RECOMMENDATIONS TO WHATCOM COUNTY

December 4, 2025

Dear Members of the Whatcom County Council and Planning Commission,

I respectfully urge the Council and Planning Commission to consider the following recommendations aimed at protecting the Critical Aquifer Recharge Areas (CARAs) serving Blaine and Birch Bay, and at strengthening responsible governance and sustainable planning practices.

1.  Recommend a Moratorium on New Development Applications Affecting East Blaine and Birch Point CARAs

A temporary moratorium is a prudent and necessary step.  Water Planning Matters has recommended such a pause, and strong rationale supports it.  A moratorium would allow the County to conduct a cumulative assessment of risks, ensure long-term resiliency and sustainability, and guide land-use decisions in a manner consistent with the importance of protecting these sensitive environmental areas.

2. Recommend Establishing an Advisory Committee to Develop Recommendations for Protecting Endangered Ecosystems

Council leadership has an opportunity to initiate a solutions-oriented process to protect endangered and sensitive ecosystems, including CARAs.  Establishing a dynamic stakeholder advisory committee would enable comprehensive research, consultation with subject-matter experts, engagement across stakeholder groups, and alignment with other ongoing environmental work.  This committee should be tasked with evaluating protective options and developing recommendations.

3. Recommend that Whatcom County Not Approve the De-Annexation of East Blaine

East Blaine includes significant portions of a CARA that supplies drinking water to both Blaine and Birch Bay.  It is among the region’s most sensitive and strategically important environmental assets and has been within the City of Blaine’s limits for nearly three decades.

The City of Blaine has both a moral and legal obligation to steward East Blaine and find solutions to protect its own drinking water source.  Allowing the City to distance itself from this responsibility through de-annexation would undermine the integrity of local land-use planning and the Growth Management Act (GMA) and would set an undesirable precedent of boundary instability tied to private land transactions.

Council leadership should provide clear strategic direction to the Whatcom County Boundary Review Board.  Without such guidance, Blaine’s de-annexation request may be approved without adequate consideration of:

1.      Blaine’s responsibility to protect the water source serving its own residents;

2.      The broader regional need to evaluate and protect sensitive areas and CARAs through a cumulative and science-based process; and

3.      The importance of ensuring that Blaine remains an active participant in identifying and implementing protective solutions.

4. Recommend that Whatcom County Leadership Ensure the City of Blaine Legally Complies with the GMA and Public Engagement Requirements

As a long-time Blaine homeowner, participant on two city advisory committees and a strong proponent that public engagement is critical to government success, I am deeply concerned that Blaine’s governance processes are broken and not functioning as intended under the GMA.

The City has been in a precarious financial position for over a decade, and has become increasingly desperate for new revenue sources – perhaps more so with the recent withdrawal of Canadians.  Approving development proposals have become a critical priority for the government, and the City’s processes, procedures, tactics, and management performance have become slanted toward such approvals.  The need for affordable housing and multiplex developments appear to fall by the wayside as gated communities with large single-family homes become the desired sweet-spot.

Public engagement—legally required to be “early and continuous”— has been non-existent in Blaine.  Community members who raise concerns are routinely dismissed.  Meaningful public participation does not occur.  Despite repeated requests, the City has not adopted a public engagement strategy and appears to have no intentions to do so.  The City does what it wants and does not follow the GMA, designed to balance growth with conservation while engaging community participation.  As seen today, the City develops its own Comprehensive Plan independently, in absence of any meaningful participation from the community.  

The City’s repeated actions reinforce a clear message that public participation is not wanted or valued.  In addition, the City’s development approval process and the reliance on a Hearing Examiner all appear to compound, curtail and alienate public participation.  In Blaine it is a closed shop – residents having no meaningful opportunity to participate in planning the future of their own community.

While no independent body oversees municipal compliance, Whatcom County leadership does approve Blaine’s Comprehensive Plan.  I urge the Council to fully exercise its authority to ensure the City legally complies with the GMA and fulfills its public engagement obligations.

5. Recommend Tabling Any New Annexation Requests for the City of Blaine

The City of Blaine should not be granted any new annexation authority until it demonstrates progress and compliance in the following areas:

·         Full adherence to the GMA, including a clear plan for meaningful early and continuous public engagement;

·         Updated environmental protection standards, procedures, and checklists that meet or exceed Whatcom County requirements and incorporate best available science;

·         Adoption of the 2024 Western Washington Stormwater Manual;

·         Adoption of Whatcom County’s CARA-inclusive mapping;

·         Publication of critical-area determinations to allow public review and correction of any deficiencies in wetland studies, stormwater plans, or pollution assessments;

·         Reform of the development approval processes and SEPA appeals to ensure meaningful and inclusive public participation;

·         Modernization of outdated ordinances, procedures, and code-enforcement capacity;

·         Resolve allegations of 20+ code violations occurring on developed properties along Drayton Harbour (These allegations suggest the City is struggling to enforce violations of City ordinances and the Shoreline Master Act.);

·         Consultation with Birch Bay leadership and securing their support for any future annexation proposals (Many in Birch Bay now consider incorporation as a defensive measure to protect itself from Blaine’s overreach);

·         Restoration of sound planning practices to develop responsible proposals based on best-practices (...and trust, integrity and public transparency).

The Council may wish to consider adjusting Comprehensive Plan and annexation timelines to allow the City sufficient opportunity to complete this essential work.

Flawed Proposition

Of note, Proposition 2025-07 “Reduction of City Limits” – the City’s attempt to convince voters to support de-annexing East Blaine – appeared manipulated and misleading.  The City’s communication’s indicated a “Yes” vote:

·         Could protect Blaine’s aquifer

·         Eliminate Blaine from its obligation to pay millions of dollars in infrastructure costs that would be incurred even if there was no further development in East Blaine

·         Was necessary to enable Blaine to request other land annexation

The “Swap” was communicated as a win-win for everyone.   Most voters were unaware that:  

·         Birch Point is CARA

·         Birch Bay leadership was  opposed to Blaine’s request to annex Birch Point

·         Whatcom County leadership was opposed and voted no to Blaine’s request for Birch Point lands

·         The City of Blaine would be required to pay tens of millions in infrastructure costs for Birch Point – far more than the infrastructure costs for East Blaine

 

Thank you for your time and thoughtful consideration of these recommendations.

Sincerely,
Glen Pentland
1283 Harrison Avenue
Blaine, WA