July 30, 2002

Mr. Dan Stahl
Port of Anacortes
P.O. Box 297
Anacortes, WA. 98221
Submitted by FAX (360-293-9608)

Dear Mr. Stahl:

Re:  T. Bailey Steel Fabrication Facility – March’s Point

On behalf of People For Puget Sound I am submitting these comments on the Port of Anacortes Mitigated DNS for the T. Bailey Steel Fabrication Facility proposed at March’s Point.

People For Puget Sound’s mission is to protect and restore the health of Puget Sound and the Northwest Straits.  Our members are actively involved in habitat protection and restoration in Skagit County, including the March’s Point area.

The March Point Heronry is very significant to Puget Sound’s nearshore environment. With more than 430 nests, this fast-growing heronry is second only to the Point Roberts Heronry in size.  Padilla Bay’s adjacent eelgrass beds provide a perfect fishing area, and the open fields nearby provide plentiful rodents, making March’s Point ideal heron habitat.  Herons are identified as a priority species and heronries as a priority habitat by the State of Washington Department of Fish and Wildlife.

While it is apparent that the Port is aware of and concerned about the heronry, we have a number of concerns about the project, which could best be evaluated in a full environmental impact statement, along with alternative sites and alternative site designs.

Specifically with respect to heron impacts, the proposal should be modified to avoid both construction and operations impacts from March through August.  Both during construction and during operation, sudden loud noises need to be avoided especially in April and May when eggs are in the nests.  This is a time when it is crucial not to scare adults off the nest.

In addition, a much bigger permanent buffer is necessary to avoid impacts during operation of the facility over the long term.  The proposed 200-foot buffer does not measure up to guidance from the Washington Department of Fish and Wildlife (820-984 feet), nor is it at all comparable to the 300 meter buffer required at Point Roberts for a much quieter development (a golf course).  Any development in the vicinity of the heronry should also include a thorough, independent monitoring program so that additional protective measures can be taken if impacts are noted.

There are other important issues that need to be addressed in an environmental impact statement:

Bald eagle nesting and activity in the vicinity of the project.

Emissions from the proposed facility.

Stormwater pollution and management.

Details about the site design and the “best management practices.”

Lighting.

Reclamation of the site after its previous use.


We cannot stress enough the significance of the March’s Point Heronry.  We appreciate the opportunity to comment, and look forward to working with you in an EIS process that will fully evaluate the project’s impacts and alternatives.

Thank you.

Sincerely,



Kathy Fletcher
Executive Director