Wednesday, September 26, 2012

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