The City of Bellingham administrative staff continues to manipulate the waterfront planning process to its own advantage. Waterfront planning must be reflected in the waterfront district subarea plan, approved and enacted by the council, and clearly, this should include the overwater walkway that will connect Boulevard Park to the Cornwall Landfill. Instead, staff has advised city council that this project is a done deal.
If the overwater walkway is not part of the waterfront planning process, why is it continually discussed and included in the waterfront discussion? Why is waterfront funding being used to pay for this project? Why was $4 million in Greenway Levy funds, identified by voters to create waterfront district trails, allocated to the OWW? Why has the OWW been identified, along with the Cornwall Park, as a priority waterfront project? Why is the city holding a public meeting for the Cornwall Park master plan which includes the overwater walkway? These are the real questions that govern the matter of whether the OWW is an independent, predetermined project, or whether it is part of the current and on-going waterfront planning process.
At the same time, staff attempts to hide behind legal fiction and technicalities to avoid accountability. It asserts that the OWW is part of the South Neighborhood District, and therefore, not subject to waterfront district planning review. Staff should not be allowed to pick and choose when it will treat the OWW as a waterfront district project, and when it will not.
The city is attempting to piecemeal its obligations in a manner that is contrary to SEPA provisions. The reality is that the OWW impacts Bellingham Bay, the same marine resource that will be impacted by all other waterfront development. Marine resources can not be divided by artificial neighborhood boundaries. All waterfront projects, where ever located, are ecologically connected and must be treated as such. This is particularly true when they are drawing upon the same funding sources and staff resources for implementation, and are moving forward concurrently.
Please consider these other factors as well:
- There has been substantial public objection and controversy over this project by the environmental community, the Lummis and local residents, which the city has ignored. Please review the public comment tracker (76 pages) and the SEPA Comment Response Matrix (36 pages) found on the linked project website. The City is falsely stating there is overwhelming support for this project. http://www.cob.org/government/departments/parks/projects/boulevard-over-water-walkway.aspx.
- There has been no NEPA review, or at least a public determination by the WSDOT that it will not be conducting a NEPA review. Public controversy is an important concern in making a NEPA classification. Neither the state nor the city will advise me of when and where the information regarding the NEPA process will be published.
- The city requires WSDOT approval for the OWW, and my last information is that the city permit is still on hold. The city is proceeding with OWW development without the final approval required by the state.
- The city and the Lummi have not publicly announced a resolution to the conflict over OWW impacts to treaty rights and until this is settled, the OWW can not move forward.
- Because the OWW impacts the same marine resource as waterfront redevelopment, it should be included in the EIS analysis for Bellingham Bay, particularly with regard to cumulative impacts. It was not.
- Overwater walkways are highly discouraged by DOE because they are very damaging to the marine environment. The city is planning no mitigation other than a required eelgrass project, and has it has filed a marine mammal take permit due to impacts on harbor seal habitat.
- The city has run into continued problems with its eelgrass mitigation project required by WDFW for the OWW, refusing to make adjustments in analysis and planning necessary for proper mitigation. It failed to consider the impacts of the OWW landing at the Cornwall Landfill, and WDFW put this project on hold pending permit approval by WSDOT.
- We have recently learned that the city does not plan to review habitat connectivity as part of waterfront planning, and that it has allocated zero waterfront funding to shoreline restoration projects. Habitat connectivity is particularly important for an overwater structure that is a half mile long, and is connected to existing overwater structures because this amplifies the harmful ecological impacts.
Is anyone going to hold the city administrative responsible for its manipulation of the planning process? If the OWW is a done deal, it is not entitled to consideration as part of the waterfront planning process, and it is certainly not entitled to any portion of waterfront funding that becomes available. Instead of providing a meaningful response to public concerns, the staff summarily dismisses the credibility of those raising objections, and unfortunately, the city council appears to be accepting of this.
Please hold the staff accountable for the contradictory position it has taken on the OWW. Requesting waterfront handouts while proclaiming project autonomy is unjustifiable and not in the public's best interest. Attend the city public meeting on the Cornwall Park Master Plan on Wednesday, Oct. 16, 2013 from 7-8:30 PM in the City Council Chambers, and tell the city staff what you think. Please consider sending a letter to the City Council and to Mayor Linville as well. Finally, when the federal government is functioning, consider a phone call to Senator Patty Murray's office, since she provided the earmarked funding for the OWW project.