The city is still moving forward with its Waterfront District Sub Area Plan without review and analysis of waterfront wildlife impacts.  The public's repeated requests for a supplemental review have fallen on the administration's deaf ears.  Jack Weiss was listening however, and last Thursday, he attempted to introduce amendments that would have required some type of review.    

The hope and belief that this had the Mayor's support were dashed when the planning department adamently opposed the Weiss motion, claiming that it would be duplicative of work that was already done in 2004 for the SMP Characterization and Inventory.  This assertion is so patently false, it is difficult to imagine how it could have been made in good faith.

Among the reasons that the SMP Characterization and Inventory is not a replacement for a real EIS review:

  • Many parts of the waterfront district are governed under the GMA and the city CAO, rather than the SMP.
  • The Characterization and Inventory fails to analyze terrestrial species.   
  • The Characterization and Inventory fails to address issues of habitat connectivity, whether aquatic or terrestrial.
  • The purpose of an EIS review is to determine development impacts and analyze if and how impacts can be mitigated. The Characterization and Inventory addresses only opportunities for restoration.
  • The Characterization and Inventory discusses potential shoreline species, without specifics or quantification.  Imprecise, general information does not create a baseline standard for measuring and monitoring ecological function.     
  • Information in the Characterization and Inventory is insufficient to protect biodiversity.  For example, the Inventory review for the shoreline from Bellingham Plywood to the south end of Cornwall landfill, stated, in full:

Potential PHS/TSE Species: Bull trout presence is possible and presence is based on suitable habitat and prey. Bull trout are federally listed as a threatened species. Puget Sound Chinook and Puget Sound coho salmon may occur seasonally within this segment. Puget Sound chinook are federally listed as a threatened species. Puget Sound coho salmon are a candidate species for federal listing. Marbled Murrelets may occur seasonally offshore along this segment. Marbled Murrelets are federally listed threatened species.

Wildlife: Potential mustelid and pinneped habitat may occur along the entire shoreline of this segment. There is documented regular harbor seal use of logs for haul outs off the Georgia Pacific site and along the outer rock bulkhead of the marina and GP lagoon. California sealion use of a dock in the I/J waterway is recorded and confirmed by NES staff. Caspian terns and Glaucous-winged gulls are documented to use the roof of the Bellingham Cold Storage and Marina buildings. High winter concentrations of diving birds occur in the marine waters along this segment.Surf smelt spawning beach is recorded within the marina inner harbor along the eastern beach and the north side of the I/J Waterway. Low to moderate populations of crab and pandalid shrimp are documented offshore of this segment.

I sent a letter to the city council and asked them to have the staff respond to the following questions before accepting the adminstration's contention that a supplemental EIS is unneccesary and duplicative.

  1. How will it use the SMP to determine the impacts from waterfront development when this was never reviewed?
  2. How will it determine compensatory mitigation necessary to meet no net loss standards? Does it intend to provide any compensatory mitigation?
  3. How will it protect biodiversity without documentation of all species present in the waterfront district, and information on the size and health of each species population?
  4. The restoration projects the staff points to from other programs are focused on nearshore fish species. What will the staff do for all other species, such as seabirds, marine mammals and invertebrates?
  5. How will the city determine a measurable baseline standard and monitor changes in ecological function?
  6. What about the parts of the waterfront under the jurisdiction of the GMA?
  7. The SMP and the CAO are concerned with habitat fragmentation and isolation of species. How will the staff address this without any review of habitat connectivity issues?
  8. How will the staff ensure that waterfront development is not a barrier to migration corridors on land, sea and air, and prevent harmful habitat sinks?
  9. How will the staff ensure that the shoreline habitat buffer widths are adequate for the species present?   
  10. How will the staff mitigate for impacts from increased commercial and recreational marine traffic?
  11. How will the staff mitigate for impacts from increased intensity of waterfront use and activity?

How disappointing to see our own city act like a greedy developer unconcerned about the impacts of its actions or its legal obligations. The staff’s refusal to analyze and plan properly has recklessly endangered our waterfront plants and wildlife.  The city is avoiding its legal obligation to protect and mitigate because this is expensive, and it requires waterfront land that could have otherwise been developed for profit.  But to deliberately mislead the council, knowing that the technical complexity of this issue would leave the council without the ability to evaluate the administration's claim, hits below the belt. 

The council has decided not to conduct a public hearing following its relatively minor waterfront district plan revisions. It is not technically obligated to do so because it held a public hearing at the very beginning of its review process.  Still, its failure to provide a formal hearing after a lengthy review process on a very controversial plan feels undemocratic. 

I encourage the public to show up and voice its opinion during open sesssion at the next council meeting, on November 18th. There are many other problems and concerns with this plan, including the failure to include a community agreement for working wage jobs.  However, for those of you focused on habitat issues, the questions that I have raised provide talking points regarding the need for a waterfront wildlife analysis.  If you are unable to testify at the meeting, the record is still open for public comment.