Lake Whatcom has been infested by Asian clams, and 9 invasive plant species, and no solution has yet been identified.  In fact, an aquatic invasive species protection plan has not been completed.  Our highest priority should be to protect the interests of 100,000 residents who rely on the Lake for drinking water.  We need a temporary moratorium on shoreline development that carries a high risk of introducing invasive species until there is a funded plan for the prevention, management and control of aquatic infestation.

Proof of this is found on the City’s website.  The City issued a “Notice of Application and Optional Determination of Nonsignificance” under the State Environmental Policy Act (SEPA) for a dock to berth kayaks at Bloedel Donovan Park.  See http://www.cob.org/cob/Pubnot.nsf/%28vwluUNID%29/5A82AC55B2AF476A88257967006F8A6A/$file/Notice%20of%20Application.pdf. (To be clear, this is not just a City issue.  The County would have handled this in a similar way.)

This dock was previously at the WWU Lakewood Recreational Facility and is being relocated to Bloedel Donovan.  It will first be installed near the boat launch, and then moved to a location near the Electric Avenue Bridge. Of particular concern, the applicant, Whatcom Rowing Association, competes in racing competitions, taking its kayaks to different water bodies.

When mapped out, the hot spots of Asian clam infestation in Lake Whatcom correlate with watercraft launches, and it is no surprise that Lakewood has one of the worst infestation problems on the Lake. This confirms what science has already established. The risk of invasive species infestation and re-infestation increases with shoreline modification and recreational use of watercraft.

Each time a kayak enters another waterbody and returns to Lake Whatcom, it carries a risk of introducing aquatic invasive species.  Even re-infestation of an established species is a problem. Asian clams likely spread throughout the Lake through multiple infestation events.  In areas already infested, this allows an invasive species, such as clams, to expand, making control efforts more challenging and expensive. 

The environmental impacts considered during a SEPA review of Lake Whatcom shoreline applications must now include the costs of prevention, clean-up and control of invasive species.  Additionally, the TMDL and required water quality clean-up plan should be incorporated into the SEPA process because all invasive species impact the aquatic ecosystem, degrading water quality. The Asian clam is infamous for its water quality impacts.

When the kayak dock was installed at the Lakewood Facility, the City was not aware of an Asian clam infestation, or the connection between the infestation and the kayaks. However, adequate environmental protection requires review, determination and mitigation based on current conditions. Relocating the dock from Lakewood to Bloedel should not be treated as an environmental “like-kind” exchange.

However, use of the SEPA Optional DNS process indicates that the City has predetermined that the project will likely have no significant environmental impact. This is clearly an incorrect determination.

The Optional DNS process reduces the time for public notice and comment, as well as the right to a public hearing on a matter that impacts water quality for 100,000 Whatcom County residents.  Given the potential impact of the kayak dock on Bloedel Donovan Park and the Lake, and the lack of progress that has been made in protecting and restoring the Lake, there should be a public hearing.

The public can submit comments on the SEPA application until January 16, 2012 at ssundin@cob.org.  My recommendations for comments include:

·         The City should provide a public hearing on the SEPA review.

·         The City should prioritize the public’s interest in drinking water before any other use of the Lake.

·         This application, and other shoreline development that facilitates the use of recreational watercraft, such as new or redeveloped docks, should be denied until the City and County have instituted a funded and effective plan to protect the Lake from invasive species, and to control or eradicate the invasive species.  

·         There should be a public discussion on whether it is still appropriate to have recreational watercraft on Lake Whatcom after the Asian clam infestation, which also increases the risk of invasion by quaddra and zebra mussels.

·         The 2009-2010 Lake Whatcom Monitoring Program annual report reflects an accelerated rate of water quality degradation that requires urgent action.  We must err on the side of extreme caution with regard to allowed uses for Lake Whatcom and its shorelines.