The City of Bellingham's Land Use Policy Trick: Making Buildable Land Disappear.
- Brian Gass

- Oct 19
- 7 min read
Updated: Oct 22

“Now you see it — now you don’t.”In most magic shows, the illusionist hides a rabbit. In Bellingham’s Planning Department, they hide developable land.
The Setup
City planners love to talk about “limited buildable land.”They point to charts and maps that show a shrinking supply, then use that “evidence” to justify higher density, smaller lots, and new fees. But behind the curtain lies a trick that would make Houdini proud: they don’t just measure land — they make it vanish on paper.
In the City’s 2025 Land Capacity Analysis, North Yew Street (UGA 15) — once the largest reserve for future housing — shows only 125 acres of “buildable” land left. Yet when we measured it parcel-by-parcel, the same area contained over 1,000 acres, with more than 870 privately owned and physically developable. This isn’t real demand-caused scarcity in the economic sense we all know; it’s a planning illusion born from subtraction.”
How the Trick Works
The sleight of hand happens through a stack of “deductions.”
Layer these “buffers” together, and two-thirds of the land disappears — without a single bulldozer moving an inch.
Each of these may sound technical, but when combined, they erase real, buildable land — not because it’s undevelopable, but because it’s politically inconvenient.”
City of Bellingham says "Hold My Beer" when it comes to land use.
Step 1 – What the City Code really says
All of these are linear distances, not percentages. But you will see how COB Planning Department and the City will "up percentage" each requirement.
Step 2 – How planners turned those feet into percentages
Because they can’t model buffers parcel-by-parcel, staff run GIS overlays and then apply average deduction factors to whole sub-areas.Here’s how those distances roughly translate when generalized over mixed parcel sizes:
Then they layer on top:
Stormwater / ROW = +15–25 %
Market factor = +25–40 %
Result: a “composite deduction” of 50–70 % of total area once all factors stack together — even though the code-based buffers alone might only eliminate 10–20 %.
Step 3 – Example: North Yew Street UGA
So roughly two-thirds of the area was erased on paper through generalized buffers and policy add-ons — not through new environmental mapping. AGAIN: No mention of how much property the city owns or its effect on buildable lot affordability and no new development occurred between 2018 and 2025 — the only thing that changed was the math.
Step 4 – Who defines those numbers
The CAO buffer distances → set in BMC Title 16 (legally adopted ordinance).
The conversion to % deductions → set internally by Planning & Community Development staff during LCA modeling.
The decision to apply or inflate them → approved by the Mayor and City Council when they adopt the Comprehensive Plan or LCA update.
Here’s where the illusion flips.
The “Reverse” Part
In a normal magic trick, something physical disappears. In this one, it’s the definition of developable land that vanishes. Instead of starting with what exists and removing real constraints, the City starts with what it wants the outcome to be — a “shortage” — and works backward by inflating every deduction until the math fits the narrative.

Just to make sure the illusion holds, the City buys the easiest and most affordable parcels for itself — often with Greenways or Watershed funds. Those public purchases are immediately declared “protected,” permanently off-limits for housing. The result? Private builders and first-time buyers are left with the hardest, steepest, and costliest ground in town.
"When we look at the Yew corridor, especially west of Yew, the terrain is favorable and infrastructure already exists. That area would be the easiest to bring online for housing if it were available. However, most of that land is City-owned and designated for open space, so it’s not considered in the capacity model.”— City of Bellingham Planning & Community Development, Joint Growth-Management Workshop
Listen to when the planners "DON'T EVER SAY" when it comes to land use. They will never say up front just how many acres the city owns. They will say "land is City-owned and designated for open space", but they will never say what "percentage of open space" is required, or the actual percentage that the city owns. I'd say that 99% of residents in Bellingham have no idea the city owns 55% of the easiest property to develop.
The Cost of the Illusion
When land supply shrinks on paper, prices rise in reality. Impact fees climb. Permit timelines stretch. Developers pass the cost along to buyers and renters. And every time the City claims “we’re out of land,” it wins political cover to demand more density, more fees, and more control.
Capacity Implications (using the City’s own density factor ≈ 4.3 du/ac)
➡️ Even after deducting environmentally constrained parcels, the physical land area still supports several times the City’s stated “buildable” capacity. North Yew Street alone lost roughly 3,000 potential homes through spreadsheet manipulation. Multiply that by every UGA in Whatcom County, and the illusion costs thousands of families their shot at ownership.
Why It Matters
Washington’s Growth Management Act never required these inflated deductions. State law says to protect critical areas and ensure sufficient land for housing — not to erase acres because of policy preference. The “shortage” is a local choice dressed up as state compliance.
Here is the change the city made with the same UGA between 2018 and 2025. Note NOT A SINGLE PROPERTY WAS DEVELOPED BETWEEN THESE DATES.
Example: North Yew Street UGA
💬 Same land. Different math.
What looks like data is really direction. The mayor and city council set the priorities, the planning staff build the model to match them, and the public sees only the final slide deck:
“Limited capacity — time to densify.”
What the City’s Model Says vs. What the Land Shows
Pulling Back the Curtain
Once you see the trick, you can’t unsee it. Land didn’t disappear. It was deducted. And while officials insist it’s “just methodology,” the outcome is the same: fewer lots, higher prices, and a city increasingly owned by itself.
Pattern Over Time
So next time a planner says “there’s no more room for housing,” ask them to show their math. Ask how 1,000 acres became 125 acres. Ask why the City keeps buying starter-home land while preaching affordability.
Because this isn’t magic. It’s manipulation — and the cost of the trick is paid by every future homeowner who can no longer afford to live here.
Sources & Data
City of Bellingham 2018 Annexation Strategy
2025 Whatcom County Land Capacity Analysis (Draft)
Field measurements — North Yew Street UGA (2025)
Real Housing Reform Initiative Analysis
Call to Action
If you want a transparent, data-based housing policy in Bellingham, share this post, tag @RealIssuesPodcast, and subscribe at www.RealHousingReform.org. The only way to stop the illusion is to shine a light on the stage.



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