Friends of Pierce County

Draft of the New Buildable Lands document:

On Tuesday, October 30, the Puget Sound Clean Air Agency will be hosting a Public Hearing on their SEIS regarding Tacoma's proposed LNG facility.

CHB has a message for PSCAA:

Citizens for a Healthy Bay stands in opposition to the LNG facility. The information in the SEIS is alarming and the project poses unacceptable environmental risks to Tacoma. We urge PSCAA to update the SEIS, reissue it when it is complete and credible, and then re-open the public comment period.

Read our full letter to PSCAA stating our opposition below.

October 25, 2018

Puget Sound Clean Air Agency (PSCAA)
ATTN: Public Comment on DSEIS, PSE LNG Project
1904 Third Ave, Suite 105
Seattle, WA 98101
publiccomment@pscleanair.org

Hello,

Thank you for the information contained in the draft Supplemental Environmental Impact Statement (SEIS) for the Tacoma Liquefied Natural Gas Project (LNG project).

Citizens for a Healthy Bay (CHB) is a 28-year-old organization whose mission is to represent and engage people in the cleanup, restoration, and protection of Commencement Bay, its surrounding waters and natural habitat. We are a 501(c)3 nonprofit providing practical, solutions-based environmental leadership in the Puget Sound area. We work side-by-side with residents, businesses, and government to prevent and mitigate pollution and to make our community healthier and more vibrant.

We commented on the original draft EIS for this project in 2015, and had concerns that were addressed by Puget Sound Energy’s modifications to the project. After that, we were neutral on the LNG project. For the SEIS, CHB’s Policy and Technical Advisory Committee, staff, and board have reviewed information in light of recently published reports on climate change, and we are alarmed by the new information available on this project.

Within the SEIS is information that shows the LNG plant would have higher climate impacts than the no action alternative for the life of the project, and CHB finds that the LNG project poses unacceptable risks to Commencement Bay and the Tacoma environment. We also find important parts of the SEIS to be incomplete and misleading for the public. By unanimous vote of our board of directors, CHB opposes any further development of the LNG project. We urge PSCAA to revise and update the SEIS and re-release it for public input.

The most alarming information in the SEIS relates to the amount and impact of methane emissions during the life of the project. A key step to PSCAA’s conclusion that the LNG project is better than the no action alternative is evaluating the impacts of the methane emissions after 100 years, at a time when their potency would be significantly diminished. At 100 years, after the methane emissions have lost most of their potency, the SEIS says the emissions from the plant would only be 4 or 5% better than the no action alternative. However, because methane’s potency is much higher in the first few decades it is emitted, examining the impact of methane emissions on a shorter timeline would show the climate impact of the LNG plant to be much worse than the no action alternative.

Climate change is an immediate local and global concern. The 0.5 degrees Celsius increase we have already experienced has impacted our Puget Sound communities and environment. These changes affect the planet as a whole and impact Commencement Bay. Ocean acidification is one example of a global problem from climate change impacting the Puget Sound and Commencement Bay; ocean acidification is hurting shellfish and the people who eat or sell shellfish. We know that climate change impacts Puget Sound and Commencement Bay and that cutting greenhouse gas emissions now must be a global and local priority.

Recent reports about the progress of climate change indicate that the planet is experiencing rapid warming. Without drastic, unprecedented cuts to greenhouse gas emissions, the planet will warm by more than 1.5 degrees Celsius in the next few decades, and potentially 4 degrees Celsius by 2100. The impact of changes beyond 1.5 degrees Celsius is unacceptable to us. It will massively impact the Puget Sound fishery and ecosystem, and change our communities and economy in ways we cannot yet imagine. To prevent more than 1.5 degrees warming, scientists report that global greenhouse gas emissions must fall to zero by 2050 and then go negative. Cutting greenhouse gas emissions to zero by 2050 is a massive task, and will take drastic, unprecedented measures to accomplish.

With the scale of change that needs to happen in mind, the LNG project is a step in exactly the wrong direction. Increasing methane emissions, which are 86 times more potent than carbon dioxide as a greenhouse gas, in the next few decades is the opposite of what we should be doing. This LNG project would release hundreds of thousands of tons of a potent greenhouse gas at the exact time when we must drastically reduce greenhouse gas emissions. It is a bad idea and should not proceed.

We are also extremely concerned that this SEIS is incomplete and relies on outdated, inaccurate information and is misleading for the public. A critical table in the analysis appendix, Table C.1. uses placeholder figures rather than actual data. Although we have requested the accurate data for this table, it has not been provided.

In the SEIS, the global warming potential of methane and nitrous oxide is assessed based on an outdated standard (AR4) from 2007. The newest standard, AR5, shows that methane has a greater impact on climate change than previously thought. Bizarrely, the SEIS discusses the updated standard and includes the figures for it in its report, but then chooses to use the outdated standard from 2007 for its analysis.

Additionally, the conclusions in the SEIS rely heavily on the assertion from PSE that the plant will only use natural gas from British Columbia. The SEIS fails to provide any analysis or discussion of the potential greenhouse gas emissions if the plant’s natural gas comes from another source, such as the United States or other Canadian provinces. As a result, it is impossible to assess the true impact of the project in the likely scenario that the natural gas will be sourced from multiple locations. The SEIS provides an incomplete picture of greenhouse gas impacts because it insisted on an analysis restricted to a certain geography.

Further, the SEIS fails to indicate how the LNG plant scenario compares to the no action alternative in terms of global warming impacts during the 40 year life of the project. The SEIS relies on a 100-year timescale to assess greenhouse gas emissions even though the life of the plant is only anticipated to be 40 years. The public deserves to know the true impact of the project during its lifespan, or, at least, during a timeframe that is relevant to the important changes that need to be made to address climate change. Why have an SEIS that is scoped to explore the greenhouse impacts of a project and then not disclose the greenhouse impacts in a relevant way?

Finally, we are concerned about the exclusion of tribal communities at a critical stage in the process. The City of Tacoma had a legal responsibility to meaningfully involve the Puyallup Tribe of Indians in consultation at the early stages of this project. CHB did an open records request earlier in 2018, and found that the City did not have records to show it followed the meaningful consultation requirements under the Land Claims Settlement Act. Please do not perpetuate the illegal denial of meaningful consultation with the Puyallup Tribe about actions that impact tribal resources. Take the time to address the flaws in this process. Consult with the Tribe about the information in the SEIS and the significant risks to the Tribe’s resources. Then, please revise and update the SEIS with full and complete information, and to re-release it to the public for public comment.

In its current state, the SEIS is incomplete, inaccurate and unreliable. We stand in opposition to this project. We encourage you to pause this process and reissue a complete SEIS on which the public can comment.

Thank you for your consideration. Please do not hesitate to contact me with any questions about this letter.

Sincerely,

Melissa Malott
Executive Director, Citizens for a Healthy Bay
mmalott@healthybay.org, (253) 383-2429

CC: Victoria Woodards, City of Tacoma Mayor
Members of the City of Tacoma City Council
Members of the Puyallup Tribe of Indians Tribal Council
Members of the Puget Sound Clean Air Agency Board of Directors
Jay Inslee, Governor of Washington State
Rep. Jake Fey, Washington State House of Representatives
Rep. Laurie Jinkins, Washington State House of Representatives
Sen. Jeannie Darnielle, Washington State Senate
Hartleigh Caine, TOTE Maritime Alaska

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Citizens for a Healthy Bay is a non-profit organization that engages people to clean up, restore and protect Commencement Bay, its surrounding waters and natural habitat.

Hello All:

I had a busy week catching up on all the other business of the reserves, and want to send out a post event Thank You!

To everyone that pitched in preparing for and hosting last Saturday to make it a success…

Of course there are lots of things to improve on, but I’m just ecstatic that we pulled it off (and families came, etc). We have the Kapowsin Half-Millennium birthday card displayed here at the office (thanks to Bob Walter for making it). Russ Blount is not in the photo because he held down the fort at the off-site parking in his field. Thanks Russ!

A few folks have emailed that we should schedule a work party. I am not going to be the organizer this time – I have other events and project to focus on this summer, but maybe by September I will think about it. You can reply all to start a discussion on what needs to be done and who might want to do it, and when.

Also, a meeting to de-brief while we still remember, and consider next steps was suggested; so I will test the waters of August to see if you will be here and can meet.

PLEASE reply if you are available all or any of these dates: August 9, 16, or 23. I sent an email to the fire station inquiring about room availability.

Our invasive species team is available for loosestrife and yellow iris work at the lake on July 30-31 so I’ll be out there at that time.

Thanks again, it was really fun.

Birdie Davenport

Aquatic Reserves Program Manager

Aquatic Resources Division

360-902-1073

Looking for all Pierce County wetlands

In Washington, the existing statewide wetland maps (National Wetlands Inventory [NWI] maps) are out of date and inaccurate in many locations. They are based on imagery and data from the 1980s and do not reflect current wetland location and extent.

Additionally, wetlands are missing from the NWI maps. These errors of omission have been recorded to be as high as 50% in some areas, and may be as high as 90% in some forested areas. Inaccuracies and errors of omission are due in part to the difficulty of photo-interpreting certain land cover types. Also, many wetlands on agricultural lands were not mapped.

The NWI classified wetlands to identify wetland habitat types. It lacks abiotic information such as landscape position, landform, and water flow path, which can be used to predict functions and, in combination with land uses, wetland condition. To complete this project, the University of Washington will use remote sensing data sources, such as LiDAR, high-resolution aerial imagery, Landsat imagery, digital elevation data, hydrography, and updated soil maps provide an opportunity to address these known shortcomings. Moreover, recent developments in automated remote sensing technologies allow for more efficient coverage of large areas.

An improved, statewide map of wetland location and type is critical to the ability of local governments to protect wetlands. Under the Growth Management and Shoreline Management Acts, local governments play a critical role in wetland protection and management. They do this through comprehensive planning, zoning, and permit review. Planners and permit reviewers rely on existing NWI maps for these processes. A few local jurisdictions have conducted their own wetland inventories and improved their maps, but these are limited due to lack of resources, and none have predicted functions and conditions of wetlands. This leaves many local governments with inadequate maps and information on local wetlands, and the state with uneven coverage.

This project will improve the ability to more efficiently and accurately identify the location, size, and type of wetland resource. available as a publicly accessible, web-based map. Information about the maps, and any analyses using the data, will be disseminated through articles and presentations to state and federal agencies, and local governments and planners.

Source: https://portal.nifa.usda.gov/web/crisprojectpages/1013138-washington-wetland-mapping.html

From Pierce County:

The Regulation Roadmap for Agriculture is now posted on the Pierce County Farming website: https://www.co.pierce.wa.us/3422/Getting-Started. The Regulation Roadmap was developed to assist producers to identify possible permits and licenses needed to produce and sell farm products. It also identifies the primary regulatory agencies dealing with farm products.

The Regulation Roadmap for Agriculture project is a partnership with the Agriculture Community of Interest, Pierce County Agriculture Program and Tacoma Pierce Health Department.

Diane Marcus-Jones | Senior Planner | Pierce County Planning and Public Works| (253)798-2616 |

2401 South 35^th Street, Room 175, Tacoma, WA, 98409-7490 | dmarcus@co.pierce.wa.us | www.co.pierce.wa.us/pals I www.piercecountywa.org/farming

NEWS RELEASE
November 2, 2017

MEDIA CONTACT: Cathy Cochrane, 360.790.7958, cathy.cochrane@psp.wa.gov

2017 State of the Sound report shows greater commitment needed to protect Puget Sound ecosystem

The 2017 State of the Sound report, released this week, shows that Puget Sound recovery efforts are effective, but at the current level of effort and investment, many 2020 recovery targets will not be met.

“The health, wellbeing and vitality of the people of Washington are all closely tied to the health and wellbeing of Puget Sound. The State of the Sound report details the enormous and growing pressures on our ecosystem and the toll they are taking—including rapid population growth, ocean acidification, storm water pollution, and climate change,” said Gov. Jay Inslee. “This report shows how we can do better in applying the ingenuity and values of our state to these crucial problems.”

The report summarizes the status of recovery targets and highlights how innovation and new technology are being used to restore beach habitat, build new partnerships to open shellfish beds, and clean pollution from stormwater. Nonetheless, the investments to date have been a fraction of what is needed to reach recovery targets. The report includes recommendations from the Puget Sound Partnership’s Leadership Council, Science Panel, and Executive Director for immediate and long-term action.

Two of the recovery targets assessed involve the Southern Resident orca and Puget Sound Chinook salmon populations. “We are at a particularly critical juncture now, with the future of Southern Resident orcas and their main food source—Chinook salmon—so imperiled,” said Sheida Sahandy, Executive Director of the Puget Sound Partnership. “We can see that our investments are working, but the scale is inadequate to the challenge. Much greater commitment is needed, from a much larger swath of the community and with a greater focus on innovation.”

The report also highlights how management approaches have changed to improve the collective recovery effort. “We can look to the great work of our many partners, including the region’s tribes, to demonstrate the types of efforts that need to be supported and expanded,” said Ms. Sahandy.

About the State of the Sound

Required by state law, the State of the Sound provides data and information that can help guide decision makers in allocating resources to programs, policies, and funding efforts that can make progress in restoring Puget Sound. This report reflects the work accomplished by hundreds of groups throughout the Puget Sound region, including governments, tribes, nonprofits, communities, scientists, and businesses. For more information, go to www.psp.wa.gov/sos.

About the Puget Sound Partnership

The Puget Sound Partnership is the state agency formed to lead the region’s collective effort to restore and protect Puget Sound. Working with hundreds of governments, tribes, scientists, businesses, and nonprofits, the Partnership mobilizes partner action around a common agenda, advances Sound investments, and tracks progress to optimize recovery.

For more information, go to www.psp.wa.gov.

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2017 State of the Sound report shows greater commitment needed to protect Puget Sound ecosystem

About the State of the Sound

About the Puget Sound Partnership