GPT: EIS Scoping Comment No. 15

Wasteful Water Use

The GPT Application -Section 5.13.1.2- contemplates the use of 5.33 Million gallons per day of PUD #1 water, primarily for coal dust suppression and reduction of spontaneous combustion risk.
However, there are likely better uses for this water, such as for agricultural use, in-stream flows, hydraulic well re-supply, etc.

This amount represents almost one-third of the approximately 17 million gallons a day of PUD supplies of industrial water to other industries located at Cherry Point; just over a third of its total water rights of 53 million gallons a day. 
The estimated water supply is anticipated as sufficient for all GPT terminal operations including dust suppression, plus fire suppression and safety.
GPT would make its own potable water by treatment of industrial water with a reverse-osmosis treatment system.

For comparison, this GPT water is equivalent to about one-half of the water used by the City of Bellingham per day to supply the needs of over 95,000 people.

It has been estimated that the water permits already issued in Whatcom County by DOE may amount to up to 2.5 times the water that is actually available.
In the interest of responsible water conservation -already a serious seasonal concern for the Nooksack River and its drainage- does this projected use make sense?

How much, if any, of this water will be reclaimed for re-use?
Will the storm water treatment systems be designed to recapture this spray water as runoff?

Certainly better uses of 5.33 million gallons per day can be found than spraying it on mounds of coal in an operation that might employ only about 200 people.

GPT: EIS Scoping Comment No. 14

Chuckanut Drive Landslide Hazard

The BNSF single mainline track south of Bellingham and below Chuckanut Drive follows a narrow passage between steep slopes on one side and water on the other. 

This particular corridor has a long history of landslides, which periodically block both State Highway 111 -Chuckanut Drive- and the railroad, requiring traffic delays and emergency clearing of both routes before vehicles or trains can proceed in either direction.

Because the geology of the Chuckanut Mountains contains formations of Chuckanut Sandstone that are frequently layered at angles tilted down slope, this represents an extremely hazardous situation that is conducive to landslides, especially in wet weather.

If a blockage due to landslide or other factors were to cause a train derailment occurrence in this narrow and relatively inaccessible corridor, how would this be handled in terms of clearing the railroad right-of-way? 
How would multiple carloads of coal dumped on the shoreline be cleared, and with what impacts on the water and other rail traffic, including AMTRAK passenger trains?

What special emergency services would be needed to rescue any injured people, and how would these be deployed and paid for?

Since this corridor is very constricted with limited platforms capable of supporting cranes and other lifting devices, how would disaster response be provided?

This problem needs to be treated as an integral part of the EIS Scope, and a comprehensive Hazard Response Plan developed to satisfy the important need for public safety throughout the recognized zone of influence of the GPT proposal.

GPT: EIS Scoping Comment No. 13

Coal Dust Clouds?

There have been repeated reports of sightings from boats traveling in Rosario Strait, of dense, dark clouds that appear periodically from north of Point Roberts.
These are suspected to be emanating from the coal terminal in British Columbia, which has troubling health-related implications should the much larger GPT facility ever be built here in Whatcom County.

The MAP Team needs to have these reports checked out to confirm if these dust clouds are, in fact, coal dust, and if so, to utilize that qualitative information to inform its EIS evaluation accordingly.

The GPT Applicants claims that dust suppression methods -including partial enclosures, baffles, negative pressure ventilation with bag filters, and water sprays- it plans to use will effectively prevent such dust clouds from escaping its premises, however these claims do need to be independently verified by competent authority to insure the Applicant's claims are accurate.

Only by quantifying the amount of coal dust generated from trains, violent car dumping, operation of stacker-reclaimers, multiple conveyors and conveyor transfer towers, and ship loaders, plus solids recovered from storm water treatment systems, will we know the extent of dust problems likely to impact the public and the environment.

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.
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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?

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.

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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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?

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.

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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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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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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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. 
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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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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?