By Chom Graecen
“Scoping” is your first opportunity to make a difference in the permitting process of the Gateway Pacific Terminal (GPT), the coal terminal proposed for Cherry Point.
Before the coal terminal can proceed, a lengthy environmental review must be conducted jointly by Whatcom County, the Washington Department of Ecology, and the U.S. Army Corps of Engineers. Until Jan. 21, 2013, these agencies will accept public comment on the scope of this environmental review and you have and several options to be heard.
These agencies want to know what you want them to study; that’s “Scoping.” Scoping is very important—topics left out of the scope of review won’t be studied. It’s up to you to tell the agencies what you want included—and why.
A scoping comment can be written however you want, but comments can be made especially effective by describing how or why the impact you’re concerned about is:
Adverse- the impact affects people, businesses, resources or ecosystems negatively
Significant- the impact affects a lot of people, or a few people severely
Reasonably foreseeable – the impact is likely to result from the proposed development (in this case a coal terminal at Cherry Point)
“The lead agency shall narrow the scope of every EIS to the (1) probable SIGNIFICANT ADVERSE IMPACTS and (2) REASONABLE ALTERNATIVES, including MITIGATION measures” (Wash. Admin. Code sec. 197-11-408(1)).
Here is a good outline for writing effective comments: https://www.coaltrainfacts.org/docs/comment_outline.pdf
1. Impact: Introduce yourself, state your purpose for writing, and the impact you want scoped. Be specific, stating the direct, indirect, or cumulative impact you want studied (“Please study the effect of emissions from (diesel and bunker oil) particulates from ships on people with asthma living on the south end of Lopez where ships would idle while waiting for clear passage on Rosario Strait).
Avoid stating an opinion (“I oppose…,” “I do not believe that…,” “I fear….”).
2. Significance: Describe the significance of the impact (risks to lives, species, businesses, opportunities, etc). Define the breadth of the scoping necessary to adequately address the significance of the impact in terms of time, geography, and all populations impacted. Discuss cumulative Impacts. Consider if an impact is measureable.
3. Foreseeable: Provide support as to why this impact is foreseeable. Link the harm to an activity necessary for the operation of a coal terminal. Consider specific references to the Project Information Document if available. Provide supporting information or relevant research when arguing potential harms of the impact.
4. Alternatives: Discuss the alternative(s) or mitigations you want the EIS to consider, including: (a) no action (no project permitted), (b) proposal with mitigations, and (c) other reasonable courses of action.
Proceed with caution:do you want a coal terminal with mitigations or do you want to stop the construction of the coal terminal? If the latter, you should discuss why mitigations are inadequate.
5. Ask: Ask what you would like studied, why, and any ideas as to how:
“Please study… (the impacts of quakes and tsunamis on coal ships and terminal)… by… (conducting a worst case risk analysis of earthquakes in the Salish Sea and an analysis of if and how adverse impacts from a worst case quake can be mitigated)…because … (if the risk is not zero and the impacts of ships running aground can be devastating and cannot be mitigated, the project should not be permitted).
Where to submit a comment:
Mail:
GPT/Custer Spur EIS c/o CH2M HILL,
1100 112th Avenue NE Suite 400
Bellevue, WA 98004
Email: comments@eisgatewaypacificwa.gov
Web: www.eisgatewaypacificwa.gov
Comment Meetings:
Friday Harbor, Friday Harbor HS, Nov 3, 12-3 pm
Mt. Vernon, Skagit Comm College, Nov 5, 4-7 pm
Seattle, N. Seattle Comm College, Nov 13, 4-7 pm
Ferndale, Ferndale Events Center, Nov 29 3-7 pm
Spokane, Spokane Fairgrounds, Dec 4, 4-7 pm
Vancouver, Clark College, Dec 12, 4-7 pm
Resources:
Coal Train Facts: coaltrainfacts.org
CommunityWise Bellingham: communitywisebellingham.org
Power Past Coal: powerpastcoal.org
Protect Whatcom: protectwhatcom.org
SafeGuard the South Fork: safeguardthesouthfork.org
Whatcom County Planning: co.whatcom.wa.us/pds
Gateway Pacific Terminal: gatewaypacificterminal.com
For more information and links to resources and impact list, please visit:
www.orcasnocoalition.net
Notes: The above text are borrowed and adapted from RE-sources and Coal Train Facts.
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