Individual comment detail

Olson, Sanford
Date: Jul. 29, 2014
Multiple/not listed
Human environment:
Other human environment topic
EIS process:
Alternatives, Area of potential effect, EIS/regulatory process, Other EIS process topic
In the 7/23/14 Crosscut article Ms. Kelly was quoted as follows: “Ecology’s Alice Kelly told Crosscut that work has been done on off-site or “indirect” issues, such as rail, shipping, fish and health issues, that will not be affected by changes to wetlands.”

I would emphasize RAIL and SHIPPING are not "indirect" issues to the GPT DEIS. The revised site plan includes an immediate build-out to full capacity and the maximum number of vessels utilizing the facility instead of the previous phase development plan. Here in the San Juan Islands this means an abrupt increase in ship transits through our waters without adequate study and work on pilotage expansion and oil spill prevention and response capabilities. Those on the mainland will also likely alarmed by a more rapid increase in the numbers of unit coal trains passing through communites, particularly when considering the added cumulative effects of increased oil shipment by rail. Cumulative rail shipment on mainland communities and vessel transport of fossil fuels through San Juan County waters must be properly evaluated.

Puget Sound Pilots don’t currently pilot the Cape size vessels that will call on GPT (the Cape size vessels in San Juan waters now are traveling to and from Canada with Canadian pilots). It would seem prudent to assume that a training period would be required for the Puget Sound Pilots to gain experience and expertise in piloting these vessels. It bears review in an EIS whether an application plan with phases that more gradually ramp up the numbers of Cape size vessels would result in less risk of an accident and less risk of an oil spill than a plan with immediate full build-out and maximum vessel numbers.

Therefore, I conclude that GPT’s “new preferred alternative” terminal design now includes significant changes that would affect San Juan County and thus would require a new application and the opportunity for public comment on the EIS scoping process.