGA needs an additional 493 single-family
units between 2021 and 2036.
• The Columbia Valley UGA has an estimated
2021-2036 capacity for 840 single-family
and 9 multi-family housing units (Exhibit
37).
The capacity to accommodate single family
residential housing in the Columbia Valley
UGA is sufficient to accommodate the single
family dwelling units needed in the planning
period as established in the Whatcom County
Comprehensive Plan (Chapter 3-Housing,
Chart 3).
Employment Capacity 2021-2036
Whatcom County is using an average of the
small city F ARs for future commercial and
industrial development, since there is little or
no data on achieved densities in the Columbia
Valley UGA (Exhibit 38).
The Columbia Valley UGA has estimated net
land capacity for employment growth of 33.1
acres (Exhibit 39), with a total estimated
potential occupied commercial and industrial
capacity of 278,205 square feet. Based on
square feet per employee assumptions, the
PAGE 79
JULY 2022, REVISED FEB 2023
UGA has an estimated employment capacity of
420, indicating an estimated employment
capacity surplus of 119 (Exhibit 40).
Regulatory Changes
The County has evaluated development
regulations adopted in the review period
(April 1, 2016 -March 31, 2021). No
ordinances adopted during the review period
have been identified that would prevent
assigned densities from being achieved or
impact the quantity ofland suitable for
development in the remainder of the 20-year
planning period (2021-2036).
Infrastructure Gaps
Whatcom County has reviewed capital facility
plans and/or consulted with service providers.
Based upon these actions, the County has the
following comments on infrastructure gaps
that would prevent service providers from
supplying planned capital facilities to
developable land in the Columbia Valley UGA
within the planning period (2021-2036).
Water District 13 is the only sewer purveyor
in the UGA. There is no public sewer in parts
of the UGA outside of District 13, including
the Planned Industrial area north of
Limestone Rd. On-site sewage systems may
be used in areas with no sewer, which will
WHATCOM COUNTY
BUILDABLE LANDS REPORT
especially affect the Planned Light Impact
Industrial Area. A 30% deduction will be
taken from the land in the Planned Light
Impact Industrial Area to account for the lack
of public sewer. A map of the Columbia Valley
UGA showing the land area associated with
this deduction is provide below. Residential
areas located outside District 13 are platted
already and have developed with on-site
sewage systems.
Additionally, the Water District 13 Sewer
Plan will need to be updated to serve planned
growth within its boundaries, as the existing
Sewer System Plan only plans for projected
population and sewer connections through the
year 2029.
PAGE 80
JULY 2022, REVISED FEB 2023
WHATCOM COUNTY
BUILDABLE LANDS REPORT
Columbia Valley UGA
-Infrastructure Gaps
Legend
Columbia Valley UGA
;/st Ill W>t~l~tlR tOU\"ff$ ~!S~-'lA il"J>'.l($lK1. .n11l"S
~,11; ;1(HH 11:ffll 'k• fOU..Ol'tl~\; STJl;u•r~t
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-==-=i---===--•·<:::<:t J ,ioo aoo 1.soo ;; -:00 '.)_::>oo
PAGE 81
JULY 2022, REVISED FEB 2023
Analysis of Comprehensive Plan
Objectives and Reasonable Measures
The Columbia Valley UGA has experienced
slow employment growth between 2016 and
2021. The Whatcom County Comprehensive
Plan employment projection would suggest
that about 78 jobs should be created in the
Columbia Valley UGA over a given five-year
period (Chapter 1, page 1-8). However, the
Data Reporting Tool estimates that only 11
jobs were created in the UGA between 2016
and 2021.
The County rezoned land in the UGA from
Urban Residential to General Commercial in
2009 to provide land for business within the
UGA. There is also a Planned Light Impact
Industrial designation in the northern portion
of the UGA, but this site has not yet been
rezoned to accommodate industry. Therefore,
it is not able to accommodate intensive
employment growth at this time. A potential
reasonable measure the County could consider
is rezoning the Planned Light Impact
Industrial area for industrial uses as set forth
in the Foothills Subarea Plan (pages 2-12, 12-
4, 12-5, and 12-10).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 82
JULY 2022, REVISED FEB 2023
Residential Development
Exhibit 35. Residential Development, Achieved and Assumed Densities, Columbia Valley UGA, 2016-2021
Zoning Development Acres Dwelling Achieved Density
Designation Type Developed Units Density Assumed
(Units/Acre) (Units/Acre)
UR4 Single Family 22.2 109 4.91 4.91
GC Multifamily N/A N/A N/A 4.91
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
Note: "Density Assumed" is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 83
JULY 2022, REVISED FEB 2023
Exhibit 36. Residential Land Supply, Columbia Valley UGA, 2021-2036
Vacant Land
Gross Acres
Critical Areas
Future Public Uses
Infrastructure Gaps
Quasi-Public Use Deduction
Infrastructure Deduction
Market Factor
Net Acres
Partially-Used Land
Gross Acres
Critical Areas
Future Public Uses
Infrastructure Gaps
Quasi-Public Use Deduction
Infrastructure Deduction
Market Factor
Net Acres
Underutilized Land
Gross Acres
Critical Areas
Future Public Uses
Infrastructure Gaps
Quasi-Public Use Deduction
Infrastructure Deduction
Market Factor
Net Acres
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
UGA Total
408.37
101.05
3.00
0.00
15.22
69.70
52.66
166.74
29.17
6.53
0.00
0.00
1.13
5.21
4.89
11.41
0.49
0.00
0.00
0.00
0.02
0.05
0.13
0.29
UR4
406.02
100.94
3.00
0.00
15.10
69.48
52.20
165.29
29.17
6.53
0.00
0.00
1.13
5.21
4.89
11.41
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
GC RF
2.35 0.00
0.11 0.00
0.00 0.00
0.00 0.00
0.11 0.00
0.22 0.00
0.46 0.00
1.45 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.49 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.02 0.00
0.05 0.00
0.13 0.00
0.29 0.00
PAGE 84
JULY 2022, REVISED FEB 2023
Exhibit 37. Developable Residential Land Capacity, Columbia Valley UGA, 2021-2036
Net Developable Residential Acres
(Vacant, PU, UU)
Single Family Developable Acres
Assumed Single Family Density (units/acre)
Subtotal Single Family Unit Capacity
Existing Single Family Units
Pending Single Family Units
Master Planned Single Family Units
Subtotal: Net Single Family Unit Capacity
Potential Occupied Single Family Units
Single Family Population Capacity
Multifamily Developable Acres
Assumed Multifamily Density (units/acre)
Subtotal Multifamily Unit Capacity
Existing Multifamily Units
Pending Multifamily Units
Master Planned Multifamily Units
Subtotal: Net Multifamily Unit Capacity
Potential Occupied Multifamily Units
Multifamily Population Capacity
Net Dwelling Unit Capacity
Potential Occupied Dwelling Units
Population Capacity
Remaining Population Growth to
Accommodate (2021-2036)
Population Capacity Surplus (Deficit)
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
UGA
178.45
176.71
868
87
58
840
739
2,144
1.74
9
9
8
23
849
747
2,167
899
1,268
UR4
176.71
176.71
5
868
86
58
840
739
2,144
840
739
2,144
GC RF
1.74 0.00
1.74
5
9
9
8
23
9
8
23
PAGE 85
JULY 2022, REVISED FEB 2023
Commercial and Industrial Development
Exhibit 38. Nonresidential Development, Achieved and Assumed Densities, Columbia Valley UGA, 2016-
2021
Zoning Development Acres Built Square Achieved Assumed
Designation Tyee Develoeed Feet Density (FAR) Density (FAR)
UR4 Commercial 0.1 864 0.27 N/A
GC Commercial 2.6 5,500 0.05 0.18
RF · Industrial N/A N/A N/A 0.22
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
Note: Assumed Density is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 86
JULY 2022, REVISED FEB 2023
Exhibit 39. Developable Nonresidential Land Supply, Columbia Valley UGA, 2021-2036
UGA Total
Vacant Land
Gross Acres 59.74
Critical Areas 0.97
Future Public Uses 0.00
Infrastructure Gaps 11.57
Quasi-Public Use Deduction 2.36
Infrastructure Deduction 4.72
Market Factor 9.63
Net Acres 30.49
Partially-Used Land
Gross Acres 0.00
Critical Areas 0.00
Future Public Uses 0.00
Infrastructure Gaps 0.00
Quasi-Public Use Deduction 0.00
Infrastructure Deduction 0.00
Mark et Factor 0.00
Net Acres 0.00
Underutilized Land
Gross Acres 4.43
Critical Areas 0.00
Future Public Uses 0.00
Infrastructure Gaps 0.00
Quasi-Public Use Deduction 0.22
Infrastructure Deduction 0.44
Market Factor 1.13
Net Acres 2.64
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
UR4 GC
0.00 21.16
0.00 0.97
0.00 0.00
0.00 0.00
0.00 1.01
0.00 2.02
0.00 4.12
0.00 13.04
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 4.43
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.22
0.00 0.44
0.00 1.13
0.00 2.64
RF
38.58
0.00
0.00
11.57
1.35
2.70
5.51
17.45
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
PAGE 87
JULY 2022, REVISED FEB 2023
Exhibit 40. Developable Nonresidential Land Capacity, Columbia Valley UGA, 2021-2036
Net Developable Employment Acres
(Vacant, PU, UU)
Commercial Developable Acres
Assumed Commercial Density (FAR)
Subtotal: Commercial Capacity (SF)
Existing Commercial Space (SF)
Pending Commercial Space (SF)
Master Planned Commercial Space (SF)
Subtotal: Net Commercial Capacity (SF)
Potential Occupied Commercial Space (SF)
UGA
33.12
15.68
125,658
125,658
119,375
UR4
0.00
GC
15.68
15.68
0.2
125,658
125,658
119,375
RF
17.45
-----------------Commer c i a I Employment Capacity
Industrial Developable Acres
Assumed Industrial Density (FAR)
Subtotal: Industrial Capacity (SF)
Existing Industrial Space (SF)
Pending Industrial Space (SF)
Master Planned Industrial Space (SF)
Subtotal: Net Industrial Capacity (SF)
Potential Occupied Industrial Space (SF)
Industrial Employment Capacity
Net Commercial & Industrial Capacity (SF)
Potential Occupied Commercial & Industrial
Em p Io y men t Capacity
Remaining Employment Growth to
Accommodate (2021-2036)
Employment Capacity Surplus (Deficit)
Sources: Whatcom County, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
224
17.45
167,189
167,189
158,830
196
292,847
278,205 ---------420
301
119
224
17.45
0.2
167,189
167,189
158,830
196
125,658 167,189
119,375 158,830
224 196
PAGE 88
JULY 2022, REVISED FEB 2023
6. Everson UGA
The Everson Urban Growth Area is projected
to reach a total population and employment of
3,907 and 1,312 respectively by 2036. The
UGA has projected growth allocation of 1,080
for population and 523 for employment
between 2016 and 2036 (Exhibit 1 and
Exhibit 2).
Achieved Growth 2016-2021
Based on permit data collected between 2016
and 2021 and occupancy and persons per
household and square feet per employee
assumptions, the Everson UGA grew by an
estimated 317 population (100% within the
City of Everson) and 16 employment (79%
within the City of Everson) (Exhibit 6 and
Exhibit 7).
Between 2016 and 2021, the City of Everson
achieved densities greater than planned for
residential uses, 4.8 units per acre achieved
compared to 4.0 planned based in the
Whatcom County Land Capacity Analysis
Report referenced in the 2016 City of Everson
Comprehensive Plan. This achieved residential
density also falls within the planned density
range of 4.0 to 6.0 units per acre adopted in
the Whatcom County Comprehensive Plan for
the City of Everson. The unincorporated
portions of the Everson UGA have seen no
WHATCOM COUNTY
BUILDABLE LANDS REPORT
residential or commercial development
between 2016 and 2021 (Exhibit 11).
The City of Everson, in the Comprehensive
Plan, references commercial and industrial
planned densities based on the Whatcom
County Land Capacity Analysis. Whatcom
County has not adopted planned densities for
commercial or industrial uses. Planned
commercial and industrial FAR for the
Everson UGA are 0.20 and 0.30, respectively.
Between 2016 and 2021, incorporated areas of
the UGA have achieved a commercial FAR of
0.26, exceeding the adopted FAR. No
industrial developed has occurred in the City
of Everson between 2016 and 2021. Limited
industrial development in the unincorporated
portion of the UGA achieved a 0.01 FAR
(Exhibit 11).
Population and Employment Assumptions
Specific occupancy rate and population and
employment density assumptions for
estimating future growth capacity in the
Everson UGA are:
• 97.0% Single Family occupancy rate
• 92.8% Multifamily occupancy rate
• 95.0% Commercial and Industrial
occupancy rate
PAGE 89
JULY 2022, REVISED FEB 2023
• 3.066 Single Family persons per
household
• 2.901 Multifamily persons per
household
• 800 and 1,501 respectively Commercial
and Industrial square feet per employee
The Everson UGA has an estimated 763
population and 507 employment growth
remaining to accommodate between 2021 and
2036 (Exhibit 6 and Exhibit 7).
Population Capacity 2021-2036
The City of Everson is utilizing achieved
densities when estimating future residential
land capacity. Based on achieved densities
between 2016 and 2021 and planning
assumptions, City of Everson planners are
assuming future single family density of 4.4
units per acre, and 8.5 units per acre for
multifamily zones (Exhibit 41).
The Everson UGA has estimated net land
capacity for population growth of 248.4 acres
(Exhibit 42), with a total estimated potential
occupied unit capacity of 1,203 dwelling units.
Based on persons per household assumptions,
the UGA has an estimated population capacity
of 3,634, indicating an estimated population
capacity surplus of 2,871 (Exhibit 43).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
Housing Needs by Type
The Whatcom County Comprehensive Plan
(Chapter 3-Housing, Chart 3 -Estimated
Dwelling Units Needed, page 3-8) indicates
that Everson has a need for 277 single-family,
129 multi-family, and 28 other ("group
housing") new dwelling units during the 2013-
2036 planning period. The calculation for
Chart 3 in the Whatcom County
Comprehensive Plan included building activity
from 2013. Therefore, the analysis below
includes permit data from April 1, 2013, even
though the planning period for this Buildable
Lands Report is from 2016.
• Between April 1, 2013 and March 31 2021 ' ' Everson issued building permits for 11 7
single-family and 20 multi-family units. No
group housing has been built during this
time. Comparing units built and the needs
indicated on Chart 3, Everson needs an
additional 160 single-family units, 109
multi-family units, and 28 group housing
units between 2021 and 2036.
• The City and unincorporated UGA have an
estimated 2021-2036 capacity for 904
single-family and 351 multi-family housing
units (Exhibit 43). The multi-family
capacity includes group housing.
PAGE 90
JULY 2022, REVISED FEB 2023
These capacities are sufficient to accommodate
the dwelling unit types needed in the planning
period as established in the Whatcom County
Comprehensive Plan (Chapter 3-Housing,
Chart 3).
Employment Capacity 2021-2036
The City of Everson is utilizing achieved
densities (when available) when estimating
future land capacity for employment. Based on
achieved densities between 2016 and 2021 and
planning assumptions, City of Everson
planners are assuming a future commercial
FAR of 0.26 and an industrial FAR of 0.30
(Exhibit 44).
The Everson UGA has estimated net land
capacity for employment growth of 179.4 acres
(Exhibit 45), with a total estimated potential
occupied commercial and industrial capacity of
2.1 million square feet. Based on square feet
per employee assumptions, the Everson UGA
has an estimated employment capacity of
1,575, indicating an estimated employment
capacity surplus of 1,065 (Exhibit 46).
Regulatory Changes
The City of Everson has not identified any
regulatory changes that would prevent
assigned densities from being achieved or
impact the quantity of land suitable for
WHATCOM COUNTY
BUILDABLE LANDS REPORT
development during the remainder of the
planning period.
Infrastructure Gaps
The City of Everson has not identified any
infrastructure gaps that would prevent
assigned densities from being achieved or
impact the quantity of land suitable for
development during the remainder of the
planning period (2021 to 2036).
Analysis of Comprehensive Plan
Objectives and Reasonable Measures
The City of Everson has determined that
growth targets and assumptions are being met
to a reasonable degree; therefore, an analysis
of comprehensive plan development targets,
assumptions and objectives is not deemed
necessary.
Based on the results presented in the
Buildable Land Report, implementation of
reasonable measures is not deemed necessary.
If in the future it is determined that
Reasonable Measures are appropriate, then
the following measures could be considered for
implementation:
• Increase residential densities by reducing
minimum lot sizes in the Residential District
above the increases likely to result from
PAGE 91
JULY 2022, REVISED FEB 2023
establishment of the Residential-7500
Subzone.
· Increase opportunities for construction of
accessory dwelling units (ADUs).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 92
JULY 2022, REVISED FEB 2023
Residential Development
Exhibit 41. Residential Development, Achieved and Assumed Densities, City of Everson, 2016-2021
z · D I t Acres D Ir Achieved Density omng eve opmen we. mg Density Assumed
Designation Type Developed Units (Units/Acre) (Units/Acre)
RES Single Family 20.3 89 4.38 4.38
Multifamily 0.3 2 7.14 N/A
RES-7500 Single Family N/.A N/A N/A 4.38
RMU Single Family 0.4 3 7.33 N/A
Multifamily 1.6 14 8.50 8.50
Sources: City of Everson, 2022; Community Attributes Inc., 2021.
Note: "Density Assumed" is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 93
JULY 2022, REVISED FEB 2023
Exhibit 42. Residential Land Supply, Everson UGA, 2021-2036
UGA Total RES RES-7500
Vacant Land
Gross Acres 201.31 161.60 0.64
Critical Areas 20.18 20.18 0.00
Future Public Uses 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00
Quasi-Public Use Deduction 9.06 7.07 0.03
Infrastructure Deduction 9.06 7.07 0.03
Market Factor 24.45 19.09 0.09
Net Acres 138.57 108.19 0.49
Partially-Used Land
Gross Acres 214.57 201.09 0.00
Critical Areas 51.84 50.37 0.00
Future Public Uses 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00
Quasi-Public Use Deduction 8.14 7.54 0.00
Infrastructure Deduction 8.14 7.54 0.00
Mark et Factor 36.61 33.91 0.00
Net Acres 109.84 101.74 0.00
Underutilized Land
Gross Acres 0.00 0.00 0.00
Critical Areas 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00
Quasi-Public Use Deduction 0.00 0.00 0.00
Infrastructure Deduction 0.00 0.00 0.00
Market Factor 0.00 0.00 0.00
Net Acres 0.00 0.00 0.00
Sources: City of Everson, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
RMU COM LI
39.07 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
1.95 0.00 0.00
1.95 0.00 0.00
5.27 0.00 0.00
29.89 0.00 0.00
13.48 0.00 0.00
1.48 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.60 0.00 0.00
0.60 0.00 0.00
2.70 0.00 0.00
8.10 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
PAGE 94
JULY 2022, REVISED FEB 2023
Exhibit 43. Developable Residential Land Capacity, Everson UGA, 2021-2036
UGA RES RES-7500
Net Developable Residential Acres
(Vacant, PU, UU) 248.41 209.93 0.49
Single Family Developable Acres 210.42 209.93 0.49
Assumed Single Family Density (units/acre) 4 4
Subtotal Single Family Unit Capacity 921 919 2
Existing Single Family Units 63 37
Pending Single Family Units 20 20
Master Planned Single Family Units
Subtotal: Net Single Family Unit Capacity 904 902 2
Potential Occupied Single Family Units 877 875 2
Single Family Population Capacity 2,689 2,683 6
Multifamily Developable Acres 37.99
Assumed Multifamily Density (units/acre)
Subtotal Multifamily Unit Capacity 323
Existing Multifamily Units
Pending Multifamily Units 28
Master Planned Multifamily Units
Subtotal: Net Multifamily Unit Capacity 351
Potential Occupied Multifamily Units 326
Multifamily Population Capacity 945
Net Dwelling Unit Capacity 1,255 902 2
Potential Occupied Dwelling Units 1,203 875 2
Population Capacity 3,634 2,683 6
Remaining Population Growth to
Accommodate (2021-2036) 763
Population Capacity Surplus (Deficit) 2,871
Sources: City of Everson, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
RMU COM LI
37.99 0.00 0.00
5 16 5
37.99
9
323
28
351
326
945
351
326
945
PAGE 95
JULY 2022, REVISED FEB 2023
Commercial and Industrial Development
Exhibit 44. Nonresidential Development, Achieved and Assumed Densities, City of Everson, 2016-2021
Zoning Development Acres Built Square Achieved Assumed
Designation Ty~e Develo~ed Feet Density (FAR} Density (FAR}
COM Commercial 0.9 10,825 0.26 0.26
LI Industrial N/A N/A N/A 0.30
Sources: City of Everson, 2022; Community Attributes Inc., 2021.
Note: Assumed Density is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 96
JULY 2022, REVISED FEB 2023
Exhibit 45. Developable Nonresidential Land Supply, Everson UGA, 2021-2036
UGA Total RES RES-7500 RMU COM LI
Vacant Land
Gross Acres 175.15 0.00 0.00 0.00 9.89 165.25
Critical Areas 2.52 0.00 0.00 0.00 0.19 2.33
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 8.63 0.00 0.00 0.00 0.48 8.15
Infrastructure Deduction 8.63 0.00 0.00 0.00 0.48 8.15
Market Factor 23.30 0.00 0.00 0.00 1.31 22.00
Net Acres 132.06 0.00 0.00 0.00 7.42 124.64
Partially-Used Land
Gross Acres 6.20 0.00 0.00 0.00 3.52 2.68
Critical Areas 0.00 0.00 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 0.31 0.00 0.00 0.00 0.18 0.13
Infrastructure Deduction 0.31 0.00 0.00 0.00 0.18 0.13
Market Factor 1.40 0.00 0.00 0.00 0.79 0.60
Net Acres 4.19 0.00 0.00 0.00 2.38 1.81
Underutilized Land
Gross Acres 79.02 0.00 0.00 0.00 26.46 52.55
Critical Areas 15.01 0.00 0.00 0.00 0.00 15.01
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 3.20 0.00 0.00 0.00 1.32 l.88
Infrastructure Deduction 3.20 0.00 0.00 0.00 1.32 l.88
Market Factor 14.40 0.00 0.00 0.00 5.95 8.45
Net Acres 43.20 0.00 0.00 0.00 17.86 25.34
Sources: City of Everson, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY PAGE 97
BUILDABLE LANDS REPORT JULY 2022, REVISED FEB 2023
Exhibit 46. Developable Nonresidential Land Capacity, Everson UGA, 2021-2036
Net Developable Employment Acres
(Vacant, PU, UU)
Commercial Developable Acres
Assumed Commercial Density (FAR)
Subtotal: Commercial Capacity (SF)
Existing Commercial Space (SF)
Pending Commercial Space (SF)
Master Planned Commercial Space (SF)
Subtotal: Net Commercial Capacity (SF)
Potential Occupied Commercial Space (SF)
Commer c i a I Employment Capacity
Industrial Developable Acres
Assumed Industrial Density (FAR)
Subtotal: Industrial Capacity (SF)
Existing Industrial Space (SF)
Pending Industrial Space (SF)
Master Planned Industrial Space (SF)
Subtotal: Net Industrial Capacity (SF)
Potential Occupied Industrial Space (SF)
Industrial Employment Capacity
Net Commercial & Industrial Capacity (SF)
UGA RES RES-7500 RMU COM LI
179.45 0.00 0.00 0.00 27.66 151.79
27.66 27.66
0.3
313,283 313,283
4,592 4,592
308,691 308,691
293,256 293,256 ------------------------367
151.79
1,983,592
84,096
1,909,122
1,813,666
1,208
2,217,813
367
151.79
0.3
-1,983,592
9,626 74,470
-1,909,122
-1,813,666
1,208
308,691 1,909,122
Potential Occupied Commercial & Industrial 2,106,922 293,256 1,813,666 ------------------------Em p Io y men t Capacity 1,575 367 1,208
Remaining Employment Growth to
Accommodate (2021-2036)
Employment Capacity Surplus (Deficit)
510
1,065
Sources: City of Everson, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 98
JULY 2022, REVISED FEB 2023
7. Ferndale UGA
The Ferndale Urban Growth Area is the
second largest in the County and is projected
to reach a total population and employment of
19,591 and 9,372 respectively by 2036. The
UGA has projected growth allocation of 5,942
for population and 3,478 for employment
between 2016 and 2036 (Exhibit 1 and
Exhibit 2).
Achieved Growth 2016-2021
Based on permit data collected between 2016
and 2021 and occupancy and persons per
household and square feet per employee
assumptions, the Ferndale UGA grew by an
estimated 2,089 population (99% within the
City) and 1,001 employment (94% within the
City) (Exhibit 6 and Exhibit 7).
The City of Ferndale has achieved residential
densities of 6.1 units per net acre, a
commercial FAR of 0.09, and an industrial
FAR of 0.19 between 2016 and 2021. Achieved
residential densities are greater than the
planned densities for residential within the
Whatcom County Comprehensive Plan of
between 6.0 and 10.0 units per net acre. The
City of Ferndale has not adopted commercial
or industrial planned densities (Exhibit 11).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
The unincorporated portions of the Ferndale
UGA have an achieved residential density of
0.3 units per acre, based on construction of
three dwelling units in the 2016-2021 time
period (Exhibit 11). Densities within the City
limits are consistent with county planned
urban densities for the City. The
unincorporated areas serve as urban growth
potential for future growth after annexation,
when city zoning is adopted and public water
and sewer provided.
Population and Employment Assumptions
Occupancy rate and population and
employment density assumptions for the
Ferndale UGA are:
• 96.4% Single Family occupancy rate
• 95.1% Multifamily occupancy rate
• 95.0% Commercial and Industrial
occupancy rate
• 2.850 Single Family persons per
household
• 2.310 Multifamily persons per
household
• 580 and 1,129 respectively Commercial
and Industrial square feet per employee
PAGE 99
JULY 2022, REVISED FEB 2023
The Ferndale UGA has an estimated 3,853
population and 2,477 employment growth
remaining to accommodate between 2021 and
2036 (Exhibit 6 and Exhibit 7).
Population Capacity 2021-2036
Based on achieved densities between 2016 and
2021 and planning assumptions, City of
Ferndale planners are assuming future single
family density between 5.0 and 7.0 units per
acre depending on the zone, and between 7.0
and 15.0 units per acre for multifamily zones
(Exhibit 4 7).
The Ferndale UGA has estimated net land
capacity for population growth of 561.94 acres
(Exhibit 48), with a total estimated potential
occupied unit capacity of 4,310 dwelling units.
Based on persons per household assumptions,
the UGA has an estimated population capacity
of 10,786, indicating an estimated population
capacity surplus of 6,933 (Exhibit 49).
Housing Needs by Type
The Whatcom County Comprehensive Plan
(Chapter 3-Housing, Chart 3 -Estimated
Dwelling Units Needed, page 3-8) indicates
that Ferndale has a need for 2,024 single-
family, 456 multi-family, and 125 other
("group housing") new dwelling units during
the 2013-2036 planning period. The
WHATCOM COUNTY
BUILDABLE LANDS REPORT
calculation for Chart 3 in the Whatcom County
Comprehensive Plan included building activity
from 2013. Therefore, the analysis below
includes permit data from April 1, 2013, even
though the planning period for this Buildable
Lands Report is from 2016.
• Between April 1, 2013 and March 31, 2021,
Ferndale issued building permits for 919
single-family and 532 multi-family units.
No group housing, which in Ferndale are
assisted living facilities, has been built
during this time. Comparing units built and
the needs indicated on Chart 3, Ferndale
needs to accommodate an additional 1,105
single-family units and 125 group housing
units between 2021 and 2036.
• The City and unincorporated UGA have an
estimated 2021-2036 capacity for 2,392
single-family and 1,918 multi-family
housing units (Exhibit 49). The multi-
family capacity includes group housing.
These capacities are sufficient to accommodate
the dwelling unit types anticipated in the
planning period as established in the Whatcom
County Comprehensive Plan (Chapter 3-
Housing, Chart 3).
PAGE 100
JULY 2022, REVISED FEB 2023
Employment Capacity 2021-2036
Based on achieved densities between 2016 and
2021 and planning assumptions, City of
Ferndale planners are assuming a future
commercial FAR of 0.09 to 0.20 and an
industrial FAR of 0.20 (Exhibit 50).
The Ferndale UGA has estimated net land
capacity for employment growth of 273.49
acres (Exhibit 51), with a total estimated
potential occupied commercial and industrial
capacity of approximately 2.5 million square
feet. Based on square feet per employee
assumptions, the Ferndale UGA has an
estimated employment capacity of 3,484,
indicating an estimated employment capacity
surplus of 1,007 (Exhibit 52).
Regulatory Changes
The City has evaluated development
regulations adopted in the review period (April
1, 2016 -March 31, 2021). Only Ordinances
1969 and 1976 could prevent assigned
densities from being achieved or impact the
quantity of land suitable for development in
the remainder of the 20-year planning period
(2021-2036). Both ordinances adopted new
regulations for stormwater treatment within
the City, these regulations may impact the
ability to meet densities in the City's
WHATCOM COUNTY
BUILDABLE LANDS REPORT
multifamily zones that have minimum gross
densities.
During this period of time the City of Ferndale
adopted several ordinances that would assist
with realizing increased density within the
UGA. Ordinance 1995 allowed for the
establishment of Accessory Dwelling Units
(ADUs) in all of the City's single family zones.
Ordinance 217 4 further reduced barriers to
the establishment of ADU s by eliminating off-
street parking and owner occupancy
requirements.
The City of Ferndale created new multifamily
zones through the adoption of ordinances 2026
and 2098. Ordinance 2026 established the
Residential Multifamily Medium Density zone
with a minimum density of 10 dwelling units
and a maximum density of 30 dwelling units
per gross acre. Ordinance 2098 established the
Residential Multifamily High Density Zone
with a minimum density of 15 dwelling units
per gross acre and no maximum density.
The City of Ferndale also adopted ordinance
2173 which allows duplex and single-family
attached duplexes in single family residential
zones which the City believes will assist infill
development with attaining densities at or
near the maximum permitted.
PAGE 101
JULY 2022, REVISED FEB 2023
Infrastructure Gaps
The City of Ferndale has reviewed capital
facility plans and/or consulted with service
providers. Based upon these actions, the City
has not identified any infrastructure gaps that
would prevent service providers from
supplying planned capital facilities to
developable land in the Ferndale UGA.
Analysis of Comprehensive Plan
Objectives and Reasonable Measures
The City of Ferndale has determined that
growth targets and assumptions are being
met. Therefore, an analysis of comprehensive
plan development assumptions, targets, and
objectives is not necessary. The City is
realizing efficient development of the land
within the UGA. The achieved density in the
UGA is in part a result of the City establishing
minimum densities in all of its residential
zones. No inconsistencies between planned
and actual growth have been identified in the
Ferndale UGA. Therefore, reasonable
measures are not required under RCW
36.70A.215.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 102
JULY 2022, REVISED FEB 2023
Residential Development
Exhibit 47. Residentia~ Development, Achieved and Assumed Densities, City of Ferndale, 2016-2021
Development Acres Dwelling Achieved Density
Zoning Designation Type Developed Units Density Assumed
(Units/Acre) (Units/Acre)
RS-H Single Family 23.9 101 4.22 7.00
RS-M Single Family 42.4 241 5.68 6.00
Multifamily 3.0 66 21.89 N/A
RS-L Single Family 38.1 197 5.18 5.00
MC Single Family 2.3 19 8.41 7.00
Multifamily 3.4 64 18.55 7.00
RMH Multifamily 0.4 8 22.22 15.00
RMM Single Family 3.9 2 0.51 N/A
Multifamily 6.0 55 9.15 10.00
RO Single Family 1.0 5 4.76 N/A
Multifamily 5.5 38 6.85 7.00
UR Multifamily 0.7 12 17.91 15.00
cc Multifamily 0.3 5 15.36 12.00
Sources: City of Ferndale, 2022; Community Attributes Inc., 2021.
Note: "Density Assumed" is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 103
JULY 2022, REVISED FEB 2023
Exhibit 48. Residential Land Supply, Ferndale UGA, 2021-2036
UGA Total cc GB LI M MC RMH RMM
Vacant Land
Gross Acres 626.73 0.00 0.00 0.00 0.00 159.88 12.31 59.41
Critical Areas 262.06 0.00 0.00 0.00 0.00 69.41 9.78 28.40
Future Public Uses 13.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 17.08 0.00 0.00 0.00 0.00 4.52 0.13 l.55
Infrastructure Deduction 17.08 0.00 0.00 0.00 0.00 4.52 0.13 l.55
Market Factor 46.13 0.00 0.00 0.00 0.00 12.21 0.34 4.19
Net Acres 261.39 0.00 0.00 0.00 0.00 69.21 1.94 23.72
Partially-Used Land
Gross Acres 664.19 0.00 0.00 0.00 0.00 6.06 0.00 6.73
Critical Areas 219.43 0.00 0.00 0.00 0.00 0.97 0.00 0.49
Future Public Uses 5.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 19.40 0.00 0.00 0.00 0.00 0.25 0.00 0.31
Infrastructure Deduction 19.40 0.00 0.00 0.00 0.00 0.25 0.00 0.31
Market Factor 87.30 0.00 0.00 0.00 0.00 l.14 0.00 l.40
Net Acres 261.89 0.00 0.00 0.00 0.00 3.43 0.00 4.21
Underutilized Land
Gross Acres 76.26 0.00 0.00 0.00 0.00 32.61 5.77 27.l l
Critical Areas 18.99 0.00 0.00 0.00 0.00 9.25 0.07 5.83
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 2.86 0.00 0.00 0.00 0.00 l.17 0.28 l.06
Infrastructure Deduction 2.86 0.00 0.00 0.00 0.00 l.17 0.28 l.06
Market Factor 12.89 0.00 0.00 0.00 0.00 5.26 l.28 4.79
Net Acres 38.66 0.00 0.00 0.00 0.00 15.77 3.85 14.36
Sources: City of Ferndale, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
RO RR RS-H RS-L RS-M
12.95 0.00 50.45 219.47 99.91
9.04 0.00 30.52 67.45 37.60
0.00 0.00 0.00 10.00 3.00
0.00 0.00 0.00 0.00 0.00
0.20 0.00 l.00 6.60 2.97
0.20 0.00 l.00 6.60 2.97
0.53 0.00 2.69 17.82 8.01
2.99 0.00 15.25 101.01 45.38
0.44 0.00 40.29 462.56 148.12
0.00 0.00 24.27 133.83 59.87
0.00 0.00 0.00 5.00 0.00
0.00 0.00 0.00 0.00 0.00
0.02 0.00 0.80 13.60 4.41
0.02 0.00 0.80 13.60 4.41
0.10 0.00 3.60 6 l.19 19.86
0.30 0.00 10.81 183.58 59.57
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
PAGE 104
JULY 2022, REVISED FEB 2023
UR
12.33
9.85
0.00
0.00
0.12
0.12
0.34
1.90
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
10.77
3.84
0.00
0.00
0.35
0.35
l.56
4.68
Exhibit 49. Developable Residential Land Capacity, Ferndale UGA, 2021-2036
UGA cc GB LI M MC RMH
Net Developable Residential Acres
(Vacant, PU, UU) 561.94 0.00 0.00 0.00 0.00 BB.41 5.78
Single Family Developable Acres 428.22 12.63
Assumed Single Family Density (units/acre) 7
Subtotal Single Family Unit Capacity 2,323 88
Existing Single Family Units 363 13 51 4 4 19 24
Pending Single Family Units 262 3 3 150
Master Planned Single Family Units
Subtotal: Net Single Family Unit Capacity 2,392 3 3 219
Potential Occupied Single Family Units 2,306 3 3 211
Single Family Population Capacity 6,572 8 8 602
Multifamily Developable Acres 133.72 75.78 5.78
Assumed Multifamily Density (units/acre) 12 7 15
Subtotal Multifamily Unit Capacity 1,162 530 87
Existing Multifamily Units 180 4 16 5 7
Pending Multifamily Units 916 149 416 116
Master Planned Multifamily Units
Subtotal: Net Multifamily Unit Capacity 1,918 149 941 196
Potential Occupied Multifamily Units 1,824 142 895 186
Multifamily Population Capacity 4,214 327 2,067 431
Net Dwelling Unit Capacity 4,310 152 3 1,160 196
Potential Occupied Dwelling Units 4,130 145 3 1,106 186
Population Capacity 10,786 335 8 2,669 431
Remaining Population Growth to
Accommodate (2021-2036) 3,853
Population Capacity Surplus (Deficit) 6,933
Sources: City of Ferndale, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
RMM
42.29
30
42.29
10
423
131
190
482
458
1,059
482
458
1,059
RO RR RS-H RS-L RS-M
3.29 0.00 26.06 284.58 104.95
26.06 284.58 104.95
7 5 6
182 1,423 630
2 12 80 82
6 82 18
176 1,425 566
170 1,374 546
484 3,915 1,555
3.29
7 15
23
23
22
51
23 176 1,425 566
22 170 1,374 546
51 484 3,915 1,555
PAGE 105
JULY 2022, REVISED FEB 2023
UR
6.58
41
6.58
15
99
17
45
127
121
279
127
121
279
Commercial and Industrial Development
Exhibit 50. Nonresidential Development, Achieved and Assumed Densities, City of Ferndale, 2016-2021
Zoning Designation Development Acres Built Square Achieved Assumed
Tyee Develoeed Feet Density (FAR) Density {FAR)
RS-H Commercial 1.3 2,337 0.04 N/A
Industrial N/A N/A N/A N/A
RS-M Commercial 4.4 3,012 0.02 N/A
Industrial N/A N/A N/A N/A
MC Commercial 16.8 105,793 0.14 0.09
Industrial 1.5 19,844 0.30 N/A
RO Commercial N/A N/A N/A 0.09
Industrial N/A N/A N/A N/A
GB Commercial 90.7 307,415 0.08 0.09
Industrial 39.4 269,619 0.16 0.15
M Commercial N/A N/A N/A N/A
Industrial N/A N/A N/A. 0.20
LI Commercial N/A N/A N/A N/A
Industrial 5.5 103,994 0.44 0.20
UR Commercial 0.3 7,061 0.49 0.09
Industrial N/A N/A N/A N/A
cc Commercial 0.1 156 0.03 0.50
Industrial N/A N/A N/A N/A
Sources: City of Ferndale, 2022; Community Attributes Inc., 2021.
Note: Assumed Density is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 106
JULY 2022, REVISED FEB 2023
Exhibit 51. Developable Nonresidential Land Supply, Ferndale UGA, 2021-2036
UGA Total cc GB LI M MC Pub RMH
Vacant Land
Gross Acres 609.33 2.61 265.l l 47.23 130.31 68.52 8.20 0.00
Critical Areas 279.58 l.72 100.25 31.28 91.63 29.75 l.58 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 77.98 0.00 77.98 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 12.59 0.04 4.34 0.80 l.93 l.94 0.33 0.00
Infrastructure Deduction 12.59 0.04 4.34 0.80 l.93 l.94 0.33 0.00
Market Factor 33.99 0.12 l l .73 2.15 5.22 5.23 0.89 0.00
Net Acres 192.61 0.68 66.46 12.20 29.59 29.66 5.06 0.00
Partially-Used Land
Gross Acres l 4 l.41 0.00 105.28 9.19 24.24 2.60 0.00 0.00
Critical Areas 53.74 0.00 38.18 7.02 8.13 0.42 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 36.18 0.00 36.18 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 2.57 0.00 l.55 0.ll 0.81 0.1 l 0.00 0.00
Infrastructure Deduction 2.57 0.00 l.55 0.1 l 0.81 0.1 l 0.00 0.00
Market Factor 11.58 0.00 6.96 0.49 3.62 0.49 0.00 0.00
Net Acres 34.75 0.00 20.87 1.46 10.87 1.47 0.00 0.00
Underutilized Land
Gross Acres 213.28 2.29 124.32 39.76 9.30 13.98 0.00 0.00
Critical Areas 68.38 0.23 44.30 16.15 2.77 3.96 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 76.56 0.00 76.56 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 3.42 0.10 0.17 1.18 0.33 0.50 0.00 0.00
Infrastructure Deduction 3.42 0.10 0.17 1.18 0.33 0.50 0.00 0.00
Market Factor 15.38 0.46 0.78 5.31 l.47 2.25 0.00 0.00
Net Acres 46.13 1.39 2.34 15.94 4.41 6.76 0.00 0.00
Sources: City of Ferndale, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
RMM
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
RO RR RS-L RS-M UR
3.24 82.73 0.00 0.00 l.37
2.26 20.01 0.00 0.00 l.09
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.05 3.14 0.00 0.00 0.01
0.05 3.14 0.00 0.00 0.01
0.13 8.47 0.00 0.00 0.04
0.75 47.98 0.00 0.00 0.21
0.11 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.01 0.00 0.00 0.00 0.00
0.01 0.00 0.00 0.00 0.00
0.02 0.00 0.00 0.00 0.00
0.07 0.00 0.00 0.00 0.00
0.00 22.45 0.00 0.00 l.20
0.00 0.55 0.00 0.00 0.43
0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00
0.00 l.10 0.00 0.00 0.04
0.00 l.10 0.00 0.00 0.04
0.00 4.93 0.00 0.00 0.17
0.00 14.78 0.00 0.00 0.52
PAGE 107
JULY 2022, REVISED FEB 2023
Exhibit 52. Developable Nonresidential Land Capacity, Ferndale UGA, 2021-2036
UGA cc GB LI M MC Pub RMH
Net Developable Employment Acres
(Vacant, PU, UU) 273.49 2.07 89.67 29.60 44.87 37.89 5.06 0.00
Commercial Developable Acres 199.01 2.07 89.67 37.89 5.06
Assumed Commercial Density (FAR) 0.5 0.1 0.1 0.1
Subtotal: Commercial Capacity (SF) 981,204 45,050 351,548 -148,545 19,847
Existing Commercial Space (SF) 48,652 9,518 9,839 1,700 17,523
Pending Commercial Space (SF) 742,332 5,000 674,886 54,446
Master Planned Commercial Space (SF)
Subtotal: Net Commercial Capacity (SF) 1,683,790 40,532 1,016,595 -185,468 19,847
Potential Occupied Commercial Space (SF) 1,599,601 38,505 965,766 -176,195 18,855
Commercial Employment Capacity 2,758 66 1,665 304 33
Industrial Developable Acres 74.48 29.60 44.87
Assumed Industrial Density (FAR) 0.2 0.2 0.2
Subtotal: Industrial Capacity (SF) 648,830 -257,902 390,928
Existing Industrial Space (SF) 123,676 24,919 4,000 29,076 60,939 1,984
Pending Industrial Space (SF) 246,662 -215,806 30,856
Master Planned Industrial Space (SF)
Subtotal: Net Industrial Capacity (SF) 862,416 -215,806 253,902 392,708
Potential Occupied Industrial Space (SF) 819,295 -205,016 241,207 373,073
Industrial Employment Capacity 726 182 214 330
Net Commercial & Industrial Capacity (SF) 2,546,206 40,532 1,232,401 253,902 392,708 185,468 19,847
Potential Occupied Commercial & Industrial 2,418,896 38,505 l, 170,781 241,207 373,073 176,195 18,855
Employment Capacity 3,484 66 1,847 214 330 304 33
Remaining Employment Growth to
Accommodate (2021-2036) 2,477
Employment Capacity Surplus (Deficit) 1,007
Sources: City of Ferndale, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
RMM
0.00
4,610
RO RR RS-L RS-M UR
0.82 62.77 0.00 0.00 0.73
0.82 62.77 0.73
0.1 0.2 0.1
3,220 410,128 2,866
1,200 4,262
8,000
3,220 410,128 8,000
3,059 389,622 7,600
5 672 13
0.2
1,200 1,558
3,220 410,128 8,000
3,059 389,622 7,600
5 672 13
PAGE 108
JULY 2022, REVISED FEB 2023
8. Lynden UGA
The Lynden Urban Growth Area is projected
to reach a total population and employment of
19,275 and 7,103 respectively by 2036. The
UGA has projected allocation of 5,568 for
population growth and 1,876 for employment
growth between 2016 and 2036 (Exhibit 1 and
Exhibit 2).
Achieved Growth 2016-2021
Based on permit data collected between 2016
and 2021 and occupancy and persons per
household and square feet per employee
assumptions, the Lynden UGA grew by an
estimated 1,685 people (nearly 100% within
the City of Lynden) and 624 jobs (100% within
the City) (Exhibit 6 and Exhibit 7).
The City of Lynden has an overall achieved
residential density of 7.2 units per net acre
between 2016 and 2021. Lynden's single-
family zones have built out at 4.8 units per net
acre, its multi-family zones achieved 17.5
units per net acre. The overall achieved
residential density of 7.2 units per net acre is
greater than the adopted planned density of
5.0 units per acre in the 2016 City of Lynden
Comprehensive Plan. The overall achieved
residential density also falls within the
adopted planned residential density for the
City of Lynden of 6.0 to 10.0 units per net acre
WHATCOM COUNTY
BUILDABLE LANDS REPORT
in the Whatcom County Comprehensive Plan
(Exhibit 11).
The unincorporated portions of the Lynden
UGA have an achieved residential density of
1.7 units per acre (Exhibit 11). This density,
which is based on construction of one dwelling
unit in the 2016-2021 time period, lags county
planned urban densities for the City. Land in
the UGA, outside of City limits, is currently
zoned for Agriculture or urban residential
uses. The Agriculture zone does not allow
urban densities. This land would need to be
rezoned for urban land uses and served with
public water and sewer, which typically occurs
upon annexation. The urban residential zones
in the unincorporated portion of the UGA do
not allow urban densities until public water
and sewer are available, which typically occurs
upon annexation. These unincorporated areas
serve as future urban growth potential. Until
annexation, they do not have access to City
infrastructure or urban densities.
Neither the City of Lynden nor Whatcom
County have adopted planned densities for
commercial or industrial development.
Between 2016 and 2021, commercial
development in the City of Lynden achieved an
overall FAR of 0.12. Totals for commercial
development are skewed by one project -the
PAGE 109
JULY 2022, REVISED FEB 2023
construction of the new Lynden Middle School
on a 30-acre vacant parcel. That one project
accounted for 60% of the built commercial
square footage during this time. Industrial
development saw an overall FAR of 0.26. This
was largely driven by construction associated
with Lynden Door, Inc expansion and the new
cold storage plants built to store agricultural
products. More than 400,000 square feet of
new industrial space was built in the city
limits during this time. The unincorporated
areas of the Lynden UGA did not see any
commercial or industrial development
(Exhibit 11).
Population and Employment Assumptions
Specific occupancy rate and population and
employment density assumptions for
estimating future growth capacity in the
Lynden UGA are:
• 98.0% Single Family occupancy rate
• 95.0% Multifamily occupancy rate
• 95.0% Commercial and Industrial
occupancy rate
• 2.88 Single Family persons per
household
• 1. 70 Multifamily persons per household
WHATCOM COUNTY
BUILDABLE LANDS REPORT
• 721 and 1,037 respectively Commercial
and Industrial square feet per employee
Based on estimated growth since 2016 and
population and employment projections
adopted in the Whatcom County
Comprehensive Plan, the Lynden UGA is
expected to accommodate another 3,880 people
and 1,252 jobs between 2021 and 2036
(Exhibit 6 and Exhibit 7).
Population Capacity 2021-2036
Based on achieved densities between 2016 and
2021 and planning assumptions, City of
Lynden planners are assuming future single
family density of 4.0 and 8.0 units per acre
depending on the zone. Assumed multifamily
densities range between 8.0 and 24.0 units per
acre (Exhibit 53).
The Lynden UGA has an estimated net land
capacity for population growth of 459.5 acres
(Exhibit 54), with a total estimated potential
occupied unit capacity of 3,481 dwelling units.
Based on persons per household assumptions,
the UGA has an estimated population capacity
of 8,467, indicating an estimated population
capacity surplus of 4,587 (Exhibit 55).
PAGE 110
JULY 2022, REVISED FEB 2023
Housing Needs by Type
The Whatcom County Comprehensive Plan
(Chapter 3-Housing, Chart 3 -Estimated
Dwelling Units Needed, page 3-8) indicates
that Lynden has a need for 1,887 single-
family, 627 multi-family, and 97 other ("group
housing") new dwelling units during the 2013-
2036 planning period. The calculation for
Chart 3 in the Whatcom County
Comprehensive Plan included building activity
from 2013. Therefore, the analysis below
includes permit data from April 1, 2013, even
though the planning period for this Buildable
Lands Report is from 2016.
• Between April 1, 2013 and March 31, 2021,
Lynden issued building permits for 652
single-family and 551 multi-family units.
No group housing, which in Lynden are
assisted living facilities, has been built
during this time. Comparing units built and
the needs indicated on Chart 3, Lynden
needs an additional 1,235 single-family
units, 76 multi-family units, and 97 group
housing units between 2021 and 2036.
• The City and unincorporated UGA have an
estimated 2021-2036 capacity for 2,204
single-family and 1,391 multi-family
housing units (Exhibit 55). The multi-
family capacity includes group housing.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
These capacities are sufficient to accommodate
the dwelling unit types needed in the planning
period as established in the Whatcom County
Comprehensive Plan (Chapter 3-Housing,
Chart 3).
Employment Capacity 2021-2036
Looking forward, Lynden is assuming a FAR
of 0.184 for future commercial development.
This number (0.184) is the average achieved
commercial FAR for all the small cities in the
County between 2016-2021. Lynden is using
this assumption, which is different than its
achieved commercial FAR of 0.12 because
Lynden's achieved commercial development
data during this time was skewed by the
Lynden Middle School project. Additionally,
Lynden is assuming a FAR of 0.26 for future
industrial development. This is what was
achieved for industrial development between
2016-2021 (Exhibit 56).
The Lynden UGA has an estimated net land
capacity for employment growth of 388.4 acres
(Exhibit 57), with a total estimated potential
occupied commercial and industrial capacity of
3. 7 million square feet. Based on square feet
per employee assumptions, the Lynden UGA
has an estimated employment capacity of
4,038, indicating an estimated employment
capacity surplus of 2,786 (Exhibit 58).
PAGE 111
JULY 2022, REVISED FEB 2023
Regulatory Changes
Since 2016, the City of Lynden has approved
several regulatory changes that impact either
the amount of land available for development,
or the densities and types of development
allowed on buildable lands. These regulatory
changes are documented in the Data Reporting
Tool worksheet.
Three annexations brought more than 90 acres
of unincorporated UGA into the City, the
largest (80 acres) of which is in the Pepin
Creek Subarea, the area expected to house the
majority of incoming residents during the
remainder of the planning period.
Subsequently, the City adopted the Pepin
Creek Subarea Plan which established zoning
designations (including the RM-PC zone which
is a new multifamily zone), development
densities (including minimum density
requirements), transportation routes, and
recreational and open space opportunities
within this 460-acre subarea.
Multiple rezones and Comprehensive Plan
Amendments have been approved that are
adapting to employment growth needs (i.e.
increasing Industrial lands) and, in general,
trend toward rezoning land to increase
residential densities.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
The City updated its Critical Areas Ordinance
and Shoreline Master Program, which regulate
potential impacts to environmental resources.
These regulations restrict development in
protected locations, as they establish buffers,
setbacks, and the regulatory process for
protecting these resources. The City has
considered known critical areas and their
buffers in its evaluation of population and
employment growth and determined that the
land supply can still accommodate projected
growth during the remainder of the planning
period.
Finally, other regulatory updates expanded
the allowed types of commercial uses in
commercial zones and business parks,
incentivized low impact development
techniques, and eased restrictions for making
an accessory dwelling unit legal on residential
properties.
Infrastructure Gaps
The City of Lynden has reviewed capital
facility plans and/or consulted with service
providers that will provide service for future
growth. Based on this review, Lynden has not
identified infrastructure gaps that would
prevent service providers from supplying
planned capital facilities to developable land
in the Lynden UGA within the planning period
(2021-2036).
PAGE 112
JULY 2022, REVISED FEB 2023
Analysis of Comprehensive Plan
Objectives and Reasonable Measures
The City of Lynden has determined that
growth targets and assumptions are being
met. Therefore, an analysis of comprehensive
plan development assumptions, targets, and
objectives is not necessary. No inconsistencies
between planned and actual growth have been
identified in the Lynden UGA. Therefore,
reasonable measures are not required under
RCW 36. 70A.215.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 113
JULY 2022, REVISED FEB 2023
Residential Development
Exhibit 53. Residential Development, Achieved and Assumed Densities, City of Lynden, 2016-2021
Zoning Development Acres Dwelling Achieved Density
Designation Type Developed Units Density Assumed
(Units/ Acre) (Units/ Acre)
RS-100 Single Family 25.9 93 3.59 4.00
Multifamily 0.4 4 8.97 N/A
RS-84 Single Family 0.4 2 4.82 4.50
RS-72 Single Family 41.8 236 5.65 5.00
RMD Single Family 8.7 16 1.84 8.00
Multifamily 0.7 9 12.42 N/A
MH Single Family N/A N/A N/A
RM-1 Single Family 0.5 5 10.90 N/A
Multifamily 1.7 14 8.36 8.00
RM-2 Single Family 2.1 11 5.29 N/A
M ult if amily 1.5 17 11.01 12.00
RM-3 Single Family 6.4 49 7.60 N/A
Multifamily 10.0 144 14.34 16.00
RM-4 Multifamily 0.7 12 16.76 24.00
RM-PC Multifamily N/A N/A N/A 12.00
CSL Multifamily 3.3 128 38.88 N/A
HBO Multifamily 0.2 9 50.01 N/A
Sources: City of Lynden, 2022; Community Attributes Inc., 2021.
Note: "Density Assumed" is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 114
JULY 2022, REVISED FEB 2023
Exhibit 54. Residential Land Supply, Lynden UGA, 2021-2036
UGA Total RS-100 RS-84 RS-72
Vacant Land
Gross Acres 345.52 49.26 0.00 52.72
Critical Areas 69.30 19.58 0.00 3.65
Future Public Uses 1.28 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 13.75 1.48 0.00 2.45
Infrastructure Deduction 13.75 l.48 0.00 2.45
Market Factor 37.12 4.01 0.00 6.62
Net Acres 210.33 22.71 0.00 37.54
Partially-Used Land
Gross Acres 426.03 81.78 0.00 70.51
Critical Areas 68.26 13.28 0.00 7.60
Future Public Uses 0.28 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 17.88 3.43 0.00 3.15
Infrastructure Deduction 17.88 3.43 0.00 3.15
Market Factor 80.44 15.41 0.00 14.15
Net Acres 241.31 46.24 0.00 42.46
Underutilized Land
Gross Acres 11.59 0.00 0.00 0.00
Critical Areas 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 0.58 0.00 0.00 0.00
Infrastructure Deduction 0.58 0.00 0.00 0.00
tv"\arket Factor 2.6 l 0.00 0.00 0.00
Net Acres 7.82 0.00 0.00 0.00
Sources: City of Lynden, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
RMD MH
140.61 0.00
19.06 0.00
0.00 0.00
0.00 0.00
6.08 0.00
6.08 0.00
16.41 0.00
9298 0.00
161.34 19.21
4.58 8.69
0.00 0.00
0.00 0.00
7.84 0.53
7.84 0.53
35.27 2.37
105.81 7.10
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
RM-1
0.42
0.00
0.00
0.00
0.02
O.Q2
0.06
0.32
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
RM-2 RM-3 RM-4 RM-PC CSR CSL ID
22.74 0.27 3.82 75.69 0.00 0.00 0.00
8.65 0.00 0.00 18.37 0.00 0.00 0.00
1.28 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.64 O.Ol 0.19 2.87 0.00 0.00 0.00
0.64 0.01 0.19 2.87 0.00 0.00 0.00
1.73 0.04 0.52 7.74 0.00 0.00 0.00
9.80 0.20 2.92 43.86 0.00 0.00 0.00
58.46 29.62 5.11 0.00 0.00 0.00 0.00
18.96 14.71 0.44 0.00 0.00 0.00 0.00
0.00 0.28 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
1.97 0.73 0.23 0.00 0.00 0.00 0.00
1.97 0.73 0.23 0.00 0.00 0.00 0.00
8.89 3.29 1.05 0.00 0.00 0.00 0.00
26.66 9.88 3.15 0.00 0.00 0.00 0.00
1.20 10.38 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.06 0.52 0.00 0.00 0.00 0.00 0.00
0.06 0.52 0.00 0.00 0.00 0.00 0.00
0.27 2.34 0.00 0.00 0.00 0.00 0.00
0.81 7.01 0.00 0.00 0.00 0.00 0.00
PAGE 115
JULY 2022, REVISED FEB 2023
IBZ
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.06
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Exhibit 55. Developable Residential Land Capacity, Lynden UGA, 2021-2036
UGA RS-100 RS-84 RS-72
Net Developable Residential Acres
(Vacant, PU, UU) 459.46 68.95 0.00 80.00
Single Family Developable Acres 354.85 68.95 -80.00
Assumed Single Family Density (units/acre) 4 5 5
Subtotal Single Family Unit Capacity 2,266 276 400
Existing Single Family Units 167 33 24
Pending Single Family Units
Master Planned Single Family Units
Subtotal: Net Single Family Unit Capacity 2,204 243 376
Potential Occupied Single Family Units 2,160 238 368
Single Family Population Capacity 6,221 686 -1,061
Multifamily Developable Acres 104.62
Assumed Multifamily Density [units/acre)
Subtotal Multifamily Unit Capacity 1,395
Existing Multifamily Units 8
Pending Multifamily Units
Master Planned Multifamily Units
Subtotal: Net Multifamily Unit Capacity 1,391
Potential Occupied Multifamily Units 1,321
Multifamily Population Capacity 2,246
Net Dwelling Unit Capacity 3,595 243 376
Potential Occupied Dwelling Units 3,481 238 368
Population Capacity 8,467 686 -1,061
Remaining Population Growth to
Accommodate (2021-2036) 3,880
Population Capacity Surplus (Deficit) 4,587
Sources: City of Lynden, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
RMD MH
198.80 7.10
198.80 7.10
8
1,590
5 29
1,585
1,553
4,474
-
1,585
1,553
4,474
RM-1 RM-2 RM-3 RM-4 RM-PC CSR CSL ID
0.32
0.32
8
3
3
3
5
3
3
5
37.28 17.09 6.07 43.86 0.00 0.00 0.00
19 12 23 20
37.28 17.09 6.07 43.86
12 16 24 12
447 273 146 526
4 4
443 273 146 526
421 259 139 500
715 441 236 849
443 273 146 526
421 259 139 500
715 441 236 849
PAGE 116
JULY 2022, REVISED FEB 2023
IBZ
0.00
Commercial and Industrial Development
Exhibit 56. Nonresidential Development, Achieved and Assumed Densities, City of Lynden, 2016-2021
Zoning Development Acres Built Square Achieved Assumed
Designation Ty~e Develo~ed Feet Density (FAR) Density (FAR)
RS-72 Commercial 30.6 113,444 0.09
CSR Commercial 3.0 31,976 0.25 0.18
CSL Commercial 2.7 37,744 0.32 0.18
HBO Commercial 0.18
ID Industrial 16.1 198,000 0.28 0.26
IBZ Commercial 1.5 8,112 0.13
Industrial 15.5 185,818 0.28 0.26
PU Industrial 3.9 22,000 0.13
Sources: City of Lynden, 2022; Community Attributes Inc., 2021.
Note: Assumed Density is the assumed density for evaluation of land suitable for development by zone. RS-72 development was a School.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 117
JULY 2022, REVISED FEB 2023
Exhibit 57. Developable Nonresidential Land Supply, Lynden UGA, 2021-2036
UGA Total RS-100 RM-2 RM-3 RM-4 CSR CSL HBD ID IBZ PU
Vacant Land
Gross Acres 299.58 0.00 0.00 0.00 0.00 69.80 17.52 0.00 78.25 134.01 0.00
Critical Areas 16.67 0.00 0.00 0.00 0.00 7.93 5.32 0.00 3.10 0.32 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 14.15 0.00 0.00 0.00 0.00 3.09 0.61 0.00 3.76 6.68 0.00
Infrastructure Deduction 14.15 0.00 0.00 0.00 0.00 3.09 0.61 0.00 3.76 6.68 0.00
Market Factor 38.19 0.00 0.00 0.00 0.00 8.35 1.65 0.00 10.15 18.05 0.00
Net Acres 216.43 0.00 0.00 0.00 0.00 47.34 9.33 0.00 57.49 102.27 0.00
Partially-Used Land
Gross Acres 82.26 0.00 0.00 0.00 0.00 39.30 3.66 0.00 31.50 7.80 0.00
Critical Areas 5.75 0.00 0.00 0.00 0.00 4.94 0.00 0.00 0.00 0.81 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 3.83 0.00 0.00 0.00 0.00 1.72 0.18 0.00 1.57 0.35 0.00
Infrastructure Deduction 3.83 0.00 0.00 0.00 0.00 1.72 0.18 0.00 1.57 0.35 0.00
Market Factor 17.21 0.00 0.00 0.00 0.00 7.73 0.82 0.00 7.09 1.57 0.00
Net Acres 51.64 0.00 0.00 0.00 0.00 23.19 2.47 0.00 21.26 4.72 0.00
Underutilized Land
Gross Acres 186.70 0.00 0.00 0.00 0.00 82.57 26.22 0.00 62.72 15.19 0.00
Critical Areas 8.51 0.00 0.00 0.00 0.00 7.72 0.79 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 8.91 0.00 0.00 0.00 0.00 3.74 1.27 0.00 3.14 0.76 0.00
Infrastructure Deduction 8.91 0.00 0.00 0.00 0.00 3.74 1.27 0.00 3.14 0.76 0.00
Market Factor 40.09 0.00 0.00 0.00 0.00 16.84 5.72 0.00 14.11 3.42 0.00
Net Acres 120.28 0.00 0.00 0.00 0.00 50.52 17.17 0.00 42.33 10.25 0.00
Sources: City of Lynden, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY PAGE 118
BUILDABLE LANDS REPORT JULY 2022, REVISED FEB 2023
Exhibit 58. Developable Nonresidential Land Capacity, Lynden UGA, 2021-2036
Net Developable Employment Acres
(Vacant, PU, UU)
Commercial Developable Acres
Assumed Commercial Density (FAR)
Subtotal: Commercial Capacity (SF)
Existing Commercial Space (SF)
Pending Commercial Space (SF)
Master Planned Commercial Space (SF)
UGA
388.35
150.02
1,202,435
16,054
Subtotal: Net Commercial Capacity (SF) l, 195,888
Potential Occupied Commercial Space (SF) l, 136,094
RS-100 RM-2 RM-3 RM-4 CSR CSL HBD ID
0.00 0.00 0.00 0.00 121.05 28.97 0.00 121.09
121.05 28.97
0.2 0.2 0.2
-970,220 232,215
5,281 1,266
-964,939 230,949
-916,692 219,402
IBZ PU
117.24 0.00
9,507
-------------------------------Commercial Employment Capacity
Industrial Developable Acres
Assumed Industrial Density (FAR)
Subtotal: Industrial Capacity (SF)
Existing Industrial Space (SF)
Pending Industrial Space (SF)
Master Planned Industrial Space (SF)
Subtotal: Net Industrial Capacity (SF)
Potential Occupied Industrial Space (SF)
Industrial Employment Capacity
Net Commercial & Industrial Capacity (SF)
1,575
238.33
2,699,209
62,752 14,128 5,568 6,888 6,080
2,688,861
2,554,418
2,463
1,271 304
1,200 18,540
121.09
0.3
117.24
0.3
-1,371,372 1,327,837
10,348
-1,361,024 1,327,837
-1,292,973 1,261,445
1,247 1,216
3,884,749 -964,939 230,949 -1,361,024 1,327,837
Potential Occupied Commercial & Industrial 3,690,512 -916,692 219,402 -1,292,973 1,261,445 -------------------------------Em p Io y men t Capacity 4,038 1,271 304 1,247 1,216
Remaining Employment Growth to
Accommodate (2021-2036)
Employment Capacity Surplus (Deficit)
1,252
2,786
Sources: City of Lynden, 2022; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 119
JULY 2022, REVISED FEB 2023
9. Nooksack UGA
The Nooksack Urban Growth Area is projected
to reach a total population and employment of
2,425 and 369 respectively by 2036. The UGA
has projected growth allocation of 861 for
population and 100 for employment between
2016 and 2036 (Exhibit 1 and Exhibit 2).
Achieved Growth 2016-2021
Based on permit data collected between 2016
and 2021 and occupancy and persons per
household and square feet per employee
assumptions, the Nooksack UGA grew by an
estimated 177 population and 8 employment
(100% within the City) (Exhibit 6 and
Exhibit 7).
Between 2016 and 2021, the City of Nooksack
achieved an overall residential density of 5.2
units per acre. No development occurred
within the unincorporated area of the UGA
within the period. The City of Nooksack
Comprehensive Plan has an adopted planned
residential density of 4.4 units per acre. The
Whatcom County Comprehensive Plan has
adopted planned residential density of 4.0 to
6.0 units per acre. Achieved residential
density within the City of Nooksack exceeded
the minimum planned density (Exhibit 11).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
The City Comprehensive Plan references
planned densities for commercial and
industrial developed based on the Whatcom
County Land Capacity Analysis. Whatcom
County has not adopted planned densities for
commercial or industrial uses. The City
achieved a commercial FAR of 0.14, below the
planned density of 0.25. The adopted planned
industrial FAR is 0.10. No industrial
development occurred within the City during
the review period (Exhibit 11).
Population and Employment Assumptions
Specific occupancy rate and population and
employment density assumptions for
estimating future growth capacity in the
Nooksack UGA are:
• 96.9% Single Family occupancy rate
• 94.5% Multifamily occupancy rate
• 95.0% Commercial and Industrial
occupancy rate
• 3.088 Single Family persons per
household
• 3.173 Multifamily persons per
household
• 605 and 795 respectively Commercial
and Industrial square feet per employee
The Nooksack UGA has an estimated 687
population and 92 employment growth
PAGE 120
JULY 2022, REVISED FEB 2023
remaining to accommodate between 2021 and
2036 (Exhibit 6 and Exhibit 7).
Population Capacity 2021-2036
The City of Nooksack is utilizing achieved
densities (when available) when estimating
future residential land capacity. Based on
achieved densities between 2016 and 2021 and
planning assumptions, City of Nooksack
planners are assuming future single family
density between 3.9 and 5.9 units per acre for
single family residential development. The
Nooksack UGA does not include any
multifamily zones (Exhibit 59).
The Nooksack UGA has estimated net land
capacity for population growth of 89.8 acres
(Exhibit 60), with a total estimated potential
occupied unit capacity of 416 dwelling units.
Based on persons per household assumptions,
the UGA has an estimated population capacity
of 1,283, indicating an estimated population
capacity surplus of 599 (Exhibit 61).
Housing Needs by Type
The Whatcom County Comprehensive Plan
(Chapter 3-Housing, Chart 3 -Estimated
Dwelling Units Needed, page 3-8) indicates
that Nooksack has a need for 243 single-
family, 48 multi-family, and 49 other ("group
housing") new dwelling units during the 2013-
WHATCOM COUNTY
BUILDABLE LANDS REPORT
2036 planning period. The calculation for
Chart 3 in the Whatcom County
Comprehensive Plan included building activity
from 2013. Therefore, the analysis below
includes permit data from April 1, 2013, even
though the planning period for this Buildable
Lands Report is from 2016.
• Between April 1, 2013 and March 31, 2021,
Nooksack issued building permits for 49
single-family and 10 multi-family units. No
group housing has been built during this
time. Comparing units built and the needs
indicated on Chart 3, Nooksack needs an
additional 194 single-family units, 38 multi-
family units, and 49 group housing units
between 2021 and 2036.
• The City and unincorporated UGA have an
estimated 2021-2036 capacity for 425
single-family and 4 multi-family housing
units (Exhibit 61). The multi-family
capacity includes group housing. Given that
Nooksack does not have a designated multi-
family zoning district and that multi-family
development is allowed in the City's single-
family zones, it is anticipated that some of
the above single-family capacity will be
utilized to accommodate multi-family and
group housing needs.
These capacities are sufficient to accommodate
the dwelling unit types needed in the planning
PAGE 121
JULY 2022, REVISED FEB 2023
period as established in the Whatcom County
Comprehensive Plan (Chapter 3-Housing,
Chart 3).
Employment Capacity 2021-2036
Based on achieved densities between 2016 and
2021 and planning assumptions, City of
Nooksack planners are assuming a future
commercial FAR of 0.26 and an industrial FAR
of 0.10 (Exhibit 62).
The Nooksack UGA has estimated net land
capacity for employment growth of 38.5 acres
(Exhibit 63), with a total estimated potential
occupied commercial and industrial capacity of
238,772 square feet. Based on square feet per
employee assumptions, the Nooksack UGA has
an estimated employment capacity of 355,
indicating an estimated employment capacity
surplus of 263 (Exhibit 64).
Regulatory Changes
The City of Nooksack has not identified any
regulatory changes that would prevent
assigned densities from being achieved or
impact the quantity of land suitable for
development during the remainder of the
planning period.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
Infrastructure Gaps
The City of Nooksack has not identified any
infrastructure gaps that would prevent
assigned densities from being achieved or
impact the quantity of land suitable for
development during the remainder of the
planning period (2021 to 2036).
Analysis of Comprehensive Plan
Objectives and Reasonable Measures
The City of Nooksack has determined that
growth targets and assumptions are being met
to a reasonable degree; therefore, an analysis
of comprehensive plan development targets,
assumptions and objectives is not deemed
necessary.
Based on the results presented in the
Buildable Land Report, implementation of
reasonable measures is not deemed necessary.
If in the future it is determined that
Reasonable Measures are appropriate, then
the following measures could be considered for
implementation:
• Increase residential densities by reducing
minimum lot sizes in the Residential District
above the increases likely to result from
establishment of the Residential-8600
Subzone.
PAGE 122
JULY 2022, REVISED FEB 2023
• Reduce limitations on the placement of
multifamily structures in the Residential
District.
• Establish a multifamily residential zoning
district.
• Increase opportunities for construction of
accessory dwelling units (ADUs).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 123
JULY 2022, REVISED FEB 2023
Residential Development
Exhibit 59. Residential Development, Achieved and Assumed Densities, City of Nooksack, 2016-2021
Z • D I t Acres D 11 • Achieved Density onmg eve opmen we mg
D · t· T D I d un·its Density Assumed esIgna IOn ype eve ope
RES
RES-8600
AG UR
Single Family
Multifamily
Single Family
Single Family
5.6
1.3
4.4
Sources: City of Nooksack, 2022; Community Attributes Inc., 2021.
23
10
26
(Units/ Acre) (Units/ Acre)
4.11 3.93
7.97
5.88 5.88
4.80
Note: "Density Assumed" is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 124
JULY 2022, REVISED FEB 2023
Exhibit 60. Residential Land Supply, Nooksack UGA, 2021-2036
UGA Total RES RES-COM CMD LI AG UR 8600
Vacant Land
Gross Acres 83.36 43.41 9.66 0.00 0.00 0.00 30.29
Critical Areas 28.68 16.68 3.30 0.00 0.00 0.00 8.69
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 2.73 1.34 0.32 0.00 0.00 0.00 1.08
Infrastructure Deduction 2.73 1.34 0.32 0.00 0.00 0.00 1.08
Mark et Factor 7.38 3.61 0.86 0.00 0.00 0.00 2.92
Net Acres 41.83 20.44 4.87 0.00 0.00 0.00 16.52
Partially-Used Land
Gross Acres 87.19 86.08 1.10 0.00 0.00 0.00 0.00
Critical Areas 16.08 16.08 0.00 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 3.56 3.50 0.06 0.00 0.00 0.00 0.00
Infrastructure Deduction 3.56 3.50 0.06 0.00 0.00 0.00 0.00
Market Factor 16.00 15.75 0.25 0.00 0.00 0.00 0.00
Net Acres 48.00 47.25 0.74 0.00 0.00 0.00 0.00
Underutilized Land
Gross Acres 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Critical Areas 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Deduction 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Mark et Factor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Net Acres 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Sources: City of Nooksack, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY PAGE 125
BUILDABLE LANDS REPORT JULY 2022, REVISED FEB 2023
Exhibit 61. Developable Residential Land Capacity, Nooksack UGA, 2021-2036
UGA RES RES-COM CMD LI AGUR 8600
Net Developable Residential Acres
(Vacant, PU, UU) 89.83 67.70 5.61 0.00 0.00 0.00 16.52
Single Family Developable Acres 89.83 67.70 5.61 16.52
Assumed Single Family Density (units/acre) 4 6 5
Subtotal Single Family Unit Capacity 378 266 33 79
Existing Single Family Units 33 21 l 8 2
Pending Single Family Units 69 8 61
Master Planned Single Family Units
Subtotal: Net Single Family Unit Capacity 425 253 93 79
Potential Occupied Single Family Units 412 245 90 77
Single Family Population Capacity 1,271 757 278 236
Multifamily Developable Acres
Assumed Multifamily Density (units/acre)
Subtotal Multifamily Unit Capacity
Existing Multifamily Units
Pending Multifamily Units 4 4
Master Planned Multifamily Units
Subtotal: Net Multifamily Unit Capacity 4 4
Potential Occupied Multifamily Units 4 4
Multifamily Population Capacity 12 12
Net Dwelling Unit Capacity 429 253 97 79
Potential Occupied Dwelling Units 416 245 94 77
Population Capacity 1,283 757 290 236
Remaining Population Growth to
Accommodate (2021-2036) 684
Population Capacity Surplus (Deficit) 599
Sources: City of Nooksack, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 126
JULY 2022, REVISED FEB 2023
Commercial and Industrial Development
Exhibit 62. Nonresidential Development, Achieved and Assumed Densities, City of Nooksack, 2016-2021
Zoning Development Acres Built Square Achieved Assumed
Designation Tyee Develoeed Feet Density {FAR} Density {FAR}
COM Commercial 0.6 3,765 0.14 0.25
CMD Commercial 0.2 1,160 0.15 0.25
LI Industrial 0.10
Sources: City of Nooksack, 2022; Community Attributes Inc., 2021.
Note: Assumed Density is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 127
JULY 2022, REVISED FEB 2023
Exhibit 63. Developable Nonresidential Land Supply, Nooksack UGA, 2021-2036
UGA Total RES RES-8600 COM CMD LI AG UR
Vacant Land
Gross Acres 19.96 0.00 0.00 2.10 0.17 17.70 0.00
Critical Areas 0.74 0.00 0.00 0.74 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 0.96 0.00 0.00 0.07 0.01 0.89 0.00
Infrastructure Deduction 0.96 0.00 0.00 0.07 0.01 0.89 0.00
Market Factor 2.60 0.00 0.00 0.18 0.02 2.39 0.00
Net Acres 14.71 0.00 0.00 1.04 0.13 13.54 0.00
Partially-Used Land
Gross Acres 0.45 0.00 0.00 0.45 0.00 0.00 0.00
Critical Areas 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 0.02 0.00 0.00 0.02 0.00 0.00 0.00
Infrastructure Deduction 0.02 0.00 0.00 0.02 0.00 0.00 0.00
Market Factor 0.10 0.00 0.00 0.10 0.00 0.00 0.00
Net Acres 0.30 0.00 0.00 0.30 0.00 0.00 0.00
Underutilized Land
Gross Acres 38.53 0.00 0.00 21.10 0.59 16.83 0.00
Critical Areas 3.73 0.00 0.00 3.73 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 1.74 0.00 0.00 0.87 0.03 0.84 0.00
Infrastructure Deduction l.74 0.00 0.00 0.87 0.03 0.84 0.00
Market Factor 7.83 0.00 0.00 3.91 0.13 3.79 0.00
Net Acres 23.49 0.00 0.00 11.72 0.40 11.36 0.00
Sources: City of Nooksack, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY PAGE 128
BUILDABLE LANDS REPORT JULY 2022, REVISED FEB 2023
Exhibit 64. Developable Nonresidential Land Capacity, Nooksack UGA, 2021-2036
UGA RES RES-8600 COM CMD LI AG UR
Net Developable Employment Acres
(Vacant, PU, UU) 38.50 0.00 0.00 13.07 0.53 24.90 0.00
Commercial Developable Acres 13.59 13.07 0.53
Assumed Commercial Density (FAR) 0.3 0.3
Subtotal: Commercial Capacity (SF) 148,035 142,288 5,747
Existing Commercial Space (SF)
Pending Commercial Space (SF)
Master Planned Commercial Space (SF)
Subtotal: Net Commercial Capacity (SF) 148,035 142,288 5,747
Potential Occupied Commercial Space (SF) 140,633 135,174 5,460
Commercial Employment Capacity 232 223 9
Industrial Developable Acres 24.90 24.90
Assumed Industrial Density (FAR) 0.1
Subtotal: Industrial Capacity (SF) 108,486 108,486
Existing Industrial Space (SF) 8,622 3,440 5,182
Pending Industrial Space (SF)
Master Planned Industrial Space (SF)
Subtotal: Net Industrial Capacity (SF) 103,304 103,304
Potential Occupied Industrial Space (SF) 98,139 98,139
Industrial Employment Capacity 123 123
Net Commercial & Industrial Capacity (SF) 251,339 142,288 5,747 103,304
Potential Occupied Commercial & Industrial 238,772 135,174 5,460 98,139
Employment Capacity 355 223 9 123
Remaining Employment Growth to
Accommodate (2021-2036) 92
Employment Capacity Surplus (Deficit) 263
Sources: City of Nooksack, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY PAGE 129
BUILDABLE LANDS REPORT JULY 2022, REVISED FEB 2023
10. Sumas UGA
The Sumas Urban Growth Area is projected to
reach a total population and employment of
2,323 and 1,145 respectively by 2036. The
UGA has projected growth allocation of 760 for
population and 387 for employment between
2016 and 2036 (Exhibit 1 and Exhibit 2).
Achieved Growth 2016-2021
Based on permit data collected between 2016
and 2021 and occupancy and persons per
household and square feet per employee
assumptions, the Sumas UGA grew by an
estimated 190 population and 65 employment
(100% within the City) (Exhibit 6 and
Exhibit 7).
Between 2016 and 2021, the City of Sumas
achieved an overall residential density of 7.5
units per acre. No development occurred
within the unincorporated area of the UGA
within the period. The City of Sumas
Comprehensive Plan has an adopted planned
residential density of 4.9 units per acre. The
Whatcom County Comprehensive Plan has
adopted planned residential density of 4.0 to
6.0 units per acre. Achieved residential
density within the City of Sumas exceeded
both the City and County planned densities
(Exhibit 11).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
The City Comprehensive Plan references
planned densities for commercial and
industrial developed based on the Whatcom
County Land Capacity Analysis. Whatcom
County has not adopted planned densities for
commercial or industrial uses. No commercial
development occurred within the City during
the review period. The City achieved an
industrial FAR of 0.12, exceeding slightly the
planned density of 0.11. The adopted planned
commercial FAR is 0.22 (Exhibit 11).
Population and Employment Assumptions
Specific occupancy rate and population and
employment density assumptions for
estimating future growth capacity in the
Sumas UGA are:
• 95.8% Single Family occupancy rate
• 82.2% Multifamily occupancy rate
• 95.0% Commercial and Industrial
occupancy rate
• 3.008 Single Family persons per
household
• 2.199 Multifamily persons per
household
• 669 and 890 respectively Commercial
and Industrial square feet per employee
The Sumas UGA has an estimated 570
population and 322 employment growth
PAGE 130
JULY 2022, REVISED FEB 2023
remaining to accommodate between 2021 and
2036 (Exhibit 6 and Exhibit 7).
Population Capacity 2021-2036
Based on achieved densities between 2016 and
2021 and planning assumptions, City of
Sumas planners are assuming future single
family density between 2.5 and 4.5 units per
acre for single family residential development.
Assumed density for future multifamily
development is 13.5 units per acre (Exhibit
65).
The Sumas UGA has estimated net land
capacity for population growth of 65.8 acres
(Exhibit 66), with a total estimated potential
occupied unit capacity of 435 dwelling units.
Based on persons per household assumptions,
the UGA has an estimated population capacity
of 1,073, indicating an estimated population
capacity surplus of 503 (Exhibit 67).
Housing Needs by Type
The Whatcom County Comprehensive Plan
(Chapter 3-Housing, Chart 3 -Estimated
Dwelling Units Needed, page 3-8) indicates
that Sumas has a need for 168 single-family,
146 multi-family, and 47 other ("group
housing") new dwelling units during the 2013-
2036 planning period. The calculation for
Chart 3 in the Whatcom County
WHATCOM COUNTY
BUILDABLE LANDS REPORT
Comprehensive Plan included building activity
from 2013. Therefore, the analysis below
includes permit data from April 1, 2013, even
though the planning period for this Buildable
Lands Report is from 2016.
• Between April 1, 2013 and March 31, 2021,
Sumas issued building permits for 57
single-family and 45 multi-family units. No
group housing has been built during this
time. Comparing units built and the needs
indicated on Chart 3, Sumas needs an
additional 111 single-family units, 101
multi-family units, and 47 group housing
units between 2021 and 2036.
• The City and unincorporated UGA have an
estimated 2021-2036 capacity for 151
single-family and 353 multi-family housing
units (Exhibit 67). The multi-family
capacity includes group housing.
These capacities are sufficient to accommodate
the dwelling unit types needed in the planning
period as established in the Whatcom County
Comprehensive Plan (Chapter 3-Housing,
Chart 3).
Employment Capacity 2021-2036
The City of Sumas is utilizing achieved
densities (when available) when estimating
future land capacity. Based on achieved
PAGE 131
JULY 2022, REVISED FEB 2023
densities between 2016 and 2021 and planning
assumptions, City of Sumas planners are
assuming a future commercial FAR between
0.22 and 0.50 depending on the specific zone
and an industrial FAR of 0.12 (Exhibit 68).
The Sumas UGA has estimated net land
capacity for employment growth of 110.6 acres
(Exhibit 69), with a total estimated potential
occupied commercial and industrial capacity of
601,950 square feet. Based on square feet per
employee assumptions, the Sumas UGA has
an estimated employment capacity of 758,
indicating an estimated employment capacity
surplus of 436 (Exhibit 70).
Regulatory Changes
The City of Sumas has not identified any
regulatory changes that would prevent
assigned densities from being achieved or
impact the quantity ofland suitable for
development during the remainder of the
planning period.
Infrastructure Gaps
The City of Sumas has not identified any
infrastructure gaps that would prevent
assigned densities from being achieved or
impact the quantity of land suitable for
development during the remainder of the
planning period (2021 to 2036).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
Analysis of Comprehensive Plan
Objectives and Reasonable Measures
The City of Sumas has determined that
growth targets and assumptions are being met
to a reasonable degree; therefore, an analysis
of comprehensive plan development targets,
assumptions and objectives is not deemed
necessary.
Based on the results presented in the
Buildable Land Report, implementation of
reasonable measures is not deemed necessary.
If in the future it is determined that
Reasonable Measures are appropriate, then
the following measures could be considered for
implementation:
• Increase residential densities by reducing
minimum lot sizes in the Residential, Low-
Density zoning district.
• Reduce conditional use permitting
requirements for construction of multifamily
structures in the Residential, High-Density
zoning district.
• Increase opportunities for construction of
accessory dwelling units (ADUs).
PAGE 132
JULY 2022, REVISED FEB 2023
Residential Development
Exhibit 65. Residential Development, Achieved and Assumed Densities, City of Sumas, 2016-2021
Zoning Development Acres Dwelling Achieved Density
Designation Type Developed Units Density Assumed
{Units/ Acre) {Units/ Acre)
RES LOW Single Family 0.8 2 2.44 2.50
RES MED Single Family 5.5 27 4.91 4.50
RES HIGH Single Family 2.5 12 4.77
Multifamily 1.8 36 19.54 13.50
BUS GEN Multifamily 0.1 4 44.44
Sources: City of Sumas, 2022; Community Attributes Inc., 2021.
Note: "Density Assumed" is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 133
JULY 2022, REVISED FEB 2023
Exhibit 66. Residential Land Supply, Sumas UGA, 2021-2036
UGA Total RES LOW RES MED RES HIGH BUS GEN LI BUSTO BUS LOW
Vacant Land
Gross Acres 69.68 4.36 24.36 40.95 0.00 0.00 0.00 0.00
Critical Areas 27.26 2.80 3.96 20.50 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 2.12 0.08 1.02 1.02 0.00 0.00 0.00 0.00
Infrastructure Deduction 2.12 0.08 1.02 1.02 0.00 0.00 0.00 0.00
Market Factor 5.73 0.21 2.75 2.76 0.00 0.00 0.00 0.00
Net Acres 32.45 1.19 15.61 15.65 0.00 0.00 0.00 0.00
Partially-Used Land
Gross Acres 84.72 38.38 25.39 20.94 0.00 0.00 0.00 0.00
Critical Areas 35.27 16.40 13.52 5.35 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 2.47 1.10 0.59 0.78 0.00 0.00 0.00 0.00
Infrastructure Deduction 2.47 1.10 0.59 0.78 0.00 0.00 0.00 0.00
Market Factor 11.13 4.95 2.67 3.51 0.00 0.00 0.00 0.00
Net Acres 33.38 14.84 8.01 10.52 0.00 0.00 0.00 0.00
Underutilized Land
Gross Acres 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Critical Areas 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Deduction 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Market Factor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Net Acres 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Sources: City of Sumas, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 134
JULY 2022, REVISED FEB 2023
Exhibit 67. Developable Residential Land Capacity, Sumas UGA, 2021-2036
UGA RES LOW RES MED RES HIGH
Net Developable Residential Acres
(Vacant, PU, UU) 65.83 16.03 23.63 26.17
Single Family Developable Acres 39.66 16.03 23.63
Assumed Single Family Density (units/acre) 3 5
Subtotal Single Family Unit Capacity 146 40 106
Existing Single Family Units 38 6 7 9
Pending Single Family Units 18 18
Master Planned Single Family Units
Subtotal: Net Single Family Unit Capacity 151 34 117
Potential Occupied Single Family Units 145 33 112
Single Family Population Capacity 435 98 337
Multifamily Developable Acres 26.17 26.17
Assumed Multifamily Density (units/acre) 14
Subtotal Multifamily Unit Capacity 353 353
Existing Multifamily Units 4
Pending Multifamily Units
Master Planned Multifamily Units
Subtotal: Net Multifamily Unit Capacity 353 353
Potential Occupied Multifamily Units 290 290
Multifamily Population Capacity 638 638
Net Dwelling Unit Capacity 504 34 117 353
Potential Occupied Dwelling Units 435 33 112 290
Population Capacity 1,073 98 337 638
Remaining Population Growth to
Accommodate (2021-2036) 570
Population Capacity Surplus (Deficit) 503
Sources: City of Sumas, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
BUS GEN LI BUS TO BUS LOW
0.00 0.00 0.00 0.00
13 2
4
PAGE 135
JULY 2022, REVISED FEB 2023
Commercial and Industrial Development
Exhibit 68. Nonresidential Development, Achieved and Assumed Densities, City of Sumas, 2016-2021
Zoning Development Acres Built Square Achieved Assumed
Designation Tyee Develoeed Feet Density (FAR} Density (FAR}
RES LOW Commercial N/A N/A N/A 0.50
RES MED Commercial N/A N/A N/A 0.44
RES HIGH Commercial N/A N/A N/A 0.25
BUS GEN Commercial N/A N/A N/A 0.22
BUSTO Commercial N/A N/A N/A 0.22
BUS LOW Commercial N/A N/A N/A 0.22
LI Industrial 11.2 60,549 0.12 0.12
Sources: City of Sumas, 2022; Community Attributes Inc., 2021.
Note: Assumed Density is the assumed density for evaluation of land suitable for development by zone.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 136
JULY 2022, REVISED FEB 2023
Exhibit 69. Developable Nonresidential Land Supply, Sumas UGA, 2021-2036
UGA Total RES LOW RES MED RES HIGH BUS GEN LI BUS TO BUS LOW
Vacant Land
Gross Acres 206.54 0.00 0.00 0.00 5.15 168.29 32.89 0.21
Critical Areas 97.92 0.00 0.00 0.00 2.19 88.44 7.08 0.21
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 5.43 0.00 0.00 0.00 0.15 3.99 1.29 0.00
Infrastructure Deduction 5.43 0.00 0.00 0.00 0.15 3.99 1.29 0.00
Market Factor 14.66 0.00 0.00 0.00 0.40 10.78 3.48 0.00
Net Acres 83.09 0.00 0.00 0.00 2.26 61.08 19.75 0.00
Partially-Used Land
Gross Acres 13.87 0.00 0.00 0.00 0.00 13.87 0.00 0.00
Critical Areas 6.35 0.00 0.00 0.00 0.00 6.35 0.00 0.00
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 0.38 0.00 0.00 0.00 0.00 0.38 0.00 0.00
Infrastructure Deduction 0.38 0.00 0.00 0.00 0.00 0.38 0.00 0.00
Market Factor 1.69 0.00 0.00 0.00 0.00 1.69 0.00 0.00
Net Acres 5.08 0.00 0.00 0.00 0.00 5.08 0.00 0.00
Underutilized Land
Gross Acres 50.02 0.00 0.00 0.00 4.11 45.62 0.00 0.29
Critical Areas 16.81 0.00 0.00 0.00 0.98 15.54 0.00 0.29
Future Public Uses 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Infrastructure Gaps 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Quasi-Public Use Deduction 1.66 0.00 0.00 0.00 0.16 1.50 0.00 0.00
Infrastructure Deduction 1.66 0.00 0.00 0.00 0.16 1.50 0.00 0.00
Market Factor 7.47 0.00 0.00 0.00 0.70 6.77 0.00 0.00
Net Acres 22.42 0.00 0.00 0.00 2.11 20.31 0.00 0.00
Sources: City of Sumas, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
PAGE 137
JULY 2022, REVISED FEB 2023
Exhibit 70. Developable Nonresidential Land Capacity, Sumas UGA, 2021-2036
UGA RES LOW RES MED RES HIGH
Net Developable Employment Acres
(Vacant, PU, UU) 110.59 0.00 0.00 0.00
Commercial Developable Acres 24.12
Assumed Commercial Density (FAR) 0.5 0.4 0.3
Subtotal: Commercial Capacity (SF) 231,113
Existing Commercial Space (SF)
Pending Commercial Space (SF)
Master Planned Commercial Space (SF)
Subtotal: Net Commercial Capacity (SF) 231,113
Potential Occupied Commercial Space (SF) 219,557
Commercial Employment Capacity 328
Industrial Developable Acres 86.47
Assumed Industrial Density (FAR)
Subtotal: Industrial Capacity (SF) 451,991
Existing Industrial Space (SF) 49,472
Pending Industrial Space (SF)
Master Planned Industrial Space (SF)
Subtotal: Net Industrial Capacity (SF) 402,519
Potential Occupied Industrial Space (SF) 382,393
Industrial Employment Capacity 430
Net Commercial & Industrial Capacity (SF) 633,632
Potential Occupied Commercial & Industrial 601,950
Employment Capacity 758
Remaining Employment Growth to
Accommodate (2021-2036) 322
Employment Capacity Surplus (Deficit) 436
Sources: City of Sumas, 2022; Whatcom County, 2021; Community Attributes Inc., 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
BUS GEN LI BUSTO BUS LOW
4.37 86.47 19.75 0.00
4.37 19.75 0.00
0.2 0.2 0.2
41,882 189,231
41,882 189,231
39,788 179,769
59 269
86.47
0.1
451,991
49,472
402,519
382,393
430
41,882 402,519 189,231
39,788 382,393 179,769
59 430 269
PAGE 138
JULY 2022, REVISED FEB 2023
APPENDIX A: ANNEXATIONS
Between 2016 and 2021, 445 total acres were annexed to cities in Whatcom
County. These annexations increased the total incorporated area in Whatcom
County to 35,385 acres (Exhibit 71). These annexations were adopted by the
following city legislative actions:
• City of Bellingham Ordinances 2018-11-027 and 2018-12-033
• City of Lynden Ordinances 1506, 1509, and 1561
• City of Nooksack Ordinance 712
Exhibit 71. Whatcom County Acres Annexed by City, 2016-2021
~~;~s 2016 2017 2018 2019 2020 2021 Total Acres Acres
Annexed 2021
Bellingham 19,275 0 0 0 249 0 0 249 19,524
Blaine 5,464 0 0 0 0 0 0 0 5,464
Everson 877 0 0 0 0 0 0 0 877
Ferndale 4,561 0 0 0 0 0 0 0 4,561
Lynden 3,382 82 0 10 0 0 0 92 3,474
Nooksack 446 0 0 0 104 0 0 104 550
Sumas 935 0 0 0 0 0 0 0 935
Total 34,940 82 0 10 353 0 0 445 35,385
Sources: Whatcom County and Cities, 2022 (Countywide Data Reporting Tool).
Notes: Acres 2016 represents acres within city limits as of March 31, 2016. Acres 2021
represents acres within city limits as of March 31, 2021. Numbers have been rounded. For
Bellingham, land area excluding Bellingham Bay, Lake Whatcom, and Lake Padden is equal
to 18,046 acres.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
JULY 2022, REVISED FEB 2023
PAGE 139
APPENDIX B: URBAN GROWTH AREA CHANGES
Between 2016 and 2021, 345 acres were added to Whatcom County's urban
growth areas. UGAs include areas within the city limits and unincorporated
areas that have been designated for urban growth. UGA changes authorized
by Whatcom County Ordinance 2016-034 include a reduction of 20 acres in
the Everson UGA, as well as increases in the Ferndale, Lynden, and
Nooksack UGAs. Overall, as of March 31, 2021, Whatcom County's UGAs
total 52,029 acres (Exhibit 72).
Exhibit 72. Whatcom County Acres Added to Urban Growth Areas, 2016-
2021
Acres 2016 2017 2018 2019 2020 2021 Total Acres Acres
2016 Added to UGAs 2021
Bellingham 23,172 0 0 0 0 0 0 0 23,172
Birch Bay 3,607 0 0 () 0 () () 0 3,607
Blaine 4,071 () () () 0 0 0 0 4,071
Cherry Point 7,035 0 () C) () 0 () 0 7,035
Columbia Valley 1,157 () 0 0 0 0 0 0 l, 157
Everson 1,287 (20) 0 0 () 0 0 (20) 1,267
Ferndale 5,869 117 0 0 0 0 0 117 5,986
Lynden 3,979 193 0 () () 0 () 193 4,172
Nooksack 548 55 0 () 0 () 0 55 603
Sumas 959 0 0 0 0 C) C) 0 959
Total 51,684 345 0 0 0 0 0 345 52,029
Sources: Whatcom County and Cities, 2022 (Countywide Data Reporting Tool).
Notes: Acres 2016 represents acres within each UGA as of March 31, 2016. Acres 2021
represents acres within each UGA as of March 31, 2021.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
JULY 2022, REVISED FEB 2023
PAGE 140
APPENDIX C: ZONING MAP CHANGES
Zoning map changes documented in Exhibit 73 and Exhibit 74 provide a
detailed accounting of changes to zoning within each UGA for residential,
commercial, industrial, and other types of zones between 2016 and 2021.
Many of the general land use categories encompass a number of zoning
districts. In 2016, land was added to some UGAs or moved between UGAs.
This land has not been rezoned and therefore these changes are reflected in
Exhibit 72, but not in the zoning map changes.
Ordinances authorizing zoning changes from one land use category to
another between April 1, 2016 and March 31, 2021:
• Bellingham UGA
o City of Bellingham Ordinance 2017-07-018 rezoned 0.51 acres
from Residential -Single Family to Commercial.
o City of Bellingham Ordinance 2017-07-019 rezoned 10 acres
from Residential -Single Family to Industrial.
o City of Bellingham Ordinance 2017-07-020 rezoned 3.6 acres
from Industrial to public and 17. 7 acres of Commercial/
Industrial/ Residential Multifamily to Public.
o City of Bellingham Ordinance 2017-11-025 rezoned 12.7 acres
from Commercial to Institutional.
• Everson UGA
o City of Everson zoning changes in 2016 were part of the 2016
Comprehensive Plan update, adopted through Ordinance 767-
16.
o City of Everson zoning changes in 2019 were adopted through
Ordinance 806-19.
• Ferndale UGA
o Ferndale Ordinance 1957 (2016) -Rezoned 0.75 acres from
Residential -Single Family to Residential -Multifamily.
o Ferndale Ordinance 1977 (2016) -Rezoned 6.78 acres from
Residential -Single Family to Commercial.
o Ferndale Ordinance 2080 (2019) -Rezoned 112 acres from
Floodplain to Public (3.9 acres), Residential -Single Family
(8.51 acres), Residential -Multifamily (48.62 acres), and
Commercial (52.14 acres). Rezoned 18.92 acres from
Commercial to Residential -Multifamily and 4.45 acres from
Commercial to Residential -Single Family.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
JULY 2022, REVISED FEB 2023
PAGE 141
o Ferndale Ordinance 2160 (2020) -Rezoned 2.71 acres from
Residential -Single Family to Residential -Multifamily, and
3.8 acres from Residential -Multifamily to Commercial.
• Lynden UGA
o Lynden Ordinances 1506 and 1509 (2016) -Annexed 82 acres
and rezoned to Residential.
o Lynden Ordinance1519 (2016) -Rezoned 7 acres from
Commercial to Industrial, 1 acre from Residential to
Commercial, and 5 acres from Residential to Public Use.
o Lynden Ordinance 1548 (2017) -Rezoned 27 acres from
Commercial to Residential.
o Lynden Ordinance 1569 (2018) -Rezoned 16 acres from
Residential to Commercial (6 acres), Industrial (8 acres), and
Public Use (2 acres). This Ordinance also rezoned 9 acres from
Commercial to Industrial.
o Lynden Ordinance 1561 (2018) -Annexed 10 acres and rezoned
to Residential.
o Lynden Ordinance 1597 (2019) -Rezoned 1 acre from Single
Family Residential to Multifamily Residential.
o Lynden Ordinance 1619 (2020)-Rezoned 83 acres from Single
Family Residential to Multifamily Residential (80 acres) and
Public Use (3 acres) in the Pepin Creek Subarea.
• Nooksack UGA
o City of Nooksack Ordinance 712 rezoned 31 acres of a 104 acre
annexation area from Residential to Public zoning.
• Sumas UGA
o City of Sumas Ordinance No. 1685 adopted zoning changes
from the 2016 Comprehensive Plan update.
• Areas Outside UGAs
o Whatcom County Ordinance 2016-036 rezoned 2 acres of Rural
one dwelling per five acres to Rural-Industrial.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
JULY 2022, REVISED FEB 2023
PAGE 142
Exhibit 73. Whatcom County Zoning Changes by Urban Growth Area and
Land Use, Acres, 2016-2021
City County Zoning Total Zoning
UGA Zoning Zoning 2016 2016 2017 2018 2019 2020 2021 Changes 2016 2016
Bellingham
Residential -Single Family 7,868 2,205 10,073 0 (11) 0 0 0 0 (11)
Residential -Multifamily 3,209 46 3,255 (J 0 (J () Cl Cl 0
Commercial 1,847 314 2,161 0 (12) Cl Cl (] 0 (12)
Industrial 2,434 2,486 4,919 () 6 () () 0 () 6
Other 2,444 139 2,583 0 16 () () 0 () 16
Subtotal 17,802 5,190 22,992 0 0 0 () 0 0 0
Birch Bay
Residential -Single Family 0 1,728 1,728 () () 0 () Cl () 0
Residential -Multifamily 0 1,281 1,281 () Cl () Cl () () 0
Commercial 0 551 551 () 0 () () () () 0
Industrial 0 0 0 0 0 0 () () () 0
Other 0 0 0 0 (' ,J () () () () 0
Subtotal 0 3,560 3,560 0 ;\
V 0 (' J (' ,J 0
Blaine
Residential -Single Family 2,505 494 2,999 () ,,
l; 0 () () () ()
Residential Multifamily 262 0 262 () 0 n 0 () 0 0 i.)
Commercial 347 0 347 0 () () () () 0 0
Industrial 287 0 287 () () 0 CJ 0 0 0
Other 144 0 144 () 0 () () 0 0 0
Subtotal 3,545 494 4,039 0 0 0 (1 u CJ 0 0
Cherry Point
Industrial 0 7,029 7,029 () 0 () () 0 () 0
Subtotal 0 7,029 7,029 r, f' () 0 n r, 0 \J ,J u '.J
Columbia Valley
Residential -Single Family 0 1,065 1,065 0 () 0 Cl 0 Cl 0
Residential -Multifamily 0 0 0 0 Cl 0 0 0 0 0
Commercial 0 40 40 0 0 0 () (] 0 0
Industrial 0 0 0 (] 0 0 0 ,,,
l; () 0
Other 0 40 40 () () (] 0 0 (] 0
Subtotal 0 I, 145 I, 145 0 0 0 0 0 {' ,; 0
Everson
Residential -Single Family 421 108 529 (60) 0 0 (1) () Cl (61)
Residential -Multifamily 124 0 124 Cl () 0 4 l) 0 4
Commercial 47 7 54 10 0 () (1) () 0 9
Industrial 173 42 215 (26) () () 0 () () (26)
Other 116 251 367 76 () 0 (2) () () 74
Subtotal 881 408 1,289 0 0 CJ 0 n 0 0 V
Sources: Whatcom County and Cities, 2022 (Countywide Data Reporting Tool).
Notes: Acres 2016 represents acres as of March 31, 2016. Acres 2021 represents acres as of
March 31, 2021. Numbers may not add up because of rounding.
WHATCOM COUNTY
BUILDABLE LANDS REPORT
JULY 2022, REVISED FEB 2023
PAGE 143
Zoning
2021
10,062
3,255
2,149
4,926
2,600
22,992
1,728
1,281
551
0
0
3,560
2,999
262
347
287
144
4,039
7,029
7,029
1,065
0
40
0
40
I, 145
468
128
63
189
441
1,289
Exhibit 74. Whatcom County Zoning Changes by Urban Growth Area and
Land Use, Acres, 2016-2021
City County Zoning Total Zoning UGA Zoning Zoning 2016 2017 2018 2019 2020 2021
2016 2016 2016 Changes
Ferndale
Residential -Single Family 1,580 1,599 3,179 (8) 0 0 13 (3) 0 3
Residential -Multifamily 485 0 485 l 0 0 63 (l) () 63
Commercial 1,628 31 1,659 7 () () 33 4 () 44
Industrial 516 415 931 0 0 0 0 () () 0
Other 112 89 201 0 () () (109) () (J (109)
Subtotal 4,321 2,134 6,455 0 0 0 0 0 0 0
Lynden
Residential -Single Family 1,854 135 1,989 76 7 (6) (l) (83) 0 (7)
Residential -Multifamily 442 23 465 0 20 CJ 80 0 101
Commercial 479 0 479 (6) (27) (3) () 0 C) (36)
Industrial 337 0 337 7 0 17 0 0 Cl 24
Other 189 446 635 (77) 0 (8) 0 3 () (82)
Subtotal 3,300 604 3,904 0 0 0 0 () 0 0
Nooksack
Residential -Single Family 350 95 445 () () () (31) 0 0 (31)
Residential -Multifamily 0 0 0 Cl 0 0 0 () () 0
Commercial 35 0 35 () 0 Cl (l () 0 0
Industrial 13 0 13 0 0 () CJ 0 'i ,, 0
Other 45 ll 56 0 () (, 31 0 0 31
Subtotal 443 106 549 0 () 0 () () () 0
Sumas
Residential -Single Family 160 0 160 (4) () () () () () (4)
Residential -Multifamily 193 0 193 (16) (\ ,; CJ () () CJ (16)
Commercial 71 0 71 (l) 0 () Cl 0 Cl (l)
Industrial 376 0 376 8 0 Cl 0 () 0 8
Other 135 26 161 13 () CJ () () Cl 13
Subtotal 935 26 961 () 0 0 0 0 0 0
Areas Outside UGAs
Rural one dwelling/two acres N/A l, 157 l, 157 () () () 0 0 0 0
Rural one dwelling/five acres N/A 90,331 90,331 (2) () 0 0 0 0 (2)
Rural one dwelling/ten acres N/A 30,21 l 30,211 () () Cl 0 () 0 0
Rural Residential (LAMI RD) N/A 10,634 10,634 0 0 Cl () 0 0 0
Rural-Commercial (LAM I RD) N/A 1,286 1,286 0 () Cl () 0 0 0
Rural -Industrial (LAM I RD) N/A 494 494 2 () () 0 () 0 2
Agriculture N/A 86,276 86,276 0 Cl () () () () 0
Rural Forestry N/A 36,208 36,208 () () () CJ CJ () 0
Commercial Forestry N/A 187,31 l 187,31 l () () () 0 () () 0
Mineral Resource Lands N/A 0 0 () () 0 () CJ () 0
Subtotal NIA 443,908 443,908 0 0 0 0 0 0 0
Total 31,227 464,604 495,831 0 0 0 0 0 0 0
Sources: Whatcom County and Cities, 2022 (Countywide Data Reporting Tool).
Notes: Acres 2016 represents acres as of March 31, 2016. Acres 2021 represents acres as of
March 31, 2021. LAM/RD stands for "limited area of more intensive rural development" (see
RCW 36. 70A.070(5)(d)).
WHATCOM COUNTY
BUILDABLE LANDS REPORT
JULY 2022, REVISED FEB 2023
PAGE 144
Zoning
2021
3,182
548
1,703
931
92
6,455
1,982
566
443
361
553
3,904
414
0
35
13
87
549
156
177
70
384
174
961
l, 157
90,329
30,211
10,634
1,286
496
86,276
36,208
187,31 l
0
443,908
495,831