Lummi Indian Business Council - EISs for the Proposed Gateway ...

All wetlands on the projects sites should be delineated, categorized, and function assessmentscompleted. All work should be confirmed by an independent third party to ensure accuracyand completeness. All avoidance, minimization, and compensatory mitigation measures shouldbe identified.13.3 Significant Unavoidable Adverse ImpactsThe construction and operation of the proposed projects will eliminate numerous wetlands andthe cultural and ecological functions that they provide.The elimination of wetlands by the two projects can preclude the ability and/or interfere withthe ability of the Lummi People to collect culturally significant plants and animals and toexercise their treaty rights to fish throughout their U&A – these impacts will result in significant,unavoidable, and unacceptable interference with our treaty rights and irreversible andirretrievable damage to our spiritual values if the proposed projects are approved.14 Potential Impact: Geologic Process – Littoral Drift14.1 Issue Definition/Rationale:The Sandy Point peninsula on the Lummi Indian Reservation is an accretion shoreform that is aproduct of littoral drift (i.e., the movement of sediment along the shoreline). The sedimentthat formed the Sandy Point peninsula originated from feeder bluffs near Point Whitehorn andother feeder bluffs to the south extending through the proposed project site. Littoral drift isdue to the action of breaking waves and currents along the shoreline. The construction andoperation of the proposed wharf and trestle and associated vessel traffic can be expected tomodify the wave angles, wave frequency, wave magnitudes, and potentially the currents alongthe shoreline. These modifications can in turn be expected to affect the littoral drift, which willaffect the deposition rates and quality of beach sediments along the shoreline and on theLummi Indian Reservation.14.2 Extent/Geographic Scale of EvaluationImmediate AreaLocal AreaThe impacts of the wharf, trestle, vessels moored at the facility, and vessel traffic on littoraldrift must be evaluated.Like all of the potential project impacts, the analysis of littoral drift impacts should specificallyconsider environmental justice and cumulative effects – including the effects of the existingpiers along the shoreline.14.3 Significant Unavoidable Adverse ImpactsThe construction and operation of the proposed Georgia Pacific Terminal project will interferewith littoral drift processes. This interference could reduce or alter the amount and quality ofLummi Nation Scoping CommentsCorps Project Ref. No. NWS‐2008‐260Corps Project Ref. No. NWS‐2011‐325January 201320