No Environmental Considerations

April 2025 public comments to Whatcom County regarding the 2025 Comprehensive Plan include a letter regarding the proposed Blaine UGA SWAP, which notes that, "In reviewing your Study Session on the UGA Swap scheduled for April 28th, there is no mention of any environmental considerations in looking at this UGA swap. Your focus appears to be limited only to public facilities. We ask that you correct this deficiency and direct staff to identify the required open space corridors and the environmental impacts (and benefits) of any UGA swap." 

Another letter regarding county wide planning policies and water availability addresses the shortcomings of the Coordinated Water System Plan under the Whatcom County Health Department, saying, "the County Council’s discussion should take into account the information provided about water availability in the updated Coordinated Water System Plan (CWSP), which according to the Whatcom County Health Department’s website is due to be completed by December of 2025. ...We further ask that the Council, and the public, be provided with updated information as it becomes available during the CWSP update process, since the current CWSP is nearly a decade old and already shows numerous water providers, including many municipalities (Ferndale, Blaine, Everson, Nooksack), with insufficient water to accommodate future buildout as shown in the current Comprehensive Plan. 

Yet another letter regarding county planning and water notes, "We are not the ones speculating about water availability. Instead, our letter asks the County to stop speculating on water availability before adopting population projections and allocations. Our letter highlights that Lynden has publicly stated they are out of water (as are other areas), and that due to climate change water will be less available during critical months in the future. Yet despite these facts, there appears to be no consideration of water system planning currently in the County's growth projections and allocations. Because of this we support Councilmember Galloway's recommendation that the Countywide Planning Policies should reflect the Growth Management Act requirement that water is available in quantities adequate to serve future population growth. The record, thus far, does not show that this mandate is being met... It is the responsibility of local policy decision makers to design, approve, and fund solutions to these critical water issues, and the time to start working on solutions is now, not in a decade when the slow adjudication process provides more information. We are just asking that your comprehensive planning process does not continue to make things worse while adequate water solutions are being sought.

Growth projections and allocations, the CWPPs, and early and continuous public participation are all fundamental elements of coordinated growth management planning. The CWPPs should influence growth projections and allocations. Public review and comment should influence all County decisions. Instead, the Council approved (“non-binding”) growth projections and allocations without inviting public input, apparently relying solely on planning staff and the cities. It appears to be on a path to allow public comment regarding the CWPP amendments only after the Council has been told that it must approve CWPPs on an “up or down” vote. The public deserves a fair and reasonable opportunity to comment on issues of concern that will impact the public for decades to come, such as the County’s apparent decision not to follow the “most accurate” growth forecast from the state or its upcoming decision about whether to comply with the GMA’s requirements relating to water availability.