# Bellingham's Environmental Guardianship — A Day of Major Decisions for Wetlands and Water On a crisp October afternoon, the City of Bellingham's Public Works and Natural Resources Committee achieved a significant milestone in environmental policy, advancing two major initiatives that will fundamentally change how the city manages its natural resources for decades to come. After nearly a decade of meticulous planning, the committee unanimously approved a groundbreaking mitigation bank ordinance and adopted a comprehensive rapid response plan for invasive freshwater mussels threatening Lake Whatcom. The meeting, chaired by Council Member Hannah Stone and attended by Council Members Lisa Anderson and Jace Cotton, represented the culmination of years of careful preparation. Council Member Dan Hamill joined remotely, demonstrating the importance of these decisions. Both agenda items passed unanimously, signaling strong council support for the city's evolving environmental stewardship approach. ## The Bellingham Mitigation Bank Takes Shape — Nine Years in the Making The star of the afternoon was Agenda Bill 24695, establishing the framework for operating the Bellingham Mitigation Bank — a revolutionary approach to wetland conservation that transforms how development projects handle unavoidable environmental impacts. Analiese Burns, Acting Public Works Assistant Director for Natural Resources, presented the ordinance with barely contained excitement about reaching this milestone. "We are at a very exciting milestone," Burns told the committee. "We've been coming to council pretty regularly over a period of years. Last time we were here was in 2024 about a year ago, and I'm pleased to provide some pretty important updates and we are on schedule." The mitigation bank represents a fundamental shift away from the traditional "permittee-responsible" mitigation approach, which Burns described as plaguing the region with "high rates of site failure, low ecological value, inefficient land use, and development project delays." Instead, the bank will consolidate many small mitigation projects into larger, more ecologically connected sites where wetlands and streams are restored, enhanced, or preserved before impacts occur. "A bank instead does the reverse," Burns explained. "You have to have the ecological performance working and have proved that's working before you can sell the credits." The approval process for establishing a mitigation bank is extraordinarily complex and lengthy. Burns detailed how the process is led by the Interagency Review Team, co-chaired by the Washington Department of Ecology and the U.S. Army Corps of Engineers. The process typically takes five to ten years in Washington State — the city has been pursuing this since 2016. "It's a very formal process dictated by state and federal rules," Burns emphasized. "It's not something that we make up. This is a very formulaic process." The ordinance establishes several critical operational components. Credit pricing will be determined by a finance committee consisting of the Public Works Director, Finance Director, and Mayor or their designees. The pricing will consider factors including the cost of operating the bank, market rates from other mitigation banks, and ensuring a reasonable return on investment. Perhaps most significantly, the city faces a unique challenge: unlike most mitigation banks that have abundant credits available, Bellingham anticipates having limited supply relative to demand. This scarcity requires careful management through the bank's operating principles, which prioritize ecological benefit, city project needs, city development goals, and bank solvency. Council Member Anderson expressed particular excitement about the project while raising important questions about long-term planning. "I've been excited because mitigation banks fill up pretty quickly in this region," she noted. "With our TIP and some of our other plans, I'm just wondering has potential mitigation bank needs been addressed for like the next 10 years?" Burns confirmed that the city has conducted extensive analysis and continues updating forecasts, looking out seven years for city project needs. However, she emphasized the need for flexibility: "There may be a decision though that the cash flow into the bank selling to outside entities to bring money into the city may be a higher priority than a city project." The city has already made substantial investments in preparation. Burns revealed that they've not only purchased the primary bank site but have also acquired a second site that was at risk of being sold to private developers. "The second site was at risk of being sold and the city was concerned about that. We actually have already purchased the second site," she explained. Council Member Cotton raised important questions about the appeals process and whether projects could challenge denials. City Attorney Matt Stamps clarified that the ordinance positions the city in a proprietary rather than regulatory capacity. "The way that this ordinance is set up, if you notice at the front end under the purpose section, it specifies that the city here is acting in its proprietary capacity rather than a regulatory one," Stamps explained. The service area for the bank extends beyond Bellingham's city limits to include much of the urban growth area and portions of Whatcom County, reflecting the ecological reality that environmental impacts don't respect municipal boundaries. However, the ordinance allows for exceptional situations where credits could be sold outside the service area, though this requires additional regulatory approval. One particularly forward-thinking aspect of the ordinance is the establishment of the Bellingham Mitigation Bank Fund, a special revenue fund that can only be used for acquiring, establishing, constructing, operating, monitoring, maintaining, and managing the mitigation bank. This protected funding structure was required by federal and state agencies to ensure long-term viability. The timeline ahead remains ambitious. Burns anticipates bringing the actual mitigation banking instrument — the formal interagency agreement — to Council by late 2026 or early 2027, with bank operations beginning sometime in 2027. The timeline depends on federal and state agency review processes that are largely outside the city's control. ## Lake Whatcom's Defense Against Invasive Mussels The second major agenda item, Bill 24696, addressed a more immediate environmental threat: the potential invasion of Lake Whatcom by quagga, zebra, or golden mussels. Mike Olinger, Deputy Public Works Director, and Mike Parelskin, Superintendent of Natural Resources Field Operations, presented the comprehensive rapid response plan alongside consultant Mark Cecchini Beaver from Four Peaks Environmental. The threat is both real and urgent. Beaver described how "we can see it on the horizon" as invasive mussels have been detected in nearby states, with quagga mussels recently found in the Snake River in Idaho. The plan stands out as "the first of its kind in Washington state and one of only a handful nationwide" for locally-led, site-specific freshwater mussel response planning. The potential impacts are severe. These mussels can "contaminate drinking water supplies, out-compete native species, alter habitats, change food web dynamics, clog water intakes — very significant issue for Lake Whatcom — as well as fish screens," Beaver explained. They can also overtake docks, buoys, boat anchors, and affect recreation and public access. What makes Lake Whatcom's situation particularly complex is the varying risk levels for different mussel species. The lake's low calcium levels (averaging less than 6 mg/L) make it less suitable for quagga and zebra mussels, which require higher calcium concentrations for shell development. However, golden mussels — recently detected for the first time in North America in California's Sacramento-San Joaquin Delta — tolerate much lower calcium levels and pose a higher establishment risk. Council Member Anderson picked up on this distinction, noting her surprise "about reading a little more about the calcium and how the impact on the zebra and I think it's quagga mussel because we hear a lot about those two and the low calcium in the lake and how that doesn't give the right chemical makeup for them to develop their shell." However, the plan treats all three species seriously. As Beaver explained from their June workshop: "Perhaps the biggest takeaway from June is that there is a bias towards taking action regardless of the mussel species detected. The consensus was that all invasive freshwater mussels should be treated the same despite there being a lower risk of establishment for quagga and zebra mussels compared to golden mussels." The response plan operates in two phases: rapid response (within the first week) and extended response (within six weeks). The rapid response focuses on establishing incident command, range delimitation through extensive sampling, and minimizing additional spread. The plan includes detailed sampling protocols, communication strategies, and containment measures including potential deployment of containment curtains to quarantine affected areas. The extended response phase involves a structured decision-making workshop where all stakeholders evaluate treatment options. Current options include bacterial treatments like Zequinox, chemical treatments such as potassium chloride or copper-based products, manual removal by divers, or benthic mats that block sunlight and oxygen. The workshop participants strongly favored the bacterial treatment within contained areas, viewing it as having fewer impacts on non-target species and water quality compared to chemical options. One particularly impressive aspect of the planning process was the collaborative approach. The plan was developed with input from the Washington Department of Fish and Wildlife, Whatcom County, Lake Whatcom Water and Sewer District, and Western Washington University's Institute for Watershed Studies. Multiple rounds of workshops and reviews ensured comprehensive stakeholder input. The plan also addresses practical concerns about material availability and funding. Parelskin explained that "Washington Department of Fish and Wildlife since they're the lead agency for response, they actually practice all of their response efforts. Like the containment curtains are extremely expensive, but they already own them and they practice deploying them." Current monitoring efforts are already robust. The city and WDFW conduct monthly sampling from April through October at three public boat launches that allow motorized boats: Bloedel Donovan Park, Sudden Valley Marina, and the WDFW launch. Staff have been trained in environmental DNA sampling, plankton tows, and shoreline surveys. The plan recognizes that early detection followed by rapid response offers the best chance of successful eradication. As Beaver noted, "The goal is to minimize the probability of muscle establishment by acting quickly and decisively to eradicate the population that arrives in the lake while it's still at a manageable size." The joint resolution will also be adopted by Whatcom County Council in early November and the Lake Whatcom Water and Sewer District Board of Commissioners on October 28th or 29th, demonstrating the regional coordination essential for protecting this critical water supply. ## Regional Coordination and Future Implications Both items approved today demonstrate Bellingham's commitment to proactive environmental management that extends far beyond municipal boundaries. The mitigation bank will serve projects throughout the region, potentially improving ecological outcomes across multiple watersheds. The invasive mussel response plan protects a water supply serving over 120,000 people and coordinates with multiple jurisdictions and agencies. Chair Stone, who also serves on the Lake Whatcom Policy Group, expressed appreciation for "the preventative work" and noted that while "it's a contingency plan that we're putting in place hoping that we won't need, it's good to have that there." The unanimous support for both measures reflects the committee's recognition that environmental challenges require long-term planning, regional cooperation, and innovative approaches. The mitigation bank represents a fundamental shift toward more effective ecological restoration, while the invasive mussel response plan demonstrates the necessity of preparing for emerging threats. As Council Member Anderson noted about the mitigation bank, "I'm really excited to see where we are with this. It started a little bit before me, but I've been here for quite a few of the steps, and it's been great work seeing this come almost full circle." Both recommendations will proceed to the full City Council for final approval, with implementation timelines stretching into 2027 for the mitigation bank and immediate readiness for the invasive mussel response plan. These decisions position Bellingham as a leader in environmental stewardship, balancing development needs with ecological protection through innovative policy tools and comprehensive emergency planning. The meeting adjourned with both items approved unanimously, setting the stage for a new era of environmental management that prioritizes ecological success, regional coordination, and proactive threat response. For a city that draws its identity partly from its natural setting, these decisions represent a significant investment in protecting and enhancing the environmental assets that define Bellingham's character and support its residents' quality of life.