The Port of Bellingham and the City of Bellingham have proposed revisions to the Waterfront District Subarea Plan that will be the subject of Bellingham Planning Commission review beginning on March 14, 2013. The planning commission will hold two public hearings for the revised plan on March 21 and March 28. Few people are aware that the port and city have already revised the Environmental Impact Statement (EIS) to reflect this revised proposal.
After quiet consultation with the city, the port issued an EIS Addendum on December 14, 2012, modifying the 2010 preferred alternative for waterfront redevelopment plans. We now have an Updated Preferred Alternative.
This is a marked change in policy from 2008 to 2010, when the public was involved in the drafting and redrafting of four SEPA EIS documents, including a first draft EIS (DEIS) in January 2008; a supplemental DEIS in October, 2012; an EIS Addendum in February 2010 and a Final EIS (FEIS) in July, 2010.
If Mayor Linville is as committed to public transparency as she asserts, why didn't the city and port wait until after public input and planning commission review to determine whether the existing SEPA document needed to be revised? Or provide public notice and opportunity to comment on the EIS amendment, as was done for the 2010 EIS addendum?
It is questionable whether the 2012 EIS Addendum complies with the State Environmental Policy Act (SEPA). According to WAC 197-11-600 and 197-11-706, an Addendum is an environmental document used to provide additional information or analysis that does not substantially change the analysis of significant impacts and alternatives in the existing environmental document.
Under the 2012 EIS Addendum Updated Alternative, there will fewer parks, reduced residential and office development, more industrial development but fewer jobs, increased traffic and congestion, and an expanded waterfront district boundary.
The port and city assert that these changes are not substantial. I disagree. This is a revised land use plan. It modifies the existing EIS Preferred Alternative, and reflects more than additional information or analysis. This exceeds the port's authority under the SEPA addendum process. Changing the 2010 EIS Preferred Alternative ignores prior and extensive public involvement in the SEPA process and reflects, at minimum, an insensitivity toward public process.
Chapter Two of the EIS Addendum compares the 2010 Preferred Alternative to the 2012 Updated Preferred Alternative, with interesting result. According to a table in the EIS Addendum, waterfront jobs will be reduced by 1825 under the revised plan. (Table 2-2, Page 2-3 of the Dec. 2012 EIS Addendum.) I hope this reflects a mistake, or sloppy drafting, because the loss of 1825 waterfront jobs is substantial and this information has been withheld from the public. I would like the port and city to confirm the number of anticipated jobs under the 2010 and the 2012 EIS, and to show us the method of analysis employed.
I would also like to know why the waterfront district boundary has been increased by 21 acres, most of it in the steep, geologically unstable bluff above and below the South Bay Trail, as this land separates the Cornwall Landfill and R.G. Haley sites from the rest of the city. (EIS Addendum, Figure 2-1, page 2-6.)
The port states that this fills a zoning gap between the waterfront district and the Sehome neighborhood. (EIS Addendum, page 2-5.) This is factually incorrect. According to the city neighborhood base map, this bluff is included within the Central Business District, not all of which is part of the waterfront district. I am concerned the city and port may have designs for this land that are not being disclosed.
If future transporation plans exist, there is good reason not to make this information public. The city is still waiting to receive federal grant money for the overwater pedestrian bridge. The funding is available only if there is no alternative transporation route to connect Fairhaven and Boulevard Park to downtown. In other words, now is not a good time to call attention to the South Bay Trail. However, earlier waterfront plans noted the potential to connect South Bay Trail to the future Cornwall waterfront park, which would also provide connection to the overwater pedestrian bridge.
I am looking forward to these issues, and others, being clarified during the public process and review before the Planning Commission.
