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2025 Bellingham Comprehensive Plan: Housing
How the City redefined “housing” to make the math work.
What the City Says
The City calls the 2025 Comprehensive Plan a “balanced approach” to housing—promising more choices, more affordability, and more “middle housing.”
In practice, the plan eliminates detached single-family homes as a growth category. The City now defines housing as:
“Single-Unit (attached or detached)” — a phrase that lumps duplexes, townhomes, and ADUs together with traditional detached homes.
This redefinition inflates housing diversity on paper but hides the reality that detached homes are no longer part of the City’s growth strategy.
What’s Missing
Nowhere in the Plan’s Housing Element or the Land Capacity Analysis will you find a category for “Single-Family Detached.”
Detached homes have been erased from the City’s growth tables and replaced with generic terms like “single-unit” and “middle housing.”
The City’s own numbers project just 981 new detached homes, er "units"?, through 2045—housing for fewer than 2,500 residents in a plan that anticipates 33,000 new people. That’s not housing diversity—it’s engineered scarcity.
The Ownership Void
The Plan’s affordability model ends at 120% of Area Median Income (AMI)—about $100,000 a year. But in a city where the median home costs $700,000, even a 120% AMI household can’t buy.
In other words, the Plan models rental housing, not ownership.
Detached homes are labeled “exclusionary.” Homeownership is treated as an afterthought.
“Bellingham’s housing plan ends at 120% AMI—about $100K a year. The median house costs $700K. So who’s the plan for? Everyone except the people trying to buy a home.”
“Bellingham is using yesterday’s map to justify tomorrow’s policy—counting land that won’t exist once the County approves the Plan.”
The Phantom UGAs
The City’s growth math is based on Urban Growth Areas (UGAs) it plans to delete after adoption. Here is a map of the city where the OLD MAP is still being used. Here's the issue:
This is the "map" that 20 years ago ALL the 15 UGA "would be annexed by 2025"
Guess what? Only 133 acres of 775 were ever annexed for residential development.
These unannexed areas inflate the City’s population and land-capacity numbers. but they have no intention of ever annexing them.
Bait and Switch
When the County approves the Plan in 2025, those same UGAs will be removed—instantly manufacturing “scarcity” on paper. Because perversely the city has to show the map they have no intention of using, in order to get Whatcom County to approve their "UGAs" that won't be around.
The Capacity Illusion
The Plan claims 19,000 units of land capacity by 2045—but that number is theoretical.
It assumes every parcel redevelops, every ADU is built, and every fourplex replaces a single-family home.
None of that reflects real market or infrastructure conditions.
City quote (2020 PRO Plan):
“Project improvements and operations costs will be adjusted as needed to match available revenue sources concurrent with the annual Capital Facilities Plan.”Translation: infrastructure expansion isn’t funded—it’s conditional on future revenue.
The City has spent millions in “growth” fees without expanding capacity, and now it’s redefining zoning to generate more revenue without building new infrastructure.
The Reality Check
In Bellingham’s new definition, even your own home isn’t considered single-family—it’s just one of many “attached or detached units” in a continuum.
The 2025 Plan isn’t a housing plan. It’s a density plan—built to generate fees, not homes, but perpetual tenancy.