My Comments to the City of Anacortes Regarding Its UGA Extension Application

by Ross Barnes Monday, August 20, 2012 6:46 AM

(Since Dr. Barnes’s comments are technical, the editor has added brief headings have been included to aid the reader.  The additional headings are bold text enclosed in parentheses.)

Mayor Dean Maxwell,
Anacortes City Council


(Tongue in Cheek)
Once again I applaud Mayor Maxwell and the Anacortes Chamber of Commerce for seeking good wage jobs for Anacortes.  I urge the Council to move this application on to the county where I am sure it will receive the attention and action it deserves.  I have a few observations and questions that if considered may make this application even more deserving. 
(Note: all references to Skagit County Code SCC 14.08.020 and 14.16.170 (7)(e)can be found in Appendix D)

(By Skagit Code, a UGA Application Must Include a Development Proposal)

Skagit County Code SCC 14.08.020 (7)(b)(i) requires that a UGA amendment/rezone application include "a detailed development proposal that is consistent with the applicable designation criteria".  Tethys proposal and no other IS obviously the code required development proposal.  Without that proposal about half of the application would be redacted and the application would not be complete or responsive to code requirements.  The code also makes clear that viability of the required "detailed development proposal" will be an essential element of review and approval of the application--see SCC 14.08.020 (7)(b) & (c), including "commercial and industrial zoning is not intended for speculative purposes".  Also, as stated in the application at Section 3, question 9, the only early public involvement required by SCC 14.08.020 (5)(b)(xi) was one opportunity for public comment in the fall of 2011, not on the UGA expansion, but on the Tethys contract.

(A City GMA Appeal Created the UGA Dogleg Anomaly)

The application errs at Section 3 Response 2. C. when it says that the dog leg in the Anacortes UGA was an anomaly of the original UGA boundary.  The original UGA boundary as shown on the attached section of the November, 1999, Skagit County Comprehensive Plan map (Exhibit A) was rationally drawn along Stevenson Road with NO dog leg.  The dog leg "spot zone" was created later and associated with actions and appeals of the City of Anacortes.  In fact, the current application does not "correct" the dog leg condition but just makes it worse, contrary to the assertion of Section 3 Response 5. 

(The Destruction of the Turners Bay Saltwater Marsh)
To wit, this application leaves the Turners Bay western shoreline and the Bay estuarine habitat in Skagit County jurisdiction south of Stevenson Road.  Does anyone believe that Skagit County would/could approve filling and destruction of the Turner Bay shoreline and estuary to construct the rail storage and switching yard that is an essential part of the jobs creation proposed by this application?  Turners Bay is the site of a current major salmon habitat restoration project supported by the tribes (Exhibit B).  With regard to Turners Bay estuarine wetlands, the application response to question 12 is ludicrously inaccurate. 

(The Proposed Site Is In Both The City and In the County)
Does anyone believe this application will meet contractual requirements for job creation IN Anacortes when the City/County boundary passes thru the middle of the jobs creating industrial building, with the County's portion located in incompatible RMI zoning?  When the greater part of the rail storage and switching yard that is an essential part of the jobs creating development proposal will be located in adjacent Skagit County in incompatible RMI and RRv zoning, not to mention again--critical estuarine habitat?  Also with respect to RMI zoning, the required development site plan violates SCC 14.16.170 (7)(e) which requires storage areas (i.e. - a rail storage yard) to be located entirely outside shoreline jurisdiction.   And in these issues, the application violates SCC 14.08.020 (7)(b) & (c) because the proposed "development area" extends far beyond the UGA expansion/rezone into Skagit County where zoning, shorelines, and land use regulations, including setbacks and impervious lot coverage are incompatible with the proposed development.  Thus, the application in no way facilitates or supports the viability of the required "detailed development proposal". 
With the required proposed "development area" split between City and County, how will applicable taxes be apportioned between City and County?

(The Lengthy Rail Yard Extends into Rural Fidalgo Island)
Does anyone believe that the rail storage and switching yard that is an essential part of the jobs creation proposed by this application can or will be blasted 700' or more into a steep bedrock hillside in incompatible County RRv zoning, because that is what the application proposes? 

(The Emergency Services to the Padilla Height Area Will Be Compromised)
Does anyone support the idea that ALL four of the local roads and associated emergency access--South March Point, Padilla Heights, Reservation and Stevenson Roads--will be blocked by slow moving, stopped, switching, assembling and disassembling trains many times a day, or perhaps continuously, for an unspecified number of jobs, because that is what this application proposes (see Appendix C)?  The County review of this application must consider under SEPA the probable impacts and viability of the rail activity inherent in the operations of the "detailed development proposal". 

(The City Is Engaging in Speculation)
SCC 14.08.020 (7)(c)(iii) states that for "Rezones....commercial and industrial zoning is not intended for speculative purposes."  The numerous statements by City staff, mayor and council that the application is not tied specifically to Tethys' development proposal, but will provide opportunity for any future industrial development show clearly the City's intent to engage in speculative rezoning in violation of the UGA amendment code. 
I trust again my observations and questions will assist the Council in making this application even more deserving than it already is.

Ross O. Barnes, Ph.D.




Certain operational conclusions can be drawn from scaling Tethys' site plan and adjacent areas.  I assume ALL local road/rail crossings except Hwy. 20 will be on the same grade since Tethys' required "detailed development proposal" and site plan show nothing else.  Any attempts at grade separation would be major and costly engineering and construction efforts that would need to be carefully evaluated for feasibility and impact on rail, road and local access and "who pays". 
Tethys' proposed rail service and staging yard extends about 2800' southwest from Stevenson Road with clear track lengths of individual siding tracks varying from about 1900' to 2700' as shown.  There is about 3500' of old track bed ROW from the south side of Stevenson Road to the south side of South March Point Road for a total length south of March Point Road of about 6300'. 
The standard double stack depressed well intermodal rail car is almost 77' long and newer standard high capacity 50' to 60' box cars vary from 58+' to 68' in length.  Thus, a standard 100 car unit train will vary from 7700' long for all intermodal, to about 6300' for mixed box cars PLUS multiple engines.  Such a train will need to be split into at least 3 sections on a similar number of rail yard tracks. 

A 100 car unit train backed south as far as possible will block all four local access roads--South March Point, Padilla, Reservation, and Stevenson Roads--and most probably block the March Point rail line as well.  At that point the train will be stopped and engaged in some sort of train decoupling/coupling action.  And all or some of these roads will continue to be blocked as the train splits itself into pieces or assembles itself from pieces on multiple siding tracks in the Tethys rail yard.  At Tethys' full production, this will happen 6 to 8 times a day (350 rail cars in, 350 rail cars out as stated by Tethys' economic study). 
To move rail cars from one rail yard track to another, they will have to be moved north across 3 roads to clear the siding switches and then reversed onto another track.   This will happen 2 times to move a different train section onto a given track such as a "loading" track.  Since each unit train is split into at least 3 sections, this rail switching/road blocking action will happen at least 4 times to process each incoming unit train, or 24 to 32 times a day.  And this activity is IN ADDITION to the 6 to 8 times a day in which inbound and outbound trains are split and reassembled using the SAME road blocking track section north from Stevenson Road. 
Further, the bottling plant building is only about 1300' long so a train segment on a loading track will need to be moved progressively north across 2 roads to bring all the rail cars into position at the loading bays of the building or the loading stations of the intermodal track.  This will happen 9 to 12 times a day to process the 3 to 4 trains a day at full production. 
NONE of this train switching activity occurs in "fast" mode.  Go to March Point sometime and observe the glacial pace at which the daily refinery train accomplishes its minimal train splitting/assembling and switching operations at the two refineries.  I think we ran out of road blocking hours in a day long before we ever got to the end of all this train switching activity necessary for the daily operation of the Tethys plant at full production.  If unit trains are split or assembled somewhere else before they enter or after they leave the Tethys facility, that doesn't help because there will be a proportionate increase in the number of trains entering and leaving and traveling on the March Point rail spur where they will also block all roads from Burlington to March Point and keep the rusty creaking Swinomish Channel rail bridge swinging to and fro all day and night. 
In order to switch train segments between siding tracks, one track will need to remain open to accommodate the switch and one track is allocated to inbound supply unloading, so the eight tracks proposed by Tethys will only accommodate two of the 3 to 4 unit trains per day proposed by Tethys.  Tethys proposed keeping at least a day’s supply of trains in close proximity as a minimal buffer to train schedule disruptions.  Where will the other trains be stored, presumably west of the mainline in Burlington?  Will additional track sidings not shown on the Tethys site plan need to be constructed elsewhere?  What will be their road traffic disruption impacts? 

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