RE Sources Comments on City’s Decision not to Require an EIS for Mud Bay Cliffs Development

After reviewing the updated documents from the City of Bellingham, we still believe that the development of 38 properties will have significant environmental impacts. | August 11, 2025

On Friday July 25th, 2025, The City of Bellingham issued a SEPA mitigated determination of non-significance (MDNS) for The Woods at Viewcrest, a proposed subdivision on 38 acres known as the Mud Bay Cliffs, which overlook north Chuckanut Bay on the south end of Bellingham.

This determination essentially means the City believes that this project will not have adverse environmental impacts, so long as the developers follow certain conditions, and will not require a full Environmental Impact Statement, or EIS.

Back in April 2024, RE Sources submitted comments to the City of Bellingham outlining environmental concerns and requesting that a complete EIS be performed to adequately evaluate all the proposed project’s potential impacts to the area. After reviewing the MDNS issued in lated July, we submitted the following comment to the City outlining remaining concerns that we believe have not been fully addressed:


To: Steve Sundin, Senior Planner
Kathy Bell, Senior Planner
Planning and Community Development Dept.
City Hall, 210 Lottie St.
Bellingham, WA 98225

Transmitted Online Via: https://cob.org/gov/public/public-hearing-testimony

8 Aug 2025

RE: SEPA MDNS decision for The Woods at Viewcrest Development

Dear Mr Sundin and Ms. Bell,

Thank you for the opportunity to comment once again on the proposal to develop the 38-acres on the Mud Bay Cliffs overlooking Chuckanut Bay. After reviewing the updated documents on the City’s website and the expanded SEPA review, we still believe that the construction of the 38 properties will have significant environmental impacts. 

RE Sources is a non-profit organization located in northwest Washington and founded in 1982. We mobilize people in Northwest Washington to build just and thriving communities and to protect the land, water and climate on which we all depend. RE Sources has thousands of supporters in Whatcom, Skagit, and San Juan counties, and we submit these comments on their behalf.

There has been some effort made by the developers to minimize impacts from the development project but there will still be considerable, long-term environmental and societal damages done. 

  • The undeveloped, open space that people in the surrounding neighborhoods have come accustomed to and rely on for recreation and tranquility will be destroyed.
  • The refugia and habitat corridor that wildlife rely on will be considerably impacted. Blasting and construction noise and chaos for several years will likely spook away the majority of the wildlife. The wildlife analysis found no federally listed species on the property but 28 non-federally recognized species were found and they play significant roles in our ecosystem and still have value. 
  • Native trees and shrubs will be removed to make way for buildings and roads which will create an ideal pathway for invasive species to take root, further degrading the habitat. 
  • The documents claim that 80% of the trees will remain in place initially; removing 20% of the canopy and rooting structure can dramatically change the forest climate and slope stability. Furthermore, there is no guarantee that additional trees won’t be removed once people move into their houses, creating more expansive views. This could leave the area much more vulnerable to erosion and wind blown trees. 
  • The geotechnical reports claim there are risks associated with building on such steep terrain. A landslide could be catastrophic to human lives and property, as well as the water quality in Chuckanut Bay. 
  • The developers justify the number of properties being built by saying they could legally double that number. The topographic maps tell a different story; the current plan occupies all the more easily buildable flatter areas, leaving only very steep terrain undeveloped. These flatter areas are also the places that wildlife and people use for habitat and recreation, respectively.  This means that almost all of the buildable and habitable land will be occupied by buildings. 
  • Increased impervious surfaces along with toxic building materials, household chemicals, and pets will result in toxic stormwater chemicals being discharged into Chuckanut Bay. The proposed pretreatment of stormwater in modules and detention will help mitigate high flows but it will not filter out stormwater toxics such as 6PPDq, petroleum, sediment, and bacteria.  This will further degrade the already impaired Bay. 
  • Connecting to the City’s sewage system should minimize fecal coliform contamination in the short term, but over time sewage pipes can get clogged and damaged resulting in eventual fecal contamination.
  • Natural gas may be used to heat the properties which will result in greenhouse gas emissions. Why not limit natural gas for cooking and use electricity for heat? Electric heat pumps would provide both heating and cooling for the homes. 

This project may have managed to check all the appropriate boxes in the SEPA document and meet the definition of “no net loss” but it is clear to us that this development project will have long lasting impacts. Over time, in reality, there will be a net loss of habitat, a net loss in open space and recreation, a net loss in soil, and a net loss in water quality. Thank you for taking the time to read our letter and listen to the many community concerns about this planned development project.  Once this development is done, it can not be undone. 

Sincerely,

Kirsten McDade
RE Sources, North Sound Waterkeeper

 

Make Your Voice Heard

You can review documents related to the Woods at Viewcrest project, as well as other public comments that have been submitted, on the City’s webpage. You can also submit your own public comment using this form on City’s Engage website.

Protect Mud Bay Cliffs, a volunteered-led community group that has been advocating for protecting the area from the adverse environmental impacts of the proposed Woods at Viewcrest development since 2021, has filed a formal appeal of the City’s 7/25/25 SEPA Mitigated Determination of Non-Significance (MDNS) and failure to require a full Environmental Impact Statement (EIS) for the proposed development. You can learn more about their efforts at: https://mudbaycliffs.org/