CityView Private Dormitory Slogging Forward

In a specific and obviously sternly written request for information, the city outlined the deficiencies in the CityView project proposal.

In a specific and obviously sternly written request for information, the city outlined the deficiencies in the CityView project proposal.


[This article was jointly prepared and written by myself and Don Diebert, a resident of the Puget Neighborhood.]

It is now one year since developer Morgan Bartlett presented his plans for a large (408 bed) private dormitory complex in the Puget Neighborhood (bordering the Samish Neighborhood) at the corner of Nevada St. and Consolidation Ave. His initial submission to the city for a permit to build was rejected by the Planning Department in August 2019 for incompleteness and non-adherence to certain city codes. Since then, the developer updated the application (now for 3 buildings/318 residents) and the city accepted it as complete. However, acceptance is not approval. On July 6, 2020, the Planning Department issued a Request For Information (RFI) citing the lack of certain items of information within the documentation. Principally, the city told the developer to:

“...prepare a SEPA threshold determination, technical analysis for Planning Commission review and permit decision compliant with applicable regulations of the Bellingham Municipal Code (BMC) and Comprehensive Plan.”

The developer was given 120 days to reply to the RFI (November 3rd), although additional extensions are possible. After the developer answers the RFI, the Planning Commission will hold a public meeting to review the project and make recommendations to the Planning Department. [All project information is on the city website here.]

Overview of the RFI

The Request for Information (RFI) issued by the City of Bellingham on July 6, 2020, requires numerous actions, as quoted above, be completed by the CityView developer in order to proceed with the review and approval process. Emphasis is placed on responding to Bellingham Municipal Code Title 20 (Land Use Development), with specific references to Planned Development and Infill sections. The RFI states,

“It is strongly recommended that all responses provided to the information below (Required Actions), take in to consideration how the proposal, including any new information, addresses the specific code references [as stated].”

The take-away is that responses to the list of Required Actions must include additional detail and explanation of how the proposal meets requirements of the BMC code citations.

RFI Response Schedule

The issuance of the Request for Information (RFI) by the City to the CityView developer, introduces a new 120 day response period starting July 6th and concluding approximately November 3rd. As noted in the RFI, the response period can be extended by the Planning Director, if requested by the developer, assuming the Planning Department agrees that satisfactory progress has been made on finalizing the application.

The take-away is that the schedule is fluid, with flexibility available to the developer and the City as to schedule.

Developer Required Actions

The RFI has a comprehensive list of Required Actions for the developer. The list is extensive, including many issues identified during the recent public comment period during which over 200 comments were received. The developer is required to respond to the Required Actions in order to finalize the application.

Interested parties should review the RFI, especially the Required Actions that align with previous public comments. A key requirement of the RFI is that the developer respond to each of the public comments. The RFI states,

“It is the applicant’s burden to demonstrate how a proposal meets code and addresses public concerns. It is strongly recommended that all responses provided to this Request for Information take in to consideration how the proposal, including any new information, addresses the specific code and comprehensive plan references above.”

The take-away is that developing an understanding of BMC Title 20 (Land Use Development) and the Comprehensive Plan will provide important background for review, analysis and responding to the developer’s response to the RFI.

Puget Neighborhood Working Group – Next Steps

A Working Group of Puget and Samish Neighborhood residents will continuously monitor activity related to the CityView application, especially in communication with the City of Bellingham Planning and Community Development Department. Their goal is to keep the Puget Neighborhood, surrounding neighborhoods and interested parties updated on activity related to the CityView application.

Revised Timeline

The following is a revised timeline based on the issuance of the RFI and required response:

1. Application Status. Due to the issuance of the RFI, the Application is on-hold pending successful submission of additional information. The ball is in the developer’s court to respond to the RFI.

2. Developer Response to RFI. At the moment, the developer has until approximately November 3, 2020, to issue a written response to the RFI including completion of the Required Actions. As noted previously, this date can change at the request of the developer or the City.

3. Review of RFI Response. Upon submission of the response to the RFI, the City will determine if the information is sufficient, or if additional information is required. If the response to the RFI is deemed sufficient, the processing of the Application will resume.

4. Public Comment Period. The acceptance and publication of the developer’s RFI Response by the City, will provide a period of time for Public Comment.

5. SEPA Threshold of Determination. Prior to presentation of the application to the Planning Commission for review, the SEPA response would be accepted or rejected.

6. Planning Commission Review. The City is planning a technical analysis of the Application for presentation to the Planning Commission for review and comment. This is not a hearing but a special meeting (at the discretion of the Planning Director) to receive comments from the public and to allow the commission to issue recommendations to the Planning Department.

7. Permit Decision. Upon receipt of the completed Application and after Planning Commission review, the Planning Director issues a Permit Decision.

It is surprising to this writer that the developer continues to slog forward in the face of such vehement opposition from the neighborhoods. The Request for Information repeatedly refers to these comments and by the requirments of the RFI it is evident that this commentary has guided the RFI’s content, especially when it comes to the SEPA requirements. Equally baffling is forward movement on this project in a time of such social and economic turmoil. There are no guarantees that Western Washington University will continue to bring in enough students to fill private dormitory space. Re-purposing an apartment complex that is obviously built for a student population (each bedroom has a separate bathroom) will be difficult, if not impossible, in a failing economy.

But nothing is pre-ordained. You can add your comments about this development by writing to the Planning Department through the online comment form or to Senior Planner Kathy Bell at

As always, the above is subject to change. Spillover into 2021 is almost assured.

Attached Files

About Dick Conoboy

Citizen Journalist and Editor • Member since Jan 26, 2008

Dick Conoboy is a recovering civilian federal worker and military officer who was offered and accepted an all-expense paid, one year trip to Vietnam in 1968. He is a former Army [...]

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