Thursday, October 1, 2026
At its meeting on Tuesday, Feb. 3, the Tumwater City Council will decide whether to support keeping the BAR Holdings/Salish Landing urban growth area (UGA) swap on Thurston County’s comprehensive plan docket.
Over 440 people have signed a petition opposing the development. If you care about affordability, consider giving public comment at Tuesday’s 7 p.m. city council meeting. Attend in person or register with Zoom by 6:45 p.m.
Two problems should most concern council members. First, the council has been told that groundwater contamination may be coming from septic systems at the Melody Pines and Village Green manufactured home parks to the north and that extending sewer to BAR Holdings would solve this by allowing those 90 homes to hook up. This idea originated with the BAR Holdings developers, one of whom owns a well-drilling business.
No evidence of contamination has been shown. Even if there were evidence, largely fixed income homeowners there have no practical ability to pay for sewer hookups, which often cost tens of thousands of dollars per home. The city subsidizes sewer hookups in certain circumstances. But connecting 90 households would require several million dollars in public subsidy, which may be beyond what Tumwater is willing to pay.
Even more important: sewer service is essentially already at those 90 homes because it runs to the neighboring Bradbury development. Thus, BAR Holdings is unnecessary. Worse, the development itself would likely harm groundwater. It would pave over 33 acres of “critical aquifer recharge area—extreme” next to the groundwater-dependent Deschutes River. This poses a threat to salmon runs, according to a county hydrology report.
A second problem is that the development is a legal nonstarter. UGA swaps are resource intensive for cities. Pursuing it would waste taxpayer dollars. As in the case of the Davis Meeker oak, this UGA swap is likely to be overturned in court because it does not conform to statutory requirements.
Residents’ tax dollars would be better spent creating a vibrant urban core.
Supporters present BAR Holdings as a way to increase housing supply and improve affordability. But that idea is based on a misunderstanding of Washington’s growth management framework.
Under the Growth Management Act, UGAs function like a belt around a city. Outside stays rural; inside is where urban density goes.
The BAR Holdings proposal would add development capacity to the Tumwater UGA at the far outer fringe: it would swap unbuildable parcels out (near Black Lake) and swap buildable parcels in (at the corner of Old Highway 99 and 93rd Avenue).
Thurston County’s Buildable Lands Report shows that Tumwater’s UGA already has 20% more development capacity than it needs to accommodate population growth for the next 20 years. Adding even more development capacity will not increase housing supply.
If a bathtub isn’t filling quickly because the faucet is slow, making the tub bigger doesn’t make the faucet run faster. The central constraint in Tumwater is not lack of land — i.e., it has a big enough bathtub. The central constraint is lack of housing production — i.e., a slow faucet. Housing production depends on financing, labor, infrastructure and market conditions.
Instead of increasing housing supply, BAR Holdings would add unnecessary development capacity to the UGA’s fringe. This would shift new housing away from the urban core. That means 200 apartment units filled with people who will need cars to drive farther to jobs and schools.
Additionally, it would likely displace low-income people at the 90 homes at Melody Pines and Village Green because the land beneath those homes would become much more valuable to investors.
The location cannot be served by frequent transit
BAR Holdings is located outside Tumwater’s transit service area. Transit in Tumwater primarily serves the Capitol Way/state office corridor. Planning research generally finds that residential densities need to be seven to 12 units per acre along bus routes to support frequent transit service. The airport between the state offices and BAR Holdings contains no housing and will not reach densities of seven to 12 units per acre because housing cannot be built on an airport.
As a result, frequent transit service to the site is not likely for the foreseeable future. Thus, residents would be functionally auto-dependent for the long-term.
That means higher transportation costs, longer commutes, and greater household vulnerability to fuel price spikes. Low-income households already spend a disproportionate share of income on transportation. Housing affordability is not just about rent or mortgage payments. Real affordability equals housing cost + transportation + infrastructure + time. Fringe development may lower construction costs, but it increases the other three costs.
A UGA swap would also be bad for Tumwater’s budget over the long term. Low density, fringe development costs more per household to serve compared to when cities grow compactly. Cities must provide and maintain sewer and water systems, stormwater facilities, roads, police and fire coverage, parks, solid waste services, and school capacity.
Impact fees at the time of construction help, but they seldom cover the full lifecycle costs of infrastructure. Most residential development does not fully pay for itself over its lifecycle. That leads to higher utility rates, higher local taxes and fees, deferred maintenance, or reduced services.
Meanwhile, if the swap were to happen, the developers who bought the 33 acres of forestland at BAR Holdings for a mere $400,000 would be sitting on land worth millions of dollars more. If instead the swap is denied, the land stays outside the UGA and they can build only one house per five acres.
If Tumwater wants to improve affordability and protect its fiscal health, it should:
Tumwater City Council should not support keeping the BAR Holdings/Salish Landing UGA swap on the county’s docket. The proposal would raise costs for residents, strain the city’s budget, and move Tumwater in the wrong direction.
Additional documents and analysis regarding the proposal’s impacts are available here.
Ronda Larson Kramer is an Olympia attorney with a master's degree in urban planning.
The opinions expressed above are those of the writers and not necessarily those of The JOLT's staff or board of directors. Got something to say about a topic of interest to Thurston County residents? Send it to us and we’ll most likely publish it. Click here to email to us.
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JohnGear
This is such an important warning, we can only hope Tumwater council listens and considers. The pattern of development proposed with this swap is a slow-burning dumpster fire as far as municipal fiscal health is concerned — it’s only through creative accounting and ignoring the whole life cycle and attendant costs that this can be seen as attractive.
All local government officials and anyone concerned with housing affordability should read “Escaping the Housing Trap” by Chuck Marohn and Daniel Herriges, reviewed here:
https://democratizedevelopment.org/2024/05/20/book-review-escaping-the-housing-trap/
Monday, February 2 Report this
BobJacobs
Under this proposal, the public pays and private parties benefit. That's not how our governments are supposed to operate. Is there some arrangement that has not been disclosed?
Bob Jacobs
Monday, February 2 Report this
Skywarrior-Pilot
Ronda,
Thank you for the excellent description of how the Urban Growth Act is supposed to work. Tumwater has caved to developers in the recent past, hopefully this time they will support responsible growth.
Tom Fender
Carlyon Neighborhood
Tuesday, February 3 Report this
Yeti1981
This piece sounds technical and responsible, but it rests on several assumptions that do not hold up in the real world.
First, the claim that Tumwater already has 20 percent excess capacity misses the central point. The Buildable Lands Report measures theoretical zoning capacity. It does not measure what is financially feasible, permitted, infrastructure ready, or actually buildable. There is a massive difference between paper capacity and units that can realistically be delivered. Anyone who has worked in land use or development understands that entitlement timelines, environmental constraints, infrastructure timing, interest rates, and construction costs dramatically shrink what can actually be built.
Second, the bathtub analogy is flawed. Housing production is not water passively filling a tub. It is capital flowing toward viable projects. If you create a site that is feasible, serviceable, and financeable, it increases the odds that units actually get delivered. If you rely on sites that look good on a spreadsheet but are constrained in reality, production slows. Adding viable land inside the UGA can absolutely matter.
Third, the argument assumes growth is fixed and zero sum. It is not. People are coming to this region regardless. If Tumwater blocks feasible sites, that growth shifts to other jurisdictions or further into the county. That does not protect affordability. It constrains supply and pushes people farther out.
Fourth, the fiscal argument relies heavily on a Strong Towns theory that residential development does not pay for itself. In Washington, impact fees, utility connection charges, property tax revenue, and long term valuation all factor in. Multifamily housing generates significantly more tax revenue per acre than low density rural land. Comparing 33 acres of planned urban land to one house per five acres is not a serious fiscal comparison.
Fifth, on groundwater and sewer. If aging septic systems are a concern, coordinated sewer extension is an environmental improvement, not a threat. Saying sewer is essentially already there because a line exists nearby ignores the real cost and coordination required to extend service. That is exactly why a structured project matters.
Sixth, the transit argument needs perspective. Much of Tumwater is auto dependent today. The relevant question is whether housing inside the UGA near existing infrastructure is better than pushing development into truly rural patterns. Two hundred units inside the urban boundary is not sprawl. It is planned urban growth.
Seventh, the displacement claim is speculative. Rising land value does not automatically equal eviction. Manufactured housing parks are governed by state law, and protections exist. That conversation should be had honestly, not used as a blanket reason to block development.
Finally, framing this as public pays and private benefits ignores how housing actually gets built. Private capital assumes risk to deliver housing the public says it wants. If we make it impossible or impractical to do so, we should not be surprised when supply falls short.
If Tumwater is serious about affordability, the answer cannot be that we zoned enough land on paper. The question is whether we are willing to allow projects that can actually get built. That is the real test.
Tuesday, February 3 Report this
RondaLarsonKramer
@Yeti1981, you’re right that housing only gets built when the market is willing to build it — i.e., when it is "financially feasible." But local government planning policies determine what is financially feasible. When cities make sprawl easier than infill, markets predictably choose sprawl.
Your comment illustrates one approach to growth: a hands-off posture that lets development occur wherever it pencils. But whether cities are hands-off or hands-on, they are still shaping the market. If cities fail to direct growth into existing urban areas, it becomes financially feasible to build in rural areas. If cities actively direct growth into urban areas, it becomes financially feasible to build in cities.
You have written in the past, "Eliminate the need for cars by focusing on building housing density and services in the city." I agree. We have the power to determine what is financially feasible for developers. Through our planning choices, we can decide what kind of communities we build — and what kind of future our descendants inherit.
Wednesday, February 4 Report this
Yeti1981
@RondaLarsonKramer, I think we need to be very clear about something fundamental in your comment.
Local governments do not determine what is financially feasible. They influence it. And too often, they influence it by adding cost, delay, and uncertainty.
Feasibility is math. It is land cost plus entitlement time plus carrying costs plus impact fees plus construction cost plus financing plus risk. When those inputs exceed what the end buyer or renter can pay, the project does not move forward. No amount of policy preference overrides that equation.
Cities shape feasibility primarily through regulatory structure. Permit timelines. Design standards. Impact fees. Concurrency requirements. Infrastructure phasing. Environmental review layering. Appeals risk. Each of those may have a policy rationale. But cumulatively they increase the cost per unit.
That cost does not disappear. It shows up in rent and home prices.
So when you say cities can “decide what is financially feasible,” what that often means in practice is cities can decide how expensive and how risky it is to build. They can remove barriers and make projects more viable. Or they can add friction and make them less viable. But they cannot simply declare that infill will pencil if the inputs do not support it.
And this is not a “hands off versus hands on” environment. Washington operates under the Growth Management Act. UGAs are mandatory. Rural densities are capped. Concurrency is required. SEPA is required. Impact fees are authorized. This is already a deeply managed system.
The Salish Landing proposal is not opening rural land to unregulated sprawl. It is a UGA swap tool specifically authorized under RCW 36.70A.110(8). The statute allows boundary refinement when patterns of development create pressure exceeding available developable lands inside the UGA.
That legal phrase matters. Available developable lands. Not gross zoning capacity.
Even Tumwater’s own planning documents acknowledge that not all vacant land is realistically available due to environmental constraints, ownership fragmentation, and infrastructure timing. If the County can demonstrate that development pressure is outpacing realistically available land, and that the swap results in no net increase in capacity, then the statute permits it. If they cannot, it should not move forward.
But the debate should be grounded in that statutory test and in real land supply analysis.
You referenced my past comment about reducing car dependence by building density near services. I agree with that goal. But achieving it requires projects that can actually get built. That means aligning regulatory structure with economic reality.
We cannot regulate our way into affordability. Every added layer has a cost. Every month of delay has a cost. Every new requirement has a cost. Those costs compound, and ultimately they are borne by the household trying to buy or rent the home.
Planning absolutely shapes markets. But it does so largely by raising or lowering the barriers to entry. If we want more housing inside the urban framework, we need to be honest about that dynamic.
Intent does not produce housing. Feasible projects do.
Wednesday, February 4 Report this
RondaLarsonKramer
@Yeti1981, in fact, BAR Holdings does not comply with the anti-sprawl provisions of the UGA swap statute, and it is not a close call. For one thing, the statute allows UGA swaps only when the swap does not increase development capacity. BAR Holdings would increase Tumwater’s UGA development capacity. A plain-language explanation of the ways BAR Holdings violates the swap law is here: https://www.upnotout.net/uga-swap-law
And while you describe Washington as a “deeply managed system,” what we are seeing on the ground is proposals that do not meet statutory standards being advanced by local governments anyway. BAR Holdings is a concrete example of that problem.
Regarding SEPA, I routinely see local governments approve projects based on SEPA determinations that do not comply with the law.
Laws only “deeply manage” us if they are actually followed.
Wednesday, February 4 Report this
JohnGear
A really insightful Strong Towns essay on “The Impact Fee Illusion” by Dan Herriges, co-author of “Escaping the Housing Trap.”
https://www.strongtowns.org/journal/2026-2-4-the-impact-fee-illusion
Tuesday, February 10 Report this
Yeti1981
@RondaLarsonKramer The swap statute is being summarized in a way that overstates what it requires.
The law does not require a UGA to be “bursting at the seams.” It requires a finding that patterns of development have created pressure exceeding the amount of available developable land. Available developable land is not the same as gross zoning capacity on a map. It requires a real analysis of what can actually be delivered.
On development capacity, the statute prohibits a net increase in capacity. That is a math exercise. It requires a side by side calculation of total allowable units before and after the swap. Calling one site “buildable” and the other “constrained” is not the statutory test. Zoning capacity controls unless legally extinguished.
On groundwater, the statute prohibits a net increase in CARA acreage inside the UGA. It does not prohibit swapping moderate CARA for extreme CARA if the total acreage does not increase.
On rural pressure, the analysis turns on contiguity and whether the revised boundary increases outward urbanization pressure. That is a planning determination that must be supported by findings.
If the County cannot support those findings with evidence, the swap will not survive review.
But declaring that it “clearly violates” the law without walking through the capacity math and boundary analysis is advocacy, not a final legal determination.
Wednesday, February 11 Report this
RondaLarsonKramer
@Yeti1981, the swap out parcels contain BPA powerline easements. One cannot build urban density in such a location, and so when one swaps that land out of the UGA and swaps land into the UGA that is not so constrained, the development capacity of the urban growth area undoubtedly increases, thus violating the statute. This is one of the ways the BAR Holdings swap clearly fails the statutory requirements.
Senator Bateman's UGA swap bill this session (SB 6016) would have helped BAR Holdings overcome some of the statutory obstacles. Thankfully, it died today. Presumably she will try again next session.
Wednesday, February 18 Report this
RondaLarsonKramer
@JohnGear, thank you for your insightful comments and for bringing attention to “Escaping the Housing Trap”. I will definitely look into it.
Wednesday, February 18 Report this