RECEIVED
To:
Bellingham Planning Commission
Date: June 3, 2015
Re:
UGA Recommendation to City Council
JUN 0 4 2015
City of Bellingham
Planning & Community Development
Dear City of Bellingham Staff and Planning Commission,
Thank you for this opportunity to provide Bellingham with important information relevant to
the reactivation of the Yew Street Reserve UGA to Urban Growth Area status. The wide ly
acknowledged fact is that Bellingham is in need of bui ldable land, especially single-family zoned
land, and has reached the much discussed "trigger point".
HISTORY
The entire Yew Street UGA has a long history as an important part of Bellingham's growth plans.
Indeed, current Bellingham planning documents such as the Comprehensive Plan, Water
Comprehensive Plan, and others fully plan out development for the entire area. The Yew Street
UGA Reserve, surrounded on three sides by the Bellingham city limits/UGA, is currently served
with numerous urban amenities such as city park land, stormwater controls, si dewalks, bicycle
lanes, flashing pedestrian crosswa lks, sewer, water, police, and is served by f ull time, 24/7 fire
service. The Yew Street Reserve also contains urban residential development. To quote t he
Bellingham UGA proposal in 2009, "The Yew Street UGA has been in Bellingham's UGA since
1997 and in the City/County approved urban service area since the mid-1980s. For nearly 30
years, property owners have had an expectation that their property would be annexed and
developed to urban densities. The County, City, Bellingham School District, and private
property owners have invested in infrastructure in t he area in anticipation of urban
development and eventual annexation ."
STAFF CONFIRMED THAT THE YEW STREET RESERVE MEETS BOTH PRIMARY CRITERIA FOR
INCLUSION
During your meeting, as noted by your Planning Director mult iple times, the Yew Street Reserve
meets the criteria for reactivation within the Bellingham UGA. You have been told that it is
good growth management planning for the Yew Street UGA Reserve to be included within the
Bellingham UGA, and that the area will help to provide the detached hou sing type that
Bellingham is sorely lacking. Of paramount importance, you r staff gave you two primary
criteria, "Growth Demands" and "Presence of Urban Levels of Development." Only the Yew
Street UGA Reserve meets both of those primary criteria. In addition, the Yew Street Reserve
contains the land for multiple planned for arterials designed to provide access for in-city infill
development, UGA development, and emergency services access inside the city and throughout
the north and south UGA. This wi ll also enab le a live/work/play situation for teachers,
students, parents, and others that would like to live within walking distance of their school,
park, golf course, restaurant, and other recreationa l activities such as fishing, cycling, and
hiking. Because there is already functioning WTA transit service and bicycle lanes (with more
planned), there is also opportunity for this area to help economically support downtown and
Fairhaven with less impact to our transportation system.
ACTIVATING A UGA RESERVE IS NOT CONSIDERED UGA EXPANSION BY THE COUNTY OR BY
THE COUNTY COMPREHENSIVE PLAN
In discussions on May 13, 2014 at the Growth Management Co-coordinating Council regarding
the activation of several UGA Reserve areas around the County, Executive Jack Louws and Long
Range Planning Manager Mark Personius explained the following: Executive Louws stated that
he doesn't think a UGA reserve should require TDRs because the county considers them more a
part of the UGA of a city than other areas. Long Range Planning Manager Mark Personius
stated that their comp plan doesn't view the activation of a UGA reserve as a UGA expansion.
There is an important distinction between adding new UGA lands and removing the reserve
status from UGA lands, especially land that has been partially built out to urban density, with
many urban services such as a one of the largest and most popular parks in Bellingham
containing a golf course and restaurant adjacent to the UGA Reserve, a walkable school, transit
lines, bicycle lanes, sidewa lks, a flashing pedestrian crosswalk, and elementary school, even a
fully staffed 24/7 fire station providing service at an urban standard, specifically because it was
urban growth area.
CURRENT RESEARCH AN D DATA SHOWS THAT DEVELOPMENT HAS NOT HARMED LAKE
PADDEN
Concern over Lake Padden water quality was the stated reason the former County Executive
placed the South Yew Street UGA area into reserve status, pending further testing (against the
wishes of the City Council to leave it as active UGA). Lake Padden is a heavily used recreational
lake located in Lake Padden Park; stocked with trout for sport fishing purposes, and is located
next to the City owned Lake Padden Golf Course. The requested further testing has been
completed with help from Huxley College, and the City of Bellingham. The conclusion ofthis
testing is, "Lake Padden 's water quality appears to be stable at this time. There currently is no
trend towards a worsening of the lake's water quality that we can detect through our study."
Lake Padden water quality is stable and has been for many decades. Lake Padden was originally
tested for phosphorus in 1974 by "Dion et al", with the lake having acceptable levels of total
phosphorus or "TP". Recent testing found phosphorus levels to be similar to 1974, even be low
the measureable limit during the same timeframe. In addition, it has been concluded that Lake
Padden exhibits the same historic seasonal pattern, called "fall turnover" now, as the lake did in
the 1970s. Of special note, the Lake Padden watershed was only 1% built out in 1974,
compared to now. The strict stormwater controls in place are doing their job very well.
Recently, Bellingham has adopted even more strict standards, contained in the newest Ecology
Stormwater Manual.
The sole reason for the 303(d) listing is due to persistent organic pollutants found in planted
sport fishing trout residing in Lake Padden. Since listing Lake Padden and many other lakes with
planted fish, the departm ent of Ecology has investigated this issue and documented in Ecology
Publication 06-03-017, that PCBs found in planted trout are the byproduct of the feed used at
Washington Department of Fish and Wildlife hatcheries. The conclusion states on p.31, "The
positive correlation between feed and fish !PCB and between feed and fish !DDT supports the
conclusion that feed is the primary contaminant source to hatchery fish."
The main sources of contam ination identified, in addition to the contaminated hatchery fish,
are park and recreation related, with the City of Bellingham taking action over the past few
years to reduce pollution inputs from park users.
Contained in the draft environmental impact statement, the only up to date environmental
analysis you have to rel y on at this time, are maps with which you can compare several
different environmental aspects of the UGA areas you are looking at. First is Figure 3-2 "Critical
Areas Bellingham". You will see that while both the UGA Reserve and potential new UGA area
have critical areas, they are much less than most of the rest of the UGA area analyzed, with the
Yew Street Reserve having very little. The next map is Figure 3-12 "Biodiversity Relative
Conservation Values". Com paring the Yew Street Reserve to other areas, you will see there are
no "high" biodiversity areas, while other UGA areas such as Dewey Valley and the potential
northern UGA area conta ins a significant number of areas rated "high" for biodiversity value.
We know all of the commissioners care about the environment and wildlife and believe this is
another reason the Yew Street Reserve should be taken out of Reserve status and annexed into
the City sooner rather than later.
STAFF AND PLANNING DOCUMENTS SHOW THAT MANY OF THE COSTLY ITEMS ARE NOT
ASSOCIATED WITH THE ACTIVATION OF THE YEW STREET UGA RESERVE
The activation and annexation of the Yew Street UGA Reserve differs from the potential new
UGA area in the north beca use the Yew Street area will help pay for the many projects City staff
have told you must happen whether or not the Reserve is annexed. The Samish Neighborhood
Plan adopted in 2007, calls out the need for a school and a city run fire station in the area. The
fire station is necessary to serve the existing, under and un-served Samish neighborhood, which
contains a large portion of vacant single-family land inside the city limits (infill), the North Yew
Street UGA area, and Lake Padden Park. Although adequate EMS and fire service benefits
everyone in the city, a fire station built in the Sa mish neighborhood would benefit by having
more development within the LOS reach. According to City planning documents, the station is
required for infill development within the current city limits and is to be built somewhere near
the Yew Street UGA Reserve along with access roads, to provide fire service to the current
Northern Yew Street area, the Samish neighborhood, Lake Padden Park, and when annexed,
the South Yew street area. Activation and annexation of the Yew Street UGA Reserve will
increase the number of people within the LOS reach, maximizing tax dollar efficiency. The
current Comprehensive Plan, the one you are upd ating now, also contains analysis of police
need in this area, concluding that the type of development would produ ce a very low call
volume - call volume is the LOS the city has chose n to use as discussed in the Comprehensive
Plan as well . This is similar to the fire station that was bonded and built on Deemer road to
enable growth in the Bakerview, King, and Queen Mountain areas.
In 2008, the needed school faci lity was built. It is important to note, Wade King Elementary was
specifically built adjacent to our property, because of the number of families expected to live in
the area. The school district has submitted a letter regarding this decision an d reconfi rming
their position that the school was built there because Bellingham assured the district that th e
Yew Street UGA reserve would be developed with urban density family homes.
The city purchased parkland and open space in this area long ago. This means another part of
the city will benefit from reserve activation because the park impact fee and other money does
not need to be spent in parks and open space acquisition.
In sum, the only project listed in the financial model that cou ld be partially attributed to
annexation of the UGA Reserve would be the Yew Street Road improvements to urban
standards, about $5-10 million dollars according to the financial model.
CONCLUS ION
The public, via rights of way, public facilities, and urban services such as Bellingham parkland, a
fire station, and an elementary school, are the largest land owners. Ou r group of families owns
87 acres of the approximately 500 acres within the Yew Street UGA Reserve, has had an
approved preliminary plat and several others substa ntially complete and has spent
approximately one half million dollars on studies, resea rch, engineering, and mitigation all at
the request of t he city and county. The need for more land in Bellingham, especia lly for land
that provides homes for fam ilies, has been trigge red and now is the time for action. All of the
criteria required to activate the UGA reserve have been met as laid out in the County
Comprehensive Plan. There are numerous advantages that make the Yew Street UGA Reserve
the best choice for Bellingham to grow:
1. This is th e only area that meets both of the "tests" given you by the planning department both "Growth Demands" and "Presence of Urban Levels of Development." You have been told
this is valid GMA planning, the reason t he area is a UGA Reserve and not regu lar rural lands.
2. There has been much certainty as to the adequacy of the population/jobs allocation. In the
letter Bellingham sent the Cou nty originally, it states, "Bellingham's proposal is consistent with
past trends. The city has averaged annual growth of 1,527 people per year (ppy) over the last
20 years. The BERK high allocation is closest (1,562 ppy) to the past growth rate. The BERK
medium allocation forecasts a much lower growth rate for Bellingham (1,235 ppy)."
3. Our research, city plan ning documents, and staff comments to the commission show that
only a small fraction of the area wide costs wou ld be due to annexation of the reserve.
4. Properly engineered environmental protections have kept Lake Padden in pre-development,
scientifically confirmed conditi on. Development done right.
5. This area already includes many urban amenities, including a golf course and restaurant
adjacent to the UGA Reserve, a wa lkable school, transit lines, bicycle lanes, sidewalks, a flashing
pedestrian crosswalk, and one of the largest and most popular parks in Bellingham.
6. Th is area will provide much needed single-family homes into the current unbalanced mix of
land supply available now.
7. This area will not impact the Lake Whatcom Watershed and, unlike northern Bellingham,
does not impact salmon bea ring streams feeding the Nooksack.
Thank you for your time and consideration. We urge you to recommend the city activate the
Yew Street UGA Reserve tonight.
Regards,
Cal and Bernetta Leenstra
Mickey and Carole Ghio
Frank and Sandy Muljat, TAL Properties
Jim Olson, Westpac Management
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