City and County Comprehensive Plans: A Giant Jigsaw Puzzle

By David Stalheim and Cynthia Mitchell July 14, 2026

Whatcom County is in the final stages of updating

its Comprehensive Plans in

David Stalheim, WEC Secretary-Treasurer

compliance with the State’s Growth Management Act (GMA). Bellingham completed their update in December 2025. Picture a huge jigsaw puzzle framed to manage population growth, fitting together the often-competing pieces of economic development, and protection of natural ecosystems, air and water quality, and open spaces and recreation. Add to that puzzle the 2023 state law that cities and counties develop strategies to reduce greenhouse gas emissions, vehicle miles traveled (VMT) and urban sprawl, with priority attention to overburdened communities.

Bellingham Plan

In February, WEC filed an appeal of the Bellingham Plan to the Growth Management

Hearings Board on the grounds that

Cynthia Mitchell, WEC Board Member

the Bellingham Plan failed to comply with GMA requirements -- falling short of preventing sprawl and encouraging denser development in the city’s core, protecting Lake Whatcom watershed, and reducing VMT via affordable, transit-oriented development. WEC also believes that Bellingham’s Plan does not adequately account for climate-related hazards by demonstrating a reduction of emissions, particularly at its Post Point wastewater treatment plant.

Whatcom County’s Draft Plan

Similarly, WEC finds that the County’s Draft Plan draft falls short of meeting the requirements of the GMA to reduce GHG emissions and VMT and prioritize GHG reductions that benefit overburdened communities. In a letter for the Whatcom County Council’s July 16^th public hearing, WEC recommends that the County:

·       Adopt the 2021 Climate Action Plan (CAP) by reference into the Comprehensive Plan.

Specifically, the 2021 CAP recommended that industries such as Cherry Point refinery (accounting for 51% of Whatcom County’s GHG emissions, 2017) need to use new greener technologies for refining processes now, and plan to respond to future demands by reducing the production of refined petroleum products as internal combustion engine (ICE) technology and gasoline continue to lose market share.  The Draft Plan fails to incorporate these policies to require greener technologies and to reduce the production of refined petroleum products. Even though Cherry Point receives free GHG credits through 2035 and is not subject until then to the cap on emissions, Cherry Point should begin the process of transitioning away from fossil fuels to renewable energy. The CO2e data 2017-2022 indicates that industrial gas use has increased 153%. Going forward, that number should come down.

·       Revise and adopt actions to ensure that the Draft Plan meets GMA requirements to reduce GHG and VMT.

The GMA requires, not suggests, that the Draft Plan reduce GHG emissions and per capita vehicle miles traveled. The Draft Plan needs to be revised to include strong, directive policies with specific dates and targets to ensure compliance. The Draft Plan does not comply with the GMA because it will increase, not decrease, GHG and VMT.

The Draft Plan is filled with aspirational policies that are not directive or measurable. The policies fail to establish how and when policies will be implemented, and what entity is responsible for implementing the policies. For example, key goals and subsequent policies do not alter the Final Environmental Impact Statement conclusion that all alternatives will increase per capita vehicle miles traveled. The Draft Plan’s statement that the County will “support” efforts and various ways to reduce per capita vehicle miles traveled is not directive or measurable. “Support” needs to be replaced by “require”, with directives as to how and when the County will implement policies. 

·       The County should not approve the Draft Plan because it incorporates Bellingham’s adopted Comprehensive Plan (Bellingham Plan), which fails to meet GMA requirements for GHG and VMT reduction.   

GHG emissions in Bellingham increased 38% from 2022 to 2023, with yearly emissions increasing every year since 2015. The Bellingham Plan does not ensure that GHG emissions will be reduced in compliance with the GMA. The Bellingham Plan shows an increase in per capita vehicle miles traveled. The Bellingham Plan failed to adopt any reduction targets or milestones to monitor progress, instead relying on vague aspirational policies in the hopes that reductions would occur.

Whatcom County is responsible for ensuring that its Comprehensive Plan results in a reduction of GHG emissions and per capita VMT. This responsibility is coupled with the requirement to designate urban growth areas (UGAs). Bellingham also must comply with GMA climate requirements, and the Bellingham Plan’s failure to meet those requirements implicates the County’s actions with respect to Bellingham’s Urban Growth Area.

The Bellingham Plan failed to identify any targets or milestones for reducing GHG emissions. The City’s 2018 Climate Action Plan (CAP), which is not adopted by reference into the City’s GMA Plan, did set targets. The 2023 inventory shows that the City failed to meet 2020 targets and a significant change must take place to meet the 2018 CAP targets.

For the Draft Plan to meet the requirements of GMA, it must show that GHG emissions and per capita vehicle miles traveled will be reduced. WEC believes that Whatcom County should require the City to demonstrate compliance before it designates an urban growth area for the city. The City’s failure to comply with the GMA constitutes a substantial burden on the Draft Plan and helps to ensure that the Draft Plan similarly fails to reduce GHG and VMT.