I remain concerned that the city is moving forward with waterfront development plans without an updated analysis of plant and wildlife impacts.  Unless environmental impacts are identified in the EIS, they will not be mitigated as part of the development process.  Nor does this protect plants and animals as required under the Endangered Species Act, the Washington Shoreline Management Act (enacted pursuant to initiative by the public), the Bellingham Shoreline Master Plan or the Critical Area Ordinance. Finally, it does not conform to public values.  

The staff advised the council that the EIS Addendum incorporates marina impacts on aquatic wildlife by referencing the 2007 Whatcom Waterway EIS, which reviews the marina as option 6, reflected on table 4-2 on the DOE website, attached as Exhibit B of the Planned Action Ordinance.  This type of convoluted obscurity is not appropriate in the EIS process.  Environmental impacts should be listed in the body of the EIS and discussed in a clear, straightforward manner.  

Beyond this, the use of the 2007 Whatcom Waterway EIS is an inadequate substitute for a current Waterfront District EIS for the following reasons:

• The Whatcom Waterfront EIS addressed only a specific sub-area of the Bellingham Bay waterfront.  We need an EIS analysis that analyzes plant and animal impacts throughout the entire waterfront.  
• The Whatcom Waterfront EIS addresses only aquatic issues. It does not address terrestrial species or habitat, habitat connectivity and biodiversity.
• The waterfront EIS needs to determine impacts under the current waterfront plan, which did not exist in 2007.  This was recognized by the port in its EIS Addendum issued last year, but plants and animal impacts were not included.
• The Whatcom Waterfront EIS was developed for purposes of a MTCA cleanup, rather than for impacts resulting from waterfront land use and zoning.  Land use plans create issues, such as intensity of use, inadequate buffers, and conflicting land uses, which do not exist and are not addressed in a site cleanup plan.

We are left with a waterfront plan advancing quickly toward enactment, without any proper review of plant and animal impacts, and therefore, of necessary mitigation. This calls into question the legal validity of the waterfront plan, and creates future problems that could more easily be addressed right now.

The city needs to supplement the waterfront district EIS to analyze plant and animal impacts.  And after it has this information, it needs to develop a comprehensive conservation strategy that addresses the data gaps and the connectivity and habitat needs first called out by Ann Eissinger in the 1995 and 2003 Bellingham Habitat and Wildlife Assessment. Please submit a written comment to the city council and the mayor requesting additional analysis and protection for Bellingham Bay and its uplands.  We need to continue to ask until our voices are heard.