No Net Loss
The Proposed Amendment to the Bloedel Park Master Plan
by Wendy Harris
Wendy Harris is a retired citizen who comments on development, mitigation and environmental impacts.
Bellingham excels at providing advice on Lake Whatcom stewardship practices and in assisting watershed residents in being good stewards. Apparently, it is not as good at taking its own advice, at least with regard to proposed development at Bloedel Donovan Park. The park, located on the shores of Lake Whatcom, adjacent to one of its only remaining urban wetlands and habitat corridors, is slated for greater development, with emphasis on promoting recreational watercraft use.
Normally, this would a wonderful addition to a beloved park that contains the only public dock on a large urban lake. In the case of Bloedel, it is a mixed blessing, at best. Lake Whatcom fails to meet water quality standards for drinking water, leaving 100,000 residents to rely increasingly on carcinogenic chemical alteration of its water supply. The primary source of lake degradation is watershed development.
It seems discrepant, then, that the proposed Master Plan amendment includes greater development in the form of a large boathouse, another dock, a trail, and a wetland-adjacent road that accommodates the needs of a rowing club. This is in addition to plans for a watercraft inspection station, increased parking, and road improvements. A concrete bulkhead will be removed and the shoreline will be softened, increasing the presence of people and pets.
The city is attempting to offset the impacts of additional development through a shoreline stormwater infiltration trench, and a native vegetation protection area. The Parks Department advised the public that the development will have “a direct ecological benefit to Lake Whatcom” and improve water quality, without releasing public information regarding the net increase in impervious surface, the anticipated effectiveness of the stormwater engineering, or the results of a “no net loss” of ecological function analysis required by law.
The Parks Department has falsely advised the public that new development will have an ecological benefit to priority species. In fact, this proposal increases impacts to an important wetland and wildlife corridor adjacent to the boat launch area, despite city department policies and regulations that require protection of high value habitat.
The wetland is a designated “Fish and Wildlife Conservation Area” protected under the Bellingham Critical Areas Ordinance. This was not mentioned in public information nor was it considered by the Planning Department when granting permits for Park development that could impact the ecological functions of the wetland. Recently, a dock and a large boat storage area were authorized in close proximity to the wetland.
A proposed road runs parallel to the wetland, creating an additional barrier to wildlife traveling from the wetland to Whatcom Creek and Bellingham Bay, which reduces genetic exchange within species. The proposed native vegetation area will create an isolated habitat island surrounded by people and pets, with little conservation value and no consideration of habitat connectivity and species diversity. Park development will increase the presence of people and pets on land and water, but the city is not requiring mitigation for the impacts to wildlife that rely upon the lake, the wetland, or the habitat corridor. Park planning, which is required to protect the non-human species that rely upon the lake, simply does not.
Vegetated Shoreline Buffers Reduce Picnic Area
As proposed, the new vegetation area will displace an existing picnic area, although this is a very popular park use. An additional concern is that the reduction in available parkland will affect the continuing use of the park as a dog off-leash area. A better and less disruptive use of native vegetation would be vegetated shoreline buffers that allow lake access for swimming and use of the dock area. This complies with specific policy goals in the city’s updated Shoreline Master Plan (pending Department of Ecology approval). Shoreline buffers are, in conjunction with dogs, an effective deterrent to geese, which contribute to the phosphorus and fecal coliform problems affecting the lake.
And unlike a shoreline infiltration trench, which performs one ecological function, a vegetated buffer provides many ecological functions. Perhaps this is why a recent city/county sponsored study determined that protecting and restoring watershed land is generally more effective and less costly than an engineered solution.
Invasive Aquatic Infestation
Improvements proposed for the benefit of the city’s first freshwater row club, the Whatcom Rowing Association (WRA), will increase the risk of infestation from invasive species. Yet, simultaneously, the city is developing and siting a watercraft inspection program at Bloedel intended to prevent aquatic infestation.
Bloedel Donovan is infested with Asian clams. Aquatic infestation is generally associated with recreational water use. A map of identified Asian clam hotspots corresponds to locations on the lake that have public dock facilities. The largest hotspot of infestation is at the Lakewood facility, the former site of the WRA. The proposed Master Plan amendment will increase recreational water use at Bloedel Park. The new dock is intended, at least in part, to accommodate greater watercraft use that will result from the classes and events sponsored by Whatcom Rowing Association (WRA).
WRA’s watercraft pose a particularly high risk of infestation because the club sponsors competition racing, frequently traveling to other water bodies, increasing the likelihood that watercraft will return with invasive species. The “Whatcom Rowing Association Rower’s Handbook” fails to mention or reflect concern for the potential introduction of invasive species. At a public meeting on the Master Plan amendment, the city asserted that non-motorized watercraft have low risk of introducing invasive species. This is contradicted by prior statements that were made at other meetings, and by the city’s intention to include non-motorized watercraft in an invasive species inspection plan.
Public participation in the proposed Park Master Plan amendment has been particularly flawed. The city is engaging in a meaningless exercise intended only to meet its legal obligations. While the Parks Department is soliciting public input, “proposed” changes in design and use have already been implemented, and the ink on a Facility Use Agreement with the Whatcom Rowing Association has long since dried.
The proposed amendments to the Park Master Plan were released on March 13, 2012. This is subsequent to installation of a new dock and a 2,400-square-foot boat storage area for the Whatcom Rowing Association. The WRA website and Facebook page proudly lists Bloedel Park as its home, as well as the location of its boathouse. Public plans reflect a “proposed” boathouse, but the public was not advised that a fenced boat storage area already exists and that WRA is paying rent of $144 per month for land that was formerly part of the soccer field.
Amendment to a Park Master Plan should be the first action taken when substantial development or changes to park use are proposed. In this case, it was the last. The Parks Department first obtained approval at city Parks Board meetings, and discussed the changes at a City Council committee meeting, despite knowledge that few residents track these actions. To pretend that this sequence of events allows for public process is disingenuous.
Public Land for Special Interest Group
Concerns have been raised about providing public land to a special interest group, and rightly so. The city asserts that this is a non-profit organization. However, it takes money to be a part of this non-profit organization. Membership is $150 per calendar year for an adult and $75 for each additional family member. With the exception of an introduction class, membership is required to enroll in classes, which have an additional fee, or to use club facilities and equipment, or to participate in special events located at our public park. Land formerly available to the general public will only be accessible to those with an interest in rowing and the ability to pay required fees.
This also reflects a change in the way facilities are handled at Bloedel Park. Currently, there are two park buildings available for rent to any local organization on a first come, first serve basis. A new boathouse is being built for the sole use of the Whatcom Rowing Association. This reflects award of a special privilege.
WRA has not impressed me as a good Lake Steward. Its State Environmental Policy Act (SEPA) checklist application indicated that there would be no impacts from a new dock, despite science establishing the harmful ecological impacts of overwater structures, and the need for compensatory mitigation. No mitigation was provided. WRA professed to “not know” if Lake Whatcom was a sensitive water body. The club is attempting to justify its special treatment by claiming that rowing is an activity for the disabled. Competition rowing is not an appropriate activity for most disabled people, nor does WRA currently offer classes for disabled people.
The Bloedel Donovan Park Master Plan amendment calls for inappropriate development in an inappropriate location. The public is being deceived by misleading claims and is not being provided public process. This proposal benefits only the Whatcom Rowing Association and other non-motorized watercraft users. It is a losing proposition for the public, the land and the lake.