BLAINE INDUSTRIAL UGA REZONE DEFICIENCIES

TO: Whatcom County Planning Commission 

FROM: Otto Pointer, Water Planning Matters 

DATE: February 26, 2026 

RE: East Blaine UGA Industrial Rezone – Wetlands, Flooding, and Infrastructure Deficiencies 

Major deficiencies in the East Blaine industrial proposal 

The Planning Commission has already found that the land Blaine proposes for its East UGA is “substantially more impaired by Wetlands and Buffers” than the area being de-annexed and that development in this UGA “will require a massive investment to create wetlands mitigation credits.” Despite those findings, the City has not supplied the basic information the Commission requested. Specifically: 

1. No current, site-specific wetland mapping has been provided for the full 263-acre rezone area, even though City and County documents acknowledge “forested wetlands,” “naturally occurring ponds,” and “several wetland complexes” in East Blaine. 

2. No quantitative summary of wetland, stream, and flood-prone acreage, or any depiction of how these constraints reduce net developable land, has been presented. 

3. No assessment of the likely cost of wetland mitigation and stormwater/flood control needed to support industrial development has been prepared, notwithstanding the Commission’s concern about a “massive investment” in mitigation. 

4. No infrastructure cost estimate or funding plan shows who would pay for the roads, utilities, and drainage necessary to serve industrial uses on this constrained site or whether industrial development can realistically carry those costs rather than shifting them to Blaine ratepayers and taxpayers.

PDS’s February 17, 2026 staff report already recommends that the Commission not support the 263-acre UR-4 to LII rezone at this time and notes that regulated critical areas in this location could affect the feasibility of the desired level of industrial development. 

Wetland mitigation and flood management: significant cost exposure 

The Planning Commission’s January 22, 2026 letter correctly recognizes that development in the East Blaine UGA will require “a massive investment to create wetlands mitigation credits” and asks the City to identify how much mitigation will be required, where it will occur, what it will cost, and whether development can actually support those costs. The City has not provided: 

1. An estimate of wetland acreage likely to be affected by road extensions, building pads, and utilities in the 263-acre area. 

2. A planning-level estimate of mitigation requirements using its own adopted mitigation ratios (for example, 2:1 or 3:1 for Category II and III wetlands). 

3. Any order-of-magnitude cost range for mitigation, whether implemented on-site, offsite, or through purchase of mitigation bank credits, nor an indication of where mitigation is expected to occur.  

4. An analysis of how frequently flooded or poorly drained soils will affect stormwater design, flood management, and associated costs for industrial uses with high impervious cover. 

5. Typical wetland mitigation and long-term monitoring costs can reach into the millions of dollars for multi-acre impact scenarios, and stormwater and flood control for industrial sites in wet, low-lying terrain also add substantial capital cost. If those costs are not realistically evaluated now, they risk being shifted onto Blaine ratepayers and taxpayers when industrial development does not fully materialize or cannot bear the level of investment assumed.

Infrastructure uncertainty and taxpayer risk 

County planning policies require that land designations and UGA decisions consider land capacity outside critical areas and buffers and the cost of infrastructure needed to serve urban development. Yet, for the East Blaine rezone area, the City has not identified: 

1. The major transportation, water, sewer, fire protection, and stormwater facilities needed to support industrial build-out in this UGA, particularly in light of the extensive wetlands and flood-prone areas. 

2. The expected division of costs between private development and public capital budgets, rates, or taxes. 

3. Whether the net developable acreage remaining after subtracting wetlands, streams, and frequently flooded areas is sufficient to generate the industrial tax base needed to pay for those improvements. Without this information, the Commission cannot determine whether the proposed industrial UGA is economically realistic or whether it would create long-term financial obligations for Blaine residents without delivering the anticipated industrial capacity.

Recommendation 

The Planning Commission should recommend denial of the proposed rezoning of the 263-acre East Blaine UGA from UR-4 to Light Impact Industrial at this time. The proposal does not quantify mapped wetlands, streams, frequently flooded areas, or buffers and therefore does not demonstrate how much land is actually available for industrial development; it provides no planning-level analysis of wetland mitigation needs or costs, despite the Commission’s expressed concern that development here would require a massive investment in mitigation; and it offers no estimate of the public and private cost of roads, utilities, and stormwater facilities needed to serve industrial uses on such a constrained site or who would pay those costs. 

Before any revised industrial rezone proposal for East Blaine is considered, the City should return with: 1. Updated mapping and acreage totals for wetlands, streams, frequently flooded areas, and required buffers across the entire 263 acres, so that net developable land can be clearly understood. 

2. A planning-level assessment of wetland mitigation and stormwater/flood management needs and costs, including indicative mitigation ratios, mitigation locations, Habitat Conservation Areas and order-of-magnitude cost ranges. 

3. A planning-level estimate of the infrastructure required to serve industrial development in this UGA, together with a clear description of which costs would be borne by developers and which could fall on Blaine ratepayers and taxpayers.