Yesterday, the Bellingham Bay Foundation sent comments to City Staff, Planning, the Mayor, and the WAG on the Shoreline Master Program. The comments are below. We encourage everyone to make your own comments. Send them to:

citycouncil@cob.org
smpupdate@cob.org
planningcommission@cob.org
mayorsoffice@cob.org
wag@cob.org

For a pdf of the following comments, please go here.

March 15, 2007

Dear Planning Commissioners, City Staff, Planning Staff, City Council, Waterfront Advisory Group, and Mayor Douglas:

Thank you for your careful consideration of the Shoreline Master Program. Overall, this document is very protective of the environment while allowing an excellent framework for public access. Our goals remain thorough cleanup, public ownership, and an excellent redevelopment. To that end, we have some concerns which we've noted here. Please accept these suggestions and revisions, and thank you for your time.

Sincerely,
Frances Badgett
Bellingham Bay Foundation
(360) 527-2733 | frances@bbayf.org | www.bbayf.org

The Bellingham Bay Foundation supports the protection of public access, sensitivity to habitat restoration and protection, and prioritization of water-dependent uses as outlined in the Draft Shoreline Master Program.

The following areas of concern remain.

Buffers and Setbacks
In our design concept, we illustrated exceptionally developed shorelines with ample public access and connected green space that did not include a large, wide green belt along the shoreline of the NWSDA. However, we believe that should Bellingham lose the opportunity for a large, central park in the Aerated Stabilization Basin, then shoreline green space becomes critical. Therefore, we recommend the Planning Commission and City Council return to the previously recommended 100–200' buffers along the shoreline. Should it become necessary to shave these green spaces in the design process, a mechanism for doing so should exist for the Planning Commission. The concern is that instead of giving our designers and planners the minimum and forcing them to fight for more green space, they should receive the maximum and be able to pare it down where necessary. Not only should our parks be the backbone of the planning process, they should act as buffers between recovering habitat under threat by urban impacts and dense development.

We are concerned about the following wording on the matrix: "Except where there is an existing pier, wharf, sheet pile or other vertical in-water structure, the 25' buffer does not apply." Please revise this to ensure that the regulated buffer (whatever size it ends up being) is in place wherever possible. As it is written, almost the entire shoreline is exempted from a buffer.

The buffers and setbacks are both set at the Ordinary High Water Mark. This has been confusing to the public, as a buffer and a setback can be set within each other, and the uses within a setback can be anything from a lemonade stand to a convention center. Please clarify language about buffers and setbacks (i.e., placing a setback at the outer edge of a buffer) and distinguish the primary and general uses for a setback more clearly.

We also request that under 20.02.20 2c the Cornwall Avenue Landfill be removed from mixed-use designation and kept for green space and open space and shoreline habitat restoration and protection.

Economic Development
22.02.20 C
The Bellingham Bay Foundation applauds the desire to make the new waterfront a place to work. We believe that for a proper redevelopment, cleanup, meaningful public access, well-designed green space, and excellent habitat restoration must take place before development begins. We do not separate ecology from economics, and we would like to see a statement supporting this perspective added to this section.

Management Policies
22.03 F, 2, a
Please reinstate the redacted statement "be good stewards of the environment."

22.03.F, 2, j
"The majority of the water's edge should be accessible via non-vehicular means of transportation, including pedestrian walkways..."

Please revise to say, "The majority of the NWSDA should be accessible via non-vehicular means..."

22.03 F, 2, l
Please remove, "Subject to the New Whatcom Master Plan design and phasing, surface parking may be developed as an interim use on areas planned for future development, enabling its evolution over time into a denser environment."

Surface parking has tremendously negative impacts on the environment, and particularly when juxtaposed with a sensitive aquatic environment. Surface parking should be an option of last resort for our new waterfront.

Public Access
22.08.70
Please revise "employee gathering areas" as "gathering areas."

22.08.70 A, 5
The Bellingham Bay Foundation supports either partial or a majority of public ownership. Please include language to that effect. Suggested revision: "The City and the Port of Bellingham should implement a variety of techniques including leases, easements, design and development innovations, enlightened private property interests, and a public development authority to achieve public access goals and to provide diverse public access opportunities."

Mitigation
22.08.100 A, 6
"Monitoring the hazard or other required mitigation and taking remedial Action when necessary."

The Foundation doesn't believe that a broad, vague policy for monitoring is effective. We request a specified monitoring timeline.

Boating Facilities
22.09.20 A, 3
An important feature on the new waterfront could be dry-stack storage for smaller boats, hand-carried non-motorized craft, and other small vessels.  Please reinstate "upland dry-stacking (storage)" in the wording of this policy. This is not to "replace" marinas with dry-stack storage, merely to relieve marina demand and to ensure a place on the waterfront for smaller boats.

22.09. B, 4
Please reinstate this redacted section, "Prior to approval of new in water boating facilities, the applicant shall demonstrate that there are no alternatives to an in water facility to supply an anticipated demand for boat storage over a twenty-year period." (For example, relocation of moorage slip tenant into a new dry-stack storage facility.)

Dry-stack storage should be prioritized over in-water storage throughout the waterfront to protect the aquatic environment from contaminants, shading, propeller wash and other problems with boat traffic.

Dredging
22.09.40 A, 5
Please reinstate this redacted sentence, "Where feasible and appropriate, contaminated dredge material should be removed from the aquatic environment."

The permanent removal of contaminants should have a place in the SMP.

Landfill
22.09.100 A, 2
Please reinstate and revise the redacted sentence, "Remediation of existing contaminated landfills should ideally occur at the time of redevelopment" to read, "Remediation of existing contaminated landfills should ideally occur prior to redevelopment."

Roads, Railways, and Utilities
22.09.150
Please revise this section. The creation of new roads on the waterfront should be minimal, and all forms of non-motorized transportation or alternative modes should be explored. Please remove mention of highways and interstates and wireless communication facilities (cell towers?).

22.09.150 A, 2
Please reinstate the redaction "...should not be located within shorelines unless no other feasible alternative exists. If no other feasible alternative exists, new roadways should not be located parallel to the shoreline."

Stormwater Management Facilities
22.09.170 B, 6, c
Monitoring should be frequent and long-term. 5 years is not long-term.