Submission Number: MBTL-EIS-0002793 

Received: 11/16/2013 12:47:00 AM
Commenter: Nicholas Lacey

Agency: Cowlitz County, the Washington Department of Ecology, and the U.S. Army Corps of Engineers
Initiative: Millennium Bulk-Terminals Longview EIS
Attachments: No Attachments
Submission Text
From:Lacey, Nicholas <> Sent:Saturday, November 16, 2013 12:48 AM Subject:EIS comment

November 12, 2013

U.S. Army Corps of Engineers, Seattle District Care of: GPT/BNSF Custer Spur EIS Co-Lead Agencies 1100 112th Avenue NE Suite 400 Bellevue, WA 98004

RE: Scoping Gateway Pacific Terminal Environmental Impact Study

Dear Gateway Pacific Terminal Co-Lead Agencies,

As citizens of the inland Northwest and students of Gonzaga University, we thank you for the opportunity to provide public comment concerning the proposed Gateway Pacific Terminal at Cherry Point. We urge careful consideration to be taken concerning all aspects of environmental preservation, particularly the future stake of all marine life dependent on the Salish Sea ecosystem.

If approved, the Cherry Point Terminal would transport an estimated 48 million metric tons of coal per year. This translates to an additional 450 Panamax and Capesize class vessels passing through the Strait of Georgia each year. This increase in traffic could negatively affect Puget Sound's ecosystem in a number of ways. This geographic region is prone to exceptionally heavy rainfall and yearlong winds further accelerating the escape and contamination of coal dust into seawater. This inevitable accumulation of particulate coal matter in the marine environment surrounding coal terminals, pose a significant threat to the sustainability of aquatic life and biodiversity. Coal suspended in the water column presents a high risk to organisms by abrasion, smothering, reduction of spectral quality, and clogging of respiratory and feeding organs. Unburnt coal contains potential toxicants such as polycyclic aromatic hydrocarbons and trace metals. Exposure to high concentrations of these compounds suspended in water and settled on the ocean floor has been proven to result in crippling neurogenic and developmental defects. Of primary concern is coals potential damage to the benthos surrounding coal loading and unloading facilities. The ecological significance of benthic microinvertebrates is of utmost importance to the continued function and support of the Salish Sea ecosystem. Essential organisms such as, clams, mussels, barnacles, and crabs would experience significant population declines. These key species comprise a substantial percentage of seasonal food for juvenile salmonids and herring thereby causing damage to a greater number of animals higher up on the food chain. Furthermore, suspended coal particulate coal in marine water would lead to the inhibition of larval settlement and recruitment.

In the shipping process, tankers transport up to 10 million gallons of ballast water between ports. The ballast water from Asian ports could introduce hundreds of invasive aquatic species. Once established, these invasive species prove detrimental to local wildlife and are very difficult to remove. The reality of this risk has been branded as one of the four biggest threats to the world's oceans by the UN. Although the International Maritime Organization has recommended mid- ocean ballast exchange as a method to mitigate this risk, the US has yet to enforce it.

A 2008 Vessel Traffic Risk Assessment conducted by BP projects an increased risk of vessel collisions and groundings, should traffic levels increase by as little as 17%. The rocky conditions of the Cherry Point area could puncture even a double-hull ship in the event of grounding. These coal ships carry over a million gallons of heavy bunker oil, which in the event of a spill can sink below the surface making traditional oil cleanup much more difficult. The response agency responsible for cleaning up spills in this region faces budget cuts every biennium, and with a workforce of only 70, their capacity for response is questionable.

When carrying out the EIS, please keep these issues in mind. If the Cherry Point terminals are approved consider these solutions to the above issues. Consider the benefits of listing the Cherry Point Herring as an endangered species. This would allow the species to receive the protection they need to survive for the benefit of the greater ecosystem. To mitigate the effects of an oil spill, a quick and effective response is vital and would be possible through an increase in the Washington Oil Spill Team's budget. To reduce the risks involved with ballast water, consider mandating procedures such as mid-ocean ballast transfer. We appreciate your consideration in this EIS process and trust you will make an educated decision.


Nick Lacey, Bella Colpo, Amberlyn Olsen, Alex McKelvey