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Bellingham Comments from Digital Recorder - EISs for the Proposed ...

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GATEWAY PACIFIC TERMINAL EIS SCOPING HEARING VOL. II<br />

COURT REPORTER: BETH DRUMMOND PROCEEDING DATE: October 27, 2012<br />

Page 151<br />

1 freshwater impacts.<br />

2 There's been a lot of focus on marine impacts.<br />

3 But if you look at <strong>the</strong> mitigation plan that's been<br />

4 submitted, SSA's only proposing to address aquatic impacts.<br />

5 That leaves a lot of terrestrial impacts that are not being<br />

6 addressed.<br />

7 There's a number of priority species,<br />

8 particularly birds, and a number of priority habitats that<br />

9 won't be addressed. Additionally, <strong>the</strong>y're requesting that<br />

10 <strong>the</strong>y do an off-site mediation, yet <strong>the</strong>y're not citing to and<br />

11 complying with <strong>the</strong> Whatcom County code with regards to<br />

12 off-site mitigation, which requires that off-site mitigation<br />

13 be improved. It has to enhance biological function and<br />

14 provide greater likeness to be assessed.<br />

15 I don't see any of that being done here.<br />

16 Additionally, <strong>the</strong>y don't have on paper enough<br />

17 mitigation points to even go <strong>for</strong>ward with <strong>the</strong> project.<br />

18 They're -- even with <strong>the</strong> new property <strong>the</strong>y<br />

19 purchased <strong>for</strong> off-site, <strong>the</strong>y're still 30 credits short,<br />

20 which means that <strong>the</strong>y're proposing ei<strong>the</strong>r an in-lieu-of-fee<br />

21 program or <strong>the</strong> non-mitigation bank.<br />

22 One program, in particular, doesn't exist. The<br />

23 o<strong>the</strong>r of which, <strong>the</strong> people who have come out and run <strong>the</strong><br />

24 program, have posted this project.<br />

25 They're also talking about economy, trades, which

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