Review the following letters from the North Sound Baykeeper on the City of Bellingham Waterfront Redevelopment proposals.
Related North Sound Baykeeper links:
Wendy Steffensen
North Sound Baykeeper
RE Sources
1155 N. State St., suite 623,
Bellingham, WA 98225
Waterfront Advisory Group
1801 Roeder Ave.
Bellingham WA 98225
March 13, 2006
Dear Members of the Planning Commission:
Thank you for taking comment on the numerous plans and ideas put forth by the community on redevelopment of the City Center area. As stated before, it is of crucial importance that habitat be incorporated into redevelopment plans, in order to promote salmon recovery and provide for connectivity of fish and aquatic wildlife populations throughout the urban area.
To further your understanding of habitat concerns, (as outlined in letters dated 2-15-06 and 2-28-06 on redevelopment plans, and in a letter dated 2-16-06 on strategic guidelines), I have enclosed a chart and a map to illustrate and detail the habitat areas of concern for your consideration.
Baykeeper concerns are focussed on habitat and cleanup. The Waterfront Advisory Group will need to consider issues such as parks, transportation, the placement of water-dependent businesses and the necessity and desire for a potential marina. In regard to these other concerns and their interaction with habitat and cleanup concerns, I note the following:
- The enclosed map shows a continuous riparian edge along the water. This would be the best possible outcome for habitat. It is acknowledged that this is not a practical solution in an urban area. Where water dependent businesses are located, these businesses will need to have access to the water and will be unable to provide riparian habitat. It is asked that riparian habitat be provided to the largest extent possible. In areas where there is no conflict with water-dependent businesses, it would be best to provide a 200' buffer of native plants, shrubs, and some small trees along the shoreline edge.
- The cleanup of contaminated sites, much of the entire redevelopment area, is still in very formative stages. The absence of cleanup decisions and plans, and in some cases, even thorough site investigations, makes planning of redevelopment problematic. Cleanup will affect redevelopment to some extent, and some acknowledgement and allowances must be made for that.
Once again, thank you for the time and effort devoted to the redevelopment process.
Sincerely,
Wendy S. Steffensen
North Sound Baykeeper
RE Sources
- Map showing a continuous riparian edge along the water - Click to see full map
- This area is the I& J pocket beach, also known as Broadway Cove, in the Port's plans. Pocket beaches provide feeding habitat for crab, salmon, and aquatic birds, and spawning habitat for forage fish. This area needs restoration in the form of riparian plantings to provide shade and the addition of softened shorelines to further introduce intertidal habitat. This intertidal habitat will provide feeding and refuge areas for crab and salmon.
- This area is the "G" street pocket beach. Forage fish eggs have been found on his beach and eelgrass lies to the South and West of it. Because of this area's outstanding habitat attributes, it is crucial to protect and restore it to the largest extent possible. Softening and addition of intertidal or subtidal habitat is proposed to promote habitat and connectivity in this area.
- The enclosed map shows a closed GP aeration basin, with habitat benches. Since the fate of the lagoon is under discussion, I submit that the fate of the lagoon is a community discussion. From a habitat and cleanup perspective, the opening of the lagoon will not necessarily be a better or worse outcome. Much yet needs to be worked out in terms of the cleanup plan and any proposal for a "clean marina" to make such a determination. If the lagoon is opened for use as a marina, it does need to be done in the most environmentally benign and restorative manner as possible.
- This is the "C" Street pocket beach. This pocket beach represents an opportunity for restoration through cleanup action, riparian plantings, and stormwater treatment.
- This area is an existing mudflat (Roeder St Beach) and beach (Central St. beach). Mudflats are productive habitat for crab, juvenile salmon, and aquatic birds. After any remediation action that needs to occur in this place, restoration actions such as planting riparian vegetation (where possible, given property ownership) and removal of creosote pilings should occur. The Central St. beach is presently covered by the stub end of Central St., which is not in use and is supported by pilings. Beach restoration would be accomplished by removal of this structure.
- Creosoted timbers and piling should be removed from this area and the existing dock should be removed because of its shading effect. Riparian vegetation should be planted and intertidal habitat should be restored in this area to provide for a salmon migratory corridor.
- The log pond is functioning habitat as of now. It needs to be monitored, maintained, and buffered so that it retains its function as habitat.
- The pocket beach at West Pine and Cornwall needs to be maintained and expanded through riparian plantings and intertidal enhancements along the rip-rapped shore. It is the best opportunity for beach restoration in this area.
- The Cornwall Landfill should, during or after remediation, be armored with soft shore techniques to produce intertidal habitat. There are two small pocket beach opportunities and habitat enhancements that can be realized along this stretch.
- While not essential for habitat, the section to the southeast of the Cornwall Landfill should be considered as a park to maintain connectivity to an upland buffer/habitat.
Addendum to letter dated March 13, 2006 RE: City of Bellingham Waterfront Redevelopment- March 16, 2006
From the North Sound Baykeeper
What is the importance and need of habitat?
- We know that species are in decline and we know that this is happening for a myriad of factors. These are habitat loss, pollution, overharvest of fish, global warming and subsequent change of ecological conditions. Habitat loss is one piece of the overall picture, but it is an important one. In Inner Bellingham bay we have lost over 200 acres of eelgrass and over 320 acres of intertidal habitat.
- Salmon are in decline and part of the ecosystem that is valuable to them as they make their transition from freshwater to sea water is the estuary. Shallow migratory nearshore corridors are used by salmon for feeding and as refuge from large predators. By steepening and bulkheading our shorelines, we have made Bellingham Bay less hospitable to salmon. Puget Sound Chinook salmon are listed as a threatened species under the federal endangered species act and we have Chinook salmon in Bellingham Bay.
- Sand lance, one of the major species of forage fish and prey for salmon, spawn on the upper intertidal beaches. Sand lance are especially vulnerable to upper intertidal hard armoring, and so bulkheading is a detriment to them, and soft shores should be restored wherever possible.
- Many species of marine birds are in decline-- some at an alarming rate. In the North Puget Sound area, western grebes have declined by 95% over the past 10 years, and surf scoters have declined by nearly 70%. We still do not know the reasons for this, but habitat degradation is likely one contributing factor.
Why should habitat be restored in an urban area, like Bellingham?
- Salmon, birds and other fish need continuous and connected habitats. Because we are in an urban area we do not often think about habitat in our midst-- yet it runs throughout the city. We can choose to make it beneficial habitat or not.
- Nearshore corridors and pocket beaches are areas that should be preserved, enhanced, or restored in order to provide feeding, rearing, spawning and refuge for resident populations. While we cannot restore all of the migratory corridors that would be of the most benefit to salmon, we can provide enough of these such that they become islands of refuge and that salmon habitat, and thereby health, is enhanced
- We should do this where we can--- and it is not asked that we do away with commerce or water-dependent businesses, but that we place restore and protect the most sensitive and beneficial areas and that we provide a network of connected nearshore subtidal refuge areas.
- Pocket beaches, mudflats and intertidal areas provide feeding areas for crabs, salmon, and aquatic birds.
- In addition, pocket beaches provide spawning areas for two types of forage fish and refuge areas for crabs.
- Intertidal/ soft shore bench areas vegetated with eelgrass provide spawning areas for herring and refuge areas for crab and salmon.
- Mudflats also provide rearing habitat for salmon. (See Roeder St.)
February 28, 2006
Dear Members of the Waterfront Advisory Group:
Please consider this letter as an addendum to the letter written on 2-15-2006 regarding the draft plans. This letter is designed to assist you in directing the drafting of the 5th consolidated plan. It consists of direct comments on each of the four plans and on common elements of the plans.
Once again, thank you for you time and effort on Bellingham's waterfront redevelopment process.
Sincerely,
Wendy Steffensen
North Sound Baykeeper
Green Seam
The wide swath of "green" surrounding the log pond is a great attribute. It is important that the area closest to the pond be planted and maintained as habitat, whereas the outer edges could be parkland.
The road adjacent to the proposed marina appears to be a multi-use trail. This is appropriate.
The over-water bridge should not be built over the waterway since it will be a pollution source.
Green Bank
A primary street running along the proposed marina is not appropriate. If the marina is built, it is proposed to be a "clean" marina. Clearly, a road should not be allowed at its interface.
Pearl Parks
Two roads hug the shoreline in this plan, one along the proposed marina and one along the Waterway and log-pond. Neither of these are acceptable. Roads should be set back wherever possible, even in urban landscapes, in order to prevent pollutant from directly entering the Waterway.
The green edge shown along Pine street is a good attribute. This area needs to be greatly expanded and the existing road at Pine needs to be removed as depicted in the other drawings.
Green Fingers
The green finger along the proposed marina is a good attribute. This area should consist of park and habitat at the two pocket beach ends (G street and C street).
The head of the I& J Waterway should be designated as "open space" as in the other plans, most preferably as habitat.
The southernmost green finger should be located at Pine Street. This "green finger" at Pine Street should consist of park, beach, and habitat.
All Plans
The road that extends from the beach at Cornwall & Pine to the Cornwall landfill hugs the shore much too closely. This road should be relocated during redevelopment if at all possible, given ownership constraints, away from the shore by 200'.
The proposed green space at Cornwall Landfill should consist of habitat at the edge of the landfill, as engineered during remediation, using soft-shore techniques. This site should be comprised of habitat and park, waterward from the South Bay Trail.
The proposed boat launch should be moved away form the C street pocket beach, into the marina or another suitable location.
"Open Space" must be further delineated, such that it is clear where habitat, park, and impervious plazas will be located.
Buildings at the edge of the Whatcom Waterway should be considered for removal, as they interfere with the re-establishment of habitat in the intertidal area.
Green areas visioned at the head of I& J Waterway, adjacent to the G street, pocket beach, and along the Whatcom waterway should be widened and maintained as habitat areas.
The Whatcom Waterway area between Roeder and Holly Street needs to be designated as habitat. This area has the potential to beprime intertidal habitat, pending investigation and remediation, if necessary. This area also represents an area that will connect the Whatcom Creek estuary and the designated habitat at the head of the Waterway.
Sincerely,
Wendy Steffensen
North Sound Baykeeper
RE Sources
Feb 16, 2006
Dear Planning Commission Members:
Thank you for taking comment on the strategic guidelines and the four design plans for New Whatcom. I have spoken publicly at the last Planning Commission meeting on the design plans. Attached, as well, are written comments on the design plans delivered to the Waterfront Advisory Group (WAG) on Feb 15, 2005.
The following remarks pertain to the Jan 24 06 draft WAG recommendation, section II, of the strategic guidelines.
Section II; 1, 2 ,3, 6:
These guidelines are worthy, but their implementation may be compromised by the sequencing of events and design steps. These guidelines call for identification of natural areas for protection or enhancement, as well as the implementation of remediation actions at contaminated sites and protection along the shoreline in accordance with the City's updated SMP. The implementation of protection, restoration, or remedial actions may impact and alter design elements along the shoreline. Design elements of parks and streets should not trump the required protection and remedial actions. As well, they should not preclude or encroach upon restoration of more functional habitat. Implementation of the draft guidelines would mean that habitat restoration and protection as well as remediation of contaminated sites would be occur prior to the designation of roads and parks.
Section II; 4:
This section should be amended to include the other habitat opportunities not included. Please add the following sentence to 4A.
Protect and functionally enhance the pocket beaches at "G" street, "C" street, Central Street, Roeder Avenue, the North end of the Cornwall landfill, and the South end of the Cornwall landfill, unless a greater restoration opportunity precludes their enhancement.
Section II; 5, 7, 8, 9,10:
These sections are strong and protective of the environment. They should be included. The recommendation to include 8B is not an endorsement of the marina pe se; it is an endorsement of a clean marina if there is to be marina.
In regard to section II of the strategic guidelines, the guidelines and their implementation strategies are worthwhile. One lingering concern is how do we, the public, know or ensure, the guidelines and their implementation strategies will be used?
Thank you for consideration of my thoughts and concerns.
Sincerely,
Wendy Steffensen
North Sound Baykeeper
RE Sources
February 15, 2006
Dear Members of the Waterfront Advisory Group:
Thank you shepherding the vision of the Waterfront Futures Group for Bellingham's redevelopment. It is an important undertaking.
As the North Sound Baykeeper, I am an educator and advocate for the marine waters of Whatcom County. My concerns at this stage are focussed on ensuring that we preserve, enhance, and restore, where possible, habitat that lies within the redevelopment area. I was intimately involved with the Waterfront Futures Group process and have been following the clean-up process since 2000. My comments reflect my knowledge of Bellingham Bay, and the process for both its redevelopment and cleanup.
Restoring habitat in Bellingham Bay is important. Within the last 100 years, the Inner Bay has lost 200 acres of eelgrass and approximately 320 acres of estuary and intertidal habitat. The City's shoreline is fragmented and approximately 40% of the shore is armored.
In order to start restoring populations of salmon, crab, forage fish, birds and other species to health we must start connecting and restoring habitat where we can. This means that we should ensure nearshore migratory corridors from the north to the south, and that we should provide habitat refuges wherever feasible.
The four design plans that the Port has put forward do not adequately address habitat. At this beginning stage of design, it is critical to incorporate habitat considerations, such that they are not precluded.
Please note that the draft New Whatcom implementation guidelines, section II, Restore the Health of Land & Water, states the following:
1) Enhance or reintroduce natural systems.
A) Continue to work with… to be good stewards of the environment. Identify opportunities for cooperative projects and joint funding for shoreline restoration, habitat enhancement, environmental remediation, and public access improvements.
2. Create and Restore habitat wherever possible.
A) Evaluate sites identified in the WFG "Opportunities and Ideas for Habitat Restoration"… as shoreline restoration sites…
The draft guidelines listed above followed from the WFG's work. These guidelines also make good sense if habitat is a priority. These guidelines cannot be implemented unless habitat is considered prior to design.
The bare-bones of what should be considered in the design plans are as follows:
- more extensive estuary rehabilitation further up the Whatcom Waterway, to provide additional feeding, rearing and refuge habitat for salmon.
- the incorporation and restoration of 9 pocket beaches (from NW to SE; I&J, "G" St, "C" St, Roeder St, Central St, GP Log Pond, Cornwall& Pine, North Cornwall Landfill and South Cornwall Landfill), to provide spawning habitat for forage fish, and feeding habitat for other fish, crabs, and aquatic brds.
- the incorporation of salmon benches along I&J Waterway, Whatcom Waterway, and Pine St, in addition to those already sketched at the proposed marina, to provide feeding and refuge for salmon and crab.
- A softening of shoreline edges wherever possible and the establishment of native and riparian vegetation along the shoreline to support the food supply for juvenile salmon and nearshore shade for forage fish eggs.
Areas near the pocket beaches and estuary are of concern in the draft plans. In these areas roadways and development must be pulled back so that the design of appropriately sized, restored, and functional habitat can be incorporated. (Locations of the pocket beaches can be found in the WFG Environmental Opportunities workshop report)
In order to make the redevelopment habitat and fish-friendly, the design should consider the following:
- Roadways in the draft plans should be pulled back from the shoreline so that they do not run close to it, nor over it, as proposed in Green Seam design. Roadways near the shore or over the water will increase toxics loading into the Bay.
- The proposed boat launch should be located within the proposed marina, rather than in the Waterway or on the C street pocket beach. (location too close to the "C" St. pocket beach will preclude the function of that area as a pocket beach.)
- The proposed in-water visitor moorage may interfere with salmon habitat. Prior to deciding upon this option, an analysis of the moorage option and its effects on salmon feeding and migration should be assessed.
- Parks at the water's should incorporate native vegetation, and overhanging vegetation wherever possible, within the constraints of a park system.
- Sensitive habitat areas should not be considered parks; these should be reserved for habitat. The seal haulout at the GP log pond may be one example where this reservation should apply.
- Habitat area must be maximized and the percentage of actual habitat should also be given to the public to consider. (Open Space in the current designation could mean anything from habitat to lawn to brick plazas; this should be made more clear.)
Thank you for your hard work on this important project and for taking habitat concerns into consideration.
Sincerely,
Wendy Steffensen
North Sound Baykeeper
August 28, 2004
Dear Ms. Decker and Waterfront Futures Group Members:
Thank you for this opportunity to comment on the Waterfront Futures Group (WFG) plans. Enclosed you will find comments from RE Sources and the completed RE Sources charrette documents.
As the North Sound Baykeeper, I have been looking at the WFG plans with an eye on providing habitat connectivity and on the remediation of contamination. I know that you all will look at these plans and re-evaluate these plans with an eye to gathering and melding many perspectives, that of economic, cultural, social, and environmental.
I believe that habitat and environmental protection underlie the foundation of a sustainable and thriving community. All other concerns and developments can be overlain on top of maintaining a healthy environment, whereas the reverse is not true.
The City of Bellingham is at a crossroads. As we redevelop we have the opportunity to choose restoration and health, and reverse the very substantial degradation and loss of aquatic habitats in inner Bellingham Bay.
As you make your decisions about priorities and restoration opportunities, please consider the following impacts that have occurred within the last 100 years, as outlined by the Habitat Action Team of the Bellingham Bay Pilot Work Group:
Loss of approximately 200 acres of eelgrass habitat
Loss of 320 acres of estuary and intertidal habitats from historic filling
Loss of Squalicum, Whatcom and Padden Creek estuary habitats from filling and dredging.
Fragmentation of shoreline from filling and dredging
Sediment contamination at approximately 15 different sites.
The restoration of Inner Bellingham Bay is important. Its health and restoration should not be dismissed. Inner Bellingham Bay is part of a larger ecosystem, provides connectivity up and down the coast for a myriad of nearshore inhabitants, and is part of our heritage. In your deliberations, I hope you will choose to prioritize restoration and environmental health.
I look forward to working with you all to make the Bellingham waterfront a more enjoyable and vital place in the years to come.
Sincerely,
Wendy S. Steffensen
North Sound Baykeeper
RE Sources
.
PROCEDURAL COMMENTS AND CONCERNS:
The guiding principle to "Restore the Health of Land & Water", is a necessary and important component. We applaud the Waterfront Futures Group for recognizing its importance.
It is evident that the goals under restoring the health of land and water will sometimes be in conflict with economic and access goals. It is unclear how decisions will be made as to what
goal will take precedence. It appears obvious that each decision will need to be made on a case by case basis. However, a framework for making those decisions should be discussed now, to minimize conflict.
The subheading, " Require sustainable practices in all development" is absolutely worthy and commendable. In order for this goal to become enacted or at least partially achieved, it will be necessary to define what sustainable development and sustainable practices are.
Identification of areas of overriding environmental significance needs to occur prior to other planning and implementation efforts.
As cited in the June 24, Waterfront Action Plan timetable, the phase to "identify areas of overriding environmental significance" does not occur before some other phases are started. While it may be advantageous to perform some tasks concurrently, it does not make sense to do that when determining areas that should be effectively "off-limits", as is the case with areas of overriding environmental significance, as well as with significant historical and cultural sites. To protect habitat and significant environmental areas, and to prevent conflict over usage of the sites, these sites must be delineated prior to other planning and implementation efforts.
The implementation of the first phase of early action projects, appears to occur PRIOR to identifying areas of overriding environmental significance. Planning and implementation efforts that are stated to occur concurrently, include the preparation of a city center waterfront renewal plan, the second phase of implementation of early action projects, the creation of a new city center waterfront neighborhood, identifying sites for open space and parks, and bringing educational institutions to the waterfront. All of these tasks should occur after areas of overriding environmental significance have been identified.
Accountability of Waterfront Futures Advisors and Waterfront Renewal Authority to the public is unclear.
It appears that the appointment of a group of Waterfront Futures Advisors will be duplicating the efforts of the Waterfront Futures Group (WFG), to some extent. It also appears that they may not be as accountable to the public as the WFG, Since considerable public outreach and public input has been funneled into the WFG process, all of the information and comment generated should be used. What assurances does the public have that this new process will be accountable to the public and will build upon the information already generated? What structures and assurances will be in place to ensure that Waterfront Futures Advisors and Waterfront Renewal Authority are accountable to the public? How will these boards be structured and how will appointments be made in an open and fair manner? Will these boards have a representative for the environment?
The Waterfront Renewal Authority appears to have less accountability to the public and to the public's vision of waterfront development than the Waterfront Futures Advisors, as they are not charged with being "Keepers of the Vision" and they will come up with a new "City Center Waterfront Renewal Plan". It is stated that the City Center Waterfront Renewal Plan will be consistent with adopted community plans and policies. Does this include the Waterfront Futures Group plan? What will the relationship be between the Waterfront Futures Advisors and the Waterfront Renewal Authority? The City Center Plan is said to consider a number of elements, but not one of them is concerned with habitat or public access and the environment. A good deal of comment related to the natural systems and the environment has gone into the City Center area during the Waterfront Futures Group process. How will environmental concerns and previous comments to the Waterfront Futures Group be addressed by the Renewal Authority?
RE Sources requests the two following actions to help assure that environmental concerns are not neglected as the waterfront futures group planning process moves forward. 1) Appoint someone to represent the environment on all newly formed/ proposed administrative and planning bodies, including those of the waterfront futures advisors, waterfront renewal board, and waterfront renewal authority. 2) Incorporate environmental concerns, including those presented during the WFG process, as part of the cornerstone framework, upon which development occurs in the "City Center Waterfront Renewal Area".
As outlined under the goal of "Restore the Health of Land and Water", the use of the inventory of environmental resources and opportunities is unclear.
It is assumed, but not stated, that the inventory will be used to identify areas that should be protected and restored. Will a plan for restoration and protection of natural areas that places them in the context of a larger system be prepared, as for the shoreline trails plan? Will these resources and opportunities be prioritized, and be made an integral part of redevelopment efforts? Under what framework will this occur? And, how will this be accomplished?
There are a few errors in map presentation that should be corrected and/or clarified.
In the map of Little Squalicum, the cement plant / future redevelopment area is shown in green and could be misleading. This area should be shown in industrial gray, not park green, consistent with the other maps.
Also in the map of Little Squalicum, it is not clear what is meant by "habitat enhancement" and by "beach enhancement".
DESIGN CONCERNS:
The Waterfront Futures Group is to be commended for specifically calling out areas that should be protected, enhanced, or restored.
Among these are the following actions as outlined in the Waterfront Framework Plan (6-8), Plan Update (6-24), or as indicated graphically in the Waterfront Framework Plan (6-8G). Where there is concern about whether an intended action is best for the environment it is noted and discussed in more detail below. In addition, please review what is depicted graphically and clarify if the graphics are intended as part of the official "framework plan" and guidance.
Little Squalicum:
Remove carbon material (the bark and wood chip debris accumulated from years of log raft and milling activity, added by WS) along the beach (6-8)
Replace or remediate creosoted pilings (6-8)
Monitor Little Squalicum Creek and uplands and remediate as appropriate (6-24)
Squalicum:
Relocate Squalicum Creek mouth to create a new estuary west of and separate from the Squalicum Creek Waterway (6-8)
Create sub-tidal habitat migration habitat with benches along the west side of I &J Waterway (6-8)
Remove old in-water structures and restore shoreline and creek delta (6-24)
At the West side of Mount Baker plywood, expand the backshore of beach, and convert the boulder and rock to finer gravels and substrate (6-8G) NEED CLARIFICATION
Create intertidal habitat, i.e. salmon benches, inside marina margins and outside of breakwaters. (6-8G) NEED CLARIFICATION
City Center:
Clean up contamination of the ASB on the bay side (6-8)
Examine implications of leaving the Whatcom Waterway sediment in place. (6-8)
Cap the Cornwall landfill and provide marine habitat enhancement and a new public open space along the water for the length of the site. (6-8) CONCERN
Examine contamination levels to help shape renewal master plan and then tailor remediation to planned use (6-8) CONCERN
Restore beaches where possible (6-8)
Remove all contaminated sediment from the ASB and reconnect with Bellingham Bay (6-24) CONCERN
Remove creosote piles from intertidal and subtidal areas near RG Haley site (6-24)
Protect enhancements at the Log Pond site and extend habitat and beach enhancement into upland areas. (6-24)
Investigate opportunities for stormwater treatment and creation of marsh habitat at stormwater outfalls and adjacent open space areas. (6-24) CONCERN
Beach enhancement at "C" and "G" streets, on either side of the ASB. (6-8G) NEED CLARIFICATION
South Hill and Boulevard:
Maintain separation between public access trails and the water's edge to protect land and water habitat areas from the South end of Cornwall Landfill to the North end of Boulevard Park. (6-8)
Remove creosote piling along shoreline between Boulevard Park and Cornwall Landfill. (6-8)
Reduce some of the grassy areas and hardened edges to create a more naturalized transition from grass to native plants, and native plants to beach. (6-8)
Recreate eelgrass beds along and near the shore. (6-8)
Fairhaven:
Naturalize the area along the east side of Padden Lagoon (6-8)
Evaluate impact on existing structures of reducing hardened edge on east side of Padden Creek lagoon (6-8)
Enhance the estuary lagoon at Padden Creek, increase water flow through the railroad causeway and protect and enhance eelgrass beds in the adjacent near shore areas (6-8)
Naturalize the shoreline area between the launch ramp and the cruise terminal (6-8)
Protect and enhance eelgrass beds in the near shore adjacent to Marine Park and support plans to create a softened edge along the shoreline (6-8)
Protect Post Point lagoon from pollutants, designate off leash areas, and protect natural areas by enhancing or reintroducing native vegetation. (6-8)
Utilize storm water as a sustainable asset (6-8) CONCERN
Protect natural areas by enhancing or reintroducing native vegetation (6-24)
Protect the heron rookery and add substantially to the acreage of the wetland/marsh system below the wooded slope of the rookery (6-24)
Move designated off-leash dog area to the SE side of the Post Point Treatment Plant and consider putting a pond there for the dogs. (6-24)
Chuckanut & Edgemoor:
Perforate the railroad causeways across Chuckanut bay to improve water circulation and reduce siltation (6-8)
Maintain Clark's Point as an open space resource (6-8)
Complete acquisition of the Woodstock Farm as a new city park. (6-24)
Address septic tank contamination in Chuckanut bay (6-24)
Taken as a whole, these actions, will enhance the habitat that is present, but impaired, in Bellingham Bay. Other actions should be considered in order to have a greater positive impact on habitat.
It is noteworthy that other relevant and important habitat ideas put forth by the Habitat Action Team of the Bellingham Bay Pilot Work Group (HAT) or by the Interagency Workshop sponsored by the Waterfront Futures Group (IA) have not been picked up. These are reviewed here and I urge you to reconsider and incorporate them into your final work plan. Also included, are some additional site notes.
Squalicum:
The Mount Baker Plywood site consists of fill. Some of this fill should be removed on the Northwest and South side and this area should be converted to marsh and/ or sand or mudflat. (HAT)
Beach expansion and conversion of rock and boulder to finer gravels at the West side of Mount Baker Plywood should also occur to enhance the area for the already present spawning site of forage fish. (6-8G, HAT, IA)
Intertidal salmon bench installation should be looked at as a possibility along the breakwaters. If installations such as these are part of a mitigation plan, it should be acknowledged that these are experimental in nature, and that their stability will be dictated by wind and wave action and the establishment of vegetation. (6-8G, IA)
Pocket beaches near breakwaters and marina margins should be considered to increase habitat for forage fish (IA)
City Center:
The I& J Waterway has a functioning, yet degraded, pocket beach at its base. This beach is a documented forage fish spawning site. Its preservation is required. Enhancement of this site should be a priority (IA). Additonally, this site is suitable for a kayak launch.
Intertidal eelgrass and salmon bench areas should be installed in the City Center area to create a migration route that is less stressful for salmonids. Installation of intertidal benches at the margins of the ASB breakwaters, and the southwest side of the Port shipping area, should be considered based on their overall stability given dominant wave and wind patterns. (HAT, IA)
Other existing pocket beaches should be protected and enhanced to provide opportunity for forage fish spawning, and in some cases, for kayak launch sites. These are at "G", "C", Roeder, Central, and north and south of Cornwall Landfill, and at the base of Cornwall at Pine Street. (6-8G, IA)
A linear park along the waterfront was an item that was deleted in the 6-24 Framework Plan update. Habitat and park buffers are needed along the waterfront. Please reinstate this item. (6-24)
The Cornwall Beach at Pine Street, has specifically been called out due to it being a significant, natural public access beach within the city. This site is a prime location for habitat and public/ kayak access. In light of this information, it is not wise to place development at this site. To improve the value of the habitat, buffer the beach area with native plants and parkland, and place buildings for Western Washington University further away from the water's edge. To accomplish this goal, the small park presently pictured approximately at Commercial and Beale Memorial Parkway should be moved waterward and enlarged, and roadways should be vacated near the water's edge, to the extent feasible. The Cornwall Beach and the water's edge surrounding it presents a significant habitat resource and public attraction. It should be used to maximum benefit as habitat and park. Additionally, if more housing is brought nearer the downtown area, a larger more natural park in the downtown area will be a significant and needed amenity. (6-8G, IA)
An alternative RE Sources rendering of the City Center has been provided attached to this document. This RE Sources rendering takes from the Waterfront Futures Group and Interagency Work Group comments, and build upon that, given the considerations of feasibility and habitat. This depiction of the City Center differs from that offered in the WFG in the following ways:
the pocket beach at I&J waterway is preserved,
beach enhancement and restoration is included on the West side of Whatcom Waterway at Roeder Avenue and along Pine Street,
the kayak launch site has been removed from the West side of the ASB to minimize impact from kayakers on the eelgrass that is present,
parking areas directly adjacent to the waterway have been removed,
the jitney stop at the head of Whatcom Waterway has been removed as this is where habitat restoration is occurring,
riparian vegetation has been emphasized along waterways at Whatcom Creek, the GP- log pond, and the Cornwall Avenue landfill,
a salmon bench has been added along Pine Street; it has replaced one of the two transient moorage locations
the central park has been moved waterward and enlarged to provide a more enjoyable community space and a buffer for habitat,
roadways and transit have been moved away from the waters edge,
a green buffer has been retained on the bluff next to the rail line, and parking has been removed from this location, in order to retain a larger natural space along Boulevard trail and to counter bluff erosion,
the GP lagoon has been designated as a place for a community supported use or environmental restoration site.
South Hill and Boulevard:
Creosote on the wood trestle at Boulevard Park should be remediated by replacing or covering the creosoted pilings. (IA)
Two over water trails are shown that extend from Cornwall Landfill to Boulevard Park. These trails should not be built unless an on land trail is infeasible to construct. Twinned water and land trails are not necessary. Overwater structures shade eelgrass and are a migration barrier for salmon, and their construction disrupts habitat. (6-8)
In addition to the recommendation to: " reduce some of the grassy areas and hardened edges to create a more naturalized transition from grass to native plants, and native plants to beach", there are other actions that may be taken in the Boulevard Park area to enhance habitat. Specifically, The Interagency report details the potential to actually recreate some beaches within Boulevard Park. These opportunities should be assessed. (6-8)
A wetland should be enhanced between Boulevard Park and Taylor Street. This area can be restored to a more functional wetland and habitat by removing fill. Presently this area is depicted as a park in the 6-8 Framework Plan, please amend this to habitat, instead. (IA)
Fairhaven:
Padden Creek Estuary represents one of the greatest potential areas for habitat improvement in Bellingham Bay. Fill should be removed to the extent possible, especially on the East side; this will entail moving two Port warehouse-type buildings. This action is needed because the Padden Creek channel is severely constrained. According to the IA report, removal of fill on the East side will "expand the estuary, provide a buffer of woody vegetation bordering commercial/ industrial use, and allow for a more natural channel to form. Currently Padden Creek drains directly into the rip rap revetment on the east side of the lagoon". (HAT, IA)
Removal of fill South of Harris Avenue on either side of Padden Creek should also be considered. Again, According to the IA report, "Fill removal is also proposed south of Harris Avenue in a 200 foot wide swath to recreate a wider riparian area. The culverted fill pedestrian "path" (McKenzie Avenue fill) is proposed to be removed and replaced with a footbridge. Vacating of 8th Street is proposed between Harris Avenue and McKenzie Avenue, but no buildings or other paving would be affected. Most of the land in this area is already City Park." This project will yield long-term habitat benefit and restoration. In the short-term, however this project would require some removal of riparian vegetation, and so should be done in stages. (HAT, IA)
The Post Point embayment should be opened up to create more habitat. This would include enlarging the embayment by opening up the culvert and by removing some fill to create a marsh. (HAT, IA)
Nourishment of the beach is needed between Boulvard Park and Padden Lagoon, especially because this is a documented forage fish spawning site. It is not clear from the text in the 6-8 Framework Plan whether "support plans to create a softened edge along the shoreline", indicates beach nourishment in this area or not.
The Waterfront Future Group is to be commended for supporting ongoing habitat actions and plans already in process. These include the expansion of Squalicum Estuary and the creation of a beach at Marine Park. The restoration of Whatcom Creek Estuary and remediation of the Holly Street Landfill is also an ongoing activity that will greatly enhance habitat, although it was not specifically mentioned or endorsed by the Waterfront Futures Group.
RE Sources and the North Sound Baykeeper agree with the findings of the Natural Systems and the Environment Work Group subcommittee of the Waterfront Futures Group.
From the Desired Outcomes in the Natural Systems and the Environment Work Group Initial Findings Report: "The Sub-committee after review of the literature and inspecting the shoreline believes that a policy of "no net loss" is insufficient towards the necessary healing operations to re-achieve historical natural system operations. We feel that thorough analysis of environmental implications should be made for every finding and recommendation made by the Waterfront Futures Group. Restoration of ecological balance on the waterfront must be supported, rather than compromised by built interventions."
The thorough analysis suggested by the Natural Systems group has not been accomplished and may be outside the scope of the present framework and vision documents. This thorough analysis, however, must happen as a comprehensive piece of overall waterfront redevelopment planning. If it does not occur, the City of Bellingham will have lost an important opportunity to enhance habitat and to provide habitat connectivity to the north and south of our urban area.
The management of stormwater to enhance estuarine habitat is of concern.
Utilizing stormwater as an asset has been specifically promoted in the City Center and Fairhaven areas of the Framework Plan. Many of us know that wetlands can be used to treat stormwater, but using stormwater to enhance estuarine habitat does not appear founded. Stormwater contains many toxic pollutants that degrades habitat. Stormwater treatment is essential to maintaining the health of our estuaries. Whether treated stormwater can actually be used to enhance our existing estuaries is open to question. More investigation into this possibility is needed. Under the guise of "managing stormwater to enhance estuarine habitat" we should not be using our estuaries to treat stormwater, and degrade them in the process.
Specific remediation solutions should be dictated by the health of the environment, first and foremost, the nature and extent of contamination, and the appropriateness of the solution.
The Waterfront Futures Group may know what land use they would like to see at the Cornwall Avenue Landfill and the ASB, but the Waterfront Futures Group is not qualified to make decisions about contamination remediation, especially before all of the remedial investigation work has been performed. Capping the Cornwall Landfill and reconnecting the ASB with Bellingham Bay may or may not be the best thing for the environment and our community. The Waterfront Futures Group should wait for the remedial investigations to be complete, before any pronouncements are made as to remediation solutions.
The goal to "Tailor environmental cleanup strategies and remediation to planned use" is also of concern.
The idea that environmental cleanup should only go so far, depending on planned use, is an idea born out of wrong-headed practicality. It is true that cleanup costs a lot of money. It is also true that cleanup is the price we pay for poor decisions and poor practices. To not pay the price of full cleanup, we are saying that it is alright to pollute, and it is alright to not clean up the environment. To have a City- and Port-appointed body endorse the idea that this type of practice is acceptable sends the wrong message. While it is true, that it will be "impossible" to clean up some sites to their original "condition, that determination should be made during investigation; half-hearted cleanup should not be endorsed by the WFG. Additionally, uses may change for any particular site. Thus, the best cleanup is necessary to ensure that all possible uses for a site can be employed in the future.
There is a very real concern about promoting residential use of the waterfront.
While having residences in the waterfront area may enable some revitalization there, it can also be detrimental. The waterfront should be preserved and used for the majority of the public and for water-dependent and water-associated uses. Private residences do not satisfy either of these needs.
Additionally, the waterfront is built on fill and will be unstable in the event of a seismic event. The fill can fail and liquefy and the overhanging bluffs can slump. Clearly, there are substantial risks with residential use of the waterfront.
The promotion of healthy fisheries and sustainable fishing as a livelihood should be highlighted more than it is in the current WFG plan.
Fishing as a livelihood certainly gives one a sense of place, and historically Bellingham relied on its extraction industries, including its fisheries. While we cannot go back historically and have fishing in as prominent a place as it once had, it is important for a sense of place and also as a demonstration of our connection to the water, that fishing remains prominent on our waterfront. Healthy and sustainable fisheries should be promoted. These rely on good management, environmentally aware and savvy fishers, and the protection of the health of our water, estuaries and streams. To promote fisheries, we would like plans to specifically look at the moorage for fishing vessels, as well as maintaining the web lockers at Squalicum Harbor for fishers. Presently, the map designates the web locker area as an area for "long-term mixed use".
The use of a water jitney or taxi, especially given the proposed number and location of stops, appears to be unnecessary, is of questionable viability, and is potentially polluting and damaging to habitat.
The jitney is proposed to stop in 9 separate places within approximately 3 miles. It seems unlikely that the jitney could run frequently enough or cover enough area to be convenient for residents. Bellingham is a small city. It seems unlikely that even with the combined numbers of tourist and resident passengers that a jitney would be used at a rate that would ensure its long-term viability. Prior to purchasing and operating a jitney, a thorough feasibility study should be done, and there should be little infrastructural outlay prior to ensuring its feasibility. Part of the feasibility study should include an environmental analysis to ensure that pollution from fuel leakage and turbidity from prop wash is assessed in the routing and siting of the jitney and so that jitney use does not impact eelgrass or other sensitive nearshore habitats
Suitable areas for jitney stops might be at Squalicum Harbor at an existing dock, at the far end of the Whatcom Creek Waterway in a section of the area designated for "deep draft moorage", at the Taylor Street Dock, and at the Fairhaven Transportation Terminal. Some spots that have been designated as jitney stops are inappropriate. These locations are inappropriate because they are places needing habitat protection, are prime locations for habitat restoration, or do not have an existing dock. They are as follows: Squalicum Creek Estuary (habitat restoration, no dock), Whatcom Creek Waterway; near Roeder (part of estuary restoration, no dock); Pine Street at spot designated "transient moorage"; (proposed habitat bench, no dock), North end of Boulevard Park (has eelgrass, habitat can be enhanced by pocket beach formation); and near Padden lagoon (habitat protection and restoration).
Parking, although needed in some places, must be designed to have the least environmental impact possible.
Transit should be promoted wherever possible so that the impact of parking surfaces and of cars themselves, can be minimized. Parking surfaces should be placed away from the water, as they are impervious delivery systems for oils, grease, heavy metals, anti-freeze and other contaminants.
Some of the parking areas identified in the framework plan are environmentally poor choices. In the Squalicum Area, two parking areas are designated at the waters edge on the North side of Mount Baker Plywood; these are too close to the water. In the City center area, two areas are designated as parking areas near the waters edge to facilitate the kayak launches. The one on the NW side should be removed as there is sensitive eelgrass habitat there. The other one should be set back from the water's edge and be properly outfitted with stormwater controls.
Waterfront property should be prioritized for habitat, recreation, and for businesses that are water-dependent or water-related.
To this end, viable waterfront businesses should not be replaced with commercial endeavors,that may be able to pay a higher rent. In addition, non-water dependent businesses should relocate, if feasible. SSC should look at relocating. Mount Baker Plywood is a small viable business, but it is not water-dependent. In a long-term redevelopment plan (20-50 years) the possibility that Mount Baker Plywood may no longer be operating on this peninsula should be given serious consideration. This site should be restored to its natural beach condition through the removal of structures and fill, such that the Squalicum Creek estuary and the intertidal and beach area between it and Little Squalicum Creek are restored. Businesses that are in the Fairhaven Industrial Park that are not water dependent should also look at relocating. It would be wise to consolidate the water-dependent business here a bit, to enable the widening of Padden Creek Estuary.
The City and Port should institute ways to reduce stormwater pollution.
Stormwater is a major contributor of pollutants to Bellingham Bay, and the extensive amount of impervious area in the City is a very effective conveyance system of pollutants to Bellingham Bay. To minimize stormwater contamination, a system to treat stormwater treatment must be in place. Existing wetlands or estuaries should not be used to treat stormwater because these already fragile natural resources will then be subjected to deleterious contaminants and an unnatural, uneven flow regime. If properly managed, clean stormwater may be introduced into these areas as a resource. However, this proposition is questionable and must be demonstrated to be effective before it should be allowed.
The presence of impervious surfaces greatly exacerbates the problem of stormwater pollution. During redevelopment, the reduction of impervious surface should be required as should be the use of Low Impact Development (LID) techniques.
The principle to "Require sustainable practices in all development" is a laudable one.
Green building and sustainable practices should be encouraged wherever possible through the use of incentive programs. To make our community healthier and more vibrant, new businesses and development should reflect the sustainability value shared throughout our community. As the City and Port go about their work in attracting businesses and employers to the area, it must be kept in mind that the community wants to promote sustainability and environment-friendly businesses. A marketing plan should be developed that specifically focuses on attracting sustainable and environment-friendly businesses.
In the Framework Plan, numerous bulleted items on sustainable practice were specified for one section or another, however, these should be applied to all sections. The following principles should be instituted broadly throughout waterfront redevelopment:
• For polluted outfalls, including that of contaminated groundwater and stormwater, establish and enforce a contamination collection and treatment plan to prevent contaminants from entering the Bay
• Use building materials which do not produce toxics, i.e. avoid copper roofs
• Reduce heat island effect by selecting light colored paving materials, use open grid surface systems, and/ or utilize highly reflective roofing materials and vegetated roof systems.
• Make use of in-site renewable energy such as solar and daylighting, to satisfy building energy needs
• Favor plans which exploit adaptive reuse of existing structures
• Incorporate Leadership in Energy & Environmental Design (LEED) intentions and requirements in design and construction of new structures
The promotion of ecotourism should be part of Bellingham's sustainable economy, as it will ensure that there is benefit for the economy, the environment, and the community.
Ecotourism has the potential to bring in a substantial amount of money to the economy and Bellingham , with its natural amenities and beauty is well-positioned to benefit from it. The already prominent activities of hiking, birding, and kayaking should be promoted more extensively. These activities already have strong support and a community base. If promotion of these activities is done wisely, Bellingham can reap economic benefit without damaging the environment.
The Whatcom Association of Kayak Enthusiasts (WAKE) has proposed a Bellingham Bay Water Trail to the Marine Advisory Committee (6-7-04). RE Sources agrees with their proposal to highlight the kayaking opportunity in Bellingham and to connect our "water trail" to that of the already well-established Cascadia Marine Trail. RE Sources also agrees with their assertion that " a Bellingham Bay Trail would be a low-cost boost to Bellingham's economy by fostering tourism, human-powered water sports, and small businesses serving these activities." WAKE has recognized that actual "improvement" to kayak launch sites should be minimal, in order to preserve habitat at these sites. Thus, establishment of the water trail largely rests on recognition and advertisement of the existing sites, and some improvement where necessary. In order to protect habitat, parking should be placed away from the water, stormwater from parking lots should be treated, and docks should not be installed except where they need to be replaced and will not interfere with existing habitat. RE Sources also agrees that to foster ecotourism and kayaking, installation of a small boat storage facility is important.
Birding, as well, represents a well-established activity occurring in and around Bellingham. In order to preserve and promote birding and to reap the economic benefit from birding as a tourist industry, we must preserve habitats essential to birds. The North Cascades Audubon Society NCAS) has identifed many of the areas on the Bellingham Bay waterfront as important for protection, restoration, and enhancement. The areas are as follows:
• Little Squalicum Creek and its terminus at Bellingham Bay,
• the shoreline running west from the terminus of little Squalicum Creek,
• Whatcom and its terminus with Bellingham bay,
• the beach area and offshore area at the foot of Cornwall Ave.,
• the shoreline running north from Boulevard Park to the warehouses at the foot of Cornwall Ave.,
• the shoreline running south from the southern end of Boulevard Park to the former Uniflite property,
• Padden Creek corridor and Padden Lagoon,
• The Post Point Treatment Facility property
• Chuckanut Bay, in its entirety
From a letter dated March 21, 2003 to the WFG, "NCAS recommends that these sites remain as natural in character as they are presently and that restoration and enhancement be prioritized where natural character has been altered and/or degraded".
Habitat elements should be included in parks, especially those that are along the water. Often it appears, that people view habitat enhancement as something that happens in the water and parks as something that happens out of the water. We need to acknowledge that habitat extends upland, and that it is important to enable connectivity of our water and upland areas. Specifically, the new parks depicted in the Framework Plan should include habitat as a major component, and in some cases, areas designated as parks should be completely reclaimed as habitat.
• new park on the west side of Mount Baker Peninsula; grade to intertidal habitat, include a park border
• new parks along the City Center water edge, both those planned on GP property and on the Cornwall Landfill; Cornwall Landfill Park should be graded to intertidal habitat
• a park should be included contiguous with habitat restoration at the base of Cornwall Ave.
• new park near Taylor Dock; actually should be restored to wetland
• new park on Fairhaven / South Hill border
• new park on east side of Padden Creek; actually, should be restored to estuary instead
To include habitat in parks, riparian vegetation should be planted for shading of the water, native plants should be used where possible, land at the waters edge should be graded to provide intertidal habitat, and there should be areas specifically designated for habitat.
NEW WHATCOM REDEVELOPMENT:
How to be involved in preserving habitat in Bellingham’s central waterfront area:
Learn more
Sign up on the Baykeeper’s News & Events list to get weekly updates on the waterfront goings on, plus other marine related news and events around the County.
Email sign-up: waters@re-sources.org
Check out the New Whatcom Website: www.newwhatcom.org
Participate in the City of Bellingham Shoreline Master program update:
The Shoreline Master Program will dictate development regulations around the City’s shorelines, including those around New Whatcom.
Attend the next public hearing on the Draft Shoreline Master Program:
July 20th, 7:00 pm, Bellingham City Council Chamber Hall, 210 Lottie Street, Bellingham.
The draft plan is available at : www.cob.org/pcd/planning/environment.htm
The newest draft plan will be posted July 10th.
Visit the Baykeeper’s web page to view comment letters
Participate in the Whatcom Waterway cleanup public comment period
The Remedial Investigation/ Feasibility Study (RI/FS) is an important decision-making document that will come from the Washington State Department of Ecology in late June or early July. It will give background information on the cleanup, compare cleanup options and select a preferred cleanup remedy. When the RI/FS becomes available for public review, it is important to review and comment on it, because public comment can influence the remedy. Ask for a solution with the best cleanup and habitat benefits.
For information on the Whatcom Waterway cleanup see Ecology’s website:
www.ecy.wa.gov/programs/tcp/sites/whatcom/ww.htm
Check out the Baykeeper’s web page for comments on the cleanup and the RI/FS
Participate in the New Whatcom Development Master Plan
The Master Plan, developed by the Port and City, with input from the public will provide the base plan for the New Whatcom area. This plan will include whether a marina will be present within the GP treatment lagoon, and the location and size of major transportation routes, parks, restoration projects, and trails. After numerous meeting and draft plans in early 2006, and a summer hiatus, expect revised planning documents and new meetings to start in September, with an expected decision on the final plan in late fall.
See the public comment calendar and more information at:
www.newwhatcom.org/public-involvement.htm
Check out the Baykeeper’s web page for comments on the New Whatcom draft plans:
www.re-sources.org/baykeeper.htm
Related North Sound Baykeeper links:
