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A Policy of Neglect: How Waterfront Plans Fail to Protect Bellingham Bay Wildlife


July 2013

No Net Loss

A Policy of Neglect: How Waterfront Plans Fail to Protect Bellingham Bay Wildlife

by Wendy Harris

Wendy Harris is a retired citizen who comments on development, mitigation and environmental impacts.

Part 1

Not many people are aware of the ecological significance of Bellingham Bay. The bay contains large estuarine areas from the influx of fresh water from Nooksack river and the Chuckanut, Padden, Whatcom and Squalicum creeks. As a result, the bay has been an area of high biological diversity and productivity, and a water body of regional significance in the Salish Sea. The shoreline and nearshore by the Nooksack delta and the mouths of the creeks have particularly high habitat value (or potential) for birds, fish and marine mammals.

The city and port of Bellingham are ignoring impacts to fish and wildlife as they attempt to squeeze as much development as possible out of the waterfront. It is unlikely that aquatic life on Bellingham Bay will ever recover. These results were predicted in a May, 2007 Whatcom Watch article by Terrance Wahl entitled, “Waterfront and Wildlife.” The local, renowned bird expert stated that “the planned development of the central waterfront will have little benefit for wildlife and in fact will worsen things to the point of virtual elimination.” 1

This prediction is almost certain to become a reality under the current waterfront redevelopment plan promoted by the city and port administrations. It is a telling sign that the Bellingham Planning Commission, which recommended that the City Council approve the proposal, failed to conduct a single work session focused on shoreline issues or fish and wildlife conservation, even after the Washington State Department of Ecology found that the waterfront plan was in conflict with city shoreline regulations. Even more telling is the lack of effective mitigation to offset the harmful impacts of waterfront redevelopment. In fact, the city and port refuse to acknowledge that there will be impacts on the marine ecosystem.

The city and the port argue that the waterfront is degraded and therefore, of such low habitat value that redevelopment will improve habitat functions. This analysis overlooks our functional marine habitat, which will be harmed through intensified use of the water and the shorelines by people, pets and watercraft. And while some shoreline restoration is planned, it will have limited functional value because it does not establish adequate buffers, protect against human intrusion, or ensure habitat connectivity.

This policy of willful neglect is contrary to the goals articulated when the waterfront planning process first began, and it overlooks an important opportunity to plan at a “landscape based” scale, which is the approach recommended by wildlife agencies. The city and port have ignored the economic benefits of developing the waterfront for eco-tourism, although this is an annual two billion dollar industry in Washington. Eco-tourism is more compatible with the stated desires of many Bellingham’s residents for a more natural waterfront experience and would provide an alternative source of income beyond intense urban level development and privatization of the waterfront.

The waterfront proposal ignores an important reality. We can not protect the bay and its shorelines without protecting fish and wildlife. Biodiversity keeps our ecosystems healthy and sustainable, makes the land more resilient to human impact and provides crucial ecosystem benefits, often too expensive or too difficult to duplicate. Moreover, ecosystem benefits are increasingly recognized as necessary for human survival. In sum, our future is connected to the future of our local species.

This month, I discuss the importance and vulnerability of Bellingham Bay’s fish and wildlife. Next month, I examine how the proposed waterfront plan fails to address conservation issues. It is clear that waterfront plans must be revised to better connect, protect and restore Bellingham Bay biodiversity.

Bellingham Bay Biodiversity

Bellingham Bay has well over 50 species of fish.2 Three important species of forage fish, surf smelt, sand lance and Pacific herring (Chuckanut Bay), spawn on Bellingham Bay beaches. They supply over 50 percent of the diet of adult salmonid species and are a key factor in protecting and maintaining local anadromous fish populations. Northern anchovies are also found in the bay.

Salmonid species, including coho salmon, chum salmon, Chinook salmon, pink salmon and sockeye salmon, use the bay. These salmon species are an important food source for other aquatic and upland species and have high commercial value. Nooksack River Chinook salmon are a designated “Evolutionarily Significant Unit” because they are genetically distinct from other Chinook. The estuarine areas and the shorelines of Bellingham Bay are essential to the survival of all salmonid species, but Chinook and chum salmon, in particular, require extensive use of the nearshore.

The bay supports other anadromous fish species such as steelhead trout, cutthroat trout, bull trout, Dolly varden (a char species), longfin smelt and Pacific lamprey. A number of rockfish species are found in Bellingham Bay. Additionally, the bay is home to Pacific cod, ling cod, and flatfish species such as English sole and Starry flounder.

Bellingham Bay is abundant in shellfish, and contains many species of crab, shrimp, clams, oysters, mussels, scallops, and cockles. While commercial and recreational shellfish harvesting is prohibited in Bellingham Bay, the shellfish remain an important food source for marine species. The bay is also abundant in lower forms of life, including worms, insects and intertidal species (anemones, stars, urchin, cucumbers, jellies) that are also an important source of food.

A number of important plant species are found in the Bellingham Bay, including kelp and eelgrass, which are a source of food, shelter and oxygen to a wide variety of invertebrate and vertebrate species. The plants also serve as migration corridors. Current eelgrass cover is believed to have declined more than 90 percent from historic levels in the 1800’s.

Bellingham Bay is well known for its important bird habitat: because it is situated along the Pacific Flyway, between Skagit Bay and the Fraser Estuary, tens of thousands of birds pass over, rest and refuel here during migration. In particular, Bellingham Bay is known for its large winter seabird population. Based on a MESA (Marine Ecosystem Analysis Program) study by the National Oceanic and Atmospheric Administration (NOAA), Bellingham Bay was identified as a “significantly important subregion.” (Wahl, et. al, 1981).

A Rich Diversity of Avian Species and Marine Mammals

Great Blue Heron are an iconic image on Bellingham Bay. But they are only one of a wide variety of avian species found here. Local marine birds can often be found floating in large rafts, and include Harlequin ducks, long tail ducks, bufflehead ducks, widgeon, brants, Canada geese, grebes, cormorants, gulls, terns, scoters, scaups, goldeneyes, mergansers and loons. The bay is home to more unusual alcids species such as pigeon guillemots, marbled murrelet, common murre and rhinoceros auklet. Migratory shorebirds that visit the bay include dunlin, western sandpipers, sanderlings, turnstone, surfbirds and black oystercatchers. Belted kingfishers’ are found along the shorelines. Raptors hunt in this area. Bald eagles, osprey, peregrine falcon, and several species of hawk have been sighted. Numerous songbird species can be found along the vegetated bluff above the waterfront.

Marine mammals can be found in Bellingham Bay, with harbor seals prominent on haul-out logs around the waterfront area, particularly the log pond. California sea lions and Pacific Harbor porpoises use the outer bay. River otters have been spotted, sometimes with pups, in the bay and on local park shorelines, such as Boulevard Park and Maritime Heritage Park. Whale spottings are infrequent, but Orcas and Grey Whales have been sighted.

Species At Risk

Bellingham Bay’s abundant fish and wildlife sustained indigenous peoples for thousands of years. Salmon runs were once so productive that the fish could be harvested with pitchforks. Recently, many historic wildlife populations have plummeted. While there are many reasons for this, shoreline development and loss of habitat are primary problems. The ongoing impacts of 100 years of industrial operations, residential development and, more recently, recreational activities have greatly impaired the habitat value of the bay.

In particular, Bellingham Bay is seeing the same sharp decline in marine bird populations affecting Puget Sound. Only 20 years ago, Bellingham Bay had some of the largest winter concentrations of western grebes in North America, estimated to be as high as 38,000. Today, those numbers have declined by over 87 percent. This severe decline has generated scientific and media attention.

Western Washington University professor John Bower completed a study in 2009 that documented the decline in marine bird species, based on 1978 and 1979 census data.3 The seven most common species, brant goose, western grebe, surf scoter, American wigeon, greater scaup, glaucous-winged gull and Pacific loon, have collectively dropped by 67 percent, with declines even greater than that for particular species such as the brant, the common murre and the marbled murrelet. According to Dr. Bower, “If we have declines in the birds, it means the ecosystem that supports those birds is in trouble.”

The North/Middle Fork and South Fork spring Chinook populations had historic abundances of an average of 26,000 and 13,000 respectively for the North Fork and the South Fork populations. Now, natural-origin Chinook return in the low hundreds, averaging 170 (North/Middle Fork) and approximately 80 (South Fork) fish in recent years. According to a 2002 report by the National Marine Fisheries Service, included as part of the Puget Sound Chinook Salmon Recovery Plan, 2011, habitat factors responsible for the decline include development along marine shorelines in Bellingham Bay and in nearshore areas.4

Development near the shorelines has fragmented and destroyed most upland habitat. However, there is limited terrestrial wildlife in the upland areas of Bellingham Bay. The most important remaining habitat is the natural bluff line above the bay, which extends north from the Chuckanuts through the city. This provides a vegetated corridor used by birds and smaller mammals. However, the bluff corridor is threatened by increased human use along the South Bay trail, tree clearing for views, and the use of harmful pesticides and chemicals. Whatcom Creek also provides terrestrial habitat but, even after restoration, lacks adequate connectivity between the marine waters and the uplands necessary for full functionality.

Conservation Requirements

In theory, a number of laws and non-regulatory guidelines protect Bellingham Bay wildlife from the impacts of development, most prominently the federal Endangered Species Act (ESA). Species are classified as either endangered (seriously threatened with extinction), threatened, (likely to become endangered if no action is taken) or sensitive (vulnerable or declining in population).

Orca whales are listed as endangered and the protected habitat range of pods J, K and L includes Bellingham Bay. Boccacio rockfish were added to the endangered list in 2010. Threatened species include the marbled murrelet, Chinook salmon, steelhead trout, bull trout, yelloweye rockfish and canary rockfish. Sensitive species include peregrine falcons, common loons and bald eagles. Western grebes, common murres, eagles and chum salmon are “candidate species” being considered for ESA listing.

Bellingham Bay’s marine mammal species, such as harbor seals, otters and porpoises, are protected under the Marine Mammal Protection Act, which prohibits the unauthorized ‘take” of any marine mammal. Raptors and shorebirds are protected under the Migratory Bird Treaty Act.

Washington also protects “priority habitats and species” (PHS) through publication of management recommendations;5 these are non-regulatory guidelines. Priority habitat and species are much more extensive than ESA species. State priority species include almost every fish and wildlife species found in Bellingham Bay, including the forage fish, salmonid species, rock fish, and all marine birds, cavity nesting ducks, alcids, waterfowl and marine bird concentrations, raptors and the Great Blue Heron. Additionally, Washington has adopted “Aquatic Habitat Guidelines” through a multi-agency program that includes a number of state and federal agencies.

Locally, Bellingham Bay is a designated critical area or, more specifically, a “Habitat Conservation Area” (HCA), which imposes special requirements on development within 300 feet. (Bellingham Municipal Code 16.55.470). These regulations also apply in shoreline areas through the city’s Shoreline Master Program (SMP).6 The Bellingham Critical Area Ordinance states that mitigation of alterations to HCA must include mitigation for adverse impacts upstream or downstream of the development proposal site and must address each function affected by the alteration to achieve functional equivalency or improvement on a per function basis. (BMC 16.55.490).

Willful Ignorance

The city and port are well aware that Bellingham Bay wildlife is at risk due to fragmentation and loss of habitat connectivity, inadequate habitat buffers and intensified human uses. True, the city and port largely ignored these issues in the Waterfront District Environmental Impact Assessment (EIS) required under the State Environmental Policy Act (SEPA). The Waterfront District EIS, which requires the review of five separate documents drafted over a five year period, is disjointed, inadequate and confusing. However, the status of Bellingham Bay fish and wildlife is reflected in a multitude of other city and port documents.

These issues were extensively analyzed by field biologist Ann Eissinger of Nahkeeta Northwest Wildlife Services. Ms. Eissinger completed the City of Bellingham Wildlife and Habitat Assessment Plan and Wildlife Habitat Plan in December, 1995. It remains the seminal work on Bellingham fish and wildlife species, arranged by watershed. This work emphasized the need for empirical data to fill large gaps in the available information, before additional city development occurred. This recommendation continues to be ignored.

Ms. Eissinger also drafted the City of Bellingham 2003 Bellingham Habitat Assessment, which was an updated review of habitat conditions within the city, allowing opportunity to track habitat trends. The assessment rated the functional value of habitat blocks and identified, at a rough scale, the city’s habitat corridors. The assessment stated that inner Bellingham Bay, although industrialized and severely modified, “harbors significant wildlife populations,” concluding that the “marine habitat represents a vast area of significant value in the region.” However, the assessment warned that, without better protection, Bellingham would lose many of its wildlife species. Ms. Eissinger’s reports were not popular with city officials and were never officially adopted although, even today, they are cited as sources of information.

The city SMP, updated in 2013, designates Bellingham Bay as a “Shoreline of Statewide Significance” (SSWS). As part of the SMP update, the city did a functional assessment of each shoreline area (referred to as a “reach”.) The Bellingham Bay shoreline analysis reflects the importance and vulnerability of aquatic habitat, as well as the extent of shoreline degradation. Of note, the shoreline analysis for Boulevard Park, which will be connected to Cornwall Beach park via a controversial 8-million dollar overwater bridge, acknowledges that the popularity of the park and shoreline trail interferes with conservation efforts, likely leading to loss of pigeon guillemot nests.

Both the port and the city are part of the multi-agency task force that continues to meet bi-monthly for the Bellingham Bay Demonstration Pilot Project, which includes a habitat restoration component. The Pilot Project has identified the highest-priority habitat restoration areas in Bellingham Bay and, while there are plans to move forward with certain restoration efforts, these plans are not reflected in the waterfront plans, reducing the city and the port’s accountability to the public.

In summary, Bellingham Bay remains important habitat for a wide range of wildlife, but this habitat is fragile and subject to increased degradation. Waterfront redevelopment will expedite the loss of marine habitat. It is clear that Bellingham Bay must be connected, protected and restored as part of the waterfront redevelopment process.

Next Month: How waterfront redevelopment plans threaten biodiversity and what can be done about it.


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