Sample Letter to DOE and the Port

Word Document – https://bellingham.savethewaterfront.org/shared-files/2512/?ABC-StormwaterPermit-LetterDOE-POB-review1V2.docx

  Copy and paste these emails:

ecyrewqianoi@ECY.WA.GOV; michaels@portofbellingham.com; bobbyb@portofbellingham.com; kenb@portofbellingham.com; smfleetwood@cob.org; robf@portofbellingham.com; BrianG@portofbellingham.com; adrienneh@portofbellingham.com; alicec@portofbellingham.com; benh@portofbellingham.com; alanb@portofbellingham.com [Please remember to sign your name below at the [Name] _________________________ Dear Department of Ecology and the Port of Bellingham, As a very concerned resident of Bellingham I am writing to urgently request a complete State Environmental Protection Act (SEPA) review of the Stormwater application for activities at the ABC Recycling Bulk Storage Facility (ARBSF), 735 Cornwall Avenue, Bellingham. A full SEPA review and new Environmental Impact Statement is required for the activity because:

• Of a Significant Process change, due to the addition of a new industrial activity, NAICS code 423930 (“RECYCLABLE MATERIAL MERCHANT WHOLESALERS”).
• This new industrial activity was not anticipated and is unreviewed by any prior Environmental Impact Statement.
  1. The activity is Heavy Industrial per the definition by the existing Waterfront EIS and by Bellingham Municipal Code, which was not anticipated by any previous EIS nor the Waterfront Sub-area Plan.
• Due to the unpermitted activity, prior to a Stormwater permit being issued (ISGP S2(A)(1)(b)(i)), that activity cannot be used as ‘existing discharges’ under RCW 43.21C.0383(1), for exemption from SEPA for the current Stormwater Permit application at the ARBSF.
• If an EIS is not completed for the Stormwater Permit application, the risk to the community and the local environment is extremely high, as the activity is Heavy Industrial in a light/marine industrial location. The ARBSF has been operating for 18 months without environmental review or the required Stormwater permitting.
• The Port and the DOE each have the obligation under Washington law to provide the community with this safeguard.

There is a risk of a SEPA not being completed due to the SEPA Lead Agency, the Port of Bellingham, declaring the activity “Exempt” from SEPA review. Any attempted exemption due to past unpermitted discharge (RCW 43.21C.0383(1)) at the Log Pond would be unlawful. Since the Summer of 2022, ABC Recycling has been storing metal at the Log Pond, where they were lawfully required to have their own stormwater coverage prior to beginning the activity. This unpermitted activity (per ISGP) is what they are using to bypass environmental review and is improper. As the Department of Ecology is empowered, and obligated, by the State Environmental Protection Act, even when not a Lead Agency, we call on them to require a full SEPA review that encompasses all aspects of the activity at the ARBSF, including air, water, and noise pollution, as focused on in the SEPA Checklist. Sincerely, [Name]