Friday, September 28, 2012

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.
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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.
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