I have a great deal of respect for the port's mission and feel that it has, at times, strayed into territory best left to other agencies, so if the letter isn't quite what some folks would desire please note that the port's mission, though seemingly broad, is actually narrowly defined by state law and the letter below attempts to stay within the bounds of what ports do.
Thanks for reading and feel free to comment!
21 January 2013
From: Port of Bellingham
1801 Roeder Ave.
Bellingham, WA 98225
To: GPT/Custer Spur EIS
c/o CH2MHill and Co-lead Agencies
1100 112th Ave. NE, Suite 400
1100 112th Ave. NE, Suite 400
Bellevue, WA 98004
Re: Gateway Pacific Terminal Scoping Comments
Dear Sir or Madam,
As the only government body with elected representation tasked by the people of Whatcom County to focus strictly on the fulfillment of certain, “essential transportation and economic development needs of this region while providing leadership in maintaining greater Whatcom County’s overall economic vitality” and, given that the Gateway Pacific Terminal project meets county and state thresholds of significant impact, it is, therefore, incumbent upon the Port of Bellingham, on behalf of the citizens of Whatcom County whose interests the port serves, to request that the Environmental Impact Statement (EIS) for the Gateway Pacific Terminal (GPT) project, as proposed, include a robust assessment of transportation and economic impacts, both positive and negative, created by the project.
It should be noted that in 2010 the Port of Bellingham submitted a letter to the Washington State Department of Natural Resources in support of a potential terminal at Cherry Point. While not specific in drawing distinctions regarding the commodities supported by a terminal, the Port of Bellingham has a long standing position generally in favor of a deep-water terminal at that location.
Because an EIS is designed less as a tool to find what is ‘right’ about a project and more intent on finding those actions that will create significant environmental burdens or consequences, it is important for the port to be interested in issues pertaining to the purview of the port and within the bounds of law; specifically, the economic and transportation impacts of the project.
Per Washington Administrative Code (WAC) 197-11-444, the EIS is required to consider the following:
(i) Transportation systems
(ii) Vehicular traffic
(iii) Waterborne, rail, and air traffic
(v) Movement/circulation of people or goods
(vi) Traffic hazards
The Washington State Department of Ecology and Whatcom County have determined GPT to be a project of significant impact, it is, therefore, wise to consider not only the immediate environmental impacts at the site but also the wider impacts upon the infrastructure required to support the terminal. Most notably, that infrastructure will be a private rail line operated by Burlington Northern Santa Fe Railroad (BNSF) and the many public roadways the rail line intersects.
While the burden and risk associated with the commodities carried on the rail are to be borne by private entities, the rail line itself does cross a significant number of public roadways and will create impacts at or near those crossings. An example of an analogous situation is the addition of a multi-acre shopping center at a busy intersection; there is a local standard for Level of Service (LoS) that is acceptable at that intersection, with the addition of the shopping center that LoS will be reduced if not mitigated by improvements. In regards to the GPT project there will be additional and easily measurable traffic at the intersections of public roadways with the BNSF line.
On behalf of the citizens of Whatcom County, the Port of Bellingham has a direct interest in understanding and mitigating transportation impacts to public properties owned by the port, notably in the City of Bellingham’s Fairhaven and Waterfront Districts but also, in general, impacts that may accrue at various crossings throughout the county causing notable delays to commerce on county roadways.
There are quantifiable costs for traffic delays that prevent business, commercial or commuter activities from ready access to truck routes, state highways and major county roadways historically utilized by Whatcom County businesses and residents. As such, please include in the EIS a complete analysis and possible mitigations for traffic impacts that consider both the additional burdens from auto traffic and the effects of increased rail traffic throughout the county.
Furthermore, per WAC 197-11-448 the EIS may consider “the general welfare, social, economic, and other requirements…in making final decisions.”
Private enterprise should not unduly burden the public by shifting responsibilities and costs onto that public when that enterprise has no broad public purpose. This statement is reinforced by Whatcom County Code, Section 20.88.130(6): the proposed major development “Will not impose uncompensated requirements for public expenditures for additional utilities, facilities and services, and will not impose uncompensated costs on other property owned.”
Whereas the Port of Bellingham is chartered to directly serve the public within the bounds of Whatcom County and indirectly the public in our region, it is inherent in that charter that the port has “pledge[d]…to be a responsible trustee of our publicly owned assets”, in part, by appraising projects of significance, such as GPT, where the project has wide ranging economic impacts.
To that end, it is in the best interest of the people of Whatcom County that the Port of Bellingham request that the EIS thoroughly consider the economic impacts, both positive and negative, of the GPT proposal on Whatcom County’s various cities, the county itself and the region serving or being served by Whatcom County.
The Port of Bellingham was chartered by a vote of the people 92 years ago to serve public interests throughout Whatcom County and, by extension of those interests, the northwestern region of Washington State. The port owns, on behalf of the people of Whatcom County, substantial real estate holdings directly affected by the proposed project. Furthermore, as a key economic development agency for Whatcom County, the port has an interest in efforts that impact the county and regional economy. It is in the spirit of fully understanding the effects of the project on this county that the Port of Bellingham requests the NEPA and SEPA processes engage a robust analysis of the transportation and economic impacts in developing the Gateway Pacific Terminal EIS.
With most sincere regards,
____________________________________________Jim Jorgenson, Commission President
Mike McAuley, Commission Vice-President
Scott Walker, Commission Secretary