GPT: Scoping Comment No. 7

Safety & Levels of Service at Rail Crossings 

I am concerned that the many unspoken potential off-site impacts appear to grossly out-weigh those strictly on-site impacts identified in GPT's Application.For example, the 48 railway crossings in or near Whatcom County listed below and on the Communitywise website: http://www.communitywisebellingham.org.

While some of these crossings are tunnels and over-passes that do limit at-grade interferences, most are at-grade and seem to entail significant and expensive mitigation that GPT apparently intends to externalize onto citizens, businesses and other jurisdictions. 

• The tunnels listed do represent choke points at which blockages could disrupt all train service.

• The over-passes listed have a similar potential as choke points should a derailment or structural damage be encountered for any reason, including natural causes.

• The at-grade crossings present the clear potential for vehicle & pedestrian accidents, as well as Level of Service degradation at varying degrees of impact to other vehicular traffic as well as to people, businesses and public marinas and ferry services that provide essential water transportation to remote locations where people live, work and recreate. Many municipalities, including Bellingham, have long since  adopted Level of Service 'E' for major streets, leaving little room for additional traffic delays, which could degrade the LOS to "F", a failing grade.   

A comprehensive study is required to clearly define likely problems caused by the anticipated greatly increased unit coal train rail traffic at each of these 48 railway crossings, as well as the much greater number outside of Whatcom County, as well as to assess reasonable mitigation and all its associated costs and potential funding.

The Applicant would appear to need the expectation of bearing very substantial costs in this regard, with the necessary amounts to be determined in consultation with the applicable jurisdictions.

1. Bow Siding North  [Skagit County]

2. Bow Siding South  [Skagit County]

3. At Grade

Colony Road - MilePost 80.94  [Skagit County]

4. At Grade

S. Blanchard - MP 81.21  [Skagit County]

5. At Grade

S Legg Road - MP 81.41  [Skagit County]

6. At Grade

N Legg Road - 81.81  [Skagit County]

7. Under-crossing

Chuckanut Drive - MP 82.4  [Skagit County]

8. Tunnel

Chuckanut Point Road

9. Tunnel

Chuckanut Shore Road

10. At Grade

Yacht Club Road - MP 89.37 [Main access to Larrabee State Park Boat Launch Area & expensive homes]

11. Tunnel

Clark's Point

12. South Bellingham Siding

South end

13. South Bellingham Siding

North End

14. At Grade

Harris Avenue - MP 93.34 [Major conflict with Alaska State Ferry Terminal, AMTRAK, Businesses near water, City of Bellingham Wastewater Treatment Plant, Port of Bellingham's Marine Park/water access] 

15. At Grade

6th Street Ferry Access - MP 93.46 [Popular Public Boat Launch site]

16. At Grade

Bayview Drive Boulevard Park - MP 94.24 [Only vehicular access to very popular City of Bellingham Park on waterfront, Woods Coffee, Taylor Street Dock Overwater Walkway]

17. At Grade

Bay Trail Boulevard Park - MP ?? [Very popular pedestrian/cycling trail]

18. Siding

Cornwall Landfill - South

19. Siding

Cornwall Landfill - North

20. At Grade

Wharf Street - MP ?? [Access to Port of Bellingham Waterfront Area, Cornwall Avenue entrances to former G-P property Redevelopment Site]

21. At Grade

Cornwall Avenue - MP 96.33

22. At Grade

Beal Memorial - MP 96.33

23. At Grade

Laurel Street - MP 96.65

24. Over-crossing

Chestnut & Bay Streets - MP 96.81

25. At Grade

Central Avenue - MP 97.02 [Major access point to former G-P property to be redeveloped, Whatcom Waterway]

26. Siding

Roeder South - MP 97.13 [Access to Waterfront]

27. At Grade

C Street - MP 97.16 [Access to Waterfront]

28. At Grade

F Street - MP ?? [Major Access to Waterfront, Commercial business complex, Hotels, Restaurants, POB Marina], USCG hdqtrs]

29. Siding

Roeder N - MP ??

30. Over-crossing

Squalicum Parkway - MP 96.3 [Major Truck Access to Waterfront Businesses, Marina, Port of Bellingham, and Redevelopment Site]

31. Over-crossing

Seaview - MP 98.43

32. Under-crossing

Locust Avenue - MP 99.66

33. At Grade

Cliffside Drive - MP 100.3 [Access to Waterfront]

34. Over-crossing

Marine Drive - P 100.9

35. At Grade

Wynn Road - MP 101.1

36. At Grade

Country Lane - MP 101.62

37. At Grade

Rural Avenue - MP 103.12

38. At Grade

Slater Road - MP 103.6

39. At Grade

Hovander Road - MP 105.06

40. Under-crossing @ Ferndale Main Street - MP 105

41. At Grade @ Ferndale 2nd Avenue - MP ?? 

42. Siding @ Ferndale - South

43. At Grade @ Ferndale Washington Street - MP 106.2

44. At Grade @ Ferndale Thornton Street - MP ??

45. At Grade Ferndale Brown Road - MP 108.6

46. At Grade @ Ferndale Grandview Road - MP 109.4

47. Siding  @ Ferndale N - MP ??

48. At Grade @ Cove Road - MP ?? 

--------------------------------------- 

GPT: EIS Comment No. 6

Lake Terrell Wildlife Preserve

The EIS website is functioning so now submitted comments can be read online at this URL:
-----------------------------
September 29, 2012

Mr Tyler Schroeder, Whatcom County

Mr Randel Perry, U.S. Corps of Engineers

Ms Jeannie Summerhays,  Washington State Department of Ecology

Subject: Scoping for Draft EIS for Proposed Gateway Pacific Terminal, Cherry Point, Whatcom County

As a Whatcom County resident and former elected official, I am submitting this comment for the careful consideration of the MAP Team:

I have a concern about the 1500 acre Lake Terrell Wildlife Preserve that lies to the east, adjacent to the GPT site.
Coal dust, noise and continuous vehicular traffic will not help keep Lake Terrell a place for people and wildlife to enjoy. 

Recently, WDFW announced the latest is a series of steps to reintroduce salmonids to this preserve by reopening the creek which drains to the north. This Bellingham Herald article describes this action: http://www.bellinghamherald.com/2012/08/26/2662441/lake-terrell-will-see-salmon-soon.html 

Through many years, the ARCO refinery -now BP- has provided good stewardship of the area surrounding the refinery complex, including nesting areas for birds. 
It would be a shame to see all of this careful stewardship wasted by shortsightedly approving a proposal with so many potentially harmful impacts as to threaten the Lake Terrell Wildlife Preserve.
-----------------------------

GPT: EIS Scoping Comment No. 5

Is GPT Appropriate For Cherry Point?

Two articles appeared today, one concerning northwest tribes insistence on no shortcuts for coal projects, the other reporting on the collapse of the coal market.

-----------------------------------

Here is another submission to the MAP Team:

September 28, 2012

Mr Tyler Schroeder, Whatcom County

Mr Randel Perry, U.S. Corps of Engineers

Ms Jeannie Summerhays,  Washington State Department of Ecology

Subject: Scoping for Draft EIS for Proposed Gateway Pacific Terminal, Cherry Point, Whatcom County

As a concerned Bellingham resident and former elected official, I am submitting this comment for the careful consideration of the MAP Team:

Please explain how the proposed GPT project described in the Application differs from the former CBI terminal proposal that was eventually vetoed by former WA Governor Spellman in 1982.

Also, please explain why the Applicant believes this latest proposal is NOT significantly different from its earlier proposal submitted in 1992, which was later represented as 'vested' in 1997, and then became the subject of a negotiated Settlement [JARPA] in 1999? 

The Cherry Point Industrial Area has been designated for heavy industrial water-dependent use by Whatcom County for some time, although several schemes proposed earlier have never come to fruition. 

The question is, is this current GPT proposal idea the best and highest use of this sensitive site?

Moving huge volumes of relatively low value commodities, like coal, does not create nearly as many sustainable US jobs as a value-added manufacturing facility would. 

Additionally, bulk commodities are quite sensitive to world supply/demand pressures and may not prove profitable as a sustainable business model for very long.

A Port of Bellingham study, performed by the credible professional firm Deloitte & Touche several years ago, concluded that the County would likely be better served by a strategy of simply leaving the area around Cherry Point open to naturally attract gradual industrial infill and growth from the I-5 Corridor, from either Seattle or Vancouver, BC.

Why is this not a viable alternative to a plan like GPT's that potentially causes so much harm as to create such serious concerns as been expressed by so many citizens?

I am especially concerned about the unintended [and unfunded] financial impacts on cities, communities and citizens that may easily outweigh the estimated benefits from the new jobs claimed, additional tax revenues and business activity claimed by this proposal. 
I am also concerned about the certain environmental impacts of GPT, many of which simply cannot be mitigated.

Just looking one side of an equation -the benefits- doesn't usually give one the information needed to make a reasonably good judgement on any proposal.
The concept of Triple Bottom Line [TBL] or so-called Full Cost Accounting works best to insure the true sustainability of any project, since it seeks a reasonable balance between economic, ecological and social values.

If the Applicant subscribes to this TBL concept, how might this be demonstrated, aside from a thorough EIS scoping and evaluation that includes all cumulative impacts?

Such an approach may work to help GPT achieve more balance in its goals, which would also serve to address many of the public concerns about unwanted and undesirable impacts more readily.

That would also allow a much more interactive approach to the proposal, instead of the 'take it or leave it' approach currently being pursued.
---------------------------

GPT: EIS Comment No. 4

Vessels, Jobs & Cold-Ironing

Today's Crosscut carried another excellent article by Floyd Mckay that addresses the coal issue facing the Northwest. 
--------------------
Here is today's submission to the MAP Team:

September 27, 2012

Mr Tyler Schroeder, Whatcom County

Mr Randel Perry, U.S. Corps of Engineers

Ms Jeannie Summerhays,  Washington State Department of Ecology

Subject: Scoping for Draft EIS for Proposed Gateway Pacific Terminal, Cherry Point, Whatcom County

As a long time Bellingham resident and former elected official, I am submitting this comment and recommendation for the careful consideration of the MAP Team:

Much is being touted about the proposed Gateway Pacific Coal Terminal bringing a few hundred well-paying jobs to our area. 
Are these jobs limited to the relatively few on-site and associated operations described only, or do they include significant US off-site jobs included in the multiplier effect, as well?

For one example, will only US-built, US registry and US-manned ships be specified as the exclusive bulk carriers to call at GPT? Such a commitment would help generate many more US jobs for steel-making, shipbuilding, marine equipment manufacturing, US merchant marine crews, and the like, which are exactly the kind of value-added jobs the US needs most.

Should GPT consider committing to a goal like this, it could more tangibly help sustain existing American industry and essential jobs, and also promote confidence in a likely much cleaner and safer vessel operation in US waters because national pride would at stake as well as the standard profit motive. 

I am concerned that the many behemoth ships -of whatever registry- anticipated to haul coal and other bulk cargoes will continue to burn heavy petroleum residual 'Bunker Fuel' and their own diesel fuel while moored, anchored and at the loading wharf. 
This would constitute a major new source of air pollution to our area, which is widely noted for its relatively clean air.

Since the GPT Application mentions that electrical utility junctions are to be included in the wharf and terminal design, does that mean that the use of shore power -commonly termed Cold-Ironing- will be mandatory for all vessels that load or unload at GPT? If not, why not?

From  a recent article on Port of Tacoma: 
"CLEANER POWER WHILE PARKED
The port is equipping all of its new facilities with conduit and electric substations capable of providing ships operating at its docks with power generated by shore-base power plants.

Under the shore power plan, ships would operate their internal lighting, heating, cooling and mechanical systems with shore power when they’re tied up at the pier. Now, most ships continue operating their internal combustion engines while at the pier to power those systems. The shore power switch could cut pollution from those engines because the generators that create that power are likely far cleaner than the ship’s engines, particularly if that power is generated from water flowing through dams, from windmills or other green sources.

TOTE pioneered shore power in 2010. The $2.7-million project is expected to reduce carbon emissions by 2,600 tons a year. TOTE’s shore power facility is the first cargo shore power operation on the Sound. No other shipping lines have followed suit, but Jordan expects more will in time as newer ships are equipped with shore power receptacles."
------------------------------

GPT: EIS Scoping Comment No. 3

Corporate Structure & Responsibilty

September 26, 2012

Mr Tyler Schroeder, Whatcom County

Mr Randel Perry, U.S. Corps of Engineers

Ms Jeannie Summerhays,  Washington State Department of Ecology

Subject: Scoping for Draft EIS for Proposed Gateway Pacific Terminal, Cherry Point, Whatcom County

As a concerned Bellingham resident and former elected official, I am submitting these connected comments and questions for the careful consideration of the MAP Team:

The GPT ownership and operations responsibility hierarchy needs additional explanation, specifically to provide specific accountability for potential harmful accidents and cumulative degradation to the impacted environs in the broader zone of influence attributable to this Applicant's proposal, in two parts;

A. As described in the Application, the ownership of the terminal seems largely dis-associated from 'ownership' of any problems that may occur that damage either public resources, the existing built community or the health of human and fauna. 

Specifically, which entity or combination of entities will be responsible for either, human or environmental damages?

The applicant's proposal appears to limit its liability to successive, shelled layers of corporate structure, with no ultimate responsibility identified or committed to. 

Is this the Applicant's accurate intent ?   

If so, what guarantee(s) of responsibility is the Applicant willing to provide? 

If outside insurance is to be used for this purpose, to what limits? 

Will a public entity be able to control these funds and timely determine when and where they will be used?

B. As described in the Application, the Applicant appears to assume no responsibility for the actions of its supply chain partners, either Peabody Coal, BNSF Railway Co. or any of the various owners or operators of the Marine Vessels expected to transport bulk coal and other cargoes to foreign clients. 

Please explain exactly where does each supply chain party's responsibility begin and end? 

The Applicant asserts it will never 'own' any of the bulk commodities it will handle, but merely charge what amounts to a toll only for the unloading, materials handling and loading operations. 

Since some parts of these bulk commodities -primarily coal- will find their ways into the soils, waters, and air in -and outside- the vicinity of the proposed terminal, who will 'own' these fugitive particulates, liquids and gases? 

By means of example, please explain the following using and/or citing a recognized scientific basis:

• What will happen to coal and other 'dust' collected by various means, including bag-houses, onsite? 

Will it be considered a hazardous waste?

How will this be disposed? 

• What will happen to fine coal particles and other sediments collected by the various storm water and/or water treatment systems proposed? 

Which, if any, will be considered as hazardous waste?

How will these be disposed?

How will the stormwater and process water spray effluent be disposed, and to what standards?

• What methods are proposed to measure, monitor and control coal dust particles - especially PM 2.5 and PM 10 - generated from railcar unloading, materials handling conveyor system, and ship loading at the terminal from being carried offsite? 

At the coal railcar unloading facility, a pole building with roof and open sides, what does a vent stack 'opacity of 10%', equate to in terms of lbs per day of particulates?

How much is likely to be lost by wind blowing through this open shed?

What air pollution liability will be assumed by the applicant? How will this be amount be monitored, determined and paid?

GPT: EIS Scoping Comment No. 2

Scope of Project

This morning, the Cascadia Weekly's Gristle topic - Xwe' chi' eXen -  covered the Lummi Nation's recently stated opposition to the proposed Gateway Pacific Terminal, which together with growing linkage between Northwest communities demonstrates expanding concerns about GPT and its obvious, wide-spread potential adverse impacts.

Readers should take encouragement from this article and understand their concerns need to be expressed -during the next 3 months- directly to the MAP Team responsible for scoping the GPT EIS. 

Monday's blog gives essential details of how this can be done, plus an example comment I have submitted.

Remember, the more of us who speak up, the better chance we have to mitigate harmful impacts that may cost us far more than any benefits we derive from GPT being built and operated!

------------------------

Here is a second comment I submitted yesterday:

September 25, 2012

Mr Tyler Schroeder, Whatcom County

Mr Randel Perry, U.S. Corps of Engineers

Ms Jeannie Summerhays, Washington State Department of Ecology

Subject: Scoping for Draft EIS for Proposed Gateway Pacific Terminal, Cherry Point, Whatcom County

As a Bellingham resident and former elected official, I am submitting these concerns for careful consideration by the MAP Team:

The geographical 'scope' described in the GPT Application Document seems unusually -even grotesquely- small since the Applicant wishes to limit it to the immediate site's footprint, a total of only 350 acres. 

That claimed limitation grossly understates the actual zone of influence of the proposed GPT facility and needs to be greatly expanded to include not only much more of the immediate surrounding area, but also all the dozens of communities and hundreds of crossings through which the railroad rights of way pass in the supply chain to transport PRB coal to the proposed facility.

I am encouraged by the MAP Team's decision to hold seven public hearings at various locations along the railroad route through the State of Washington, and hope that signifies an intent to appropriately evaluate potential impacts in a wider area.

However, the estimated annual shipping traffic of four hundred and eighty seven [487] very large Panamax and Capesize Bulk Carriers will create unprecedented vessel traffic, not only in the scenic, narrow and sensitive Salish Sea, but in the Straits of San Juan de Fuca and major great circle shipping lanes through the Aleutians and on to Asia. 

That volume of vessel traffic brings with it all the risks of concentrated congestion, collisions, spills, interference with fishing and pleasure craft, and general degradation of the uniquely beautiful and highly valued San Juan Islands, a leading attraction to our area.

The proposed GPT facility is nothing more than a nexus, planned specifically to attract very heavy coal-carrying traffic, both incoming and out-going, thus spreading its zone of directly related impacts quite broadly.

For that reason, the EIS Scope needs to recognize this reality and evaluate these broader impacts commensurately.

At a minimum, a detailed evaluation needs to be performed which identifies all safety and Level Of Service impacts at each railroad track crossing, and suggests suitable mitigation and their associated costs. 

The communities affected can ill afford enduring either the impacts imposed or the costs of their mitigation - if indeed any mitigation is possible.

Evaluating potential marine vessel impacts is more problematic and will necessarily involve multiple stakeholders, including federal and state agencies among others. 

This effort will need to focus on problem avoidance, including emergency planning with emphasis on proven preventative measures to preclude accidents, plus requiring publicly accessible and adequate contingency funding -including mandatory insurance- to timely pay for any mishap that may occur.

Very truly yours,
John B Watts

Coal: GPT EIS Scoping Comment No. 1 - Adding Insult to Injury

Incomplete Application

Today begins the official public comment period for the proposed Gateway Pacific Terminal's Environmental Impact Statement [EIS].
These may be sent by mail to:

Mr. Randel Perry, U.S. Army Corps of Engineers, Seattle District, Care of: GPT/BNSF Custer Spur EIS Co-Lead Agencies, 1100 112th Avenue Northeast, Suite 400, Bellevue, Washington 98004 

or via e-mail to comments@eisgatewaypacificwa.gov.

I certainly hope every concerned citizen will take advantage of this one opportunity to be heard!
Personally, I plan to submit my first comment later today. 
[see below]

Copies of all documents will be available at this website: www.eisgatewaypacificwa.gov  

The time for commenting will end on January 21, 2013, 120 days hence.
In between will come seven public hearings, with only two in Whatcom County:

• on Oct 27 at Bellingham's Squalicum High School from 11 AM until 3 PM, and

• on Nov 29 at the the Ferndale Events Center from 3 PM until 7 PM.

I take some encouragement from the fact that 5 public hearings are scheduled for other WA communities, including Mt Vernon, Friday Harbor, Seattle, Vancouver and Spokane.
This seems to acknowledge that impacts from heavy rail and ship traffic to and from GPT would be felt much more widely than just within the proposed terminal's footprint, as the proponents wish.
----------------------------

Last Friday marked another annual season change, the Autumnal Equinox.
That marks the time when cooler weather and shorter days means harvest time is approaching, a necessary prelude to enduring winter challenges.

The early harvest SSA-Marine reaped Friday at the Cherry Point beach seemed to exactly fit what they have sown, toxic weed seeds that threaten the very way of life [Sche Lang en] for the Lummi Nation.
The Lummi name for their former Cherry Point area village is Xwe'chi'eXen, which is considered a sacred ancestral site, located near traditional fishing waters.

Resolution #2012-060 of the Lummi Indian Business Council, certified on June 19, 2012, registered their opposition to the GPT project proposed by SSA-Marine.
That sentiment was strongly conveyed at the Lummi gathering, attended by about 200 people that I witnessed last Friday.

If the GPT project itself is considered an injury, then attempts to buy Lummi support for it adds insult.
That was the clear message conveyed by ceremonially burning a replica of a very large check marked NON-NEGOTIABLE in red paint, with SSA officials looking on.

After wondering what the Lummi position would be, I was encouraged by this gathering and the unmistakeable public message that was sent to SSA-Marine.
------------------------------
A few published articles describe these recent events:

http://www.nwcitizen.com/entry/lummi-nation-opposes-coal-terminal - Local blog report

http://crosscut.com/2012/09/21/coal-ports/110640/lummi/ - Floyd McKay's report on Lummi gathering at Cherry Point

http://www.bellinghamherald.com/2012/09/21/2700524/lummi-nation-leaders-come-out.html - Report on Lummi gathering at Cherry Point

http://earthfix.opb.org/energy/article/wash-tribe-comes-out-against-coal-export-terminal/ - Lummi statement

http://daily.sightline.org/2012/09/19/fish-vs-coal/?utm_source=Sightline+Newsletters&utm_campaign=af6bfc296a-SightlineWeekly&utm_medium=email - 

http://www.coaltrainfacts.org - a valuable, one-stop resource

http://www.coaltrainfacts.org/scoping

http://www.nws.usace.army.mil/Missions/CivilWorks/Regulatory/PublicNotices.aspx - contains  Special Public Notice
and Notice of Intent to Prepare a Draft EIS

-------------------------------
Here is the comment I submitted today:

September 24, 2012

Mr Tyler Schroeder, Whatcom County

Mr Randel Perry, U.S. Corps of Engineers

Ms Jeannie Summerhays,  Washington State Department of Ecology

Subject: Scoping for Draft EIS for Proposed Gateway Pacific Terminal, Cherry Point, Whatcom County

As a long time Bellingham resident and former elected official, I am submitting these comments for the careful consideration of the MAP Team:

From reading the GPT Application Document submitted to Whatcom County Planning & Development Services on Feb 28, 2011, it is apparent that much thought has gone into its preparation. 

However, it is also apparent that much more additional, important information is required before this Document can be reasonably considered complete and is therefore ready for any sort of final evaluation or approval. 

This EIS Scoping Process will undoubtedly provide a number of questions that thoughtful decision makers will need to have answered to their -and the public's - satisfaction.

For example, to be fair, impartial and complete, I wonder why several studies that are referenced in the Application have not already been completed? 

Some of these studies are quite important, such as the Vessel Traffic Analysis, the Aquatic Species Study for the local herring stock at Cherry Point, a detailed Storm Water Collection & Treatment Plan for the entire terminal, an Analysis of Meteorological Data as it applies to surrounding population centers, Noise Studies, Vehicular Traffic Impacts outside the immediate site footprint, and the like.

Without being able to actually examine these studies, there is no way for the public to know what they contain or whether the data and conclusions are accurately derived and used or not! Is the public to accept verbal promises on faith in lieu of reviewing the actual studies?

As an unpaid citizen with no professional staff, I expect to have this potentially critical information available to me in a timely fashion so that I can review it and develop any important questions I might have, without risking that the time for commenting will run out before I finish. 

I certainly hope the Applicant -and the MAP Team- values the type of stakeholder that I represent, especially when a project like this one has the clear potential for unduly weighing against a fair cost -versus- benefit analysis.

I can think of no way this particular situation can be remedied, short of making the substantial relevant information timely available before any Final EIS is attempted. 

Please commit to seeing this course of action is followed before allowing the Public Scoping period to become a pre-ordained charade.

Very truly yours,

John Watts

--------------------------