The thousand acre dilemma: Part 1
As you may recall, in January 2007 the Growth Management Hearings Board (GMHB) found that the city’s comprehensive plan violated the internal consistency requirement of the Growth Management Act (GMA) and ordered the city to bring its plan into compliance. In April of last year, Council members complied with the GMHB order by adopting a 47.5-acre park level of service that would expand our park system to more than 5,000 acres by 2022 to accommodate projected growth.*
Now, according to the most recent draft of the Bellingham Parks, Recreation & Open Space Plan update, city officials claim we only need 4,000 acres to do the job. What happened to the other thousand acres?
Q1: Did the city shrink its population forecast, thereby reducing the amount of parkland needed?
No. The 2022 population estimate is still 113,055, an increase of 31,601 during the 20-year planning period.
Q2: Did we, as taxpayers, decide we didn’t really want to maintain the 47.5-acre park level of service (LOS) adopted by Council just last year?
No. There hasn’t been any true public process to that effect.
Q3: Are projected park acquisition revenues significantly less than anticipated?
Not really. According to the city’s 2007 “Financial Strategies” analysis, estimated total revenues for the 15-year period from 2007 to 2022 were $171 million, or $11.4 million per year. In the 2008 Park Plan update, projected revenues at the high end are $155 million for the 14-year period from 2008 to 2022, or $11.1 million per year, a difference of less than 3%.
Q4: Perhaps the city adopted an unrealistically optimistic park LOS when it amended its comp plan in 2007?
Well… consider this: There are approximately 13,600 existing residents in Bellingham’s UGA who do not contribute toward the cost of acquiring parkland and open space. As long as they reside in their current homes, none of these residents will ever be subject to the city’s park impact fee. Additionally, prior to being annexed, none will contribute to the city’s Greenways levy or pay real estate excise taxes that can be applied toward the expansion of the city’s park system.
In adopting its comprehensive plan, the city assumed that all 13,600 UGA residents will be annexed by 2022. According to the comp plan, the city will acquire 47.5 acres for every 1,000 newly annexed residents, a total of 646 acres for the 13,600 existing UGA residents. Additionally, the city is expected to develop related park facilities, such as ball fields, playgrounds, trails, and restrooms.
With the current value of the city’s park system at roughly $5,100 per capita, acquiring land and facilities to accommodate the annexation of these 13,600 residents is projected to cost city taxpayers more than $69 million ($5,100 x 13,600 = $69.4 mil). Given that these residents have never contributed toward the cost of expanding the city’s park system - nor can they be expected to do so before annexation - how realistic is it that $69 million will be available immediately upon annexation to pay for these park acquisitions?
Q5: OK, then why did the city adopt an unrealistic park LOS?
That question is beyond the scope of this article but will be addressed in Part 2 (Bellingham’s land supply: deception, lies and videotape). In the meantime, I invite city officials – including past and present City Council members - to tackle this issue directly by adding their own comments below. To be sure, any complete response must address the city’s desire, at the time, to expand its UGA and the requirement to create a land supply analysis to justify that expansion.
This much I will say. It is clear that the GMA requires the city’s comprehensive plan to be an internally consistent document. If the city adopts a new park LOS in its Park Plan, it will need to reflect that change in its land supply analysis to maintain consistency. Failure to do so will represent another violation of the GMA and will prompt further GMHB appeals.
It is important to understand that if the city does not preserve these thousand acres of parkland and open space as originally planned, they will become available for development. How many people can these thousand acres accommodate? When this acreage is added to the mix, will the revised land supply analysis reveal that the city has an adequate supply of land without the need to expand its UGA or continue the relentless upzoning of properties in our neighborhoods? Will the revised land supply analysis make the GMHB appeals of Whatcom County’s decision to limit the size of Bellingham’s UGA moot?
Q6: What can we do now to address the future needs of our park system?
First, in order to establish a baseline, we should determine what expansion of our park system, if any, would be needed under a hypothetical no-growth scenario. In other words, if Bellingham’s population remained the same as it is today, what land and/or facility additions would be needed?
Next, we should determine the best way to expand our park system assuming our projected growth forecast of 113,055 is realized. These land and facility additions, above and beyond those in the baseline, represent the portion of the park system expansion needed to accommodate growth.
Certainly, if we have any hope of adequately expanding our park system to accommodate projected growth, we must require development to pay the vast majority of these costs. While the GMA does not allow impact fees of 100%, the theoretical limit is as high as 99% according to research conducted on behalf of former Council member Joan Beardsley in April 2006 by Patrick Mason, Legal Consultant with the Municipal Research & Services Center of WA (MRSC). In other words, City Council could and should immediately consider raising the park impact fee to cover up to 99% of the costs associated with accommodating growth.
Finally, we must have faith in - and encourage - those we have elected to do the right thing while meeting this challenge head on.
(The following questions are for you, the reader.)
Q7: Are you aware of any other plausible explanations for this thousand acre dilemma?
Q8: What other solutions should city officials consider?
Next: Part 2 – Bellingham’s land supply: deception, lies, and videotape
* Note: The Park Plan chapter of the Bellingham Comprehensive Plan indicates that the city intends to increase its park system acreage to 5,369 acres as of 2022; however, this amount includes 337 watershed acres that are outside the boundaries of the city and its UGA. Adjusting for these 337 watershed acres, total projected park system acreage within city limits as of 2022 is 5,032 acres.
The 2008 Park Plan update indicates that the park system will be increased to 4,043 acres within city limits as of 2022. This represents a reduction in projected parkland to be acquired of 989 acres (5,032 – 4,043), or 20% (989 / 5,032). For purposes of this article, 989 has been rounded to 1,000.