Still a Dormitory, Still in Non-Compliance

• Topics: Bellingham, Planning, WWU,

[Our Guest Writer, Linda Diebert, spent the first years of her career teaching young children here in Bellingham. She changed careers and became Transit Planner, Principal and Co-owner, TransitPlus, LLC, Boulder, Colorado; Former Executive Director of Via Transit, Boulder, CO. She is a trained, long-time Pranic Energy Healer. In retirement, she is an avid reader, volunteers at Hospice House, tends her large veggie and flower gardens and makes quilts and dotes on her three grandsons.]

Mr. Morgan Bartlett’s company, Madrona Bay Real Estate Investments, has finally submitted the updated CityView Complex application. Property owners and residents of the Puget Neighborhood will be severely and negatively impacted if CityView is built, despite its resubmitted format. In August of 2019, the City of Bellingham gave Mr. Bartlett a very
specific list of issues in its Notice of Incomplete Application document. It basically had a list of 30 items that had to be addressed to allow the proposed development to move forward. Several of those issues were either addressed partially or not at all.

Mr. Bartlett submitted his updated application and states that the overall goal is to provide safe, affordable multi-family housing. However, it is clear that he is creating a “boarding house” or dormitory structure that will not meet the needs of families and especially, low-income families. While his proposal says this development will provide “a significant option for low-income residents currently living without amenities” and says it will address “the current short supply of multi-family infill housing,” it is far more likely this development will be another student housing option that appeals mostly to Western’s students.

At the Lark apartment complex on Lincoln, nearly all (95+%) of the three-bedroom apartments (with bathrooms attached to each bedroom) are rented to Western Washington University students. Current rent estimates of $800-$900/month, per bedroom, would put the cost of renting one of these apartments far out of reach of low-income families; however, it will definitely attract college students. It is noted that Mr. Bartlett’s new proposal has removed any wording that might point to this fact. Plopping a college-based dormitory complex in the middle of a neighborhood surrounded by single-family homes is not good growth management in any neighborhood. It is simply in-fill for the sake of increasing density at the expense of the neighborhood and families who live in the area.

Two-bedroom apartments in the Puget Neighborhood are currently renting from approximately $1,200/month. A three-bedroom CityView apartment will rent from $2,700 per month. If Bartlett legitimately wants to build “apartments” for low-income families, the layout design needs to remove the bathrooms attached to each bedroom, decrease bedroom sizes, increase the communal living space and provide one bathroom. CityView is nothing more than a college dormitory.

In this dormitory setting where three unrelated students are cohabitating in one unit, it is more than likely all three students will be upper-classmen, most of who, own cars. The industry standard of 1.5 spaces/per apartment unit is woefully inadequate to meet the need. Overflow parking will spill out into the immediate neighborhood. If CityView were truly being built for low-income families, the parking plan would likely work. Anecdotally, we currently observe three to five cars parked outside each of the student rental homes on upper Nevada/44th St. The overflow-cars park on the street—and occasionally in the street. It should also be noted that the students who live in rental homes on 44th (upper Nevada), almost without exception, drive from Nevada to the park-and-ride at the bottom of the hill on Lincoln St., or directly to Western Washington University. This is especially true in the dark, winter months or on stormy days. Mr. Bartlett’s assertion that all students will be walking to the park-and-ride is simply nothing more than wishful thinking without a study to support this assertion.

Bartlett’s project narrative has been revised to include three buildings, rather than the one large building in the initial proposal. It is absolutely appalling that the revised CityView submittal still has a six-story apartment building, Building C, as part of the development plan. A six-story building (66-feet in height), is completely out of place with the culture and character of the Puget Neighborhood. There are no other six-story residential apartment buildings in the Puget Neighborhood, other than the Lark, (multi-family apartment complex on Lincoln Street). In fact, all the homes surrounding the proposed development are single-family homes of one and two stories. Building a six-story structure here is like locating a building that is twice the height of City Hall in the Puget neighborhood.

This building will, in fact, be visible from Puget, Nevada, and Consolidation streets as well as many other streets in the Puget and surrounding neighborhoods. While it may or may not actually obstruct views from Puget St., light and noise pollution will be significant in Puget and Nevada streets as well as others in the neighborhood; the developer did not address this issue. If CityView is constructed, the building will be visible even from Interstate-5 and most likely, from many more locations in town. It will dominate the view looking up-hill. The building is 353-feet in length, as long as Civic football field, including the track. It will not enhance neighborhood character, nor preserve it as required by Policy LU-4 of the Comprehensive Plan - Protect the unique character and qualities of existing neighborhoods, while identifying opportunities for improved livability, safety, and housing affordability and diversity (see aerial photo of the proposed site above). It will, in fact, destroy the character of our neighborhood.

Currently, Bellingham Municipal Code, 20.38, contains no expressed height standards except for buildings located within 200 feet of a residential zone that is not designated “Planned.” Instead, the planning director could impose a height restriction that would conform to the comprehensive plan, the existing development, and protect neighboring properties. The building proposed by CityView is approximately 65.5 feet in height, far taller than the surrounding one-and two-story homes. The impacts for noise simply cannot be mitigated with vegetation when sound travels both uphill and down.

In response to the city of Bellingham’s Notice of Incomplete Application (August 10, 2019), there are a number of critical areas in the Site Plan that were either completely ignored or only partially addressed by Mr. Bartlett in his submittal. One of the most egregious omissions includes an updated geohazard study. The City required that a new geohazard study for the CityView proposal be completed, prior to resubmitting a revised plan. Clearly, this requirement has not been met since the former geohazard study was done in 2013, for the proposed University Ridge development. A new cover letter on the 2013 document does not meet this requirement.

Additionally, drainage flow on all parts of the property is another area that was only partially addressed by the revised submittal. It is Mr. Bartlett’s opinion that he does not need to address the significant drainage issues on the north end of the property. These drainage issues are particularly evident when it rains during the winter months. There are trees at the north end of the property that are leaning “down-hill” because of the instability of the soil. This is where a proper and more extensive geohazard study would be useful.

While the revised plan for CityView appears to have met the basic request for a tree retention plan, there are concerns. Plans call for retaining approximately 50% of the current trees. But according to certified arborist Patrick Sullivan, a percentage of those trees are likely to become destabilized. He suggests removing all but six of the largest Douglas Firs from the entire property. He also states, “If the City wants all of these trees retained, the trees should be monitored on an annual or semi-annual basis once construction begins.” The question is, will the city, or the developer, be responsible for these initial and on-going inspections?

Mr. Sullivan has also advised the removal of most of the trees on the western border of the property, behind the homes on Nevada St. This will result in little to no privacy buffer from the proposed open-space, trail, benches and picnic areas that are to be built instead. The removal of existing trees will result in more noise and light pollution for Nevada residences. Bartlett’s proposal shows that he will plant trees along the western boundary of the “open space;” however, he will be removing the conifers that are currently there and replacing them with primarily deciduous trees—that are leafless for six or seven months of the year. This significantly impairs residential privacy, will increase light pollution, noise pollution, and simply does nothing to address privacy and noise issues. For the homes on the north-end of Nevada and Marionberry Ct. there are no trees, only native grasses and mounds of blackberry bushes. Will any trees be planted?

City View Site Plan
City View Site Plan

The City has required that CityView buildings reflect the existing neighborhood. Homes in the Puget Neighborhood are basically one and two-story dwellings. Mr. Bartlett erroneously contends that the homes in the neighborhood are from one to three stories—there are no three-story homes. He is wrong to think Buildings A and B are consistent with the homes surrounding the development. However, even more troubling, is the five-and-a-half story Building C. As stated earlier, there is absolutely no similarity to this structure in the one to two-story homes flanking the entire development. This building is simply out of scale with every dwelling on this hill. A building twice the height of City Hall would be out of place in any residential neighborhood.

The proposed “Juliet” balconies for each apartment will create sound and noise throughout the neighborhood, especially in the warmer months. As observed from student rental homes on upper Nevada, loud music is often heard coming from those residences and travels downhill throughout the streets of the neighborhood. With 106 Juliet balconies, there will be a significant increase in noise, which will travel up to both Puget and Nevada streets and well beyond.

It is this writer’s contention that for a variety of reasons, this application should be permanently denied. It is fairly clear that the developer has completely failed or partially failed to address several of the areas requested by the City in the Notice of Incomplete Application, dated August 10th, 2019. Based on this alone, the application should be denied by the City.

Additionally, this is clearly not an apartment complex for low-income residents as Mr.Bartlett states over and over in his submittal. It is nothing more than a dormitory, with amenities that appeal to college students at Western. The average cost of renting one of these apartments is $2700+ per month. This cost for basic housing is far out of reach for low-income families. The industry standard of 1.5 parking spaces per apartment is unreasonable with three unrelated adults living in one unit. This will result in street parking on all of Nevada, Consolidation, 44th, 43rd and 42nd streets, Blueberry Lane, Marionberry Court, and Marionberry Lane.

Planting primarily deciduous trees simply will not mitigate the noise and light pollution. The building heights, with the added slope of the property will significantly disrupt the privacy of the homeowners in the area.

All of these issues aside, the single most important reason this application should not move forward is the issue of density. The Puget Neighborhood challenges the historical assumption for the buildable density of 176 units in the Hawley Replat—Tract F. While Mr. Bartlett is proud of the fact that he is building under that assumed unit density or 176 units, his proposal is woefully over the only documented and definable density for this tract of 8.7 units per buildable acre. See the February 6th letter from the Puget Neighborhood’s Attorney, Mr. Phillip Buri.

NB: The city is accepting comments on this project through this Friday, 8 May at 5PM. Click here for information on commenting.

About Guest Writer

Citizen Journalist • Member since Jun 15, 2008

Since 2008, this moniker has been used over 130 times on articles written by guest writers who may write once or very occasionally for Northwest Citizen, but not regularly.

Comments by Readers

Tip Johnson

May 06, 2020

“Densification”, a city objective espoused by both Bellingham mayoral finalists in our last election, may require reexamination as immunity to covid19 remains in question, mutation is being further documented, functionality is unknown and possibly evolving, and the single best correlation with contagion is urban density. 


Dick Conoboy

May 06, 2020


Yup.  That “rule of three” is looking a lot different now, eh?


Gaythia Weis

May 07, 2020

As the former president of the Puget Neighborhood association at the time of the previous University Ridge proposal I strongly agree that relying now on the geohazard study done in 2013 is a big mistake.

My opinion at that time was that the geohazard study prepared for University Ridge seemed inadequate.  It is my understanding that the neighboring properrty, Hawley Open Space was set aside because it contains wetlands. In other words, highly  likely to be undevelopable.  These wet areas, obviously on the side of a ridge, may exist because of springs origniating from aquifer containing rock layers that become exposed to the surface there.  There is a seasonal stream that runs down through the property proposed for development.  All this moisture seems to be making the large trees, with underlying ferns and other moisture requiring vegitation, on these properties very happy, and they, in turn slow and absorb some of this water that would otherwise continue to flow down towards Lincoln Creek. Lincoln Creek already has flooding issues. So large scale development here has the potential to affect areas downstream from the Puget neighborhood.

These same rock layers and their associated groundwater aquifers seem to me to be highly likely to extend beneath the property proposed for development.  It was my concern back then that the soil depth sampling done seemed to me to be designed to stop just as or just before that aquifer layer was unequivically detected. And, as I recall, the depth sampling did not even extend to the depth of some of the proposed footings for the buildings and associated retaining walls.  Thus I was concerned that the developer was avoiding finding out much about the stability of the ground beneith the proposed buildings.  On a steep slope, that might even include potential for landslides.  This new developer ought to be reaquired to do a new and very complete geohazard survey.

(While I do have an undergraduate degree in geology, I am not a geohazards expert, which is exactly why I believe that the developer should hire someone with that recognized expertise, and that City officials charged with evaluating reports from those with such expertise ought to do so carefully and completely.).

I think that the City of Bellingham could also do a better job at functioning as an overall community. It does students no favors to have the housing designed for them to be so far from campus and related services and activities.  It defeats important aspects of the college experience, making after class and evening campus activities much more difficult.  These sorts of activities could be as important for their social and intellectual development as attending classes.

High density is appropriate and makes for desirable living space if done as part of an overall urban plan that encompasses daily life needs and activites. But not if it is plopped willy nilly here and there at the whims of a developer who has managed to pick up property at a lower price than would be the case if it were more reasonable to develop.   Outlets at such an urbanized location could include a vibrant commercial district that could absorb the energy otherwise expended on loud parties at distant housing locations.  Thus making Bellingham a more vibrant community for all.  (Once the virus issue is over, obvoiusly).

I believe that there are some obvious conclusions that ought to be drawn from the fact that this property has remained undeveloped for so long, that lead directly to the conclusion that it ought to remain that way. Or at the very least, be develped at very low density.


Dick Conoboy

May 07, 2020


A welcome comment from a former Puget resident now living afar!! 

I would like to suggest that you submit your comment to the planning office too.  .(JavaScript must be enabled to view this email address)




Konrad Lau

May 07, 2020

I always find it amusing when we have elected officials running on high density housing plans to include “low income” residents and then when the neighborhood…any neighborhood…is actually faced with living with one of these projects in their own back yard, all sorts of resistance is thrown up.

In virtually every case, the folks living in the neighborhoods voted for the officials who are now threatening their status quo. Like many in Congress, some people can never envision these changes being wrought right next door!

These are the same folks who will endlessly lecture the Great Unwashed on their own imagined moral superiority, advanced ecological ethics and how those who resist are somehow Neanderthal.

Excuses will be found to support their resistance from geologic, economic, sociologic and ecologic sources.

How about a little intellectual honesty? Just drop the subject of low income/high density housing and move on!

When I first moved to Washington over 20 years ago, I attended a town hall meeting with Representative Rick Larsen. Open comments presented a raft of complaints regarding increasing traffic in our region. One of the commentators actually said, “When we moved here, things were pretty nice. Now, everyone else is moving here and things are changing. Isn’t there something we can do to stop new people from moving here?”

In other words, I got mine and to hell with everybody else.

It would appear nothing has changed.


Linda Diebert

May 07, 2020

Mr. Lau makes a good point; however, the old NIMBY (not in my backyard) argument isn’t the focus of the article. This development is not for low-income families, it’s a dormatory for students. In addition, a great deal of the proposal is in defiance of the City of Bellingham’s own municiple code and Infill Tool Kit.  I have focused my comment on the proposal as submitted by the developer and the issues that do not meet rules set forth by the City. 

Linda Diebert



Konrad Lau

May 07, 2020

My commentary was of a generalized nature but also applies to this article.

However, it has been my experience that college dormitory type projects also attract resistance just as vociferous as the resistance toward low income housing from local neighbors. They are concerned (and rightly so) about late night noise, screeching tires, speeding cars, drunken brawls, garbage on lawns and in the streets, and cars parked outside designated areas blocking residents driveways.

Just like politicians proclaiming they in favor of low income/high density housing, you will find they are almost always supporters of college expansion. It has also been my experience that whenever politicians are in favor of construction projects, many times the are the recipient of generous campaign contributions.

I do not mean to impugn anyone specifically. I do mean to point out that many times motivations do not match advertised propaganda on both sides of an argument like this.

Case in point: The proposed Cherry Point coal terminal.


Dianne Foster

May 17, 2020

Konrad Lau,

In response to your comment that low-income housing always brings resistance from local neighborhoods,  I would point out the the old Aloha Motel site will be mixed,  low and middle income residents, provided by Bellingham/Whatcom Housing Authority,  and that all the adjoining neighborhood associations not only approved it,  but we fought for it.   Primarily that was Sehome,  York,  and Puget NA.

Dianne Foster,   former  vice-president,  Sehome Neighborhood Association


Konrad Lau

May 17, 2020

The Aloha was a known drug den and center of criminal activity that had been contaminated by meth cooking. The truely residents rejoiced when the city finally acted against that establishment but were sadly disappointed when city officials failed to knock it down and level it to the foundations. Consequently, the homeless and other less desirable types re-infested the building and within a short time, things were back to status quo without any management or law enforcement.

When given the choice between an open drug market/shooting gallery/den of iniquity and managed “low income housing”, of course they chose the latter.

There may have been celebration, but it wasn’t loud or prolonged. Instead, the local residents are holding their collective breath waiting to see how things will shake out.


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