October 17, 2016 Wendy Harris
The Samish Crest Logging Application; SEPA Review
(Comments Due 10.19.16)
Need another reason to be concerned about an attempt to log 30% of this undeveloped habitat corridor in advance of eventual multi-million dollar homes?
How about this? Old Growth Forest. We should NEVER be cutting down old growth forest. There is one stand on this lot and one stand of mature growth (more than 2nd growth, but not yet old growth.). There are high value wetlands that will be lost.
Tell COB [City of Bellingham] to provide the public with more time to comment on this project, which almost no one has heard about yet. It is removing trees in the last large remaining habitat greenbelt running up from Lake Padden to Samish Hill. The city failed to include a habitat conservation area report, which is required for development within a habitat conservation area.
Please write to firstname.lastname@example.org.
Below is one of my comments.
You have failed to obtain all required critical area reports as required under state and local law. The Bellingham CAO [Critical Areas Ordinance], at 16.55.470.A.7 classifies land useful or essential for preserving connections between habitat blocks and open spaces as a habitat conservation area, triggering a requirement for a critical area report. Additionally, the applicant was advised in writing that, “If there will be any work within Critical Areas or their buffers, submit a complete Critical Areas Permit.” The wetland review update, using the 2014 DOE [Department of Ecology] wetland rating system, indicates that this is high value habitat, both for townsend bats and for old growth forest. It fails to reflect this area as an important habitat corridor and last large green belt in the city that connects greater Bellingham to Lake Padden.
The city has failed to conduct an updated terrestrial wildlife inventory and analysis for protection against no net loss. It can not hide behind its lack of due diligence and GMA compliance as an excuse for lack of knowledge regarding the protected species that may be present. We do know that the Padden watershed is a biodiversity hotspot because it is the largest protected contiguous open space within the city, with the greatest habitat diversity, second only to Chuckanut in known species abundance, as documented in the 1995 COB Wildlife and Habitat Assessment and Wildlife Habitat Plan by Nahkeeta Northwest.
It was noted at the time that only limited wildlife field studies had been conducted, and “with the severing of corridors, increased human development and related disturbances, clearing, wetland loss and more domestic predators, the Padden wildlife community is in the need a baseline study, monitoring and habitat restoration.” At the time, a number of bat species existed within the watershed and a great many bird and mammal and reptile and amphibian species were believed present. The report noted that providing the necessary corridors so that populations are not isolated will require forethought in planning and restorative and enhancement action by the city and its citizens. To date, that forethought remains missing. While the Padden creek daylight project was nice for fish, the placement of people and bicycles in the riparian area has limited its value for terrestrial wildlife.
This project site (Samish Hill) was identified as a major habitat reserve. Identification and preservation of viable habitat corridors was considered a very high priority, requiring buffers of at least 100 feet. It was emphasized that “on site assessment is needed for all projects that may alter wildlife habitat.
Because there is no HCA report, this SEPA review is premature, and based on the information discussed above, at the time a SEPA review is appropriate, a DNS determination is unlikely to be adequately protective.
Therefore, I request that you rescind the SEPA and deny the land use application until this case is properly developed and adequate protection and mitigation is provided that will satisfy the no net loss standards necessary for GMA compliance. I suggest that the city incorporate this area into its habitat corridor and open space identification required under the GMA. Given the importance of this issue, an optional DNS process, which provided only a level 2 process is not appropriate and should not be used.