The thousand acre dilemma: Part 1

As a community, we ‘hamsters absolutely love our parks. It’s too bad we’ll have significantly fewer to love in the future compared with the level city officials had planned f

As a community, we ‘hamsters absolutely love our parks. It’s too bad we’ll have significantly fewer to love in the future compared with the level city officials had planned f

As a community, we ‘hamsters absolutely love our parks. It’s too bad we’ll have significantly fewer to love in the future compared with the level city officials had planned for only a year ago. In fact, about a thousand acres fewer!

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.

About Larry Horowitz

Commenting member • Member since Jan 16, 2008

Comments by Readers

g.h. kirsch

Jul 20, 2008

I’ve been waiting some time for you to write this.  And you’re the one to do it.

We all knew that the planning process at the city had been gamed and corrupted to produce a result that rationalized UGA expansion.  City officials from A to Z went along with it.  An honorable minority of course objeted.

When caught and the game was exposed, the city had two choices: come clean, adjust the land supply analysis and forgo expansion; or fudge the park numbers.  The council voted to fudge.

We all knew that fudge would turn into a sticky mess.  We said the cost of the fudged LOS would create unacceptable tax burdens which, as it turns out, are actually unacceptable.  Surprise surprise.

You are entirely right.  Now the city is faced with amending their comp plan to adjust the land supply analysis, and the real need for expansion, given the some 1,000 acres they pretended they didn’t have for residential growth.

And the sooner the new mayor and council get it, the sooner they will see their duty to come to the county’s aid in the petition brought by Caitac et al challenging the decision that denied Bellingham’s unnecessary expansion.

There’s been plenty of mumbo jumbo about process, timing and whatever.  The city did the wrong thing.  Now’s the time to make it right.  Help the county.


Larry Horowitz

Jul 21, 2008

Thanks for your comments Greg.  Perhaps you should write Part 2 instead of me.  Seems like you?ve got the gist of the conspiracy theory down.

I was hoping to hear from some others by now.  Perhaps they nodded off while reading the article; it is a bit long.  The silence from our city officials ? past, present, elected and appointed - is especially deafening.

In the meantime, I thought I?d throw out another suggestion.  How about implementing an interlocal agreement regarding impact fees in the UGA?  Greg, since you seem to be the only one willing to respond, what do you think?


g.h. kirsch

Jul 21, 2008

Well Larry, I’ll defer to you to wrap up the story in your inimitable style.  I’m just a generalist.  Your command of the details is most enjoyable.  I’ve enjoyed it since you and Susan and Donna hooked up.

Suppose I’d of been more surprised if any had raised their heads on this one.  But will confess I thought John Watts, if no one else, would have disagreed with you.

As to the present council members; it’s understandable that they don’t know what to say.  And then there’s the problem most electeds have “doing the publics business in public.”

Regarding your impact fee idea;  when I see my friend Pete I’ll bring it up.  Am sure he’ll want to enter into agreements in the UGAs that have county codes coordinated with city requirements in anticipation of annexation.

Know he’ll want to see that the county contributes to the city budget for the impacts new development outside the city limits cause.

After that I’ll teach the pigs to fly!


L.S. King

Jul 21, 2008

Thanks for a great article. As a resident of the King Mountain area, I especially appreciate seeing this issue addressed.

The supposed need for additional land for development has been used to justify adding the undeveloped portion of King Mountain to the City’s UGA. Our neighborhood group has been making the case for years that the City does not need this land. This is further proof that the City does not need to rush to expand further into this area, with the huge, 700 unit development that has been proposed.

I wish we saw more of this kind of analysis in the Herald, but I am happy to be able to find it here.

For readers who do not know, part of the case that is being made for urbanizing the slopes of King Mountain is that the developer intends to “donate” acreage for a park. County Councilor Seth Fleetwood is quoted in the Bellingham Herald on July 18, as saying that the land “would otherwise cost government millions of dollars”.

I have news for Fleetwood: this acreage will NOT be free, it WILL cost taxpayers millions to provide services, schools, and roads that would be needed if this area is annexed. We might not pay directly for the park, but we certainly will pay indirectly.

Likewise, City Council member Terry Bornemann said in the same Herald article that “the project could help solve transportation problems on the north side”, because the project calls for a north/south arterial right through the heart of King Mountain.

Again, this fix will also not be “free”. And before the project can “solve transportation problems”, you first have to deal with the daily car trips of 700 households plunked down in the middle of an area that is already surrounded by heavily congested roads. I think the cure could be worse than the existing problem.

The City still needs to “solve the transportation problems” on north/south arterials such as James Street Road farther south towards Sunset Pond. The road here is narrow, with no bike lane and little room for bike riders or pedestrians. Last I checked, the area was listed as a needed road project, but no money was actually budgeted to do the work. Maybe that has changed, but I doubt it.

Residential development comes with costs to the community. And it seems that recent elections have shown Bellingham voters to prefer candidates who support growing slowly and carefully.

I hope that Bellingham leaders will take the implications of the change in LOS to the logical conclusion, and take action to rescind the addition of the King Mountain area into the UGA.

Thanks for a great article that once again points out that Bellingham already DOES have sufficient land for current and future growth needs.


Larry Horowitz

Jul 22, 2008

Thanks for taking on the interlocal agreement for impact fees, Greg.  Please say hi to your friend Pete?  Wait a minute, aren?t interlocal agreements the purview of Council?  Perhaps you should contact your friends Carl and Seth instead.

Either way, please let me know when the pigs are flying.  I?d like to get some pictures of that.


John Watts

Jul 22, 2008

Not wanting to disappoint anyone, and because I’ve now been called out by name, here’s a quick 2 cents worth:

Predictably, I do have concerns with Mr Horowitz latest missive, which appears to merely amplify his past opinions, with which I also had serious concerns.
After one prior discussion with Larry, I said that I thought it was better to be approximately correct than precisely wrong. He didn’t like me saying that then, so he may not have learned to like it now.

But, let me think about this piece for while, then I might decide to respond in some manner- maybe in a blog of my own. And, maybe not. But, in any event, I’m not planning any new full scale review, especially since others have assumed the task of carefully considering the Parks Recreation & Open Space Plan and it’s 6-year update that is currently in progress. I do have great confidence the ongoing public process and new Council will do a fine job of that.

But on the subject of pigs, I can offer a few quotes, some of which may even fit this discussion:

“Never wrestle with a pig. You both get dirty, and besides, the pig likes it.” - George Bernard Shaw

“You can put lipstick on a pig, but it’s still a pig” - Dick Cheney

“I like pigs. Dogs look up to you; cats look down at you; pigs treat you as equals.” - Winston Churchill


Larry Horowitz

Jul 22, 2008


I have no desire to enter into a power struggle with you over this issue.  However, I will repeat what I told you earlier, ?It is better to be precisely correct than approximately wrong.?  Had Council taken the time to get it right the first time, the city would not be in the fudgy, sticky mess it?s in now and would not have wasted all of the resources to promote and defend an ill-conceived expansion of the UGA.

Apparently you haven’t read the staff report on the 2008 Park Plan update.  They have essentially agreed with what I have been saying for two years now: they cannot afford to provide parks for existing UGA residents.

Whether you are willing to admit it or not, you share in the blame for the city?s failure to get it right.


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