Sharply increased marine traffic, physical disruption of ecologically sensitive areas, and open coal storage in proximity to the Cherry Point Aquatic Reserve give rise to concerns about the proposed coal export facility. The risk of collisions and oil spills rises as coal ships are added to waters already crowded with oil tankers. 80-100 acres of open coal heaps will be in proximity to the aquatic reserve, in an area sometimes subjected to high winds; it is unknown to what extent coal dust in the water might affect the marine plants and animals. The construction of the facility and rail loops on wetlands and uplands, and of the wharf and trestle area over the water, have the potential to disrupt fragile ecosystems. Cherry Point herring are a keystone species, providing food for a number of other species; their status is currently fragile, and would likely be further stressed by activities associated with the coal port. Increased noise pollution, increased risk of collision with marine vessels, threatened food sources (i.e. herring), and a degraded marine environment would pose challenges to killer whales, salmon and a myriad of shore and migratory bird populations. Ballast water carried from Asian ports and released into local waters could introduce invasive species, to possibly devastating consequence.

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While there are many effects to consider regarding the proposed terminal and increase in marine traffic, several key areas of concern were identified by environmental groups and state agencies during negotiations to a 1999 Settlement Agreement between Pacific International Terminals, Inc. and five citizen groups, including: “impacts to habitat in the footprint of the pier from shading and ship operations; impacts to herring, particularly during spawning season; ballast water exchange; water quality deterioration from construction and operation of the facility; vessel traffic impacts; public access issues, and questions surrounding how many additional piers will be allowed….” As key conditions of the settlement, Pacific International Terminals, Inc. agreed to conduct and fund mitigation and monitoring programs for macroalgae, herring, ballast water, sediment, as well as a vessel traffic analysis, which will evaluate impacts of increased vessel traffic, oil spill risk, hazards at the facility, and bunkering (fueling) operations. Many of these studies have yet to be completed. Additionally, a Biological Assesment (in preparation) will evaluate impacts on marine habitat, threatened, endangered, and priority species, including salmon and herring.

Because part of the proposed terminal (the wharf and nearly all the trestle) will need to be built on state-owned tidelands, a lease from the Washington Department of Natural Resources (WDNR) is required. These tidelands have been recognized by the State of Washington as part of the Cherry Point Aquatic Reserve. In 2010, the WDNR adopted a Management Plan to assist in its management and protection of the Reserve. The Management Plan identifies environmental protection of the Reserve over and above all other management actions. In addition to following the Management Plan, it is also the responsibility of the WDNR, under state law, to withhold from leasing lands which it finds to have significant natural values.

In order to maintain stability and structural strength during transit, cargo vessels fill their ballast tanks with water at one port and then discharge it at another when receiving cargo. A single modern cargo vessel can carry anywhere from 100,000 to 10 million gallons or more of ballast water (6 million gallons is approximately 10 Olympic-size swimming pools) — all potentially containing several hundred different invasive aquatic species (plants, insects, animals, microbes). Once established, the invasive species can become a significant threat to biodiversity because there are often no natural predators to control them. The introduction of invasive marine species into new environments by ships’ ballast water has been identified by the United Nations as one of the four greatest threats to the world’s oceans . The International Maritime Organization (IMO) recommends guidelines to minimize the risk of spreading aquatic nuisance species such as mid-ocean water exchange of ballast water. Several countries have adopted the IMO standards. However, in the United States, the US Coast Guard (USCG) has yet to mandate a ballast water discharge standard to help vessel operators comply with its ballast water management practices.

A wetland impact assessment of the proposed project at Cherry Point has determined direct permanent wetland impacts to approximately 140.6 acres of wetlands, including filling and grading or cutting to raise areas for rail embankments. The project will be located within two coastal watersheds—the Gateway Pacific Terminal Watershed and the Birch Bay Watershed, which contains extensive wetlands associated with Terrell Creek and Lake Terrell, including a 1,500-acre wildlife area managed by the Washington Department of Fish and Wildlife (WDFW) for wintering waterfowl (Canada geese, duck, trumpeter and tundra swans, pheasants). In addition, Lake Terrell wetlands support the second largest heron rookery in Washington. Indirect effects to aquatic systems downstream are expected as well. Potential negative changes to stormwater; soil erosion and sedimentation; and spills and fugitive coal dust all would degrade water quality.

The Cherry Point Aquatic Reserve encompasses important habitats, including those of mixed microalgae (critical for salmon and herring), kelp, eelgrass beds, a salt marsh, and two small freshwater streams, which provide lower salinity in the nearshore, which in turn provides habitat for many fish species, including Pacific herring, salmon, surf smelt, and groundfish. Surf smelt spawning very high up in the tideland area rely on the beach’s mix of sand and fine gravel. The Reserve is listed as a significant bird habitat, and its wetland supports many species of marine and migratory birds. Marine mammals that may use the Reserve’s waters include: Dall’s porpoise, Stellar and California sea lions, gray whales, harbor seals, Southern Resident Killer Whales, humpback whales, seals, and Pacific harbor porpoise.

Marine mammals in and around the waters at the proposed Terminal may be injured or killed by collision with vessels . Disturbance by marine traffic from noise and vessel movement, reduction of food (Chinook salmon, herring, cod), and high levels of environmental contaminants are the three main factors causing the decline of threatened Northern Resident and endangered Southern Resident Killer Whales.

Washington herring are a keystone species, as they provide food for a number of other species. Cherry Point herring, unlike other regional herring populations that spawn at sea in the winter, migrate toward fresh water and estuaries to spawn in the spring. This unique spawning schedule and location makes the Cherry Point herring a vital source of food for endangered Chinook salmon . The Chinook salmon, in turn, provide sustenance for orca/killer whales, porpoises and other marine mammals. Cherry Point herring was once the most abundant herring species in Washington state waters; their population has declined by over 90%. Efforts to have this critical and fragile species declared “endangered” have so far been unsuccessful.

Of recent concern is how to prepare for and respond to an oil spill from bitumen –the type of oil moving through B.C. Canada’s pipeline. Originating from the Alberta Oil Sands, bitumen is thicker and heavier than crude oil and may sink rather than float on the surface making traditional oil spill response and clean-up methods likely ineffective. Not knowing how much bitumen is currently exported through our region’s waters or how a spill would affect the environment, the Washington Department of Ecology acknowledges its concern, especially in light of the planned pipeline expansion.

Tens of thousands of marine vessels transit the Strait of Georgia every year, including those destined for Cherry Point. The Strait of Georgia has been designated by Parks Canada as Canada’s “most-at-risk natural environment. ” Vessel traffic is growing due to a rise in exports and plans for a major oil pipeline expansion in Canada. Coal transport from the proposed terminal at Cherry Point would require, at build-out, an additional 974 annual transits by some of the largest oceangoing vessels. Despite the increase in vessel traffic and a Vessel Traffic Risk Assessment correlating higher vessel traffic levels with a higher risk of accidents and oil spills, Washington’s oil spill response program is facing budget cuts . Effects from collision or grounding are amplified by the type of vessel and cargo; oil and/or coal would be devastating to marine life, shorelines, and Washington’s economy in the event of a spill.

FISHERIES

Partly due to its deep water feature, Cherry Point has been an especially rich and fertile marine area. The waters around Cherry Point have traditionally been part of abundant salmon and lingcod fisheries. There has also been a vigorous recreational, commercial, and tribal Dungeness crab fishery. Damages to the local herring population would result in damages to the salmon and lingcod fisheries, as herring are a primary source of nutrition for these fish. Heavily increased marine traffic could result in losses both the fisheries and the fisherman, as crabbing gear can be destroyed or carried away by large marine vessels.

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QUALITY OF LIFE and REGIONAL IDENTITY

The Northwest is a region noted for spectacular physical beauty, an emphasis on “quality of life,” and a dedication to clean, healthy living and environmental stewardship. It is considered a prime tourist destination spot and a highly desirable place to live; it is both agriculturally rich and a haven for innovative business. The pollution, traffic, noise, and degradation of our waters and fisheries that would come with significant coal train and ship traffic is at odds with our enjoyment and stewardship of this region. Choosing to become an economy in which coal transport is an emphasis seemingly undermines aspirations to build on the Northwest economies of tourism, healthy agriculture, innovative businesses, clean energy and the manufacture of local goods. Even our icons – the salmon and the orca– would be imperiled by the proposed project. The Northwest’s most valuable asset is our quality of life –witness the profusion of Northwest communities on “best places” lists– and this quality is what hangs in the balance.

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Along the Puget Sound rail corridor, many communities have invested in the transformation of waterfront from industrial to commercial use as an essential part of a plan for sustainable economic viability. A continuously in-use train track effectively shears such a town off from its waterfront, and jeopardizes such long-term planning. For example, according to a study conducted by CommunityWise Bellingham, Bellingham’s waterfront Boulevard Park and Taylor Street Dock could be cut off entirely from vehicular access by the addition of coal train rail siding. The transport of another region’s goods to another country brings limited benefit to our region, at significant cost to our region. In particular, many feel that the export of a highly polluting form of fossil fuel is contradictory to this region’s values and dedication to phase out domestic coal-burning power plants. The Puget Sound Partnership compiled an action agenda which addresses many of these quality of life concerns.

COAL DUST

Coal dust is notoriously difficult to control. BNSF estimates that each uncovered car loses between 500 pounds and a ton of coal dust en route. It is unknown how much coal dust will be released into the air, onto the land, and into the water from the from the 80-100+ acres of open, continuously turned-over, coal heaps in storage at the terminal site. There are concerns about train derailments, the effects of dust on human health, local clean water supplies, and on the marine environment. The methods of containing coal dust, especially in adverse weather conditions (wind, rain) are unproven, and it is uncertain which party would pay for dust mitigation measures.

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COAL TRAIN DERAILMENTS

And, a 2006 spill that resulted in 2 loaded cars being submerged in the Clark Ford River:

Trout Creek, MT – November 2006, 2-4 cars spilled and submerged into Clark Fork River – resulting in EPA Superfund action.

AIR QUALITY

Pollutants, weather, wind patterns and topography all affect local air quality. Accurately predicting the effects of the Gateway Pacific Terminal on the air we breathe, and thus on public health, will require much good science. Both the means of transporting coal and the coal itself present potential air quality challenges. Diesel particulate matter emitted by the coal trains and ships; fugitive coal dust from the trains and from storage at the port site; and the toxins that blow over the Pacific to the West Coast of the US from coal combustion in Asia, are all cause for concern with regard to regional air quality and the resultant health effect on humans who breathe that air.

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The locomotives and ships that would transport coal through our region are diesel-burning; diesel particulate matter causes cancer and other diseases. Up to 18 trains a day, each powered by an average of 4 locomotives, would pass through our rail communities; immense coal ships would make over 950 annual transits right by island and coastal communities. Emissions from locomotives and ships vary depending upon the type of fuel burned, how old the engine is, and how hard the engine is working at a given time. Air quality studies conducted in Spokane and in California have shown that neighborhoods in proximity to heavy rail activity have increased rates of cancer. The EPA considers ocean vessels and large ships to be “significant contributors to air pollution.” BNSF has indicated that each coal car loses 500 lbs to a ton of coal dust en route; 80 near shore acres at the GPT terminal site would be covered in open heaps of coal. Newspaper photos of coal dust over two relatively small British Columbia coal ports, one at Westshore and one at Ridley would seem to indicate that dust management, as currently practiced, is not effective. While coal dust is a reported nuisance in coal port communities, the health effects of pulverized coal released into the air have not yet, to our knowledge, been systematically studied. Coal dust inhalation in closed situations is, of course, a different matter, although instructive in the kind of governmental oversight and corporate compliance that is necessary to keep people safe: NPR and the Center for Public Integrity recently reported the resurgence of black lung disease in American miners is due to “weak regulation and industry deception.” It is worth considering that our air is directly affected by what happens in Asia, the market to which GPT would ship coal. The Jaffe Group has proven that mercury emitted by coal combustion in Asia crosses over the Pacific Ocean and pollutes our Northwest water supplies; mercury is implicated in a number of health problems, especially those involving the brain and nervous system. The New York Times has written that sulphur dioxide, which can cause respiratory disorders, likewise blows back to us from Asia. Noted meteorologist and UW atmospheric scientist Cliff Mass has shown that the haze over much of the Pacific Northwest coastline in early summer 2012 was smoke from massive Asian wildfires. What burns in Asia does not stay in Asia: we all breathe the same air.

NOISE

While there are many sources of noise from trains (high-pitch screeching, idling engines; moving cars, etc.), horn sounding is the most significant. Federal rules governing the blowing of locomotive engine horns require that engineers of all trains sound horns for at least 15-20 seconds at 96-110 decibels (dB) at all public crossings. Decibels in the range of 80-105 are labeled extremely loud, whereas those above 105 are dangerous. Decibels are logarithmic, meaning that 100 decibels is ten times as loud as 90, 110 decibels is ten times as loud as 100, and so on. While impacts to quality of life from repeated loud noise are self-evident, chronic noise exposure has proven adverse health effects, including impaired sleep and cognitive function, and cardiovascular effects.

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Noise Level and Frequency: The Federal Railroad Administration (FRA), regulates the sounding of train horns at public highway railroad at-grade crossings i.e. where a public roadway crosses the railroad tracks at the same level. Under the train horn rule, the FRA requires train horns to be at least 96 dB and no louder than 110 dB. Since sound propagates depending on conditions like weather, openness of land, etc., only someone standing right next to the train hears the horns at 96-110 dB levels. Using the inverse square law, an estimate of someone living within 300 feet of the rail can be predicted to hear a train horn of 110 dB at 70.77 dB, which is categorized as very loud. With few exceptions, before reaching an at-grade crossing, the FRA requires a locomotive engineer to sound the horn in a pattern: 2 long: 1 short: 1 long for a minimum of 15 second and a maximum of 20 seconds. An Example of Potential Noise Increases: There are 12 at-grade public crossings within the City of Bellingham. Current train traffic through Bellingham is estimated at 12-15 trains per day, accounting for at least 36 minutes of horn noise (15-second soundings x 12 at-grade crossings x 12 existing trains = 2,160 seconds). An additional 18 trains per day will add 54 minutes of horn soundings: (15-second soundings x 12 at-grade crossings x 18 trains = 3,240 seconds) for a total of 90 minutes. Each day, this 90 minutes will be comprised of at least 1440 horn blows (4 x 12 at-grade crossings x 30 trains). Adverse Health Impacts from Noise: Studies on noise from aircraft, roadways, and trains show that continuous noise above 30 dB or frequent intermittent noise disturbs sleep. In addition to sleep disturbance, noise during sleep causes increased blood pressure, increased heart rate, increased pulse amplitude, vasoconstriction, changes in respiration, cardiac arrhythmias, and increased body movement. Secondary effects from sleep disturbance can also occur including fatigue, depressed mood and well-being, and decreased performance and alertness. Cardiovascular effects, independent of sleep disturbance, can also occur with acute exposure to noise mostly due to elevated blood pressures and levels of stress-induced hormones. In addition, noise can exacerbate stress and anxiety and impair task performance. The National Institute for Occupational Safety and Health recommends less than 15 minutes of exposure per day to noises over 100dB. Noise Mitigation: To mitigate train noise, some cities have established quiet zones, in which safety modifications are made to public crossings; exempting trains from their horn soundings at the modified crossing. However, the high cost of significant improvements at public crossings borne by cities and taxpayers has been a deterrent. Moreover, once a crossing is converted into a quiet zone, liability shifts from the railroad to the city for any traffic or personal injury incurred within the quiet zone.

PUBLIC HEALTH

Frequent long trains at rail crossings will mean delayed emergency medical service response times, as well as increased risk of accidents, traumatic injury and death.

The scale of the proposed terminal would require a dramatic increase in the number of diesel-burning locomotives and marine vessels affecting Puget Sound airsheds. Diesel particulate matter is a particularly noxious form of air pollution, as it is of sufficiently small size (PM 2.5) to embed in the lung tissue. Diesel particulate matter is associated with both pulmonary and cardiovascular issues, including cancers, heart disease, and asthma. Children, teens and the elderly are especially vulnerable. Noise exposure can cause cardiovascular disease; cognitive impairment in children; sleep disturbance and resultant fatigue; hypertension; arrhythmia; and increased rate of accidents and injuries; and exacerbation of mental health disorders such as depression, stress and anxiety, and psychosis. Transporting coal to China in particular has the potential to raise levels of mercury in our waters. Mercury is associated with neurological dysfunction, as in ALS, Parkinson’s, and Alzheimer’s.

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GLOBAL IMPACTS

While the Gateway Pacific Terminal and the associated coal trains would be active in only the transport and export of coal, it is important to recognize that the only function of coal transport is to link coal mining to coal combustion: GPT and related enterprises need to be considered as part of this larger system. Each of the various processes associated with coal have negative effects on local economies, public health, communities and the environment. The coal mines in the Powder River Basin (Montana and Wyoming) continue to degrade local aquifers and water supplies. Coal combustion in China presents a serious health risk to the hundreds of millions of people, especially children, who live in affected airsheds. Coal combustion is also associated with negative impacts that transcend geographic borders. Ocean acidification, acid rain, mercury emissions, and climate change affect global populations, regardless of where the coal is burned. The financial cost accrued from health and environmental damages from coal mining, processing, transport and combustion are currently estimated at a third to over half a trillion dollars annually in the U.S. alone.

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SCOPING: THE PUBLIC’S OPPORTUNITY TO BE INVOLVED

The public will never vote on the GPT project, however, it had an opportunity to officially express concerns about the proposal during a period called scoping. The scoping period lasted for 120 days; beginning on Monday September 24, 2012 and ending on Tuesday January 22, 2013. Comments made at official sessions or submitted in writing during the scoping process will help inform the type and the geographic scope of impacts to be included in the Environmental Impact Statement (EIS). The EIS is the key document for the various agencies and individuals involved with approving or denying permits, permissions and/or leases for the project. You can view submitted comments as part of the GPT EIS scoping process.

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PERMITTING: WHO DECIDES AND HOW

The permitting process for GPT will be complex and will involve multiple levels of federal, state and local review. Decision-makers include the Whatcom County Council for shoreline and development permits and the Public Lands Commissioner at the Department of Natural Resources for an aquatic lease (state-owned tide lands). The Department of Ecology, the Department of Fish and Wildlife and the U.S. Army Corps of Engineers must also grant approvals in order for the project to go through. These governmental bodies will consider the Environmental Impact Statement when making their decisions. The Lummi and Nooksack Nations, following their own processes, will render pivotal decisions regarding usual and accustomed fishing grounds.

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ENVIRONMENTAL REVIEW