Evergreen Islands PO Box 223 Anacortes, WA
PO Box 223
Anacortes, WA 98221
March 21, 2002
Port of Anacortes
P.O. Box 297
Anacortes, WA 98221
Re: Lease of March Point Property to T. Bailey
cc: Skagit Land Trust, City of Anacortes, Skagit Audubon,
Friends of Skagit County, People for Puget Sound
Evergreen Islands is duly concerned that moving T. Bailey’s current operation to the Port of Anacortes’s March Point property will drive the herons away from this heronry of statewide significance. We are concerned about the following potential impacts on the heronry:
o Loud noises that will be generated 24 hours a day and 7 days a week.
o Ground vibrations that occur around the clock.
o The effect of increased light throughout the night.
o Increased traffic on the frontage road.
o Significant loss of value of the adjacent Skagit Land Trust holding.
The development of sensitive environmental sites like March Point are formally addressed by both the Port’s Comprehensive Plan (CP) and the State Environmental Policy Act (SEPA). The Port’s CP (Page II-3) lists 3 basic criteria to be used by the Commission: Community, Environmental, and Economic/Functional. The Environmental Criteria include: compatible with existing adjacent uses, protects sensitive environmental areas, and encourages resource conservation. On the very same page, the SEPA process is included in the table entitled Project Implementation (Opportunity for Public/City/Agency Comment).
Evergreen Islands strongly believes that an Environmental Impact Statement Process is required for this proposed project. As stated in the State Environmental Policy Act Handbook,
“The primary purpose of an EIS is to provide an impartial discussion of significant environmental impacts, and reasonable alternatives and mitigation measures that avoid or minimize adverse environmental impacts. This environmental information is used by agency officials—in conjunction with applicable regulations and other relevant information—to make decisions to approve, condition, or deny the proposal.”
According to the Handbook (page 36 of the SEPA Handbook describes the EIS Process in more detail and is attached to this letter), the EIS Process:
o Provides opportunities for the public, agencies, and tribes to participate in developing and analyzing information.
o Improves proposals from an environmental perspective.
o Provides decision-makers with environmental information.
o Provides the information necessary for conditioning or denying the proposal.
The SEPA Rules, WAC 197-11-794(1), state that significant “means a reasonable likelihood of more than a moderate adverse impact on environmental quality.” The loss of this heronry will be “more than a moderate adverse impact on environmental quality,” and the noise currently emanating from T Bailey’s manufacturing process presents a reasonable likelihood that the relocation of this business to March Point will negatively impact the heronry. We urge the Port of Anacortes to acknowledge the potential environmental impacts of this project, and in so doing, issue a Determination of Significance for this project.
SEPA Handbook, Washington State Dept. of Ecology,
Publication # 98-114, Sept. 1998, p. 36
3. Environmental Impact Statement Process
An environmental impact statement (EIS) is prepared when the lead agency has determined a proposal is likely to result in significant adverse environmental impacts (see section on how to Assess Significance on page 23). The EIS process is a tool for identifying and analyzing probable adverse environmental impacts, reasonable alternatives, and possible mitigation.
The EIS process:
o Provides opportunities for the public, agencies, and tribes to participate in developing and analyzing information. Public, agency, and tribal input help to identify a proposal's significant adverse environmental impacts, reasonable alternatives, possible mitigation measures, and methods of analysis for the EIS. Outside participation during all phases of the process increases understanding of the proposal and garners trust.
o Improves proposals61 from an environmental perspective. Proposals are improved through mitigation of identified adverse environmental impacts, and development of reasonable alternatives that meet the objective of the proposal. Changes may be made voluntarily by the proponent, or they may be mitigated through SEPA substantive authority62 or other regulatory authority. Through the EIS process, areas of controversy and other significant issues are identified early when the opportunities to consider a broad range of solutions are greatest.
o Provides decision-makers with environmental information. An EIS provides decision-makers and the public with a complete and impartial discussion of the proposed project, existing site conditions, probable significant adverse environmental impacts, and reasonable alternatives and mitigation measures that would avoid or minimize adverse impacts. This provides the information needed for informed decisions.
o Provides the information necessary for conditioning or denying the proposal. Based on information in the EIS and the agency’s adopted SEPA policies, SEPA substantive authority allows a decision-maker to:
o Deny a proposal when “significant” environmental impacts cannot be reasonably mitigated;
o Place additional conditions on the project to protect the environment from adverse environmental impacts; or
o Approve the proposal without further mitigation.
(See section on Using SEPA in Decision Making, page 62.)
61 WAC 197-11-400(4)
62 WAC 197-11-660