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Packet Special COTW Feb 4 2025
Whatcom County Council Special Committee of the Whole COUNTY COURTHOUSE 311 Grand Avenue, Ste #105 Bellingham, WA 98225-4038 (360) 778-5010 Meeting Agenda Tuesday, February 4, 2025 9AM Hybrid Meeting - Council Chambers HYBRID MEETING - ADJOURNS BY 9:55 A.M. (PARTICIPATE IN -PERSON, SEE REMOTE JOIN INSTRUCTIONS AT www.whatcomcounty.us/joinvirtualcouncil, OR CALL 360-778-5010) COUNCILMEMBERS Barry Buchanan Tyler Byrd Todd Donovan Ben Elenbaas Kaylee Galloway Jon Scanlon Mark Stremler CLERK OF THE COUNCIL Cathy Halka, AICP, CMC Council Special Committee of the Whole Meeting Agenda Call To Order Roll Call February 4, 2025 Announcements Individuals who require special assistance to participate in the Council's meetings are asked to contact the Council Office at 360.778.5010 at least 96 hours in advance. This committee meeting is also noticed as a meeting of the Whatcom County Council, with the agenda limited to committee business. Committee Discussion 1. AB2025-081 Discussion relating to population and employment projections for the County as a whole, Urban Growth Areas, and the Rural & Resource Lands associated with the 2025 Comprehensive Plan Update Items Added by Revision Other Business Adjournment Whatcom County Pure 2 Printed on 412512025 Whatcom County Agenda Bill Master Report File Number: AB2025-081 File ID: AB2025-081 Version: 1 File Created: 01/13/2025 Entered by: Matt Aamot Department: Planning and File Type: Discussion Development Services Department Assigned to: Council Committee of the Whole Agenda Date: 03/11/2025 Primary Contact Email: maamot@co.whatcom.wa.us TITLE FOR AGENDA ITEM: COUNTY COURTHOUSE 311 Grand Avenue, Ste #105 Bellingham, WA 98225-4038 (360)778-5010 Status: Discussed and Motion(s) Approved Final Action: 03/11/2025 Enactment #: Discussion relating to population and employment projections for the County as a whole, Urban Growth Areas, and the Rural & Resource Lands associated with the 2025 Comprehensive Plan Update SUMMARY STATEMENT OR LEGAL NOTICE LANGUAGE: Discussion relating to population and employment projections for the County as a whole, Urban Growth Areas and the Rural & Resource Lands associated with the 2025 Comprehensive Plan Update. HISTORY OF LEGISLATIVE FILE Date: Acting Body: Action: Sent To: 01/28/2025 Council Committee of the Whole DISCUSSED 02/04/2025 Council Special Committee of the Whole DISCUSSED 02/11/2025 Council Committee of the Whole PRESENTED AND DISCUSSED 02/25/2025 Council Committee of the Whole DISCUSSED 03/11/2025 Council Committee of the Whole DISCUSSED AND MOTION(S) APPROVED Whatcom County Page 1 Printed on 4/25/2025 Agenda Bill Master Report Continued (AB2025-081) Attachments: Staff Memo for 1.28.2025, City of Bellingham Letter, City of Bellingham Letter - Revised 1.27.2025, City of Blaine Letter, City of Everson Letter, City of Ferndale Letter, City of Lynden Letter, City of Nooksack Letter, City of Sumas Letter, Schedule of Presentations, Staff Memo for 2.4.2025, Presentation - Bellingham 2.4.2025, Presentation - County 2.4.2025, Presentation - Blaine 2.11.2025, Presentation - Everson 2.11.2025, Presentation - Ferndale 2.11.2025, Presentation - Lynden 2.11.2025, Presentation - Nooksack 2.11.2025, Presentation - Sumas 2.11.2025, Growth Projections - scenarios for 2.25.2025, Draft Non -Binding Resolution for discussion on 2.25.2025, Flood Maps 2.25.2025, Everson Flood Map 2.25.2025, Donovan discussion draft 2.25.25, Scanlon discussion draft for 3.11.2025, Letter - Whatcom Environmental Council Whatcom County Page 2 Printed on 4/25/2025 WHATCOM COUNTY Planning &Development Services 5280 Northwest Drive Bellingham, WA 98226 W A S H I N T N PDS@co.whatcom.wa.us 360-778-5900 January 16, 2025 TO: The Honorable Whatcom County Council FROM: Matt Aamot, Senior Planner THROUGH: Mark Personius, Director RE: 2025 Comp Plan Update - Preliminary Population and Employment Projections The Growth Management Act (GMA) requires Whatcom County and the cities to review and revise our respective comprehensive plans and development regulations by December 31, 2025 (RCW 36.70A.130). Additionally, the GMA requires review of urban growth areas (UGAs) under RCW 36.70A.130(3). The UGAs must have sufficient areas and densities to accommodate population, housing and employment growth projected for the new planning period (2023 - 2045). The GMA also requires that County and City Comprehensive Plans, including population and employment growth projections, must be coordinated and consistent (RCW 36.70A.100). Therefore, Whatcom County has initiated a Comprehensive Plan and development regulations update. The Comprehensive Plan update, which includes the UGA review, is being conducted in close coordination with the seven cities in Whatcom County. This memo provides additional background information, discussion of the preliminary growth projections, identification of several issues for the County Council's consideration, and next steps. Ultimately, we are seeking direction from the Council on the preliminary population and employment growth projections for a "Non -Binding Multi -Jurisdictional Resolution." A "Non -Binding Multi -Jurisdictional Resolution" relating to population and employment growth allocations was approved in 2016 Comp Plan update process (Resolution 2014-013). We are asking the County Council to consider a similar resolution in the 2025 Comprehensive Plan update process. The seven city councils would consider similar resolutions. The Non -Binding Resolutions would facilitate coordination between the County and cities relating to issues such as housing allocations, capital facility planning, and UGA planning as required by the GMA. Final growth projections would ultimately be adopted by the County Council in the 2025 Comprehensive Plan. 1 In the fall of 2023, the County Executive invited elected officials from the County and cities to a series of meetings to discuss the Comprehensive Plan Update and UGA review. The first elected officials meeting was held on November 8, 2023 and these meetings have been held periodically since that time. The County and cities hired a consulting firm to develop initial population and employment growth projections. The Whatcom County Comprehensive Plan Population and Employment: Growth Projections and Preliminary Allocations Technical Report (Leland Consulting Group, May 22, 2024, referred to as "Tech Report" in the tables below) includes preliminary low, middle, and high growth projections to UGAs and the Rural and Resource Lands. County Planning and Development Services (PDS) and the consultant met with the County Council's Planning and Development Committee on June 4, 2024, to discuss the consultant's population and employment Tech Report. County PDS met with the County Council's Committee of the Whole to discuss growth allocations for the Birch Bay UGA, Cherry Point UGA, Columbia Valley UGA, and Rural & Resource Lands outside UGAs on October 8, 22, and 29. At the October 22 meeting, the County Council approved a motion as follows: Have Planning and Development Services plan to shift some of those 10,000 that are currently assigned for LAMIRDS and the rural area to other locations. In response, County PDS reduced the Rural and Resource Lands population allocation from 10,000 to 9,000. The cities were developing UGA proposals based upon their unique circumstances and we did not shift the 1,000 people removed from Rural and Resource Lands to other areas. In late October and early November, the cities submitted preliminary growth proposals to the County. Involvement by city councils in developing their respective growth proposals is described in most of the letters submitted by the cities in January 2025. At the November 14, 2024 County Planning Commission meeting, the cities and the County presented their respective preliminary population and employment growth proposals for UGAs and Rural & Resource Lands (located outside UGAs). The Planning Commission held a public hearing and work session that same evening. The Commission held another work session on December 12, 2024, but did not arrive at a majority vote on the growth projections. The preliminary growth proposals presented by the cities and the County at the November 14 Planning Commission meeting are summarized below, along with notes indicating how these proposals relate to the Technical Report's low, middle and high projections. 2 Table 1. Population Growth Proposals Area Tech Tech Tech Report Report Report Low Middle High Bellingham UGA 16,242 24,158 36,462 Birch Bay UGA 1,555 2,313 31490 Blaine UGA 1,865 2,774 4,186 Cherry Point UGA 0 0 0 Columbia Valley UGA 665 988 1,492 Everson UGA 627 933 1,408 Ferndale UGA 4,883 7,262 10,961 Lynden UGA 4,481 6,665 10,060 Nooksack UGA 237 352 531 Sumas UGA 468 697 1,052 Rural/Resource Lands 7,243 10,773 16,260 (Outside UGAs) TOTAL 38,266 56,915 85,902 City & Percent City and County County of Total Proposals in Relation to Proposals Growth Tech Report 30,310 44.8% Between Middle and High 2,662 3.9% Between Middle and High 3,500 5.2% Between Middle and High 0 0.0% N/A 1,137 1.7% Between Middle and High 1,408 2.1% High 10,961 16.2% High 6,665 9.90/0 Middle 995 1.50/0 Above High 1,000 1.50/0 Between Middle and High 9,000 13.3% Between Low and Middle Note: Cherry Point is an industrial UGA and does not have a population allocation. Table 2. Employment Growth Proposals Area Tech Tech Tech Report Report Report Low Middle High Bellingham UGA 9,719 15,172 23,642 Birch Bay UGA 80 124 194 Blaine UGA 449 701 1,092 Cherry Point UGA 316 493 769 Columbia Valley UGA 9 13 21 Everson UGA 130 203 317 Ferndale UGA 1,372 2,141 3,337 Lynden UGA 1,152 1,799 2,803 Nooksack UGA 51 79 124 Sumas UGA 96 150 233 Rural/Resource Lands 2,180 3,403 5,302 (Outside UGAs) City & Percent City and County County of Total Proposals in Relation to Proposals Growth Tech Report 19,384 59.9% Between Middle and High 450 1.4% Above High 1,092 3.4% High 1200 3.7% Above High 350 1.10/0 Avove High 602 1.90/0 Above High 3,337 10.3% High 1,799 5.6% Middle 232 0.7% Above High 500 1.50/0 Above High 3,403 10.50/0 Middle TOTAL 15,554 24,278 37,8341 32,349 100.00/0 3 There are three issues related to growth projections (housing, UGA sizing, and population in Rural and Resource Lands) that we would like to highlight: 1. Housing - The State Legislature passed House Bill 1220 amending the GMA to require local comprehensive plans to address housing needed for households of various income levels. The State of the State's Housing 2024 Supply and Affordability in Washington State (Washington Center for Real Estate Research, University of Washington, October 2024) indicates: ... House Bill 1220, passed in 2021, required communities to "plan for and accommodate" housing affordable to all income levels. The bill also required the Washington State Department of Commerce to project housing needs for communities in the state. These needs were calculated for income categories corresponding to those established by the US Department of Housing and Urban Development: extremely low income or 0-30% of Area Median Income (AMI); very low income or >30-50% of AMI); low income or >50-80% of AMI; moderate income or >80-120% of AMI; and upper income or >120% of AMI. Needs for emergency housing and shelters were also projected... (p. 7). In order to identify the number of housing units needed for each jurisdiction, the State Department of Commerce developed the Housing for All Planning Tool (HAPT) spreadsheets for use by local jurisdictions (our consultant modified the tool to address UGAs and limitations on Rural housing under GMA). The overall countywide population figure is inserted in the HAPT, and it calculates the number of housing units that are needed at the various income bands (low, moderate, high income) in each UGA and the Rural & Resource Lands outside UGAs. Therefore, the countywide population figure has implications for how much housing will need to be accommodated in each UGA and the Rural areas. The tables below show the housing units needed for each UGA and the Rural & Resource Lands from the HAPT, based upon Draft EIS Alternatives 1 and 2. Alternative 1 includes countywide population growth of 56,915 over the 22- year planning period (2023-2045) consistent with the OFM medium projection. Alternative 2 includes countywide population growth of 67,638 people consistent with the preliminary City/County proposal. If a lower countywide growth projection is selected, then the cities and County would plan for fewer housing units including fewer more affordable low- and moderate -income units. If a higher countywide growth projection is selected, then the cities and County would plan for more housing units, including more affordable housing units for low and moderate income households. As shown below, the jurisdictions would plan for approximately 4,800 more housing units under Alternative 2 than Alternative 1. 4 ALTERNATIVE 1 (OFM MEDIUM) 0-30% Emergency %of Total Total Non-PSH PSH >30-50% >50-80% >80-100% >100-120% >120% Housing Need Bellingham City & UGA 48.75% 15,219 4,711 1,901 3,864 760 709 1,119 2,155 253 Birch Bay UGA 3.00% 936 290 117 238 47 44 69 132 16 Blaine City & UGA 4.68% 1,461 452 182 371 73 68 107 207 24 Cherry Point UGA 0.00% -1 0 0 0 0 0 0 0 0 Columbia Valley UGA 1.43% 447 138 56 113 22 21 33 63 7 Everson City & UGA 1.39% 433 134 54 110 22 20 32 61 7 Ferndale City & UGA 10.60% 3,308 1,024 413 840 165 154 243 468 55 Lynden City & UGA 11.38% 3,552 1,100 444 902 177 166 261 503 59 Nooksack City & UGA 0.61% 190 59 24 48 10 9 14 27 3 Sumas City & UGA 1.53% 476 147 59 121 24 22 35 67 8 LAMIRDs and Rural Areas 16.65% 5,198 0 0 45 855 301 305 3,692 87 Total 100.00% 31,220 8,055 3,250 6,652 2,155 1,514 2,218 7,376 520 ALTERNATIVE 2 (COUNTYICITY SCENARIO) % of Total Total 0-30% Housing Housing Non-PSH PSH Units Units Bellingham City & UGA 51.06% 18,390 4,978 1,944 Birch Bay UGA 2.92% 1,051 285 111 Blaine City & UGA 4.93% 1,774 480 188 Cherry Point UGA 0.00% 0 0 0 Columbia Valley UGA 1.39% 502 136 53 Everson City & UGA 1.70% 610 165 65 Ferndale City & UGA 12.94% 4,659 1,261 492 Lynden City & UGA 9.82% 3,535 957 374 Nooksack City & UGA 1.20% 433 117 46 Sumas City & UGA 1.79% 643 174 68 Rural/Resource Lands 12.26% 4,416 0 0 >30-50% >50-80%?80-100% >100-120% >120% 4,158 1,197 989 1,400 3,725 238 68 56 80 213 401 115 95 135 359 0 0 0 0 0 113 33 27 38 102 138 40 33 46 124 1,053 303 250 355 944 799 230 190 269 716 98 28 23 33 88 145 42 35 49 130 45 855 304 307 2,905 Totals 100.00% 36,013 8,553 3,340 7,189 2,912 2,002 2,712 9,305 Notes: PSH means "Permanent supportive housing." This term is defined in the Growth Management Act at RCW 36.70A.030(31)). The 0-30%, 30-50%, 50-80%, etc. figures refer to Area Median Income (AMI) as described above. Emergency Housing Needs 299 17 29 0 8 10 76 58 7 10 72 2. UGA Sizing - Growth projections have implications for UGA sizing. The GMA states "... the county and each city within the county shall include areas and densities sufficient to permit the urban growth that is projected to occur in the county or city for the succeeding twenty-year period..." (RCW 36.70A.110(2)). The preliminary growth proposals from the cities and County were included in the Planning Commission's November 14 packet. Each growth proposal in the packet has a section relating to land capacity of the UGA. The preliminary land capacity analyses compare the proposed growth allocations to the capacity of each UGA to accommodate growth. A deficit of land capacity in a given UGA can be addressed by increasing densities in the existing UGA and/or expanding the UGA. The land capacity analysis section of the proposals gives a preliminary indication of whether UGA expansions may be considered by the jurisdictions to accommodate their respective population and employment growth proposals. 586 5 3. Population in Rural and Resource Lands (outside UGAs) Population growth in the Rural areas and Resource Lands has slowed over the last several decades, as shown below. Population Growth in Rural and Resource Lands (1990-2020) Average Average Share of Annual Annual Countywide Growth for Growth for Growth Growth for Year Population Decade Decade Rate Decade 1990 45,321 2000 56,775 11,454 1,145 2.3% 29.3% 2010 64,862 8,087 809 1.3% 23.6% 2020 69,821 4,959 496 0.7% 19.3% Source: Population data from 1990 and 2000 is from the Whatcom County Population and Employment Projections and Urban Growth Area Allocations Phase I Technical Report (BERK, 2013, p. 9). Population data for 2010 and 2020 is derived from the State Office of Financial Management's Small Area Estimates Program. The projections in the 2024 Technical Report middle population scenario would increase population in Rural and Resource Lands by 10,773 people over the planning period (2023-2045). The middle scenario, based upon the share of countywide growth the Rural and Resource Lands received from 2013 to 2023, would equate to an additional 490 people per year in the Rural and Resource Lands from 2023-2045. On an average yearly basis, this is comparable to growth experienced between the last two Censuses. According to analysis by the State Office of Financial Management (OFM) and the Puget Sound Partnership shown in the table below, 86% of the countywide growth from 2017-2023 was accommodated in cities and UGAs and 14% outside UGAs. This means Whatcom County had the fourth highest share of new development accommodated within UGAs of all twelve Puget Sound counties in the last six years. 11 100% 90% N 80% a = 70% 3 60% r "3 50% D C7 40% 0 30% = m v 20% `m a 10% 0% 2011 - 20161 100% 93% 92% 88% 92% 93% 2017 - 2023 Change -1% -0% -4% -3% -11% -15% ``Q, .11 C11 F VO o I mQ y T .2011 - 2016 ■ 2017 - 2023 1 72% 41% 44% 18% 39% 6% 0' +5% +8% -12% +10% -12% +8% 41 The current County Planning and Development Services' proposal is to allocate population growth of 9,000 new residents in the Rural and Resource Lands over the planning period (2023-2045). The 9,000 population growth projection for Rural and Resource Lands would equate to growth of about 409 people per year in these areas over the 22-year planning period. It would continue the trend of lower growth experienced outside UGAs over the last three decades. The current Whatcom County Comprehensive Plan allocates 16.1% of countywide growth to areas outside UGAs. If this same percentage growth were allocated to the countywide population figures being studied in the Draft EIS, it would equate to the Rural population allocations as shown below: Theoretical Rural Growth Allocations (2023-2045) Countywide Rural Growth Rural Growth Growth Share Allocation No Action Alternative 39,650 16.1% 6,384 Alternative 1 (OFM Medium) 56,915 16.1% 9,163 Alternative 2 (City & County Proposals) 67,638 16.1% 10,890 Alternative 3 (Technical Report High) 85,902 16.1% 13,830 NOTE: The theoretical Rural Growth Allocations shown above were derived by applying the the 16.1% growth share to the countywide growth projection associated with each alternative. The Rural Growth Allocations shown above are for illustrative purposes only and are not the same as the rural growth allocations in the actual alternatives (except for the No Action Alternative, which uses the 16.1% rural growth share). 7 Please note that, if the OFM medium countywide projection (Alternative 1) were used, the current 16.1% future growth allocation to the Rural and Resource Lands adopted in the existing Comprehensive Plan would result in approximately 9,000 additional people in these areas over the 22-year planning period. Of course, the County Council can make the policy choice to allocate lower growth to Rural areas than in the past. As indicated in the County Planning and Development Services' memo to the County Council dated October 25, 2024, Whatcom County Comprehensive Plan Chapter 2 includes Policy 2DD-1, which requires the County to: ... compare nonurban population growth trends with the adopted nonurban population growth projection. If the trend over five years indicates that nonurban growth is significantly higher than adopted projections, the County shall take action to address the discrepancy. Actions may include changing the allocation of the projected population growth during the comprehensive plan update required per RCW 36.70A.130(1), or changing development regulations to limit growth outside the urban growth areas. In addition, as the County and cities review the capacity for growth in the urban growth areas, the county should coordinate with the cities to ensure that policies are in place that are consistent with encouraging growth in the urban areas and reducing demand for development in rural areas (emphasis added). Based upon existing Policy 2DD-1, the County must act if future Rural growth "significantly" exceeds the projection in the Comprehensive Plan. Potential actions may include: 1. Changing the allocation of the projected population growth during the comprehensive plan update required per RCW 36.70A.130(1); 2. Changing development regulations to limit growth outside the urban growth areas; and 3. The County and cities reviewing the capacity for growth in the urban growth areas, the county coordinating with the cities to ensure that policies are in place that are consistent with encouraging growth in the urban areas and reducing demand for development in rural areas. There's always the option of simply changing the Rural allocations at a later date to reflect the growth that has already happened (# 1 above). However, under House Bill 1220 and related state guidance on planning for housing, the Growth Management Act now requires a county -wide process to allocate housing at the various income bands to the UGAs and Rural areas. Changing the Rural allocation would modify how many housing units each city and UGA must accommodate at the various income bands. Therefore, any future change to the Rural allocation would involve discussion with the cities to ensure our respective comprehensive plans are coordinated and consistent. Another action mentioned in Policy 2DD-1 is to change development regulations to limit growth in Rural areas (# 2 above). This could include downzoning. For example, the EIS will include a mitigating measure to potentially downzone "Rural Study Areas" (lands zoned R5A or R10A that have agricultural significance), further restricting land division. Rezoning other Rural areas to allow less development could also be considered. It should be noted that downzoning to reduce land divisions in Rural areas would not prevent development on the many existing legal H., lots in these areas. If rural growth were to significantly exceed the final rural population projection adopted by the County Council, then slowing development on existing lots in Rural areas may require additional measures such as capping or rationing the number of building permits that can be issued each year outside of UGAs. There are risks with this approach that would require close consultation with the County's legal counsel. Budget implications of reduced permit fee revenue should also be considered. The final action mentioned is working with the cities to encourage growth in UGAs (# 3 above). Local governments can do a number of things to encourage growth in urban areas such as provide adequate land supply through zoning, plan and construct infrastructure to support development, and facilitate annexation of land in UGAs. At the current time, all seven cities have policies that generally do not allow extension of public water and sewer outside city limits prior to annexation. There is concern that when a city extends public water and sewer for development in the UGA (outside city limits) it may reduce the incentive for property owners in these areas to petition for annexation at a later date. However, the State Legislature has amended annexation statutes over the last 15 years to allow alternative annexation methods such as when the city, county, and fire district enter into an interlocal agreement for annexation (a property owner petition is not required). If the Council is interested in incorporating any of these strategies into this current planning process please make a motion making that request. PDS would then work with the Prosecuting Attorney's Office and the cities, as appropriate, to identify options for your consideration. Draft Environmental Impact Statement (DEIS) The Draft EIS will be issued in the 1st quarter of 2025. The Draft EIS will include four alternatives that range in total County population growth from 39,650 to 85,902 over the 22-year planning period (2023-2045). This provides "bookends" that allow decision makers to select a population growth figure within the range of alternatives studied in the EIS. PDS has heard concerns that the Draft EIS alternatives may not provide decision makers with enough information to distinguish between the impacts when there is a single countywide population growth projection that is distributed differently (e.g. including a higher percentage of population growth in the Bellingham UGA). In response, PDS and the consultant are exploring the possibility of a separate study analyzing traffic, GHG emissions, and housing distributions for other alternatives that are not being studied in the Draft EIS. This information could inform selection of a "preferred alternative" for the Final EIS without delaying the Draft EIS process, which would result in loss of State grant funding that must be expended by June 30, 2025. pi Summary PDS would like to discuss the population and employment projections at the County Council's Committee of the Whole meeting on January 28. Additionally, we would like to have a follow up meeting in February where the cities and County present and explain their growth proposals to Council. The growth projections would come back to Council in the form of a draft non -binding multi -jurisdictional resolution, which would also be considered by all seven city councils. The intent is to facilitate County and city plans that are coordinated and consistent as required by the GMA (RCW 36.70A.100). Thank you for your consideration of this matter. We look forward to discussing it with you. 10 U City of Bellingham 210 Lottie Street Bellingham, WA 98225 MEMORANDUM - BELLINGHAM PRELIMINARY GROWTH PROPOSAL TO: Whatcom County Council CC: Bellingham Mayor Kim Lund, City Council, City Planning Commission FROM: Chris Behee, Long Range Division Manager, City of Bellingham Department of Planning and Community Development SUBJECT: Bellingham Preliminary Growth Proposal DATE: January 10, 2025 Purpose As the County Council considers a multi -jurisdictional resolution on growth, the City of Bellingham is grateful for this opportunity to share our priorities and work to -date on a preliminary growth proposal for the 2025 periodic update to the comprehensive plan. Perspective on the Countywide Growth Strategy In alignment with Bellingham's climate action, sustainability, and housing goals, the City supports a countywide growth strategy that directs more growth to city and county urban growth areas (UGAs) while minimizing growth in rural areas outside UGAs. To accomplish this, Bellingham is willing to accept a percentage of countywide growth that is higher than the historic shares allocation and at the same time, recommends a countywide total that aligns with the Washington State Office of Financial Management (OFM) Medium (most -likely) growth projection. The success of this growth strategy depends on a significant commitment of City resources to provide infrastructure and urban services, and the ability of Whatcom County to approve land use changes directing growth to UGAs rather than rural areas. The resulting concentration of lower -income households in Bellingham will also mean a greater reliance on County health resources to provide necessary human services support. Bellingham's Preliminary Growth Proposal The City of Bellingham Planning Commission and City Council Planning Committee convened a joint work session on October 24, 2024, to discuss growth in Bellingham related to the 2025 periodic update to the comprehensive plan. The discussion centered around population, housing, and employment projections, capacity, and a preliminary growth proposal to recommend for inclusion in the countywide non -binding multi -jurisdictional resolution. The preliminary growth proposal is intended to provide a starting point for impacts analysis, land use policy development, and capital infrastructure planning. Bellingham's preliminary proposal for population, housing, and employment growth is as follows: Bellingham City + UGA 2023 Total 2023-2045 22-Year 2025-2045 20-Year Annual 1-Year 2045 Total Population (people) 105,529 30,310 27,555 1,378 135,839 Housing (units) 104,884 18,390 16,718 835 123,274 Employment (jobs) 70,384 19,384 17,622 881 89,768 These totals were recommended by City staff at the joint work session, were discussed in detail, and were agreed to by the Planning Commission and City Council Planning Committee as appropriate for a preliminary proposal for inclusion in the non -binding resolution. Planning Commission and Council Planning Committee members emphasized that this proposal is a starting point and that the results of the impacts analysis and infrastructure planning work should guide adjustments to these totals as a final growth strategy is developed. Relationship to Alternatives in the Environmental Impact Statement The Environmental Impact Statement (EIS) is currently underway and includes three growth alternatives for evaluation in the impacts analysis. • Alternative 1 assumes population growth of 56,915 people for Whatcom County by 2045 which matches the OFM Medium (most likely) projection. This alternative allocates Bellingham a percentage equal to our historic 42.4% share of growth or about 24,158 people. Alternative 2 has a countywide growth total of 67,638 people. This alternative is a collection of unique requests from each city and the County. The population growth of 30,310 people for Bellingham matches the City's preliminary growth proposal. Because most cities chose hiaher population totals than their historic share of the OFM Medium oroiection. the countvwide total for this alternative is 10.723 people hiaher than that protection. • Alternative 3 has a countywide growth total of 85,902 people which matches the Adjusted High projection and, like Alternative 1, allocates growth based on the historic shares model. Under this alternative Bellingham receives growth of 36,462 people. Rationale for the Proposal Bellingham's preliminary proposal is driven by three factors. These include the close alignment with recent population growth in Bellingham, the urgent need for more housing, and a desire to limit climate impacts and meet sustainability goals by accommodating more growth in Bellingham and less growth the rural areas of Whatcom County. Close Alignment with Recent Population Growth Over the past 10 years (2014-2024) the Bellingham UGA has accommodated 13,341 new residents or about 1,334 people per year. EIS Alternative 1 allocates Bellingham growth of 1,098 people per year and Alternative 3 allocates 1,657 people per year. The City's preliminary proposal (matching the City's growth in EIS Alternative 2) allocates 1,378 people per year which splits the difference 2 between the Alternative 1 and 3 allocations and aligns very closely with growth Bellingham has accommodated over the past 10 years. It should be noted that over the past 3-5 years Bellingham has averaged higher growth than the 10-year average (1,447 to 1,680 people per year). This means we should not plan for anything less than continuing that 10-year average. Urgent Need for More Housing As expressed in the Mayor's November 21, 2024, executive order, Bellingham has a critical shortage of housing and is committed to immediate action increasing opportunities for more housing supply affordability and choices to match the growing needs in our community. The WA State Department of Commerce housing allocation for Bellingham's preliminary growth proposal of 30,310 people is 18,390 housing units. In addition to providing housing for new residents, this allocation accounts for households that are currently un- housed, households that are cost -burdened (living in housing that requires more than 30% of household income) and increasing Bellingham's community -wide vacancy rate from 2.5% to a more healthy 6% rate. The allocation assumes completion of an average 835 new housing units per year. Compared to the 610 units per year Bellingham averaged between 2000 and 2024 this is an increase of about 37% or 225 more homes per year. Also of critical importance, the Commerce housing allocation identifies that about 60% of these housing units or about 500 units per year should be affordable to households earning less than 80% of area median income. Accommodating more Growth in Bellingham to Meet Climate and Sustainability Goals Bellingham places a high priority on our response to climate change, protection of resource lands, and fiscal sustainability. Accommodating growth in compact urban areas close to jobs and services minimizes vehicle trips and related greenhouse gas emissions. It also preserves resource lands and makes the most efficient use of city services and infrastructure. To that end, the City has adopted urban village master plans, has revised multi -family zoning, accessory dwelling unit, and infill housing regulations, and has adopted and invested in implementation of multi -modal infrastructure plans. And Bellingham continues to work toward creative and innovative ways to support smart, sustainable development in the coming decades. Over the past 10 years the City has accommodated 44% of countywide population, 63% of employment, and 52% of housing growth. Unincorporated rural areas have accommodated 19% of population, 6% of employment, and 15% of housing growth. A 2025-2045 growth allocation that places a larger share of population and housing in Bellingham and less in rural areas is consistent with Bellingham's goals, the Countywide Planning Policies, and the Growth Management Act. As the only Tier 1 city north of Everett, Bellingham is the one Whatcom County jurisdiction subject to the middle -scale housing requirements of HB1110. These regulatory changes will unlock new housing capacity making it more likely that the City will accommodate a higher proportion of countywide growth than in past planning cycles. Comparing the City's preliminary growth proposal to the OFM Medium (most -likely) projection for 2045 would mean Bellingham would accommodate about 53% of countywide population growth. Preliminary Estimate of Growth Capacity Bellingham's preliminary estimate of growth capacity accounts for changes to residential zoning to comply with recent State housing legislation. Specifically, allowing middle -scale housing (including townhomes) in all residential zones and up to four homes per lot or a fifth or sixth if they are affordable. The analysis follows the steps outlined in the approved countywide Land Capacity Analysis Methodology. It accounts for critical areas and associated buffers, future infrastructure, infrastructure gaps, market factors, and the anticipated impact of landmark trees. Additional analysis steps unique to Bellingham estimate how much infill development on already developed lots is likely to occur during the 20-year planning period (ADUs and middle -scale housing). The analysis shows that with these anticipated zoning changes and current and funded infrastructure improvements, Bellingham has estimated capacity to accommodate about 17,185 housing units and 17,727 jobs by 2045. Residential Capacity Analysis Summary 1,980 single -detached units 5,045 middle -scale units (ADUs, townhomes, etc.) 9,160 multi -unit (7+ unit types) 1,000 group quarters units (7+ unit types) 17,185 Total housing units Comparing this estimated capacity to the preliminary proposal there is a capacity shortfall of about 1,200 housing units and 1,660 jobs. An analysis of potential additional zoning and UGA boundary changes shows capacity for an estimated 3,625 more housing units and 1,355 jobs by 2045. Enabling this capacity would require significant investment in a variety of infrastructure elements to provide opportunities for development. These potential changes are summarized below: NOTE — If the above -average 8% commercial vacancy rate in Bellingham's downtown area normalizes to the citywide average 3%, the capacity shortfall for future jobs is significantly less. Activate transit -oriented development (TOD) within walking distance of high -frequency transit routes by allowing additional density, height, floor area, or incentives to create opportunities for more housing and jobs. The City estimates that these changes could create capacity for up to 1,275 additional housing units split 1/3 middle -scale (townhomes etc.) and 2/3 multi -unit (7+ unit types), and up to 640 jobs in commercial development by 2045. The City's baseline capacity estimate already assumes close collaboration with Whatcom Transportation Authority to plan, fund, and build transit and pedestrian infrastructure elements. Adopting TOD land use changes would make these efforts even more critical for successfully accommodating growth. UGA boundary adjustments that bring either the North Bellingham UGA Reserve or South Yew Street UGA Reserve into Bellingham's UGA could add capacity for an estimated 400 to 1,600 housing units and 175 and 715 jobs by 2045. Development of 4 the North Bellingham UGA Reserve (about 1,200 housing units and 540 jobs by 2045) would require a new water reservoir on King Mountain, a new fire station (including building, equipment, and staff), and extension of arterial streets and other urban services. Development of the South Yew Street UGA Reserve (about 400 housing units and 175 jobs by 2045) would require a new water reservoir on Samish Hill, extension of arterial streets, sanitary sewer system improvements, a new fire station (including building, equipment, and staff), and extension of other urban services. The infrastructure investments to activate these areas would also provide additional development opportunities for adjacent areas already inside the City or UGA (areas with currently limited development capacity due to existing infrastructure gaps). It is estimated that these additional opportunities could provide capacity for up to 750 housing units by 2045. Housing Affordability Bellingham's high proportion of multi -unit housing capacity provides market rate options for households earning close to 80% of area median income (AMI). Providing deeper affordability to households earning 60% or less of AMI typically requires public subsidy. The combined $14M in annual funds from Bellingham's voter -approved housing levy, affordable housing sales tax, City general and REET funds, and federal funds are currently able to support production of about 130 subsidized rental housing units per year (as noted above, the need is much greater). Just as important as funding affordable housing is the need for qualified non-profit and government partner organizations to provide on -site case management and related human services. Addressing the funding and community partner resource gap between what is currently possible, and the communitywide need is a challenge best shared by all jurisdictions in Whatcom County. Next Steps There are unresolved questions associated with this proposal. When the Draft EIS impacts analysis becomes available in February, Bellingham will determine which zoning and boundary changes and infrastructure investments best address community housing and employment needs, balance environmental impacts, and are fiscally achievable and sustainable. Additionally, the preliminary proposals independently submitted by each jurisdiction represent a combined countywide growth 19% (10,723 people) higher than the OFM Medium (most -likely) projection for 2045. Bellingham supports further discussion with Whatcom County and the cities, working towards a strategy encouraging growth in UGAs and minimizing growth in rural areas that aligns more closely with the OFM Medium population projection. U City of Bellingham 210 Lottie Street Bellingham, WA 98225 MEMORANDUM - BELLINGHAM PRELIMINARY GROWTH PROPOSAL TO: Whatcom County Council CC: Bellingham Mayor Kim Lund, City Council, City Planning Commission FROM: Chris Behee, Long Range Division Manager, City of Bellingham Department of Planning and Community Development SUBJECT: Bellingham Preliminary Growth Proposal DATE: January 10, 2025 (corrected January 27rn) Purpose As the County Council considers a multi -jurisdictional resolution on growth, the City of Bellingham is grateful for this opportunity to share our priorities and work to -date on a preliminary growth proposal for the 2025 periodic update to the comprehensive plan. Perspective on the Countywide Growth Strategy In alignment with Bellingham's climate action, sustainability, and housing goals, the City supports a countywide growth strategy that directs more growth to city and county urban growth areas (UGAs) while minimizing growth in rural areas outside UGAs. To accomplish this, Bellingham is willing to accept a percentage of countywide growth that is higher than the historic shares allocation and at the same time, recommends a countywide total that aligns with the Washington State Office of Financial Management (OFM) Medium (most -likely) growth projection. The success of this growth strategy depends on a significant commitment of City resources to provide infrastructure and urban services, and the ability of Whatcom County to approve land use changes directing growth to UGAs rather than rural areas. The resulting concentration of lower -income households in Bellingham will also mean a greater reliance on County health resources to provide necessary human services support. Bellingham's Preliminary Growth Proposal The City of Bellingham Planning Commission and City Council Planning Committee convened a joint work session on October 24, 2024, to discuss growth in Bellingham related to the 2025 periodic update to the comprehensive plan. The discussion centered around population, housing, and employment projections, capacity, and a preliminary growth proposal to recommend for inclusion in the countywide non -binding multi -jurisdictional resolution. The preliminary growth proposal is intended to provide a starting point for impacts analysis, land use policy development, and capital infrastructure planning. Bellingham's preliminary proposal for population, housing, and employment growth is as follows: Bellingham City + UGA 2023 Total 2023-2045 22-Year 2025-2045 20-Year Annual 1-Year 2045 Total Population (people) 105,529 30,310 27,555 1,378 135,839 Housing (units) 47,719 18,390 16,718 835 66,109 Employment (jobs) 70,384 19,384 17,622 881 89,768 These totals were recommended by City staff at the joint work session, were discussed in detail, and were agreed to by the Planning Commission and City Council Planning Committee as appropriate for a preliminary proposal for inclusion in the non -binding resolution. Planning Commission and Council Planning Committee members emphasized that this proposal is a starting point and that the results of the impacts analysis and infrastructure planning work should guide adjustments to these totals as a final growth strategy is developed. Relationship to Alternatives in the Environmental Impact Statement The Environmental Impact Statement (EIS) is currently underway and includes three growth alternatives for evaluation in the impacts analysis. • Alternative 1 assumes population growth of 56,915 people for Whatcom County by 2045 which matches the OFM Medium (most likely) projection. This alternative allocates Bellingham a percentage equal to our historic 42.4% share of growth or about 24,158 people. Alternative 2 has a countywide growth total of 67,638 people. This alternative is a collection of unique requests from each city and the County. The population growth of 30,310 people for Bellingham matches the City's preliminary growth proposal. Because most cities chose hiaher population totals than their historic share of the OFM Medium oroiection. the countvwide total for this alternative is 10.723 people hiaher than that protection. • Alternative 3 has a countywide growth total of 85,902 people which matches the Adjusted High projection and, like Alternative 1, allocates growth based on the historic shares model. Under this alternative Bellingham receives growth of 36,462 people. Rationale for the Proposal Bellingham's preliminary proposal is driven by three factors. These include the close alignment with recent population growth in Bellingham, the urgent need for more housing, and a desire to limit climate impacts and meet sustainability goals by accommodating more growth in Bellingham and less growth the rural areas of Whatcom County. Close Alignment with Recent Population Growth Over the past 10 years (2014-2024) the Bellingham UGA has accommodated 13,341 new residents or about 1,334 people per year. EIS Alternative 1 allocates Bellingham growth of 1,098 people per year and Alternative 3 allocates 1,657 people per year. The City's preliminary proposal (matching the City's growth in EIS Alternative 2) allocates 1,378 people per year which splits the difference 2 between the Alternative 1 and 3 allocations and aligns very closely with growth Bellingham has accommodated over the past 10 years. It should be noted that over the past 3-5 years Bellingham has averaged higher growth than the 10-year average (1,447 to 1,680 people per year). This means we should not plan for anything less than continuing that 10-year average. Urgent Need for More Housing As expressed in the Mayor's November 21, 2024, executive order, Bellingham has a critical shortage of housing and is committed to immediate action increasing opportunities for more housing supply affordability and choices to match the growing needs in our community. The WA State Department of Commerce housing allocation for Bellingham's preliminary growth proposal of 30,310 people is 18,390 housing units. In addition to providing housing for new residents, this allocation accounts for households that are currently un- housed, households that are cost -burdened (living in housing that requires more than 30% of household income) and increasing Bellingham's community -wide vacancy rate from 2.5% to a more healthy 6% rate. The allocation assumes completion of an average 835 new housing units per year. Compared to the 610 units per year Bellingham averaged between 2000 and 2024 this is an increase of about 37% or 225 more homes per year. Also of critical importance, the Commerce housing allocation identifies that about 60% of these housing units or about 500 units per year should be affordable to households earning less than 80% of area median income. Accommodating more Growth in Bellingham to Meet Climate and Sustainability Goals Bellingham places a high priority on our response to climate change, protection of resource lands, and fiscal sustainability. Accommodating growth in compact urban areas close to jobs and services minimizes vehicle trips and related greenhouse gas emissions. It also preserves resource lands and makes the most efficient use of city services and infrastructure. To that end, the City has adopted urban village master plans, has revised multi -family zoning, accessory dwelling unit, and infill housing regulations, and has adopted and invested in implementation of multi -modal infrastructure plans. And Bellingham continues to work toward creative and innovative ways to support smart, sustainable development in the coming decades. Over the past 10 years the City has accommodated 44% of countywide population, 63% of employment, and 52% of housing growth. Unincorporated rural areas have accommodated 19% of population, 6% of employment, and 15% of housing growth. A 2025-2045 growth allocation that places a larger share of population and housing in Bellingham and less in rural areas is consistent with Bellingham's goals, the Countywide Planning Policies, and the Growth Management Act. As the only Tier 1 city north of Everett, Bellingham is the one Whatcom County jurisdiction subject to the middle -scale housing requirements of HB1110. These regulatory changes will unlock new housing capacity making it more likely that the City will accommodate a higher proportion of countywide growth than in past planning cycles. Comparing the City's preliminary growth proposal to the OFM Medium (most -likely) projection for 2045 would mean Bellingham would accommodate about 53% of countywide population growth. Preliminary Estimate of Growth Capacity Bellingham's preliminary estimate of growth capacity accounts for changes to residential zoning to comply with recent State housing legislation. Specifically, allowing middle -scale housing (including townhomes) in all residential zones and up to four homes per lot or a fifth or sixth if they are affordable. The analysis follows the steps outlined in the approved countywide Land Capacity Analysis Methodology. It accounts for critical areas and associated buffers, future infrastructure, infrastructure gaps, market factors, and the anticipated impact of landmark trees. Additional analysis steps unique to Bellingham estimate how much infill development on already developed lots is likely to occur during the 20-year planning period (ADUs and middle -scale housing). The analysis shows that with these anticipated zoning changes and current and funded infrastructure improvements, Bellingham has estimated capacity to accommodate about 17,185 housing units and 17,727 jobs by 2045. Residential Capacity Analysis Summary 1,980 single -detached units 5,045 middle -scale units (ADUs, townhomes, etc.) 9,160 multi -unit (7+ unit types) 1,000 group quarters units (7+ unit types) 17,185 Total housing units Comparing this estimated capacity to the preliminary proposal there is a capacity shortfall of about 1,200 housing units and 1,660 jobs. An analysis of potential additional zoning and UGA boundary changes shows capacity for an estimated 3,625 more housing units and 1,355 jobs by 2045. Enabling this capacity would require significant investment in a variety of infrastructure elements to provide opportunities for development. These potential changes are summarized below: NOTE — If the above -average 8% commercial vacancy rate in Bellingham's downtown area normalizes to the citywide average 3%, the capacity shortfall for future jobs is significantly less. Activate transit -oriented development (TOD) within walking distance of high -frequency transit routes by allowing additional density, height, floor area, or incentives to create opportunities for more housing and jobs. The City estimates that these changes could create capacity for up to 1,275 additional housing units split 1/3 middle -scale (townhomes etc.) and 2/3 multi -unit (7+ unit types), and up to 640 jobs in commercial development by 2045. The City's baseline capacity estimate already assumes close collaboration with Whatcom Transportation Authority to plan, fund, and build transit and pedestrian infrastructure elements. Adopting TOD land use changes would make these efforts even more critical for successfully accommodating growth. UGA boundary adjustments that bring either the North Bellingham UGA Reserve or South Yew Street UGA Reserve into Bellingham's UGA could add capacity for an estimated 400 to 1,600 housing units and 175 and 715 jobs by 2045. Development of 4 the North Bellingham UGA Reserve (about 1,200 housing units and 540 jobs by 2045) would require a new water reservoir on King Mountain, a new fire station (including building, equipment, and staff), and extension of arterial streets and other urban services. Development of the South Yew Street UGA Reserve (about 400 housing units and 175 jobs by 2045) would require a new water reservoir on Samish Hill, extension of arterial streets, sanitary sewer system improvements, a new fire station (including building, equipment, and staff), and extension of other urban services. The infrastructure investments to activate these areas would also provide additional development opportunities for adjacent areas already inside the City or UGA (areas with currently limited development capacity due to existing infrastructure gaps). It is estimated that these additional opportunities could provide capacity for up to 750 housing units by 2045. Housing Affordability Bellingham's high proportion of multi -unit housing capacity provides market rate options for households earning close to 80% of area median income (AMI). Providing deeper affordability to households earning 60% or less of AMI typically requires public subsidy. The combined $14M in annual funds from Bellingham's voter -approved housing levy, affordable housing sales tax, City general and REET funds, and federal funds are currently able to support production of about 130 subsidized rental housing units per year (as noted above, the need is much greater). Just as important as funding affordable housing is the need for qualified non-profit and government partner organizations to provide on -site case management and related human services. Addressing the funding and community partner resource gap between what is currently possible, and the communitywide need is a challenge best shared by all jurisdictions in Whatcom County. Next Steps There are unresolved questions associated with this proposal. When the Draft EIS impacts analysis becomes available in February, Bellingham will determine which zoning and boundary changes and infrastructure investments best address community housing and employment needs, balance environmental impacts, and are fiscally achievable and sustainable. Additionally, the preliminary proposals independently submitted by each jurisdiction represent a combined countywide growth 19% (10,723 people) higher than the OFM Medium (most -likely) projection for 2045. Bellingham supports further discussion with Whatcom County and the cities, working towards a strategy encouraging growth in UGAs and minimizing growth in rural areas that aligns more closely with the OFM Medium population projection. CITY OF BLAINE CITY MANAGER'S OFFICE 435 MARTIN STREET, STE. 2000 • BLAINE, WA • 98230 January 16, 2025 Whatcom County Council 311 Grand Avenue, Suite 105 Bellingham, WA 98225 Whatcom County Executive Satpal Sidhu 311 Grand Avenue, Suite 108 Bellingham, WA 98225 Director Mark Personius Whatcom County Planning & Development Services 5280 Northwest Drive Bellingham, WA 98226 Re: Supplement to the Cite of Blaine's UG_A growth pmosal submission to Whatcom Counf The City of Blaine urges Whatcom County to move expeditiously forward with its required Comprehensive Plan update process without delay. Further, the City urges the Whatcom County Council to support this effort and Blaine's corresponding work by adopting a non -binding multi - jurisdictional resolution relating to preliminary growth projections. The City also requests that the County recognize, support, and incorporate into its Comprehensive Plan the City's proposed Urban Growth Area ("T TGA") Swap (described below and ir, the City's October 31, 2024 submission) that provides an opportunity for more appropriate and efficient urban growth aligned with urban services. 1. Delaying the adoption of a non -binding resolution will unnecessarily delay the City's Comprehensive Plan update and related processes. Blaine has been proceeding with its Comprehensive Plan update and related processes, including its Water System Plan update, based on the understanding, as represented by the County, that the County Council would vote on a non -binding multi -jurisdictional resolution relating to the preliminary growth projections in late 2024 or early 2025. This is the drueframe provided to us by the County. This type of preliminary resolution was used in the 2013-2014 update to provide a starting point for jurisdictions to commence the development of land use planning proposals and PHONE: (360) 332-8311 FAX: (360) 332-9562 draft capital facility plans. In short, timely adoption of the non -binding resolution is a critical tool that has worked in the past and is needed to keep the planning process on track. Delay in adopting the non -binding resolution materially jeopardizes the City's ability to (i) meet the December 31, 2025, statutory deadline to update its own Comprehensive Plan; (ii) maintain grant funding it has received for its update; (iii) plan for and consider a de-annexation/UGA Swap proposal; and (iv) plan for its submissions in the ongoing water rights adjudication. Blaine will continue to endeavor to meet the December 31, 2025 deadline, despite County delays, to ensure that its grant funding is not put at risk and to ensure compliance with its obligations under the Growth Management Act. To that end, the Blaine City Council adopted a medium -high population growth projection of 3,500 and a high employment growth projection of 1,092 jobs for the Blaine UGA over the 2023-2045 planning period. Unfortunately, it has come to the City of Blaine's attention that the County may be considering delay in adopting the coordinated preliminary growth projections in a non -binding resolution. Blaine strongly encourages the County Council not to delay the adoption of the non -binding resolution and to act, if not immediately, sooner rather than later. A delay in the process will also impact Blaine's current work to explore a de-annexation/UGA Swap alternative and could prejudice Blaine's ability to ensure that its Comprehensive Water System Plan is updated in anticipation of the upcoming Water Resource Inventory Area 1 (Nooksack) water rights adjudication. As noted above, the non -binding resolution is just that —non -binding. It provides a preliminary point of departure for the jurisdictions of Whatcom County to continue their respective growth planning processes in compliance with the Growth Management Act. There is simply no reason to delay the adoption of this resolution. 2. Blaine is exploring a UGA Swap to promote the development of various housing types and prices and to encourage the development or expansion of businesses that will provide employment opportunities, among other goals. — We mention this briefly here to supplement Blaine's prior submission to the County and to emphasize the need to avoid delay in the process. The UGA Swap alternative is summarized as follows: • De -annexation of approximately 552 acres of east Blaine • Removal of approximately 37 acres of unincorporated UGA near the mouth of Dakota Creek • The addition of 124 acres of UGA near Harvey Road • The addition of 460 aces of UGA west of Semiahmoo • A new UGA reserve in two areas totaling approximately 299 acres west of Semiahmoo 2 PHONE: (360) 332-8311 FAX: (360) 332-9562 Multiple factors indicate that this alternative UGA boundary should be strongly considered. The County and the City must consider adjustments to Blaine's UGA to effectuate this alternative. This UGA Swap alternative should be in the Environmental Impact Statement ("EIS") being developed for the County's Comprehensive Plan update. The de -annexation process will require additional processes on the part of Blaine and its residents, including considering reducing Blaine's city limits by a vote of the people. This adds complexity to Blaine's planning effort, making timely consideration of the non -binding resolution paramount. This UGA Swap alternative would initially appear to address several planning goals shared with the County and the cities within the County, including the goal to encourage growth in UGAs. We look forward to coordinating with Whatcom County in the ongoing periodic update and request the timely adoption of the proposed non -binding resolution regarding growth projections. Sincerely,/ Michael L. Harmon City Manager 3 PHONE: (360) 332-8311 FAX: (360) 332-9562 e�city e of n CITY OF EVERSON PLANNING DEPARTMENT Alex Putnam, City Planner MEMO DATE: January 10, 2025 TO: Whatcom County Council Committee of the Whole FROM: Alex Putnam, City Planner RE: Everson Growth Proposal The City of Everson proposes a projection allocation of 1,408 people for the 22-year periodic update planning period. This allocation is the same as the Leland Consulting Technical Report high. Everson has developed this allocation proposal through the collaboration of elected officials and city staff. A population allocation of 1,408 people is the appropriate proposal for Everson for several reasons. According to numbers presented in the Leland Consulting Report, between 2013 and 2023, Everson had a growth rate of 1.7%. The high allocation of 1,408 people from 2023 to 2045 would equal an annual growth rate of 1.7%, consistent with the past growth rate. In more recent years, 2016 to 2024, Everson has increased by 535 people, a 2.7% growth rate across 7 years. In addition to using past trends to develop our proposal, city staff has also compiled a list of completed (post-April-2023), pending, and preliminary development projects in the city. This list is presented in Figure 1 below. Please note that this list does not include proposed or completed (post- April-2023) ADUs. Based on known completed or upcoming projects, Everson expects an additional 505 units in the first 10 years of the planning period. Using Everson's average household size of 2.88, this equates to about 1,454 people, exceeding our proposed allocation. Of these 505 units, 58 units have either completed construction post April 2023 or are nearing completion within the next year. This is an increase of roughly 167 people in 2 years. Figure 1. Proposed, Pending, and Completed Projects in Everson, WA Project Name Proposed # of Additional Units Status Beverly Estates LP 15 Complete Hougens Landing LP 73 Preliminary Approval Everson Meadows LP 4 Preliminary Approval Robinson Townhomes SP 1 Preliminary Approval Blankers Crossing LP 57 Preliminary Approval DeHoog Property 80 Pre -Application Emerson Rd Property 12 Pre -Application Greenes Ln LP 42 Pre -Application Tjoekler Property 15 Pre -Application Beld Property 92 Pre -Application Hawks Landing LP 21 Preliminary Approval Mateo Meadows 38 Preliminary Approval Fieldview Terrace 15 Pre -Application Younkin SP 3 Pending Approval Mi SP 5 Pre -Construction Vermeulen SP 3 Pre -Construction Kelto Holdings SP 11 Complete Colton Ln Duplexes 16 Complete Baker St Duplex 2 Complete While the land capacity analysis has not been finalized for Everson, it is anticipated that there will be a modest deficit in residential capacity. To accommodate this projected deficit, Everson anticipates taking additional action to increase residential densities and altering current UGA boundaries to replace undevelopable, agricultural UGA land with developable UGA land outside of the floodplain. The direction of future development in Everson is west of the river, which contains no current or future floodplains. Based on the evidence provided in the Leland Technical Report, population trends from Office of Financial Management, and city projections, Everson anticipates a significant population increase in the next 10 years. To accommodate this projected increase, the technical report high population allocation would be most appropriate for city planning efforts related to capital facilities, transportation, and land use. p fER,Oy Office of the Mayor January 3, 2025 Whatcom County Council Members, Subject: 2025 Comprehensive Plan Periodic Review: Growth in Whatcom County Council Members, Please accept this letter as a summary of the City of Ferndale's position on growth within Whatcom County for your consideration during the 2025 Comprehensive Plan Periodic Review Process. We wanted to take a moment to communicate our desires, concerns, and recommendations for our community and the future of our region. Population Growth and Housing Allocation: The City of Ferndale respectfully requests that you approve our proposed population projection and housing growth allocation so that we may plan for growth. This proposal was reviewed by our Planning Commission, and approved unanimously by our City Council prior to forwarding it to the County for acceptance. The City is planning for the Technical Report Adjusted High: • Population Projection: 10,961 people • Employment Projection: 3,337 jobs The City believes that proactively planning for growth is the appropriate course to take for several reasons. The Office of Financial Management (OFM) provides a range of population growth projections; high, medium, and low. There has been continued emphasis on using the medium, citing that this is the growth that is most likely to occur. The County had their consultant revise the population range, which resulted in a lower high and a higher low projection, effectively narrowing the range of the OFM estimates. Given the growth that the region has experienced since the Growth Management Act (GMA) was adopted, Ferndale believes it is prudent to plan for the adjusted high growth for our community, which is still below the OFM High projection. Following OFM's guidance in the past has not resulted in an adequate housing supply to meet the region's need, we believe continuing to do so will likely result in the same outcome. Planning for growth does not result in sprawl, rather we believe that planning for growth results in the ability to accommodate growth and ensures that infrastructure is accurately designed. The City has very specific goals and policies within our comprehensive plan and regulations within our code to inhibit leapfrog development and ensure the development of land after the extension of services. We have an Annexation Blueprint, a component of our P.O. Box 936 1 2095 Main Street, Ferndale, WA 98248 1 (360) 685-2350 1 greghansen@cityofferndale.org comprehensive plan, that sets timelines and conditions for annexation of land into the City. Ferndale's policies and actions reflect a commitment to infill development. By embracing minimum densities, allowing infill, and rezoning portions of the existing city limits to allow mixed use and denser development, it has allowed us to grow over the past 15 years without the need for expansion of our Urban Growth Area (UGA). We have heard several comments and responses suggesting that the timeline for completion of the comprehensive plan does not need to be adhered to, noting that the State will not do anything if we do not meet these timelines. The reality is that the timeline is also connected to grant funding that has been provided by the State, which is set and unlikely to change. If the County and cities do not meet the timelines and deliverables specified within the grants, we likely will not receive all of our funding. Many of the cities relied upon the deliverables and timelines identified by the County for our grants. The cities are also obligated to pay the County to support the regional comprehensive plan work. While we understand there is frustration at the County level concerning how staff have coordinated their work with the County Council, your actions can negatively impact all of the communities within the County. We have also read responses and heard comments regarding when population projections are needed and when housing allocations are needed to support our work. All of the other counties that have completed this work ahead of us, or are in our same review cycle, have completed this work well ahead of Whatcom County. While Ferndale does not shy away from taking different approaches, this is not the situation where we believe that we want to be the outlier, especially when it is apparent that the County elected officials do not appear to be well coordinated with their staff. If you are not going to approve our request, please tell us why and provide us with guidance on how we should go about planning for growth. There was a lot of discussion about the cities' proposed growth projections at the Whatcom County Planning Commission, but little to no discussion about the proposed growth within the UGAs the County oversees and the rural areas outside of the UGAs. The proposals you received from the cities appear to be coordinated with their respective officials and represent each community's request. It appears this type of coordination has not occurred at the County level for your UGAs and the Rural Areas, we believe it would be prudent for you to work with your staff to address your UGAs and the Rural Areas. There are two comments within the record from the last county planning commission meeting from the development community (Jones Engineering) and the Whatcom Environmental Council, which we suggest you look at where these two letters overlap and consider changes to County policies and goals where there is agreement. While we do not agree with everything in each of these letters, we do agree with components from both, especially where the recommendations from the two groups are consistent. Concerns and Recommendations Regarding Growth: The City believes continuing to manage growth as we have historically is not appropriate. It is time to make changes to ensure we are planning for and accommodating the growth we need 2 to thrive, the growth that is needed to address our housing crisis, and the job growth that will support our residents. Now is the time for the County to revisit growth in the rural areas outside of the UGAs. Over the last 10 years the rural areas have added the second most amount of growth (nearly 19%), behind only Bellingham and ahead of Ferndale (12.8%). This means almost 1 out 5 new homes are not being built within a UGA. Now would be the appropriate time for County elected officials to weigh in before the DRAFT Environmental Impact Statement is completed. This would allow the needed units to then be distributed to the UGAs before each jurisdiction begins their detailed land capacity analysis. The City of Ferndale is concerned with how land in the UGA, UGA Reserve, and adjacent to our City is managed. We believe acting on our concerns can reduce the cost of developing these lands and make the annexation process easier. Addressing these concerns can assist other communities as well. Our preference is for the County to manage these areas to retain large tracts of land that can more easily be urbanized after annexation. The City of Ferndale raised many of these issues with County staff when we were negotiating the Interlocal Agreement regarding the annexation and management of the UGA in 2021. It was communicated at that time that these requests were "non-starters." The City strongly believes that these concerns should be addressed within the next twelve months, and is working with several other jurisdictions to mandate these changes statewide. Rather than disengaging with these planning efforts, the County should embrace the obligations to show leadership, not only in the region, but statewide. Manage Growth in Unincorporated Areas: Growth has not been managed well, specifically as it relates to UGAs and UGA Reserves, and we urge you to make significant modifications to County policies and regulations by December 31, 2025. In order to manage the unincorporated UGA, UGA Reserve, and Rural Areas to retain large tracts of land, the County may want to revisit the goals and policies within the comprehensive plan and the standards within the development code. This would include precluding the establishment of new uses, restricting further land division, and downzoning properties to prevent further parcelization. The existing cluster land division approach should also be revisited. While the cluster land division approach appears consistent with retaining large tracts of land for future urbanization, it often reserves the worst possible areas for future development, as well as preventing logical ingress/egress to a site. Permitting development dependent on septic systems and wells complicates the ability to urbanize these areas when they are annexed. The more development and investment in these areas, the more difficulty there is in the annexation and development process. The City requests that Whatcom County establish an immediate development moratorium on all projects within the unincorporated UGAs and UGA Reserves for both residential and employment properties, and that this moratorium not be lifted until new policies to ensure management of the UGAs is established. 3 Designated Agricultural Land: The County is in the process of examining how and where new agricultural land can be designated in the comprehensive plan. We understand two of these potential areas are located to the east and west of the City of Ferndale's UGA. We support this project overall as we are tremendously supportive of preserving agricultural and forestry land within the County. We do believe it is appropriate to make sure that we do not create a situation where we box in Ferndale (or another community), similar to what has occurred in Sumas. The County should be deliberate in designating any new agricultural lands within the comprehensive plan to ensure the long-term viability of those lands. This means providing adequate space for communities to continue to grow beyond the 20-year planning horizon of the comprehensive plan. Urban Growth Reserve Areas: The City of Ferndale strongly supports the establishment and management of Urban Growth Area Reserves. Just like a UGA, these areas should be studied and managed to ensure adequate land is preserved to support the growth of our communities in a rational and efficient way. Just like a UGA, these areas should be protected to maintain large tracts of lands. We support the establishment of a minimum 20-year planning horizon for these areas, resulting in land identified to meet an individual community's 40-year needs. At present, the cities have reserves; however, there is no methodology established to guide the ongoing management of these areas. There is no understanding of what the capacity is in these areas. The Purpose of the UGA and UGA Reserve: City staff continue to hear from County staff that UGAs are intended to support more development, and that it is appropriate to permit growth in the unincorporated UGA (outside of City Limits) based on the GMA. We strongly disagree with this concept. We believe that the County is failing to understand the purpose of the GMA and long-range planning, and we believe that these different perspectives highlight the City's strong belief that County policies and development regulations must be changed. We do agree that growth should be directed to UGAs, but not until services are provided and development standards are in place to support the development of these areas. These areas should be protected until services can be provided and urbanized efficiently. Failing to protect these areas will result in increased development, parcelization, and investment that will ultimately increase the cost to urbanize these areas in the future. Impact Fees: Who Pays for Growth? We believe that to the extent it can, new growth should pay for their impact to our infrastructure. We believe the County should demonstrate more leadership in this area. We support the collection of impact fees, and we would like to see the County take a more active role in the collection of City and Special District Impact Fees. We also believe it is prudent for the County to collect impact fees for transportation, which would reduce the amount of tax existing residents pay. Not collecting impacts fees for transportation results in the County being more reliant on taxes and grants to fund improvements. Please consider shifting the burden for funding transportation improvements away from existing residents to proposed development. 4 At present, the City of Ferndale collects impact fees on behalf of the Ferndale School District. These fees are not collected by new development that occurs in the County, resulting in residents of the City shouldering more of the burden for new facilities, as well as higher property taxes for the general public, as the general public has been required to subsidize County general fund expenditures, rather than development associated with growth in Whatcom County. There is currently a policy in the County's comprehensive plan regarding impact fees. We would like to see the County take a more active role in implementing this policy. Alternatively, if the County wants to continue to permit growth within the UGA and UGA Reserve, you should establish street standards specific to the UGA that include provisions for pedestrian bicycle facilities, requirements for internal infrastructure to be stubbed out to facilitate future connections to City services, and similar methods. Please do not hesitate to reach out to me, or City staff, if you would like to discuss anything in more detail. We look forward to discussing these concepts, as well as working with all of you as part of the 2025 Compr ensive Plan Update to make Whatcom County the best region to live, work, and play. Sin Gig Hans Mayo ity oT ndate GreeHansenCcirndale.o 360.685.2350 5 CITY OF LYNDEN ADMINISTRATION DEPARTMENT Scott Korthuis, Mayor January 10, 2025 RE: 2025 Comprehensive Plan Periodic Review — Population Projections Whatcom County Council Members, The City of Lynden is asking the Whatcom County Council to approve the proposed population projection and housing growth allocation developed by the Planners Group. Over the last few months, the Planning staff from each city and the County have been working diligently to reach out to their respective communities, manage grant funding, and coordinate with their legislative bodies and consultant teams while responding to the expectations of the State and the Growth Management Act in order to complete the 2025 Comprehensive Plan Periodic Review. One key aspect of this work has been solidifying a population projection for the County and its jurisdictions. The projection, as you know, is a critical planning guide that is needed to gauge the potential for transportation and infrastructure impacts. We do not embrace the notion that planning for growth causes sprawl. The City of Lynden appreciates the cooperative process that our Planners Group and legislators have used to determine the proposed population allocations while other counties have simply assigned allocations to their jurisdictions. Whatcom County is a good example of why city -specific allocations are warranted. Some cities like Nooksack and Everson are poised for significant near future growth that would quickly exceed the medium 20-year projection that some groups are suggesting be applied to all cities. Alternatively, in Lynden we have reached a point where residential growth is slowing. This throttle on growth, we know, is not from lack of demand but is due to the complexity and costs of development on those properties queued for the next phases of growth. We want to be sure that the Council understands that this review has been an iterative process that included our analyst from Leland Consultants and the City Council's Committee for Community Development. Lynden's initial review of population projection considered the Technical Report Adjusted High but after additional review of the City's growth capacity and even the capacity with density increases it was obvious that a more realistic projection was the Technical Report Medium projection. The Whatcom Environmental Council submitted an alternative population projection that does not benefit from the detailed analysis that each city has conducted. While the input from the Environmental Council is appropriate and valuable, it would be short-sighted to prioritize their conclusions over the informed and detailed work that has gone into the proposal brought forward by the Planners Group. 300 41h Street, Lynden, WA 98264 www.lyndenwa.org CITY OF LYNDEN ADMINISTRATION DEPARTMENT Scott Korthuis, Mayor Lynden shares concerns with the Whatcom Environmental Council and other cities that the regulations and lack of impact fees in unincorporated Whatcom County disincentivize growth and construction within urban boundaries. We strongly support the goal of preserving agricultural and forestry land within the County but with the foresight to know that each jurisdiction will continue to grow over time. Even if UGA expansion is not needed in the next 20 years, it will be needed in the long term. Whatcom County may be in the difficult position of modifying zoning and development standards to reduce growth outside of city boundaries. There are many developable lots within the County and selecting a reduced population projection will not prevent the development of these properties. However, one theme consistently rises to the top among Planners, the Whatcom Environmental Council, and our legislators and that is the preservation of rural lands. We urge you to consider your role in the County's continued growth and development but to support the work already done by the Planners Group by approving the Planners Group population projections which will allow us to continue to successfully produce deliverables to our communities and the State and utilize the grant funds we were awarded. Sincerely, Scott Korthuis, Mayor City of Lynden 300 4h Street, Lynden, WA 98264 www.lyndenwa.org CITY OF &C1111K N00 MEMORANDUM DATE: January 10, 2025 TO: Whatcom County Council, Committee of the Whole FROM: Holly G. Hamilton, Hamilton Planning + Design Rollin Harper, Sehome Planning and Development Services RE: City of Nooksack UGA Growth Proposal The City of Nooksack's UGA Growth Proposal as a collaboration between City Council and Planning Staff at the close of October 2024, notes the following regarding our long-range analysis for the Comprehensive Plan Update 2025-2045: POPULATION GROWTH ■ Nooksack recognizes Whatcom County Planning Commission's concern for growth which exceeds the County Consultants' Medium Growth Share. ■ Current housing production in Nooksack (2023 through 2026, 4 years) i.e. developments built, approved and / or under construction, following a period of relatively slower growth is 126 housing units. ■ Growth over this initial four-year period is equal to the County Consultants' Medium Growth Allocation for 2023-2045. ■ At the start of 2025, 47 units remain to be constructed (less than half). ■ In 2027, Nooksack's annual forecast growth is 15 new units through 2030, reduced to 12 through 2040, then 10 units for the remainder of the planning period. ■ The approved forecast anticipates a slowing of growth over the planning period and is consistent with OFM's Planning Forecasts. NOOKSACK POPULATION GROWTH Current and Forecast Based on 2.88 Peaple pet OU (2023 2045) 'CenwsIACSSYR Estimates) NOOKSACK EFF APR 01 YEAR WA OEM POPto EST POP %ANNUAL HOUSING UNRS FORECAST OVPLT CP Update 2023 GROWTH GROWTH GROWTH YEAR 2010 1,338 457 2011 464 2012 443 2013 481 2014 489 2015 1.405 498 2016 505 2017 514 2018 520 2019 539 2020 1.471 44 2.99% 510 2021 1,515 45 2.97% 531 2022 1.560 13 0.93% 590 2023 1,573 111 7.06% Ei47 31 2024 1,684 121 7.18% 584 42 OVILPT1 2025 1,805 69 3.83% 126 24 OVLPT2 1 2026 1,874 66 3.53% 650 23 DVLP72 2 2027 1,940 43 2.23% 673 15 Est. 3 2028 1,984 43 2.18% 688 15 Est. 4 2029 2,027 43 2.13% 703 15 Est 5 2030 1.0]0 43 2.091* 711 15 Esc 6 2031 2,113 35 1.64% 733 12 Est 7 2032 2.148 35 1.61% 741 12 Es, 8 2033 2, 282 35 1.58% 757 12 Est. 9 2034 2.217 35 2.56% 769 12 Est. 10 2035 2.251 35 1.54% 781 12 Est 11 2036 2.286 35 1.51% 793 12 Est. 12 2037 2,320 35 1.49% 805 12 Est 13 2038 2.355 35 1.47% 817 12 Est. 14 2039 2,390 35 1.45% 829 12 Est. 15 2040 2.424 29 2.19% 841 10 Est. 16 2041 2,453 29 1.17% 851 30 Est 1] 2042 2.482 29 1.16% 861 10 Est. 18 2043 2,511 29 1.15% 871 30 Est 19 2044 2,539 29 1.1341 881 10 Est. 20 2045 2,568 891 Est. NETGROWIH 20232045 -5 63.27% 3" 3" ial,il Pu�ulnTiun %Pap. G-h Ptaleclsd OU z Increase Increase EMPLOYMENT GROWTH ■ Employment growth allocation for the City of Nooksack is recommended at 232 positions. ■ Growth allocation for employment is above the Consultant's HIGH projection and is consistent with the city's population growth forecast. ■ This number is intended to address the shortfall in Small Business/Light Industrial employment to meet the needs of the region, to improve local business / community services and to reduce vehicle miles travelled (VMT) along the Highway 5 corridor. Please see the City's UGA Growth proposal, dated November 141", 2025 for additional information. Please contact Nooksack City Planners for additional information. CITY J CITY OF SUMAS 433 Cherry Street/PO Box 9, Sumas, WA 98295 P: (360) 988-5711 F: (360) 988-8855 Memo To: Whatcom County Council of the Whole Committee From: Carson Cortez, City Planner, City of Sumas Date: January 7, 2024 Re: Response to Comments on City Growth Proposal On November 14 and December 12, 2024, Whatcom County Planning and Development Services, along with planners representing each of the 7 cities, met with the Whatcom County Planning Commission to discuss a potential non -binding multi -jurisdictional resolution identifying a proposed growth projection for the next 20 years, agreed upon by all jurisdictions. Both written comments received prior to the meetings, as well as spoken comments received during the meetings showed hesitation towards the adoption of a non -binding multi -jurisdictional resolution, and some comments were made about certain jurisdiction's growth proposals. This memo will serve to allow the City of Sumas the opportunity to address those comments and provide the Whatcom County Council of the Whole Committee with some insight into Sumas' growth proposal. Flood Risk A recurring comment regarding Sumas was a question of why population growth should be directed to a place that sees frequent flooding. The City of Sumas is aware of the concerns about putting growth in a place that has seen recent severe damage from flooding, and we are taking steps to direct growth to areas of town that are less frequently flooded. The problem remains that a majority of Sumas exists in the direct path of floodwater, so finding places to direct growth where damage can be mitigated is a challenge. The priority step that the City of Sumas is willing to take is to expand the Sumas UGA to the west of town. That area rises in elevation to the point where all new developments would be safe from floodwater. The challenge with expanding Sumas in this direction is that the area immediately west of town is still in the FEMA-regulated 100-year floodplain. Under State law, jurisdictions are not normally allowed to expand their UGA into floodplain without putting covenants on the land, restricting their development rights. This area within the floodplain is used primarily for agricultural purposes and wellhead protection around the City wellfield, so restricting development rights shouldn't be much of a concern. The other challenge with this action is that all areas around the Sumas UGA are zoned agriculture. This means that, in order to expand the Sumas UGA in any direction, the land would have to be de -designated as resource land. This would decrease the number of agricultural lands, while the County is making steps to improve the amount of agricultural land available. Sumas' argument for de -designating the land to the west is that while the lower -lying areas of are used for agriculture, the more elevated areas farther west are not used in the same manner. Their use is primarily as large -lot residential properties and would more accurately reflect a R- 5A or R-10A zoning. To de -designate this land would not take away as much useful agricultural land as the zoning would make it seem. Whatcom County's support in resolving these matters would help Sumas create capacity for new growth and in a direction that minimizes the risk that these new homes would have to face from flood damage. City Council and Planning Commission Participation There were comments made during the December 12, 2024 Whatcom County Planning Commission meeting about the level of participation that local decision -makers had in the generation of these population growth proposals. The City of Sumas can confirm that both the Sumas Planning Commission and the City Council were a part of generating the proposal. Discussions with both groups were held before the proposal was sent to Whatcom County for consideration. Comprehensive Plan Timeline As stated above, there was significant hesitation from the majority of the Planning Commission towards adoption of a non -binding multi -jurisdictional resolution. The City of Sumas understands that the Planning Commission felt that the proposals listed in the resolution feel rushed and not coordinated with the subsequent environmental review. The City also understands that the Planning Commission would like more time to review the materials before making a final recommendation to the County Council. However, due to delays in the release of State grant funds, the timeline to complete the City and County comprehensive plans by the State's deadline of December 31, 2025 has been significantly shortened, so we need to begin moving forward now. The main benefit of having a non -binding multi -jurisdictional resolution approved by all the jurisdictions is that it makes official the understanding between the jurisdictions about what each other's population and growth projections will be. This helps to conform to the State's requirement that all comprehensive plans within a county be coordinated and consistent with one another. By taking this step of agreeing to region -wide population and employment growth projections, the County is also giving the authors of the various comprehensive plans the green light to begin making significant steps in the drafting of the plans, a majority of which is largely based on the projected growth that the jurisdiction expects to receive during the 20-year planning horizon. Approving the resolution will give all the jurisdictions the freedom to draft the rest of their comprehensive plans in time to begin the review and approval process in the later half of this year so that they can be approved and made official in time for the December 31 deadline. The City of Sumas and the other jurisdictions need the County Council to approve this proposal as soon as possible so that all the jurisdictions can reach this deadline. 2 Schedule of Presentations February 4 (9:00 a.m.) Special Committee of the Whole • Bellingham • Birch Bay • Cherry Point • Columbia Valley February 11 (Committee of the Whole, time TBDJ • Blaine • Everson • Ferndale • Lynden • Nooksack • Sumas WHATCOM COUNTY Planning &Development Services 5280 Northwest Drive Bellingham, WA 98226 W A S H I N T N PDS@co.whatcom.wa.us 360-778-5900 January 28, 2025 TO: The Honorable Whatcom County Council FROM: Matt Aamot, Senior Planner THROUGH: Mark Personius, Director RE: 2025 Comp Plan Update - Preliminary Population and Employment Projections / City and County Presentations in February The Growth Management Act (GMA) requires Whatcom County and the cities to review and revise our respective comprehensive plans and development regulations by December 31, 2025 (RCW 36.70A.130). Additionally, the GMA requires review of urban growth areas (UGAs) under RCW 36.70A.130(3). The UGAs must have sufficient areas and densities to accommodate population, housing and employment growth projected for the new planning period (2023 - 2045). The GMA also requires that County and City Comprehensive Plans, including population and employment growth projections, must be coordinated and consistent (RCW 36.70A.100). Therefore, Whatcom County has initiated a Comprehensive Plan and development regulations update. The Comprehensive Plan update, which includes the UGA review, is being conducted in close coordination with the seven cities in Whatcom County. The Cities and County will make presentations relating to their proposals for population and employment growth at the County Council's February 4 and 11 meetings. Ultimately, we are seeking direction from the Council on the preliminary population and employment growth projections for a "Non -Binding Multi -Jurisdictional Resolution." A "Non -Binding Multi -Jurisdictional Resolution" relating to population and employment growth allocations was approved in 2016 Comp Plan update process (Resolution 2014-013). We are asking the County Council to consider a similar resolution in the 2025 Comprehensive Plan update process. The seven city councils would consider similar resolutions. The Non -Binding Resolutions would facilitate coordination between the County and cities relating to issues such as housing allocations, capital facility planning, and UGA planning as required by the GMA. Final growth projections would ultimately be adopted by the County Council in the 2025 Comprehensive Plan. The preliminary growth proposals presented by the cities and the County at the November 14 Planning Commission meeting are summarized below, along with notes indicating how these proposals relate to the Technical Report's low, middle and high projections. 1 Table 1. Population Growth Proposals Area Bellingham UGA Tech Report Low 16,242 Tech Report Middle 24,158 Tech Report High 36,462 City & County Proposals 30,310 Percent of Total Growth 44.8% City and County Proposals in Relation to Tech Report Between Middle and High Birch Bay UGA 1,555 2,313 3,490 2,662 3.9% Between Middle and High Blaine UGA 1,865 2,774 4,186 3,500 5.2% Between Middle and High Cherry Point UGA 0 0 0 0 0.00/0 N/A Columbia Valley UGA 665 988 1,492 1,137 1.7% Between Middle and High Everson UGA 627 933 1,408 1,408 2.1% High Ferndale UGA 4,883 7,262 10,961 10,961 16.2% High Lynden UGA 4,481 6,665 10,060 6,665 9.90/0 Middle Nooksack UGA 237 352 531 995 1.50/0 Above High Sumas UGA 468 697 1,052 1,000 1.50/0 Between Middle and High Rural/Resource Lands 7,243 10,773 16,260 9,000 13.3% Between Low and Middle (Outside UGAs) TOTAL 38,266 56,915 85,902 67,638 100.0% Note: Cherry Point is an industrial UGA and does not have a population allocation. Table 2. Employment Growth Proposals Area Bellingham UGA Tech Report Low 9,719 Tech Report Middle 15,172 Tech Report High 23,642 City & County Proposals 19,384 Percent of Total Growth 59.9% City and County Proposals in Relation to Tech Report Between Middle and High Birch Bay UGA 80 124 194 450 1.4% Above High Blaine UGA 449 701 1,092 1,092 3.4% High Cherry Point UGA 316 493 769 1200 3.7% Above High Columbia Valley UGA 9 13 21 350 1.10/0 Avove High Everson UGA 130 203 317 602 1.90/0 Above High Ferndale UGA 1,372 2,141 3,337 3,337 10.3% High Lynden UGA 1,152 1,799 2,803 1,799 5.6% Middle Nooksack UGA 51 79 124 232 0.7% Above High Sumas UGA 96 150 233 Soo 1.50/0 Above High Rural/Resource Lands 2,180 3,403 5,302 3,403 10.50/0 Middle (Outside UGAs) TOTAL 15,554 24,278 37,834 32,349 100.00/0 2 The Cities and County will present their respective UGA growth proposals to Council on February 4 and 11 to explain the rationale for these proposals and to discuss any questions that Council may have relating to the proposals. The intent is to facilitate County and city plans that are coordinated and consistent as required by the GMA (RCW 36.70A.100). Thank you for your consideration of this matter. We look forward to discussing it with you. 3 Bellingham UGA Preliminary Growth Proposal February 4, 2025 1 Adding and investing in land Since the UGA was established in 1995, Bellingham has approved 22 annexations (averaging one every 1-2 years). These areas total over 3,300 acres, and today accommodate more than 4,350 homes, about 9,000 residents, and 8,000 jobs. The City has invested more than $150 million dollars in transportation, utilities, parks, and trail infrastructure, and expansion of public safety and other urban services to these areas. d Gity Limits Urban Growth Areas \� UGA Annexed Since 1995 ® UGA Reserve Areas City of Bellingham Urban Growth Area ns� Miles 9 0.5 1 2 Adding Capacity In recent years Bellingham has approved urban village master plans, multi -family and commercial zoning code updates, Infill Toolkit, and accessory dwelling unit (ADU) regulations. All of these actions have added capacity for thousands of new homes in areas where additional development was not previously allowed. Urban villages alone have accommodated about 1/3 of all new development in Bellingham since 2006. Mayor's Executive Order on Housing 11/1/2024 • Removed parking minimums 1/13/2025 • More actions to follow Ferndale Wfinghom Bay Key CO aty Lin-& ■ Info TodO Projects Urban Vitloges Multi Famly Zoring . cornrnercid zonhg ADUs City of Bellingham ■ IL • [nkr �,� • • � . W�rofc o7rn � r .• R A •. .•tip wwu Un i • A Foirha v • Pu�ne- Geneva HN' rZ� Miles 0 0.5 1 3 Addressing the Housing Crisis Bellingham leverages funds from the voter - approved Housing Levy, the Affordable Housing Sales Tax, Real Estate Excise Tax, General Fund, and federal funds. For 2023 these funds totaled about $14 million and were used in partnership with community non -profits to build or preserve 333 affordable housing units, and provide related human services aimed at prevention, crisis response and stability. To -date, more than 1,700 affordable housing units have been built or preserved. Despite these investments, community needs still exceed available resources. ORecent Projects • Other Projects How this Funding is Spent Housing Preservation 4% Admin & Contingency 3% r Accommodating Growth The 2016 Comprehensive Plan allocated Bellingham annual growth of about 1,350 people per year. 2016 to 2024 Bellingham averaged growth of 1,446 people per year or about 7% more than anticipated. 14,000 12,000 Bellingham UGA Allocated & Actual Population Growth Allocated Growth Actual Growth 10,000 8,000 6,000 3,619 4,000 1,836 2,000 1,350 ,r. 6 5,810 ,75D 11,568 10,267 10,800 8,192 9,450 8,100 5,400 1111�— 4,141 4,050 WWU Students moved home 2,700 during COVID-19 C}uarantine. 20-16 2017 2018 2019 2020 2021 2022 2023 2024 Sources - Whatcom county 2016 Comprehensive Pfau & Washington State Office of Financial Management 5 Bellingham accommodated more than half of housing built in Whatcom County since 2016 (5,771 out of 11,157 homes). Bellingham also accommodates about 62.5% of countywide employment (about 70,400 out of 1125600 jobs). Employment data from Whatcom County Comprehensive Plan — Population and Employment: Growth Projections and Preliminary Allocations Technical Report. Prepared by Leland Consulting Group May 7, 2024. New Housing Built 2016-2024 by UGA Rural Areas 15.2% Sumas 1.7% Nooksack 0.9% Lynden 10.2% Ferndale 9.5% Everson 1.3% Columbia Valley 1.7% Blaine 5.1%' ' Birch Bay 2.6% WA State OFM Small Area Estimates Program WA State OFM April 1st Housing Estimates Program �9 Bellingham.Prelimin Population Growth Proposal UGA Population Allocation Proposal (2023-2045) 1 Phase I —Technical Report Medium Growth Allocation (people) 241158 2 Phase I —Technical Report Adjusted High Growth Allocation (people) 361462 3 Phase II — Preliminary City Proposal (people) 30,310 4 Difference between 1 and 3 6,152 5 Comments: The City of Bellingham Planning Commission and City Council Planning Committee recommend use of a population allocation mid -way between the Technical Report Medium (OFM) and Adjusted High growth projection as the starting point for the update to the City's Comprehensive Plan. 7 Bellingham.Prelimin Employment Growth Proposal UGA Employment Allocation Proposal (2023-2045) 1 Phase I —Technical Report Medium Growth Allocation (jobs) 151172 2 Phase I —Technical Report Adjusted High Growth Allocation (jobs) 23,642 3 Phase II — Preliminary City Proposal (jobs) 191384 4 Difference between 1 and 3 4,212 5 Comments: The City of Bellingham Planning Commission and City Council Planning Committee recommend use of an employment allocation mid -way between the Technical Report Medium (GFM) and Adjusted High growth projection as the starting point for the update to the City's Comprehensive Plan. Fool Bellingham.Prelimin Residential Capacity Preliminary Residential Land Capacity Analysis (2023-2045) 1 Estimated Population Growth Capacity of existing UGA (people) 251270 2 Population Growth Allocation Proposed (people) 301310 3 Estimated Housing Growth Capacity of existing UGA (housing units) 141370 4 Housing Growth Allocation Proposed (housing units) 181443 5 Difference between 1 and 2 (people) (51040) 5 Difference between 3 and 4 (housing units) (41073) 7 Comments: Note that the land capacity numbers are preliminary. These estimates are based on existing zoning regulations. They do account for 2023 ADU amendments (HB 1337). It may also be appropriate to revise factors used to model the impacts of landmark tree protection, critical areas and buffers, infrastructure gaps, market factors, or anticipated production rates for infill housing, ADUs, and other housing types. There are additional required and discretionary actions that the city could take to increase housing and population capacity. • Required actions include code revisions related to HB 1110 (middle housing), HB 1998 (co -living housing), and HB 1293 (streamlining design review process). • Discretionary actions include consideration of increased development capacity along high -frequency transit routes (Transit Oriented Development or TOD corridors), implementing minimum density requirements in all residential zones, and expansion of the UGA boundary to include more land for housing. The potential impacts and costs associated with these options will be evaluated in the update to the comprehensive plan. Bellingham.Prelimin Employment Capacity Preliminary Employment Land Capacity Analysis (2023-2045) 1 Estimated Employment Growth Capacity of existing UGA (jobs) 191350 2 Employment Growth Allocation Proposed (jobs) 19,384 3 Difference between 1 and 2 (jobs) (24} 4 Comments: Note that the land capacity numbers are preliminary. These estimates are based on existing zoning regulations. It may also be appropriate to revise factors used to model the impacts of landmark tree protection, critical areas and buffers, infrastructure gaps, market factors, or changes in market conditions related to specific industry sectors. 11 There are additional discretionary actions that the city could take to increase employment capacity. These include: • Consideration of increased development capacity along high -frequency transit routes (Transit Oriented Development or TOD corridors). • Allowing small-scale commercial services in all residential zones. • Expansion of the UGA boundary to include more land for jobs. The potential impacts and costs associated with these options will be evaluated in the update to the comprehensive plan. i How the UGA Might Change ier Priority lore housing capacity sooner awer infrastructure needs at Terrain awer environmental constraints OCurrent city boundary OUGA (to remain) OReserve areas to consider adding to UGA OUGA to consider shifting to reserve area Lower Priority • Less housing capacity • More infrastructure needs • Steep terrain • More environmental constraints This map shows updates under consideration for the UGA (the area into which the city can grow) and the UGA Reserve (the next round of areas for evaluation to become part of the UGA). Population and Employment Projections Birch Bay UGA, Cherry Point UGA, and Columbia Valley UGA, Whatcom County Planning & Development Services Presentation at County Council Committee of the Whole Meeting February 4, 2025 Birch Bay UGA Birch Pt. Park WASHINGTON NBL-A A H. Street Rd. 01 CBo61e iMarina O Pipeline d. DRAYTON HARBOR H oier Rd. Hall Rd. West Rd. O e¢ � � a � MCGe in $ 1r3iahmoo a 0 m ` %Ck A a o m Lincoln Rd. '— Rd Uf Fleet Rd. Loon 8 Anderson Rd - m Bich Bay IJGA Birch C� a Cottonwood Beach Birch Bay Lynden Rd. BIRCH BAY w B A BIRCH BAY Arnie R Arnie Ri Aid rson Rd. Tarte Rd ry Bay UGA llGReserve Ba Rtl Y BIR-H BAY Ba STATE P'rRK Terrm � cr Pt. Whitehorn 0 %' / �� Gr ndview Rd. `/p/J�`����� m SR 548 Y zi o BP Cherry Point IJGA Brown Rh a a Irorm A11 rgroveIII, Rd.. If s Tr: C i City of Blaine ! '� seNVHe Ro � c�� g aX� } S � RGL®N RX ONEGN pIX.[. �cOn i 4Q� w' w } w FPp ER ST i il�t� w H�FATwY �Y � [hf mco.X Ro a[e* Y •X�FASEX �f f:OJKSE tlR � - 5� x RFE [R 3 kHERSCN Ro �F FF DR m FY°f� S _ t `9 EcoR [X f- cx..Xovrtw Ro cR+xo�[wa,, Birch Bay Urban Growth Area Urban Growth Area Urban Growth Area Reserve uIMM-� uX 2024 Population Growth in the Birch Bay UGC#(1990-2020) Average Average Share of Annual Annual Countywide Growth for Growth for Growth Growth for Fear Population Decade Decade Fate Decade 1990 21141 000 4jr 16 3 2.rO22 202 6.9% 5.2% 2010 7r379 3.r2i6322 ,5.9110 9. 116 020 81685 1F396 131 1. 6 9/6 511010 Birch Bay UGA Population Growth Proposal Technical Report Middle: County Preliminary Proposal: Difference: 2,1313 -MR Birch Bay UGA Ave. Annual Population Growth Historical Growth 2013-2023 Average Annual Growth: 121 per year Current Proposal 2023-2045 Average Annual Growth: 121 per year Birch Bay UGA Residential Land Capacity • Potential changes to the Zoning Code would allow middle housing (duplex, triplex, and fourplex development) in the Urban Residential zone to satisfy the requirements of House Bill 1220. • With this zoning change, the preliminary land capacity analysis indicates the existing Birch Bay UGA can accommodate the proposed population growth projections. Birch Bay UGA Employment Growth Proposal Technical Report Middle: County Preliminary Proposal: Difference: 124 450 326 Birch Bay UGA Employment Land Capacity • No changes needed to accommodate projected employment growth. Cherry Point UGA IL {r Agriculture Rural Urban Reserve U Commercial 4] Industrial Residential -Rural Heavy Impact Industrial Light Industrial Park Public Parks/Recreation Comm'/Utilities mq. other Transportat ion Major Arterial _.� Secondary Arterial Collector - Cherry Point Urban Growth Area"' Urban Growth Area (Major Portllydustrial) u ' MfX' Cherry Point UGA Employment Growth Proposal Technical Report Middle: County Preliminary Proposal: Difference: 493 707 Cherry Point UGA Employment Land Capacity • The preliminary land capacity analysis indicates the existing UGA can accommodate the proposed employment growth. Columbia Valley UGA 5umas Nooksack rson • "WOO Columbia Vail( 41 ff � !{ r• e 5umas Mountain Mountain ..� 14 ,s Kendall / \ / \ | -® W�,*- ƒ +, .... :.... % - \ �a % f \ Columbia Valley Urban Growth Area ®' � Urban GrowthArea \ \ \ u� nCro «B_aeervc — ®— • C w 2024 Population Growth in the Columbia Valley UGA (1990-2020) Average Average Share of Annual Annual Countywide Growth for Growth for Growth Growth for Year Population Decade Decade Rate Decade 1990 454 2000 2,384 1,930 193 18.0% 4.9% 2010 3,056 672 67 2.5% 2.0% 2020 3,353 297 30 0.90/0 1.2% Columbia Valley UGA Population Growth Proposal Technical Report Middle: County Preliminary Proposal: Difference: 149 Columbia Valley UGA Ave. Annual Population Growth Historical Growth 2013-2023 Average Annual Growth: 52 per year Current Proposal 2023-2045 Average Annual Growth: 52 per year Columbia Valley UGA Residential Land Capacity • Potential rezoning of some land within the UGA from Urban Residential 4 units/acre to Urban Residential Medium Density 6 units/acre. • With this zoning change, the preliminary land capacity analysis indicates the existing Columbia Valley UGA can accommodate the proposed population growth projections. Columbia Valley UGA Employment Growth Proposal Technical Report Middle: County Preliminary Proposal: Difference: 13 350 337 Columbia Valley UGA Employment Land Capacity • Potential rezoning to Light Impact Industrial north of Limestone Rd. as set forth in the Foothills Subarea Plan. • With this zoning change, the preliminary land capacity analysis indicates the existing Columbia Valley UGA can accommodate the proposed employment growth projections. Whatcom County I Plan sive Alan - zaa5 :,. 7. s s U R-1 i pia.• 41 — , -Columbia Valley Urban Growth Area Urban Growth Area Moo Urban Growth Area Rerserve Existing Zoning Summary I] a owl WA _ ,,tom - '� = �'�_ -�'� ., -y � � �• . .��� � . _ . r - - -�.. -46 Owe WaAoAr PreliminaryProposalGrowth `r ; Whatcom County Council February 11, 2025 Growth Proposal Timeline �� •N -fyg Ph ACE. j l ARCH CITY is Sn Coordinated Planning Effort: 1. October loth — Blaine Planning Commission recommends medium population and high preliminary growth figures 2. October 28th — Blaine City Council passes Resolution 1956-24, agreeing to "medium -high" population and high employment preliminary growth f igu res. 3. November 14th — Blaine staff presents preliminary growth figure proposal to the Whatcom County Planning Commission. 4. December 12th — Blaine staff testifies at Whatcom County Planning Commission continued public hearing. �� Growth Allocation Request -fyg Ph ACE. j l ARCH CITY is Sn • 3,500 Population 1,092 Employment Approved by Blaine City Council Resolution County EIS Alternative Population Employment Alt 1 - Low forecast (No Action) 21513 433 Alt 3 - Medium forecast 21774 701 Alt 4 - High forecast 41186 11092 County Preliminary Growth Figures Figure 5: Revised Population Forecast Ranges, Whatcom County Population 350,000 --- OFM, High 300,000 ' ". *Adj. High —OFM, Middle •••••Adj.Low 250,000 — OFM, Low H istorica I 200,000 150,000 100,000 • 337,551 100 Op OV #� 321,702 � �• • • • 292,714 00 226,855 258,231 + ,.•' am OW 1990 1995 2000 2005 2010 2015 2020 p2025 p2030 p2035 p2040 p2045 Source: OFM - Forecasting & Research, December 2022; and Leland Consulting Group Nate: P means projection. For example "p2045" is the projected population in the year 2045. $101 Buell 1 dr.1 1 1910M.11 to M -Fw- all; WIN tip. i r Recent n PlannedActions ad �� •N -fyg Ph ACE. j l ARCH CITY Ls Sn • Approved Parking Relief in the Central Business District • Approved Increasing the Maximum Building Height in the Central Business District Waterview District • Planning (docketed) a new Urban Mixed Use District with focus on a variety of housing styles • Planning (docketed) updates to our R/0 District for townhouses, multifamily, and hotels. • Planning Accessory Dwelling Unit reform We've got the Capacity! is • Current UGA has capacity for 10,597 people —City of Blaine 20-Yr population request of 3,500 — UGA surplus of land for another 7,097 people • Current UGA has capacity for 51088 jobs —City of Blaine 20-Yr employment request of 1,092 — UGA surplus of land for another 3,996 jobs Semihamoo Bav J S irch P of Drayton H Lincoln Road Birch Bay R d. H Street Road Road IN w c O f� l Haynie Road I Loomis Trail Road �- LIN and �Iil:*u f: k � ��;�„•�.=_.- 5;' rM'd BLAINE INDUSTRIAL PARK rt,. Bellingham Int'I Airport: 23 min. Vancouver Int'l Airport: 41 min. Part of Bellingham: 27 min. Part of Vancouver: 53 min. GREGG RIVA LIAM O`KELLEY KENDRA MILLS COLLIERS Executive Vice President Associate Senior Client Services Specialist 11225 SE 6th St., Suite 240 Colliers +1 206 595 1525 +1 425 453 3135 +1 425 453 3135 Bellevue, WA 98004 gregg.rivaCgkolliers.com liam.okelley@a colliers.com kendra.mills,@ colliers.com colliers.com Cl imatmpacts �r r rr r r a r r^ W ..ram-rwir ■ r ► ■ • .' a E ■ ■ i I — Flooding & Sea Level i • f a♦ 48. � 1 rat 1 k 1 • ■ rrr�rr -r rr r r r r r r rfr a. r Figure 3-54 Climate Impacts: Flooding & Sea - Level Rise Blaine Legend Area to consider adding ® to UGA (� torGXResenre adding Area to consider 0 removing from UGA Q Urban Growth Area IC 1 City Limits Climate impact Area Climate impacts represented on this map include flooding and sea - level rise. AL N 0 aZ5 0.5 1 Miles Date: 01/2712025 Sources: Whatcom County (2024), EEMA(2025), and 'JUGS (2023) SCJ At_LIANC:E CONS—nHe 5"e ICea Wellhead Protection Areas L-JIkJIJAI PA - 41 UNITED STATES V. d=; r---------- -- � 1 • 3 1 o 4 H — -- -- — —— — -- IrI1II1 1 Year TOT" Blaine ,'♦� 5Year TOT' Watershed 10 Year TOT' ♦ �� Recommended 1 year protection area Recommended 5 year protection area Well Head Locations and Protection Areas City of Blaine 1flOa 0 1000 2000 Feet meofrave neamoumofnmeuwouwake CommunityDevelopmert Sourc¢. Wellhead Prcled� Program; Golder Associates; 1996 --i— —irg et the same rate as ground 6-17-2004 water w reach the well within 1,6 or 10 years. Aquifer Recharge Areas _ M - praTgOt t�dsrn -Q'-v_ L -� R,r:r,i • H 17V71T L H ��enes nee Swcct Rnad Drayton Harbor Legend Aquitier recharge areas - High recharge potential MO Moderate recharge potential © Low recharge potential - • City wellhead Wellhead ProtecKion Area " Critical Areas - Aquifer Recharge Areas CDS Dept. A ° 2 W eseroaar 4/16/09 SOURCE: �l-ellhead Protecuou Rogram. Golde, �@ Associates; 199G All MINNINT- --�'low .rvl 1 I _ --`L.: A _saw � -•� _ �;�a�� ���� { -+.�-1 + t ' - Support the Non -Binding Multijurisdictional Resolution Deadlines: 1. June 2025 — Blaine Comprehensive Plan & Climate deliverables are due 2. December 2025 — Council adoption • Comprehensive Water System Plan Update • Informs WRIA water rights adjudication filing. 1LT ;S: .The Peace Arch City f= Y ne r 1 � •' look .4 r ANEW City of Everson Growth Allocation Proposal Whatcom County Council - Committee of the Whole February 11, 2025 4city of evesscy� City Limits Nolte Rd AG 709 Jf 544 7!7 ft Van Dyk 05 C> c 0 v l C.l R5A I MRLI "fhe Cay nfEve 4Vsc19ims the—hannihilay or ware ly ofinnz�s th data lire any parliml purpose. etther express or pphed. Nc rdpi=j nn M—n I ;, mode cunAemins the aecumcy. currency. cvmpletvi ss. or - of ) . .inc%all m,rmsihility for use thereof. axekGlLhn l t '544 hanniess Gom asrd agaiaslany damagealoss.Dr�Pple Rd L _.ingfnm anv use of this daFfl_ AG f b CL 0 0 Everson ' Nooksack 15441 AG f ' J O � o Ej n Ln ® .?01 ft AGMassey Rd c J Gl 9] B S Pass Rd N City Limits Urban Urban Growth Area Growth Area Reserve 0 0.25 0.5 1 Mi 3,500 3,000 ,500 1f500 11000 500 Everson Total Population 2000-2023 Total Population 000 2005 2010 2015 2020 Everson Population Growth 2000-2023 PA�0] 00 150 W{O 50 0 Population Growth 000 71OP2 2004 2006 ZOOS 2010 2012 2014 2016 2018 2020 2022 -50 Current and Upcoming Projects Proposed # of Project Name Status Additional Units Beverly Estates 15 Complete Hougens Landing 73 Preliminary Approval Everson Meadows 4 Preliminary Approval Robinson Townhomes 1 Preliminary Approval Blankers Crossing 57 Preliminary Approval DeHoog Property 80 Pre -Application Emerson Rd Property 12 Pre -Application Greens Ln SP 42 Pre -Application Tjoekler Property 15 Pre -Application Beld Property 92 Pre -Application Hawks landing 21 PreliminarvAm)roval Mateo Meadows 38 Preliminary Approval Fieldview Terrace 15 Pre -Application Younkin SP 3 Pending Approval MJ Short Plat 5 Pre -Construction Vermeulen SP 3 Pre -Construction Kelto Holdings 11 Complete Colton Ln Duplexes 16 Complete Baker St Duplex 2 Complete Total Proposed Units: 505 city of everson i n Current and Nooksack a Upcoming Projects ® 5 pass Rtl Nolte m N N J E ® pa E v• 709- 777 fl _-q� IU7 fr Van Dyk LJ 4rP - Massey Rd B E m F I B®®EEI m � B®�� � .f J N 0 City Limits Urban Urban Project Growth Area Growth Area Location Reserve 1 the City of F.terson 4i,cI tms the merchantahility nr 11-1v trdllne ithl r Bala fnr any pariind $`` pnrl— e3t1w nipr— nr [mphnj. No re¢rexess n n nrr11 tr�arranty is made —e.—g the accuracy. c .Y.. mmplereness. nr- . at' 1 0 .25 U , 5 der¢ depirtcd- swtnn a11—E—hility for use tlty A a.dfikther e>wlwldther,�annnh:mnlessGomuitJxgnenstynydnmxeekns.dPole Rd IVI swg fium nn7 use of ibn dnln, Everson UGA Population Growth Proposal Technical Report Medium: City Preliminary Proposal: Difference: 933 475 Everson UGA Average Annual Population Growth and Share of Overall County Growth Historical Growth Average Annual: Average Annual Growth Rate: Share of Growth: Current Proposal Average Annual: Average Annual Growth Rate Share of Growth 2013-2023 48 per year 1.7% 1.3% 2023-2045 64 per year 1.7% 2.1 % Everson UGA Growth since 2016 Comprehensive Update 2016-2023 Increase of 535 people over 7 years Average Annual: 76 per year Growth Rate: 2.7% Everson UGA Employment Growth Proposal Technical Report Medium: City Preliminary Proposal: Difference: 203 602* 399 *This is the same allocation as presented in the 2016 County Comprehensive Plan Everson anticipates a deficit in population growth capacity Everson anticipates a modest surplus in employment growth capacity. Accommodating Additional Growth Everson anticipates continuing to increase residential densities. Expanding ADU code to comply with HB 1337. Currently working on Sewer and Water System Comprehensive Plans Swapping undevelopable agricultural UGA land with developable land outside of the floodplain I l- 127.58 8r ` f - 701, 6 1 5 F;) 203 1 I � I0 0.25 0.5 1 Miles Proposed UGA Removal Proposed UGA Addition ! Q Current UGA UGA Reserve yy� Urban Growth Area ate ram/ 7 ram/ r�/5 _ 1Y CI}� O� Date: L-.I ! IL-.O` 111mrss of this data faranv puucular pnrpo nhcr anpwss or -ph d. ho r,presamau,- or ,a¢anly isevers" made Stud Area concerning the accuracy. currency- comple.d or yg,,iy .1. d depicted. Any user assumes all responsibdiTy fonue thereof. nud £vnher agrees to hold the Pity afEversan harmless from end agevist .1y damage. loss. or habiffiy adsiug from any —f dus dnm. i - 1 27.58 8 8.18 R 'I I ` —L 7 0 0.25 5 Propo cd UGA Removal 0 Proposcd UGAAddition Cuncnt U0A ' UGA Reserve i 1 Miles Ffff Zane AE (100-year Floodplain) ZoncAF (Floodway) city of Urban Growth Area Date: 21712025 eye ThL City or r pilrp- aiT inu [lix i Or 11u PILed. O repr enty ri ness nF[his deep For any Study Area with Flood -plain lu icular parpnsr eitherenpre sorimplied. lrepresenla[iaeorwammy[smade oncermvg the accuracy. currency. cunspietrness, en ynah[y ut da[e depected, Any nser !� rswnee all napuruihihty for use thereof, end lufhei agees m hold tLe Coy ofFversnn lLI.111s Fro[n and against any Aama¢c. lass, o[ liahiliry ansin¢ tivns aayuse of tLis data. r � 1 Whatcom County Council February 11, 2025 Michael Cerbone, AICP Pbpulation • Fastest groW ng mrnrinity (2013-21,3) • Secaid largest Oty En#WTent • Strong Industrial jab bass 15.2% of eAsting • (lose proA nity to major enplopmrit areas • amrry Fb nr • BAU ngham Urmi Mt i on Ferndale rw--nfion • Far highmy irterchanges on 1-5 • Bail Access • Close prod nity to BU • Close pro)d nity to Vancouver, BC GraMh Preparaticn AdionsTaken • Ntna* groM h and facilitated i nfi It devek V-- I B-ILL (no LEA oqmnd om) • Annexation RuepHnt to guide grawth and identify infrastrLdure reeds • Earty adopters d rrisang rriddle Cottage Hib ng, AOL$ DLiploeq, etc • Mnimmdersityregiirerr�tsinresderrtialzorus • L.�gracW wil evat er t reat nBI plant • Abi lity to add capacity • FW sed r-at e st ruct ure and i n-pact f in place • L�gracW mt er treat nmnt plant • Deep aquifer source with sufficient rights to eland • FeWised rate structure and inpact fees in place tgEIUNIHidngb• RevisedTraixtation 2nand t in 2023 • CaYpletedirtertiewith Otyoflirx,jiamVMter *stem GraM h Preparat i cn Ad i ons Ranred Planning for I nf ndure gni ng extensi on of sanitary swu li ne(s) to serve GrarxM ewA-ea (vull also provide acce- S to mch of LJ34 • gni ng i n-pravenBls to Portal fty 1-5 Interchange (B ke/VW too) • Vb4<i ng with W3DOT and Lnmi on rarxlabaits on Rxal and Rater Fbads • IrrprwementstoftterTreat ment Rant to in7ove v%eter quality • Pedecting a newMI. to acki redu-dancy to mter system • Irrplementing federal gait (fingers a-o�ecQ 6 to irrprae st and non motorized travel along Portal Vey Pbi i cy Request: GrDM h Priqm ect i Urra City of Ferrxiale Requested Fbpulation Prqadiaws • Pbpulatiari 10,961 people (OFMAdjusted Hgh) • EnApluyri u itm 3,337 jabs (,(WM1E ed H gh) Pdicy Request: GroAh Projections cort i nued wed m preli ni nary analysis of the LJGA- • ft can aaamrodate ar residential graAh within the UGAthrough rezones • All d the LCAis outside d flocxiptain le ft are exarrining adding the area to the LCAfor erYployment needs • Can be easily mrviced through extension d existing water and sever • If need lip, we would remove the area min Establish a f - Mqui Utan GraoA h kea Reserve program • Obligate the Canty to corrplete the vwrk necessary by 2027 • U i li ze a 20-year planni ng hod zon Benefits • Ala,% sties to plan for graAh 0 • AhAs qmaal distrids to plan for the grovAh • Fbtional and recaroa ,�ized appch to graAh rranagei rent Fblicy Request: Agdcultural Land Desigrations Ferndale fully �.pportsthe abli r"I Unit and protectim d bath Farm and Fbrest lands Wthi n the cmnty • Indudi ng the establishnmnt d support fad lities necessary to sLipport t hese i ndust H es 0rg fadlitie!4 laydam yawls, etc • Fit What they need Wxre they need it, listen to the i ndustHes RaLU 1 0 of new desi gnat ed tand i n d proxinitytoexisting �oF F ERNp UGAs dmdd be avoided (Ity representation d-aid be inciuded in the designation P--•'L �'�SNINCt� A=I", " 0 -AM Request: • menage these areas to mairtain large tracts of land • Ivbnagetheseareastofacilitateredeveloprrmnt at urban der�ties M ni n-um 40 acre holding zone (a newzonr, not one that eaasts) Rationale Take steps no✓vto prevent further parceli ion and deve[Wrent that will carplicate the ability to amen and4 . i the cost to develop these areas ;07,f. i cy Requenscl.:Fbmwe isrd ers t oAnroat on Request: e Ramwe bani ers t oAnre)(at i on • Consider steps to renmve the Bmidary Roxtiew rd • Fbmwe the need for cities to Lu Imnsate, the county for lost revenue span annexation • Fbmwe t he need f or ci t i es; t o pLrch-:L% i nf nxt u-e f rom t he county won annexation • Provide cities guidance and sort in their efforts • Vb* with cities to i i m ze arvrexation Thankyou ity of Lynde Preliminary Growth Proposals 25 Comprehensive Plan Updab ;ounty Council Committee, February Growth in UGAs — considerations Where do the City proposal numbers come from? Historic patterns — 120+ new units / year Land Capacity Analysis — how much land is available Development potential —the easy land is gone Community sentiment - vetted with policymakers Past Population Growth 18,000 16,000 14,000 12,000 10,000 8,000 6,000 4,000 Cb Co 0~ ``% 01 01 0) C) o0 Q~ Z o� oo� ob o� o� o� �o �\ �`ti �� �� �`� ti6 �'\ ,�� ,�� ,�� ,� ,�� ,�� ,�� ,�� �� ,�� �o �o Growth Metrics )90, Lynden's population has nearly tripled - from F 0 16,696 (2023) Averaged -2.5% annual growth rate since 2010 - around 3 residents every year In 2023, Lynden holds 7% of the County's population but h,, 12% of the last 10 years of County -wide growth Looking to 2045 Low to High population projection is between 4,500 (1.2%) and 10,000 (2.2%) r residents. The OFM Middle is 6,665 (1.5%). Lynden is planning for the OFM P Growing Pains: Past growth pressure (above 2%) places unsustainable demanc services - transportation and schools m� Remaining vacant UGA land is difficult to develop - high water table, critical arE infrastructure needs � Recent SW Lynden Annexation - much is slated for industrial uses Future Population Growth Leland Technical Report Medium Growth Allocation • • • Preliminary City Proposal (Technical Report M P Employment Growth Leland Technical Report Medium Growth Allocation Preliminary City Proposal (Technical Report Medium P Land Capacity Analysis Capacity Cemads Flats 1 Units 0 U n its '' 28 EJ n iks _ m 6 Unfits (ale rest'd) 2, 3, �4-plLx a, 10 piaxr b o� QUal l ty Const. � - a Units o i u i� b ■ r +� m o ae Liars Gate . n 129 U n1S I i It ri a i�6. w No i �1 to F ITOL a *'INOtL --AMR _ fit} Gate'-:-- vi units W TA -' Legend i� Parcel Status vacwt Partially-usecl Moving into public hearing stage - PC in March Finish element drafts for public review Consider any additional land use changes Capital facilities planning CITY OF XTnnVoi A rlV C tidy_' PRELIMINARY GROWTH PROPOSAL - low zw _- f2M ,ti tti y�. Zll �r YN y Imagery Date; 9J5J2024 48155'08.17" N 122118'32.48" W elev 93 ft eye alt 4888 ft ITY OF NOOKSACK UGA STUDY AREAS ■ SA4-8 ■ INDUSTRIAL ■ RESIDENTIAL (SA4) ■ o/s FLOODPLAIN ■ SAR 5 (RESERVE) UGA RESERVE ■ Currently Zoned: Industrial - 29.4 ac URBAN GROWTH AREAS Zones: ■ Public Use 5.31 ac (School Ball Field) ■ Commercial 9.60 ■ Residential 10.00 <25 ac NOO&C'K N 3,500 3,000 2,500 2,000 1,500 1,000 500 2023 TR P090SEDFORECAST R O a TVP� a O YEAR O O O O O O O In O m O In O H N M m CO I— w m O H N M m O H N M zt In M Ln l0 f� 00 m m O O N N N N N N N N N N M m M M M M m m m m a a 0) m m m m m m m O O O O O O O O O O O O O O O r-I r-I O O O O O O O O O O O O O O O H H H H H H H H N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N E IMAGERY COURTESY NOOKSACK COMMUNITY PRODUCERS POPULATION GROWTH: 2010 to 2028 CURRENT and * BASED ON DEVELOPMENTS IN APPROVAL or in CONSTRUCTION CITY OF NOOk A r UGA POPULATIO" GROWTH: ALLOCATED and PROPOSED R� s AbOA LLOCATION PROPOSAL@ County Technical Report MEDIUM: 352 .� (based on OFM'S growth projections) City Proposal: 995 Difference: 643 taw e' !'• R - S r * � � ` ` � � �'` ► � � i• a �` - CITY OFL - r r OOMK - °I*AGERY C. RT _ KSAC1t COMMUNIT C ' *MM:101:1 I I • N • F Actual Share of Prescribed MEDIUM Proposed County Growth Growth Share Growth Share Time 1990's 2000's 2023-2045 2023-2045 Average 0.7% 1.4% 0.6% 1.5% 3 Count 28 47 16 45 Ike- {r IMAGERY COURTESY NOOKSACK COMMUNITY PRODUCERS i CITY OF'4'A NOO;A Analysis of recommendec ❑ Nooksack's analysis shows a minor deficit of population growth capacity over the twenty-year comprehensive plan development period. ❑ HB1220 Addressing Housing Needs ❑ A minor expansion of residential UGA outside of the floodplain would support higher density, affordable housing in cluster or townhome format ❑ Nooksack is anticipating increased residential densities to support prescribed longer term growth ❑ Construction in 2023-24 included 23 Affordable Housing Units. CITY OF NOOk A , UGA EMPLOYMENT GROWTH: ALLOCATED and PROPOSED OCAT I O N PROPOSAL r I -J , r> I h4ii.,•N�•irr a. f h'! � ^,1,ati1l�r,�,i{§dgjf ++jgS.17 fJT: „1�f1'jl xNr`Ytf:iY 4 r►�ri'yyJi;�'N�!�'�-�'Pf,� �� 1�!� V -• II 4"i�i Y 'r(�!¢I�#s, fi I ',�,rY554�UUi� l� � j1.y�L1�,. , ar s,�!�I',t.rT�''�7 ��i9, .;�p�' ��.1.,1�i,''iA.' r .�ial�'�' l,'fyr!�yv9y ��i�a yr a.� rP .=.,'.�r,�(6,{,2�y5,.�6 +, +,' i .'r ,�.� ; I! 1 1i ►!'�yP ±k 1y�J ifi� ' '�r - 9 :Ir � , � - �i •r_ .u't;+.�dl ��! ir; .;, I, ;I r r� ;�J� ' �i �:+, 41:� �d�`';'y`, ,.*i �. I, fq #ill.i� �.I VIF.i �:1 II I I �il�i.';144 �r r.�. �.�1 r4l �r r 111II 1�.`I'� i,n If...��y��l..lw•,f' '��'. I it�l n_ .'��� -y�� i. i. '� 1 I r. i�..���i: .�.l��'�+r� l .r. �� 44 �, r III . I.,.r,l i ��', r I 'i' o !I I i i1� � ' If : � 1r f ? �, +1 �: � f. J i � {•i f yi' ' � I;� I i r 'r 'f 'V ,y •. !ify .f�rrr. �i.-, i,,fl: Ai �lf�l►-rLltll'�: i'—t; 1.:�.. '� 'r f�� � ,r, ��. -,If �I,. f,��.' �1 l (��_ !„ 1 rr(, ��',I'�kl•.r'r �rl-';,nt,� fr'j 1- �� II tilf �: �.. ii-i� �r �l•- I.r i t' � ��f ��;' �} + `1�- �1'J(.` ty i?' f.f u, { {I I I r ,,. '� %1. jI4 I I sl �.:'r . I•G t r� �' �'' 1i 1; ��� �► i� 1 I '� F 1,: ,# {ll�. I!`F kffI� �` (, �?� �. I 1 l , r r +' if l� I;1:I;�, II f 1 f r "� �i'.J� I�lfl�1 j r I 1 tJ, 1 r :tf.l a'� ,f\�� `�, I:t• �u':, I I'?1 g 1 J CITY OF� IMN,00k r. . gGERY COURTESY NOOKSP,CACK. K COMMUNITY PRODUCERS1 8 Analysis of recommended capacity changes: ❑ Expected moderate deficit in employment growth capacity, ❑ To support increased employment growth and available land for Light Industrial and Commercial, ■ improves access to amenities and services in the region, ■ reduces traffic volumes to Bellingham ❑ Employment allocation at the local level underpins job creation and community investment to support its local economy (town center). CITY OF NOO ACK s Nooksack's Growth: ❑ Current community growth exceeds historic patterns and reflects ex -urbanites chasing affordable housing 70, - S� : l ❑ SR-9 Trucking Freight Volumes are increasing creating opportunities for LI investment ❑ Industrial /Commercial Sector has lagged residential growth, expectation is that local demand will support LI/COM investment NOOKSACK POPULATION GROWTH Current and Forecast Based on 2.88 People per DU (2023-2045) *Census (ACS 5-YR Estimates) August 14, 2024 NOOKSACK WAOFMPOP to EFFAPR01 %ANNUAL FORECAST CPUpdate YEAR EST POP HOUSING UNITS DVPPT 2023 GROWTH GROWTH YEAR GROWTH 2010 1,338 457 2011 464 2012 443 2013 481 2014 489 2015 1,405 498 2016 505 2017 514 2018 520 2019 539 2020 1,471 44 2.99% 510 2021 1,515 45 2.97% 531 2022 1,560 13 0.83% 590 2023 1,573 111 7.06% 547 37 2024 1,684 121 7.18% 584 42 DVLPT 1 2025 1,805 69 3.83% 626 24 DVLPT2 1 2026 1,874 66 3.53% 650 23 DVLPT 2 2 2027 1,940 43 2.23% 673 15 Est. 3 2028 1,984 43 2.18% 688 15 Est. 4 2029 2,027 43 2.13% 703 15 Est. 5 2030 2,070 43 2.09% 718 15 Est. 6 2031 2,113 35 1.64% 733 12 Est. 7 2032 2,148 35 1.61% 745 12 Est. 8 2033 2,182 35 1.58% 757 12 Est. 9 2034 2,217 35 1.56% 769 12 Est. 10 2035 2,251 35 1.54% 781 12 Est. 11 2036 2,286 35 1.51% 793 12 Est. 12 2037 2,320 35 1.49% 805 12 Est. 13 2038 2,355 35 1.47% 817 12 Est. 14 2039 2,390 35 1.45% 829 12 Est. 15 2040 2,424 29 1.19% 841 10 Est. 16 2041 2,453 29 1.17% 851 10 Est. 17 2042 2,482 29 1.16% 861 10 Est. 18 2043 2,511 29 1.15% 871 10 Est. 19 2044 2,539 29 1.13% 881 10 Est. 20 2045 2,568 891 Est. NET GROWTH 2023-2045 995 63.27% 344 344 Total Population % Pop. Growth Projected DU Growth Increase Increase CITY DF 1 City of M S Population and Employment Growth Proposal Whatcom County Council February 11, 2025 s Ar 4b4 Whatcom County Carreona - 2025 we Map UGA-7 arrtrsh cohrmbia, earwda hh •�•AAIStr+iT 1 d .F6JYY RL $ _ r ST 1 YJSOfON�iT � •J� HtMLST � Sum ' �k wTF�osT +• n»op cT fI Y�'i'J R { _f — u 5 - 1 � r 4rcKusi d ' ia ga 4VIIr.I�Sr f : r, ��""'-c•` � wfuuxT ST R i im.Ta uoc�Ra �I S� 2 Y—FT� ........... —"— —•--` lam} r l a - Sumas Urban Growth Area City of Sumas FEMA ioo-year Flaodplain- ���Urban Growth Area C1% annual chance of flood) U rban GTowkh Area Reserve FEMA Floodway CcmprEhensive Plan Designation G Surnas Population Since GMA Adoption 1990: 744 2000 : 978 • 2010: • 2020: • 2024: 11319 11665 11835 2NO law 16M 14M 12W a 100{} a a am r 6m 400 2M 0 199D umas Annual Population 1990- 0 4 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018 2020 2022 2024 Year Surnas 2024 UGA Population Growth Proposal Technical Report Medium: Citv Preliminary Proposal: Difference: 697 1,000 City Preliminary Proposal slightly lower than Technical Report High of 1,052 303 Annual Growth Rate: Historic vs. Projected Sumas Historic Population Growth 2003-2023: Annual Sumas Population Growth 2003-2023: Annual Growth Rate %: Sumas Proposed Population Growth 2023-2045: Annual Sumas Population Growth 2023-2045: .m 3.0% 45.5 Annual Growth Rate %: 2.0% Sumas UGA Residential Land Capacity Population Capacity of Existing UGA: 269 Citv Growth Allocation Proposed: 1,000 Difference: -731 (Deficit) Sumas 2024 UGA Employment Growth Proposal Technical Report Medium: Citv Preliminar Difference: Proposal: 150 500 350 Sumas UGA Employment Land Capacity Employment Capacity of Existing UGA: 219 Citv Growth Allocation Proposed: 500 Difference: -281 (Deficit) Pause for Reflection Sumas' Problems • More Growth in next 20 years • Not Enough Land Capacity • In Direct Path of Flooding Solution • Flood -resilient UGA Expansion iMmunityof earb or ck b 0 1,000 2,000 3,000 ft jjrjWUARRISONT ENMW GARFIELD-ST JONESRD Ellm ® BOWEN ce O Legend: Cty Lfrnits CLEARBRO4K a ] Current UGA UGA Reserve (To be Included) UGA Reserve (To be Removed) MORGAN Rb Q UGA Suitability Analysis Study Areas i 0 FEMA Regulatory 100-year Floodplain �.. City of Sumas DATA SOURCES: PROJECTION: ci rY OF%, Proposed UGA Whaktorn County Assessors UTM Zone 10 North � Office & Planning Department NAD 27 LJIt E]IlI f Study a�lr 5 and the City of Sumas Scale: 1:34,000 �.. r , .,r .n n_,■.■ �'� ■ruulllFlw�ur�u== i� ■w l Eul 71P wl - - .■� .■� ■_ -ri �III�� r lil ■�■■ r; t■■r■ ■■■■i ii ■kl y _ no 1'll i 19 j[II 7 e� r ■ M 1111=oil �� �1111 dill J - �■� 111■11 ■I� � ■la■ lul_ lu FRONT STII-�l I lU 1 I l I ROCK-RD BOW -EN R II SR547 rr .1 try JI r'4 5C 7. Legend: omm unity 0, x City Limits learbrook j J CLEAR AOOXRD C3 Current UGA f Q UGA Reserve jo be Included] I C3 UGA Reserve (To be Removed) 0 MRGAN Ra 0 UGA Suitability Analysis Study Areas z ;� 0 FEMA Regulatory 104-year Floodplain 1 OQ� {]00 3 �U�7 f[ City of Sumas DATA SOURCES: PROTECTION: F r F CITY 01" s, Proposed UGAWhatcom County A5sessor's UTM Zone 10 North Office & Planning Department NAo 27 Suitability Study Areas and the City of Sumas Scale: 1.34,000 Flood -resilient UGA Expansion Benefits • Outside FEMA 100-year floodplain • Accommodates new population growth • Provides additional land capacity for future growth New Problems • UGAs must include some amount of Floodplain • All areas around Sumas zoned Agriculture Agricultural Zoning Potential Solution • Development Rights - All properties included in UGA would be required to pay a fee per acre to the Whatcom Conservation Futures Fund prior to the approval of a development permit. These funds would be used by the County to retire development rights in agricultural or rural study areas. Thank you! The preliminary recommendations / current requests from PDS and the cities for population growth are summarized in Table 1 below showing how the preliminary numbers compare to the high, medium, and low technical report population projections (Table 2 shows the proposals for employment growth). Because the preliminary recommendations from most cities, and from PDS for the County's UGAs, are higher population totals than their historic share of the medium projection, the countywide total for population growth in the preliminary proposal is about 10,700 people higher than the medium projection (the medium is what has been used historically). Table 1: Preliminary Population Growth Projections Preliminary Low Medium Recommendations High High Population Population Low Population Medium Population Population Share Population Share Population Share Population Share Bellingham City & 30,310 44.8% 16,242 42.4% 24,158 42.4% 36,462 42.4% UGA Birch Bay UGA 2,662 3.9% 1,555 4.1% 2,313 4.1% 3,490 4.1% Blaine City & UGA 3,500 5.2% 1,865 4.9% 2,774 4.9% 4,186 4.9% Cherry Point UGA 0.0% 0 0 - - - - Columbia Valley 1,137 1.7% 665 1.7% 988 1.7% 1492 1.7% UGA Everson City & UGA 1,408 2.1% 627 1.6% 933 1.6% 1408 1.6% Ferndale City & UGA 10,961 16.2% 4,883 12.8% 7,262 12.8% 10,961 12.8% Lynden City & UGA 6,665 9.9% 4,481 11.7% 6,665 11.7% 10,060 11.7% Nooksack City & 995 o 1.5/ 237 0 0.6/ 352 0 0.6/ 531 0 0.6/ UGA Sumas City & UGA 1,000 1.5% 468 1.2% 697 1.2% 1052 1.2% Rural and Resource Lands 9,000 13.3% 7,243 18.9% 10,773 18.9% 16,260 18.9% TOTAL 67,638 100% 38,266 100.0% 56,915 100.0% 85,902 100.0% Table 2: Preliminary Employment Growth Projections Preliminary Low Medium L 7 High Recommendations I Employment Low Employment Medium Employment High Employment Employment Share Employment Share Employment Share Employment Share Bellingham City & 19,384 � 59.9% 9,719 ° 62.5/ 15,172 ° 62.5/ 23,642 ° 62.5/ UGA Birch Bay UGA 450 1.4% 80 0.5% 124 0.5% 194 0.5% Blaine City & UGA 1,092 3.4% 449 2.9% 701 2.9% 1,092 2.9% Cherry Point UGA 1,200 3.7% 316 2.0% 493 2.0% 769 2.0% Columbia Valley 350 ° 1.1 /0 9 ° 0.1 /0 13 ° 0.1 /0 21 ° 0.1/o UGA Everson City & UGA 602 1.9% 130 0.8% 203 0.8% 317 0.8% Ferndale City & UGA 3,337 10.3% 1,372 8.8% 2,141 8.8% 3,337 8.8% Lynden City & UGA 1,799 5.6% 1,152 7.4% 1,799 7.4% 2,803 7.4% Nooksack City & 232 0.7% 51 0.3% 79 0.3% 124 0.3% UGA Sumas City & UGA 500 1.5% 96 0.6% 150 0.6% 233 0.6% Rural and Resource Lands 3,403 10.5% 2,180 14.0% 3,403 14.0% 5,302 14.0% TOTAL 32,349 100% 15,554 100.0% 24,278 L 100.0% 37,834 100.0% At least one councilmember has indicated interest in lowering the overall countywide growth number to the medium projection; if that is the Council's policy direction, PDS and the Cites also need to understand how the Council wants to reallocate that lower number between the cities and the County's UGAs and rural and resource lands. If the Council changes the distribution to cities further work with the cities is necessary to ensure there is coordination between the County and the cities plans. To aid in the Council's discussions, below are two alternative scenarios that are not a recommendation but presented for discussion purposes to show what it might look like if the Council wishes to reduce the total countywide population projections. Scenario 1 would reduce the preliminary population projections for the County's non -municipal UGAs and rural and resource lands to the low projection. This would reduce the countywide number from 67,638 to 64,310 (7,395 above the medium projection); this scenario would get closer to the medium projections but would not require that cities modify their proposals. Scenario 2 uses the countywide medium projection and allocates numbers to each city using the same proportional distribution as presented in the current preliminary requests from the cities; this scenario would require getting concurrence on the lower numbers from the cities. Both scenarios would reduce the growth projections for the County's rural and resource lands further below the medium projections for those areas. Reducing the numbers for rural and resource lands to the low projection is not consistent with past development patterns and would likely require future policy and regulatory changes if growth in rural and resource lands exceeds the numbers if adopted in the Comprehensive Plan (please see the discussion on pages 8-9 of the Staff Memo for 1.28.2025 for more details). Scenario 1 Population Population Share Scenario 2 population Population Share Bellingham City & UGA 30,319 47.1% 25,509 44.8% Birch Bay UGA 1,555 2.4% 2,240 3.9% Blaine City & UGA 3,500 5.4% 2,945 5.2% Cherry Point UGA 0 0 0 0 Columbia Valley UGA 665 1.0% 957 1.7% Everson City & UGA 1408 2.2% 1185 2.1% Ferndale City & UGA 10,961 17.0% 9,222 16.2% Lynden City & UGA 6,665 10.4% 5,608 9.9% Nooksack City & UGA 995 1.5% 837 1.5% Sumas City & UGA 1000 1.6% 841 1.5% Rural and Resource Lands 7,242 11.3% 7,572 13.3% Total 64,310 100.0% 56,915 100.0% Multi jurisdictional Resolution, ??/??/2025 Proposed by: Introduction date: RESOLUTION NO. NON -BINDING MULTI -JURISDICTIONAL RESOLUTION REGARDING POPULATION, HOUSING AND EMPLOYMENT ALLOCATIONS WHEREAS, the Growth Management Act (GMA) requires Whatcom County and the cities to review and, if needed, update their respective comprehensive plans by December 31, 2025; and WHEREAS, the GMA requires county and city comprehensive plans to be coordinated and consistent; and WHEREAS, the GMA states that urban growth areas (UGAs) must be revised to accommodate the urban growth projected to occur in the succeeding 20-year planning period by December 31, 2025 (RCW 36.70A.130); and WHEREAS, the GMA, county -wide planning policies and inter -local agreements indicate that review of UGAs should be coordinated between the County and the cities; and WHEREAS, population, housing, and employment allocations are a critical component in the comprehensive plan update and UGA review process; and WHEREAS, while final decisions on population, housing, and employment allocations will not be made until the comprehensive plan is adopted in 2025, it is important for the County and cities to agree upon preliminary allocations in order to coordinate transportation modeling, capital facility planning, environmental review, and UGA recommendations; and NOW, THEREFORE, BE IT RESOLVED that the Whatcom County Council hereby agrees to utilize the population, housing, and employment growth allocations shown on Exhibit A as the preliminary allocations for initial review of urban growth areas by the County and cities. It is acknowledged that a range of population, housing, and employment allocations will also be studied in the environmental impact statement and UGA review process and the final UGA growth allocations may be different than set forth in this Resolution. APPROVED this ATTEST day of Cathy Halka, Clerk of the Council APPROVED AS TO FORM: Civil Deputy Prosecutor 2025. WHATCOM COUNTY COUNCIL WHATCOM COUNTY, WASHINGTON Kaylee Galloway, Council Chair Exhibit A Population, Housing Unit, and Employment Growth (2023-2045) Population Housing Housing Employment Population Share Units Unit Share Employment Share Bellingham City & UGA 30,310 44.8% 18,390 51.1% 19,384 59.9% Birch Bay UGA 2,662 3.9% 1,051 2.9% 450 1.4% Blaine City& UGA 3,500 5.2% 1,774 4.9% 1,092 3.4% Cherry Point UGA 0 0.0% 0 0.0% 1,200 3.7% Columbia Valley UGA 1,137 1.7% 502 1.4% 350 1.1% Everson City& UGA 1,408 2.1% 610 1.7% 602 1.9% Ferndale City & UGA 10,961 16.2% 4,659 12.9% 3,337 10.3% Lynden City& UGA 6,665 9.9% 3,535 9.8% 1,799 5.6% Nooksack City & UGA 995 1.5% 433 1.2% 232 0.7% Sumas City& UGA 1,000 1.5% 643 1.8% 500 1.5% Rural & Resource Lands 9,000 13.3% 4,416 12.3% 3,403 10.5% Total 67,638 100.0% 36,013 100.0% 32,349 100.0% Notes: 1. The population, housing, and employment allocations represent, for preliminary planning purposes, the additional growth anticipated between 2023 and 2045. The housing figures are from the Housing for All Planning Tool (HAPT). 3 Exhibit B Housing Unit Growth by Income Band (2023-2045) 0-30% %of Total Total Non-PSH PSH >30-50% >50-80% >80-100% >100-120% >120% Bellingham City & UGA 51.06% 18,390 4,978 1,944 4,158 1,197 989 1,400 3,725 Birch Bay UGA 2.92% 1,051 285 111 238 68 56 80 213 Blaine City & UGA 4.93% 1,774 480 188 401 115 95 135 359 Cherry Point UGA 0.00% 0 0 0 0 0 0 0 0 Columbia Valley UGA 1.39% 502 136 53 113 33 27 38 102 Everson City & UGA 1.70% 610 165 65 138 40 33 46 124 Ferndale City & UGA 12.94% 4,659 1,261 492 1,053 303 250 355 944 Lynden City & UGA 9.82% 3,535 957 374 799 230 190 269 716 Nooksack City & UGA 1.20% 433 117 46 98 28 23 33 88 Sumas City & UGA 1.79% 643 174 68 145 42 35 49 130 Rural & Resource Lands 12.26% 4,416 0 0 45 855 304 307 2,905 Emergency Housing Needs 299 17 29 0 8 10 76 58 7 10 72 Total 100.00% 36,013 8,553 3,340 7,189 2,912 2,002 2,712 9,305 586 Notes: 1. The housing figures are from the Housing for All Planning Tool (HAPT) and represent, for preliminary planning purposes, the additional growth anticipated between 2023 and 2045. PSH means "Permanent supportive housing." This term is defined in the Growth Management Act at RCW 36.70A.030(31)). The 0-30%, 30-50%, 50-80%, etc. figures refer to Area Median Income (AMI). Emergency housing needs represent the beds needed. 4 FEMA Mapping Committee of the Whole 2/25/25 Current Effective Mapping AG Evekson ' -A a i Rural _.._,.� i MRL tart, r- Rural MAL AG f' nb... ioo-yearFloodp]ain- I,t (i%annual chance of flood) CRAFT Mapping (2023) - Floodway Urban Growth Area r Urban Growth Area Resene ITe 2 +c rw�l ...... oksa ZI to � 4 R mart _ •trr � 1 Rural AG MRl_ { 44 Urban Growth Area Urban Growth Area Reserve ioo year floodplain (i% annual chance of flood) - Floodway Current EffectiviNapping _ AG AG E Nooksack UGA ' (Everson) AG M RL. RVFtAL DRAT Mapping ('63) 'e AG i f F Y vas at Nook -sick F F, k IJ 1 er I_ f r . _.._ .�,. _.•_.. r.y eFb 1 In UGA (EversoAG AG i RURAL �..o MRL eoecim AG f � 4 Rural i oo-year f loodp la in - Urban Growth Area{i%annual chance of flood) f f Urban Growth Area Reserve rf. %• Floadway COurrrenat Effective Mapping 4 Sumac _ rL s �, L At a® __rl AG DRAFT Mapping (2025 = 2023 draft without floodway) 8riiish Colurn biu, Canada I b 4 f " y {4 Rail a 4 J � � wwrrJn cr J' �wqi. S � owner � i 1 bkloMe[ ' IIII[+ n.ox. st 1[oCx 1mJ' y 4 8 i Urban Growth Area loo year Floodplain (i% annual chance of flood) Urban Growth Area Reserve Floadway Current Effective Mapping.,-. AG Reighburhacd 11-4 'AP j 7 Faral ........ ..... ........ t 7 Current Effective Mapping Urban Growth Area ioo•year Floodpla in - DRAFT Mapping (2025 2023 with floodway mod) •(1% ann ua I chance of flood) Urban Growth Area Reserve Floodway rkL11FgJ1 7 r 57M Rural q IN Rural Ferndale Furrl jr Rurd Pw Rural aos y�� aw., I Ruraf Ros NelghbwhoW V r I 1 ROS k Rural RO AG i AG r C--.— U.M...O.M, uiaMo6righam) Status of FEMA Mapping Meeting/Deliverable i Revised Draft Map Release Preliminary FIRMS and FIS Release Consultation Coordination Officers Meeting Public Meeting/Workshop Appeal Period Starts Appeal Period Ends Letter of Final Determination Maps and FIS become Effective January 15, 2025 Fall 2025* Winter 2025* Winter 2025/2026* TBD TBD TBD TBD q rl L WHEREAS, the Washington State Growth Management Act (GMA) requires that Whatcom County and the cities review and update their comprehensive plans; and WHEREAS, the GMA states that urban growth areas (UGAs) must be revised to accommodate the urban growth projected to occur in the succeeding 20-year planning period; and WHEREAS, Countywide Planning Policies encourage placing a larger share population growth and housing allocations in Bellingham and urban areas, and less in rural areas; and WHEREAS the GMA encourages placing a larger share population growth and housing allocations in Bellingham and urban areas, and less in rural areas; and WHEREAS, the City of Bellingham is coordinating with Whatcom Transit Authority to plan, fund, and build Transit Oriented Development that could create the capacity for over 1000 new housing units; and WHEREAS, the County and cities climate action and sustainability goals include minimizing vehicle trips from rural areas to urban areas; and WHEREAS, the success of these strategies depend on a significant investment of cities resources to provide infrastructure for achievable housing and employment growth, and WHEREAS, the proposal from PDS to plan for 19% greater population housing growth above the State Office of Financial Management's (OFM's) most likely projection for growth through 2045; and WHEREAS, inflated population projections direct capital facility planning and potential capital facilities investments to areas that may not eventually be developed; and WHEREAS, the County's current land use policies led the City of Ferndale to request that Council adopt a moratorium on further development in unincorporated areas that Ferndale may seek to annex, as County policies may lead to piecemeal development in these areas that make future annexation too difficult; and WHEREAS; current population projections include planning goals well above OFM most likely medium in areas far from current employment areas and projected employment growth, including Columbia Valley and Birch Bay; and WHEREAS; despite best efforts at mitigation, the physical geography surrounding Columbia Valley often produces some of worst air quality in the state, and WHEREAS; some current planning projections well above the most likely OFM medium come from some cities suffering from increased flooding; and WHEREAS, any non -binding resolution would by default, be non -binding and subject to change in the future; and WHEREAS, Council has not yet seen EIS scenarios that would inform any decision on population and employment projections; NOW, THEREFORE, BE IT RESOLVED, that the Whatcom County Council requests that the Executive and Whatcom County Planning and Development Services: 1) Address the City of Bellingham's concerns about inflated rural and county -wide population and employment projections; and 2) Respond to the City of Ferndale's concerns about how current County policy threatens piecemeal rural development that may frustrate annexation and inflate future housing costs; and 3) Reconsider population and employment projections that, county -wide, are well over the most -likely forecast of OFM most -likely medium; and 4) Present Council with population housing projections where the sum of all jurisdictions' proposals net to something closer the OFM most -likely medium; 4a) With higher that medium projections in Ferndale and Bellingham, and higher than medium elsewhere in urban areas and existing urban UGAs adjacent to incorporated cities, and 4b) Potentially with projections below medium in rural and rural resource areas, and UGAs not associated with incorporated cities, and 4c) Potentially with projections at medium in Columbia Valley and Birch Bay; and 4d) Potentially with median projections in flood prone areas as defined in most appropriate mapping 4e) Potentially providing information aligning planned commercial and industrial land capacity and zoning in cities and unincorporated areas with employment growth projections well above the most likely projection from OFM. Comprehensive Plan Additional Guidance, ??/??/2025 Proposed by: Introduction date: RESOLUTION NO. RESOLUTION REGARDING ADDITIONAL GUIDANCE FROM THE COUNTY COUNCIL TO THE EXECUTIVE AND PLANNING AND DEVELOPMENT SERVICES ON THE POPULATION, HOUSING AND EMPLOYMENT ALLOCATIONS WHEREAS, the Growth Management Act (GMA) requires Whatcom County and the cities to review and, if needed, update their respective comprehensive; and WHEREAS, the GMA requires county and city comprehensive plans to be coordinated and consistent; and WHEREAS, the GMA states that urban growth areas (UGAs) must be revised to accommodate the urban growth projected to occur in the succeeding 20-year planning period that extends through 2045(RCW 36.70A.130); and WHEREAS, population, housing, and employment allocations are a critical component in the comprehensive plan update and UGA review process; and WHEREAS, Countywide Planning Policies encourage placing a larger share population growth and housing allocations in Bellingham and urban areas, and less in rural areas; and WHEREAS the GMA encourages placing a larger share population growth and housing allocations in urban areas, and less in rural areas; and WHEREAS, the County and cities' climate action and sustainability goals include minimizing vehicle trips from rural areas to urban areas; and WHEREAS, Transit Oriented Development is key to these climate action and sustainability goals include minimizing vehicle trips from rural areas to urban areas; and WHEREAS, Transit Oriented Development is more practical when housing and employment growth is concentrated in urban areas; and WHEREAS, through a separate resolution, titled "Non -Binding Multi -Jurisdictional Resolution Regarding Population, Housing and Employment Allocations," the County Council will approve preliminary allocations for initial review of urban growth areas by the County and cities; and WHEREAS, while final decisions on population, housing, and employment allocations will not be made until the next comprehensive plan is adopted, it is important for the County and cities to agree upon preliminary allocations in order to coordinate transportation modeling, capital facility planning, environmental review, and UGA recommendations; and WHEREAS, the final population and employment allocations may affect how accurately the cities and County plan for investing substantial amounts of capital into infrastructure needed for achieving housing and employment growth; and WHEREAS, the preliminary population, housing, and employment growth allocations shown in Exhibit A to the "Non -Binding Multi -Jurisdictional Resolution" plan for population growth above 19% greater the State Office of Financial Management's (OFM's) most likely projection for growth through 2045; and WHEREAS, higher city and UGA population projections will allow for increased housing supply and densities to help address our affordable housing needs, they also increase capacity and feasibility for Transit Oriented Development, but may direct capital facility planning and potential capital facilities investments to areas that may not be developed within the 20-year planning period; and WHEREAS, population and employment proposals in Exhibit A to the "Non -Binding Multi -Jurisdictional Resolution" include levels above the medium growth projections in some UGAs not adjacent to major projected employment areas, such as Columbia Valley, providing additional employment capacity in such UGAs as Columbia Valley may also reduce vehicle trips from such areas to other major employment centers; and WHEREAS, the County's current land use policies may lead to piecemeal development in unincorporated areas that cities may seek to annex in the future, making future annexations more difficult and housing even more expensive; NOW, THEREFORE, BE IT RESOLVED that the Whatcom County Council acknowledges that a range of population, housing, and employment allocations are being studied in the environmental impact statement and UGA review process and the final UGA growth allocations may be different than set forth in Exhibit A to the "Non -Binding Multi -Jurisdictional Resolution". BE IT FURTHER RESOLVED the Whatcom County Council requests that as part of the development of the 2025 Comprehensive Plan Update, the Executive and Whatcom County Planning and Development Services: 1) Coordinate with the cities and County Council to recommend tools for improving development potential in municipal unincorporated UGAs (e.g., annexation incentives) where cities do not extend public sewer and water prior to annexation. Furthermore, consider if policies such as the following might address those concerns: (a) Modifying County zoning in existing and city -proposed Urban Growth Areas to allow a maximum of one dwelling/20 acres. (b) Modifying County zoning in existing and city -proposed Urban Growth Area Reserves to allow a maximum of one dwelling/20 acres. (c) Encourage the cities to develop or review future land use designations that would take effect in the UGAs upon annexation. (d) Encourage alternative funding mechanisms such as impact fees and other mechanisms to pay for infrastructure needs in the UGAs to enable cities and other urban service providers more feasible means to extend these services into municipal unincorporated UGAs. 2) Present options and an analysis of the pros and cons of reducing or mitigating potential population growth impacts to the County's rural and resource lands. 3) Encourage increasing transit from outlying small cities and rural areas into major employment areas to reduce VMT's. 4) Study street standards in municipal UGA and UGA reserves to align bicycle, pedestrian, and mobility infrastructure to connect with similar adjacent municipal infrastructure. 5) Provide County Council information on how employment projections in Exhibit A to the "Non -Binding Multi -Jurisdictional Resolution" for rural and rural resource areas, and for UGAs not associated with incorporated cities, align with planned commercial and industrial land capacity and zoning in those areas. 6) Present options to County Council to discourage growth in vulnerable floodplains and coastal areas projected to experience sea level rise and to encourage growth in safer locations 7) Establish and publish goals and metrics to expedite and reduce the cost of permitting 8) Develop a work program to conduct a full code simplification process 9) Establish a policy to ensure that when permit applicants receive responses from Planning and Development Services all county requests must be justified by citing o a specific and publicly accessible county code or state or federal law or regulation. 10) Update the County Council on discussion between the County, the City of Bellingham, City of Ferndale, and other cities that work toward addressing these issues. APPROVED this ATTEST day of Cathy Halka, Clerk of the Council APPROVED AS TO FORM: Civil Deputy Prosecutor 4 2025. WHATCOM COUNTY COUNCIL WHATCOM COUNTY, WASHINGTON Kaylee Galloway, Council Chair Whatcom Environmental Counci Carl Weimer, President Former Whatcom County Council Stan Snapp, Vice President Former Bellingham City Council David Stalheim, Secretary Retired Planning Director Rick Dubrow, Treasurer Retired Owner of A-1 Builders John Blethen Retired business owner, Greenways and Parks Board Laurie Caskey-Schreiber Former County Council Rick Eggerth Retired Litigation Attorney, Environmental Activist Oliver Grah Retired Physical Ecologist and Water Resource Manager Jean Melious Retired WWU Professor Barry Wenger Retired Ecology Planner Email: whatcomec@gmail.com Website: www.whatcomenvirocouncil.org Facebook: Whatcom Environmental Council March 10, 2025 TO: Whatcom County Council Whatcom County Executive RE: Nonbinding Resolution (AB2025-224) The Whatcom Environmental Council urges the County Council to reject the proposed multi -jurisdictional resolution that has been added to the agenda for March 11th (AB2025-224). Adoption of this resolution is not required by the Growth Management Act (GMA), is inconsistent with the public participation and environmental review requirements and fails to even consider how growth projections and allocations affect our response to climate change and resilience, or available water resources. Population Allocations: The resolution requests approval of the population and employment allocations proposed by the cities, which appear in some cases to be based on aspirational goals rather than realistic, data -driven estimates. The county -wide growth projections are approximately 19% higher than the Office of Financial Management's medium - growth forecasts, which have historically been an accurate estimate of future growth. This disparity highlights the need for a more rigorous analysis to ensure allocations align with probable growth trends and avoid unnecessary overestimation. Some areas may need projections higher than the medium population numbers, and some areas, particularly the rural areas, should have lower projections, but the overall projected number should be more closely align with the OFM medium number. The numbers proposed for the non -binding resolution make no attempt to accomplish this difficult but critical balancing act. Higher population allocations risk triggering unnecessary expansions of Urban Growth Areas (UGAs), potentially leading to sprawl and encroachment on farmland and other resource lands. Such impacts could undermine the county's goals of preserving agricultural viability and protecting critical natural areas. Any decision to expand UGAs must be grounded in demonstrated need and informed by comprehensive environmental and public review. Water Availability: It appears that the County Council is considering "non -binding" approval of growth projections that exceed the OFM medium number without knowing whether water will be available in areas where new growth will be allocated. Lynden's mayor, at a city -county elected officials meeting on October 29, 2024, admitted that Lynden has been "out of water ... for 20 years", yet the proposed Resolution would allocate 6,665 more people (4,659 housing units) and 1,799 more jobs to a city that has publicly admitted it is out of water. Water availability concerns are not limited to Lynden, however. While the City of Bellingham may have additional water rights to serve a larger growth allocation, no evidence addresses whether increased urban water consumption will impair water resources in the Nooksack watershed. We have asked the City of Bellingham how their proposed growth strategy affects water for fish and wildlife, and the absence of a response indicates that the City probably does not know. We understand that "the city of Bellingham is in discussions with the Lummi Nation over water use" and that "the city and tribe differ over which studies should be used in negotiations. Bellingham is launching its own $500,000 study, with field work to be completed by the end of the summer." There is no reason to approve a population allocation to Bellingham before this study is completed, even if the allocation is said to be "non- binding." Climate impacts: The resolution asks the County Council to approve population allocations before the Council has reviewed or considered any analysis of climate change and resilience. In 2022, the County Council spent several meetings (AB2022-422) establishing priorities for the GMA Update, culminating in Resolution 2022-036. At that time, the Council directed to "[m]ore thoroughly consider how growth patterns may have been altered from ...climate change ... and what impact this should have on future planning." Despite our repeated requests to delay growth allocations until the Environmental Impact Statement might show where growth is best allocated to address climate change, the proposed proposed Resolution would be adopted before the Council has considered any climate change information. Failure to address other GMA issues: It is essential to consider other critical issues before approving growth projections and population allocations. The County needs to consider how to direct growth out of rural areas to urban areas, how it intends to ensure 100,000 acres of agricultural land is designated, and how it intends to address the GMA requirement for open space corridors within and between Urban Growth Areas. We have provided recommendations regarding these issues in our letters, linked below. Public Participation Concerns: Finally, we are alarmed that you added this resolution to the agenda on Friday, March 7t" and may take action only two business days later, on March 11t", without any additional public notice, public hearing or environmental review. The legislative record before the County Council is devoid of any input except letters from cities. Letters written by WEC and other citizens are not included in the packet or posted online. The record also fails to include the proceeding of the County Planning Commission in 2024 (see Planning Commission materials at A132025-081. to the Council should not proceed without providing an pg. 2 adequate opportunity for public participation, especially when public input to date is excluded from the record. Thank you for consideration of our comments. To ensure that our previous comments are in the record in the event you decide to move forward with this resolution, the following are links to letters that WEC previously provided to Whatcom County. 1) January 27, 2025. Allocating Population. 2) December 8, 2024. Population and EIS. 3) December 1, 2024. Bellingham Growth Strategy. 4) November 12, 2024. Growth Protections. 5) October 21, 2024. Proposed Growth Strategy. 6) August 23, 2024. Open Space Corridors — Bellingham & Ferndale, Cherry Point & Birch Bay, Blaine & Birch Bay. 7) July 30, 2024. Urban Growth Areas, Growth Projections. Regards, Carl Weimer, President pg. 3