Monday, September 24, 2012

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

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:  

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: - Local blog report - Floyd McKay's report on Lummi gathering at Cherry Point - a valuable, one-stop resource

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