Thursday, October 1, 2026
A reader opinion appeared on The JOLT News on Feb. 2, claiming that a proposed UGA Swap by Bar Holdings, known as Salish Landing, (“Bar Holdings/Salish Landing”) would hurt Tumwater’s budget and make housing less affordable. In asserting her position, the author makes incorrect statements and excludes important information.
The Bar Holdings UGA swap proposes reducing the total size of the Tumwater UGA by removing approximately 65 acres near the north end of Black Lake in exchange for adding 46 acres at the intersection of 93rd Ave SE and Old Highway 99 SE.
The author alleges that the proposed UGA swap would harm Tumwater’s budget because the city would have to subsidize future connections its sewer system within the adjacent Melody Pines mobile home park (which is already within the city) even though there is no indication these septic systems are failing or contaminating groundwater. This assertion is preposterous in many ways, including:
1. The future water and sewer infrastructure needed to serve the area proposed for removal from the UGA would (be) boring a sewer main under Percival Creek and it would also be lengthier and more expensive than what’s required to serve the Bar Holdings/Salish Landing expansion area given the expansion area’s closer proximity to existing city utilities. Thus, completing the swap would reduce the overall future length of Tumwater’s water and sewer systems and eliminate at least two costly sewer lift stations — actions that also reduce long-term system maintenance costs.
2. All new development is responsible for extending water and sewer utilities “to and through” projects at the expense of the new development. Bar Holdings/Salish Landing would be responsible for extending water and sewer mains to its future development. Further, new development is responsible for paying both connection charges and system development fees for water and sewer.
3. The Bar Holdings/Salish Landing project would extend sewer utilities proximate to the Melody Pines Mobile Home Park, which the proponents of Bar Holdings/Salish Landing have pointed out would enable these homes (and others in the area) the ability to convert from septic systems (which are proven to be environmentally damaging if not properly maintained) should those systems fail. Connection would not be a requirement.
4. The utilities that Bar Holdings/Salish Landing would be required to extend to serve its development are already identified in future city capital facilities plans because they are necessary to serve future development in the UGA that will be adjacent to the Bar Holdings/Salish Landing proposal. This swap creates significantly more efficiency than the extensions (though planned) that would be necessary to serve the area that would be removed from the UGA.
The author claims that the Bar Holdings/Salish Landing proposal would pave over 33 acres of CARAs and threaten groundwater that is needed for salmon runs in the Deschutes River. But what the author doesn’t share is:
1. Most of Thurston County (both inside and outside cities) is classified as a CARA.
2. The proposed UGA swap would result in an 18 acres net reduction of CARAs within the UGA.
3. The 65 acres the swap proposes to remove from the UGA are located adjacent to Black Lake and along Black Lake Ditch and Percival Creek — waters that flow into Budd Inlet and are likely habitat for the Oregon Spotted Frog (a federally recognized threatened species). In fact, this reduction in the Tumwater UGA along Black Lake is consistent with a recommendation in Goal B.2 of the EPA funded 2015 Black Lake Basin Study Final Report, which seeks to protect and improve water quality.
Next the author incorrectly argues that adding to the supply of available housing doesn’t improve affordability and that Tumwater’s UGA already has 20% more housing capacity than it needs. However, the author neglects to inform readers that:
1. The Thurston County Buildable Lands report she cites was issued in 2021, but its analysis relies on land capacity maps from 2017 and population and employment forecast data from 2018 and 2019. Further, it only looks at whether Thurston County (and in this case Tumwater) has the land capacity to support its 2035 target allocations for population and employment as established by the 2015 comprehensive plans. In sum, the author’s argument is based on old data and maps — some of which are nearly a decade old.
2. The current conversation about comprehensive plans and UGA swaps involves looking at the next 20 year planning horizon and determining whether Tumwater has the land capacity to support new, higher population, employment, and housing targets. And in Tumwater this also means considering how much of the current, developable land supply the city will need to set aside under the city’s future habitat conservation plan (HCP).
3. Washington’s Supreme Court (in a case involving Thurston County) has previously found that counties and cities are required under the Growth Management Act (GMA) to size UGAs sufficient to accommodate projected growth plus a reasonable land market supply factor (aka safety factor). Moreover, the state’s Growth Management Hearings Board, as early as 1995, has found that market supply factors of 25% or less are reasonable.
4. If increasing housing supply doesn’t improve housing affordability, as the author suggests, then why has the (Washington) State Legislature spent the last several sessions passing an incredible amount of housing legislation aimed at increasing the supply and diversity of housing?
While the author is correct that the Bar Holdings/Salish Landing property is currently outside the service boundary for Intercity Transit, (the author doesn’t) mention that most of the area proposed to be removed from the UGA is also outside the transit service area. Further, in stating that transit needs densities of at least “seven to 12” dwelling units per acre the author doesn’t mention that:
1. The residential areas between the airport and the Bar Holdings/Salish Landing proposal consist of single family medium and multifamily medium zoning and allow densities between 6 and 15 dwelling units to the acre with actual developed densities exceeding the minimum 7 dwelling units per acre (du/ac) not as a minimum for transit. For example, the density in Bradbury Division 4 is 7.39 du/ac.
2. The proposed zoning for Bar Holdings/Salish Landing includes mixed use and general commercial, and Tumwater’s mixed use zone allows up to 14 dwelling units per acre in the mixed use zone. Again, this is a transit supportive density.
3. The proposed Bar Holdings/Salish Landing expansion at Old Highway 99 and 93rd Ave SE complements adjacent, existing patterns of development. Combined this area will have densities that can leverage future service from Intercity Transit’s redesigned system, which is now focused on serving corridors (like Old Highway 99 and 93rd Ave SE).
We agree with the author that sprawl is expensive. However, we disagree with how the author has categorized the Bar Holdings/Salish Landing UGA swap as sprawl. According to Goal 2 of GMA, the intent is to “reduce the inappropriate conversion of undeveloped land into sprawling, low-density development.” As pointed out above, the Bar Holdings/Salish Landing UGA swap proposes to trade out 65 acres that is already zoned for low densities, and which would be expensive and difficult to serve with existing public facilities (especially utilities). In exchange, 45 acres is proposed to be added to the Tumwater UGA, which area could accommodate higher densities, and is more proximate to and can more efficiently be served by existing public facilities and services.
Thus, the act of leaving those 65 acres within the UGA would promote development of currently undeveloped land into what absolutely would be sprawling low-density development in the future. The Bar Holdings/Salish Landing UGA swap is an alternative that better aligns with and balances all the goals of GMA as it would:
• Eliminate 65 acres of future low density sprawling development along Black Lake and Percival Creek.
• Locate future urban development where planned future public facilities will exist and can be provided in the most efficient manner, reducing the city’s long-term cost to maintain such facilities.
• Support development along the major transportation corridors of 93rd Ave SE and Old Highway 99.
• Complement existing patterns of development at the southeast corner of Tumwater’s UGA by providing a commercial node with transit supportive densities that can align with potential expansion of Intercity Transit’s service.
• Locate future urban development where planned future public facilities will exist and can be provided in the most efficient manner consistent with GMA Goal 1.
David Toyer is President of Toyer Strategic Advisors, Inc. of Everett and Mike Brewer represents Bar Holdings/Salish Landing.
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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RondaLarsonKramer
I will respond in more detail later, but I want to mention at the outset that the Growth Management Act prohibits this development. See https://www.upnotout.net/uga-swap-law. This reader opinion states that the development is in line with the GMA, but this isn’t correct. It doesn’t comply with the anti-sprawl provisions of the swap law. (The swap law is part of the GMA.)
Friday, February 6 Report this
jimlazar
Keep in mind that the author, Mike Brewer, has a financial interest in the Bar Holdings project moving forward. He is an owner of the land and a developer of the project.
His arguments do not hold water. The property proposed to be "swapped" is already preserved, due to steep slopes, the BPA power lines, and other factors.
This project is sprawl at its worst. It is absolutely absurd to build apartments and commercial buildings halfway to Tenino.
There is almost no chance that the purported YMCA or supermarket will be built there. There simply is not the population density in the area to support those. Nor should there be.
Tumwater annexed a huge area just a few years ago. Most of it is not yet developed. Tumwater should be REDUCING the size of their urban growth area, not increasing it.
The current president has stopped immigration almost entirely. Without immigration, the US population will be declining, not increasing, as the fertility rate is far below replacement. We don't need to tear up good forest land for development.
We need to build UP, not OUT.
https://www.upnotout.net/
Friday, February 6 Report this
MarDav
The swap out parcels by Black Lake are already preserved by the fact they are not buildable due to BPA power line easements, steep slopes, floodways and wetlands. Taking the parcels out of the UGA wouldn’t add more protections than already exist there. The Tumwater City Council meeting on February 3rd featured friends and colleagues speaking on behalf of the owner of Bar Holdings, Mike Brewer. In attendance were developers, realtors, bankers and others who would benefit economically from Salish Landing. This isn’t about whether or not the developers are “good guys” like so many stressed at the meeting. This is about expanding the UGA into the rural area, and the impacts of that, which include the current residents. This is not a development for affordable housing, which sadly is being used as a buzz word by developers. UGA swaps are concerning for all of us who have chosen to live within, and protect, our rural lands. We do not want sprawl. Build up in the UGA for smart economic growth. King County is not even considering UGA swaps because they have determined swaps provide “no public benefit.” Let that sink in.
Friday, February 6 Report this
KEW100
This development has spurred legislation in the present session to codify this poorly designed specific development here in Thurston County. The codification of this kind of UGA swap would have consequences far beyond this development and Thurston County. Specifically, SB 6016 which was co-sponsored by District 22's Senator Bateman, has been moved to the Senate floor calendar.
From these two opinion pieces, folks can discern that codifying this kind of UGA swap into Washington law is at best premature. I urge folks to write to Senator Bateman regarding SB 6016.
Information on the bill can be found here:
https://app.leg.wa.gov/billsummary/?BillNumber=6016&Year=2025&Initiative=false
Saturday, February 7 Report this
JnNwmn
I agree with some of the comments given; build up, not out.
This proposed land swap, with Thurston County, moves development of houses outside of the urban area;
which means that people will have to drive and drive to get groceries, to go to work, go to the doctor, pick up kids. This does not make sense. Plus this is not affordable housing we are talking about, this is "market rate" housing, which is expensive! I do not understand why WA State Senator Jessica Bateman would support a WA State bill that would put into law; rules allowing this type of development in WA State. She says she wants to support housing, but this is expensive housing, most people cannot afford this! This proposed UGA Land swap bill would encourage real estate developers to pave over aquifers, so important to our drinking water! Wa state is in a drought. Because of climate change, many states have this huge problem with drought; where will be get our drinking water? We cannot allow this WA State bill to go forward. I sent in my comments to Wa Senator Jessica Bateman, in Olympia, WA. I suggest that you also do this!
Saturday, February 7 Report this
kellykelly
To JnNwmn, I live on the west side of Black Lake. Would I write to Senator Bateman or to my own senator to express my opinions about this proposed development? I am adamantly against this proposal.
And to KEW100, thank you for the link to this bill.
Saturday, February 7 Report this
Porter
Greed, greed, greed.
Saturday, February 7 Report this
RondaLarsonKramer
@kellykelly, since you live on the west side, you are in Senator Bateman's district, which means your email will have more weight. You can write to all three of the LD 22 legislators and say that you are a constituent and that you do not support the UGA swap bill sponsored by Senator Bateman. Their emails are jessica.bateman@leg.wa.gov, lisa.parshley@leg.wa.gov, beth.doglio@leg.wa.gov. The more people that write to them, the more it helps stop the bill.
Saturday, February 7 Report this
RondaLarsonKramer
When a proposal requires this much explanation to justify why it’s “not really sprawl,” that’s usually because it is.
The Growth Management Act exists precisely to prevent local governments—which are routinely lobbied by developers seeking upzones—from trading long-term public costs for short-term private gains.
What Tumwater may not fully appreciate is that it has no leverage to ensure the project being advertised is the project that ultimately gets constructed. The developer has already stated to nearby residents that he does not intend to enter into a development agreement with Tumwater. There is no incentive for him to sign such an agreement either, because rezoning authority rests entirely with the County, not the City. Once the land is added to the UGA, the City bears the fiscal and service impacts without enforceable guarantees.
It is also worth noting that nothing in the proposed new zoning would require the mix of uses that the two developers are claiming they want to build. One developer’s past work has been exclusively single-family housing, and the other’s primary projects have been storage facilities. In fact, storage uses appear in the developers’ own concept materials previously shared with the media. A marked-up version of that design concept is available here: https://upnotout.net/maps#concept-design .
The design concept shows substantial commercial and retail space, but the site is surrounded by forestland and is far from established population centers. That location makes large-scale retail and mixed-use development inherently speculative. As Briggs Village illustrated, when promised commercial uses do not materialize because the customer base is not there, those elements are dropped after zoning is secured.
Saturday, February 7 Report this
JurisWhiz
One issue that has not been acknowledged is the role County leadership has played in advancing this proposal. Through a public records request, residents obtained text messages showing a County Commissioner communicating with the developer, Mike Brewer, in August 2024 and providing information to assist him in lobbying other elected officials in support of proposed UGA swap policy language that originated with the developers and that was later adopted in a UGM subcommittee meeting. That same County Commissioner later publicly claimed to have had no advanced notice that the policy language would be presented for adoption at the UGM subcommittee meeting.
Regardless of intent, this raises serious concerns about process and leverage. Tumwater does not control the rezone — the County does. Tumwater therefore cannot require a development agreement and has no enforceable mechanism to ensure that what is being promised is what ultimately gets built. Once land is added to the UGA, the City bears the long-term fiscal and service impacts without control over the outcome.
Sunday, February 8 Report this
tolerd
You'll notice Mr Brewer provided no evidence that this will provide affordable housing. His only " proof" is that the Legislature is bending over for the housing industry to relax important environmental regulations under the guise of more affordable housing.
It's a ruse, reports from the Building Industry Association of WA show that while housing development has more than kept up with population, prices and affordability continued to worsen.
There is no evidence that more supply will bring more affordable housing and this project will likely do little, if anything, to bring more affordability.
Monday, February 9 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
KEW100
kellykelly you are welcome! And it makes my heart go pitter patter to know that it helped someone make an informed decision. Even better when I agree with the decision.
And I am not paid by The Jolt, but I hope y'all know what an invaluable service this is. This civil, informative exchange is so rare on line. As such, helping out this platform with a few $$ would be great.
Wednesday, February 11 Report this
Yeti1981
There is a lot of emotion in this thread, but not much discussion of what the Growth Management Act actually says about UGA swaps.
The 2024 amendment to RCW 36.70A.110 does not prohibit swaps. It allows them under specific conditions. The statute requires no net increase in total UGA acreage or development capacity. The land added cannot be long term agricultural, forest, or mineral resource land. There cannot be a net increase in critical aquifer recharge areas inside the UGA. The added land must be suitable for urban growth. Transportation and capital facilities must be identified and financially supportable. The land removed cannot already be urban in character. The revised boundary must be contiguous and cannot increase pressure to urbanize rural lands.
That is the legal framework. Not a slogan. Not a website summary.
So when it is stated that the GMA prohibits this development outright, that overstates the law. The statute does not ban edge swaps. It sets criteria. The real question is whether those criteria are met.
If 65 acres are removed and 46 are added, acreage decreases. If the removed land is low density fringe and the added land is corridor adjacent mixed use, then the capacity calculation becomes a numbers exercise. If there is a net reduction of CARAs within the UGA, that satisfies the aquifer provision. If the added land is contiguous and aligned with planned infrastructure corridors, the claim that this automatically increases rural pressure is not a settled conclusion. It is an argument that would need to be proven.
On the fiscal issue, new development is required to extend utilities to and through the project and pay system development charges. That is how growth financing works in Washington. If the swap shortens future sewer extensions and eliminates lift stations that would otherwise be required to serve the Black Lake acreage, that is a legitimate capital planning consideration. Examining infrastructure efficiency is not trading long term public costs for short term gain. It is responsible planning.
On the idea that the Black Lake parcels are already preserved, there is a difference between constrained land and permanently protected land. Slopes, easements, and wetlands limit development form. They do not remove zoning capacity. Removing land from the UGA does.
On affordability, no one is claiming this is subsidized housing. It is market rate supply. But arguing that supply does not matter contradicts both basic economics and the direction of state housing policy over multiple legislative sessions. Market rate housing alone does not solve affordability. Constraining supply in a high demand region certainly does not lower prices.
Build up not out is a phrase many of us agree with in principle. The harder question is whether existing infill capacity is actually producing housing at the scale required. Paper capacity and deliverable units are not the same thing. That is why the statute allows a reasonable land market supply factor.
If the concern is leverage or development agreements, then that is a governance discussion about interlocal agreements and capital facilities alignment. It is not proof that the swap itself is illegal.
Every stakeholder in this debate has an interest. That includes developers, environmental advocates, rural property owners, and city governments. The Growth Management Act is designed to structure those competing interests within statutory criteria.
The serious question is whether this specific swap meets RCW 36.70A.110 and whether it aligns with long term fiscal, environmental, and housing planning goals.
If opponents believe it fails the statute, the Growth Management Hearings Board exists to make that determination.
But declaring it prohibited before that analysis is completed is advocacy, not law.
Wednesday, February 11 Report this
Yeti1981
SB 6016 does not eliminate groundwater protections or authorize unlimited expansion. The bill retains the no net acreage rule and the no net CARA rule. It clarifies how swaps are evaluated during the periodic comprehensive plan update. You can oppose it as a policy matter, but it does not gut the environmental guardrails people are describing.
Wednesday, February 11 Report this
Yeti1981
On the process concerns. Stakeholders circulating draft policy language to policymakers is not unusual in land use. Environmental groups do it. Business groups do it. Neighborhood coalitions do it. If there are Open Public Meetings Act or SEPA violations, those belong in a legal forum and should be addressed there. But characterizing routine pre-meeting lobbying as proof of a rigged system requires more than advocacy language.
Wednesday, February 11 Report this
RondaLarsonKramer
@Yeti1981, regarding the Open Public Meetings Act issues, thank you for mentioning that law. As you recall, Councilmembers Dani Madrone and Eileen Swarthout issued minority reports because of process concerns with the UGM subcommittee meeting in August 2024 in which the agenda was amended and a policy decision was voted on all in the same meeting, with no notice to the public or to the staff members of the various jurisdictions.
Regarding your comment about whether BAR Holdings meets the requirements of the swap law, there is no interpretation of the law that is needed. It's a simple application of the law's provisions. The swap out parcels contain BPA powerline easements, steep slopes, and floodways. One cannot build urban density in such locations, 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. Presumably she will try again next session.
Instead of trying to poke holes in urban growth area boundaries, wouldn't it be better if we all put our energies into helping Tumwater have a town center? For example, Rep. Parshley and Rep. Doglio are both co-sponsoring HB 1742. It seeks to help communities redevelop distressed urban properties, including the Tumwater brewery location.
That's something to celebrate. I'm so grateful for Lisa and Beth's leadership on that bill. And I'm grateful for Senator Bateman's middle housing bill previously. Likewise, I'm grateful for Councilmembers Madrone and Swarthout for issuing a minority report in 2024 due to process concerns. These are all examples of responsible actions by elected officials.
Friday, February 20 Report this
Yeti1981
@Rhonda, I agree with you on one narrow point. If a swap results in a net increase in development capacity inside the UGA, then it fails the statute. That part of the law is straightforward. Where we disagree is the assumption that constrained land equals zero capacity.
The swap law does not say that parcels with slopes, floodways, or easements have no development capacity. The legal test is a before and after capacity calculation across the entire UGA boundary. Zoning capacity is compared, and constraints are accounted for through the buildable lands analysis. But the statute does not treat every constrained parcel as if it carries no capacity at all. Saying one side is constrained and the other is easier to build does not by itself prove a net capacity increase. That requires actual numbers.
So if the claim is that the swap increases capacity, the straightforward way to demonstrate that is to show the math. What is the total allowable capacity associated with the 65 acres being removed once constraints are deducted, and what is the total allowable capacity associated with the 46 acres proposed to be added under the planned zoning? That comparison is the legal test.
The same applies to the other provisions of the statute. The law prohibits a net increase in CARA acreage within the UGA. It does not prohibit swapping parcels with different CARA classifications if the overall acreage decreases. And the question of whether a revised boundary increases pressure on rural lands is something that must be supported by findings in the planning record.
On SB 6016, the bill did not eliminate groundwater protections or authorize unlimited expansion. The core guardrails remained in place, including the requirements for no net increase in UGA acreage and no net increase in CARA area. People can certainly oppose the bill as a policy matter, but it did not remove the statutory standards you are citing.
I agree with you that investing in Tumwater’s town center and redeveloping distressed properties is worth pursuing. That is a policy discussion many of us support. But it is separate from the legal question of whether a particular swap meets the criteria in RCW 36.70A.110. If opponents believe those criteria are not met, the Growth Management Hearings Board exists to evaluate the record and make that determination. Until that analysis is completed, stating that the violation is “undoubted” assumes the conclusion before the capacity calculations and findings are actually shown.
Tuesday, March 10 Report this