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HomeMy WebLinkAboutPacket Special Council May 8 2024Whatcom County COUNTY COURTHOUSE 311 Grand Avenue, Ste #105 Bellingham, WA 98225-4038 (360) 778-5010 Meeting Agenda COUNCILMEMBERS HAVE BEEN INVITED TO ATTEND AN INFORMAL 2025 COMPREHENSIVE PLAN REVIEW AND UGA UPDATE MEETING - A QUORUM OF THE COUNCIL MAY ATTEND THIS EVENT COUNCILMEMBERS Barry Buchanan Tyler Byrd Todd Donovan Ben Elenbaas Kaylee Galloway Jon Scanlon Mark Stremler CLERK OF THE COUNCIL Dana Brown-Davis, C.M.C. Council (Special) Wednesday, May 8, 2024 2 PM Hybrid Meeting - Bellingham City Hall May 8, 2024Council (Special)Meeting Agenda Call To Order Roll Call Discussion 1.AB2024-312 2025 Comprehensive Plan Update and UGA Review Other Business Adjournment Page 2 Printed on 8/12/2025Whatcom County Agenda Bill Master Report Whatcom County COUNTY COURTHOUSE 311 Grand Avenue, Ste #105 Bellingham, WA 98225-4038 (360) 778-5010 File Number: AB2024-312 1AB2024-312 Status:DiscussedFile ID:Version: DBrown@co.whatcom.wa.us05/02/2024File Created:Entered by: DiscussionCouncil OfficeDepartment:File Type: Assigned to:Council (Special)Final Action:02/20/2025 Agenda Date:02/20/2025 Enactment #: Primary Contact Email: DBrown@co.whatcom.wa.us TITLE FOR AGENDA ITEM: 2025 Comprehensive Plan Update and UGA Review SUMMARY STATEMENT OR LEGAL NOTICE LANGUAGE: See attached agenda and letter. HISTORY OF LEGISLATIVE FILE Action: Sent To: Date: Acting Body: DISCUSSED05/08/2024 Council (Special) DISCUSSED08/02/2024 Council (Special) DISCUSSED08/29/2024 Council (Special) DISCUSSED09/11/2024 Council (Special) DISCUSSED12/04/2024 Council (Special) DISCUSSED01/23/2025 Council (Special) DISCUSSED02/20/2025 Council (Special) DISCUSSED05/21/2025 Council (Special) Attachments:Executive Letter to Elected Officials 10.11.2023, Elected Officials Meeting Agenda 5.8.2024, SEPA Presentation 5.8.2024, HB 1220-HAPT Presentation 5.8.2024, Population and Employment Presentation 5.8.2024, Elected Officials Meeting Agenda 8.2.2024, Elected Officials Meeting Agenda 8 29 2024, Elected Officals Meeting - Presentation 8 29 2024, Elected Officials Meeting Agenda 9 11 2024, Elected Officials Meeting Agenda 12.4.2024, Presentation 12.4.2024 (Non-Binding Resolution), Presentation 12.4.2024 (Housing), Presentation 12.4.2024 (EIS), Page 1Whatcom County Printed on 8/12/2025 Agenda Bill Master Report Continued (AB2024-312) Elected Officials Meeting Agenda 1.23.2025, Elected Officials Meeting Agenda 2.20.2025, Elected Officials Meeting Agenda 5.21.2025 Page 2Whatcom County Printed on 8/12/2025 Satpal Singh Sidhu Whatcom County Executive 311 Grand Avenue Bellingham WA, 98225 (360) 778-5200 ssidhu@whatcomcounty.us To: Honorable City Mayors, City Managers, and City Council Members Honorable County Council Members From: Satpal Singh Sidhu, County Executive Date: October 11, 2023 Subject: 2025 Comprehensive Plan Update and UGA Review The Growth Management Act (GMA) requires Whatcom County and the seven cities within the County to update our comprehensive plans and review urban growth areas by June 30, 2025. The GMA expects the County and cities to work cooperatively in this endeavor, and it is to our advantage to do so. That is why each interlocal agreement for planning, annexation and development signed in 2022 includes a clause that the County Executive may convene a group of elected officials from the County and cities to discuss and review issues associated with growth management planning. It is critical to coordinate planning efforts between the County and cities for this important endeavor. Therefore, I am inviting elected officials from the County and the cities to a series of informal meetings to discuss matters relating to growth planning and the urban growth area review. The 1st meeting date and location is: • Wednesday November 8, 2023 - Lynden City Hall, 300 4th Street, Lynden at 2:00 – 4:00 p.m. (this will be a hybrid meeting, so a virtual option will be provided). I am requesting that each city and the County Council provide representation at these meetings. The purpose of the meetings will be to engage in discussions, come to mutual understanding of the goals and issues of each jurisdiction, and coordinate land use planning activities. However, there will not be voting or final decisions made at these meetings. Rather, elected officials will take the information back to their respective jurisdictions for consideration in their own decision making processes. While there is no set number of representatives from each jurisdiction, it must be less than a quorum of the legislative body. Thank you for considering my invitation and I hope to see representatives from each city and the County Council at these meetings. Staff will send out a meeting agenda prior to the meeting. Sincerely, Satpal Singh Sidhu County Executive City/County Elected Officials Meeting Growth Management Coordination – 2025 Update Agenda May 8, 2024 2:00 – 4:00 p.m. Bellingham City Hall, 210 Lottie Street Mayor's Boardroom in Mayor's office on 2nd floor (virtual option also provided) 2:00 – 4:00 p.m. 1. Welcome and Introductions 2. Population and Employment Growth Projections 3. Housing: House Bill 1220 and Housing for All Planning Tool 4. Environmental Impact Statement (EIS) - Status update 5. Discussion – Elected Officials and Staff 6. Next Meeting, Wednesday September 11 7. Wrap-up and Adjourn Microsoft Teams meeting Join on your computer, mobile app or room device Click here to join the meeting Meeting ID: 211 728 377 510 Passcode: H9vf8X Download Teams | Join on the web Or call in (audio only) +1 929-352-1870,,849265777# United States, New York City Phone Conference ID: 849 265 777# Find a local number | Reset PIN Learn More | Meeting options City of Bellingham City of Blaine City of Everson City of Ferndale City of Lynden City of Nooksack City of Sumas Whatcom County EIS Update | May 8, 2024 2025 Comprehensive Plan and Development Regulations Update & Urban Growth Areas Review Whatcom County Photo Credit: Rich Stratman SEPA Process SEPA Process Final EIS •Definition of Preferred Alternative •Impact Evaluation •Proposed Mitigation •Response to Comments •County Adoption DEIS Publication •30-day Public Comment Period •Public Hearing Draft EIS Preparation •Definition of Alternatives •Existing Conditions •Impact Evaluation •Mitigation Strategies Notice of Intent and Scoping •30-day Public Comment Period •Scoping Summary 3 Growth/Land Use Alternatives •The No-action Alternative would assume that the existing Whatcom County Comprehensive Plan and growth projections are carried forward, which represents a lower growth option (275,450 total County population in 2045). •Alternative 1 would use the Washington State Office of Financial Management (OFM) medium population projection (292,714 total County population in 2045) and allocate growth to each UGA and the area outside the UGAs using recent historic population shares. •Alternative 2 would use a population projection and allocations to each UGA and the area outside the UGAs requested by the cities and County. •Alternative 3 would use a higher population projection than both the OFM medium projection and the population projection requested by the cities and County for 2045 and allocate growth to each UGA and the area outside the UGAs similar to the growth allocations requested by the cities and County. •Alternatives may include, where appropriate, changes to land use/zoning designations, residential densities, and/or urban growth area boundaries to accommodate projected housing and employment growth through the year 2045. 4 Existing Conditions •SEPA required element for baseline evaluation •Areas of the environment included in the EIS: •Earth •Air Quality/Climate •Water Resources •Plants and Animals •Land and Shoreline Use •Plans and Policies •Population, Housing, and Employment •Environmental Justice •Cultural Resources •Transportation •Public Services and Utilities •Input from County departments on existing issues 5 Next Steps in the EIS Process Publication of the Draft EIS for public comment is anticipated in early fall of 2024. Public hearing on the Draft EIS Publication of the Final EIS is anticipated in the first quarter of 2025. Complete impact analysis/comparison of the alternatives and mitigation strategy development. 6 Project Duration Topic-Specific Citizen Advisory Committees December 2023 Project Kickoff Orientation Interviews June-July 2024 Interactive Community Survey Regional Pop-Ups and Workshops Planning Commission Meetings County Council Meetings Aug-Oct 2024 Draft EIS Release Planning Commission Meetings County Council Meetings Non-binding multi-jurisdictional resolution regarding allocation of growth to UGAs Fall 2024 Open House: Plan Recommendations Planning Commission Meetings County Council Meetings 2025 Final EIS Planning Commission Work Sessions, Hearings, and Recommendations County Council Meetings, Hearings and Adoption Timeline 7 Questions on the Process? Project Contacts Matt Aamot Senior Planner Whatcom County 2025Update@co.whatcom.wa.us 360.778.5939 Sharese Graham (Consultant) Senior Environmental Planner SCJ Alliance Consulting Services bill.grimes@scjalliance.com 509.835.3770 https://www.whatcomcounty.us/4218/2025-Comprehensive-Plan-Updates Project Website 9 City/County Elected Officials Meeting | May 8, 2024 House Bill 1220 and Housing Planning for All Tool Whatcom County Photo Credit: Rich Stratman LELAND CONSULTING GROUP HB 1220 amended the GMA in 2021 to require that jurisdictions “plan for and accommodate housing affordable to all economic segments of the population of the state” Additionally, RCW 36.70A.070(2) now requires that Commerce project housing needs including “units for moderate, low, very low, and extremely low-income households and emergency housing, emergency shelters and permanent supportive housing.” HAPT generates total Countywide need based on population projections. County then allocates units to jurisdictions by income band (as a % of Area Median Income) Jurisdictions must show land capacity to accommodate the units through zoning, and document potential barriers to production and racially disparate impacts in housing policy. Housing Allocation & HB1220 Overview Further details in HB 1220 Book 1: Establishing Housing Targets for your Community and HB 1220 Book 2: Guidance for Updating Your Housing Element https://deptofcommerc e.box.com/s/chqj8wk1 esnnranyb3ewzgd4w0 e5ve3a https://deptofcommerc e.app.box.com/s/1d9d 5l7g509r389f0mjpowh 8isjpirlh 2 HAPT Tool Introduction •Excel tool developed by Commerce •Housing units categorized by the income bands that they could potentially serve •Income expressed as a % of Area Median Income (AMI), HUD’s measurement of family income adjusted for household size (1.34) –standard income measurement for subsidized housing eligibility. •Whatcom County AMI: $102,600•Tool projects net new units needed by 2045 based on OFM population projections: 3 Baseline and New Units Categorized by Income •2020 baseline units categorized by income band that they serve. •Data from Comprehensive Housing Affordability Strategy and Public Unit Microdata Sample (HUD/Census datasets)•New units needed broken down by income band accounting for several categories of need: •Emergency Housing and Permanent Supportive Housing needs determined using Monte Carlo model •Many factors, including disability rate, evictions, incarceration rate, number of one-person households, severe rent-burden, receipt of cash benefits, unemployment, current estimate of homelessness based on the point-in-time count and a number of other data sources. •Full methodology on pp. 43-58 of Book 1. 4 Total Whatcom County Need Step 1 Select a County Whatcom ✔Low Medium High Projected Population (2045)258,231 292,714 337,551 Step 2 Select a Projection Year Table 2: Projected Countywide Housing Needs Based on User Inputs 2045 ✔Whatcom County Population Target = 292,714 Total Non-PSH PSH 30-50%50-80%80-100%100-120%120%+ Step 3 Total Future Housing Needed (2045)130,841 11,062 3,836 15,955 28,123 16,778 14,015 41,072 1,295 Enter Population Target in Range Estimated Housing Supply (2020)*95,217 2,996 404 9,108 24,150 14,457 11,771 32,331 775 292,714 ✔Net New Housing Needed (2020-2045)35,624 8,066 3,432 6,847 3,973 2,321 2,244 8,741 520 * Note: Supply of PSH in 2020 is beds. However, projections of Net New Housing Needed (2020-2045) are in housing units. See Overview tab for details. Emergency Housing/Shelter Beds Table 1: OFM GMA Population Projections, 2045 Whatcom County Projected Population, 2045 0-30% Affordability Level (% of Area Median Income) •Initial Whatcom County housing baseline and net new units needed based on OFM Medium Projection: •Baseline units updated by Leland Consulting Group (LCG) from Commerce-generated 2020 baseline to 2023 using permit data from cities and the County 5 2023 Baseline Units 2023 Revised Baseline by UGA Emergency % of Total Total Non-PSH PSH >30-50%>50-80%>80-100%>100-120%>120%Housing Needs Bellingham Total 49.8%47,564 1,207 586 4,119 16,782 6,400 5,029 13,442 693 Bellingham City 45.6%43,575 1,137 586 3,767 15,503 6,016 4,539 12,027 693 Bellingham Unincorporated UGA 4.2%3,989 70 0 352 1,279 384 490 1,415 0 Birch Bay Unincorporated UGA 5.6%5,322 197 0 975 1,292 1,155 425 1,278 0 Blaine Total 3.9%3,746 169 0 246 728 918 401 1,284 0 Blaine City 3.7%3,548 158 0 230 681 900 374 1,205 0 Blaine Unincorporated UGA 0.2%198 11 0 16 47 18 27 79 0 Cherry Point Unincorporated UGA 0.0%6 0 0 1 1 1 0 1 0 Columbia Valley Unincorporated UGA 1.6%1,541 153 0 432 727 38 28 163 0 Everson Total 1.1%1,085 30 0 120 371 207 81 277 0 Everson City 1.1%1,053 29 0 116 359 201 78 270 0 Everson Unincorporated UGA 0.0%32 1 0 4 12 6 3 7 0 Ferndale Total 6.3%5,980 203 0 568 1,385 915 694 2,216 0 Ferndale City 6.1%5,818 197 0 552 1,346 889 674 2,160 0 Ferndale Unincorporated UGA 0.2%162 6 0 16 39 26 20 56 0 Lynden Total 6.9%6,576 76 0 328 1,462 1,175 922 2,614 0 Lynden City 6.8%6,521 75 0 325 1,451 1,165 914 2,591 0 Lynden Unincorporated UGA 0.1%55 1 0 3 11 10 8 23 0 Nooksack Total 0.6%546 0 0 29 150 140 51 175 0 Nooksack City 0.6%542 0 0 29 149 139 51 174 0 Nooksack Unincorporated UGA 0.0%4 0 0 0 1 1 0 1 0 Sumas Total 0.7%701 30 0 83 272 168 58 90 0 Sumas City 0.7%701 30 0 83 272 168 58 90 0 Sumas UGA 0.0%0 0 0 0 0 0 0 0 0 LAMIRDS 9.9%9,407 335 0 853 990 1,471 1,459 4,299 12 Area Outside UGAs and LAMIRDS 23.5%22,410 797 0 2,032 2,369 3,508 3,476 10,228 70 Total 100.0%95,477 2,862 586 8,933 25,538 14,626 11,164 31,768 763 0-30% 6 Allocating Countywide Need to Jurisdictions •HAPT Tool allocates housing units by income band to Cities and unincorporated County areas •LCG modified tool to allocate units to: •Cities + UGAs •Unincorporated UGAs (Birch Bay and Columbia Valley) •Limited areas of more intensive rural development (LAMIRDS) •Rural/Resource Land Areas (Outside LAMIRDS and UGAs) •Counties can choose method of allocation: •Commerce baseline method (Method “A”) allocates an equal share of new units at each income band to each jurisdiction •Commerce is in the process of updating this methodology to reflect specific considerations of low -income units in rural areas 7 Income Bands and Housing Types •Commerce “Guidance for Updating Your Housing Element” broadly connects income bands to housing types. 8 Method A –Modified Geographies and Base Year Method A -Equal Share of Countywide Income Band to All Jurisdictions 0-30%Emergency % of Total Total Non-PSH PSH >30-50%>50-80%>80-100%>100-120%>120%Housing Needs Countywide Net New Units 2023-2045 31,334 8,055 3,250 6,652 2,155 1,514 2,218 7,490 520 Share of Countywide Net New Units 2023-2045 100%26%10%21%7%5%7%24% 0-30%Emergency % of Total Total Non-PSH PSH >30-50%>50-80%>80-100%>100-120%>120%Housing Needs Bellingham City & UGA 49.7%15,570 4,002 1,615 3,305 1,071 752 1,102 3,722 258 Birch Bay UGA 3.0%931 239 97 198 64 45 66 223 15 Blaine City & UGA 4.5%1,408 362 146 299 97 68 100 336 23 Cherry Point UGA 0.0%0 0 0 0 0 0 0 0 0 Columbia Valley UGA 1.5%470 121 49 100 32 23 33 112 8 Everson City & UGA 1.4%449 115 47 95 31 22 32 107 7 Ferndale City & UGA 9.8%3,055 785 317 649 210 148 216 730 51 Lynden City & UGA 11.0%3,448 886 358 732 237 167 244 824 57 Nooksack City & UGA 0.6%194 50 20 41 13 9 14 46 3 Sumas City & UGA 1.6%495 127 51 105 34 24 35 118 8 LAMIRDs 5.7%1,771 455 184 376 122 86 125 423 29 Area Outside UGAs and LAMIRDS 11.3%3,543 911 367 752 244 171 251 847 59 Total 100.0%31,334 8,055 3,250 6,652 2,155 1,514 2,218 7,490 520 9 Method A -Modified Method A (Adjusted for Rural Areas to 50% AMI) 0-30%Emergency % of Total Total Non-PSH PSH >30-50%>50-80%>80-100%>100-120%>120%Housing Needs Bellingham City & UGA 49.7%15,570 4,820 1,945 3,980 777 546 800 2,701 311 Birch Bay UGA 3.0%931 288 116 238 46 33 48 162 19 Blaine City & UGA 4.5%1,408 436 176 360 70 49 72 244 28 Cherry Point UGA 0.0%0 0 0 0 0 0 0 0 0 Columbia Valley UGA 1.5%470 146 59 120 23 16 24 82 9 Everson City & UGA 1.4%449 139 56 115 22 16 23 78 9 Ferndale City & UGA 9.8%3,055 946 382 781 153 107 157 530 61 Lynden City & UGA 11.0%3,448 1,068 431 882 172 121 177 598 69 Nooksack City & UGA 0.6%194 60 24 50 10 7 10 34 4 Sumas City & UGA 1.6%495 153 62 126 25 17 25 86 10 LAMIRDs 5.7%1,771 0 0 0 285 200 294 992 0 Area Outside UGAs and LAMIRDS 11.3%3,543 0 0 0 571 401 587 1,984 0 Total 100%31,334 8,055 3,250 6,652 2,155 1,514 2,218 7,490 520 10 Next Steps / Discussion •County and Cities refining housing allocations •Land Capacity Analysis test run 11 Permanent Supportive Housing •Definition from RCW 36.70A.030 •"Permanent supportive housing" is subsidized, leased housing with no limit on length of stay that prioritizes people who need comprehensive support services to retain tenancy and utilizes admissions practices designed to use lower barriers to entry than would be typical for other subsidized or unsubsidized rental housing, especially related to rental history, criminal history, and personal behaviors. Permanent supportive housing is paired with on-site or off-site voluntary services designed to support a person living with a complex and disabling behavioral health or physical health condition who was experiencing homelessness or was at imminent risk of homelessness prior to moving into housing to retain their housing and be a successful tenant in a housing arrangement, improve the resident's health status, and connect the resident of the housing with community-based health care, treatment, or employment services. Permanent supportive housing is subject to all of the rights and responsibilities defined in chapter 59.18 RCW. 12 Elected Officials | May 8, 2024 Population and Employment: Growth Projections and Preliminary Allocations Whatcom County Photo Credit: Rich Stratman LELAND CONSULTING GROUP Population and Employment Forecasts Growth Fundamentals •The State of Washington OFM makes demographic projections at the state and county level •Statewide and Whatcom County forecasts both assume decreasing average annual % growth in future years 3.3% 2.2%2.1% 1.7% 0.9% 1.5% 1.2%1.1%1.0%0.9%0.9%0.8% 0.00% 0.50% 1.00% 1.50% 2.00% 2.50% 3.00% 3.50% 1995 2000 2005 2010 2015 2020 p2025 p2030 p2035 p2040 p2045 p2050 Whatcom Average Annual Growth Rates (OFM Middle) 3 7.1% 7.5% 6.5% 6.1%6.0% 5.7% 5.2% 5.5%5.6% 5.2% 5.0%4.9% 3.9%4.1%3.8%3.9%3.7%3.7% 4.1% 4.8% 4.4% 4.9% 5.2%5.3% 0.0% 1.0% 2.0% 3.0% 4.0% 5.0% 6.0% 7.0% 8.0% 1990 1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 births deaths Births minus Deaths = Natural Increase •The fundamental dynamics behind that assumption are decreasing birth rates in the face of increasing death rates. OFM Middle Scenario Projections 4 5-yr Births & Deaths as a Pct. of Population actual (estimated)projected 7.4% 13.9% 8.6% 8.7% 6.5% 2.5% 6.9% 5.2%4.6%4.9%5.0%4.8% 0% 2% 4% 6% 8% 10% 12% 14% 16% 1990 1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 Net Migration is a More Volatile Factor •OFM assumes a relatively steady, but conservative net migration rate going forward OFM Middle Scenario Projections 5 actual (estimated)projected 5-year Net Migration as % of Population Updating Countywide Growth Projections •Updates to countywide population and employment growth projections –and allocations of that growth to UGAs –generally followed methods used in the 2016 Comprehensive Plan Update. •Review of OFM Middle projections for population, 2023 to 2045 •Revision of Low and High ranges --general tightening to make extremes more actionable for jurisdictions’ planning purposes •As with 2016, the OFM Low range was deemed too conservative relative to historical growth •OFM High range projection was also adjusted --but not as much, to remain conservative for infrastructure planning (i.e. avoiding risk of under-building infrastructure in the face of higher-than-expected growth pressure). 6 OFM vs. Adjusted Population Growth •Baseline (Middle) growth trajectory is tapering as natural increase declines and region depends more on net migration inflows. OFM High is further from Middle than Low is. We preserve that relationship but tighten the range for both (via adjustments to the more volatile migration rate assumptions). 7 Allocation of Population Growth to UGAs •After settling on a countywide growth trajectory and high/low range, we allocated overall population gains to UGAs •Based on shares of recent (10-year) growth within each UGA boundary (and areas outside UGAs as a rural/resource lands category) UGA Pop. 2013 Pop. 2023 Growth 2013 to 2023 Share of County Population 2023 Share of 10-yr. County Growth Bellingham 92,915 105,529 12,614 44.8%42.4% Birch Bay 7,698 8,908 1,210 3.8%4.1% Blaine 5,277 6,728 1,451 2.9%4.9% Cherry Point 35 61 26 0.0%0.1% Columbia Valley 3,060 3,577 517 1.5%1.7% Everson 2,683 3,171 488 1.3%1.6% Ferndale 12,962 16,762 3,800 7.1%12.8% Lynden 13,208 16,696 3,487 7.1%11.7% Nooksack 1,389 1,573 184 0.7%0.6% Sumas 1,445 1,810 365 0.8%1.2% Areas outside UGAs 65,349 70,985 5,637 30.1%18.9% Total 207,937 235,800 29,779 100.0%100.0% 8 Allocation of Population Growth to UGAs •Distributing shares for each of the scenario/ranges: Allocated Growth by Scenario(2023 to 2045) UGA Allocation Share Low Middle High Bellingham 42.5%16,242 24,158 36,462 Birch Bay 4.1%1,555 2,313 3,490 Blaine 4.9%1,865 2,774 4,186 Cherry Point ---- Columbia Valley 1.7%665 988 1,492 Everson 1.6%627 933 1,408 Ferndale 12.8%4,883 7,262 10,961 Lynden 11.7%4,481 6,665 10,060 Nooksack 0.6%237 352 531 Sumas 1.2%468 697 1,052 Areas outside UGAs 18.9%7,243 10,773 16,260 Total Population Growth 100%38,265 56,914 85,902 9 Employment Growth •After looking at historical small area employment by industry, GIS-matched to UGA boundaries •We computed shares by industry type (in broad groups of Industrial, Retail, Commercial, Resources) and by UGA to guide allocation across UGAs: Middle Scenario UGA Resources Industrial Retail Comm'l Total Bellingham 138 2,820 1,841 10,373 15,172 Birch Bay 0 22 10 92 124 Blaine 4 327 48 322 701 Cherry Point 0 450 0 43 493 Columbia Valley 0 6 3 4 13 Everson 10 88 24 81 203 Ferndale 19 961 201 961 2,141 Lynden 20 606 183 991 1,799 Nooksack 0 29 7 44 79 Sumas 2 98 8 43 150 Area outside UGAs 736 927 172 1,567 3,403 Whatcom Total 928 6,333 2,497 14,521 24,279 10