The Port's New Plan
The Port made a key policy decision that centers on the ASB. The Port proposed changing the land use of the ASB from an upland to a marine environment. They wanted the ASB to become a marina.
This policy position meant that Alternative J was no longer acceptable. This meant that the ASB had to be cleaned up before it could be opened to the marine environment. In addition ASB could no longer be used as a location to place dredged sediment from the waterway and bay. GP had considered lots of other alternatives, including dredging and hauling the dredge spoils to a landfill. GP rejected those alternatives because they would cost over $100 million. GP went with a $23 million solution of dredging and placing dredged sediment in part of the ASB. The Port was faced with the same problem as GP. Only the problem was bigger and self-inflicted because they were adding to the area that needed a cleanup plan; while GP was facing cleanup of the bay and waterway, the Port was now facing cleanup of the bay, waterway and the ASB.
Facing the added costs associated with the need to cleanup the ASB, the Port crafted a new policy regarding the Federal channel in the waterway. Remember that when GP was considering options for cleaning up the Bay, the Port insisted GP dredge the waterway to the mandated depth of 38 feet as a Federal Waterway. Now that the Port was faced with the cleanup costs of dredging the waterway and having a marina instead of ready made disposal site, the Port made a second fundamental policy shift regarding the federal channel designation for the waterway. The Port along with the City of Bellingham's approval moved to have most of the waterway de-designated as a Federal channel. Deep draft boats would no longer be able to pull into the waterway. The Port and City began lobbying the U.S. Congress to remove the Federal Shipping lane status for the upper waterway. I have not researched this, but I suspect it is extremely unusual for a Port and a city served by a port to actively seek having a shipping channel removed from designation. That is why it takes an act of Congress.
The Port had decided that a federal shipping channel was not of much value anymore. Indeed because of the way Bellingham is hemmed in by mountains, the Port of Bellingham has never been a big shipping terminal relative to the huge ports in Portland, Tacoma, Seattle and Vancouver. With closure of GP the need for a shipping channel was greatly reduced at least in the near term. Further, with the channel no longer under federal standards, the Port would have greater flexibility in how the channel would be managed. The Port called the de-designated channel a "locally managed multipurpose channel".
With the Federal Channel no longer an issue, the amount of dredging was greatly reduced. The Port could now cap the contaminated areas with a layer of clean sediment. Capping is a much less expensive approach to cleanup. Another factor is that dredging is highly disruptive of the sediments and can cause short term harm when the sediments are disturbed. Previous testing had indicated that much of the contaminated sediments had been naturally capped by natural processes from the silt laden glacial melt water of the Nooksack River which empties into the bay. A few areas of dredging would still need to take place at locations where currents did not allow silt to settle on the sea floor and in areas where deep draft shipping could still take place. Just how thick the cap would need to be, and where dredging would take place would require a fair bit more detailed study and the port began those studies. The success of capping approaches are not without significant debate. Mercury can mobilize under changing oxygen and pH conditions on a very localized level; hence, capping approaches are not without significant risk and require lots of ongoing monitoring to ensure the cap approach is actually working.
Besides the Federal channel issue the Port needed to get the Department of Natural Resources to change the inner and outer harbor line boundary in order to have full control over most of the cleanup issues. That move was completed as well.
Besides the advantage of greatly reducing the costs, the Port could claim that by removing the federal Channel designation, they would have greater flexibility to do shoreline restoration work along the shoreline. Indeed the Port has completed a small scale version of a shoreline restoration project at another location along the shore of the bay. The possible shoreline restoration component had the potential for the Port to acquire some additional grant funding that would reduce the costs associated with capping.
By significantly de-designating the waterway, the Port greatly reduced the cleanup costs for the waterway and bay. Where GP would have been required to do a huge dredging project under Alternative J, the Port was able to avoid most of those dredging costs by shifting policy on the federal channel designation. However, the Port choice of turning the ASB into a marina added a major cleanup expense. The Port estimated that the cleanup of the Bay and waterway via primarily capping and the removal of and proper disposal of the ASB sediments would cost $44 million dollars. A fair bit more than GP's Alternative J which was estimated at $23 million.
With Alternative J, GP had made a corporate policy decision to remove permanently the contaminated sediment from the waterway and bay and placing that sediment in part of the ASB at an estimated cost of $23 million - a plan that was less expensive than the Port's plan and was supported by the Department of Fish and Wildlife and the Department of Natural Resources.
I made some modifications to the chart. In terms of contaminated sediments left as indicated by the blue line in the diagram, I do not think sediment removed from the waterway in alternatives 3 and 4 should be considered as left on site as the chart indicates. If they are placed in the ASB, they are no longer in the bay or waterway as the chart would indicate.
I altered the green line based on new information that indicates that the alternative plan that the port has proposed will not be $44 million but will in fact be nearly $100 million. That will be discussed in a future post.
Next: Ecology offers cleanup money for building a marina.
This policy position meant that Alternative J was no longer acceptable. This meant that the ASB had to be cleaned up before it could be opened to the marine environment. In addition ASB could no longer be used as a location to place dredged sediment from the waterway and bay. GP had considered lots of other alternatives, including dredging and hauling the dredge spoils to a landfill. GP rejected those alternatives because they would cost over $100 million. GP went with a $23 million solution of dredging and placing dredged sediment in part of the ASB. The Port was faced with the same problem as GP. Only the problem was bigger and self-inflicted because they were adding to the area that needed a cleanup plan; while GP was facing cleanup of the bay and waterway, the Port was now facing cleanup of the bay, waterway and the ASB.
Facing the added costs associated with the need to cleanup the ASB, the Port crafted a new policy regarding the Federal channel in the waterway. Remember that when GP was considering options for cleaning up the Bay, the Port insisted GP dredge the waterway to the mandated depth of 38 feet as a Federal Waterway. Now that the Port was faced with the cleanup costs of dredging the waterway and having a marina instead of ready made disposal site, the Port made a second fundamental policy shift regarding the federal channel designation for the waterway. The Port along with the City of Bellingham's approval moved to have most of the waterway de-designated as a Federal channel. Deep draft boats would no longer be able to pull into the waterway. The Port and City began lobbying the U.S. Congress to remove the Federal Shipping lane status for the upper waterway. I have not researched this, but I suspect it is extremely unusual for a Port and a city served by a port to actively seek having a shipping channel removed from designation. That is why it takes an act of Congress.
The Port had decided that a federal shipping channel was not of much value anymore. Indeed because of the way Bellingham is hemmed in by mountains, the Port of Bellingham has never been a big shipping terminal relative to the huge ports in Portland, Tacoma, Seattle and Vancouver. With closure of GP the need for a shipping channel was greatly reduced at least in the near term. Further, with the channel no longer under federal standards, the Port would have greater flexibility in how the channel would be managed. The Port called the de-designated channel a "locally managed multipurpose channel".
With the Federal Channel no longer an issue, the amount of dredging was greatly reduced. The Port could now cap the contaminated areas with a layer of clean sediment. Capping is a much less expensive approach to cleanup. Another factor is that dredging is highly disruptive of the sediments and can cause short term harm when the sediments are disturbed. Previous testing had indicated that much of the contaminated sediments had been naturally capped by natural processes from the silt laden glacial melt water of the Nooksack River which empties into the bay. A few areas of dredging would still need to take place at locations where currents did not allow silt to settle on the sea floor and in areas where deep draft shipping could still take place. Just how thick the cap would need to be, and where dredging would take place would require a fair bit more detailed study and the port began those studies. The success of capping approaches are not without significant debate. Mercury can mobilize under changing oxygen and pH conditions on a very localized level; hence, capping approaches are not without significant risk and require lots of ongoing monitoring to ensure the cap approach is actually working.
Besides the Federal channel issue the Port needed to get the Department of Natural Resources to change the inner and outer harbor line boundary in order to have full control over most of the cleanup issues. That move was completed as well.
Schematic of the Port's vision. Click to enlarge and note dredge areas and cap areas
The Port's vision of the cleanup and the resulting land use is pictured above. A far cry from the existing industrial paper mill site with a large water treatment lagoon and a waterway hemmed in by docks. Instead a large marina, parks along the southeast side of the waterway and some sort of amorphous development on the old mill site.
By significantly de-designating the waterway, the Port greatly reduced the cleanup costs for the waterway and bay. Where GP would have been required to do a huge dredging project under Alternative J, the Port was able to avoid most of those dredging costs by shifting policy on the federal channel designation. However, the Port choice of turning the ASB into a marina added a major cleanup expense. The Port estimated that the cleanup of the Bay and waterway via primarily capping and the removal of and proper disposal of the ASB sediments would cost $44 million dollars. A fair bit more than GP's Alternative J which was estimated at $23 million.
With Alternative J, GP had made a corporate policy decision to remove permanently the contaminated sediment from the waterway and bay and placing that sediment in part of the ASB at an estimated cost of $23 million - a plan that was less expensive than the Port's plan and was supported by the Department of Fish and Wildlife and the Department of Natural Resources.
The Port has indicated they would prefer to convert the lagoon to a marina and follow a different alternative to clean up the waterway and bay. A plan that would cap most of the contaminated sediment in the waterway and bay and convert an upland site that did not require cleanup into an an aquatic one that does with a price tag of at $44 million dollars for cleanup alone. This plan meant that far more contaminated sediments would be left be capped in a portion of the waterway and that sediment cleanup and removal from elsewhere in the waterway and other sites around the Bay will cost more due to disposal costs.
At the time the Port did what is called a disproportionate cost analysis of various cleanup alternatives. Ecology accepted this analysis and accepted the Port's preferred cleanup approach.
Disproportionate Cost Analysis Diagram
Dashed blue line, green line and red rectangle and red arrow are my modifications
I made some modifications to the chart. In terms of contaminated sediments left as indicated by the blue line in the diagram, I do not think sediment removed from the waterway in alternatives 3 and 4 should be considered as left on site as the chart indicates. If they are placed in the ASB, they are no longer in the bay or waterway as the chart would indicate.
I altered the green line based on new information that indicates that the alternative plan that the port has proposed will not be $44 million but will in fact be nearly $100 million. That will be discussed in a future post.
Next: Ecology offers cleanup money for building a marina.
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