Environment Chapter

City of Bellingham Comp Plan Update Review

Thank you for your work on this important Comp Plan update. The materials offered as review of Comp Plan chapter updates via PowerPoint are ineffective as the content is strictly a conceptual outline. There is no detail to review. These chapters are more closely scoping documents submitted for comment before the actual work is conducted. Although providing the public with opportunity to comment is always welcomed, we question the effectiveness of issuing PowerPoint presentations that only provide a very rough conceptual-level of detail that summarizes what the City plans to do. Given that fact, we offer the following comments on both the Climate and Environment chapters.

Environment Chapter:

Slide 1:
There is very little content to review and comment on in this brief PowerPoint presentation.

Slide 2:
There must have been many more “most common” opinions presented during the scoping phase. How did the City objectively determine the most common opinions?

Slide 3:
“Streamlining the chapter” may be a goal of Comp Plan update, but if streamlining is used to update the Comp Plan, then aggressive incorporation by reference and citations must be used so it is clear that best available science was used to update the Comp Plan. Will there be a Best Available Science technical report companion to the Comp Plan?

The referenced “Summary of Proposed Updates” provides even less information than this PowerPoint presentation.

Slide 4:
An explicit topic area should include streamflow and water supply, which are major determinants of growth allocation and planning. This topic area also supports the other already mentioned topic areas.

Slide 5:
No comment.

Slide 6:
There really isn’t any concepts presented in this PowerPoint presentation.

Slide 7:
“Aquatic ecosystems” should include the water availability and supply to sustain these ecosystems and tier to the Climate chapter.

“Water quality and quantity” should include the impact of land use on water availability and supply as well as water quality.

“Coastal resiliency” should include mitigation of sea level rise impacts.

“Urban forest benefits to water”, excellent to include this topic. It seems that the rate of forest cover removal in the City due to development exceeds the rate of forest cover protection and increase, a goal of the urban forest plan.

Slide 8:
“Terrestrial Ecosystems”. This topic area should include urban wildlife corridors.

Slide 9:
“Natural Resource Management.” The body of best available science needs to be updated from the current Comp Plan (2016). Lots of relevant science has been accomplished since 2016.

“Control invasives” should include requiring job site power equipment to be power washed between job sites to reduce the translocation of invasives.

“WRIA 1 coordination” should explicitly include water supply, water availability, and water rights, not just “water.”

Slide 10:
“Human Health and Environment.” “Promote urban tree canopy”, this goal needs to include not just “promote”, but increase urban tree canopy to offset climate impacts, including the heat island effect.

Slides 11-14:
No comment.

I am pleased to hear that the City has taken steps to encourage a reduction in plastic usage. This should be a priority in the coming years, for the sake of the environment and human health, and the City should work with county, state, and non-governmental partners to accelerate these reductions.

To boost biodiversity and urban forestry, the City should repurpose underused car infrastructure (shared turning lanes with nowhere to actually turn into, empty parking spaces, missing bumpouts/pinch points/chicanes, etc) into green infrastructure.

Using these spaces for native plants supports pollinators, protects against atmospheric rivers, and cleans the air — what’s not to like?

For examples of what this looks like in action, cities like Paris and Utrecht are already doing this in a big way, and we can, too.

Our reliance on grey infrastructure and lack of tree preservation has lead to unhealthy water quality, and we need to have responsibility for these declines imbedded in urban planning. Right tree right place needs to be replaced with best tree right place, not all trees are providing the services we want from an urban forest.

Protecting urban ecosystem functions can be done as is demonstrated in many places. Planning for these to be measured and incorporated throughout, and not traded off-we build density and somehow that means ecosystems are saved elsewhere is not a realistic measure. Creating density and providing for ecosystem services everywhere is needed. Shade or habitat does not travel across distances, and can not be relegated to a park.

I love the addition of human health and welfare. Please consider connecting with disability communities and ensure accessible access to nature spaces.

I love the addition of human health and welfare. Please consider connecting with disability communities and ensure accessible access to nature spaces.

Please do not use more turf and rubber byproducts for the unknown impacts of it on 66PDQ contributions. This includes athletic fields. It would be deeply problematic for our obligations to preserve salmon. Also streetcars could reduce the amount of traffic via tired vehicle and replace it with steel wheels.

As I read through both Chapters on Climate and Environment I am not seeing specific policy verbage in regards to the kinds of job creation we want to see for the next 10/20 years. For example, the detrimental environmental footprint of industrial operations which also hire minimal workers for the square footage they occupy, would impede progress toward 2025 outlined goals in the immediate and long term future when considering cleanup costs, risks to human health and aquatic and land species, air pollution, resource extraction, etc. This topic deserves more attention, I believe, as we need to transition toward responsible and thoughtful commerce that supports healthy, sustainable and ample jobs for generations to come. Job training should be part of this evolution.

In places where buildings with large lawns/yards aren't being infilled, we should encourage and help owners to plant native plants instead of grass lawns to support biodiversity and water conservation. This could be also a great opportunity to partner with the Lummi Nation, Nooksack Tribe, Western, and/or WCC to support these efforts.

To protect water quality, habitats, and human health, the City must have a waste management strategy, especially to reduce plastic usage as much as possible. Plastic is well-known to be harmful to people, other animals, and plants, and recycling is not a viable strategy to substantially reduce plastic production (less than 10% of plastic is recycled). Through stronger waste management regulations and collaborations with local businesses in the city and county, Bellingham should work to support alternatives to plastic wherever possible, as well as advocating for state-level support for the same purpose.

Under Natural Management, my concern is about the open spaces (Samish Crest) where large amounts of debris/slash could end up fueling a substantial wild fire, threatening us here on Samish Hill. The issue has not been addressed as far as I know.

Any serious effort to address environmental concerns must focus on alleviating auto-dependence. That means 1) a fully connected network of protected bicycle/rolling infrastructure that includes all destinations, 2) removing density restrictions on housing, and enabling mixed-use in all neighborhoods, so that residents may walk or bike/roll safely to work, to stores, to coffee shops, 3) expanding tree cover, especially in the neighborhoods with the least coverage, by removing street parking on the approach to intersections, 4) adopting dynamic pricing for parking that reflects its true costs rather than subsiding automobiles

Staff Note: Comments made early than this one were based on an older version of the chapter material released in November 2024.

The Environment goal of GMA (RCW 36.70A.020(10)) was amended in 2023 to require the enhancement of the environment, not just protection. We do not see anything in your November 2024 Environment Chapter Update Summary that indicates the measures you propose to enhance the environment in Bellingham.

Answers to some of our questions are often found in the environmental review of proposed plans, where the public and decision-makers can see “one or more alternative means of accomplishing that goal {GMA Update] and the environmental effect can be meaningfully evaluated.” (WAC 197-11-784) The project timeline does not include any reference to when you will comply with the State Environmental Policy Act (SEPA). The growth alternatives in the Whatcom County Environmental Impact Statement (EIS) regarding greenhouse gas emissions, vehicle miles traveled, fish and wildlife corridors should be available before you move forward with many elements of your plan.

Removed by moderator.

Hello. Thank you for your commitment to the natural environment of Bellingham, and for providing this opportunity to provide input. The following excerpts from the Environment Chapter's Update to the Bellingham Plan are of particular importance to my wife and I, our family and friends.

"....a healthy natural environment is a major strength of Bellingham...."
"We care about trees...[they need to be honored and respected] to be balanced with growth and increased density."

"Balance natural resources with development – speaks to importance of balancing competing interests...."

"Promote native plants" [Preserving existing, healthy, flourishing old-growth trees certainly qualifies as promoting native plants (e.g. The trees at Lat: 48.745535 Lon: -122.460902)].

"Stewardship"
"Environmental equity."
"....minimize environmental burdens...."
"Consider the environmental...value of trees; encourage tree preservation...." [a good place to interject something "big missing" which is including for consideration the already-threatened habitat for the animal wildlife of our fair city; they are so dependent on the existing ecosystems that are ever-dwindling]

"Promote urban tree canopy."
"Outdoor air quality."

Thank you.

The Human Health objective is tightly tied to existence of tree canopy. Street trees as they are being planted now are not meeting any of these objectives, because the species are to small, and will never provide the kind of benefits we are looking for - an example is downtown with the street lined with Sycamore trees, and then the area of Holly St uphill from State St. There are trees there but they are providing no benefit. Substantial tree rules that use metrics such as the 3-30-300 rule can help avoid outcomes that do not map to our values and policy statements.

I love this part of the new Bellingham Comprehensive Plan. You have put a great deal of thought into this lan and this part is the best. I see most people agree. As a child, it was thrilling to watch the salmon negotiating the fish ladder under the Guide near Cornwall Park as Squalicum Creek flowed underneath. I applauded your efforts as well as the state’s to increase salmon populations by improving culverts and other fish passages.

Please spare the large deciduous trees near the current Carl Cozier school. These lend magnificent shade to an area with so much concrete and asphalt. What s great location for picnics and story time.

Please keep the digesters and acid ball. They are a big part of Bellingham’s industrial history. As someone who worked there for a few years thus enabling me to fund my college education, I would like then to remain. Seattle has its Gasworks Park, we have the remnants of GP.

Yes, to everything outlined in the Environment chapter. Honestly, I’d love to see a car-free downtown (bring back the trolley on Railroad Ave!) as much as possible, coinciding with an increase in trees, native plants, and downtown nature parklets. It would also be lovely if we could remove the last vestiges of the old GP plant (digesters? Acid ball? Really?) and convert that area into a public mixed-use space with waterfront views and access (maybe a Coast Salish museum? A PNW native plant park? For a city surrounded by water, it sure has a limited number of places to get near the water!

Focusing population growth in the City of Bellingham will reduce the potential for sprawl into the rural areas. By allocating the majority of population growth to the City we can reduce the carbon footprint associated with driving into town for work, housing incursions into flood prone areas, ag lands, resource lands and open spaces throughout the county.