Scrap Metal Pile Includes Many Hazards and Few Benefits

[Our Guest Writer, Scott Jones, is a Bellingham resident along with his family.  He is President of the South Hill Neighborhood Association. He founded and ran Beyond Clothing, a custom American made clothing company, for 17 years. He is a local advocate for Affordable Housing, Food Security, and a high quality of life for Bellingham and Whatcom residents.]

At the Bellingham Waterfront, new condos are under construction, a new affordable housing apartment complex is being built, the Portal and Pump Track support successful new business, and a six acre, three story tall pile of scrap metal grows like a giant red pimple on the landscape, easily seen from Google Earth. The Metal Pile started to appear in July 2022. By October it was gigantic, and when the first ship came in, Bellingham residents discovered the Pile now needed to be moved a third of a mile to the ship, one dump truck load at a time.

It takes 10 days to load a ship. Dump trucks are loaded using long-armed excavators with massive claws. The trucks make continuous loops across the Shipping Terminal, beeping whenever they back up. Chunks of metal screech and scream down the ramps every time the dump-beds are raised, ultimately crashing onto the concrete beside the ship. Finally, the claws on the ship’s crane go to work, picking up the hunks of metal and dropping them into the steel hulls. A bulldozer assists this process by continuously scraping the metal over the concrete to shape and reshape the pile. The noise permeates homes from South Hill to the Lettered Streets. 

Each ship can carry a minimum of 27,000 metric tons of cargo. The process takes 10 days and could occur every month for the next 25 years. During those 10 days, the hours of operation are 7 A.M. to 3 in the morning. 

This process seems out of character for a developing Bellingham Waterfront.

The Log Pond at the Waterfront

The property the Metal Pile sits on is called the Log Pond. This portion of the Waterfront is an earth-filled location, with a cement cap, that during the GP days was used for mercury discharge in their wastewater. Over the years, as the Bellingham Waterfront came to be a planned development area, the Log Pond became a Department of Ecology Clean-Up Site. 

While the land from the Granary building to the Boardmill building is zoned Commercial-mixed use, the area south, including the Log Pond and the Shipping Terminal are deemed Industrial.

Although industrial land can be anything from lite manufacturing to mining and steel production, the land at the Log Pond and Shipping Terminal is an “Industrial Mixed-use area to be utilized for transportation, construction or light industrial uses.” The 2018 Waterfront District Sub-area Plan describes possible uses as “light manufacturing and assembly, high technology, and research and development.”

In the summer of 2022, as Bellingham residents became aware of the Metal Pile, with the climax of loading the first ship, new information came to light that jarred the community. The Port of Bellingham had quietly signed a 15-25 year lease with a Canadian recycling collection company, ABC Recycling, to store vast amounts of Canadian ferrous metal at the Log Pond, and then ship it to places such as Vietnam and India.

Land Use Designation

When the Port and ABC Recycling came to an agreement and signed the lease, one assumes it included promises to ABC that the land could be used for heavy industrial storage of ferrous scrap metal, moving the metal, and shipping it. In February of 2022, around the time these negotiations and decisions were being made, the City of Bellingham hired a new planning director, Blake Lyon. Steve Sundin, a long-time senior planner within the Planning Department, and the City’s lead planning contact for the Shoreline Master Plan, and the Bellingham Waterfront, allowed the activity to proceed under the Land Use classification of BMC 20.37.420.E.10, a Barge Loading Facility. Two permits were issued: one for a truck scale, and one for a portable office. 

This E10 Land Use determination was incredibly beneficial to ABC Recycling. It meant the project could move forward without additional review by the Planning Department for further mitigation of the project for issues such as noise or size. It also allowed ABC to work any time, day or night, and create massive piles of used metal in the middle of the Bellingham Waterfront.

The Bellingham Municipal Code, under 20.16.010.E7, states that the Director must “Not create influences substantially detrimental to neighboring uses. “Influences” shall include, but not necessarily be limited to: noise, odor, smoke, light, electrical interference, and/or mechanical vibrations.” To translate, even if a Permitted Land Use fits the bill, it must still be mitigated if it is large, possibly unsafe, and/or emits noise that disturbs thousands of people.

Further, the Waterfront Sub-area Plan calls into question ABC’s ability to use the land at the Log Pond. It designates the Log Pond as a place for “transportation, construction or light industrial uses,” and/or “light manufacturing and assembly, high technology, and research and development.” 

But, upon review of the actual usage, the dust plumes and noise emanating from the property, the hours of operation, the size of the piles, and the possibly hazardous nature of the material, it is clear the land is being used for Heavy Industrial applications.

The Port of Bellingham has the right to lease their land, and although it seems contrary to good business practice of a prime piece of real estate, they have the right to lease their land for 25 years. What they do not have the right to do, is to operate a metal recycling collection facility without environmental mitigation, as dictated in Bellingham Municipal Code. Neighbors have called on the city to correct the use to F11, a Recycling Collection and Processing Facility. This designation correctly defines the use, and mitigates the high industrial nature of the activity. The City continues to insist that E10, a Barge Loading Facility, is the correct use. The Planning Director Blake Lyon has all power in this situation.

Environmental Protections

There is deep concern for the challenges the Metal Pile places on our environment. The State Environmental Protection Agency uses a system of checklists and rules to determine whether a project will have environmental impacts that must be mitigated. It is called a SEPA review. So far, we cannot determine whether a SEPA checklist was completed, nor whether there was a Determination of Non-significance. It has been suggested by some experts that the City or the Port were not fully aware of the extent of the Use when any environmental review occurred. If this is the case, the City has the right to revisit the Land Use classification of E10, as well as review the activity under SEPA.

What is obvious is that the Metal Pile is massive and difficult to control regarding water and air pollution. We know that dust plumes blow from the southwest to the northeast. The new Mercy affordable housing complex, including a childcare center, is northeast, as are new condominiums, a planned hotel, and the Waterfront Playground. Departing barges can be seen leaving a trailing red dust cloud over the Bay. 

As early as December 2020, when the Port signed an Option Agreement with ABC Recycling, the Department of Ecology became involved. In a rare move, due to the lengthy lease term, and enormous size and scope of the project, Ecology has required ABC to have its own Wastewater Permit.  As of January 2023, ABC Recycling continues to pile, store, and move massive amounts of Canadian scrap, feet from the Bellingham Bay shoreline without the required wastewater permit.

There is a lot wrong with the Metal Pile. The Port, though, continues to call the ABC Recycling scrap pile a win for the community. Here are the wins: 18 local union jobs (6-9 full time equivalents) working a total of 20 shifts every 2-3 months, lease of the Log Pond at $200,000/year, and shipping terminal fees accrued while loading. 

What has it cost? Environmental damage, the health and safety of those downwind of the Metal Pile, damage to protected eel grass beds below the ships, thousands of hours of sleep and peaceful enjoyment of their homes by residents, and the possible loss of many union jobs that were planned for, under the Waterfront Plan.

Bellingham’s future is on a cusp. ABC Recycling is planning a metal shredder just north of the Birchwood residential neighborhood, near the cement factory. If completed, 40 trucks a day spewing heavy metals will travel through Bellingham, in a loop to the Metal Pile. Hazardous waste will be added to our landfills, as the scrapped car and appliance ‘residues’ that cannot be recycled must go somewhere. But that is for the future.

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Since 2007, this moniker has been used over 150 times on articles written by guest writers who may write once or very occasionally for Northwest Citizen, but not regularly. Some guest writers [...]

Comments by Readers

Liz Marshall

Sep 28, 2023

Thanks to Scott Jones for continued excellent work.

Considering numerous industrial violations discovered in autumn 2022 official state government inspections (violations right at the start of a new lease!), I wonder why the Washington State Department of Ecology (or US Coast Guard or US Army Corps of Engineers etc.) didn’t revoke ABC’s license to operate. There is also the Governor’s task force -

Curiously, today September 28th is World Maritime Day 2023. The theme this year is “Celebrating 50 years of MARPOL.”  MARPOL is an abbreviation for marine pollution. The International Maritime Organization’s position is that marine pollution is a BAD THING and the organization works to prevent it, rather like various municipal, county, state, federal, trade and lobbying agencies the world over. | SAFETY4SEA

 #marinelife #marinepollution #fridays4future #foragefish #eelgrass #BellinghamBay #WhatcomCounty #USACE #IMO #MARPOL  #worldmaritimeday


Thomas Gilmore

Sep 28, 2023
Bellingham’s mayor and city council, Whatcom county executive and council members, all Port of Bellingham council members and staff, and the local Washington Department of Ecology need to seriously consider the recent corporate actions by ABC Recycling on the local community.  Public corporate testimony and transparency by ABC Recycling officials and community feedback are necessary.
For example:
  1. Does an environmentally safe metal shredding plant currently exist?  Can local leaders examine  or visit this environmentally safe, quiet, and traffic friendly plant? What would the permitting process actually involve to build a similar closed plant in Bellingham?
  2. What are the local zoning requirements and environmental regulations for this metal shredding plant?  Do they need to be changed or updated? How would they be enforced to prevent violations?
  3. What technology would be used to contain volatile organic compounds (VOCs), hazardous air pollutants (HAPs), and nuisance odors. More importantly, how and where would these cancer causing compounds be stored and later disposed of in a safe and secure land fill?
  4. Why would ABC Recycling, a Canadian company, not want to build this environmental friendly and job creating plant at one of their sites in British Columbia? Could the less restrictive USA environmental laws and requirements be a factor motivating ABC Recycling to favor Bellingham?  Semi truck transportation to Bellingham by Canadian drivers for millions of tons of metals every year must be very expensive.
  5. After ABC leases run out how much will it cost to clean up another toxic waste site? Our local leaders already spent millions of dollars cleaning up up the contaminated dioxin and mercury laden soil from the old Georgia Pacific paper plant. How large of a cash clean up bond would be required by the Port for ABC Recycling?  It would now be wise to read the Wendy Harris article “Bellingham’s Dioxin-Contaminated Mountain” in the February 2013 issue of Whatcom Watch.
  6. Since ABC Recycling’s shredder plant plans will not be revealed until after the local November elections, would the companies spokesman, Riley Sweeney, like to comment on the following 94 page report: State of California, Department of Toxic Substances Control—Evaluation and Analysis of Metal Shredding Facilities and Metal Shredder Wastes 2021 content/uploads/sites/31/2021/08/2021.08.09_Metal_Shredder_Analysis.pdf
Thomas Gilmore

Dick Conoboy

Sep 28, 2023


Meanwhile over at the Whatcom Watch.  Click here for the complete article.

“Now, ABC has purchased 20 acres on Marine Drive from Lehigh Cement for the purpose of installing a highly polluting metal shredder, and the stakes just went up. Way up. Marine Drive is the location where cars and appliances will be shredded, trucked to the waterfront by truck after truck, then sent overseas creating a noisy waterfront operation no one expected to be so large. Probably not how you want to envision Bellingham.

Bellingham and Whatcom County will be the end point for thousands upon thousands of truckloads of scrap metal coming to Marine Drive mainly from western Canada. The port signed a lease for 15 years, with an additional 10-year option. Bellingham will bear the brunt of all the impacts from shredding, trucking, dust, pollution, and noise. It is high time before the November election for public conversations to occur about whether these particular land uses are in the best interest of the community at large.”


Thomas Gilmore

Sep 28, 2023
More Question for ABC Recycling:
1.  Why doesn’t ABC Recycling do all this wonderful metal recycling, and
demonstrate their corporate environmental concerns in British Columbia? 
2.  Why waste all the the time, money, and diesel fuel shipping the metal
to Bellingham? Trucking tons of metal just adds more green house
carbon dioxide to the atmosphere thus warming the planet? 
3.  Why not build their amazing metal shredding plant to create “clean
the safe living wage jobs” in beautiful British Columbia?   
4.  Why not build a steel mill in BC and avoid all the wasted labor and
fuel shipping the metal to India.  But we know the answer to that question—
India has extremely cheap labor costs and very few environmental restrictions!

5. Could the city of Bellingham annex the old cement plant land so 

that it falls under Bellingham city zoning and environmental ordinances? 
So far Bellingham’s official response seems to be: We have no authority over
port land, or over the old cement plant on county land. We can’t do anything
concerning any type of marine water pollution, noise, or air born dust problems.

Thomas R. Scott

Sep 28, 2023

Foresight vs. hindsight.

This contention is precisely what was foreseen by several members of the Mayor’s Neighborhood Advisory Commission (MNAC) roughly four to six City administrations ago.  They were first ignored on this topic, then steamrolled, then pushed aside, then made nearly completely irrelevant as the administrations came and went.

Those individuals, back at 2003 and a little hense noted that the City Leaders were removing 128 acres of industrial land in a massive rezone that partially disallowed such uses as well as shrinking opportunity for those dependent on industrial jobs.  They also noted that even if future industrial land was to be designated to attract such jobs for many of our neighbors within and without Bellingham, that it would create another location on which to mitigate environmental issues.

It should be noted, that before all that, aluminum ingots were staged in a nearby area and then moved and loaded onto ships in a somewhat similar manner.  Further, it should be noted that Bellingham grew up around an industrial waterfront and from the jobs that it created.

Conversely, from Scott’s article’s detail, it does seem a little additional “slap-dash” has ocurred, again with little foresight on the part of Planning.

Both of these issues are recurrances of a theme here in Bellingham.  In general, we seem to not look at down the road consequences.  For instances, the loss of GP (which was already on its way out but…) the then mayor went back on a handshake deal overnight (litterally) causing jobs and taxes to evaporate withing months while leaving an environmental disaster sight on our waterfront.  All that was over a situation that was about to go away permanently in just a few weeks.

The second recurring problem on this theme is our Planning Department.  It continually ignores what seems obvious to others what the down-the-road use for a property for which they issue permits, often having been warned by the “others” (lowly Bellingham citizens) that what they are actually permitting is something entirely beyond what they are signing off on.  I would say, “much to their chagrin” but I have yet to see once of them indicate any chagrin as to the results of their having ignored that those they have done business with have planned all along (evidently, when many said businesses have repeated  their misbehavior for decades.

From Scott’s article, it would appear that some mitigation may be obtained for the focus of this particular article.  However, this is but an illustration of Bellingham’s lack of foresight and self-inflicted wounds in how we handle our zoning and permitting.


Geoff Middaugh

Sep 29, 2023

Excellent article, Scott, and thank you for your diligence.  And excelleent comments also.  One question I have:   Is anyone focusing on the need for permits for wasterwater and particulate emissions at the Waterfront.   From what I can tell, ABC Recycling is operating without a wasterwater permit from DOE, nor an emissioins permit from NWCAA.  From what I can tell, a wasterwater permit and emissions permit are required from the state of Washington to enforce the Federal Clean Air Act and Clean Water Act.   These state permits are not in place, and how can operations contnue without them.   



Geoff Middaugh

Oct 02, 2023

A legal notice SEPA DNS was posted in today’s  (October 2, 2023) Herald.   It seems this is a step forward.  We (the public) should comment to Whatcom County in support of a year’s moratorium on applications.  Note the short 14 day comment period.  




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