October 16, 2016 Dena Jensen
|Dear Whatcom County Planning and Development Services Director Ryan, Assistant Director Personious [sic], and Senior Planner Aamot:
I am writing regarding the information presented on your 2016 Docket, Cherry Point Amendments (PLN2016-00012) webpage at this link: http://wa-whatcomcounty.civicplus.com/1612/2016-Docket. I notice that one of the alternatives that is identified, Alternative # 1 – Council Member Alternative (proposed by an individual Council Member), does not meet the criteria listed in the SEPA handbook under 3.3.2 Identifying Alternatives, which is, as follows:
I can see from reviewing the Proposal – Council Resolution (initiated by Council under Resolution 2016-027), and Alternative # 1 separately, and also from looking at the comparison provided at this link, Comparison of Proposal and Alternatives, that Alternative #1 does not provide a lower environmental cost or decreased level of environmental degradation than the proposal.
Alternative #1 does not provide these protections included in the Proposal under Policy 2CC-2:
The protections below, offered in under Policy 2CC-2 for Alternative #1, are non-specific and would only be potentially pursued if and when existing facilities expand or upgrade.
Also, if facilities expand or upgrade, depending on the nature of the expansion or upgrade (for example if crude-by-rail operations were expanded), there could be a greater environmental cost and increased environmental degradation. “Increasing environmental protection” on an operation with greatly increased hazards to the environment attached may not be effective in reducing environmental cost and degradation as a whole.
For Policy 2CC-10, Alternative #1 does not indicate that no additional industrial piers can now be allowed at Cherry Point (since the GPT project cannot proceed without the required permit from the Army Corps of Engineers) and does not note that the prohibition of industrial piers is in force in order to:
Here again Alternative #1 would offer a potentially greater, not lower, environmental cost and a potentially increased, not decreased, environmental degradation.
For Policy 2CC-14, Alternative #1 does not offer any comparable policy (and thus does not offer lower environmental cost or decreased level of environmental degradation) to the protections offered by the Proposal, that proposes new policy to,
For Policy 2CC-15 Alternative #1 does not offer the protection included in the Proposal to
Excluding this protection from Policy 2CC-15 would, once again, not offer a lower environmental cost or decreased level of environmental degradation.
I remind you that the SEPA Handbook states:
Since for each and every policy included in the Proposal and Alternative #1 comparison, Alternative #1 fails to offer a lower environmental cost or decreased level of environmental degradation, Alternative #1 does not meet the criteria to be considered an alternative according to the SEPA Handbook. Therefore, I ask that Alternative #1 be removed as an alternative for the Cherry Point Amendments to the Whatcom County Comprehensive Plan.
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And was copied to these addresses: