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

August 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 2

Bellingham City Council will conduct a public hearing for the proposed waterfront plan on August, 5, 2013, with council work sessions to follow. Hopefully, this will be more productive than the work sessions conducted by the Bellingham Planning Commission, which resulted in a rubber stamp of the plan promoted by the port and city administration. In the meanwhile, the staff used the month of July to promote their waterfront plan to the public, offering tours that focused on public access and aesthetic vistas. Controversial issues, negative impacts, and alternative planning options were not discussed.

We need to make important changes to this plan to protect Bellingham Bay biodiversity. The waterfront plan needs to create habitat connectivity, mitigate impacts from increased use of land and water, and resolve conflicts between public access and shoreline restoration. In short, the public must have a realistic understanding of the competing priorities for limited shoreline access and use, and the waterfront plan needs to include a conservation component that protects and restores habitat for all aquatic and nearshore species.

No Environmental Assessment of Wildlife Impacts

When waterfront planning first began, protection of local species and habitat was strongly emphasized, as reflected in the Waterfront Futures Group Vision and Framework Plan. Over time, wildlife issues were de-emphasized, in a process so gradual, few people were cognizant of it. In the current waterfront plan, wildlife impacts are ignored..

Waterfront district environmental impacts were analyzed in the Environmental Impact Statement (EIS), which consists of five documents reflecting the changes that were made in waterfront plans over time. The first EIS document, the 2008 Draft EIS, had a discussion of fish and wildlife impacts, supported by a technical report. These items were present, in a smaller version, in the second EIS report. The third EIS fails to address plant and animals, noting that prior assumptions are unchanged. The fourth and final EIS focuses on “key topic areas,” which do not include plants and animals.

Recently, the port issued an EIS addendum, without public input or notice, which made significant changes to the waterfront plan, reflected as the new “updated preferred alternative.” The resulting impacts to plants and animals are not addressed. I do not know how the city and port avoided an updated wildlife analysis without repercussion. Perhaps the complicated and lengthy waterfront planning process and the multiple EIS documents prevented recognition of what had occurred. IIt is essential that this be corrected before waterfront planning proceeds any further.

Too Much Flexibility

The issue of adequate wildlife protection is muddled by a waterfront plan that lacks adequate detail and clarity. This is justified as something desirable because it provides the city and port staff with “flexibility.” Staff successfully convinced the Planning Commission that they must have the ability to adapt and modify waterfront redevelopment over the many years and planning phases that will be necessary to complete construction. Comprehensive planning always requires a long term perspective, so the extraordinary need for flexibility in waterfront planning is unclear.

I believe a more accurate appraisal is that the staff wants the freedom to develop the waterfront as they see fit, with little interference from the public. The planning commission lacked understanding that “flexibility” comes at a cost. It reduces public input, staff accountability, government transparency, and wildlife protection.

The results are tangible. We have been given a draft Waterfront District Sub-Area Plan (also known as a “master plan”) that leaves the public unclear about what is going to occur at the waterfront. For habitat restoration, all that is generally disclosed is a site location and a stated intention to improve habitat function or restore eelgrass. (Waterfront District Sub-Area Plan, Chapter 3 generally, and Figure 3-3, page 3-20). This is an inadequate amount of disclosure, even for a comprehensive planning document intended to be general.

While there are many documents associated with the Sub-Area Plan, such as the development regulations, they are not instructive. For example, Waterfront District Phasing Maps for Phases 1 through 5 of the draft Interlocal Agreement for Facilities within the Waterfront District identifies “shoreline restoration areas” but provides no further information.

The city and port have information that would allow habitat restoration details to be included in the waterfront plans.1 By providing only the most basic of information, the city and port avoid affirmative obligation to fund habitat mitigation projects. This also allows the staff to proceed under an uncoordinated, piecemealed, site-specific approach to wildlife issues.

Effective conservation can not be achieved through a “site-by-site” approach. Only landscape scale planning, which is what the waterfront district master plan process is supposed to reflect, can fully protect fish and wildlife. A larger, ecosystem-based analysis is necessary to identify, protect, and restore the highest conservation value areas of the waterfront, along with key connectivity corridors.


The planning “scale” is critical with regard to habitat connectivity, an essential requirement for functional habitat. Habitat corridors allow species to move across the landscape for migration, foraging, life stage needs, and genetic exchange. When habitat becomes fragmented, species become isolated, lose genetic diversity and become dependent on one location for survival. This greatly increases the risk that a species subpopulation will become extirpated.

Connectivity requires assessment of land and water beyond the development site, and therefore, can only be done at the master planning level. Restoring or protecting habitat on a site specific basis, as proposed, does not ensure that habitat will be accessible by fish and wildlife. Only a landscape based approach identifies habitat sinks, such as roads, structural barriers and severed habitat linkages, which need to be addressed before site specific development is planned.

Habitat connectivity was highlighted as necessary but missing in the city’s 2003 Habitat Assessment.2 The Habitat Assessment advocated the development of a wildlife habitat network, which included connection between Bellingham Bay and the uplands, stating that “the planning process needs to incorporate wildlife movement and the retention of functional corridors as a fundamental part of development.”

Contrary to this recommendation, the draft waterfront plan largely neglects the issue of habitat connectivity. The only mention of connectivity that remains in the draft Waterfront District Sub-Area Plan (Chapter Three) is a reference to “nearshore connectivity”, (Page 3-17). Nearshore connectivity is limited to lateral movement along the shoreline, without consideration of connectivity between aquatic habitat and the nearshore, or between nearshore and upland terrestrial habitat.

This limited form of connectivity is intended to benefit salmon and forage fish, most likely because this is often a requirement of state and federal permits prior to development. By omission, the city and port have no intention of protecting habitat connectivity for biodiversity.

Intensity of Use

The waterfront plan ignores the inherent conflict between human land use and wildlife habitat. As the intensity of human use and development increases, the presence of fish and wildlife declines.3 By ignoring these impacts, the city and port are failing to provide appropriate mitigation of habitat impacts.

Yet the science is uncontroverted. Study after study documents the harm caused by human presence. Humans bring domestic pets, such as cats and dogs, which wreck havoc on native wildlife. Humans create noise, lights, and odors that interfere with migration patterns and other wildlife lifecycle activities. Lawns, parks and utility corridors reduce native vegetation, and introduce harmful pesticides and herbicides. Buildings with vertical glass windows are a leading cause of bird mortality. Roads and trails create connectivity barriers, and result in high animal mortality. Increased development density adds to existing water and air pollution, which correlates to a decrease in biodiversity and loss of functional habitat. In short, when humans appear, other species disappear.

Impacts will be felt even in areas that are alleged to be too degraded for any habitat value. The city is developing a new public trail around the ASB (Aerated Stabilization Basin) facility, one of the contaminated industrial sites. The ASB perimeter is currently used as habitat for birds, seals and otters.4 The city habitat analysis for this project revealed harmful indirect impacts from the increased presence of people. Although loss of habitat is a primary cause of species decline, the city and port have not proposed mitigation connected to the ASB trail or any other waterfront site.

In 2010, the GP site became the largest Caspian tern nesting colony on the west coast of North America, generating scientific field research and study. Although an empty industrial site, it had high conservation value. But redevelopment plans for this area include recreational and mixed industrial use. The port has harassed the terns every summer after 2010 to prevent another nesting colony, which would complicate the ability to develop the site and trigger mitigation requirements. The port has no plans to provide alternative habitat for the terns.

There has been no consideration of impacts from constructing 100’ and 200’ foot buildings within the Pacific Flyway, creating a tall barrier between the land and the sea. Although windows in tall buildings are a particular mortality hazard for birds, this issue has never been (publicly) discussed. And instead of mitigation for loss of harbor seal haul-out areas along the waterfront, the city filed a “take” permit to allow incidental harm or death of seals in connection with development of the overwater walkway near Cornwall Landfill.

Waterfront redevelopment will create more roads and trails that fragment land and create barriers to wildlife movement. Otters, seals, and terns will lose existing habitat along abandoned waterfront sites. Seabirds will be driven away by increased boat traffic. Song birds will fly into high rise windows. Small mammals will be hit by cars due to increased traffic and roads. And all forms of shoreline wildlife will be harassed by dogs and waterfront recreational users. And the city and port have no plans to mitigate the impacts.

Public Access Creates Problems

The waterfront plan ignores conflict between public access and shoreline restoration, a matter about which the Department of Ecology recently commented. Public access and wildlife habitat generally cannot exist in the same location, although most waterfront shoreline locations reflect both uses. Some people, (and apparently city and port planners), fail to understand the harmful impacts that recreational water activities, such as hiking, boating, wildlife watching, photography, swimming and on-shore recreation, have on wildlife.

Kayaking is one of the most harmful of recreational activities, since it allows people to get close to shoreline and marine areas normally inaccessible to humans. This can have significant impact on migrating birds, resulting in the need to take flight, reducing opportunity to forage and rest, and using crucial energy reserves. It is also disruptive to breeding marine mammals.

Simply put, habitat has value when it protects against human intrusion. The port and city have admitted there is a conflict, and have noted a potential for restricted public access at some waterfront areas, but they refuse to commit to anything definitive, stating that decisions will be made on an (ineffective) site-specific basis.


Shoreline buffers are an important tool is protecting nearshore and aquatic wildlife from incompatible land use activities and development. But buffers cannot serve their intended purpose if they are subject to activities that undermine their function.5 The waterfront plan places shoreline pedestrian trails and bike paths within the buffer, undermining a goal of keeping humans at a safe distance from wildlife.

Buffer width is an important determinant of buffer effectiveness. Shoreline buffers should be based on an analysis of shoreline ecological functions, development patterns and anticipated uses. Instead, the city and port provided a uniform 50 foot shoreline buffer around the entire waterfront without consideration of differences in zoning and use, or the presence of fish and wildlife. Review of scientific studies indicates that this is an inadequate buffer width for high urban density and use.

Native vegetation within shoreline buffers increases and protects shoreline ecological functions, but it appears from the waterfront plan that landscaping will be based on human aesthetic values, rather than shoreline functional values. In sum, the waterfront shoreline buffers will have greatly compromised functional value for wildlife.

Boat Traffic

The impacts from boat traffic deserve special attention.6 The first EIS document, which analyzed plant and animal impacts, considered potential impacts from increased boat traffic. It determined that there would be an increase in recreational boat traffic from the new marina, but this would be offset by the proposed decrease in commercial vessel traffic. The recent EIS Addendum reflects an increase in both recreational boating and commercial shipping, but fails to consider the impacts on aquatic wildlife. Given what is known about the harmful impacts of boat traffic, this is a glaring defect, and one that requires correction before a waterfront plan is adopted.


The proposed waterfront plan largely ignores wildlife issues. At best, shoreline restoration projects will benefit a few fish species. Waterfront planning needs to be placed on hold until there is an updated EIS analysis of impacts to plants and animals, which addresses conflicting shoreline uses, intensity of use impacts, and habitat connectivity. And these impacts must be rectified through meaningful mitigation that replaces any habitat that is lost through redevelopment. Unless significant changes are made in the current waterfront plan, inner Bellingham Bay is at risk of becoming an ecological dead zone.


1 The Waterfront District Sub-Area Plan incorporates by reference the Bellingham Bay Pilot, which identified the highest priority habitat restoration areas in Bellingham Bay, as does the recently updated city Shoreline Master Program. High priority conservation needs are identified in the City’s Wildlife and Habitat Assessment Plan and Wildlife Habitat Plan, December 1995 and updated 2003 Habitat Assessment, Nahkeeta Northwest.

2 City of Bellingham 2003 Habitat Assessment, Ann Eissinger, Nahkeeta Northwest. This document is marked as a “draft” because it was never adopted, but it is a completed analysis by a highly reputable field biologist.

3 U.S. Geological Survey, see citations discussing urban expansion at

4 City of Bellingham Parks Department, ASB Trail Fish and Wildlife Conservation Area Analysis, Consultant Report by Northwest Ecological Services, LLC, 2013.

5 Washington Department of Ecology, SMP Handbook, Chapter 11, Vegetation Conservation, Buffers and Setbacks, Nov. 28, 2011, Publication Number 11-06-010

6 U.S. Department of Interior, National Biological Survey, Recreational-boating Disturbances of Natural Communities and Wildlife: An Annotated Bibliography, Biological Report No. 22, May 1994; documenting harm to marine life from increasing noise in Puget Sound shipping terminals;; National Oceanic and Atmospheric Administration website with hyperlinks regarding human impacts on aquatic life.

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