Thursday, October 4, 2012

GPT: EIS Scoping Comment No. 11

Bulk Carrier Vessel Concerns

As a former Helmsman and Navigating Quartermaster in the US Navy, aboard the Presidential flagship -the USS Northampton CC-1- I still have hair-raising memories of first-hand experience in the problems routinely encountered by Navy ships, especially in restricted waters around harbor entrances, sinuous passages, and ports. 

Other than the sometimes enormous difficulties wrought by wind, weather, currents and tides, the danger from other vessels - particularly foreign registry merchant vessels or fishing boats- is a constant problem, which the Navy very frequently deals with by taking extraordinary efforts to evade collisions or other in extremis situations. 

Too frequently, having the right-of-way doesn't automatically mean safety, because -like driving a car- the main problem is often the other guy, and what he's doing.
One big difference is that in open water on the high seas, there aren't stop-lights or traffic cops to enforce the law; only prudence and -as the USCG says- eternal vigilance, both of which can easily be missing.

Merchant vessels, particularly those that continuously transit oceans, seas, large gulfs and channels, often set their auto-pilots even before clearing congested or dangerous waters. 
That means no one qualified is always in charge of looking out for potential harmful conditions, especially with other vessels. 

The situation can be further complicated by crews, tired of overwork on relentlessly long and often boring duty, many of which do not speak english or have the skills necessary to read charts, use electronic navigation devices properly, or make simple calculations to determine whether their course and speed through the water might closely intersect with that of other vessels. 
Neither are the crew members on duty always qualified to take or recommend prudent evasive action to remove their vessel from harm's way. 

These combinations of factors too often add up to serious potential danger, even if weather conditions are otherwise ideal. 
When heavy fog, driving rain or sleet, high winds, big waves, tricky currents and abnormal tides enter the picture, the potential for problems is greatly exacerbated, often leading to collisions, spills, fires, near-misses, groundings, sinking, confusion for other vessels, and a major load for the US Coast Guard to oversee and provide assistance.

While very large vessels do usually have highly trained Masters [who can sometimes become incapacitated] and Owners who are adverse to expensive casualties from accidents, these alone do not insure against disasters, as the Exxon Valdez [whose Master was drunk] and other enormous vessels have vividly demonstrated from time to time at unexpected intervals.

The Salish Sea and the San Juan Islands simply cannot bear so many real and predictable threats, and should not be offered as sacrificial lambs on the altar of unrestricted commerce.
The Vessel Traffic Hazard Study is a exceptionally critical document that needs to be timely completed, vetted and opened to full public review before any level of approval is granted to SSA-Marine's GPT Application.

Wednesday, October 3, 2012

GPT: EIS Scoping Comment No. 10

Waterfront Redevelopment

For several years, the City of Bellingham and the Port of Bellingham have been planning a very ambitious -and expensive- Redevelopment of the former G-P industrial property and adjacent areas on the Waterfront which contain various levels of contamination deemed potentially harmful if they are left un-remediated.

Both the Port and City have committed significant resources toward the Waterfront Redevelopment effort, which holds remarkable promise in creating a very desirable area to enable building new businesses, institutions, residences and recreation areas for wide public use.

To enable this, millions of public dollars will need to be spent on clean-up, infrastructure and reliable waterfront access, with significant funds already spent or committed to this effort.

Upon completion, likely to require 20 years or more, this new 'neighborhood', adjacent to the existing downtown, is expected to accommodate businesses providing between 2500 and 4800 new jobs and over 2000 new dwelling units to house future growth.

Additionally, this venture is intended to make the Waterfront 'Bellingham's Front Door' by providing a clean, accessible, waterfront area designed to sustainably attract businesses, tourists and area residents interested in shopping, recreating and generally enjoying a great gathering space for multiple activities.

Converting this former, uninviting industrial area into a very desirable spot requires not only years of hard work, vision and funding, but insuring against unanticipated changes in events likely to be detrimental to it, like more than doubling the rail traffic that separates the Waterfront from the downtown and residential areas.

It is hard to imagine an unanticipated event that could be more harmful to the goals of a successful Waterfront Redevelopment than the sudden addition of 18 unit coal trains per day, each 1.5 miles long, blocking necessary road crossings, blaring high decibel noise and spewing diesel fumes and dust into the air.

What tourist, shopper, business owner or resident would consciously wish for such a round-the-clock nuisance?
Certainly no one that I know!

Even if grade-separated crossings were possible, they would likely be prohibitively expensive and take years to build, since there are more than a dozen of these, alone, within Bellingham's City Limits.
An average cost per bridge might approach $10 million, providing sufficient space is available and could be acquired.

That is a very large burden to impose upon any municipality and ought not to be allowed, particularly for selfish and arbitrary reasons.
Even with substantial mitigation, providing that is possible, the imposition of 18 additional very long trains per day, is a hurdle that threatens the very viability of the entire Waterfront Redevelopment Project.
That is simply unacceptable!
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Tuesday, October 2, 2012

GPT: EIS Comment No. 9

Financial Underpinnings

I have some concerns over the long term financial underpinnings upon which the GPT proposal is based, notwithstanding the deep-pocketed backers including Goldman Sachs. 
 The GPT proposal seems a distinct major departure from prior projects undertaken by SSA-Marine, one so ambitious that is expected to practically double SSA's reported annual revenues.
 Every such venture has a 'pro forma' basis for it to be seriously considered for advancement and undertaken, and so must GPT, with its reported corporate secrecy and opportunistic aggressive operating philosophy and lack of management experience in building and operating a large bulk terminal with the potential of creating so many collateral social, environmental and economic problems. 

What underlying assumptions are baked into this proposal that make it so attractive to the investment partners, besides a quick payout and avoidance of liability? 

What is GPT's best case scenario? A 10-year, or better, payback?

At what point would the idea become so much less attractive that the proposal would simply be withdrawn?
 Is GPT a truly long-term commitment to the economic health of our community, as is being claimed so loudly, or is it simply an opportunity to make a quick buck by flipping any favorable permitting result into a sale to another owner(s)?

Our community needs to know these answers with some degree of certainty to make sure the expectations for jobs, increased local business activity and the generation of new tax revenues to support local government, is fully realized by both the public and the final decision-makers. 

This EIS Scoping is serious business and needs to develop some serious answers that we can count on, before we commit to GPT our hopes for economic, ecological and social improvement. 

It is the community that must live with these results, not some financier or executive sitting in privileged silence and opulence somewhere else!

My concern is that the GPT proposal is built upon a questionable foundation that sits upon these several variables, among possible others: 

• natural resource extraction of a relative low value commodity [something more worthy of  a desperate, third world country]

• volatile and fluctuating global prices  [risky and often resulting in a race to the bottom]

• a 19th century technology that is known to have harmful impacts worldwide  [a step backwards into history that arrogantly disregards healthful common sense]

• a capital intensive method of transport logistics  [why ship relatively low value goods halfway around the world?]

• a business model that depends upon economies of scale and materials handling efficiency to compensate for an inherent lack of profitability  [a ticket to disaster, especially in the global economy]

• risky weather and other natural conditions that often and sometimes unpredictably threaten land, sea and air, often in sensitive areas  [very large, single hulled, single screw ships carrying a flammable cargo in dangerous conditions; a disaster waiting to happen]

• reliance upon foreign competitors to buy coal at prices that insure profits over a long time.  [a fool's dream]

• excessive focus on a low-tech business model that avoids other, value-added products and modern, domestic technologies that are much more likely to provide more good jobs and sustain our economy in the future.  [opportunistically shortsighted] 

• creating at least as many harmful and disruptive impacts as benefits, and externalizing these costs to others, including taxpayers, governments, businesses affected and future generations.  [not the sort of behavior normally expected of a good corporate neighbor]

• failing to understand the finite nature of our essential resources on this planet that must sustain us all.  [just plain stupid]

• buying into the flawed theory that indiscriminate, continual growth is necessary, good and unavoidable.  [the philosophy of a cancer cell; unsustainable, neanderthal thinking]

• deliberate denial of the environmental policies adopted by the States of Washington and Oregon, both of which have decided to phase out coal fired power plants. Shipping coal to China will mean the coal burned there will create the same atmospheric pollutants that harm us, without any benefits.  [willful ignorance and distain for policies and regulations deemed necessary for human and ecological health]

• forceful intrusion into areas and regions unprepared for the congestion and dangers inherent in massive unit trains and marine bulk carriers that threaten the very communities and sensitive environments they pass through on the way to foreign 'markets'.  [callous disregard for preservation of the planet and its people]

Surely, there are better business models for providing the same -or greater- benefits now being claimed by GPT.

What assurance can this community have that the present owners -SSA- will maintain ownership for the designed life of this facility [50 to 75 years], should it be built?

Monday, October 1, 2012

GPT: EIS Scoping Comment No. 8

Vessel & Rail Capacity & Congestion

The very ambitious proposed GPT project depends upon a very large wharf and trestle structure that extends into a known, critical herring spawning area and is in close proximity to BP's existing petroleum loading pier, which supplies crude oil from Alaska and ships valuable refined products from the refinery to US markets. 
Soon, BP will need to expand this facility to accommodate additional crude and refined products shipping for US consumption.

I am concerned that the huge GPT wharf will constitute too much potentially dangerous ship congestion in that immediate area, as well as the narrow shipping lanes that provide water access to it. It is particularly troubling that the use intended by GPT is to ship large volumes of American coal to foreign powers and competitors, while burdening communities and citizens to deal with the offsite impacts. 

A similar concern applies to GPT's dependence on BNSF's rail capacity, which likely will become necessary to convey petroleum products.

Our natural resources, rail system capacity and deepwater access are valuable, and should prioritize those uses that are in our national interest.
Rather than have the GPT proposal absorb so much rail and maritime access capacity, a better plan would be to reserve these capacities for existing, sustainable and domestically important uses.

Sunday, September 30, 2012

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 ?? 
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Saturday, September 29, 2012

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:
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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.
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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.
-----------------------------------
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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Thursday, September 27, 2012

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."
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Wednesday, September 26, 2012

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