Please don’t approve this proposal for the following reasons:

1) The Geology: The developed section under consideration, from reading the elevation demarcations on the site plan, has a drop of over 100 vertical feet from top-to-bottom. This is onerous stratigraphy for a development of this scale, under any conditions, and suggests that massive amounts of hydrostatic pressure from underground water will be constantly working to subvert the foundation and whatever fanatically engineered retaining wall is proposed to support the uphill slope.

Site disturbance will be significant, obviously, and even with outfalls and detention reservoirs designed into the build there seems an unruly amount of physics involved, to say nothing of wishful thinking, if the prospect of landslide subsidence is not considered for the very, very long term.

In the nearer term, the logistics of violently carving out a steep hillside in a region that gets 35-40 inches of rain per-year seems freakishly dangerous: I’m not sure how insurance premiums for the houses below will account for a D-90 front-end loader cartwheeling through their rafters.

2) Wetland Hydrology: While it is great that the developer is not using the full acreage, please do not assign this benevolence to generosity or some spasm of eco-consciousness.

The site is a nightmare for development at this scale: Aside from the cliff-like plunge from Puget to Nevada streets, the north end of the lot is an un-buildable swamp. Aside from the swamp and cliff, please note that access from Puget was considered and then rejected due to the engineering logistics involved in attempting to build a road into the site and the additional prohibitive costs of attempting to widen Puget with a required sidewalk dangling in space.

The copse of trees the developer proposes to “save,” between Puget and the proposed apartments below, are only being retained because all the laws of physics and Keynesian economics cannot validate the cost of doing anything else there: It would be absurdly expensive to build anything abutting Puget; The city of Bellingham, for over a decade, has wrestled with the same mathematics in sporadic schemes to extend San Juan Boulevard (just south of the proposed site) due to the same gnarly geography—aka, that damn cliff.

Whatever water is naturally migrating to the abutting wetlands and Critical Areas has, by now, been established and has metabolized the impacts of the existing development around it. That system of wetlands, however, will be altered by this development no matter what nifty pipes and engineered basins are installed under the buildings: You cannot snuggle five-story towers next to wetland habitats without long-term impacts. The EPA notes this in their analysis of water storage in forests and how downhill aquatic systems are impacted. Replacing an abutting mature forest with towers and retaining walls and parking lots will raise hell with the subterranean water dynamics on this site even if the presumption is that every drop of water flows majestically straight downhill, which it doesn’t.

The hydrology will change. “Saving” the uphill strip of trees is certifiably a good thing, yes, but development on this scale will alter the swamp to the north and will likely result in trophic unraveling of whatever free ecosystem functions and stormwater control it has been providing. (Note: This heading should also entail the obliteration of the existing stream, on Consolidation Ave, which I mention below in “Stormwater Impacts.”)

3) Greenways Trail Impacts: It might not be terribly obvious to those who are not fluent in the long-term goals of the Greenways program, but for decades the City has been methodically purchasing tracts along Samish Crest with the long-term goal of stitching together a trail that goes all the way to Lake Padden and the recreational mecca of Galbraith Mountain.

Since this project proposal clearly mashes as tightly as possible to the wetlands, there will be an impossible pinch-point created if ever this vision of a connected trail is considered through this tract. The Critical Areas Ordinance, to say nothing of having to dogleg violently uphill, seems like it could be highly problematic if ever the swamp below and forest above are going to be available as an uphill connection to the trail on Samish Crest—a portion of that trail is not far from where Puget smacks into Consolidation, at the top corner of this proposed development.

It might not even be viable as a north/south connector. But it would be a bummer if the prospect isn’t at least considered for the long-term.

Also, as a footnote to the larger design problems with this proposal, if a proper trail were to be installed, it might someday validate any of the currently non-existent arguments that suggest parking should be reduced since other transportation modalities are an option. They aren’t an option if there is no trail. You cannot take people’s cars away and just expect them to “figure it out.”

4) Stormwater Impacts: There is, right now, a creek that follows the trajectory where a mythical Consolidation Ave might want to go up the cliff. On a rainy day, the outfall spreads gravel and flotsam onto the street where it ends.

While Stormwater Impact Fees are surely accounted for in this development, it is worth pondering what happens when previously forested acreage, on more than a 100’ drop, suddenly becomes an impermeable mass of asphalt and concrete.

I will predict that whatever downhill infrastructure COB and Public Works currently has in place will prove to be inadequate for the additional volume of water. Furthermore, as anyone who tracks climate science might know, the data strongly suggests that we are going to see an increase in anomalous rain events coupled with our inevitable slow incineration from temperature increases, i.e. we are going to get more big-ass storms. Has the City considered that a detention pond, likely down in the basin by Lincoln Street, may need to be installed if the natural permeability and ability to absorb rainwater is removed? Will taxpayers, years hence, be footing the bill if all the spiffy underground vaults and pipes on-site at this proposal become angry geysers and the houses and streets below the hillside are impacted?

(I know the current narrative among Public Works engineers is that vaults and other underground infrastructure have ZERO impact on downstream ecosystems and species. I’d like to see the science on that. I’d like to know, for example, what the enforcement regimen looks like for cleaning and maintaining those vaults—which fill with road sludge and whatever vape pens and boogers wash off the street—and if, in the decades that these large-scale projects exist, there have ever been cases where a storm surge scours out all that toxic snot and blows it into Bellingham Bay. Surely it happens often. The ecological decimation of Puget Sound, in and of itself, suggests that it does.)

5) Housing and affordability impacts: Whatever dark corner of Satan’s rectum fermented long enough to birth the trend of “Dormitory Housing” here in Bellingham, it is sorely due for analysis and review—it is time to pluck out the furuncle and hold it close for a good sniff.

These apartments will be rented and assigned rates for each bedroom, not for the square footage of the units themselves. Out-of-town investors, including sprawling realty consortiums that are traded on Wall Street, adore this model. Aside from being packaged with idiotic waivers that void parking and density codes, the schemes ensure maximum profit will be siphoned out of a local economy, and the flexibility for developers to pin their rates to the most usuriously possible benchmark—the “market rate” per-bedroom.

In what world does that benefit the housing crisis here in Bellingham? How is this model improving home ownership, savings spent in local restaurants and shops, or expanding the range of housing options throughout the city? A casual perusal of Craigslist will show that, already, there are baked-in resources for people to split rent in a multitude of ways that are more than flexible enough to suit our population; “Roomates wanted” is one sub-heading, “Rooms for rent” is another.

By transferring the zoning gimmicks onto the public’s shoulders (in the form of parking impacts and skewed density and heinously ugly buildings) the benefits only accrue to the private developers who, owning the buildings outright, can merrily tweak and bend the “market rate” of per-bedroom housing to suite the whimsy of their greed and lack of concern for a community they have, perhaps aside from filling out permits over a long weekend a few years ago, never given a single damn about otherwise. These are large-scale projects. They are spangling our landscapes now at alarming rates. But I’ve never once heard anyone from Planning or City Council explore what the impacts are to affordability when these absentee landlords decide, from an office somewhere in Houston or Hong Kong, to dial the most accessible entry-level costs of getting shelter up or down for no other reason than they can or they want to.

I think the entire scheme of “university housing” was concocted by quants in the realty kingdom who saw a town like ours as ripe for plunder and abuse as we writhed around with zero housing stock. We got sold the dream, but they aren’t sharing the pipe.

As it pertains to this particular project, the City should be asking the simpler question of why a whole neighborhood should be required to suffer—including in lost property values (also known as tax revenues, btw)—just because Western Washington University has chosen to be utterly derelict in providing ACTUAL dormitory housing on their own gumption. If the spiffy idea was to simply metastasize the impacts of 12,000 students throughout neighborhoods, then mission accomplished.

6) Parking and traffic impacts: I’ve been on the CityView site multiple times now and, whenever I go there, I envision what it will be like to have hundreds of added vehicle trips noodling through the roundabouts and odd street vectors of the neighborhood below. These are, for the most part, single-family homes. There is nothing whatsoever that informs of an architecturally logical place, anywhere nearby, for a series of three and five-story towers.

There is, for that reason, nothing whatsoever that implies this is the sort of dense urban hub where apartment dwellers can just saunter to the store or local restaurants; it is surrounded by goddamn single-family houses on all sides, after all. Nor is it likely there’s magically going to be room for bike lanes and bus connections at the site, nor any prospect that the houses will magically become retail outlets. They’ll drive. All of them will drive.

I studied urban design and planning at WWU, eventually acquiring a Sustainable Design minor through Huxley. I was deeply involved in mayor Pike’s “MyDowntown” design conferences. I’ve been a construction project manager on multiple sites throughout the city, including at least three projects that were five stories. I served a spell on the Transportation Committee a few years back and, as it pertains to non-motorized options, two terms on the Greenways Advisory Committee thinking about trails. I’ve occasionally volunteered with Sustainable Connections on various urban design meditations and campaigns, from stormwater mitigation to, more recently, the successful adoption of the ADU ordinance.

Throughout all of these endeavors there has been a recurring thematic syntax that invokes basic design vocabularies: words like ‘scale,’ ‘massing,’ or ‘infrastructure’ are often woven into layers that consider access, public amenities, sustainability, and the other goals of so-called New Urbanism. The City, too, often prattles about these things through phrases like “The Triple Bottom-line,” and “Place-making,” and “Legacies and Strategic Commitments,” that each, in their specific way, are supposed to define the thought and purpose for why we build stuff where we do.

I cannot name any metrics whereby siting these multi-story towers in this location makes any goddamn sense. CityView just fails on every level described by the city of Bellingham’s own criteria—it is so flagrantly out of context with the parameters and language broadcast by both electeds and staff that, unless we knew any better, we’d have to assume nobody at all among these institutions has listened to themselves talk for the past decade.

Traffic, obviously, is going to be an issue on the roads weaving through these single-family neighborhoods. And, as much as I favor the ideal of making cars extinct through forced attrition, the parking models here are laughably delusional as well. Just accounting for the massive excavation and foundation work that this jobsite will demand—the hundreds of trips ferrying the dirt out and the concrete in—should be sufficient to lobotomize resale values for any home within the orbit of dust and flatulent diesel trucks that will be rumbling by for months on end.

7) Impacts to COB Long-term Density Objectives: The City has been struggling, oftentimes mightily, to find inroads for density. With equal amounts of struggle and mightiness, they often are facing alarm and opposition to their schemes in the form of pissed-off neighborhoods.

There is an administrative campaign right now, for example, that aims to boost the proper application of density in areas zoned residential multi-family—an effort to thwart builders from installing single-family homes on these tracts and, instead, build more units and more diverse housing types. Another example might be the on-going effort to introduce the Infill Toolkit into less dense areas, a goal that seems like it has been trundling along for years with limited success.

But, almost as if to undercut these sensible and progressive shifts in density, we also have malignant mutations like CityView Apartments erupting in bizarre locations. Whenever depraved levels of density somehow make it on the zoning ledger—such as Padden Heights or Chuckanut Ridge—it effectively scuttles whatever trust and communication the public might have bothered to harbor in local government. The fissures last. They last in the form of roiling resentment and angst after a long and tedious fight pitting the public against remote millionaire developers and their paid lobbyists who waft around City Hall like bad cologne. They last far longer, of course, if the ass-ugly behemoths are built and allowed to mangle the community with blight and idiocy for time immemorial.

I’d caution against any ill-advised instinct to ram this turd through approval right now. There are other, better, ways to nudge density objectives forward. And, considering that the main thought pressing hard against anyone’s mind nowadays has something to do with a global pandemic of a lethal virus, it might behoove leadership to not agitate citizens further with yet another outbreak of the Dormitory Housing strain that has already plagued us.

The smart move here would be to social distance this proposal back to where these particular prospectors are from—scrap it and tell them to bring something workable to the table in a few years.

Thanks, in advance, for denying this proposal before it goes any further.

[Note: A version of this article was submitted as comment to the city planning staff.]