Comment On Proposed Anchorages Near Guemes Island

The Coast Guard proposes establishing official sites for marine traffic - tankers, tugs, barges and commercial fishing boats - to anchor in waters near Guemes Island.

"Of the 15 sites included in the proposal, five are in the waters of northwest Skagit County near Samish, Guemes and Vendovi islands.

Two sites near Vendovi Island — to the north of Samish and Guemes islands — would be made available for deep draft commercial ships more than 200 feet long.

A site just north of Samish Island’s William Point would create an area for tug and barge ships to anchor.

Two sites near Jack Island northeast of Guemes Island would be available to tugs, barges and commercial fishing boats less than 200 feet long to anchor for up to 10 days at a time."

-   Skagit Valley Herald

Comment On The Anchorages Proposal

Please Submit Your Comments By August 9.

Suggested comments:

Affected citizen comments on Docket number USCG-2016-0916

I am a resident of Guemes Island who is affected by various aspects of tanker activity in and near the Vendovi Island and Jack Island Preserves.  The action proposed in the Docket number above will have an effect on me, my neighbors, marine life, air quality, and other aspects of the environment to a degree that requires an Environmental Impact Statement be prepared.

An EIS is required in order to allow decision-makers to fully understand the impacts of their decisions on the human environment as required by the National Environmental Policy Act.  Equally important, the decision-makers are required to consider alternatives to the proposed action.  Neither of these requirements is met by the current handling of this matter by the Coast Guard or other authorities.  An EIS is required.

The regulations.gov web site explains that, “The purpose of these actions is to improve the safety of all Puget Sound waterway users.”  This of course is an admirable goal which I fully support.  But the proposal to pursue this without environmental analysis (i) is based on fatally circular logic, (ii) gives too short shrift to the very real environmental impacts of the proposal, and (iii) uses conclusions based on that inadequacy to avoid the need to consider alternatives to accomplishing the stated goal.  With a regulation of this magnitude, the law requires more.

CIRCULAR LOGIC
Much, if not all, of the justification for avoiding further study of the impacts of the proposal is the jarringly circular logic of the statement “the affected areas of the Puget Sound have been used historically as informal anchorages and areas in the manner proposed.”  Thus, the logic is:
1.  The Coast Guard works with “shipping agents, pilots, and other stakeholders” to “to start using these anchorages and areas to improve the safety of maritime traffic.”  No environmental impact is studied because the arrangement is “informal.”  That is, no regulations are proposed like those now presented.
2.  The “informal” use begins and, we are now told, has become “historic.”
3.  Now the agency concludes that no Environmental Impact Statement is needed exactly because the proposal simply formalizes the “historic” and “informal” use (of whose impacts we are completely ignorant).
This is a flagrant skirting of the agency’s responsibilities under NEPA.

ENVIRONMENTAL IMPACTS
Air quality.  It is beyond question that moored tankers emit noxious and potentially harmful fumes.  Reports from Bellingham and nearby communities make this clear.  The Coast Guard’s explanation is that, “The smell of the fumes is indicative of cargo vapors being released as a result of pressure build-up within the cargo tanks.  This is a normal occurrence that ensures the safety of the tanker and our waterways.”  The proposed action will facilitate these “normal occurrences” by better accommodating the offending vessels.  More, it might move some of those “occurrences” closer to populated areas.
This environmental impact cannot be brushed off by the Coast Guard by saying, as its web site explanation offers, “Well, tankers already use these areas ‘informally.’”  Formalizing this use and its impacts on air quality, and formally authorizing the toxic occurrences closer to human residences is an agency action that surely requires more thought and investigation.  The Coast Guard should be preventing these impacts, not writing them into law and regulations.

Light and noise.  Similarly, moored tankers present a light and noise problem in the human environment.  Encouraging more of this by making it “safer” for tankers to anchor in the area, let alone closer to human habitation, is a step warranting careful consideration and weighing of alternatives.

Marine life. The impacts on marine life are unknown because we haven’t investigated it because these impacts occur only “informally.”  Tell that to the orcas, salmon, other marine mammals, and the rest of the food chain whose ultimate impact on human live is critical.  The proposed response is, “Well, the tankers are going to do it anyway, so let’s at least make is safer.”  This crabbed approach to the agency’s responsibility is unacceptable both as a matter of policy and of law.

ALTERNATIVE WAYS TO IMPROVE SAFETY
With impacts of the magnitude contemplated here, NEPA requires that federal agencies consider alternative ways to accomplish identified goals.  In the present situation, one obvious alternative is to reduce the amount of tanker traffic in the affected area.  This is not a flippant or frivolous comment.  Increasing tanker traffic is obviously a safety issue in the area, as demonstrated by the very existence of the current proposal, and traffic reduction would clearly advance the goal of safety.

Instead of contemplating and evaluating alternatives, though, the current proposal appears to assume increased traffic simply must be accommodated.  That is not consistent with NEPA’s requirements.

NEPA is one of our primary tools for protecting the environment on which we all depend.  Innumerable governmental and other authorities have noted with great concern that we are currently experiencing climate change so critical that it rises to the level of a national security issue. 

The cumulative impact requirement of NEPA and the EIS process is intended to empower us to protect critical environmental facets from “death by a thousand cuts.”  We cannot allow our environment and attendant national security concerns to suffer that fate while all we do is produce a thousand reasons not to do an EIS each time saying, “Well, this particular cut won’t really matter so much. We suspected it might be a cut but we decided it wasn’t big enough to think about.”  That outcome is plainly a failure to heed NEPA’s call and to meet its legal requirements.

Actions like this one require consideration not only of its immediate and local impacts, but of how it contributes to cumulative impacts.

Thank you for your consideration.
 
Email Comments Are Due August 9, 2017, 10:00 pm PST
All Comments Must Include: Docket Number USCG-2016-0916
Copy the suggested text and paste it into an email. Alter it or add to it as you wish.
Email: SectorPugetSoundWWM@uscg.mil


Stephen Orsini's Comments On The Proposed Anchorages

"With growing alarm, I have witnessed the increasing anchorage of large tankers, well in excess of 200 feet, and large oil barges in the vicinity of Vendovi, Jack, Guemes Islands and the Samish Peninsula.  It is not now uncommon to see 4 large tankers and two large oil barges in these anchorages at the same time.  Some of the tankers, all of foreign registry, anchor for weeks at a time."  [Read more]


Burping Tankers Yield Sulfurous Vapors

"The smelly cloud of sulfurous fumes that wafted over Bellingham Saturday evening, June 3, was apparently not that unusual an occurrence."


Vendovi Anchorages

(i) Vendovi South General Anchorage. All waters shoreward of a line beginning at latitude 48°36′40″ N., longitude 122°36′51″ W.; thence to latitude 48°35′34″ N., longitude 122°36′51″ W.; thence to latitude 48°35′34″ N., longitude 122°35′53.62″ W.; thence to latitude 48°36′31.38″ N., longitude 122°35′53.62″ W.

(ii) Vendovi East General Anchorage. All waters in an area beginning at latitude 48°37′43″ N., longitude 122°34′45.5″ W.; thence to latitude 48°37′43″ N., longitude 122°31′44″ W.; thence to latitude 48°35′43″ N., longitude 122°31′44″ W.; thence to latitude 48°35′43″ N., longitude 122°34′45.5″ W.; thence to point of origin.

Jack Island Anchorages

(iii) Jack Island North Tug and Barge Holding Area. All waters within a circular area centered at latitude 48°35′22″ N., longitude 122°37′20″ W., with a radius of six hundred yards.

(iv) Jack Island South Tug and Barge Holding Area. All waters within a circular area centered at latitude 48°34′24″ N., longitude 122°36′13.5″ W., with a radius of six hundred yards.