Dear County Councilmembers,

Now that Bellingham has adopted a resolution signaling its desire to work with the County on the size of its UGA, the County has a tremendous opportunity to ensure that Bellingham's Land Supply Analysis is accurate.

In summarizing his resolution, Mayor Pike noted that the analysis' underlying assumptions should be reconsidered stating, "I and others have many questions about the underlying assumptions reflected in the City's analysis. City staff has done good work analyzing the impacts of those assumptions, but concerns about the appropriateness of those underlying assumptions remain." (See Pike resolution summary below.)

I strongly urge the County to work with Mayor Pike to address the key assumptions that are clearly erroneous: 1) the UGA density assumption; and 2) the developable park acres assumption.

I will not address the park acreage here because the City is in the process of revising its adopted park level of service (LOS). One thing is clear: The City cannot afford the 47.5 acre/1000 LOS it adopted in an attempt to mollify the GMHB. The City's Park LOS in the previous Comp Plan was 35.6 acres/1000. Who in their right mind believes the City can afford to increase its Park LOS by 33%?

Regarding the UGA density assumption, I have attached a 1-page summary of CTED's instructions on how to prepare a land supply analysis and provide an adequate UGA. (See Land Supply Analysis-CTED Basic Steps below.) Here's a brief explanation of how the City erred:

Step 7 states, "Determine total capacity" by multiplying the number of acres by the number of units per acre allowed. As you know, the term capacity is defined as "the maximum number that can be accommodated." It is understood that Step 7 (Determine total capacity) requires the city to multiply the number of acres by the maximum number of units per acre allowed. However, for all parcels in the UGA, the city failed to do this. Instead, the City multiplied the number of acres by the minimum number of units per acre.

The City's logic in using minimum rather than maximum density was to allow for parcels that may not be available for development within 20 years or that may develop at less than capacity. CTED's instructions have already allowed for this "land availability reduction" in Step 5, and the City properly utilized this step for all parcels within City Neighborhoods. For these "City" parcels, the analysis correctly uses maximum density and reduces capacity by a 15% land availability reduction. The question is: Why didn't the City treat UGA parcels on a basis consistent with City parcels?

Regardless of the answer, now that Mayor Pike has shown an interest in getting this right, the County should as well. Now, to get to the chase...

If the City and County simply agreed to correct the UGA density assumption by changing it from min to max and changing the UGA land availability factor from 0% to 15% to maintain consistency ...

...the land supply would show that the City has a population surplus of 829 (including a safety factor reduction of 25%).

Therefore, based on this corrected analysis, there is absolutely no justification to expand the City's UGA, not even by a single acre!

I am happy to provide you with the City's Excel spreadsheet so you can see this for yourself.

If you have any questions or would like to meet, please email or call.