This is what the city SMP (Shoreline Master Plan) regulations, cited in the staff report for the G Street Stairwells and new trail, require for the G Street pocket beach:
22.02.020 Shoreline goals.
k. Squalicum, Whatcom, Padden and Chuckanut Creek estuaries as well as other tidally influenced lagoons or pocket estuaries and pocket beaches should be restored in order to provide an improved level of habitat function and processes. These pocket estuaries are valuable for their diversity of aquatic and upland species habitat opportunities and their ability to support non-natal anadromous fish. As redevelopment occurs adjacent to these areas, these estuaries should be restored to achieve the following:
i. Improved tidal floodwater attenuation;
ii. Improved nutrient filtering and recycling;
iii. Higher quality shellfish habitat;
iv. Increased biological support and habitat value for juvenile salmonids and other upland species;
v. Shoreline stabilization and large woody debris (LWD) recruitment via native vegetation.
l. Restoration efforts should be consistent with the Function Analysis sections for each shoreline reach within the 2004 City of Bellingham Shoreline Characterization and Inventory (SCI).
m. Bellingham’s shorelines and their ecological functions should be inventoried simultaneous with future updates to the shoreline master program and the city’s critical areas ordinance in order to determine if there has been a net gain in overall ecological function of our shoreline areas and within our watersheds.
n. Conservation efforts should be focused on protecting and sustaining ecological functions via protection with conservation easements or dedications to the city of Bellingham for public benefit.
o. Restoration should occur as remediation of contaminated sediments or sites occurs within shorelines and should result in a net gain in shoreline ecological function.
c. Development should take appropriate steps to avoid shoreline modification and stabilization, utilize a range of low impact development techniques, minimize site disturbance, and avoid or minimize impacts to critical areas within shorelines.
d. Redevelopment should be encouraged to improve ecological functions and restore riparian buffers where feasible.
So let us summarize. Under the SMP, the city is required to protect and restore pocket beaches because they are very valuable to nearshore and upland species. As redevelopment occurs, these areas require improved ecological function (this is beyond the normal “no net loss” standard, which prevents degradation but does not require improvement.) Development should avoid shoreline modification and stabilization, and should restore riparian buffers where feasible. An inventory is required to establish a net gain in ecological function.
In reality, this was what we are provided: (See photos.) The city has placed concrete stairs, which act as a bulkhead, in the pocket beach uplands. This acts like a shoreline modification. All the vegetation was ripped out of the riparian buffer. The G Street beach is littered with invasive varnish clams so that problem has not improved. The driving, and only, consideration was public access. There was no attempt to minimize impacts to the shoreline. In short, the city did the opposite of everything it was required to do, and covered it up by citing to other provisions of the SMP.
The Parks Development Director announced to council last week that the city intended to put trail and stairs down to other pocket beaches, and it is also attempting to exempt city public projects from the requirements of the Critical Area Ordinance under the GMA. The city REFUSES to do any inventory and assessment of wildlife,habitat or habitat corridors which is the prerequisite for a baseline standard to review ecological function. In fact, the planner director is actually asserting the city has no obligation to do this for the CAO.
The city has allocated only a 25 foot habitat buffer within the entire waterfront district and within that buffer it is siting a walking trail and a bike trail, (i.e. it is destroying the value and purpose of a buffer.) And it is ignoring the intensity of use impacts and the conflicting adjacent land use conflicts that will also impact the buffer.
So, when the city asserts that the waterfront redevelopment will improve habitat for wildlife, that is a bald faced lie. I am not sure how to make this any clearer. It distresses me when I see people repeating this lie. Let us at least be honest about the total cost of the waterfront, because it becomes much more expensive once the ecological carnage is included.