The Bellingham Plan: Land Use Capacity

This page provides additional information related to topics covered by the Bellingham Plan. 

The Washington State Growth Management Act requires cities like Bellingham to plan for growth in a variety of ways, particularly through land capacity analyses. Each time the City’s Comprehensive Plan goes through a periodic update (most recently in 2025), the City must analyze what capacity the land has to provide for a variety of uses over the 20-year planning period.

A similar analysis is now required five years later, halfway to the next period update. Staff use this opportunity to check in on progress since the last periodic update in a “buildable lands analysis.” This analysis looks at what land has developed since the most recent update, if that land developed as anticipated, what land is still available to build upon, and what land use capacity therefore remains.

Both the periodic update and buildable lands analyses use a similar process. They use the current (or proposed in the case of the periodic update) land use map and associated development regulations and policies to assume potential build-out scenarios for each land use designation. Unique factors that might impact the likelihood of development, like the presence of wetlands, steep slopes or challenges with access, are taken into account. If land is already built out close to that potential, it is assumed that it likely would not redevelop, whereas vacant or underutilized land is flagged as having the potential to provide additional capacity for development in the city. This information is utilized to calculate assumed capacity across the city for new housing and employment within the planning period.

The results of this work inform land use policy choices. If there is not enough land capacity to accommodate anticipated growth, the City can consider changes to development regulations to increase capacity on available land. These changes might be increases in allowed building height, allowing more building area per lot, more housing units per lot, allowing conversion of existing buildings to new uses, or potentially expanding the city boundary to include more buildable land. State law encourages jurisdictions to explore regulatory changes to increase capacity inside current boundaries before considering expansion to new areas. This is because it is generally more cost-effective and better for the environment and climate to keep urban development as compact as possible. Compact growth also reduces impacts to agricultural, forest, and other resource lands in rural areas. Appendix A of the Bellingham Plan provides details on the methodology used for the land capacity analysis from the 2025 plan.

The 2025 analysis showed the following capacity, found on page 29 of the Bellingham Plan.

Land Use DesignationEstimated Housing Unit Capacity (Units)Estimated Employment Capacity (Jobs)
Residential Low6,62966
Residential Medium1,87231
Residential High1,40543
Residential Watershed354
Urban Village6,4079,202
Commercial1,3751,505
Industrial5,767
Commercial / Industrial944
Industrial / Residential Medium
Commercial /Industrial/ Residential High53554
Institutional / Residential High60
Institutional3042,770
Public / Institutional71
Public1795
Airport Operations677
Total:18,891 (Units)21,085 (Jobs)

The assumed land use capacity can be summarized by area of the city. For example, 34% of future housing growth and 44% of future employment growth is anticipated in the urban villages (2023 – 2045).

2023 Existing Development Totals

Growth AreaSingle Detached HousingMiddle Housing (2-6 units & ADUs)Multi-Attached Housing (7+ units & Group Qtrs)Total Existing HousingTotal Existing Jobs*
Urban Villages5333754,0594,96713,493
Other Areas Inside City19,5133,97717,84841,33852,762
Unincorporated Urban Growth Area1,8601046742,6384,129
Total Growth21,9064,45622,58148,94370,385
* Overall 2023 job total for Bellingham from US Bureau of Labor Statistics data. Industrial job distribution based on building square feet for industrial and resource sector uses (resource sector jobs are about 5% of total). Commercial job distribution based on a combination of available square feet for commercial uses and proportion of housing by growth area to account for home occupation uses and for work from home employment.

Estimated Growth Capacity 2023 – 2045

Growth AreaSingle Detached HousingMiddle Housing (2-6 units & ADUs)Multi-Attached Housing (7+ units & Group Qtrs)New Housing CapacityNew Job Capacity
Urban Villages68286,3116,4079,202
Other Areas Inside City7015,5373,96510,2039,003
Unincorporated Urban Growth Area1621,9192002,2812,880
Total Growth9317,48310,47718,89021,085

Totals Anticipated by 2045

Growth AreaSingle Detached HousingMiddle Housing (2-6 units & ADUs)Multi-Attached Housing (7+ units & Group Qtrs)Total HousingTotal Jobs
Urban Villages59940210,20411,20521,953
Other Areas Inside City20,1959,36721,70951,27161,038
Unincorporated Urban Growth Area2,0181,9728694,8596,777
Total Growth22,81211,74132,78167,33489,769

Washington State requirements around housing planning (particularly from HB 1220, passed in 2021) require jurisdictions to plan for and accommodate housing at a range of income levels. This means that a separate process takes place beyond the land capacity analysis described above. That analysis provides an estimated number of housing units, as well as what types of housing those might fall within (multifamily apartments vs middle-scale housing, for example).

Further analysis of these estimates allows staff to anticipate what affordability range those housing units might fall within. For instance, large single family homes are expected to be more expensive than small apartment units. Staff takes into account policies and programs, such as affordable housing incentives or federal grant programs, that may subsidize some units. They then estimate about how much capacity for housing exists in each income band.

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