There is still no resolution regarding an updated waterfront EIS analysis of plant and animal impacts.  I understand that the administrative staff is supposed to be reviewing this question, among others, and reporting back to the city council, but it is clear that they do not intend to supplement the waterfront environmental analysis.   

This remains a crucial matter.  Developers are not allowed to degrade the environment below its current condition.  And the waterfront has habitat value, largely because it is empty and unpopulated right now, creating a safe shoreline and upland space for some local species.

To determine what mitigation is required to prevent harm during and after construction, there must be a quantifiable baseline standard that is established and monitored.  That is why an updated assessment of plants and animals is so necessary.

The staff insists that there is adequate analysis based on the prior studies that have been done. Although studies might have been done, that does not mean that adequate information was developed for purposes of imposing mitigation requirements. This is an important distinction.    

For example, staff cites to the shoreline inventory developed when the SMP was updated.  However, the information in the shoreline inventory is not comprehensive or detailed, and fails to reflect the number and size of all shoreline plant and animal species. And it fails to reflect a few species of rockfish that were added to the Endangered Species Act recently. Thus, the SMP shoreline inventory can not be used to establish a baseline standard for determining changes in ecological function. Nor does it address issues regarding upland plants and animals. 

Gaps in city wildlife data are long standing and well established. The lack of adequate and updated data is reflected in the city’s 1995 and 2003 wildlife assessment, and the consultant, Ann Eissinger of Nahkeeta Northwest, repeatedly emphasized the need to fill data gaps, yet this was never done.  

Most recently, Environmental Science Associates, (ESA), the city consultant working on a draft habitat restoration master plan, noted “a significant lack of data on terrestrial habitats.”  In a memo dated 2.21.2013, the consultant stated:   

Specific data on plant and animal distributions across the entire study area was found in only two data sources: the Nahkeeta Northwest assessments performed in 1995 and 2003 and Washington Department of Fish and Wildlife Priority Habitat and Species data sets. The Nahkeeta NW data was well compiled, but may no longer reflect existing conditions. Data on species of concern (PHS and state and listed plant and animal species) is spotty and captures very few species. Information on habitat structure is also lacking. Other reviewed data originates from regional analysis on species distribution and lacks the specificity require for this analysis.

In sum, an EIS analysis is necessary to establish a baseline standard for the types and numbers of waterfront species, and to determine areas of high conservation value, connectivity corridors and areas where restoration would have the greatest impact.  If this information is not obtained, then impacts to plants and animals will not be mitigated. 

Failing to update the environmental impacts to plants and animals serves the interests of the port and city. It increases the amount of development that can be squeezed into the waterfront and maximizes the amount of land that can be sold off to developers for profit. And it benefits the developers because if impacts are not identified, it does not have be mitigated and monitored, and this significantly reduces development costs. 

This does not serve the public’s interest, however, in protecting and restoring a healthy environment.  Nor does this conform to the requirements of the CAO and the SMP.  Please ensure that the administration complies with our local laws by conducting an updated environmental analysis on local waterfront wildlife and plants.