The Land Use Element
What It Is (City’s Framing)
The Land Use Element is the foundation of the Comprehensive Plan.
It establishes how land inside the City and within the Urban Growth Areas (UGAs) will be used for housing, jobs, parks, and open space over the next 20 years.
In theory, this section answers the questions:
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How much land is available for new homes?
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Where should density go?
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How will the City balance growth, livability, and the environment?
Bellingham’s 2025 draft claims to “manage growth responsibly” by directing infill toward existing neighborhoods and preserving open space.
It also asserts that the City has “sufficient land capacity” to accommodate its population target through 2045.
What the City Says
“The Land Use Element provides the overall pattern of growth in Bellingham and identifies where future housing and employment areas will occur. The Plan focuses on compact, walkable, mixed-use neighborhoods supported by transit and public services.”
On paper, that sounds responsible.
In practice, it’s how the City justifies shrinking the developable area while inflating the growth numbers it says it can handle.
The Land Use Element is the foundation of the Comprehensive Plan. It establishes how land inside the City and within the Urban Growth Areas (UGAs) will be used for housing, jobs, parks, and open space over the next 20 years.
In theory, this section answers the questions:
-
How much land is available for new homes?
-
Where should density go?
-
How will the City balance growth, livability, and the environment?
Bellingham’s 2025 draft claims to “manage growth responsibly” by directing infill toward existing neighborhoods and preserving open space. It also asserts that the City has “sufficient land capacity” to accommodate its population target through 2045.
Reality Check: The Shrinking City Strategy
Key Findings
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Capacity Mirage – The City inflates its buildable-land inventory by including un-annexed UGAs (North Yew, King Mountain, Geneva, etc.) that have little to no infrastructure.
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Annexation Paralysis – Despite listing annexation as a growth tool, the City hasn’t annexed significant land in nearly two decades.
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Fee-Driven Zoning – Density is positioned as a moral good, but it also drives higher development fees, planning revenues, and staff budgets.
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Critical Area Creep – “Environmental protection” overlays are applied selectively, removing high-value parcels from the housing supply.
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Revenue Plan Disguised as Growth Plan – Each “density increase” scenario translates to new impact-fee categories and permit revenue, not affordability outcomes.
Why It Matters
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Homeowners: expect more restrictions, higher fees, and loss of traditional neighborhood zoning without guaranteed infrastructure upgrades.
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Renters: see “infill” projects that increase density and rents, but not actual affordability.
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Taxpayers: finance City land acquisitions and Greenways projects that remove land from the housing supply, while City departments expand payroll under the banner of “growth management.”
The Reality Check
Bellingham isn’t running out of land.
It’s choosing to restrict, reclassify, and re-price it.
The Land Use Element treats housing capacity as a math problem it can manipulate—counting parcels it owns, can’t develop, or won’t annex—to produce a narrative of “sufficient supply.”
But sufficiency on paper isn’t affordability in reality.