EIS Home > EIS Library > Scoping Report > Appendix G - All Scoping Comments > Organizations

Allyson Brooks (League of Women Voters of Thurston County) (#6498)

Date Submitted: 01/06/13
Location: Olympia, WA
Comment:
As President of the League of Women Voters of Thurston County I am submitting comments on the Scoping process. We ask that you include an analysis effects to our county in the Environmental Impact Statement.
Sincerely,
Allyson Brooks Ph.D.
President, League of Women Voters of Thurston County

(see attached)
Attached Files:

Amy Carey (Preserve Our Islands) (#12196)

Date Submitted: 01/22/13
Location: Vashon, WA
Comment:
Comment letter from Preserve Our Islands is attached. Please add the organization as a party of record and add us to electronic and hard copy mailing lists.


Thank you,

Amy Carey, Executive Director
Preserve Our Islands
PO Box 845
Vashon, WA 98070
acarey@preserveourislands.org
Attached Files:

Arlene French (Evergreen Islands) (#2875)

Date Submitted: 11/12/12
Comment:
To whom it may concern:

The attached letter contains Evergreen Islands comments regarding the danger to the 3 resident Orcas Whale pods, living in the San Juans, due to increased shipping, particularly by the proposed use of the “Cape Size” container vessels. The most serious danger is the increased possibility of collisions of ships with Orcas.

Thank you for your consideration,

Arlene French, Board Member
Evergreen Islands
Attached Files:

Arthur Grunbaum (#11839)

Date Submitted: 01/22/2013
Location: Westport, WA
Comment:
Cumulative effects. Coal and Crude Oil projects See attached, pdf
January 22, 2013
Whatcom County,
Washington Department of Ecology
U.S. Army Corps of
Engineers
GPT/Custer Spur EIS
1100 112th Ave. NE, Suite 400
Bellevue, WA 98004
Submitted via email: comments@eisgatewaypacificwa.gov
To Whom it May Concern:
Thank you for the opportunity to comment on the proposed coal export terminal at Cherry Point.
FOGH is a broad-based 100% volunteer tax-exempt 501(c)(3) citizens group made up of crabbers, fishers, oyster growers and caring citizens. The mission of FOGH is to foster and promote the economic, biological, and social uniqueness of Washington’s estuaries and ocean coastal environments. The goal of FOGH is to protect the natural environment, human health and safety in Grays Harbor and vicinity through science, advocacy, law, activism and empowerment.
We understand that you have received thousands of concerned comments about this project, including but not limited to various tribal organizations, the Waterkeeper Alliance, Washington Environmental Council, Puget Soundkeeper, Friends of the San Juans, Power Past Coal, Climate Solutions and others. We incorporate those comments by reference.
We have some specific concerns that we would like addressed:
1. Water, air, earth, transportation, fish and other marine resources that could be affected by this and other projects which rely on fossil fuels for their economic base. How will this affect the marine resource industries and human health of the Pacific Coastal Communities?
2. Cumulative effects for this fossil fuel and similar projects which consider crude by rail (CBR) to the above referenced Port. In addition what would be the cumulative effect of the three projects for CBR proposed at the Port of Grays Harbor in Central Washington.
Sincerely,
Arthur (R.D.) Grunbaum
President
Attached Files:

Ben Grace (#11364)

Date Submitted: 01/22/2013
Location: Seattle, WA
Comment:
Please see the attached letter.
Attached Files:

Bob & Molly Boudinot & Doran (Skagit Land Trust) (#2582)

Date Submitted: 11/06/12
Location: Mt Vernon, WA
Comment:
see attached
Attached Image:

Brian Gruber (Ziontz, Chestnut, Varnell, Berley & Slonim (Attorneys for League of Women Voters of Bellingham/Whatcom County and North Cascades Audubon Society) (#11964)

Date Submitted: 01/21/13
Location: Seattle, WA
Comment:
see attached
Attached Files:

Brian Wright (#10182)

Date Submitted: 01/21/2013
Location: Lake Stevens, WA
Comment:
In the Viewpoints section of Everett Herald on Sunday January 20th 2013 a piece entitled Oceans at risk, a culture at stake by Terry Williams, Commissioner of Fisheries and Natural Resources and Director of the Tulalip Tribes Natural Resources Treaty Rights Office spoke of the damage being done to our oceans due to the acidity caused by excess CO2 in the atmosphere. Mr. Williams makes the following statement in his article:

“Frankly, there's not much we Washingtonians can do by ourselves about the cause of ocean acidification: global CO2 emissions. We contribute such a small amount to the 70 million tons of CO2 that the world pumps into the atmosphere every day. What we can do is be a model for taking thoughtful and responsible action, for educating others about acidification and urging them to reduce greenhouse gas emissions.”

I disagree that there is not much Washingtonians can do as a bit later in the same article he writes the following:

“An immediate choice that faces Washington is whether to allow coal mined in Utah and Wyoming to be transported across our state and shipped to Asia. The Tulalip Tribes and other first nations in the Salish Sea are unanimously opposed to this project due to the negative impacts that it would cause locally, regionally and globally. The most ecologically sound action to take with that coal is to leave it in the ground where it sequesters all that carbon and other pollutants. When promoters of the project speak about the jobs that will be created, they neglect to consider the potential jobs lost among those who catch, raise, process and sell seafood.”

I concur with Mr. Williams and the first nations in the Salish Sea area and recommend that the people of this state, our state government and the federal government take a step forward in halting further increases in global CO2 emissions by refusing to have any additional coal shipped through the state of Washington to be further transported to other countries for consumption in order to satisfy the greed of those who would rape the earth to mine the coal.

Sincerely

The Rev. Brian Wright
Deacon St. Hilda St. Patrick Episcopal Church
15224 52nd Avenue W.
Edmonds, WA 98026-4304
Tel: (425)743-4655
Attached Files:

Carla Morgan (Lopez Island Family Resource Center) (#11998)

Date Submitted: 01/17/13
Location: Lopez Island, WA
Comment:
see attached
Attached Image:

Carol Seaman (Citizens for a Clean Harbor) (#6646)

Date Submitted: 01/07/13
Comment:
As a lifetime citizen of the Pacific Northwest, I have always taken pride in this beautiful and pristine area, The Evergreen State, Washington, my home of beaches, mountains, orchards, agriculture, rivers, fish, trees, wheat fields etc . The people living here are, and have been historically, concerned with the way in which we look at the earth, our mother, as versus the lack of concern displayed by certain big business, such as the petroleum and coal industries. You cannot tell me we need another environmental statement by the Army Corps of Engineers or anyone else. They can say whatever they choose-- WE know, and the scientific evidence is in--this business of transporting coal from Wyoming, Montana, Anywhere? is not good. WE citizens are left to lobby against this absurd proposal and that is what we intend to do...and continue doing until we make our point and the trains head a different direction. The coal should be in the ground. The ONLY, and I repeat ONLY, benefactors of coal trains through the Pacific Northwest on their way to the proposed polluting terminals where the coal will be shipped to Asia--are the petroleum companies. Dangling a few jobs out there for people in Washington is dishonest. WE are not that desperate. We do not need YOUR kind of jobs. We need to support industries that are beneficial to the citizens of this state in a healthful and clean way...that is possible! Certainly.

I ask you, who on earth, besides these particular, greedy money making concerns, wants millions of tons of coal dust blowing along our beautiful waterways, over our fields along the way from Montana and Wyoming, causing sickness in our communities, in our schools and in our citizens, so that Asia can burn coal? Please, this has been thrust upon the citizens of the states of Washington and Oregon in the most underhanded manner. It is shameful! And our government who is handing out the mining rights, for practically nothing, to these big business concerns should be ashamed also. Do you know how many coal miners are dead? We could use them here to lobby for us at this moment.

Specifically, it appears this plan to make Cherry Point the largest exporter of coal in the United States has been in the making for some time...kept under the radar until recently. Bellingham is a thriving community--a university town on the Puget Sound. This plan would ruin Bellingham and communities all along the way. At least citizens are fighting back now--responding to the environmental & health facts & concerns which have been revealed to them. Do you know that 500 to
1000 pounds of coal dust spews into the air & water from each one of those proposed 125 car trains coming down the Columbia River Gorge, or through the Tongue River Valley in Montana. Do the math...that's an overwhelming amount of coal dust and there is nothing anyone can say to change the facts!

Arsenic kills--as do many other elements in coal. It kills water! It kills people! It makes us sick, both literally and figuratively that the proposal to send these trains, carrying millions of pounds of coal through our scenic byways and our communities is being considered simply in the name of greed. Nothing else. There is no benefit. Period.
WE can only hope that the COAL MONGERS will awaken from a very evil dream and realize that the citizens whom they are trying to "roll over" are not going to take this lying down.

Why isn't the Governor of the State of Washington, or the Superintendent of Public Lands, or the Dept. of Fish and Wildlife, or any other powers that be standing up and assisting the thousands of people opposed to making Washington a conduit for cheap coal to China? While the big profits for the rails & coal industry mount up-- our environment is literally destroyed, and our citizens of this state are sickened in the process. It is our state! Say, "No" to this inhumane, environmentally unsound plan of coal trains & coal terminals stockpiling in Washington State--or Oregon, or anywhere for that matter. Where is the common sense so lacking in this situation?

Sincerely,

Carol Seaman
Citizens for a Clean Harbor
Grays Harbor County
Washington State

Cascadia Wildlands (#8545)

Date Submitted: 01/17/2013
Location: Eugene, OR
Comment:
Cascadia Wildlands
P.O. Box 10455
Eugene, OR 97440

January 17, 2013


Mr. Randall Perry, NW Field Office
U.S. Army Corps of Engineers
1440 10th Street, Suite 102
Bellingham, WA 98225
Randel.J.Perry@usace.army.mil

Mr. Ted Sturdevant, Director
Washington Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
tstu461@ecy.wa.gov

Mr. Tyler Schroeder, Current Planning Supervisor
Whatcom County Planning and Development Services
5280 Northwest Drive
Bellingham, WA 98226
Tschroed@co.whatcom.wa.us

Via E-mail and U.S. Mail

RE: Docket number COE-2012-0016: Proposed Gateway Pacific Terminal coal export proposal draft EIS scoping comments


U.S. Army Corps of Engineers:

The following comments are submitted by Cascadia Wildlands. Cascadia Wildlands is an environmental non-profit organization based in Eugene, Oregon. We work to protect wildlife and wild places throughout the Cascadia bioregion, which stretches from northern California to Alaska. We have more than 6,000 members, who are concerned about threats to the environment in Cascadia from logging, the transport, mining, and export of natural resources, and other environmentally-harmful projects.

We urge the U.S. Army Corps of Engineers (“USACE”) to conduct a thorough, comprehensive environmental impact statement (“EIS”) for SSA Marine's proposed Gateway Pacific Terminal at Cherry Point. The proposed project would adversely impact Federally-listed endangered species, keystone species, air and water quality, local economies and public health and safety. Additionally, it would unreasonably interfere with navigation, transportation, fishing, and public recreation and accelerate the impacts of climate change.. The proposed project would see the export of 48 million metric tons of coal per year, which would have disastrous impacts on endangered fish species, water resources, navigation, fishing, and public recreation. The facility would be the largest coal terminal in the U.S. shipping up to 48 million metric tons annually and should not be authorized before a comprehensive EIS considers the impacts of mining coal in the Powder River Basin, transporting that coal to Washington, exporting it via the Gateway Pacific Terminal, and burning that coal in international markets. This analysis should also be cumulative in nature and consider this proposal in the context of the overall collection of Northwestern coal export proposals.

The proposed project would adversely impact Federally-listed endangered species. The Salish Sea is designated critical habitat for eight Federally-listed fish species, including threatened and endangered Chinook salmon, bull trout, and Puget Sound steelhead trout. The proposed project would impact these endangered species. In addition, Cherry Point herring located in the project area are a keystone species, providing food for many other species in the area at a critical time. The Cherry Point herring population has already vastly declined, likely due to industrial discharges in the area. Further threatening the herring's survival by allowing the construction of the Gateway Pacific Terminal could have disastrous impacts for many marine species in the Salish Sea. For example, Cherry Point herring constitute roughly two-third of the diet of Chinook salmon. Chinook salmon are an important food source for Puget Sound orca whales. Fisheries consultant Fred Felleman stated that “the proposed Gateway coal terminal would most likely be the dock that breaks the herrings' back.” In 1999, under the terms of a settlement agreement between SSA Marine and a coalition of state agencies and environmental nonprofits, baseline studies of the status of Cherry Point herring were ordered. However, these studies have not been initiated. If there's no clear sense of what's caused the decline in herring population and what their current numbers are, it will be exceedingly difficult to evaluate the impact of a potential project on their numbers.

SSA Marine states that it will protect marine life by aligning the wharf to maximize the amount of natural light that reaches the water, using a cargo loading system that will minimize dusting as coal is transferred to barges, and requiring that incoming ships discharge their ballast 200 miles from shore to avoid introduction of invasive species. However, there is no assurance that SSA Marine will truly undertake these voluntary initiatives. For example, there is no Federal standard for ballast discharge. The increase in marine traffic, the potential for coal dust release, and disruption of natural light all pose significant dangers to local endangered and embattled species. The in-water construction for the Gateway Pacific Terminal in designated critical habitat would result in the loss of critical habitat. Over-water work would increase shading in designated critical habitat, which attracts species which prey on endangered salmon and steelhead. USACE must consider the scope of the project's impacts on endangered marine species and Cherry Point herring.

The proposed project would adversely impact water quality. Trains carrying coal from the Powder River Basin would arrive uncovered and be staged at the Gateway Pacific Terminal, where dust from the trains would surely enter the Salish Sea via process wastewater and stormwater. Most coal terminals are not enclosed, which further amplifies the risk that coal dust and other contaminants could enter the Salish Sea. SSA Marine states that it will use enclosed conveyor belts and enclosed unloading facilities in order to prevent the spread of coal dust, but has not included design specifics demonstrating the extent to which the terminal will be covered and the feasibility of constructing a covered coal terminal. Powder River Basin coal is particularly friable because of its low BTU content, which further increases the likelihood of coal dust entering the waterway if the terminal is not fully enclosed. USACE must consider the impacts the proposed project would have on water quality.

The proposed coal export project would vastly increase greenhouse gas emissions, because it would export 48 million metric tons of coal per year to be burned. This will result in an immense increase in greenhouse gas emissions, which have been demonstrated to contribute to climate change. Although the coal will be burned primarily in Asia, greenhouse gases are non-fixed and migrate globally. Climate change is an international issue blind to national borders. Additionally, the transport of coal in the U.S. via rail and barge will also result in greenhouse gas emissions. This increase in temperature is predicted to have disastrous impacts on Washington's waters and ecosystems. USACE must consider the climate change impacts resulting from the cumulative proposed project. There are similar concerns for ocean acidification which is a growing problem in the Pacific Northwest linked to global discharges of carbon dioxide and other fossil fuel emission such as sulfur and nitrogen compounds.

The proposed project would harm navigation, fishing, and recreation activities on the Salish Sea. The Salish Sea is used for recreational boating and fishing, as well as tribal fishing. The increased number of tugboats and barges on the Salish Sea as a result of the project will hamper the ability of individuals to use the River for recreational purposes. Tribes in the northwest, including the Lummi, the Swinomish, and the Tulalip, have expressed concern about impacts on their fishing rights as well as other tribal resources—the proposed project would result in air and water pollution, threaten tribal health and safety, and negatively impact tribal economic development. Tribal fishing rights are one of the few rights reserved by the tribes under the treaties entered into between tribes and the U.S. during the nineteenth century. The Puget Sound Area tribes, including the Lummi, Swinomish, and the Tulalip, were assured “the right of taking fish at usual and accustomed grounds” in the Treaty of Point Elliott of 1855. These tribes' fishing rights were upheld in 1974, and later affirmed by the U.S. Supreme Court in 1979. USACE must consider the proposed project's impacts on treaty-granted tribal fishing rights.

The proposed project has broad and significant impacts that must be considered in an Environmental Impact Statement. SSA Marine's proposed Gateway Pacific Terminal for the export of coal to China and South Korea is part of a broader scheme to transport coal from the Powder River Basin to ports in Washington and Oregon and then export this coal for use in Asia. The cumulative impacts of this comprehensive project, which would see the export of 155 million tons of coal each year from ports in Washington and Oregon, must be considered. Roughly 60 trains would come and go through Washington and Oregon each day. This cumulative project threatens disastrous impacts, including the acceleration of climate change, pollution of air and waterways, and public health and safety impacts. In addition to environmental, endangered species, and air and water quality impacts, operation of the Gateway Pacific Terminal would also create traffic, noise, dust, and public health and safety concerns. These considerations cannot be pushed off to a later date. The USACE must consider the cumulative impacts of the overall project to export 155 million tons per year of coal from Oregon and Washington to Asia.

The USACE should also consider that there is no public need for the proposed project. The coal exported via the terminal will not be used to generate energy in Washington or even in neighboring states. Instead, the coal will be exported for use in China and South Korea. Foreign “need” for a U.S. natural resource is not a “public need.” The only individuals who will benefit if the proposed project moves forward are a handful of industry executives, as well as Asian purchasers. Furthermore, because Powder River Basin is from a de-certified coal-producing region, the coal is sold at a far lower price than fair market value, so the project is a disadvantageous sale that will not benefit the people of Washington financially. The state of Washington and its citizens have already decided that coal isn't a worthwhile energy source; Washington's final remaining coal-burning power plant is slated to close by 2025 after campaigns from environmental groups and the passing of state legislation setting climate change goals. USACE must consider the lack of public need for the proposed project.

SSA Marine points to the creation of jobs as a major justification for the proposed Gateway Pacific terminal. However, because of the volatile nature of the coal market, jobs are not guaranteed, and Pacific Northwest residents are rightfully skeptical after the collapse of the Port of Portland coal export project in the 1980s. A developer began constructing a terminal, but never completed it when Asian demand for U.S. coal plummeted, and the Port of Portland and private investors lost millions of dollars as a result of the failed deal. There is no guarantee that the same will not happen again. In 2008, Kinder Morgan, a pipeline and terminal company considering constructing a coal export terminal at the Port of Vancouver, stated in an internal e-mail that coal is “the most-risky bulk mineral market” and that the volatile prices for coal create “a real danger in losing investment.” The jobs and economic benefit that SSA Marine insists the Gateway Pacific Terminal project would create are too risky to rely on.

We are also concerned about the scoping process for the Gateway Pacific Terminal. The e-mail for submitting comments was phished by a pro-coal organization which sent e-mails to other supporters of the project soliciting comments. SSA Marine paid day laborers to stand in line at scoping meetings and comment favorably on the project, depriving those who wished to comment verbally of the chance to do so. Both of these events demonstrate a lack of fair play by those supporting the project and, more importantly, a deprivation of the chance to comment for those who are concerned about environmental, health, and public safety impacts of the project.

The proposed project threatens disastrous consequences for the Salish Sea's endangered fish species, the environment, and recreational and tribal uses of the Sea. There is no demonstrated public need or benefit from the proposed project. Cascadia Wildlands urges USACE to undertake a comprehensive Environmental Impact Statement evaluating the environmental impacts of the coal export project as a whole, including the mining of coal in the Powder River Basin, the transport of this coal to Cherry Point, the export of coal from Cherry Point to Asia, and the burning of coal in Asia, in order to ensure that the proposed project does not cause permanent and irreparable harm to Washington's environment, endangered species, and citizens.

Chris Johnson (#1695)

Date Submitted: 10/25/12
Location: Bellingham, WA
Comment:
See attached.
Attached Image:

Chris Wilke (Puget Soundkeeper Alliance) (#11919)

Date Submitted: 01/22/2013
Location: Seattle, WA
Comment:
Please see attached.
Attached Files:

Colin Lauderdale (#11191)

Date Submitted: 01/22/2013
Location: Billings, MT
Comment:
Attached is a comment letter from the Western Organization of Resource Councils concerning scope of study for proposed Gateway Pacific Terminal and Custer Spur expansion projects.
Attached Files:

Communitywise Bellingham (#11570)

Date Submitted: 01/22/2013
Location: Bellingham, WA
Comment:
Communitywise Bellingham has been identified by the EIS Agencies as a Key Stakeholder. We have been active in developing research and suggesting process for the last two years. Our focus is local, Whatcom County and Bellingham. This is one in a series of comments on specific aspects of issues.

CWB respectfully requests that the GPT EIS include a comprehensive, economic cost-benefit analysis for Whatcom County, covering the specific impact and issue areas detailed in the follow pages. In addition, we request that the EIS include a broader economic cost-benefit analysis that includes its economic impacts on the communities directly impacted by the project’s train and vessel traffic. While our organizational mandate focuses on Whatcom County, we are compelled by the call of other rail and vessel corridor communities that the project’s potential impact on their local economies should be fairly considered.

Specific impacts that we believe are significant and reasonably foreseeable consequences of GPT and merit close study as part of a comprehensive cost-benefit analysis follow below:

GPT’s train traffic-related impacts will likely reduce Whatcom County’s projected rate of employment growth with a possible net negative employment impact for the County.
As a result of other impacts outlined below, GPT’s train traffic-related impacts on other economic sectors can be expected to reduce Whatcom County’s projected rate of employment growth. If this drain on other projected employment growth passes above the 13% threshold during the first ten years of the terminal’s construction and operation, GPT’s impact will produce a net negative impact on Whatcom County employment, according to the 2012 study by Public Financial Management. (1) Some economic areas and assets identified as particularly vulnerable to negative GPT impacts include: Bellingham’s waterfront development, tourism, attracting and retaining a mobile professional sector, property values, and Bellingham’s outdoor/green “brand.” (See more on these topics below.)

GPT’s train impacts could result in significant mitigation costs to local taxpayers.
The GPT train-related mitigation costs that would be required to partially recover the current level of waterfront access in Bellingham could reach into the hundreds of millions of dollars. The more than two-fold increase in train traffic as a result of GPT will require new train tracks (“active sidings”) in Whatcom County, most likely along the Bellingham waterfront, blocking vehicle access to Boulevard Park and obstructing current pedestrian access points along much of the waterfront. (2) Bridges, overpasses, parking structures and other construction would be needed to mitigate this situation. Legally, BNSF is exempt from paying above 5% of mitigation costs; the remaining 95% of the bill falls to the local jurisdictions. These substantial and foreseeable costs to the public should be identified in EIS and calculated into the GPT balance sheet.

GPT’s significant increase in train traffic will result in increased train noise and traffic congestion, possibly harming nearby businesses.
GPT will create increased train traffic along Bellingham’s waterfront and downtown areas. This is significant, probable and foreseeable as the GPT PID states that the terminal will need ten new train trips a day for Phase I and 18 trains a day for Phase II. Current train traffic though Bellingham is estimated at 12 to 14 trains a day. With this substantial increase in the volume of train traffic, coal trains’ heavy weight and their extended length spanning more than 1.5 miles, increased levels and frequency of train screeching and successive horns blowing can be anticipated.

Due to the Bellingham’s number of at-grade crossings, significant traffic delays are also expected in the downtown and waterfront areas, according to the 2012 Gibson Traffic Consultants’ report. (3) Increased noise and traffic congestion can be reasonably expected have a detrimental impact on existing and future businesses in the vicinity.

GPT train-related impacts could dampen the economic success of redevelopment at the former Georgia Pacific site along the Bellingham waterfront.
Both the PFM study of GPT’s potential economic impacts and the GTC’s traffic analysis indicate that GPT trains could pose a real threat to waterfront redevelopment. GTC concludes that, “preliminary analysis suggests potentially severe consequences for the City’s transportation plan and planned waterfront redevelopment.” (4) Investment in waterfront redevelopment could reach $1 billion over the next 25 to 30 years and produce 5,600 direct jobs, according to the Port of Bellingham. Even a minor negative impact on the waterfront’s redevelopment and employment creation could completely offset any GPT employment gains for Whatcom County.

Tourism could suffer from high volume coal train traffic.
Four out of five visitors to Whatcom County traveled through Bellingham and found Chuckanut Drive and Boulevard Park among the top attractions, both of which will be affected by GPT coal train traffic. Visitor surveys have shown that some of the highest rated County and City attractions are the environment, parks, scenic areas, recreational trails, and downtown Bellingham and Fairhaven as particularly important draws. The degree to which these visitor experiences are lessened by increased train traffic, noise, diesel exhaust, reduced waterfront access or other related GPT impacts, tourism-based revenue and employment could suffer.

GPT impacts could lessen the in-migration and retention of professional and entrepreneurial sector.
The GPT terminal could make the City and County less attractive to professionals and entrepreneurs concerned about the quality-of-life impacts of a large coal transportation and export operation. PFM found that in terms of in-migration of skilled workers and entrepreneurs to the region’s economy, ”the choice of living in the County or City is worth something to individuals and they appear willing to pay for the region's location, lifestyle, and geography.” (5) This lessening of the area’s real or perceived “livability” due to high volume coal traffic could have a significant impact on employment growth from new businesses attracted to area.

GPT impacts could damage the area’s green “brand.”
“Both tourism and the in-migration attraction are based in part on the perception of the area as environmentally conscious,” the PFM study found. Currently, the region is seen as a green and socially responsible area. To the extent that GPT changes current residents’ experiences with lifestyle characteristics they value, out-migration (particularly among those in the mobile class of skilled workers and entrepreneurs who bring large incomes to the County and/or are job creators) could be an economic risk to the area.

GPT train traffic could interfere with local freight delivery.
GPT trains could overwhelm local rail capacity, with potential impacts for local businesses that depend on the rails. GTC’s analysis identified this concern: “A key question may be whether this interstate traffic from the coal trains will have the impact of reducing the availability of local rail spur business necessary to serve Bellingham businesses. These issues can be analyzed as part of the economic impact analysis.” (6)

GPT train traffic could decrease property values along the rail corridor.
Published research shows that prospective homebuyers view locating near train track with heavy freight traffic very negatively, and would rather locate beside an interstate highway. (7) For this reason, increased freight rail traffic will diminish the value of affected real property relative to non-affected real property. The negative effect from increased freight rail traffic is multi-dimensional and cumulative. Studies suggest that negative effects on real property prices can be expected to follow from: noise, health and safety concerns (interrupted sleep, emergency vehicle delay), air quality effects (diesel particulates, coal dust), land use impacts (recreation – decreased access to parks, ability to enjoy parks), traffic (traffic delays at level crossings); and socioeconomic impacts (perceived “livability,” damage to a community’s “brand,” and loss of economic development opportunities).

Expected diminished property values will likely be one of the most tangible methods for assessing cumulative adverse impacts from increased freight rail traffic from GPT. For this reason, CWB requests that the co-lead agencies take the following actions within the EIS:

A. Carry out a comprehensive, peer-reviewed literature review on the direct, indirect and cumulative relationships between change of intensity of freight rail traffic and property values. The study should identify any non-linear relationships, or inflection points, between freight train intensity (proximity, frequency, duration, decibels, ground vibration) and property values.

B. Identify all expected direct, indirect and cumulative effects to property values attributable to increased GPT-related train activity and, to the extent possible, quantify these using an econometric analysis. Econometric methods, real estate sales data and other available data exist, making quantification possible, though new research and data analysis may be required. A study may need to be conducted in a region that could generalize to other regions along the mine-to-GPT rail corridor. A conclusion that GPT-related freight train impacts on property values cannot be considered due to the existence of little or no evidence is unacceptable.

C. Include all affected property in the rail corridor in the economic analysis.

D. Include an estimate of net change to property tax revenue following from expected decreases to property values in the economic analysis.

E. Identify proposals for mitigating negative effects on property values.

F. The econometric analysis might also be able to quantify potential benefits to real property values from effective mitigation (benefits from sound barriers, overpass construction, etc.)

Coal and shipping vessels could impact commercial fishing and exercise of tribal fishing rights.
New piers, high volume vessel traffic, anchorages, increased risk of ship collision, coal leachates, fugitive coal dust and on-going tanker discharge of pollutants into Salish Sea could each have a detrimental impact on fish populations—Cherry Point herring in particular, which is central to the health of Puget Sound salmon and marine mammals. All these impacts require close study. (Please see Friends of the San Juan’s GPT scoping submission for a fuller discussion of these concerns and a related list of specific impacts the EIS should cover.) (8)

In addition, GPT vessel impacts need to be analyzed in the EIS within a cumulative context, taking into account both current industrial operations in the region and the anticipated increase of vessel traffic from Canadian tar sands oil and coal producers shipping through the same Salish Sea routes. Daily, baseline GPT coal and vessel impacts must be studied as well as the likely damage from and response to a catastrophic event such as a vessel collision. The question of “who pays?” must be addressed.

These daily and catastrophic GPT impacts could translate into an economic loss for the local fishing industry. The economic impact on nearby island communities must be assessed. In addition, harm to local marine species and increased vessel traffic could negatively impact Lummi and other tribal nations’ ability to exercise their fishing rights, with economic and other repercussions.

Estimates of GPT economic benefits locally may be inaccurate.
A thorough cost-benefit analysis of GPT must verify the presumed benefits in addition to quantifying the costs. Some stated employment gains for Whatcom County may be, in fact, job relocations rather than “new” or “added” streams of employment revenue in the County. An example could be local longshoremen who already live in Whatcom County and commute to other ports for employment. In this case, these residents are already investing their salaries locally, and as such calculations of GPT-related “indirect” employment gains in this case may be overestimated. Other cases of job relocations could exist as well and merit study.

Another GPT benefit to study further is the level of local capital investment during the construction phase. Will train car-unloading machinery, coal-moving machinery, and pier machinery be manufactured here or elsewhere? How does that affect GPT’s estimates on construction investments locally?

In sum, decision-makers need detailed and verified data on the true costs and benefits of GPT. Only with an accurate understanding of GPT’s economic balance sheet for our communities can the permitting agencies weigh GPT’s negative impacts against the potential economic benefits.

Thank you.

Citations:
1. Public Financial Management, Inc., “The Impact of the Development of the Gateway Pacific Terminal on the Whatcom County Economy,” 2012: http://www.communitywisebellingham.org/wp-content/uploads/2012/03/Communitywise-Bellingham-Report-3.6.2012.pdf. Also note an SSA Marine-commissioned review of this report found the net negative impact threshold to be closer to 24%. This review is available here:
http://www.communitywisebellingham.org/ssa-marine-response-to-pfms-economic-impacts-study/

2. CWB, “Gateway Pacific Terminal Impacts on the Bellingham Waterfront,” 2012: http://www.communitywisebellingham.org/cwb-studies-gpt-train-impacts-on-the-waterfront/

3. Gibson Traffic Consultants, “Cherry Point Export Commodity Facility Rail Operations—City of Bellingham,” 2012: http://www.communitywisebellingham.org/gpt-traffic-impacts-on-the-waterfront/

4. Gibson Traffic Consultants, “Cherry Point Export Commodity Facility Rail Operations—City of Bellingham,” 2012: http://www.communitywisebellingham.org/gpt-traffic-impacts-on-the-waterfront/

5. Public Financial Management, Inc., “The Impact of the Development of the Gateway Pacific Terminal on the Whatcom County Economy,” 2012: http://www.communitywisebellingham.org/wp-content/uploads/2012/03/Communitywise-Bellingham-Report-3.6.2012.pdf.

6. Gibson Traffic Consultants, “Cherry Point Export Commodity Facility Rail Operations—City of Bellingham,” 2012: http://www.communitywisebellingham.org/gpt-traffic-impacts-on-the-waterfront/

7. Simons, RA. El Jaouhari, A. “The Effect of Freight Railroad Tracks and Train Activity on Residential Property Values,” The Appraisal Journal, Summer 2004; 223-233.

8. Friends of the San Juans: http://www.sanjuans.org/documents/FSJFinalScopingLetterGPTEIS11820131530.pdf

Communitywise Bellingham (#11631)

Date Submitted: 01/22/2013
Comment:
Please note: This is a text only version of this comment, please see the attached PDF for references, citations, tables and graphs.

In previous scoping comments submitted on October 22, 2012 by Buri Funston and Mumford on behalf of Communitywise Bellingham (CWB), Communitywise requested that the environmental impact statement:

(1) examine the reasonable range of alternatives for increasing rail capacity through Whatcom County, Washington; (2) analyze the effects of building, maintaining and operating a rail siding through Bellingham; (3) identify the significant adverse impacts from this active rail siding on Bellingham’s waterfront businesses, adjacent neighborhoods, community health, shore lands, marine resources, recreation areas, traffic, and emergency response times; (4) identify any measures that might minimize or mitigate the effects of constructing the siding and doubling rail capacity between Bow and Ferndale; and (5) estimate the costs of mitigation and identify who should bear these expenses.

Communitywise Bellingham has been identified by the EIS Agencies as a Key Stakeholder. We have been active in developing research and suggesting process for the last two years. Our focus is local, Whatcom County and Bellingham. This is one in a series of comments on specific aspects of issues.

These supplemental scoping comments are intended to support the requests referenced above and in other CWB submissions. The following information is foundational to understanding why the impacts from all train infrastructures needed to support GPT operations are significant, probable and reasonably foreseeable and should be scoped as part of the GPT’s environmental impact statement. Heavy coal train traffic and its impacts in Whatcom County are not inevitable; they would be a direct result of GPT’s construction.

Therefore Communitywise suggests that:

1. The impacts of coal train traffic along the rail corridor should be included as part of the GPT’s Environmental Impact Study.
2. The active siding along Bellingham’s waterfront should be included in the project permit itself, as it is required to service GPT daily operations.
3. The significant costs of GPT train-related mitigation should not be left to the local taxpayers by default, but rather covered by the project sponsors as part of the true cost of doing business.

Infrastructure to Increase Rail Capacity on the Bellingham Subdivision Line Will be a Direct Result of GPT Rail Traffic:

Communitywise asserts that the development of the GPT project will bring about an immediate and real need for additional for supporting project infrastructure, such as the South Bellingham Rail Siding . As proposed, the Gateway Terminal will overwhelm the current capacity for rail traffic between Bow and the Custer Spur, even during Phase 1 operations at the terminal. GPT plans 18 daily trains (half incoming, half outgoing) to ship 54 million metric tons at full build out. That converts into 59.5 US tons, the measure used in government reports. In 2010, the combined grand total tonnage of all railroad freight to both the states of Washington and Oregon, including local consumption and export, was 80 million tons. The proportion to the State of Washington was 57 million tons. That means GPT by itself will more than double total rail freight tonnage in the state of Washington.

Under WCC 20.88.130(5), the essential rail facilities do not currently exist for the proposed Gateway project. It is undisputed that the developer must at least double the capacity of the current rail line to make the terminal operational. Thus while project developers may assert that such infrastructure may be required in the indeterminate future for yet to be established needs, the GPT project itself brings the need for such vital structures to the very real and immediate present.

To date, the project applicant and BNSF have not documented their plans to alleviate the well documented Bow to Ferndale rail chokepoint that will inhibit daily terminal operations. Rather, they continue to assert that such disclosure is unnecessary as future events, unrelated to GPT, may manifest that would require similar capacity solutions. Most frequently, terminal proponents suggest that if not developed, Whatcom County will suffer the ill effects of high volume coal train traffic as Powder River Basin (PRB) coal is routed to B.C. terminals for export.

The claim that Whatcom County will be exposed to the same high volumes of coal train traffic regardless of GPT development demands a thorough analysis and full understanding. The argument follows that without GPT, local residents still incur the potential negative aspects of increased train traffic without deriving any potential benefits. If the claim were true, then those building and financially benefiting from GPT can make the case that they are not responsible for increases in train traffic within Whatcom County or along the rail corridor north of Chehalis. Their logic then eliminates a rationale for including train impacts on Bellingham (or anywhere off-site) in the Environmental Impact Study.

Communitywise submits that the significant, unavoidable and immediately foreseeable train impacts imposed on Bellingham and Whatcom County from the proposed project are real and directly attributable to the development of the Terminal. It follows that all train impacts should be scoped as part of the GPT’s EIS process. Furthermore, Communitywise asserts that Whatcom County will not be subjected to high volume coal train traffic as a detailed analysis of the current and future capacity of BC export facilities reveals that little capacity exists for US coal exports.

If the GPT Terminal is Not Developed, Whatcom County Will Not Experience High Volumes of Coal Train Traffic.

If one accepts that the trains “are coming anyway,” then the impacts of 18 additional GPT trains identified in the revised PID are not attributable to GPT. Bellingham would organically experience the equivalent of GPT train impact “anyway.” The public policy implication is clear: it removes train impacts on Bellingham, Whatcom County and other affected local municipalities as a responsibility of the project developers. Under the claim, these train impacts are an inevitable course of events, with or without GPT, and should be excluded from analysis during the EIS process.

In-depth research and analysis of coal contracts in B.C. indicate that only a minor fraction of the proposed PRB coal exports for the Pacific Northwest could go through B.C. ports, even after completion of planned terminal expansions in the region. A close look at the committed long-term contracts and expected future contracts for export capacity at the existing B.C. terminals shows that nearly all of the capacity has been secured by Canadian coal interests. Capacity for U.S. coal exports will be severely limited as our research reveals that Ridley and Neptune terminals are not viable options for U.S. exports. This leaves only the unsecured capacity at Westshore for new PRB or other U.S. coal exports.

Beginning in 2015, there will be a maximum of 4 to 6 Mtpa of “excess” capacity for coal exports, all through Westshore Terminal (see Table 1). This amount, in addition to U.S. coal exporter Cloud Peak’s 4 Mtpa existing secured contract through Westshore, could bring the maximum level U.S. coal exports going on rail through Washington to B.C. ports up to 8 to 10 Mtpa (see Graph 1). This is a fifth of the proposed GPT coal export volume and just 10 percent of the total proposed Pacific Northwest export capacity for PRB coal considering all five current coal terminal proposals.

If the maximum 8 to 10 Mtpa of capacity at Westshore were allocated for PRB coal exports (existing secured Cloud Peak contract plus all unsecured “excess” capacity), between 490 and 730 additional trains would travel though Whatcom County each year. This equates to a total of approximately 3 to 4 coal trains per day through Whatcom County en-route to B.C, a level on par with the record traffic volumes experienced in Whatcom County in 2011. It is equally possible that none of the available export capacity at British Columbia’s terminals will be contracted to U.S. mining interests. Canadian coal companies have had the edge in securing planned expansions in Canadian export capacity, and that trend that may continue.

It should be noted that new, presently unconstructed, export capacity could be developed in British Columbia. Port Metro Vancouver is currently reviewing a project permit application submitted by Fraser Surrey Docks (FSD) for the development of a Direct Transfer Coal Facility. If approved, up to 8 additional Mtpa of PRB coal could potentially be exported. The FSD proposal, if approved and permitted, could mean an incremental 3 coal trains per day bring the maximum foreseeable volumes of coal train traffic to approximately 6-7 trains per day; levels still far below those expected from GPT operations.

If GPT is not built, moderate to no additional coal train traffic will come through Whatcom County to Canada. Post expansion, existing B.C. coal terminals will not have significant additional capacity for U.S. exports as nearly all of the present and future export capacity has been secured through long-term contracts to Canadian mining interests. This conclusion is corroborated by a recent coal industry analysis (Arch Coal SEC filing, February 2012).

It is important to note that when an accurate accounting of limited B.C. capacity for additional U.S. coal exports is considered, the policy implications change. Heavy coal train traffic and its impacts in Whatcom County are not inevitable; they would be a direct result of GPT’s construction. This direct impact suggests that:

• The impacts of coal train traffic along the rail corridor should be included as part of the GPT’s Environmental Impact Study.
• The active siding along Bellingham’s waterfront should be included in the project permit itself, as it is required to service GPT.
• The significant costs of GPT train-related mitigation should not be left to the local taxpayers by default, but rather covered by the project sponsors as part of the true cost of doing business.
Attached Files:

Communitywise Bellingham (#11650)

Date Submitted: 01/22/2013
Location: Bellingham, WA
Comment:
Request to Evaluate Reducing Harmful Emissions

Note: Full citations included in the emailed submission and available here:
http://www.communitywisebellingham.org/submited-cwb-comments-on-the-gpt-environmental-impact-statement/

Communitywise Bellingham has been identified by the EIS Agencies as a Key Stakeholder. We have been active in developing research and suggesting process for the last two years. Our focus is local, Whatcom County and Bellingham. This is one in a series of comments on specific aspects of issues.

Many of the submitted comments by concerned citizens and members of the professional healthcare community, including the Whatcom Docs coalition, have noted in their comments that diesel particulate matter is associated with:

• impaired pulmonary development in adolescents;
• increased cardiopulmonary mortality and all-cause mortality;
• measurable pulmonary inflammation;
• increased severity and frequency of asthma attacks, ER visits, and hospital admissions in children;
• increased rates of myocardial infarction (heart attack) in adults;
• increased risk of cancer.

These citizens have asked to co-lead agencies to evaluate these risks as part of the GPT’s environmental impact statement. Communitywise Bellingham echoes these concerns.

Furthermore, we assert that given the GPT train route passes entirely through residential, recreational and business areas of Bellingham, we believe it is vitally important to study the differential pollution impacts of Tier 4 locomotive emissions versus prior emission standards. The differential impacts of Tier 4 emission standards may be even more profound on the Bellingham population given that a second active rail siding is likely to be constructed in the center of Bellingham, subjecting large numbers of residents to significant additional emissions from the trains idling on the siding area.

Communitywise respectfully requests the co-lead agencies to determine if requiring Tier 4 locomotives to service the GPT would significantly decrease health risks as part of the environmental impact statement or any health impact analysis.

Tier 4 Locomotives
Coal unit trains are the heaviest in the industry routinely using 4-6 locomotives depending on length and grade factors. The 2004 Tier 4 standards for diesel locomotives enforce similar standards on locomotives as those which other industries (and individual car owners) have been subjected to for decades. The standards represent about a 90% reduction in the release of health hazard particulate and NOx.
Tier 4 technology is available today. The GPT post-permit issuance construction schedule suggests that trains could start as early as late-2017, almost 3 years after the Tier 4 standard has been required on new and rebuilt locomotives. The dirtier engines, however, are grandfathered in until they need to be rebuilt which could be a long time. SSA representatives have publicly stated that they intend to use Tier 3 engines.

It should be noted that locomotives prior to Tier 4 do not have similar active control components and so are not subject to objective testing. This means that emission rates are unlikely to be the “at time of manufacture” ideals which quickly become degraded without a high standard of aggressive maintenance practices. Figures 1 and 2 include recent photographs of a typical coal unit train leaving the Bow siding on its way to Bellingham (the power units at both ends). We believe such an evaluation is well suited for application to other cities given the large number of densely populated areas through which the trains will pass.

RR Locomotive Pollution Controls
Class 1 railroads lost their hard fought protection from standard pollution controls in 2004 and became subject to EPA Tier 4 standards. The simple math of avoiding regulation for years while every other source in the country cleaned up eventually made locomotive emissions such a huge nonpoint contributor to pollution that even congressional allies could no longer defend exemption. The RR lobby was able to hold off implementation for an additional 10 years. Tier 4 controls include active components similar to those individual car owners have paid for on their personal vehicles for decades. This description is from a diesel industry reference site:

"On May 11, 2004, the EPA signed the final rule introducing Tier 4 emission standards, which are to be phased-in over the period of 2008-2015 [69 FR 38957-39273, 29 Jun 2004]. The Tier 4 standards require that emissions of PM and NOx be further reduced by about 90%. Such emission reductions can be achieved through the use of control technologies—including advanced exhaust gas aftertreatment ..."

Tier 4 is available today
The reluctance Class 1 railroads have always had to spending anything they are not forced into is widely recognized. There is no indication that any of them will ramp up the required transition before the end of 2014. This is a matter of choice. The Houston Port Authority, a public agency, knows it has a bad diesel pollution problem and rather than waiting until 2015 has contracted to rebuild its fleet of locomotives (and tugs) to Tier 4 standards starting this year - 2013.

We request that the EIS agencies follow the Houston Port Authority’s lead and identify a process to require that only Tier 4 locomotives service GPT in the event the terminal is built.

Thank you.

Communitywise Bellingham (#11654)

Date Submitted: 01/22/2013
Comment:
Please note: This is a text only version of this comment. For full references, citations, figures and graphs please see the attached PDF.

GPT/BNSF Custer Spur EIS Co-Lead Agencies
January 19, 2013

Communitywise Bellingham (CWB) has been identified by the EIS Agencies as a Key Stakeholder. We have been active in developing research and suggesting process for the last two years. Our focus is local, Whatcom County and Bellingham. This is one in a series of comments on specific aspects of issues.

The Big Picture: Railroad Traffic & Infrastructure – Powder River Basin Coal:

CWB has requested in other comments that the GPT EIS study several Bellingham and Whatcom County issues related to the significant, probable and foreseeable impacts of GPT train traffic in general and coal trains in particular. In this comment we broaden from what we have learned about local impacts to what we have discovered about radical regional shifts that are the driving force behind GPT and other terminal projects. We believe this brief big picture review argues strongly in support of cumulative impact approaches and supports requests for a PEIS.

Many of the impacts in Whatcom County and Bellingham are huge and directly challenge continued progress on existing decades long planning and investment decisions. GPT will, after a very short construction period, more than double railroad traffic through Bellingham from a level that took 40-50 years to evolve. The single biggest challenge to minimizing economic damage to the community is that truly comprehensive mitigation will not only be extraordinarily expensive, but to be effective it will also have to be undertaken in a same similar time period to avoid risk of a downward economic spiral with diminishing property values and population net-out migration diminishing tax base. We expect that study will show similar challenges to many other communities.

This overview of PRB coal and RR Infrastructure focuses on the underlying realities and the magnitude of regional impacts that we have discovered simply to ship coal to the Gateway Pacific Terminal planned at Cherry Point. We have found that the extraordinary dimensions of even this single operation are not well understood, likely because they are so unimaginable without having been involved in research. Keep in mind in considering the need for cumulative impact studies or a full PEIS that the several other terminal proposals in the works potentially triple the amount of coal and railroad traffic that is being discussed here.

A single fact from the overview discussion that follows may serve best to illustrate the true scale of the regional issues and why they have compelled so many to request a PEIS. We are speaking here solely of the total freight tonnage for GPT at build out. The rail freight tonnage delivered to GPT alone will be larger than the total rail freight tonnage currently delivered everywhere in the state of Washington (including all local destined and trans-shipped exports from our ports). State studies indicate that the freight rail system is already congested so more than doubling rail freight tonnage is likely to present major challenges. That other terminals could triple this tonnage would serve to magnify those challenges.

PRB Coal – While the relative “cleanliness” of Powder River Basin (PRB) coal is prominently mentioned as a rationale for its use in power generation, coal industry researchers believe that PRB coal has several drawbacks and the primary market driver is low cost . Given contemporary greenhouse gas concerns, the drawbacks identified by industry researchers are highly relevant. The fact that PRB coal is a low btu coal means that more has to be burned to produce the same amount of energy. The fact that PRB coal has high ash content creates a bigger waste disposal problem for the toxic fly ash. Economics 101 tells us that as long as the price of PRB coal can be kept low, be it through subsidy or externalizing related costs, it will distort markets by encouraging its continued use.

The reason for the low cost of PRB coal has been a history of past federal and state legislative and administrative decisions that, in the aggregate, have meant a cheap subsidized coal. The underlying policy rationale for these decades old developments was that cheap coal would fuel US manufacturing and job growth through the promotion of coal fired electrical plants. Figure 1 shows the geographic distribution of power plants using PRB coal. This is both a measure of how successful that policy was and a very clear illustration that PRB coal does not head West (a single plant each in WA and OR, both destined for closure). Figure 2 is an even more dramatic illustration of associated coal freight traffic. It shows the geographic distribution of annual rail freight tonnage for Class 1 railroads in red (where thicker lines represent larger volumes). This is ALL freight, not just coal. Even so it is hard to miss the most prominent feature on the map, a huge red swath originating in the Powder River Basin heading both East and South. There is no similar volume of railroad traffic of any kind anywhere else in the United States. It is again heading everywhere but West.

The policy reasons for these coal subsidies are long gone (as are many of the manufacturing plants originally helped by this cheap power). The subsidies are still present. This is often is the case when temporary stimulus measures have no sunset clause and get extended indefinitely through the effective lobbying of benefiting parties. The domestic demand for PRB coal is disappearing rapidly as US power companies increasingly convert to cleaner energy sources, primarily natural gas.

There are competing economies in the world with less concern about pollution and burning coal. For them access to cheap subsidized energy remains an attractive alternative for fueling their own manufacturing and job growth. This is the fundamental dynamic driving Gateway Pacific Terminal (GPT) and the several other projects in the Pacific Northwest. PRB coal, too dirty for domestic markets, is turning upwind to Asia.
Railroad Infrastructure – Figures 1 and 2 do paint a very dramatic picture of the volume of PRB coal flowing East and South but they do relatively little toward understanding the fundamentally radical changes to infrastructure that will be required to reroute that coal heading West. A very basic problem is that while mining in PRB and the RR traffic out built up over decades, the current swing towards Asian markets is a veritable “all hands on deck” rush, a fast sprint West which will not provide the many years for communities to slowly adapt like communities affected in the original development of PRB. Note sheer volume has caused many routes taken by coal out of PRB to be built up to 3 or more parallel mainlines. Even so, these routes are so congested with slow coal trains that it is impossible to schedule time sensitive intermodal traffic on those corridors. The route West from PRB, by comparison, remains a single mainline system which is totally inadequate to handle a similar volume. The rapid building of terminals will require massive RR infrastructure changes and leave communities across several states without the long time frames to plan and develop fiscal means for mitigating major impacts.

GPT plans 18 daily trains (half arriving loaded, half leaving unloaded) to ship 54 million metric tons at build out . The metric tons convert into 59.5 US tons, the measure used in US government reports. In 2010 the combined grand total tonnage of all railroad freight to both the states of Washington and Oregon, including local consumption and export, was 80 million tons. The proportion to the state of Washington, because of the major Seattle-Tacoma shipping terminals, was 57 million tons. That means GPT by itself will more than double total rail freight tonnage in the state of Washington. This while the state has documented that it already has serious capacity problems . Except for the research CWB has assembled or commissioned concerning Whatcom County and Bellingham, almost nothing is known of what infrastructure will be built for additional capacity or what its likely impacts will be. The only thing certain is that they will be big.

In Whatcom County multiple studies over the last 20 years have documented the Bow to Ferndale bottleneck through Bellingham with a practical capacity for 14-15 trains. There is evidence that the practical capacity of this corridor is actually significantly lower than for coal trains which, as the heaviest trains in operation, have separate maximum speed rules and lower performance on grades than other freight traffic. In particular CWB timed a coal train on the Bow to Ferndale segment of the mainline at 54 minutes. This is 12% longer than the 48 minute freight passage time that has been assumed for all capacity studies to date meaning there will be significantly less capacity given the planned 16 coal trains per day.

This mainline corridor currently runs at or near capacity as it has cyclically for the past decade. GPT needs 18 trains for its operation alone but there is no capacity. Existing studies indicate running a siding along the Bellingham waterfront - drastically isolating business, park, and redevelopment areas - will nearly double the capacity, but even that falls short. It is not yet known what infrastructure will be built or what its impacts will be . Similar cases may exist throughout the railroad system.
Attached Files:

Communitywise Bellingham (#11668)

Date Submitted: 01/22/2013
Comment:
Please note: This is a text only version of this comment. For full references, citations, figures and graphs please see the attached PDF.

GPT/BNSF Custer Spur EIS Co-Lead Agencies
January 19, 2013

Communitywise Bellingham (CWB) has been identified by the EIS Agencies as a Key Stakeholder. We have been active in developing research and suggesting process for the last two years. Our focus is local, Whatcom County and Bellingham. This is one in a series of comments on specific aspects of issues.

Unresolved railroad capacity issue could introduce unnecessary and major delays into the EIS process:

In the interest of avoiding delays to the EIS process we would like to highlight an unresolved issue that, if not dealt with in a timely fashion, could cause serious delays downstream. It is a fundamental issue specific to Whatcom County Code that defines requirements for a Major Project permit. This particular issue has been under discussion for some time. This is a fundamental responsibility of the project applicant. Importantly, Whatcom County has indicated that they share concern about the issue with the City of Bellingham. In their letter, the County indicated that they had insufficient time and expertise to deal with the capacity issue expeditiously. They indicated an understandable pragmatic decision to defer the required analysis until the expertise of EIS consultants became available to assist in review.

That is how things stand today. Analysis of the capacity issue has been delayed, yet the requirements of the code stand. Until this one specific railroad capacity issue is resolved, completeness of the permit remains in question. If the permit does not contain all required infrastructure plans in Whatcom County, the EIS remains in question. If additional infrastructure plans are required to complete the permit, additional time is likely required to submit them. Any plans that are added to the permit will require additional comments. All of this takes time. This is clearly an issue best addressed sooner than later.

CWB believes that the lack of capacity on the Bow to Ferndale segment has been documented beyond any reasonable doubt and that a simple review of the facts by the EIS Consultants will establish the need for additional capacity. This would allow the County to move forward in a timely manner hopefully keeping the process on track and avoiding more delays.

Should the consultants desire to look further, there is a ready avenue to confirm the facts and shed light on another potential issues - the impact on passenger rail. Whatcom Council of Governments (WCOG) rail studies from the summer of 2011 included relevant capacity simulations conducted by Wilbur Smith Associates in concert with BNSF. These studies included 4 different configurations of infrastructure which demonstrated, using BNSF peak train data from October 2010, that significant additional passenger service could be accomplished without the need for major siding improvements on the Samish Bay and Bellingham waterfronts (we note in particular simulation 3). The study also indicates that both the researchers and BNSF considered the results would not be attainable were GPT built. By reviewing those simulations and by re-running the simulations with the addition of the full build out GPT train traffic, answers could be determined for two important questions - whether capacity for GPT exists without additional infrastructure and what potential impact the traffic may have on existing or future planned passenger service.

CWB is likely not alone is sensing that there are many process participants who may ultimately be willing to challenge acts or decisions of the developers and the Agencies should they see reasonable cause. Answering this important question and insuring the County Permit and therefore the EIS process itself is complete, timely and lawful would seem to be a prudent course of action.
Attached Files:

Communitywise Bellingham (#11947)

Date Submitted: 01/22/2013
Comment:
Please note: This comment is contains text only, please see the attached PDF for full references, citations, charts and figures.

GPT/BNSF Custer Spur EIS Co-Lead Agencies
January 19, 2013

Communitywise Bellingham (CWB) has been identified by the EIS Agencies as a Key Stakeholder. We have been active in developing research and suggesting process for the last two years. Our focus is local, Whatcom County and Bellingham. This is one in a series of comments on specific aspects of issues.

Whatcom County Railroad Impacts – Fundamental Baseline Assumptions

Significant foreseeable impacts of GPT include well-documented railroad traffic and infrastructure issues for Bellingham and Whatcom County. CWB, the City of Bellingham, and others have submitted specific comments. For any study of those many issues to be meaningful, it is essential to have an objective and fact based view of the baseline situation prior to the current PRB coal push and GPT proposal. This is a fundamental requirement. This comment addresses assumptions.

CWB requests that the GPT EIS be based on and include a fact-based and objective assessment of the baseline railroad and coal shipping conditions. Faulty assumptions will produce faulty conclusion. Note that while these baseline assumptions are focused on Whatcom County, they are relevant to conditions for other communities statewide.

Emphasis on baseline assumptions has been a high priority for project proponents. They have put forward specific and widely accepted claims regarding railroad traffic in Whatcom County. It is of little surprise their set of claims, if assumed true, would pre-determine that GPT railroad traffic cannot possibly be responsible for any impacts.

Those claims identify important factors that need to be evaluated. They include: (1) coal trains have always been running through Bellingham without any notice or complaint (until organized efforts by project opponents created unfair attention); (2) the volume of train traffic with GPT will be no different than Bellingham has experienced in the recent past such as when Georgia Pacific was operating or when lumber was coming from Canada; and, (3) the trains "are coming anyway" and will simply go through to Canada if not to GPT.

The facts concerning these claims are well documented and in each case they show the claim to be false.

Claim 1: Coal Trains have always been running through Bellingham

This claim is patently false. Government data show the PRB coal trains began building up in 2009, at the same time as SSA was working hard with state and local officials as well as regulators on this project. In 2010 the GPT project became visible as a huge coal terminal that was part of the general PRB “coal rush” rather than the small bulk commodity terminal everyone had assumed. It is interesting to note that in our supposed “coal train past” none of the long sidings and heavy rail that are required for coal unit trains were in place.

The following chart shows Seattle customs district data - all exports of coal to Canada through Whatcom County. It includes the coal export data available online, from 1995 through the 2nd quarter of 2012 (the same data in tabular form is included at the end of the document).

A visual inspection of this unambiguous data reveals the facts. It shows this first claim to be false. Regular coal train traffic through Bellingham is a very recent development. Regular coal traffic has definitely not “always been passing though”. Even the minor quantity bumps that show in the mid 90’s are overstated because not all coal came through Bellingham. Seattle Customs data includes coal that was exported through Sumas in those years when the inland route was more active.

During the 10 years preceding the mid-2009 arrival of PRB coal unit trains, the full year average for coal through Whatcom County was 9,128 tons. It is interesting to note that what passed through during an entire year in those past years would only fill half of a single 150 car unit train planned for GPT (the daily traffic through Bellingham would be 16 of those, 8 of them full, plus one round trip of some other long bulk commodity train). To put it in numbers, GPT plans daily coal freight through Bellingham that is 16 times as great as past full year tonnage.

Coal trains have not “always been passing” through Bellingham. It is recent and it is our observation that once they appeared, they were very much noticed by the community.

Claim 2: Bellingham Train Traffic will be no different than in the past

As documented in recent train studies by Whatcom Council of Governments, Bellingham train traffic was actually lower in the last years of Georgia Pacific operations than during other cyclical peaks including the Canadian lumber boom. One reason the lumber train narrative has resonated is a ready local memory of many cars loaded with Canadian lumber sitting on sidings along the Roeder waterfront and on the South Bellingham siding. While this image is easy to recall it does not actually speak to the volume of through train traffic. Bellingham just happens to be a convenient yard for lumber that has passed through border customs. Those lumber cars were waiting to be dispatched on trains bound for delivery to many destinations during the US housing market boom.
The lumber boom was, in fact, a period of peak traffic. The cross border traffic component and the driving market conditions are discussed in the recent WCOG freight study “Freight rail traffic increased significantly from 2004 to 2006, supported by the removal of tariffs on lumber from Canada and unprecedented housing starts in the United States. … By 2007, train volumes had again slowed to the 2002 levels … With the closures and consolidations in Canada of the lumber industry, these volumes are unlikely to be seen in the future.”

The lumber boom created one of the cyclical 12-14 trains per day peaks of base train traffic through Bellingham. BNSF and SSA have indicated that with the addition of the recent PRB coal traffic (replacing some of the reductions due to the 2007 economic slowdown) we are at similar levels today. As has been documented elsewhere, those peaks are at or near the 14-15 trains per day capacity of the Bow to Ferndale corridor through Bellingham and there is reason to believe that previous studies overstated capacity where it involves coal trains.

Adding GPT’s planned daily base load of 18 trains per day per day to the existing 12-14 per day results in 30-32 trains per day. This is more than twice as many daily trains than Bellingham has ever experienced, there is not even the capacity to handle them, and the GPT trains will be significantly longer than any ever experienced in the past.

Train traffic like this has never been seen in the past.

Claim 3: The Trains are coming anyway

Despite its widespread acceptance, absolutely no analysis has ever been produced to substantiate the claim. All known facts lead to a contrary conclusion. Analysis of this claim can be found in many places including our own analysis (found here) and recently supplemented by our comment (found here). We also note a relevant Sightline discussion (found here), and a paper at Coal Train Facts (found here).

This is nothing more than speculation. More importantly, even if it had any factual basis - which it does not, it is not relevant to the EIS. What the EIS has to address is foreseeable impacts from actual planned traffic that will be generated by the project.

Given the speculation that somehow, under some unknown set of conditions, huge coal traffic to Canada may materialize - it is just as reasonable (or unreasonable) to argue that since this same traffic to Canada will happen “anyway” that it should be added to the GPT train traffic for the EIS analysis. Neither argument has any merit. This claim has no role in this EIS.
Attached Files:

Communitywise Bellingham (#12073)

Date Submitted: 01/22/2013
Location: Bellingham, WA
Comment:
Request for the Study of Coal Storage and Transport: Uncertainty Around Fugitive Dust and Toxic Leachates Needs to be Addressed.

Note: Full citations included in emailed submission and available at:
http://www.communitywisebellingham.org/submited-cwb-comments-on-the-gpt-environmental-impact-statement/

Communitywise Bellingham (CWB) has been identified by the EIS Agencies as a Key Stakeholder. We have been active in developing research and suggesting process for the last two years. Our focus is local, Whatcom County and Bellingham. This is one in a series of comments on specific aspects of issues.

In our investigations, CWB has found no area with so many isolated indications of potential problems and so little comprehensive study than fugitive dust and leachates. The discussion below is meant to introduce the broad range of related issues.

Communitywise respectfully requests that the co-lead agencies examine all aspects of coal dust and leachates including their toxicology as well as containment management strategies for the full cycle of storage and transport. Among the areas that various studies should examine are:
• Coal dust control during rail transport and unloading including enclosed or lidded cars;
• Coal dust from storage piles and conveyer systems including full negative pressure containment;
• Coal dust generated while loading ship holds including fully sealed, negative pressure containment;
• Coal leachates from loaded coal gondolas with surfactants applied—toxicology and volume;
• The mapping of sensitive wetlands, waters, and grasslands over or along which leachates will be drained;
• Coal storage leachates at Cherry Point in regard to groundwater intrusion as well as the closed spray system;
• Possibility of directing both regular and hydraulic overload wastewater into a separate watershed from CPAR;
• Existence of any GPT-size coal terminal anywhere in the world that does not have these problems;
• Measures to ensure system risks are borne by applicants and not by any third parties or the general public.

We also request that The GPT EIS identify the coal dust management systems with the highest level of environmental performance and determine its level of relative protection against fugitive coal dust for the CPAR and adjacent areas.

We also ask for a study to examine SSA Marine’s proposition that they can achieve a zero coal dust problem for the terminal site. This should include the development of an enforceable means that ensures that any risks are assumed by the developers and not the public at large. A fundamental component of such a mechanism, given the fragility of the nearby environments, would be a monitoring regime that totally shut down operations at the first sign of fugitive dust or leachates and kept the operation shut down until they were analyzed and repaired to the satisfaction of an independent agency.

Discussion
CWB has found that not only are there a wide variety of issues that have not been adequately studied, but there are also different corporate sensitivities about what control strategies are brought to bear on the problems. For example, the plans submitted for the Ambre Energy project on the Columbia River proposes a much higher level of focus on containment strategies than GPT. Their terminal operations are to be carried out in a negative pressure environment. This includes multiple, totally enclosed coal pile storage areas, ALL conveyer systems, and even their own water loading facilities with the goal of preventing the escape of fugitive coal dust. We do not have the expertise to know how well that process will work or hold up under normal use and maintenance, but it is hard not to see it as a higher level of commitment to environmental controls than GPT.

Plans submitted for GPT have none of these features. Their plans follow in the main what many consider failed industry-wide control strategies like those at Westshore Terminals in Canada. It seems intuitively obvious that the Ambre approach has greater chance of success. Some features of the GPT plans could actually worsen typical coal dust problems. Examples are the higher volume coal loading snouts and the partial enclosure of coal piles could actually worsen typical coal dust problems. The GPT EIS should therefore identify the systems with the highest level of environmental performance and determine its level of relative protection against fugitive coal dust for the CPAR and adjacent areas.

Coal is a toxic substance and the many effects of wind borne fugitive dust and water borne leachates from coal storage piles have long been observed. Coal storage piles exist in many different environments from mines to shipping terminals to power plants. They are stored adjacent to salt water, fresh water (streams or lakes), wetlands and dry land environments. In some fresh water instances, select aquatic plants grow bloom while others die; in others the abrasive effect of dust particles damages aquatic plants. Cautionary signs concerning potential consequences of wind and water borne coal byproducts abound. Photographs of the barren landscapes where coal transport or storage has been present for decades document the importance of these issues. No attention has been given in GPT plans to the toxic leachates from storage piles at Cherry Point nor the 136-acre feet of coal in each open-top train exposed to the heavy rains of the Pacific Northwest.

We are aware, however, that there is no proven technology at any coal terminal of this scale anywhere in the world. We understand that the proponents claim this can be done, and they are the ones that can do it (even if their control proposals seem to fall far short of others).

The proponents say they are willing to bet that they can have a zero coal dust problem solution. Then, if the permit is to be issued, it needs to be conditioned on the developers assuming the full risks of the bet they are willing to take. Nobody wants an "ah well, there used to be a good Salish Sea fishery" moment sometime in the future.

That is why we ask for a study to examine this proposition and develop an enforceable means that ensures that any risks (be it they are simply wrong or that controls deteriorate in effectiveness over time) are assumed by the developers and not the public at large. A fundamental component of such a mechanism, given the fragility of the nearby environments, would be a monitoring regime that totally shut down operations at the first sign of fugitive dust or leachates and kept the operation shut down until they were analyzed and repaired to the satisfaction of an independent agency.

Another important component would be to establish a bonding or other mechanism to hold the financial entities behind this project fiscally responsible for any damages so that they cannot shift the burden of risk onto the taxpayer by the use of limited liability subsidiaries.

Coal Train Transport
The one industry study we located on fugitive dust from coal trains may be the basis of industry claims that "most" fugitive dust comes off in the early part of the trip. It is a small study that does not include adverse environments like high winds, but it does establish a few important factors to guide future study. First is the obvious corollary to the fact that "most" coal dust escapes early which means "some" coal dust continues to escape. The study also identified factors which most affect that further escape: (1) acceleration and deceleration; and (2) passing trains on adjacent tracks. This is important because the 1,100+ mile rail corridor from PRB to Cherry Point is a single-line mainline. This is very unlike the major 3- and 4-track mainline corridors the coal now takes to power plants in the East and South. With a single line mainline there are closely spaced sidings to handle traffic with a 24/7 orchestrated stopping, starting and passing regime—the worst case for fugitive coal dust.

There has been no rigorous independent study of the techniques that the industry now presents as "having solved the dust problem." The shaping the tops of coal car loads and then spraying it with one of several surfactants has reduced problems near the mines, but the misshaped tops of many cars that pass through Bellingham clearly indicate shifting loads. GPT plans to transport 53 million shorts tons a year through Bellingham - about the same tonnage of rail freight that now goes to the entire State of Washington (including container export terminals). Plans for allowing that capacity to pass through Bellingham involve one or more additional sidings here.

Any Bellingham sidings as well as the required Samish siding extension will routinely store open-topped coal trains with leachates draining directly through the ballast and rip rap into the Salish Sea. The same Salish Sea situation exists for much of the route South of Seattle and then for rivers, lakes, wetlands and other sensitive areas as the route heads back east up the Columbia from Vancouver WA.

Thank you.

David Raskin (Friends of Alaska National Wildlife Refuges and FRIENDS of the San Juans) (#12184)

Date Submitted: 01/21/13
Location: Homer, AK
Comment:
Dear Mr. Perry, Ms. Summerhays and Mr. Schroeder:

Please accept the attached Scoping Comments for GPT/BNSF Custer Spur EIS for the record.

David C. Raskin, Ph.D.
Past President and Advocacy Chair
Friends of Alaska National Wildlife Refuges
Attached Files:

Diane Narasaki (#9125)

Date Submitted: 01/18/2013
Location: Seattle, WA
Comment:
The Asian Counseling & Referral Service and International Community Health Services request that the EIS scope for Coal Train include health and environmental impact assessment for the Seattle Chinatown International District neighborhood. See attached letter.
Attached Files:

Don Robinson (#1857)

Date Submitted: 10/24/12
Location: Bellingham, WA
Comment:
Attached is a letter from the Building Industry Association of Whatcom County regarding the EIS “scoping” process for Gateway Pacific Terminal.

Please accept this testimony into the written record.


Thank you,

Linda Twitchell
Attached Files:

Doug Chin (#10042)

Date Submitted: 01/20/2013
Location: Seattle, WA
Comment:
Dear NEPA and SEPA Team Reviewers,
We at the Organization of Chinese Americans Seattle Chapter strongly recommend that a Section 106 historic buildings impact review be included in the EIS scope given the likely negative impact of having 18 coal trains run through the Chinatown International District (CID) in Seattle. It is anticipated that the increased pollution to the poorest air quality in Seattle would exacerbate air pollution and the attendant acid rain that would degrade the historic buildings and structures in the CID, a designated historic neighborhood.
Sincerely,
Doug Chin
President, OCA Seattle Chapter
Attached Files:

Dvija Michael Bertish( Rosemere Neighborhood Association) (#12191)

Date Submitted: 01/21/13
Location: Vancouver , WA
Comment:
From: Rosemere Neighborhood Association
Box 61471
Vancouver WA 98666


Rosemere Neighborhood Association is a non-profit environmental organization based in Vancouver WA. Our members live and work in the greater Vancouver area. Rosemere is opposed to the establishment of various international coal export terminals proposed to be located in the pacific northwest, including the Gateway Pacific Terminal.

Rosemere requests a programmatic Environmental Impact Statement that will study the cumulative regional impacts along all railway corridors that are proposed to carry extensive coal shipments in the region for international transport. A programmatic regional review is needed to determine the potential adverse impacts to the environment, human health, and economic impacts throughout the region due to increased coal traffic. Each coal train (and each train car) should be classified as a point source of pollution due to the fact that coal trains are uncovered and shed hundreds of pounds of coal dust with each and every shipment. Railway corridors should be considered spill hazard zones.

Federal and state review is needed to determine how increased coal transport will affect marine life and the water column with increased exposure to coal toxins during transport, including the risks of intensified ocean acidification due to increased carbon-based emissions with increased coal use throughout Asia and the ensuing airborne toxins released from coal fired power plants.

Review is also needed to determine the impacts from construction and expansion of vast coal export terminals on shorelines, including the study of migrating coal dust throughout the region and its impact on waterways, ecosystems, and vegetation. It is vitally important to study the impacts that will occur to west coast fisheries at a time of severely weakened fish stocks and shellfish populations.

Review is further needed to determine human health impacts from vastly increased emissions caused by coal fired power plants, their impacts on the airstream, the impacts of acid rain associated with this industry, and the impacts caused by toxic exposure to increased levels of coal dust along the transport corridors. This review should include all economic impacts where the public is required to subsidize the infrastructure to support coal industry expansion throughout the pacific northwest.

Studies are also needed to understand how coal harvesting practices will impact human health and the environment where the coal is mined, the impacts to rivers, streams, groundwater and wildlife, and how those impacts might migrate westward as the industry expands.

It is Rosemere's position that the true impacts from regional coal export terminals cannot be fully understood unless they are studied collectively from the mining source all the way to the receiving ports in Asia. It is also Rosemere's position that the operation of these various coal export facilities will permanently and adversely impact the livability of the entire pacific northwest region, and the permits for all these proposed facilities should be withheld to prevent harm to our persons, our homes, and the environment. The small number of jobs created by this proposed expansion of the coal industry in our region cannot offset the irreparable harm that will be caused, and therefore, these projects should be disallowed.

Submitted by Dvija Michael Bertish, Director of Environment and Conservation, Rosemere Neighborhood Association

Edgemoor Neighborhood Association (#8410)

Date Submitted: 01/17/2013
Location: Bellingham, WA
Comment:
Our Association, The Edgemoor Neighborhood Association (ENA), encompasses some 900 homes in Bellingham, Washington and was formed in July 2004 to provide a structure for neighbors to come together to talk about common concerns and issues. Our neighborhood is located in the southwest quadrant of the City, along the waterfront and the BNSF mainline, and adjacent to the commercial district of Fairhaven.

The ENA is not taking a position on the Gateway Pacific Terminal, but believes it has a responsibility to provide information specifically related to the neighborhood. We are asking for clarification of specific situations that could impact the neighborhood if GPT were built.

We respectfully request that the scope of the GPT environmental review include several areas of potential impact that could directly affect our association’s members:

Increase train noise and vibrations
The 18 trains a day required for GPT at full build out would more than double existing train traffic levels in our community. For this reason, we request that the EIS address the following questions:
• What would this increase in train traffic mean for the level of train noise from horns, screeching and rumbling in our neighborhood, particularly for the residents living adjacent to or in close proximity to the tracks?
• What are the potential sleep disturbances and or other negative health impacts that may be associated with this increase in train traffic?
• What risks would the increase in vibrations from heavy coal trains pose to structural integrity of homes and properties along the waterfront and the stability of the bluff?

New rail infrastructure near or through the Edgemoor neighborhood
Current rail traffic is operating near peak capacity on the existing rail line. Washington State Department of Transportation planning documents have highlighted the need for a new, active rail siding on this segment should train traffic increase to levels that GPT would require.(1) The documents indicate that the preferred siding location would stretch between approximately mileposts 92 to 98 along the Bellingham waterfront running north from Fairhaven. This new siding would potentially affect our members, particularly the residents living on the north side of Edgemoor that faces Fairhaven. However, BNSF has not disclosed the siding location. One possible alternate location identified is south of Bellingham, possibly through the Edgemoor tunnel, across the trestle on Mud Bay and along Chuckanut Bay. This location could directly impact our neighborhood with higher exposure to diesel particulate matter and fugitive coal dust from trains idling on the active siding. The questions we request be studied in relation to new rail infrastructure in our areas are:
• What is the precise location of the new siding?
• What are possible adverse impacts of the siding for our neighborhood, including increased diesel emissions in our area, an increase in fugitive coal dust and noise implications?

Property values
The ENA is concerned about the very real possibility of decreased property values as a result of increased coal train freight traffic. A recent analysis by The Eastman Company, of Seattle, WA determined that for properties located north of Everett, the impacts of GPT traffic on single-family residences in close proximity to the BNSF tracks could be considerable: “The applicable range of diminution in value for single family residences, the property type expected to suffer the most severe impacts, has been concluded to range from five to twenty percent of market value.”(2) Our neighborhood encompasses many properties that are precisely the most vulnerable to decreases in market value. We therefore request that the following be studied:
• What is the anticipated impact of GPT freight traffic on Edgemoor property values?
• What is the associated decline in the value of the City’s tax base?
• How will the City and property owners be compensated for any losses?

GPT vessel anchorage in Bellingham Bay
Coal vessels anchored offshore in other residential areas, such as in the Hampton Roads area near Chesapeake Bay, have created local concern about impacts.(3) We request that the EIS examine these related questions:
• Would Bellingham Bay serve as a potential overflow anchorage for GPT ships?
• If so, what are the possible impacts for the Edgemoor shoreline and properties?

Thank you for the opportunity to comment.

Sincerely,

The Edgemoor Neighborhood Association
Bellingham, Washington

Citations:
1. http://www.communitywisebellingham.org/wp-content/uploads/2012/05/CWB-Final_BibliographyWithExtracts-Report.pdf
2. http://climatesolutions.org/nw-states/coal-train-study
3. http://hamptonroads.com/2011/02/coal-ships-create-sight-hampton-roads-waters

Eleanor Hines (American Fisheries Society) (#12212)

Date Submitted: 01/22/13
Comment:
To whom it may concern:

I would like to submit this EIS scoping comment on behalf of the American Fisheries Society Western Washington University Chapter that is attached to this email and also found copied and pasted below. Please let me know if you encounter any problems in reading or opening this comment.


Thank you for you time.

Eleanor Hines
Secretary
American Fisheries Society
Western Washington University Chapter
hinese@students.wwu.edu


GPT/Custer Spur EIS
c/o CH2M Hill
1100 112th Ave. NE Suite 400
Bellevue, WA 98004

January 15, 2013

RE: Gateway Pacific Terminal/Custer Spur EIS Scoping Comment

The American Fisheries Society (AFS) is dedicated to improve the conservation and sustainability of fishery resources and aquatic ecosystems by advancing fisheries and aquatic science and promoting the development of fisheries professionals. As a student chapter of AFS at Western Washington University of young and upcoming fisheries scientists, our AFS Chapter has concerns about the proposed Gateway Pacific Terminal and below outline adverse impacts that are important to address in the scope of the Environmental Impact Statement in order to ensure that this terminal and all associated operations will not have significantly negative impacts on our local fisheries and aquatic environment. Our concerns we request to be addressed include artificial night lighting, underwater noise, vessel traffic, coal dust/cargo spillage, nearshore habitat impacts, and economic impacts to local fisheries.


Artificial Lighting

Statement and Rationale for Concern:
Little is known or understood about the effects of artificial night lighting on aquatic organisms. Artificial lighting at night could have adverse impacts on aquatic organism in terms of predator-prey interactions, water column positioning, and more for organisms that regulate or rely on lighting for daily activities.

Recommendations: Conduct studies on the effects of artificial lighting on sensory perceptions, as well as migration, forage, and spawning behavior of forage and other fish, such as herring. Asses potential shifts in species abundance due to increased prey access under artificial lighting. Consider alternative artificial lighting options to minimize impacts, such as angle and type of lights used.

Applicable Regulations:
Chapter 90.58 RCW Shoreline Management Act of 1971
Chapter 173-26 WAC State Master Program Approval/Amendment Procedures and Master Program Guidelines.
Washington Department of Ecology Shoreline Management. Accessed January 10, 2013 at http://www.ecy.wa.gov/programs/sea/sma/laws_rules/173-16.html




Underwater Noise

Statement and Rationale for Concern: Construction and operations of this terminal would add to the surface and underwater noise at Cherry Point and along the associate vessel traffic route. Underwater noise is known to adversely affect marine mammals and finfish, including Pacific Herring, which utilize Cherry Point as an important spawning habitat. Surf smelt, bull trout, Puget Sound Steelhead trout, Chinook salmon, and three species of protected rockfish are known to use the Southeast Georgia Straits and Cherry Point region and are all listed as either Threatened or Endangered under the Endangered Species Act and could be affected by increased noise from GPT construction and associated operations.

Recommendations: Assess current surface and underwater sound levels along the shoreline at Cherry Point and compare with the projected additional noise levels that would be generated from the proposed terminal and associated vessel traffic to determine overall effects on aquatic organisms, especially those mentioned above. Consider alternative vessel routes to minimize impacts to marine organisms.

Applicable Regulations:
U.S. Endangered Species Act: http://www.nmfs.noaa.gov/pr/laws/esa/, http://www.fws.gov/endangered/.
Marine Mammal Protection Act: http://www.nmfs.noaa.gov/pr/laws/mmpa/
Magnuson-Stevens Fishery Conservation and Management Act: http://www.nmfs.noaa.gov/sfa/magact/
Chapter 70.107 RCW Noise Control.
Chapter 90.58 RCW Shoreline Management Act of 1971
Chapter 173-26 WAC State Master Program Approval/Amendment Procedures and Master Program Guidelines
See Washington Department of Ecology, Noise Pollution: http://www.ecy.wa.gov/laws-rules/noise.html.


Vessel Traffic Safety

Statement and Rationale for Concern: SSA Marine’s Gateway Pacific Terminal proposed to use cape-size ships. Vessel failure as well as collisions and allisions are likely given the local geography, the large increase of annual vessel traffic associated with the terminal, and that the maneuverability of these ships is difficult. If a collision were to occur, it is likely that large amounts of cargo and/or oil would spill into the Sound and have adverse affects on marine biota.

Recommendations: Examine potential risk of increasing vessel traffic and the risk associated with the type of vessels used to export coal and other bulk commodities. Safety plans should be in place and able to adequately respond to a cape-size ship failure to prevent running aground and spillage. Washington State needs to have tugboats powerful enough to handle these large ships and be stationed close enough to the vessel route to respond in time to prevent disaster. The Salish Sea has many organisms that could be severely affected, and may adversely affect fisheries and harm the region economically.

Applicable Regulations:
Clean Water Act.
Oil Pollution Act of 1990.
Endangered Species Act.
Migratory Bird Act.
Chapter 90-56 RCW Oil and Hazardous Substance Spill Prevention and Response
Chapter 90.58 RCW Shoreline Management Act of 1971
Chapter 173-182 WAC Oil Spill Contingency Plan
Chapter 173-26 WAC State Master Program Approval/Amendment Procedures and Master Program Guidelines
Chapter 220-150 WAC Ballast Water Management. Accessible online at http://apps.leg.wa.gov/wac/default.aspx?cite=220-150
Chapter 77.120 RCW Ballast Water Management. Accessible online at http://apps.leg.wa.gov/rcw/default.aspx?cite=77.120


Coal Dust/Cargo Spillage

Statement and Rationale for Concern: Coal dust and cargo spillage may impact marine resources at Cherry Point and the surrounding Salish Sea region. Coal and coal dust specifically have the potential to reduce the availability of light, alter sediment, and clog respiratory and feeding organs. The toxicity of coal dust and coal leachates additionally could have adverse impacts to aquatic organisms.

Recommendations: Fugitive coal will be an issue at the Gateway Pacific Terminal as no prior terminal has proven to completely control this, therefore it is important to take all precautions to minimize and mitigate the effects of fugitive coal dust to marine organisms. GPT proposes to export other bulk commodities that could also have adverse impacts if spilled into the marine environment. These affects should be examined and measures taken to reduce the risk of such occurrences.

Applicable Regulations:
The U.S. Environmental Protection Agency’s (EPA) Clean Water Act (CWA)
EPA Clean Air Act (CAA).


Nearshore Habitat Impacts

Statement and Rationale for Concern: Construction of and the pier itself, shoreline armoring structures, filled intertidal areas, increased vessel traffic, anchored vessels, vessel prop wash, bulk commodity shipping and handling, and loading/offloading of cargo that may lead to spills or releases into the marine environment are all causes of concern to nearshore habitat at Cherry Point. Wave energy and scouring, hydrology, nearshore sediment drift processes are additionally likely to be impacted as the three existing piers at Cherry Point have already impacted the shoreline in these ways. Sediment habitat for bivalves and substrate for submerged aquatic vegetation (light attenuation and sediment and turbidity, shading) could smother these organisms or provide inadequate habitat for bottom dwellers. Dungeness crab habitat, including the female refuge area identified off the shelf at Cherry Point, nearshore migration routes for juvenile salmonids, potential loss of submerged aquatic vegetation habitat, alteration or degradation in intertidal beach characteristics could affect forage fish spawning, and alteration or destruction of the salt marsh at Gulf Road could all be adversely affected due to GPT construction and operations and thereby degrade important habitat for marine organisms that are important biologically and economically.

Recommendations: Structures should use designs to minimize impact to wave energy, nearshore sediment drift, and aquatic/riparian vegetation. Any constructed structure along the shoreline should promote natural marine ecosystem processes. Consideration for potential climate change alterations in addition to historical conditions should be taken into account. Climate change may impact changes in direction and rate of sediment transport, wave energy, tidal heights, and water chemistry may impact overwater structures along the shoreline. Examine and monitor before, during, and post terminal construction for sediment quality, submerged aquatic vegetation, shellfish, fish, and other biota in the nearshore and intertidal marine environments.

Applicable Regulations:
Chapter 90-56 RCW Oil and Hazardous Substance Spill Prevention and Response
Chapter 90.58 RCW Shoreline Management Act of 1971
Chapter 173-182 WAC Oil Spill Contingency Plan
Chapter 173-26 WAC State Master Program Approval/Amendment Procedures and Master Program Guidelines
Chapter 220-110 WAC Hydraulic Code Rules:
Chapter 220-110-230 Saltwater technical provisions.
Chapter 220-110-240 Tidal reference areas.
Chapter 220-110-250 Saltwater habitats of special concern.
Chapter 220-110-270 Common saltwater technical provisions.
Chapter 220-110-271 Prohibited work times in saltwater areas.
Chapter 220-110-280 Bulkheads and bank protection in saltwater areas (non-single family residence).
Chapter 220-110-290 Saltwater boat ramps and launches.
Chapter 220-110-300 Saltwater piers, pilings, docks, floats, rafts, ramps, boathouses, houseboats, and associated moorings.
Chapter 220-150 WAC Ballast Water Management





Economic Impacts to Local Fisheries

Statement and Rationale for Concern: Given the concerns outlined above, there are a number of adverse impacts that could directly or indirectly affect local fisheries due to noise, artificial lighting, toxicity, increased vessel traffic, and other associated activities due to the construction and operation of the terminal. This could have in turn negative impacts on local fisheries, both sport and commercial, and the economy.

Recommendations: Assess the adverse impacts to local fish, shellfish, and crab populations and economic impacts to associated sports and commercial fishing.

Applicable Regulations:
The U.S. Environmental Protection Agency’s (EPA) Clean Water Act (CWA)
EPA Clean Air Act (CAA)
Chapter 90.58 RCW Shoreline Management Act of 1971
U.S. Endangered Species Act
Chapter 90.58 RCW Shoreline Management Act of 1971
Magnuson-Stevens Fishery Conservation and Management Act: http://www.nmfs.noaa.gov/sfa/magact/


Thank you for taking the time to assess our comments.


Sincerely,

WWU AS American Fisheries Society

Jordan Head (President)
Laura Junge (Vice President)
Eleanor Hines (Secretary)
Attached Files:

Eric de Place (#6297)

Date Submitted: 01/08/2013
Location: Seattle, WA
Comment:
January 8, 2012

Proposed Gateway Pacific Terminal/Custer Spur EIS
c/o CH2M HILL
1100 112th Ave NE, Suite 400
Bellevue, WA 98004
comments@eisgatewaypacificwa.gov

Randel Perry, Project Manager
USACE, Seattle District
1440 10th Street, Suite 102
Bellingham, WA 98225-7028

Tyler Schroeder, Planning Supervisor
Whatcome County, Planning & Developmment Services
5280 Northwest Drive
Bellingham, WA 98226

Alice Kelly, Planner
Washington Department of Ecology, NWRO
3190 160th Ave SE
Bellevue, WA 98008-5452

Re: Comments on proposed Gateway Pacific Terminal EIS scoping

Dear CH2M Hill, Mr. Perry, Mr. Schroeder, and Ms. Kelly,

Please consider this letter as part of the public record for the Gateway Pacific Terminal coal export project proposed at Cherry Point, Whatcom County, Washington, facility site ID #22237. With this letter, written on behalf of Sightline Institute, I respectfully request that the lead agencies carefully evaluate and respond to the following questions.

Can a large coal handling facility control the spread of coal dust?

The proposed Gateway Pacific Terminal will store coal in large piles and there is ample evidence that coal stockpiles can feed prolific quantities of dust to the wind, especially when terminal machinery are loading and unloading the fuel. As one study put it, “coal terminals by their nature are active sources of fugitive dust.”1 Unsurprisingly, coal dust problems plague export facilities in North America and around the world.

In Seward, Alaska, for example, residents have sued the local terminal operators because coal dust blowing off the terminal’s stockpiles regularly coats nearby fishing boats and neighborhoods with debris. The residents’ suit states that the conveyor system used to load ships drops coal dust into Seward’s scenic harbor, violating the Clean Water Act.2 In 2010, the state of Alaska fined the railroad company that delivers coal to the terminal $220,000 for failing to adequately control dust.3

British Columbia’s Westshore coal terminal, which shipped about 27 million metric tons in 2011, sits on a peninsula jutting into the Strait of Georgia. Some residents of Point Roberts, a beachfront community three miles away, complain that coal dust blackens their homes, patio furniture, and boats moored in the local marina.4 A comprehensive 2001 study of coal dust emissions in Canada found that the Westshore Terminal emits roughly 715 metric tons of coal dust a year. A separate study recently conducted by researchers at the University of British Columbia found that the concentrations of coal dust in the vicinity of the terminal had doubled during the period from 1977 to 1999.5 Despite measures to control the spread of dust, photographs published in the news media shows that coal dust continues to be a problem at both Westshore and Ridley Terminals in northern British Columbia.6

The Lamberts Point Coal Terminal in Norfolk, Virginia, which ships 28 million tons of coal annually, is legally permitted to release up to 50 tons of coal dust into the air each year. Black grit from the coal piles commonly coats cars, windowsills, and plants in neighboring communities. Neighbors worry that the dust is responsible for the vicinity’s elevated asthma rates.7 In Newport News, Virginia; Charleston, South Carolina; and on the Mississippi River, coal dust routinely blankets neighborhoods and local waterways.8 And coal dust is widespread near terminals in Australia, India, and South Africa.9

Project developers are promising to install mitigation devices that they say will control dust, yet it’s highly unlikely that the coal dust can be contained entirely. Huge piles of coal will stand outdoors in wind and weather, and frequently be shoveled into new positions by stacker reclaimers and other machinery. In fact, the project developers have not identified any large coal handling facility anywhere in the world that has adequately contained coal dust.

Does rail transport release coal dust or create other coal-related hazards?

Coal dust escapes from the open-top rail cars used for transporting coal and can create safety and congestion problems for rail traffic. In 2005, for example, coal dust that had accumulated in ballast, the layer of crushed rock that supports rail tracks, caused derailments. Coal dust deposits sometimes even cause spontaneous fires.

The Burlington Northern Santa Fe Railway (BNSF) has studied the problem and found that as much as a ton of coal can escape from a single loaded coal car, while other reports show that as much as 3 percent of a coal car’s load, which is typically 100 tons or more, can blow away in transit.10 The US Department of Transportation classifies coal dust as a “pernicious ballast foulant” that can weaken and destabilize rail tracks.11 It is not clear how much coal dust might escape in the Pacific Northwest, but one watchdog group has verified that coal and coal dust does escape from open rail cars traveling along Puget Sound coastlines.12

To reduce or prevent coal dust from escaping, shippers can fill cars less full, cover them, or deploy chemical sprays, but these measures run up the cost of moving coal, so coal shippers rarely employ them by choice.13 A March 2011 ruling from the US Surface Transportation Board, which oversees railway operations, allowed BNSF to require coal shippers to control dust, but there is little reason to believe the controls will be effective.14 In fact, shippers are already appealing the decision, blaming BNSF’s operating procedures for the spread of coal dust and arguing that the railway’s dust reduction goals are unrealistic and based on “junk science.”15

Complicating matters for the Northwest, Powder River Basin (PRB) coal is notoriously difficult to handle. One technical analysis finds that, “PRB coal is extremely friable and will break down into smaller particles virtually independent of how the coal is transported or handled.” According to the study’s authors, “PRB represents the extremes of handling problems.”16

The same analysis found that:

Spontaneous combustion of coal is a well-known phenomenon, especially with PRB coal. This high-moisture, highly volatile sub-bituminous coal will not only smolder and catch fire while in storage piles at power plants and coal terminals, but has been known to be delivered to a power plant with the rail car or barge partially on fire…17

Outside of confined environments, Powder River Basin coal does not spontaneously explode or burst into full flame, but under the wrong conditions it can self-ignite and burn slowly even while it is riding the rails—a troubling proposition for railroad workers and communities along the tracks.

Is non-occupational coal dust exposure harmful to people?

Coal dust degrades water quality and may pose a danger to residents’ health. Coal workers who are exposed to dust, for example, suffer elevated rates of bronchitis, emphysema, and black lung disease.18 In Liverpool, England, researchers found that, even after correcting for economic and environmental factors at home, children exposed to coal dust from the nearby docks were more likely to miss school because of respiratory problems, including wheezing and coughing.19

In Norfolk, Virginia, home of the Lamberts Point Coal Terminal, soil samples contain up to 20 percent coal by weight at a site less than 1 kilometer from the docks, 3 percent coal at a site 5 kilometers away, and 1 percent coal as far as 12 kilometers away. High coal levels in soil along railroad tracks suggest that trains are another pathway for contamination. Researchers in Norfolk also found arsenic levels were five times higher than background soil concentrations nearby, and hypothesize that the coal export terminal is at least partially responsible for the difference because coal often contains arsenic.20

Is coal dust harmful to fish and wildlife?

Several scientific studies raise serious questions about the impact of coal dust on key species such as salmon. Coal dust exposure has been shown to alter gene expression in juvenile salmon, a process that could result in cell mutations which could have profound physiological consequences.21 There is also evidence that coal byproducts and pollutants in coal dust reduce the growth rate of trout.22 Moreover, these same substances have been shown to promote hepatocellular carcinoma in fish.23

There are related concerns about the prospect of pollution from coal-handling practices. One study found that additives, such as surfactants, in the water sprayed on stockpiles can increase the mobility of pollutants in the aquatic environment.24 Moreover, coal pollution can be extremely long-lived. In fact, the majority of alkyl PAHs in water near deep marine outfalls off South Vancouver Island are not from the nearby sewage outfalls but rather from a 1891 ship that went down carrying collier waste.25

Does coal transport create other health risks?

The proposed coal exports would add a large number of trains to the Northwest’s rail lines. The proposed Gateway Pacific project would add 18 trains per day to the region’s rail network. Coal trains tend to be long – sometimes as much as a mile and a half in length – and are believed by many to be louder and produce more vibrations than other trains, owing to their weight.

A group of 160 doctors and other health professionals in Whatcom County, Washington, published a position statement documenting a number of health-related problems with coal exports. In addition to the risks of coal dust, the doctors raise concerns about the impacts of the trains themselves, which generate noise, create collision hazards, and delay emergency medical response by impeding rail crossings. Trains are also responsible for hazardous air pollution from diesel engines, a documented threat to health in Washington.26

The BNSF rail yards in Spokane—an important linkage point between the Powder River Basin and
Washington’s Pacific ports—would see increased rail traffic that is almost certain to increase harmful pollution there. A 2010 study by the Spokane Clean Air Agency identified lung cancer risks in Spokane that appear closely related to residents’ proximity to the BNSF railyard, where diesel engines generate prodigious quantities of small particulate pollution, the most health-threatening major air pollutant in the Northwest. Researchers ruled out numerous alternative explanations and concluded that “the BNSF railyard appears to be the only other air pollution source in the vicinity of Hillyard that can account for its differential lung cancer risk.”27

To what degree would coal transport worsen traffic congestion and impair freight mobility?

For many communities, coal trains are certain to worsen traffic congestion and impair truck freight. The sheer number of trains required by a full build-out of the coal terminals would dictate that even if trains traveled at 35 miles per hour they would obstruct at-grade crossings for 10 percent of every day. In urban locations, where train speeds are slower, the problem is likely to be even worse.28 In fact, a detailed traffic study by Parametrix found that coal trains would close heavily used streets in downtown Seattle by 1 to 3 hours every day.29

A series of traffic analyses conducted by Gibson Traffic Consultants found that coal train traffic will result in serious congestion and delay in many Northwest cities.30 In Marysville, Washington, for example, a single coal train passing through would delay traffic on the city’s central arterials by the equivalent of three to four continuous red light cycles and Gibson points to a potential “nightmare scenario” where all of the city’s access points to Interstate 5 are obstructed simultaneously.31

Coal trains may also create congestion problems on the Northwest’s railroads. Key areas of the region’s railway system already operate beyond their capacity, resulting in congestion and delay for freight and passenger trains alike. Rail system experts working for the Western Organization of Resource Councils analyzed coal export plans and determined that local governments would be saddled with hundreds of millions of dollars in expenses to mitigate the rail expansions and operations envisioned by coal export proponents.32

The Portland, Oregon-Vancouver, Washington area is one of the most problematic locations in part because it will be affected by coal trains no matter whether coal is shipped to Bellingham, Longview, the Port of St. Helens, or Coos Bay. In fact, the most comprehensive analysis of Washington’s freight rail system—a report prepared by Cambridge Systematics for the Washington State Transportation Commission—notes that, “delay hours per train moving through the Portland/ Vancouver area are greater than the delay hours for trains in the Chicago area, one of the nation’s most congested rail hubs.”33

Northwest Washington is another critical location because the rail mainline consists of just a single track and is already subject to frequent congestion. Coal trains serving the planned coal export facility at Cherry Point would more than double the existing rail traffic in that area—even before the region sees any other freight expansions, and before the region gets new passenger rail service. In fact, even if all existing freight and passenger trains were removed from the system—and only coal trains serving Cherry Point used the main railway—the coal shipments alone would exceed the capacity of the existing system. Not surprisingly, a study of rail capacity by the Cascadia Center concludes that the proposed terminal there “has the potential to create an operational bottleneck.”34

To what degree would burning Powder River Basin coal harm the environment?

Powder River Basin coal is lower in ash and sulfur than some other kinds of coal, but it also produces less energy per pound than the coals that are more commonly burned in modern power plants.35 To produce the same amount of energy from Powder River Basin coal requires mining, shipping, and burning about 50 percent more.36

Coal is a highly impure form of fuel, and burning it releases numerous hazardous substances, including radioactive materials such as uranium and thorium. In fact, the US Department of Energy’s Oak Ridge National Laboratory has estimated that coal plants have released hundreds of thousands of tons of uranium, and that radiation from coal plants is a greater threat to Americans than radiation from nuclear plants.37

The true costs of coal are daunting. Researchers at the Harvard Medical School recently pegged the annual cost of coal—including harm to public health, mining damage, pollution, and subsidies—at $345 billion per year in the United States alone.38 A 2010 report from the National Research Council finds that the non-climate damages from burning coal are 20 times higher than the damages from natural gas, the next dirtiest and costliest fossil fuel in use.39 And a 2009 report from the National Academy of Sciences determined that US coal burning results in $60 billion per year in health costs alone.40

Coal is also a serious contributor to global climate change, and there is little variation in the carbon intensity of coal types on an energy-adjusted basis because the amount of energy produced is simply a very close reflection of the carbon content of the coal. More importantly, coal comes with a much heavier carbon footprint than any other fuel on the planet. For example, the subbituminous coal characteristic of the Powder River Basin produces 32 percent more greenhouse gas emissions than diesel and 82 percent more than natural gas.41

Will the Gateway Pacific project increase the amount of coal burned in Asia?

US coal exports would not supplant the burning of dirtier Chinese coal. Instead, North American exports would add to the volume burned in Asia. In a recent white paper, resource economist Thomas
Michael Power demonstrated this point:

This result—that international competition to serve particular import markets will lower the prices that the importing countries have to pay—should not be startling. One of the major benefits of international trade is that it allows countries access to lower cost sources of supply.42

In other words, Washington coal exports will not simply displace other coal in the market. Instead,
American coal exports will adhere to fundamental economic principles: an increase in supply will bring down market prices and thereby increase total consumption. The extent to which increasing supply will boost demand is debatable—just like the extent to which higher prices would dampen demand—but the direction of the change is clear.

In fact, some underlying dynamics may make US exports even more critical. As Power points out, lower prices may encourage China to build more coal-burning power plants than they otherwise would, an investment that would lock in elevated coal burning and pollution for decades to come.

It is important to note that Canadian ports cannot make up for the capacity planned for the Gateway Pacific Terminal and other coal export proposals in Oregon and Washington. Despite planned capacity expansions, big increases in shipments of American coal from British Columbia are highly unlikely. Canadian steelmaking coal is in high demand, and it brings significantly higher prices than the Powder River Basin coal. Moreover, to a large extent, BC’s coal ports are structured to handle primarily Canadian coal and other exports. Finally, space is limited at BC terminals. The expansions planned for BC’s coal terminals do not come close to providing enough capacity for the volumes of coal called for by the five recent proposals in the Northwest. In fact, if all of the planned new capacity that is not already claimed by contract were filled by US coal (rather than by higher-value Canadian coal), and even if all three of BC’s coal ports were able to operate year-round at full capacity—two highly unlikely scenarios—the terminals would have less than 13 million metric tons of extra capacity, a tiny fraction of the 140 million tons planned for Oregon and Washington.43

The clearest evidence that West Coast coal exports are constrained by port capacity comes from the coal industry itself. Major coal firms have clearly and repeatedly indicated to their investors that they need new export facilities in Oregon and Washington if they are ever to export large quantities of Powder River Basin coal. For example, as Cloud Peak stated in a 2012 investor report, “While demand from our Asian customers remains strong, this year’s exports will again be limited by available terminal capacity out of the Pacific Northwest.”44

Will increased coal burning in Asia harm the Northwest’s environment?

Sulfur compounds, soot, and other byproducts of Asian coal combustion are detectable on mountaintops in the western United States.45 Researchers have also linked ozone in the air above the United States to pollution from developing Asian countries that are burning fossil fuels.46 Ozone can exacerbate asthma and heart disease. Mercury, a neurotoxin that is particularly dangerous for children, is especially likely to travel across the Pacific Ocean. An Oregon researcher estimates that as much as 18 percent of the mercury in Oregon’s Willamette River comes from sources overseas, increasingly from China.47 Another study found that human-created pollution from Asia contributed to 14 percent of the mercury dropped on Mount Bachelor in central Oregon.48

What’s more, burning large amounts of coal accelerates global climate change. Burning 140 million tons of Powder River Basin coal releases roughly 250 million tons of heat-trapping carbon-dioxide into the atmosphere, roughly equivalent to the annual emissions from 57 million cars.49 In fact, the carbon content of the coal proposed for export would vastly exceed the carbon from the dirty oil sands fuel planned for transport in the controversial Keystone XL pipeline.50

Thank you for the opportunity to provide comments on this matter. Please do not hesitate to contact me if I can be of any assistance or if I can provide additional information.

Sincerely,

Eric de Place
Sightline Institute
1402 Third Avenue, Suite 500
Seattle, WA 98101
206-4471-1880 x105
eric@sightline.org
1 Douglas L. Cope and Kamal K. Bhattacharyya, A Study of Fugitive Coal Dust Emissions in Canada, “Chapter 8: Coal Terminals:
Fugitive Dust Emissions and Control,” prepared for The Canadian Council of Ministers of the Environment, November 2001.
2 Andrew Jensen, “Judge Allows Lawsuit: Seward Coal Facility Faces Clean Water Act Suit,” Alaska Journal of Commerce, January
24, 2011, http://www.peninsulaclarion.com/stories/012411/new_775559217.shtml.
3 Mary Pemberton, “Alaska Railroad Takes Steps to Reduce Coal Dust,” Ventura County Star, July 9, 2010, http:// www.vcstar.com/
news/2010/jul/09/alaska-railroad-take-steps-to-reduce-coal-dust.
4 Erik Olson, “Westshore provides glimpse of Longview’s potential future with coal,” Daily News, February 12, 2011, http://tdn.
com/news/local/article_35ad9c0c-3634-11e0-8eea-001cc4c03286.html.
5 Douglas L. Cope and Kamal K. Bhattacharyya, A Study of Fugitive Coal Dust Emissions in Canada, “Chapter 8: Coal Terminals:
Fugitive Dust Emissions and Control,” prepared for The Canadian Council of Ministers of the Environment, November 2001;
and Ryan Johnson and R. M. Bustin, “Coal dust dispersal around a marine coal terminal (1977–1999), British Columbia: The
fate of coal dust in the marine environment,” International Journal of Coal Geology, Volume 68, Issues 1-2, 1 August 2006, Pages
57-69, http://www.sciencedirect.com/science/article/pii/S0166516206000206.
6 Shaun Thomas, “Port Edward raises concerns after large coal cloud spotted over Ridley Terminals,” The Northern View, June 16, 2011, http://www.thenorthernview.com/news/124013379.html; and The Delta Optimist, “Unexpected wind gust stirs up coal dust at Roberts Bank,” The Vancouver Sun, April 13, 2012, http://www.vancouversun.com/Unexpected+wind+gust+stirs+coal+dust+Roberts+Bank/6455530/story.html.
7 William J. Bounds and Karen H. Johannesson, “Arsenic Addition to Soils from Airborne Coal Dust Originating at a Major
Coal Shipping Terminal,” Water, Air, & Soil Pollution, June 21, 2007, 185: 195-207, http://www. springerlink.com/
content/98146r1160021h13/; and Joe Lawlor, “Coal Dust, Piles an Issue for Southeast Newport News,” July 16, 2011, http://
articles.dailypress.com/2011-07-16/news/dp-nws-cp-nn-coal-dust-20110716_1_coal-dust-coal-piles-coal-terminals.
8 Eric de Place, “The Facts About Kinder Morgan,” Sightline Daily blog, April 5, 2012, http://daily.sightline.org/2012/04/05/thefacts-
about-kinder-morgan/.
9 Eric de Place, “Australia’s Coal Dust Problem,” Sightline Daily blog, February 7, 2012, http://daily.sightline.org/2012/02/07/
australias-coal-dust-problem/; Eric de Place, “Coal Dust in India,” Sightline Daily blog, February 15, 2012, http://daily.sightline.
org/2012/02/15/coal-dust-in-india/; and Eric de Place, “Coal Dust in South Africa,” Sightline Daily blog, May 1, 2012, http://daily.
sightline.org/2012/05/01/coal-dust-in-south-africa/.
10 Eric de Place, “At Least the Website is Clean,” Sightline Institute blog, August 10, 2011, http://daily.sightline. org/2011/08/10/atleast-
the-website-is-clean/.
11 “Surface Transportation Board Authorizes Tariff Rules on Coal Dust but Strikes Down Specific BNSF Tariff,” Troutman Sanders
LLP, Washington Energy Report, http://www.troutmansandersenergyreport.com/2011/03/surface-transportation-board-authorizestariff-
rules-on-coal-dust-but-strikes-down-specific-bnsf-tariff.
12 Gary Chittim, “Traces of coal found along Washington railways,” King 5 News, August 16, 2011, http://www. king5.com/news/
environment/Coal-Found-Along-Washington-Railways-127907523.html.
13 Josh Voorhees, “Railroads, Utilities Clash Over Dust From Coal Trains,” New York Times, January 25, 2010, http://www.nytimes.
com/gwire/2010/01/25/25greenwire-railroads-utilities-clash-over-dust-from-coal-55265.html; and Joe Deaux, “Regulations Could
Derail Railroad Profits,” The Street, August 21, 2011, http://www.thestreet. com/story/11215990/1/regulations-could-derailrailroad-
profits.html.
14 Surface Transportation Board, “Decision, Docket No. FD 35305, Arkansas Electric Cooperative Corporation: Petition for
Declaratory Order,” March 3, 2011, http://www.troutmansandersenergyreport.com/wp-content/ uploads/2011/03/Coal-Dust.pdf.
15 Steven Johnson, “Shippers Challenge Railroad Coal Fee,” Electric Co-op Today, October 17, 2012, http://www.ect.coop/
regulatory-watch/transportation-regulation/shippers-challenge-railroad-coal-fee/49155.
16 Roderick J. Hossfeld and Rod Hatt, “PRB Coal Degradation: Causes and Cures,” PRB Coal Users Group, http://www.prbcoals.
com/pdf/paper_archives/56538.pdf.
17 Roderick J. Hossfeld and Rod Hatt, “PRB Coal Degradation: Causes and Cures,” PRB Coal Users Group, http://www.prbcoals.
com/pdf/paper_archives/56538.pdf.
18 US Occupational Safety and Health Administration, “Occupational Safety and Health Guideline for Coal Dust,” http://www.osha.
gov/SLTC/healthguidelines/coaldust-greater5percentsio2/recognition.html.
19 Liverpool from Bernard Brabin et al., “Respiratory morbidity in Merseyside schoolchildren exposed to coal dust and air
pollution,” Archives of Disease in Childhood, 1994; 70: 3015-312, http://www.ncbi.nlm.nih.gov/pmc/ articles/PMC1029784/pdf/
archdisch00564-0049.pdf.
20 William J. Bounds and Karen H. Johannesson, “Arsenic Addition to Soils from Airborne Coal Dust Originating at a Major
Coal Shipping Terminal,” Water, Air, & Soil Pollution, June 21, 2007, 185: 195-207, http://www. springerlink.com/
content/98146r1160021h13/.
21 Campbell P.M.; Devlin R.H., “Increased CYP1A1 and ribosomal protein L5 gene expression in a teleost: The response of juvenile chinook salmon to coal dust exposure,” Aquatic Toxicology, Volume 38, Number 1, May 1997 , pp. 1-15(15),
http://www.ingentaconnect.com/content/els/0166445x/1997/00000038/00000001/art00848.
22 Herbert, D.W.; Richards, J.M., “The growth and survival of fish in some suspensions of solids of industrial origin,” International Journal of Air and Water Pollution, June 1963;7:297-302, http://www.ncbi.nlm.nih.gov/pubmed/13953887.
23 Jerry D. Hendricks et al., “Hepatocarcinogenicity of Benzo[a]pyrene to Rainbow Trout by Dietary Exposure and Intraperitoneal Injection,” Oxford Journals, Journal of the National Cancer Institute, Volume 74, Issue 4, pp. 839-851, http://jnci.oxfordjournals.org/content/74/4/839.abstract.
24 J.D. Enzminger & R.C Ahlert, “Environmental fate of polynuclear aromatic hydrocarbons in coal tar,” Environmental Technology Letters, Volume 8, Issue 1-12, 1987, pages 269-278, http://www.tandfonline.com/doi/abs/10.1080/09593338709384486.
25 Mark B. Yunker, Avrael Perreault, Christopher J. Lowe, “Source apportionment of elevated PAH concentrations in sediments near deep marine outfalls in Esquimalt and Victoria, BC, Canada: Is coal from an 1891 shipwreck the source?” Organic Geochemistry, Volume 46, May 2012, Pages 12-37, http://www.sciencedirect.com/science/article/pii/S0146638012000071.
26 “Whatcom Docs Position Statement and Appendices,” Coal Train Facts, http://www.coaltrainfacts.org/whatcom¬docs-positionstatement-
and-appendices.
27 Charles E. Studer, “Health Risk Study for the Burlington Northern / Santa Fe Railroad Spokane Railyard,” Spokane Regional
Clean Air Agency,” June 16, 2010, http://www.spokanecleanair.org/documents/Study_Reports/BNSF%20Spokane%20
Railyard%20Health%20Study.pdf.
28 Eric de Place, “Why Seattle’s Freight Interests Should Worry About Coal Exports,” Sightline Daily blog, June 27, 2012, http://daily.
sightline.org/2012/06/27/why-seattles-freight-interests-should-worry-about-coal-exports/.
29 Parametrix, “Coal Train Traffic Impact Study,” October 2012, http://www.seattle.gov/mayor/media/PDF/121105PR-CoalTrainTrafficImpactStudy.pdf.
30 Gibson Traffic Consultants, “Traffic Study” series, October 2012, http://www.powerpastcoal.org/library/.
31 Edward Koltonowski, “Cherry Point Coal Export Facility Rail Operations,” Gibson Traffic Consultants memo, Juen 15, 2011,
http://www.powerpastcoal.org/wp-content/uploads/2012/10/traffic-study-Marysville.pdf.
32 Western Organization of Resource Councils, “Heavy Traffic Ahead: Rail Impacts of Powder River Basin Coal to Asia by Way of
Pacific Northwest Terminals,” July 2012, http://www.heavytrafficahead.org/.
33 Cambridge Systematics, “Statewide Rail Capacity and System Needs Study,” December 2006; http://www.wstc.wa.gov/Rail/
RailFinalReport.pdf and Eric de Place, “Coal Trains and Rail Congestion,” Sightline Daily blog, September 21, 2011, http://daily.
sightline.org/2011/09/21/coal-trains-and-rail-congestion/.
34 Eric de Place, “How Coal is Already Congesting Washington’s Railways,” Sightline Daily blog, October 24, 2011, http://daily.
sightline.org/2011/10/24/how-coal-is-already-congesting-washingtons-railway/.
35 Coal quality from Wyoming State Geological Survey, “Wyoming Coal Quality,” http://www.wsgs.uwyo.edu/ coalweb/library/
science/wyquality.aspx.
36 Union of Concerned Scientists, “How Coal Works,” http://www.ucsusa.org/clean_energy/coalvswind/brief_coal. html.
37 Alex Gabbard, “Coal Combustion: Nuclear Resource or Danger?” Oak Ridge National Laboratory Review, Summer/Fall 1993,
Vol. 26, No. 3&4, http://www.ornl.gov/info/ornlreview/rev26-34/text/contents.html.
38 Keith Bradsher and David Barboza, “Pollution from Chinese Coal Casts a Global Shadow,” New York Times, June 11, 2006,
http://www.nytimes.com/2006/06/11/business/worldbusiness/11chinacoal.html.
39 National Research Council, “Report in Brief: The Hidden Costs of Energy: Unpriced Consequences of Energy Production and
Use,” The National Academies Press, http://dels-old.nas.edu/dels/rpt_briefs/hidden_costs_of_energy_ Final.pdf.
40 Matthew L. Wald, “Fossil Fuels’ Hidden Costs is in Billions, Study Says,” New York Times, October 19, 2009, http://www.
nytimes.com/2009/10/20/science/earth/20fossil.html.
41 Eric de Place, “The Myth of Low Carbon Coal,” Sightline Daily blog, September 20, 2012, http://daily.sightline.org/2012/09/20/
the-myth-of-low-carbon-coal/.
42 Thomas M. Power, “The Greenhouse Gas Impact of Exporting Coal from the West Coast: An Economic Analysis,”; and Sightline
Institute, http://sightline.org/research/energy/coal/Coal-Power-White-Paper.pdf.
43 Eric de Place and Pam MacRae, “Coal Exports From Canada,” Sightline Institute, July 2012, http://www.sightline.org/research/
coal-exports-from-canada/.
44 For example, Peabody Energy, “Peabody Energy Announces Results for the Quarter Ended March 31, 2012,” April 19, 2012,
http://www.peabodyenergy.com/content/120/Press-Releases; and Cloud Peak Energy, “Cloud Peak Energy Inc. Announces Results
for the First Quarter of 2012,” April 30, 2012, http://www.cloudpeakenergy.com/investor-relations/press-releases.
45 Keith Bradsher and David Barboza, “Pollution from Chinese Coal Casts a Global Shadow,” New York Times, June 11, 2006,
http://www.nytimes.com/2006/06/11/business/worldbusiness/11chinacoal.html.
46 O.R. Cooper et al., “Increasing springtime ozone mixing ratios in the free troposphere over North America,” Nature, January 21,
2010, 463:344-348, http://www.nature.com/nature/journal/v463/n7279/pdf/nature08708.pdf.
47 “China’s mercury flushes into Oregon rivers,” Oregonian, November 24, 2006, http://www.atmos.washington. edu/ jaffegroup/
publications/116400a.pdf.
48 Sarah A. Strode et al., “Trans-Pacific transport of mercury,” Journal of Geophysical Research, 2008, Vol. 113, D15305, http://
www.atmos.washington.edu/jaffegroup/publications/Pacific_Transport_Hg.pdf.
49 Eric de Place, “Coal Exports and Carbon Consequences,” Sightline Institute blog, February 22, 2011, http://daily.sightline. org/2011/02/22/coal-exports-and-carbonconsequences/.
50 Eric de Place, “Coal Exports Are a Bigger Threat Than Tar Sands Pipeline,” Sightline Daily blog, November 16, 2011, http://daily.
sightline.org/2011/11/16/coal-exports-are-bigger-threat-than-tar-sands-pipeline.
---------------

------------------------------------------------------------

---------------

------------------------------------------------------------

Eric Johnson (Washington Public Ports Association) (#11802)

Date Submitted: 01/21/13
Location: Olympia, WA
Comment:
see attached
Attached Files:

Evelyn Adams (Transition Fidalgo & Friends) (#5064)

Date Submitted: 12/15/12
Comment:
see attached
Attached Image:

Floyd Gaibler (US Grains Council) (#4694)

Date Submitted: 12/12/12
Location: Washington, DC
Comment:
Dear Sir:

Attached are comments from the U.S. Grains Council regarding today’s scoping hearing on the GPT project. Thank you for your consideration.

Sincerely,

Floyd D. Gaibler
Attached Files:

Friends Friends of Chuckanut (#8918)

Date Submitted: 01/18/2013
Location: Bellingham, WA
Comment:
Please find attached the Friends of Chuckanut letter regarding the scope of the EIS for the GPT proposal at Cherry Point.
Attached Files:

Friends of Chuckanut (#11516)

Date Submitted: 01/22/2013
Location: Bellingham, WA
Comment:
Please accept our comments on the GPT Proposal. As your program is not accepting our pdf file I am resending this with the text of our 10 page letter included within this Comment Box. Please note, a hard copy was alos sent to CH2MHILL's address in Bellevue.

Proposed Scope
Gateway Pacific Terminal Environmental Impact Study
Comments submitted by Friends of Chuckanut
January 18, 2013

Introduction: Friends of Chuckanut is a not-for-profit organization of concerned local citizens dedicated to preserving the scenic beauty of Chuckanut Drive, protecting the natural resources, and enhancing recreational opportunities in the Chuckanut area of Whatcom County. Within this scope of purpose we have significant concerns regarding the proposed Gateway Pacific Terminal (GPT) export terminal at Cherry Point. Members of Friends of Chuckanut generally live within one mile, and often within 200 yards, of the existing rail corridor as it passes between the Chuckanut Mountains and Chuckanut Bay and adjacent waters. As such, members would be directly and substantially affected, in both near and long-terms, by the proposed GPT project and associated changes in rail and marine traffic.
In general, our environmental concerns relate to the presence of Critical Areas as defined by the relevant Washington statute: RCW 36.70A.050 - Guidelines to classify agriculture, forest, and mineral lands and critical areas, and shorelines.

The Chuckanut area contains many such Critical areas; agricultural lands, forest lands, wetlands, shorelines, geologically hazardous areas, and fish and wildlife habitat conservation areas. Notwithstanding the proposed mitigation measures, all of these critical attributes of the Chuckanut area will undergo significant and reasonably foreseeable adverse impacts from this project. We urge that a complete review of rail traffic, coal cargo, and vessel traffic in Puget Sound and all adjoining waters must be included in the Environmental Impact Study (EIS).
Although our focus in this submission is on the Chuckanut area, we believe the scope of the environmental impact studies should not be limited to Whatcom and Skagit Counties. Rather, it should rigorously examine the potential effects of the proposed terminal and associated transport along the entire transportation route, land and sea, from coal extraction to the ultimate purchaser and user, including human communities, environment, and natural habitats.
Although the rail and marine movement of coal through the area is of highest concern, many of our concerns apply equally to other possible cargos proposed by the project sponsors.

Comments on scope of Environmental Impact Study: Accordingly, we request and strongly urge that the scope of the county, state, and federal environmental impact studies give careful and comprehensive attention to the following:

1. Chuckanut Drive as a State designated Scenic By-way

The scenic value of this extraordinary State Highway and surrounding areas is well documented. The 21 mile Chuckanut Drive passes through a variety of landforms. In the south, the Samish farmlands, it passes through flat fields acting as a dike through this reclaimed estuarine land. In the central area, Chuckanut Mountainside, it closely hugs both the forested mountains to the east and the bay to the west with substantial changes in vertical alignment while providing grand vistas of the San Juan Islands. In the northern-most segment, Historic Fairhaven Parkway, the highway returns to level terrain. Highway SR 11 serves residents, farmers, businesses, recreational travelers, and commuters. (4) The review should consider the potential effects of the proposal on this designated Scenic By-Way.

The existing Burlington Northern Santa Fe (BNSF) rail corridor follows the same route but travels closely along the marine shoreline from where it leaves the Skagit Flats until it enters Bellingham at waters edge, thus making a large part of the project subject to review under the Shoreline Management Program SMP WCC Title 23. (3).

According to the 2004 Washington Coastal Zone Atlas maintained by the Washington Department of Ecology, coastal landslide hazard areas occur along the marine bluffs of Whatcom County. Areas of unstable slopes include portions of the coastline at Birch Point, Point Whitehorn, Cherry Point, the west side of Lummi Island, north of Neptune Beach, and other scattered areas, and including the Chuckanut Mountains.
We urge that the regulatory requirements of the existing code’s Critical Areas Ordinance CAO WCC16 and Shoreline Management Program SMP WCC 23 must be thoroughly adhered to and all relevant factors carefully reviewed. The rail corridor paralleling Chuckanut Drive that travels along the edge of Samish, Chuckanut, and Bellingham Bays must be inventoried as to the presence of Critical Areas, including, but not limited to, steep slopes, the risk of erosion from the geologically unstable sandstone slopes, and the Critical fish and wildlife corridor that provides critical habitat. (2,3).

The introduction of more trains carrying coal with the resultant pollution, noise, vibrations, and rail crossing closures of varying lengths of time will lead to predictable and reasonably foreseeable adverse impacts on the scenic quality of Chuckanut Drive as well as its function as a viable and safe highway. These potential effects should be included in the scope of the EIS.

2. Impacts of increased rail traffic through the Chuckanut Area:

The GPT project proponents have forecast a significant and sustained increase in freight rail traffic through the area. The risks and benefits, to the general public and local residents, should be carefully studied in the EIS. Among other foreseeable effects will be increased congestion on the rail lines, decreasing the availability of the lines for passenger rail and other uses. The resulting unpredictability and inconvenience for passengers is likely to encourage greater use of automobiles for inter-city travel, with the consequent environmental effects. These consequences should be included in the scope of the EIS.
The EIS should study measures proposed by the project sponsor and BSNF to mitigate the entirely foreseeable increased risk of mud and landslides along this fragile coastal rail line. The study should rigorously evaluate the effects of the projected increase in traffic and the increased vibrations of heavy coal trains on slope stability near the tracks and the highway, especially where the rail lines run directly below the highway. Please include in the EIS a study of the costs to clean up the probable resultant landslides and the impacts of such events caused by interruption of use of these transportation corridors for other, non-coal related uses. Gunite has been used to stop erosion on steep slopes on Chuckanut Drive in the past. It is unsightly, of limited long-term effectiveness, and decreases the value of the aesthetics along this scenic drive. The study should consider all options available to mitigate mud and rockslides on highway and rail lines.

Train derailments and predictable landslides all must be studied. Please include a toxicology study of the fish in these Bays. As one example, a train derailed in 1981 along Samish Bay, with rail cars in the water. Neither project proponents nor BNSF can rule out recurrence. As the project sponsors have projected an increased frequency and volume of rail traffic in the area, and as each train movement is associated with a small, but non-zero, finite probability of accident, the increased frequency will necessarily lead to an increased frequency of accidents. The study should carefully assess the probable frequency of derailment, collision, and/or accidental cargo discharges, along with the severity of the consequences of such events. We note also that such hazards cannot be limited only to rail movement, but should be applied equally to transport by ship through all adjoining waters.

As noted in the Whatcom County Shoreline Management Program, "Whatcom County's shorelines are among the most valuable of this state's natural resources. Shoreline ecosystems are diverse, dynamic, fragile and sensitive environments. Protection and management of these areas is important to the preservation of ecological functions and values of our natural environment, as well as the protection of the public health, safety and welfare of our community. Unregulated or inappropriate development on or near shorelines can result in impacts that threaten the public welfare and shoreline resources, including: pollution, erosion and sedimentation, habitat loss, flooding, or loss of property" (3) [Emphasis added]. The EIS should rigorously assess the potential consequences of the proposed project according to all these criteria.

As the railroad right of way through most of Whatcom County, and specifically the Chuckanut area, is clearly within the jurisdiction of the state Shoreline Management Act (SMA), please critically evaluate the effects of this project according to the policy guidelines of the SMA. Please include all reasonably foreseeable effects on clean water, fish, (including federally listed endangered Chinook Salmon and other threatened species of fish that inhabit this area), including, but not limited to toxicology studies. The EIS should also assess the risk of local lowland flooding caused by increases in sea level caused by burning of coal associated with this project and its contributions to general global warming.
As noted in the Whatcom County Critical Areas Ordinance, Best Available Science Review and Recommendations for Code Update, 2.4, Hazard Management and Protection Tools (1):
"One way to address geologic hazard risk management is to acknowledge that our knowledge and ability to predict some risks are often limited, and to use the best available information and apply a factor of safety.
This is a common approach in engineering, where the factor of safety is greater for less well-investigated problems or factors that are more difficult to predict. Safety factors vary with the development type, with more caution taken for critical structures where failure could be more serious. With geologic hazards the factor of safety often involves excluding some development types in some areas and defining buffers or areas where development is restricted or allowed pursuant to special engineering or other intensive and often more costly approaches.
Fundamental physical geologic processes need to be identified, and numerous secondary impacts may also need to be considered. Failure to consider the entire physical and social environment that relates to a project often results in significant public costs." (1) p.34 [Emphasis added]
Whatcom County is a geologically active area and some areas within the County are considered to be geologically hazardous. According to WAC 365-190-080 (4)(a), geologically hazardous areas include areas susceptible to erosion, landslides, earthquakes, volcanic eruptions, or other geological events.
The study should carefully follow the guidelines in State and County Codes for weighing the risks and the benefits of this project for the general public. The regulatory requirements of the existing codes WCC16.16 and WCC 23 must be thoroughly applied to this proposal, and the rail corridor along Chuckanut Drive, Samish, Chuckanut, and Bellingham Bays must be reviewed as to the presence of steep slopes, risk of erosion and the geologic hazard of unstable sandstone mountains.

3. The Chuckanut Wildlife Corridor:

Whatcom County's critical area ordinance designates the Chuckanut Wildlife Corridor as a habitat conservation area, which is identified as being of critical importance to the maintenance of certain fish, wildlife, and/or plant species. As defined by the County, this area ― which extends eastward from Chuckanut Mountain, including Lookout Mountain, Stewart Mountain, and the northern portions of Anderson Mountain and westward to Chuckanut Bay and the adjacent marine waters -- represents the last remaining place in the Puget Sound Trough where the natural land cover of the Cascades continues to the shore of Puget Sound.
Designation of fish and wildlife habitat conservation areas means the land must be managed to maintain the integrity of species in suitable habitats within their natural geographic distribution so that isolated subpopulations are not created (WAC365-190-080).
In a recent Compliance Order the Western Washington Growth Management Hearings Board, reaffirmed;
"Measures to Protect Critical Areas - Chuckanut Wildlife Area
The County is required to apply Best Available Science processes as outlined in the County's Critical Areas Ordinance and is required to assess the ecological functions and value of the wildlife area to determine the appropriate development density for wildlife. Whatcom County's Comprehensive Plan policies 11G-10 require the County to ―develop and administer regulations and incentives for no net loss of ecological functions and values of wildlife habitats." - WCC 16.16.710(a). (5). [Emphasis added]
The foreseeable risks to fish and wildlife are many, and will likely result from the different components of this project. These include increased rail traffic, types of loads in the rail cars, proximity to the water of rail lines, building of the terminal at Cherry Point, filling of wetlands, and the increase in large cargo ships in Puget Sound, the Salish Sea, Strait of Juan de Fuca, Strait of Georgia, and adjoining waters.
The study must rigorously and systematically review and describe the different toxins that already enter the air, the farmlands of Whatcom and Skagit Counties, and the water and shoreline along the railroad right of way, along with the likely increased releases associated with increased rail traffic along the corridor. Factors to be considered include copper from train brakes, metal from wear on the rails, diesel emissions from the 5-6 locomotive engines per train required to move the heavy coal trains, hydraulic oil from lines, other lubricants used to keep trains running, the loss of coal particles from coal cars, both loaded and empty, and the creosote from current and replaced railroad ties that leach into the ground and water (fresh and marine). Please include a toxicology study, including a baseline study, of the wildlife that depends on this area for habitat, and assess the likely effects of an increase in the heavy metal load birds, fish, and animals are subjected to as they graze and forage for food.
Migrant Trumpeter Swans, Snowy Owls, and geese are well known to winter in the Skagit Valley in large numbers. They forage for corn and potatoes in the fields along the railroad tracks. Many birdwatchers come to this area for the pleasure of viewing the variety of bird species attracted to this area. The EIS should study the likely effects these pollutants on the waterfowl, both resident and transitory, that depend on this region as part of the Pacific Flyway for winter habitat and food.
In the north end of Chuckanut Bay the train trestle crosses the Bay and obstructs the mouth of Chuckanut Creek, home to migrating Chum and Coho Salmon. Please study the effects on these salmon of the increased introduction of copper, diesel particulates, coal dust, grease, metals from the rails, creosote, and the noise, lights, and vibrations from the trains as the salmon migrate under this trestle. Local residents report that BNSF uses this North Chuckanut Bay trestle from time to time as a site to hold trains delayed by traffic elsewhere on the single line. This would unavoidably lead to the introduction of more toxic and harmful wastes into the Bay. The EIS should carefully assess this further potential hazard.
More generally, that trestle has altered the natural flushing functions in the north end of Chuckanut Bay (Mud Bay). Over the years, this has caused sediment deposition altering forever this area of the Bay, eliminating important eelgrass and estuarine areas. The study should assess whether the better alternative route would be to avoid the Chuckanut Bay crossing altogether.
The study should also carefully assess to what extent the proposed increase in train transits will contribute to more collisions between native animals and trains, and the resulting mortality along the length of the rail corridor.
Fish and wildlife habitat conservation areas contribute to the state's biodiversity and exist on both publicly and privately owned lands. With reference to the inventory of fish and wildlife living in the Chuckanut Wildlife corridor cited in Footnote #1, the EIS should study the likely effects of the proposed project on biodiversity resulting from limited or divided habitats, added noise and light disturbances, and toxins introduced into the environment and food sources. The study should evaluate whether this proposed project would meet the standard of 'no net loss of ecological functions' required by the Compliance Order of the Western Washington Growth Management Hearings Board cited above.

4. Recreational Opportunities:

The rail lines already limit, significantly degrade, and, in some areas, prohibit the public's right of access to many of our local State, County and City Parks (which the public pays for). In the Chuckanut area these include; Clayton Beach, Larrabee State Park Boat launching facility, and Teddy Bear Cove. The increased noise, light and vibrations inevitably diminish the experience visitors have at these parks as well as Woodstock Park and Inspiration Point further north along Chuckanut Drive. Visitors to Larrabee State Park number over I million persons per year. The trains disrupt the quality of solitude and wilderness experience that attract visitors and overnight campers.
Small boats and kayaks are frequently launched from Larrabee State Park. Collection of local shellfish is already prohibited at many of the nearby beaches due to current contamination levels. The study should assess whether the proposed increase in ship and rail traffic would increase contamination levels and possibly spread it to crustaceans and fish as well.
The number of people who use our Parks is very large and they should not be denied the value of that recreation. Please include in the EIS the effect on the general public of decreasing their access to use of Parks along our shoreline, and the feasibility of requiring project sponsors to provide pedestrian overpasses and other mitigation measures. Similarly, the effects of increased numbers of moored and anchored ships in Samish Bay on public rights of navigation and sport fisheries should be assessed. The EIS should also consider whether the proposed increase in private industrial uses of navigable waters would be compatible with the Public Trust Doctrine covering those common resources.

5. Marine Environment:

Please study the reasonably foreseeable effects -- on public health, the environment, and wildlife -- of fugitive coal dust emanating from the moving coal cars as they pass through the Chuckanut area. This assessment should include coal losses from both the full cars heading north to the proposed GPT site and the returning empty cars heading south. Through this area, the train tracks hug the shoreline, from northern Skagit County to the southern part of Whatcom County.

Coal dust is toxic and contains known carcinogens and neurotoxins. Larger fugitive coal particles sink to the sea floor where they accumulate, while the smaller particles travel farther until they either sink or wash up on shore. Creosote from railroad ties is absorbed into soil and water in the surrounding areas and goes into the ditches and through culverts into the Bay. Bottom feeders such as Dungeness crabs and shellfish will ingest the coal dust particles and the toxins would become concentrated in whatever eats them, such as seabirds and humans. Local fisheries – both sport and commercial -- will therefore be negatively affected. We believe these adverse impacts to be foreseeable and significant. They should be thoroughly covered by the EIS.

As there are already a few coal trains traveling through the Chuckanut area to the Westshore coal export terminal in British Columbia, please study the cumulative impacts of the fugitive coal dust at current levels of transport as a baseline.

Please analyze the risks (both probability and severity of consequences) and study the reasonably foreseeable impacts of a significant oil spill from ship collisions and from ships running aground in the entire sea and inland water route to and from the proposed GPT site. According to Fred Felleman, formerly of Ocean Advocates, large coal carriers are single hulled, can hold more than 2 million gallons of bunker fuel, and are difficult to maneuver, especially in areas of strong tidal currents and often strong winds.

From the Chuckanut area, many oil tankers can be seen traveling to and from the two refineries at Cherry Point and the two refineries near Anacortes. Also visible from the Chuckanut area are the usual one to five oil tankers anchored/moored South/Southwest of Vendovi Island while they wait to moor at one of the four nearby refineries. Needless to say, a significant oil/fuel spill will be devastating to the shoreline and all marine creatures. The EIS should rigorously assess the probability and severity of such events, along with likely costs of clean up. The study should critically evaluate all proposed mitigation measures and whether the project proponents would be liable for all associated costs.

The EIS should evaluate where the massive bulk coal carriers will anchor/moor while waiting for their turn at the proposed GPT pier, and the associated risks of grounding or collision. It should also evaluate the environmental effects of stationary and transiting coal carriers, oil tankers and other large ships burning heavy and polluting bunker fuel. What will be the foreseeable cumulative adverse impact of the toxins and particulates which result from the continual burning of bunker fuel by all of these ships? How will the resulting air pollution affect marine life and humans?

The EIS should critically review the potential introduction of non-native invasive plants and animals on ship hulls, in ballast water tanks, and bilges of vessels – both foreign and US-registered. The GPT project’s proposed mitigation of chemical sterilization of such water before discharge in inshore waters should be rigorously evaluated for effectiveness and potential environmental harms.

6. Noise:

There are currently more than 350 homes in the Chuckanut area. They are located at varying distances from the train tracks, but a high percentage are located very close (within 200 yards) to the tracks. This includes northern Skagit County, southern Whatcom County, and a few in Bellingham just north of the city limits. Of concern, is the decibel measurement of horn blasts, squealing wheels, and rail transit noise in general. The EIS should rigorously assess the effects on human and animal health and quality of life caused by the foreseen massive increase in train traffic due to the proposed GPT terminal.

A recent study of the Eastman Company [7] found that transportation noise has been ranked among the most significant causes of community dissatisfaction. The threshold of high annoyance is 70 percent at around 85 decibels. A rail transit horn at 50 feet away is 90 decibels, more than a jack hammer at 50 feet away. At-grade rail transit at 50 mph is 80 decibels, more than an air compressor, and both at 50 feet away.

Whatcom Docs, a group of 160 Whatcom County physicians, conducted a careful review of the data published in peer-reviewed medical journals, which show that noise exposure causes

* cardiovascular disease, including increased blood pressure, arrhythmia,
stroke, and ischemic heart disease;
* cognitive impairment in children;
* sleep disturbance and resultant fatigue, hypertension, arrhythmia, and increased rate of
accidents and injuries;
* exacerbation of mental health disorders such as depression, stress and anxiety, and
psychosis.

We support Whatcom Docs' call for a comprehensive Health Impact Assessment which includes noise exposure as well as diesel particulate matter and coal dust. As they do, we feel that the risk of negative effects on individual and public health is significant from the additional mile-and-a-half long heavy trains projected for the proposed GPT project. Please conduct a comprehensive Health Assessment as requested by Whatcom Docs.
http://www.coaltrainfacts.org/whatcom-docs-press-release

As noted above, beyond the effects on health of audible noise, we urge that the EIS evaluate the effects of sub-audible vibrations caused by increased rail traffic on health as well as adjacent landforms, house foundations, road structures, drainage culverts, and other sub-ground structures. The study should fully evaluate the effectiveness of any proposed mitigation measures, on public and private lands and structures, and determine that the costs should be borne by the project sponsors.

7. Geology and Landforms:

Chuckanut's unique geology and terrain is characterized by steep, forested sandstone slopes descending to a largely isolated marine shoreline. The proposed longer and more frequent coal trains would add to the current physical barrier created where these steep slopes meet the shoreline at the railroad tracks. The current coal trains are the heaviest and longest of today’s rail users in the area. They cause the most vibration, far exceeding that from other general freight and passenger trains.

Chuckanut Drive, US State Highway 11, has a long history of closures almost yearly due to landslides. The geology and repair history from 1974 to the present is outlined by local expert Dave Tucker (at: nwgeology.wordpress.com/the-fieldtrips/the-chuckanut-formation/chuckanut-drive-landslides/ ). Vehicle weight restrictions are often in effect, especially during heavy rains and post freeze-thaw weather cycles. The EIS should thoroughly evaluate how the mass, speed, vibration, and duration of the proposed coal rains will increase landslides and ground subsidence along Chuckanut Drive and generate the same landslide pattern on the shoreline railroad tracks below Chuckanut Drive.

Residents along this forested highway, with no secondary access for emergency evacuation or aid, already experience one or more closures north, south, or in both north and south-bound directions for a day to months during excavation and repairs. One-way lanes are common during reconstruction. Please study the reasonably foreseeable significant unavoidable adverse impacts of closures on Chuckanut Drive to health and safety of the public, preservation of homes and Larrabee State Park, work loss and school absences, tourism, and economic losses to businesses and restaurants if such closures become more frequent.

The history of landslides and closures on Chuckanut Drive is echoed by the escalation of railroad closures to freight, Sounder, and Amtrak passenger service since coal trains began hauling to Westshore coal export in B.C. Please study the rate of closures before and after this recent increase in coal train traffic and the reasonably foreseeable, significant, unavoidable adverse impact the proposed eighteen additional coal trains per day will likely cause.

Without any freeze-thaw cycles in the winter of 2012-2013 to date, 73 slides have affected rail traffic between Seattle and Everett. BNSF "officials say this is the worst season for mudslides they have seen in a generation" reported KOMO News 1/9/13 with 130 scheduled Sounder trips north of Seattle cancelled since mid-December. Only 7 days of full passenger service were available on this northward route between 12/1/12 and 1/8/13. BNSF is logging trees, fully aware that their roots stabilize the land, because slides pushed trees to precarious angles adjacent to tracks. Please study if this is sustainable long term mitigation for existing train traffic, as well as the projected increase due to the proposed GPT project.

8. Economic Impacts:

The EIS should carefully assess questions arising from the proposed increases in rail and ship traffic such as:
· What mitigations will be in place for the significant, foreseeable unavoidable adverse impacts if coal train traffic increases in mass, velocity, vibration, length and duration to GPT project levels?
· What is the economic impact of the current loss of passenger service and commercial/agriculture freight service?
· What will be the economic impact if landslides proportionately escalate with coal train traffic at project estimates?
· Will ongoing excessive vibration from massive coal loads trigger more landslides and land subsidence?
· Will this route be irreparably damaged for any and all rail traffic?
· What will be the economic impact to all other commercial/agriculture freight, tourism, and passenger service?
· Will it cause additional structural damage to the current infrastructure of existing businesses, local and state parks and private residences with damage to roads, foundations, wells, water lines, septic systems, utility poles, and culverts?
· Will a similar fate extend to other areas such as the Eldridge neighborhood and Boulevard Park?
· Will accumulated damage cause failure of the rail connection between Seattle and Bellingham, as well as the ultimate failure of parks, homes, and businesses along the Chuckanut corridor?
· What assurance is there that any proposed mitigation measures will be effective over the long-term?

As one example of potential effects, both on local businesses and human health and the environment, the EIS should assess the consequences of a derailment and cargo spill (including arsenic and heavy metals) on the commercial shellfish operations of Taylors Shellfish Farms along Chuckanut Drive on the Samish Flats.

9. Safety:

Train derailment is a natural consequence of many landslides. For 12/19/12 video of landslide derailing freight train south of Everett, WA see www.katu.com/news/local/Caught-on-Video-Landslide-derails-Wash-freight-train. US train derailment has increased from 2 in 2008, 14 in 2009, 12 in 2010, 16 in 2011, and to 17 in 2012. Please study the causes of this rapid escalation in derailments. To what degree are derailments caused by damage to tracks and track substructures via mass, weight, speed, vibration, duration and accumulated effects of vastly increased coal train traffic? To what extent does particulate matter contribute to derailments due to coal dust, oils, copper and other metals deposited by the train engines, braking, and other systems? What are the economic impacts on the communities where landslides occur? What are the health and safety risks to humans, wildlife, wetlands, marine ecology and species, parks, homes, and businesses when coal cars spew their contents across steep forested slopes and sensitive shorelines? Bear in mind in this study that GPT coal trains at full capacity are projected to haul 70+% more than all current rail freight to this area and that there would be a 200% increase in all current freight via the five proposed projects.

Fires occur with derailments due to sparks, combustible loads, and the torches used to untangle and clean up derailed debris. Forested steep slopes, inaccessible marine shorelines, and brisk winds make the Chuckanut corridor highly vulnerable to uncontrollable wild fires. Risk increases with each additional rail trip. Frequent 1.5 mile long trains loaded with combustible coal and coal dust radically increase the threat of devastating fire in the area, especially during dry summer months (as occurred in summer 2011 due to BNSF’s negligent right of way maintenance and a passing train). The Chuckanut area fire department is minimal, requires reinforcement from city fire departments 8 miles north, and can access only small portions of shoreline railroad tracks to fight fire due to the steep slopes. The EIS should evaluate mitigations by BNSF and the project sponsors provide to protect public and private property. For example, will GPT station fire boats along these inaccessible tracks to protect passengers on Chuckanut Drive, residents and homes, restaurants, and Larrabee State Park and tourists? What protection and restitution from project sponsors, BNSF, and governing and permitting agencies are available to citizens especially if they suffer predictable losses?

Trains blocking grade level crossings throughout Chuckanut residential areas, Larrabee State Park, and Larrabee Park Boat Launch present significant foreseeable adverse impacts. Tourism study [8] shows 1/4 of all 1st time visitors to Bellingham tour Larabee State Park, which is bisected by the railroad track. These ground level crossings had 4 unannounced blockage closures for 4+ hours, 2 hours, 45 minutes, and 20 minutes, respectively, during a four month period in 2012. With no secondary access, these events denied 52 homes of all paramedic/fire/police response, emergency evacuation, school bus, or employment commute – all without compensation. During the same four month period, one resident suffered a heart attack requiring the paramedic ambulance. In the same period, local residents rescued 3 boating accident victims, one of whom required emergency paramedic ambulance for lifesaving hypothermia treatment.

Blocked rail crossings caused by increased train traffic are increasing, threatening health and safety of residents and tourists. Please study the cause of the rapid increase in blockages and all contributing factors to the blockages, including but not limited to earthquakes, landslides, fires, derailment from accumulated damage to rails and surrounding fragile geology, and resultant maintenance and repair. The EIS should carefully consider the economic impacts to tourism, residents' work losses, and school absences.

Please include a review of Whatcom County Codes 20.88.010, 20.88.130, and 20.88.140 and apply them to the EIS and permit process regarding overpass infrastructures along the Chuckanut corridor. Consider also how the applicant will be required to address off-site infrastructure for all environmental and uncompensated costs before issuing the Final Scoping Document. The study should specifically evaluate the question of whether ground level crossing infrastructure overpasses should be required mitigation and whether all related costs will be borne by the applicant, rather than the public, as specified in the relevant codes.


As concerned citizens, likely to be directly affected by the proposed GPT project, we expect a thorough, systematic, and scientific review of the risks posed to the local, state, national, and global environment. We look forward to public answers to the questions posed here.


Respectfully submitted,

Laura Leigh Brakke, President
For the Board of Directors of Friends of Chuckanut

By reference we cite the following documents:

1.Whatcom County Critical Areas Ordinance
Best Available Science Review and Recommendations for Code Update
http://www.co.whatcom.wa.us/pds/naturalresources/criticalareas/pdf/bas_final_20050520.pdf

2. Whatcom County Title 16 Environment - Chapter 16 CRITICAL AREAS
http://www.codepublishing.com/wa/whatcomcounty/

3. Whatcom County Shoreline Management Program Title 23
http://www.codepublishing.com/wa/whatcomcounty/

4. Chuckanut Drive State Route 11 Corridor Management Plan
http://www.wsdot.wa.gov/NR/rdonlyres/1024829C-9D40-442C-8EFC-1B4CE3A273AA/0/ChuckanuatDriveCMP.pdf

5. Compliance Order and Order Following Remand on Issue of LAMIRDS Case Nos. 11-2-0010c and 05-2-0013 January 4, 2013
http://blogs.bellinghamherald.com/politics/wp-content/uploads//2013/01/11-2-0010c-05-2-0013-compliance-order-and-order-following-remand.pdf

6. Washington State GMA Critical areas - Designation and protection - Best available science to be used.
http://apps.leg.wa.gov/rcw/default.aspx?cite=36.70A.172

7. Paul Zemtseff; The Eastman Company, 925 North 130th St, Seattle, WA 98133; Tel.: 206-363-6611; File No. 2036.1; October 30, 2012

8. Michael Lilliquist, City Council Member, City of Bellingham; January 8, 2013 Community Wise Bellingham Economic Impacts Forum

9. BNSF at: http://domino.bnsf.com/website/updates.nsf/service-coal?OpenView&Count=999

Gregory Sotir - Cully Association of Neighbors (Portland, OR.) (#4797)

Date Submitted: 12/13/12
Comment:
Cully Association of Neighbors ({Portland, OR.)
Statement and Resolution on Coal Transport via the Columbia River and along railways on both sides of the Columbia River (Oregon and Washington.)

Whereas, the Cully Association of Neighbors seeks to enhance the physical and social livability in the neighborhood of the Cully neighborhood; and

Whereas, the residents of Cully express concern at the changes to our climate that derive from combustion of coal and coal related products; and

Whereas, the combustion of coal and coal related products will create mercury compounds that will deposit themselves in Oregon; and

Whereas, the combustion of coal and coal related products accelerates ocean acidification and will impact marine life that Cully residents may use for sustenance; and

Whereas, in 2009 the City of Portland approved the Climate Action Plan, with a goal of achieving a 40 percent reduction in carbon emissions by 2030 and an 80 percent reduction by 2050; and

Whereas, City of Portland opposes coal export on trains through its jurisdiction until a complete National Environmental Policy Act process, including an area-wide Environmental Impact Statement is completed; and

Whereas, coal transport via barge, rail and train will increase noise and diesel pollution, release toxic elements such as lead, cadmium, and other contaminants, and carcinogens, into the local environment, neighborhoods, homes, and gardens near the rail lines, have negative health impacts on residents of Cully, particularly children and the elderly; and

Whereas, increased coal rail traffic through Cully will obstruct local roads, causing air pollution, loss of property values, delays of emergency vehicles, commuters, business and domestic traffic in residential communities and business districts; and

Whereas, the increase in coal transport via rail will bisect and negatively affect the quality of life and recreational activities at Colwood Golf Course site and Thomas Cully Park; and

Whereas, the negative impacts of shipping coal by barge on the Columbia River will have similar effects on the Columbia River as those associated with rail; and

Now therefore, be it resolved that the Cully Association of Neighbors opposes coal transport through the Cully neighborhood, the City of Portland, along the Columbia River, and through the states of Oregon and Washington, until the process of a programmatic, comprehensive and area-wide Environmental Impact Statement, is completed; and

Be it further resolved that the Cully Association of Neighbors urge the coal transport and rail companies to respect the wishes of the local community regarding coal transport through the Cully neighborhood area and the City of Portland.

Gretchen Starke (#9908)

Date Submitted: 01/20/2013
Location: Vancouver, WA
Comment:
Co-Lead Agencies
Proposed Gateway Pacific Terminal and Custer Spur Projects

January 20, 2013

To whom It May Concern:

The Vancouver Audubon Society promotes the conservation of wildlife and wildlife habitat. We are concerned with both local and global threats to wildlife and birds. Thus, we are alarmed by the proposal to ship the coal mined in Montana and Wyoming to Asia. We are further alarmed by the suggestion that the co-lead agencies that will prepare the Environmental Impact Statement (EIS) would consider only the local impacts of this proposal. The environmental impacts of exporting coal to Asia to be burned are much greater than those that will be felt immediately around the Gateway Pacific Terminal development, or even along the railway from Montana to Washington. The ultimate impacts will be felt globally. Below are the issues and arguments that we feel must be addressed in an EIS.

1) While there are many environmental impacts that would result should this proposal be implemented, the most serious and far-reaching impact would be the carbon emissions that would be released into the atmosphere should all that coal be burned.
2) To avoid the worst effects of climate change, the nations of the world agreed at the Copenhagen conference that the highest average temperature the world should be allowed to increase is 2o C. Many climatologists and other scientists think that even that temperature may be pushing it.
3) The average world temperature has increased .08o. The effects of this warming are happening faster than climate scientists had at first thought. These effects have included an increase in drought, flooding, forest fires. While it is true that no one event can be blamed on climate change, there is a pattern that does signal that climate change is occurring. And it hasn't been fun.
4) It is predicted that in the Pacific NW we will have wetter and warmer winters and hotter and dryer summers. Snowpack will be less. The effects on our salmon and our Douglas fir forests will be devastating. The City of Seattle is now considering the effects of sea rise. The projections have much of the city underwater at high tide.
5) To bump up against the limit of 2o C, we need to increase the world's temperature only 1.2o C more.
6) The estimated numbers of gigatons of carbon that can be put into the atmosphere and remain below 2o C, is 565. The EIS should address the issue of the estimated amount of carbon that is in the coal that would be shipped through our communities and then to China, there to be sent into the atmosphere. The coal companies should be able to help in that calculation.
7) An environmental impact statement should examine all adverse impacts that might be reasonably expected to occur. It is obvious that sending the carbon in that coal into the atmosphere would cause adverse impacts -- here and worldwide.
8) When a governmental agency or private company prepares an environmental review document, whether an Environmental Assessment, Finding of No Environmental Impact, or full-blown EIS, it should be on the entire project -- not on just a piece of it. To break up a project into pieces, whether in time or in space, is called segmentation and is to be strongly discouraged. To do this allows a large project to escape adequate environmental review. After all, each small piece by itself may not pose much of an environmental risk. But the entire project would.
9) It doesn't matter if different companies or agencies develop different pieces of a project, the entire project should be analyzed in a programmatic process. The Gateway Pacific Terminal project is only one of five or six coal export facilities that have been proposed. All these proposals were made in about the same time. The real issue is not about one particular port facility, it is about mining, transporting, and, especially, burning coal.
10) The proposal to export coal to China, if implemented, would have a profound impact on the environment. The impacts start in Montana and Wyoming with the extraction of the coal, continues as the coal is transported through our communities with the impacts of the huge trains and potential coal dust blowing from the trains, further continues at the ports themselves. Finally, when the coal reaches its destination and is burned, there are the worst impacts. The burning creates a number of pollutants that will blow back across the Pacific for us to breathe into our lungs. And the final environmental insult -- the injection of that carbon into the atmosphere. The Corps must address all -- all these issues in a programmatic EIS. To fail to do so would be irresponsible.
11) As for the argument that if we don't sell coal to China, someone else will, is it wise to buy an alcoholic a bottle of whiskey? Making it more difficult for China to obtain coal would further encourage China to develop renewable sources of energy.
We thank you for the opportunity to comment on this vital issue.

Sincerely,

Gretchen Starke
Conservation Chair,
Vancouver Audubon Society

308 NE 124th Ave
Vancouver, Washington 98684

(360) 892-8617

Heather Trim (Futurewise) (#12198)

Date Submitted: 01/22/13
Location: Seattle, WA
Comment:
To the Lead Agencies,

Thank you for accepting Futurewise’s comments on the scoping for the proposed GPT/BNSF Custer Spur EIS.

Sincerely,

Heather




Heather Trim
Futurewise
Director of Science and Policy
----------------------------------------
email: heather@futurewise.org
web: www.futurewise.org
----------------------------------------
816 Second Avenue, Suite 200
Seattle, WA 98104-1535
o 206 343-0681 X115
c 206 351-2898
Attached Files:

Holly O'Neil (Evergreen Land Trust Association) (#12199)

Date Submitted: 01/22/13
Location: Deming, WA
Comment:
January 22, 2012

GPT/Custer Spur EIS
c/o CH2M Hill
1100 112th Avenue NE Suite 400
Bellevue WA 98004

The Evergreen Land Trust holds property in Whatcom County, and we are formally requesting a thorough analysis of the economic, social, health and environmental costs, direct, indirect and cumulative, that may impact our local economy, relative to this project.

We are further requesting that this analysis be done in the context of current data related to global climate change, available to Whatcom County staff and to CH2M Hill staff.

We further request that alternative economic development opportunities be identified and evaluated, so that these can be assessed in relation to the proposed project.

Lastly, we request that you mitigate the risk posed to the local economy by not allowing any development or activity at the site.

Thank you,

Holly O’Neil
Project Manager, Evergreen Land Trust Association
3231 Hillside Road
Deming, WA 98244
360-303-3217
Attached Files:

Howard Garrett (#2872)

Date Submitted: 11/12/12
Comment:
My name is Howard Garrett. As co-founder and president of Orca Network based on Whidbey Island, dedicated to raising awareness of the whales of the Pacific Northwest, and the importance of providing them healthy and safe habitats.

We urge a no-action alternative on the Pacific Gateway coal terminal proposal. Coal export plans are stirring up opposition across the Northwest for many, many very good reasons.

Cheap coal under public land in the Powder River Basin in Montana and Wyoming has been sold to China without public debate. To get the coal to Asia they need to haul it by train to west coast terminals and load it on ships. Two potential sites in Washington—Cherry Point, north of Bellingham, and Longview on the Columbia River—are currently in the most active planning stages.

On September 22 the Lummi Nation announced they were opposed to the proposed terminal at Cherry Point. Oregon Governor Kitzhaber has also asked for an environmental review, and 57 Indian Tribes from around the Northwest have called for a full environmental analysis.

Approval of this plan will allow strip-mining coal in the American west, loading it on mile-long, 120-car trains that release tons of dust along 1100 miles of track to Cherry Point to be piled into about 400 bulk cargo ships (three-and-a-half football fields long, with a seven-story building below the waterline) per year to maneuver the Salish Sea in heavy ship traffic to be burned into electricity and greenhouse gases that add to the blanket of carbon dioxide now rapidly warming our planet and further degrading our climate? What could go wrong?

So much could go wrong that it's hard to pick out only one or two likely calamities from this abominable scheme. What about the scoters that depend on the unique Cherry Point herring that spawn in April and May, when scoters need to fatten up for their trip to Canada's interior.

The numbers of coal cargo ships that this terminal would require, would add more than one per day. Bear in mind that coal is a very cheap commodity and it's very poorly regulated, so there's not a lot of investment made in coal transport ships or their crews. They're less valuable than most other ships from the industry's viewpoint. They tend to be shaky old cargo ships with cheap labor operating them, loaded with heavy bunker fuel to cross the Pacific.

If the industry gets their way, as they usually do, these coal cargo ships will not only be weaving and dodging around the dozens of container ships, barges, and tankers etc. already going in and out of ports from Tacoma to Vancouver, they'll also have to avoid hitting at least as many increased tankers carrying oil boiled out of tar sands in Alberta, known as bitumen loaded up from pipelines in Vancouver.

As we learned from the Exxon Valdez, an oil spill in these waters could kill many of the orcas who live here and devastate the salmon they depend on, that we are working so hard to restore to health.

This EIS should examine:

One, how much would the cumulative effects of large vessel traffic increase the risk of an oil spill in these waters?

Two, how likely is it that our oil spill response system would be able to protect our shores and waters when a major spill occurs. Remember the Exxon Valdez?

Three, even before a spill happens, how much would the increase in large vessel traffic affect the health of endangered Southern resident orcas — considering the increasing underwater noise and overall traffic in their habitat?

And fourth, please examine all measures the shipping industry must be required to take to minimize the risk of an oil spill and to maximize timely response and recovery of oil should a spill occur.

If you cannot ensure the safety of our climate, our shorelines, our marine ecosystem, our whales and our salmon, don’t permit this project.

Thank you for the opportunity to comment on this plan.

Howard Garrett
Orca Network
info@orcanetwork.org
www.orcanetwork.org
1-866-ORCANET

Orca Network - Connecting whales and people in the Pacific Northwest
Orca Network is dedicated to raising awareness about the whales of the Pacific Northwest,
and the importance of providing them healthy and safe habitats.

Projects include the Whale Sighting Network and Education Programs, the Free Lolita Campaign,
and the Central Puget Sound Marine Mammal Stranding Network.

Inye Wokoma (#9109)

Date Submitted: 01/18/2013
Location: Seattle, WA
Comment:
January 17, 2013

Combined NEPA/SEPA Review Teams
Proposed Gateway Pacific Terminal/Custer Spur
RE: Scoping Comment Impact


Dear NEPA/SEPA Reviewers,

We at the Community Coalition for Environmental Justice (CCEJ), GotGreen, and the Wilderness Inner-city Leadership Development (WILD) Program strongly request that the NEPA/SEPA EIS for the proposed Gateway Pacific Terminal include an environmental justice and adverse health impact assessments in its environmental impact statement for the proposed Gateway Pacific Terminal/Custer Spur coal to China project.

Our respective missions call for environmental justice advocacy. The mission of CCEJ is to “achieve environmental and economic justice in low income communities of color”. Got Green's mission includes “ensuring that the voices of low income communities and communities of color are included on issues related to the green economy”. WILD’s mission is to provide opportunities for students to lead Chinatown International District (CID) neighborhood projects related to environmental justice, empowering action through environmental education and intergenerational learning.

Specifically, it is our understanding that the Pacific International Terminals’ proposed Gateway Pacific marine terminal at Cherry Point Whatcom County would provide storage and handling for the export and import of up to 54 million metric tons per year of commodities, primarily coal from the Powder River Basic of Wyoming and Montana. This would mean that 9 full northbound long trains or 18 train trips a day with possibly 1.5 mile long trains would run through the tunnel adjacent to Seattle’s Chinatown International District (CID) and that the number of trains would increase as business expands.

This proposal presents serious environmental justice problems for the CID with lasting effects. Running 18 plus coal trains a day would exacerbate the air quality of the CID, which already has the poorest air quality in the City of Seattle. It is likely to lead to significant public health impacts on the vulnerable youth, elderly, immigrants and the
January 17, 2013
NEPA/SEPA Review
Page 2 of 2


poor living at the CID as well as the numerous visitors who come to the CID to shop, eat and play. They are likely to suffer respiratory health impacts from diesel particulate matter associated with increased train traffic/coal dust, the health effects associated with mercury and other heavy metal pollution from open-pit coal trains, and acid rain degradation of their living conditions in low income senior housing located in rehabilitated historic buildings. The likely ravages to the CID will also discourage visitors from coming to the CID and kill the businesses, shops and restaurants present in the historic community.

We ask that the NEPA/SEPA Review:

• Include an environmental justice assessment and a health impact assessment on the CID neighborhood where vulnerable elderly, poor and immigrant populations live, work and visit, and
• Engage our organizations as partners in this endeavor.

We appreciate the opportunity to provide input into the EIS review scope. We look forward to the inclusion of our concerns in the NEPA/SEPA review process and partnering with you on the assessment effort. Thank you.

Sincerely,

Alice Park
CCEJ Board Chair
alnampark@yahoo.com CCEJ Facebook

Inye Wokoma
Board Chair, Got Green
PO Box 18794
Seattle, WA 98118

Hyeok Kim
Director Interim CDA

Cc: Bernie Matsuno, Dept. of Neighborhoods
Running Grass, Environmental Justice, Dept. of Environmental Protection Agency
Attached Files:

James Garrett (International Union of Operating Engineers) (#7518)

Date Submitted: 01/10/13
Location: Spokane, WA
Comment:
see attached
Attached Image:

Jayne Frueudenberger (#5582)

Date Submitted: 12/30/2012
Location: Bellingham, WA
Comment:
Comment on Health Impacts
The League of Women Voters of Bellingham-Whatcom County
Jayne Freudenberger Co-president

The League of Women Voters of Bellingham Whatcom County believes we must consider health impacts of the transportation of coal. We request a programmatic EIS which would study the cumulative impacts on the health of citizens from the expected increase in rail transportation of coal from the Powder River Basin to all the proposed West Coast terminals.

For the Gateway Pacific Terminal’s EIS alone, we support the over 200 physicians from our county who have called for studies on the health impacts from the huge amount of coal dust that will be lost from the 18 (150 car) coal trains (full and empty) which will service GPT, as well as the release of increased diesel particulates from at least 4 diesel engines per train. Burlington Northern estimates over 500 lbs. of fugitive coal dust are lost from each car as it travels from the Powder River Basin to the coast. Dust from coal and diesel engines contain toxic substances including mercury which contribute to respiratory diseases such as asthma, emphysema and other chronic pulmonary diseases. 1

We are also asking you to study the effect of noise on people’s sleep which leads to increased health problems such as depression, high blood pressure and cognitive impairment in children.

We need a cost/benefit analysis about how the train traffic will impact our air quality and our health system’s ability to deal with our citizen’s increased risks for serious medical problems as a result of the degradation of air quality.

Related to health costs are the delayed emergency response times that will occur when 150 car trains block vehicle crossings in the many towns that are divided by the rail tracks. How many deaths and/or serious injuries will be caused when emergency response is delayed? If the only way to mitigate this impact is to build over passes the costs should be borne by the proponents of the project not by individual municipalities or the state.

Currently over 900 pedestrian accidents and over 3000 collisions occur with rail crossings across the nation each year. 2 We should study how the addition of these super trains might increase this figure.


1 Whatcom Docs position paper and appendices coaltrainfacts.org

2 “Heavy Traffic Ahead” Western Organization of Resource Councils July 2011

Jeff Juel (#11920)

Date Submitted: 01/22/2013
Location: Spokane, WA
Comment:
January 22, 2013


Reference: Docket number COE-2012-0016: Proposed Gateway Pacific Terminal coal export proposal draft EIS scoping comments.
(Submitted to: http://www.eisgatewaypacificwa.gov/get-involved/comment)


Dear Army Corps of Engineers, Department of Ecology and Whatcom County Council:

The Lands Council strongly opposes the construction of a coal export terminal at Cherry Point, Washington, the transportation of strip-mined coal from Montana and Wyoming on trains and ships throughout the Northwest, and all other connected actions involving the transportation and combustion of the coal.

The Lands Council is a non-profit environmental organization with a mission to preserve and revitalize our Inland Northwest forests, water, and wildlife through advocacy, education, effective action, and community engagement. The Lands Council has approximately 1,500 members who live across the Northwest. The forests, water, and wildlife, our members, and all human and natural communities are threatened by the proposal now on the table.

The proposal illustrates an emerging scientific and philosophical consensus which has become especially pertinent in this era of globalization: Everything Is Connected to Everything Else. The impacts of approving this proposal would be local, regional, national, and global.

At the sites where the coal is mined there would be pollution of air and water, essentially the permanent loss of wildlife habitat, the productivity of the land, and the long-term impacts on lifestyles and local economies.

All along the railroad corridors disruption of traffic would occur, and the resultant increased risks to human safety. There would also be air pollution from emission of diesel exhaust and coal dust. There would also be the increased noise of the trains, and the risk to the environment from accidents and coal spills.

At the site of the proposed terminal there would be damage to aquatic ecosystems and fishing grounds, and the long-term impacts on lifestyles and the local economy.

In Puget Sound and the Pacific Ocean we would see increased risk to marine ecosystems from accidents and spills.

At the sites in Asia where the coal would be offloaded, and along the transportation corridors to the coal-burning plants, there would be similar impacts as we describe above for the Northwest. Additionally, there would be worsening health effects on people in China, as shown in recent media coverage of poor air quality associated with emissions from coal burning and other sources of air pollution, which are poorly regulated in that nation.

The emissions of coal-burning plants include mercury, which transported across oceans through the atmosphere poison water and fish even here in the Northwest. A United Nations report shows the amount of mercury in the world’s oceans has doubled in the past century. And global emissions are rising. An increase equivalent to about one-quarter of the 2005 human-caused mercury emissions, or about 500 tons per year, is expected by 2020 if there are no major changes in economic trends or emissions, according to a 2011 report by the Arctic Monitoring and Assessment Programme.

Asia is already by far the largest source of new mercury emissions, and coal-burning power plants are the top contributor. Exposure to high levels of mercury, often from consumption of fish and other seafood, can damage developing brains, reducing children’s IQs. Mercury has also been linked to cardiovascular effects in some adults and children. Scientists warn that ongoing emissions are more of a threat to food webs than the mercury already in the environment. University of Wisconsin researchers recently found that mercury added to a lake reached top predators faster than the mercury that already existed in their environment.

Another Arctic Monitoring and Assessment Programme report finds that impacts of ice loss include reduction in the Earth’s albedo; a positive feedback that leads to further global warming. Burning coal would increase particulate pollution, which combined with solar energy causes more heating of the surface of glaciers and snow from dark particulate deposit; and when added to already higher temperatures leads directly to the rise of sea level, which has already impacted human and biological communities around the world.

But those impacts may pale in comparison to the increased damage to the atmosphere that would accrue from burning the coal. There is no longer a scientific debate on the issue: human-caused climate change is real. We face an increasing urgency for everyone to do their part to reduce carbon dioxide (CO2) emissions.

The additional burning of diesel and coal that this proposal would facilitate would increase CO2 emissions, adding to the threats to the Earth’s biosphere that are already playing out in ways that affect humans, economies, and ecosystems. In an era when human population is increasing and the need to address the long-term sustainability of our use of natural resources is critical, the impacts on ecosystems of climate change makes taking steps to address sustainability even more challenging.

Rising CO2 levels also cause ocean acidification. In November of 2012, Governor Gregoire released an Executive Order initiating action on ocean acidification. The Executive Order directs the Office of the Governor and the cabinet agencies that report to the Governor to advocate for reductions in emissions of carbon dioxide at a global, national, and regional level.

Climate change is believed to have already led to the increase in frequency of weather events such as Superstorm Sandy and Hurricane Katrina, and unless we urgently address the human actions that increase greenhouse gas emissions, such storms will likely further increase in frequency and intensity.

This letter only begins to mention all the connected and cumulative actions that relate to the proposal to construct a coal export terminal at Cherry Point, Washington, and transport strip-mined coal from Montana and Wyoming on trains and ships throughout the Northwest. There are also currently at least four other coal export proposals that, with this one, would transport as much as 150 million tons through the Northwest. We urge the Army Corps of Engineers to conduct an area-wide Environmental Impact Statement (EIS) to assess all the cumulative and connected impact of these proposals.

The EIS must consider potential natural resource impacts associated with the construction and expansion of all the shipping terminals along the west coast (Oregon, Washington, British Columbia and possibly California), which would not be adequately addressed through the regulatory processes for each individual terminal.

The EIS study area should encompass all of the potential rail routes under consideration for transport of coal from the sources of origin in Montana and Wyoming to the proposed Gateway Pacific Terminal at Cherry Point.

At hearings held for this proposal, we’ve heard it stated that requiring this EIS to address all these connected and cumulative actions and impacts would unnecessarily create a negative precedent. On the contrary, we believe that failing to do our part in recognizing how all these things are connected on a global scale would be a symptom of a vast dysfunction of human institutions, which cannot be tolerated if humans are to persist on the planet.

Applicable law allows for consideration of effects that may occur outside the U.S. From SEPA: “(A) lead agency shall not limit its consideration of a proposal's impacts only to those aspects within its jurisdiction, including local or state boundaries.” [Wash. Admin. Code sec. 197-11-060(4)(b).] SEPA recognizes the world-wide scope of environmental issues. SEPA considers “each person’s” right to a “healthful environment” to be “fundamental and inalienable.” Rev. Code Wash. Sec. 43.21C.020(3) “(r)ecognize(s) the worldwide and long-range character of environmental problems” and directs agencies, “where consistent with state policy, (to) lend appropriate support to initiatives, resolutions, and programs designed to maximize international cooperation in anticipating and preventing a decline in the quality of the world environment… .” [RCW 43.21C.030(1)(f)].

The Environmental Protection Agency has recognized the materials emitted from combustion, including CO2, as pollutants which threaten human health and the environment, and has initiated CO2 emissions regulation. The New Source Performance Standards state that any new coal-fired power plant in the U.S. must meet a very tight standard for low CO2 emissions. A new export terminal built for the purpose of supplying coal to be burned in a manner that does not meet these new standards would undermine the entire purpose of the NSPS standards.

Your agencies must broadly consider the public interest in considering this proposal, because the project must use government and public resources. The effect of greenhouse gas emissions is relevant to the public interest, because climate change and ocean acidification represent a very serious threat to our environment and the livability of our planet.

Finally, the U.S. is a signatory to the Copenhagen Climate Accord, which agrees in concept to large worldwide reductions in greenhouse gas emissions. Large new coal export schemes are clearly inconsistent with the intent of the Accord.


In sum, this proposal risks harming us in countless ways. These include increasing congestion and noise with more coal train traffic, polluting our air and local waterways, harming existing businesses, delaying emergency responders, damaging aquatic ecosystems and fishing grounds at the terminal site, escalating climate change, ocean acidification, increasing tanker traffic, and creating the potential for serious shipping accidents. We urge you to consider all these impacts in the scope of the Environmental Impact Statement.

Thank you for considering our comments.

Sincerely,

Jeff Juel
The Lands Council
25 W. Main Ave. Ste. 222
Spokane, WA 99201

Note: comments also attached in pdf form.
Attached Files:

Jeff Margolis (Safeguard the Southfork) (#12186)

Date Submitted: 01/21/13
Location: Deming, WA
Comment:
Safeguard the Southfork,
POB 262 Deming WA 98244

GP GPT/Custer Spur EIS c/o Ch2M Hill
1100 112th Avenue NE, Suite 400 Bellevue, WA 98004
January 21, 2013





Safeguard the Southfork is a legal non-profit organization in the State of Washington. We are organized around a shared commitment to protecting family farms and businesses, healthy air and water, the sustainment of our natural resources, and the unique quality of life in the South Fork Valley in Whatcom County, Washington. We advocate on behalf of the ability of those living here to shape the public policies that affect our land, our air, our water, and our lives.
The BNSF Railroad currently owns the Farmland Route that branches in Burlington, WA northeast through Sedro Woolley, the South Fork Valley, Nooksack, Everson through the Sumas. There has also been consideration of an east/west rail expansion proposal connecting the rail like through Lynden to Custer (see: Whatcom County Comprehensive Plan’s rail map ) BNSF can choose to use or further develop this route at any time, for additional freight or for coal trains going to or returning empty from Cherry Point. In addition to requesting that all existing rail lines and potential rail expansion projects tin Whatcom County be adequately studied in the Environmental Impact Statement, consider the following impacts on agricultural and rural communities:

TRAIN IMPACTS to consider on the FARMLAND ROUTE:
NOISE and impacts on sleep cycles of residents, children, the elderly, livestock, as well as cumulative effects of 24/7 whistles;
AGRICULTURAL risks, including vibration and noise on livestock and dairy production, soil and crop pollution, crop damage, loss and division of farmland, sense of place, heritage;
CONSTRUCTION upgrades, spurs, links, bridges, etc. and the impacts of that construction on traffic, the environment, and the transformative impacts upon our communities and sense of place, etc. Also, expense to TAXPAYERS;
DERAILMENTS and increased risks of derailments associated with wet soils, landslides, and seismic activity areas, as well as home safety close to the tracks and ecological impacts of derailments.
TRAFFIC and the potential for ACCIDENTS at unsafe rural crossings, or with increasing stops on winding roads and/or attempts for cars or trucks to “beat” delays (naming specific crossings);
WAIT TIMES for trains to cross (or if a train derails) and impacts on first responders, school bus routing, and increased commute times, etc.;
COMMUNITY HEALTH risks associated with diesel particulates (asthma, lung, and heart), loss of coal in transport and coal dust or runoff from rain— either airborne or after settling on crops and in water ways.
SCHOOLS and proximity of the schools to the tracks and exposure of children to noise, health risks, and safety issues.
WATERWAYS and FISH and their proximity to the tracks and risks to habitats from rail line pollution and coal dust and runoff; and
Anything else (and PLEASE let us know your concerns)
TERMINAL IMPACTS include: fugitive coal dust, ecosystem destruction, aquifer degradation, ecosystem destruction, and impacts on existing natural resource industries such as fishing, farming, and tourism.
Please consider these items in the GPT EIS.
Thank you,
Jeff Margolis
Co-Chair SGSF
Nicole Brown
Co-Chair SGSF

Jeffrey Johnson (AFL-CIO) (#10227)

Date Submitted: 01/21/2013
Location: Seattle, WA
Comment:
January 21, 2013

Gateway Pacific Terminal/Custer Spur EIS
c/o CH2M HILL
1100 112th Avenue NE, Suite 400
Bellevue, WA 98004

To Whom It May Concern:

Please find below the comments from affiliate representatives of the more than 425,000 working families represented by the Washington State Labor Council, AFL-CIO and its more than 500 affiliated unions, regarding the Gateway Pacific Terminal/Custer Spur EIS.

We appreciate the opportunity to present comments to you regarding the Gateway Pacific Terminal/Custer Spur EIS. While there are multiple proposals for moving commodities overseas through seaport development, we have only endorsed a single proposal: Gateway Pacific Terminal. We are committed to a design of the highest and best science. We intend to promote the safest design for the workers and community in which the project resides. We support mitigation and remedies as outlined below that will lessen community risk, lessen worker risk, and lessen risk to our environment.

Having participated in all of the public hearings, we ask you to resist being drawn in to issues that we believe are distractions and beyond the scope of the EIS. One such distraction is the coal dust concern. We find no reported health claims from any state or federal agency regarding coal dust from trains in Washington State. Further surfactants cover the coal on train cars for the purpose of suppressing dust, the workers who have moved the trains for the past 25 years have not suffered injury, and the Gateway Pacific Terminal project proposes covered unloading areas and covered conveyors. Similarly we find the suggestion of studying diesel particulates from Wyoming to China to be a distraction beyond the scope of the EIS and intended to distort public perception.

Finally, we believe that suggestions to study grade crossings and rail improvements beyond the Custer Spur and, perhaps, Whatcom County, go beyond the scope of this EIS, though certainly within the purview of other entities, should they chose to enter negotiations with a common carrier.

We do, however, want indigenous tribes’ cultural claims to be reviewed and considered. Where there are legitimate claims, they need to be addressed. We all have significant interest in preserving healthy fisheries.

Respectfully, we would like to draw your attention to several issues relating to the industrial site, and the EIS process, and what we believe are important areas to study in the marine environment, including safety and incident response, as well as the socio-economic environment of the community where the project proposes to locate. We believe the EIS review should include:
1. We would encourage you to make a determination that a site-specific EIS is the appropriate way forward. The Army Corp of Engineers, the WA Public Ports Council, local development entities and private individuals have all written on this subject in a very comprehensive way. While comparisons abound, just one recent comparison of a scoping process and EIS within sixty miles of Gateway involved the additional rail and necessary transfer infrastructure for the Tesoro Refinery in Anacortes to be able to receive Bakken Oil from North Dakota. Very similar aspects of the two developments become obvious; an industrial area is expanded in order to accommodate the input of a commodity product which is then distributed by rail and ship. There are several of these proposals in various locations due to the Bakken fields coming online. This was a site-specific EIS for a location specific industrial development. The Gateway Pacific Terminal is no different and should be evaluated in the same way.
2. We encourage you to review the Martin and Associates Study of economic impact to the local area as you review other social and economic factors. Martin and Associates’ modeling is accepted worldwide as a definitive model of direct, indirect and induced economic factors relating to a port facility such as Gateway. As such, we hope you will review the impact of the economics of an industrial development on industrially zoned land, and determine that economic impact is relevant to the EIS review. The socio-economic impact of a project, with as many opportunities for short- and long-term employment as this one proposes, will provide many social improvements in the communities surrounding it due to the increased tax revenues produced, increased wages in the communities, increased security of families, and improved economic diversification.
3. We ask you to study the proposed site, specifically the fencing that is proposed to mitigate our winter and summer high winds and, additionally, the fast-growing tree buffer that the applicant intends to use. We believe that it is important to review representative wind speed and directions in all seasons in order to determine whether the fence and tree buffer proposed by the applicant as mitigation are sufficient or whether there is need for a more substantial mitigation. We are concerned that even a fast-growing tree buffer will need to have an alternative for the first fifteen years of growth, and we are additionally concerned that if the tree buffer is deciduous, there will need to be studies to determine if said buffer is sufficient in any case, due to the high winter winds from the NE, SE, and SW, depending on the origination of the storm system.
4. We ask you to review the water right available to the applicant, in order to determine whether it is sufficient in all seasons to properly wet the surface of the coal pile.
5. The Washington State Labor Council, AFL- CIO is a member of the Puget Sound Harbor Safety Committee. This committee was created by federal Port Safety and Security legislation to provide for all stakeholders to have a place to review and comment on the safety and security of the public waterways surrounding Washington State, from the Pacific Ocean Gateway Pacific Terminal/Custer Spur EIS approaches to the Strait of Juan de Fuca to Puget Sound and the Strait of Georgia and approaches. Many of the Vessel Risk Assessment studies are being reviewed there, and input from stakeholders, including labor, will be contained in those assessments when they are completed and made part of the full application.
6. We encourage you to review the comments by Capt. Michael Moore, former Coast Guard Captain of the Port (the area referred to, above), regarding vessel traffic baselines that exist, and baselines that are needed. We concur with the Captain’s urging to not make assumptions on yearly increases to bear on the data. And we also ask you to not make assumptions of collision from other areas into our waterway. There has been no collision or grounding caused oil spills by cargo vessels transiting to or from Puget Sound ports in 40 years of recordkeeping. We encourage you to study and focus on peak activity days or scenarios where vessel transits could be bunched closer together, and make risk mitigation determinations on that basis.
7. There are comments that recommend certain maritime risk studies be coordinated. While we do not want to duplicate efforts, we ask the regulatory partners not to lose sight of the rationale under which these assessments are being made. We would not want to lose an area of justified study for assessment, mitigation or alternative treatment in order to “streamline” or “coordinate” activities that appear similar at first glance.
8. We recommend that you include a comprehensive assessment of suitable tug availability that includes the distribution of tugs in the study area, both during escort and assist work, as well as during repositioning transits and most common mooring locations in-between jobs. With respect to mooring locations, please fully consider tug mooring capabilities at or near the proposed Cherry Point Gateway terminal in addition to the current locations used by tugs in the area.

Finally, we want to thank the regulatory partners for the opportunity to comment seriously on this proposal. We are available to provide additional information, should you require it.

Sincerely,


Jeffrey G. Johnson Vince O’Halloran Nicole Grant
President President, Puget Sound Exec. Director
Ports Council Cert. Electrical
Workers of WA


Dan McKisson Mike Elliott Lee Newgent
President, ILWU WA State Legislative Exec. Secretary
Puget Sound District Brotherhood of Locomotive Seattle Building and
Council Engineers Construction Trades
Council


Dave Myers Mark Lowry Larry Brown
Executive Secretary President Legislative Director
WA State Building and NW WA Central WA Machinists Council
Construction Trades Labor Council
Council

Herb Krohn Bob Guenther, Chair
State Legislative Director WSLC Economic Development
United Transportation Union and Job Retention Committee

JGJ:jh
opeiu8/afl-cio
Attached Files:

Jenny Godwin (#1806)

Date Submitted: 10/27/12
Location: Bellingham, WA
Comment:
See attached.
Attached Image:

Jim Littlefield (Surfers' Environmental Alliance) (#12641)

Date Submitted: 01/14/13
Location: Aptos, CA
Comment:
SURFERS' ENVIRONMENTAL ALLIANCE (SEA)

THE LEADING EDGE OF COASTAL ACTIVISM

Respectful greetings from Surfers' Environmental Alliance,

As a preliminary matter, Surfers’ Environmental Alliance (SEA) is committed to the preservation and protection of the environmental and cultural elements that are inherent to the sport of surfing. Our goals are achieved through grassroots activism, community involvement, education and humanitarian efforts. We engage in projects that strive to conserve the quality of our marine environment, preserve or enhance surf breaks, protect beach access rights, and safeguard the coastal surf zone from unnecessary development. www.seasurfer.org

Dear Army Corps of Engineers, Department of Ecology and Whatcom County Council:

I strongly oppose the construction of a coal export terminal at Cherry Point, Washington and transporting strip-mined coal from Montana and Wyoming on trains and ships throughout the Northwest. This proposal would negatively affect my community by increasing congestion and noise with more coal train traffic, polluting our air and local waterways, harming existing businesses, delaying emergency responders, damaging aquatic ecosystems and fishing grounds at the terminal site, increasing tanker traffic and the potential for serious shipping accidents and escalating climate change. I urge you to consider these impacts in the scope of the Environmental Impact Statement.

There are currently five coal export proposals that would transport as much as 150 million tons through the Northwest. I urge the Army Corps of Engineers to conduct an area wide Environmental Impact Statement to assess the cumulative impact of these proposals.

As you may know, SEA is based in California on the West Coast and New Jersey on the East Coast. SEA operates nationally and overseas also when appropriate, so we are extremely interested in the proposed ban. Any public action which reduces water quality, beach access or surfing access is strongly opposed by all SEA members.
We welcome your interest in this matter.

Sincerely,

Jim Littlefield
West Coast Environmental Projects Director Surfers' Environmental Alliance (SEA)

Joe Scott (Conservation Northwest) (#12214)

Date Submitted: 01/22/13
Location: Bellingham, WA
Comment:
Dear Folks

Please find attached scoping comments for GPT.

Sincerely


Joe Scott (360) 671-9950 x 11
International Programs Director (360) 319-7056 cell
Conservation Northwest (360) 671-8429 fax
1208 Bay #201
Bellingham WA 98225
jscott@conservationnw.org

www.conservationnw.org
Attached Files:

John Aschoff (San Juan Marine Resources Committe) (#2376)

Date Submitted: 10/30/12
Location: Friday Harbor, WA
Comment:
see attached
Attached Files:

John Covert (#5414)

Date Submitted: 12/26/2012
Comment:
I am the President of the Citizens for Sensible Transportation Planning 501(c)(3) non-profit and submit the following comments on behalf of my organization.

Statewide, BNSF railroad has 524 “at Grade” rail crossings that have gates and/or warning lights (so called ‘Active Protection’). See attachment. Union Pacific has 100 “at Grade” crossings. The eis process needs to identify which rail lines and which “at Grade” crossings are going to be used to transport coal from the mines to the terminal(s) in Washington or elsewhere. Will trains be allowed on the entire railroad network or will they be restricted to certain lines? If they get diverted onto unauthorized lines, what is the penalty? The scope can’t be limited to coal going to just one terminal. We need to understand the impacts across the board at its broadest implications for our country. If I am stuck in traffic at a railroad crossing in Spokane County because a coal train is going by, I don’t care where its ultimate destination will take it. Stuck in traffic is stuck in traffic. The increase in traffic congestion created by the additional trains being added to the existing rail network needs to be identified and properly mitigated. Transportation projects under construction in just Spokane County are spending billions of dollars to add capacity to the transportation road grid and this project is going to increase traffic congestion on dozens of arterials that cross rail lines at “at Grade” crossings.

Adding this congestion to the grid is contrary to the Washington state Transportation Implementation Plan and is not authorized in the SRTC Transportation Improvement Plan. How is it legal for a project to create as much congestion in the road network at the local level and at the state level as this project is going to create?

Some news reports suggest as many as 63 additional coal trains per day will enter/leave Washington state through the Spokane area. Others suggest the number of trains per day will be less than 10. There is widespread uncertainty about the maximum number of trains. The eis needs to clarify the maximum number of trains that will be necessary to move the projected maximum volume of coal. Future traffic congestion impacts need to be evaluated based on the maximum build out. The cost of the increased congestion created by the additional volume of rail traffic needs to be calculated. When the state of Washington transportation department estimates the cost of congestion, they use an estimate of $21.90/hour per hour of congestion (WSDOT 2012 Congestion Report). In Spokane County, on just the BNSF rail line to Pasco, there are 25 “at Grade” crossings. See attachment. The average daily traffic count for these roads is more than 51,000 cars per day. A portion of this traffic volume will be subjected to increased congestion for so many minutes per day as the additional train volume traverses the county. This will lead to several hundred hours of delay per day of increased congestion. Over the course of a year, this will cost Spokane County drivers over one million dollars in increased congestion (at $21.90/hour). The additional delay added to the road grid will cause emergency medical transportation delays in getting sick/injured people to hospital emergency rooms. It will create additional delay transporting children to schools, and workers to their jobs. These impacts also need to be evaluated under future, modeled traffic counts for the life of the project. These impacts need to be evaluated and mitigated. These types of issues will need to be addressed along the entire length of the rail grid that will move the additional coal supplies.

According to the Federal Railroad Administration, in Washington state between 2008 and 2011 there were 86 highway-rail accidents reported at public crossings on public roads. 19 fatalities were reported during that time period. As the number of trains increases, the number of accidents and fatalities is likely to increase. These impacts need to be evaluated in the eis.

An article in the August, 2007 Journal of the American Board of Family Medicine says that on an equal horsepower basis, diesel exhaust is 100 times more toxic than gasoline exhaust, even when carbon monoxide is considered. The study also identifies proximity to rail lines as a source of clinically significant exposure to diesel exhaust. In 2006 the California Air Resources Board estimated that diesel exhaust pollution directly accounts for 2400 deaths and, annually, nearly 3000 hospital admissions for respiratory and cardiac-related diseases, at a total cost of $19 billion in California alone. With the potential of 60+ additional trains each day in the Spokane area (~240 diesel locomotives) the impacts of the additional diesel exhaust on the health of people residing in the airshed also need to be evaluated.

The eis needs to fully analyze and explain to the public what the implications are for this project and its increase in rail freight volume moving through our communities.
Attached Image:

John Havekotte (#14253)

Date Submitted: 01/18/13
Location: Seattle, WA
Comment:
see attached
Attached Image:


Josh Nelson (Credo Action) (#11655)

Date Submitted: 01/22/2013
Location: San Francisco, CA
Comment:
Hello,

On behalf of 427 CREDO Action members in Montana, we urge you conduct a through review of the proposed Gateway Pacific Terminal's regional and global impacts, and to reject the project.

The attached public comments were made by CREDO Action Members in, and though they vary throughout, the messages within can be summed up as follows:

"The Gateway Pacific coal export terminal is a bad deal for Montana. It would escalate climate change, increase congestion and noise with more coal train traffic, pollute the air and local waterways, harm existing businesses, delay emergency responders, damage aquatic ecosystems and fishing grounds at the terminal site, and increase tanker traffic and the potential for serious shipping accidents. I urge you to consider all of these impacts in the scope of your Environmental Impact Statement."

If you have any questions about these public comments, don’t hesitate to contact me.

Josh Nelson, Campaign Manager
CREDO Action from Working ASsets
Attached Files:

Josh Nelson (Credo Action) (#11659)

Date Submitted: 01/22/2013
Location: San Francisco, CA
Comment:
Hello,

On behalf of 415 CREDO Action members in Idaho, we urge you conduct a through review of the proposed Gateway Pacific Terminal's regional and global impacts, and to reject the project.

The attached public comments were made by CREDO Action Members, and though they vary throughout, the messages within can be summed up as follows:

"The Gateway Pacific coal export terminal is a bad deal for Idaho. It would escalate climate change, increase congestion and noise with more coal train traffic, pollute the air and local waterways, harm existing businesses, delay emergency responders, damage aquatic ecosystems and fishing grounds at the terminal site, and increase tanker traffic and the potential for serious shipping accidents. I urge you to consider all of these impacts in the scope of your Environmental Impact Statement."

If you have any questions about these public comments, don’t hesitate to contact me.

Josh Nelson, Campaign Manager
CREDO Action from Working ASsets
Attached Files:

Josh Nelson (Credo Action) (#11662)

Date Submitted: 01/22/2013
Location: San Francisco, CA
Comment:
Hello,

On behalf of 5,662 CREDO Action members in Oregon, we urge you conduct a through review of the proposed Gateway Pacific Terminal's regional and global impacts, and to reject the project.

The attached public comments were made by CREDO Action Members, and though they vary throughout, the messages within can be summed up as follows:

"The Gateway Pacific coal export terminal proposal would negatively affect the Pacific Northwest by escalating climate change, increasing congestion and noise with more coal train traffic, polluting our air and local waterways, harming existing businesses, delaying emergency responders, damaging aquatic ecosystems and fishing grounds at the terminal site, increasing tanker traffic and the potential for serious shipping accidents. I urge you to consider all of these impacts in the scope of your Environmental Impact Statement."

If you have any questions about these public comments, don’t hesitate to contact me.

Josh Nelson, Campaign Manager
CREDO Action from Working Assets
Attached Files:

Josh Nelson (Credo Action) (#11848)

Date Submitted: 01/22/2013
Location: San Francisco, CA
Comment:
Mr. Perry, Ms. Kelly and Mr. Schroeder,

On behalf of 46,700 CREDO Action members outside the Pacific Northwest, we urge you to conduct a comprehensive study of the Gateway Pacific Terminal's environmental impacts that includes global climate impacts, and to reject the project.

The attached public comments were made by CREDO Action Members throughout the country, and though they vary throughout, the messages within can be summed up as follows:

"The Gateway Pacific coal export terminal would escalate climate change by leading to increased greenhouse gas emissions in China and other Asian countries. It would crowd out investments in clean sources of energy, encourage investments in dirty coal and lead to increased cumulative greenhouse gas emissions. As an American who is concerned about climate change, I urge you to include the impact on global greenhouse gas emissions and climate change in your environmental impact statement, and to reject the dangerous and misguided Gateway Pacific Terminal."

To download a PDF of these public comments, click here:
http://act.credoaction.com/admin/petitions/pdfs/petition_1955/US.pdf

If you have any questions about these public comments, don’t hesitate to contact me through the information provided below.

Sincerely,
Josh Nelson, CREDO Action

Josh Nelson (Credo Action) (#12163)

Date Submitted: 01/22/13
Location: , WA
Comment:
On behalf of 5,662 CREDO Action members in Washington, we urge you to conduct a comprehensive study of the Gateway Pacific Terminal's environmental impacts, and to reject the project.

The attached public comments were made by CREDO Action Members in Washington, and though they vary throughout, the messages within can be summed up as follows:

"The Gateway Pacific coal export terminal proposal would negatively affect my community by escalating climate change, increasing congestion and noise with more coal train traffic, polluting our air and local waterways, harming existing businesses, delaying emergency responders, damaging aquatic ecosystems and fishing grounds at the terminal site, increasing tanker traffic and the potential for serious shipping accidents. I urge you to consider all of these impacts in the scope of your Environmental Impact Statement."
If you have any questions about these public comments, don’t hesitate to contact me through the information provided below.
Sincerely,
Josh Nelson, CREDO Action
Attached Files:

Judy Bevington (League of Women Voters) (#5303)

Date Submitted: 12/18/12
Comment:
The League of Women Voters of Seattle-King County urges you to assess the array of economic , human and environmental impacts that are associated with the shipping and transport of large quantities of coal. Short term jobs must be weighed against impacts from noise, traffic delays and coal dust to businesses and property near transport sites, as well as long-term effects to fisheries and related industries. The effects of the diesel emissions and coal dust on human health need to be assessed. The impacts on marine and freshwater ecosystems need to be assessed, with consideration of habitat for salmon and other species.

Besides the near-location impacts, the assessment needs to look at the comprehensive and cumulative effects of the proposed action. To divide this program into small enough units that individually could be perceived as having less than significant effects, but to fail to add in major contributors to climate change, acidification of oceans and mercury deposition omits the very real and present threats to our human habitat, here and offshore.

Recent studies based on increasingly sophisticated models predict catastrophic changes to climate within our children and grandchildren's life-times. We must support low-carbon solutions to our energy needs-not allow actions that will significantly increase high carbon sources that will exacerbate the problem. It is vital to assess the contribution of carbon that this action will enable.

We urge you to use a broad lens as you assess the environmental and human impacts of coal trains. "Coal train" is a short-hand term for a suite of severe problems that are likely to result from the shipment and transportation of coal.


Judy Bevington, President
League of Women Voters of Seattle-King County president@seattlelwv.org
206-329-4848
www.seattlelwv.org

Julia Page (Western Organization of Resource Councils) (#12192)

Date Submitted: 01/22/13
Location: Billings, MT
Comment:
To Whom It May Concern:

Attached is a letter from the Western Organization of Resource Councils regarding scope of study for an EIS for Gateway Pacific Terminal and Custer Spur expansion projects. This letter was also submitted as an attachment to the online comment form, but because I did not receive a confirmation email, I'm submitting them to this email address as well.

Thank you,
Colin Lauderdale, WORC
Attached Files:

Kathleen Snyder (#10620)

Date Submitted: 01/21/2013
Location: Snohomish, WA
Comment:
See PDF attachment
Attached Files:

Katie Sweeney (#11754)

Date Submitted: 01/22/2013
Comment:
The National Mining Association submits the attached comments on the Gateway Project.
Attached Files:

Ken Oplinger (#1776)

Date Submitted: 10/31/2012
Location: Bellingham, WA
Comment:
25 October 2012

GPT/Custer Spur-EIS
c/o CH2M Hill
1100-112th Avenue NE, Suite 400
Bellevue, WA 98004
via email to: www.eisgatewaypacificwa.gov

RE: Scoping


To Whom It May Concern:

On behalf of the 850 members of the Bellingham/Whatcom Chamber of Commerce & Industry, representing tens of thousands of jobs across NW Washington and the Lower Mainland of British Columbia, I am writing to provide our thoughts on what should be included in the upcoming Environmental Impact Statement (EIS) for the proposed Gateway Pacific Terminal and Custer Spur expansion.

First and foremost, we support all efforts to ensure a full and complete review of this proposal. This would include the positive and negative impacts of the proposal in a wide variety of areas (including on off shore and on shore habitats, storm water runoff and discharge, rail traffic throughout Whatcom County, the full economic impact on Whatcom County, the ability to ship US produced commodities overseas, etc)

We ask that the following items be taken into account when preparing the scope of this EIS:

1. It is our belief that the impacts, both positive and negative, of this project should be looked at solely as they pertain to the proposal, and should not include impacts of other proposed dry bulk facilities in other parts of the region. Lumping these projects together can only serve to put issues only faced by a single project behind those issues that affect multiple locations, thereby potentially bringing less attention to these important single-site issues. Each project should have a full and complete EIS review such as the one we are looking forward to for this proposal.

2. We ask that specific attention be given to areas that you have omitted from the materials being circulated about this project, namely those regarding local economic impacts. This should include the impacts on tax collection in all jurisdictions affected by the proposal, the potential for new temporary and permanent jobs, including direct, in-direct and induced jobs, as well as the impacts on key industries in Whatcom County, including tourism.

3. We believe that a full review of the impacts of train traffic from this proposal should not only include the potential increase from 2012 train traffic, but should include a historic snap shot to review train traffic in recent history. The review should also include length and speed of trains, type of engines used for the trains, relative impacts on the environment for each type of engine, and the impacts on the environment from using other modes of transportation to carry the commodities currently being hauled on the BNSF line through Whatcom County (i.e. using semi trucks on I-5).

4. Opponents of the project have produced internal studies to suggest that Canadian dry bulk material terminals would refuse to ship Powder River Basin coal in order to ship Canadian produced coal from their limited-capacity terminals. The EIS should include a review of the current and proposed terminals in Canada, their potential for expansion, and whether they could be used to ship US-produced dry bulk goods overseas. This study should then determine the rail impacts on Whatcom County if additional capacity for US-produced dry bulk goods is found.

We appreciate the opportunity to submit our thoughts during the scoping process for the impending GPT and Custer Spur EIS. We will continue to monitor the scoping process, and reserve the right to add additional thoughts to the record prior to the closing of the scoping process.


Sincerely,

Ken Oplinger, ACE, President/CEO
Bellingham/Whatcom Chamber of Commerce & Industry

Kent Chamber of Commerce Kent Chamber of Commerce (#8806)

Date Submitted: 01/18/2013
Location: Kent, wa
Comment:
The Kent Chamber of Commerce has concerns regarding the application of Pacific International Terminals to develop the largest coal export facility in North America at Cherry Point in Northwest, Washington. The “Gateway Pacific Terminal” would be operated by SSA Marine who is a global leader in maritime services. Coal mined from Montana and Wyoming would be hauled by trains along the Burlington Northern Santa Fe (BNSF) rail lines. The coal train corridor extends from mines in Montana and Wyoming through Sandpoint, Idaho, to Spokane, down through the Columbia River Gorge, then up along the Puget Sound coast, passing through Longview, Tacoma, Kent, Seattle, Edmonds, Everett, Mt. Vernon, Bellingham, Ferndale and all points in between.

We believe that coal trains would create significant adverse impact on local jobs and businesses, property values, human health and quality of life. The trains are expected to haul up to 54 million tons of coal per year. There is uncertainty regarding the number of additional trains that will be added to the existing rail facilities but initial estimates of 18 coal trains per day, each up to one and a half miles in length are expected to move along the corridor. This will adversely impact traffic and freight mobility along with impeding emergency vehicles. Estimations in crossing delays range from one to two hours of additional delay every day from these 18 new coal trains in Kent. The impact of local traffic congestion should be examined in the EIS and future congestion impacts need to be evaluated based on realistic expectations of future coal train traffic and not just initial minimum numbers of proposed trips at start up. The City of Kent is the fifth largest industrial and warehouse distribution center in the nation and is the second largest on the west coast. Freight mobility is at the utmost importance of the Kent business community. Substantial taxpayer investment may be required to support infrastructure to mitigate some of the potential adverse impacts created by the project.

Freight mobility is at the forefront of the Kent Chamber of Commerce concerns and we have myriad of these concerns that need to be evaluated in the EIS including:

• Increased traffic congestions and crossing delays will increase tailpipe emissions from stopped and idling vehicles and increased diesel emissions from train engines. These impacts to traffic congestion and air quality need to be evaluated in the EIS.
• Increased delay to school buses which may increase the burden on financially strapped school districts to increase their fleets and transportation budgets to restore the transit times they originally planned for picking up children and transporting them to local schools.
• Rail capacity – residents and business in Kent rely on Sound Transit Commuter Rail as mode of transportation. Will this traffic supplant or preclude additional Sounder Rail service? We request that the EIS look at how this project will affect completion for future rail capacity.
• According to the 2012 Washington State Congestion Report, the cost of congestion is $21.90 per hour. Considering 18 trains per day imposing anywhere from one to two hours of delay and around 100,000 vehicles being affected, many with more than one occupant, the cost of delay could be estimated to be in the millions of dollars to Kent residents and businesses alone. The EIS should examine the magnitude of this economic cost to communities along the corridor.

We look forward to working together for solutions to mitigate and quell our concerns regarding the “Gateway Pacific Terminal.” The Kent Chamber of Commerce wants to be a partner in the State’s economic vitality but not to the determent of our community.
Best Regards,

Andrea Keikkala

Cc: Scoping comments: www.eisgatewaypacificwa.gov/get-involved/comment
City of Kent Council, Members of the WA State Legislature 33rd, 47th and 11th District, King County Council Members, Kent Reporter, Kent Chamber membership and Business Examiner

Kim Abel (League of Women Voters of Washington) (#12006)

Date Submitted: 01/21/13
Location: Seattle, WA
Comment:
see attached
Attached Image:

Kim Lund (Communitywise Bellingham) (#12226)

Date Submitted: 01/22/13
Comment:
Dear Co-lead Agencies,

Please accept this scoping comment on behalf of Communitywise Bellingham.

Kindly,
Kim Lund
739-2389

Dear Co-lead Agencies,

Please accept this scoping comment on behalf of Communitywise Bellingham.

Kindly,
Kim Lund
739-2389

Greetings Co-Lead Agencies:

Please accept this comment of behalf of Communitywise Bellingham.

Thank you.
Kim Lund
739-2389

Greetings Co-Lead Agencies:

Please accept this comment of behalf of Communitywise Bellingham.

Thank you.
Kim Lund
739-2389

Greetings Co-Lead Agencies:

Please accept this comment of behalf of Communitywise Bellingham.

Thank you.
Kim Lund
739-2389
Attached Files:

Kimerly Rorschach (#14341)

Date Submitted: 01/18/13
Comment:
see attached
Attached Image:

Kristen & Gregg Boyles & Small (Earth Justice & Climate Solutions) (#12209)

Date Submitted: 01/22/13
Location: Seattle, WA
Comment:
The attached Scoping Comments (and indexes to exhibits) on Proposed Gateway Pacific Coal Terminal Facility and Custer Spur Rail Expansion Project are submitted by Earthjustice on behalf of Climate Solutions, Columbia Riverkeeper, RE Sources, National Wildlife Federation, Greenpeace, Sierra Club, Friends of the Columbia Gorge, Center for Biological Diversity, Washington Environmental Council, and Oregon Physicians for Social Responsibility.

There are 267 voluminous exhibits that support these Scoping Comments, and due to their size we are unable to attach them to this email. They will be delivered by Federal Express tomorrow along with the original of our Scoping Comments. As an added precaution, we are also submitting these Scoping Comments on the comment form on your website.
__________________________________
Cathy Hamborg
Secretary
Earthjustice
705 Second Ave., Suite 203
Seattle, WA 98104
T: 206-343-7340 ext. 1031
F: 206-343-1526
www.earthjustice.org
Attached Files:

Kristen L. Boyles (#11585)

Date Submitted: 01/22/2013
Location: Seattle, WA
Comment:
The attached Scoping Comments (and indexes to exhibits) on Proposed Gateway Pacific Coal Terminal Facility and Custer Spur Rail Expansion Project are submitted by Earthjustice on behalf of Climate Solutions, Columbia Riverkeeper, RE Sources, National Wildlife Federation, Greenpeace, Sierra Club, Friends of the Columbia Gorge, Center for Biological Diversity, Washington Environmental Council, and Oregon Physicians for Social Responsibility.

There are 267 voluminous exhibits that support these Scoping Comments, and due to their size we are unable to attach them to this comment form. They will be delivered by Federal Express tomorrow along with the original of our Scoping Comments. As an added precaution, we are also submitting these Scoping Comments by email.
Attached Files:

Lauren Goldberg (#11767)

Date Submitted: 01/22/2013
Comment:
Columbia Riverkeeper's comments are attached in the uploaded PDF document. Please confirm receipt of these comments. Thank you.

Lauren Goldberg
Staff Attorney
Columbia Riverkeeper
Attached Files:

Lauren Goldberg (Columbia Riverkeeper) (#12220)

Date Submitted: 01/22/13
Location: Hood River, OR
Comment:
Mr. Perry,



I submitted the attached comment (see below) and the email bounced back. I am submitting the comment to you in the event the email problem is not rectified before the close of the comment period. Please confirm receipt of this comment.



Thank you.



Lauren



Description: Description: columbiariverkeeper smaller image

Lauren Goldberg | Staff Attorney
Columbia Riverkeeper | 111 Third St. Hood River, OR 97031
541.965.0985 | lauren@columbiariverkeeper.org

Description: Description: facebook <http://www.facebook.com/pages/Columbia-Riverkeeper/276552284164> Description: Twitter RIght size <https://twitter.com/ColumbiaRKeeper> Description: Description: youtube <http://www.youtube.com/user/columbiariverkeeper> www.columbiariverkeeper.org <http://www.columbiariverkeeper.org/>
Attached Files:

League of Woman Voters Bellingham Whatcom (#6099)

Date Submitted: 01/06/2013
Location: Bellingham, WA
Comment:
The League of Women Voters urges you to study the effects of the increase in the degradation of our air and water by shipping Powder River Basin Coal to China.

The League of Woman Voters believes global climate change threatens the integrity of the earth’s climate system and that there is a need to reduce greenhouse gas emissions.
Coal is the major contributor of CO2 emissions in the United States. Each short ton of Powder River Basin coal contributes over 2.8 tons of CO2 to the atmosphere.1 In addition coal contains toxins like mercury—only 35% of which is captured by pollution control devices. 2

As Washington State weans itself from fossil fuels, the coal industry is seeking to ship coal through our state to overseas markets. If China proceeds with intensive coal burning plans, experts estimate that China’s contribution to greenhouse gases from coal burning over the next 25 years will exceed that of all other industrial countries combined.3

Powder River Basin coal is a cheap source of fuel—cheaper than China’s domestic product. It is especially cheap for China as they won’t have to bear the costs of infrastructure and facilities. By providing shipment of our cheap coal are we being asked to enable an environmental disaster by slowing China’s new investments in renewable energy 4 It is true that China may seek other coal resources, but we could make the choice to use coal less attractive.

You should also consider the volatility of the coal market. China is ahead of their projections in investing in solar and wind and has just joined with Conoco Philips in a multi-billion dollar contract to develop China’s gas reserves by the process of fracking. We could build this facility, fill our train capacity with coal, degrade our air quality, and threaten our inland waters, only to find the market has disappeared. What would be the cost of an environmental cleanup?

We urge the scoping agencies to do a cost/benefit analysis. Is it worth shipping this resource to China where it will add to global emissions and pollute our air and water as prevailing winds bring the coal back to our shore? Study the economics of fueling our competitors, the costs to our fishing industry of polluted waters, the health costs to our citizens and our medical systems caused by breathing airborne toxins. Would the increase in tax revenue offset these costs?

The League urges you to take these impacts into consideration on any permitting decisions.


1 DOE www.eia.gov/cneaf/electricity/page/co2report/co2emiss.pdf

2The Energy Challenge: Pollution from Chinese Coal Casts a Global Shadow NY Times 6/11/2006

3Mercury: basic information: http.//www.epa.gov/mercury/about.htm

4 China as World Arbitrage on Coal Stanford Study 2010

LeeAnne Beres (Earth Ministry) (#13758)

Date Submitted: 01/22/13
Location: Seattle, WA
Comment:
See Attached

[NOTE FROM PROJECT TEAM: Attached is a letter from the Earth Ministry along with 398 comments collected by them from individuals by the end of the comment period, January 22, 2013. All individual comments have been reviewed by the project team and will be considered in the scoping report.]
Attached Files:

Leroy Rohde (#14350)

Date Submitted: 01/19/13
Location: Bellingham, WA
Comment:
see attached
Attached Image:

Lesley Adams (Waterkeeper Alliance) (#12216)

Date Submitted: 01/22/13
Location: Talent, OR
Comment:
To Whom it May Concern,

Oral testimony given by Waterkeeper Alliance staff both in Spokane and Seattle hearings are not currently in the searchable database.

For the record, the following Waterkeeper Alliance staff gave oral comments as follows:

Lesley Adams, Western Regional Coordinator, Waterkeeper Alliance: December 4, 2012 in Spokane, WA.

Pete Nichols, National Director, Waterkeeper Alliance, December 13, 2012 in Seattle , WA

Attached are written comments on behalf of the Waterkeeper Alliance that were also emailed in earlier today.

Thanks.

--
Lesley Adams
Western Regional Coordinator
Waterkeeper Alliance
P.O. Box 240
Talent, Oregon 97540
541.897.0208 (o) 541.821.3882 (c)

[NOTE: ATTACHED WATERKEEPER ALLIANCE WRITTEN COMMENTS WERE ALSO SUBMITTED IN A SEPARATE EMAIL. TOPIC AREAS ARE CHECKED IN THAT DATABASE COMMENT RECORD.]
Attached Files:

Loreene Reid (Sacajawea Audubon Society) (#12028)

Date Submitted: 01/21/13
Location: Bozeman, MT
Comment:
see attached
Attached Image:

LUMMI ISLAND CONSERVANCY LUMMI ISLAND CONSERVANCY (#11760)

Date Submitted: 01/22/2013
Location: Lummi Island, WA
Comment:
January 20, 2013

TO: Gateway Pacific Terminal Co-Lead Agencies
FROM: Lummi Island Conservancy
SUBJECT: EIS Scoping comments

The Lummi Island Conservancy is a non-profit organization dedicated to safeguarding the environmental health and quality of life of Lummi Island and the greater Puget Sound region. We respectfully request that the following concerns be included in the Environmental Impact Statement.

OIL/COAL SPILL RISKS: How will GPT’s marine vessel traffic increase collision risks with tankers and other cargo ships in the area? What would be the effects on our region of a catastrophic oil and/or coal spill? How will coal dust blowing and/or leaching into the water affect coastal habitat. All of the coastal habitat (including all of Lummi Island) in the vicinity of the proposed GPT terminal has been federally designated critical habitat for ESA-listed threatened Puget Sound Chinook salmon and is currently under study for critical habitat designation for ESA-listed threatened Puget Sound Steelhead. What affect could such spills have on these habitat areas and the species they support?

HERRING POPULATION: How will terminal construction, operations, shipping traffic, potential oil/coal spills and coal dust affect the already seriously declining herring population in the area? As a keystone species, even minimal adverse impacts to this species could ripple out into severe harm to the salmon fishery, as well as to several marine and mammal species dependent on herring.

ORCA, MARINE MAMMALS & BIRDS: How would the noise, pollution and physical presence of the additional huge transport vessels affect our orca populations? How would construction and operation of the coal port and the continuous transiting of coal ships affect other marine mammals, fish, priority bird species, and the food web that supports them?

SALMON & FISHERIES: How would construction and operation of the coal port; up to 100 acres of pulverized coal in open, near-shore storage; and the coal ships themselves (size, pollution, noise, anchor dragging, etc) impact the crab, herring and salmon fisheries?

BOATING & SAFETY: How might fishing and recreational boating be affected by the additional cape-size and Panamax coal ships in our waters? How much will accident and collision rates increase?

TOURISM & OTHER ECONOMIC COSTS: How would lost beauty, decreased orca populations, damaged fisheries and more crowded waterways affect our tourism industry? How much will we, the taxpayers, ultimately pay for costs directly and indirectly associated with GPT?

ECONOMIC IMPACTS: The entire shoreline of Lummi Island is designated shoreline of statewide significance. Herring and other forage fish species spawn on our shoreline. The reefnet salmon fishery is economically important to the island. Residents and tourists enjoy recreational boating, fishing, crabbing and whale watching off our shores. Damage to our shoreline caused by oil/coal spills could result in serious economic impacts to these activities on a local and regional level. Loss of value to prime shoreline properties could also result, not only for Lummi Island but for shoreline property throughout the North Puget Sound area. These impacts must be studied.

HUMAN HEALTH: Sudden, unexpected wind gusts are common in the area of the proposed GPT terminal increasing the likelihood of air quality harm due to coal dust released into the air from open air coal storage, and loading/unloading operations at the terminal. These weather patterns and high wind patterns must be studied, as well as the potential harm to human health. Study should include the estimated range of harm to air quality in the region. Lummi Island residents, in particular, would be very vulnerable, living less than 10 miles from the proposed terminal and in the direct path of high and gale-force winds common in winter months.

Respectfully submitted,

Meredith Moench
President, Lummi Island Conservancy
Box 213
Lummi Island, WA 98262
Attached Image:

Marc Daily (Puget Sound Partnership) (#8886)

Date Submitted: 01/16/13
Location: Tacoma, WA
Comment:
Please find the attached comment letter from the Puget Sound Partnership regarding scoping for the Pacific Gateway Terminal Project. Please contact me with any questions. Thanks... Marc





Marc Daily
Deputy Director - Implementation

PUGETSOUNDPARTNERSHIP

p: 360.339.5861 | c: 360.584.5217 | email: marc.daily@psp.wa.gov
Attached Files:

Marcie Keever (Friends of the Earth) (#12215)

Date Submitted: 01/22/13
Location: Berkeley, CA
Comment:
To Whom It May Concern:

Please find attached the comments of Friends of the Earth regarding the scoping for the Environmental Impact Statement for the proposed Gateway Pacific Terminal & Custer Spur. In addition, members and supporters of Friends of the Earth also submitted approximately 12,700 individual comment letters to the Army Corps, Dept. of Ecology and Whatcom County. We are able to forward those comments to CH2M HILL at the email above if requested.

Sincerely,
Marcie Keever

****************************************
**PLEASE NOTE FRIENDS OF THE EARTH'S NEW ADDRESS**

Marcie Keever
Oceans & Vessels Project Director
Friends of the Earth
David Brower Center
2150 Allston Way, Ste. 240
Berkeley, CA 94704
510-900-3144 phone
510-900-3155 fax
mkeever@foe.org
www.foe.org
Attached Files:

Mariann Carrasco (Whatcom Marine Mammal Stranding Network) (#12197)

Date Submitted: 01/22/13
Location: Acme, WA
Comment:
Dear Sirs,

The Whatcom Marine Mammal Stranding Network respectfully submits a comment letter (attached) for your scoping process for the Gateway Pacific Terminal project. If you have any questions, please don't hestitate to let me know.

Thanks,

Mariann Carrasco
Wildlife biologist, Marine Mammal Biologist
Whatcom Marine Mammal Stranding Network Coordinator
P.O.Box 108 Acme, WA 98220
360-595-2114, hm/off, 360-303-3608, cell
www.wmmsn.org
Attached Files:

Mark Lowry (#12189)

Date Submitted: 01/22/13
Location: Bellingham, WA
Comment:
see attached
Attached Image:

Mark Lowry (Northwest Washington Central Labor Council) (#12188)

Date Submitted: 01/21/13
Comment:
Please find an attached document to this e-mail from the Northwest Washington Central Labor Council.

Thank you for your detailed work on this important issue!

Mark Lowry
President, NWWCLC
Attached Files:

Marla Nelson (Northwest Environmental Defense Center) (#12213)

Date Submitted: 01/22/13
Location: Portland, OR
Comment:
Good afternoon,

Attached please find the Northwest Environmental Defense Center's scoping comments for the proposed Gateway Pacific Terminal and Custer Spur. Due to the Martin Luther King holiday, we are submitting these comments now, prior to today's 5:00PM deadline. We request confirmation that these comments have been received and that they have been included in the public record for this project. Thank you for the opportunity for early public involvement in this process.

Regards,
JJ England
Air Quality Project Coordinator
Northwest Environmental Defense Center
Attached Files:

Mary Toland (#3713)

Date Submitted: 12/02/2012
Location: Sagle, ID
Comment:
Please accept the following comments as a part of the Scoping Hearing to be held in Spokane, WA 12/4/12. I am writing this letter on behalf of Lake Pend Oreille Waterkeepers and all residents of the Sandpoint, ID. area. I ask you to deny the pending removal-fill permit for Ambre Energy's coal export project. I implore you to preceed with a Programmic Environmental Impact Statement for the following reasons.
*If the proposed coal export terminal is built and coal exporting is approved, our community will take the brunt of coal transport impacts,witnessing the passage of > 100 trains per day and half of these will be dedicated to coal.
* Coal is problematic as it contains heavy metals, radioactive compounds, and carcinogens with the potential to severely degrade air and water quality in our community. As it is transported along 30 miles of Lake Pend Oreille shoreline, our community will be vulnerable to air and water pollution as a result of possible derailments, added diesel train engine exhaust and coal dust emissions from rail cars.
Traffic in our community will suffer major delays and complications at our dozens and dozens of RR crossings scattered throughout our city and county.
* There are no economic incentives and benefits to our community and there are numerous threats to public health, natural resources, and our quality of life.
*IMPACTS TO OUR COMMUNITY ARE MULTIPLIED IN EVERY TOWN ALONG THE RAIL TRANSPORT ROUTE.
*Looking at the larger picture, coal is not "clean". The extraction, transport and burning of coal will add carbon dioxide, mercury, ash and other contaminants to soil, water and atmosphere all along the route. Having no control of China's emissions, their air pollution will also come back to us .
* This permit and project must be denied. Ambre's plans are not consistent with the protection, conservation and best use of this region's water resources, clean air or with the public health of people, animals and plants in the Northwest and beyond.
*I urge you to take a courageous stand. Insist that an EIS be done for every community along the transport/export route. Stand up for our communities, future generations, and this planet home. We must protect this planet from further ravages of climate change.
Thank you.
Mary Toland

Mary Toland (#4229)

Date Submitted: 12/06/12
Location: Sagle, ID
Comment:
Dear Mr. Gagnon,
Please accept the following comment as a part of the Scoping Hearing to be held in Spokane, WA. on Dec. 4th, 2012.

I am writing this letter on behalf of Lake Pend Oreille Waterkeeper and all the residents of Sandpoint, Idaho. I call on your to deny the pending removal-fill permit for Ambre Energy's coal export project. I implore you to proceed with a Programmatic Environmental Impact Statement for the following reasons.

* If the proposed coal exports are approved,our community will take the brunt of coal transport impacts, witnessing the passage of > 100 trains per day, half dedicated to coal.
* Coal is problematic as it contains heavy metals, radioactive compounds and carcinogens with the potential to severely degrade air and water quality in our community. As it is transported along the 30 mile shoreline of Lake Pend Oreille, our community will be vulnerable to air and water pollution as a result of possible derailments, added diesel exhaust from train engines and coal dust emissions from the coal cars. Traffic in our community will suffer major delays and complications in connection with dozens and dozens of RR crossings scattered throughout town and the county. There are absolutely non economic incentives for Sandpoint but numerous threats to natural resources, public health and our quality of life.
* Impacts to our community are multiplied in every town and city along the route.
* Looking at the larger picture, coal is not clean. The extraction, transport and burning of coal will add carbon dioxide, mercury,ash and other contaminants to our atmosphere. We have no control over China's procedures and it will return to us as air pollution in the atmosphere.
* It saddens me to know that all of the efforts to protect water quality upstream of the Columbia River, will be threatened by one of the dirtiest energy sources available.
* The permits for this project must be denied. Ambre's plans are not consistent with the protection, conservation, and best use of this region's water resources or with the public health of plants, animals and people in the Northwest and beyond.
* I urge you to make a courageous stand. Insist that the Programatic Environmental Impact Statement be done for every affected community. Stand up for our communities and this planet. We do not have to become a participant in a project with major global pollution outcomes.
* WE must protect this planet from further ravages of climate change. We are responsible for the quality of life on this planet for generations to come!

Please include these comments in the information received for the Spokane Scoping Hearing 12/4.

Thank you.

Mary Toland

Matt Krogh (#11694)

Date Submitted: 01/22/2013
Location: Bellingahm, WA
Comment:
Please find attached a scoping comment letter and select sources for RE Sources for Sustainable Communities. Thank you.
Attached Files:

Matt Krogh (RE Sources for Sustainable Communities) (#12219)

Date Submitted: 01/22/13
Comment:
Dear Ms. Kelly, Mr. Perry, and Mr. Schroeder:

Please find attached RE Sources for Sustainable Communities' scoping letter and select references pertaining thereto. Thank you for this opportunity to comment on the Gateway Pacific/Custer Spur project.

Regards,

Matt Krogh


--
Matt Krogh, North Sound Baykeeper
RE Sources for Sustainable Communities
2309 Meridian St.
Bellingham, WA 98225
http://www.re-sources.org

360 733-8307 (office)
360 820-2938 (cell)

Check out the North Sound Baykeeper team blog
Or join us on Facebook
Attached Files:

meghan Hallam (#12046)

Date Submitted: 01/22/2013
Location: Bellingham, WA
Comment:
Thank you for taking time to assess both the local and regional community concerns. We at Coastal Conservation Association North Sound chapter are submitting these comments for your review and consideration. We hope the process takes into account any impacts to marine life, marine life habitat and recreational fishing; in particular our cherished fisheries in the Cherry Point region.
Many of our salmonid stocks are either listed Endangered Species, Threatened Species or Species of Concern. According to various studies one of their food sources, the Pacific Herring (Clupea Pallasii) are below historic low levels throughout Puget Sound waters. In the 2011 Acoustic/Trawl Survey the Cherry Point stock were found to be at critically low levels. These herring are unique by their spawn time, that differs from other stocks by a matter of months, and whose spawning grounds are in the immediate vicinity of the proposed terminal. We hope impacts to this species spawning grounds are taken into consideration as well as potential impacts to the nearby Cherry Point Aquatic Reserve.
Additionally we hope the project does not limit or impair access for recreational fishing. Potential impacts to recreational fishing are important for social and economic reasons. We hope a robust analysis on recreational fishing is undertaken that takes into account, among other aspects, potential impacts from increased shipping traffic and/or other variables related to changes in shipping patterns.
Thank you for your time and for the opportunity to comment on this proposal.

Meredith Moench Lummi Island Conservancy (#12217)

Date Submitted: 01/22/13
Location: Lummi Island, WA
Comment:
LUMMI ISLAND CONSERVANCY (lummiislandconservancy@yahoo.com) sent a message using the contact form at http://www.eisgatewaypacificwa.gov/contact.

January 20, 2013

TO: Gateway Pacific Terminal Co-Lead Agencies
FROM: Lummi Island Conservancy
SUBJECT: EIS Scoping comments

The Lummi Island Conservancy is a non-profit organization dedicated to safeguarding the environmental health and quality of life of Lummi Island and the greater Puget Sound region. We respectfully request that the following concerns be included in the Environmental Impact Statement.

OIL/COAL SPILL RISKS: How will GPT’s marine vessel traffic increase collision risks with tankers and other cargo ships in the area? What would be the effects on our region of a catastrophic oil and/or coal spill? How will coal dust blowing and/or leaching into the water affect coastal habitat. All of the coastal habitat (including all of Lummi Island) in the vicinity of the proposed GPT terminal has been federally designated critical habitat for ESA-listed threatened Puget Sound Chinook salmon and is currently under study for critical habitat designation for ESA-listed threatened Puget Sound Steelhead. What affect could such spills have on these habitat areas and the species they support?

HERRING POPULATION: How will terminal construction, operations, shipping traffic, potential oil/coal spills and coal dust affect the already seriously declining herring population in the area? As a keystone species, even minimal adverse impacts to this species could ripple out into severe harm to the salmon fishery, as well as to several marine and mammal species dependent on herring.

ORCA, MARINE MAMMALS & BIRDS: How would the noise, pollution and physical presence of the additional huge transport vessels affect our orca populations? How would construction and operation of the coal port and the continuous transiting of coal ships affect other marine mammals, fish, priority bird species, and the food web that supports them?

SALMON & FISHERIES: How would construction and operation of the coal port; up to 100 acres of pulverized coal in open, near-shore storage; and the coal ships themselves (size, pollution, noise, anchor dragging, etc) impact the crab, herring and salmon fisheries?

BOATING & SAFETY: How might fishing and recreational boating be affected by the additional cape-size and Panamax coal ships in our waters? How much will accident and collision rates increase?

TOURISM & OTHER ECONOMIC COSTS: How would lost beauty, decreased orca populations, damaged fisheries and more crowded waterways affect our tourism industry?

ECONOMIC IMPACTS: The entire shoreline of Lummi Island is designated
shoreline of statewide significance. Herring and other forage fish species
spawn on our shoreline. The reefnet salmon fishery is economically important to the island. Residents and tourists enjoy recreational boating, fishing, crabbing and whale watching off our shores. Damage to our shoreline caused by oil/coal spills could result in serious economic impacts to these activities on a local and regional level. Loss of value to prime shoreline properties could also result, not only for Lummi Island but for shoreline property throughout the North Puget Sound area. These impacts must be studied.

HUMAN HEALTH: Sudden, unexpected wind gusts are common in the area of the proposed GPT terminal increasing the likelihood of air quality harm due to coal dust released into the air from open air coal storage, and loading/unloading operations at the terminal. These weather patterns and high wind patterns must be studied, as well as the potential harm to human health. Study should include the estimated range of harm to air quality in the region. Lummi Island residents, in particular, would be very vulnerable, living less than 10 miles from the proposed terminal and in the direct path of high and gale-force winds common in winter months.

Respectfully submitted,

Meredith Moench
President, Lummi Island Conservancy
Box 213
Lummi Island, WA 98262
new4meredith@yahoo.com

Michael Sacco (AFLCIO) (#12011)

Date Submitted: 01/21/13
Location: Washington, DC
Comment:
see attached
Attached Image:

Mike Deller (The Trust for Public Land) (#12194)

Date Submitted: 01/22/13
Location: Seattle, WA
Comment:
January 22, 2012
My name is Mike Deller. I am the Washington State Director for the Trust for Public Land. I live in Mukilteo, Washington and work in Seattle. I am writing in regard to the proposed Gateway Pacific Coal Terminal at Cherry Point and the anticipated increase in coal trains and ship traffic to serve it.
The Trust for Public Land's mission is to conserve land for people to enjoy as parks, gardens, and other natural places, ensuring livable communities for generations to come.
Since 1975 in the 12 Puget Sound counties alone, The Trust for Public Land has:
• Completed 151 transactions that conserved 19,883 acres of land valued at over $225 million
• 32 of these transactions were on the Puget Sound Shoreline, protecting 1,902 acres with a fair market value of $52 million
• Since 2006 as part of the Alliance for Puget Sound Shorelines, we completed 10 shoreline projects to conserve 890 acres valued at more than $30 million
As you can see, our efforts to conserve land around Puget Sound have been extensive and expensive. Giving countless Washington residents and visitors precious access to our shoreline has been made possible with hard work and millions of dollars in public grants and private donations. We want to make sure that those investments in public shoreline lands are protected for many generations to come. We want to be assured that the environmental review process will fully investigate the risk of potential harm to the Puget Sound marine life, shorelines and public space from potential coal dust release, coal spills or accidents.
At minimum, the following should be thoroughly investigated:
1. The human and habitat health impacts of the ongoing release of coal dust on shoreline and uplands from coal trains using the BNSF main line that hugs the Puget Sound shorelines through Pierce, King and Snohomish counties.
2. The result of train derailments along the many miles of coastal railway where wet-season mud slides greatly increase the risk of such accidents.
3. The impact of substantial increases in diesel emissions, dust and other accidental spillage from the increased train traffic.
4. The potential impact on marine life and shoreline habitat from coal ships voyaging through Puget Sound, the Straits of Juan de Fuca and into the Pacific, including the projected consequences if one of these ships should founder, or spill its cargo.
I urgently request that these potential environmental impacts are considered in detail. I appreciate the opportunity to comment.

Mike Deller
Washington State Director
901 Fifth Avenue, Suite 1520
Seattle, WA 98164

206-274-2916 - direct
425-422-2409 - cell

The Trust for Public Land
Celebrating 40 years of creating parks and conserving land for people.
tpl.org

Mike Foley (United Association of Plumbers and Steamfitters Local #44) (#7670)

Date Submitted: 01/10/13
Location: Spokane, WA
Comment:
see attached
Attached Image:

Mitchell Smith (Southwest County Coalition) (#14356)

Date Submitted: 01/15/13
Comment:
See attached.
Attached Files:

N/A Newport Presbyterian Church (#14685)

Date Submitted: 01/21/13
Location: Bellevue, WA
Comment:
see attached
Attached Files:

na Stanwood Area Merchants Association (#2348)

Date Submitted: 10/29/12
Comment:
see attached
Attached Files:

Nicole Brown (#11944)

Date Submitted: 01/22/2013
Location: Deming, WA
Comment:
Please accept the attached comment and related attachments regarding Purpose and Needs analysis in the EIS on behalf of SafeGuard the South Fork.
Attached Files:

Nicole Brown (#11949)

Date Submitted: 01/22/2013
Location: Deming, WA
Comment:
Please accept the attached comment and related attachments regarding Rail Capacity Issue and the Whatcom Farmland Route on behalf of SafeGuard the South Fork.
Attached Files:

Pete Nichols (Waterkeeper Alliance) (#12193)

Date Submitted: 01/22/13
Location: Talent, OR
Comment:
To Whom it May Concern,

Please find the attached scoping comments from the Waterkeeper Alliance on the proposed Gateway Pacific coal export project.

Thank you.

--
Lesley Adams
Western Regional Coordinator
Waterkeeper Alliance
P.O. Box 240
Talent, Oregon 97540
541.897.0208 (o) 541.821.3882 (c)
Attached Files:

Philip Buri (#11607)

Date Submitted: 01/22/2013
Location: Bellingham, WA
Comment:
Note: Citations included in mailed hard copy and available here:
http://www.communitywisebellingham.org/wp-content/uploads/2012/10/Siding.pdf

To The Co-Lead Agencies:

I represent Communitywise Bellingham, a non-profit dedicated to providing independent information regarding the proposed Gateway Pacific Terminal. The Gateway Terminal will add 18 train trips to the 12 or 13 that currently travel the rail line through Whatcom County. In 2006, the Washington State Transportation Commission identified a choke point between Bow and Ferndale that limits the number of trains to 15 trips. To qualify for a major project permit, the Terminal’s developer must explain how it will double capacity on the rail line for 15 additional train trips. The Transportation Commission found only one viable proposal -- constructing a rail siding through south Bellingham.

Communitywise Bellingham requests that the environmental impact statement: (1) examine the reasonable range of alternatives for increasing rail capacity through Whatcom County, Washington; (2) analyze the effects of building, maintaining and operating a rail siding through Bellingham; (3) identify the significant adverse impacts from this active rail siding on Bellingham’s waterfront businesses, adjacent neighborhoods, community health, shorelands, marine resources, recreation areas, traffic, and emergency response times; (4) identify any measures that might minimize or mitigate the effects of constructing the siding and doubling rail capacity between Bow and Ferndale; and (5) estimate the costs of mitigation and identify who should bear these expenses.

I. Whatcom County Must Conduct Special Review Of A Major Development

The Gateway Pacific Terminal is a major development under the Whatcom County Code. As a consequence, the County must conduct “special review of those projects or developments that because of their magnitude and impact will tend to affect the public at large.” WCC 20.88.010. The Terminal is an archetype of a major development.

One aspect of this “special review” is careful scrutiny of the Terminal’s impacts on essential facilities, including the rail line that runs through the City of Bellingham and Whatcom County. Under WCC 20.88.130, the Terminal’s developer must prove that this major project:

(5) Will be served by, or will be provided with essential utilities, facilities and services necessary to its operation, such as roads, drainage facilities, electricity, water supply, sewage disposal facilities, and police and fire protection. Standards for such utilities, facilities and services shall be those currently accepted by the state of Washington, Whatcom County, or the appropriate agency or division thereof.

(6) Will not impose uncompensated requirements for public expenditures for additional utilities, facilities and services, and will not impose uncompensated costs on other property owned.

Rail service is an essential facility for the Terminal. And the County has a responsibility to ensure adequate capacity exists, even for infrastructure like private rail lines. For example, under its Comprehensive Plan, the County identifies rail service as a critical part of the County’s transportation system.

Whatcom County’s transportation system is a network of structures – highways, arterial streets, rural roads, rail, marine, airport, bikeways, ferries, and many other facilities. At the same time, the transportation system is a link among land use patterns, population growth, economic opportunities, energy consumption, environmental stress, and other facets of Whatcom County growth. The Growth Management Act requires the county to plan for the future of both network and linkage aspects of the transportation system.

Comprehensive Plan, Chapter 6 at 6-3 (emphasis added).

As proposed, the Gateway Terminal will overwhelm the current capacity for rail traffic between Bow and the Custer Spur. Furthermore, by not detailing a solution to this problem, the Terminal will impose uncompensated requirements for public expenditures on the City of Bellingham and Whatcom County to mitigate the effects of additional rail traffic. The project description is incomplete without a specific proposal for increasing rail capacity between Bow and the Custer Spur.

II. A Rail Choke Point Currently Exists Between Bow And Ferndale

In December 2006, the Washington State Transportation Commission released its Statewide Rail Capacity and System Needs Study. The purposes of the study were to:

• Assess rail needs in the State;
• Determine the State’s interest in the rail system;
• Develop policies to govern the State’s participation in the rail system; and
• Develop a plan for managing the rail lines, railcars, and service rights owned by the State.

(Rail Capacity Study at 1). The Commission concluded that the rail system in general is nearing capacity, and that “some half dozen sections are chronic choke points, causing delays that ripple across the entire Washington State and Pacific Northwest rail system.” (Rail Capacity Study at 3).

A critical choke point now exists between Bow and Ferndale. (Rail Capacity Study at 24; Figure 4) (attached).

The problem is that only one track runs between Bow and Ferndale. This means that only one train can run the entire stretch at a time.

At any time, a train must have exclusive occupancy of the track on which is it located as well as the track in front of the train that is within stopping distance. Thus, it may be necessary for a train to have exclusive right to several miles of track at any time. On main lines, the signal system determines the amount of track ahead of the train that the train must occupy. On a single track line, a train must occupy the segment of line between sidings exclusively as well.

(TSM Study at 6-7). Communitywise Bellingham commissioned Transportation Safety Management to study whether the current rail lines could handle the increased traffic from the proposed terminal.

TSM concluded that the current line could handle only 15 train trips per day --three more than exist now.

Travel time for a freight train through the capacity-limiting segment between Bow and Ferndale is 48 minutes. That generates a theoretical capacity of 31 trains per day (24 hours / 0.8 hours), which is a practical capacity of 15 trains. Previous to the current economic downturn, normal traffic on the line would regularly reach 12 trains per day, including the four Amtrak trains. Thus, any expected increase in normal traffic, freight or passenger, would require additional infrastructure.

(TSM Study at 14). This confirms the Rail Capacity Study, which concluded that the Bow to Ferndale segment had a capacity of 14 train trips per day. (Rail Capacity Study at 22; Figure 3).

The rail lines between Bow and Ferndale run at or near practical capacity today. As described in the next section, the Terminal’s developer must somehow find capacity for an additional 18 trips per day.

III. The Terminal Will Overwhelm Existing Rail Capacity

On February 28, 2011, the Terminal’s developer submitted its Project Information Document, relying on it to meet the County’s requirements for a major project permit. The Document specifically addressed the question of railroad capacity as required under WCC 20.88.130(5). In the original Document, the developer disclosed that the Terminal will generate 18 additional train trips along the Bow to Ferndale segment.

At full operational capacity, up to 9 trains (18 train movements) per day may use the terminal. Most trains serving the Terminal are anticipated to be approximately 8,500 feet long. Although the Terminal would be designed to have the capacity to stage trains up to 8,500 feet, initially trains would be no more than 7,000 feet long. The overall rail system has adequate capacity to handle the rail needed for the Terminal, though improvements are proposed to the Custer Spur by BNSF Railway to accommodate the future, local rail needs within the Cherry Point Industrial Area.

(Original Public Information Document § 5.6.3 at 5-128) (emphasis added). The italicized statement is inaccurate. There is not adequate capacity. The railroad corridor through Bellingham is already operating at or near capacity. There is no additional room to serve even the 10 train movements a day planned for the first phase of the Terminal’s operation.

Tacitly acknowledging this lack of capacity, on March 5, 2012, the Terminal’s developer submitted a revised final Public Information Document, deleting all references to the project’s effects on rail service. Rather than address the rail choke point, the revised Document states only:

The Washington State Transportation Plan identifies shortages of rail capacity as a limitation in providing the level of service necessary to meet expected growth within the state transportation network.

(Revised Public Information Document § 5.10.2 at 5-101). This is an understatement. As detailed above, the Rail Capacity Study found a lack of additional capacity on the segment between Bow and Ferndale. This is critical to the Terminal’s operation.

Furthermore, the revised Document implies that no additional work is necessary on the line.

No interdependent projects have been identified on the BNSF Railway’s mainline—Bellingham Subdivision, or any other portion of BNSF Railway’s infrastructure. BNSF Railway would be the permitting applicant for any needed permits to complete improvements on the Custer Spur. BNSF Railway would rely on this document to provide disclosure of potential effects under the requirements of NEPA and SEPA.

(Revised Public Information Document § 4.3.5 at 4-34). Yet the Terminal cannot operate without a solution to the rail choke point.

Under WCC 20.88.130(5), essential rail facilities do not currently exist for the proposed Terminal. The developer must double the capacity of the current rail line to make the Terminal operational.

IV. The Proponent Must Show How It Will Double Existing Rail Capacity

To date, the Terminal’s developer has not identified how it will find capacity for 18 additional train trips. Past Washington State studies, however, have identified specific projects for increasing capacity in this corridor.

The 2006 comprehensive Statewide Rail Capacity and System Needs Study included a companion analysis of capacity projects for the 2006 Amtrak Cascades Operating and Infrastructure Plan. That plan was, in turn, the basis for the summary 2007 Long-Range Plan for Amtrak Cascades. To eventually accommodate 4 daily round trips and substantially faster (110 mph) trains on the Amtrak Cascades route to Vancouver, B.C, the plan recommended building a train siding in South Bellingham, effectively doubling the capacity of the line. As the TSM study describes,

The optimum location for a siding to provide the required capacity would be as close as possible to half way (in travel time) between Bow and Ferndale. That location would have been somewhere south of Chuckanut Bay. It would have been very costly construction with potentially significant environmental consequences. The resulting inter-siding travel times would have been more than 20 minutes, still the longest inter-siding travel times on the line. The Bow-Ferndale segment would have twice the capacity, but would still limit capacity of the line to less than the other segments.

The solution that was developed for the final plan, extending the Samish and South Bellingham sidings, provided the greatest benefit for the expenditure, would be less costly then a siding south of Chuckanut Bay, and have smaller environmental consequences than a siding south of Chuckanut Bay.

(TSM Study at 11).

The state studies recognized difficulties with this Bellingham siding and seriously examined alternatives. The first was rejected because it would not work,

Extending the siding is difficult, but a new siding north of Bellingham does not meet the capacity requirement. It would extend the running time between meeting points (Samish and a new siding north of Bellingham) so they are similar to the current single track running time between Bow and South Bellingham, providing no capacity improvement.

(Amtrak Cascades Operating and Infrastructure Plan at 4-26).

The second alternative was rejected because of even greater costs and environmental impacts of two sidings required for the same capacity,

Two sidings, one extending the existing South Bellingham siding southward and a new siding extending north from the north end of Bellingham yard would also provide the required capacity; however, it would require a new or expanded tunnel at the south end of the current South Bellingham siding, a causeway and bridge crossing Chuckanut Bay, and some extensive bridge and embankment construction north of Bellingham yard.

(Amtrak Cascades Operating and Infrastructure Plan at 4-27).

Communitywise Bellingham does not advocate any particular solution. But as past studies have established, any solution will be located in Whatcom County, will have a host of financial and environmental consequences, and will be well beyond the means of local jurisdictions to mitigate. This is not surprising given that the Terminal would add more traffic in a few years than normal growth created in the last 50.

V. Federal Law Limits Burlington Northern’s Financial Responsibility for Mitigating Rail Impacts, Transferring the Cost to Local Taxpayers.

The Terminal’s developers must identify how they intend to increase rail capacity through Bellingham, in part because it affects public funding for the necessary infrastructure. By failing to propose any solutions to the existing rail choke point, the Terminal’s developers shift all financial responsibility to the public. Doubling train capacity through the Bellingham waterfront will have significant effect on the built environment.

A complicated web of federal statutes and regulations limit the amount class I railroads like Burlington Northern pay in mitigation. For example, under 23 CFR § 646.210(b)(3), the railroad is responsible for only 5% of the project costs to close an existing grade crossing with warning devices in place. If the railroad corridor through Bellingham becomes so congested that railroad crossings are impractical, the public, not the railroad, must foot a large proportion of the bill.

VI. The Environmental Impact Statement Must Carefully Examine The Full Range of Impacts From Doubling Rail Capacity Through Bellingham

At this early stage of the project, Communitywise Bellingham and other interested parties can only outline the potential impacts from the Terminal and its pressure on existing rail lines. The Terminal’s developers and Burlington Northern have made analysis more difficult by refusing to disclose specific plans for accommodating the increased train traffic. However, even with the developer’s vague statements, the potential detrimental impacts on Bellingham from a new, congested rail siding along the waterfront are obvious. These impacts include but are not limited to:

Economic:

• Current waterfront businesses: The siding would intermittently block access to the Alaska Ferry Terminal and adjacent businesses as well as maritime industry access to the boat launch at the Padden Creek lagoon. It would permanently block direct vehicle access to Woods Coffee located in Boulevard Park. The locomotives’ southern idling area would be located in close proximity to the Chrysalis Hotel, possibly decreasing the hotel’s appeal with increased rail noise and exhaust levels.
• Redevelopment of the Georgia Pacific site: The siding would result in closure of vehicle access via Wharf Street to redevelopment of Georgia Pacific site. This represents a barrier to access for all forms of the site’s redevelopment including light industries near the Port’s International Terminal. It eliminates a logical route for Bellingham and regional vehicular access to the waterfront including the beach at the base of Wharf Street, planned new parks at the south of the site and the wide park promenades along the waterway leading to Central Avenue. This can be mitigated, but it would take a carefully designed and costly structure to accommodate the many challenges this closure presents.

Health:

• Coal trains will have three leading and two trailing diesel locomotives. The train indicated on CWB’s map is to scale and shows approximate locations of engines in a typical situation. The locomotives would idle at the siding for periods of time, producing exhaust beyond what a passing train may emit. Note that regardless of precise location on this active siding, diesel emissions will be adjacent to parks and population centers. Exposure to diesel particulate matter has shown to cause severe health impacts. Two recent studies show greater exposure linked to steadily higher cancer rates.

Marine:

• A waterfront siding would increases the amount of time that the surface area of coal on a 150-car unit train (1.7 acres of surface area) will be exposed to rain and draining leachates onto the roadbed along the waterfront. Studies from coal piles have documented adverse affects on terrestrial and aquatic life. Studies have established that coal dust events increase during acceleration, deceleration, and passing an oncoming train — they are at a maximum when trains are accelerating between 15 and 30 miles per hour. With this siding, all of these conditions will be present on a routine basis.

Recreation:

• The siding would result in the permanent closure of vehicle access from Bayview Drive at Boulevard Park as well as pedestrian access from the South Bay Trail at the north end of the park.
• The siding would be built on the waterside of tracks requiring riprap fill into the bay in several locations, including the highly utilized beaches at Boulevard Park.

Emergency response time and traffic:

• The siding can be expected to impact the frequency and duration of traffic closures at F and C Streets, key access points for Holly Street. A Gibson Traffic Consultants’ study detailed the potential increase in city traffic and delay time for emergency responders. Footnote
• These traffic delays may also delay emergency response times, affected residents’ health and safety.

Other potential impacts and possible mitigation opportunities are detailed in the CWB report, “Gateway Pacific Terminal Train Impacts on the Bellingham Waterfront.”

VII. Location Of the Rail Siding Affects Future Studies

The Terminal’s developers and Burlington Northern must disclose their plans for a South Bellingham siding or alternative rail infrastructure before Whatcom County can adequately examine the environmental and community impacts from the proposed Terminal. For example, an expanded rail corridor will alter restoration plans for Padden Creek and lagoon, create safety hazards through Bellingham’s waterfront developments, and will require expensive mitigation that the public must fund.

Therefore, it is essential that both Burlington Northern and the Terminal’s developers reveal exactly how they will route rail traffic through Whatcom County. This must be a core section of the EIS to fully analyze the impacts from this project. All infrastructure required to address the requisite near doubling of the current rail line’s present capacity needs to be addressed in the EIS process. Failure to consider such infrastructure could profoundly skew later studies.

Communitywise Bellingham respectfully requests the Co-Lead Agencies to require the developer of the Gateway Pacific Terminal to disclose how it will double rail capacity between Bow and Ferndale. Without this disclosure, the County, the City of Bellingham and the public cannot adequately review the project and its long-term consequences.

Sincerely,

BURI FUNSTON MUMFORD, PLLC

Philip J. Buri

Puget Sound Advocates for Retirement Action Organization (#8894)

Date Submitted: 01/18/2013
Location: Seattle, WA
Comment:
The Puget Sound Advocates for Retirement Action voted to indicate our opposition to the construction of a deep water coal terminal at the Bellingham Cherry Point location. As a multi generational organization with a large proportion of seniors, we believe that the issue of climate change is the transcendent issue of this time in history. As one of our members said, "we are cooking the planet with the use of fossil fuels." We have a legacy and obligation to do all that we can to diminish the use of fossil fuels which is destroying air quality and negatively impacting the health and well being of all living things. In addition, the increase in train traffic will have a deleterious impact on the movement of people in the Puget Sound region.

We call on the Army Corp of Enginners to consider and include in your EIS the overall crisis our planet is facing and the negative impact the use of fossil fuels like coal are having on present and future life on the planet. If the Army Corp of Engineers is charged with making a recommendation through the EIS process, we urge you to recommend that the plans to build the deep water coal terminal not be approved.

Regna Merritt (Oregon Physicians for Social Responsibility) (#12222)

Date Submitted: 01/22/13
Location: Portland, OR
Comment:
Please see attached scoping comments

Thank you!
Regna Merritt


--
--
Regna Merritt
Oregon Physicians for Social Responsibility
812 SW Washington Street, Suite 1050
Portland, Oregon 97205
O: 503.274.2720
C: 971.235.7643
regna@oregonpsr.org
www.oregonpsr.org
Find us on Facebook
Attached Files:

Richard Brisbee & Sustainable Edmonds (#5089)

Date Submitted: 12/17/12
Location: Edmonds, WA
Comment:
see attached
Attached Files:

Richard Hadley (Greater Spokane Incorporated) (#4130)

Date Submitted: 12/06/12
Location: Spokane, WA
Comment:
see attached
Attached Image:

Rick Eichstaedt (#11525)

Date Submitted: 01/17/13
Location: Spokane, WA
Comment:
Justice and The Lands Council.

Rick Eichstaedt
Attorney
35 West Main, Suite 300
Spokane, Washington 99201
Phone: (509) 835-5211
Fax: (509) 835-3867
Attached Files:

Rick Eichstaedt (Center for Justice) (#12195)

Date Submitted: 01/22/13
Location: Spokane, WA
Comment:
Please find attached comments for consideration in the environmental review process for the Proposed Gateway Pacific Terminal and Custer Spur Projects. A copy of these comments with attachments is being sent via U.S . Mail. The website and your email are unable to accept larger attachments.

Rick Eichstaedt
Attorney
35 West Main, Suite 300
Spokane, Washington 99201
Phone: (509) 835-5211
Fax: (509) 835-3867
Attached Files:

Rick Eichstaedt (Center for Justice) (#12284)

Date Submitted: 01/22/13
Location: Spokane, WA
Comment:
See attached
Attached Files:

Rick Till (Friends of the Columbia Gorge) (#13686)

Date Submitted: 01/21/13
Comment:
Mr. Perry and Mr. Schroeder,

I revised one of the attachments to my prior e-mail, reducing the number of pages and size of the document. Please find the revised document. Also, for your convenience, I created a single PDF file with all four documents combined. The attached PDF includes a cover letter, comment, declarations, and derailments news articles.

Thanks,

Richard Till, Conservation Legal Advocate
Friends of the Columbia Gorge
rick@gorgefriends.org
Direct: 971-634-2032
General Office: 503-241-3762
Fax: (503) 241-3873

Become a Friend of the Columbia Gorge at www.gorgefriends.org
Attached Files:

Robert May (WA Assoc of Naturopathic Physicians) (#5876)

Date Submitted: 12/27/12
Location: Seattle, WA
Comment:
see attached
Attached Files:

Robert May (WA Association of Naturopathic Physicians) (#14452)

Date Submitted: 01/09/13
Location: Seattle, WA
Comment:
See attached.
Attached Image:

Ross Eisenberg (#11772)

Date Submitted: 01/22/2013
Location: Washington, DC
Comment:
Attached are the written comments of the National Association of Manufacturers, the largest manufacturing association in the United States, representing nearly 13,000 small, medium and large manufacturers in all 50 states.
Attached Files:

Russell Roseberry (#4452)

Date Submitted: 12/12/2012
Location: Vancouver, WA
Comment:
Friends of the Ridgefield National Wildlife Refuge
PO Box 1022
Ridgefield, WA 98642

December 10, 2012

To Whom It May Concern:

Founded in 1996, and established as a non-profit in 2000, the mission of the Friends of Ridgefield National Wildlife Refuge (Friends) is to support, protect, and enhance the Ridgefield National Wildlife Refuge (Refuge) and its wildlife habitat, and to broaden public awareness and participation in its environmental, cultural, and educational opportunities.

The pending coal export via rail lines would impose huge risks and costs on adjacent communities and surrounding environment. The large number of trains with coal-filled rail cars would daily elevate noise and pollutants throughout our neighborhoods. These uncovered coal trains have the potential of discharging large amounts of toxic coal dust, known to be linked to lung cancer and asthma. Diesel exhaust from increased train engine traffic would also impact local air quality.

The Burlington Northern Santa Fe (BNSF) rail line runs adjacent and through the Refuge, whose purpose is to protect, enhance, and restore the natural diversity of native habitat and wildlife representative of the historic Columbia River ecosystem. Added train traffic could have significant impact to the habitat and wildlife that are dependent on it, as well as increased exposure to the visiting public and refuge employees. Access to the Refuge by the visiting public must cross BNSF rail lines. Increased train passage would impede access to the Refuge Units open to the public, and could potentially delay emergency vehicle access. Further, coal dust that will end up in the surrounding watershed of the refuge.

The Friends fully support growth of state and local economies, and understand that rail traffic is a consequence of certain economic growth projects, but coal trains bound for Asia do not yield net economic growth for Washington, and especially not for Southwest Washington. Establishing our state as a transportation middleman between coal mines in Wyoming and Montana and coal plants in Asia does not lead to economic prosperity. It does lead to degradation of the environment and as a result, a diminished quality of life.

The Friends ask you to press for in-depth analysis of impacts of coal exports on Southwest¬ Washington especially in ecological significant and sensitive areas such as the Refuge and to publicly apply your leadership to object to development of regulations and environmental protection for coal export projects.

With great concern,

Russell Roseberry

For the Board,
Board of the Friends of the Ridgefield National Wildlife Refuge

Russell Russell Roseberry (#4941)

Date Submitted: 12/18/2012
Location: Vancouver, WA
Comment:
December 11, 2012

To whom it may concern:

Founded in 1996, and established as a non-profit in 2000, the mission of the Friends of Ridgefield National Wildlife Refuge (Friends) is to support, protect, and enhance the Ridgefield National Wildlife Refuge (Refuge) and its wildlife habitat, and to broaden public awareness and participation in its environmental, cultural, and educational opportunities.

The pending coal export via rail lines would impose huge risks and costs on adjacent communities and surrounding environment. The large number of trains with coal-filled rail cars would daily elevate noise and pollutants throughout our neighborhoods. These uncovered coal trains have the potential of discharging large amounts of toxic coal dust, known to be linked to lung cancer and asthma. Diesel exhaust from increased train engine traffic would also impact local air quality.

The Burlington Northern Santa Fe (BNSF) rail line runs adjacent and through the Refuge, whose purpose is to protect, enhance, and restore the natural diversity of native habitat and wildlife representative of the historic Columbia River ecosystem. Added train traffic could have significant impact to the habitat and wildlife that are dependent on it, as well as increased exposure to the visiting public and refuge employees. Access to the Refuge by the visiting public must cross BNSF rail lines. Increased train passage would impede access to the Refuge Units open to the public, and could potentially delay emergency vehicle access. Further, coal dust that will end up in the surrounding watershed of the refuge.

The Friends fully support growth of state and local economies, and understand that rail traffic is a consequence of certain economic growth projects, but coal trains bound for Asia do not yield net economic growth for Washington, and especially not for Southwest Washington. Establishing our state as a transportation middleman between coal mines in Wyoming and Montana and coal plants in Asia does not lead to economic prosperity. It does lead to degradation of the environment and as a result, a diminished quality of life.

The Friends ask you to press for in-depth analysis of impacts of coal exports on Southwest Washington especially in ecological significant and sensitive areas such as the Refuge and to publicly apply your leadership to the development of regulations and environmental protection for coal export projects.

With great concern,

Russell P. Roseberry

For the Board,
Board of the Friends of the Ridgefield National Wildlife Refuge
Po Box 1022
Ridgefield, WA 98642

Sarah Crosby (League of Women Voters of the San Juans (#11747)

Date Submitted: 01/16/13
Location: Friday Harbor, WA
Comment:
see attached
Attached Files:

Scott Somohano (#4145)

Date Submitted: 12/07/2012
Location: Portland, OR
Comment:
I am chair of Sumner neighborhood association in NE Portland Oregon. Our neighborhood maps closely to Census Tract 77 in Multnomah County. We border both I-205 freeway and have a Northern Pacific rail line through our neighborhood.

The Oregon Dept of Environmental Quality indicates that our neighborhood already has some of the poorest air quality in the state. We understand and accept that situation. However, running 16-20 coal trains each day each 1.5-miles long poses an unnecessary additional risk to the air quality & public health of residents in this neighborhood -- and all over the northwest.

Similarly, we are close to the Columbia River where I-205 crosses at Government Island. Coal barges on the Columbia would also be an unwelcome health risk. We get some of the high Gorge winds in this part of town, and the impact from daily coal dust would be unwelcome.

There are other concerns as well -- noise and disruption at RR crossings -- but the grave chronic threat to public health and air quality from coal dust is my primary concern.

Please include the public health and air quality impact of coal transportation methods in your EIS for the entire shipment route from the mine, through the Gorge and Portland or Vancouver to Bellingham. That is the true scope of this proposal -- not just the Cherry Point terminal itself -- and so the EIS should reflect that reality. This impacts all of us along the way. Thank you for your hard work and public service.

Shannon Wright (#1865)

Date Submitted: 10/23/12
Comment:
Attached please find a GPT scoping comment from Communitywise Bellingham. The law offices of Phil Buri have send a hard copy complete with attachments as well.

Please do not hesitate to contact me for additional information or clarification.

Sincerely,

Shannon Wright
360-510-4766
Attached Files:

Shannon Wright (Communitywise Bellingham) (#12225)

Date Submitted: 01/22/13
Comment:
Dear EIS Agencies,

Thank you for your reviewing our submission. Please contact me if you need any additional information or clarification.

Regards,

Shannon Wright
36O-51O-4766

Dear EIS Agencies,

Thank you for your reviewing our submission. Please contact me if you need any additional information or clarification.

Regards,


Dear EIS Agencies,

Thank you for your reviewing our submission. Please contact me if you need any additional information or clarification.

Regards,

Shannon Wright
36O-51O-4766
Attached Files:

Stephanie Buffum Field (#9268)

Date Submitted: 01/19/2013
Location: Friday Harbor, WA
Comment:
Dear Co-Lead Agencies’ Representatives Ms. Kelly (DOE), Mr. Perry (USACE), and Mr. Schroeder (Whatcom County):

Thank you for this opportunity to provide scoping comments for preparation of an Environmental Impact Statement (EIS) for the Pacific International Terminals Inc.’s proposed Gateway Pacific Terminal project at Cherry Point, Washington and the Burlington Northern Santa Fe Railway’s (BNSF’s) Custer Spur Rail Expansion project (“GPT”). Please accept as the official filing from FRIENDS of the San Juans the attached letter and the attached Summary Itemization of Analyses Needed to Assess and Evaluate Concerns document which has appended numerous supporting Scoping Memorandums and interactive links to the internet.

Sincerely,
Stephanie Buffum Field
Executive Director
FRIENDS of the San Juans
Attached Files:

Stephanie Buffum Field (#11474)

Date Submitted: 01/22/2013
Location: Friday Harbor, WA
Comment:
Dear Mr. Perry, Ms. Summerhays and Mr. Schroeder:
Thank you for this opportunity to provide scoping comments for preparation of an Environmental Impact Statement (EIS) for the Pacific International Terminals Inc.’s proposed Gateway Pacific Terminal project at Cherry Point, Washington and the Burlington Northern Santa Fe Railway’s (BNSF’s) Custer Spur Rail Expansion project (hereinafter collectively referred to as “GPT”). Please accept the following comments from Friends of Alaska National Wildlife Refuges and FRIENDS of the San Juans.

Sincerely,
Stephanie Buffum Field
Executive Director, FRIENDS of the San Juans
Attached Files:

Steve Erickson (#11865)

Date Submitted: 01/22/2013
Location: Langley, WA
Comment:
Please find Whidbey Environmental Action Network's (WEAN) EIS scoping comments attached. Please inform me if these comments have been received.
Attached Files:

Tamara Schiff (Cascadia Wildlands) (#12221)

Date Submitted: 01/22/13
Location: Eugene, OR
Comment:
Dear Mr. Perry,

Attached please find scoping comments submitted on behalf of Cascadia Wildlands, an environmental nonprofit organization. These comments were also submitted via the online form. Thank you for your thorough consideration of the potential impacts of the proposed Gateway Pacific Terminal.

Best regards,

Tamara Schiff
Public Interest Fellow
Cascadia Wildlands
Attached Files:

Teresa Anderson (Cliffside Community Club Board of Trustees) (#7724)

Date Submitted: 01/08/13
Location: Bellingham, WA
Comment:
see attached
Attached Files:

Terry Wechsler (Protect Whatcom) (#8400)

Date Submitted: 01/11/13
Comment:
Please see the comment of Protect Whatcom, attached. Please acknowledge receipt.

Thank you.

Terry J. Wechsler
Bellingham, WA
Attached Files:

Terry Weschler (Project Whatcom) (#12224)

Date Submitted: 01/22/13
Comment:
Attached please find Protect Whatcom's request that the GPT EIS include a comprehensive Economic Impact Assessment.

Please confirm receipt. Thank you very much for your attention.
Terry J. Wechsler
Bellingham, WA
360-656-6180 (r), 541-913-5976 (c)
Attached Files:

Terry Weschler (Protect Whatcom) (#12180)

Date Submitted: 01/18/13
Location: Bellingham, WA
Comment:
Attached please find Protect Whatcom's comment on the alternatives analysis for the Gateway Pacific Terminals EIS. Thank you for including this in the record for the agency co-leads' consideration.

Given recent issues with e-mail submissions, acknowledgement of receipt would be appreciated.

Thank you very much.
Terry J. Wechsler
Bellingham, WA
360-656-6180 (r), 541-913-5976 (c)

Attached please find Protect Whatcom's comment on the need for the EIS to measure the net negative impact on jobs if the currently proposed coal terminal were constructed in Whatcom County.

Given recent issues with e-mail submissions, please confirm receipt.

Thank you very much.
Terry J. Wechsler
Bellingham, WA
360-656-6180 (r), 541-913-5976 (c)
Attached Files:

Terry Weschler (Protect Whatcom) (#12182)

Date Submitted: 01/20/13
Location: Bellingham, WA
Comment:
Please see attached and add this comment to the record.
Terry J. Wechsler
Bellingham, WA
360-656-6180 (r), 541-913-5976 (c)
Attached Files:

Thornton Creek Alliance (#11730)

Date Submitted: 01/22/2013
Location: Seattle, WA
Comment:
The Thornton Creek Alliance of Seattle and Shoreline has serious concerns about the proposed project and its transit corridors. This plan is regressive and antithetical to the ideals of sustainability and a healthy environment that so many of our communities are working toward today.

As advocates for a sustainable Thornton Creek watershed we cannot sit silent while this unsound proposal works its way through the permitting process. Some would say that it is a choice between ecology and employment, but according to an article in the Bellingham Herald (http://www.bellinghamherald.com/2012/03/06/2424393/study-proposed-cherry-point-coal.html) the Cherry Point Terminal could actually result in a net loss of local jobs.

We strongly urge that the EIS for the Cherry Point project include not just the terminal portion and the marine corridors through the San Juan Islands, but also any inland routes that the trains may use on their journey from the mines to the port. Deleterious environmental, economic, and health impacts would be occurring all along the way, and they must be calculated and considered. Any other method will render the Cherry Point EIS inadequate.

The best approach is the Programmatic Environmental Impact Statement that would examine the combined effects of all the terminals and rail schedules currently proposed for the Pacific Northwest. Please do not permit any work until a comprehensive PEIS is completed, one that includes environmental, health, and economic effects caused by the processes here at home, and also the environmental degradation caused by the consumers of this coal, which would have a worldwide effect.

Thank you for your consideration.

Sincerely,

Ruth Williams
President, Thornton Creek Alliance
P.O. Box 25690
Seattle, WA 98165-1190

TCA is an all-volunteer grassroots, nonprofit organization of 115 members dedicated to preserving and restoring an ecological balance throughout the Thornton Creek watershed. Our goal is to benefit the watershed by encouraging individuals, groups, schools, businesses, and government to work together in addressing the environmental restoration of the creek system including: water quality, stabilization of water flow, flood prevention, and habitat improvement through education, collaboration, and community involvement.

Timothy Manns (#8578)

Date Submitted: 01/17/2013
Location: Mount Vernon, WA
Comment:
January 17, 2013

GPT/BNSF Custer Spur EIS
c/o CH2MHill 1100 112th Avenue Northeast, Suite 400
Bellevue, WA 98004

Attn: Mr. Randel Perry, U.S. Army Corps of Engineers; Ms. Alice Kelly, Washington State Department of Ecology; and Mr. Tyler Schroeder, Whatcom County Planning Department

RE: Scoping Comments for GPT/BNSF Custer Spur EIS, Topic: Effects on birds and other wildlife

Dear Mr. Perry, Ms. Kelly and Mr. Schroeder:

I am writing as president of Skagit Audubon Society on behalf of the 200 member families of the National Audubon chapter centered in Skagit County, Washington. Skagit Audubon’s mission is to conserve and restore natural ecosystems, focusing on birds, other wildlife and their habitats for the benefit of humanity and the earth’s biological diversity. Puget Sound and the islands and straits to its north are an important area for birds, particularly in winter. Many of us have chosen to live here in part because of the bird species and abundance which the forests, fields, shorelines, and bays of Skagit County support. The area of the proposed Gateway Pacific Terminal and the rail line serving it are close to especially important areas for birds. We are concerned about the impact which the coal trains, terminal operations, and coal-carrying ships would have on these populations. These impacts will affect the birds and will thereby also affect our quality of life as people who value living in a place with healthy and abundant wildlife populations.

We are concerned that the operation of the proposed terminal and the associated trains and coal ships will significantly impact bird populations both directly and also by degrading their required habitats. These impacts could occur around Cherry Point but also any other place where the coal-carrying trains cross waterways, run along bays, or pass through fields and forests, and in the waters through which coal-carrying ships would pass. We request that you study and include in the E.I.S. the full range of effects on birds and other wildlife from the Powder River Basin to Cherry Point and on to the Asian points of delivery. The following paragraphs include more specific examples of what we request that the study include.

Please study the impact on the quality of bird habitat of diesel particulates and fumes from ships and trains associated with the proposed project from the Powder River Basin to Cherry Point and across the Pacific Ocean to the eventual destinations of the coal.

Please study the impact of coal dust blown from trains from the Powder River Basin to Cherry Point and from coal piles at the proposed Cherry Point terminal, on birds and their food species. How will coal dust affect the eelgrass of Samish and other bays on which the world’s entire population of Gray-bellied Brant geese depend in winter? How will coal dust affect the population of Great Blue Herons which feed by the thousands in fields and bays passed by the rail line? Great Blue heronries on bay shorelines in Skagit County include the largest in the western United States and several others of very significant size. These birds depend on the environmental quality of the bays and fields for their food. These birds are here in such high numbers because of the present biological richness of the habitat. Please study what specific effects the proposed project, including terminal, trains, and ships, could have on these habitats in relation to the biological needs of the full range of bird species which utilize them.

Please study and include in the E.I.S. an analysis of how the terminal and shipping operations at Cherry Point would affect the herring spawning at the Cherry Point Aquatic Reserve on which Surf Scoters, Harlequin Ducks, and other species depend at key points in their life cycles. The population of Surf Scoters wintering in Puget Sound, the straits, and bays has already declined almost to half of what it was historically. The Puget Sound Partnership, charged with restoring Puget Sound, uses Surf Scoter numbers and those of other declining sea birds such as the Western Grebe, as indicators of environmental quality or distress. How will coal export operations at Cherry Point affect the Surf Scoter population given that this sea duck species feeds on herring eggs and bivalves? How will these operations affect Western Grebes, which feed on forage fish?

Herring are an important forage fish, a component of the base of the food chain for many species, including federally listed chinook salmon, which are in turn fed upon by federally listed orcas. How will terminal operations at Cherry Point affect this food chain? Please study the effects of coal dust there and blown off of trains passing along Samish Bay, Port Susan Bay, and equivalent areas on eel grass meadows and on the species dependent on this particularly important habitat.

Please include in the E.I.S. an analysis of how the proposed Cherry Point terminal, the coal-carrying trains supplying it, and the ships being loaded at the terminal will impact a range of other marine animals and plants from orcas to bull kelp, and study how this will affect the State of Washington’s ability to accomplish the urgently needed restoration of Puget Sound.

Please study how fuel spills from coal-carrying ships would impact the many sea birds wintering on the bays of Puget Sound, the Straits, and the San Juan Islands which move widely among these areas. Please specifically study the effects of the various components of the proposed project, including associated trains, any new rail infrastructure, and coal ships on the federally-listed and declining Marbled Murrelet, which depends on healthy forage fish populations in these waters.

Please also study the cumulative effects on marine birds of the coal-carrying ships added to the existing marine traffic all the way from Cherry Point, past the San Juan Islands, out to the Pacific, and along the likely route to Asia through the Aleutians via Unimak Pass.

Increasing CO2 in the atmosphere is causing increased acidification of the oceans, including the waters of Puget Sound and the straits. This affects marine creatures in a number of ways, including inhibiting reproduction and shell formation by bivalves. As filter feeders, bivalves are an essential element of the local marine ecosystem and are also an important food source for a variety of birds and other marine animals. Please study how the coal sent from the proposed Gateway Pacific Terminal to be burned overseas will affect global warming and ocean acidification. Please also include in the E.I.S. analysis of how mercury and other toxics emitted by coal-fired power plants in Asia burning Powder River coal will affect the environment in the U.S. when they reach here on the prevailing winds.

Studying the effects which the Gateway Pacific Terminal and its associated coal trains and coal-carrying ships would have on birds due to diesel fumes and particulates, fuel and coal spills, and coal dust is particularly significant because of the importance this has for wintering marine bird species. These include 3 or more species of loons, 5 different grebes, 3 cormorant species, many species of ducks, 5 species of geese, and 2 species of swans. Most of the world population of Trumpeter Swans, North America’s largest waterfowl and a species once near extinction, winters in Whatcom, Skagit, and Snohomish Counties, to which the swans migrate from breeding areas in Alaska and western Canada. The heaviest concentrations of Trumpeter Swans are in Skagit County, where they feed in the shallow bays and harvested farm fields. Some of these bays, such as Samish Bay, and many of these fields lie directly along the rail line which 18 coal trains will use each day to reach the proposed terminal at Cherry Point. Please study how dust coming off these uncovered coal cars and landing in the bays and on the fields will affect Trumpeter Swans and the Tundra Swans and Lesser Snow Geese often in the same areas. Please study the cumulative effects on Trumpeter and Tundra Swans and Snow Geese of the coal dust and the particulates and fumes from diesel locomotives in regards to the birds’ health and reproductive success. The nutritional quality and quantity of their winter food relates directly to reproduction on their summer breeding ranges.

Living in a place where populations of such magnificent wild animals as Trumpeter Swans, Snow Geese, Marbled Murrelets, and Harlequin Ducks live and thrive is very important to Skagit Audubon members. Decreases in bird populations or diversity would degrade our quality of life by impacting something central to our lives. It would deprive us of our choice to leave these natural resources to our children, grandchildren, and to all future generations. If any harmful effects on wildlife cannot be 100% mitigated in the construction, supplying, and operation of the proposed Gateway Pacific Terminal, we recommend the “no action” alternative.

Thank you for your consideration of our requests for topics to be included in the Environmental Impact Statement.

Sincerely,

Timothy Manns
President, Skagit Audubon Society

Timothy Seifert (San Juan Preservation Trust) (#14206)

Date Submitted: 01/10/13
Location: Lopez Island, WA
Comment:
See attached.
Attached Image:

Tom Glade (#2720)

Date Submitted: 11/12/2012
Location: Anacortes, WA
Comment:
On behalf of Evergreen Islands, I am submitting the attached comment letter regarding the Gateway Pacific Terminal and Custer Spur Projects EIS.

Respectfully yours,

Tom Glade
President, Evergreen islands
Attached Files:

Tom Ikeda (#10278)

Date Submitted: 01/21/2013
Location: Seattle, Wa
Comment:
See attached letter (pdf)
Attached Files:

Tom Skjervold (Nisqually Delta Association) (#12190)

Date Submitted: 01/22/13
Location: Olympia , WA
Comment:
To whom it May Concern:

Please regard this letter as a part of the public record for the Gateway Pacific Terminal coal export project proposed for Cherry Point, Whatcom County, Washington, Facility Site ID #22237. We believe that the impacts of coal export at Cherry Point extend throughout the State of Washington, and in fact have real world implications for all of the people of this planet, and need to be considered in those terms.

The Nisqually Delta Association notes that Washington State is currently working to phase out the use of coal in electrical generation that does not meet State Department of Ecology air quality standards (Trans Alta mine in Centralia, Washington.)

As citizens of the planet, we are concerned that insufficiently regulated burning of coal is one of the greatest contributors to both green house gases and fine particulate in the atmosphere upon which we fundamentally depend. The Gateway Pacific Terminal project at Cherry Point, Washington has the potential to move coal to areas where less stringent air quality standards are currently employed, and thus it seems sending such shipments through the state will ironically exacerbate a problem that Washington State is trying to address in our own boundaries.

We therefore ask that the EIS include in its scope an examination of methods that might be used to mitigate the impacts of the coal’s use. Our recommendation is that the State of Washington set up agreements that any plant that would burn coal that passes through a Port of the State be compelled by agreements and statute to only be burned in plants that meet the same air quality standards that would be enforced here at home. If such contractual agreements were developed in advance of the trans-shipment of the coal through the proposed Gateway Pacific Terminal, it would potentially reduce the ecological damages inflicted on the global atmosphere that all the world’s people share.

Further, agreements to compel the use of the standards that we in Washington believe are necessary to protect the health and well being of the people of our State, would also, over time, prove to be an effective way to begin to shift the burden of protecting against the environmental and economic losses to those who would increase the risk of such injury. Over time, the consistent use of such a strategy would have the potential to help incentivize a move to cleaner and more sustainable energy sources around the world.


Tom Skjervold, President
Nisqually Delta Association

PO Box 4777
Olympia, WA 98501

(360) 485-9470 (mobile)

www.NisquallyDelta.org
tskjervold@gmail.com

Tracy Bier (Washington Physicians for Social Responsibility) (#4779)

Date Submitted: 12/13/12
Location: Seattle, WA
Comment:
Please accept testimony from Washington Physicians for Social Responsibility delivered during the Scoping meeting in Seattle, WA.

````````````````````````````````````````````````````````````````````````````````````````````

My name is Tracy Bier, executive director, Washington Physicians for Social Responsibility. Our group represents hundreds of physicians and health professionals around the state of Washington. WPSR is opposed to any type of coal production, transport or handling in our state. We believe the Gateway Project and others represent significant adverse impacts that should be avoided and that the health of Washington citizens --- a hugely significant resource --- will be greatly jeopardized with any new coal commerce in our state.

Physicians for Social Responsibility has done research on the effect of coal on human health. We believe the damage and costs to human health far surpasses any financial or economic benefits of any project such as Gateway. It is imperative that a Health Impact Assessment be conducted.

We would not allow corporations introduce medicines or equipment into our hospitals that will make people sicker and die more --- why would we allow corporations to introduce a process that will do this?

Major health impacts from coal are primarily caused by particulate matter from truck and train engines, leading to increased and new cases of diseases and illnesses as well as making worse already existing diseases and illnesses. Only a few examples include:

-Increasing complications and death from cardiovascular disease -Increasing asthma cases and worsening of already existing cases -Poor lung function in children and increased infant mortality

Consider who are the most vulnerable to the problems caused by coal emissions and coal transport:

Children, the elderly, anyone with pre-existing lung conditions, asthma, emphysema, diabetics --- this is millions and millions of people in our state!

In addition to particulate matter, the commerce of coal in our state will introduce increased levels of noise pollution

And on top of particulate matter and noise pollution, the longer wait times at railroad crossings is estimated to contribute significantly to more deaths in our state.

In summary, we believe that no amount of jobs or economic improvement factors justify the extreme damage to human health caused by any new coal commerce in our state. And there should be no further action on any of the current coal proposals by corporations until a Health Impact Assessment is conducted.

Please contact us for more information if we can help

Tracy Bier
Washington Physicians for Social Responsibility
--
Tracy Bier, M Ed
Executive Director
Washington Physicians for Social
Responsibility
1604 NE 50th Street
Seattle, WA 98105
www.wpsr.org
206-227-2369
206-547-2630

(see attached)
Attached Files:

Various 350.org (#12240)

Date Submitted: 01/22/13
Location: , WA
Comment:
See Attached

[NOTE FROM PROJECT TEAM: Attached are comments that were collected by and mailed from 350.org from 3,948 individuals by the end of the comment period, January 22, 2013. All comments are being reviewed by the project team and will be considered in the scoping report.]
Attached Files:

Various Cascadia Wildlands (#14160)

Date Submitted: 01/22/13
Location: , OR
Comment:
I urge the U.S. Army Corps of Engineers (USACE) to complete a thorough and comprehensive Environmental Impact Statement (EIS) for the proposed Gateway Pacific Terminal at Cherry Point, which would ship 48 million tons of coal per year to Asia. This EIS must consider the broad impacts of mining, transporting, and exporting coal via the proposed terminal. The proposed project, if approved, would have significant and disastrous impacts on communities, including on air and water quality, marine life (including several endangered species), and public health and safety.

Additionally, the proposed Gateway Pacific Terminal is part of a greater plan to export coal from several ports in Oregon and Washington. The Gateway Pacific Terminal would be the largest, but the cumulative impacts of transporting coal to and exporting coal from all of these proposed ports must be considered. Powder River Basin coal is especially friable, and mining, transporting, and exporting this coal will lead to ocean acidification, train derailments, public health issues, and water quality impairment. Several endangered fish species, including Chinook salmon, bull trout, and Puget Sound steelhead trout, are present in the Salish Sea, and the embattled Cherry Point herring are a keystone species vital to the life of many other marine species living near the project area.

Finally, the USACE must also consider the impacts of burning coal in Asia, which is the final destination of Powder River Basin coal shipped through the Gateway Pacific Terminal. Coal is a dirty fossil fuel and accelerates the impacts of climate change. I respectfully ask that the USACE prepares a thorough and comprehensive EIS considering all of the points discussed above.

[NOTE FROM THE PROJECT TEAM: INDIVIDUALS HAVE SUBMITTED COMMENTS THROUGH CASCADIA WILDLANDS' ONLINE COMMENT FORM. ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 125. PERSONALIZED COMMENTS SUBMITTED THROUGH THE COMMENT FORM WILL BE UPLOADED INDIVIDUALLY.]
Attached Image:

Attached Files:

Various Count on Coal (#14180)

Date Submitted: 01/22/13
Comment:
I fully support the construction of the proposed Gateway Pacific terminal in Cherry Point,Washington. The construction of the Gateway Pacific terminal is important to broadening the marketing opportunities for U.S. coal, agricultural and other natural resource goods at a competitive price. This project would allow producers of diverse U.S. goods to compete internationally, strengthening U.S. businesses, creating U.S. jobs and helping to improve the U.S. trade balance. I urge your support of the Gateway Pacific export terminal EIS.

[NOTE FROM PROJECT TEAM: ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 111.]
Attached Image:

Attached Files:

Various EcoWatch (#5146)

Date Submitted: 12/20/2012
Comment:
I DEMAND A THOROUGH ENVIRONMENTAL IMPACT STATEMENT THAT:

• Analyzes impacts to every community impacted by the mining, transport and burning of coal, including impacts in Montana, Idaho, Washington, India, China and Bangladesh.
• Quantifies the air, land and water pollution from coal dust that will blow off rail cars, barges, transfer stations and loading areas contaminating communities, people, wildlife and waterways with heavy metals and particulates.
• Thoroughly assesses the impacts of habitat alteration and pollutant impacts to natural resources, parks and wildlife including the rare, threatened and endangered species in the Columbia River Basin, the Puget Sound Basin and in the Cherry Point Aquatic Reserve where the terminal might be built, including impacts to threatened Puget Sound Chinook Salmon, steelhead trout and bull trout as well as endangered Southern Resident Orca Whales.
• Calculates and reports the amount of mercury, fine particulates and other air pollutants that will blow back across the Pacific Ocean and pollute Pacific Northwest after the coal has been burned in power plants in India and China.
• Analyzes the impacts to cultural and archaeological resources in tribal communities that are located in the path of the coal trains, barges and ships that will supply the Gateway Pacific Terminal.
• Assesses the likely drop in property values due to air emissions, coal dust and traffic disruption along railroad path.
• Fully assesses the increased risk of a marine accident that could result in a major oil spill in the already-crowded waters of Puget Sound and the Salish Sea, due to 900 or more container ship transits per year. This should include a major spill’s likely impact on the economy and on threatened and endangered species, including the endangered Southern Resident orca whale.
• Quantifies the carbon emissions generated by the burning and transport of the coal, as well as its impact on global climate change and ocean acidification.
• Includes a no-action alternative.

[NOTE FROM PROJECT TEAM: INDIVIDUALS HAVE SUBMITTED COMMENTS THROUGH THE ECOWATCH WEBSITE. ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 1,293. THIS WILL BE UPDATED WEEKLY. PERSONALIZED COMMENTS SUBMITTED THROUGH THE COMMENT FORM WILL BE UPLOADED INDIVIDUALLY.]
Attached Image:

Attached Files:

Various Friends of the Columbia Gorge (#12241)

Date Submitted: 01/22/13
Location: , OR
Comment:
See Attached

[NOTE FROM PROJECT TEAM: Attached are comments that were collected by and mailed from Friends of the Columbia Gorge from over 516 individuals by the end of the comment period, January 22, 2013. All comments are being reviewed by the project team and will be considered in the scoping report.]
Attached Image:

Attached Files:

Various Fuse Washington (#1087)

Date Submitted: 10/23/2012
Comment:
I strongly oppose the construction of a coal export terminal at Cherry Point, Washington and transporting strip-mined coal from Montana and Wyoming on trains and ships throughout the Northwest. It would increase traffic, pollute our air and water, harm small businesses, delay emergency vehicles, and increase hipping traffic and noise. The coal export terminal would also hurt our environment by damaging aquatic ecosystems at the terminal site, increasing the potential for serious shipping accidents, and exacerbating climate change. I urge you to consider these impacts in the scope of the Environmental Impact Statement.

There are currently five coal export proposals that would transport as much as 150 million tons through the Northwest. I urge the Army Corps of Engineers to conduct an area wide Environmental Impact Statement to assess the cumulative impact of these proposals.

[NOTE FROM PROJECT TEAM: INDIVIDUALS HAVE SUBMITTED COMMENTS THROUGH THE FUSE WASHINGTON WEBSITE. ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 141. THIS WILL BE UPDATED WEEKLY. PERSONALIZED COMMENTS SUBMITTED THROUGH THE FUSE WASHINGTON COMMENT FORM WILL BE UPLOADED INDIVIDUALLY.]
Attached Image:

Attached Files:

Various Fuse Washington (#13909)

Date Submitted: 01/22/13
Comment:
I am deeply concerned about the potential impact of coal exports on my family and community. Coal exports pose great threats to the health, safety, and environment of the Pacific Northwest. In addition, burning this coal would be a huge step backward in combating global warming

We need to have a thorough review of the risks and impacts to our communities - from mine to rail, from port to plant, and from plant to our region's air.

Please support a cumulative and comprehensive area-wide environmental impact statement is conducted that takes into account the impacts of all six proposed coal export terminals currently on the table.

[NOTE FROM PROJECT TEAM: INDIVIDUALS HAVE SUBMITTED COMMENTS THROUGH THE FUSE WASHINGTON WEBSITE. ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 144. PERSONALIZED COMMENTS SUBMITTED THROUGH THE FUSE WASHINGTON COMMENT FORM WILL BE UPLOADED INDIVIDUALLY.]
Attached Image:

Attached Files:

Various Greenpeace (#14161)

Date Submitted: 01/22/13
Comment:
I strongly oppose the construction of a coal export terminal at Cherry Point, Washington and transporting strip-mined coal from Montana and Wyoming on trains and ships throughout the Northwest. This proposal would negatively affect my community by increasing congestion and noise with more coal train traffic, polluting our air and local waterways, harming existing businesses, delaying emergency responders, damaging aquatic ecosystems and fishing grounds at the terminal site, increasing tanker traffic and the potential for serious shipping accidents and escalating climate change. I urge you to consider these impacts in the scope of the Environmental Impact Statement.

There are currently five coal export proposals that would transport as much as 150 million tons through the Northwest. I urge the Army Corps of Engineers to conduct an area wide Environmental Impact Statement to assess the cumulative impact of these proposals.

[NOTE FROM PROJECT TEAM: INDIVIDUALS HAVE SUBMITTED COMMENTS THROUGH THE GREENPEACE ONLINE COMMENT FORM. ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 1,170. PERSONALIZED COMMENTS SUBMITTED THROUGH THE COMMENT FORM WILL BE UPLOADED INDIVIDUALLY.]
Attached Image:

Attached Files:

Various National Wildlife Federation Action Fund (#1086)

Date Submitted: 10/23/2012
Comment:
I strongly oppose the construction of a coal export terminal at Cherry Point, Washington and transporting strip-mined coal from Montana and Wyoming on trains and ships throughout the Northwest.

The project will harm imperiled wildlife species and their designated critical habitat, interfere with recreational and tribal fishing, transform the region with rail congestion, and dramatically increase carbon pollution that is driving climate change. I urge you to consider these impacts in the scope of the Environmental Impact Statement.

Given the broad impact/significant effects that proposed coal export terminals will have on our natural resources and public health, strict oversight is essential.

[NOTE FROM PROJECT TEAM: INDIVIDUALS HAVE SUBMITTED COMMENTS THROUGH THE NATIONAL WILDLIFE FEDERATION ACTION FUND WEBSITE. ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 2,977. PERSONALIZED COMMENTS SUBMITTED THROUGH THE NATIONAL WILDLIFE FEDERATION ACTION FUND COMMENT FORM WILL BE UPLOADED INDIVIDUALLY.]
Attached Image:

Attached Files:

Various Resources for a Sustainable Community (#12513)

Date Submitted: 01/15/13
Comment:
See Attached

[NOTE FROM THE PROJECT TEAM: The attached comments were submitted by Resources for Sustainable Communities. We received 251 individual comment forms. All comments have been reviewed by the project team.]
Attached Files:

Various Physicians for Social Responsibility (#14179)

Date Submitted: 01/22/13
Comment:
I strongly oppose the construction of the Proposed Gateway Pacific Terminal coal export in Washington State.

This facility, as part of a larger scheme to strip-mine coal in Montana and Wyoming, transport it across the Northwest and ship it to Asia, would negatively affect the health of human communities and ecosystems in the region:

* Coal dust and diesel exhaust will contribute to serious respiratory and cardiovascular diseases.
* Coal dust creates exposure to toxic metals including mercury, a known neurotoxin, and is linked to increases in asthma, especially in children. Burlington Northern Santa Fe Railroad studies estimate that up to 500 pounds of coal dust could be lost from each car en route.
* More coal burning in Asia means more toxic air pollution, including mercury, travelling back across the Pacific to pollute West Coast rivers, lakes and fish. As professionals in the medical field, we are concerned about health in our backyard, AND the health of humans in every part of our world.

There are currently five coal export proposals that would transport as much as 150 million tons through the Northwest. I urge the Army Corps of Engineers to conduct an area- wide Environmental Impact Statement to assess the cumulative impact of these proposals.

[NOTE FROM PROJECT TEAM: INDIVIDUALS HAVE SUBMITTED COMMENTS THROUGH THE PHYSICIANS FOR SOCIAL RESPONSIBILITY COMMENT FORM. ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 945. PERSONALIZED COMMENTS SUBMITTED THROUGH THE COMMENT FORM WILL BE UPLOADED INDIVIDUALLY.]
Attached Image:

Attached Files:

Various Power Past Coal (#1085)

Date Submitted: 10/23/2012
Comment:
I strongly oppose the construction of a coal export terminal at Cherry Point, Washington and transporting strip-mined coal from Montana and Wyoming on trains and ships throughout the Northwest. This proposal would negatively affect my community by increasing congestion and noise with more coal train traffic, polluting our air and local waterways, harming existing businesses, delaying emergency responders, damaging aquatic ecosystems and fishing grounds at the terminal site, increasing tanker traffic and the potential for serious shipping accidents and escalating climate change. I urge you to consider these impacts in the scope of the Environmental Impact Statement.

There are currently five coal export proposals that would transport as much as 150 million tons through the Northwest. I urge the Army Corps of Engineers to conduct an area wide Environmental Impact Statement to assess the cumulative impact of these proposals.

[NOTE FROM PROJECT TEAM: INDIVIDUALS HAVE SUBMITTED COMMENTS THROUGH THE POWER PAST COAL WEBSITE. ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 3,250. UNIQUE PERSONALIZED COMMENTS SUBMITTED THROUGH THE POWER PAST COAL COMMENT FORM WILL BE UPLOADED INDIVIDUALLY.]
Attached Image:

Attached Files:

Various Sierra Club (#77)

Date Submitted: 09/25/2012
Comment:
I strongly oppose the construction of a coal export terminal at Cherry Point, Washington. This proposal would negatively affect my community by increasing traffic, polluting our air and water, harming existing business, delaying emergency vehicles, increasing shipping traffic and noise, damaging aquatic ecosystems at the terminal site, increasing the potential for serious shipping accidents and exacerbating climate change. I urge you to consider these impacts in the scope of the Environmental Impact Statement.

[NOTE FROM PROJECT TEAM: INDIVIDUALS HAVE SUBMITTED COMMENTS THROUGH THE SIERRA CLUB WEBSITE. ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 4,273. PERSONALIZED COMMENTS SUBMITTED THROUGH THE SIERRA CLUB COMMENT FORM WILL BE UPLOADED INDIVIDUALLY.]
Attached Image:

Attached Files:

Various Sierra Club Portland Office (#13789)

Date Submitted: 01/22/13
Location: Portland, OR
Comment:
See Attached

[NOTE FROM PROJECT TEAM: Attached are comments that were collected by and mailed from Sierra Cub Portland from 476 individuals by the end of the comment period, January 22, 2013. All comments are being reviewed by the project team and will be considered in the scoping report.]
Attached Files:

Various Sierra Club Seattle Office (#13798)

Date Submitted: 01/22/13
Location: Seattle, WA
Comment:
See Attached

[NOTE FROM PROJECT TEAM: Attached are comments that were collected by and mailed from Sierra Cub Seattle Office from approximately 1,800 individuals by the end of the comment period, January 22, 2013. All comments are being reviewed by the project team and will be considered in the scoping report.]
Attached Files:

Various Sierra Club, Spokane (#13573)

Date Submitted: 01/18/13
Location: Spokane, WA
Comment:
See attached.

[NOTE FROM THE PROJECT TEAM: Attached are comments that were collected by and mailed from the Sierra Club, Spokane Office from 450 individuals by the end of the comment period, January 22, 2013. All comments are being reviewed by the project team and will be considered in the scoping report.]
Attached Files:

Various Sierra Club, Spokane (#13581)

Date Submitted: 01/22/13
Location: Spokane, WA
Comment:
See Attached

[NOTE FROM PROJECT TEAM: Attached are comments that were collected by and mailed from Sierra Cub Spokane from 457 individuals by the end of the comment period, January 22, 2013. All comments are being reviewed by the project team and will be considered in the scoping report.]
Attached Files:

Various Western Organization of Resource Councils (#5147)

Date Submitted: 12/20/2012
Comment:
If permitted, the Gateway Pacific Terminal will generate a massive increase in trains traveling through the region. The environmental impact study on this project needs to consider the following questions and concerns from communities along the way.

What is the cost of infrastructure needed to prevent increased train traffic from imposing devastating impacts on local businesses and public safety?

Who will pay for that infrastructure: local taxpayers or the rail companies, coal companies and their Asian customers?

What are the air quality and public health implications of dozens of coal trains passing through communities?

How will massive increases in coal train volume on rail lines that are already at or near capacity affect other shippers, including agricultural commodities that currently move approximately 40 million tons per year to ports in Washington and Oregon for export markets?

How will increases in coal train volume affect Amtrak passenger service through the Pacific Northwest and the vital tourism economy of the region?

How will increased coal related train traffic affect existing businesses near the railroad in towns and cities along the route?

I urge the Army Corps of Engineers to conduct an area-wide Environmental Impact Statement that includes Montana and Wyoming to assess the cumulative impact of coal export facility proposals.

[NOTE FROM PROJECT TEAM: INDIVIDUALS HAVE SUBMITTED COMMENTS THROUGH THE WESTERN ORGANIZATION OF RESOURCE COUNCILS WEBSITE. ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 131. PERSONALIZED COMMENTS SUBMITTED THROUGH THE COMMENT FORM WILL BE UPLOADED INDIVIDUALLY.]
Attached Files:

Various Various (#1088)

Date Submitted: 10/23/2012
Comment:
As a supporter of the proposed Gateway Pacific Terminal in Whatcom County, I encourage you to complete the environment impact statement process based on the same strict federal and state environmental regulations that have been protecting our region for years.

This proposed export terminal project present Whatcom County with an incredible opportunity to strengthen its economy and improve our area regions\' quality of life in an environmentally responsible way. We can - and must - grow the economy and protect the environment at the same time.

The critics make it sound like we have to choose between the economy and the environment. I believe that\'s a false choice. The Northwest has been a national leader in the trade industry for generations, and we can continue to lead the way in an environmentally conscious manner. The Cherry Point project will do just that.

As our region\'s economy continues to struggle, it is essential not to over-regulate or delay the approval process of this project.

I urge you to not stand in the way of creating new, much-needed Northwest jobs and strengthening our economy through increased exports by completing this environmental impact statement in a fair and expedient manner.

[NOTE FROM PROJECT TEAM: ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 170.]
Attached Image:

Attached Files:

Various Various (#1098)

Date Submitted: 10/23/2012
Comment:
See Attached

[NOTE FROM PROJECT TEAM: ATTACHED ARE MAILED FORMS THE TEAM RECEIVED AS OF 1/22/13. THE ATTACHED FORMS DO NOT HAVE ANY ADDITIONAL INFORMATION OTHER THAN THE STANDARD FORM AND THE SENDER'S INFORMATION. MAILED FORMS SENT IN WITH UNIQUE COMMENTS WILL BE UPLOADED INDIVIDUALLY.]
Attached Files:

Various Various (#12176)

Date Submitted: 01/22/13
Comment:
I support the Gateway Pacific Terminal and request a fair review of the proposal that will put thousands of local residents back to work and be designed in a way that will protect the environment. This project would positively affect my community by creating much needed family-wage jobs, increasing local tax revenue, and utilizing a site that has been zoned for heavy industry for decades. Please ensure compliance with Washington's high environmental standards, but avoid unnecessary delays.

[NOTE FROM PROJECT TEAM: Attached are comment forms that were collected by and mailed from an outside organization (unidentified) from 213 individuals by the end of the comment period, January 22, 2013. All individual comments have been reviewed by the project team and will be considered in the scoping report.]
Attached Files:

Various Various (#14181)

Date Submitted: 01/22/13
Comment:
I strongly oppose the construction of a coal export terminal at Cherry Point, Washington, the transport of strip-mined coal from Montana and Wyoming on trains throughout the Northwest and the export of coal by ship through the Salish Sea and the Pacific Ocean. The proposed Gateway Pacific Terminal would negatively affect communities in the Pacific Northwest by increasing congestion and noise with more coal train traffic, polluting the air and local waterways, harming existing businesses, delaying emergency responders, and damaging aquatic ecosystems and fishing grounds at the terminal site. In addition, the proposal would threaten endangered orcas, salmon and herring, increase high-risk freighter traffic in the Salish Sea and Pacific Ocean -- and thus the potential for serious shipping accidents and oil spills -- and escalate climate change. I urge you to consider these significant impacts in the scope of the Environmental Impact Statement.

There are currently five coal export proposals that would transport as much as 150 million tons of coal annually through the Northwest and the Salish Sea. All the ships from these proposed projects are bound for China, meaning their routes will impact the San Juan Islands, the Strait of Juan de Fuca or the Columbia River, and then Unimak Pass along Alaska’s Aleutian Peninsula. Therefore, I urge the Army Corps of Engineers to conduct an area-wide Environmental Impact Statement to assess the cumulative impact of these proposals.

[NOTE FROM PROJECT TEAM: ATTACHED IS A LIST OF THE NAMES OF PEOPLE WHO SUBMITTED THE ABOVE COMMENT AS OF 1/22/13. THE TOTAL NUMBER TO DATE IS 12,523.]
Attached Image:

Attached Files:

Walter Archer (Northern Plains Resource Council) (#12242)

Date Submitted: 01/22/13
Location: Billings, MT
Comment:
See Attached

[NOTE FROM PROJECT TEAM: Attached are comments that were mailed from Northern Plains Resource Council from 155 individuals by the end of the comment period, January 22, 2013. All comments are being reviewed by the project team and will be considered in the scoping report.]
Attached Files:

Wanda Cucinotta (#3463)

Date Submitted: 11/28/2012
Location: Lummi Island, WA
Comment:
November 28, 2012
Dear Mr. Schroeder, Mr. Perry, and Ms. Kelly,
Re: Gateway Pacific Terminal and BNSF Custer Spur Modifications Project
The Lummi Island Watershed Enhancement Committee is very concerned about the proposed Gateway Pacific Terminal project at Cherry Point that could significantly impact all marine life in the waters of Puget Sound and the viability of our marine natural resources. Our way of life, would be greatly jeopardized by this project and the significant risks it imposes to this region needs to be studied extensively including all cumulative effects. We request that the scope of the Environmental Impact Statement recognize the increased risk to the environment within the shipping lanes proposed to transport the coal from the port at Cherry Point, Washington
• This project poses risks to the recovery and protection of federally listed threatened Chinook salmon and the critical habitats they dependent on.
• An increase in larger ships and maritime traffic poses a significant increased risk of a major oil spill.
• This and the amplitude of engine sounds these ships create could possibly devastate the endangered Southern Resident Killer Whale populations.
• This project also increases risk to the highly valuable Cherry Point herring stock which serves as an important food source to many marine species, including salmon and in turn the killer whales.
• The air pollution from this coal will contribute to the growing global air pollution that contributes to climate change and its direct impacts to the marine environment including a rise in sea level due to thermal expansion, increases in water temperature, changes in water acidity and circulation patterns, and related consequences for marine food chains. All of which need extensive studies.
• Spraying down the coal with large quantities of water from the Nooksack River, a limited water resource, as well as polluted runoff from this use needs to be fully studied and analyzed.
• This project also directly conflicts with our local and regional management plans based on state and federal regulations.

The Lummi Island Watershed Enhancement Committee was formed to implement restoration projects, and to provide education and outreach to our community to protect our water resources. . We ask that the Environmental Impact Statement for the proposed Gateway Pacific Terminal project at Cherry Point fully and completely include the connected and cumulative actions, issues, and concerns of the citizens in this area.

Thank you for consideration.

Sincerely,
Wanda Cucinotta, Lummi Island Watershed Enhancement Committee Chair
2303 Tuttle Lane • Lummi Island, WA 98262 • 360-220-3077

Washington Conservation Voters, Whatcom County Chapter HARRIS (#11147)

Date Submitted: 01/22/2013
Location: Bellingham, WA
Comment:
Washington Conservation Voters, Whatcom County Chapter
Board of Directors:
Bob Aegerter, Wendy Harris, Kurt Waldenburg, Alex Ramel, Isabel VanDerslice
EIS Scoping Comment
Submitted 1-22-13

Whatcom Conservation Voters is a chapter of Washington Conservation Voters and works in Whatcom County on quality of life issues, such as responsible growth, clean water and sustainability. Our focus is on protecting Lake Whatcom, promoting sustainable policy on the Bellingham waterfront, preventing sprawl, promoting green jobs, preserving agricultural land, conserving habitat and doing our part to curb global climate change.

We are concerned that proposed mitigation for the Gateway Pacific Terminal (GPT) proposal is inadequate. We request that the EIS assess the direct, indirect and cumulative impacts of the proposed development on ecosystem functions and processes. This should be reviewed under a watershed/landscape based analysis to determine if, and how, ecological impacts can be mitigated. As a matter of local law, the proposal can not be permitted unless the ecological functions of critical areas and shorelines are protected against net loss. Where compensatory mitigation is proposed, ecological functions must be enhanced.

Based on our review of the application materials, it is clear that the proposal does not meet minimum statutory standards. We urge Whatcom County, the Department of Ecology and The Army Corp of Engineers to use the EIS process to explore these issues in depth.

More specifically, our comments are provided below.

PUBLIC PROCESS CONCERNS
The information reflected in the Master Development Permit application, including the wetland mitigation plan, is inaccurate. The application is based on a project area of 1200 acres. The applicant recently purchased lots 14 and 15 (the Cherry Point Industrial Project) and the project area now covers more than 1500 acres. This has not been reflected in an updated supplemental application, leaving the public uniformed that an additional 330 acres has been added to the project area for use in mitigation. It is unclear if or how this modifies the submitted mitigation plans. This impairs the public’s right to participate in the SEPA scoping process and reduces the likelihood that significant adverse environmental impacts from the development proposal will be recognized, and therefore addressed, in the EIS.

Based on undisclosed information, as well as large gaps in ecological function assessments, discussed below, we suggest that the EIS be drafted as a collaborative, open process where missing information can be fully developed with input from public agencies, tribes and stakeholders. This is permissible under NEPA and SEPA, and is further justified by the public interest and controversy that this proposal has generated. At a minimum, we suggest that this be done for development of preferred alternatives.

WETLAND CREDIT SHORTFALL
We think it is significant that the application fails to meet mitigation requirements. The wetland mitigation plan submitted by the applicant reflects a wetland mitigation shortfall of 30.1 credits. The applicant cites potential for additional wetland credits from a County In Lieu of Fee plan, mitigation bank credits and use of “out of kind resource trade-offs”. In the meanwhile, the applicant continues to search for “opportunities to mitigate impacts, including avoidance and minimization, through engineering and design features.” (Wetland mitigation plan, page 81).

Whatcom County does not currently have an In Lieu of Fee plan, nor is it “near implementation of the Birch Bay Habitat Mitigation Fund” as asserted on page 76 of the wetland mitigation plan. The Planning Department is still working on plan revisions. Moreover, as revised, the In Lieu of Fee program specifically excludes the Cherry Point Industrial District. This provision resulted from strong public opposition to the use of the In Lieu of Fee proposal by the applicant. And while the Lummi Nation received state approval to create a wetland mitigation bank, it is unlikely to sell mitigation credits to the applicant because of its strong opposition to the proposal. Moreover, the applicant expects to have its mitigation projects completed within 2 years, and the Lummi mitigation bank is at least several years away from being operational. Accordingly, neither of these alternatives is a viable source of mitigation credits.

The applicant also proposes meeting its mitigation short fall through the use of “out of kind resource trade-offs.” Out of kind resource trade-offs, which involve replacing wetlands with habitat or ecosystems other than wetlands, are approved by agencies infrequently, and in limited circumstances, because it is unlikely to replace the specific wetland functions that are lost or degraded. Moreover, even when approved, the applicant is still required to provide wetland mitigation on a 1:1 ratio, with non-wetland resources limited to the difference between mitigation ratios. State and federal approval of an “out of kind resource trade-off” plan is uncertain.

The applicant fails to address local standards, but the Whatcom County Code (WCC) appears to limit or preclude the use of “out of kind resources trade-offs”. It is not specifically authorized or discussed in the Critical Area Ordinance (CAO), but development proposals that do not maintain or replace critical areas functions and values will be denied. WCC 16.16.260. Compensatory mitigation (which is a primary component of the proposal) requires “replacing, enhancing, or providing similar substitute resources or environments.” WCC 16.16.260.A.1.e. For wetlands, “compensatory mitigation projects shall restore, create, rehabilitate, enhance, and/or preserve equivalent wetland functions and values.” WCC 16.16.680.B.1. For Conservation Habitat Areas, “mitigation must be a similar habitat type as the permitted alteration.” Under WCC 16.16.760.B.1, “compensatory mitigation for alterations to habitat areas…shall provide similar functions to those that are lost or altered.”

In sum, the ability to meet wetland mitigation credits has not been established at a federal, state or local level. The applicant, PIT, remains over 30 wetland mitigation credits short, without a dependable means to meet its mitigation obligations.

ECOLOGICAL ASSESSMENT
The proposal does not protect shoreline and critical areas from a net loss in ecological functions. This is a predicate requirement for County permit approval. The Whatcom County Shoreline Management Program (SMP) and Critical Area Ordinance (CAO) prohibit development of state shorelines, and critical areas within the Cherry Point Management Area, unless mitigation of direct, indirect and cumulative impacts achieves no net loss of ecological functions and processes. WCC 23.90.03.A; WCC 23.100.17.B.3; WCC 16.16.260. The EIS should identify all critical area and shoreline ecological functions and then determine if no net loss standards can be achieved.

The importance of protecting ecosystem functions and processes must be emphasized. In 2005, the Millennium Ecosystem Assessment, sponsored by the U.N, reflected consensus of 1360 international scientists, (supported by five technical volumes and six synthesis reports), that “human actions are depleting Earth’s natural capital, putting such strain on the environment that the ability of the planet’s ecosystems to sustain future generations can no longer be taken for granted.” The Millennium Ecosystem Assessment emphasized the importance of “ecological services”, or the human benefits of healthy ecosystem functions and processes, such as air and water filtration, decomposition of waste, increased carbon sequestration, temperature reduction, flood and erosion control, soil production, creation of food and pharmaceutical sources and control of infectious disease. Healthy ecosystems were referred to as “humanity’s life support system.”

Wetlands
Whatcom County protects wetland functions, which include but are not limited to providing food, breeding, nesting and/or rearing habitat for fish and wildlife; recharging and discharging ground water; contributing to stream flow during low flow periods; stabilizing stream banks and shorelines; storing storm and flood waters to reduce flooding and erosion; and improving water quality through biofiltration. WCC 16.16.600.A. Wetlands are also significant source of biodiversity and have the ability to sequester carbon, lower water temperature and moderate the rate of climate change. Wetlands support recreation, education, a healthy economy, scientific study, and aesthetic values, all of which needs to be protected.

The applicant asserts that its wetland Draft Conceptual Compensatory Mitigation Plan reflects an ecological assessment, but we disagree. The plan attempts to establish adequate mitigation through: 1) size replacement standards and 2) an ecological lift analysis (required for compensatory mitigation). However, it fails to meet even replacement standards, remaining 30 wetland mitigation credits short and arguing for approval of an out-of-kind resource tradeoff.

The ecological lift analysis provides a functional score (39) for existing wetlands based on the 2004 DOE Western Washington Wetland Rating System, which evaluates three basic wetland ecological functions; water quality, hydrologic and habitat. The functional score (56) for the compensatory wetlands is based on “anticipated site conditions 15 years post-construction.” (Wetland report, pages 82 and 83). If there is a scientifically based analysis that supports the anticipated future site conditions, it is not readily discernable. (But we suspect that the applicant is aware of the requirement that compensatory wetland scores exceed existing wetland scores by 1/3 to be considered equivalent, in this case a minimum of 52 points.)

It is problematic that the applicant used the Western Washington wetland rating system to evaluate proposed compensatory wetland mitigation. The wetland rating system was developed to provide a quick and inexpensive method of assessment, but it does not replace a full functional analysis. DOE acknowledges problems in relying upon the wetland rating system in the context of compensatory mitigation. The applicant is aware of these problems, but asserts that a site specific functional assessment would be too difficult and too expensive. (Wetland mitigation plan, page 40). The applicant states that a DOE debit/credit methodology for compensatory mitigation “is currently in development” as an excuse for taking no further action. In fact, guidance for adopting this approach, based on voluntary compliance, was first issued for Western Washington in 2010 and was updated in March, 2012.

The wetland rating system may be appropriate for small projects that do not involve compensatory mitigation, critical areas, shorelines and protected species. It is certainly not appropriate for a 1500 acre project site that impacts many natural resources, results in acres of compensatory mitigation, and requires a Major Development Permit, Zoning Variance Permit and a Shoreline Substantial Development Permit. The applicant’s desire to minimize the costs of mitigation should not outweigh its responsibility to comply with SMP and CAO assessment requirements.

One of the limitations of relying upon the wetland rating system for functional assessment is that it only addresses three wetland ecological functions. This leaves many functions and processes unevaluated, reducing the possibility of meeting no net loss standards. The role of wetlands and forested riparian buffers in sequestering carbon, generating oxygen and reducing the rate of climate change acceleration was not assessed and mitigated. Yet the loss of wetlands and forests is scientifically linked to increased air and water temperature and decreased air and water quality. At the same time that the proposal destroys/degrades wetlands and forest, it increases activities (mining, transporation, exportation and burning of coal) that exacerbate global warming. We also note that climate change is expected to make wetland mitigation more challenging.

Another constraint of the wetland rating system is that all wetlands with the same classification rating are treated as equivalent in value. This does not protect local species or habitat areas with the highest conservation value. DOE acknowledges the problem for threatened and endangered species, stating that “recommendations on buffers and mitigation ratios that result from this categorization are too generic to adequately protect a single species…..for example, a category II riverine wetland that provides overwintering habitat for endangered coho may need more than standard buffers recommended for a category II wetland to protect fish.” We believe this logic applies equally to all local species, whether or not protected under federal or state law.

The applicant attempts to mitigate habitat without consideration of species-specific use and needs. The only site-specific review of habitat conducted was for terrestrial bird species, but even then, failed to identify migration pathways or the specific location of bird sightings. (See the Avian Baseline Inventory Study). While standards for choosing an off-site mitigation area are discussed, in reality, the receiving site location was based on size and availability. Because the “Terminal design footprint was finalized” as a first action, the receiving site was limited to an area large enough to compensate for acres of destroyed wetlands. (Wetland mitigation plan, pages 64-66).

To achieve no net loss of habitat, mitigation must meet species-specific breeding, foraging and resting needs, maintain minimum habitat buffers and habitat patch sizes, and protect or restore habitat connectivity, wildlife corridors and bird migration pathways. This has not occurred. Making the mitigation numbers work on paper, based on wetland ratings, fails to protect highly rated habitat.

Another shortfall of the wetland rating system is that it does not reflect the synergistic impacts of a functioning ecosystem. WCC 16.680.A allows the technical administrator to consider “the ecological processes that affect and influence critical area structure and function within the watershed or sub-basin.” The 530 acres of wetland that exist on the proposal site function in relationship to each other, and form a larger landscape-scale ecosystem. Once all or parts of some wetlands are filled, the remaining wetlands are impaired. Where, as here, compensatory mitigation creates smaller, less connected wetlands, overall watershed ecosystem function suffers. And changes in freshwater ecological functions will have impacts on marine and shoreline ecological functions that need to be addressed. In this case, we note that two watersheds are affected and need to be considered.

Streams
Streams provide a variety of important functions including the movement of water and sediment, storage of flood waters, recharge of groundwater, treatment of pollutants, dynamic stability, and habitat diversity. For fish bearing streams, Whatcom County requires functional analysis of specific lifecycle requirements such as in stream flow requirement and water temperature, habitat suitability, channel gradient, presence or lack of barriers, and a reasoned evaluation of current, historic and potential fish use.

The applicant submitted a Freshwater Streams Baseline Inventory Report which focused heavily on habitat conditions. However, this report does not analyze all lifecycle requirements such as in stream flow requirements and water temperature. While the Baseline Inventory report may satisfy requirements under specific state or federal standards, but it does not appear to meet County CAO requirements.

Shorelines
Under the County SMP, protected shoreline ecological functions include fish and wildlife habitat, food chain support, and water temperature maintenance. Shoreline processes include water flow; littoral drift; erosion and accretion; infiltration; ground water recharge and discharge; sediment delivery, transport, and storage; large woody debris recruitment; organic matter input; nutrient and pathogen removal; and stream channel formation/maintenance. WCC 23.90.03.A. The applicant has not submitted a comprehensive marine mitigation plan. Because protecting shoreline ecological functions will be a particular challenge, the EIS should address ecological impacts and the feasibility and practicality of mitigation for shoreline functions.

Other Critical Areas and Shorelines
The ecological functions and processes for forested uplands, meadows, a coastal lagoon, estuarine areas, beaches and feeder bluffs, all present on the proposal site, should also be reviewed and mitigated. The potential for significant adverse environment impacts from development on or near geologically hazardous critical areas, such as landslide and erosion zones, should be included within the scope of the EIS.

ENVIRONMENTAL ENHANCEMENT
A significant portion of the proposed mitigation is actually subject to a higher standard than no net loss. Compensatory mitigation, which restores/recreates critical area and shoreline functions destroyed by development, is the least preferred form of mitigation because it is the least likely to fully and successfully replace lost ecological function. For this reason, the highest mitigation standard is imposed on compensatory mitigation.

To be permitted under the County SMP or CAO, compensatory mitigation must result in environmental enhancement (increased ecological function) and greater likelihood of mitigation project success. The standards for Habitat Conservation Areas (HCA) are even stricter. Under WCC 16.16.760.B.4, “compensatory mitigation shall be provided on-site or off-site in the location that will provide the greatest ecological benefit to the species and/or habitats affected and have the greatest likelihood of success. Mitigation shall occur as close to the impact site as possible, within the same sub-basin, and in a similar habitat type as the permitted alteration unless the applicant demonstrates to the satisfaction of the technical administrator through a watershed- or landscape-based analysis that mitigation within an alternative sub-basin of the same watershed would have greater ecological benefit.”

This mandates a species or habitat specific review for each impacted HCA, and requires compensatory mitigation where it will provide the greatest ecological lift, not where it is most convenient. Instead, the application materials suggest that terminal and plant facility designs, affecting 334 acres, were developed without consideration of important natural resource and ecosystem impacts.

The application reflects extensive detail about the proposal design and engineering while important ecosystem impacts remain unaddressed. The proposal requires compensatory mitigation for 154.8 acres of forested, shrub and emergent wetlands, enhancement of 145.7 acres of existing wetlands and 10.4 acres of riparian corridor enhancement. Yet the applicant states in the Revised Project Information Document, that “more studies are underway to better understand the upland vegetation, wildlife and habitats.” (pg. 5-14). The applicant failed to consider bird migration patterns, or the impacts of six 18 story silos, and overhead high voltage electrical cable as part of site design. 7 miles of road are proposed, without consideration of disturbance to wildlife corridors or habitat connectivity.

In particular, ecological impacts to marine species and habitat have not been addressed, or have been addressed in a cursory manner based on review of studies. The applicant states that a detailed review will be contained in a Preliminary Draft Biological Evaluation, although it appears that review will be limited to ESA and state priority species. This excludes review of some ecological functions. (The Biological Evaluation is incorrectly cited as an existing reference throughout the wetland mitigation plan and bibliography.)

We find this very concerning given the sensitivity and importance of marine and shoreline habitat and species, the difficulty in effectively mitigating impacts, and the failure to use avoidance as the preferred method of mitigation. For example, it is unclear to us how the development impacts to Cherry Point herring, an important component in the local food chain, and a genetically distinct species, can be mitigated to environmental enhancement standards.

In particular, we note that the applicant has failed to address impacts to seabirds, waterfowl and migrating shorebirds. This is inexcusable for a project area located within the Cherry Point Aquatic Reserve, one of 18 significant bird habitats in the Strait of Juan de Fuca and the Georgia Straight. This is important habitat for high numbers of fish-eating birds and important wintering grounds for migratory birds. According to the Cherry Point Environmental Aquatic Reserve Management Plan (November, 2010), studies reflect a 79% decline in over-wintering species, suggesting heightened sensitivity to additional development and difficulty in mitigating proposal impacts to an environmental enhancement standard.

The applicant fails to note that ospreys, sighted at Cherry Point, are a designated locally important species protected under the County’s Habitat Conservation Area provisions. WCC 16.16.710.C.10. The applicant notes that marbled murrelets, an ESA species, are possible, ignoring documented sightings at Cherry Point.

As noted in the Cherry Point Management Plan, “airborne pollution at Cherry Point is considerable, but the potential effect of atmospheric deposition on aquatic environments is unknown.” The existing facilities at Cherry Point accounted for 92% of all monitored industrial air pollutants from stationary sources in Whatcom County in 2005 and 2006. The Revised Project Information Document failed to address air quality impacts, although it lists as a goal, “implement measures from the Northwest Ports Clean Air Strategy.” (Pages 95-96).

The proposal will increase vessel traffic from Asian ports, which are the source of many aquatic invasive species. The EPA has identified ballast water as one the most universal and ubiquitous vectors for transport and discharge of non-native species in marine and coastal areas. The risk of aquatic infestation will increase as a result of global warming. The Washington Department of Ecology tracks oil spills over 150 gallons and reflects seven spills at Cherry Point between 1998 and 2008. The Cherry Point Management Plan identified additional potential threats to Cherry Point natural resources, (pages 27-30), such as shoreline modifications, overwater structures, artificial light, noise, and vessel traffic. It is not clear to us how environmental enhancement from compensatory mitigation can be achieved in the face of these risks.

LANDSCAPE ANALYSIS
Ecosystems function synergistically, reflecting the truism that the whole is greater than the sum of individual parts. A landscape-based assessment is the most scientifically sound way to mitigate development impacts, particularly where compensatory mitigation is involved. The EIS should assess proposal impacts and determine adequate mitigation based on a site-specific functional analysis of the project site, including the two watersheds that are impacted, the GPT watershed and the Birch Bay watershed. (At a minimum, this should be reflected in the EIS as a requirement for the applicant before approval of a mitigation plan.)

Whatcom County’s Critical Area Ordinance (CAO) specifically provides the technical administrator with authority to require a landscape based functional analysis. WCC 16.16.680.A and 16.16.760.A. (“The ecological processes that affect and influence critical area structure and function within the watershed or sub-basin, and the individual and cumulative effects of the action upon the functions of the critical area and associated watershed”).

The CAO also requires a critical area analysis that is “commensurate with the value or sensitivity of a particular critical area and relative to the scale and potential impacts of the proposed activity.” WCC 16.16.260.B.1. The project site is 1500 acres of largely undeveloped land that contains extensive critical areas and sensitive marine shorelines. The proposal site spans two watersheds (GPT and Birch Bay), including almost the entirety of one (GPT), and the Custer Spur will directly impact Terrell Creek and California Creek in the Birch Bay and Drayton Harbor watersheds, respectively. There is high biodiversity of species, including several genetically distinct fish species, and rare habitat, including a coastal lagoon. It is located within the DNR Cherry Point Aquatic Reserve and .25 miles from the WDFW Lake Terrell Wildlife Area. This proposal has generated elevated local, national, and international scrutiny regarding the cumulative impacts of mining, transporting, exporting and burning coal on human health, local economies, public safety, and global warming. Development directly impacts tribal treaty rights and ceremonial/cultural practices. The totality of impacts indicates the need for an EIS with scientific accuracy and detail.

The applicant incorrectly asserts that a watershed/landscape based analysis was used. The applicant failed to assess important ecological functions, as documented above, or consider how changes to these functions change larger process at the landscape scale. The ecological functions it did assess were reviewed independent of each other, without consideration of larger landscape issues, location of sensitive or rare species and habitat, or determination of watershed sub-basins most appropriate for development, restoration or protection.

The Revised Project Information Document relies heavily on general studies and cursory site review. For example, “an extensive literature search was conducted to identify the presence and abundance of terrestrial mammals, amphibians and reptiles in the project. “ (Page 5-18.) The only field investigation involved birds in 2008 and 2009. Given the loss in bird populations, particularly seabirds, this information is outdated. In short, the application fails to reflect how ecosystems function on the site, and minimizes the totality and complexity of development impacts. A detailed, well-developed watershed/landscape assessment is necessary to meet “no net loss” requirements and environmental enhancement standards.

We note that with regard to the Birch Bay watershed, some of the necessary analysis has been completed as part of the Birch Bay Watershed Characterization and Pilot Study. at. This watershed study, which is referenced in application material, lies within the “Terrell Creek Watershed Assessment Area” and the “Industrial Tributary” sub-basin. With purchase of the Cherry Point Industrial Project, it is possible that the project site also includes “Lake Terrell Tributary 2” sub-basin.

TEMPORAL GAP
The proposed compensatory mitigation fails to mitigate for temporal gap, measured as the period between development and the successful replacement of lost ecological functions through mitigation projects. Important ecological functions are lost, sometimes permanently, during this temporal gap. When habitat is lost for a period of time, fish and wildlife perish. When forested buffers are replanted, it takes many years to mature and achieve equivalent ecological function.

The WDFW requires temporal gaps to be mitigated. Whatcom County Code states that “where feasible, mitigation projects shall be completed prior to activities that will disturb habitat conservation areas. In all other cases, mitigation shall be completed as quickly as possible following disturbance and prior to use or occupancy of the activity or development.” WCC 16.16.760.B.3. We are skeptical of the applicant’s claim that all mitigation projects, for phases 1 and 2, will be completed within a 2 year period. Given the magnitude of compensatory mitigation required, the difficulty in replacing rare habitat, such as the proposed coastal lagoon, and the time required for forested buffers and uplands to reach maturity, equivalent functional value takes many years to achieve. Nor does the applicant factor in a failure rate, although compensatory mitigation failure rates are quite high.

This proposal will destroy 72 acres of deciduous forested wetlands of high habitat value. The applicant notes that “loss of wetland forest habitat would be partially offset by the enhancement of emergent wetlands in pastures or hayfields to forested wetlands 2 years in advance of some of the impacts. During the time that it takes for the establishment of these forested habitats, those species dependent on mature forest could use mature forested areas on-site and off-site.” (Wetland mitigation plan, page 50).

The applicant is clearly aware of the time requirements for growth of mature forest, and the connection between habitat loss and species loss. It should be clear, therefore, that species are generally unable to relocate to habitat in other locations, particularly when habitat corridors have been destroyed. The applicant notes that “adjacent roads and land use inhibit undisturbed corridors and connections to other habitats.” (Wetland mitigation plan, page 53). Development of electrical lines and six silos 18 stories high should also be expected to impact migration patterns and bird habitat

INTENSITY OF USE
GPT will operate 24 hours a day for 365 days of the year, increasing use of land and water, generating noise, lights, vibrations, odors, etc. It will increase human presence by at least an estimated 173 new employees.

Scientific studies have connected the intensity of human activity and human presence to loss of species survival. It is among the most difficult impacts to mitigate. Under Whatcom County regulations for Habitat Conservation Areas, “buffers shall be established for activities adjacent to habitat conservation areas as necessary to protect the integrity, functions and values of the resource. Buffer widths shall reflect the sensitivity of the species or habitat present and the type and intensity of the proposed adjacent human use or activity.” WCC 16.16

Nonstop industrial activity on land and water is a high intensity use requiring larger habitat buffers, but this has not been addressed within the proposal. It should be addressed within the EIS. Mitigation of impacts requires identification of all wildlife species protected under the CAO, and assessment of minimum habitat patch sizes, connectivity, and buffers necessary to protect a species throughout its lifecycle, with consideration of existing and future growth patterns. Particular attention should be paid to roads, power lines and other barriers to species movement and habitat connectivity. Mitigation should be based on quantifiable species-specific information. The draft habitat assessment for the Birch Bay Watershed Characterization and Pilot Study (Appendix E) provides a good example of how this could be done.

Intensity of use and development is also a risk factor for bluff erosion and slides. Activities that can have potential impacts include increased impervious surfaces, increased drainage concentrations such as stormwater runoff or septic drain fields, removal of trees and vegetation, new roads, excavation and fill. These are all significant components of the proposal. Engineered attempts to control the erosion can often make the impacts worse, as reflected on the Whatcom County Planning Department website. “Prevention of erosion and landsliding in some areas may actually result in considerable declines in sediment supplies that continually replenish our beaches. A reduction in materials can essentially starve beaches and downshore areas, leading to the loss of beaches, fish and wildlife habitat, and accelerate erosion of previously stable areas. The Cherry Point Aquatic Reserve Management Plan indicates that Cherry Point has exceptional feeder bluffs, indicating that development might increase erosion and landslides, but engineered solutions might interfere with natural ecological functions.

ELECTRIC POWER LINES
The development proposal requires new dedicated overhead 115 kilowat electric power lines, but the application states that “no design features to reduce impacts are proposed for the use of utilities by the Gateway Pacific Terminal project.” (Revised Project Information Document Page 5-93). Millions of birds are killed each year by power line interactions. The Migratory Bird Treaty Act makes it illegal for anyone to kill a protected bird (including eagles and other raptors) by any means without first obtaining a permit. The placement and amount of new overhead lines should be assessed and mitigated. We note that many forms of effective mitigation are inexpensive and could be easily implemented.

Raptors, such as eagles, hawks and owls, are most often killed by power lines. This occurs through electrocution, collision and habitat degradation. Large birds can easily contact two wires or a wire and a transformer, or brush against a live wire. The problem of bird electrocution has increased as a result of rising energy demands, raising global biodiversity concerns. Electrocution is particularly prevalent in natural areas, such as the 1500 acre proposal site, where the introduction of power lines causes significant disruption to local species.

Collision with power lines is also a common source of bird mortality. In flight, power lines are difficult to see, particularly neutral cables. Migrating birds flying at heights between 65 and 165 feet are at considerable risk. High collusion rates are reported where power lines cut across flyways and migration corridors, such as riparian valleys. Finally, utility lines remove and degrade habitat, reducing prey food sources. This may be a particular problem at the proposal site as Bonneville Power has instituted a new and aggressive plant control plan that removes trees and vegetation and relies upon increased amounts of herbicide.

Power lines and poles should be sited away from sensitive and protected bird habitat areas such as the Cherry Point Aquatic Reserve and the Lake Terrell Wildlife Management Area; migration paths, including the Pacific flyway and shoreline areas used by migrating shorebirds; or areas of high raptor concentration, such as wetlands, watercourses and shorelines. Power lines should be installed in conjunction with a bird protection plan. Guidelines for one such plan were developed by FWS.

Power line design can also reduce bird mortality. Multi-level power line arrangements create the highest risk, while single level arrangements create the lowest risk. Power lines can be made less dangerous by widening the gap between conducting and ground wires, insulating wires and metal parts, and moving wires farther away from pole tops. Guards should be built around favorite raptor perches. Voltage powers lines up to 110 volts should be constructed underground. Neutral cable should be marked for visibility. Colored hanging tags placed on power wires reduce bird collisions.

VEGETATION CONTROL PROGRAM
The application materials include a letter dated October 26, 2012 from the Bonneville Power Company regarding an aggressive vegetation control project within its easement on the project site. All potentially tall growing trees or brush species that could threaten power lines will be removed. Herbicide treatment may be used to prevent re-vegetation, although not within waterways or wetlands.

The impacts from the vegetation control program need to be included in the EIS review. When trees and shrubs are removed and land within a utility easement is treated with herbicides, the environment is less intact and less functional. Herbicides are known to contaminate and degrade water and soil, even when not sprayed directly into a wetland or waterway. Fish and wildlife are harmed. Habitat is removed, food sources are lost, and habitat connectivity and species mobility is impaired.

Because the development site will be impaired from the vegetation control program, the environment will be less resilient and impacts from the GPT proposal are more likely to harm ecological functions and values. This increases the potential for significant adverse environment impacts from the development proposal.

BIODIVERSITY
Biodiversity, in its simplest form, refers to the variety of life on earth. Biodiversity includes genetic diversity within a species, species and habitat diversity within an ecosystem and ecosystem diversity within a region. Biodiversity boosts ecosystem productivity and resiliency and protects human health. Biodiversity is maintained through preservation of large and diverse habitat areas, wildlife corridors and species mobility. Development destroys biodiversity by degrading and fragmenting habitat.

While the word “biodiversity” is not used in the CAO, the concept is. The purpose of Habitat Conservation Areas is to “regulate development so that isolated populations of species are not created and habitat degradation and fragmentation are avoided, especially along riparian corridors; and to maintain the natural geographic distribution, connectivity, and quality of fish and wildlife habitat.” WCC 16.16.700. In addition, the HCA provisions apply to wide variety of habitats and species, not all of whom are protected under state and federal laws. This includes: areas with which federally and/or state-listed species have a primary association; fish-bearing streams, kelp and eelgrass beds; Surf smelt, Pacific herring, and Pacific sand lance spawning areas; the marine nearshore habitat and the associated vegetated marine riparian zone, (which protects eelgrass beds, marine algal turf, and kelp beds used for forage fish, seabird and shorebird foraging and nesting sites, and harbor seal pupping and haulout sites), and commercial and recreational shellfish areas. WCC 16.16.710.C.10.

Biodiversity is not addressed in the proposal and should be a prominent consideration in the EIS. It plays a vital role in protecting ecological functions. Unlike federal and state laws, biodiversity protects the abundance of all species, even the most common ones. It also requires protection of rare habitat, such as coastal lagoons and feeder bluffs, as well as high conservation habitat, such as shorelines, forested riparian buffers and forested uplands.

Cherry Point has a unique marine and fresh water ecosystem with high aquatic biodiversity. In particular, the nearshore is identified as highly diverse and productive. A high diversity of algal species is noted. Nooksack River Chinook salmon are genetically distinct and are considered essential to recovery of Puget Sound Chinook, a federally threatened species. Other species protected under the ESA include Bull trout, Coho salmon, Puget Sound Steelhead Trout, Humpback Whale, Leatherback Sea Turtle, Stellar Sea Lion, Southern Resident Killer Whale, Bald Eagle and Marbled Murrelet.

3 species of forage fish can be found in the project site shoreline and nearshore, including spawning Pacific herring, which is a keystone species in the Pacific Northwest ecosystem and an important food source for other species in the area. Surf Smelt, who spawn along the shorelines, and Pacific sand lances are also present. All five species of native salmon can be found here. Adult Chinook, pink, coho and chum salmon migrating to the Fraser and Nooksack rivers travel along the Cherry Point shoreline. Sea-run cutthroat trout are present all year. Eelgrass, macroalgea beds and submerged aquatic vegetation provide critical habitat for salmonids species.

Commercially important Dungeness crab are common along the Cherry Point shoreline and support recreational and local commercial fisheries. Flatfish species are also commercially important, particularly English sole and Pacific Sanddabs. Other flatfish species found within the Aquatic Reserve are Dover sole, Rock sole, Sand sole, Flathead sole, Rex sole, Slender sole and Starry Flounder.

Marine birds are particularly numerous. Bird species include Bald eagle, Red-throated loon, Pacific loon, Yellow-billed loon, Harlequin duck, Bufflehead duck, Long tailed duck, Black scoter, Surf scoter, White winged scoter, 5 species of gull, Marbled murrelet, Pigeon guillemot, Common mure, Brandt’s cormorant, Double-crested cormorant, Horned grebe, Western grebe, Pied-billed grebe, Killdeer, Belted kingfisher and Peregrine Falcon. Migrating shorebirds, such as Dunlin, Sanderlings, Western Sandpipers, Black-bellied plover and Semipalmated plover use the Cherry Point Reach Aquatic Reserve, which is along the Pacific Flyway.

Marine mammals have been seen at Cherry Point, including Pacific harbor porpoise, California sea lion, Grey whale and Killer whales. Habor seals are found in the Aquatic Reserve and use nearby beaches to haul-out and to pup.

AVOIDANCE REQUIREMENTS
Terminal development, including roadways, rail loops and other infrastructure would affect almost 335 acres of the project site, almost half of which are wetlands. The majority of the project area is undeveloped with many forested areas. The site contains rare habitat for the Straight of Georgia, adding to regional biodiversity and many federal and state protected species are found on the site.

It is difficult to believe that the avoidance requirements of mitigation sequencing were followed. The applicant is only entitled to reasonable use of its property, not to the highest and best use. Despite the size of the development and the size of the project site, the applicant is still requesting a zoning set-back variance. Variances are intended to be granted only in rare instances where reasonable use would otherwise be denied and the public’s interest is not harmed.

It is clear that the applicant can obtain reasonable use of its property from a smaller design proposal. The prior application involved a much smaller terminal, while still providing for reasonable use of property. In light of the significant adverse environmental impacts associated with this proposal, we request that the EIS evaluate an alternative that involves a smaller design with fewer impacts on ecological functions.


Thank you for allowing us to participate in the EIS scoping process.



Sincerely,


Isabel VanDerslice
Board Chair, Whatcom County Chapter
Washington Conservation Voters


________________________________________________________________
EXHIBIT A


----- Original Message -----
From: Hruby, Tom (ECY)
To: Wendy Harris
Sent: Tuesday, June 26, 2012 5:57 AM
Subject: RE: Credit Debit Method

Wendy,
I agree that it is much better if we integrate our mitigation projects with broader planning needs. However, many local jurisdictions have not yet been able to move in that direction and we at the state level do not have the authority to impose such planning. I have tried to facilitate the integration of mitigation projects with broader landscape planning by giving more credit to mitigation that meets the criteria we established in our guide “Selecting Wetland Mitigation Sites Using a Watershed Approach” (Ecology publication #09-06-032 https://fortress.wa.gov/ecy/publications/SummaryPages/0906032.html ). In this document we highlight the need to choose mitigation sites that meet local planning needs as well as ones that are sustainable in the long run. If a mitigation site meets the criteria in the guide then the risk factor is lowered in the calculation of the credits (see the table for risk factors on page 6 of the worksheet in Appendix E).

Also, one of my co-workers, Stephen Stanley, is leading an effort to develop a landscape-scale method for characterizing the environmental and habitat processes in watersheds, and I am working with him on integrating the landscape-scale information with the site-scale information we get from the credit debit method. One of our first pilot projects in the Birch Bay area in your neighborhood.

Sincerely,

Tom Hruby, PhD, PWS
Senior Ecologist
Washington State Department of Ecology
PO Box 47600
Olympia WA 98504
(360) 407-7274
tom.hruby@ecy.wa.gov


From: Wendy Harris [
Sent: Monday, June 25, 2012 2:56 PM
To: Hruby, Tom (ECY)
Subject: Credit Debit Method

Hi Tom. I have been looking over the new credit/debit system for wetland mitigation and do not see how this includes consideration of specific needs of local species, or issues of connectivity and biodiversity. My concern is that without a local comprehensive wildlife conservation plan, the use of the credit/debit system will create successful wetlands that end up as little more than habitat islands. There seems to be widely high belief that wetland mitigation, by itself, protects wildlife without having to address these types of conservation issues.

Will any efforts be made to coordinate the credit/debit system for wetlands with the need for comprehensive conservation planning?

Thank you
Wendy Harris
Bellingham resident

Wendy Steffensen (#11867)

Date Submitted: 01/22/2013
Location: Bellingham, Wa
Comment:
Please see the attached comment.
Attached Files:

Wendy Steffensen (RE Sources for Sustainable Communities) (#12223)

Date Submitted: 01/22/13
Location: Bellingham, WA
Comment:
Dear Ms. Kelly, Mr. Perry, and Mr. Schroeder:

Please find attached RE Sources for Sustainable Communities' scoping letter addendum. Thank you for this opportunity to comment on the proposed Gateway Pacific Terminal.

Thank You,
Wendy Steffensen

--
Wendy Steffensen, Lead Scientist
North Sound Baykeeper Team
RE Sources for Sustainable Communities
2309 Meridian St.
Bellingham, WA 98225

360 733-8307 (office)
360 739-5518 (cell)
Attached Files:

Wendy Steffensen (Whatcom County Marine Resources Committee) (#11938)

Date Submitted: 01/21/13
Location: Bellingham, WA
Comment:
see attached
Attached Files:

Whatcom Land Trust (#12075)

Date Submitted: 01/22/2013
Location: Bellingham, WA
Comment:
Whatcom Land Trust (WLT) owns property and holds conservation easements on lands that are within the proposed Custer Spur Railroad Right of Way. Below, WLT has identified a few areas where the proposed project could significantly affect conservation and habitat values of the land.

1) (California Creek Timberline Preserve)
Please study the necessity of protecting wetland environments and creeks along the Custer Spur Railroad right-of-way. California Creek and its tributaries and Terrell Creek will be crossed by this rail line and will be impacted by construction of right-of-way upgrades. The proposed expansion of the rail line right-of-way will share a boundary with the Whatcom Land Trust California Creek Timberline Preserve and WSDOT mitigation site that will impact the habitat and wildlife that utilize the wetland preserve. Noise, coal dust, and continual traffic will degrade the conservation value of these parcels and could adversely impact the water quality of these sensitive lands.

Railroad right-of-ways should not impinge on sensitive conservation lands, buffer zones should be established around these conservation lands. Covered coal cars should be used to transport coal to contain any dust that would escape and contaminate conservation lands or stream resources.

2) (Madrona Point Estuary Preserve)
Please study the necessity of protecting estuary habitat along the proposed Mainline Railroad of the Gateway Pacific Terminal (GPT). Whatcom Land Trust and the City of Bellingham have conserved pocket estuaries along the mainline that will be impacted by coal dust and/or spilled coal into these environments. These estuaries have limited tidal exchange. Coal dust accumulations in these environments have the potential to accumulate in the shellfish living in sediments in these areas. Species eating these shellfish that have bio-accumulated the toxins from the coal will pass toxins further on in these fragile food webs. Pelagic and benthic fish species, marine birds and marine vertebrate and invertebrate animals will in turn be impacted by the loss of rearing and refuge capacity if estuary function is degraded.
Covered coal cars will help mitigate the cumulative impacts from dust in these constrained environments. Coal spill impacts to these areas would destroy the habitats that they contain because cleanup of sediments would alter their composition and productive quality while re-suspending legacy contaminants. The safest course of action is to not ship coal through this marine environment.

3) (Pigeon Point Tideland and Upland Preserve) (Facility Wharf)
Please study the necessity of protecting tideland dependent organisms at the Wharf and Access Trestle area and along the proposed Mainline Railroad serving GPT. Whatcom Land Trust has conserved areas along marine portions of the Mainline Railroad line that include tidelands and near shore habitats that will be impacted by coal dust, spilled coal and noise. Shellfish beds, spawning habitats and eelgrass beds on these conserved lands will be impacted by coal dust which will introduce toxins into the food webs. This coal dust will also smother or bio- accumulate in organisms that occupy these habitats. These effects will be felt all by all marine organisms along the Mainline Railroad wherever the tracks are bound by tidelands. Numerous marine animal and plant species that depend on this specialized habitat will be impacted by uncontained coal dust and coal loading procedures that release coal into this ecosystem.

Study the direct impacts of coal dust and spilled coal on the near-shore dependent organisms (sand lance, crab, herring, eelgrass beds,) from transport (along marine portions of the mainline railroad) and loading of coal (at the wharf and aboard ship) to establish a baseline of how much escaped coal is acceptable and would not harm the near-shore environment.

4) (South Fork Nooksack, alternate route)

In the event that an alternate route is proposed through the South Fork Nooksack River valley, WLT would have similar concerns about the impact (noise, traffic, toxins) on sensitive ecosystems conserved in that region and ask that thorough impact assessments be conducted.