COUNTY PLANNING LETTER TO ALEX WENGER

October 3, 2025, letter from Whatcom County Planning to Blaine Community Development Services:

From: Matt Aamot 

To: Alex Wenger (AWenger@cityofblaine.com) 

Cc: Mark Personius 

Subject: 2025 Update / Blaine UGA Proposal - Updated Sept 29, 2025 

Date: Friday, October 03, 2025 12:10:00 PM Attachments: Blaine Proposed UGA Expansions - Critical Areas (GIS email Sept 8, 2025).pdf GMHB FDO 2011-04-11 text searchable.pdf 

Hi Alex: 

County Planning has several concerns about the updated City of Blaine UGA/UGA Reserve Proposal (September 29, 2025), including [edited for brevity]:

LAND CAPACITY

"The land capacity surpluses cause concern relating to compliance with this requirement of the Growth Management Act."

CAPITAL FACILITIES

"Blaine’s UGA proposal indicates that City water and sewer plans will be updated in 2026 following adoption of the Comp Plan (pp. 15 and 18). Additionally, the North Whatcom Fire & Rescue Capital Facilities Plan update has not been completed. This causes concern that the capital facility information required by RCW 36.70A.070(3), relating to capital facility planning for the two new UGAs for the 20-year planning year (through 2045), will not be provided in a timely manner."

"The Growth Management Hearings Board has required adopted capital facility plans for UGA expansions. Draft capital facility plans are not sufficient."

CRITICAL AREAS

"For UGA Swaps, the GMA requires that “Less than 15 percent of the areas added to the urban growth area are critical areas” (RCW 36.70A.130(3)(c)(iii)). Critical Areas include Critical Aquifer Recharge Areas. Blaine’s proposal includes a written description addressing this criterion (p. 21). Blaine’s Proposal indicates less than 15% of the UGA expansion areas are mapped as Critical Areas by the City (Blaine’s mapping does not show any Critical Aquifer Recharge Areas in the proposed UGA expansions). However, County’s mapping includes Critical Aquifer Recharge Areas covering the entire proposed UGA expansion areas."


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