When Is Less More?
When Is Less More?
When Environmental Impact Statements (EIS) are prepared, more than one development model might be evaluated. But a no-action alternative is always required as a baseline reference. Convention
When Environmental Impact Statements (EIS) are prepared, more than one development model might be evaluated. But a no-action alternative is always required as a baseline reference. Conventionally, this is just an empty basket, merely stating the obvious - that impacts will be less without development. Sometimes it is used to highlight the perceived benefits of development, for instance, to show what tax base or infrastructure the city would forego without development. But it could be much more.
Recently, both the Port's waterfront plans and the Fairhaven Highlands project offer examples of how valuable a meaningful no-action alternative analysis could be to the community. The trick is, of course, getting anyone to do it.
With Fairhaven Highlands, we see the only property that could be used to expand Fairhaven Park to a size consistent with the City's own standard for the population targeted for the area, the only property that can connect to and leverage the value of our substantial Interurban investments, the only property that can sustain the food chain of a valuable habitat corridor and associated salmon streams, and the only property that could transform Fairhaven Park into a Gateway to the Chuckanuts, to become a regionally significant recreational and educational resource. Wow, imagine adding all that up!
Of course, no one will. Surely not Horizon Bank. After all, they are adept accountants. They certainly know better than to account for what they rob from the community they are chartered to serve. Likely, we will not even get them to address the estimated $12 million tax subsidy their project will require. But if they would add up these values to the community in the no-action alternative, the sums would be impressive, indeed.
Down on the Waterfront, the situation is similar, but worse. Here, the developer is their own lead environmental agent in charge of overseeing the EIS. We actually pay them $7 million a year to do what they do. And the pay is enough that they can hire an "official" in charge of the environmental review who is an expensive commercial litigator out of Seattle who specializes in getting controversial projects through the regulatory process. O.K., so at least we know where we stand.
There are some interesting features to the waterfront plan. First, in the wake of GP's departure, the public currently owns a large industrial water supply to the project site and a treatment lagoon designed to receive the capacity of that supply. The Port plans to build a marina in the lagoon, rendering it useless for water treatment, leaving the water supply useless, too. A couple of points here:
You might think they would feel obliged to account for the value of the public facilities they intend to ruin. But they refuse. One might guess they would be interested in the future costs of replacing the treatment capacity we know we will eventually need. They refuse. One might wonder what it costs the community to be unable to recruit family wage jobs because that treatment capacity was squandered. They won't even talk about it. The Port has decided that commercial real estate development is more exciting than their traditional role of supporting commerce and trade. They've come a long way, baby!
These are all things that might reasonably be quantified in a meaningful no-action alternative. But they probably won't, and there's more!
Downtown suffered for decades from the development of Bellis Fair Mall. It now seems to be on the mend. How will more than 200 acres of spanking new commercial development on the waterfront affect it? Will downtown get pushed into another localized recession? What will happen to Bellis Fair, already showing signs of strain from the proliferation of other area malls? Will the Port suck the lifeblood out of existing commercial areas? Many of those do not enjoy the amenities of a waterfront, or the luxury of a tax base subsidy.
Of course, it will be a miracle if any of these questions are meaningfully addressed, but the ones they will avoid at all costs would be even more revealing:
What about doing nothing? What would a broad public waterfront add to downtown, or to places like Bellis Fair, to the City and all of Whatcom County? Is there a long-range advantage to retaining the waterfront for public and water-dependent uses? What is the value of a regional attraction that lifts all boats in our economic harbor, not just the Port's?
It could be that less is more. But it will be tough getting anyone to do a true community-based analysis.
Recently, both the Port's waterfront plans and the Fairhaven Highlands project offer examples of how valuable a meaningful no-action alternative analysis could be to the community. The trick is, of course, getting anyone to do it.
With Fairhaven Highlands, we see the only property that could be used to expand Fairhaven Park to a size consistent with the City's own standard for the population targeted for the area, the only property that can connect to and leverage the value of our substantial Interurban investments, the only property that can sustain the food chain of a valuable habitat corridor and associated salmon streams, and the only property that could transform Fairhaven Park into a Gateway to the Chuckanuts, to become a regionally significant recreational and educational resource. Wow, imagine adding all that up!
Of course, no one will. Surely not Horizon Bank. After all, they are adept accountants. They certainly know better than to account for what they rob from the community they are chartered to serve. Likely, we will not even get them to address the estimated $12 million tax subsidy their project will require. But if they would add up these values to the community in the no-action alternative, the sums would be impressive, indeed.
Down on the Waterfront, the situation is similar, but worse. Here, the developer is their own lead environmental agent in charge of overseeing the EIS. We actually pay them $7 million a year to do what they do. And the pay is enough that they can hire an "official" in charge of the environmental review who is an expensive commercial litigator out of Seattle who specializes in getting controversial projects through the regulatory process. O.K., so at least we know where we stand.
There are some interesting features to the waterfront plan. First, in the wake of GP's departure, the public currently owns a large industrial water supply to the project site and a treatment lagoon designed to receive the capacity of that supply. The Port plans to build a marina in the lagoon, rendering it useless for water treatment, leaving the water supply useless, too. A couple of points here:
You might think they would feel obliged to account for the value of the public facilities they intend to ruin. But they refuse. One might guess they would be interested in the future costs of replacing the treatment capacity we know we will eventually need. They refuse. One might wonder what it costs the community to be unable to recruit family wage jobs because that treatment capacity was squandered. They won't even talk about it. The Port has decided that commercial real estate development is more exciting than their traditional role of supporting commerce and trade. They've come a long way, baby!
These are all things that might reasonably be quantified in a meaningful no-action alternative. But they probably won't, and there's more!
Downtown suffered for decades from the development of Bellis Fair Mall. It now seems to be on the mend. How will more than 200 acres of spanking new commercial development on the waterfront affect it? Will downtown get pushed into another localized recession? What will happen to Bellis Fair, already showing signs of strain from the proliferation of other area malls? Will the Port suck the lifeblood out of existing commercial areas? Many of those do not enjoy the amenities of a waterfront, or the luxury of a tax base subsidy.
Of course, it will be a miracle if any of these questions are meaningfully addressed, but the ones they will avoid at all costs would be even more revealing:
What about doing nothing? What would a broad public waterfront add to downtown, or to places like Bellis Fair, to the City and all of Whatcom County? Is there a long-range advantage to retaining the waterfront for public and water-dependent uses? What is the value of a regional attraction that lifts all boats in our economic harbor, not just the Port's?
It could be that less is more. But it will be tough getting anyone to do a true community-based analysis.
