Friday, October 5, 2012

GPT: EIS Scoping Comment No. 12

Purpose = Need?

Chapter 3 of the GPT Application document describes 'Purpose & Need', citing several national, state and local policies, plus international commerce, as the justification. 
It further asserts that GPT would purposely advance the economic development and environmental protection goals of Whatcom County, which stretches credulity and needs to be demonstrated to the public by a comprehensive cost versus benefit analysis, a cumulative & programmatic environmental impact analysis, a thorough health impacts analysis and completed studies on vessel & rail congestion and hazard safety.
Only when these studies are done and evaluated, can we know whether GPT actually will benefit anyone other than the Applicant and its associates.
Section 3.2.1 claims GPT would meet three principal needs;
1. The need to ship bulk cargo to and from Asia and other markets to meet current and future market demand;
2. The need for deep water, bulk marine terminals in the Puget Sound region; and
3. The need for community and economic development in Whatcom County consistent with the Whatcom County Comprehensive Plan for the Cherry Point Industrial UGA.

It seems curious that each of these three 'needs' also extend into national and world affairs, yet the Applicant insists that for EIS purposes, their 'site' should limited to only a 350 acres footprint, despite clear reliance upon greatly increased levels train and vessel to and from GPT to achieve its goals. 
It would be inconceivable to ignore these certain, extremely widespread and admitted impacts in any honest EIS evaluation or determination!

Pacific Rim markets are intended benefit from GPT by receiving bulk commodities from the US, with coal exports accounting for by far the greatest volume.
It seems strange that GPT cites economic growth and improvement in the quality of life and life expectancy in Asia has created large demands for these commodities, with demand predicted to remain high for the long term. 
This appears to say that Asia benefits more than we do from GPT operations, a conclusion that may well be true.

Section 3.2.2 states we need for another Multi-Modal Deep-Water Bulk Marine Terminal in the Puget Sound Region, because the others are in urban areas, crowded and oriented to containers, not  bulk. 
Of course this need serves mainly GPT's purpose of creating a large Asian market for US coal.

The clearest statement about this need is the following:
The proposed Gateway Pacific Terminal would help meet the need for deep-water bulk marine terminals that have the ability to effectively and efficiently transfer cargo between overland and waterborne modes of transport in the Puget Sound region.
Section 3.2.3 further describes the Need for Community and Economic Development by citing US Government and Washington State adopted policies and initiatives to expand interstate commerce and export trade. 
It also claims consistency with various other plans and goals, which may or may not be exactly true.

Section 3.2.4 talks more about the need for an appropriate site to achieve GPT's goals, that is very large and able to efficiently accommodate large numbers of unit trains and large marine vessels almost without restrictions.
Does this really describe something that is likely to be compatible with the kind of community we are now and want to be in the future?

Let's complete the required studies as thoroughly as possible, then we'll see our options more clearly.
The needs stated merely serve to support the Applicant's purpose, not necessarily ours.
What is the rush when something with so many potentially harmful impacts is seeking approval?