Comments Submitted to the KPB Lands Committee for their meeting on June 3 at 4:30. Send comments to the clerk at micheleturner@kpb.us

Here is a link to the ordinance, with images of which parcels we are talking about.

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Dear Members of KPB Lands Committee:

We urge you to remove Parcels 179-080-10 and 179-080-11 from Ordinance 2025-10 for the following reasons: (1) The services provided by these high-value wetlands to the public are extremely valuable and should be preserved; (2) the monetary gain to the borough associated with the sale of the lands will almost certainly be offset by the cost to the public of developing them, including costs associated with flood mitigation, road repair, culvert maintenance, the serious health and safety hazards associated with ice on the road, increased risk of septic system failure—the range of issues you are likely familiar with along K-Beach are a good point of comparison; (3) The Kenai Peninsula Borough had an agreement with the City of Homer that the City would purchase these lands from the Borough, but negotiations recently broke down: we urge both the City and Borough to come back to the table and try again—don’t throw the baby out with the bathwater: there is too much at stake for the public to let this vital green infrastructure project fall apart. 

1)) The City and community of Homer has a vested interest in keeping these high-value wetlands undeveloped, which is why we have secured grant funding for to the purchase of these lands for conservation. And as our current City of Homer Draft Comprehensive Plan points out:

“77 percent of the 551 community survey respondents said that preserving open public spaces within the city from development was important and 34 percent of residents listed sustainable and resilient development as the single most important priority during the Growth Scenarios event…Solutions called out by residents in surveys and meetings include green infrastructure incorporation, open space preservation, and greater attention to development standards for both private development and public infrastructure.”  

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The wetlands that the borough is proposing to sell, likely for development and commercial activity provide many important and unique functions that are of great value to the people of Homer, it’s visitors, and it’s businesses, including: Flood Mitigation, Erosion mitigationStormwater treatment, and thereby protection of essential fish habitat in Kachemak Bay, Migratory Bird Habitat and Moose Habitat.

We’d like to talk a bit about the value of these services, and what Homer stands to loose with the sale and development of these high-value wetlands in the heart of town.

Flood Mitigation

KPB Parcels 179-080-10 and 179-080-11 are part of the Beluga Wetland Complex, a basin of wetlands at the base of the Homer bluff, right above Kachemak Drive. These parcels are a kind of wetland known as peatlands. Peatlands’ capacity to absorb large volumes of water is very useful for people who live around them. They are typically 95% water and 5% organic matter by weight and a one-acre peatland can typically store about one million gallons of water. The stream map below gives a good sense of the huge volume of water that flows into the Beluga  Wetlands Complex. Acting as a catchment basin, peatlands in this complex absorb large volumes of water and mitigate the harmful effects of storm surges and thaw events of the drainages that feed into it, protecting Kachemak Drive, as well as the homes and businesses on both sides of the road from large-scale flooding. Think of the peatlands like a reservoir and gravel fill like like a roof and ditches like gutters. Filling and developing peatlands of this size is going to increase  peak flow rates —and all associated problems—significantly.This area is already at-capacity or just over in terms of fill. We say that because it already has a lot of flooding issues, see eg. The images below. We have also attached additional photos and video related  to flooding. 

Kachemak Drive is already flooded many times a year, and when the flood turns to ice on the road, as it often does, it creates a really dangerous situation for drivers. These floods and freeze-thaw conditions also create havoc on the road itself, the culverts and ditches along it, causing expensive and frequent maintenance. The increased risk of septic system failures in the area is an important consideration. You all are likely familiar with the challenge and expense of managing water issues on K-Beach. This is the same kind of thing. Selling these lands for development is going to hurt not help Homer. For example, the City of Homer has analyzed the costs of upsizing culverts to manage increased stormwater runoff associated with increased development and the costs are significant.  

As can be seen in the  map generated by Homer Drawdown Peatland Project, while the specific parcels in question were not measured, peat depths in this area range from 7 to 24 ft. This means water depths are 7 to 24 ft. Filling peatlands like this increases the volume of water. The Beluga Wetlands Complex is mitigating this stormwater, and they should be left in place to do their work. Known variously as Green Infrastructure, Nature-Based Engineering, Nature-Based Flood Solutions, the utilization of nature to help manage stormwater is endorsed by FEMA, the US Army Corps of Engineers, and the EPA as the preferred path to effective stormwater management.

Erosion Mitigation

Homer has a long-term trend of significant coastal erosion. Coastal erosion in the Homer area is largely driven by a high incidence of unstable clay soils and flood conditions: high volumes of groundwater and surface water are steadily eroding the coastal the bluff. The image illustrates that peatlands play an important role in mitigating erosion, with erosion rates much reduced around the Beluga Wetlands area in comparison to the Baycrest area. The catchment based holds water during peak flows and significantly reduces the rate of erosion. Filling these wetlands will speed it up.

In recent years, the natural buffer provided by the peatlands has been increasingly compromised through property fill and drainage works on the north side of Kachemak Drive. These developments increase the speed and volume of water flowing through the system during storm surges, driving increased bluff and littoral erosion. As we chip away at the peatlands above Kachemak Drive, hardening surfaces and ditching, we jeopardize the very existence of the high-value properties and road below them. 

The stakes here are quite high, and we hope the Borough will work with the City of Homer to protect the peatlands above Kachemak Drive and help preserve the coastline below and direct commercial development to areas zoned for it.  

Stormwater Treatment and Essential Fish Habitat  Peatlands are known to remove sediment, fecal coliform, micro-plastics, and hydrocarbons such as engine oil and diesel discharged off of roads, parking lots, boat storage facilities, etc. The water quality of stormwater runoff in this area is of paramount importance to the Homer community, because it goes directly into Kachemak Bay, which is an Alaska Department of Fish and Game Critical Habitat Area, an International Reserve of the Western Hemisphere shorebird reserve Network and the Kachemak Bay National Estuarine Research Reserve. Kachemak Bay is essential habitat for salmon, shellfish, migratory birds and marine mammals. The value of the ecology and biodiversity of Kachemak Bay cannot be overstated, as Homer’s culture is based the health of Kachemak Bay; it is also a significant factor in our property values and propels our tourism industry. 

Development of these large borough-owned parcels in the Beluga Wetlands Complex with contribute to reducing teh water quality of stormwater runoff into the bay, damaging essential habitat for fishes, waterfowl, and marine mammals. The impact of increased turbidity alone is worth special attention. According to USGS: “high concentrations of particulate matter affect light penetration and ecological productivity, recreational values, and habitat quality…Particles also provide attachment places for other pollutants, notably metals and bacteria. For this reason, turbidity readings can be used as an indicator of potential pollution in a  water body.”

Migratory Bird and Moose Habitat

Despite the fact that these peatlands are in the middle of town, they support an amazingly rich ecosystem, valued by residents and visitors alike. Increased industrialization of this area represents a diminishment of a rich and valuable local resource that builds up residents’ quality of life, the values of our properties, is a basis for substance hunting, and drives tourism. According to the Alaska Department of Fish and Game: 

“More than 100 species of birds visit the vicinity [of Beluga Lake] during spring migration or nest in summer, including shorebirds, waterfowl and songbirds such as golden-crowned and ruby-crowned kinglets. Aleutian terns [classified as vulnerable] sometimes raise young in the Beluga wetlands along Kachemak Drive. Owls, northern harriers and bald eagles take wing over the lake. Chickadees, kinglets and sparrows can be seen in the brush and forest.”

These birds are also a major source of revenue for local people. Every year thousands of people come to Homer for the Kachemak Bay Shorebird Festival, staying in hotels, using water taxies, visiting local restaurants, etc. Birding is a big industry that supports many local businesses and good jobs: a recent study found that the Alaska bird tourism sector generated a total of $204 million in wages, salary, and benefit. Its contribution to Alaska's GDP as measured through value added, amounted to $326 million, roughly 1% of Alaska's current-dollar GDP.  

In addition to the high-value bird habitat, this area is also important habitat for our iconic Moose population, especially in the winter months. According to the Alaska Department of Fish and Game: 

“from November through April, up to 100 moose can be observed feeding on dwarf willows and other plants growing in the [Critical Habitat] area, or seeking shelter from winds and cold temperatures in the area's spruce forest.” 

These moose depend on the wetlands at the proposed site. ADF&G has identified the Beluga Wetland Complex as essential for the survival to the local Homer bench moose herd.  It is critical overwintering habitat, valuable in both its food source and its quietude during the stressful late winter months prior to spring “green-up.” If moose habitat is not protected, a “large proportion of the population will die due to malnutrition every winter.” This is especially important because the Homer moose population likely act as a "source" population in providing dispersing individuals to areas of lower moose densities around the lower Kenai Peninsula. Hunters, visitors, and local nature-lovers alike all lose when the moose populations are harmed.

In conclusion, we urge you to remove Parcels 179-080-10 and 179-080-11 from Ordinance 2025-10. We ask that you recommend that the City and Borough to come back to the table and try to find a mutually agreeable point-of-sale for the benefit of the public. There is too much at stake to abandon this vital green infrastructure project now. 

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